ML072840495

Request for Additional Information Regarding Amendment 17 of Operating License R-120 for the North Caroline State University Pulstar Reactor

ML072840495
Person / Time
Site:	North Carolina State University
Issue date:	10/23/2007
From:	Hughes D NRC/NRR/ADRA/DPR/PRTA
To:	Hawari A North Carolina State University
Hughes D, NRR/DPR/PRT, 301-415-1631
References
TAC MD4280
Download: ML072840495 (8)

Text

October 23, 2007 Dr. Ayman I. Hawari, Director Nuclear Reactor Program Department of Nuclear Engineering North Carolina State University Campus Box 7909 2500 Stinson Drive Raleigh, NC 27695-7909

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT 17 OF OPERATING LICENSE R-120 FOR THE NORTH CAROLINA STATE UNIVERSITY PULSTAR REACTOR (TAC NO.

MD4280)

Dear Dr. Hawari,

We are continuing our review of your application for amendment 17 of operating license No. R-120 for the North Carolina State University PULSTAR Reactor submitted by letter dated February 6, 2007. During our review questions have arisen for which we require additional information and clarification. Please provide a response to the enclosed request for additional information within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. If you have any questions regarding this request, please contact me at (301)-415-1631.

Sincerely,

/RA/

Daniel E. Hughes, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-297

Enclosure:

As stated cc: Please see next page

October 23, 2007 Dr. Ayman I. Hawari, Director Nuclear Reactor Program Department of Nuclear Engineering North Carolina State University Campus Box 7909 2500 Stinson Drive Raleigh, NC 27695-7909

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT 17 OF OPERATING LICENSE R-120 FOR THE NORTH CAROLINA STATE UNIVERSITY PULSTAR REACTOR (TAC NO. MD4280)

Dear Dr. Hawari,

We are continuing our review of your application for amendment 17 of operating license No. R-120 for the North Carolina State University PULSTAR Reactor submitted by letter dated February 6, 2007. During our review questions have arisen for which we require additional information and clarification. Please provide a response to the enclosed request for additional information within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. If you have any questions regarding this request, please contact me at (301)-415-1631.

Sincerely,

/RA/

Daniel E. Hughes, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-297

Enclosure:

As stated cc: Please see next page DISTRIBUTION:

PUBLIC DPR/PRT r/f RidsNrrDprPrta RidsNrrDprPrtb GHill (2) RidsNrrDpr ADAMS ACCESSION NO: ML072840495 TEMPLATE #: NRR-088 OFFICE PRTA:PM PRTA:LA PRTA:BC PRTA:PM NAME DHughes deh CHart for EHylton DCollins dsc DHughes deh DATE 10/17/07 10/19/07 10/22/07 10/23/07 OFFICIAL RECORD COPY

North Carolina State University Docket 50-297 cc:

Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Dr. Mohamed Bourham, Head Nuclear Engineering Department North Carolina State University P.O. Box 7909 Raleigh, NC 27695-7909 Beverly Hall, Section Chief Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 3825 Barrett Drive Raleigh, NC 27609-7221 Dr. Louis Martin-Vega Dean of Engineering North Carolina State University P.O. Box 7909 Raleigh, NC 27695-7909 Gerald Wicks North Carolina State University Department of Nuclear Engineering Campus Box 7909 2500 Stinson Dr.

Raleigh, NC 27695 Andrew T. Cook Manager of Engineering and Operations Nuclear Reactor Program Department of Nuclear Engineering North Carolina State University Campus Box 7909 2500 Stinson Drive Raleigh, NC 27695-7909 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

REQUEST FOR ADDITIONAL INFORMATION NORTH CAROLINA STATE UNIVERSITY PULSTAR REACTOR DOCKET NO. 50-297

1. The ventilation exhaust flow rate with the new ventilation system is given as 1870 cfm.

a) Attachment B-1 shows a flow of 270 cfm into the exhaust plenum from an unidentified source. Is this source external to the reactor bay? If so, how are the fuel failure event durations, as calculated on page 49 of Appendix B, affected by the decreased reactor bay exhaust flow rate, and how does this affect off-site doses and AEC fractions? How are occupational accident doses affected by a longer reactor bay air exchange time?

b) Attachment B-1 shows a flow of 200 cfm into the exhaust plenum from the BT&TC exhaust fan. Is this fan required to be running during accident scenarios? If not, how are the fuel failure event durations, as calculated on page 49 of Appendix B, affected by the decreased reactor bay exhaust flow rate, and how does this affect off-site doses and AEC fractions?

How are occupational accident doses affected by a longer reactor bay air exchange time?

2. The worse case, 24-hour average Ar-41 concentration in the reactor bay is given as 2.7E-5 Ci/ml on page 44 of Appendix B. This gives an AEC fraction of 2700. Section 5.1 of Revision 8 of the Emergency Plan gives an AEC fraction of 2500 as the Action Level for Notification of Unusual Events for noble gas releases. Section 5.0 of the descriptions of the changes to the Emergency Plan states, from Appendix B, it can be concluded that airborne effluent from an experimental failure and postulated fuel failure continue to remain below the Notification of Unusual Event classification EAL. Please justify the inconsistency of this statement.

3. The analysis in Appendix B treats noble gases differently from other radionuclides. AEC values given in 10 CFR 20, Appendix B are equivalent to the concentration of a specific nuclide that would result in an annual total effective dose equivalent of 0.05 rem, and ANSI/ANS-15.16 and NUREG-0849 do not differentiate between noble gasses and all other radionuclides. Please justify treating these categories of nuclides differently.

4. Revision 7 of the Emergency Plan cited a worse case Ar-41 concentration in the reactor bay of 2.0E-4 Ci/ml. Please explain the reason for the significant decrease in the worse case Ar-41 concentration cited in Revision 8 (2.7E-5 Ci/ml). Please explain the basis for the PN tube volume length of 61 cm.

5. Calculations of the worse case Ar-41 concentrations on page 44 of Appendix B use a value of 2.25E9 ml for the volume of the reactor building, while calculations of event durations on page 49 of Appendix B use a value of 2.4E9 ml for the volume of the reactor building. Please justify the use of the two different values, or make the value consistent throughout the analysis.

6. Specification 1.2.9.a, Tried Experiment Your justification says this was changed to make it consistent with ANSI/ANS-15.1-1990, however this definition is not in that standard. Please explain.

7. Specifications 1.2.19 and 1.2.27 In these two definitions for Reactor Operator and Senior Reactor Operator the reference, 10 CFR 50.55, is wrong. Please correct.

8. Figure 2.2-1, Power-Flow Safety Limit Curve In the proposed TS this figure does not show the Operating Envelope as the same figure did in the previous version of TS. Also, in the proposed version of the figure the labeling does not specify the Safety Limit Specifications that the pool level shall be 14 feet or greater and the pool temperature shall not be greater than 120 °F. Since Specification 2.2.1.a. references the operating envelop in the figure the fact that it is missing may cause confusion. In addition, the title for the figure contains a typo with the word "full" rather than "flow."

Please clarify your intentions with regard to the labeling on this figure.

9. Specification 3.2.f Apparently the version of the SAR, as supplemented, that was part of the license renewal application used 2900 pcm since NUREG 1572, "Safety Evaluation Report related to the renewal of the operating license for the research reactor at North Carolina State University," refers to this value in section 13.9. To what version of your SAR are you referring in the justification of this change?

10. Specification 3.3-1 g Provide discussion and assurance that the risk to the health and safety of the public will not significantly increase with the removal of the Manual SCRAM from the Specification for the Pool Water Temperature Monitoring Switch.

11. Specification 3.3.l Provide discussion and assurance that the risk to the health and safety of the public will not significantly increase with the removal of the Manual SCRAM from the Specification for the Over-the-Pool Radiation Monitor.

12. Specification 3.7.e(iii)

Justify that this change will not reduce the oversight of experiments involving the use of explosive materials.

13. Specification 3.7.e(v)

The change in the wording of specification is not included in TS change analysis and justification. Provide justification for the change. In particular, justify how this change does not reduce the oversight of experiments involving the use of cryogenic, flammable, or toxic materials.

14. Specification 3.8 You have stated that the changes being requested are consistent with the definition of fueled experiments given in TS 1.2.9.e, i.e. any fissionable material, and therefore do not limit the type of fuel used assuming it is allowed by the R-120 license.

The definition is not a specification in the sense that it places or doesnt place limits on an action or actions. The specification on fueled experiments is TS 3.8.

The TSs and the regulations are the requirements placed on experiments. The basis is not part of the TSs, however, the analyses in the SAR, from which the TSs are derived, provide the benchmark against which the 10 CFR 50.59(c)(2) criteria are assessed.

You have stated that using the MHA consequences (maximum off-site dose given in the FSAR for the fuel handling accident is well below 1 mrem) is very restrictive when compared to 10 CFR Part 20 limits.

However, without a less restrictive analysis in the SAR the MHA methodology and consequences are what must be used as the criteria in doing a 10 CFR 50.56 review. Stating that credible failures of fueled experiments are not allowed to exceed 10 CFR 20 limits in the TS does not release you from doing the 10 CFR 50.59 review.

You have also stated that credible failures of fueled experiments depend on many factors and each case needs to be analyzed, e.g. in-pool irradiation vs.

out-of-pool irradiation, fuel chemical formulation, fuel enrichment, type of encapsulation used and other barriers to the escape of fission products (coatings, fuel shape and size, cladding, gap inventory, fraction of equilibrium).

However, 10 CFR 50.36(b) states that the TSs are derived from the analyses and evaluations made in the SAR. A TS that uses the term credible failure must be derived from a specific experiment and analysis in the SAR. The staff cannot make a determination of the acceptability of the credibility of an experiment failure without evaluating a fully described experiment and its detailed analysis in the SAR.

15. Specification 6.1.1 The advice and liaison lines have been removed with the proposed Figure 6.1-1.

Provide discussion of the changes in the organizational structure. Include changes in responsibility, authority, and lines of communications, e.g. what are the interface inter relationships between the Reactor Health Physicist, the Nuclear reactor Program personnel, the Reactor Safety Committee, and the Reactor Safety and Audit Committee. Discuss the change from the Reactor Safety Committee reporting to the Reactor Safety and Audit Committee which in turn reports to the Chancellor and the proposed structure where they both report to the Chancellor independently. Discuss how the proposed changes will affect safety, independence, and oversight.

16. Specification 6.1.3.a Verify that the reference is 10 CFR 55 rather than10 CFR 50.55.

17. Specification 6.2 One change to Figure 6.1-1 is that it now shows the RSAC no longer reports to the RSC. This is reinforced by the removal of the statement that the RSC performs final review of the actions of the RSAC. Discuss the reason for that change and the safety implication.

18. Specification 6.2.1 a Is there still a requirement for a permanent member on the RSC from the Radiation Safety Division of the Environmental Health and Safety Center?

Discuss the reason for the changes and the safety implications of them.

19. Specification 6.2.1 b The NRP Director is listed as being a faculty member. The minimum qualifications that are listed in TS 6.1.1 do not specify that the position is a faculty position. Clarify your intention?

20. Specification 6.2.2 a The term "University Management" is not defined. Figure 6.1-1 shows the committees reporting to the Chancellor. The existing TSs state that the office of the Vice Chancellor for Finance and Business and the Provost. Considering TS 6.1.2, which specifies how responsibility may be delegated, clarify the proposed change, discuss the purpose of the change, and justify it.

21. Specification 6.2.2 It is not clear from the proposed TS that there is a requirement to have an established charter for the RSC and RSAC as recommended in the ANSI/ANS-15.1-1990 guidance. What is the purpose of TS 6.2.2? Please discuss.

22. Specification 6.2.2 b TS 6.2 states that the RSC is informed of the actions of the RSAC and may require additional actions by RSAC and the NRP. With the meeting schedule dictated by the State broad scope license (TS 6.2.2.b) and the possibility of mismatched meeting schedules how is it ensured that the RSC is informed and responds in a timely manner to the actions of the RSAC?

23. Specification 6.2.3 There is no statement in TS 6.2.3 that the Manager of Engineering and Operations shall receive a summary of RSAC meeting minutes as mentioned in your justification. Is that still your intention?

24. Specification 6.2.3 The requirement in TS 6.2.3 of the existing TSs is that: "Recommendations of the annual audit made by RSAC are forwarded to the RSC for concurrence before being implemented." That requirement no longer appears in the proposed TS 6.2.4. Justify its removal.

25. Specification 6.2.3 a The regulation 10 CFR 50.59 applies to: changes in the facility as described in the final safety analysis report (as updated), changes in the procedures as described in the final safety analysis report (as updated), tests or experiments not described in the final safety analysis report (as updated). It is not clear that the RSC will perform or review the results of all of those 10 CFR 50.59 reviews that involve production and release of radioactive material, and radiation protection. Please clarify the scope of their responsibility. Does the committee also review changes to the Emergency Plan? Who makes the determination as

to what is reviewed by the RSC, RSAC, or both when it is not explicitly stated in the TS and or charter? Discuss the interrelationships of the facility, the RSC, and the RSAC.

26 Specification 6.2.3.a The existing TS 6.2.3 lists the items that "shall be reviewed and approved by the RSC or by referral to the RSAC, as needed:.." This implies a dominate role for the RSC as shown and stated more explicitly in the existing Figure 6.1-1 and TS 6.2.1 and TS 6.2.4. Discuss how the interaction of the two committees will change if the TSs are approved as proposed. Discuss how it is assured that safety and oversight will not be diminished.

27. Specification 6.2.3.b The meaning of the proposed TS 6.2.3.b.i is not clear as written. Please reword as desired to clarify its meaning and scope.

28. Specification 6.2.3.b In the wording of the proposed TS 6.2.3 and TS 6.2.3.b in particular, there appears to be a screening or triage process where changes, new procedures, new experiments, "major" revisions are determined to have safety significance or not, affect reactivity or not, release radioactivity or not, and go to the RSC, RSAC, or both or neither. Describe this process and what oversight is there on this process?

29. Specification 6.2.4 In your proposed TS 6.2.4 the audit responsibility is to be changed from the RSC to the RSAC. Discuss this change and how it is assured that safety and oversight will not be diminished. Also see questions under TS 6.2.1, TS 6.2.3, and TS 6.2.3.a concerning the responsibilities of the two committees.

30. Specification 6.2.4 The proposed specification states that a "summary" of the audit made by the RSAC will be forwarded to the RSC and not the audit report as stated in the justification section of your application. Is there a difference between the report and the summary of the audit? How is it assured that the RSC has prompt and full review of the audit and all other actions of the RSAC?

31. Specification 6.2.4.c In TS 6.2.4.c there is a missing the word, "of" after the word "methods."

32. Specification 6.7 The proposed TS 6.7, as submitted, does not contain the change in the submission time for the annual operating report as you have stated in the justification section of the your application. Clarify your intention.

33. Specification 6.8.3 Operator licenses are on a 6 year cycle and the training cycle is 2 years. This specification is not clear. Please clarify by suggesting a restatement of the TS.