ML20138C592

Forwards Response to 970320 RAI Re License Amend to Withdraw Authorization to Operate General Atomic Triga Mark I non-power Reactor.Revised Tss,Also Encl

ML20138C592
Person / Time
Site:	General Atomics
Issue date:	04/25/1997
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Alexander Adams NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20138C595	List: ML20138C592 ML20138C614
References
38-2726, TAC-M97502, NUDOCS 9704300147
Download: ML20138C592 (19)

Text

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4 h CENERAL ATORNCE l 1

April 25,1997 38-2726 Document Control Desk ATTN: Alexander Adams, Jr., Senior Project Manager Non-Power Reactors, Decommissioning and Environmental Project Directorate Division of Advanced Reactors & Special Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ,

Washington, D.C. 20555

Subject:

Facility License R-38; Docket 50-89: Responses to NRC Request for Additional Information / Request for License Amendment to Withdraw Authorization to Operate General Atomics' TRIGA Mark l Non-power Reactor - TAC No. M97502

References:

1) Asmussen, Keith E. letter to Dr. Seymour H. Weiss, " Facility License R-38; Docket 50-89: Request for License Amendment to Withdraw ,

Authorization to Operate General Atomics' TRIGA Mark l Non-power Reactor," dated December 17,1996.

2) Adams, Alexander, Jr. letter to Dr. Keith E. Asmussen," REQUEST FOR ADDITIONAL INFORMATION (TAC NO. M97502)

Dear Mr. Weiss:

In reference 1, General Atomics (GA) requested that its License Number R-38 be amended so as to withdraw U.S. Nuclear Regulatory Commission (NRC) authorization to operate the subject reactor. You responded for the NRC with a request for additional information (Ref. 2). Accordingly, in response to your request for additional information and in further support of our request in reference 1, GA hereby submits the following enclosures:

Attachment 1: General Atomics' Responses to NRC's Request Dated March 20,1997 for Additional Information Re; General Atomics TRIGA Mark l Research Reactor (Docket No. 50- l

89) l Attachment 2: Information submitted in support of General Atomics' request j for a possession only license amendment for its non-power reactor license no. R-38 (Revised to reflect NRC commenis_in Ref. 2)

Attachment 3: Copy of entire revised technical specifications: " TECHNICAL SPECIFICATIONS / TRIGA MARK I REACTOR" 200130 gg 9704300147 970425 PDR ADOCK 050000891 7 lllhllll P PDR i 3%0 GENERAL A70%CS COURT. SAN DIEGQ CA 921211194 PO BOX 86606. SAN D! EGO, CA 92186 9784 (8191455 3000

3 Mr. Alexander Adams, Jr., U.S. NRC April 25,1997 38-2726 Page 2 GA requests that the R-38 License and associated Technical Specifications be amended as described in the enclosed attachment to this letter. The attachment also includes a description of measures that will be taken to ensure the continued safety of the facility.

GA appreciates your assistance in considering this request and is hopeful of an expeditious approval. If you have any questions or require additionalinformation, please do not hesitate to contact me at (619) 455-2823, or Dr. Junaid Razvi at (619) 457-8850.

Very truly yours, Y $.

Dr. Keith E. Asmussen, Director Licensing, Safety and Nuclear Compliance Attachments: as stated in text above cc: Regional Administrator, U. S. Nuclear Regulatory Commission, Region IV l

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i Attachment No.1 GA Letter No. 38-2726 April 25,1997 - Page 1

- General Atomics' Responses to NRC's Request Dated March 20,1997 for l Additional Information Re: General Atomics TRIGA Mark I Research Reactor (Docket No. 50-89)

NRC ltem 1:

Proposed License Condition 2. Are you proposing any changes to the  ;

introductoryphrase of License Condition 2? In yourproposed License Condition '

2, you refer to Facility License No. R-67. You have also added the words "as amended." Are these typographical errors? Please correct orjustify your proposed wording.

GA Resoonse to item 1:

GA is not proposing any changes to the introductory phrase of license condition

2. The proposed wording in GA's December 17,1996 request is being l withdrawn. I NRC ltem2; i Proposed License Condition 2.B. You refer to "10 CFR Chapter 1"in your  ;

proposed license conditions. The correct reference is "10 CFR Chapter I." l Please correct these license conditions.

GA Response to item 2:

GA has corrected reference. 1 NRC ltem 3: l Proposed License Conditions 2.B.(2) and (3). Yourproposed changes to l License Condition 2.B(3) refer to special nuclear material. This license condition is for byproduct material only. Any reference to special nuclear material should be in License Condition 2.B.(2). Please correct these license conditions. ,

GA Resoonse to item 3: I GA has corrected the subject license conditions. i NRC ltem 4:

Proposed License Condition 2.C.(2). The first sentence of this license condition is standard for non-power reactor licenses and would read for your proposed license amendment:

The Technical Specifications contained in Appendix A, as revised

. through Amendment No. 34, are hereby incorporated in the license.

Please correct orjustify your proposed changes to this sentence.

. - . . ~ -- - - -- .- - - ,. , . - .

Attachment No.1

GA Letter No. 38-2726 1

. AprH 25,1997 Page 2

. GA Resoonse to item 4. .

GA has corrected the subject sentence.  ;

, ' NRC 'I tem 5:

Proposed License Condition 2.C.(3). Please state the title of the Physical ,

, Security Plan and the date of the plan. Also, state the provisions of the ,

i regulations under which the contents of the plan are protected.  ;

GA Resoonse to item 5:  :

GA is withdrawing this proposed change; which is not needed.

' B R C Ite m 6: .,

Proposed new License Conditions 2.C.(2)(a)-(d). Changes to the regulations that became effective on August 28,1996, (see Federal Register of July 29, l 1966, page 39278) extended the use of to CFR 50.59 to non-power reactor (see l new 10 CFR 50.59(e). Given this change to the regulations, do you still want to l

. make these proposed changes to your license? l GA Resoonse to item 6: .

i No, GA does not want to make the subject proposed changes. The request for '

the proposed new License Conditions 2.C.(2)(a)-(d) is being withdrawn.

' NRC Item 7:

Please provide NRC with updated technical specification (TS) pages that reflect

yourproposed changes.

. GA Resoonse to item 7:

' Updated technical specifications (TS) which refect GA's requested changes are being provided.

l NRC ltem 8:

Proposed TS 1.2. ~ You have proposed deleting TS 1.2.b. and have proposed

, changes to TS 1.2.c. Please provide Justification for these proposed chan.o;ss.

GA Resoonse to item 8:

y TS.1.2 b in the existing Technical Specifications is to be deleted in its entirety.

This TS applies only if the reactor is to be operated, and will not apply when the license is amended to withdraw authorization to operate, i.e., a possession only ,

license amendment. Similarly, TS 1.2 e is to be changed to remove portions  !

which would only be applicable if the reactor was in operation. i NRC ltem 9:

TS 1.10. Yourproposed changes to TS 1.3 will result in the reactor not being in operation again.' In light of yourproposed changes to TS 1.3, please review TS 1.10 to determine what events still need to be considered reportable occurrences during possession-only status.

GA~ Resoonse to item 9: . .

TS 1.10 will be modified by revising the introductory sentence to reflect the l status of the reactor license being amended to authorize possession only, and items / paragraphs a, b, c and d will be deleted.' The deleted items / paragraphs i

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l Attachment No.1 GA Letter No. 38-2726 April 25,1997 - Page 3 are only applicable when conducting reactor operations, and do not apply to a reactor with a possession only license amendment. Similarly, item / paragraph 1.10 e will be revised to delete reference to " operation" of the reactor.

Also, note that the historical title to TS 1.10 was Abnormal Occurrances, rather than Repo table Occurrances. It is not known how, when or why the change ,

occurred to cause it to read " Reportable." Therefore, this TS is being revised by changing the word " Reportable" back to the original " Abnormal."

NRC ltem 10:

Proposed TS 5.2.3. You have proposed changes to TS 5.2.3. Please provide justification for your proposed changes.

GA Resoonse to item 10:

The proposed changes remove references to operation of the reactor, which are not applicable in the context of a possession only license amendment. Actually, the proposed revisions to the TS result in it being more restrictive than currently, because it will require that the area radiation monitoring system be operable at all times. The current TS only requires that such systems be operable when the  !

reactor is in operation, or when work is being dine around the reactor core.

NRC ltem 11:

Proposed TS 9.1. Please providejustification for removing the requirement for j the Physicist-in-Charge or designate to be a licensed senior reactor operator. l Please discuss your plans to keep licensed operators qualified and train new operators when needed.

GA Response to item 11:  ;

it is GA's intention, as stated herein, to transfer all fuel from the Mark I reactor J core to storage racks in the Mark I pool, or the adjacent Mark F pool (R-67).

With that being the case, it is GA's position that the requirement to have senior '

reactor operators (SRO) or reactor operators (RO) for the facility, licensed in accordance with the requirements of 10CFR55, does not apply. l 1

Certain future operations, subsequent to the transfer of all of the fuel from the reactor core to storage, will require handling of the fuel elements. This is normally carried out at GA only by licensed SROs or ROs. More specifically, it is not anticipated that the fuel, once removed from the reactor core and placed in storage racks, willl require any handling until such time that all fuel is transferred to the Idaho Engineering Laboratory (or other DOE designated facility); at some future date. At that time, fuel handling will be required to transfer the fuel from the storage racks to the shipping cask, necessitating having trained fuel handlers.

Training of fuel handlers will be the responsiblity of the Physicist-in-Charge. As a minimum, fuel handlers will be trained in the operating principles of the fuel handling tools, and be given instructions in its proper use at least once a year. In addition, the fuel handlers will be adequately trained in the principals of criticality safety and radiation safety at a level comensurate with the content of their job. A

O Attachment No.1 GA Letter No. 38-2726 April 25,1997 - Page 4 list of qualified fuel handlers and the current status of their qualification will be mair;tained by the Physicist-in Charge, and shall be reviewed and approved by the Criticality and Radiation Safety Committee (CRSC).

NRC ltem 12:

Proposed TS 9.1. You have proposed changes to your organizational chart.

Please explain these changes. Your current TS show both solid and dotted lines. While not defined in the TS. solid lines normally show reporting lines while dotted lines show communication lines. Please discuss the relationships in your proposed organizationalchart.

GA Response to item 12:

The organization chart show in our application dated December 17,1997, has been revised to correctly show solid lines (which represent reporting relationships) and dotted lines (which denote communication lines). GA's corporate standing Criticality and Radiation Safety Committee (CRSC) will function in place of the Criticality Safegaurds Committee. The expertise of the members of the CRSC encompasses that of membership pf the previous Criticality Safegaurds Committee, assuring that there i.= no decrease in effectiveness.

NRC ltem 13:

Proposed TS 9.2. You have proposed additional changes to this TS beyond changing the name of the committee and deleting reference to reactor operation. 1 Please describe and providejustification for allyourproposed changes. l GA Resoonse to item 13: I Yes, GA proposes to change more than the name of the committee, as reflected in the proposed changes to TS 9.2. As mentioned above (in GA response to ,

item No.12), the proposed oversight committee is the General Atomics site wide '

oversight committee known as the Criticality and Radiation Safety Committee  !

(CRSC). This is a GA corporate standing committee, whose charter and l authority to function are provided through the GA corporate Company Policy <

Manual. The CRSC has oversight over alllaboratories and facilities at GA where l radioactive material, special nuclear material or radiation producing machines i are used or stored. Its membership includes specific expertise relevant to all I aspects of safe possession, storage and handling of TRIGA* fuel. The l proposed changes to TS 9.2 reflect the charter of the CRSC, and mirror the requirements for the present TRIGA Criticality Safeguards Committee which reviews TRIGA reactor operations, it should also be noted that with the withdrawal of authorization to operate GA's reactors (Licenses R-38 and R-67), the requirement of an oversight committee to oversee reactor operations is no longer applicable.

NRC ltem 14:

Proposed TS 9.3. Please describe andprovide justification for allyourproposed changes to this TS, For example, you have proposed eliminating the requiremont in TS 9.3.f. for written procedures for routine maintenance that could

f i

Attachment No.1 GA Letter No. 38-2726 April 25,1997 Page 5 have an effect on reactor safety. Please justify, GA Resoonse to item'14:

The proposed changes and deletions to TS 9.3 reflect the fact that GA does not intend to conduct reactor operations, but intends to only possess the reactor. TS j 9.3. b, e and f specifically require written instructions for reactor operation and j maintenance, and therefore are not required for possession only. Similarly, the 1 proposed changes to wordings in other paragraphs of TS 9.3 recognize the fact '

that the reactor will be in possession only status, and will not be operated.

BBC Item 15: ,

TS 9.6. Please update reference to the AEC with NRC. Please update the

- references to telegraph notification with facsimile to reflect changes in technology. Please update the reporting requirements for telephone reports to '

provide the reports to the NRC Operations Center and Region IV, and written reports to the Document Control Desk and Region IV.

GA Resoonse to item 15:

~

TS 9.6 has been updated to replace references to AEC with NRC, and to include ,

references to facsimilie notification where applicable.

NRC Item 16: -

Proposed TS 9.6.e. You have proposed deleting TS 9.6.e. However, some of the routine report topics appear to be still valid for a facility in possession-only status. Also, because the report provides information on past events, the first reports with the reactorin possession-only status would still need to provide oporating information.

GA Resoonse to item 16:

It'is requested that, with the exception of 9.6.e.5, all other items under TS 9.6e

. on reporting requirements be deleted. This is justified by the fact that TS 9.6.e.1  :

through 9.6.e.4 require reporting of information related to reactor operations and  :

l major facility maintenance operations and its effects on the safe operation of the reactor. These clearly are not applicable in possession only status. TS 9.6.e.6 ,

i through 9.6.e.8 require reporting of facility radiological data. Site wide radiological data is already reported to the NRC annually in GA's 10CFR20 site

! report, and it is our position that separate reporting of such data under a POL 1

license for a small research reactor facility which is not in operation is not i warranted. GA proposes to leave in 9.6.e.5 in the TS on 10CFR50.59 changes

, to the facility in possession only status, if any such changes have been implemented.

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Attachment N2. 2 GA Lett:r No. 38-2726 April 25,1997 - Page 1 This attachment contains the following information submitted in support of General Atomics' (GA's) request for a possession only license amendment for its non-power reactor License R-38 (this attachment has been revised from an earlier submission dated Dec.17,1996 in response to NRC comments dated March 20,1997) :

1) REQUESTED AMENDMENTSTO GENERAL ATOMICS'(GA'S) NON-POWER REACTOR LICENSE R-38; h) REQUESTED AMENDMENTS TO THE TECHNICAL SPECIFICATIONS ASSOCIATED WITH LICENSE R-38; AND lil) A DESCRIPTION OF ADDITIONAL MEASURES THAT WILL BE TAXEN TO ENSURE SAFETY.

1) REQUESTED AMENDMENTS TO LICENSE R-38 in support of CA's request to have NRC withdraw authorization to operate GA's TRIGA Mark I research reactor, GA hereby requests: 1) that License Condition 2.C. (1) " Maximum Power Level," be deleted in its entirety,2) that License Condition 2.C. (4) " Fuel Storage" be added, and 3) that Commission findings 1.C. through 1.E. and License Conditions 2.B (1),2.B (2),2.B (3) and 2.C (2) of License No. R-38 (Docket No.50-89) be amended to read as follows:

i

1. The Atomic Energy Commission (hereinafter "the Commission") has found that:

C. The facility will be possessed in conformity with the application as amended, the provisions of the Act, and the rules and regulations of the Commission; D. There is reasonable assurance that the reactor facility can be possessed (i) without endangering the health and safety of the public and (ii) in compliance with the regulations in this chapter; E. General Atomics is technically and financially qualified to possess the facility in accordance with the regulations in this chapter;"

2. Facility License No. R-38 is hereby amended in its entirety to read as follows:

j Attachment No. 2 GA Letter N3. 38-2726 l April 25,1997 - Page 2 B. Subject to the conditions and requirements incorporated herein, thCommission {

hereby licenses General Atomics:

(1) Pursuant to Section 104c of the Act and 10 CFR Chapter I, Part 50 " Licensing of Production and Utilization Facilities", to possess, but not operate, the reactor at the designated location at San Diego, California, in accordance with the procedures and limitations described in the application and in this license.

1 (2) Pursuant to the Act and 10 CFR Chapter I, Part 70 " Domestic Licensing of Special Nuclear Material", to receive and possess up to 5.0 kilograms of contained uranium-235 in connection with possession of the facility, and to possess but not separate special nuclear material such as may have been ,

I produced by past operation of the reactor.

(3) Pursuant to the Act and 10 CFR Chater 1, Part 30 " Rules of General Applicability to Domestic Licensing of Byproduct Material", to possess but not to separate such byproduct material as may have been produced by past operation of the reactor. 1 C. This license shall be deemed to contain ... or incorporated below: j (1) Maximum Power Level (paragraph 2. C. (1) is to be deleted in its entirety)

(2) Technical Soecifications The Technical Specifications contained in Appendix A , as revised through Amendment No. 34, are hereby incorporated in the license. The licensee shall possess the facility in accordance with the Technical Specifications. ,

(4) Fuel Storage So long as General Atomics possesses the reactor in accordance with the Technical Specifications as amended, no reactor fuel shall be stored in, or moved into, the reactor core structure, in support of the above request, GA hereby commits to cease operation of its TRIGA Mark

Attachment No. 2 GA Lettir N2. 38-2726 April 25,1997 - Page 3 l reactor effective 30 days after the date of issuance of the requested license amendment. In furtherance of this commitment, GA will, during this 30 day period following issuance of the license amendment, remove all fuel from the reactors core so as to render it incapable of operation. Once removed from the reactofs core, the fuel will never again be placed in the reactors grid plate. The fuel elements removed from the core will be stored in a safe geometry in GA's TRIGA Reactors (R-38 and R-67) Facility's fuel storage racks. The 30-day period requested above will allow GA to ensure that the facility will be in a possession-only configuration when the possession-only amendment to license R-38 becomes effective.

As mentioned above, GA intends to remove all fuel elements from the reactor core. The fuel removed from the reactor core will be placed in safe storage in the reactors pool storage racks, or other approved storage areas, including storage racks in GA's Mark F reactor pool (and canal).

GA will continue to safely store all of the Mark I reactor fuel until such time as arrangements can be made for shipping it off site for ultimate disposition.

II) REQUESTED AMENDMENTS TO THE TECHNICAL SPECIFICATIONS FOR R-38 in view of the above request to withdraw GA's authorization to operate its TRIGA Mark l Reactor (R 38), there are technical specifications (TS) which, as a result of placing the reacto in a possession-only configuration / status, need to be amended by their modification or deletion. .

These changes, described below, are provided in the attached copy of "Tecnical Specifications / TRIGA Mark I Reactor." The changes are identified by being italicized.

The technical specifications which GA wishes to amend involve (a) definitions which define conditions for ooerating the reactor, (b) calibration of reactor power measurement channels, (c) calibration and inspection requirements for fuel elements and control rods, and (d) administrative controls that addrese and/or refer to operation of the reactor. Specifically, the technical specifications for which GA is requesting amendments are listed and described below:

Section 1.1: Reactor Shutdown:

l I

Amend this definition to read as follows: i i

Attachment No. 2 .

GA Letter No. 3s-2726 April 25,1997 - Page 4

" Reactor shutdown shall mean that the reactor is subcritical at all times by at least one dollar of reactivity."

Section 1.2: Reactor Secured:

Amend this definition by deleting 1.2(b) and revising 1.2(c) such that TS 1.2 reads as follows:

" Reactor secured shall mean that condition wherein:

(a) The reactor is shutdown, and (b) no work is in progress involving handling of fuel, experiments or reactor core related maintenance operations."

[ Note: TS 1.2 b applies only if the reactor is to be operated, and will not apply when the license is amended to withdraw authorization to operate, i.e., a possession only license amendment. Similarly, TS 1.2 c is being revised to remove portions which would only be applicable if the reactor was in operation.]

Section 1.3: Reactor Operation:

Note: in the possession only mode, the reactor will not be capable of achieving criticality. Further, Section 5.1.2, as amended below, requires that the reactor be AlEAtt abuidgwn by at least one dollar of reactivity. .

Under the following proposed revision of Section 1.3, fuel handling does not constitute " reactor operation." Thus, the effect of this  !

proposed revision to Section 1.3 is to allow fuel handling to occur while  !

always maintaining the reactor shutdown by at least one dollar of reactivity without having the reactor meet the definition of " reactor operation." This will allow necessary fuel handling, in instances such as defueling and/or decommissioning, without unnecessary Technical Specifications (such as those of Sections 5.2.1,5.2.2 and 5.2.4) invoking no longer needed requirements associated with " reactor operation."

Therefore, Amend *Section 1.3: Reactor Ooeration" to read as follows:

" Reactor operation shall mean any condition wherein the reactor is not

I Attachment N). 2 GA Letter No. 38-2726 April 25,1997 - Page 5 shutdown."

Section 1.10: Abnormal Occurrence

[TS 1.10 will be modified by revising the introductory sentence to reflect the status of the reactor license being amended to authorize possession only, and items / paragraphs a, b, c and d will be deleted.

The deleted items / paragraphs are only applicable when conducting reactor operations, and do not apply to a reactor with a possession only license amendment. Similarly, item / paragraph 1.10 e will be revised to delete reference to " operation" of the reactor.]

Therefore, revise the introductory sentence to TS 1.10 to read as follows:

"An abnormal occurence is any of the following which occurs during reactor possession:"

Revise TS 1.10 e. To read as follows:

"e. An observed inadequacy in the implementation of either administrative or procedural controls, such that the inadequacy could have caused the existence or development of a condition which could result in possession of the reactor outside the specified safety limits; and "

Delete 1.10(a), (b) and (d).

Section 5.1.2: 5.0 CONTROL AND SAFETY SYSTEMS 5.1 Control Systems Amend Section 5.1.2 to read as follows:

"The number and configuration of fuel elements and control rods in the reactor shall be such as to maintain the reactor shut down by at least one dollar of reactivity at all times, even if all control rods were removed."

Section 5.2.3 5.2 Safety Systems Amend Section 5.2.3 to read as follows:

Attachment No. 2 GA Letter No. 38-2726 April 25,1997 Page 6 1

• Radiation monitoring systems shall be operable as follows:

)

(a) An area radiation monitoring system - capable of activating an evacuation alarm.

(b) When the reactor is not secured, a continuous monitoring system for airborne activity having a readout and audible alarm which can be heard in the reactor and control rooms.

,1 These systems shall be calibrated annually and their set points verified monthly. For periods of time for maintenance or repair to the above systems, ,

or during periods of other forced outages, the intent of this specification shall be satisfied if the Insta!!ed system (s) is replaced with appropriate alternate  ;

or portable radiation monitoring system (s)."  ;

l Section 6.0 FUEL STORAGE ,

Additem 6.4 to read as follows: ,

t "6.4 Fuel handling tools or devices shall be stored in a secure manner such that their use can be limited to authorized movements of fuel."

Section 9.1 Organization:

Amend this section to delete reference to the Physicist-in-Charge being a licensed senior operator, and to delete reference to safe operation of the reactor. The amended Section 9.1 is to read: >

"The facility shall be under the supervision of the Physicist in Charge or his designated attemate. The minimum qualitication for the Physicists in-Charge shall include a Bachelor's degree or equivalent academic education and three years experience in activities related to reactor operations. He shall be responsible to a Vice President whose duties include responsibility for research and development, or his designated attemate, for limiting exposure of personnel and dispersal or radioactive material. The reactor shall be related to the ccrporate structure as shown in the following chart:"

, ~ . ,

Attachment No. 2 GA Letter No. 38-2726 April 25,1997 - Page 7 Health Vice-President Criticality & Radiation Physicist or Safeguards designated alternate Committee Physicist-in-Charge -- - I Facility Staff Section 9.2 Review Committee:

Amendthis section to replace reference to " Criticality Safeguards Committee" with " Criticality and Radiation Safety Committee (CRSC)," and to delete references to reactor operation.

The amended Section 9.2 is to be titled " Criticality and Radiation Safety Committee (CRSC)."

Paragraph 9.2 a. is to read as follows:

a. "There shall be a Criticality and Radiation Safety Committee (CRSC) which mil review activities of th9 facility to assure criticality and radiation safety. The Committee shall be composed of at least four members selected by the cognizant Vice President, or a designee, considering their experience and education with regard to the various aspects of nuclear physics, chemistry, radiological health and statistics, as well as appropriate experience in other disciplinas such as metallurgy and engineering. Subcommittees shall be appointed by the Chairman of the CRSC. The subcommittee assigned the responsibility for reviewing facility operations shall not have thereon person (s) who are directly involved with that facility."

Attachment No. 2 GA Letter NS. 38-2726 April 25,1997 - Page 8 Paragraph 9.2 b. is to read as follows:

b. "The Criticality and Radiation Safety Committee shall be in accordance with a written charter including provisions for:

1. Hold meetings or audits at least annualiy; special meetings may be called by subcommittees of the CRSC or by the Chairman of the CRSC at times when such meetings are deemed appropriate.

2. Have a quorum when a majority of the members attend.

3. Prepare minutes or audit findings of the CRSC meetings by the Chairman or his designee. Evidence of approval of the participat-Ing mernbers of the CRSC shall be obtained before distribution.

Paragraph 9.2 c. is to read as follows:

c. "The Criticality and Radiation Safety Committee, or subcommittee, shall review and approve safety standards associated with possession of the Facility. The CRSC or a subcommittee thereof shall audit the Facility annually but at intervals not to exceed fifteen (15) months."

Paragraph 9.2 d., item 4 is to read as follows:

4. " Review of facility records."

Paragraph 9.2 d., item 5 is to read as follows:

5. " Review of abnormal performance of plant equipment and other anomalies; and" Section 9.3 Written Procedures:

Amend paragraph 9.3 a. as follows:

a. " Testing and calibration of instrumentation and controls necessary to meet the requirements of the Technical Specifications."

Attachment No. 2 GA Letter No. 38-2726 April 25,1997 - Page 9 Delete paragraphs 9.3 b, e, and f.

Amend the paragraph of text following 9.3 g to read as follows:

" Changes which alter the original intent of the above procedures shall be made only with the approval of the Criticality and Radiation Safety Committee (CRSC). Changes to the procedures that do not change their original intent may be made by the Physicist in-Charge; all such changes shall be documented and subsequently reviewed by the CRSC."

Section 9.4 Action to be Taken in the Event of a Reportable Occurrence Amend paragraphs b. and c. of Section 9.4 to read as follows (replaces reference to Criticality Safeguards Committee with CRSC):

b. "The Physicist in-Charge or other person notified under Section 9.4a shall notify the Chairman of the CRSC and the Vice President, or his designated alternate, identified in Section 9.1."

c. "A report shall be made to the CRSC which shall include an analysis of )

the cause of the occurrence, efficacy of corrective action, and recommendations for measures to prevent or reduce the probability of recurrence."

I Inasmuch as GA will not be authorized to operate the reactor and the reactor will not contain enough fuel to be capable of achieving criticality, it will be unequivocally unnecessary and/or impossible to raeet the requirements in Sections 4.4,5.1.3,5.1.4,5.1.5,5.2.5, 9.3 b,9.3 e,9.3 f and 9.6 e of the TRIGA Mark i Reactor's (R-38) Technical Specifications. GA therefore requests that these technical specifications be amended by deleting them in their entirety, i. e.,

GA requests that the following Technical Specifications be amended by deleting them:

Section 4.4: Delete this section which establishes requirements for periodic inspections of fuel elements in accordance w!th criteria specified in the technical specifications. By requesting the deletion of this technical specification requirement, GA hereby relinquishes the exemption granted in Section 4.5 from the requirements of 10CFR70.51(d), and GA will return to the requirements for physical inventory of Special Nuclear Material in accordance with 10CFR70.51(d).

Anachment No. 2 GA Letter No. 38-2726 April 25,1997 - Page 10 Section 5.1.3: Delete this section which places requirements for periodic verification of control rod scram times.

Section 5.1.4: Delete this section which requires periodic visual inspection of control rods.

Section 5.1.5: Delete this section which requires periodic inspection of transient rod drive cylinder and the associated air supply system.

Section 5.2.5: Delete this section which requires periodic calibration of the reactor power ,

measuring channels.

Section 9.3 5 Delete this item which refers to procedures for reactor operation.

I Section 9.3 e Delete this item which refers to procedures for control rod replacement.  ;

i Section 9.3 f Delete this item which refers to procedures for maintenance of control rod l drives.

l Section 9.6 e Delete this section except for subsection 9.6e(5), which requires an annual report summarizing reactor operating experience.  :

lil) ADDITIONAL MEASURESlQENSUBESAEEIY Measures that wili be taken, in addition to the above described steos, to ensure the safety j of the above proposed action willinclude the following:

e All fuel will be stored in accordance with existing technical specification requirements for safe fuel storage.

e Pool water quality will be maintained and ensured in accordance with existing technical specifications and following existing procedures, this in turn wil! ensure the safety and physicalintegrity of the fuel, e All stored fuel will be secure in its storage location.

e All fuel movements required to achieve the safe and secure storage of the fuel will be conducted following existing fuel handling and storage practices and procedures.

T Attachment No. 2 GA Lett:r NL 38 2726 t April 25,1997 - Page 11 1

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e GA will continue to maintain the facility to assure that the fuel is always stored in a safe and secure manner prior to it being shipped off site for ultimate disposition. ,

o Physical security of the stored fuel will be assured by the continued implementation of applicable measures specified in GA's NRC-approved fixed site physical protection plan (Ref.1), which shall remain in effect.

e The applicable requirements of GA's NRC-approved radiological contingency plan (Ref.

2) will continue to apply to the facility. l

• All existing pertinent safety related technical specifications applicable and relevant to the reactor in a shutdown mode and/or to safe handling and storage of fuel will remain in

effect. The requirements of these technical specifications will continue to be met until the ,

fuel is removed from the facility and/or shipped off site for ultimate disposition. In particular, the requirements of the following Mark I (R-38) Technical Specifications are ,

relevant, directly applicable and will continue to be met:

Sections 3.2,3.3, and 3.4

Requirements on reactor pool water conditions.

Section 5.2.3: Requirements for area radiation and continuous ,

monitoring systems and alarms. Note the above requested revision to Section 5.2.3.

. Sections 6.1,6.2 and 6.3: Requirements on safe fuel storage.

Clearly, with the reactor being incapable of achieving criticality, the fuel being stored in approved safe and secure locations, and in view of all of the above described measures to ensure continued safety and security, GA submits that there are no safety considerations affected by the requested amendments to GA's TRIGA Mark l (R-38/ Lcense and Technical Specifications.

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