ML16238A196

Penn State University - Response to Request for Additional Information Regarding 02/07/2012 License Amendment Request for Breazeale Reactor

ML16238A196
Person / Time
Site:	Pennsylvania State University
Issue date:	08/23/2016
From:	Sharkey N Pennsylvania State Univ
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML16238A196 (29)

Text

Penn State eil A. Sharkey Vice President for Research 814-865-6332 Fax: 814-863-9659 The Pennsylvania State University nas9@psu.edu 304 Old Main www.psu.edu/research University Park, PA 16802-1504 August 23, 2016 USN RC Document Control Desk Docket 50-005 Response to NRC 7-27-2016 (ML16188A393) 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 2/7 /12 license amendment request (LAR) for the Penn State Breazeale Reactor R-2 license.

Also attached is revised Tech Spec (TS) wording that reflects the results of the ongoing review process. In addition to the previously reviewed changes, pages 47 text and 48 Organization chart were modified to reflect a change to the title of the level 1 management position, the individual remains same. The attached TS pages supersede the previous detailed TS submittal pages in their entirety.

Please exempt this request from fees per 10CFR170.11.l. (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.

COMMONWEALTH OF PENNSYLVANIA Notarial seal Lorri L. Somsky, Notary Public State College Boro, Centre County My Commission Expires Nov. 15, 2016 Attachments:

RAI (ML16188A393) response Technical Specification Change Summary Tab Updated Technical Specifications Pages State of:

County of:

CC - email Alexander Adams - NRC Xiaosong Yin - NRC Ossy Font - NRC R-2 NRC Correspondence File

PSU RBHVES LAR RAI # 3 dtd 7/27 /16 RESPONSES

1. Provide a quantitative calculation to support the conservative assumption you made and demonstrate that both the ground release and elevated dilution release are fully assessed and the radiological consequences from both of these releases meet the regulatory requirements. In addition, the calculation would confirm that TS 3. 7 e. (3) requirement would not be compromised.

The PSU SAR MHA is not purported to be an aerial or elevated release calculation , it is a ground release calculation. The Breazeale Reactor has no stack that meets the criteria of RegGuide 1.145 R1. While the normal and "emergency" release path is out through roof level openings, no credit was taken in the analysis for elevation or dispersion with distance. This limiting calculation has an accepted assumption of an initial dilution in the very low (stable class) wind velocity of 1 meter/sec and the cross sectional area of the building. This initial dilution assumption results in a constant x IQ value of 1/200 sec/M 3 . This value is within the range of values resulting from similar ground based calculations given at the limits of methodology in the RegGuide. The methodology used for the PSU SAR MHA was accepted as a license basis calculation as recently as the 2009 license renewal reviews.

As asserted in previous responses, the reduced flow rates with no operating exhaust fan will result in lower unrestricted area dose because more fission products have time to decay in the reactor building prior to release. A realistic building leak rate is not known and that rate will vary with external wind forces on the building. High wind results in more leakage, but also more dilution. Low wind would result in little dynamic load, less leakage and less dilution. The PSU SAR reports an unrestricted area 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> dose of 26 mR. Using the same licensing basis calculation methodology and reducing the leakage rate (exhaust flow) , the dose will be:

50% exhaust flow rate; 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Dose Unrestricted Area would be 24 mR 10% exhaust flow rate; 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Dose Unrestricted Area would be 22 mR Note that in all three cases the over 90% of the activity is removed from the confinement in 1 to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> into the event.

2. Provide technical justifications that by renaming TS 3.5, the effectiveness of reactor bay exhaust systems serving as engineered safety features is not reduced and/or changed.

The change as proposed is purely editorial, and the title only serves the purpose of a pointer in the table of contents to link to the ventilation systems. The change in the title of the specification was done to simplify the pointer and conform with the guidance of ANS/ANSI 15.1 The Development of Technical Specifications for Research Reactors which does not list Engineered Safety Features as a LCO title . The title change does not change the functions as specified in the SAR or the basis of the specification; therefore the importance of and functions of the system are not diminished .

Page 1of2

PSU RBHVES LAR RAI # 3 dtd 7/27 /16 RESPONSES

3. a) and b) Provide revised Technical Specification 3.5 wording to ensure the meaning is clear.

See attached revised Technical specification wording . Note that entire Technical Specification revision is included in this submission to ensure that no editorial compilation errors will be made.

The revision also includes the addition of a title Change to the Level 1 license holder which was recently made permanent by the University. The Individual filling the position remains the same.

4. Provide revised Technical Specification 3.6.2 wording to ensure the meaning is clear.

See attached revised Technical specification wording.

Page 2 of 2

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 Amendment 39

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. I 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 Amendment 39

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:

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

Page 4 of 56 Amendment 39

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.

Objective 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.

a. Thermal and hydraulic calculations and operational experience indicate that a compact TRI GA 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 Amendment 39

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.

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 Amendment 3 9

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).

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 .

Objective 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.

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 Amendment 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. The reactor SHALL NOT be operated unless at least one reactor bay exhaust fan is operating.

Upon discovery of no operating exhaust fans, within one hour restore a reactor bay exhaust fan to operation or shutdown the reactor.

b. Except for periods of time less than 30 days during maintenance or repair, the emergency exhaust system SHALL be operable.

c. If 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.

Upon discovery of no operating exhaust fans OR discovery of an inoperable emergency exhaust system, complete the movement in progress then cease all further movements until compliance with 3.5.c is restored.

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 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit to restore exhaust allows operators to investigate and respond. Reactor bay area radiation and/or particulate radiation monitors will continue to assure an unrecognized hazardous condition does not develop.

Amendment 3 9 Page 26 of 56

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2

b. 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. 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.

c. During irradiated fuel or fueled experiment movement, the likelihood of event releasing fission products to the bay is increased. Therefore continuous operation of a reactor bay exhaust fan 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 a safe storage condition. This is necessary and remains within the requirement of the limiting condition for operation remedial action. No additional movements may be conducted until the limiting condition for operation is satisfied.

Amendment 39 Page 26a of 56

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.6 Radiation Monitoring, Evacuation, and Effluents 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 Number 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 ism use.

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 information to the user and to the reactor operator when this laboratory is in use.

Page 27 of 56 Amendment 39

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 An 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.

Exception: Upon discovery of a failure of the evacuation alarm system or to allow for maintenance during operations an alternative evacuation alarm may be substituted for the normal system. The alternate evacuation alarm system shall be established within one (1) hour of discovery of inoperability or prior to entry into maintenance. Use of an alternate evacuation alarm system shall not exceed a period of 30 days.

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 PSBR building has local radiation alarms, it is reasonable that the building wide 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 ifrequired. Use of an alternative alarm for extended periods is inconsistent with the design and intent of the system and the SAR and the system is to be restored to normal operations expeditiously, not to exceed thirty days.

Amendment 39 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.

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 1o*8 µCi/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 µCi /ml in an unrestricted area (see Environmental Impact Appraisal, December 12, 1996).

Page 28a of 56 Amendment 39

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% ~k/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% ~k/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% Wk (~$3.50) to ensure that the sum is less 2.45%

~k/k (~$3.50) .

Page 29 of 56 Amendment 39

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% ~k/k

(~$3.50). The sum of the reactivity worth of all experiments SHALL be less than 2.45% ~ (~$3.50). During measurements made to determine experimental worth, this specification is suspended provided the reactor is operated at power levels no greater than 1 kW.

c. When the keff of the core is less than 1 (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°F 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 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).

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.

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.

Objective 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.

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.

Amendment 39 Page 42of56

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.

Objective 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 1 mrem at the exclusion boundary.

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.

Authorized reviewers are appointed by the facility director.

Page 43 of 56 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 m3 .

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.

Thermal and hydraulic calculations and operational experience indicate that a compact TRI GA 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 (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 47of56 Amendment 3 9

TECHNICAL SPECIFICATIONS : PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 ORGANIZATION CHART Senior Vice President for Finance Vice President for Research and Business/Treasurer (Level 1)

I Vice President for Dean, College Physical Plant of Engineering Director of Environmental Health and Safety Manager of Radiation Protection Penn State Reactor Safeguards Committee I

I I

I I

I I

I I

Director ,_ __II I

~---------------- Penn State Breazeale Reactor (Level 2)

Associate Director for Operations (Level 2)

Operating Staff Senior Reactor Operators (Level 3)

Reactor Operators (Level 4)

Page 48 of 56 Amendment 3 9

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.

L 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 Amendment 39

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI Ml16188A393 Technical Specification Changes Summary Table

. I S pec1"fi1cafion pages k d up T ec h nica R e f er to attac he d mare

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-15.1

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.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI ML16188A393 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 April 1 2014.

10. 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 April 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.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI ML16188A393 Technical Specification Changes Summary Table

12. 3.5~ Editorial - Split specification Editor preference/readability into 3.5.a and 3.5.b to separate normal exhaust from emergency exhaust Changed IF to whenever in 3.5.a and 3.5.b Ensure consistent application Editorial - changed "if the reactor is operating" to "the reactor shall not be operated unless" Recognize new system name and that Editorial/Technical changed any one of the four exhaust fans meets facility exhaust to reactor bay the requirement exhaust See the previous RAI (ML12346A349)

Technical added a one hour response #4 time clock to restore an exhaust fan to operation or shutdown

13. Page 26 and 26a 3.5.Q.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 reactor bay."

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

15. 3.5.fa 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 .fa 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 Ql and fa) sections specification .

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI ML16188A393 Technical Specification Changes Summary Table

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).

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 #2 (ML14259A336) 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 4 1 (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 Page 4 of 6

PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI ML16188A393 Technical Specification Changes Summary Table

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 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.

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PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAI ML16188A393 Technical Specification Changes Summary Table

35. Page 47 (of 56) 6.1.1 Editorial - updated text title of Recent 12ermanent title change, Vice President for Research individual filling position has not (level 1) changed .

Editorial - updated text title of Correct historic oversight.

Physical Plant vice president to match organization chart on next page 36 . Paae 48 (of 56) Ora Chart Revised Title of Level 1 As stated above

~- 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.

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