ML20210M634

Forwards Responses to NRC 970709 Request for Addl Info Re Triga Mark I Research Reactor & Revised Ts.Licensee in Process of Removing All Fuel Elements from Reactor Core Structure & Placing Elements Into Storage Canal of Reactor

ML20210M634
Person / Time
Site:	General Atomics
Issue date:	08/18/1997
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Alexander Adams NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210M639	List: ML20210M634 ML20210M643
References
TAC-M97502, NUDOCS 9708220095
Download: ML20210M634 (8)

Text

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? CENERAL ATORNCE August 18,1997

, 38 2800

. Document Control Desk ATTN: Alexander Adams, Jr., Scalor Project Managor Non Power Reactors, Decommissioning and Environmontal Project Directorato Division of Advanced Reactors & Special Projects Offico of Nucinar Roactor Rogulation U.S. Nuclear Rogulatory Commission Washington, D.C. 20555

Subject:

Facility License R 38; Docket 50 89: Response to NRC Request for Additional Information; TAC No M97502 Roforence: Adams, Alexandor, Jr., Lottor to Dr. Kolth E. Asmusson,

• REQUEST FOR ADDITIONAL INFORMATION (TAC NO. M97502), Dated July 9,1997 Doar Mr. Adams:

As you are aware, Gonoral Atomics (GA) has requested that the liconso for its TRIGA Mark

• i reactor, l.o., License Number R 38, be amended so as to withdraw U.S. Nuclear Regulatory

~ Commission (NRC) authorization to oporato the subject roactor. Rocontly, you respond 6d for the NRC with a request for additional information (Roforenco). Accordingly, in responso to your requsst i

for additional information and in further support of our request, GA horoby submits tho following onclosuros:

Attachment 1: General Atomics' Responses to NRC's Roquest Dated July 9,1997 for Additional Information Ro: General Atomics TRIGA Mark l Rosearch Reactor (Docket No. 50-89)

Attachmont 2: Copy of ontire rovised technical specifications: " TECHNICAL SPECIFICA.

TIONS / TRIGA MARK l REACTOR" Following up on its commitment to rondor the subject reactor incapablo of operation, GA is in the process of removing all fuel elomonts from the Mark I reactor coro structure and placing them into the storage canal of the Mark F reactor. As of this date,33 fuel elements (out of a total of 76) have boon removed from the Mark I core and placed in the Mark F storago canal.

GA appreciates your assistanco in considering this request and is hopeful of, and in nood of, an expeditious approval, if you have any questions or require additionalinformation, please do not hesitate to contact me at (619) 455 2823, or Dr. Junald Razvi at (619) 457 8850.

I Very truly yours, 090

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Attachment No.1 GA Letter No. 38 2800 July 30,1997. Page 1 l

l General Atomics' Responses i to NRC's Request Dated July 9,1997 for Additional Information Re: General Atomics TRIGA Mark i Research Reactor (Docket No. 50-89)

NRC llem 1:

- Please provide a copy of your proposed technical specifications (TSs) without the changes italicized.

GA Respense to item 1:

A copy of the proposed technical specification without italicized changes is enclosed.

NBC llem 2:

Your answer to question 2 dated April 25,1997, states that corrections have been made to license condition 2.B.(3). However, your proposed wording does not show the correction. Please address.

GARasponse to item 2:

The proposed wording inadvertently did not show the correction. GA requests-that License Condition 2.B.(3) of its license No. R-38 be amended to read.

" Pursuant to the Act and 10 CFR Chapter I, Part 30 " Rules of General Applicability to Domestic Licensing of Byproduct Material", to possess but not to separate such byproduct material as may have been produced by past operation of the reactor."

NRC_ Item 3:

In your proposed TS 1.2 and 1.3, the wording in your replacement TS pages is different that the wording proposedin your application. Please address.

GA Resoonse to_ltem 3:

GA requests that the wording in TS 1.2 and 1.3 be revised to be consistent with the original application. This revised wording is incorporated into the copy of proposed technical specifications provided in response to item 1 above.

NBDJtemA You have proposed changing the title of TS 1,10 from " Reportable Occurances"

c Attachment No,1 GA Letter No. 38 2800 July 30,1997. Page 2 to " Abnormal Occurances," which was the historicaltitle of the TS. You state that you do not know when or why the name was changed. The title was changed by Amendment No. 23 to the license dated July 18,1976, which provided for a change in nomenclature for events which require reporting.

Please provide ajustification for your proposed change. We note that section 9 of the TSs refer to TS 1.10 by both titles. Please insure that the TSs are internally consistent.

You have proposed eliminating TS 1.10d. PleaseJustify why any unanticipated or uncontrolled change in reactivity greater than $1.00 while handling fuel would not be reportable.

Also, you have proposed changes to TS 1.10e. That refers to possession of the reactor outside the specified safety limits. What limits does this TS refer to in the possession-only mode?

GA Resoonse to item 4:

The term " Abnormal Occurrences" in TS 1.10 has been changed to " Reportable Occurrences" as the approved terminology specified in Amendment No. 23 to the '

license dated July 18,1978. All references in TS section 9 referring to

" Abnormal Occurrences" were changed accordingly. These proposed revisions have been incorporated into the proposed technical specifications provided in response to item 1 above.

GA hereby withdraws its proposed elimination of Technical Specification 1.10d.

TS 1.10d is to remain in the revised technical specifications.

As written, Technical Specification 1.10e is only applicable to an operable reactor, it does not apply to a reactor with a possession only license amendment.-- .

Therefore, GA proposes that TS 1,10e be revised to read as follows:

"An observed inadequacy in the implementation of either administrative or procedural controls, such that the inadequacy could have caused the existence or develo 3 ment of a condition which could result in possession of the reactor outsic e the requirements of the Technical Specifications."

NRCltem 2

- In light of your decision to remove all fuel from the reactor grid plate and place into storage, please reconsider the proposed wording of TS 5.1, " Control Systems." While the wording is true (a reactor without !::0!i:;autdown by at least one dollar), it is possible to have the wording similar to that of your proposedlicense condition 2.C.(4). Please address.

GA Response to Itanti GA proposes revising TS 5.1.2 as follows:

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l Attachment No.1 GA Letter No. 38 2800 July 30,1997. Page 3

'No reactor fuel elements or control elements with fuel followers shall be located in, stored in, or moved into, the reactor core structure."

NRC Item B;

' In your proposed TS 5.2.3 a., the wording in your replacement TS pages is different that the wording proposed in your application. Please address.

GA Resoonse to item 6:

i The proposed wording in TS 5.2.3 a. Has been revised to match the wording in GA's original application. This revision has been incorporated into the proposed technical specifications provided in response to item 1 above.

NRC Item 7; Please providejustification foryour new proposed TS 6.4.

GA.[Resoonse to item 7:

The addition of TS 6.4 is a precautionary measure to prevent unauthorized movement of fuel or, damage to the fuel handling equipment from use outside of their intended purpose. By requiring that fuel handling tools and devices be stored in a secure manner, their use can be limited to only authorized movements of fuel.

_. NRCllem8:_ l Please add a legend to your organizational chart that defines the difference

^between dotted and solid lines. Also please show the reporting lines for the Health Physicist and the Criticality and radiation Safeguards Committee, Some other TS (e.g., 8.2.9) still refer to the Criticality Safeguards Committee. Please make the Committee title throughout the TSs consistent.

GA Response to item 8:

- The revisions requested in item 8 have been made in the revised technical specifications provided in response to item 1 above.

- NRC Item 9:

- Your answer to our question number 11 discusses replacing licensed reactor operators with trained fuel handlers. Licensed reactor operators are required by the regulations until fuelis removed from the site. In light of this, please provide justification for removing the requirement for the Physicist-in-Charge or designate to be a licensed senior reactor operator as proposed in TS 9.1.

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Attachment No.1 GA Letter No. 38 2800 July 30,1997 - Page 4 GALRasponse to_llem3; l GA is evaluating its options for eddressing this issue. Currently, two approac'1es are being considered; these are: 1) request an exemption from the requ rement l for licensed o )erators, end 2) re-defining its reactor operator requalification program to ac dress reactor operator duties as they will exist undu a possession only license amendment. Inasmuch as the resolution of this item will take time, and is of great importance to GA to expeditiously obtain its requested possession only license amendment (POLA), GA requests that this issue be aduressed in a manner that will no'. impede the issuance of the POL A NRC ltem 10:

You have proposed changing the frequency of audita in TS 0.2.c. from quanedy to annually. Please provide a justification for this change.

t I your proposed TS 9.2.a., the wording in your replacement TS pages is different than the wording prcposedin your application. Please address.

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GA. Responstta item 10; The CRSC audit frequency was propo;'ed to be reduced fiom quarterly to ,

annually to be commensurate with too change in reactor status fr >ra operabie to incapable of operaticn and tho issuance of a possession caly license >

amendment (POLA) The quarterly audit fraquency was warranted while the reactcr was still operable due to the various conditicas the reactor experienecd, i.e.. pulsing, steady state power operations and shutoown. The likelihood of off normal conditions that would be deiacted t:y CRSC audits were certainly greater under normal operations than under the POLA conditior. which is shutdown and defueled. Accordingly, an annual CRSC audit frequency was determined to be adequate under the static POLA conditions. This audit fiequencyis consistent with the existing CRCS audit policy. ,

The wording in TS 9.2.a has been changed to reflect the exact wording in the original application. This wording is incorporated into the version of the technical specificuions provided in response to item 1 above. <

NBC.RenLL.11 The introduction to TS 9.3 refers to safety of oparation of the reactor. Please consider cnanging this woniing to reflect possesson-only status.

Your proposed wording fa r TS 9.3.a. elimina:ed reference to testing and calibration of radiation monitors. Please addrosa.

You have proposed eliminating TS 9.3.f. Will any systems romain operational to ensure integrity of the fuel (e.g. deminenalizer system) t' sat require maintenance? llso, there should be a TS requiremont for wntten maintenance

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4 Attachment No.1 GA Letter No. 38 2800 July 30,1997. Page s procedures.

You have proposed changes to the paragraph following 9.3.g. One of the changes would allow the Physicist-in Charge to make changes to procedures that were not temporaryin nature. The existing TS allowed temporary changes to be made to allow operational flexibility and continued operation of the reactor 1

if minor deviation from procedures was needed. Pleasejustify your proposed change including how the requirement; of 50.59 will be met for Physicist-in-Charge changedprocedures, if applicable.

GA Resoonsg to item 1.t The terrn " safety of operation" in the introductory paragraph of TS 9.3 was l changed to

• safe possession" to ref:ect the POLA status of the recctor. This L revisien has been incorporated into the copy of the technical specifications l provided in response to item 1 above.

TG 9.3.a. has been changed to include the requirement for testmg and calibration of rodlation monitors. This revision has been incorporated into the s

copy of the tuchnical specifications provided in response to item i sbove.

TS 9.3.t will not be deleted but be changed to read: -Maintenance of systems i necessary foi assuring the inMgrity of the fuel or otherwise maintaining the l

reactor in POLA status." This revision has been incorporated into the copy of the I

technical specifications provided in response to item 1 above.

Tho proposed change to TS 9.3.g has been revised to be consistent with the existing TS and allow the Physicist-in Charge to inake only temporary char.ges to procedures. This allows flexibility in the posaession of the reactor if minor deviations fiom procedures are needed. This revision has, been incorporated into ine copy of the technical specificctions provided in response to item 1 above.

NBCJtenLIC 10 50ur proposed TS 9.6 you havs the NRC zip code as 20545. The current zip code for the NRC is 20555. Pleasc address You have proposed changes to TP 9.6.e for the facility arnual report. We agree that some of the items listed an) not applicable to a facility in possession-only status. However, because the report provides information on past events, all the reporting requirements must stey in place until repotts that cover the time period forthe cperating license are submitted. Please address. Please consider revising 78 9.6 e. ! and 4 to refer to possessionmnly activities. Also, you state timt TS 9.6.e.6 th.ough 9.6.e.8 am requ* red by GA's 10 CFR 20 site report.

Clease reference the regulation in 10 CFr' Part 20 that requires submission of the radiologicalinformation in the TS. If tht: roquiramcnt can not be found, please justify your proposud deletion of these ,equirements.

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4 Anachment No.1 GA Letter No. 38 2800 July 30,1997. Page 6 Gall 0E0nsa to item 12:

The NRC zip code in TS 9.6 was changed from 20545 to 20555. This change is incorporated into the version of the technical specifications provided in response to item 1 above.

GA hereby withdraws its request of April 25,1997 to revise TS 9.6.e and, instead, requests that only the introductory paragraph to TS 9.6.e be revised.

GA proposes that the introductory paragraph read as follows:

• e. By April 15,1998, a routine report in writing to the Document Control Desk, U.S. Nuclear Regulatory Commission providing the following information:"

Further, GA requests that a new technical specification 9.6.f be added. The proposed TS 9.6.f is to read as follows:

'f. Commencing in 1999, a routine report in writing to the Document Control Desk, U.S. Nuclear Regulatory Commission by April 15 of each year, providing the following information:

1. A brief narrative summary of: (1) pcssession and storage and (2) changes in facility storage design.

2. Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe possession of the reactor, and the reasons for any corrective maintenance required.

3. A summary of each change, if such changes have been made, to the facility, or procedures, tests, and experiments carried out under the conditions of Section 50.59 of CFR Part 50.

4. A summary of the nature and amount of radioactive affluents released or discharged to the environs beyond the effective control of the licensee as measured at or prior to the point of such release or discharge.

5, A description of any environmental surveys performed outside the facility.

6. A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facility."

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