ML21267A405

Purdue Univ., Reply to Notice of Violation in NRC Special Inspection Report No. 05000182/2021203

ML21267A405
Person / Time
Site:	Purdue University
Issue date:	09/14/2021
From:	Miller T Purdue University
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR 2021203
Download: ML21267A405 (2)

Text

' PURDUE UNIVERSITY0 School of Nuclear Engineering September 14, 2021 U.S. Nuclear Regulatory Commission AT1N: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001

SUBJECT:

Reply to Notice of Violation in NRC Special Inspection Report NO. 05000182/2021203 1.) Reason for the Violation In inspection report NO. 05000182/2021203, it was found that PUR-1, docket number 50-182, had committed a level IV violation by failing to measure the amount of Argon-41 being released to the environment. As noted in the violation, going back to at least the 1980's PUR-1 has been reporting "no measurable amount of radioactive effluent was released to the environs beyond our effective control, as measured at or prior to the point of such release.". This violation occurred due to two reasons. The first being that the release of Ar-41 was thought to have been adequately monitored_

using a TLD however this was found to be inadequate as it is not possible to quantify the amount of Ar-41 being released from the reading of the TLD, as required by PUR-1 TS 6.7.6.b.i.l. The second reason for the violation is that previous theoretical calculations were conducted for the safety analysis report (SAR) showing that very small levels of Ar-41 would be produced and released during full power operations leading previous operators to report that "no measurable amount of radioactive effluent was released ... " which is not verifiable without an adequate means of measuring the amount of Ar-41 being released.

2.) Corrective Steps Taken and Results Achieved The TLD monitoring the exhaust stack has been removed and research into detectors capable of monitoring the quantity of Ar-41 being released from the PUR-1 exhaust stack is ongoing. Products from several nuclear monitoring device vendors are currently being investigated to find the detector best suited to PUR-1 's needs.

3.) Corrective Steps to be Taken Future corrective actions include purchasing and installing a detector capable of monitoring the quantity of Ar-41 being released from the PUR-1 exhaust stack. This detector will be installed so the effluent flowing through the exhaust duct can be monitored. The quantity of Ar-41 being released will be recorded for each operation and the total quantity summarized monthly. Additionally, a correlation between reactor power and Ar-41 being released will be determined in order to back calculate the amount released for any operations prior to installing the monitoring equipment.

4.) Date When Full Compliance Will be Reached It is planned to have the Ar-41 monitoring detector purchased, installed and operation as soon as possible and before the next annual report is due in March of 2022.

School of Nuclear Engineering I 516 Northwestern Ave I West Lafayette, IN, 47906I765-494-5739 I ne@purdue,edu I www.purdue.edu/NE

Please feel free to contact me or any of us with questions or if you need further clarification.

Sincerely,

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True Miller Reactor Supervisor N.E. Radiation Laboratory Coordinator School of Nuclear Engineering CC. Mung Chiang, Seungjin Kim, Stylianos Chatzidakis, David Storz Page 2 of2