Letter Sequence RAI |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance
- Supplement, Supplement, Supplement
Results
Other: ML110270002, ML11318A281, ML113460038, ML120180131, ML120730278, ML120800032, ML120800036, ML12137A151, ML12137A171, ML13022A010, ML13094A006, ML13113A001
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MONTHYEARML1016106562010-06-17017 June 2010 Dow Chemical Company, Request for Additional Information Regarding Financial Qualifications for Triga Research Reactor (Tac ME1595) Project stage: RAI ML1018101622010-07-12012 July 2010 Dow Chemical Company - Request for Additional Information Regarding the Environmental Assessment for the License Renewal Review (TAC Me1595) Project stage: RAI ML1022900132010-08-12012 August 2010 Dow Chemical Company Extension Request for Financial RAI Project stage: Request ML1023802992010-09-0101 September 2010 Dow Chemical Company - Approval of Request for an Extension, Financial Request for Additional Information Dated June 17, 2010 (Tac ME1595) Project stage: RAI ML1025202812010-09-16016 September 2010 Dow Chemical Company - Request for Additional Information Regarding the Emergency Plan for the License Renewal and Power Uprate Application Review Project stage: RAI ML1027900032010-10-27027 October 2010 Dow Chemical Company - Request for Additional Information Regarding the Operator Requalification Program for the License Renewal and Power Uprate Application Review Project stage: RAI ML1027003072010-11-0202 November 2010 Dow Chemical Company - Request for Additional Information Required for the License Renewal and Power Uprate Application Review Project stage: RAI ML1101305012011-01-12012 January 2011 Dow Chemical Company, Withdrawing of to Increase Licensed Power Level to 750 Kw Request Project stage: Request ML1102700022011-01-31031 January 2011 Dow Chemical Company, Retraction of the Power Uprate Request for License Renewal Application Project stage: Other ML1104903912011-02-11011 February 2011 Dow Chemical Triga - Revised Safety Analysis Report, Technical Specifications and RAI Responses (2/11/2011), Redacted Version Project stage: Request ML1107300742011-03-21021 March 2011 Dow Chemical Company - Response to Dow Chemical Request for Additional Information Dated February 11, 2011 for Extension to Answer 18 Project stage: RAI ML1134601202011-04-20020 April 2011 Dow Chemical Company - *Redacted* Response to NRC Request for Additional Information License Renewal Clarifications to March 9, 2011 Telephone Conference Project stage: Response to RAI ML11136A2292011-05-12012 May 2011 Dow Chemical Company - Response to Request for Additional Information for the Renewal of License Triga Research Reactor No. 108 Project stage: Response to RAI ML11144A2872011-05-23023 May 2011 Dow Chemical Company - Management Changes. License No. R-108 Project stage: Request ML1121503272011-05-27027 May 2011 Dow Chemical Company - Redacted Version of ML11151A266, Dow Responses Dated May 27, 2011 Project stage: Request ML1117305822011-07-11011 July 2011 Dow Chemical Company - Request for Additional Information Regarding Financial Qualifications for the Dow Chemical Company Triga Research Reactor License Renewal Project stage: RAI ML1117400552011-07-11011 July 2011 Dow Chemical Company - NON-PROPRIETARY Version - Request for Additional Information Regarding Financial Qualifications for the Dow Chemical Company Triga Research Reactor License Renewal (Tac No. ME1595). License No. R-108; Docket No. 50-26 Project stage: RAI ML1115204782011-07-14014 July 2011 Dow Chemical Company - Response to Request for Additional Information Dated May 12, 2011 (Tac No. ME1595) Project stage: RAI ML11228A1172011-08-10010 August 2011 Dow Chemical Company, Response to Request for Additional Information Regarding Financial Qualifications in Support of License Renewal Project stage: Response to RAI ML11228A1162011-08-12012 August 2011 Letter Dow Chemical Company - Response to the Request for Additional Information for the Renewed License of the Triga Research Reactor Project stage: Request ML11249A0432011-08-31031 August 2011 The Dow Chemical Company, Revised Responses to RAI Questions 6, 11, 15-1, 17-1, 17-3, 34, 35, 36-2, 41,52, 54, 56, 57, 61-3, 62-2, 64-1, 65-1, 65-2 in Support of the License Renewal Project stage: Response to RAI ML1123719452011-09-0606 September 2011 Dow Chemical Company - Response to Request for Additional Information Dated August 10, 2011 and August 12, 2011 Project stage: RAI ML1125902622011-09-26026 September 2011 Dow Chemical Company - Review of the Revised Emergency Plan Submitted July 7, 2011, Project stage: Approval ML11287A0352011-10-12012 October 2011 The Dow Chemical Company - Request for Additional Information Regarding Financial Qualifications for the Dow Chemical Company Triga Research Reactor License Renewal Project stage: Request ML1129300352011-10-12012 October 2011 Dow Chemical Company, Redacted Revised Responses to NRC Request for Additional Information Questions 11, 14, 15-1, 16, 17-1, 17-3, 18, 19, 41, 52, 53, 54, and 56 in Support of the License Renewal Project stage: Response to RAI ML1130400042011-11-0202 November 2011 Dow Chemical Company, Approval of Extension Request to Respond to NRC Request for Additional Information Project stage: RAI ML1134101682011-11-10010 November 2011 Dow Chemical Company - *Redacted* Responses to NRC Request for Additional Information Technical Project stage: Response to RAI ML11318A2812011-11-10010 November 2011 The Dow Chemical Company, Revised Submittal for the Technical Specification in Support of the License Renewal Project stage: Other ML1134600382011-12-0606 December 2011 Dow Chemical Company - Redacted Updated Neutronic and Thermal Hydraulic Reports in Support of the License Renewal Dated December 3, 2011 (Tac No. ME1595) Project stage: Other ML11343A6462011-12-0707 December 2011 Dow, Submittal of Revised Response for the July 11, 2011 NRC Letter Request for Additional Information Regarding Financial Qualifications for Triga Research Reactor License Renewal TAC ME1595 Project stage: Request ML12019A0072012-01-13013 January 2012 The Dow Chemical Company Revised Response for July 11, 2011 NRC Letter Request for Additional Information Regarding Financial Qualifications for the Dow Chemical Company Triga Research Reactor License Renewal Project stage: Request ML12026A1522012-01-20020 January 2012 Dow Chemical Company - *Redacted* Revised Responses to NRC Request for Additional Information Questions 52, 54, and 56 in Support of the License Renewal (Tac ME1595) Project stage: Response to RAI ML12025A0892012-01-20020 January 2012 Dow Chemical Company, Transmittal of Dtrr Revised Responses to RAI Questions 52, 54, and 56 in Support of the License Renewal Project stage: Response to RAI ML1201801312012-01-26026 January 2012 Dow Chemical Company - Letter to Licensee Determination of Acceptability Project stage: Other ML12040A1282012-02-0707 February 2012 The Dow Chemical Company - Dtrr Revised Technical Specifications and Supplemental Information to the Dtrr Revised Response to RAI 54, Dated January 20, 2012 in Support of the License Renewal Project stage: Supplement ML1201801522012-02-0707 February 2012 FRN: Dow Chemical Company - Notice of Acceptance for Docketing of Application and Opportunity to Request a Hearing and Order Imposing Procedures for Access to SUNSI Project stage: Acceptance Review ML1207302782012-03-0505 March 2012 Dow Chemical Company - E-mail from K. Yale, Michigan Dept. of Environmental Quality to G. Wertz, NRC Project Manager, Notification of No Comments Environmental Assessment Project stage: Other ML12164A7842012-06-11011 June 2012 The Dow Chemical Company, Dtrr Revised Technical Specifications and Supplemental Information to the Dtrr Revised Response to RAI 41, Dated November 10, 2011, in Support of the License Renewal Project stage: Supplement ML1208000322012-07-10010 July 2012 Dow Chemical Company - Letter to Licensee Availability of Environmental Assessment Federal Register Notice (Tac ME1595) Project stage: Other ML1208000362012-07-10010 July 2012 General Notice - FRN: Notice of Availability of Environmental Assessment and Finding of No Significant Impact Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor (Tac No. ME1595) Project stage: Other ML13022A0102013-01-18018 January 2013 Dow Chemical Company - E-mail from S. Yusuf, Dow to G. Wertz, NRC Dow Technical Specification Typographical Edits (Tac No. ME1595) Project stage: Other ML13094A0062013-05-0101 May 2013 FRN: General Notice: Dow Chemical Company - Supplement to Environmental Assessment (77 Fr 42771-42774) Waste Confidence Rule Project stage: Other NRC-2012-0026, FRN: General Notice: Dow Chemical Company - Supplement to Environmental Assessment (77 Fr 42771-42774) Waste Confidence Rule2013-05-0101 May 2013 FRN: General Notice: Dow Chemical Company - Supplement to Environmental Assessment (77 Fr 42771-42774) Waste Confidence Rule Project stage: Supplement ML13113A0012013-05-0606 May 2013 Dow Chemical Company - Letter to Licensee Notification of Supplemental Federal Register for Environmental Assessment Waste Confidence Rule Project stage: Other ML13157A4122013-06-26026 June 2013 Dow Chemical Company - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor Project stage: RAI ML13196A2992013-07-11011 July 2013 Dow Chemical Company Response to RAI Letter Dated June 26, 2013 and Dtrr Revised Technical Specifications Project stage: Request ML13225A2512013-09-0606 September 2013 Dow Chemical Company - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor Project stage: RAI ML14058B1342014-03-0606 March 2014 Dow Chemical Company Request for Additional Information Regarding Renewal of Facility Operating License No. R-108 for Dow Chemical Triga Research Reactor Project stage: RAI ML14070A1792014-03-0707 March 2014 Dow Triga Research Reactor - Annual Report - 2013 Project stage: Request ML14100A3492014-04-0909 April 2014 The Dow Chemical Co., Submittal of Responses to RAI Letter Dated 03/06/2014 and Dtrr Revised Technical Specifications Project stage: Request 2011-07-14
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Category:Letter
MONTHYEARML25056A0582025-02-19019 February 2025 Dow Chemical Co., Response to Order EA-NRR-2025-0013 ML24341A0422024-12-0404 December 2024 Dow Chemical Co. - a Dow Triga Researcher Reactor Senior Reactor Operators (SRO) on Medical Leave IR 05000264/20242012024-05-22022 May 2024 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2024201 ML24066A1472024-03-11011 March 2024 Dow Chemical Company - Change of Facility Project Manager ML24057A0092024-02-21021 February 2024 Dow Triga Research Reactor Annual Report - 2023 IR 05000264/20232012023-08-0101 August 2023 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2023201 - Cover Letter and Enclosure ML23062A1132023-02-28028 February 2023 Dow Chemical Co., Submittal of Annual Report for 2022 ML22284A0472022-10-0606 October 2022 Closure of Level 1 Finding for the Quad Cities Generating Station ML22062B6492022-05-24024 May 2022 Supplemental Information Needed for Acceptance of Proposed Alternative to Use ASME Code Case N-921 IR 05000264/20222012022-04-15015 April 2022 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Inspection Report 05000264/2022201 ML22080A0722022-03-11011 March 2022 Dow Chemical Company - Management Change ML22055A5772022-02-0404 February 2022 Dow Chemical Co., Submittal of Annual Report for 2021 ML21271A0952021-10-0404 October 2021 Dow Chemical Company Change of Facility Project Manager IR 05000264/20212022021-08-10010 August 2021 Dow Chemical Company U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2021202 IR 05000264/20212012021-05-27027 May 2021 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2021201 ML21153A1642021-05-26026 May 2021 Dow Chemical Company - Management Change Update ML21063A2492021-02-16016 February 2021 Dow Triga Research Reactor Annual Report - 2020 ML20295A4242020-11-16016 November 2020 Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards ML20247J3712020-09-0303 September 2020 Examination Confirmation Letter No. 50-264/OL-21-01, Dow Chemical Company Reactor ML20045F1952020-04-17017 April 2020 The Dow Chemical Company - Order Approving Indirect Transfer of Renewed Facility Operating License No. R-108 for the Dow Triga Research Reactor ML20062A1872020-02-24024 February 2020 Dow Chemical Co., Submittal of Annual Report ML19339F8002020-02-0606 February 2020 Dow Chemical Co., Notice of Consideration of Approval of Indirect License Transfer and Conforming Amendment and Opportunity for a Hearing and Petition for Leave to Intervene ML19330E2442019-11-22022 November 2019 Dow Chemical Co., Transmittal of Consent for an Indirect License Transfer IR 05000264/20192012019-10-30030 October 2019 Dow Chemical Company Nuclear Regulatory Commission Routine Inspection Report No. 05000264/2019201 IR 05000264/20192022019-10-30030 October 2019 Cover Letter - Dow Chemical Company - U.S. Nuclear Regulatory Commission Security Inspection Report No. 05000264/2019202 ML19063A4972019-02-22022 February 2019 Annual Report for the Dow Triga Research Nuclear Reactor, Docket No. 50-264 ML18365A3552019-01-0808 January 2019 Dow Chemical Company - Change of Facility Back-Up Project Manager IR 05000264/20182012018-10-19019 October 2018 Dow Chemical Company - U.S. Nuclear Regulatory Commission Routine Safety Inspection Report No. 05000264/2018201 ML18060A0792018-02-22022 February 2018 2017 Annual Report for the Dow Triga Research Reactor IR 05000264/20172012017-11-0808 November 2017 Dow Chemical Co., NRC Routine Inspection Report 05000264/2017201 ML17067A2792017-03-23023 March 2017 Dow Chemical Company - Non-Power Reactor Closeout of Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools, for the Dow Triga Research Reactor, Docket No. 50-264 (CAC No. A11010) ML17061A5102017-02-24024 February 2017 Annual Report for the Dow Triga Research Nuclear Reactor IR 05000264/20162022016-09-16016 September 2016 Dow Chemical Company, NRC Security Related Inspection Report 05000264/2016202 IR 05000264/20162012016-09-14014 September 2016 Dow Chemical Company - NRC Routine Inspection Report 05000264/2016201, July 19-21, 2016 ML16166A4152016-06-13013 June 2016 The Dow Triga Research Reactor, Response to NRC Generic Letter 2016-01: Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools ML16068A1772016-02-29029 February 2016 Dow Triga Research Nuclear Reactor - Transmittal of Annual Report for 2015 ML15364A3732016-01-19019 January 2016 Dow Chemical Company Triga Research Reactor - Closure of Confirmatory Action Letter No. NRR-04-009 on Site-Specific Compensatory Measures Implementation Plan ML14290A4862015-06-0303 June 2015 Y020140127 - Withdrawal of Order EA-05-007, Order Imposing Additional Security Measures ML15051A3672015-02-17017 February 2015 Annual Report 2014 for the Dow Triga Research Nuclear Reactor IR 05000264/20142012014-09-15015 September 2014 IR 05000264/2014201 on August 26-28, 2014 at Dow Chemical Company -NRC Routine Inspection Report No. 50-264/2014-201 ML14202A3282014-07-23023 July 2014 Dow Chemical Company Review of the Surety Bond Increase Rider and Updated Standby Trust Agreement (TAC No. M79548) ML12137A1512014-06-18018 June 2014 Dow Chemical Company - Letter to License and Renewed Facility Operating License No. R-108 for the Dow Triga Research Reactor (Tac No. ME1595) ML14129A2742014-05-27027 May 2014 Dow Chemical Company - Change of Facility Backup Project Manager ML14100A3492014-04-0909 April 2014 The Dow Chemical Co., Submittal of Responses to RAI Letter Dated 03/06/2014 and Dtrr Revised Technical Specifications ML14133A0182014-03-0707 March 2014 Dow Chemical Company Surety Bond Increase Rider and Updated Standby Trust Agreement Schedules (TAC M79548) ML14070A1792014-03-0707 March 2014 Dow Triga Research Reactor - Annual Report - 2013 ML14058B1342014-03-0606 March 2014 Dow Chemical Company Request for Additional Information Regarding Renewal of Facility Operating License No. R-108 for Dow Chemical Triga Research Reactor IR 05000264/20132012013-09-27027 September 2013 IR 05000264-13-201 on August 26-29, 2013 at Dow Chemical Company - NRC Routine Inspection Report ML13261A0262013-09-16016 September 2013 Letter from Dow Chemical Company Regarding Transmittal of Documents in Support of License Renewal ML13225A2512013-09-0606 September 2013 Dow Chemical Company - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor 2025-02-19
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML14058B1342014-03-0606 March 2014 Dow Chemical Company Request for Additional Information Regarding Renewal of Facility Operating License No. R-108 for Dow Chemical Triga Research Reactor ML13225A2512013-09-0606 September 2013 Dow Chemical Company - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor ML13157A4122013-06-26026 June 2013 Dow Chemical Company - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor ML12026A1522012-01-20020 January 2012 Dow Chemical Company - *Redacted* Revised Responses to NRC Request for Additional Information Questions 52, 54, and 56 in Support of the License Renewal (Tac ME1595) ML1117400552011-07-11011 July 2011 Dow Chemical Company - NON-PROPRIETARY Version - Request for Additional Information Regarding Financial Qualifications for the Dow Chemical Company Triga Research Reactor License Renewal (Tac No. ME1595). License No. R-108; Docket No. 50-26 ML1027003072010-11-0202 November 2010 Dow Chemical Company - Request for Additional Information Required for the License Renewal and Power Uprate Application Review ML1027900032010-10-27027 October 2010 Dow Chemical Company - Request for Additional Information Regarding the Operator Requalification Program for the License Renewal and Power Uprate Application Review ML1025202812010-09-16016 September 2010 Dow Chemical Company - Request for Additional Information Regarding the Emergency Plan for the License Renewal and Power Uprate Application Review ML1018101622010-07-12012 July 2010 Dow Chemical Company - Request for Additional Information Regarding the Environmental Assessment for the License Renewal Review (TAC Me1595) ML1016106562010-06-17017 June 2010 Dow Chemical Company, Request for Additional Information Regarding Financial Qualifications for Triga Research Reactor (Tac ME1595) ML0527102392005-10-0707 October 2005 RAI Letter - Security Measures - Rigot 2014-03-06
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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.