ML14058B134

Dow Chemical Company Request for Additional Information Regarding Renewal of Facility Operating License No. R-108 for Dow Chemical Triga Research Reactor

ML14058B134
Person / Time
Site:	Dow Chemical Company
Issue date:	03/06/2014
From:	Geoffrey Wertz Research and Test Reactors Licensing Branch
To:	O'Connor P Dow Chemical Co
Wertz G
References
TAC ME1595
Download: ML14058B134 (9)

Text

March 6, 2014 Paul J. OConnor, Ph.D.

Facility Director Dow Chemical TRIGA Research Reactor Dow Chemical Company Building 1602 Midland, MI 48674

SUBJECT:

DOW CHEMICAL COMPANY - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL OF FACILITY OPERATING LICENSE NO. R-108 FOR THE DOW CHEMICAL TRIGA RESEARCH REACTOR (TAC NO. ME1595)

Dear Dr. OConnor:

The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009 (a redacted version of the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System (ADAMS) Accession No. ML092150443), as supplemented by letters dated January 20, 2012 (ADAMS Accession No. ML12026A152), and July 11, 2013 (ADAMS Accession No. ML13196A299).

We require additional information and clarification on questions that have arisen during our review. 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 (10 CFR) Section 50.30(b), you must execute your response in a signed original document 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 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. Information related to security should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information: Performance requirements. Following receipt of the additional information, we will continue our evaluation of your license renewal request.

If you have any questions about this review, or if you need additional time to respond to this request, please contact me at 301-415-0893 or via electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely,

/Alexander Adams for RA/

Geoffrey A. Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-264 License No. R-108

Enclosure:

Request for Additional Information cc: See next page

Dow Chemical Company Docket No. 50-264 cc:

Office of the Mayor 333 West Ellsworth Midland, MI 48640 Office of the Governor Room 1 - Capitol Building Lansing, MI 48913 Mr. Dan Rader Environmental Health and Safety Responsible Care Leader Chair, Radiation Safety Committee 1790 Building Midland, MI 48674 Dr. Wayde Konze Global Research and Development Director for Analytical Sciences Chair, Reactor Operations Committee The Dow Chemical Company 1897 Building Midland, MI 48667 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML14058B134; *Concurrence via email NRR-088 OFFICE NRR/DPR/PRLB/PM*

NRR/DPR/PRLB/LA NRR/DPR/PRLB/BC NRR/DPR/PRLB/PM NAME GWertz PBlechman AAdams (AAdams for) GWertz DATE 02/27/2014 03/04/2014 03/06/2014 03/06/2014 Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL REVIEW FOR THE DOW CHEMICAL COMPANY TRIGA RESEARCH REACTOR LICENSE NO. R-108 DOCKET NO. 50-264 The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009 (a redacted version of the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System (ADAMS) Accession No. ML092150443), as supplemented by letters dated January 20, 2012 (ADAMS Accession No. ML12026A152), which provided the results of the DTRR maximum hypothetical accident (MHA) analysis, and July 11, 2013 (ADAMS Accession No. ML13196A299), which provided the proposed Technical Specifications (TSs). We require additional information and clarification related to the DTRR MHA analysis and TSs, as described in the documents referenced above. We request that you provide your responses to the following requests for additional information within 30 days of the date of this letter.

The requests for additional information (RAIs) are, in part, based on a comparison of the DTRR license renewal application and NUREG-1537, Guidance for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, dated February 1996 and the American Nuclear Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors.

1. The proposed DTRR TS 3.7.2, Materials, Specification b, does not appear to provide an upper limit for the quantity of explosives (e.g., greater than 25 milligrams TNT equivalent) that may be irradiated. NUREG-1537 provides guidance that licensees should establish an upper limit for the quantity of explosive material that may be irradiated. Provide justification for the proposed TS 3.7.2, or revise to follow the guidance provided in NUREG-1537 and establish an upper limit for the quantity of explosive material that may be irradiated.

2. The proposed DTRR TS 3.7.2, Materials, Specification c, provides a specification for the irradiation of fissionable material. However, an accompanying license condition is needed to permit the possession of fissionable material for irradiation. Provide a proposed license condition for the possession of fissionable material for irradiation including a mass (gram) limit and a description of the material form, or, if the DTRR does not intent to irradiate fissionable material, revise or delete the TS, as appropriate.

3. The proposed DTRR TS 3.7.3, Experimental Failure and Malfunctions, provides requirements to limit the radioactivity release due to an experimental failure or malfunction to not exceed the limits in Title 10 of the Code of Federal Regulations (10 CFR) Part 20.

Your proposed TS does not specify what section of 10 CFR 20 is limiting. However, the

guidance in NUREG-1537 specifies the effluent limits not to exceed the limits listed in 10 CFR 20, Appendix B. Provide justification for the proposed TS 3.7.3, or revise to provide a limit based on 10 CFR 20, Appendix B.

4. The proposed DTRR TS 3.6.2, Effluents, Bases, states, in part, a dose value that is 30%

lower than the 10 CFR 20 Appendix B effluent concentration value. It is not clear if the 30% reduction relates to the dose or concentration value. The dose value given is not consistent with Appendix B. Provide justification for the proposed TS 3.6.2, Bases, or revise to accurately reflect the 30% reduction.

5. The following RAIs are based on the MHA results, as provided in your response to RAI No. 52 (ADAMS Accession No. ML12026A152):

a. The ventilation system response to a significant radiological release, such as an MHA, is not fully described. NUREG-1537 provides guidance to describe the response by the ventilation system to an MHA event. Provide a description of the response of the ventilation system to the MHA. Indicate if the ventilation system response is the result of any automatic initiation or the result of operator action, or both. For any operator action, describe the supporting procedure guidance.

b. The results of the dose calculations provided in Scenario 3 to a member of the public at the fence line boundary were based on effluent releases provided by the ventilation system operating in normal mode. However, dose calculations were not provided with the ventilation system not operating (i.e., in shutdown mode). Given that the ventilation system could be shutdown during, or shortly after the initiation of an MHA event, provide a dose calculation to the maximally exposed member of the public. List any assumptions for MHA effluent leakage from building penetrations (e.g., door seals, etc.) and for direct radiation shine from the radioactive materials retained in the reactor room.

6. The proposed DTRR TS 1.3, Definitions, Experiment, provides definitions for several categories of experiments (Moveable, Modified Routine, Routine, Secured, Special, and Unsecured), which appear to be based, in part, on reactivity characteristics or approval requirements. However, the definition of Routine Experiment includes an experiment, which is not defined as any other kind of experiment. Based on this definition, is not clear as to the applicability of the various definitions of experiments to other DTRR TSs (e.g., TS 6.5.).

Provide justification for the various definitions of experiments described in the proposed TS 1.3, Definitions, and apply the definitions consistently through the applicable DTRR TSs (e.g., TS 6.5), or revise TS 1.3, Definitions, Experiment as applicable.

7. The proposed DTRR TS 1.3, Definitions, Reference Core Condition, provides a value of

-$0.30 for Xenon reactivity. Given that the reactivity required to satisfy the DTRR shutdown margin (SDM), TS 3.1, Reactivity Limits, Specification 1, is -$0.50, in the Reference Core Condition, the resulting SDM reactivity could be as low as -$0.20, which is not consistent with the guidance in NUREG-1537, which provides a value of -$0.50 SDM reactivity.

Provide justification for the proposed TS 1.3, Definitions, Reference Core Condition by proposing a TS 3.1 SDM reactivity limit that is consistent with the SDM guidance in NUREG-1537 or revise TS 1.3, Definitions, Reference Core Condition.

8. The proposed DTRR TS 4.0, General, Specifications 1 and 4, provide items that may not be deferred during a reactor shutdown. However, the items identified in Specification 1 do not match those items identified in Specification 4. As such, the resulting inconsistency could be subject to misinterpretation. Provide justification for the proposed TS 4.0, Specifications 1 and 4, or revise to identify a consistent list of surveillance items that may be deferred during reactor shutdown.

9. The proposed DTRR TS 4.1, Reactor Core Parameters, Specification, states, in part, that the reactivity measurements will be performed following any change of reactivity by $0.25 or more from the reference core. Details describing the types of activities that could result in a reactivity change of $0.25 or more are not provided. Provide information that describes the types of activities that could result in reactivity changes of $0.25 or more.

10. The proposed DTRR TS 4.3, Control and Safety Systems, Specification 4, provides for control rod inspection, but lacks any inspection criteria. NUREG-1537 provides guidance for control rods that should be inspected for damage and deterioration. Provide justification for the proposed TS 4.3, or revise to include inspection criteria consistent with the guidance in NUREG-1537.

11. The proposed DTRR TS 4.4, Reactor Coolant Systems, Specifications 3 and 5, state, in part, that [a] channel calibration is performed if required as a result of the channel test.

However, no periodic channel calibration is provided and the calibration criteria are not defined. NUREG-1537 provides guidance that manufacturers recommendations should be considered for calibration. Provide justification for the proposed TS 4.4, Specifications 3 and 5, or revise to ensure a periodic calibration, consistent with the guidance in NUREG-1537 (e.g., manufacturers recommendations), is provided.

12. The proposed DTRR TS 6.1.1, Structure, Figure 6.1., indicates a communication relationship (i.e., the dashed line) between the Dow Core R&D Director (Level 1) and the Reactor Operations Committee (ROC). However, NUREG-1537 provides guidance that the review/audit group should report (i.e., a solid line) to the Level 1. Additionally, the Radiation Safety Committee (RSC) appears to have a typographical error as ROC is referenced in the RSC box. Provide justification for the communication relationship in proposed TS Figure 6.1, or revise to indicate a reporting relationship consistent with the guidance in NUREG-1537.

13. The proposed DTRR TS 6.1.3, Staffing, Item 1, states, in part, [t]he minimum staffing when the reactor is operating. NUREG-1537 provides guidance that the minimum reactor staffing is required when the reactor is not secured. Provide justification for the proposed TS 6.1.3, Item 1, or revise to ensure the minimum staffing requirements consistent with the guidance in NUREG-1537.

14. The proposed DTRR TS 6.1.3, Staffing, Item 3.d, states, in part, [r]ecovery fromsignificant power reduction. However, the criteria for the determination of a significant power reduction are not defined in the DTRR TSs. Provide justification for the proposed TS 6.1.3, Item 3.d, or revise by incorporating criteria in order to determine a significant power reduction.

15. The proposed DTRR TS 6.2.1, Composition and Qualification, states, in part, that [t]he ROC shall consist of at least four members and shall be appointed by Level 1 management. However, TS 6.2.1 subsequently lists more than four members by title and the determination and composition of the ROC membership is not clearly defined. Provide justification for the proposed TS 6.2.1, or revise to provide clear guidance as the composition and determination of the ROC membership.

16. The proposed DTRR TS 6.2.2, ROC Rules, Item a, states, in part, that no more than one-half of the voting members present may be of the operating staff. However, the operating staff is not defined. Provide justification for the proposed TS 6.2.2, Item a, or revise to provide guidance as to which voting members constitute operating staff.

17. The proposed DTRR TS 6.2.2, ROC Rules, Item e, states, in part, that [t]he ROC shall report at least twice per year to the Radiation Safety Committee (RSC) through presentations by the reactor supervisor at the quarterly RSC meetings. However, it is not clear how the report through presentations is accomplished. Provide justification for the proposed TS 6.2.2, Item e, or revise to provide clear guidance as to how the ROC communicates the audit findings. Confirm that TS Figure 6.1 accurately depicts the relationship between the ROC and RSC.

18. The proposed DTRR TS 6.2.3, ROC Review Function, Item a, states, that the ROC shall

[r]eview all changes made under 10 CFR 50.59. NUREG-1537 provides guidance that the review should include the determinations that the proposed changes were allowed without prior NRC approval. However, TS 6.2.3, Item a, does not includes this determination.

Provide justification for the proposed TS 6.2.3, Item a, or revise to include the review guidance for proposed changes consistent with the guidance in NUREG-1537.

19. The proposed DTRR TS 6.4, Procedures, states, in part, that [o]perating procedures shall be in effect but does not indicate if the procedures are required to be used and followed.

Provide justification for the proposed TS 6.4, or revise to include guidance for using these procedures.

20. The proposed DTRR TS 6.5, Experimental Review and Approval, states, in part,

[a]pproved experiments and [a]ll new experiments However, approved experiments and new experiments are not defined in the list of experiments provided in TS 1.3, Definitions, Experiment, (which included Moveable, Modified Routine, Routine, Secured, Special, and Unsecured Experiments). It is not clear which category of experiments is applicable in proposed TS 6.5. Provide a justification for the proposed TS 6.5, or revise to delineate which experiments require review and approval.

21. The proposed DTRR TS 6.6.1, Actions to Be Taken in Case of Safety Limit Violation, Item b, states, in part, [a]n immediate notification of the occurrence shall be made to theU.S. NRC Headquarters Operations Center. This notification requirement conflicts with DTRR TS 6.7.2, Special Reports, Item 1, which requires [a] report not later than the following working day. Additionally, TS 6.6.1, Item b, does not appear consistent with the guidance in NUREG-1537. Provide justification for the proposed TS 6.6.1, Specification b, or revise to be consistent with the guidance in NUREG-1537.

22. The proposed DTRR TS 6.7.1, Annual Operating Reports, Item c, states, in part, the annual report shall include a tabulation of new tests and experiments that are significantly different from those performed previously and are not described in the Safety Analysis Report. NUREG-1537 provides guidance that the annual report should include all new tests and experiments and not just significant tests and experiments to meet the requirements of 10 CFR 50.59. Provide justification for the proposed TS 6.7.1, Item c, or revise to be consistent with the guidance in NUREG-1537.

23. The proposed DTRR TS 6.8.1, The following records shall be kept for a minimum period of five years or for the life of the component involved if less than five years, Item 7, states, in part, ; and which appears to be a typographical error. Provide justification for the proposed TS 6.8.1, Item 7, or revise to remove the typographical error.

24. The proposed DTRR TS 6.8.2, Records to be Retained for at Least One Certification Cycle, states, in part, that [r]ecordsshall be retained for at least one complete requalification schedule The length of the time for schedule is not defined. The guidance in NUREG-1537 suggests the term of a cycle. Provide justification for the proposed TS 6.8.2, or revise to use the term cycle to be consistent with the guidance in NUREG-1537.