ML072900027

Worcester Poly Technical Institute - Request for Additional Information Amendment Amendment Request for Possession of the Worcester Poly Technical Institute Reactor

ML072900027
Person / Time
Site:	05000134
Issue date:	10/22/2007
From:	Alexander Adams NRC/NRR/ADRO/DPR/RTRBA
To:	Curley M Worcester Polytechnic Institute
ADAMS A, NRC/NRR/ADRA/DPR/PRTA 415-1127
References
TAC MD6410
Download: ML072900027 (6)

Text

October 22, 2007 Mr. Michael J. Curley, Reactor Director Worcester Polytechnic Institute Office of the Vice President for Finance and Operations 100 Institute Road Worcester, MA 01609-2280

SUBJECT:

WORCESTER POLYTECHNIC INSTITUTE C REQUEST FOR ADDITIONAL INFORMATION RE: AMENDMENT REQUEST FOR POSSESSION OF THE WORCESTER POLYTECHNIC INSTITUTE REACTOR (TAC NO. MD6410)

Dear Mr. Curley:

We are continuing our review of your amendment request for Facility Operating License No. R-61 for the Worcester Polytechnic Institute Reactor which you submitted on August 13, 2007. During our review of your amendment request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your amendment request.

Please note that the review of your request for changes to the requalification program is being conducted separately from your request for license amendment. Any questions concerning your proposed changes to the requalification program will be provided by separate letter.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely,

/RA/

Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-134

Enclosure:

As stated cc: See next page

Worcester Polytechnic Institute Docket No. 50-134 cc:

City Manager City Hall 455 Main Street, Room 309 Worcester, MA 01608 Dr. John A. Orr Provost ad interim and Dean of Undergraduate Studies Office of Academic Affairs Worcester Polytechnic Institute 100 Institute Road Worcester, MA 01609 Frank Diliado III, District Chief Worcester Fire Department Worcester, MA 02180 Department of Environmental Protection One Winter Street Boston, MA 02180 Director Radiation Control Program Department of Public Health 90 Washington Street Dorchester, MA 02121 Nuclear Preparedness Manager Massachusetts Emergency Management Agency 40 Worcester Road Framingham, MA 01702-5399 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML072900027 OFFICE PRTA:LA PRTA:PM PRTA:SC NAME CHart for EHylton AAdams aa DCollins dsc DATE 10/19/07 10/22/07 10/22/07 REQUEST FOR ADDITIONAL INFORMATION WORCESTER POLYTECHNIC INSTITUTE REACTOR DOCKET NO. 50-134 The purpose of the following question is to determine the status of your application for license renewal.

1. On November 25, 2002, WPI applied for renewal of Facility Operating License No. R-61 which was scheduled to expire on December 30, 2002. Because your renewal application satisfied the requirements of 10 CFR 2.109, Effect of Timely Renewal Application, by letter dated December 13, 2002, we informed you that the license is not deemed to have expired until your application has been finally determined. With your decision to permanently shut down the reactor and terminate the license, your application for renewal no longer needs to be acted upon. Please confirm that you no longer want to pursue license renewal and that you withdraw your application for license renewal. Note that in accordance with 10 CFR 50.51(b), your license continues in effect until the Commission notifies you in writing that the license is terminated.

The purpose of the following question is to determine compliance with 10 CFR 50.82(b).

2. Your application for license amendment states that there will be no alteration or dismantling of the reactor facility that could affect the ability to monitor and contain radioactivity, or which provides a protective function. It is not clear what this means in relation to decommissioning and dismantling activities. Please confirm that no dismantling or decommissioning activities will occur before a license amendment is issued approving a decommissioning plan.

The purpose of the following question is to determine compliance with requirements of your facility license.

3. Your application discusses changes to license condition 2.B.(2). However, the license condition you quote was amended in 1988 during conversion of the reactor to low-enriched uranium fuel. Please propose and justify changes to the current wording of license condition 2.B.(2).

The purpose of the following questions is to determine compliance with 10 CFR 50.36.

4. License condition 2.D and 2.E duplicate (with minor differences in wording) the requirements of TS 5.6 and 6.7(1). Current practice is to have administrative requirements in the TSs. Please propose elimination of these license conditions or provide justification as to why these duplicate license conditions need to remain in the license.

5. Please provide replacement TS pages that reflect your proposed TS changes.

6. Please define the abbreviations used in your proposed definition of Readily Available on Call. Is the expanded list of positions meeting the definition of Readily Available on

Call consistent with the positions that can serve as emergency director per the facility emergency plan? If not, what purpose does having positions not able to serve as emergency director in the definition of readily available on call serve?

7. You have proposed the elimination of many TS requirements. While your application contains a general discussion of the justification of your proposed changes, please provide specific justification of why the eliminated TSs are no longer needed.

8. You have proposed having the TS on water purity and surveillance of that quality only apply when fuel is in the reactor pool. Discuss the need to control water purity to control corrosion of remaining activated and contaminated components and structures after the fuel is removed but while water remains in the pool.

9. Please provide a basis for your proposed water level and water temperature TSs and why these TSs can be eliminated once fuel is removed from the facility. The TS on radiation levels is based in part on controlling radiation levels 1 m above the pool surface. If all water is removed from the reactor pool, how will radiation levels be controlled (Also see TS 3.3)? Is a TS needed for radiation levels once all water is removed from the pool? If so, please propose and justify a TS.

10. There does not appear to be a TS requirement for calibration of radiation area monitors in your proposed TSs. Please propose a surveillance requirement or discuss why this requirement is not needed.

11. TS 4.2 refers to 10 CFR 20.105. This regulation no longer exists. Please update this TS with reference to the current 10 CFR Part 20.

12. TS 4.5.2, 4.5.3, and 4.5.4. Given the fact that the reactor will not operate again and that the fuel has been removed from the reactor grid plate to storage, are these TSs required for safe possession of the reactor? If not, provide justification for eliminating these TSs.

13. Your proposed changes to TS 5.1 and 5.2 include having the Facility Director report to the Provost and having the Provost (along with the President) appoint members of the Radiation, Health, and Safeguards Committee. Please describe the Provosts position in the Institute. Does the Provost have the same level of authority and responsibility (as related to the reactor) as the Dean of Faculty and the Vice President that the Provost is replacing? If not, explain how the level of authority and responsibility of the Provost is sufficient for the possession-only status of the reactor.

14. TS 5.4 refers to unreviewed safety questions. Amendments to 10 CFR 50.59 have eliminated this terminology from the regulation. Please propose changes to this TS to be consistent with 10 CFR 50.59.

15. TS 5.7 refers to the Division of Reactor Projects-III/IV/V & Special Projects (DRSP). The organizational replacement for DRSP is the Division of Waste Management and Environmental Protection (DWMED) in the Office of Federal and State Materials

and Environmental Management Programs. Please propose updates to your TSs to reflect the current NRC organization.

16. TS 5.8(1)(e) and 5.8(5). The regulations in 10 CFR 50.59 have been updated such that the reference to 10 CFR 50.59(a) is outdated. Please propose changes to the TS to reflect the current wording of 10 CFR 50.59.

17. Please discuss the movement of fuel from the storage racks to the shipping cask. Will movements be performed using procedures that meet the requirements of TS 5.5?

Discuss how criticality safety will be maintained during fuel movement. Your proposed TS refers to the fuel movement process being overseen by the SRO and RSO. Please discuss the duties that the SRO and RSO will perform.