ML20236K228

Responds to Violations Noted in Insp Rept 50-020/86-01. Emergency Plan & Procedure Pages Requiring Mod to Reflect Action Taken to Resolve Item 84-01-02 Encl

ML20236K228
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	11/05/1987
From:	Bernard J, Lisa Clark NUCLEAR REACTOR LABORATORY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8711090155
Download: ML20236K228 (7)

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NUCLEAR REACTOR LABORATORY- i b f2 7 AN INTERDEPARTMENTAL CENTER OF MASSACHUSETTS INSTITUTE OF TECHNOLOGY l

O.K. H ARLING 138 Albany Street Cambridge, Mass. 02139 L CLARK, JR.

Dirtetor (617) 253- 4211/4202 Director of Reactor Operations L

November 5,_1987 l U.S. Nuclear Regulatory Commission l' ATTN: Document Control Desk Washington, D.C. 20555

( Gentlemen:

Subject:

.0 pen Item ' #84-01-02, Facility Operating License No. R-37, Docket No.,50-20 Inspection report No. 50-20/86-01 notes that item #84-01-02 re-mains open. The purpose of this letter is to inform you, pursuant to 10 CFR 50.549 , that action has been taken to resolve this item. This action was - -implemented in accordance with the general guidelines provided in discussions with your staff during the aforementioned t

inspection.

Enclosed are two sets of the pages of both our emergency plan and our emergency procedures that required modification to reflect this action.

Sincerely, ek f( Yhm t .Ac '

John A. Bernard, Ph.D. Lincoln Clark, Jr.

Superintendent Director of Reactor Operations JAB /gv

Enclosure:

Plan and Procedure page changes Copy to: USNRC, Region I Chief, Reactor Projects USNRC, Region I Project Inspector I

Resident Inspector Pilgrim Nuclear Station

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Table 4.7.2.1-1: Effluent Detector Characteristics A. Plenum / Stack Particulate Monitors l

1. Monitor flow rate: 3 10" ml/ min

2. Efficiency:

(0.54 MeV Beta) 16.6%-18.2%

(Alpha without self-absorption) 6.4%- 8.8%

(Alpha with self-absorption) 3.2%- 4.4%

3. Range:

(All except stack particulate #2) 20-200K cpm (Stack particulate #2) 20-2000K cpm

4. Means to collect iodine: Charcoal filter B. Plenum / Stack Gas Monitors

1. Monitor flow ratc: 3 10" ml/ min

2. Efficiency:

(Ar-41) 1.9 0-8-2.6 10-8 pCi/ml-epm 3.. Range:

( All except stack gas #2) 20-200K cpm (Stack gas #2) 20-2000K cpm C. Stack Area Monitor 1

i 1. Monitor flow rate: Immersed in stack

2. Efficiency:

(Ar-41) 10-" uCi/ml = 1.8 mR/hr l 3. Range: 0-100 mR/hr D. Core Purge Monitor

1. Monitor flow rate: 4-6 cfm

2. Efficiency:

j_ (Fission gas spectrum) 45K cpm = 10% MPC(I)

3. Range: 0-200K cpm 0-2000K cpm with x10 switch E. Auxiliary Core Purge Monitor

1. Monitor flow rate: 4-6 cfm

2. Efficiency:

(Fission gas spectrum) 1.0 uCi/mi = 96 mR/hr

3. Range 0-10,000 mR/hr (1) This means that a rise of 45K counts above the core purge moniter's back-ground level corresponds to 10% of MFC at the point of public occupation when a dilution factor of 900 is assumed and when the nuclides present are those found in a fission gas spectrum.

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l' PM 4. 7. 2 Pg. 4 of 21 Table 4.7.2.1-2:

L Effluent Detector Efficiencies Assumed in the Calculation of Projected Off-Site Doses l

A.. Plenum / Stack Particulate Monitors Efficiency:

(0.54 HeV Beta) 12.5%

(Alpha without self-absorption) 4.8%

(Alpha with self-absorption) 2.4% 4 B. Plenum / Stack Gas Monitors s

Efficiency 3.25+10-8 UCi/ml-cpm 1

'C. Stack Area Monitor Efficiency- 10-" pCi/ml = 1.35 mR/hr ,

1 D. Core Purge Monitor.

Efficiency 34K = 10.0% MPC E. Auxiliary Core Purge Monitor.

Efficiency 1.0 uCi/cl = 72 mR/hr Note: Figures shown here assume, as a conservatism, that the action levels are reduced by 25%.

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"4i N's. :One ' solution; would be to eliminate some .of the . conservatism > in calculating f

the' projected off-site doses , for 'a General Emergency... .However, the ' approach j L.: . . . - ; <

specifie'dl has been used ' by : the MITR II f o r . yea rs ', is' well-understood by, the t -]

facility's st'aff, and does insure lthat timely, albeit conservative, action wouldL I

, . be taken to protect the public. Another solution would be to Linstall additional I

'ef fluent . instruments that, ' by monitoring the ef fluent streams prior .to ' the point' l

where they merge with. the containment building's exhaust ventilation, would be

'more sensitive. This hassbeen accomplished through'the installation of an auxi-11ary . core purge monitor which :is a specially shielded detector positioned near j i

> an enlarged volume .in the core purge piping.- ' This unit has been calibrated . so '

that it> indicates radiation . levels corresponding to the unusual ' event alert ,

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and ' site area . emergency criteria. i It should be recognized that, unlike the General' Emergency situation where f

immediate action cust be taken to protect the public, there are at least twenty-four - hours available for assessment and decision-making in the event of condi-tions that would warrant declaration of one of the lesser classes of emergency. {

i The . MITR-II's ' policy has been ' and .- is to maintain written procedures at the i

' Abnormal Operating Procedure (AOP) level which, among other things, require that any abnormal radiation level be investigated, and, if levels approaching those i stipulated for a given emergency class are confirmed, the appropriate emergency be declared. This policy, besides being conservative and practical, takes ad-  !

vantage of the excellent counting equipment available at the MIT Reactor. As an illustration of how this policy works, consider the reactor's core purge monitor which continuously samples an air purge that is drawn across the surface of the primary coolant. This detector uses a GM pancake tube, has characteristics sim-Ilar to the plenum gas monitors described in section 4.7.2 of this plan, and is calibrated at least quarterly. The air purge that is drawn across the primary coolant is approximately (5/8000) or 0.06% of the containment building's total ventilation flow. Its detection efficiency, which is given for a fission gas spectrum in Table 4. 7. 2.1-2 of this plan, shows that a constant level of 3400K SRf-0-86-5 oCT 1 1987 1

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cpm' sustained over ~ a twenty-four hour period would be necessary to create an off-site dose of 10 MPC. (Note: The upper limit of the monitor's range is l 2000K cpu so it would not be practical to specify 3400K cpm as an EAL for ]

I declaration of an unusual event.)

The w rit ten AOP requires that sampling, beyoi.d the routine analyses, be initiated if levels increase 5-107. above background and that the reactor be shut down if a conservatively set level is sustained for a specified brief period. Tne reset level is well below that for j i

the lowest emergency class. ]

l 4.7.2.3 Portable Instruments

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The MIT Research Reactor is equipped with several dozen portable radiation f I

monitoring instruments. Most units use either ion chambers or GM tubes to {

detect either gamma or beta radiation or both. In addition, the MITR-II has -)

a portable alpha survey me t e rs as well as polyethylene-encased BF3 tubes and a l

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spherical, 11thium-6, europium-doped detector for use 1n making neutron surveys. l These instruments, which are all calibrated at least quarterly, would be used to measure and confirm projected radiation dose rates both on and of f-site. Each survey meter is calibrated tn read in units of mrem / hour. Contamination levels l both inside and outside the facility would be measured by wiping a filter paper over a standard area (100 cm 2

) of exposed surface, recording the location of the surface, and then counting the paper in a low background area.

1 Additional survey meters would be available f rom either NRL laboratories or the MIT Radiation Protection Of fice.

The MIT Campus Police have been issued a sturdy metal container that holds a beta / gamma detector, an air sampler, protective respiratory devices, direc- s tions on the use of equipment, survey sheets, and spare filters etc. All patrol f

r cars used or owned by MT have been specially outfitted so that the air samplers i will plug into an attachment on the car's dashboard. These instruments are maintained by the MITR Radiation Protection Of fice and are calibrated quarterly.

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Page 1 of 16 j 4.4.4.15 Escape of Airborne Radioactive Material From the Containment Building I

l The MITR's standard, abnormal, and emergency operating plans are structured  !

to insure that there will be an appropriate, graded response to any emergency, l l

particularly those involving radiation. The actions specified by this procedure are to be taken if there has been or is an airborne release of radiation, either gaseous or particulate, in excess of predetermined limits. Situa tions involving i radiation releases that are below these limits should be addressed in accordance with AOP #5.6.2, "High Level Radiation Monitors".

IMPLEMENTING CRITERIA

1. The criteria used to select among the possible responses (Action IX, action 2X, A0P #5.6.2) to an escape of airborne radioactive material are given in

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the following tab 13. Note that all dose rates are expressed as excess over f normal operating background. If action 2X is appropriate, determination of the emergency class (event, alert, site) should be made by direct reference to the auxiliary core purge monitor.

EHERGENCY DIRECTOR

'l. Initially, the Emergency Director is the on-duty shift supervisor. That individual is responsible for initiating and carrying out all provisions of the emergency plan, including this procedure. Once the on-site staff is augmented by other members of the staff, the senior licensed member on-s t te will assume the responsibilities of the Emergency Director. Ultimately, responsibility and authority will be divided as follows:

a) Emergency Director - Director of Reactor Operations b) Supervisor of Off-Site Activities - Reactor Superintendent c) Supervisor of On-Site Activit.ies -

Assistant Superintendent j NOTIFICATION LISTS l

1. Notification lists are appended to this procedure.

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PM 4.4.4.15 Pags 14 of 16

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Action 2X - Event / Alert / Site Emergency

1. Implement the immediate and f ollow-up actions listed under action IX (Gen-eral Emergency) except that the active participation of Civil Authorities should not be requested. Instead, Civil Authorities should be notified of the emergency and requested to stand-by. Also, notify the agencies listed in step #8 of the off-site follow-up action of procedure IX.

2. If air samples drawn from downstream of the filters at the base of the reactor stack indicate the presence of excess particulate activity and if the escape is likely to continue, request by telephone that the ventilation system be stopped' in the following:

NECCO 876-4700

3. If the magnitude of the release is such that the probable internal dose to l

people in the path of the effluent will exceed 1 rem whole body or 5 rem j thyroid over a period of ona hour, a General Emergency (1X) should be de-clared and protective actions for the public recommended to Civil Authori-

.i ties.

4. Determine the class of the emergency using the following table:

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Required Condition Emergency Emergency Emergency Class Class Class ]

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- Auxiliary Core Purge Monitor average 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: i indication is in ' Unusual Event' range for j time shown and ventilation not isolated Event i

- Auxiliary Core Purge Monitor average 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s: 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

indication is in ' Alert' range for time shown and ventilation not isolated Event Alert 1

Auxiliary Core Purge Monitor average 1 hour: 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s: 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: l indication is in ' Site Area' range for l time shown and ventilation not isolated Event Alert Site j l

Plan 2X initiated Site Site Site l l

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