ML20211B185
| ML20211B185 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 08/16/1999 |
| From: | Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| To: | Alexander Adams NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20211B191 | List: |
| References | |
| NUDOCS 9908240241 | |
| Download: ML20211B185 (22) | |
Text
ORIGINAL FOR !
UNIVERSITY OF VIRGINIA D D C U M E N ^I CONTROL DE$K NuaEAR REACWR FACRITY U.S. Mall ADDRESS STREET ADDRESS RO. Box 3425 675 Old Reservoir Road University Station Charlottesville, VA 22903 Charlottesville, VA 22903 Telephone: 804-982-5440 Fax: 804-982-5473 August 16,1999 Mr. Alexander Adams, Jr.
Senior Project Manager Non-power Reactors and Decommissioning Project Directorate U.S. Nuclear Regulatory Commission M.S. 0-11-B-20 D - 19 Rockville, MD 20852-2738
Subject:
NRC's March 1999 Request for AdditionalInformation; Amendments to UVAR License and Technical Specifications (TS); University of Virginia Reactor, Docket No. 50-62, License R-66.
Dear Mr. Adams:
Please find enclosed the University of Virginia response to NRC's March 8,1999 Request for AdditionalInformation. Also enclosed is proposed wording for a UVAR Possession-Only License, as well as revised and new UVAR Technical Specifications as per NRC requut, and substitute UVAR TS pages (with and without markings) and associated key sheet. Please ! ,
contact me at (804) 982-5440, or by e-mail sent to mm@ Virginia.EDU, should you have need i I for additional information.
f Sincerely Gty/ County of 4 #b h Commonwealth of Virginia .I i
I hereby certify that the attached docun ent is a true end
- presented before k exact copy of a ;
Rcbert U. Mulder, Director me this / day of Cuf 19 gg U.Va. Reactor Facility &
Assoc. Prof. of Nuclear Eng. by gg ,,,, _
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cc: Mr. Craig Basset, NRC Region II, Atlanta, Ga. Mv commission expires b d(O -
Document Control Desk, NRC, Washington 9908240241 990816 PDR ADOCK 05000062 P PDR
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i 1 Answers to NRC's March 8,1999 Request for Additional Information i l (August 2,1999, U.VA Research Reactor Docket No. 50-62) .
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- 1. Your proposed changes to license condition II.B(4) results in wording that is similar !
' to that in license condition II.B.(2). To reduce the possibility for confusion as to l special nuclear material (SNM) possession limits, please consolidate possession for L l any SNM that remains under license condition II.B.(4) to license condition II.B.(2). i If the possession limit of one kilogram of uranium-235 of any enrichment needs to be i modified to accommodate the consolidated material, please propose and justify l
' increased possession limits. There are differences in wording between the proposed license conditions given in your answers to our request for additional information I and in the proposed license included in your submission. Please address.
l Answer:
The possession of 1 kg of contained uranium-235 under license condition II.B.(4) has .
been consolidated into license condition II.B.(2), Thus, paragraph II.B.(4) has been i
. eliminated, at NRC request. (Please see attached proposed Facility Possession - Only License). With the recent shipments of all spent reactor fuel from the Reactor Facility, the possession limit of contained uranium at any enrichment can be reduced to 5 kilograms at ;
this time. This new limit allows possession of LEU fresh fuel elements, fission chambers !
and flux foils. The 10 fresh fuel elements will be shipped off-site at the earliest opportunity.
All Pu-239 is now carried on the University's By-Product License, thus none will be authorized under the UVAR Technical Specifications or on the UVAR License.
Small differences between wording used in the answers to an NRC Request for Additional Information and the proposed license included in our earlier submittal did indeed occur as a result of typos and transcription mistakes. To resolve any future possible typo-originating discrepancies between our response to the NRC Request for Additional Information, the text of the Reactor License submitted should be taken as the true and binding version.
- 2. While fuel and cobalt are stored in the reactor pool, a potential radiation hazard exists from the loss of pool water. Please propose a TS for maintaining a system to provide warning ofloss of pool water. Please propose associated operability and surveillance requirements, if appropriate.
l Answer:
2 We agree that the loss of pool water presents a potential radiation hazard while cobalt is stored in the pool. All spent fuel already has been shipped off-site. To address this issue, new Technical Specifications TS 4.10 and TS 3.12 are proposed, as follows:
"TS 4.10 Eurveillance of Reactor Poolwater Level Applicability: Technical Specification 4.10 applies until all Cobalt-60 pins have been removed from the UVAR pool. This TS specifies the surveillance frequency of poolwater 1 level monitoring instrumentation.
Obiective: The goal is to detect significant poolwater leak rates well before loss of ,
poolwater results in radiation hazard due to cobalt stored in the pool. l Specification: The poolwater level float switch shall be ch:cked for operability, alarm and alen functions on a weekly basis until all cobalt pins have been removed permanently from 1 the UVAR pool.
Bases: Poolwater is lost from the open UVAR pool by evaporation and small leaks.
Makeup water is added about twice weekly, at which time the actual water level is checked and recorded." l The poolwater monitoring / alarm instrumentation is based on a simple, reliable float mechanism which actuates an audible and visual alarm in the first floor hallway (near the j reactor staff offices). Additionally, an automatic phone dialer is actuated to alert reactor staff during oft-work hours.
Note: It is a simple matter to verify that the level indicating float is snag-free and able to trip the alarm circuit. Also, UVAR poolwater level is normally kept well above a level which would result in a radiation hazard.
"TS 3.12 Poolwater-Level Monitoring Applicability: This specification applies to the poolwater-level float switch which monitors poolwater level and has alert and alarm functions.
i Objective: The goal is to prevent severe loss of poclwater level while cobalt pins are kept l in storage in the UVAR pool. Excessive loss of water level could result in diminished l shielding and generation of a radiation hazzard. )
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Specification: Until all cobalt pins have been permanently removed from the UVAR pool, I a poolwater level float switch shall be operating. l l
Basis: The water-level float switch is a simple device able to sense small decreases in poolwater level and perform timely local and remote alen and alarm functions. 1
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l 3. Your answer dated January 20,1999, to our question 5.B. states that procedures will require the air monitor in the reactor room to be turned on during fuel shipments. While irradiated fuel remains on site, a potential exists for a cladding I failure and release of fission products. Ilow would this be detected during fuel storage? Please propose a TS to ensure operation of the air monitor during fuel movement and,if needed, during fuel storage. Please propose associated operability and surveillance requirements,if appropriate. Your answer to question 8 has l proposed wording to calibrate the bridge radiation monitor until the fuel and cobalt-60 pins are removed from the reactor pool, but there does not appear to be a !
requirement to have the monitorin operation. Likewise, there does not appear to )
be a specification similar to 4.4.1 for required radiation monitoring equipment. )
1 Answer:
- As of June 4,1999, all UVAR spent nuclear reactor fuel had been shipped to the l Savannah River Plant site. Thus, fission product containment and monitoring is no longer l
a concern at the Reactor Facility. Safe storage of cobalt-60 pins in the UVAR pool have been addressed in the answer to NRC question 2. Poolwater sampling and analysis, together with poolwater level monitoring, are sufficient to ensure safe cobalt storage.
Thus, reactor bridge area radiation monitoring, and confinement air monitoring, will not be required again until such time as concrete removal work would begin under an NRC-approved Decommissioning Plan. New Technical Specifications will be proposed to cover l those work activities at an opportune future time.
- 4. Your proposed changes to TS 4.5 would eliminate this TS. Please propose a TS l requirement (or modifications to this TS) that would insure that operation of the radiation monitors is verified after maintenance or modification.
Answer:
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l At NRC request, we propose a change to TS 4.5 that would ensure that operation of the radiation monitors is verified following maintenance or calibration.
"4.5 hiaintenance Applicablity: This specification applies to the surveillance requirements following maintenance of the area radiation monitoring system.
Obiective: The goal is to ensure that the area radiation monitoring system is operable following maintenance, repair or modification and prior to first use.
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l l Specification: Following maintenance, repair or modification of the area radiation monitoring system, it shall be verified that the system is operable before it is returned to service.
- Bases
- It is necessary to ensure that any work on or change made to the system is carried I out properly so that the system will operate as intended and that the system or component has been properly reinstalled or reconnected. Operability must be verified prior to the first use of the system following maintenance, repair or modification."
- 5. Your proposed changes to TSs 4.6 and 5.2 would eliminate requirements on the l confinement and ventilation system. Please propose wording that would require
! operability and surveillance of these systems until fuelis permanently removed from )
l the facility orjustify not operating these systems. j l
Answer:
As of June 4,1999, all spent nuclear fuel has been permanently removed from the UVAR I
! Facility. Thus, until decommissioning work begins, under an NRC-approved Decommissioning Plan, the changes U.Va. proposed to TSs 4.6 and 5.2 are appropriate and operability and surveillance requirements on these systems can be postponed until and whenever the systems are required again.
- 6. TS 5.3.1 refers to use of contained uranium-235. However, your proposed license condition II B.(2) does not allow use of uranium-235. Please make the license condition and TS consistent. Your proposed TS 5.3.2 refers to use of plutonium.
Ilowever, your proposed license condition 11 B.(2) does not allow use of plutonium.
Please make the license condition and TS consistent. If you choose to continue to l authorize use of these materials, please give some examples of your intended uses. l I
Answer:
l The inventony of Pu-239 at the Reactor Facility totals 130.45 grams, mostly in Pu-Be sources. All Pu-239 is now under the University's By-Product License. The 16 grams previously specified in the Reactor License has been placed under the By-Product License.
Thus, to bring the proposed UVAR Facility License in conformity with UVAR TS, it is necessary to amend TSs 5.3.1 and TS 5.3.2. as follows:
"5.3.1 LEU Possession Limit A maximum of 4 kilograms of contained uranium-235 at less than 20% enrichment (which is dermed as low enriched uranium, LEU) may be possessed at the Reactor Facility."
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5 "5.3.2. Plutonium Possession Limit All plutonium contained in start-up sources, irradiation targets, flux foils and fission chambers, which totals less than 131 grams, is possessed at the Reactor Facility under the >
University's By-Product License and not the Reactor License."
Pu-Be neutron sources might be used at the University under the Broad Byproduct License for lab experiments and classes involving neutron detectors.
- 7. Please define on your proposed organizational charts the meaning of solid and dashed lines similar to that on your current organizational chart.
Answer:
The solid lines describe lines of authority, while the dashed lines reflect communication lines. These definitions have now been added to the organizational chart in Fig. 6.1 of the UVAR TS. (Please see enclosures).
- 8. One of the attributes of the review and audit committee discussed in ANSI /ANS-15.1 is that members of the operating staff do not constitute the majority of a quorum. While with the permanent shutdown of the reactor, an " operating stafr' will not exist after removal of the fuel, this concept is still valid for members of the Reactor Decommissioning Committee (RDC). Please propose a technical specification that prohibits persons (e.g., reactor staff, reactor decommissioning subcontractors, or health physics staff directly supporting decommissioning) who will be directly affected by decisions of the committee from making up a majority of a quorum.
l Answer:
Historically, the Reactor Director has cast the sole vote in the name of the operations group at Reactor Safety Committee (ReSC) Meetings. Therefore in response to this NRC request, a new TS 6.2.C.2.(4) is proposed, which will read as follows:
"(4) The Reactor Director shall cast a single vote in the name of the operations staff at Reactor Decommissioning Committee meetings. The operations staff encompasses the reactor staff, decommissioning subcontractors and anyone directly supporting decommissioning and working under the d . %n of the Reactor Director."
- 9. Please propose a TS that requires timely dissemination, review, and approval of ReactorSafety Committee, Radiation Safety Committee and RDC meeting minutes.
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, Answer:
In response to this NRC request, new TS 6.2.A.2.(4), TS 6.2.B.2.(4) and TS 6.2.C.2.(5) l are proposed which read as follows:
TS 6.2. A.214)
, - (4) Radiation Safety Committee meeting minutes shall be distributed to the committee membership within three months following a meeting. These minutes shall be reviewed for approval at the next scheduled committee meeting."
TS 6.2.B.214)'
"(4) Reactor Safety Committee meeting minutes shall be distributed to the committee membership within three months following a meeting. These minutes shall be reviewed for approval at the next scheduled committee meeting."
TS 6.2.C.215)
"(5) Reactor Decommissioning Committee meeting minutes shall be distributed to the committee membership within three months following a meeting. These minutes shall be reviewed for approval at the next scheduled committee meeting."
- 10. Please propose review functions for the Reactor Safety Committee and the RDC similar to those in ANS-15.1, considering the permanent shutdown status of the l facility, or justify the differences in your proposed TSs. For example, the Reactor Safety Committee does not have review responsibility for 10 CFR 50.59 changes and violations of TSs and license or internal procedures having syfety significance.
While the list of responsibilities for the RDC includes reference to 10 CFR 50.59(a),
the committee responsibilities do not match the requirements of 10 CFR 50.59(a).
The RDC does not have review responsibility for violations of TSs, license or ,
internal procedures having safety significance.
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l Answer:
ANSI /ANS-15.1 Section 6.2.3.(1) addressing the review of proposed changes to i equipment, systems, test, experiments or procedures for safety significance is already ;
covered for the ReSC in UVAR TS 6.2.B.3.(1), (2) and (3). During decommissioning, no tests or experiments will be run. Thus, this item also is appropriately addressed for the l RDC in UVAR TS 6.2.C.3.(1) and (2). .
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ANSI /ANS-15.1 Section 6.2.3(2) concerning review of new and revised procedures having safety significance, and of changes to equipment, is presently adequately addressed for the ReSC in UVAR TS 6.2.B.3.(2) and (3). This item is appropriately addressed for the RDC UVAR TS 6.2.C 3.(1) and (2).
ANSI /ANS-15.1 Section 6.2.3.(3) involving review of new experiments affecting reactivity or with the potential for radioactivity release, is addressed for the ReSC in UVAR TS 6.2.B.3.(1) and (2).
Since reactor related experiments will not be conducted during the decommissioning phase, this item need not be covered for the RDC in the TS.
ANSI /ANS-15.1 Item 6.2.3.(4) concerning changes to TS and license is addressed for the ReSC in UVAR TS 6.2.B.3.(3), and for the RDC in UVAR TS 6.2.C.3.(2).
ANSI /ANS-15.1 Item 6.2.3.(5) involving review of TS, and license or SOPS violations having safety significance, is addressed for the ReSC in UVAR TS 6.2.B.3(4) and (6),
although not using the ANSI suggested language. U.Va. uses the phrase " review of reponable occurrences" Violations of TS, license or SOPS with safety significance certainly are " reportable occurrences."
Nevenheless, to fully address this matter, U.Va. proposes to reword UVAR TS 6.2.B.3.(4) as follows: l
"(4) Review reportable occurrences, to include violations of Technical Specifications, License or of Standard Operating Procedures that have safety significance, as well as the j occurrences listed in ANSI /ANS-15.1 Item 6.6.2. Also, to review the actions taken to identify and correct the cause of these occurrences."
In the same vein, U.Va. proposes to reword UVAR TS 6.2.C.3.(3) as follows:
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"(3) Review unusual and reportable occurrences, to include those violations of Technical Specifications, License, or of Standard Operating Procedures that have safety significance, as well as the occurrences listed in ANSI /ANS-15.1 Item 6.6.2. Also, to review the actions taken by reactor management to identify and correct the cause of these occurrences."
ANSI /ANS-15.1 Section 6.2.3.(6) regarding review of(reactor) operating abnormalities having safety significance is addressed for the ReSC in UVAR TS 6.2.B.3.(4). A completely defueled and shutdown reactor cannot have operating abnonnalities, thus there is no UVAR TS to cover this for the RDC.
ANSI /ANS-15.1 Section 6.2.3.(7) involving review of reportable occurrences as defined in ANSI /ANS-15.1 Item 6.6.2.] is covered for the ReSC in the newly above proposed wording to UVAR TS 6.2.B.3.(4) and for the RDC in proposed revision to UVAR TS l
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' 6.2.C.3.(3).
To make explicit the ReSC review responsibility for changes as per 10 CFR 50.59, U.Va.
proposes the addition of UVAR TS 6.2.B.3.(7) reading as follows:
"(7) Review and approval of changes to experiments, reactor systems and procedures as per 10 CFR 50.59."
To make explicit the RDC review responsibilities for changes as per 10 CFR 50.59, U.Va.
proposes to modify recently proposed UVAR TS 6.2.C.3.(1) as follows:
"(1) Review and approval for changes to the Reactor Facility and to the UVAR SOPS as applicable and described in 10 CFR 50.59."
- 11. Please propose audit functions for the Reactor Safety Committee and the RDC similar to those in ANS-15.1, considering the permanent shutdown status of the facility, orjustify the differences in your proposed TSs. For example, the Reactor Safety Committee does not appear to have an audit function for the operator requalification program, corrective actions, or the emergency plan and implementing procedures. The RDC does not appear to have an audit function for the corrective actions, or the emergency plan and implementing procedures. Audit functions that are an internal requirement ofindividual plans or programs are acceptable and need not be repeated in the TSs.
I Answer:
1 The audit functions specified in ANSI /ANS-15.1 Section 6.2.4 have been carried out by the ReSC in the past. However, in response to the NRC suggestion, these ReSC audit functions can be made explicit by amending the recently proposed UVAR TS 6.2.B.3.(6) as follows:
"(6) Audit annually [through a selective yet comprehensive examination of records, logs and personnel]:
a) Facility operations for conformance to TS and License ,
l b) Results of actions taken to correct verified deficiencies that may occur in reactor equipment, systems, structures or method of operations that affect reactor safety.
. and audit biennially:
c) Operator retraining and requalification program for the reactor operations staff d) Reactor Facility Emergency Plan and Implementing Procedures"
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To address the audit function of the RDC, U.Va. proposes revising recently proposed UVAR TS 6.2.C.3. (4) and adding a new TS 6.2.C.3.(5) to read as follows:
"(4) Annually audit [through a selective, yet comprehensive, examination of records, logs and personnel] facility operations for conformance to licenses, Technical Specifications, NRC regulations and inspections, as well as UVAR SOPS; and to recommend remedial l action to correct identified deficiencies."
"(5) Biennially audit the Operator Retraining and Requalification Program of the reactor staff, as well as the Reactor Facility Emergency Plan and Implementing Procedures."
- 12. In your two proposed organizational charts the title of Provost appears to have been changed to Vice President and Provost. Also the position of Provost on the organizational chart has changed with the change in title. Please justify these proposed changes.
Answer:
The change in the title of the " Provost" to "Vice-President and Provost", and the change in the location of the Provost on the organizational chan in TS Figure 6.1, are
- administrative changes desired by the University's President. The Provost title change was made to make it clear to non-academics that the Provost's title also carried administrative power and responsibility. These title change does not reduce the degree of j administrative oversight over the Reactor Facility and its decommissioning activities. j i
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- 13. Your current TS 6.3.2 discusses changes to procedures that do not change the original intent and minor changes. Your proposed TS do not appear to have an i equivalent concept. Please explain. j l
Answer:
i By oversight, the following statement was dropped and is now added to TS 6.3.2 Changes 4 to SOPS:
" Changes that do not change the original intent of the procedures may be made with the approval of the Facility Director. All such minor changes shall be documented and subsequently reviewed by the Reactor Safety Committee (or by the Reactor Decommissioning Committee afler the ReSC ceases to exist)."
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- 14. ' Question 23 in our request for additional information dated November 23,1998 asked about elimination of reporting violations of TS. Your answer focused on the permanent shut down status of the facility. However, NRC still considers violation l of the remaining TS that are applicable to the permanently shut down reactor important enough to report. Please propose a TS that accomplishes this or justify not reporting violation of these remaining TS.
l Answer:
This concern is best resolved with the addition of UVAR TS 6.7.l(c) stating as follows:
"(c) Violation of UVAR Technical Specifications."
- 15. TSs 6.7.1.(2)(b) and 6.7.1.(3)(b) refer to TS 6.6.2. However, your proposed revisions to the TSs eliminated TS 6.6.2. Please address.
Answer:
l This is correctable by revising UVAR TS 6.7.l(2)(b) and UVAR TS 6.7.l(3)(b) to both state:
"(b) Reportable occurrences as defined in Section 6.6.2 of ANSI /ANS-15.1."
- 16. Your proposed wording of TSs 6.7.1.(3)(a) and (b) is the same as TSs 6.7.1.(4)(a) and (b). Please justify the elimination of TS 6.7.1.(4)(a) and (b), considering the fact that fuel remains on site.
Answer:
UVAR TS 6.7.1 (3)(b) should be revised to read:
"(b) Reportable occurrences as defined in Section 6.6.2 of ANSI /ANS-15.1."
The eliminaticn of present UVAR TS 6.7.l(4)(a) and (b) is justified because reference is made in those TS to reactor performance specifications and a significant change in the reactor transient or accident analysis. Performance specifications and transient or accidents no longer apply to a de-fueled and shutdown reactor. Proposed UVAR TS 6.7.1.(4)(a) addresses concerns with accident scenario involving storage of UVAR spent nuclear fuel, however, all spent nuclear fuel has been shipped off-site already.
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- 17. Your current TS 6.7.2 contains a requirement to report 50.59 changes as part of the annual report. Your proposed TS 6.7.2 does not contain a similar requirement.
Please explain. I Answer:
Proposed UVAR TS 6.7.2.(15) was left incomplete. It should read:
! "(I 5) Significant Changes to the Reactor Facility, Reactor SOPS and of all changes made as per 10 CFR 50.59," l l
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- 18. Do any of the changes to the license and TSs for the UVAR need to be made to the !
CAVALIER TSs and License or will the CAVALIER decommissioning proceed i under the existing Order and TSs?
Answer:
Approved changes to UVAR TS 6 Administrative Controls will have to be reflected in CAVALIER TS section 6. An amendment request for the CAVALIER TS is being sent ;
to N'RC under separate cover..
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, Kev of UVAR Tech Spec Chanoan _
All pages have some format differences and the amendment numbers at the bottom have been L removed.
Nag Qld Dancription
! ^DA8C DASC 1 .I_ ' New title page 2' 2 ' New table of contents 3 3 Two new definitions have been added, " Decommissioning" and " Decontamination" 4 4 Two definitions moved to this page from page 5 I
5- 5 Two definitions moved to page 4, three moved from page 6 6 6 ' One new definition added, " Reactor Facility" Three definitions moved to page 5, three moved from page 7 7 7 One new definition added, " Permanent Reactor Shutdown" Three definitions moved to page 6, two moved from page 8 8 8 Two definitions moved to page 7, three moved from page 9 1 9 9 Three delcitions moved to page 8 10 --
Add a new figure of the Reactor Facility area 11 10 12 'll 13 12 i
l 14 13 15 14 16~ 15- 1.5 paragraphs have been moved from page 17 to 16 l 17 -16 1.5 paragraphs have been moved to page 16 from 17 18- 17 ,
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-20 19 )'
l 21_ 20 l 22 21 i l; 23 22- l 24 23 25 24 3.6.6. "Cobah Facility" changed;" rods" changed to " pins" so as not to ccnfuse these with " control rods". Requirements have been modified so that it is only in force when cobalt-60 pins are in the pool.-
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Nag Old Description DASA DASA 27 26 28- 27 29' 28 3.10 " Emergency Removal ofDecay Heat" has been deleted and replaced with a statement telling why it was deleted.
-30 29 3.11 " Primary Coolant Condition" has been modified to require a certain pool water quality only while fuel and cobalt-60 pins are in the reactor pool.
3 0-31, - - A new section has been added, 3.12 " Pool Level Monitoring" requires pool level monitoring until all the cobalt-60 pins are removed from the reactor pool.
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A new page describing all the changes to section 4. Sections 4.1,4.2,4.3,4.6,
! 4.7 and 4.9 have been completely eliminated (old pages 30,31,32,35 and 36).
l 33- 33 Section 4.4 has been modified. ' Applicability and Calibration have been changed I
to eliminate these requirements when the fuel and cobalt-60 pins are no longer in the reactor pool.
33 34 Section 4.5 has been modified to apply only to the area monitoring system, the
~only remaining control or safety system.
34 37 Section 4.8 has been modified to be able to end this requirement when fuel and cobalt-60 pins have been removed from the reactor pool.
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Section 4.10 has been added to provide surveillance of pool water level device while cobalt-60 pins are in the reactor pool.
35 38 36 39 37- 40 5.2 " Reactor Building" has been deleted and replaced with a statement telling why it was deleted.
38 41 5.3 " Fuel Use and Storage" has been changed. The possession limits have been reduced to reflect the material that has been shipped off-site. It has also been modified to reflect that the section will not be applicable once all the fuel is shipped off-site.
39-40 42 6.1 " Organization" has a number of changes.
In " Applicability" and Objective"; " operation of the Reactor Facility" has been changed to " safe maintenance, defueling, decontamination and decommissioning of the Reactor Facility".
E i i-3 Nga Old ~ Description In 6.1.1. " Structure", "Vice P4ovost for Research" updated to the new name f "Vice President for Research and Public Service" and section added describing the duties of the Chair of the Reactor Decommissioning Committee and the
- members of the Decommissioning Committee..
In 6.1.2. " Responsibility", the responsibilities of the Reactor Facility Director and the Reactor Supervisor have been changed to reflect the change in duties with the change in the mission of the Reactor Facility from operations to decommissioning.
"The Reactor Facility Director shall be responsible for the overall facility
. operation (Level 2)" has been changed to >>> "During the UVAR permanent shutdown and decommissioning period, the Reactor Facility Director (Level 2) shall be responsible for the overall facility operation and the direction of the decommissioning activities at the Reactor Facility".
"During periods when the Reactor Facility Director is absent, his responsibilities are delegated to the Reactor Supervisor (Level 3)" has been L
changed to >>> "During periods when the Reactor Facility Director is absent, the Director's responsibilities are automatie=Hv delegated to the Reactor Supervisor (Level 3)".
I "The Reactor Supervisor (s) shall be responsible for the day-to-day operation of the UVAR and for ensuring that all operations are conducted in a safe manner and within the limits prescribed by the facility license and !
the provisions of the Reactor Safety Committee." has been changed to >>>
- l. "The Reactor Supervisor shall be responsible for the day-to-day activities at the UVAR and ensuring that these are conducted in a safe manner and L within the limits prescribed by the faciliiy license" "A NRC Senior Reactor Operator license, or a Reactor Operator license, is not required for level 3 and 4 personnel once all reactor fuel elements have
- been shipped offsite" has been added.
t i 40 43 In 6.1.3. " Staffing", has been changed to reflect the fact that the reactor is no longer operational and that all spent reactor fuel has been shipped off-site.
~ "When the reactor is operating the following conditions will be met:
(1) A licensed Senior Reactor Operator or a licensed Reactor Operator shall be present at the reactor controls.
(2) A licensed Senior Reactor Operator shall be on call, but not necessarily at the Reactor Facility.
(3) At least one other person, not necessarily licensed to operate the reactor, shall be present at the Reactor Facility, j
4 Ngg Old Dancription pass - page (4) All rearrangements of the core shall be supervised by a licensed Senior Reactor Operator.
(5) One or more health physicists, organizationally independent of the )
Reactor Staff as shown in Figure 6.1, shall be responsible for radiological safety at the Reactor Facility" has all been deleted and replaced with >>>
"A licensed Senior Reactor Operator shall supervise any movement of reactor fuel. One or more health physicists, organizationally independent of the Reactor Staff as shown in Figure 6.1, shall be responsible for radiological safety at the Reactor Facility".
In 6.1.4. " Selection and Training ofPersonnel", has been changed to reflect the fact that the reactor is no longer operational and that the staff's principal new duties are related to the planning for decommissioning.
"The selection, training and requalification of operations personnel shall i meet or exceed the requirements of the American National Standard for I Selection and Training ofPersonnel for Research Reactors, ANSI /ANS- {
15.4-1988, Sections 4-6" has been changed to >>> "The selection, training and requalification of Reactor Facility personnel shall follow the American ,
, National Standard for Selection and Training of Personnel for Research l Reactors, ANSI /ANS-15.4-1988, Sections 4-6, to the extent applicable to i the decommissioning status of the facility. The selected criteria for the
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personnel will be contained in the NRC-approved Operator Requalification ;
Program, as amended". l Add to the bases: "Some of the ANSI standard recommendations apply to !
operable or operating reactor facilities, and are not necessarily valid for l staff hired to perform decommissioning activities". !
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New section 6.2.A, " Radiation Safety Committee" added to describe this ,
committee and its duties related to the Reactor Facility.
42-44 44-45 New section 6.2.B. takes the place of old section 6.2 " Reactor Safety Committee" (ReSC). This modified section describes the change in responsibilities of the
' ReSC and foresees the elimination of the committee when all reactor fuel
! elements have been shipped off-site.
l 45-46 -- New section 6.2.C, " Reactor Decommissioning Committee", describes the composition of this committee, the required qualifications ofits members and
. their responsibilites.
47 46 New organizational chart, for before fuel is shipped off-site, i l
p . .
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h - QM - l Damerintian
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New organizational chart, for after fuel is shipped off-site.
49- 47 Several minor changes to reflect the change in status of the Facility and the oversight committee which will review changes to the standard operating procedures.
'50 49
~51 50 52 52 . Add one additional record type to the list of those that must be retained for at least five years.
53 53 54- 54 Since'the reactor has not been operational for over one year and all the used fuel elements have been shipped off-site it would be impossible to exceed a safety limit. Therefore, the procedure that tells one what to do if a safety limit is exceeded is not necessary and has bean removed. The section on what to do if there is a Reportable Occurrence has also been modified.
~ "Anglic=hiliev The specifications below apply to instances where reactor safety limits have been exceeded, or radiologically unsafe situations have been, or were likely to have been, generated" has been changed to >>>
"Anglic=hilitv: The specifications below apply to instances where radiologically unsafe situations have been, or were likely to have been, generated".
" Objective: The objective is to report safety limit violations or unsafe conditions, study their causes and consequences, determine their effect on the health and safety of personnel and the public, and take corrective action to prevent recurrence" has been changed to >>>
l
" Objective: The objective is to report unsafe conditions, study their causes and consequences, determine their effect on the health and safety of personnel and the public, and take corrective action to prevent recurrence".
The section titled: Actions To Be Taken in the Event the Safety Limit is Exceeded has been deleted.
Under 6.6.2. Action To Be Taken in the Event of a Renortable Occurrence the following four sections has been deleted and the remaining three sections have been renumbered.
"(1) Safety system setting less conservative than specified in Section 2.2 of these specifications.
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6 Nsa Old Danniption pasc pass (2) Operating in violation of a Limiting Condition of Operation (LCO) established in these specifications, unless prompt remedial action is taken.
(3) Safety system component malfunctions or other component or system malfunctions during reactor operation that could, or threaten to, render the safety system incapable of performing its intended safety function, unless immediate shutdown of the reactor is initiated.
(4) An uncontrolled or unanticipated increase in reactivity in excess of 0.70$."
Under the section with the heading "In the event of a reportable occurrence, the following action shall be taken" add a new action:
"(a) Ongoing activities shall cease until the occurrence has been resolved."
and change the action: "(a) The Director of the Reactor Facility shall be notified as soon as possible and corrective action shall be taken before Issuning the operation involved" to >>> "(b) The Director of the Reactor Facility or his designee shall be notified as soon as possible and corrective action shall be taken as foreseen in the procedures "
and change to action: "(b) A written report of the occurrence shall be made l which shall include an analysis of the cause of the occurrence, the corrective action taken, and recommendations for measures to preclude or reduce the probability of reoccurrence. This report shall be submitted to the Director and the Reactor Safety Committee for review" to >>>
"(c) A written report of the occurrence shall be made which shall include an analysis of the cause of the occurrence, the corrective action taken, and recommendations for measures to preclude or reduce the probability of reoccurrence. This report shall be submitted to the Director and the Reactor Safety Committee and/or the Radiation Safety Officer for review".
1 55 56 Section 6.7," Reporting Requirements", has been modified in sections
. 6.7.1.(2)(b) and 6.7.1.(3)(b) in that the phrase "Section 6.6.2 of these specifications" has been changed to >>> "Section 6.6.2 of ANSI /ANS-15.1" and i
l 6.7.1.(2)(c) and 6.7.1.(3)(c) has been changed from " Violation of a safety limit" l to >>> " Violation of a safety limit or technical specification."
56-57. 57-58 Section 6.7.1.(4), about reports that are required to be sent within 30 days has been changed to reflect the change in status of the reactor and the changes in the ,
personnel responsible for the oversight of the reactor. !
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"(4) A special written report should be sent by mail within 30 days to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, of:
(a) Sinhatantial variance from nerformance snecifications contained in thana anacificatinns or in the UVAR SAR.
(b) Significant change in the transient or accident analyses as described in the UVAR SAR.
(c) Changes in personnel serving as Vice Provost for Research, Reactor Facility Director, or Reactor Supervisor."
has been changed to >>>
"(4) A special written report should be sent by mail within 30 days to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, of:
(a) Accidantal off-mite ratanna of radinactivity above 10CFR20 timite whether or not the relamaa raniilteA in pronerty damane nersonnel iniurv. or exnosure.
(b) Reportable occurrence as defined in Section 6.6.2 of these
. specifications.
(c) Changes in personnel serving as Vice President For Research and Public Service. the Padiatinn Safety Committee Chair. Reactor Dec.c,mminaionino Committee Chairman Ranctor Safety Committee Chair, Reactor Facility Director, or Reactor Supervisor."
Section 6.7.2., " Routine Reports", has been changed to reflect that the reactor is no longer operating and is being prepared to be decommissioned.
1 (August 2,1999)-
PROPOSED UNIVERSITY OF VIRGINIA DOCKET NO. 50-62 FACILITY POSSESSION-ONLY LICENSE Amendment No. 25 License No. R-66 I. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by the University of Virginia (the licensee) dated March 9,1977, as supplemented by filings dated December 18,1978, January 19, 1979, September 18,1979, July 15,1980, February 12,1981, August 19,1981, March 11,1982, March 19,1982, May 18,1982, June 7,1982, August 27,1982, and August 2,1999 complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will be possessed, but not operated, in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conduced without endangering the health and safety of the public, and (ii) that such activities will be conduced in compliance with the regulations of the Commission;
. D. The licensee is technically and financially qualified to engage in the activities authorized by this possession only license in accordance with the rules and regulations of the Commission; E. The licensee is a nonprofit educational institution and has satisfied the applicable provisions of 10 CFR 140, " Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; F. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and does not involve a significant hazards consideration; G. The issuance of this amendment is in accordance with 10 CFR 51 of the Commission's regulations and all applicable requirements have been satisfied; and
, e
2 H. The possession and disposal of byproduct and special nuclear material, as authorized by this license, will be in accordance with the Commission's regulations in 10 CFR 30 and 70. '
II. Facility Operating License No. R-66 is hereby amended in its entirety to read as follows: i A. This license applies to the light water-cooled and -moderated pool nuclear reactor l owned by the University of Virginia (the licensee), located on the grounds of the University of Virginia at Charlottesville, Albemarle County, Virginia.
B. Subject to the conditions and requirements incorporated herein, the Commission, hereby, licenses the University of Virginia:
(1) 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 at the designated location near Charlottesville, Virginia, in accordance with the procedures and limitations described in the application and in this license.
, (2) Pursuant to the Act and 10 CFR Part 70," Domestic Licensing of Special Nuclear Material," the maximum U-235 possession limits are as follows:
I hiaximum U-23."
(Kilograms) % Enrichment _F_qrm 1
4 < 20% hiaterials testing reactor (hfTR)-type fuel i 1 Any Fission chambers, flux foils, and other forms l used in connection with the reactor (3) Pursuant to the Act and 10 CFR Part 30," Rules of General Applicability to Licensing of Byproduct hiaterial" at the Reactor Facility, to possess and store 2,000 curies of cobalt 60; to possess and store 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."
l C. This license shall be deemed to contain, and be subject to, the conditions specified l in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Sections 50.54 and 50.59 of10 CFR Part 50, and Section 70.32 of l
10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now, or hereinafler in efTect, and is subject to the additional conditions specified below:
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i (1) Maximum Power Level The University of Virginia will not load the reactor core and not operate the reactor.
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 25 are hereby incorporated in the license. The University of Virginia shall operate the facility in accordance with the Technical Specifications.
(3) Physical Security Plan The licensee shall maintain and fully implement all provisions of the Commission's approved physical security plan, including amendments and changes made pursuant to the authority of10 CFR 50.54(p). The <
approved security plan consists of documents withheld from public l disclosure pursuant to 10 CFR 2.790, entitled " University of Virginia Nuclear Reactor Facility Physical Security Plan (July 1980)," submitted by letter dated July 15,1980, as revised by letters dated February 26,1981 and July 29,1981.
This license is efTective as of the date ofissuance and shall expire at from the date ofissuance.
FOR THE NUCLEAR REGULATORY COMMISSION Date ofIssuance:
Enclosure:
Appendix A - UVAR Technical Specifications, August 2,1999 1