ML20329A340
| ML20329A340 | |
| Person / Time | |
|---|---|
| Site: | University of California - Irvine |
| Issue date: | 01/14/2021 |
| From: | Michael Balazik NRC/NRR/DANU/UNPL |
| To: | |
| Tran L,NRR/DANU/UNPL,30147103 | |
| Shared Package | |
| ML20328A273 | List: |
| References | |
| Download: ML20329A340 (5) | |
Text
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 7 TO RENEWED FACILITY OPERATING LICENSE NO. R-116 THE BOARD OF REGENTS OF THE UNIVERSITY OF CALIFORNIA UNIVERSITY OF CALIFORNIA, IRVINE, NUCLEAR REACTOR FACILITY DOCKET NO. 50-326
1.0 INTRODUCTION
By letter dated August 20, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20274A377), as supplemented by letters dated October 15, 2020 (ADAMS Accession No. ML20297A680), and October 29, 2020 (ADAMS Accession No. ML20303A317), the Board of Regents of the University of California (the licensee) submitted a license amendment request (LAR) that would amend the technical specifications (TSs) for the University of California, Irvine (UCI), Nuclear Reactor Facility. The request would revise TS 6.1, Figure 1, UCI Reactor Organization Chart, to reflect organizational changes, change communication relationships, and clarify the direct reactor reporting line within the facilitys organizational structure.
2.0 REGULATORY EVALUATION
The U.S. Nuclear Regulatory Commission (NRC) staff evaluated the proposed changes based on the following regulations and guidance:
- Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, Section 50.36, Technical specifications, requires TSs to be included in utilization facility licenses, which includes research reactor licenses. 10 CFR 50.36(c)(5), Administrative controls, requires that TSs include provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
- 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, identifies licensing, regulatory, and administrative actions eligible for categorical exclusion from the requirement to prepare an environmental assessment or an environmental impact statement.
Enclosure 2
- NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content, Appendix 14.1, Format and Content of Technical Specifications for Non-Power Reactors, Section 6.1.1, Structure (ADAMS Accession No. ML042430055), provides guidance to licensees preparing research reactor applications and TSs regarding organizational structure.
- NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, Chapter 14, Technical Specifications (ADAMS Accession No. ML042430048), provides guidance for reviewing and evaluating the TSs submitted to the NRC by applicants for research reactor licenses.
- American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors, Section 6.1, Organization, and Section 6.1.1, Structure, provides guidance on administrative controls that should be included in the TSs for research reactors. The 2007 version is a revision of ANSI/ANS-15.1-1990 that is cited in NUREG-1537, Parts 1 and 2.
Sections 6.1 and 6.1.1 of the 2007 version are not substantively different from the 1990 version. However, Section 6.1.1 of the 1990 version provides examples of Level 4 operating staff as Class A and B Reactor Operators and trainees; this differs from the 2007 version, which provides examples of Level 4 operating staff as senior reactor operators, reactor operators, and trainees. Because the licensee uses the terms Senior Reactor Operator and Reactor Operator in the TSs, the NRC staff used the current version, ANSI/ANS-15.1-2007, to conduct this LAR review.
3.0 TECHNICAL EVALUATION
3.1 Technical Specification 6.1, Organization and Structure The licensee proposed to revise TS 6.1, Figure 1, UCI Reactor Organization Chart, to reflect organizational changes, change communication relationships, and clarify the direct reactor reporting line within the facilitys organizational structure. Specifically, the licensee proposed to revise TS 6.1, Figure 1, as follows:
- to remove the Deputy Director of Environmental Health and Safety (EH&S) to accurately reflect an organizational change that eliminated the position from the licensees organizational structure;
- to change the titles of the Vice Chancellor and Associate Vice Chancellor of the Administration and Business Services to Division of Finance and Administration because of an organizational change at UCI;
- to change the communication relationship between the Director of EH&S and the Radiation Safety Committee from a reporting to a working relationship; and
- to clarify the direct reactor reporting and communication relationships within the UCI organization.
The current TS 6.1, Figure 1, UCI Reactor Organization Chart, states:
The proposed TS 6.1, Figure 1, states:
NUREG-1537, Part 2, Chapter 14, Technical Specifications, provides guidance that the review should conform to ANSI/ANS-15.1-2007 and NUREG-1537, Part 1. The NRC staff evaluated
the proposed changes to TS 6.1, Figure 1, using the guidance in ANSI/ANS-15.1-2007, Section 6.1.1, which states that radiation safety personnel shall report to Level 2 or higher and that other organizational levels or staffing may be added to meet specific facility needs. The NRC staff also used the guidance in NUREG-1537, Part 1, Appendix 14.1, Section 6.1.1 that states, in part, that information should be clearly stated, including how and when the radiation safety staff communicates with the facility manager and the Level 1 management to resolve safety issues.
In addition, the NRC staff evaluated the proposed changes to TS 6.1, Figure 1, to ensure that the changes are consistent with the requirements of Section 6, Administrative Controls of the TSs. TS 6.1.2, Responsibilities, Section e, states, in part, that the Radiation Safety Officer shall report to the Office of Environmental Health and Safety.
The NRC staff finds that, with respect to the proposed removal of the Deputy Director, EH&S from the UCI organizational chart, the Radiation Safety Officer and Radiation Safety Staff will continue to have reporting responsibility to the Office of Environmental Health and Safety and to Level 1 management and will continue to meet the requirements of TS 6.1.2, Section e, which is consistent with the guidance in NUREG-1537, Part 1, Appendix 14.1, Section 6.1.1 and ANSI/ANS-15.1-2007. Therefore, based on the information above, the NRC staff concludes that the removal of the Deputy Director, EH&S from TS 6.1, Figure 1, is acceptable.
The licensee also proposed to change TS 6.1, Figure 1, by deleting Administration and Business Services (ABS) from the title of the Vice Chancellor and replacing it with Division of Finance and Administration (DFA) to reflect a name change in the UCI organization.
Additionally, the licensee proposed to delete ABS from the Associate Vice Chancellor title and replace it with the corresponding acronym, DFA. The NRC staff evaluated these proposed changes using the guidance in ANSI/ANS-15.1-2007, Section 6.1, which states that the functions, assignments, and responsibilities shall be specified. The NRC staff finds that the updated organizational name does not alter the responsibilities and structure of the operating organization. The NRC staff also finds that the proposed change to TS 6.1, Figure 1, is to the position or title of an officer of the licensee and is consistent with ANSI/ANS-15.1-2007, Section 6, in that the TSs continue to specify that UCI has the organization structure and management responsible for reactor facility operations. Therefore, based on the information above, the NRC staff concludes that changing the above organizational names in TS 6.1, Figure 1, is acceptable.
The licensee proposed to change the communication relationship between the Director of EH&S and the Radiation Safety Committee from a reporting to a working relationship in TS 6.1, Figure 1. This change is shown in proposed TS 6.1, Figure 1, by changing the communication relationship from a dashed to a solid line between the two organizations. NUREG-1537, Part 1, Appendix 14.1, Section 6.1.1 states, in part, that information should be clearly stated, including how the radiation safety staff communicates with Level 1 management. The NRC staff finds that with the proposed change, the Radiation Safety Officer and Radiation Safety Staff continue to maintain a direct communication path through the Associate Vice Chancellor to Level 1 management. Further, the NRC staff finds that the Radiation Safety Committee maintains a direct reporting path to Level 1 management through the Vice Chancellor of Research.
Therefore, based on the information above, the NRC staff concludes that changing the communication relationship between the Director of EH&S and the Radiation Safety Committee from a reporting to a working relationship in TS 6.1, Figure 1, is acceptable.
The licensee proposed to add a legend to TS 6.1, Figure 1, to specify reporting, direct reactor reporting, and working relationships. The proposed change specifies that solid lines are reporting relationships, dashed lines are working relationships, and bold text indicates direct reactor reporting. TS 6.1.1 states, in part, that the reactor is related to the University structure of positions shown in the organization chart, Figure 1, where solid lines represent direct reporting responsibility, dashed lines indicate working relationships. The NRC staff finds that the proposed change to specify reporting and working relationships in TS 6.1, Figure 1, is consistent with TS 6.1.1 and, therefore, acceptable. The NRC staff also finds that specifying direct reactor reporting in TS 6.1, Figure 1, ensures that the organization for the management and operation of the reactor facility is structured. Therefore, based on the information above, the NRC staff concludes that specifying direct reactor reporting in TS 6.1, Figure 1, is acceptable.
3.2 Conclusion The NRC staff reviewed and evaluated the licensees proposed changes to TS 6.1, Figure 1, in the LAR, as supplemented. The NRC staff finds that the revision to TS 6.1, Figure 1, that reflects organizational changes, changes communication relationships, and clarifies direct reactor reporting lines within the facilitys organizational structure is consistent with the guidance in NUREG-1537, Part 1, Appendix 14.1 and ANSI/ANS-15.1-2007, Section 6. The NRC staff also finds that the proposed changes will continue to provide organization and management controls that assure operation of the facility in a safe manner as required by 10 CFR 50.36(c)(5).
Therefore, based on its review, the NRC staff concludes that the proposed changes to TS 6.1, Figure 1, are acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment changes recordkeeping, reporting, or administrative procedures or requirements; changes the name, position, or title of an officer of the licensee; or changes the format of the license or otherwise makes editorial, corrective, or other minor revisions.
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: M. Balazik, NRR Date: January 14, 2021