ML18345A054
| ML18345A054 | |
| Person / Time | |
|---|---|
| Site: | MIT Nuclear Research Reactor |
| Issue date: | 12/06/2018 |
| From: | Lau E, Queirolo A Massachusetts Institute of Technology (MIT) |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| CAC MF5003, EPID L-2016-LLA-0003 | |
| Download: ML18345A054 (2) | |
Text
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L ______.......;:..:...J MIT NUCLEAR REACTOR LABORATORY AN MIT INTERDEPARTMENTAL CENTER Edward S. Lau Assistant Director Reactor Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn.:
Document Control Desk Mail Stop: NW12-122 138 Albany Street Cambridge, MA 02139 Phone: 617 253-4211 Fax: 617 324-0042 Email: eslau@mit.edu 6 December 2018
Subject:
Supplement to Response to RAI for Nuclear Safety System Upgrade License Amendment Request (CAC #MF5003, EPID #L-2016-LLA-0003)
The Massachusetts Institute of Technology (MIT) hereby submits a supplement to its 25 October 2018 Response to the August 30, 2018, Request for Additional Information (RAI) on the License Amendment Request (LAR) to upgrade the Nuclear Safety System at the MIT Reactor (MITR).
Question #19 of the RAI is repeated below, followed by a revised answer from MIT.
was submitted as part of the original application in a letter dated September 30, 2014. The NRC staff compared the replacement page to the page in the license and could not identify any changes aside from a small grammatical change deleting the word "the" from the last line on the page. A second replacement page 4-4 was submitted as part of the RAJ response in a letter dated December 14, 2017. The NRC staff compared the second replacement page to the page in the license and identified that the word "drive" was added to TS 4.2.2 in two places, 1) after the phrase "shim blade" and 2) after "regulating rod." The addition of the word "drive" changes the meaning of the phrase and appears to exclude the reactivity insertion device (shim blade or regulating rod) itself MIT failed to identify this apparent change and did not provide a safety basis for the change. Additionally, the addition of the word "drive" changes the surveillance requirement so that it no longer appears to meet the regulatory requirements of ensuring that the LCO (TS 3.2.2.1) will be met.
Identify the desired changes/or TS 4.2.2 on page 4-4 providing a safety basis/or the changes and explaining how the proposed surveillance ensures TS 3.2.2.1 will be met or withdraw the request to replace page 4-4 in the TSs.
Response to RAI #19:
MIT withdraws its proposed change to Technical Specification 4.2.2 on page 4-4. The proposed change would have added the word "drive" to TS 4.2.2 in two places - after the phrase "shim blade" and after the phrase "regulating rod". MIT has concluded that the proposed change is unnecessary for the new nuclear safety system upgrade, and could potentially create ambiguity in
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TS RAI Response Supplement for Upgrade of NSS Page2 interpreting the intent of the technical specification. Therefore, page 4-4 is to revert to the current version that was approved and issued by NRC on November 1, 2010.
The RAI responses aae @aslesares submitted herewith do not contain any proprietary information.
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Sincerely, Edward S.Lau,NE Assistant Director of Reactor Operations MIT Research Reactor I declare under penalty of perjury that the foregoin Executed on d:k~pt,i, ', ;Joi&
Date cc:
USNRC -
Senior Project Manager Research and Test Reactors Licensing Branch Division of Licensing Projects Office of Nuclear Reactor Regulation USNRC -
Senior Reactor Inspector Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Alberto Queirolo Director of Reactor Operations MIT Research Reactor correct.