ML13024A411

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Response to Request for Additional Information - License Amendment Request R-2
ML13024A411
Person / Time
Site: Pennsylvania State University
Issue date: 01/07/2013
From: Foley H
Pennsylvania State Univ, University Park, PA
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME8001
Download: ML13024A411 (31)


Text

PENNSTATE Henry C. Foley The Pennsylvania State University 814-865-6332 Vice President for Research 304 Old Main Fax: 814-863-9659 Dean of the Graduate School University Park, PA 16802 hcf2@psu.edu www.research.psu.edu January 7, 2013 Attn: Document Control Desk United State Nuclear Regulatory Commission Washington, DC 20555 Subj: The Pennsylvania State University - Response to Request for Additional Information (RAI) - License Amendment Request R-2 Docket 50-005 (TAC NO ME8001)

Dear Sir/Madame:

Attached please find responses to the NRC RAI dated November 21, 2012. Also attached, which will help to clarify the responses to RAI questions 1 and 2, is a copy of the requested Technical Specification changes more clearly delineating the requested changes and a highlighted version of Safety Analysis Report (SAR) Figure 6-1 Reactor Bay HVAC and Emergency Exhaust Systems.

Please exempt this request from fees per 10CFRI 70.11 .a.(4).

If there are any questions regarding the information submitted, please contact Mr. Mark A. Trump Associate Director for Operation.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on I /5 1 X/ _zX COMMONWEALTh OF PENNSYLVANIA_

Notarial Seal Lorri L Sormsky, Notary Public State College wlro, Centre County Sincerely, yC l Exire Nov. 15, 2016 Henry C. F rey'~

Attachments:

Updated Technical Specification Change Detail PSBR SAR Chapter 6 Figure 1 cc - electronic Mary Muessle - NRC Xiaosong Yin - NRC Greg Schoenebeck - NRC NRC correspondence File

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001)

1. Please specify ALL modifications you have made to your Technical Specifications (TS) that were submitted with your amendment request and provide brief justifications to each and every one of them accordingly.

Refer to attached marked u Technical Specification pages

  1. Technical Change Justification Specification
1. Table of Contents Editorial - formatted TS 4.3 as Improper formatting of TS 4.3 header (TOC) (actually a header level 2 which added led to missed TOC entries. PSU does format error in the missing TS 4.3 Coolant not consider the TOC a part of word file for TS 4.3) System and sub areas 4.3.1, Appendix A.

4.3.2, and 4.3.3 Page numbers updated to reflect new numbering

2. All numbered pages Page X of Y numbers change Increase in specification length by 2 pages
3. 1.1.29.a Editorial - Capitalize and bold Improve readability and reduce operator existing word "OR" error in compliance
4. 1.1.29.b.1) Editorial - Capitalize and bold Improve readability and reduce operator existing word AND error in compliance
5. 1.1.29.b.2) Editorial - Capitalize and bold Improve readability and reduce operator existing word AND error in compliance
6. 1.1.29.b.3) Editorial - Capitalize and bold Improve readability and reduce operator existing word AND error in compliance
7. 3.1.1 .b basis Editorial - correct SAR SAR section reference was incorrect reference to Section B. license and amendment request
8. 3.3.3 specification Technical - Specification See submittal and RAI response #2 and basis changed to remove the requirement that the Air monitor actuate the evacuation horn as per original amendment request attachment.
9. 3.4 specification Technical - the specification Provided a more rational technical and basis and basis were replaced in specification that supports the TS their entirety as per original concept of confinement and is amendment request consistent with ANSI/ANS 15.1 attachment.
10. 3.5 Title and Editorial - Changed to reflect Facility exhaust system renamed to applicability the ventilation system name Reactor Bay Heating Ventilation and changes Exhaust
11. 3.5 Editorial - Changed IF to Editor preference/readability whenever in 3.5.a and 3.5.b Page 1 of 8

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001) 12.1 3.5.a Technical - changed from "not Equivalent change completed secured" to whenever reactor subsequent amendment request and is operating; issued in Amendment 38 increased Emergency Exhaust See RAI #4 response below system maintenance period from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 30 days; See RAI #4 response below added a one hour time clock to restore an exhaust fan to operation or shutdown Editorial - Capitalized "AND" Improve readability, error reduction

13. 3.5.b Editorial - Capitalized "AND" Improve readability and reduce operator error in compliance
14. 3.5.b Technical - changed "Facility" Reflects name change, recognizes that to "reactor bay" exhaust fan any one of the exhaust fans including the EES fan to be used.
15. 3.5.b Technical - add remedial Prevents automatic TS violation.

action if an exhaust fan goes inoperable during fuel or experiment movement

16. 3.5 basis Technical - updated added a) Updated to reflect the changes in the and b) sections specification.
17. 3.6 title Editorial - update to reflect Ease of use content of specification
18. 3.6.1 title Editorial - update to reflect Ease of use content of specification
19. 3.6.1 table 3 and Updated to reflect the rename Lab renamed, air monitor naming basis of the Neutron Beam inconsistent (continuous verses Laboratory, air monitor particulate) renamed to match TS 3.3.3
20. 3.6.2 Technical - added remedial Prevents automatic TS violation while action if evacuation alarm is in maintaining safety considerations. See operable RAI response 3 and 4 below.
21. 3.6.2 basis Technical - updated Updated to reflect the changes in the specification.
22. 3.6.3 Ar-41 Delete in entirety See RAI 5 below
23. 3.6.4 ALARA Delete in entirety See RAI 5 below
24. 4.1 title Editorial - update to reflect Ease of use/clarity content of specification
25. 4.2 title Editorial - update to reflect Ease of use content of specification
26. 4.4 Technical - the specification Reflects change in TS 3.4, See and basis were almost amendment request and basis for more completed replaced as per information.

original amendment request attachment.

27. 4.5 title, applicability Editorial - updated to reflect Consistency of specifications and objective change exhaust system name and function Page 2 of 8

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001)

28. 4.5.b Editorial - updated to reflect Consistency of specifications change exhaust system name and function; changed "secured" to isolated Recognize operation of system
29. 4.6 title Editorial - update to reflect Ease of use content of specification
30. 4.6.1 title Editorial - update to reflect Consistency of specifications applicability, content of specification 3.6.1 objective and and name change of neutron specification beam lab and air monitor.

Separated evacuation alarm into specification 4.6.2 for consistency to match section 3.6

31. 4.6.1. Editorial - separated channel Specification only applicable when check, test, and test into reactor is scheduled for operations.

separate line items, added Ease of reading/understanding applicability to reactor operations

32. 4.6.1 basis Editorial update Updated for consistency and completeness.
33. 4.6.2 entirety Deleted Ar-41 specification, See amendment request and RAI redefined 4.6.2 to evacuation response below.

alarm

34. 4.6.3 entirety Deleted ALARA specification See amendment request and RAI response below.
35. 5.5 title, Editorial - updated to reflect Necessary clarifications consistent with specification and system title change and system design.

basis correct reference to emergency exhaust discharge height.

36. 6.1.1 Editorial - updated text title of Correct historic oversight.

Physical Plant vice president to match organization chart on next page

37. 6.7.3.a Technical - Updated radiation Reduce facility burden and exposure records retention maintenance of unnecessary data on requirements to reflect visitors.

10CFR20.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001)

2. Please clarify how many fans are associated with the new ventilation system. In your application, you identified that there are two roof top exhaust fans and one emergency fan. However the Safety Analysis Report Section 6.1, Summary Description, attached to your application, states there are "three fans" associated with the new Reactor Bay Heating, Ventilation, Air Conditioning, and Exhaust System plus one for the Emergency Exhaust System.

Both descriptions (R-2 license amendment application and Safety Analysis Report (SAR)) are correct but Section 6.1 of the updated SAR is written for "future" personnel and describes the system post modification with all normal operational exhaust fans being associated with and controlled by the Reactor Bay Heating, Ventilation, air conditioning, and Exhaust System (RBHVES). The Facility Exhaust System (FES) designation for the two existing roof top exhaust fans is being eliminated, but the two roof top fans remain and are now associated with the RBHVES. The new RBHVES adds another exhaust fan bring the total EXHAUST fans associated with the RBHVES to three (one new and two existing rooftop). The Emergency Exhaust System (EES) - consisting of one exhaust fan and filters - is unchanged, not renamed and not affected by this modification. The total number of fans associated with the new RBHVES system is five (highlighted below) - three (3) exhaust fans, one(l) supply fan, one(l) recirculation fan. See the simplified drawing in SAR Section 6.

Existing Fans Modification Post Modification One (1) Emergency No change Normally secured. Emergency Exhaust Exhaust fan normally Fan starts and operates on Building secure!gL(standby) evacuation or manual demand.

Two (2) Facility Exhaust 4101 System roof top fans - likkWWO normally one (or both) fan runnin-q dest" t* FES is w g tor Addi4ft6w-ROWES, P9dnwW(*i fan wfth he;Wn Wid 40" Six (6) steam heater fan Demolished Function replaced by RBHVES heating/air units conditioning unit (RAHU-2)

One (1) recirculating air To be demolished/not Function replaced by RBHVES heating/air conditioner and heating functional conditioning unit (RAHU-2) fan unit Page 4 of 8

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001)

3. Under TS 3.3.3, you have requested to remove the requirement that the air particulate monitor activate the building evacuation alarm. Please provide detailed justification to support your request. Specifically, state your reasoning and the resulted safety impact for this modification; how this modification will change the current emergency procedure; under what circumstances this change will benefit your reactor operation; and how reactor personnel and public safety will not be compromised because of this change.

Justification - As described in the amendment request justification for changes to TS 3.6.2, the facility is in process of upgrading the evacuation alarm to a supervised (active components monitored remotely) life-safety system (building fire alarm). This system is maintained by certified offsite technicians. The existing wording of TS 3.3.3 Fission Product Activity may require shutdown of the reactor whenever technicians enter the panel for maintenance. It is necessary and reasonable to be flexible in maintenance capability.

TS 3.3.3 is redundant but inferior in requirements for the minimum number of radiation monitors during reactor operation to TS 3.6 Radiation Monitoring. TS 3.6.1 objective is to ensure sufficient radiation monitoring information is available to the operator to ensure personnel radiation safety during reactor operations. TS 3.3.3 requires only the air particulate detector be operating when the reactor is operating whereas TS 3.6.1 also requires radiation area monitors be in operation.

TS 3.3.3 is redundant and inconsistent with TS 3.6.2 Evacuation Alarm. TS 3.6.2 requires the Evacuation Alarm be operable and audible during reactor operation when activated by any of the radiation monitors in TS 3.6.1 OR by a manual switch (operator action). TS 3.3.3 negates the OR for the air particulate monitor without public safety, personnel safety, or regulatory basis. These conflicts increase the likelihood of error in implementation. This requested change returns the control of the evacuation alarm requirement to the evacuation alarm specification (TS 3.6.2).

Benefit - The existing wording of TS 3.3.3 may require shutdown of the reactor whenever technicians enter the panel for maintenance. The requested amendment for TS 3.6.2 considers these factors and provides for remedial operator action. Although TS 3.3.3 is redundant to TS 3.6, complete deletion was not requested for simplicity of the amendment review and approval. Instead TS 3.3.3 remains and credit is taken for the existing redundant local alarm which is adequate to notify all personnel in the affected areas (original reactor building, low bay and control room) that the monitor is in an alarm state.

Safety Impact - There is no impact on the safety of the public or reactor personnel. Removal of the automatic building evacuation alarm actuation requirement in TS does not increase the likelihood, severity, or the consequences of high airborne particulate in the reactor bay. Nor is the operators' ability to monitor and respond to the situation diminished. The reactor operator and personnel in the immediate vicinity who might be exposed to reactor bay airborne particulate are immediately alerted.

Under current control system design, the reactor will automatically shut down. There are no changes planned to this control design. TS 4.6.1 and 4.6.2 continue to require surveillance of the system and ensure operability of the monitors and alarm.

Impact on Emergency Procedures - There will be no impact on the system function, emergency procedures, or operator response. There is no planned change in the system operation or design.

Under the license amendment, if the evacuation alarm is inoperable/inaudible, the alarm or an alternate means of evacuating the building must achieved within one hour or reactor operations are no longer authorized by TS 3.6.2. If the air particulate monitor alarms when the evacuation alarm is not functional, the reactor will shut down, personnel will evacuate affected areas and notify personnel in the attached buildings using alternate methods as described in the amended TS 3.6.2.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001)

4. Under TS 3.5, you have requested to increase the reactor operation time pertaining to the emergency exhaust fan operability from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 30 days. In addition, you have also proposed a new one (1) hour window to allow the reactor to operate without ANY exhaust fans.

Provide detailed justification to support these change requests. Please provide your safety analysis results to support the increases to demonstrate that there will be no increased (or very minimum) safety risks to the reactor personnel and/or to the reactor due to these proposed changes.

30 day Emer-qency Exhaust System (EES) repair window:

Justification - The EES actuates and functions to reduce release of radioactive particulate matter during a fuel cladding or fueled experiment containment failure. The request for the increase in EES outage time is a practical recognition of the age and design of the system. The custom built EES is nearly 50 years old and historically very reliable. The system is currently started daily for testing. While reliable, acquiring spare parts is problematic. A failure in the system could result in an extended outage at the reactor while parts are being procured. This could significantly impact the facility mission of research, education, and service.

Analysis results - Effect on release: The EES was designed and installed to mitigate the release of airborne radioactive material from a fueled experiment failure or massive fuel cladding breach. SAR Section 13.1.1 Maximum Hypothetical Accident (MHA) provides an upper bound for any release from the fuel and TS 3.7.f (Limitationsof Experiments) limits fueled experiment fission product content to less than the postulated MHA release. The SAR MHA analysis does not credit the EES operation as providing any mitigation (filtration) of the release to the public.

This analysis shows that filtration is not required during the MHA for compliance with 10CFR20 public dose limits. The analysis assumes the EES provides a constant (3100 CFM) release rate that is diluted by air flow around the structure. If the EES is out of service during the event, release rate from the structure is reduced with resultant increase in decay of fission products inside the building. This reduces the calculated release rate (EES inoperative) and will result in a reduced calculated integrated exposure to public. The airborne radioactive release of fission products from operating fuel element or fueled experiment under water is significantly less than the MHA and the public impact proportionally less. Since the area will be evacuated, operability will have no impact on the expected exposure to reactor personnel.

Analysis results - Probability of occurrence: There is no probability of occurrence for the MHA as the mechanism for release of fission products from an operating maximum power fuel element in air as there is no plausible mechanism for this postulated worse case event.

Therefore there is no increase in the possibility of the MHA. The highest probability of a fission product release is during fuel or fueled experiment movement. No relief for EES operability during these operations is requested in the amendment. Operability of the EES is still continuously required by TS 3.5.b. The probability of fuel or fueled experiment fission product release during routine reactor operation is very low, and is not changed by the operability of the EES. Additionally the availability of a 30 day maintenance window will not adversely affect the operation or reliability of the system.

Our analysis concludes the amendment request for a 30 day EES maintenance window does not increase the probability of a release from the facility and any release that may occur during a postulated maintenance interval is still bounded by existing analysis and below regulatory guidance as described in 10CFR20.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001)

One hour time limit with no exhaust fan Justification - As part of the 10CFR50.59 review for the installation of the RBHVES, applicable Technical Specifications were reviewed for impact and improvement. The current TS 3.5 ventilation specification wording has resulted in instances of noncompliance without technical/regulatory merit. If the operating exhaust fan trips, an "instantaneous" noncompliance with TS 3.5.a occurs. To protect against TS non-compliance, the digital control system will initiate a reactor scram and minimize the regulatory impact. Unnecessary scrams have resulted because of the scram feature based on the TS. The requested wording change provides operators with a reasonable time frame to take corrective actions. This remedial action "time clock" is consistent with the TS mechanisms used by the commission to regulate power reactor and has been licensed at comparable non-power reactor facilities.

Analysis results - Safety of reactor personnel: As described in SAR Section 6 Engineered Safety Featuresa reactor bay exhaust fan is operated to minimize the buildup of any airborne radioactive material and gases resulting from reactor operation. With no exhaust fans in operation, any airborne material and gases previously diluted by the continuous flow of fresh air will begin to accumulate. Gases may slowly migrate to other areas of the facility due to changes in air flow patterns. For accident scenarios, TS 3.6.1 Radiation Monitoring requires operable airborne particulate and radiation monitors if the reactor is operating. With no exhaust fans operable and no dilution, reactor bay radiation levels (airborne) will rise faster resulting in monitor alarm and automatic or operator action to shut down the reactor. During routine operation, the SAR elaborates that Ar-41 is the only gas that presents an accumulation issue. During normal operations with an exhaust fan, Ar-41 is barely detectable in the reactor bay (MDA -3E- 7 uCi/ml).

Per 10CFR20 App C, Ar-41 is a submersion class whole body exposure for the occupational exposure (DAC limit) of 3E-6 pCi/ml for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />. Significant levels cannot accumulate in the proposed one hour remedial action time limit. If levels were to accumulate, the reactor bay radiation monitors would again alert the operators to the developing hazard.

Our analysis concludes the amendment request for one hour remedial time limit for reactor operation with no exhaust fan does not increase the probability of an accident, change the exposure to the public, increase exposures to reactor personnel, or present an unmonitored hazard to reactor personnel.

5. Under TSs 3.6.3, 3.6.4, 4.6.2, and TS 4.6.3, you have requested to remove those sections regarding argon-41 (Ar-41) and as low as reasonably achievable (ALARA) specifications. While realizing those requirements are codified in 10 CFR Part 20, what (where) are your commitments to those requirements after the removal of these reference TS sections?

The commitment to comply with 10CFR20 (and by default effluent and ALARA limits) is specified in Section C.2 of the license itself: This renewed license shall be deemed to contain and is subject to the conditions specified in Parts 20, 30, 50,51,55 and 73 of the Commission's regulations...

Additionally, Section 11 of the PSBR SAR elaborates on effluents released from the facility (11.1.1.1 for Ar-41), provides discussion of the Penn State Radiation Protection Program (11.1.2) and the ALARA Program (11.1.3). Routine release of Ar-41 is reported annually as required by Technical Specification 6.6.1 OperatingReports. PSBR operations release a fraction of the limits for 10CFR and are historically below the reporting limits. The performiance of the ALARA program has rarely resulted in any worker exceeding 10% of the 10CFR20 limit and more typically 1 or 2% of the limits.

Public exposure (visitor) is generally less than the minimum dose on the electronic dosimeters and environmental dosimeters show no statistical impact from operation of the facility.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PENN STATE BREAZEALE REACTOR LICENSE AMENDMENT REQUEST (TAC NO ME8001)

6. Please provide clarifications to TS 5.5 regarding air exhaust stack height at the roof level. In your application, you are using "34 feet above reactor bay floor" versus the current TS version as "24 feet above ground level." Is this only a reference change or is this an air stack height change to reflect the new ventilation system? Please justify for this change accordingly.

There has been no change or modification to the emergency exhaust stack height as described in the SAR and this modification and amendment request does not change this system. The new RBHVES system has a new separate exhaust stack (as described in the application).

In preparing and reviewing this amendment request, it was noted that there is no defined "ground level" since the facility is built into the side of a hill with no apparent ground level reference point.

The reactor bay roof is 34 feet above the defined reactor bay floor and the installed emergency exhaust stack is several feet higher. It is believed that the original submittal of 24 feet was a typographic error for roof height of 34 feet and it seemed prudent to request correction. There is little technical basis for use of an exhaust stack of any specific height other than the deterministic objective of promoting mixing and dilution of any postulated release.

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Roof Top Exhaust Fans Economizer Makeup Gravity Backdraft Air Damper Dampers RBHVES F rAbove 0 Supply Fan , z Reactor Bay 3000CFM - tI,*

Eh t A 123 Roofline

'RBHVES Confinement REACTOR 18 ia.

Exhaust Fan Isolation Bay Filter 3500 CFM Dampers3100 0F CFM

-- 75 Pre-Filter

_Z Absolute Filter mergency Exhaust Makeup Charcoal Filter System (EES)

Air Damper Exhaust To Above Outside Reactor Bay Air Roofline.

Intake Figure 6-1 RBHVES and Emergency Exhaust Systems

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 SDeleted: ¶ J.0 INTRODUCTION --

1.1 Definitions 1 2.0 SAFETY LIMIT AND LIMITING SAFETY SYSTEM SETTING 8 2.1 Safety Limit - Fuel Element Temperature 8 2.2 Limiting Safety System Setting (LSSS) 9 3.0 LIMITING CONDITIONS FOR OPERATION 10 3.1 Reactor Core Parameters 10 3.1. 1 Non-Pulse Mode Operation 10 3.1.2 Reactivity Limitation 11 3.1.3 Shutdown Margin 12 3.1.4 Pulse Mode Operation 13 3.1.5 Core Configuration Limitation 14 3.1.6 TRIGA Fuel Elements 15 3.2 Reactor Control and Reactor Safety System 16 3.2.1 Reactor Control Rods 16 3.2.2 Manual Control and Automatic Control 17 3.2.3 Reactor Control System 18 3.2.4 Reactor Safety System and Reactor Interlocks 19 3.2.5 Core Loading and Unloading Operation 21 3.2.6 SCRAM Time 21 3.3 Coolant System 22 3.3.1 Coolant Level Limits 22 3.3.2 Detection of Leak or Loss of Coolant 23 3.3.3 Fission Product Activity 23 3.3.4 Pool Water Supply for Leak Protection 24 3.3.5 Coolant Conductivity Limits 24 3.3.6 Coolant Temperature Limits 25 3.4 Confinement 26 3.5 Engineered Safety Features - Facility Exhaust System and Emergency Exhaust System 27 3.6 Radiation Monitoring System 29 3.6.1 Radiation Monitoring Information 29 3.6.2 Evacuation Alarm 30 3.6.3 Argon-41 Discharge Limit 30 3.6.4 As Low As Reasonably Achievable (ALARA) 31 3.7 Limitations of Experiments 31 4.0 SURVEILLANCE REQUIREMENTS 34 4.1 Reactor Parameters 34 4.1,1 Reactor Power Calibration 34 4.1.2 Reactor Excess Reactivity 34 4.1.3 TRIGA Fuel Elements 35

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TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.2 Reactor Control and Safety System 36

4. 21 Reactivity Worth 36 42.2 Reactivity Insertion Rate 36 4.2.3 Reactor Safety System 37 4.2.4 Reactor Interlocks 38 4.2.5 Overpower SCRAM 39 4.2.6 Transient Rod Test 39 4.3 Coolant System 40 4.3.1 Fire Hose Inspection 40 4.3.2 Pool Water Temperature 41 4.3.3 Pool Water Conductivity 41 4.3.4 Pool Water Level Alarm 42 4.4 Confinement 42 4.5 Facility Exhaust System and Emergency Exhaust System 43 4.6 Radiation Monitoring System and Effluents 44 4.6.1 Radiation Monitoring System and Evacuation Alarm 44 4.6.2 Argon-41 44 4.6.3 ALARA 45 4.7 Experiments 45 5.0 DESIGN FEATURES 46 5.1 Reactor Fuel 46 5.2 Reactor Core 46 5.3 Control Rods 47 5.4 Fuel Storage 47 5.5 Reactor Bay and Exhaust Systems 48 5.6 Reactor Pool Water Systems 48 6.0 ADMINISTRATIVE CONTROLS 49 6.1 Organization 49 6.1.1 Structure 49 6.1.2 Responsibility 49 6.1.3 Staffing 51 6.1.4 Selection and Training of Personnel 51 6.2 Review and Audit 52 6.2.1 Safeguards Committee Composition 52 6.2.2 Charter and Rules 52 6.2.3 Review Function 53 6.2.4 Audit 53 6.3 Operating Procedures 54 6.4 Review and Approval of Experiments 55

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TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 6.5 Required Action 55 Deleted:1. INTRODUC11ON 1¶ 6.5.1 Action to be Taken in the Event the Safety Limit is Exceeded 55 6.5.2 Action to be Taken in the Event of a Reportable Occurrence 56 LO SAFETY LIMIT AND LIMITING SAFETY SYSTEM SETTING 8¶ 2.1 Safety Limst- Fuel Element Temnerature 8S 6.6 Reports 56 2 Limiting Safety System Setting (LSSS) 9¶ 6.6.1 Operating Reports 56 3.0 UMIING CONDITIONS FOR 6.6.2 Special Reports 57 OPERATION 10¶ M. Reactor Core Parameters 10¶ 3.L1 Non-Pulse Mode Oneration t0¶ 6.7 Records 58 3.1.2 Reactivity Limitation I1¶ 6.7.1 Records to be Retained for at Least Five Years 58 3.t13 Shutdown Mamin 12¶ 6.7.2 Records to be Retained for at Least One Training Cycle 58 3.1.4 PulseModeOeration 13¶ 3.1.5 CoreConfiguvationLimitation 14¶ 6.7.3 Records to be Retained for the Life of the Reactor Facility 58 3I& TRIGA Fuel Elements 15¶

.2 Reactor Control and Reactor Safety Sytem 16$

3.2.1 Reactor Control Rods 16¶ 3.2.2 Manual Control and Automatic Control 17¶ 3.2.3 Reactor Control System 18¶ 3,2.4 Reactor Safety System and Reactor Interlocks 195 325 Core Loading and Unloading Operation 21¶ 32.6 SCRAMTime 21¶ 33 Coolant System 22¶ 3.1. Coolant Level Limits 22¶ 3.3.2 Detection of Leak or Loss of Coolant 23¶ 3.33 Fission Product Activity 23¶ 3.3.4 Pool Water Suoolv for Leak Protection 24¶ 3 Coolant Conductivity Limits 24¶ 3.3,6 Coolant Tenmerature Limits 25¶ 3.4 Confinement 2!n 3.5 Engineered Safety Features - Facility Exhaust System and Emergency Exhaust satm 261 3.6 Radiation Monitoring System 27T 3A1 Radiation Monitoring Information 27¶ 3.6.2 EvacuationAlarm 2M¶ 3.6.3 Argon-41 Discharge Limit 25¶ 3.6.4 As Low As Reasonably Achievable (ALARA) 29¶ 3.7 Limitations of Exoeriments 29¶

-ag Break 4.0 SURVEILLANCE REQUIREMENTS 321 4.1 Reactor Parameters 32¶

4. 1.1 Reactor Power Calibration 32¶ 4.1.2 Reactor Excess Reactivity 32¶ 4,13 TRIGA Fuel Elements 33¶ 4.2 Reactor Control and Safety System 34M 4.2.1 Reactivity Worth 34¶ 4.2.2 Reactivity Insertion Rate 34¶ 4.2.3 ReactrlSafety System 35¶ 4.2.4 Reactor Interlocks 36¶ 4.2.5 Overoower SCRAM 37¶ 426 Transient Rod Test 37¶ 4.3.1 Fire Hose lnspection 391 43.2 Pool Water Temperature 391 4.3.3 Pool Water Conductivity 39¶ 4.3.4 Pool Water Level Alarm 40¶ 4.4 Confi 4(¶ 4.5 Facility Exhaust System and Emergency Exhaust System 41¶ A& Radiation Monitoring System and EMuents 41¶ 4.6.1 Radiation Monitoring System and Evacuation Alarm 41¶ 4.6.2 Aron-4l 42¶ 463 ALARA 42¶ 4.7 E 43 5.0 DESIGN FEATURES 44¶ 5,1 Reactor Fuel 441!

5.!&

5.

CotrlRos 45¶ CotolRd 44¶

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TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 1.1.25 Reactivity Worth of an Experiment The reactivity worth of an experiment is the maximum absolute value of the reactivity change that would occur as a result of intended or anticipated changes or credible malfunctions that alter experiment position or configuration.

1.1.26 Reactor Control System The reactor control system is composed of control and operational interlocks, reactivity adjustment controls, flow and temperature controls, and display systems which permit the operator to operate the reactor reliably in its allowed modes.

1.1.27 Reactor Interlock A reactor interlock is a device which prevents some action, associated with reactor operation, until certain reactor operation conditions are satisfied.

1.1.28 Reactor Operating The reactor is operating whenever it is not secured or shutdown.

1.1.29 Reactor Secured The reactor is secured when:

a. It contains insufficient fissile material or moderator present in the reactor, adjacent experiments, or control rods, to attain criticality under optimum available conditions of moderation, and reflection., OR ........... Deleted: or
b. A combination of the following:
1) The minimum number of neutron absorbing control rods are fully inserted or other safety devices are in shutdown positions, as required by technical specifications ...... ....................... ... Deleted: and AND1
2) The console key switch is in the off position and the key is removed from the lock, - - - --- - - Deleted: and AND
3) No work is in progress involving core fuel, core structure, installed control rods, or control rod drives unless they are physically decoupled from the control rods__
  • Deleted: and AND
4) No experiments in or near the reactor are being moved or serviced that have, on movement, a reactivity worth exceeding the maximum value Deleted: I allowed for a single experiment or one dollar whichever is smaller.

Deleted: 6 Page 4 of 58-------------------------------

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.0 LIMITING CONDITIONS FOR OPERATION The limiting conditions for operation as set forth in this section are applicable only when the reactor is operating. They need not be met when the reactor is shutdown unless specified otherwise.

3.1 Reactor Core Parameters 3.1.1 Non-Pulse Mode Operation Applicability These specifications apply to the power generated during manual control mode, automatic control mode, and square wave mode operations.

Obiective The objective is to limit the source term and energy production to that used in the Safety Analysis Report.

Specifications

a. The reactor may be operated at steady state power levels of 1 MW (thermal) or less.
b. The maximum power level SHALL be no greater than 1.1 MW (thermal).
c. The steady state fuel temperature SHALL be a maximum of 650°C as measured with an instrumented fuel element if it is located in a core position representative of MEPD in that loading. If it is not practical to locate the instrumented fuel in such a position, the steady state fuel temperature SHALL be calculated by a ratio based on the calculated linear relationship between the normalized power at the monitored position as compared to normalized power at the core position representative of the MEPD in that loading. In this case, the measured steady state fuel temperature SHALL be limited such that the calculated steady state fuel temperature at the core position representative of the MEPD in that loading SHALL NOT exceed 650'C.

Basis

a. Thermal and hydraulic calculations and operational experience indicate that a compact TRIGA reactor core can be safely operated up to power levels of at least 1.15 MW (thermal) with natural convective cooling.
b. Operation at 1.1 MW (thermal) is within the bounds established by the SAR for steady state operations. See Chapter 13, Section ,_of the SAR. - -F Deleted: C
c. Limiting the maximum steady state measured fuel temperature of any position to 650'C places an upper bound on the fission product release fraction to that used in the analysis of a Maximum Hypothetical Accident (MIA). See Safety Analysis Report, Chapter 13.

I eleted: 6)

Page 10 of 58,----------------------------- .

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.3.2 Detection of Leak or Loss of Coolant Applicability This specification applies to detecting a pool water loss.

Objective The objective is to detect the loss of a significant amount of pool water.

Specification A pool level alarm SHALL be activated and corrective action taken when the pool level drops 26 cm from a level where the pool is full.

Basis The alarm occurs when the water level is approximately 18.25 ft. above the top of the bottom grid plate. The point at which the pool is full is approximately 19.1 ft. above the top of the bottom grid plate. The reactor staff SHALL take action to keep the core covered with water according to existing procedures. The alarm is also transmitted to the Police Services annunciator panel which is monitored 24 hrs. a day. The alarm provides a signal that occurs at all times. Thus, the alarm provides time to initiate corrective action before the radiation from the core poses a serious hazard.

3.3.3 Fission Product Activity Applicability This specification applies to the detection of fission product activity.

Objective The objective is to ensure that fission products from a leaking fuel element are detected to provide opportunity to take protective action.

Specification An air particulate monitor SHALL be operating in the reactor bay whenever the reactor is operating. An alarma__ctuated by this unit SHALLlert * - Deleted: oa personnel. Deleted: activate a building evacuation alarm Basis This unit will be sensitive to airborne radioactive particulate matter containing fission products and fission gases and will alert personneltq .. - Deleted: intime evaluate the situation and take appropriate protective action.

Deleted: 6 Page 23 of 58,_

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.4 Confinement ApplicabilitV This specification applies to the boundary walls and doors that make up the confinement.

Objective The objective is to define the components and conditions requiring confinement.

Specification Whenever the reactor is operating or irradiated fuel or a fueled experiment with significant fission product inventory is being moved outside containers, systems or storage areas:

a. Reactor bay doors SHALL be closed or operable, except that the door is continuously attended AND provisions in place to immediately close the door OR establish a low pressure confinement boundary.

AND

b. Large penetrations SHALL NOT exist in the confinement boundary except that the penetration is continuously attended and provisions in place to immediately close the penetration or establish a low pressure confinement boundary Basis During reactor operation or a of movement of irradiated fuel or fueled experiments, the probability of fission product release increases. This specification ensures that Deleted: TI tis specification applies to reactor bay the reactor bay boundary is intact to ensure that a controlled air flow passage can doors. ¶ exist to meet the definition of confinement during these times. Controlled air flow ¶ is maintained by one or more exhaust system fans and ensures controlled release of any airborne radioactivity (see TS 3.5 Ventilation). For the purpose of this The objective is to ensure that no large air passages specification, the confinement includes the reactor bay, low bay and control room exist to the reactor bay during reactor operation. ¶ (if the control room door is blocked open). ¶

a. Large open penetrations can disrupt the flow of ventilation. Except for the The reactor ,mytruck door SHALL be closed and the attended passage of people or equipment, doors shall remain closed. A door is boctrebay pe,rsonnel doors SHALL NOT be and left unattended if either of the operable when it is closed or capable of closing via an automatic closure following conditions are true.¶ mechanism. To be operable, a blocked door or manual door must be attended to ¶ or is not secured, or¶ ensure that in an event that requires closure, it can and will be closed. If a door is a. The reacts inoperable or under maintenance, a temporary low pressure confinement or b. Irradiated fuel or a fueled experiment with alternative boundary can be established. Temporary or alternative boundaries significant fis sion product inventory is being moved should be verified acceptable by the Senior Reactor Operator. An established low outside contaiiners, systems or storage areas.¶ pressure boundary that satisfies this specification may or may not meet the T requirement of the Physical Security Plan. The existing doors include the reactor ¶ This spueifics ation helps to ensure that the air bay personnel doors, reactor bay rollup or exterior weather door, low bay equipment doors, and the pipe tunnel boundary partition/door. The low bay remainder oft e reactor bay is lower than the the building and the outside air equipment doors include the Hot Cell Access plugs. pressure. controlled air pressure is maintained the air exhaut by stsystem and ensures controlled release

....... of any airbormte radioactivity. ¶ Deleted: 6 Page 26 of 58,

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2

b. Temporary penetrations may be established in the confinement for ongoing maintenance and modifications. Whenever such penetrations exist, a low pressure confinement boundary should be established or a designated individual assigned with all necessary provisions in place to close the penetration. Provisions and preparations for low pressure boundaries should be verified acceptable by the Senior Reactor Operator. The high flow rate of the exhaust systems will maintain air flow into the confinement even with relatively large penetrations. A large penetration is defined as any penetration greater than approximately 100 square inches and is limited by security, not air flow considerations.

3.5 Ventilation Systems I- - -1 Deleted: Engineered Safet Features - Facility Exhaust System and Emergency Exhaust I Applicability This specification applies to the operation of the~reactor bay heating ,ventilation and [ Deleted: facility exhaiust exhaust system and the emergency exhaust system.

Objective The objective is to mitigate the consequences of the release of airborne radioactive materials resulting from reactor operation.

Specification

a. Wheneverithe reactor ispperating, at least onereactor bqay exhaust fan SHALL be operatingAND, except forperiods of time less than,3 days during maintenance or repair, the emergency exhaust system SHALL be operable.

I1 Delete: If Deleted: not secured Deleted: facility With no operating exhaust fans, restore an exhaust fan to operation within A1 Deleted: and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or shutdown the reactor. Deleted: 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

b. Whenever irradiated fuelor a fueled experiment with significant fissionproduct Deleted: If inventory is being moved outside containers, systems or storage areas, at least one facility exhaust fan SHALL be operatingAND the emergency exhaust.... Deleted: and system SHALL be operable.

With no operating exhaust fans or discovery of an inoperable emergency exhaust system, complete the movement in progress then cease all further movement until compliance with 3.5.b is restored.

Deleted: 6 Page 27 of 58,

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 Basis

a. During normal operation, the concentration of airborne radioactivity in unrestricted areas is below effluent release limits as described in the Safety Analysis Report, Chapter 13. The operation of any of the reactor bay exhaust fans (reactor bay heating ventilation air conditioning and exhaust system or the emergency exhaust system) will maintain this condition and provide confinement per TS 1.1.8. If all exhaust to the reactor bay is temporarily lost, the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit to restore exhaust allows operators to investigate and respond. Reactor bay area radiation and/or air radiation monitors will continue to assure an unrecognized hazardous condition does not develop.

In the event of a substantial release of airborne radioactivity, an air radiation monitor and/or an area radiation monitor will alert personnel and lead to initiation of thebuilding evacuation alarm which will automatically cause the reactor bay heating ventiation air condit ion-ing- and exh aust systempn4shut down. The - Deleted: facility iIDeleted: sound a exhaust system emergency exhaust system will start and the exhausted airvill be passed through Deletd: close the emergency exhaust system filters before release. This reduces the radiation within the building. The filters will removez 90% all of the particulate fission to zDeleted:

products that escape to the atmosphere.

The emergency exhaust system activates only during an evacuation whereupon all personnel are required to evacuate the building (TS 3.6.2). If there is an evacuation while the emergency exhaust system is out of service for maintenance or repair, personnel evacuation is not prevented.

In the unlikely event an accident occurs during emergency exhaust system maintenance or repair, the public dose will be equivalent to or less than that calculated in the Safety Analysis Report, Chapter 13 as this analysis does not take credit for the filtration provided by emergency exhaust system. Therefore the system filtration and operation is not required to meet the accident analysis and a 30 day repair period is mandated or operations will cease.

b. During irradiated fuel or fueled experiment movement, the likelihood of event releasing fission products to the bay is increased. Therefore operation of the exhaust system and availability of an operable filtered exhaust is prudent. If the system fails or is discovered inoperable during movement activities, the movement in progress must be completed to store the fuel or experiment in an approved location. This is prudent and remains within the requirement of the limiting condition for operation remedial action. No further movements may be conducted until the limiting condition for operation is satisfied.

Deleted: 6 Page 28 of 58k

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.6 Radiation Monitoring System and Evacuation Alarm 3.6.1 Radiation Monitoring, I - -Deleted: Information Applicability This specification applies to the radiation monitoring information which must be available to the reactor operator during reactor operation.

Obiective The objective is to ensure that sufficient radiation monitoring information is available to the operator to ensure personnel radiation safety during reactor operation.

Specification The reactor SHALL NOT be operated unless the radiation monitoring channels listed in Table 3 are operating.

Table 3 Radiation Monitoring Channels Radiation Monitoring Channels Function Number Area Radiation Monitor Monitor radiation levels in the reactor bay.

(Deleted: Coinuou

,Air Particulate --------- Monitor radioactive (Radiation) Monitor particulates in the reactor bay air.

- ( Deleted: Beamhole N__eutron Beam_ Laboratory Monitor radiation in the Monitor ,NJeutron Beam Laboratory_ -[ Deleted: Beamhole (required only when the laboratorv is in use.)

Basis

a. The radiation monitors provide information to operating personnel of any impending or existing danger from radiation so that there will be sufficient time to evacuate the facility and to take the necessary steps to control the spread of radioactivity to the surroundings.
b. The area radiation monitor in theNeutron _BBeam Laboratory provides .1 - -[ Deleted: Beamhole information to the user and to the reactor operator when this laboratory is in use.

( Deleted: 6 Page 29 of 58_

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.6.2 Evacuation Alarm Applicability This specification applies to the evacuation alarm.

Objective The objective is to ensure that all personnel are alerted to evacuate the PSBR building when a potential radiation hazard exists within this building.

Specification The reactor SHALL NOT be operated unless the evacuation alarm is operable and audible to personnel within the PSBR building when activated by the radiation monitoring channels in Table 3 or a manual switch.

With no operable evacuation alarm system, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> return the evacuation alarm to operation or verify that an evacuation can be initiated using the facility announcement system or other audible alarm.

Basis The evacuation alarm system produces an audiblealarm throughout the PSBR building when activated., The alarnr noti fies all by PSBR building to evacuate the building as prescribed personnel within the the PSBR I Deleted: loud pulsating sound Deleted: there is any impending or existing danger from radiation.

emergency procedure. Deleted: sound Since the probability of a valid need for a full facility evacuation is very low Deleted: 3.63 Argon-41 Discharae Limitl

¶ and areas of the building that have significant sources of radiation have local alarms, it is reasonable that the evacuation system may be removed ¶ from service for maintenance and testing without ceasing reactor operations. This specification applies to the concentration of Argon-41 that may be discharged from the PSBR. ¶ The one hour time limit allows for routine maintenance and testing. ¶ Verification of a suitable substitute alarm or a functioning facility announcement system will ensure the facility can be evacuated in ¶ The objective is to ensure that the health and safety accordance with emergency procedures and allow for longer maintenance of the public is not endangered by the discharge of intervals if required. Argon-41 from the PSBR. ¶

¶ 5nmuificatin$

¶ All Argon-41 concentrations produced by the operation of the reactor SHALL be belowthe limits imposed by 10 CFR Part 20 when averaged over a year. ¶

¶ The maximum allowable concentration ofArgon-41 in air in unrestricted areas as specified in Appendix B, Table 2 of 10 CFR Part 20 is 1.0 x I0" O Ci/ml.

Measurements of Argon-41 have been made in the reactor bay when the reactor operates at I MW.

These measurements show that the concentrations averaged over a year produce less than 1.0 x 10"s Ci/mI in an unrestricted area (see Environmental Impact Appraisal, December 12, 1996). ¶ Deleted: 6 Page 30 of 58,

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2

,,3.7 Limitations of Experiments ......................................- Deleted: ¶ 3.6.4. As Low As Reasonably Achievable (ALARA)

Applicability ¶ Aoolicabilitv¶

¶ These specifications apply to experiments installed in the reactor and its This specification applies to all reactor operations that could result in occupational exposures to experimental facilities. radiation or the release of radioactive effluents to the environs. ¶ Obiective ¶ Qblective¶

¶ The objective is to prevent damage to the reactor and to minimize release of The objective is to maintain all exposures to radioactive materials in the event of an experiment failure. radiation and release of radioactive effluents to the environs ALARA. ¶

¶ Specifications

¶ An ALARA program SHALL be in effect. ¶ The reactor S1HALL NOT be operated unless the following conditions governing ¶ experiments exist:

¶ Having an ALARA program mill ensure that

a. The reactivity of a movable experiment and/or movable portions of a secured occupational exposures to ¶ experiment plus the maximum allowed pulse reactivity SHALL be less than radiation and the release of radioactive effluents to 2.45% Ak/k (-$3.50). However, the reactivity of a movable experiment and/or the environs vill be ¶ ALARA. Having such a formal program will keep movable portions of a secured experiment SHALL have a reactivity worth less the staffcognizant of the ¶ than 1.4% Ak/k (-$2.00). During measurements made to determine specific importance to minimize radiation exposures and worth, this specification is suspended provided the reactor is operated at power effluent releases.

levels no greater than I kW. When a movable experiment is used, the maximum Deleted: ¶ allowed pulse SHALL be reduced below the allowed pulse reactivity insertion of ¶ 2.45% Ak/k (-$3.50.) to ensure that the sum is less 2.45% Ak/k (-$3.50).

Jb._ A single secured experiment SHALL be limited to a maximum of 2.45% Ak/k D-eleted: - Page Break-(-$3.50). The sum of the reactivity worth of all experiments SHALL be less than 2.45% Ak/k (-$3.50). During measurements made to determine experimental worth, this specification is suspended provided the reactor is operated at power levels no greater than,IkW. -" Deleted: t I

c. When the keff of the core is less than I (one) with all control rods at their upper limit and no experiments in or near the core, secured negative reactivity experiments may be added without limit.
d. An experiment may be irradiated or an experimental facility may be used in conjunction with the reactor provided its use does not require a license amendment, as described in 10 CFR 50.59, "Changes, Tests and Experiments."

The failure mechanisms that SHALL be analyzed include, but are not limited to corrosion, overheating, impact from projectiles, chemical, and mechanical explosions.

Explosive material SHALL NOT be stored or used in the facility without proper safeguards to prevent release of fission products or loss of reactor shutdown capability.

If an experimental failure occurs which could lead to the release of fission products or the loss of reactor shutdown capability, physical inspection SHALL be performed to determine the consequences and the need for corrective action.

The results of the inspection and any corrective action taken SHALL be reviewed by the Director or a designated alternate and determined to be satisfactory before operation of the reactor is resumed.

[ Deleted: 6 Page 31 of 58,.

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.0 SURVEILLANCE REQUIREMENTS IF a Surveillance Requirement(s) is not accomplished in the specified interval that prohibits reactor operation; THEN the reactor SHALL NOT be operated until the Surveillance Requirement(s) is satisfied EXCEPT as required to accomplish the required Surveillance(s).

4.1 Reactor Core Parameters 4.1.1 Reactor Power Calibration Applicability This specification applies to the surveillance of the reactor power calibration.

Obiective The objective is to verify the performance and operability of the power measuring channel.

Specification A thermal power channel calibration SHALL be made on the linear power level monitoring channel biennially, not to exceed 30 months.

Basis The thermal power level channel calibration will ensure that the reactor is operated at the authorized power levels.

4.1.2 Reactor Excess Reactivity Applicability This specification applies to surveillance of core excess reactivity.

Obiective The objective is to ensure that the reactor excess reactivity does not exceed the Technical Specifications and the limit analyzed in Safety Analysis Report, Chapter 13.

Specification The excess reactivity of the core SHALL be measured annually, not to exceed 15 months, and following core or control rod changes equal to or greater than 0.7% Ak/k (-$ 1.00).

I Deleted: 6 Page 34 of 58 ------------------------------ I

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.2 Reactor Control and Reactor Safety System 4.2.1 Reactivity Worth Applicability This specification applies to the reactivity worth of the control rods.

Objective The objective is to ensure that the control rods are capable of maintaining the reactor subcritical.

Specification The reactivity worth of each control rod and the shutdown margin for the core loading in use SHALL be determined annually, not to exceed 15 months, or following core or control rod changes equal to or greater than 0.7% Ak/k (-$1.00).

Basis The reactivity worth of the control rod is measured to ensure that the required shutdown margin is available and to provide an accurate means for determining the core excess reactivity, maximum reactivity, reactivity insertion rates, and the reactivity worth of experiments inserted in the core.

4.2.2 Reactivity Insertion Rate Applicability This specification applies to control rod movement speed.

Obiective The objective is to ensure that the reactivity addition rate specification is not violated and that the control rod drives are functioning.

Specification The rod drive speed both up and down and the time from SCRAM initiation to the full insertion of any control rod from the full up position SHALL be measured annually, not to exceed 15 months, or when any significant work is done on the rod drive or the rod.

Basis This specification ensures that the reactor will be promptly shut down when a SCRAM signal is initiated. Experience and analysis have indicated that for the range of transients anticipated for a TRIGA reactor, the specified SCRAM time is adequate to ensure the safety of the reactor. It also ensures that the maximum reactivity addition rate specification will not be exceeded.

-(Deleted: 6 Page 36 of 58,

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.3.4 Pool Water Level Alarm Applicability This specification applies to the surveillance requirements for the pool level alarm.

Obiective The objective is to verify the operability of the pool water level alarm.

Specification The pool water level alarm SHALL be channel checked monthly, not to exceed 6 weeks, to ensure its operability.

Basis Experience, as exhibited by past periodic checks, has shown that monthly checks of the pool water level alarm ensures operability of the system during the month.

4.4 Confinement Applicability This specification applies to reactor bay doors and penetrations.

Objective The objective is to ensure that reactor bay doors and penetrations are naintained operable as per TS 3.4. I D eted: kept closed Specification A verification that reactor confinement doors and temporary penetrations comply with TS 3.4 SHALL be made on each day that the reactor is to be operated, or prior to each operation that extends more than one day, fDeled: Doors to the reactor bay SHALL be locked or under supervision by an authorized keyholder Basis The operability status of reactor bay doors is commonly observed by the users of the door throughout each day. The existence of temporary penetration is an unusual maintenance event. The failure of a door to properly close will not result in an increase in the likelihood or severity of a release. Therefore a daily check of the door and penetration status is more than adequate to assure confinement function, Dee*te : A keyholder is authorized by the Director I or his designee. I (Deleted: 6 Page 42 of 58,

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.5 Ventilation Systems .1- IDeleted:

ExhaustI Facility Exhaust System and Emergency Applicability These specifications apply to the reactor bay heating ventilation air conditioning and exhaustsystem and emergency exhaust system. - Deleted: facility exhaust Obiective The objective is to ensure the proper operation of the reactor bay heating ventilation air conditioning and exhaustystem_ andmergency exhaust system in controlling_ _ - Deleted: facility exhaust releases of radioactive material to the uncontrolled environment. " Deleted: I Specifications

a. It SHALL be verified monthly, not to exceed 6 weeks, whenever operation is scheduled, that the emergency exhaust system is operable with correct pressure drops across the filters (as specified in procedures).
b. It SHALL be verified monthly, not to exceed 6 weeks, whenever operation is scheduled, that the reactor bay heating ventilation air conditioning and exhaust system ,isjsolated when the emergencyexhaust system activates during an Deleted: facility exhaust system evacuation alarm (See TS 3.6.2 and TS 5.5). Deleted: secured Deleted: T Basis Experience, based on periodic checks performed over years of operation, has demonstrated that a test of the exhaust systems on a monthly basis, not to exceed 6 weeks, is sufficient to ensure the proper operation of the systems. This provides reasonable assurance on the control of the release of radioactive material.
  • Deleted: 6 Page 43 of 58,- ...........................- I'

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.6 Radiation Monitoring System and.Evacuation Alarm ............ . Deleted: Effluent 4.6.1 Radiation Monitoring System and Evacuation Alarm Applicability This specification applies to surveillance requirements for the reactor bay area radiation4nonitor, theneutron beam _tboratory-area radiation monitor,1 Deleted: I and the reactor bay air particulate monitor, and the evacuation-alarm. Deleted: Beanihole (Deleted:L Objective Deleted: radiation The objective is to ensure that the radiation monitors and evacuation alarm are operable and to verify the appropriate alarm settings.

Specification The area radiation monitor, the neutron beamiJaboratory radiation m onitor Deleted: Beamhole and , th e_ ir pa rt i c ul a t e ( rad iat io n) m on i to r SH A L L b e : ----------------

a. Channel checked each day that the reactor is operated if the monitor is required to be in service per T.S. 3.6.1; Deleted:,
b. $Channeltested monthly notto exceed 6 weeks, whenever operations -

are scheduledý .... .................. continuous EWICIeW-" and the evacuation aluma system

c. Cdibrated annually, not to exceed 15 months, whenever operations are scheduled -------- .-- --------------- - Deleted:

Deleted: c Basis Deleted:. They SHALL be verified to be operable by a channel check daily when the reactor is to be operated, and SHALL be A daily channel check when the monitor is required to be in service is prudent and adequate to ensure personnel protection. Additionally, experience has shown this frequency of verification of the_ radiation monitor set points and operability and the evacuation alarm operability is adequate to correct for any variation in the system due to a change of operating I t Deleted:c 4Deleted: E characteristics. Annual channel calibration ensures that units are within the specifications defined by procedures. If no operations are scheduled, then calibration and testing intervals are not applicable.

4.6.2 Evacuation Alarm ...... ... ..... Deleted: A,4wn-41 Applicability This specification applies to the emergency evacuation alarm.

1 I Obiective..

The objective is to ensure that the emergency alarm is audible when l produced during This specification of the Argon-41 to surveillance reactor applies operation.Deleted:

Deleted: To ensure that the production of Argon-actuated automatically or via a manual switch. 41 does not exceed the limits ¶ specified by 10 CFR Part 20.

Specification Deleted: The production of Argon-41 SHALL be measured and/or calculated for each I The evacuation alarm SHALL be verified audible annually not to exceed 15 new experiment or experimental facility that is estimated to produce a dose greater than I mrem at months, _----. --- ------ ...

-. I.. ... .. .. the exclusion boundary rDeleted: 6'Il")

Page 44 of 58,

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 Basis During an abnormal radiation event an evacuation alarm is transmitted through the building via the public address system or the life safety fire panel. The public address system is frequently used for information paging and malfunction is readily apparent. The life safety fire alarm system is maintained in accordance with building codes and is highly reliable with backup power and automated trouble identification. This specification works in conjunction with specification 4.6.1 to comprehensively test the alarm system with this specification only testing the enunciators. Therefore annual testing of the audible enunciator is adequate to verify the alarm function,. Delt*e*: One (I) rmremdose per experiment or experimental facility represents 1% of the maximum 10 CFR Part 20 annual dose. It is considered

,4.7 Experiments ....... prudent to analyze the Argon-41 production for any experiment or experimental facility that exceeds 1%

Applicability of the annual limit Delftd: 4.6.3 ALARA¶ This specification applies to surveillance requirements for experiments. ¶ Applicabi*lo

¶ Obiective This specification applies to the surveillance of all reactor operations that could result in occupational exposures to radiation or the release of radioactive The objective is to ensure that the conditions and restrictions of TS 3.7 are met. effluents to the environs. ¶

¶ Specification The objective is to provide surveillance of all Those conditions and restrictions listed in TS 3.7 SHALL be considered by the operations that could lead to occupational exposures PSBR authorized reviewer before signing the irradiation authorization for each to radiation or the release of radioactive effluents to the environs.¶ experiment. I Basis ¶ As part of the review of all operations, consideration SHALL be given to alternative operational modes Authorized reviewers are appointed by the facility director. that might reduce staff exposures, release of radioactive materials to the environment, or both. ¶

¶ Experience has shown that experiments and operational requirements can, in many cases, be satisfied with a variety of combinations of facility options, core positions, power levels, time delays, and effluent or staff radiation exposures. Similarly, overall reactor scheduling achieves significant reductions in staffexposures. Consequently, ALARA must be a part of both overall reactor scheduling and the detailed experiment planning. ¶

¶ (DeleWe: 6 Page 45 of 58,

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 5.5 Reactor Bay Confinement and VentilationSystems I - - Deleted: Exhaust Specifications

a. The reactor SHALL be housed in a room (reactor bay) designed to restrict leakage. The minimum free volume ,total bay volume minus occupied volume) in the reactor bay SHALL be 1900 m-.
b. The reactor bay SHALL be equipped with two exhaust systems. Under normal operating conditions, the reactor bay heating ventilation air conditioning and exhaust,system exhausts unfiltered reactor bay air to the environment releasing - Deleted: facility exhaust it at a point at least 34 feet (10.5 m) above the reactor bay floor, Upon initiation - Deleted: 24 feet above ground level of a building evacuation alarm, the previously mentioned system is automaticallyjisolated and an emergency exhaust system automatically starts._ I d[ Deleted: secured The emergency exhaust system is also designed to discharge reactor bay air at a point at least 3,4 feet above the reactor bay floor, .1 -j Deleted: 2 Deleted: ground level Basis The value of 1900 m' for reactor bay free volume is assumed in the SAR 13.1.1 Maximum Hypothetical Accident and is used in the calculation of the radionuclide concentrations for the analysis.

The SAR analysis 13.1.1 Maximum Hypothetical Accident does not take credit for any filtration present in the emergency exhaust system. The height above the reactor bay floor leve, of the release helps to ensure adeguate mixing prior to Deleted: ground possible public exposure.

5.6 Reactor Pool Water Systems Specification The reactor core SHALL be cooled by natural convective water flow.

Basis Thermal and hydraulic calculations and operational experience indicate that a compact TRIGA reactor core can be safely operated up to power levels of at least 1.15 MW (thermal) with natural convective cooling.

( Deleted: 6 Page 48 of 5k_

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 6.0 ADMINISTRATIVE CONTROLS 6.1 Organization 6.1.1 Structure The University Vice President for Research Dean of the Graduate School (level 1) has the responsibility for the reactor facility license. The management of the facility is the responsibility of the Director (level 2),

who reports to the Vice President for Research, Dean of the Graduate School through the office of the Dean of the College of Engineering.

Administrative and fiscal responsibility is within the office of the Dean.

The minimum qualifications for the position of Director of the PSBR are an advanced degree in science or engineering, and 2 years experience in reactor operation. Five years of experience directing reactor operations may be substituted for an advanced degree.

The Manager of Radiation Protection reports through the Director of Environmental Health and Safety, the assistant Vice President forOffice of - - Deleted: Safety and Environmental Services Physical Plant, and to the Senior Vice President for Finance and Business/Treasurer. The qualifications for the Manager of Radiation Protection position are the equivalent of a graduate degree in radiation protection, 3 to 5 years experience with a broad byproduct material license, and certification by The American Board of Health Physics or eligibility for certification.

6.1.2 Responsibility Responsibility for the safe operation of the reactor facility SHALL be within the chain of command shown in the organization chart. Individuals at the various management levels, in addition to having responsibility for the policies and operation of the reactor facility, SHALL be responsible for safeguarding the public and facility personnel from undue radiation exposures and for adhering to all requirements of the operating license and technical specifications.

In all instances, responsibilities of one level may be assumed by designated alternates or by higher levels, conditional upon appropriate qualifications.

Deleted: 6 Page 49 of 5k_ I

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 6.7 Records To fulfill the requirements of applicable regulations, records and logs SHALL be prepared, and retained for the following items:

6.7.1 Records to be Retained for at Least Five Years

a. Log of reactor operation and summary of energy produced or hours the reactor was critical.
b. Checks and calibrations procedure file.
c. Preventive and corrective electronic maintenance log.
d. Major changes in the reactor facility and procedures.
e. Experiment authorization file including conclusions that new tests or experiments did not require a license amendment, as described in 10 CFR 50.59.
f. Event evaluation forms (including unscheduled shutdowns) and reportable occurrence reports.
g. Preventive and corrective maintenance records of associated reactor equipment.
h. Facility radiation and contamination surveys.
i. Fuel inventories and transfers.
j. Surveillance activities as required by the Technical Specifications.
k. Records of PSRSC reviews and audits.

6.7.2 Records to be Retained for at Least One Training Cycle

a. Requalification records for licensed reactor operators and senior reactor operators.

6.7.3 Records to be Retained for the Life of the Reactor Facility

a. Radiation exposurefor all personnelmonitored in accordance with I OCFR20.2106. fDeleted:

-[Deleted: facility "JDeleted-: and viitors

b. Environmental surveys performed outside the facility.
c. Radioactive effluents released to the environs.
d. Drawings of the reactor facility including changes.
e. Records of the results of each review of exceeding the safety limit, the automatic safety system not functioning as required by TS 2.2, or any limiting condition for operation not being met.

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