ML20034F168
| ML20034F168 | |
| Person / Time | |
|---|---|
| Site: | Washington State University |
| Issue date: | 04/08/2020 |
| From: | Michael Balazik NRC/NRR/DANU/UNPL |
| To: | Hines C Washington State Univ |
| Balazik M, NRR/DANU/UNPL, 301-415-2856 | |
| Shared Package | |
| ML20034F306 | List: |
| References | |
| Download: ML20034F168 (14) | |
Text
Enclosure 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 21 TO FACILITY OPERATING LICENSE NO. R-76 WASHINGTON STATE UNIVERSITY WASHINGTON STATE UNIVERSITY MODIFIED TRIGA NUCLEAR REACTOR DOCKET NO. 50-27
1.0 INTRODUCTION
By letter dated September 30, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19273A941), as supplemented by letter dated January 27, 2020 (ADAMS Accession No. ML20027C553), the Washington State University (the licensee or WSU) requested an amendment to the technical specifications (TSs) for the WSU Modified TRIGA (Training, Research, Isotopes, General Atomics) Nuclear Reactor. The requested amendment would revise TS Section 1, Definitions, Section 3, Limiting Conditions of Operation, and Section 4, Surveillance Requirements, Section 5, Design Feature, Section 6, Administrative Control.
2.0 REGULATORY EVALUATION
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed WSUs license amendment request (LAR). The NRC staff evaluated the proposed changes based on the regulations and guidance in:
Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, Section 50.36, Technical specifications, which provides the requirements for TSs to be included in facility operating licenses, including research reactor licenses. Section 50.36(a)(1) requires that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs.
Section 50.36(c)(2), Limiting conditions for operation, requires that TSs include limiting conditions for operation that specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. Section 50.36(c)(3),
Surveillance requirements, requires that TSs include requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation (LCOs) will be met. Section 50.36(c)(4), Design features, requires that TSs include those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety. Section 50.36(c)(5), Administrative controls, requires that TSs include provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, which identifies licensing, regulatory, and administrative actions eligible for categorical exclusion from the requirement to prepare an environmental assessment or environmental impact statement.
NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content, Appendix 14.1, Format and Content of Technical Specifications for Non-Power Reactors; Section 3.3, Coolant Systems; and Section 4.3, Coolant Systems (ADAMS Accession No. ML042430055),
which provides guidance to licensees preparing research reactor applications and TSs.
NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, Chapter 14, Technical Specifications (ADAMS Accession No. ML042430048), which provides guidance to the NRC staff for performing reviews of the LAR.
NRC Memorandum, Research and Test Reactors Pool Water - Safety Evaluation on Electrolytic Conductivity dated May 11, 2015 (ADAMS Accession No. ML15114A433).
American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors, Section 5.1, Site and facility description, Section 6.1, Organization, Section 6.1.1, Structure, and Section 6.1.2, Responsibility, which provides guidance on design features (including building location) and administrative controls that should be included in the TSs. The 2007 version was a revision of the ANSI/ANS-15.1-1990 standard cited in NUREG-1537 that was issued in 1996. Sections 5.1, 6.1, and 6.1.2 of the 2007 standard are not substantively different from the 1990 version. However, Section 6.1.1 of the 1990 standard provides examples of Level 4 operating staff as Class A and B Reactor Operators and trainees differing from the 2007 standard. The 2007 standard provides examples of Level 4 operating staff as senior reactor operators, reactor operators, and trainees. Because WSU uses the terms Senior Reactor Operator, Reactor Operator, and Reactor Operator trainees in the TSs, the NRC staff used the current version, ANSI/ANS-15.1-2007, to conduct this TS review.
ANSI/ANS-15.4-2007, Selection and Training of Personnel for Research Reactors, Section 3.5, Level 4, which provides guidance on the responsibilities for the staffing of Level 4 positions. The licensees TSs commit to using the guidance in ANSI/ANS-15.4-2007. TS 6.3, Selection and Training of Personnel, states the that the selection, training and requalification of each member of operations personnel shall meet or exceed the requirements of ANSI/ANS-15.4-2007.
3.0 TECHNICAL EVALUATION
3.1 Technical Specification 1, Definitions, Licensed Area WSU proposed to change the formatting of the TS 1 definition of Licensed Area by realigning the numbered list at the left margin to match other lists contained in the TSs.
The NRC staff reviewed the proposed change and finds that the proposed reformatting is consistent with the format in other TSs and does not substantively alter the content of the TS.
Therefore, NRC staff finds the proposed editorial change acceptable.
3.2 Technical Specification 3.3, Primary Coolant Conditions, Specification (2)
WSU proposed to delete TS 3.3, Specification (2), thereby removing the requirement that the primary coolant have a pH range between 5.0 and 7.5 and to renumber the remaining specifications in TS 3.3 to reflect the deletion of the pH requirement. In its LAR, WSU states that, due to the relationship between conductivity and pH, the current limit and surveillance requirement in the WSU TSs for conductivity provide acceptable pH control of primary coolant chemistry to prevent corrosion of reactor components. WSU also states that NRC Memorandum, Research and Test Reactors Pool Water - Safety Evaluation on Electrolytic Conductivity, concluded that the TS on pH limits and measurement of pool water may be eliminated if there is a requirement to limit electrolytic conductivity and an associated surveillance schedule. WSU further states that the primary coolant conductivity monitoring system is a real-time continuous measurement that will alarm at the reactor control console to alert the operator of increased conductivity at 1.1 micromhos/cm (1.1 microsiemens/cm).
TS 3.3, Specification (1), requires a conductivity limit of no higher than 5 micromhos/cm (5 microsiemens/cm) as an LCO for the WSU TRIGA reactor.
The current TS 3.3 Specifications state:
(1) Conductivity of the primary coolant shall be no higher than 5 x 10-6 mhos/cm.
(2) The pH of the primary coolant shall be between 5.0 and 7.5.
(3) The bulk primary coolant temperature shall not exceed 50 °C.
(4) The radionuclide content of the primary coolant shall not exceed 10 CFR 20 effluent release limits.
(5) The reactor shall not be operated with less than 16 feet of water above the top of the core.
The proposed TS 3.3 Specifications state:
(1) Conductivity of the primary coolant shall be no higher than 5 x 10-6 mhos/cm.
(2) The bulk primary coolant temperature shall not exceed 50 °C.
(3) The radionuclide content of the primary coolant shall not exceed 10 CFR 20 effluent release limits.
(4) The reactor shall not be operated with less than 16 feet of water above the top of the core.
The NRC staff evaluated the proposed deletion of the LCO requiring a specific primary coolant pH range using information in NUREG-1537, Part 1, Section 3.3; and the 2015 Conductivity safety evaluation (SE). In the 2015 Conductivity SE, the NRC staff concluded that conductivity would be an effective control measure for maintaining the reactor primary pool water purity sufficient to minimize the potential for corrosion or oxidation of submerged reactor components in the pool, including fuel element cladding. The NRC staff also concluded in the 2015 Conductivity SE that for open (to the atmosphere) pool light water reactor coolant systems, the relationship between high purity water and conductivity at or below 5 micromhos/cm (5 microsiemens/cm) ensures that the pH values will remain within 5.6 to 5.8. The NRC staff further concluded in the 2015 Conductivity SE that the requirement to maintain pH is not necessary if the facility design includes an open reactor primary pool coolant system and the facilitys TSs and related surveillance require the reactor coolant water to be maintained at a conductivity of 5 micromhos/cm (5 microsiemens/cm) or less.
As stated in Chapter 4, Reactor Description, Section 4.1, Summary Description, of the WSU safety analysis report (SAR), dated June 6, 2002 (ADAMS Accession No ML092390202), the WSU TRIGA reactor is a one megawatt open pool-type research reactor using light-water as a moderator, coolant, reflector, and shield. In addition, TS 3.3, Specification (1), requires conductivity of the primary coolant in the pool to be no higher than 5 x 10-6 mhos/cm (5 microsiemens/cm), which is equivalent to 5 micromhos/cm (5 microsiemens/cm) and is sufficient to maintain water quality at pH values within the range currently required by TS 3.3, Specification (2). Further TS 4.3, Primary Coolant Conditions, Specification (1), requires conductivity of the primary coolant water to be measured at least once every two weeks, the same interval currently required for pH measurements. The amendment request would not change the conductivity requirements in TS 3.3, Specification (1), and TS 4.3, Specification (1).
The NRC staff reviewed the proposed deletion of the pH range requirement from TS 3.3, and finds that because the design of the WSU TRIGA reactor and the current conductivity limit of 5 x 10-6 mhos/cm (5 microsiemens/cm) in TS 3.3, Specification (1) is consistent with the criteria in the 2015 Conductivity SE to ensure that the pH will be adequately maintained to prevent corrosive degradation of submerged reactor components in the pool. Thus, the lowest functional capability or performance levels of equipment required for safe operation of the facility will be maintained.
Based on the above, the NRC staff finds the current required pH range in TS 3.3 for primary coolant is not needed to meet the 10 CFR 50.36(c)(2) requirement that an LCO specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. Therefore, the NRC staff concludes that the proposed deletion of TS 3.3, Specification (2), is acceptable.
The NRC staff also evaluated the WSU proposed renumbering of the Specifications in TS 3.3 to reflect the proposed removal of the pH requirement in TS 3.3, Specification (2). The NRC staff concludes that WSUs proposed renumbering of the specifications in TS 3.3 is editorial, and therefore is acceptable.
3.3 Technical Specification 4.3, Primary Coolant Conditions, Specification (1)
WSU proposed to delete the surveillance requirement to measure pH of the primary coolant water at least once every two weeks from TS 4.3, Specification (1). Additionally, WSU proposed to revise the surveillance frequency from 2 weeks to two weeks.
The current TS 4.3, Specification (1) states:
The conductivity and pH of the primary coolant water shall be measured at least once every 2 weeks.
The proposed TS 4.3, Specification (1) states:
The conductivity of the primary coolant water shall be measured at least once every two weeks.
The proposed change would delete the words and pH from TS 4.3, Specification (1) and would change 2 weeks to two weeks. As stated in Section 3.2 of this SE, the NRC staff finds that the removal of the pH requirement for the reactor primary coolant in current TS 3.1, Specification (1), is acceptable because current conductivity limit of 5 x 10-6 mhos/cm (5 microsiemens/cm) in TS 3.3, Specification (1) is consistent with the criteria in the 2015 Conductivity SE to ensure that the pH will be adequately maintained to prevent corrosive degradation of submerged reactor components in the open pool. Similarly, the NRC staff finds that the surveillance to measure pH of the primary coolant water at least once every two weeks in TS 4.3 is not required to maintain water quality of the pool. The proposed change would not change the requirement in TS 4.3, Specification (1), that WSU measure conductivity of the primary coolant water at least once every two weeks. The existing requirement to measure conductivity at least once every 2 weeks is sufficient to confirm that primary coolant chemistry is maintained at pH levels that prevent corrosive degradation of submerged reactor components in the pool. Therefore, the NRC staff finds that the proposed deletion of the surveillance requirement to measure the pH of the reactor primary coolant water is not needed to meet the 10 CFR 50.36(c)(3) requirement that TSs require tests, calibration or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met. Therefore, the staff finds the proposed change to TS 4.3 acceptable.
Additionally, the NRC staff reviewed the proposed revision to the surveillance frequency from 2 weeks to two weeks in TS 4.3, Specification (1), because this editorial change does not alter the existing required surveillance interval, the NRC staff finds the proposed change acceptable.
3.4 Technical Specification 5.1, Site and Facility Description WSU proposed to revise TS 5.1, Specification (1), to update the organization name that operates the WSU Modified TRIGA Nuclear Reactor from Nuclear Radiation Center, to Nuclear Science Center, to describe the site in TS 5.1, Specification (1).
The current TS 5.1, Specification (1), states:
The site is that area bound by the perimeter that encloses the Nuclear Radiation Center building, (also known as the Dodgen Research Facility), the fenced area immediately outside the east pool room loading dock door and the fenced area immediately outside the beam room west loading dock door.
The proposed TS 5.1, Specification (1), states:
The site is that area bound by the perimeter that encloses the Nuclear Science Center building, (also known as the Dodgen Research Facility), the fenced area immediately outside the east pool room loading dock door and the fenced area immediately outside the beam room west loading dock door.
WSU proposed to change TS 5.1, Specification (1), by deleting Radiation and replacing it with Science to reflect a change in the name of the organization that operates the facility. The NRC staff evaluated the proposed change using guidance in ANSI/ANS-15.1-2007, Section 5.1, Site and facility description, which states that a general description of the site and of the facility include location and exclusion or restricted areas shall be presented. The NRC staff finds that that updating the name of a portion of the building that houses the facility licensed area to reflect the operating organization name change is appropriate and does not significantly alter the physical site and boundary specified in TS 5.1, Specification (1). Because design features such as the site geometric arrangements, restricted area boundary, and reactor design do not change, therefore the NRC staff finds that the TS, as revised, is consistent with 10 CFR 50.36(c)(4) and the proposed change is acceptable.
3.5 Technical Specification, Section 6, Administrative Control WSU proposed to revise Section 6 of the TSs to change the name of the organization that operates the WSU TRIGA reactor, from Nuclear Radiation Center to Nuclear Science Center, to accurately reflect the updated name of the organization.
The current TS 6.1, Responsibility and Organization, states, in part:
(1) The Washington State University research reactor shall be operated by the Nuclear Radiation Center of Washington State University.
The proposed TS 6.1, Specification (1), states, in part:
(1) The Washington State University research reactor shall be operated by the Nuclear Science Center of Washington State University.
The current TS 6.4.1, Function, states, in part:
The Reactor Safeguards Committee shall function to provide an independent review and audit of the Nuclear Radiation Center activities including:
The proposed TS 6.4.1 states, in part:
The Reactor Safeguards Committee shall function to provide an independent review and audit of the Nuclear Science Center activities including:
The current TS 6.4.2, Composition and Qualifications, Specification (2)(a) states that:
one Senior Reactor Operator who may be the Director of the Nuclear Radiation Center. The presence of Nuclear Radiation Center staff members shall not be counted to constitute a quorum. Nuclear Radiation Center staff members shall not be voting members of the Committee.
The proposed TS 6.4.2, Specification (2)(a) states:
one Senior Reactor Operator who may be the Director of the Nuclear Science Center. The presence of Nuclear Science Center staff members shall not be counted to constitute a quorum. Nuclear Science Center staff members shall not be voting members of the Committee.
The current TS 6.4.2, Specification (4) states, in part:
The Reactor Safeguards Committee is a WSU Presidential Committee which performs reviews and audits of the WSU Nuclear Radiation Center.
The proposed TS 6.4.2, Specification (4) states, in part:
The Reactor Safeguards Committee is a WSU Presidential Committee which performs reviews and audits of the WSU Nuclear Science Center.
The current TS 6.4.4, Reviews, Specification (3) states:
review of the operation and operational records of the Nuclear Radiation Center; The proposed TS 6.4.4, Specification (3) states:
review of the operation and operational records of the Nuclear Science Center; WSU proposed to change the above TSs in Section 6 by deleting Radiation and replacing it with Science to reflect the updated name of the organization that operates the reactor. The NRC staff evaluated the proposed changes using guidance in ANSI/ANS-15.1-2007, Section 6.1, Organization, which states that the functions, assignments, responsibilities shall be specified. The NRC staff finds that the updated name does not alter the responsibilities and structure of the operating organization. The NRC staff also finds that (1) the change to TS 6.4.2, Section (2)(a) is to the position or title of an officer of the licensee, is consistent with ANSI/ANS-15.1-2007, Section 6, in that the TSs continue to specify that WSU have the organization structure and management responsible for reactor facility operations and (2)
TS 6.4.2(2)(a) and the other above-listed TSs, as revised, continue require the organization and management to assure safe operation of the facility as required by 10 CFR 50.36(c)(5).
Therefore, the NRC staff concludes that the proposed changes are acceptable.
3.6 Technical Specification 6.1, Responsibility and Organization, and Technical Specification 6.4.2, Composition and Qualifications WSU proposed to revise TS 6.1 and TS 6.4.2 to change the title, Director of the Nuclear Radiation Center, to Director of the Nuclear Science Center, to update the position title to reflect the name change of the organization that operates the WSU TRIGA Reactor.
The current TS 6.1, Section (2)(b), which specifies the WSU organizational levels and responsibilities, states, in part:
Director of the Nuclear Radiation Center (Level 2): The Director of the Nuclear Radiation Center shall report to the Vice President for Research.
The proposed TS 6.1, Section (2)(b) states, in part:
Director of the Nuclear Science Center (Level 2): The Director of the Nuclear Science Center shall report to the Vice President for Research.
The current TS 6.1, Section (2)(c) states:
Reactor Supervisor (Level 3):
(i)
The Reactor Supervisor shall report to the Director of the Nuclear Radiation Center and is responsible for guidance, oversight, and technical support of reactor operations.
(ii)
The Reactor Supervisor shall report to the Director of the Nuclear Radiation Center and to the Reactor Safeguards Committee in matters of radiation protection.
The proposed TS 6.1, Section (2)(c) states:
Reactor Supervisor (Level 3):
(i)
The Reactor Supervisor shall report to the Director of the Nuclear Science Center and is responsible for guidance, oversight, and technical support of reactor operations.
(ii)
The Reactor Supervisor shall report to the Director of the Nuclear Science Center and to the Reactor Safeguards Committee in matters of radiation protection.
The current TS 6.1, Section (2)(e)(iii) states:
The Director of the Radiation Safety Office, as an ex-officio member of the Reactor Safeguards Committee shall provide communication regarding radiation safety to the Director of the Nuclear Radiation Center.
The proposed TS 6.1, Section (2)(e)(iii) states:
The University Radiation Safety Officer, as an ex-officio member of the Reactor Safeguards Committee shall provide communication regarding radiation safety to the Director of the Nuclear Science Center.
The NRC staff evaluated the proposed change using guidance in ANSI/ANS-15.1-2007, Section 6.1.1, Structure, which states that the organization for the management and operation of the facility include an individual responsible for facility operation. The NRC staff finds that, under the proposed changes, the responsibilities and reporting and communicating lines of the director specified in TS 6.1(2) remain unchanged. The NRC staff also finds that the change to the TSs, as revised, position or title of an officer of the licensee, is consistent with guidance, and will help ensure will continue to require that WSU will continue to have administrative controls relating to the organization and management that helps to assure operation of the facility in a safe manner as required by 10 CFR 50.36(c)(5). Therefore, the NRC staff concludes that the proposed changes to TS 6.1 and TS 6.4.2 are acceptable.
3.7 Technical Specification 6.1, Responsibility and Organization and Technical Specification 6.4.2, Composition and Qualifications WSU proposed to revise TS 6.1 and TS 6.4.2 to update the organizational reporting lines and titles within the facility organization. WSU proposed to change the title of the, Director of the Radiation Safety Office, to University Radiation Safety Officer, to reflect an organizational change at WSU. In its LAR, WSU states that, in the past, the Director of the Radiation Safety Office and the Radiation Safety Officer have been the same individual, but after the organizational change at WSU, the Radiation Safety Office was moved under the WSUs Office of Research Assurances and the Director of the Office of Research Assurances and the University Radiation Safety Officer are no longer the same individual. WSU also proposed to revise TS Figure 6.1 to add the Director of the Office of Research Assurances to accurately reflect an organizational change and the change in the licensee position title from Director of the Nuclear Radiation Center to Director of the Nuclear Science Center. Further, WSU proposed to revise Figure 6.1 to add Level 4 to the reactor operating staff organization level as shown in the facility organization structure.
The current TS 6.1, Figure 6.1, Facility Organization, states:
The proposed TS 6.1, Figure 6.1, states:
The current TS 6.1, Section (2)(e)(iv) states:
The Director of the Radiation Safety Office shall have oversight, through the Reactor Safeguards Committee, of activities utilizing radioactive material.
The proposed TS 6.1, Section (2)(e)(iv) states:
The University Radiation Safety Officer shall have oversight, through the Reactor Safeguards Committee, of activities utilizing radioactive material.
The current TS 6.4.2, Section (3) states:
The Director of the WSU Radiation Safety Office shall be an ex-officio member of the Committee.
The proposed TS 6.4.2, Section (3) states:
The University Radiation Safety Officer shall be an ex-officio member of the Committee.
The NRC staff evaluated the changes to TS 6.1 and TS 6.4.2 using the guidance in ANSI/ANS-15.1-2007, Section 6.1.1, which states that radiation safety personnel shall report to Level 2 or higher and that other organizational levels or staffing may be added to meet specific facility needs. The NRC staff finds that the communication lines and responsibilities of facility radiation safety personnel remains unchanged as a result of the organizational changes at WSU. The addition of the WSU Director of the Office of Research Assurances to TS Figure 6.1 is consistent with ANSI/ANS-15.1-2007, Section 6.1.1, in that staffing may be added to the organizational structure to meet specific facility or organizational needs. The NRC staff also finds that the proposed changes maintain the radiation safety personnel reporting line to Level 1 management, albeit now through the WSU Director of the Office of Research Assurances. The NRC staff also evaluated the changes to TS Figure 6.1 using the guidance in ANSI/ANS-15.1-2007, Section 6.1.1 and ANSI/ANS-15.4-2007, Section 3.5, which describes the Level 4 organization as the operating staff, such as senior reactor operators and reactor operators. The NRC staff finds that adding Level 4 to the Reactor Operating Staff organizational structure in TS Figure 6.1 is consistent with the guidance because Level 4 accurately describes the operating staff, the reporting lines of the operating staff are unchanged, and operating staff activities would continue to be directed by the reactor supervisor (Level 3). Also, as stated in Section 3.5 of this SE, the NRC staff concluded that changing the name of the facility director from Director of the Nuclear Radiation Center to Director of the Nuclear Science Center is acceptable to reflect the new name of the organization that operates the reactor. Because the changes to TS 6.1 and TS 6.4.2 are consistent with guidance and provide administrative controls relating to organization, management, review, and reporting that are necessary to assure operation of the facility in a safe manner as required by 10CFR50.36(c)(5), the NRC staff finds the proposed changes acceptable.
3.8 Technical Specifications Bases Changes Consistent with 10 CFR 50.36(a)(1), WSU provided revised basis statements related to proposed TSs 3.3, 4.3, and 5.1 that explain the reasons for the proposed TSs.
3.9 Conclusion The NRC staff evaluated WSUs proposed changes to the TSs in the LAR, as supplemented.
The NRC staff finds that proposed revisions to TS 3.3.1 and TS 4.3 that remove the pH range and associated surveillance requirement are consistent with NUREG-1537, Part 1, ANSI/ANS-15.1-2007 and the 2015 Conductivity SE, and meet the 10 CFR 50.36(c)(2) and (3) requirements. Further, the NRC staff finds that the proposed revision to TS 5.1, to revise the name of the operating organization is consistent with the guidance in ANSI/ANS-15.1-2007 and that, apart from the updated organization name, the physical site description and boundary specified in TS 5.1 remains unchanged and accurately describes the site. The NRC staff also finds that the revisions to TS 6.1, TS 6.4.1, TS 6.4.2, and TS 6.4.4 updating the organization, positions and reporting lines are consistent with the guidance in ANSI/ANS-15.1-2007, Section 6, and will continue to provide organization and management controls that assure operation of the facility in a safe manner as required by 10CFR50.36(c)(5).
Therefore, based on its review, the NRC staff concludes that the requested revisions to the WSU Modified TRIGA Nuclear Reactor TSs are acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
Pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement is required for any action within the category of actions listed in 10 CFR 51.22(c), for which the Commission has declared to be a categorical exclusion by finding that the action does not individually or cumulatively have a significant effect on the human environment.
4.1 Regulatory Evaluation This amendment revises TS 3.3 and TS 4.3 and thus involves changes to a requirement in the installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, Standards for Protection against Radiation. The issuance of this amendment meets the requirements for the categorical exclusion under 10 CFR 51.22(c)(9) provided that:
(i)
The amendment involves no significant hazards consideration; [10 CFR 51.22(c)(9)(i)]
The regulations in 10 CFR 50.92(c) states that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the proposed amendment, would not:
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated [10 CFR 50.92(c)(1)]; or As discussed in Section 3 of this SE, the proposed changes to TS 3.3 and TS 4.3 would delete the LCO that specifies a pH range and delete the associated surveillance requirement to control reactor primary pool water chemistry to reduce the potential for corrosion and oxidation of submerged reactor components, including fuel element cladding. The pH is controlled, within the currently required range, by the existing TS conductivity limit for the WSU open pool light water reactor because of the relationship between pH and conductivity. Therefore, the existing conductivity limit and surveillance frequency are sufficient to maintain pH within the range previously required to help ensure that the potential for corrosion of reactor fuel or submerged reactor components are minimized. The previously evaluated accident that could be affected by this amendment is the failure of the fuel element cladding as a result of corrosion. This accident scenario was previously evaluated in the 2007 conversion SAR, dated August 15, 2007 (ADAMS Accession No. ML080170058) by postulating the maximum hypothetical accident (MHA) and assumes that the release of fission products from a TRIGA fuel element to the unrestricted environment results in radiological consequences. The proposed amendment does not change the licensed power level of the reactor, fission product inventory, or design features of the reactor and does not change any potential release paths from the facility.
Therefore, the NRC staff finds that the proposed changes to TS 3.3 and TS 4.3 do not involve a significant increase in the probability or consequences of an accident previously evaluated.
(2) Create the possibility of a new or different kind of accident from any accident previously evaluated [10 CFR 50.92(c)(2)]; or The changes in TS 3.3 and TS 4.3 would delete the LCO that specifies a pH range and delete the associated surveillance requirement to control reactor primary pool water chemistry to reduce the potential for corrosion and oxidation of submerged reactor components, including fuel element cladding. The pH is controlled, within the currently required range, by the existing TS conductivity limit for the WSU open pool light water reactor because of the relationship between pH and conductivity.
Therefore, the existing conductivity limit and surveillance frequency are sufficient to maintain pH within the range previously required to help ensure that the potential for corrosion of reactor fuel and submerged reactor components are minimized. These TS changes do not authorize installation of new equipment or significantly change the operation of the facility. In addition, there is no change to the licensed power level of the reactor or fission product inventory. As a result, the changes do not change or create any new potential release paths at the facility. Further, the changes do not adversely affect any current system interfaces or create any new interface that could result in an accident or malfunction that is different from that previously evaluated. Therefore, the NRC staff finds that the proposed changes to TS 3.3 and TS 4.3 do not create the possibility of a new or different kind of accident from any accident previously evaluated.
(3) Involve a significant reduction in a margin of safety [10 CFR 50.92(c)(3)].
The changes in TS 3.3 and TS 4.3 would delete the LCO that specifies a pH range and delete the associated surveillance requirement to control reactor primary pool water chemistry to reduce the potential for corrosion and oxidation of submerged reactor components, including fuel element cladding. The pH is controlled within the specified range by the existing TS conductivity limit and associated surveillance for the WSU open pool light water reactor because of the relationship between pH and conductivity. Therefore, the existing conductivity limit and surveillance frequency are sufficient to maintain pH within the range previously required to help ensure that the potential for corrosion of reactor fuel and submerged reactor components are minimized. Because existing requirements for control of conductivity in TS 3.3 and TS 4.3 are sufficient to maintain reactor coolant pH within the range required by the deleted TSs, the changes to these TSs do not reduce the margin of safety.
Therefore, the NRC staff finds that the issuance of an amendment authorizing the proposed changes does not involve a significant reduction in a margin of safety.
(ii)
There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; and [10 CFR 51.22(c)(9)(ii)]
The changes in TS 3.3 and TS 4.3 would delete the LCO that specifies a pH range and delete the associated surveillance requirement to control reactor primary pool water chemistry to reduce the potential for corrosion and oxidation of submerged reactor components, including fuel element cladding. The pH is controlled by the existing TS conductivity limit and the associated surveillance for the WSU open pool light water reactor because of the relationship between pH and conductivity. Therefore, the existing conductivity limit and surveillance frequency are sufficient to maintain pH within the range previously required to help ensure that the potential for corrosion of reactor fuel and submerged reactor components are minimized. This amendment does not change the licensed power level of the reactor or any reactor design features. Further, the amendment does not change the amount or type of special nuclear material authorized to be possessed and used at the facility. Moreover, TS 3.3, Specification (4), requires the radionuclide content of the reactor coolant shall not exceed 10 CFR Part 20 effluent limits. Thus, the NRC staff finds that there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite due to allowing conductivity to limit reactor primary coolant pH.
(iii)
There is no significant increase in individual or cumulative occupational radiation exposure [10 CFR 51.22(c)(9)(iii)].
The changes in TS 3.3 and TS 4.3 would delete the LCO that specifies a pH range and delete the associated surveillance requirement to control reactor primary pool water chemistry to reduce the potential for corrosion and oxidation of submerged reactor components, including fuel element cladding. The pH is controlled by the existing TS conductivity limit and associated surveillance for the WSU open pool light water reactor because of the relationship between pH and conductivity. Therefore, the existing conductivity limit and surveillance frequency are sufficient to maintain pH within the range previously required to help ensure that the potential for corrosion of reactor fuel and submerged reactor components are minimized. This amendment does not change the licensed power level of the reactor or the facility design and does not increase the individual or cumulative in radiation exposure. TS 6.5, Radiation Safety, which is not altered by this amendment, still requires the implementation of a radiation protection program to ensure that individual and cumulative occupational radiation exposure are as low as is reasonably achievable and within 10 CFR Part 20 limits. Therefore, the NRC staff finds that there is no significant increase in individual or cumulative occupational radiation exposure.
The proposed amendment also changes TS 1, TS 5.1, TS 6.1, TS 6.4.1, TS 6.4.2, and TS 6.4.4.
Thus, the amendment involves changes to recordkeeping, reporting, or administrative procedures or requirements and is subject to categorical exclusion pursuant to 10 CFR 51.22(c)(10)(ii); changes to the position or title of an officer of the licensee and is subject to categorical exclusions pursuant to 10 CFR 51.22(c)(10)(iv); and changes to formatting or makes editorial, corrective or other minor changes and is subject to categorical exclusions pursuant to 10 CFR 51.22(c)(10)(v).
4.2 Conclusion Accordingly, the NRC staff has determined that issuance of this amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area under 10 CFR Part 50. The NRC staff has determined that amendment involves no significant hazards consideration as well as no significant increase in the amounts, and no significant increase in the types, of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure. In addition, issuance of the amendment changes recordkeeping, reporting, or administrative procedures or requirements; changes the position or title of an officer of the licensee; and makes formatting, editorial, corrective, or other minor changes. Therefore, this amendment meets the eligibility criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9), (c)(10)(ii), (c)(10)(iv), and (c)(10)(v). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Michael Balazik, NRR Date: April 8, 2020