ML102710556

University of Maryland, Request for Additional Information Regarding the License Renewal for the Maryland University Training Reactor

ML102710556
Person / Time
Site:	University of Maryland
Issue date:	09/22/2010
From:	Al-Sheikhly M Univ of Maryland
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1592
Download: ML102710556 (10)

Text

~'UNIVERSITY OF 2101 Main Administration Building College Park, Maryland 20742 301.405.4945 TEL 301.314.9395 FAX OFFICE OF THE PRESIDENT September 22, 2010 Document Control Desk United States Nuclear Regulatory Commission Washington, D.C. 20555-0001

REFERENCE:

University of Maryland, Request for Additional Information Regarding the License Renewal for the Maryland University Training Reactor, Docket No. 50-166, License No. R-70 (TAC NO. ME 1592)

Enclosed please find responses to 41 of the 52 Requests for Additional Information (RAI) regarding technical specifications (TS) issued by the NRC to the University of Maryland on August 20, 2010.

Eleven responses or approximately 21% of the original 52 requests remain to be submitted.

As we agreed to do in our September 16, 2010 meeting, the University has assessed how much time it will need to prepare responses to the remaining eleven TS RAIs. Based on our assessment, we respectfully request an extension of time to December 1, 2010. If we complete any of the outstanding RAIs before that date, we will send them to you before December.

Other responses will likely require us to consult with General Atomics and will take much longer to complete, hence the requested extension to December 1, 2010.

We remind you the University previously requested by letter of August 27, 2010, an extension of time to November 15, 2010, to respond to Technical Request #2 issued by the NRC to the University on April 6, 2010. That response requires the assistance of General Atomics (GA).

Although GA has provided a preliminary response, we determined that it used an incorrect power level in its calculations and will have to update their preliminary response using the correct power level.

I greatly appreciate your consideration of this request.

I declare under penalty of perjury that the foregoing response is true and correct.

Sincerely, Mohamad A1-Sheikhly Professor and Director Maryland University Training Reactor Enclosure cc: Robert Briber, Gary Pertmer

. I OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION MARYLAND UNIVERSITY TRAINING REACTOR LICENSE NO. R-70: DOCKET NO. 50-166 We are continuing our review of the Application for Renewal of Facility Operating License No.

R-70, Docket No. 50-166 for the University of Maryland (UMD). The application was submitted on May 12, 2000, as supplemented by letter dated December 18, 2006, to include revised technical specifications (TS).

During our review of the revised proposed TS, questions have arisen for which we require additional information and clarification.

NUREG-1 537, Part 1, states that the format and content of the technical specifications (TSs) discussed in Appendix 14.1 follow the format of the 1990 revision of the American National Standards Institute/American Nuclear Society (ANSI/ANS)-1 5.1, "The Development of Technical Specifications for Research Reactors". The current version of the standard is dated 2007 (ANSI/ANS-15.1-2007). The basis for the questions below is the 2007 version of the standard with applicable modifications based on NUREG-1537.

1. TS 1.0. Definitions: ANSI/ANS-15.1-2007, Section 1 provides definitions for key terminology utilized in TSs. Please include definitions of Core Configuration, and Shall, Should, and May, in Maryland University Training Reactor (MUTR) TS 1.0 Definitions, or provide a basis for not defining these terms.

Definitions of Shall, Should, and May will be added to TS 1.0. The definition of core configuration in TS 1.0 will be changed to conform to the ANSI standard.

2. TS 1.0, Definitions: ANSI/ANS-1 5.1-2007, Section 1 defines key terminology. Please evaluate MUTR TS against the standard definitions in ANSI/ANS-1 5.1-2007 for the below listed TS items. Propose changes to meet ANSI/ANS-1 5.1-2007 or justify your definitions:

a. TS 1.1 - "in this part" should refer to "in 10 CFR Part 20" Wording in TS 1.1 will be changed from 'in this part' to 'in 10 CFR Part 20'.

b. TS 1.3 - if your confinement is designed to limit release of effluents, this needs to be included in your definition By controlling airflow, the MUTR confinement is designed to limit effluent release.

Wording in TS 1.3 will be changed to include this detail.

c. TS 1.4 - "reactivity control devices" should be replaced with control rods

Wording in TS 1.4 will be changed from 'reactivity control devices' to 'control rods'.

d. TS 1.8 - use either fuel element or fuel rod terminology consistently in the TSs The term 'fuel element' will be used in all technical specifications. Changes will be made as needed.

e. TS 1.22 - U. S. Nuclear Regulatory Commission (NRC) licenses operators, we do not certify operators, please update to reflect NRC terminology Wording in TS 1.22 will be changed from 'certified' to 'licensed by the NRC'

f. TS 1.24.d - replace "the maximum value allowed for a single experiment, or one dollar, whichever is smaller" with the smaller of the two reactivity values Wording in TS 1.2.4.d will be changed to indicate which of the two is smaller.

g. TS 1.25 - The NRC staff has proposed modifications to the definition for reactor shutdown given in ANSI/ANS-15.1-2007 as follows:

"The reactor is shut down if it is subcritical by at least one dollar in the reference core condition with the reactivity worth of all installed experiments included and the following conditions exist:

(a) No work is in progress involving core fuel, core structure, installed control rods, or control rod drives unless they are physically decoupled from the control rods; (b) No experiments are being moved or serviced that have, on movement, a reactivity worth exceeding the maximum value allowed for a single experiment, or one dollar, whichever is smaller."

Please adopt the NRC-modified definition or discuss why your proposed definition continues to be acceptable.

TS 1.25 will be changed to conform to the ANSI definition.

h. TS 1.27 - conform to Section 6.7.2(1)(c) of ANSI/ANS 15.1-2007; remove "which occurs during reactor operation."

The wording 'which occurs during reactor operation' will be deleted from TS 1.27.

TS 1.27(3) - remove "or periods of reactor shutdown"

'or periods of reactor shutdown' will be deleted from TS 1.27.3

j. TS 1.27(5) - change containment to confinement

'Containment' will be replaced with 'confinement' in TS 1 .27.5

k. TS 1.27(5) - remove "exceeding prescribed radiation exposure limits."

The phrase 'exceeding prescribed radiation exposure limits' will be deleted in TS 1.27.5 TS 1.28: The definition of Rod-Control should match what physically exists at the UMTR facility.

The words 'or fuel' will be deleted from the definition of rod control in TS 1.28

m. TS 1.34: NRC licenses operators, we do not certify operators, please update to reflect NRC terminology.

The word 'certified' will be changed to 'licensed by the NRC' in TS 1.34

4. TS 3.1.4: Please define fuel damage. ANSI/ANS-15.1-2007, Section 3.1(6) indicates that limits shall be established for fuel inspections. Please discuss how MUTR inspects fuel elements and under which conditions is fuel considered damaged.

Fuel damage will be defined as a clad defect that results in fission product release into the reactor coolant.

Routine fuel inspection has never been required. As a conversion TRIGA, fuel inspection would require disassembly of the four fuel element assembly.

5. TS 3.2: The applicability statement of the TS needs to be labeled. Minimum channels needed for operation appear to be missing from the TS. Please address. In Table 3.2 clarify the log power level and explain the interlock.

'APPLICABILITY' will be added above the first sentence in TS 3.2. A new table (Table 3.5) will be added which lists minimum channels required for operation. Minimum channels required for operation are listed in Table 3.1. In table 3.2, the 'function' description of the log power level will be changed to indicate the interlock functions of the channel.

6. TS 3.3: ANSI/ANS-15.1-2007, Section 3.3(9) indicates that limits shall be established for water chemistry requirements. MUTR TS 4.3.5 includes pH and conductivity values, which are considered LCO limits and should be moved to TS 3.3. Please discuss whether the LCO conditions in TS 4.3.5 should be placed in TS 3.3 and also include an LCO for gross gamma measurements or justify why it is not needed. Should an LCO be established for maximum pool water temperature? The numbering of the water (coolant) specifications and their bases should be made consistent.

The pH and conductivity LCO values will be deleted from TS 4.3.5 and added to TS 3.3.

An LCO for gross gamma measurement will be added. This LCO will be 'a measured gross gamma measurement that is greater than two times greater than historical data measurements'.

The need for an LCO based on water temperature is being analyzed.

7. TS 3.3.2: Should this be part of the radiation protection TSs in section 3.6? Please move or justify the continued placement of this information in TS 3.3.2.

TS 3.3.2 will be moved to TS 3.6.

9. TS 3.4.1: ANSI/ANS-15.1-2007, Section 3.4 provides guidance for the operations and equipment required to establish confinement while Section 5 includes design features related to the site and facility. Please discuss whether TS 3.4.1 is a facility design feature that should be included in Section 5 or justify your placement.

TS 3.4.1 will be moved to TS 5.1, Site Characteristics

11. TS 3.4.3: Explain whether establishing confinement is a requirement. If it is, "must" should be replaced by "shall". Please review your proposed TSs in their entirety to ensure that requirements are "shall" statements.

Establishing confinement is a requirement. 'Must' will be replaced by 'shall' in TS 3.4.3.

14. TS 3.6.1 and Table 3.5: ANSI/ANS-15.1-2007, Section 3.7 provides guidance for the radiation monitoring system. TS 3.6.1 appears to require both monitors to be in operation but Table 3.5 seems to say only 1 of the 2 is needed. Please clarify the number of radiation monitors required for operation.

One of two, as indicated in Table 3.5, is needed. Wording of TS 3.6.1 will be revised.

16. TS 3.7: Why does TS 3.7 have six specifications and seven bases? The numbering of specifications and bases should be made consistent.

Revised TS 3.7.3 will be revised to include seven specifications and seven bases.

17. TS 3.7.3: Failure of experiments that release materials may damage reactor fuel or structural components. Physical inspection would allow a determination if damage occurred and necessary corrective actions. Please propose TS changes to require reactor structural and component inspection on experiment failure or justify why it is not needed.

An additional specification will be added, stating that in the event of an experimental failure that releases materials that could damage the reactor, physical inspections will be required. The basis for this specification will be 'Inspection of reactor structures and components will be performed in order to verify that the experimental failure did not cause damage. If damage is found, appropriate corrective actions will be taken.'

18. TS 3.7.4: This specification states in part that explosive materials in quantities less than 25 mg TNT may be irradiated provided the pressure produced upon detonation of the explosive has been calculated and/or experimentally demonstrated to be less than the design pressure of the containment. Section 10.3 of the UMTR SAR states that calculations must show that the pressure produced if detonation occurs is less than the failure pressure of the container. Since the container design pressure should have a safety factor of two (Regulatory Guide 2.2), the failure pressure should be half the design pressure. Therefore, TS 3.7.4 should be modified accordingly. Moreover, there

are no example calculations in the SAR comparing the detonation pressure to the failure pressure. Please provide an example calculation for a container that demonstrates compliance with the factor of 2 margin or justify not including a calculation in the SAR.

This specification is now TS 3.7.5 (in the revised version). The statement 'The failure pressure of the container is one half of the design pressure.' will be added after '... less than the design pressure of the container' A sample calculation will be provided in the SAR.

20. TS 4.0: General surveillance requirements for actions after system or component modifications, replacement or maintenance are not clearly defined. Please propose TS changes addressing the requirements for system testing after modifications, replacement or maintenance or justify why it is not needed.

The statement 'Any system or component that is modified, replaced, or had maintenance performed will undergo testing to ensure that the system/component continues to meet performance requirements' will be added to TS 4.0

21. TS 4.1: ANSI/ANS-15.1-2007, Section 4.1 provides guidance for surveillance requirements for core configuration changes. Please propose TS changes to include a surveillance requirement addressing TS 3.1.3 and TS 3.1.5, which contain LCOs related to core and fuel configuration or justify why there is no need for such TS requirements.

Licensed core configuration is verified prior to the first startup of the day. This will be added as a surveillance requirement in TS 4.1. Also, annual burnup reports will be used as the surveillance requirement for TS 3.1.6 (requirement for <50% burnup).

22. TS 4.2: There does not appear to be a LCO for TSs 4.2.7 and 4.2.8 requiring 3 operable control rods. Please add an LCO or explain why it is not needed.

TS 3.1.3.d will be added: 'The reactor shall only be operated with three operable control rods.'

23. TS 4.2.4. The TS refers to the calibration of scram channels. There appears to be no calibration required for the instrumented fuel element which measures fuel temperatures.

Please add a surveillance requirement or explain why it is not needed.

A surveillance requirement for the IFE will be added to TS 4.2.4. Calibration will be done using coolant temperature as the reference value (once the system has reached equilibrium with the reactor shut down).

24. TS 4.3: The numbering of water (coolant) specifications and bases should be made consistent. For example there is no specification 4.3.3. It appears that specification 4.3.3 has been numbered 4.3.4. Please verify. See also related comments in TS 3.3 The numbering of specifications and bases in TS 4.3 will be made consistent.

25. TS 4.3.1: Pool gross gamma activity is measured. However, there is no LCO as to what is acceptable. Explain why an LCO is not needed or establish one. Provide a justification for the frequency of measuring the gross gamma activity. Discuss the need

for a more detailed measurement of pool water activity by isotope.

As noted in the response to RAI 6, a gross gamma LCO will be added to TS 3.03. The frequency of measurement (monthly, not to exceed six weeks) is historical. We currently do a detailed analysis of the pool water sample to determine isotope activity. Question -

should the TS be changed to require this?

26. TS 4.4: It is not clear what "isolation" means. Please define. Does it mean closing of doors, louvers to the outside, etc? What is the operating status of fans, isolation valves, and other components?

Isolation refers to confinement, which is defined in TS 3.4 and refers to closing of two doors - the upstairs door to the west balcony area, and the downstairs door to the reception area.

A definition of isolation will be added to TS 1.0.

27. TS 4.5: If the ventilation system is required to establish confinement including its operability as per TS 3.4 and TS 3.5, then verification of its operation is also required.

Please propose a TS change to address the surveillance and operability requirements of the ventilation system or justify why it is not needed.

Operability of the ventilation system is verified prior to the first startup of the day. The ventilation system automatically secures if radiation levels exceed a preset level.

System shutdown is verified prior to the first startup of the day. These will be added to TS 4.5 as surveillance requirements.

28, TS 4.6.1 states "The objective of these specifications is to ensure operability of each radiation area monitoring channel as required by section 3.4..." The radiation monitoring system is addressed in Section 3.6. Please explain this discrepancy. The specification discusses Table 3.2. Should this be Table 3.5? The reactor scrams and the ventilation system secures with high radiation. Please explain where the surveillance requirement is for this action.

'3.4' will be changed to '3.6', which is correct. 'Table 3.2' will be changed to 'Table 3.5',

which is correct. As noted in the response to RAI 27, securing of the ventilation system and reactor scram due to high radiation is verified prior to the first startup of the day.

30. TS 4.7: Surveillance requirements appear to be missing for TS 3.7.1, 3.7.2, 3.7.3, 3.7.4, 3.7.5 and 3.7.6. Should TS 6.5.4 be moved into TS 4.7? Please explain and address.

Surveillance requirements for TS 3.7.1 - 3.7.6 will be added.

TS 6.5.4 refers to the review and approval of experiments, so it should remain as is.

31. TS 5.0: ANSI/ANS-15.1-2007 Section 5.0 provides guidance for design features including the reactor core. Please propose TS changes to include specifications for the reactor core and control rods or justify why they are not needed.

Additional data, such as fuel element dimensions, will be added to TS 5.0.

33. Section 6.0 contains "will" and "must" statements. This is also true for other Sections of the TSs. Replace by "shall" statements as appropriate.

'Will' and 'Must' will be replaced by 'Shall' where appropriate

34. TS 6.1.3.1 contains minimum staffing requirements when the reactor is not in a secured condition. TS 6.1.3.1.b contains requirements when the reactor is operating. These two conditions are different. Please explain.

Wording in TS 6.1.3.1 will be changed to 'when the reactor is operating'. This change will make TS 6.1.3.1 consistent with TS 6.1 .3.1a and TS 6.1.3.1b,

35. TS 6.1.4 addresses the selection and training of personnel. It states in part that this selection shall be in conjunction with the guidelines in set forth in ANSI/ANS-1 5.1 and 15.4. Considering that these are guidance documents, a "should" statement would also be acceptable.

'Shall' will be replaced with 'should' in TS 6.1.4.

36. TS 6.2.2: ANSI/ANS-1 5.1-2007, Section 6.2.2 contains requirements for the charter (or directive) and rules of the review and audit committee. Please compare TS 6.2.2 against ANSI/ANS-15.7-2007, Section 6.2.2 and make appropriate changes to the TS or explain why changes are not needed. TS 6.2.2.2 states that a quorum has at least three members. ANSI/ANS-15.1-2007 states that the quorum is not less than half of the voting membership. TS 6.2.1 requires the committee to have a minimum of five persons. If the university chooses to have more than five persons on the committee, TS 6.2.2.2 may not meet the ANSI/ANS-15.1-2007 recommendation of at least half the voting membership be a quorum. Please address.

TS 6.2.2.2.2 will be changed to 'A quorum of the RSC will be not less than half of the committee members, one of whom must be the Campus Radiation Safety Officer (or designated alternate)...'

37. TS 6.2.3.1 requires the RSA to determine that changes do not involve an "unreviewed safety question." With revisions to 10 CFR 50.59, the term "unreviewed safety question" is not longer used. Please propose TS changes to conform to 10 CFR 50.59 or justify why it is not needed.

TS 6.2.3.1 will be revised to remove the term 'unreviewed safety question'

38. TS 6.2.3: ANSI/ANS-15.1-2007, Sections 6.2.3 and 6.2.4 provide guidance for review and audit functions including dissemination of reports, findings, and recommendations.

Please propose TS changes to address the distribution of review and audit reports, findings, and recommendations or justify why these are not needed.

The wording of TS 6.2.3 and 6.2.4 will be changed to conform to the wording and reporting requirements as specified in the ANSI standard.

39. TS 6.2.3.4 and TS 6.2.3.5 refer to "charter'. The appropriate term for MUTR is "license",

which is already included in the statements. The term "charter" should be eliminated or a justification for it remaining should be provided.

The word 'charter' will be deleted in TS 6,2.3.4 and 6.2.3.5

40. TS 6.4: This section should state that changes to procedures shall be made in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, or justify why this is not required.

Wording in TS 6.4 will be changed to: 'Substantive changes to... Reactor Safety Committee and will be made in accordance with 10CFR50.59.'

41. TS 6.4.2: ANSI/ANS-15.1-2007, Section 6.4.2 provides guidance on required written procedures including procedures for fuel handling operations such as fuel movement within the reactor. Please propose TS changes to address the need for a written procedure for fuel movements within the reactor or justify why it is not needed.

MUTR is licensed to operate with only one core configuration, which precludes fuel movements within the reactor. Therefore, there is no need for a procedure for in-reactor fuel movement.

42. TS 6.4.2: Remove the statement "experiment approval" or justify its meaning and inclusion in the TS.

'Experiment approval' will be deleted from TS 6.4.2.

43. TS 6.4.4: ANSI/ANS-15.1-2007 Section 6.4.4 provides guidance to develop written procedures for surveillance checks, inspections, and calibrations as specified by the TS.

MUTR TS 6.4.4 specifies surveillance of reactor instrumentation and safety systems and area monitors, but may not address all TS surveillance requirements. Please propose TS changes to address procedure for all TS surveillance requirements or justify why these are not needed.

TS 6.4.4 will be changed to 'Periodic surveillance checks, calibrations, and inspections required by these Technical Specifications or those that may have an effect on reactor safety.' to reflect the wording in the ANSI standard.

44. TS 6.4.6: ANSI/ANS-15.1-2007, Section 6.4 (6) provides guidance to develop written procedures for administrative controls for operations, maintenance, and experiments that could affect reactor safety. Please propose TS changes addressing the procedures for administrative controls related to these items or justify why these are not needed.

TS 6.4 will be rewritten to conform exactly to ANSI 6.4

47. TS 6.6.1: This section should follow ANSI/ANS-15.1-2007, Section 6.6.1, or a justification for not following it should be provided.

TS 6.6.1 as written contains the actions in the ANSI standard, although the wording is different. We'll re-write the section to exactly conform with the standard.

48. TS 6.6.2: ANSI/ANS-15.1-2007, Section 6.6.2 provides guidance on special event reporting and conditions for resuming operation of the facility including authorization by reactor management. MUTR TS 6.6.2 assigns the authorization function to the Reactor Safety Committee and not to the reactor management. Please discuss the role of

reactor management in the authorization to resume operation of the facility after the occurrence of special events.

TS 6.6.2 will be changed such that the Reactor Director, not the RSC, authorizes operations to resume. The report will be reviewed by the RSC at its next meeting.

49. TS 6.7.1: Sending the annual reports only to Document Control Desk is acceptable.

The second sentence in TS 6.7.1 will be changed to read 'This report shall be submitted by September 30 of each year to the NRC Document Control Desk.

50. TS 6.7.1.2: ANSI/ANS-15.1-2007, Section 6.7.1.1 provides guidance on the content of the operating report to include operating experience. Please propose changes in TS 6.7.1.2 to include a summary of operating experience or justify why this is not needed.

TS 6.7.1.1 will be changed to 'A brief narrative summary of reactor operations and results of surveillance tests and inspections...'. TS 6.7.1.2 fulfills the energy production reporting requirement.

51. TS 6.7.3: ANSI/ANS-15.1-2007, Section 6.7.2.2 provides guidance on providing special reports to the licensing authority due to significant changes at the facility or the facility analyses. The written report required to be submitted to the NRC per MUTR TS 6.7.3 should be addressed to the NRC Document Control Desk. Please amend your TS or justify why it is not required.

TS 6.7.3 will be changed to 'A written report shall be forwarded within 30 days to the NRC Document Control Desk, with a copy.....'.

52. Regulation 10 CFR 55.59(c)(5)(i) requires that the facility licensee shall retain operator requalification documentation records until the operator's license is renewed. In addition, Section 6.8.2 of ANSI/ANS 15.1-2007 contains the recommendation that training records for reactor operators be maintained at all times the individual is employed or until the certification is renewed. MUTR TS 6.8.2 specifies that operator requalification records are maintained for a training cycle, which usually does not coincide with the operator license renewal cycle. Please discuss whether TS 6.8.2 meets the criteria in 10 CFR 55.59(c)(5)(i) and ANSI/ANS-15.1-2007,Section 6.8.2.

Please amend your TS as needed or justify why it is not required.

TS 6.8.2 will be changed to 'Retraining and requalification records of current licensed operators shall be maintained at all times that an operator is employed or until the operator's licensed is renewed.'