ML20212G420
| ML20212G420 | |
| Person / Time | |
|---|---|
| Site: | General Atomics |
| Issue date: | 10/29/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20212G407 | List: |
| References | |
| NUDOCS 9711060173 | |
| Download: ML20212G420 (12) | |
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S UNITED STATES f
,j NUCLEAR REGULATORY COMMISSION o
't WASHINGTON, D.C. 3066641001 s'...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 35 TO FACILITY LICENSE NO. R 38 GENERAL ATOMICS DOCKET NO. 50-89
1.0 INTRODUCTION
By letter dated December 17,1996, as supplemented on April 25, and August 18,26, and 29,1997, General Atomics (GA or licensee) submitted a request for amendment to Amended Facility License No. R 38 and Appendix A, " Technical Specifications for the Torrey Pines TRIGA K.:. I Reactor." The requested changes would remove authorization from the license to operate the reactor, authorize possession only of the reactor, and change the Technical Specifications (TSs) to remove or modify operational TSs that are not needed for l
possession only status. The TRIGA Mark l Research Reactor (Mark l)is on the same site as the TRIGA Mark F Research Reactor (Mark F). The Mark F ivactor license (License No.
R-67, Docket No. 50-163) was amended on March 22,1995, to authorize possession only of the reactor. The licensee has requested changes to the Mark Ilicense that reflect the approved wording of the Mark F license to the extent practicable.
2.0 EVALUATION 2.1 Introduction GA has requested that the license for the Mark I be amended to remove authorization to operate the facility because there is not sufficient foreseeable future utilization of the 4
reactor to warrant the costs of maintaining the reactor in an operable status, in addition, the licensee has requested the amendment of certain TSs that are associated with the operable reactor to remove requirements ncs necossary for a reactor in possession-only status.
The licensee has proposed that the licenst amendment be effective 30 days from the date of issuance. GA commits to permanently cease operation when the amendment becomes effective. The 30-day window wi'l allow the licensee to make any necessary changes to the reactor to be in a possession-only configuration when the license amendment becomes effective.
The reactor in possession-only configuration will be incapable of achieving criticality under all environmental conditions. All fuel would have been removed from the core and placed into approved fuel storage 'acilities. Fuel will not be retumed to the reactor grid plate after it is removed.
9711060173 971029 PDR ADOCK 05000089 P
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2 The proposed license amendment does not change any TS requirements for fuel storage. Fuel will be moved and stored in accordance with the existing TSs and GA procedures until removed from the site. The licensee is able to transfer fuel from the Mark I to the Mark F under the current licenses and procedures. Some Mark I fuelis currently stored in the Mark F fuel storage facilities. The fixed site physical protection plan and radiological contingency plan will j-continue in place without modification.
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TSs relevant to the safety of the shutdown reactor will continue in effect. This includes TSs conceming minimum shutdown margin, pool water quality, radiation monitoring, and fuel j
storage.
The licensee has proposed changes to TSs to remove wording from the TSs not applicable to a possession-only status. TSs proposed to be removed from the license are those requiring periodic inspection of fuel, control rods, and the trans:ent rod drive cylinder and associated air i
supply system; those requiring periodic measurements to verify control rod scram times; those requiring periodic calibration of reactor power measuring channels; and those administrative TSs related solely to reactor operation. The licensee has proposed changes to the definitions of reactor shutdown, reactor secure, and reactor operation to make these definitions consistent i
with the proposed possession-only status.
2.2 Changes to License Conditions l
The licensee has proposed changes to paragraphs 1.6.,1.D., and 1.E. of the license to remove i
reference to operation of the facility. These paragraphs currently read:
1.C.
The facility will operate in conformity with the application as amended, the provisions of i
the Act, and the rules and regulations of the Commission; l
1.D.
There is reasonable assurance (i) that the activities authorized by the operating license l
can be conducted without endangering the heahh and safety of the public, and (ii) that j
such activities will be conducted in compliance with the regulations in this chapter; 1.E.
The applicant is technically and financially qualified to engage in the activities authorized j.
by the operating license in accordance with the regulations in this chapter, it is proposed by the licensee that these paragraphs be amended to read:
1.C.
The facility will be possessed in conformity with the application as amended, the -
provisions of the Act, and the rules and regulations of the Commission; 1.D.-
There is reasonable assurance that the reactor facility can be possessed (i) without l
endangering the health and safety of the public and (ii) in compliance with the regulations in this chapter; i
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4 1.E.
General Atomics is technically and financially qualified to possess the facility in accordance with the regulations in this chapter; t
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k' 3-4 The licensee has requested amendment of paragraph 2.B. of the license. Paragraph 2.B.
. currently reads:
B.
Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the General Atomics:
(1) Pursuant to Section 104c of the Act and 10 CFR Chapter I, Part 50 -
" Licensing of Production and Utilization Facilities", to possess, use and i
operate the reactor as a utilization facility at the designated location at San j.
Diego, California, in accordance with the procedures and limitations described in the application and in this license.
i' (2) Pursuant to the Act and 10 CFb '" er 1, Part 70 "Special Nuclear i
Material", to receive, possess a
, Jp to 5.0 kilograms of contained uranium-235 in connection with operation of the facility.
l (3) Pursuant to the Act and 10 CFR Chapter I, Part 30 " Rules of Genera!
Applicability to Licensing of Byproduct Material", to possess, but not to separate such byproduct material as may be produced by operation of the facility.
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GA has proposed amending paragraph 2.B. to remove reference to operation of the facility:
B.
Subject to the conditions and requirements incorporated herein, the Commission hereby licenses General Atomics:
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(1) Pursuant to Section 104c of the Act and 10 CFR Chapter I, Part 50 -
" Licensing of Production and Utilization Facilities", to possess, but not i
operate, the reactor at the designated location at San Diego, California, in accordance with the procedures and limitations described in the appiication i
and in this license.
(2) Pursuant to the Act ano 10 CFR Chapter I, Part 70 " Domestic Licensing of Special Nuclear Material", to receive and possess up to 5.0 kilograms of i
contained uranium-235 in connection with possession of the facility, and to i
possess but not separate special nuclear material such as may have been produced by past operation of the reactor.
(3) Pursuant to the Act and 10 CFR Chapter I, Part 30 " Rules of General l
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.
Paragraph 2.C.(2) reads in part:
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. d The licensee shall operate the facility in accordance with the Technical Specifications.
The licensee has proposed amending part of this paragraph to remove reference to operation by having the paragraph read:
The licensee shall possess the facility in accordance with the Technical Specifications.
The staff finds these changes to license conditions acceptable because they remove reference to reactor operation and are consistent with the possession-only status requested by the licensee.
The licensee has proposed deleting paragraph 2.C.(1) of the license, which describes the maximum power level and pulse reactivity insertion of the reactor. The wording of Paragraph 2.C.1. proposed for deletion:
(1) Maximum Power Level The licensee may operate the reactor at power levels not in excess of 250 kilowatts i
(thermal) and, in the pulsing mode, with reactivity insertions not to exceed $3.00.
This change is being requested to remove the authority to operate the reactor from the license.
The staff finds this change acceptable beccuse it is consistent with the format of a possession.
only license amendment and removes authority to operate the reactor from the license.
l GA has requested the add; tion of a new license condition 2.C.(4) that states:
(4) Fuel Storace l
So long as General Atomics possesses the reactor in accordance with the Technical l
Specifications as amended, no fuel shall be stored la, or moved into, the reactor core structure.
Because this proposed change helps to ensure that the reactor will not achieve criticality again, l
it is acceptable to the staff.
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2.3 Changes to Technical Specifications The licensee has requested that the requirements of several TSs be deleted from the license to reflect the possession-only status. One TS proposed for deletion is TS 4.4, which requires fuel element inspection. This TS required periodic inspection of fuel elements to ensure that steady-state operation and pulcing was not damaging the fuel cladding, and to remove fuel elements from operation that had excessive bending, elongation, or cladding defects. Because the reactor will not be operated again, inspecting fuel elements for operational damage ir meaningless. This TS also contains a requirement for physicalinventory of special nuclear material. GA was granted an exemption from the requirements of 10 CFR 70.51(d) on '
j 5-February 6,1992 (Amendment No. 31), which allowed GA additional flexibility in timing of the physicalinventory to meet operational needs. GA is relinquishing this exemption as part of deleting this TS and will conduct physical;nventories of special nuclear material in accordance with the regulations.
4 TS 5.1.3, x iceming maximum scrc,i time and verification of maximum scram time, has been proposed for deletion. This TS is no longer needed because the reactor core will be completely unloaded. Because the reactor will not be operated again, the verification of maximum scram time is meaningless.
TS 5.1.4, conceming visualinspection of control rods for signs of deterioretion, has been proposed for deletion. This TS is no ionger needed because the reactor core will be unloaded and the control rods are no longer needed to maintain the reactor subcritical.
TS 5.1.5, concerning functional checks of the transient rod and inspection and maintenance of the transient rod, has been proposed for deletion. This TS is no longer needed because the reactor will never again be pulsed, the reactor core will be unloaded, and the control rods are no longer needed to maintain the reactor suberitical.
TS 5.2.5, concerning calibration of reactor power measuring channels, has been proposed for deletion. This TS is no longer needed because the reactor will not be operated again.
Meeting these TS 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.
The licensee has proposed amending the definitions nf reactor shutdown, reactor secured, and reactor operation. These definitions currently read:
1.1 Reactor Shutdown i
The reactor is shut down when the reactor is suberitical by at least one dollar of reactivity.
1.2 Reactor Secured The reactor is secured when all the following conditions are satisfied:
(a) The reactor is shut down, (b) Power to the control rod magnets and actuating solenoids has been switched off and the key removed, and 4
(c) No work is in progress involving in-core fuel handling or refueling operations, maintenance of the reactor or its control mechanisms, or insertion or withdrawal 4
of experiments from the core.
1.3 Reactor Operation i
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Reactor operation is any condition wherein the reactor is not secured.
.The licensee has proposed the following wording for the definitions:
s 1.1 Reactor Shutdown
'l Reactor shutdown shall mean that the reactor is subcritical at all times by at least one j
dollar of reactivity.
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1.2 Reactor Secured l
Reactor secured shall mean that condition wherein:
(a) Tne reactor is shut down, and (b) no work is in progress involving handling of fuel, experiments or reactor core related maintenance operations.
l 1.3 Reactor Operation Reactor operation shall mean any condition wherein the reactor is not shutdown, j
The definition of reactor shutdown has been modified to add the phase "at all times" because the reactor will always be subcritical by at least $1.00 of reactivity and thus shut down.
l The definition of reactor secured has been modified to remove the requirement that power to the control rod magnets and actuating solenoids has been switched off and the key removed because the reactor will no longer be operated and the fuel has been removed from the reactor i
core so that the control rods are no longer needed to maintain the reactor subcritical. The definition of reactor secured _has also been modified to remove reference to refueling because the reactor will not be refueled in possession-only status. The definition of reactor secured has i
been modified to remove reference to maintenance of control mechanisms because the reactor -
control mechanisms are no longer needed since the reactor will no longer be operated, the -
. reactor core will be unloaded, and the control rods are no longer needed to maintain *hs reactor subcritical.
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The definition of reactor operation has been modified to refer to the reactor not shut down instead of not secure. The change in definition is made to allow handling of fuel and experiments, and core-related maintenance operations, to be conducted in the subcritical reactor without having the reactor be in or.eration. Some TSs refer to reactor operation but i
these TSs are not necessary for the hand;ing of fuel and experiments or for the conduct of core related maintenarice with the reactor in a permanent suberitical condition.
1 The licensee has proposed changes to TS 1.10. " Reportable Occurrences." These changes would modify the definition to those events that occur during possession instead of operation.
Events that refer to reactor operation, experiments, and changes in reactivity are removed from i
the definition. Because the reactor will not be operated again and fuel will be removed from the I
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reactor core, these changes are acceptable to the staff. The licensee referred to reportable occurrences as abnormal occurrences in several places in the TSs. The licensee has proposed that the term " reportable occurrences" be used consistently throughout the TSs. This is acceptable to the staff because it clarifies the TSs and makes the wording consistent.
The licensee has proposed changes to TS 5.1.2 conceming the reactor control system and minimum shutdown ma. gin. TS 5.1.2 currently reads:
5.1.2 The number and position of operable control rods, at least one of which shall be a standard control rod, and their respective worths shall be such as to make the reactor tuberitical by at least 50 cents at all times, even with the most reactive rod stuck out.
The licensee has proposed that TS 5.1.2. read:
5.1.2 No reactor fuel elements or control elements with fuel followers shall be located in, stored in, or moved into, the reactor core structure.
The proposed wording ensures that a'i # Jet will be removed from the reactor while in possession-only status and is acceptable to the staff.
The licensee has proposed changes to TS 5.2.3 conceming radiation monitoring systems. The TS currently reads:
5.2.3 The following monitoring systems shall be operable during reactor operation or when work is done on or around the reactor core. (For periods of time when maintenance or repair to the radiation monitoring systems is being performed, the intent of this specification will be satisfied if the installed system is replaced as needed with alternative or portable gamma sensitive instruments having their own alarms or which shall be kept under visual observation.):
(a) An area radiation monitoring system capable of activating the evacuation alarm.
(b) A cortinuous monitoring system for airborne radioactivity having a readout and audible alarm which can be heard in both the reactor and control rooms.
(c) The monitoring systems in a. and b. shall be calibrated annually and their set points verified weekly.
The licensee has proposed new wording for TS 5.2.3 reads:
5.2.3 Radiation monitoring systems shall be operable as follows:
(a) An area radiation monitoring system capable of activating an evacuation alarm.
8-(b) When the reactor is not secured, a continuous monitoring system for airbome activity having a readout and audible alarm which can be heard in the reactor and control rooms.
These systems shall be calibrated annually and their set points verified monthly. For periods of time for maintenance or repair to the above systems, or during periods of other forced outages, the intent of this specification shall be satisfied if the installed system (s) is replaced with appropriate attemative or portable radiation monitoring system (s).
The TS has been changed to remove reference to operation of the reactor. The proposed TS is more restrictive than the current TS. The current TS does not require radiation monitoring systems to be operable when the reactor is not operating or when work is not done on or around the reactor core. The proposed TS requires an area radiation monitor to be operable at all times Because the proposed TS adds radiation monitoring requirements to the TS when the reactor is shut down, it is acceptable to the sta'f.
The licensee has proposed a new section 6.4, " Fuel Storage," to the TSs. The proposed section reads:
6.4 Fuel handling tools or devices shall be stored in a secure manner such that their use can be limited to authorized movements of fuel.
The TS was proposed along with License Condition 2.C.(4) to ensure that fuel will be removed from the grid plate and not returned. This proposed TS provides additional assurance that movements of fuel will be controlled and is, therefore, acceptable to the staff.
The licensee has proposed a change to TS 9.1, " Organization," to replace reference to reactor operation with reactor possession. This change is acceptable to the staff because it is consistent with the change in the reactor status to possession only.
The licensee has proposed adding a legend to the organizational chart to define lines of communication and linet or reporting. The licensee has also proposed additions to the chart that show the reporting of the health physicist and the Criticality and Radiation Safety Committee up to the Vice President level. These changes are acceptable to the staff becam,e they clarify the organizational chart.
The licensee has proposed changes to TS 9.2, " Review Committee," changing the committee responsible for reactor safety from the " Criticality Safeguards Committee" to the " Criticality and Radiation Safety Committee." This is a corporate-wide committee that oversees alllaboratories and facilities at GA at which rsdioactive material, special nuclear material, and radiation-producing machines are used or stored. The expertise of the Criticality and Radiation Safety Committee encompasses that of the Criticality Safeguards Committee, which assures that there is no decrease in effectiveness of the committee. It is proposed that the title of this section be changed to Criticality and Radiation Safety Committee, that reference in the TSs to the Criticality Safeguards Committee be changed wherever it appears, including TS 9.4 and the organizational chart. The proposed changes to this section of the TSs remove reference to
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reactor operation and adopt the charter requirements of the Criticality and Radiation Safety Committee, which are similar to those of the Criticality Safeguards Committee. The licensee has also proposed changing the audit frequency for the facility from quarterly to annually.
TS 9.2 a., b., and c., currently read:
a.
There shall be a Criticality Safeguards Committee which shall review the TRIGA reactor operations. This Committee shall be composed of not less than four persons who are not directly involved in the TRIGA reactor operations and who are selected by the Vice President, or his designated attemate, identified in Section 9.1. The Committee shall collectively possess expertise in all areas of reactor operations and reactor safety.
b.
The operations of the Criticality Safeguards Committee shall be in accordance with a written charter including provisions for:
1.
Meeting frequency 2.
Voting rules 3.
Quomms 4.
Method of submission and content of presentations to the Committee 5.
Use of sybcommittees 6.
Review, approval, and dissemination of minutes c.
The Criticality Safeguards Committee shall review and approve safety standards associated with operation and use of the Facility. The Criticality Safeguards Committee or a subcommittee thereof shall audit reactor operations at least quarterly, but at intervals not to exceed four months.
The licensee has proposed changing these sections of the TS to read:
a.
There shall be a Criticality and Radiation Safety Committee (CRSC) which shall review activities of the facility to assure criticality and radiation safety. The Committee shall be composed of at least four members selected by the cognizant Vice President, or a designee, considering their experience and education with regard to the various aspects of nuclear physics, chemistry, radiological health and statistics, as well as appropriate experience in other disciplines such as metallurgy and engineering. Subcommittees shall be oppointed by the Chairman of the CRSC. The subcommittee assigned the responsibility for reviewing facility operations shall not hiive thereon person (s) who are directly involved with that facility.
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The Criticality and Radiation Safety Committee shall be in accordance with a written charter including provisions for:
1.
Hold meetings or audits at least annually; special meetings may be called by subcommittees of the CRSC or by the Chairman of the CRSC at times when such meetings are deemed appropriate.
2.
Have a quorum when a majority of the members attend.
3.
Prepare minutes or audit findings of the CRSC meetings by the Chairmen or his designee Evidence of approval of the participating members of the Ch0C shall be ebtained before distribution, c.
The Criticality and Radiation Safety Committee, or subcommittee, shall review and approve safety standards associated with possession of the Facility. The CRSC or a subcommittee thereof shall audit the Facility annually but at intervals rot to exceed fifteen (15) months.
The stafi has determined that it is acceptable to change reference to the facility review committee from the Criticality Safeguards Committee to the Criticality and Radiation Safety Committee. The responsibilities and charters of the committees are similar and these changes reflect the change in status of the facility to possession only. The reduction in frequency of facility audits is also acceptable to the staff. The frequency is commensurate with the change of the facility status to possession only and is within the guidance given in American National Standard ANS!'?.JS-15.1-1990, "The Development of Technical SpecJications for Research Reactors."
TS 9.2.d.4. and 5. conceming responsibilities of the review committee currently read:
4.
Review of the operation and operational records of the facility; 5.
Review of abnormal performance of plant equipment and operating anomalies; and The licensee has proposed changing these TSs to remove the reference to facility operations, and to have the TSs read:
4.
Review of facility recorG 5.
Review of abnormal performance of plant equipment and other anomalies; and Because these changes remove reference to facility operations and are consistent with possession-only status, the staff finds these changes acceptable.
TSs 9.3.a. and f. which are part of the TS, ' Written Procedures," read:
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Testing and calibration of reactor operating instrumentation and controls, l
control rod drives, and area radiation monitors and air particulate monitors.
f.
Routine maintenance of the control rod drives and reactor safety and interlock systems or other routine maintenance that could have an effect on reactor safety.
The licensee has proposed changing these TSs by removing reference to systems needed for reactor operation and control rod drives to read:
a.
Testing and calibration of instrumentation, controls and radiation monitors necessary to meet the requirements of the Technical Specifications, f.
Maintenance of systems necessary for assuring the integrity of the fuel or otherwise maintaining the reactor in POLA status.
The licensee has also proposed removing reference to reactor operation in the introduction to TS 9.3. Bec.ause these changes remove reference to reactor operation and the control rod drives that at i not needed with the reactor core unloaded, the staff finds that these changes are consistent wi h possession-only status and are acceptable.
TS 9.3 reac s in part:
Substantive changes to the above procedures shall be made only with the approval of the Criticality Safeguards Committee. Temporary changes to the procedures that do not change their original intent may be made by the Physicist-in-Charge. All such temporary changes shall be documented and subsequently reviewed by the Criticality Safeguards Committee.
The licensee has proposed changing this TS Changes which alter the original intent of the above procedures shall be made only with tha approval of the Criticality and Radiation Safety Committee (CRSC).
Temporary changes to the procedures that do not change their original intent and do not constitute an unreviewed safety question (as defined in 10 CFR 50.59) may be made by the Physicist-in-Charge. All such temporary changes shall be documented and subsequently reviewed by the CRSC.
The licensee has also proposed deleting TSs 9.3b and e., which refer to written procedures for reactor startup, operation, and shutdown, and control rod removal or replacement. The staff finds these changes acceptable because the reactor will not be operated again and the control rods are no longer needed to maintain the reactor in a suberitical condition.
The licensee has proposed changes to TS 9.6, " Reporting Requirements," to update the points of contact at the NRC. This change is acceptable to the staff because it updates the TS and is administrative in nature.
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The licensee has proposed changes to TS 3.6 e, which requires submittal of an annual report about reactor operation, and has added a new TS,9.6 f, which requires that an annual written report be submitted to NRC about the facility while it is in possession-only status. The licensee has proposed deleting reporting requirements that relate to reactor operations. Because the reactor will not be operated again, these changes are acceptable to the staff.
l 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
' possess but not operate" status of the facility is acceptable because the reactor will be placed in a permanent suberitical state and tha fuel will be stored in accordance wlth the TSs, procedures, and the fixed site physical protection 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 amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released off i
site, and there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
1 4.0 QONCLUSION The staff concludes that amending this license to a possession-only status is appropriate. The staff has further concluded, on the basis of the considerations discussed above, that (1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously evaluated, or create the possibility of a new or different kind of accident 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 activities, 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 common defense and security or the health and safety of the public.
Principal Contributor: A. Adams, Jr.
Date: October 29, 1997
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