ML19308B421

The Ohio State University - Issuance of Amendment No. 19 to Renewed Facility Operating License No. R-75 for the Ohio State University Research Reactor

ML19308B421
Person / Time
Site:	Ohio State University
Issue date:	03/30/2020
From:	Xiaosong Yin NRC/NRR/DANU/UNPL
To:	Cao L Ohio State University
Yin X,NRR/DANU/UNPL, 415-1404
References
EPID L-2018-LLA-0231
Download: ML19308B421 (20)

Text

March 30, 2020 Dr. Lei Raymond Cao, Director Nuclear Reactor Laboratory Ohio State University 1298 Kinnear Rd Columbus, OH 43212

SUBJECT:

THE OHIO STATE UNIVERSITY - ISSUANCE OF AMENDMENT NO. 19 TO RENEWED FACILITY OPERATING LICENSE NO. R-75 FOR THE OHIO STATE UNIVERSITY RESEARCH REACTOR (EPID L-2018-LLA-0231)

Dear Dr. Cao:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 19 to Renewed Facility Operating License No. R-75 for the Ohio State University (OSU) Research Reactor (OSURR). The amendment consists of changes to the facility operating license and technical specifications (TSs) in response to OSU application dated August 27, 2018, as supplemented by letters dated October 16, 2018, November 14, 2018, April 10, 2019, September 6, 2019, October 22, 2019, and November 6, 2019. The amendment modifies the OSURR TSs by removing the specific facility ventilation flow rate.

A copy of the NRC staffs safety evaluation is enclosed. If you have any questions, please contact me at (301) 415-1404, or by electronic mail at Xiaosong.Yin@nrc.gov.

Sincerely,

/RA/

Xiaosong Yin, Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-150 License No. R-75

Enclosures:

1. Amendment No. 19 to Renewed Facility Operating License No. R-75

2. Safety Evaluation cc: w/enclosures: See next page

The Ohio State University Docket No. 50-150 cc:

Chief Ohio Department of Health Bureau of Environmental Health and Radiation Protection 246 North High Street Columbus, OH 43215 Radiological Branch Chief Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235 2206 Andrew Kauffman, Associate Director Nuclear Reactor Laboratory Ohio State University 1298 Kinnear Road Columbus, OH 43212 David B. Williams, Dean College of Engineering Ohio State University 142A Hitchcock Hall 2070 Neil Ave.

Columbus, OH 43210-1278 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

ML19308B421

• concurrence via e-mail NRR-058 OFFICE NRR/DANU/PM*

NRR/DANU/LA*

OGC*

NRR/DANU/BC*

NRR/DANU/PM*

NAME XYin NParker MYoung/NLO GCasto XYin DATE 11/8/2019 11/8/2019 3/25/2020 3/30/20 3/30/2020

THE OHIO STATE UNIVERSITY DOCKET NO. 50-150 THE OHIO STATE UNIVERSITY RESEARCH REACTOR AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 19 License No. R-75

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for an amendment to Renewed Facility Operating License No. R-75, filed by the Ohio State University (the licensee) on August 27, 2018, as supplemented by letters dated October 16, 2018, November 14, 2018, April 10, 2019, September 6, 2019, October 22, 2019, and November 6, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance that the activities authorized by this amendment can be conducted (i) without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations set Forth in 10 CFR Chapter I; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, of the Commissions regulations and all applicable requirements have been satisfied.

F.

Prior notice of this amendment was not required by 10 CFR 2.105, Notice of proposed action, and publication of a notice for this amendment is not required by 10 CFR 2.106, Notice of issuance.

2.

Accordingly, the license is amended by changes to the technical specifications as indicated in Attachment 2 to this license amendment, and paragraph 2.C.2 of Renewed Facility Operating License No. R-75 is hereby amended to read as follows:

The technical specifications contained in Appendix A, as revised by Amendment No. 19, are hereby incorporated in the license. The licensee shall operate the reactor in accordance with the technical specifications.

3.

This license amendment is effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Greg Casto, Chief Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Attachments:

1. Changes to Renewed Facility Operating License No. R-75

2. Changes to Appendix A, Technical Specifications Date of Issuance: March 30, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 19 RENEWED FACILITY OPERATING LICENSE NO. R-75 DOCKET NO. 50-150 Replace the existing page of the Renewed Facility Operating License No. R-75 with the following revised page. The revised page is identified by amendment number and contains lines in the margin indicating the areas of change.

Renewed Facility Operating License No. R-76 REMOVE INSERT 2

2 Amendment No. 19 March 30, 2020

1.

Pursuant to subsection 104c of the Act, and Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, of the Code of Federal Regulations (10 CFR Part 50), to possess, use, and operate the reactor as a utilization facility at the designated location in Columbus, Ohio.

2.

Pursuant to the Act and 10 CFR Part 70, Domestic Licensing of Special Nuclear Material, to receive, possess, and use in connection with operation of the facility:

a.

up to 5.2 kilograms of contained uranium-235 at enrichments less than 20 percent;

b.

up to 30 grams of highly enriched, contained uranium-235 in the form of fission chamber linings, foil targets, and other research applications;

c.

up to 80 grams of plutonium contained in encapsulated plutonium-beryllium sources; and

d.

to possess and use, but not to separate such special nuclear material as may be produced by operation of the reactor.

3.

Pursuant to the Act and 10 CFR Part 30, Rules of General Applicability to Domestic Licensing of Byproduct Material, to possess and use, but not to separate, except for byproduct material produced in non-fueled experiments, such byproduct material as may be produced by operation of the reactor.

C.

This license shall be deemed to contain and is subject to the conditions specified in Parts 20, 30, 50, 51, 55, 70, and 73 of the Commissions regulations; is subject to all applicable provisions of the Act and rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

1. The licensee is authorized to operate the reactor at steady-state power levels up to a maximum of 500 kilowatts (thermal).

2. The technical specifications contained in Appendix A, as revised through Amendment No. 19, are hereby incorporated in the license. The licensee shall operate the reactor in accordance with the technical specifications.

D.

This license is effective as of the date of issuance and shall expire at midnight twenty years from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Eric J. Leeds, Director Office of Nuclear Reactor Regulation

Enclosure:

Appendix A, Technical Specifications Date of Issuance: June 18, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 19 RENEWED FACILITY OPERATING LICENSE NO. R-75 DOCKET NO. 50-150 Replace the existing pages of the Appendix A, Technical Specifications, with the following revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Technical Specifications REMOVE INSERT 15 15 15a

OSURR License No. R-75 15 Amendment No. 19 March 30, 2020 3.5 Ventilation Systems 3.5.1 Normal Operations Applicability: This specification applies to ventilation equipment required for normal operations, which is only the exhaust fan.

Objective: To specify needed ventilation equipment for normal operations.

Specification: The exhaust fan shall be operating when the reactor is operating.

Bases: An operating exhaust fan is necessary to meet the requirements for confinement, as specified in Section 3.4.

3.5.2 Emergency Operations Applicability: This specification applies to ventilation equipment related to emergency operations, which includes all heating, ventilating, and air conditioning systems that exhaust from the restricted area to the outside environment.

Objective: To specify 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 heating, ventilating, and air conditioning systems that exhaust from the restricted area to the outside environment shall have the capability to be shut off from a single switch in the control room.

Bases: In the unlikely event of an emergency situation involving the release of fission products or other airborne radioactivity, a means must be available for shutting off ventilation fans and rapidly isolating the building. Section 8.4.4 of the SAR includes an analysis of fission product release.

3.6 Radiation Monitoring Systems and Radioactive Effluents 3.6.1 Radiation Monitoring Applicability: This specification applies to the availability of radiation monitoring equipment that shall be operable during reactor operation.

Objective: To ensure that monitoring equipment is available to evaluate radiation levels in restricted and unrestricted areas and to be consistent with the ALARA principle.

OSURR License No. R-75 15a Amendment No. 19 March 30, 2020 Specification:

(1)

When the reactor is operating, the building gaseous effluent monitor shall be operating and have a readout and alarm in the control room. It may be used in either the normal mode or sniffer mode.

(2)

When the reactor is operating, the following area radiation monitors (ARMs) shall be operating and have both local and control room readouts and alarms.

a. pool top

b. primary cooling system

c. beam port/rabbit area

d. thermal column area (3)

Portable survey instrumentation shall be available whenever the reactor is operating to measure beta-gamma exposure rates and neutron dose rates.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 19 TO RENEWED FACILITY OPERATING LICENSE NO. R-75 THE OHIO STATE UNIVERSITY THE OHIO STATE UNIVERSITY RESEARCH REACTOR DOCKET NO. 50-150

1.0 INTRODUCTION

By letters dated August 27, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18242A075), as supplemented by letters dated October 16, 2018 (ADAMS Accession No. ML18291A913), November 14, 2018, (ADAMS Accession No. ML18324A585), April 10, 2019 (ADAMS Accession No. ML19105A137), September 6, 2019 (ADAMS Accession No. ML19253A051), October 22, 2019 (ADAMS Accession No. ML19298A110), and November 6, 2019 (ADAMS Accession No. ML19317D799), the Ohio State University (OSU) submitted a license amendment request (LAR or application) for the OSU Research Reactor (OSURR) and requested that the U.S. Nuclear Regulatory Commission (NRC) issue a license amendment to the Renewed Facility Operating License No. R-75 for the OSURR. The proposed license amendment would modify the OSURR technical specifications (TSs) to remove the specific reference to the ventilation fan flow rate in TS 3.5.1 and clarify existing emergency actions in 3.5.2.

The initial proposed LAR, by letter dated August 27, 2018, included a revision to TS 5.1.2, Controlled and Restricted Area. On October 22, 2019, the licensee withdrew this request.

2.0 REGULATORY EVALUATION

2.1 Background

During an NRC inspection (August 2016, Inspection No. 50-150/2016-201, ADAMS Accession No. ML16273A008) at the OSURR, it was identified in TS 3.5 that an exhaust fan with capacity of at least 1,000 cubic feet per minute (cfm) shall be operable when the reactor is operating, but there was no corresponding surveillance requirement to measure the flow rate. In its August 27, 2018, amendment application, the licensee stated that specific exhaust fan flow value was an historical relic that was carried forward when the OSURR was relicensed in 2008, and provided information to support its position that specifying a minimum flow rate capacity is not necessary and should be removed.

2.2 Regulatory Requirements The NRC staff reviewed the licensees amendment request, as supplemented, to ensure that there is reasonable assurance that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and that such activities will be conducted in compliance with the Commissions regulations, and that the issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public. The NRC staff considered the following regulatory requirements and guidance during its review of the proposed changes:

Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection against Radiation, which establishes standards for protection against ionizing radiation resulting from activities conducted under licenses issued by the NRC. 10 CFR Part 20 requires that licensees implement procedures and controls to achieve occupational doses and public doses that are as low as is reasonably achievable (ALARA). The limits on occupational dose limits for adults and dose limits for individual members of public in 10 CFR 20.1201 and 10 CFR 20.1301, respectively.

10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, which provides regulatory requirements for licensing of non-power reactors.

10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, which provides regulatory requirements for the protection of the environment.

The Atomic Energy Act of 1954, as amended, Section 182a, requires that each utilization facility operating license include TSs. The regulatory requirements related to the content of the TSs for nuclear reactors are in 10 CFR 50.36, Technical specifications, which requires that TSs include items in the following categories:

(1) safety limits and limiting safety system settings, (2) limiting conditions for operation, (3) surveillance requirements, (4) design features, and (5) administrative controls.

NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content, February 1996 (ADAMS Accession No. ML042430055), provides guidance on the format and content of non-power reactor licensing applications submitted to the NRC. NUREG-1537, Part 1, Appendix 14.1, Format and Content of Technical Specifications for Non-Power Reactors, provides guidance on the format and content of non-power reactor TSs and references American Nuclear Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors.

NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, February 1996 (ADAMS Accession No. ML042430048), provides guidance for the NRC staff to use in conducting reviews of non-power reactor license applications and provides guidance for the review acceptability of proposed TSs.

3.0 TECHNICAL EVALUATION

3.1 The current TS 3.5, Ventilation Systems states:

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 capacity to be shut off from a single switch in the control room.

The proposed TS 3.5 would specify requirements for Normal and Emergency Operations in new TSs 3.5.1 and 3.5.2, respectively, as follows:

3.5 Ventilation Systems 3.5.1 Normal Operations Applicability: This specification applies to ventilation equipment required for normal operations, which is only the exhaust fan.

Objective: To specify needed ventilation equipment for normal operations.

Specification: The exhaust fan shall be operating when the reactor is operating.

Bases: An operating exhaust fan is necessary to meet the requirements for confinement, as specified in Section 3.4.

3.5.2 Emergency Operations Applicability: This specification applies to ventilation equipment related to emergency operations, which includes all heating, ventilating, and air conditioning systems that exhaust from the restricted area to the outside environment.

Objective: To specify 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 heating, ventilating, and air conditioning systems that exhaust from the restricted area to the outside environment shall have the capacity to be shut off from a single switch in the control room.

Bases: In the unlikely event of an emergency situation involving the release of fission products or other airborne radioactivity, a means must be available for shutting off ventilation fans and rapidly isolating the building. Section 8.4.4 of the SAR includes an analysis of fission product release.

Proposed TS 3.5.1 would remove the specific exhaust fan flow rate by deleting the words with a capacity of at least 1000 cubic feet per minute and require that the exhaust fan be operating (instead of operable) when the reactor is operating. Also, the TS 3.5.1 applicability and objective would be modified to specify that exhaust fan is the only heating, ventilating, and air conditioning (HVAC) system limited for the normal operation. The new TS 3.5.2 would clarify that existing emergency actions implied by the current TS 3.5(2) apply to all HVAC systems and restate and modify the applicability and objective currently in the TS 3.5 to specify that the systems that exhaust from the restricted area in lieu of the building or reactor building.

3.2 Proposed Action to TS 3.5.1, Normal Operations In its LAR, the licensee indicated that the specified exhaust fan flow rate of 1,000 cfm was historically carried over from licensees prior TSs conditions but had never been verified or monitored as for its accuracy. In its August 27, 2018, letter, the licensee provided six (6) items to justify that exhaust fan minimum flow rate capacity was not necessary, and should be removed, as follows:

1) The Basis for TS 3.5 does not indicate a need for specifying an exhaust fan flow rate capability. It only states that the ventilation system will reduce radioactivity inside the reactor building or be able to be isolated. No particular flow rate is needed to achieve this;

2) The surveillance requirements in TS 4.5 do not specify measuring a flow rate. Other Section 3 TSs have corresponding surveillances;

3) The exhaust fan helps to provide confinement as defined in TS 3.4 as a closure on the overall facility which controls the movement of air into it and out of it through a controlled path and does not indicate a need to specify an exhaust fan flow rate capacity;

4) ANSI/ANS 15.1 does not mention specification of exhaust fan flow rate capability and states that TS 3.5 should specify necessary ventilation system equipment for normal and emergency operations;

5) The building exhaust fan is operated for normal reactor operations in order to meet the requirement for confinement in TS 3.4 by maintaining a controlled path of release.

During normal operations, low activities of Ar-41 produced by the reactor are released to the outside by the exhaust fan. The OSU annual report estimated that the annual dose to a member of the public were a fraction of a millirem. If the exhaust fan was exhausting air at either a smaller or greater volumetric flow rate than 1000 cfm, no limits for members of the public would be exceeded, and therefore public safety would not be impacted for normal operations;

6) In an emergency situation, the exhaust fan would be turned off to isolate the building in order to minimize the release of radioactive material to the environment and the exposure of the public. The fan volumetric flow rate is unrelated to public dose in an emergency situation.

The NRC staff requested additional information (RAI) by letter, dated October 3, 2018 (ADAMS Accession No. ML18270A166), to provide technical justifications for the proposed change to remove the reference of the exhaust fan flow rate in the TS 3.5. By letters dated October 16, 2018, and November 14, 2018, the licensee provided calculational comparisons to demonstrate that scenarios with lesser and greater fan flow (than the current TS 3.5 value of 1,000 cfm) could not result in radioactive material effluent concentrations greater than licensed limits in TS 3.6.2.

The NRC staff requested additional information by letter, dated January 16, 2019 (ADAMS Accession No. ML18360A359) regarding how the licensee accounted for decay of Argon-41 (Ar-41) in its radioactive effluent calculations previously provided by letter dated November 14, 2018. By letters, dated April 10, 2019, and September 6, 2019, the licensee described half-life related losses, per safety analyses report (SAR) Section 6.3.4.2. Additionally, the licensee described using indications from radiation measurement instrumentation to monitor and alert operators of Ar-41 buildup resulting from reduced flow and compared the doses calculated to the annual regulatory dose limits of 5 rem in 10 CFR 20.1201 (occupational), and 0.1 rem in 10 CFR 20.1301 (public) and Table 2 of 10 CFR Part 20, to demonstrate sufficient margin to regulations would be maintained. Further, the licensee described the physical difficulty in performing direct measurement of exhaust fan flow due to the location of the fan. TS 3.4, confinement, requires the reactor fan be operating during the reactor operation to prevent exposure of the public from airborne radioactivity exceeding the limit of 10 CFR Part 20 and the ALARA principle. The primary gaseous effluent release point is from the building ventilation fan located at the top of the north wall of the building and is about 30 feet above floor (ground) level.

The licensee provided a range of 500 cfm to 1,500 cfm of exhaust fan flow rate calculation to support its conclusion that no radioactive effluent release limits will be exceeded during normal operations.

In its September 6, 2019, letter, the licensee provided a fan rate calculation based on the fans cross section, rotational speed, and its effective pitch, and showed a fan volumetric flow rate of 1,217 cfm.

When the licensee performed its safety analyses estimation on the impact of this exhaust fan flow rate it used a range of 500 - 1,500 cfm for fan flow rate in its calculations. The licensee concluded that a fan flow rate of 500, 1,000, or 1,500 cfm has no safety impact because effluent releases would continue to remain below licensed limits in TS 3.6.2, which requires that annual occupational and public doses that meet the requirements in 10 CFR 20.1201 and 10 CFR 20.1301, and the release of Ar-41 in the restricted areas meets the requirement in 10 CFR Part 20, Table 2 (Effluent concentration) to Appendix B, Annual Limits on Intake (ALIs) and Derived Air Concentrations (DACs) of Radionuclide for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage. Further, the licensee stated that in an unlikely scenario that the exhaust fan spins, but does not generate any flow, the concentration of Ar-41 would increase in the reactor bay. Licensees SAR Section 8.4.4.5, Tables 8.11 and 8.12 provided the results for the isotopes of concern when the fan is turned off (flow rate zero) and turned on (assuming a 1,000 cfm rate), which shows a higher concentration in the reactor bay when the fan is turned off. The licensee described Ar-41 as a submersion (in a hemispherical semi-infinite cloud of airborne) hazard rather than an inhalation hazard to occupational dose per Appendix B to the 10 CFR Part 20 (i.e., the potential hazard from Ar-41 is from external dose which can be monitored using the four area monitors in the reactor bay that keep workers informed of external doses). Since the exhaust fan provides no flow, there would be no release of the Ar-41 through this mode of transportation outside of the facility because when the exhaust fan is turned off, the reactor is isolated, and the resulting public doses would be less than when the reactor is operating.

The NRC staff reviewed the licensees proposed change to TS 3.5. Specific to proposed TS 3.5.1, the NRC staff finds that, as stated in the licensees September 6, 2019, RAI response, the purpose of the exhaust fan is to minimize building buildup of the noble radioactive gas Ar-41 in the facility and to meet the requirements in SAR Section 6.1and TS 3.4 for confinement.

Should a large radioactive release occur, the facilitys emergency procedures direct operators to turn off exhaust fan to minimize the amount of radioactive effluent released from the reactor building and potential radioactive dose to the public. The occurrence of a large radioactive material release is detected using four (4) radiation monitors located in the reactor bay. In addition, OSURR operators are trained and have procedures that direct actions to mitigate events and minimize radiological exposure to OSU staff and exposure to the public. The NRC staff reviewed the analysis of the exhaust fan provided by the licensee and finds that an operating fan is sufficient to keep occupational doses ALARA and within the limits of 10 CFR Part 20 during normal operations. Additionally, the NRC staff reviewed the licensees occupational doses, area and environmental monitor readings, and personnel dosimetry readings provided in its annual reports for the past 10 years, and finds that the licensee has maintained occupational and public doses well within 5 rem and 0.1 rem limits in 10 CFR 20.1201 and 10 CFR 20.1301, respectively Based on its review, the NRC staff finds that the proposed change to TS 3.5.1 does not change the functional requirements of the exhaust fan, as described in the SAR. Licensee analyses demonstrated that the exhaust fan flow rate range of 500 cfm to 1,500 cfm yields offsite effluent concentrations released and resulting doses are less than 10 CFR Part 20 dose limits. The past 10 years of monitoring records, which includes measurements of the Ar-41 concentration and releases from the facility, indicate that the radiological consequences are well within the 10 CFR Part 20 regulatory limits. The NRC staff finds that the licensees analysis of estimated fan flow rates and the licensees radiation monitoring records show that normal operation effluent releases are expected to remain well below offsite radiological regulatory dose limits in 10 CFR 20.1301 and the occupational dose and radionuclides concentration release limits 10 CFR 20.1201 and Table 2 to Part 20 Appendix B, respectively. Further, the requirement that the fan be operating instead of operable during reactor operations is consistent with the TS 3.4 confinement requirement that the fan be operating during reactor operations to prevent airborne radioactivity in excess of 10 CFR Part 20 and the ALARA principle. Therefore, the NRC staff finds that revised TS 3.5.1, including the revised applicability and objective that specify that the exhaust fan is the only HVAC system required for normal operation, specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility, as required by 10 CFR 50.36(c)(2), and is acceptable.

3.3 Proposed Addition of TS 3.5.2, Emergency Operations The licensee proposed TS 3.5.2 to clarify requirement for emergency operations in the current TS 3.5(2) with the related applicability and objective statements for consistency with TS 3.5.1 The current TS 3.5(2) states:

The fan, as well as all other heating, ventilating, and air conditioning systems, shall have the capacity to be shut off from a single switch in the control room.

The proposed 3.5.2 Specification states:

3.5.2 Emergency Operations Applicability: This specification applies to ventilation equipment related to emergency operations, which includes all heating, ventilating, and air conditioning systems that exhaust from the restricted area to the outside environment.

Objective: To specify 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 heating, ventilating, and air conditioning systems that exhaust from the restricted area to the outside environment shall have the capacity to be shut off from a single switch in the control room.

Bases: In the unlikely event of an emergency situation involving the release of fission products or other airborne radioactivity, a means must be available for shutting off ventilation fans and rapidly isolating the building. Section 8.4.4 of the SAR includes an analysis of fission product release.

The change would expand text currently in TS 3.5(2), Specification and move it to a new TS 3.5.2, to distinguish the requirements for emergency operations and to clarify the applicability and objective of those requirements. The new TS 3.5.2 would clarify that existing emergency operation requirements implied by the current TS 3.5(2) apply to all HVAC systems and state in applicability and objective that those systems exhaust from the restricted area in lieu of the building or reactor building.

Based on its review, the NRC staff finds that the revised TS 3.5.2 will clarify existing requirements for reactor emergency operations, including relocated and clarified statements of the TS objective and applicability currently in TS 3.5. The substitution of the word of any for words this fan, as well as other appropriately clarifies that the TS applies to all HVAC equipment that exhaust from the facility have the capability to be shut off from the control room.

Also, the use of restricted area in the proposed TS 3.5.2 specification, objective and applicability sections in lieu of reactor building or building (as in the current TS 3.5) is consistent with the TS 5.1.2 definition of restricted area, which specifies that the restricted area consists of the reactor building, clarifies the TS 3.5(2) requirement. Because the proposed changes appropriately distinguish or clarify current requirements for emergency operations and clarify which equipment is subject to the TS, the NRC staff finds that the proposed TS 3.5.2 would provide the lowest functional capability or performance levels of equipment required for safe operation of the facility, as required by 10 CFR 50.36(c)(2), and is acceptable.

3.4 Conclusion The NRC staff reviewed the licensees proposed changes to TS 3.5, which is related to reactor operation and is part of the license. Based on its review, the NRC staff finds that a specific exhaust fan flow rate is not necessary to meet annual occupational and public radiological dose limits in 10 CFR Part 20 or the release limits in Table 2 of Appendix B to Part 20, or the ALARA principle, as demonstrated by the licensees analyses in accordance with Section 6 of the SAR and the 10 years of facility personnel and environmental monitoring records. The NRC staff finds that proposed TS changes specify the lowest functional capability or performance levels of equipment required for safe operation of the facility for normal and emergency operations, as required by 10 CFR 50.36(c)(2), and therefore, the NRC staff finds the proposed changes in the LAR acceptable.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment would change a requirement with respect to installation or use of a facility component. Pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement is required for any action within the category of actions listed in 10 CFR 51.22(c), for which the Commission has declared to be a categorical exclusion by finding that the action does not individually or cumulatively have a significant effect on the human environment.

10 CFR 51.22(c)(9), states, in part, that issuance of an amendment that changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined by 10 CFR Part 20, meets the definition of a categorical exclusion, provided that, the proposed change satisfies each of 10 CFR 51.22(c)(9) criteria listed below:

(i)

The amendment or exemption involves no significant hazards consideration;

[10 CFR 51.22(c)(9)(i)]

Pursuant to 10 CFR 50.92(c), the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated [10 CFR 50.92(c)(1)];

Proposed TS 3.5.1 requires the existing exhaust fan to operate during normal reactor operations without requiring a specific fan flow rate and proposed TS 3.5.2 clarifies that all HVAC equipment that exhaust from the restricted areas is subject to requirements for remote shut off capability during emergency operations. SAR Section 8.4 (ADAMS Accession No. ML993610231), which was approved when the NRC renewed the OSU License, previously evaluated a postulated maximum hypothetical accident that bounds all accidents at the facility and assumes that the release of fission products from a fuel element to the unrestricted environment results in radiological consequences. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because no changes are being proposed to reactor design or hardware, or to structures, systems, and components (SSCs) that are relied upon for accident detection, mitigation, or response. If an accident occurs, proposed TS 3.5.2 will continue require that the exhaust fan and other HVAC equipment have the capability to be shut off, and fan operation has no impact on the probability or consequence of an accident. In addition, the proposed amendment does not change the licensed power level of the reactor, fission product inventory, and or change any potential release paths from the facility. Therefore, the NRC staff concludes that there is no significant increase in the probability or consequences of an accident previously evaluated.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated [10 CFR 50.92(c)(2)];

The proposed amendment would remove the exhaust fan flow rate requirement, but otherwise clarify existing requirements for normal and emergency operations, including specifying which HVAC systems are subject to those requirements.

TS 3.5.1 would require that the exhaust fan be operating (rather than operable),

which is a stricter requirement and consistent with the TS 3.4 requirement for confinement. TS 3.5.2 would refer to all systems that exhaust for the restricted area in lieu of the building or reactor building. These changes do not create any new or different accident from any accident previously evaluated because no changes SSCs that are relied upon for accident detection, mitigation, or response to an accident given that the fan (and other HVAC systems) would be shut off in the event of an accidental release. In addition, the changes would not introduce any new accident scenarios, transient precursors, failure mechanisms, or limiting single failures, and there would be no adverse effect or challenges to any reactor safety related systems as a result of the proposed amendment. Therefore, the amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Involve a significant reduction in a margin of safety [10 CFR 50.92(c)(3)];

The proposed TS 3.5.1 requires an operating exhaust fan for normal reactor operations and the proposed TS 3.5.2 clarifies existing requirements for emergency operations and the HVAC equipment that is subject to those requirements. The proposed changes do not authorize any changes in SSCs design, function, operation, or in authorized reactor power levels. The proposed amendment does not alter how safety limits, limiting safety system settings or limiting conditions for operation are determined and does not adversely affect existing facility safety margins or the reliability of equipment assumed to mitigate accidents in the facility.

The removal of the exhaust fan flow rate does not affect equipment required to safely shut down the reactor and to maintain it in a safe shutdown condition, and the requirement that the fan be operating during normal operations provides assurance that routine releases will not hinder operator actions. Additionally, the proposed changes do not alter or decrease the functional capability of any SSCs used for defense in depth because the exhaust fan flow rate is not needed to meet any reactor safety limits. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

Based on the above, the NRC staff concludes that the amendment involves no significant hazards consideration.

(ii)

There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; and [10 CFR 51.22(c)(9)(ii)].

Proposed TS 3.5.1 and TS 3.5.2 do not change the types of effluents that may be released offsite or cause any significant increase in the amount of radioactive material that could be released offsite because the existing requirements for monitoring and release of radioactive effluents are unchanged. The reactor power level, the amount of radioactive material used, and the design of reactor SSCs are not changed. In addition, the proposed amendment does not change TS 3.4, which requires that the fan operate to provide confinement of releases, and TS 3.6.2, which requires that radioactive effluents be monitored to ensure that releases beyond the site boundary do not exceed limits in 10 CFR Part 20 and Table 2 of 10 CFR Part 20, Appendix B. Therefore, there is no significant change in the types of significant increase in the amounts of any effluents that may be released offsite.

(iii)

There is no significant increase in individual or cumulative occupational radiation exposure [10 CFR 51.22(c)(9)(iii)].

The proposed TS 3.5.1 requires that the exhaust fan operate during normal reactor operations and the proposed TS 3.5.2 clarifies existing requirements for emergency operations, including the HVAC equipment that exhausts from the restricted area that is subject to those requirements. Proposed TS 3.5.1 and TS 3.5.2 do not change existing requirements for individual or cumulative occupational radiation exposure. The proposed amendment does not cause a significant increase in individual or cumulative occupational exposure because the fan flow rate is not necessary to meet any regulatory limits, as demonstrated by OSUs analysis. Additionally, the licensees radiation safety program has effectively controlled radioactive material exposure as required in TS 3.4 to prevent exposures that exceeding the dose limits of 10 CFR Part 20 and the release limits in Table 2 of Appendix B to Part 20. Further, facility radiation protection program requirements, including the TS requirement to keep doses ALARA, remain unchanged.

Therefore, there is no significant increase in individual or cumulative radiation exposure.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: X. Yin, NRR G. Wertz, NRR Date: March 30, 2020