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{{#Wiki_filter:December 6, 2012  
{{#Wiki_filter:December 6, 2012 Dr. Yassin Hassan Department Head- Acting, Nuclear Engineering Texas A&M University 337 Zachry Engineering Center College Station, TX 77843-3133
 
Dr. Yassin Hassan Department Head- Acting, Nuclear Engineering Texas A&M University 337 Zachry Engineering Center College Station, TX 77843-3133  


==SUBJECT:==
==SUBJECT:==
TEXAS A & M UNIVERSITY - ADDITIONAL CLARIFICATION TO RESPONSES TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE TEXAS A & M UNIVERSITY AGN-201M RESEARCH REACTOR LICENSE RENEWAL (TAC NO. ME1588)  
TEXAS A & M UNIVERSITY - ADDITIONAL CLARIFICATION TO RESPONSES TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE TEXAS A & M UNIVERSITY AGN-201M RESEARCH REACTOR LICENSE RENEWAL (TAC NO. ME1588)


==Dear Dr. Hassan:==
==Dear Dr. Hassan:==


The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-23 for the Texas A & M University AGN-201M Reactor dated July 22, 1997, (a redacted version of the safety analysis report is available on the NRC's public Web site at www.nrc.gov under Agencywide Documents Access and Management System (ADAMS) Accession No. ML102790087). As part of our review, the NRC staff submitted requests for additional information (R AI) by letter dated July 25, 2011, (ADAMS Accession No. ML112000240).  
The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-23 for the Texas A & M University AGN-201M Reactor dated July 22, 1997, (a redacted version of the safety analysis report is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System (ADAMS) Accession No. ML102790087). As part of our review, the NRC staff submitted requests for additional information (RAI) by letter dated July 25, 2011, (ADAMS Accession No. ML112000240).
 
The NRC staff has reviewed your responses and identified in the attached table those RAI responses needing additional clarification. Please provide your responses within 90 days of the date of this letter. In accordance with Title 10 of the Code of Federal Regulations (10 CFR)
The NRC staff has reviewed your responses and identified in the attached table those RAI responses needing additional clarification. Please provide your responses within 90 days of the date of this letter. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, "Written Communications." Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding."
Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, Written Communications. Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding.
If you have any questions regarding this review, please contact Patrick Boyle at (301) 415-3936 or by electronic mail at Patrick.Boyle@nrc.gov. Sincerely, /JLising for RA/ Geoffrey Wertz, Project Manager Research and Test Reactors Licensing Branch  
If you have any questions regarding this review, please contact Patrick Boyle at (301) 415-3936 or by electronic mail at Patrick.Boyle@nrc.gov.
 
Sincerely,
Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-59  
                                              /JLising for RA/
Geoffrey Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-59


==Enclosure:==
==Enclosure:==


As stated cc w/encl: See next page Texas A&M University Docket No. 50-59
As stated cc w/encl: See next page
 
cc:  Mayor, City of College Station P.O. Box Drawer 9960 College Station, TX  77840-3575
 
Governor's Budget and  Planning Office P.O. Box 13561 Austin, TX  78711
 
Chris Crouch AGN-201M Reactor Supervisor Nuclear Engineering Department 129 Zachry Engineering Center College Station , TX  77843
 
Radiation Program Officer Bureau of Radiation Control Dept. Of State Health Services
 
Division for Regulatory Services 1100 West 49 th Street, MC 2828 Austin, TX  78756-3189 Technical Advisor Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087
 
Test, Research, and Training
 
Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL  32611 
 
ML112000240).
The NRC staff has reviewed your responses and identified in the attached table those RAI responses needing additional clarification. Please provide your responses within 90 days of the date of this letter. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, "Written Communications." Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding."
 
If you have any questions regarding this review, please contact Patrick Boyle at (301) 415-3936 or by electronic mail at Patrick.Boyle@nrc.gov. Sincerely, /JLising for RA/ Geoffrey Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
 
DISTRIBUTION:
PUBLIC  DPR/PRT r/f  RidsNrrDpr  RidsNrrDprPrta  RidsNrrDprPrtb DHardesty, NRR GLappert, NRR PBoyle, NRR
 
ADAMS Accession No: ML12312A232  *via email TEMPLATE # NRR-088 OFFICE PRLB:NE PRLB:PM* PRLB:LA PRLB:ABC PRLB:PM NAME PBoyle GWertz GLappert PIsaac GWertz DATE  11/8/12    11/7/12 11/14 /12 12/6/12    12/6/12 ENCLOSURE OFFICE OF NUCLEAR REACTOR REGULATION ADDITIONAL CLARIFICATION ON RESPONSES FOR THE RENEWAL OF FACI LITY OPERATING LICENSE TEXAS A & M UNIVERSITY AG N-201M RESEARCH REACTOR LICENSE NO. R-23 DOCKET NO. 50-59 The U.S. Nuclear Regulatory Commission (NRC) has reviewed your responses to our requests for additional information (RAIs) and has identified the following RAI responses that need additional clarification.
RAI No. Original RAI Description RAI Response Date Additional Clarification Needed 06 Describe the design criteria for the console upgrade.
12/22/2011 Please describe the hardware components and software associated with "AGN computer" discussed in Chapter 7 of the Safety Analysis Report (SAR). Include a discussion of what verification and validation was used for the design and installation. Identify which reactor scram signals are generated by the" AGN computer" and which ones are hardwired directly to the scram circuit. Describe the design elements addressing the potential for a single failure disabling multiple scram inputs.
07 Limiting Condition of Operation for the skirt radiation monitor scram. 12/02/2011 Please explain why the Limiting Conditions for Operation (LCO) for a scram was proposed for section 3.4, "Radiation Monitoring, Control, and Shielding" instead of section 3.2 "Control and Safety Systems" which contains a listing of all of the other scram inputs 08 Channel #2 Period Scram design impact from the AGN
 
computer 04/12/2012 Please explain how the "computer" calculates the period and how frequently this is compared to the trip set point. Explain the safety impact of using a computer for this function compared to the previously installed rate meter. RAI No. Original RAI Description RAI Response Date Additional Clarification Needed 09 Channel #3 Linear Power Scram design impact from the console
 
upgrade 04/12/2012 Describe how the "AGN computer" takes the signal from the picoammeter and generates a scram signal based on the output of the Channel #3 detector. How often is the signal compared to the set point and what processors are involved?  What is the cumulative effect of the delay associated with each step between an increase (or decrease for low power trip) in the detector output and initiation of a scram signal including processor delays associated with the other processor demands on the "AGN computer"?  Explain what digital filtering is used and how this affects the overall response time.
11 Reactor Control System does not show how the Interlock Relay function was incorporated into the upgrade.
12/22/2011 Your statement that "There was no Technical Specification (TS) requirement for this interlock feature" is not consistent with the current wording TS 3.2.e, 3.2.f and 3.2.g. Please explain how you are complying with the requirement to have "shield water level interlock," and "shield water temperature interlock" that will "prevent a reactor start up and scram the reactor" 13 Incorporation of the "watch-dog" scram into the appropriate LCO and Chapter 13 update 04/12/2012 The proposed wording for LCO 3.2.k contains the word "installed."  It is not clear what is meant by the word "installed."  Please provide a definition for the word "installed," to be included in section 1 or consider the use of a defined word such as "operable" or "operating" in the proposed LCO.


Please provide a safety analysis of the design change that discusses the "AGN computer," its potential failure modes, and what features are relied
Texas A&M University                            Docket No. 50-59 cc:
Mayor, City of College Station P.O. Box Drawer 9960 College Station, TX 77840-3575 Governors Budget and Planning Office P.O. Box 13561 Austin, TX 78711 Chris Crouch AGN-201M Reactor Supervisor Nuclear Engineering Department 129 Zachry Engineering Center College Station , TX 77843 Radiation Program Officer Bureau of Radiation Control Dept. Of State Health Services Division for Regulatory Services 1100 West 49th Street, MC 2828 Austin, TX 78756-3189 Technical Advisor Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611


upon to ensure operability (ability to perform its intended safety function).
ML12312A232 *via email                                TEMPLATE # NRR-088 OFFICE            PRLB:NE      PRLB:PM*          PRLB:LA      PRLB:ABC            PRLB:PM NAME              PBoyle        GWertz            GLappert      PIsaac              GWertz DATE                11/8/12      11/7/12          11/14 /12    12/6/12              12/6/12
14 Radiation protection program and as low as reasonably


achievable ( ALARA) considerations 08/25/2011 Some of the survey locations indicate a dose rate greater than 10 milli-Roentgen Equivalent Man/hour (mrem/hr). What actions are being implemented in these areas to ensure ALARA principles are considered?
OFFICE OF NUCLEAR REACTOR REGULATION ADDITIONAL CLARIFICATION ON RESPONSES FOR THE RENEWAL OF FACILITY OPERATING LICENSE TEXAS A & M UNIVERSITY AGN-201M RESEARCH REACTOR LICENSE NO. R-23 DOCKET NO. 50-59 The U.S. Nuclear Regulatory Commission (NRC) has reviewed your responses to our requests for additional information (RAIs) and has identified the following RAI responses that need additional clarification.
The RAI response indicates three phantom monitors are present at the facility. What are these phantom monitors and how are they used?  The RAI response also indicated, "facility personnel "are supplied with dosimetry.
RAI RAI Original RAI Description           Response       Additional Clarification Needed No.
Who is considered to be "facility personnel" and what type of dosimetry is used?    RAI No. Original RAI Description RAI Response Date Additional Clarification Needed 15 Ar-41 production consideration 08/25/2011 The percentages of the 10 CFR Part 20 Appendix B Derived Air Concentration (DAC) and effluent release limits are provided in the RAI responses which are based on a dose rate. Based on the maximum allowed operations, what annual dose does this represent to the occupational workers and to members of the public?
Date Please describe the hardware components and software associated with AGN computer discussed in Chapter 7 of the Safety Analysis Report (SAR). Include a discussion of what verification and validation was used for Describe the design criteria for 06                                        12/22/2011      the design and installation. Identify which reactor scram signals are the console upgrade.
17 Personnel monitoring during experiment handling 08/25/2011 Are students allowed in the reactor room when the reactor is operating?  What type of dosimetry is required for the students?  Explain how this is controlled (procedure, etc.).
generated by the AGN computer and which ones are hardwired directly to the scram circuit. Describe the design elements addressing the potential for a single failure disabling multiple scram inputs.
20 Evaluation of MHA related to occupational dose limits 12/02/2011 Amendment 10 only considered one of the severe accidents (slow controlled excursion) 1% reactivity increase without the fuse melting. The original MHA also consider a 2% step reactivity increase (runaway) with fuse melt. Please discuss why the 2% step reactivity increase MHA scenario was not considered in your analysis related to dose limits.
Please explain why the Limiting Conditions for Operation (LCO) for a scram Limiting Condition of Operation was proposed for section 3.4, Radiation Monitoring, Control, and Shielding 07    for the skirt radiation monitor    12/02/2011 instead of section 3.2 Control and Safety Systems which contains a listing scram.
21 Add TS definitions per ANSI/ANS-15.1-2007 guidance for: reactor secured, reactor
of all of the other scram inputs Channel #2 Period Scram                            Please explain how the computer calculates the period and how frequently 08    design impact from the AGN          04/12/2012      this is compared to the trip set point. Explain the safety impact of using a computer                                            computer for this function compared to the previously installed rate meter.
ENCLOSURE


shutdown, and shutdown margin. 12/02/2011 The proposed TS Section 1 definition for Reactor Shutdown (1.19) includes a reference condition of $1.00. Please provide the relationship between
RAI RAI Original RAI Description        Response  Additional Clarification Needed No.
$1.00 and the %k/k or propose wording for the definition of shutdown that is expressed in %k/k consistent with other TSs.
Date Describe how the AGN computer takes the signal from the picoammeter and generates a scram signal based on the output of the Channel #3 detector. How often is the signal compared to the set point and what Channel #3 Linear Power Scram              processors are involved? What is the cumulative effect of the delay 09  design impact from the console  04/12/2012 associated with each step between an increase (or decrease for low power upgrade                                    trip) in the detector output and initiation of a scram signal including processor delays associated with the other processor demands on the AGN computer? Explain what digital filtering is used and how this affects the overall response time.
24 The proposed TS 3.2 and Table 3.1 do not include Interlock Relay Scrams 12/02/2011 The previous console included interlocks for the Rod Drive Cable and Relay Chassis. Activation of these relays resulted in an automatic reactor scram. Please explain why these automatic scrams are no longer required including a discussion of the safety impact of replacing these automatic scram functions with operator action.  
Your statement that There was no Technical Specification (TS) requirement Reactor Control System does for this interlock feature is not consistent with the current wording TS 3.2.e, not show how the Interlock 11                                  12/22/2011 3.2.f and 3.2.g. Please explain how you are complying with the requirement Relay function was incorporated to have shield water level interlock, and shield water temperature into the upgrade.
interlock that will prevent a reactor start up and scram the reactor The proposed wording for LCO 3.2.k contains the word installed. It is not clear what is meant by the word installed. Please provide a definition for the word installed, to be included in section 1 or consider the use of a Incorporation of the watch-dog defined word such as operable or operating in the proposed LCO.
13  scram into the appropriate LCO  04/12/2012 and Chapter 13 update Please provide a safety analysis of the design change that discusses the AGN computer, its potential failure modes, and what features are relied upon to ensure operability (ability to perform its intended safety function).
Some of the survey locations indicate a dose rate greater than 10 milli-Roentgen Equivalent Man/hour (mrem/hr). What actions are being Radiation protection program                implemented in these areas to ensure ALARA principles are considered?
and as low as reasonably                    The RAI response indicates three phantom monitors are present at the 14                                  08/25/2011 achievable ( ALARA)                        facility. What are these phantom monitors and how are they used? The RAI considerations                              response also indicated, facility personnel are supplied with dosimetry.
Who is considered to be facility personnel and what type of dosimetry is used?


RAI No. Original RAI Description RAI Response Date Additional Clarification Needed 25 TS 3.2.g states that a seismic displacement interlock switch shall be installed. This requires a set point. 12/02/2011 Per TS 4.2.h - The shield tank water level interlock, shield water temperature interlock and seismic displacement safety channel shall be tested by perturbing the sensing element to the appropriate set point. These tests shall be performed annually, but at intervals not to exceed 16 months.  
RAI RAI Original RAI Description       Response   Additional Clarification Needed No.
Date The percentages of the 10 CFR Part 20 Appendix B Derived Air Concentration (DAC) and effluent release limits are provided in the RAI 15  Ar-41 production consideration 08/25/2011 responses which are based on a dose rate. Based on the maximum allowed operations, what annual dose does this represent to the occupational workers and to members of the public?
Are students allowed in the reactor room when the reactor is operating?
Personnel monitoring during 17                                08/25/2011 What type of dosimetry is required for the students? Explain how this is experiment handling controlled (procedure, etc.).
Amendment 10 only considered one of the severe accidents (slow controlled excursion) 1% reactivity increase without the fuse melting. The original Evaluation of MHA related to 20                                12/02/2011 MHA also consider a 2% step reactivity increase (runaway) with fuse melt.
occupational dose limits Please discuss why the 2% step reactivity increase MHA scenario was not considered in your analysis related to dose limits.
Add TS definitions per        12/02/2011 The proposed TS Section 1 definition for Reactor Shutdown (1.19) includes ANSI/ANS-15.1-2007 guidance              a reference condition of $1.00. Please provide the relationship between 21  for: reactor secured, reactor            $1.00 and the %k/k or propose wording for the definition of shutdown that shutdown, and shutdown                    is expressed in %k/k consistent with other TSs.
margin.
The proposed TS 3.2 and Table  12/02/2011 The previous console included interlocks for the Rod Drive Cable and Relay 3.1 do not include Interlock              Chassis. Activation of these relays resulted in an automatic reactor scram.
Relay Scrams                              Please explain why these automatic scrams are no longer required including 24 a discussion of the safety impact of replacing these automatic scram functions with operator action.


The reply indicates the switch cannot be calibrated because of its design.
RAI RAI Original RAI Description          Response  Additional Clarification Needed No.
Date TS 3.2.g states that a seismic    12/02/2011 Per TS 4.2.h - The shield tank water level interlock, shield water displacement interlock switch                temperature interlock and seismic displacement safety channel shall be shall be installed. This requires            tested by perturbing the sensing element to the appropriate set point. These a set point.                                tests shall be performed annually, but at intervals not to exceed 16 months.
25 The reply indicates the switch cannot be calibrated because of its design.
Please explain how Texas A&M is in compliance with TS 4.2.h if the set point cannot be verified. Additionally, please justify the use of this interlock.
Please explain how Texas A&M is in compliance with TS 4.2.h if the set point cannot be verified. Additionally, please justify the use of this interlock.
29 Maximum Hypothetical Accident assumptions include no escape of fission products from the core tank. Propose changes to 3.4.f for core tank seal integrity 12/02/2011 Please state how the fission barrier boundary integrity (core tank seal) is ensured via an appropriate TS LCO.}}
Maximum Hypothetical Accident     12/02/2011 Please state how the fission barrier boundary integrity (core tank seal) is assumptions include no escape                ensured via an appropriate TS LCO.
29  of fission products from the core tank. Propose changes to 3.4.f for core tank seal integrity}}

Revision as of 20:23, 11 November 2019

Texas a & M University - Additional Clarification Requested Responses to NRC Request for Additional Information Dated July 25, 2011
ML12312A232
Person / Time
Site: Texas A&M University
Issue date: 12/06/2012
From: Geoffrey Wertz
Research and Test Reactors Licensing Branch
To: Hassan Y
Texas A&M Univ
Boyle, Patrick
References
TAC ME1588
Download: ML12312A232 (7)


Text

December 6, 2012 Dr. Yassin Hassan Department Head- Acting, Nuclear Engineering Texas A&M University 337 Zachry Engineering Center College Station, TX 77843-3133

SUBJECT:

TEXAS A & M UNIVERSITY - ADDITIONAL CLARIFICATION TO RESPONSES TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE TEXAS A & M UNIVERSITY AGN-201M RESEARCH REACTOR LICENSE RENEWAL (TAC NO. ME1588)

Dear Dr. Hassan:

The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-23 for the Texas A & M University AGN-201M Reactor dated July 22, 1997, (a redacted version of the safety analysis report is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System (ADAMS) Accession No. ML102790087). As part of our review, the NRC staff submitted requests for additional information (RAI) by letter dated July 25, 2011, (ADAMS Accession No. ML112000240).

The NRC staff has reviewed your responses and identified in the attached table those RAI responses needing additional clarification. Please provide your responses within 90 days of the date of this letter. In accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, Written Communications. Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding.

If you have any questions regarding this review, please contact Patrick Boyle at (301) 415-3936 or by electronic mail at Patrick.Boyle@nrc.gov.

Sincerely,

/JLising for RA/

Geoffrey Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-59

Enclosure:

As stated cc w/encl: See next page

Texas A&M University Docket No. 50-59 cc:

Mayor, City of College Station P.O. Box Drawer 9960 College Station, TX 77840-3575 Governors Budget and Planning Office P.O. Box 13561 Austin, TX 78711 Chris Crouch AGN-201M Reactor Supervisor Nuclear Engineering Department 129 Zachry Engineering Center College Station , TX 77843 Radiation Program Officer Bureau of Radiation Control Dept. Of State Health Services Division for Regulatory Services 1100 West 49th Street, MC 2828 Austin, TX 78756-3189 Technical Advisor Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML12312A232 *via email TEMPLATE # NRR-088 OFFICE PRLB:NE PRLB:PM* PRLB:LA PRLB:ABC PRLB:PM NAME PBoyle GWertz GLappert PIsaac GWertz DATE 11/8/12 11/7/12 11/14 /12 12/6/12 12/6/12

OFFICE OF NUCLEAR REACTOR REGULATION ADDITIONAL CLARIFICATION ON RESPONSES FOR THE RENEWAL OF FACILITY OPERATING LICENSE TEXAS A & M UNIVERSITY AGN-201M RESEARCH REACTOR LICENSE NO. R-23 DOCKET NO. 50-59 The U.S. Nuclear Regulatory Commission (NRC) has reviewed your responses to our requests for additional information (RAIs) and has identified the following RAI responses that need additional clarification.

RAI RAI Original RAI Description Response Additional Clarification Needed No.

Date Please describe the hardware components and software associated with AGN computer discussed in Chapter 7 of the Safety Analysis Report (SAR). Include a discussion of what verification and validation was used for Describe the design criteria for 06 12/22/2011 the design and installation. Identify which reactor scram signals are the console upgrade.

generated by the AGN computer and which ones are hardwired directly to the scram circuit. Describe the design elements addressing the potential for a single failure disabling multiple scram inputs.

Please explain why the Limiting Conditions for Operation (LCO) for a scram Limiting Condition of Operation was proposed for section 3.4, Radiation Monitoring, Control, and Shielding 07 for the skirt radiation monitor 12/02/2011 instead of section 3.2 Control and Safety Systems which contains a listing scram.

of all of the other scram inputs Channel #2 Period Scram Please explain how the computer calculates the period and how frequently 08 design impact from the AGN 04/12/2012 this is compared to the trip set point. Explain the safety impact of using a computer computer for this function compared to the previously installed rate meter.

ENCLOSURE

RAI RAI Original RAI Description Response Additional Clarification Needed No.

Date Describe how the AGN computer takes the signal from the picoammeter and generates a scram signal based on the output of the Channel #3 detector. How often is the signal compared to the set point and what Channel #3 Linear Power Scram processors are involved? What is the cumulative effect of the delay 09 design impact from the console 04/12/2012 associated with each step between an increase (or decrease for low power upgrade trip) in the detector output and initiation of a scram signal including processor delays associated with the other processor demands on the AGN computer? Explain what digital filtering is used and how this affects the overall response time.

Your statement that There was no Technical Specification (TS) requirement Reactor Control System does for this interlock feature is not consistent with the current wording TS 3.2.e, not show how the Interlock 11 12/22/2011 3.2.f and 3.2.g. Please explain how you are complying with the requirement Relay function was incorporated to have shield water level interlock, and shield water temperature into the upgrade.

interlock that will prevent a reactor start up and scram the reactor The proposed wording for LCO 3.2.k contains the word installed. It is not clear what is meant by the word installed. Please provide a definition for the word installed, to be included in section 1 or consider the use of a Incorporation of the watch-dog defined word such as operable or operating in the proposed LCO.

13 scram into the appropriate LCO 04/12/2012 and Chapter 13 update Please provide a safety analysis of the design change that discusses the AGN computer, its potential failure modes, and what features are relied upon to ensure operability (ability to perform its intended safety function).

Some of the survey locations indicate a dose rate greater than 10 milli-Roentgen Equivalent Man/hour (mrem/hr). What actions are being Radiation protection program implemented in these areas to ensure ALARA principles are considered?

and as low as reasonably The RAI response indicates three phantom monitors are present at the 14 08/25/2011 achievable ( ALARA) facility. What are these phantom monitors and how are they used? The RAI considerations response also indicated, facility personnel are supplied with dosimetry.

Who is considered to be facility personnel and what type of dosimetry is used?

RAI RAI Original RAI Description Response Additional Clarification Needed No.

Date The percentages of the 10 CFR Part 20 Appendix B Derived Air Concentration (DAC) and effluent release limits are provided in the RAI 15 Ar-41 production consideration 08/25/2011 responses which are based on a dose rate. Based on the maximum allowed operations, what annual dose does this represent to the occupational workers and to members of the public?

Are students allowed in the reactor room when the reactor is operating?

Personnel monitoring during 17 08/25/2011 What type of dosimetry is required for the students? Explain how this is experiment handling controlled (procedure, etc.).

Amendment 10 only considered one of the severe accidents (slow controlled excursion) 1% reactivity increase without the fuse melting. The original Evaluation of MHA related to 20 12/02/2011 MHA also consider a 2% step reactivity increase (runaway) with fuse melt.

occupational dose limits Please discuss why the 2% step reactivity increase MHA scenario was not considered in your analysis related to dose limits.

Add TS definitions per 12/02/2011 The proposed TS Section 1 definition for Reactor Shutdown (1.19) includes ANSI/ANS-15.1-2007 guidance a reference condition of $1.00. Please provide the relationship between 21 for: reactor secured, reactor $1.00 and the %k/k or propose wording for the definition of shutdown that shutdown, and shutdown is expressed in %k/k consistent with other TSs.

margin.

The proposed TS 3.2 and Table 12/02/2011 The previous console included interlocks for the Rod Drive Cable and Relay 3.1 do not include Interlock Chassis. Activation of these relays resulted in an automatic reactor scram.

Relay Scrams Please explain why these automatic scrams are no longer required including 24 a discussion of the safety impact of replacing these automatic scram functions with operator action.

RAI RAI Original RAI Description Response Additional Clarification Needed No.

Date TS 3.2.g states that a seismic 12/02/2011 Per TS 4.2.h - The shield tank water level interlock, shield water displacement interlock switch temperature interlock and seismic displacement safety channel shall be shall be installed. This requires tested by perturbing the sensing element to the appropriate set point. These a set point. tests shall be performed annually, but at intervals not to exceed 16 months.

25 The reply indicates the switch cannot be calibrated because of its design.

Please explain how Texas A&M is in compliance with TS 4.2.h if the set point cannot be verified. Additionally, please justify the use of this interlock.

Maximum Hypothetical Accident 12/02/2011 Please state how the fission barrier boundary integrity (core tank seal) is assumptions include no escape ensured via an appropriate TS LCO.

29 of fission products from the core tank. Propose changes to 3.4.f for core tank seal integrity