ML20149M755

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Proposed Tech Specs,Responding to RAI Concerning Request for Amend to License TR-3 for Renewal of possess-but-not-operate License
ML20149M755
Person / Time
Site: Plum Brook
Issue date: 01/31/1997
From:
NATIONAL AERONAUTICS & SPACE ADMINISTRATION
To:
Shared Package
ML20149M753 List:
References
NUDOCS 9701270203
Download: ML20149M755 (28)


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APPENDIX A TECHNICAL SPECIFICATIONS FOR THE LICENSE NO. TR-3  !

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION l PLUM BROOK STATION I

. SANDUSKY, OHIO l

DOCKET NO. 50-30 JANUARY 1997 I

3 9701270203 961220 PDR ADOCK 05000030~

P PDR ,

Table of Contents Eage

1. Introduction - -- -

1 1.1 Scope- 1 1.2 Applications - 1 1.3 Definitions -

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2. Requirements- -

4 2.1 Control of Access to PBRF Site- 4 2.2 Reactor Tank (RT) 4 2.3 Containment Vessel (CV)-- 5 2.4 Primary Cooling Water System and Primary Pump House 6 2.5 Alarm System 7 2.6 Quadrant and Canal System 8 2.7 Radiochemistry Laboratory 9 2.8 Hot Drains 9 2.9 Hot Laboratory 10 2.10 Hot Pipe Tunnel 10 2.11 Waste Handling Building -- 11 2.12 Emergency Reternon Basin 11 2.13 Hot Retention Awa 12 2.14 Contaminated Air System 13 2.15 Designated Storage Areas within PBRF 13 2.16 Access to Radiological Control Zones 14 2.17 Alarm Response 15 2.18 Facility Radiclogical Monitoring 15 2.19 Procedures - - - - -

16 2.20 Inspection, Test, and Surveys 16 2.21 Nitrogen Purge System 17 2.22 Cathodic Protection System 18 2.23 Primary Pumphouse Roof Plugs 18

3. Administrative Controls --

19 3.1 Organization -

19 3.2 Procedures -

23 3.3 Reports 23 3.4 Records-- 24

4. References 25

Attachment:

) Figure 1 Generic Organization Chart

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'1. Introduction Where applicable, these Technical Specifications follow the format of the American National Standard ANSI /ANS-15.1-1990. I 1

l l l 1.1 Scope i

These Technical Specifications apply to all portions of the Plum Brook Reactor Facility (PBRF), with the exception of the Mock-Up Reactor (MUR) l which is separately licensed. The PBRF contains a non-operable test reactor, its support facilities, and its inventory of radioactive materials

! generated as a result of previous operations. The reactor was shut down l in 1973 after 98,000 megawatt days of operation.

The radioactive inventory, with the exception of distributed radioactive material existing as contamination within process systems and laboratories, is stored in four locations. These are located inside of the Containment Vessel, in the Reactor Building Canal G, in the Hot )

Laboratory, and in the Waste Handling Building. The PBRF contains no l

l fuel and no special nuclear material.

1.2 Application l These Technical Specifications govern the condition of the National j l Aeronautics and Space Administration's PBRF in the Possession-Only j status. The PBRF is described in the Design Manual and Hazard Analysis I

! submitted for the original PBRF license and now contained in Docket No.

! 50-30. The PBRF systems which are radioactive, contaminated, or reouired to maintain a protected safe storage condition, are covered in these Technical Specifications. These systems are listed in the Table of Contents for these Technical Specifications under the Requirements Section (Items 2.2 through 2.14 and 2.21 through 2.23).

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1.3 Definitions 1.3.1 General Authorized Entry - Entry to the PBRF which is sanctioned by the l

PBRF Engineer or his designee, for those persons having a legitimate need to enter and who have knowledge of the conditions, hazards, and procedures at the facility, or who are accompanied by an authorized person with this knowledge.

l Clean - The condition of an area wherein contamination levels do not exceed 20 dpm alpha /100 cm2 and 1000 dpm beta-gamma /100 cm2 transferable; 500 dpm alpha and 1500 dpm beta-gamma fixed.

Kent Dry - The condition of an area which is normally dry, or drained and mopped dry as soon as practical after becoming inadvertently wet.

Non-ooerable - The condition of a component or syctem which has been intentionally disabled to prevent it from performing its intended function.

Protected Safe Storage - The custodial state of undefined duration characterized by physical and procedural access control and periodic l

monitoring, maintenance and inspection.

l Shall - The word "shall" is used to denote a requirement.

I Surveillance Freauency - Unless otherwise stated in these specifications, periodic sun'eillance tests, checks, calibrations, and examinations shall be performed within the specified surveillance l intervals. In cases where the elapsed interval has exceeded 100% of l the specified interval, the next surveillance interval shall l commence at the end of the original specified interval. Allowable 1

surveillance interval, as defined in ANSI /ANS 15.1 (1990) shall not exceed the following:

1. Annual (interval not to exceed 15 months).
2. Semiannual (interval not to exceed seven and one-I half months).

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3. Quarterly (interval not to exceed four months).
4. Monthly (interval not to exceed six weeks).

1.3.2 Radioactive Materials Contaminated Material-Irradiated or non-irradiated items containing particles of radioactive materials on their surfaces.

Radioactive Material-Items which have been activated as a result of previous reactor operations. These may also be contaminated.

1.3.3 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 the 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 alpha /100 cm2 and 10,000 dpm beta-2 gamma /100 cm2 transferable; 2,500 dpm alpha /100 cm and 8,000 dpm beta-gamma fixed. The magenta-yellow zone, for purposes of direct radiation control, is any area which could expose major portions of the body to direct radiation levels from 2.5 to less than 100 mrem /hr.

White Zone - Is an area with contamination levels below 20 dpm 2

alpha /100 cm2 and 1,000 dpm beta-gamma /100 cm transferable; 500 dpm alpha and 1,500 dpm beta-gamma fixed. In this area, direct radiation levels to major portions of the body shall be less than 2.5 mrem /hr and no protective clothing is required.

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2. Reauirements 2.1 Control of access to the PBRF Site l Acolicability - This specification applies to protection of the PBRF Site by control of access.

Objective - The objective is to prevent unauthorized entry.

Soecification:

I Access to the PBRF shall be controlled by means of two fences with locked gates. The outer fence surrounds the Plum Brook Station; the inner fence surrounds the PBRF. In addition, access to all buildings within the PBRF l

is controlled by means of locked entrance doors.

Bases:

Access to the PBRF is limited by two physical barriers (fences) each with locked gates. Access to keys for the gates in the outer fence surrounding l the Plum Brook Station is controlled by the Plum Brook Station l Management Office. Access to keys for the gates in the irmer fence

! surrounding the PBRF is controlled by the PBRF Engineer and is limited

! to authorized personnel.

l 2.2 Reactor Tank (RT)

Acolicability - This specification applies to the contaminated and radioactive material which makes up the reactor tank, and the contents within.

Obiective - The objective is to safely store the irradiated materials and control radiation levels.

Specification:

l a. The reactor tank, which is surrounded by a thick concrete biological l

shield, shall be drained and maintained in a dry condition. All tank l nozzles and penetrations which could stream radiation shall have shields fixed in place.

b. The three shrapnel shields (20 tons each) shall be positioned above the reactor tank.

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c. Radiation levels at accessible reactor tank surfaces shall be less than 100 mrem /hr.
d. All openings shall be closed, except those openings required for a dry gas purge through an absolute filter to the stack. )
e. The sub-pile room door shall be closed and locked except for authorized entry. l

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l High radiation levels inside the RT, and streaming through RT penetrations, are contained by the shielding methods described.

I a. Past experience with protected safe storage at PBRF has I

demonstrated that shielding described in this section is adequate to permit classifying of all accessible quadrant areas around the reactor tank as magenta-yellow zones.

b. The reactor tank top is covered with three shrapnel shields for radiation shielding.

l c. Additional shields are tack welded in place where needed to reduce radiation levels to below 100 mrem /hr in all accessible areas.

l d. In addition, during the past years of protected safe storage, airborne 1

contamination has never exceed maximum permissible l concentration in unrestricted areas. Since 1993, airborne l

contamination has never exceed the Derived Air Concentrations (DAC) in unrestricted areas. Therefore, additional protection l against airborne radioactivity is not required outside the tank.

e. Access to sub-pile room is per approved written procedures.

2.3 Containment Vessel (CV)

Applicability - This specification applies to protected safe storage of the reactor and contents inside the CV.

Obiective - The objective is to control personnel access to the CV and prevent entry of water which could be a vehicle to spread contaminated material.

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l Specification:

a. The CV shall be provided with two primary openings designed to ,

1 breathe the CV to atmosphere through absolute filters.  !

, b. One of the two existing personnel doors shall be used for controlled i

personnel access. This door shall be locked to prevent .

1 unauthorized entry. The other door shall be operable only from the )

1 inside as an emergency exit.

c. The truck door shall be closed and dogged in place except during temporary controlled periods to accommodate transfer of equipment which is 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 from 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: l Specification 2.3(a) provides authorized personnel an inhabitable atmosphere in the CV, eliminating the need for air packs or other respiratory equipment. Specifications 2.3(b) and (c) limit entry to j authorized personnel and Specification 2.3(d) eliminates all outside l

sources of water entry which could spread contamination from the CV.

The only other source of water is from moisture condensation. A dry, protected, safe storage, with access control, is provided by these specifications.

2.4 Primary Cooline Water System and Primary Pumn House (PPH)

Aoplicability - This specification applies to protectio 1 and safe storage of the primary cooling water system outside the CV. This includes piping to the primary pump house, primary pumps, heat exchanger and deionizers.

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Obiective - The objective is to isolate the RT from the PPH, control access and prevent spread of contaminated materials.

Specification:

l a. The primary cooling water supply and return headers shall be blank-flanged to isolate the reactor tank from the Primary Pump

House (PPH). Lines between the blank flanges and the PPH shall be j drained.
b. The PPH roof hatch plugs shall be in place. The roof hatch plugs i

and personnel doors of the PPH shall be locked except for

authorized entry.

Bases:

l These specifications provide a dry primary cooling water system outside the CV and prevent unauthorized access to the system in the PPH.

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2.5 Alarm System

} Applicability - This specification applies to the alarms listed below as a, b, I and c.

Obiective - The objective is to receive a warning of off-normal conditions.

Specification:

An alarm system shall be operating to provide local alarms at the PBRF and a summary alarm at the Plum Brook Station Communication Center.

The individual alarms at the PBRF include:

a. CV Entry
b. Loss of Power
c. Sump Alarm The alarm response is provided in Section 2.17.

Bases-This specification provides a warning system to alert the Communication Center of an off normal condition. These off-nornal alarms are as follows:

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l a. Entry Alarm willindicate entry to the CV; i

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4 b. Loss of Power Alarm will indicate a loss of electrical power at the ,

' 'l PBRF; l l

c. Sump Alarm will indicate a high level in one of the PBRF l

} cold sump areas. j

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i 2.6 Ouadrant and Canal System Applicability - This specification applies to the Quadrant and Canal System for protected safe storage, except for Canal H which is covered under the R-93 license.

Obiective - The objective is to provide a safe storage area for contaminated l and radioactive materials.

l Soecification:

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a. The quadrants and canals are clean, drained, and shall be kept dry.

i a b. The deionizer system was flushed and drained and shall be isolated

by valves and flanges. The deionizer shall not contain ion exchange material.
c. The quadrants and canals within the CV are Magenta-Yellow Zones.

Small localized fenced areas within the quadrants are Magenta Zones because of the field from the reactor core.

Bases:

These specifications provide for a secure and dry Quadrant and Canal System through the following:

a. The Quadrant and Canal systems are visually inspected for any accumulation of water under written approved procedures;
b. The Quadrant and Canal systems are surrounded by fence and locked gates to prevent unauthorized access;
c. Since there is no water in the Quadrant and Canal systems, there is )

no longer a need for a purification system.

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2.7 Radiochemistry Laboratory Applicability - This specification applies to the chemical fume hoods of the Radiochemistry Laboratory.

Objective - The objective is to prevent unauthorized personnel access and uncontrolled entrance of water to these areas.

Specification:

The chemical fume hood doors shall be welded closed to prevent opening and hoods shall be kept dry.

Bases:

Contamination spread is minimized by access prevention. Periodic 1

inspection and surface smears assure control of contamination. The ,

outside of the hoods are not contaminated.

2.8 Hot Drain System.

I Applicability - This specification applies to the protected safe storage of the j Hot Drain System throughout the PBRF.  !

l Obiective - The objective is to prevent spread of radioactive materials remaining in the hot drains.

Specifications:

l The Hot Drain System shall remain "non-operable" as defined in Section 1.3.1.

a. All accessible (white zone) external surfaces shall be clean.
b. All floor drains and other flow paths supplying a hot sump shall be l

l l plugged or sealed.

c. All seals on hot sumps and drains, and all plugged floor hot drains shall be checked annually to insure their integrity.
d. The hot drain pump motors shall be de-energized from the power bus at the motor control centers.

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Bases:

j These specifications provide for a static, relatively clean, Hot Drain System through the following:

a. Decontamination of external surfaces will remove loose radioactive

! material; l b. Plugging access to the Hot Drain System prevents inadvertent entry 1 of water into the system; and

c. Draining the hot drains and maintaining them dry eliminates the i need for the hot drain pumping system.

2.9 Hot Laboratory and Hot Drv Storage Applicability - These specifications apply to protected safe storage in the Hot Laboratory including the Hot Dry Storage.

Obiective - The objective is to prevent unauthorized entry to contaminated or radioactive material storage areas.

Specifications:

Hot cell doors and the 80-ton access door to the Hot Dry Storage area shall be locked. Access doors to the Hot Laboratory shall be locked.

Bases:

Authorized access with procedural control prevents personnel exposure and spread of contamination.

2.10 Hot Pipe Tunnel (HPT)

Applicability - This specification applies to the protected safe storage of the Hot Pipe Tunnel.

Obiective - This objective is to prevent personnel access and entrance of water to this area.

Specification:

a. The Hot Pipe Tunnel entrances at each end of the tunnel shall be padlocked closed.

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b. The tunnel shall be kept dry.

Bases:

These specifications provide for control of the Hot Pipe Tunnel through the following:

a. Authorized access with written procedural controls prevents personnel exposure and
b. Inspection of the tunnel per authorized written procedures assures that it is kept dry.

2.11 Waste Handling Building (WHB)

Apolicability - This specification applies to protected safe storage of the i Waste Handling Building.

Obiective - The objective is to prevent unauthorized entry to the Waste l Handling Building. t Specifications:

a. Access doors leading to the Waste Handling Building shall be l

locked closed. l l

b. Access doors to the evaporator room and waste packaging room -

shall be locked closed.

Lues These specifications provide for control of radioactive materials and contamination in the Waste Handling Building because authorized access  ;

through written procedural control limits personnel exposures. This applies to all areas described in Specification 2.11 Sections a and b.

2.12 Emergency Retention Basin (ERB) 7 Applicability - This specification applies to the protected safe storage of the ERB.

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I l Obiective - This objective is to minimize the accumulation of water in the ERB and to prevent the release of a potential source of contaminated liquid to the environment.

Specification:

a. The ERB drain line shall remain open to prevent rain water 1
accumulation in the basin.
b. Any accumulated water shall be sampled quarterly to verify that l

limits of 10 CFR Part 20, Appendix B, Table II, " Radioactivity in Effluents to Unrestricted Areas," are not exceeded.

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c. The pumps shall be removed from the supply line.

Bases:

Water samples per authorized written procedures assure that ERB water discharges have not exceed the limits of 10 CFR Part 20, Appendix B Table II, Column 2, " Concentrations in Air and Water Above Natural Background."

l 2.13 Hot Retention Area (HRA)

Applicability - This specification applies to protected safe storage of the HRA.

Obiective - The objective is to control access and prevent release of contamination from this source.

Specification:  ;

a. The HRA tanks, which are flushed and partially decontaminated, )

shall be kept dry.

b. All HRA entrances or access plugs are welded closed, except that one entrance to the annulus and the tunnel area shall be locked to allow
only authorized entry.

Bases:

These specifications provide for authorized access and preclude inadvertent exposure of personnel. These specifications also mitigate 1

against liquid accumulation and release of potentially contaminated liquid. j i

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2.14 Contaminated Air Systems (CAS) ,

Applicability - This specification applies to protected safe storage of the contaminated Air Systems (CAS) which includes the Stack.

1 Obiective - The objective is to provide controlled access into relatively j

clean CAS.

, Soecification:

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1 l a. These systems shall include the 5-foot diameter,100-foot-high stack l and all contaminated air ventilating systems except those presently l 1

serving the reactor tank, CV and HRA.

! b. The fan motors shall be de-energized from the power bus at the l motor control centers,

c. All manual and automatic operated valves shall be disabled in a fixed closed position.  ;
d. The CAS which were vacuumed, partially decontaminated and l purged, shall be kept dry with absolute filters removed.

Bases:

The CAS has been vacuumed to remove loose contamination, was l

purged, and is maintained in a dry condition for use, if required. The CAS .

l can, with minor repairs be placed in operation, when and if required. Past j l monitoring under the above conditions verifies the absence of airborne ]

radioactivity. The above program will continue to maintain the CAS in a j low radiation condition.

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l 2.15 Designated Radioactive Storage Areas Within PBRF l Applicability - This specification applies to the monitoring and

( surveillance of the radioactive storage areas within the PBRF.

Obiective - The objective is to identify the areas for radiological control.

l Soecification:

a. Radioactive material associated with the PBRF, with the exception of distributed radioactive material existing as contamination within process systems and laboratories, shall be stored in four areas:

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1. The Containment Vessel
2. The Reactor Building Canal G
3. The Hot Laboratory which includes the Hot Cells and the Hot Dry Storage Area
4. The Waste Handling Building
b. Storage areas shall be posted as Radiological Control Zones, defined in Section 1.3. Radiological monitoring of these areas shall be l performed in accordance with PBRF Inspection Test Report #11

( (ITR #11), " Facility and Environmental Radiological Monitoring."

Bases:

The specifications identify the areas used for radioactive material storage and define the control for these radiological control zones.

2.16 Access to Radiological Control Zones Applicability - These specifications apply to surveillance of radiological control zones at the PBRF.

Objective - The Objective is to provide surveillance systems for these zones.

Specifications:

a. Magenta zones shall be posted. Access to magenta zones shall require continuous radiation monitoring by health physics personnel, use of safe work permit, and use of personnel dosimetry.
b. Magenta-yellow zones shall be posted. Access to magenta-yellow l

zones shall require health physics monitoring, and control and use

of personnel dosimetry.
c. White zones - Access to white zones shall be by authorized personnel, without health physics personnel monitoring.

Bases:

Written procedural control, implementation of ALARA, and conformance to 10 CFR 20 standards assure satisfactory surveillance of the radiation control zones at the PBRF.

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2.17 Alarm Response i Applicability - This specification applies to alarm response.

Obiective - The objective is to control access to the CV, monitor facility electrical power, and control ground water infiltration. 1 Specification: ,

1 All alarms shall annunciate in the Communication Center (CC). The CC 1 j is continuously staffed. Response to alarms shall include visual l inspection to determine the cause. Response shall be within one hour of  ;

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annunciation. The following conditions shall initiate alarms:

a. CV Door Open
b. Loss of Facility Electrical Power l
c. Hot Retention Area Sump High Ground Water l I

Alarms shall be continuously operable except during maintenance. If l alarms are to be replaced, the alarm system may be inoperable for periods not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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l Bases:

This specification ensures a response for abnormal conditions during the protected safe storage condition.

1 2.18 Facility Radiological Monitoring

. Applicability - This specification applies to routine radiological surveys at 1

l the PBRF. )

Obiective - The objective is to determine that radioactivity is confined to l radiological control zone .

Specification:

Routine radiological surveys shall be performed quarterly by trained health physics personnel using survey and counting equipment commensurate with sound health physics practices.

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Bases: l This specification ensures that radioactive levels are maintained i consistent with 10 CFR 20 limits and with ALARA.

2.19 Procedures Applicability - This specification applies to approved written procedures that help administer the protected safe storage condition.

Obiective - The objective is to list the types of procedures required for protected safe storage conditions.

Specifications:

Detailed written and approved procedures shall be in effect covering the following areas:

a. Response to alarms
b. Entrance to the PBRF, PBRF building, Containment Vessel, and radiological control areas
c. Facility and environmental radiological monitoring and i surveillance
d. Facility changes
e. Response to emergencies that may arise from fire, floods, and tornadoes
f. Training program for the PBRF Manager and Alternate
g. Maintenance programs These procedures shall be approved by the PBRF Safety Committee Bases:

This specification ensures protected safe storage procedures are provi<ied.

2.20 Inspection. Tests, and Surveys l Applicability - This specification applies to a program of inspections, tests, L and surveys during protected safe storage.

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Specification:

Inspections, tests, and respective frequencies shall be performed as follows:

Frequency

a. PBS Fence Integrity Inspection Quarterly
b. PBRF Fence Integrity Inspection Monthly l
c. Building and CV Locks Inspection Monthly .
d. Building and CV General Condition Inspection Monthly -
e. Alarm Tests Quarterly
f. Facility Radiological Surveys Quarterly
g. Environmental Radiological Surveys Quarterly .

l h. Absolute Filters Inspections Annually ,

! i. CV Integrity Test Annually l

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The PBRF Engineer shall review results of the inspections, tests, and l surveys and assure necessary corrective actions are taken to preserve the l 1 ,

protected safe storage condition.

Bases:

These inspections, tests, and surveys provide a reasonable assurance that radioactivity is controlled and personnel exposure is minimized.

2.21 Nitrogen Purge System (NPS)

Applicability - These specifications apply to protected safe storage of the RT internal ,urfaces by means of maintaining a dry nitrogen purge.

Obiective - The objective is to maintain the dry nitrogen purge of the RT.

Specifications:

a. The NPS shall remain in constant operation, continuously flowing dry nitrogen through the RT in order to reduce the corrosion of any interior surfaces and components.
b. The NPS will be continually monitored for proper operation, and an alarm shall sound in the event of either high (blockage) or low f

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(loss of supply) nitrogen pressure. From the time of this alarm the system will be restored to normal operation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Bases:

These specifications provide a means to reduce corrosion within the RT and to provide a warning of loss of system function.

l 2.22 Cathodic Protection System (CPS)

Apolicability - These specifications apply to the protected safe storage of the CV by means of maintaining the CPS. l Obiective - The objective s to insure the physical integrity of the CV. l Specifications:

a. The physical integrity of the CV shall be maintained by means of the CPS. This system shall consist of sacrificial anodes located in deepwells around the CV, and the associated wiring and control equipment. Proper operation of this system will prevent corrosion of the CV by groundwater.
b. The CPS will be checked on a quarterly basis for proper operation.
c. If the CPS is non-operable during two consecutive quarterly checks, )

1 procedures will be instituted to monitor the integrity of CV by means of below grade ultra-sonic thickness readings. This monitoring activity will continue until the CPS is returned to service.

Bases These specifications provide a means to protect and monitor the physical integrity of the CV.

2.23 Primary Pumphouse Roof Plug (PPH RP)

Applicability - These specifications apply to the protected safe storage of the l Primary Pump House (PPH) by means of insuring that the weather seals l on the Roof Plugs (RP) remain intact.

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Obiective - The objective is to prevent water entering into the pump rooms within the PPH.  ;

Specifications:

a. The PPH RP's shall be installed with intact weather seals at all times, except when the RP's are removed for facility maintenance,
b. The quality of the weather seals will be monitored by annually -

checking the PPH pump rooms for any accumulated moisture.

c. Following any period of maintenance which requires the removal of the RP's, the weather seals will be replaced in full.

Bases:

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- These specifications provide a means to ensure no water enters the l PPH pump rooms.

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! 3. Administrative Controls 3.1 Organization -

The Plum Brook Reactor Facility is owned by the National Aeronautics and Space Administration (NASA), which shall be responsible for j l maintaining the protected safe storage condition as required by these i Technical Specifications. NASA shall provide whatever resources are j required to maintain the PBRF in a condition that poses no hazard to the l general public or to the environment. Figure 1 charts the generic l

organization.

! j j 3.1.1 Level 1 Directorate  !

The Directorate Head shall be responsible for assuring compliance l with the reactor facility's license and providing regulatory reports and correspondence. He or she shall have overall responsibility for  ;

the protected safe storage of the facility.

The Directorate shall provide the resources to maintain the PBRF in i

protected safe storage.

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l: i 3.1.2 ' Internal Audit An annual internal audit shall be performed at the PBRF. The audit shall be performed by an audit committee chaired by a NASA employee. The remainder of the committee members may be NASA-personnel or NASA contractor personnel who have nuclear  ;

experience. Neither the chair nor the committee members shall be directly associated with the facility. Special attention shall be given to compliance with procedures, the NRC licenses, regulations, and recordkeeping. 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.

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3.1.3 Radiation Safety Officer (RSO)

The RSO shall be responsible for organization, administration, and  ;

direction of the radiological control and monitoring program, as required by these Technical Specifications, and shall 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 i 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 or the equivalent 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.

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3.1.4 Executive Safety Board (ESB)

The ESB serves as a Lewis Research Center (LeRC) safety policy and decision making board, and is responsible to the Center Director for the overall direction of the Lewis Safety Program. The ESB established a system of Safety Committees to conduct detailed third party reviews of specified Center operations.

3.1.5 PBRF Safet, v Committee (PSC)

The PSC was chartered by the ESB to conduct safety reviews of all matters with safety implications relative to maintaining protected j safe storage of the Plum Brook Reactor Facility. The purpose of the reviews is to assure that operations, written procedures, facility changes, and future plans comply with NRC licenses and regulations, do not involve unreviewed safety questions, and provide protection to the public, on-site workers, the facility, and the environment. A prime consideration in the PSC activities is to l

ensure that all public and employee radiation exposures are I maintained as low as reasonably achievable. Items of review shall include routine maintenance, proposed changes, new and revised procedures, facility changes, changes in Technical Specifications, and audit reports. l l

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 a nuclear background and one other member familiar with the conditions of 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 or her actions to the 21

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Committee at its next regular meeting. Meeting minutes will be distributed to all members and be retained on file.

3.1.6 Plum Brook Station Management Office (PBMO)

The Chief, PBMO, shall be knowledgeable of the Station activities that may affect the protected safe storage condition at the PBRF. The Chief, PBMO, is responsible for administering a program to ensure - <

i that proper operations, control, and safeguards are maintained for '  !

L the Station. This includes a key control system. Keys for the PBRF l are authorized by the Chief, PBMO, on a "need-to-have" basis to persons having knowledge of the conditions, the hazards and procedures of the PBRF. Implementation is by authorization letter issued to the key distributor. The PBMO shall provide for the

. services of Plant Security, Inspection, Health Physics, and Maintenance as necessary at the PBRF.

3.1.7 PBRF Engineer (Reactor Manager)

The PBRF Engineer shall be responsible for the daily management and shall assure the protected safe storage condition is maintained

l. 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 for familiarization with the duties of the Reactor Manager.

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3.2 Procedmes i All new or revised procedures will be reviewed by the PBRF Safety-Committee and approved by signature of the PBRF Engineer and the Chairman of the PSC.

I 3.3 Reports 3.3.1 Annual Report An annual report describing the status of the facility, the results of environmental and facility radiation surveys, and evaluation of the performance of security and surveillance measures, personnel exposures to radiation, and any abnormal occurrences during the previous calendar year shall be submitted to the Director of Nuclear Reactor Regulation, ATTN: Document Control Desk, with a copy to the Regional Administrator, Region III, prior to March 31 of each calendar year.

i 3.3.2 Reportable Occurrences Reportable occurrences shall be reported as expeditiously as possible by telephone and confirmed by telegraph, mailgram, or facsimile transmission to the Administrator of NRC Region III, or his representative, no later than the first work day following the event.

A written follow-up report describing the reportable occurrence including causes, probable consequences, corrective actions, and measures to prevent recurrence 'shall be submitted within 14 days, j

Information provided shall contain narrative materials for a' j complete explanation of circumstances surrounding the event. The following events shall be reported: l

a. Discovery of significant, unexplained increase in radiation or l contamination levels within or around the reactor facility or

! fuel storage area.

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. . - . - . , . - . - . - . _ ~ . . - . . - - . . . . . . - . . . . - . - - - . .

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b. Abnormal degradation discovered in protective barriers for the reactor facility or fuel storage area which would compromise the physical security established for protective storage of the reactor.

3.3.3 Special Reports Special reports which may be required by the Nuclear Regulatory Commission shall be submitted to the Director of Nuclear Reactor i Regulation, ATTN: Document Control Desk, with a copy to the L

Administrator, Region III, within the time period specified for each- l

( such report. ,

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3.4 Records NASA shall keep records required by applicable licenses and regulations including the following:  ;

a. Radiological survey results of the PBRF and environment.
b. Equipment maintenance records (EMRs) of non-routine l maintenance operations involving substitution or replacement of vital components.  !
c. The end condition statements, the procedures used to i

! place the facility in the possession-only condition,' and the procedure completion reports shall reflect the facility l 1

condition in possession-only status.  !

d. Any change which alters the end condition of Safe Protective Storage to any building, structure, system, equipment, or grounds shall be documented by a facility change record.

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4. References (1) Code of Federal Regulations, Title 10, " Energy", Government Printing Office, Washington, DC (2) American National Standard for the Development of Technical Specifications for Research Reactors, ANSI /ANS 15.1-1990, American Nuclear Society, LaGrange Park, Illinois.

I

Attachment:

l Figure 1 Generic Organization Chart 4 l 'l l

l ,

I l

{-

l i

i l

1 .

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GENERIC O RG ANIZ ATIO N CHART l '

l NASA LEWIS l RESEARCH l l CENTER I l

DIRECTOR I

l EXECUTIVE LEVEL 1 SAFETY DIRECTORATE ,

BOARD l

DIRECTOR l

l i

IffrERNAL i AUDIT j l

(

l l

l l

l l

PBRF LEVEL 2 RADIATION l l SAFETY P B STATION SAFETY l COMMITTEE MANAGEMENT OFFICER OFFICE l

I PLANT SECURTIY HEALTH PHYSICS i AND LEVEL 3 AND i

INSPECTION PBRF ENGINEER MAINTENANCE (Contract) (Contract) l l

t RESPONSIBILITIES:

LEVEL 1 - Compliance LEVEL 2 - Surveillance and Maintenance LEVEL 3 - Day-to-Day Oversite ggy