ML14121A546

Reed College - Request for Additional Information Regarding Amendment to the Technical Specifications for the Reed Research Reactor

ML14121A546
Person / Time
Site:	Reed College
Issue date:	05/16/2014
From:	Geoffrey Wertz Research and Test Reactors Licensing Branch
To:	Krahenbuhl M Reed College
Watford M
References
TAC MF1928
Download: ML14121A546 (6)

Text

May 16, 2014 Dr. Melinda Krahenbuhl, Director The Reed Research Reactor Reed College 3203 SE Woodstock Blvd.

Portland, OR 97202-8199

SUBJECT:

REED COLLEGE - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE AMENDMENT TO THE TECHNICAL SPECIFICATIONS FOR THE REED RESEARCH REACTOR (TAC NO. MF1928)

Dear Dr. Krahenbuhl:

By letter dated May 24, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13149A016), as supplemented by letter dated February 12, 2014 (ADAMS Accession No. ML14055A403), Reed College (the licensee) requested an amendment to the Technical Specifications (TSs), Appendix A, of Facility Operating License No. R-112, for the Reed Research Reactor.

The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in your application, as supplemented, and determined that additional information is required in order to complete its review. Please provide responses to the enclosed request for additional information within 30 days after the date of this letter. Additionally, for each proposed change to the TSs, include a basis (i.e., as to why the change is necessary) and a justification (i.e., why the change is acceptable, e.g. by referencing an applicable guidance document such as NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors).

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 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. Information related to security should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information:

Performance requirements. Following receipt of the additional information, we will continue our evaluation of your license amendment request.

M. Krahenbuhl If you have any questions or need additional time to respond to this request, please contact me at 301-415-0893 or by electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely,

/Alexander Adams for RA/

Geoffrey Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-288 License No. R-112

Enclosure:

Request for Additional Information cc: See next page

Reed College Docket No. 50-288 cc:

Mayor of the City of Portland 1220 Southwest 5th Avenue Portland, OR 97204 Reed College ATTN: Dr. Nigel Nicholson, Dean of Faculty 3203 SE Woodstock Boulevard Portland, OR 97202-8199 Reed College ATTN: Mr. John Kroger, President 3203 SE Woodstock Boulevard Portland, OR 97202-8199 Division Administrator Nuclear Safety Division Oregon Department of Energy 625 Marion Street NE Salem, OR 97301-3737 Program Director Radiation Protection Services Public Health Division Oregon Health Authority 800 NE Oregon Street, Suite 640 Portland, OR 97232-2162 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML14121A546 NRR-088 OFFICE NRR/DPR/PRLB/PM NRR/DPR/PRLB/LA NRR/DPR/PRLB/PM NRR/DPR/PRLB/BC NAME MWatford PBlechman (AAdams for) GWertz AAdams DATE 05/09/2014 05/06/2014 05/16/2014 05/16/2014 REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT TO THE TECHNICAL SPECIFICATIONS FOR REED COLLEGE REED RESEARCH REACTOR DOCKET NO. 50-288 LICENSE NO. R-112 By letter dated May 24, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13149A016), as supplemented by letter dated February 12, 2014 (ADAMS Accession No. ML14055A403), Reed College (the licensee) requested an amendment to the Technical Specifications (TSs), Appendix A, of Facility Operating License No. R-112, for the Reed Research Reactor (RRR).

The U.S. Nuclear Regulatory Commission (NRC) staffs review used the guidance in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, and supporting information from the American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors. During our review, the following questions have arisen which require responses:

1. ANSI/ANS-15.1-2007, Section 6.1.2, Responsibility, states that Responsibility for the safe operation of the reactor facility shall be with the chain of command established in Fig. 1. In the proposed RRR TS 6.1.1, Figure 1, Administrative Structure, the Level 3 staffing includes Reactor Operations Manager and Supervisor.

a. Proposed RRR TS 6.1.2, Specification c, only includes the title Reactor Operations Manager. Please indicate if the Level 3 title in proposed RRR TS 6.1.2, Specification c, should also include Supervisor to match the Level 3 staffing in proposed RRR TS 6.1.1, Figure 1, or justify the current description.

b. Proposed RRR TS 6.1.2, Specification c, states that the Level 3 staffing includes Supervisors, implying more than one Supervisor. Please indicate if the Level 3 position in proposed RRR TS 6.1.1, Figure 1, should say Supervisors to match proposed RRR TS 6.1.2, Specification c, or justify the current discrepancy.

2. In the proposed RRR TS 6.1.1, Figure 1, Administrative Structure, Level 4 staffing includes Operating Staff. However, in the proposed RRR TS 6.1.2, Responsibility, Specification d, uses the title Operations Staff - Reactor Operators and Senior Reactor Operators. Please indicate if the Level 4 title in the proposed RRR TS 6.1.2, Specification d, should say Operating Staff to match proposed RRR TS 6.1.1, Figure 1, or justify the current description.

Enclosure

3. In the current RRR TS 6.6.1, Actions to Be Taken in Case of Safety Limit Violation, Specification b, says [a]n immediate notification of the occurrence shall be made to the Director, the Chair of the ROC, the NRC, and the President of Reed College.

Part of this statement conflicts with the requirement stated in RRR TS 6.7.2, Special Reports, Specification a, which states that the Director shall send a report not later than the following working day by telephone and confirmed in writing by facsimile to the NRC Operations Center. Please indicate if the NRC should be removed from RRR TS 6.6.1, Specification b, or justify the current description.

4. In the current RRR TS 6.2.3, ROC Review Function, Specification a, states, in part, that the Reactor Operations Committee (ROC) shall [r]eview changes made under 10 CFR 50.59. NUREG-1537 provides guidance that the review should include the determinations that the proposed changes were allowed without prior NRC approval.

However, TS 6.2.3, Specification a, does not include this determination. Provide justification for TS 6.2.3, Specification a, or revise to include the review guidance for proposed changes consistent with the guidance in NUREG-1537.

5. In the current RRR TS 6.4, Procedures, states, in part, that [o]perating procedures shall be in effect but does not indicate if the procedures are required to be used and followed. Provide justification for TS 6.4, or revise to include guidance for that the procedures shall be used.

6. Various references in the current RRR TSs refer to the NRC. For clarity, these references should indicate if the reference is:

a. the Document Control Desk, U.S. NRC, Washington, DC; or,

b. the U.S. NRC Headquarters Operations Center.

7. The current RRR TS 6.8.2 states, in part, that records shall be retained at all times the individual is employed. However, if the individual were to leave the facility employment, there is no requirement to retain the record, and thus, no opportunity for NRC review. Propose a revision to TS 6.8.2 such that the records shall be retained for at least one complete requalification cycle, and maintained at all times the individual is employed, or justify the controls established to ensure that the NRC will have the ability to review retraining and requalification records for all licensed reactor operators and senior reactor operators.

Enclosure