ML13246A014

Request for Renewal of Facility Operating License R-129

ML13246A014
Person / Time
Site:	University of Texas at Austin
Issue date:	08/21/2013
From:	Whaley P M University of Texas at Austin
To:	Boyle P G Document Control Desk, Division of Policy and Rulemaking
References
TAC ME7694
Download: ML13246A014 (32)

Text

Department oC Mechanical EngineeringV THE UNIVERSITY OF TEXAS A" AUSTIN-' Nuclear Enginieering "lhaching Laboratory -Austin, Texas 78758512-232-5370 -.,FAX512-4714-4589 h- p.'llwww.rne.utexas.eda/-netl/08/21/2013ATTN: Document Control Desk,U.S. Nuclear Regulatory Commission,Washington, DC 20555-0001Patrick G. BoyleNuclear EngineerNRR/DPR/PRLBSUBJECT: Docket No. 50-602, Request for Renewal of Facility Operating License R-129REF: UNIVERSITY OF TEXAS AT AUSTIN -REQUEST FOR ADDITIONAL INFORMATION REGARDING THELICENSE RENEWAL REQUEST FOR THE NUCLEAR ENGINEERING TEACHING LABORATORY TRIGAMARK II NUCLEAR RESEARCH REACTOR (TAC NO. ME7694)Sir:Attached is a partial response to the Request for Additional Information referenced above, including:* RAI 4* RAI 5* RAI 16.2* RAI 17 (in 2 parts)* RAI 25* RAI 30" RAI 32.1" RAI 32.2* RAI 35.7" RAI 35.8* RAI 36.2* RAI 36.4* RAI 40.1* RAI 40.3* RAI 40.5* RAI 40.6* RAI 40.7k f~

If there are any questions, please feel free to contact P. M. Whaley at 512 232 5373 orwhaley@mail.utexas.edu.Your attention in this matter is greatly appreciated,P. M. Whaley /I declare under penalty of perjury that the foregoing is true and correct.S. BiegalskiATT: RAI RESPONSES RAI 16.2The coolant flow rates cited in UT SAR Table 5-1 for the tubes and shell side of the primary coolant heat exchangerappear to be in error. Please confirm and revise accordingly.RESPONSEThe shell and tube flow rate values for Table 5-1 appear to have been inadvertently transposed, and will bechanged to indicate:Flow Rate (shell)Flow Rate (tubes)400 gpm (25.2 Ips)250 gpm (15.8 Ips)

RAI 17 (a)The guidance in NUREG-1537 Section 5.2, "Primary Coolant System," requests that the licensee provideinformation regarding the coolant system control and safety instrumentation, including the location and functionsof sensors and instruments; the SCRAM or interlock functions that prevent exceeding the safety limits should beshown and discussed. UT SAR Section 5.3.4 provides a summary of the control system, but does not includeinformation on the pool low-level scram setpoint referred to in UT SAR, Section 13.6.2 and the UT TRIGA TS 3.4,Table 2....RESPONSESection 5.3.4 Control System will be revised to add information and structure as indicated:a. Level gageA metric scale is used to provide local indication of pool level. With the 23.5 cm mark secured to the tankequipment monitoring ring, 8 cm corresponds to 8.10 meters above the floor of the pool. Pool level is normallymaintained at 8.10 + 0.05 m, corresponding to an indicated 8 +/- 5 cm.b. Level Control FunctionsPool level is monitored by 5 float switches using sealed relays on two separate assemblies. Two level switches areadjusted to alarm if water level is 5 cm above or 10 cm below the nominal value (8.15 or 8.05 m above the poolfloor, 8.8 or 7.5 cm gage level). Two level switches are adjusted to provide a reactor trip initiation if water levelfalls to 7.79 m above the pool floor, 30 cm below normal pool level. One level switch is adjusted below the reactortrip switches to alarm at a remote 24-hour response station.c. Temperature Control(Followed by the information currently in the draft Safety Analysis Report.)

RAI 17, Part 2:The guidance in NUREG-1537 Section 5.2, "Primary Coolant System," requests that the licenseeprovide information regarding the coolant system control and safety instrumentation, includingthe location and functions of sensors and instruments; the SCRAM or interlock functions thatprevent exceeding the safety limits should be shown and discussed...In addition, it does notdescribe actions that are needed, or should be taken, should pressure at the chilled water outletrise above the pressure at the pool inlet to the heat exchanger. Please confirm and reviseaccordingly.RESPONSE:Section 3.8.3 specifies:D The pressure difference between chilled water outlet from the pool heat exchanger and poolwater inlet SHALL NOT be less than 7 kPa (1 psig)Section 3.8.4 specifies:D.1 ENSURE the reactor is D.1 IMMEDIATESHUTDOWNORD. The pressure difference D.2 Verify pressure differential is D.2 IMMEDIATEbetween chilled water outlet greater than 7 kPa (1 psig)from the pool heatexchanger and pool water ORinlet is less than 7 kPa (1 D.3 IMMEDIATEpsig) D.3 RESTORE pressure difference togreater than 7 kPa (1 psig)ORD.4 Isolate chill waterD.4 IMMEDIATE"Actions that are needed, or should be taken, should pressure at the chilled water outlet rise above the pressure atthe pool inlet to the heat exchanger" are to (1) ensure the reactor is shutdown or (2) one of the following (a) verifydifferential pressure is greater than 7 kPa (1 psig), (b) restore the pressure difference to greater than 7 kPa (1 psig),or (c) isolate the chill water.The basis states, "The specified pressure difference assures that any postulated heat exchanger leakage will notrelease potentially contaminated water to the chill water system." If a limiting condition for operation cannot bemet, the reactor should be shutdown. It is possible that the differential pressure channel is not operating properly,and actual differential pressure is adequate to me the specification. If it can be verified that actual pressure isadequate, operations may continue. If differential pressure does not meet the specification but can be restored,operation contingent on restoration is acceptable. If the pressure differential does not meet the specification andcannot be restored, isolation of the chill water system from the heat exchanger will prevent flow from the poolwater system into the chill water system.

RAI 25:The guidance in NUREG-1537 Section 11.1.5, "Radiation Exposure Control and Dosimetry," requests that thelicensee consider of all groups (including embryos and fetuses, declared pregnant women, minors, and students)when establishing dose limits. The UT SAR does not mention these groups, or whether they were considered inestablishing dose limits. Please confirm that these considerations are included in your radiation protectionprocedures or elsewhere.RESPONSE:While ALARA has always been applied to doses to all groups, an exposure limit for special categories of radiationworkers (declared pregnant workers, minors, etc.) was not explicitly stated in the NETL ALARA program. A revisedversion of the NETL ALARA program has been drafted and will be submitted to the Reactor Oversight Committeefor approval stating that for special categories of radiation workers (declared pregnant workers, minors, etc.), thedose limit will be established on a case-by-case basis by the NETL Director with concurrence from the HP.

RAI 30The guidance in NUREG-1537 Section 13.1.6, "Experiment Malfunction," requests that the licensee provide analysisof an experiment malfunction event. UT SAR, Section 13.8.2.C includes an analysis of fueled experiment fissionproduct inventory to estimate the allowable limit on production of iodine and strontium in an experiment basedon a 2-hour DAC limit; the analysis uses fission yield data from uranium-235. Please clarify the source of theactivation materials for producing iodine, and identify actions needed if it is not 231U. In addition, please show thatthe limits for the iodine and strontium are less than the values that could be released in an MHA and the doses tothe public from such releases are within the 10 CFR Part 20 limits.RESPONSEThis RAI is addressed in 2 parts. Fission product isotopes of interest are first considered, then neutron activatedmaterials. In both cases, the derived air concentrations of 10CFR20 appendix B is identified for each element ofinterest, then the activity that (if released into the reactor bay, volume of 4.12E9 ml) would result in 1000 DAC iscalculated. Finally, the maximum potential exposure associated with a postulated release is calculated using CAP-88.FISSION PRODUCT ISOTOPES OF INTERESTFission products of interest include radioactive strontium and iodine. The results of calculations for fueledexperiments are provided in Table 1.Table 1, Maximum Potential Dose Outside Reactor Bay from Fueled ExperimentsFueled Exp. Bay Activity Max. DoseIsotope Limit Max. Dose DAC (1000 DAC) (1000 DAC)tCi mrem/yr ICi/ml PCi mrem/yrSr-90 (D) 93500 2.65 8E-09 32960 0.93416Sr-90 (Y) 93500 2.65 2E-09 8240 0.233541-131 932000 0.414 2E-08 82400 0.0366031-132 932000 0.00509 0.000003 12360000 0.0675031-132m 932000 0.00142 0.000004 16480000 0.0251091-133 932000 0.0452 1E-07 412000 0.0199811-134 932000 0.00461 0.00002 82400000 0.4075791-135 932000 0.0137 7E-07 2884000 0.042394NEUTRON ACTIVATED MATERIALSNeutron activation products with the potential to exist in a vapor form (e.g., noble gases, low vaporpressure, and sublimation potential at near atmospheric pressure) were identified. The maximumpotential dose associated with potentially gaseous activation products is provided in Table 2, with the exceptionthat materials with a half-life too short to be included in CAP-88 calculations are not included.

Table 2: Maximum Potential Dose from Release ofVolatile Material (at 1000 DAC in the Reactor Bay)Isotope DACjiCi/mlH-3 0.00002F-18 1E-07CI-36 0.000001CI-38 0.00002Ar-37 1Ar-39 0.0002Ar-41 0.000003Ga-70 0.00008Ga-72 0.000001As-74 3E-07As-76 6E-07As-77 0.000002Se-75 3E-07Se-77m 1E-07Se-81 0.0001Se-81m 0.00003Se-83 0.00005Br-80 0.00009Br-80m 0.000007Br-82 0.000002Kr-85m 0.00002Kr-87 0.000005Kr-88 0.000002Rb-86 3E-07Rb-88 0.00003Xe-125 0.00002Xe-127 0.00001Xe-129m 0.0002Xe-131m 0.0004Xe-133 0.0001Xe-133m 0.0001Xe-135 0.00001Xe-135m 0.000009Xe-138 0.000004Hg-197 0.000006Hg-197m 0.000004Hg-199m 0.00007Hg-203 5E-07Bay ActivityPCi824000004120004120000824000004.12E+128.24E+08123600003.3E+08412000012360002472000824000012360004120004.12E+081.24E+082.06E+083.71E+082884000082400008240000020600000824000012360001.24E+0882400000412000008.24E+081.65E+094.12E+084.12E+0841200000370800001648000024720000164800002.88E+082060000Max. Dosemrem/yr0.04980.0009843230.25900.003993.04E-050.05130.1430.7320.02890.0362.5800.0370.02610.7990.07010.02790.001010.02340.0320.03650.3410.1512.810.01960.03180.02430.02320.02240.01910.02050.03661.151.030.5590.156 Of the materials analyzed, only chlorine 36 has the potential to exceed the 100 mrem/yr exposure limitfor routine non-occupational exposure or the 10 mrem/yr limit on routine effluents. Neutron activationis calculated by:A = 0 .N -.(l-e-"')Where A is the specific activity, b is the neutron flux, N is the number density of the target material, ais the cross section, and A is the decay constant. Defining KC as total activity, VC135 as the volume of thetarget material, and using the standard mass/atomic weight relationship:AMU : VC135jVc13 (1 -e -A,)orKC AMUm 0 .(1 -e-"') NAFor an activity that would result in 1000 times the C136 DAC (4.12E6 QCi), neutron flux approximately1E13 n/cm2-s, cross section of approximately 60 barns, the number of target chlorine 35 atoms requiredto achieve the 1000 DAC value (where t is the irradiation interval) is:(4.12 Ci)(3.7x1010 Bq)(cn2 s)(AMU) = 4.22x10-4/(1 -eAt)(Ci)(1013 n)(60x1o_24 cn2)(1-e_1t)(6.023x1O23)The decay constant (2) is 0.693/t%; the denominator of the equation is on the order of 1E-8 for valuesless than about 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. Therefore the mass of C135 required to achieve 1000 DAC is on the order of42 kg. The 100 mrem/yr exposure limit for routine operations can be met if the target mass is reducedto 31%, on the order of 13 kg. The annual limit of 10 mrem/yr from routine effluents can be met if thetarget mass is reduced to 3.1%, or 1.3 kg. The chemical reactivity, physical form, and half-life of chlorine36 (3E5.years) render generation of C136 quantities that are capable of challenging exposure limitsvirtually impossible.Since there is no realistic mechanism to generate a quantity of C136 that could challenge limits, a singlespecified value of 1000 DAC is preferred (rather than noting the exception) to provide simple and clearguidance.TRIGA fuel elements are specifically exempted from consideration in experimental limits, and thisanalysis does not rely on or impact the maximum hypothetical accident (TRIGA fuel element failure).

RAI 32.132. The "Interim Staff Guidance for the Streamlined Research Reactor License Renewal Process," (ISG)identifies ANSI/ANS-15.1-2007 and the corresponding regulatory positions in NUREG-1537, Appendix 14.1are the guidance documents for the review of technical specifications. The guidance in ANSI/ANS-15.1-2007 Section 1.3, "Definitions," recommends definitions commonly used in Research and Test Reactor TS.The TS definitions noted below were either missing, were not consistent with guidance, or were lackingrecommended details. (Note: capitalization for this sequence of RAIs follows the style of the proposed UTTRIGA TS.)32.1 The proposed UT TRIGA TS definitions section 1.0 does not describe definitions for: coreconfiguration; license; licensee; protective action; reactivity worth of an experiment; reactoroperator; reactor operating; responsible authority; safety limit; scram time; senior reactoroperator; shall/should/may definitions (only the definition for "shall" is provided); true value;unscheduled shutdown. Please provide definitions for the above or provide justification for notusing them.RESPONSEThe following terms are not used at all: Responsible Authority, Scram time, Should, True Value, and UnscheduledShutdown. In the absence of the term "Should," May is unambiguous.The following terms are not used in specification statements, but are unambiguous and understood In context:Core Configuration, Reactor Operating, and Protective Action. In addition, protective action is used in a genericsense, and includes reactor safety system response as well as actions for protection of personnel.License and licensee have more than one 10CFR20 definition, and are understood in context.Reactivity worth of an experiment is unambiguous and understood in context.Safety Limit is an explicit section of the Technical Specifications, and has specific statements and requirementsrelated to the section.As per a recent proposed Technical Speciation change, reactor operator and senior reactor operator are currentlybeing changed to the terminology of 10CFR55. Since operators are trained to 10CFR55 the terms should be wellunderstood, and "certified" is not a correct term.

RAI 32.232. The "Interim Staff Guidance for the Streamlined Research Reactor License Renewal Process," (ISG)identifies ANSI/ANS-15.1-2007 and the corresponding regulatory positions in NUREG-1537, Appendix 14.1are the guidance documents for the review of technical specifications. The guidance in ANSI/ANS-15.1-2007 Section 1.3, "Definitions," recommends definitions commonly used in Research and Test Reactor TS.The TS definitions noted below were either missing, were not consistent with guidance, or were lackingrecommended details. (Note: capitalization for this sequence of RAIs follows the style of the proposed UTTRIGA TS.)32.2 The following definitions are not consistent with the guidance: channel calibration, excessreactivity; experiment; confinement; movable experiment; secured experiment. Please reviseaccordingly or provide justification for the deviations.RESPONSE1. channel calibrationANSI/ANS-15.1-2007 defines:channel calibration: A channel calibration is an adjustment of the channel such that its output correspondswith acceptable accuracy to known values of the parameter that the channel measures. Calibration shallencompass the entire channel, including equipment actuations, alarm, or trip, and shall be deemed toinclude a channel test.The original proposed definition is:Channel CalibrationChannel calibration is an adjustment of the channel such that its output corresponds with acceptableaccuracy to known values of the parameter which the channel measures. Calibration shall encompass theentire channel, including equipment actuation, alarm, or trip and shall be deemed to include a channeltest.The defined term is taken verbatim from the current approved Technical Specifications. Since this wasacceptable in the current (approved) Technical Specifications, it remains unchanged.Differences between the approved definition and ANSI standard include (1) avoiding multiple uses of theword "that", deletion of "s" for parallel construction, and deletion of a comma. This is an editorialdifference, and does not change the meaning of the definition in any way.On further consideration, the second sentence will be split into two sentences for clarity in asecond editorial change that does not change the meaning of the definition in any way, so that thedefinition will be:Channel CalibrationChannel calibration is an adjustment of the channel such that its output corresponds with acceptableaccuracy to known values of the parameter which the channel measures. Calibration shall encompass the entire channel, including equipment actuation, alarm, or trip. Calibration shall be deemed to include achannel test.1. excess reactivityANSI/ANS-15.I-2007 defines:Excess reactivity: Excess reactivity is that amount of reactivity that would exist if all reactivity controldevices were moved to the maximum reactivity condition form the point where the reactor is exactlycritical (keff =1) at reference core conditions or at a specified set of conditions.The original proposed definition is:Reactivity, ExcessExcess reactivity is that amount of reactivity that would exist if all the control rods were moved to themaximum reactive condition from the point where the reactor is exactly critical.The defined term is taken verbatim from the current approved Technical Specifications. Since this wasacceptable in the current (approved) Technical Specifications, it remains unchanged.The last phrase of the ANSI definition ("or at a specified set of conditions") requires additional informationto have an unambiguous meaning. Since "reactivity control devices" at the UT TRIGA are "control rods,"and since "exactly critical" does not need amplification, the equivalent and unambiguous definition is lessambiguous than, but otherwise explicitly agrees with, the ANSI definition.2. experiment:ANSI/ANS-15.1-2007 defines:experiment: any operation, hardware, or target (excluding devices such as detectors, foils, etc.) that isdesigned to investigate nonroutine reactor characteristics or that is intended for irradiation within thepool, or on or in a beam port or irradiation facility. Hardware rigidly secured to the core or shield structureso as to be part of its design to carry out experiments is not normally considered an experiment.The original proposed definition is:ExperimentAny operation, component, or target (excluding devices such as detectors, foils, etc.), which is designed toinvestigate non-routine reactor characteristics or which is intended for irradiation within the pool, on or ina beam tube or irradiation facility and which is not rigidly secured to a core or shield structure so as to bepart of their design.The defined term is taken verbatim from the current approved Technical Specifications. Since this wasacceptable in the current (approved) Technical Specifications, it remains unchanged.The meaning of the word "hardware" in the ANSI standard definition is not as well defined as when thestandard was developed; "component" as used in the approved definition is more descriptive. However, the definition is still difficult to read; after further consideration, the definition will be edited in a way thatdoes not alter the meaning to:ExperimentAny operation, component, or target (excluding devices such as detectors, foils, etc) that is:(1) designed to investigate non-routine reactor characteristics, or intended for irradiation within thepool, on or in a beam tube or irradiation facility; and(3) not rigidly secured to a core or shield structure so as to be part of the core or shield structuredesign.3. confinement:ANSI/ANS-15.1-2007 defines:confinement: Confinement is on enclosure of the overall facility that is designed to limit the release ofeffluents between the enclosure and its external environment through controlled or defined pathwaysThe proposed definition is equivalent:ConfinementConfinement means an enclosure on the overallfacility which controls the movement of air into it and outthrough a controlled path.The defined term is taken verbatim from the current approved Technical Specifications. Since this wasacceptable in the current (approved) Technical Specifications, it remains unchanged.4. moveable experiment:ANSI/ANS-15.1-2007 defines:moveable experiment: A moveable experiment is one where it is intended that all or part of the experimentmay be moved in or near the core or into and out of the reactor while the reactor is operatingThe proposed definition:Experiment, MoveableA moveable experiment is one where it is intended that all or part of the experiment may be moved in ornear the core or into and out of the reactor while the reactor is operating.The defined term is taken verbatim from the current approved Technical Specifications. Since this wasacceptable in the current (approved) Technical Specifications, it remains unchanged.In comparison to the ANSI standard, the defined term is changed from "moveable experiment" to"experiment, moveable" in the current approved Technical Specifications in order to place the definition alphabetically near the definition of "experiment." Since this was acceptable in the current (approved)Technical Specifications, it remains unchanged.5. secured experimentANSI/ANS-15.1-2007 defines:secured experiment: A secured experiment is any experiment, experimental apparatus, or component of anexperiment that is held in a stationary position relative to the reactor by mechanical means. Therestraining force must be substantially greater than those to which the experiment might be subjected byhydraulic, pneumatic, buoyant, or other forces that are normal to the operating environment of theexperiment, or by forces which can arise as a result of credible malfunctions.The proposed definition:Experiment, SecuredA secured experiment is any experiment, experiment facility, or component of an experiment that is held ina stationary position relative to the reactor by mechanical means. The restraining force must besubstantially greater than those to which the experiment might be subjected by hydraulic, pneumatic,buoyant, or other forces which are normal to the operating environment of the experiment, or by forceswhich can arise as a result of credible conditions.The defined term is taken verbatim from the current approved Technical Specifications. Since this wasacceptable in the current (approved) Technical Specifications, it remains unchanged.In comparison to the ANSI standard, the defined term was changed from "secured experiment" to"experiment, secured" for the currently approved Technical Specifications in order to place the definitionalphabetically near the definition of "experiment." Since this was acceptable in the current (approved)Technical Specifications, it remains unchanged.

RAI 35.7 Section 3.3 of the guidance describes specifications for leak or loss of coolant detection and a secondarycoolant activity limit. No such specifications are found in the proposed UT TRIGA TS.RESPONSE:The chill water subsystem for the pool cooling system as described in the Safety analysis Report is protected fromradioactive contamination by:1. System design, which maintains chill water pressure greater than pool water pressure so that anypotential leakage will be from chill water to pool water, and2. Automatic closure of a pneumatic valve if differential pressure drops to 2 psid, and3. Control room alarms if differential pressure falls to 5 psidThe alarm and valve actuation are functionally tested prior to each startup. A pool- to chill- water leak wouldrequire multiple failures of the heat exchanger, heat exchanger design, and associated automatic controls as wellas personnel failure to respond to an abnormal condition. A primary to secondary leak is not credible for the UTreactor.

RAI 35.8 Section 3.8.2 of the regulatory interpretations states that containers for experiments containingknown explosive materials shall be designed such that the design pressure of the container istwice the pressure the experiment can potentially produce. Proposed UT TRIGA TS 3.6"Limitations on Experiments," does not include such a specification.RESPONSE:The 13.8.2, D provides analysis for over pressure from explosives in a standard capsule used at the UT TRIGAreactor. Experiment design specification (5.4.3, part 9) will be revised to:9. Use of explosive solid or liquid material with a National Fire Protection Association Reactivity(Stability) index of 2, 3, or 4 in the reactor pool or biological shieldinga. SHALL NOT exceed the equivalent of 25 milligrams of TNT without prior NRC approval.b. SHALL be irradiated in a container capable of withstanding twice the pressure the experimentcan potentially produce.

RAI 36: ANSI/ANS-15.1-2007 Section 3, "Limiting conditions for operations," requests that the licensee provideLCOs for constraints and operational characteristics that shall be adhered to during operation. The ISGstates that the applicable TSs should explain why the TSs, including their bases, are acceptable. Thefollowing deficiencies and differences are noted with the proposed UT TRIGA LCOs: Please confirm andrevise accordingly, or explain why such changes are not necessary.36.2 The setpoint stated for condition B for Specification B in proposed UT TRIGA TS 3.3, "MeasuringChannels," is stated as 2mW. However, the neutron count rate should be stated in terms of-neutrons per unit time.RESPONSE3.3.3 Specifications will be revised to state:A The MEASURING CHANNELS specified in TABLE 1 SHALL be OPERATINGB The startup channel indicates greater than 2 mWAnd the basis will be revised to include:Experience has shown that subcritical multiplication with the neutron source used in the reactor does notprovide enough neutron flux to correspond to an indicated power level of 2x10y7 %. Therefore an indicatedpower of 2xl0-7 % (or 2 mW) or more indicates operating in a potential critical condition, and at least oneneutron channel is required with sensitivity at a neutron flux level corresponding to reactor power levelsless than 2x10-7 % ("Startup Channel"). If the indicated neutron level is less than the minimum sensitivityf for the channel, a neutron source will be used to determine that the channels is responding to neutrons toensure that the channel is functioning prior to startup.

RAI 36: The guidance in ANSI/ANS-15.1-2007 Section 3, "Limiting conditions for operations," provides guidanceand recommendations for the specifications pertaining to the limiting conditions for operation (LCO). Thisguidance is supplemented by NUREG-1537 Appendix 14.1. Some deficiencies and differences with theproposed UT TRIGA TS are described below. Please discuss these deficiencies and differences and reviseaccordingly.36.4: Proposed UT TRIGA TS 3.4 Table 2 does not provided the scram setpoints for the Reactor PowerLevel, Fuel Temperature, and Pool Water Level SAFETY SYSTEM CHANNELS.RESPONSETable 2 will be revised as:TABLE 2: REQUIRED SAFETY SYSTEM CHANNELSMinimum Function OPERATING ModeSafety System Channel Number Setpoint/Applicabilityor Interlock Operable STEADY STATE PULSEMODE MODEReactor power level 2 Scram 1.1 MW NAManual scram bar 1 Scram YES YESFuel Temperature 1 Scram 550°C 550°CPool water level 1 Scram YES YESCONTROL ROD Prevent withdrawal of(STANDARD) position 1 standard rods in the NA YESinterlock PULSE MODEPrevent inadvertentPulse rod interlock['] 1 pulsing while in YES NASTEADY STATE MODE RAI 4The guidance in NUREG-1537 Section 4.2.5, "Core Support Structure," requests that the licensee provide designinformation pertaining to the core support structure. UT SAR Section 4.2.5 provides some information, but doesnot address suitability for continued use. Please confirm whether there is any visual evidence of cracking,corrosion, or deformation of the core support structure, and state whether the structure is appropriate forcontinued use for the operating period being requested.RAI 5The guidance in NUREG-1537 Section 4.3, "Reactor Tank or Pool," requests that the licensee provide a descriptionof the reactor tank and associated components including how those components will perform their intendedfunctions to prevent possible leakage associated with chemical interactions, penetration, and weld failures. TheUT SAR does not provide sufficient information. Please confirm whether there is any visual evidence of cracking,corrosion, or deformation of the reactor pool liner, connected pipes or beam ports and provide a discussion ofpreventative measures employed to monitor and maintain the integrity of the connected primary coolant systemover the life of the facility.RESPONSE(1) In 2004 the reactor reflector was replaced, using support by in-pool divers with helmet mounted cameras.Although not specifically acquired to inspect the pool and reflector stand, the extensive video providesevidence that there is no detectable degradation in the reflector stand or the pool. Four snapshots taken fromthe video are provided, strictly as a sample of available graphic information.

(2) There is no current visible evidence of cracking, corrosion or deformation of the core support structure or thereactor pool, connected pipes or beam ports.(3) Maintenance of conductivity minimizes potential corrosion (RAI 18).(4) Monitoring pool level provides a means to detect pool and pool cooling system leakage.

RAI 40.1ANSI/ANS-15.1-2007 Section 6.1 "Organization," recommends organizational structures including levels andreporting authority. UT TRIGA TS 6.1.1 "Structure," Figure 6.1, does not describe the organizational structure asdescribed in ANSI/ANS-15.1-2007, Section 6.1 "Organization."RESPONSELevels and reporting authority are represented on the organizational charts. A correlation between ANSI standardand UT structure will be incorporated in the basis.

RAI 40.3 Although the guidance of ANSI/ANS-15.1-2007 Section 6.1.3 "Staffing," have been included in proposedUT TRIGA TS 6.1.3 "Staffing," the following items are not consistent with the guidance:A designated senior reactor operator shall be readily available on call. "Readily Available onCall" means an individual who has been specifically designated and the designation known tothe operator on duty, can be rapidly contacted by phone, by the operator on duty.A list of reactor facility personnel by name and telephone number shall be readily available inthe control room for use by the operator. The list shall include (a) management personnel, (b)radiation safety personnel, (c) other operations personnel.Events requiring the presence at the facility of the senior reactor operator are (a) initial startupand approach to power, (b) all fuel or control-rod relocations within the reactor core region, (c)relocation of any experiment with reactivity worth greater than one dollar; (d) recovery fromunplanned or unscheduled shutdown or significant power reduction.RESPONSEThe proposed Technical Specifications includes a definition for INITIAL STARTUP:INITIAL STARTUPA reactor startup and approach to power following:1 Modifications to reactor safety or control rod drive systems,2 Fuel element or control rod relocations or installations within the reactorcore region,3 Relocation or installation of any experiment in the core region with areactivity worth of greater than one dollar, or4 Recovery from an unscheduled (a) shutdown or (b) significant powerreductions.The proposed specification for staffing (section 6.1.3) includes:Whenever the reactor is not secured, the reactor shall be (1) under the direction of or (2) directly operatedby a (USNRC licensed) Senior Operator, designated as Reactor Supervisor. The Supervisor may be on call ifcognizant of reactor operations and capable of arriving at the facility within thirty minutes.The specification statement from section 6.1.3 referenced above will be revised to:1. Replace "on call" with "capable of being rapidly contacted by phone by the operator on duty," and2. Add "The Supervisor will be present at the facility for any INITIAL STARTUP."The statement "Names and telephone numbers of reactor facility management personnel, radiationsafety personnel, other operations personnel shall be listed in the control room for use by the operator"will be added to section 6.1.3.

RAI 40.5 ANSI/ANS-15.1-2007 Section 6.4 "Procedures," recommends that procedures be written for surveillancechecks, calibrations, and inspections required by the TS or those that may have an effect on reactorsafety.RESPONSEThe proposed Technical Specifications section 6.3 requires written procedures for:a. Startup, operation, and shutdown of the reactorb. Fuel loading, unloading, and movement within the reactor.c. Control rod removal or replacement.d. Routine maintenance, testing, and calibration of control rod drives and other systems that couldhave an effect on reactor safety.e. Administrative controls for operations, maintenance, conduct of experiments, and conduct oftours of the Reactor Facility.f. Implementing procedures for the Emergency Plan or Physical Security Plan.and:a. Personnel radiation protection, in accordance with the Radiation Protection Program as indicatedin Chapter 11b. Administrative controls for operations and maintenancec. Administrative controls for the conduct of irradiations and experiments that could affect coresafety or reactivityThe currently approved proposed Technical Specifications section 6.3 explicitly incorporates the ANSIrecommendations for written procedures, and the proposed specifications will be revised to:a. Startup, operation, and shutdown of the reactor.b. Fuel loading, unloading and movement in the reactor.c. Routine maintenance of major components of systems that could have an effect on reactorsafety.d. Surveillance calibrations and tests required by the technical specifications or those that couldhave an effect on reactor safety.e. Administrative controls for operation, maintenance and the conduct of experiments orirradiations that could have an effect on reactor safety.f. Personnel radiation protection, consistent with applicable regulations or guidelines, and shallinclude a management commitment and programs to maintain exposures and releases as low asreasonably achievable.g. Implementation of required plans such as the emergency plan or physical security plan.

RAI 40.6 ANSI/ANS-15.1-2007 Section 6.7.2(1) "Special reports," specifies facsimile or similar conveyance of thespecial report. Proposed UT TRIGA TS 6.8(c) specifies telegraph of similar conveyance.RESPONSEThe referenced part is:The SAFETY LIMIT violation shall be reported to the Nuclear Regulatory Commission within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> bytelephone, confirmed via written statement by email, fax or telegraphThe Merriam-Webster online dictionary defines FAX as synonymous with FACSIMILE.

RAI 40.7 ANSI/ANS-15.1-2007 Section 6.8 "Records," provides recommendations for record retention. Section6.8.2 recommends an administrative control that retraining and requalification records for operators beretained for at least one certification cycle (per 10 CFR 55.55(a) this period is 6 years) and be maintainedat all times the individual is employed or until the certification is renewed. The proposed UT TRIGA TS6.10 is not consistent with this guidanceRESPONSE1OCFR55(a)5 states:Records. The requalification program documentation must include the following:(i) The facility licensee shall maintain records documenting the participation of each licensed operator andsenior operator in the requalification program. The records must contain copies of written examinationsadministered, the answers given by the licensee, and the results of evaluations and documentation ofoperating tests and of any additional training administered in areas in which an operator or senioroperator has exhibited deficiencies. The facility licensee shall retain these records until the operator's orsenior operator's license is renewed.The regulation explicitly addresses licenses that will be renewed, and does not address record retention followingtermination of licenses. Paragraph § 55.55 (Expiration) states:(a) Each operator license and senior operator license expires six years after the date of issuance, upontermination of employment with the facility licensee, or upon determination by the facility licensee thatthe licensed individual no longer needs to maintain a license.Therefore the proposed Technical Specification will be revised to:One License CycleThe facility licensee shall maintain records documenting the participation of each licensed operator andsenior operator in the requalification program. The records must contain copies of written examinationsadministered, the answers given by the licensee, and the results of evaluations and documentation ofoperating tests and of any additional training administered in areas in which an operator or senioroperator has exhibited deficiencies. The facility licensee shall retain these records until the operator's orsenior operator's license is renewed, expired, or terminated.

UT-Austin, License RenewalJune 25, 2012 RAIResponse StatusCommentNot submitted when plannedNot submitted when plannedrIltdbt: Ut~bUlUe LIM I iit:IIVUb Ubet: tU1 bWOaUy bWLU ICUUUIiIt IktMdUY-ýWLW OllU Nil IC-~.) OaU LIE I 101-YUIO-UI Ott-y-land include comparisons with UT TRIGA measurements that demonstrate that those methods are appropriate toanalyze the limits imposed by the UT TRIGA TS.partial responsepartial responsePartially acceptable for the 1992 and LCC, but OC ismissingPartially acceptable for the 1992 and LCC, but OC ismissing8.3 Please provide the technical parameters including analysis of "reactor kinetic behavior, basis reactor criticality, controlrod worth, definition of the limiting core configuration (LCC), [etc.]" (NUREG-1 537, Section 4.5.1). State whether thecomparison of calculated and measured values demonstrates acceptable model development.9 The GA-4361 unit cell parameters are displayed and compared with UT TRIGA core parameters. Please provide thetechnical parameters that are applicable to UT TRIGA.10 Given the difference between the "Reference" and 'Current" values of excess reactivity and shutdown margin, whichvalues are being used in the UT TRIGA TS.11.1 Please describe any limits or conditions on the evaluation of excess reactivity contributors, such as those due totemperature variations and poisons (e.g., xenon and samarium).Please provide calculations of full power reactivitydefects for power, xenon, and samarium.11.2 Please provide calculations for excess reactivity and control rod worths, and evaluate whether they are in agreementwith the analytical model and with UT TRIGA performance. Provide a discussion that describes the evaluation of thesecalculations to demonstrate acceptable reactor shutdown and shutdown margin. Include consideration of experimentreactivity12/19/2012 ML13002A015 P12/19/2012 ML13002A015 P11.3 Please provide "a transient analysis assuming that an instrumentation malfunction drives the most reactive control rodout in a continuous ramp mode," (NUREG-1537, Section 4.5.3) of the reactor using a rate of withdrawal consistent withproposed UT TRIGA TS values of the maximum control rod withdrawal speed, reactivity rate, and the control rod scramtime including uncertainties.NNot submitted when planned11 .4 Please provide all other applicable technical parameters, "excess reactivity, control rod worth, temperature coefficients,[etc.]" (NUREG-1 537, Section 4.5.3).1 of 7 UT-Austin, License RenewalJune 25, 2012 RAIResponse StatusRAt # Question13 Please confirm that the Bernath correlation is used to characterize DNBR for UT TRIGA, or demonstrate theapplicability of Biasi correlation to UT TRIGA analysis.14.1 Please provide clarification as to the relationship of the reactivity coefficient with the analysis provided in UT SARSection 4.6.14.2 The basis for TS 3.2 "Pulsed Mode Operation," states that the reactivity limits are established so as to meet fueltemperature limits. However, this is inconsistent with the statements in UT SAR Section 4.6 as described above. Pleaserevise the discussion in UT SAR Section 4.6 to support the UT TRIGA TS.14.3 UT SAR, Section 4.6 (p. 4-46) provides a series of statements regarding pulse reactivities and responses that are notsupported by analyses. Please provide analysis supporting these statements in sufficient detail so that a confirmatoryanalysis can be performed.15.1 Please describe the analytical methods used to determine the DNBR, including the core inlet and exit conditions[assumed and other assumptions and correlations employed. This [TRACE DNBR] analysis should describe theparameters determined from the LCC such as peaking factors and limiting coolant inlet temperature and that the inlettemperature used for DNBR is a limiting value by showing how it corresponds to the primary pool water temperaturemeasuring channel value.15.2 Please provide a comprehensive description of the calculational methods and the results thatdemonstrate the acceptability of design assumptions and TS for pulsing at UT TRIGA (e.g., the LCC, the approvedpower level, the pulse of reactivity inserted by the transient rod as allowed by TS, the value of the fuel temperaturecoefficient, the effective delaved neutron fraction, the Dromot neutron lifetime.Reply Date ADAMSAcceptCommentI Please provide a pH testing TS or provide a justification for not doing so.The licensee cites a correlation that determines effective release height above the building exhaust stack due to effluentmomentum from the purged air system or the ventilation system. Please confirm that the correct form of the correlationis AH = D (Vs/p)1 .4 and not as it is stated in the UT SAR.Not submitted when planned19.2 The licensee uses two different stack exit diameter values for the stack (0.4012 m2 on UT SAR, p. 9-6 and 45.72 cm onUT SAR p. 9-2). Please explain this discrepancy.19.3 Ensure the impact of the above changes on offsite doses for both normal operation and accident conditions areconsidered and revised accordingly.20.1 Please identify all locations covered by the license where fuel elements are stored, identify the types and numbers offuel elements that are stored, provide details concerning the storage rack or bin geometry, and analysis thatdemonstrates that such racks or bins provide adeauate conditions for storage.2 of 7 UT-Austin, License RenewalJune 25, 2012 RAIResponse StatusRA usinReply Date ADAMS Accept Comment22.2 Please provide the 4lr occupational xosr includingi stay timeis and theý effect of venitila3tion, and hoihscomIpare to, the limi1tsý of 10- CFR Part 20 and the co,,mmitmnents of the UTI TRIGA ALARA program.22.4 UTI SAR Section 11 .1. 1.1.2 provides a conservative estimate of offlsite, 41lAr air concentrations using an equation forground level concentration at the building center. Please provide a reference for the equation cited, and a discussion ofits suitability for providing dose calculations for members of the public and their location.22.5 Please provide a complete description of the maximally exposed individual calculation, including how the estimatescompare to the limits in 10 CFR Part 20 and the commitments of the UT TRIGA ALARA program.22.6 UT SAR Section 11.1.1.1.2 provides conservative dose estimates for the maximally exposed individual of 66 mrem peryear using the CAP88-PC computer code. UT TRIGA TS 3.5.3(D) indicates that releases of 41Ar from the reactor bayto an unrestricted environment SHALL NOT exceed 100 Ci per year, and provides CAP88-PC model results indicatingthat 100 Ci per year release of 41Ar would result in a maximally exposed individual dose of 0.142 mrem per year.Please resolve this discrepancy between the maximally exposed individual doses in the UT SAR and those provided inthe TS.22.7 UT SAR Section 11. 1.1.1.2 provides a discussion of the maximally exposed offsite individual, but does not providedoses to members of the public. Please provide a discussion of potential public doses.27 Please provide an ana eM A for the UT TRIGA including doses to the workers and to the individuals in thenon-restricted areas that bounds all other accident analyses. Please describe all assumptions, the operating conditionsof the HVAC system, and the sequence of events used in calculating the potential radiological consequences anddiscuss how those consequences are less than the applicable limits in 10 CFR Part 20. Please provide sufficient detailto allow independent onfirmation of these resultsh27.2.1 The [atmospheac dispersion] calculations are then performed for distances from 10 to 100 meters from the building.Because, the reactor building is both tall and wide, any re ease from the stack culd be accumulated in the buildingswake. Thereforesytea l e assumption of elevated release is appears inaccurate. Please justity the use ofthe elevated release values for dose estimates at nearby distances from the facility. 227.2.2 if there is an error in the correlation used for the plume rise (see RAt 19.1), the estimated plume rise above the stackheight may be inaccurate. Please confirm and revise accordingly.27.3 For the determination of effluent leakage around doors and HVAC duct vents the licensee employs complicateddiscussions and assumptions that are not supported or justified. Please revise the discussion and calculations usingapplicable assumptions for building overpressure.27.4 UT SAR page 3-7 states that the reactor bay is about 18.3 m on each side, with a total of 4575 m3 of volume. Thisleads to a wall cross section area of about 250 m2, which is in-line with the value of 234 m2 given in the originalapplication for licensing safety analysis report in 1991 (1991 SAR). Please confirm the building wall cross section areaand revise accordingly.27.5 For the offsite public dose calculations, in the UT SAR it does not appear consistent with the potential for groundrelease of the reactor bay air content, similar to that evaluated in the 1991 SAR27,6 UT SAR Appendix 13.1, SCALE 6.1 input file, cites an input value 1.6 for the weight fraction of the ZrH1.6U fuel. Is thisinput value for the weight fraction of hydrogen in the fuel? Please confirm and revise accordingly.28.1 It appears that the UT SAR does not provide sufficient information on the peaking factors and other assumptions usedto estimate the maximum fuel temperature rise as listed in UT SAR Tables 13.20 and 13.21. Please provide sufficientadditional information to allow confirmatory analysis.3of7 UT-Austin, License RenewalJune 25, 2012 RAIResponse StatusRAI # Question29.1 Please provide a LOCA analysis that represents the current licensed power level for the UT TRIGA in sufficient detail toallow confirmatory analysis.29.2 Please confirm that the LOCA analysis uses peaking factors that are consistent with the LCC and revise the analysisaccordingly.29.3 UT SAR Section 13.5.8 Resultsand Conusion,' states that the maximum fuel temperature in a LOCA event after"long-term operation at full power of 2000 kW is 750°C." Please provide the analysis that supports this temperature.Rel Date ADAMSAceptCommentlot submitted when planned32.3 Please revise to the following: when IMMEDIATELY is used as a COMPLETION TIME, The REQUIRED ACTIONshould be pursued without delay and in a controlled manner.32.4 The proposed UT TRIGA TS definition of REACTOR SHUTDOWN only requires the reactor to be subcritical by $0.29.Please explain the discrepancy in using the value of an abnormal condition (shutdown margin) for a normal condition,i.e., the definition of Reactor Shutdown.32.5 The proposed UT TRIGA TS definition of REACTOR SECURED MODE requires that 3 of the 4 control rods be fullyinserted. Please either provide analysis demonstrating the acceptability of the insertion of 3 out of 4 rods or revise thedefinition to require insertion of all 4 control rods in order to satisfy the requirements of this mode.33 The basis provided in support of the TS 2.1 references Chapter 4, Section'4.2.1 zwihich does not exist Please discussthis error and/or revise accordingly.34.1 The basis provided in support of the UT TRIGA TS 2.2 references Chapter 4 Section 4.6 B which does not exist. Please,,- 1A. .h.ii f-, +h. I 1J4. J35.1Section 3.1 of the guidance describes having specifications for fuel burnup, core configurations, and reactivitycoefficients (if such coefficients establish required conditions). Such specifications are not present in the proposed UTTRIGA TS Pease discuss.sufficient accuracy to justify this small value of the shutdown margin.35.4 Section 3.2 of the guidance describes that a limit be established for the maximumcontrol rod reactivity insertion rate for non-pulsed operation. The proposed UTTRIGA TS do not provide such a specification. This rate, and the control rod scram times, are typically justified throughthe analysis of an uncontrolled, control rod withdrawal transient.35.5 Section 3.2 of the guidance describes a specification for permitted bypassing ofchannels for checks, calibrations, maintenance, or measurements. Proposed UT TRIGA TS 3.3, 'Measuring Channels,"does not specify when it is permitted to bypass channels for checks, calibrations, maintenance or measurements35.6 Proposed UT TRIGA TS 4.3 'Measuring Channels,' contain Surveillance Requirements for the Fuel TemperatureChannel and the Upper Level Radiation Monitor. However, there are no associated LCO specifications.4 of 7 UT-Austin, License RenewalJune 25, 2012 RAIResponse StatusIRi# Qu n Rep e ADAMS A t Comment36.1 'The list of measuring channels presented in Table 1 of proposed UT TRIGA TS 3.3 'Measuring Channels," does notinclude the data acquisition and control (DAC) and control system computer (CSC) [watchdog] which are [is] listed as[a] SCRAM channels in UT SAR Table 4.6. Please revise or justify36.3 'The basis for propose UT TRIGA TS 3.3 contains a statement 'According to General Atomics, detector voltages less:than 80% of required operating value do not provide reliable ..." Please explain how this statement applies to UT TRIGAand how the required conditions for safe operation are ensured by your TS. Such information should be discussed in theSAR and then utilized in the TS basis.36A PrpsdLT TRIA TS3.4 Table2 dosntpoie h ca epit o h eco PowerLevel Fue36.5 Proposed UT TRIGA TS 3.5 "Gaseous Effluent Control," Specification A does not establish the conditions thatdetermine HVAC OPERABILITY (e.g., conditions or positions for the fans/louvers/doors); a basis statement is not:provided for the stated value of 10,000 cpm; such information should be discussed in the SAR and then utilized in theTS basis. Also, there are more COMPLETION TIMEs for Specification A than there are REQUIRED ACTIONs. Pleaseexplain or revise.36.6 Proposed UT TRIGA TS 3.5 'Gaseous Effluent Control," Specification B does not provide a basis statement for thestated limit of 10,000 cpm; such information should be discussed in the SAR and then utilized in the TS basis. Also, Ithere is a missing COMPLETION TIME for REQUIRED ACTION B.3.36.7 ProPosed UT TIRIGA TS 3.5, "Gaseous Effluent Contro1,' Specification D does not provide a basis statement for thestated limit of 100 Ci/yr; such information should be discussed in the SAR and then utilized in the TS basis.36.8 !The basis for the proposed UT TRIGA TS 3.7 'Fuel Integrity," does not provide an appropriate basis statement tosupport the limits in Specification C. Specification B is missing the word "not" in the REQUIRED ACTION. The secondoccurrence of CONDITION B should be CONDITION C,36.9 TS 3.8, "Reactor Pool Water" has no specification for maintaining an acceptable pH level.Question 37 series require review against ANS/ANSI 15.1-2007 section 3 to explain deviation or revise TS.37.1 Proposed UT TRIGA TS 3.2 "Pulsed Mode Operation," the COMPLETION TIME listed for the REQUIRED ACTION is"immediate." Please consider the COMPLETION TIME to be "prior to commencement of pulsing operation."37.2.1 CONDITION A.2 the lumping together of COMPLETION TIME(S) under A.2 is confusing as to which REQUIREDACTION must be completed first.37.2.2 The REQUIRED ACTION(S) A.1.1 and A.1.2 are, "Restore channel to operation OR ENSURE the reactor isSHUTDOWN.' The COMPLETION TIME is stated as Immediate for both REQUIRED ACTION(S). Please consider asequence of events (e.g., either restore the channel to operation within an acceptable COMPLETION TIME, ORshutdown).37.2.3 The COMPLETION TIME(S) for the REQUIRED ACTION(S) A.3.1 through A.3.3 are confusing in that no action isidentified to take precedence over another, potentially leaving the operator to make their own assumptions as to thepriority of events within one hour of any specified CONDITION.37.2.4 -CONDITION(S) A4 through A.7 state a series of REQUIRED ACTION(S) that are not sequentially linked. Use of thesame COMPLETION TIME for each action is contradictory.37.2.5 The REQUIRED ACTION(S) A.4.3 and A.4.4 seem to contradict each other.37.3:! Proposed UT TRIGA TS 3.4 'Safety Channel and Control Rod Operability," Specification B has no associatedREQUIRED ACTION(S) or COMPLETION TIME(S).37.4 Proposed UT TRIGA TS 3.5 'Gaseous Effluent Control," logical "AND/OR" connectors are missing betweenREQUIRED ACTION(S) C.2.a-C.2.b and C.2.b-C.2.c. COMPLETION TIME(S) are all listed as IMMEDIATE which iscontradictory. Please revise providing a clear sequence of the expected steps.5 of 7 UT-Austin, License RenewalJune 25, 2012 RAIResponse StatusRAI# Qmtton37.5 Proposed UT TRIGA TS 3.7 "Fuel Integrity," the COMPLETION TIME listed for all REQUIRED ACTION(S) isIMMEDIATE. Please consider revising the REQUIRED ACTION(S) for Specification A and B to state, "Discharge fuelelements prior to reactor operation."37.6.1 REQUIRED ACTION(S) A.1 through A.3 are in reverse order. The COMPLETION TIME(S) are all IMMEDIATE which iscontradictory.37.6.2 REQUIRED ACTION(S) B.1 and B.2 are in reverse order.37.6.3 REQUIRED ACTION(S) C.1 and C.2 are in reverse order. The COMPLETION TIME(S) are all IMMEDIATE which iscontradictory. Also, and the CONDITION seems to be improperly stated.37.6.4 REQUIRED ACTION(S) D.2 and D.3 are in reverse order. TheCOMPLETION TIME(S) are all IMMEDIATE which is contradictory. Abasis to support the established limits in Specification D is not provided. Such information should be discussed in theSAR and then utilized in the TS basis.38.1 There are no SRs for the DAC or CSC that are listed as SCRAM channels in UT SAR Table 4.6.38.21There are no SRs for the reactor bay differential pressure for CONDITION A.3 in proposed UT TRIGA TS 3.3"Measuring Channels."38.3 Proposed UT TRIGA TS 3.3 "Measuring Channels," contains Surveillance Requirements for the Fuel TemperatureChannel and the Upper Level Radiation Monitor but there are no associated LCO specifications38.4 There are no SRs for the Reactor Power Level scram, the Manual scram, or Fuel Temperature scram to supportproposed UT TRIGA TS 3.4 "Safety Channel and Control Rod Operability."38.5 There are no SRs to support proposed UT TRIGA TS 3.7 "Fuel Integrity," CONDITION C.39,1 Proposed UT TRIGA TS 5.1.3(1) allows fuel having a stoichiometry of 1.55 to 1.80 in hydrogen to be used in UTTRIGA.39,2 1) core parameters; 2) conditions for operation of the reactor with damaged or leaking fuel elements; 3) parameterssuch as maximum core loading, thermal characteristics, physics parameters, etc; and 4) fuel bum-up limits. Thesedesign features are not stated in the proposed UT TRIGA TS.39.3 Please provide a basis for meeting UT TRIGA TS 5.2 "Reactor Fuel and Fueled Devises in Storage," in recommendedbyANS Standard 15.1, Section 5.4.39A4 Proposed UT TRIGA TS 5.4 incorporates considerations for experiments into the design features section. Theseconsiderations do not meet the regulations of the definition for design features from 10 CFR 50.36.40.1 ANS/ANS-15.1-2007 Section 6.1 ," recommends tresra inrildig levels and reportngauthority. UT TRIGA TS 6.1.1 '$triucture," Figure 6.i1, doenot tdescribe the oraiainlstiuctire as described inANSVANS-15.1-2007, Section 6.1 *Organization.'40.2 individual or group that shall be assigned responsibility for implementing the radiation protection program using theguidelines of "Radiation Protection at Research Reactor Facilities," ANSI/ANS-1 5.11-1993 (R2004). This individual orgroup shall report to Level 1 or Level 2. The proposed UT TRIGA TS contains no such section.40.3 UT TRIGA TS 6.1,3"Staffing," the followng items are not consistent with the 40.4 ANSI/ANS-15.1-2007 Section 6.1.4 "Selection and training of personnel," recommends a section for ensuring that theselection and training of UT TRIGA staff is consistent with ANSI/ANS-15.4-1988. No such section is provided in the UTTRIGA TS.Riq* DtU ADAMS AcceptComment41 UT SAR does not provide a written statement whether U I is 'owned, controlled, or dominated, Dy an alien, toreigncorporation, or foreign government." Please provide a written statement that confirms or denies this status.42 UT's latest annual financial statements were not included in the UT SAR. Please provide a copy of UT's latest annualfinancial statements.43 Assuming review of this application is completed on schedule, and a renewed license granted in FY 2013, pleaseprovide the estimated operating costs for each of the FYs 2013 through FY2017.L6 of 7 UT-Austin, License RenewalJune 25, 2012 RAIResponse StatusRAI # QueonRpIy Date ADAMS Accpt Comment44.1 !A comparison of the UT TRIGA decommissioning cost estimate to more recently decommissioned research reactors ofsimilar licensed power limit as the UT TRIGA.44.2 decommissioning cost estimate for the UT TRIGA to meet the NRC's radiological release criteria for decommissioningthe facility, which should also include a contingency factor of at least 25 percent. A contingency factor providesreasonable assurance for unforeseen circumstances that could increase decommissioning costs44.3 Provide a calculation detailing how the rates in Table 15.3 "Escalation Costs." were derived.44.4 Provide a calculation showing how the escalation factors in Table 15.4 'Calculation Summary," were derived.45.1 Provide the following information: An updated SOl containing the decommissioning cost estimate in 2013 dollars, andthe name of the document(s) governing control of funds45.2 Provide the following information: Written documentation verifying that the signator of the Sol, Kevin P. Hegarty, VicePresident and Chief Financial Officer, is authorized to execute the SOl that binds UT financially.7 of 7