ML21021A182
| ML21021A182 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 01/08/2021 |
| From: | Cindy Montgomery NRC/NRR/DANU/UNPL |
| To: | Tomlinson W US Dept of Defense, Armed Forces Radiobiology Research Institute |
| Montgomery C | |
| References | |
| EPID L-2020-NFA-0012 | |
| Download: ML21021A182 (6) | |
Text
January 8, 2021 Mr. Walter Dale Tomlinson Reactor Facility Director Armed Forces Radiobiology Research Institute 4555 South Palmer Road, Building 42 Bethesda, MD 20889-5648
SUBJECT:
ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF THE APPLICATION FOR A LICENSE AMENDMENT RE: UPGRADE OF DIGITAL INSTRUMENTATION AND CONTROL SYSTEM (EPID L-2020-NFA-0012)
Dear Mr. Tomlinson:
By letter dated November 10, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20318A339), and enclosures (ADAMS Accession Nos. ML20318A340, ML20318A343, ML20318A346, ML20318A347, ML20318A348, ML20318A349), Armed Forces Radiobiology Research Institute applied for an amendment to Facility Operating License No. R-84 for the Armed Forces Radiobiology Research Institute TRIGA-Mark F tank-type nuclear reactor facility. The license amendment request proposes an upgrade to the digital instrumentation and control system and related technical specification (TS) changes.
Consistent with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, an application to amend a license (including the TSs) must be filed with the Commission, as specified in 10 CFR Section 50.4, Written communications. The application must fully describe the changes desired, and follow, as far as applicable, the form prescribed for the original application. Section 50.34, Contents of applications; technical information, of 10 CFR addresses the content of technical information required and stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The U.S. Nuclear Regulatory Commission (NRC) staff performed an acceptance review of the license amendment request (LAR) and determined that the information described in the enclosure to this letter is needed to find the application acceptable and begin the detailed technical review. Accordingly, the NRC staff requests a supplement to the application to address the information described in the enclosure to this letter by 30 days from the date of this letter.
W. Tomlinson If the supplement is not received by the agreed date, the application will not be accepted for review pursuant to 10 CFR Section 2.101, Filing of application, and the NRC may cease its associated review activities. Any request for additional time to provide the supplement should include the reason for requesting additional time and a proposed date to provide the supplement to allow the NRC staff to make an informed decision on whether to grant the request.
The NRC staff discussed the enclosure and the time frame for providing a supplement with you on December 10, 2020. If you have any questions, please contact me at (301) 415-3398, or by electronic mail at Cindy.Montgomery@nrc.gov.
Sincerely, Signed by Montgomery, Cynthia on 01/08/2021 Cindy Montgomery, Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-170 License No. R-84
Enclosure:
As stated cc: See next page
Armed Forces Radiobiology Research Institute Docket No. 50-170 cc:
Director, Maryland Office of Planning 301 West Preston Street Baltimore, MD 21201 Montgomery County Executive 101 Monroe Street, 2nd Floor Rockville, MD 20850 Environmental Program Manager III Radiological Health Program Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd., Suite 750 Baltimore, MD 21230-1724 Director Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd., Suite 710 Baltimore, MD 21230 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Manager Nuclear Programs Maryland Department of Natural Resources Tawes B-3 Annapolis, MD 21401 Colonel Mohammad Naeem, Director Armed Forces Radiobiology Research Institute 4301 Jones Bridge Road Bethesda, MD 20814
ML20356A297 NRR-106 OFFICE NRR/DANU/PM NRR/DANU/LA NRR/DEX/BC NRR/DANU/BC NRR/DANU/PM NAME CMontgomery NParker MWaters GCasto CMontgomery DATE 12/22/2020 12/22/2020 12/29/2020 12/29/2020 01/08/2021 OFFICE OF NUCLEAR REACTOR REGULATION SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF A LICENSE AMENDMENT REQUEST ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE TRIGA-MARK F TANK-TYPE NUCLEAR REACTOR FACILITY LICENSE NO. R-84; DOCKET NO. 50-170 By letter dated November 10, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20318A339), and enclosures (ADAMS Accession Nos. ML20318A340, ML20318A343, ML20318A346, ML20318A347, ML20318A348, ML20318A349), the Armed Forces Radiobiology Research Institute (AFRRI) submitted a license amendment request (LAR) for the AFRRI Training, Research, Isotopes, General Atomics
[TRIGA] Reactor. The LAR is to replace and upgrade the digital instrumentation and control (I&C) systems for the reactor. In addition, AFRRI submitted modifications to its technical specifications (TSs) related to the upgrade of the digital I&C systems.
The U.S. Nuclear Regulatory Commission (NRC) staff performed an acceptance review of the LAR and determined that information is needed to find the application acceptable and begin the detailed technical review. The LAR described some of the proposed digital I&C systems that would replace the existing digital I&C systems and related modifications to AFRRI TSs.
However, the LAR is unclear and contradictory regarding the scope of review requested for NRC approval and does not thoroughly identify the specific digital I&C systems proposed to be replaced and/or upgraded; nor does the LAR provide the necessary safety analysis of all proposed changes to the digital I&C systems.
The LAR should clearly identify, specify, and describe all systems being requested for approval, including all of those that are new, those that feature different/combined functions, as well as those that are being replaced like-for-like, have identical form and function, and/or contain equivalent equipment. Supporting information should be provided to demonstrate that the design satisfies applicable acceptance criteria in NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria (ADAMS Accession No. ML042430048), as well as why the change is safe. In a table similar to Table 1-1 in the LAR, a complete list of changes should be provided to summarize all changes to the AFRRI control systems. The updated table should list the equipment to be replaced or upgraded and the function performed by the old and new equipment, as well as provide a brief discussion of the difference between the old and new equipment.
As an example, in Enclosure 1c of the submittal letter, AFRRI stated that [w]ith the exception of the neutron flux detectors the entire control system has been replaced; however, the descriptions provided in the LAR for certain digital I&C systems are not clearly defined. The following examples represent additional comments made by the NRC staff that AFRRI can use to aid in their understanding of the complete information expected by the NRC staff in AFRRIs submission, and please note that the NRC staff emphasizes that this is not a complete list of items to be addressed:
Enclosure
The LAR identifies equipment that appears not to have been replaced, even though AFFRI stated that all systems were replaced. For example, the transient rod drive is described in detail but the transient rod drive is not being replaced.
The LAR identifies equipment that has been replaced with another piece of equipment that apparently provides the same functionality, but the LAR does not clearly describe the new equipments functionalities and components. Nor does the LAR provide an analysis of why that new piece of equipment is safe. For example, the NM-1000 is being replaced with NLW-1000 and NMP-1000. This replacement requires adding a new compensated ion chamber (CIC) near the reactor core. The LAR states that the new CIC will be coupled with the new NMP-1000. The LAR only mentions the new CIC in Table 1-1 and does not provide additional description or safety analysis; and the LAR provides no description of the impact of the geometry associated with the new location of the fission chamber and companion CIC.
The LAR identifies equipment that has been upgraded to a newer version; however, the LAR does not sufficiently describe the equipment; nor does the LAR provide a safety analysis for the new equipment. For example, the LAR states that the NP-1000 was upgraded to a new version of the channel and that the NP-1000 now features an added digital display and local controls using touchscreen buttons. However, the LAR does not discuss exactly what the upgrade includes, nor does it discuss information about the added display and local controls, nor how the analog safety channel is maintained since digital display and local controls via touchscreen were added.
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