ML20151C068

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Safety Evaluation Supporting Amend 7 to License R-97
ML20151C068
Person / Time
Site: Neely Research Reactor
Issue date: 07/12/1988
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20151C055 List:
References
NUDOCS 8807210213
Download: ML20151C068 (5)


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~g UNITED STATES

- E o NUCLEAR REGULATORY COMMISSION

;e WASHINGTON. D. C. 20555 k*****,o#

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l l

SUPPORTING AMENDMENT NO. 7 TO >

FACILITY OPERATING LICENSE NO. R-97 l l

GEORGIA INSTITUTE OF TECHNOLOGY DOCKET NO. 50-160

1.0 INTRODUCTION

By letters dated August 6,1987, as supplemented, an4 March 1,1988, the Georaia Institute cf Technology (Georgia Tech) requ oted changes to Facility Operating License No. R-97 and to Appendix A of the License, Technical Specifications for the Georgia Tech Research Reactor (GTRR).

The requested changes would (1) remove from the license authority to receive and possess up to 700 grams of U-235 in the form of AGN-201 reactor fuel, (2) add nitrogen to the Technical Specifications as a cover gas over the heavy water in the aluminum tank of the reactor, (3) clarify the technical specifications requirements as to the timing and number of samples to be analyzed in connection with release of the contents of the liquid waste tanks to the sanitary sewer, and (4) modify the' technical specifications organizational structure of the GTRR and change the structure and responsibilities of the Nuclear Safeguards Comittee (NSC).

2.0 EVALUATION 2.1 Decrease in Fuel Inventory ,

1 Georgia Tech operated an AGN-201 reactor on its campus from 1968 to 1979 l under Operating License No. R-111 (Docket 50-276). The license was terminated by an NRC Order issued on January 7, 1986. To allow for the orderly and timely decommissioning of this reactor and termination of the operating license, the authority to receive and possess '.he AGN-201 fuel was transferred to the GTRR license by Amendment No. 6 cated March 14, 1985. This would allow possession of the fuel until st:h time that shipping containers were available to return the fuel v.o its owner, tne ,

Department of Energy. The fuel was returned to Oak Ridge National Laboratory on December 8, 1987. Therefore, the authorization to receive and possess this fuel is no longer needed in the GTRR license, 880721o213 DR e00712 ADOCK 05000160 PNU

. 2.2 Addition of Nitrogen as a Reactor Cover Gas The GTRR circulates a cover gas over the heavy water coolant and moderator in the aluminum reactor tank to carry dissociated deuterium and oxygen out of the reactor tank and into a recombiner. The only cover gas allowed by the Technical Specifications has been helium. Due to helium leakage out of the core vicinity and a resulting increase in Ar-41 production due to inleakage of air, the licensee requested that nitrogen be added as an approved cover gas. Nitrogen is heavier than helium and will not leak out of the system as readily as helium.

The licensee addressed and the staff reviewed the following considerations:

(1) chemical interaction between nitrogen and heavy water. Continuous operation at 5 MW(t) would produce a small decrease h pH of the heavy water due to the formation of oxides of nitrogen. There are existing limits on pH in the Technical Specifications to limit corrosion. The licensee continues to be bound by the Technical Specifications.

(2) Production of radioisotopes in the cover gas. A small amount of C-14 (approximately 30 pCi/hr at 5 MW(t)) would be produced from tk n/p reaction on nitrogen. This would result in C-14 concentrahons much below the limits of 10 CFR Part 20. (3) The recombiner creration would be unaffected by the addition of nitrogen as a cover gas. *(4) The ,

Technical Specifications require that the deuterium concentration in the  !

cover gas sweep system is less than 2% by volume. This is confirmed by  ;

measuring the deuterium concentration in the cover gas using a gas  !

chromatograph. The gas chromatograph used to confirm this specification I will perform its function with nitrogen as the sweep gas.

In addition, the staff considered flamability of deuterium in oxygen-helium and oxygen-nitrogen mixtures and concluded that there is no significant difference in the behavior of the two systems. The Technical Specifi-cations requirement of 2% deuterium by volume in the cover gas continues to provide a large margin of safety with regard to flammability.

2.3 Surveillance of Release of Liquid Effluents The licensee has requested a change in Technical Specificatien 3.5.a.5 which governs the number and timing of samples that must be analyzed in the process of releasing liquid effluents from the liquid waste tank to the sanitary sewer system. The current specification has been interpreted i as requiring up to three samples while the licensee's practice and l 1

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7 intent is to take two samples. The requested change clearly requires two samples be taken and analyzed to confirm that the discharge will be  :

within 10 CFR Part 20 and Technical Specifications limits. The first sample is taken after the tank has been isolated but prior to initiation of the discharge to the sanitary sewer and the second is taken at a point ,

after the discharge halfway mark but before the_ tank is three-quarters l empty. This second sample point was discussed with and agreed to by l Georgia Tech in a telephone conversation with the Project Manager on June 17, 1988. The discharge will be stopped when the second sample is ,

taken pending an acceptable result from the second analysis. The entire j discharge process will be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This change clarifies the conditions for release of liquid effluents which j currently exist. The licensee is still bound to meet the Technical '

Specifications concerning liquid effluents and the repuirements of 10 CFR Part 20.

2.4 Changes in Organizational Structure The licensee requested changes to the organizational structure of the GTRR. This structure is outlined in a February 19, 1988 memo from the President of Georgia Tech and was presented to NRC at a February 23, 1988 Enforcement Conference. A telephone conversation with the Director i on June 2, 1988, confirmed that this is the requested organization structure. The changes were requested to improve coordination between the Radiation Safety Office staff and the Reactor Operations staff. In the former organizational structure the radiation safety staff was independent of the GTRR Director and under the direct management of the University Radiation Safety Officer (RS0). Georgia Tech requested that the radiation safety staff become the responsibility of the GTRR Director from a day-to-day supervision and administrative reporting standpoint.

From a safety and safety 3olicy standpoint, the radiation safety staff would report to the NSC W11ch is chaired by the RSO. This organizational arrangement, where the radiation safety staff reports to the facility director, is successfully in use at other non-power reactors to stream-line facility operation.

To reduce the possibility that a conflict of interest may occur because the GTRR Director has responsibility for facility operation and safety, oversight responsibility is given to the NSC and to the RSO. The Manager of the Office of Radiation Safety reports to the NSC on issues concerning safety and safety policy. This arrangement allows the Director to have management control over the radiation safety staff while allowing for outside oversight that enhances radiation safety.

The licensee requested changes in the review and audit responsibilities of the NSC. The duties requested of the NSC were less than those suggested in NiS/ ANSI-15.1-1982, "The Development of Technical Specifications for Research Reactors" (ANS-15.1). In their response of February 18, 1988 to a Request for Additional Information from the NP,C dated December 7, 1987

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on this subject, the licensee stated that all of the duties in ANS-15.1 l were implicitly included in the requested Technical Specifications and in the Emergency Preparidness Plan. In view of the expanded responsibility that the Director h.s in the area of radiation safety and the need for strong oversight, it is desirable to formalize the duties of the NSC. In telephone conversations with the GTRR Director on July 6 and 7, 1988, it I was agreed that in addition to the NSC duties requested by Georgia Tech to be included in the Technical Specifications, those duties which the licensee stated were implicit have been formalized by adding them to the Technical Specifications.

The licensee also stated in response to the Request for Additional Information that the NSC performs audits of the facility on an informal annual frequency. To maintain strong oversight, it is important for the NSC to audit the program at a regular interval. Withbut the incentive of

. a technical specifications requirement, it cannot be insured that the program will undergo regular review by the NSC. In telephone conversations with the GTRR Director on July 6 and 7, 1988, it was agreed that audits of reactor operations and correction of deficiencies will occur annually with the interval between audits not to exceed 15 months. The reactor operator training program will be audited every two years with the interval between audits not to exceed 30 months. Because the licensee states that audits are currently performed annually, adding these requirements to the Technical Specifications will serve to formalize existing practice.

3.0 ENVIRONMENTAL CONSIDERATION

3.1 Decrease in Fuel Inventory, Addition of Nitrogen as a Reactor Cover Gas, and Surveillance of Release of Liquid Effluents This section of the amendment involves changes in the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes in inspection and surveillance requirements.

The staff has determined that the amendment involves (1) no significant hazards consideration, (2) no significant increase in the amounts, and no significant ch,n offsite, and (3)gethere in theistypes, of any effluents no significant increasethat may be released in individual or cumulative occupational radiation exposure. Accordingly, this section of the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this section of the amendment.

3.2 Changes in Organizational Structure This section of the amendment involves changes in the category of recordkeeping, reporting, and administrative procedures and requirements.

Accordingly, this section of the amendment meets the eligibility criteria

for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this section of the amendment.

4.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that: (1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously evaluated, or create the possibility of a new or different kind of accident from any accident previously evaluated, and does not involve a significant reduction in a margin of safety, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed activities, and (3) 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 Contributor: Alexander Adams, Jr.

Dated: July 12, 1988

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