ML25226A072
| ML25226A072 | |
| Person / Time | |
|---|---|
| Site: | Rensselaer Polytechnic Institute |
| Issue date: | 08/15/2025 |
| From: | Lovett J NRC/NRR/DANU/UNPL |
| To: | Ji W Rensselaer Polytechnic Institute |
| Jessica Lovett | |
| References | |
| EPID L-2025-NFA-0005 | |
| Download: ML25226A072 (1) | |
Text
Dr. Wei Ji, Director Reactor Critical Facility Rensselaer Polytechnic Institute 110 8th Street JEC 5040 Troy, NY 12180 3590
SUBJECT:
RENSSELAER POLYTECHNIC INSTITUTE - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE:
REVISIONS TO TECHNICAL SPECIFICATIONS TO ADD EXTENDED SHUTDOWN CONDITION (EPID L-2025-NFA-0005)
Dear Dr. Ji:
By letter dated June 26, 2025 (Agencywide Documents Access and Management System Accession No. ML25188A197), the Rensselaer Polytechnic Institute (RPI) submitted a license amendment for the Critical Experiments Facility. The proposed amendment request would add a new section to the facility technical specifications (TS), section 6.10 Special Administrative Controls for Extended Shutdown, to account for limited staffing during extended shutdowns.
The proposed amendment requests also updates TS sections 1.3 Definitions, 4.7 Radiation Monitoring, and 6.1 Organizational Structure to incorporate the creation of section 6.10. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the facility.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an application for an amendment to a license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.
In order make the application complete, the NRC staff requests that RPI supplement the application to address the information requested in the enclosure by September 17, 2025. This August 15, 2025
W. Ji will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staffs detailed technical review by separate correspondence.
The information requested and associated time frame in this letter were discussed with you on August 7, 2025.
If you have any questions, please contact the me at (301) 415-4002, or by email at Jessica.Lovett@nrc.gov.
Sincerely, Jessica Lovett, 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. 50-225 License No. CX-22
Enclosure:
As stated cc: GovDelivery Subscribers Signed by Lovett, Jessica on 08/15/25
ML25226A072 NRR-106 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA NRR/ DANU/UNPL/BC NRR/ DANU/UNPL/PM NAME JLovett NParker JRady JLovett DATE 8/14/2025 8/14/2025 8/15/2025 8/15/2025 Enclosure OFFICE OF NUCLEAR REACTOR REGULATION SUPPLEMENTAL INFORMATION NEEDED FOR REVIEW OF LICENSE AMENDMENT REQUEST RENSSELAER POLYTECHNIC INSTITUTE CRITICAL EXPERIMENTS FACILITY LICENSE NO. CX-22; DOCKET NO. 50-225 The U.S. Nuclear Regulatory Commission (NRC) staff requests the following:
1.
Request the definition of task-training and task-trained individual (Section 6.10). How would task-training and qualification be documented?
2.
Request the definition of licensed fuel handlers (Section 6.10) be added to the definition section of the technical specifications (TSs). Who would license the fuel handlers? What are the requirements for licensing a fuel handler? What kind of license would these fuel handlers receive?
3.
Request explicit changes to administrative controls under Section 6.10.
a.
As written, it is not clear if the Nuclear Safety Review Board (NSRB) intends to allow additional relaxations or changes to TS Sections 6.1 - 6.9 in the written transition plan or once operating under the special administrative controls. The NRC staff notes that Section 50.59 of Title 10 of the Code of Federal Regulations (10 CFR) identifies changes to the TSs will require a license amendment.
Modifications to TS sections 6.1-6.9 not specifically stated in this amendment would not be authorized. Clearly identify what reactor state or actions in which Section 6.10 controls are not authorized.
b.
It is unclear to the NRC staff how the proposed additions to section 6 of the TSs change how the facility currently conducts administrative controls. 10 CFR part 50, section 36, Technical Specifications, item (5), Administrative controls, states that [a]dminstrative controls are the provisions relating to organization Enclosure and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. For research reactors, guidance for the administrative controls section of the TS is in NUREG 1537, appendix 14.1, Format and Content for Technical Specifications for Non-Power Reactors, section 6, Administrative Controls. The guidance endorses ANSI/ANS 15.1-2007 (R2023), section 6.1.1, Structure, for the organizational structure. In section 6.1.1 in ANSI/ANS 15.1-2007 (R2023) states that [t]he organization for the management and operation of the reactor facility shall include the structure indicated in Fig. 1, which shows levels 1, 2, 3, and 4 which are equivalent to the current facility structure in TS 6.1, Organization. The request does not explain why the elimination of level 3 and 4 staff (SRO and RO) from the administrative structure would assure operation of the facility in a safe manner.
4.
Request the definitions of reactor fueled and reactor defueled (Section 4.7) be added to the definition section of the TSs.
5.
Request if changes to TS Section 4.7 are intended to align section 4.7 with NUREG 1537 Part 1, App 14.1, Section 4 and ANSI/ANS 15.1-2007 (R2023), which allows for surveillances to be deferred while the reactor is shut down but requires performance before next reactor startup. It is not clear to the NRC staff when the surveillances in TS 4.7 are required to be met during fuel movements.
6.
Request the definition of fuel movement and fuel transfer. TS Section 3.9 states All fuel transfers shall be conducted under the direction of a SRO and Section 6.10 states movement of the fuel within the facility shall only be performed by licensed fuel handlers. It is unclear as to what defines and bounds a fuel movement vs fuel transfer and what the staffing requirements would be for the movement under special administrative controls.