ML20154D432
| ML20154D432 | |
| Person / Time | |
|---|---|
| Site: | Oregon State University |
| Issue date: | 09/30/1998 |
| From: | Binney S Oregon State University, CORVALLIS, OR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-MA3303, NUDOCS 9810070219 | |
| Download: ML20154D432 (5) | |
Text
RADIATION CENTER a
OREGON STATE UnivEnstry
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100 Radiation Center, Corvallis. oregon 97331-$903 Telephone 541-737-2341 Fax 541-737 0480 September 30,1998 1
~ U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555
Reference:
Oregon State University TRIGA Reactor (OSTR)
Docket No. 50-243, License No. R-106
Subject:
a) Request for Additional Information (TAC No. MA3303) on Proposed Amendme its to OSTR Technical Specifications.
1 b) Notification of Personnel Changes Gentlemen.
The following information is in response to your request for additional information on proposed amendments to the OSTR Technical Specifications.
Pr posed Change to Technical Specification 3.8,e.
The wording below is a replacement for that submitted in our July 27,1998 letter to the NRC.
Although the wording, currently in place may be satisfactory, there is concern on our part about how the phrase "airtsorne concentration of radioactivity in the reactor bay and the unrestricted area will not exceed the applicable regulatory concentration limits in 10 CFR 20" cordd possibly be interpreted. There are imaginable situations wherein the radionuclide concentration could exceed the concentration limit in 10 CFR 20, but the associated dose to an individual would never come close to the applicable dose limit. This is especially true with many of the short-lived radionuclides that are produced in a research reactor.
Consequently Technical Specification 3.8.e. has been rewritten to avoid any ambiguity in interprett.t:on. The new wording focuses on not exceeding the applicable 10 CFR 20 dose limits
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rather than concentration limits. We feel that this is a much more appropriate approach in that it
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addresses the actual intent of the regulatory requirements in the new Part 20, namely to operate such that the " total dose to an individual...does not exceed the standards for protection against radiation prescribed in" 10 CFR 20.
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The charges in Technical Specifica*. ion 3.8.e. and the corresponding basis are given below.
9810070219'900930 SDR ADOCK0500g3 P
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U. S. Nuclear Regulatory Commission
.Page 2 September 30,1998 Key: [deletedtext] added tex (
3.8 LIMITATIONS ON EXPERIMENTS Where the possibility exists that the failure of an experiment (except fueled experiments) e.
under (1) normal operating conditions of the experiment or reactor, (2) credible accident conditions in the reactor, or (3) possible accident conditions in the experiment [,] could release radioactive gases or aerosols to the reactor bay or the unrestricted area, the quantity and type of material in the experiment shall be limited such that the airborr.e (concentration of] radioactivity in the reactor bay [and] or the unrestricted area will not (exceed] result in exceeding the applicable (regrdatory concentration] dose limits in 10 CFR 20, assuming 100% of the gases or aerosols escape from the experiment.
Bases.
This specification is intended to meet the purpose of 10 CFR 20 by [ reduce] reducing e.
the likelihood that released airborne radioactivity to the reactor bay or unrestricted area surrounding the OSTR will result in exceeding the total dose limits to an individual [in excess of the limits in Appendir B] as specified in [of] 10 CFR [Part] 20
[will be released to the reactor bay and unrestrictedarea surrounding the OSTR].
Attachment A contains the corrected text for Technical Specification 3.8.e. and its basis should you agree to the amendments proposed in the letter of July 27,1998 and this letter.
Personnel changes In separate matters, I would like to provide notification of changes to personnel shown in the organization chart of the OSTR Technical Specifications as required by Technical Specification 6.7.c.3. Dr. Steven R. Reese has replaced Dr. Jack F. Higginbotham as Reactor Administrator of the OSTR. Also Dr. Jack F. Higginbotham has replaced Dr. Stephen E. Binney as Chairman of the Reactor Operations Committee.
Since ly, i
Stephen E. Binney Director c:
Ai Adams, Senior Project Manager, Non-Power Reactors and Decommissioning Projects Directorate, U.S. Nuclear Regulatory Commission, M.S. 0-11-B-20, Washington, D.C.
20555
U. S. Nuclear Reguiatory Commission Page 3 September 30,1998 j
Oregort Office of Energy,625 Marion Street, NE, Salem, Oregon 97310, Attn: David Stewart-Smith
' Wilson C. Hayes, Vice Provost for Research Jack F. Higginbotham, Chairman, Reactor Operations Committee Steven R. Reese, Reactor Administrator David S. Pratt, Senior Health Physicist Arthur.D. Hall, Reactor Supervisor i
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U. S. Nuclear Regulatory Commission
, Page 4 September 30,1998 State of Oregon
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) ss County of Benton
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Stephen E. Binney, being first duly sworn on oath, deposes and says that he has affixed his signature to the letter above in his official capacity as Director, Oregon State University Radiation Center; that he has signed this letter requesting Technical Specification changes as required by 10 CFR 50.4b(5)(ii); that in accordance with the provisions of 10 CFR 50.30(b), he is attaching this affidavit; that the facts set forth in the letter within are tme to his best information and belief.
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9 COMMisSIONNO.304648 SHDUYCMPBELL unWPUBUC OREGON
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WCONSSON EXPIRES SEPEEERW.21
$tephen E. Binney" Director Subscribed and sworn before me, a Notary Public, in and for the County of Benton, State of Oregon,'this Jod day of C c,pf er
,A.D.,1998, 9/4/0/
a
'otary Pu ic fOregon(/
My Cdmmission Expires
U. S. Nuclear Regulatory Commission
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,,Page 5 September 30,1998 ATTACHMENT A 3.8 LIMITATIONS ON EXPERIMENTS Where the possibility exists that the failure of an experiment (except fueled experiments) e.
under (1) normal operating conditions of the experiment or reactor, (2) credible accident conditions in the reactor, or (3) possible accident conditions in the experiment could release radioactive gases or aerosols to the reactor bay or the unrestricted area, the quantity and type of material in the experiment shall be limited such that the airborne radioactivity in the reactor bay or the unrestricted area will not result in exceeding the applicable dose limits in 10 CFR 20, assuming 100% of the gases or aerosols escape from the experiment.
Basis.
This specification is intended to meet the purpose of 10 CFR 20 by reducing the likelihood e.
that rele,ed airborne radioactivity to the reactor bay or unrestricted area surrounding the OSTR will result in exceeding the total dose limits to an individual as specified in 10 CFR 20.
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