ML20127J547

Forwards Answers to Request for Addl Info Re Authorization to Possess & Use U-235

ML20127J547
Person / Time
Site:	University of Illinois
Issue date:	01/19/1993
From:	Holm R ILLINOIS, UNIV. OF, URBANA, IL
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9301250171
Download: ML20127J547 (10)

Text

,

, University of Illinois Departnient of cotiege of Engineering

' Nude Enginening at Urbana-Champaig'n 214 Nudear Engineering 217 333-1295 laboratory 217 333 2906 fn 103 South Goodwin Avenue Urbana,IL 61801 2984 January 19, 1993 Docket No. 50-151 U.S. Nuclear Regulatory Commission ATTN: Docament, sntrol Desk M.S. P1-22 Washington, DC 20555 i

Dear Sir,

Please find attached answers to your REQUEST FOR ADDITIONAL INFORMATION dated January 4, 1993. If there are any further questions please contact me at 217-333-7755. i Respectfully,

+rh Richard L. Holm Reactor Supervisor Enc.

cc: Mr. Alexander Adams, Jr. , NRR, USNRC Regional Administrator, Region III, USNRC File 22001G 0

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l STATE OF ILLINOIS COUNTY OF CHAMPAIGN Richard L. Holm, being first duly sworn on oath, deposes and says that he has

! affixed his signature to the letter above in his official capacity as Reactor

-Supervisor, University of I111nois Nuclear Reactor Laboratory; that in accorde.nce'with the provisions of Part 50, Chapter 1, Title 10 of the Code of Federal Regulations,-he is attaching this affidavit; that the facts set forth in-the within letter are true to his best information and belief.

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Jkb/Y Yh liichard L. Holm Reactor Supervisor.

Subscribed and sworn to before me, a Notary Public, in and.for the County of Champaign, State'of Illinois, this 1 day of January , A.D.', 1993.

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" OFFICI AL SEAL"h KATHLEEN M. DYS ART '

NOTARY PUBLIC. STATE OF ILLINOIS MY COMMISSION EXPlaES .8n9/c;

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. l RE.SDONSE IQ REQUEST FOR ADDITIONAL INFORMATION DOCKET NO. 50-151 i

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QUESTION: Please provide additional information concerving your request to remove authorization from the Facility License to receive, possess

and use 2. 6 kilograms of contained uranium-235.. Why are you making this request?

! ANSWER: Part 2.B of the Facility License delineates this 2.6 kilograms of utanium-235 to be used in connection with operation of a subcritical assembly in the Bulk Shielding Facility of the reactor. This l paragraph is a precursor to the licensing of the LOPRA reactor and should no longer be present on our license.

QUESTION: Please rewrite paragraph 2.B. of Facility License R-ll5 breaking down the 5 kilograms of uranium-235 -into amount, er.richment and form. Also include authority to possess, but not separate, such

special nuclear material as may be produced by the operation by the operation of the facility. Attachment 1 provides an example of the "Part 70 paragraph" of a license written in this format. The purpose of this format is to specifically identify the high enriched uranium, if any, possessed under the Facility License .

i- ANSWER: Paragraph 2.B of Facility License R-115 is requested to be written as follows:

! " Pursuant to the Act and 10 CFR 70, " Domestic Licensing of Special i Nuclear Material", tu receive, possess and use up to 5.0 kilograms of uranium-235.for use in connection _with the operation of the reactor of which up to-20 grams is contained uranium-235 of any enr'chment in the form'of fission chambers and the balance is 4 contained uranium-235 enriched to less than 20 percent in the isotope uranium-235 in the' form of fuel; and to possess, but not separate, such special nuclear material as may oe produced by the

-operation of the facility;"' i i

l QUESTION: Item e. of proposed. Definition 1.14,' Abnormal Occurrence, an l unplanned reactor scram due zo, for example, component failure or l power failure s would be rep-:rtab!e because it is an unanticipated i change under your current Th. AdSI/.\NS 15.1-1990, "The Development of Technical Specifications for hesearch Reactors," excludes reactor

, trips- from a known cause ss being reportable.- Consider naking this ,

change to your TS to reduce abnormal occurrences that have little or 1

-no safety significance.

LANSWER: Change Section 1.14 Abnqtmal Occur.rgag_e part e to read at Jollows:

. "" e . An uncontr^11ed or unanticipated change in reactivity { Reactor 4

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• trips resulting from a known cause are excluded); ". A revised page is attached.

QUESTION: Item T. of proposed Definition 1.14, Abnormal Occurrence, discusses an observed inadequacy that could have caused an unsafe condition.

What about an observed inadequacy that does cause an unsafe condition? As the definition is currently written, this is not an abnormal occurrence. Please address this issue.

ANSWER: Change Section 1.14 Abnormal OcqurrERCR part f to read as follows:

"f. An observed inadequacy in the implementation of either 1 administrative or procedural :ontrols, such that the inadequacy )

causes or could have caused the existence or development of an unsafe condition in connection with the operation of the reactor." A revised page is attacSed.

QUESTION: Iten g. of proposed Definition 1.14, Abnormal Occurrence, discusses degraaation of the containment boundary. Dces your reactor facility have a containment? If it has a confinement, change Iten g. to reflect your facility design.

ANSWER: The University of Illinois Nuclear Reactor Laboratory has a confinement boundary.- Change Section 1.14 Abnotaal Occurrenga part g to read as follows:

"g. Abnormal and significant degradation in reactor 'luel or cladding, or both, coolant boundary, or confinement boundary (excluding minor leaks), which could rssult in- exceedir.g j

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prescribed radiation exposure limits of personnel or environment, or both." A revised page is attached.

QUESTION: In your proposed TS 6.1.~2 a. 3. , Staffing, what ic considered "readily available on call" under the current Nuclear I.aboratory Rules and Regulations?

ANSWER: The current Nuclear Reactor Laboratory Rules and Regulations dated

. November 1992 states the following:

" "On call" shall be defined as the ability to be reachud by phone.

or other device and reach the facility within one hour."

QUESTION: In your proposed TS 6.1.3, Selection and Training of Personnel, what is your understanding of the current regulations and guidelines for the selection, training, and requalification of operations personnel? Are these regulations and guidelines stated in a facility peccedure?

ANSWER: The selection and training of personnel at the Nuclear Reactor Laboratory follows the requirements of 10CFR55 and the guidelines of

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k ANSI /ANS - 15.4 - 1988 "American National Standard for the Selection and Trtining of Personnel for Research Reactors". Requalification is performed under the auspices of the approved requalification plaa while initial training is performed using c training program developed as a systems approach to training, s

QUESTION: In Section 6.2 of the current TS, Review, Responsibility number 7 of the Nuclear Reactor Committee, to approve individuals for the supervision and operation of the reactor, appears to have been deleted. Who has this responsibility under your proposed TS?

ANSWER: Approval of individuals for the supervision and operation of the reactor is an administrative function and therefore outside the

• review and audit function of the Nuclear Reactor Committee.- This function resides within the administrative chain of command (i.e.

Beactor Supervisor, Reactor Director and Nuclear Engineering Department Head.)

QUESTION: In your proposed TS 6.4, Procedures, does item g concerning procedures for radiation protection include handling of byproduct material produced by the reactor and the shipment of byproduct

,' material from tho reactor license?

ANSWER: The procedures written to comply with TS 6.4 g will cover the i handling of byproduct waterial and the shipment of byproduct material.

e QUESTION: In your proposed Section 6.8, Reporting Requirements, please remove reference to the Director, Office of Nuclear Reactor-Regulation, from the address for headquarters reports. Addressing reports for

' headquarters to the Document :ontrol Desk is sufficient.

1 i ANSWER: The reference to the Director will be deleted. A revised page is attached.

QUESTION: In your proposed Section 6,8 a., Reporting Requirements, you discuss confirming telephone reporta in writing by telegraph or similar conveyance. - Please consider changing this to confirming in writing by facsimile or similar conveyance. Required telephone reports to the region should also be made to the headquarters operations center.

ANSWER: The changes requested have been made and a revised page is attached.

QUESTION: In your proposed Section 6.8 d. i Reporting Requirtuents, you deleted 10 CFR 50.59 change summaries from the list of items to be included in-the annual report. Please be aware that these summaries are a requirement of 10 CFR 50.59 (b) (2) and must continue to be provided to the SRt st an arnual interval. Keeping this as a requirement of

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the annual report would insure that this' regulation-is met.

l ANSWER: TS 6.8 d 4 is a verbal d.*scription of b0.59 reviews. However an additional line has been added that specifically states 10 CFR 60.59. A revised page is attached.

QUESTION: In your proposed Table of C6ntents, Section 6.9, Plant Operating Records does not have a page number. Please correct.

ANSWER: The page has been numbered and a revised page-is attached.

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i j- 5.0 DESIGN FEATURES i

, 5.1--Re_ actor Fuel 27 5.2 I -Reactor BuOiling 28 l_

1 i 5.3 Fuel Storage 29 i

- 5.4 Emergency Removal of Decav_lle.a.1 30 i

{ 6.0'ADRlRLSTRATLYE CONTROLS 6.1 Qrfanization 31-3 l- 6.2 Review and' Audit' 33-4 4

] ' 6. 3 Radiation safetr 35

.- 6.4 Erscedures 36 4

1 6.5 Experiments Review and Anoroval 37 e

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6.6 Action to be taken in the Event a Safety- Limit

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is_.Jxceeded i_ . -

j_ _6. 7 - Action to be Taken in_the Event of an_Abnarmal 40

Qp_purrertce d

l 6.8 Re2qrting Regttir_ements 41 i

l 6.9 Elant_Operatt.ng Records- 43 i

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e 2-l.10 Epise llods - The reactor.is in the pulse mode when the. reactor mode selection i switch is in the pulse position. In this mode, reactor power is increased on periods less than one second by motion of the transient control rod (e),

1.11 Expatiagnt - An experiment is:

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a. Any apparatus, device or material placed in the reactor core region, in an j experimental facility, or in-line with a beam of radiation emanating from

the reactor, b.. Any operation designed to measure reactor characteristics 1.12 Untried Exoerlmani - An untried experiment is any experiment not previously l-

performed in this reactor.

1.13 EXEgrimental Facilitleg - Experimental facilities _are the beam ports, thermal l columns, pneumatic transfer systems, central thimble, rotary specimen rack.

bulk shielding facility, and the in-core facilities ( including single-element

positions, three element position, and the seven-element position).

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1.14 Abnormal Occurrence --An abnormal occurrence is any of the following:

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Operating with any actual-safety system setting less conservative than a.

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specified in Section 2.2, Limiting Safety System Settings;

b. Operation in violation of limiting conditions for operation established in the technical specifications unless prompt remedial action is taken; l c. Malfunction of a required reactor or experiment safety system component I

which renders or could render the reactor or experiment safety system incapable of performing its intended safety function unless the malfunction or cond. tion is discovered during maintenance tests or periods of reactor shutdown;

d. Release of fission products from a fuel-element;

e. An uncontrolled or unanticipated change in reactivity { Reactor trips resulting from a known cause are excluded};

f. An observed inadequacy in the implementation of either administrative or procedural controls, such that the inadequacy causes or.could have caused

' the existence or development of an unsafe condition in connection with the i- operation of the reactor-.

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g. Abnormal and significant. degradation in reactor fuel or cladding, or both.

coolant boundary, or confinement boundary (excluding minor leaks), which could result in exceeding prescribed radiation exposure limits of personnel' or environment, or both.

1.15 Standard Thermocounle Fuel Element - A standard thermocouple fuel! element is a i standard fuel element containing three sheathed thermocouples embedded near the axial and radial center of the fuel element.

1.16 'dgasured Value - The measured value of a process variable is -the value of the variable as it appears on the output of a channel.

. Amendment No. 6 4

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'o - 41 6.8 - ReDorting Reauirements In addition to the requirements of applicable-regulations, and in no way su'atituting therefore, reports shall be made to the USNRC as follows:

a. There shall be a report not later than the following working day by telephone and confirmed in writing by facsimile or similar conveyance to the Regional Administrator, USNRC, Region 111 and the USNRC headquarters operations center to be.followed by a written report that describes the circumstances of-the event that describes the event within 14 days to the Document Control Desk, USNRC Headquarters, and a copy to the Regional

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Administrator, USNRC, Region 111 of any of the following:

1. Release of radioectivity from the site above allowed limits.-

2. Violation of safety-limits.-

3. Any-significant variation from measured values from a corresponding predicted or previously measured value of safety-connected operating characteristics occurring during operation of the_ reactor.

4. Incidents or conditions relating to operation of the facility which prevented or could have prevented the performance of engineered safety features as described in-these specifications.

5. Any abnormal occurrences as defined in Section~1.14 of these specifications.

b. A report within 30 days (in writing to the Document Control Desk, USNRC Headquarters) of:

1. =Any substantial-variance from performance specifications contained in these specifications.

2. Significant changes in the' transient or-accident analysis as described in tha. Safety Analysis Report.

3. Permanent changes-in the facility organization involving the Reactor Supervisor, Reactor Director or Department Head.

c. A -retort within 60 days af ter criticality of the reactor (in. writing to -

the Document Control Desk,- USNRC Headquarters) upon receipt of a new.

facility license or an amendment to the'lleense authorizing an increase in reactor power level-or the installationLof a new core, describing'the measured values of the. operating conditions or characteristics of.the reactor under:the new conditions, including:

-1. Total control rod reactivity worth.

2. Reactivity worth of t'ae ningle control rdd of highest reactivity worth.

3. Total and individual reactivity worths of any experiments inserted Amendment No.: 6 i

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in the reactor. ,

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4. Minimum shutdown margin both.at room and' operating temperatures.

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d. A routine report (in writing to the Document Control Desk, USNRC lleadquarters) within 60 days after completion of the first six monthsLof

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facility operation.and at the end of each-12' month-period thereafter, ,

providing the following informationi

!. 1. A narra'tive summary of reactor operating experience including the:

l. energy produced by the' reactor, hours critical, and amount'of pulsing

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operation.

! 2. The unscheduled shutdowns including. where applicable, corrective i action taken to preclude recurrence.

3. Tabulation of major preventive and corrective maintenance operations

-having safety significance.

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4. Tabulation of major changes. In the reactor facility and procedures, and tabulation of new tests, experiments.or both, that are significantly different from those performed previously and are.not

! -described in the Safety Analysis' Report, includingLa summary of

safety evaluation leading to the conclusions that-no unreviewed l~ safety questions were involved.-{per 10 CFR'50.59 (b) (2)}-

! 5. A summary of the nature and amount of radioactive effluents released or discharged to environs beyond the-effective control of the

! licensee as measured at or prior to the point of such release or discharge. The summary shall include to the extent practicable an ,

estimate of individual radionuclidea present in the. effluent. If the-

' estimated average release af ter dilution or dif fusion' is less than 25 .

percent of the concentration allowed or recommended,- a statement :to '

this effect is sufficient. v l- 6. A eummarized result of environmental surveys' performed outside the. <

i facility.

L 7. A summary of exposures received by facility personnel and visitors l

where such exposures are greater-than 25 percent of that allowed or-recommended.

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Amendment No. 6

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