ML20082M742
| ML20082M742 | |
| Person / Time | |
|---|---|
| Site: | Washington State University |
| Issue date: | 11/28/1983 |
| From: | Wilson W WASHINGTON STATE UNIV., PULLMAN, WA |
| To: | Thomas C Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20082M745 | List: |
| References | |
| NUDOCS 8312060258 | |
| Download: ML20082M742 (2) | |
Text
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. e WASHINGTON STATE UNIVERSITY PULLMAN, WASHINGTON 99: a i3oo NUCLEAR RADIATION CENTER November 28, 1983 [
Mr. Cecil 0. Thomas, Chief Standards and Special Projects Branch Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C. 20555 I
Dear Mr. Thomas:
In accordance with the provisions of Section 5.90 of 10 CFR 50, application is ,
hereby submitted to amend the Technical Specifications of Facility License No.
R-76. The specific proposed changes are to Sections 5.4 and 4.3.3 as attached and 3.12 as described below.
j The change to Section 4.3.3 is desired to more clearly define the radiation mor.itoring instrumentation installed at the facility and the required surveil-i lance activities for these systems. The actual systems were reviewed by the NRC during the recent licensing of the facility and were found to be adequate as indicated in the NRC written SER on the facility. However, due to an over-sight, a technical specification surveillance requirement for the Argon-41 syste.a was omitted and that for the continuous air monitor was improperly stated.
The attached proposed revised Section 4.3.3 corrects these problems and provides more clearly defined surveillance requirements for all radiation monitoring d systems.
The change in Section 5.4 is desired to make this section correspond with section 4.3.3. In addition, a change is desired in paragraph (2) of Section 3.12 related to ALARA. The facility has for a number of years been monitoring the radiation background level around the site and in the Pullman area. The standard deviation
+>f the composite data was recently calculated and found to be of the order of 19%
of the measured value. Thus the 20% criteria that WSU suggested and that was put into the Technical Specifications is not statistically valii.
A more statistically meaningful criteria would be to replace tu "20%" specifi-cation with a 95% confidence limit of "two sigma." That is, if the annual radiation exposure level at the closest offsite point of extended occupancy ;
exceeds the mean offsite measured background by two signs, one can assert with 95% confidence that the increase is due to other than background radiation. This l 8312060258 831128 PDR ADOCK 05000027 90 P PDR E9 ,
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November 28, 1983 Mr. Cecil O. Thomas From W. Wilson Page 2 i
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r ALARA criteria is really quite strict and essentially specifies "no statis- !
tically significant increase in the offsite background at the closest off-site point of extended occupancy." Accordingly, we desire the "20%" in the AMRA criteria to be changed to "two -;igns."
Sincerely,,
A2. f. 61)-
W.'E. Wilson Associate - Director Y M ,1 l kCtfe yd 72 bay <% M- ,
WEW:eim fs.fL/,mam, f,j.p3 m g y
enclosures t
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i APPROVED: /A//1/24 V
[) J. C. !h pard, Chairman Reactor Safeguards Committee i
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