ML121290640

University of Texas at Austin Request for Additional Information License Amendment, Submission of Changes to License Technical Specifications

ML121290640
Person / Time
Site:	University of Texas at Austin
Issue date:	06/14/2012
From:	Paulette Torres Research and Test Reactors Licensing Branch
To:	Whaley P University of Texas at Austin
Torres P
References
TAC ME8072
Download: ML121290640 (8)

Text

June 14, 2012 Mr. P. Michael Whaley, Associate Director Nuclear Engineering Teaching Laboratory The University of Texas at Austin 1 University Station, R9000 Austin, Texas 78712

SUBJECT:

THE UNIVERSITY OF TEXAS AT AUSTIN REQUEST FOR ADDITIONAL INFORMATION, RE: LICENSE AMENDMENT, SUBMISSION OF CHANGES TO LICENSE TECHNICAL SPECIFICATIONS (TAC NO. ME8072)

Dear Mr. Whaley:

We are continuing our review of your amendment request dated February 8, 2012, for Facility Operating License No. R-129 for the University of Texas at Austin Research Reactor. During our review of your amendment request, 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.

Several of your proposed technical specification changes are related to initial start-up and operator staffing requirements. The NRC staff is currently developing interpretation guidance in this area. Because of this, the NRC staff has not evaluated your proposed definition of initial startup or proposed changes to TS 6.1.3, Staffing (Part 2).

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. Your response must be submitted in accordance with 10 CFR 50.4, Written Communications. Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Following receipt of the additional information, we will continue our evaluation of your amendment request.

P. Whaley If you have any questions regarding this review, please contact me at (301) 415-5656 or by electronic mail at paulette.torres@nrc.gov.

Sincerely,

/RA/

Paulette Torres, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-602 cc w/encl:

See next page

University of Texas at Austin Docket No. 50-602 cc:

Governors Budget and Planning Office P.O. Box 13561 Austin, TX 78711 Bureau of Radiation Control State of Texas 1100 West 49th Street Austin, TX 78756 Dr. William Powers, Jr., President University of Texas at Austin Nuclear Engineering Teaching Laboratory Austin, TX 78758 Office of the Governor P.O. Box 12428 Austin, TX 78711 P. Michael Whaley, Associate Director Nuclear Engineering Teaching Laboratory The University of Texas at Austin 10100 Burnet Road Austin, TX 78758 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML121290640 OFFICE DPR/PRLB: PM DPR/PRLB: LA DPR/PRLB: PM DPR/PRLB: BC DPR/PRLB: PM NAME PTorres GLappert AAdams JQuichocho PTorres DATE 5/2/2012 5/17/2012 5/17/2012 6/12/2012 6/14/2012 OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR THE UNIVERSITY OF TEXAS AT AUSTIN LICENSE NO. R-129; DOCKET NO. 50-602 We are continuing our review of your amendment request for Facility Operating License No.

R-129 for the University of Texas at Austin which you submitted on February 8, 2012. During our review of your amendment request, questions have arisen for which we require additional information and clarification.

Please provide responses to the following requests for additional information (RAI) within 45 days of the date of the letter.

1. Your proposed technical specification (TS) table of contents included in your application does not appear to reflect the changes proposed to the TSs. Please provide an updated table of contents to reflect your changes or provide justification for not doing so.

2. You have proposed to replace the definition of Certified Operators with Licensee.

Your proposed definition refers to licensed reactor operators and senior reactor operators. The term licensee does not appear to be used in the TSs. However, the term licensee is used in the facility operating license to refer to the University of Texas at Austin.

a. Please provide a justification of the need for replacing this definition given it can lead to confusion with the term licensee as it is used in the facility operating license.

b. Your current TSs continues to use the term Certified Operators (e.g., TS 6.1.3).

Please ensure that your proposed TSs reflect the proposed changes in definitions throughout the document.

3. You have proposed a definition for Senior Reactor Operator with the stated purpose of bringing the UT TSs into compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 55. However, the terminology in 10 CFR 55.4 is senior operator.

Please provide updated proposed TS in accordance with 10 CFR 55.4 or provide justification for not doing so.

4. You have proposed a definition for Operator which states in accordance with 10CFR55, an operator is licensed as either a Reactor Operator or a Senior Reactor Operator. Your definition does not appear to be consistent with the regulations. Please provide a justification for this statement or revise your definition.

5. In proposed TS 3.1.2 Shutdown Margin:

a. You have proposed to reword the current TS to The magnitude of shutdown margin in reference core conditions with no reactivity from negative worth experiments shall be greater than 0.2% k/k ($0.29). Please provide a justification why the proposed TS does not provide written direction that the reactor shall not be operated under these conditions as stated in the current TS 3.1.2 a.

b. The minimum shutdown margin is defined in the reference core condition. The reference core condition allows the reactivity of xenon to be negligible which is less than $0.30. Your minimum shutdown margin is $0.29. Please discuss the possibility that a core that meets minimum shutdown margin requirements with maximum allowed xenon reactivity could become critical if the xenon decays to

$0.00. Please discuss the accuracy of control rod calibrations and the resulting shutdown margin determinations.

c. The bases of the TS have not been updated to address your proposed changes in proposed TS 3.1.2 wording. Please review this and all other TS applicability, objective and bases statements associated with proposed changes to the TS to ensure that they reflect your proposed specification changes throughout the document.

6. Your proposed wording for TS 3.1.3 could be clarified as applying to limiting the time the pulse rod remains withdrawn after a pulse when the reactor is in pulse mode. Please reword this technical specification to avoid confusion.

7. In proposed TS 3.2.3 Reactor Safety System and proposed TS 3.2.4 Reactor Instrument System, you have requested to reduce minimum safety channels from 2 to 1.

Redundancy and diversity of safety channels is an important part of defense in depth.

a. For proposed TS 3.2.3, please provide a detail discussion explaining that only one channel is required for reactor safety.

b. For proposed TS 3.2.4, please provide additional information that can better justify the decrease in scram channels.

8. In proposed TS 3.4.2 a. you have requested to replace the Handbook of Laboratory Safety" Tables of Chemical Information published by CRC press with the Material Safety Data Sheet (MSDS) on file or similar source of information involving hazardous chemicals. Hazard categories in CRC tables are defined consistently which allows hazards such as explosive materials to be applied consistently in safety evaluations.

Are MSDSs equivalent to CRC tables or are MSDSs more conservative? How does the information in the MSDS compare with the Handbook of Laboratory Safety? Please provide additional information that can support this replacement. Please identify what similar source of information involving hazardous chemicals you are referring to.

9. In your application in the current and proposed TS 3.4.2 a. you refer to compounds high reactive with water. In NRCs official copy of the TS, TS 3.4.2 a. indicates the word highly. Should this be compounds highly reactive with water? Please verify if this was an editing error or submit an amendment request for this change.

10. Your current wording for TS 3.4.2 e. given in your application does not match the wording in NRCs official copy of your TSs. Please verify if this was an editing error or submit an amendment request for this change.

11. In your proposed TS 3.4.2 e., please discuss the escape of radioactivity from the experiment to the reactor room or to the environment.

12. Your current wording for TS 4.1.3 given in your application does not match the wording in NRCs official copy of your TSs. Please verify your wording. Your proposed TS 4.1.3 discuses evaluation of transient rod function following significant reactor core changes.

Please define what constitutes significant reactor core changes and provide a justification for your definition.

13. Your proposed TS 5.1.1 d. appears to increase the area of the Nuclear Engineering Teaching Laboratory under the reactor license. Please describe activities directly related to reactor operation or the reactors utilization program that will be conducted in the new areas. Discuss how these activities relate to the reactor radiation protection, security and emergency plans. Please discuss how the proposed area relates to the facility indemnity agreement.

14. In proposed TS 6.1.1 Structure (Organizational Chart):

a. You have proposed to eliminate the use of level 1 to 4 terminologies which is the structure indicated in ANSI 15.1-2007 Section 6.1.1. Please provide your basis for eliminating the use of level 1 to 4 terminologies.

b. You have proposed to add new positions and reporting requirements that are specific to facility needs. Please provide a description for each of these new positions and their responsibility for the safe operation of the reactor.

c. The term Operations Staff has been removed from the proposed organizational chart. This term is still used in the TS (e.g., TS 6.1.1). Please explain and justify deleting the term Operations Staff from the organizational chart and basis.

d. The current TSs contains solid lines and dotted lines. In the proposed TSs, do solid lines continue to indicate lines of responsibility and dotted lines communication? Please add this information to the proposed organizational chart.

e. It appears in your proposed organizational chart that the Reactor Oversight Committee and the Radiation Safety Committee have no lines of responsibility, only communication whereas the committees have both lines of responsibility and communications in your current TSs. This is not consistent with the

guidance of ANSI 15.1-2007 Section 6.1.1 or NUREG-1537 Section 12.1.1.

Please describe and justify how these committees function without being responsible to anyone in the organization.

15. There appears to be an error in your proposed changes to TS 6.3 Operating Procedures.

You also refer to this section with a section 6.4 number. Please clarify and correct as needed.