ML17244A232
| ML17244A232 | |
| Person / Time | |
|---|---|
| Site: | Ohio State University |
| Issue date: | 08/22/2017 |
| From: | Cao L Ohio State University |
| To: | Xiaosong Yin Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML17244A232 (3) | |
Text
U.S. Nuclear Regulatory Commission Document Control Desk Attn: Xiaosong Yin One White Flint North 11555 Rockville Pike Rockville MD 20852-2738 22-August-2017
Subject:
Request for an amendment to The Ohio State University Research Reactor (OSURR, License R-75 Docket 50-150) Technical Specifications (TSs)
OSURR Technical Specification (TS) 3.5, Ventilation Systems, is written as follows:
Applicability: This specification applies to all heating, ventilating, and air conditioning systems that exhaust building air to the outside environment.
Objective: To provide for normal ventilation and the reduction of airborne radioactivity within the reactor building during normal reactor operation and to provide a way to turn off all vent systems quickly in order to isolate the building for emergencies.
Specification:
(1)
An exhaust fan with a capacity of at least 1000 cubic feet per minute shall be operable whenever the reactor is operating.
(2)
This fan, as well as all other heating, ventilating, and air conditioning systems, shall have the capability to be shut off from a single switch in the control room.
Bases: In the unlikely event of a release of fission products or other airborne radioactivity, the ventilation system will reduce radioactivity inside the reactor building or be able to be isolated.
Section 8.4.4 of the SAR includes an analysis of fission product release.
The corresponding surveillance requirements in Section 4.5 of the Technical Specifications are written:
Applicability: This specification applies to the surveillance requirements for the building ventilation system.
Objective: To ensure that the ventilation shutoff functions satisfactorily.
Specification: The shutoff switch for all fans and air conditioning systems shall be tested on a quarterly basis.
Bases: This surveillance will ensure that the building can be isolated quickly if necessary to prevent uncontrolled escape of airborne radioactivity to the unrestricted environment.
During the most recent NRC inspection at the OSURR, it was noted that while there was a mention of "a capacity of at least 1000 cubic feet per minute" in TS 3.5, there was no corresponding surveillance requirement to measure this flow rate. This request has been written to address that inconsistency by revising TS 3.5 such that the words "with a capacity of at least 1000 cubic feet per minute" have been removed. In addition, another related minor change is requested.
1
The mention of a particular flow rate in TS 3.5 is an historical relic that was carried forward when the OSURR was relicensed in 2008, and the inconsistency that this caused was missed by b.oth NRL staff and NRC staff during that renewal process. Although the building exhaust fan is operated at any time the reactor is in operation as an ALARA function and to meet the requirement for confinement in TS 3.4, if there were to be a release of radioactive material in an accident, the fan would be turned off to isolate the building to minimize release to the environment and exposure of the public. Thus, the safety function is associated with the switch that shuts off the fan. Therefore, it is not appropriate to have a fan flow rate capacity stated in this TS. Rather, it should be made clear in TS 3.5 that the building exhaust fan and other exhaust fans are capable of being shut off in the event of an emergency. This proposed change is consistent with ANSl/ANS-15.1, which is the guidance document for technical specifications for research reactors. Section 3.5 of ANSI/ ANS-15.1 makes no mention of specifying an exhaust fan flow rate capability. Rather, it states that TS 3.5 should specify necessary ventilation system equipment for normal and emergency operations.
Given this, we request an amendment to the OSURR Technical Specifications in which the phrase "with a capacity of at least 1000 cubic feet per minute" has been removed from Section 3.5. In addition, some other minor changes have been made for clarity. We propose the resulting Section 3.5 to read as follows:
Applicability: This specification applies to all heating, ventilating, and air conditioning systems that exhaust from the restricted area to the outside environment.
Objective: To provide a means to quickly turn off all heating, ventilating, and air conditioning systems that exhaust from the restricted area in order to isolate the building for emergencies.
Specification: Any fan exhausting from the restricted area while the reactor is operating shall have the capability to be shut off from a single switch in the control room.
Bases: In the unlikely event of a release of fission products or other airborne radioactivity, a means must be provided for shutting off ventilation fans and rapidly isolating the building. Section 8.4.4 of the SAR includes an analysis of fission product release.
Note that the minimum equipment for normal operations is not specified in TS 3.5 because the only ventilation equipment necessary for normal operations is the building exhaust fan to provide confinement. This is already specified in TS 3.4, so it is unnecessary to repeat in TS 3.5.
The related minor change we are requesting is to update TS 5.1.2 to make it consistent with the Emergency Plan. A few years ago, a lobby was built in front of the Reactor Building. It is connected to the Reactor Building, but it is an independent structure, and it is not part of the restricted area. This has been made clear in the Emergency Plan, and TS 5.1.2 should be revised to match. Therefore we request to change TS 5.1.2 from:
The fence surrounding the reactor building shall describe the controlled area. The restricted area, as defined in 10 CFR Part 20, shall consist of the reactor building.
to read as:
The fence surrounding the reactor building shall describe the controlled area. The restricted area, as defined in 10 CFR Part 20, shall consist of the reactor building, which does not include the lobby addition.
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If you have any questions on this matter, please contact Mr. Andrew Kauffman at Kauffman.9@osu.edu or at 614-688-8220.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 22-August-2017.
Sincerely, e/J-;~~
Dr. Lei Raymond Cao Director, OSU Nuclear Reactor Laboratory 1298 Kinnear Rd Columbus, OH 43212 3