ML18263A235

North Carolina State University, Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding Fueled Experiments for the Pulstar Research Reactor

ML18263A235
Person / Time
Site:	North Carolina State University
Issue date:	10/03/2018
From:	Edward Helvenston Research and Test Reactors Licensing Projects Branch
To:	Hawari A North Carolina State University
Helvenston E, NRR/DLP, 415-4067
References
EPID L-2018-LLA-0247
Download: ML18263A235 (6)

Text

October 3, 2018 Dr. Ayman I. Hawari, Director Nuclear Reactor Program Department of Nuclear Engineering North Carolina State University Campus Box 7909 2500 Stinson Drive Raleigh, NC 27695-7909

SUBJECT:

NORTH CAROLINA STATE UNIVERSITY - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION REGARDING FUELED EXPERIMENTS FOR THE PULSTAR RESEARCH REACTOR (EPID NO. L-2018-LLA-0247)

Dear Dr. Hawari:

By letter dated August 27, 2018 (Agencywide Documents Access and Management System Accession No. ML18241A135), North Carolina State University (NCSU) submitted a license amendment request (LAR) for the NCSU PULSTAR research reactor. NCSU requested the amendment to revise its license conditions (LCs) and technical specifications (TSs) to allow it to increase the quantity of uranium-235 (U-235) in fueled experiments; to allow it to perform fueled experiments with neptunium-237 or plutonium-239, in addition to U-235; and to allow it to perform vented fueled experiments. The amendment would also make other changes related to fueled experiments, including revising the TS definition of fueled experiment, and increasing license possession limits for fissile and fissionable materials to be used in fueled experiments.

NCSU stated that the amendment would allow the LCs and TSs to accommodate its planned experimental needs.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this LAR. The NRC staff performed this acceptance review 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 satisfaction of the regulatory requirements or the characterization of the licensing basis for the facility.

Consistent with Section 50.90, Application for amendment of license, construction permit, or early site permit, of Title 10 of the Code of Federal Regulations (10 CFR), whenever a holder of a license desires to amend the license, an application for an amendment must be filed with the Commission, as specified in 10 CFR 50.4, Written communications, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. Section 50.34, Contents of applications; technical information, 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.

A. Hawari The NRC staff has reviewed NCSUs application, and concluded that the information delineated in the enclosure to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed LAR in terms of meeting regulatory requirements, and protecting the public health and safety, and the environment. The NRC staff requests that NCSU either 1) supplement the application to address the information needs described in the enclosure by November 5, 2018, in order to make the application complete; or,

2) withdraw and resubmit the application at a later date.

The supplemental information will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs information needs is not received by the above date, the application, if not withdrawn, will not be accepted for review pursuant to 10 CFR 2.101, Filing of application, and the NRC staff will cease its review activities associated with the application.

If the application is subsequently accepted for review, NCSU will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.

The information needs and associated response time frame in this letter were discussed with your staff on October 1, 2018.

If you have any questions regarding this review, please contact me at 301-415-4067, or by electronic mail at Edward.Helvenston@nrc.gov.

Sincerely,

/RA/

Edward Helvenston, Project Manager Research and Test Reactors Licensing Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-297 License No. R-120

Enclosure:

As stated cc: See next page

North Carolina State University Docket No. 50-297 cc:

Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Dr. Kostadin Ivanov, Head Department of Nuclear Engineering North Carolina State University Campus Box 7909 Raleigh, NC 27695-7909 W. Lee Cox, Section Chief Department of Health and Human Services Division of Health Service Regulation Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645 Dr. Louis Martin-Vega, Dean College of Engineering North Carolina State University 113 Page Hall Campus Box 7901 Raleigh, NC 27695-7901 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611

ML18263A235 *concurred via email OFFICE NRR/DLP/PRLB/PM* NRR/DLP/PRLB/LA* NRR/DLP/PRLB/BC NRR/DLP/PRLB/PM NAME EHelvenston NParker AAdams EHelvenston DATE 9/26/2018 9/25/2018 10/3/2018 10/3/2018

SUPPLEMENTAL INFORMATION NEEDS LICENSE AMENDMENT REQUEST REGARDING FUELED EXPERIMENTS FOR THE PULSTAR RESEARCH REACTOR NORTH CAROLINA STATE UNIVERSITY DOCKET NO. 50-297 LICENSE NO. R-120 By letter dated August 27, 2018 (Agencywide Documents Access and Management System ADAMS Accession No. ML18241A135), North Carolina State University (NCSU) submitted a license amendment request (LAR) related to fueled experiments at the NCSU PULSTAR research reactor.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following information is necessary to make the application complete and acceptable for docketing:

1. Atmospheric Dispersion Calculation Methodology The analyses in the application include atmospheric dispersion calculations that appear to differ significantly from those used in the 2017 safety analysis report (SAR) (ADAMS Accession No. ML17201Q129), submitted in support of NCSUs request for renewal of the PULSTAR reactor license, which the NRC staff is currently reviewing separately. The application should be supplemented to include a discussion of the differences in the calculations in the fueled experiment amendment request versus the 2017 SAR, and the rationale for the use of a different methodology.

2. Vented Fueled Experiments The application does not appear to include sufficient discussion of the vented fueled experiments that are proposed as part of the amendment request. The application should be supplemented to describe the location and configuration of components such as the experiment holder, filters, holdup tanks, radiation and flow monitors, isolation valves, and connections between these components, with respect to existing reactor components such as beam tubes and beam tube exhaust. The NRC staff recommends that diagrams of the proposed vented experiment system be provided, if possible. Additionally, the application should be supplemented to discuss how, as stated in the LAR, the [r]elease of particulate, powder, liquid, and solid material is prevented by design of the [vented experiments].

3. Filter Efficiencies The analyses of doses from failures of encapsulated fueled experiments, and routine releases from vented fueled experiments, appear to credit particulate and charcoal filters (as part of the facility confinement system or in the vented experiment system) for removal of radioactive material from air, but the current or proposed technical specifications (TSs) do not appear to include limiting conditions for operation (LCOs) requiring specific minimum efficiencies for these filters. The application should be supplemented to include proposed LCO TSs requiring applicable minimum filter efficiencies.

Enclosure

4. Surveillance Requirements Related to Vented Fueled Experiments The proposed TSs do not appear to include any surveillance requirement TSs for proposed LCO TS 3.8.d.iv related to vented fueled experiments. The application should be supplemented to include proposed surveillance TSs for LCO TS-required vented fueled experiment equipment (such as filters or radiation monitors) and parameters (such as exhaust flow rates).

5. Possession Limit Changes The application does not appear to specify the form or enrichment of uranium-235, neptunium-237, or plutonium-239 for which a possession allowance is being requested. The application also does not appear to specify whether any current license conditions (LCs) related to radioactive material possession (e.g., current LC 2.B.(2), which, in part, allows NCSU to possess up to 2 grams of contained uranium-235 of any enrichment in the form of foils should be replaced by the new possession limit conditions. The application should be supplemented to provide these details of the requested possession limit changes.

6. Description of Technical Specification Changes The application does not appear to contain a sufficient description of, or justification for, all of the proposed changes to TS 3.8. The application should be supplemented to provide a complete description of all of the proposed changes to TS 3.8 compared to the current NRC-approved TS 3.8 (i.e., each deletion or modification of a portion of current TS 3.8, including minor numbering, formatting, or editorial changes, as well as each addition to current TS 3.8). In addition, the application should be supplemented to include a detailed discussion and/or analysis, as applicable, justifying each change.

7. Proposed Technical Specification Change Pages The application does not appear to include proposed TS change pages that are marked-up to indicate the areas of change (compared to the current NRC-approved TSs of record), to support the LAR. The NRC staff recommends that the application be supplemented to include marked-up proposed TS change pages.October 3, 2018

Dr. Ayman I. Hawari, Director

Nuclear Reactor Program

Department of Nuclear Engineering

North Carolina State University

Campus Box 7909

2500 Stinson Drive

Raleigh, NC 27695-7909

SUBJECT: NORTH CAROLINA STATE UNIVERSITY - SUPPLEMENTAL INFORMATION

NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION

REGARDING FUELED EXPERIMENTS FOR THE PULSTAR RESEARCH

REACTOR (EPID NO. L-2018-LLA-0247)

Dear Dr. Hawari:

By letter dated August 27, 2018 (Agencywide Documents Access and Management System

Accession No. ML18241A135), North Carolina State University (NCSU) submitted a license

amendment request (LAR) for the NCSU PULSTAR research reactor. NCSU requested the

amendment to revise its license conditions (LCs) and technical specifications (TSs) to allow it to

increase the quantity of uranium-235 (U-235) in fueled experiments; to allow it to perform fueled

experiments with neptunium-237 or plutonium-239, in addition to U-235; and to allow it to

perform vented fueled experiments. The amendment would also make other changes related to

fueled experiments, including revising the TS definition of fueled experiment, and increasing

license possession limits for fissile and fissionable materials to be used in fueled experiments.

NCSU stated that the amendment would allow the LCs and TSs to accommodate its planned

experimental needs.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission

(NRC) staffs acceptance review of this LAR. The NRC staff performed this acceptance review

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 satisfaction of

the regulatory requirements or the characterization of the licensing basis for the facility.

Consistent with Section 50.90, Application for amendment of license, construction permit, or

early site permit, of Title 10 of the Code of Federal Regulations (10 CFR), whenever a holder of

a license desires to amend the license, an application for an amendment must be filed with the

Commission, as specified in 10 CFR 50.4, Written communications, fully describing the

changes desired, and following as far as applicable, the form prescribed for original

applications. Section 50.34, Contents of applications; technical information, 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.

A. Hawari - 2 -

The NRC staff has reviewed NCSUs application, and concluded that the information delineated

in the enclosure to this letter is necessary to enable the NRC staff to make an independent

assessment regarding the acceptability of the proposed LAR in terms of meeting regulatory

requirements, and protecting the public health and safety, and the environment. The NRC staff

requests that NCSU either 1) supplement the application to address the information needs

described in the enclosure by November 5, 2018, in order to make the application complete; or,

2) withdraw and resubmit the application at a later date.

The supplemental information will enable the NRC staff to begin its detailed technical review. If

the information responsive to the NRC staffs information needs is not received by the above

date, the application, if not withdrawn, will not be accepted for review pursuant to 10 CFR 2.101,

Filing of application, and the NRC staff will cease its review activities associated with the

application.

If the application is subsequently accepted for review, NCSU will be advised of any further

information needed to support the NRC staffs detailed technical review by separate

correspondence.

The information needs and associated response time frame in this letter were discussed with

your staff on October 1, 2018.

If you have any questions regarding this review, please contact me at 301-415-4067, or by

electronic mail at Edward.Helvenston@nrc.gov.

Sincerely,

/RA/

Edward Helvenston, Project Manager

Research and Test Reactors Licensing Branch

Division of Licensing Projects

Office of Nuclear Reactor Regulation

Docket No. 50-297

License No. R-120

Enclosure:

As stated

cc: See next page

North Carolina State University Docket No. 50-297

cc:

Office of Intergovernmental Relations

116 West Jones Street

Raleigh, NC 27603

Dr. Kostadin Ivanov, Head

Department of Nuclear Engineering

North Carolina State University

Campus Box 7909

Raleigh, NC 27695-7909

W. Lee Cox, Section Chief

Department of Health and Human Services

Division of Health Service Regulation

Radiation Protection Section

1645 Mail Service Center

Raleigh, NC 27699-1645

Dr. Louis Martin-Vega, Dean

College of Engineering

North Carolina State University

113 Page Hall

Campus Box 7901

Raleigh, NC 27695-7901

Test, Research and Training

Reactor Newsletter

P.O. Box 118300

University of Florida

Gainesville, FL 32611

A. Hawari - 3 -

SUBJECT: NORTH CAROLINA STATE UNIVERSITY - SUPPLEMENTAL INFORMATION

NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION

REGARDING FUELED EXPERIMENTS FOR THE PULSTAR RESEARCH

REACTOR DATE: OCTOBER 3, 2018

DISTRIBUTION:

PUBLIC

PRLB r/f

RidsNrrDlp

RidsNRrDlpPrlb

RidsNrrDlpProb

CMontgomery, NRR

AMendiola, NRR

JEads, NRR

NParker, NRR

AAdams, NRR

EHelvenston, NRR

DHardesty, NRR

ADAMS Accession No. ML18263A235 *concurred via email

OFFICE NRR/DLP/PRLB/PM* NRR/DLP/PRLB/LA* NRR/DLP/PRLB/BC NRR/DLP/PRLB/PM

NAME EHelvenston NParker AAdams EHelvenston

DATE 9/26/2018 9/25/2018 10/3/2018 10/3/2018

OFFICIAL RECORD COPY

Enclosure

SUPPLEMENTAL INFORMATION NEEDS

LICENSE AMENDMENT REQUEST REGARDING FUELED EXPERIMENTS FOR

THE PULSTAR RESEARCH REACTOR

NORTH CAROLINA STATE UNIVERSITY

DOCKET NO. 50-297

LICENSE NO. R-120

By letter dated August 27, 2018 (Agencywide Documents Access and Management System

ADAMS Accession No. ML18241A135), North Carolina State University (NCSU) submitted a

license amendment request (LAR) related to fueled experiments at the NCSU PULSTAR

research reactor.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following

information is necessary to make the application complete and acceptable for docketing:

1. Atmospheric Dispersion Calculation Methodology

The analyses in the application include atmospheric dispersion calculations that appear to differ

significantly from those used in the 2017 safety analysis report (SAR) (ADAMS Accession

No. ML17201Q129), submitted in support of NCSUs request for renewal of the PULSTAR

reactor license, which the NRC staff is currently reviewing separately. The application should

be supplemented to include a discussion of the differences in the calculations in the fueled

experiment amendment request versus the 2017 SAR, and the rationale for the use of a

different methodology.

2. Vented Fueled Experiments

The application does not appear to include sufficient discussion of the vented fueled

experiments that are proposed as part of the amendment request. The application should be

supplemented to describe the location and configuration of components such as the experiment

holder, filters, holdup tanks, radiation and flow monitors, isolation valves, and connections

between these components, with respect to existing reactor components such as beam tubes

and beam tube exhaust. The NRC staff recommends that diagrams of the proposed vented

experiment system be provided, if possible. Additionally, the application should be

supplemented to discuss how, as stated in the LAR, the [r]elease of particulate, powder, liquid,

and solid material is prevented by design of the [vented experiments].

3. Filter Efficiencies

The analyses of doses from failures of encapsulated fueled experiments, and routine releases

from vented fueled experiments, appear to credit particulate and charcoal filters (as part of the

facility confinement system or in the vented experiment system) for removal of radioactive

material from air, but the current or proposed technical specifications (TSs) do not appear to

include limiting conditions for operation (LCOs) requiring specific minimum efficiencies for these

filters. The application should be supplemented to include proposed LCO TSs requiring

applicable minimum filter efficiencies.

- 2 -

4. Surveillance Requirements Related to Vented Fueled Experiments

The proposed TSs do not appear to include any surveillance requirement TSs for proposed

LCO TS 3.8.d.iv related to vented fueled experiments. The application should be supplemented

to include proposed surveillance TSs for LCO TS-required vented fueled experiment equipment

(such as filters or radiation monitors) and parameters (such as exhaust flow rates).

5. Possession Limit Changes

The application does not appear to specify the form or enrichment of uranium-235,

neptunium-237, or plutonium-239 for which a possession allowance is being requested. The

application also does not appear to specify whether any current license conditions (LCs) related

to radioactive material possession (e.g., current LC 2.B.(2), which, in part, allows NCSU to

possess up to 2 grams of contained uranium-235 of any enrichment in the form of foils should

be replaced by the new possession limit conditions. The application should be supplemented to

provide these details of the requested possession limit changes.

6. Description of Technical Specification Changes

The application does not appear to contain a sufficient description of, or justification for, all of

the proposed changes to TS 3.8. The application should be supplemented to provide a

complete description of all of the proposed changes to TS 3.8 compared to the current

NRC-approved TS 3.8 (i.e., each deletion or modification of a portion of current TS 3.8,

including minor numbering, formatting, or editorial changes, as well as each addition to current

TS 3.8). In addition, the application should be supplemented to include a detailed discussion

and/or analysis, as applicable, justifying each change.

7. Proposed Technical Specification Change Pages

The application does not appear to include proposed TS change pages that are marked-up to

indicate the areas of change (compared to the current NRC-approved TSs of record), to support

the LAR. The NRC staff recommends that the application be supplemented to include

marked-up proposed TS change pages.