ML23194A184

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North Carolina State University - Safety Evaluation for the Application for a License Amendment Request for TS 6.1.1 Regarding Training of Level 3 Management
ML23194A184
Person / Time
Site: North Carolina State University
Issue date: 07/20/2023
From: Holly Cruz
NRC/NRR/DANU/UNPL
To: Hawari A
North Carolina State University
References
EPID L-2023-NFA-0004
Download: ML23194A184 (1)


Text

July 20, 2023 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 -- ISSUANCE OF AMENDMENT NO. 19 TO RENEWED FACILITY OPERATING LICENSE NO. R-120 AND TECHNICAL SPECIFICATIONS FOR THE PULSTAR NUCLEAR RESEARCH REACTOR RE: TRAINING OF LEVEL 3 MANAGEMENT (EPID NO. L-2023-NFA-0004)

Dear Dr. Hawari:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 19 to Renewed Facility Operating License No. R-120 for the North Carolina State University (NCSU) PULSTAR Nuclear Research Reactor. The amendment modifies technical specification (TS) 6.1.1, Organizational Structure, in response to NCSUs application dated July 6, 2023 (Agencywide Documents Access and Management System Accession No. ML23187A455). The amendment revises the TSs to extend the time required for the Manager of Engineering and Operations to become a certified senior reactor operator (SRO) from within one year to within two years. The amendment is based on the typical time needed for training and facility experience before becoming an SRO at NCSU and other similar facilities.

The request is consistent with statements in NUREG-1478, Revision 2, Operator Licensing Examiner Standards for Research and Test Reactors (ML072000059), regarding SRO applications.

A. Hawari A copy of the related safety evaluation is also enclosed. If you have any questions, please contact me at (301) 415-1053, or by email at Holly.Cruz@nrc.gov.

Sincerely, Signed by Cruz, Holly on 07/20/23 Holly D. Cruz, Senior 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

Enclosures:

1. Amendment No. 19 to Renewed Facility Operating License No. R-120
2. Safety Evaluation cc w/enclosures: GovDelivery Subscribers

ML23194A184 NRR-058 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA OGC/NLO NAME HCruz NParker JWachutka DATE 7/13/23 7/17/23 7/20/23 OFFICE NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME JBorromeo HCruz DATE 7/20/23 7/20/23 NORTH CAROLINA STATE UNIVERSITY DOCKET NO. 50-297 PULSTAR NUCLEAR RESEARCH REACTOR AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 19 License No. R-120

1. The U.S. Nuclear Regulatory Commission (NRC, the Commission) has found that:

A. The application for amendment to Renewed Facility Operating License No. R-120, filed by the North Carolina State University (the licensee) on July 6, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance that (i) the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; E. The issuance of this amendment is in accordance with 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, of the Commissions regulations and all applicable requirements have been satisfied; and F. Prior notice of this amendment was not required by 10 CFR 2.105, Notice of proposed action, and publication of a notice of issuance for this amendment is not required by 10 CFR 2.106, Notice of issuance.

Enclosure 1

2. Accordingly, the license is amended as described in Attachment 1 to this license amendment and by changes to the Technical Specifications as indicated in Attachment 2. The following paragraph of Renewed Facility Operating License No. R-120 is hereby amended to read as follows:

2.C.(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 19, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Joshua M. Digitally signed by Borromeo Joshua M. Borromeo Joshua M. Borromeo, Chief Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Attachments:

1. Changes to Renewed Facility Operating License No. R-120
2. Changes to Appendix A, Technical Specifications Date of Issuance: July 20, 2023

ATTACHMENT 1 TO LICENSE AMENDMENT NO. 19 RENEWED FACILITY OPERATING LICENSE NO. R-120 DOCKET NO. 50-297 Replace the following page of Renewed Facility Operating License No. R-120 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Renewed Facility Operating License No. R-120 Remove Insert Attachment 1

C. This license shall be deemed to contain and is subject to the conditions specified in Parts 20, 30, 50, 51, 55, 70, and 73 of 10 CFR Chapter I, to all applicable provisions of the Act, and to the rules, regulations, and orders of the Commission now or hereafter in effect and to the additional conditions specified below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady-state power levels not to exceed 1000 kilowatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 19, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Physical Security Plan The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security plan, including all amendments and revisions made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p), which are part of the license.

This plan, which contains information withheld from public disclosure under 10 CFR 2.790, is entitled NCSU PULSTAR Physical Security Plan, Revision 8, dated January 12, 1996.

D. This license is effective as of the date of issuance and shall expire 20 years from its date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation

Enclosure:

Appendix A Technical Specifications Date of Issuance: April 30, 1997 Amendment No. 19 July 20, 2023

ATTACHMENT 2 TO LICENSE AMENDMENT NO. 19 RENEWED FACILITY OPERATING LICENSE NO. R-120 DOCKET NO. 50-297 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Technical Specifications Remove Insert Cover Page Cover Page Attachment 2

Appendix A Technical Specifications for the North Carolina State University PULSTAR Reactor Facility License No. R-120 Docket No. 50-297 Amendment No. 19 Date: July 20, 2023

Appendix A Amendment 19 Technical Specifications July 20, 2023 Level 3 - Manager of Engineering and Operations The Manager of Engineering and Operations (MEO) performs duties as assigned by the NRP Director associated with the safe and efficient operation of the facility as specified in the facility license and Technical Specifications. The MEO is responsible for coordination of operations, experiments, and maintenance at the facility, including reviews and approvals of experiments as defined in Technical Specification 1.2.9 and 6.5, and making minor changes to procedures as stated in Technical Specification 6.4. The MEO shall receive appropriate facility specific training within three months of appointment and be certified as a Senior Reactor Operator within two years of appointment. The minimum qualifications for the MEO are a Bachelor of Science in engineering or physical science and at least six years of nuclear experience related to fission reactor technology. The degree may fulfill up to four years of the required six years of nuclear experience on a one-for-one time basis. The MEO reports to the NRP Director.

Level 4 - Operating and Support Staff This level includes licensed Senior Reactor Operators (SRO), licensed Reactor Operators (RO), and other personnel assigned to perform maintenance and technical support of the facility. Senior Reactor Operators and Reactor Operators are responsible for assuring that operations are conducted in a safe manner and within the limits prescribed by the facility license and Technical Specifications, applicable Nuclear Regulatory Commission regulations, and the provisions of the Radiation Safety Committee and Reactor Safety and Audit Committee. All Senior Reactor Operators shall have three years of nuclear experience and shall have a high school diploma or successfully completed a General Education Development test. A maximum of two years equivalent full-time academic training may be substituted for two years of the required three years of nuclear experience as applicable to research reactors for Senior Reactor Operators. Other Level 4 personnel shall have a high school diploma or shall have successfully completed a General Education Development test. All Level 4 personnel report to the Manager of Engineering and Operations.

Reactor Health Physicist The Reactor Health Physicist (RHP) is responsible for implementing the radiation protection program and monitoring regulatory compliance at the reactor facility. The RHP shall have a high school diploma or shall have successfully completed a General Education Development test and have three years of relevant experience in applied radiation safety. A maximum of two years equivalent full-time academic training may be substituted for two years of the required three years of experience in radiation safety as SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 19 TO RENEWED FACILITY OPERATING LICENSE NO. R-120 NORTH CAROLINA STATE UNIVERSITY PULSTAR NUCLEAR RESEARCH REACTOR DOCKET NO. 50-297

1.0 INTRODUCTION

By letter dated July 6, 2023 (Agencywide Documents Access and Management System Accession No. ML23187A455), North Carolina State University (NCSU, the licensee) requested an amendment to Renewed Facility Operating License No. R-120 for the NCSU PULSTAR nuclear research reactor under the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit. Specifically, the licensee requested to revise the facilitys technical specifications (TSs) to extend the time required for the Manager of Engineering and Operations (MEO) to become a certified senior reactor operator (SRO) from within one year to within two years. The amendment is based on the typical time needed for training and facility experience before becoming an SRO at NCSU and other similar facilities. NCSU stated that the request is consistent with statements in NUREG-1478, Revision 2, Operator Licensing Examiner Standards for Research and Test Reactors (ML072000059), regarding SRO applications. To this end, NCSU proposed to change TS 6.1.1, Organizational Structure, to require certification as an SRO for the Level 3 MEO from within one year to within two years of appointment.

1.1 BACKGROUND

The NCSU PULSTAR nuclear research reactor is located in the Burlington Engineering Laboratory complex on the NCSU campus in Raleigh, North Carolina. The reactor, which was built by the American Machine and Foundry Company, is a heterogeneous light-water moderated and cooled, pool-type reactor that uses uranium dioxide fuel. NCSU is currently authorized to operate the reactor at a maximum steady-state thermal power level of 1.0 megawatt-thermal.

NCSUs currently approved TSs (ML14136A070), state at TS 6.1.1, in part, that the Level 3 MEO shall receive appropriate facility specific training within three months of appointment and be certified as a Senior Reactor Operator within one year of appointment. The proposed Enclosure 2

change to the TSs would extend the time required for the MEO to become a certified SRO from within one year to within two years of appointment.

2.0 REGULATORY EVALUATION

The U.S. Nuclear Regulatory Commission (NRC, the Commission) staff considered the following applicable regulatory requirements and guidance during its review of the proposed changes:

Section 50.92, Issuance of amendment, of 10 CFR, which states, in part, that in determining whether an amendment to a license will be issued, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

Section 50.34, Contents of applications; technical information, of 10 CFR, which states, in part, that each application for a construction permit shall include a preliminary plan for the applicants organization, training of personnel, and conduct of operations and that each application for an operating license shall include the applicants organizational structure, allocations or responsibilities and authorities, and personnel qualifications requirements.

NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content (ML042430055), which provides guidance on the format and content of non-power reactor licensing applications.

NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria (ML042430048), which provides guidance on the conduct of NRC licensing reviews of non-power reactor licensing applications.

NUREG-1478, Revision 2, Operator Licensing Examiner Standards for Research and Test Reactors (ML072000059), which establishes the procedures and practices for administering initial and requalification written examinations and operating tests for applicants for and holders of operators licenses.

3.0 TECHNICAL EVALUATION

3.1 Technical Specification Changes Changes discussed in this section use the following format: a strikethrough indicates a deletion from the TSs and an underline indicates an addition to the TSs.

3.1.1 Introductory Change The proposed change to the TS title page is:

Amendment No. 1819 This proposed change would change the amendment number given for the TSs from License Amendment No. 18 to License Amendment No. 19. The licensee stated that this proposed

change would reflect the requested, newly issued amendment. The NRC staff finds that this proposed change would be consistent with the issuance of the requested amendment by updating the revision number to reflect that issuance and would not alter the meaning or intent of the TSs. Therefore, the NRC staff concludes that the proposed change to the TS title page is acceptable.

3.1.2 Administrative Controls Change The proposed change to TS 6.1.1 of the administrative controls TSs is:

Level 3 - Manager of Engineering and Operations The Manager of Engineering and Operations (MEO) performs duties as assigned by the NRP [Nuclear Reactor Program] Director associated with the safe and efficient operation of the facility as specified in the facility license and Technical Specifications. The MEO is responsible for coordination of operations, experiments, and maintenance at the facility, including reviews and approvals of experiments as defined in Technical Specification 1.2.9 and 6.5, and making minor changes to procedures as stated in Technical Specification 6.4. The MEO shall receive appropriate facility specific training within three months of appointment and be certified as a Senior Reactor Operator within onetwo years of appointment. The minimum qualifications for the MEO are a Bachelor of Science in engineering or physical science and at least six years of nuclear experience related to fission reactor technology. The degree may fulfill up to four years of the required six years of nuclear experience on a one-for-one time basis.

The MEO reports to the NRP Director.

In accordance with 10 CFR 50.92, in determining whether the proposed change will be issued, the NRC staff was guided by the considerations that govern the issuance of initial licenses at 10 CFR 50.34, including the requirement for appropriate training and qualifications of personnel. The NRC staff finds that the proposed change represents an appropriate training and qualification requirement for the MEO because it aligns TS 6.1.1 with the guidance in NUREG-1478, Revision 2. This is because NUREG-1478, Revision 2, Examiner Standard 202N, Section E, Initial License Eligibility Guidelines, items 2 and 3 related to SROs note that an SRO-Instant (SRO-I) applicant should have a minimum of 3 years of nuclear experience where two years of full-time academic training may be substituted for 2 years of experience and that an SRO-Upgrade (SRO-U) applicant should have a minimum of 1 year of experience as a reactor operator (RO) at the facility or meet the requirements for an SRO-l and because the training to become an RO or SRO takes up to one year. Since one year of experience and one year of training is typically required to become an SRO according to NUREG-1478, Revision 2, a requirement for the MEO to be certified as an SRO within two years of appointment is an appropriate training and qualification requirement. Requiring the MEO to be certified as an SRO within two years of appointment is also consistent with the remainder of the requirements of TS 6.1.1, which provide that the MEO must have at least six years of nuclear experience and that a degree may fulfill up to four years of the required six years of nuclear experience on a one-for-one time basis. Therefore, the NRC staff concludes that the proposed change to TS 6.1.1 is acceptable.

4.0 ENVIRONMENTAL CONSIDERATION

The amendment relates to changes in administrative requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: H. Cruz, NRR Date: July 20, 2023