ML102150544

Texas A&M University, Response to NRC Requests for Additional Information Questions 9 and 11, Chapter 14 - Technical Specifications

ML102150544
Person / Time
Site:	05000128
Issue date:	07/28/2010
From:	Reece W Texas A&M Univ
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2010-0042
Download: ML102150544 (6)

Text

TEXAS ENGINEERING EXPERIMENT STATION TEXAS A&M UNIVERSITY 3575 TAMU COLLEGE STATION, TEXAS 77843-3575 July 28, 2010 NUCLEAR SCIENCE CENTER 979/845-7551 FAX 979/862-2667 Document Control Desk U.S. Nuclear Regulatory Commission 2010-0042 Washington, DC 20555-0001

Subject:

Response to NRC Requests for Additional Information Questions 9 and 11, Chapter 14- Technical Specifications, from the Texas A&M University System, Texas Engineering Experiment Station, Nuclear Science Center Reactor (NSCR, License No. R-83, Docket 50-128)

To Whom It May Concern:

The Texas A&M University System, Texas Engineering Experiment Station (TEES), Nuclear Science Center (NSC, License No. R-83) operates a LEU, 1MW, TRIGA reactor under timely renewal. In December, 2003 the NSC submitted a Safety Analysis Report (SAR) as part of the license renewal process. In December, 2005 a conversion SAR (Chapter 18) was submitted resulting in an order to convert from the NRC. In July 2009, the NSC submitted an updated SAR, dated June 2009, to the Nuclear Regulatory Commission (NRC). This updated 2009 version of our SAR incorporated the information from the conversion SAR and the startup of the new LEU reactor core. On June 24, 2010 the NRC submitted a Request for Additional Information as a part of the review process. This request included thirty-seven questions related to the NSC's SAR submittal. Attached to this letter are the NSC's response to Questions 9, and 11 of the NRC's non-financial RAIs. Please note in the attachment that text from the NRC's June 24th letter has been italicized and the NSC's non-italicized response immediately follows each question.

If you have any questions, please contact Jim Remlinger or me at 979-845-7551.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 28, 2010.

W. D. Reece NSC, Director Xc: 2.11/Central File Chris Cowdrey, NRC Project Manager RESEARCH AND DEVELOPMENT FOR MANKIND http://nsc.tamu.edu

Texas A&M University System Texas Engineering Experiment Station Nuclear Science Center License No. R-83 Docket No. 50-128 Responses to Request for Additional Information Chapter 14 - Technical Specifications

9. NUREG-1537 states that the format and content of the TSfollow that ofANSI/ANS 15.1.

ANSI/ANS-15.1-2007, Section 6. 7.2 discusses special reportingrequirementsfor operationaloccurrences. TAMU TS 14.1.31(3) lists a reportableoccurrence as "A reactorsafety system component malfunction that renders or could render the reactorsafety system incapableofperforming its intendedsafety function unless the malfunction or condition is discovered during maintenance tests or periods of reactorshutdowns. "ANSI/ANS-15. 1, Section 6. 7.2 does not include the stipulationfor conditions discovered duringmaintenance. Pleaseconsider removing the stipulationor provide a basisfor including this stipulation.

NSC Response: The Nuclear'Science Center will modify the TS 14.1.31(3) [now TS 14.1.39(3)] to remove the stipulation and conform to the American National Standards Institute (ANSI), American Nuclear Society (ANS) 15.1. ANSI/ANS- 15.1-2007, Section 6.7.2.

14.1.39 Reportable Occurrence

3. A reactor safety system component malfunction that renders or could render the reactor safety system incapable of performing its intended safety function. If the malfunction or condition is caused by maintenance, then no report is required. (Note: Where components or systems are provided in addition to those required by the technical specifications, the failure of the extra components or systems is not considered reportable provided that the minimum numbers of components or systems specified or required perform their intended reactor safety function.)

Texas A&M University System Texas Engineering Experiment Station Nuclear Science Center License No. R-83 Docket No. 50-128 Responses to Request for Additional Information Chapter 14 - Technical Specifications

11. NUREG-1537 states that the format and content of the TSfollow that ofANSI/ANS 15.1.

ANSI/ANS-15.1-2007, Section 3.2(1) includes guidance on establishingLCOs for minimum number of operable control rods (defined in terms of scram time). Please discuss whether TAMU TS 14.3.2 is consistent with the standardguidance.

NSC Response: TAMU TS 14.3.2 does not define an LCO for minimum number of operable control rods. We will modify the TS 14.3.2.3 Scram Time to include this LCO.

14.3.2.3 Minimum Number of Operable Scrammable Control Rods Applicability This specification applies to the minimum number of operable scrammable control rods in the core, where operable is specified in terms of maximum scram time from the instant that the fuel temperature safety channel variable reaches the Limiting Safety System Setting.

Obiective The objective is to achieve prompt shutdown of the reactor to prevent fuel damage.

Specification During standard operation all scrammable control rods shall be operable. The scram time measured from the instant a simulated signal reaches the value of the LSSS to the instant that the slowest scrammable rod reaches its fully inserted position shall not exceed 1.2 seconds. During core manipulations, i.e. core loading and unloading, all installed scrammable control rods shall be operable.

Basis This specification ensures that the reactor will be promptly shutdown when a scram signal is initiated.

Experience and analysis have indicated that for the range of transients anticipated for a TRIGA reactor, the specified scram time is adequate to assure the safety of the reactor.

TEXAS ENGINEERING EXPERIMENT STATION TEXAS A&M UNIVERSITY 3575 TAMU COLLEGE STATION, TEXAS 77843-3575 NUCLEAR SCIENCE CENTER 979/845-7551 FAX 979/862-2667 July 27, 2010 2010-0041 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Response to NRC Requests for Additional Information Questions 12 and 17, Chapter 14- Technical Specifications, from the Texas A&M University System, Texas Engineering Experiment Station, Nuclear Science Center Reactor (NSCR, License No. R-83, Docket 50-128)

To Whom It May Concern:

The Texas A&M University System, Texas Engineering Experiment Station (TEES), Nuclear Science Center (NSC, License No. R-83) operates a LEU, IMW, TRIGA reactor under timely renewal. In December, 2003 the NSC submitted a Safety Analysis Report (SAR) as part of the license renewal process. In December, 2005 a conversion SAR (Chapter 18) was submitted resulting in an order to convert from the NRC. In July 2009, the NSC submitted an updated SAR, dated June 2009, to the Nuclear Regulatory Commission (NRC). This updated 2009 version of our SAR incorporated the information from the conversion SAR and the startup of the new LEU reactor core. On June 24, 2010 the NRC submitted a Request for Additional Information as a part of the review process. This request included thirty-seven questions related to the NSC's SAR submittal. Attached to this letter are the NSC's response to Questions 12, and 17 of the NRC's non-financial RAIs. Please note in the attachment that text from the NRC's June 24th letter has been italicized and the NSC's non-italicized response immediately follows each question.

If you have any questions, please contact Jim Remlinger or me at 979-845-7551.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 27, 2010.

W. D. Reece NSC, Director Xc: 21 I/Central File Chris Cowdrey, NRC Project Manager RESEARCH AND DEVELOPMENT FOR MANKIND http://nsc.tamu.edu

Texas A&M University System Texas Engineering Experiment Station Nuclear Science Center License No. R-83 Docket No. 50-128 Responses to Request for Additional Information Chapter 14 - Technical Specifications

12. TAMU TS 14.3.2, Table 14-2, establishesthe function for the Fuel Element Temperatureand High Power Level safety channels as "Scram at LSSS'" and "Scram at 125%" respectively. Pleaseconsider changingto statements where the safety channels are requiredto scram "priorto exceeding" ratherthan "at" the designatedlimit.

The NSC proposes to change the technical specification wording to show that the Fuel Element Temperature and High Power Level'safety channels will "Scram < the LSSS" and "Scram < 125%".

Texas A&M University System Texas Engineering Experiment Station Nuclear Science Center License No. R-83 Docket No. 50-128 Responses to Request for Additional Information Chapter 14 - Technical Specifications

17. NUREG-1537 states that the format and content of the TSfollow that ofANSI/ANS 15.1.

ANSI/ANS-15.1-2007, Section 3.7.1 provides a time limitfor alternate methods of radiationmonitoring with a channel out of service. Please review the notes associatedwith TAMU TSs 14.3.5.1 and 14.3.5.3, and consider adding time limits consistent with the standardguidance orprovide a basisfor not including time limits.

The NSC proposes to make changes to applicable technical specification(s) to include the following:

Note: When required monitors are inoperable, or for periods of maintenance, the intent of this specification will be satisfied if this monitor is replaced for a period of no more than 1 week with a portable gamma sensitive instrument having its own alarm which shall be kept under visual observation. If two of the above monitors are not operating, the reactor will be shutdown.