ML13032A005

Reed College - Reply to Notice of Violation

ML13032A005
Person / Time
Site:	Reed College
Issue date:	01/30/2013
From:	Krahenbuhl M Reed College
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13032A005 (2)

Text

REED COLLEGE January 30, 2013 REACTOR FACI LITY 3203 Southeast U.S. Nuclear Regulatory Commission ATTN; Document Control Desk Portland. Oregon Washington, D.C. 20555-0001 97202-8199 telephowe RE: Reply to Notice of Violation 503/777-7222 The Notice of Violation dated Jan. 2, 2013 states in part that:

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"...the licensee made a change to the facility as described in the safety analysis report 503/777-7274 without conducting an evaluation to determine whether or not the change should have enoil required a license amendment. Specifically, the licensee added 15 more fuel elements reactor@reed.edu to the reactor core in addition to those already installed...

web http:H/rr.ctor.rrrd.rdu The licensee contends that it completed the required screening. This screening is referred to in IR 50-288/2012-201. However, after reviewing the applicable documents and events leading up to the core loading in February 2011, the licensee concurs that the screening was not complete.

This response is organized to address the four specific items listed in the notice of violation.

1. The reason for the violation, or, if contested, the basis for disputing the violation or severity level.

The decision to add additional fuel elements without further analysis has two contributing factors. These factors are: the safety evaluation report issued in conjunction with R-1 12 amendment 8 and the operating history of the incoming fuel.

a. The safety analysis completed in support of the license amendment issued Jan. 4, 2012 was submitted solely for the purpose of possession and use of the University of Arizona Research Reactor (UARR) fuel. The Nuclear Regulatory Commission (NRC) staff Safety Evaluation Report (SER) issued in conjunction with facility license R-112 amendment 8 includes the following two statements:

"The NRC staff finds that receipt, possession and use of the UARR fuel in the Reed research reactor (RRR) meets the requirements of the RRR TSs because the fuel is essentially identical to the fuel currently used at the RRR. Based on these findings, the NRC staff concludes that the receipt, possession and use of the UARR fuel in the RRR is acceptable."

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"The proposed license amendment did not change any of the accident analysis for the RRR."

The licensee felt that these conclusions supported the immediate use of the UARR fuel without further analysis, and relied on these conclusions in proposing the core change to the Reactor Operations Committee.

b. The UARR fuel was burned more than the fuel being replaced. The burned condition of the fuel precluded a direct one-for-one replacement to create an operational core.

The licensee felt that if the installed core met the shutdown margin and excess reactivity of the applicable license, the conditions and outcomes stated in the Updated Facility Safety Analysis Report (UFSAR) would remain unchanged. Based on the UARR fuel history, the licensee surmised that neutronic and thermohydraulic analysis of the 62-element core described in the applicable UFSAR would be inclusive of the February 2011 core. The Reactor Operations Committee approved the adding the elements by amending Special Experiment #1. However, this discussion and analysis were not included in the screening form.

2. The corrective steps that have been taken and the results achieved.

The licensee has completed a thermohydraulic and neutronic evaluation of the Feb.

2011 core. The analyses support the licensee's supposition that the 79-element core did not alter the outcomes enumerated in the UFSAR applicable at the time. Additionally, a new safety analysis report and subsequent responses to requests for additional information have been submitted in support of the license renewal that concluded on April 24, 2012.

3. The corrective steps that will be taken to avoid further violations.

We will modify two Standard Operating Procedures (SOP). These procedures are SOP 60 Logbook Entries and SOP 62 Changes, Tests, and Experiments to include a prescriptive approach to maintenance of equipment and guidance in how to document a facility changes. These modifications will reduce the likelihood of a repeat occurrence.

We will also create a new SOP for changes to the core configuration.

4. The date when full compliance will be achieved.

These corrective actions will be completed by April 1, 2013 Respectfully, Melinda Krahenbuhl Ph.D.

Director, Reed Research Reactor