ML12031A223

Purdue University - Responses to the Request for Additional Information Regarding the Purdue University Reactor License Renewal Dated July 6, 2011

ML12031A223
Person / Time
Site:	Purdue University
Issue date:	01/30/2012
From:	Joel Jenkins Purdue University Research Reactor
To:	Cindy Montgomery Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1594
Download: ML12031A223 (15)

Text

PURDUE SCHOOL OF NUCLEAR ENGINEERING U N I V E R S I T Y 30 Jan 2012 Document Control Desk US Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Attn: Ms. Cindy Montgomery, Research & Test Reactors (NRR/DPR/PRLB), Mailstop 012 D20

SUBJECT:

PURDUE UNIVERSITY - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594),

RESPONSES TO RAls DATED 6 JULY 2011 (ML101460429)

Dear Ms. Montgomery:

Enclosed please find the responses to the Request for Additional Information regarding the Purdue University Reactor License Renewal dated 6 July 2011. Included with this submission are responses to questions 3, 4, 7, 10, 17, 19, 20, 22, 24, 29, 34, and 40. This completes the question set included in the above referenced letter, as summarized in the table below.

Letter dated Questions addressed 11/15/2011 1, 2, 5, 6, 8, 9, 14, 26, 32, 01/04/2012 11, 12, 13, 15, 16,18, 21, 23, 25, 27, 28, 30, 31, 33, 35, 36, 37, 38, 39 01/30/2012 3, 4, 7, 10, 17, 19, 20, 22, 24, 29, 34, 40 A revised version of the Technical Specifications with the changes required by these responses will be submitted 7 February 2012.

Should you have any questions or require further information, please don't hesitate to call me at 765.496.3573, or e-mail at jere@purdue.edu.

I hereby certify under penalty of perjury with my signature below that the information contained in this s.submission is tru correct to the best of my knowledge.

D ct Radiation Laboratories Attachments: As described.

Cc: Duane Hardesty, USNRC Project Manager Leah Jamieson; Purdue University College of Engineering Jim Schweitzer, Purdue University REM Ahmed Hassanein, Purdue NE School of Nuclear Engineering Nuclear Engineering Building ra 400 Central Drive n West Lafayette, IN 47907-2017 (765) 494-5739 13Fax: (765) 494-9570 o https://engineering.purdue.edu/NE

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

REQUESTED ADDITIONAL INFORMATION IN RESPONSE TO RAIs DATED 6 JULY 2011 (ML101460429)

REGARDING THE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594) 3 TS 1.32 and TS1.33: The Reactor secured and Reactor shutdown definitions provided in TS 1.32 and TS 1.33 differ from the definitions the NRC has previously found acceptable. The definitions for Reactor Secured and Reactor Shutdown are provided in ANSI/ANS- 15.1-2007, Section 1 as tailored by NUREG-1537. The following are definitions, from guidanceprovided in NUREG 1537, Appendix 14.1, deemed acceptable:

Reactor secured:A reactoris secured when:

1. Eitherthere is insufficient moderatoravailable in the reactorto attain criticalityor there is insufficient fissile materialpresent in the reactorto attaincriticality under optimum available conditions of moderationand reflection;

2. Or the following conditions exist:

a. The reactoris shutdown, as requiredby TS 1.33, and;

b. The requirementsof the reactorsecure procedureare met.

Reactor shutdown: A reactoris shutdown when the following conditions exist:

a. The minimum number of neutron absorbingcontroldevices is fully inserted or other safety devices are in shutdown position, as requiredby TS;

b. The console key switch is in the off position, and the key is removed from the lock;

c. No work is in progress involving core fuel, core structure,installed control rods, or control rod drives unless they are physically decoupled from the control rods;

d. No experiments are being moved or serviced that have, on movement, reactivity worth exceeding the maximum value allowed for a single experiment, or one dollar, whichever is smaller.

Note: For subparagraphd., a single value should be chosen to specify the smaller value of either "one dollar"or "the maximum value allowed for a single experiment." Do not specify both options in the definition.

Please evaluate PUR-1 TS 1.33 against the suggested definitions for Reactor secured and Reactor shutdown and propose TS changes orjustify your currentdefinitions.

The definitions for Reactor Secured and Reactor Shutdown are to be changed as follows (as suggested in ANSI 15.1-2007 with some minor modifications for operations at PUR-1, none of which change the intent):

1.32 Reactor secured: A reactor is secured when:

a. Either there is insufficient moderator available in the reactor to attain criticality or there is insufficient fissile material present in the reactor to attain criticality under optimum available conditions of moderation and reflection;

b. Or the following conditions exist:

The minimum number of neutron absorbing control devices is fully inserted or other safety devices are in shutdown position, as required by technical specifications; Page 1 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429) ii. Electrical power to the control rod circuits is switched off via the console key switch, and the switch key is in proper custody.

iii. No work is in progress involving core fuel, core structure, installed control rods, or control rod drives unless they are physically decoupled from the control rods; iv. No experiments are being moved or serviced that have, on movement, reactivity worth exceeding the maximum value allowed for a single experiment.

1.33 Reactor shutdown: The reactor is shut down if it is subcritical by at least one dollar in the reference core condition with the reactivity worth of all installed experiments included.

Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.

4 TS 1.36 and TS 6.6.2: ANSI/ANS-15.1-2007, Section 6.7.2 provides a schedule of events that requirespecial reports. The Reportable Occurrencedefinition in PUR-1 TS 1.36 that addresses these special reports does not appearto be consistent with the guidance in ANSIIANS-15.1-2007, Section 6.7.2. Additionally, per NUREG-1537, Appendix 14.1, TS 6.6.2 should state that specialwritten reports should be sent to the NRC document control desk and special telephone reports of events should be made to the NRC OperationsCenter. Please propose changes to the TS or provide an explanation describingyour reason(s) for not incorporating the changes.

The definition of Reportable Occurrence is removed from the Technical Specifications, and left to T.S.

6.6.2, which brings the TS into closer alignment with ANSI/ANS 15.1 and NUREG 1537.

The following section will be added to the technical specifications:

6.6.2 Non-Routine Reports

a. Special Reports Special reports are used to report unplanned events as well as planned major facility and administrative changes. The following schedule shall be incorporated in the specifications:

(1) There shall be a report not later than the following working day by telephone and confirmed in writing by facsimile or similar conveyance to licensing authorities, to be followed by a written report to NRC Document Control that describes the circumstances of the event within 14 days of any of the following:

(a) operation with actual safety system settings for required systems less conservative than the limiting safety system settings specified in the technical specifications, (b) operation in violation of limiting conditions for operation established in the technical specifications unless prompt remedial action is taken as permitted in Sec. 3, (c) a reactor safety system component malfunction that renders or could render the reactor safety system incapable of performing its intended safety function. If the malfunction or condition is caused by maintenance, then no report is required.

Page 2 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

(d) an unanticipated or uncontrolled change in reactivity greater than 0.6%

Ak/k, (e) abnormal and significant degradation in reactor fuel or cladding, or both, coolant boundary, (f) an observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to reactor safety; Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.

7 TS Section 3.0: NUREG-1537 states the content of the TSs follow ANSIIANS 15.1 guidance.

ANSI/ANS-15.1-2007 Section 3.5 provides specifications for the ventilation systems. Section 3 of the PUR-1 TSs does not contain Limiting Conditionsfor Operationof the Ventilation Systems as referenced by ANSI/ANS-15.1-2007. Please propose TS changes for the ventilation system limiting conditions for operations (LCOs) or provide an explanation describingyour reason(s) for not incorporatingthe changes.

The ventilation system for the reactor room is always on, except during maintenance and testing.

Maintenance and testing do not generally occur during operations.

The PUR-1 TS do contain an LCO for operation of the ventilation system, TS 3.4. The TS 3.4.a.1 was changed in response to Q1 1, and is shown here.

3.4 Confinement Applicability - This specification applies to the integrity of the reactor room.

Obiective - The objective is to limit and control the release of airborne radioactive material from the reactor room.

Specification -

a. During reactor operation the following conditions will be met:

1. The reactor room will be maintained at a negative pressure of at least 0.05 inches of water with the operation of the room exhaust fan.

10 TS 3.3: ANSI/ANS-15.1-2007, Section 3.3 provides a list of minimum operating equipment or operatinglimits, or both, for the limiting conditions for operations for the coolant systems.

PUR-1 TS 3.3 specifies the limiting conditions for operationsfor the water chemistry and coolant level specifications.PUR-1 TS 3.3 does not contain specificationsfor the reactorpool coolant system parameterslisted in ANSIIANS 15.1, Section 3.3, such as pool temperature (core cooling) or leak or loss-of-coolantdetection. Pleasepropose TS changes to meet the specification operatinglimits for the coolant system by ANSI/ANS 15.1, Section 3.3 or provide an explanation describingyour reason(s) for not incorporatingthe changes.

Page 3 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

The appropriate items from ANSI 15.1-2007, Sec. 3.3 are included in the TS 3.3, namely pH and resistivity (as suggested in 3.3(9) of ANSI 15.1), and coolant level limits (as suggested in 3.3(3) of ANSI 15.1). None of the other systems mentioned in ANSI 15.1-2007, Sec. 3.3 are applicable to PUR-1.

As determined in NUREG-1283, the Safety Evaluation Report for PUR-1, Section 14.4, "The reactor pool is designed to prevent unintentional drainage. The pool is constructed of a stainless steel liner and set in a second steel tank with the interstitial region filled with sand. The tank rests on a concrete pad about 4.6 m below the floor of the reactor room, which is in the basement of the building. The pool has no drains or coolant pipes that could open or break.

Therefore, a sudden loss of coolant is considered to be extremely unlikely. Furthermore, if the pool drained instantaneously, while the reactor was operating, the loss of water (moderator) would shut down the reactor."

The pool water level is checked at least weekly, and before every startup. And historical records of makeup water use are maintained. Substantive changes in makeup water volumes would be identified each time makeup water is added, and compared to historical data. Therefore, a leak or loss-of-coolant detection system is not required.

No changes will be made to TS 3.3.

17 TS Section 4.0: ANSI/ANS-15.1-2007, Section 4 states that for each surveillance requirement (SR), it should be specified if the surveillanceactivity can or cannot be deferred during reactor shutdown, as well as, guidancepertaining to deferred SR that must be performed priorto reactoroperations.

(a) a. Please identify those surveillances that may be deferred during reactorshutdown, and; (b) b. Identify systems and/orcomponents that requiresurveillance after any addition, modification, or maintenancebefore declaringthat system operationalin accordance with the originalspecifications to which the systems were designed and fabricated.

This is already done in TS 4.1 and 4.2. For 4.3, the following changes are made:

a. The pH of the primary coolant shall be recorded monthly, not to exceed six weeks. This cannot be deferred during reactor shutdown.

b. The conductivity of the primary coolant shall be recorded monthly, not to exceed six weeks. This cannot be deferred during reactor shutdown.

c. The reactor pool water will be at or above the height of the skimmer trough whenever the reactor is operated.

d. The primary coolant shall be sampled monthly, not to exceed six weeks, and analyzed for gross alpha and beta activity. This cannot be deferred during reactor shutdown.

19 TS 4.3. TS 4.3(d) specifies a monthly primary coolant sampling requirementfor gross alpha and beta activity. Please update the TS to indicateunder which modes of reactoroperation monthly sampling is required.Also, consider whether a correspondingLCO for this surveillanceis requiredin TS 3.3 This was already answered in the response to Q1 7. An LCO is not necessary.

Page 4 of 7 31 January 2012

PUR-1: Responses to Part of RAls dated 6 July 2011 (ML101460429) 20 TS 4.4(d): TS 4.4(d) specifies inspectionrequirements for the fuel cladding. Per the guidance of ANSIIANS-15.1-2007, fuel inspections,if appropriate,are normally included as part of reactorcore parameters(Section 3.1 / Section 4.1). Please considermoving TS 4.4(d) for inspecting fuel assemblies into a separate TS from confinement surveillance.Additionally, please identify the Section 3 LCO that establishes the minimum performancelevel for this surveillance or add an LCO, if needed.

TS 4.4.d has been moved to TS 5.2.5, as recommended in ANSI 15.1 Sec 5.3.

5.2 Fuel Assemblies 5.2.5 Representative fuel assemblies shall be inspected annually for channel blockage or plate deformation, with no interval to exceed 15 months.

22 ANSI/ANS-15.1-2007, Section 4.7.2 provides for dosimetry monitoring of effluents at the boundary of the facility and for environmentalmonitoring,e.g., sampling of soil, vegetation, or water in the vicinity of the facility. TS 6.6.1.a.4. discusses results of surveillances requiredby these TSs, but the PUR-1 TS do not appearto contain any such surveillancerequirements.

Please propose TSs to address these requirements, reference where the requirements exist, or provide an explanation describingyour reason(s) for not incorporatingthe changes.

PUR-1 is a small training reactor, and generates no effluents. The TS 6.6.1 discusses the annual report requirements, which is similar to the requirements outlined in ANSI 15.1-2007 6.7.2. The annual reports have summarized that PUR-1 releases no effluents.

24 TS 5.3. Guidance in ANSIIANS-15.1-2007, Section 5.3 states there should be requirements for periodic fuel inspectionand conditions for operation,as appropriatefor operationof the reactorwith damaged fuel. Please update the TS to establish surveillance for fuel condition and limiting conditions for operation when and if the reactorcan operate with damaged fuel (LCO) orjustify why these are not required.

A description for surveillance of the fuel condition is already provided for in 4.4.d (now 5.3.6) and 4.3.d.

Based on the long successful history of fuel integrity at PUR-1, the excellent control of water chemistry with no evidence of fuel degredation, and the fact that coolant water is tested monthly to verify fuel integrity, PUR-1 does not see an LCO for operation with damaged fuel as necessary.

29 TS 6.1.11, TS 6.1.14: ANSI/ANS-15.1-2007, Section 6.1.3(3) provides guidance for events requiringthe presence at the facility of the senior reactoroperator.Please update PUR-1 TS 6.1.11 and 6.1.14 for compliance with the requirements in ANSI/ANS-15.1- 2007, Section 6.1.3(3) and 10 CFR 50.54(m)(1) or provide an explanation describingyour reason(s) for not incorporatingthe changes.

TS 6.1.11 and 6.1.14 have been moved to the new 6.1.2 (Staffing). Item (3) reads as follows:

(3) Events requiring the presence at the facility of a senior reactor operator are (a) Initial startup and approach to power following a core change. The presence of an SRO at the reactor facility is unnecessary for the initial daily start up, provided the core remains unchanged from the previous run; (b) All fuel or control-rod relocations within the core region; Page 5 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

(c) Recovery from an unplanned or unscheduled shutdown except in instances which resulting from the following (i) A verified electrical power failure or interruption exclusive of internal power supply failures or interruption of the reactor instrumentation, control, and safety systems; (ii) Accidental manipulation of equipment in a manner which does not affect the safety of the reactor; (iii) A verified practice of the evacuation of the building initiated by persons exclusive of reactor operations personnel.

The SRO shall be notified of the shutdown and shall determine its cause. If due to one of the enumerated reasons above, he shall decide if his presence is necessary for a subsequent start up.

34 Section 5.1 Site and FacilityDescription.ANSI/ANS-15.1-2007, Section 5.1 provides guidance to provide a general descriptionof the site and facility includinglocation and exclusion areas.

Please update TS 5.1 to describe in detail which areas are under the jurisdictionof the reactor license (licensedarea) and include a descriptionof the facility location, as well as, the location of exclusion and restricted areas,as appropriate.

Section 5.1 of ANSI 15.1-2007 reads as follows:

5.1 Site Description 5.1.1 The reactor is located on the ground floor of the Duncan Annex of the Electrical Engineering Building, Purdue University, West Lafayette, Indiana.

5.1.2 The School of Nuclear Engineering controls approximately 5000 square feet of the Duncan Annex ground floor, which includes the reactor room. Access to the Nuclear Engineering controlled area is restricted except when classes are held there.

5.1.3 The licensed areas include the reactor room, and a fuel storage room. Both of these areas are restricted to authorized personnel, or those escorted by authorized personnel.

5.1.4 The reactor room remains locked at all times except for the entry or exit of authorized personnel or those escorted by authorized personnel, equipment, or materials.

5.1.5 The PUR-1 reactor room is a closed room designed to restrict leakage.

5.1.6 The minimum free volume of the reactor room is approximately 15,000 cubic feet.

5.1.7 The ventilation system is designed to exhaust air or other gases from the reactor room through an exhaust vent at a minimum of 50 feet above the ground.

5.1.8 Openings into the reactor room consist of the following:

a. Three personnel doors

b. One door to a storage room with no outside access.

c. Air intake Page 6 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

d. Air exhaust

e. Sewer vent The information requested in this question is already provided in 5.1.3.

40 TS 4.2(a) and Table Ill. The Reactor Safety System channels requiredto be tested before each reactorstartup following a shutdown in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> are provided in Table III as referenced by TS 4.2(a). The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement for this specification has no basis. Please provide adequatejustification for the 8 hourrequirement or revise the TS to be consistent with NUREG-1537, Appendix 14.1, which requires surveillanceonly if the reactoris secured (assuming the updated definitions for reactorshutdown and reactorsecured as tailoredby NUREG-1537 (see RAI 3)). The following is an example revision based on NUREG 1537, Appendix 14.1 previously found acceptableto the NRC: a. A channel test of each of the reactorsafety system channels listed in Table Ill shall be performed prior to reactoroperation:

L anytime the reactorhas been placed in a secure condition, and ii. monthly, not to exceed 6 weeks, since last channel test < LIST TABLE Ill SURVEILLANCES>

We disagree with the definitions suggested in Q3, and have modified our existing definitions slightly to be more consistent with ANSI 15.1. However, they were already similar to the ANSI 15.1 recommended definitions for "reactor shutdown" and "reactor secure".

The reactor can be placed in a secure shutdown condition by the removal of the key from the console key switch (which opens the circuit for the control rod electromagnets) without de-energizing any of the other instrumentation and control systems. This would allow for an operator to leave the room with other non-operating personnel present, then he can return and resume operations without performing a new start-up with channel tests. This is of particular importance with a small operations staff such as the one at PUR-1.

Furthermore, item (5) of NUREG 1537 Appendix 14.1 (see page 32 of Appendix 14.1) reads as follows:

"(5) Scram and Power Measuring Channels Channel tests of all scram and power measuring channels requiredby technical specifications,including scram actions with safety rod release and interlocks, should be performed before each reactorstartup following a shutdown of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or following each secured shutdown. If the reactoroperating schedule calls for no secured shutdowns, the channel tests should be performed at least quarterly."

There appears to be some disparity between NUREG 1537 and ANSI 15.1 over what secured shutdown entails. Utilizing the present definition of "reactor secured" from ANSI 15.1 (see the answer to Q3), and the reasoning described above which describes a condition where an operator may need to leave the reactor room temporarily with non-operations personnel present, we do not agree that a channel test is necessary after every such secured shutdown, and the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is sufficient. Moreover, we feel the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is justified because: (1) the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement in the PUR-1 TS is more conservative than the 24 suggested by NUREG 1537, (2) the reactor can be placed in a "secured shutdown" condition without de-energizing the I&C systems, (3) based on the operational experience at PUR-1 which indicates that the electronics are stable for periods of days. Therefore, we see no reason to make any changes.

Page 7 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

REQUESTED ADDITIONAL INFORMATION IN RESPONSE TO RAIs DATED 6 JULY 2011 (ML101460429)

REGARDING THE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594)

3. TS 1.32 and TS1.33: The Reactorsecured and Reactor shutdown definitions provided in TS 1.32 and TS 1.33 differ from the definitions the NRC has previously found acceptable. The definitions for Reactor Secured and Reactor Shutdown are provided in ANSIIANS- 15.1-2007, Section 1 as tailoredby NUREG-1537. The following are definitions, from guidance provided in NUREG 1537, Appendix 14.1, deemed acceptable:

Reactor secured:A reactoris secured when:

1. Eitherthere is insufficient moderatoravailable in the reactorto attain criticalityor there is insufficient fissile materialpresent in the reactorto attaincriticality under optimum available conditions of moderation and reflection;

2. Or the following conditions exist:

a. The reactoris shutdown, as requiredby TS 1.33, and;

b. The requirements of the reactorsecure procedureare met.

Reactor shutdown: A reactoris shutdown when the following conditions exist:

a. The minimum number of neutron absorbingcontrol devices is fully inserted or other safety devices are in shutdown position, as requiredby TS;

b. The console key switch is in the off position, and the key is removed from the lock;

c. No work is in progress involving core fuel, core structure,installed control rods, or control rod drives unless they are physically decoupled from the control rods;

d. No experiments are being moved or serviced that have, on movement, reactivity worth exceeding the maximum value allowed for a single experiment, or one dollar, whichever is smaller.

Note: For subparagraphd., a single value should be chosen to specify the smaller value of either "one dollar"or "the maximum value allowed for a single experiment." Do not specify both options in the definition.

Please evaluate PUR-1 TS 1.33 againstthe suggested definitions for Reactor secured and Reactor shutdown and propose TS changes orjustify your currentdefinitions.

The definitions for Reactor Secured and Reactor Shutdown are to be changed as follows (as suggested in ANSI 15.1-2007 with some minor modifications for operations at PUR-1, none of which change the intent):

1.32 Reactor secured: A reactor is secured when:

a. Either there is insufficient moderator available in the reactor to attain criticality or there is insufficient fissile material present in the reactor to attain criticality under optimum available conditions of moderation and reflection;

b. Or the following conditions exist:

The minimum number of neutron absorbing control devices is fully inserted or other safety devices are in shutdown position, as required by technical specifications; Page 1 of 7 31 January 2012

PUR-A: Responses to Part of RAIs dated 6 July 2011 (ML101460429) ii. Electrical power to the control rod circuits is switched off via the console key switch, and the switch key is in proper custody.

iii. No work is in progress involving core fuel, core structure, installed control rods, or control rod drives unless they are physically decoupled from the control rods; iv. No experiments are being moved or serviced that have, on movement, reactivity worth exceeding the maximum value allowed for a single experiment.

1.33 Reactor shutdown: The reactor is shut down if it is subcritical by at least one dollar in the reference core condition with the reactivity worth of all installed experiments included.

Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.

4. TS 1.36 and TS 6.6.2: ANSI/ANS-15.1-2007, Section 6.7.2 provides a schedule of events that require specialreports. The Reportable Occurrencedefinition in PUR-1 TS 1.36 that addresses these special reports does not appearto be consistent with the guidance in ANSI/ANS-15. 1-2007, Section 6.7.2. Additionally,per NUREG-1537, Appendix 14.1, TS 6.6.2 should state that special written reports should be sent to the NRC document control desk and special telephone reports of events should be made to the NRC OperationsCenter. Please propose changes to the TS or provide an explanation describingyour reason(s) for not incorporating the changes.

The definition of Reportable Occurrence is removed from the Technical Specifications, and left to T.S.

6.6.2, which brings the TS into closer alignment with ANSI/ANS 15.1 and NUREG 1537.

The following section will be added to the technical specifications:

6.6.2 Non-Routine Reports

a. Special Reports Special reports are used to report unplanned events as well as planned major facility and administrative changes. The following schedule shall be incorporated in the specifications:

(1) There shall be a report not later than the following working day by telephone and confirmed in writing by facsimile or similar conveyance to licensing authorities, to be followed by a written report to NRC Document Control that describes the circumstances of the event within 14 days of any of the following:

(a) operation with actual safety system settings for required systems less conservative than the limiting safety system settings specified in the technical specifications, (b) operation in violation of limiting conditions for operation established in the technical specifications unless prompt remedial action is taken as permitted in Sec. 3, (c) a reactor safety system component malfunction that renders or could render the reactor safety system incapable of performing its intended safety function. If the malfunction or condition is caused by maintenance, then no report is required.

Page 2 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

(d) an unanticipated or uncontrolled change in reactivity greater than 0.6%

Ak/k, (e) abnormal and significant degradation in reactor fuel or cladding, or both, coolant boundary, (f) an observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to reactor safety; Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.

7. TS Section 3.0: NUREG-1537 states the content of the TSs follow ANSI/ANS 15.1 guidance.

ANSI/ANS-15.1-2007 Section 3.5 provides specifications for the ventilation systems. Section 3 of the PUR-1 TSs does not contain Limiting Conditionsfor Operationof the Ventilation Systems as referenced by ANSI/ANS-15.1-2007. Please propose TS changes for the ventilation system limiting conditions for operations(LCOs) or provide an explanation describingyour reason(s) for not incorporatingthe changes.

The ventilation system for the reactor room is always on, except during maintenance and testing.

Maintenance and testing do not generally occur during operations.

The PUR-1 TS do contain an LCO for operation of the ventilation system, TS 3.4. The TS 3.4.a.1 was changed in response to Q1 1, and is shown here.

3.4 Confinement Applicability - This specification applies to the integrity of the reactor room.

Obiective - The objective is to limit and control the release of airborne radioactive material from the reactor room.

Specification -

a. During reactor operation the following conditions will be met:

1. The reactor room will be maintained at a negative pressure of at least 0.05 inches of water with the operation of the room exhaust fan.

10. TS 3.3: ANSI/ANS-15.1-2007, Section 3.3 provides a list of minimum operatingequipment or operatinglimits, or both, for the limiting conditions for operations for the coolant systems.

PUR-1 TS 3.3 specifies the limiting conditions for operationsfor the water chemistry and coolant level specifications.PUR-1 TS 3.3 does not contain specifications for the reactorpool coolant system parameterslisted in ANSI/ANS 15.1, Section 3.3, such as pool temperature (core cooling) or leak or loss-of-coolantdetection. Please propose TS changes to meet the specification operating limits for the coolant system by ANSI/ANS 15.1, Section 3.3 or provide an explanation describingyour reason(s)for not incorporatingthe changes.

31 January 2012 Page 33of7 Page of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

The appropriate items from ANSI 15.1-2007, Sec. 3.3 are included in the TS 3.3, namely pH and resistivity (as suggested in 3.3(9) of ANSI 15.1), and coolant level limits (as suggested in 3.3(3) of ANSI 15.1). None of the other systems mentioned in ANSI 15.1-2007, Sec. 3.3 are applicable to PUR-1.

As determined in NUREG-1 283, the Safety Evaluation Report for PUR-1, Section 14.4, "The reactor pool is designed to prevent unintentional drainage. The pool is constructed of a stainless steel liner and set in a second steel tank with the interstitial region filled with sand. The tank rests on a concrete pad about 4.6 m below the floor of the reactor room, which is in the basement of the building. The pool has no drains or coolant pipes that could open or break.

Therefore, a sudden loss of coolant is considered to be extremely unlikely. Furthermore, if the pool drained instantaneously, while the reactor was operating, the loss of water (moderator) would shut down the reactor."

The pool water level is checked at least weekly, and before every startup. And historical records of makeup water use are maintained. Substantive changes in makeup water volumes would be identified each time makeup water is added, and compared to historical data. Therefore, a leak or loss-of-coolant detection system is not required.

No changes will be made to TS 3.3.

17. TS Section 4.0: ANSI/ANS-15.1-2007, Section 4 states that for each surveillancerequirement (SR), it should be specified if the surveillance activity can or cannot be deferred during reactor shutdown, as well as, guidancepertainingto deferred SR that must be performed priorto reactoroperations.

(a) a. Please identify those surveillances that may be deferred during reactorshutdown, and; (b) b. Identify systems and/orcomponents that requiresurveillance after any addition, modification, or maintenance before declaring that system operationalin accordance with the originalspecifications to which the systems were designed and fabricated.

This is already done in TS 4.1 and 4.2. For 4.3, the following changes are made:

a. The pH of the primary coolant shall be recorded monthly, not to exceed six weeks. This cannot be deferred during reactor shutdown.

b. The conductivity of the primary coolant shall be recorded monthly, not to exceed six weeks. This cannot be deferred during reactor shutdown.

c. The reactor pool water will be at or above the height of the skimmer trough whenever the reactor is operated.

d. The primary coolant shall be sampled monthly, not to exceed six weeks, and analyzed for gross alpha and beta activity. This cannot be deferred during reactor shutdown.

19. TS 4.3. TS 4.3(d) specifies a monthly primary coolant sampling requirementfor gross alpha and beta activity. Please update the TS to indicate under which modes of reactoroperation monthly sampling is required.Also, consider whether a correspondingLCO for this surveillanceis requiredin TS 3.3 This was already answered in the response to Q1 7. An LCO is not necessary.

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20. TS 4.4(d): TS 4.4(d) specifies inspection requirementsfor the fuel cladding. Per the guidance of ANSI/ANS-15.1-2007, fuel inspections,if appropriate,are normally included as part of reactorcore parameters(Section 3.1 / Section 4.1). Please considermoving TS 4.4(d) for inspectingfuel assemblies into a separateTS from confinement surveillance.Additionally, please identify the Section 3 LCO that establishes the minimum performance level for this surveillanceor add an LCO, if needed.

TS 4.4.d has been moved to TS 5.2.5, as recommended in ANSI 15.1 Sec 5.3.

5.2 Fuel Assemblies 5.2.5 Representative fuel assemblies shall be inspected annually for channel blockage or plate deformation, with no interval to exceed 15 months.

22. ANSIIANS-15.1-2007, Section 4.7.2 provides for dosimetry monitoring of effluents at the boundary of the facility and for environmental monitoring,e.g., sampling of soil, vegetation, or water in the vicinity of the facility. TS 6.6. 1.a.4. discusses results of surveillancesrequiredby these TSs, but the PUR-1 TS do not appear to contain any such surveillance requirements.

Please propose TSs to address these requirements, reference where the requirements exist, or provide an explanation describingyour reason(s) for not incorporatingthe changes.

PUR-1 is a small training reactor, and generates no effluents. The TS 6.6.1 discusses the annual report requirements, which is similar to the requirements outlined in ANSI 15.1-2007 6.7.2. The annual reports have summarized that PUR-1 releases no effluents.

24. TS 5.3. Guidance in ANSI/ANS-15.1-2007, Section 5.3 states there should be requirements for periodic fuel inspection and conditions for operation,as appropriatefor operation of the reactorwith damaged fueL Please update the TS to establish surveillance for fuel condition and limiting conditions for operationwhen and if the reactorcan operate with damaged fuel (LCO) orjustify why these are not required.

A description for surveillance of the fuel condition is already provided for in 4.4.d (now 5.3.6) and 4.3.d.

Based on the long successful history of fuel integrity at PUR-1, the excellent control of water chemistry with no evidence of fuel degredation, and the fact that coolant water is tested monthly to verify fuel integrity, PUR-1 does not see an LCO for operation with damaged fuel as necessary.

29. TS 6.1.11, TS 6.1.14: ANSI/ANS-15.1-2007, Section 6.1.3(3) provides guidance for events requiringthe presence at the facility of the seniorreactoroperator.Please update PUR-1 TS 6.1.11 and 6.1.14 for compliance with the requirements in ANSI/ANS-15.1- 2007, Section 6.1.3(3) and 10 CFR 50.54(m)(1) or provide an explanationdescribingyour reason(s) for not incorporatingthe changes.

TS 6.1.11 and 6.1.14 have been moved to the new 6.1.2 (Staffing). Item (3) reads as follows:

(3) Events requiring the presence at the facility of a senior reactor operator are (a) Initial startup and approach to power following a core change. The presence of an SRO at the reactor facility is unnecessary for the initial daily start up, provided the core remains unchanged from the previous run; (b) All fuel or control-rod relocations within the core region; Page 5 of 7 31 January 2012

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(c) Recovery from an unplanned or unscheduled shutdown except in instances which resulting from the following (i) A verified electrical power failure or interruption exclusive of internal power supply failures or interruption of the reactor instrumentation, control, and safety systems; (ii) Accidental manipulation of equipment in a manner which does not affect the safety of the reactor; (iii) A verified practice of the evacuation of the building initiated by persons exclusive of reactor operations personnel.

The SRO shall be notified of the shutdown and shall determine its cause. If due to one of the enumerated reasons above, he shall decide if his presence is necessary for a subsequent start up.

34. Section 5.1 Site and FacilityDescription.ANSI/ANS-15.1-2007, Section 5.1 provides guidance to provide a generaldescription of the site and facility including location and exclusion areas.

Please update TS 5.1 to describe in detail which areas are under the jurisdictionof the reactor license (licensed area) and include a description of the facility location, as well as, the location of exclusion and restrictedareas, as appropriate.

Section 5.1 of ANSI 15.1-2007 reads as follows:

5.1 Site Description 5.1.1 The reactor is located on the ground floor of the Duncan Annex of the Electrical Engineering Building, Purdue University, West Lafayette, Indiana.

5.1.2 The School of Nuclear Engineering controls approximately 5000 square feet of the Duncan Annex ground floor, which includes the reactor room. Access to the Nuclear Engineering controlled area is restricted except when classes are held there.

5.1.3 The licensed areas include the reactor room, and a fuel storage room. Both of these areas are restricted to authorized personnel, or those escorted by authorized personnel.

5.1.4 The reactor room remains locked at all times except for the entry or exit of authorized personnel or those escorted by authorized personnel, equipment, or materials.

5.1.5 The PUR-1 reactor room is a closed room designed to restrict leakage.

5.1.6 The minimum free volume of the reactor room is approximately 15,000 cubic feet.

5.1.7 The ventilation system is designed to exhaust air or other gases from the reactor room through an exhaust vent at a minimum of 50 feet above the ground.

5.1.8 Openings into the reactor room consist of the following:

a. Three personnel doors

b. One door to a storage room with no outside access.

c. Air intake Page 6 of 7 31 January 2012

PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)

d. Air exhaust

e. Sewer vent The information requested in this question is already provided in 5.1.3.

40. TS 4,2(a) and Table Ill. The Reactor Safety System channels requiredto be tested before each reactorstartup following a shutdown in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> are provided in Table Ill as referenced by TS 4.2(a). The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement for this specification has no basis. Please provide adequatejustification for the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement or revise the TS to be consistent with NUREG-1537, Appendix 14.1, which requires surveillance only if the reactoris secured (assuming the updated definitions for reactorshutdown and reactorsecured as tailoredby NUREG-1537 (see RAI 3)). The following is an example revision based on NUREG 1537, Appendix 14.1 previously found acceptableto the NRC: a. A channel test of each of the reactorsafety system channels listed in Table Ill shall be performed priorto reactoroperation:

i. anytime the reactorhas been placed in a secure condition, and ii. monthly, not to exceed 6 weeks, since last channel test < LIST TABLE III SURVEILLANCES>

We disagree with the definitions suggested in Q3, and have modified our existing definitions slightly to be more consistent with ANSI 15.1. However, they were already similar to the ANSI 15.1 recommended definitions for "reactor shutdown" and "reactor secure".

The reactor can be placed in a secure shutdown condition by the removal of the key from the console key switch (which opens the circuit for the control rod electromagnets) without de-energizing any of the other instrumentation and control systems. This would allow for an operator to leave the room with other non-operating personnel present, then he can return and resume operations without performing a new start-up with channel tests. This is of particular importance with a small operations staff such as the one at PUR-1.

Furthermore, item (5) of NUREG 1537 Appendix 14.1 (see page 32 of Appendix 14.1) reads as follows:

"(5) Scram and Power Measuring Channels Channel tests of all scram and power measuring channels required by technical specifications, including scram actions with safety rod release and interlocks, should be performed before each reactorstartup following a shutdown of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or following each secured shutdown. If the reactoroperatingschedule calls for no secured shutdowns, the channel tests should be performed at least quarterly."

There appears to be some disparity between NUREG 1537 and ANSI 15.1 over what secured shutdown entails. Utilizing the present definition of "reactor secured" from ANSI 15.1 (see the answer to Q3), and the reasoning described above which describes a condition where an operator may need to leave the reactor room temporarily with non-operations personnel present, we do not agree that a' channel test is necessary after every such secured shutdown, and the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is sufficient. Moreover, we feel the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is justified because: (1) the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement in the PUR-1 TS is more conservative than the 24 suggested by NUREG 1537, (2) the reactor can be placed in a "secured shutdown" condition without de-energizing the I&C systems, (3) based on the operational experience at PUR-1 which indicates that the electronics are stable for periods of days. Therefore, we see no reason to make any changes.

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