ML20236Q575

Application for Amend to License R-67,revising Section 8.0 of Mark F Triga TS to Be Consistent W/Mark I Reactor TS

ML20236Q575
Person / Time
Site:	General Atomics
Issue date:	07/16/1998
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
ML20236Q578	List: ML20236Q575 ML20236Q579
References
38-2900, NUDOCS 9807200347
Download: ML20236Q575 (3)

Text

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i ggNERAI, AT'EMWCW

! July 16,1998 38-2900 VIA PRIORITY MAIL SERVICE Document ControlDesk ATTN: Mr. Alexander Adams, Jr., Senior Project Manager

Non-Power Reactors & Decommissioning Projects Directorate 1

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Docket No. 50163; Facility License R-67: Request for TRIGA@ Mark F Technical Specification  !

! Amendment Regarding Safety Committee

Dear Mr. Adams:

, As you know, General Atomics (GA) received a possession only license amendment (POLA) to its Mark F TRIGA l Research Reactor License R-67 in March 1995. Similarly, GA received a POLA to its Mark l TRIGA reactor in October 1997. The technical specifications for the Mark F reactor, which were last revised in 1995, refer to the " Criticality Safeguards Committee (CSC)," a TRIGA oversight committee. The more recently revised (1997) Mark i TRIGA reactor

. technical specifications were re-written to replace reference to the CSC with reference to the " Criticality and Radiation Safety Committee (CRSC)," a standing GA committee. This has resulted in an unwanted inconsistency between the technical specifications for GA's two TRIGA reactors, as well as an unwarranted burden on GA's limited resources.

Therefore, GA requests your approval of the attached proposed revisions to Section 8.0 of the Mark F TRIGA technical specifications " Administrative Requirements." The proposed revisions will make the Mark F technical specifications consistent with the technical specifications of the Mark I reactor. That is, both documents will refer to GA's CRSC instead of each to a different committee.

, Enclosed are the proposed revised technical specifications preceded by a brief description of, and justification for,the revision.

I l

l GA appreciates your assistance in considering this request and is hopeful of an expeditious approval. If you i have questions or require additional information conceming the above, please contact me at (619) 455-2823.

! Very truly yours, ,

w-Dr. Keith E. Asmussen, Director

\

f Licensing, Safety and Nuclear Compliance

Enclosures:

Description of Requested Changes ,[

Mark F Technical Specifications Revised Pages 7(a) & 8 9007200347 980716 '

PDR ADOCK 05000163 P PDR  ;

3550 GE NE RAL ATOMICS COURT, SAN DIEGO. CA 92121 1194 PO BC 85608. SAN DIEGO, CA 92186 5608 (619)455 3000

Attachment to GA Letter No. 38-2900 July 16,1998 - Page 1 Reauested Amendments to Technical Spec 3fications for GA's Mark F TRIGA@ Reactor GA wishes to amend the Mark F (R-67) techn! cal specifications which address administrative requirements. The proposed revisions will make the subject technical specifications consistent with the corresponding Mark I (R-38) technical specifications. The proposed revision consists of:

A. Adding " Organization" as a title to Section 8.1; editing Section 8.1 to replace the word " operation" with " possession," to be consistent with the possession only license amendment; and deleting the last two sentences - which are replaced by corresponding revisions in new Sections 8.2c and 8.2b, respectively, B. Combining old Sections 8.2 and 8.3 into a new Section 8.2 (a through d), adding

" Criticality and Radiation Safety Committee" as the title of Section 8.2; revising the text to be consistent with the replacement of the TRIGA Criticality Safety Committee (CSC) with GA's Criticality and Radiation Safety Committee (CRSC), and C. Replacing the old Section 8.4 with a new Section 8.3 and adding " Written Procedures" as the title of Section 8.4.

The above revisions, in affect, replace the old " Administrative Requirements" technical specifications of the Mark F reactor (R-67) with the corresponding " Administrative Controls" technical specifications of the Mark I reactor (R-38), i.e., Sections 9.2 and 9.3. In summary, the last two sentences of the old Section 8.1 and the old Sections 8.2 and 8.3 are replaced with a new Section 8.2. The old Section 8.4 is replaced with the new Section 8.3. Note: as mentioned above, the new Sections 8.2 and 8.3 parallel the NRC-approved Mark I (R-38) technical specification Sections 9.2 and 9.3.

The proposed revised technical specifications are attached to this enclosure. The following discussion provides the justification for the proposed revisions; the same justification as applied to the same revisions that were approved by NRC for the Mark I (R-38) technical specifications:

The term " safe operation"in the introductory paragraph of TS 8.1 was changed to " safe possession" to reflect the POLA status of the reactor.

It is proposed to replace the TRIGA Criticality Safety Committee (CSC) with GA's corporate Criticality and Radiation Safety Committee (CRSC). The CRSC, is a GA corporate standing committee, whose charter and authority to function are provided through the GA corporate Company Policy Manual. The CRSC has oversight over all i

laboratories and facilities at GA where radioactive material, special nuclear material or radiation producing machines are used or stored. Its membership includes specific expertise relevant to all aspects of safe possession, storage and handling of TRIGA*

fuel. The proposed changes to TS 8.2 reflect the charter of the CRSC, and mirror the requirements for the present TRIGA Criticality Safeguards Committee which reviews TRIGA reactor operations.

I

Attachment to GA Letter No. 38-2900 July 16,1998 - Page 2 It should also be noted that with the withdrawal of authorization to operate GA's reactors I (Licenses R-38 and R-67), the requirement of an oversight committee to cversee reactor operations is no longer applicable.

The CRSC audit frequency is proposed to be reduced from quarterly to annually to be i commensurate with the change in reactor status from operable to incapable of operation and the issuance of a possession only license amendment (POLA). The quarterly audit frequency was warranted while the reactor was still operable due to the various l conditions the reactor experienced, i.e., pulsing, steady-state power operations and J shutdown. The likelihood of off-normal conditions that would be detected by CRSC audits were certainly greater under normal operations than under the POLA condition, which is shutdown and defueled. Accordingly, an annual CRSC audit frequency was determined to be adequate under the static POLA conditions. This audit frequency is ,

consistent with the existing CRSC audit policy. l The proposed TS 8.3 is consistent with the existing TS's and allows the Physicist-in-Charge to make temporary changes to procedures. This allows flexibility in the possession of the reactor if minor deviations from procedures are needed. l The proposed technical specification revisions are all appropriate for and consistent with the fact that GA will not conouct reactor operations, but will only possess the reactor j under its POLA. In fact, the Mark I and the Mark F reactors have both had all fuel  ;

removed from them.  !

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