ML20343A278

University of Massachusetts Lowell, Draft Follow-up Audit Questions

ML20343A278
Person / Time
Site:	University of Lowell
Issue date:	12/03/2020
From:	Office of Nuclear Reactor Regulation
To:	Univ of Massachusetts - Lowell
Shared Package
ML20343A276	List: ML20343A277 ML20343A278
References
Download: ML20343A278 (4)

Text

Follow-up 2020 Audit Questions Related to UMLs Supplemental Information Submitted September 30, 2020, and Related to Financial Information

1. Audit item 1: Some of the TS bases still do not appear to be consistent with the revised TSs and/or information in the SAR, as supplemented.

a. TS 2.2.1 basis: Based on information in UMLs response to RAI-13.1 (ADAMS Accession No. ML17090A350), a step reactivity transient is no longer bounding.

b. TS 3.1.1 basis: A value appears to be missing in the first sentence.

c. TS 3.2.1 basis: The basis appears inconsistent with information in UMLs response to RAI-13.1.

d. TS 3.2.2 basis: The basis appears inconsistent with information in UMLs response to RAI-13.1.

e. TS 3.3 basis: The basis does not appear to reflect UMLs proposed TS 5.2 change to allow a titanium heat exchanger.

f. TS 3.6.1 basis: The basis states that TSs 3.6.1(1) provides minimum equipment when the reactor is operating, but the TS 3.6.1(1) applicability is not limited to reactor operation.

g. TS 4.3 basis: The basis does not appear to address TS 4.3(4).

h. TS 4.4 basis: The first sentence appears to contain a typographical error, and does not appear to address the proposed change to TS 4.4(1) to verify intake fan operability at 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> intervals.

i. TS 4.6 basis: The basis appears to contain 2 typographical errors (missing space in the first sentence, and 10CRF in the last sentence).

2. Audit item 10: The revised applicability statement appears to be missing a comma after reactor.

3. Audit item 14: Revised proposed TS 3.2.3 still does not appear to require that at least one of the two required reactor power level channels be the log power/period monitoring channel for natural convection mode. Additionally, supplemental docketed 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, and which states that the required Log PPM channel provides redundancy and diversity to the single required linear channel, does not appear to have been provided.

4. Audit item 17: Although references to SAR section that describe primary piping limit switches have been added to the TS bases, it is still unclear which specific switches TS 3.2.3, item 13, applies to.

5. Audit item 21: UML proposed an alternative approach to that discussed during the audit, but it is not clear whether UMLs proposed alternative administrative control requiring beam tube shutters be closed when the reactor is in the stall pool with the pool divider gate in place should be added as an additional TS.

6. Audit item 23: UML proposed additional changes to TS 3.4.1 (specifically, revising TS 3.4.1(2), and deleting TS 3.4.1(3)) beyond those discussed in audit, but it is not clear whether those changes are appropriate or facility-specific. Additionally, it appears some information added to the basis for TS 3.4.1 (specifically, the references to significant fission product inventory and reactivity transients) in conjunction with audit item 23 may not be accurate or appropriate.

7. Audit item 25: The revised TS 3.5(2) contains an apparent typographical error (extra period at the end of the TS).

8. Audit item 26: It is not clear whether UML has completed a 10 CFR 50.59 evaluation of its radiation monitoring system changes and has implemented (or will implement) the changes prior to issuance of a renewed license, or whether UML is requesting NRC review and approval of these changes in conjunction with its license renewal review. Also, supplemental docketed information confirming that new radiation monitor alarms will be provided by the existing annunciator panel does not appear to have been provided.

9. Audit item 31: The typographical error does not appear to have been corrected.

10. Audit item 37: It is still not clear that the TS applies for any condition, regardless of whether the beam ports are being accessed.

11. Audit item 38: TS 4.0, item A., has been revised, but the revisions to the TS do not appear to reflect other revisions to TS 4.6, and whether it is appropriate for revised TSs 4.6(3) and 4.6(4) to also be included in the list of TSs that may not be deferred. Additionally, TS 4.0, item A., includes the wording, as soon as practical, but it appears that as soon as practicable may have been what was meant.

12. Audit item 46: TSs 4.2.3(2) and 4.2.3(6) continue to use the language or prior to each operation extending more than one day which is inconsistent with the TS definitions.

13. Audit item 49: The revised proposed TS 4.4(3) language fail-safe condition does not appear to be consistent with fail-safe position used in the corresponding LCO and the TS 4.4 basis.

14. Audit item 54: In addition to changes discussed during the audit, the TS 5.1(2) revision added an exclusion describing areas that the reactor licensed boundary does not include, but the specific areas excluded, and the purpose of this exclusion, is not clear.

15. Audit item 56: Although the proposed TS 5.2(3) and TS 5.2 basis were revised as discussed during the audit, the possible use of a titanium heat exchanger does not appear to be discussed in the SAR, as supplemented, and the justification for the acceptability of titanium is not clear.

16. Audit item 62: The supplemental information states that 10 CFR 70.24(a) would apply for any SNM stored, handled, or used outside of the pool, but does not appear to confirm that

any fissionable material UML stores, handles, or uses outside of the pool or licensed containers is less than the quantities specified in 10 CFR 70.24(a).

17. Audit item 75: The revised proposed TSs include TS 6.4(2) which requires the Reactor Supervisor or Radiation Safety Officer to approve procedures, but it not clear whether their designees may approve procedures. Additionally, the revised proposed TS 6.4(1) requires that RSSC review all procedures, but this appears to conflict with UMLs response to RAI-14.6.15 (ADAMS Accession No. ML19064B373). Also, in addition to changes discussed during the audit, UML proposed to delete the requirement that procedures shall be adequate to ensure the safe operation of the reactor and gamma irradiation facilities from TS 6.4(1), but the justification for this deletion is not entirely clear.

18. Audit item 78: The revised proposed TS does not appear to require that experiments be carried out using written procedures.

19. Audit item 80: The revised cross-references in proposed TSs 6.6.1(3) and 6.6.1(5) do not appear to be correct.

20. Audit item 91: The revised proposed TS 6.8.3(5) appears to refer to limiting condition for operations instead of the limiting condition for operation used elsewhere in the TSs.

21. Audit item 97.i: The documents provided with UMLs supplemental information do not appear to include coversheets for part of item (5) under audit item 97.i, specifically, supporting documentation (TFS PPM configuration record and test reports).

22. Audit item 97.xvii: The supplemental information states that similar information from the 1985 SAR describing the startup counter drive will be added to an updated SAR, but the supplemental information does not provide a specific, current description of the startup counter drive and its configuration.

23. Audit item 97.xix: The supplemental information does not appear to provide the correct nominal value of the regulating rod speed, or indicate which section(s) of the SAR have incorrect information.

24. TS 6.4(3) (additional TS change separate from audit items): In its revised proposed TSs, UML deleted the requirement that temporary deviations from procedures be documented and reviewed pursuant to 10 CFR 50.59. However, the justification for removing the requirement to document such deviations is not clear. Additionally, the NRC staff notes that all procedure changes, including temporary changes, are potentially subject to 10 CFR 50.59.

25. TS 6.8.1(9) (additional TS change separate from audit items): UML revised the proposed TS for greater consistency with ANSI/ANS-15.1-2007, but it is not clear whether the revised TS is appropriately facility-specific, if proposed TS 6.2.4 does not require that all audits be performed by the RSSC.

26. TS 4.6(1) (inconsistency between clean and tracked changes versions of revised proposed TSs): The clean version of TS 4.6(1) appears to read monitoring channels in Specification 3.6.1(1) but the tracked changes version appears to read monitoring channels in TS 3.6.1(1).

27. Financial information (if, for any of the questions below, there is no change from previously submitted information, please clearly state no change, or not applicable):

1. Please provide updates for the following information:

a. Projected operating costs of the UMLRR for each of the fiscal years (FYs) 2020 through 2025 (or the first five-year period after the projected license renewal).

b. UMLs source of funding to cover the operating costs for the above FYs.

2. As described above, please provide updates for the following information:

a. A current decommissioning cost estimate in 2020 dollars for the UMLRR to meet the NRCs radiological release criteria for decommissioning the facility. Accordingly, describe the basis on how the decommissioning cost estimate was developed.

b. A summary of total decommissioning costs broken down into the categories of labor, waste disposal, other items in current dollars, and a contingency factor.

c. A statement of the decommissioning method to be used

d. A description of the means of adjusting the cost estimate and associated funding level periodically over the life of the facility, pursuant to 10 CFR 50.75(d)(2)(iii).

e. A numerical example showing how the decommissioning cost estimate will be updated periodically in the future.

3. As described above, please provide updates for the following information:

a. An updated statement of intent (SOI) which includes the current (2020 dollars) cost estimate for decommissioning, a statement that funds for decommissioning will be obtained when necessary, the typed name and title of the signator, the original signature of the signator, and the signators oath or affirmation attesting to the information.

b. Documentation verifying that the signator of the SOI is authorized to execute such a document that binds the applicant financially. For example, provide a copy of UMLs governing board or equivalent resolution or a copy of an official UML delegation of authority showing that the signator of the SOI has been authorized by UML to bind the university financially to at least the funding for the decommissioning of the UMLRR.