ML23054A321
| ML23054A321 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 02/23/2023 |
| From: | GE-Hitachi Nuclear Energy Americas |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23054A319 | List: |
| References | |
| M230008 | |
| Download: ML23054A321 (1) | |
Text
GEH Supplemental Information for NTR License Renewal Application DOCUMENT PURPOSE:
This document is an accompanying document to the GE-Hitachi submittal of the final Technical Specifications (TSs) and Safety Analysis Report (SAR) related to renewal of the R-33 operating license for the GE-H Nuclear Test Reactor.
Items 1.0 and 2.0 below are specific requests for changes to the R-33 license. The balance of this roadmap document identifies, explains, and provides justification for substantive changes to the NTR TSs and SAR. These substantive changes are the product of both GEH internal review and NRC recommendations made over the course of five audits held 8/18/2022 (audit
- 1), 8/19/2022 (audit #2), 11/30/2022 (audits #s 3 & 4)), and 12/12/2022 (audit #5). Because these audits reviewed several incremental TS draft documents proposed by GEH, some specific references in this document may appear to make incorrect or obscure references to proposed TS changes. In most cases these are referenced as draft to indication they are in-process developmental comments. In the end, this document attempts to be inclusive of all give-and-take between GEH and the NRC over the entirety of the audit process.
Contents 1.0 Requested Changes in License R-33 Possession Limits.................................................................... 4 2.0 Requested Clarification for Transporting Radioactive Materials Under the R-33 License: .............. 4 3.0 Internal Review - reactor shut down vs reactor shutdown:........................................................ 5 4.0 Audit Suggestion - Numbering of Definitions & Bases Statements ................................................. 5 5.0 Audit Suggestion - Add Definitions ................................................................................................. 5 6.0 Audit Suggestion - Add Plurals to Definitions ................................................................................. 5 7.0 Audit Suggestion - Inconsistent Internal References ........................................................................ 5 8.0 Internal Review - Add Definition of Administrative Change ....................................................... 5 9.0 Audit Suggestion - Proposed Definition of Administrative Change: ............................................ 5 10.0 Audit Suggestion - 1.2.2 Reasonable Channel Calibration ........................................................... 6 11.0 Audit Suggestion - 1.2.3 Variable vs Parameter ............................................................................... 6 12.0 Internal Review - 1.2.7 Explosive Material Definition ..................................................................... 6 13.0 Internal Review - 1.2.8 Facility Definition ....................................................................................... 6 14.0 Audit Suggestion - 1.2.11 LCO Definition ....................................................................................... 6 15.0 Audit Suggestion - 1.2.12 LSSS Definition ...................................................................................... 6 16.0 Audit Suggestion - Manual Poison Sheet (MPS) Definition ............................................................ 6 17.0 Internal Review - 1.2.13 Measured Value Definition ....................................................................... 7 18.0 Internal Review - 1.2.16 Reactivity Worth (Experiment) Definition ............................................... 7 1 of 21
19.0 Internal Review - 1.2.17 Reactor Operating Definition .................................................................... 7 20.0 Audit Suggestion - 1.2.20/21 Reactor Secured / Shutdown .............................................................. 7 21.0 Audit Suggestion - 1.2.22 Readily Available on Call Definition ..................................................... 7 22.0 Audit Suggestion - 1.2.23 Safety Limit (SL) Definition................................................................... 7 23.0 Internal Review - 1.2.24 Secured Experiment .................................................................................. 7 24.0 Internal Review - 1.2.25 Shutdown Margin Definition .................................................................... 8 25.0 Audit Suggestion - 1.2.25 Shutdown Margin Definition .................................................................. 8 26.0 Internal Review - 1.2.26 Site Definition ........................................................................................... 8 27.0 Audit Suggestion - 1.2.27 True Value Definition ............................................................................. 8 28.0 Internal Review - Surveillance Intervals Definitions........................................................................ 8 29.0 Audit Suggestion - Define Interval Daily to Align with ANSI 15.1: ............................................. 8 30.0 Internal Review - Unsafe Condition Defined ................................................................................... 9 31.0 Audit Suggestion - Define Shall, Should, and May ......................................................................... 9 32.0 Audit Suggestion - Tech Specs General Formatting Should Be Per ANSI 15.1. ............................. 9 33.0 Audit Suggestion - Subcritical Rod Position in TS 3.1.3.2: .............................................................. 9 34.0 Audit Suggestion - TSs 3.1.3.4 & 4.1.3.4 Describe a Design Feature .............................................. 9 35.0 Audit Suggestion - TSs 3.1.3.5 & 4.1.3.5 Describe a Design Feature ............................................ 10 36.0 Audit Suggestion - No General Actions for Safety System Specifications: ................................... 10 37.0 Audit Suggestion - TS 3.2.3.2 Safety Rod Withdrawal Ambiguous: ............................................. 10 38.0 Internal Review - TS 3.2.3.4 Implies Single Rod Withdrawal ....................................................... 10 39.0 Internal Review - TS 3.2.3.5 Term inflight time Not In SAR ..................................................... 10 40.0 Internal Review - TS 3.2.3.6 Conflates Safety & Safety-Related Systems .................................... 11 41.0 Audit Suggestion - TS 3.2 Basis Editorial Change: ........................................................................ 11 42.0 Audit Suggestion - Table Column Headers Are Not Consistent: .................................................... 11 43.0 Internal Review - TS 3.3.3.1 Contains Unnecessary Instruction .................................................... 11 44.0 Internal Review - TS 3.3.3.2 Is Not Verifiable ............................................................................... 11 45.0 Audit Suggestion - TS 3.3.3.3 Conductivity Not Per NUREG-1537.............................................. 11 46.0 Audit Suggestion - TS 3.4 Confinement Is Not an LCO: ............................................................... 12 47.0 Internal Review - TS Table 3-3 Not Actionable ............................................................................. 12 48.0 Audit Suggestion - Negative Reactor Cell Pressure ....................................................................... 13 49.0 Audit Suggestion - SAR 9.1 Alignment with TS 3.5.2 ................................................................... 13 50.0 Internal Review -TS 3.5.3.8 Plutonium Experiment Cladding Not in Draft TS ............................. 13 2 of 21
51.0 Audit Suggestion - No TS 3.6, Emergency Power, As Per ANSI 15.1 .......................................... 13 52.0 Internal Review - No TS 3.7, Radiation Monitoring and Effluents, As Per ANSI 15.1 ................. 13 53.0 Audit Suggestion - Draft TS 3.7.1.1 Terminology ......................................................................... 14 54.0 Audit Suggestion - Draft TS 3.7.1.3 Rad Monitor Locations ......................................................... 14 55.0 Internal Review - Draft TS 3.7.1, 3.7.2, 4.7.1, and 4.7.2 Reformatted ........................................... 14 56.0 Audit Suggestion - Draft TS 3.8.1 Internal Reference to TS 3.1.1 ................................................. 14 57.0 Audit Suggestion - TS 3.8.3 Doesnt Define Terms Used in Calculation ...................................... 15 58.0 Audit Suggestion - TS Surveillances Following Maintenance ....................................................... 15 59.0 Audit Suggestion - TS 4.1.3 Minimum Shutdown Margin Periodicity .......................................... 15 60.0 Audit Suggestion - TS Table 4-1 Daily Check or Test ............................................................ 15 61.0 Internal Review - TS 4.5.1 & 4.5.2 Unclear ................................................................................... 15 62.0 Audit Suggestion - TS 4.5.2 Reference to Table 4-2 ...................................................................... 16 63.0 Audit Suggestion - Daily Surveillance Interval in 4.6.3.1 Not Per ANSI 15.1 .............................. 16 64.0 Internal Review - Draft TS 4.7.1(2) Doesnt Support Daily Channel Check When Reactor is Shutdown ......................................................................................................................................... 16 65.0 Internal Review - TS 5.1.1 Location of NTR ................................................................................. 16 66.0 Internal Review - TS 5.1.2 488 meters (1600 feet) ..................................................................... 17 67.0 Internal Review - TS 5.1.3 Moved to 5.3 ....................................................................................... 17 68.0 Internal Review - TS 5.1.4 Moved to 5.3 ....................................................................................... 17 69.0 Internal Review - TS 5.2 Reformatted Per ANSI 15.1 ................................................................... 17 70.0 Internal Review - TS 5.3 Missing Core Configuration Information as Per ANSI 15.1 .................. 17 71.0 Internal Review - TS 5.4 Reformatted Per ANSI 15.1 ................................................................... 18 72.0 Internal Review - TS Section 6.0 Reformatted Per ANSI 15.1 ...................................................... 18 73.0 Internal Review - Manager Levels Not Per ANSI-15.1 .................................................................. 18 74.0 Audit Suggestion - TS Section 6.1 and 6.1.1, Organization Chart Not Per ANSI 15.1:................. 18 75.0 Audit Suggestion - Draft TS 6.1.2 Doesnt Include Level 4........................................................... 18 76.0 Audit Suggestion - TS 6.2 Not Per ANSI 15.1 ............................................................................... 18 77.0 Internal Review - TS 6.3 Does Not Include Site-wide RP Organization ........................................ 18 78.0 Audit Suggestion - Draft TS 6.4 Level 2 Procedure Authorization ................................................ 19 79.0 Audit Suggestion - TS 6.4.1 Should Include Procedures for Byproduct Material .......................... 19 80.0 Internal Review - TS 6.4.2 - 6.4.4 Lack Detail About Procedure Approval ................................... 19 81.0 Audit Suggestion - TS 6.4.4 Is to Be Reported Within 24-hrs ....................................................... 19 82.0 Audit Suggestion - TS Section 6.0 Does Not Require a Basis ....................................................... 19 3 of 21
83.0 Internal Review - TS 6.5 Experiments Review and Approval Missing Per ANSI 15.1 ................. 20 84.0 Audit Suggestion - Draft TS 6.5.3 Uses Vague Term Significantly ........................................... 20 85.0 Internal Review - TS 6.5 Required Actions, Doesnt Align with ANSI 15.1 ................................. 20 86.0 Audit Suggestion - Draft TS 6.6.1 NRC Authorization for Restart ................................................ 20 87.0 Internal Review - Draft TS 6.6.2 - Replace 10 CFR 50.73(d) Reference ....................................... 20 88.0 Internal Review - 6.6.1, Operating Reports, Doesnt Align with ANSI 15.1 ................................. 21 89.0 Internal Review - 6.6.2, Special Reports, Doesnt Align with ANSI 15.1 ..................................... 21 90.0 Internal Review - 6.7 Records, Doesnt Align with ANSI 15.1 ..................................................... 21 1.0 Requested Changes in License R-33 Possession Limits Current possession limits in 2.B.(2) generally describe a safeguards Category III facility, but Category II quantities can be achieved using the U235 + 2(U233 + Pu) formula rule.
Detail:
The possession limits in 2.B.(2) allow possession of up to 1,900 formula grams using the U235 + 2(U233 + Pu) formula rule. Special Nuclear Material was used in fueled experiments in the NTR prior to 1985. These experiments have been discontinued. A review of the historical NTR CLA from 1980-1985 (when these experiments were most recently performed) shows the NTR housed up to 200 gm U-235, 33 gm Pu, and no U-233. These quantities have not been in the facility for decades.
To eliminate the mathematical possibility that a Category II quantity could be compiled at the NTR, GEH requests that, during the process of license renewal, the possession limits in section 2.B.(2) be revised as follows:
2.B.(2)b. - 100 grams of plutonium should be changed to 50 grams of plutonium.
2.B.(2)c. - 100 grams of uranium-233 should be changed to 50 grams of uranium-233.
2.B.(2)d. - 1500 grams of contained U-235 in uranium enriched to less than 4%
U-235 should be changed to 800 grams of contained U-235 in uranium enriched to less than 4% U-235 2.0 Requested Clarification for Transporting Radioactive Materials Under the R-33 License:
The R-33 license authorizes receipt, possession, and use of byproduct, source, and SNM, but does not specifically authorize transport or delivery to carrier for transport.
Detail:
The VNC currently performs shipments of radioactive materials under our SNM-960 license or our California byproduct material license. Therefore, as we are able to ship radioactive materials, we have no specific requests related to this issue other than that the 4 of 21
language be improved to clarify whether the shipping and/or transport of such materials is permitted under the license and to what extent.
3.0 Internal Review - reactor shut down vs reactor shutdown:
Issue: The terms reactor shutdown and reactor shut down are both used multiple times in both the exiting and draft TSs. In many cases, these terms have the same meaning, but reactor shut down is not defined.
Response: Corrected throughout TSs to indicate the defined term, reactor shutdown, where applicable.
4.0 Audit Suggestion - Numbering of Definitions & Bases Statements NRC Comment: Numbering of TS definitions and bases are not per ANSI 15.1 formatting and are not necessary.
Response: Numbering has been removed from definitions and from bases.
5.0 Audit Suggestion - Add Definitions NRC Comment: Add definitions to align with ANSI 15.1: confinement, control rod -
(including scram capability), core configuration, (potential) excess reactivity, fixed (secured) experiment, moveable experiment, operating, protective action, reference core condition, license, scram time, secured, and shutdown.
Response: Definitions have been added as agreed to by audit team.
6.0 Audit Suggestion - Add Plurals to Definitions NRC Comment: Lack of inclusion of plural forms of defined terms in TS 1.2 creates ambiguity.
Response: Plural forms have been added to applicable definitions. Additionally, other variants of defined terms (e.g., license, licensed, or licensee; licensed reactor operator(s) /
reactor operator(s) / senior reactor operator(s)) have been included where applicable and defined terms used in the body of the TSs have been capitalized and italicized to identify them as defined terms.
7.0 Audit Suggestion - Inconsistent Internal References NRC Comment: Internal document references sometimes say Refer to TS and in other locations say, Refer to specification.
Response: Internal references have all been edited so that references to LCOs are referenced as LCO. Likewise, references to Administrative Controls, Surveillance Requirements, and Design Features are specifically called out verses the generic use of the term specification.
8.0 Internal Review - Add Definition of Administrative Change See item 80.0 and 84.0.
9.0 Audit Suggestion - Proposed Definition of Administrative Change:
NRC Comment: The proposed draft definition of (non)Administrative Change(s) is confusing in that it unnecessarily includes (non).
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Response: The definition has been changed to remove (non). References to non-administrative changes made in the document (e.g., TS 6.4.2(2)) include lower case non and upper case & italicized ADMINISTRATIVE CHANGE(S). Capitalizing and italicizing is the convention chosen to identify phrases in the document body that are included in section 1.2, Definitions.
10.0 Audit Suggestion - 1.2.2 Reasonable Channel Calibration NRC Comment: Definition of channel check uses the term reasonable as a qualifier to encompassing the entire channel when performing calibrations. It is unclear in what case this would be unreasonable.
Response: There is no such case. The definition has been revised to remove this qualifier.
11.0 Audit Suggestion - 1.2.3 Variable vs Parameter NRC Comment: Current definition of channel check discusses measuring the same variable when performing comparisons of the channel to other independent channels.
ANSI 15.1 prefers the term parameter, which is also consistent with TS 1.2.1 and 1.2.2.
Response: Term variable was replaced with parameter to align with ANSI.
12.0 Internal Review - 1.2.7 Explosive Material Definition Issue: Definition of explosive material(s) changed in SAR to include DOT hazard class divisions.
Response: Definition updated in TS to align with SAR.
13.0 Internal Review - 1.2.8 Facility Definition Issue: Description of facility has been updated in the SAR to include the names of rooms that constitute the associated support areas.
Response: Definition updated in TS to align with SAR and clarify the components of the associated support areas.
14.0 Audit Suggestion - 1.2.11 LCO Definition NRC Comment: It is not necessary to define Limiting Conditions of Operation (LCO) as per TS 1.2.11.
Response: Definition has been removed.
15.0 Audit Suggestion - 1.2.12 LSSS Definition NRC Comment: It is not necessary to define Limiting Safety Systems Settings (LSSS) as per TS 1.2.12.
Response: Definition has been removed.
16.0 Audit Suggestion - Manual Poison Sheet (MPS) Definition Definition added (See item 34.0.).
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17.0 Internal Review - 1.2.13 Measured Value Definition Issue: The definition of measured value restates the term being defined. This is redundant.
Response: Definition revised to remove restatement of term.
18.0 Internal Review - 1.2.16 Reactivity Worth (Experiment) Definition Issue: The definition of reactivity worth restates the term being defined. This is redundant.
Response: Definition revised to remove restatement of term.
19.0 Internal Review - 1.2.17 Reactor Operating Definition Issue: Phrase considered to be is ambiguous.
Response: Definition has been revised - phrase removed.
20.0 Audit Suggestion - 1.2.20/21 Reactor Secured / Shutdown NRC Comment: These terms should better align with ANSI 15.1. Reactor Shutdown is not understood relative to reference core condition.
Response: Definitions revised to better align with ANSI. Definition added for Reference Core Condition to better clarify Reactor Shutdown.
21.0 Audit Suggestion - 1.2.22 Readily Available on Call Definition NRC Comment: This definition should better align with ANSI 15.1.
Response: Definition revised to better align with ANSI. GEH has modified the (e.g., 1/2 hour / 15-mile radius) suggested in the ANSI to (approximately 1/2 hour / 30-mile radius.) This is possible and necessary. The NTR is now located within a hub of freeways that reached final completion in 1999. This enhanced access has made it possible for employees who live within a selective 30-mile radius to access the NTR in 1/2 hour during normal conditions. Adjusting the on call radius to 30 miles avails more reasonably priced housing choices for SROs in communities to the north and east of the VNC. These communities are within 1/2-hour from the VNC under normal conditions traveling at freeway speeds.
22.0 Audit Suggestion - 1.2.23 Safety Limit (SL) Definition NRC Comment: It is not necessary to define Safety Limit (SL).
Response: Definition has been removed.
23.0 Internal Review - 1.2.24 Secured Experiment Issue: Since a definition was added for a moveable experiment, these terms are better understood comparatively and should be included in the definition of experiment.
Response: Definitions for secured and moveable experiments are included as subsets of the defined term experiment and have been placed within that definition.
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24.0 Internal Review - 1.2.25 Shutdown Margin Definition Issue: The definition of shutdown margin restates the term being defined.
Response: Definition has been revised to remove restatement of term.
25.0 Audit Suggestion - 1.2.25 Shutdown Margin Definition NRC Comment: It is not clear what rods are in what positions to initiate the condition.
Response: Definition has been revised to clarify the initiating safety and control rod positions. A definition for Safety Rod has also been added to enhance clarity.
26.0 Internal Review - 1.2.26 Site Definition Issue: This definition of Site is as per license amendment 25; however, an updated definition was submitted in Item 4 of Enclosure 3 of the license renewal application submitted 11/19/2020 (ADAMS ML20325A197 [non-public]).
Response: Added (Refer to Safety Analysis Report, Figure 2-3.) to the definition. This aligns with the definition provide in letter, License Amendment Request - NTR Facility Amendment 24, Supplement 3, Sept 4, 2019, (ADAMS ML19247D270).
27.0 Audit Suggestion - 1.2.27 True Value Definition NRC Comment: Definition of true value includes the qualifier at any instant which is implicit and is not aligned with ANSI 15.1.
Response: Definition has been changed to align with ANSI.
28.0 Internal Review - Surveillance Intervals Definitions Issue: Since the surveillance intervals are defined terms and not themselves surveillances, it would be an enhancement to the overall document to place them in the definitions section rather than in the surveillance section.
Response: A definition for surveillance intervals has been moved from 4.6.3.1 to section 1.2 and each interval has been individually defined therein. Intervals have been edited to better conform to ANSI 15.1; specifically, quinquennial and prior to startup intervals have been added, semi-annual is noted as not exceeding 7.5 months (vs 32 weeks) and quarterly is noted as not exceeding 4 months (vs 18 weeks). The daily interval now conforms to the ANSI and is more thoroughly discussed in item 29.0 (See also item 61.0.).
29.0 Audit Suggestion - Define Interval Daily to Align with ANSI 15.1:
NRC Comment: The term daily used in section 1.2 to describe frequencies for actions contained in the technical specifications (TS) appears to be a combination of two terms from the ANSI 15.1 and is tied exclusively to the operation of the reactor. This does not account for daily checks / tests that might necessarily be performed on qualifying systems that are required to be run when the reactor is not operating.
Response: The interval prior to the first reactor start-up of the day (Prior to SU) has been added and included where applicable in Tables 4-1 and 4-2. Daily is retained as applicable to specifications 3.5.2 and 3.7.2 (See item 63.0.) and included in surveillances 8 of 21
4.5.2 and 4.7.2 for activities that may create unacceptable radiological conditions while the reactor is not operating. Specification applicability statements have been edited to clarify facility conditions which dictate when each specification (and hence each surveillance) is required to be performed. Ts 3.7.2.2 has been modified (and renumber 3.7.5) to clarify that the stack monitors are to be operating when the reactor is above 0.1 kW or when any activity is performed in the facility that could release radioactivity in the reactor cell.
30.0 Internal Review - Unsafe Condition Defined Issue: The reporting of conditions that could develop into an unsafe condition is required under the existing special reporting sections of the NTR TSs as well and ANSI 15.1; however, no specific instruction is offered as to what constitutes an unsafe condition.
Special reporting requirements should be clear and well understood.
Response: A definition for unsafe condition has been added. This definition is better explained in Item 4 of Enclosure 3 of the license renewal application submitted 11/19/2020 (ADAMS ML20325A197 [non-public]).
31.0 Audit Suggestion - Define Shall, Should, and May NRC Comment: The terms shall, should, and may are used inconsistently throughout the tech specs, and are not defined.
Response: A definition for should, shall, and may has been added to section 1.2 Definitions, and terms have been updated throughout the document. The convention of capitalizing and italicizing terms defined in section 1.2 has been applied.
32.0 Audit Suggestion - Tech Specs General Formatting Should Be Per ANSI 15.1.
NRC Comment: For each TS, Applicability, Objective, and Specification should be provided, but not be numbered. Bases should not be numbered. Each specification should be given a name and each surveillance should service a specific specification.
Applicability should also explain the mode(s) of operation the Specification is applicable.
Response: The entirety of the NTR TSs have been extensively reformatted. Numbering has been revised to align with ANSI 15.1, operating modes are addressed in applicability statements, each TS has been assigned a name, and each surveillance in section 4 is associated with a specification in section 3.
33.0 Audit Suggestion - Subcritical Rod Position in TS 3.1.3.2:
NRC Comment: The term subcritical rod position is suggested as a name for TS 3.1.3.2 but is not explained or defined in section 1.2 and does not appear to be explained in the SAR.
Response: This term is implicitly explained in section 4.4.3 of the SAR; however, the exact term is not used. For clarity, the term subcritical rod position has been included in TS 3.1.2, 4.1.2, and added to the explanation in section 4.4.3 of the SAR.
34.0 Audit Suggestion - TSs 3.1.3.4 & 4.1.3.4 Describe a Design Feature NRC Comment: Since the restraints used for manual poison sheets (MPS) are a design feature, TS 3.1.3.4 does not describe a technical specification.
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Response: Information about MPS and restraints has been moved from section 3 to 5.3.1.
A definition of MPS(s) has been added to section 1.2 and references TS 5.3.1 for further clarity.
35.0 Audit Suggestion - TSs 3.1.3.5 & 4.1.3.5 Describe a Design Feature NRC Comment: The temperature coefficient of reactivity, at which reactivity rolls from positive to negative at 124 degrees, appears to be a design feature, with no effective way to verify it according to 4.1.3.5 or to adjust it.
Response: SAR 4.4.2 discusses temp coefficient as not being affected by reactor configuration or fuel burnup and not expected to vary significantly over core life.
Potential excess reactivity has been maintained within limits by periodically removing MPS cadmium to compensate for positive excess reactivity loss from fuel burnup. The temperature coefficient has therefore been moved from TS section 3 to TS 5.3.4 and is presented as a design feature.
36.0 Audit Suggestion - No General Actions for Safety System Specifications:
NRC Comment: The existing TSs contain no general direction for actions to be taken when a reactor safety system specification is violated.
Response: TS 3.2.0 has been added to instruct operators to place the reactor in shutdown immediately if any of the reactor safety system malfunctions except as provided for in Tables 3-1 and 3-2.
37.0 Audit Suggestion - TS 3.2.3.2 Safety Rod Withdrawal Ambiguous:
NRC Comment: TS 3.2.3.2 specifies no more than one safety rod at a time shall be allowed to be moved. This language is not clear as to the increment of time being discussed.
Response: TS has been edited to read: No more than one safety rod shall be simultaneously moved in an outward direction and has been renumbered as TS 3.2.2.
38.0 Internal Review - TS 3.2.3.4 Implies Single Rod Withdrawal Issue: TS 3.2.3.4 read in context with other rod specifications could be errantly interpreted to imply that the 1/6 in-per-second rate is applicable only when withdrawing each rod singularly.
Response: Detail added to TS 3.2.4 to explain the rods can be inserted or withdrawn singly or multiple rods simultaneously and that the withdrawal rate is applicable in all cases.
39.0 Internal Review - TS 3.2.3.5 Term inflight time Not In SAR Issue: TS 4.2.3.5 requires the rod scram time (inflight time) be measured semi-annually, indicating that the two terms are synonymous. Scram time is discussed in section 16.2 of the SAR, but inflight time is not mentioned anywhere in the SAR and appears to be a colloquial term that was included into the TS.
Response: The term inflight time has been removed from the TS for consistency. The term scram time has been defined in section 1.2 (See item 5.0.).
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40.0 Internal Review - TS 3.2.3.6 Conflates Safety & Safety-Related Systems Issue: Table 3-1 specifies automatic reactor trip set points, scram system components, and minimal number of channels necessary to ensure protective actions can be taken to place the reactor in reactor shutdown. Table 3-2 specifies alarm set points and rod interlock features that prompt operator actions to ensure the facility is maintained within normal operating parameters. TS 3.2.3.6 gives these tables the same weight and implies alarms in Table 3-2 indicate an immediate shutdown of the reactor is warranted when all that is needed is timely operator response to address an alarm.
Response: TS 3.2.6 has been rewritten to clarify the differences between these tables and actions to be taken.
41.0 Audit Suggestion - TS 3.2 Basis Editorial Change:
NRC Comment: The fourth paragraph in the Basis for TS 3.2 says established for this type reactor when The word of should be inserted after type.
Response: The word of has been added as per suggestion.
42.0 Audit Suggestion - Table Column Headers Are Not Consistent:
NRC Comment: The table headers in TS tables 3-1, 3-2, 4-1, 4-2 and in SAR tables 7-1 and 7-2 are not consistent. This is confusing.
Response: TS tables 3-1, 3-2, 4-1, and 4-2 and SAR tables 7-1 and 7-2 have been updated with consistent column headers.
43.0 Internal Review - TS 3.3.3.1 Contains Unnecessary Instruction Issue: TS 3.3.3.1 instructs that forced coolant flow is not required below 0.1 kW. This is explanatory basis material.
Response: TS 3.3.1 has been reworded and explanatory information moved to the basis section.
44.0 Internal Review - TS 3.3.3.2 Is Not Verifiable Issue: TS 3.3.3.2 requires that the core tank is filled; however, there is no way directly to check the level in the core tank. In practice, this TS is met by ensuring the fuel loading tank is full of water (which can be verified) as, by design, the core tank is gravity fed by the fuel loading tank.
Response: TS 3.3.2 has been reworded to ensure that the fuel loading tank is full, which ensures the core tank is full, and instructs that the reactor be placed in shutdown if the fuel loading tank is not full.
45.0 Audit Suggestion - TS 3.3.3.3 Conductivity Not Per NUREG-1537 NRC Comment: TS 3.3.3.3 requires primary coolant be maintained at 10 mhos/cm to maintain the pH between 4.8 and 8.7. NUREG-1537 indicates that traditionally conductivity for primary water should be maintained at 5 mhos/cm to maintain the pH between 5.0 and 7.5. The NRC acknowledges the NTR is of aluminum piping construction and operated at atmospheric pressure (which may affect this parameter) but suggests that the analysis in section 5.4 of the SAR be verified.
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Response: GEH has verified the current TS as adequate; however, has opted for the more conservative limit of NUREG-1537. According to operational history, the coolant conductivity readings have not approached 5 mhos/cm in 60 years of operation.
Therefore, GEH believes that conforming to the acceptable standard of 5 mhos/cm is prudent. SAR section 5.4 has been revised accordingly and units have been changed to
µS/cm to correlate directly to the installed conductivity meter. TS 3.3.3 has been updated to require that primary coolant be maintained less than 5 µS/cm averaged over a month and the basis for section 3.0 has been updated to reflect changes to SAR section 5.4.
46.0 Audit Suggestion - TS 3.4 Confinement Is Not an LCO:
NRC Comment: The NRC agrees with the stated position that confinement helps mitigate releases but isnt required to meet 10 CFR 20 limits; however, in this case, confinement then is not an LCO.
Response: Technical specifications sections 3.4 and 4.4 have been maintained to align with ANSI 15.1 formatting but have been updated as This section left intentionally blank. Explanatory narrative that was included in TS 3.4 has been moved to the section basis. Specification 3.5, Ventilation, has been added to align with ANSI 15.1, and has been slightly modified and retitled Reactor Cell, Ventilation, and Confinement System to include the confinement function performed by the ventilation system in maintaining the reactor cell at negative pressure relative to the balance of the facility. TS 3.4.3.1 through 3.4.3.4 have been incorporated into new TSs 3.5.1, 3.5.2, 3.7.4, and 3.7.5.
Sections 4.5 and 4.7 have also been updated to address surveillances for these TSs (See also items: 29.0, 52.0, 48.0, 49.0, 61.0, and 63.0.)
47.0 Internal Review - TS Table 3-3 Not Actionable Issue: The stack monitor is only capable of directly reading gaseous and particulate activity, which the control room recorder displays as a stack discharge rate in units of
µCi/cc. Likewise, the alarm for the stack monitor also only alarms in response to exceeding the gaseous or particulate channel setpoints. The SAR presents additional release action levels for Halogen, and alpha and beta particulate separately; however, only beta is actionable as it reflects a combined Beta/Gamma component detectable by the particulate channel. Halogen and alpha levels are not independently detectable by the installed instrumentation at the NTR and so are not useful as technical specifications.
Further, weekly rates of release are not easily actionable because there is no instrument that measures or computer that compiles an ongoing weekly release rate.
Response: As explained in section 11.2.5 of the SAR (and Table 11-4), the alarm/action set point for gas is selected as the rate which would give an annual average concentration of Ar-41 at the site boundary of 10% of the ECL, further divided by two to allow for the contribution of other stack releases at the VNC. Therefore, these setpoints are extremely conservative and any increase in non-emergency related effluent would be reflected in incremental increases in the stack gaseous and/or particulate channels. Table 3-3 has been reduced to include only those levels that are actionable. TS 3.7.4 has been revised to require that the operator respond to a stack effluent alarm by determining the weekly effluent release rate and taking actions to ensure that rate is not exceeded. If the weekly 12 of 21
effluent release rate is exceeded, the reactor is to be placed in shutdown until the condition can be evaluated and release rates are again below the action levels.
48.0 Audit Suggestion - Negative Reactor Cell Pressure NRC Comment: June 2022, TS 3.4.3.1 (proposed 3.5.1) requires negative pressure in the reactor cell when the reactor is operating, but it seems that there may be evolutions performed in the facility when the reactor is not operating during which the ventilation system should be run to mitigate releases of radioactive material to the environment.
Response: New TS 3.5.2 has been added to establish negative cell pressure for activities that could release airborne radioactivity into the reactor cell. 4.5.2 added to include surveillances (See also item 63.0.)
49.0 Audit Suggestion - SAR 9.1 Alignment with TS 3.5.2 NRC Comment: SAR section 9.1 does not include the requirement that reactor cell negative pressure must be established when performing activities that could release airborne radioactivity into the reactor cell.
Response: The SAR draft, 9.1, has been updated to discuss the need to establish negative ventilation when performing activities that could release airborne radioactivity into the reactor cell.
50.0 Internal Review -TS 3.5.3.8 Plutonium Experiment Cladding Not in Draft TS Issue: TS 3.5.3.8 discusses the cladding / encapsulation of fuel elements containing plutonium. As discussed in Chapter 6 of the revised SAR, fueled experiments containing plutonium are not performed at the NTR. The limiting experiment accident, discussed in SAR 13.2 is for an experiment involving encapsulated U-235.
Response: TS 3.5.3.8 (now 3.8.11) requires that experimental fuel elements containing uranium be clad. Although, such experiments have not been performed at the NTR for approximately 40 years and are unlikely to be performed in the future, the uranium fuel capsule scenario was selected as a bounding experiment for Chapter 13 analysis. TS 3.8.11 ensures that any such experiment falls within the initiating conditions (assumptions) of the accident according to SAR 13.2.2.
51.0 Audit Suggestion - No TS 3.6, Emergency Power, As Per ANSI 15.1 NRC Comment: TS 3.6, Emergency Power, is not included in the draft TSs being reviewed. Although the NRC acknowledges that the NTR has no emergency power systems, an acceptable solution to maintain ANSI 15.1 heading formatting would be to include this section as left intentionally blank.
Response: TS sections 3.6 and 4.6, Emergency Power, have been added and noted as This section left intentionally blank.
52.0 Internal Review - No TS 3.7, Radiation Monitoring and Effluents, As Per ANSI 15.1 Issue: Although the installed radiation monitors for the NTR have no reactor safety function and have no associated TS, surveillance requirements are included for the reactor cell radiation monitor in Table 4-2. Moreover, the personnel safety function of these instruments should be addressed. Also stack monitoring previously in TS section 13 of 21
3.4 should be addressed in 3.7 as an effluent monitoring system as per ANSI 15.1.
Finally, the TSs contain no requirement for site monitoring by TLD or effluent sampling as per ANSI 15.1.
Response: TS sections 3.7 and 4.7 have been added and include TSs and surveillance requirements for area monitors, stack monitors, and for site environmental monitoring (See also items: 29.0, 46.0, 48.0, 61.0, 63.0, and 49.0.).
53.0 Audit Suggestion - Draft TS 3.7.1.1 Terminology NRC Comment: The term reactor operations isnt defined in draft TS section 1.2; only reactor operating and reactor operation. Also, the TS doesnt give detail as to what type of radiation monitor is used.
Response: The definition of reactor operations has been updated to reactor operating or reactor operation(s) to include all forms of this terminology used in the TSs. The phrase gamma sensitive has been added to clarify the type of monitor that must be used for area monitors.
54.0 Audit Suggestion - Draft TS 3.7.1.3 Rad Monitor Locations NRC Comment: The locations of monitors should be in included in draft TS 3.7 but are only in the basis.
Response: The locations of monitors is not explicitly required by the ANSI 15.1.
Additionally, including them in the TS may be interpreted as excluding the use of substitute instruments that may be necessary if the installed monitors fail. GEH maintains that inclusion of these locations is appropriate for the basis.
55.0 Internal Review - Draft TS 3.7.1, 3.7.2, 4.7.1, and 4.7.2 Reformatted Issue: Surveillance requirements were not clearly aligned with the specifications.
Response: Moved the TLD specification to 3.7.3 to align with ANSI 15.1. Combined applicability statements in 3.7.1 and 3.7.2 in a single applicability statement.
Moved 4.7.1(1) for stack monitor surveillances to new 4.7.4 & 4.7.5.
The result is that 3.7.1, 3.7.2, 4.7.1, and 4.7.2 now address only ARMS and 3.7.3, 4, & 5 and 4.7.3, 4, & 5 now address only effluents (TLDs, REMP sampling, and stack releases).
56.0 Audit Suggestion - Draft TS 3.8.1 Internal Reference to TS 3.1.1 NRC Comment: TS 3.5.3.1 (draft TS 3.8.1) makes an internal reference to TS 3.1.3.1 (draft TS 3.1.1) for inclusion of the $.76 value for potential excess reactivity. It would be clearer if this reference simply stated $.76 or potential excess reactivity.
Response: In responding to this question, it should be noted that TS section 3.8, Experiments, was previously numbered as TS section 3.5 in the June 2022 TSs. This renumbering is the result of adding sections 3.4, 3.6, and 3.7 to align with ANSI 15.1 formatting. New TS 3.8.1 has been edited to say, to comply with the specification on POTENTIAL EXCESS REACTIVITY (See Technical Specification 3.1.1.).
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57.0 Audit Suggestion - TS 3.8.3 Doesnt Define Terms Used in Calculation NRC Comment: TS 3.5.3.2 (draft TS 3.8.3) uses terms W and D but doesnt define them.
Response: These terms are defined in TS 3.8.4; nevertheless, because more detail is contained in SAR section 13.6.2, the following statement has been added to the basis to TS 3.8: Specifications 3.8.3 and 3.8.4 detailed bases are included in SAR Chapter 13.6.4 Experiment Limitations.
58.0 Audit Suggestion - TS Surveillances Following Maintenance NRC Comment: There is no evident generic TS to require performing surveillances on systems prior to restoring them to operation following maintenance.
Response: Tables 4-1 and 4-2 include footnotes that include this requirement; however, these tables do not include new TS 4.7.1. Therefore, the requirement to perform surveillances on area radiation monitors following repair or declared inoperability has been added to TS 4.7.1.
59.0 Audit Suggestion - TS 4.1.3 Minimum Shutdown Margin Periodicity NRC Comment: TS 4.1.3.3 (draft TS 4.1.3) does not include a structured periodicity for performing the minimum shutdown margin calculation, nor does it appear to include a requirement to perform the calculation following maintenance on rods.
Response: TS 4.1.3 has been revised to include a biennial calculation. This calculation would also necessarily be performed following rod maintenance according to the footnote in Table 4-1 (See Item 58.0.).
60.0 Audit Suggestion - TS Table 4-1 Daily Check or Test NRC Comment: The requirements in draft Table 4-1 to perform daily checks and monthly tests seems unusual and appear inconsistent within the table.
Response: The requirements of checks versus tests is overlapping with both fulfilling the requirements of the other. The cadence is long established and understood by staff.
However, it was noted that Log N surveillances were inconsistent with other system surveillances in the table. Therefore, Log N surveillances have been changed to a daily check and a monthly test to standardize the cadence in the table. Notably, both a check and a test are performed daily and monthly for the Log N. NOTE: This audit suggestion was made to a draft during the audit process. Subsequently, the prior to startup (prior to SU) periodicity was added and is included in the final Table (See items 28.0 and 61.0.).
61.0 Internal Review - TS 4.5.1 & 4.5.2 Unclear Issue: The daily surveillance requirements of TS 4.6.3.1.g, and draft 4.5.1 & 4.5.2 are unclear.
Response: It is noted that TS surveillance 4.5.1 and 4.5.2 corelate to 4.4.3.1 in the June 2020 TSs. In response to this issue, the definition of daily has been shortened to Must be done during the calendar day. The 4.5.1 Surveillance requirements have been changed for the instrumentation and equipment required to comply with Specification 15 of 21
3.5.1 to say that it shall be tested as listed in Specification 4.2, Table 4-2, Item No. 1 & 5.
Changed 4.5.2 to say that a channel check of reactor cell pressure and gas and particulate stack radioactivity shall be performed daily during activities that could release airborne radioactivity into the reactor cell (See also items 48.0, 55.0, 64.0, & 49.0).
This wording of 4.5.2 will allow the daily check performed during a maintenance activity to be used as the Prior to SU check IF maintenance is performed prior to startup AND to use the PTSU check to support post-SD maintenance performed later in the day. In either case, the channel check need only be documented once per day.
62.0 Audit Suggestion - TS 4.5.2 Reference to Table 4-2 NRC Comment: TS 4.5.2 says that surveillances are performed according to table 4-2; however, it is not clear which surveillances within the table are to be performed.
Response: To increase clarity, TS 4.5.2 has been revised (and renumbered 4.5.1) to specify the item column number that is applicable to the TS and now says shall be tested as listed in Specification 4.2, Table 4-2, Item No. 1. This was also done for TS 4.7.5 for stack monitor operability (See also items 55.0 & 64.0).
63.0 Audit Suggestion - Daily Surveillance Interval in 4.6.3.1 Not Per ANSI 15.1 Issue: The daily surveillance interval appears to incorporate both the ANSI definitions for daily and Prior to the first reactor start-up of the day and presumes that no surveillances need be performed when the reactor is shutdown.
Response: Surveillance intervals have been moved from section 4.6 to 1.2, Definitions (See items 28.0 and 29.0). The definition of daily has been changed to align with ANSI and a new ANSI surveillance interval, prior to first startup of the day, has been added. Changes were also necessary to tables 4-1 and 4-2 to specify the appropriate intervals for operational surveillances, and technical specifications / surveillances were added (TS 3.5.2, 4.5.2, 3.7.2, 4.7.2) to address the use of area monitors and ventilation stack monitors for activities undertaken when the reactor is not operating.
64.0 Internal Review - Draft TS 4.7.1(2) Doesnt Support Daily Channel Check When Reactor is Shutdown Issue: Draft 4.7.1(2) points to Table 4-2, item 5 for surveillance requirements for the stack monitors. However, this is redundant (since the requirement is already in the table) and, since Table 4-2 only addresses reactor operating conditions, doesnt address the need for a daily channel check when the reactor is in shutdown and maintenance is taking place in the reactor cell that could create airborne contamination.
Response: Moved stack surveillances to new 4.7.4 & 4.7.5 and added new 4.7.2 to perform daily channel check of the reactor cell radiation monitor during Rx cell maintenance. Also, new 4.7.3 addresses surveillances for TLDs and environmental monitoring as per specification 3.7.3 (See also items 52.0 & 55.0.).
65.0 Internal Review - TS 5.1.1 Location of NTR Issue: NTR License Renewal Application submitted 11/19/2020, Item 12 of Enclosure 3 (ADAMS ML20325A197 [non-public]) points out that the license renewal process also 16 of 21
changes the definition of Site in section 1.2 of these TSs to specify that the Site is per SAR Figure 2-3, which includes the exact Lat/Long of the Site boundary. TS 5.1.1, which defines the location of the NTR, contains the descriptive phrase, which is owned and controlled by the licensee. This statement is irrelevant to location and is not required by ANSI 15.1 or NUREG-1537.
Response: TS 5.1.1 has been shortened to remove unnecessary detail not relevant to location.
66.0 Internal Review - TS 5.1.2 488 meters (1600 feet)
Issue: Per NTR License Renewal Application submitted 11/19/2020, Item 12 of Enclosure 3 (ADAMS ML20325A197 [non-public]), this detail is to be removed from TS
5.1.2. Response
Detail has been removed. Detailed justification is in the aforementioned license renewal application.
67.0 Internal Review - TS 5.1.3 Moved to 5.3 Issue: Core reel information is control system information and should be included in TS section 5.3 to align with ANSI 15.1.
Response: Information about the core reel assembly has been relocated to 5.3.3 to align with ANSI 15.1 formatting.
68.0 Internal Review - TS 5.1.4 Moved to 5.3 Issue: Control system information should be included in TS section 5.3 to align with ANSI 15.1.
Response: Information about the control and safety rods as well as information about manual poison sheets, including that from TS 3.1.3.4, has been relocated and combined into TS 5.3.1 (See also item 34.0) to align with ANSI 15.1 formatting. Additionally, TS 5.1.5 which discusses the height of the effluent stack, is now renumbered to 5.1.3 as a consequence of moving information.
69.0 Internal Review - TS 5.2 Reformatted Per ANSI 15.1 Issue: TS 5.2 requires reformatting and restating. Since the reactor coolant system is maintained at atmospheric pressure by way of a permanent vent line from the holdup and fuel tanks it is a design feature and would require a plant modification to change.
Therefore, the application of the command shall in this instance is ambiguous.
Response: TS 5.2.1 has been created to align with ANSI formatting and has been reworded to properly convey that the atmospheric vent line is a design feature that ensures the primary system is maintained at atmospheric pressure.
70.0 Internal Review - TS 5.3 Missing Core Configuration Information as Per ANSI 15.1 Issue: TS 5.3 contains only information on fuel and fuel configuration. Information from TS 5.1.4 that discusses rods and MPS should be relocated to this section.
Response: As per item 68.0, information about core configuration design has been moved to TS section 5.3. Control system design information is included in TS 5.3.1 17 of 21
while fuel design information is now in TS 5.3.2. Core reel assembly has been moved to 5.3.3 as per item 67.0, and section 5.3.4 discusses temperature coefficient as per item 35.0.
71.0 Internal Review - TS 5.4 Reformatted Per ANSI 15.1 Issue: TS 5.4 requires reformatting.
Response: TS 5.4.1 has been created to better align with ANSI 15.1.
72.0 Internal Review - TS Section 6.0 Reformatted Per ANSI 15.1 Issue: The entirety of Section 6.0 requires reformatting.
Response: Section 6.0 has been reformatted to align with ANSI 15.1.
73.0 Internal Review - Manager Levels Not Per ANSI-15.1 Issue: As per NTR License Renewal Application submitted 11/19/2020, Item 15 of Enclosure 3 (ADAMS ML20325A197 [non-public]), manager levels are backwards from the ANSI 15.1 guidance and the balance of the RTR community.
Response: Manager levels have been changed throughout section 6.0 to align with ANSI 15.1 and RTR community standards.
74.0 Audit Suggestion - TS Section 6.1 and 6.1.1, Organization Chart Not Per ANSI 15.1:
NRC Comment: Both the descriptions in section 6.1 and the org chart included in 6.1.1 deviate from the ANSI 15.1.
Response: The TS 6.1.1 organization chart has been edited to delete unnecessarily included organizations and clarify reporting lines. Section 6.1 has been comprehensively revised to align with the ANSI.
75.0 Audit Suggestion - Draft TS 6.1.2 Doesnt Include Level 4 NRC Comment: Neither the draft org chart included in TS 6.1.1 nor TS 6.1.2 include the Level 4 licensed staff.
Response: The org chart has been revised as per NRC Audit Suggestion 74.0, and TS 6.1.2(4) has been added to include operating staff.
76.0 Audit Suggestion - TS 6.2 Not Per ANSI 15.1 NRC Comment: The review and audit functions are not clearly delineated, nor are their responsibilities or functions.
Response: TS 6 has been extensively edited to align with ANSI 15.1.
77.0 Internal Review - TS 6.3 Does Not Include Site-wide RP Organization Issue: TS 6.3 does not clearly convey the interactive roll between the site-wide RP organization and NTR staff. The site radiation safety officer (RSO), who has front-line responsibility for implementing the RP program at the VNC (including the NTR), is not discussed.
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Response: TS 6.3 has been revised to include the roll of the RSO in implementing radiation safety at the NTR.
78.0 Audit Suggestion - Draft TS 6.4 Level 2 Procedure Authorization NRC Comment: Draft TS 6.4 preamble isnt clear that the Level 2 is responsible for all implementing procedures related to the NTR license. The NRC recognizes this is complicated because of site-wide programs at the VNC that overlap with procedure authorities specified in the ANSI 15.1.
Response: The section 6.4 preamble has been revised to clarify the separation of authority for procedures at the VNC vs those that are NTR-centric and to also clarify that the Level 2 is responsible for NTR-centric procedures that implement elements of broader site-wide programs / procedures at the VNC. SAR section 12.3.2 has been likewise edited to clarify this.
79.0 Audit Suggestion - TS 6.4.1 Should Include Procedures for Byproduct Material NRC Comment: TS 6.4.1 doesnt specifically include procedures for controlling byproduct material as per the ANSI 15.1.
Response: Transfer of byproduct materials at the VNC are generally performed according to the California broad-scope byproduct material license under the site-wide radiation protection program. Nevertheless, TS 6.4.1 has been revised to include implementing procedures for on-site transfer of by-product material for any such activities performed under the R-33 license. Other procedures that are not specifically included in ANSI 15.1 have been removed from TS 6.4.1.
80.0 Internal Review - TS 6.4.2 - 6.4.4 Lack Detail About Procedure Approval Issue: TSs 6.4.2, 6.4.3, and 6.4.4 lack sufficient detail to describe the process and authority for procedure authorization and do not reflect the management levels included in TS 6.1.
Response: TS 6.4.2, 6.4.3, and 6.4.4 have been revised to include necessary detail and proper authorizing management levels. Additionally, TS 6.4.3 now includes the term administrative change to replace the vague term minor change. A definition for Administrative change(s) has been added to section 1.2 to align with the same term as included in the site procedure process. (See also item 84.0.).
81.0 Audit Suggestion - TS 6.4.4 Is to Be Reported Within 24-hrs NRC Comment: TS 6.4.4 doesnt specifically include that reporting of temporary deviations from procedures must be made to the Level 2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the next working day as per ANSI 15.1.
Response: TS 6.4.4 has been revised to state that reporting of temporary deviations shall be made to the Level 2 by the end of the next working day.
82.0 Audit Suggestion - TS Section 6.0 Does Not Require a Basis NRC Comment: Section 6 in the TS draft includes a basis section that is not required by the ANSI 15.1.
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Response: The basis has been removed from section 6.0 of the TS draft.
83.0 Internal Review - TS 6.5 Experiments Review and Approval Missing Per ANSI 15.1 Issue: TS 6.5 is titled Required Actions, which is 6.6 in the ANSI 15.1. ANSI 15.1 includes a 6.5, Experiments Review and Approval, which is absent in the current TS. TS 4.5, Experiments, says that surveillance activities shall be established during the review and approval process as specified in 6.2.3, Review Function; however, specifics are not included in the TSs.
Response: Section 6.5 has been added to the TSs as per ANSI 15.1 to define the approval process for experiments. TS 6.5 generally follows the process in SAR 12.3.4 for experiments, which are performed according to the change authorization process.
Sections 6.5, 6.6, have been revised to align with ANSI 15.1 and following sections renumbered accordingly.
84.0 Audit Suggestion - Draft TS 6.5.3 Uses Vague Term Significantly NRC Comment: Draft TS 6.5.3 uses the word significantly when referring to the degree of change made to an experiment. Although the ANSI 15.1 also uses the subjective adjective substantive, this seems inadequate to differentiate those changes requiring Level 2 approval.
Response: TS 6.5.3 has been revised to allow an SRO to make administrative changes and a definition has been added to TS 1.2 for administrative change(s) that aligns with the VNC site accepted definition of an administrative change for a procedure (See item 80.0.). This term was applied to both procedures and experiments and TSs 6.4.2, 6.4.3, 6.5.2, and 6.5.3 were revised to be in alignment. SAR section 12.3.2.2 was also revised to include administrative rather than minor changes.
85.0 Internal Review - TS 6.5 Required Actions, Doesnt Align with ANSI 15.1 Issue: TS 6.5 Require Actions, in the current TSs does not align with the ANSI 15.1. For example, TS 6.5.1 describes actions to be taken for events requiring reporting under the reporting TS and TS 6.5.2 describes actions necessary in the event of a safety limit violation. This is backwards from ANSI 15.1.
Response: Section 6.6, Required Actions, has been edited to align with ANSI 15.1.
86.0 Audit Suggestion - Draft TS 6.6.1 NRC Authorization for Restart NRC Comment: Draft TS 6.6.1 does not include a requirement to attain NRC approval for restart following a safety limit violation according to the ANSI 15.1.
Response: TS 6.6.1(1) has been revised to require authorization of the NRC prior to restarting the reactor after a safety limit violation-initiated shutdown.
87.0 Internal Review - Draft TS 6.6.2 - Replace 10 CFR 50.73(d) Reference Issue: Draft TS 6.6.2 indicates that special reports shall be forwarded to the NRC addressed in accordance with 10 CFR 50.73(d). However, this is an incorrect reference in that 50.73(d) contains no explicit information about addresses and simply defers to 10 CFR 50.4 for this information. Further, inclusion of this reference is ambiguous in that it implies some level of compliance is required with 10 CFR 50.73 for submitting written 20 of 21
licensee event reports. In fact, applicability to 50.73 is limited to power reactors licensed under 50.21(b) or 50.22. The NTR is licensed under 50.21(c) and is outside of applicability. Further, TS 6.6.2 clearly limits written reports to changes in Level 1 & 2 Managers and significant changes in transient or accident analysis.
Response: Reference to 10 CFR 50.73(d) has been replaced with 10 CFR 50.4 in TS 6.6.2, which is now renumbered as 6.7.2.
88.0 Internal Review - 6.6.1, Operating Reports, Doesnt Align with ANSI 15.1 Issue: 6.6.1.d, reference to 10 CFR 50.59(d)(2) is deficient in that it does not include (d)(2). TS 6.6.1.e does not include the following statement from ANSI 15.1: The summary SHALL include to the extent practicable an estimate of individual radionuclides present in the effluent. If the estimated average release after dilution or diffusion is
<25% of the concentration allowed or recommended, a statement to this effect is sufficient.
Response: 6.6.1 has been revised to align with ANSI 15.1.
89.0 Internal Review - 6.6.2, Special Reports, Doesnt Align with ANSI 15.1 Issue: Although the reporting of a safety limit violation is identified as required in existing 6.5.2, it is not required in 6.7.2(1)(a) as per ANSI 15.1.
Response: 6.7.2(1)(a) has been added to report a violation of safety limit.
90.0 Internal Review - 6.7 Records, Doesnt Align with ANSI 15.1 Issue: 6.7.1(i) doesnt include records of meeting reports of audit groups. 6.7.3 does not include off-site environmental-monitoring surveys required by TSs as records needing to be retained for the lifetime of the facility.
Response: 6.8.1(9) has been revised to include audit groups meeting reports as records to be retained for at least five years. TS 6.8.3(2) added to include off-site surveys as records to be retained for the lifetime of the facility.
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