ML23243B064

Utah Issuance of Amendment No. 10 to Facility License No. R-126 and Technical Specifications for the University of Utah Triga Nuclear Reactor Re Administrative Changes

ML23243B064
Person / Time
Site:	University of Utah
Issue date:	09/19/2023
From:	Xiaosong Yin NRC/NRR/DANU/UNPL
To:	Sjoden G Univ of Utah
Yin X
References
EPID L-2023-NFA-0006
Download: ML23243B064 (1)

Text

September 19, 2023 Dr. Glenn E. Sjoden, Director University of Utah Nuclear Engineering Program Energy Solutions Presidential Endowed Chair Department of Civil and Environmental Engineering 110 Central Campus Drive, Room 2000 Salt Lake City, UT 84112

SUBJECT:

UNIVERSITY OF UTAH -- ISSUANCE OF AMENDMENT NO. 10 TO FACILITY OPERATING LICENSE NO. R-126 AND TECHNICAL SPECIFICATIONS FOR THE UNIVERSITY OF UTAH TRIGA NUCLEAR REACTOR RE:

ADMINISTRATIVE CHANGES (EPID L-2023-NFA-0006)

Dear Dr. Sjoden:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 10 to Facility License No. R-126 for the University of Utah TRIGA Nuclear Reactor (UUTR). The amendment revises technical specifications (TSs) 6.1, 6.4, 6.6, and 6.7, related to administrative changes in response to UUTRs application dated June 21, 2023 (Agencywide Documents Access and Management System Accession No. ML23192A110). The amendment revises the TSs to modify the UUTRs organizational structure and the roles and responsibilities of the reactor staff. UUTR indicated that the proposed changes continue to meet Title 10 of the Code of Federal Regulations (10 CFR) requirements and is consistent with NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development Technical Specifications for Research Reactors, ANSI/ANS-15.4-2016, Selection and Training of Personnel for Research Reactors, and 10 CFR 50.54, Conditions of licenses.

G. Sjoden A copy of the related safety evaluation is also enclosed. If you have any questions, please contact me at (301) 415-1404, or by email at Xiaosong.Yin@nrc.gov.

Sincerely, Signed by Yin, Xiaosong on 09/19/23 Xiaosong Yin, 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. 50-407 License No. R-126

Enclosures:

1. Amendment No. 10 to Facility Operating License No. R-126

2. Safety Evaluation cc w/enclosures: GovDelivery Subscribers

ML23243B064 NRR-058 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA OGC/NLO NAME XYin NParker DRoth DATE 9/5/2023 9/6/2023 9/19/2023 OFFICE NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME JBorromeo (HCruz for) XYin DATE 9/19/2023 9/19/2023 UNIVERSITY OF UTAH DOCKET NO. 50-407 TRIGA NUCLEAR REACTOR AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 10 License No. R-126

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

A. The application for amendment to Facility Operating License No. R-126, filed by the University of Utah (the licensee) on June 21, 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 paragraphs of Facility Operating License No. R-126 is hereby amended to read as follows:

2.C.(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 10, 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 Holly D. Digitally signed for Cruz by Holly D. Cruz 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 Facility Operating License No. R-126

2. Changes to Appendix A, Technical Specifications Date of Issuance: September 19, 2023

ATTACHMENT 1 TO LICENSE AMENDMENT NO. 10 FACILITY OPERATING LICENSE NO. R-126 DOCKET NO. 50-407 Replace the following page of Facility Operating License No. R-126 with the attached revised page. The revised page is identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License No. R-126 Remove Insert Attachment 1

c. to receive, possess, and use in connection with operation of the facility, up to 240 grams of plutonium in the form of a plutonium-beryllium neutron source; and

d. to receive, possess, use, but not separate, in connection with operation of the facility, such special nuclear material as may be produced by the operation of the facility.

(3) Pursuant to the Act and 10 CFR Part 30, to receive, possess, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which cannot be separated except for byproduct material produced in non-fueled experiments.

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

(1) Maximum Power Level The licensee is authorized to operate the facility at a steady-state power level not in excess of 100 kilowatts (thermal) as specified in the Technical Specifications.

(2) Technical Specification The Technical Specifications contained in Appendix A, as revised through Amendment No. 10, 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 physical security plan approved by the Commission and all amendments and changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p), respectively. The approved plan, which is exempt from public disclosure pursuant to the provisions of 10 CFR 73.21, is entitled, University of Utah Physical Security Plan for the Protection of SNM of Low Strategic Significance under Licenses R-25 and R-126, Revision 1, dated July 28, 1980.

Amendment No. 10 September 19, 2023

ATTACHMENT 2 TO LICENSE AMENDMENT NO. 10 FACILITY OPERATING LICENSE NO. R-126 DOCKET NO. 50-407 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 56 56 57 57 58 58 59 59 63 63 65 65 66 66 67 67 Attachment 2

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).

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 facilitys 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 Reactor Facility Director, shall be 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 the Reactor Supervisor (RS). This person shall be an SRO.

l P a g e 56 Amendment No. 10 September 19, 2023

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

Figure 6-1 University of Utah Administrative Organization for Nuclear Reactor Operations l P a g e 57 Amendment No. 10 September 19, 2023

UUTR TECHNICAL SPECIFICATIONS AND 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 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 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 Reactor 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 SRO:

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.

l P a g e 58 Amendment No. 10 September 19, 2023

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 - 2016; R2021, Standard for the Selection and Training of Personnel for Research Reactors.

l P a g e 59 Amendment No. 10 September 19, 2023

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 2 and documented by the Level 2 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 2.

l P a g e 63 Amendment No. 10 September 19, 2023

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 2, and 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 2 notified,

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

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.

l P a g e 65 Amendment No. 10 September 19, 2023

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 Supervisor to the U.S. NRC 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,

5. 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.

l P a g e 66 Amendment No. 10 September 19, 2023

UUTR TECHNICAL SPECIFICATIONS AND 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 2 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 ControlDesk, 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 l P a g e 67 Amendment No. 10 September 19, 2023

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 10 TO FACILITY OPERATING LICENSE NO. R-126 UNIVERSITY OF UTAH TRIGA NUCLEAR REACTOR DOCKET NO. 50-407

1.0 INTRODUCTION

By letter dated June 21, 2023 (Agencywide Documents Access and Management System Accession No. ML23192A110), University of Utah TRIGA Nuclear Reactor (UUTR) requested an amendment to Renewed Facility License No. R-126 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.

The licensee requested to revise its technical specifications (TSs) to modify its organizational structure involving level 2 management of the UUTR and to specify the roles and responsibilities for the reactor operators, senior reactor operators and the reactor supervisor. UUTR indicated that proposed changes continue to meet 10 CFR requirements and is consistent with NUREG-1537 Guidelines for Preparing and Reviewing Applications for the Licensing of Non Power Reactors, American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors, ANSI/ANS-15.4-2016, Selection and Training of Personnel for Research Reactors, and 10 CFR 50.54, Conditions of licenses. UUTR proposes to change TS 6.1 and the subsections of TS 6.1 and sections of TSs 6.4, 6.6, and 6.7 to reflect the proposed changes.

2.0 REGULATORY EVALUATION

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

Part 50, Domestic Licensing of Production and Utilization Facilities, of 10 CFR, which provides for the licensing of production and utilization facilities, including research reactors.

Enclosure 2

10 CFR 50.36(c)(5), Administrative controls, TSs include administrative controls, which are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

10 CFR 50.54, Conditions of licenses, provides paragraphs that are, with certain exceptions, conditions in every nuclear power reactor operating license issued under 10 CFR Part 50. 10 CFR 50.54(m)(1) states that a licensed senior reactor operator 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 facility license.

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.

ANSI/ANS-15.1-2007, The Development of Technical Specifications for Research Reactors, ANSI/ANS-15.4-2016, Selection and Training of Personnel for Research Reactors,

3.0 TECHNICAL EVALUATION

Description of the proposed change:

The UUTR proposes to make the following changes to the administrative section of the TSs:

1) Amendment to the TSs, section 6.1.2, Responsibilities, that specifies the responsibilities of Level 2 management of the UUTR facility and modifies the organizational chart to reflect the change.

2) Amendment to TS 6.1.3, Staffing, staffing requirements for changing the requirements from events requiring direction of the RS to events requiring the presence at the facility of an SRO and to have an SRO readily available on call versus the RS.

3) Amendment to TS 6.1.4, Selection and Training of Personnel, which refers to ANSI/ANS-15.4 as the standard protocol related to the facility personnel issues.

4) Amendment to TS 6.4, Procedures, to designate the responsibilities to the level 2 management for the facility procedures.

5) Amendment to TS 6.6.1, Actions to be taken in Case of Safety Limit Violation, to specify the responsibility of level 2 in taking this action.

6) Amendment to TS 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, to clarify the level 2s responsibility in taking these actions.

7) Amendment to TS 6.7, Reports, to designate the reactor supervisors responsibility for annual facility reporting.

8) Amendment to TS 6.7.2, Special Reports, to clarify level 2 managers responsibility for special reporting.

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

The current 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).

The proposed TS 6.1.2.2 states:

2.2 Level 2: Individual responsible for reactor facility operation, i.e., the Reactor Facility Director, shall be an individual designated by the University administration who satisfies the requirements of ANSI/ANS 15.4.

According to the licensee, 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 TSs.

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. This amendment would provide the University flexibility in its selection of a director of UNEP versus another individual knowledgeable of reactor policy that would be able to serve as the Reactor Facility Director, i.e., ANSI-15.4 Level 2 management.

The current TS 6.1.2.2.2.4 organization chart:

Figure 6-1 University of Utah Administrative Organization for Nuclear Reactor Operations

The proposed TS 6.1.2.2.2.4 has the following with regard to Level 2:

Figure 6-1 University of Utah Administrative Organization for Nuclear Reactor Operations This organization chart change is to incorporate the change for 6.1.2.2 into this chart.

The current TS 6.1.3 states:

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

1.3 If neither of these two individuals is the RS, the RS shall be readily available on call. Readily available on call means an individual who

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 UNEP Director and/or UNEF Manager

3. Events requiring the direction of the RS Changes discussed in this section use the following format: bold indicates an addition to the TSs.

The proposed TS 6.1.3 states:

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:

2.1 Reactor Facility Director

3. Events requiring the presence at the facility of an SRO:

According to the licensee, by changing the terminology in TS 6.1.3.3 from requiring direction of the RS to TS 6.1.3.3 'requiring the presence at the facility of an SRO, the TSs will be matching the wording mentioned in 10 CFR 50.54 and ANSI/ANS-15.1. The current 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. As for TS 6.1.3.2.1, it is to reflect the change regarding the level 2 change as in TS 6.1.2.2.

Furthermore, according to the licensee, applicable 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 (per ANSI/ANS-15.1-2007 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.

Evaluation of proposed changes The NRC staff has reviewed the proposed changes by the licensee and finds that NUREG-1537, Part 1, 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). The licensees request to change the level 2 in the organization structure is consistent with this definition of the intermediate levels. In addition, ANSI/ANS-15.1-2007 specifically defines the level 2 as individual responsible for reactor facility operation, (i.e., the Facility Director/Manager/Administrator). Plus, ANSI/ANS-15.4-2016 has the level 2 defined as facility director or administrator, therefore NRC staff finds the proposed change to TS 6.1.2.2.2.2 to change the wording in the TSs regarding the level 2 is acceptable. The NRC staff also finds that TS 6.1.2.2.2.2 change also directly affects TSs 6.4, 6.6.1, 6.6.2, 6.7.1 and 6.7.2, in these TSs subsections, all references of UNEP Director has been proposed to change to level 2, for the same reason above, they are acceptable. Proposed TSs 6.1.2.2.2.4 is a graphic reflection of 6.1.2.2.2.2 change for the UUTR organizational chart and therefore is acceptable.

Proposed TS 6.1.3.2.2.2 regarding reactor supervisor has been defined in 6.1.2.2.2.3, therefore it is not necessary to redefine. Therefore, this change is not incorporated.

As for TSs 6.1.3.1.3 and 6.1.3.3 the proposed changes regarding an SRO functions and responsibilities are consistent with the requirements of 10 CFR 50.54(m)(1). ANSI/ANS-15.1 has also provides the similar requirements. Based on the requirements of 10 CFR 50.54 and ANSI/ANS-15.1 standard, the proposed change to TS 6.1.3.3 is acceptable. TS 6.1.3.2 has proposed to change from UNEP director and/or UNEF Manager to Reactor Facility Director

which is to make it consistent with the proposed level 2 change through the TSs, as discussed above, the change is acceptable.

TS 6.1.4 has proposed to update the reference of ANSI/ANS-15.4 from 1988 to 2016 version.

The two versions are factually identical and after its routine update, the 2016 version maintains all the essential elements of the 1988 version. The NRC staff finds that referring to the 2016 standard will provide the necessary guidance for the continuation of safe operation of the facility, therefore it is acceptable.

TS 6.1.2.1 is an editorial change made by the licensee, that the wording of at the University of Utah, was deleted. The wording was not necessary because firstly it did not alter the organizational function of the licensee and secondly it makes the statement of TS 6.1.2.1 more clear to read. The revised TS will continue to provide the necessary provisions to assure safe operation of the facility because the removed wording is not necessarily needed to assure safe operation of the facility, therefore it is acceptable.

4.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, paragraph (b), no environmental assessment or environmental impact statement is required for any action within the category of actions listed in 10 CFR 51.22(c), for which the Commission has declared to be a categorical exclusion.

The NRC staff determined that changes to the TSs in this amendment are related to training, experience, qualifications, or other employment suitability requirements.

Accordingly, this change in the amendment meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(3)(iv).

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: X. Yin, NRR Date: September 19, 2023