ML14196A044

Letter from Melinda Krahenbuhl Response to the Request for Additional Information Dated May 16, 2014

ML14196A044
Person / Time
Site:	Reed College
Issue date:	07/01/2014
From:	Krahenbuhl M Reed College
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14196A044 (29)

Text

REED COLLEGE REACTOR FACILITY 3203 Southeast Woodstock Boulevard Portland, Oregon 97202-8199 July 1, 2014 telephloe 503/777-7222 fax 503/777-7274 email reactor@reed.edu web http://reactor.reed.edu ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket: 50-288 License No: R-112 Enclosed are the following

1. Response to the Request for additional information dated May 16, 2014.

2. Mark-up version of chapter 6 of the current technical specifications.

3.

A table of proposed changes, basis for the proposed change and justifications for the proposed change.

4. The proposed final version of technical specifications chapter 6.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on

//

Melinda Krahenbuhl, Ph.D.

Director, Reed Research Reactor 0,9 0

9, Response to the request for additional information Dated May 16,2014

1. ANSI/ ANS -15.1-2007, Section 6.1.2,"Responsibility," states that "responsibility for the safe operation of the reactor facility shall be with the chain of command established in Fig. 1." in the proposed RRR TS 6.1.1, Figure 1, Administrative Structure, the Level 3 staffing includes "Reactor Operations Manager" and "Supervisor."

a. Proposed RRR 6.1.2, Specification c, only includes the title "Reactor Operations Manager". Please indicate if the level 3 title in proposed RRR TS 6.1.2, Specification c, should also include "Supervisor" to match the level 3 staffing in proposed RRR TS 6.1.1, Figure 1, or justify the current description.

b. Proposed RRR TS 6.1.2, Specification c, states that the Level 3 staffing includes "Supervisors", implying more than one Supervisor. Please indicate if the Level 3 position in proposed RRR TS 6.1.1, Figure 1, should say "Supervisors" to match proposed RRR TS 6.1.2, Specification c, or justify the current discrepancy.

RRR response Figure 1 in TS 6.1.1 Level 3 will be changed to changed to Supervisor(s).

Additionally TS 6.1.2 will also be changed to Supervisor(s).

A Supervisor helps the Operations Manager in completing day-to-day obligations. The plural of supervisor is used to accommodate and anticipate the changing needs of the program. All reactor staff holding the title of Supervisor will function as a Level 3 as described in ANSI/ANS 15.4 2007.

2. In the proposed RRR TS 6.1.1, Figure 1, Administrative Structure Level 4 staffing includes "Operating Staff." However, in the proposed RRR TS 6.1.2,"

Responsibility ", specification d, uses the title Operations Staff-Reactor Operators and Senior reactor operators." Please indicate if the level 4 title in the proposed RRR TS 6.1.2, Specification d, should say "Operating Staff" to match proposed RRR TS 6.1.1, Figure 1, or justify the current description.

RRR response TS 6.1.2 d will be changed to "Operating Staff." This change is included in Table 1.

3. In the current RRR TS 6.6.1, "Actions to be taken in the Case of Safety Limit Violation," Specification b, says '[a]n immediate notification of the occurrence shall be made to the Director, the Chair of the ROC, the NRC, and the President of Reed College." Part of this statement conflicts with the requirement stated in RRR TS 6.7.2, "Special Reports," Specification a, which states that the Director shall send a "a report no later than the following working day by telephone and confirmed in writing by facsimile to the NRC Operations Center..." Please

indicate if "the NRC should be removed from RRR TS 6.6.1, Specification b, or justify the current description.

RRR Response The phase "the NRC" will be removed from RRR TS 6.6.1. This change is noted in Table 1.

4. In the current RRR TS 6.2.3, "ROC review function," Specification a states, in part, that the Reactor Operations Committee (ROC) shall "[rleview changes made under 10 CFR 50.59." NUREG-1537 provides guidance that the review should include determinations that the proposed changes were allowed without prior NRC approval. However, TS 6.2.3 Specification a, does not include this determinations. Provide justification for TS 6.2.3, Specification a, or revise to include the review guidance for proposed changes consistent with the guidance in NUREG-1537.

RRR Response The current RRR TS 6.2.3 a. will be changed to "determinations that proposed changes in equipment, systems, test, experiments, or procedures are allowed without prior authorization by the U.S. NRC" This change is noted in Table 1.

5. In the current RRR TS 6.4, "Procedures," states in part, that "operating procedures shall be in effect... " but does not indicate if the procedures are required to be used and followed. Provided justification for TS 6.4, or revise to include guidance for that the procedures shall be "used".

RRR Response RRR TS 6.4 will be changed to:

"Operating procedures shall be in effect and used for the following:"

The change is noted in Table L.

6. Various references in the current RRR TSs refer to the NRC. For clarity, these references should indicate if the reference is:

a. The Document Control Desk, U.S. NRC, Washington, DC; or,

b. The U.S. NRC Headquarters Operations Center.

RRR Response The following technical specifications will be changed to:

RRR 6.7.1 "... the Document Control Desk, U.S. NRC Washington, DC..."

RRR 6.7.2 a. "... the U.S. NRC Headquarters Operation Center..."

"... 14 days to the Document Control Desk, U.S. NRC Washington, DC..."

I.

RRR 6.7.2 b "... writing to the Document Control Desk, U.S. NRC Washington, DC..."

These changes are also noted in Table 1.

7. The current RRR TS 6.8.2 states, in part, "records shall be retained at all times the individual is employed.... " However, if the individual were to leave the facility employment, there is no requirement to retain the record, and thus, no opportunity for the NRC review. Propose a revision to TS 6.8.2 such that "the records shall be retained for at least one complete requalification cycle, and maintained at all times the individual is employed,' or justify the controls established to ensure that the NRC will have the ability to review retraining and requalification records for all licensed reactor operators and senior reactor operators.

RRR Response TS 6.8.2 will be changed to include "for at least one complete requalification cycle and maintained" This change is included in Table 1.

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!TECHNICAL SPECIFICATIONS 6

ADMINISTRATIVE CONTROLS 6.1 Organization Individuals at the various management levels, in addition to being responsible for the policies and operation of the reactor facility, shall be responsible for safeguarding the public and facility personnel from undue radiation exposures and for adhering to all requirements of the operating license, TS, and federal regulations.

6.1.1 Structure The reactor administration shall be as shown in Figure 1. The Levels refer to ANSI/ANS-15.4-1988; R1999.

Figure 1: Administrative Structure Communication Authority

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TECHNICAL SPECIFICATIONS 6.1.2 Responsibility The following specific organizational levels and responsibilities shall exist.

a. President (Level 1): The President of Reed College is responsible for the facility license and represents Reed College,

b. Director and Asociatc Dirczter (Level 2): The Director reports to the President of Reed College via the Dean of the Faculty, and is accountable for ensuring that all regulatory requirements, including implementation, are in accordance with all requirements of the NRC and the Code of Federal Regulations. T,-,,e....

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Supe"cr (Level 3): Th*pcraticnu Supzrfiicr reports to the As.eei"e eieet-Director and is responsible for directing the activities of the reactor staff and for the day-to-day operation and maintenance of the reactor(*

d.Aeactor Operators and Senior Reactor Operators (Level 4): The Reactor Operators (RO) and Senior Reactor Operators (SRO) report to the.Operations Supe:vihor, Azjjciat'"

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, and the Director, and are primarily involved in the manipulation of reactor controls, monitoring of instrumentation, and operation and maintenance of reactor-related equipment.

e. Radiation Safety Officer: The Radiation: Safety Officer reports to the President of Reed College via the Vice President and Treasurer and is responsible for directing health physics activities including implementation of the radiation safety program. The Radiation Safety Officer shall communicate with the Reactor Director regarding health physics issues.

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TECHNICAL SPECIFICATIONS 6.1.3 Staffing Ao4-seLC\\A'(tA-

a. The minimum staffing when the reactor is epeaing shall be:

1. A licensed reactor operator in the control room;

2. A second person present in the reactor facility able to scram the reactor and summon help;

3. If neither of these two individuals is an SRO, a designated SRO shall be readily available on call. "Readily available on call" means an individual who:

a) has been specifically designated and the designation known to the operator on

duty, b) can be contacted quickly by the operator on duty, and c) is capable of getting to the reactor facility within 15 minutes.

b. A list of reactor facility personnel by name and telephone number shall be readily available in the control room for use by the operator. The list shall include:

1. Reactor Director;

.2.

3.

4.

5.

..... ioa Supervisor; Radiation Safety Officer; and At least one other person who is a licensed SRO.

c. Events whidh require the presence of an SRO in the facility shall include:

1. Initial start-up and approach to power of the day or following significant changes

(> $0.25) to the core;

2. All fuel or control rod relocations in the reactor core;

3. Maintenance on any reactor safety system;

4. Recovery from unscheduled reactor scram or significant power reduction; and

5. Relocation of any in-core experiment or irradiation facility with a reactivity worth greater than one dollar.

6.1.4 Selection and Training of Personnel The selection, training, and requalification of personnel should be in accordance with ANSI/ANS 15.4-1988; RI 999, "Standard for the Selection and Training of Personnel for Research Reactors."

Reed Research Reactor 37 April 2012 Reed Research Reactor 37 April 2012

TECHNICAL SPECIFICATIONS 6.2 Review And Audit The Reactor Operations Committee (ROC) shall have primary responsibility for review and audit of the safety aspects of reactor facility operations, and to assure that the facility is operated in a manner consistent with public safety and within the conditions specified in the facility license.

Minutes, findings, or reports of the ROC shall be presented to the President (Level 1) and the Director (Level 2) within ninety days of completion.

6.2.1 ROC Composition and Qualifications The ROC shall have at a minimum 3 members, at least two of whom are knowledgeable in fields that relate to physics and nuclear safety. The Dean of the Faculty, the Reactor Director, and the campus Radiation Safety Officer shall be voting members. Additional voting members shall be added at the President's discretion.

6.2.2 ROC Rules The operation of the ROC shall be in accordance with written procedures including provisions for:

a. Meeting frequency: not less than once per calendar year.

b. Quorums: a group consisting of at least half of.the voting members, of which the operating staff (i.e. the director and anyone who reports to that person) does not constitute a majority.

c. Use of subcommittees.

d. Review, approval, and dissemination of minutes.

6.2.3 ROC Review Function The responsibilities of the ROC, or designated subcommittee thereof, include, but are not limited to, the following:

a. Review 9hanges made under.

i0 CFR 50.59; (--

b. Review new procedures and substantive changes to existing procedures;

c. Review proposed changes to the TS or license;

d. Review violations of TS, license, or violations of internal procedures or instructions having safety significance;

e. Review operating abnormalities having safety significance;

f. Review events from reports required in Section 6.6.1 and 6.7.2 of these TS;

g. Review and approve new experiments under Section 6.5 of these TS; and

h. Review audit reports.

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TECHNICAL SPECIFICATIONS 6.2.4 ROC Audit Function The ROC, or a subcommittee thereof, shall audit reactor operations at least annually. The annual audit shall include at least the following:

a. Facility operations for conformance to these TS and applicable license conditions;

b. The requalification program for the operating staff;

c. The results of action taken to correct deficiencies that may occur in the reactor facility equipment, systems, structures, or methods of operation that affect reactor safety; and

d. The Emergency Plan and implementing procedures.

6.3 Radiation Safety The Radiation Safety Officer shall be responsible for implementation of the radiation safety program. The requirements of the radiation safety program are established in 10 CFR 20. The program shall use the guidelines of the ANSI/ANS 15.11-1993; R2004, "Radiation Protection at Research Reactor Facilities."

6.4 Procedures Written operating procedures shall be adequate to ensure the safe operation of the reactor, but shall not preclude the use of independent judgment and action if the situation requires. Operating procedures shall be in effect for the following:

a. Startup, operation, and shutdown of the reactor;

b. Fuel loading, unloading, and movement within the reactor;

c. Maintenance of major components of systems that could have an effect on reactor safety;

d. Surveillance checks, calibrations, and inspections required by the TS or those that have an effect on reactor safety;

e. Radiation protection;

f. Administrative controls for operations and maintenance and for the conduct of irradiations and experiments that could affect reactor safety or core reactivity;

g. Implementation of required plans, such as the Emergency and Security Plans; and

h. Use, receipt, and transfer of byproduct material held under the reactor license.

Substantive changes to the above procedures shall be made only after review and approval by the ROC. Non-substantive changes shall be reviewed and approved prior to implementation by the Director or Aikseiatc Dgirectr. *J.c 0 r 690 p'*4\\4 v\\

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Temporary deviations from the procedures may be made by the responsible SRO when the procedure contains errors or in order to deal with special or unusual circumstances or conditions.

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TECHNICAL SPECIFICATIONS 6.5 Experiment Review and Approval

a. Approved experiments shall be carried out in accordance with established and approved procedures.

b. All new experiments or classes of experiments shall be reviewed and approved by the ROC.

c. Substantive changes to previously approved experiments shall be made only after review by the ROC and approval in writing by the Director or :A,,,iate Dirfter. "ge,*c+o,- oeev.-V"

d. Minor changes that do not significantly alter the experiment may be approved by *& Aot t,

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6.6 Required Actions 6.6.1 Actions to Be Taken in Case of Safety Limit Violation In the event the safety limit is exceeded:

a. The reactor shall be shut down and reactor operation shall not be resumed until authorized by the NRC.

b. An immediate notification of the occurrence shall be made to the Director, the Chair of the ROC, 41i-N-R, and the President of Reed College.

c. A report shall be prepared and reviewed by the ROC. The report shall describe the following:

I. Applicable circumstances leading to the violation including, when known, the cause and contributing factors;

2. Effects of the violation upon reactor facility components, systems, or structures and on the health and safety of personnel and the public; and

3. Corrective action to be taken to prevent recurrence.

6.6.2 Actions to Be Taken in the Event of an Occurrence of the Type Identified in Section 6.7.2 Other than a Safety Limit Violation For all events that are required by regulations or TS to be reported to theANRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under Section 6.7.2, except a safety limit violation, the following actions shall be taken:

a. The reactor shall be shut down and the Director or "..qeeimea Dfrztzr and ROC chair notified; "a

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c. The ROC shall review the occurrence at or before their next scheduled meeting; and U..5

d. A report shall be submitted to the NRC in accordance with TS 6.7.2.

Reed Research Reactor 40 April 2012

TECHNICAL SPECIFICATIONS 6.7 Reports 6.7.1 Annual Operating Report CD An annual report shall be created and submitted by the Director to the NICQby November 1 of each year consisting of:

a. A brief summary of operating experience including the energy produced by the reactor;

b. The number of unscheduled shutdowns, including reasons therefor;

c. A tabulation of major preventative and corrective maintenance operations having safety significance;

d. A brief description, including a summary of the safety evaluations, of changes in the facility or in procedures and of tests and experiments carried out pursuant to 10 CFR 50.59;

e. A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or prior to the point of such release or discharge. The summary shall include to the extent practicable an estimate of individual radionuclides present in the effluent. If the estimated average release after dilution or diffusion is less than 25 percent of the concentration allowed or recommended, a statement to this effect is sufficient;

f. A summarized result of environmental surveys performed outside the facility; and

g. A summary of exposures received by facility personnel and visitors where such exposures are greater than 25 percent of that allowed.

Reed Research Reactor 41 April 2012

TECHNICAL SPECIFICATIONS

• 6.7.2 Special Reports In addition to the requirements of applicable regulations, and in no way substituting therefor, the Director shall report to the1.NRC as follows:

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a. A report not later than the following working day by telephone and confirmed in writing by facsimile to the "'RC O9pratis Gn Czntzi,. o be followed by a written report that describes the circumstances of the event within 14 days to the NT-RC Dz....umoont Ccnrcl Pook of any of the following:

1. Violation of the safety limit;

2. Release of radioactivity from the site above allowed limits;

3. Operation with actual safety system settings from required systems less conservative than the limiting safety system setting;

4. Operation in violation of limiting conditions for operation unless prompt remedial action is taken as permitted in Sec. 3;

5. A reactor safety system component malfunction that renders or could render the reactor safety system incapable of performing its intended safety function. If the malfunction or condition is caused by maintenance, then no report is required;

6. An unanticipated or uncontrolled change in reactivity greater than one dollar. Reactor trips resulting from a known cause are excluded;

7. Abnormal and significant degradation in reactor fuel or cladding, or both, coolant boundary, or confinement boundary (excluding minor leaks) where applicable; or

8. An observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to reactor operations.

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b. A report within 30 days in writing to the NRC Doetmr CGotvore Resi. of:

1. Permanent changes in the facility organization involving Level 1-2 personnel; or

2. Significant changes in the transient or accident analyses as described in the Safety Analysis Report.

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TECHNICAL SPECIFICATIONS 6.8 Records 6.8.1 Records to be Retained for a Period of at Least Five Years or for the Life of the Component Involved if Less than Five Years

a. Normal reactor operation;

b. Principal maintenance activities;

c. Reportable occurrences;

d. Surveillance activities required by the TS; e;

Reactor facility radiation and contamination surveys;

f. Experiments performed with the reactor;

g. Fuel inventories, receipts, and shipments;

h. Approved changes to the operating procedures; and

i. ROC meetings and audit reports.

6.8.2 Records to be Retained for the duration of a requalification cycle Records of retraining and-requalification of licensed reactor operators and senior reactor operators shall be retained" all times the individual is employed or until the certification is renewed. For the purpose of this technical specification, a certification is an NRC issued operator license.

6.8.3 a.

b.

C.

d.

e.

Records to be Retained for the Lifetime of the Reactor Facility Gaseous and liquid radioactive effluents released to the environs; Offsite environmental monitoring surveys; Radiation exposures for all personnel monitored; Drawings of the reactor facility; and Reviews and reports pertaining to a violation of the safety limit, the limiting safety system setting, or a limiting condition of operation.

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Table 1. Proposed changes to RRR Technical Specifications Affected Proposed changed Basis Justification RRR TS (Why the change is necessary)

(Why the change is acceptable) 6.1.1 Deletion of the title "Associate The Associate Director Position has The change is consistent with Figure 1 Director" been eliminated at Reed College.

ANSI/ANS-15.4 2007 and ANSI/ANS Level 2 15.1-2007.

6.1.1 Addition of the title "Reactor The Reactor Operations Manager The change is consistent with Figure 1 Operations Manager" position was created at Reed College.

ANSI/ANS-15.4 2007 and ANSI/ANS Level 3 The individual who holds this position 15.1-2007.

is responsible for the day-to-day obligations of reactor operation.

6.1.1 Deletion of the title "Operations The descriptor (operations) is The change is consistent with Figure 1 Supervisor" unnecessary.

ANSI/ANS-15.4 2007 and ANSI/ANS Level 3 15.1-2007.

6.1.1 Addition of title "Supervisor(s)"

A Supervisor helps the Reactor The change is consistent with Figure 1 Operations Manager in completing ANSI/ANS-15.4 2007 and ANSI/ANS Level 3 day-to-day obligations. The plural of 15.1-2007.

supervisor is used to accommodate and anticipate the changing needs of the program. All reactor staff holding the title of Supervisor will function as a Level 3 as described in ANSI/ANS 15.42007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.42007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1.1 Removal of "Reactor Operators" Level 4 personnel are both Senior The change is consistent with Figure 1 Reactor Operators and Reactor ANSI/ANS-15.4 2007 and ANSI/ANS Level 4 Operators.

15.1-2007.

Page 1 of 7

6.1.2. b Removal of "and Associate Director" The Associate Director Position has The change is consistent with been eliminated at Reed College.

ANSI/ANS-15.4 2007 and ANSI/ANS 15.1-2007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.1-2007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1.2 b Removal of" The Associate Director The Associate Director position has The change is consistent with reports to the Director and is been eliminated at Reed College.

ANSI/ANS-15.4 2007 and ANSI/ANS responsible for guidance, oversight 15.1-2007.

and technical support of reactor operations" 6.1.2 c Removal of "Operations Supervisor",

The Associate Director position has The change is consistent with "Operations Supervisor", and been eliminated at Reed College. All ANSI/ANS-15.4 2007 and ANSI/ANS "Associate Director and" reactor staff holding the title of 15.1-2007.

Supervisor will function as a Level 3 as described in ANSI/ANS 15.4 2007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.4 2007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1.2 c Addition of The Reactor Operations Manager is The change is consistent with

1. "Reactor Operations Manager and responsible for the day-to-day ANSI/ANS-15.4 2007 and ANSI/ANS Supervisor(s)"

operations. The Reactor Operations 15.1-2007.

2. "Reactor Operations Manager" Manager directs the Supervisor(s) in completing tasks needed for operating and maintaining the RRR program.

6.1.2 c Addition of The Reactor Operations Manager is The change is consistent with

3. "The Supervisor(s) report to the responsible for the day-to-day ANSI/ANS 15.4 2007 and ANSI/ANS Reactor Operations Manager."

operations. The Reactor Operations 15.1-2007.

Manager directs the Supervisor(s) in completing tasks needed for operating and maintaining the RRR program.

6.1.2 d Addition of Operating staff is the collective term The change is consistent with 4."Operating Staff-"

used for Senior Reactor Operators and ANSI/ANS 15.4 2007 and ANSI/ANS Reactor Operators.

15.1-2007.

Page 2 of 7

6.1.2 d Deletion of "Operations Supervisor, Associate Director position has been The change is consistent with Associate Director" eliminated at Reed College. The ANSI/ANS 15.4 2007 and ANSI/ANS descriptor (operations) is unnecessary.

15.1-2007.

6.1.2 d Addition of The Operating Staff report to the The change is consistent with

5. "Supervisor(s), Reactor Operations Supervisor(s) and Reactor Operations ANSI/ANS 15.4 2007 and ANSI/ANS Manager" Manager.

15.1-2007.

6.1.3 Deletion of "operating" and the The change clarifies the specification.

The change is consistent with Addition of "not secured" Specifically, 'operating' could be ANSI/ANS 15.1-2007.

interpreted as only when the reactor is generating thermal power. By changing operating to "not secured" an licensed reactor operator must be at the console when the key is in.

6.1.3 b 2 Deletion of "Reactor Associate The Associate Director position has The change is consistent with Director" been eliminated at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS 15.1-2007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.1-2007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1.3 b 2 Addition of "Reactor Operations The Reactor Operations Manager The change is consistent with Manager" position was created at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS The individual who holds this position 15.1-2007.

is responsible for the day-to-day obligations of reactor operation.

6.1.3.b 3 Deletion of "Operations" The descriptor (operations) is The change is consistent with unnecessary. All reactor staff holding ANSI/ANS 15.4 2007 and ANSI/ANS the title of Supervisor will function as 15.1-2007.

a Level 3 as described in ANSI/ANS 15.4 2007. Only one Supervisor shall be required to be on the call list.

Page 3 of 7

6.2.3 Deletion of "Review Changes made The specification might be The change is consistent with under 10 CRF 50.59" misinterpreted as only reviewing ANSI/ANS 15.4 2007 and ANSI/ANS changes that were approved through 15.1-2007.

the 10 CFR 50.59 process.

6.2.3 Addition of This specification is specific and will The change is consistent with 6." Review determinations that reduce possible misinterpretations.

ANSI/ANS 15.1-2007 proposed changes in equipment, systems, test, experiments or procedures are allowed without prior authorization by the U.S. NRC."

6.4 Insertion of "and used" Although "in effect" implies that the The change is consistent with procedures are used, the inclusion of ANSI/ANS 15.1-2007 the word "used" is more definitive.

6.4 Deletion of "Associate Director" and The Associate Director Position has The change is consistent with "Associate Director" been eliminated at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS 15.1-2007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.1-2007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..4 Addition of "Reactor Operations The Reactor Operations Manager The change is consistent with Manager" and "Reactor Operations position was created at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS Manager" The individual who holds this position 15.1-2007.

is responsible for the day-to-day obligations of reactor operation.

6.5 c Deletion of "Associate Director" The Associate Director Position has The change is consistent with been eliminated at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS 15.1-2007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.1-2007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..5 c Addition of "Reactor Operations The Reactor Operations Manager The change is consistent with Manager" position was created at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS The individual who holds this position 15.1-2007.

is responsible for the day-to-day obligations of reactor operation.

Page 4 of 7

6.5 d Deletion of" the Operations" and The descriptor (operations) is The change is consistent with "Associate Director" unnecessary. All reactor staff holding ANSI/ANS 15.4 2007 and ANSI/ANS the title of Supervisor will function as 15.1-2007.

a Level 3 as described in ANSI/ANS 15.4 2007. The Associate Director Position has been eliminated at Reed College.

6.5 d Addition of "a" and "Reactor The Reactor Operations Manager The change is consistent with Operations Manager" position was created at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS The individual who holds this position 15.1-2007.

is responsible for the day-to-day obligations of reactor operation.

6.6.1 b Deletion of "the NRC,"

The inclusion of the NRC in the The change is consistent with current TS 6.6.1 conflicts with RRR ANSI/ANS 15.1-2007.

TS 6.7.2. The notification of the NRC after a Safety Limit Violation is described in RRR TS 6.7.2. The notification timeline indicated in RRR TS 6.7.2 is consistent with ANSI/ANS 15.1-2007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.1-2007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..6.2 Addition of "U.S."

The inclusion of specific designations As requested in the Request for and official titles for licensing Additional Information dated May 16, authority as described in ANSI/ANS 2014.

15-1-2007 provides clarity.

6.6.2 a Deletion of "Associate Director" The Associate Director Position has The change is consistent with been eliminated at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS 15.1-2007.

Page 5 of 7

6.6.2 a Addition of "Reactor Operations The Reactor Operations Manager The change is consistent with Manager" position was created at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS The individual who holds this position 15.1-2007.

is responsible for the day-to-day obligations of reactor operation.

6.6.2 b Deletion of "Associate Director" The Associate Director Position has The change is consistent with been eliminated at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS 15.1-2007.

6Property "ANSI code" (as page type) with input value "ANSI/ANS 15.1-2007.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..6.2 b Addition of "Reactor Operations The Reactor Operations Manager The change is consistent with Manager" position was created at Reed College.

ANSI/ANS 15.4 2007 and ANSI/ANS The individual who holds this position 15.1-2007.

is responsible for the day-to-day obligations of reactor operation.

6.6.2 d Addition of "U.S."

The inclusion of specific designations As requested in the Request for and official titles for licensing Additional Information dated May 16, authority as described in ANSI/ANS 2014.

15-1-2007 provides clarity.

6.7.1 Deletion "NRC" The inclusion of specific designations As requested in the Request for Addition and official titles for licensing Additional Information dated May 16,

7. "Document Control Desk, U.S.

authority as described in ANSI/ANS 2014.

NRC Washington, DC" 15-1-2007 provides clarity.

6.7.2 Addition of "U.S."

The inclusion of specific designations As requested in the Request for and official titles for licensing Additional Information dated May 16, authority as described in ANSI/ANS 2014.

15-1-2007 provides clarity.

I Page 6 of 7

6.7.2a Deletion of "NRC Operations Center" The inclusion of specific designations As requested in the Request for and "NRC Document Control Desk" and official titles for licensing Additional Information dated May 16, Addition of authority as described in ANSI/ANS 2014.

8. "U.S. NRC Headquarters Operation 15-1-2007 provides clarity.

Center" and

9. "Document Control Desk, U.S.

NRC Washington, DC" 6.7.2 b Deletion of "NRC Document Control The inclusion of specific designations As requested in the Request for Desk" and official titles for licensing Additional Information dated May 16, Addition of authority as described in ANSI/ANS 2014.

10. "Document Control Desk, U.S.

15-1-2007 provides clarity.

NRC Washington, DC" 6.8.2 Addition of The inclusion clarifies the record This change is consistent with

11. "for at least one complete retention for of operators that ensures ANSI/ANS 15-1-2007.

requalification cycle and maintained that the NRC has the ability to review at" retraining and requalification records for licensed operators.

Page 7 of 7

TECHNICAL SPECIFICATIONS 6

ADMINISTRATIVE CONTROLS 6.1 Organization Individuals at the various management levels, in addition to being responsible for the policies and operation of the reactor facility, shall be responsible for safeguarding the public and facility personnel from undue radiation exposures and for adhering to all requirements of the operating license, TS, and federal regulations.

6.1.1 Structure The reactor administration shall be as shown in Figure 1. The Levels refer to ANSI/ANS-15.4-1988; R1999.

Figure 1: Administrative Structure Level 1 President of Reed College Dean of Faculty

[

Vice President & Treasurer Reco Oprtin Lee 2J adation SafetyvOf~fcer~

~Leve 13 Reactor Operations Manager, E

Suoervisorl's)

I Level 4 Communication F

Operating Staff IAuthority Reed Research Reactor 35 proposed July 1, 2014

TECHNICAL SPECIFICATIONS 6.1.2 Responsibility The following specific organizational levels and responsibilities shall exist.

a. President (Level 1): The President of Reed College is responsible for the facility license and represents Reed College.

b. Director (Level. 2): The Director reports to the President of Reed College via the Dean of the Faculty, and is accountable for ensuring that all regulatory requirements, including implementation, are in accordance with all requirements of the NRC and the Code of Federal Regulations.

c. Reactor Operations Manager and Supervisor(s) (Level 3): The Reactor Operations Manager reports to the Director and is responsible for directing the activities of the reactor staff and for the day-to-day operation and maintenance of the reactor. The Supervisor(s) report to the Reactor Operations Manager.

d.

Operating Staff-Reactor Operators and Senior Reactor Operators (level 4): The Reactor Operators (RO) and Senior Reactor Operators (SRO) report to the Supervisor(s), Reactor Operations Manager and the Director, and are primarily involved in the manipulation of reactor controls, monitoring of instrumentation, and operation and maintenance of reactor related equipment.

e. Radiation Safety Officer: The Radiation Safety Officer reports to the President of Reed College via the Vice President and Treasurer and is responsible for directing health physics activities including implementation of the radiation safety program. The Radiation Safety Officer shall communicate with the Reactor Director regarding health physics issues.

Reed Research Reactor 36 proposed July 1, 2014

TECHNICAL SPECIFICATIONS 6.1.3 Staffing

a. The minimum staffing when the reactor is not secured shall be:

1. A licensed reactor operator in the control room;

2. A second person present in the reactor facility able to scram the reactor and summon help;

3. If neither of these two individuals is an SRO, a designated SRO shall be readily available on call. "Readily available on call" means an individual who:

a) has been specifically designated and the designation known to the operator on

duty, b) can be contacted quickly by the operator on duty, and c) is capable of getting to the reactor facility within 15 minutes.

b. A list of reactor facility personnel by name and telephone number shall be readily available in the control room for use by the operator. The list shall include:

1. Reactor Director;

2. Reactor Operations Manager;

3. Supervisor

4. Radiation Safety Officer; and

5. At least one other person who is a licensed SRO.

c. Events which require the presence of an SRO in the facility shall include:

1. Initial start-up and approach to power of the day or following significant changes

(> $0.25) to the core;

2. All fuel or control rod relocations in the reactor core;

3. Maintenance on any reactor safety system;

4. Recovery from unscheduled reactor scram or significant power reduction; and

5. Relocation of any in-core experiment or irradiation facility with a reactivity worth greater than one dollar.

6.1.4 Selection and Training of Personnel The selection, training, and requalification of personnel should be in accordance with ANSI/ANS 15.4-1988; R1999, "Standard for the Selection and Training of Personnel for Research Reactors."

Reed Research Reactor proposed July 1, 2014 37

TECHNICAL SPECIFICATIONS 6.2 Review And Audit The Reactor Operations Committee (ROC) shall have primary responsibility for review and audit of the safety aspects of reactor facility operations, and to assure that the facility is operated in a manner consistent with public safety and within the conditions specified in the facility license.

Minutes, findings, or reports of the ROC shall be presented to the President (Level 1) and the Director (Level 2) within ninety days of completion.

6.2.1 ROC Composition and Qualifications The ROC shall have at a minimum 3 members, at least two of whom are knowledgeable in fields that relate to physics and nuclear safety. The Dean of the Faculty, the Reactor Director, and the campus Radiation Safety Officer shall be voting members. Additional voting members shall be added at the President's discretion.

6.2.2 ROC Rules The operation of the ROC shall be in accordance with written procedures including provisions for:

a. Meeting frequency: not less than once per calendar year.

b. Quorums: a group consisting of at least half of the voting members, of which the operating staff (i.e. the director and anyone who reports to that person) does not constitute a majority.

c. Use of subcommittees.

d. Review, approval, and dissemination of minutes.

6.2.3 ROC Review Function The responsibilities of the ROC, or designated subcommittee thereof, include, but are not limited to, the following:

a. Review determinations that proposed changes in equipment, systems tests, experiments or procedures are allowed without prior authorization by the U.S. NRC;

b. Review new procedures and substantive changes to existing procedures;

c. Review proposed changes to the TS or license;

d. Review violations of TS, license, or violations of internal procedures or instructions having safety significance;

e. Review operating abnormalities having safety significance;

f. Review events from reports required in Section 6.6.1 and 6.7.2 of these TS;

g. Review and approve new experiments under Section 6.5 of these TS; and

h. Review audit reports.

R'eed Research Reactor 38 proposed July 1, 2014

TECHNICAL SPECIFICATIONS 6.2.4 ROC Audit Function The ROC, or a subcommittee thereof, shall audit reactor operations at least annually. The annual audit shall include at least the following:

a. Facility operations for conformance to these TS and applicable license conditions;

b. The requalification program for the operating staff;

c. The results of action taken to correct deficiencies that may occur in the reactor facility equipment, systems, structures, or methods of operation that affect reactor safety; and

d. The Emergency Plan and implementing procedures.

6.3 Radiation Safety The Radiation Safety Officer shall be responsible for implementation of the radiation safety program. The requirements of the radiation safety program are established in 10 CFR 20. The program shall use the guidelines of the ANSI/ANS 15.11-1993; R2004, "Radiation Protection at Research Reactor Facilities."

6.4 Procedures Written operating procedures shall be adequate to ensure the safe operation of the reactor, but shall not preclude the use of independent judgment and action if the situation requires. Operating procedures shall be in effect an used for the following:

a. Startup, operation, and shutdown of the reactor;

b. Fuel loading, unloading, and movement within the reactor;

c. Maintenance of major components of systems that could have an effect on reactor safety;

d. Surveillance checks, calibrations, and inspections required by the TS or those that have an effect on reactor safety;

e. Radiation protection;

f. Administrative controls for operations and maintenance and for the conduct of irradiations and experiments that could affect reactor safety or core reactivity;

g. Implementation of required plans, such as the Emergency and Security Plans; and

h. Use, receipt, and transfer of byproduct material held under the reactor license.

Substantive changes to the above procedures shall be made only after review and approval by the ROC. Non-substantive changes shall be reviewed and approved prior to implementation by the Director or Reactor Operations Manager.

Temporary deviations from the procedures may be made by the responsible SRO when the procedure contains errors or in order to deal with special or unusual circumstances or conditions.

Such deviations shall be documented and reported by the next working day to the Director or Reactor Operations Manager.

Reed Research Reactor 39 proposed July 1, 2014

TECHNICAL SPECIFICATIONS 6.5 Experiment Review and Approval

a. Approved experiments shall be carried out in accordance with established and approved procedures.

b. All new experiments or classes of experiments shall be reviewed and approved by the ROC.

c. Substantive changes to previously approved experiments shall be made only after review by the ROC and approval in writing by the Director or Reactor Operations Manager.

d. Minor changes that do not significantly alter the experiment may be approved by the a Supervisor, Reactor Operations Manager, or Director.

6.6 Required Actions 6.6.1 Actions to Be Taken in Case of Safety Limit Violation In the event the safety limit is exceeded:

a. The reactor shall be shut down and reactor operation shall not be resumed until authorized by the NRC.

b. An immediate notification of the occurrence shall be made to the Director, the Chair of the ROC, and the President of Reed College.

c. A report shall be prepared and reviewed by the ROC. The report shall describe the following:

1. Applicable circumstances leading to the violation including, when known, the cause and contributing factors;

2. Effects of the violation upon reactor facility components, systems, or structures and on the health and safety of personnel and the public; and

3. Corrective action to be taken to prevent recurrence.

6.6.2 Actions to Be Taken in the Event of an Occurrence of the Type Identified in Section 6.7.2 Other than a Safety Limit Violation For all events that are required by regulations or TS to be reported to the U.S. NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under Section 6.7.2, except a safety limit violation, the following actions shall be taken:

a. The reactor shall be shut down and the Director or Reactor Operations Manager and ROC chair notified;

b. Operations shall not resume unless authorized by the Director or Reactor Operations Manager;

c. The ROC shall review the occurrence at or before their next scheduled meeting; and

d. A report shall be submitted to the U.S. NRC in accordance with TS 6.7.2.

Reed Research Reactor proposed July 1, 2014 40

TECHNICAL SPECIFICATIONS 6.7 Reports 6.7.1 Annual Operating Report An annual report shall be created and submitted by the Director to the Document Control Desk, U.S. NRC, Washington DC by November 1 of each year consisting of:

a. A brief summary of operating experience including the energy produced by the reactor;

b. The number of unscheduled shutdowns, including reasons therefor;

c. A tabulation of major preventative and corrective maintenance operations having safety significance;

d. A brief description, including a summary of the safety evaluations, of changes in the facility or in procedures and of tests and experiments carried out pursuant to 10 CFR 50.59;

e. A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or prior to the point of such release or discharge. The summary shall include to the extent practicable an estimate of individual radionuclides present in the effluent. If the estimated average release after dilution or.diffusion is less than 25 percent of the concentration allowed or recommended, a statement to this effect is sufficient;

f. A summarized result of environmental surveys performed outside the facility; and

g. A summary of exposures received by facility personnel and visitors where such exposures are greater than 25 percent of that allowed.

Reed Research Reactor 41 proposed July 1, 2014

TECHNICAL SPECIFICATIONS 6.7.2 Special Reports In addition to the requirements of applicable regulations, and in no way substituting therefor, the Director shall report to the NRC as follows:

a. A report not later than the following working day by telephone and confirmed in writing by facsimile to the U.S. NRC Headquarters Operations Center, to be followed by a written report that describes the circumstances of the event within 14 days to the Document Control Desk, U.S. NRC Washington DC of any of the following:

1. Violation of the safety limit;

2. Release of radioactivity from the site above allowed limits;

3. Operation with actual safety system settings from required systems less conservative than the limiting safety system setting;

4. Operation in violation of limiting conditions for operation unless prompt remedial action is taken as permitted in Sec. 3;

5. A reactor safety system component malfunction that renders or could render the reactor safety system incapable of performing its intended safety function. If the malfunction or condition is caused by maintenance, then no report is required;

6. An unanticipated or uncontrolled change in reactivity greater than one dollar. Reactor trips resulting from a known cause are excluded;

7. Abnormal and significant degradation in reactor fuel or cladding, or both, coolant boundary, or confinement boundary (excluding minor leaks) where applicable; or

8. An observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to reactor operations.

b. A report within 30 days in writing to the Document Control Desk, U.S. NRC Washington DC of:

1. Permanent changes in the facility organization involving Level 1-2 personnel; or

2. Significant changes in the transient or accident analyses as described in the Safety Analysis Report.

Reed Research Reactor 42 proposed July 1, 2014

TECHNICAL SPECIFICATIONS 6.8 Records 6.8.1 Records to be Retained for a Period of at Least Five Years or for the Life of the Component Involved if Less than Five Years

a. Normal reactor operation;

b. Principal maintenance activities;

c. Reportable occurrences;

d. Surveillance activities required by the TS;

e. Reactor facility radiation and contamination surveys;

f. Experiments performed with the reactor;

g. Fuel inventories, receipts, and shipments;

h. Approved changes to the operating procedures; and

i. ROC meetings and audit reports.

6.8.2 Records to be Retained for the duration of a requalification cycle Records of retraining and requalification of licensed reactor operators and senior reactor operators shall be retained for at least one complete requalification cycle and maintained at all times the individual is employed or until the certification is renewed. For the purpose of this technical specification, a certification is an NRC issued operator license.

6.8.3 Records to be Retained for the Lifetime of the Reactor Facility

a. Gaseous and liquid radioactive effluents released to the environs;

b. Offsite environmental monitoring surveys;

c. Radiation exposures for all personnel monitored;

d. Drawings of the reactor facility; and

e. Reviews and reports pertaining to a violation of the safety limit, the limiting safety system setting, or a limiting condition of operation.

Reed Research Reactor proposed July 1, 2014 43