ML20207J818
| ML20207J818 | |
| Person / Time | |
|---|---|
| Site: | 05000131 |
| Issue date: | 03/12/1999 |
| From: | Claassen J DEPT. OF VETERANS AFFAIRS MEDICAL CENTER, OMAHA |
| To: | Alexander Adams NRC |
| Shared Package | |
| ML20207J794 | List: |
| References | |
| 636-151, NUDOCS 9903160404 | |
| Download: ML20207J818 (12) | |
Text
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DEPARTMENT OF VETERANS AFFAIRS Medical Center 4101 Woolworth Avenue Omaha NE 68105 March 12,1999 in Reply Refer To: 636/151
- Alexander Adams, Jr.
j Senior Project Manager US Nuclear Regulatoiy Commission Mailstop O-11-D-19 11555 Rockville Pike Rockville, MD 20852-2738 Re: Docket 50-131
Dear Al:
Enciosed you wil; iind two copies of the additional information requested for the renewal of our Facility Operating License R-57. The original has been sent to the Document Control Desk.
It is my hope that I have adequately addressed the questions and comments outlined in your July 20,1998 letter. The documente herein have also been revised based on meetings during your Site Visit to our facility last January.
The Safety Analysis Report and Technical Specifications are enclosed as complete documents.
There were numerous changes and additions to both. For purposes of clarity, I have included five attachments to this letter. Attachment #1 is an itemized summary list of additions and changes made to the SAR. Attachment #2 is a memo authorizing ALARA responsibility to the Reactor Manager in response to Question A.I. In response to our phone conversation of February 10, I am also oroviding a " Financial Statement" as Attachment #3. To represent this information, I have enclosed the Depertment of Veterans Affairs, Office ofInspector General, " Semiannual Report to Congress, April 1,1998 to September 30,1998." Attachments #4 and #5 are the Safety Analysis Report and Technical Specifications respectively.
Sincerely, m
John P. Claassen Reactor Manager
Enclosures:
Reply to Questions (Attachments 1 and 2)
Financial Report (Attachment 3)
Safety Analysis Report (Attachment 4)
Technical Specifications (Attachment 5) 9903160404 990312 7 PDR ADOCK 05000131s k
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A I I AC-lMENT #1 1
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ATTACHMENT #1 Answers to Questions in Request for Additional Information
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A.
Radiation Protection Program 1.
Section 2; The Reactor Manager is responsible for the ALARA program as delegated by the Chairmea of the Reactor Safeguards Committee. A copy of the appropriate memorandum is provided as Attachment #2.
2.
Section 4.3.1; The table provided in Section 4.3.1 was written with respect to Table 1 of ANSI /ANS-15.11-1993, " Radiation Protection at Research Reactor Facilities". However, this table has now been deleted and the section reads as follows:
4.3.1 Limits for Removable and Fixed Contamination:
Radioactive waste to be disposed ofin this manner shall be held for decay a minimum of 10 half-lives. Before disposal as ordinary trash, byproduct material shall be surveyed at the container surface with the appropriate meter set on its most sensitive scale and with no interposed shied 3 to determine that its radioactivity cannot be distinguished from backgroand. All radiation labels shall be removed or obliterated. A record of each disposal permitted under this condition shall be retained for 3 years. De record must include the date of
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disposal, the date of which the byproduct material was placed in storage, the (s
radionuclides disposed, the survey instruments used, the background dose rate, the dose rate measurM at the surface of each waste container, and the name of the individual who P.ormed the disposal. Otherwise, the material will be deposed ofin accordance with 10 CFR 20 subpart K and other applicable regulations.
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- 3. Section 5.3, page 7; The last sentence has been deleted.
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- 4. Section 5.3, page 8; Additional criteria have been added in Section 5.3 to I
address internal radiation control.
B Safety Analysis Report, December 17,1997 1.
Section 1.2; The value has been changed to 250 MW.
2.
Section 2.1; There is no longer a rail line that runs by the medical center.
Figures 2.1 (Omaha Area Map) and 2.7 (Omaha Area Topography Map) have been updated. There is no rail line that runs near the medical center on the updated maps.
There is no industrial activity in the are that would have an impact on the facility. Additionalinformation has been provided in Section 2.1.
l Section 8.2.4 Air Traffic and figures 8.1 to 8.3 have been added to OV t
l address questions regarding local airports and flight airways.
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3.
Section 2.4.1, Groundwater Hydrology; a.
Appendix D was altered to reference Section 2.4.1 to show a connection between the two.
b.
Section 2.4.1 was thanged to address these questions.
4.
Section 2.5, Earthquakes; Section 2.5 now addresses these questions.
5.
Section 2.6, Tornadoes; Tomado calculations have been reassessed with regard to NUREG/CR-4461.
6.
Section 3.2.1; Calculations were perforr"ed with MCNP for aluminum fuel for both dry and wet conditions. The results are provided as Appendix E (referenced from Section 3.2.1) and show k, < 0.8 for all conditions up to 25 elements per pit.
7.
Section 3.2.9, Reactor Water and Purification System; There are no significant radiological consequences of such a release. This section was rewritten to address these concems.
8.
Section 3.2.10.2.5, Effects of Fuel Aging; The fuelinventory currently in use were acquired as new elements. Thus, the core element irradiation history is known. This section has been amended to add this information.
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Section 3.2.13, Limiting Design Basis; this section has been reworded so that it does not imply primary reference to NRC documents.
10.
Section 3.2.13, Dynamic Behavior of Reactor; a.
Page 3-23, second paragraph; the paragraph has been corrected. The value was for the effective neutron lifetime.
1 b.
Subsection a); Additionalinformation has been provided in Section 3.2.13 with respect to the phase change of zirconium hydride with increase" temperature.
11.
Figure 4-1, Block diagram of instrument; (a&b). This Figure has been redrawn.
12.
Table 4.1, Minimum reactor safety channels; The footnote has been corrected.
13.
Section 4.2; Section 4.2 has been amended and Section 8.1.4
- Failure of the Recorder" has been added to analysis this scenario.
l 14.
Section 4.3.1.1, Nuclear Instrumentation; Use of the term " hardwired" in these sections means analog connections. Sections 4.3.1.1 and
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4.3.1.2 have been clarified.
15.
Figure 4.3.1.2, Functional Diagram NM - 1000; A clear copy has been provided.
16.
Section 4.3.1.2, Reactor Power Safety Channel, third paragraph; There are no specific nuclear qualification design standards applied to the TRIGA reactors. The requirement is simply some system that will scram the reactor if limited safety system settings are exceeded. Any specified response time would normally have to be incorporated into the technical specifications. The two systems meet two requirements (1) to provide two sources of reactor power ir. formation, and (2) provides two independent high power scrams. However, specific references to requirements have been deleted in order to eliminate confusion.
17.
Watchdog timers are typically incorporated into the software. In these cases, it is the software that activates an independent timer every time the code passes one or more steps. Consequently, if the software program hangs up, the timer will not be reset and the scram will occur.
Section 4.3.1.3 has been amended to respond to these questions, in regard to the term
- key soft tasks"; I was unable to locate this specific terminology. As a result, its usage was eliminated. A more descriptive term and its properties were substitut~j into Section 4.3.1.3.
I 18.
Section 4.3.2, Process Instrumentation; (a) Based on calculations provided in Appendix B, the maximum activity available for release to the coolant per element is 0.07 Cl. Since General Atomic sized the wates box to give 100 mR/h for a 0.1 Mci /cm3 solution of 5 minute old tission products, the alarm would only sound if more that 25 elements tailed. The water box monitor will not alarm for a single fuel failure. However, the increased readings should be noticeabia. Section 4.3.2 has been changed to address these issues.
This paragraph has been reworded.
(b) There are currently 2 CAM's (NMC AM2D & Eberline AMS 3A)
(c) available for operation. Procedures are available for detemlination of the CAM's alarm set point based on the detection of 2000 picoeuries/ milliliter. This section has been rewritten and section 7.4.1 has been referenced. The iodine monitor mentioned previously is simply a charcoal filter that can be detached and counted to identify iodine.
19.
Section 5.2, Void coefficient, last sentence; Section 5.2 has been reworded.
20.
Chapter 6, Conduct of Operations; a.
Section 6.2 has been changed to reference additional documents.
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' Section 6.1.1.4 has been changed to be more descriptive of the commit'ee's activities.
c.
Section 6.1.1.5 has been changed to address this question.
d.
These activities are outlined in the Facility Technical Specifications. Section 6.2 has been altered to address this question.
e.
These activities are outlined in the Facility Technical Specifications. Section 6.2 has been altered to address this question.
21.
Based on future needs and possible up-grades the possession limits and where the need is written in the SAR are as follows:
(1) 3.3 kilograms of uranium - 235 at enrichments less than 20%
(section 7.1.1).
(2) 20 grams of uranium - 235 at enrichments greater than 20%(section 7.1.2).
(3) 8 curies of sealed polonium - beryllium (section 7.1.7).
(4) 4 curies of americium - beryllium (section 7.1.7).
(5) 1.5 curies of cesium - 137 as a sealed source (s) (section 7.1.7).
(6) 10 millicurie of iodine - 129, simulated iodine - 131, lead - 210, cobalt - 60, and technetium - 99 (section 7.1.7).
Items (1) and (2) will be for use in connection with operation of the k
reactor. Either of items (3) or (4) will be used as a sealed neutron source for reactor start-up. Byproduct material requirements specified in items (5) and (6) are sealed sources necessary to check and calibrate radiation detection equipment used in conjunction with reactor operation.
22.
Section 7.1.6, Radioactive Waste; Section 7.1.7 has been amended to address this issue.
23.
Section 7.1.7, Other Radioactive Material; This issue has been addressed in Question A.2. Section 7.1.7 has been changed and Table 7.1 has been deleted.
24.
Section 7.2.1, second paragraph; Section 7.2.1 has been changed to
. address this isssue.
25.
Section 7.2.3, Management Survei!!ance; Section 7.2.3 has been changed to address these issues. Additional information includes the scope and criteria for restrictions on experiments to limit potential hazards to the public and to reactor components.
i 26.
Section 7.4, Evaluation of Monitoring Systems; j
(a) This statement has been deleted as it is not fundamentally sound.
(b) The efficiencies for the CAM's are based on Tc-99. References to the efficiencies have been changed and moved to section 7.4.1.
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(c) Currently we have two CAM's, both of which can detect radioactive particulates but are unable to detect noble gases, iodines, and mar.
As stated in SAR, Section 4.3.2, the potential for release by these radionuclides are held below 10CFR20 limits. This is with respect to the Maximum Hypothetical Accident (MHA), normal operations, and approved experiments.
Section 7.4.1,This table has been deleted as it does not appropriate for 27.
Particulate Air Monitor; (a) Table 7-2; these calculations.
(b) Last paragraph; Section 7.4.1 has been completely rewritten.
Experiments are restricted administratively so that failure of experiments will not lead to deses in excess of 10 CFR20 limits.
Please refer to SAR, Section 4.3.2.
28.
Section 7.5; page 7 - 10, second paragraph; this value has been recalculated. Changes have been made to Section 7.5. Appendix F, Gamma Flux from Irradiated Fuel has been added. The new appendix presents the deductions and calculations for the value specified in Section 7.5.
29.
Chapter 8, Accident Analysis (a) Section 8.1, third and fourth paragraphs; aMaximum Hypothetical Accident" has replaced " Design Basis Accident" where needed. SAR, Appendix B, Section B.2 addresses the issue of element release in water.
(b) Section 8.1.1; (1) First paragraph; the references to the long term contamination of the coolant from a leaking fuel element has been deleted. However, its significance is minute in that a leaking fuel element would be found and removed form the core once it was discovered. The majority of the calculations for release of fission products are performed in Appendix B, Section B.1. Please also note that the sections in Chapter 8 have been rearranged for clarity.
30.
Section 8.1.3, Handling irradiated fuel; (a) Appendix B has been completely rewritten and 48-hour references have been eliminated.
(b) The ventilation is not a designed safety feature and at ' result is assumed to be running during the acciden' scenario.
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would however be significantly reduced as expense or occupations; exposure.
(c) These tables have been deleted in favoi of newly created tables.
(d) Section 8 now contains a more detailed summary of results.
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C Appendix A 1.
The title has been changed to "Airbome Releases during Normal Operation".
- 2. Section A.1, paragraph 2; The decay term has been noted.
- 3. Page A-4, section A.1; The release fraction f,_,3has been recalculated based on the model presented by Dorsey. This is a similar approach to that of the University of Texas-Austin's 1991 SAR.
- 4. Page A-5, section A.1; The value for the Argon-40 cross section has been changed to 0.47 x 10-24 cm2 which is slightly less than the purely thermal value of 0.65 x 10 24 Our value takes into consideration the harder neutron spectrum of the TRIGA reactor.
- 5. Page A-5, Section A.1, list of variaoles; The hemispherical dose calculations have been recalculated.
- 6. Page A-6, Section A.1, list of variable,; The hemispherical dose calculations have been recalculated.
- 7. Page A-6, Section A.2,last paragraph;
- a. The section A.2 has been amended to include Atmospheric and stability class descriptions. Figure A-1 "Offsite Distances" has been added to this section.
Figure A-1 will provide distances from the exhaust sites in question. The sites of release, can therefore, be referenced to Table #1 of this Appendix.
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This table has alsv been modified to provide additional clarity.
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- b. Calculations will be based on 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> of operation as a realistic estimate on the side of conservatism. A maximum value is highly subjective as values are dependant on the number of samples irradiated, their irradiation times, decay times, etc. However, as a maximum value a factor of 2 could be applied to activity production values.
- c. These values have been recalculated.
- d. As stated in 7a, additional information on atmospheric conditions, etc. have i
been added.
- e. This section has been clarified to address these issues.
- 8. Section A.3, page A-8 next-to-last paragraph; this calculation hau been changed. Physically, the approach is similar to the calculation for d'Ar which was addressed in before mentioned question C3.
- 9. Section A.3, page A-9; equation 23 has been chan~d and subsequent values have been altered.
- 10. Section A.4 No.1, page A-12, equation 28; this equation is no longer used.
- 11. Section A.4, No.1, page A-13 first paragraph; this section has been revised using more appropriate methodology.
- 12. Section A.4; the appropriate numerical quantities have been revised.
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C Appendix A (O]
1.
The title has been changed to "Airbome Releases during Normal Operation".
- 2. Sectien A.1, paragraph 2; The decay term has been noted.
- 3. Page A 4, section A.1; The release fraction f,yhas been recalculated based on the model presented by Dorsey. This is a similar approach to that of the University of Texas-Austin's 1991 SAR.
- 4. Page A-5, section A.1; The value for the Argon-40 cross section has been changed to 0.47 x 10-24 cm2 which is slightly less than the purely thermal value of 0.65 x 10-24 Our value takes into consideration the harder neutron spectrum of the TRIGA reactor.
- 5. Page A-5, Section A.1, list of variables; The hemispherical dose calculations have been recalculated.
- 6. Page A-6, Section A.1, list of variables; The hemispherical dose calculations have been recalculated.
- 7. Page A-6, Section A.2,last paragraph;
- a. The section A.2 has been amended to include Atmospheric and stability class descriptions. Figure A-1 "Offsite Distances" has been added to this section.
Figure A-1 will provide distances from the exhaust sites in question. The sites of release, can therefore, be referenced to Table #1 of this Appendix.
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- b. Calculations will be based on 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> of operation as a realistic estimate on the side of conservatism. A maximum value is highly subjective as values are dependant on the number of samples irradiated, their irradiation times, decay times, etc. However, as a maximum value a factor of 2 could be applied to activity production values.
- c. These values have been recalculated.
- d. As stated in 7a, additionalinformation on atmospheric conditions, etc. have been added.
- e. This section has been clarified to address these issues.
- 8. Section A.3, page A-8, next-to-last paragraph; this calculation has been changed. Physically, the approach is similar to the calculation for d'Ar which was addressed in before mentioned question C3.
- 9. Section A.3, page A-9; equation 23 has been changed and subsequent values have been altered.
- 10. Section A.4 No.1, page A-12, equation 28; this equation is no longer used.
- 11. Se,ction A.4, No.1, page A-13 first paragraph; this section has been revised using more appropriate methodology.
- 12. Section A.4; the appropriate numerical quantities have been revised.
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C Appendix A
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The title has been changed to "Airbome Releases during Normal Operation".
- 2. Section A.1, paragraph 2; The decay term has been noted.
- 3. Page A-4, section A.1; The release fraction f,yhas been recalculated based on the model presented by Dorsey. This is a similar approach to that of the University of Texas-Austin's 1991 SAR.
- 4. Page A-5, section A.1; The value for the Argon-40 cross section has been changed to 0.47 x 1024 cm2 which is slightly less than the purely thermal value of 0.65 x 10-24 Our value takes into consideration the harder neutron spectrum of the TRIGA reactor.
- 5. Page A-5, Section A.1, list of var; ables; The hemispherical dose calculations have been recalculated.
- 6. Page A-6, Section A.1, list of variables; The hemispherical dose calculations have been recalculated.
- 7. Page A-6, Section A.2,last paragraph
- u. The section A.2 has been amended to include Atmospheric and stability class descriptions. Figure A-1 "Offsite Distances" has been added to this section.
Figure A-1 will provide cistances from the exhaust sites in question. The sites of release, can therefore, be referenced to Table #1 of this Appendix.
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This table has also been modified to provide additional clarity.
- b. Calculations will be based on 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> of operation as a realistic estimate on the side of conservatism. A maximum value is highly subjective as values are dependant on the number of samples irradiated, their irradiation times, decay times, etc. However, as a maximum value a factor of 2 could be applied to activity production values.
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- c. These values have been recalculated.
- d. As stated in 7a, additional information on atmospheric conditions, etc. have been added.
- e. This section has been clarified to address these issues.
- 8. Section A.3, page A-8, next-to-last paragraph; this calculation has been changed. Physically, the approach is similar to the calculation for 41Ar which was addressed in before mentioned question C3.
- 9. Section A.3, page A-9; equation 23 has been changed and subsequent values have been altered.
- 10. Section A.4 No.1, page A-12, equation 28; this equation is no longer used.
- 11. Se,ction A.4, No.1, pa0e A-13 first paragraph; this section has been revised using more appropriate methodology.
- 12. Section A.4; the appropriate numerical quantities have been revised.
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- 13. The summaries at the end of the appendix have been referenced.
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- 14. Section A.4, No. 2, page A-14, mid page; This section has been rewritten.
- 15. Section A.4, No. 2, page A-15, equation (32); This section has been rewritten the equation has been adjusted appropriately, and the summary table has been revised.
D Appendix B 1 -g Appendix B has been completely rewritten from scratch. Determinations are now based on ORIGEN Calculations.
E Appendix C
- 1. This Appendix has been completely rewritten.
F Appendix D
- 1. Determination of soil activities and their migration with respect to the health and safety of the public was reevaluated. References to water volumes and their relative quantities in comparison with 10CFR20 limits have been deleted. New calculations were performed based on ground hydrology transport and subsequent decay at the 30 foot depth and at the site boundary.
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- 2. Table 4 has been revised to assess the activities that might be available to members of the public.
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J ATTACH VIENT #2 O
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Memorandum July 22,1998 ow Chief of Statt(11)
Deiegation of Authority To:
Manager, Nuclear Reactor (151C)
The Chairman of the Reactor Safeguards Committee (Chief of Staff) hereby delegates the responsibility of the A.J. Blotcky Reactor Facility Radiation Protection Program (ALARA) to the reactor manager.
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