ML24262A198
| ML24262A198 | |
| Person / Time | |
|---|---|
| Site: | Idaho State University |
| Issue date: | 10/10/2024 |
| From: | Duane Hardesty NRC/NRR/DANU/UNPL |
| To: | Dunik-Gougar M Idaho State University |
| References | |
| EPID L-2023-NFA-0002 | |
| Download: ML24262A198 (1) | |
Text
Dr. Mary Lou Dunzik-Gougar Reactor Administrator Idaho State University Professor of Nuclear Engineering 921 S. 8th Avenue, MS 8060 Pocatello, ID 83209-8060
SUBJECT:
IDAHO STATE UNIVERSITY - ISSUANCE OF AMENDMENT NO. 8 TO RENEWED FACILITY OPERATING LICENSE NO. R-110, FOR IDAHO STATE UNIVERSITY AGN-201M RESEARCH REACTOR TO REMOVE A LOW POWER SCRAM CHANNEL (EPID NO. L-2023-NFA-0002)
Dr. Dunzik-Gougar:
The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 8 to Renewed Facility Operating License No. R-110 for the Idaho State University (ISU)
Aerojet-General Nucleonics (AGN)-201M research reactor. The amendment consists of changes to the renewed facility operating license and technical specifications (TSs) in response to your application dated February 13, 2023 (Agencywide Document Access and Management System Accession No. ML24283A157), as supplemented by letters dated June 15, 2023 (ML23174A111), and April 26, 2024 (ML24137A307).
Idaho State University requests that four changes be made to facility license R-110 Docket No. 50-284:
- 1) Removal of Channel 2 low scram.
- 2) Removal of the exception statement from TSs section 3.2.d.
- 3) Removal of Unit A and Unit B from TSs Table 3.1.
- 4) Correction of the reactivity insertion limit number ($ per second) in TSs section 3.2.b.
The first change will accommodate replacement of obsolete and commercially unavailable BF3 detectors with modern B10 lined detectors. The second change will prohibit potentially unsafe operating conditions. The third change will remove an artifact reference to a former control console. The fourth change corrects a typographical error.
October 10, 2024
M. Dunzik-Gougar 2
A copy of the NRC staffs safety evaluation is also enclosed. If you have any questions, please contact Andrew Miller at (301) 415-1080, or by email at Andrew.Miller@nrc.gov.
Sincerely, Duane A. Hardesty, 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. 50-284 License No. R-110
Enclosures:
1.
Amendment No. 8 to Renewed Facility Operating License No. R-110 2.
Safety Evaluation cc w/enclosures: GovDelivery Subscribers Signed by Hardesty, Duane on 10/10/24
ML24262A198 NRR-058 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA NAME AMiller DHardesty NParker DATE 9/19/2024 9/19/2024 9/20/2024 OFFICE OGC NLO NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME DRoth HCruz DHardesty DATE 10/9/2024 10/9/2024 10/10/2024 IDAHO STATE UNIVERSITY DOCKET NO. 50-284 IDAHO STATE UNIVERSITY AGN-201M RESEARCH REACTOR AMENDMENT TO RENEWED FACILITY OPERATING LICENSE NO. R-110 Amendment No. 8 License No. R-110 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to Renewed Facility Operating License No. R-110, filed by Idaho State University (the licensee) on February 13, 2023, as supplemented by letters dated June 15, 2023, and April 26, 2024, 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 set forth in 10 CFR Chapter I; 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.
2.
Accordingly, the license is amended as described in Attachment 1 to this amendment and by changes to the Technical Specifications as described in Attachment 2.
Paragraph 2.C.2 of Renewed Facility Operating License No. R-110 is hereby amended to read as follows:
2.
Technical Specification The Technical Specifications contained in Appendix A, as revised through Amendment No. 8, 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.
FOR THE NUCLEAR REGULATORY COMMISSION Holly D. Cruz, 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-110 2.
Changes to Appendix A, Technical Specifications Date of Issuance: October 10, 2024 Holly D. Cruz Digitally signed by Holly D. Cruz ATTACHMENT TO LICENSE AMENDMENT NO. 8 RENEWED FACILITY OPERATING LICENSE NO. R-110 DOCKET NO. 50-284 Replace the following page of Renewed Facility Operating License No. R-110 with the attached revised page. The revised page is identified by amendment number and contains vertical lines in the margin to indicate the areas of change.
Renewed Facility Operating License No. R-110 Remove Insert
- 2 -
Amendment No. 8 October 10, 2024 2.
Facility Operating License No. R-110 is hereby amended in its entirety to read as follows:
A. This license applies to the AGN-201M research reactor (herein the reactor), owned by the Idaho State University and located on its campus in Pocatello, Idaho, and is described in the application for license dated November 21, 1995, and supplements dated January 31, 2003 and July 10, 2003, (renewal herein referred to as the application), and authorized for operation of License No. R-110.
B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Idaho State University:
1.
Pursuant to Section 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use and operate the reactor as a utilization facility in accordance with the procedures and limitations described in the application and in this licensee; 2.
Pursuant to the Act and 10 CFR Part 70, Domestic Licensing of Special Nuclear Material, to receive, possess and use up to 995 grams of contained uranium-235, enriched to 20% in uranium dioxide (UO2) embedded in radiation stabilized polyethylene, in connection with the operation of the reactor; and 3.
Pursuant to the Act and 10 CFR Part 30, Rules of General Applicability to Domestic Licensing of Byproduct Material, to possess, but not to separate, such byproduct material as may be produced by the operation of the reactor.
C. This license shall be deemed to contain and be subject to the conditions specified in Parts 20, 30, 40, 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 reactor at steady-state power levels up to a maximum of 5 watts (thermal).
2.
Technical Specification The Technical Specifications contained in Appendix A, as revised through Amendment No. 8, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
ATTACHMENT TO LICENSE AMENDMENT NO. 8 RENEWED FACILITY OPERATING LICENSE NO. R-110 DOCKET NO. 50-284 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contains vertical lines in the margin to indicate the areas of change.
Technical Specifications Remove Insert Page 9 of 31 Page 9 of 31 Page 10 of 31 Page 10 of 31 Page 11 of 31 Page 11 of 31
Page 9 of 31 Amendment No. 8 October 10, 2024 Specification a.
The total scram withdrawal time of the safety rods and coarse control rod shall be less than 1 second.
b.
The average reactivity addition rate for each control or safety rod shall not exceed 0.065% k/k per second ($0.0877 per second).
c.
The safety rods and coarse control rod shall be interlocked such that:
(1)
Reactor startup cannot commence unless both safety rods and coarse control rods are fully withdrawn from the core.
(2)
Only one safety rod can be inserted at a time.
(3)
The coarse control rod cannot be inserted unless both safety rods are fully inserted.
d.
All reactor safety system instrumentation shall be operable in accordance with Table 3.1.
- e.
The shield water interlock shall be set to prevent startup and scram the reactor if the shield water level falls 10 inches below the highest point on the reactor shield tank manhole opening.
- f.
The shield water temperature interlock shall be set to prevent reactor startup and scram the reactor if the shield water temperature falls below 15°C.
- g.
The seismic displacement interlock sensor shall be set to prevent reactor startup and scram the reactor during a seismic displacement.
- h.
A manual scram shall be provided on the reactor console.
- i.
A loss of electric power shall cause the reactor to scram.
- j.
An operable installed area radiation monitor capable of detecting gamma radiation shall be immediately available to reactor operating personnel whenever the reactor is not secured. When required monitors are inoperable, portable instruments may be substituted for any installed monitor for periods up to two weeks, while the installed monitor is being repaired.
Basis The specifications on scram withdrawal time in conjunction with the safety system instrumentation and set points assure safe reactor shutdown during the most severe foreseeable transients. Interlocks on control and safety rods assure an orderly approach to criticality and an adequate shutdown capability. The limitations on reactivity addition rates allow only relatively slow increases of reactivity so that ample time will be available for manual or automatic scram during any operating conditions.
Page 10 of 31 Amendment No. 8 October 10, 2024 The neutron detector channels (Nuclear Safety Channels Nos. 1 through 3) assure that reactor power levels are adequately monitored during reactor startup and operation.
Requirements on minimum neutron levels will prevent reactor startup unless Channel 1 is operable and responding, and will cause a scram in the event of instrumentation failure. The power levels initiate redundant automatic protective action at power level scrams low enough to assure safe shutdown without exceeding any safety limits. The period scram conservatively limits the rate of rise of reactor power to periods which are manually controllable and will automatically scram the reactor in the event of unexpected large reactivity additions.
The AGN-201's negative temperature coefficient of reactivity causes a reactivity increase with decreasing core temperature. The shield water temperature interlock will prevent reactor operation at temperatures below 15°C thereby limiting potential reactivity additions associated with temperature decreases.
Water in the shield tank is an important component of the reactor shield and operation without the water may produce excessive radiation levels. The shield tank water level interlock will prevent reactor operation without adequate water levels in the shield tank.
The reactor is designed to withstand 0.6g accelerations and 6 cm displacements. A seismic instrument causes a reactor scram whenever the instrument receives a horizontal acceleration that causes a horizontal displacement of 1/16 inch or greater. The seismic displacement interlock assures that the reactor will be scrammed and brought to a subcritical configuration during any seismic disturbance that may cause damage to the reactor or its components.
The manual scram allows the operator to manually shut down the reactor if an unsafe or otherwise abnormal condition occurs that does not otherwise scram the reactor. A loss of electrical power de-energizes the safety and coarse control rod holding magnets causing a reactor scram and thus assuring safe and immediate shutdown in case of a power outage.
An area radiation monitor must always be available to operating personnel to provide an indication of any abnormally high radiation levels so that appropriate action can be taken to shut down the reactor and assess the hazards to personnel.
Page 11 of 31 Amendment No. 8 October 10, 2024 Table 3.1 Reactor control and safety systems set-point specifications.
SAFETY CHANNEL SET POINT FUNCTION Nuclear Safety Channel No. 1 (Startup Count Rate Channel)
Low Power 0.5 counts/second Scram at levels below the set points Nuclear Safety Channel No. 2 (Log Power Channel)
High Power 6 watts (120% of licensed power)
Scram at power
> 6 watts Reactor Period 5 seconds Scram at periods
< 5 seconds Nuclear Safety Channel No. 3 (Linear Power Channel)
High Power 6 watts (120% of licensed power)
Scram at power
> 6 watts Nuclear Safety Channel No. 3 (Linear Power Channel)
Low Power 5% Full Scale Scram at levels
< 5% of Full Scale Manual Scram Scram at operator option Area Radiation Monitor
< 10 mR/hr Alarm at or below level set to meet requirements of 10 CFR 20 3.3 Limitations on Experiments Applicability This specification applies to experiments installed in the reactor and its experimental facilities.
Objective To prevent damage to the reactor or excessive release of radioactive materials in the event of an experiment failure.
Specification a.
Experiments containing materials corrosive to reactor components or which contain liquid or gaseous, fissionable materials shall be doubly encapsulated.
b.
Explosive materials shall not be inserted into experimental facilities or the reactor or stored within the confines of the reactor facility.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 8 TO RENEWED FACILITY OPERATING LICENSE NO. R-110 IDAHO STATE UNIVERSITY IDAHO STATE UNIVERSITY AGN-201M RESEARCH REACTOR DOCKET NO. 50-284
1.0 INTRODUCTION
By letter dated February 13, 2023, (Agencywide Documents Access and Management System Accession No. ML24283A157), as supplemented by letters dated June 15, 2023, and April 26, 2024 (ML23174A111 and ML24137A307, respectively), Idaho State University (ISU, the licensee) requested an amendment to Renewed Facility Operating License No. R-110 for its Aerojet General Nucleonics (AGN) 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.
2.0 BACKGROUND
The licensees license amendment request (LAR) is primarily based on the need to replace obsolete and commercially unavailable neutron detectors. The detector replacements require a change to technical specification (TS) 3.2, Control and Safety Systems, Table 3.1, Reactor Control and Safety Systems Set-Point Specifications, to remove the Nuclear Safety Channel No. 2 (Channel 2) low power scram and a related revision to TS 3.2, specification d to remove the exception allowing Nuclear Safety Channel No. 1 (Channel 1) to be bypassed. Additionally, the licensee proposes to modify TS 3.2, table 3.1 to remove a reference to an optional display console that has been removed. The licensee proposes to correct a typographical error in TS 3.2, specification b for reactivity insertion rate.
3.0 REGULATORY EVALUATION
The NRC staff evaluated the LAR based on the following regulations and guidance:
Part 20, Standards for Protection Against Radiation, of 10 CFR, which provides the regulatory requirements for protection against ionizing radiation resulting from activities conducted under licenses issued by the Nuclear Regulatory Commission (NRC).
Part 50, Domestic Licensing of Production and Utilization Facilities, of 10 CFR, which provides the regulatory requirements for licensing of non-power reactors.
Section 50.34(b)(2) of 10 CFR, which requires a description and analysis of the SSCs of the facility, with emphasis upon performance requirements, the bases, with technical justification therefor, upon which such requirements have been established, and the evaluations required to show that safety functions will be accomplished. The description shall be sufficient to permit understanding of the system designs and their relationship to safety evaluations.
Section 50.34(b)(2)(i) of 10 CFR, which requires such items as the instrumentation and control systems be discussed insofar as they are pertinent.
Section 50.34(b)(4) of 10 CFR, which requires a final analysis and evaluation of the design and performance of SSCs with the objective stated in 10 CFR 50.34(a)(4) and considering any pertinent information developed since the submittal of the preliminary safety analysis report (SAR).
Section 50.36, Technical specifications, paragraph (a)(1) of 10 CFR, which requires that each applicant for a license authorizing operation of a production or utilization facility include in this application proposed TSs and a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs.
Section 50.36(b) of 10 CFR, which requires that the TSs be derived from the analyses and evaluation included in the SAR.
Section 50.36(c) of 10 CFR, which requires the TSs to include:
Safety limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity (50.36(c)(1)(i)(A));
Limiting safety system settings for automatic protective devices related to those variables having significant safety functions (50.36(c)(1)(ii)(A));
Limiting conditions for operation, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility (50.36(c)(2));
Surveillance requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met (50.36(c)(3)).
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 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, paragraph (c) of 10 CFR, which identifies licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review.
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.
American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors, which provides guidance that identifies and establishes the content of TSs for research and test reactors.
4.0 TECHNICAL EVALUATION
4.1 Removal of the Channel 2 Low Power Scram The LAR proposes to remove the Channel 2 low power scram. The request is based on the need to replace obsolete and commercially unavailable neutron detectors. Removal of the Channel 2 low power scram will also necessitate corresponding changes to the ISU TSs, which are evaluated in section 4.2 of this safety evaluation. Channel 1 low power will still scram if power is too low during startup (less than 0.5 counts/second) and Nuclear Safety Channel No. 3 (Channel 3) Low Power will scram on low counts at an indication of less than five percent of each selectable range of indication (5 percent of full scale).
The licensee states that the LAR is required to accommodate future installation of Boron-10 (B10) lined uncompensated nuclear instrumentation ion chamber detectors. The licensee also states that the original Boron trifluoride (BF3) detectors have surpassed their expected lifetimes and regularly malfunction. The licensee states that BF3 detectors are no longer commercially available requiring the substitution of B10 detectors. The licensee also states that the new B10 detectors are intended to be installed in Channels 2 and 3. The licensee states that the replacement detectors will not output electric current that is distinguishable from background noise at low reactor power levels. Thus, the detector current output and minimum response from the B10 detector will be below the low count rate scram of Channel 2, which would prevent normal operation of the reactor unless the Channel 2 low power scram at source levels less than 3 x 10 13 amperes is removed. The ISU SAR (ML24283A156), states that Channel 1 Low Power is the primary channel for providing low level protection to ensure the reactor cannot be started up without a neutron source response being above 0.5 counts/second; the licensee did not request to amend license requirements associated with Channel 1. The ISU SAR indicates that safety margins during normal operations and transient conditions remain unchanged, and the likelihood of accidents leading to the release of significant radioactive fission products remains extremely low with this LAR.
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. This included review of the licensees evaluation of the design and performance of nuclear instrumentation scrams to ensure there is reasonable assurance that public health and safety will be adequately protected under the proposed change.
The NRC staff reviewed the proposed changes using the guidance in NUREG-1537. Section 7, Instrumentation and Control Systems of NUREG-1537 provides guidance on licensing actions reviews for components and subsystems that compose the Instrumentation and control systems of research and test reactors. The NRC staff finds that the removal of the Channel 2 Low Power safety channel does not reduce operable protection capability in all operating modes and conditions, as analyzed in the SAR, since Channels 1 and 3 will continue to provide a low count rate protection function. The NRC Staff finds the proposed change acceptable.
The licensee indicates that the LAR does not alter the ISU AGN-201M research reactor safety limits or limited safety system settings for automatic protective actions initiated to prevent a safety limit from being exceeded. Similarly, the licensee did not propose any changes to the surveillance requirements to perform a channel test of Channel 1, 2, and 3 or to the annual requirement to calibrate the period, count rate, and power level measuring channels. The licensee also states that the change in channel readings with and without the safety rods inserted validates that the detection channels are functioning properly.
There are no identified changes under this LAR that affect the reliable indication or control of reactor power level or the protection for rate of change of power levels. The existing nuclear instruments will continue to give sufficient overlap and continuous indication of the neutron flux from subcritical through the licensed maximum power range. Additionally, the ISU start up procedure requires a Rod Drop Test, in which Safety Rods 1 and 2 are inserted and the readings of all three detection channels are recorded.
The NRC staff finds that the proposed change to remove the Channel 2 Low Power setpoint does not impact the Channel 1 (startup channel) functionality to prevent reactor startup with insufficient neutron levels (i.e., levels too low) to verify the channel is operable and responding).
Therefore, the NRC staff concludes that sufficient interlocks, redundancy, and diversity of the required subsystems exists to avoid a total loss of operating information or control. The remaining TS continue to provide the lowest functional capability or performance level for the subsystems necessary for safe operation of the facility. Accordingly, the NRC staff find the removal of the Channel 2 Low Power scram at source levels less than 3 x 10-13 amperes is acceptable.
4.2 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.
4.2.1 TS 3.2, Table 3.1, Reactor Control and Safety Systems Set-Point Specifications The change proposed by the licensee deletes the entire third row from TS 3.2, table 3.1. This removes reference to the Channel 2 having a low current setpoint and scram function within the ISU safety system.
Nuclear Safety Channel No. 2 (Log Power Channel)
Low Power 3.0 x 10-13 amperes Scram at source levels
< 3.0 x 10-13 amperes The removal of the Channel 2 low power scram was reviewed and found acceptable by the NRC staff (discussed in section 4.1 of this safety evaluation). This conforming TS change is acceptable because the remaining TS will continue to require the lowest functional capability or performance levels of equipment required for safe operation of the facility.
In addition to the change to TS 3.2, table 3.1 to remove the Channel 2 low power scram, the licensee proposes to modify the table to remove the nomenclature reference for the option to operate using one of two control consoles. The licensee states that Unit A display console was removed under 10 CFR 50.59 without the need for prior NRC approval.
SAFETY CHANNEL SET POINT FUNCTION Nuclear Safety Channel No. 1 (Startup Count Rate Channel)
Low Power Unit A) 5% Full Scale OR Unit B) 0.5 counts/second Scram at levels below the set points Unit A is the original AGN console Unit B is the ISU all solid state electronic control console Either Unit A or Unit B will be in service any time the reactor is operating The Unit A and Unit B designations were added as part of License Amendment No. 7 to the ISU TSs. At the time, the licensee constructed a new control console to replace obsolete technology in its original console. However, the licensee requested to retain the flexibility to operate the reactor with either console. This necessitated the Unit A and Unit B designation to distinguish between the original console with Channel 1 ranged indicator and the new control console with a wide range Channel 1 indicator that did not require switching. License Amendment No. 7 on August 14, 2006, allowed the licensee to operate the reactor with the original [Unit A] or the new control console [Unit B].
The licensee has requested that reference to Unit A and its setpoint be removed. Additionally, the licensee requests that the Unit B designation be removed, retaining just the corresponding 0.5 counts/second setpoint. The licensee indicates it permanently implemented the previously designated Unit B control console and no longer require the option for operation using the Unit A control console.
The LAR reflects removing a set-point from the TSs for the limiting condition for operation (LCO), listed in TS 3.2, table 3.1 for a control console the licensee states is now obsolete.
Specifically, the request deletes a set-point to the Channel 1 low power scram, for Unit A, which also removes the option of using Unit A for the ISU AGN-201M research reactor operation.
The NRC staff finds that the purpose and functionality remain to prevent control rod withdrawal if the indicated neutron flux signal is less than 0.5 counts/second. The retained set point for the ISU all solid-state electronic control console was previously evaluated to be functionally equivalent to the corresponding set-point of 5% of Full Scale for the original AGN-201M console under License Amendment No. 7.
Based on the above discussion and the approval of License Amendment No. 7, the NRC staff finds that the proposed TS LCO for Channel 1 meets the requirements of 10 CFR 50.36(c)(2)(ii)(C) to include the LCO for a SSC that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Accordingly, the revised TSs will continue to ensure that a startup cannot be attempted without instrumentation that is responsive and indicating neutron signal levels high enough to allow reliable observation of the rate and level of reactor power. Therefore, the TS changes are appropriate and acceptable.
The NRC staff notes that the area radiation monitor setpoint in the proposed TS 3.2, Table 3.1, submitted (ML24283A157), does not match the area radiation monitor setpoint in the NRC approved TS 3.2, Table 3.1 for License Amendment No. 7. The licensee clarifies, in email dated September 16, 2024 (ML24283A167), that there are no changes for the area radiation monitor setpoint. The license confirms that the setpoint is 10 mR/hr instead of = 10 mR/hr.
Accordingly, no change was made to the area radiation monitor setpoint.
4.2.2 TS 3.2, Control and Safety Systems 4.2.2.1 Proposed revision to TS 3.2, specification b Proposed TS 3.2, specification b is changed as follows:
The average reactivity addition rate for each control or safety rod shall not exceed 0.065% k/k per second ($0.00877 per second).
The licensee states in its application that the reason for this request is because the reactivity insertion rate limit for the safety and course control rods is $0.0877 per second but the value is incorrectly cited in the parenthetical of TS 3.2, specification b as $0.00877 per second. The licensee provides the calculation to support the correction based on the TS 3.2, specification b limit on reactivity addition rate for all control rods as 0.065% k/k per second.
Mathematically, reactivity is a dimensionless number, but various units can express it. The most common units for research reactors are %K/K or dollars. The conversion between units of reactivity, (k/k) to dollars ($), is based on the effective delayed neutron fraction, which is commonly referred to as Beta effective (eff). eff is a quantity related to the production of a small fraction of neutrons during radioactive decay of certain fission products (delayed neutron precursors). eff is the ratio of delayed neutrons to total core neutrons that have reached thermal energy and is a function of the type of fuel and core design. In its application, as supplemented, eff is given by the licensee as 0.0074 for the AGN-201M research reactor, which is consistent with the value provided in the ISU AGN-201M research reactor SAR.
=
0.065% /
=
0.065% /
0.0074
= $0.08778 In accordance with 10 CFR 50.92, in determining whether the proposed change will be issued, the NRC staff was guided by the considerations in 10 CFR 50.36(b). The NRC staff finds that proposed change to TS 3.2, specification b correctly reflects the calculation derived from the analyses and evaluation included in the ISU AGN-201M research reactor SAR. Additionally, the typographical correction does not change the original intent of the TS. Therefore, the NRC staff concludes that the proposed change to TS 3.2, specification b is acceptable.
4.2.2.2 Proposed revision to TS 3.2, Specification d The licensee proposes a change to TS 3.2, specification d that removes the exception allowing Channel 1 to be bypassed. Additionally, the licensee included corresponding changes to the TS 3.2, Basis, to indicate that only Channel 1 will respond to minimum neutron levels with new detectors in Channels 2 and 3.
Proposed TS 3.2, specification d is changed as follows:
- d. All reactor safety system instrumentation shall be operable in accordance with Table 3.1 with the exception that, with the approval of the Reactor Supervisor, Safety Channel No. 1 may be bypassed whenever the reactor control or safety rods are not in their fully withdrawn position.
The licensee states that the current wording of TS 3.2, specification d allows for Channel 1 to be disabled when the reactor is in a critical or supercritical configuration. As written, TS 3.2, specification d maintains its original intent only when the Channel 2 low scram exists. The licensee has proposed elimination of the exception because if the low scram for Channel 2 is removed as proposed and TS 3.2, specification d remains unchanged, there exists a potentially unsafe operating condition in which an operator can configure a critical or supercritical reactor without a startup source. The licensee further states that the original intent of the exception was to disable Channel 1 and its associated high scram as reactor power increased towards the limit of the Channel 1 Sensitrol relay and that TS 3.2, specification d was never intended to bypass Channel 1 during startup and eliminate the need for a startup source.
The licensee also proposes removal of the TS 3.2, specification d language because the scenario is not physically possible on the new console. Channel 1 no longer has a Sensitrol relay, which was part of the original Unit A control console, therefore, there is no longer a need to bypass Channel 1. The licensee states that removing the exception statement from TS 3.2, specification d will not impact normal reactor operation and will ensure safety during startup.
Based on the above, the NRC staff finds that the requested change to TS 3.2, specification d reflects removing an operational exception for a control console the licensee states is now obsolete. The current exception in TS 3.2, specification d was intended to permit bypassing an instrument channel that no longer exists. In addition, the exception could mislead operators regarding actual operation of the TS required instrumentation channels and lead to a potential impact on (or understanding of) safe operations. The NRC staff also finds that removing the exception statement from TS 3.2, specification d will not impact normal reactor operation and will help ensure safety during startup. Further, the proposed TS 3.2, specification d meets the intent of the guidance in ANSI/ANS-15.1-2007, to administratively established constraints on equipment and operational characteristics that shall be adhered to during operation of the facility. Additionally, the proposed LCO continues to provide the lowest functional capability or performance level required for safe operation of the ISU AGN-201M research reactor.
Therefore, the NRC staff concludes that the proposed change to TS 3.2, specification d is acceptable.
The licensee included bases with its application and showed the changes. TS 3.2, Basis (2nd sentence of 2nd paragraph) is changed as follows:
The neutron detector channels (Nuclear Safety Channels Nos. 1 through 3) assure that reactor power levels are adequately monitored during reactor startup and operation.
Requirements on minimum neutron levels will prevent reactor startup unless Channel 1 is channels are operable and responding, and will cause a scram in the event of instrumentation failure.
The proposed change to the basis indicates the corresponding changes to the protective setpoints and functionality described by the licensee.
4.3 Conclusion for Technical Evaluation The NRC staff reviewed the proposed changes using the regulations in 10 CFR Part 50 and the guidance in NUREG-1537 and ANSI/ANS-15.1-2007. The licensee provided sufficient description, analysis, and technical justification of the instrumentation and control system changes as they are relevant to the performance requirements, TSs, and the bases that are sufficient to permit understanding of the system design and its relationship to safety as described in the ISU AGN-201M research reactor SAR to show that required safety functions will be accomplished.
The NRC staff also finds that the proposed changes to the TSs, as reviewed above, are consistent with the requirements of 10 CFR 50.36(c) to provide LCO representing the lowest functional capability or performance levels of equipment required for safe operation. Based on the information described above, the NRC staff concludes that the proposed changes to the ISU AGN-201M research reactor TS 3.2 are acceptable.
5.0 ENVIRONMENTAL CONSIDERATION
The majority of changes in this amendment fit into the category of changes in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that this amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released off site, and no significant increase in individual or cumulative occupational radiation exposure.
Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Additionally, the other changes in this amendment makes editorial, corrective or other minor revisions to the license that 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 this amendment.
6.0 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 Contributors: D. Hardesty, NRR A. Miller, NRR Date: October 10, 2024