ML11130A027

University of California, Irvine, Request Additional Time to Respond to Request for Additional Information for the Review of Proposed Technical Specifications

ML11130A027
Person / Time
Site:	University of California - Irvine
Issue date:	04/28/2011
From:	Geoffrey Miller University of California - Irvine
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11130A027 (2)

Text

UNIVERSITY OF CALIFORNIA, IRVINE BERKELEY

• DAVIS IRVINE LOS ANGELES

• RIVERSIDE

• SAN DIEGO

• SAN FRANCI*LO SANTA BARBARA

• SANTA CRUZ George E. Miller IRVINE, CA 92697-2025 Senior Lecturer Emeritus (949) 824-6649 or 824-6082 Department of Chemistry and FAX: (949) 824-8571 Director, Nuclear Reactor Facility email : gemiller@uci.edu Faculty Advisor for Science, UCI Center for Education Partnerships April 28th, 2011 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 ATTN: Linh Tran; Francis DiMeglio

References:

Docket 50-326. License R-116 UC Irvine Nuclear Reactor Facility RAI re License Renewal, TAC ME1579, dated April 5 th 2011 I regret to inform you that we need to request additional time to respond to the latest Request for Additional Information and for the review of revisions to proposed Technical Specifications. Several reasons exist for this request:

(1) personal illness involving respiratory infections that have been difficult to clear over a period of about 4 weeks has significantly delayed my addressing these issues. Unfortunately no other personnel are available to take over this work.

(2) re RAI (1). The rationale for a seismic scram switch was never addressed before since it was provided by the reactor manufacturer as part of the installation. Thus we need to develop such a rationale from scratch and establish, perhaps through research at other facilities, whether and how a need for a specific level of response is justified.

(3) re RAI (2). We need to redevelop our MHA analysis (rewriting the SAR section completely) using more realistic source terms, direct radiation assessments not made before, and using updated values from revisions that have been made to our ventilation systems (under 10 CFR 50.59) since our relicense application. We have asked for DOE supported assistance in developing realistic source terms using recent models for our "hottest" fuel elements as sources for the MHA. At some point following 9/11/2001 we were asked by NRC to submit a more realistic source term for a fuel element based on core history. While we did provide provisional information at that time we did not develop a model for subsequent use. A complete description of our current ventilation system is also apparently needed for incorporation into the Technical Specifications, a feature not present in previous iterations.

(4) re RAI (3). We are revising our system at the facility to significantly reduce the chance of future external tank corrosion by reducing the

'o, surrounding "water pool" to a level below that of the reactor tank, by/,

°

, S

installation of a superior pumping and monitoring system. This work is nearing completion and will be ready to be described shortly. Pumping is underway but water level monitoring instrumentation has yet to be specified and installed.

Respectfully, we must request more time for this entire process. We currently anticipate that completion of all items should be possible by the end of June, so that final action in these specifics should be taken by July 1st 2011.

Thank you for your patience and consideration.

Dr. George E. Miller Director and Acting Supervisor