ML23192A110

Administrative License Amendment Request for License Number R-126, Docket Number 50-497

ML23192A110
Person / Time
Site:	05000497
Issue date:	06/21/2023
From:	Sjoden G Univ of Utah
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML23192A110 (1)

Text

TliEa UNIVERS ITY.

OF UTAH Department of Civil &. Environmental Engineering 1 to S th Central Campus Drive, Suite 2000 Salt Lake City, Utah 84112 (801)581-6931 FAX (801) 585-5477 21 June 2023 From: Dr. Glenn E. Sjod n, Director Chair, University f Utah Nuclear Engineering Program Energy Solutions residential Endowed Chair Department of Ci ii and Environmental Engineering 110 Central Cam us Drive, Room 2000, Salt Lake City, UT 84112 Subj: Administrative Li ense Amendment Request for License number R-126, Docket number 50-497 To: U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Ref: (1) UUTR Technical Specification 6.2.3 We respectfully request review of the attached license amendment in regard to the administrative section of our technical specifications. Our Reactor Safety Committee (RSC) has reviewed and approved all documents supporting this request. Therefore, in accordance with UUTR TS 6.2.3. I declare, under penalty of perjury, that the foregoing is true and correct to the best of my knowledge.

Correspondence regarding this request should be addressed to our facility Reactor Supervisor, Andrew Allison (Andrew.Allison@utah.edu, 801-581-4188, under the mailing address above).

Sincerely,

~~~. g_

Glenri E. Sjoden, Ph.D., P.E.

_-,.,,,.--1-t...,

Professor and Director, Nuclear Engineering Program Energy Solutions Presidential Endowed Chair Department of Civil and Environmental Engineering University of Utah

Description of the Proposed change:

The University of Utah TRJGA reactor intends to make the following permanent changes to the Administrative Section of our Technical Specifications:

1) Amendment to Chapter 6 of our Technical Specifications that would separate the Level 2 of our facility from the Utah Nuclear Engineering Program (UNEP) director. This amendment would provide the University of Utah greater flexibility in its selection of a director of UNEP versus another individual knowledgeable of reactor policy that would be able to serve as our Reactor Facility Director, i.e. ANSI 15.4 Level 2 management.

2) Amendment to TS 6.1.3 staffing requirements for shifting the requirements for "events requiring direction of the Reactor Supervisor (RS)" to "events requiring the presence at the facility of a senior reactor operator (SRO)" and to have an SRO readily available on call versus the RS. These changes are necessary since they would provide the reactor facility with greater flexibility in scheduling and supporting events in the absence of the Reactor Supervisor.

Discussion of the current technical specification and effect of the change:

The current technical specification under TS 6.1.2.2 states:

2.2 Level 2: Individual responsible for reactor facility operation, i.e., the Utah Nuclear Engineering Facility (UNEF) Manager shall be the Director of the Utah Nuclear Engineering Program (UNEP).

By changing the wording to "i.e., the Reactor Facility Director, shall be an individual designated by the University administration who satisfies the requirements of ANSI 15.4.", the University will have the option to designate an individual specifically for this role. Currently, the Level 2 position is automatically assigned to the UNEP Director by technical specifications. Since the UNEP Director already has several other university administrative responsibilities and may or may not have nuclear reactor expertise, it is not necessarily in the best interest of the university for this individual to serve as Level 2. However, the new Reactor Facility Director will be expected to communicate and coordinate with the UNEP director on pertinent matters of the reactor facility.

The current technical specification under TS 6.1.3 states:

1. The minimum staffing when the reactor is operating shall be:

1.1 A licensed RO or the RS in the control room, 1.2 A second person present in the UNEF able to carry out prescribed instructions, and, 1.3 If neither of these two individuals is an SRO, an SRO shall be readily available on call. Readily available on call means an individual who:

i. Has been specifically designated and the designation is known to the operator on duty,

ii. Can be rapidly contacted by phone by the operator on duty, and, iii. Is capable ofgetting to the reactor facility within a reasonable time under normal conditions (e.g., 30 minutes or within a 15-mile radius).

3. Events requiring the direction of the RS:

3.1 Initial startup and approach to power of the day, 3.2 All.fuel or control-rod relocations within the reactor core region, 3.3 Relocation of any in-core experiment or irradiation facility with a reactivity worth greater than one dollar, and, 3.4 Recover from unplanned or unscheduled shutdown or significant power reduction.

By changing the terminology from "requiring direction of the RS" to requiring the presence at the facility of an SRO" our technical specifications will be matching the wording mentioned in 10 CFR 50.54 and ANSI/ANS 15.1. The term, direction, is ambiguous and could be interpreted as anything from permission to actively present giving orders for the event. Presence in the facility is unambiguous since our facility is clearly defined in the Emergency Plan.

Furthermore, as will be discussed later, applicable nuclear regulation/guidance only requires an SRO to be present for these events and readily available on call for minimum staffing requirement. As the full-time SRO in charge of day-to-day operations, the reactor supervisor will most likely be present for these mentioned events or on call for minimum staffing requirements.

However, in the absence of the RS, it is reasonable (and accepted regulatory standard per ANSI/ANS 15.1 and 10 CFR 50.54) for these events to be performed with another SRO present at the facility. Any licensed SROs will be trained to inform the RS that they are performing or had to perform these events in his absence.

Supporting Safety Analysis: Since these are_ only administrative changes to our technical specifications, please see evaluation section below for discussion related to applicable regulatory guidance and requirements. UUTR SAR 12.1 describes the same organization structure as described in technical specifications and will be updated once appro ed by the NRC. :

Evaluation of proposed changes continuing to meet 10 CFR Requirements, NUREG:-1537 guidance, and ANSI/ANS 15.1:

NUREG-1537 section 12.1.1 with regards to organization structure of a research reactor facility states, "Intermediate levels should show the individuals who are in charge of the reactor facility and reactor operations (e.g., the facility director and the operations manager)." This requirement is still satisfied with our new proposed structure, since we are continuing to have intermediate levels of supervision that include the Reactor Facility Director and a Reactor Supervisor in between the operating staff and the Vice President of Research, who is ultimately responsible for the facility license.

Additionally, appendix 14.1 section 6.1 ofNUREG-1537 points to ANSI/ANS 15.1 for structure and responsibility. The University intends to follow this structure. However, the distinction that the ANSI/ANS 15.1 Level 2 is the UNEP Director will be removed. This change will allow the University administration to select an individual with reactor facility expertise as a dedicated ANSI/ANS 15.1 Level 2 and a separate person (who may or may not have reactor specific knowledge) as the UNEP Director.

NUREG-153 7 does not contain any references to the position of reactor supervisor (or operations manager except for the previously mentioned point that it is supposed to be an intermediate level in the organization structure). Rather, it states, "staffing requirements shall meet at a minimum, the requirements of 10 CFR 50.54(i), G), (k), (1), and (m)(l). The applicant should show that these requirements are met" Of the mentioned sections in 10CFR 50.54, only 10 CFR 50.54 (m)(l) is applicable to the proposed changes for "events requiring the direction of the RS". 10 CFR 50.54 (m)(l) states:

A senior operator licensed pursuant to part 55 of this chapter shall be present at the facility or readily available on call at all times during its operation, and shall be present at the facility during initial start-up and approach to power, recovery from an unplanned or unscheduled shut-down or significant reduction in power, and refueling, or as otherwise prescribed in the facilJty license.

ANSI/ANS 15.1 6.1.3.3 repeats these requirements as well and cites the duties are for an SRO.

Similarly, ANSI/ANS 15.1 6.1.3.1 only requires an SRO to be readily available on call.

Therefore, it is justifiable to return these responsibilities to an SRO since that is the acceptable standard established in nuclear regulatory guidance.

Requested Time frame for this change: September 1st, 2023

UUTR TECHNICAL SPECIFICATIONS AND BASES

6. ADMINISTRATIVE CONTROLS 6.1 Organization Individuals at the various management levels, in addition to being responsible for the policies and operation of the reactor facility, shall be responsible for safeguarding the public and facility personnel from undue radiological exposures and for adhering to all requirements of the operating license, technical specifications, and federal regulations.

6.1.1 Structure The reactor administration shall be related to the University as shown in Fig. 6-1.

6.1.2 Responsibilities The following specific organizational levels, and responsibilities shall exist:

1. The UUTR is an integral part of the Utah Nuclear Engineering Facilities (UNEF) of the University of Utah Nuclear Engineering Program (UNEP)~

University ef Utaf:l. The organization of the facility management and operation is illustrated in Fig. 6-1. The responsibilities and authority of each member of the operating staff shall be defined in writing, and

2. As indicated in Fig. 6.1, the RSC shall report to Level 1. Radiation safety personnel shall report to Level 2. Additional description of levels follows:

2.1 Level 1: Individual responsible for the reactor facility's licenses, i.e., the Associate Vice President for Research in the Office of Vice President for Research; The Vice President for Research will assign which of the Associate Vice Presidents for Research will be the responsible Level 1 individual.

2.2 Level 2: Individual responsible for reactor facility operation, i.e., the Utaf:l N11elear Engineering Faeilit*1 {UNEF) ManagerReactor Facility Director, shall be tf:le Qireetereftf:le Utaf:l N11elear Engineering Pregrarn fU-NE!lt,an individual designated by the University administration who satisfies the requirements of ANSI 15.4.

2.3 Level 3: Individual responsible for day-to-day operation or shift shall be J page 56

UUTR TECHNICAL SPECIFICATIONS AND BASES the Reactor Supervisor (RS). This person shall be an SRO.

I p age 57

UUTR TECHNICAL SPECIFICATIONS AND BASES 2.4 Level 4: Operating staff shall be SROs, ROs, and trainees.

i CofflMMlild (M'IJ:JJpdltlcJap.6-1 LEVELi TIie IJnNffllty of Utah .

Vlc:eprmidlntfor

"-<h(VPR)

T 'I lEVEl2 Dlnictar of the UH£P REACTOR Mllnapr of the Utah Nuclear En1ineerin1 IC***** SAFETY COMMITTEE (RSC) facifrty (UNEF) ,)

~ T lEVEL3 Radiation Safety Committee c----* 5upeMso<y Senior Reattol"Operator (SRO)

,)

T Line of communication lEVEL4 Line of responsibility Operatinc Slaff And reporting JFonnltt9d: Centered LEVELi The University of Utah Vice President for Research t

LEVEL2 REACTOR

- Reactor Faciity Director Responsible for reactor I<* .* *>

SAFETY COMMITTEE facility operations (RSC)

" t Radiation Safety LEVEL3 Committee I< - - -> Reactor supervisory senior Operator (SRO)

Line of t

<- - -> communication LEVEL4 Line of responsibility Operating Staff

+--+ and reporting Figure 6-1 Unhlersity of Utah Administrative Organization for Nuclear Reactor Operations I p age 58

UUTR TECHNICAL SPECIFICATIONS ANO BASES 6.1.3 Staffing

1. The minimum staffing when the reactor is operating shall be:

1.1 A licensed RO or the RS in the control room, 1.2 A second person present in the UNEF able to carry out prescribed instructions, and, 1.3 If neither of these two individuals is the RS, the RSan SRO. an SRO shall be readily available on call. Readily available on call means an individual who:

i. Has been specifically designated and the designation is known to the operator on duty, ii. Can be rapidly contacted by phone by the operator on duty, and, iii. Is capable of getting to the reactor facility within a reasonable time under normal conditions (e.g., 30 minutes or within a 15-mile radius).

2. A list of reactor facility personnel by name and telephone number shall be readily available in the control room for use by the operator. The list shall include:

2.1 l::l~IEP E>iFeetor aRElfor l::INEF MaRageFReactor Facility Director 2.2 Reactor Supervisor (RS}

2.3 Radiation Safety Officer 2.4 Any Licensed RO or SRO

3. Events requiring the presence at the facility of an SROElireetioR of the RS:

3.1 Initial startup and approach to power of the day, 3.2 All fuel or control-rod relocations within the reactor core region, 3.3 Relocation of any in-core experiment or irradiation facility with a reactivity worth greater than one dollar, and, 3.4 Recover from unplanned or unscheduled shutdown or significant power reduction.

I p age 59

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.1.4 Selection and Training of Personnel The selection, training and requalification of operations personnel shall be in accordance with current revision of ANSI/ANS 15.4 ~988J Rl9992016; R202l,j. "Standard -* *{ ~ l',\A2]: Updated RftislDn forthlsgulda,.:e for the Selection and Training of Personnel for Research Reactors."

I p age 60

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.2 Review and Audit The RSC shall have primary responsibility for review and audit of the safety aspects of reactor facility operations. The RSC or a subcommittee thereof shall audit reactor operations semiannually. Minutes, findings or reports of the RSC shall be presented to Level 1 and Level 2 management within ninety (90) days of completion.

6.2.1 RSC Composition and Qualifications An RSC of at least five (S) members knowledgeable in fields, which relate to reactor engineering and nuclear safety, shall review and evaluate the safety aspects associated with the operation and use of the facility. Level 1 management shall appoint the RSC members and RSC chair. Individuals may be either from within or outside the University of Utah. Qualified and approved alternates may serve in the absence of regular members. The Level 2 and Level 3 should be the members of the RSC but they shall not comprise a majority of voting RSC members.

6.2.2 RSC Rules The operations of the RSC shall be in accordance with written procedures including provisions for:

1. Meeting frequency (at least annually),

2. Voting rules,

3. Quorums (S members, no more than two voting members may be of the operating staff at any time),

4. Method of submission and content of presentation to the committee,

5. Use of subcommittees, and,

6. Review, approval, and dissemination of minutes.

I p age 61

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.2.3 RSC Review Function The responsibilities of the RSC, or designated Subcommittee thereof, include, but are not limited to, the following:

1. Review all changes made under 10 CFR 50.59,

2. Review of all new procedures and substantive changes to existing procedures,

3. Review of proposed changes to the technical specifications, license or charter,

4. Review of violations of technical specifications, license, or violations of internal procedures or instructions having safety significance,

5. Review of operating abnormalities having safety significance,

6. Review of all events from reports required in Sections 6.6.1 and 6.7.2 of these Technical Specifications,

7. Review of audit reports, and,

8. Review of the experiments and classes of the experiments.

6.2.4 RSC Audit Function The RSC or a Subcommittee thereof shall audit reactor operations at least annually. The annual audit shall include at least the following:

1. Facility operations for conformance to the technical specifications and applicable license or charter conditions,

2. The retraining and requalification program for the operating staff,

3. The results of action taken to correct those deficiencies that may occur in the reactor facility equipment, systems, structures, or methods of operation that affect reactor safety, and

4. The Emergency Response Plan and implementing procedures.

I p age 62

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.3 Radiation Safety The Radiation Health Physicist from the Radiological Health Department shall be responsible for implementation of the radiation safety program. The requirements of the radiation safety program are established in 10 CFR 20. The program shall use the guidelines of the ANSI/ANS 15.11 - 1993; R2004, "Radiation Protection at Research Reactor Facilities."

! Page 63

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.4 Procedures Written operating procedures shall be adequate to assure the safety of operation of the reactor, but shall not preclude the use of independent judgment and action should the situation require such. Operating procedures shall be in effect for the following items:

1. Startup, operation and shutdown of the reactor,

2. Fuel loading, unloading, and movement within the reactor,

3. Maintenance of major components of systems that could have an effect on reactor safety,

4. Surveillance checks, calibrations, and inspections required by the technical specifications or those that have an effect on reactor safety,

5. Radiation protection,

6. Administrative controls for operations and maintenance and for the conduct of irradiations and experiments that could affect reactor safety or core reactivity,

7. Implementation of required plans such as emergency or security plans, and,

8. Use receipt, and transfer of by-product material held under the reactor license.

Substantive changes to the above procedures shall be made only after review by the RSC. Except for radiation protection procedures, unsubstantive changes shall be approved prior to implementation by the Level 2YNiP QireEter and documented by the Level 2YNEP Qirecter within 120 days of implementation. Unsubstantive changes to radiation protection procedures shall be approved prior to implementation by the Radiation Safety Officer (RSO), and documented by the RSO within 120 days of implementation.

Temporary deviations from the procedures may be made by the responsible SRO in order to deal with special or unusual circumstances or conditions. Such deviations shall be documented and reported by the next working day to the Level 2YNEP Qirecter.

I Page 64

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.5 Experiments Review and Approval Approved experiments shall be carried out in accordance with established and approved procedures. Procedures related to experiment review and approval shall include:

1. All new experiments or class of experiments shall be reviewed by the RSC and approved in writing by the Level 2 or designated alternates prior to initiation, and,

2. Substantive changes to previously approved experiments shall be made only after review by the RSC and approved in writing by the Level 2 or designated alternates. Minor changes that do not significantly alter the experiment may be approved by Level 3 or higher.

) Page 65

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.6 Required Actions 6.6.1 Actions to Be Taken in Case of Safety Limit Violation In the event a safety limit (fuel temperature) is exceeded:

1. The reactor shall be shut down and reactor operation shall not be resumed until authorized by the NRC,

2. An immediate notification of the occurrence shall be made to the Level

,ZUNl!:PDiFeeter, Jnd Chairperson of the RSC, NRC, and,

3. A report, and any applicable follow-up report, shall be prepared and reviewed by the RSC. The report shall describe the following:

3.1 Applicable circumstances leading to the violation including, when known, the cause and contributing factors, 3.2 Effects of the violation upon reactor facility components, systems, or structures and on the health and safety of personnel and the public, and, 3.3 Corrective action to be taken to prevent recurrence.

6.6.2 Actions to Be Taken in the Event of an Occurrence of the Type Identified in Section 6.7.2 Other than a Safety Limit Violation For all events, which are required by regulations or Technical Specifications to be reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under Section 6.7.2, except a safety limit violation, the following actions shall be taken:

1. The reactor shall be secured and Level 2UNl!:P E>ireeter notified,

2. Operations shall not resume unless authorized by the Level 2UNEP Directer,

3. The RSC shall review the occurrence at their next scheduled meeting, and,

4. A report shall be submitted to the NRC in accordance with Section 6.7.2 of these Technical Specifications.

! Page 66

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.7 Reports 6.7.1 Annual Operating Report An annual report shall be created and submitted by the Reactor SupervisorYNE-P-

-9tf:eetef to the U.S. N RC by the end of July of each year consisting of:

1. A brief summary of operating experience including the energy produced by the reactor and the hours the reactor was critical,

2. The number of unplanned SCRAMs, including reasons therefore,

3. A tabulation of major preventative and corrective maintenance operations having safety significance,

4. A brief description, including a summary of the safety evaluations, of changes in the facility or in procedures and of tests and experiments carried out pursuant to 10 CFR 50.59, S. A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or prior to the point of such release or discharge. 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 less than 25 % of the concentration allowed or recommended, a statement to this effect is sufficient,

6. A summarized result of environmental surveys performed outside the facility, and,

7. A summary of exposures received by facility personnel and visitors where such exposures are greater than 25 % of that allowed.

I p age 67

UUTR TECHNICAL SPECIFICATIONS ANO BASES 6.7.2 Special Reports In addition to the requirements of applicable regulations, and in no way substituting therefore, reports shall be made by the Level 2YNEP QiFeetoF to the NRC as_follows:

1. A report not later than the following working day by telephone and confirmed in writing by facsimile to the NRC Headquarters Operation Center, and followed by a written report that describes the circumstances of the event within 14 days to the U.S. NRC, Attn: Document Control Desk, Washington, D.C. 20555, of any of the following:

1.1 Violation of the safety limit, 1.2 Release of radioactivity from the site above allowed limits, 1.3 Operation with actual safety system settings from required systems less conservative than the limiting safety system setting, 1.4 Operation in violation of limiting conditions for operation, 1.5 A reactor safety system component malfunction that renders or could render the reactor safety system incapable of performing its intended safety function. If the malfunction or condition is caused by maintenance, then no report is required, 1.6 An unanticipated or uncontrolled change in reactivity greater than one dollar. Reactor trips resulting from a known cause are excluded; 1.7 Abnormal and significant degradation in reactor fuel or cladding, or both, coolant boundary, or confinement boundary (excluding minor leaks) where applicable, or 1.8 An observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to reactor operations, and

2. A report within 30 days in writing to the U.S. NRC, Attn: Document Control Desk, Washington, D.C. 20555 of:

2.1 Permanent changes in the facility organization involving Level 1- 2 personnel, and 2.2 Significant changes in the transient or accident analyses as described in the Safety Analysis Report.

( Page 68

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.8 Records 6.8.1 Records to be Retained for a Period of at Least Five Years or for the Life of the Component Involved if Less than Five Years

1. Normal reactor operation {but not including supporting documents such as checklists, log sheets, etc., which shall be maintained for a period of at least one year),

2. Principal maintenance activities,

3. Reportable occurrences,

4. Surveillance activities required by the Technical Specifications,

5. Reactor facility radiation and contamination surveys,

6. Experiments performed with the reactor,

7. Fuel inventories, receipts, and shipments,

8. Approved changes to the operating procedures, and,

9. RSC meetings and audit reports.

6.8.2. Records to be Retained for at Least One Certification Cycle Records of retraining and requalification of licensed ROs and SROs shall be retained at all times the individual is employed or until the certification is renewed. For the purpose of this technical specification, a certification is an NRC issued operator license.

! Page 69

UUTR TECHNICAL SPECIFICATIONS AND BASES 6.8.3 Records to be Retained for the Lifetime of the Reactor Facility

1. Gaseous and liquid radioactive effluents released to the environs,

2. Offsite environmental monitoring surveys,

3. Radiation exposures for all personnel monitored,

4. Drawings of the reactor facility, and S. Reviews and reports pertaining to a violation of the safety limit, the limiting safety system setting, or a limiting condition of operation.

I P age 70