ML101170597
| ML101170597 | |
| Person / Time | |
|---|---|
| Site: | Rensselaer Polytechnic Institute |
| Issue date: | 05/05/2010 |
| From: | William Kennedy Research and Test Reactors Licensing Branch |
| To: | Trumbull T Rensselaer Polytechnic Institute |
| Kennedy W, NRR/ADRA/DPR/PRT, 415-2784 | |
| References | |
| TAC ME1591 | |
| Download: ML101170597 (6) | |
Text
May 5, 2010 Mr. Timothy Trumbull, Director Reactor Critical Facility Nuclear Engineering and Science Building Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12180
SUBJECT:
RENSSELAER POLYTECHNIC INSTITUTE, REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL OF FACILITY OPERATING LICENSE (TAC NO. ME1591)
Dear Mr. Trumbull:
The U.S. Nuclear Regulatory Commission (NRC) is continuing the review of your application for renewal of Facility Operating License No. CX-22, Docket No. 50-225 for the Rensselaer Polytechnic Institute Reactor Critical Facility dated November 19, 2002, as supplemented on July 28, and September 3, 2008. During our review, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 45 days of the date of this letter. In accordance with Title 10 of the 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 Duane A. Hardesty for/
William B. Kennedy, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-225 License No. CX-22
Enclosure:
Request for Additional Information cc w/encl: See next page
Rensselaer Polytechnic Institute Docket No. 50-225 Reactor Critical Facility cc:
Mayor of the City of Schenectady Test, Research, and Training Schenectady, NY 12305 Reactor Newsletter University of Florida Tim Rice 202 Nuclear Sciences Center Chief, Radiation Section Gainesville, FL 32611 Division of Hazardous Waste and Radiation Management NY State Dept. of Environmental Conservation 625 Broadway Albany, NY 12233-7255 Peter F. Caracappa, Ph.D, CHP Radiation Safety Officer NES Building, Room 1-10, MANE Department Rensselaer Polytechnic Institute 110 8th St.
Troy, NY 12180-3590 Mrs. Jessica Berry, RCF Supervisor NES Building, Room 1-10, MANE Department Rensselaer Polytechnic Institute 110 8th St.
Troy, NY 12180 Peter Collopy, Director EH&S Rensselaer Polytechnic Institute 21 Union Street Gurley Building 2nd Floor Troy, NY 12180 Alyse Peterson, State Liaison Officer Designee Senior Project Manager Radioactive Waste Policy and Nuclear Coordination New York State Energy Research &
Development Authority 17 Columbia Circle Albany, NY 12203-6399
May 5, 2010 Mr. Timothy Trumbull, Director Reactor Critical Facility Nuclear Engineering and Science Building Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12180
SUBJECT:
RENSSELAER POLYTECHNIC INSTITUTE, REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL OF FACILITY OPERATING LICENSE (TAC NO. ME1591)
Dear Mr. Trumbull:
The U.S. Nuclear Regulatory Commission (NRC) is continuing the review of your application for renewal of Facility Operating License No. CX-22, Docket No. 50-225 for the Rensselaer Polytechnic Institute Reactor Critical Facility dated November 19, 2002, as supplemented on July 28, and September 3, 2008. During our review, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 45 days of the date of this letter. In accordance with Title 10 of the 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 Duane A. Hardesty for/
William B. Kennedy, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-225 License No. CX-22
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC DPR/PRT r/f RidsNrrDpr RidsNrrDprPrlb RidsNrrDprProb WKennedy, NRR GLappert, NRR STraiforos, NRR ACCESSION NO.:ML101170597 Office PRLB:PM PRPB:LA PRLB:BC PRLB:PM Name WKennedy GLappert KBrock WKennedy (DHardesty for)
Date 4/30/2010 5/3/2010 5/3/2010 5/5/2010 OFFICIAL RECORD COPY
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING FACILITY OPERATING LICENSE RENEWAL FOR RENSSELAER POLYTECHNIC INSTITUTE REACTOR CRITICAL FACILITY LICENSE NO. CX-22 DOCKET NO. 50-225 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, contains the requirements for proposed technical specifications (TS) submitted as part of a license application. Important general requirements in 10 CFR 50.36 include:
Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section (10 CFR 50.36).
A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.
The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to 10 CFR 50.34.
Regulation 10 CFR 50.36(c) states that technical specifications will include safety limits (SL),
limiting safety system settings (LSSS), limiting conditions for operation (LCO), surveillance requirements, design features, and administrative controls.
In regard to SLs, 10 CFR 50.36(c)(1)(i)(A) states:
Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity.
In regard to LSSS, 10 CFR 50.36(c)(1)(ii)(A) states:
Limiting safety system settings for nuclear reactors are 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 must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded.
ENCLOSURE
In regard to LCOs, 10 CFR 50.36(c)(2) states:
(i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility.
(ii) A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of [four criteria specified by 10 CFR 50.36(c)(2)(ii)(A), (B), (C), and (D)]
In regard to surveillance requirements, 10 CFR 50.36(c)(3) states:
Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
In regard to design features, 10 CFR 50.36(c)(4) states:
Design features to be included are those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in
[10 CFR 50.36(c)(1), (2), and (3)].
In regard to administrative controls, 10 CFR 50.36(c)(5) states:
Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
American National Standards Institute/American Nuclear Society standard ANSI/ANS-15.1, 2007, Development of Technical Specifications for Research Reactors, (ANSI/ANS-15.1) and NUREG-1537 (Part 1 and 2), Guidance for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, provide guidance for satisfying the requirements of 10 CFR 50.36.
The following requests for additional information (RAIs) are related to the proposed technical specifications (TS) submitted by letter dated July 28, 2008, for the Rensselaer Polytechnic Institute (RPI) Critical Experiments Facility (RCF). In responding to the following RAIs, provide a response to each individual RAI, including any revised wording of the proposed TS. A complete set of revised proposed TS that incorporate any changes made as a result of the responses to these RAIs will be required by a future letter. Although Limited Safety Systems Settings, Surveillance Requirements, and Administrative Control regulations are referenced above, these topics will be addressed under a separate request for additional information.
- 1. Provide a table of contents for the proposed TS.
- 2. TS 1.3 contains definitions that do not appear to be used in the proposed TS. Examples include certificate or charter, certified, Class A reactor operator, Class B reactor
operator, facility-specific definitions, licensed, licensee, owner or operator, permit, research reactor, research reactor facility, responsible authority, and supervisory reactor operator. Explain the reason for including these definitions, and revise the proposed TS as appropriate.
- 3. The proposed TS use the terms on the bottom, bottomed, inserted, and fully inserted to describe the positions of the control rods. Clarify whether these terms are synonymous, and revise the proposed TS to use consistent terminology as appropriate.
- 4. The wording of the definitions of reactor operator, research reactor, and research reactor facility are not specific to the RCF. Explain the reasons for not making these definitions specific to the RCF, and revise the definitions as appropriate.
- 5. The proposed TS do not appear to contain requirements for reporting SL violations as required by 10 CFR 50.36(c)(1)(i)(A). In accordance with the regulation, propose TS for reporting SL violations. (See RAI 8)
- 6. The definition of reportable occurrences, item 4., states that, Operation in violation of limiting conditions for operation unless prompt remedial action is taken, is reportable.
The use of the phrase, unless prompt remedial action is taken, is inconsistent with the requirement of 10 CFR 50.36(c)(2)(i) that, When a limiting condition for operation of a nuclear reactor is not met,... the licensee shall notify the Commission. Revise the definition to be consistent with the regulatory requirement.
- 7. The definition of shutdown margin states that the nonscramable rods are assumed to be in their most reactive position. The safety analysis report does not describe any nonscramable rods. Clarify whether the RPI RCF has any nonscramable rods, and revise the proposed TS as appropriate.
- 8. The proposed TS do not contain a SL for the RPI RCF. According to 10 CFR 50.36(c),
technical specifications will include... safety limits. In accordance with the regulation, propose SLs for the RPI RCF derived from appropriate analyses in the safety analysis report.
- 9. TS 3.9 contains facility-specific limiting conditions for operation, but does not contain bases. In accordance with 10 CFR 50.36(a)(1), provide bases for the proposed TS.
(Consider also including Applicability and Objective statements consistent with the formatting of ANS/ANSI-15.1.)
- 10. In accordance with 10 CFR 50.36(a), provide bases for the specifications in Section 5 of the proposed TS.