ML043080317

Response to Request for Additional Information Dated September 30, 2004

ML043080317
Person / Time
Site:	University of Illinois
Issue date:	10/26/2004
From:	Holm R University of Illinois
To:	Alexander Adams NRC/FSME
References
Download: ML043080317 (12)

Text

UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN I

College of Engineering Assistant to the Dean 306 Engineering Hall, MC-266 217-244-7560 1308 West Green Street r-holm(uizic.edi Urbana, IL 61801 October 26, 2004 Docket No. 50-151 Mr. Alexander Adams, Jr.

U.S. Nuclear Regulatory Commission Mail Stop 012-G13 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

Dear Sir,

Please find enclosed the response to your Request for Additional Information dated September 30, 2004.

If there are any further questions please do not hesitate to contact me.

Sincerely,

"_-___7 Richard L. Holm Reactor Administrator

(::)P-0

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 Administrator, University of Illinois Nuclear Reactor Laboratory\; that in accordance 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.

Richard L. Holm Reactor Administrator Subscribed and sworn to before me, a Notary Public, in and for the County of Champaign, State of Illinois, this&?L day of 4670?3 , A.D., 2004.

Nf4tary Public ofillino My Commission Expires OFFICIAL SEAL KATHLEEN M.DYSART NOTARY PUBUC, STATE OF IWNOIS MY COMMISSiON EXPIRES 6-19-2008

Response to Request for Additional Information Dated Sept. 30, 2004 University of Illinois - Docket No. 50-151

1. The existing technical specification (TS) 6.1.1 c. requires the Reactor Health Physicist to be responsible for assuring the day to day and routine radiological safety activities at the Nuclear Reactor Laboratory. Please describe how these activities have changed with the permanent shutdown and removal of reactor fuel from the facility such that the Reactor Administrator and Radiation Safety Office staff can perform the remaining duties. Your proposed changes to the TS 6.1.1 c. removes the entire first sentence which removes all responsibility for assuring the day to day and routine radiological safety activities. Please justify deletion of this entire sentence or replace the position of Reactor Health Physicist with Reactor Administrator and Radiation Safety Office staff to reflect the transfer of responsibility as discussed in your justification.

Section 6.1. .c has been revised to reflect that the responsibilitiesfor day to day radiologicalsafety activities belong to the ReactorAdministratorwith the support ofthe RadiationSafety Office. With the removal of thefuelfrom thefacility the radiological supportfor thefacility is reduced. The facility has no activities in it from researchers, etc. The building is effectively mothballedpendingdevelopment and approvalofa decommissioningplan. Current needsfor radiologicalcontrols at thefacility are commensurate with mothballing. At such time that decommissioningactivities are in progress, other supportfor radiologicalsafety 'ill be requiredandappropriated. A revised copy of the Technical Specifications is attached.

2. You have proposed deleting TS 6.1.2 a.2. requiring the Reactor Health Physicist as part of the minimum staffing requirements. In addition to health physics duties, this position also has reactor operations responsibility as indicated by meeting the requirements for a Level Three individual as given in ANS/ANSI-15.4-1988. Please discuss how the change in activities at the facility following permanent reactor shutdown and removal of fuel justifies a minimum staffing of the Reactor Administrator. Please note that ANS/ANSI-15.1-1990, "The Development of Technical Specifications for Research Reactors,"

indicates the minimum staffing requirement is for periods when the reactor is not secured.

If the reactor will be shut down or secured with the removal of reactor fuel complete, the need for a TS discussing minimum staffing may be eliminated given proper justification.

It is desiredto maintain the requirementfora ReactorAdministratorat this time due to the needfor a knowledgeable individualon thefacility duringthe decommissioning period. With the removal of thefuel, and hence the lack of a needfor licensedsenior reactoroperatorsat thefacility, the needfor a health physicist/SRO is negated As describedabove, these duties may befilfilled by other individuals. Currentneeds are minimal due to no activity in the building. At such time that decommissioning activities commence other radiologicalsupport will be determinedandacquired.

3. You have proposed deleting from TS 6.1.2 b. the requirement for designated personnel to be reachable and respond to the facility within approximately one hour. Your justification is with the removal of all reactor fuel from the facility, accident scenarios are similar to laboratories that use radioactive material on campus and that response is covered by the

campus Radiation Safety Manual. Please discuss why the Radiation Safety Manual is applicable to accident scenarios at the Nuclear Reactor Laboratory. Please describe the response outlined by the Radiation Safety Manual and the ability of university staff responding in accordance with the Radiation Safety Manual to initiate the requirements of the reactor emergency plan if needed.

The potentialforradiologicalaccidents at the Nuclear Reactor Laboratoryis now similarto a normal radiationlaboratoryon campus. The capacityfora fuel breach/releaseis now gone. The CampusRadiationSafety manual has response criteria in itfor an accident at a radiationlaboratoryto determine location, isotope, extent, containmentof the spill/incidentand cleanup. The campus RadiationSafety Office has someone on call at all times to provide response assistance in the event of an accident at a radiationlaboratory.

In addition,the Nuclear Reactor LaboratoryEmergency Plan andProceduresare still in effect andprovide detailed response to an incident at the laboratory. The accident criteriadescribedin the Emergency Plan are now significantlyreduced without the potentialforafissionproduct release. The Emergency Plan/Procedureshave a call list andproceduresforresponse at the facility including RadiationSafety Office support.

6.0 ADMINISTRATIVE CONTROLS 6.1 Organization 6.1.1 Structure and Responsibility

a. The reactor facility shall be an integral part of the Department of Nuclear, Plasma and Radiological Engineering of the University of Illinois. The reactor shall be related to the University structure as shown in Chart 1.

b. The reactor facility shall be under the supervision of the Reactor Administrator who shall have been qualified as a licensed senior reactor operator for the reactor. He shall be responsible for assuring that all operations are conducted in a safe manner and vithin the limits prescribed by the facility license and the provisions of the Nuclear Reactor Committee.

c. The Reactor Administrator. with support from the Radiation Safety Office, shall be responsible -lDeeted: ThiemshailbeaRactor for assuring the day to day and routine radiological safety activities at the Nuclear Reactor IHcaith Physicist Laboratory. The University of Illinois Radiation Safety Officer shall be responsible for monitoring, planning, and promoting radiological safety at the Nuclear Reactor Laboratory. He has the responsibility and authority to stop, secure or otherwise control as necessary any operation or activity that poses an unacceptable radiological hazard.

CHART I I Division of Environmental Health and Safety I I Radiation Safety Officerl I

CHART 1: Administrative organization of the reactor facility. Dashed lines indicate reporting paths outside the operational chain of supervision, indicated by solid lines.

6.1.2 Staffine

a. The minimum staffing at the Nuclear Reactor Laboratory shall be:

1. Reactor Administrator. This individual shall meet the requirements of ANSUANS-15.4-1988 "American National Standard for the Selection and Training of Personnel for Research Reactors" for a Level Two individual.

________ _ _ ____ _ __ __ ___ _Deleted: 2-Reactor Health Physicist.

This individual shall meetthe requirements of ANSLANS-15.4-l988

b. A list of reactor personnel by name and telephone number shall be readily available to the UIUC American National Standard forthe Division of Public Safety dispatcher. ,The list shall include: Selection and Training of Personnel for

___ ___ ___Research Reactors" for a Level Three individual in addition to training in health

1. Campus Radiation Safety Officcr physicas Deleted: One of these individuals shall

2. Reactor Administrator be reachable and able to respond to the facility within approximately one hour.

3. Head, Department of Nuclear Engineering I, [ Dekted: 4. Reactor Health Physicisti v _ _ ___

___ _ __ __ _ _ _ _ _ _ ___._Deleted: 5. Licensed opcraton

c. Events requiring the presence at the facility of a Senior Reactor Operator:

1. Initial startup and approach to power.

2. All fuel or control rod relocations..

3. Relocation of any in-core experiment with a reactivity worth greater than one dollar.

4. Recovery from unplanned or unscheduled shutdown or significant power reduction (In these instances, documented verbal concurrence from the Senior Reactor Operator is required).

6.1.3 Selection and Training of Personnel The Reactor Administrator is responsible for the training and requalification of the facility reactor operators and senior reactor operators. The selection, training, and requalification of operations personnel shall be consistent with all current regulations and guidelines.

6.2 Review and Audit 6.2.1 Charter and Rules

a. The Reactor Committee shall be composed of at least five voting members, one of whom shall be a Health Physicist designated by the campus Radiation Safety Officer for the Universityn, one whom _ -_ Deleted:.

shall be the Reactor AdministratorThe remaining members shall be appointed by the Head of the _ kted:,and one whom shall be the Department of Nuclear Engineering, so as to maintain a balanced knowledge of reactor safety and Reotor Health Physicist.

regulation.

b. The Reactor Committee shall have a written statement deening such matters as the authority of the committee, the subjects within its purview, and other such administrative provisions as are required for the effective functioning of the Reactor Committee Minutes of all meetings of the Reactor Committee shall be kept.

c. A quorum of the Reactor Committee shall be a majority of not less than one half of the members and the reactor staff shall not constitute a voting majority.

d. The Reactor Committee shall meet at least semiannually not to exceed nine months 62.2 Review Function The review function of the Committee shall include, but is not limited to the following:

a. Dctermination that proposed changes in equipment, systems, tests, experiments, or procedures do not involve an unreviewed safety question.

b. All new procedures and major revisions thereto having safety significance, proposed changes in reactor facility equipment, or systems having safety significance.

c. All new experiments or classes of experiments for determination that an unreviewed safety question does not exist

d. Proposed changes in the technical specifications or license.

e. Violations of technical specifications or license.

f. Operating abnormalities having safety significance.

g. Reportable occurrences as listed in 6.8.

h. Audit reports.

A written report or minutes of the findings and recommendations of the Committee shall be submitted to the Head, Department of Nuclear Engineering, and the Reactor Committee members in a timely manner after each meeting.

6.3 Radiation Safety I The Reactor Administrator shall be responsible for implementing the Radiation Protection Program at the - - Deleted Health Physici.t reactor such that all regulatory requirements are met and guidelines followed as applicable.

6.0 ADMINISTRATIVE CONTROLS 6.1 Organization 6.1.1 Structure and Responsibility

a. The reactor facility shall be an integral part of the Department of Nuclear, Plasma and Radiological Engineering of the University of Illinois. The reactor shall be related to the University structure as shown in Chart I.

b. The reactor facility shall be under the supervision of the Reactor Administrator who shall have been qualified as a licensed senior reactor operator for the reactor. He shall be responsible for assuring that all operations are conducted in a safe manner and within the limits prescribed by the facility license and the provisions of the Nuclear Reactor Committee.

c. The Reactor Administrator, with support from the Radiation Safety Office, shall be responsible for assuring the day to day and routine radiological safety activities at the Nuclear Reactor Laboratory. The University of Illinois Radiation Safety Officer shall be responsible for monitoring, planning, and promoting radiological safety at the Nuclear Reactor Laboratory. He has the responsibility and authority to stop, secure or otherwise control as necessary any operation or activity that poses an unacceptable radiological hazard.

CHART I Head of Department of Division of Environmental Nuclear Engineering Health and Safety RadiationSafety Officer:l Reactor - Reactor Administrator CommitteeI, .

Radiation Safety Office Support CHART I: Administrative organization of the reactor facility. Dashed lines indicate reporting paths outside the operational chain of supervision, indicated by solid lines.

6.1.2 Staffing

a. The minimum staffing at the Nuclear Reactor Laboratory shall be:

1. Reactor Administrator. This individual shall meet the requirements of ANSI/ANS-1 5.4-1988 "American National Standard for the Selection and Training of Personnel for Research Reactors" for a Level Two individual.

b. A list of reactor personnel by name and telephone number shall be readily available to the UJUC Division of Public Safety dispatcher. The list shall include:

1. Campus Radiation Safety Officer

2. Reactor Administrator

3. Head, Department of Nuclear Engineering

c. Events requiring the presence at the facility of a Senior Reactor Operator:

1. Initial startup and approach to power.

2. All fuel or control rod relocations..

3. Relocation of any in-core experiment with a reactivity worth greater than one dollar.

4. Recovery from unplanned or unscheduled shutdown or significant power reduction (In these instances, documented verbal concurrence from the Senior Reactor Operator is required).

6.1.3 Selection and Training of Personnel The Reactor Administrator is responsible for the training and requalification of the facility reactor operators and senior reactor operators. The selection, training, and requalification of operations personnel shall be consistent with all current regulations and guidelines.

6.2 Review and Audit 6.2.1 Charter and Rules

a. The Reactor Committee shall be composed of at least five voting members, one of whom shall be a Health Physicist designated by the campus Radiation Safety Officer for the University and one whom shall be the Reactor Administrator. The remaining members shall be appointed by the Head of the Department of Nuclear Engineering, so as to maintain a balanced knowledge of reactor safety and regulation.

b. The Reactor Committee shall have a written statement defining such matters as the authority of the committee, the subjects within its purview, and other such administrative provisions as are required for the effective functioning of the Reactor Committee Minutes of all meetings of the Reactor Committee shall be kept.

c. A quorum of the Reactor Committee shall be a majority of not less than one half of the members and the reactor staff shall not constitute a voting majority.

d. The Reactor Committee shall meet at least semiannually not to exceed nine months 6.2.2 Review Function The review function of the Committee shall include, but is not limited to the following:

a. Determination that proposed changes in equipment, systems, tests, experiments, or procedures do not involve an unreviewed safety question.

b. All new procedures and major revisions thereto having safety significance, proposed changes in reactor facility equipment, or systems having safety significance.

c. All new experiments or classes of experiments for determination that an unreviewed safety question does not exist.

d. Proposed changes in the technical specifications or license.

e. Violations of technical specifications or license.

f. Operating abnormalities having safety significance.

g. Reportable occurrences as listed in 6.8.

h. Audit reports.

A written report or minutes of the findings and recommendations of the Committee shall be submitted to the Head, Department of Nuclear Engineering, and the Reactor Committee members in a timely manner after each meeting.

6.3 Radiation Safety The Reactor Administrator shall be responsible for implementing the Radiation Protection Program at the reactor such that all regulatory requirements are met and guidelines followed as applicable.