Text

the Pennsylvania State University - Issuance of Amendment No. 40 to Renewed Facility Operating License No. R-2 for the Penn State Breazeale Reactor
	ML20121A197
Person / Time
Site:	Pennsylvania State University
Issue date:	07/28/2020
From:	Xiaosong Yin; NRC/NRR/DANU/UNPL
To:	Weiss L; Pennsylvania State Univ, University Park, PA
	Yin X, NRR/DANU/UNPL, 301-415-1404
References
	EPID L-2019-LLA-0089
	Download: ML20121A197 (44)
	v • d • e

July 28, 2020 Dr. Lora Weiss Senior Vice President for Research The Pennsylvania State University 304 Old Main University Park, PA 16802-6501

SUBJECT:

THE PENNSYLVANIA STATE UNIVERSITY - ISSUANCE OF AMENDMENT NO. 40 TO RENEWED FACILITY OPERATING LICENSE NO. R-2 FOR THE PENN STATE BREAZEALE REACTOR (EPID NO. L-2019-LLA-0089)

Dear Dr. Weiss:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 40 to Renewed Facility Operating License No. R-2 for the Pennsylvania State University (PSU)

Breazeale Reactor. This amendment consists of changes to the renewed facility operating license and technical specifications (TSs) in response to the application dated March 26, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19094B798), as supplemented by letters dated December 16, 2019, April 21, 2020, May 5, 2020, July 3, 2020, and July 27, 2020 (ADAMS Accession Nos. ML19357A058, ML20122A156, ML20149K583, ML20188A038, and ML20210M011, respectively). The amendment modifies the PSU TSs in Sections 3.5, 3.6, 4.5, 4.6, 5.5, and 6.1 to change the primary exhaust system to the Reactor Bay Heating Ventilation and Exhaust System, change the name of a laboratory monitor, and change a university position title.

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.50-005 License No. R-2

Enclosures:

As stated cc: w/enclosures: See next page

The Pennsylvania State University Docket No.50-005 cc:

Yuanqing Guo Manager of Radiation Protection The Pennsylvania State University 0201 Academic Project Bldg University Park, PA 16802 Director, Bureau of Radiation Protection Department of Environmental Protection P.O. Box 8469 Harrisburg, PA 17105 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 Dr. Jeffrey Geuther Associate Director for Operations Radiation Science & Engineering Center 104 Breazeale Nuclear Reactor Building University Park, PA 16802-1504 Dr. Kenan Unlu, Director The Pennsylvania State University Breazeale Nuclear Reactor Radiation Science and Engineering Center University Park, PA 16802-2301

ML20121A197 *concurrence via e-mail NRR-058 OFFICE NRR/DANU/UNPL/PM* NRR/DANU/UNPL/LA* NRR/DANU/UNPL/BC* OGC/NLO* NRR/DANU/UNPL/PM*

NAME XYin NParker/wcomments GCasto MYoung XYin DATE 5/5/2020 5/5/2020 7/28/2020 7/27/2020 7/28/2020 THE PENNSYLVANIA STATE UNIVERSITY DOCKET NO.50-005 PENN STATE BREAZEALE REACTOR AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 40 License No. R-2

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-2, submitted by the Pennsylvania State University (the licensee) on March 26, 2019, as supplemented by letters dated December 16, 2019, April 21, 2020, May 5, 2020, July 3, 2020, and July 27, 2020, 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 (i) the activities authorized by this amendment can be conducted 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; 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; and 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.

Enclosure 1

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-2 is hereby amended to read as follows:

Technical Specifications

2. The technical specifications contained in Appendix A, as revised by Amendment No. 40, 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 and shall be implemented within 14 days. Implementation shall include revision of the safety analysis report as approved in the safety evaluation supporting this amendment.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Greg A. 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-2

2. Changes to Appendix A, Technical Specifications Date of Issuance: July 28, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 40 RENEWED FACILITY OPERATING LICENSE NO. R-2 DOCKET NO.50-005 Replace the following page of the Renewed Facility Operating License No. R-2 with the revised page. The revised page is identified by amendment number and contains a marginal line indicating the areas of change.

Renewed Facility Operating License No. R-2 REMOVE INSERT 3 3 Attachment 1

3. Pursuant to the Act and 10 CFR Part 30, Rules of General Applicability to Domestic Licensing of Byproduct Material, to receive, possess, and use in connection with operation of the reactor: (1) two sealed 50-curie antimony-beryllium neutron sources, either or both of which may be used for reactor start-up, (2) a sealed 0.235 milligram californium-252 neutron source, and (3) a sealed 3-curie americium-beryllium neutron source.

4. Pursuant to the Act and 10 CFR Part 30 to possess, use, and transfer 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 renewed 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:

Maximum Power Level

1. The licensee is authorized to operate the reactor at a steady-state power level of 1.0 megawatt (thermal). The maximum power level shall not exceed 1.1 megawatts (thermal) when operated in the manual control mode, the automatic control mode, or the square wave mode. In pulsing mode, reactivity insertions shall not exceed 2.45%k/k.

Technical Specifications

2. The technical specifications contained in Appendix A, as revised by Amendment No. 40, are hereby incorporated in the license. The licensee shall operate the reactor in accordance with the technical specifications.

Additional Conditions

3. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The approved physical security plan consists of a Pennsylvania State University document, withheld from public disclosure pursuant to 10 CFR 73.21, entitled, The Physical Security Plan for the Pennsylvania State University Breazeale Reactor, dated June 11, 1990, as revised.

Amendment No. 40 July 28, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 40 RENEWED FACILITY OPERATING LICENSE NO. R-2 DOCKET NO.50-005 Replace the existing pages of Appendix A, Technical Specifications, with the revised pages.

The revised pages are identified by amendment number and contain marginal lines to indicate the areas of change.

Technical Specifications REMOVE INSERT i i ii ii 10 10 26 26.a 26.b 27 27 41 41 42 42 43 43 46 46 47 47 48 48 Attachment 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 Fission Product Activity 23 3.3.4 Pool Water Supply for Leak Protection 24 3.3.5 Coolant Conductivity Limits 24 3.3.6 Coolant Temperature Limits 25 3.4 Confinement 25 3.5 Engineered Safety Features - Ventilation Systems 26 3.6 Radiation Monitoring System 27 3.6.1 Radiation Monitoring Information 27 3.6.2 Evacuation Alarm 28 3.6.3 Argon-41 Discharge Limit 28 3.6.4 As Low As Reasonably Achievable (ALARA) 29 3.7 Limitations of Experiments 29

-i-Amendment No. 40 July 28, 2020

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 System and Effluents 41 4.6.1 Radiation Monitoring System and Evacuation Alarm 41 4.6.2 Argon-41 42 4.6.3 ALARA 42 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 and Exhaust Systems 46 5.6 Reactor Pool Water Systems 46

- ii -

Amendment No. 40 July 28, 2020

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 650C 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 650C.

Basis

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

b. Operation at 1.1 MW (thermal) is within the bounds established by the SAR for steady state operations. See Chapter 13.1.B of the SAR.

c. Limiting the maximum steady state measured fuel temperature of any position to 650C 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 No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.5 Engineered Safety Features - Ventilation Systems Applicability This specification applies to the operation of the reactor bay heating ventilation and exhaust system (RBHVES) and the emergency exhaust system (EES).

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

Specification

a. EXCEPT for conditions 3.5.a(i) and 3.5.a(ii), the reactor SHALL NOT be operated unless reactor bay differential pressure is negative.

(i) Following discovery of loss of negative differential pressure, the reactor may be operated for up to 30 minutes while negative differential pressure is restored.

(ii) The reactor may continue to operate during brief changes to bay pressure that are not long enough to extinguish the RBHVES differential pressure indicator lamp.

b. If the reactor is operating, except for periods of time less than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 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 reactor bay exhaust fans OR discovery of an inoperable emergency exhaust system, immediately place the fuel or fueled experiment in a safe storage location and cease further movements until compliance with 3.5.b is restored.

Basis 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, either the reactor bay heating ventilation and exhaust system or emergency exhaust system, will maintain this condition and provide confinement as defined by TS 1.1.8. If all exhaust from the reactor bay is temporarily lost, the thirty minute limit to restore exhaust gives the operators sufficient time to investigate and respond by checking for penetrations into the confinement bay and energizing fans. Reactor bay area radiation and/or particulate radiation monitors will continue to assure than an unrecognized hazardous condition does not develop. The RBHVES differential pressure indicator lamp is in plain view of the reactor operator in the control room.

Due to integration time constants built into the RBHVES control software, brief (<5 minute) losses of differential pressure will not change the state of the indicator lamp.

Page 26.a of 56 Amendment No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 In the event of a substantial release of airborne radioactivity, an air radiation monitor and/or an area radiation monitor will sound a building evacuation alarm which will alert personnel and 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.

During irradiated fuel or fueled experiment movement, the likelihood of an event releasing fission products is increased. Therefore the continuous operation of a reactor bay exhaust fan and the availability of an operable filtered exhaust is prudent. If the system fails or is discovered to be inoperable during movement activities, the fuel or fueled experiment must be immediately placed in a safe storage location. No additional movements may be conducted until the limiting condition for operation is satisfied.

Page 26.b of 56 Amendment No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 3.6 Radiation Monitoring System 3.6.1 Radiation Monitoring Information 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.

Continuous Air Monitor radioactive 1 (Radiation) Monitor particulates in the reactor bay air.

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

Basis

a. The radiation monitors provide information to operating personnel of any impending or existing danger from radiation 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 No. 40 July 28, 2020

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

c. Reactor bay differential pressure monitors SHALL be calibrated annually, not to exceed 15 months.

Basis Experience, based on periodic checks performed over years of operation, has demonstrated that a test of the exhaust systems on a monthly basis, not to exceed 6 weeks, is sufficient to ensure the proper operation of the systems. This provides reasonable assurance on the control of the release of radioactive material. Annual calibration of the differential pressure sensors will ensure the accurate assessment of reactor bay negative pressure as required by TS 3.5.

4.6 Radiation Monitoring System 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 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 No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 Specification The area radiation monitor, the Neutron Beam Laboratory radiation monitor, the continuous air (radiation) monitor, and the evacuation alarm system SHALL be channel tested monthly not to exceed 6 weeks. They SHALL be verified to be operable by a channel check daily when the reactor is to be operated, and SHALL be calibrated annually, not to exceed 15 months.

Basis 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. Annual channel calibration ensures that units are within the specifications defined by procedures.

4.6.2 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.

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

4.6.3 ALARA Applicability This specification applies to the surveillance of all reactor operations that could result in occupational exposures to radiation or the release of radioactive effluents to the environs.

Objective The objective is to provide surveillance of all operations that could lead to occupational exposures to radiation or the release of radioactive effluents to the environs.

Page 42 of 56 Amendment No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 Specification As part of the review of all operations, consideration SHALL be given to alternative operational modes that might reduce staff exposures, release of radioactive materials to the environment, or both Basis Experience has shown that experiments and operational requirements can, in many cases, be satisfied with a variety of combinations of facility options, core positions, power levels, time delays, and effluent or staff radiation exposures. Similarly, overall reactor scheduling achieves significant reductions in staff exposures. Consequently, ALARA must be a part of both overall reactor scheduling and the detailed experiment planning.

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

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

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

Basis Authorized reviewers are appointed by the facility director.

Page 43 of 56 Amendment No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 5.5 Reactor Bay 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 point at least 24 feet above ground level. Upon initiation of a building evacuation alarm, the previously mentioned system is automatically secured (fans deenergized and exhaust dampers closed) and an emergency exhaust system automatically starts. The emergency exhaust system is also designed to discharge reactor bay air at a point at least 24 feet above ground level.

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 ground of the release helps to ensure adequate mixing prior to possible public exposure.

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

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

Page 46 of 56 Amendment No. 40 July 28, 2020

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

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

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

Page 47 of 56 Amendment No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

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

Vice President for Dean, College Physical Plant of Engineering Director of Environmental Health and Safety Penn State Reactor Manager of Safeguards Committee Radiation Protection Director 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 No. 40 July 28, 2020

TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)

FACILITY LICENSE NO. R-2 Page 48 of 56 Amendment No. 40 July 28, 2020

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 40 TO RENEWED FACILITY OPERATING LICENSE NO. R-2 THE PENNSYLVANIA STATE UNIVERSITY PENN STATE BREAZEALE REACTOR DOCKET NO.50-005

1. INTRODUCTION By letter dated March 26, 2019, as supplemented by letters on December 16, 2019, April 21, 2020, May 5, 2020, July 3, 2020, and July 27, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML19094B798, ML19357A058, ML20122A156, ML20149K583, ML20188A038, and ML20210M011, respectively), the Pennsylvania State University (PSU, the licensee) submitted a license amendment request (LAR) to amend its Appendix A of Renewed Facility Operating License No. R-2, Technical Specifications for the Pennsylvania State University Breazeale Reactor.

The proposed changes in the LAR would revise technical specifications (TSs) 3.0, Limiting Conditions of Operations, 4.0, Surveillance Requirements, 5.0, Design Features, and 6.0, Administrative Controls. Specifically, Sections 3.5, Engineered Safety Features - Facility Exhaust System and Emergency Exhaust System, 4.5, Ventilation Systems, and 5.5, Reactor Bay and Exhaust Systems, would be revised to incorporate the use of an upgraded reactor bay heating, ventilation and exhaust system, which was installed and in operation, but was not incorporated in the TSs and the facility safety analysis report. The proposed TS changes would also revise the name of a laboratory monitor in Section 3.6, Radiation Monitoring System, and change the Level 1 management title in Section 6.1, Organization. The licensee also submitted proposed revisions to sections of the facility safety analysis report (SAR) and the TS bases sections 3.1.1.b, 3.5, 3.6.1.b, and 5.5 that reflect the proposed TS changes.

2. REGULATORY EVALUATION 2.1 System Description The following system description is based on information provided in the licensees letters dated March 26, 2019 and December 16, 2019, which submitted the proposed TS and SAR changes, the licensees evaluation of the proposed TS changes, and the licensees response to the U.S.

Nuclear Regulatory Commission (NRC) staffs request for additional information (RAI) (ADAMS Accession No. ML19296E142). The system description is also based on information described in the NRC Safety Evaluation Report Related to the Renewal of Facility Operating License No. R-2 for the Penn State Breazeale Reactor, Pennsylvania State University, dated Enclosure 2

November 20, 2009 (License Renewal safety evaluation report (SER)) (ADAMS Accession No. ML092930497). The licensee upgraded the heating, ventilation, and air conditioning (HVAC) system at the facility in 2012 to a new system designated as the reactor bay heating ventilation and exhaust system (RBHVES) as part of a facility maintenance initiative to improve building efficiency to reduce heating and cooling costs.

In a LAR submitted in 2012 (ADAMS Accession No. ML12040A166), the licensee stated it completed a Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiment, analysis and concluded that prior NRC approval of the installation was not required, but TS changes are required to support the operation of the system. The licensee withdrew the LAR in 2018 after multiple rounds of RAIs (ADAMS Accession No. ML18201A198).

An NRC inspection conducted from August 6-8, 2013, identified no issues (Inspection Report 2013-201, dated September 4, 2013, ADAMS Accession No. ML13241A031). The licensee submitted the current LAR, along with revised SAR Sections 6 and 9, in 2019 in order to support TS revisions necessary to allow the RBHVES, which includes the facility exhaust system (FES),

to be used as the primary exhaust system. The SAR revisions provide detailed descriptions and a diagram of the RBHVES system and describe how one or more of the existing FES exhaust fans or the new HRU-02 exhaust fan can maintain differential pressure during normal operations. The RBHVES has been installed since 2012 and is operable, but the FES remains the primary exhaust system for normal reactor operations. Therefore, the installation meets 10 CFR 50.59(c)(1)(ii) safety criteria, however, apart from this licensing action the NRC staff will separately consider whether 10 CFR 50.59(c)(1)(i) criterion was met.

The heating and air conditioning units in use before the RBHVES were recirculation type cooling units located within the reactor bay. In contrast, a significant portion of the RBHVES is located outside of the reactor bay. The supply and return ducts to and from the RBHVES to the reactor bay pass through the reactor bay boundary and each duct is equipped with an isolation damper.

2.1.1 Reactor Bay Heating, Ventilation and Exhaust System The RBHVES consists of two major components, the Heat Recovery Unit (HRU-02) and the Recirculating, Heating and Cooling Unit (RAHU-02). The major elements of the HRU-02 are an outdoor intake fan, exhaust fan, and an enthalpy wheel. The enthalpy wheel performs a heat recovery function by transferring enthalpy between the incoming and exhaust air passing through the HRU-02. The nominal flow capacity of the exhaust fan is higher than the intake fan to maintain a negative pressure in the reactor bay. The RAHU-02 contains a supply fan, filter, cooling coil, and heating coils. The cooling and heating are through chilled water and steam from the PSU chilled water and power plants. The supply fan in the RAHU-02 transports conditioned air into the reactor bay through a duct that passes through the reactor bay boundary. Similarly, a separate duct returns the air back to the RBHVES through the boundary.

A portion of the returned air is exhausted outside above the reactor bay roof line by the exhaust fan in the HRU-02. The remaining quantity of retuned air is mixed with fresh air from the outside intake fan in the HRU-02 and continues to flow to the suction of the supply fan in the RAHU-02 and eventually gets discharged into the reactor bay. Modulating control dampers in the HRU-02 determine the makeup, recirculation, and discharge flows to maintain a negative pressure in the reactor bay. In addition, the outdoor intake fan, exhaust fan, and supply fan have variable speed operation capability to work in conjunction with the modulating dampers.

A separate outside air intake with a control damper is provided to the suction of the supply fan in the RAHU-02 to facilitate an economizer mode of operation for the RBHVES under certain weather conditions. During the economizer mode, the reactor bay temperature can be

maintained by the RAHU-02 supply fan without the need for chilled water or steam heating and without any assistance from the HRU-02. However, operation of the existing FES, which remains as a part of the RBHVES, is necessary in the RBHVES economizer mode and to satisfy the definition of confinement as described below.

2.1.2 Confinement TS 1.1.8, Confinement, states, Confinement means an enclosure on the overall facility which controls the movement of air into it and out through a controlled path. At PSU, the reactor bay serves as a confinement designed to limit the exchange of effluents with the external environment through controlled pathways.

Prior to the RBHVES installation, the confinement of the reactor bay was achieved by the operation of the FES during normal operations and by the emergency exhaust system (EES) during an emergency by maintaining a negative pressure in the reactor bay. During normal conditions, one of the two exhaust fans in the FES operates to maintain a negative pressure in the reactor bay. In the event of a radioactive release, an air radiation monitor and/or an area radiation monitor will sound a building evacuation alarm and activate a signal to shut down the FES and operate the EES, which has a single fan dedicated to maintain the negative pressure in the reactor bay. Both the FES and the EES exhaust to locations above the reactor bay roofline. The EES has the capability to process the exhaust air through a set of filters (pre-filter, absolute filter and charcoal filter) prior to discharging above the reactor bay roof. The FES and EES remain, the licensee included the operation of FES within the RBHVES and the EES function remains unchanged. Therefore, three exhaust fans (one in the HRU-02 and the two existing FES exhaust fans) are available to draw a negative pressure in the reactor bay during normal conditions and the EES fan continues to maintain the negative pressure and filtration function during an emergency evacuation. In addition, the closure of the isolation dampers in the supply and return ducts of the RBHVES to the reactor bay and the shutdown of the RBHVES, including the FES, is necessary to provide confinement during an emergency.

2.1.3 System Operation and Controls The RBHVES has an occupied mode (reactor operating, or operator demands occupied) and an emergency mode, which correspond to normal operation and emergency operation of the facility, respectively.

The RBHVES control system controls the position of dampers. In the event of an emergency, the reactor operator (RO) can quickly close the dampers by depressing the RBHVES shutdown button in the control room. The facility exhaust fans and the EES have control panels located in the reactor bay.

Upon the loss of power to the RBHVES initiated by the emergency shutdown button, the facility exhaust fans would automatically be energized and restore negative differential power. Also, placing the control switches on the FES control panel to ON ensures the FES is operating regardless of the RBHVES mode.

Automatic activation of the EES system occurs whenever the building evacuation alarm is initiated. The control panel shows the operational status of the EES, including filter pressure drops and pilot lights to indicate system is energized and flow is taking place. The control panel also contains a switch to manually activate the system. Manual start of the EES does not affect the RBHVES operation.

Normal Operation Prior to installation of the RBHVES, the FES fan status was verified by visual observation of the fan blades and open dampers. The RBHVES includes three differential pressure transducers and a differential pressure indicator lamp. If any one of the three transducers sense low differential pressure, the indicator lamp is extinguished. The indication of loss of pressure is not immediate due to a timer typically set to five minutes to ensure that the loss of pressure signal is not false positive. The indicator lamp is read by the RO every hour as part of routine logs.

Upon observing the loss of negative pressure as indicated by the lamp, the RO would consult with the senior reactor operator (SRO), leading to further actions as appropriate. The quickest action available to the operator is to secure power to the RBHVES using the shutdown button in the control room. Following the loss of the RBHVES power, the facility exhaust fan would automatically energize to restore negative differential pressure. The SRO could also toggle the facility exhaust fan control switches located in the reactor bay to ON to ensure that the exhaust fan is operating regardless of the RBHVES mode.

Emergency Operation In the event of a release of airborne radioactivity, an air radiation monitor and/or an area radiation monitor will sound a building evacuation alarm. Upon activation of the alarm, any operating RHBVES fans are shutdown, associated motor-driven confinement isolation dampers shut in approximately five seconds, and the EES system starts. The facility exhaust fans, if operating, also automatically shut down during an evacuation. The communication between the RBHVES control system and the evacuation alarm is through a set of auxiliary contacts on a multiplier relay in the evacuation alarm system. When the evacuation alarm is actuated, the relay opens contacts that interrupt control power from the RBHVES system to the confinement dampers. Without power, the dampers fail to the closed position. In addition, the RBHVES trips the exhaust, supply, and recirculation fans.

2.1.4 Accident Analysis SAR Section 1.2, Summary and Conclusions on Principal Safety Considerations (ADAMS Accession No. ML091250487), states that during an accident the emergency exhaust system (EES) would reduce any exposures to the public to less than three percent of the Total Effective Dose Equivalent (TEDE) limit of 100 millirem for the public in 10 CFR Part 20, Standards for Protection Against Radiation, and even if the EES fails to work properly, the public exposures are still only about 25 percent of the 100 millirem limit allowed to the public.

SAR Section 13.1.1, Maximum Hypothetical Accident, assumes that a fuel element cladding ruptures in an air-cooled core releasing volatile fission products to the reactor bay. The results of the analysis indicate that the total exposure in the reactor bay (restricted area) and the unrestricted area would be less than the annual 10 CFR 20.1201, Occupational dose limits for adults, and 10 CFR 20.1301, Dose limits for individual members of the public, limits. SAR Section 13.1.1 states, in part: Since credit is not taken for the emergency exhaust system filtration in determining of the consequences of this accident, a Technical Specification requiring filtration as a limiting condition for operation [LCO] is not required.

In its SAR, PSU analyzed the maximum hypothetical accident by assuming a ground release without taking credit for radionuclide dilution via the elevated exhaust stacks. The elevated exhaust stacks of the EES and facility exhaust fans is an ALARA (as low as is reasonably

achievable) feature (as defined in 10 CFR 20.1003, Definitions) and is not credited in the accident analysis.

Prior to the installation of the RBHVES, SAR Section 13 and the TSs included the FES and EES to maintain confinement as engineered safety features.

2.2 Regulatory Requirements The NRC staff reviewed the licensees LAR and evaluated the proposed TS changes based on the regulations or guidance in:

10 CFR Part 20, Standards for Protection Against Radiation, which provides the regulatory requirements for protection against ionizing radiation resulting from activities conducted under licenses issued by the NRC.

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

10 CFR Section 50.36, Technical specifications, paragraph (b), which requires that the TSs be derived from the analyses and evaluation included in the SAR.

10 CFR Section 50.36(c), which requires the TSs to include:

Limiting conditions for operation, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility (50.36(c)(2));

Surveillance requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met (50.36(c)(3));

Design features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety (50.36(c)(4)); and Administrative controls relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner (50.36(c)(5)).

NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors - Standard Review Plan and Acceptance Criteria (ADAMS Accession No. ML042430048), which provides guidance to the NRC staff for performing reviews of the LAR. Specifically, Section 6.2.1 provides a functional description of Confinement and provides guidance to the NRC staff for performing safety reviews of the effluent controls associated with maintaining a confinement structure.

American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research

Reactors, Section 4, Surveillance Requirements, which provides guidance, used by the NRC staff, including definitions, parameters and operating characteristics of a research reactor that should be included in the TSs. The 2007 version is a revision of the ANSI/ANS-15.1-1990 standard cited in NUREG-1537 that was issued in 1996.

Because Section 4 of ANSI/ANS-15.1-2007 is not substantively different from the 1990 version, the NRC staff uses the 2007 version of ANSI/ANS-15.1.

3. TECHNICAL EVALUATION 3.1 Proposed Changes to the TSs Related to the RBHVES The NRC staff reviewed the PSU LAR using the guidance provided in Section 6.2.1, Confinement, of NUREG-1537, Part 2, as applicable and appropriate with the RBHVES in operation. The NRC staff compared the confinement configuration of the HVAC system that existed prior to the installation of the RBHVES with the RBHVES to verify that the licensee fully described the systems and components of the RBHVES, including its interfaces with the FES and EES systems. Based on the review, the NRC staff asked the licensee to clarify proposed changes to TS 3.5 via RAIs (detailed in ADAMS Accession No. ML19296E142).

In RAI-1, the NRC staff requested clarification regarding communication between the evacuation system and RBHVES. The NRC staff noted that the LAR referred to the evacuation system, the emergency evacuation system, and the evacuation alarm. The NRC staff asked the licensee to confirm if there is only one evacuation system interface with the RBHVES or if there are multiple evacuation system interfaces. The licensee response by letter dated December 16, 2019 (ADAMS Accession No. ML19357A058), stated that there is only one evacuation system.

In RAI-2, the NRC staff, noting an inconsistency between TS 3.5 Limiting Condition of Operation and the system design, asked the licensee to clarify or propose changes to the LCO, including any changes as necessary to the action statements and allowed outage times (AOT). The NRC staff also asked the licensee to provide a markup of the proposed changes, using the TSs as modified by Amendment No. 39 (ADAMS Accession No. ML12212A235), to the reactor license.

3.1.1 TS 3.5, Engineered Safety Features - Facility Exhaust System and Emergency Exhaust System The current TS 3.5 states:

3.5 Engineered Safety Features - Facility Exhaust System and Emergency Exhaust System Applicability This specification applies to the operation of the facility 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. If the reactor is operating, at least one facility exhaust fan SHALL be operating and, except for periods of time less than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during maintenance or repair, the emergency exhaust system SHALL be operable.

b. If irradiated fuel or a fueled experiment with significant fission product inventory is being moved outside containers, systems or storage areas, at least one facility exhaust fan SHALL be operating and the emergency exhaust system SHALL be operable.

The proposed TS 3.5 states:

3.5 Engineered Safety Features - Ventilation Systems Applicability This specification applies to the operation of the reactor bay heating ventilation and exhaust system (RBHVES) and the emergency exhaust system (EES).

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

Specification

a. EXCEPT for conditions 3.5.a(i) and 3.5.a(ii), the reactor SHALL NOT be operated unless reactor bay differential pressure is negative.

(i) Following discovery of loss of negative differential pressure, the reactor may be operated for up to 30 minutes while negative differential pressure is restored.

(ii) The reactor may continue to operate during brief changes to bay pressure that are not long enough to extinguish the RBHVES differential pressure indicator lamp.

b. If the reactor is operating, except for periods of time less than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 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 reactor bay exhaust fans OR discovery of an inoperable emergency exhaust system, immediately place the fuel or fueled experiment in a safe storage location and cease further movements until compliance with 3.5.b is restored.

Staff Evaluation of Proposed TS 3.5 Current TS 3.5 lists the FES and EES in the TS title and applicability statement. The licensee proposes to replace FES and EES with Ventilation Systems in the title and to change the FES to the RBHVES in the applicability statement because the FES is now part of the RBHVES and

the RBHVES also has an exhaust fan which can be used to maintain reactor bay differential pressure. In addition, the proposed LCO includes requirements related to loss of differential pressure (as indicated by the RBHVES indicator lamp) and the operator actions to maintain confinement during normal operations. The proposed generic title change is sufficient to encompass the RBHVES (which includes the FES and the differential pressure indicator lamp) and the EES. The proposed applicability statement reflects the functions of the RBHVES, which includes exhaust fans required by TS 4.5 to maintain confinement and the differential pressure indicator lamp to indicate loss of pressure. Therefore, the NRC staff finds the revised title and applicability statements are acceptable.

The proposed change to the LCO 3.5.a deletes the requirement that FES be operating during normal operation and instead requires the reactor bay differential pressure to be negative when the reactor is in operation, aside from the following two exceptions.

Exception 3.5.a(i) provides an AOT of 30 minutes following discovery of a loss of negative differential pressure and while that pressure is being restored. The licensee stated that 30 minutes upon the loss of negative pressure is adequate for the watch team to verify that there are no abnormal penetrations into the reactor bay, and if needed, the operator can implement remedial actions by manually tripping the RBHVES from the control room, causing the FES (a component of the RBHVES that currently serves as the primary exhaust system for the facility) to turn ON, thus restoring negative pressure in the reactor bay.

Exception 3.5.a(ii) allows reactor operation during brief reactor bay pressure changes that do not extinguish the RBHVES differential pressure indicator lamp. The licensee stated that based on the operating experience since the installation of the RBHVES in 2012, the negative pressure indicator lamp has never changed state due to entry / egress. In addition, facility procedures do not allow the doors to be propped open while the reactor is operating. If the brief changes in reactor bay pressure are long enough to extinguish the indicator lamp, the 30-minute AOT provides reasonable time to exit the LCO entry based on the availability of multiple reactor bay exhaust fans, the HRU-02 fan and two FES fans, to maintain the reactor bay at a negative pressure.

The proposed change to the LCO 3.5.a would also designate, as TS 3.5.b, the existing requirement for an operable EES during normal operations, except for less than 48-hour maintenance or repair period.

The proposed change to LCO 3.5.b, which would be renumbered as TS 3.5.c, addresses irradiated fuel or fueled experiment movement and would replace facility exhaust fan with reactor bay exhaust fan. The change is consistent with proposed SAR revisions that describe the integration of the two facility exhaust fans as components of the RBHVES, which includes the exhaust fan in the HRU-02, however, the licensee must operate at least one of these fans.

The proposed LCO 3.5.c states that upon discovery of no operating reactor bay exhaust fans OR discovery of an inoperable EES, the fuel or fueled experiment will be immediately placed in a safe storage location and further fuel movements will be ceased until compliance with 3.5.c is restored (i.e., one reactor bay exhaust fan is operating and EES is operable--capable of performing its intended function--as confirmed by the surveillance requirement in TS 4.5.a).

By letter, dated December 16, 2019, PSU clarified that: 1) the proposed revision to the LCO addresses all causes of loss of negative pressure, 2) the AOT for loss of pressure is 30 minutes, and 3) a loss of negative pressure for 30 minutes or less, or loss of negative pressure due to ingress / egress is unlikely based on operating experience and procedural controls. The licensee also stated that recovery actions can be implemented due to the design features in the

reactor bay to start the reactor bay exhaust fans and emergency exhaust system from their respective control panels. In addition, the proposed requirement to place the fuel and fueled experiment in a safe location immediately upon discovery of no operating reactor bay exhaust fan or discovery of an inoperable emergency exhaust system and to cease any further fuel movement until compliance with LCO 3.5 is restored follows standard practices at nuclear facilities. For example, TS 3.7.10 Control Room Emergency Filtration System (CREFS) in NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Volume 1, Revision 4 (ADAMS Accession No. ML12100A222), states that upon loss of CREFS suspend movement of irradiated fuel assemblies immediately. The basis for 3.7.10 clarifies that immediate suspension does not preclude the movement of fuel to a safe location (ADAMS Accession No. ML12100A228).

The NRC staff reviewed the licensees proposed changes to TS 3.5 and the related information in the revised SAR Section 6, which provides a detailed description and diagram of the RBHVES system, identifies the additional exhaust fan available in HRU-02, and role of the RBHVES in maintaining differential pressure during reactor normal operations. The NRC staff finds that the proposed TS 3.5 changes are derived from licensee analyses and evaluation that show confinement of the reactor bay as a result of the RBHVES operation was evaluated and appropriately considered in accordance with 10 CFR 50.36(b). Replacing the TS 3.5.a requirement that an exhaust fan be operating during normal operations with a negative differential pressure requirement is consistent with proposed revisions to SAR Section 6, which state that a negative pressure is achieved by the operation of one or more reactor bay exhaust fans. The requirements to have an operating exhaust fan or to maintain reactor bay negative pressure are comparable. The NRC staff finds, as to proposed TS 3.5.a, that continued reactor operation during bay pressure changes that are not long enough to extinguish the RBHVES differential pressure indicator lamp is acceptable to address brief disruptions to negative pressure (e.g., due to ingress / egress in the reactor bay) and that the proposed 30-minute AOT to restore a negative pressure is adequate time for the licensee to verify that there are no abnormal penetrations into the reactor bay, and to manually trip the RBHVES from the control room, causing the FES to operate and restore reactor bay negative pressure. In addition, proposed addition of the TS 3.5.c requirement to cease, upon the discovery of an inoperable EES, the movement of items with a significant product inventory (irradiated fuel or fueled experiments) outside containers, systems or storage areas and to move them immediately to a safe location until compliance with 3.5.c is restored, is acceptable to prevent the potential for a significant fission product release. The NRC staff further finds that renumbering, as TS 3.5.b, the existing requirement that the EES be operable during reactor operations is acceptable. As a result, the NRC staff finds that the proposed TS changes meet 10 CFR 50.36(c)(2) requirements by specifying the lowest functional capability or performance levels of equipment required for safe operation of the facility and when a LCO is not met, the reactor shall be shut down or take remedial actions until the condition can be met. Therefore, the NRC staff finds the proposed changes to LCO, TS 3.5, Ventilation Systems, acceptable.

3.1.2 TS 4.5, Facility Exhaust System and Emergency Exhaust System The current TS 4.5 states:

4.5 Facility Exhaust System and Emergency Exhaust System Applicability These specifications apply to the facility exhaust system and emergency exhaust system.

Objective The objective is to ensure the proper operation of the facility 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 facility exhaust system is secured when the emergency exhaust system activates during an evacuation alarm (See TS 3.6.2 and TS 5.5).

The proposed TS 4.5 states:

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

c. Reactor bay differential pressure monitors SHALL be calibrated annually, not to exceed 15 months.

Staff Evaluation of Proposed TS 4.5 Consistent with the nomenclature changes to reflect the use of the RBVHES in TS 3.5 LCO, the licensee proposed to change the title of TS 4.5 from Facility Exhaust System and Emergency Exhaust System to Ventilation Systems. The term facility exhaust system in the applicability, objective and specifications would be replaced by reactor bay heating, ventilation and exhaust system. The proposed change to TS 4.5.b would also require the licensee to verify that the RBHVES is secured when the EES activates during an evacuation alarm, on the same surveillance interval currently required for the FES under TS 4.5.b.

PSU also proposed to add a new surveillance requirement TS 4.5.c to calibrate the reactor bay differential pressure monitors annually, not to exceed 15 months. There are three differential pressure transducers to detect low differential pressure, with any one of the differential pressure transducers reading a low differential pressure extinguishing the differential pressure indicating lamp. The indication of loss of power is not immediate due to a timer set to five minutes. The licensee stated that the indicator lamp is read every hour for routine logs.

The NRC staff reviewed the licensees proposed changes to TS 4.5. In reviewing the acceptance criteria for confinement as described in Section 6.2.1 of NUREG-1537, Part 2, the NRC staff compared the existing confinement (an enclosure on the overall facility which controls the movement of air into it and out through a controlled path) versus modified confinement with the use of the RBHVES. During an emergency, the confinement dampers close and the EES operates, leaving the configuration of containment unchanged. The RBHVES includes three differential transducers and a differential pressure indicator lamp to warn the operators of inadequate differential pressure. In addition, the RBHVES includes simple and immediate actions that operators can initiate from the RBHVES emergency shutdown panel to restore the negative pressure, including closure of the confinement dampers.

The SRs in TS 4.5.a and TS 4.5.b ensure on a monthly frequency, not to exceed 6 weeks, that the EES is operable and that the RBHVES is secured when EES activates during an evacuation alarm. The surveillance requirement in TSs 4.5.c requires that reactor bay differential pressure monitors are calibrated annually, not to exceed 15 months. The NRC staff concludes that the modified confinement with the RBHVES continues to meet the acceptance criteria in Section 6.2.1, Confinement, of NUREG-1537, Part 2. The NRC staff also concludes that the frequency of the routine logs (see SE section 2.1.3, above) provides the operators a means to detect any noticeable changes and take further action to implement remedial actions as necessary. The NRC staff finds that the proposed annual frequency, not to exceed 15 months, for calibrating the differential pressure monitors is consistent with ANS/ANSI 15.1 Section 4, Surveillance Requirements, which recommends calibrations to be completed annually to biennially and defines an annual interval as not to exceed 15 months. Therefore, the NRC staff concludes that the proposed frequency for calibrating the differential pressure monitors is acceptable. Further, the NRC staff finds that that the proposed changes meets the 10 CFR 50.36(c)(3) requirements to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Therefore, the NRC staff finds the proposed changes to TS 4.5 acceptable.

3.1.3 TS 5.5, Reactor Bay and Exhaust Systems The current TS 5.5 states:

5.5 Reactor Bay 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 facility exhaust system exhausts unfiltered reactor bay air to the environment releasing it at a point at least 24 feet above ground level.

Upon initiation of a building evacuation alarm, the previously mentioned system is automatically secured and an emergency exhaust system automatically starts.

The emergency exhaust system is also designed to discharge reactor bay air at a point at least 24 feet above ground level.

The proposed TS 5.5 states:

5.5 Reactor Bay 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 point at least 24 feet above ground level. Upon initiation of a building evacuation alarm, the previously mentioned system is automatically secured (fans deenergized and exhaust dampers closed) and an emergency exhaust system automatically starts. The emergency exhaust system is also designed to discharge reactor bay air at a point at least 24 feet above ground level.

The proposed change to TS 5.5.b revises design features to reflect operation of the RBHVES during normal operations by replacing the reference to facility exhaust system with reactor bay heating, ventilation and exhaust system. The change also adds design detail to define secured by adding fans deenergized and exhaust dampers closed, after automatically secured. The deenergized fans and closed exhaust dampers force the exhausted flow to pass through filters (charcoal, HEPA) in the emergency exhaust system to reduce releases. The existing capability to shut down all systems other than the EES system during an evacuation, which results in treating the exhaust flow through filters, is unaffected by the proposed change.

The NRC staff reviewed the proposed changes and finds that the changes reflect the use of the RBHVES and clarify the meaning of RBHVES secured. The NRC staff finds that the proposed changes accurately describe the design features of the RBHVES during normal operations and maintain those facility design features that, if altered, would have a significant effect on safety.

Therefore, the NRC staff finds the proposed changes are consistent with 10 CFR 50.36(c)(4) and are acceptable.

3.2 Other TSs Changes 3.2.1 TS 3.6.1, Radiation Monitoring Information The current TS 3.6.1, Radiation Monitoring Information, Table 3, Radiation Monitoring Channels, states:

Table 3 Radiation Monitoring Channels Radiation Monitoring Channels Function Number Area Radiation Monitor Monitor radiation levels 1 in the reactor bay.

Continuous Air Monitor radioactive 1 (Radiation) Monitor particulates in the reactor bay air.

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

The proposed TS 3.6.1 Table 3 states:

Table 3 Radiation Monitoring Channels Radiation Monitoring Channels Function Number Area Radiation Monitor Monitor radiation levels 1 in the reactor bay.

Continuous Air Monitor radioactive 1 (Radiation) Monitor particulates in the reactor bay air.

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

TS 3.6.1 requires that the reactor not be operated unless the radiation monitors channels listed in Table 3 are operating. The objective of the TS is to ensure personnel radiation safety during reactor operation.

The proposed change to TS 3.6.1 Table 3 would replace Beamhole Laboratory with Neutron Beam Laboratory to provide consistency between the TS and terminology used at the facility.

TS 3.6.1 requires the radiation monitoring channels listed in Table 3 to be operating in order to operate the reactor. The NRC staff reviewed the proposed change to TS 3.6 and finds that the name change from Beamhole Laboratory to Neutron Beam Laboratory is consistent with the nomenclature in the SAR and does not substantively alter the functional requirements for radiation monitoring in the Laboratory or safe operation of the facility. Further, the proposed change also meets 10 CFR 50.36(c)(2) requirements by clarifying the lowest functional capability or performance levels of equipment required for safe operation of the facility.

Therefore, the NRC staff finds the changes to the TS acceptable.

3.2.2. TS 4.6.1, Radiation Monitoring System and Evacuation Alarm The current TS 4.6.1 states:

4.6.1 Radiation Monitoring System and Evacuation Alarm Applicability This specification applies to surveillance requirements for the area radiation monitor, the Beamhole Laboratory radiation monitor, the air 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.

Specification The area radiation monitor, the Beamhole Laboratory radiation monitor, the continuous air (radiation) monitor, and the evacuation alarm system SHALL be channel tested monthly not to exceed 6 weeks. They SHALL be verified to be operable by a channel check daily when the reactor is to be operated, and SHALL be calibrated annually, not to exceed 15 months.

The proposed TS 4.6.1 states:

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 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.

Specification The area radiation monitor, the Neutron Beam Laboratory radiation monitor, the continuous air (radiation) monitor, and the evacuation alarm system SHALL be channel tested monthly not to exceed 6 weeks. They SHALL be verified to be operable by a channel check daily when the reactor is to be operated, and SHALL be calibrated annually, not to exceed 15 months.

The proposed change to TS 4.6.1 replaces Beamhole Laboratory with Neutron Beam Laboratory. The licensee stated that the proposed change would provide consistency between the TS and terminology used at the facility and throughout the SAR. The NRC staff reviewed the licensees proposed change to TS 4.6.1 and finds that the change in terminology is an update that does not affect the operation of the radiation monitor or substantively alter any technical or safety requirements for radiation monitoring at the facility. Further, the NRC staff finds that that the proposed change clarifies a TS requirement that ensures the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Therefore, the NRC staff finds the change meets 10 CFR 50.36(c)(3) and is acceptable.

3.2.3. TS 6.1.1, Structure and the Organization Chart The current TS 6.1.1 states:

6.1.1 Structure The University Vice President for Research Dean of the Graduate School (level 1) has the responsibility for the reactor facility license. The management of the facility is the responsibility of the Director (level 2),

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

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

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

The Manager of Radiation Protection reports through the Director of Environmental Health and Safety, the assistant Vice President for Safety and Environmental Services, 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.

The proposed TS 6.1.1 states:

6.1.1 Structure The University Senior 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 Senior Vice President for Research 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 Safety and Environmental Services, 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.

The current Organization Chart within TS 6.1 shows:

ORGANIZATION CHART Senior Vice President for Finance Vice President for Research and Business/Treasurer Dean of the Graduate School (Level 1)

Vice President for Dean, College Physical Plant of Engineering Director of Environmental Health and Safety Penn State Reactor Manager of Safeguards Committee Radiation Protection Director Penn State Breazeale Reactor (Level 2)

Associate Director for Operations (Level 2)

Operating Staff Senior Reactor Operators (Level 3)

Reactor Operators (Level 4)

The proposed Organization Chart shows:

ORGANIZATION CHART Senior Vice President for Finance Senior Vice President for Research and Business/Treasurer (Level 1)

Vice President for Dean, College Physical Plant of Engineering Director of Environmental Health and Safety Manager of Penn State Reactor Radiation Protection Safeguards Committee Director Penn State Breazeale Reactor (Level 2)

Associate Director for Operations (Level 2)

Operating Staff Senior Reactor Operators (Level 3)

Reactor Operators (Level 4)

The proposed changes to TS 6.1.1 and the Organization Chart within TS 6.1 change the level 1 management title from Vice President for Research, Dean of the Graduate School to Senior Vice President for Research. The licensee stated that the changes reflect a title change at PSU. The position duties, responsibilities, and lines of reporting remain the same. The NRC staff reviewed the proposed changes to TS 6.1.1 and the Organization Chart and finds that the title change does not affect the responsibility and position of the level 1 management and continues to provide administrative controls relating to organization, management, and reporting necessary to assure operation of the facility in a safe manner as required by 10 CFR 50.36(c)(5). Therefore, the NRC staff finds the changes acceptable.

3.3 Other Changes 3.3.1 TS 3.1.1, Non-Pulse Mode Operation, Basis b.

Consistent with the requirement in 10 CFR 50.36(a), the LAR also included a change to Basis b.

in TS 3.1.1 to correct a reference to the SAR.

3.3.2 Table of Contents Changes The LAR proposed changes to the Table of Contents to reflect the proposed TSs 3.5 and 4.5 title changes. The NRC staff finds the changes to be consistent with TS 3.5 and TS 4.5 and are therefore acceptable.

3.3.3 SAR Changes The LAR proposed changes to SAR Section 6, Engineered Safety Features and Section 9, Auxiliary Systems which provide detailed descriptions and a diagram of the RBHVES system and how one or more of the existing FES exhaust fans or the new HRU-02 exhaust fan can maintain differential pressure during normal operations. The revised SAR Section 6 also provides a detailed description of the RBHVES control system that in the event of an accident automatically closes the exhaust dampers, shuts down the RBHVES fans, and starts the EES.

The NRC staff finds that the SAR revisions are acceptable.

3.4 Conclusion The NRC staff reviewed the licensees proposed changes to TSs 3.5, 3.6, 4.5, 4.6, and 5.5, which reflect the use of the RBHVES, specify requirements for the RBHVES, and change the name of a laboratory monitor. Based on its review, the NRC staff finds that the licensee provided information that shows the proposed TSs would continue to provide requirements for the confinement to control the movement of air into and out of the reactor bay through a controlled path and for monitoring releases, and thus continue to limit occupational and public exposures. The NRC staff also finds that the TSs, as revised, meet 10 CFR 50.36(c)(2) requirements by specifying the lowest functional capability or performance levels of equipment required for safe operation of the facility, 10 CFR 50.36(c)(3) requirements by stating requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, and 10 CFR 50.36(c)(4) requirements by describing the design features during normal operations and maintaining those facility design features that, if altered, would have a significant effect on safety. The NRC staff also finds the proposed changes to TS 6.1 meet 10 CFR 50.36(c)(5) requirements by specifying administrative controls relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. In addition, the

NRC staff determined that SAR revisions that reflect the use of the RBHVES are acceptable.

Therefore, the NRC staff finds the changes proposed in the LAR acceptable.

4. 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.

4.1 Proposed Changes to TSs 3.5, 4.5, and 5.5 Related to RBHVES The regulation in 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 TSs 3.5, 4.5, and 5.5 changes support the use of the RBHVES, which includes the existing FES and an additional exhaust fan, as the reactor bay ventilation system for normal operations. The RBHVES is an upgraded ventilation system that improves heating and cooling efficiency. Proposed revised TS 3.5 would ensure that reactor bay differential pressure is negative and lists limited exceptions for reactor operation and/or fuel handling process when negative pressure is briefly interrupted, and actions are being taken to restore required pressure conditions.

Proposed TS 4.5 would add a requirement to calibrate differential pressure monitors annually, not to exceed 15 months, to ensure monitor functionality, and reflect the use of the RBHVES system, which includes the existing FES. Proposed TS 5.5 would also reflect the use of the RBHVES system and add a clarification that defines when the ventilation system is secured. The proposed changes to TS 3.6 and TS 4.6.1 replace Beamhole Laboratory with Neutron Beam Laboratory to be consistent with terminology used throughout licensees SAR and at the facility.

In License Renewal SER, Section 13.1, Maximum Hypothetical Accident, the NRC staff evaluated the postulated maximum hypothetical accident (MHA) that bounds all accidents at the facility and assumes that the release of fission products from a fuel element cladding rupture in an air-cooled core releasing volatile fission products to the reactor bay to the unrestricted environment results in radiological consequences and concluded that calculated doses would remain below the limits in

10 CFR 20.1201 for occupational workers, and 10 CFR 20.1301 for individual members of the public. The proposed change does not alter any of the assumptions or limits used in postulating or evaluating the MHA. The RBHVES is not relied on in an accident scenario and serves no safety functions during an airborne release accident. The laboratory name change does not affect the design or operation of the radiation monitor. Further, 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. 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)];

Proposed TSs 3.5, 4.5, and 5.5 changes reflect the use of the RBHVES, which includes the existing FES and an additional exhaust fan, for normal operations to maintain the negative differential pressure and adds a differential pressure monitor calibration requirement. The RBHVES is an upgraded ventilation system that improves heating and cooling efficiency but plays no role in an accident scenario.

The EES remains as the only emergency exhaust and the use of the RBHVES does not change or alter the EES emergency function. The correction of the name of the laboratory monitor does not affect the design or operation of the radiation monitor.

The proposed changes do not create a new or different kind of accident from any accident previously evaluated in the SAR (ADAMS Accession No. ML091250487),

because there are no changes to SSCs relied upon for accident detection, mitigation, or response to an accident as the design of, and TS requirements for, the EES, the only ventilation system used during an emergency, remain unchanged. In addition, the proposed 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 TS changes to reflect the use of RBHVES, which improves the facilitys air flow and maintains differential pressure, and the addition of a differential pressure monitor calibration requirement do not alter the safety functions of the existing FES and EES.

The RBHVES, which includes the FES and an additional exhaust fan, controls reactor bay air flow and maintains negative differential pressure, and in turn, controls the occupational exposure. The correction of the name of the laboratory monitor does not alter any technical or safety requirements for radiation monitoring at the facility. The proposed TS changes do not authorize any changes in SSC design, function, operation, or in authorized reactor power levels or affect equipment required to safely shut down the reactor and to maintain it in a safe shutdown condition. The proposed changes do 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. Additionally, the proposed changes do not alter or decrease the functional capability of any SSCs used for defense in depth.

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 TSs 3.5, 4.5, and 5.5 changes reflect the use of the RBHVES, which includes the existing FES and an additional exhaust fan, for normal operations to maintain the negative differential pressure, and add a differential pressure monitor calibration requirement. In the event of a release, a building evacuation alarm automatically deenergizes the RBHVES fans and closes the exhaust dampers and the EES automatically starts. The use of the RBHVES does not change or alter the EES function. The correction of the name of the laboratory monitor does not alter any technical or safety requirements for radiation monitoring at the facility or alter offsite releases. The proposed changes 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. TS 3.6.3, Argon-41 Discharge Limit, continues to require that annual releases from the facility do not result in a radiation dose (to a member of the public) in excess of the annual dose limits in 10 CFR 20.1101, Radiation protection programs, (10 millirem) and 10 CFR 20.1301, Dose limits for individual members of the public, (100 millirem). The reactor power level, the amount of radioactive material used, and the design of reactor SSCs are not changed. Therefore, the NRC staff finds that there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite because the proposed change does not affect the offsite radiological material released from the facility.

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

Proposed TSs 3.5, 4.5, and 5.5 changes reflect the use of the RBHVES. The RBHVES, which includes the existing FES and an additional exhaust fan, improves the reactor bay air flow, and in turn, it helps to control the occupational exposures. Proposed changes to TS 4.5 also add a new requirement to calibrate differential pressure monitors annually, not to exceed 15 months, to ensure the monitor functionality. These changes, as well as the correcting the laboratory monitor name, do not alter any technical or safety requirements for radiation monitoring at the facility or affect occupational radiation exposure. The reactor power level, the amount of radioactive material used, and the design of reactor SSCs are not changed. Further, the licensees radiation safety program has effectively controlled radioactive material exposure as required in TS 3.6.3 to prevent exposures that exceeding the dose limits of 10 CFR Part 20 and the TS 3.6.4, As Low As Reasonable Achievable (ALARA), program that ensures all exposure to radiation and release of radioactive effluents to the environs ALARA, remain unchanged. Licensee annual reports for the past 10 years indicate that both occupational and public doses and offsite effluent releases were well below the

10 CFR Part 20 limits. Therefore, there is no significant increase in individual or cumulative radiation exposure.

Accordingly, the NRC staff finds that the proposed amendment meets the eligibility criteria for categorical exclusion in 10 CFR 51.22(c)(9).

4.2 Proposed Change to TS 6.1.1 and Organization Chart The proposed change to TS 6.1.1 and the Organization Chart within TS 6.1, which changes the name, position, or title of an officer of the licensee in Section 6.0 of the TSs, reflects the Level 1 management position title change. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10)(iv).

4.3 Environmental Conclusion Based on the discussion above, the NRC staff concludes that the amendment meets the eligibility criteria for categorical exclusions set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10)(iv). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

5. 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 Commission's 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 N. Karipineni, NRR MK. Gavello, NRR Date: July 28, 2020

v t e Letter Sequence Approval
EPID:L-2019-LLA-0089, Pennsylvania State Univ. University Park, PA - License Amendment Request (Approved, Closed)
Initiation Request, Request, Request Acceptance Administration Questions 30 October 2019 Answers 16 December 2019 Results Approval Other: ML20188A038, ML20210M007, ML20210M008, ML20210M010
MONTHYEAR2019-05-22 [Table View]

ML20121A197

Text

SUBJECT:

Dear Dr. Weiss:

Enclosures:

1.0 INTRODUCTION

Navigation menu

Search