ML20236X594
| ML20236X594 | |
| Person / Time | |
|---|---|
| Site: | Oregon State University |
| Issue date: | 07/27/1998 |
| From: | Dodd B Oregon State University, CORVALLIS, OR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20236X596 | List: |
| References | |
| NUDOCS 9808100125 | |
| Download: ML20236X594 (5) | |
Text
RADIATION CENTER OREGON STATE UNIVERSITY 100 Radiation Center. Corvallis. oregon 9733 l 5903 Telephone 541-737-2341 Fax 541737-0480 July 27,1998 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 Senior Reactor Operator's License No. SOP-3776-5; Docket No. 50-243
Subject:
Staff Changes and Proposed Amendments to OSTR Technical Specifications Gentlemen:
This purpose of this letter is to inform you of personnel changes at the Radiation Center and to request a clarifying amendment to the OSTR Technical Specifications.
Personnel Changes In accordance with Technical Specification 6.7.c.3, I would like to inform you that I will be taking a leave of absence from Oregon State University to fill a Research Reactor Specialist position with the International Atomic Energy Agency in Vienna. Effective September 16,1998, Dr. Stephen E.
Binney will be the new Radiation Center Director. He will also be the Interim Director during my vacation beginning August 8,1998.
It should also be noted that because I will not be present to meet the operational requirements of the OSTR requalification plan during this leave ofabsence, my Senior Reactor Operator's license, license (No. SOP-3776-5) will become inactive.
E Proposed Change to Technical Specification 3.8.e.
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'y Add the words " averaged owr ayear " so that the revisedphrme will read: "the quantity and type ;
ofmaterialin the experiment shall be limitedsuch that the airborne concentration ofradioactivity in the reactor bay and the unrestricted area averaged over a year will not exceed the applicable 9808100125 90'727 v PDR ADOCK 05000243 P PDR
l lb U.S. Nuclear, Regulatory Commission Page 2 Ju!y 27,1998 regulatory concentration limits in 10 CFR 20, assuming 100% ofthe gases or aerosols escapefrom the experiment. "
As stated in the basis of this Technical SpeciGcation, the purpose is to " reduce the likelihood that airborne radioactivity in excess of the limits in Appendix B of 10 CFR 20 will be released to the reactor bay and unrestricted areas surrounding the OSTR."
Appendix B of10 CFR 20 specifically states that the Table ! "ALIs are the annualintakes...which would result in either (1) a conunitted effective dose equivalent of 5 rems (stochastic AL1) or (2) a committed dose equivalent of 50 rems to an organ or tissue (non-stochastic All)." It also states that "The derived air concentration (DAC) values are derived limits intended to control chronic occupationalexposures." These are bssed on dividing the ALI by 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per working year. In addition the Table 2 notes in Appendix B state that "The concentration values...are equivalent to the radionuclides concentrations which, ifinhaled or ingested continuously over the course of ayear, would produce a total effective dose equivalent of 0.05 rem (50 millirem or 0.5 millisieverts)."
It is clear from these references that it requires inhaling on ingesting radioactive material at the 10 CFR 20 Appendix B concentration limits for a whole year to result in a dose equal to the annual dose limit. However, as currently written, it could be argued that Technical Specification 3.8.e. appears to limit an instantaneous concentration in the reactor bay or unrestricted area to these annual values.
Clearly this is extremely conservative and is almost certainly not what was originally intended (as indicated by the basis). For example, in order for a person to receive a dose equal to the occupational limit in the reactor bay, the experiment would have to fail by continuously releasing airborne activity to keep the concentration at the Appendix B, Table 1, Cohima 3 value for a whole year! Such a situation is totally unrealistic. In reality, any accidental release would be a one-time, puff event and the reactor bay would be evacuated within a minute or two at the most. If the putTrelease was at the Appendix B limit then a two minute exposure would result in an individual's dose being 2/(2000x60),
or 0.000017 of the annual limit. The same arguments hold for the unrestricted area concentration.
Since the Appendix B values are so clearly related to annual limits, it could be argued that the proposed wording clarification is not needed. but is already implied in Technical Specification 3.8.e.
However, we believe that the Technical Specifications should be as clear as possible and therefore !
respectfully request the proposed change. Attachment A contains the necessary replacement page should you agree to the proposed Technical Specification amendment.
I On a separate matter, you have for a long time sent copies ofyour letters to M. W. Alsworth of the Oregon Department of Energy. Please be informed that Mr. Alsworth left this agency several years l
l l ago, and the Oregon Department of Energy is now the Oregon Office of Energy. Therefore, in the i l
future you may wish to copy such correspondence to Mr. David Stewart-Smith, at the Oregon Office l cf Energy. The rest of the address is correct. !
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- e-U.S. Nuclear, Regulatory Commission Page 3 July 27,1998 l
l Please feel free to contact me or my replacement, Steve Binney, should you have any questions with l respect to the personnel changes or the proposed amendment.
gYours si cerely, Wi O Brian Dodd, PhD Director
! c: Al Adams, Senior Project Manager, Non-Power Reactors and Decommissioning Projects l' Directorate, U.S. Nuclear Reguiatory Commission, M.S. 0-11-B-20, Washington, D.C.20555 Oregon Office of Energy,625 Marion Street, NE, Salem, Oregon 97310, l Attn: David Stewart-Smith Wilson 'Toby' Hayes, Vice-Provost for Research Stephen E. Binney, Chairman Reactor Operations Conunittee Jack F. Higginbotham, Reactor Administrator David S. Pratt, Senior Health Physicist Arthur D. Hall, Reactor Supervisor L
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4-U.S. Nuclear, Regulatory Commission Page 4 July 27,1998
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State of Oregon )
) ss County of Benton )
Brian Dodd, being first duly sworn on oath, deposes and says that he has aflixed his signature to the .
letter above in his olliciel 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 aflidavit; that the facts set forth in the letter within are true to his best information and belief.
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@stomamsmutwsussensuraten Brian Dodd, Director Subscribed and sworn before me, a Notary Public, in and for the County of Benton, State of oregon, this $'d day of 42vp , A.D.,1999.
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