License Amendments Patrick Boyle Nuclear Engineer

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Presentation transcript:

License Amendments Patrick Boyle Nuclear Engineer Research and Test Reactors Licensing Branch

License Amendments 10 CFR 50.90 10 CFR 50.59(c)(1)-Changes may be made without obtaining a license amendment per 50.90 only if: (i) A change to the technical specifications incorporated in the license [Appendix A] is not required (ii) does not meet any of the criteria in … (c)(2) Application for amendment 50.90 Issuance of Amendment 50.92 Noticing 50.91 – not required for most RTR NIST is the only test reactor, and as such is the only one required to notice an amendment (No Significant Hazards Consideration) per 50.91.

License Amendments Submittal Requirements 10 CFR 50.4 - All license amendment requests and supplemental correspondence must be signed and submitted under oath or affirmation including: Initial request Supplemental information Response to a letter from the NRC (RAI) Response to a conversation or email with the NRC provided the question is restated in the response (public disclosure requirement) May be volunteered for clarification Any information not submitted per 50.4 cannot be used in a regulatory decision.

License Amendments Content Per 10 CFR 50.90 must fully describe the changes desired, and following as far as applicable, the form prescribed for the original application What is being changed? What is the relation to safety? How is the safety basis affected? What makes the change acceptable? (especially when safety margin is decreased) These questions should have been developed when performing the 50.59 screening. Now the information needs to go to the NRC to determine acceptability. The answer to an amendment request can be “no.”

License Amendments Safety Analysis If equipment-related, how does it currently function and describe how that function is affected by the change If new equipment or interface is included describe potential failures Build “What if” scenarios Consider partial failures Consider impact to other equipment or ability to operator to respond (is equipment used to make operational decisions?) Discuss redundancy impact (defense in depth)

License Amendments WHY? NRC needs to determine: Do the bases and assumptions make sense? Can the information be independently verified? quantifiable - perform separate calculation/analysis engineering judgment - consistent with current practices Is the impact to safety is acceptable (FINE PRINT: reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner)

License Amendments TS Revisions Marked up original TS Only replace page(s) affected by change (with change bars in margin) Cannot change other sections of TS without specifically addressing in request letter (includes administrative changes) Wholesale replacement of all TS pages requires careful review for unintended changes

License Amendment Opportunities Original bases may need to be more robust Formatting less than ideal TS wording may include ambiguities Equipment function descriptions can be enhanced TS may contradict other sections

License Amendments Current Status License renewal included attempt to “modernize” TS and bases ANS 15.1/NUREG-1537 includes allowance for action statements related to Limiting Conditions for Operation Equipment LAR are very infrequent Currently have 12 amendment request in progress that are not license renewal. Two are administrative in nature, two are related to material possession limits and one is security related. Only one is purely equipment related. Time to process the amendment directly related to complexity and completeness of submittal.

Questions ?