ML20115E667

Forwards Proposed Modified Emergency Plan,Including Strikethrough Format (Deletion) or Bold Format (Additions) Version & Version W/Changes Incorporated in Text

ML20115E667
Person / Time
Site:	Dow Chemical Company
Issue date:	07/08/1996
From:	Rigot W DOW CHEMICAL CO.
To:	Alexander Adams NRC (Affiliation Not Assigned)
Shared Package
ML20115E670	List: ML20115E667
References
NUDOCS 9607160174
Download: ML20115E667 (7)

Text

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The Dow Chemical Company Mdand, Michgan 48667 July 8,1996 Mr. Alexander Adams, Jr., Senior Project Manager Non-Power Reactors and Decommissioning Projects Directorate Division of Project Support Office of Nuclear Reactor Regulation DeuMr. Adams Enclosed is a proposed modified emergency plan for The Dow TRIGA Reactor, Facility Operatir.g License No. R-108. I feel the changes are significant and we will not apply the proposud changes until approval by US NRC has been made. Enclosed are two versions of tne plan. One version has all changes highlighted; either in the form of strikethrsegh format (deletions) or bold format (additions); and an explanation for each change. One version has all changes incorporated into the text of the plan. If you have any questions regarding these proposed changes, please contact me at (517) 636-6584.

Regards c

Ward L. Rigot Reactor Supervisor Dow TRIGA Research Reactor Dow Chemical Company G 9607160174 960700 PDR F

ADOCK 05000264 PDR TAMMY A. ECKERD NOTARY PUBLic, BAY COUNTY, MN

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. .w Page 1: a-of a : This is a correction of a misplaced word, "a".

Sciences: The Department is now known as the Analytical Sciences Laboratory.

raGeiger-Mueller4tector+ quipped-witheneir-pumpend paper filter;: This deletion is intended to improve the clarity of this sentence.

a Geiger-Mueller detector equipped with an air pump and paper filter,:

This insertion is intended to provide information about the Continuous Air Monitor.

calibrated to provide dose rate information: This insertion is intended to provide information about the Area Monitor.

up40 not exceeding: This change is intended to clarify the sentence; the reactor is not necessarily operated at power levels up to 300 kilowatts each day.

Page 2: Facilliv Director. A manager within the organization of the Analytical Sciences Department who has line management responsibility for members of the reactor staff. This new definition is designed to identify a person with specific responsibilities.

reactoredministrator- Facility Director: There is no person or function labelled

" reactor administrator"; a Facility Director is defined.

normal: This addition is intended to reflect the differences between the normal management organization and the emergency management organization.

Page 3: administrator supervisor: This change is intended to clarify the identity of the person who will initiate emergency activities; there is no reactor administrator, willwankw>f: Delete n ference to the specific rank of the member of management as this changes from time to time.

to: a grammatical change responsible for the administration of all Dow Midland location activities involving the use of radioactive materials and radiation sources including assurance of compliance with United States Nuclear Regulatory Commission (NRC) regulations. a group of knowledgeable persons-from-severalereasef-The-DowC-hemicalfompany-whielnietermines4he policiesendsafety-standards +nellsiattersemeerning+adiological+afety-at4he Midland 4ocation-andoversees4he-facilities-whichetilizefadiationand+adioactive materials: : The Radiation Safety Committee has defined itself thus.

Page 4: Safety-Goordinator-and4heRe-Entry-Teamef4he-Persons responsible for the normal Analytical Sciences Laboratory safety program Inorganie-Analysis Grouprwhieh-is4toused-: Management and organizational changes have eliminated the specific functions of Safety Coordinator and the Re-Entry team but the safety program remains. Persons working in this building are no longer an independent group within the Analytical Sciences Laboratory.

Sciences: See above.

l and-will4iaveponab'e+quipment-for4akingeir-samples: the Michigan Division ,

Industrial hygiene group does not have equipment for taking air samples. I 1

active \ working \em plan \ changes 949426 page i of vi

i l

i Page 5: or-higher-classdemergeney: There is no credible way for this facility to experience an  ;

emergency classified higher than " Notification of Unusual Event".

Page 6: salaried: All Senior Reactor Operators, salaried and bargained-for, are included in the )

line of succession. l hi+any: This is intended to remove references to gender.

He-and: This is intended to remove references to gender.

Page 7: Re-entry into a previously evacuated area: This is the addition of a previously missing heading

[ radiological hazard or a potential radiological hazard. or cau= damages :c the facility cr the :;:aff which in g=:ral do ac: include re!:=e:; of+ignific=: q=ntities of radioactive ma:cria! nor ';ignific=: risk 4c the general public. Th:2 emergencies will have effects which tend :c be confined c the facility =d whichcan be corrected with the available persc=c! =d equipment.

Emergency situations within this classification would include breaches of =curi:y, tornado warning:;, prolcaged fireein *- ---^'- '- ""y, ]: The emergency classification is changed to include only radiological hazards; other hazards mentioned in the original Emergency Plan do not credibly lead to radiological hazards at this small research reactor.

snehundary Dow fence line: This is intended to identify a specific boundary. l A 1. 4

[c,\P. -.

The-Alert-class-includes :hc= even:s which+culd, through a combi = tion of failure';

of-fuel <4 adding and+xperiments, lead to a relea= cf radicactive material which could exceed-50 M"C a:4he :,ite be=dary, avemged ever 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,75 mrem whole bcdy dose-accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,-241-mrem /hr for I hour whole body de';e ra:e, cr 100 mrem-iodine dese. This class includes catastrophic-natura! =d == made events, such as tornado or uncontrolled re!== cf toxic gax';, which would =verely injure the inhabitants: There are no credible circumstances which could lead to this level of classification at this research reactor.

active \ working \em plan \ changes 949426

. page il of vi

O 2 Page 8: Alert: There is no credible combination of circumstances that could lead to an emergency classified as Alert at this facility.

9 A detailed examination of accidents is presented by S. C. Hawley and

, R. L. Kathren in " Credible Accident Analyses for TRIGA and TRIGA-Fueled Reactors" (NUREG/CR-2387 PNL-4028, April 1982). : This j reference is added to provide more information about the evaluation of hazards.  !

over4he-past-16-years since 1967: This change is intended to reflect the passing of time.

i Page 9: which is sufficiently lower than that expected from a release from a 1

damaged fuel element (see July 1967) that any such event would surely be detected. At the same time this alarm level is set sufficienmtly higher than the maximum observed natural background that no alarms due to natural background are expected about-three-times the maximum-observed n atural-backgroundrIf-a-release-of-radioactive-materials-is-suspeeted;-either-by-an ,

alarm-from-the-Gontinuous-Air-Monitor-or-the-Area-Moniterr eir-sampling-will-be l initiated 4edetermine4he-magnitudeef4he-release and4hus4he<lassification-levelef4he  !

emergency- l The-air-sampling-will-be-conducted to allow an estimate +f4he amount-of-iodine-141 andether-materials-released-Thisavill-consist +f-a-10-minute 40-cubic feet per minute sampleef-airmolleeted-through-a-1-inch-TEDA+harcoal411ter-eartridgeende-particulate prefilter--The-total-activity +naherharcoal-cartridge-is-assumed 4o-be-iodine 131 A G-M-pancakedetector4vith a 2% efficieney4 vill-bessed4o-monitor 4he-radioactivity-on the-charcoal-filter-The models-and-valuesfound-in4GRP-2r10-and-304mve been used to-calculate-a-count-rate-corresponding 4e+-100-mrem 4otal4hyrmd-dese, assuming-a 4-hour-exposure-ande-breathing-rateef-204iters-per-minute-Sueh+n-exposure-could only-be-possible-if-the-total-release-fraction-equilibrium-inventory of 21 mGi-tetal iodines +feachef-24-TRIGA-fuel +1ementsavas-released 4o4he-atmosphere-withinene hour-(Sutton's-formula-for-dispersion)4aking-no+reditfor-any-retentionef-iodine-in4he poolorfor-any-plate-out- i A-portable ionehamber-will-bessed4o-evaluate 4he-possible-wholebody-dose-at4he-site boundary,  ;

i active \ working \em plan \ changes 949426 page iii of vi

l The reactor-room area meni:cr-fa O M de:ce:cr) ::: m: :c alarm a: 2 mrem /hr. ' This corre:;pcads to approxima::!y 3 x 10ipGi/mL, the :c:a! re!:ase fraction inventory of noble ga=s at-the equilibrium of one of the TRICA fuel elements, as:;uming perfect mixing-itHhe'-reaetor-room.--- U;ing Sutton':; formula for dispersion this amcun: cf nob!c gas would g:ve a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> average concentratien-of approximately 0.02 MM' at the neares: ';ite boundary in slightly :; table wind conditicas.: These changes have been made as a result of a review of the design basis accident (damage of one fuel element containing the maximum burden of radioactive fission products and the subsequent release of a fixed fraction of these radioactive fission fragments) as follows:

The Dow'TRIGA research reactor achieved initial criticality 6 July 1967. On 10 July 1967 the continuous air monitor alarmed after the very first operation at 100 kilowatts.

Testing indicated the presence of a leaking fuel element in the F (outer) ring which was identified and removed from the core. This event had effects far lower than the design basis accident in that the fuel element was in the outer ring (lowest fission activity) and the reactor had been operated for only a few minutes before the alarm, not the many hours necessary to approach the maximum fission product inventory.

During the testing period in 1967 the continuous air monitor background (radon daughters in the air) was about 100 counts per minute; when the reactor was operated at 100 kilowatts the monitor usually alarmed at 1000 counts per minute within about 75 seconds and leveled off at 4000-4500 counts per minute. If the present continuous air i monitor were no more sensitive that the unit used in 1967 we would expect a leaking fuel element located at the lowest neutron flux, at far from the maximum inventory of..

radioactive fission products, to register more than 10,000 counts per minute on the continuous air monitor during operation at 240 kikowatts.

For comparison the normal background from radon daughters on particulates in the air ranges from about 30-40 counts per minute on a clean day (early Spring in Midland or a north-easterly wind) to some 400-500 counts per minute (late summer in Midland or a temperature inversion).

Thus the choice of the alarm setpoint for the continuous air monitor (4000 counts per minute) is well above the normal background levels and well below the levels expected from the design basis accident.

l l

active \ working \em plan \ changes 949426 page iv of vi i

l From Table 4 (Gaseous Fission Product Activity in the TRIGA Element Containing the i Greatest Activity Following Operation at 365 MWD) of Hawley and Kathren we l choose those noble gas isotopes likely to be present after a three-hour operation, l ignoring those with half-lives too long (days or years) or too short (32 seconds). This l includes the krypton isotopes 85m,87,88, and 89, and xenon isotopes 135 and 135m.

We correct the saturation activity values for the 300-kilowatt maximum operating power of the Dow TRIGA reactor and the 78 fuel elements (rather than 50, as in Hawley and Kathren), apply the calculation for a three-hour operation, apply a low-temperature release fraction of 1.5E-5 proposed by Foushee and Peters, and assume that all of these materials are released from the water at the top of the pool as noble gases. The result is  !

that we would expect the release of about 10 millicuries of noble gases, of which more l than halfis due to the 3.2-minute krypton-89 which decays to 15-minute rubidium-89, following damage of the cladding of one fuel element in the B or C rings.

The air exhaust rate in the reactor room is 1700 cubic feet per minute, which is equivilant to 6.9E10 milliliters / day. The release of radioactive materials as above would result in a concentration of about 1.4E-7 microCuries/ milliliter, averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, from the exhaust stack at the east side of the reactor room. The nearest Dow

']

fenceline is about 160 feet west of this stack, some 40 feet west of the western-most J portion of 1602 Building.

This quantity is not sufficient to warrant declaration of an emergency classified as

" Notification of Unusual Event".

In such a case, however, an emergency classified as " Notice of Unusual Event" would be declared because of the fuel damage.

Page 10: [G-M-Pancake-TEDA Charecal 2000 cpm 100 mrem dyroid (Site-Boundary) above baekground dose is pessible.

l Portable-lon-Chamber 0.6 mrem /hr 15 mrem /whole body (Site-Boundary) dese/24 hours is I

pessible.

3 mrem //hr 75-mrem'whele Scdy desel 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is-pessible]:  ;

There is no credible way for these Emergency Action Levels to be attained at this facility.

5 7: The number of siren switches has been increased.

active \ working \em plan \ changes 949426 page v of vi

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1 Page11: calibrated-weekly-wititeknowraource tested daily and calibrated semi-annually: The calibration and testing procedures have been changed.

Page 12: vacation 4ists: There is no longer a vacation list that can be used for accounting for j persons during emergencies.

l re-entry 4eantstaff: There is no re-entrj team; the reactor staff performs this function.. I twoportable+, elf-contained breathing-kits 4md: The breathing apparatus has been j removed from the laboratory; the Dow fire department people arrive equipped with this i type of equipment paper..... boots: The coveralls are a lightweight impermeable composite material, and the foot coverings are connected.

Page 13: (Li): Lithium-drifted detectors are no longer used. l l

LarkinLatumd-17021803: Larkin and 1702 facilities have closed; equipment is I available at 1803 Building Page 14: five: seven: The number of siren switches has been increased.

Page 15: re-entry 4eam stali: There is no longer a re-entry team; see above. l i

Page 16: annual biennial: The requalification program is now on a biennial basis.

biennial annual: Training is now a part of the annual hypothetical exercises, fire 4ighting-: Most emergency scenarios do not include fires.

annual: The requalification program is now on a biennial schedule.

l active \ working \em plan \ changes 949426 page vi of vi