ML20207K250

Forwards Request for Addl Info Re Amend Request for License R-66 Submitted on 980929

ML20207K250
Person / Time
Site:	University of Virginia
Issue date:	03/08/1999
From:	Alexander Adams NRC (Affiliation Not Assigned)
To:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
References
TAC-MA3737, NUDOCS 9903170101
Download: ML20207K250 (7)

Text

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rch 8,:1999- ]

. ~ Dr. Robert U. Mulder

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! Director, University of Virginia Reactor Facilityi .

Department of Mechanical, Aerospace. '

' , and Nuclear Engineering  !

' University of Virginia . - ' 1 Chariottesville, VA 22903-2442 '

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MA3737)

Dear Dr. Mulder:

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i We are continuing our review of your amendment request for Amended Facility Operating  ;

License No. R-66 for the University of Vir0i nia Research Reactor which you submitted on  ;

September 29,1998, as supplemented. During our review of your amendment request, l questions have arisen for which we require additional information and clarification. Please . j provide responses to the enclosed request for additional information within 30 days of the date ,

of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed l original under oath or affirmation. Following receipt of the additional information, we will '!

continue our evaluation of your amendment request. I if you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely, _

Original Signed By: l Alexander Adams, Jr., Senior Project Manager  !

Non-Power Reactors and Decommissioning Project Directorate Division of Regulatory Improvement Programs  :

Office of Nuclear Reactor Regulation I Docket No. 50

Enclosure:

As statd cc w/ enclosure:

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de; 1 March 8, 1999 Dr. Robert U. Mulder

. Director, University of Virginia " actor Facility Department of Mechanical, A, ace and Nuclear Engineering University of Virginia Charlottesville, VA 22903-2442

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MA3737)

Dear Dr. Mulder:

We are continuing our review of your amendment request for Amended Facility Operating License No. R-66 for the University of Virginia Research Reactor which you submitted on September 29,1998, as suppiemented. During our review of your amendment request, questions have arisen for which we require additional infonnation and clarification. Please provide responses to the enclosed request for additional information within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of tha additional information, we will continue our evaluation of your amendment request.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely, original Signed By:

Alexander Adams, Jr., Senior Project Mar'ager Non-Power Reactors and Decommissioning j Project Directorate l Division of Regulatory improvement Programs l Office of Nuclear Reactor Regulation Docket No. 50-62

Enclosure:

As stated cc w/ enclosure:

See next page DISTRIBUTION:

E-MAIL HARD COPY 1

PDoyle TBurdick Docket File 50-62 SNewberry TDragoun MMendonca PUBLIC AAdams TMichaels SWeiss OGC EHylton SHolmes CBassett DMatthews PDND r/f WEresian Pisaac P A PDN M BO .

on AA SWeiss 7 /99 3/499 q/999 .

/ i OFFICIAL RECORD COPY DOCUMENT NAME: G:\SECY\ ADAMS \62RAl225.WPD i

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t UNITED STATES i[" ) M. .j NUCLEAR REGULATORY COMMISSION

'2 WASHINGTON, D.C. 20tW54001 March 8, 1999 Dr. Robert U. Mulder Director, University of Virginia Reactor Facility Department of Mechanical, Aerospace and Nuclear EngineerinD University of Virginia Charlottesville, VA 22903-2442

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MA3737)

Dear Dr. Mulder:

We are continuing our review of your amendment request for Amended Facility Operating License No. R-66 for the University of Virginia Research Reactor which you submitted on September 29,1998, as supplemented. During our review of your amendment request, questions have arisen for which we require additionalinformation and clarification. Please provide responses to the enclosed request for additionalinformation within 30 days of the date of this letter. In accordance with 10 CFP. 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your amendment request.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely, 4/ha+A h .

Alexander Adams, Jr., S ior roject Manager Non-Power Reactors and commissioning Project Directorate Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation Docket No. 50-62

Enclosure:

As stated cc w/ enclosure:

See next page 1

)

w University of Vir0 inia Docket Nos. 50-62/396 cc:

Department of Environmental Quality Mr. Paul E. Benneche, Supervisor Office of Grants Nuclear Reactor Facility Management / Intergovernmental University of Virginia Affairs c/o Thornton Hall 629 East Main Street, Sixth Floor Charlottesville, VA 22903-2442 Richmond, VA 23219 Dr. William Vernetson Director of Nuclear Facilities Department of Nuclear Engineering Sciences University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611 Dr. Rolan E. Hertel, Director i Neely Nuclear Research Center  ;

Georgia Institute of Technology l 900 Atlantic Drive, N.W.

Atlanta, GA 30332 Mr. Pedro B. Perez, Associate Director Nuclear Reactor Program North Carolina State University P.O. Box 7909 Raleigh, NC 27695-7909 Office of the Attorney General 101 North 8th Street Richmond, VA 23219 Virginia Department of Health Radiological Health Program P.O. Box 2448 Richmond, VA 23218 l

Dr. Ralph O. Allen, Chairman Reactor Decommissioning Committee University of Virginia Environmental Health and Safety P.O. Box 3425 Charlottesville, VA 22903

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1 REQUEST FOR ADDITIONAL INFORMATION l UNIVERSITY OF VIRGINIA RESEARCH REACTOR l DOCKET NO. 50-62

1. Your proposed changes to license condition ll.B.(4) results in wording that is similar to that in license condition ll.B.(2). To reduce the possibility for confusion as to special j nuclear material (SNM) possession limits, please consolidate possession for any SNM that remains under license condition ll.B.(4) to license condition ll.B.(2). If the possession limit of one kilogram of uranium-235 of any enrichment needs to be modified to accommodate the consolidated material, please propose and justify increased possession limits. There are differences in wording between the proposed license conditions given in your answers to our request for additional information and in the i proposed license included in your submission. Please address.

2. While fuel and cobalt are stored in the reactor pool, a potential radiation hazard exists from the loss of pool water. Please propose a TS for maintaining a system to provide warning of loss of pool water. Please propose associated operability and surveillance requirements,if appropriate.

3. Your answer dated January 20,1999, to our question 5.B. states that procedures will require the air monitor in the reactor room to be turne,d on during fuel shipments. While irradiated fuel remains on site, a potential exists for a cladding failure and release of fission products. How would this be detected during fuel storage? Please propose a TS to ensure operation of the air monitor during fuel movement and, if needed, during fuel storage. Please propose associated operability and surveillance requirements, if appropriate. Your answer to question 8 has proposed wording to calibrate the bridge radiation monitor until the fuel and cobalt-60 pins are removed from the reactor pool, but there does not appear to be a requirement to have the monitor in operation. Likewise, there does not appear to be a specification similar to 4.4.1 for required radiation monitoring equipment.

4. Your proposed changes to TS 4.5 would eliminate the TS. Please propose a TS requirement (or modifications to this TS) that would insure that operation of the radiation monitors is verified after maintenance or modification.

5. Your proposed changes to TSs 4.6 and 5.2 would eliminate requirements on the confinement and ventilation system. Please propose wording that would require operability and surveillance of these systems until fuelis permanently removed from the facility or justify not operating these systems.

6. TS 5.3.1 refers to use of contained uranium-235. However, your proposed license condition ll B.(2) does not allow use of uranium-235. Please make the license condition and TS consistent. Your proposed TS 5.3.2 refers to use of plutonium. However, your proposed license condition ll B.(2) does not allow use of plutonium. Please make the license condition and TS consistent. If you choose to continue to authorize use of these materials, please give some examples of your intended uses.

7. Please define on your proposed organizational charts the meaning of solid and dashed lines similar to that on your current organizational chart.

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8. One of the attribuies of the review and audit committee discussed in ANSI /ANS-15.1 is l that rnembers of the operating staff do not constitute the majority of a quorum. While j with the permanent shutdown of the reactor, an " operating staff" will not exist after i removal of the fuel, this concept is still valid for members of the Reactor Decommissioning Committee (RDC). Please propose a technical specification that prohibits persons (e.g., reactor staff, reactor decommissioning subcontractors, or health physics staff directly supporting decommissioning) who will be directly affected by decisions of the committee from making up a majority of a quorum.

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9. Please propose a TS that requires timely dissemination, review, and approval of Reactor Safety Committee, Radiation Safety Committee and RDC minutes.

10. Please propose review functions for the Reactor Safety Committee and the RDC similar to those in ANS-15.1, considering the permanent shutdown status of the facility, or justify the differences in your proposed TSs. For example, the Reactor Safety Committee does not have review responsibility for 10 CFR 50.59 changes and violations of TSs and license or internal procedures having safety significance. While the list of responsibilities for the RDC includes reference to 10 CFR 50.59(a), the committee responsibilities do not match the requirements of 10 CFR 50.59(a). The RDC does not have review responsibility for violations of TSs, license or internal procedures having safety significance.

11. Please propose audit functions for the Reactor Safety Committee and the RDC similar to those in ANS-15.1, considering the permanent shutdown status of the facility, or justify the differences in your proposed TSs. For example, the Reactor Safety Committee does not appear to have an audit function for the operator requalification program, corrective actions, or the emergency plan and implementing procedures. The RDC does not appear to i ave an audit function for the corrective actions, or the emergency plan and implementing procedures. Audit functions that are an internal requirement of individual plans or programs are acceptable and need not be repeated in the TSs.

12. In your two proposed organizational charts the title of Provost appears to have been changed to Vice President and Provost. Also, the pusition of Provost on the organizational chart has changed with the change in title. Please justify these proposed changes.

13. Your current TS 6.3.2 discusses changes to procedures that do not change the original intent and minor changes. Your proposed TS do not appear to have an equivalent concept. Please explain.

14. Question 23 in our request for additional information dated November 23,1998, asked about elimination of reporting violations of TS. Your answer focused on the permanent shut down status of the facility. However, NRC still considers violation of the remaining TS that are applicable to the permanently shut down reactor important enough to report.

Please propose a TS that accomplishes this or justify not reporting violation of these remaining TS.

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' 15. TSs 6.7.1.(2)(b) and 6.7.1.(3)(b) refer to TS 6.6.2. However, your proposed revisions to the TSs eliminated TS 6.6.2. Please address.

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16. Your proposed wording of TSs 6.7.1.(3)(a) and (b) is the same as TSs 6.7.1.(4)(a) and j (b). Please justify the elimination of TS 6.7.1.(4)(a) and (b), considering the fact that i fuel remains on site.

17.' Your current TS 6.7.2 contains a requirement to report 50.59 changes as part of the annual report. Your proposed TS 6.7.2 does not contain a similar requirement. Please explain.

18. Do any of the changes to the license and TSs for the UVAR need to be made to the CAVALIER TSs and license or will the CAVALIER decommissioning proceed under the existing Order and TSs?

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