ML080650352
| ML080650352 | |
| Person / Time | |
|---|---|
| Site: | Ohio State University |
| Issue date: | 02/29/2008 |
| From: | Blue T Ohio State University |
| To: | Hughes D NRC/NRR/ADRO/DPR |
| References | |
| TAC MA7724 | |
| Download: ML080650352 (64) | |
Text
T -H E 1298 Kinnear Road EO1~HIR~i ~ The Ohio SColumbus, OH 43212 oState;University Phone 614-688-8220 S-* -[I UNIVERSITY' Nuclear Reactor Laboratory Fax 614-292-2209 29-Feb-2008 Daniel E. Hughes, Project Manager Research and Test Reactors Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation RE: REQUEST FOR ADDITIONAL INFORMATION REGARDING THE OHIO STATE UNIVERSITY RESEARCH REACTOR (OSURR) APPLICATION FOR RE-LICENSING (TAC NO. MA7724)
Mr. Hughes, Please find enclosed our response to your letters dated 21-Aug-2007 and 31-Oct-2007 requesting additional information to supplement the OSURR re-licensing application. In addition, this response letter and its attachments include additional information that corrects some errata in our prior mailings.
If you have any questions, please contact Andrew Kauffman at 614-688-8220 or kauffman.9@osu.edu.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 29-Feb-2008.
Sincerely, Thomas E. Blue, Director OSU Nuclear Reactor Lab The Ohio State University (License R-75, Docket 50-150)
- c. W.A. "Bud" Baeslack Ill, Dean, College of Engineering Andrew C. Kauffman, Associate Director, OSU Nuclear Reactor Lab Aoz
REQUESTED ADDITIONAL INFORMATION REGARDING THE OHIO STATE UNIVERSITY RESEARCH REACTOR (OSURR) - DOCKET NO. 50-150 This document is the main body of our responses to the Requests for Additional Information (RAI) from the Nuclear Regulatory Commission dated 21-Aug-2007 and 31-Oct-2007. In this document and its attachments, we have attempted to address the clarifications asked for in the requesting documents. In addition, we have included additional information that corrects some errata in our prior mailings. The corrections will be discussed in further detail below.
For organizational purposes, the responses are broken down by RAI. RAI questions are shown below in bold italics, and the responses are shown in plain text Responses to the 21 -Aug-2007 RAI Note: Question 2 of this RAI has been superceded by Question 2 of the 31-Oct-2007 RAI, so no answer is given below for this question.
- 1. The applicationdescribes the method/assumptions used to update the 1990 cost estimate to decommission the reactor,with the current cost estimatedat about $3.5 million. In accordancewith 10 CFR 50.75(d), please provide a description of the means of adjusting the cost estimate and associatedfunding level periodicallyover the life of the facility.
The cost estimate for decommissioning given in our RAI response letter dated 26-July-2006 was comprised of four components:
- Labor
- Waste disposal
- Other
- Contingency Labor costs were estimated by multiplying our current staff rate by the estimated number of hours to decommission. For updated estimates, the staff rate would be updated in this calculation to reflect the current rate at that time.
The cost for radioactive waste disposal was estimated by multiplying the estimated volume of waste by the volumetric rate cost. According to the Radiation Safety Section of the OSU Office of Environmental Health and Safety, the primary broker for radioactive waste disposal is Bionomics. This is from whom a price rate quote was obtained for use in the decommissioning cost estimate given in our letter dated 26-July-2006. To adjust the cost estimate, an updated disposal price rate quote would be obtained from OSU's waste broker at that time and used in the calculation. As Bionomics has filled this role for many years for OSU, they will likely still be the waste broker. Currently, waste from The Ohio State University goes to Energy Solutions.
The estimated costs for "Other" was based on the assumption that labor and waste-disposal costs would comprise 90% of the total cost. Therefore, the estimate for the remaining 10% will be updated based on the increased cost estimates for labor and waste disposal.
In the initial cost estimate for disposal given in the 26-July-2006 letter, contingency costs were added to the estimate, based on the decommissioning experience of the University of Virginia. This contingency added a 60% of the cost of Labor + Waste Disposal + Other to the total. To adjust the cost estimate, this contingency would be increased according to increasing the other costs (i.e. the new Contingency component of the estimate would be 60% of the new total of Labor + Waste Disposal + Other).
Responses to the 31 -Oct-2007 RAI
- 1. Under 10 CRF 50.33(d), certaininformation is requiredby an applicant,as applicable. To complete the requirements in 10 CFR 50.33(d), please state the organizationalform of the Ohio State University and provide the information that is applicable to Ohio State University. If none of the provisions of 10 CRF 50.33(d) are applicable,please so state.
The Ohio State University (OSU) is not a corporation, but rather an instrumentality of the state of Ohio. See, Ohio Revised Code Chapter 3345.11 (Creating "State University" entities and specifically naming OSU); Thomas v. Bd. Of Trustees of the Ohio State University (1904), 195 U.S. 207, 215-16, 25 S. CT. 24, 49 L.Ed. 160 ("the supreme court of Ohio has adjudged that the defendant board [of trustees] is not, and was not intended to be made, a corporation of the state, but only an agency to manage and control a state institution as the state may direct or provide."); Bailey v. The Ohio State University (S.D. Ohio 1980), 487 F. Supp. 601, 606 (citing Ottinger v. Riggs, Civil Action No. 79-262-A at 6 (E.D. Va. 1979) ("Ohio State is the alter ego of the State of Ohio for eleventh amendment purposes."); Neil v. The Bd. of Trustees of the Ohio Agricultural & Mechanical College (1876), 31 Ohio St. 15, 21 ([the Act that created the University] "does not assume to, nor does it in fact, create or constitute such board of trustees a corporation; and hence does not clothe it with corporate functions or powers."); Thacker v. Bd. of Trustees of the Ohio State University (1973), 35 Ohio St.2nd 49, paragraph 2 of the syllabus, 298 N.E.2d 542 ("The Ohio State University and the Ohio State University Hospitals are instrumentalities of the state of Ohio and as such are not suable in tort. . . ."); Agora Columbus, Inc. v. The Ohio State University (Mar. 4, 1976), Franklyn App. No. 75AP-467, 1976 WL 189433, *2, unreported ("the Supreme Court has characterized the Ohio State University as an instrumentality of the state of Ohio."). As instrumentality of the state, none of the provisions of 10 CFR 50.33(d) would be applicable, as OSU is not an "individual," "corporation," or other entity as noted in the section.
- 2. (This RAI replaces item 2 of the NRC RAI issued August 21, 2007.) The applicationincludes a statement of intent as the method to provide decommissioning funding assurance,as provided for by 10 CFR 50.75(e)(1)(iv).
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Where the applicantintends to use a statement of intent as the method to provide decommissioning funding assurance,the staff must find that the applicant"...is a Federal,State, or local government licensee..." under 50.75(e)(1)(iv). To make this finding, the applicantmust state that it is a State government organizationand that the decommissioning funding obligationsof the applicantare backed by the State government, and also provide corroboratingdocumentation. Further,the applicantmust provide documentation verifying that the signatorof the statement of intent is authorizedto execute such a document that binds the applicant financially. This documentationmay be a governing body resolution, management directives, or other form that provides an equivalent level of assurance.
Because the applicationdoes not include all of the above information, please submit the following:
(a) State whether the applicantis a State of Ohio government licensee under 10 CFR 50.75(e)(1)(iv), and provide documentation that corroboratesthat statement.
As an instrumentality of the state of Ohio, the Ohio State University is a state government licensee under section 10 CFR 50.75(e) (1) (IV). (See response to #1 above.)
(b) State whether the decommissioning funding obligationsfor the Ohio State University Research Reactor (OSURR) are backed by the State of Ohio government. Provide documentation that corroboratesthat statement. For example, provide a copy of or complete citation to a state statute that expressly provides that the obligations, or at least the decommissioning funding obligations, of the Ohio State University are obligationsbacked or supportedby the full faith and credit of the State of Ohio, or provide an opinion of the General Counsel of the Ohio State University with citations to statutes, regulations,and/or case law that the obligations,or at least the decommissioning funding obligations, of the Ohio State University are obligationsbacked or supportedby the full faith and credit of the State of Ohio.
The Board of Trustees of OSU, and their designees, have been empowered by the State of Ohio to administer funds, contract, adopt rules, supervise, invest, and control funds, and oversee the property and operation of the University. See, Ohio Revised Code Chapters 3335.03 (granting the Board of Trustees of Ohio State University the right to ". . . contract and be contracted with .... "); 3335.08 (granting the Board of Trustees the power to "adopt bylaws, rules, and regulations. . . ."); 3335.10 (granting the Board of Trustees ". . . general supervision of all lands, buildings, or other property belonging to the university, and the control of all expenses therefore . . . ."); and, 3345.05 (all "fees, deposits, charges, receipts, income and revenue ... ." shall be "held and administered", by the Board of Trustees.) While not specifically delineating' decommissioning funding, such funding relating to the property of the university in the form of Ohio State University Research Reactor (OSURR) would clearly be part of the 3
broad powers granted by the state to the Board of Trustees as noted in the Ohio Revised Code.
(c) Provide documentation verifying that the signatorof the statement of intent is authorizedto execute such a document that binds the applicantfinancially. For example, provide a copy of a university governing board or equivalent resolution that shows that the signatorof the statement of intent has been authorizedby the Ohio State University to bind the Ohio State University financially,at least with respect to funding the decommissioning of the OSURR, or provide a copy of an official Ohio State University delegation of authority showing the signatorof the statement of intent is authorized to bind the Ohio State University financially, at least with respect to funding the decommissioning of the OSURR.
Section 3335-1-03(F) notes that the Executive Vice President and Provost is the "chief operating officer of the university who has the responsibility and requisite authority for a number of tasks and function including the authority ". . . develop and administer the university budget. ... ." Section 3335-1-03(G) notes that the Senior Vice President for Business and Finance and Chief Financial Officer has the responsibility and authority for "administration of the university finances, including planning and resource allocation
... ." (Bylaws section included as Attachment A).
10 CFR 50.75(e) (1) (IV)notes that the method of "Financial Assurance "of decommissioning funds is to be provided, "for a non-power reactor licensee that is a Federal, State, or local government licensee, [by] a statement of intent containing a cost estimate for decommissioning, and indicating that decommissioning funds will be obtained when necessary." The provisions of 10 CFR 50.75(e) (1) (iv) are applicable as the OSURR is a non-power reactor and OSU as an instrumentality of the State of Ohio is a State licensee. The OSURR staff presented the NRC With financial information dated July 26, 2006 indicating the decommissioning costs were estimated at approximately $3.4 million. The OSU Executive Vice President and Provost and Senior Vice President for Business and Finance presented the NRC with a fully executed statement of intent letter dated May 14, 2007 indicating the Provost was the responsible University official with the Authority to commit to spending the necessary funds to accomplish decommissioning when necessary.
- 3. In accordancewith 10 CFR 50.21(c), a class 104 license will be issued for a production or utilization facility which is useful in the conduct of researchand development activities of the types specified in section 31 of the Atomic Energy Act of 1954, as amended, and which is not a facility of the type specified in 10 CFR 50.21(b) or 10 CFR 50.22. The NRC understands that the OSURR is not a facility of the type specified in 10 CFR 50.21(b). In order to satisfy the requirements of 10 CFR 50.21(c), provide a statement that the OSURR is not a facility of the type specified in 10 CFR 50.22. Specifically, provide a statement that no more than 50 percent of the annualcost of owning and operating the OSURR is devoted to the production of materials or products for sale or 4
commercial distribution,or to the sale of services, other than researchand development or education or training.
No more than 50 percent of the annual cost of owning and operating the OSURR is devoted to the production of materials or products for sale or commercial distribution, or to the sale of services, other than research and development or education or training.
Corrections and Changes Below is some additional information that has been included to provide corrections for some information in our prior mailings.
1 ) A table has been included in this document as Attachment B to serve as a replacement for the table labeled Integral Whole-Body Gamma Doses From Direct (From the Building) Dose At the Controlled-AreaBoundaryAssuming a Leakage Fractionof 0.0042 Hr-1 (Purge Fan Off) in our RAI response letter dated 28-Sep-2007. This replacement table corrects a units error that was present in the prior mailing. The replacement table correctly lists dose rate units as mRem instead of Rem.
- 2) In Section 3.2.2, Maximum Reactivity Insertion Rate, of the TSs submitted with the 04-Sep-2007 response letter, the Basis given for this TS relied on operator intervention. To eliminate this, a new analysis is included in this letter as Attachment C. As seen in the attachment, a new section is proposed for addition to the SAR to which the revised TS Basis can reference. The revised Basis is also shown.
- 3) An updated version of the Technical Specifications (TSs) that was submitted as Attachment C with our RAI response letter dated 04-Sep-2007 has been included as Attachment D of this letter to correct the following:
a) In the 04-Sep-2007 submittal, the text "Attachment C" was shown in the upper left hand of the title page of the TSs. As this is not to be part of the official TSs, this text has been removed from the title page.
b) An entry for Section 5.5 was missing from the Table of Contents. This has been corrected.
c) The definition for "Safety Limits" was updated in the 04-Sep-2007 submittal of the TSs to make it consistent with the guidance given in ANSI/ANS-15.1-1990. Part of the definition given in the guidance document for this term is, "The principle physical barrier is often the fuel cladding." This statement was mirrored verbatim in our submitted TSs, but instead should state, "The principle physical barrier is the fuel cladding" to be specific to our reactor. This has been corrected.
d) The revised TSs Section 3.2.2 Basis shown in Attachment C'of this letter has replaced the old TSs Section 3.2.2 Basis.
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Attachment A: Board of Trustees Bylaws Section 3335-1-03 6
3335-1-03 Administration of the university.
(A) The office of the president.
(1) The office of the president shall consist of:
(a) The president, (b) Chief of staff, and (c) 'Special assistants to the president.
(2) The office of the president shall include such additional officers as the president, in consultation with the board, may from time to time appoint.
(B) The president.
(1) The president shall be the chief executive officer of the Ohio state university and shall be responsible for the entire administration of the university, subject to control of the
.board of trustees and excepting therefrom those functions reserved exclusively to the board treasurer and trustees in paragraph (H)(2) of rule 3335-1-02 of the Administrative Code. The president shall lead in fostering and promoting education and research as the primary aims of the university. It shall be the duty of the president to enforce the bylaws, rules and regulations of the board of trustees, and, as a member of the faculty, to interpret to the board proposals and actions of the faculty. The president is hereby clothed with the authority requisite to that end.1 (2) Any authority or responsibility of the president may be delegated by the president to another person in the office of the president or to any other member of the faculty or staff of the university. Delegation of major areas of authority or responsibility shall have the prior consent of the board of trustees.
(3) The president shall be a voting member of all college faculties, of the graduate school faculty, and of the faculty of the arts and sciences, and shall be a voting member and presiding officer of the university faculty and of the university Senate. The president shall appoint all committees of the university faculty and of the university senate, unless membership has been designated by rule.
(4) After consultation with the steering committee of the university senate, the president may recommend to the board of trustees candidates for honorary degrees. The number of candidates so recommended shall be limited to eight per calendar year.
This right and its limitation in no way abrogates the power of the university senate to recommend candidates for honorary degrees (rule 3335-5-41 of the Administrative Code).
(C) The president; duty to present matters to the board. All major appointments and all major questions of university policy, including the annual budget, to be recommended by the president shall be presented (either completely or in summary form) by the president to each member of the board prior to the meeting at which the matter is to be considered by the board.
(D) The president; relation to faculty and staff. All members of the faculty shall be responsible to the chair of their department or to the director of their school and through the chair or director to the dean and the president for the faithful and efficient performance of their duties. Every other member of the university staff shall be so responsible to his or her division head and through the division head (and When applicable) to his or her director and dean, and then to the president.
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(E) The president's planning cabinet.
(1) The president's planning cabinet shall consist of the president, the executive vice president and provost, the senior vice president for business and finance and chief financial officer, the vice president for student affairs, the vice president for business and finance, the senior vice president for health sciences, the vice president for agricultural administration and university outreach, and executive dean for food, agricultural, and environmental sciences, the vice president for development and president of the university foundation, the senior vice president for research, the senior vice president for university relations, the vice president for legal affairs and general counsel, the vice president for health services, the vice provost for minority affairs, the associate vice president for human resources, executive dean of the colleges of the arts and sciences, executive dean for the professional colleges, executive dean for the regional campuses, secretary of the university senate, chief information officer, director of athletics, the chief of staff, and the secretary of the board.
(2) Each member of the president's planning cabinet shall have a major area of responsibility as assigned by the president, in consultation with the board of trustees.
He or she shall be the executive head of that area and, subject to the control of the president, shall exercise authority within and be responsible for theadministration of that area and such other responsibilities as may be assigned to him or her by the president from time to time. Unless otherwise specified, all assigned responsibilities shall be on a university-wide basis, including the regional campuses of the university.
(3) Within each planning cabinet member's office there shall be such principal administrative officials as are approved by the president.
(4) Each member of the president's planning cabinet shall keep appropriate records regarding the administration of his or her area, and such records shall be available to the president upon request.
(F) Executive vice president and provost. The major area of responsibility and authority of the executive vice president and provost shall be that of the instructional and faculty affairs of the university, and the chief operating officer of the university. Without limiting the generality of the foregoing, the executive vice president and provost shall, under the direction of the president and with the approval of the board of trustees, be responsible and have the requisite authority for: providing coordinated leadership for the development and evaluation of curricular patterns and teaching methods; the selection, promotion, professional development, tenure and salary of instructional staff; in partnership with the senior vice president for business and finance, develop and administer the university budget; development and administration of human resources programs and services for faculty and staff; through the office for the coordination of minority affairs and in*
cooperation with the other existing agencies of the university, the development and maintenance of supplemental 'programs for the recruitment, orientation, counseling, tutoring, and financial assistance for minority students and the search for necessary funds to support these programs; through the constituent academic divisions, the appraisal of the effectiveness of academic counseling and devising the organization and procedures to improve its effectiveness; the development and administration of policies and operating procedures for enrollment services including admissions, registration, records, and scheduling; student financial aids and scholarships; the development of the services of the university libraries and other learning resources; the development of instructional programs of the departments of air force aerospace studies, military science and naval science; the development of the four regional campuses; oversight of the office of the chief information officer and university systems; and as a deputy of the president of the university, the coordination of all matters administratively assigned to the other vice presidents of the university which relate to the academic program of the university.
(G) Senior vice president for business and finance and chief financial officer. The major area of responsibility and authority of the senior vice president for business and finance and chief financial officer shall be that of the administration of university finances, including 11-6
planning and resource allocation, and oversight of the university's administrative and business operations. Without limiting the generality of the foregoing, the senior vice president for business and finance and chief financial officer shall, under the direction of the president and with the approval of the board of trustees, be responsible and have the requisite authority for: policy formulation and direction for the university treasurer functions, excepting therefrom those functions reserved exclusively to the board treasurer and trustees in paragraph (H)(2) of rule 3335-1-02 of the Administrative Code; formulation, review and monitoring of capital and current funds budgets; managing university debt instruments, investments and cash flow; policy formulation and direction for financial accounting and management; monitoring the state budget process and its impact on the university; indirect cost analysis and recovery; strategic analysis; enrollment projections and long-range financial planning to support the academic mission and goals of the university; oversight of the office of the vice president for business and finance; and internal audit. The senior vice president for business and finance and chief financial officer shall report to the president and, as appropriate, shall- consult with the executive vice president and provost.
(H) Vice president for student affairs. The major area of responsibility and authority of the vice president for student affairs shall be that of the administration of the student services of the university. Without limiting the generality of the foregoing, the vice president for student affairs shall, under the direction of the president and with the approval of the board of trustees, be responsible for: the promulgation of rules governing student conduct both on and off campus; the coordination of student extracurricular activities including all student (or student-connected) organizations; the administration of all residence and dining hall facilities, including the operation of the Fawcett center for tomorrow; nonacademic student discipline; the student health service; student union facilities and programs; student recreation and intramural programs; counseling; office for disability services; student personnel assistant program; off-campus student housing; and international student programs. The vice president for student affairs shall report to the president, and, as appropriate, shall consult with the executive vice president and provost.
(I) Vice president for business and finance. The major area of responsibility and authority of the vice president for business and finance shall be that of the administration of university business, administrative, and financial operations. Without limiting the generality of the foregoing, the vice president for business and, finance shall, under the direction of the senior vice president for business and finance and chief financial officer, and with the approval of the board of trustees, be responsible and have the requisite authority for:
administrative operations and coordination of the university controller, resource planning and institutional analysis, and the university treasurer, excepting therefrom those functions reserved exclusively to the board treasurer and trustees in paragraph (H)(2) of rule 3335 02 of the Administrative Code; management improvement and quality programs; business operations; facility planning and development; allocation, utilization, and maintenance of the physical facilities; the function of the university architect and physical planning for the university; real estate and property management services; university trademark and licensing programs; university public safety; university-wide environmental health and safety; and coordination of all matters administratively assigned to the other vice presidents which relate to the business and administrative areas of the university.
(J) Senior vice president for health sciences. The major area of responsibility and authority of the senior vice president for health sciences shall be the academic medical center of the university. The academic medical center includes the college of medicine; the Prior health sciences library; centers designated by the provost to be part of the academic medical center; and all hospitals, health services, and health care delivery enterprises owned and/or operated wholly or in part by the university exclusive of:
(1) Those clinics operated by other colleges; and (2) The departmental practice plan corporations.
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Without limiting the generality of the foregoing, the senior vice president for health sciences shall, under the direction of the president and provost and with the approval of the board of trustees, have responsibility for advancing the academic mission of teaching, research, and service and have authority over, the academic medical center; and shall be responsible for agreements and cooperative arrangements between the academic medical center and non-university health care providers. The senior vice president for health sciences shall report to the president regarding all administrative and fiscal matters, and to the executive vice president and provost regarding all academic matters.
(K) Vice president for agricultural administration and university outreach, and executive dean for food, agricultural, and environmental sciences. The major area of responsibility and authority of the vice president with respect to agricultural administration and as executive dean for food, agricultural, and environmental sciences shall be that of serving as dean of the college of food, agricultural, and environmental sciences, including the school of environment and natural resources and the agricultural technical institute, and the administrative responsibility for the Ohio agricultural research and development center, and the Ohio state university extension, Stone laboratories, and the Ohio sea grant college program. Without limiting the generality of the foregoing, the vice president shall, under the direction of the president a/nd with the approval of the board of trustees, be responsible and have the requisite authority for: the administrative details and authorization ,for all expenditures of agricultural administration which shall be in accordance with policies and procedures of the Ohio state university. As vice president for university outreach, the vice president provides leadership, vision and coordination for institutional outreach and engagement programs and relationships between and among Ohio state faculty, staff and students and external partners, communities and institutions in furtherance of the university's land-grant mission. The vice president for agricultural administration and university outreach, and executive dean for food, agricultural, and environmental sciences shall report to the president of the university for all administrative and fiscal affairs and to the executive vice president and provost on all academic matters.
(L) Vice president for development and president of the university foundation. The major area of responsibility and authority of the vice president for development and president of the university foundation shall be the administration of the development activities of the university and serving as president of the university foundation. Without limiting the generality of the foregoing, the vice president for development and president of the university foundation shall, under the direction of the president and with the approval of the board of trustees, be responsible and have the requisite authority for:
(1) As vice president for development, the management and direction of fund raising, including individual, corporate and foundation giving; formulating policy recommendations; overseeing a university-wide review system for all fund raising projects and coordinating fund raising goals with the academic planning process; and (2) As president of the university foundation, for the proper management and coordination of the activities of the foundation, and assisting the board of directors in developing long-range fund raising activities, as well as other related functions which serve to enhance the university.
The vice president for development and president of the university foundation shall report to the president, and, as appropriate, shall consult with the executive vice president and provost.
(M) Senior vice president for research. The major area of responsibility and authority of the senior vice president for research shall be that of encouraging, stimulating, and coordinating the research programs of the university. Without limiting the generality of the foregoing, the senior vice president for research shall, under the direction of the president and with the approval of the board of trustees, be responsible and have the requisite authority for: developing broad policies and operating procedures for the research activities of the university; stimulating research developments and assisting in the evaluation of the total research program of the university; providing advice and. assistance to college 11-8
research administrators in the development of research programs within the colleges; supplying coordinated leadership in securing governmental, industrial, and individual support for the research programs of the university; developing-the interdepartmental and inter-college cooperative arrangements for the administration of the research projects; in cooperation with the executive vice president and provost and the dean, of the graduate school, assist in the coordination of the research programs and the instructional program of the university; and in cooperation with the senior vice president for business and finance, be responsible for developing the contracting procedures and contract terms for sponsored research undertaken by the colleges and divisions of the university. The senior vice president for research shall report to the president.
(N) Senior vice president for university relations. The major area of responsibility and authority of the senior vice president for university relations shall be the communications, public relations, and marketing of the university, WOSU stations, and the administration of all aspects of the university's relationships and dealings with federal, state and, local government officials, representatives and agencies to advance the university's mission and substantive agenda. Without limiting the generality of the foregoing, the senior vice president for university relations shall, under the direction of the president and with the approval of the board of trustees, be responsible and have the requisite authority for:
developing broad policies and operating procedures for communications, public relations, and marketing activities in support of the university's institutional goals; developing and implementing the university's marketing, communications, and public relations strategies; coordinating all internal and external institutional marketing and communications activities; instituting and coordinating collaborative strategies and activities with academic and academic-support units; presenting the university properly. to its key audiences nationally and statewide; -and informing the university's constituencies about the many benefits it offers and services it provides; advising the president and senior university leadership on all legislative and regulatory matters impacting the university's, interests; overseeing the development of strategies to effectively advance the university's academic agenda with government policymakers and funding agencies at all levels; maintaining top-level communications between the university and government officials; and overseeing development of support for the university's agenda among advocacy groups, institutional colleagues, policymakers, and Ohio citizens. The senior vice president for university relations shall report to the president, and, as appropriate, shall consult with the executive vice president and provost.
(0) Vice president for legal affairs and general counsel. The major area of responsibility and authority of the vice president for legal affairs and general counsel shall be that of administration of legal affairs for the university. Without limiting the generality of the foregoing, the vice president for legal affairs and general, counsel shall provide legal advice to the board of trustees, the president, and university officers and administrators. The vice president for legal affairs and general counsel shall, subject to the Ohio Revised Code sections 109.02, 109.12 and 3345.15, be the chief legal officer of the university and supervise all legal work performed on behalf of the university, including legal and contract services. The vice president for legal affairs and general counsel shall serve in an appropriate capacity with university affiliated organizations to coordinate legal matters between the university and these affiliated organizations. The vice president for legal affairs and general counsel, working with the secretary of the board of trustees, shall be responsible for the safekeeping of the university's legal documents and records.
(P) Chief of staff. The major area of responsibility and authority of the chief of staff shall be that of managing the office of the president; providing staff assistance relative to policy analysis; gathering information necessary to facilitate presidential decisions; performing any functions for the president that do not require the president's direct attention; serving as staff consultant and facilitator in the resolution of problems which cut across the university; advising the president on organizational and policy decisions; serving, , as the designee of the president, in committee meetings, university functions, and community events/affairs; and preparing reports and developing special position papers and other presentations for the office of the president.
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(Q) Advisory committees. The president and, subject to the direction of the president, each member of the president's planning cabinet shall have authority to designate advisory committees to advise in affairs relating to their respective responsibilities. These committees shall have such responsibilities as are assigned to them, and committee membership shall be determined by the person designating the committee. Any such committee may be discharged at any time by the person designating it.
(R) Principal administrative officials.
(1) The term "principal administrative official" shall include the members of the president's planning cabinet, the deans of the colleges and the dean and directors of regional campuses and their designated staffs, the director of the university libraries, chairs of academic departments, and directors of schools and academic centers. The members of the president's planning cabinet shall identify to the president such other persons in their areas of responsibility who shall be considered principal administrative officials of the university.
(2) The president of the university and the members of the president's planning cabinet shall be responsible for conducting both annual and periodic formal reviews of the principal administrative officials in their areas of responsibility.
(a) The purpose of the annual review shall be:
(i) To evaluate the official's performance; (ii) To provide information for improvement; (iii) To determine whether the official should be recommended for continued appointment; and (iv) To recommend compensation.
(b) The purpose of the formal periodic review shall be:
(i) To evaluate in a comprehensive manner the official's, performance, through formal review procedures; (ii) To provide information for improvement; and (iii) To determine whether or not the official should be recommended for continued appointment.
(c) Recommendations shall be forwarded to the president.
(3) Periodic formal reviews for deans shall be conducted toward the conclusion of each five-year period of service; for chairs, directors of schools and major centers toward the conclusion of each four-year period of service; and for other principal administrative officials toward the conclusion of each four-year period of service.
(4) Criteria for evaluation shall be established and defined by the members of the president's planning cabinet in consultation with the persons evaluated and the president. Qualities to be evaluated shall include but not be limited to: knowledge and ability, initiative, judgment, leadership capacity, tact, ability to communicate effectively and resolve conflicts; commitment to personal and professional growth and assisting others to achieve such growth; ability to manage budgets, delegate responsibility, and establish intelligent priorities in the administrator's area of responsibility; and commitment to the mission and goals of the institution.
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(5) In general, each review shall be performed by the person to whom the principal administrative official reports, in consultation with the principal administrative official and persons who report to or through the official being reviewed or by a committee appointed by the person to whom the official reports.
(S) University hospitals board.
(1) The university hospitals board shall be responsible to the board of trustees for the oversight of patient care services in university hospitals. The hospitals board shall be accountable through the president to the university board of trustees. The bylaws of the hospitals board will be subject to the approval of the university board of trustees.
(2) The hospitals board shall be comprised of two members of the university board of trustees, twelve persons selected from the general public, and the chairperson of the integrated faculty practice group or other senior faculty physician leader, all who shall be appointed by the university board of trustees in consultation with the president.
(3) The president of the Ohio state university.
(4) The executive director, medical director and chief of the medical staff of university hospitals, senior vice president for health sciences and dean of the college of medicine, and vice president for health services shall be ex-officio members with vote of the hospitals board.
(T) The Arthur G. James cancer hospital and the Richard J. Solove research institute board.
(1) The Arthur G. James cancer hospital and the Richard J. Solove research institute board shall be responsible to the board of trustees for establishing policy, maintaining quality patient care and providing for organization management and planning within the Arthur G. James cancer hospital and the Richard J. Solove research institute. The James cancer hospital board shall be accountable through the president to the university board of trustees. The bylaws of the James cancer hospital board will be subject to the approval of the university board of trustees.
(2) The Arthur G. James cancer hospital and the Richard J. Solove research institute board shall be comprised of two members of the university board of trustees, the director of the Arthur G. James cancer hospital and Richard J. Solove research institute, the director of the comprehensive cancer center, the director of medical affairs of the James cancer hospital and Solove research institute, the chief of staff of the James cancer hospital and Solove research institute, two senior university administrators, one member of the OSU cancer scholars program, six citizens from the general public, the university senior vice president for health sciences and dean of the
-college of medicine and public health, the president of the Arthur G. James cancer hospital and Richard J. Solove research institute foundation, and the vice president for health services, all appointed by the university board of trustees in consultation with the university president.
(U) Regional campuses boards.
(1) The Lima, Mansfield, Marion, and Newark boards shall advise and assist the dean/directors in the administration of their respective regional campuses. Subject to the authority and periodic review of the university board of trustees, each regional board shall:
(a) Develop support for the regional campus in their service area; (b) Advise the dean/directors concerning local educational needs, and perceptions of university programs; 11-11
(c) Serve as an advocate for the needs of the regional campus in local and state government agencies, and in the legislature; (d) Participate in the strategic planning process for the regional campus; (e) Review and provide a recommendation with respect to current funds and capital budgets prior to their submission to the university board of trustees by the president; and (f) Coordinate with the board of the appropriate technical college in all areas of common interest.
(2) Each regional campus board shall be composed of ten members appointed by the Ohio state university board of trustees in consultation with the president of the university: nine members shall be private citizens who have an interest in and knowledge of higher education and who reside within the area served by the institution; and one member shall be a student who is currently enrolled at the applicable regional campus and shall have no voting power on the board, shall not be considered as a member of the board in determining whether a quorum is present, and shall not be entitled to attend executive sessions.
The executive vice president and provost or the provost's designee, in cooperation with the appropriate dean/director, shall serve as the liaison between the regional boards and the various colleges and departments of the university, and may attend all meetings of the boards. The applicable chair of the faculty assembly shall serve as a resource person for the appropriate regional board and, in order to serve that function, may attend all public meetings of the appropriate regional board. (B/T 9/6/2002, B/T 12/5/2003, B/T 5/7/2004, B/T 9/22/2004, B/T 12/2/2005, B/T 7/7/2006, B/T 2/2/2007) 3335-1-04 The faculty and staff.
(A) University faculty; membership.
(1) As used in these rules and in the "Rules of the University Faculty," the term faculty shall include persons with regular tenure-track, regular clinical, regular research, auxiliary, and emeritus faculty titles on full or part-time appointments with or without salary.
(2) For purposes of the legislative authority described in paragraph (B) of this rule, the term university faculty shall mean all regular tenure-track faculty, the president, members of the president's planning cabinet serving at the president's pleasure and designated as executive heads of offices, the deans of the colleges and of the graduate school, the executive dean of the colleges of the arts and sciences, and the dean for undergraduate education.
(B) University faculty; powers.
(1) The legislative authority to establish educational and academic policies of the university is vested in the university faculty, subject to the approval of the board of trustees. In this connection, the university faculty shall have the authority, subject to the approval of the board of trustees, to adopt rules to effectuate the educational and academic policies of the university. It shall also act upon all matters of routine faculty business in pursuance of already established university policies and shall recommend to the board of trustees candidates for honorary degrees.
(2) The university faculty may delegate any or all of its authority and responsibility to a university senate if such senate is established by rule and approved by the board.
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Attachment B: Replacement Table 15
Integral Whole-Body Gamma Doses From Direct (From the Building) Dose At the Controlled-Area Boundary Assuming a Leakage Fraction of 0.0042 Hr-1 (Purge Fan Off)
Dose In mRem Exposure Times Isotope 5 10- 15 30 60 2 24 48 168 720 symbol Minutes Minutes Minutes Minutes Minutes Hours Hours Hours Hours Hours 131I 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1321 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 133 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 134 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 135 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 85m Kr 0.0 0.0 0.1 0.1 0.2 0.4 1.4 1.5 1.5 1.5 87Kr 0.1 0.2 0.3 0.6 1.0 1.6 2.4 2.4 2.4 2.4 8
'Kr 0.5 1.1 1.6 3.0 5.7 10.2 25.4 25.5 25.5 25.5 3
l lmxe 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.2 0.5 0.8 033mxe 0.0 0.0 0.0 0.0 0.0 0.1 0.8 1.3 2.1 2.3 133 Xe 0.0 0.1 0.1 0.2 0.5 0.9 9.7 17.4 37.7 46.8 35 1 mXe 0.1 0.1 0.2 0.3 0.4 0.4 0.4 0.4 0.4 0.4 35 1 Xe 0.1 0.2 0.4 0.7 1.4 2.8 16.1 18.4 18.8 18.8 TOTALS 0.9 1.8 2.6 5.0 9.2 16.3 56.3 67.1 88.9 98.4 16
Attachment C To remove reliance on operator intervention in the Basis for the proposed Specification in Section 3.2.2, Maximum Reactivity InsertionRate, of the Technical Specifications (TSs) submitted in the 04-Sep-2007 response letter, the following replacement is proposed. As seen below, the new analysis uses the safety system to bound the maximum possible reactivity insertion by that analyzed already in the SAR. Note that in addition to replacing the text of the Basis of Section 3.2.2, a new section will be added to the SAR to provide the analysis.
Technical Specifications change:
The following text is to replace the Basis given for Section 3.2.2 of the TSs in our response letter dated 04-Sep-2007.
Basis: This maximum reactivity insertion rate limit assures that the Safety Limit will not be exceeded due to a short period generated by a continuous linear reactivity insertion.
Section 8.4.3.5 of the SAR describes how the safety system will ensure that the reactivity inserted during a ramp reactivity insertion is bounded by the analysis performed for step reactivity insertions in SAR Sections 8.4.3.1 - 8.4.3.4, which shows that the Safety Limit will not be exceeded due to reactivity step insertions.
SAR addition:
The following text is to be added to Section 8.4.3 of the SAR:
8.4.3.5 Insertion at the Maximum Reactivity Insertion Rate Step insertions of up to 0.9312% Ak/k ($1.20) reactivity worth were analyzed in Sections 8.4.3.1 - 8.4.3.4 of the SAR, and it was concluded that for the design-basis accident scenario, the integrity of the fuel cladding would not be compromised (i.e., the Safety Limit specified in the Technical Specifications will not be exceeded). In this section, we show that inserting reactivity at the rate limit of 0.05% Ak/k per second specified in Section 3.2.2 of the Technical Specifications does not result in addition of greater reactivity than that analyzed for the design-basis scenario to therefore show that analysis of the maximum reactivity insertion rate is bounded by analysis of step reactivity insertion.
There are multiple scrams in place in the safety system and specified in the Technical Specifications that would prevent more than 0.9312% reactivity worth being inserted at the Technical Specifications rate limit of 0.05% Ak/k reactivity per second. These are: a scram for an indicated period of less than 5 seconds on the reactor period time-trace display, a scram for an indicated period of less than 1 second on the reactor period scram module, and a scram for an indicated power greater than 120% of the current 17
scale on the linear power level time-trace display. Because the linear channel will scram at 120% of whatever scale it is currently on, it will likely scram first for a fast exponential increase. However, to be conservative we are going to analyze based on the 1-second period scram.
Using a curve of stable reactor period versus reactivity, which was derived from the reactor kinetics equations (ANL-5800, Reactor Physics Constants, 2nd Edition, Section 5.3.2), we can find a value for the reactivity insertion corresponding to a stable reactor period of 1 second. Using values for the delayed neutron constants from Tables 4.1 and 8.2 of the SAR, the equation yields a reactivity value of 0.6035% Ak/k for a 1-second period. If reactivity is inserted at 0.05% Ak/k per second, it would take a little over 12 seconds to reach a reactivity insertion of 0.6035% Ak/k and therefore a 1-second period. Once a 1-second period was reached, a scram would be initiated by the reactor period scram module. The Technical Specifications limit for control rod scram time is 0.6 seconds. Therefore, up to another 0.6 s
- 0.05% Ak/k/s = 0.03% Ak/k reactivity could be added before the reactor was shut down, yielding a total maximum reactivity insertion of 0.6335% Ak/k. This value is well below the step input of 0.9312% Ak/k analyzed in the design basis scenario.
However, use of a curve of stable reactor period versus reactivity is not entirely correct for this situation. For an insertion of reactivity, the reactor kinetics equations yield a solution of reactor power versus time that consists of one positive exponential term and six negative exponential terms. For a step insertion, the negative terms decay away quickly, leaving just the positive term after a short amount of time. For a ramp reactivity insertion, the negative terms do not disappear, as reactivity is being continually added.
Because of this, the apparent reactor period will be less than that predicted by the stable-period value.
A ramp input of reactivity makes the reactor kinetics equations nonlinear, precluding a simple analytical solution. As a result, a solution must be obtained numerically to yield the time at which the reactor reaches a 1-second period. This has been done, and the answer predicts the reactor period reaching the 1-second scram limit at about 11.4 seconds after the start of the transient, versus the 12 seconds predicted by the stable-period curve. Therefore, the scram will be initiated more quickly than what was predicted by the stable-period curve, and less total reactivity will be inserted, making the value predicted by the stable-period curve a conservative bound on the actual value.
In summary, analysis of a ramp reactivity insertion at the Technical Specification 3.2.2 rate limit of 0.05% Ak/k/s is bounded by the analysis of a step reactivity insertion performed for the design-basis accident scenario by scram action of the period safety module. Also, as was mentioned previously, there are other scrams in the safety system to ensure that the reactor would be shut down by scram in such a scenario. In addition to the period safety module providing a scram in response to a 1-second period, there is a scram for an indicated period of less than 5 seconds on the reactor period time-trace display and a scram for an indicated power greater than 120% of the current scale on the linear power level time-trace display.
18
Attachment D 19
APPENDIX A TO FACILITY OPERATING LICENSE NO. R-75 Technical Specifications And Bases For The Ohio State University Pool-Type Nuclear Reactor Columbus, Ohio Docket No. 50-150
TABLE OF CONTENTS
1.0 INTRODUCTION
......................................................... 1 1.1 Scope.............................................................. 1 1.2 Application........................................................ 1 1.2.1 Purpose........................................................1 1.2.2 Format.......................................................... 1 1.3 Definitions........................................................ 1 2.0 SAFETY LIMIT AND LIMITING SAFETY SYSTEM SETTINGS (LSSS)............ 7 2.1 Safety Limit....................................................... 7 2.2 Limiting Safety System Settings.................................... 7 3.0 LIMITING CONDITIONS FOR OPERATION................................... 9 3.1 Reactor Core Parameters........................................... 9 3.1.1 Reactivity..................................................... 9 3.2 Reactor Control and Safety System................................ 10 3.2.1 Control Rod Scram Time........................................ 10 3.2'.2 Maximum Reactivity Insertion Rate............................ 10 3.2.3 Minimum Number of Scram Channels............................. 11 3 .3 Coolant System.................................................... 14 3.3.1 Pump Requirements............................................ 14 3.3.2 Coolant Level................................................. 14 3.3.3 Water Chemistry Requirements................................. 15 3.3.4 Leak, or Loss of Coolant Detection........................... 15 3.3.5 Primary and Secondary Coolant Activity Limits............... 15 3.4 Confinement....................................................... 16 3.5 Ventilation Systems.............................................. 16 3.6 Radiation Monitoring Systems and Radioactive Effluents.......... 17 3.6.1 Radiation Monitoring......................................... 17 3.6.2 Radioactive Effluents......................................... 18 3.7 Experiment's....................................................... 19 3.7.1 Reactivity Limits............................................ 19 3.7.2 Design and Materials......................................... 20 4.0 SURVEILLANCE REQUIREMENTS.......................................... 21 4.1 Reactor Core Parameters.......................................... 21 4.1.1 Excess Reactivity and Shutdown Margin....................... 21
4.1.2 Fuel Elements ........................... ..... 21 4.2 Reactor Control and Safety Systems .......... ..... 22 4.2.1 Control Rods ............................ ..... 22 4.2.2 Reactor Safety System .................... ..... 22 4.3 Coolant System .............................. ..... 23 4.3.1 Primary Coolant Water Purity ............ ..... 23 4.3.2 Coolant System Radioactivity ............ 24 .
4.4 Confinement .................................. ...... 24 4.5 Ventilation System .......................... ..... 24 4.6 Radiation Monitoring Systems and Radioactive Effluents.. ..... 25 4.6.1 Effluent Monitor ..................... . . .. . . .. . .. . . . . .. . . . . 2 5 4.6.2 Area Radiation Monitors (ARMs) ....... . . .. . . .. . .. . . .. . . . . . . 25 4.6.3 Portable Survey Instrumentation ...... . . . . . . .. .. . . . .. . . . . . . 2 5 5.0 DESIGN FEATURES ............................ . . . . . . .. . . . . .. . . . .. . . 2 6 5.1 Site and Facility Description ............ . .. . .. . . . . . .. . .. .. . . . 2 6 5.1.1 Facility Location .................... . . . . . . . . . . . . . . . . . . . . . 26 5.1.2 Controlled and Restricted Area ....... . . .. . . . . . . . . .. . . .. . . . 2 6 5.2 Reactor Coolant System ................... . . . . .. . . . .. . . . .. . . . . . 2 6 5.2.1 Primary Coolant Loop .................. .. .. . . .. . .. . . . .. . . . . . 2 6 5.2.2 Secondary and Tertiary Coolant Loops . . . . . . . . . . . . . . . . . . . . . . 2 6 5.3 Reactor Core and Fuel .................... . .. . . .. . . . . .. . . . .. . . . 2 6 5.4 Fuel.Storage .............................. . .. . .. . . . . . .. . . .. . .. . 2 7 5.5 Fuel Handling Tools ...................... . .. . .. . . . . .. . . .. . . . . . 2 7 6.0 ADMINISTRATIVE CONTROLS ..................... ................... ... 28 6.1 Organization ............................. ..... 28 .
6.1.1 Structure.............................. 28 .
6.1.2 Responsibility ....................... . . .. . . . . . .. . . . . . .. . . . 2 8 6.1.3 Staffing ............................. . . .. . . . . . .. . . . . . .. . . . 2 8 6.1.4 Selection and Training of Personnel .. . . .. . . .. . . . . . . . .. . . . 3 0 6.2 Review and Audit ........................... ....................... 30 6.2.1 Composition and Qualifications of the ROC .................. 30 6.2.2 ROC Meetings ......................... 31 6.2.3 Review Function ...................... 31 6.2.4 Audit Function ....................... 32.
6.3 Procedures ............................... 32 ii
6.3.1 Reactor Operating Procedures ............................... 32 6.3.2 Administrative Procedures ................................... 33 6.4 Experiment Review and Approval ................................ 33 6.4.1 Definitions of Experiments .................................. 33 6.4.2 Approved Experiments ...................................... 34 6.4.3 New Experiments ........................................... 34 6.5 Required Actions .............................................. 34 6.5.1 Action To Be Taken In the Event A Safety Limit Is Exceeded 34 6.5.2 Action To Be Taken In The Event Of A Reportable Occurrence 35 6 .6 Reports ....................................................... 37 6.6.1 Operating Reports ......................................... 37 6.6.2 Special Reports ........................................... 37 6 .7 Records ....................................................... 39 6.7.1 Records to be Retained for a Period of at Least Five Years 39 6.7.2 Records to be Retained for at Least One Requalification Cycle
.... ..... .... ...... .... ...... .... ...... ..... ...... ..... ...... ... 39 6.7.3 Records to be Retained for the Life of the Facility ...... 40 iii
1.0 INTRODUCTION
1.i1 Scope' This document constitutes the Technical Specifications for Facility License No. R-75 and supersedes all prior Technical Specifications.
Included are the "Specifications" and the "Bases" for the Technical Specifications. These bases, which provide the technical support for the individual technical specifications, are included for information purposes only. They are not part of the Technical Specifications, and they do not constitute limitations or requirements to which the licensee must adhere.
This document was written to be in conformance with ANSI/ANS-15.1-1990. The content of the Technical Specifications includes:
Definitions,. Safety Limits, Limiting Safety System Settings, Limiting Conditions for Operation, Surveillance Requirements, Design Features, and Administrative Controls.
1.2 Applicationr 1 .2.1 Purpose These Technical Specifications have been written specifically for The Ohio State University Research Reactor (OSURR).
The Technical Specifications represent the agreement between the licensee and the U.S. Nuclear Regulatory Commission on administrative controls, equipment availability, and operational parameters.
Specifications are limits and equipment requirements for safe reactor operation and for dealing with abnormal situations. They are typically derived from the Safety Analysis Report (SAR). These specifications represent a comprehensive envelope for safe operation. Only those operational parameters and equipment requirements directly related to preserving that safe envelope are listed.
1.2. 2 Format The format of this document is in general accordance with ANSI/ANS-15.1-1990.
1.3 Definitions
- Administrative Controls those organizational and procedural requirements established by the Nuclear Regulatory Commission and/or the facility management.
I
ALARA - as low as is reasonably achievable.
Channel - the combination of sensor, line, amplifier, and output devices which are connected for the purpose of measuring the.value of a parameter.
Channel Calibration - an adjustment of the channel such that its output corresponds with acceptable accuracy to known values of the measured parameter. Calibration shall encompass the entire channel, including equipment actuation, alarm, or trip settings,. and shall be deemed to include a channel test.
Channel Check a qualitative verification of acceptable performance by observation of channel behavior. This verification, where possible, shall include comparison of the channel with other independent channels or systems measuring the same variable.
Channel Test - the introduction of a signal into the channel'for verification that it is operable.
Cold Clean Core - when the core is at ambient temperature and the reactivity worth of xenon is negligible.
Confinement - a closure on the overall facility which controls the movement of air into it and out of it through a controlled path.
Control Rod - a device fabricated from neutron absorbing material which is used to establish neutron flux changes.
Control Rod Scram Time - elapsed time from the 'receipt of a safety signal to when a shim/safety rod is fully inserted.
Controlled Area - an area, outside of a restricted area but inside the site boundary, access to which can be limited by the licensee for any reason.
Controls - mechanisms used to regulate the operation of the reactor.
Core - the general arrangement of fuel elements and control rods.
Critical - when the effective multiplication factor (keff) of the reactor is equal to unity.
Excess Reactivity - that amount of reactivity that would exist if all control rods were removed from the core.
Experiment - any operation, or any apparatus, device, or material installed in or near the core or which could conceivably have a reactivity effect on the core and which itself is not a core component or experimental facility, intended to investigate 2
non-routine reactor parameters or radiation interaction parameters of materials.
Experimental Facility - any structure or device associated with the reactor that is intended to guide, orient, position, manipulate, or otherwise facilitate completion of experiments.
Explosive Material - any material that is given an Identification of Reactivity (Stability) index of 2, 3, or 4 by the National Fire Protection Association in its publication 704-M, Identification System for Fire Hazards of Materials, or is enumerated in the Handbook for Laboratory Safety published by the Chemical Rubber Company (1967).
Facility - the Reactor Building including offices and laboratories.
Fuel Element, Blank - A core element with no fuel plates. The bottom ends of these elements are closed to minimize coolant flow bypassing core elements with fuel. Also called "Filler Fuel Element".
Fuel Element, Control Rod - a fuel element with less than the full number of plates that is capable of holding a control rod.
Fuel Element, Partial - a fuel element with the full number of plates and less than 100% of the nominal fuel element loading Fuel Element, Standard - a fuel element with the full number of plates and 100% of the nominal fuel element loading Fueled Experiment - any experiment that contains U-235 or U-233 or Pu-239, not including the normal reactor fuel elements.
Indicated Value - See Measured Value.
Limiting Conditions for Operation (LCO) - administratively established constraints on equipment and operational characteristics that shall be adhered to during operation of the facility. The LCOs are the lowest functional capability or performance level required for safe operation of the facility.
Limiting Safety System Settings (LSSS) - settings for automatic protective devices related to those variables having significant safety functions. Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting shall be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded.
Measured Value - the value of a parameter as it appears on the output of a channel.
3
Movable Experiment - one for which it is intended that all or part of the experiment may be moved in relation to the core while the reactor is operating.
NRC - Nuclear Regulatory Commission.
ONE - onset of nucleate boiling.
Operable - a component or system is capable of performing its intended functions in a normal manner.
Operating - a component or system is performing its intended function'.
Protective Action -the initiation of a signal or the operation of eqýuipment within the reactor safety system in response to a variable or condition of the reactor facility having reached a specified limit.
Reactivity Worth of an Experiment - value of the reactivity change that results from the experiment being inserted into or removed from its intended position.
Reactor - the combination of core, permanently installed experimental facilities, control rods, and connected control instrumentation. ý Reactor Operating - the reactor is operating whenever it is not secured or shutdown.
ROC -.Reactor Operations Committee.
Reactor Operator (RO) - an individual who is licensed to manipulate the controls of the reactor in accordance with 10CFR55.
Reactor Safety Systems - those systems, including their associated input channels, which are designed to initiate automatic reactor protection or to provide information for initiation of manual protective action.
Reactor Secured - the reactor is secured when:
(1) Either there is insufficient moderator available in the reactor to attain criticality or there is insufficient fissile material present in the reactor to attain criticality under optimum available conditions of moderation and reflections, or (2) The following conditions exist:
- a. All shim/safety rods are fully inserted, and
- b. The console key switch is in the OFF position and the key is removed from the lock, and 4
- c. No work is in progress involving core fuel, core structure, installed control rods, or control rod drives unless they are physically decoupled from the control rods, and
- d. No experiments are being moved or serviced that that have, on movement, a reactivity worth exceeding the maximum value allowed for a single experiment.
Reactor Shutdown - when the reactor is subcritical by at least 1%
delta k/k in the cold clean core condition.
Regulating Rod - a low reactivity-worth control rod used primarily to maintain an intended power level.
Restricted Area - area to which access is controlled for purposes of protection of individuals from exposure to radiation and radioactive materials.
SAR Safety Analysis Report.
Safety Channel - a measuring or protective channel in the reactor safety system.,
Safety Limits - limits on important process variables that are found to be necessary to reasonably protect the integrity of the principle physical barriers that guard against the uncontrolled release of radioactivity. The principle physical barrier is the fuel cl'bdding.
Scram - the rapid insertion of the shim/safety rods into the reactor for the purpose of quickly shutting down the reactor.
Secured Experiment - any experiment, experimental facility, or component of an experiment that is held in a stationary position relative to the reactor by mechanical means. The restraining forces must be substantially greater than those to which the experiment might be subjected from the normal environment of the experiment or by forces which can result from credible malfunctions.
Senior Reactor Operator (SRO) - an individual who is licensed to direct the activities of reactor operators. Such an individual may also operate the controls of the reactor pursuant to 10CFR55.
Shall, Should, and May - the word "shall" is used to denote a requirement; the word "should" to denote a recommendation; and the word "may" to denote permission, which is neither a requirement nor a recommendation.
Shim/Safety Rods - high-reactivity worth control rods used primarily to provide coarse reactor cont'rol. They are connected electro-magnetically to their drive mechanisms and have scram capabilities.
5
Shutdown Margin - the shutdown reactivity necessary to provide confidence that the reactor can be made subcritical by means of the control and safety systems with the most reactive shim/safety rod and the regulating rod in the most reactive position (fully withdrawn) and that the reactor will remain subcritical without further operator action.
Startup Source - a spontaneous source of neutrons which is used to provide a channel check of the startup (fission chamber) channel and provide neutrons for subcritical multiplication during reactor startup.
Surveillance Time Intervals - The average over any extended period for each surveillance time interval shall be closer to the normal surveillance time, e.g. for the biennial interval the average shall be closer to two years rather than 30 months.
Five-year (interval not to exceed 6 years).
Biennial (interval not to exceed 30 months).
Annual (interval not to exceed 15 months).
Semiannual (interval not to exceed 7-1/2 months).
Quarterly (interval not to exceed 4 months).
Monthly (interval not to exceed 6 weeks).
Weekly (interval not to exceed 10 days).
Daily (shall be done during the same working day).
Any extension of these intervals shall be occasional and for a valid reason and shall not affect the average as defined.
True Value - the actual value of a parameter.
Unscheduled Shutdowns - any unplanned shutdown of the reactor caused by actuation of the reactor safety systems, operator error, equipment malfunction, or a manual shutdown in response to conditions which could adversely affect safe operation. They do not include those shutdowns resulting from expected testing operations, or planned shutdowns, whether initiated by controlled insertion of control rods or planned manual scrams.
6
2.0 SAFETY LIMIT AND LIMITING SAFETY SYSTEM SETTINGS (LSSS) 2.1 Safety Limit Applicability: This specification applies to the melting temperature of the aluminum fuel cladding.;
Objective: The objective is to assure that the integrity of the fuel cladding is maintained.
Specification: The reactor fuel temperature shall be less than 550 0C.
Bases:- The melting temperature of aluminum is 660 °C (1220 OF). The blister threshold temperature forU 3Si 2 dispersion fuel has been measured as approximately 550 °C. (ANL/RERTR/TM-10, October 1987, NRC NUREG 1313). Because the objective of this specification is to prevent release of fission products, any fuel whose maximum temperature reaches 550 °C. is to be treated as though the safety limit has been reached until shown otherwise.
2.2 Limiting Safety System Settings Applicability: This specification applies to the following items associated with core thermodynamics:
(1) Reactor Thermal Power Level and (2,) Reactor Coolant Inlet Temperature.
Objective: To assure that the fuel cladding integrity is maintained.
Specification:
(1) Reactor safety systems settings shall initiate automatic protective action at or below an indicated reactor power of of 600 kW.
(2) Reactor safety systems settings shall initiate automatic protective action so that core inlet water temperature shall not exceed 35 °C.
Bases: The criterion for these safety system settings is established as the fuel integrity. If the temperature of the clad is maintained below that for blister threshold then cladding integrity is maintained. This is the case for a power level of 600 kW and a core inlet temperature of 35 °C (normal inlet temperature is = 20-25 °C).
7
The maximum credible accident analysis is provided in Section 8.4.3.2 of the Safety Analysis Report. The maximum credible accident assumes steady state operation at 600 kW and initiation of a scram at. 750 kW. The maximum temperature of the cladding reaches 91 °C (SAR 8.4.3.3).
8
3.0 LIMITING CONDITIONS FOR OPERATION 3.1 Reactor Core Parameters
- 3. 1. 1 Reactivity Applicability: These specifications apply to the reactivity condition of the reactor and the reactivity worths of the shim/safety rods and regulating rod under any operating conditions.,
Objective: To ensure the capability for safe shutdown of the reactor and that the safety limits are not exceeded.
Specification: With the exception of operations performed solely for determination of reactor reactivity worth values, the reactor shall be operated only if the following conditions exist:
(1) The reactor core shall be loaded so that the excess reactivity, including the effects of installed experiments does not exceed 2.6% delta k/k under any operating condition.
(2) The minimum shutdown margin under any operating condition with the maximum worth shim/safety rod and the regulating rod full out shall be no less than 1.0% delta k/k.
(3) All core grid positions internal to the active fuel boundary shall be occupied by a standard, partial, control rod, or blank fuel element; or. by an experimental facility.
(4) The moderator temperature coefficient shall be negative and shall have a minimum absolute reactivity value of at least 2x10-5 /°C across the active core at all normal operating temperatures.
(5) The moderator void coefficient of reactivity shall be negative and shall have a minimum value of at least 2.8x10-3
/1% void across the active core.
- Bases:
(1) The maximum allowed excess reactivity of 2.6% delta k/k provides sufficient reactivity to accommodate fuel burnup, xenon buildup, experiments, control requirements, and fuel and moderator temperature feedback (Section 4.2 of the SAR).
Also, calculations show that this excess reactivity assures that the maximum temperature of the surface of the cladding will be well below the blister threshold of the U3Si 2 fuel during a design basis accident (SAR 8.4.3.2).
(2) The minimum shutdown margin ensures that the reactor can be 9
shutdown from any operating condition and remain shutdown after cooling and xenon decay even with the highest worth rod and the regulating rod fully withdrawn.
(3) The requirement that all grid positions be filled during reactor operation assures that the volume flow rate of
'primary coolant which bypasses the heat producing elements will be within the range specified in Section 4.8 of the SAR.
Furthermore, the possibility of accidentally dropping an object into a grid position and causing increase of reactivity is precluded.
(4) A negative moderator temperature coefficient of reactivity assures that any moderator temperature rise will cause a decrease in reactivity. The U3Si 2 fuel also has a significant negative temperature coefficient of reactivity due to the Doppler broadening of neutron capture resonances in 238U, but no credit is taken for this effect in our safety analyses.
(5) A negative void coefficient of reactivity helps provide reactor stability in the event of moderator displacement by experimental devices or other means.
3.2 Reactor Control and Safety System 3.2.lControl Rod Scram Time Applicability: This specification applies to the elapsed time from the receipt of a safety signal to when a shim/safety rod is fully inserted.
Objective: To ensure that the reactor can be shutdown within a specified period of time.
Specification: The reactor will not be operated unless the control rod scram time for a fully-withdrawn rod for each of the three shim/safety rods is less than 600 msec.
Bases: Control rod scram times as specified ensure that the safety limit will not be exceeded in a short-period transient.
The analysis for this is given in Section 8.4.3.3 of the SAR.
3.2.2 Maximum Reactivity Insertion Rate Applicability: This applies to the maximum positive reactivity insertion rate by the most reactive shim/safety rod and the regulating rod simultaneously.
10
11 Objective: To ensure the reactor is operated safely and the safety limit is not exceeded due to a short period.
Specification: The reactor will'not be operated unless the maximum reactivity insertion rate is less than 0.05% delta k/k per second.
Basis: This maximum reactivity insertion rate limit assures that the Safety Limit will not be exceeded due to a short period generated by a-continuous linear reactivity insertion. Section 8.4.3.5 of the SAR describes how the safety system will ensure that the reactivity inserted during a ramp reactivity insertion is bounded by the analysis performed for step reactivity insertions in SAR Sections 8.4.3.1 - 8.4.3.4, which shows that the Safety Limit will not be exceeded due to reactivity step insertions.
3.2.3 Minimum Number of Scram Channels Applicability: This specification applies to the reactor safety system channels.
Objective: To stipulate the minimum number of reactor safety system channels that shall be operable to ensure the Safety Limits are not exceeded by ensuring the reactor can be shutdown at all times.
Specification: The reactor shall not be operated unless the safety system channels described in the following table are operable.
Reactor Safety System Minimum Function Component Required
- 1. Core H20 Inlet Temp. 1 Scram if temp. > 35'C
- 2. Reactor Thermal power level 2 Scram if thermal power > 600 (Safety Channels) kW, as indicated on calibrated ionization chamber channels.
- 3. Reactor Period 1 Scram if period < 1 sec
- 4. Reactor Thermal power 1 Scram if primary and level/coolant system pumps .secondary coolant system pumps not on by > 120 kW thermal power 11
Reactor Safety System Minimum Function Component Required
- 5. Coolant Flow Rate Scram if coolant system has no flow (primary) by > 120 kW thermal power
- 6. Pool Water Level Scram if pool level < 20 feet (15 feet above core)
- 7. Switches *8 Scram if any listed switch is not set properly. Switches to
- a. Magnet Power Key switch select between operating mode
- b. Effluent Monitor and non-operating mode (e.g.
Counter switch on/off) must be set to
- c. Effluent Monitor operating mode. Switches to Compressor power switch select between operating mode
- d. LOG-N Amp calibrate or and a test or calibrate mode test mode switch (e.g. Norm/Test)' must be set
- e. Period Amp calibrate or to operating mode.
test mode switch
- f. Reactor power-level safety modules (2) calibrate or test mode switch
- g. Reactor period safety module calibrate or test mode switch
- 8. Time-Trace Displays 5 Scram if power is lost to any one of the listed time-trace
- a. LOG-N displays
- b. Linear Level
- c. Start-Up
- d. Period
- e. Effluent Monitor
- 9. Manual Scrams 5 Scram upon activation of any one manual scram switch
- a. Control Room Console
- b. Pool Top Catwalk
- c. BSF Catwalk
- d. Rabbit/BP Area
- e. Thermal Column/BP Area
- 10. Neutron-Sensitive 4 Scram if bias voltage drops Ionization Chambers below operational specifications 12
Reactor Safety System Minimum Function Component Required
- 11. Safety Set Points 3 Scram if any value listed Associated with Time-trace below is exceeded Display Signals
- a. Period < 5 sec
- b. Linear Level > 120% of licensed power
- c. Start-Up < 2 cts/sec (may be bypassed if Kf < 0.9)
- 12. Safety System 2 Scram in case of a safety amp fault or if system is discontinuous
- 13. Shim/Safety Rod Magnet 3 Rod drop will occur for any Current Shim/Safety rod which has magnet current > 100 ma Bases:
- 1. Assures safety limit is not exceeded
- 2. Assures safety limit is not exceeded
- 3. Assures safety limit is not exceeded
- 4. Assures coolant system pumps are functional before raising power > 120 kW
- 5. Assures there is always primary coolant flow when greater than 120 kW
- 6. Assures there is enough primary coolant for natural convection cooling
- 7. Assures nuclear instrumentation is in proper mode for operation
- 8. Assures information is available for observation by the reactor operator during operation, and is recorded if required as a record of reactor operations
- 9. Assures that the reactor can be shut down by the reactor operator in the control room or at other locations near experimental facilities if deemed necessary by other reactor staff 13
- 10. Assures shutdown if nuclear instrumentation fails
- 11. Assures backup shutdown capability from-short period or high power level. Assures shutdown if count rate is too low to provide meaningful startup information. The startup interlock may be bypassed if Kff is < 0.9
- 12. Assures all components of the safety system are installed and operational
- 13. Assures that any control rod exhibiting excess magnet current will be released and fall to the bottom due to gravity 3.3 Coolant System 3 .3.1 Pump Requirements Applicability: This specification applies to the operation of pumps for both the primary and secondary coolant loops.
Objective: To ensure that both pumps are functioning whenever the reactor is operated above 120 kW.
Specification: The reactor will not be operated above 120 kW unless both the primary and secondary coolant pumps are activated and there is flow in the primary coolant loop.
Bases: Having both pumps operating and flow in the primary loop will ensure there is adequate cooling of the primary coolant so the Safety Limit is not exceeded.
3.3.2 Coolant Level Applicability: This specification applies to the height of the water in the Reactor Pool above the core.
Objective: To ensure there is adequate primary coolant in the Reactor Pool and sufficient biological shielding above the core.
Specification: The reactor shall not be operated unless there is 20 feet of water in the reactor pool and 15 feet of water above the core.
Bases: With the pool full of water to a level of 20 feet there is adequate primary coolant for natural convection cooling. With 15 feet of water above the core there is sufficient shielding at the licensed power level. Section 7.1.1.4 of the SAR discusses this shielding. I 14
3.3.3 Water Chemistry Requirements Applicability: This specification applies to the purity of the primary coolant water.
Objective: To minimize corrosion of the-cladding on the fuel elements, and to reduce the probability of neutron activation of ions in the water.
Specification:
(1) The conductivity of the pool water shall not exceed the limit of 2.0 g mho/cm.
(2) The pH of the pool water shall not exceed 8.0.
Bases: Operation in accordance with these specification ensures aluminum corrosion is within acceptable limits, and that the concentration of dissolved impurities that could be activated by neutron irradiation remains within acceptable limits.
3.3.4 Leak, or Loss of Coolant Detection Applicability: This specification applies to the capability of detecting and preventing the loss of primary coolant.
Objective: To ensure there is adequate primary coolant in the Reactor Pool and sufficient biological shielding above the core when the reactor is operating.
Specification: The pool water level shall be at least 15 feet above the top of the fuel in the core.
Bases: The same system that functions to scram the reactor on low pool level will also be used as the detection system for this specification. Design criteria of the cooling system to prevent
-large losses of pool water due to siphoning are discussed in Section 3.2.2.1 of the SAR.
3.3.5 Primary and Secondary Coolant Activity Limits Applicability: This specification applies to the buildup of radioactive materials in the secondary coolant system.
Objective: To ensure there is a level low enough so as not to exceed 10CFR20 limits if coolant is released to the sanitary sewer system.
15
Specification: The primary and secondary coolant system shall be monitored, for the buildup of radioactivity and analyzed at least semiannually for increase in the concentration of radionuclides.
Ba sis: The basis for this specification is to ensure releases are legal and consistent with the ALAPA principal..
3.4 Confinement Applicability: This specification applies to the capability to provide confinement for-the reactor building.
Objective: To prevent the exposure of the public to airborne.
radioactivity exceeding the limits of 10CFR20 and the ALAPA principle.
Specification: The reactor shall not be operated unless the following conditions are met:
(1) Exhaust fan operating (2) With exceptions for ingress and egress, all exterior doors and windows closed.
Bases: By having the capability to provide confinement for the Reactor Building, exposure of the public to airborne radioactivity may be limited to the extent analyzed in the SAR.
3 .5 Ventilation Systems Applicability: This specification applies to all heating, ventilating, and air conditioning systems that exhaust building air to the outside environment.
Objective: To provide for normal ventilation and the reduction of airborne radioactivity within the reactor building during normal reactor operation and to provide a way to turn off all vent systems quickly in order to isolate the building for emergencies.
Specification:
(1) An exhaust fan with a capacity of at least 1000 cfm shall be operable whenever the reactor is operating.
(2) This fan, as well as all other heating, ventilating, and air conditioning systems shall have the capability to be shut off from a single switch in the control room.
Bases: In the unlikely event of a release of fission products or other airborne radioactivity, the ventilation system will reduce 16
radioactivity inside the reactor building or be able to be isolated.
An analysis of fission product release is found in section 8.4.4 of the SAR.
3.6 Radiation Monitoring Systems and Radioactive Effluents 3.6. 1 Radiation Monitoring Applicability: This specification applies to the availability of radiation monitoring equipment which shall be operable during reactor operation.
Objective: To assure that monitoring equipment is available to evaluate radiation levels in restricted and unrestricted areas and to be'consistent with ALARA.
Specification:
(1) When the reactor is operating, the building gaseous effluent monitor shall be operating and have a readout and alarm in the control room. It may be used in either the "normal" mode or "sniffer" mode.
(2) When the reactor is operating, the following Area Radiation Monitors (ARMs) shall be operating and have both local and control room readouts and alarms.
- a. Pool Top
- b. Primary Cooling System
- c. Beam Port/Rabbit Area
- d. Thermal Column Area (3) Portable survey instrumentation shall be available whenever the reactor is operating to measure beta-gamma exposure rates and neutron dose rates.
(4) When required monitors are inoperable, portable instruments, surveys, or analyses may be substituted for any of the normally-installed monitors in Section 3.6.1 above for periods of one week or for the duration of a reactor run in cases where the reactor is continuously operated.
Bases:
(1) The gaseous effluent monitor will detect Ar-41 levels in the reactor building. During "normal" mode' operation it will sample and monitor air just before it is released from the reactor building. (SAR 6.3.1) During "sniffer" mode of operation it may be used for short periods to monitor in and around experimental facilities to determine local Ar-41 17
levels.
(2) The ARMs provide a continuing evaluation of the radiation levels within the Reactor Building (SAR 3.7) and provide a warning if levels are higher than anticipated.
(3) The availability of survey meters enables the Reactor Staff to independently confirm radiation levels throughout the building.
(4) In. the event of instrument failure short term substitutions will enable the safe continued operation of the Reactor.
3.6.2 Radioactive Effluents Applicability: This specification applies to the monitoring of radioactive effluents from the facility.
Objectives:
(1) To ensure that liquid radioactive releases are safe and legal.
(2) To ensure that the release of Ar-41 beyond the site boundary does not result in concentrations above the Effluent Concentration limit for unrestricted areas (IOCFR20.1302; 10CFR20 Appendix B, Table 2).
(3) To assure that the release of Ar-41 in the restricted area does not result in concentrations above the DAC.
Specifications:
(1) The concentration of radioactive liquids released into the sanitary sewer shall not exceed the limits as specified in IOCFR20.2003.
(2) The concentration of Ar-41 at ground level below the point of release into the unrestricted area shall not exceed the unrestricted area Effluent Concentration limit (IOCFR20.1302; 10CFR20 Appendix B, Table 2) when averaged over one year or ten times the Effluent Concentration limit when averaged over one day.
(3) The concentration of Ar-41 in the restricted area shall not exceed the DAC when averaged over a 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> work year.
Bases:
(1) The basis for this specification is found in Section 6.2 of 18
the Safety Analysis Report.
(2) The basis for this specification is found in Section 6.3 of the Safety Analysis Report.
(3) The basis for this specification is found in Section 6.3 of the Safety Analysis Report and 10CFR20.1003.
3.7 Experiments
- 3. 7. 1 Reactivity Limits Applicability: This specification applies to experiments to be installed in or near the reactor and associated experimental facilities.
Objectives: To prevent damage to the reactor or excessive release of radioactive materials in the event of an experiment failure.
Specification:
(1) The absolute value of the reactivity worth of any single secured experiment shall not exceed 0.7% delta k/k.
(2) The absolute value of the reactivity worth of any single movable experiment shall not exceed 0.4% delta k/k.
(3) The absolute value of the reactivity worth of all movable experiments shall not exceed 0.6% delta k/k.
(4) The absolute value of the reactivity worth of experiments having moving parts shall be designed to have an insertion rate less than 0.05% delta k/k per second.
(5) The absolute value of the reactivity worth of any movable experiment that may be oscillated shall have a reactivity change of less than 0.05% delta k/k.
(6) The total reactivity worth of all experiments shall not be greater than 0.7% delta k/k.
Bases:
(1) The bases for specifications 1, 2, 3, and 6 are found in Section 8.4.3.2 of the SAR which evaluates a step insertion of reactivity from an experiment.
(2) The bases for specifications 4 and 5 allows for certain reactor kinetics experiments to be performed but still liimits the rate of change of reactivity insertions to levels that 19
have been analyzed. Section 8.4.3.2 of the SAR evaluates a step insertion of reactivity from an experiment.
/
3.7.2 Design and Materials Specification:
(1) No experiment shall be installed that could shadow the nuclear instrumentation, interfere with the insertion of a control rod, or credibly result in fuel element damage.
(2) All materials to be irradiated in the reactor shall be either corrosion resistant or doubly encapsulated within corrosion resistant containers.
(3) Explosive materials shall not be allowed in experiments, except for neutron radiographic exposures of items performed outside of the core and experimental facilities. The amount of explosive material contained in capsules used for radiographic exposures shall not exceed 5 grains of gunpowder.
Bases:
(1) Specification 1 assures no physical interference with the operation of the reactor detectors, control rods, or physical damage to fuel element will take place.
(2) Limiting corrosive materials in Specification 2, and explosives in Specification 3 reduces the likelihood of damage to reactor components and/or releases of radioactivity resulting from experiment failure.
(3) Limiting explosive materials to neutron radiographic exposures done outside of the core and experimental facilities reduces the likelihood of damage resulting for this experimental failure.
20
- 4. 0 SURVEILLANCE REQUIREMENTS 4.1lReactor Core Parameters 4.l1.l1Excess Reactivity and Shutdown Margin Applicability: This specification applies to surveillance requirements for determining the excess reactivity of the reactor core and its shutdown margin.
Objective: To assure that the excess reactivity and shutdown margin limits of the reactor are not exceeded.
Specifications:
(1) Whenever a net change in core configuration, for which the predicted change in reactivity is > 0.2% delta k/k, involv ing grid position is made, both excess reactivity and shutdown margin shall be determined.
(2) Both shutdown margin and excess reactivity shall be determined annually.
Bases: A determination of excess reactivity is needed to preclude operating without adequate shutdown margin. Moving a component out of the core and returning it to its same location is not a change in the core configuration and does not require a determination of excess reactivity.
4 .1.2 Fuel Elements Applicability: This specification applies to surveillance requirements for determining the physical condition of the reactor fuel.
objective: To ensure that visible deterioration, corrosion, or other physical changes to the fuel elements are detected in a timely manner.
Specification: All fuel elements, both in-core and out, shall be visually inspected at least once every five years, by inspecting at least one fifth of the elements annually.
Basis: If the water purity is continuously maintained within specified limits, it is projected that chemical corrosion of the fuel clad will proceed slowly. However, faults in the basic materials or fabrication could lead to loss of cladding integrity.
21
4.2 Reactor Control and Safety Systems 4.2.1 Control Rods Applicability: This specification applies to the surveillance requirements for the shim safety rods and the regulating rod.
Objective: To assure that all rods are operable.
Specifications:
(1) The reactivity worth of the shim safety rods and regulating rod shall be determined annually and prior to the routine operation of any new core configuration.
(2) Shim safety control rod scram times and drive times and regulating rod drive time shall be determined annually or after maintenance or modification is completed on a mechanism.
(3) The shim safety rods and regulating rod shall be visually inspected annually for indication of corrosion and indication of excessive friction with guides.
Bases: The reactivity worth of the rods is measured to assure the required shutdown margin and reactivity insertion rates are maintained. It also provides a means for determining the reactivity of experiments. Measuring annually will provide corrections for burnup and after core changes assures that altered rod worths will be known prior to continued operations.
The visual inspection of the rods and measurements of control rod scram times and drive times are made to assure the rods are capable of performing properly. Verification of operability after maintenance or modification of the control system will ensure proper reinstallation.
4.2.2 Reactor Safety System Applicability: This specification applies to the surveillance requirements for the Reactor Safety System.
Objective: To assure the reactor safety system channels will remain operable and prevent safety limits from being exceeded.
Specification:
(1) A channel check of each measuring channel shall be performed daily when the reactor is operating.
22
(2) A channel test of each measuring channel shall be performed prior to each day's operation or prior to each operation extending more than one day.
(3) A channel calibration of the reactor power level measuring channels shall be made annually. (Linear Level and LOG-N.)
(4) A channel calibration of the Level and Period Safety Channels shall be made annually. Channel tests are done on these before each day's operation.
(5) A channel calibration of the following shall be made annually
- a. Core inlet temperature measuring system
- b. Adequate pool water level indication
- c. Indication of coolant system pumps operating
- d. Indication that there is flow in the primary coolant loop (6) The control room manual scram shall be verified to be operable prior to each day's operation. All other manual scram switches shall be tested annually.
(7) Other scram channels shall be tested/calibrated annually.
(8) Any instrument channel replacement shall be calibrated after installation and before utilization.
(9) Any instrument repair or replacement shall have a channel test prior to reactor operation.
Bases: The daily channel tests and checks will assure that the scram channels are operable. Appropriate annual tests or calibrations will assure that long term functions not tested before daily operation are operable.
4.3 Coolant System 4.3.1 Primary Coolant Water Purity Applicability: This specification applies to the conductivity of the primary coolant water.
Objective: To assure high quality pool water.
Specification: The conductivity and pH of the pbol water shall be measured weekly.
Bases: This assures that changes that might increase the corrosion rate are detected in a timely manner and that the concentrations of 23
impurities that might be made radioactive do not increase significantly.
4.3.2 Coolant System Radioactivity Applicability: This specification applies to the radioactive material in the primary coolant or secondary coolant.
Objective: To identify radionuclides as potential sources of release to the sanitary sewer system.
Specification: Primary and secondary coolant shall be analyzed for radioactivity quarterly or before release.
Bases: Radionuclide analysis of the pool water or secondary coolant allows for determination of any significant buildup of fission or activation products and helps assure that radioactivity is not permitted to escape to the tertiary system in an uncontrolled manner.
4.4 Confinement Applicability: This specification applies to the surveillance requirements for building confinement.
Objective: To assure that building confinement capability exists.
Specification: A quarterly test shall be made to assure that the building exhaust fan is operable and all exterior doors and windows have closure capability.
Bases: Quarterly surveillance of this equipment will verify that the confinement of the reactor bay can be maintained if needed.
4.5 Ventilation System Applicability: This specification applies to the surveillance requirements-for the building ventilation system.
Objective: To assure that the ventilation shutoff functions satisfactorily.
Specification: The shutoff switch for all fans and air conditioning systems shall be tested on a quarterly basis.
Bases: This surveillance will assure that the building can be isolated quickly if necessary to prevent uncontrolled escape .of air-borne radioactivity to the unrestricted environment.
24
4.6 Radiation Monitoring Systems and Radioactive Effluents 4.6.1 Effluent Monitor Applicability: This specification applies to the surveillance requirement of the effluent monitor.
Objective: To assure the effluent monitor is operational and providing accurate effluent readings.
Specification: The effluent monitor shall have a channel calibration annually and a channel test before each days operation.
Bases: The calibration will assure effluent release estimates are accurate and the test will assure the monitor is operable whenever the reactor is operating.
4.6.2 Area Radiation Monitors (ARMs)
Applicability: This specification applies to the area radiation monitoring equipment.
Objective: To assure that radiation monitoring equipment is operable whenever the reactor is operating.
Specification: A channel test of the ARMs shall be completed before each day's operation and a channel calibration shall be completed annually.
Bases: Calibration annually will insure the required reliability and a check on days when the reactor is operated will detect obvious malfunctions in the system.
4.6.3 Portable Survey Instrumentation Applicability: This specification applies to the portable survey instrumentation available to measure beta-gamma exposure rates and neutron dose rates.
Objective: To assure that radiation survey instrumentation is operable whenever the reactor is operating.
Specification: Beta-gamma and neutron survey meters shall be checked with a source for operability quarterly and shall be calibrated annually.
Bases: Checks with a source will detect obvious detector deficiencies and an annual calibration will assure reliability.
25
5.0 DESIGN FEATURES 5.1 Site and Facility Description 5.1.1 Facility Location The reactor and associated equipment is housed in a building at 1298 Kinnear Road, Columbus, Ohio, located on the West Campus of The Ohio State University. The minimum free air volume of the building housing the reactor will be > 70,000 ft 3 . There is an exhaust fan with dampers providing for control of release of airborne radioactivity.
5.1.2 Controlled and Restricted Area The fence surrounding the Reactor Building shall describe the controlled area. The restricted area as defined in 10CFR20 shall consist of the Reactor Building.
5.2 Reactor Coolant System 5.2.lPrimary Coolant Loop Natural convective cooling is the primary means of heat removal from the core. Water enters the core at the bottom and flows upward through the flow channels in the fuel elements.
5.2.2 Secondary and Tertiary Coolant Loops The secondary coolant loop removes heat from the primary coolant.
The secondary coolant (ethylene glycol and water) passes through two separate heat exchangers to remove heat if necessary. Heat is removed from the first by an outside fan-forced dry cooler. City water flow through the secondary side of an additional heat exchanger makes up the tertiary loop. It provides additional cooling for the secondary coolant.
5.3 Reactor Core and Fuel Up to 30 positions on the core grid plate are available for use as fuel element positions. Control rod fuel elements occupy four of these positions and one is reserved for the Central Irradiation Facility flux trap. Several arrangements for the cold, clean, critical core have been investigated. Approximately eighteen standard fuel elements in addition to the control rod fuel elements are currently required. Partial elements, blank elements, and graphite elements may be utilized in various combinations to achieve the proper K excess.
26
The reactor fuel is The DOE Standard uranium-silicide (U3Si 2 ) with a U-235 enrichment of less than 20%. It is flat plate fuel with a "meat" thickness of 0.020" and aluminum cladding of 0.015". Standard fuel elements have a total of 16 fueled plates and 2 outer pure aluminum plates. The control rod fuel'elements have eight of the inner fuel plates removed to allow the control rods to enter. Pure aluminum guide plates are on the inside of this gap. The outer two plates for each control rod assembly are fueled. Partial elements are also available with 25, 40, 50, and 60 percent of the nominal loading of a standard element. These partial fuel elements are prefabricated by the vendor with fixed numbers of plates.
(1)
References:
NRC NUREG 1313 ANL/RERTR/TM-10 ANL/RERTR/TM-11 5.4 Fuel Storage The fuel storage pit, located below the floor of the reactor pool and at the end opposite from the core, shall be flooded with water whenever fuel is present and shall be capable of storing a complete core loading. When fully loaded with fuel and filled with water Kff shall not exceed 0.90, and natural convective cooling shall ensure that no fuel temperatures reach a point at which ONB is possible.
5.5 Fuel Handling Tools All tools designed for or capable of removing fuel from core positions or storage rack positions shall be secured when not in use by a system controlled by the supervisor of reactor operations, or the senior reactor operator on duty.
27
6.0 ADMINISTRATIVE CONTROLS 6..1 Organization 6 . 1.1 Structure The Ohio State University Research Reactor is a part of the College of Engineering administered by the Engineering Experiment Station.
The organizational structure is shown in Figure 6.1.
6..1.2 Responsibility The Director of the Engineering Experiment Station (Level 1) is the contact person for communications between the U.S. Nuclear Regulatory Commission and The Ohio State University.
The Director of the Nuclear Reactor Laboratory (Level 2) will have overall responsibility for the management of the facility.
The Associate Director (or Manager of Reactor Operations) (Level 3) shall be responsible for the day-to-day operation and for ensuring that all operations are conducted in a safe manner and within the limits prescribed by the facility license and Technical Specifications. During periods when the Associate Director is absent, his responsibilities are delegated to a Senior Reactor Operator (Level 4).
6.1.3 Staffing (1) The minimum staffing when the reactor is not secured shall be:
(a) A certified reactor operator in the control room (b), A second designated person present at the facility complex able to carry out prescribed written instructions. Unexpected absence for as long as two hours to accommodate a personal emergency may be acceptable provided immediate action is taken to obtain a replacement.
(c) A Senior Reactor Operator shall be readily available on call.
"Readily Available on Call" means an individual who (1) has been specifically designated and the designation known to the operator on duty, (2) keeps the operator on duty informed of where he may be rapidly contacted and the phone number, and (3) is capable of getting to the reactor facility within a reasonable time under normal conditions (e.g. 30 minutes or within a 15-mile radius).
28
Provost Senior Vice President Dean, I
Business and Finance Associate Vice President College of Enginee: Facilities, Operations, and Development Director, Engineer Senior Director Experiment Static Environmental Health and (Level 1) N Reactor Operations 0 Committee I Safety Director, Nuclear Director, Radiation Reactor Laboratorn Safety Section (Level 2)
Associate Director, Nuclear Reactor Laboratory (Level 3)
Senior Reactor Operator 1
(Level 4)
Reactor Operations Staff Solid Lines Paths of Direct Responsibility Dashed Lines Paths of Information Figure 6.1: Administrative Organization 29
(2) A list of reactor facility personnel by name and telephone number shall be readily available in the control room for use by the reactor operator. The list shall include:
(a) Management personnel (b) Radiation safety personnel (c) Other operations personnel (3) Events requiring the presence at the facility of a senior reactor operator:
(a) Initial startup and approach to power, (b) All fuel or control-rod relocations within the reactor core region (c) Recovery from an unplanned or unscheduled shutdown. (In these instances, documented verbal concurrence from a senior reactor operator is required.)
6.1.4 Selection and Training of Personnel The selection, training, and requalification of operations personnel shall meet or exceed the. requirements of American National Standard for Selection and Training of Personnel for Research Reactors, ANSI/ANS-15.4-1988.
6.2 Review and Audit There shall be a Reactor Operations Committee (ROC) for independent review of the safety aspects of reactor operations to assure the facility is operating in a manner consistent with public safety and within the terms of the facility license.
A member or menmbers of this committee or another qualified person or persons shall audit safetyaspects of reactor operations as described in Section 6.2.4 of this document.
6.2.1 Composition and Qualifications of the ROC The ROC shall be composed of a minimum of three members, who should collectively represent a broad spectrum of expertise in appropriate fields (i.e. having professional backgrounds in engineering, physical, biological, or medical sciences, as well as knowledge of and interest in applications of nuclear technology and ionizing radiation). Members and alternates shall be appointed by and report to Level 1 management. Individuals may be either from within or 30
outside the operating organization. Qualified and approved alternates may serve in the absence of regular members.
6.2.2 ROC Meetings ROC functions shall be conducted in accordance with the following:
(1) Meetings shall be held at least once per calendar year and more frequently as circumstances warrant, consistent with effective monitoring of facility activities.
(2) A meeting quorum shall consist of at least half of the membership where the operating staff does not constitute a majority.'
(3) The ROC may appoint a subcommittee from within its membership to act on behalf of the full committee on those matters which cannot await the next meeting. The ROC shall review the actions taken by the subcommittee at the next regular, meeting.
(4) Meeting minutes shall be distributed to ROC members before the next meeting and shall be reviewed at the next meeting.
6.2.3 Review Function The ROC shall review the following:
(1) Determination that proposed changes in equipment, systems, tests, experiments, or procedures do not require a license update as described in I0-CFR-50.59.
(2) All new procedures and major revisions thereto having safety significance; proposed changes in reactor facility equipment or systems having safety significance (3) All new experiments or classes of experiments that could
- affect reactivity or result in the release of radioactivity.
(4) Proposed changes in technical specifications or license (5) Violations of technical specifications or license; violations of internal procedures having safetysignificance.
(6) Operating abnormalities'having safety significance.
(7) Reportable occurrences listed in Section 6.6.2 of this document (8) Audit reports 31
A written report or minutes of the findings and recommendations of the review group shall be submitted to Level 1 management and ROC.
members in a timely manner after the review has been completed.
6 .2 .4Audit Function The audit function shall include selective (but comprehensive) examination of operating records, logs, and other documents.
Discussions with cognizant personnel and observations of operations should be used also as appropriate. In no case shall the individual immediately responsible for an area perform an audit in that area.,
The following items shall be audited:
(1) Facility operations for conformance to the technical specifications and license, at least once per calendar year (interval between audits not to exceed 15 months)
(2) The requalification program for the operating staff, at least once every other c'alendar year (interval between audits not to exceed 30 months)
(3) The results of action taken to correct those deficiencies' that may occur in the reactor facility, equipment, systems, structures, or methods of operations that affect reactor safety, at least once per calendar year (interval between audits not to exceed 15 months)
(4) The reactor facility emergency plan and implementing procedures at least once every other calendar year (interval between audits not to exceed 30 months)
Deficiencies found that affect reactor safety shall be reported immediately to Level 1 management. A written report of audit findings should.-be submitted to Level 1 management and the full Reactor Operations Committee within three months of the audit's completion.
6.3 Procedures 6.3.l1Reactor Operating Procedures Written procedures, reviewed and approved by the Director, or his/her designee., and reviewed by the ROC, shall be in effect and followed. The procedures shall be adequate to assure the safety of the reactor, but should not preclude the use of independent judgement and action should the situation require such. All new procedures and changes to existing procedures shall be documented by the NRL staff and subsequently reviewed by the ROC. At least the following items shall be covered:
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(1) Startup, operation, and shutdown of the reactor, (2) Installation, removal, or movement of fuel elements, control rods, experiments, and experimental facilities, (3) Actions to be taken to correct specific and foreseen potential malfunctions of systems or components including responses to alarms, suspected cooling system leaks, and abnormal reactivity changes, (4) Emergency conditions involving potential or actual release of radioactivity including provisions for evacuation, re-entry, recovery, and medical support, (5) Preventive and-corrective maintenance procedures for systems which could have an effect on reactor safety, (6) Periodic surveillance of reactor instrumentation and safety systems, area monitors, and radiation safety equipment, (7) Implementation of the Emergency Plan, reactor operator training and requalification requirements, and the security requirements of I0-CFR-73.67.
(8) Personnel radiation protection.
6.3.2 Administrative Procedures Procedures shall also be written and maintained to assure compliance with Federal regulations, the facility license, and commitments made to the ROC or other advisory or governing bodies. As a minimum, these procedures shall include:
(1) Audits, (2) Special Nuclear Material accounting, (3) Operator requalification, (4) Record keeping, and (5) Procedure writing and approval.
6.4 Experiment Review and Approval 6.4.lDefinitions of Experiments Approved experiments are those which have previously been reviewed and approved by the ROC. They shall be documented and may be 33
included as part of the Procedures Manual. New experiments are those which have not previously beenreviewed, approved, and performed.
Routine tests and maintenance activities are not experiments.
6.4.2 Approved Experiments All proposed experiments utilizing the reactor shall be evaluated by the experimenter and a licensed Senior Reactor Operator to assure compliance with the provisions of the utilization license, the Technical Specifications, and 10CFR Parts 20 and 50. If, in the judgement of the Senior Reactor Operator, the experiment meets with the above provisions, is an approved experiment, and does not constitute a threat to the integrity of the reactor, it may be approved for performance. When pertinent, the evaluation shall include considerations of:
(1) The reactivity worth of the experiment (2) The integrity of the experiment, including the effects of changes in temperature, pressure, or chemical composition (3) Any physical or chemical interaction that could occur'with the reactor components, and (4) Any radiation hazard that may result from the activation of materials or from external beams 6.4.3 New Experiments Prior to performing an experiment not previously approved for the reactor, the experiment shall be reviewed and approved by the Reactor Operations Committee. Committee review shall consider the following information:
(1) The purpose of the experiment, (2) The procedure for the performance of the experiment, and (3) The safety evaluation previously reviewed by a licensed Senior Reactor Operator.
6.5 Required Actions 6.5.1Action To Be Taken In the Event A Safety Limit Is Exceeded (1) The reactor shall be shut down, and reactor operations shall not be resumed until authorized by the NRC.
(2) The safety limit violation shall be promptly reported to the Director of the Reactor Laboratory.
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(3) The safety limit violation shall be reported by telephone to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(4) A safety limit violation report shall be prepared. The report shall describe the following:
- a. Applicable circumstances leading to the violation including, when known, the cause and contributing factors,
- b. Effect of the violation upon reactor facility components, systems, or structures and on the health and safety of personnel and the public, and
- c. Corrective action to be taken to prevent recurrence.
(5) The report shall be reviewed by the Reactor Operations Committee and shall be submitted to the NRC within 14 working days when authorization is sought to resume operation of the reactor.
6.5.2Action To Be Taken In The Event Of A Reportable Occurrence A reportable occurrence is any of the following conditions:
(1) Operating with any safety system setting less conservative than stated in these specifications, (2) Operating in violation of a Limiting Condition for Operation established in Section 3 of these specifications.
(3) Safety system component malfunctions or other component or system malfunctions during reactor operation that could, or threaten to, render the safety system incapable of performing its intended function.
(4) An uncontrolled or unanticipated increase in reactivity in excess of 0.4% delta k/k, (5) An observed inadequacy in the implementation of either administrative or procedural controls, such that the inadequacy could have caused the existence or development of an unsafe condition in connection with the operation of the reactor, and (6) Abnormal and significant degradation in reactor fuel and/or cladding, coolant boundary, or confinement boundary (excluding minor leaks) where applicable that could result in exceeding prescribed radiation exposure limits of personnel and/or the environment.
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(7) Any uncontrolled or unauthorized release of radioactiviity to the unrestricted environment.
In the event of a reportable occurrence, the following action shall be taken:
(1) Thereactor conditions shall be returned to normal, or the reactor shall be shutdown, to correct the occurrence.
(2) The Director of the Reactor Laboratory shall be notified as soon as possible and corrective action shall be taken before resuming the operation involved.
(3) A written report of the occurrence shall be made which shall include an analysis of the cause of the occurrence, the corrective action taken, and the recommendations for measures to preclude or reduce the probability of recurrence. This report shall be submitted to the Director and the Reactor Operations Committee for review and approval.
(4) A report shall be submitted to the Nuclear Regulatory Commission in accordance with Section 6.6.2 of these specifications.
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6.6 Reports Reports shall be made to the Nuclear Regulatory Commission as follows:
6.6. 1 Operating Reports An annual report shall be made by September 30 of each year to the NRC's Document Control Desk (if on paper, the signed original),
with a copy to the appropriate Regional Office, in accordance with 10-CFR-50.4, providing the following information:
(1) A narrative summary of operating experience (including experiments performed) and of changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period.
(2) A tabulation showing the energy generated by the reactor (in kilowatt hours) and the number of hours the reactor was in use.
(3) The results of safety-related maintenance and inspections.
The reasons for corrective maintenance of safety-related items shall be included.
(4) A table of unscheduled shutdowns and inadvertent scrams, including their reasons and the corrective actions taken.
(5) A summary of the Safety Analyses performed in connection with changes to the facility or procedures, which affect reactor safety, and performance of tests or experiments carried out under the conditions of Section 50.59 of 10CRF50.
(6) A summary of the nature and amount of radioactive gaseous, liquid, and solid effluents released or discharged to the environs beyond the effective control of the licensee as measured or calculated at or prior to the point of such release or discharge.
(7) A summary of radiation exposures received by facility personnel and visitors, including the dates and times of significant exposures.
6.6.2 Special Reports (1) A telephone or telegraph report of' the following shall be submitted as soon as possible, but no later than the next working day, to appropriate Regional Office:
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(a) Any accidental offsite release of radioactivity above authorized limits, whether or not the release resulted in property damage, personal injury, or known exposure.
(b) Any exceeding of the safety limit as defined in Section 2.1 of these specifications.
(c) Any reportable occurrences as defined in Section 6.5.2 of these specifications.
(2) A written report shall be submitted within 14 days to the NRC's Document Control Desk (if on paper, the signed original), with a copy to the appropriate Regional Office, in accordance withl10CFR 50.4, of the following:
(a) Any accidental offsite release of radioactivity above permissible limits, whether or not the release resulted in property damage, personal injury, or known exposure.
(b) Any exceeding of the safety limit as defined in Section 2.1.
(c) Any reportable occurrence as defined in Section 6.5.2 of these specifications.
(3) A written report shall be submitted within 30 days to the NRC's Document Control Desk (if on paper, the signed original), with a copy to the appropriate Regional Office in accordance with 10CFR 50.4, of the following:
(a) Any substantial variance from performance specifications contained in these specifications or in the SAR, (b) Any significant change in the transient or accident analyses as described in the SAR, and (c) Changes in personnel serving as Director, Engineering Experiment Station, Reactor Director, or Reactor Associate Director.
(4) A report shall be submitted within nine months after initial criticality of the reactor or within 90 days of completion of the startup .test program, whichever is earlier, to the NRC's Document Control Desk (if on paper, the signed original),
with a copy to the appropriate Regional Office, upon receipt of a new facility license, an amendment to license authorizing an increase in power level or the installation of a new core of a different fuel element type or design than previously used.
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The report shall include the measured values of the operating conditions or characteristics of the reactor under the new conditions, and comparisons with predicted values, including the following:
(a) Total control rod reactivity worth, (b) Reactivity worth of the single control rod of highest reactivity worth, and (c) Minimum shutdown margin both at ambient and operating temperatures.
(d) Excess reactivity (e) Calibration of operating power levels Cf) Radiation leakage outside the biological shielding (g) Release of radioactive effluents to the unrestricted environment.
6.7 Records Records or logs of the items listed below shall be kept in a manner convenient for review, and shall be retained for as long as indicated.
6.7.1 Records to be Retained for a Period of at Least Five Years (C) normal plant operation, (2) principal maintenance activities, (3) experiments performed with the reactor, (4) reportable occurrences, (5) equipment and component surveillance activity, (6) facility radiation and contamination surveys, (7) transfer of radioactive material, (8) changes to operating procedures, and (9) minutes of Reactor Operations Committee meetings.
6.7.2 Records to be Retained for at Least One Requalification Cycle 39
Regarding retraining and requalification of licensed operations personnel, the records of the most recent complete requalification cycle shall be maintained at all times the individual is employed.
6.7.3 Records to be Retained for the Life of the Facility (1) gaseous and liquid radioactive effluents released to the environment, (2) fuel inventories and transfers (3) radiation exposures for all personnel, (4) changes to reactor systems, components, or equipment that may affect reactor safety, (5) updated, corrected, and as-built drawings of the facility.
(6) records of significant spills of radioactivity, andstatus, (7) annual operating reports provided to the NRC, (8) copies oT NRC inspection reports, and related correspondence 40