ML033420017

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Letter Concerning Revision of the Rhode Island Atomic Energy Commission License R-95
ML033420017
Person / Time
Site: Rhode Island Atomic Energy Commission
Issue date: 11/20/2003
From: Tehan T
State of RI, Atomic Energy Comm
To: Mendonca M
Division of Regulatory Improvement Programs
References
Download: ML033420017 (15)


Text

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS OW RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 November 20, 2003 Docket No. 50-193 Mr. Marvin Mendonca, Senior Project Manager Non-Power Reactors, Decommissioning and Environmental Project Directorate Division of Reactor Projects - IIIVN U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Mendonca:

This letter concerns revision of the Rhode Island Atomic Energy Commission License R-95. The following three changes to the Technical Specifications are requested:

(1) To change the following surveillance specification items concerning the inspection of the core components from annually to a five year cycle.

Surveillance specifications 4.9.a. Beryllium Reflectors (page 38) 4.9.b. LEU Fuel Elements (page 39)

Basis for this change: The Technical Specifications require an annual test and check of the above surveillances of core components (54 elements [fuel and reflector]). The annual inspection of irradiated fuel elements consists of visually inspecting the elements for cracking and/or swelling. Inspections of fuel element are conducted with the element hanging about ten feet below the pool water level to reduce dose rates to personnel. Due to the construction of a fuel element, these inspections are of minimal value as one can only see the two outside surfaces of the outside fuel plates on anyone fuel element. Each fuel element has 42 fuel plate surfaces that cannot be visually inspected with any confidence in the results.

The annual inspection interval of these tests and checks create too many chances to damage and/or drop an element with almost no chance of sighting any swollen or cracked element. To minimize these chances, the core components should be visually inspected and functionally fit into the core grid box' on a continuing basis -

approximately eleven elements (three fuel & eight reflectors) per year, ideally, during i)rQ

Mr. Marvin Mendonca November 20, 2003 Page 2 normal core configuration changes and experiments. This frequency will result in the test and checks of all the elements of the core are completed within a five-year period.

The Technical Specification (4.3.a.3) currently requires that the primary coolant water be analyzed weekly to detect a ruptured element. This technical specification requirement provides for the most sensitive method to discover a failed element.

(2) To change the following Reactor Safety System specification:

a. Add paragraph 3.2.5. - 'At least one radiation monitor on the experimental level of the reactor building and one monitor over the reactor pool are operable and capable of warning personnel of high radiation levels.'
b. Remove listing of area monitors and the continuous air monitor from table 3.2.
c. Add note to table 3.2 - 'Grab sampling may be substituted for monitoring operations for up to eight hours in the event of a monitor failure.'
d. Add text to the bases: page 16.

Basis for this change: The current Technical Specification requires a minimum of two radiation monitors to warn personnel of abnormal radiation levels. However, the current Technical Specification is ambiguous and fails to provide a practical alternative in the event of monitor failure. The change ensures that monitors are provided to cover the two main experimental areas within the reactor area. Failure of either monitor necessitates grab sampling coverage until the monitor can be fixed or the risk is terminated by normal reactor shutdown.

(3) To change page 42, paragraph 6.1.2 from: 'An operator or senior operator licensed pursuant to 10CFR55 shall be present in the control room unless the reactor is secured as defined in these specifications.

The minimum operating crew shall be two individuals.'

to: 'An operator or senior operator licensed pursuant to 10CFR55 shall be present in the control room unless the reactor is shutdown as defined in these specifications. The minimum operating crew shall be two individuals.'

Basis for this change: To allow the reactor operator to leave the control room in order to conduct routine pre-checks of systems and experiments at the pool level without having to turn the control console master switch to the off position.

Enclosed is an original and changed pages, (changes identified with mark in right margin), of the Technical Specifications. This change is submitted as amendment # 29.

Mr. Marvin Mendonca November 20, 2003 Page 3 If there are any questions regarding these changes to the Technical Specifications, you can reach me at (401) 789-9391.

Sincer Terry~~an, Ph.D RI Ato Energy Commission, Director cc: Craig Bassett, U.S. NRC, Region 2

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I Specification 3.1.10 assures that the full volume of the pool water is available to provide cooling of the core during normal operation and in the event of a loss of coolant accident.

3.2 Reactor Safety System Applicability:

These specifications apply to the reactor safety system and other safety related instrumentation.

Objective:

To specify the lowest acceptable level of performance or the minimum number of acceptable components for the reactor safety system and other safety related instrumentation.

Specification:

The reactor shall not be made critical unless:

I. The reactor safety systems and safety related instrumentation are operable in accordance with Tables 3.1 and 3.2 including the minimum number of channels and the indicated maximum or minimum setpoint;

2. All shim safety blades are operable in accordance with Technical Specification 4.1.1 and 4.1.2.
3. The time from initiation of a scram condition until the control element is fully inserted shall not exceed I second in accordance with Technical Specification 4.2.5 and 4.2.6.
4. The reactivity insertion rates of individual control and regulating blades will not exceed 0.02 %AK/K per second.

Bases:

Neutron flux level scrams provide redundant automatic protective action to prevent exceeding the safety limit on reactor power. The period scram limits the rate of rise of the reactor power to periods which are manually controllable without reaching excessive power levels or fuel temperatures.

Page 5 Amendment 28

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I The loss of flow scram assures that an automatic loss of flow scram will occur in the event of a loss of flow when the reactor is operating at power levels above 0.1 MW.

The reactivity insertion rate limit was determined in the SAR,Section XI and predicts a safe fuel clad temperature.

Page 16 Amendment 28

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I TABLE 3.2 Required Safety Related Instrumentation Minimum Reactor Number Operating Mode Instrumentation Setpoint Required Function In Which Reqd.

1. Reactor Coolant < 1110F I Alarm FCŽ0.1MW Inlet Temperature
2. Reactor Coolant c 1190 F I Alarm FC>0.IMW Outlet Temperature
3. Log Count Rate <3 cps I Rod with- Both Modes drawal interlock
4. Servo Control 2 30 sec 1 Auto Control Both Modes Interlock (fullout) Interlock Facility Radiation (a)

Monitoring System

5. Building Air Gaseous 2.5 x I Alarm Both Modes Exhaust (Stack) normal particulate 2 x normal
6. Reactor Bridge 2 x normal Alarm Both Modes
7. Fuel Safe 2 x normal Alarm Both Modes or 5mR/hr, which ever is higher Page 19 Amendment 28

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I Review of the experiments using the appropriate LCO's and the Administrative Controls assures that the insertion of experiments will not negate the consideration implicit in the Safety Limits.

4.9 Reactor Core Components Applicability:

This specification applies to the surveillance requirements for reactor core components affecting reactor power.

a. Beryllium Reflectors Applicability:

This specification applies to the surveillance of beryllium lifetime for the standard and plug type beryllium reflectors.

Objective:

To prevent physical damage to the beryllium reflectors in the core from accumulated neutron flux exposure.

Specification:

The maximum accumulated neutron flux shall be lx1022 neutrons/cm 2 .

The exposure shall be determined annually in accordance with the operating procedures. Inspections and core fit shall be conducted annually.

Bases:

The RINSC SAR (Part A Section VIII) has addressed this limit as a conservative limit. (Annual inspections and core box fit as well as calculated total exposure serve as a method to monitor the beryllium lifetime.)

b. LEU Fuel Elements Applicability:

This specification applies to surveillance of LEU fuel elements.

Objective:

Page 38 Amendment 28

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I To prevent operation with damaged fuel elements and verify the physical condition of the fuel element.

Specification:

The fuel elements shall be visually examined and functionally fit into the core grid box annually.

Bases:

Fuel elements are initially inspected for manufactured specifications and then inserted into the grid box in accordance with QA/QC program requirements for functional fit. Core reloading is performed in accordance with operating procedures. Routine fuel movements are logged and visual inspections are conducted during fuel movements. Pool sampling also is used to detect a ruptured element (Tech. Spec. 4.3.3). The fission density limit for this reactor cannot be exceeded (reference SAR, Part A,Section VI). Burnup calculations are made quarterly (4.9.1).

Page 39 Amendment 28

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision 1 6.0 ADMINISTRATIVE CONTROLS 6.1 Organization and Management

1. The Rhode Island Atomic Energy Commission (RIAEC) shall have the responsibility for the safe operation of the reactor. The organization of RIAEC is shown in Figure 6-1. The RIAEC shall appoint a Director and a Nuclear and Radiation Safety Committee (NRSC) consisting of a minimum of seven members, as follows:
a. The Director, RIAEC
b. The Assistant Director for Reactor Operations
c. The Radiation Safety Officer
d. A qualified representative from the faculty of Brown University
e. A qualified representative from the faculty of Providence College
f. Two qualified representatives from the faculty of the University of Rhode Island A qualified alternate may serve in lieu of one of the above. The Director, Assistant Director and Radiation Safety Officer are not eligible for chairmanship of the Committee.
2. An operator or senior operator licensed pursuant to IOCFR55 shall be present in the control room unless the reactor is secured as defined in these specifications. The minimum operating crew shall be two individuals.
3. A licensed senior operator shall be on duty or readily available on call whenever the reactor is in operation.

Page 42 Amendment 28

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I Specification 3.1.10 assures that the full volume of the pool water is available to provide cooling of the core during normal operation and in the event of a loss of coolant accident.

3.2 Reactor Safety System Applicability:

These specifications apply to the reactor safety system and other safety related instrumentation.

Objective:

To specify the lowest acceptable level of performance or the minimum number of acceptable components for the reactor safety system and other safety related instrumentation.

Specification:

The reactor shall not be made critical unless:

1. The reactor safety systems and safety related instrumentation are operable in accordance with Tables 3.1 and 3.2 including the minimum number of channels and the indicated maximum or minimum setpoint;
2. All shim safety blades are operable in accordance with Technical Specification 4.1.1 and4.1.2;
3. The time from initiation of a scram condition until the control element is fully inserted shall not exceed I second in accordance with Technical Specification 4.2.5 and 4.2.6;
4. The reactivity insertion rates of individual control and regulating blades will not exceed 0.02 %AK/K per second;
5. At least one radiation monitor on the experimental level of the reactor building and one radiation monitor over the reactor pool are operable and capable of warning personnel of high radiation levels.

Bases:

Neutron flux level scrams provide redundant automatic protective action to prevent exceeding the safety limit on reactor power. The period scram limits the rate of rise of the reactor power to periods which are manually controllable without reaching excessive power levels or fuel temperatures.

Page 15 Amendment 29

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I The loss of flow scram assures that an automatic loss of flow scram will occur in the event of a loss of flow when the reactor is operating at power levels above 0.1 MW.

The reactivity insertion rate limit was determined in the SAR,Section XI and predicts a safe fuel clad temperature.

When the reactor is operating, a stack monitor provides continuous gaseous and particulate measurement of the stack effluent with a read-out in the control room.

Its primary function is to warn operators of abnormal airborne releases from the facility. This LCO ensures that particulate and noble gas releases are continuously monitored during operation.

A radiation monitor located on the reactor bridge continuously monitors radiation levels directly above the reactor core. Its primary function is to warn operators of abnormal radiation levels directly above the pool. The monitor detects rising radiation levels caused by decreased pool water level, build-up of radioactivity within the pool water, incipient fuel failure, loss of delay for Nitrogen-16 decay, problems with in-core experiments and similar problems. Radiation monitors are located throughout the reactor facility to continuously monitor radiation levels.

Their primary function is to warn personnel of abnormal radiation levels at a particular location. The monitors detect possible failures in shielding leading to neutron and/or gamma streaming occupied areas. This LCO ensures that radiation levels above the pool and throughout the reactor building are continuously monitored during reactor operation.

Page 16 Amendment 29

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision 1 TABLE 3.2 Required Safety Related Instrumentation Minimum Reactor Number Operating Mode Instrumentation Setpoint Required Function In Which Recid.

I. Reactor Coolant < 111F I Alarm FCŽ0.IMW Inlet Temperature

2. Reactor Coolant < 119°F 1 Alarm FC 0.1MW Outlet Temperature
3. Log Count Rate < 3 cps 1 Rod with- Both Modes drawal interlock
4. Servo Control Ž 30 sec 1 Auto Control Both Modes Interlock (fullout) Interlock
5. Ln Period < 7 seconds I Alarm/rundown Both Modes
6. Building AirGaseous 2.5 x 1* Alarm Both Modes Exhaust (Stack) normal particulate 2 x normal
  • Grab sampling may be substituted for monitoring operations for up to eight hours in the event of monitor failure.

Page 19 Amendment 29

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I Review of the experiments using the appropriate LCO's and the Administrative Controls assures that the insertion of experiments will not negate the consideration implicit in the Safety Limits.

4.9 Reactor Core Components Applicability:

This specification applies to the surveillance requirements for reactor core components affecting reactor power.

a. Beryllium Reflectors Applicability:

This specification applies to the surveillance of beryllium lifetime for the standard and plug type beryllium reflectors.

Objective:

To prevent physical damage to the beryllium reflectors in the core from accumulated neutron flux exposure.

Specification:

The maximum accumulated neutron flux shall be lx1022 neutrons/cm 2 .

The exposure shall be determined annually in accordance with the operating procedures. Inspections and core fit shall be conducted on a rotating basis not to exceed five years.

Bases:

The RINSC SAR (Part A Section VIII) has addressed this limit as a conservative limit. (Annual inspections and core box fit as well as calculated total exposure serve as a method to monitor the beryllium lifetime.)

b. LEU Fuel Elements Applicability:

This specification applies to surveillance of LEU fuel elements.

Objective:

Page 38 Amendment 29

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I To prevent operation with damaged fuel elements and verify the physical condition of the fuel element.

Specification:

The fuel elements shall be visually examined and functionally fit into the core grid box on a rotating basis not to exceed five years.

Bases:

Fuel elements are initially inspected for manufactured specifications and then inserted into the grid box in accordance with QA/QC program requirements for functional fit. Core reloading is performed in accordance with operating procedures. Routine fuel movements are logged and visual inspections are conducted during fuel movements. Pool sampling also is used to detect a ruptured element (Tech. Spec. 4.3.3). The fission density limit for this reactor cannot be exceeded (reference SAR, Part A,Section VI). Burnup calculations are made quarterly (4.9.1).

Page 39 Amendment 29

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95 Revision I 6.0 ADMINISTRATIVE CONTROLS 6.1 Organization and Management

1. The Rhode Island Atomic Energy Commission (RIAEC) shall have the responsibility for the safe operation of the reactor. The organization of RIAEC is shown in Figure 6-1. The RIAEC shall appoint a Director and a Nuclear and Radiation Safety Committee (NRSC) consisting of a minimum of seven members, as follows:
a. The Director, RIAEC
b. The Assistant Director for Reactor Operations
c. The Radiation Safety Officer
d. A qualified representative from the faculty of Brown University
e. A qualified representative from the faculty of Providence College
f. Two qualified representatives from the faculty of the University of Rhode Island A qualified alternate may serve in lieu of one of the above. The Director, Assistant Director and Radiation Safety Officer are not eligible for chairmanship of the Committee.
2. An operator or senior operator licensed pursuant to 10CFR55 shall be present in the control room unless the reactor is shutdown as defined in these specifications. The minimum operating crew shall be two individuals.
3. A licensed senior operator shall be on duty or readily available on call whenever the reactor is in operation.

Page 42 Amendment 29