ML13157A412

Dow Chemical Company - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-108 for the Dow Chemical Triga Research Reactor

ML13157A412
Person / Time
Site:	Dow Chemical Company
Issue date:	06/26/2013
From:	Geoffrey Wertz Research and Test Reactors Branch B
To:	O'Connor P Dow Chemical Co
Geoffrey Wertz 415-0893
References
TAC ME1595
Download: ML13157A412 (8)

Text

June 26, 2013 Dr. Paul J. OConnor, Ph.D.

Facility Director Dow Chemical TRIGA Research Reactor Dow Chemical Company Building 1602 Midland, MI 48674

SUBJECT:

DOW CHEMICAL COMPANY - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL OF FACILITY OPERATING LICENSE NO. R-108 FOR THE DOW CHEMICAL TRIGA RESEARCH REACTOR (TAC NO. ME1595)

Dear Dr. OConnor:

The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009 (a redacted version of the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System (ADAMS) Accession No. ML092150443) as supplemented by letter dated February 7, 2012 (ADAMS Accession No. ML12040A128).

We require additional information and clarification on questions that have arisen during our review. Please provide responses to the enclosed request for additional information within 30 days of the date of this letter. 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 document 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.

P. OConnor If you have any questions about this review or if you need additional time to respond to this request, please contact me at 301-415-0893 or via electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely,

/RA/

Geoffrey A. Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-264

Enclosure:

Request for Additional Information cc: See next page

Docket No. 50-264 cc:

Office of the Mayor 333 West Ellsworth Midland, MI 48640 Office of the Governor Room 1 - Capitol Building Lansing, MI 48913 Mr. Dan Rader Environmental Health and Safety Responsible Care Leader Chair, Radiation Safety Committee 1790 Building Midland, MI 48674 Dr. Wayde Konze Global Research and Development Director for Analytical Sciences Chair, Reactor Operations Committee The Dow Chemical Company 1897 Building Midland, MI 48667 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611 Office of the Mayor 333 West Ellsworth Midland, MI 48640

ML13157A412 *Concurrence via email NRR-088 OFFICE NRR/DPR/PRLB/LRPM NRR/DPR/PRLB/LAit NRR/DPR/PRLB/LA NRR/DPR/PRLB/BC NRR/DPR/PRLB/LRPM*

NAME GWertz PBlechman GLappert AAdams GWertz DATE 06/12/2013 06/12/2013 06/12/2013 06/26/2013 06/26/2013 OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL REVIEW FOR THE DOW CHEMICAL COMPANY TRIGA RESEARCH REACTOR LICENSE LICENSE NO. R-108 DOCKET NO. 50-264 The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009 as supplemented by letter dated February 7, 2012. We require additional information and clarification on questions that have arisen during our review.

Provide responses to the following requests for additional information (RAIs) within 30 days of the date of this letter.

The RAIs are based on a comparison of the DTRR license renewal application and NRC NUREG-1537, Guidance for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, February 1996 and American Nuclear Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications [TSs] for Research Reactors.

1. In the DTRR response to NRC RAI No. 47, solid radioactive waste containing isotopes with half-lives of 15 days or less are stored for 150 days (10 half-lives) prior to disposal (incineration). This decay period reduces the radioactivity to less than 0.01 percent of the original activity. The material is surveyed with a Geiger counter to confirm no detectable activity prior to incineration. However, the detection limit of survey instrumentation was not provided in the RAI response. Provide the types of survey instrumentation used to free release materials. Describe why the survey instrumentation is appropriate for the types of radiation anticipated. Also provide the lower level of detection of your survey instrumentation and techniques. Describe how your process ensures radioactive materials are not inadvertently released to the environment.

2. In the DTRR response to RAI No. 52, scenario 2 provides the maximum hypothetical accident (MHA) submersion dose to occupants of the control room from leakage out of the reactor bay. However, the RAI response did not indicate if the dose included the contribution from the suspended airborne (scattered) radioactive material in the reactor bay emitting gamma rays through the intervening wall? Indicate or provide the contribution to the MHA dose to the control room from the reactor room.

3. In the DTRR response to RAI No. 54, the Loss of Coolant Accident (LOCA) analysis provided the potential radiological consequences to workers and members of the public directly near the reactor. However, the RAI response did not provide the results of the potential environmental consequences due to the LOCA tank breach leaking into the ground and groundwater. Provide an analysis of the consequences of a leak from the primary Enclosure

coolant tank into the ground. If possible, consider using assumptions based on equipment maintained by DTRR TSs or actions described in the DTRR emergency plan.

4. The proposed DTRR TS 1.1, Scope, last sentence, indicates that the Bases do not constitute limitations or restrictions. However, the proposed DTRR TSs provide numerous TS Bases that reference sections from the DTRR Safety Analysis Report (SAR), which contains assumptions used in analyses and calculations, which form TS limits. Justify the proposed TS or propose a sentence, which does not conflict with references to SAR results.

5. The proposed DTRR TS 1.3, Definitions - Reactor Secured, Item No. 2.d, contains the phrase or of one dollar, which seems redundant to TS 3.7.1, which limits the reactivity worth of all experiments to $1.00. Justify the proposed TS or remove the phrase or of one dollar.

6. The proposed DTRR TS 1.3, Definitions - Control Rod, Item No. 2, Shim/Safety Rod describes the capabilities of the control rod, but does not indicate how its position can be changed. Justify the proposed TS or provide a description of the control of the position of the Shim/Safety Rod.

7. The proposed DTRR TS 3.3, Reactor Control Rods and Safety Systems and Interlocks, Specification No. 3, does not appear to include the time for the electrical signal to initiate control rod movement as provided in the definition of the scram time. Justify the proposed TS or propose a revision to include the electrical signal time component as described in the definition of the scram time.

8. The proposed DTRR TS 3.5, Ventilation, does not appear to contain a provision for requiring ventilation when core or control rod work, which could cause a reactivity change of more than $1.00 as provided in the guidance of NUREG-1537 and ANSI/ANS-15.1-2007. Justify the proposed TS 3.5 or propose a revision to add the core or control rod work as provided in the guidance of NUREG-1537 and ANSI/ANS-15.1-2007.

9. The proposed DTRR TS 3.7.1, Specification b. does not indicate the absolute value of reactivity for an experimental worth. Justify the proposed TS or propose a revision to account for the absolute value of reactivity worth for experiments.

10. The proposed DTRR TS 3.7.3, Bases, 1st paragraph, describes the release of fission products and the 2nd paragraph describes the effect of an undisturbed column of water.

Both items do not appear consistent with the requirements in TS 3.7.3. Justify the proposed TS Bases or propose a revision to the Bases.

11. The proposed DTRR TS 4.3, Control and Safety Systems, does not appear to include a surveillance requirement (e.g., Channel Check, Test or Calibration) for the Reactor Pool Water Radioactivity Monitor listed in DTRR TS 3.3, Table 3.3B. Justify the proposed TS or propose a surveillance requirement for the Reactor Pool Water Radioactivity Monitor.

12. The proposed DTRR TS 4.4, Reactor Coolant Systems, Bases indicates that a channel calibration of the Reactor Pool Water Temperature Monitor is performed as required as a result of the channel test. This appears to be a specification in the Bases, rather than in the

TSs. Justify leaving this specification in the Bases or propose adding to TS 4.4, Specification 3.

13. The proposed DTRR TS 5.1, Reactor Site and Building, does not indicate the licensed area as defined in the DTRR TS Definitions. Justify the proposed TS or propose adding the licensed area to TS 5.1.

14. The proposed DTRR TS 6.1.2, Responsibility, does not indicate the reporting relationship (solid line in TS Figure 6.1) between the Radiation Safety Officer and the Dow Core R&D Director, Analytical Services (Level 1). Justify the proposed TS Figure 6.1 or propose a revised figure to indicate the reporting relationship.

15. The proposed DTRR TS 6.2.1, Composition and Qualification states that the Reactor Operations Committee (ROC) shall consist of at least four members, but then lists five members by title or name. The minimum number of ROC members is not clear. Justify the proposed TS 6.2.1 or propose a revised TS, which clearly states the minimum composition of the ROC.

16. The proposed DTRR TS 6.2.2, ROC Rules:

a. Specification c., indicates that the meeting minutes shall be reviewed and approved at the next meeting, which could be as long as a year. NUREG-1537 and ANSI/ANS-15.1-2007 guidance suggests a review in a timely manner. Justify the proposed TS or propose a revised TS with a review performed in a timely manner.

b. Specification e., does not indicate how the ROC communicates with the Radiation Safety Committee. NUREG-1537 and ANSI/ANS-15.1-2007 guidance suggests a written report or minutes of the findings. Justify the proposed TS or propose a revised TS indicating the communication method or format.

17. The proposed DTRR TS 6.2.3, ROC Review Function, Specification c., and TS 6.2.4, Specification a, describe requirements applicable to a charter. However, a charter is not defined elsewhere in the TSs. Justify the proposed TS, or propose revised TSs 6.2.3 and 6.2.4 delineating the applicability of a charter.

18. The proposed DTRR TS 6.2.4, ROC Audit Function, does not appear to require deficiencies that affect reactor safety to be immediately reported to the Level 1 as provided in the guidance in NUREG-1537 and ANSI/ANS-15.1-2007. Justify the proposed TS or propose a revised TS to ensure that deficiencies that affect reactor safety are immediately reported to the Level 1.

19. The proposed DTRR TS 6.4, Procedures:

a. Specification e., provides control rod removal or installation as an example of major components, which could have an effect of reactor control and safety. It is not clear if control rod removal or installation is the only consideration to have an effect on reactor safety or control. Justify the proposed TS or propose a revised TS to ensure that the TS is not limited to control rod removal or installation.

b. The paragraph discussing substantive changes to the above procedures does not provide a definition or criteria for those changes which would be considered substantive or unsubstantive. Additionally, it is unclear if the review requirements of 10 CFR 50.59 are maintained within this TS paragraph. Provide a description of substantive and unsubstantive changes to procedures and how this TS paragraph ensures conformance to the requirements of 10 CFR 50.59.

c. The paragraph discussing temporary deviations does not appears to provide the methodology for establishing and changing procedures as provided in the guidance in NUREG-1537, Part 1, Appendix 14.1, Section 6.4, Procedures. Additionally, it is unclear if the review requirements of 10 CFR 50.59 are maintained within this TS paragraph. Provide the methodology for temporary deviations and how this TS paragraph ensures conformance to the requirements of 10CFR 50.59.

20. The proposed DTRR TS 6.5, Experimental Review and Approval, Specification b., discusses minor changes that do not significantly alter the experiment. It is not clear what constitutes minor changes that do not significantly alter the experiment. Additionally, it is unclear if the review requirements of 10 CFR 50.59 are maintained within TS 6.5. Justify the proposed TS or propose a revised TS that defines minor changes that does not significantly alter the experiment and ensures conformance to the requirements of 10CFR50.59.

21. The proposed DTRR TS 6.6.2, Actions to Be Taken in the Event of an Occurrence of the Type Identified in Section 6.7.2 Other Than a Safety Limit Violation, states for all events, which are required by regulations or TSs to be reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under Section 6.7.2:

a. It is not clear why regulations needs to be identified in the TSs since NRC regulations remain requirements as specified in Title 10 of the Code of Federal Regulations. Justify the proposed TS or propose a revised TS that does not refer to regulations.

b. It is not clear why within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> needs to be identified in TS 6.6.2 when TS 6.7.2 states the report needs to be provided not later than the following day. Justify the proposed TS or propose a revised TS that do not refer to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time.

22. The proposed DTRR TS 6.7.1, Annual Operating Reports, states that a report shall be created and submitted annually. However, the reporting period and the time following the submittal of the report following the end of the reporting period are not specified. Justify the proposed TS or propose a revised TS that indicates the reporting period and time allowed for submittal.