ML23332A105

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University of Texas at Austin - Regulatory Audit Re Renewal of Facility Operating License No. R-129 for Its Triga Mark II Nuclear Reactor
ML23332A105
Person / Time
Site: University of Texas at Austin
Issue date: 12/07/2023
From: Geoffrey Wertz
NRC/NRR/DANU/UNPL
To: Charlton W
University of Texas at Austin
Geoffrey Wertz, NRR/DANU
References
EPID L-2020-NFR-0009
Download: ML23332A105 (1)
v • d • e


Text

December 7, 2023 Dr. William Charlton, Director Nuclear Engineering Teaching Laboratory The University of Texas at Austin Pickle Research Campus, Building 159 10100 Burnet Road Austin, TX 78758

SUBJECT:

UNIVERSITY OF TEXAS AT AUSTIN - REGULATORY AUDIT IN SUPPORT OF LICENSE RENEWAL APPLICATION FOR THE UNIVERSITY OF TEXAS AT AUSTIN TRIGA MARK II NUCLEAR REACTOR (EPID NO. L-2020-NFR-0009)

Dear Dr. Charlton:

By letter dated December 12, 2011 (Agencywide Documents Access and Management System Accession No. ML12156A097), as supplemented, by letter dated August 4, 2023 (ML23216A212 - cover letter, and ML23279A146 - updated safety analysis report (SAR), and ML23216A214 - technical specifications (TSs), the University of Texas at Austin (UTA) submitted an application for renewal of Facility Operating License No. R-129 for its TRIGA Mark II Nuclear Reactor. The requested licensing action would renew the facility operating license for a period of 20 years.

The U.S. Nuclear Regulatory Commission (NRC) staff will conduct a virtual regulatory audit beginning on December 18, 2023, and continue as necessary. The intent of the audit is to gain a better understanding of the license renewal application (LRA), specifically the updated SAR and TSs provided by letter dated August 4, 2023. In addition, the regulatory audit will identify information that support the basis of the licensing decision and allow the NRC staff to efficiently gain insights necessary to complete its review of the UTA LRA. The NRC staff has provided a copy of the audit plan as an enclosure to this letter.

To improve the efficiency of the virtual audit, UTA and NRC staff discussed the implementation of an online reference document portal, established by UTA staff, that would allow the NRC staff to have read-only access to documents and other reference materials cited in the LRA.

At the completion of the audit, the NRC staff will provide an audit summary. The summary will include a description of any information identified during the audit that will need to be docketed to supplement the LRA and allow the NRC staff to continue its review.

The NRC staff completed an audit of the UTA neutronics and thermal-hydraulic analyses and documented its results in letter dated March 7, 2023 (ML23052A171). Based on the NRC staffs audit review and familiarity with the UTA LRA, the NRC staff expects to complete its review and make a final determination on the LRA by July 2025.

W. Charlton We appreciate your support in providing the requested documentation and access to the online reference document portal that will assist in an efficiently conducted audit. If you have any questions regarding the NRC staffs audit, please contact me at 301-415-0893, or by email at Geoffrey.Wertz@nrc.gov.

Sincerely, Signed by Wertz, Geoffrey on 12/07/23 Geoffrey A. Wertz, 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. 50-602 License No. R-129

Enclosure:

As stated cc: GovDelivery Subscribers

ML23332A105 NRR-106 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME GWertz NParker JBorromeo(HCruz for) GWertz DATE 11/28/2023 12/1/2023 12/7/2023 12/7/2023 OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT PLAN REGARDING RENEWAL OF FACILITY OPERATING LICENSE NO. R-129 UNIVERSITY OF TEXAS AT AUSTIN TRIGA MARK II NUCLEAR REACTOR DOCKET NO. 50-602

1. Background

The U.S. Nuclear Regulatory Commission (NRC) staff is continuing its review of the University of Texas at Austin (UTA) license renewal application (LRA) for its TRIGA Mark II Nuclear Reactor provided by letter dated December 12, 2011 (Agencywide Documents Access and Management System Accession No. ML12156A097), as supplemented by letter dated August 4, 2023 (ML23216A212 - cover letter, and ML23279A146 - updated safety analysis report (SAR), and ML23216A214 - technical specifications (TSs)). This regulatory audit is intended to assist the NRC staff in its review of the LRA.

2. Regulatory Audit Bases The purpose of this audit is to determine if the licensees LRA requesting renewal of Facility Operating License No. R-129 meets the applicable regulatory requirements of Title 10 of the Code of Federal Regulations and addresses the applicable guidance provided in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 1, Format and Content, and Part 2, Standard Review Plan and Acceptance Criteria (ML042430055 and ML042430048, respectively).
3. Regulatory Audit Scope The NRC staff will conduct this audit via teleconference and/or video conference with UTA staff.

This audit will provide information necessary to complete the NRC staffs evaluation of the LRA.

In addition, the regulatory audit may identify additional information that will be required to be docketed to support the basis of the licensing decision and will allow NRC staff to gain insights more efficiently on the license renewal.

The NRC staff will request the use of the online reference document portal provided by UTA staff. Access to the online portal is limited to only the NRC staff on the audit team and will be controlled by email addresses or the use of passwords, and the documents in the online portal are read-only (i.e., to prevent NRC staff from saving, copying, downloading, or printing any documents). The conditions associated with the online reference document portal must be maintained throughout the review process. The NRC staff who should be granted access to the portal are those listed in the Audit Team section below. The NRC staff will provide a request to close the online reference document portal at the conclusion of the audit.

Enclosure

4. Information and Other Material Necessary for the Regulatory Audit The UTA staff should be prepared to begin discussions with the NRC staff on the regulatory audit questions provided with this letter, involving the updated UTA SAR and UTA TSs, provided by letter dated August 4, 2023 (ML23279A146, and ML23216A214, respectively).

Audit Team The NRC staff performing this audit, and their respective review areas, are listed below:

  • Joe Staudenmeier (Technical Reviewer- thermal-hydraulic, accidents)
  • Justin Hudson (Technical Reviewer - technical specifications, accidents)
  • Andrew Miller (Technical Reviewer - technical specifications, accidents)
  • Santosh Bhatt (Technical Reviewer - reactor)
  • Madelyn Nagel (Technical Reviewer - environmental)
  • Rao Tammara (Technical Reviewer - environmental)
  • Brian Glowacki (Technical Reviewer - environmental)
5. Logistics The audit will involve a focused review between the NRC and UTA staff. The audit will initiate on December 18, 2023, as discussed in an email dated October 16, 2023. Following the focused audit review, the audit will continue as necessary until NRC staff have adequate understanding of issues to be addressed to complete the review of the LRA. The audit activities will be conducted via teleconference and video conferences, as appropriate, to support the efficient gathering of information by the NRC staff.

An entrance meeting teleconference will commence the audit, as indicated in the schedule below. Additional audit activities, such as a daily status debriefs, may also be planned, as necessary, to support the understanding of information necessary to complete the review of the LRA. It is expected that additional interaction may be needed to identify information requests to support LRA review activities.

6. Audit Questions The questions for discussion during the regulatory audit are primarily based on the questions provided to UTA staff as an attachment to this enclosure. At the conclusion of the audit, requests for additional information (RAIs) may be issued by the NRC staff, or supplemental information may be provided by the licensee, in order to support the NRC staffs determinations and findings in support of the license renewal review.
7. Deliverables At the completion of the regulatory audit the NRC staff will prepare a regulatory audit summary, which will be issued by letter, within 90 days after the audit. The regulatory audit summary will include the documents reviewed, the audit activities, and any RAIs that were discussed or that will be issued based on the audit, as applicable.
8. Audit Schedule The NRC staff will conduct teleconferences and/or video conferences with UTA staff on the dates and times provided below. These times can be modified as necessary.

Monday, December 18, 2023 (all times are Eastern Daylight Time) 2:00 - 4:30 pm Entrance meeting/discussions between NRC and UTA staff

OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT QUESTIONS REGARDING RENEWAL OF FACILITY OPERATING LICENSE NO. R-129 FOR THE UNIVERSITY OF TEXAS AT AUSTIN TRIGA MARK II NUCLEAR REACTOR DOCKET NO. 50-602 By letter dated December 12, 2011 (Agencywide Documents Access and Management System Accession No. ML12156A097), as supplemented, by letter dated August 4, 2023 (ML23216A212 - cover letter, and ML23279A146 - updated safety analysis report (SAR), and ML23216A214 - technical specifications (TSs)), the University of Texas at Austin (UTA) submitted an application for renewal of Facility Operating License No. R-129 for the TRIGA Mark II Nuclear Reactor. The requested licensing action would renew the facility operating license for a period of 20 years.

During the U.S. Nuclear Regulatory Commission (NRC) staffs review of the updated SAR and TSs, questions have arisen for which information is needed for the NRC staff to determine that there is reasonable assurance of adequate protection of public health and safety and that applicable regulatory requirements are met. These questions identify information needed for the NRC staff to continue its review and may become formal requests for additional information following the regulatory audit.

Regulatory Basis and Applicable Guidance Documents The license renewal application for the UTA reactor is being evaluated using the applicable regulations in Title 10 of the Code of Federal Regulations (10 CFR), and the following guidance:

  • NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content, issued February 1996 (ML042430055)
  • NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, issued February 1996 (ML042430048)
  • American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007 (R2013) The Development of Technical Specifications for Research Reactors Attachment

The following questions refer to the UTA SAR (ML23279A146), unless stated otherwise.

Chapter 4 - REACTOR 4.1 Section 4.2.2.a states While there are no current plans to change the control rod inventory or configuration there are viable options for alternate control rod locations as indicated in Figure 4.5. The NRC staff would like to discuss viable options during the audit.

4.2 Section 4.2.2.b states Measurements of the actual rate provide a speed of 27 inches per minute (1.14 cm/s). Provide details on the measurements of these values.

Chapter 13 - ACCIDENT ANALYSIS 13.1 SAR section 13.2.1 states that while the licensed power level is 1.1 megawatt (MW),

calculations of accident radionuclide concentrations and doses were performed assuming reactor operation at 2 MW, including a hot channel core peaking factor of 1.7 and a single element power of 43.2 kilowatt (kW) for an 81-element core.

However, SAR section 13.2.2.a discusses iodine (I)-131 activity per element for equilibrium operation of the core at 3.5 kW, distributed over 81 elements and that the worst-case element would be about twice that. These assumptions appear to then be used to calculate the I-131 released from the worst-case element.

Explain the apparent discrepancy between SAR section 13.2.1, which states that a single element would have a power of 43.2 kW and SAR section 13.2.2.a., which indicates that a worst case element would be about 7 kW?

Also, in SAR sections 13.2.2.d, 13.2.2.e, and 13.2.2.h, a total power level of 3.5 MW is used. Clarify the different power levels and ensure that the application is clear and accurate regarding what power levels and assumptions are used in the different scenarios and why.

13.2 The last bullet of SAR section 13.2.2.e states that the maximum hypothetical derived air concentration (DAC) ratio is 1.14 for strontium (Sr)-90, yet table 13.5b, shows a maximum DAC ratio of 0.92. Explain this apparent discrepancy.

13.3 In SAR section 13.2.2.e, all the discussion is about controlling the dose to individuals from Sr-90, while iodines and gases have the higher DAC fraction in the short term?

Why isnt controlling doses from iodines and gasses also discussed?

13.4 SAR section 13.2.2.g.1 states that the auxiliary purge system operates at a nominal 1100 cubic feet per minute (0.52 cubic meters per second), yet equation 13.6 uses a value of 0.52 cubic centimeters per second. It is unclear if this is just an editorial error or it affects the results. Explain.

13.5 Editorial error: SAR section 13.2.2.g.1 states that the maximum X/Q value that provides the least dispersion is 0.001416 (Class C, 0.02 kilometers (km)). However, table 13.9 indicates that 0.001416 is Class C, 0.03 km.

13.6 It is unclear what table 13.10 is showing. Explain what the values in table 13.10 represent (what are the two things being compared).

13.7 Clarify this statement found in both SAR sections 13.2.2.g.2 and 13.2.2.h. The reactor bay ventilation system as described in Chapter 9 is designed to provide at least two air changes per hour (2.29 m3 s-1, 2.29E6 cm3 s-1), and produces about five air changes per hour.

13.8 SAR section 13.2.2.h discusses table 13.15. However, table 13.15 does not appear in this section (there is a table 13.15 provided later in chapter 15, but it does not provide the information discussed in section 13.2.2.h). Provide the missing table or clarify the language in the SAR.

13.9 SAR section 13.2.2.g.1 discusses a high efficiency particulate filter in the auxiliary purge system that is credited in the analysis, however, no other information related to the filter or its efficiency to filter different radionuclides is provided. Discuss the filter and the assumed efficiency for different radionuclides used in the analysis.

13.10 The quantities or concentrations of radionuclide calculated to be released from the ventilation stack or through building leakage following the maximum hypothetical accident (MHA) is not provided. Provide additional information regarding the total quantities of radionuclides released from the building through each pathway following the MHA (if in addressing the previous questions, this information becomes available or easy to calculate, it may not be necessary to provide new data).

13.11 In SAR section 13.4.1.b, are the doses specified in table 13.22, strictly from direct radiation shine? If so, is it accurate to say in a core uncover event that decay heat will not be sufficient to result in fuel damage and release of radioactive material?

13.12 In SAR section 13.7.2.c, explain table 13.24 better. What does the isotope yield in table 13.24 represent and what are its units? In table 13.24, explain how the sum/vol values were calculated (elsewhere in chapter 13 it states that the reactor bay free volume is 4120 m3 and that 10 percent is assumed to be occupied so the remaining volume is 3719 m3, yet the sum/vol values appear to be calculated with a different volume. In addition, based on the values, the sum/vol values would appear to use different volumes for strontium than for iodine).

Chapter 14 Technical Specifications General Comments/Questions:

  • For each TS limiting condition for operation (LCO), we need a basis for the completion times specified, (e.g., proposed TS 3.1.3.B, the completion time is Immediate, which can allow the TS to be in non-compliance condition for up to an hour).
  • Check TS section numbering for consistency.
  • Check for typographical issues.
  • The Basis information in TS section 5 is not required.
  • Can we get a change document to identify the differences between the current TSs and the proposed TSs.

14.1 The guidance in NUREG-1537, part 1, chapter 14, appendix 14.1, and ANSI/ANS-15.1-2007, states that the TS chapter 1, are titled Introduction, and include a section titled Scope. The proposed UTA TSs chapter 1 is titled Definitions, and no Scope section is provided. Provide the chapter 1 title and Scope section as provided in the guidance or justify why no change is needed. [Pg. TS-5]

14.2 The proposed definition of DAILY states, in part, or before an[y] operation extending more than 1 calendar day, which is not found in the guidance in ANSI/ANS-15.1-2007, nor does the statement seem to add any clarity since the definition already includes prior to operation each calendar day. Explain the meaning of the phrase or before an operation extending more than 1 calendar day.

[Pg. TS-6]

14.3 The proposed TS definition for IMMEDIATE states Without delay, and not exceeding one hour. The NRC staff are unable to find reference to this definition in the guidance in NUREG-1537, part 1, chapter 14, appendix 14.1 or ANSI/ANS-15.1-2007. The proposed definition could allow required action to be as long as an hour. The NRC staff is not clear as to the purpose for including a maximum upper boundary to this definition. If the upper time limit is to allow operation after exceeding the safety limit, limiting safety system setting (LSSS) and LCO, provide additional justification and basis for exceeding the TS limits for up to an hour. [Pg. TS-6]

14.4 The proposed TS definition REQUIRED ACTION (ACTION) is not consistent with the guidance in NUREG-1537, part 1, chapter 14, appendix 14.1 and ANSI/ANS-15.1-2007, and the NRC staff has the following issues for discussion

[Pg. TS-9]:

a. What does (ACTION) mean?
b. What are the applicable modes and where are they defined?
c. For every TS specification that has a completion time, is there a justification for why the amount of time that the condition is exceeded and why it is acceptable?

14.5 TS 1.0: The proposed TS definition SHUTDOWN MARGIN (1)(b) is unclear to the NRC staff as the section appears to be incomplete. Complete or provide an explanation for the specification. [Pg. TS-11]

14.6 TS 1.0: The proposed TS definition for TECHNICAL SPECIFICATION VIOLATION states that a violation only occurs when the LSSS is violated AND automatic action does not occur AND the required setpoint is set to a less conservative value. It is unclear to NRC staff the purpose of this section as the NRC issues violations when the LSSS value/setpoint is exceeded as determined by the NRC. Explain the purpose of this section. [Pg. TS-12]

14.7 TS 1.0: The proposed TS definition for TECHNICAL SPECIFICATION VIOLATION contains two section (3), A violation of a Limiting Condition for Operation occurs when and A violation of a Limiting Condition for Operation has not occurred if Re-number this section. [Pg. TS-12]

14.8 The proposed LSSS for reactor power level (TS 2.2.3, specification A) states that the power SHALL NOT exceed 1100 kW (th) in STEADY STATE MODE of operation.

The basis for this LSSS states that in the Limiting Core Configuration, reactor thermal power of 1210 kW (1100 kW and maximum instrument error of 10 percent) will result in a minimum Critical Heat Flux Ratio of 2.39 and a fuel temperature of 543 degrees Celsius. It is not clear to the NRC staff how the principle of instrument error is applied. It is not clear to the NRC staff if this principle of instrument error is applied to all safety system channels as well as reactor power.

Provide an explanation on how and when this principle of instrument error is applied.

[Pg. TS-14]

14.9 TS 3.1: Section numbering for proposed Applicability of Core Reactivity Limitations matches proposed Applicability of MEASURING CHANNELS. Additionally, section numbering is inconsistent with table of contents. Correct the section numbering for administrative clarity. [Pg. TS-15]

14.10 TS 3.1.3: It is not clear to the NRC staff as to what assurance there is that the shutdown margin (0.2% k/k) can be measured accurately and precisely. Typically, shutdown margins are within $0.50 for research reactors as NUREG-1537, part 1, chapter 14, appendix 14.1, section 3.1 (2), suggests. Provide an explanation/justification for this proposed specification. [Pg. TS-15]

14.11 TS 3.1.3, specification B: SAR section 4.5.3 states: [t]he limit on shutdown margin is 0.2% k/k with the most reactive control rod fully withdrawn, all moveable experiments in their most reactive state, ambient temperature, and xenon less than

$0.30. In this measurement, it could be possible that the xenon poison could be the negative reactivity keeping the reactor shutdown ($0.29 from xenon is greater than the shutdown margin of $0.285). It is not clear to the NRC staff why shutdown margin can be measured when the xenon poison reactivity in the core could be greater than the shutdown margin. Provide an explanation/justification for this proposed specification. [Pg. TS-15]

14.12 TS 3.2.3, specification A: 2.2% k/k = $3.14. This does not equal the amount in dollars in the statement/required action ($3.00). It is not clear to the NRC staff as to why the two reactivity numbers are used interchangeably. SAR section 13.3.1.b states from low power, the 2.2% k/k is the limit from low power pulsing. SAR section 13.3.1.c states that the $3.00 pulse is the pulsing limit from power. It is not clear to the NRC staff as to which value is the correct pulse reactivity limit. Provide an explanation for this proposed specification. [Pg. TS-17]

14.13 TS 3.3.3: It is not clear to the NRC staff as to why there are no scram setpoints listed in this section. The guidance in NUREG-1537, part 1, chapter 14, appendix 14.1, section 3.2 (4), suggests that a table should specify all required scram channels and setpoints, the minimum number of channels, and other functions performed by the channel. Provide a justification as to why this information is not included for this proposed specification. [Pg. TS-18]

14.14 TS 3.3.3: It is not clear to the NRC staff how instrument error is applied for the reactor power scram since there is a lack of power level setpoints. This relates back to how the LSSS setpoint was determined. See question 14.8. [Pg. TS-18]

14.15 TS 3.3.3, specification F: It is not clear to the NRC staff as to what these monitors are. Chapter 11 in the SAR does not describe what these monitors are specifically or what they measure. Provide an explanation for these monitors. [Pg. TS-18]

14.16 TS 3.3.4, specification G: It is unclear to the NRC staff as to why there is a six-month completion time for a TS required channel. The basis does not speak to this large inoperability timeframe. There is no relief statement that describes how the licensee will substitute or ensure the Argon (Ar)-41 effluents are measured. The reactor could be operated for six months without a TS required measuring channel. Provide a justification for this large inoperability timeframe for this required channel.

[Pg. TS-20]

14.17 TS 3.4: It is not clear to the NRC staff if the Argon continuous air monitor (CAM) is the same as the Argon monitor discussed in specification 3.3.3 and 3.3.4, specification g. There should be consistent usage of naming throughout the TSs for clarity if they are the same. Also, this monitor can be out of service for 6 months. The basis states that it should be a one-week repair time, even though TS 3.3.3, 3.3.4, and 3.4 all state six months. This is inconsistent. Provide an explanation/justification for these monitors and the out of service time inconsistencies. [Pg. TS-23]

14.18 TS 3.4: It is unclear to the NRC staff as to which of these radiation monitors are the lower or middle level area monitors. It is not clear to the NRC staff as to what type of detector they are, such as CAMs or area radiation monitors (ARMs). Provide an explanation as to the type of detectors and provide clarification for the usage of these names throughout the TS. [Pg. TS-23]

14.19 TS 3.4.3, specification A: The NRC staff potentially identified a typo in the specification (metes) versus (meters). [Pg. TS-23]

14.20 TS 3.4.4, specification D: The NRC staff requires additional justification for the completion time of one week for this CAM. The specification does not provide a substitute for the actions performed by this CAM. The basis does not describe how confinement will be isolated if the radiation reading reaches or exceeds the setpoint when the CAM is out of commission (OOC). It is unclear to the NRC staff how the operator would know what the particulate CAM is reading to satisfy this TS if it is down. The operator could have all these functions down and could still operate the reactor for one week with no substitutions. Provide additional justification for this proposed action statement. [Pg. TS-24]

14.21 TS 3.5: These required reactor safety system channels all have an hour completion time in the action statements. It is not clear to the NRC staff why the reactor can operate outside of the TSs for up to an hour. There is no guidance, substitutions, limits, or general controls in the immediate completion time basis. Provide an explanation as to why the reactor may be operated beyond the TSs for an hour, and provide the required substitutions, limits, and controls for operating beyond the TSs.

[Pg. TS-26]

14.22 TS 3.6.4, specification B: It is unclear to the NRC staff as to how would the operator know to initiate manual confinement if the particulate CAM is OOC. The reactor can be operated for a week while the particulate CAM is OOC. Since there are no

substitutions required for the CAM while it is out of service, provide a justification for how the operator will know to initiate the manual confinement. [Pg. TS-29]

14.23 TS 3.7: The NRC staff notes that there is a large amount of information missing that NUREG-1537, part 1, chapter 14, appendix 14.1 and ANSI/ANS-15.1-2007 recommends in this section (limits on materials, explosives, encapsulation requirements, etc.). Provide an explanation as to why this information is not included in this specification. [Pg. TS-31]

14.24 TS 3.9.4, specification D: It is not clear to the NRC staff as to what is the basis for allowing reactor coolant water to leak into the chilled water system up to an hour.

This could be classified as an uncontrolled release if this system leaves the controlled area. Provide a basis for the one-hour leak time that is allowed by the action statement. [Pg. TS-35]

14.25 TS 3.10: The NRC staff note that the numbering for this specification is incorrect.

[Pg. TS-36]

14.26 TS 3.10: It is not clear to the NRC staff as to why this specification is in the LCO.

This specification is normally covered in the surveillance requirements section and is not normally listed as an LCO. This specification seems redundant to standard operating principles for surveillance requirements. Provide a justification as to why this specification exists, and why this specification should be considered a LCO.

[Pg. TS-36]

14.27 General TS 4.0 comment: There are several redundant surveillances between the specifications. There are naming inconsistencies that cause confusion. It is not clear to the NRC staff why some surveillances have an applicability section and others do not. This is not consistent with the guidance in ANSI/ANS-15.1-2007, section 4.

14.28 TS 4.1.2: The guidance in NUREG-1537, part 1, chapter 14, appendix 14.1, section 4.2 (1) states that the frequency for measuring control rod reactivity worth should be performed at least annually. The surveillance frequency states to measure control rod reactivity worth biennially. It is not clear to the NRC staff why the frequency is not consistent with the guidance since the basis for this surveillance states that the biennial frequency is adequate. Provide an explanation for why this frequency is adequate. [Pg. TS-37]

14.29 TS 4.2.2: There are two different reactivity values discussed in this surveillance. The specification states that the transient pulse rod position shall not cause a reactivity insertion greater than 2.2% k/k. The basis states verifying pulse rod position corresponds to less than or equal to $3.00 ensures that the maximum pulsed reactivity meets the limiting condition for operation. It is not clear to the NRC staff why the specification limit of reactivity is larger (2.2% k/k = $3.14) than the basis reactivity ($3.00). Provide an explanation for why the basis reactivity is less than the specification reactivity. [Pg. TS-39]

14.30 TS 4.3.2: A surveillance requirement in this specification states, Lower- or middle level Area Radiation Monitor. It is not clear to the NRC staff if either monitor can meet the requirement, then why is the surveillance an or statement. It is not clear to

the NRC staff what controls the licensee has in place that will prevent an operator from putting a monitor in service that has not had the surveillance completed.

Provide an explanation or more justification for this surveillance requirement.

[Pg. TS-40]

14.31 TS 4.4.2: It is not clear to the NRC staff what the difference is between the ARMs and the upper, middle, and lower radiation monitors. Clarify the difference between the monitors. [Pg. TS-42]

14.32 There is an inconsistency between the calibration of the ARMs between TS 4.3 and TS 4.4. The NRC staff is not clear as to why there are redundant surveillance requirements for the same monitors, and why the redundant surveillances do not have the same requirement for calibration. It is unclear to the NRC staff if there are other ARMs that have a surveillance but are not listed in the LCO section. Provide an explanation/justification for these inconsistencies. [Pg. TS-42]

14.33 There is an inconsistency between the calibration of the Particulate Continuous Air Monitor between TS 4.3 and TS 4.4. The NRC staff is not clear as to why there are redundant surveillance requirements for the same monitors, and why the redundant surveillances do not have the same requirement for calibration. Provide an explanation/justification for this inconsistency. [Pg. TS-42]

14.34 TS 4.5.2: It is not clear to the NRC staff how the pool level scram can be channel checked. It is also not clear to the NRC staff why a reactor safety scram channel is not tested, or why the channel check is performed monthly. This is inconsistent with the guidance in NUREG-1537, part 1, chapter 14, appendix 14.1, section 4.2 (5),

which states that a channel test for all scram channels required by TSs should be performed before each reactor startup. Provide a justification for the deviation from the approved guidance. [Pg. TS-44]

14.35 TS 4.6.2: The NRC staff is not clear as to the kind of surveillance that is performed for ENSURE adequate auxiliary air purge system valve alignment (operability check, calibration, or inspection) and for the frequency of performance Prior to entering an operating mode with an EXPERIMENTAL FACILITY in use. There is no basis for CONFINEMENT ISOLATION damper inspection and the basis for the Ar-41 calculation states annual, but the specification states semiannual. Provide an explanation/justification for these inconsistencies. [Pg. TS-46]

14.36 TS 4.6.2: The NRC staff is not clear as to why is there no surveillance requirement for the argon purge system. Provide an explanation for the lack of a surveillance requirement for this purge system. [Pg. TS-46]

14.37 TS 4.7.2: It is not clear to the NRC staff as to why administrative controls for experiments are in the surveillance section of the TS. This is not consistent with the guidance in ANSI/ANS-15.1-2007, section 4.8. Provide an explanation for including the administrative controls in the surveillance section. [Pg. TS-47]

14.38 TS 4.7.2: It is not clear to the NRC staff why all experimental reactivity worths are not recorded. It is also not clear to the NRC staff why this is a surveillance requirement and not a part of the administrative review process. This surveillance is not

consistent with the guidance in ANSI/ANS-15.1-2007, section 4.8. Provide an explanation or additional justification for this proposed specification. [Pg. TS-47]

14.39 TS 4.8.3: The inspection frequency for the fuel measurement and visual inspection is not consistent with guidance in NUREG-1537, part 1, chapter 14, appendix 14.1, section 4.1 (6), which states, for pulsing TRIGA reactors, the fuel should be inspected and measured annually. Provide an explanation or additional justification as to why the proposed surveillance frequency is adequate. [Pg. TS-48]

14.40 TS 4.8.3: It is unclear to the NRC staff how a quarter of the core be inspected annually with a frequency of biennial. The frequency of biennial is not consistent with guidance in NUREG-1537, part 1, chapter 14, appendix 14.1, section 4.1 (6), which states the fuel should be inspected annually. Provide an explanation on how this proposed surveillance will be performed. [Pg. TS-48]

14.41 It is unclear to the NRC staff as to why TS 4.10 is a surveillance. The proposed TS 4.10 surveillance do not involve an operability check, calibration, or inspection as the guidance in ANSI/ANS-15.1-2007, section 4 and NUREG-1537, part 1, chapter 14, appendix 14.1, section 4 suggest. Provide an explanation or justification for this proposed surveillance. [Pg. TS-50]

14.42 TS 5.0: It is not clear to the NRC staff as to why the format changed for having a specification on each page to having multiple specifications on one page. Provide an explanation/justification for the format change.

14.43 The NRC staff identified a potential typographical error: TS 5.1.3, specification (l):

Should this be a 1 not an l? [Pg. TS-52]

14.44 TS 5.1.3, specification 2: It is unclear to the NRC staff what elements shall be loaded in an array except for experimental facilities or for single positions occupied by control rods and a neutron startup source. Provide an explanation for this process. [Pg. TS-52]

14.45 The NRC staff identified a potential typographical error: TS 5.3.3, specification (l):

Should this be a 1 not an l? [Pg. TS-53]

14.46 TS 5.3.3, specification 2: It is not clear to the NRC staff why this specification is not an LCO. If there is a concern with the free air volume in the reactor building, then it should be measured as a surveillance. Section 3.1.6.b of the SAR, Reactor Bay, states that the free air volume is 4575 cubic meters. It is not clear to the NRC staff how much of this volume is taken up by equipment, furniture, etc. Provide an explanation/justification for this proposed specification. [Pg. TS-53]

14.47 TS 5.3.3, specification 3: It is not clear to the NRC staff why this specification is not an LCO. ANSI/ANS-15.1-2007, section 3.7.2 (2), states that a limit shall be established at the point of release or measurement using accepted diffusion factors to the boundary. Provide and explanation/justification for this proposed specification.

[Pg. TS-53]

14.48 TS 5.3.3, specification 4: It is not clear to the NRC staff what the purpose is for this proposed specification. This proposed specification seems more like supplemental information or the definition of operable for the system than a TS. Provide a justification for this proposed specification, and if it is necessary, then provide a justification for why it is not an LCO. [Pg. TS-53]

14.49 TS 5.4: It is not clear to the NRC staff why are these experiment specifications not in the LCO for experiments, as per ANSI/ANS-15.1-2007, section 3.8, and NUREG-1537, part 1, chapter 14, appendix 14.1, section 3.8. The NRC staff notes that there appears to be some administrative controls in these specifications as well. Provide an explanation/justification for why these proposed specifications are captured in TS section 5 and not in TS section 3 and section 6, as per the guidance in NUREG-1537, part 1, chapter 14, appendix 14.1 and ANSI/ANS-15.1-2007.

[Pg. TS 54,55]

14.50 TS 6.0, general comments: The NRC staff identifies this section as disorganized.

The numbering is inconsistent, there are several typographical errors and format changes, and there is no specification on a radiation protection program.

14.51 TS 6.0.1: It is not clear to the NRC staff as to why the organizational structure from ANSI/ANS-15.18-1979 in the TS. ANSI/ANS-15.-1979 is not endorsed by NUREG-1537, part 1, chapter 14, appendix 14.1, section 6.1.1. It is not clear to the NRC staff who holds the facility license, as there are three level one positions. The position descriptions do not say who is the facility license holder. Provide an explanation/justification for the organizational chart and identify the facility license holder. [Pg. TS-57]

14.52 TS 6.0.2: It is not clear to the NRC staff why is the Dean of Cockrell School of engineering is missing from the functional responsibilities section. Provide a position description for this role. [Pgs. TS-58:62]

14.53 TS 6.1.3:

a. It is not clear to the NRC staff what are the requirements to be a SSRO. It is also not clear the NRC staff why the SSRO position not described in the functional responsibility section. Provide a position description and an explanation of the requirements for a SSRO. [Pg. TS-62]
b. Reactor Operator shall be at the reactor control console is very specific. It is not clear to the NRC staff if the operator needs to adjust something with the HVAC controls, is that still the reactor console, even though the ventilation controls are across the room? Provide an explanation on the personnel requirements for the control room during normal operation. [Pg. TS-62]
c. This section does not describe staffing requirements for fuel movements - only an SSRO needs to supervise. It is not clear to the NRC staff on who can move fuel while being supervised by the SSRO. Provide an explanation for personnel requirements for fuel movement. [Pg. TS-62]
d. It is not clear to the NRC staff as to why are the staffing requirements for the SSRO so restrictive. According to ANSI/ANS-15.1-2007, section 6.1.3, the

presence of a licensed senior reactor operator (SRO) is required to recover from an unplanned or unscheduled shutdown. If a licensed SRO is not the SSRO, according to these proposed controls, they cannot authorize a startup from an unexpected shutdown. This is not consistent with the guidance in ANSI/ANS-15.1-2007. Provide an explanation of this proposed specification.

[Pg. TS-62]

e. The NRC staff noticed that there was no mention of a called list in this section, as described by ANSI/ANS-15.1-2007, section 6.1.3 (2). Provide an explanation/justification for not needing an up-to-date call down list in the control room. [Pg. TS-62]

14.54 TS 6.2:

a. It is not clear to the NRC staff as to why are there no procedure requirement for surveillance activities. This is not consistent with the guidance in NUREG-1537 part 1, chapter 14, appendix 14.1, section 6.4, and ANSI/ANS-15.1-2007, section 6.4. It is also not clear to the NRC staff what is classified as routine maintenance. Provide an explanation/justification for this proposed specification.

[Pg. TS-64,65]

b. It is not clear to the NRC staff what the Written procedures shall also govern section means and the difference between the two procedure sections. Provide an explanation/justification for these procedures. [Pg. TS-64,65]
c. It is not clear to the NRC staff if the Oversight Committee review all major changes to these procedures in TS 6.2. Provide an explanation on what counts as a safety significant procedure and how it applies to the procedure section.

[Pg. TS-64,65]

14.55 TS 6.3:

a. In specification b (1), it is unclear to the NRC staff what happens when the reactor supervisor reviews the experiment operation. It is unclear to the NRC staff what happens after the written document is reviewed. Does the Reactor Oversight Committee review it? Is it a new experiment? Provide an explanation for this proposed specification. [Pg. TS-66]
b. It is unclear to the NRC staff as to who approves minor deviations and what is a minor deviation in a procedure. Provide an explanation for this proposed specification. [Pg. TS-66]
c. It is unclear to the NRC staff as to when does a change in an experiment result in a new experiment. Provide an explanation for this proposed specification.

[Pg. TS-66]

d. It is unclear to the NRC staff as to why there are several requirements in this section that seem to be non-TS related administrative controls. Provide an explanation as to why these requirements need to be in the proposed specifications. [Pg. TS-66]

14.56 TS 6.4: It is unclear to the NRC staff as to why is this section in the TS. The requalification program is approved by the NRC and required by 10 CFR Part 55, Operators' Licenses, Section 55.59, Requalification. Provide an explanation/justification for this proposed specification. [Pg. TS-67]

14.57 TS 6.5: It is not clear to the NRC staff as to why is this section in the TS. The emergency plan is required by the Operating License. Provide an explanation/justification for this proposed specification. [Pg. TS-67]

14.58 TS 6.6: It is not clear to the NRC staff as to why is this section in the TS. The physical security plan is required by the Operating License. Provide an explanation/justification for this proposed specification. [Pg. TS-67]

14.59 TS 6.7, specification f: The NRC staff is not clear on what report is referenced and the time frame for the submittal of the report. Provide a clarification for this report.

[Pg. TS-68]

14.60 TS 6.8:

a. It is not clear to the NRC staff as to why the definition for violation changes between the definition section and section 6 of the TS. It is also not clear to the NRC staff as to why the violation is defined twice in the TS. A violation is not typically defined in the TS, nor is it in the guidance documents NUREG-1537, part 1, chapter 14, appendix 14.1, or in ANSI/ANS-15.1-2007. Identify which definition is the correct definition for violation, and what the intended purpose is for defining a violation. [Pg. TS-68]
b. For specification 4: It is unclear to the NRC staff which limits in 10 CFR Part 20 on fission product release will trigger a reportable occurrence. It is also unclear to the NRC staff as to how this specification will meet the intent in ANSI/ANS-15.1-2007, section 6.7.2, fuel damage reportable occurrence. Provide an explanation/justification for this reporting requirement which is not consistent with the guidance. [Pg. TS-68]
c. It is unclear to the NRC staff as to why is there no reportable occurrence for release of other radioactive materials above the regulator limits. Provide a justification for this inconsistency from the guidance in ANSI/ANS-15.1-2007, section 6.7.2. [Pg. TS-68]
d. TS 6.8, specification b: It is unclear to the NRC staff as to why the reporting requirements to the NRC are not part of the proposed TS 6.8, specification b.

This is inconsistent with the guidance in NUREG-1537, part 1, chapter 14, appendix 14.1, section 6.7.2, and ANSI/ANS-15.1-2007, section 6.7.2. Provide a justification as to why the reporting requirements to the NRC are in their own section of the TSs. [Pg. TS-69]

14.61 TS 6.9: The NRC staff notes a section numbering inconsistency, which results in no activities listed in this section. Provide the correct numbering and identify the activities that should be listed in this section. [Pg. TS-69]

14.62 TS 6.10: It is not clear to the NRC staff as to why is this section not in reporting requirements section, TS 6.8, specification b. Provide a justification as to why the reporting requirements are in their own section of the TSs. [Pg. TS-70]

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