ML21253A001

Us Department of Defense Armed Forces Radiology Research Institute - Regulatory Audit Plan for Digital Instrumentation and Control System Upgrade

ML21253A001
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	09/13/2021
From:	Cindy Montgomery NRC/NRR/DANU
To:	Cook A US Dept of Defense, Armed Forces Radiobiology Research Institute
Montgomery C
References
EPID L-2020-NFA-0012
Download: ML21253A001 (9)

Text

September 10, 2021 Mr. Andrew Cook Interim Reactor Facility Director Armed Forces Radiobiology Research Institute 4555 South Palmer Road, Building 42 Bethesda, MD 20889-5648

SUBJECT:

U.S. DEPARTMENT OF DEFENSE ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE - REGULATORY AUDIT RE: DIGITAL INSTRUMENTATION & CONTROL SYSTEM UPGRADE (EPID L-2020-NFA-0012)

Dear Mr. Cook:

By letter dated November 10, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20318A339), as supplemented by letters dated February 5, 2021, and February 11, 2021, (ADAMS Accession Nos. ML21036A297 and ML21042B841, respectively) 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 requested licensing action would replace and upgrade the instrumentation and control (I&C) systems for the reactor and would amend the technical specification related to the upgrade.

The U.S. Nuclear Regulatory Commission (NRC) staff will conduct an onsite and remote regulatory audit from September 13 to September 15, 2021, and continue the audit remotely (via teleconference) as necessary throughout the review period, in order to expedite the NRC staff review. The intent of the audit is to gain a better understanding of the application and all proposed changes to the facility. The audit will include review of documentation, observation of the facility, and discussions with facility personnel and management. In addition, the audit will identify information that will support the basis of the licensing decision and identify information that needs to be docketed. The enclosed audit plan provides additional details of the objective and scope of the audit. To facilitate an efficient audit, please provide ready access to working space, requested documentation and other materials, necessary personnel, and areas of the facility.

Following completion of the audit, the NRC staff will provide an audit summary. The summary will include a description of any information identified during the audit that will need to be docketed to supplement the application and information that that is needed to allow the NRC staff to continue its review. You will have the opportunity to supplement the application to provide the additional information or the option to withdraw the application.

A. Cook 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 09/10/21 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:

Manager Director, Maryland Office of Planning Nuclear Programs 301 West Preston Street Maryland Department of Natural Resources Baltimore, MD 21201 Tawes B-3 Annapolis, MD 21401 Montgomery County Executive 101 Monroe Street, 2nd Floor Colonel Mohammad Naeem, MD, FCCP, Rockville, MD 20850 FACR, Medical Corps, US Army Director, Armed Forces Radiobiology Environmental Program Manager III Research Institute Radiological Health Program 4301 Jones Bridge Road Air & Radiation Management Adm. Bethesda, MD 20814 Maryland Dept of the Environment 1800 Washington Blvd., Suite 750 Baltimore, MD 21230-1724 Director Air & Radiation Management Adm. Test, Research and Training Maryland Dept of the Environment Reactor Newsletter 1800 Washington Blvd., Suite 710 Attention: Amber Johnson Baltimore, MD 21230 Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

ML21253A001 NRR-088 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME CMontgomery JBorromeo, PBoyle for CMontgomery DATE 8/13/2021 9/10/2021 9/10/2021 OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT PLAN REGARDING AMENDMENT TO FACILITY OPERATING LICENSE NO. R-84 ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE TRIGA-MARK F TANK-TYPE NUCLEAR REACTOR FACILITY DOCKET NO 50-170

Background

By application dated November 10, 2020 (Reference 1) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20318A339), as supplemented by letters dated February 5, 2021 (Ref. 2), and February 11, 2021 (Ref. 3), (ADAMS Accession Nos.

ML21036A297 and ML21042B841, respectively) Armed Forces Radiobiology Research Institute (the licensee or AFRRI) submitted an application for an amendment to Facility Operating License No. R-84 for the Armed Forces Radiobiology Research Institute Training, Research, Isotopes, General Atomics (TRIGA)-Mark F tank-type nuclear reactor facility. The requested licensing action would upgrade the instrumentation and control (I&C) systems for the AFRRI TRIGA reactor by replacing it with new analog or digital instrumentation and control (DI&C) systems. Additionally, the licensee requested editorial changes to its technical specifications (TSs).

The I&C systems for AFRRI consists of hybrid analog and digital system to monitor, protect, and control the reactor. The proposed I&C systems include a hardwired Reactor Protection System (RPS) with dedicated displays and controls so that safe operation and monitoring of the reactor is not affected if the digital systems become unavailable. Components of the I&C systems will be installed in the Data Acquisition Cabinet (DAC). The reactor will be operated from the Control System Console (CSC) located in the control room.

This regulatory audit is intended to assist NRC staff in confirming information submitted as part of the licensing amendment request.

Regulatory Bases for the Audit The purpose of this audit is to support the NRC staffs review of the licensees proposed I&C systems described in the Chapter 7, Instrumentation and Control Systems, of the AFRRI proposed safety analysis report (SAR) in accordance with the applicable regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) and applicable guidance provided in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 1, Format and Content, and Part 2, Standard Review Plan and Acceptance Criteria, (ADAMS Accession Nos. ML042430055 and ML042430048, respectively).

Enclosure

Regulatory Audit Scope As part of the audit, the NRC staff will review non-docketed procedures and records related to the design and development processes followed by General Atomics for both analog and digital instrumentation and control systems. In addition, during the audit, the NRC staff will interview key AFRRI personnel to discuss the acceptance process followed and proposed operation of the system. The NRC staff will be evaluating whether the results of these actions substantiate the description and assessments included in the proposed SAR for AFRRI.

Information Necessary for the Regulatory Audit AFRRI should be prepared to have the following documentation and information available for the audit, as applicable:

Quality Assurance Documentation Project Quality Assurance Plan Verification & Validation Plan Functional Requirements Specification Hardware Design Document Human Factors Documentation Logic Diagrams and Description Neutron Flux Detection System Documentation System Architecture Diagram Software Requirements Specification and Software Design Description documents Test Plan, Test Procedures, Test Results Factory Acceptance Testing Documentation Operating and Maintenance Procedures Reports documenting results of Verification & Validation Secure Development and Operational Environment Documentation Team Assignments The NRC staff performing this audit will be:

Rossnyev Alvarado (Technical Reviewer)

Joe Ashcraft (Technical Reviewer)

Patrick Boyle (Technical Reviewer)

Cindy Montgomery (Project Manager)

Logistics The audit will take place at AFRRI in Bethesda, MD and via teleconference. The audit will start on the morning of September 13, 2021 continue through the afternoon on September 15, 2021 and will continue remotely (via teleconference) as necessary until the NRC staff have adequate understanding of the issues to be addressed to complete the review of the LAR.

Deliverables At the completion of the regulatory audit, NRC staff will prepare a regulatory audit report, which will be issued after the audit has been completed.

Audit Questions:

The questions for discussion during the audit are primarily based on the open items list provided as an enclosure to this letter. At the conclusion of the audit, the staff will discuss necessary documents to be docketed and the potential requests for additional information (RAI) with the licensee. The goal of these discussions is that the licensee has a clear understanding of these potential requests.

Audit Schedule September 13, 2021 8:00 a.m. Entrance meeting, introductions, and project status 9:00 a.m. Begin Audit 12:00 p.m. Break for Lunch 1:00 p.m. Resume Audit 5:00 p.m. End for the day September 14, 2021 8:00 a.m. Meeting between NRC staff and AFRRI to discuss logistics for the day 8:15 a.m. Begin Audit 12:00 p.m. Break for lunch 1:00 p.m. Resume Audit 5:00 p.m. End for the day September 15, 2021 8:00 a.m. Meeting with NRC staff and AFRRI to discuss logistics for the day 8:15 a.m. Resume Audit 12:00 p.m. Break for Lunch 1:00 p.m. Resume Audit 4:00 p.m. Internal NRC staff meeting 4:30 p.m. Exit Meeting - Summary of audit, general overview of observations, and discussion of open items and potential RAIs 5:00 p.m. End for the Day As needed The NRC staff will continue audit interaction remotely (via teleconference) as needed.

References

1. AFRRI LAR for Digital I&C Upgrade dated November 10, 2020 (ADAMS Accession Nos.

ML20318A339, ML20318A340, ML20318A341, ML20318A342, ML20318A343, ML20318A344, ML20318A345, ML20318A346, ML20318A347, ML20318A348, and ML20318A349).

2. Response to NRC 01/08/2021 Letter re License Amendment Request for Facility Operating

License No. R-84 for the AFRRI TRIGA Reactor Docket No. 50-170, dated February 5, 2021 (ADAMS Accession Nos. ML21036A297, ML21036A298, ML21036A299, ML21036A300, and ML21036A301).

3. Transmittal of Proposed changes to the technical specifications in support of the license amendment request for the digital instrumentation and control upgrade for the AFRRI TRIGA Reactor, dated February 11, 2021 (ADAMS Accession Nos. ML21042B841 and ML21042B842).

Enclosure Open items for regulatory audit Open item(s) Topic Notes 4, 12 Power supply and distribution for I&C systems and components.

9 Operation of interlocks in the rod withdrawal circuit logic and display in the Interlocks Pane.

11 Operation and location of the Warning Pane.

12 Operation of the power On/Off pushbutton in the Mode Control Panel in the control console.

13, 14, 44, 45, 47, Operation of the magnet power key switch.

72, 94 14, 47, 48, 49, 62, Review scram loop logic.

94 15 Operation of the Acknowledge pushbutton.

21 Operation and logic for the transient rod.

22 Operation and logic of the control rods and Rod Control Panel.

23, 27, 29, 30, 32, Interlocks signals and operation of FIS.

33, 34, 37, 38, 40, 41, 44, 45, 47, 48, 49, 72 30, 33 Panel, signals and logic in the control boxes and status panel in the experiment room.

46 Operation of the lights in the FIS cabinet.

51 Configuration and use of NLW-1000 signal trips.

64, 73 Configuration and operation of the steady-state timer.

65 Configuration when erroneous indications or out of range of a parameter is indicated in the control console.

67, 68 Review procedures for calibration of nuclear instruments, including adjusting setpoints.

Open item(s) Topic Notes 70 Configuration and operation of the Primary Coolant Conductivity.

73, 75 Test of timers in the control console.

74 Configuration, operation, and test of the two rotary test switches for the scrams and interlocks in the reactor control mode control pane.

76 Operation of the pulse time scram.

77 Identification and labeling of systems and components.

80 Configuration management and control of the TRIGA basic program installed in the console system.

81 Function in the CSC to gather data from the DAC and process I/O signals.

82 Operation of the automatic bank rod and rods available.

83 Observe operation modes (e.g., startup test mode, administrative mode, etc.) available in the CSC.

86, 87, 89, 90, 91 Confirm the parameters shown in the control console displays and how the operator navigate through the different displays and panes.

88 Use of and access to the printer included with the control console.

92, 93 Configuration, operation and communication between DI/O drawer and the CSC.

101 Configuration and use of the primary coolant conductivity.

102 AFRRI Digital Upgrade Process.