ML110240212
| ML110240212 | |
| Person / Time | |
|---|---|
| Site: | Rensselaer Polytechnic Institute |
| Issue date: | 01/31/2011 |
| From: | William Kennedy Research and Test Reactors Licensing Branch |
| To: | Sreepada S Rensselaer Polytechnic Institute |
| Kennedy W, NRR/DPR, 415-2784 | |
| References | |
| TAC ME1591 | |
| Download: ML110240212 (6) | |
Text
January 31, 2011 Prof. Sastry R Sreepada, Department of Mechanical, Aerospace and Nuclear Engineering, Building JEC- room 2032, Rensselaer Polytechnic Institute, 110 8th Street Troy, NY 12180-3590
SUBJECT:
RENSSELAER POLYTECHNIC INSTITUTE, REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL OF FACILITY OPERATING LICENSE NO. CX-22 (TAC NO. ME1591)
Dear Dr. Sreepada:
The U.S. Nuclear Regulatory Commission (NRC) is continuing the review of your application for renewal of Facility Operating License No. CX-22, Docket No. 50-225 for the Rensselaer Polytechnic Institute Critical Experiments Facility dated November 19, 2002, as supplemented by letters dated July 28, and September 3, 2008, and June 28, August 31, October 14, and October 28, 2010. During our review, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information by March 4, 2011. 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 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 security, 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.
If you have any questions regarding this review, please contact me at 301-415-2784 or by electronic mail at William.Kennedy@nrc.gov.
Sincerely,
/RA/
William B. Kennedy, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-225 License No. CX-22
Enclosure:
Request for Additional Information cc w/encl: See next page
Rensselaer Polytechnic Institute Docket No. 50-225 Reactor Critical Facility cc:
Mayor of the City of Schenectady Test, Research, and Training Schenectady, NY 12305 Reactor Newsletter University of Florida Tim Rice 202 Nuclear Sciences Center Chief, Radiation Section Gainesville, FL 32611 Division of Hazardous Waste and Radiation Management NY State Dept. of Environmental Conservation 625 Broadway Albany, NY 12233-7255 Peter F. Caracappa, Ph.D, CHP Radiation Safety Officer NES Building, Room 1-10, MANE Department Rensselaer Polytechnic Institute 110 8th St.
Troy, NY 12180-3590 Mrs. Jessica Berry, RCF Supervisor NES Building, Room 1-10, MANE Department Rensselaer Polytechnic Institute 110 8th St.
Troy, NY 12180 Peter Collopy, Director EH&S Rensselaer Polytechnic Institute 21 Union Street Gurley Building 2nd Floor Troy, NY 12180 Alyse Peterson, State Liaison Officer Designee Senior Project Manager Radioactive Waste Policy and Nuclear Coordination New York State Energy Research &
Development Authority 17 Columbia Circle Albany, NY 12203-6399
ML110240212 OFFICE PRLB:PM PRPB:LA PRLB:BC PRLB:PM WKennedy NAME WKennedy GLappert JQuichocho DATE 1/25/11 1/25/11 1/27/11 1/31/11
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING FACILITY OPERATING LICENSE RENEWAL FOR RENSSELAER POLYTECHNIC INSTITUTE CRITICAL EXPERIMENTS FACILITY LICENSE NO. CX-22 DOCKET NO. 50-225 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, contains the requirements for proposed technical specifications (TS) submitted as part of a license application. American National Standards Institute/American Nuclear Society standard ANSI/ANS-15.1, 2007, Development of Technical Specifications for Research Reactors, (ANSI/ANS-15.1) and NUREG-1537 (Part 1 and 2), Guidance for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, provide guidance for satisfying the requirements of 10 CFR 50.36.
The following requests for additional information (RAIs) are related to the proposed TS submitted by letter dated October 28, 2010, for the Rensselaer Polytechnic Institute (RPI)
Critical Experiments Facility (RCF). In responding to the following RAIs, provide a response to each individual RAI, including any revised wording of the proposed TS. Also, provide complete revised proposed TS that incorporate any changes made as a result of the responses to these requests.
- 1. Provide a title page for the TS that does not contain a signature line for approval by the Chair of the Nuclear Safety Review Board.
- 2. The regulation 10 CFR 50.54(k) requires a reactor operator (RO) or senior reactor operator (SRO) licensed pursuant to 10 CFR Part 55 to be present at the controls during operation of the RCF. Item 1.a of the staffing section of TS 6.1 appears to be consistent with the regulatory requirement in that it states, A RO or SRO licensed pursuant to 10 CFR 55 present at the controls. However, TS 1.3 defines a reactor operator as, An individual who is deemed capable and qualified by the SRO on duty to manipulate the controls of the reactor. This implies that the RO does not need to be licensed, but only deemed capable by the SRO on duty. Clarify whether the RO must be licensed pursuant to 10 CFR 55 and revise the proposed TS as appropriate.
- 3. The definition of shutdown margin states that, Shutdown margin is the minimum shutdown reactivity... with the most reactive rod in the most reactive position... TS 1.3 defines shutdown reactivity as, the reactivity of the reactor at ambient conditions with all control rods bottomed... Explain this apparent discrepancy and revise the proposed TS as appropriate.
ENCLOSURE
- 4. TS 3.1.1 states, The excess reactivity of the reactor above cold, critical shall not be greater than 0.60 $. TS 3.1.2 allows a net positive reactivity insertion of 0.15 $ due to a temperature increase from 50 degrees Fahrenheit (cold) to 100 degrees Fahrenheit.
Given that the definition of excess reactivity in TS 1.3 does not include reactivity effects due to temperature and TS 3.1.1 specifies that excess reactivity is relative to the cold core condition, explain how the net positive reactivity is treated when determining the excess reactivity.
- 5. The bases for TS 3.1 reference Section 4 of the Safety Analysis Report (1964), which appears to be out of date since the RCF converted to low enriched uranium fuel in 1987.
Update to the reference to refer to the applicable section(s) of the current safety analysis report, or justify retaining the reference to the 1964 Safety Analysis Report.
- 6. TS 3.2.2 states, There shall be a minimum of four operable control rods. Clarify when this specification must be met and revise the proposed TS as appropriate.
- 7. TS 3.2.2 states, The reactor shall be subcritical by more than 0.70 $ with the most reactive control rod fully withdrawn. Clarify whether this specification should refer to the shutdown margin (as defined in TS 1.3) and revise the proposed TS as appropriate.
- 8. TS 4.2.4 states that the interlock system shall be tested daily and after a secured shutdown. Clarify whether the terms tested and retested should be channel tested, and revise the proposed TS as appropriate.
- 9. The 2nd paragraph of the bases for TS 4.2 states that a check is sufficient to determine the operability of some of the safety systems. TS 4.2.4 requires a test of the safety systems. Clarify this apparent discrepancy and revise the proposed TS as appropriate.
- 10. TS 4.7 states, Portable instruments shall be calibrated annually, and Portable survey meters shall be calibrated at the manufacturers recommended frequency. Explain whether portable instruments are different from portable survey meters, or explain why there are two different surveillance intervals for the same portable equipment.
- 11. Section 4.3 of ANSI/ANS-15.4, 1988, Selection and Training of Personnel for Research Reactors, recommends that the facility director have at least a baccalaureate degree in science or engineering and at least six years of nuclear experience, with the degree fulfilling only four years of experience. TS 6.1 specifies the minimum qualification for the facility director as an advanced degree in nuclear science or nuclear engineering.
Explain the reason for not requiring the Facility Director to have any related experience in addition to the advanced degree in nuclear science or nuclear engineering, and revise the proposed TS as appropriate.
- 12. Section 6.2.2(2) of ANSI/ANS-15.1 recommends that, the operating staff (i.e., the Level 2 facility director or administrator and anyone who reports to that person), should not constitute the majority of a quorum. TS 6.2, specifies that the majority of a quorum shall not be composed of operating staff (administrative levels 3 and 4). Provide a justification for not including the Facility Director in the operating staff as it applies to quorums, or revise the proposed TS as appropriate.
- 13. TS 6.6.3 states that a safety limit violation shall be reported to the NRC in accordance with TS 6.8, Special Reports, Item 2. TS 6.8, Special Reports, Item 2 does not meet the reporting requirements of 10 CFR 50.36(c) for exceeding a safety limit. Clarify whether the reference in TS 6.6.3 should be to TS 6.8, Special Reports, Item 1 and correct the reference, or revise the proposed TS to meet the reporting requirements of 10 CFR 50.36(c) for exceeding a safety limit.
- 14. As we discussed during our telephone conversation of January 20, 2011, the following sections of the proposed TS appear to contain typographical and/or grammatical errors:
- a. Definition of Surveillance Frequency, Item 3
- c. TS 3.7, Bases, 3rd paragraph
- d. TS 4.2, Bases, 2nd paragraph
- e. TS 4.2, Bases, last paragraph
- f. TS 6.1, Responsibility, 1st paragraph, 3rd sentence
- g. TS 6.1, Staffing, Item 1.a
- h. TS 6.1, Staffing, Item 5
- i. TS 6.2, Review Function, Item 2
- j. TS 6.2, Review Function, Item 3
- k. TS 6.2, Audit Function, last sentence As appropriate, revise the proposed TS to correct any such errors.