ML20198S117

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Forwards Response to 971119 RAI Re Proposed TS Amend for Penn State Breazeale Reactor.Amend 32 of Ts,Encl W/Changes Marked W/Bar in right-hand Margin
ML20198S117
Person / Time
Site: Pennsylvania State University
Issue date: 01/19/1998
From: Randy Erickson
PENNSYLVANIA STATE UNIV., UNIVERSITY PARK, PA
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198S119 List:
References
TAC-M99647, NUDOCS 9801260076
Download: ML20198S117 (6)


Text

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(814) 86 1 9580 PENNSTATE ~

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Ihwiney A.1:rkkaan ne h nnsylvanii ble Utiimsby Vwe President for Research 3M old Main Dean of the Graduate scium! Univenity Park. PA 16Ao215N January 19,1998 Nuclear Regulatory Commission Document Control Desk -

Washington,DC 20555

' Re: Response for Additional Information (TAC No. 99647), Penn State Breazeale Reactor 4 Docket No.50-005 dated November 19,1997

Dear Sir or Madame:

Attached is the response to the Re Breazeale Reactor Docket 005No.

dated50 quest 19,1997.

November for Additional Ir. formation (TAC No. 99647 The xesponse answers the questions and has led to a revised T*, Pmposed Amendment No. 32, 1 l

January 16,1998. Additional changes were made to change the inspection frequency of the fuel.

Editonal changes also were made. All changes for Amendment No. 32 are marked with a bar in I the right hand margin. Changes with this revision are listed on the attached response.

Sincerely, k

Dr.Rodney A.Erickson Vice President for Research Dean of the Graduate School RAE:CFS:DEH/ldb4000.98

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' Attachments {

pc: RegionI Administrator 9901260076 990119 PDR ADOCK 05000005

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Subscribed to the sworn before me on this O day of #2/A,1998, Notary Public in and for Centre County, Pen ylvania, f f~

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s qva g dw >V s NOTARIAL SEAL PAMELA J. STAUFFER, Nota Put2c 8 tate College Boro, Centre PA

. My Commission Expires July 2 1 An IMual opportunity University .1 a

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Response To Request For Additional Information z a

. (TAC NO. 99647, November 19,1998) ~

Penn State Breazeale Reactor l i 3 Docket No.50-005 --

Question liJ ._ __

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The proposed License statement on " Maximum Power Level" specifies " 2.45 AK/K."

Provide verification that this is correct or correct to 2.45 %AK/K. -

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- Answer to question 1: .

De proposed License statement on Maximum Power Level is corrected to: j

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De licensee is authorized to operate the facility at a steady state power level of 1.0 1

- megawatt (thermal). The maximum power level shall not exceed 1.1 megawatts -!

(thermal). In pulsing mode, reactivity insertions shall not exceed 2.45 %AK/K. ,

Question 2:

, The proposed technical specification (TS) 1.1.19. TS 1.1.46, TS 3.ll.a and TS 3.1.1.c do .

- not allow for instrument drift or inaccuracies in that it specifies that it is the maximum :

power to be used for power calibrations only. Given this, power variations above the 1.0

' Mw level would not be allowed except for power channel calibration. Also, the use of die term intentionally in TS 3.1.1.a leaves room for interpretation. Provide clarification.

Answer to question 2:

- TL 1.1.19 and TS 1.1.46 have been renumbered to TS 1.1.17 and TS 1.1.44 respectively.

The pupc,ec4 technical specification TS 1.1.17, TS 1.1.44, TS 3.11.a and TS 3.1.1.c

- have been changed to allow for instrument drift or inaccuracies.

Question 3:

The xoposed TS 1.1.36 adds a reportable occurrence item of"Any other violation of NRC e . regu ations." His is not part of the NRC's guidance (NUREG-1537) or the ANSI /ANS 15.1-1990," Development of Technical Specifications for Research Reactors."

Provide justification that this item is required or eliminate it.

. Answer to ouestion 3:

TS 1.1.36 h'as be renumbered to TS 1.1.34. Part h. of TS 1.1.34 has been removed.

l Qtt. stion 4.. ._

De proposed TS 3.1.3 " Basis" deletes the sentence that shutdown margin supe.rsedes excess reactivity of TS 3.1.2. Provide justification or reinstate this sentence.

4  : Answer to question 4:

%c proposed TS 3.1.3 Basis has been changed. The sentence starting "In addition..." has

- been removed since it added nothing to be basis. nc sentence,"The shutdown margin

~

-requirement may be more restrictive than Specification 3.1.2", has been added.

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. Question 5' De proposed Table 2a unddr the fuel temperature asterisk says 'The limit of 650 degrees C-i may be reduced based on specification 2.2" indicates it is a permissive specification rather than a required specification. Pmvide justification or change the _ word "may" to "will."

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NOTARIAL SE/1 -

. PAMELA J. STAUFFER. Notary Puhse g

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' Answer to question 5:

The sthtement after the asterisk under Table 2a has been changed to "The limit of 650 degrees C shall be reduced as required by specification 2.2."

Question 6

'Ile proposed Table 2b does not specify the power level for the source range interlock. A 3revious submittal states that SOP-02 acceptably defines the condition. Provide a power evel value or provide SOP-02.

Answer to question 6:

SOP-02 is t ic standard o perating procedure for the daily reactor check out. The following or equivalent is proposed as part of the SOP-02 once the proposed amendment is approved.

Fission Chamber Soume Response and Source Level Interlock Channel Check

1. D.emove the source from the core. Verify:
a. The wide range log power indication decmases and b, FC Count Rate Low (True) (Source Level Interlock) message is on DCC-X or DCC-Z.
2. Return the source to the core. Verify:
a. The wide range log power indication incmases and
b. FC Count Rate Low (False) (Source Level Interlock) message is on DCC-X or DCC Z.

Note if the residual neutron population due to recent power operation is at such a level that the specified response (s) can not be verified, this channel check may be waived after

.eview and signoff by the Director or his/her designee (TS 4.2.4.a)

Question 7 TS 6.5.2.f. TS 6.6.1 and TS 6.6.2 refer to the regional Administrator who no longer has direct responsibility for research reactor programs. Provide correction.

Answer to question 7:

TS 6.5.2.f, TS 6.6.1 and TS 6.6.2 have been corrected as recommended.

Question 8 Because of the complexity of this amendment, verify that the enclosed expresses accurately the analyses and associeted requirements.

Answer to question 8; The Licensee verifies that text after the question 8 of the letter from the USNRC ( Marvin M. Mendonca, signatory), Request For Additional Infomtation (TAC NO. 9947, November 19,1998), expresses accurately the analyses and associated requimments as submitted prior to this response.

The following is a listing of editorial changes and changes to accommodate the answers to the above questions, to increase the clarity , to removed unnecessary material, and to support a change in the inspection frequency of the fuel. These are only the changes to the technical specifications since the last submi:tal. All changes in the proposed amendment No. 32 are indicated with a bar in the margin of the revised technical specifications.

TS 1.1.8-This definition has been removed since it is no longer necessary with the revised TS 3.1.5. Subsequent definitions have be renumbered.

2

TS 1.1.1'0nis definition has been removed since it is not used in the present technical .

specifications or as proposed. Subsequent dermitions have be renumbered.

- TS 1.1.16 previously TS 1.1.18-The it.st sentence was added to clarify the applicability of -

the term Maximum Elemental Power Density.=

TS 1.1.17 previously TS 1.1.19-De definition for Maximum Power Level was changed to differentiate it from Steady State Power Level.

1

TS 1.1.44 'pieviously TS 1.1.46-The definition for Steady State Power Level wa
: changed :

c ' to diffewntiate it from Maximum Power i evel.

TS 1.1.34 previously TS 1.1.36-Part h. was removed to make the section consistent with

NUREG-1537 and ANSI /ANS 15.1.

TS 3.1.1-%e title was changed to Non Pulse Mode Operation to more precisely indicate the applicability, in the applicability section " maximum power" was changed to " power" to ,

avoid confusion. Specification part a. was changed to specify the allowable steady state 1

i . power levels. Specification part b was changed to specify the maximum power level.

t Specification part c. is the previous part b. and is unchanged otherwise from earlier submittals. The bases a., b., and c. were changed tojustify the specification. '

l TS 3.1.3 An ", and" was added to the end of part a. of the specification to indicate the union with part b. A sentence was removed from the basis which added no meaning. A sentence was added to indicated that the shutdown margin requirement may be more

restrictive than the specification 3.1.2.

I TS 3.1.5-in the applicability "except as noted" was added for clarity. In specification part b, the phrase "for non pulse operation" was added to indicate the applicability of the '

. specification. Specification part c, was removed. It is not needed with the proposed specification part b. Specification part d.- has been changed to part c. and the "can" was -

c manged to "may" to indicate permission and not capability, in bases part b the phrase "for non pulse operation" was added to indicate the applicability of the specification and bases.

Bases part c. was removed. It is not needed with t me removal of specification part c. Bases part d. has been changed to part c. and the "can" was changed :o "may" to indicate permission ano not capability.

- TS 3.2.2-In the specification and the basis"~90c" was changed to"~$0.90" for consistency.

TS 3.2.4-In the bases part b. "MW" was changed to "Mw" for consistency.

Table 1-The nomenclature of the channeh was changed to more closely describe the present instrumentation without changing the functional requirements of the table.

e Table 2a The "MW" was changed to "Mw.'? The asterisk note at the bottom of the table was changed. The "may" was changed to "shall" to indicate a requirement. The " based on"_was -

changed to "as required by" to further indicate a requirement.

Table 2b-De name of the " Log Power" chantal was changed to " Pulse Mode inhibit" which is a name more descriptive of the function of the interlock and matches the nomenclature on the present console. In the function statement of the' source' level channel "startup" was replaced by " log power" to match the channel name in Table 1.

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. TS 3.2.5 In the specification and the basis " low count rate interlock" was replaced with ,

" source level interlock to be consistent with Table 2b.

TS 3.3.5 _In the objective' an ", and" was added to the end of part a. to make pans a. and '

b. inclusive.L  ;

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- TS 3.5 De specification was rewritten for clarity, it was not a requirement change. De {

omission and addition to the basis was to increase the clarity of the basis.  !

TS 3.61. " Beam hole" and " Beam were changed to "Beamhole" in the Table 3 and the -

basis pan b. for consistency.

.TS 3.7 In the ob tive the phrase " prevent excessive release" was changed to " minimize =!

release" to av ' the undefined word " excessive."in toe specification pan d. the phrase

sufficient to cause suvh damage" was removed to clarify the mcar.ing or the Gentence, in  :

the bases part a. "kW" was changed to "kw" for consistency. In the cases pan b. "MW" .

1

-was changed to "Mw" for consistency. In the bases part d. paientheses were placed around the phrases "such as detonated TNT" and "such as a steam explosion or a high pressure gas <

r container explosion" to increase clarity. In the bases pan d. the last sentence was removed as it was unnecessary.

TS 4.1.3 To reduce the handling of fuel elements during inspection the interval of inspection was increased for elements operated at an NP sl. The requirement for ,

inspection of elements which are removed fmm service was discontinued. The inspection

  • interval for elements operating at NP>l remains the sa:ne. Elements retumed to service

. shall be inspected prior to use.

TS 4.2.3 The specifications parts a., b., c., and d were changed to be consistent with Table 1..

i TS 4.2.4-in specification pan a, the phrase "except when the neutron signal is greater than the setpoint when the source is removed from the core" was added to accommodate a '

situation which would otherwise have no solution. The " Basis" was changed to " Bases." A basis was added tojustify the exception added to the specification.

4 c TS 4.3.4-The hyphen was removed from between " pool" and " water" for consistency.

TS 4.5- In specification pan b. " secures" was changed to "is secured" for clarity.

TS 6.1.1 Parsgraphs 3 and 4 were removed. Delegation of authority by the Director will be handled by administrative procedures.

TS 6.1.4-The ANSI /ANS 15.4 version was changed to the most current, which is "1988."

TS 6.3 The requirement for approval of procedures by Health Physics Office was removed from the procedures f. through u.

TS 6.5.2-The reference is changed from "1.1.36" to "1.1.34" due to the renumbering of

. the definitions.

TS 6.5.2.f., TS 6.6.1, and TS 6.6.2.a. were changed to reflect the new USNRC reponing

- requirements. ,

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-TS 6.62.a.3)- The re erence to"Section 1.1.35" was corrected to "Section 1.1.34" due to t the nnumbering of the definitions, TS 3.1.2,~ TS 3.1.3, TS 3.1.4 TS 3.1.5, TS 3.1.6, TS 3.2.1, TS 3.2.2, TS 3.2.3, TS 3.2.4, TS 3.2.6, TS 3.3.1, TS 3.3.3, TS 3.3.4, TS 3.6.1 TS 3.6.2, TS 3.6.3, TS 3.6.4,

TS 3.7, TS 4.1.1.-TS 4.1.2, TS 4.2.1, TS 4.2.2, TS 4.2.3, TS 4.2.4, TS 4.2.5.1TS .

4.2.6, TS 4.3.1, TS 4.3.2, TS 4.3.3, TS 4.3.4, TS 4.4, TS 4.5, TS 4.6.1, TS 4.6.2, TS 1 4.7, and TS 6.3-All " assure (s)" and insure (s)" were changed to " ensure (s)" to use the ,

correct word for the intended meaning.

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