ML22152A233
| ML22152A233 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 06/07/2022 |
| From: | Edward Helvenston NRC/NRR/DANU/UNPL |
| To: | Hawari A North Carolina State University |
| Helvenston E | |
| References | |
| EPID L-2022-NFA-0004 | |
| Download: ML22152A233 (7) | |
Text
June 7, 2022 Dr. Ayman I. Hawari, Director Nuclear Reactor Program Department of Nuclear Engineering North Carolina State University Campus Box 7909 2500 Stinson Drive Raleigh, NC 27695-7909
SUBJECT:
NORTH CAROLINA STATE UNIVERSITY - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF THE APPLICATION FOR A LICENSE AMENDMENT REGARDING FUELED EXPERIMENTS FOR THE PULSTAR RESEARCH REACTOR (EPID L-2022-NFA-0004)
Dear Dr. Hawari:
By letter dated April 18, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22108A168), North Carolina State University (NCSU) applied for an amendment to Facility Operating License No. R-120 for the NCSU PULSTAR Research Reactor. The license amendment request (LAR) proposes to amend NCSUs license conditions (LCs) and technical specifications (TSs) to allow it to increase the quantity of uranium-235 (U-235) in fueled experiments; to allow it to perform fueled experiments with other fissionable material (e.g., plutonium and neptunium) in addition to U-235; and to allow it to perform vented fueled experiments. The amendment would also make other changes related to fueled experiments, including revising the TS definition of fueled experiment, and increasing license possession limits for fissile and fissionable materials to be used in fueled experiments. NCSU stated that the amendment would allow the LCs and TSs to accommodate its planned experimental needs.
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 technical specifications) 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 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 July 7, 2022. If the supplement is not received by the agreed date, the application will not be accepted for review pursuant to 10 CFR 2.101, Filing of application, and
A. Hawari 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 Gerry Wicks and Dr. Colby Fleming of NCSU on June 3, 2022. If you have any questions, please contact Justin Hudson at (301) 287-0538 or by electronic mail at Justin.Hudson@nrc.gov, or me at (301) 415-4067 or by electronic mail at Edward.Helvenston@nrc.gov.
Sincerely, Signed by Helvenston, Edward on 06/07/22 Edward Helvenston, 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. 50-297 License No. R-120
Enclosure:
As stated cc: See next page
North Carolina State University Docket No. 50-297 cc:
Department of Government Affairs Gerald Wicks, CHP 2001 Mail Service Center Reactor Health Physicist Raleigh, NC 27699-2001 Department of Nuclear Engineering North Carolina State University Dr. Kostadin Ivanov, Head Campus Box 7909 Department of Nuclear Engineering 2500 Stinson Dr.
North Carolina State University Raleigh, NC 27695-7909 Campus Box 7909 Raleigh, NC 27695-7909 Mrs. Nina Colby Fleming, Ph.D.
Acting Manager of Engineering and W. Lee Cox, Section Chief Operations Department of Health and Human Services Nuclear Reactor Program Division of Health Service Regulation 2500 Stinson Drive Radiation Protection Section Raleigh, NC 27695-7909 1645 Mail Service Center Raleigh, NC 27699-1645 Test, Research and Training Reactor Newsletter Dr. Louis Martin-Vega, Dean Attention: Amber Johnson College of Engineering Dept of Materials Science and Engineering North Carolina State University University of Maryland 113 Page Hall 4418 Stadium Drive Campus Box 7901 College Park, MD 20742-2115 Raleigh, NC 27695-7901
ML22144A113 NRR-106 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA NAME JHudson EHelvenston NParker DATE 6/1/2022 6/1/2022 6/2/2022 OFFICE NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME JBorromeo EHelvenston DATE 6/7/2022 6/7/2022 OFFICE OF NUCLEAR REACTOR REGULATION SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF A LICENSE AMENDMENT REQUEST NORTH CAROLINA STATE UNIVERSITY PULSTAR RESEARCH REACTOR License No. R-120; Docket No. 50-297 By letter dated April 18, 2022 (Agencywide Documents Access and Management System ADAMS Accession No. ML22108A168), North Carolina State University (NCSU) submitted a license amendment request (LAR) related to fueled experiments at the NCSU PULSTAR research reactor.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following information is necessary to make the application complete and acceptable for docketing:
- 1. Radiation Dose Monitoring for the Public The LAR, in the Executive Summary and in Section 8, Dose Assessment, states that proposed limits for vented fueled experiments are based on a planned release of fission products from the experiment that results in a public dose of 10 millirem (mrem) in 1 year.
Discuss how NCSU plans to ensure it meets the 10 mrem as low as is reasonably achievable constraint on annual public doses from airborne radioactive effluents in Title 10 of the Code of Federal Regulations (10 CFR) 20.1101, Radiation protection programs, paragraph (d), if a single experiment could result in a 10 mrem public dose, given that NCSU could perform multiple vented fueled experiments per year and that the reactor also produces effluents (e.g.,
argon-41) from sources other than fueled experiments. Although the LAR, in the Introduction, states that [m]onitoring, experiment and administrative controls, and frequent dose assessment from airborne effluent is made to ensure the 10 CFR Part 20 dose constraint of 0.01 rem per calendar year is not exceeded for all airborne effluent, clarify, as appropriate, how NCSU will design and plan vented fueled experiments (before experiments are started) to ensure they will not cause the constraint to be exceeded.
The NRC staff also noted that the LAR, in the technical specification (TS) 3.8 discussion in the Discussion of Technical Specification Changes, appears to indicate that proposed limits for vented fueled experiments are based on three percent of the annual public dose limit in 10 CFR 20.1301, Dose limits for individual members of the public (i.e., 3 mrem), instead of 10 mrem. Clarify this apparent discrepancy.
- 2. Surveillance Requirements Related to Fueled Experiments The NRC staff noted that some limiting conditions for operation (LCOs) for fueled experiments, for example, the vented fueled experiment flow rate limit and the requirement for the vented fueled experiment exhaust isolation function, do not appear to have corresponding surveillance requirements. All LCO TSs related to fueled experiments should have corresponding surveillance TSs, unless they are LCOs describing basic design features of experiments (i.e.,
the types of TSs discussed in Section 3.8 of American National Standards Institute/American Enclosure
Nuclear Society-15.1-2007 and Section 3.8 of Appendix 14.1 to NUREG-1537, Part 1 (ML042430055)). As appropriate, provide surveillance TSs for equipment and operating conditions or limits that are credited in the fueled experiment safety analysis and included as LCOs.
- 3. Possession Limit Changes Provide requested possession limit license condition changes which more clearly describe the form and isotope(s) of uranium (U), neptunium (Np), and plutonium (Pu) that NCSU desires to possess for use in fueled experiments. The requested possession limits should consider that U, Np, and Pu are typically isotopically impure, and that Np is not classified as special nuclear material pursuant to 10 CFR Part 70, Domestic Licensing of Special Nuclear Material. The NRC staff noted the NCSUs fueled experiment analyses appear to discuss irradiation of uranium-233, and therefore, the requested possession limits should also include uranium-233, if appropriate.
- 4. Change Pages for the Technical Specifications The NRC staff noted that the LAR Attachment 3 appears to have a complete, clean copy of the TSs including all changes proposed in the LAR. To reduce the level of TS review required, the NRC recommends that the LAR only include clean TS change pages for pages that would be changed by the proposed LAR. In addition, the NRC staff recommends that clean change pages include change bars indicating areas of change (similar to the markup change pages in LAR ).
- 5. Confinement and Ventilation System Requirements for Fueled Experiments The NRC staff noted that the LAR does not propose any changes to current TSs 3.6 and 4.5 related to the PULSTAR reactor confinement and ventilation systems. However, the NRC staff noted that some changes to these TSs may be appropriate, given the LARs request to increase the scope of fueled experiments that may be conducted at the reactor, and the details of the LAR analyses. For example, current TS 3.6 does not appear to require any confinement or ventilation equipment when irradiated fueled experiments are being moved or handled, or during decay time when fission products could still be in the vented fueled experiment exhaust system following reactor shutdown. In addition, current TS 3.6 does not appear to include the specific confinement filter efficiencies credited in the LAR analyses. Discuss whether additional changes to current TSs 3.6 and/or 4.5 are necessary as part of the LAR.
- 6. Additions, Edits, and Removals from the Technical Specifications The LAR does not appear to contain a sufficient description of, or justification for, all proposed TS changes. For example, the change to TS 3.5 to make its requirements apply when irradiated fuel is being moved, the removal of the current radiation monitor setpoint requirements from TS 3.5, and the removal of certain fueled experiment requirements from TS 3.8 do not appear to be fully described and justified. The application should be supplemented to provide a complete description of all of the proposed changes compared to the current NRC-approved TSs (i.e.,
each deletion or modification or a portion of a current TS, including minor numbering, formatting, or editorial changes, as well as each addition to a current TS). In addition, the application should be supplemented to include a detailed discussion and/or analysis, as applicable, justifying each change. Where a current TS would be revised or replaced, the justification should discuss why
the current TS wording is no longer applicable or necessary and may be removed, as well as why the proposed new TS wording is acceptable.
- 7. Technical Specification Limit for Vented Fueled Experiments Proposed TS 3.8 provides a limit for vented fueled experiments that is based on the total fission gas activity (in Curies) released from the experiment per day. However, it does not appear this limit would comprehensively bound vented fueled experiments at NCSU consistent with the LAR analysis, because the activity limit is based on total Curies of all gaseous fission products released, without defining limits for any specific fission product(s), or production or inventory of fission products. The NRC staff notes that based on specific conditions of vented fueled experiments (for example, if a longer experiment exhaust decay time than the proposed TS 3.8.d.iv.4 minimum-required 100 minutes were used), the quantities of individual fission products released (and corresponding doses), and vented fueled experiment inventories available for an accidental release, could vary if an experiment were releasing fission products at the TS limit. Provide proposed TS limit(s) for vented fueled experiments that would comprehensively bound vented fueled experiments.