ML19327C149

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Application for Amend to License R-66,authorizing Conversion to Low Enriched U Fuel.No Changes in Physical Security & Emergency Plans Proposed.Sar,Revised Tech Specs,Selected Refs in Support of SAR & Updated Conversion Schedule Encl
ML19327C149
Person / Time
Site: University of Virginia
Issue date: 11/09/1989
From: Mulder R
VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To: Murley T
Office of Nuclear Reactor Regulation
Shared Package
ML19327C150 List:
References
NUDOCS 8911210021
Download: ML19327C149 (13)


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UNIVERSITY OF VIRGINIA DEPAMTMENT OF NUCLEAR ENGINEERING AND ENGINEERING PHYMC8

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NUCLEAR REACTOR FACILITY m e fl V j SCHOOL OF ENGINEERING AND APPLIED SCIENCE Cl!ARLOTTESVILLE, VA 22901 l

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I Telephone: 8M 9244186 November 9, 1989 l l

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, Attnt Mr. Thomas E. Murley -

l Director of the Office of Nuclear Reactor Regulation  !

r U.S. Nuclear Regulatory Commission l Washington D.C. 20555 '

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Subject:

Application for Authorization to Convert to LEU I L

t Gentlement In attachment please find the following documentation in

' support of the University of Virginia's application to convert its "UVAR" 2 MW pool reactor from high enriched uranium (HEU) to low }

enriched uranium (LEU) fuel: j (1) LEU Safety Analysis Report (LEU SAR)  !

(2) revised Technical Specifications (TS), with list of changes (3) selected references in support of the LEU SAR (4) updated conversion Schedule and Proposal  !

Review and approval of the new TS and SAR by our Reactor Safety  !

Committee was completed on October 24, 1989, af ter several meetings l held over the span of two months. -

t At this time, no changes in the physical security and l emergency plans for the facility are proposed. Potential changes i related to the conversion will be considered at the nere scheduled i i review date for-these documents. However, at most, minor changes i l are foreseen. We understand that changes may be made to these  ;

plans by the licensee without prior NRC approval, provided that  ;

they do not reduce their effectiveness.  !

l The present UVAR operator requalification program will f not be greatly affected by the conversion, because the LEU core will have operating characteristics very cimilar to those of the i current HEU core. Changes to TS, SAR and SOP's related to the conversion will be covered in requalification lectures prior to their taking effect.

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hoolication to Convert (cont.)

A reactor start-up report, containing comparisons of actual neasurements performed on the new core with calculations presented in the LEU SAR, will be submitted to the NRC after the new core has been loaded and within the time period proposed in the updated conversion schedule in attachment. The contents of the report will be in accordance with the recommendations proposed in the paper presented at the 1988 TRTR meeting by T. Michaels (USNRC-PDSNP).

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day cf . .. . AW(mx u ~~~J 19 I Robert U. Mulder, Director Witr . i tr> l.uu. ! M91 to~:

U.Va. Reactor Facility

/J/t 14 b. b (?d fictary Pubtle uyc a m:.bnC"rtc' }l2fl93 cc Mr. Al Adams, NRC Project Manager for U.Va. Wash. D.C.

Regional Administrator, USNRC Region II, Atlanta, Georgia

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UPDATED PROPOSAL AND SCHEDULE FOR CONVERSION I t

t OF THE UNIVERSITY OF VIRGINIA

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t NON. POWER 2 MWgh UVAR RESEARCH REACTOR l 1

FROM HEU TO LEU FUEL

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Submitted to:

f Director of the office of. Nuclear Reactor Regulation h U.S. Nuclear Regulatory Commission  !

Washington D.C. 20555 (

Attn: Mr. Thomas E. Murley j!

I Submitted by: i Robert U. Mulder ,

L Director U. Va. Reactor Facility [

Department of Nuclear Engineering i and  !

l Engineering Physics i

University of Virginia 22903 1 i

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November 1989 l

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l WAR LEU CONVERSION SCHEDULE I t

i Hilestones Dates

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.g ............................................. ........... 1 Availability of DOE conversion funds September 86 L Notification of WAR LEU core availability January 90 f

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t t EC&G Tuel Element Drawing Approval by U Va. November 90 '

il Submittal to the NRC of a SAR by Virginia November 89 t l Fitting of dummy LEU element (s) in WAR May 90  !

! Receipt of NRC's " Order to Convert" A July 19907

' Completion of shipping plans and scheduling A+1 -i Completion of all HEU fuel shipments from site A+2 September 907 >

Expected WAR reactor downtime 1 mo.

i :i, Receipt of LEU fuel for a complete WAR core A42 September 907  !

. Loading of LEU fuel in WAR core A+2 l Completion of initial LEU fuel operating A+3 parameter tests October 907 1 T

i I Report to NRC containing summary of '

new WAR reactor operational conditions, comparisons with SAR predictions, A+12 i and license / tech spec conditions l A -

Date of NRC order to convert, expected for end of summer '90 i.

  • If the milestones indicated in this schedule can't be met, despite best efforts, the conversion of the WAR will be delayed  :

accordf.ngly. HEU spent fuel shipping is date dependent on cask t

! availability. J

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CONVERSION IMPLEMENTATION CONSIDERATIONS  !

i j A. Application by Virginia for NRC Authorization to Convert According to the schedule presented, the University of Virginia .

Reactor Facility is presently submitting to the NRC a Safety l Analysie Report (SAR) for the conversion of the WAR to low Enriched Uranium (LEU) 22 Plate Fuel Elements, as part of its application to  ;

convert. The calculations required by the Facility's Reactor Safety Committee have been performed, the new Technical Specifications and j

SAR reviewed and approved. The new TS are also enclosed in the  ;

conversion application.

l; In order to maintain similar WAR performance characteristics,  !

Virginia opted to increase the number of fuel plates in the LEU  !

elements from 18 curved to 22 flat. Neutronics and thermo. i' hydraulic calculations show that this increase, initially proposed by the RERTR personnel at ANL, does not result in significantly ,

reduced safety margins. Moreover, the calculations predict that this slight fuel element design change will be beneficial from an  ;

economical standpoint, providing for longer. lived and smaller cores.  !

Thus, WAR operations will be more efficient because of fewer core "

changes and spent. fuel shipments, j

EG&G/ Idaho has been developing the new LEU fuel element specifications and plan drawings. Based on these specifications, ,

dummy fuel elements of each type will be built by B&W for trial i fitting into the WAR grid plate, prior to the contracting for the fabrication of fuel elements by B&W, Virginia from EG&G/ Idaho for review and approval at the, endreceived the drawings of October 1989.

Some small revisions in the control rod drawings were still necessary and will be completed by mid November. Based on this, r dummy elements for trial fitting should be available to the Facility l early in the summer of 1990. A full LEU core for the WAR has been tentatively promised for the end of summer 1990.

Virginia wishes to ship all its HEU fuel from the Reactor Facility just prior to the receiving the new LEU fuel. So that fuel  !

may be shipped as per schedule, notifications and preparations have I begun. Experience has shown that it is not always possible to  ;

guarantee spent fuel shipment dates, which depend on cask ~

availability and concurrence from the shipper, receiver and the NRC.

The withdrawal of the GE 700 casks from circulation could cause delay in our shipping date. It is also noted that DOE is expected ,

to provide the funding for spent fuel shipments in separate from the funding provided for the conversion study.

Virginia wishes to receive NRC's order to convert shortly before or after the scheduled date of its spent HEU fuel shipments. As previously stated, the present schedule may be subject to change, despite best efforts by all parties concerned. A revised schedule will be sent to the NRC at yearly intervals, as required by the federal regulations.

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l 3 i Description and Analysis of Safety Pactors l

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i The licensee has included in the UVAR LEU SAR a description of I those reactor safety factors significantly affected by the change '

from HEU to 1.EU fuel. The calculations indicate that no significant "

safety effects are assuciated with the fuel conversion. No changes ,

to the reactor systems have been proposed except for the replacement '

of the HEU fuel elements by LEU fuel elements. Reactor operating  ;

characteristics will remain the same, save for a small increase in the minimum reactor coolant LSSS flow rate setting to 900 gpm.

The total inventory of fission products will not be significantly different between the HEU and LEU cores. The basic difference between the inventory of radioactivity in the two fuel types is the greater abundance of plutonium 239 (formed by neutron capture in the uranium 238) in the LEU fuel. However, the level of additional plutonium buildup is small and radiologically i insignificant. Therefore, it has been shown and concluded that no significant change in the risk to the health and safety of the public will be caused by the conversion.

C. Necessary Changes in Reactor License Tech. Specs, and Plans Based on the results of the conversion study carried out by the ,

licensee, proposed necessary changes to the facility license and the I technical specifications are being indicated in the application to ,

convert. These consist of minor editorial changes and a some l changes made necessary by the use of LEU fuel. These are listed in an attachment to the application to convert.

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The Physical Security Plan and the Emergency Plan are only marginally affected by the UVAR conversion. The CAVALIER decommissioning which will be underway in 1990 has a greater l potential impact on these plan. This will be dealth with in t separate from the conversion. Changes to these plans will be done '

at their next scheduled review date, ,

Reactor operators will be active in the various aspects of the I conversion study and document reviews. They will also participate l in the loading of the new core and development and performance of l the initial tests. The SOP's will not be greatly affected, since i the information presently available indicates imperceptible variance .

t in operating performance and characteristics between the two fuel f l types. Changes in procedures are as a matter of practice reviewed '

during regularly scheduled staff meetings and requalification meetings. ,

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4 D. Quantity of HEU to be Shipped Off site L The Reactor Facility presently maintains a total of 42 curved '

plate HEU elements, and 8 curved HEU fuel plates. Thirty six flat .

plate HEU elements, which were only used in the UVAR, were shipped off site in September and October of 1987. These shipments were {

considered an initial step of the conversion process. The curved  ;

plate elements and extra individual plates contain 6568.2 gm of U.

235. The license limits are 3.6 kg U 235.for the CAVALIER and 14.U {-

Kg U 235 for the UVAR.  !

The CAVALIER core was unloaded in 1988, in preparation for its i eventual decommissioning, The HEU fuel elements used in the  !

CAVALIER and UVAR are identical. Of the 42 curved plate elements at the Reactor Facility, 16 elements were in the 100 U CAVALIER reactor j

(and are considered " irradiated fuel"). Most of these elemente are '

presently stored in the Facility's fuel storage room but a few are  !

now in use in the UVAR. The remaining lightly irradiated CAVALIER l elements will be maintained in dry storage by the Facility for  !

possible use in the UVAR reactor, should the conversion date be i greatly delayed. The UVAR license limit for U 235 is not be '

exceeded as CAVALIER HEU fuel is transferred to the UVAR license, r

i The other 26 curved plate elements are kept either in the UVAR i core or in UVAR pool fuel storage racks. No spare fresh (reactor unirradiated) HEU fuel is kept in fuel storage. A few Virginia fresh fuel elements are still held by B&W. The licensee expects to  !

continue UVAR reactor operation with the HEU curved plate fuel until the LEU fuel becomes available and arrangements for the complete '

removal of the HEU are finalized. >

E. Interim Period for Possession of both LEU and HEU The University of Virginia Reactor Facility does not wish to simultaneously possess both LEU and HEU fuel during an interim period, and believes that with the proper coordination of the spent .

and fresh fuel shipments such a period is not needed. However,  ;

flexibility in this regard is prudent. Since it appears that Virginia has little control over this aspect of the conversion, reasonable proposals by DOE and NRC will be considered.

F. Compliance with Physical Security Regulations The UVAR HEU fuel is either in core or rotated through the core  !

to maintain "self protecting" radiation levels. No further I requirements or procedures, beyond those already listed in the

) Facility's NRC approved security plan, need to be implemented to maintain compliance with the relevant regulations, in particular those contained in 10 CFR 73. The conversion to LEU may eventually permit relaxation of some provisions contained in the security plan.

Certaisly, no upgrading in the plan will be necessary.

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O. Operator Requalification for Converted Reactor It is anticipated that the operating characteristics of the i

converted UVAR reactor will not differ significantly from that of the present reactor. Therefore, SOP changes will not be appreciable. The operators will be made aware of any changes to SOP's during scheduled reactor operator requalification meetings,

i. and receive training as warranted.

H. Certification of Federal Government Funding Federal Government funding for the conversion study of the UVAR

, reactor has been secured from DOE by the University of Virginia.

In addition, DOE has paid for four HEU spent-fuel shipments made in September and October of 1987, e have been in direct contact with EC&G regarding fuel plate and fuel element specifications and have been told that B&W has initiated manufacture of the standard LEU fuel plates' .

Conversion of the UVAR appears on track, with conversion completion expected by end of 1990, i

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i' 1 LIST OF PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS The UVAR LEU TS are based on the current HEU TS. The LEU TS have i been typed in Wordperfect 4.2 file format.

EDITORIAL CHANGES TO PROPOSED fNEW) UVAR TECH. SPECS. L The TS title page was altered to reflect the fact that the TS apply to the ,

University of Virginia Reactor, not U.Va.. The September 1989 date on the  ;

title shect reflects the date of Reactor Safety Committee approval.

A search was made for the word "ANY" in the original TS; As appropriate, :

the word was left as is, dropped, or changed to "A" or "AN".

The TS pagination and spacing was changed to better organize the document. i Where the amount of blank space on a page following the conclusion of a '

section was considerable, the phrase " rest of page intentionally left blank" was added.

Reactivity values originally expressed in % delta k/k were converted over l to " dollars and cents". The conversion factor 0.74 % delta k/k = IS, referenced in the LEU SAR analysis, was used. Small " rounding off" of the  !

values was done where necessary. This change is justified because core reactivity measurements are actually made in terms of dollars, and it is thus the " primary" unit. Following approval of this change by the NRC, the UVAR SOP's will be changed where necessary to conform with the new TS.

For consistency, the spelling of the word " beam port" was changed to l "beanport" throughout the LEU TS and LEU SAR. i l

In the new LEU TS, references to the LEU SAR mention only chapter number, ,

and not page number, etc.., to accommodate future revisions to the SAR '

under 10CFR50.59.

t As a single safety limit based on fuel plate integrity has been adopted, the plural case (safety limits) was changed to the singular case (safety limit) were appropriate, throughout the TS text.  !

In TS 3.1., the basis were identified by numerals to more clearly  !

correspond to the specifications. l In the basis to TS 3.2., a small wording change was made regarding the purpose of the period scram.

Table 3.1 was updated to reflect new setpoints for minimum primary reactor coolant flow LSSS and reactor period.

For clarity, the phrase "5 years of nuclear experience" was changed to "5 years of experience in the nuclear field" in TS 6.1.2., second paragraph.

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EDITORIAL CHANGES fCONT.1 2 For clarity the following TS wording were changed!

TS 6.5.1. (1) " normal plant operation" to

" reactor operation logbook" TS 6.5.1. (2) " principal maintenance activities" to

" reactor systems maintenance records" TS 6.5.1 (3) " experiments with the reactor" to

" experiments performed using the reactor" TS 6.5.1 (7) " transfer of radioactive material" to

" transfer of radioactive material to and from the R-66 licanse" TS 6.5.2. (1) " gaseous and liquid radioactive affluents released to the environs" to

" gaseous and liquid radioactive affluents released from the Reactor Facility" TS 6.5.2. (2) "off-Jite environmental monitoring surveys" to "off-site (radiological) environmental monitoring surveys" t

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i i MAJOR CHANGES TO PROPOSED fNEW) LEU UVAR TECH. SPECD2 3 h The original " safety limits" were " collapsed" to a single safety limit based on the integrity of the aluminum cladding, to reflect the current i regulatory approach. This resulted in text changes to TS 2.1 and 2.2. l Requirements for safe operation no longer to be considered as safety limits  ;

are now covered as limiting safety system settings (LSSS). As a result, r a LSSS on reactor power was set for the forced convection and natural circulation modes of operation. Also, the LSSS on coolant flow was increased from 800 to 900 GPM to account for the conversion from 18 to 22 plate / element fuel elements. The wording used in the basis was also clarified.

Figure 2.1 in the TS entitled " Safety Limits with Forced convection Flow" ,

will be deleted in the new TS. A figure covering this topic for the LEU fuel exists in the LEU TS.

The wording of TS 4.7.1., entitled " Airborne Effluents," was changed to agree more closely with TS 3.4.1. on " Airborne Radioactive Effluents" and SAR Figure S-9-1, " Exhaust System to Stack". The applicability statement now indicates that the monitoring is done in the ventilation line from the ground floor experimental area. Specification (1) indicates when a channel check is required. Specification (2) has been re-phrased for clarity.

Finally, the wording of the bases for this TS was expanded to clarify the ,

requirements.

The original TS 4.8 entitled " Reactor Fuel Dose Measurementa" was deleted.

With the introduction of LEU fuel, the potential to exceed nonexempt SNM license limits will cease to exist. HEU TS 4.9 (Primary Coolant Condition) therefore becomes TS 4.8.

TS 5.1. , describing " Reactor Fuel", was rewritten specifically to address l the new LEU fuel whose use will be required by the NRC. The detailed fuel '

specifications are listed in the LEU SAR.

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L . r glyOR CHANGES TO PROPOSED fNEW) LEU UVAR TECH. SPECS. 4

( The wording in the definition of " channel calibration" was clarified. '

i The definition of " fueled experiments" was modified to account for natural '

trace levels of Uranitta which might be present in non-industrially  !

processed samples irradiated for NAA purposes. '

In the definitions for " measured value", " measuring channel" and "true (

value", the term " process variable" was changed to carameter. ,

A definition for Reactor Staff was added to TS.

g The wording of the basis to TS 3.1 was clarified.

l The basis for TS 3.1.(2) was rewritten.  !

The specification to TS 3.4.1. was substantially reworded, but the intent  !

was totally maintained. '

In TS 3.5. the word " exhaust" was deleted from the phrase " ventilation ,

exhaust duct doors." f r

In TS 3.7, Specifications (1)(a) and (2)(b) were reworded for clarity. l In TS 4.2. the wording of specification (5) was changed for clarification.

The old wording incorrectly implies that the iteas listed in that '

specification are not reactor safety channels, when TS 3.2 states that they are.

t In TS 5.3, the wording was changed to require the analysis to be done [

assuming water moderation only, since it is not possible to repeat these l calculations for all conditions of moderation.

In TS 6.0, Figure 6.1, " Organizational Structure of UVA Relating to Reactor Facility", is amended to permit various health physicists from the Office

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' of Environmental Health and Safet;y (F.H&S) staff to serve as the designated Reactor Health Physicist. The Reactor Health Physicist will be funded '

through EH&S and will have a channel of communication directly with the  :

Chairman of Nuclear Engineering and Engineering Physics. The reactor ,

health physicist position is identified by the Health Physics box in the figure of the organizational structure.

l TS . ' 6.1. 3. (5) was reworded to more clearly permit rotation of health  !

physicists from the EH&S staff through the position of Reactor Health HP. ,

TS 6.2, entitled " Review and Atidit", was renamed " Reactor Safety Committee"  !

which corresponds better to the topic covered. i i

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! Minor chanaes fcont.) 5 In-TS 6.2.1, the limit of two members from reactor operations was reduced to one member from the reactor staf f. The term " Reactor Staff" was defined in the definitions section.  ;

TS 6.2.3. " Review Functions" was renamed "Revier and Audit Functions".

The line in parenthesis at the end of TS 6.2.3.(6) was deleted, as the I frequency of RSC audits is defined .in the Reactor Safety Committee charter.

TS 6.3 " Operating Procedures" was renamed " Standard Operating Procedures",

for the procedures specified are in a Reactor Facility document identified i by that name. TS 6.3.(7) was created from wording immediately after TS , 6.3.(6), and preserves the original intent of the TS. l t

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