ML23334A195

Response to Request for Additional Information in Reference to LAR 2023-1: License Amendment Request Section 5 of the Technical Specifications and Bases for the Washington State University Modified Triga Reactor and Facility License R-76, P

ML23334A195
Person / Time
Site:	Washington State University
Issue date:	11/30/2023
From:	Hines C Washington State Univ
To:	Paulette Torres Office of Nuclear Reactor Regulation, Document Control Desk
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ML23334A194	List: ML23334A195 ML23334A197
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Download: ML23334A195 (1)

Text

Nuclear Science Center November 30, 2023 Document Control Desk ATTN: Paulette Torres, Project Manager U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

Washington State University Modified TRIGA Reactor License No. R-76; Docket No.50-027

Subject:

Response to Request for Additional Information in Reference to LAR 2023-1: License Amendment Request - Section 5 of the Technical Specifications and Bases for the Washington State University Modified TRIGA Reactor and Facility License R-76, Proposed Amendment 22

Dear Ms. Torres:

The following responses are in reference to the U.S. NRC request for addition information dated September 20, 2023. These RAI responses and further proposed changes clarify sections in technical specifications that use certain descriptive language when referring to certain parts or a whole of either the WSU reactor, a licensed area, or the research reactor facility.

RAI 1: The TSs definition for Licensed Area in section 1 DEFINITIONS is not identical to how it is redefined in proposed TSs section 5.1(3) and has the potential to cause confusion. Submit a proposed change to TSs 5.1(3) reconciling the License Area definition differences (e.g., a single definition for Licensed Area) or provide a justification why reconciling the License Area definition difference are not needed.

WSU Response: The proposed change to TS 5.1(3) is attached. In summary, WSU proposes removal of the TS specification 5.1(3) as the term licensed area is already defined in section 1.

Justification: The removal of TS 5.1(3) is necessary because it redefines the research reactor facility to be a licensed area. The research reactor facility is a restricted area; only a part of the research reactor facility is a licensed area as defined in section 1.

RAI 2: The facility in TSs section 5.1(4) was not defined in TSs section 1 DEFINITIONS.

a) Clarify if the term The facility in TS 5.1(4) and the term Research Reactor Facility in TS section 1 DEFINITIONS are the same.

PO Box 641300, Pullman, WA 991641300 l 5093358641 l nsc.wsu.edu l or.nsc@wsu.edu

WSU LAR 2023-1 RAI Response 11/30/2023 Page 2 of 2 b) If the terms are not the same, explain why two different definitions are needed and provide a definition for The facility to avoid confusion from Research Reactor Facility or provide a justification why a definition for The facility is not needed.

WSU Response: The proposed change to TS 5.1(4) is attached. In summary, WSU proposes to change instances facility to research reactor facility in TS specification 5.1(4) and in locations in the TS where the facility is use where research reactor facility should instead be used.

Justification: The terms the facility, Dodgen Research Facility, the building, and research reactor facility are synonymous. Throughout the technical specifications, these terms are used interchangeably. In order to clarify and prevent redefinition of descriptive terms outside of those terms defined in TS section 1, new definitions must not be introduced in subsequent sections.

WSU proposes amending instances in the Technical Specifications where the facility, the building, or Dodgen Research Facility as they are synonymous to research reactor facility. In a similar fashion, instances of ventilation system or pool room ventilation system should be reactor ventilation system as to avoid confusion. Additionally, WSU proposes to change instances of "facility or facility area used in reference to BNC facility as stated in the definitions in section 1.

Justification: The terms BNC facility and research reactor facility are defined in section 1 of the Technical Specifications. Those terms, along with the applicability obtained from their definition in the Technical Specifications, should be used in sections to distinguish between different areas within the research reactor facility or of the research reactor facility as a whole.

If you have any questions, please do not hesitate to contact me.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 11/30/2023 .

Best regards, C. Corey Hines Director

Attachment:

Proposed Amendment 22 to the License, Technical Specifications, and Bases for the WSU Modified TRIGA Reactor - Microsoft Word (editable) document