ML101320069
| ML101320069 | |
| Person / Time | |
|---|---|
| Site: | Rhode Island Atomic Energy Commission |
| Issue date: | 05/04/2010 |
| From: | Mecca S State of RI, Atomic Energy Comm, Nuclear Science Ctr |
| To: | Jaczko G NRC/Chairman |
| Kennedy W, NRR/DPR, 415-2784 | |
| References | |
| CORR-10-0053, EDATS: SECY-2010-0263, G20100292, LTR-10-0213, SECY-2010-0263 | |
| Download: ML101320069 (7) | |
Text
EDATS Number: SECY-2010-0263 Source: SECY Geerl norato Assigned To: NRR OEDO Due Date: 6/2/2010 11:00 PM Other Assignees:
SECY Due Date: NONE
Subject:
Request for Meeting on the License Renewal of the Rhode Island Nuclear Science Center Research Reactor
==
Description:==
CC Routing: Regionl; OGC ADAMS Accession Numbers -
Incoming: NONE Response/Package: NONE IOhe Ifra t~io I
Cross Reference Number: G20100292, LTR-10-0213 Related Task:
File Routing: EDATS Staff Initiated: NO Recurring Item: NO Agency Lesson Learned: NO OEDO Monthly Report Item: NO I
Prcs Inomto I
Action Type: Letter Signature Level: NRR Approval Level: No Approval Required OEDO Concurrence: NO OCM Concurrence: NO OCA Concurrence: NO Special Instructions:
Priority: Medium Sensitivity: None Urgency: NO Originator Name: Stephen Mecca Date of Incoming: 5/4/2010 Originating Organization: Rhode Island Atomic Energy Document Received by SECY Date: 5/11/2010 Commission Addressee: Chairman Jaczko Date Response Requested by Originator: NONE Incoming Task Received: Letter Page 1 of I
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: May 10, 2010 17:36 PAPER NUMBER:
ACTION OFFICE: 213.,~h dq s$t~ t LOGGING DATE: 05/10/2010 AUTHOR:
AFFILIATION:
ADDRESSEE:
Dr. Stephen Mecca RI CHRM Gregory Jaczko
SUBJECT:
Request for a meeting with Commissioners to discuss concerns regarding the license renewal of the Rhode Island Nuclear Science Center (RINSC) research reactor ACTION:
DISTRIBUTION:
LETTER DATE:
ACKNOWLEDGED SPECIAL HANDLING:
NOTES:
FILE LOCATION:
Appropriate Chrm, Comrs, EDO, OGC, SECY (R.Bavol), RF 05/04/2010 No' ADAMS DATE DUE:
DATE SIGNED:
EDO -- G20100292
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS 4RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 May 4, 2010 Chairman Gregory B. Jaczko United States Nuclear Regulatory Commnission Washington, D.C. 20555-0001
Dear Chairman Jaczko:
This letter concerns the license renewal of the Rhode Island Nuclear Science Center (RINSC) research reactor by your agency. The Commissioners of the Rhode Island Atomic Energy Commission have been in discussions with your staff regarding the re4uiremnents of the review process.::The. review process for. license-renewal of research reactors -is*not well :defined and;, by default,.parallels!an initial licensing -effort.- The level of-effort by-.the-NRC. and :the -RtNSC-to--complete a,, second initial licensing <is unreasonable given-that the reactor has-been-safely operating for 50 years, most. recently Under revised Technical Specifications that were reviewed and approved by the NRC during its fuel conversion effort in 1993, and that the facility is subject to continual NRC inspection. When compared to power reactors, whose source term is considerably larger, their license renewals are -focused on age related degradation. which is the important regulatory and safety matter for license renewals.
Additionally, the present funding and staffing levels of research reactors of the size of RINSC are small and are focused on safe operation of the reactor. To remove them from those duties, given the 60 day turn-around demanded by the Request for Additional Information dated April 13, 2010 and the quantity of questions focused on initial licensing type instead of age related degradation questions will divert the staff from their first priority of safe operation. The small technical staff will not have time to give adequate attention to the routine regulatory requirements that are needed to operate the reactor, as they will be totally involved, in meeting an arbitrary time constraint of two months for submittal of answers even after, the. Nuclear-. Regulatory Commission has had the -*application
- :.for. -.-.over:- six "years,..,The RINSC - staff that.ompleted the renewal lpplication has' since.; retired: and the current': staff will-require time to-get up.-o speed on the technical is'sues required.to-answer.the,massive number of:comments in the subject Relueist for 'Additional Information
We believe that the NRC staff policy of a default license renewal process for research reactors the size of the RINSC requiring an extensive "initial license" review creates an excessive regulatory burden that is not risk informed or necessary to assure safety of the facility for extended operation. This is supported by the renewal process for power reactors that is limited to effects on aging of systems, structures and components, and aging management programs to ensure ongoing safety is maintained. As with power reactors, the focus of the license renewal for research reactors should be on age related items as the facility is almost sixty years old. The review should start from the last NRC approved Safety Analysis Report and technical specifications, not as if it had never been safely operated which is the current approach.
RINSC converted to Low Enriched Uranium fuel in 1993. As part of the conversion order, an extensive Safety Analysis was conducted for the new compact core design. The NRC approved a new Safety Analysis after a multi-year extensive review. New technical Specifications were completed to comply with ANSI/ANS 15.1-1990, The Development of Technical Specification for Research Reactors. These technical specifications were reviewed by the NRC and approved.
The sixty. pages of questions in the current RAI do not focus on aging issues. A significant amount of information is requested questioning the initial General Electric Safety Analysis report. This report is more than 50 years old and the supporting studies will be extremely hard to find. The safety basis of the reactor is found in the operation of the reactor, is tested daily and is reinforced in the reactor's simplicity and fundamental robustness of the reactor design. The technical specification questions are broad and far-reaching and give no credit to the fact that the current version has been in effect for over 15 years with only one issue from NRC inspectors that was quickly resolved. Many of the RAI questions also appear to be more appropriate to Triga reactors and other questions strongly imply back fit will be needed to comply with no subsequent regulatory back fit analysis. Some questions imply new requirements when it is evident that the current situation is adequate from a safety perspective.
We had the NRC questions reviewed by a reputable nuclear contractor who gave us an estimate of $300,000 to provide the necessary response. That figure is three times the facility operating budget. We request the NRC staff review these questions from an age related license renewal perspective and focus on safety issues important to age related degradation rather than a full technical "initial licensing" review. This is essential for RINSC to continue its excellent safety record and contribution to the nuclear research this country has enjoyed over the last 60 years.
Given the seriousness of this issue that threatens the continued viability of this important teaching and research asset to the. state of Rhode Island, the Commissioners of the Rhode.
Island Atomic Energy Commission request a meeting with the NRC Commissioners to discuss this matter as soon as possible.
truly yours, Stephen Mecca, Ph.D., Chairman Rhode Island Atomic Energy Commission Copy to: Governor Donald L. Carcieri Senator Jack Reed Senator Sheldon Whitehouse Commissioner Svinicki Commissioner Apostolakis Commissioner Magwood Commissioner Ostendorff
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 015H14113623 l
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$0.44 05/04/10 Mailed Fro'm 02882 Chairman Gregory B. Jaczko US Nuclear Regulatory Commission Washington, D.C. 20555-0001