ML20199K000

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Forwards Request for Addl Info Re 970206,0428 & 0919 Ltrs Related to Changes to Penn State Breazeale Research Reactor License & TS
ML20199K000
Person / Time
Site: Pennsylvania State University
Issue date: 11/19/1997
From: Mendonca M
NRC (Affiliation Not Assigned)
To: Randy Erickson
PENNSYLVANIA STATE UNIV., UNIVERSITY PARK, PA
References
TAC-M99647, NUDOCS 9711280289
Download: ML20199K000 (7)


Text

_ _ _ . . _ - .

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Novemtwr 19, 1997 ,

i' Dr. Rodney A. Erickson Vice President for Research Ponnsylvania State University 207 Old Main Building

- University Park, Pennsylvanta 16802 3396

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 99647)

Dear Dr. Erickson:

We are continuing our review of your February 6,1997, submittal as supplemented on April 28, and September 19,1997, related to changes to the Penn State Breareale Research Reactor License and Technical Specificatl3ns. During our review, questions have arisen for which we require additionalinformation and clarification. Please provide responses to the enclosed request for additionallnformation within 60 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirrnation. This request affects nine or fewer respondents and therefore,is not subject to Office of Management and Budget review under P.L. 96 511. Following receipt of the additionalinformation, we will continue our evaluation of your application.

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. ,1f you have any questions regarding this review, please contact me at (301) 4151128.

1 Sincerely,

) Original signed by:

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Marvin M. Mendonca, Senior Project Manager *

) 't Non Power Reactors and Decommissioning '

Project Directorate

f ,. Division of Reactor Program Management -

, Office of Nuclear Reactor Regulation s s 4 9  ;

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Docket Nb.50-005 -

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UNITED STATES j NUCLEAR REGULATORY COMMIS810N WASHINGTON O.C. 30e06-0001 f

~%*****/ November 19, 1997 I

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Dr. Rodney A. Erickson Vice President for Research Pennsylvania State University 207 Old Main Building University Park. Pennsylvania 16802 3396

SUBJECT:

REOUEST FOR ADDITIONAL INFORMATION (TAC NO. 99647)

Dear Dr. Erickson:

We are continuing our review of your February 6,1997, submittal as supplemented on April 28, and September 19,1997, related to changes to the Penn State Breezeole Research Reactor License and Technical Specifications. During our review, questions have arisen for ,

which we require additionalinformation and clarification. Please provide responses to the enclosed request for additionalinformation within 60 days of the date of this letter, in accordance with 10 CFR 50 30(b), your response must be executed in a signed original under oath or affirmation. This request affects nine or fewer respondents and therefore,is not subject to Office of Management and Budget review under P.L. 96 511. Following

' receipt of the additionalinformation, we will continue our evaluation of your applicatiun.

If you have any questions regarding this review, please contact me at (301) 4151128.

Sincerely, A_ w .,4 b<-_

Marvin M. Mendonca, Senior Project Manager Non Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.50-005 cc: See next page

\

Pennsylvania State University Docket No. 50 5 cc:

Mr. Rodger W.' Granlund University Health Physicist The Pennsylvania State University =

- 228 Academic Projects Building University Park, PA 16802 Dr. C. Frederick Sears Penn State Breareale Reactor '

The Pennsylvania State University

  • Breareale Reactor Building .

University Park, PA 16802 - ,

Mr. William P. Dornsefe, Director of l Radiation Protection Department of Environmental Protection '

- 13til Floori Rachel Carson State Office

. Building P. O. Box 8469 Harrisburg, PA 17105 8469 i

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REQUEST l OR ADDITIONAL INFORMATION l 3

PENN STATE BREAZEALE RESEARCH REACTOR i DOCKET NO.50-005 The proposed License statement on

  • Maximum Power Level" specifies "2.45 AK/K.*

f 1.

l Provide verification that this is correct or correct to 2.45%oK/K.

2. The proposed technical specification (TS) 1.1.19. TS 1.1.46, TS 3.1.1.a and TS 3.1.1.c .

do not allow for instrument drif t or inaccuracles in that it specifies that it is the maximum power to be used for power channel calibrations only. Given this, power variations above the 1.0 MW level wou'd not be ailowed except for the power channel calibration. Also, the use of the term intentionally in TS 3.1.1.a leaves room for interpretation. Provide clarification.

3. The proposed TS 1.1.36 adds a reportable occurrence itero of "Any other violation of NRC regulations." This is not part of the NRC's guidance (NUREG 1337) or the American National Standards Institute /American Nuclear Society Standard 15.1 1990,

" Development of Technical Specifications for Research Reactors" (ANSI /ANS 15.1).

Provide justification that this item is required or eliminate it.

4. The proposed TS 3.1.3
  • Basis" deletes the sentence that shutdown margin supersedes excess reactivity of TS 3.1.2. Provide justification or reinstate this sentence.
5. The proposed Table 2a under the fuel temperature 6.sterisk says "The limit of 650 '

degrees C may be reduced based on specification 2.2" indicates it is a permissive specification rather than a required specificatien. Provide justification or change the word "may" to "will".

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6. The proposed table 2b does not specify the p war level for the source range interlock.

A previous submittel states that SOP 02 acceptably defines the condition. Provide a power level value or provloe SOP-02,

7. TS 6.5.2.f. TS 6.6.1 and TS 6.6.2 rcfer to the Regional Administrator who no longer has dirert responsibility for research reactor programs. Provide correction.
8. Because of the complexity of this amendment, verify that the enclosed expresses accurately the analyses and associated requirements.

License paragraph 2.C(1):

(1) Maximum Power Level The licensee is authorized to operate the f acility at a steady state power level of 1.0 megawatt (thermall The maximum power level shall not exceed 1.1 megawatts (thermal). In the pulsing mode, reactivity insertions shall not exceed 2.45%Ak/k.

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By letter dated February 6,1997, and as sapplemented on April 28, and September 19, I

1997, the Pennsylvania State University (the licensee) submitted a request for amendment to the Amended Facility Operating License No. R-2, and associated Technical Specifications 4

(TS) for the Pennsylvania State UnivPtsity Breazeale Research Reactor. The amendment l clarifies requirements to be consistent with 10 CFR Part 20 requirements and the Safety L Analysis Report (SAR), as well as the f acility's physicalinstallation, experimental f acility limitations, and orgtnizational structure, it also makes some administrative and editorial chenges to clarify the TS.

The proposed changes to License Condition 2.C(1) involve an increate in the maximum allowed power level and an increase in the allowable reactivity insettion in accordance with the revised SAR, With regard to the increase in maximum allowed power level, the License Ccndition designete $ e steady stata power level of 1.0 megawatts thermal (MWtj which was the pievious maximum power level. The Ucense Condition also designates a maximum power level of 1.1 MWt, which la the limiting power level that is assumed in the SAR for accident and protnctive action initiation. Without these designations, the License Condition does not 91 tow for variations in instrument indications (e.g., drif t and noiseL Therefore, those two changes in the Uconso Cnndition will not chance actual operation or potential accident conditions or mitigation, and will ensure that actual operations are consistent with the License Conditions. The licensee also proposed changes to TS 1.1.19. TS 1.1.46, TS 3.1.1.a end TS 3.1.1.c to supply definitions and specifications for maximum power level and steady state power level consistent with the License Conditions. Similar clarifying changes have boon modo for other non power reactors (e.g., University of Michigan, Docket No. 50-02, Amendment No. 39). Therefore, these changes are acceptable.

With regard to the increase in the maximum allowed reactivity insertion from 2.31%Ak/k to 2.45%Ak/k, the licensee submitted SAR analyses for this insertion and demonstrated that no fuel safety limit would be exceeded. These analyses used the methods that were previously approved. The change is also specified in TS 3.1.4 to ensure compliance with the reactivity insertion limit. Further, the licensco proposed reducing the transient rod worth and experiment worth allowable limits in TS 3.1.4, TS 3.7.a, and TS 3.7.b from 2.59%Ak/k to 2.45%6k/k to be consistent with the SAR analysis. The licensee also proposed to delete the specification that removes the limit on transient rod worth when excess reactivity was below that limit, since this requirement no longer applies, dased on the analyses for and the specification of this limitation, these changes are acceptable.

The licensee proposed changes to TS 1.1.2, TS 1.1.17, TS 1.1.25, TS 1.1,28 and TS 1.1.45 to supply defioitions that are consistent with the current operations and facility configuration with the digital control ccnsole that was accepted for use in License Amendment No. 30. Therefore, these changes are acceptable.

The proposed changes to TS 1.1.7, TS 1.1.8, TS 1.1.32, TS 1.1.36, TS 1.137, fS 3.1.2, TS 3.1.5.a T6 3.1.6, TS 3.2.3, TS 3.2.4 Table 2a title and "High Power" channol, Table 2b title and " Shim, Safety and Regulating Rod" channel and "Beses," TS 3.2.5, TS 3.2.6. TS 3.3.6, TS 3.6.1. TS 3.6.3, TS 3.6.4, TS 3.7 " Applicability," TS 3.7.f. TS 4.1.1, TS 4.1.2,

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TS 4.1.3, TS 4.2.3, TS 4.2.4 " Applicability," TS 4.2.5, TS 4.2.6, TS 4.4, TS 4.5, TS 4.6.1, TS 4.7, TS 5.1.a TS 5.3, TS 6.4, TS 6.5, TS 6.6 are editorial or administrative in nature.

Additionally, changes in the TS numbering are also editorial. These changes are acceptable.  ;

The proposed TS 1.1.18 TS 2.2 TS 3;1.1.b, TS 3.1.5.b, and TS 3.1.5.d involve changes to ensure that the fuel temperature limiting safety system setting (LSSS)is conservatively 6stablished. These changes involve a calculational and empirical technique, This technique ensures consideration of the maximum core power density location for the LSSS. The change to TS 2.2 also reduces the LSSS from 700 'C to 650 'C to provide additional margin to the safety limit. A change to TS 3.2.4 Table 2a provides the fuel temperature channel set point requirement for this LSSS reduction. This technique has been described in the licensee's Salaty Analysis Report (SAR) and has been demonstrated by the licensee to prov!do a ccnservative method to establish the LSSS. There were also editorial changes to TS 2.2. ': hose changes are acceptable.

d i ti of Tha rrepond changes to TS 1.1.34, TS 3.1.3, and TS 3.2.2i nvo ve es gna on l

ree/Xty b units of %Ak/k in addition to the units of $, Since this is only an expression of the c* ma value in terms of an additional unit, these changes are acceptable.

The proposed thbnges to TS 2.1 are editorial and make the

  • Basis" section consistent with the SAR. Therefore, these changes are accoptable.

The licensoo proposed a change to TS 3.2.4 Table 2b for the "Sourco Lovel" channel. This change would replace the 2 counts per second with a neutron induced signal. These specifications accomplish the same function, which was to ensure that control rods are not withdrawn without instrument indication, and, thereiore, are acceptable.

The analysis is conservative and demonstrated that fuel damage is not expected in the event of a potential LOCA. These changes are acceptable.

The proposed change to TS 3.3.5 involves designation of conductivity in units of microsiemens/cm in addition to the value in units of micrombos/cm, This change only expresses the same value in terms of an additional unit and represents the same condition as the previous specification. There are also editorial changes proposed in this TS.

Therefore, those changes are acceptable.

The licensee proposed changes to TS 3.5, TS 3.7.e. and TS 4.6.2 to be consistent with current 10 CFR Part 20 requirements. These changes are acceptable.

The licensee proposed changes to TS 3.7.d to broaden and cover all damage mechanisms

'or research with explosive materials. These changes clarify the limitations and are, therefore, acceptable.

The proposed change to TS 4.2.4.b increased the maximum time allowed for the channel check of the transient rod interlock from 7 to 7% months. This change is con 6istent with toguhtory guidance and doss not change the designated semiannual surveillance frequency.

    • .% t 4

TS 5.5.a was updated to reflect current reactor bay free volume consistent with the SAR, and previous licensee reports and analyses. The licensee demonstrated in these analyses and reports that reactor bay free volume was conservatively taken into consideration for applicable potential radiological consequences. Therefore, this change is acceptable, The licenses proposed changes to TS 6.1.1 and the associated chart describing the organizational structure for this non-power reactor. This involved changes in titles, which are solely administrative. It also involved changes to the radiation protection organization which remained acceptabiy independent from the reactor management. Changes also involved separation of the f acility director and Manager of Operations and Training into different levels (level 2 and 3, respectively), and combination of the Senior Operators and the Reactor Operators into level 4 in the organization chert. These changes are consistent with the guidance of American National Standards Institute /American Nuclear Society Standard 15.1 1990 " Development of Technical Specifications for Research Reactors" (ANSI /ANS 15.1). This guidance has been found acceptable in the NRC's "Guldelines for i Preparing and Review Applications for the Licensing of Non Power Fieactors," February 1996, NUREG 1537. On this basis, these changes are acceptable.

The changes proposed to TS 6.2.3 provide additional clarification to the safety committee's 10 CFR 50.59 review function. These changes are acceptable.

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