ML15203A555

Submittal of Response for the Request for Additional Information Dated June 25, 2015

ML15203A555
Person / Time
Site:	Reed College
Issue date:	07/10/2015
From:	Krahenbuhl M Reed College
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15203A555 (3)

Text

REED COLLEGEREACTOR FACILITY' :3203 Southeast :..-, .. " 2 .," ." ... , .. .:.r .... .... .... .. ..Woodsrock BoulevardPortland, Oregon97202-8199telephone503/777-7222tax503/777-7274emailreactor@'reed.ed uhttp://reactor.reed.eduiJuly 10, 2015 .ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001Docket: 50-288License No: R-112Enclosed is the response for the request for additional information dated June 25,2015.I declare under penalty of perjury that the foregoing is true and correct.Executed on 4/12/I-pMelinda Krahenbuhl, Ph.D.Director, Reed Research Reactor&Y-/(0-9p(Le, Response to the request for additional informationDated June 25, 20151. The requested TS amendment proposes to eliminate the position described in thecurrent RRR TS 6.1.2, Specification b., of "Associate Director" as a Level 2, andadds a position of "Reactor Operations Manager" as a Level 3. The guidance inNUREG -1537, Guidelines for preparing and reviewing applications for thelicensing of Non-Power Reactors, "Part 1, Appendix 14.1, Format and Content ofTechnical Specifications," states in part, that the organizational functions,assignments, and responsibilities should be stated. Provide an explanation,justification and/or basis for the elimination of Level 2 position and the creationof a Level 3 position, or justify why no response is necessary.RRR responseBoth the current and proposed administrative structures are consistent with theguidance in NUREG -1537, Guidelines for preparing and reviewingapplications for the licensing of Non-Power Reactors, "Part 1, Appendix 14.1,Format and Content of Technical Specifications, and ANSI/ANS 15.4 2007.During 2013, Reed College's Human Resources embarked on staff functionreview that included a questionhaire. The data from the questionnaire wasused to update job descriptions, and evaluate the job for appropriateclassification based duties and compensation. This data was compared tosimilar businesses and institutions. As a result of the review, Reed CollegesHuman Resources identified that the title Associate Director was inconsistentwith the duties and compensation of similar positions at peer institutions. Thecompensation and duties expected, specifically day-to-day operations wereconsistent with those of a Manager. Additionally, these duties were morealigned with Level 3 in NUREG-1537 and ANSI/ANS 15.4. Therefore, theposition was renamed to convey the actual duties, responsibilities andcompensation of the position.2. The current RRR TS 6.1.2, Specification b, states in part, "The Associate DirectorReports to the Director, and is responsible for guidance, oversight and technicalsupport of reactor operations." The requested amendment removes theresponsibility for guidance, oversight and technical support of reactor operations."The guidance in NUREG -1537, Guidelines for preparing and reviewingapplications for the licensing of Non-Power Reactors, "Part 1, Appendix 14.1,Format and Content of Technical Specifications," states in part, that theorganizational functions, assignments, and responsibilities should be stated.Explain why these responsibilities are being removed from the TSs, the basis forthis change, if these responsibilities are maintained in RRR technical oradministrative procedures, or justify why no response is necessary.1 RRR responseThe proposed language does not remove any responsibilities from the reactoroperations manager. The proposed language is:"Reactor Operations Manager and Supervisor(s) (Level 3): The ReactorOperations Manager reports to the Director and is responsible for directing theactivities of the reactor staff and for the day-to-day operation and maintenanceof the reactor. " This language was chosen to clearly -state an over-archingresponsibility that implicitly includes guidance, technical support andoversight of the reactor.2