ML20137P178

Responds to NRC Re Violations Noted in Insp Rept 50-199/96-01.Corrective Actions:Core Has Been Defueled W/ Elements Placed in Storage

ML20137P178
Person / Time
Site:	05000199
Issue date:	04/02/1997
From:	Duggan W MANHATTAN COLLEGE, RIVERDALE, NY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9704090158
Download: ML20137P178 (2)

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Manhattan College Parkway Riverdale, New York City, New York 10471-4098 (718) 862-7145 fax (718) 862-7163

{QLLEGE mechdept@ manhattan.edu Mechanical Engineering Departsncnl Computer-Alded Design Computer-Alded Alanufacturing

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• Ileating, Ventilating and Air Conditioning Nuclear Engineering April 2,1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Response to Apparent Violations in Inspection Report No. 50-199/96-01 Manhattan College Zero Power Reactor LICENSE: R-94 DOCKET: 50-199

Dear Sir:

This letter is in response to the NRC letter of January 23,1997 listing three apparent violations of NRC  !

requirements at the Manhattan College Zero Power Reactor (MCZPR). As discussed with the NRC Inspector and reficcted in the report, at the time of the inspection it was likely that the facility would be decommissioned in the ,

near future, a fate that was awaiting confirmation from the College Administration. The delay in submitting this response stems from waiting for a formal statement from the College that the facility would be decommissioned.

That intention has now been confirmed formally by the College President. However, in order to make the record 1 accurate and complete, the following responses are submitted regarding the apparent violations:

1. Violation 50-199/96-01-02  :

Exceeding allowable excess reactivity Reason: Physics testing of the (new) LEU core was proceeding in a sequential manner with determination of the critical rod positions and rod worth calculations being conducted. Two circumstances contributed to the  ;

condition noted in the report. First, the excess reactisity limit was developed for the (old)IIEU core, and it had been discussed with a previous NRC Inspector that the Technical Specifications would be revised to i reflect the new core characteristics after suitable measurements had been made. Second, the reactor 1 instrumentation was going to be upgraded, and after informal discussions with the NRC Inspector it was decided by reector staff that the measurements should be confimied by the new, more reliable instruments.

Ilowever, indications by the College that the facility would be decommissioned led to delays in installation of the new electronics.

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g' Steps taken: The core has been defueled, with the elements placed in storage. The rea:*or is therefore below  ;

the reactivity limit. g l if the reactor was not decommissioned, some fuel would be removed from the partial hI E Preventive Steps: fuel element and measurements taken to assure that the reactivity limit is met. . Alternatively, E future reactor staff may choose to apply for a modifcation of the technical specifications to allow i the higher excess reactivity. <

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Compliance: The facility has been in compliance with tlie limit since reactor defueling in December,1997.

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"2. ' fiolation 50-199/96-01-03 Exceeding maximum power level Reason: The power level of the MCZPR is determined by comparison of the neutron flux with a maximum as determined by an Uncompensted Ion Chamber. At no time did the indicated power level exceed the maximum level established for the previous core. The inspector refers to specific flux mapping and flux determination not taking place. However, using a general relationship of flux times macroscopic cross section shows that the maximum power could not be exceeded if the flux itself was kept below the limit. As a note, it is impossible for a 0.1 watt reactor to measure power by any means other than radiation levels, particularly not thermal means.

Steps taken: The reactor has not been operated since December,1997 when the core was defueled, with the elements plac-d in storage.

Preventive If the reactor is was not decommissioned, it would be necessary to calibrate the new instruments, which will include correlation of the reactor power and n utron flux measurements.

Compliance: The facility has been in compliance with the limit since reactor defueling in December,1997.

3. Violation 50-199/96-01-03 Non-measurement of control rod drop times Reason: At least one drop test was performed, but the readings from the oscilloscope not transferred to the appropriate log. The other periodic tests were not performed because of a misunderstanding of the required frequency (semi-annually versus annually).

Steps taken: The reactor was defueled in December,1996, in anticipation of decommissioning. The reactor will not be operated again.

Preventive: The reactcc will not be operated again, and the facility will start the decommissioning process by applying for a Possession Only License amendment. If the facility was to be restarted, recurrence would be avoided by updating the " tickler" list used to schedule the tests and surveillances.

Compliance: This surveillance was not performed afler the inspection in understanding the College's intention to s.at the reactor facility, it is my understanding that a separate staten.cnt of the College's intentions is being sent under separate cover.

It is the MCZPR stalf's intention to maintain the facility m a safe manner in accordance with regulations. The decommissioning process will be undertaken in a timely manner based on consultation with and approval by the Nuclear regulatory Commission.

Yours truly, c' jf William P. Duggan, PhD l Reactor Administrator l

ec: Region 1 Administrator, USNRC i

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