ML20205N446

Safety Evaluation Supporting Amend 10 to License R-115

ML20205N446
Person / Time
Site:	University of Illinois
Issue date:	04/12/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20205N439	List: ML20205N434 ML20205N440 ML20205N446
References
NUDOCS 9904160279
Download: ML20205N446 (12)

Text

--

v ,

p-p@%q)t UNITED STATES 5 g NUCLEAR REGULATORY COMMISSION

$ $ WASHINGTON, D.C. 20555-4001

%...../

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.10 TO FACILITY LICENSE NO. R-115 THE UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN DOCKET NO. 50-151

1.0 INTRODUCTION

By' letter dated October 5,1998, as supplemented on January 12, and February 3 and 11, 1999, the University of Illinois at Urbana-Champaign (UlUC or licensee) submitted a requesi 'or an amendment to Facility License No. R-115 for the UlUC Advanced TRIGA Reactor (TRIGA) and Appendix A, " Technical Specifications for the Illinois Advanced TRIGA Reactor." The requested changes would remove authorization from the license to operate the reactor, would authorize a possession-only status for the reactor, and would change the technical specifications (TSs) to remove or modify operational TSs that are not needed for possession-only status. The licensee also requested changes in the administrative controls for the reactor facility.

2.0 EVALUATION 2.1 Introduction UlUC has requested that the license for the TRIGA be amended to remove authorization to operate the facility because the facility has been permanently shut down in preparation for decommissioning. In addition, the licensee has requested the amendment of certain TSs associated with the operable reactor to remove requirements not necessary for a reactor in possession-only status.

The reactor in a possession-only configuration will be incapable of achieving criticality under all environmental conditions. All fuel except the fuel-followed control rods and instrumented fuel elements have been removed from the cere and placed into approved fuel storage facilities.

The fuel-followed control rods and instrumented fuel elements represent a very small fraction of a critical mass. This remaining fuel on the reactoi grid piate cannot become critical under any circumstances.

Fuel will be stored according to existing TSs on reactivity and cooling. The physical secunty plan and the emergency plan will continue in place without modification.

The licensee will place the reactor into a SAFSTOR condition in which the reactor will be in a L period of storage followed by decommissioning at some point in the future. The licensee will l place the reactor in SAFSTOR because the soonest the Department of Energy can accept fuel from the TRIGA is 2009.

9904160279 990412 PDR ADOCK 05000151 p PDR

U TSs relevant to the safety of the shutdown reactor with fuel in storage will continue in effect, !

including TSs concerning peol water quality, the ventilation system, radiation monitoring, and j fuel storage. 1 The licensee has proposed changes to the license and TSs to remove wording not applicable to a possession-only status. The TSs proposed to be removed from the license include those )

requiring periodic inspection of the transient rod drive cylinder and the associated air supply system, periodic measurements to verify control rod scram times and control rod worth, functional checks of the transient rod system, a periodic calibration of reactor power and temperature measuring channels, and operability and testing of the emergency spray cooling system. Administrative TSs related to reactor operation are proposed to be modifiea is reflect the permanent shutdown status of the facility. The licensee has proposed changes to the definition of " reactor secure" to make this definition consistent with the proposed possession-only status.

, 2.2 Changes to License Conditions The licensee has proposed changes to paragraphs 2.A,2.B. 2.C,3.A, and 3.B of the license to remove reference to operation of the facility, use of tne reactor, and the use of byproduct and special nuclear material.

Paragraph 2.A currently reaos:

2.A. Pursuant to Section 104c of the Act and Title 10, Chapter I, CFR, Part 50,

" Licensing of Production and Utilization Facilities", to possess, use and operate the reactdr as a utilization facility in accordance with the procedures and limitations described in the application and in this license; The licensee has proposed changing this paragraph to read:

2.A. Pursuant to Section 104c of the Act and Title 10, Chapter I, CFR, Part 50, 1

" Licensing of Production and Utilization Facilities", to possess, but not to operate the reactor in accordance with the procedures and limitations described in the application and in this license; Paragraph 2.B. currently reads:

2.B. Pursuant to the Act and 10 CFR Part 70, " Domestic Licensing of Sg:ial Nuclear Material," to receive, possess and use up to 9.6 kilograms of contained uranium-235, of which 7.0 kilograms of contained uranium-235 is for use in connection with the operation of the reactor and up to 2.6 kilograms of contained uranium-235 is for use i , connection with operation of a subcritical assembly in the Bulk Shielding Facility of the reactor; up to 20 grams of the contained uranium-235 is of any enrichment in the form of fission chambers and the balance is contained uranium-235 enriched to less than 20 percent in the isotope uranium-235 in tne form of reactor fuel; up to 1.0E-5 grams of plutonium in the form of reactor fuel transferred from Facility Operating License No. R-117; and to possess, but not separate, such special nuclear material as may oe produced by the operation of the facility; and

p u

?.

\

l The licensee has proposed changing this paragraph to read:

2.B. Pursuant to the Act and 10 CFR Part 70, " Domestic Licensing of Special Nuclear Material," to receive and possess up to 9.6 kilograms of contained uranium-235,

of which 7.0 kilograms of contained uranium-235 was for use in connection with ]

the operation of the reactor and up to 2.6 kilograms of contained uranium-235 was for use in connection with operation of a subcritical assembly in the Bulk Shielding Facility of the reactor; up to 20 grams of the contained uranium-235 is of any enrichment in the form of fission chambers and the balance is contained uranium-235 enriched to less than 20 percent in the isotope uranium-235 in the form of reactor fuel; up to 1.0E-5 grams of p'utonium in the form of reactor fuel l

transferred from Facility Operating License No. R-117; and to possess, but not to separate, such special nuclear material as may have been produced by the operation of the facility; and Paragraph 2.C currently reads:

2.C. Pursuant to the Act and 10 CFR Part 30, " Rules of General Applicability to Domestic Licensing of Byproduct Material," to receive, possess and use up to 0.2 curie of byproduct materialin the form of components for the operation of a suberitical assembly in the Bulk Shielding Facility of the reactor transferred from Facility Operating License No. R-117; to receive, possess, use, but not to separate up to 0.5 curie of byproduct material in the form of reactor fuel for the operation of a suberitical assembly in the Bulk Shielding Facility of the reactor transferred from Facility Operating License No. R-117; and to possess, use, but not separate except for byproduct material produced in experiments, any amount ,

of byproduct material as may be produced by the operation of the facility. l l

The licensee has proposed changing this paragraph to read: l I

2.C. Pursuant to the Act and 10 CFR Part 30," Rules of General Applicability to i Domestic Licensing of Byproduct Material," to receive and possess up to 0.2 I curie of byproduct materialin the form of components of a subcritical assembly in the Bulk Shielding Facility of the reactor transferred from Facility Operating License No. R-117; to receive and possess, but not to separate up to 0.5 curie of byproduct material in the form of reactor fuel of a subcritical assembly in the Bulk 1 Shielding Facility of the reactor transferred from Facility Operating License No.

R-117; and to possess, but not separate except for byproduct material produced in experimen't, any amount of byproduct material as may have been produced

by the opera

an of the facility.

Paragraph 3.A cunently reads:

3.A. Maximum Power Level The licensee may operate the reactor at power levels not to exceed 1500 kilowatts (thermal) and, in the pulse mode, with reactivity insertions not to exceed 4.60$.

U O

The licensee has proposed changing this paragraph to read:

3.A. Maximum Power Level l

The licensee shall not operate the reactor. I 1

1 Paragraph 3.B currently reads:

3.B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 9, are hereby incorporated :n the license. The licensee shall operate the facility in accordance with the Technical Specifications.

The licensee has proposed changing this paragraph to read: )

3.B. Technical Soecifications The Technical Specifications contained in Appendix A, as revised through Amendment No.10, are hereby incorporated in the license. The licensee shall maintain the facility in accordance with the Technical Specifications.

The licensee has proposed removing authority to operate the reactor from paragraph 2.A of the facility license. License paragraph 3.A, which places limits on the maximum power level of the reacto; and maximum reactivity addition in pulse mode, will be changed to state that the licerisee shall not operate the reactor. License paragraph 3.B is changed to have the licensee maintaining the facility in accordance with the TSs instead of operating the facility in accordance with the TSs. These changes are commensurate with the change to possession-only status and put in place the primary objective of a change to possession-only status, which

! is permanent removal of the authority to operate the reactor. The licensee has proposed changes to license paragraphs 2.B and 2.C to remove authority to use byproduct material and special nuclear material possessed under the license. The licensee may still receive and possess these materials.

The staff finds these changes to license conditions acceptable because they remove reference to reactor operation, use of the reactor, and the use of byproduct ani special nuclear material l and are consistent with the possession-only status requested by the Jcensee.

l 2.3 Change' to Technical Gpecifications l

The licensee has proposed changes to the table of contents of the TSs that reflect the other changes to the TSs. These changes are acceptable to the staff because they are administrative in nature.

The licensee has requested that the requirements of several TSs be deleted from the license to reflect possession-only status. One TS proposed for deletion is TS 4.2.a, which requires the worth of the control rods to be determined semiannually. This TS is no longer needed because fuel elements (with the exception of the fuel-followed control rods and instrumented fuel elements) wi!I be removed from the reactor core into storage, resulting in a core configuration in which the control rods are no longer needed to maintain the reactor subcritical.

u l

l 5

l TS 4.2.b concerning control rod drop time has been proposed for deletion. This TS is no longer needed because the reactor core will be unloaded to much less than a critical mass. Because the reactor will not be operated again, the verification of the control rod drop time is meaningless.

The licensee has proposed deleting TS 4.2.d that requires a functional performance check of the pulse rods on each day that the pulse mode of operation is planned. Because the reactor will not be operated again, this TS is not needed.

TS 4.2.e, which requires the pulse rod drive cylinders and associated air supply system to be inspected, cleaned, and lubricated as necessary at semiannual intervals, has been proposed for deletica. This TS is no longer needed because t.'e reactor will never again be pulsed, the reactor core will be unloadad to much less than a critical mass, and the control rods are no longer needed to maintain the reactor subcritical.

The licensee has proposed the deletion of TS 4.3.d, which requires semiannual calibrations of the power monitor channels, and TS 4.3.e. which requires semiannual calibrations of temperature measuring channels. These TSs are no longer needed because the reactor will not be operated again.

TS 5.4, which requires the licensee to have an operable emergency cooling system, and TS 4.4, which requires weekly verification of operation of the system, have been proposed for deletion. The system was installed in anticipation of reactor operation at 3 MW(t) and was not needed for 1.5 MW(t) operation. The reactor has been shut down since August 9,1998, and decay her'. levels do not require any emergency cooling upon loss of coolant.

Meeting these TS proposed for deletion in a possession-only status is either impossible because they require operation of the reactor or meaningless because they refer to equipment or measurements not required if the reactor is not operated. The staff finds these TS deletions to be acceptable because they delete TSs that are not needed for the possession-only status of the reactor facility.

I The licensee has proposed an addition to the TSs 1.2, the definition of " Reactor Secured." The definition currently reads: ,

Reactor Secured - The reactor is secured when all of the following conditions are satisfied:

a. Sufficient control rods are inserted so as to assure that it is subcritical by at leaet

$1.00 of reactivity; I

b. Power to the control rod magnets and actuating solenoids is off, and the key removed; and

c. No work is in progress involving fuel or in-core experiments or maintenance of the core structure, control rods, or control rod drive mechanisms.

I

r- u o

l l  ;

l The licensee has proposed changing the definition to read:

i Reactor Secured - The reactor is secured when:

a. It contains insufficient fissile material or moderator present in the reactor, l adjacent experiments, or control rods, to attain criticality under optimum available conditions of moderation, and reflection, or

b. All of the following conditions are met:

1) Sufficient control rods are inserted so as to assure that it is subcritical by at least $1.00 of reactivity;

2) Power to the control rod magnets and actuating solenoids is off, and the key removed; and

3) No work is in progress involving fuel or in-core experiments or l maintenance of the core structure, control rods, or control rod drive i mechanisms.

This definition is similar to the definition of " reactor secured" suggested by ANSl/ANS 15.1, l "The Development of Technical Specifications for Research Reactors," which is supported by l the NRC staff. The addition to the definition allows the licensee to perform work on the l defueled reactor without having to place the reactor into operation, which would require meeting l a number of TS requirements thet cannot be met with the reactor permanently shutdown. This

! definition is commensurate with the change to possession-only status and is, therefore.

acceptable to the staff.

The licensee has proposed changes to TS 3.7, " Ventilation System." This TS states that the reactor shall not be operated unless the ventilation system is in operation. The TS allows the system to be out of operation for periods not to exceed 2 days to permit repairs. The proposed change to the definition of " reactor secured" could allow fuel to be moved without the ventilation system being in operation. To account for this situation, the licensee has proposed adding a requirement that fuel shall not be moved unless the ventilation system is in operation.

l - Also, during periods of repair to the ventilation system, the licensee has proposed that fuel shall not be moved. Thus, with these proposed changes, the proposed change to the definition of

" reactor secured" does not change the requirement for operation of the ventilation system when l fuelis moved. Because a controlled ventilation pathway will exist when fuel movement occurs, l the change in TS 3.7 is acceptable to the staff.

The licensee has proposed changes to TS 3.9, "Suberitical Experiments Using the Bulk Shielding Facility," and the associated TS 4.7 concerning surveillance. The title of the two TSs is changed to "Suberitical Experiments and Fuel Storage Using the Bulk Shielding Facility." The proposed changes to these TSs would allow fuel to be stored in the Bulk Shielding Facility, which is a separate pool located next to the reactor pool within the biological shield of the reactor. The new specifications are also applicable to fuel stored in the TRIGA pool. Two new specifications are added to TS 3.9 that read as follows:

t-

eu 1

f. During periods when the Bulk Shielding Facility (BSF) or TRIGA pool is used for fuel storage a continuous air monitor shall be in operation in the reactor bay and an area radiation monitor shall be in operation above the pool. The continuous )

i air monitor and/or area radiation monitor (s) may be out of service for up to ten days provided that no fuel handling takes place. ,

i

g. During periods when the Bulk Shielding Facility (BSF) or TRIGA pool is used for fuel storage the pool level will oe maintained at a level at least six (6) feet above the top of the fuel elements. ,

The licensee has ans. proposed changes to the Applicability, Objective, and Basis sections of this TS commensurate ith the changes made to the specifications section of the TS. The requirements in TS 5.3 concerning criticality and cooling of fuel in storage continue unchanged.

The radiation monitors are only required by the current TSs when the reactor is in operation.

The proposed TS is more conservative than the existing TS for reactor operation. Permitting a radiation monitor to be out of service for up to 10 days allows a reasonable period for repair.

During this period, fuel movement will not be Sowed. This restriction is similar to the current TSs because if the reactor is not in operation, radiation monitors are not required. Because the proposed TS adds radiation monitoring requirements to the TSs when fuel is in storage, it is acceptable to the staff.

The licensee has also propcsed a requirement in TS 3.9.g that the storage pool level be maintained at least 6 feet above the top of the fuel elements. The purpose cf this TS is to control radiation levels above the fuel pools. There is currently no requirement for minimum water above fuel in storage. The licensee must still meet the applicable regulations governing radiation exposure in 10 CFR Part 20. Because this TS adds new water level requirements to the TSs, it is acceptable to the staff.

The licensee has proposed adding a new section, TS 4.7.f, that reads as follows:

f. The Bulk Shielding Facility poollevel and TRIGA poollevel shall be checked on a weekly (not to exceed ten days) basis when used for fuel storage.

This new surveillance verifies that TS 3.9.g is being met. Because the reactor is permanently shut down, this surveillance interval and TS is acceptable to the staff. l A change is proposed to the applicability section of TS 3.11 " Primary Coolant Quality," and the applicablity and specification sections of TS 4.8, " Primary Coolant Quality." The TSs currently l refer to water in contact with the cladding of fuel in the TRIGA core. The licensee has proposed I changing this reference to read " reactor pool" to reflect the fact that fuel may be stored in the reactor pool. The change is acceptable to the staff because it clarifies the TSs.

The licensee has proposed a change to TS 4.1 concerning fuel surveillance to eliminate a requirement to inspect fuel elements in the B and C hexagonals annually. The requirement existed because elements operated in these core locations were subjected to the most severe stresses during reactor operation.

l

V l

l 1

The licensee has also proposed changing TS 4.7.d, which reads as follows:

d) Approximately 20% of the fuel elements in the suberitical assembly shall be l

visually inspected annually for any indication of deterioration or distortion (interval not to exceed 15 months) such that all of the elements in the subcritical assembly are inspected over a five year period (interval not to exceed five and one-half years). If any indication of deterioration or distortion is noted the element shall be removed from service.

The licensee has proposed that fHs TS be changed to read:

d) Approximately 10% of the fuel elements in the Bulk Shielding Facility or TRIGA pool, shall be visually inspected annually for any indication of deterioration or distortion (interval not to exceed fifteen months) such that all of the elements are inspected over a ten year period (interval not to exceed ten and one-half years). l if any indication of deterioration or distortion is noted the element shall be i removed to other storage and all elements shall be inspected within one week.

Other storage shall be any other approved fuel storage area at the Nuclear Reactor Laboratory.

The licensee has based the request to extend the fuel inspection interval for the total fuel l inventory from 5 to 10 yeers on the basis of 38 years of experience with Nel inspections in which no evidence of deterioration was apparent. The NRC staff notes thd with the reactor permanently shutdown, the fuel is no longer subject to the stresses of operation, which can accelerate distortion or deterioration. If an element exhibiting distortion or deterioration is found during fuel inspections, moving the fuel to other storage would allow the damaged elements to be isolated. During the annual inspection, if any element is found with deterioration or distortion, all elements in the Bulk Shielding Facility and the TRIGA pool will be inspected within i 1 week to ensure that the damaged fuelis an isolated event and not an indication of a widespread problem. The 10-year interval for fuelinspection is acceptable to the staff on the basis of the history of 38 years of successful fuelinspection at the facility, the fact that the fuel is no longer subject to the stresses of operation, and the fact that if deterioration or distortion is found, the fuel element will be moved to other storage and all other elements will be inspected.

An exception to the 10-year inspection interval is that the fuel-followed control rods will continue to be inspected biennially as required by TS 4.2.c. The licensee has proposed a change to the bases of TS 4.2 to change the basis of the inspection from determining if the control rods are capable of performing properly to an adequate inspection interval on the basis of prior experience that indicated a lack of fuel cladding deterioration over time. The change to the bases of TS 4.2 is acceptable because it clarifies the TS as it pertains to the change to possession-only status.

The licensee has proposed a change to the applicability section of TS 5.1, " Reactor Fuel" The change would specify that the TS is applicable for a reactor core for a critical mass. This  !

measure would allow the fuel-followed control rods and the instrumented fuel elements to remain on the reactor grid plate without violating TS 5.1.c, which requires that fuel elements be placed in a closely packed array. The purpose of the packed array is to have predictable reactor performance during reactor operation. Because the reactor is permanently shut down, this change is acceptable to the staff.

U e

l

.g.

I A change to TS 4.5, " Radiation Monitoring Equipment," has been proposed by the licensee.

l The TS currently requires alarm setpoints for the radiation monitoring instrumentation to be verified weekly when the reactor is in operation. The licensee has proposed changing this verification to monthly, not to exceed 6 weeks. This change would require verification even with the reactor shutdown. The licensee states that experience with the equipment has shown little drift in equipment setpoints during the last 10 years. Because of the licensee's experience with the stability of equipment setpoints and the fact that the potential for a release of radioactive material is greatly reduced with the permanent shutdown of the reactor, this change is acceptable to the staff.

The licensee has proposed removing reference to the Operations Supervisor, operations staff, and reactor operation in TS 6.0, " Administrative Controls," to reflect the shutdown status of the reactor. TS responsibilities of the Operations Supervisor (TSs 6.4,6.5.a and c, and 6.7.a) will be performed by the Reactor Administrator, who is at a higher level in the management structure and is qualified to perform these duties. For the facility calllist, the Campus Radiation Safety Officer replaces the Operations Supervisor. For review and approval of irradiation of materials (TS 6.5.d), because the reactor will not be run again and, thus, the irradiation of materials is impossible, removal of reference to the Operations Supervisor does not affect safety. These changes are acceptable to the staff because they are commensurate with the change in status to possession-only and because the Reactor Administrator and the Campus Radiation Safety Officer are qualified to perform duties that were the responsibility of the Operations Supervisor.

TS 6.1.2, " Staffing," currently reads, in part:

6.1.2 Staffino

a. The minimum staffing when the reactor is not shutdown shall be:

1

1. A licensed reactor operator shall be in the control room.

2. A second designated person shall be present inside the reactor building able to shutdown the reactor in an emergency.

Unexpected absence for as long as two hours to accommodate a personal emergency may be acceptable provided immediate action is taken to obtain a replacement.

3. A Senior Reactor Operator shall be readily available on call as defined in the Nuclear Reactor Laboratory Rules and Regulations.

I'

b. A list of reactor facility personnel by name and telephone number shall be readily available in the control room for use by the operator. The list shall include:

]

1. Operations Supervisor  !

c. Events requiring the presence at the facility of a Senior Reactor Operator:

l 2. All fuel or control rod relocations within the reactor core regim l

l

0 The licensee has proposed changing these portions of this TS to read:

6.1.2 Staffina

a. The minimum staffing at the Nuclear Reactor Leboratory shall be:

1. Reactor Admiristrator. This individual shall meet the requirements of ANSI /ANS-15.4-1988 "American National Standard for the Selection and Training of Personnel for Research Reactors" for a Level Two individual.

2. Reactor Health Physicist. This individual shall meet the requirements of ANSI /ANS-15.4-1988 "American National Standard for the Selection and Training of Personnel for Research Reactors" for a Level Three individual in addition to training in health physics.

b. A list of reactor personnel by name and telephone number shall be readily available to the UlUC Division of Public Safety dispatcher. One of these individuals shall be reachable and able to respond to the facility within approximately one hour. The list shallinclude:

1. Campus Radiation Safety Officer

c. Events requiring the presence at the facility of a Senior Reactor Operator:

2. All fuel or control rod relocations.

l The licensee has eliminated minimum staffing on the site when the reactor is not shut down because the reactor will not operate again. However, there is a requirement for a Senior Reactor Operator to be present when fuel or controls rods are relocated. The licensee is adding a requirement to the TSs that the Reactor Administrator and the Reactor Health Physicist meet the requirements of ANSI /ANS-15.4-1988, "American National Standard for the Selection and Training of Personnel for Research Reactors." This standard is generally supported by the NRC staff. Licensee staff members who meet the requirements of the standard for their positions have qualifications that are acceptable to the NRC staff. Therefore. l these TSs changes are acceptable to the staff.

The licensee maintains a list of reactor personnel who serve as contacts. During reactor i operation, this list was for the use of the reactor operator, but with the permanent shutdown of the reactor, the list is for the UlUC Division of Public Safety to use to contact reactor personnel.

At least one individual on the list is on call and shall be reachable and able to respond to the facihty within approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (the licensee states that the upper limit on this response time is 1.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />). The Campus Radiation Safety Officer, who is familiar with the facility, replaces the Operations Supervisor on the calllist. The staff finds this level of response acceptable, given the permanent shutdown condition of the facility. The TSs contain a listing of events that require the presence of a Senior Reactor Operator at the facility. The licensee has expanded the TSs requirements on the presence of a Senior Reactor Operator at the facility by requiring a Senior Reactor Operator for all fuel or control rod relocations. The current TSs l

O require the presence of a Senior Reactor Operator only for fuel or control rod relocation within the reactor core region. Movement of fuel out of the reactor core region into storage facilities and into shipping containers is common when a facility permanently shuts down. Because the proposed change to the TSs expands the requirements for the presence of a Senior Reactor Oprator, this new wording is commensurate with the change in facihty status to possession-only and is acceptable to the staff.

The licensee has proposed changes to TS 6.2.1, " Charter and Rules," of the Nuclear Reactor Committee. One change would appoint the Reactor Health Physicist as a voting member of the committee. The Reactor Health Physicist is currently a nonvoting member. The licensee believes that this change is warranted because decommissioning work is radiologically oriented.

The current TS requirement (TS 6.2.1.c) that the members of the reactor operating staff not constitute a voting majority of a quorum of the Reactor Committee would be changed to members of the reactor staff to reflect the permanent end of reactor operation. These channes are acceptable to the staff because they are commensurate with the change in status of the facility to possession-only and because reactor staff members would not constitute a majority  ;

on the committee.

A requirement would be deleted in TS 6.2.1.a that the other members of the committee come from the faculty of Nuclear Engineering. This change would allow a wider pool of potential members of the committee. The TS requirement for a balanced knowledge of reactor safety and regulation from committee members would remain. Because this change allows greater flexibility in selecting members of the committee, it is acceptable to the staff.

TS 6.2.1.d currently requires the committee to meet at least quarterly. The licensee has proposed changing this requirement to semiannually, with the interval not to exceed 9 months.

With the permanent shutdown of the facility and the placement of the facility into SAFSTOR status, committee activity will be reduced. This measure is acceptable to the staff because of the permanent shutdown of the facility.

A change has been proposed to TS 6.2.3, " Audit Function," to remove reference to operating documents and observation of operations. Because this change is commensurate with the change in the facility status to possession-only, it is acceptable to the staff.

The licensee has proposed a change to TS 6.8.a, " Reporting Requirements," to correct grammar. The staff has determined that this change is administrative in nature and is, j therefore, acceptable.

J i

The licensee has proposed a change to TS 6.8.b.3 that requires certain changes to the facility l organization to be reported to NRC. Changes to the Operations Supervisor position would be  :

replaced with changes to the Reactor Health Physicist position to reflect the removal of the Operations Supervisor position from the reactor organization. This change reflects the permanent shutdown of the facihty and is acceptable to the staff.

l Several minor typographical errors were noted by the staff on the proposed TSs submitted by I the licensee. On March 1,1999, the NRC project manager discussed these errors with the Reactor Adminittrator, who agreed to their correction.

[ ., o o

4 The staff has determined that removal of authorization to operate the reactor, the authorization to possess but not operate the reactor, and amendment of the license and TSs to reflect the status of possession but not operation of the facility is acceptable because the reactor will be placed in a permanent shutdown subcritical state and the fuel will be stored in accord with the TSs, procedures, and the physical security plan.

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves changes in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, changes in inspection and surveillance requirements, or changes in recordkeeping, reporting, or administrative procedures or requirements. The staff has determined that this amer.dment involves no significant increase in l the amounts, and no significant change in the types, of any effluents that may be released l offsite, and there is no .gnificant increase in individual or cumulative occupational radiation l exposure. Accordingl) his amendment meets the eligibility criteria for categorical exclusion l set forth in 10 CFR 51.. I do) and (10). Pursuant to 10 CFR 51.22(b), no environmental l impact statement or enviiv.unental assessment need be prepared in connection with the issuance of this amendment.

t

4.0 CONCLUSION

The staff has concluded, on the basis of the considerations discussed above, tha' (1) because l the amendment does not involve a significant increase in the probability or conseqt, %es of I i

accidents previously evaluated, or create the possibility of a new or different kind of accident l

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 activitiec; 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 l

common defense and security or the health and safety of the public.

Principal Contributor: A. Adams, Jr, i i l Date: April 12,1999 l

i l

i t