ML20202A824
| ML20202A824 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 01/20/1999 |
| From: | Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| To: | Alexander Adams NRC |
| Shared Package | |
| ML20202A829 | List: |
| References | |
| TAC-MA3737, NUDOCS 9901280289 | |
| Download: ML20202A824 (24) | |
Text
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M UNIVrRSirY Of VIRGINIA h
Q Nuc TAR REAcron FAcntrY U.S. MAIL ADDRESS STREET ADDRESS i
RO. Box 3425 675 Old Reservoir Road 9
University Station Charlottesville, VA 22903 3
Charlottesville, V.k 22903 Tehyhone:
804-982-5440 Fax:
804-982 5473
-g January 20,199/
2 Mr. Alexander Adams,Jr.
Senior Project Manager Non-power Reactors and Decommissioning Project Directorate g
U.S. Nuclear Regulatory Commission j
One White Flint North 2
11555 Rockville Pike, Mail Stop O-11-D-19 Rockville, MD 20852-2738 ip
Subject:
NRC Request for Additional Information (TAC No. MA3737); UVA Request for a Possession i
Only Amendment to the license for the University of Virginia Reactor, Docket No. 50-62, License R-66.
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Dear Mr. Adams:
On September 29,1998, the University of Virginia filed with the NRC an amendment request for the 2
Technical Specifications of the University of Virginia Reactor (UVAR), Facility Operating License No.
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R-66. On November 23,1998, the NRC replied with a Request for Additional Information. On i
December 21, U.Va. filed a 30-day time extension request for its response. At this time we are
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submitting our response to the NRC questions. We are also proposing changes to the reactor license that
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reflect the permanent shut down state of the reactor, as requested by the NRC.
Please contact me at (804) 982-5440, or at rum @ Virginia EDUg'ou have)l c#
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j i hereby certify that the attached document is a true and
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f1018'y PL8W M, 8 n, --
t-,;..n mrdra Enc: Response to NRC Questions, Proposed UVAR TS, Proposed UVAR PO License, Justification for T
TS Changes, Reactor Decommissioning Committee Charter, Radiation Safety Committee Charter 1
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-d cc: Mr. Craig Ba.sset, NRC Region II, Atlanta, Ga.
1 Document Control Desk, NRC, Washington DC
}o h-o 9901290289 990 gDR ADOCK 0 2
REQUEST FOR ADDITIONAL INFORMATION UNIVERSITY OF VIRGINIA RESEARCH REACTOR i
DOCKET NO. 50-62 i
1.
Please propose changes to the reactor license to reflect the permanent shut down of the reactor. License paragraphs 1.B, ll.B.(1), and ll.C.(1) refer to operation of the reactor. License paragraphs I. H. and li.B.(2) and (3) refer to use of byproduct or special nuclear meterial or both.
' 2.
License condition ll.B.(3) refers to your cobalt-60 source. Storage of the source is limited to the reactor pool. This license condition needs amendment if technical 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 li.B.(4) be removed from the license?
4.
TS 1.0. Definition of Methods. Will methods be written after the Reactor Safety j
Committee is eliminated? If so, what committee will be sent newly developed methods as information items? Definition of Reactor Facility. Please consider adding a iigure 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 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 purposc 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 4.4 and 4.7. Are there future plans to have radiation monitoring equipment operable during 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 because only 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 4
are present in the pool, conductivity of the water shall be no higher than 5 x 10 mhos/cm."
8.
TS 4.4. Please place wording about limitations on the TS in the specification because only the specification is governing.
9.
TS 4.6 and 5.2. Are there future plans to maintain confinement during decommissioning activities that have the potential to generate airborne activity?
l
e 2
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.
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 Vice President for Research and Public Service? Will there be any reduction in Level 1 oversight of the reactor facility?
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 of responsibility and communication. Also please show the position of the radiation 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 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 Radiation Safety Committee, the Director of the Office of Environmental Health and Safety, and is a level two reactor manager. In addition, it appears that the radiation safety officer and radiation protection function report to this person. Please explain how the two committees can give independent advice to reactor management and i
upper university management under this proposed organization. Also how can the j
requirement in TS 6.1.3 for organizationally independent health physicists be met 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)?
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.
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
l 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 t
appears that the review and audit responsibilities of the Reactor Safety Committee have been removed from your proposed TSs. Please justify.
20.
TS 6.2.8. Your proposed TS lists experience that members of the RDC provide.
Decommissioning is not on that list. Please explain. Reference is made to a decommissioning plan in the proposed TS when a plan has not been submitted.
TI.is type of requirement should be proposed as part of the TSs for the decommissior;ing plan amendmer.t application. The proposed TSs and RDC charter give the committee responsibilities such as the collection and maintenance of complete decommissioning records, the preparaticn of reports to NRC, the control of i
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 j
different than those listed in the proposed TSs. Please explain.
71.
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)?
i 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 l
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?
l 24.
TS 6.7.2. Please propose a reporting requirement for the possession-only period including information to be included in the report.
I-i 1
l I
l U.Va. RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION UNIVERSITY OF VIRGINIA RESEARCH REACTOR i
DOCKET NO. 50-62 1.
Please propose changes to *5e reactor license to reflect the permanent shut down of the reactor. License paragraphs I.8, 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.
Reply:
License paragraph I.B. presently states:
"The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;"
Since the UVAR cannot be operated because it has been shut down permanently, it is proposed that paragraph I.B. be amended to:
l "The facility will be managed, but not operated, in conformity with the application, l
the provisions of the Act, and the rules and regulations of the Commission;"
License paragraph II.B.(1) presently states:
" Pursuant to Section 104c of the Act and 10 CFR 50," Licensing of Production i
and Utilization Facilities," to possess and operate the reactor as a utilization facility at the designated location near Charlottesville, Virginia, in accordance i
with the procedures and limitations described in the application and in this license."
l Again, the UVAR cannot be operated because it has been shut down. Therefore, it is proposed that paragraph II.B.(1) be amended to:
l Pursuant to Section 104c of the Act and 10 CFR 50," Licensing of Production and Utilization Facilities," only to possess, but not operate, the reactor as a utilization facility at the designated location near Charlottesville, Virginia, in accordance with the procedures and limitations described in the application and I
in this license."
License paragraph II.C.(1) presently states; I
"The University of Virginia is authorized to operate the reactor at steady state 1
I power levels up to a maximum of 2 megawatts (thermal)."
i it is proposed that the wording to paragraph II.C.(1) read:
"The University of Virginia will not load the reactor core and therefore not operate the reactor at any power level."
License paragraph I. H. presently reads:
"The receipt, possession and use of the byproduct and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10CFR30 and 70, including sections 30.33,70.23 and 70.31."
i No byproduct and special nuclear material will be received under the reactor license now that the reactor has been shut down. However, existing byproduct material and i
special nuclear material currently possessed under this license should remain under the reactor's license, and the possibility of its use, if needed, preserved. Therefore the J
proposed new wording for paragraph I. H. is-
"The possession and use of the byproduct and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR30 and 70."
License paragraph II.B.(2) currently states:
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1
" Pursuant to the Act and 10 CFR Part 70," Domestic Licensing of Special Nuclear Material," to receive, possess, and use up to a maximum of 12 kilograms of contained uranium-235 at various enrichments, up to a maximum of 16 grams of plutonium in the form of a sealed plutonium-beryllium neutron source in I
connection with operation of the reactor, and to possess, but not separate, such special nuclear material as may be produced by the operation of the facility.
Without exceeding the foregoing maximum possession limits, the maximum limits on specific enrichments of U-235 are as follows:
Maximum U-235 Kilograms
% Enrichment Form 11
< 20%
Materials testing reactor (MTR)-type fuel 1
Any Fission chambers, flux foils, and other forms used in connection with the operation of the reactor" Following removal of all UVAR LEU fuel elements, Uranium-235 will be held on-site awaiting final disposition. This uranium is at various enrichments, in the form of foils,3 HEU fresh fuel plates (<50 grams U-235), etc... Neutron sources containing plutonium 2
will be possessed until transferred to another license. For the period of time that the reactor is permanently shutdown and fuel is still onsite, the proposed wording is:
" Pursuant to the Act and 10 CFR Pan 70," Domestic Licensing of Special Nuclear Material," to possess a maximum of 12 kilograms of contained uranium-235 at various enrichments, up to a maximum of 16 grams of plutonium in the form of a sealed plutonium-beryllium neutron source previously used in connection with the operation of the reactor, and to possess, but not separate, such special nuclear material as may have been produced by the operation of the facility prior to its permanent shutdown. Without exceeding the foregoing maximum possession limits, the maximum limits on specific enrichments of U-235 are as follows:
Maximum U-235 Kilograms
% Enrichment Eorta 11
< 20%
Materials testing reactor (MTR)-type fuel 1
Any Fission chambers, flux foils, and other forms used in connection with the operation of the reactor" i
License paragraph II.B(3) presently is worded:
" Pursuant to the Act and 10 CFR Part 30," Rules of General Applicability to Licensing of Byproduct Material" to receive, possess, store and use in the reactor pool 70,000 curies of cobalt 60; to receive, possess and use 1.0 gram of neptunium 237; and to possess, but not separate, such byproduct materials as may be produced by the operation of the reactor."
The cobalt 60 pins held in the reactor pool have decayed down to less than 10,000 Curies. Additional cobalt 60 will not be acquired under the reactor license. An effort is underway to determine their original manufacturer. It may be possible to return the pins to the manufacturer. If the manufacturer will not receive the cobalt pins back, the option to remove them from the pool and to hold them at the Reactor Facility for shielded decay and eventual disposal is desirable. Removal of Co-60 pins from the UVAR pool would permit draining it at some future date.
Currently the facility possesses about 15 milligrams of neptunium 237.
Based on the above considerations, the suggested revised wording of this paragraph is:
" Pursuant to the Act and 10CFR30," Rules of General Applicability to Licensing of Byproduct Material," at the Reactor Facility, to possess, store and use 10,000 3
l curies of cobalt 60; to possess and use 1.0 gram of neptunium 237; and to possess, but not separate, such byproduct materials as may have been produced by operation of the reactor prior to its permanent shutdown."
2.A.) License condition ll.B.(3) refers to your cobalt-60 source. Storage of the source is limited to the reactor pool. This license condition needs amendment if technical specification (TS) 3.11 is changed to allow possession and storage of the cobalt-60 outside the reactor pool.
Reply:
Wording changes to license amendment II.B.(3) thN would permit possession, storage and use of the remaining Cobalt-60 at the RearJc. Facility, and not just in the pool, have been proposed in answer to the NRC's first question (see above).
2.B.) Please discuss the radiation protection aspects of storage of the cobalt-60 sources outside of the reactor pool.
The option permitting dry shielded storage of Co-60 pins, in a secured area yet to be determined within the Reactor Facility, is highly desirable. The Co-60 oins could be held safely for decay and eventual disposal. Specific radic*.:on protection aspects cannot be described until the precise conditions of cobalt storage have been worked out, however, the University commits to providing the radiation protection level required to meet federal regulations.
l
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l 3.
Can license paragraph II.B.(4) be removed from the license?
Reply:
No, but that paragraph can be modified. License paragraph II.B.(4) presently states:
" Pursuant to the Act and 10 CFR Part 70, " Domestic Licensing of Special Nuclear Material," to possess, but not to use, a maximum of 5.0 kilograms of contained uranium-235 at greater that 20-percent enrichment and other special nuclear material produced by the operation of the facility in the form of MTR-type reactor fuel until the existing inventory of high-enriched MTR-type fuel is removed from the facility."
The UVAR HEU fuel elements were shipped off-site in 1994 as part of the fuel conversion to LEU. However,3 HEU fresh fuel plates used in conjunction with an element with removable plates are in storage. The amount of U-235 in these plates is 4
l 1
less than 45 grams, with the uranium at a stated enrichment of about 93%. The total amount of contained U-235 in possession is less than 1 Kg. For that reason, the maximum amount of contained uranium-235 allowed in HEU form by license paragraph ll.B.(4) can be reduced. The proposed revised wording of this paragraph is:
" Pursuant to the Act and 10 CFR Part 70, " Domestic Licensing of Special Nuclear Material," to possess, but not to use, a maximum of 1 kilogram of contained uranium-235 at greater that 20-percent enrichment."
4.A.) 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?
Reply:
At U.Va. we make a distinction between " methods" and " standard operating procedures."
Currently, the definition of methods in TS 1.0 reads:
" Methods: Methods are written and approved instructions which provide guidance to the reactor staff for the completion of tasks specified in Standard Operating Procedures (SCP's). While SOP's, and changes thereto, are reviewed and approved by the Reactor Safety Committee (RSC), methods are written and reviewed by the reactor staff and j
approved by the reactor supervisor or administrator. Newly developed methods or changes to existing methods should be sent to the RSC as information items."
New SOP's applicable to reactor decommissioning will be written after the Reactor Safety Committee is eliminated. However, following removal off-site of all reactor fuel elements, such procedures no longer will involve reactor safety issues. Radiation safety issues could be involved, therefore new SOP's will be approved by the UVAR Decommissioning Committee, which will function as a subcommittee to the Radiation Safety Committee. The Reactor Director and the University's Radiation Safety Officer will be permanent members of the Decommissioning Committee, and thus also be members of the Radiation Safety Committee.
Therefore, in answer to the NRC question, yes, methods will be written after the Reactor Safety Committee is eliminated. Therefore, the definition for " methods" in TS 1.0 should be updated to reflect the above considerations as follows:
" Methods: Methods are written and approved instructions which provide guidance to the reactor staff, and/or subcontractors working for reactor management, for the completion of tasks specified in Standard Operating Procedures (SOPS). While SOP's, and changes thereto, are reviewed and approved by the UVAR Decommissioning Committee (RDC), methods are written and reviewed by the reactor staff and/or subcontractors working for reactor management, and approved by the reactor 5
~
supervisor or reactor director. Newly developed methods, or changes to existing methods, should be sent to the RDC as information items."
4.B.) Definition of Reactor Facility. Please consider adding a figure to the TSs that shows the reactor facility boundary.
Reply:
To complement the definition of " Reactor Facility," Figure 1.1 : Reactor Facility Boundary
- Area, page 10, is submitted for inclusion in UVAR TS 1.
5.A.) is there a TS requirement to have any radiation monitoring instruments operable during activities that have the potential to produce airborne radiation hazards or radiation fields, for example, fuel movement for shipping purposes (it appears 4
that TS 3.3 is not applicable with the core permanently unloaded)?
)
l Reply:
There is no TS requirements to have the radiation monitoring instruments formerly used in connection with the operation of the UVAR operable because the UVAR will not be operated again. Indeed, TS 3.3 is not applicable when the reactor is unloaded given its wording which states that "the reactor shall not be operated unless..." To reduce the number of requested TS amendments at this time, the licensee chose not to propose removal of TS such as TS 3.3 which clearly are only applicable to an operable / operating reactor. However, requests for removal of TS which are no longer applicable may be filed with NRC in the future, as time permits. (Please read reply to NRC question 5.C.)
5.B.) How do you propose to show compilance 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 4.4 and 4.7.
The objective of TS 3.4.1 is to ensure that exposure to the public resulting from the release of Ar-41 and other airbome effluents to the environment will be below the limits of 10CFR20 for unrestricted use. It is noted that Ar-41 is produced only during reactor i
operation, and that the reactor will not be operated again. Hence, Ar-41 is no longer a i
concem. Oher airbome effluents could, conceivably, be produced as a result of fuel element cladding damage. Such damage is possible during reactor operation or fuel movement. Again, the reactor has been permanently shutdown. During fuel shipments, compliance with 10CFR20 limits is achieved through use of the UVAR room air monitor.
As per the UVAR Spent Fuel Shipping Procedure, the air monitor in the reactor room is tumed on when fuel is shipped. Finally, the potential for generation and relcase of 6
l "other airbome effluents" associated with the spent fuel will cease once all LEU spent fuel elements have been shipped off-site. (See below the discussion about effluents associated with decommissioning activities in responce to questions 5.C and 9).
TS 4.4 applies to area radiation monitoring equipment operability and calibration, which is required only "during periods when the reactor is in operation"(see TS 4.4.1). Since the reactor will not be operated, non-compliance with this TS is impossible.
TS 4.7 sets specifications for calibration and channel check of the airborne effluent monitor "when the operations of the airborne effluent monitor is required (TS 3.4.1)."
(see TS 4.7.1) We have established in the discussion on TS 3.4.1 that the requirement disappears if the reactor is not operating.
5.C.) Are there future plans to have radiation monitoring equipment operable during decommissioning activities that have the potential to generate airborne activity?
Reply:
Yes, there are plans to have radiation monitoring equipment operable during those future decommissioning activities having a potential to generate airbome activity. Compliance with TS 3.4.1 during decommissioning activities will be assured by requirements contained in the UVAR Decommissioning Plan. The equipment for this purpose could be taken from the existing used equipment inventory at the reactor, or purchased as necessary for compliance with UVAR TS and federal regulations. It is premature to describe this equipment at this time.
6.
TS 3.6.G. 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.
Reply:
A word-processor search and replacement was done to find and convert all instances of "Co-60 rods" to "Co-60 pins"in the documents recently sent to NRC. Apparently, not all instances were found. While the terms are interchangeable, the use of " pin" over " rod" is preferred because the term " rods" is commonly associated with " reactor control rods."
The preferable term is now used in the proposed UVAR TS.
7.
TS 3.11. Please place wording about limitations on the TS in the specification because only 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 10-6 mhes/cm.
Reply:
7 I.
1 The NRC comment is appreciated. The prior proposed wording for TS 3.11 as it pertains to the pool water specifications is now revised to:
"Soecifications:
3.11.1. Conductivity If reactor fuel elements or cobalt-60 pins are present in the UVAR pool, the conductivity of the pool water shall be no higher that 5 x 10-8 mhos/cm.
3.11.2. Water oH If reactor fuel elements or cobalt-60 pins are present in the UVAR pool, the water pH of the pool water shall be between 5.0 and 7.5."
We are sending NRC in attachment an updated copy of proposed UVAR Technical Specifications which includes this all other changes brought about by the NRC questionnaire.
8.
TS 4.4. Please place wording about limitations on the TS in the specification because only the specification is governing.
Reply:
The wording in TS 4.4.1 is specific to periods when the reactor is in operation. Like TS 3.3 (please see the discussion above in answer to question 5) this TS does not apply to the permanently shutdown UVAR. The proposed revised wording for TS 4.4.2, in response to NRC's suggestion, now reads:
4.4.2. Semiannual Calibration "The calibration of the bridge radiation monitor referenced in Table 3.1 shall be performed semiannually until all fuel elements have been removed from the Reactor Facility and all Co-60 pins have been taken from the UVAR pool for dry shielded storage or appropriate disposal."
9.
TS 4.6 and 5.2. Are there future plans to maintain confinement during decommissioning activities that have the potential to generate airborne activity?
Reply:
It can be anticipated that certain decommissioning activities, most likely those associated with the physical disassembly of the reactor pool and associated components, could generate a potential for airbome activity. The UVAR 8
Decommissioning Plan shallinclude considerations about all such potentials as well as provide the detailed planning to confine eventual airborne activity possibly using temporary local confinement structures rather than the UVAR confinement itself.
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..."
Reply:
The licensee agrees to keep TS 4.8, and takes the opportunity to suggest minor editorial modifications that better explain its applicability, as well as its connection with TS 3.11.
Revised and proposed TS 4.8 now reads:
4.8.
Primary Coolant Conditions Acolicability: This specification applies to the surveillance of primary water quality whenever either fuel elements and/or Co-60 pins are in storage in the UVAR pool.
Obiective: The objective is to ensure that water quality does not deteriorate over extended periods of time should the reactor not be operated and either fuel elements and/or Co-60 pins be in storage in the UVAR pool.
Specification: If the conductivity and pH of the primary coolant water is required to be maintained as per TS 3.11, then they shat! be measured at least once every 2 weeks and verified to be as follows:
4 Conductivity: < 5 x 10 mhos/cm pH:
between 5.0 and 7.5 Basis: Section 3.11 of these specifications ensures that pool water quality is adequate during reactor operation. This section ensures that water quality is adequate whenever either fuel elements and/or Co-60 pins are in the UVAR pool and the reactor is not operated.
11.
TS 5.3. Please place wording about limitations on the TS In the specification because only the specification is governing.
Reply:
Again, the NRC observation is appropriate. Previously proposed TS 5.3.2.A. is hereby withdrawn. The revised wording for TS 5.3.2 is:
5.3.2. PJutonium Possession Limit 9
All plutonium generated or present in UVAR LEU reactor fuel, start-up sources, irradiation targets, flux foils and fission chambers may be possessed and used.
Following removal of all reactor fuel elements from the Reactor Facility, only the plutonium present in start-up sources, sources, irradiation targets, flux foils and fission chambers may be possessed and used.
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.
Reply:
Please see an enclosure justifying changes to TS 6."
13.
What is the difference between the Vice President for Research (current TS) and Vice President for Research and Public Service? Will there be any reduction in Level 1 oversight of the reactor facility?
Reply:
There is no difference between Vice President for Research and Vice President for Research and Public Service. The term *Public Service" was an addition to the original title recently made by the University.
The name change has not resulted in a reduction of Level 1 oversight over the Reactor Facility. Nevertheless, in response to this and other NRC questions regarding the organizational management structure for the UVAR Facility, the University is amending its earlier request with respect to TS Figure 6.1, ' Organizational Chart - University of Virginia Nuclear Reactor Facility." New Figures 6.1"A" and 6.1"B" show how a system of checks and balances on reactor decommissioning operations will be preserved. The Vice President for Research and Public Service would continue to exercisc Level 1 oversight over the Reactor Facility in the new Figures 6.1"A" and "B". Figure 6.1 "A" shows the desired organization while the Reactor Safety Committee exists, while Figure 6.1 *B" shows the orgarizational structure following the elimination of the Reactor Safety Committee. The Reactor Safety Committee will be officially terminated by the University soon after all reactor fuel elements have been shipped from the Reactor Facility.
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 of responsibility and communication. Also please show the position of the radiation safety committee on the organization chart (chart only shows the committee chair).
10 1
-q Reply:
Please see the enclosed UVA Reactor Facility Organizational Chart, Figures 6.1 "A" and "B".
15.A. 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 matters while TS 6.2.B states that the RDC advises the Vice President. Please clarify.
Reply:
Proposed wording for TS 6.0 has been rewritten and the Organizational Chart revised to clarify the reporting lines. The Chair of the RDC is also the Chair of the Radiation Safety Committee, and he repnrts to the Vice President and Provost, while the Director of the Office of Environmental Health and Safety reports to another University vice-president, the Vice President for Research and Public Service (Level 1).
15.B. It appears that the same person is the Chair of the RDC, the Chair of the Radiation Safety Committee, the Director of the Office of Environmental Health and Safety, and is a level two reactor manager. In addition, it appears that the radiation safety officer and radiatien 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 under this proposed organization?
Reply:
In response to this and other NRC questions related to the organizational structure for the Reactor Facility, a new management structure is being proposed as shown in Fig.
6.1 "A" and "B" in attachment. Here, the Radiation Safety Officer would report to the Director of the Office of Environmen;al Health and Safety while the Reactor Director (Level 2) reports directly to the Vice President for Research and Public Service (Level e
1). The Office of Environmental Health and Safety would also report to the VP for Research and Public Service. Thus, the health physicists would remain organizationally independent from reactor management.
16.
How will the radiation safety committee communicate with reactor management after the reactor safety committee is eliminated (see organization chart)?
Reply:
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The Reactor Director is a permanent member of both the Radiation Safety Committee and the Reactor Decommissioning Committee.
i 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.
Reply:
An error in redaction occurred. The statement:
"Within rnne months after being assigned to the position, the Reactor Supervisor shall obtain and maintain an NRC Senior Reactor Operator license if the fuel is still at the Facility, or an NRC Reactor Operator license if all reactor fuel has been shipped offsite."
should have stated:
"Within nine months of being assigned to the position, the Reactor Supervisor shall obtain and maintain a NRC Senior Reactor Operator license if reactor fuel elements are still at the Facility. A NRC Senior Reactor Operator, or Reactor Operator license, is not required once all reactor finel elements have been shipped offsite."
This has been corrected in the attached copy of the revised proposed UVAR TS.
18.
TS 6.1.4. Your proposed TS states that ANSl/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.
Reply:
ANSI /ANS 15.4-1998, Selection and Training of Personnel for Research Reactors," is an American National Standard that provides guldance on the techniques for selection, training and requalification of research reactor personnel. It is recognized by the standard itself that many of its " requirements" may not be applicable, or may be too restrictive for reactor groups having very small staffs or having little distinctions between responsibility functions.
The parts of the standard that we consider applicable (with regards to their value as guidance, and not necessarily regulatory requirements or commitments) at the present time, and into the decommissioning period, include:
a) The terms defined in Section 2. Definitions, to the extent that ihese are not superseded by definitions in the UVAR TS; b) the management line organizational concept of four levels of responsibility as 12
1 outlined in Section 3. Functional Levels and Assignments of Responsibility (and adopted in UVAR TS Fig 6.1);
c) the concept, but not necessarily the exact specifics, of requiring minimum qualifications for personnel hired into any of the four management levels as outlined in Section 4. Qualification; d) the general concept of a training and requalification program described in Section 5.
Initial Training and Certification and Section 6. Requalification and Recertification;
[Once all reactor fuel is gone, the need for reactor staff training and requalification j
with respect to reactor operations will no longer exist. The criteria for training of workers in decommissioning activities would then be covered in the UVAR Decommissioning Plan.]
e) the recommendations on medical requirements made in Section 7. Medical Certification and Monitoring of Certified Personnel;[This section would not be applicable once all fuel has left the site.]
f) the on-the-job, classroom lectures, and self-study training methods mentioned in Section 8. Training Methods.
A revision to an UVA Reactor Operator Requalification Pogram incorporating ideas j
taken from this standard was recently approved by the NRC. This standard serves a useful guidance purpose, and is not to be considered binding on the Reactor Facility.
Good ideas from this standard may be incorporated in a future decommissioning plan for the facility as may be considered applicable in the future.
19.A. 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 Committee is eliminated. Please explain the role of the Radiation Safety Committee after elimination of the Reactor Safety Committee.
Reply:
The U.Va. Radiation Safety Committee is charged with overall control of radioactive material use on the grounds of the University and on property owned or controlled by the University. The Reactor Safety Committee will be eliminated once the reactor fuel has been shipped and reactor safety issues no longer exist. The role of the Radiation Safety Committee will be to oversee the work of the Decommissioning Committee, which is one of its sub-committees. Radiation safety issues arising during the course of reactor decommissioning will thus be handled by the Decommissioning Committee, and if necessary by the Radiation Safety Committee. Thus, the Reactor Safety Committee will take over all residual responsibilities from the Reactor Safety Committee when that committee is eliminated.
Note: The Reactor Director and the Radiation Safety Officer will be permanent members of the UVA Reactor Safety Committee, the UVA Radiation Safety Committee and the UVAR Decommissioning Committee.
19.B. Please add TS requirements that pertain to the operation and responsibility of the 13
Radiation Safety Committee for the reactor facility.
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Reply Please see the wording in the attached proposed UVAR TS 6.2.
19.C. 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 aud!t responsibilities of the Reactor Safety Committee have been removed from your proposed TSs. Please justify.
Reply:
Following the permanent shutdown of the reactor, no further experiments involving the reactor and reactor safety have been performed, nor will any be performed. The closure of the reactor was followed by the termination of the Nuclear Engineering program at U.Va.. Thus, the number of NE faculty is decreasing and they will not be replaced. The proposed membership reduction is justified both by the decreased need for reactor sefety expertise on the Committee and the reduced number of individuals available to serve on the Reactor Safety Committee. The review and audit responsibilities of the ReSC have been retained (see TS6.2.B.3.).
20.A. TS 6.2.B. Your proposed TS lists experience that members of the RDC provide.
Decommissioning is not on that list. Please explain.
Reply:
Formerly proposed TS 6.2.B.1. has been renamed TS 6.2.C.1. and also revised to include decommissioning as an expertise to exist on the decommissioning committee.
New TS 6.2.C.1. now states:
6.2.C.1. Comoosition and Qualifications There shall be a Reactor Decommissioning Committee (ReDC) to plan the safe, legal and timely decommissioning of the Reactor Facility. Collectively, the decommissioning committee members shall represent a broad spectrum of expertise in the research-reactor and health-physics fields, with experience in reactor operations, radiological safety, research reactor decommissioning and university administration. Committee members may be drawn from within and outside the University of Virginia, including j
subcontracted companies. The Committee shall be compcsed of at least four members, and shall include the Radiction Safety Officer of the University and the Dir3ctor of the Reactor Facility.
The Reactor Decommissioning Committee shall be part (a subcommittee) of the Radiation Safety Committee, which reports to the Vice President and Provost. The Decommissioning Committee shall advise the Reactor Director (Level 2) on all matters 14 mJ T
l impacting the decommissioning of the Reactor Facility.
1 20.B. Reference is made to a decommissioning plan in the proposed TS when a plan has not been submitted.This type of requirement should be proposed as part of l
the TSs for the decommissioning plan amendment application.
Reply:
The proposed TS have been scanned for references to a decommissioning plan not yet submitted to NRC, and the references removed.
20.0. The proposed TSs and RDC charter give thepommittee 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 i
of licensed activities. These responsibilities are normally given to facility management and not the independent oversight committee. Please address.
Reply:
)
The proposed TSs and RDC Charter have been revised, and activities normally given to facility management have been retumed to facility management. The RDC will pick up the non-reactor safety respon3ibilities of the Reactor Safety Committee when the ReSC is terminated.
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20.D. The review and audit responsibilities discussed in the RDC charter are different l
than those listed in the proposed TSs. Please explain.
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Reply:
l The review and audit responsibilities have been made the same in the newest proposed version of RDC Charter and UVAR TS.
21.A. 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.
Reply:
A revised organizational structure and revised RDC Charter are now proposed in which substantive changes to procedures will be approved by the Reactor Decommissioning Committee, a sub-committee of the Radiation Safety Committee, after the Reactor Safety Committee is eliminated. Non-substantive changes made by the Reactor Director will be reviewed by the Reactor Decommissioning Committee.
21.B. Who will review and approve new procedures (also see the definition for l
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Standard Operating Procedures)?
Reply:
Under the revised organizational structure and revised RDC Charter now proposed, the RDC would approve new procedures following elimination of the Reactor Safety Committee. See also proposed UVAR TS 6.2.C.3.(2).
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?
Reply:
Yes, please see UVAR TS 6.5.1.(10) Records of meetings and audit reports of 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?
Reply:
The current TSs 6.6.2 (1) and (2) state:
- A reportable occurrence is any of the following conditions:
(1) Safety system setting less conservative than specified in Section 2.2 of these specifications.
(2) Operating in violation of a Limiting Condition of Operation (LCO) estaiAshed in these specifications, unless prompt remedial action is taken."
Section 2.2 of the UVAR TS contains the limiting safety system settings, in other words, the set points for the safety channels monitoring reactor thermal power, coolant flow rate, reactor coolant inlet temperature, and the height of water above the core. Section 3.3 of the UVAR TS contain the limiting conditions for operation, in other words, reactivity conditions of the reactor and the reactivity worth of control rods and experiments that ensure the reactor can be shut down at all times without a safety limit being exceeded. The UVAR ccre has been disassembled, the regular fuel elements placed in undenvater fuel storage, and its four control rod elements shipped offsite. By administrative order the UVAR the core will not be rebuilt. Thus, TS 6.6.2.(1) and (2) cannot be violated with the UVAR in a permanently shut down state and do not need to be carried over as reportable events.
24.TS 6.7.2. Please propose a reporting requirement for the possession-only period including information to be included in the report.
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Reply:
It is proposed that TS 6.7.2 read as follows:
6.7.2. Routine Reoorts A routine report will be made by March 31 of each year on decommissioning activities completed during the previous calendar year. The report should be sent to the U.S.
l Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, l
. providing the following information:
(1) Reactor Facility utilization, (2) Description of university staff assigned to decommissioning: numbers, background and responsibilities, (3) TS compliance and reportable events, (4) Results of NRC inspections and licensing actions.
(5) Summary report on RDC meetings and audit findings, (6) Health Physics Program l
(7) Annual waste content and volume shipped, (8) Summary of the nature and amount of radioactive solid, liquid and airborne effluents i
released or discharged to the environs beyond the effective control of the licensee, as measured or calculated at or prior to the point of such release or discharge, (9) Results of environmental surveys and sampling outside the Reactor Facility, (10) Reactor Facility personnel and visitor radiation exposure summary report, including the dates and times of significant exposures (greater than 500 mrem for adults and 50 mrem for persons under 18 years of age),
l (11) Summary of radiation and contamination surveys performed within the Reactor Facility.
(12) Status of decommissioning funding and expenditures, (13) Description of contractor companies operating on-site, (14) Summary of contracted tasks and timelines, (15) Significant Changes to the Reactor Facility, (16) Summary of large equipment transfers, (17) New and modified SOPS having radiation safety significance, (18) Status of emergency preparedness, (19) Figures on industrial accidents or incidents.
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1 Justifications for Proposed Arnendrnents to UVAR TS 6 Introduction UVAR Technical Specification (UVAR TS) 6 deals with Administrative Controls over the University of Virginia Reactor (UVAR). These controls must be revisited in light of the permanent shutdown of the UVAR and the termination of the University's nuclear engineering program. The operational needs of the reactor have changed, with the focus having shifted from reactor operations to preparations for decommissioning.
The University is dealing with the situation in a prudent manner. As can be expected, the reactor staff has been reduced greatly. And, the nuclear engineering faculty is either retiring or moving on to employrnent at other universities. However, key people have been retained at the University to deal with the evolving situation. The Reactor Director's position will continue to exist at least for the next 2.5 years, and the services of the Reactor Supervisor have been reasonably assureu oy the University for the duration of the UVAR decommissioning period. [A UVAR staff member with a long employment history at the reactor continues to be a University employee, albeit in another department.
Another former reactor supervisor is retired and living in the Charlottesville area.]
Reactor line management now reports to the Provost's Office. Therefore, the Reactor Facility is being given special attention to assure that the path to license termination is smooth and direct.
To assist the University in the upcoming decommissioning, a request for proposals has been issued, with good response from finns in the research reactor decommissioning field.
The end of reactor operations and the eventual de-fueling of the facility will place the facility in a status in which reactor safety issues will cease to exist. Thus, it is envisioned that the present-day Reactor Safety Committee (ReSC) will be terminated shortly afler this status is reached. Still, there will be radiation safety and decommissioning issues to be addressed. Therefore, a Reactor Decommissioning Committee (RDC) is being set up as a subcommittee to the University's Radiation Safety Committee to take over the residual responsibilities and authority of the ReSC, and to assume some new responsibilities and duties. For this reason, we are requesting amendments to UVAR TS 6, in which we describe the evolving roles of the University's Radiation Safety Committee (RaSC), the Reactor Decommissioning Committee and the Reactor Safety Committee. In connection with these items, a newly proposed Figure 6.1 A and B is attached.
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Basisfor the Proposed Amendments I'
TS 6.1. Organization As a result of a prior amendment approved by the NRC, the Reactor Director (Level 2) reports to the Vice President for Research and Public Service (Level 1). These specifications clarify that the Chair of the RDC is to advise the Reactor Director on decommissioning matters pertaining to the UVAR (please also see proposed TS Figures
)
6.1 A and 6.1 B). The responsibilities of the Reactor Director and the Reactor Supervisor l
have been updated to take into account the present and expected future status of the UVAR. Once the Reactor Facility has been totally de-fueled, the TS recognizes that reactor staff need no longer have or maintain active NRC operator licenses. A SRO license is still required for legal fuel movement during fuel shipping operations.
Selection and training ofline personnel shall take into account the status and needs of facility, subject to NRC requirements.
TS 6.2. Radiation Safety. Reactor Safety and Reactor Decommissioning Committers i
Three University committees are now described in UVAR TS, while formerly only the ReSC was mentioned in detail. Both the ReSC and the RDC are part of the Radiation Safety Committee,(RaSC) and function as subcommittees. The RaSC is described first (in TS 6.2.A.), using language that is in accordance with provisions contained in its charter. The ReSC is described next (TS 6.2.B.). The language currently in use for the ReSC in the UVAR TS has been updated to reflect the desired new organizational structure pictured in Figure 6.1 A and B, and to allow the tennination of the ReSC upon the complete de-fueling of the Reactor Facility. Residual duties from the ReSC will be l
taken on by the RDC, and this is described in TS 6.2.C. The language describing the RDC is consistent with its charter and with an organizational structure wherein checks and balances between line management and health physics are preserved. The functions of the RDC are given in TS 6.2.C.3.. It is clear that the RDC takes over residual responsibilities from the ReSC when it is terminated.
To assure efficient communications between line management and the committees, both the Radiation Safety Officer and the Reactor Director will be permanent members of all three committees.
TS 6.3.2. Changes to SOPS The proposed change will pennit the RDC to take over the ReSC responsibility of reviewing and approving substantive changes to procedures when the ReSC is tenninated.
t
III TS 6.5 Plant Operating Records TS 6.5.1.(10) provides assurance that records of meeting and audit reporte of the Reactor Decommissioning Committee will be kept.
TS 6.6. Reauired Actions Safety limits cannot be exceed any longer since the UVAR has been pennanently shut down. Thus, safety limit violations are no longer possible and no actions need to be listed in TS in connection with such violations. Thus, present TS 6.6.1. is being ddeted and replaced by present TS 6.6.2., which is itself being renumbered and its language updated. For example, non-conservative safety system settings, violations of Limiting Conditions of Operation, safety system malfunctions, uncontrolled or unanticipated increases in reactivity are also no longer possible given the UVAR shutdown, and so need not be addressed any longer in this TS. Those items in present TS still applicable to the shutdown and decommissioning period have been retained. Some editing oflanguage and numeration changes have also been done. The result is to make very clear in the TS what events and situations are reportable to NRC.
TS 6.7 Reoorting Requirements In TS 6.7.1.(4)(C), the new organizational structure is taken into account, as far as the need to report to NRC changes in line management personnel.
TS 6.7.2. describes the content of routine annual reports to the NRC. Content requirements no longer applicable to a permanently shutdown reactor have been taken out, while new topics ofinterest during the decommissioning phase have been added.
Should the NRC wish to add topics ofits interest not yet included here, we would be happy to add these.
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