ML20126K498
| ML20126K498 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1992 |
| From: | Alexander Adams Office of Nuclear Reactor Regulation |
| To: | Raby T NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| References | |
| NUDOCS 9301070150 | |
| Download: ML20126K498 (6) | |
Text
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December 31, 1992 Mr. Tawfik H. Raby Chairman, N-17 Building 235, Room A141 National Institute of Standards and Technology Gaithersburg, Maryland 20899
Dear Mr. Raby:
SUBJECT:
ANS-15.7 N-17 COMMITTEE BALLOT Enclosed is my ballot for ANS-15.7 "Research Reactor Site Evaluation "
I have voted " approved with comments" and have included the required comments, furthermore, I have reviewcd the Scope, and have no objections, if you have any questions concerning this ballot, please contact me at
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301-504-1127.
Sincerely, Alexander Adams, gned by -
- original si Jr.
Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation
Enclosures:
1.
Ballot 2.
Comments DISTRIBUTION: [ANS15.7) (A. Adams diskette)
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December 31, 1992 Mr. Tawfik M. Raby Chairman, N-17 Building 235, Room A141 National Institute of Standards and Technology Gaithersburg, Maryland 20899
Dear Mr. Raby:
SUBJECT:
ANS-15.7 N-17 COMMITTEE BALLOT Enclosed is my ballot for ANS-15.7 "Research Reactor Site Evaluation."
I have voted " approved with comments" and have included the required comments, furthermore, I have reviewed the Scope, and have no objections.
If you have any questions concerning this ballot, please contact me at 301-504-1127.
Sincerely, 00 Alexander Adams, Jr.
Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation
Enclosures:
1.
Ballot 2.
Comments l
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4 ANSI N 17 COMMITTEE BALLOT DOCUMENT: ANS-15.7 "Research Reactor site Evaluation" (Revision)
DALLOT DUE: December 31, 1992 Approved y
Approved with Comments Not Approved Not Voting Comments:
(NOTE all ' Approved with Comments' and 'Not Approved' ballots must include comments.
See attached.
4*M' Retum ballot to:
Signature (/-
Alexander Adams JV..
Tawfik M. Raby USNRC Chairman, N 17 Reptesenting-NationalInstitute of Standards & Technology Building 235. Room A141 December 31,;1992 Gaithersburg, MD 20099 Date t'
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COMMENTS ON ANS-15.7 RESEARCH REACTOR SITE EVALUATION 1.
Section 2., definitions, boundaries and zones, operations boundary.
The definition discusses this area having evacuation procedures.
This is an emergency planning requirement and should not directly bear on site selection.
2.
Section 2., definitions, boundaries ar.d zenes, rural zone, and urban boundary. We recommend that any reference to an evacuation time be deleted. Applicailon of the standard does not appear to require use of i
the evacuation times, 3.
Section 2., definitions, capable fault. The term " capable fault" which has been borrowed from Appendix A to 10 CFR Part 100 is proposed to be replaced with the term " capable tectonic source" in the aroposed Appendix B to 10 CFR Part 100. The proposed rule changes were pu)11shed for public comment in the FEDERAL REGISTER on October 20, 1992. Associated draft regulatory guides were released for public comment in the fEDfRAL REGISTER on November 25, 1992.
The proposed revision would update the seismic siting and engineering criteria for new power plants based on advancements in the earth sciences and experience gained in the application of the procedures and methods used in the current regulations. These changes should be reviewed to determine if they are applicable to this standard.
4.
Section 2., definitions, research reactua. Although this is the standard definition of research reector used in,A standards, for the case of this standard it should be clear that research reactors do not include testing facilities or test reactors. Test reactors must use 10 CFR Part 100 for-siting criteria.
5.
Section 2., definitions, total effective dose equivalent.
Subsequent to the publishing of revised 10 CFR Part 20 in the FEDERAL REGISTER as an effective rule, the NRC staff is reviewing certain applicable regulations (Appendices A and I to 10 CFR Part 50 and paragraphs 100.11 of 10 CFR Part 100) to determine if the referenced' individual doses in thest regulations should be recast in terms of TEDE.
The staff is planning to use this review as a basis for evaluating the need for future changes to
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regulatory guides and the standard review plan associated with these potential rule changes. Although these regulations do not apply to research reactors, we believe that the use of the TEDE concept for
- research reactor site evaluation is premature until the NRC completes its review and evaluation.
6.
Section 3.1, population.
This section states-that the criteria listed in Sections 4, 5, and 6 are an acceptable method for dose calculations;.-
actual data are to be preferred where available. What actual data does this refer to and how should the data be acquired if it is for a site under consideration?
7.
Section 3.1.1. TEDE, persons within operations boundary.
This section and the note to this section introduce emergency planning and escape. time.
See comment 2 above.
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Sections 3.1.3 and 3.1.4, TEDE.
It-is not clear what the distinction is between the urban zone and thi rural zone, if the distinction is that a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exposure period is to be assumed for persons in the rural zone, while a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> exposure is to be assumed for persons beyond the urban boundary, then this should be clearly stated in the standard.
9.
Section 3.2, Geology / Seismology. A basis should be given. for siting a research reactor at least 400 meters from the surface location of a known capable fault.
In 3.2 b., replace " intensity V" with " intensity Mercalli V" for improved clarity.
Define design basis-vibratory ground motion.
- 10. Section 3.4, Meteorology. Replace " dispersion of radioactivity" with dispersion of radioactive material."
- 11. Section 3.5.3 b.,
air traffic.
The last line of this section discusses -
i release of radioactivity. However, Section 3.-1 discusses exposures. This appears to be conflicting.
- 12. Section 4, criteria for downwind concentration.. This section describes concentration (x) calculation methodologies for different conditions.
However, this version of ANS-15.7 does not describe dose calculation methodologies nor guide the reader to obtain aopropriate dose calculation methodologiesforTEDE,dosecommitment'andothers. Guidelines to calculate doses (e.g., doses from the different pathways for iodine release, beta and gamma air doses from noblo gases) should be added or-referenced clearly in the main body of the text, or the terms related to-dose in the foreword, Section 2, and Section 3 should be deleted from the text.
- 13. In Section 4 the term radioactivity should be replaced with radioactive material when referring to disperr. ion.
In the titles for Sections 4.1 and 4.2 diffusion should be replaced with dispersion.
In the equations, o, should be defined as a dispersion factor instead of standard. deviation, in the equations, C, should be defined as a building _ shape-factor instead of an arbitrary constant.
- 14. Section 5, criteria for radionuclide release from the reactor building.
In line 2, experiment is misspelled.-
- 15. Section 5. -The amounts, release timing, and chemical compositions of-fission products-(source term) immediately available for leakage-followings a design basis accident are similar to those shown in Regulatory Guides-1.3 and 1.4, and in TID-14844.
In light of the publication of NUREG-1465,.
" Accident Source Terms for Light-Water Nuclear Power Plants" for' comment,.
the ANS Committee should consider. reviewing the source term specified11n the NUREG for _ future updating of the standard.-
16 ' A difference between arriving at source terms using Regulatory Guides 1.3 and 1.4, and T10-14844 and the standard is the fact that the regulatory guide method uses a source term based on the percentage of noble gases and iodine of the full power operation of the core where the-standard is based
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Because the analyst has latitude in the choice of a design basis accident, we recommend that a statement similar to that below be added to the standard:
A design basis accident for use in evaluating the site shall be selected and described.. The selection of a design basis accident should be based upon a thorough knowladge of the operational modes, potential vulnerabilities and release characteristics-of the research reactor, fuel elements, and any experiments contemplated.
The design basis accident selected should be among the most severe analyzed, in terms of radiological consequences, and one which leads to a quantity of fission products or radioactive material released into the reactor building that is not likely to be exceeded, based upon a realistic understanding of the reactor and the experiments contemplated.
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