ML20126B809

Forwards Updated Tech Specs,Independent of Upcoming Conversion to LEU Fuel,In Response to Request for Addl Info

ML20126B809
Person / Time
Site:	University of Virginia
Issue date:	12/14/1992
From:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:	Alexander Adams Office of Nuclear Reactor Regulation
Shared Package
ML20126B813	List: ML20126B809 ML20126B814
References
NUDOCS 9212220216
Download: ML20126B809 (3)

Text

l WH001. UI' n l ENGINEERING 21 l December 14, 1992 k /\PPLIED SCIENCE l Mr. Alexander Adams, Jr. M l?Utlu M C m R I X H./ W l Senior Project Manager [[ I Non-Power Reactors, Decommissioning

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and Environmental Project Directorate Un""* "I V"Phb Division of Reactor Projects - III/IV/V ( I"' I""""" Y^ 2 2

• 2" 2 Office of Nuclear Reactor Regulation Now94n i As wuw9n United States Nuclear Regulatory Commission Was).ington, D.C. 20555

Subject:

Reply to Requests for Additional Information (RAI), regarding TS amendments unrelated to Low Enriched Uranium (LEU) fuel conversion, from the University of Virginia Reactor Facility [ Reactor Docket Nos.

50-62 and 50-396).

Dear Mr. Adams:

Please find in attachment those updated UVAR Technical Specification (TS) proposed amendments which are independent of the upconing conversion to LEU fuel. You are being provided with a clean copy of the TS, as well as a copy marked with bars in the margins, or red underlines, to indicate areas of wording change in comparison with the current (HEU) TS. Where necessary in these copies, pages which contain LEU-related TS have been substituted with blank pages Jabeled " LEU Related TS." Also in attachment, please find a reference which provides a detailed justification for all TS amendments being proposed. These changes are being requested under the normal license amendment process.

Some general observations are provided below.

With regard to definitions in TS 1.0, terms common to both the UVAR TS and the ANS 15.1 standard have been standardized, as you had suggested.

Additional definitions which appear in the UVAR TS were taken from sections of ANS 15.1 other than its definitions section, or were retained from the current UVAR TS. As you requested, a definition for trace quantity has been added. This definition is justified by a table (see enclosures) which lists typical U and Th trace concentration levels in materials which could be irradiated in the UVAR without adverse consequence. It is noted that TS 3.7 places requirements on those fueled experiments in which the thermal power generated would be greater than one watt. Hence, no special requirements for materials with greater than trace quantities but generating less than one Watt of power are necessary.

You are correct in pointing out that the proper term in basis 1 of TS 3.1 is " highest worth shim rod" and not " highest worth control rod."

This has been corrected in the present submittal. In TS 3. 6 (8 ) the word "any" which had been omitted in the retyping of the original TS has been reinserted, so no change is involved here. Also, in TS 3.6(10) the typographical error which you found has been corrected and the word

" safe" substituted for " safety."

9212220216 PDR ADOCK h2 PDR /

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(Cover letter to TS amendment submittal, page 2, cont.)

References previously made to the LEU Safety Analysis Report (SAR) in

the bases accompanying recently proposed TS 4.7 and 4.8 have been deleted. Because the LEU SAR includes sections taken from th* present i High Enriched Uranium (HEU) SAR, the references to the " LEU" were

correct but unnecessary. Since these TS are not related to the HEU to 2

LEU fuel conversion, removal of the references can be made without detriment and thus prevent a possibic misperception that these TS are fuel conversion related. As you requested, TS 4.8 (and not "3.8", as mistyped in the RAI) will remain in the TS, although reworded to take into account an interim period following the conversion order when HEU j may still be present at the Reactor Facility. Since this reworded TS l will become part of the conversion order it is not presented in this package. Because TS 4.8 is retained, changes to TS 4.9 proposed by us l in a previous version of TS will not necessary.

l Section 6 of the UVAR TS has been reformatted to match the other TS

, sections in appearance. I would like to call your attention to recent substantial changes made in this section. In TS 6.1.1., the department i name has been updated to account for the merger of the Department of Nuclear Engineering with that of Mechanical and Aerospace. TS 6.1.4.,

I a now subsection on selection and training of reactor operators, has i

been added with basis in ANSI /ANS 15.1.. A substantial change has teen made to the wording in TS 6.2 and Figure 6.1 in regards to the new

. reporting structure for the Reactor Safety Committee. (The detailed bases for the reporting change is in the enclosure explaining the requested amendments.). Former TS 6.6 has been renumbered as a new TS 6.7, former TS 6.% has been renumbered as TS 6.6, and a new section on

, review and approval of experiments has been created and numbered TS 6.4.

i Your observation in the November 19 RAI that in our previous TS 6.4.2 submittal, a reference to TS 6.7 had been changed to TS 6.6 to correct a typographical error in the current TS is right. This reference been 4

updated a third time to correspond to the latest TS numeration scheme.

Please bear with the confusion that these renumeration changes can lead to, proposed TS 6.5.1 has been reworded to take into account ANS Standard 15.1's " normal plant operation records" term. To answer your RAI question specifically, records of UVAR poolwater quality and addition are not required to be listed in the reactor logbook. Water quality is tracked on daily checklists, and water makeup is recorded in a water makeup logbook. Both records are kept as permanent records. The following operations are documented in the reactor logbook:- all manipulations in and out of the reactor, including fuel and experiment manipulations; reactor startups; power operation; shutdowns; unusual

, events; and a list of unplanned shutdowns. Irradiations of experiments are noted briefly in the logbook, but the detailed records are kept in the irradiation request form (IRF) logs.

As requested, NRC addresses for reporting purposes have been updated in Section 6.6. Note has . also been taken of recent changes to 10 CFR 3 20.403, as reported in the NMSS (NRC) Licensee Newsletter of Sept.1992.

i

J l

4 i

a

] (Cover letter to TS amendment submittal, page 3, cont.)

l It is requested that these TS amendments, which are not related to fuel ,

! conversion, be made effective on the date the conversion-related TS, '

j submitted under separate cover, become offective. This simultaneity is necessary to take into account the extensive updating that has been made

in the Technical Specifications, involving TS reformatting, renumbering i and repagination.

~; I Thank you for your very helpful comments which have enabled us to update and upgrade the UVAR TS.

l J

^

Sincerely,X i\ :-

QUAN~

Ifobert U. Mulder, Director

! U.Va. Reactor Facility I

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i I C u p uw. n , vi bM*f -

oy.ma caun of weinh I bc reby certify that the attaded document is a true and ru:,1 copy of a. _lfj ___

- presented tefore ow. . uw, me this 1 day of bl(' ,19 $ h _,

' by ...... , ,...Nu...l...._Dh_b.m,lWm .

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I onc: Non-LEU TS Amendments

, Justification for proposed Non-LEU TS Amendments

! Table listing typical U and Th trace-level concentrations i

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