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University of Massachusetts Lowell, Draft Uml Audit Question Summaries
	ML20275A090
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Site:	University of Lowell
Issue date:	09/29/2020
From:	Edward Helvenston; NRC/NRR/DANU/UNPL
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	Helvenston E
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ML20275A088	List: ML20275A089; ML20275A090;
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Audit Questions: Instrumentation and Controls (2017 audit)

(Note: Except where indicated otherwise, these I&C audit questions for the 2017 audit refer to the UMLRR open items list (ADAMS Accession No. ML17193A373), and RAI responses submitted by letter dated October 18, 2019 (ADAMS Accession No. ML19291C293), in response to the NRC staffs RAI dated July 19, 2019 (ADAMS Accession No. ML18092B090).

The 2017 audit questions (i.e., open items) and responses/resolutions are summarized in this audit report. Refer to the UMLRR open items list (ADAMS Accession No. ML17193A373) for the full text discussion of the audit questions and responses/resolutions.)

1. The UMLRR SAR is not clear which systems and descriptions are existing or are new on the I&C system in Ch. 7. The NRC staff requests an updated SAR with change bars or an erratum in a LRA supplement to annotate actual hardware (HW) and software (SW) changes.

UML stated it would provide an addendum or errata stating the changes to be made by license renewal for the I&C system. This was provided in subsequent responses to RAIs.

2. The NRC staff requested to review documentation regarding the design criteria and bases for the General Atomics (GA) NMP systems.

During the Audit, the NRC staff noted that the GA documents a. through n. below were listed as being applicable to other facilities, not including the UMLRR. The NRC staff reviewed the following documentation regarding the design criteria and bases for the GA NMP, NLW, and NLX systems:

a) T3322000-1AT_Rev A NLW-1000 Acceptance Test Procedure b) T3322000-RTM_Rev A NLW-1000 Traceability Matrix - easy read c) T3322000-RTM_Rev A NLW-1000 Traceability Matrix d) T3401000-1AT_Rev A NMP-1000 Acceptance Test Procedure e) T3401000-RTM_Rev A NMP-1000 Traceability Matrix - easy read f) T3401000-RTM_Rev A NMP-1000 Traceability Matrix g) T9S900D940-SYR_Rev A NMP-1000 System Requirements Specification (SyRS) h) T9S900D941-SRS, NMP-1000 Software Requirements Specification (SRS) i) T9S900D950-SYR_Rev A NLX-1000 SyRS j) T9S900D951-SRS, NLX-1000 SRS k) T9S900D980-FME Rev A, NMP-1000 Failure Modes Effects Analysis l) 20130207001-RPT Rev 2, NetBurner-MOD54415 Validation Summary Report m) LPC E117-1017 Rev 1, NMP1000 operations and maintenance manual n) T3401000-1UMB, NMP-1000 user manual o) Letter from General Atomics to Tom Regan (UML) explaining how to modify the NMP-1000 to accommodate dual-mode operations, dated February 3, 2014 p) GEN2 NMP-1000 Linear Power Channel Installation Plan, Revision 0.

q) UML Control Doc. No. RF-RO-7B, Reactor Checkout, Revision, dated August 17, 2015 r) Evaluation under 10 CFR 50.59; screen 16-01 Enclosure

In its response to RAI-7.13.b, UML stated it received an electronic communication dated June 20, 2017, in which a representative of GA confirmed the UMLRR NMP1000 modules are identical to the INL NMP1000 modules detailed in the applicable GA documentation.

Confirmation was also provided by GA that the documents a. through n. pertain to the UMLRR, by letters dated July 26, 2017, and January 8, 2020 (ADAMS Accession Nos.

ML17249A080 and ML20017A155, respectively). However, UMLs response to RAI-7.4.a states that the GA documentation for the NLW and NLX nuclear instrumentation no longer apply to the UMLRR. An open item was carried forward to the 2020 audit for confirmation to provide documentation for the replacement TFS Log power and period meter (PPM) system.

3. The NRC staff noted that GA documentation is marked as proprietary. All design documentation should be docketed when used by the NRC in the licensing determination and should be made publicly available unless the information is deemed to meet the criteria under 10 CFR 2.390 for withholding from public disclosure.

UML stated it would submit a request for withholding for any document submitted to the 50-223 docket with an affidavit from the content owner justifying withholding. By letters dated July 26, 2017, and January 8, 2020 (ADAMS Accession Nos. ML17249A080 and ML20017A155), the NRC staff received the 10 CFR 2.390 withholding requests, including redacted versions of some of the documentation from General Atomics related the UML docket 50-223.

4. The NRC staff requested that UML provide a system performance analysis consistent with the guidance in NUREG-1537, Section 7.2, to include accuracy, reliability, adequacy and timeliness of I&C system action, trip setpoint drift, quality of components, redundancy, independence, and single failure criteria with functional and environmental design information that compares the system design requirements and describes how they are met by the new components of the I&C system.

In its RAI response, UML provided a description of how the I&C systems meet the applicable design criteria guidance of NUREG-1537, Section 7.2 for the reactor protection system.

Additional information was provided for the TFS Log PPM by letter dated April 10, 2019 (ADAMS Accession No. ML19100A273).

5. UMLRR should provide information that compares the system design requirements are met by the new components of the I&C system, for system performance. For example, UML should provide information on vendor or facility programs for equipment qualification, including electromagnetic compatibility, temperature, pressure, radiation, relative humidity, power surges, and operational cycling.

In its RAI response, UML provided a description of how the I&C systems meet the applicable design criteria guidance of NUREG-1537, Section 7.2, for equipment qualification.

Additional information was provided for the TFS Log PPM by letter dated April 10, 2019 (ADAMS Accession No. ML19100A273).

6. UMLRR should explain how potential access control and cyber security vulnerabilities (physical and electronic) are adequately addressed for the digital safety system software and how administrative controls prevent/limit unauthorized physical and electronic access to critical digital assets.

UML stated that facility procedures require password management (to include having passwords that are strong and are changed when people are no longer on staff), key management, and chain of custody. UML also stated that the maintenance port on the NMP-1000 will be disabled, and that there is no firmware/software that is modified by UML staff. UML also stated that its processes and controls for changing setpoints will not change for the NMP-1000. Additionally, in its RAI 7.6 response, UML provided an example in the CP 2-04, Linear Power Channel Check and Calibration, procedure of required administrative controls to prevent/limit unauthorized access through supervisory notification for equipment changes. This procedure requires the Chief Reactor Operator or Reactor supervisor to perform or supervise changes to NMP-1000 calibration parameters.

7. The NRC staff requested additional documentation specific to software requirements, development, quality assurance (QA), configuration management (CM), and testing for the NMP-1000s.

UML stated it would provide documentation and correspondence from GA that would be submitted under UMLs oath or affirmation, with confirmation from UML that the documentation and correspondence was applicable to the UMLRR. Confirmation was provided by GA that the NMP-1000 documents pertained to the UMLRR. However, UML did not state that the referenced GA documentation applies to UMLRR and the open item was carried forward to the 2020 audit. (See audit item No. 2 above for documents reviewed by the NRC staff.) Additionally, a request for similar documentation for the TFS Log PPM was included in the 2020 audit.

8. UML should describe how the verification and validation activities (V&V) were performed by individuals or groups with appropriate technical competence in an organization separate from the development and program management organizations. UMLRR should provide documentation that shows the plan for the V&V tasks, and when available, the results confirming V&V has been successfully accomplished.

UML provided GA documentation for the NMP-1000 Acceptance Test Procedure and the NMP-1000 [requirements] Traceability Matrix that appropriately traces safety system requirements from design implementation to implementation and vendor testing. In its RAI response, UML similarly provided procedural examples of the required installation and testing of the second generation NMP-1000 multi-range linear power module (Gen2 NMP-1000 Linear Power Channel Installation Plan) and the procedures for calibration of NMP-1000 parameters (UML Procedure, CP-2-04, Linear Power Channel Check and Calibration.).

UML also provided documentation for NRC staff review to demonstrate assurance that the required computer system hardware and software are installed in the appropriate system configuration, including a program to ensure that the correct version of the software/

firmware is installed in the correct hardware components (Control Doc. No. RO-7, Reactor checkout). Additionally, in its RAI response, UML described how the software and hardware for other I&C changes, such as the display upgrades were integrated; and how UML verified the required system hardware and software is installed in the appropriate system configuration. The NRC staff noted that the calibration and checkout procedures both described parameters that should be under configuration control (i.e., under a CM program).

However, no details were provided on how these parameters are controlled. The NRC staff request to review the UML CM program or procedure was carried forward to the 2020 audit.

9. UML should describe the actual methods being used at both the vendor and UMLRR to ensure software CM includes a determination that any software modifications, including firmware, during the design process, and after acceptance of the software for use, will be made to the appropriate version and revision of the software.

During the Audit, the NRC staff reviewed the software CM plan, QA plan and software development plan. UML staff confirmed the NRC staffs observation (from its document review) that GA would do all software installs as stated in the NMP-1000 user manual. In its RAI response, UML stated that software/firmware changes are not readily accomplished by the UML staff and normally would be performed by the manufacturer. If the manufacturer should neglect to communicate that a change was made during service or repair, the surveillance required by TS 4.0B and the UMLRR CM Program would determine if the software/firmware version number has changed, triggering a review.

10. UML should provide a description of any applicable program used to ensure that the correct version of the software/firmware is installed on the correct hardware components.

UML stated that verification of the software version will be added by UML Reactor checkout procedure for the NMP-1000 software version. UML also stated that the TFS Log PPM is completely analog. In its RAI 7.6 response, UML stated that the TSs require RSSC review of proposed changes to the facility systems or equipment, procedures, and operations, including the reactor check out procedure (procedure No. RO-7) verifying the software version.

11. UML should provide evidence that the digital computer system equipment upgrade, including hardware, software, firmware, and interfaces, can perform its required functions per the design basis and design criteria for the UMLRR.

In its RAI response, UML provided evidence of UML/Vendor collaboration for ensuring the NMP-1000 met the requirements for the UMLRR (RAI responses 7.9.a, 7.11, and 7.12).

Additionally, during the audit, NRC staff reviewed specific instructions that GA provided to UML on how to modify the NMP-1000 to specifically accommodate the UMLRR natural circulation (100 kWt) mode. In reviewing the instructions, the NRC staff noted that the linear power modules will utilize two spare trips designed into the trip circuitry and a make-before-break contact design will ensure that switching from natural convection to forced convection does not produce an open circuit fault and the associated scram. UML also indicated that each of the four trips (alarm and scram for both modes) will have independent trip set points.

UML also provided a generic (not specific to UML) document for the TFS Log PPM vendor.

A request for UMLRR-specific documentation for the TFS Log PPM was included in the 2020 audit.

12. UML should provide verification that the testing, calibration, and inspections of the control console instrumentation, display instruments, and safety systems (watchdog timers) for the drives control and process controls displays are sufficient to show that, once performed, they confirm the operability of the related system.

During the audit and in its RAI 7.14 response, UML stated that the proposed TS required verifications include confirming that surveillance test and self-test features address failure detection, that appropriate self-test features (e.g., monitoring memory and memory reference integrity, using watchdog timers or processors, monitoring communication channels, monitoring central processing unit status, and checking data integrity) are

operable, and that appropriate actions are taken upon failure detection (related operator alarm and reactor scram).

13. Because the UMLRR is a 1 megawatt-thermal non-power reactor, a risk-informed or a graded approach may be appropriate in identifying or eliminating design criteria from further consideration. Describe any areas where a graded approach or risk-informed approach was used, if any, and describe and provide justification for grading.

In its response to RAI 7.1, (as opposed to using a graded approach) UML stated that it selected new equipment for the UMLRR that is in wide use at other similar research reactors. For example, the facility procured a wide range logarithmic power/period instrument (model TR-10) from TFS that has been installed and used at several NRC-licensed non-power reactors, including: MURR, RINSC, NCSU, Ohio State University, Penn State University, Texas A&M, Oregon State University, Reed College, MU-Rolla, and UC-Irvine. Similarly, UML stated that the replacement NMP-1000 is a second-generation version of the NMP-1000 currently in use. The replacement NMP-1000 was purchased to the same performance specification as that which is currently installed and in use.

14. UML stated it may propose the TFS Neutron Flux Monitoring Systems in lieu of the equivalent GA NLW1000 system; the TFS system is not described in the UMLRR application for license renewal that includes the proposed I&C upgrade.

In its response to RAI 7.1.a., UML stated a facility staff decision was made not to use the GA logarithmic power/period channel for technical reasons. Instead, UML procured a wide range logarithmic power/period instrument (model TR-10) from TFS. During the audit, UML also stated that they no longer propose to use the NLW intermediate range power channel, and in RAI response 7.4.a., UML stated that the NLW and NLX systems do not apply.

15. The NRC reviewers noted unused code was detected and subsequently removed as noted in 4.2.1.2 of T9S900D980-FME RevA NMP-1000 Failure Modes Effects Analysis. UML should verify and document this unused code was removed from subsequent NMP-1000 units, specifically the one sold to UML.

In its RAI 7.13.a response, UML stated it had received an electronic communication dated July 14, 2017, in which a GA representative confirmed the unused code was removed from all product releases, including the NMP1000 modules procured by UMLRR. The electronic mail was requested for NRC staff review as part of the 2020 audit.

16. The UMLRR safety analysis report (SAR) submitted for license renewal indicates 16 Alarms and Indicators. According to 50.59 screen 16-01, there are 22 alarms and indicators.

UMLRR should update the SAR to indicate the additional alarms and indicators.

UML stated in its RAI 7.3.b response that RAI response Table 7-1 is inclusive of the facility changes associated with I&C. UML included the 50.59 reviews and screens requested by the NRC staff in its RAI, including screen 16-01, in appendix B of its RAI response. (The NRC staff noted that screen 16-01 is dated 2016, after the 2015 license renewal SAR.)

17. The UMLRR SAR describes a failure analysis for components of the I&C system. For example, SAR Section 7.4.1.1.5 describes the output neither increasing or decreasing, then states that the linear power channels operate independently (1 of 2 mode). This description

does not appear to meet the TS requirements for minimum number of channels nor to be a detectable failure (i.e., the system is actually 1 of 1). (See also SAR Section 7.4.1.2.5.)

During the audit, UML stated that the two linear channels (NMP-1000) operate independently of each other, i.e., either channel is capable of scramming the reactor.

However, the TS Table 3.2.3-1, item 2. TS Table 3.2.5-1, item 3 only rely on one of the two channels (do not take credit in SAR or TS for redundancy). Further clarification related to the minimum required power channels and the TSs was carried forward to the 2020 audit (see 2020 audit item 14).

18. Intentionally blank to preserve numbering of Open Items

19. According to 50.59 screen 16-01, there are 6 additional alarms and indicators on the new display panel. UML should describe the consideration given to determine if the human-system interface (HSI) aspects of a display modification have an adverse effect on SAR-described design functions. Potential impacts due to the number and/or type of parameters displayed by and/or available from the HSI should be addressed.

In its RAI response, UML provided a copy of all 50.59 reviews and screens related to the UMLR I&C systems (RAI response Appendix B), and these impacts are considered in the screen.

20. UML is requested to provide copies of relevant 50.59 reviews and screens for the I&C audit In its RAI response, UML provided a copy of all 50.59 reviews and screens related to the UMLR I&C systems (RAI response Appendix B).

21. UML is requested to provide additional information on the watchdog timers, including whether they are required by UMLRR TSs and how they are surveilled.

UML provided explanation of when and how the watchdog timers activate the trip relays in the scram circuit, and information on surveillance of the watchdog timers, in its response to RAI-7.14.

22. UML should provide a diagram depicting the overall trip circuit, showing how each circuit in the train is arranged to ensure a protective system action interrupts the overall scram circuit.

UML provided a diagram in its RAI response. However, the document was not readable.

A follow-on request was carried over to the 2020 audit.

Audit Questions: Technical Specifications (2020 audit)

(Note: Except where noted otherwise, these questions refer to the UMLRR license renewal TSs and RAI responses submitted by letter dated March 5, 2019 (ADAMS Accession No. ML19064B373), in response to the NRC staffs RAI dated November 5, 2018 (ADAMS Accession No. ML18253A088).)

During teleconferences on February 18 and 20, 2020, UML stated that in a follow-up TS submittal (not related to or in response to any specific audit item), it may reorganize TSs 6.6 and 6.7 for clarity and to reduce cross-references. The NRC staff noted that it would need to review any TS changes proposed by UML, in response to the audit items below or otherwise.

During a teleconference on March 10, 2020, UML stated (related to audit items 64, 67, 68, 71, and 74) that it intends references to the facility or reactor facility in the UMLRR TSs to mean all areas controlled under the UMLRR license, consistent with the TS definitions. However, for such references in Section 6 (Administrative Controls) of the TSs, UML stated that it does not consider the use of facility or reactor facility instead of reactor to imply that any UML personnel responsibilities, review requirements, procedure requirements etc., delineated in the TSs be interpreted as having applicability for any purpose other than ensuring nuclear and radiological safety and that NRC requirements are met. For example, UML stated that it would not consider a reference to safe operation of the facility in TS 6.1.2(3) to necessarily include occupational health and safety issues if they do not relate to nuclear or radiological safety, or NRC requirements. UML stated that it may provide follow-up supplemental information (in addition to follow-up submittal information and a follow-up TS submittal it stated it would provide in response to the audit items below) discussing its intended meaning of Section 6 TSs.

1. General: Some of the TS bases appear to need to be updated further to properly reflect the revised TSs and information in the SAR, as supplemented.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal with appropriate corrections and updates to the TS bases.

2. TS definition of Core Configuration: RAI-14.1.2 does not appear to be fully addressed because the definition does not include all components that are or could be potentially located in the UMLRR core grid, for example, radiation baskets, lead void boxes, and grid plugs. Additionally, there is an apparent typographical error in that rod/ should be rod.

During teleconferences on February 11 and 13, 2020, UML stated that it will provide a follow-up TS submittal that adds radiation baskets, lead void boxes, and grid plugs to this definition, and corrects the typographical error.

3. TS definition of Excess Reactivity: RAI-14.1.3 does not appear to be fully addressed because the definition refers to regulating devices and the maximum reactive condition instead of the facility-specific regulating rod and fully withdrawn position, respectively.

Additionally, UML added and with all installed experiments in their most reactive condition to the definition, which does not appear to be appropriate or necessary because UML always needs to continue to meet the TS 3.1.1(1) excess reactivity requirement for any condition or configuration of experiments.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal that uses the facility-specific language and deletes and with all experiments in their most reactive condition.

4. TS definition of Reactor Secured: Item (2)(a) does not appear to be facility-specific because it does not specifically state that all 4 control blades (required by TS 3.2.1(1)) are fully inserted, and because the language or other safety devices are in shutdown position does not appear to be applicable to the UMLRR. Additionally, item (2)(d) appears to include an unnecessary <.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises item (2)(a) to all four control blades are fully inserted, and deletes the < symbol in item (2)(d).

5. TS definition of Research Reactor: RAI-14.1.9 does not appear to be fully addressed because the definition does not specify that the terms research reactor and reactor are used interchangeably. Additionally, the definition appears to contain a typographical error in that -A should be - A.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal that indicates that these two terms are equivalent and corrects the typographical error.

6. TS definition of Research Reactor Facility: The definition does not state that reactor facility, which is used in the TSs, is also equivalent to research reactor facility and facility.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which indicates that these three terms are equivalent.

7. TS definition of Shutdown Margin: RAI-14.1.7 does not appear to be fully addressed because the definition appears to use in the most reactive positions instead of the facility-specific fully withdrawn.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which uses the facility-specific language.

8. TS definition of Surveillance Time Intervals: The language [a]ny extension of these intervals shall be occasional and for a valid reason would appear to allow extension of the maximum allowable intervals. This language should be justified or deleted.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which deletes this language.

9. TS 2.2.2: RAI-14.2.2 does not appear to be fully addressed because there appear to be typographical errors in that Limited in TSs 2.2.2(1), 2.2.2(2), and 2.2.2(3) should be Limiting.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical errors.

10. TS 3.1.1: The title and applicability of TS 3.1.1 do not appear to encompass all included in TSs 3.1.1(1) through 3.1.1(6).

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises the title of the TS 3.1.1 to Reactivity and Core Configuration, or similar wording, and expands the applicability to cover all items in TS 3.1.1.

11. TS 3.1.1(2): The TS appears to use the term regulating blade, but regulating rod is the term defined in the TS definitions.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which uses the term in the TS definitions.

12. TS 3.1.1(4): The TS appears to indicate that UMLRR natural convection operation is at power levels of less than 100 kilowatts-thermal (kWt), but the UMLRR can operate in natural convection mode at steady-state power levels of less than or equal to 100 kWt.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises the less than symbol with a less than or equal to symbol.

13. TS 3.2.2(3): RAI 14.3.14 does not appear to be fully addressed because the TS states that only one control blade shall be withdrawn at a time, but does not clearly indicate that only one control blade shall be able to be withdrawn at a time (i.e., requiring operability of the interlock preventing withdrawal of more than one blade).

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises shall be withdrawn to shall be able to be withdrawn.

14. TS 3.2.3, Table 3.2.3-1, item 2: The TS does not appear to clearly indicate (e.g., with an asterisk or note) that one of the two required power level scrams must come from the log power level (i.e., Log PPM) channel, consistent with the TS 3.2.5 requirement that the log power level channel be one of the operable power level channels.

During teleconferences on February 11 and 25, 2020, UML clarified that it intends to have the log channel, and at least one of the two linear channels, operating and capable of providing a scram when the reactor is operating. UML stated that it will provide a follow-up TS submittal which adds an asterisk to item 2 indicating that at least one of the two required scrams must be provided by each type of channel. UML also stated that it will provide follow-up supplemental information which clarifies the SAR (including SAR Section 7.4.1.1.5) by stating that the linear channels do not operate in a 1 out of 2 mode, but that only one linear channel is required and the second channel provides redundancy to the required channel. Additionally, UML stated that it will provide follow-up supplemental information which states that the required Log PPM channel provides redundancy and diversity to the single required linear channel.

15. TS 3.2.3, Table 3.2.3-1, item 11: The specific setpoint has been removed from the TS, but this does not appear to be acknowledged in the TS submittal. Discuss why the specific setpoint no longer needs to be in the TS and clarify whether the information in SAR Section 3.4 related to the specific setpoint UML uses and the basis for this setpoint is still accurate.

During a teleconference on February 11, 2020, UML stated that it will provide follow-up supplemental information that acknowledges the removal of the setpoint from the TSs, confirms that the information in SAR Section 3.4 is still accurate, and explains that the specific setpoint does not need to be in the TS because it is a nominal value and the scram can continue to serve its purpose without a specific TS-required setpoint.

16. TS 3.2.3, Table 3.2.3-1, item 12: The bridge movement scram is required during both forced and natural convection mode operation, but the requirement for this scram during natural convection operation appears to conflict with the basis for TS 3.2.3, and SAR Table 7-5, which indicates that this scram only occurs during forced convection operation.

During a teleconference on February 11, 2020, UML stated that it will provide follow-up supplemental information correcting the information in the SAR to be consistent with the TS

and indicate that this scram also occurs during natural convection operation. (UML will also update all TS bases as stated under audit item 1.)

17. TS 3.2.3, Table 3.2.3-1, item 13: It does not appear be clear from the TS or information in the SAR, as supplemented, which specific alignment limit switches are subject to this TS requirement.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises the basis for this TS to clearly indicate (by references to the SAR or otherwise) which specific switches are subject to the TS.

18. TS 3.2.4, Table 3.2.4-1, item 2: The TS requires the beam port chamber door scram to be operable during any reactor operation, but this appears to conflict with SAR Section 7.7.9, which states that this scram only occurs when the reactor is operating above 1 kWt.

During a teleconference on February 11, 2020, UML stated that it will provide follow-up supplemental information correcting the information in the SAR to be consistent with the TS and indicate that this scram occurs during any reactor operation.

19. TS 3.2.5: The TS requires that the reactor channels in Table 3.2.5-1 be operable but does not appear to require that the channels be operating, as needed to ensure parameters are continually being measured and information made available to the reactor operator during reactor operation. Additionally, the numbering of the eight items listed in Table 3.2.5-1 appears to be incorrect.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises operable to operating, and corrects the table numbering.

20. TS 3.3: TSs 3.3(1) through 3.3(3) are applicable only during reactor operation, but this does not appear to be appropriate for these TSs given the need to prevent corrosion and detect excess radioactivity in the pool water (from fuel, cobalt-60, or other sources) during any reactor conditions (this also appears to conflict with TS 4.0.A, which does not allow surveillances for TSs 3.3(1) through 3.3(3) to be deferred during reactor shutdown).

Additionally, TS 3.3(3) states that if the radionuclide concentration limit is exceeded, the source of the radionuclide(s) should be identified and corrected, but the applicability of this portion of TS 3.3(3) (i.e., if it is applicable only during reactor operation, or during any conditions) is not clear.

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to make TSs 3.3(1) through 3.3(3) applicable during all conditions, but re-words TS 3.3(4) such that it continues to only be applicable during reactor operation (or as revised by UML in response to audit item 21). Additionally, UML stated that in its follow-up TS submittal, it will revise the averaging period in TS 3.3(1) from two weeks to one month, and delete the second sentence of TS 3.3(3); UML stated that it will also provide follow-up supplemental information that explains its justification for these changes.

21. TS 3.3(4): TS 3.3(4) is applicable only during reactor operation, but it appears that this TS should also be applicable for 3,947 seconds following reactor operation, to ensure the validity of UMLs loss of coolant accident (LOCA) analysis in the SAR, as supplemented.

(However, UML should consider whether a revised TS 3.3(4) prohibiting the pool divider gate from being in position to separate the bulk and stall pools for 3,947 seconds following

reactor operation would need to permit UML flexibility to put the gate in position during that period of time to mitigate an actual LOCA.)

During teleconferences on February 11, 20, and 25, and March 3, 2020, UML stated that it will provide a follow-up TS submittal which either revises TS 3.3(4), or adds an additional TS, to prohibit the pool divider gate from being in position to separate the bulk and stall pools for at least 3,947 seconds following reactor operation if the reactor is in the stall pool.

UML also stated that it will provide follow-up supplemental information (and/or revised TS bases) regarding its basis for the revised TS 3.3(4) or additional TS. UMLs supplemental information and/or revised TS bases will indicate that UML would not consider putting the divider gate in place following reactor operation when the reactor is in the stall pool to be a violation if this action were taken as a mitigating response to a leak in the bulk pool.

UML stated that it is not necessary for TS 3.3(4) to be applicable following reactor operation when the reactor is in the bulk pool. Per TS 3.8, in order for UML to open a beam tube plug while the corresponding beam tube shutter is also open, the reactor must not only be shutdown but also moved to the bulk pool. When the reactor is in the bulk pool, having the divider gate separating the bulk and stall portions of the pool would not be an issue from the standpoint of keeping the reactor core covered following a beam tube break (and may actually be beneficial) because the beam tubes are in the stall pool, and a damaged beam tube (while the beam tube plug and shutter are both open) would only cause water to drain from the stall pool. The shutdown reactor would remain covered with water in the bulk pool.

22. TS 3.4: UMLs response to RAI-14.3.22 states that a TS for the reactor building vacuum relief valve is no longer necessary given the proposed re-designation of the building as a confinement. Additionally, UMLs response to RAI-6.1, submitted by letter dated March 31, 2017 (ADAMS Accession No. ML17090A350), describes the conditions under which the emergency exhaust system would operate following the proposed re-designation but does not appear to indicate whether or when the system automatically shuts off to prevent excessive building under-pressure. Given that UML proposes to eliminate the relief valve TS clarify how excessive building under-pressure from emergency exhaust system operation would be avoided (e.g., by the system automatically shutting off when building differential pressure drops back to negative 0.10 inches of water or some other value).

During a teleconference on February 11, 2020, UML stated that it will provide follow-up supplemental information clarifying that its proposed changes to emergency exhaust system operation will only change when the system turns on, and not when it shuts off, and that the system will continue to automatically shut off when building pressure drops to or below approximately negative 0.25 inches of water.

23. TS 3.4.1(1): Requiring confinement whenever the reactor is not secured appears to exceed the recommendations in ANSI/ANS-15.1, Section 3.4.1, items (1), (3), and (4), but may be too restrictive given the equipment that is required by other TSs 3.4.2, 3.5, and 3.6.1 when any of the conditions in TS 3.4.1 are met (i.e., when confinement is required),

and UMLs potentially limited ability to maintain required equipment such as the main intake fan or certain radiation monitors operable and/or operating when the reactor may not be secured, in a condition such as a loss of offsite power. (The NRC staff notes that if TS 3.4.1(1) is revised to be more consistent with ANSI/ANS-15.1, Section 3.4.1, items (1), (3),

and (4), it may be appropriate to modify the ANSI/ANS-15.1 recommended TSs to be specific to the UMLRR and the analyses in the SAR, as supplemented.)

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises TS 3.4.1(1) to state [t]he reactor is operating. Additionally, the follow-up TS submittal will add two additional specifications to TS 3.4.1 that are consistent with ANSI/ANS-15.1-2007, Section 3.4.1, items (3) and (4), except that the one dollar in item (4) will be changed to a facility-specific 0.5% k/k (the NRC staff also recommends that reactivity units of % k/k be used in both of the specifications added to TS 3.4.1, for consistency with other TSs).

24. TS 3.5(1): RAI-14.4.20 does not appear to be fully addressed because it is not clear that the TS 3.5(1) requirement (or another TS requirement) includes the operability of valve F (see SAR Section 6.2) which automatically opens (upon reactor building isolation) to allow air from the main intake fan to dilute the emergency exhaust system air leaving the stack.

(See also audit item 49.)

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises TS 3.4.2(2) to require that all ventilation isolation valves and the bypass valve (i.e., valve F) are either operable or in the fail-safe position (closed for the isolation valves, open for the bypass valve).

25. TS 3.5(2): The TS requires that fans capable of maintaining negative pressure be operable, but does not appear to require that the fan(s) actually be operating to maintain negative pressure, consistent with analyses in the SAR, as supplemented (or consistent with surveillance TS 4.4(2), which requires verification of negative building pressure).

During a teleconference on February 11, 2020, UML stated that it will provide a follow-up TS submittal which revises TS 3.5(2) to state that building pressure shall be maintained at or more negative than 0.1 inch water column or similar language.

26. TS 3.6.1(1): RAI-14.3.23 does not appear to be fully addressed because the TS does not clearly require that the TS-required radiation monitors individually have control room alarm indicators, such that the operator would be immediately alerted and could take appropriate action if any single required radiation monitor reached its setpoint (the SAR, as supplemented, also does not appear to describe individual alarms for all TS-required monitors, or what actions operators would take based on such alarms). RAI-14.3.23 also does not appear to be fully addressed because it is not clear whether local alarms and/or readouts for TS 3.6.1(1)-required radiation monitors are necessary to ensure safety and should be in the TSs. When the reactor is secured, but other activities that require radiation monitor(s) (and confinement) are in progress, it is not clear that a reactor operator or other individual would necessarily be in the control room to take appropriate actions (e.g., alerting facility staff and/or isolating normal ventilation) if a required radiation monitor reaches its setpoint.

During a teleconference on February 20, 2020, UML stated that the TS 3.6.1(1)-required radiation monitors do not currently have individual remote audible alarms (that would necessarily immediately alert an operator) in the control room. The only audible alarms produced by these monitors would be generated by the ARMS computer logic, and require multiple combinations of monitors to reach their setpoints. UML stated that all TS 3.6.1(1)-

required monitors currently have readouts in the control room, but for the stack and continuous air monitors, the only readout is on the ARMS computer screen. Because individual monitors do not currently produce an alarm, and because the ARMS could represent a single point of failure, UML stated that it will make changes to its radiation

monitoring system (during the implementation period of a renewed license and TSs, or sooner). The changes will consist of adding additional ratemeters for the stack gas and particulate monitors, that will provide for independent readouts and individual audible alarms in the control room; and configuring the existing ratemeters for TS-required area monitors to provide for individual audible alarms in the control room (these ratemeters already provide readouts). UML stated that these new individual alarms for the stack and area monitors will be provided by the existing control room annunciator system. UML stated that it does not plan to make any changes related to the TS-required pool level continuous air monitor, but that because this monitor is near the control room, has a loud local audible alarm that is easily heard by the operator (even with the control room door closed), and also produces a visible (bright light) alarm that is easily visible to the operator, a new control room alarm is not necessary for this monitor. UML stated that it will provide follow-up supplemental information confirming this information describing these proposed changes, including a discussion of how the proposed configuration is sufficient to ensure the operator will be immediately alerted and can evaluate the situation and take appropriate action if any single TS-required radiation monitor reaches its setpoint (UML stated that its current procedures already require operator evaluation of a high level on any radiation monitor channel). UML stated that it does not plan to make changes to the TS 3.6.1(1) wording proposed in its March 5, 2019, submittal (except as discussed under audit item 27), but that its follow-up supplemental information will include a discussion of how TS 3.6.1(1) will be met by the proposed configuration (e.g., how the continuous air monitor alarm requirement will be met by the alarm outside the control room, and how the readout requirements will be met).

Regarding local readouts or alarms for TS 3.6.1(1)-required monitors, UML stated that specific TS requirements for these are not necessary. Typically, an operator in the control room would be alerted to elevated radiation levels and could alert other staff in the facility as necessary. Although there could be situations when radiation monitors are required by TS 3.6.1(1) but an operator would not be required to be in the control room because the reactor is secured (such as during radioactive material handling activities), there are multiple redundant fixed local area monitor alarms, and the local continuous air monitor alarms (discussed in the SAR, as supplemented) which could alert facility staff to a radiation hazard and allow them to take appropriate actions. Additionally, portable radiation monitors are used as necessary (per procedures) to supplement fixed monitors.

27. TS 3.6.1(1), item a.: The TS appears to contain a typographical error in that particulates should be particulate.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical error.

28. TS 3.6.1(2): RAI-14.3.23 does not appear to be fully addressed because it is not clear whether the TS is intended to require area radiation monitors near (outside of) each gamma irradiation facility, or inside the facilities. Additionally, RAI-14.3.23 does not appear to be fully addressed because it is not clear whether local alarms and/or readouts for TS 3.6.1(2) required radiation monitors are necessary to ensure safety and should be in the TSs (the NRC staff notes that, when the reactor is secured, but other activities that require radiation monitor(s) are in progress, a reactor operator or other individual would not necessarily be in the control room to take action if a required radiation monitor reaches its setpoint). (See also audit item 65.)

During a teleconference on February 20, 2020, UML stated that its purpose for TS 3.6.1(2) is to require monitors that are sufficient to alert personnel near irradiation facilities that a source is in use; regarding the location of the monitor, its intends the TS to allow flexibility and it does not intend the TS to require that the monitor be in any specific location inside or outside the irradiation facility, as long as the monitor accomplishes its purpose. UML stated that it will provide a follow-TS submittal which revises the TS 3.6.1(2) language readout and alarm indicator in the control room to local readout and alarm indicator capable of alerting personnel. Additionally, UML stated that it will provide a follow-up TS submittal which revises the TS 3.6.1 basis to clarify that the intent of the TS 3.6.1(2)-required alarms is to ensure personnel are aware that a gamma irradiation source is in use.

29. TS 3.6.1(3): The TS would state that operations may continue if the monitor can be repaired or replaced, but would not clearly require that operations only continue if the monitor is actually repaired or replaced. Additionally, RAI-14.3.24 does not appear to be fully addressed because the TS does not specify whether a replacement monitor may be a portable monitor, and if so, a maximum time that the replacement can serve for.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS wording can be repaired or replaced to is repaired or replaced. UML also stated that it would not need to replace TS-required monitors with portable monitors (given the redundant fixed monitors it has available), and no allowance for this in the TS is necessary.

30. TS 3.6.1(4): RAI-14.3.26 does not appear to be fully addressed because TS 3.6.1(4) does not appear to have a corresponding surveillance requirement.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which adds a semi-annual surveillance requirement to measure and record accumulated environmental dose. UML stated that it typically reads environmental monitors quarterly, but this surveillance requirement would allow flexibility.

31. TS 3.6.2(1): The TS appears to contain a typographical error in that sewage should be sewerage.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical error.

32. TS 3.6.2(2): The TS appears to contain a typographical error in that into the unrestricted area should be released into the unrestricted area. Additionally, the TS may be overly restrictive as written if the argon-41 concentration could potentially exceed 10 CFR Part 20, Standards for Protection against Radiation, Appendix B, effluent concentration limits at the point of release (i.e., the top of the stack), before any atmospheric dilution occurs.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS language into the unrestricted area to at the location of the maximum exposed individual in the unrestricted area or similar language.

33. TS 3.7.1: RAI-14.3.29 does not appear to be fully addressed because the wording sum total absolute value of reactivity worth (TS 3.7.1(2)), sum total absolute reactivity worth (TS 3.7.1(4)), or sum absolute value of reactivity worth (TS 3.7.1(5)) does not clearly indicate that the limits are limits on sums of the absolute values of reactivity worths (see

recommended wording in ANSI/ANS-15.1, Section 3.8.1, item (2)).

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the language in these three TSs to sum of the absolute values of reactivity worths.

34. TS 3.7.2: It is not clear that the language [e]xperiments irradiated with either neutrons from the reactor or gamma rays from the Co-60 sources encompass all experiments that may be conducted at the UMLRR, and that could fall under the TS definition of Experiment.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which removes [e]xperiments irradiated with [] shall conform to the following:

from the beginning of TS 3.7.2. Additionally, the NRC staff noted that it may be appropriate to clarify the meaning of maximum expected pressure in TS 3.7.2(4), and UML stated that it will provide a follow-up TS submittal which revises this to maximum expected pressure from detonation.

35. TS 3.8(1): RAI-14.3.18 does not appear to be fully addressed because the TS is applicable during reactor operation, but not during the 3,947 seconds following reactor operation.

Additionally, it is not clear from the TS wording that when a beam port shutter is open, it is the shield plug from that same beam port which shall not be removed.

During teleconferences on February 11 and 20, and March 10, 23, and 31, 2020, UML stated that it is not necessary for TS 3.8(1) to be applicable following reactor operation. Per TS 3.8, in order for UML to open a beam tube plug while the corresponding beam tube shutter is also open, the reactor must not only be shutdown but also moved to the bulk pool.

If the shutdown reactor were in the stall pool and a beam tube were damaged, any drainage would be limited to a 4 inch diameter round opening (similar to the 4.5 inches used in UMLs LOCA analysis) per the TS 3.8(2) limit on the size of any opening in a beam tube plug. If the shutdown reactor were in the bulk pool, a beam tube damage scenario could potentially cause drainage through an 8 inch diameter round opening if both a beam tube plug and the corresponding shutter were open. However, UML stated that although its LOCA analysis only assumes that drainage occurs through a 4.5 inch diameter opening, the assumptions in its analysis are extremely conservative, including that the reactor has been operated at full power for an infinite period of time, and that pool drainage starts immediately upon reactor shutdown. In actuality, even without a TS requiring UML to wait a certain amount of time after shutdown to open a beam port plug and shutter, it would take UML some time to move the reactor to the bulk pool (as required by TS 3.8(3)), and actually perform the beam tube reconfiguration, and this time would allow for some decay following shutdown. Additionally, given the design of, and operational practices at, the UMLRR, the complete shearing of a beam tube that would allow the reactor pool to be drained through an 8 inch diameter opening is an extremely unlikely scenario. UML stated that, per procedure, it does not move or handle heavy loads (e.g., using the overhead crane) over the stall pool (in which the beam tubes are located), regardless of the position of the reactor in the pool. Furthermore, even if a beam tube shearing scenario did occur, UML would be able to mitigate the scenario. UML could close the pool divider gate to isolate the reactor in the bulk pool (this could be accomplished very quickly, within a few minutes and well before the pool could drain to the level of the reactor even with an 8 inch break, because the reactor would already be in the bulk pool), preventing the reactor from becoming uncovered. The pool divider gate would be closed using the overhead crane, and this could be accomplished by

personnel located away from the pool such that they would not be exposed to any direct radiation from fuel (in the core or storage racks) or the cobalt-60 sources in the pool (the radiation level above the pool could increase as the pool level decreases). UML could also close the beam tube shutter (similarly without exposing personnel to direct radiation from the pool) to effectively stop the pool drainage because the heavy lead shutter would block the beam tube. UML stated that it will provide follow-up supplemental information confirming the above and its justification for TS 3.8(1) not being applicable following reactor operation.

Regarding the beam tube shutter, UML stated that it will provide follow-up supplemental information clarifying SAR Section 10.2.1.1 by stating that beam tube shutters are typically opened and closed using the overhead crane, rather than a manual crane.

UML also stated that it will provide a follow-up TS submittal which revises the TS 3.8(1) wording the beam port lead shutter in the up (open) position and the beam-port shield plug removed to a beam port lead shutter in the up (open) position and the corresponding beam-port shield plug removed, or similar language.

During teleconferences on April 21 and May 5, 2020, in response to NRC staff questions about where it places fuel within the storage racks in the pool, and cooling of stored fuel, UML stated that although its fuel handling procedures do not specifically designate where types of fuel with various activity and radiation levels (e.g., fresh fuel, lightly irradiated fuel, and more heavily irradiated fuel) are stored in the racks (e.g., in the lower racks that are at approximately the height of the core, or the upper racks that are above the core), it typically stores higher-activity fuel in the lower racks, which are deeper in the pool at approximately core level, as a best practice. UML stated that its fuel storage configurations and methods are intended to provide adequate cooling both for normal conditions, and abnormal conditions such as a possible LOCA. In response to NRC staff questions about the fuel storage descriptions in SAR Section 9.2.1, and the specific position of the lower racks, UML also clarified dimensions and information related to its fuel storage racks. UML clarified that the references to fuel elements in SAR Section 9.2.1 refer to the entire length of the elements (including the end boxes), and that when fuel elements are in the racks, roughly one-third of the entire length of an element protrudes out of the top of the rack. UML stated the 22.25 inch overall rack height provided in SAR Section 9.2.1 is an error that should have read 26 inches, and that the UMLRR pool contains 9 racks (capable of holding up to 9 elements each), rather than the 8 racks described in the SAR. Additionally, regarding the location of the lower racks, UML stated that the vertical centerline of the lower storage racks is 1.5 inches above the core centerline. UML stated that it will provide follow-up supplemental information confirming the above clarifications related to the dimensions, position, and number of fuel storage racks.

36. TS 3.8(2): RAI-14.3.18 does not appear to be fully addressed because the TS uses the language does not instead of shall not to denote a requirement.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises this language to shall not.

37. TS 3.8(3): The wording of the TS does not appear to clearly indicate that for any condition (i.e., regardless of whether the beam ports are being access[ed]), the reactor shall be positioned in the bulk pool if a beam port lead shutter is in the up position while that beam ports shield plug is also removed.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises TS 3.8(3) to more clearly require that the reactor shall be positioned in the bulk pool whenever a beam port lead shutter is open and the corresponding beam port shield plug is also removed.

38. TS 4.0, item A.: The TS appears to contain an incorrect TS reference in that 4.1(7) should be 4.1(8). Also, the TS lists surveillance requirement TSs that may not be deferred during shutdown, but the NRC staff notes that there are other surveillance requirements which may also be inappropriate to defer during shutdown, e.g., TSs 4.4, 4.5, and 4.6(1), because they relate to equipment required during activities such as fuel movement that could occur during an extended reactor shutdown. Additionally, the TS states that surveillance TS 4.3 in its entirety may not be deferred during shutdown, but the NRC staff notes that UML may be able to defer TS 4.3(4) given that it is only required prior to a reactor startup.

During teleconferences on February 13 and 18, 2020, UML stated that it will provide a follow-up TS submittal which corrects the TS 4.1(7) reference (if necessary, depending on other changes to TS 4.1 numbering in response to other audit item discussions), and adds TSs 4.4, 4.5, and 4.6(1) as TSs which may not be deferred during shutdown. UML stated that it is not necessary for TS 4.3(4) to be able to be deferred. Additionally, UML stated that in a follow-up TS submittal, it may further revise TS 4.0, item A., to explicitly list TSs which may be deferred during shutdown, instead of listing TSs which may not be deferred.

39. TS 4.0, item B.: The TS appears to contain a typographical error in that considerable should be considered.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical error.

40. TS 4.1(1): The wording excess reactivity above reference core condition does not appear to be consistent with the TS definition of excess reactivity because it is not clear that this means the excess reactivity at the (or in the) reference core condition. Additionally, it is not clear that TS 4.1(1) requires that excess reactivity be verified following any regulating rod change.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which changes the wording to excess reactivity at the reference core condition, and also requires that excess reactivity be verified following any significant core configuration, control blade, and/or regulating rod change.

41. TS 4.1(3): The TS appears to contain a typographical error in that positions should be position.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical error.

42. TS 4.1(4): The TS does not appear to be consistent with its corresponding limiting condition for operation (LCO) TS 3.1.1(4) because TS 3.1.1(4) requires that [n]o more than five (5) of the radiation baskets [] be without flow restricting devices, but TS 4.1(4) requires verification that all but 5 of the radiation baskets contain flow restricting devices.

Additionally, the TS appears to indicate that UMLRR natural convection operation is at power levels of less than 100 kWt, but the UMLRR can operate in natural convection mode

at steady-state power levels of less than or equal to 100 kWt.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the language to no more than 5 radiation baskets are without flow restricting devices, and replaces the less than symbol with a less than or equal to symbol.

43. TS 4.1(6): RAI-14.3.18 does not appear to be fully addressed because TS 4.1(6) does not provide appropriate surveillance for LCO TS 3.8(3); a beam port shutter could be opened and plug removed when the reactor is not operating.

During teleconferences on February 13 and 18, 2020, UML stated that it will provide a follow-up TS submittal which revises TS 4.1(6) to indicate that prior to the first reactor start-up of the day, a visual verification shall be made confirming the beam ports meet the criteria of TSs 3.8(1) and 3.8(2), and adds a new specification under TS 4.1 requiring that prior to any beam port configuration change, a visual verification shall be made confirming TS 3.8(3) is met.

44. TS 4.1(7): In its response to RAI-7.14.a, submitted by letter dated October 18, 2019 (ADAMS Accession No. ML19291C293), subsequent to its March 5, 2019, TS submittal, UML stated that TS 4.1(7) would be deleted in a future TS revision. (If TS 4.1(7) is deleted, TS 4.1(8) should be renumbered appropriately.)

During teleconferences on February 13 and March 10, 2020, UML stated that it will provide a follow-up TS submittal which deletes TS 4.1(7), and re-numbers TS 4.1(8) to 4.1(7) (if necessary following other revisions/re-numbering of TSs; see audit item 43).

45. TS 4.2.2: TS 4.2.2(1) appears to contain a typographical error in that following any significant core configuration should be following any significant core configuration change. Additionally, TS 4.2.2(2) appears to contain a typographical error in that verify only control blade should be verify only one control blade.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical errors.

46. TSs 4.2.3(2) and 4.2.3(6): The wording prior to each days operation, or prior to each operation extending more than one day (used in both TSs) does not appear to be consistent with the surveillance time intervals listed in the TS definitions.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises this wording in both TSs to prior to the first reactor start-up of the day.

47. TS 4.2.3(5): RAI-14.4.9 does not appear to be fully addressed because TS 4.2.3(5), item d.

uses the language [p]rimary coolant inlet temperature, but this is inconsistent with the LCO TS 3.2.3 and 3.2.5 language Pool Inlet Temperature.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises Primary coolant to Pool.

48. TS 4.4(1): It is not clear that the surveillance is sufficient to ensure continued operation of

the main intake fan during prolonged reactor operation (or other prolonged operations when the fan is required).

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to Prior to any of the operations specified in 3.4.1 and at no less than 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> intervals during, the main intake fan [] or similar language.

49. TS 4.4(3): The language functionally tested appears to be inconsistent with the TS definition of operable to denote a component or system that is capable of performing its intended function. It is also not clear whether TS 4.4(3) is an appropriate surveillance for TS 3.4.2(2) because TS 3.4.2(2) allows isolation valves to be inoperable if they are in the closed position; TS 4.4(3) requires confinement system testing but does not clearly require that valves be verified operable or closed. Additionally, RAI-14.4.20 does not appear to be fully addressed because it is not clear whether TS 4.4(3) (or another surveillance TS) encompasses verification of the operability of valve F (see audit item 24).

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to state that The ventilation isolation valves and bypass valve shall be verified operable semi-annually, or similar language. Additionally, UML stated that it will provide follow-up supplemental information stating that it does not intend TS 4.4(3) to require testing of valves if it knows the valves are inoperable; verification and documentation that the inoperable valves are in the fail-safe position would be sufficient to satisfy TS 4.4(3) for the inoperable valves.

50. TS 4.5(1): The language or following any maintenance or modifications that could affect the operability of the system appears to be redundant to, and inconsistent with, the general requirement for surveillance testing after maintenance in TS 4.0, item B.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which deletes the language or following any maintenance [] of the system from the TS.

51. TS 4.5(2): The SAR, as supplemented, does not appear to discuss what the testing required by this TS entails.

During a teleconference on February 13, 2020, UML stated that it performs an in-place test of the filter with stable elemental iodine. UML also stated that it will provide a follow-up TS submittal which revises the TS basis to specify periodic efficiency testing of the filter.

52. TS 4.6(1): The SAR, as supplemented, does not appear to specify whether the required channel tests are source checks, or whether the channels are tested using another method.

Additionally, TS 4.6(1) requires testing of monitors required by TS 3.6.1(1), but TS 4.6(1) (or other TSs) do not appear to require testing of monitors required by TS 3.6.1(2), which may not necessary also be required by TS 3.6.1(1). Also, it is not clear that the language prior to each days operation encompasses all operations for which radiation monitors are required in accordance with TS 3.6.1 (i.e., irradiations, fuel handling, etc., as well as reactor operation).

During teleconferences on February 13, 18, and 20, 2020, UML stated that it performs a source check for the required channel tests, and stated that it will provide a follow-up TS submittal which revises the TS basis to clarify that channel operability is verified by use of a

check source. UML also stated that it will provide a follow-up TS submittal which revises TS 4.6(1) to require a channel test of radiation monitors required by TS 3.6.1(1) prior to the first start of any TS 3.4.1 operation of the day. Additionally, UML stated that it will provide a follow-up TS submittal which adds a new specification to TS 4.6 requiring a channel test of a radiation monitor required by TS 3.6.1(2) prior to the first start of operation of the associated gamma irradiation facility of the day. UML further stated that it will provide a follow-up TS submittal which revises the TS 4.6 basis to clearly indicate that TS 4.6(1) and the new TS 4.6 specification are not intended to require re-testing each day if the activity requiring monitors is continuous over more than one day.

53. TS 4.6(2): It is not entirely clear whether this surveillance TS only applies to the LCO-required radiation monitors, or all installed monitors.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to state The radiation monitoring channels required by specifications 3.6.1(1) and 3.6.1(2) shall be calibrated [] or similar language.

54. TS 5.1(2): RAI-14.5.2 does not appear to be fully addressed because the TS uses the language [t]he facility is the area instead of the facility shall be the area to denote a requirement. Additionally, the TS specifies that the reactor building shall be the restricted area, but the NRC staff notes that this may not allow UML appropriate flexibility to expand the restricted area to other areas within the licensed boundary if necessary.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to state The facility shall be the area under the reactor license and The reactor building shall be the minimum restricted area as defined in 10 CFR Part 20.

55. TS 5.2(2): The language single cooling loop is not clear because the UMLRR has both primary and secondary cooling loops.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to state A single primary cooling loop [].

56. TS 5.2(3): The revised language which may include stainless steel components in the March 5, 2019, TS submittal does not appear to appropriately constrain the heat exchanger materials, given the TS definition of may. Additionally, the purpose and justification for the revised language in the March 5, 2019, TS submittal does not appear to be discussed in the SAR, as supplemented.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to state [] except for the heat exchanger which shall be comprised of stainless steel or titanium, and small non-corrosive components [].

Additionally, UML stated that it will provide a follow-up submittal which revises the TS basis to state that specifying that the heat exchanger shall be stainless steel or titanium allows flexibility for future heat exchanger upgrades.

57. TSs 5.3(2) and 5.3(4): The bases for the maximum fuel element limit (26, per TS 5.3(2))

and the maximum partial fuel element limit (2, per TS 5.3(4)) do not appear to be clearly stated in the SAR, as supplemented.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which clarifies the second sentence of the basis for TS 5.3 to state that the UMLRR core design analyses considered cores with combinations of U3Si2 and UAlx fuel, including up to 2 partial U2Si2 elements, for core loadings from 21 to 26 elements.

58. TS 5.3(6): The requirement that the analysis be reviewed and approved by the reactor safety subcommittee (RSSC) appears to be inconsistent with UMLRR Administrative Controls TSs (Section 6.0 of the TSs), which only require RSSC review of facility changes, experiments, etc.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which deletes the language and approved from the TS.

59. TS 5.3(7): It is not clear whether the TS limits average fission density over the entire core, or the average fission density in each fuel element.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to The average fission density in a fuel element [].

60. TS 5.4(1): If the restricted area may be expended beyond the reactor building (see audit item [54]), it may not be appropriate to specify the entire restricted area as the fuel storage area.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises restricted area to reactor building in the TS.

61. TS 5.4(2): TS 5.4(2) states that the considerations of the container apply but does not appear to clearly indicate that the requirements of TS 5.4(1) do not apply where a licensed shipping container is used.

During a teleconference on February 13, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to clarify that where a licensed shipping container is used, TS 5.4(1) does not apply (in its entirety). UML stated that the TS 5.4(1) requirements are not necessary as TSs when fuel (including fueled experiments or fueled devices) is in a licensed shipping container, and this allows flexibility for shipments.

62. TS 5.4: Given that the revised TS 5.4 in the March 5, 2019, TS submittal no longer limits fuel storage only to the reactor pool and licensed shipping containers, it is not clear whether UML plans to store quantities of fissionable material outside of the pool or licensed containers that would cause UML to be subject the requirements of 10 CFR 70.24, Criticality accident requirements.

During teleconferences on February 13 and March 10, 2020, UML stated that it will provide follow-up supplemental information confirming that any fissionable material it stores, handles, or uses outside of the pool or licensed containers is less than the quantities specified in 10 CFR 70.24(a).

63. TS 6.1.2(1): The TS does not appear to explicitly state that the Level 1 individual is responsible for the UMLRR license.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS language to be responsible for ensuring that []

regulations to to be responsible for the reactor license.

64. TS 6.1.2(3): RAI-14.6.2 does not appear to be fully addressed because the TS refers to safe operation of the reactor, but not the entire facility.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS language safe operation of the reactor to safe operation of the reactor facility.

65. TS 6.1.3(1): The TS does not appear to require specific facility staffing when the reactor is secured but gamma irradiation facilities are in use, and it is not clear from the SAR, as supplemented, what staffing the UMLRR would have in this scenario. (See also audit item 28.)

During teleconferences on February 18 and 20, and March 10, 2020, UML stated that gamma irradiation facility operators are trained individuals with unescorted access to the UMLRR facility. Individuals trained in UMLRR gamma facility operation are present for the setup and termination of gamma irradiations (including when gamma sources are being moved into or out of place for irradiations); however, ongoing static irradiations may continue during periods when there is no one present at the UMLRR facility (e.g., overnight).

Because the reactor may be secured when gamma irradiation facilities are in use, there is not necessarily anyone in the control room during gamma irradiation facility operation (including setup and termination of irradiations), so an operator would not necessarily be able to monitor radiation conditions from the control room and alert personnel to radiation hazards. However, the gamma irradiation facilities have multiple fixed radiation monitors with local alarms that can alert personnel to radiation hazards, including monitors that are both connected to, and independent of, the ARMS. Additionally, portable radiation monitors are used as necessary (per procedures) to supplement fixed monitors. As discussed for audit item 28, UML stated that it will revise TS 3.6.1(2) to require local area radiation monitors that will alert personnel when a gamma irradiation source is in use. UML stated that it will provide follow-up supplemental information confirming the above, and discussing facility staffing when the gamma irradiation facilities are in use.

66. TS 6.1.4(2): Although the TS references the 2007 revision of ANSI/ANS-15.4, Selection and Training of Personnel for Research Reactors, the NRC staff notes that the most current revision of this document is dated 2016. Additionally, the NRC staff notes that because the TS states that UML shall (denoting a requirement) comply with the most current version of ANSI/ANS-15.4, if ANSI/ANS-15.4 were revised subsequent to the issuance of a renewed UMLRR license, this could constitute an effective change to the TS requirements without NRC approval.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises shall to should, and revises R2007 to R2016.

67. TS 6.2 (introductory text): RAI-14.6.2 does not appear to be fully addressed because the TS states that the RSSC shall review reactor operations but does not clearly state that the operations of the entire facility shall be reviewed.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the language shall review reactor operations to shall review reactor facility operations.

68. TSs 6.2.1 and 6.2.2(2): In TS 6.2.1, it is not clear what is meant by shall not have line responsibility for operation of the reactor, e.g., whether this excludes any Level 1, 2, 3, or 4 individual in the UMLRR organizational structure, only individuals at certain levels, or something else. Similarly, in TS 6.2.2(2), it is not clear what is meant by the reactor staff does not constitute a majority. RAI-14.6.2 also does not appear to be fully addressed for TS 6.2.1 because the referenced portion of TS 6.2.1 refers to operation of the reactor, rather than operation of the facility.

During teleconferences on February 18 and 20, 2020, UML stated that it will provide a follow-up TS submittal which revises the last sentence of TS 6.2.1 to The RSSC chairman shall be elected from the membership and shall be from outside the reactor facility operating staff or Level 1, or similar language. UML also stated that it will provide a follow-up TS submittal which revises the TS 6.2.2(2) language reactor staff to operating staff. UML stated that it considers operating staff to include the Level 2 individuals and anyone who reports to them, consistent with ANSI/ANS-15.1-2007, Section 6.2.2, item (2).

69. TS 6.2.3(1), item e.: It is not clear whether having safety significance refers only to violations of internal procedures, or to violations of technical specifications or license, as well.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which adds a comma after license in TS 6.2.3(1), item e., for clarity.

70. TS 6.2.4(2): The TS appears to contain a typographical error in that audit should be audits. Additionally, the TS does not appear to contain a requirement to audit the physical security plan, consistent with the guidance in NUREG-1537, Appendix 14.1, Section 6.2.4.

During teleconferences on February 18 and 20, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical error, and adds an additional item to TS 6.2.4(2) stating The physical security plan on an [annual or biennial] basis. UML stated that it performs these audits on an annual basis, but it will consider proposing a TS allowing biennial audits for flexibility.

71. TS 6.2.4(2), item c., and TS 6.2.4(3): RAI-14.6.2 does not appear to be fully addressed because TS 6.2.4(2), item c., and TS 6.2.4(3), both state affect reactor safety rather than referring to affecting facility safety. Additionally, TS 6.2.4(3) appears to contain a typographical error in that there is an extra . following the first sentence.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises affect reactor safety to affect reactor facility safety in both TS 6.2.4(2), item c., and TS 6.2.4(3). UML also stated that it will provide a follow-up TS submittal which corrects the typographical error.

72. TS 6.3(1): Although the TS references the 2009 revision of ANSI/ANS-15.11, Radiation Protection at Research Reactor Facilities, the NRC staff notes that the most current revision of this document is dated 2016.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises R2009 to R2016.

73. TS 6.4(1): RAI-14.6.1 does not appear to be fully addressed because the TS uses should not preclude instead of shall not preclude to denote a requirement.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the language to shall not preclude.

74. TS 6.4(1), items c., d., and f.: RAI-14.6.2 does not appear to be fully addressed for these items because they use the term reactor where facility may be more appropriate.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises reactor safety to reactor facility safety in each of items c., d., and

f. Additionally, UML stated that it will provide a follow-up TS submittal which revises facility radiation monitoring to reactor facility radiation monitoring in TS 6.4(1), item e. (unless otherwise modified as discussed under audit item 75).

75. TS 6.4(1), item e.: This item does not appear to encompass all personnel radiation protection procedures used at the UMLRR. Although UMLs response to RAI-14.6.15 states that other general personnel radiation protection procedures that do not fall under item e. are campus-wide procedures that are not necessarily reviewed or approved by the RSSC and UMLRR Reactor Supervisor, the NRC staff notes that any procedure used at the UMLRR is subject [to] the review requirements of 10 CFR 50.59, Changes, tests and experiments.

During teleconferences on February 18 and 20, 2020, UML confirmed that as discussed in its response to RAI-14.6.15, general (i.e., campus-wide) radiation protection procedures that are used at the UMLRR are managed and controlled under the campus-wide Radiation Safety Program, which is subject to the requirements of UMLRR TS 6.3. However, for clarity and comprehensiveness of TS 6.4, UML stated that it will provide a follow-up TS submittal which revises TS 6.4(1), item e., to personnel radiation protection specific to the facility. UML also stated that it will provide a follow-up TS submittal which adds a new item to TS 6.4(1) which covers other personnel radiation protection procedures which are UML campus-wide; this new item will include a note that these other procedures shall be reviewed and approved by the Radiation Safety Committee and Radiation Safety Officer, respectively, instead of the Reactor Safety Subcommittee and Reactor Supervisor.

Additionally, UML stated that it will provide a follow-up TS submittal which adds a note to TS 6.2.3(1), item b., clarifying that campus-wide personnel radiation protection procedures shall not be subject to the TS 6.2.3(1), item b., review requirement per TS 6.4(1).

76. TS 6.4(1), item g.: The item appears to contain an editorial error in that the for is redundant to the introduction to TS 6.4(1).

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which deletes the for.

77. TS 6.4(2): It is not entirely clear that [d]eviations from procedures refers specifically to temporary deviations from procedures required by TS 6.4(1). Additionally, if general personnel radiation protection procedures are added to the TS 6.4(1) list of required procedures (see audit item 75), it may be appropriate to specify that deviations may

alternatively, be made by members of the health physics staff, and reported to the Radiation Safety Officer, as applicable.

During teleconferences on February 18 and 20, 2020, UML stated that it will provide a follow-up TS submittal which revises Deviations from procedures to Temporary deviations from procedures required by TS 6.4(1), or similar language. Additionally, UML stated that it will provide a follow-up TS submittal which revises senior reactor operator (Level 3) to senior reactor operator (Level 3) or member of the radiation safety staff, as applicable, and Reactor Supervisor or designee to Reactor Supervisor or Radiation Safety Officer or designees, as applicable, or similar language.

78. TS 6.5: The TS does not appear to specify that approved experiments shall be carried out in accordance with established and approved written procedures (which are subject to the requirements of UMLRR TS 6.4), in accordance with the guidance in NUREG-1537, Appendix 14.1, and ANSI/ANS-15.1.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which adds a new item to TS 6.5 stating that approved experiments shall be carried out in accordance with established and approved written procedures, or similar language.

79. TS 6.5(1): The TS appears to contain a typographical error in that class should be classes.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical error.

80. TSs 6.6.1(3) and 6.6.1(5): Both TSs refer to TS 6.7.2, but it is not entirely clear which specification of TS 6.7.2 (TS 6.7.2(1) or another part). Additionally, TS 6.6.1(5) states that a safety limit violation report shall be approved by the RSSC, but this appears to be inconsistent with TS 6.6.2(2), item e., and the guidance in ANSI/ANS-15.1.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the 6.7.2 references in TSs 6.6.1(3) and 6.6.1(5) to 6.7.2(1) and 6.7.2(2), respectively. Additionally, UML stated that it will provide a follow-up TS submittal which deletes the language and approved from TS 6.6.1(5).

81. TS 6.6.2(1), item a.: Given that UML proposed in its March 5, 2019, TS submittal to expand the reactor licensed boundary beyond the reactor confinement building, it may be appropriate to designate any release of radioactivity into unrestricted areas (not necessarily limited to a release from the confinement building) as a reportable occurrence.

(Additionally, TS 6.6.2(1), item a., appears to be inconsistent with TS 6.7.2(1), item b.,

which does specify release of [radioactivity] to unrestricted areas.)

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the language from the reactor confinement building to into unrestricted areas.

82. TS 6.6.2(1), item c.: It is not clear what unless prompt remedial action is taken as specified in Section 3 is referring to.

During a teleconference on February 18, 2020, UML clarified that this language refers to TS 3.6.1(3), which allows operations to continue with a required radiation monitor inoperable if the condition is corrected within one hour.

83. TS 6.6.2(1), item g.: The language could have caused does not appear to be adequately comprehensive or consistent with the language causes or could have caused[]

recommended in ANSI/ANS-15.1, Section 6.7.2(1), item (c)(vi). Additionally, RAI-14.6.2 does not appear to be fully addressed because the item refers to operation of the reactor, rather than the entire facility.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the language could have caused to causes or could have caused, and operation of the reactor to operation of the reactor or gamma irradiation facilities.

84. TS 6.6.2(2), items d. and e.: Item d. refers to TS 6.7.2, but it is not entirely clear which specification of TS 6.7.2 (TS 6.7.2(1) or another part). Additionally, in item e., it is not entirely clear if the report referred to is the same report required to be submitted in accordance with TS 6.7.2(2), or something else.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the 6.7.2 reference in TS 6.6.2(2), item d., to 6.7.2(1).

Additionally, UML stated that it will provide a follow-up TS submittal which adds to TS 6.6.2(2), item e., that the report is submitted to the NRC in accordance with TS 6.7.2(2).

85. TS 6.7.1(4): RAI-14.6.27 does not appear to be fully addressed because the TS does not require that the list of changes include a summary of evaluations, consistent with ANSI/ANS-15.1, Section 6.7.1(4), and 10 CFR 50.59(d)(2).

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the TS to clearly require that the tabulation of changes includes a summary of the evaluations conducted pursuant to 10 CFR 50.59.

86. TS 6.7.2(1): The language and followed by a written report [] Washington, DC 20555, added in the March 5, 2019, TS submittal, appears to be redundant to TS 6.7.2(2).

Additionally, TS 6.7.2(1) appears to contain 2 typographical errors in that Operation should be Operations, and and sent (if not deleted) should be and is sent.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which deletes the language and followed by a written report [] Washington, DC 20555, and corrects Operation to Operations (the and sent typographical error was part of the deleted portion of the text).

87. TS 6.7.2(1), item b.: This TS appears to be redundant to TS 6.6.2(1), item a., because release of [radioactivity] is already a reportable occurrence defined in TS 6.6.2.

Additionally, the wording of TS 6.7.2(1), item b., is not entirely consistent with TS 6.6.2(1),

item a. (see audit item 83).

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which deletes TS 6.7.2(1), item b.

88. TS 6.7.2(2): TS 6.7.2(2) references TS 6.6.2(2) as listing the information required for follow-up reports, but it appears that TSs 6.6.1(4) and 6.6.2(2) both contain information required for follow-up reports. Additionally, it is not entirely clear which part of TS 6.6.2(2) is being referenced (item e. or another item).

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which revises the 6.6.2(2) reference to 6.6.1(4) and/or 6.6.2(2).e, as applicable.

89. TS 6.7.2(3), item a.: The TS appears to contain a typographical error in that 1or should be 1 or.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which corrects the typographical error.

90. TS 6.8.1(2): The TS appears to be less broad than the recommended language in ANSI/ANS-15.1, Section 6.8.1, and it is also not clear if nuclear safety refers to the safety of the entire facility or only the reactor.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which deletes the language including inspection [] nuclear safety from TS 6.8.1(2).

91. TS 6.8.3: RAI-14.6.1 does not appear to be fully addressed because TS 6.8.3 does not include a shall to denote a requirement. Additionally, TS 6.8.3(5) appears to contain a typographical error in that conditions should be condition.

During a teleconference on February 18, 2020, UML stated that it will provide a follow-up TS submittal which adds the sentence The following records shall be retained for the life of the facility at the beginning of TS 6.8.3. Additionally, UML stated that it will provide a follow-up TS submittal which revises the TS 6.8.3(5) language from limiting conditions for operations to limiting condition for operation.

Audit Questions: Other Topics (2020 audit)

(Note: Except where noted otherwise, these questions refer to the RAI responses submitted by letter dated March 5, 2019 (ADAMS Accession No. ML19064B373), in response to the NRC staffs RAI dated November 5, 2018 (ADAMS Accession No. ML18253A088).)

92. The SAR states that that the control blade active region consists of BORTEC material.

However, as discussed in the UMLRR annual reports for 2014-2015, 2015-2016, and 2016-2017 (ADAMS Accession Nos. ML15243A028, ML16224A324, and ML17209A491, respectively), the old blades (which are boron carbide in an aluminum matrix clad with aluminum) were still in the process of being replaced with the new BORTEC blades. It is not clear whether the replacement of these blades is complete, such that the currently-installed control blades when a renewed license is issued will be consistent with the descriptions in the SAR.

During a teleconference on February 18, 2020, UML stated that it had replaced three of four control blades to date. UML stated that it needs to anodize the fourth BORTEC control blade before installing it, but it currently expects to have the fourth (and final) BORTEC blade installed by June 30, 2020, the date by which the NRC staff informed UML that it

expected to complete its license renewal review as of January 13, 2020 (see ADAMS Accession No. ML20009E848). UML stated that it will provide follow-up supplemental information clarifying the SAR by stating that it expects to have four BORTEC control blades installed consistent with the SAR descriptions by June 30, 2020, but it currently has one aluminum-clad control blade and three BORTEC blades, and could have either configuration when a renewed license would be issued.

93. It is not clear from the LRA, as supplemented, whether UML requests that its license conditions for a renewed license allow it to separate byproduct material produced in non-fueled experiments.

During a teleconference on February 18, 2020, UML stated that it will provide follow-up supplemental information requesting that its license conditions for a renewed license allow it to separate byproduct material produced in non-fueled experiments.

94. Discuss whether UML requests that a renewed license allow a delayed implementation of its renewal TSs and license, beyond the actual date of issuance (i.e., effective date) of a renewed license.

During a teleconference on February 18, 2020, UML stated that it will provide follow-up supplemental information requesting that its renewed license state that the license is effective upon issuance, but must be implemented within a certain period of time following issuance. UML stated that it will specify an implementation time such as 30 or 60 days, and the purpose of the delayed implementation would be to allow for time to make facility changes and procedure changes, and conduct operator training, consistent with the new license and TSs. UML stated that it could later update its implementation time request based on considerations with its schedule, and any updates from the NRC staff on when the NRC staff expects a renewed license could be issued; however, it would provide further follow-up supplemental information if it decided to modify this request.

95. RAI-12.1 does not appear to be fully addressed because it is not entirely clear how UMLs startup procedures will provide confirmation of modeling and/or analysis predictions for cores containing aluminide fuel (e.g., by verifying similarity of calculated and measured parameters).

During a teleconference on February 18, 2020, UML stated that for its initial startup of the reactor with aluminide fuel in the core, UML will perform comparisons to verify the similarity of calculated and measured reactor parameters (e.g., reactivity and critical blade height), to help confirm modelling and analysis predictions for cores containing aluminide fuel. UML further stated that for any new fuel configuration, even with the same type of fuel, it performs measurements of reactor parameters not just to ensure compliance with TSs, but also to verify reasonable consistency with expected parameter values for the new configuration.

UML stated that it will provide follow-up supplemental information confirming these statements.

96. SAR Section 6.2.3 states that, in the event of a general reaction in the ventilation system (GRVS), the main exhaust fan ceases to operate, while the main intake fan continues to operate, except for the case where electrical power is lost. SAR Figures 8-2 and 8-3 appear to indicate that the main intake fan (fan AC-2) is on the emergency power distribution switchboard, but the main exhaust fan is not supplied by emergency power.

SAR Section 13.2.7 states that one of the principal purposes of the UMLRR emergency

power system is to provide backup power for the main exhaust fan. Based on the information in the SAR, it is not clear whether the main intake and exhaust fans are supplied by the emergency power system.

During a teleconference on February 18, 2020, UML stated that the main intake fan is on emergency power, but the main exhaust fan is not. The main intake fan would shut off for a period of time following a loss of offsite power, but would normally restart once the emergency generator starts. UML stated that it will provide this information as follow-up supplemental information to correct and clarify the SAR.

Audit Question: Instrumentation and Controls (2020 audit)

(Note: During the audit, the NRC staff and UML discussed various topics and questions within the scope of audit item 97 but which expanded upon the level of detail in the original audit item 97. Therefore, in its discussion summary below (under the restatement of original audit item 97 from the audit letter), the NRC staff included both summaries of the various detailed topics/questions discussed (provided in non-italicized text and numbered i., ii., iii., etc.), and summaries of the discussion of the resolution to each detailed topic/question (provided in italicized text).

97. The NRC staff transmitted RAIs to UML by letter dated July 19, 2019 (ADAMS Accession No. ML18092B090), to which UML provided a response by letters dated October 18, October 24, December 19, and December 20, 2019 (ADAMS Accession Nos.

ML19291C293, ML19297F433, ML19353C523, and ML19354A610, respectively) (UMLs complete response to RAI-7.4.c and RAI-7.5.a is still pending [Note: these two RAIs were closed out subsequent to the February 4, 2020, issuance of the audit letter by a letter from UML dated February 24, 2020 (ADAMS Accession No. 20055F604]). However, documentation referenced in some UML responses to the I&C RAIs were not included and the bases for some statements in RAI responses are not clear. For example:

a. UMLs response to RAI-7.4.d states that the documents related to the Thermo Fisher Scientific PPM are incorporated by reference into the UMLRR SAR, but these documents do not appear to be in ADAMS, nor do they appear to be commercially-available documents.

b. UMLs responses to other Section 7 I&C RAIs reference vendor documentation, correspondence, communications, etc. to substantiate the suitability of the UMLR I&C systems. However, the referenced information does not appear to be in ADAMS, nor was it made available to the NRC staff during previous audits.

c. UMLs responses to RAIs cite UMLRR documentation, such as acceptance checklists, pre-critical checkout procedures, calibration procedures, acceptance tests, and a UML configuration management program. However, these updated documents do not appear to be in ADAMS, nor were they made available to the NRC staff during previous audits.

i. During the audit discussion, the NRC staff requested that UML provide supporting documents and reports, calculations, and computer code verification, as applicable, to support the analysis documented in the SAR, as supplemented, bases for TSs, or rationale for any required plans and procedures. The NRC staff requested that UML make these additional materials available on the online reference portal discussed in the audit plan. Based on discussion during the audit and additional review by the

NRC staff, the NRC staff stated that it was no longer necessary for UML to provide some of the specific documents listed in the Information Needed for the Audit section of the audit plan (the documents actually provided by UML and reviewed by the NRC staff are listed in the resolution summary below).

UML specifically agreed to make available, via the online reference portal, documents which are referenced in UMLs RAI responses (related to I&C systems) submitted by letters dated October 18 and 24, and December 19 and 20, 2019 (ADAMS Accession Nos. ML19291C293, ML19297F433, ML19353C523, and ML19354A610, respectively).

The NRC staff reviewed the following documentation during the 2020 audit regarding the I&C upgrades via UMLs online portal[c]:

(1) Scram chain circuit diagram, contact numbering key, and description [Ref. response to RAI-7.1.b, Appendix A, which is not legible]

(2) OPTO22 Software Quality Assurance Plan and vendor component data sheets [Ref.

response to RAI-7.2.a]

(3) TFS Neutron Flux Monitoring Systems Instruction Manual 1126 for UML(b) [Ref.

response to RAI-7.4.d]

(4) TFS Quality Assurance Program Manual Revision 22, dated October 11, 2018(b)

[Ref. response to RAI-7.4.d]

(5) TFS PPM Certificate of Conformance and supporting documentation (TFS PPM Configuration Record and Test Reports) (b), dated June 27, 2019 [Ref. response to RAI-7.4.d]

(6) Logarithmic Power Channel Check and Calibration Procedure (Control Doc. No. CP-7-0) [Ref. response to RAI-7.6, RAI-7.12.b, and RAI-7.12.c]

(7) UMLs procedure for Software configuration management, Control Doc. No. AP 00, [Ref. response to RAI-7.7, RAI-7.8.a, and RAI-7.8.b]

(8) UMLs Pre-Startup Check Sheet (Forced Convection), RF-RO-7, revised August 17, 2015, completed and signed July 26, 2017.

(9) UMLs Standing Order #5, Setpoints for Various Scrams and Alarms.

(10) Updated Figure 7-9 of UMLR SAR showing annunciator configuration [Ref. response to RAI-7.10.a(i)]

(11) [Intentionally blank to preserve numbering of documents]

(12) Evidence to support GA vendor statements for NMP1000 installed at UML (e.g.,

electronic communication) (a) [Ref. responses to RAI-7.13 and RAI-7.15]

(13) UML Detailed Specifications for Nuclear Instrumentation to purchase its TFS Wide Range Neutron Flux Monitoring System (including a fission chamber detector) (a) [Ref.

response to RAI-7.12.a]

(14) NMP-1000 Multi-range Linear Power Monitor Procurement documents(a) [Ref.

response to RAI-7.12.a]

Notes:

(a) With regard to procurement documents (last three items listed above), UML specifically agreed to docket (in addition to any other NMP1000 and TFS PPM documents) the actual GA and TFS procurement documents used to outline the detailed specifications for the nuclear instrumentation, to supplement the generic list of specifications provided in its response to RAI-7.12.a. These documents are not designated as proprietary but will have price-related details redacted in the submissions.

(b) UML stated that it has been unable to obtain a 10 CFR 2.390 affidavit from the vendor (i.e., the owner of this information). However, the NRC staff reviewed the material in accordance with the requirements of 10 CFR 2.390, and based on its

review, determined that the information appears to contain both proprietary information and material protected under copyright laws and should not be placed in ADAMS without the owners express permission. Therefore, the docketed information will contain only the document coversheet under fair use to preclude copyright infringement on the exclusive rights granted to the copyright holder, such as the right to reproduce, distribute, or display the protected work. The NRC staff notes that if cover pages are submitted without any of the copyright and/or proprietary information contained in the documents, any copyright and/or proprietary legend on the submitted cover pages should be struck or blacked out.

(c) After review of the above documentation, the NRC staff has determined that several of the above listed documents provide information necessary for documenting its licensing basis decision. Accordingly, subject to 10 CFR 2.390 and copyright restrictions (Note (b) above), UML is requested to place document number(s) (2), (3), (4), (5), (7), (9), (12), (13), and (14) on the 50-223 docket under oath or affirmation.

ii. The NRC staff requested that UML provide follow-up supplemental information confirming that information submitted to the NRC by GAs letter dated January 8, 2020 (ADAMS Accession No. ML20017A148), completes its responses to RAI-7.4.c and RAI-7.5.a.

During a teleconference on February 11, 2020, UML stated that it will provide follow-up supplemental information that confirms that it considers GAs January 8, 2020, submittal to provide information that completes UMLs response to RAI-7.4.c and RAI-7.5.a.

UML submitted its follow-up RAI supplement, dated February 24, 2020 (ADAMS Accession No. ML20055F604), which completes UMLs response to RAI-7.4.c and RAI-7.5.

iii. The NRC staff noted that in the UMLRR license renewal TSs and RAI responses submitted by letter dated March 5, 2019 (ADAMS Accession No. ML19064B373), TS 4.2.3(3) refers to Log-N, but Log PPM may be more consistent and appropriate given UMLs proposal to install the TFS PPM.

During teleconferences on February 11 and 13, 2020, UML stated that it will provide a follow-up TS submittal that revises Log-N in TS 4.2.3(3) to Log PPM.

iv. In the 2017 audit, UML stated that the draft linear power channel installation plan required the addition of a section for the 100 kWt mode (i.e., natural circulation mode). The NRC staff noted that the latest version of the plan submitted as Appendix C to UMLs response to RAI-7.6 still does not contain a 100 kWt mode section. The NRC staff also questioned references in the procedure for testing the watchdog timer to verify pulsing has stopped and started on the NLW.

During teleconferences on February 20 and July 14, 2020, UML stated that finalizing this installation procedure is still an outstanding action for the implementation of the new NMP-1000 linear power channels that will be accomplished once the license renewal, including the linear power channel upgrades, is approved, but prior to the implementation. UML stated that the modification of the channels to accommodate dual-mode operations will be completed by a UMLRR technician, using the instruction

provided by GA, per the [Gen-2] NMP-1000 Linear Power Channel Installation Plan.

UML stated that the updated procedure will include the 100 kWt mode changes (i.e., the modification of the channels to accommodate dual-mode operations), and also stated that the NLW references were errors that will be corrected in the plan update. UML stated that it will provide follow-up supplemental information confirming these statements regarding finalizing the installation procedure and the changes/corrections that will be made. (Although it initially stated that the updated installation procedure would be placed on the audit portal, UML subsequently clarified that the procedure update would not occur until after the license renewal is approved.)

v. In the 2017 audit, UML stated that the NMP-1000 hardware required range select modifications to accommodate the dual-mode operations of the UMLRR, and produced a memo from GA (document o listed under 2017 audit item 2) describing the required changes. The required 100 kWt mode modifications reviewed by the NRC staff during the 2017 audit were listed to be:

- add a diode, two resistors, and a capacitor to the Motherboard (T3400111); and,

- add two double-pole, double-throw toggle switches and modify jumper locations on the Trip/Alarm board (T3301131).

It is not clear to the NRC staff how UML will verify these modifications are implemented correctly (e.g., by testing) and properly documented (e.g., by configuration management).

During teleconferences on February 20 and 25, 2020, UML stated that this is still an outstanding action for the implementation of the new NMP-1000 linear power channels that will be accomplished once the license renewal, including the linear power channels upgrades, is approved. UML further stated that the hardware modifications will be tested as part of the Linear Power Channel Installation Plan and the Linear Power Channel Check and Calibration procedure. Drafts of these documents were initially submitted in response to RAI-7.6 (RAI response, Appendix C), and UML stated that the Linear Power Channel Installation Plan will be updated prior to UMLs implementation of the channel upgrades. (Although it initially stated that the updated installation procedure would be placed on the audit portal, UML subsequently clarified that the procedure update would not occur until after the license renewal is approved.)

vi. The proposed changes for the UMLRR license renewal include re-designation of the reactor containment building as a confinement. It is not clear to the NRC staff if the proposed facility changes to go from containment to confinement will affect the operation of the area radiation monitoring systems or any of the UMLRR I&C systems.

During a teleconference on February 20, 2020, UML stated that the proposed changes for the UMLRR license renewal to change from containment to confinement do not involve or result in any changes to the I&C systems.

vii. During the 2017 audit, UML performed a reactor checkout. Several changes to the written procedures were noted to be needed to accommodate the proposed changes to the I&C systems. Describe the reactor checkout procedure changes that will be made prior to use of the proposed I&C systems.

UML provided on the portal the completed and signed reactor checkout procedure for forced convection that it used to perform the reactor checkout during the 2017 audit (document No. 8 under item i.). During a teleconference on February 20, 2020, UML stated that revisions to the reactor checkout procedure (RO-7), including revisions associated with 100 kWt mode operation, are still an outstanding action for the implementation of the new instrumentation (NMP-1000 and Log PPM), which will be completed prior to the implementation. (Although it initially stated that the updated checkout procedure would be placed on the audit portal, UML subsequently clarified that the procedure update would not occur until after the license renewal is approved.)

viii. During the 2017 audit (as noted in RAI-7.16), the NRC staff reviewed the response time constants in Section 1.2, Specifications, in the NMP-1000 Multi-Range Linear Module User Manual, Revision B (ADAMS Accession No. ML20017A149), and noted that the response time values in the manual appear to be inconsistent with those in the NMP-1000 module specifications provided in SAR Table 7.2 and in the procedure for Test 2.29, EMRT.STP.01, Electrometer - Response Time - Rev A, in the Ethernet Core Module Validation Summary Report (provided as a proprietary attachment to GAs letter dated July 26, 2017 (ADAMS Accession No. ML17249A080)).

In its response to RAI-7.16, UML stated it was unaware of a revision to the GA user manual at the time the 2015 license renewal SAR was submitted to NRC. UML stated that it specifically asked GA to confirm the Revision B values. UML stated that, if confirmed, the values in SAR Table 7-2 would be updated by UML. Provide the confirmation of the correct NMP-1000 response times.

During a teleconference on February 20, 2020, UML stated the time constant values in the NMP-1000 User Manual Revision B (dated June 2015) are correct. Additionally, UML confirmed that, as stated in its response to RAI-7.16.b, the NMP1000 response time at the LSSS power levels has no measurable effect on the delay time used in the accident analyses.

ix. The procedure for the NMP-1000 Linear Power Channel Check and Calibration (Control Doc. No. CP-2-04) was audited during the 2017 audit. Additionally, UML included the procedure in its response to RAI-7.6, and the procedure states that its purpose is to perform the TS 4.2.3 required annual calibration for the reactor power level measuring channels. UMLs response to RAI-7.6 also stated that UML is going to generate a similar procedure for the PPM. Explain if the nuclear instruments are adjusted based on differences between indicated and calculated neutronic power and, if so, how the adjustment is performed.

During a teleconference on February 20, 2020, UML stated the NMP-1000 procedure entails a channel calibration (to satisfy TS 4.2.3(3) (in UMLs proposed license renewal TSs submitted March 5, 2019) for the NMP-1000) that is an actual adjustment of the channel based on the vendors operation and maintenance manual to adjust linearity of circuit components (meters, setpoint adjusts, HV adjusts, power supply voltages, and the electrometer). This is an electronic calibration. On February 28, 2020, UML uploaded the Logarithmic Power Channel Check and Calibration (see document No. 6 under item i.), which is the corresponding TS 4.2.3 procedure for the Log PPM. The thermal power verification (to satisfy TS 4.2.3(4) in UMLs proposed license renewal TSs submitted March 5, 2019) is a channel calibration based on the thermal balance, in

which the indication is adjusted to match thermal power by adjusting a pinion which physically moves the neutron detector vertically up or down, as necessary, to match the thermal power. UML stated that this adjustment procedure applies to both linear power channels and the logarithmic power channel. Additionally, UML stated that the nitrogen-16 (N-16) power monitor is also calibrated by applying calorimetry techniques. UML also confirmed that the N-16 power module provides a high-power trip (1.15 MWt) via the PCS scram contacts in the scram safety chain.

x. In T9S900D940-SYR_Rev A "NMP-1000 System Requirements Specification, (provided as a proprietary attachment to GAs letter dated July 26, 2017 (ADAMS Accession No. ML17249A080)), sections 3.2.20.1.1 and 3.5.3.1.3.2 discuss a watchdog timer reset for the NMP-1000. However, the NMP-1000 watchdog timer does not appear to be in the UMLRR TSs. Provide confirmation of the purpose and function of the NMP-1000 watchdog timer reset.

During a teleconference on February 25, 2020, UML confirmed that the NMP-1000 heart beat sends a scram signal, but that it is not a TS-required scram. UML stated that the information to explain the operation of the NMP-1000 watchdog timer is contained in the NMP-1000 User Manual, which is on the UML docket under ADAMS Accession No. ML20017A149. The NRC Staff noted that, per the GA documentation, the internal watchdog timer trips the same output as the NMP-1000 high power scram in the RPS scram chain.

xi. As a follow-up to the 2017 audit, and RAI submittals, the NRC staff requested a larger scram chain diagram for the UMLRR that was more legible. The NRC staff also requested additional explanation of the seismic, bridge and piping alignment sensors and a key to the 31 numbered contacts on the diagram.

During a teleconference on February 25, 2020, UML agreed to upload to the portal a larger diagram for the UMLRR scram chain to facilitate review by the NRC staff (part of document No. 1 under item i). The diagram was discussed during the teleconference on February 25, 2020, and the NRC staff requested that UML upload a key to the 31 scram contacts in the scram chain. On March 27, 2020, UML uploaded to the portal a document that provided the identification of the scram contacts (also part of document No. 1 under item i). The NRC staff requested additional explanation of the seismic, bridge and piping alignment sensors, and, on June 10, 2020, UML provided a written description on the online audit portal of the related relays for the scram bypass for 100 kW mode and for the bridge movement contacts (also part of document No. 1 under item i).

xii. As a follow-up to UMLs response to RAI-7.2 regarding the upgrades to the ARMS, DCS and PCS, the NRC staff requested UML provide additional information regarding the OPTO22, Inc. quality assurance program. Subsequently, the NRC staff requested the data sheets for major components used in the OPTO upgrade.

During a teleconference on February 25, 2020, UML agreed to provide the OPTO22 software quality assurance plan for NRC staff review on the online audit portal (document No. 2 in item i. above). On March 16, 2020, in response to the NRC staff request, UML also uploaded to the online audit portal vendor data sheets for the Snap' controller, analog and digital I/O modules (also in document No. 2 in item i. above).

xiii. At the end of the 2017 audit, contrary to its license renewal application, UML stated its intent is to replace the current Log Power Measuring Channel with a Wide-Range Logarithmic Power/Period channel manufactured by Thermo Fisher Scientific (TFS).

An open item was carried forward to the 2020 audit for confirmation to provide documentation for the replacement TFS Log power and period meter (PPM) system, including QA, CM, V&V, and operation manuals.

During the 2020 audit, UML uploaded several proprietary and copyright TFS Log PPM documents including the UML procurement specification, TFS quality assurance manual, TFS Log PPM user manual, and certificate of compliance for the UMLRR Log PPM.

However, UML also stated that after multiple attempts, the vendor was unable (or unwilling) to provide an affidavit for use by the NRC staff. See Note (b) to the document list provided under item 97.i of this 2020 audit report.

xiv. In its response to RAI-7.13.b, UML stated it received an electronic communication dated June 20, 2017, in which a representative of GA confirmed several procurement details related to the applicability of previously supplied GA documentation and agreed to provide electronic mail documenting these details. An open item was carried forward to the 2020 audit for UML to provide documentation to support these details.

During the 2017 audit, UML confirmed that GA had stated that the NMP-1000 procured by UML was the same build and model as the NMP-1000 documented in the INL SRS, SYR and FMEA (see items 2.a. through 2.n. under the 2017 audit document list). On February 28, 2020, in response to the NRC staff request, UML uploaded to the online audit portal additional documentation for the applicability of the GA documentation to the UMLRR NMP-1000 (document No. 12 in item i, above).

Additionally, during a teleconference on July 29, 2020, in response to NRC staff questions about differences between the NMP-1000 units proposed for installation at UML and older NMP-1000 models, UML confirmed that the architecture of the proposed (Generation 2) NMP-1000 is fundamentally the same as all previous (Generation 1)

NMP units. UML stated that it would provide follow-up supplemental information confirming this statement.

xv. During the 2017 audit, the NRC staff noted that the calibration and checkout procedures both described parameters that should be under configuration control (i.e., under a CM program). However, no details were provided on how these parameters are controlled. The NRC staff request to review the UML CM program or procedure was carried forward to the 2020 audit.

During the 2020 audit, UML provided on the online audit portal the Software Configuration Management procedure (Control Doc. No. AP-7-0). This procedure establishes the UMLRR program for checking, documenting, and reviewing changes to instrumentation software and trip point settings for the NMP-1000 Linear power channels (document No. 7 in item i, above). Additionally, during the 2020 audit, to establish how setpoints are further controlled, UML uploaded to the online audit portal Standing Order

5 from the Chief Reactor Operators book that documents the current setpoints and shows that the actual equipment setpoints are set conservative to the LSSSs and LCOs (document no. 9 in item i, above). UML confirmed that setpoints associated with the

proposed NMP-1000 and Log PPM channels will continue to be administratively set (by procedure) to be conservative relative to the LSSSs and LCOs.

xvi. The NRC staff noted that in the UMLRR license renewal TSs and RAI responses submitted by letter dated March 5, 2019 (ADAMS Accession No. ML19064B373), the TS definition of reactor secured refers to the console key switch. However, SAR Section 7.3.3 and SAR Figure 7-8 appear to indicate that this switch (the key-operated master control switch) is located on the control room instrumentation panel, rather than the console.

During a teleconference on April 21, 2020, UML stated that it would provide a follow-up TS submittal updating the TS definition of reactor secured to refer to the Master Key switch on the instrumentation panel to ensure clarity of the switchs actual location.

xvii. Although SAR Section 7.4.1.3 discusses the startup channel and SAR Section 7.6.1.9 discusses the startup counter drive indicators, the NRC staff noted that the SAR, as supplemented, does not appear to include any detailed discussion of the startup counter drives. The NRC staff noted that the 1985 UMLRR SAR (Section 4.4.10) appears to contain more detailed information regarding the startup counter drives, but it is not clear if that information is still valid or if more detailed information should be included in the 2015 renewal SAR, as supplemented.

During teleconferences on April 21 and May 5, 2020, UML stated that it reviewed the 1985 SAR details on the startup counter drives and compared them to the details in the 2015 license renewal SAR. UML stated that additional information, similar to the information provided in the 1985 SAR, should have been provided in the license renewal SAR. UML stated that it would provide follow-up supplemental information adding the information to the license renewal SAR.

xviii. SAR Section 7.6.1.3 states that the PCS, DCS, and ARMS HMI configurations are password protected to prevent unauthorized changes. The OPTO QAP (document No. 2 under item i.) states that OPTO software products are usually updated periodically with new features, enhancements, and bug fixes, and between major releases of software products, OPTO typically releases new minor versions (i.e.,

patches) that contain just bug fixes. Clarify whether there have been any updates to the UML software, either for OPTO software releases or for malfunctions or errors in the program at UML.

During a teleconference on April 21, 2020, UML stated that the software programs developed for the PCS and DCS are on a standalone network, disconnected from any external interface. The programs have not been updated since they were installed and have not had any operational issues since being installed and tested. UML also stated that the PCS has two computers (one as a backup) since some ventilation valves and fans would have to be locally controlled if the PCS computer were to malfunction. The second computer is a laptop running an independent version of the same control system that is completely redundant and is installed, if needed.

xix. SAR Table 1-2 indicates that the withdrawal rate of the UMLRR regulating rod is 55 inches per minute. However, SAR Section 3.5.2 states that the nominal speed of the regulating rod is 78 inches per minute, and SAR Section 4.2.2.3 states that the

maximum speed of the regulating rod is 78 inches per minute. Clarify which regulating rod speed is correct.

During a teleconference on May 5, 2020, UML clarified that 55 inches per minute is the correct nominal value for the regulating rod speed. UML stated that it would provide follow-up supplemental information correcting the incorrect values in the SAR.

ML20275A090

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