ML093521670
| ML093521670 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 12/23/2009 |
| From: | William Kennedy Research and Test Reactors Licensing Branch |
| To: | Bernard J Massachusetts Institute of Technology (MIT) |
| Kennedy W, NRR/ADRA/DPR/PRT, 415-2784 | |
| References | |
| TAC MA6084 | |
| Download: ML093521670 (10) | |
Text
December 23, 2009 Dr. John A. Bernard, Director Nuclear Reactor Laboratory Massachusetts Institute of Technology 138 Albany Street Cambridge, MA 02139-4296
SUBJECT:
MASSACHUSETTS INSTITUTE OF TECHNOLOGY, REQUEST FOR ADDITIONAL INFORMATION REGARDING THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY RESEARCH REACTOR LICENSE RENEWAL (TAC NO. MA6084)
Dear Dr. Bernard:
The U.S. Nuclear Regulatory Commission is continuing our review of your application for renewal of Facility Operating License No. R-37 for the Massachusetts Institute of Technology Research Reactor dated July 8, 1999, as supplemented by letters dated May 8, 2000, January 29, 2004, February 22, May 29, August 15, August 21, August 26, October 6, October 7, November 7, and December 1, 2008, and May 26, August 27, October 5, October 9, and November 19, 2009. During our review, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information no later than January 29, 2010. In accordance with Title 10 Code of Federal Regulations Section 50.30(b), your response must be executed in a signed original under oath or affirmation.
If you have any questions regarding this review, please contact me at 301-415-2784 or by electronic mail at William.Kennedy@nrc.gov.
Sincerely,
/RA by Alexander Adams For/
William B. Kennedy, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No.50-020
Enclosure:
As stated cc w/ enclosure: See next page
Massachusetts Institute of Technology Docket No.50-020 cc:
City Manager City Hall Cambridge, MA 02139 Department of Environmental Protection One Winter Street Boston, MA 02108 Director Radiation Control Program Department of Public Health 90 Washington Street Dorchester, MA 02121 Nuclear Preparedness Manager Massachusetts Emergency Management Agency 40 Worcester Road Framingham, MA 01702-5399 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611
December 23, 2009 Dr. John A. Bernard, Director Nuclear Reactor Laboratory Massachusetts Institute of Technology 138 Albany Street Cambridge, MA 02139-4296
SUBJECT:
MASSACHUSETTS INSTITUTE OF TECHNOLOGY, REQUEST FOR ADDITIONAL INFORMATION REGARDING THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY RESEARCH REACTOR LICENSE RENEWAL (TAC NO. MA6084)
Dear Dr. Bernard:
The U.S. Nuclear Regulatory Commission is continuing our review of your application for renewal of Facility Operating License No. R-37 for the Massachusetts Institute of Technology Research Reactor dated July 8, 1999, as supplemented by letters dated May 8, 2000, January 29, 2004, February 22, May 29, August 15, August 21, August 26, October 6, October 7, November 7, and December 1, 2008, and May 26, August 27, October 5, October 9, and November 19, 2009. During our review, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information no later than January 29, 2010. In accordance with Title 10 Code of Federal Regulations Section 50.30(b), your response must be executed in a signed original under oath or affirmation.
If you have any questions regarding this review, please contact me at 301-415-2784 or by electronic mail at William.Kennedy@nrc.gov.
Sincerely,
/RA by Alexander Adams For/
William B. Kennedy, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No.50-020
Enclosure:
As stated cc w/ enclosure: See next page DISTRIBUTION:
PUBLIC DPR/PRT r/f RidsNrrDpr RidsNrrDprPrta RidsNrrDprPrtb WKennedy, NRR Glappert, NRR ACCESSION NO.:ML093521670 Office PRTA:PM PRTA:LA PRTA:BC PRTA:PM Name WKennedy GLappert KBrock WKennedy (AAdams For) (KBrock For)
Date 12/22/09 12/22/2009 12/23/09 12/23/09 OFFICIAL RECORD COPY
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL FOR THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY REACTOR LICENSE NO. R-37 DOCKET NO.50-020 The following requests for additional information (RAI) pertain to the technical specifications (TS) proposed for the Massachusetts Institute of Technology (MIT) research reactor by letter dated October 5, 2009. Individual RAIs are labeled by TS number for ease of reference. The response to these RAIs should include a complete, revised copy of the TS.
TS 1 Chapter 1 of the proposed TS designates the MIT Research Reactor as the MITR-III. The TS also use the acronyms MITR and MITR-II, but do not define these acronyms. Define these acronyms when they are first used in the proposed TS. Revise the proposed TS in their entirety to use these acronyms consistently and appropriately.
TS 1.3 The proposed definitions for channel (1.3.1), channel calibration (1.3.2), channel check (1.3.3), containment (1.3.5), and protective action (1.3.23) differ from those given in the American National Standards Institute American Nuclear Society standard (ANSI/ANS) 15.1, 2007. Revise the definitions to be consistent with those in the standard, or explain the reasons for the differences.
TS 1.3.7 (1) Explain the meaning of the phrase, unless waived by MIT after evaluation, used in the first definition of damaged fuel. Clarify whether the waiver could allow operation of the reactor with fuel that does not meet the fabrication specifications, and if so, explain how the evaluation process ensures that operation with out-of-specification fuel is bounded by the analyses in the safety analysis report (SAR).
(2) The second definition of damaged fuel is based on an increase in fission product levels associated with a fuel element above the average background level for the core. Revise the definition to clarify where the increase in fission product levels is measured (e.g., the primary coolant or the space above the primary coolant). Explain the basis for the factor of five used to determine whether a fuel element is damaged. Discuss whether this factor is consistent with the action guideline for the core purge channel specified in TS 3.7.1.8.
TS 1.3.13 The definition uses the term MIT Committee on Reactor Safeguard. TS 7.2.1 uses the term MIT Reactor Safeguard Committee. Revise the definition or TS 7.2.1 to use consistent terminology.
TS 1.3.32 Section 6.7.2(1)(c)(v) of ANSI/ANS-15.1, 2007, includes abnormal and significant degradation of the coolant boundary and containment as events that should be covered by special reports. Revise the definition of reportable occurrence to include these events or explain how the proposed TS already address reporting of abnormal and significant degradation of the coolant boundary and containment.
TS 1.3.43 The second sentence of the definition of shutdown margin states, It should be assumed that the most reactive shim blade and the regulating rod are in their most reactive positions... Proposed TS 3.1.2 requires that the reactor can be made subcritical with the most reactive operable blade and the regulating rod fully withdrawn. Revise the definition of shutdown margin to be consistent with the requirement in TS 3.1.2.
TS 3.1.1 The proposed TS refers to moveable and non-secured samples. Revise the proposed TS to use terminology that is defined in the definitions section of the proposed TS (i.e., moveable and non-secured experiments).
TS 3.1.3 The wording of the proposed TS that refers to the state of the reactor when the specification shall be met is inconsistent with the wording used in other TS.
Specifically, the TS 3.1.3 uses the phrase critical reactor, whereas TS 3.1.4 uses the phrase, the reactor shall not be made critical unless. Clarify whether the two phrases are intended to be synonymous, and if so, revise the wording of TS 3.1.3 to be consistent with the other proposed TS.
TS 3.1.4.4(c) The specification lists events that require an evaluation to ensure that the items in TS 3.1.4.4(a) and (b) are satisfied. Given that item 4(a) includes power peaking considerations, provide a justification for not including change out of an absorber in the list, or include change out of an absorber in the list.
TS 3.2.1.2 Revise the proposed TS to include the state of the reactor when the specification shall be met (e.g., the reactor shall not be operated unless... or the reactor shall not be made critical unless...).
TS 3.2.2 (1) As appropriate, revise the individual specifications of the proposed TS to include the state of the reactor when the specification shall be met (e.g.,
the reactor shall not be operated unless... or the reactor shall not be made critical unless...).
(2) Provide clarification in the definitions section of TS 3.2.2 that the facility-specific definitions are only applicable to TS 3.2.2, or move the definitions to Section 1.3 of the proposed TS.
(3) TS 3.2.2.3, TS 3.2.2.4, and TS 3.2.2.5 regarding automatic control use the term automatic controller. Facility-specific definition 1 uses the term automatic control system. Revise the proposed TS to use consistent terminology.
TS 3.2.3 (1) TS 3.2.3.1 states that the reactor shall not be made critical unless the reactor protection system is operable in accordance with Table 3.2.3-1.
However, the basis for TS 3.2.3 states that the neutron flux level channels and period channels are required at all power levels including subcritical operation. Address this apparent discrepancy between the specification and the basis.
(2) Revise TS 3.2.3.3 to include the state of the reactor when the specification shall be met (e.g., the reactor shall not be operated unless... or the reactor shall not be made critical unless...).
TS 3.2.4 (1) Section 4.2.9 of ANSI/ANS-15.1, 2007, recommends annual surveillance of required interlocks. Provide surveillance requirements (in Chapter 4 of the proposed TS) for the interlocks required by TS 3.2.4 or provide justification for not requiring surveillance on these interlocks.
(2) Provide justification for not including any restriction on the maximum reactor power level during operation with the Subcritical Limit - Shim Blade Interlock bypassed. Alternately, revise the proposed TS to include a maximum allowed reactor power during operation with the interlock bypassed that ensures that power peaking in the fuel will not exceed that analyzed in the SAR.
TS 3.2.5 (1) Revise TS 3.2.3.5.1 to include the state of the reactor when the specification shall be met (e.g., the reactor shall not be operated unless... or the reactor shall not be made critical unless...).
(2) Section 4.2.9 of ANSI/ANS-15.1, 2007, recommends annual surveillance of required backup shutdown mechanisms. Provide surveillance requirements (in Chapter 4 of the proposed TS) for the D2O reflector dump or provide justification for not requiring any surveillance.
TS 3.3.4 Revise TS 3.3.4.2 to include the state of the reactor when the specification shall be met (e.g., the reactor shall not be operated unless... or the reactor shall not be made critical unless...).
TS 3.3.5 Revise TS 3.3.5.3 to specify the particular Title 10 Code of Federal Regulations (10 CFR) Part 20 limits referenced in the specification (e.g., 10 CFR 20 Appendix B, Table 3 limits for releases to sewers, or 10 CFR 20 Appendix B, Table 2 limits for water effluent concentrations).
TS 3.3.6 (1) TS 3.3.6.1 and TS 3.3.6.2 specify limits for the pH and conductivity of the primary coolant. As worded, these TS must always be met, except as provided by TS 3.3.6.3. Because TS 3.3.6.3 specifies that the reactor may be operated with the pH and conductivity outside the limits specified in TS 3.3.6.1 and TS 3.3.6.2, it is unclear whether the coolant quality limits must be satisfied when the reactor is not operating. Revise proposed TS 3.3.6 to eliminate this apparent discrepancy.
(2) TS 3.3.6.3(c) requires sampling of the coolant every eight hours if the coolant quality does not meet the limits specified in TS 3.3.6.1 and TS 3.3.6.2. Revise the proposed TS to specify what coolant properties shall be measured by the required sampling (e.g., pH, conductivity, and chloride ion concentration).
TS 3.4 TS 3.4.3 specifies the acceptable leakage rate for the containment building but does not specify when the leakage rate must be maintained (e.g., when containment integrity is required to be maintained by TS 3.4.1). Revise the proposed TS to include this information. Additionally, revise TS 3.4.4 and TS 3.4.5 to include similar information, unless the intent is that these specifications shall always be met.
TS 3.5 (1) Revise the objective of the proposed TS to include the specific 10 CFR requirements that are intended to be met by the proposed TS.
(2) TS 3.5.1 requires a minimum flow rate through the containment building stack whenever the reactor is operating at power levels in excess of 250 kW, but does not require that the ventilation system be operating or operable in accordance with TS 3.5.4. Revise TS 3.5.1 to require that the ventilation system be operating when the reactor is operating at power levels in excess of 250 kW, or provide justification for not requiring operation of the ventilation system.
(3) TS 3.5.3 requires that containment building differential pressure be negative by at least 0.1 inch of water prior to reactor startup. TS 3.5.4(b) requires that auxiliary fans be operable to maintain building differential pressure, if needed. The basis for TS 3.5 states that it is intended to operate the reactor with a negative containment building differential pressure. However, TS 3.5 does not specify any requirement for building differential pressure during reactor operation. Revise the proposed TS to include any restrictions on building differential pressure during reactor operation or provide justification for not including such restrictions.
TS 3.7.1 (1) TS 3.7.1.1 requires a continuous air monitor to be operable whenever the reactor building is occupied, but Chapter 4 of the proposed TS does not contain any surveillance requirements for the monitor. Provide surveillance requirements (in Chapter 4 of the proposed TS) for the air monitor required by TS 3.7.1.1 or provide justification for not requiring surveillance on the air monitor.
(2) TS 3.7.1.3 requires an instrument capable of detecting fission products to monitor the purge gas drawn from above the primary coolant, but Chapter 4 of the proposed TS does not contain any surveillance requirements for the instrument. Provide surveillance requirements (in Chapter 4 of the proposed TS) for the instrument required by TS 3.7.1.3 or provide justification for not requiring surveillance on the instrument.
TS 3.7.2 The proposed TS references an exemption to the provisions of 10 CFR Part 20 related to the use of a dilution factor for airborne effluents. 10 CFR 20.1101(d) and 10 CFR 20.1302(b)(1) do not preclude the use of dilution factors when calculating the dose expected to be received by the maximally-exposed member of the public. Additionally, the use of a dilution factor is consistent with NUREG-1537, Guidelines for Preparing and Reviewing Applications for the licensing of Non-Power Reactors. Accordingly, revise the proposed TS to eliminate the reference to an exemption from 10 CFR Part 20 requirements.
TS 3.7.3 Clarify whether the interlock required by proposed TS 3.7.3(b) precludes restarting the hot cell blower when the main ventilation system blower or dampers are shut down. If not, describe the controls or requirements in place that ensure that the hot cell blower will not be restarted under these conditions.
TS 3.7.4 The proposed TS specifies that certain types and quantities of byproduct material can be received for the purpose of materials studies. Clarify whether the material studies may involve irradiating the byproduct material in the reactor.
TS 4 Chapter 4 of ANSI/ANS-15.1, 2007, recommends specifying if surveillance activities can be deferred during reactor shutdown. Consider revising Chapter 4 of the proposed TS to specify which surveillance requirements can be deferred during reactor shutdown, and of those that can be deferred, which shall be performed prior to reactor operations. Each revision must be fully justified.
TS 4.2 (1) TS 4.2.1 states that calculations or measurements of the reactivity worth of control devices shall be made upon significant changes in core configuration. Revise the proposed TS to define the changes that constitute a significant change in core configuration (e.g., a change that requires an evaluation per proposed TS 3.1.4(c)).
(2) TS 4.2.5 requires operability tests of instruments or channels listed in Table 4.2-1 of the proposed TS following modifications or repairs. The term operability test is not defined in the proposed TS. Include a definition of operability test or revise the proposed TS to use terminology already defined (e.g., channel test, channel check, or channel calibration).
(3) TS 4.2 does not contain surveillance requirements for control system interlocks or backup shutdown mechanisms. Propose surveillance requirements for control system interlocks and backup shutdown mechanisms or provide justification for not requiring such surveillances.
(See RAI TS 3.2.4 and RAI TS 3.2.5.)
(4) Table 4.2-1, column 2, labeled surveillance, uses the undefined terms scram test, major scram test, and operational test. Revise the terminology to use terms already defined in the proposed TS, or add definitions of the undefined terms. Also, the surveillance for the fission converter specified in the table is as specified in fission converter SER.
Revise this surveillance to reference the appropriate TS related to fission converter surveillances.
TS 4.3.5 Given the importance placed on the chloride ion concentration in TS 3.3.6, revise TS 4.3.5 to include the chloride ion concentration in the list of coolant properties that shall be measured when the coolant quality is out of specification.
Alternately, provide justification for not requiring measurement of the chloride ion concentration.
TS 4.4.7 The table uses the undefined term scram test. Define this term or use a term that is already defined in the proposed TS. (See RAI TS 4.2.)
TS 4.5.2 (1) The table uses the undefined term operation test. Define this term or use a term that is already defined in the proposed TS. (See RAI TS 4.2.)
(2) The table does not include a surveillance requirement for the interlock of the hot cell blower with the containment building exhaust system blower required by TS 3.7.3. Revise the proposed TS to include a surveillance requirement for the interlock or provide justification for not requiring surveillance on the interlock.
TS 4.7.1 The proposed TS does not contain surveillance requirements for the core purge, sewer, or continuous air monitor radiation monitors required by TS 3.7.1. Revise TS 4.7.1 to include surveillance requirements for these monitors or provide justification for not requiring surveillance on these monitors.
TS 5.3.1 The proposed TS states that local regions of the clad shall not be less than 0.008 inches thick. The basis for the TS indicates that the clad will adequately prevent the release of fission products if the uniform clad thickness is greater than 0.008 inches. Revise the proposed TS or the basis to resolve this apparent discrepancy.
TS 6.1.4(c) The proposed TS states that irradiation capsules may be vented provided that the vented release is less than 10.0 percent of the limit in 10 CFR Part 20. Table 6.1-1, footnote c of the proposed TS states that irradiation capsules may be vented, provide that the vented release is less than 1.0 percent of the limit in 10 CFR Part 20. Revise the proposed TS to eliminate this apparent discrepancy.
TS 6.5.12 The table uses the undefined terms scram test and operational test. Define these terms or use terms that are already defined in the proposed TS.
TS 7.3.1 Revise the proposed TS to eliminate the reference to exceptions to the requirements of 10 CFR Part 20 given in TS 3.7.2. (See RAI TS 3.7.2)
TS 7.3.3 The proposed TS states that the Reactor Radiation Protection Officer has the authority to interdict or terminate activities that may compromise safety.
TS 7.1.2.6 states that the course determined by the Director of Reactor Operations to be more conservative shall be followed. Revise the proposed TS
to resolve this apparent discrepancy. Additionally, correct the reference to TS 7.1.2.5 in the proposed TS.
TS 7.4.3 ANSI/ANS-15.1, 2007, recommends that procedures be established for the use, receipt, and transfer of byproduct material. If these activities are carried out under the reactor license, revise the proposed TS to include requirements for procedures for use, receipt, and transfer of byproduct material or provide justification for not requiring such procedures.
TS 7.6.1(e) The proposed specification states that in the case of a safety limit violation, actions required by TS 7.6.2 shall be taken. However, some actions required by TS 7.6.2 are inconsistent with or redundant to those already required by TS 7.6.1. Revise the proposed TS to clarify the specific additional actions that are required in the case of a safety limit violation.
TS 7.6.2(a) The proposed TS requires the reactor to be shut down in the event of a reportable occurrence unless the occurrence has no immediate safety significance to the reactor. Reportable occurrences defined in Section 1.3 of the proposed TS include operation in violation of a limiting condition for operation.
Given that some limiting conditions for operation may impact the safety of reactor personnel or the public without necessarily impacting reactor safety, justify not requiring the reactor to be shut down if a reportable occurrence has an immediate impact on the safety of reactor personnel or the public. Alternately, revise the proposed TS to require the reactor to be shut down if the reportable occurrence has an immediate impact on the safety of reactor personnel or the public.
TS 7.7.2.1 Revise the proposed TS to specify that reports shall be made to the U.S. Nuclear Regulatory Commission Headquarters Operations Center.
TS 7.8.3(f) Regulation 10 CFR 50.36 requires that records of the results of each review of exceeding the safety limit, the automatic safety system not functioning as required by the limiting safety system settings, or any limiting condition for operation not being met be retained by the licensee until the Commission terminates the license for the facility. Accordingly, revise the proposed TS to include these additional records retention requirements.