ML20134K299

Responds to 960816 RAI Re Requests for Exemption from Certain Parts of Regulation,Bases for Such Requests & Detailed Info Re Facility

ML20134K299
Person / Time
Site:	University of Lowell
Issue date:	10/31/1996
From:	Bettenhausen L MASSACHUSETTS, UNIV. OF, LOWELL, MA (FORMERLY LOWELL
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9702130231
Download: ML20134K299 (4)

Text

. NOV-01-1996 16:24 FRCH U.Lowell. Rad. Lab.

TO 13014152260 P.02 4

TNIVERSITY OF MASSACHUSETTS LOWELL Radiation Laboratory 1 University Avenue Lowell,MA 01854 i

(508) 934-3365 October 31,1996 Docket No. 50-223 License No. R-125 U.S. Nuclear Regulatory Commission Document Control Desk Washington D.C. 20555

SUBJECT:

ADDITIONAL INFORMATION This responds to a letter from T.S. Michaels dated August 16,1996. It responds to questions regarding requests for exemption from certain parts of the regulation, the bases for such requests, and detailed information regardmg the facility.

1 The response to questions as posed is attached. Should you need further information, please contact me or Mary Montesalvo, Radiation Services Manager.

AA Mee H.

ausen, P.E., Ph.D.

I Reactor Supervidor l

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9702130231 961031 DR ADOCK 05000223 p

PDR 130042

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. NOV-01-1996 16:24 FROM U.Lowell, Rad. Lab.

TO 13014152260 P.03

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RESPONSES 10 8/16/% REQUEST POR ADDITIONAL INPORMATION l

EXEMPTION REQUESIS POR GAMMA CAVE AT THE UNIVERSITY OF MASSACHUSETIS f

1 LOWELL RESEARCH REACTOR J

i 1.

The minimurn number of Cobalt strips meeting the scenario posed is one strip. The source strengths vary from 70 Ci to 1100 Cf. Treating the weakest source as a point and taking the distance to the door opening of 12 feet, D calc = 7 R/hr. This is consistent with repeated measurements using a 3-strip rack of activity 251 Ci which gave 50R/hr at 8 3/4 ft from the l

window. The meter used for cave entry monitoring is used on a low scale of 0-5 ll millirem /hr.

2.

See above.

The strips continue to provide useful radiation levels after 3 half-lives at Iowdl; no i

projection has been made regarding the end of useful life of the cobalt strips. his question win need to be revisited near the time of reactor license expiration in 2015.

3.

In the first 8 months of 1996, the radiation monitoring system was cheued on 69 days of 143 days available for reactor operation. At the time of system checkout on 13 of those days, the gamma cave was in use and that portion of the system could not be tested since entry to the i

1 access corridor was prohibited. The contact Q1 is a normally closed relay contact in the l

Radiation Monitoring System module (Tracerlab TA-30 Station Indicator) which is held open by bypass current flowing through a parallel gated SCR. Removal of power or failure of components on the module results in Q1 closing and initiating the warnings and alarms as j

though a high radiation level were detected. Once the contact has closed, manual action is required for reset.

4.

The in-cave detector and the in-cave cable ends failed from a combination of high radiation levels and damp environment. The in-cave system has not functioned at any time in the memory of present staff members.

S, The bell warning of cobalt source move can be heard clearly in the Gamma Cave.

6-In order to answer the question in detail, the wiring would have to be disassembled.

Functional tests show that the red light is activated when the in-cave alert switch is thrown.

7.

The radiation survey meter is held a8ainst a check source fastened to the wall to the left of the cave door prior to unlocking the door.

8.

3633 Requirement UMLRR TS or Daalan Feature i

(c) A means to replenish water TS 2.1.3 The true value of pool water j

losses to the pool.

level shall not be less than 24 feet above i

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the center line of the core. A supply system described in Safety Report fulfills this 'IS requirement.

i (d) A visible indicator must be An audible and visible alarm is sounded l

provided in a clearly visible at the continuously manned police location if the pool water dispatch console if poollevelis-13/4". A i

level'is below normallow low pov11evel alarm is sounded in the water level.

control room at -21/2" and a scram occurs (with visible and audible alarms) at -71/2" per TS table 3.2.

I (e) Fools must be equipped witit a TS 3.8.1 The conductivity of the pool water i

purification system capable of

' shall be maintained at a value of 5 microsiemens.

l maintaining 20 microslemens per cm or less averaged over a month.

per em nr less and with a clarity so that the sources can be seen j

clearly.

)

(f) A physical barner must be used The UMLRR pool is designed w that a waist-around or over irradiator pools high pool wall surrounds the pool. Workstations during normal oper. don to prevent such as the gamma cave window and the rolling l

personnel from accidentally falling work platform have railings to further provide

{

into the pool.

protection against falling.

(g) If long handled tools or poles are used The handling tools used are water-filled hollow in irradiator pools, the radiation dose tubes.without streaming paths. An area monitor rate on the handling areas may not at the handling area alarms in the central control exceed 0.02 mil 11 sievert per hour.

room at 0.03 millsievert per hour and locally and again in the control room at 0.1 millislevert 1

per hour.

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9.

In regard to 36.37(c), the operator uses an operable and calibrated radiation survey meter l

located just outside the control mom and a flashlight located in the control room to visually assure control blades are inserted into the core. The operator would at this time also note the i

positions of the cobalt sources. Operator instructions (Emergency Operation 8) then state that i

containment should be secured (i.e., the cobalt sources and experiment left in their pnsitions t

prior to the loss of electrical power. No attempt would be made to move sources or access l

experiments until power is restored or an Emergency Team under an Emergency Director takes action under the Emergency Plan.

3

10. UMLRR Technical Spedfications state,"T.S. 4.5.2 The radioactivhy in the pool water shall be analyzed weekly." The technical spedfication change which accompanied the license amendment for cobalt possession stated that the analysis shall be capable of detectmg levels of 1 x 10-7 micro Ci per ml. If sample analysis reveals a significant increase of activity in the 4

j water or a contamination level greater than 1 x 104 mic:ro Ci per m1, prompt action shall be

NOV-01-1996 16*26 FROM U.Lowe11 Rad. Ltb.

TO 13014152260 P.05 taken to prevent furthe-contamination. If the gross activity of the sample is less than 1 x 10-7 micro Ci per m1, specific analysis for Co-60 need not be performed. These analyses have been performed since 1982. An analysis of sample tesults for the past two years showed tlutt detectable levels of Co-60 are absent when the reactor does not operate at significant megawatt-day levels. Co 60 is only occasionally detectable as a result of reactor operation and has not exceeded 1.5 E-8 micro Ci/ml in the past two years.

11. Reaulrement of E36.61(a)

UMLRR TS (1) Operability of each access control 4.3.2 Radiation Monitoring System semi system.

annual calibration. The access control system is tested in an appendix to the test of this system.

l (2) Functioning of the source position Exemption requested; there is no source indication.

position indicator as explained often.

(3) Operability of radiation system and 4.3.1 Radiation monitoring system checked (4) monitors prior to each [ reactor) operation.

(7) Leak tightness of systems through 2.1.3 Pool water level which pool water circulates.

2.2.2 Fool water level and (9) Operability of the means of pool 3.2 Fool water level l

water replenishment.

4.2.2 Fool water level and (10) Operability of the indicator of high 4.2.4 Pool water Icyc1 and low pool water levels.

(11) Operability of the intrusion alarm.

Security Plan, p. 27 (14) Amount of water added to pool to Good practice to insure TS 2.1.3,2.2.2, 3.2, determine if pool is leaking.

4.2.2, and 4.2.4 are met.

l (15) Electrical wiring on required safety 4.3 Radiation Monitoring system rec uires systems for radiation damage.

maintenance, surveillance, and qualuty assurance.

1 TOTAL P.05