ML043370224

Resubmittal of Package Dated September 8, 2004: Eliminate Reactor Health Physicist Position and One Hour on-call Requirement from Technical Specifications

ML043370224
Person / Time
Site:	University of Illinois
Issue date:	11/22/2004
From:	Holm R University of Illinois
To:	Alexander Adams NRC/FSME
References
Download: ML043370224 (16)

Text

Nuclear Reactor Laboratory niversity of Illinois at Urbana-Champaign Department of Nuc Jear, Radiological and Plasma Engineering I College of Engineering 0 214 Nuclear Engineering Lab 217-333-7755/0866 103 South Goodwin Avenue 217-333-2906 fax Urbana, IL 61801-2984 r-ho/m~uiuc.edu ReactorAdministrator:Richard L. Holm November 22, 2004 Docket No. 50-151 Mr. Alexander Adams, Jr.

United States Nuclear Regulatory Commission ATTN: Alexander Adams, REXB MS 012-G13 Washington, DC 20555-0001

SUBJECT:

Resubmittal of package dated September 8, 2004: Eliminate Reactor Health Physicist Positionand one hour on-call requirementfrom Technical Specifcations.

Dear Mr. Adams,

Please find enclosed a resubmittal, under oath and affirmation, of the package submitted September 8, 2004. I have also enclosed corrected "as incorporated" technical specification pages.

If there are any questions or concerns with this response, please contact me at 217-333-7755 or email at r-holm(iuiuc.edu.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 22nd, 2004.

Respectfully Submitted, Richard L. Holm Reactor Administator Attach.

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Nuclear Reactor Laboratory University of Illinois at Urbana-Champaign Department of Nuclear, Radiological and Plasma Engineering I College of Engineering 214 Nuclear Engineering Laboratory 217-333-7755A1866 103 South Goodwin Avenue 217-333-2906 fax Urbana. IL 61801-2984 rIiom@vufurc&du ReactorAdministrator: Richard L -oim September 8, 2004 Docket No. 50-151 Mr. Alexander Adams, Jr.

United States Nuclear Regulatory Commission ATIN: Alexander Adams, REXB MS 012-G13 Washington, DC 20555-0001

SUBJECT:

Eliminate Reactor Health Physicist Position and one hour on-call requirement from Technical Specifications.

Dear Mr. Adams,

Please find enclosed a request for changes to the Technical Specifications at the University of Illinois. The following attachments are enclosed:

• Justification for Changes - this document shows the "callout" on the revised specification and a justification for the change.

• Appropriate pages from the technical specifications showing the revisions.

• Appropriate pages from the technical specifications with the revisions incorporated.

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

Regards, Richard L. Holm Reactor Administator Attach.

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Justification for Sentember 2004 Chanees to UIUC Nuclear Reactor Laboratory Technical Specifications Docket 50-151 JUSTIFICATION:

1. JhepositionofReactorHealthPhysicist at the reactorhas been eliminated._Dutleswill be performed by rhe Reactor Dekted: Therme oll bea Re'aio I1k1rh Pys"Iu rmipmlbIfor uwwing Administratorandsupportfrom the Radiation Safety Office. the dqv to day ondrodbwrmhdog mSt aOrIcINa oVgA rMheAW Rfoccr l2. The ReactorHealth Physicist is replacedby "RadiationSafety Office Support . _ ____ _ ___

Deeted: Reacor Healthb Pf cskt

3. ,Theposition ofReacor Health Physicist at the reactorhas been eliminated. -- Deeted: 2.tescor lealh Pysicist.

This bndual shaf me the requnnb ofANSIIANS-15.4.1982

'Amrkan Natiocal Standad for the Seltkon xn Thinng of Pewonel for Reeab Retm' for aLmel Thne idiidmdal I addition to tWaing inheahm logertherheremoval offulfrmrhsfailiy,reducingthe amount ofSNMon-sine to less than 1Ograms, rkrequirementis no o oteia l longer necessary. Accident scenariosare now the same as an laboratoryusing radioactivematerial. Response to this type of D ekfd one arde"h&Ved$ Ot scenarioIs covered by the campus Radiation Safety Manual. I reachale aihn ableto andhoth.

5. th reactorhas been eliminated.

irin o Reactor HealthPhysicist arthe - Deed: 4. Res"to llheabPhkist]

6. JKrththe removal offuelfrom hefacilitythere are nolicense operators. _ _ _ - Delted: S. Lk.ened ot

7. Deleted a comma and Inserted "and"forgrammaticalcorrection. __ Dted:.

8. The position of Reactor HealthPhysicistat thereactorhas been eliminated. lenctorwln etbe I 9. 5Ince the Reactor Health Physicistposition elimsnaed (heiReactorAdministrator(nserted "Administrator') shallbe _ Dele: Health Phykcist responsibleforthe Radiation ProtectionProgram.

6.0 ADMINISTRAllVE CONTROLS 6.1 Oreanization 6.1.1 Structure and Resmonsibilitv

a. The reactor facility shall be an integral part of the Department of Nuclear, Plasma and Radiological Engineering ofthe 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 within the limits prescribed by the facility license and the provisions of the Nuclear Reactor Committee.

le. The University of Illinois Radiation Safety Officer shall be responsible for monitoring, _-rut rbw sa be aRod planning, and promoting radiological safety at the Nuclear Reactor Laboratory. He has the d a y l dygdi'a;U responsibility and authority to stop, secure or otherwise control as necessary any operation or sa&qy wtiv . &Nukwe Reaw at activity that poses an unacceptable radiological hazard. By CHART I Head of Department ofl Division of Environmental I Nuclear Engineering I Ilealth and Safety I c I iation Safiety Offceirl

!L~ --1 0 Radiation Safety Office _ _ - _IDeAd: Xn. HPeh tysky -j I I - Sunor I 3 CHART I: Administrative organization ofthe reactor facility. Dashed lines indicate reporting paths outside the operational chain of supervision, indicated by solid lines.

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

1. Reactor Administrator. This individuai shall meet the requirements ofANSIIANS-i5.A-I988 "American National Standard for the Selection and Training of Personnel for Research Reactors" for a Level Tut individual.

This 6divI l mla- te ANSVANS-13.4-IM8 fttellbof

b. A list ofreactor personnel by name and telephone number shall be readily available to the UIUC 'innN Sddor&

Division ofPublic Safety dispatcher. [he list shall include: SetetoTnmmgorf Pmoiwefor

1. Campus Radiation Safety Officer idboms ai A n mntg- henh Detd: ne o hese dim~vIfisfd l

2. Reactor Administrator be w h and "i to Apdw othe faeitay wih qppreximately ow barn.

3. Ilead, Department ofNuclear Engineering j ._De_ ___eted__4_ ______ __ikh__i_ __._

' c. Events requiring the presence at the facility of a Senior Reactor OperatorS

1. Initial startup and approach to power.

2. All fuel or control rod relocations..

3. Relocation ofany 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).

6.13 Selection and Training orPersonnel 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 Universityji, one whom_ DeI d:.

shall be the Reactor Administrator,The remaining mr s hall b appointede by the Headofthe__d Department orNuclear 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 halfof the members and the reactor staffshall not constitute a voting majority.

d. The Reactor Committee shall meet at least semiannually not to exceed nine months 6.22 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 ofexperiments for determination that an unreviewed safety question does not exist.

d. Proposed changes in the technical specifications or license.

e. Violations ortechnical 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 orthe findings and recommendations of the Committee shall be submitted to the Head, Department orNuclear Engineering, and the Reactor Committee members in a timely manner after each meeting.

6.3 Radiation Savety The ReactorAdministrator shall be responsible for implementing the Radiation Protec ion Program at the - Ddes: shhbicit reactor such that all regulatory requirements arc 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 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 within the limits prescribed by the facility license and the provisions of the Nuclear Reactor Committee.

c. 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 DivisiozI of Environmental Nuclear Engineering Hea ilth and Safety a------

Lion Safety Ofie itor:

I.1

- - - I Radiation Safety Office Support 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 Staffing

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

1. Reactor Administrator. This individual shall meet the requirements of ANSI/ANS-15.4-1988 "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 UIUC 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.

C -

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.

Corrected pages to Insert November 22, 2004

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 Nuclear, Plasma and Radiological Enginecring Division of Environmental Health and Safety r

I-I Radiation Safety Officer tor I I I I

. I 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 StaffinQ

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

1. Reactor Administrator. This individual shall mect the requirements of ANSIIANS-15.4-1988 "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 UIUC Division of Public Safety dispatcher. The list shall include:

1. Campus Radiation Safety Officer

2. Reactor Administrator

3. Head, Department of Nuclear, Plasma and Radiological 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, Plasma and Radiological 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. Determinations 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.

c. 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, Plasma and Radiological 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.