ML14259A336

Response to NRC 4-1-2014 RAI (ML14036A319) Regards Psu Breazeale Reactor (R-2) License Amendment Request(ML12040A166)

ML14259A336
Person / Time
Site:	Pennsylvania State University
Issue date:	09/19/2014
From:	Sharkey N Pennsylvania State Univ, University Park, PA
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14259A336 (45)

Text

PEN NSTATE Neil A. Sharkey The Pennsylvania State University 814-865-6332 Interim Vice President for Research 304 Old Main Fax: 814-863-9659 University Park, PA 16802 nas9@psu.edu www.research.psu.edu USNRC Document Control Desk Docket 50-005 Response to NRC 4-1-2014 RAI (ML14036A319) Regards PSU Breazeale Reactor (R-2) License Amendment Request (ML12040A166)

Dear Sir/Madame:

Attached please find the response to the request for additional information (RAI) issued 4/1/14 regarding the 2/7/12 license amendment request (LAR) for the Penn State Breazeale Reactor R-2 license.

Also attached is revised license wording that reflects the results of the ongoing review process and a Technical Specification (TS) change listing document detailing each change requested. This submittal supersedes the previous detailed TS submittal in its entirety.

Please exempt this request from fees per IOCFRI70.1 .a.( 4)

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

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

Executed on Sincerely

ýel NOTARY PUBLIC State of: '? Subscribed and sworn before this ddayon 2014 1

Coun oCo n y o:Notary Publicf2 Research My cormnsineprs N*,/ J5**.*

Attachments:

RAI (ML14036A319) response Ct)MMONWEALTH OF PENNSYLVANIA Technical Specification Change Summary Tabl Notarial Seal Lord L.Sornsky, Notary Public Updated Technical Specifications Pages State College Boro, Centre County I MvWCommission Exolres

• Nov. 15.w 2016 CC - email Alexander Adams - NRC Xiaosong Yin -NRC Ossy Font- NRC R-2 NRC correspondence File C);-)

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PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES

1. TS 3.3.3, "an air particulate monitor" was used in reference to the fission product activity monitoring. In Table 3 of TS 3.6.1, a "continuous air (radiation) monitor" was used as one of the radiation monitoring channels. Clarify if they are the same monitor and the purpose of these monitors. Revise your proposed TS as required.

The "continuous air" and "air particulate" monitor requirements are the same monitor with redundant operability requirements in the two referenced technical specifications.

In light of the continued confusion the existence of two specifications for the same monitor has generated in the review process, it becomes apparent that the decision to modify TS 3.3.3 as opposed to request deletion (as discussed in the previous RAI (ML12346A349) response #3 and suggested in phone conference) was ill-advised.

PSU requests, via this response, that TS 3.3.3 Fission Product Activity be deleted in its entirety.

The Justification for this request is the requirement for air particulate monitor and evacuation alarm is duplicated in TS 3.6.1 Radiation Monitoring Information. Refer also to the previous RAI (ML12346A349) response #3. The Benefit is reduced duplication in the licensing requirements that have developed over the years since implementation of Technical Specifications and reduced confusion over the specifications and system. The licensing requirements at PSBR will be comparable to other 1 MW TRIGA pool reactors demonstrating consistent licensing process.

Safety Impact - Removal of TS 3.3.3 has no impact on the health and safety of the public or facility workers because the specification is redundant to other specifications. The requirement that a fission product (particulate) monitor be operating whenever the reactor is operating is contained in TS 3.6.1 and the requirement for a functioning evacuation alarm system is contained in TS 3.6.2. The operability of the monitor has no impact on the probability of a release and the consequences of a release are clearly bounded by the PSU Safety Assessment Report (SAR) chapter 13 Maximum Hypothetical Accident (MHA). The basis for 3.6.1.a is adjusted to reflect that fission product monitoring is part of the function.

2. In TS 3.4, you have rewritten the section and replaced it with the proposed TS 3.4.

Provide detailed justification for the proposed changes.

In light of the concerns raised during the review process on the proposed revision to TS 3.4, PSU withdraws the requests for replacement of TS 3.4 and its linked surveillance TS 4.4. PSU requests a small scope revision of TS 3.4.a specification from reactor "is not secured" to "is operating". Justification: This minor wording change aligns the specification with the specification objective and the guidance given in ANSI/ANSI5.1 Technical Specifications for Research Reactors 2007. The Benefit of this change is the avoidance of a TS LCO violation during shutdown conditions where concurrent maintenance often occurs that might result in the reactor bay door being opened while the reactor key is inserted to perform instrumentation checks. Safety Impact - since TS will continue to require the reactor be shutdown whenever the reactor bay door is open, there is no impact on the safety to the operators or the public.

Page 1 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES Specifically, respond to the following:

a) Define the "low pressure confinement boundary (LPCB)".

b) Describe the relationship between the LPCB and the confinement that is defined in the current PSU TSs?

Request for LPCB is withdrawn.

c) Describe how the LPCB is established, including a discussion of the materials required, how they will be put in place, and what instruction is provided for establishing the boundary.

Request for LPCB is withdrawn d) Clarify if there will be surveillance in place associating with this LPCB.

Request for LPCB is withdrawn e) Describe how this proposed LPCB meets the performance requirement as specified for a confinement and is consistent with the definition in TS 1.1.8.

Request for LPCB is withdrawn f) Describe the time needed to re-establish a confinement for the reactor bay when a confinement as defined in TS 1.1.8 is lost and describe how to verify the operability of the LPCB.

Request for LPCB is withdrawn g) Evaluate the impact of an emergency or accident situation on the methodology used for establishing a LPCB and the effectiveness of the LPCB.

Request for LPCB is withdrawn h) Describe the potential radiological impact to the personnel establishing the LPCB and others affected by the lack of confinement, until the end of the time it takes to establish a temporary confinement boundary, during accident conditions.

Request for LPCB is withdrawn i) In this proposed TS, it also stated that "[L]arge penetrations SHALL NOT exist" to the reactor bay during reactor operation. Explain how this proposed TS is satisfied when the reactor bay heating ventilation air conditioning and exhaust system (RBHVES) is in service since the confinement isolation dampers represent a large air passage to the reactor bay.

The request to address large penetrations in TS 3.4 is withdrawn, however the question is still relevant. With the RBHVES in service, the system is part of the confinement enclosure and does not represent a large opening. This is essentially same configuration as the existing Facility Exhaust Fan (FES) and Emergency Exhaust (EES) ducts and dampers. During an "accident" the system is secured and the dampers automatically close isolating the penetrations and duct work similar to the current FES damper operation.

Page 2 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES j) Describe why the additional open dampers, running fans, and connections to outside air related to the RBHVES do not compromise the objective of TS 3.4 and continues to satisfy the basis to ensure that the air pressure in the reactor bay is lower than the remainder of the building and the outside air pressure.

Relative negative pressure is a consequence of exhaust fan operation, restrictions caused by building structure on inlet air flow, dynamic wind loading on the building, and attached building ventilation status.

The penetrations and ductwork added by RBHVES are similar in size to the existing roof fan penetrations that communicate directly with outside air. The existence of the ductwork, filters, and enthalpy wheel have the characteristic of slightly restricting flow if the dampers are open and all fans are shutdown. The new dampers are an active component more positively closed by an actuator as opposed to FES dampers which rely on relative barometric pressure (backflow) and gravity to operate. With the ventilation fans operating as designed, the ductwork becomes part of the confinement controlled air movement path and is consistent with the definition of confinement. During an evacuation, this path is isolated from the remainder of confinement by design (Confinement isolation dampers close). The failure of the system to isolate is bounded by the MHA and does not create a new event. Multiple simultaneous failures during an MHA event such as exhaust fan off, dampers fail open and supply fan keeps running are not credible. Even if a non-credible failure were to occur the RBHVES exhaust is the same as the FES and EES, no new event or release path or scenario is created. Commissioning testing of the system was completed to ensure that air flow balance results in more exhaust than makeup therefore fulfilling the definition of confinement. As with the existing system, failure of a running fan may require remedial action by the operator to prevent TS LCO violation.

(see also RAI 9 and 1 O.d response for a discussion of the consequences of non-negative air pressure conditions).

3. Additional information is needed for TS 3.5. Respond to the following:

a) Provide an analysis supporting your justification to extend the reactor operation time from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 30 days without an emergency exhaust fan. In Section 13.1.1 of PSU's current Safety Analysis Report (SAR), a credit has been taken to evaluate the radiological consequence using a stack release dilution. When this stack release credit can no longer be taken due to the fact that there is no operable emergency exhaust fan available, what is the radiological consequence? Show a calculation to support your justification. (see Regulatory Guide 1.145 "Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants," Revision 1, for an example of a method acceptable to the NRC staff).

The analysis of the Maximum Hypothetical Accident (MHA) in Chapter 13 of the PSU SAR does not take credit for an elevated stack release or the filtration provided by the emergency exhaust system. The analysis is a ground level release with no plume, weather conditions or dispersion of the release when calculating the dose at the boundary (facility restricted area fence). The analysis assumes only dilution by mixing in the cross-sectional area of the reactor building with low velocity wind (1 M/sec) and in-situ decay after the fuel failure (after t=0). The accident release (failure of a hot operating fuel element in air) analysis is designed to provide the worst case release of airborne fission products to the un-restricted area without credit for partitioning, plate out, capture in filters, or dispersion. No credible mechanism to accomplish a release of this Page 3 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES magnitude from the fuel has been devised. The MHA does not consider direct radiation (shine) from the fuel element in air or released products remaining in the reactor bay.

The extreme conservatisms of the PSU MHA calculation include:

• The fuel element is assumed to operate at the maximum steady state power of 24.7 kW (provides an unrealistically high fission product inventory) for an extended period.

" The surface of the fuel is unrealistically assumed to be operating at the LSSS value of 650 C when the release occurs. (maximizes release fraction) as opposed to a more realistic 200 C.

" The element fails in air (no credit for water capture of the operating fuel element release)

• All gap fission products are released (no retention, plate out or capture of noble gases or halogens)

• Instantaneous mixing in a conservative volume for the reactor bay free air space.

With the EES inoperable, leak rate from the confinement is reduced allowing more decay in place and plate out of fission products on material in the confinement. Fission product leak rate would be driven by dynamic building pressure (wind loading) and attached buildings operating ventilation systems. A lower release rate will reduce the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> calculated exposure to the public due to released fission products in all cases.

The conclusions reached in NUREG CR2387 Credible Accident Analyses for TRIGA and TRIGA-Fueled Reactors although dated are noteworthy. NUREG CR2387 states for operating reactor fuel failure event:

Swelling of the fuiel could lead to cladding rupture and release offission product activity into the pool. The radiologicalconsequences of such a release would in general be confined to the immediate vicinity of the reactor. Even assuming the relatively large releasefr-action of 10-4, offsite, lifetime, whole body dose equivalents would not exceed 1 mrero, mostly from noble gases. Radio-iodinesand otherfission products would be largely retainedin the pool, and the dose equivalents to criticalorgans of offsite observers would be insignificant--i,e.,

less than the one millirem value de minimnis guidance level adopted at DOE sites.

And, for the more likely fuel handling events:

The calculateddose equivalents are extremely conservative and thus representan extreme upper limit. if such an accident occurred,exposure levels would more realisticallybe one to several orders of magnitude lower. Hence, even under the worst of circumstances, the potential exposure to personnel outside the facilityfrom any crediblefuel-handling accident would be small and of little or no health significance. Whole body and thyroidlife-time dose equivalents are well within those putforth by regulatory requirements or by internationalbodies concernedwith radiationprotection (ICRP 1977, 1978; NCRP 1971, 1975, 1976).

Additionally, a comparable facility (1 MW stainless steel clad TRIGA) demonstrated in license submittals using slightly more realistic assumptions much lower public and worker exposure from a release than the PSU analysis (reference Chapter 13 Oregon State University (OSU)

SAR). The OSU TRIGA analyses show that the confinement is wholly unnecessary to meet the 10CFR20 unrestricted area effluent limits during their MHA. At the OSU TRIGA, TS require the exhaust systems be secured to reduce public exposure during a release event and no TS requirement for a confinement is specified in the OSU license.

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PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES Since the methodologies described in Reg Guide 1.145 are methods to dilute and disperse the release and since the PSU assumes no dilution or dispersion, the PSU SAR is more conservative than Reg Guide 1.145 and clearly bounds any credible scenario making additional analysis un-necessary and un-warranted.

b) Identify radiation release pathway(s) if none of the exhaust fans are operable.

The leakage paths would be out of the reactor bay into the attached buildings and the environment through air gaps in the confinement enclosure. The leak rate would be less than if the fans were operating and the result of the dynamic and static pressure differences caused by the wind or adjacent buildings ventilation systems. The sum of all these pathways and the slow release rate would further dilute the release and allow more time for decay resulting in a reduction in the MHA assumed dose to the public in the unrestricted area.

c) Calculate the radiation consequence to the nearest receptor if none of the exhaust fans are operable for normal and post-accident conditions.

NORMAL Operations: As described in the PSU SAR Section 6 Engineered Safety Features, a reactor bay exhaust fan is operated to minimize the buildup of any airborne radioactive material and gases resulting from reactor operation. During routine 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. The SAR elaborates that Ar 4' is the only gas that presents an accumulation issue. Gases may also slowly migrate to other areas of the facility due to changes in air flow patterns. TS 3.6.1 Radiation Monitoring requires operable airborne particulate and radiation monitors whenever the reactor is operating During normal operations with an exhaust fan, Ar 4l is barely detectable in the reactor bay (MDA -3E-7 uCi/ml). Per 10CFR20 App C, Ar 4' 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. And if levels were somehow to accumulate, the reactor bay radiation monitors would again alert the operators to the developing hazard. Note per TS 3.5.b the moving of fuel or a fueled experiment is not authorized without an exhaust fan operating. Please refer to the response to Question 4 of the previous RAI (ML12346A349).

POST-ACCIDENT: For the MHA the normal exhaust fans automatically shut down. With no fans operating, the dose predictions in the unrestricted area approach zero as the release rate approaches zero in any calculation. The release rate will not reach zero because dynamic air pressure (from wind) will result in some air exchange with the confinement. See 3.a), b) above and PSU SAR Section 13 for the assumptions built into the SAR MHA.

Any additional calculation using reduced flow rates is bounded by the existing MHA, so further calculations are unnecessary to evaluate the impact of the release on the health and safety of the public.

d) Specify who will be directly exposed (worker and general public) if an emergency occurs and there is no emergency exhaust fan operable.

Personnel inside the reactor bay or inside the restricted area of the facility: The emergency exhaust fan is normally secured. EES starts automatically on Evacuation alarm actuation as described in existing and proposed TS 3.5 basis. When the evacuation alarm sounds personnel are required to exit the facility. The SAR MHA assumes it takes one minute Page 5 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES for operators to exit the reactor bay. There is no appreciable decrease in radio-nuclide concentration in the first minute of an event due to exhaust flow. Therefore, personnel exiting the reactor bay will receive essentially the same exposure whether or not the exhaust system is operable.

General public at the boundary of the restricted area: Without a start of the emergency exhaust fan, the release rate will be lower than the value assumed in MHA. With a lower release rate the public will receive a lower exposure than that outlined in the PSU chapter 13 SAR MHA as discussed greater detail in response to Question 4 of the previous RAI (ML12346A349). With no exhaust fan operable, dose to the public is reduced. For comparable facilities (RTRs) without filtered exhaust systems, the exhaust system is secured by TS requirement during a release event to reduce offsite exposure. With no operable EES, this facility will respond as most other comparable licensed facilities do, normal exhaust is secured, and radionuclides decay in place with slow confinement leakage driving offsite dose, e) Calculate potential maximum exposure during a movement of irradiated fuel or a fueled experiment when the fuel ruptured in the air and there are no exhaust fans operable. Use the maximum possible time period for this calculation from the discovery of the fuel rupture to the time when personnel were evacuated from the reactor under the assumption that there are no operable exhaust fans. Compare this potential maximum exposure to the scenario where fuel movement is immediately stopped after the discovery of no operable exhaust fans at the reactor bay.

This question appears to be a result of a misunderstanding of the requested TS revision. There is no change in the requirements for ventilation operations during fuel movement. Actual releases from a fuel failure underwater (at ambient temperatures) during fuel movement will be negligible or undetectable as described in NUREG CR2387 CredibleAccident Analyses for TRIGA and TRIGA-Fueled Reactors. The same can be said for TS allowed fueled experiments where the failure occurs in the reactor pool.

The following simple calculation is offered to address the question of additional operator exposure time during the existing Chapter 13 MHA.

Calculation Assumptions:

" No exhaust

• PSU SAR MHA event (un-partitioned air release of available fission products from a 650 0 C fuel operated at sustained 24.7 kW, instantaneous mixing in reactor bay atmosphere)

• No direct (gamma/neutron) exposure from the fuel element (only from released activity)

From Chapter PSU SAR 13.1.1

" An operator in the reactor bay will accumulate occupational exposure during the initial event sequence at 1038 mR/minute. (before exhaust or decay lowers the exposure rate)

" It takes no more than 1 minute to evacuate the bay From experience, it takes a calm skilled operator approximately 30 seconds to 1 minute to store a fuel element in an immediately available underwater rack or core location.

Assume

• 2 minutes to store fuel element (2 to 4 times normal)

Page 6 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES

• 30 seconds to store fuel tool 0 1 minute to leave reactor bay.

3.5 minutes

• 1038 mR/minute = 3633 mR TEDE As mentioned in response to RAI Question 3, the PSU MHA assumptions are highly conservative. A slightly more realistic but still conservative number can be taken from the same scenario at the Oregon State University TRIGA reactor SAR (Table 13-9). A five minute exposure (without exhaust fans) to a reactor room occupant yields a calculated TEDE of 26 mR during a MHA.

The question also asks to compare this exposure to an exposure where "fuel movement is immediately stopped." There is no practical difference between immediately stopped and "complete the fuel movement in progress." Fuel handling is performed with hand held tools.

The operator will immediately stop fuel movement on a reactor bay radiation alarm (by safely storing the fuel using the fuel handling tool). Therefore the exposure during a MHA level release for an "immediate stop" is the same as described above.

f) Describe how the confinement negative pressure is being monitored and is the loss of negative pressure immediately obvious to the reactor operator at the controls?

Negative pressure is a consequence of exhaust fan operation. Historically, FES damper position was the indicator of fan running status available to the operator (this indication remains available for the roof fans). No pressure monitoring was provided and negative pressure was an implied characteristic of fan operation and confinement construction.

RBHVES has added supply and exhaust damper status (not closed) light and negative pressure status (greater than -0.01 inch water on the least negative of 3 sensors) as a simple operator aid during normal operation.

Since there is no consequence of a loss of negative pressure, there is no need for the loss of negative pressure to be "immediately obvious." The indicating light is visible to the reactor operator from the control room and currently, the status of building negative pressure is checked during hourly logs when operating.

g) What is the maximum potential radiological consequence when considering the combination of this proposal, which will allow 30 day reactor operation without an emergency exhaust fan and the extended 1-hour operation without any operable exhaust fans, with the proposal in TS 3.4, which will allow a LPCB to be established to re-establish a confinement?

Since the concept of a LPCB has been abandoned (see RAI question #2 response), only the 30 day EES and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> FES time clocks will be addressed.

The maximum potential radiological consequences are bounded by the assumptions of the SAR MHA.

• The MHA source term is highly inflated by the power history, Fuel temperature, release and partitioning assumptions Page 7 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES

" The MHA disperses the entire source term uniformly into the reactor bay volume without removal by water or plate out on building components.

" The EES (or the FES or RBHVES or any other driver) drives an unfiltered ground release

• The release is mixed and diluted in the leeward area of the building by the 1 m/sec wind speed assumption, no further dilution is assumed

" The source term components decay during the duration of the release.

" Shine is not considered in this release exposure calculation.

Since dilution is fixed by the MHA assumptions, integrated dose at the boundary of the restricted area is influenced only by the release rate. Decreasing the release rate (CFM from the fan) reduces integrated dose by allowing for more decay in place of the source radio-nuclei.

Increasing the exhaust rate can have a slight effect on the integrated dose (92% of which is accumulated in the first hour of the MHA).

With these concepts in mind, let us evaluate the impact of each of the conditions:

• No EES fan results in a release driven only by atmospheric conditions (leakage). Since no filtration is assumed to occur with the EES, a reduced release rate allows more time for decay in the reactor bay and integrated dose to the public at the restricted area boundary is reduced.

• 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> operation with no operable exhaust fan will result in result in buildup of Ar 41 in the reactor bay. Storing the Ar 41 and allowing decay in the reactor bay reduces public exposure. Additionally since the Ar 41 would have been released without mitigation to the public, its contribution to public dose is already accounted for and reported as part of routine operation. The facility generates less than 10% of the annual release limits.

Integrated dose to the public in the unrestricted area is unaffected or reduced as a result of no exhaust fan.

None of the conditions presented in the question increase the source term of the MHA. In the existing MHA calculation, only release rate affects dose rate in the unrestricted area because the calculation assumes some decay in place of radio-nuclei. From the PSU SAR MHA (pg.

XIII-32):

The activity is removed rapidlyfrom the reactor bay and about 92% of the TEDE in the unrestrictedarea is received in the first hour. Essentiallyall activity has been releasedto the unrestrictedareawithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> anddoses in both the reactor bay and the unrestrictedarea have reachedtheir maximun values. Release of the activity from a fuel element over an extended period oftimne would reduce the dose because of the decay of short half-life radioisotopesbefore release.

Note for the integrated dose in the unrestricted area, any factor slowing the release from the confinement (example no exhaust fans) will reduce dose because of in-situ decay.

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PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES

4. Section 7.3.1.3 of the SAR lists reactor console digital control computer (DCC-X) generated scrams. Two of these scrams, "Reactor Bay Truck Door Open" and "Both East and West Facility Exhaust Fans Off" help ensure the confinement pressure boundary is maintained. Will these scrams remain in place and are any additional scrams being developed to support operation of the RBHVES?

The DCC-X computer provides user features and scrams from auxiliary input ports of the input output (1/0) system. A more accurate purpose of these scrams is "to minimize the possibility of an operator induced LCO violation by preventing reactor reset." The FES fan off scram will be eliminated with the incorporation of the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> remedial action specifications in TS 3.5.a.

Currently the facility runs both fans to ensure that scrams do not occur. This will help reduce spurious reactor scrams and save energy. Since operation of the reactor with the reactor door open remains prohibited, no plans are in place to remove the reactor bay truck door scram at this time. No additional scrams for the RBHVES system are anticipated.

5. Your response No. 2 to NRC's RAI dated January 7, 2013, and the revised PSU SAR Chapter 6, described most of the components in the RBHVES system. There are several components on Figure 6-1 that have not been adequately described:

a) Provide additional details to the purpose of the economizer air damper and the relief damper.

In the design of the RBHVES, for energy efficiency under certain weather conditions, an economizer mode was included. In the economizer mode, the 2 existing roof fans are started and the economizer air damper is opened to provide makeup air without the need for air conditioning. As long as the reactor bay is negative relative to the ambient pressure, air will be drawn in the makeup air damper to replace air removed by the roof fans. This mode of operation (when enabled) is anticipated to save cooling cost under certain ambient air conditions to comply with energy efficiency standards and codes.

The relief damper is present to provide duct work protection from the dynamic load caused by the rapid closure of the confinement isolation dampers. To simplify the reliability of the interface between the RBHVES control system and the emergency evacuation system, the only communication is through a set of auxiliary contacts on a multiplier relay in the emergency evacuation system. When the evacuation system is actuated, an evacuation system relay opens contacts that interrupt power from the RBHVES system to the confinement damper actuators. Without power, the dampers fail to the closed position. The RBHVES digital logic senses the damper power interruption and trips the exhaust, supply, and recirculation fans and opens the relief damper.

b) On Figure 6-1, the gravity backdraft dampers, makeup air damper, economizer makeup air damper, and relief damper (dampers) are designated as normally closed. Describe the conditions when these dampers would be open.

The gravity backflow dampers are open whenever the associated roof fan is in operation. The gravity backflow dampers are opened by barometric action (negative pressure/flow forces) that exist when the FES fans operate. See answer 5 above for the economizer and relief damper operation.

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PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES c) The economizer air and relief dampers appear to communicate with outside air; describe the location of the intake or discharge point for this flow path.

The economizer air and relief dampers are located on the roof of RSEC west wing (laboratory wing attached to and west of the reactor bay). The dampers communicate with the outside air at this intermediary roof height of about 15 feet above the reactor bay floor.

d) No back draft dampers are shown for either one of these normally closed dampers, which means that the air can flow in either direction. Are these intended release points, and if so, what is the elevation for the release? If they are not intended to be a discharge point, what prevents air flow in the discharge direction?

As with the FES roof fan dampers, when the dampers are open, air could flow in either direction based on local static and dynamic pressures. When the dampers are closed only minor leakage (in or out) can occur. The RBHVES economizer and relief dampers are not intended release points and nothing other than damper position and relative pressures prevent flow. The elevation of these dampers is approximately 15 feet above the reactor bay floor reference elevation. When the system is shutdown, the confinement dampers isolate these dampers from the confinement. With the system operating, the relief damper is closed; the economizer may be open as described in 5.a) above. It would take multiple failures to have these dampers act as a release path during an accident, and leakage or release through this path is of no consequence during normal operations since the same unfiltered air is discharged to the environment at essentially the same location. (see also RAI answer to 3.c and 9.e) e) Are these normally closed dampers positively controlled (i.e., locked closed) or is their position controlled only via the RBHVES controls?

The position is only controlled by the RBHVES digital control system.

6. In the proposed TS 3.6.2, respond to the following:

a) Specify the time limit on how long the evacuation alarm could remain out of service. The proposed language would allow the facility to not have an automatic alarm for an unspecified period, providing the facility announcement system is "verified" to be working.

The local automatic annunciators on the radiation monitors in the monitored areas and the reactor control computer will still function to automatically alert the workers and the operators to any hazardous condition. This is the normal license requirement at other facilities. There is no technical basis to require a facility wide evacuation system. Existing Fire safety building codes require the fire alarm systems be immediately returned to service, but no time clocks are specified. The facility finds no regulatory or public health and safety basis for an additional restriction in technical specifications. However to address this NRC concern, a 30 day time limit on alternate alarm use is added to TS 3.6.2.

Page 10 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES b) Describe the impact to the operator actions when the alarm is not operable and other means must be utilized to notify facility personnel for the need to evacuate.

Specifically address the potential to delay the operator from exiting the reactor bay following an elevated radiation level condition and the related dose consequence.

With the evacuation audible alarm inoperable, the on-watch RO or SRO will make announcement using the public address system from the control room or any phone handset to evacuate the building. This is the same expectation that exists for events that do not automatically actuate the evacuation system. During an accident with no evacuation alarm, the time to evacuate the bay or transit from the control room through the reactor bay would not be affected as there is no phone handset in the reactor bay for an operator to delay exit while making an announcement. Worst case dose in the reactor bay during the MHA is provided in PSU SAR Chapter 13 and the additional fuel handling scenario requested in 3.e above.

7. Provide detailed technical justification for the removal of TSs 3.6.3 and 4.6.2 regarding the Argon-41 (Ar-41) concentration limit and monitoring. Specifically, respond to the following:

Penn State withdraws the request for deletion of TS 3.6.3 and 4.6.2 at this time.

a) Are there other normally released isotopes that will have a health and safety impact being discharged from the facility operation?

Penn State withdraws the request for deletion of TS 3.6.3 and 4.6.2 at this time.

b) If there are other isotopes, evaluate the scenario where Ar-41 is the only effluent release versus when there are other isotope effluent releases from the reactor operation.

Penn State withdraws the request for deletion of TS 3.6.3 and 4.6.2 at this time.

Page 11 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES

8. The current TS 4.6.1 requires that the facility radiation monitors and the evacuation alarm system "SHALL be channel tested monthly not to exceed 6 weeks. They SHALL be verified to be operable by a channel check daily.... and SHALL be calibrated annually, not to exceed 15 months." In the proposed TS 4.6.2, the only requirement for the evacuation alarm is that "the evacuation alarm SHALL be verified audible annually not to exceed 15 months." Respond to the following to address the differences between the current TS and proposed TS in relating to the facility's evacuation alarm's operability:

General Discussion:

The TS 3.6.1 prescribed radiation monitors are 3 of 7 radiation monitor inputs to the DCC-X control computer. When DCC-X is operating, the DCC-X high alarm setpoint on any one of the monitors (that are not in bypass) or a manual pushbutton will initiate a reactor scram, FES shutdown, RBHVES damper closure, EES start and evacuation horn via the building public address system. The evacuation "system", including the manual pushbutton, is a software function of DCC-X.

The current TS 4.6.1 combines the surveillance requirements of the radiation monitors with that of the evacuation alarm. This is not a technically valid concept.

The daily "channel check" for a radiation monitor channel is a well-established non-intrusive concept defined in TS and the industry but is an unclear requirement for the evacuation system software. The facility interprets this as a requirement to actuate the evacuation system daily, cycling the fans off and on and disrupting the facility, police, nearby buildings and passersby with sounding of the evacuation horn.

The monthly "channel test" again is a well-established concept defined by TS for the radiation monitors and includes operability testing of the function to initiate an evacuation. The horn and fans are cycled multiple times for the testing of the seven radiation channels. Channel test is interpreted at the facility as another actuation test of the evacuation system accomplished during the channel test of the radiation monitors.

The annual calibration is defined by TS for the radiation monitor channels but has no application to the evacuation system.

The result of the combination of the testing requirements of radiation monitors and evacuation alarm in the same surveillance specification has been excessive testing of the building evacuation horn, unnecessary wear of the fan systems and components, and complacency on the part of building occupants to the evacuation horn. As described in the amendment submittal, the planned incorporation of the evacuation horn into the life safety (fire alarm) system improves reliability and makes the current modes and frequency of testing unfeasible.

Separation of the audible horn from the radiation monitor requirements is necessary for this upgrade.

a) What constitutes an evacuation verify protocol?

Currently, the evacuation alarm verification is done daily by audible horn sounds. The verification of the audibility of the horn is checked on the monthly radiation monitor channel check as the horn is sounded multiple times, and following maintenance on the systems. The audibility of the horn is verified with operators in different areas of the building during the testing.

Page 12 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES b) How do you verify the evacuation alarm's operability?

The audibility of the horn is verified with operators in different areas of the building during the testing.

c) Clarify the technical difference between the terminologies of a "verify" and a "test" and justify that the evacuation alarm verification can meet the objective of the current TS 4.6.1.

"Verify" is the act "to make sure or demonstrate that (something) is true, accurate, or justified."

"Test" is a procedure or process performed to establish the quality, performance, or reliability.

A "test" is a specific procedure used to establish the conditions in order to "verify" performance.

As stated in the objective of TS 4.6.2 (as proposed) the surveillance ensures the alarm is audible when actuated.

The specification as submitted was a less verbose version of the evacuation alarm SHALL be tested to verify audibilityannually not to exceed 15 months.

The exact mechanism of the test or conditions need not be stated to ensure clarity of the requirement. Similarly, existing technical specifications surveillances use verbs such as measured, determined, compared, inspected, cleaned, lubricated, visually inspected, considered, and verified.

In the planned upgrade of the evacuation system to use the life safety (fire alarm), technicians conduct an annual test (in addition to the continuous computer self-diagnostics) required by building codes to verify that each evacuation enunciator (and strobes) function as designed.

In addition, based on your revised SAR Section 6, the RBHVES is intended to perform the same function as the emergency exhaust system (EES) described in Section 1.3 of the SAR utilizing one or more of four separate exhaust fans. Fresh air can now be supplied by the RBHVES in addition to the previously assumed leakage around doors and penetrations. Respond to the following questions specifically applicable to RBHVES system:

It is presumed the lead in (above) for the remaining questions meant the RBHVES is intended to perform the same function as the facility exhaust system (FES) as described in Section 1.3 of the SAR, not the EES. The RBHVES does not perform HEPA or Charcoal filtering that the EES does and the RBHVES is isolated in an "emergency" condition. The amendment does not seek to credit the RBHVES for the EES under any circumstance.

9. Prior to installation of the RBHVES the facility exhaust system (FES) provided sufficient flow to ensure negative pressure is maintained with the operation of a single fan, so no monitoring of relative pressure was required. Use of this system requires a flow balance to ensure the negative pressure is maintained.

Page 13 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES a) Describe how this flow balance was performed on RBHVES to ensure adequate negative pressure in the reactor bay for the initial installation.

The RBHVES has not yet been commissioned to perform this function and is run in parallel with the FES. Ventilation modifications in one of the attached buildings and additional fire barrier seals must be completed before final testing can be completed. The system provides the status of relative air pressure to operators to confirm that the exhaust systems are exhausting.

b) How is this flow balance adjusted and how frequently is that adjustment required?

The flow balance will be completed as part of the commissioning. The specified acceptance criteria for system operation require the ability to maintain air flow and by consequence negative pressure. No other specific or routine balancing is planned.

c) Are the licensed reactor operators capable or expected to make these adjustments?

No, operators cannot change damper positions. Operators can influence flow and (by that action) negative pressure by manually starting/stopping additional exhaust fans.

d) Does a senior reactor operator (or other senior licensed staff) supervise or approve the flow balance adjustments?

Senior licensed staff review the results of the commissioning measurements.

e) Identify the minimum pressure differential (negative reactor bay pressure) required to ensure adequate radiological control and the basis for that determination.

There is no "minimum" differential pressure to ensure adequate radiological control. As discussed in answer to question 3 above for the TRIGA reactors in general and for PSU in particular, there is no impact on public health and safety as a result of operation of the facility, release during the MHA or release from any experiment currently allowed under the limitations of TS 3.7 Limitations of Experiments. The fundamental purpose and basis of the FES and the its upgrade - RBHVES as stated in SAR Section 6.2.1 is to control airflow through the reactor bay to minimize worker radiationexposure and to release the reactorroom airin a controlled manner (-3000 cu.ft/min or 8.5 x 104 /min with both fans running) where dilution and diffusion of the effluent occurs before it comes into contact with the public. The purpose is to dilute reactor bay air for ALARA considerations, the design consideration is flow (dilution) not negative pressure. Experience has shown that with no exhaust system in operation, natural background Radon daughter products build up in the reactor bay and result in spurious air particulate monitor alarms and evacuation system activation. Additionally, unrestricted operation of the reactor without exhaust will eventually result in accumulation of measurable Ar 41 concentrations.

Like Radon, buildup of Ar 41 may be observed on the air particulate monitors and may be noted as abnormal indications on the area monitors. No other radiological considerations are part of the design bases of FES or RBHVES. Although the presence of negative pressure may help prevent the spread of volatile radioactive material into adjacent facility areas during a spill it is not a design requirement and spill response protocol calls for securing unfiltered ventilation.

Page 14 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES

10. Your response No. 2 to NRC's RAI dated January 7, 2013, and the revised PSU SAR Chapter 6, described most of the components in the RBHVES system. Pressure sensors were not mentioned in this description.

a) Are there any pressure sensors installed or related to the RBHVES? If you do not have pressure sensors describe how you ensure that the air pressure in the reactor bay is lower than the surrounding building or the atmosphere as stated in the SAR and TS bases.

To provide assurance that the system is operating as expected 3 differential pressure (dp) sensors were installed. The sensors have no control functions.

b) Describe, in detail, the displays, sensors (including location), controls, and information available to the operator for the RBHVES.

The operator has following indications/information for RBHVES

• Existing FES roof fans - on/off demand status and damper (position sensor) on DCC-X operator and message screens (no change), new RBHVES "demand on" light (small LED west wall attached to existing motor controller)

• Confinement dampers not closed status light - if either one of two damper is "not closed" from a switch on the damper operator this indicator is lit. The green status light is located on the east wall of the reactor bay in sight of the control room operator.

• Differential pressure negative status light (software driven based on lowest (least negative) of the 3 sensors). The green status light is located on the east wall of the reactor bay in sight of the control room operator.

o Reactor bay to west building wing dp - West reactor bay wall with local readout (see picture below) o Reactor bay to east building wing dp - East reactor bay wall with local readout o Reactor bay to outside dp - South reactor bay wall (no local readout)

The operator has the following controls for the RBHVES:

• Existing FES roof fan operator manual on/off demand through DCC-X

• Existing evacuation system actuation (reactor console pushbutton) which closes confinement dampers independent of RBHVES.

• New confinement damper close pushbutton (west wall of control room)

Page 15 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES Local DP Indication I RBHVES Control Room Shutdown c) Explain the expected operator action when the negative reactor bay air pressure appears to be compromised based on the RBHVES indications.

Negative pressure is an indicator of proper system operation, just like the existing FES fan on status. If the dp status light or damper status light indicate a problem, the control operator is expected to notify the SRO who will investigate the cause and initiate corrective action which might include starting additional fans, shutdown of RBHVES, and/or initiating maintenance.

d) What is the radiological consequence when the reactor bay negative pressure is not maintained?

It is assumed the intent of the question is what are the radiologicalconsequences of a positive pressure in the reactorbay relative the outside or adjacentbuildings? Since the normal release is unfiltered with no delay, the radiological consequences to persons in the unrestricted area do not change. With positive pressure in the reactor bay monitored air will flow through open doors or gaps into the adjacent facility wings. This diluted reactor bay air and any associated airborne radio-nuclei would create a slight increase in background radiation levels in the adjacent laboratories and office space. From SAR Table 11-1, Reactor bay Ar4 1 levels are calculated to be 4.2E-8 pCi/ml (.014 DAC or .035 mR/hr). It is not plausible that the dose to a person in the adjacent buildings from the routine reactor operation be any higher than the source air levels.

2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> exposure to this source air term is 70 mR in a year. Ar4 1 exposure results in a whole body immersion dose. The entire facility is a controlled access area and all personnel in the facility buildings (including visitors) are monitored for whole body exposure. Therefore, there is no adverse radiolo-gical impact to the staff or visitors to the facility or the public.

Page 16 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES e) If pressure sensors are present how sensitive are they to normal personnel movement in and out of the reactor bay and does this tend to create nuisance alarms for the operator?

The logic for the status light does limited averaging and does not typically change state during an individual passing through a door. There is no alarm function to disturb the operator, the light is checked during hourly logs.

f) Does the RBHVES control contain any supervisory logic?

The RBHVES has supervisory logic and off-site centralized performance monitoring and alarm.

However, on emergency, operator demand, or loss of reactor control power the system is isolated by automatic closure of the confinement dampers without reliance on the supervisory system or external power.

11. In the revised SAR Section 6.2.1 "Confinement," it states that the confinement isolation dampers were programmed to close on loss of control power.

a) Describe the motive force to close these dampers on loss of power. If it is an energy storage device, describe this energy storage device including how long the charge can be maintained.

The dampers are motor-operated with a capacitive energy storage device. On loss of power to the actuator the device immediately drives the dampers closed so additional storage time is un-necessary.

b) What speed will the dampers move (relative to how they are normally powered) when relying on the energy storage device to close?

As installed and operated by the facility, the isolation dampers are almost always operated in the close direction on stored power. The operator's only control of the system is to remove power from the dampers and verify they drive closed. The dampers close in about 5 seconds.

c) What surveillance is performed to ensure the system functions as expected on loss of external alternating current power?

Beyond commissioning testing, no continuing testing of the RBHVES system for response to loss of AC will be conducted. As mentioned above, the only response of RBHVES to loss of AC is to close the dampers. The dampers are "fail-safe" (closed) on loss of power and are now part of the daily (under current TS) and monthly (current and amended TS) system test. The test is conducted by removing power to the actuators via the evacuation alarm relay and verifying the dampers close.

12. The RBHVES isolates on conditions that cause the building evacuation alarm to be sounded. This is required to ensure that the EES controls the release path or airborne radiation during accident conditions. What testing has been performed to ensure the confinement isolation dampers provide sufficient isolation to the reactor bay from the RBHVES to prevent it from compromising the intended release path?

The confinement isolation dampers close when demanded by the operator, on loss of power, or on any evacuation system actuation. RBHVES supervisory loQic does not monitor or isolate on Page 17 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES any confinement conditions. No specific or ongoing testing is planned or necessary to ensure the leak tightness of the confinement dampers. The radiological consequence analysis does not take credit for an airborne release and the release path (via EES or other locations) is a ground release. Therefore release via an open confinement damper (with or without the EES operating) is bounded by the MHA. The consequence of confinement damper failure is same or less than it is for the existing FES roof fan gravity backflow dampers. During a release event where the RBHVES shuts down and the EES starts, the flow rate from EES will assure that any leakage that occurs (damper closed or not) will be into the building. Air moving into the confinement will take the paths of least resistance. A confinement damper open will allow air in-leakage from exhaust header through the associated filters enthalpy wheel and static fan resistance. Adding multiple additional failures to the already non-credible MHA is not reasonable, but continued operation of the RBHVES system throughout the event is still practically bounded by the MHA as the release rate and point is the essentially the same and no filtration was credited in the MHA radiological consequences.

13. Review of the revised SAR Section 6.0 revealed that the RBHVES (multiple components or control system failure) has the potential to pressurize the confinement.

Consistent with Title 10 of the Code of FederalRegulations Section 50.36(c)(2)(ii)(C) propose a TS for maintaining the reactor bay at a negative pressure relative to the remainder of the building or the atmosphere consistent with the bases for TSs 3.4 and 3.5. If credit is being taken for the pressure sensors, include a surveillance with a frequency for testing and calibration of these sensors and associated alarm responses.

The proposed TS should be a replacement for the existing TS requiring at least one facility exhaust fan to be running. If it is not being proposed, provide justification.

The responses to several questions in this RAI and the previous RAI (ML12346A349) have discussed the radiological impact and lack of consequences of loss of negative pressure or of positive pressure during routine operations. During routine operations, the RBHVES functions as a dilution mechanism for ALARA considerations of the reactor bay occupants. It's failure to function or to shut down and isolate on an accident event has no appreciable impact on the health and safety of the public. It is not a safety system required to function to preserve a fission product barrier and its failure to function has no effect on the probability, frequency, or consequences of an accident. Its proper operation, improper operation, malfunction or failure to function as designed does not change the fundamental assumptions of the SAR accident analysis or significantly affect the outcome of the analysis for release provided in the SAR.

Negative pressure is not a SAR accident assumption and therefore an additional Technical specification to protect negative pressure is not necessary. Indeed no credible event consistent with existing Technical Specifications can result in a significant consequence to the public as provided in NUREG CR2387.

Existing and proposed Technical Specifications adequately protect the SAR assumptions.

Some of the relevant specifications include TS 3.4 which provides for confinement; TS 3.5 which requires exhaust fan operation and EES operability when the reactor is operating or when fuel is being moved; TS 3.6.1 which requires radiation monitors that secure ventilation when required; and TS 3.6.2 which requires evacuation horn operation. These specifications in conjunction with the associated surveillance requirements ensure that the RBHVES will be operated as designed. Additional indication has been provided to the operator to ensure the exhaust portion of the system is operating as expected. Improper indications will result in investigation and action to remain in compliance with Technical Specifications. Although not discussed, relied upon or credited, due to ongoing concerns with reliability of digital systems, the RBHVES digital supervisory system will take action to secure the system and alarm at a Page 18 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES remote monitoring station if the system malfunction's providing backup to the operator's indication and remedial action.

Additionally, PSU has reviewed Title 10 of the Code of FederalRegulations Section 50.36 Technical Specifications to better understand the NRC concern and the regulatory basis for the request for an additional TS requirement. Based on this review PSU maintains that a technical specification to maintain the reactor bay at a negative pressure relative to the adjacent building or the outside is neither technically nor administratively necessary to comply with the rule. The following justifications are provided:

Technical justification: The question proposes the need for a technical specification requirement to maintain negative pressure during routine operations to satisfy 10CFR50.36.

10 CFR Section 50.36(c)(2)(ii)(C) Introduction states: A technical specification limiting condition for operationof a nuclearreactormust be establishedfor each item meeting one or more of the following criteria: (C) Criterion3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accidentor transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Negative pressure in the reactor bay is a relative condition of reactor bay (or confinement) that results from operation of an exhaust fan. It is not a structure,system or component as described in the referenced Criterion 3. This condition (negative pressure during routine operations) is not part of the primarysuccess path which functions or actuates to mitigate a design basis accident and has no impact on the integrity of a fission product barrier. RBHVES has no part in a primary success path during any postulated accident. During an accident the RBHVES is expected to isolate. Existing and proposed TS 4.6 will provide for monthly verification of the system's ability to meet that function.

Therefore Criterion 3 does not describe a case where a negative pressure technical specification is needed during routine operations.

The remaining 10CFR50.36 TS criteria were reviewed and a similar conclusion was reached. A technical specification is not necessary to protect the assumptions of the SAR, ensure the facility remains within the design basis, protect the fuel or fission product boundaries or protect the health and safety of the public.

14. In the SAR Section 6.2.1, it states "[W]hen the evacuation alarm is activated, any operating RBHVES fans are shutdown, associated confinement isolation dampers shut, and the EES system starts." Describe how the signal from the evacuation alarm interfaces with the RBHVES. What type of isolation has been provided to ensure the integrity of the signal and to prevent system feedback from preventing other automatic actions that are required when the evacuation alarm sounds?

Neither the RBHVES or the DCC-X evacuation system are "safety grade" or safety related systems. However prudent engineering isolation practices were employed to prevent un-desirable interaction. The design was developed to be simple, direct and reliable.

Page 19 of 20

PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES Fused 24v Reactor auxiliary power is supplied through the spare contacts of an existing evacuation system multiplier relay to the coil of a relay (PR-20) in the RBHVES control system.

Operation of PR-20 directly interrupts power to the damper motor operators causing them to fail closed using stored power. The RBHVES supervisory system sees this loss of power and initiates shutdown of the remaining components outside the isolation boundary to prevent damage.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI Technical SDecification Changes Summary Table Refer to attached marked u Technical Specification pages

1. Page Number Technical Change Justification Specification

1. TOC i and ii Table of Contents Editorial - updated table to Necessary to reflect changes in the (TOC) (actually a reflect changes in specifications and correct missing format error in the specifications. Added missing header word file for TS 4.3) TS 4.3 Coolant System Replace TOC page I and II

2. Page 4 (of 56) 1.1.29.a Editorial - Capitalize and bold Improve readability and reduce operator existing word "OR" error in compliance

3. 1.1.29.b Editorial - replaced lead in Improve readability and reduce operator phrase error in compliance, match ANS-1 5.1

4. 1.1.29.b.1) Editorial - Capitalize and bold Improve readability and reduce operator existing word "AND" error in compliance Adjusted Margin To fit existing page

5. 1.1.29.b.2) Editorial - Capitalize and bold Improve readability and reduce operator existing word "AND" error in compliance Adjusted Margin To fit existing page

6. 1.1.29.b.3) Editorial - Capitalize and bold Improve readability and reduce operator existing word "AND" error in compliance Adjusted Margin To fit existing page

7. 1.1.29.b.4) Adjusted Margin To fit existing page

8. Page 10 (of 56) 3.1.1 .b basis Editorial - correct SAR SAR section reference was incorrect

__ _reference to Section B.

Page 1 of 5

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI Technical Specification Changes Summary Table

9. Page 23 (of 56) Deleted 3.3.3 Technical/Editorial - deleted TS 3.3.3 was redundant and specification and specification in its entirety. subordinate to TS 3.6. The basis specification duplication combined with slightly different terminology lead readers to believe there were 2 separate air monitors with different functions. The referenced monitors are the same monitor with local alarm and remote function to activate the evacuation system. The TS 3.3.3 stated function (to monitor fission products) was incorporated into TS 3.6.1 and associated basis. See also discussion in the accompanying response to question 1 of the RAI dtd

+ *4 I April 1 2014.

10.1 Page 25 (of 56) 3.4.a specification Technical - changed reactor This change will more closely align the not secured to operating confinement specification with the associated ventilation specification requirement and allow maintenance activities with key in the console but the reactor shutdown with the bay door open. This eliminates the automatic LCO violation if the reactor key is inserted with the door open. With the reactor shutdown the objective of the specification (to ensure no large air passages exist when the reactor is operating) is maintained unchanged.

See also discussion in the accompanying response to question 2 of the RAI dtd ADril 1 2014.

11. Page 26 and 26a 3.5 Title and Editorial - Changed to reflect Facility exhaust system renamed to (of 56) applicability the ventilation system name Reactor Bay Heating Ventilation and changes Exhaust.

12. 3.5 Editorial - Changed IF to Editor preference/readability whenever in 3.5.a and 3.5.b Page 2 of 5

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI Technical Specification Chancies Summary Table

13. Page 26 and 26a 3.5.a Technical - increased See the previous RAI (ML12346A349)

(of 56) Emergency Exhaust system response #4 and the question 3 of the maintenance period from 48 April 1 2014 RAI response. - Improved hours to 30 days; changed readability.

facility to reactorbay.

See the previous RAI (ML12346A349) added a one hour time clock to response #4 restore an exhaust fan to operation or shutdown Editorial - Capitalized "AND" Improve readability, error reduction

14. 3.5.b Editorial - Capitalized "AND" Improve readability and reduce operator error in compliance

15. 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 can be used to maintain ventilation and confinement.

16. 3.5.b Technical - add remedial Prevents automatic TS violation. See action if an exhaust fan goes the previous RAI (ML12346A349) inoperable during fuel or response #4 and several question experiment movement responses in the current RAI.

17. 3.5 basis Technical - updated/added a) Updated to reflect the changes in the and b) sections sDecification.

18. Page 27 (of 56) 3.6 title Editorial - update to reflect Ease of use content of specification

19. 3.6.1 title Editorial - update to reflect Ease of use content of specification

20. 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, Continuous air particulate) and incorporated TS 3.3 monitor changed to air function. See response to RAI question particulate monitor. 1. The incorporation of TS 3.3.3 into TS Incorporated the particulate 3.6.1 eliminates redundant monitor function (detect fission requirements and reduces confusion.

products).

Page 3 of 5

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI Technical Specification Changes Summary Table

21. Page 28 (of 56) 3.6.2 Technical - added remedial Prevents automatic TS violation while action if evacuation alarm is maintaining safety considerations. See inoperable and limitations on previous RAI (ML12346A349) use of the remedial action response 3 and 4 and several responses in the current RAI for further information..

22. 3.6.2 basis Technical - updated Updated to reflect the changes in the specification.

23. Page 28a (of 56) 3.6.3 Ar-41 Editorial - moved to page 28a Format and space considerations

24. Page 29 (of 56) 3.6.4 ALARA Delete in entirety Specification duplicated 10 CFR 20 requirements see previous RAI (ML12346A349) response 5

25. Page 30 (of 56) 3.7.b Editorial - replaced that with Corrected improper wording resulting than in last sentence from a previous typographical error.

26. Page 41 (of 56) 4.5 title, applicability Editorial - updated to reflect Consistency of specifications and objective change exhaust system name and function

27. 4.5.b Editorial - updated to reflect Consistency of specifications change exhaust system name and function; changed "secured" to isolated Recognize operation of system

28. 4.6 title Editorial - update to reflect Ease of use, consistency of content of specification specifications

29. 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

30. Page 42 (of 56) 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 Page 4 of 5

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI Technical Specification Changes Summary Table

31. Page 42 (of 56) 4.6.1 basis Editorial update Updated for consistency and completeness.

32. 4.6.2 entirety 4.6.2 Becomes the See amendment request and RAI evacuations alarm testing response below.

requirements Ar-41 renumbered unchanged to 4.6.3 to be consistent with section 3 of TS. specification,

33. Page 43 (of 56) 4.6.3 entirety Deleted ALARA specification See amendment request and See the previous RAI (ML12346A349).

Section 4.6.2 Ar-41 becomes Updated for consistency and section 4.6.3 to maintain completeness.

consistency of specification numbering

34. Page 46 (of 56) 5.5 title, Editorial - updated to reflect Necessary clarifications consistent with specification and system title change and system design. See the previous RAI basis correct reference to (ML12346A349).

emergency exhaust discharge height.

35. Page 47 (of 56) 6.1.1 Editorial - updated text title of Correct historic oversight.

Physical Plant vice president to match organization chart on next page

36. Page 56 (of 56) 6.7.3.a Technical - Updated radiation Reduce facility burden and exposure records retention maintenance of unnecessary personal requirements to reflect data on visitors.

10CFR20.

Page 5 of 5

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2

1.0 INTRODUCTION

1 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 Deleted 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 25 3.5 Ventilation Systems 26 3.6 Radiation Monitoring, Evacuation, and Effluents 27 3.6.1 Radiation Monitoring 27 3.6.2 Evacuation Alarm 28 3.6.3 Argon-41 Discharge Limit 28a 3.6.4 Deleted 29 3.7 Limitations of Experiments 29

-i-IZ menment 39 I

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.0 SURVEILLANCE REQUIREMENTS 32 4.1 Reactor Parameters 32 4.1.1 Reactor Power Calibration 32 4.1.2 Reactor Excess Reactivity 32 4.1.3 TRIGA Fuel Elements 33 4.2 Reactor Control and Safety System 34 4.2.1 Reactivity Worth 34 4.2.2 Reactivity Insertion Rate 34 4.2.3 Reactor Safety System 35 4.2.4 Reactor Interlocks 36 4.2.5 Overpower SCRAM 37 4.2.6 Transient Rod Test 37 4.3 Coolant System 38 4.3.1 Fire Hose Inspection 38 4.3.2 Pool Water Temperature 39 4.3.3 Pool Water Conductivity 39 4.3.4 Pool Water Level Alarm 40 4.4 Confinement 40 4.5 Ventilation Systems 41 4.6 Radiation Monitoring, Evacuation, and Effluents 41 4.6.1 Radiation Monitoring System and Evacuation Alarm 41 4.6.2 Evacuation Alarm 42 4.6.3 Argon-41 43 4.7 Experiments 43 5.0 DESIGN FEATURES 44 5.1 Reactor Fuel 44 5.2 Reactor Core 44 5.3 Control Rods 45 5.4 Fuel Storage 45 5.5 Reactor Bay Confinement and Exhaust Systems 46 5.6 Reactor Pool Water Systems 46

- ii -

Amnmnt 39 J

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

b. All of the following conditions exist:

I) The minimum number of neutron absorbing control rods are fully inserted or other safety devices are in shutdown positions, as required by technical specifications, AND

2) The console key switch is in the off position and the key is removed from the lock, 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, 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 allowed for a single experiment or one dollar whichever is smaller.

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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 B of the SAR.

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 (MHA). See Safety Analysis Report, Chapter 13.

Page 10 of 56 Amendmnt3

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 Deleted Page 23 of 56 I Aendent 39 1

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.3.6 Coolant Temperature Limits Applicability This specification applies to the pool water temperature.

Objective The objective is to maintain the pool water temperature at a level that will not cause damage to the demineralizer resins.

Specification An alarm SHALL annunciate and corrective action SHALL be taken if during operation the bulk pool water temperature reaches 140*F (60°C).

Basis This specification is primarily to preserve demineralizer resins. Information available indicates that temperature damage will be minimal up to this temperature.

3.4 Confinement Applicability This specification applies to reactor bay doors.

Obiective The objective is to ensure that no large air passages exist to the reactor bay during reactor operation.

Specifications The reactor bay truck door SHALL be closed and the reactor bay personnel doors SHALL NOT be blocked open and left unattended if either of the following conditions are true.

a. The reactor is operating, or

b. Irradiated fuel or a fueled experiment with significant fission product inventory is being moved outside containers, systems or storage areas.

Basis This specification helps to ensure that the air pressure in the reactor bay is lower than the remainder of the building and the outside air pressure. Controlled air pressure is maintained by the air exhaust system and ensures controlled release of any airborne radioactivity.

Page 25 of 56 SAmendment 39

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.5 Ventilation Systems Applicability This specification applies to the operation of the reactor bay heating ventilation and 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. Whenever the reactor is operating, at least one reactor bay exhaust fan SHALL be operating AND, except for periods of time less than 30 days during maintenance or repair, the emergency exhaust system SHALL be operable.

With no operating exhaust fans, restore an exhaust fan to operation within 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.

b. Whenever irradiated fuel or a fueled experiment with significant fission product inventory is being moved outside containers, systems or storage areas, at least one reactor bay exhaust fan SHALL be operating AND the emergency exhaust 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.

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 and exhaust system or the emergency exhaust system) will maintain this condition and provide confinement per TS 1.1.8. If all exhaust from the reactor bay is temporarily lost, the I hour time limit to restore exhaust allows operators to investigate and respond. Reactor bay area radiation and/or particulate 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 the building evacuation alarm which will automatically cause the reactor bay heating ventilation and exhaust system to shut down. The emergency exhaust system will start and the exhausted air will be passed through the emergency exhaust system filters before release. This reduces the radiation within the building. The filters will remove = 90% all of the particulate fission products that escape to the atmosphere.

Page 26 of 56 Amendment 39

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 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.

Page 26a of 56 Amendment 39

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

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

Objective 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 Nu.--moer l--Am Area Radiation Monitor Monitor radiation levels 1 in the reactor bay.

Air Particulate Monitor radioactive 1 (Radiation) Monitor particulates including fission products in the reactor bay air.

Neutron Beam Monitor radiation in the 1 Laboratory Monitor Neutron Beam Laboratory (required only when the laboratory is in use.)

Basis

a. The radiation monitors provide information to operating personnel of any impending or existing danger from radiation or airborne activity including fission products 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 the Neutron Beam Laboratory provides I information to the user and to the reactor operator when this laboratory is in use.

Page 27 of 56 AmedmetZ3

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 /> of discovery return the evacuation alarm to operation or verify that an evacuation can be initiated using the facility announcement system or other audible alarm. The use of an alternate alarm shall not exceed a period of 30 days.

Basis The evacuation alarm system produces an audible alarm throughout the PSBR building when activated. The alarm notifies all personnel within the PSBR building to evacuate the building as prescribed by the PSBR emergency procedure.

Since the probability of a valid need for a full facility evacuation is very low 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. 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 accordance with emergency procedures and allow for longer maintenance intervals if required.

Page 28 of 56

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.6.3 Argon-41 Discharge Limit Applicability This specification applies to the concentration of Argon-41 that may be discharged from the PSBR.

Objective The objective is to ensure that the health and safety of the public is not endangered by the discharge of Argon-41 from the PSBR.

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

Basis The maximum allowable concentration of Argon-41 in air in unrestricted areas as specified in Appendix B, Table 2 of 10 CFR Part 20 is 1.0 x 10s [LCi/ml.

Measurements of Argon-41 have been made in the reactor bay when the reactor operates at 1 MW. These measurements show that the concentrations averaged over a year produce less than 1.0 x 10.8 jiCi/ml in an unrestricted area (see Environmental Impact Appraisal, December 12, 1996).

Page 28a of 56 I I Aenmnt 391

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.6.4 Deleted 3.7 Limitations of Experiments Applicability These specifications apply to experiments installed in the reactor and its experimental facilities.

Objective The objective is to prevent damage to the reactor and to minimize release of radioactive materials in the event of an experiment failure.

Specifications The reactor SHALL NOT be operated unless the following conditions governing experiments exist:

a. The reactivity of a movable experiment and/or movable portions of a secured experiment plus the maximum allowed pulse reactivity SHALL be less than 2.45% Ak/k

(-$3.50). However, the reactivity of a movable experiment and/or movable portions of a secured experiment SHALL have a reactivity worth less than 1.4% Ak/k (-$2.00).

During measurements made to determine specific worth, this specification is suspended provided the reactor is operated at power levels no greater than 1 kW. When a movable experiment is used, the maximum 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).

Page 29 of 56 IZAendenZ3

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2

b. A single secured experiment SHALL be limited to a maximum of 2.45% Ak/k

(-$3.50). The sum of the reactivity worth of all experiments SHALL be less than 2.45% AkMk (-$3.50). During measurements made to determine experimental worth, this specification is suspended provided the reactor is operated at power levels no greater than I kW.

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.

e. Experiment materials, except fuel materials, which could off-gas, sublime, volatilize, or produce aerosols under (1) normal operating conditions of the experiment and reactor, (2) credible accident conditions in the reactor, or (3) possible accident conditions in the experiment, SHALL be limited in activity such that the airborne concentration of radioactivity averaged over a year SHALL NOT exceed the limit of Appendix B Table 2 of 10 CFR Part 20.

When calculating activity limits, the following assumptions SHALL be used:

1) If an experiment fails and releases radioactive gases or aerosols to the reactor bay or atmosphere, 100% of the gases or aerosols escape.

2) If the effluent from an experimental facility exhausts through a holdup tank which closes automatically on high radiation level, at least 10% of the gaseous activity or aerosols produced will escape.

3) If the effluent from an experimental facility exhausts through a filter installation designed for greater than 99% efficiency for 0.3 micron particles, at least 10% of these vapors can escape.

4) For materials whose boiling point is above 130 0F and where vapors formed by boiling this material can escape only through an undisturbed column of water above the core, at least 10% of these vapors can escape.

Page 30 of 56 1 Amendment 39

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.5 Ventilation Systems Applicability These specifications apply to the reactor bay heating ventilation and exhaust system and emergency exhaust system.

Objective The objective is to ensure the proper operation of the reactor bay heating ventilation and exhaust system and emergency exhaust system in controlling releases of radioactive material to the uncontrolled environment.

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 and exhaust system is isolated when the emergency exhaust system activates during an evacuation alarm (See TS 3.6.2 and TS 5.5).

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.

4.6 Radiation Monitoring, Evacuation, and Effluents 4.6.1 Radiation Monitoring System and Evacuation Alarm Applicability This specification applies to surveillance requirements for the area radiation monitor, the Neutron Beam Laboratory radiation monitor, the air particulate radiation monitor, and the evacuation alarm.

Objective The objective is to ensure that the radiation monitors and evacuation alarm are operable and to verify the appropriate alarm settings.

Page 41 of 56 Amendment 39

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 Specification The area radiation monitor, the Neutron Beam Laboratory radiation monitor and the air particulate (radiation) monitor SHALL be:

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;

b. Channel tested monthly not to exceed 6 weeks, whenever operations are scheduled;

c. Calibrated annually, not to exceed 15 months, whenever operations are scheduled.

Basis 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 characteristics. An 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 Applicability This specification applies to the emergency evacuation alarm.

Obiective The objective is to ensure that the emergency alarm is audible when actuated automatically or via a manual switch.

Specification The evacuation alarm SHALL be verified audible annually not to exceed 15 months.

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.

P 4Amendment 39 Page 42 of 56

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 4.6.3 Argon-41 Applicability This specification applies to surveillance of the Argon-41 produced during reactor operation.

Obiective To ensure that the production of Argon-41 does not exceed the limits specified by 10 CFR Part 20.

Specification The production of Argon-41 SHALL be measured and/or calculated for each new experiment or experimental facility that is estimated to produce a dose greater than I mrem at the exclusion boundary.

Basis One (1) mrem dose per experiment or experimental facility represents 1% of the maximum 10 CFR Part 20 annual dose. It is considered prudent to analyze the Argon-41 production for any experiment or experimental facility that exceeds 1%

of the annual limit.

4.7 Experiments Applicability This specification applies to surveillance requirements for experiments.

Objective The objective is to ensure that the conditions and restrictions of TS 3.7 are met.

Specification Those conditions and restrictions listed in TS 3.7 SHALL be considered by the PSBR authorized reviewer before signing the irradiation authorization for each experiment.

Basis Authorized reviewers are appointed by the facility director.

Page 43 of 56 I Amendment 39

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 5.5 Reactor Bay Confinement and Exhaust Systems 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 in 3 .

b. The reactor bay SHALL be equipped with two exhaust systems. Under normal operating conditions, the reactor bay heating ventilation and exhaust system exhausts unfiltered reactor bay air to the environment releasing it at a height at least 34 feet (10.5 m) above the reactor bay floor. Upon initiation of a building evacuation alarm, the previously mentioned system is automatically isolated and an emergency exhaust system automatically starts. The emergency exhaust system is also designed to discharge reactor bay air at a height at least 34 feet (10.5 m) above the reactor bay floor.

Basis The value of 1900 m3 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. Although analyzed as a ground release, the height above the reactor bay floor level of the release helps to ensure adequate mixing prior to 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.

Page 46 of 56 Amendment 39

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 for Office of 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.

Page 47 of 56 Amendment 39

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 exposure for all personnel monitored in accordance with 10 CFR 20.2106.

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.

Page 56 of 56 Amdm ent 39