ML18127A075
| ML18127A075 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 04/30/2018 |
| From: | Slaughter D Aerotest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18127A075 (3) | |
Text
AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 April 30, 2018 ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.
SUBJECT:
Elimination of TS 6.6 Ladies and Gentlemen:
The current Technical Specification (TS) 6.6 as written: "During a critical experiment, subcritical multiplication plots shall be obtained from at least three instrument channels. These channels may be used in addition to the normal operating instrumentation in Table l ." After continued evaluation c.onceming the modification or elimination of TS 6.6 for ARRR, I request the contents of the letter dated March 29, 2018, which requested a modification to Technical Specification 6.6, be superseded by this request. I propose the elimination of TS 6.6. It is not required to be present in the technical specifications according to 10 CFR 50.36 Technical Specifications there is no NUREG guide or ANSI standard that requires such a condition to be present in the License's TSs. Review of TSs of licenses of similar reactor type, that were recently renewed, confirms this belief. Operating procedures are the typical type of document that provide the safe application. As required, any changes to the procedures are reviewed by the Reactor Safety Committee. The approach to critical procedure is given in the ARRR restart plan dated 4/03/18.
There is no written justification in the historical documents for presence of TS 6.6. It is most likely an artifact of the start-up activities; TS 6.6 may have been seen as relevant upon startup in 1965 and 1966 during the time when the reactor operational characteristics were being defined.
(The approach to criticality is no longer performed as an experiment.) The research indicated the detector type, source orientation to the detector, and the loading sequence impact the safety of the approach to critical process, the quality and usefulness of the data. Procedures and
instructions for approach to critical have been modified for effective use as needed. For example, the last approved change by the Reactor Safety Committee was in January 1981 to Procedure IV.
The current TS 6.6 if followed will most likely produce inaccurate and low quality data from 2 of the 3 instruments due to less optimal element loading sequence and orientation of source and detector, etc.
I enclosed a replacement for TS page 5. Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (801) 631 5919 or dmsraven@gmail.com I declare under penalty of perjury that the statements above are correct and truthful.
Sirl~urs, ~
\J David M. Slaughter, Ph.D.
President and Reactor Admin.
Aerotest Operations, Inc.
Enclosure:
Appendix A license No. R-98 TS Page 5 , "6.6 Blank" replacing "6.6 During a critical experiment experiment, subcritical multiplication plots shall be ....... "
-*-**-**- -- . - . ---- . **----. - .. *- - - --* -- . --~- . -- -- . ----- ------ : ..
- r-*-, 5
.. *,. 1 6.6 Blank 6.7 Process instru;nentation with readout in the control room shall be ~perating to permit continuous indication of pool wa~er tem~erature and condu~tivity.. Alarms shall be pper-abted_to 1ndicate*1ow water flow, low pool water and improper location of the crane bridge, 7 .O *Radiation Monitoring -- **
II 7. 1 TA~f~17*x='='ed~-.==g'=amm=~a==m'='o'=n"!;i~t;;::o===r~em::==pfl~o=y=;,i=n=g=;:G~e:=:i;:::g;;e;;;;r=t;;;u~b..:::e=d:=::e:;:t=e=c=t=o=r=s===.;:;;::===-...-:.Jj shall be located on the wall connecting the control room and the reactor room. This monitor shall .serve.
as both an area radiation monitor and a criticality*
alarm and will annunciate through an automatic monitoring* system to tq._e San Ramon*, California, Fire Department and actuate a siren within the reactor
.. building on high radiation level. The monitor shall
- ~)*. hav:_e a minimum range of O to 20* mr/hr.\ The annun- ~ .
. ' ciation and the siren actuation shall be tested , 0 _ 11d'4-pv
/* man thly. " ~ i-:r** f a" s o
~ee..,,
- 7.2 During reactor operation, a gas sample shall be continuously /
withdrawn £rom the roof vent above ~he reactor, or from the vicinity of the reactor bridge and glory hole over the reactor core, and _pumped *through a radioactive gas detection chamber.*
The gas chamber shall be _monitored by a beta-gamma detector which .shall hav~ a continuous readout in the control room *
. An annunciator shall indicate when the gas exceeds 2 mr/hr.
7.3 A fission_product water monitor shall be attached to the process water cleanup system *1oo*p adjacent to the deminer-alizer and shall provide continuous indication :in the control room. High radiation levels within the demineralizer or
=pool water shall annunciate an audible alarm on the reactor console. The range of the monitor shall be £;om 0.1 to *100 mr/hr.
7.4 Portable survey instruments for measuring beta-gamma dose rates *in* the range of 0.01 mr/hr *to 50 r/hr.shall be.. **:
available at the facility.
7.5 Portable instruments for measuri~g fast and thermal neutron dose rates from 0.1 mrem/hr to l.O rem/hr *shall be,1.1 *'.!
- avai-lable .at the facility.
AEROTEST OPERATIONS, INC.
3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212
- FAX (925) 866-1716 April 30, 2018 ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.
SUBJECT:
Elimination of TS 6.6 Ladies and Gentlemen:
The current Technical Specification (TS) 6.6 as written: "During a critical experiment, subcritical multiplication plots shall be obtained from at least three instrument channels. These channels may be used in addition to the normal operating instrumentation in Table l ." After continued evaluation c.onceming the modification or elimination of TS 6.6 for ARRR, I request the contents of the letter dated March 29, 2018, which requested a modification to Technical Specification 6.6, be superseded by this request. I propose the elimination of TS 6.6. It is not required to be present in the technical specifications according to 10 CFR 50.36 Technical Specifications there is no NUREG guide or ANSI standard that requires such a condition to be present in the License's TSs. Review of TSs of licenses of similar reactor type, that were recently renewed, confirms this belief. Operating procedures are the typical type of document that provide the safe application. As required, any changes to the procedures are reviewed by the Reactor Safety Committee. The approach to critical procedure is given in the ARRR restart plan dated 4/03/18.
There is no written justification in the historical documents for presence of TS 6.6. It is most likely an artifact of the start-up activities; TS 6.6 may have been seen as relevant upon startup in 1965 and 1966 during the time when the reactor operational characteristics were being defined.
(The approach to criticality is no longer performed as an experiment.) The research indicated the detector type, source orientation to the detector, and the loading sequence impact the safety of the approach to critical process, the quality and usefulness of the data. Procedures and
instructions for approach to critical have been modified for effective use as needed. For example, the last approved change by the Reactor Safety Committee was in January 1981 to Procedure IV.
The current TS 6.6 if followed will most likely produce inaccurate and low quality data from 2 of the 3 instruments due to less optimal element loading sequence and orientation of source and detector, etc.
I enclosed a replacement for TS page 5. Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (801) 631 5919 or dmsraven@gmail.com I declare under penalty of perjury that the statements above are correct and truthful.
Sirl~urs, ~
\J David M. Slaughter, Ph.D.
President and Reactor Admin.
Aerotest Operations, Inc.
Enclosure:
Appendix A license No. R-98 TS Page 5 , "6.6 Blank" replacing "6.6 During a critical experiment experiment, subcritical multiplication plots shall be ....... "
-*-**-**- -- . - . ---- . **----. - .. *- - - --* -- . --~- . -- -- . ----- ------ : ..
- r-*-, 5
.. *,. 1 6.6 Blank 6.7 Process instru;nentation with readout in the control room shall be ~perating to permit continuous indication of pool wa~er tem~erature and condu~tivity.. Alarms shall be pper-abted_to 1ndicate*1ow water flow, low pool water and improper location of the crane bridge, 7 .O *Radiation Monitoring -- **
II 7. 1 TA~f~17*x='='ed~-.==g'=amm=~a==m'='o'=n"!;i~t;;::o===r~em::==pfl~o=y=;,i=n=g=;:G~e:=:i;:::g;;e;;;;r=t;;;u~b..:::e=d:=::e:;:t=e=c=t=o=r=s===.;:;;::===-...-:.Jj shall be located on the wall connecting the control room and the reactor room. This monitor shall .serve.
as both an area radiation monitor and a criticality*
alarm and will annunciate through an automatic monitoring* system to tq._e San Ramon*, California, Fire Department and actuate a siren within the reactor
.. building on high radiation level. The monitor shall
- ~)*. hav:_e a minimum range of O to 20* mr/hr.\ The annun- ~ .
. ' ciation and the siren actuation shall be tested , 0 _ 11d'4-pv
/* man thly. " ~ i-:r** f a" s o
~ee..,,
- 7.2 During reactor operation, a gas sample shall be continuously /
withdrawn £rom the roof vent above ~he reactor, or from the vicinity of the reactor bridge and glory hole over the reactor core, and _pumped *through a radioactive gas detection chamber.*
The gas chamber shall be _monitored by a beta-gamma detector which .shall hav~ a continuous readout in the control room *
. An annunciator shall indicate when the gas exceeds 2 mr/hr.
7.3 A fission_product water monitor shall be attached to the process water cleanup system *1oo*p adjacent to the deminer-alizer and shall provide continuous indication :in the control room. High radiation levels within the demineralizer or
=pool water shall annunciate an audible alarm on the reactor console. The range of the monitor shall be £;om 0.1 to *100 mr/hr.
7.4 Portable survey instruments for measuring beta-gamma dose rates *in* the range of 0.01 mr/hr *to 50 r/hr.shall be.. **:
available at the facility.
7.5 Portable instruments for measuri~g fast and thermal neutron dose rates from 0.1 mrem/hr to l.O rem/hr *shall be,1.1 *'.!
- avai-lable .at the facility.