ML102230338

University of Maryland Training Reactor, Request for Additional Information Regarding License Renewal Revised Technical Specifications Dated December 18, 2006 (Tac No. ME1592)

ML102230338
Person / Time
Site:	University of Maryland
Issue date:	08/20/2010
From:	Alexander Adams Research and Test Reactors Licensing Branch
To:	Al-Sheikhly M Univ of Maryland
Traiforos S, NRR/PRPB, 301-415-3965
References
TAC ME1592
Download: ML102230338 (8)

Text

August 20, 2010 Dr. Mohamad Al-Sheikhly, Professor and Director Radiation Facilities and Nuclear Reactor Chemical and Nuclear Engineering Building 090 University of Maryland College Park, MD 20742

SUBJECT:

UNIVERSITY OF MARYLAND - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL FOR THE MARYLAND UNIVERSITY TRAINING REACTOR (TAC NO. ME1592)

Dear Dr. Al-Sheikhly:

We are continuing our review of the Application for Renewal of Facility Operating License No. R-70, Docket No. 50-166 for the University of Maryland. The application was submitted on May 12, 2000 as supplemented by letter dated December 18, 2006 to include revised technical specifications.

During our review of the proposed Technical Specifications, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 30 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. Following receipt of the requested information, we will continue our evaluation of your application.

If you have any questions regarding this matter, please contact Spyros A. Traiforos at 301-415-3965 or via email at Spyros.Traiforos@nrc.gov or myself at 301-415-1127 or via email at Alexander.Adams@nrc.gov.

Sincerely,

/RA/

Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-166

Enclosure:

As stated cc w/encl: See next page

University of Maryland Docket No. 50-166 cc:

Director, Dept. of Natural Resources Power Plant Siting Program Energy & Coastal Zone Administration Tawes State Office Building Annapolis, MD 21401 Mr. Roland G. Fletcher, Program Manager IV Radiological Health Program Maryland Department of Environment 1800 Washington Blvd., Suite 750 Baltimore, MD 21230 Mr. Vincent G. Adams Facility Coordinator Chemical and Nuclear Engineering Building 090 University of Maryland College Park, MD 20742 Tom OBrien Radiation Safety Officer Department of Environmental Safety 3115 Chesapeake Building 338 University of Maryland College Park, MD 20742 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML102230338 NRR-088 OFFICE PRPB:PM PRLB:PM PRPB:LA PRLB:BC PRLB:PM NAME STraiforos AAdams GLappert JQuichocho AAdams DATE 8/17/2010 8/18/2010 8/17/2010 8/20/2010 8/20/2010

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION MARYLAND UNIVERSITY TRAINING REACTOR LICENSE NO. R-70; DOCKET NO. 50-166 We are continuing our review of the Application for Renewal of Facility Operating License No.

R-70, Docket No. 50-166 for the University of Maryland (UMD). The application was submitted on May 12, 2000, as supplemented by letter dated December 18, 2006, to include revised technical specifications (TS).

During our review of the revised proposed TS, questions have arisen for which we require additional information and clarification.

NUREG-1537, Part 1, states that the format and content of the technical specifications (TSs) discussed in Appendix 14.1 follow the format of the 1990 revision of the American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1, The Development of Technical Specifications for Research Reactors. The current version of the standard is dated 2007 (ANSI/ANS-15.1-2007). The basis for the questions below is the 2007 version of the standard with applicable modifications based on NUREG-1537.

1.

TS 1.0. Definitions: ANSI/ANS-15.1-2007, Section 1 provides definitions for key terminology utilized in TSs. Please include definitions of Core Configuration, and Shall, Should, and May, in Maryland University Training Reactor (MUTR) TS 1.0 Definitions, or provide a basis for not defining these terms.

2.

TS 1.0, Definitions: ANSI/ANS-15.1-2007, Section 1 defines key terminology. Please evaluate MUTR TS against the standard definitions in ANSI/ANS-15.1-2007 for the below listed TS items. Propose changes to meet ANSI/ANS-15.1-2007 or justify your definitions:

a.

TS 1.1 - in this part should refer to in 10 CFR Part 20

b.

TS 1.3 - if your confinement is designed to limit release of effluents, this needs to be included in your definition

c.

TS 1.4 - reactivity control devices should be replaced with control rods

d.

TS 1.8 - use either fuel element or fuel rod terminology consistently in the TSs

e.

TS 1.22 - U. S. Nuclear Regulatory Commission (NRC) licenses operators, we do not certify operators, please update to reflect NRC terminology

f.

TS 1.24.d - replace the maximum value allowed for a single experiment, or one dollar, whichever is smaller with the smaller of the two reactivity values

g.

TS 1.25 - The NRC staff has proposed modifications to the definition for reactor shutdown given in ANSI/ANS-15.1-2007 as follows:

The reactor is shut down if it is subcritical by at least one dollar in the reference core condition with the reactivity worth of all installed experiments included and the following conditions exist:

(a)

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; (b)

No experiments are being moved or serviced that have, on movement, a reactivity worth exceeding the maximum value allowed for a single experiment, or one dollar, whichever is smaller.

Please adopt the NRC-modified definition or discuss why your proposed definition continues to be acceptable.

h.

TS 1.27 - conform to Section 6.7.2(1)(c) of ANSI/ANS 15.1-2007; remove which occurs during reactor operation.

i.

TS 1.27(3) - remove or periods of reactor shutdown

j.

TS 1.27(5) - change containment to confinement

k.

TS 1.27(5) - remove exceeding prescribed radiation exposure limits.

l.

TS 1.28: The definition of Rod-Control should match what physically exists at the UMTR facility.

m.

TS 1.34: NRC licenses operators, we do not certify operators, please update to reflect NRC terminology.

3.

TS 3.1.2: ANSI/ANS-15.1-2007, Section 3.1(2) provides guidance for establishing a Limiting Condition for Operation (LCO) for shutdown margin. In MUTR TS 3.1.2, the LCO specifies that the shutdown margin shall not be less than $0.50. Please discuss whether the following conditions should also be specified for the measurement of shutdown margin

a.

Reference core condition,

b.

Non-secured experiments in their most reactive state,

c.

Most reactive control rod being withdrawn Please discuss how TS 3.1.2 should be revised to determine the shutdown margin under the most limiting conditions or justify why these conditions are not needed.

4.

TS 3.1.4: Please define fuel damage. ANSI/ANS-15.1-2007, Section 3.1(6) indicates that limits shall be established for fuel inspections. Please discuss how MUTR inspects fuel elements and under which conditions is fuel considered damaged.

5.

TS 3.2: The applicability statement of the TS needs to be labeled. Minimum channels needed for operation appear to be missing from the TS. Please address. In Table 3.2 clarify the log power level and explain the interlock.

6.

TS 3.3: ANSI/ANS-15.1-2007, Section 3.3(9) indicates that limits shall be established for water chemistry requirements. MUTR TS 4.3.5 includes pH and conductivity values, which are considered LCO limits and should be moved to TS 3.3. Please discuss whether the LCO conditions in TS 4.3.5 should be placed in TS 3.3 and also include an LCO for gross gamma measurements or justify why it is not needed. Should an LCO be established for maximum pool water temperature? The numbering of the water (coolant) specifications and their bases should be made consistent.

7.

TS 3.3.2: Should this be part of the radiation protection TSs in section 3.6? Please move or justify the continued placement of this information in TS 3.3.2.

8.

TS 3.4 or 3.5: ANSI/ANS-15.1-2007, Section 3.4 provides guidance for the operations which require confinement and the equipment required to establish confinement. Please discuss whether any equipment, such as the ventilation system is required for confinement. The objective is stated as ensuring that sufficient confinement volume is available for the dilution of radioactive releases. Is this the only purpose of the confinement? There is no reference to the need for controlled air flow and discharge.

Please explain. The bases state that the release conditions are similar to these assumed in the safety analysis report (SAR). Please explain.

9.

TS 3.4.1: ANSI/ANS-15.1-2007, Section 3.4 provides guidance for the operations and equipment required to establish confinement while Section 5 includes design features related to the site and facility. Please discuss whether TS 3.4.1 is a facility design feature that should be included in Section 5 or justify your placement.

10.

TS 3.4.2: The description of the confinement does not address limiting the release of effluents and the need for controlled air flow. Please explain. See request for additional information 2.b.

11.

TS 3.4.3: Explain whether establishing confinement is a requirement. If it is, must should be replaced by shall. Please review your proposed TSs in their entirety to ensure that requirements are shall statements.

12.

TS 3.5.1: Does this TS mean that the reactor confinement is airtight? If not, please explain airflow pathways to the atmosphere during operation and emergency conditions.

Please revise the TS to reflect the operation of the system.

13.

TS 3.5.3: Explain the automatic operation of securing the forced air ventilation.

Securing is interpreted as turning off the fans and other components. What are the preset radiation levels for securing ventilation? How are facility personnel protected by securing the forced air ventilation?

14.

TS 3.6.1 and Table 3.5: ANSI/ANS-15.1-2007, Section 3.7 provides guidance for the radiation monitoring system. TS 3.6.1 appears to require both monitors to be in operation but Table 3.5 seems to say only 1 of the 2 is needed. Please clarify the number of radiation monitors required for operation.

15.

TS 3.6.3. The NRC staff agrees that specific alarm set points (e.g., 1,500 cpm) need not be TSs because of the potential for the value to change with equipment aging or maintenance. However, the bases for the alarm should be TS specifications. Please add alarm set point bases to the TSs or discuss why they are not needed.

16.

TS 3.7: Why does TS 3.7 have six specifications and seven bases? The numbering of specifications and bases should be made consistent.

17.

TS 3.7.3: Failure of experiments that release materials may damage reactor fuel or structural components. Physical inspection would allow a determination if damage occurred and necessary corrective actions. Please propose TS changes to require reactor structural and component inspection on experiment failure or justify why it is not needed.

18.

TS 3.7.4: This specification states in part that explosive materials in quantities less than 25 mg TNT may be irradiated provided the pressure produced upon detonation of the explosive has been calculated and/or experimentally demonstrated to be less than the design pressure of the containment. Section 10.3 of the UMTR SAR states that calculations must show that the pressure produced if detonation occurs is less than the failure pressure of the container. Since the container design pressure should have a safety factor of two (Regulatory Guide 2.2), the failure pressure should be half the design pressure. Therefore, TS 3.7.4 should be modified accordingly. Moreover, there are no example calculations in the SAR comparing the detonation pressure to the failure pressure. Please provide an example calculation for a container that demonstrates compliance with the factor of 2 margin or justify not including a calculation in the SAR.

19.

TS 3.7.5: The occupational dose is addressed. However, the dose to the public is not addressed. Please explain.

20.

TS 4.0: General surveillance requirements for actions after system or component modifications, replacement or maintenance are not clearly defined. Please propose TS changes addressing the requirements for system testing after modifications, replacement or maintenance or justify why it is not needed.

21.

TS 4.1: ANSI/ANS-15.1-2007, Section 4.1 provides guidance for surveillance requirements for core configuration changes. Please propose TS changes to include a surveillance requirement addressing TS 3.1.3 and TS 3.1.5, which contain LCOs related to core and fuel configuration or justify why there is no need for such TS requirements.

22.

TS 4.2: There does not appear to be a LCO for TSs 4.2.7 and 4.2.8 requiring 3 operable control rods. Please add an LCO or explain why it is not needed.

23.

TS 4.2.4. The TS refers to the calibration of scram channels. There appears to be no calibration required for the instrumented fuel element which measures fuel temperatures.

Please add a surveillance requirement or explain why it is not needed.

24.

TS 4.3: The numbering of water (coolant) specifications and bases should be made consistent. For example there is no specification 4.3.3. It appears that specification 4.3.3 has been numbered 4.3.4. Please verify. See also related comments in TS 3.3.

25.

TS 4.3.1: Pool gross gamma activity is measured. However, there is no LCO as to what is acceptable. Explain why an LCO is not needed or establish one. Provide a justification for the frequency of measuring the gross gamma activity. Discuss the need for a more detailed measurement of pool water activity by isotope.

26.

TS 4.4: It is not clear what isolation means. Please define. Does it mean closing of doors, louvers to the outside, etc? What is the operating status of fans, isolation valves, and other components?

27.

TS 4.5: If the ventilation system is required to establish confinement including its operability as per TS 3.4 and TS 3.5, then verification of its operation is also required.

Please propose a TS change to address the surveillance and operability requirements of the ventilation system or justify why it is not needed.

28.

TS 4.6.1 states The objective of these specifications is to ensure operability of each radiation area monitoring channel as required by section 3.4 The radiation monitoring system is addressed in Section 3.6. Please explain this discrepancy. The specification discusses Table 3.2. Should this be Table 3.5? The reactor scrams and the ventilation system secures with high radiation. Please explain where the surveillance requirement is for this action.

29.

TS 4.6.2: This appears to be part of verification of TS 3.6.5. Please explain. It is expected that LCO and surveillance requirement sections will correspond in the TSs Please address this discrepancy.

30.

TS 4.7: Surveillance requirements appear to be missing for TS 3.7.1, 3.7.2, 3.7.3, 3.7.4, 3.7.5 and 3.7.6. Should TS 6.5.4 be moved into TS 4.7? Please explain and address.

31.

TS 5.0: ANSI/ANS-15.1-2007 Section 5.0 provides guidance for design features including the reactor core. Please propose TS changes to include specifications for the reactor core and control rods or justify why they are not needed.

32.

TS 5.4.1: Requirements for fissionable material need to consider all conditions of reflection. Are these addressed under moderation? Please explain.

33.

Section 6.0 contains will and must statements. This is also true for other Sections of the TSs. Replace by shall statements as appropriate.

34.

TS 6.1.3.1 contains minimum staffing requirements when the reactor is not in a secured condition. TS 6.1.3.1.b contains requirements when the reactor is operating. These two conditions are different. Please explain.

35.

TS 6.1.4 addresses the selection and training of personnel. It states in part that this selection shall be in conjunction with the guidelines in set forth in ANSI/ANS-15.1 and 15.4. Considering that these are guidance documents, a should statement would also be acceptable.

36.

TS 6.2.2: ANSI/ANS-15.1-2007, Section 6.2.2 contains requirements for the charter (or directive) and rules of the review and audit committee. Please compare TS 6.2.2 against ANSI/ANS-15.7-2007, Section 6.2.2 and make appropriate changes to the TS or explain why changes are not needed. TS 6.2.2.2 states that a quorum has at least three members. ANSI/ANS-15.1-2007 states that the quorum is not less than half of the voting membership. TS 6.2.1 requires the committee to have a minimum of five persons. If the university chooses to have more than five persons on the committee, TS 6.2.2.2 may not meet the ANSI/ANS-15.1-2007 recommendation of at least half the voting membership be a quorum. Please address.

37.

TS 6.2.3.1 requires the RSA to determine that changes do not involve an unreviewed safety question. With revisions to 10 CFR 50.59, the term unreviewed safety question is not longer used. Please propose TS changes to conform to 10 CFR 50.59 or justify why it is not needed.

38.

TS 6.2.3: ANSI/ANS-15.1-2007, Sections 6.2.3 and 6.2.4 provide guidance for review and audit functions including dissemination of reports, findings, and recommendations.

Please propose TS changes to address the distribution of review and audit reports, findings, and recommendations or justify why these are not needed.

39.

TS 6.2.3.4 and TS 6.2.3.5 refer to charter. The appropriate term for MUTR is license, which is already included in the statements. The term charter should be eliminated or a justification for it remaining should be provided.

40.

TS 6.4: This section should state that changes to procedures shall be made in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, or justify why this is not required.

41.

TS 6.4.2: ANSI/ANS-15.1-2007, Section 6.4.2 provides guidance on required written procedures including procedures for fuel handling operations such as fuel movement within the reactor. Please propose TS changes to address the need for a written procedure for fuel movements within the reactor or justify why it is not needed.

42.

TS 6.4.2: Remove the statement experiment approval or justify its meaning and inclusion in the TS.

43.

TS 6.4.4: ANSI/ANS-15.1-2007 Section 6.4.4 provides guidance to develop written procedures for surveillance checks, inspections, and calibrations as specified by the TS.

MUTR TS 6.4.4 specifies surveillance of reactor instrumentation and safety systems and area monitors, but may not address all TS surveillance requirements. Please propose TS changes to address procedure for all TS surveillance requirements or justify why these are not needed.

44.

TS 6.4.6: ANSI/ANS-15.1-2007, Section 6.4 (6) provides guidance to develop written procedures for administrative controls for operations, maintenance, and experiments that could affect reactor safety. Please propose TS changes addressing the procedures for administrative controls related to these items or justify why these are not needed.

45.

ANSI/ANS-15.1-2007, Section 6.4(8) is missing from the TSs. Is byproduct material used under the reactor license? If so, please add a requirement for procedures or justify why procedures are not needed.

46.

TS 6.5: Routine experiment, modified routine experiment and special experiment are not defined. Please define. TS 6.5 should follow the recommendations of ANSI/ANS-15.1-2007, Section 6.5. Please address or explain why changes to TS 6.5 are not needed.

47.

TS 6.6.1: This section should follow ANSI/ANS-15.1-2007, Section 6.6.1, or a justification for not following it should be provided.

48.

TS 6.6.2: ANSI/ANS-15.1-2007, Section 6.6.2 provides guidance on special event reporting and conditions for resuming operation of the facility including authorization by reactor management. MUTR TS 6.6.2 assigns the authorization function to the Reactor Safety Committee and not to the reactor management. Please discuss the role of reactor management in the authorization to resume operation of the facility after the occurrence of special events.

49.

TS 6.7.1: Sending the annual reports only to Document Control Desk is acceptable.

50.

TS 6.7.1.2: ANSI/ANS-15.1-2007, Section 6.7.1.1 provides guidance on the content of the operating report to include operating experience. Please propose changes in TS 6.7.1.2 to include a summary of operating experience or justify why this is not needed.

51.

TS 6.7.3: ANSI/ANS-15.1-2007, Section 6.7.2.2 provides guidance on providing special reports to the licensing authority due to significant changes at the facility or the facility analyses. The written report required to be submitted to the NRC per MUTR TS 6.7.3 should be addressed to the NRC Document Control Desk. Please amend your TS or justify why it is not required.

52.

Regulation 10 CFR 55.59(c)(5)(i) requires that the facility licensee shall retain operator requalification documentation records until the operator's license is renewed. In addition, Section 6.8.2 of ANSI/ANS 15.1-2007 contains the recommendation that training records for reactor operators be maintained at all times the individual is employed or until the certification is renewed. MUTR TS 6.8.2 specifies that operator requalification records are maintained for a training cycle, which usually does not coincide with the operator license renewal cycle. Please discuss whether TS 6.8.2 meets the criteria in 10 CFR 55.59(c)(5)(i) and ANSI/ANS-15.1-2007,Section 6.8.2.

Please amend your TS as needed or justify why it is not required.