ML20205F907
| ML20205F907 | |
| Person / Time | |
|---|---|
| Site: | Plum Brook |
| Issue date: | 08/11/1986 |
| From: | Bernard H Office of Nuclear Reactor Regulation |
| To: | Pfanner H NATIONAL AERONAUTICS & SPACE ADMINISTRATION |
| References | |
| NUDOCS 8608190352 | |
| Download: ML20205F907 (39) | |
Text
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August 11, 1986
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Docket No. 50-30 T
Mr. Henry Pfanner, Manager Plum Brook Reactor Facility National Aeronautics and Space i Administration
- Plum Brook Station 6100 Columbus Avenue Sandusky, Ohio 44870
Dear Mr. Pfanner:
SUBJECT:
REVIEW 0F> TECHNICAL SPECIFICATIONS The staff'has reviewed the Technical Specifications submitted with your July 26, 1985 request to reinstate a " Possess-But-Not-0perate" license for the Plum Brook Reactor, License No. TR-3.
Enclosed are suggestioris for your proposed Technical Specifications
, (Enclosure 1). Line numbers refer to the numbers on the left side of each page of the enclosed copy of the Technical Specifications (Enclosure 2).
Please respond with completely re-written Technical Specifications within sixty days of the date of this letter.
Sincerely, original signed by Harold Bernard, Project Manager Standardization and Special Projects Directorate Division of PWR Licensing-B Office of Nuclear Reactor Regulation
Enclosures:
8608190352 860811 cc w/ enclosures: p m ADom 0500hD!
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%, ,o# August 11, 1986 Docket No. 50-30
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Mr. Henry Pfanner, Manager Plum Brook Reactor Facility National Aeronautics and Space Administration Plum Brook Station 6100 Columbus Avenue Sandusky, Ohio 44870
Dear Mr. Pfanner:
SUBJECT:
REVIEW 0F TECHNICAL SPECIFICATIONS The staff has reviewed the Technical Specifications submitted with your July 26, 1985 request to reinstate a " Possess-But-Not-Operate" license ,
for the Plum Brook Reactor, License No. TR-3.
Enclosed are suggestions for your proposed Technica', Specifications (Enclosure 1). Line numbers refer to the numbers on the left side of each page of the enclosed copy of the Technical Specifications (Enclosure 2).
Please respond with completely re-written Technical Specifications within sixty days of the date of this letter.
Since el , f
' / -.
,i
,@ t aoldBeNIard,ProjectManager Standardization and Special Projects Directorate Divjsion of PWR Licensing-B Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/ enclosures:
See text page -
- v. National Aeronautics and Docket Nos. 50-30/185 Space Administration cc: Earl C. Boitel, Jr.
Manager, Plum Brook Reactor Facility National Aeronautics and Space Administration J Lewis Research Center Cleveland, Ohio 44135 Ohio Department of Health ATTN: Radiological Health Program Director P. O. Box 118 Columbus, Ohio 43216 Attorney General Department of Attorney General 30 East Broad Street Columbus, Ohio 43215 Planning Coordinator 361 East Broad Street P. O. Box 1735
. Columbus, Ohio 43215 Ohio Environmental Protection Agency Division of Planning Environmental Assessment Section P. O. Box 1049 Columbus, Ohio 43216 e
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Enclosure 1 e)# **4 UNITED STATES d' 't NUCLEAR REGULATORY COMMISSION h .. $ WASHINGTON,0. C. 20555 f
%, ...../
NASA REQUEST FOR REINSTATEMENT OF "T0 POSSESS-BUT-NOT-0PERATE" LICENSE NO. TR-3 COMMENTS AND REQUEST FOR ADDITIONAL INFORMATION Page 1 Line 25 A line or two is missing from the sentence starting with "The PBRF contains no . . . .".
Page 2 Section 1.2 The SAR accompanying the Technical Specifications should have a sufficient facility description, including figures of the facility, to make these Technical Specifications and the accompanying SAR an independent submittal. The other alternative is to provide an exact cite for the reference
[i.e. title, date and page].
Page 2 Line 6 This sentence needs to be modified so that both NASA and NRC understand explicitly the parts of the facility that are covered by the Technical Specifications.
For example:
If everything in the PBRF except the Mock-up Facility is covered by these Technical Specifications for the Test Reactor, that should be so stated.
Page 2 Line 17 . . . accompanied (add) "an authorized person" with this knowledge.
Page 3 Section 1.3 Line 5 Add . . . "by neutron activation" after word " . .
. activated" Page 3 Line 13 Sentence should read . . . is any area (add) "in" which major portions of the body (add) "could be exposed to" direct radiation . . .
Line 20 Change to . . . portions of the body (add) "could be exposed to direct radiation levels from 2.5 (add) up to 100 mrem /hr" Line 21-23 Provide dpm values for contamination levels below which protective clothing will not be required. Also, in last sentence change to "In this area, direct radiation levels to major portions of the body shall be less than 2.5mPem/hr Page 4 Section 2.1 Change title of section to " Control of Access to PBRF Site" Line 3 Applicability: Change this specification to apply to the control of access to the PBRF site.
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o Page 4 Section 2.1 Specification This specification should include the fact that there are locked gates, only authorized persons have the keys, and that there are locked doors to the PBRF itself.
Bases This section should describe the fences, gates, locks, locked building, and visitors accompanied by the authorized persons wha can open the various security barriers.
Page 4 Section 2.2 Indit6 P units as (a), (b), (c), (d), (e) and (f) so the bases can be related to the same sub-parts in addition Line 22 (add) " maintained" before drained so it reads ". . . .. shall be maintained drained."
Line 24825 Are shrapnel shields still necessary? Why not remove them and eliminate from the Specification and Bases?
Page 5 Section 2.2 Add to last line "Therefore, protection for airborne radioactivity is not required outside the tank."
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Line 13 Page 6 Change 2.3 Bases to read:
Line 15 Add to end of sentence ". . . . eliminating the need for personnel safety equipment."
1.ine 16 Bases 2.3b (add) limits entry to authorized personnel and 2.3c eliminates a (add) " potential source of contamina-tion from entering the CV," except for minor condensation.
Page 6 Section 2.4 Where is the primary cooling water purification system described?
Page 7 Line 11 Add " unauthorized" before " access to the . . ."
Page 7 Section 2.5 Alann System What is meant by reliable alarms? " Applicability" should I Line 15 indicate the types of alanns being referenced, i.e. fire, radiation, entry etc.
The " Specifications" should also refer to the above types.
In " Bases", provide primary reasons for the alarms. History only confirms adequacy, not need for.
! Page 7 Line 18 Change " maintained" to " operating".
Page 7 & 8 2.6 Electricity Is there a need for this specification? Perhaps it could be one of the " alarms" in 2.5.
Page 8 Line 19 What does the word " clean" mean? No loose contamination; i
reading below?? dpm; etc? It wculd be better to provide a level commensurate with its color designation.
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Line 20 Change to read: (b) the deionizer system (add) "shall not contain ion exchange material, shall be maintained in a dry condition and shall . . ., etc." Make first sentence (a) and second sentence (b).
Line 22 " Bases" for (a); again, history is not basis. Indicate, how these specifications maintain in the Quadrant and the Canal System within the specs for (b). Basis could be that there is no longer any water, eliminating the need for a purification system.
Page 9 Line 5 Change to read ". . . prevent (add) unauthorized personnel access and (add) uncontrolled entrance of water to these areas."
Line 8 " Secured" should be dofined in Section 1 (i.e. what type-locks, seals, etc??) or in this and other places where it is used.
Bases: This seems to apply to only the inside of the hoods. Was contamination removed from outside of the hood so that part is " clean"? Where are the foot and hand counter (s) to verify the above - or how is the control of contamination verified??
Page 9 2.9 Hot Drains Are the hot drains only within the Containment Vessel (CV) or are they in other parts of the facility.
Objective Delete " contamination" and add to sentence " materials remaining in the hot drains."
Specification Indicateeachsentencewith(a)(b)(c)(d)and(e).
"Non-operable" is an inadequate descriptor unless (b) (c)
(d) & (e) are an amplification of "in-operable." If so, perhaps that sentence should be omitted or placed in the Bases.
Line 22&23 Need a better description for " clean" and " cleaned to a practical extent." This applies throughout the Technical Specifications.
Line 24 Are these " hot drain pumps" for pumping from the hot drain system?
Bases (b) decontamination of external surfaces will remove loose radioactive material;.
(c) flushing hot lines will remove all easily removable radioactive material, leaving the remainder immobile; (d) plugging access to the hot drain system prevents in-advertent drainage into the system; (3) need basis for hot drain pumps, to wit: with all lines flushed and plugged, there is no longer a need i for the hot drain pumps.
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Section 2.10 Title should be Hot Laboratory and Hot Dry Storage.
Line 12 List first sentence as (a) and second as (b).
Page 11 Bases What contamination is in either area that could be
" spread"? Replace " Limited" with " Authorized".
Page 11 Line 11 Replace " areas" with " Waste Handling Building". 1 Specification Sentences should have (a) and (b) respectively. !
"(c)" Consider if there are any alarms or monitors in this building that should be in this specification.
Bases The SAR indicates that the Waste Handling Building was 1
" decontaminated to a practical level." What does that l mean? What type of contamination was allowed to remain? l Since this jargon is utilized throughout, perhaps a definition should be considered.
Line 17 Replace " Limited" with " Authorized." Is " procedural control" via written procedures? If so, state that fact.
Line 26 The Objective is not clear. I think the objective is, to wit: " . . . to minimize the accumulation of water in the
. ERB and to prevent a release of a potential source of contaminated liquid to the environment."
Page 12 Specification Identify each respective sentence with (a) or (b) or (c).
Line 4 (b)shouldstartwith"Anyaccumulatedwater..."
(c) There is no reference to a pump so the sentence should be changed, to wit: "the pumps shall be removed from the supply line."
- Bases Periodic checks over 12 years are not a Basis.
Line 16 Change end of sentence to read ". . . prevent release of contamination from this source."
Line 19-22 Make sentences (a) & (b), respectively.
Line 19 Change first part "the HRA tanks which had been flush and Line 24 Bases Change, to wit: "these specifications provide for authorized access and preclude inadvertment exposure of i personnel and mitigate against liquid accumulation and release of potentially contaminated liquid."
Page 13 Rewrite, to wit:
2.15 " Contaminated Air System" (CAS).
Applicability - This specification applies to protected safe storage of the contaminated Air System (AS) for possible future need.
Objective - OK.
Specification: (a) the CAS includes the 5-foot diameter, 100 ft. high stack and all contaminated air ventilating
! systems except those presently serving the reactor tank, CV
! and HRA;
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l (b) fan motors shall be de-energized from the power but at the motor control centers; (c) all valves in the CAS shall be disabled and are to be maintained in a fixed-closed position; (d) the CAS shall be kept dry and shall be equipped with absolute filters.
Bases The CAS has been vacuumed for removal of loose contamination, purged and maintained in a dry condition for use, if required. The CAS can, with minor repairs, be placed in operation, when and if required. Twelve years of monitoring under the above conditions verifies the absence of airborne radioactivity and availability for re-use of the CAS, if required. The above program will continue to maintain the CAS in a low radiation condition.
Section 3, 3.1 Surveillance Change to " Designated Radioactive Storage Area Within PBRF."
Applicability Change to: This specification applies to the monitoring and surveillance of the radioactive storage areas within the PBRF."
- Page 14 Specification Line 5 - The modifier " prime-ily" doesn't signify very much, i.e.,
radioactive materials can be stored anywhere.
"Primarily" should be omitted. If the delineated areas are the only areas, "primarily" is not required. If other areas store radioactive materials, they should be so identified. The designators, "a, b, c, & d" should be changed to "1, 2, 3, 4," respectively.
Line 11 Designateas(b).
After Line 13 Add " monitoring, for loose contamination by surface swipes shall be conducted (semi-annually, annually)? What else would constitute sur/eillance -
periodic meter reading?? etc. Need specs on what, type, and frequency of surveillance.
Bases This section is on Surveillance Bases. It should contain justification for what, type, and frequency of surveillance.
Here the history of swipes, readings, etc., could justify the frequency and type of surveillance that you mention.
Section 3.2 Access to Radiological Control Zones This section is " Surveillance." " Controls" are in Section
- 2. Therefore, Applicability should read ". . . apply to surveillance of radiological control zones in the PBRF.
Objective - should read ". . . is to provide surveillance systems for these zones.
Line 25(a) Magenta Zones Eliminate first and second sentences. Do these zores have CAM's or other radiation instrumentation? What type of continuous or intermittent surveillance is applied to these unattended areas?
Page 15 Clarify Line 7 Clarify (c). The above two areas should then be decontaminated also, because they are " accessible to authorized personnel." Do you mean this to be areas accessible to authorized personnel who are not escorted by a health physicist?
Bases This section should address ALARA, 10 CFR 20, procedures, escorts, etc.
Section 3.3 Alarm Response Radiation Alarms are not included here; why not?? If it is not intended to include radiation alarms in this section, there should be a section relegated to that type of surveillance system. Also this section should be so designated. For example:
Applicability - This specification applies to alarm response.
Objective ". . . to control access, and maintain integrity of the containment vessel, Hot Retention Area, .
Specification All alarms shall annunciate in the Comunication Center (CC). The CC is continuously staffed. Response to alarms shall include visual inspection to determine the cause (except for power failure). Response shall be within one hour of annunciation. The following areas shall have alarms:
a ok b ok C ok d others-list e) others-list Alarms shall be continuously operable except during maintenance. If alarms are to be replaced, the alarm system may be inoperable for periods not to exceed (fill in) hours.
Bases If the alarm condition is mentioned in the Specification section, then the one sentence in the " Bases" is adequate. If not, then set-points need to be posted in this section; this is especially true for radiation alarms.
Page 16 Section 3.4 The section heading appears to be a misnomer. From the Applicability and the Objective statements, and Monitoring, activities appear to be confined to the facility, only, and do not include the contiguous environment. If this is true, the title should be re-named " Facility Radiological Monitoring", i.e., there is no environmental monitoring mentioned in any of the parts of this secticn.
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Specification This paragraph, as annotated, would be better located in the " Bases". This specification should provide the frequency of surveys for the three color-designated zones.
Bases:
Assuming the paragraph in " Specifications" will be relocated to this subsection, add at end of Line 12 "and radiation levels are consistent with 10 CFR 20 limits and with ALARA."
3.5 Minimum Procedures This section is usually included within the
" Administrative Controls" section. However comments are as follows:
" Minimum" should be omitted.
Line 20 - Replace word "some" with " approved".
Line 22 - The words "more important" should be changed.
Line 25 - After " Detailed", add " written and approved . . ."
Page 17 Start with:
(a) Includes the specified functions in Section 3.6.
Change existing a, b, c, d, e, to b, c, d, e and f.
Line 4 Add "and surveillance" to end of sentence.
Line 6 Change to " Response to emergencies that may arise from fire, floods, and tornadoes.
Add items (g))
functions,(h Training programs Maintenance programs. for various staff Line 20 Change to, " Inspections, tests and respective frequencies shall be performed as follows:" (Frequencies are in accordance with those specified in ANSI /ANS 15.1,1982.)
Line 18 Bases Add to end of existing sentence ". . . . in order to provide reasonable assurance that radioactivity and personnel exposure are controlled and minimized.
Page 18 Section 4.1 The organization chart is part of these Technical Specifications. Therefore, ". . . . and is submitted for information only" must be omitted. Any changes in the organization will require an amendment to the license.
Page 19 Section 4.1.2.
Add ". . . and is under the management of the Level 1 Director."
Line 25 Change to read, "An RS0, responsible to the Level 1 Director, shall be responsible for organization, administration, and direction of the radiological control . . ."
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8-Page 20 Line 8 Add "or the equivalent," after " biological science."
Line 24 Add, " facility changes," after " written procedures."
Page 21 Line 1 Add at beginning of this line "public, on-site workers,"
Page 22, Section 4.1.8 Line 7 Change to "The PBRF Engineer shall be responsible for the daily management and shall assure the protected . . ."
We believe that the text following item "c" can be omitted, inasmuch as this position has the responsibility for maintaining the facility in accordance with the Technical Specifications.
Page 23 Add 4.3(g)
Any release of radioactive material from the PBRF site.
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National Aeronautics and Docket Nos. 50-30/185 Space Administration cc: Earl C. Boitel, Jr.
Manager, Plum Brook Reactor Facility National Aeronautics and Space Administration Lewis Research Center Cleveland, Ohio 44135 Ohio Departnent of Health ATTN: Radiological Health Program Director P. O. Box 118 Columbus, Ohio 43216 Attorney General Department of Attorney General 30 East Broad Street Columbus, Ohio 43215 Planning Coordinator 361 East Broad Street P. O. Box 1735 Columbus, Ohio 43215 Ohio Environmental Protection Agency Division of Planning Environmental Assessment Section P. O. Box 1049 Columbus, Ohio 43216
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Enclosure 2 APPENDIX A TECHNICAL SPECIFICATIONS LICENSE N0. TR-3 NATIONAL AERONAUTICS AND SPACE ADMINISTRATION DOCKET NO. 50-30 l
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TABLE OF CONTENTS PAGE 1
- 1. Introduction - - - - - - - - - - - - - - - - - - - - - - - - -
1.1 Scope l
1.2 Application l 1.3 Definitions 3
- 2. Requirements - - - - - - - - - - - - - - - - - - - - - - - - -
2.1 Access 2.2 Reactor Tank (RT) 2.3 Containment Vessel (CV) 2.4 Primary Cooling Water System and Primary Pump House .
2.5 Alarm System 2.6 Electrical System 2.7 Quadrant and Canal System -
2.8 Radiochemistry Laboratory 2.9 Hot Drains 2.10 Hot Laboratory 2.11 Hot Pipe Tunnel 2.12 Waste Handling Building 2.13 Emergency Retention Basin 2.14 Hot Retention Area 2.15 Contaminated Air System
- 3. Su rv ei l l a nce - - - - - - - - - - - - - - - - - - - - - - - - - 13 3.1 Designated Storage Areas within PBRF 3.2 Access to Radiological Control Zones l 3.3 Alarm Response l
3.4 Facility and Environmental Monitoring l
I 3.5 Minimum Procedures 3.6 Inspection, Tests and Surveys
- 4. Administrative Controls - - - - - - - - - - - - - - - - - - - 18 4.1 Organization 4.2 Procedures _
4.3 Reports "
4.4 Records
- 5. References - - - - - - - - - - - - - - - - - - - - - - - - - - 24 l
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APPENDIX A
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1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS l 2 LICENSE N0. TR-3 ,
a NATIONAL AERONAUTICS AND SPACE ADMINISTRATION 4 DOCKET NO. 50-30 .
5 6
7 1. Introduction -
S 9 Where applicable, these technical specifications follow the fonnat of to the American National Standard ANSI /ANS-15.1-1982.
11
- 12 1.1 Scope 13 jo These technical specifications apply to all portions of the Plum Brook 35 Reactor Facility (PBRF), with the exception of the Mock-up Reactor 16 (MUR) which is separately licensed. The PBRF contains a non-operable ,
17 test reactor, its support facilities, and its inventory of radioactive is materials generated as a result of previous operations. The reactor 19 was shutdown in 1973 after 98,000 megawatt days of operation.
l 20 21 The radioactive inventory, with the exception of distributed radio-22 active material existing as contamination within process systems and 23 laboratories, is stored in four locations. These are inside the 24 Containment Vessel, in the Reactor Building Canals G, in the Hot 25 Laboratory, and in the Waste Handling Building. The PBRF contains no 26 27 - _ . _ _ -_-___ _ __ _ ___._____ _ __._ _ -_ .. _ _ .. _ _ _ _ _ _
1 1.2 Application 2
3 These technical specifications govern the condition of National 0 Aeronautics and Space Administration's PBRF in the possess-but-not- _
5 operate status. The PBRF is described in past documents submitted and 6 now contained in Docket No. 50-30. Only systems, components, or areas 7 which are radioactive, contaminated, or needed to maintain a protected s safe storage condition are covered in these technical specifications.
9 to 1.3 Definitions 11 12 1.3.1 General 13 14 Authorized Entry - Entry by people authorized by management with a 15 legitimate need to enter the PBRF who have knowledge of the condi-16 tions, the hazards, and procedures of the facility or who are 17 accompanied by someone with this knowledge.
18 Kept Dry - A condition which is normally dry and mopped or drained 19 as soon as practical when becoming inadvertently wet.
20 Nonoperable - A condition of a component or system which has been 21 intentionally disabled to prevent it from performing its intended 22 function.
23 Protected Safe Storage - A custodial statemf undefined duration 24 characterized by physical and procedural access control and 25 periodic monitoring, maintenance and inspection.
26 Shall - The work "shall" is used to denote a requirement.
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1.3.2 Radioactive Materials , )
. I 1-2 ContaminatedMaterial-Irradiatedornonirradiateditem%,
3 containing particles of radioactive material on its surface.
4 Radioactive Material - Items which have been activated as a result -
5 of previous reactor operations. These items may also be 6 contaminated.
7 s 1.3.3 Radiological Control Zones 9
to Magenta Zone - For purposes of contamination control, levels will it be as low as reasonably achievable but can exceed the
, 12 magenta-yellow limit. For purposes of direct radiation control, a 13 magenta zone is any area which could expose major portions of the 24 body to dire.ct radiation levels of 100 mrem /hr or more.
15 Magenta-Yellow Zone - For purposes of contamination control, is levels will not exceed 100 dpm d 100
/ cm2 and 10,000 dpmS -/ /100 17 Cm2 transferable; 2500 dpmdand 8,000 dpm4 -)' fixed. Magenta-is yellow zone for purposes of direct radiation control, is any area 19 which could expose major portions of the body to direct radiation 20 levels from 2.5 to less than 100 mrem /hr.
21 White Zone - Is an area with contamination levels so low that no 22 protective clothing is required. This area will have direct 23 radiation levels less than 2.5 mrem /hr.
24 25 2. Requirements 26 27 _ -
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1 2.1 Access 2
3 Applicability - This specification applies to protectio.n of the 4 facility by control of access. -
5 Objective - The objective is to prevent unauthorized entry.
6 Specification:
7 The PBRF access shall be controlled through two fences. The outer S
fence surrounds the Plum Brook Station. An inner fence surrounds 9 the PBRF within station.
to Bases:
17 The specification of 2.1 provide two physical barriers before
, 12 gaining access to the locked buildings of the PBRF.
13 14 2.2 Reactor Tank (RT)
I 15 is Applicability - This specification applies to the contaminated and 17 radioactive material of the reactor tank and contents within.
Is Objective - The objective is to safely store the irradiated 19 materials and control radiation levels.
20 Specification:
l 21 The reactor tank, surrounded by a thick concrete biological 22 shield, shall be drained. All tank nozzles and penetrations which l
l 23 could stream irradiation shall have shields fixed in place. The 24 three shrapnel shields (20 tons each) shall be positioned above 25 the reactor tank. All openings shall be closed, except those 26 openings required for a dry gas purge through an absolute filter 27 to the stack.
. 1 Radiation levels at accessible reactor tank surfaces shall be less 2 than 100 mrem /hr. The sub-pile room door shall be closed and 3 locked except for authorized entry.
4 Bases:
5 High radiation level inside the RT and streaming through RT 6 penetrations are prevented by various shields. The reactor tank 7 is covered with shrapnel shields and is surrounded by thick 8 concrete biological shields. Additional shields needed to make 9 all accessible areas to the RT below 100 mrem /hr are tack welded to in place. Twelve years experience at PBRF has found the shielding 11 adequate for all quadrant accessible areas to be classified as 12 magenta-yellow zones. In addition, the experience has found no 13 airborne contamination in excess of MPC (unrestricted areas).
14 15 2.3 Containment Vessel (CV) 16 .
-17 Applicability - This specification applies to protected safe 18 storage of the reactor and contents inside the CV.
19 Objective - The objective is to control personnel access to the CV 20 and,fpEevententryofwaterwhichcouldbeavehicletospread 21 contaminated material.
22 _ Specification:
23 a. The CV shall be provided with two primary openings designed to 20 breathe the CV atmosphere through absolute filters.
25 b. One of the two existing personnel doors shall be used for 26 controlled personnel access. This door shall be locked to prevent 27 5-F
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1 unauthorized entry. The other door shall be operable only from 2 the inside as an emergency exit. Access shall be through a single ;
3 door of the original airlock door system.
4 c. The truck door shall be closed and dogged in place except ,
5 during temporary controlled periods to accomodate transfer of 6 equipment too large to fit through the personnel door.
7 d. All original liquid containing process lines penetrating the s CV shall be drained and blank flanged or capped to prevent liquid i 9 entering the CV. The blank flange or cap shall be secured against to unauthorized opening. All other process penetrations shall be it closed with locked or welded valves, or capped to prevent 12 unauthorized opening from the outside.
u Bases:
14 Specification 2.3 a. provides authorized personnel an inhabitable 15 atmosphere in the CV. Specification 2.3 b controls authorized is entry while specification 2.3 c. eliminates a source of water 17 except for minor cundensation. A dry protected safe storage with 1s access control is provided by these specifications.
19 2o 2.4 Primary Cooling Water System and Primary Pump House (PPH) 21 22 Applicability - This specification applies to protection and safe 23 storage of the primary cooling water system outside the CV.
l 24 Objective - The objective is to isolate the RT from the PPH, 25 control access and prevent spread of contaminated materials.
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i Specification!
2 a. The primary cooling water supply and return headers shall be 3 blank-flanged to isolate the reactor tank from the Primary Pump 4 House. Lines between the blank fianges and the Primary Pump House ,
5 shall be drained.
6 b. The PPH roof hatch plugs shall be in place. The roof hatch 7 plugs and personnel doors of the PPH shall be locked except for s authorized entry.
9 Bases:
10 These specifications provide a dry primary cooling water system is outside the CV and prevent access to the system in the PPH.
. 12 33 2.5 Alarm System 10 35 Applicability - This specification applies to reliable alarms.
16 Objective - The objective is to receive'off normal warning.
Specification:
17 is An alarm system shall be maintained to provide local alarms at the 19 PBRF and a sumary alarm at the Plum Brook Station Communication 20 Center. The alarm response is provided in Section 3.3.
21 Bases:
22 This specification provides a requirement which demonstrated a 23 reliable warning system over the past 12 years.
20 25 2.6 Electrical System 26 27 i Applicability - This specification applies to reliable power.
2 Objective - The objective is to receive off normal warning.
3 Specification:
4 The PBRF electrical power shall be supplied by a commercial power .
5 system. When powen is restored following an outage, all load 6
circuits shall automatically reenergize.
7 Bases:
g These specifications provide requirements which have demonstrated 9
a reliab}e power source over the past 12 years.
10 2.7 Quadrant and Canal System ti 12 Applicability - This specification applies to the Quadrant and 33 y Canal System for protected safe storage except for Canal H 35 (coveredunderR93 license).
Objective - The objective is to provide a safe storage area for 16
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37 contaminated and radioactive materials.
3, Specifications:
The quadrants and canals are cleaned, drained and shall be kept 39 dry. The deionizer system was flushed, drained and shall be 20 isolated by valves and flanges.
21 22 Bases:
By these specifications,12 years experience demonstrates the 23 24 Quadrant and Canal System can be successfully used as storage 25 locations.
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1 s 1 2.8 Radiochemistry Laboratory ;
2 3 Applicability - This specification applies to the chemical fume 4' hoods of the Radiochemistry Laboratory. .
. 5 Objective - The objective is to prevent personnel access and )
6 entrance of water to these areas.
7 Specification:
s The chemical fume hood doors shall be secured to prevent opening 9 and hoods shall be kept dry.
to Bases:
si Contamination spread is minimized by accest prevention.
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33 2.9 Hot Drains 14 35 Applicability - This specification applies to the protected safe 16 storage of the Hot Drain System.
17 Objective - The objective is to prevent spread of radioactive is contamination.
19 Specification:
20 The Hot drain system shall remain nonoperable. All accessible (white zone) external surfaces shall be clean. All hot drains, 21 22 sumps, and lines shall be flushed, cleaned to a practical extent 23 and drained. All floor drains and other flow paths supplying a 24 hot sump shall be plugged or sealed. Pump motors shall be 25 deenergized from the power bus at the motor control centers.
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- o 1 Bases: ,
2 These specifications provide for a static relatively clean hot 3 drain system. In addition they prevent access to these systems.
4 -
,5 2.10 Hot Laboratory 6
7 Applicability - These specifications apply to protected safe 8 storage in the Hot Laboratory including the Hot Dry Storage.
9 Objective - The objective is to prevent unauthorized entry to to contaminated or radioactive material storage areas.
1T Specification:
12 Access doors to the Hot Laboratory shall be locked. Hot cell is doors and the 80 tor, access door to the Hot Dry Storage area shall 14 be loclied.
15 Bases:
16 Limited access with procedural control prevents personnel
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17 exposure and spread of contamination.
Is
! 19 2.11 Hot Pipe Tunnel 20 21 Applicability - This specification applies to the protected safe 22 storage of the Hot Pipe Tunnel.
23 Objective - The objective is to prevent personnel access and 24 entrance of water to this area.
25 Specification:
, 26 The Hot Pipe Tunnel entrances at each end of the tunnel shall be 23 l
t' l I padlocked closed. The tunnel shall be kept dry. t 2 Bases:
3 Contamination spread is minimized by access prevention,and 4 maintenance of the dry condition,. ,
5 6 2.12 Waste Handling Building 7 ,
s Applicability - This specification applies to protected safe 9 storage in the Waste Handling Building.
10 Objective - This objective is to prevent unauthorized entry to it areas containing contaminated or radioactive materials.
12 Specification:
13 Access doors leading to the Waste Handling Building shall be locked closed. Access doors to the evaporator room and waste 14 is packaging room shall be locked closed.
16 Bases:
17 Limited access with procedural control prevents personnel exposure is ar;d spread of contamination.
19 20 21 2.13 Emergency Retention Basin (ERB) 22 23 Applicability - This specification applies to the protected safe 24 storage of the ERB.
25 Objective - The objective is to provide a basin which will minimize the accumulation of water and prevent a potential source 26 27
o ,
P*
s i of contamination to the er.viron: rent.
2 Specification:
3 The ERE drain line shall remain open to prevent rain water 4 accumulation. The water shall be sampled quarterly to verify -
5 limits of 10 CFR Part 20 for an unrestricted area are not 6 exceeded. By pump removal, the supply line shall not be a water ,
7 source to the ERB.
g Bases:
, Periodic checks over the past 12 years show ER'S water samples have to not exceeded the limitt of 10 CFR Part 20 for unrestricted areas.
11 12 2.14 Hot Retention Area (HRA) 13 34 Applicability - This specification applier to protected safe 3g storage of the HRA.
26 Objective - The objective is to control access and prevent spread ,
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g7 of contamination, Specification:
- y, 19 The HRA tanks were flushed, decontaminated to a practical level, 20 ard shall be kept' dry. All HRA entrances or access plugs are 21 welded closed, except that one entrance to the annulas and the i 22 tunnel area shall be locked to allow only authorized entry.
Bases:
- 3 l 20 These specifications provide a restricted access to a relatively l 25 clean and dry system. I 26 1 27
, 1 2.15 Contaminated Air Systems 2
3 Applicability - This specification applies to protected safe 4 storage of the Contaminated Air Systems which includes the Stack. .
5 Objective - The objective is to provide controlled access into 6 relatively clean Contaminated Air Systems.
7 Specification:
5 The contaminated air systems were vacuumed, decontaminated as 9 practical, purged and shall be kept dry with absolute filters
. to removed. All manual and automatic operated valves shall be it disabled in a fixed closed position. These systems shall include 12 the S-foot diameter, 100-foot-high stack and all contaminated air
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13 ventilating systems except those presently serving the reactor 14 tank, CV and HPA The fan motors shall be deenergized from the 15 power bus at the motor control centers.
16 Bases:
-17 A systematic clean up followed by 12 years of monitoring verifies is the absence of significant airborne activity.
19 ,
20 3. Surveillance 21 22 3.1 Designated Storage Areas within PBRF 23 23 Applicability - This specification applies to the radioactive 25 storage areas at the FBRF.
26 Objective - The objective is to identify the areas for 27
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' I radiological control.
2 Specification:
3 Radioactive raaterial, with the exception of distributed 4 radioactive material existing as contamination within process ,
5 systems and laboratories, shall be stored primarily in four areas:
6 a. The Containment Vessel.
7 b. The Reactor Building Canal G.
8 c. The Hot Laboratory which includes Hot Cells and Hot Dry 9 Storage Area.
10 d. The Waste Handling Building.
11 Storage areas shall be posted as Radiological Control Zones 12 defined in Section 1.3. Access to these areas shall be controlled 13 as specified in Section 3.2. Access to Radiological control Zones.
14 Bases:
15 The specifications identify the primary areas used for radioactive 16 material storage and define the control for these radiological 17 control zones.
Is 19 3.2 Access to Radiological Control Zones 20 11 Applicability - These specifications apply to radiological control 22 zones of the PBRF.
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23 Objective - The objective is to provide controls for these zones.
20 Specifications:
25 a. Magenta zones shall be posted, secured by fixed barricades or 26 under lock and key control. Buildings containing these zones 27 l
3 i
^
1 shall also be locked. Access to magenta zones shall require 2
continuous radiation monitoring by health physics personnel, use 3 of a safe work permit, and use of personnel dosimetry.
Magenta-yellow zones shall be posted. Access to 4 b. . -
5 magenta-yellow zones shall require health physics monitoring and f 6 control and use of personnel dosimetry.
7 c. All areas accessible to authorized personnel for inspection 8' and maintenance purposes shall be decontaminated where practical 9 .
to white zones.
to Bases:
11 These specifications ensure adequate precautions prior to access to radiological control zones.
. 12 13 14 3.3 Alarm Response 15 1s Applicability - This specification applies to alarm response.
17 Objective - The objective is to provide a response for minimum
, is alarm conditions during protected safe storage.
19 Specification:
The Communication Center is continuously manned to respond within 20 one hour. The following alarms shall be operable:
21 l 22 a. CV entry door open 23 b. Loss of facility electric power
- c. Hot Retention Area sump - High ground water.
20 25 Bases:
i 26 This specification ensures a response for abnormal conditions 27 i
i 1
. I during a protected safe storage condition.
2 3 3.4 Facility and Environmental Monitoring 4 ,
5 Applicability - This specification applies to routine radiological 6 surveys at the P3RF.
7 Objective - The objectiye is to determine that radioactivity is 8 confined to radiological control zones.
9 Specification:
to Routine radiological surveys shall be performed by trained health .
11 physics personnel using survey and counting equipment commensurate 12 with sound health physics practices to ensure that radioactivity
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13 levels are within 10 CFR Part 20 limits.
14 Bases: -
15 This specification ensures that radioactive levels are maintained 16 within permissible limits.
-17 18 3.5 Minimum Procedures 19 20 Applicability - This specification applies to some procedures that 21 help administer the protected safe storage condition.
22 Objective - The objective is to list the more important 23 procedures.
24 Specification:
25 Detailed procedures shall be in effect covering the following 26 areas:
27 l
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.- 1 a. Response to alarms .
2 b. Entrance to the PBRF, PBRF building, Containment Vessel, 3 and radiological control areas.
4 c. Facility and environmental radiological monitoring. ,
5 d. Facility changes.
6 e. Emergencies such as fire, floods, and tornadoes.
7 These procedures shall be approved by the PBRF Safety Committee.
s Bases:
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9 This specification ensures protected safe storage procedures are to provided. ,
if 12 3.6 Inspection, Tests and Surveys 13 34 Applicability - This specification applies to select inspection, 15 tests, and surveys used to preserve a protected safe storage 16 condition.
17 Objective - The objective is to provide a minimum inspection and l is test program for continued protected safe storage, l
19 Specification:
20 The following inspection and tests shall be performed:
21 Current Minimum Frequency l 22
- a. PBS Fence Integrity (patrolled daily) Quarterly 23
- b. PBRF Fence Integrity Monthly 24 1
25 c. Buf1 ding and CV iocks Monthly
- d. Bt:1iing and CV General Condition Monthly 26 27
e
(*
- e. Alarm Tests Quarterly 1
- f. Facility Radiological Surveys Quarterly 2
- g. Environmental Radiological Surveys Quarterly 3
- h. Absolute Filters Annually 4 .
- 1. CV Integrity Annually 5
Frequencies shall be approved by the PBRF Safety Committee. The 6
7 PBRF Engineer shall review the results and assure necessary a
corrective actions are taken to preserve the protected safe 9 storage condition.
10
- Bases:
This specification ensures protected safe storage inspection) 12 tests, and surveys are provided.
i3 14 is 4. Administrative Controls 16
_17 4.1 Organization 18 The Plum Brook Reactor Facility is owned by the National 19 Aeronautics and Space Administration (NASA), which shall be 20 21 responsible for maintaining the protected safe storage condition as required by these Technical Specifications. NASA shall provide 22 whatever resources are required to maintain the PBRF in a 23 24 condition that poses no hazard to the general public or to the 25 environment. Attached figure 1 charts the current generic organization and is submitted for information only. Significant
! 26 27 1
l i
I changes in organization shall be reported in the annual report.
2 3 4.1.1 Level 1 Directorate 4 The Director shall be responsible for assuring compliance with the -
5 reactor facility's license and providing regulatory reports and 6 correspondence. He shall have overall responsibility for the 7 protected safe storage of the facility.
S 9 4.1.2 Health Safety and Security Division to This division shall provide the resource to maintain the PBRF in it protected safe storage.
12 ,
13 4.1.3 Internal Audit An annual internal audit, shall be performed at the PBRF. The 34 15 audit shall be performed by NASA personnel not directly associated
! with the facility who have nuclear experience. Special attention 16
~17 shall be given to compliance with procedures, the NRC licenses, is regulations, and record keeping. The auditor shall submit a report on each audit for the Executive Safety Board. Reported 19 The Plum 20 discrepancies shall be resolved by the PBRF Engineer.
21 Brook Reactor Facility Safety Committee shall review and insure 22 the proper disposition of each discrepancy.
23 24 4.1.4 Radiation Safety Officer (RS0) l l 25 A RSO shall be appointed to organize, administer, and direct the 26 radiological control and monitoring program, as required by these 27
GENERIC ORGANIZATION CHART NASA LEWIS RESEARCH CENTER DTWF N R l
1 .
EXECUTIVE LEVEL 1 SAFETY DIRECTORATE BOARD DIRECTOR INTERNAL HEALTH SAFETY AND AUDIT SECURITY DIV.
PBRF LEVEL 2 . RADIATION SAFETY P B STATION SAFETY COMMITTEE MANAGEMENT OFFICER OFFICE f PLANT SECURITY LEVEL 3 HEALTH PHYSICS
.AND . . PBRF ENGINEER AND INSPECTION MAINTENANCE l
l
- Contract) (Contract)
RESPONSIBLE FOR LEVEL 1 - Compliance LEVEL 2 - Surveilance and Maintenance LEVEL 3 - Day to Day Oversite FIGURE 1 ,
I i
f
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1 Technical Specification, and assure the program is adequately 2 performed. The RSO shall be responsible for providing on-site 3 advice, technical assistance and revtew in all areas related to 4 radiological safety. The RSO shall be a person specifically -
5 trained in the radiation health sciences and appropriately 6 experienced in applying this knowledge to the management of the 7 radiation protection program. The RSO shall have a bachelors 8 degree in physical science or biological science with a minimum of 9 two years of applied health physics experience in a program with -
10 radiation safety considerations similar t,o those associated with 11 the PBRF program.
12 .
13 4.1.5 Executive Safety Board (ESB) 14 The ESB serves as a Lewis Research Center safety policy and 15 decision making board, and is responsible to the Center Director 16 for the overall direction of the Lewis Safety Program. The ESB
.17 establishes a system of Safety Comittees to conduct detailed 18 third party reviews of specified Center operations.
19 20 4.1.6 PBRF Safety Comittee (PSC) 21 The PSC was chartered by the ESB to conduct safety reviews of all 22 matters with safety implications relative to maintaining protected 23 safe storage of the Plum Brook Reactor Facility. The purpose of 24 the reviews is to assure that operations, written procedures and 25 future plans comply with NRC licenses and regulations, do not 26 involve unreviewed safety questions, and provide protection to the 27 ,
f ,
O 1
- j. workers, the facility, and the environment. A prime consideration 2 in the PSC activities is to ensure that all public and employee 3 radiation exposures are maintained as low as reasonab.ly 4 achievable. Items of review shall include routine operation, ,
5 proposed changes, new and revised procedures, facility changes, 6 changes in technical specifications, and audit reports, l
7 s The PSC shall consist of a minimum of four persons and shall meet i 9 at least twice each year. The PSC shall have at least one member i
10 with nuclear background and one other member familiar with the ,
it conditions of the the facility. In addition, the Radiation Safety 12 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 33 10 greater. In specific instances, the PSC may designate the Chairman 15 to act in its stead, and the Chairman will report his actions to 16 the comittee at its next regular meeting. Meeting minutes will
-17 be distributed to all members and be retained on file.
18 19 4.1.7 Plum Brook Station Management Office (PBMO) 20 The Chief PBM0 shall be knowledgeable of the station activities ,
1 21 that may affect the protected safe storage condition at the P8RF.
22 The Chief PBM0 is responsible for administering a program to 23 ---- ensure that proper operations, control and safeguards are 24 maintained for the station. This includes a key control system.
25 Keys for the PBRF are authorized by the Chief, PBM0 on a "need to 1 l
26 have" basis to persons having knowledge of the conditions, the 27
/ 1 hazards and procedures of the PBRF. Implementation is by an 2 authorization letter issued to the key distributor. The PBM0 3 shall provide for the services of Plant Security, Inspection, 4 . Health Physics, and Maintenance as necessary at the PBRF. -
5 6 4.1.8 PBRF Engineer (Reactor Manager) 7 The PBRF Engineer shall be appointed to manage and assure the s protected safe storage condition is maintained in accordance with 9 these Technical Specifications. The PBRF Engineer shall have the to following qualifications:
11 a. A bachelor's degree in engineering or a related physical 12 science.
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13 b. Be knowledgeable in radiation hazards and radiation 14 protection.
15 c. Have successfully completed the training class for 16 familiarization with the duties of ^he reactor manager.
17 is The PBRF Engineer shall assure protected safe storage conditions 19 are maintained and necessary inspections are performed with 20 records to support the inspection. He shall train and/or qualify 21 personnel to maintain protected safe storage conditions. He shall 22 review maintenance procedures and results to assure buildings and 23 grounds remain in an acceptable quality condition. The PBRF 24 Engineer shall assure unusual occurrence reports, facility 25 changes, and new or revised procedures are prepared, approved and 26 issued. He shall approve all PBRF facility changes, new or 27 22-i e
( .
. . i
'I revised procedu'res. He shall approve all major material or 1 i i 2 equipment transfer in and out of the PBRF. The PBRF Engineer 3 shall prepare license change request for submission to.the NRC.
4 -
S 4.2 Procedures 6 All new or revised procedures will be reviewed by the PBRF Safety 7 Comittee and approved by signature of the PBRF Engineer and the s chainnan of the PSC.
9 10 4.3 Reports 11 Reports required under license and applicable regulations shall be 12 provided. In addition, NASA shall report in writing to NRC within
. 13 90 days after each calendar year sumarizing the following:
14 15 a. Condition of systems and components needed to maintain the is protected safe storage condition.
,17 b. An assessment of the effectiveness of security and i is surveillance.
19 c. Significant changes in PBRF management organization.
20 d. Results of facility and environmental radiological surveys.
21 e. Changes to the facility pursuant to Section 50.59 of 10 CFR 22 Part 50.
23 f. Exposure range and total number of persons provided with 24 monitoring per 10 CFR Part 20.407. l 15 26 27
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9
. . , - , ~ - - . - , - - - , - - - , - - - - - - - - -
, - - - - - - , , - ,--,,_,,,,-,,,,,,,--,,-_c-, -
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9 1 4.4 Records 2 NASA shall keep records required by applicable licenses and 3 regulations including the following:
, 4 a. Radiological survey results of PBRF and environment. -
5 b. Equipment maintenance records (EMR's) of non routine ,
6 maintenance operations involving substitution or replacement of 7 vital components.
s c. The end condition statements, the procedures used to place the 9 facility in the standby condition, and the procedure completion reports shall reflect the facility condition in the
{ lo 11 possess-but-not-operate status.
12 d. Up-to-date facility drawings.
- 13 ,
14 5. References 15 (1) ' Code of Federal Regulations, Title 10. " ENERGY", Government 16 Printing Office, Washington D.C. ,
m
.17 (2) American National Standard for the Development of Technical
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1s Specifications for Research Reactors, ANSI /ANS 15.1-1982 American 19 Nuclear Society, LaGrange Park, Illinois.
20 21 22 13 24 25 26 27
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