ML093240505

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University of California at Irvine Research Reactor Request for Additional Information on License Renewal
ML093240505
Person / Time
Site: University of California - Irvine
Issue date: 12/03/2009
From: Montgomery C K
Research and Test Reactors Licensing Branch
To: Geoffrey Miller
University of California - Irvine
montgomery c 415-3398
References
Download: ML093240505 (7)


Text

December 3, 2009 Dr. George Miller Department of Chemistry University of California, Irvine Irvine, CA 92697-2025

SUBJECT:

UNIVERSITY OF CALIFORNIA AT IRVINE - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL FOR THE UNIVERSITY OF CALIFORNIA AT IRVINE RESEARCH REACTOR (TAC NO. ME1579)

Dear Dr. George Miller:

We are continuing our review of the Application for Renewal of Facility Operating License No. R-116, Docket No. 50-326 for the University of California at Irvine Research Reactor. The application was submitted on October 18, 1999 and amended on October 23, 1999, April 24, 2000 and June 2, 2000.

During our review of the Safety Analysis Report of your application, questions have arisen for which we require additional information and clarification. Our review conformed to the Interim Staff Guidance on the Streamlined Review Process for License Renewal for Research Reactors (ML092240244). As discussed in our meeting on October 14, 15, and 16, 2009, you agreed to provide responses to the enclosed request for additional information by January 27, 2010.

In accordance with Title 10 of the Code of Federal Regulations Section 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the requested information we will continue our evaluation of your application. If you have any questions regarding this review, please contact me at 301-415-3398.

Sincerely, /RA/ Cindy Montgomery, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-326

License No. R-116

Enclosure:

1. Request for Additional Information

cc w/encl: See next page

ML093240505 NRR-088 OFFICE PRTA: PM PRTA: LA PFPB PRTA: BC NAME CMontgomery GLappert JSimpson KBrock DATE 12/3/09 11/25/09 11/25/09 12/3/09 University of California at Irvine Docket No. 50-326 cc: Dr. Donald Blake, Chair Department of Chemistry University of California, Irvine Irvine, CA 92697-2025 Mr. Steve Hsu Radiological Health Branch State Department of Health Services P.O. Box 9442732 Sacramento, CA 94234-7320 Dr. George E. Miller Department of Chemistry 516 Physical Sciences 1 University of California, Irvine Irvine, CA 92697-2025 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ENCLOSURE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING QUALIFICATIONS FOR THE RENEWED FACILITY OPERATING LICENSE FOR UNIVERSITY OF CALIFORNIA AT IRVINE REACTOR LICENSE NO. R-116 DOCKET NO. 50-326 Technical Questions and Comments Chapter 2 2.1 Chapter 2.6 indicates that at the time of application, new information regarding the seismicity of the UCI area was being reviewed and that, when complete, this information would be used to supplement the license application. Provide a more complete description of the seismicity of the UCINRF environs. 2.2 Confirm that the nearest permanent residences are located approximately 280 meters (310 yards) southeast of Rowland Hall. Chapter 3 3.1 Confirm that the seismic upgrades to the building housing the reactor, as described in Appendix A, were completed. If the structure as built differs from the Appendix A description, note any differences. Chapter 4 4.1 Section 4.2, Fuel-Moderator Elements, Page 4-5. Provide the burnup limits on the fuel and describe how burnup is monitored. 4.2 Section 4.2, Fuel-Moderator Elements, Page 4-5. Propose Technical Specification (TS) wording that meets the structure of ANSI/ANS-15.1. Consider moving the fuel element requirements to Section 3, "Limiting Conditions for Operation" and the surveillance requirements to Section 4, "Surveillance Requirements" of the TS from their current location in Section 2, "Safety Limits." 4.3 Section 4.5.2, Reactor Nuclear Parameters, Table 4-2, Page 4-21. Provide a reference for the prompt temperature coefficient value of 13.4 x 10

-5 k/k/ ºC. 4.4 Section 4.5.2, Reactor Nuclear Parameters. Propose TS wording for a surveillance requirement for excess reactivity and shutdown margin to correspond with the existing Limiting Condition for Operation. 4.5 Thermal-Hydraulic Analysis. Section 5.1, Introduction, Page 5-1. Section 4.6, Thermal-Hydraulic Design, Page IV-25. Provide justification for the statement that a thermal-hydraulic analysis of the UCINRF reactor is not warranted. This may be done by reference to an acceptable analysis for a facility with similar or bounding relevant design parameters or by analysis. 4.6 Provide the Reactor Protection System setpoints for fuel element temperature and reactor power level scrams. Chapter 5 5.1 Section 5.2, Water Cooling System, Page 5-1. Provide figures 5.1, 5.2, and 5.3 referenced in this section. 5.2 Section 5.2, Water Cooling System, Page 5-1. Propose TS wording on coolant temperature limits. 5.3 Provide a more complete description of the secondary cooling system in accordance with NUREG-1537. The description should include the provisions to detect leakage through the heat exchangers. Chapter 7 7.1 The Figures for Chapter 7 were not included in the SAR. Provide the missing figures.

Chapter 9 9.1 Various figures showing the Ventilation system (Figure 3-3 and higher) were not included in the SAR. Provide these missing figures. Chapter 12 12.1 Provide a description of the minimum facility staffing for operations and describe the activities for which a SRO is required to be present. Also, propose an appropriate TS for minimum staffing. 12.2 Describe and provide revisions to TS for review and audit functions of reactor operations and activities in accordance with the guidance of ANSI/ANS-15.1. Chapter 13 13.1 Section 13.2, Maximum Hypothetical Accident. Clarify what the anticipated occupational and public doses would be for the MHA. The doses should be presented as TEDE and CDE to the thyroid. The assumption for the exposure time of facility personnel should be clearly stated. 13.2 Section 13.4, Loss of Pool Water, Page 13-15. Provide a description of the seismic analysis including the building, reactor pool, and any equipment considered essential for placing the reactor in a safe shutdown condition. For example, the analysis should show that no binding in the control rod mechanisms or other failure mechanisms resulting from a seismic event could prevent full insertion of all rods on a seismic scram initiation. The analysis should also show that no equipment considered essential for placing the reactor in a safe shutdown condition could be adversely impacted by other structural or equipment damage caused by the seismic event, e.g. falling debris. Chapter 14 14.1 TS 3.4, Reactor Safety System, Page 10. For the Reactor Safety System, consider including an interlock to prevent withdrawal of standard rods in pulse mode. 14.2 TS 3.6, Ventilation System, Page 11, consider including: 1) a negative differential pressure requirement 2) a minimum emergency exhaust flow rate 3) a maximum leak 4) all reactor bay external doors closed and personnel doors not blocked open

5) no fuel movement during maintenance outage 6) wording changed to clarify that the outage exception applies only to emergency exhaust system, i.e. normal ventilation and negative DP are always required for reactor operation, fuel movement, etc. Also, consider proposing corresponding Surveillance TS wording for parameters 1, 4, 5, and 6 above.

14.3 TS 3.7, Pool Water Level, Page 12. Provide justification for why the pool water level TS does not include a level below which the reactor cannot be operated or propose appropriate TS wording.

Financial Questions and Comments

Pursuant to 10 CFR 50.33(f)(2), "applicants to renew or extend the term of an operating license for a nonpower reactor shall include the financial information that is required in an application for an initial license." To comply with this requirement, please provide the following updated and supplemental information to the October 18, 1999, University of California-Irvine (UCI) application (the application) for a renewed license for the University of California-Irvine Nuclear Reactor Facility (UCINRF).

1. The NRC staff will analyze the financial statements for the current year, which are required by 10 CFR 50.71(b), to determine if the applicant is financially qualified to operate the UCINRF.

Since UCI's financial statements were not included with the October 18, 1999, application, please provide a copy of the latest financial statements.

2. Pursuant to 10 CFR 50.33(f)(2), the regulation states that "the applicant shall submit estimates for total annual operating costs for each of the first five years of operations of the facility." Since the information provided in the 1999 application submittal is out of date, please provide the following additional information:

(a) The estimated operating costs for the UCINRF for each of the fiscal years (FY)11 thru FY15 (the first five-year period after the projected license renewal date).

(b) Confirm that UCI's primary source of funding to cover the operating costs for the above fiscal years will be from the state-funded budget as described in the application.

3. The application states that "A revised estimate of costs, adjusted for inflation, is $1.0 M anticipated, based on estimates of increased waste disposal prices." In order for the NRC staff to complete its review of the decommissioning cost estimate, please provide the following information:

(a) A current decommissioning cost estimate (2010 dollars) for the UCINRF to meet the NRC's radiological release criteria for decommissioning the facility for unrestricted use pursuant to 10 CFR 50.75(d)(2). Provide the basis for how the cost estimate was developed, showing costs, in current dollar amounts, specifically broken down into the categories of labor, waste disposal, other items (such as energy, equipment, and supplies), and a contingency factor of at least 25 percent.

(b) State the decommissioning method to be used (e.g., DECON, or other method).

(c) A description of the means of adjusting the cost estimate for the UCINRF periodically over the life of the facility (e.g., Consumer Price Indices, U.S. Bureau of Labor Statistics Indices, etc.) pursuant to 10 CFR 50.75(d)(2).

(d) A numerical example showing how the 2010 decommissioning cost estimate will be updated periodically in the future.

4. The application includes a statement of intent (SOI) as the method to obtain decommissioning funding when necessary to decommission the facility. Where the applicant intends to use a SOI as the method to provide decommissioning funding assurance, as provided for by 10 CFR 50.75(e)(1)(iv), the staff must find that the applicant "-is a Federal, State, or local government licensee-" To make this finding, the applicant must state that it is a State government organization and that the decommissioning funding obligations of the applicant are backed by the State government, and also provide corroborating documentation. Further, the applicant must provide documentation verifying that the signator of the statement of intent is authorized to execute said document that binds the applicant. This document may be a governing body resolution, management directives, or other form that provides an equivalent level of assurance. As the application does not include all of the above information, please submit the following:

(a) An updated SOI, which includes: the date of submittal of the SOI; the current cost (2010 dollars) estimate for decommissioning; a statement that funds for decommissioning will be obtained when necessary; typed name and title of the signator, and original signature of the signator; and the signator's oath or affirmation attesting to the information.

(b) Documentation that corroborates the statement in the application that UCI is State agency and a State of California government licensee under 10 CFR 50.75(e)(2)(iv).