ML20128D510

Forwards Set of Amends to Original Recovery Plan Submitted by Reed College to NRC on 920317,per P Qualls Request

ML20128D510
Person / Time
Site:	Reed College
Issue date:	03/30/1992
From:	Pollock M REED, J.G.
To:	Martin J NRC
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ML20126M891	List: ML20126M888 ML20128D402 ML20128D477 ML20128D496 ML20128D510
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FOIA-92-35 NUDOCS 9212070294
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RBBD C0LLEGE 'Portlana', Oregon ornt.stos Of ACIO$ f ACILITY March 30,1992 To: John B. Martin, NRC Regionej Administrator From: Michael Pollock, Acting Director, Reed Reactor Facllhy Re: Amendments to Recovery Plan for Reed Reactor Faollity The attached document is a set of amendmente to the original Rooovery Plan submitted by Reed College to the Nuclear Regulatory Commission on March 17,1992. These amendments were prepared at the request of Phil Qualla, Jim Reese, and Marvin Mendonca of the NRC, if you have any additional questions or comments regarding these amendments or the Recovery Plan, please contact either Michael Pollock, Acting Director, or Paul Terdal, Associate Director, at (503)777 7222.

s chaeFPollock, f&

/, Acting Director Reed Reactor Facility g ao g 4 920505 GOLD 92-35 PDR

March 30,1992 Reed Reactor Facility Recovery Plan Amendmente introduction This document contains a set of amendments to the Reed Reactor Faollity Recovery Plan of March 17,1992, based on discussions between Reed and NRC personnel. These amendments clarify items in the original Rooovery Plan.

Procedure for Locating the Leskina Fuel Elements in the original Recovery Plan, In Step 1, we stated that we would ' operate the reactor at the lowest power level that will produce a reasonably detectable amount of fission product." We will determine this level as follows:

1) As rec!ulted by Standard Operating Procedures, the reactor power level will be brought up to 5 W for a core excess check. The sniffer will be used, with a " wide area' funnel to attempt to identify flasjon 3roducts, if, after at least one hour of operation at this power level, fission proc uot activity le below the detection limits of our ap paratus, the l>ower level will be increased to 100 watts.

2) The procedure wil be repeatecl at 100 watts,1,000 watts,10,000 watts, 100,000 watts, and 240,000 watte until a power level is reached which produces a detectable level of fission products.

If, after five hours of operation at 240,000 watts, no detectable levels of 3) fiss ion products are found, the reactor will be shut down, and operations to locate the fuel element leak will be suspended pending consultation with the N RO.

The primary cooling system will be tumed off while the sniffer is in use,in order to reduce water currents in the pool.

The sniffer is designed to maintain Jo reactor water in a closed loop, which will be returned to the bottom of the reactor tank, except for a three way valve which will allow collection of small volumes of water in beakers for detailed analysis.

These beakers will be covered as they are filled.

All operation for thls procedure will be directly supervised by either the Director or Associate Director. As stated above, the reactor will be shut down if the RAM, CAM, APM, or GSM enters the falisafe mode, and the staff Will evaluate the attuation, if unexpected and potentially hazardous situations arise, such as an alarm on the RAM, CAM, APM, or GSM, the NRC will be contacted for

• consultation. If the staff is unable to locate the fuel element leak through the procedures outlined herein and in the original Recovery Plan, the NRC will be consulted before other approaches are attempted.

Oassous Stack Monitor Callbration:

In the March 17 Recovery Plan,in response to a concem raised in the NRC Inspection Report 50 288/9101 that some of the instrument calibrations were out of date, we stated that ' prior to any attempts to operate the reactor for the ,

Reed Reactor Fadlity: Rec 1waN Plam Amandta4.a. March 30,1992 Page1 l

, purpose of locating the source of the fuel leak, the CAM, APM, and 08M will be recalibrated."

Althou0h our foollity Standard Operatin0 Procedures call for opmlannual calibration, the Technloal Speelf oations only require annual callbration for the GSM The GSM Calibration Procedure requires Ar 41 gas, whloh is normally produced in our own resolor. We have been unable to find a vendor who is able to supply us with thle malettal. While the reactor at n State '

University could be used to produce this material, DOT re0 ne regarding transportation of radioactive gases make he ehlpment very efilout. Because the most recent OSM onllbration is still valid (according to the Technical  :

pose to begin o wrations to find the fuel element leak I

wthout recallb)ratinS 2ecifications e instrument. , wewe would prefer to redo the F cwever, callbration. During he initial leak testing at 100 W, we wlR Irradiate the necessary Ar gas for calibration of the GSM in the rotary spoolmen rack. If no significantly elevated levels of redloactivity are found in the Reactor Bay or  ;

' stack, then the reactor will be shut down and the stack monitorin0 em will be taken out of service for calibration. Operations to locate the leakin fuel l' element will be resumed after the GSM onllbration has been oo ed and the stack monitoring system has been retumed to sentios.

Air Partloulate Monitor: .!

In the original Recovery Plan, we Indloated that we would move the APM oollector out of the Reactor Bay and into the exit corridor. We have reviewed the Safety Analysis Report and Technloal Spoolfications, and there le no statement . f specliving the location of the collector. A 50.5g review is therefore unnecessary.

Continuous Air _ Monitor:

The CAM air intake la currently located in a pipe trench the reactor tank, a few inches above water level. When the facility enters isolation mode, there la a whloh could

-effect steady stream the CAM of airInthrough readings. the or ginalthe pl>e trench Recovery Plan, weinto statethe reactor bay,d that we move the CAM several feet so that it was out of the pipe trench, but stillin the reactor tank area itself.

• According to the SAR and Technloal Speelfloations, the CAM "shall be operable _ <

in the reactor room when the reactor le operating.' It does not specify where in the room the CAM or its air intake must be loosted. We feel that the primary purpose of the CAM is to alert personnelin the Reactor Bay to excessive concentrations of airbome contamination. Because the reactor tank will be covered during the procedure, the level of altbome contaminants in the space immediately a >ove the pool, but beneath the covers where the CAM ourrently samples alr) will be higher than that in the room itself(. We propose to rnov CAM air intake out of this area, so that it 3roperly samples room air frogn nearJ the breathing zone of the workers. One Itte gras samples of air from beneath the cover wl I be taken at the end of each hour of reactor operation and analyzed prior to bringing the reactor up to the next higher power level amended Procedure for Locating the Leaking Fuel Element," above). -(see Reed Ressor Faomy: Renovarv Plan Amandmama, March 30. t992_

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Air Monitorin in the original Recovery Plan, we stated that *(oharcoal cartrid pes) would be '

collected at routine Intervals and analyzed for partloulate and odine activity in the air,' It is our intention to run this sampler at all times that the recolor is  :

operating. Filters and charcoal cartridges will be changed and analyzed at  !

least once each hour of remotor operaton, teolation Mode Teett On From Friday, March 27 at 1600 to Monday, March 30, at 1000, the foollity ventilatlon system was placed into loolation mode in an experiment to determine the impact on humidity levels and back round radiation levels In the  ;

Remotor Bay. Although the air became quite stale,0as expected, no excessive humidity buildup was observed. Bookoround radiation levels on the four main '

facility radiation monitors were as follows:

Monitor: Ranka 'aundt i RAM 0.08m %r '

APM 1800 cpm GSM 70 opm -

CAM 800 cpm .

None of these levels is conaldered excesolve.

Action Levels:

The Falisafe and Alarm levels on the Continuous Air Monitor, the Gaseous Stack Monitor, and the Air Particulate Monitor will be changed to bring them in line with current regulatory practice and to make them consistent with the definition of Unusual Event, as outilnad in the Emergency Plan for the Reed i Reactor Facility. If, during the operations, the Fallsafe on any of the monitors is reached, the reactor will be shut down and the staff will review the situation. 't an Alarm levelis reached, the NRC will be notified and no further operations will be taken to find the source of the fuelleak without the concurrence of the NRC, 86td The current Faltsafe setpoint on the RAM la'0.5 mR/hr, and the current Alarm levolla 2.0 mR/hr. These will not be changed.

GSM' For the purmes of locating the fuel element leak, the Standard Operating Procedure tr Gaseous Stack Monitor Calibrations, SOP 31, will be modified as -

follows:

1 fo)rmulas:The Alarm and Falisafe setpoints will be determined by the following  !

Alarm - (10xMPC)(K)/((1/24)(F)) + Background _ '

Falisafe - (MPC)(K)/((1/24)(F)) + Back0round Where:

, K = dispersion factor (11.6) i F = detector efficiency (1.6x10 7 pCl/ cpm ml) 1 i

Reed Reactor Foer: Bagavan Plan Amendmenta.' March 30,1992 Page 3

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MPC = Maximum Permissible Concentration (2.29x10 7, as described above)

Background = 50 cpm

2) The MPC (Maximum Permiss!ble Concentration) will be 2.29x10 7pCl/ml which la based on the following assumed Isotoplo compoeltion:

53% Xe 135 30% Kr 68 17% Kr-85m

3) The dispersion factor, K, will be 11.6 Explanation:

As rreported in the NRC Inspection re >ori, the breakdown on the gases released during the Unusual Event last Fallis believed to have been 63% Xe 135,30%

Kr 88, and 17% Kr 85m. Prior to the release, the GSM was reading back (50 cpm , Indicating that no substantial Ar 41 release was taking place. ground Followin the procedures in 10CFR'20 Appendix B aragraph 1. "if radionue Jdes A, D, and C aro present in concentrat ons CA, Co, and Co, and if the applicable MPC's are MPCA, MPCs, and MPCc, respectively, then the concentrations shall be limited so that the following relationship exists:

(CA/MPCA )+(0 8/MPCB)+(Oc/MPCc) <=1" Nuclide: Percent Abundance: MPC: -

135Xe 53%

1x107 pCl/mi 88Kr 30% 2x108 Cl/ml 85mKr 17% 1x10 7 Cl/mi Thus, the comb!ned "MPC," as used for determining the GSM alarm sotpoint, would be:

(0.53x1x10 7 pCl/ml)+(0.30x2x10 8 pC1/ml)+(0.17x1x10 7pCil/ml)

= 2.29x10 7 Cl/mi The Unusual Event level of 10xMPC would be 2x10 opCl/ml.

Becauce the Unusual Event limitations are placed on the Site Boundary, which is 250 feet from the stack, we propose that we Incorporate an alr dispersion factor of 11.6. This dispersion factor was accepted in a 50.59 review of the Gaseous Stack Monitor procedure dated April 26,1990, based on dispersion from the top of the stack to the ground. Actual dispersten from the top of the stack to a point 250 feet away would be much greater, so this lv still a highly conservative value. Also, because the MPC la based on averaged release over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, we propose that we assume 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of release at the Alarm levelin a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period (our current procedure, which le aimed at Ar 41 release,is more

• liberal that this;it assumes 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of release at Alarm levelin a one week period).

Using the data from the most recent official calibrations, then, the Falisafe Setpoint would thus be 450 cpm, and the Alarm setpoint would be 4000 cpm.

Reed Reactor Facility: Re~we'v Plan AmendmeMa. March 30,1992 Page4

CNb For the purposes of locating the fuel element leak, the Standard Operating Procedure on Continuous Air Monitor Calibration (SOP 30 will be changed to use the folloWlng formulas for determlnatlon of the Falisafe)and Alarm se Fallsafe setpoint = 24 x Et F t MPC Ed + Background opm Alarm setpoint = 24 x 10 x Et F t MPC E4 + Background opm Where:

Et = Paper fitter efficiency (percent of partlotes trapped by filter 52%)

F= flow rate in mililliters per minute -

t = sample time (60 minutes)

MPC = Maximum Permissible Concentration from 10CFR20 E4= Detector Effielency Background epm - background reading from chart recorder The facility will use 3x1010 Cl/ml (6.66x10 4 dpm/ml) as the Maximun1 Permissible Concentration.

Explanation:

Currently, the official CAM Afarm Setpoint is arbitrarily set to 3600 CPM, and the Fallsafe to 3000 CPM. These points were chosen simply because the self test feature will only generate 3600 cpm, and it is thus convenient to test these levels.

As with the Gaseous Stack Monitor GSM), discussed above, these equations are based around the definition of

• nusual Event" from our Emergency Plan.

As with the GSM, the Alarm lovsils based on 10x MPC averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This equation is more conservative than the GSM equation, however, because dispersion is not taken into consideration. For the MPC value, since we won 1 always know exactly what we are faced with, we propose using the values from 10CFR20, Appendix B, paragraph Sc, whloh specifies limits "when the exact composition is unknown, but that 11 la known that certain elements are not present." Assuming that Pb 210, Ac 227, Ra 228, Pa 230, Pu 241, and alpha emitters are not present, but the exact composition is otherwise unknown, we can us an MPC of 3x1010pCI/mlin the reactor room, and 1x1011pCI/ml outside the facility. During the Unusual Event, none of the restricted elements listed above were detected in water or air filter samples.

The equation outlined above would give us some very high setpoints; using the following data (collected during a recent callbration exercise):

Et = 0.52 (according to the manufacturer)

F= 1.8x105 ml/ minute t = 60 minutes MPC = 3x1010pCl/ml(6.66 x 10 4 dpm/ml) -

E4 = 0.091 cps /dpa Background cpm = 600 cpm (for Isolation mode)

Reed Rea: tor FacMy Po~aveN Plan AmeWpMn March 30,1992 Page 5

we get a fallsafe setpolnt of about 9,000 cpm and an alarm setpoint of 83,000 cpm. If dispersion were taken into account, the setpoints would be even higher.

Since the top of the scale on the CAM ls 50,000 cpm, we wl!I use an alarm setcolnt of 45,000 opm. We can generate readings of 50,000 cpm with either a Co'eman lantern mantle or some other small detector ohook source to verify that these settinge are correct.

AP_M:

For the purposes of locating the fuel element leak, the Standard Operating Procedure on APM Cal!bration (SOP 32) will be changed to use the following formulas for determination of the Falisafe and Alarm setpoints:

Fallsafe setpoint = (24)Et F t MPC Ed + Background opm Alarm setpoint = (24)(10)Et F t MPC Ed + Background cpm Where:

Et = Paper filter efficiency (percent of particles trapped by filter 52%)

F= flow rate In milliliters per minute t = sample time (60 minutes)

MPC = Maximum Permissible Concentration, from 100FR20 but expressed in dpm/mlinstead of Cl/ml Ed = Detector Efflolency Background epm = background reading from chart recorder The facility will use 1x1010 Cl/ml (2.22x104 dpm/mi) as the Maximum Permissible Concentration.

lanation: '

O ly, the APM alarm level was based arbitrarily on release of Sr 90. Also, the FM used a moving filter paper, so the T in the above calculation would have been about 1 minute instead of 60. Filter paper efficiency was assumed to 4 be absolute (100%). Since then, the APM has been modified to use fixed filter paper, which will accumulate particles throughout an entire run, and so radiation levels are considerably higher than before. Since the APM functions very much like the CAM, wo can use the same efficiency equation to determine the setpoints. However, unlike the CAM, we conalder it very unlikely that there will be Sr 90 in the stack air. The parent for Sr 90 la Kr 90, which has a very short half life (about 33 seconds). For the most pah, then,if any Sr 90 is the Reactor Bay. Since the room will be in Iso)lation, the Sr 90 will be filteredprod out by the HEPA filter before it reaches the stack. Therefore, we can use a less restrictive MPC limit from 100FR20, which la 1x1010pCl/ml. Using sample data from a recent APM calibration, with a background of about 3000 cpm, this gives us: .

Fa!! safe = 5700 epm Alarm = 30,000 cpm Since the APM readout goes up to 1,000,000 cpm, both of these setpoints can realistically be used it we took dispersion into account, the setpoints would be Reed Reador FadPty: Raement Plan Amandtanta. March 30.1992 Page6

even higher. Actual setpoints will be based on a new calibration of the l Instrument.  ;

Respiratore:

In the original Recovery Plan, we indloated that " full face res#rstors with charcoal activsted filters will be made available, as needed, er isomty staff  :

workin;in the Beactor Ba '

propery fit tested, tralned,y. AnyforIndividuals and certifled wondnoof those their use. AvellebWty the masks masksis will be -

purely a precaution in keeping with our ALARA polloyl we do not intend to use these masks to allow personnel to enter areas with altbome concentrations in '

excess of the conoontrations spoolflod in 10CFR20.

If radioactive lodine is detected in the Reactor Bay alr, operallone will oosse, the reactor will be shut down, and the NRC will be consulted before operations  ;

resume, a

Arrangements have been made with Portland General Electrio for use of their '

whole body counters to examine personnel who have been working in the reactor bay in the event that altbome particulate or lodine contamination levels rise above background.

Fuel Element inspectione We are very concemed about the request to visually inspect all fuel elements.

We have vleually inspected at least 1/5 of the fuel elements in the reactor each year for more than 20 years. Visual inspection is verf subjective and there are no criteria upon which to decide whether or not a fue element is noce9 table.

Information from several other foollities whloh have experienced pin hole leaks suggests that the sources of these leaks are not visible. -

The ony deterioration of fuel elements whloh has been noted over the years are '

physica scratches, mostly along the long dimension of the elements, and a bent i bottom pin. The deterioration in each case has occurred during the process of handling fuel. Other than fuel element inspections, the only fuel handling whloh has over occurred at Reed has been the movement of at moet 3 4 elements during the rare process of adding fuel elements to the core, it makes very little '

sense to us to agree to arbitrarily perform the one operation Whloh la moet likely to cause the failure of an element, partloularly if there is no benefit to be gained. '

Never the less, we will agree to the following:

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' 1) Any fuel element which is handled during the process of Identifying the '

j leaking element will be subjected to a careful visual Inspection. q L 2) Once the leaking element (s) is identified, it will be subjected to a careful .

R E a visual Inspection by at feast fwo Individuals and the results dieoussed infdstall l L with the NRC and General Atomic.

3) If, during the review, identification and evaluation proossa, any criteria is identifled which would allow one to identify other elements which may have a >l i

Reed Reeaer Facilty

pa~wev Plan Amendman March 30,1992 Pa08 7  ;

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higher potential to develop leaks in the future, we will Inspect all fuel elements 4

against those ortleria prior to resuming routine operation.

Additionally, as was stated in our original Recovery Plan, the annual Inspection of 1/5 of the elements in the oors will take place after the leaking element has been located and removed from the core. .

Disposition of l.ceking Puel Element:

After the leaking fuel element has been found and examined through our l normal fuel inspection procedure, it will be placed in an in pool stornee rock. '

Should the manufacturer wish to inspect it, we will make it avaliable to them.

A note will be made In the fuel lnventory' records for the leaking fuel element to Indloate that il should not be retumed to servloe, Control Mod Inspectione:

As was stated in the orfginal Recovery Plan, the Control Rod Inspections will be conducted after the leaking fuel element has been located and removed from the core, In order to inspect control rods, we must remove several fuel elements from the remotor core, in order to keep the teactivity shutdown margin intact. As ,

we have stated above, we would prefer to keep fuel handling to a minimum for  :

safety reasons, and would rather do this at the same time as the annual fuel l Inspections, ,

Pubilo information:

All Information relating to fuel element leak, our correspondence with the NRC, and our plans for restarting the reactor are available to the publio. Coples of all regulatory documents and correspondence relating to the reactor have been-placed on file in the reserve room of the College library.and are available to anyone upon request.

Notification of the submission of the Rooovery Plan to the NRC has been-published in the campus newsletter, and submitted to the student newspaper. ,

Coples have been provided to the neighborhood orgenlaations and to those ,

media sources whleh have requested them. All college constituents, including parents of students have been notified.

A public meeting was held on February 13, to which all residents of the three nelghborhoods surrounding the Reed campus were Invited. The neighborhood associations will be given an opportunity to comment on the plan in a mutually -

,a0resable format.  ;

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5 Mood Reactor FacRy: A=very Plan Amandmenta: , March 30,1992 Page 8

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