ML20133H204
| ML20133H204 | |
| Person / Time | |
|---|---|
| Site: | Plum Brook File:National Aeronautics and Space Administration icon.png |
| Issue date: | 07/26/1985 |
| From: | NATIONAL AERONAUTICS & SPACE ADMINISTRATION |
| To: | |
| Shared Package | |
| ML20133H203 | List: |
| References | |
| NUDOCS 8508090232 | |
| Download: ML20133H204 (65) | |
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APPENDIX A i
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PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS i
t LICENSE NO. TR-3 1
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION i
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DOCKET NO. 50-30 i
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8500090232 850726 DR ADOCK 0500oo30 1
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TABLE OF CONTENTS PAGE I
1.
Introduction - - - - - - - - - - - - - - - - - - - - - - - - -
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1.1 Scope 1.2 Application 1.3 Definitions 2.
Requirements - - - - - - - - - - - - - - - - - - - - - - - - - 3 i
l 2.1 Access l
2.2 ReactorTank(RT) l i
l 2.3 Containment Vessel (CV) 2.4 Primary Cooling Water System and Primary Pump House i
T 2.5 Alarm System 2.6 Electrical System l
2.7 Quadrant and Canal System 2.8 Radiochemistry Laboratory 2.9 Hot Drains f
2.10 Hot Laboratory 2.11 Hot Pipe Tunnel l
2.12 Waste Handling Building 2.13 Emergency Retention Basin
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2.14 Hot Retention Area l
2.15 Contaminated Air System 3.
Surveillance - - - - - - - - - - - - - - - - - - - - - - - - - 13 f
3.1 Designated Storage Areas within PBRF 3.2 Access to Radiological Control Zones 3.3 Alarm Response 3.4 Facility and Environmental Monitoring l
3.5 Minimum Procedures 3.6 Inspection. Tests and Surveys 4.
Administrative Controls - - - - - - - - - - - - - - - - - - - 18 l
4.1 Organization 4.2 Proceldres l
4.3 Reports 4.4 Records 5.
References - - - - - - - - - - - - - - - - - - - - - - - - - - 24 t
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APPENDIX A PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS I
LICENSE NO. TR-3 NATIONAL AERONAUTICS AND SPACE ADMINISTRATION DOCKET NO. 50-30 1.
Introduction Where applicable, these technical specifications follow the format of the American National Standard ANSI /ANS-15.1-1982.
1.1 Scope These technical specifications apply to all portions of the Plum Brook ReactorFacility(PBRF),withtheexceptionoftheMock-upReactor (MUR)whichisseparatelylicensed.
The PBRF contains a non-operable test reactor, its support facilities, and its inventory vf radioactive i
materials generated as a result of previous operations.
The reactor was shutdown in 1973 after 98,000 megawatt days of operation.
The radioactive inventory, with the exception of distributed radio-l active material existing as contamination within process systems and laboratories, is stored in four locations.
These are inside the Containment Vessel, in the Reactor Building Canals G, in the Hot Laboratory, and in the Waste Handling Building.
The PBRF contains no 1
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1.2 Application These technical specifications govern the condition of National Aeronautics and Space Administration's PBRF in the possess-but-not-i operate status.
The PSRF is described in past documents submitted and now contained in Docket No. 50-30.
Only systems, components, or areas l
which are radioactive, contaminated, or needed to maintain a protected safe storage condition are covered in these technical specifications.
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1.3 Definitions 1.3.1 General Authorized Entry - Entry by people authorized by management with a legitimate need to enter the PBRF who have knowledge of the condi-tions, the hazards, and procedures of the facility or who are accompanied by someone with this knowledge.
Kept Dry - A condition which is normally dry and mopped or drained as soon as practical when becoming inadvertently wet.
[
Nonoperable - A condition of a component or system which has been j
intentionally disabled to prevent it from performing its intended l
function.
Protected Safe Storage - A custodial state of undefined duration characterized by physical and procedural access control and ay periodic monitoring, maintenance and inspection.
Shall - The work "shall" is used to denote a requirement.
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1.3.2 Radioactive Materials,
t Contaminated Material - Irradiated or non irradiated items containing particles of radioactive material on its surface.
Radioactive Material - Items which have been activated as a result 1
l of previous reactor operations.
These items may also be contaminated, j
1.3.3 Radiological Control Zones i
1 Magenta Zone - For purposes of contamination control, levels will i
be as low as reasonably achievable but can exceed the j
magenta-yellow limit.
For purposes of direct radiation control, a
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i magenta zone is any area which could expose major portions of the body to direct radiation levels of 100 mrem /hr or more.
l Magenta-Yellow Zone - For purposes of contamination control, i
and10,000dpm4-Y/100 j
levels will not exceed 100 dpm 4/100 cmr cmr transferable; 2500 dpmdand 8,000 dpm4-Vfixed.
Magenta-yellow zone for purposes of direct radiation control, is any area which could expose major portions of the body to direct radiation i
levels from 2.5 to less than 100 mrem /hr.
White Zone - Is an area with contamination levels so low that no i
protective clothing is required.
This area will have direct radiation levels less than 2.5 mrem /hr.
2.
Requirements
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a 2.1 Access i
Applicability - This specification applies to protection of the facility by control of access.
Objective - The objective is to prevent unauthorized entry.
l Specification:
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The PBRF access shall be controlled through two fences.
The outer fence surrounds the Plum Brook Station.
An inner fence surrounds I
the PBRF within station.
Bases:
The specification of 2.1 provide two physical barriers before gaining access to the locked buildings of the PBRF.
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2.2 ReactorTank(RT) 4 Applicability - This specification applies to the contaminated and radioactive material of the reactor tank and contents within.
Objective - The objective is to safely store the irradiated materials and control radiation levels.
Specification:
i The reactor tank, surrounded by a thick concrete biological i
shield, shall be drained.
All tank nozzles and penetrations which could stream irradiation shall have shields fixed in place.
The threeshrapnelshields(20tonseach)shallbepositionedabove i
j the reactor tank. All openings shall be closed, except those openings required for a dry gas purge through an absolute filter j
to the stack.
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Radiation levels at accessible reactor tank surfaces shall be less than 100 mrem /hr.
The sub-pile room door shall be closed and locked except for authorized entry.
Bases:
High radiation level inside the RT and streaming through RT penetrations are prevented by various shields.
The reactor tank is covered with shrapnel shields and is surrounded by thick concrete biological shields. Additional shields needed to make all accessible areas to the RT below 100 mrem /hr are tack welded l
in place. Twelve years experience at PBRF has found the shielding adequate for all quadrant accessible areas to be classified as magenta-yellow zones.
In addition, the experience has found no airbornecontaminationinexcessofMPC(unrestrictedareas).
2.3 Containment Vessel (CV)
Applicability - This specification applies to protected safe storage of the reactor and contents inside the CV.
Objective - The objective is to control personnel access to the CV and prevent entry of water which could be a vehicle to spread contaminated material.
Specification:
a.
The CV shall be provided with two primary openings designed to breathe the CV atmosphere through absolute filters.
b.
One of the two existing personnel doors shall be used for controlled personnel access.
This door shall be locked to prevent :
unauthorized entry.
The other door shall be operable only from the inside as an emergency exit.
Access shall be through a single door of the original airlock door system.
c.
The truck door shall be closed and dogged in place except during temporary controlled periods to accommodate transfer of equipment too large to fit through the personnel door, d.
All original liquid containing process lines penetrating the CV shall be drained and blank flanged or capped to prevent liquid entering the CV.
The blank flange or cap shall be secured against unauthorized opening.
All other process penetrations shall be closed with locked or welded valves, or capped to prevent unauthorized opening from the outside.
Bases:
Specification 2.3 a. provides authorized personnel an inhabitable atmosphere in the CV.
Specification 2.3 b. controls authorized entry while specification 2.3 c. eliminates a source of water except for minor condensation.
A dry protected safe storage with access control is provided by these specifications.
2.4 PrimaryCoolingWaterSystemandPrimaryPumpHouse(PPH)
Applicability - This specification applies to protectico and safe storage of the primary cooling water system outside the CV.
Objective - The objective is to isolate the RT from the PPH, control access and prevent spread of contaminated materials.
Specification:
a.
The primary cooling water supply and return headers shall be blank-flanged to isolate the reactor tank from the Primary Pump House.
Lines between the blank flanges and the Primary Pump House shall be drained, b.
The PPH roof hatch plugs shall be in place.
The roof hatch plugs and personnel doors of the PPH shall be locked except for authorized entry.
Bases:
These specifications provide a dry primary cooling water system outside the CV and prevent access to the system in the PPH.
2.5 Alarm System Applicability - This specification applies to reliable alarms.
Objective - The objective is to receive off normal warning.
Specification:
An alarm system shall be maintained to provide local alarms at the PBRF and a summary alarm at the Plum Brook Station Communication Center.
The alarm response is provided in Section 3.3.
Bases:
This specification provides a requirement which demonstrated a reliable warning system over the past 12 years.
2.6 Electrical System _ - _. -.
Applicability - This specification applies to reliable power.
Objective - The objective is to receive off normal warning.
Specification:
The PBRF electrical power shall be supplied by a commercial power system. When power is restored following an outage, all load circuits shall automatically reenergize.
Bases:
These specifications provide requirements which have demonstrated a reliable power source over the past 12 years.
2.7 Quadrant and Canal System Applicability - This specification applies to the Quadrant and Canal System for protected safe storage except for Canal H (coveredunderR93 license).
Objective - The objective is to provide a safe storage area for contaminated and radioactive materials.
Specifications:
The quadrants and canals are cleaned, drained and shall be kept d ry.
The deionizer system was flushed, drained and shall be isolated by valves and flanges.
Bases:
By these specifications,12 years experience demonstrates the Quadrant and Canal System can be successfully used as storage locations.
2.8 Radiochemistry Laboratory Applicability - This specification applies to the chemical fume hoods of the Radiochemistry Laboratory.
Objective - The objective is to prevent personnel access and entrance of water to these areas.
Specification:
The chemical fume hood doors shall be secured to prevent opening and hoods shall be kept dry.
Bases:
Contamination spread is minimized by access prevention.
2.9 Hot Drains Applicability - This specification applies to the protected safe storage of the Hot Drain System.
Objective - The objective is to prevent spread of radioactive contamination.
Specification:
The Hot drain system shall remain nonoperable.
All accessible (white zone) external surfaces shall be clean.
All hot drains, sumps, and lines shall be flushed, cleaned to a practical extent and drained. All floor drains and other flow paths supplying a hot sump shall be plugged or sealed.
Pump motors shall be deenergized from the power bus at the motor control centers, d-Bases:
These specifications provide for a static relatively clean hot drain system.
In addition they prevent access to these systems.
2.10 Hot Laboratory Applicability - These specifications apply to protected safe storage in the Hot Laboratory including the Hot Dry Storage.
Objective - The objective is to prevent unauthorized entry to contaminated or radioactive material storage areas.
Specification:
Access doors to the Hot Laboratory shall be locked.
Hot cell doors and the 80 ton access door to the Hot Dry Storage area shall be locked.
Bases:
Limited access with procedural control prevents personnel exposure and spread of contamination.
2.11 Hot Pipe Tunnel Applicability - This specification applies to the protected safe storage of the Hot Pipe Tunnel.
Objective - The objective is to prevent personnel access and entrance of water to this area.
Specification:
The Hot Pipe Tunnel entrances at each end of the tunnel shall be padlocked closed.
The tunnel shall be kept dry.
Bases:
Contamination spread is minimized by access prevention,and maintenance of the dry condition.
2.12 Waste Handling Building Applicability - This specification applies to protected safe storage in the Waste Handling Building.
Objective - This objective is to prevent unauthorized entry to a:1as containing contaminated or radioactive materials.
Specification:
Accest doors leading to the Waste Handling Building shall be locke closed. Access doors to the evaporator room and waste packaging room shall be locked closed.
Bases:
Limited access with procedural control prevents personnel exposure and spread of contamination, l '(
2.13 Emergency Retention Basin (ERB)
Applicability - This specification applies to the protected safe storage of the ERB.
Objective - The objective is to provide a basin which will minimize the accumulation of water and prevent a potential source of contamination to the environment.
Specification:
The ERB drain line shall remain open to prevent rain water accumulation.
The water shall be sampled quarterly to verify limits of 10 CFR Part 20 for an unrestricted area are not exceeded.
By pump removal, the supply line shall not be a water source to the ERB.
Bases:
Periodic checks over the past 12 years show ERB water samples have not exceeded the limits of 10 CFR Part 20 for unrestricted areas.
2.14 Hot Retention Area (HRA)
Applicability - This specification applies to protected safe storage of the HRA.
Objective - The objective is to control access and prevent spread of contamination.
Specification:
The HRA tanks were flushed, decontaminated to a practical level, and shall be kept dry. All HRA entrances or access plugs are welded closed, except that one entrance to the annulas and the tunnel area shall be locked to allow only authorized entry.
Bases:
These specifications provide a restricted access to a relatively i
clean and dry system.
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2.15 Contaminated Air Systems Applicability - This specification applies to protected safe storage of the Contaminated Air Systems which includes the Stack.
Objective - The objective is to provide controlled access into relatively clean Contaminated Air Systems.
Specification:
TI.e contaminated air systems were vacuumed, decontaminated as practical, purged and shall be kept dry with absolute filters removed.
All manual and automatic operated valves shall be disabled in a fixed closed position.
These systems shall include the 5-foot diameter, 100-foot-high stack and all contaminated air ventilating systems except those presently serving the reactor tank, CV and HRA. The fan motors shall be deenergized from the i
power bus at the motor control centers.
Bases:
A systematic clean up followed by 12 years of monitoring verifies the absence of significant airborne activity.
3.
Surveillance f
3.1 Designated Storage Areas within PBRF Applicability - This specification applies to the radioactive storage areas at the PBRF.
Objective - The objective is to identify the areas for _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
radiological control.
Specification:
Radioactive material, with the exception of distributed radioactive material existing as contamination within process systems and laboratories, shall be stored primarily in four areas:
a.
The Containment Vessel.
b.
The Reactor Building Canal G.
The Hot Laboratory which includes Hot Cells and Hot Dry c.
Storage Area.
d.
The Waste Handling Building.
Storage areas shall be posted as Radiological Control Zones defined in Section 1.3.
Access to these areas shall be controlled as specified in Section 3.2. Access to Radiological control Zones.
Bases:
The specifications identify the primary areas used for radioactive material storage and define the control for these radiological control zones.
3.2 Access to Radiological Control Zones Applicability - These specifications apply to radiological control zones of the PBRF.
Objective - The objective is to provide controls for these zones.
Specifications:
Magenta zones shall be posted, secured by fixed barricades or a.
under lock and key control.
Buildings containing these zones __
o shall also be locked. Access to magenta zones shall require continuous radiation monitoring by health physics personnel, use of a safe work permit, and use of personnel dosimetry.
b.
Magenta-yellow zones shall be posted.
Access to magenta-yellow zones shall require health physics monitoring and control and use of personnel dosimetry.
All areas accessible to authorized personnel for inspection c.
and maintenance purposes shall be decontaminated where practical to white zones.
Bases:
These specifications ensure adequate precautions prior to access to radiological control zones.
3.3 Alarm Response Applicability - This specification applies to alarm response.
Objective - The objective is to provide a response for minimum alarm conditions during protected safe storage.
Specification:
The Communication Center is continuously manned to respond within one hour. The following alarms shall be operable:
a.
CV entry door open i
b.
Loss of facility electric power Hot Retention Area sump - High ground water.
c.
Bases:
This specification ensures a response for abnormal conditions _. -. -
a during a protected safe storage condition.
3.4 Facility and Environmental Monitoring Applicability - This specification applies to routine radiological surveys at the PBRF.
Objective - The objective is to determine that radioactivity is confined to radiological control zones.
Specification:
Routine radiological surveys shall be performed by trained health physics personnel using survey and counting equipment commensurate with sound health physics practices to ensure that radioactivity levels are within 10 CFR Part 20 limits.
Bases:
This specification ensures that radioactive levels are maintained within permissible limits.
3.5 Minimum Procedures Applicability - This specification applies to some procedures that help administer the protected safe storage condition.
Objective - The objective is to list the more important procedures.
Specification:
Detailed procedures shall be in effect covering the following areas:
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e a.
Response to alarms.
b.
Entrance to the PBRF, PBRF building, Containment Vessel, and radiological control areas.
c.
Facility and environmental radiological monitoring.
d.
Facility changes.
e.
Emergencies such as fire, floods, and tornadoes.
These procedures shall be approved by the PBRF Safety Committee.
Bases:
This specification ensures protected safe storage procedures are provided.
3.6 Inspection, Tests and Surveys Applicability - This specification applies to select inspection, tests, and surveys used to preserve a protected safe storage condition.
Objective - The objective is to provide a minimum inspection and test program for continued protected safe storage.
Specification:
The following inspection and tests shall be performed:
Current Minimum Frequency a.
PBS Fence Integrity (patrolled daily)
Quarterly b.
PBRF Fence Integrity Monthly c.
Building and CV locks Monthly 1
d.
Building and CV General Condition Monthly.
. s e.
Alarm Tests Quarterly f.
Facility Radiological Surveys Quarterly g.
Environmental Radiological Surveys Quarterly h.
Absolute Filters Annually 1.
CV Integrity Annually Frequencies shall be approved by the PBRF Safety Committee.
The PBRF Engineer shall review the results and assure necessary corrective actions are taken to preserve the protected safe storage condition.
Bases:
This specification ensures protected safe storage inspection, tests, and surveys are provided.
4.
Administrative Controls 4.1 Organization The Plum Brook Reactor Facility is owned by the National Aeronautics and Space Administration (NASA), which shall be responsible for maintaining the protected safe storage condition as required by these Technical Specifications.
NASA shall provide whatever resources are required to maintain the PBRF in a condition that poses no hazard to the general public or to the environment. Attached figure 1 charts the current generic organization and is submitted for information only.
Significant _ _ _ _
. a changes in organization shall be reported in the annual report.
4.1.1 Level 1 Directorate The Director shall be responsible for assuring compliance with the reactor facility's license and providing regulatory reports and correspondence.
He shall have overall responsibility for the protected safe storage of the facility.
4.1.2 Health Safety and Security Division This division shall provide the resource to maintain the PBRF in protected safe storage.
4.1.3 Internal Audit An annual internal audit, shall be performed at the PBRF. The audit shall be performed by NASA personnel not directly associated with the facility who have nuclear experience.
Special attention shall be given to compliance with procedures, the NRC licenses, regulations, and record keeping.
The auditor shall submit a report on each audit for the Executive Safety Board.
Reported discrepancies shall be resolved by the PBRF Engineer.
The Plum Brook Reactor Facility Safety Committee shall review and insure the proper disposition of each discrepancy.
4.1.4 Radiation Safety Officer (RS0)
A RS0 shall be appointed to organize, administer, and direct the radiological control and monitoring program, as required by these ?
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i G~ENERIC ORGANIZATION CHART I
NASA LEWIS RESEARCH CENTER DTRFFTOR EXECUTIVE LEVEL 1 SAFETY DIRECTORATE BOARD DIRECTOR INTERNAL HEALTH SAFETY AND AUDIT SECURITY DIV.
LEVEL 2
. RADIATION PBRF SAFETY P B STATION SAFETY COMMITTEE MANAGEMENT OFFICER OFFICE PLANT SECURITY LEVEL 3 HEALTH PHYSICS AND PBRF ENGINEER AND INSPECTION MAINTENANCE
- Contract)
(Contract)
RESPONSIBLE FOR LEVEL 1 - Compliance LEVEL 2 - Surveilance and Maintenance LEVEL 3 - Day to Day Oversite FIGURE 1
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F Technical Specification, and assure the program is adequately performed.
The RSO shall be responsible for providing on-site advice, technical assistance and review in all areas related to radiological safety. The RSO shall be a person specifically trained in the radiation health sciences and appropriately experienced in applying this knowledge to the management of the radiation protection program.
The RSO shall have a bachelors degree in physical science or biological science with a minimum of two years of applied health physics experience in a program with radiation safety considerations similar to those associated with the PBRF program.
4.1.5 Executive Safety Board (ESB)
The ESB serves as a Lewis Research Center safety policy and decision making board, and is responsible to the Center Director for the overall direction of the Lewis Safety Program.
The ESB establishes a system of Safety Committees to conduct detailed third party reviews of specified Center operations.
4.1.6 PBRF Safety Committee (PSC)
The PSC was chartered by the ESB to conduct safety reviews of all matters with safety implications relative to maintaining protected safe storage of the Plum Brook Reactor Facility.
The purpose of the reviews is to assure that operations, written procedures and future plans comply with NRC licenses and regulations, do not involve unreviewed safety questions, and provide protection to the. -
workers, the facility, and the environment. A prime consideration in the PSC activities is to ensure that all public and employee radiation exposures are maintained as low as reasonably 1
achievable.
Items of review shall include routine operation, i
proposed changes, new and revised procedures, facility changes, changes in technical specifications, and audit reports.
The PSC shall consist of a minimum of four persons and shall meet at least twice each year.
The PSC shall have at least one member with nuclear background and one other member familiar with the conditions of the the facility.
In addition, the Radiation Safety Officer shall also be a member.
A quorum of the PSC shall be two-thirds of the members but not less than three members whichever is greater. In specific instances, the PSC may designate the Chairman to act in its stead, and the Chairman will report his actions to the committee at its next regular meeting.
Meeting minutes will be distributed to all members and be retained on file.
4.1.7 Plum Brook Station Management Office (PBM0) i The Chief PBM0 shall be knowledgeable of'the station activities f
that may affect the protected safe storage condition at the PBRF.
The Chief PBM0 is responsible for administering a program to 4
ensure that proper operations, control and safeguards are maintained for the station. This includes a key control system.
Keys for the PBRF are authorized by the Chief, PBM0 on a "need to have" basis to persons having knowledge of the conditions, the l
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hazards and procedures of the PBRF.
Implementation is by an authorization letter issued to the key distributor.
The PBM0 shall provide for the services of Plant Security, Inspection, Health Physics, and Maintenance as necessary at the PBRF.
4.1.8 PBRF Engineer (Reactor Manager)
The PBRF Engineer shall be appointed to manage and assure the protected safe storage condition is maintained in accordance with these Technical Specifications.
The PBRF Engineer shall have the following qualifications:
a.
A bachelor's degree in engineering or a related physical science.
b.
Be knowledgeable in radiation hazards and radiation protection.
c.
Have successfully completed the training class for familiarization with the duties of the reactor manager.
The PBRF Engineer shall assure protected safe storage conditions are maintained and necessary inspections are performed with records to support the inspection.
He shall train and/or qualify personnel to maintain protected safe storage conditions.
He shall review maintenance procedures and results to assure buildings and grounds remain in an acceptable quality condition.
The PBRF Engineer shall assure unusual occurrence reports, facility changes, and new or revised procedures are prepared, approved and issued.
He shall approve all PBRF facility changes, new or revised procedures.
He shall approve all major material or equipment transfer in and out of the PBRF.
The PBRF Engineer shall prepare license change request for submission to.the NRC.
4.2 Procedures All new or revised procedures will be reviewed by the PBRF Safety Conmittee and approved by signature of the PBRF Engineer and the chairman of the PSC.
4.3 Reports Reports required under license and applicable regulations shall be provided.
In addition, NASA shall report in writing to NRC within 90 days after each calendar year summarizing the following:
a.
Condition of systems and components needed to maintain the protected safe storage condition, b.
An assessment of the effectiveness of security and surveillance.
c.
Significant changes in PBRF management organization.
d.
Results of facility and environmental radiological surveys.
e.
Changes to the facility pursuant to Section 50.59 of 10 CFR Part 50.
f.
Exposure range and total number of persons provided with monitoring per 10 CFR Part 20.407.
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e *. o 4.4 Records NASA shall keep records required by applicable licenses and regulations including the following:
a.
Radiological survey results of PBRF and environment.
b.
Equipment maintenance records (EMR's) of non routine maintenance operations involving substitution or replacement of vital components.
c.
The end condition statements, the procedures used to piace the facility in the standby condition, and the procedure completion reports shall reilect the facility condition in the possess-but-not-operate status, d.
Up-to-date facility drawings.
5.
References (1)' Code of Federal Regulations, Title 10 " ENERGY", Government Printing Office, Washington D.C.
(2) American National Standard for the Development of Technical Specifications for Research Reactors, ANSI /ANS 15.1-1982 American Nuclear Society, LaGrange Park, Illinois.
BASES AND SAFETY ANALYSIS FOR PLUM BROOK REACTOR FACILITY PROTECTED SAFE STORAGE CONDITION ATTACHMENT 1 TO SUPPORT REQUEST FOR AMENDMENT TO LICENSE NO. TR-3 DOCKET h0. 50-30 o
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t TABLE OF CONTENTS PAGE 1.
Introduction - - - - - - - - - - - - - - - - - - - - - - - - - -
1 2
2.
General Information 3.
Location - - - - - - - - - - - - - - - - - - - - - - - - - - - - 3 4.
Reactor Tank - - - - - - - - - - - - - - - - - - - - - - - - - - 3 5.
Containment Vessel - - - - - - - - - - - - - - - - - - - - - - - 7 6.
Primary Cooling Water System and Primary Pump House - - - - - - 10 7.
Alarm System - - - - - - - - - - - - - - - - - - - - - - - - - - 12 8.
Electrical System - - - - - - - - - - - - - - - - - - - - - - - 13 9.
Quadrant and Canal System - - - - - - - - - - - - - - - - - - - 14 10.
Radiochemistry Laboratory - - - - - - - - - - - - - - - - - - - 17 i
11.
Hot Drain System - - - - - - - - - - - - - - - - - - - - - - - - 18
- 12. Hot Laboratory - - - - - - - - - - - - - - - - - - - - - - - - - 19 13.
Hot Pipe Tunnel
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- 14. Waste Handling Building
20 15.
Emergency Retention Basin - - - - - - - - - - - - - - - - - - - 21
- 16. Hot Retention Area - - - - - - - - - - - - - - - - - - - - - - - 22 17.
Contaminated Air Systems - - - - - - - - - - - - - - - - - - - - 25 18.
Safety Analysis for Emergencies - - - - - - - - - - - - - - - - 26 18.1 Tornadoes and Severe Storms 18.2 Flooding 18.3 Earthquakes 18.4 Fire 18.5 Sabotage 18.6 Bombing 19.
Engineering Studies and Equipment Transfer - - - - - - - - - - - 33 20.
Environmental Impact - - - - - - - - - - - - - - - - - - - - - - 34
BASES AND SAFETY ANALYSES FOR PLUM BOOK REACTOR PROTECTED SAFE STORAGE CONDITIONS TO SUPPORT REQUEST FOR AMENDMENT TO LICENSE TR-3, DOCKET N0. 50-30 l
1.
INTRODUCTION The revised Technical Specifications submitted with this application define the 4
basis for maintaining the protected safe storage condition of the NASA Plum Brook Reactor Facility (PBRF).
The following definitions are applicable to these analyses:
4 GENERAL 4
Authorized Entry - Entry by people authorized by management with a legiti-mate need to enter the PBRF who have knowledge of the conditions and hazards of the facility or who are accompanied by someone with this knowledge.
Nonoperable - A condition of a component or system which has been inten-tionally disabled to prevent it from performing its intended function.
Protected Safe Storage - A custodial state of undefined duration charac-terized by physical and procedural access control and periodic monitoring, maintenance and inspection.
Radioactive Materials:
i t - -___--
Contaminated Materials - Irradiated or non-irradiated items containing particles of radioactive materials on its surface.
Radioactive Materials - Items which have been activated as a result of previous reactor operations., These items may also be contaminated.
Radiological Control Zones:
Magenta Zone - For purposes of contamination control, levels will be as low as reasonably achievable but can exceed the magenta-yellow limit.
For purposes of direct radiation control, a magenta zone is any area which could expose major portions of a body to direct radiation levels of 100 mrem /hr or more.
Magenta-Yellow Zone - For purposes of contamination control, levels will not exceed 100 dpm 4/100cm2 and 10,000 dpm@ -V /100 cm2 transferable; 2500 dpmc(and 8,000 dpm$ -Y fixed.
Magenta-Yellow zone for purposes of direct radiation control, is any area which could expose major portions of the body to direct radiatica levels from 2.5 to less than 100 mrem /hr.
White Zone - Is an area with contamination levels so low that no protec-tive clothing is required.
This area will have direct radiation levels less than 2.5 mrem /hr.
2.
GENERAL INFORMATION The Plum Brook Reactor Facility contains a nonoperable test reactor and its inventory of radioactive materials generated as a result of previous i -
operations.
All reactor fuel, special nuclear material, and waste by-product material were removed from the facility.
3.
LOCATION The Plum Brook Station (PBS), a federal reservation of several thousand acres controlled by the National Aeronautics and Space Administration (NASA), is located near Sandusky, Ohio.
It is surrounded by a security fence which is patrolled daily.
The PBS Communication Center, which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> each day, is at the main gate and provides controlled entrance to the station.
The Plum Brook Reactor Facility (PBRF), within the federal reservation, is an area of approximately 27 acres which is surrounded by its own security fence.
Gates in both fences are locked or continuously manned to prevent unauthorized entrance.
Access doors and windows of buildings inside the PBRF fence are locked except during authorized entrance.
These controls will deter un-authorized entry.
Penetration of these controls will not be a radiological hazard to casual intruders since accessible areas outside and inside the i
buildings are white zones.
4.
REACTOR TANK (RT) 4.1 End Condition and Bases The Reactor Tank, located in the Containment Vessel, is surrounded by thick concrete biological walls.
The tank contains the irradiated core structure and components.
Penetrations i1to the RT are closed
. 4
but are not n:cessarily gas tight.
The RT is drained, defueled and covered by the shrapnel shields.
The control rods and drives have been removed.
Piping connected to the RT where practical is sep-arated and blank-flanged close to the RT to reduce the effective volume of the RT. The RT is purged with dry nitrogen through an absolute filter to the stack.
The purge is used to reduce corrosion of components inside the tank.
4.2 Safety Analysis The potential hazards associated with the reactor tank end condition are direct radiation, release of contamination with the nitrogen purge and loss of nitrogen purge flow.
The high radiation level inside the RT, streaming through unshielded RT penetrations, would constitute an immediate and direct hazard to personnel.
Shielding protects against this hazard.
Three shrapnel shields are installed over the reactor tank and limit the radiation level outside the shield to 2.5 mrem /hr.
The holes for the top-most shrapnel shield lifting eyes are welded shut to prevent unauthorized shrapnel shield removal.
All beam holes, through holes and instrument holes are shielded to reduce radiation levels at accessible areas in the quadrants to less than 100 mrem /hr.
The radiation levels at the outer surface of the concrete biological shield surrounding the reactor tank and at accessible areas within the quadrants are less than 100 mrem /hr.
Additional shields necessary to attain this value at penetrations are tack welded in place.
Radiation survey confirms that shielding is adequate for all quadrant accessible areas clas-sified as magenta-yellow zones.
By exercising the control required -
for a magenta-yellow zone, the hazards due to direct radiation are minimal.
It may be possible for the gas purge to become a vehicle to release radiocontaminants into the purge piping and possible release into the environment.
Particulate material inside the 9-foot diameter reactor tank is not likely to be disturbed by the low flow (less then 10SCFH) gas purge.
Even if disturbed and picked up by the gas, these parti-cles would be removed by the absolute filter before the gas vents to the stack.
Twelve years experience at the PBRF has found no stack release of airborne particulate contamination in excess of maximum permissible concentrations (MPC-unrestricted areas).
Thus parti-culate contamination of the nitrogen purge gas is not considered a hazard.
Found during our Engineering Study effort to date (Section 19),
i tritium (H3) is a constituent in the nitrogen purge gas.
The tritium originates from berylium metal in the reactor core box which contains trapped tritium gas as a result of previous neutron activation.
Tritium is capable of slowly migrating out of the berylium molecular lattice. As this occurs, tritium diffuses into the purge gas and is released to the environment from the top of a 100-foot high vent l
stack. A preliminary evaluation of the existing tritium data con-
[
cludes that with atmospheric dilution, stack release of tritium does l I l
i not exceed MPC for an unrestricted area.
The tritium monitoring at the stack will be included during the normal facility monitoring.
Prolonged loss of nitrogen purge could permit air to enter the RT.
This could result in the formation of nitrogen / oxygen compounds by radiolytic reactions.
Some of the reaction products are corrosive t
and toxic.
The corrosive action of the nitrogen / oxygen compounds could cause structural damage and potentially release corrosion products into the purge gas exhaust. The toxic properties of nitro-gen / oxygen compounds are important only if personnel are exposed to them and this situation is not considered likely.
To prevent buildup of nitrogen / oxygen compounds, the RT purge flow is monitored for loss of flow.
Because the corrosion rate would be slow, loss of nitrogen purge and replacement of the nitrogen with air would result in no significant attack on structural components even after several hours of exposure.
Except for special tests or maintenance, nitrogen purge ~
will be reestablished under procedural control within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The continuing need for nitrogen purge of the RT is being reviewed during
~
the Engineering Study described in Section 19.
The degree of hazards associated with the RT end condition is. accept -
able.
5.
CONTAINMENT VESSEL 5.1 End Condition and Bases All readily accessible areas of the Containment Vessel (CV) are decontamir.ated to a white zone. Two primary openings allow the CV to breathe through absolute filters to the atmosphere.
Personnel openings into the CV are closed to the outside except for one door which is locked and monitored by an intrusion alarm.
The truck door is closed and dogged in place.
This door may be opened on a tem-parary controlled basis to accommodate transfer of equipment too large to fit through the personnel door.
All liquid process lines I
which penetrate the CV are drained and blank flanged or capped.
The quadrants, canals and sumps are drained and the sumps are non-operable.
Solid radioactive equipment and components are stored in the quadrants or hot caves.
These CV end conditions are designed to prevent unauthorized entry and to prevent contamination spread by water.
Restricting CV entry to one locked and alarm monitored door precludes unauthorized access to the CV.
Isolation of liquid process lines from the CV eliminates a source of water.
CV flooding by other means, e.g. weather or ground water, is not considered possible due to tha complete continu-ity of the CV structure.
The CV is served by a failing cathodic protection system.
Ultra-sonic measurements of the metal wall below ground show essentially no change in the 3/4 inch metal wall thickness over the past twenty-four years.
CV sample metal coupons are installed in ground water of the deep wells.
These coupons are monitored and the measured results will be related to a probable CV corrosion rate.
Results of ultra-sonic measurements and coupon corrosion rates shall be reviewed to determine the effectiveness and need for a continuing cathodic protection system.
The Cathodic Protection may be terminated after review and conclusion by the PBRF Safety Committee that no unreviewed Safety question exists under the provisions of Section 50.59, 10 CFR part 50.
5.2 Safety Analysis For the CV in a protected safe storage condition, two hazards are considered credible.
They are radiological hazard and an industrial type accident.
The CV contains radioactive equipment and components stored in the quadrants, the canal, or hot caves.
Unauthorized entry could result in uncontrolled exposure to direct radiation and con-taminated materials.
Airborne radioactivity is not a problem since 12 years experience has shown the stored material emits no sig-nificant gaseous decay radioisotopes and the solid contamination does not become airborne.
Personnel entering the CV are subject to.
potential industrial accidents such as falls, sudden illness, etc.
Each type of the credible accident, radiological and industrial, is covered separately.
5.2.1 Radiological Hazard All radioactive or contaminated materials stored in the quadrants, canal or hot caves were shielded or decontaminated to activity levels not exceeding a magenta-yellow zone.
No significant radioactive gas release has been detected from any of the stored material. Material stored in the quadrants and canal have unshielded direct radiation levels less than 600 mrem /hr and further the material is shielded so the accessible radiation levels do not exceed 100 mrem /hr.
Hot Caves containing contaminated material are locked or welded closed.
Unauthorized entry into a magenta-yellow zone is prevented by fences built around these areas.
Fences are provided around the quadrants, the canal and at the entry to the subpile room.
Direct radiation levels at the fences are less than 2.5 mrem /hr. and are within limits for a white zone.
The remaining radiological hazard is associated with flooding in a contaminated area.
This is discussed in Section 16.2.
l 5.2.2 Industrial Accidents Entry into the CV is controlled by written procedure. Authorized l
_g.
1 entry begins by telephone notification to the Communication Center of intent to enter and approximate duration.
Opening the door activates the door alarm system.
The alarm deactivates when the CV door is closed, locked and acknowledge button reset.
Twelve years history shows natural ventilation provides sufficient oxygen content inside the CV.
Fences and railings around the quadrants and canal prevent accidental falls into these reservoirs.
Commercial power failure inside the CV activates emergency battery-powered lights to provide safe visibility.
These practices minimize the risk of an industrial-type accident to an acceptably low level.
Authorized entry ends by leaving the CV, closing and locking the CV door, telephone notifica-tion to the Communication Center and alarm acknowledgment at the Reactor Security Control Building.
If a tour does not end within a reasonable time, the Communication Center initiates a search to check the situation.
It is concluded that the degree of hazard associated with the CV end condition is acceptable.
6.
PRIMARY COOLING WATER SYSTEM AND PRIMARY PUMP HOUSE 6.1 End Condition and Bases The primary cooling water system was flushed, drained and purged with air.
A portion of the system noted in the Reactor Tank section 4 is separated and blank flanged close to the RT.
All valve operators which penetrate into the accessible areas of the Primary Pump House (PPH) are nonoperable. All motor driven devices are disconnected _
from their power sources.
Personnel entryways into the PPH are locked.
The PPH roof hatch plugs, which provide the only personnel access to the shielded rooms, are locked in place and sealed against water entry. All PPH accessible areas outside the shielded rooms are decontaminated to a white zone level.
6.2 Safety Analysis The hazards associated with the end conditions are personnel exposure and spread of contamination.
Entry into the shielded PPH rooms may bring personnel into a magenta-yellow and perhaps a magenta zone where they would be subjected to both direct radiation and transfer-able contamination.
Seepage of, tater into the shielded rooms through the roof hatch plugs due to weather will only spread transferable contamination within the shielded room.
As noted above, all accessible areas outside the shielded rooms are a white zone.
This ensures that personnel on routine entrance of the PPH will not be exposed to transferable contamination.
- Further, because of the shielding walls, direct radiation from the shielded rooms is reduced to white zone levels in accessible areas.
The shielded rooms of the PPH are established as magenta or magenta-yellow zones, as appropriate.
The rooms are posted and the roof hatch plugs locked in place.
Also, the crane hoists which are used to lift the roof hatch plugs are deactivated.
Thus, unauthor-ized entry is prevented.
Weather seals for each of the roof hatch plugs keep rain water from entering the shielded rooms.
These seals are periodically inspected to ensure their integrity.
In addition, periodic remote inspections for water are made in the shielded rooms.
If water is discovered in the rooms, the water will be sampled and disposed of under health physics control.
It is concluded that the degree of hazard associated with Primary Cooling Water System and Primary Pump House end conditions is accept-able.
- 7. ALARM SYSTEMS 7.1 End Condition and Bases All alarms are designed failsafe, i.e., any monitored abnormal condition including loss of electrical power will indicate an alarm condition.
The alarms connect to a summary alarm panel at the Plum Brook Station Communication Center which is continuously manned to provide response to an alarm within one hour.
7.2 Safety Analysis _
Alarm system failure could prevent monitoring of off-normal con-ditions with no indication when monitoring stopped.
The most signif-icant undetected event would be unauthorized entry into the CV.
An intruder could spread contamination as well as become overexposed to radiation.
Alarm system failure is detected by using failsafe design.
Off-normal conditions, including power and system failure, activate an alarm at the Plum Brook Station Communication Center.
It is concluded that the degree of hazard associated with the Alarm Systems end conditions is acceptable.
- 8. ELECTRICAL SYSTEMS 8.1 End Condition and Bases All facility electrical needs are provided by a Cannercial power system.
After loss of electrical power to the facility, loads automatically reenergize upon restoration of power.
8.2 Safety Analysis Commercial power has demonstrated high reliability at the PBRF.
During the past 15 years, only one occurrence led to an outage greater than two hours.
The loss of electrical energy will affect the motor-driven sump pumps and facility lighting.
In the event of a power loss, some flooding may occur.
Ground water flow rates in the sumps do not increase markedly from drier weather periods, so flooding is not likely.
Hazards associated with flooding are covered in Section 18.2.
l Facility lighting is used primarily by inspection and maintenance personnel after their entrance into the facility.
Loss of lighting during these visits could be hazardous, particularly in the contain-ment vessel with no natural lighting source.
To prevent a hazardous situation, strategically located battery power emergency lights actuate automatically upon loss of electrical power.
These units provide ample lighting for personnel to safely find their way from the buildings.
l t
It is concluded that the degree of hazard associated with the Elec-trical Systems end conditions is acceptable.
9.
QUADRANT AND CANAL SYSTEM 9.1 End Condition and Bases The quadrant and canal systems are located in the CV, the Reactor Building and the Hot Laboratory. The quadrants and canals (QC) were cleaned, flushed, drained and are dry.
The deionizer tanks and the filter housing were flushed and left dry.
Resins and filter elements were removed and disposed of as contaminated waste.
Radioactive materials are stored in the quadrants.
Some material, such as spent fuel storage baskets, underwater cutoff saw, supporting tools, and _
o
. - h:ri. rs<rnwed in 0.r.1 G.
All QC are magenta-yellow zones.
Ladders and other means of access to the QC floors are removed or barricaded. Additional fence and railing were provided around the QC.
These end conditions for the QC were chosen to protect personnel and provide a suitable storage location for radioactive or contam-inated hardware. Access to these materials is readily controlled.
9.2 Safety Analysis The hazards associated with the end conditions for the QC are radio-logical and industrial.
The radiological hazard is direct radiation exposure or contact with transferable contamination.
Industrial hazards are those typical for security tours of an industrial estab-lishment during non-work hours.
Each type of the hazard, radio-logical and industrial, is covered separately.
9.2.1 Radiological Personnel could be subjected to both direct radiation and trans-ferable contamination from materials stored in the QC.
As noted previously, the QC are magenta-yellow zones. As such they are posted and entrance is controlled.
Personnel are excluded from such zones by railing or fencing. Airborne contamination is not considered to be a problem because none of the stored radioactive materials has significant gaseous decay radioisotopes and solid contamination is not expected to become airborne.
See section 5 on Containment Vessel._
for further discussion on radiological control.
It is equally applicable for this section.
The QC clean-up deionizer tanks and filter housing have all resins and filter elements removed, the interior surfaces were flushed and left dry.
The exterior surfaces are decontaminated to white zone level while the interior surfaces, from a transferable contamination standpoint, are considered a magenta zone.
The interior surfaces of these units are inaccessible to personnel.
The outside of the tanks and filter housing are posted as areas containing radioactive materi-al.
Further, the building (Fan House) where these units are located is locked and under key control for authorized entry.
These steps reduce the potential of contamination by the QC cleanup units.
9.2.2 Industrial Accidents The Section 5 on Containment Vessel describes the industrial hazards considered and the precautions taken.
This Section should be re-ferred to for consideration of the QC inside the containment vessel.
Entry into the Reactor Building and canals is controlled by estab-lished procedures. The only apparent accident situation associated with the canals are falls.
This event is unlikely because of the fencing or railing located around the canals as demonstrated during the past 12 years.
Battery-powered emergency lights ensure adequate i
lighting is available.
The entries are monitored by approved proce-dures governing entry of persons into PBRF (Buddy System).
It is concluded that the degree of hazard associated with the QC end condition is acciptable.
10.
RADI0 CHEMISTRY LABORATORY 10.1 End Condition and Bases All chemicals, consumable supplies and unnecessary equipment were removed.
The fume hood systems were vacuumed and cleaned as well as practical.
The filters were removed and fan power was disconnected.
Doors on the fume hoods were made secured to prevent opening.
The hoods are maintained in a dry condition and are posted.
10.2 Safety Analysis The exhaust hoods in the Radiochemistry Laboratory contain some residual contamination from use during previous reactor operation.
The contamination adheres to the inside floor, walls and ducting of the exhaust hood system.
The hazard associated with the end con-ditions is the spread of contamination.
Contamination spread is minimized by access prevention.
The exhaust hood doors can not be opened to expose any contamination.
It is concluded that the degree of hazard associated with the Radio-(
chemistry Laboratory end condition is acceptable.
I _ _ _ _
o 11.
HOT DRAIN SYSTEM 11.1 End Condition and Bases The hot drain system and all floor drains were flushed, drained and sealed against water.
The sumps were flushed, cleaned to a practical extent, and sealed.
The sump pump motors are disconnected at the motor control center circuit breakers and are tagged out.
The end conditions were selected to prevent the hot drains and sumps from spreading contamination.
11.2 Safety Analysis Spread of radioactive contamination and direct radiation are the only credible hazards associated with the hot drain system.
If water could enter the hot drain system, become contaminated and then flow into a cold sump, subsequent spreading of the contaminated water could result.
The cold sumps are active sumps that discharge into the PBRF drainage system and flow off-site into Plum Brook.
By sealing the hot sumps and hot drains, spread of contamination is prevented.
The seals will be periodically checked.
Exposure to direct radiation is prevented by the use of fenced and locked ra-diation control zones.
i It is concluded that the degree of hazard associated with the hot drains end condition is acceptable.
6
12.
H0T LABORATORY 12.1 End Condition and Bases The seven hot cells were decontaminate'd to a practical level and contaminated hot lab equipment and tools are stored in these cells.
The hot cell doors are locked closed.
Other areas containing residu-al contamination are enclosed by fences or barriers and are posted.
The Hot Dry Storage area contains radioactive and contaminated materials from previous reactor operations.
The 80-ton access door to the Hot Handling room entrance to the Dry Storage area is locked closed.
12.2 Safety Analysis Hazards associated with the end conditions are personnel exposure and spread of contamination.
Personnel exposure is prevented by the biological shielding design of the Hot Laboratory and limited access through lock and key.
Limited access with procedural control pre-vents contamination spread by personnel.
Contamination spread by water has been no problem as verified by inspections over the past twelve years.
It is concluded that the degree of hazard associated with the Hot Laboratory end condition is acceptable.
- 13. HOT PIPE TUNNEL 4.
D 13.1 End Condition and Bases The Hot Pipe Tunnel was decontaminated to a level as low as rea-sonably achievable and is kept dry.
Water which cannot be pre-vented from leaking into the contaminated area of this underground tunnel will be prevented from escaping.
13.2 Safety Analysis Process piping inside the HPT contains some residual contamination from use during previous reactor operation.
Dams and collectors are installed to prevent migration of water into and out of the contam-inated area.
The hazard associated with the HPT is spread of contamination.
Twelve years experience shows the end conditions to be effective in minimizing spread of contamination by restricting access into the closed systems, controlling access into the HPT and eliminating water sources.
It is concluded the degree of hazard associated with the HPT end condition is acceptable.
14.
WASTE HANDLING BUILDING 14.1 End Condition and Bases The Waste Handling Building was decontaminated to a practical level.
This building contains radioactive materials and equipment from previous reactor operations. Areas containing residual contamination 1
are enclosed by fences or barriers and are posted.
Doors leading to the evaporator room and waste packaging room shall be locked closed.
Access doors to the Waste Handling Building shall also be locked closed.
14.2 Safety Analysis Hazards associated with the end conditions are personnel exposure and spread of contamination.
Personnel exposure is prevented by posted fences and barriers.
The direct radiation at these fences and barriers is less than 2.5 mrem /hr. which is equivalent to the limits of a white zone.
Contamination spread by water has been no problem as verified by inspections over the past twelve years.
It is concluded that the degree of :tazard associated with the Waste Handling Building is acceptable.
15.
EMERGENCY RETENTION BASIN 15.1 End Condition and Bases The Emergency Retention Basin (ERB) was drained and the drain line leading to the ditch remains open to prevent accumulation of rain water.
The bottom of the earthen ERB contains areas with soil having trace quantities of contaminated material, however, twelve years monitoring experience shows the ERB runoff water is below 10 CFR 20 levels for an unrestricted area.
The supply line is blanked shut and the supply pumps were removed.
15.2 Safety Analysis The hazard associated with the ERB end condition is release of contaminated water or soil if the drain plugged permitting accumulated water to damage the basin earth walls by excessive water.
This hazard is very unlikely since the ERB contains eight-foot-high walls and the only water source to the basin is falling rain water.
Normal yearly rainfall does not exceed 48 inches, therefore, the basin could hold over a year's water supply with no threat of damage.
Any large accumulation of water would be discovered on routine periodic inspections and would be corrected.
Even if a break occurred, any residue would settle and accumulate in an adjacent field inside the PBRF fenced area.
It is concluded that the degree of hazard associated with the ERB end conditions is acceptable.
16.
HOT RETENTION AREA (HRA) 16.1 End Condition and Bases Each of the tanks was flushed, drained, cleaned to a practical extent and left dry.
HRA transfer pumps are nonoperable.
All personnel accesses to the area, except one to the annulas and one to the tunnel area are closed against weather and welded against unauthorized entry.
The authorized entries are locked to permit authorized.. _ _. _._.
inspections.
All ventilation louvers which open to the atmosphere are closed.
The exhaust vent to the stack breathes through an absolute filter.
All external surfaces of the Hot Retention Area are decontaminated to white zone level.
The HRA ground water sump pump is activated by high water level.
The sump is monitored for high water level.
16.2 Safety Analysis The hazards for the HRA under the end condition are spread of contamination resulting from entry into the HRA and major damage to the tanks and associated components by floating of the tanks.
Each of these events will be covered separately below.
16.2.1 Spread of Contamination The tanks are to be maintained empty and all isolation valves in the lines to the tanks are closed and sealed. Airborne contamination from the tank interior is also unlikely because of the relatively clean surfaces and the absence of any significant decay products i
which are gaseous.
The only credible way for contaraination to spread from the HRA is by an intruder.
All other ways for contamination to spread are unlikely.
If rain entered the weather covers, the quantity of liquid would be small based on previous experience, and readily removed under radiological control after discovery during.--_
routine inspection.
Access to the PBRF requires the passage through the Plum Brook Station and PBRF fences.
To enter the HRA, the intruder must disable a lock and climb down into the pipe chase.
Since the pipe chase is a magenta-yellow zone, it is possible for transferable contamination to be removed by the intruder.
The events described above, while credible, are highly unlikely.
Passage of a intruder across two locked or manned fences in both directions without observation is possible; however, selection of the HRA for entrance by the intruder is unlikely.
The facility is not only innocuous in appearance but does not contain items of signifi-cant value.
Even if the intruder should enter the HRA, become contaminated, and leave, the amount of transferable contamination carried on the intruder would not be significant in terms of personnel exposure hazard or widescale spread of the contamination.
Thus, it is concluded that unauthorized entry into the HRA is very unlikely and if the event should occur, the magnitude of the contamination problem would be insignificant.
16.2.2 Floating of Tanks The HRA tanks are housed, underground, in a large concrete vault. i
o 9
Footer drains around the vault lead to a ground water sump which 4
maintains the ground water level below the tank bottoms.
In the event this sump pump failed and the ground water level rose sufficiently high to float the tanks, it is conceivable the tanks could erupt through the roof of the vault.
This would result in major damage to the facility, however, the relatively low level of contamination is of little concern.
A high water level alarm provides early warning for prompt action to reduce this occurrence.
It is concluded that the degree of hazard associated with the HRA end condition is acceptable.
17.
CONTAMINATED AIR SYSTEMS 17.1 End Condition and Bases The Contaminated Air system was shutdown after being vacuumed, washed and purged clean through absolute filters.
The roughing filters, prefilters and high efficiency absolute filters were removed.
Fan motors are disconnected.
Air controls are deenergized and vented to atmosphere. All valves and dampers are fixed in a closed position and where applicable the piping and duct inlet and outlet openings are blocked.
This arrangement restricts air movement within the piping.
The man entry ways to the vent stack were welded closed.
The stack drain line to the hot drain system was disconnected to perserve hot drain isolation and the hot drain lines was capped..__
Compared,to the operating mode, the Contaminated Air System end conditions provide a reduced level of contaminants in the vent lines and areas they service which vent to the stack.
This was accomplished by high velocity air purging with manual cleaning to minimize contaminants in accessible areas.
17.2 Safety Analysis The only possible hazard is a release to the stack of contaminants in the system.
This occurrence would spread contamination to the environment.
The impact of this event is a function of the kind and quantity of contaminants released.
A systematic cleanup was performed to remove contaminants from the Contaminated Air System.
Air sample monitoring of selected areas including the PBRF stack, over the past 12 years, verifies the absence of significant airborne activity.
It is concluded that the degree of hazard associated with the Contaminated Air Systems end condition is acceptable.
18.
SAFETY ANALYSIS FOR EMERGENCIES 16.1 Tornadoes and Severe Storms Tornadoes and severe storms are covered in Section 6.3.1 of the Final Hazards Summary, NASA Plum Brook Reactor Facility, Part I.
Statements made therein, which are not related to reactor operations, are still applicable..
=
A tornado is not exprcted to cause physical damags to the reactor tank or the Primary Pump House.
The tank is located below ground l
level inside the containment vessel.
The Primary Pump House is constructed of reinforced concrete. All magenta zones are contained within heavy process equipment of substantial steel or concrete structures and therefore their containment should not be compromised j
by a tornado.
Several magenta-yellow zones exist in the Reactor Building and auxiliary buildings where damage is possible.
j However, the inventory of radioactive materials capable of release is much smaller than when the reactor facility was in operation.
I Tornado damage of the buildings is not expected to release i
4 significant amounts of radioactivity.
Severe storms could cause flooding, power failure, or lightning damage. A power failure could be tolerated.
Lightning damage could
{
not cause release of radioactive materials, but could cause a fire.
Both fires and flooding are covered in separate sections.
The hazards associated with tornadoes and severe storms are
{
acceptable since the radioactive inventory and the potential for
{
spread of contamination are lower than during reactor operation.
i 18.2 Flooding i
Flooding could cause the release of radioactivity, if flood water 27-l I
I t
_ -.,.~,._.- m.w m
m-.____,,
,,.-.._,,_.m...,--,,,-,__,
.,.y,,., _,,
.-% m
.,,,m-~~.y,.,
a washed away radioactive materials contained within the facility.
Examples of magenta-yellow zones having surface contamination are:
(1) the hot sumps and '40t drains, (2) the Primary Pump House, (3) the Containment Vessel, (4) the quadrants and canals where radioactive and contaminated materials are stored, (5) the Hot Retention Area, and (6) other magenta-yellow zones in tne facility.
As discussed in Section 8, the floor hot drains leading to hot sumps and the hot sumps are sealed against water.
Thus, entrainment and spread of contaminants by water is not credible.
Periodic inspection is used to insure seal effectiveness.
As discussed in Section 5, the Pump House roof hatch plugs have weather seals which are maintained.
If a seal should fail, some water could enter the rooms but would be trapped there until cleaned up under health physics control.
Again, spread of contaminants is not credible.
As discussed in Section 3, the process liquid lines were isolated from the CV.
Further, the CV is a continuous steel shell protected by ground water pumps outside the CV.
Even if water entered the CV, spread of contamination outside the CV is not credible.
There is a possibility that some water (such as from a window break) could enter a canal in the Reactor Building.
However, it is not credible that a canal would be filled, since the canals are 25 feet deep.
Thus, any water entering would be contained until cleaned up under health physics control.
As stated in Section 14, entrance of water through or around the HRA weather covers into the pipe chase is unlikely.
Even if it occurred, the quantity of liquid would be manageable and it would be cleaned up under health physics control.
There are several other areas in the PBRF which are magenta-yellow zonas.
Flood water could conceivably wash contaminants from these areas to cold sumps.
Examples of these are the lowest level of the Reactor Building (RB), the basement of the Waste Handling Building (WHB), and the Hot Pipe Tunnel (HPT).
History shows that water from a very heavy storm once entered the -15 foot level of the RB.
It flowed to the lowest level of the building to a cold sump.
No spread of contamintion occurred.
To preclude this event from recurring the following actions were taken:
a.
The locations where surface water entered the RB were identified.
These were a pipe trench, an air intake, and the RB sills.
The trench and air intake were closed, a dam was built to isolate surface water from the RB wall and the trench was modified to provide better drainage away from the RB.
b.
Procedures require an inspection tour of PBRF after every heavy storm.
Action was also taken to protect the WHB against water.
During the aforementioned stonn, small quantities of flood water entered the WHB. Areas where the surface water entered are dammed and covered.
Dams are also constructed at the evaporator and waste packaging rooms where white zone levels are exceeded.
The dams prevent uncontaminated water from entering the rooms and contaminated water from leaving the rooms. Any water found in the rooms will be cleaned up under health physics control.
The Hot Pipe Tunnel HPT area was decontaminated to the greatest practical extent. The decontamination did not achieve a white zone level, so a dam was built across the HPT at the Fan House (FH) interface.
Even under the severest weather only small seepage of water has entered the HPT.
The dam effectively blocks water from spreading into the FH (HPT slopes to FH).
Periodic inspection at the dam is made for water buildup.
If water needs to be removed, this will be accomplished under Health Physics controls.
The hazards associated with flooding are acceptable.
18.3 Earthquakes Earthquakes are covered in Section 6.3.3 of the Final Hazards Summary.
Because of the low probability of a strong earthquake and the nature of the radioactive materials stored in the Reactor Facility (no liquids or gases), the risk associated with release of radioactive materials due to an earthquake is acceptable.
18.4 Fire Likely sources of fire are open flames, electrical wiring, lightning, and sparks from grass fires in the local area.
Procedures prohibit smoking at the PBRF.
Combustibles were removed as much as is practical from areas where radioactive materials stored. A fire in any magenta zone is not deemed credible because of the lack of combustible materials.
The only significant amount of combustible material in the area of contaminated material is the PBRF building roofs.
If the tar or urethane material of the roof caught fire, structural damage to the building might occur. Also, the urethane insulation of the CV dome might catch on fire and do structural damage to the CV.
Neither type of fire would release a significant amount of radiation because the radioactive material is stored at the bottom of quadrants and canals and is contained in or on the surface of solid materials, generally metallic.
It is not credible that a significant part of the radioactive material could be vaporized and carried away.
l l
l The overall fire hazard is much less than when the reactor was operating.
In the event of a fire, the fire fighters are directed by trained personnel according to station procedures which take into,
r account the possible release of radioactivity.
The hazards associated with fire are acceptable.
18.5 Sabotage Hazards due to sabotage are difficult to guard against.
- However, with the Facility in a protected safe storage condition, the motivation for sabotage is decreased by the absence of any nuclear fuel.
For a saboteur to gain access to radioactivity, he would be required to break through the NASA Plum Brook Station perimeter fence, the reactor site fence, and into one of the PBRF building, unobserved by the station armed security patrol.
Since the plant is not operating, neither sabotage nor action by a subversive employee could result in a significant safety hazard.
This is because none of the radioactive material would be readily transportable in large quantities.
The high-radiation-level material in the reactor tank and the hot laboratory could not be removed in a short period of time and there does not seem to be adequate motiva-tion for such action.
The welded shields and shrapnel shields of the reactor tank serve as protection for this material.
The presence of security and lack of motivation renders the risks associated with sabotage acceptable.
18.6 Bombing The only bombing considerations will be for bombs of a non-nuclear i
type.
The most serious situation would occur if the reactor tank was
)
demolished and its contents scattered.
The debris could be scattered over a large area but would remain within the Plum Brook Station perimeter fence.
Since the reactor tank contains solid material, a radiation survey of the survey of the Station should allow the recovery of most of the material. A radiation hazard to the public would not exist since it is not credible that any material, other than an extremely small amount of airborne activity, would leave the station as the result of bombing.
- 19. ENGINEERING STUDIES AND EQUIPMENT TRANSFER New information is constantly required to document existing conditions at reactor facilities.
The PBRF is no exception.
Information will be obtained by measurements, surveys, borings, tests, and other methods as necessary.
This may involve:
a.
Gaining temporary access to controlled areas.
b.
Minor disassembly to obtain access into some equipment or subsystems.
c.
Temporary shield removal for accurate measurements, d.
Temporary change to pertinent existing end conditions.
Items determines by survey to be non contaminated and not required for protected safe storage may be released for reuse in accordance with approved procedures.
Some specialty items such as hot cave windows, manipulators, or experiment handling equipment known to be contaminated, will upon request, be cleaned to a practical extent and may be transferred to another licensee, in accordance with 10 CFR Part 30.
These activities will be procedurally controlled and will require review and approval of the reactor engineer and of the PBRF Safety Committee to assure that the activity may be accomplished safely, is within the PBRF license requirements and involves no unreviewed safety question.
20.
ENVIRONMENTAL IMPACT The PBRF contains a nonoperable reactor with no fuel, no special nuclear material, no free by-product gaseous or liquid radioactive material. Major radioactive items are stored at four locations; in the Containment Vessel, the Reactor Building, the Hot Laboratory and in the Waste Handling Building.
As shown in the safety analysis, these items are confined and protected from unauthorized personnel and water entry.
The confinement prevents personnel access to the radioactive material and the protection restricts the spread of contamination.
This condition will not significantly affect the environment.
An Environmental Report for the Plum Brook Reactor Dismantling was prepared in February 1980.
From this, an NRC-prepared environmental impact appraisal was made available for public inspection at the Commission's Public Document Room 1 i
r at 1717 H Street, N.W., Washington D. C.
The Commission concluded an environmental impact statement is not warranted because of a finding of no significant environmental impact attributable to the proposed action.
A condition of possess-but-not-operate protected safe storage will have less environmental affect than dismantling.
Consequently, there will remain no significant environmental impact attributable to this proposed action.