ML20149M751
| ML20149M751 | |
| Person / Time | |
|---|---|
| Site: | Plum Brook File:National Aeronautics and Space Administration icon.png |
| Issue date: | 12/20/1996 |
| From: | Pfanner H NATIONAL AERONAUTICS & SPACE ADMINISTRATION |
| To: | Mendonca M NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20149M753 | List: |
| References | |
| TAC-M79569, NUDOCS 9701270196 | |
| Download: ML20149M751 (19) | |
Text
T National Aeronautics and Space Adrninistration Lewis Flesearch Center Plum Brook Station 6100 Columbus Avenue Sandusky, Ohio 44870 nwy io Ann w:
7030 December 20,1996 Nuclear Regulatory Commission
@N i
Non-Power Reactors and Decommissioning Project Directorate O -/88 Attn: Mr. Marvin M. Mendonca, Senior Project Manager i
Washington, DC 20555-0001
Subject:
Response to Request for Additional Information (TAC No. M79569) l
Dear Mr. Mendonca:
We have received your letter dated November 21,1996, which contained questions with regards to our requests to amend License Nos. R-93 and TR-3.
NASA's response to those questions raised in your letter is enclosed.
Please note that the person to whom you addressed your letter (Mr. Neal Saunders) has retired from NASA, and is not involved in the current renewal activities. Mr. Donald J. Campbell, the current Director of NASA Lewis Research Center, is the official requester for this submittal. However, future correspondence involving questions on the content of said submittal should be addressed directly to me at my Plum Brook mailing address.
If you have any questions regarding the attached response, please contact me at (419) 621-3206.
Sincerely, f
]\\cQO I
f.
nW Henry G. Pfanner l
Plum Brook Reactor Manager l
l 9701270196 961220; PDR ADOCK 05000030 P
PDR 270006
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cc:
Ohio Department of Health ATTN: Radiological Health Program Director l
P.O. Box 118 l
Columbus, Ohio 43216 Ohio Environmental Protection Agency Division of Planning Environmental Assessment Section P.O. Box 1049 Columbus, Ohio 43216 t
l Ohio Department of Industrial Relations ATTN: Chief, Boiler and Pressure Vessel Division P.O. Box 825 Columbus, Ohio 43216 l
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NATIONAL AERONAUTICS AND SPACE ADMINISTRATION DOCKET NOS. 50-30 AND 50-185 Re:
Request for Additional Information concerning the National Aeronautics and Space Administration (NASA) Plum Brook Reactor Facility (PBRF)" Request for Amendment to License TR-3, Docket No. 50-30 for Renewal of Possess-But -Not-Operate License" dated November 21,1996.
1.
This question requested NAS A provide " analysis of radiological exposures and of the waste situation with supporting references and documentation to demonstrate that the proposed delay in decommissioning meets the regulation." NASA was also asked to provide a schedule for completion of decommissioning and final termination of the license.
The statement in the application that the " renewal is requested to allow continued decay of existing radionuclices to lower total personnel exposure during decommissioning"is based on an analysis of the current and future curie content at PBRF. Over ninety percent of the radionuclide inventory at PBRF is contained in two places; inside the Reactor Vessel (RV) and in the Hot Dry Storage (HDS) area.
The isotope makeup and activity levels in these areas is well documented based on past empirical measurements, most recently updated in 1985. An analysis of the curie content over time in these areas (Enclosure One, graph and tables) indicates that the ' knee' of the decay curve will be passed by the year 2020, but that for the next twenty years there will be a significant decrease (about 60,000 curies) in the inventory located in these two areas. Allowing the time for this decrease to occur will result in less exposure to workers during decommissioning. It can not be said that the delay will have any impact on public health and safety since in either the case of prompt or delayed decommissioning the public would not be exposed to any of this material.
The statement in the application that there is a " lack of a dependably available nuclear low-level waste disposal facility" is based on conversations with numerous people.
- Mr. Greg Larson, Executive Director, Midwest Compact (6/12/96)
Mr. Larson informed us that the earliest the Midwest Compact site would be open would be 2005, and that it would likely be later than that based on expected legal objections by intervener groups. He informed us the I
Hanford site was not accepting LLW from our region, and that the only sites currently available would be Enviro-Care in Utah (class A waste only) and Barnwell, SC. He did point out Barnwell's history of opening and then reclosing to sources outside South Carolina has occurred twice in the last six years.
- Mr. Paul Smith, DOE, National LLW Disposal Project Office (6/14/96) l Mr. Smith confirmed the judgment that the only LLW site available to us to l
handle our LLW in the event of decommissioning would be Barnwell. He I
also informed us of his opinion that it would be very unlikely that one compact with an operating site would be willing to take waste from another compact whose site was not yet open.
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- Mr. Virgil Autry, South Carolina Department of Health and Human Services (6/13/96)
Mr. Autry is the regulator in charge of overseeing the operations at Barnwell. He confirmed what we had been told. While the current Govemor and General Assembly of the state support the operation of Barnwell, this support is only insured until the next election. There is not, and cannot be, any long term assurance that the site will remain open to those outside the state. In his words, "You cannot predict the decisions of the General Assembly". Chem-Nuclear, the contractor who operates Barnwell for the state, is not permitted to enter into any long term contracts or agreements to accept LLW. This is a result of Chem-Nuclear not having the authority to carry out the agreement if the state government decides to close the site to outsiders. Chem-Nuclear accepts waste only on a shipment by shipment basis, usually arranged through a LLW broker. This statement was confirmed in conversations with Mr. Jack Harrison of Chem-Nuclear (6/17/96).
As a result of this information it is NASA's belief that there is currently no LLW facility which can be.fepended on to be available to accept PBRF waste over the multiple year period which decommissioning will take. The greatest concern is if decommissioning is started and the currently intact systems have started to be opened and exposed, that a closure of the LLW site would leave PBRF in an unacceptably vulnerable condition in terms of containment. The opened and exposed systems would be required to remain in a " half way" status until a suitable LLW disposal site would become available. We believe the current situation satisfies the condition in 10 CFR 50.82(b)(4)(i) concerning the unavailability of waste disposal capacity as a reason to allow the delay of decommissioning. NASA is convinced that the proper course of action, from a public safety point of view, is to wait until a dependable LLW site is available before decommissioning. This would allow for a LLW disposal contract to be made in advance to accept all of our decommissioning generated LLW without risk of interruption. Until then the PBRF should remain in its current, safe condition.
It is NAS A's understanding that the most likely LLW disposal site available to us for use will belong to the Midwest Compact, but that it will not realistically be available until sometime after 2007. It was felt that a ten year extension of the existing license would require NASA to make a decision about decommissioning without knowing if the LLW facility would in fact be available in time. This decision is predicated on the multiyear lead time required to prepare the Decommissioning Plan and obtain approval from the NRC. It was decided that a twenty year extension would permit NASA to be sure of the status of the Midwest Compact LLW site prior to preparing our formal decommissioning plan. It was also noted that if NASA was to be granted a t,venty year extension, and the timetable for the LLW site moved forward NAS A could prepare for and apply for permission to decommission at any time prior to the end of the requested 20 year extension.
A generic schedule describing the nature, duration, and sequence of activities associated with decommissioning and license termination is attached as Enclosure
- 2. The details of the decommissioning activities shown in the schedule are taken from the 1985 Engineering Study of the PBRF.
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2.a The justification for the twenty year extension of the license was discussed in the answer to PBRF Question #1, above. In summary, the primary reason for requesting a twenty year versus a ten year extension is NASA's belief that the conditions that make decommissioning now undesirable, the lack of a deper.dably available LLW disposal site, will still be true in seven years. It would be at this seven year time that NASA would need to decide next whether or not to decommission, assuming a ten year extension. The twenty year extension should allow for the availability date of the Midwest Compact to be known prior to beginning formal decommissioning planning.
The fact that still significant radiological decay will continue at the site for l
the next twenty years is a supporting point.
2.b 10 CFR 50.82(b)(3)(ii) requires that "means be included for adjusting cost estimates and associated funding levels over the storage or surveillance period." NASA's approach to satisfying this requirement is the same as was explained in the letter from the NASA Lewis Research Center (LeRC) to the NRC, " Availability of Funds for Decommissioning the NAS A Plum Brook Reactor License No.TR-3 (Docket 50-30), and NASA Plum Brook Mock-up Reactor License No. R-93 (Docket 50-185)", dated July 18, 1990.
This letter describes the process NASA still uses to periodically update the cost estimate and required funding levels for decommissioning. The process starts with the cost estimate presented in the engineering study performed by Teledyne Isotopes, Inc., of Westwood, New Jeney. Field work for the study took place in 1984-85, and a report was prepared in 1987-1988.
The study consisted of a thorough evaluation of the Plum Brook Reactor Facility radiological inventory and physical plant condition. The development of a decommissioning workplan, a detailed work breakdown structure, and manpower requirements for decommissioning was performed by Burns and Roe, Inc., as a subcontractor to Teledyne Isotopes. Labor rates for decommissioning were established using 1985 U.S. Department of Labor construction industry rates. Waste disposal (burial) costs were established by Teledyne Isotopes, Inc., an experienced rad-waste broker.
The 1985 cost estimate ($34,100,000 total for a four year et art) has been updated over the years to factor in the effects ofinflation. For non-waste disposal costs (labor, materials, etc.) the adjustment is made using the annual Consumer Price Index published by the U.S. Department of Labor, Bureau of Labor Statistics, for the years 1985 to the present. For waste l
disposal (burial) costs the adjustment is made using current disposal cost information for disposal at Barnwell, SC. The estimate for non-waste disposal costs in 1997 is $48,965,969, and $47,894,054 for waste l
disposal. The total estimated cost for decommissioning in 1997 is l
$96,860,023.
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10 CFR 50.75(F)(3) states "[ilf necessary, the cost estimate, for power and non-power reactors, shall also include plans for adjusting levels of funds assured for decommissioning to demonstrate that a reasonable level of assurance will be provided that funds will be available when needed to cover the cost of decommissioning." As with the previously addressed 3
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requirement NAS A's approach to satisfying this requirement was discussed l
in the same NASA LeRC letter to the NRC dated July 18,1990.
As a Federal agency NASA relies on the Federal budget process for the funding it receives to operate. In order to comply with the requirement to assure that funding will be available when needed NASA LeRC intends to make all appropriate and timely budget submissions necessary to assure that required funds for decommissioning will be requested. NASA LeRC also intends to advocate appropriate priority in requesting funding for this project when it becomes necessary.
It must be noted that one aspect of the process by which funds are appropriated is not entirely within the control of the licensee, namely the role of the United States Congress in appropriating the funds by which all Federal agencies operate. A facility project of this magnitude willlikely require a specific "line item" appropriation by the United States Congress, and the licensee cannot make commitments of behalf of the United States Congress.
3.
Side bars have been added to indicate all changes in the License, the Technical Specifications (TS's) and the Safety Analysis. Reasons for each change are provided below. Where the explanatior. is provided by the answer to one of the specific questions that answer is referenced.
i For the " Amendment to License No. TR-3, Docket No. 50-30", Item 1 (page 1), the change is in response to PBRF Question #3.a. Please refer to that answer for more information.
For the " Amendment to License No. TR-3, Docket No. 50-30", Item 4, the reasons for the change from a ten year to a twenty year extension are discussed in the answer to PBRF Questions #1 and #2.a. Please refer to those answers for more information.
For the Technical Specifications (TS) Table of Contents, the new items (proposed TS 2.21,2.22,2.23, pages 17 - 19) are in response to PBRF Questions # 3.o, # 3.q, and # 3.r. Please refer to those answers for more infonnation. Proposed TS 1.2 was also modified to include reference to these new system specific TS's.
For the TS Table of Contents the Generic Organization Chart has been pulled out of the body of the document and has been designated as an attachment. This was done for clarity in the flow of the document.
For proposed TS 1.0 (page 1), TS 1.3.1 (page 2), and TS 4 (page 25), the reference has been updated from ANS 15.1-1982 to ANS 15.1 - 1990 following a review of the current ANS standard, based on PBRF Question l
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Proposed TS 2.8.c (page 9) was added in response to PBRF Questions
- 3.s and # 3.t. Please refer to the answers to those questions for more information.
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Proposed TS 2.12.b and " Bases" (page 12) have been modified in response to PBRF Question # 3.h. Please refer to the answer to this question for more information.
Proposed TS 2.15.b (page 14) has been modified in response to PBRF l
Question # 3.i. Please refer to the answer to this question for more information.
Proposed TS 3.1.1 (page 19) was modified to reflect the current management organization at NASA Lewis Research Center (LeRC). Please refer to the answer to PBRF Question # 3.k for more information.
l Proposed TS 3.1.2 (page 20) was modified in response to PBRF Question l
- 3.1. Please refer to the answer to that question for more information.
I Proposed TS 3.1.3 (page 20) was modified to reflect the current l
management organization at NASA LeRC. Please refer to the answer to PBRF Question # 3.k for more information.
l Proposed TS 3.3.2.b (page 24) was modified to delete reference to fuel since all fuel has been removed from the PBRF.
Proposed TS Figure I was changed to reflect the current NASA LeRC management organization. Please refer to the answer to PBRF Question #
3.k for more information, t
" Bases and Safety Analyses for PBkF" Table of Contents was modified to include reference to the PBRF Plot Plan which has been included for information. It was moved from the TS to its current location in response to l
PBRF Question # 3.g.
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" Bases and Safety Analyses for PBRF", section 2.0 (page 2) was modified to change the wording that indicated that all waste byproduct material had been removed from PBRF to the more accurate statement that most waste l
byproduct material had been removed, t
j In " Bases and Safety Analyses for PBRF" section 4.1 (page 3), the term j
" biological" was removed from the description of the concrete walls l
surrounding the Reactor Tank since their current status is no longer that of a biological shield.
" Bases and Safety Analyses for PBRF", section 4.2 (page 4), was modified l
j-to give exact numbers typical of maximum levels of tritium airborne l
particulate concentration actually measured in the Nitrogen Purge Gas system.
In several sections of the " Bases and Safety Analyses for PBRF" the duration of time since shutdown has been updated to 24 years, the current figure. The sections changed are: section 5.1 (page 5), section 5.2 (page 6), section 8.2 (page 9), section 9.2.2 (page 11), and section 12.2 (page 13).
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" Bases and Safety Analyses for PERF", section 5.2.2 (page 7), was modified to give exact numbers typical of oxygen levels actually measured inside the CV.
" Bases and Safety Analyses for PBRF", section 15.1 (page 15), was modified to give exact numbers typical of maximum activity levels actually measured in Emergency Retention Basin runoff.
3.a item 1 of the " Proposed Amended Facility License" has been updated to reflect all of the amendments, including the currently applied for amendment (No.9), that have a bearing on providing an exact description of the PBRF.
The combination of Amendment No.9 and the documents submitted as part of the original license provide the design bases for PBRF. The safety analyses and the facility descriptions are consistent with these documents.
Please refer to Item 1 for the list of exact documents and references which specify the design basis for the facility. Copies of all of these documents have been previously provided to the NRC.
3.b The wording ofItem 2 of the " Proposed Amended Facility License" has been changed back to be identical to the wording in the current license concerning the possession of byproduct material. The current wording may be seen in the revised and attached " Proposed Amended Facility License".
3.c The wording ofItem 3 of the " Proposed Amended Facility License" has been changed to match the wording of the current license. Proper reference to 10 CFR 10.34 has been added, and reference to 10 CFR 50.59 has been deleted.
3.d item 3c of the " Proposed Amended Facility License" has been deleted. This corresponds with the current license, which makes no reference to the possession of fuel.
3.e The wording of Item 4 of the " Proposed Amended Facility License" has been changed to match the wording in the current license, with the exception of updating the Amendment Number to reflect the current amendment (No. 9). The questionable reference to 10 CFR 50.59 has been deleted.
3.f The referenced TSs have been changed to reflect reference to ANSI /ANS 15.1 - 1990. The Technical Specifications were reviewed to insure compliance with this newer standard.
3.g Figure 1 in the TS was a plot plan of PBRF. It was included as an information item, and was not intended to lock in the current configuration as would be the result were it left in the TS. It has therefore been deleted l
from the TS and has been added to the safety analysis as was l
recommended.
3.h Proposed TS 2.12.b and the " Bases" section have been changed to indicate the correct current reference (10 CFR 20, Appendix B, " Concentrations in i
Air and Water Above Natural Background", Table II, Column 2).
3.i TS 2.15.b was changed to include a reference to the exact designation (Inspection Test Report #11," Facility and Environmental Radiological 6
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.l Monitoring") of the written procedure under which the quarterly radiological monitoring is performed.
3.j TS 2.18 " Bases" contained a typographical error, making reference to "10 CFR 10".~ This has been corrected to "10 CFR 20".
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3.k TS 3.1.1," Level 1 Directorate" has been modified from the previous license -
in order to properly reflect the current management organization and responsibihties at NASA Lewis Research Center (LeRC). This also explains the change to the Generic Organization Chart, now shown as TS j
Figure 1. The reorganization of the entire management structure ofIeRC was made official on October 1,1996. This change occurred at the same time that this application for a license amendment was being prepared. It was decided to incorporate the resulting changes into this application, rather than making it a separate application along the lines of Amendment No.8, which was made only to reflect a management change.
Under the current organization, the Plum Brook Management Office (PBMO) has effectively been elevated one level in the management chain.
The PBMO now reports directly to the Level 1 Directorate rather than to an intermediate Division, thus the elimination of the "Aeropropulsion Facilities -
l and Experiments Division". As a result of this reorganization some of the i
responsibilities, such as providing the resources required to maintain i
PBRF, now reside at a higher organizational kvel. This license renewal application has been changed to properly reflect these changes. The organization chart has been made more generic by removing specific office and directorate names. This change avoids requiring a license amendment each time the name of an office is changed. Should the actual responsibilities of any of the parties involved change, the license would be amended to reflect that. The TS clearly defines all elements of responsibility for safe possession of the PBRF.
-l 3.1 TS 3.1.2 has been changed to include specific provisions stating that neither the chair of the audit committee nor its members shall be directly associated J
with the facility, thu< assuring their independence as an auditing body. It should be noted that we intend to continue a past practice where one individual is a member of both the Audit Committee and the Safety Committee. This person ~is never in a chair position. It has been found that this practice improves communication between these two oversight groups without compromising the perfonnance of their duties or the independence of their actions. It is not felt that membership on the Safety Committee by itself constitutes a direct association with the facility which would disqualify an individual from being a member of the Audit Committee.
3.m Proposed TS Figure 2, " Generic Organization Chart", is now proposed TS Figure 1. The " Pollution Control Board" was removed from the chart since they do not carry out any activities or have any responsibilities with regard to NRC licensed functions concerning the PBRF.
3.n The title of proposed TS 3.3.3 has been changed to "Special Reports".
i 3.o Proposed TS 2.21, " Nitrogen Purge System (NPS)", has been added to address the concerns regarding insuring the NPS remains operable to reduce j
corrosion within the Reactor Tank (RT). The system currently is monitored
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by both a high and low pressure alarm, and this has been made part of the new TS. The system is now required by the TS to be returned. to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This time period is considered very conservative given the -
absence of ingress points for moist air into the RT in the event of a loss of nitrogen flow. It was proposed in the original question that there be -
" regular examination of associated components to ensure corrosion has not f
had an effect on the components and eventual decommissioning activities".
Since the components protected by the NPS are all located inside the RT which is closed, and is covered by three 20 ton shrapnel shields, it was felt that it would not be practical to require such an inspection.
There has been no documented periodic review of the continuing need for the nitrogen purge of the RT. However, a review of all PBRF systems was conducted as part of the activities during 1995 when the plans were made for the upcoming major facility maintenance project. This maintenance project will include repair of building roofs and exterior walls, upgrade of the alarm system, replacement of communication cables, refurbishment of the cathodic protection system, repair of the facility fence, and the opening and inspection of various areas such as the Primary Pump j'
House and the Hot Drains. In addition, a decision was made to upgrade the NPS from relying on a roadable nitrogen tube trailer for its source by installing a large permanently mounted nitrogen storage tank to replace the existing nitrogen supply system thus resulting in a more reliable gas supply.
i This maintenance project is expected to be completed during FY 97. The fact that the decision was made to put resources into upgrading the NPS l
serves to document that a review ofits continuing need was conducted and the decision was to keep it in service.
3.p In " Bases and Safety Analysis," section 4.2, page 4, the term MPC was used. This was identified as a term not currently in use by the NRC. The term has been replaced with the term " Derived Air Concentration limit" in the current version.
l 3.q As was discussed in the answer to question 3.o concerning the NPS, no formal, documented review of the need for cathodic protection has taken place. However, the need for this system was examined in 1995 in j
preparation for the upcoming major maintenance project. It was determined i
e that the cathodic protection system (CPS) is required for long term protection of the CV. The refurbishment of the cathodic protection system and its return to full operating capability is expected to be completed in l.
1997.
The CV sample metal coupons are made of the same grade steel as the CV wall. Six of these coupons are suspended by fishing line in the groundwater deepwells around the CV. These coupons are suspended at a height that results in their alternately being submerged by the groundwater, and then being exposed to air as the water level in the deepweils vary during sump pump operation. The coupons are removed from the deepwells as part of an annual Inspection and Test Report (ITR) procedure to check the CV integrity. The coupons are analyzed m the station chemistry lab where l
the corrosion layer is mechanically removed. They are then weighed and am retumed to the deepwells. The observed corrosion rate over the last several years has been less than 0.75% weight loss per year. There has been no preset acceptance criteria for the corrosion rate.
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It has been realized for some time that this pa*icular test, although -
considered conservative, has questionable valv Removing the oxide layer that builds up on the sample each year does not accurately represent the condition experienced by the CV wall. During a November,1996 meeting-of the Plum Brook Reactor Safety Committee it was decided that once the cathodic protection system was fully restored, the current ultrasonic thickness testing would be conducted only as a backup measure. 'In addition the sample coupon testing could be terminated due to the y
questionable value of its results. References to the sample coupon testing in
" Bases and Safety Analysis", section 5.1, have been deleted.
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Proposed TS 2.22," Cathodic Protection System (CPS)", has been added to address the questions concerning insuring the physical integrity of the CV.
As written,it requires that the CPS to be operable with quarterly checks to monitor its operation (these quarterly checks have been conducted regularly since the PBRF was shutdown in 1973). Should the CPS be found to be non-operable for two consecutive quarters the ultrasonic test of the CV wall thickness below ground will be performed until the CPS is repaired. This action will serve to monitor for potential changes in the CV wall thickness due to corrosion while the CPS is offline.
3.r Proposed TS 2.23, " Primary Pump House Roof Plugs (PPH RP) has been added to formalize the procedures already in place with regards to monitoring the integrity of the seals of the PPH RP. These procedures are described below.
i The roof hatch plugs of the Primary Pump House are sealed with silicone L
caulk prior to the application of several inches of roofm' g foam. This integral foam roof approach is used for sealing the roofs on all the PBRF buildings. The integrity of the watertight seal cannot be checked directly without cutting through the roof foam, which in tum destroys part of the j
sealing barrier. An indirect means of checking the seal is to place a piece of l
cloth on a long pole which is passed through a small penetration into each L
PPH compartment and lowering it down until it touches the floor. If the -
cloth comes back dry there is assumed to be nc leakage, and no further action is taken. Ifit came back wet the seal would be assumed to be leaking and repairs would have to be made. This method of checking the plug is performed on an annual basis under an existing Inspection and Test Report
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(ITR) procedure. If there is no moisture discovered, as has always been the case, the roof plugs themselves remain uninspected (beyond exterior visual observation) until it is time to replace the roof foam layer. The PPH RP's will be inspected as part of the FY 97 maintenance project. This will be the first time since 1985 that the roofing foam will be cut away, the roof plugs removed, and the PPH compartments fully inspected. The roof plug is the only means of access into each compartment. Upon reinstallation the plugs will be recaulked prior to the new roofing foam being installed.
3.s Proposed TS 2.8," Hot Drain System", has been modified to specifically require that the seals on the hot sumps and drains be checked annually.
l This activity has been performed since the PBRF was shut down in 1973 It is part of an existing ITR which checks every accessible penetration or access point to all contaminated systems annually.
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l 3.t Proposed TS 2.8, " Hot Drain System", has been modified to specifically require that the plugs in the floor drains be checked annually. This activity has been perfonned since the PBRF was shut down in 1973. It is part of an i
existing ITR which checks every accessible penetration or access point to all contaminated systems annually.
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Re:
Request for Additional Information concerning the National Aeronautics and Space -
Administration (NASA) Mock-Up Reactor (MUR) " Request for Amendment to License R-93, Docket No. 50-185 for Renewal of Possess-But -Not-Operate License" dated November 21,1996.
Note - Where appropriate the answers here may make reference to answers provided to l
Plum Brook Reactor Facility (PBRF) questions.
1.
Please see the answer given to PBRF Question # 1 for the response to the first part of this question. Please also refer to Enclosure 2 to see the generic schedule for completion of decommissioning and final termination of the license.
i There is an additional request in this question to provide specifications for annually reassessing the analyses of the waste disposal situation and the decay of the existing radionuclide inventory. These am the bases of reasoning behind requesting a i
license extension for the PBRF. The decision to decommission the MUR is directly linked to the decisions made concerning decommissioning the PBRF.
NASA will institute the requirement to perform and document these analyse 3 he made part of a new or existing ITR procedure. This will satisfy the request for a specification to cover these analyses.
j 2.a Please see the answer given to PBRF Question # 2.a.
2.b Please see the answer given to PBRF Question # 2.b.
3.
Side bars have been added to the License, the Technical Specifications (TS) and Safety Analysis to indicate the location of changes. Reasons for each change are provided below. Where the explanation is provided by the answer to one of the specific questions that answer is referenced.
For the " Amendment to License No. R-93, Docket No. 50-185", Item 1, the change is to make the format similar to that in the PBRF License Amendment. The additional information provided gives an improved i
listing of applicable amendments.
For the " Amendment to License No. R-93, Docket No. 50-185, Item 4, the reasons for the change from a ten year to a twenty year extension are discussed in the answer to MUR Question # 2.a.
For proposed TSs 1.2.1 (page 2) and 4.2 (page 12) the reference has been updated from ANS 15.1 - 1982 to ANS 15.1 - 1990 following a review of the current ANS standard, based on MUR Question # 3.h.
For proposed TS 3.1.1 (page 7) the description of the Level I responsible party has been updated to reflect the current NASA LeRC management arrangement. This is further explained in the answer to MUR Question 3.h.
For proposed TS 3.1.2 (page 7) the details of the requirements for the Internal Audit committee were modified in response to MUR Question #
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For proposed TS 3.4.a (page 11) the term " radioactivity" was changed to
" radiation levels". It was felt that the new term is more accurate and.
l specific.
For proposed TS Figure I the change is based on the current LeRC management arrangement. This is further explained in the answer to MUR Question 3.h.-
The figures formerly attached to the TS (PBRF Plot Plan, RB and Hot Lab Plan, MUR Cross Section) have been attached to the " Bases und Safety i
Analysis" section as suggested in MUR Question # 3.j.
For the " Bases and Safety Analysis for the Plum Brook Mock-up Reactor",
section 4.2, the duration since shutdown has been updated to indicate the passage of 24 years since the facility was shutdown.
3.a The wording'ofItem 2 of the " Proposed Amended Facility License" has l
been changed back to be identical to the wording in the current license l
concerning the possession of byproduct material. The current wording may be seen in the revised attached " Proposed Amended Facility License".
3.b The wording of Item 3 of the " Proposed Amended Facility License" has i
been changed to match the wording of the current license. Proper reference to 10 CFR 10.34 has been added, and reference to 10 CFR 50.59 has been deleted.
3.c Item 3c of the " Proposed Amended Facility License" has been deleted. This corresponds with the current license, which makes no reference to the c
possession of fuel.
3.d The wording ofItem 4 of the " Proposed Amended Facility License" has.
been changed to match the wording in the current license, with only the exception of updating the Amendment Number to reflect the current amendment (No. 9). The questionable reference to 10 CFR 50.59 has been deleted.
l 3.e Please refer to the answer to PBRF Question # 3.k.
3.f The proposed MUR TS 3.1.2," Internal Audit", has been rewritten to mirror the wording found in proposed PBRF TS 3.1.2," Internal Audit".
As currently worded the TS will ensure that the Audit Committee functions independently of PBRF management, and that its members will have nuclear experience. Please refer to the answer to PBRF Question #3.1 for a more extensive discussion of the Audit Committee.
3.g The typo noted in proposed TS 3.1.3," Radiation Safety Officer (RSO), has been corrected ("he" has been changed to "the").
3.h The referenced TSs have been changed to reflect reference to ANSI /ANS j
15.1 - 1990. The Technical Specifications were reviewed to insure i
compliance with this newer standard.
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3.i Proposed TS Figure 1," Generic Organization Chart", has been modified.
l The " Pollution Control Board" was removed from the chart since the board 12
l does not carry out any activities or have any responsibilities with regard to NRC licensed functions concerning the MUR.
3.j Proposed TS Figures 2,3, and 4 have been transferred to the " Bases and -
Safety Analysis" section, as suggested. They are now labeled " Bases and Safety Analysis" section, Figures 1,2, and 3, respectively.
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3.k Section 6. " References", of the MUR " Bases and Safety Analysis" has been l
updated to properly reflect the connection to the current " Bases and Safety l
Analysis" section of the PBRF license request.
l 3.1 Item 1 of the " Proposed Amended Facility License" has been updated to reflect all of the amendments, including the currently applied for l
Amendment No.5, that have a bearing on providing an exact description of the MUR. Amendment No.5 along with the documents submitted with the l
original license provide the design basis for the MUR. The safety analyses and the facility descriptions are consistent with these documents. This format is consistent with the approach used in the " Proposed Amended Facility License" for the PBRF. Please refer to Item 1 for the list of exact documents and references which specify the design basis for the facility.
Copies of all of these documents have been previously provided to the l
NRC.
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AMENDMENT TO LICENSE NO. TR-3
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Docket No. 50-30 General Information l
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Pursuant to 10 CFR 50.33, the following information is provided to support the request for an Amendment to License TR-3, Docket No. 50-30.
l 1.
Aoplicant -
National Aeronautics and Space Administration l
l 2.
Address -
Lewis Research Center, Cleveland, OH 44135 l
l 3.
Class of License-104; Possess-But-Not-Operate l
4.
Use of Facility -
The facility has no fuel and the reactor is in a pro-tected safe storage condition.
5.
Period of Time for which License is Sought - Twenty years from date of l
issuance l
6.
Financial Oualification - Being an agency of the United States' Govern-l ment, NASA is financially qualified to possess the requested license.
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NATIONAL AERONAUTICS AND SPACE ADMINISTRATION DOCKET NO. 50-30 PROPOSED AMENDED FACILITY LICENSE Amendment No. 9 License No. TR-3
- 1. The proposed Amendment to facility license No. TR-3 should read as follows:
This license applies ?,.ne heterogeneous light water-cooled and moderated test reactor referred to as the Plum Brook Reactor Facility (PBRF). The PBRF includes all associated on site support facilities except for the Mock-Up Reactor (MUR) which is under separate License R-93, Docket No. 50-185.
The PBRF is owned by the National Aeronautics and Space Administration (NASA), an independent agency of the United States Government and located at the NASA Plum Brook Station near Sandusky, Ohio. The PBRF is described in the application for the full-term license dated January 10,1964, and amendments thereto, including:
AMENDMENT 5 FOR STANDBY Application - March 19,1973 Supplement - May 11,1973 AMENDMENT 6 TO EXCLUDE STRUCTURES 1121.1142,1156 Application - October 27,1976 AMENDMENT 7 FOR PROTECTED SAFE STORAGE Application-July 26,1985 AMENDMENT 8 FOR CHANGE OF ADMINISTRATIVE OVERSIGHT Application - February 27,1989 Supplement -June 22,1989 AMENDMENT 9 FOR CONTINUED SAFE STORAGE Application - November 4,1996 Supplement - This submittal 1
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- 2. Subject to the conditions and requirements incorporated herein, the U.S.
Nuclear Regulatory Commission hereby licenses NASA:
.(1) Pursuant to Section 104c of the Act and 10 CFR Chapter I, Part 50,
" Licensing of Production and Utilization Facilities", to possess, but not operate, the reactor as a utilization facility; and (2) Pursuant to the Act and 10 CFR Chapter I, Part 30," Licensing of l
Byproduct Material," to possess, but not separate, such byproduct material as may have been produced by operation of the reactor.
- 3. This license shall be' deemed to contain and be subject to the conditions i
specified in Part 20, Section 30.34 of Part 30, and Section 50.54 of Part 50, l
10 CFR Chapter I, and to all applicable provisions of the Act and to the rules, j
regulations, and orders of the Commission now or hereafter in effect and to l
the additional conditions specified below:
i (A) NASA shall not reactivate the PBRF without prior approval of the Commission; and (B) NASA shall not dismantle or dispose of the PBRF without prior approval of the Commission.
- 4. TechnicalSpecifications i
The Technical Specifications contained in Appendix A, as revised through Amendment No. 9, are hereby incorporated in this license. The licensee shall maintain the facility in accordance with the Technical Specifications.
This license is effective as of the date of issuance and shall expire after twenty years.
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ATTACHMENT TO LICENSE AMENDMENT NO. 9 1
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FACILITY OPERATING LICENSE NO. TR-3 i
DOCKET NO. 50-30 1-4 1-1 i
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.f Revised Appendix A Technical Specifications in their entirety.