ML14259A336

Response to NRC 4-1-2014 RAI (ML14036A319) Regards Psu Breazeale Reactor (R-2) License Amendment Request(ML12040A166)

ML14259A336
Person / Time
Site:	Pennsylvania State University
Issue date:	09/19/2014
From:	Sharkey N Pennsylvania State Univ, University Park, PA
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14259A336 (45)

Text

PEN NSTATENeil A. SharkeyInterim Vice President for ResearchThe Pennsylvania State University304 Old MainUniversity Park, PA 16802814-865-6332Fax: 814-863-9659nas9@psu.eduwww.research.psu.eduUSNRC Document Control DeskDocket 50-005Response to NRC 4-1-2014 RAI (ML14036A319) Regards PSU Breazeale Reactor (R-2) License Amendment Request(ML12040A 166)

Dear Sir/Madame:

Attached please find the response to the request for additional information (RAI) issued 4/1/14 regarding the 2/7/12license amendment request (LAR) for the Penn State Breazeale Reactor R-2 license.Also attached is revised license wording that reflects the results of the ongoing review process and a TechnicalSpecification (TS) change listing document detailing each change requested. This submittal supersedes the previousdetailed TS submittal in its entirety.Please exempt this request from fees per IOCFRI70.1 .a.( 4)If there are any questions regarding the information submitted, please contact Mr. Mark A. Trump, Associate Director forOperations.I declare under penalty of perjury that the foregoing is true and correct.Executed onSincerelyýel NOTARY PUBLICState of: '? Subscribed and sworn before dayon this d 2014Co n y o:Notary Publicf2 1Coun oMy cormnsineprs ResearchAttachments:RAI (ML14036A319) responseTechnical Specification Change Summary TablUpdated Technical Specifications PagesCt)MMONWEALTH OF PENNSYLVANIAINotarial SealLord L. Sornsky, Notary PublicState College Boro, Centre CountyMv Commission Exolres Nov. 15. 2016W

• wCC -emailAlexander Adams -NRCXiaosong Yin -NRCOssy Font- NRCR-2 NRC correspondence FileC);-)VA ýp PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES1. TS 3.3.3, "an air particulate monitor" was used in reference to the fission productactivity monitoring. In Table 3 of TS 3.6.1, a "continuous air (radiation) monitor" wasused as one of the radiation monitoring channels. Clarify if they are the same monitorand the purpose of these monitors. Revise your proposed TS as required.The "continuous air" and "air particulate" monitor requirements are the same monitor withredundant operability requirements in the two referenced technical specifications.In light of the continued confusion the existence of two specifications for the same monitor hasgenerated in the review process, it becomes apparent that the decision to modify TS 3.3.3 asopposed to request deletion (as discussed in the previous RAI (ML12346A349) response #3and suggested in phone conference) was ill-advised.PSU requests, via this response, that TS 3.3.3 Fission Product Activity be deleted in its entirety.The Justification for this request is the requirement for air particulate monitor and evacuationalarm is duplicated in TS 3.6.1 Radiation Monitoring Information. Refer also to the previous RAI(ML12346A349) response #3. The Benefit is reduced duplication in the licensing requirementsthat have developed over the years since implementation of Technical Specifications andreduced confusion over the specifications and system. The licensing requirements at PSBR willbe comparable to other 1 MW TRIGA pool reactors demonstrating consistent licensing process.Safety Impact -Removal of TS 3.3.3 has no impact on the health and safety of the public orfacility workers because the specification is redundant to other specifications. The requirementthat a fission product (particulate) monitor be operating whenever the reactor is operating iscontained in TS 3.6.1 and the requirement for a functioning evacuation alarm system iscontained in TS 3.6.2. The operability of the monitor has no impact on the probability of arelease and the consequences of a release are clearly bounded by the PSU Safety AssessmentReport (SAR) chapter 13 Maximum Hypothetical Accident (MHA). The basis for 3.6.1.a isadjusted to reflect that fission product monitoring is part of the function.2. In TS 3.4, you have rewritten the section and replaced it with the proposed TS 3.4.Provide detailed justification for the proposed changes.In light of the concerns raised during the review process on the proposed revision to TS 3.4,PSU withdraws the requests for replacement of TS 3.4 and its linked surveillance TS 4.4. PSUrequests a small scope revision of TS 3.4.a specification from reactor "is not secured" to "isoperating". Justification: This minor wording change aligns the specification with thespecification objective and the guidance given in ANSI/ANSI5.1 Technical Specifications forResearch Reactors 2007. The Benefit of this change is the avoidance of a TS LCO violationduring shutdown conditions where concurrent maintenance often occurs that might result in thereactor bay door being opened while the reactor key is inserted to perform instrumentationchecks. Safety Impact -since TS will continue to require the reactor be shutdown wheneverthe reactor bay door is open, there is no impact on the safety to the operators or the public.Page 1 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESSpecifically, respond to the following:a) Define the "low pressure confinement boundary (LPCB)".b) Describe the relationship between the LPCB and the confinement that is definedin the current PSU TSs?Request for LPCB is withdrawn.c) Describe how the LPCB is established, including a discussion of the materialsrequired, how they will be put in place, and what instruction is provided forestablishing the boundary.Request for LPCB is withdrawnd) Clarify if there will be surveillance in place associating with this LPCB.Request for LPCB is withdrawne) Describe how this proposed LPCB meets the performance requirement asspecified for a confinement and is consistent with the definition in TS 1.1.8.Request for LPCB is withdrawnf) Describe the time needed to re-establish a confinement for the reactor bay when aconfinement as defined in TS 1.1.8 is lost and describe how to verify theoperability of the LPCB.Request for LPCB is withdrawng) Evaluate the impact of an emergency or accident situation on the methodologyused for establishing a LPCB and the effectiveness of the LPCB.Request for LPCB is withdrawnh) Describe the potential radiological impact to the personnel establishing the LPCBand others affected by the lack of confinement, until the end of the time it takes toestablish a temporary confinement boundary, during accident conditions.Request for LPCB is withdrawni) In this proposed TS, it also stated that "[L]arge penetrations SHALL NOT exist" tothe reactor bay during reactor operation. Explain how this proposed TS issatisfied when the reactor bay heating ventilation air conditioning and exhaustsystem (RBHVES) is in service since the confinement isolation dampers representa large air passage to the reactor bay.The request to address large penetrations in TS 3.4 is withdrawn, however the question is stillrelevant. With the RBHVES in service, the system is part of the confinement enclosure anddoes not represent a large opening. This is essentially same configuration as the existingFacility Exhaust Fan (FES) and Emergency Exhaust (EES) ducts and dampers. During an"accident" the system is secured and the dampers automatically close isolating the penetrationsand duct work similar to the current FES damper operation.Page 2 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESj) Describe why the additional open dampers, running fans, and connections tooutside air related to the RBHVES do not compromise the objective of TS 3.4 andcontinues to satisfy the basis to ensure that the air pressure in the reactor bay islower than the remainder of the building and the outside air pressure.Relative negative pressure is a consequence of exhaust fan operation, restrictions caused bybuilding structure on inlet air flow, dynamic wind loading on the building, and attached buildingventilation status.The penetrations and ductwork added by RBHVES are similar in size to the existing roof fanpenetrations that communicate directly with outside air. The existence of the ductwork, filters,and enthalpy wheel have the characteristic of slightly restricting flow if the dampers are openand all fans are shutdown. The new dampers are an active component more positively closedby an actuator as opposed to FES dampers which rely on relative barometric pressure(backflow) and gravity to operate. With the ventilation fans operating as designed, the ductworkbecomes part of the confinement controlled air movement path and is consistent with thedefinition of confinement. During an evacuation, this path is isolated from the remainder ofconfinement by design (Confinement isolation dampers close). The failure of the system toisolate is bounded by the MHA and does not create a new event. Multiple simultaneous failuresduring an MHA event such as exhaust fan off, dampers fail open and supply fan keeps runningare not credible. Even if a non-credible failure were to occur the RBHVES exhaust is the sameas the FES and EES, no new event or release path or scenario is created. Commissioningtesting of the system was completed to ensure that air flow balance results in more exhaustthan makeup therefore fulfilling the definition of confinement. As with the existing system,failure of a running fan may require remedial action by the operator to prevent TS LCO violation.(see also RAI 9 and 1 O.d response for a discussion of the consequences of non-negative airpressure conditions).3. Additional information is needed for TS 3.5. Respond to the following:a) Provide an analysis supporting your justification to extend the reactor operationtime from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 30 days without an emergency exhaust fan. In Section 13.1.1of PSU's current Safety Analysis Report (SAR), a credit has been taken to evaluatethe radiological consequence using a stack release dilution. When this stackrelease credit can no longer be taken due to the fact that there is no operableemergency exhaust fan available, what is the radiological consequence? Show acalculation to support your justification. (see Regulatory Guide 1.145"Atmospheric Dispersion Models for Potential Accident ConsequenceAssessments at Nuclear Power Plants," Revision 1, for an example of a methodacceptable to the NRC staff).The analysis of the Maximum Hypothetical Accident (MHA) in Chapter 13 of the PSU SAR doesnot take credit for an elevated stack release or the filtration provided by the emergency exhaustsystem. The analysis is a ground level release with no plume, weather conditions or dispersionof the release when calculating the dose at the boundary (facility restricted area fence). Theanalysis assumes only dilution by mixing in the cross-sectional area of the reactor building withlow velocity wind (1 M/sec) and in-situ decay after the fuel failure (after t=0). The accidentrelease (failure of a hot operating fuel element in air) analysis is designed to provide the worstcase release of airborne fission products to the un-restricted area without credit for partitioning,plate out, capture in filters, or dispersion. No credible mechanism to accomplish a release of thisPage 3 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESmagnitude from the fuel has been devised. The MHA does not consider direct radiation (shine)from the fuel element in air or released products remaining in the reactor bay.The extreme conservatisms of the PSU MHA calculation include:* The fuel element is assumed to operate at the maximum steady state power of 24.7 kW(provides an unrealistically high fission product inventory) for an extended period." The surface of the fuel is unrealistically assumed to be operating at the LSSS value of650 C when the release occurs. (maximizes release fraction) as opposed to a morerealistic 200 C." The element fails in air (no credit for water capture of the operating fuel element release)* All gap fission products are released (no retention, plate out or capture of noble gases orhalogens)* Instantaneous mixing in a conservative volume for the reactor bay free air space.With the EES inoperable, leak rate from the confinement is reduced allowing more decay inplace and plate out of fission products on material in the confinement. Fission product leak ratewould be driven by dynamic building pressure (wind loading) and attached buildings operatingventilation systems. A lower release rate will reduce the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> calculated exposure to thepublic due to released fission products in all cases.The conclusions reached in NUREG CR2387 Credible Accident Analyses for TRIGA andTRIGA-Fueled Reactors although dated are noteworthy. NUREG CR2387 states for operatingreactor fuel failure event:Swelling of the fuiel could lead to cladding rupture and release offission product activity intothe pool. The radiological consequences of such a release would in general be confined tothe immediate vicinity of the reactor. Even assuming the relatively large release fr-action of10-4, offsite, lifetime, whole body dose equivalents would not exceed 1 mrero, mostly fromnoble gases. Radio-iodines and other fission products would be largely retained in the pool,and the dose equivalents to critical organs of offsite observers would be insignificant--i, e.,less than the one millirem value de minimnis guidance level adopted at DOE sites.And, for the more likely fuel handling events:The calculated dose equivalents are extremely conservative and thus represent an extremeupper limit. if such an accident occurred, exposure levels would more realistically be one toseveral orders of magnitude lower. Hence, even under the worst of circumstances, thepotential exposure to personnel outside the facility from any credible fuel-handling accidentwould be small and of little or no health significance. Whole body and thyroid life-time doseequivalents are well within those put forth by regulatory requirements or by international bodiesconcerned with radiation protection (ICRP 1977, 1978; NCRP 1971, 1975, 1976).Additionally, a comparable facility (1 MW stainless steel clad TRIGA) demonstrated in licensesubmittals using slightly more realistic assumptions much lower public and worker exposurefrom a release than the PSU analysis (reference Chapter 13 Oregon State University (OSU)SAR). The OSU TRIGA analyses show that the confinement is wholly unnecessary to meet the10CFR20 unrestricted area effluent limits during their MHA. At the OSU TRIGA, TS require theexhaust systems be secured to reduce public exposure during a release event and no TSrequirement for a confinement is specified in the OSU license.Page 4 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESSince the methodologies described in Reg Guide 1.145 are methods to dilute and disperse therelease and since the PSU assumes no dilution or dispersion, the PSU SAR is moreconservative than Reg Guide 1.145 and clearly bounds any credible scenario making additionalanalysis un-necessary and un-warranted.b) Identify radiation release pathway(s) if none of the exhaust fans are operable.The leakage paths would be out of the reactor bay into the attached buildings and theenvironment through air gaps in the confinement enclosure. The leak rate would be less than ifthe fans were operating and the result of the dynamic and static pressure differences caused bythe wind or adjacent buildings ventilation systems. The sum of all these pathways and the slowrelease rate would further dilute the release and allow more time for decay resulting in areduction in the MHA assumed dose to the public in the unrestricted area.c) Calculate the radiation consequence to the nearest receptor if none of the exhaustfans are operable for normal and post-accident conditions.NORMAL Operations: As described in the PSU SAR Section 6 Engineered Safety Features, areactor bay exhaust fan is operated to minimize the buildup of any airborne radioactive materialand gases resulting from reactor operation. During routine operation with no exhaust fans inoperation, any airborne material and gases previously diluted by the continuous flow of fresh airwill begin to accumulate. The SAR elaborates that Ar4' is the only gas that presents anaccumulation issue. Gases may also slowly migrate to other areas of the facility due to changesin air flow patterns. TS 3.6.1 Radiation Monitoring requires operable airborne particulate andradiation monitors whenever the reactor is operating During normal operations with an exhaustfan, Ar4l is barely detectable in the reactor bay (MDA -3E-7 uCi/ml). Per 10CFR20 App C, Ar4'is a submersion class whole body exposure for the occupational exposure (DAC limit) of 3E-6pCi/ml for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />. Significant levels cannot accumulate in the proposed one hour remedialaction time limit. And if levels were somehow to accumulate, the reactor bay radiation monitorswould again alert the operators to the developing hazard. Note per TS 3.5.b the moving of fuelor a fueled experiment is not authorized without an exhaust fan operating. Please refer to theresponse to Question 4 of the previous RAI (ML12346A349).POST-ACCIDENT: For the MHA the normal exhaust fans automatically shut down. With nofans operating, the dose predictions in the unrestricted area approach zero as the release rateapproaches zero in any calculation. The release rate will not reach zero because dynamic airpressure (from wind) will result in some air exchange with the confinement. See 3.a), b) aboveand PSU SAR Section 13 for the assumptions built into the SAR MHA.Any additional calculation using reduced flow rates is bounded by the existing MHA, so furthercalculations are unnecessary to evaluate the impact of the release on the health and safety ofthe public.d) Specify who will be directly exposed (worker and general public) if an emergencyoccurs and there is no emergency exhaust fan operable.Personnel inside the reactor bay or inside the restricted area of the facility: Theemergency exhaust fan is normally secured. EES starts automatically on Evacuation alarmactuation as described in existing and proposed TS 3.5 basis. When the evacuation alarmsounds personnel are required to exit the facility. The SAR MHA assumes it takes one minutePage 5 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESfor operators to exit the reactor bay. There is no appreciable decrease in radio-nuclideconcentration in the first minute of an event due to exhaust flow. Therefore, personnel exitingthe reactor bay will receive essentially the same exposure whether or not the exhaust system isoperable.General public at the boundary of the restricted area: Without a start of the emergencyexhaust fan, the release rate will be lower than the value assumed in MHA. With a lowerrelease rate the public will receive a lower exposure than that outlined in the PSU chapter 13SAR MHA as discussed greater detail in response to Question 4 of the previous RAI(ML12346A349). With no exhaust fan operable, dose to the public is reduced. For comparablefacilities (RTRs) without filtered exhaust systems, the exhaust system is secured by TSrequirement during a release event to reduce offsite exposure. With no operable EES, thisfacility will respond as most other comparable licensed facilities do, normal exhaust is secured,and radionuclides decay in place with slow confinement leakage driving offsite dose,e) Calculate potential maximum exposure during a movement of irradiated fuel or afueled experiment when the fuel ruptured in the air and there are no exhaust fansoperable. Use the maximum possible time period for this calculation from thediscovery of the fuel rupture to the time when personnel were evacuated from thereactor under the assumption that there are no operable exhaust fans. Comparethis potential maximum exposure to the scenario where fuel movement isimmediately stopped after the discovery of no operable exhaust fans at thereactor bay.This question appears to be a result of a misunderstanding of the requested TS revision. Thereis no change in the requirements for ventilation operations during fuel movement. Actualreleases from a fuel failure underwater (at ambient temperatures) during fuel movement will benegligible or undetectable as described in NUREG CR2387 Credible Accident Analyses forTRIGA and TRIGA-Fueled Reactors. The same can be said for TS allowed fueled experimentswhere the failure occurs in the reactor pool.The following simple calculation is offered to address the question of additional operatorexposure time during the existing Chapter 13 MHA.Calculation Assumptions:" No exhaust* PSU SAR MHA event (un-partitioned air release of available fission products from a6500C fuel operated at sustained 24.7 kW, instantaneous mixing in reactor bayatmosphere)* No direct (gamma/neutron) exposure from the fuel element (only from released activity)From Chapter PSU SAR 13.1.1" An operator in the reactor bay will accumulate occupational exposure during the initialevent sequence at 1038 mR/minute. (before exhaust or decay lowers the exposure rate)" It takes no more than 1 minute to evacuate the bayFrom experience, it takes a calm skilled operator approximately 30 seconds to 1 minute to storea fuel element in an immediately available underwater rack or core location.Assume* 2 minutes to store fuel element (2 to 4 times normal)Page 6 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES* 30 seconds to store fuel tool0 1 minute to leave reactor bay.3.5 minutes

• 1038 mR/minute = 3633 mR TEDEAs mentioned in response to RAI Question 3, the PSU MHA assumptions are highlyconservative. A slightly more realistic but still conservative number can be taken from the samescenario at the Oregon State University TRIGA reactor SAR (Table 13-9). A five minuteexposure (without exhaust fans) to a reactor room occupant yields a calculated TEDE of 26 mRduring a MHA.The question also asks to compare this exposure to an exposure where "fuel movement isimmediately stopped." There is no practical difference between immediately stopped and"complete the fuel movement in progress." Fuel handling is performed with hand held tools.The operator will immediately stop fuel movement on a reactor bay radiation alarm (by safelystoring the fuel using the fuel handling tool). Therefore the exposure during a MHA levelrelease for an "immediate stop" is the same as described above.f) Describe how the confinement negative pressure is being monitored and is theloss of negative pressure immediately obvious to the reactor operator at thecontrols?Negative pressure is a consequence of exhaust fan operation. Historically, FES damperposition was the indicator of fan running status available to the operator (this indication remainsavailable for the roof fans). No pressure monitoring was provided and negative pressure wasan implied characteristic of fan operation and confinement construction.RBHVES has added supply and exhaust damper status (not closed) light and negative pressurestatus (greater than -0.01 inch water on the least negative of 3 sensors) as a simple operatoraid during normal operation.Since there is no consequence of a loss of negative pressure, there is no need for the loss ofnegative pressure to be "immediately obvious." The indicating light is visible to the reactoroperator from the control room and currently, the status of building negative pressure is checkedduring hourly logs when operating.g) What is the maximum potential radiological consequence when considering thecombination of this proposal, which will allow 30 day reactor operation without anemergency exhaust fan and the extended 1-hour operation without any operableexhaust fans, with the proposal in TS 3.4, which will allow a LPCB to beestablished to re-establish a confinement?Since the concept of a LPCB has been abandoned (see RAI question #2 response), only the 30day EES and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> FES time clocks will be addressed.The maximum potential radiological consequences are bounded by the assumptions of the SARMHA.* The MHA source term is highly inflated by the power history, Fuel temperature, releaseand partitioning assumptionsPage 7 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES" The MHA disperses the entire source term uniformly into the reactor bay volume withoutremoval by water or plate out on building components." The EES (or the FES or RBHVES or any other driver) drives an unfiltered groundrelease* The release is mixed and diluted in the leeward area of the building by the 1 m/sec windspeed assumption, no further dilution is assumed" The source term components decay during the duration of the release." Shine is not considered in this release exposure calculation.Since dilution is fixed by the MHA assumptions, integrated dose at the boundary of therestricted area is influenced only by the release rate. Decreasing the release rate (CFM fromthe fan) reduces integrated dose by allowing for more decay in place of the source radio-nuclei.Increasing the exhaust rate can have a slight effect on the integrated dose (92% of which isaccumulated in the first hour of the MHA).With these concepts in mind, let us evaluate the impact of each of the conditions:* No EES fan results in a release driven only by atmospheric conditions (leakage). Sinceno filtration is assumed to occur with the EES, a reduced release rate allows more timefor decay in the reactor bay and integrated dose to the public at the restricted areaboundary is reduced.* 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> operation with no operable exhaust fan will result in result in buildup of Ar41 in thereactor bay. Storing the Ar41 and allowing decay in the reactor bay reduces publicexposure. Additionally since the Ar41 would have been released without mitigation to thepublic, its contribution to public dose is already accounted for and reported as part ofroutine operation. The facility generates less than 10% of the annual release limits.Integrated dose to the public in the unrestricted area is unaffected or reduced as a resultof no exhaust fan.None of the conditions presented in the question increase the source term of the MHA. In theexisting MHA calculation, only release rate affects dose rate in the unrestricted area becausethe calculation assumes some decay in place of radio-nuclei. From the PSU SAR MHA (pg.XIII-32):The activity is removed rapidly from the reactor bay and about 92% of the TEDE in theunrestricted area is received in the first hour. Essentially all activity has been released to theunrestricted area within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and doses in both the reactor bay and the unrestricted areahave reached their maximun values. Release of the activity from a fuel element over an extendedperiod of timne would reduce the dose because of the decay of short half-life radioisotopes beforerelease.Note for the integrated dose in the unrestricted area, any factor slowing the release from theconfinement (example no exhaust fans) will reduce dose because of in-situ decay.Page 8 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES4. Section 7.3.1.3 of the SAR lists reactor console digital control computer (DCC-X)generated scrams. Two of these scrams, "Reactor Bay Truck Door Open" and "Both Eastand West Facility Exhaust Fans Off" help ensure the confinement pressure boundary ismaintained. Will these scrams remain in place and are any additional scrams beingdeveloped to support operation of the RBHVES?The DCC-X computer provides user features and scrams from auxiliary input ports of the inputoutput (1/0) system. A more accurate purpose of these scrams is "to minimize the possibility ofan operator induced LCO violation by preventing reactor reset." The FES fan off scram will beeliminated with the incorporation of the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> remedial action specifications in TS 3.5.a.Currently the facility runs both fans to ensure that scrams do not occur. This will help reducespurious reactor scrams and save energy. Since operation of the reactor with the reactor dooropen remains prohibited, no plans are in place to remove the reactor bay truck door scram atthis time. No additional scrams for the RBHVES system are anticipated.5. Your response No. 2 to NRC's RAI dated January 7, 2013, and the revised PSU SARChapter 6, described most of the components in the RBHVES system. There are severalcomponents on Figure 6-1 that have not been adequately described:a) Provide additional details to the purpose of the economizer air damper and therelief damper.In the design of the RBHVES, for energy efficiency under certain weather conditions, aneconomizer mode was included. In the economizer mode, the 2 existing roof fans are startedand the economizer air damper is opened to provide makeup air without the need for airconditioning. As long as the reactor bay is negative relative to the ambient pressure, air will bedrawn in the makeup air damper to replace air removed by the roof fans. This mode ofoperation (when enabled) is anticipated to save cooling cost under certain ambient airconditions to comply with energy efficiency standards and codes.The relief damper is present to provide duct work protection from the dynamic load caused bythe rapid closure of the confinement isolation dampers. To simplify the reliability of the interfacebetween the RBHVES control system and the emergency evacuation system, the onlycommunication is through a set of auxiliary contacts on a multiplier relay in the emergencyevacuation system. When the evacuation system is actuated, an evacuation system relayopens contacts that interrupt power from the RBHVES system to the confinement damperactuators. Without power, the dampers fail to the closed position. The RBHVES digital logicsenses the damper power interruption and trips the exhaust, supply, and recirculation fans andopens the relief damper.b) On Figure 6-1, the gravity backdraft dampers, makeup air damper, economizermakeup air damper, and relief damper (dampers) are designated as normallyclosed. Describe the conditions when these dampers would be open.The gravity backflow dampers are open whenever the associated roof fan is in operation. Thegravity backflow dampers are opened by barometric action (negative pressure/flow forces) thatexist when the FES fans operate. See answer 5 above for the economizer and relief damperoperation.Page 9 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESc) The economizer air and relief dampers appear to communicate with outside air;describe the location of the intake or discharge point for this flow path.The economizer air and relief dampers are located on the roof of RSEC west wing (laboratorywing attached to and west of the reactor bay). The dampers communicate with the outside airat this intermediary roof height of about 15 feet above the reactor bay floor.d) No back draft dampers are shown for either one of these normally closeddampers, which means that the air can flow in either direction. Are these intendedrelease points, and if so, what is the elevation for the release? If they are notintended to be a discharge point, what prevents air flow in the dischargedirection?As with the FES roof fan dampers, when the dampers are open, air could flow in either directionbased on local static and dynamic pressures. When the dampers are closed only minor leakage(in or out) can occur. The RBHVES economizer and relief dampers are not intended releasepoints and nothing other than damper position and relative pressures prevent flow. Theelevation of these dampers is approximately 15 feet above the reactor bay floor referenceelevation. When the system is shutdown, the confinement dampers isolate these dampers fromthe confinement. With the system operating, the relief damper is closed; the economizer maybe open as described in 5.a) above. It would take multiple failures to have these dampers actas a release path during an accident, and leakage or release through this path is of noconsequence during normal operations since the same unfiltered air is discharged to theenvironment at essentially the same location. (see also RAI answer to 3.c and 9.e)e) Are these normally closed dampers positively controlled (i.e., locked closed) or istheir position controlled only via the RBHVES controls?The position is only controlled by the RBHVES digital control system.6. In the proposed TS 3.6.2, respond to the following:a) Specify the time limit on how long the evacuation alarm could remain out ofservice. The proposed language would allow the facility to not have an automaticalarm for an unspecified period, providing the facility announcement system is"verified" to be working.The local automatic annunciators on the radiation monitors in the monitored areas and thereactor control computer will still function to automatically alert the workers and the operators toany hazardous condition. This is the normal license requirement at other facilities. There is notechnical basis to require a facility wide evacuation system. Existing Fire safety building codesrequire the fire alarm systems be immediately returned to service, but no time clocks arespecified. The facility finds no regulatory or public health and safety basis for an additionalrestriction in technical specifications. However to address this NRC concern, a 30 day time limiton alternate alarm use is added to TS 3.6.2.Page 10 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESb) Describe the impact to the operator actions when the alarm is not operable andother means must be utilized to notify facility personnel for the need to evacuate.Specifically address the potential to delay the operator from exiting the reactorbay following an elevated radiation level condition and the related doseconsequence.With the evacuation audible alarm inoperable, the on-watch RO or SRO will makeannouncement using the public address system from the control room or any phone handset toevacuate the building. This is the same expectation that exists for events that do notautomatically actuate the evacuation system. During an accident with no evacuation alarm, thetime to evacuate the bay or transit from the control room through the reactor bay would not beaffected as there is no phone handset in the reactor bay for an operator to delay exit whilemaking an announcement. Worst case dose in the reactor bay during the MHA is provided inPSU SAR Chapter 13 and the additional fuel handling scenario requested in 3.e above.7. Provide detailed technical justification for the removal of TSs 3.6.3 and 4.6.2 regardingthe Argon-41 (Ar-41) concentration limit and monitoring. Specifically, respond to thefollowing:Penn State withdraws the request for deletion of TS 3.6.3 and 4.6.2 at this time.a) Are there other normally released isotopes that will have a health and safetyimpact being discharged from the facility operation?Penn State withdraws the request for deletion of TS 3.6.3 and 4.6.2 at this time.b) If there are other isotopes, evaluate the scenario where Ar-41 is the only effluentrelease versus when there are other isotope effluent releases from the reactoroperation.Penn State withdraws the request for deletion of TS 3.6.3 and 4.6.2 at this time.Page 11 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES8. The current TS 4.6.1 requires that the facility radiation monitors and the evacuationalarm system "SHALL be channel tested monthly not to exceed 6 weeks. They SHALL beverified to be operable by a channel check daily.... and SHALL be calibrated annually,not to exceed 15 months." In the proposed TS 4.6.2, the only requirement for theevacuation alarm is that "the evacuation alarm SHALL be verified audible annually not toexceed 15 months." Respond to the following to address the differences between thecurrent TS and proposed TS in relating to the facility's evacuation alarm's operability:General Discussion:The TS 3.6.1 prescribed radiation monitors are 3 of 7 radiation monitor inputs to the DCC-Xcontrol computer. When DCC-X is operating, the DCC-X high alarm setpoint on any one of themonitors (that are not in bypass) or a manual pushbutton will initiate a reactor scram, FESshutdown, RBHVES damper closure, EES start and evacuation horn via the building publicaddress system. The evacuation "system", including the manual pushbutton, is a softwarefunction of DCC-X.The current TS 4.6.1 combines the surveillance requirements of the radiation monitors with thatof the evacuation alarm. This is not a technically valid concept.The daily "channel check" for a radiation monitor channel is a well-established non-intrusiveconcept defined in TS and the industry but is an unclear requirement for the evacuation systemsoftware. The facility interprets this as a requirement to actuate the evacuation system daily,cycling the fans off and on and disrupting the facility, police, nearby buildings and passersbywith sounding of the evacuation horn.The monthly "channel test" again is a well-established concept defined by TS for the radiationmonitors and includes operability testing of the function to initiate an evacuation. The horn andfans are cycled multiple times for the testing of the seven radiation channels. Channel test isinterpreted at the facility as another actuation test of the evacuation system accomplishedduring the channel test of the radiation monitors.The annual calibration is defined by TS for the radiation monitor channels but has no applicationto the evacuation system.The result of the combination of the testing requirements of radiation monitors and evacuationalarm in the same surveillance specification has been excessive testing of the buildingevacuation horn, unnecessary wear of the fan systems and components, and complacency onthe part of building occupants to the evacuation horn. As described in the amendmentsubmittal, the planned incorporation of the evacuation horn into the life safety (fire alarm)system improves reliability and makes the current modes and frequency of testing unfeasible.Separation of the audible horn from the radiation monitor requirements is necessary for thisupgrade.a) What constitutes an evacuation verify protocol?Currently, the evacuation alarm verification is done daily by audible horn sounds. Theverification of the audibility of the horn is checked on the monthly radiation monitor channelcheck as the horn is sounded multiple times, and following maintenance on the systems. Theaudibility of the horn is verified with operators in different areas of the building during the testing.Page 12 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESb) How do you verify the evacuation alarm's operability?The audibility of the horn is verified with operators in different areas of the building during thetesting.c) Clarify the technical difference between the terminologies of a "verify" and a"test" and justify that the evacuation alarm verification can meet the objective ofthe current TS 4.6.1."Verify" is the act "to make sure or demonstrate that (something) is true, accurate, or justified.""Test" is a procedure or process performed to establish the quality, performance, or reliability.A "test" is a specific procedure used to establish the conditions in order to "verify" performance.As stated in the objective of TS 4.6.2 (as proposed) the surveillance ensures the alarm isaudible when actuated.The specification as submitted was a less verbose version of the evacuation alarm SHALL betested to verify audibility annually not to exceed 15 months.The exact mechanism of the test or conditions need not be stated to ensure clarity of therequirement. Similarly, existing technical specifications surveillances use verbs such asmeasured, determined, compared, inspected, cleaned, lubricated, visually inspected,considered, and verified.In the planned upgrade of the evacuation system to use the life safety (fire alarm), techniciansconduct an annual test (in addition to the continuous computer self-diagnostics) required bybuilding codes to verify that each evacuation enunciator (and strobes) function as designed.In addition, based on your revised SAR Section 6, the RBHVES is intended to perform thesame function as the emergency exhaust system (EES) described in Section 1.3 of theSAR utilizing one or more of four separate exhaust fans. Fresh air can now be suppliedby the RBHVES in addition to the previously assumed leakage around doors andpenetrations. Respond to the following questions specifically applicable to RBHVESsystem:It is presumed the lead in (above) for the remaining questions meant the RBHVES is intended toperform the same function as the facility exhaust system (FES) as described in Section 1.3 ofthe SAR, not the EES. The RBHVES does not perform HEPA or Charcoal filtering that the EESdoes and the RBHVES is isolated in an "emergency" condition. The amendment does not seekto credit the RBHVES for the EES under any circumstance.9. Prior to installation of the RBHVES the facility exhaust system (FES) providedsufficient flow to ensure negative pressure is maintained with the operation of a singlefan, so no monitoring of relative pressure was required. Use of this system requires aflow balance to ensure the negative pressure is maintained.Page 13 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESa) Describe how this flow balance was performed on RBHVES to ensure adequatenegative pressure in the reactor bay for the initial installation.The RBHVES has not yet been commissioned to perform this function and is run in parallel withthe FES. Ventilation modifications in one of the attached buildings and additional fire barrierseals must be completed before final testing can be completed. The system provides the statusof relative air pressure to operators to confirm that the exhaust systems are exhausting.b) How is this flow balance adjusted and how frequently is that adjustment required?The flow balance will be completed as part of the commissioning. The specified acceptancecriteria for system operation require the ability to maintain air flow and by consequence negativepressure. No other specific or routine balancing is planned.c) Are the licensed reactor operators capable or expected to make theseadjustments?No, operators cannot change damper positions. Operators can influence flow and (by thataction) negative pressure by manually starting/stopping additional exhaust fans.d) Does a senior reactor operator (or other senior licensed staff) supervise orapprove the flow balance adjustments?Senior licensed staff review the results of the commissioning measurements.e) Identify the minimum pressure differential (negative reactor bay pressure)required to ensure adequate radiological control and the basis for thatdetermination.There is no "minimum" differential pressure to ensure adequate radiological control. Asdiscussed in answer to question 3 above for the TRIGA reactors in general and for PSU inparticular, there is no impact on public health and safety as a result of operation of the facility,release during the MHA or release from any experiment currently allowed under the limitationsof TS 3.7 Limitations of Experiments. The fundamental purpose and basis of the FES and theits upgrade -RBHVES as stated in SAR Section 6.2.1 is to control air flow through the reactorbay to minimize worker radiation exposure and to release the reactor room air in a controlledmanner (-3000 cu. ft/min or 8.5 x 104 /min with both fans running) where dilution and diffusionof the effluent occurs before it comes into contact with the public. The purpose is to dilutereactor bay air for ALARA considerations, the design consideration is flow (dilution) not negativepressure. Experience has shown that with no exhaust system in operation, natural backgroundRadon daughter products build up in the reactor bay and result in spurious air particulatemonitor alarms and evacuation system activation. Additionally, unrestricted operation of thereactor without exhaust will eventually result in accumulation of measurable Ar41 concentrations.Like Radon, buildup of Ar41 may be observed on the air particulate monitors and may be notedas abnormal indications on the area monitors. No other radiological considerations are part ofthe design bases of FES or RBHVES. Although the presence of negative pressure may helpprevent the spread of volatile radioactive material into adjacent facility areas during a spill it isnot a design requirement and spill response protocol calls for securing unfiltered ventilation.Page 14 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSES10. Your response No. 2 to NRC's RAI dated January 7, 2013, and the revised PSU SARChapter 6, described most of the components in the RBHVES system. Pressure sensorswere not mentioned in this description.a) Are there any pressure sensors installed or related to the RBHVES? If you do nothave pressure sensors describe how you ensure that the air pressure in thereactor bay is lower than the surrounding building or the atmosphere as stated inthe SAR and TS bases.To provide assurance that the system is operating as expected 3 differential pressure (dp)sensors were installed. The sensors have no control functions.b) Describe, in detail, the displays, sensors (including location), controls, andinformation available to the operator for the RBHVES.The operator has following indications/information for RBHVES* Existing FES roof fans -on/off demand status and damper (position sensor) on DCC-Xoperator and message screens (no change), new RBHVES "demand on" light (smallLED west wall attached to existing motor controller)* Confinement dampers not closed status light -if either one of two damper is "notclosed" from a switch on the damper operator this indicator is lit. The green status lightis located on the east wall of the reactor bay in sight of the control room operator.* Differential pressure negative status light (software driven based on lowest (leastnegative) of the 3 sensors). The green status light is located on the east wall of thereactor bay in sight of the control room operator.o Reactor bay to west building wing dp -West reactor bay wall with local readout(see picture below)o Reactor bay to east building wing dp -East reactor bay wall with local readouto Reactor bay to outside dp -South reactor bay wall (no local readout)The operator has the following controls for the RBHVES:* Existing FES roof fan operator manual on/off demand through DCC-X* Existing evacuation system actuation (reactor console pushbutton) which closesconfinement dampers independent of RBHVES.* New confinement damper close pushbutton (west wall of control room)Page 15 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESLocal DP Indication I RBHVES Control Room Shutdownc) Explain the expected operator action when the negative reactor bay air pressureappears to be compromised based on the RBHVES indications.Negative pressure is an indicator of proper system operation, just like the existing FES fan onstatus. If the dp status light or damper status light indicate a problem, the control operator isexpected to notify the SRO who will investigate the cause and initiate corrective action whichmight include starting additional fans, shutdown of RBHVES, and/or initiating maintenance.d) What is the radiological consequence when the reactor bay negative pressure isnot maintained?It is assumed the intent of the question is what are the radiological consequences of a positivepressure in the reactor bay relative the outside or adjacent buildings? Since the normal releaseis unfiltered with no delay, the radiological consequences to persons in the unrestricted area donot change. With positive pressure in the reactor bay monitored air will flow through open doorsor gaps into the adjacent facility wings. This diluted reactor bay air and any associated airborneradio-nuclei would create a slight increase in background radiation levels in the adjacentlaboratories and office space. From SAR Table 11-1, Reactor bay Ar41 levels are calculated tobe 4.2E-8 pCi/ml (.014 DAC or .035 mR/hr). It is not plausible that the dose to a person in theadjacent buildings from the routine reactor operation be any higher than the source air levels.2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> exposure to this source air term is 70 mR in a year. Ar41 exposure results in awhole body immersion dose. The entire facility is a controlled access area and all personnel inthe facility buildings (including visitors) are monitored for whole body exposure. Therefore,there is no adverse radiolo-gical impact to the staff or visitors to the facility or the public.Page 16 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESe) If pressure sensors are present how sensitive are they to normal personnelmovement in and out of the reactor bay and does this tend to create nuisancealarms for the operator?The logic for the status light does limited averaging and does not typically change state duringan individual passing through a door. There is no alarm function to disturb the operator, thelight is checked during hourly logs.f) Does the RBHVES control contain any supervisory logic?The RBHVES has supervisory logic and off-site centralized performance monitoring and alarm.However, on emergency, operator demand, or loss of reactor control power the system isisolated by automatic closure of the confinement dampers without reliance on the supervisorysystem or external power.11. In the revised SAR Section 6.2.1 "Confinement," it states that the confinementisolation dampers were programmed to close on loss of control power.a) Describe the motive force to close these dampers on loss of power. If it is anenergy storage device, describe this energy storage device including how longthe charge can be maintained.The dampers are motor-operated with a capacitive energy storage device. On loss of power tothe actuator the device immediately drives the dampers closed so additional storage time is un-necessary.b) What speed will the dampers move (relative to how they are normally powered)when relying on the energy storage device to close?As installed and operated by the facility, the isolation dampers are almost always operated inthe close direction on stored power. The operator's only control of the system is to removepower from the dampers and verify they drive closed. The dampers close in about 5 seconds.c) What surveillance is performed to ensure the system functions as expected onloss of external alternating current power?Beyond commissioning testing, no continuing testing of the RBHVES system for response toloss of AC will be conducted. As mentioned above, the only response of RBHVES to loss of ACis to close the dampers. The dampers are "fail-safe" (closed) on loss of power and are now partof the daily (under current TS) and monthly (current and amended TS) system test. The test isconducted by removing power to the actuators via the evacuation alarm relay and verifying thedampers close.12. The RBHVES isolates on conditions that cause the building evacuation alarm to besounded. This is required to ensure that the EES controls the release path or airborneradiation during accident conditions. What testing has been performed to ensure theconfinement isolation dampers provide sufficient isolation to the reactor bay from theRBHVES to prevent it from compromising the intended release path?The confinement isolation dampers close when demanded by the operator, on loss of power, oron any evacuation system actuation. RBHVES supervisory loQic does not monitor or isolate onPage 17 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESany confinement conditions. No specific or ongoing testing is planned or necessary to ensurethe leak tightness of the confinement dampers. The radiological consequence analysis doesnot take credit for an airborne release and the release path (via EES or other locations) is aground release. Therefore release via an open confinement damper (with or without the EESoperating) is bounded by the MHA. The consequence of confinement damper failure is same orless than it is for the existing FES roof fan gravity backflow dampers. During a release eventwhere the RBHVES shuts down and the EES starts, the flow rate from EES will assure that anyleakage that occurs (damper closed or not) will be into the building. Air moving into theconfinement will take the paths of least resistance. A confinement damper open will allow air in-leakage from exhaust header through the associated filters enthalpy wheel and static fanresistance. Adding multiple additional failures to the already non-credible MHA is notreasonable, but continued operation of the RBHVES system throughout the event is stillpractically bounded by the MHA as the release rate and point is the essentially the same and nofiltration was credited in the MHA radiological consequences.13. Review of the revised SAR Section 6.0 revealed that the RBHVES (multiplecomponents or control system failure) has the potential to pressurize the confinement.Consistent with Title 10 of the Code of Federal Regulations Section 50.36(c)(2)(ii)(C)propose a TS for maintaining the reactor bay at a negative pressure relative to theremainder of the building or the atmosphere consistent with the bases for TSs 3.4 and3.5. If credit is being taken for the pressure sensors, include a surveillance with afrequency for testing and calibration of these sensors and associated alarm responses.The proposed TS should be a replacement for the existing TS requiring at least onefacility exhaust fan to be running. If it is not being proposed, provide justification.The responses to several questions in this RAI and the previous RAI (ML12346A349) havediscussed the radiological impact and lack of consequences of loss of negative pressure or ofpositive pressure during routine operations. During routine operations, the RBHVES functionsas a dilution mechanism for ALARA considerations of the reactor bay occupants. It's failure tofunction or to shut down and isolate on an accident event has no appreciable impact on thehealth and safety of the public. It is not a safety system required to function to preserve afission product barrier and its failure to function has no effect on the probability, frequency, orconsequences of an accident. Its proper operation, improper operation, malfunction or failure tofunction as designed does not change the fundamental assumptions of the SAR accidentanalysis or significantly affect the outcome of the analysis for release provided in the SAR.Negative pressure is not a SAR accident assumption and therefore an additional Technicalspecification to protect negative pressure is not necessary. Indeed no credible event consistentwith existing Technical Specifications can result in a significant consequence to the public asprovided in NUREG CR2387.Existing and proposed Technical Specifications adequately protect the SAR assumptions.Some of the relevant specifications include TS 3.4 which provides for confinement; TS 3.5which requires exhaust fan operation and EES operability when the reactor is operating or whenfuel is being moved; TS 3.6.1 which requires radiation monitors that secure ventilation whenrequired; and TS 3.6.2 which requires evacuation horn operation. These specifications inconjunction with the associated surveillance requirements ensure that the RBHVES will beoperated as designed. Additional indication has been provided to the operator to ensure theexhaust portion of the system is operating as expected. Improper indications will result ininvestigation and action to remain in compliance with Technical Specifications. Although notdiscussed, relied upon or credited, due to ongoing concerns with reliability of digital systems,the RBHVES digital supervisory system will take action to secure the system and alarm at aPage 18 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESremote monitoring station if the system malfunction's providing backup to the operator'sindication and remedial action.Additionally, PSU has reviewed Title 10 of the Code of Federal Regulations Section 50.36Technical Specifications to better understand the NRC concern and the regulatory basis for therequest for an additional TS requirement. Based on this review PSU maintains that a technicalspecification to maintain the reactor bay at a negative pressure relative to the adjacent buildingor the outside is neither technically nor administratively necessary to comply with the rule. Thefollowing justifications are provided:Technical justification: The question proposes the need for a technical specificationrequirement to maintain negative pressure during routine operations to satisfy 10CFR50.36.10 CFR Section 50.36(c)(2)(ii)(C) Introduction states: A technical specification limiting conditionfor operation of a nuclear reactor must be established for each item meeting one or more of thefollowing criteria: (C) Criterion 3. A structure, system, or component that is part of the primarysuccess path and which functions or actuates to mitigate a design basis accident or transientthat either assumes the failure of or presents a challenge to the integrity of a fission productbarrier.Negative pressure in the reactor bay is a relative condition of reactor bay (or confinement) thatresults from operation of an exhaust fan. It is not a structure, system or component asdescribed in the referenced Criterion 3. This condition (negative pressure during routineoperations) is not part of the primary success path which functions or actuates to mitigate adesign basis accident and has no impact on the integrity of a fission product barrier. RBHVEShas no part in a primary success path during any postulated accident. During an accident theRBHVES is expected to isolate. Existing and proposed TS 4.6 will provide for monthlyverification of the system's ability to meet that function.Therefore Criterion 3 does not describe a case where a negative pressure technicalspecification is needed during routine operations.The remaining 1OCFR50.36 TS criteria were reviewed and a similar conclusion was reached. Atechnical specification is not necessary to protect the assumptions of the SAR, ensure thefacility remains within the design basis, protect the fuel or fission product boundaries or protectthe health and safety of the public.14. In the SAR Section 6.2.1, it states "[W]hen the evacuation alarm is activated, anyoperating RBHVES fans are shutdown, associated confinement isolation dampers shut,and the EES system starts." Describe how the signal from the evacuation alarminterfaces with the RBHVES. What type of isolation has been provided to ensure theintegrity of the signal and to prevent system feedback from preventing other automaticactions that are required when the evacuation alarm sounds?Neither the RBHVES or the DCC-X evacuation system are "safety grade" or safety relatedsystems. However prudent engineering isolation practices were employed to prevent un-desirable interaction. The design was developed to be simple, direct and reliable.Page 19 of 20 PSU RBHVES LAR RAI #2 dtd 5/1/14 RESPONSESFused 24v Reactor auxiliary power is supplied through the spare contacts of an existingevacuation system multiplier relay to the coil of a relay (PR-20) in the RBHVES control system.Operation of PR-20 directly interrupts power to the damper motor operators causing them to failclosed using stored power. The RBHVES supervisory system sees this loss of power andinitiates shutdown of the remaining components outside the isolation boundary to preventdamage.* ii ~~ I;I;~*1~**f~T4U-~ I.13Kk tArPage 20 of 20 PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAITechnical SDecification Changes Summary TableRefer to attached marked u Technical Specification pages# Page Number Technical Change JustificationSpecification1. TOC i and ii Table of Contents Editorial -updated table to Necessary to reflect changes in the(TOC) (actually a reflect changes in specifications and correct missingformat error in the specifications. Added missing headerword file for TS 4.3) TS 4.3 Coolant SystemReplace TOC pageI and II2. Page 4 (of 56) 1.1.29.a Editorial -Capitalize and bold Improve readability and reduce operatorexisting word "OR" error in compliance3. 1.1.29.b Editorial -replaced lead in Improve readability and reduce operatorphrase error in compliance, match ANS-1 5.14. 1.1.29.b.1) Editorial -Capitalize and bold Improve readability and reduce operatorexisting word "AND" error in complianceAdjusted Margin To fit existing page5. 1.1.29.b.2) Editorial -Capitalize and bold Improve readability and reduce operatorexisting word "AND" error in complianceAdjusted Margin To fit existing page6. 1.1.29.b.3) Editorial -Capitalize and bold Improve readability and reduce operatorexisting word "AND" error in complianceAdjusted Margin To fit existing page7. 1.1.29.b.4) Adjusted Margin To fit existing page8. Page 10 (of 56) 3.1.1 .b basis Editorial -correct SAR SAR section reference was incorrect__ _reference to Section B.Page 1 of 5 PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAITechnical Specification Changes Summary Table9.Page 23 (of 56)Deleted 3.3.3specification andbasisTechnical/Editorial -deletedspecification in its entirety.+ *4 ITS 3.3.3 was redundant andsubordinate to TS 3.6. Thespecification duplication combined withslightly different terminology leadreaders to believe there were 2separate air monitors with differentfunctions. The referenced monitors arethe same monitor with local alarm andremote function to activate theevacuation system. The TS 3.3.3stated function (to monitor fissionproducts) was incorporated into TS3.6.1 and associated basis. See alsodiscussion in the accompanyingresponse to question 1 of the RAI dtdApril 1 2014.This change will more closely align theconfinement specification with theassociated ventilation specificationrequirement and allow maintenanceactivities with key in the console but thereactor shutdown with the bay dooropen. This eliminates the automaticLCO violation if the reactor key isinserted with the door open. With thereactor shutdown the objective of thespecification (to ensure no large airpassages exist when the reactor isoperating) is maintained unchanged.See also discussion in theaccompanying response to question 2of the RAI dtd ADril 1 2014.10.1 Page 25 (of 56)3.4.a specificationTechnical -changed reactornot secured to operating11. Page 26 and 26a 3.5 Title and Editorial -Changed to reflect Facility exhaust system renamed to(of 56) applicability the ventilation system name Reactor Bay Heating Ventilation andchanges Exhaust.12. 3.5 Editorial -Changed IF to Editor preference/readabilitywhenever in 3.5.a and 3.5.bPage 2 of 5 PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAITechnical Specification Chancies Summary Table13.14.15.16.17.Page 26 and 26a(of 56)3.5.aTechnical -increasedEmergency Exhaust systemmaintenance period from 48hours to 30 days; changedfacility to reactor bay.added a one hour time clock torestore an exhaust fan tooperation or shutdownEditorial -Capitalized "AND"See the previous RAI (ML12346A349)response #4 and the question 3 of theApril 1 2014 RAI response. -Improvedreadability.See the previous RAI (ML12346A349)response #4Improve readability, error reduction3.5.b Editorial -Capitalized "AND" Improve readability and reduce operatorerror in compliance3.5.b Technical -changed "Facility" Reflects name change, recognizes thatto "reactor bay" exhaust fan any one of the exhaust fans includingthe EES fan can be used to maintainventilation and confinement.3.5.b Technical -add remedial Prevents automatic TS violation. Seeaction if an exhaust fan goes the previous RAI (ML12346A349)inoperable during fuel or response #4 and several questionexperiment movement responses in the current RAI.3.5 basisTechnical -updated/added a)and b) sectionsUpdated to reflect the changes in thesDecification.18. Page 27 (of 56) 3.6 title Editorial -update to reflect Ease of usecontent of specification19. 3.6.1 title Editorial -update to reflect Ease of usecontent of specification20. 3.6.1 table 3 and Updated to reflect the rename Lab renamed, air monitor namingbasis of the Neutron Beam inconsistent (continuous versesLaboratory, Continuous air particulate) and incorporated TS 3.3monitor changed to air function. See response to RAI questionparticulate monitor. 1. The incorporation of TS 3.3.3 into TSIncorporated the particulate 3.6.1 eliminates redundantmonitor function (detect fission requirements and reduces confusion.products).Page 3 of 5 PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAITechnical Specification Changes Summary Table21. Page 28 (of 56) 3.6.2 Technical -added remedial Prevents automatic TS violation whileaction if evacuation alarm is maintaining safety considerations. Seeinoperable and limitations on previous RAI (ML12346A349)use of the remedial action response 3 and 4 and severalresponses in the current RAI for furtherinformation..22. 3.6.2 basis Technical -updated Updated to reflect the changes in thespecification.23. Page 28a (of 56) 3.6.3 Ar-41 Editorial -moved to page 28a Format and space considerations24. Page 29 (of 56) 3.6.4 ALARA Delete in entirety Specification duplicated 10 CFR 20requirements see previous RAI(ML12346A349) response 525. Page 30 (of 56) 3.7.b Editorial -replaced that with Corrected improper wording resultingthan in last sentence from a previous typographical error.26. Page 41 (of 56) 4.5 title, applicability Editorial -updated to reflect Consistency of specificationsand objective change exhaust system nameand function27. 4.5.b Editorial -updated to reflect Consistency of specificationschange exhaust system nameand function;changed "secured" to isolated Recognize operation of system28. 4.6 title Editorial -update to reflect Ease of use, consistency ofcontent of specification specifications29. 4.6.1 title Editorial -update to reflect Consistency of specificationsapplicability, content of specification 3.6.1objective and and name change of neutronspecification beam lab and air monitor.Separated evacuation alarminto specification 4.6.2 forconsistency to match section3.630. Page 42 (of 56) 4.6.1. Editorial -separated channel Specification only applicable whencheck, test, and test into reactor is scheduled for operations.separate line items, added Ease of reading/understandingapplicability to reactoroperationsPage 4 of 5 PENNSYLVANIA STATE UNIVERSITY RESPONSE TO NRC RAITechnical Specification Changes Summary Table31. Page 42 (of 56) 4.6.1 basis Editorial update Updated for consistency andcompleteness.32. 4.6.2 entirety 4.6.2 Becomes the See amendment request and RAIevacuations alarm testing response below.requirementsAr-41 renumbered unchangedto 4.6.3 to be consistent withsection 3 of TS. specification,33. Page 43 (of 56) 4.6.3 entirety Deleted ALARA specification See amendment request and See theprevious RAI (ML12346A349).Section 4.6.2 Ar-41 becomes Updated for consistency andsection 4.6.3 to maintain completeness.consistency of specificationnumbering34. Page 46 (of 56) 5.5 title, Editorial -updated to reflect Necessary clarifications consistent withspecification and system title change and system design. See the previous RAIbasis correct reference to (ML12346A349).emergency exhaust dischargeheight.35. Page 47 (of 56) 6.1.1 Editorial -updated text title of Correct historic oversight.Physical Plant vice presidentto match organization chart onnext page36. Page 56 (of 56) 6.7.3.a Technical -Updated radiation Reduce facility burden andexposure records retention maintenance of unnecessary personalrequirements to reflect data on visitors.10CFR20.Page 5 of 5 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-

21.0 INTRODUCTION

11.1 Definitions 12.0 SAFETY LIMIT AND LIMITING SAFETY SYSTEM SETTING 82.1 Safety Limit -Fuel Element Temperature 82.2 Limiting Safety System Setting (LSSS) 93.0 LIMITING CONDITIONS FOR OPERATION 103.1 Reactor Core Parameters 103.1.1 Non-Pulse Mode Operation 103.1.2 Reactivity Limitation 113.1.3 Shutdown Margin 123.1.4 Pulse Mode Operation 133.1.5 Core Configuration Limitation 143.1.6 TRIGA Fuel Elements 153.2 Reactor Control and Reactor Safety System 163.2.1 Reactor Control Rods 163.2.2 Manual Control and Automatic Control 173.2.3 Reactor Control System 183.2.4 Reactor Safety System and Reactor Interlocks 193.2.5 Core Loading and Unloading Operation 213.2.6 SCRAM Time 213.3 Coolant System 223.3.1 Coolant Level Limits 223.3.2 Detection of Leak or Loss of Coolant 233.3.3 Deleted 233.3.4 Pool Water Supply for Leak Protection 243.3.5 Coolant Conductivity Limits 243.3.6 Coolant Temperature Limits 253.4 Confinement 253.5 Ventilation Systems 263.6 Radiation Monitoring, Evacuation, and Effluents 273.6.1 Radiation Monitoring 273.6.2 Evacuation Alarm 283.6.3 Argon-41 Discharge Limit 28a3.6.4 Deleted 293.7 Limitations of Experiments 29-i-IZ menment 39 I TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-24.0 SURVEILLANCE REQUIREMENTS 324.1 Reactor Parameters 324.1.1 Reactor Power Calibration 324.1.2 Reactor Excess Reactivity 324.1.3 TRIGA Fuel Elements 334.2 Reactor Control and Safety System 344.2.1 Reactivity Worth 344.2.2 Reactivity Insertion Rate 344.2.3 Reactor Safety System 354.2.4 Reactor Interlocks 364.2.5 Overpower SCRAM 374.2.6 Transient Rod Test 374.3 Coolant System 384.3.1 Fire Hose Inspection 384.3.2 Pool Water Temperature 394.3.3 Pool Water Conductivity 394.3.4 Pool Water Level Alarm 404.4 Confinement 404.5 Ventilation Systems 414.6 Radiation Monitoring, Evacuation, and Effluents 414.6.1 Radiation Monitoring System and Evacuation Alarm 414.6.2 Evacuation Alarm 424.6.3 Argon-41 434.7 Experiments 435.0 DESIGN FEATURES 445.1 Reactor Fuel 445.2 Reactor Core 445.3 Control Rods 455.4 Fuel Storage 455.5 Reactor Bay Confinement and Exhaust Systems 465.6 Reactor Pool Water Systems 46-ii -Amnmnt 39 J TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-21.1.25 Reactivity Worth of an ExperimentThe reactivity worth of an experiment is the maximum absolute value of thereactivity change that would occur as a result of intended or anticipated changesor credible malfunctions that alter experiment position or configuration.1.1.26 Reactor Control SystemThe reactor control system is composed of control and operational interlocks,reactivity adjustment controls, flow and temperature controls, and displaysystems which permit the operator to operate the reactor reliably in its allowedmodes.1.1.27 Reactor InterlockA reactor interlock is a device which prevents some action, associated withreactor operation, until certain reactor operation conditions are satisfied.1.1.28 Reactor OperatingThe reactor is operating whenever it is not secured or shutdown.1.1.29 Reactor SecuredThe reactor is secured when:a. It contains insufficient fissile material or moderator present in the reactor,adjacent experiments, or control rods, to attain criticality under optimumavailable conditions of moderation, and reflection, ORb. All of the following conditions exist:I) The minimum number of neutron absorbing control rods are fullyinserted or other safety devices are in shutdown positions, as required bytechnical specifications,AND2) The console key switch is in the off position and the key is removed fromthe lock,AND3) No work is in progress involving core fuel, core structure, installedcontrol rods, or control rod drives unless they are physically decoupledfrom the control rods,AND4) No experiments in or near the reactor are being moved or serviced thathave, on movement, a reactivity worth exceeding the maximum valueallowed for a single experiment or one dollar whichever is smaller.Page 4 of 56 1 A ne nt3 9 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.0 LIMITING CONDITIONS FOR OPERATIONThe limiting conditions for operation as set forth in this section are applicable only when thereactor is operating. They need not be met when the reactor is shutdown unless specifiedotherwise.3.1 Reactor Core Parameters3.1.1 Non-Pulse Mode OperationApplicabilityThese specifications apply to the power generated during manual control mode,automatic control mode, and square wave mode operations.ObiectiveThe objective is to limit the source term and energy production to that used in theSafety Analysis Report.Specificationsa. The reactor may be operated at steady state power levels of 1 MW (thermal) orless.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 650'C asmeasured with an instrumented fuel element if it is located in a core positionrepresentative of MEPD in that loading. If it is not practical to locate theinstrumented fuel in such a position, the steady state fuel temperature SHALLbe calculated by a ratio based on the calculated linear relationship between thenormalized power at the monitored position as compared to normalized powerat the core position representative of the MEPD in that loading. In this case,the measured steady state fuel temperature SHALL be limited such that thecalculated steady state fuel temperature at the core position representative ofthe MEPD in that loading SHALL NOT exceed 650*C.Basisa. Thermal and hydraulic calculations and operational experience indicate that acompact TRIGA reactor core can be safely operated up to power levels of atleast 1.15 MW (thermal) with natural convective cooling.b. Operation at 1.1 MW (thermal) is within the bounds established by the SARfor steady state operations. See Chapter 13, Section B of the SAR.c. Limiting the maximum steady state measured fuel temperature of any positionto 650°C places an upper bound on the fission product release fraction to thatused in the analysis of a Maximum Hypothetical Accident (MHA). See SafetyAnalysis Report, Chapter 13.Page 10 of 56 Amendmnt3 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.3.2 Detection of Leak or Loss of CoolantApplicabilityThis specification applies to detecting a pool water loss.ObjectiveThe objective is to detect the loss of a significant amount of pool water.SpecificationA pool level alarm SHALL be activated and corrective action taken when the poollevel drops 26 cm from a level where the pool is full.BasisThe alarm occurs when the water level is approximately 18.25 ft. above the top ofthe bottom grid plate. The point at which the pool is full is approximately 19.1 ft.above the top of the bottom grid plate. The reactor staff SHALL take action tokeep the core covered with water according to existing procedures. The alarm isalso transmitted to the Police Services annunciator panel which is monitored 24hrs. a day. The alarm provides a signal that occurs at all times. Thus, the alarmprovides time to initiate corrective action before the radiation from the core posesa serious hazard.3.3.3 DeletedPage 23 of 56I Aendent 39 1 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.3.6 Coolant Temperature LimitsApplicabilityThis specification applies to the pool water temperature.ObjectiveThe objective is to maintain the pool water temperature at a level that will notcause damage to the demineralizer resins.SpecificationAn alarm SHALL annunciate and corrective action SHALL be taken if duringoperation the bulk pool water temperature reaches 140*F (60°C).BasisThis specification is primarily to preserve demineralizer resins. Informationavailable indicates that temperature damage will be minimal up to thistemperature.3.4 ConfinementApplicabilityThis specification applies to reactor bay doors.ObiectiveThe objective is to ensure that no large air passages exist to the reactor bay during reactoroperation.SpecificationsThe reactor bay truck door SHALL be closed and the reactor bay personnel doors SHALLNOT be blocked open and left unattended if either of the following conditions are true.a. The reactor is operating, orb. Irradiated fuel or a fueled experiment with significant fission product inventory isbeing moved outside containers, systems or storage areas.BasisThis specification helps to ensure that the air pressure in the reactor bay is lower than theremainder of the building and the outside air pressure. Controlled air pressure ismaintained by the air exhaust system and ensures controlled release of any airborneradioactivity.Page 25 of 56SAmendment 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.5 Ventilation SystemsApplicabilityThis specification applies to the operation of the reactor bay heating ventilation andexhaust system and the emergency exhaust system.ObjectiveThe objective is to mitigate the consequences of the release of airborne radioactivematerials resulting from reactor operation.Specificationa. Whenever the reactor is operating, at least one reactor bay exhaust fan SHALLbe operating AND, except for periods of time less than 30 days duringmaintenance or repair, the emergency exhaust system SHALL be operable.With no operating exhaust fans, restore an exhaust fan to operation within1 hour or shutdown the reactor.b. Whenever irradiated fuel or a fueled experiment with significant fission productinventory is being moved outside containers, systems or storage areas, at leastone reactor bay exhaust fan SHALL be operating AND the emergency exhaustsystem SHALL be operable.With no operating exhaust fans or discovery of an inoperable emergencyexhaust system, complete the movement in progress, then cease all furthermovement until compliance with 3.5.b is restored.Basisa. During normal operation, the concentration of airborne radioactivity inunrestricted areas is below effluent release limits as described in the SafetyAnalysis Report, Chapter 13. The operation of any of the reactor bay exhaust fans(reactor bay heating ventilation and exhaust system or the emergency exhaustsystem) will maintain this condition and provide confinement per TS 1.1.8. If allexhaust from the reactor bay is temporarily lost, the I hour time limit to restoreexhaust allows operators to investigate and respond. Reactor bay area radiationand/or particulate radiation monitors will continue to assure an unrecognizedhazardous condition does not develop.In the event of a substantial release of airborne radioactivity, an air radiationmonitor and/or an area radiation monitor will alert personnel and lead to initiationof the building evacuation alarm which will automatically cause the reactor bayheating ventilation and exhaust system to shut down. The emergency exhaustsystem will start and the exhausted air will be passed through the emergencyexhaust system filters before release. This reduces the radiation within thebuilding. The filters will remove = 90% all of the particulate fission products thatescape to the atmosphere.Page 26 of 56 Amendment 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-2The emergency exhaust system activates only during an evacuation whereupon allpersonnel are required to evacuate the building (TS 3.6.2). If there is an evacuationwhile 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 systemmaintenance or repair, the public dose will be equivalent to or less than thatcalculated in the Safety Analysis Report, Chapter 13 as this analysis does not takecredit for the filtration provided by emergency exhaust system. Therefore thesystem filtration and operation is not required to meet the accident analysis and a 30day repair period is mandated or operations will cease.b. During irradiated fuel or fueled experiment movement, the likelihood of eventreleasing fission products to the bay is increased. Therefore operation of theexhaust system and availability of an operable filtered exhaust is prudent. If thesystem fails or is discovered inoperable during movement activities, the movementin progress must be completed to store the fuel or experiment in an approvedlocation. This is prudent and remains within the requirement of the limitingcondition for operation remedial action. No further movements may be conducteduntil the limiting condition for operation is satisfied.Page 26a of 56 Amendment 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.6Radiation Monitoring, Evacuation, and EffluentsI3.6.1 Radiation MonitoringApplicabilityThis specification applies to the radiation monitoring information which must beavailable to the reactor operator during reactor operation.ObjectiveThe objective is to ensure that sufficient radiation monitoring information isavailable to the operator to ensure personnel radiation safety during reactoroperation.SpecificationThe reactor SHALL NOT be operated unless the radiation monitoring channelslisted in Table 3 are operating.Table 3Radiation Monitoring ChannelsRadiation MonitoringChannelsArea Radiation MonitorAir Particulate(Radiation) MonitorNeutron BeamLaboratory MonitorFunctionMonitor radiation levelsin the reactor bay.Monitor radioactiveparticulates includingfission products in thereactor bay air.Monitor radiation in theNeutron BeamLaboratory (requiredonly when the laboratoryis in use.)Nu.--l--Ammoer111Basisa. The radiation monitors provide information to operating personnel ofany impending or existing danger from radiation or airborne activity includingfission products so that there will be sufficient time to evacuate the facility andto take the necessary steps to control the spread of radioactivity to thesurroundings.b. The area radiation monitor in the Neutron Beam Laboratory providesinformation to the user and to the reactor operator when this laboratory is inuse.IPage 27 of 56AmedmetZ3 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.6.2 Evacuation AlarmApplicabilityThis specification applies to the evacuation alarm.ObjectiveThe objective is to ensure that all personnel are alerted to evacuate the PSBRbuilding when a potential radiation hazard exists within this building.SpecificationThe reactor SHALL NOT be operated unless the evacuation alarm isoperable and audible to personnel within the PSBR building when activatedby the radiation monitoring channels in Table 3 or a manual switch.With no operable evacuation alarm system, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discoveryreturn the evacuation alarm to operation or verify that an evacuation canbe initiated using the facility announcement system or other audiblealarm. The use of an alternate alarm shall not exceed a period of 30days.BasisThe evacuation alarm system produces an audible alarm throughout thePSBR building when activated. The alarm notifies all personnel within thePSBR building to evacuate the building as prescribed by the PSBRemergency procedure.Since the probability of a valid need for a full facility evacuation is very lowand areas of the building that have significant sources of radiation have localalarms, it is reasonable that the evacuation system may be removed fromservice for maintenance and testing without ceasing reactor operations. Theone hour time limit allows for routine maintenance and testing. Verificationof a suitable substitute alarm or a functioning facility announcement systemwill ensure the facility can be evacuated in accordance with emergencyprocedures and allow for longer maintenance intervals if required.Page 28 of 56 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.6.3 Argon-41 Discharge LimitApplicabilityThis specification applies to the concentration of Argon-41 that may be dischargedfrom the PSBR.ObjectiveThe objective is to ensure that the health and safety of the public is not endangeredby the discharge of Argon-41 from the PSBR.SpecificationAll Argon-41 concentrations produced by the operation of the reactor SHALL bebelow the limits imposed by 10 CFR Part 20 when averaged over a year.BasisThe maximum allowable concentration of Argon-41 in air in unrestricted areas asspecified in Appendix B, Table 2 of 10 CFR Part 20 is 1.0 x 10s [LCi/ml.Measurements of Argon-41 have been made in the reactor bay when the reactoroperates at 1 MW. These measurements show that the concentrations averagedover a year produce less than 1.0 x 10.8 jiCi/ml in an unrestricted area (seeEnvironmental Impact Appraisal, December 12, 1996).Page 28a of 56I Aenmnt 391I TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-23.6.4 Deleted3.7 Limitations of ExperimentsApplicabilityThese specifications apply to experiments installed in the reactor and its experimentalfacilities.ObjectiveThe objective is to prevent damage to the reactor and to minimize release ofradioactive materials in the event of an experiment failure.SpecificationsThe reactor SHALL NOT be operated unless the following conditions governingexperiments exist:a. The reactivity of a movable experiment and/or movable portions of a securedexperiment plus the maximum allowed pulse reactivity SHALL be less than 2.45% Ak/k(-$3.50). However, the reactivity of a movable experiment and/or movable portions ofa secured experiment SHALL have a reactivity worth less than 1.4% Ak/k (-$2.00).During measurements made to determine specific worth, this specification is suspendedprovided the reactor is operated at power levels no greater than 1 kW. When a movableexperiment is used, the maximum allowed pulse SHALL be reduced below the allowedpulse reactivity insertion of 2.45% Ak/k (-$3.50) to ensure that the sum is less 2.45%Ak/k (-$3.50).Page 29 of 56IZAendenZ3 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-2b. A single secured experiment SHALL be limited to a maximum of 2.45% Ak/k(-$3.50). The sum of the reactivity worth of all experiments SHALL be less than2.45% AkMk (-$3.50). During measurements made to determine experimental worth,this specification is suspended provided the reactor is operated at power levels nogreater than I kW.c. When the keff of the core is less than I (one) with all control rods at their upper limitand no experiments in or near the core, secured negative reactivity experiments maybe added without limit.d. An experiment may be irradiated or an experimental facility may be used inconjunction with the reactor provided its use does not require a license amendment, asdescribed in 10 CFR 50.59, "Changes, Tests and Experiments." The failuremechanisms that SHALL be analyzed include, but are not limited to corrosion,overheating, impact from projectiles, chemical, and mechanical explosions.Explosive material SHALL NOT be stored or used in the facility without propersafeguards to prevent release of fission products or loss of reactor shutdowncapability.If an experimental failure occurs which could lead to the release of fission products orthe loss of reactor shutdown capability, physical inspection SHALL be performed todetermine the consequences and the need for corrective action. The results of theinspection and any corrective action taken SHALL be reviewed by the Director or adesignated alternate and determined to be satisfactory before operation of the reactoris resumed.e. Experiment materials, except fuel materials, which could off-gas, sublime, volatilize,or produce aerosols under (1) normal operating conditions of the experiment andreactor, (2) credible accident conditions in the reactor, or (3) possible accidentconditions in the experiment, SHALL be limited in activity such that the airborneconcentration of radioactivity averaged over a year SHALL NOT exceed the limit ofAppendix B Table 2 of 10 CFR Part 20.When calculating activity limits, the following assumptions SHALL be used:1) If an experiment fails and releases radioactive gases or aerosols to the reactor bayor atmosphere, 100% of the gases or aerosols escape.2) If the effluent from an experimental facility exhausts through a holdup tank whichcloses automatically on high radiation level, at least 10% of the gaseous activity oraerosols produced will escape.3) If the effluent from an experimental facility exhausts through a filter installationdesigned for greater than 99% efficiency for 0.3 micron particles, at least 10% ofthese vapors can escape.4) For materials whose boiling point is above 1300F and where vapors formed byboiling this material can escape only through an undisturbed column of waterabove the core, at least 10% of these vapors can escape.Page 30 of 561 Amendment 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-24.5 Ventilation SystemsApplicabilityThese specifications apply to the reactor bay heating ventilation and exhaust system andemergency exhaust system.ObjectiveThe objective is to ensure the proper operation of the reactor bay heating ventilation andexhaust system and emergency exhaust system in controlling releases of radioactivematerial to the uncontrolled environment.Specificationsa. It SHALL be verified monthly, not to exceed 6 weeks, whenever operation isscheduled, that the emergency exhaust system is operable with correct pressure dropsacross the filters (as specified in procedures).b. It SHALL be verified monthly, not to exceed 6 weeks, whenever operation isscheduled, that the reactor bay heating ventilation and exhaust system is isolated whenthe emergency exhaust system activates during an evacuation alarm (See TS 3.6.2 andTS 5.5).BasisExperience, based on periodic checks performed over years of operation, hasdemonstrated that a test of the exhaust systems on a monthly basis, not to exceed 6weeks, is sufficient to ensure the proper operation of the systems. This providesreasonable assurance on the control of the release of radioactive material.4.6 Radiation Monitoring, Evacuation, and Effluents4.6.1 Radiation Monitoring System and Evacuation AlarmApplicabilityThis specification applies to surveillance requirements for the area radiationmonitor, the Neutron Beam Laboratory radiation monitor, the air particulateradiation monitor, and the evacuation alarm.ObjectiveThe objective is to ensure that the radiation monitors and evacuation alarmare operable and to verify the appropriate alarm settings.Page 41 of 56 Amendment 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-2SpecificationThe area radiation monitor, the Neutron Beam Laboratory radiation monitor andthe air particulate (radiation) monitor SHALL be:a. Channel checked each day that the reactor is operated if the monitor isrequired to be in service per T.S. 3.6.1;b. Channel tested monthly not to exceed 6 weeks, whenever operations arescheduled;c. Calibrated annually, not to exceed 15 months, whenever operations arescheduled.BasisA daily channel check when the monitor is required to be in service is prudent andadequate to ensure personnel protection. Additionally, experience has shown thisfrequency of verification of the radiation monitor set points and operability and theevacuation alarm operability is adequate to correct for any variation in the systemdue to a change of operating characteristics. An annual channel calibrationensures that units are within the specifications defined by procedures. If nooperations are scheduled, then calibration and testing intervals are not applicable.4.6.2 Evacuation AlarmApplicabilityThis specification applies to the emergency evacuation alarm.ObiectiveThe objective is to ensure that the emergency alarm is audible when actuatedautomatically or via a manual switch.SpecificationThe evacuation alarm SHALL be verified audible annually not to exceed 15months.BasisDuring an abnormal radiation event an evacuation alarm is transmitted through thebuilding via the public address system or the life safety fire panel. The publicaddress system is frequently used for information paging and malfunction isreadily apparent. The life safety fire alarm system is maintained in accordancewith building codes and is highly reliable with backup power and automatedtrouble identification. This specification works in conjunction with specification4.6.1 to comprehensively test the alarm system with this specification only testingthe enunciators. Therefore annual testing of the audible enunciator is adequate toverify the alarm function.P 4Amendment 39Page 42 of 56 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-24.6.3 Argon-41ApplicabilityThis specification applies to surveillance of the Argon-41 produced during reactoroperation.ObiectiveTo ensure that the production of Argon-41 does not exceed the limitsspecified by 10 CFR Part 20.SpecificationThe production of Argon-41 SHALL be measured and/or calculated for eachnew experiment or experimental facility that is estimated to produce a dose greaterthan I mrem at the exclusion boundary.BasisOne (1) mrem dose per experiment or experimental facility represents 1% of themaximum 10 CFR Part 20 annual dose. It is considered prudent to analyze theArgon-41 production for any experiment or experimental facility that exceeds 1%of the annual limit.4.7 ExperimentsApplicabilityThis specification applies to surveillance requirements for experiments.ObjectiveThe objective is to ensure that the conditions and restrictions of TS 3.7 are met.SpecificationThose conditions and restrictions listed in TS 3.7 SHALL be considered by the PSBRauthorized reviewer before signing the irradiation authorization for each experiment.BasisAuthorized reviewers are appointed by the facility director.Page 43 of 56I Amendment 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-25.5 Reactor Bay Confinement and Exhaust SystemsSpecificationsa. 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 reactorbay SHALL be 1900 in3.b. The reactor bay SHALL be equipped with two exhaust systems. Under normaloperating conditions, the reactor bay heating ventilation and exhaust system exhaustsunfiltered reactor bay air to the environment releasing it at a height at least 34 feet(10.5 m) above the reactor bay floor. Upon initiation of a building evacuation alarm,the previously mentioned system is automatically isolated and an emergency exhaustsystem automatically starts. The emergency exhaust system is also designed todischarge reactor bay air at a height at least 34 feet (10.5 m) above the reactor bayfloor.BasisThe value of 1900 m3 for reactor bay free volume is assumed in the SAR 13.1.1 MaximumHypothetical Accident and is used in the calculation of the radionuclide concentrations forthe analysis.The SAR analysis 13.1.1 Maximum Hypothetical Accident does not take credit for anyfiltration present in the emergency exhaust system. Although analyzed as a groundrelease, the height above the reactor bay floor level of the release helps to ensure adequatemixing prior to possible public exposure.5.6 Reactor Pool Water SystemsSpecificationThe reactor core SHALL be cooled by natural convective water flow.BasisThermal and hydraulic calculations and operational experience indicate that a compactTRIGA 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 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-26.0 ADMINISTRATIVE CONTROLS6.1 Organization6.1.1 StructureThe University Vice President for Research Dean of the Graduate School(level 1) has the responsibility for the reactor facility license. Themanagement of the facility is the responsibility of the Director (level 2),who reports to the Vice President for Research, Dean of the GraduateSchool 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 anadvanced degree in science or engineering, and 2 years experience in reactoroperation. Five years of experience directing reactor operations may besubstituted for an advanced degree.The Manager of Radiation Protection reports through the Director ofEnvironmental Health and Safety, the assistant Vice President for Office ofPhysical Plant, and to the Senior Vice President for Finance andBusiness/Treasurer. The qualifications for the Manager of RadiationProtection position are the equivalent of a graduate degree in radiationprotection, 3 to 5 years experience with a broad byproduct material license,and certification by The American Board of Health Physics or eligibility forcertification.6.1.2 ResponsibilityResponsibility for the safe operation of the reactor facility SHALL be withinthe chain of command shown in the organization chart. Individuals at thevarious management levels, in addition to having responsibility for thepolicies and operation of the reactor facility, SHALL be responsible forsafeguarding the public and facility personnel from undue radiationexposures and for adhering to all requirements of the operating license andtechnical specifications.In all instances, responsibilities of one level may be assumed by designatedalternates or by higher levels, conditional upon appropriate qualifications.Page 47 of 56 Amendment 39 TECHNICAL SPECIFICATIONS: PENN STATE BREAZEALE REACTOR (PSBR)FACILITY LICENSE NO. R-26.7 RecordsTo fulfill the requirements of applicable regulations, records and logs SHALL beprepared, and retained for the following items:6.7.1 Records to be Retained for at Least Five Yearsa. Log of reactor operation and summary of energy produced or hours thereactor was critical.b. Checks and calibrations procedure file.c. Preventive and corrective electronic maintenance log.d. Major changes in the reactor facility and procedures.e. Experiment authorization file including conclusions that new tests orexperiments did not require a license amendment, as described in10 CFR 50.59.f. Event evaluation forms (including unscheduled shutdowns) andreportable occurrence reports.g. Preventive and corrective maintenance records of associated reactorequipment.h. Facility radiation and contamination surveys.i. Fuel inventories and transfers.j. Surveillance activities as required by the Technical Specifications.k. Records of PSRSC reviews and audits.6.7.2 Records to be Retained for at Least One Training Cyclea. Requalification records for licensed reactor operators and senior reactoroperators.6.7.3 Records to be Retained for the Life of the Reactor Facilitya. Radiation exposure for all personnel monitored in accordance with 10CFR 20.2106.b. Environmental surveys performed outside the facility.c. Radioactive effluents released to the environs.d. Drawings of the reactor facility including changes.e. Records of the results of each review of exceeding the safety limit, theautomatic safety system not functioning as required by TS 2.2, or anylimiting condition for operation not being met.Page 56 of 56 Amdm ent 39