ML20196B108

Forwards Request for Addl Info Re Amend Request for Amended FOL R-66 for University of Virginia Research Reactor, Submitted on 980929.Response Requested within 30 Days of Date of Ltr

ML20196B108
Person / Time
Site:	University of Virginia
Issue date:	11/23/1998
From:	Alexander Adams NRC (Affiliation Not Assigned)
To:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
References
TAC-MA3737, NUDOCS 9811300262
Download: ML20196B108 (7)

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November 23, 1998 Dr. Robert U. Mulder Director, University of Virginia Reactor Facility

. Department of Mechanical, Aerospace and Nuclear Engineering University of Virginia.

Charlottesville, VA 22903-2442

SUBJECT:

REQUF^T FOR ADDITIONAL INFORMATION (TAC NO. MA3737)

Dear Dr. Mulder:

' We are continuing our review of your amendment request for Amended Facility Operating License No. R-66 for the University of V:rginia Research Reactor which you submitted on September 29,1998. During our review of your amendment request, questions have arisen for which we require additionalinformation and clarification. Please provide responses to the enclosed request for additional information within 30 days of the date of -

this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a j signed original under oath or affirmation. Fo!!owing receipt of the additional information,  ;

we will continue our evaluation of your amendment request.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely, ORIGINAL' SIGNED BY:

Alexander Adams, Jr., Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-62 tinclosure:

As stated cc w/ enclosure:

See next page DISTRIBUTION:

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i November 23, 1998 Dr. Robert U. Mulder Director, University of Virginia Reactor Facility l Department of Mechanical, Aerospace j

and Nuclear Engineering l University of Virginia Charlottesville, VA 22903-2442

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MA3737) l

Dear Dr. Mulder:

We are continu:ng our review of your amendment request for Arnended Facility Operating License No. R-66 for the University of Virginia Research Reactor which you submitted on l September 29,1998. During our review of your amendment request, questions have arisen for which we require additionalinformation and clarification. Please provide '

remonses to the enclosed request for additionalinformation within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additionalinformation, we will continue our evaluation of your amendment request.

1 If you have any questions regarding this review, please contact me at (301) 4151127. l l

Sincerely, ORIGINAL Y l Alexander IGNED dams, hr.f Senior Project Manager i Non-Power Reactors and Decommissioning Project Directorate  !

Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-62

Enclosure:

As stated cc w/erciosure:

See next page DISTRIBUTION:

E-MAIL HARD COPY PDoyle TBurdick Docket File 50-62 JRoe TDragoun MMendonca PUBLIC AAdams TMichaels SWeiss OGC EHylton SHolmes CBassett DMatthews PDND r/f WEresian Pisaac PON PDN M PDND:D k N on AA . SWeiss

////'//98  !! A'798 d /v'f)8 OFFICIAL RECORD COPY DOCUMENT NAME: G:\SECY\ ADAMS \62RAl.24

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. ;5 j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 3066H001 l

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November 23, 1998

• • • • • l l

Dr. Robert U. Mulder Director, University of Virginia Reactor Facility Department of Mechanical, Aerospace and Nuclear Engineering University of Virginia Charlottesville, VA 22903-2442 l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MA3737)

Dear Dr. Mulder:

W6 are continuing our review of your amendment request for Amended Facility Opera'.ing License No. R-66 for the University of Virginia Research Reactor which you submitts.d on September 29,1998. During our review of your amendment request, questions have arisen for which we require additionalinformation and clarifica"on. Please provide responses to the enclosed request for additionalinformation > .ithin 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your amendment request.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely, 43* h Alexander Adams, Jr., Seni roject Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-62

Enclosure:

As stated cc w/ enclosure:

See next page

l University of Virginia Docket Nos. 50-62/396

)

cc:

Department of Environmental Quality Mr. Paul E. Benneche, Supervisor Office of Grants Nuclear Reactor Facility Management / Intergovernmental University of Virginia Affairs c/o Thornton Hall 629 East Main Street, Sixth Floor -Charlottesville, Virginia 22903 2442 Richmond, Virginia 23219 Dr. William Vernetson Director of Nuclear Facilities Department of Nuclear Engineering Sciences University of Florida 202 Nuclear Sciences Center

. Gainesville, Florida 32611 Dr. Rolan E. Hertel, Director Neely Nuclear Research Center

. Georgia Institute of Technology 900 Atlantic Drive, N.W.

Atlanta, Georgia 30332 Mr. Pedro B. Perez, Associate Diiector Nuclear Reactor Progr.1m North Carolina State University P. O. Box 7909 Raleigh, North Carolina 27695-7909 Office of the Attorney General 101 North 8th Street Richmond, Virginia 23219 Bureau of Radiological Health Division of Health Hazards Control l 109 Governor Street, Room 916 Richmond, Virginia 23219

. r. Ralph O. Allen, Chairman ricactor Decommissioning Committee University of Virginia Environmental Health and Safety P.O. Box 3425 Charlottesville, Virginia 22903

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l REQUEST FOR ADDITIONAL INFORMATION UNIVERSITY OF VIRGINIA RESEARCH REACTOR l DOCKET NO. 50-62 l

l 1. Please propose changes to the reactor license to reflect the permanent shut down of the reactor. License paragraphs I.B, ll.B.(1), and ll.C.(1) refer to operation of the reactor. License paragraphs 1. H. and ll.B.(2) and (3) refer to use of byproduct or special nuclear material or both.

2. License condition ll.B.(3) refers to your ccbalt-60 source. Storage of the source is j limited to the reactor pool. This license condition needs amendment if technical l specification (TS) 3.11 is changed to allow possession and storage of the cobalt-60 outside the reactor pool. Please discuss the radiation protection aspects of storage of the cobalt-60 source outside of the reactor pool.

3. Can license paragraph ll.B.(4) be removed from the license?

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4. TS 1.0. Definition of Methods. Will methods be written after the Reactor Safety Committee is eliminated? If so, what committee will be sent newly developed methods as information items? Definition of Reactor Facility. Please consider l adding a figure to the TSs that shows the reactor facility boundary.

5. Is there a TS requirement to have any radiation monitoring instruments operable during activities that have the potential to produce airborne radiation hazards or l radiation fields, for example, fuel movement for shipping purposes (it appears that TS 3.3 is not applicable with the core permanently unloaded)? How do you purpose to show compliance with TS 3.4.1 which states that the activity of gases released beyond the reactor facility's site boundary shall not exceed 10 CFR Part 20 limits?

This question also applies to your proposed deletion of TS 4.A and 4.7. Are there future plans to have radiation monitoring equipment operable during t decommissioning activities that have the potential to generate airborne activity?

6. TS 3.6.6. In your discussion (page 2) of the changes to this TS you refer to Co-60 rods. Your proposed TS wording refers to Co-60 pins. Please clarify.

7. TS 3.11. Please place wording about limitations on the TS in the specification becaus* :;nly the specification is governing (see your definition for specification).

For example, TS 3.11.1 could be worded to say "If reactor fuel or cobalt-60 rods

.are present in the pool, conductivity of the water shall be no higher than 5 x 10 8 mhos/cm."

l l 8. TS 4.4. Please place wording about limitations on the TS in the specification l because only the specification is governing.

9. TS 4.6 and 5.2. Are there future plans to maintain confinement during i decommissioning activities that have the potential to generate airborne activity?

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10. TS 4.8. This TS cannot be deleted until TS 3.11 no longer applies. For example, TS 4.8 could be worded to say "If required by TS 3.11, the conductivity and pH of the primary coolant water shall be measured at least once every 2 weeks and shall be . . . "

11. _TS 5.3. Please place wording about limitations on the TS in the specification because only the specification is governing. 1

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12. . Please give an explanation for each TS you are proposing to change in TS 6 similar to what you did for the other proposed TS changes.

13. What is the difference between the Vice President for Research (current TS) and 1

i. Vice President for Research and Public Service? Will there be any reduction in Level l

1 oversight of the reactor facility?

l l- 14. The Reactor Decommissioning Committee (RDC) is not shown on the organization

! chart. Please show the position of this committee in the organization and its lines L of responsibility and communication. Also please show the position of the radiation l safety committee on the organization chart (chart only shows the committee chair).

15. The discussion of the structure and responsibility of the RDC and the RDC chair in TS 6.1.1. and 6.1.2. is confusing. TS 6.1.1 states that the Chair of the RDC advises the Vice President for Research and Public Service on decommissioning l matters while TS 6.2.B' states that the RDC advises the Vice President. Please

- clarify. It appears that the same person is the Chair of the RDC, the Chair of the l

, Radiation Safety Committee, the Director of the Office of Environmental Health and Safety, and is a level two reactor rr.anager, in addition, it appears that the radiation safety officer and rafation protection function report to this person. Please explain how the two committees can give independent advice to reactor management and upper university management under this proposed organization. Also how can the

requirement in TS 6.1.3 for organizationally independent health physicists be met l under this proposed organization?

16. How will the radiation safety committee communicate with reactor management after the reactor safety committee is eliminated (see organization chart)?

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17. TS 6.1.2 states that the reactor supervisor will obtain a reactor operator license if all reactor fuel has been shipped offsite. There is no requirement to have licensed operators after all fuel has been removed from the site. Please clarify this TS.

18. TS 6.1.4. Your proposed TS states that ANSI /ANS-15.4-1988 will be used to the

[. extent applicable to the decommissioning status of the facility. Please explain what parts of this standard you consider applicable.

l i 19. TS 6.2.A. It appears that the Radiation Safety Committee will take over some

{ - responsibility from the Reactor Safety Committee when the Reactor Safety b.

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3 Committee is eliminated. Please explain the role of the Radiation Safety Committee after elimination of the Reactor Safety Committee. Please add TS requirements that pertain to the operation and responsibility of the Radiation Safety Committee for the reactor facility. You have proposed reducing the minimum number of members on the Reactor Safety Committee from five to four. Please justify this change. It appears that the review and audit responsibilities of the Reactor Safety Committee have been removed from your proposed TSs. Please justify.

20. TS 6.2.B. Your proposed TS lists experience that membors of the RDC provide.

I Decommissioning is not on that list Please explain. Reference is made to a l decommissioning plan in the proposed TS when a plan has not been submitted.

This type of requirement should be proposed as part of the TSs for the decommissioning plan amendment application. The proposed TSs and RDC charter give the committee responsibilities such as the collection and maintenance of complete decommissioning records, the preparation of reports to NRC, the control of decommissioning work subcontractors, the administration of the decommissioning plan, and the control of licensed activities. These responsibilities are normally given to facility management and not the independent oversight committee. Please address. The review and audit responsibilities discussed in the RDC charter are different than those listed in the proposed TSs. Please explain.

21. TS 6.3.2. It appears that the Reactor Director and Radiation Safety Officer will take over approval responsibility from the Reactor Safety Committee for substantive changes to procedures after the Reactor Safety Committee is eliminated. Please justify this change. Who will review and approve new procedures (also see the definition for Standard Operating Procedures)?

22. TS 6.5. There is a current requirement to maintain records of meetings and audit reports of the Reactor Safety Committee. Will there be a similar requirement for the Reactor Decommissioning Committee?

23. TS 6.6. Why is violation of the TSs [ current TSs 6.6.2. (1) and (2)] not carried over to the proposed TSs as a reportable occurrence?

24. TS 6.7.2. Please propoce a reporting requirement for the possession-only period l including information to be included in the report.

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