ML14279A077

Reed College - Issuance of Amendment No. 9 to Renewed Facility Operating License No. R-112, for the Reed Research Reactor, Regarding Technical Specifications, Administrative Controls

ML14279A077
Person / Time
Site:	Reed College
Issue date:	09/28/2015
From:	Geoffrey Wertz Research and Test Reactors Branch B
To:	Krahenbuhl M Reed College
Wertz G
References
TAC MF1928
Download: ML14279A077 (30)

Text

September 28, 2015 Dr. Melinda Krahenbuhl, Director The Reed Research Reactor Reed College 3203 SE Woodstock Blvd.

Portland, OR 97202-8199

SUBJECT:

REED COLLEGE - ISSUANCE OF AMENDMENT NO. 9 TO RENEWED FACILITY OPERATING LICENSE NO. R-112, FOR THE REED RESEARCH REACTOR RE: TECHNICAL SPECIFICATIONS, ADMINISTRATIVE CONTROLS (TAC NO. MF1928)

Dear Dr. Krahenbuhl:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 9 to Renewed Facility Operating License No. R-112 for the Reed Research Reactor (RRR). The amendment consists of changes to the facility operating license and technical specifications (TSs) in response to your application dated May 24, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13149A016), as supplemented by letters dated July 17, September 17, October 4, and October 25, 2013; February 12 and July 1, 2014; and July 10, 2015 (ADAMS Accession Nos. ML13212A100, ML13270A086, ML13289A180, ML13310A307, ML14055A403, ML14196A044, and ML15203A555, respectively).

This amendment implements changes to the RRR TSs, Section 6, Administrative Controls.

These changes include: 1) replacing the titles of Associate Director and Operations Supervisor with Reactor Operations Manager; 2) clarification of the Reactor Oversight Committee review of facility changes; 3) notifications required in case of a safety limit violation;

4) procedure adherence; 5) references to the U.S. NRC; and 6) retention of records of licensed operators.

M. Krahenbuhl The safety evaluation supporting Amendment No. 9 is enclosed. If you have any questions, please contact me at (301) 415-0893.

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. 50-288 Renewed License No. R-112

Enclosures:

1. Amendment No. 9

2. Safety Evaluation cc w/encls: See next page

Reed College Docket No. 50-288 cc:

Mayor of the City of Portland 1220 Southwest 5th Avenue Portland, OR 97204 Dr. Nigel Nicholson, Dean of Faculty Reed College 3203 SE Woodstock Boulevard Portland, OR 97202-8199 Mr. John Kroger, President Reed College 3203 SE Woodstock Boulevard Portland, OR 97202-8199 Division Administrator Nuclear Safety Division Oregon Department of Energy 625 Marion Street NE Salem, OR 97301-3737 Program Director Radiation Protection Services Public Health Division Oregon Health Authority 800 NE Oregon Street, Suite 640 Portland, OR 97232-2162 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML14279A077 *concurrence via e-mail NRR-088 OFFICE NRR/DPR/PRLB/PM* NRR/DPR/PRLB/LA OGC NRR/DPR/PRLB/BC NRR/DPR/PRLB/PM NAME GWertz ELee MYoung AAdams (AAdams for) GWertz DATE 08/17/2015 08/14/2015 09/28/2015 08/26/2015 09/28/2015 REED COLLEGE DOCKET NO. 50-288 REED RESEARCH REACTOR AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 9 Renewed License No. R-112

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for an amendment to Renewed Facility Operating License No. R-112 filed by Reed College (the licensee) on May 24, 2013, as supplemented by letters dated July 17, September 17, October 4, and October 25, 2013; February 12, and July 1, 2014; and July 10, 2015, conforms to the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the regulations of the Commission as stated in Chapter I of Title 10 of the Code of Federal Regulations (10 CFR);

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance that (i) the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) such activities will be conducted in compliance with the regulations of the Commission; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; E. This amendment is issued in accordance with the regulations of the Commission as stated in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, and all applicable requirements have been satisfied; and F. Prior notice of this amendment was not required by 10 CFR 2.105, Notice of proposed action, and publication of a notice for this amendment is not required by 10 CFR 2.106, Notice of issuance.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the enclosure to this license amendment, and paragraph C.(2) of Renewed Facility Operating License No. R-112 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised by Amendment No. 9, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Alexander Adams, Jr., Chief Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License and Technical Specifications Date of Issuance: September 28, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 9 RENEWED FACILITY OPERATING LICENSE NO. R-112 DOCKET NO. 50-288 Replace the following page of Renewed Facility Operating License No. R-112 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Renewed Facility Operating License REMOVE INSERT Page 3 Page 3

(3) Pursuant to the Act and 10 CFR Part 30, the following activities are included:

a. to receive, possess, and use, in connection with the operation of the facility, a 1.64-curie sealed americium-beryllium neutron startup source;

b. to receive, possess, and use, but not separate, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor.

C. This license shall be deemed to contain and is subject to the conditions specified in 10 CFR Parts 20, 30, 50, 51, 55, 70 and 73 of the Commissions regulations; is subject to all applicable provisions of the Act, and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at a steady-state power level not in excess of 250 kilowatts (thermal) as specified in the Technical Specifications.

(2) Technical Specification The Technical Specifications contained in Appendix A, as revised by Amendment No. 9, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Physical Security Plan The licensee shall maintain and fully implement all provisions of the Commission-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p). The approved physical security plan entitled "Physical Security Plan for Reed College Reactor Facility" dated June 1983, submitted by letter dated November 10, 1983, as supplemented by letter dated February 22, 1984, consists of documents withheld from public disclosure pursuant to 10 CFR 2.390(d).

Amendment No. 9

ATTACHMENT TO LICENSE AMENDMENT NO. 9 RENEWED FACILITY OPERATING LICENSE NO. R-112 DOCKET NO. 50-288 Replace the following pages of Appendix A, "Technical Specifications," with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Technical Specifications REMOVE INSERT Page 35 Page 35 Page 36 Page 36 Page 37 Page 37 Page 38 Page 38 Page 39 Page 39 Page 40 Page 40 Page 41 Page 41 Page 42 Page 42 Page 43 Page 43

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.

Reed Research Reactor 35 Amendment No. 9 September 28, 2015

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 U.S. 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 Amendment No. 9 September 28, 2015

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 37 Amendment No. 9 September 28, 2015

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 Presidents 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.

Reed Research Reactor 38 Amendment No. 9 September 28, 2015

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 and 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 Amendment No. 9 September 28, 2015

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 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 40 Amendment No. 9 September 28, 2015

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 Amendment No. 9 September 28, 2015

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 U.S. 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 Amendment No. 9 September 28, 2015

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 43 Amendment No. 9 September 28, 2015

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 9 TO RENEWED FACILITY OPERATING LICENSE NO. R-112 REED COLLEGE REED RESEARCH REACTOR DOCKET NO. 50-288

1.0 INTRODUCTION

By letter dated May 24, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13149A016), as supplemented by letters dated July 17, September 17, October 4, and October 25, 2013; February 12 and July 1, 2014; and July 10, 2015 (ADAMS Accession Nos. ML13212A100 ML13270A086, ML13289A180, ML13310A307, ML14055A403, ML14196A044, and ML15203A555, respectively), Reed College (the licensee) requested an amendment to the Technical Specifications (TSs) for the Reed Research Reactor (RRR). The proposed amendment would implement several changes to TS Section 6, Administrative Controls. The proposed changes include replacing the title of Associate Director (Level 2) and Operations Supervisor (Level 3) with Reactor Operations Manager and Supervisor(s) (Level 3) in several TSs in Section 6. The minimum staffing requirements in TS 6.1.3.a would be revised from reactor is operating to reactor is not secured. The review requirements for the Reactor Oversight Committee (ROC), associated with facility changes, would be revised in TS 6.2.3.a. TS 6.4, would be revised to require procedure use. TS 6.8.2 would be revised to clarify the retention requirements for the retraining and requalification of licensed operators. The NRC notification requirements in TS 6.6 would be revised to be consistent with the proposed title change to Reactor Operations Manager.

Various TS Section 6 references to the U.S. NRC would also be revised for consistency.

During its review, the NRC staff identified areas where clarification and additional information was needed from the licensee. Requests for additional information (RAIs) were sent to the licensee on August 27, 2013, May 16, 2014, and June 25, 2015 (ADAMS Accession Nos.

ML13238A297, ML14121A546, and ML15170A273). The licensee provided responses to the NRC staff RAIs by letters dated September 17, October 4, and October 25, 2013; July 1, 2014; and July 10, 2015 (ADAMS Accession Numbers ML13270A086, ML13289A180, ML13310A307, ML14196A044, and ML15203A555, respectively). Additional information was also provided by the licensee in letters dated July 17, 2013, and February 12, 2014 (ADAMS Accession Numbers ML13212A100 and ML14055A403, respectively).

Enclosure

2.0 EVALUATION The RRR Facility Operating License, R-112, was renewed on April 25, 2012 (ADAMS Accession No. ML120530018) and included renewal TSs. The renewal TSs were reissued by letter dated May 24, 2012, to correct an administrative error (ADAMS Accession No. ML12143A181).

2.1 Reactor Operations Manager, Supervisor(s), and Operating Staff By letter dated May 24, 2013, the licensee proposed an amendment to change the position of Associate Director to Reactor Operations Manager. The Associate Director is currently a Level 2 position in the RRR TS 6.1.1 Structure and the new position of Reactor Operations Manager will be a Level 3 position. The licensee also proposed to change the title of Operations Supervisor to Supervisor(s), and the title Reactor Operators to Operating Staff. The proposed title changes affected the following RRR TSs in Section 6, Administrative Controls:

1. TS 6.1.1,Structure, Figure 1: Administrative Structure;

2. TS 6.1.2.b, c, and d, Responsibility;

3. TS 6.1.3.b.2 and 3, Staffing;

4. TS 6.4, Procedures;

5. TS 6.5.c and d, Experiment Review and Approval; and

6. TS 6.6.2.a and b, 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.

The current TSs and the proposed TSs are set forth below to illustrate the proposed changes requested by the licensee.

The current TS 6.1.1 Figure 1

The proposed TS 6.1.1, Figure 1 The current TS 6.1.2 states:

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

b. Director and Associate 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. The Associate Director reports to the Director and is responsible for guidance, oversight, and technical support of reactor operations.

c. Operations Supervisor (Level 3): The Operations Supervisor reports to the Associate Director and 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. Reactor Operators and Senior Reactor Operators (Level 4): The Reactor Operators (RO) and Senior Reactor Operators (SRO) report to the Operations Supervisor, Associate Director, and the Director, and are primarily involved in the manipulation of reactor controls, monitoring of instrumentation, and operation and maintenance of reactor-related equipment.

The proposed TS 6.1.2 states:

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

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 U.S. 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.

The current TS 6.1.3.b.2 and 3 state:

6.1.3 Staffing

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

2. Reactor Associate Director;

3. Operations Supervisor(s);

The proposed TS 6.1.3.b.2 and 3 state:

6.1.3 Staffing

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

2. Reactor Operations Manager;

3. Supervisor(s);

The current TS 6.4 states:

6.4 Procedures 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 Associate Director.

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 Associate Director.

The proposed TS 6.4 states:

Procedures 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.

The current TS 6.5.c and d state:

6.5 Experiment Review and Approval

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

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

The proposed TS 6.5.c and d state:

6.5 Experiment Review and Approval

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 a Supervisor, Reactor Operations Manager, or Director.

The current TS 6.6.2.a and b state:

6.6.2 Action to Be Taken in the Event of an Occurrence of the Type Identified in Section 6.7.2 Other than a Safety Limit Violation

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

b. Operations shall not resume unless authorized by the Director or Associate Director; The proposed TS 6.6.2.a and b state:

6.6.2 Action to Be Taken in the Event of an Occurrence of the Type Identified in Section 6.7.2 Other than a Safety Limit Violation

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; The licensees proposed changes would: 1) eliminate the position of Associate Director in Level 2 of its administrative structure; 2) add the position of Reactor Operations Manager in Level 3; 3) change the title of Operations Supervisor to Supervisor(s), in Level 3; and

4) change the title Reactor Operators to Operating Staff, in Level 4, as provided in the licensees proposed TS 6.1.1, Figure 1, and throughout the associated TSs. The licensee indicated that the proposed TS organization structure and reporting hierarchy is unaffected by the elimination of the Assistant Director, in Level 2, and the addition of the Reactor Operations Manager position, in Level 3. The licensee stated in its letter dated July 10, 2015, that the proposed positions are consistent with the licensees organization and day-to-day reactor operations. The licensee performed a detailed analysis of the duties of the Associate Director position and concluded that the day-to-day operations were consistent with the licensees

definition of the responsibilities of an Operations Manager. Additionally, the licensee indicated that the proposed Operations Managers duties were more aligned with the Level 3 position provided in American National Standards Institute/American Nuclear Society (ANSI/ANS) 15.1-2007, The Development of Technical Specifications for Research Reactors, which describes individuals responsible for day-to-day operation or shift. ANSI/ANS-15.1-2007, Figure 1, Level 3, provides the title of Supervisor SRO.

The licensee also proposed to remove the phrase guidance, oversight, and technical support of reactor operations from the responsibilities currently described for the Associate Director, in TS 6.1.2.b. In its letter dated July 10, 2015, the licensee stated that the proposed description of the Operations Manager, in proposed TS 6.1.2.c, is not intended to remove any responsibilities from the Operations Manager. The proposed TS 6.1.2.c, includes the responsibilities of the Operations Manager to direct the activities of the staff and for the day-to-day operation and maintenance of the reactor, and the title of Operations Manager was chosen because it indicates that the over-arching responsibilities include providing guidance, technical support and oversight of the reactor, to the RRR staff for the day-to-day operation and maintenance of the reactor. Additionally, the licensee indicated that the responsibility to provide guidance, technical support and oversight of the reactor is also incumbent upon any RRR staff who operate the facility.

The NRC staff reviewed the proposed changes to: TS 6.1.1, Figure 1; TS 6.1.2. b, c, and d; TS 6.1.3.b.2 and 3; TS 6.4; TS 6.5.c and d; and TS 6.6.2.a and b, and finds that the proposed changes are consistent with the guidance in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors and ANSI/ANS 15.1-2007.

NUREG-1537, Part 1, Chapter 14, Appendix 14.1, Format and Content of Technical Specifications for Non-Power Reactors, Section 6.1, Organization, indicates that the guidance in ANSI/ANS-15.1-2007, can be used. ANSI/ANS-15.1-2007, Section 6.1, Organization, indicates that a Level 3 can be a Supervisory SRO, and describes the Level 3 position as being responsible for the day-to-day operation or shift. The licensee indicated, based on its study of the duties of the position of Operations Manager, that the Operations Manager position was consistent with the Level 3 description in ANSI/ANS-15.1-2007, for day-to-day operation or shift.

The NRC staff also finds that the responsibilities for guidance, oversight, and technical support of reactor operations, are not specifically stated in ANSI/ANS-15.1-2007. The NRC staff finds that those responsibilities are encompassed by the duties of the Operations Manager to direct the activities of the staff and for the day-to-day operation and maintenance of the reactor is acceptable.

Based on the information provided above, the NRC staff finds the proposed changes to the RRR TSs: TS 6.1.1, Figure 1; TS 6.1.2.b, c, and d; TS 6.1.3.b.2 and 3; TS 6.4; TS 6.5.c and d; and TS 6.6.2.a and b, acceptable.

2.2 Reactor Secured The current TS 6.1.3.a states:

6.1.3 Staffing

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

In response to NRC staff RAIs, by letter dated July 1, 2014, the licensee stated that the change in wording in TS 6.1.3.a, from is operating to not secured is to ensure that a licensed operator is at the controls whenever the console key is in the switch. The licensee also stated that proposed TS 6.1.3, Staffing, Specification a. is consistent with the guidance in NUREG-1537 and ANSI/ANS-15.1-2007. ANSI/ANS-15.1-2007, Section 6.1.3, Staffing, states not secured.

The proposed TS 6.1.3.a states:

6.1.3 Staffing

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

The NRC staff reviewed the proposed change to TS 6.1.3.a, and finds that it is consistent with the guidance in NUREG-1537 and ANSI/ANS 15.1-2007, which states that the minimum staffing when the reactor is not secured... The proposed TS 6.1.3.a removes a potential inconsistency in the current TSs which could allow the operating staff to leave the reactor controls unstaffed without ensuring that all the safety conditions were satisfied. The safety conditions are listed in the RRR TS 1.0, Reactor Secured, and include: 1) having all three control rods fully inserted; 2) ensuring that the key switch is in the off position; and 3) ensuring that the console key is removed from the reactor console. The NRC staff finds the proposed change will help to enhance the licensees operators control of the reactor. On the basis of its review of the information provided above, the NRC staff finds the proposed change to TS 6.1.3.a acceptable.

2.3 ROC Review of Facility Changes The current TS 6.2.3.a states:

TS 6.2.3 ROC Review Function

a. Review changes made under 10 CFR 50.59; In response to NRC staff RAIs, by letter dated July 1, 2014, the licensee proposed to change TS 6.2.3.a in order to clarify the requirement for the review of changes to the facility. The proposed TS 6.2.3.a matches the guidance in NUREG-1537 and ANSI/ANS-15.1-2007, Section 6.2.3, Review Function, item (1), which states determinations that proposed changes in equipment, systems, test, experiments, or procedures are allowed without prior authorization by the responsible authority.

The proposed TS 6.2.3 a states:

TS 6.2.3 ROC Review Function

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

The NRC staff reviewed the proposed change to TS 6.2.3.a, and finds that it is consistent with the guidance in NUREG-1537 and ANSI/ANS 15.1-2007, as described above. The proposed change to TS 6.2.3.a will help to ensure that the scope of the review of changes made to the RRR facility include proposed changes in equipment, systems, tests, experiments or procedures, are allowed without authorization by the U.S. NRC prior to implementation. Based on the information provided above, the NRC staff finds the proposed change to TS 6.2.3.a is acceptable.

2.4 Procedures The current TS 6.4 states:

TS 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:

In response to NRC staff RAIs, by letter dated July 1, 2014, the licensee proposed to change TS 6.4 in order to clarify the requirement to use procedures deemed necessary for the operation of the RRR facility.

The proposed TS 6.4 states:

TS 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 and used for the following:

The NRC staff reviewed the proposed change to TS 6.4, and finds that the proposed TS is consistent with the intent of the guidance in NUREG-1537 and ANSI/ANS 15.1-2007 that procedures are not only in effect, but that they are used in the discharge of those activities specified in the remainder of TS 6.4. The proposed change will help to clarify the procedure adherence requirements for the operating staff at the RRR facility. Based on the information provided above, the NRC staff finds the proposed change to TS 6.4 acceptable.

2.5 Records The current TS 6.8.2 states:

Records of retraining and requalification of licensed reactor operators and senior reactor operators shall be retained 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.

In the licensees response to the NRC staffs RAIs, by letter dated July 1, 2014, the licensee proposed to add for at least one complete requalification cycle and maintained to TS 6.8.2, in order to clarify the requirement to retain records of retraining and requalification of licensed operators for at least one requalification cycle.

The proposed TS 6.8.2 states:

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.

The NRC staff reviewed the proposed change to TS 6.8.2, and finds that the change clarifies the requirement to maintain records of retraining and requalification of licensed operators for one requalification cycle. The revised TS helps ensure that if a licensed operator leaves employment prior to the end of the requalification cycle, the training and requalification records would be maintained, and available for NRC staff review, until the end of the requalification cycle. Based on the information provided above, the NRC staff finds the proposed change to TS 6.4 acceptable.

2.6 Notification and Reporting to the U.S. NRC In response to NRC staff RAIs, by letter dated July 1, 2014, the licensee proposed to change references to the NRC in TS 6.7.1, and TS 6.7.2.a and b. These TSs contain notification and reporting requirements for the RRR, but use different nomenclature for the U.S. NRC. This inconsistency could result in the potential failure to provide the NRC with the required notification or report. The licensee proposed to clarify the TS reference for: 1) reporting to the U.S. NRC at: Document Control Desk, U.S. NRC, Washington, DC; and, 2) for notifications made to the U.S. NRC at: U.S. NRC Headquarters Operations Center. These changes affected TS 6.7.1, and TS 6.7.2.a and b.

The NRC staff reviewed the proposed changes and concluded that they are consistent with the guidance in NUREG-1537, and will help to ensure notifications and reports are provided properly. NUREG-1537, Part 1, Chapter 14, Appendix 14.1, Section 6.7, Reports, provides guidance that reports should be sent to the U.S. NRC Document Control Desk.

Based on the information provided above, the NRC staff finds the proposed changes acceptable.

2.7 Conclusions The NRC staff has reviewed the licensees proposed changes to the RRR TSs, and concludes that they are acceptable. The changes include revised administrative procedure requirements, changes to titles and responsibilities, changes to recordkeeping and reporting requirements, changes to the review requirements associated with facility changes, and minor corrective changes. The changes are consistent with NRC guidance in NUREG-1537 and ANSI/ANS-15.1-2007, better align the RRR TS requirements to reflect the functional

organization of the RRR facility staff, and provide clarifications to the TSs to help ensure compliance. In addition, the requested amendment will not change how the reactor is operated.

Therefore, the staff finds the proposed TS changes acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

The NRC staff has determined that this amendment involves changes to recordkeeping, reporting, or administrative procedures or requirements; and changes the name, position, or title of an officer of the licensee or permit holder; and makes corrective or other minor revisions to the RRR TSs, in accordance with the guidance in ANSI-15.1-2007, which has been endorsed by the NRC staff in NUREG-1537. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in Title 10 of the Code of Federal Regulations (10 CFR) 51.22(c)(10)(ii), (iv) and (v). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

4.0 CONCLUSION

The NRC staff concludes, on the basis of the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed activities; and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public.

Principal Contributors: G. Wertz, NRR M. Watford, NRR Date: September 28, 2015