ML12006A193

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

ML12006A193
Person / Time
Site:	Purdue University
Issue date:	01/04/2012
From:	Jenkins J H Purdue University
To:	Montgomery C K Document Control Desk, Licensing Processes Branch (DPR)
References
TAC ME1594
Download: ML12006A193 (13)

Text

PURDUEN N I V E R S I 1 YSCHOOL OF NUCLEAR ENGINEERING4 Jan 2012Document Control DeskUS Nuclear Regulatory CommissionOne White Flint North11555 Rockville PikeRockville, MD 20852Attn: Ms. Cindy Montgomery, Research & Test Reactors (NRR/DPR/PRLB), Mailstop 012 D20SUBJECT: PURDUE UNIVERSITY -REQUEST FOR ADDITIONAL INFORMATION REGARDINGTHE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594),RESPONSES TO RAIs DATED 6 JULY 2011 (ML1 01460429)Dear Ms. Montgomery:Enclosed please find the responses to the Request for Additional Information regarding the PurdueUniversity Reactor License Renewal dated 6 July 2011. Included with this submission are responses toquestions 11, 12, 13, 15, 16, 18, 21, 23, 25, 27, 28, 30, 31, 33, 35, 36, and 37. Further responses will beforthcoming as previously arranged.Should you have any questions or require further information, please don't hesitate to call me at765.496.3573, or e-mail at jere@purdue.edu.I hereby certify under penalty of perjury with my signature below that the information contained in thissubmission is true and correct to the best of my knowledge.Attachments: As described.Cc: Duane Hardesty, USNRC Project ManagerLeah Jamieson; Purdue University College of EngineeringJim Schweitzer, Purdue University REMAhmed Hassanein, Purdue NEfiwv~rc)School of Nuclear EngineeringNuclear Engineering Building a 400 Central Drive a West Lafayette, IN 47907-2017(765) 494-5739 v Fax: (765) 494-9570 w https:/lengineering.purdue.edu/NE PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)REQUESTED ADDITIONAL INFORMATION IN RESPONSE TO RAIs DATED 6 JULY 2011(ML101460429)REGARDING THE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594)11. NUREG-1537 states the content of the TSs follow ANSI/ANS 15.1 guidance. In TS 3.4, aspecification states that the reactor room will be maintained at a negative pressure of 0.05inches of water, but doesn't state what equipment maintains that negative pressure.ANSI/ANS-15.1-2007 states that equipment required to achieve confinement be specified.There is no specification(s) or surveillances for the ventilation system, which is used tomaintain confinement during reactor operations. Please update Section 3 of the TS to identifyequipment required to achieve confinement and to specify appropriate surveillances inSection 4 of the TSs for the equipment or provide an explanation describing your reason(s)for not incorporating the changes.PUR-1 ResponseTS 3.4.a.1 will be changed as follows:Specification -a. During reactor operation the following conditions will be met:1. The reactor room will be maintained at a negative pressure of at least 0.05 inches ofwater with the operation of the room exhaust fan.Justification: The ventilation system surveillances are described in TS 4.4, including the negativepressure (developed by the exhaust fan pulling through the HEPA filter) which is checked weekly (4.4.a),and the inlet and outlet dampers (TS 4.4.b) checked semi-annually. These surveillances are alreadycovered, therefore no changes are needed12. TS 3.4. TS 3.4(b) specifies requirements for HEPA filters or equivalent. However, there is nocorresponding surveillance associated with the HEPA filters. Please update the TS to includea surveillance that indicates when such filters are checked and any criteria for requiring afilter change or justify why this surveillance is not required.PUR-1 ResponseThe surveillance of the HEPA filter is done every time the room pressure is measured. If the negativeroom pressure requirement is not able to be met, the filter is changed. This pressure is checked weeklyas per TS 4.4.a. Therefore, a surveillance requirement is not necessary in the TS.13. TS 3.4. TS 3.4(d) specifies that the reactor operator can secure the air conditioner. Thepurpose of this TS or the established constraint on the system is not clear nor substantiatedin the bases. Please consider if this TS is required and update the TS and/or bases asrequired.PUR-1 ResponsePage 1 of 11 4 January 2012Page I of 114 January 2012 3N/lnpa'anpJfnd'uiJaau!iua//:sdLq

• OLm 6-t'6V (S9L) :xel 6ELS-176t7 (s9L)PUR-A: Responses to Part of RAIs datedtfutp9O01t1I (IW fINI4 9)aA!J(] legua3) OO n 6u!pl!ng 6ujaau!6u3 jeapnN3Jo lOO tSThe air conditioner is responsible for the air circulation within the room. Shutting down the air conditioner(which is done on the same switch as the room exhaust fan and damper) limits the spread ofcontamination from a failed experiment within confinement itself, and will limit the spread of contaminationtoward the egress doors and possible spread to the environment external to confinement. Therefore, asstated in the Bases, "the specifications stated above will further reduce the release to the environment".15. TS 4.1: ANSI/ANS-15.1-2007 Section 4.1 provides guidance related to annual measurement ofcore parameters. TS 4. 1(a) contains a requirement for shutdown margin calculations withoutreferring to excess core reactivity measurements. Please update TS 4. 1(a) to be inconformance with ANSI/ANS-15.1-2007 Section 4.1 or discuss how conformance is achieved.PUR-1 ResponseThe calculation of shutdown margin requires the value of core excess reactivity, so it must be determinedprior to calculating shutdown margin. Excess reactivity is determined as part of the shim-safety rod worthmeasurements.16. TS Section 4.0: NUREG-1537 states the content of the TSs follow ANSI/ANS 15.1 guidance.ANSI/ANS-15.1-2007 Section 4.5 provides surveillance requirements for the ventilationsystems. There are no TS under Section 4, Surveillance Requirements, for VentilationSystems as required by ANSI/ANS-15.1-2007. Please propose TS changes for surveillance ofthe ventilation system or provide an explanation describing your reason(s) for notincorporating the changes.PUR-1 ResponseThe ventilation system surveillances are described in TS 4.4, including the negative pressure (developedby the exhaust fan pulling through the HEPA filter) which is checked weekly (4.4.a), and the inlet andoutlet dampers (TS 4.4.b) checked semi-annually. These surveillances are already covered, therefore nochanges are needed.18. TS 4.3: TS 4.3(c) should reference the minimum 13 foot depth as specified in the LCO (TS3.3(c)) for primary coolant and provided in the bases for TS 4.3. Please update the TS toinclude the numerical minimum depth and surveillance interval for this surveillance or justifywhy an alternative measure related to the height of the skimmer trough in TS 4.3(c) is moreappropriate for specifying the minimum performance level of TS 3.3(c). Additionally,prescribe the frequency, scope and minimum water level of this surveillance when the reactoris secured or shutdown or justify why a minimum level is not required.PUR-1 ResponseThe surveillance interval is already included, it is whenever the reactor is operated, as it is also a LCO.The text will be changed as follows:c. The reactor pool water will be at a height of the 13 feet over the top of the core whenever thereactor is operated.9NI833NIDN3 dV31)flN dO 10OHDS A S H 3 A I N flafllufHnaPage 2 of 114 January 2012 PUR-A: Responses to Part of RAIs dated 6 July 2011 (ML101460429)Bases When the reactor pool water is at a height of 13 feet above the core, adequate shielding duringoperations is assured.The 13 feet of water requirement is for shielding during operations. No minimum level is necessary forsafety during shutdown.21. TS 4.5: ANSI/ANS-15.1-2007, Section 6.5. provides the review and approval process to complywith the guidance provided in Section 6.2.3, unless it is a "tried experiment". PUR-1 TS 4.5does defer the proper review and approval of the experiment to Section 6 of the TSs.However, PUR-1 TS 6.2.4(a) and 6.2.4(c) do not provide any of the formal review requirementsor established and approved procedures for experiments. Please update the formal reviewand approval requirements for experiments in PUR-1 TS 6.2.4 to include the requirements ofANSI/ANS-15.1-2007, Section 6.5, identify where the provisions are contained in the PUR-1TS, or justify why they are not required.PUR-1 ResponsePlease see the response to Q27.23. TS 5.0: NUREG-1537 states the content of the TSs follow ANSIIANS 15.1 guidance. ANSI/ANS-15.1-2007 Section 5.0 provides the requirements for Design Features. There are no PUR-1 TSsunder Section 5, Design Features, for the following systems:a. Control Elements, as required by ANSIIANS-15.1-2007 TS 5.2,b. Reactor Coolant System, as required by ANSI/ANS-15.1-2007 TS 5.2,c. Ventilation Systems, as required by ANSI/ANS-15.1-2007 TS 5.1 Please proposechanges to TS for the aforementioned systems or provide an explanation describingyour reason(s) for not incorporating the changes.PUR-1 ResponseThe TS have been changed to reflect the questions in parts a and b as follows:5.2 Reactor Coolant System5.2.1 Primary Cooling System -The PUR-1 primary cooling system is a pool containingapproximately 6,400 gallons of water.5.2.2 Process Water System -The process water system is assembled in one unit andcontains a pump, filter, demineralizer, valves, flow meters, and a heat exchanger (see5.2.4). The demineralizer contains a removable cartridge that is monitored continuouslyfor radioactivity buildup. This system limits, by the use of filters and ion-exchange resin,the aluminum corrosion rate, corrosion product buildup, and neutron activation ofimpurities in the coolant.5.2.3 Primary Coolant Makeup Water System -Makeup water for the pool is taken batchwisefrom the Purdue University water line and is passed through the demineralizer enroute toPage 3 of 11 4 January 2012Page 3 of 114 January 2012 3N/nfpaoafnpfndeupEaufiUa//:Sdd1q , OLS6-176tV (S9L) :Xe4 a 6ELS-176t7 (S9L)PUR-A: Responses to Part of RAJs dated OL*014330t1N(Kt a!Kj] lingua:) 00V7 a 5u!pfn8 5iuaau!u3 JeapnN3uz!.aau!9uit madPlnN Jo lOOqlSthe pool. A vacuum breaker excludes any possibility of siphoning pool water into thesupply line. The pool makeup water system, in addition to the demineralizer, alsoincludes a normally closed manual shutoff and throttle valve and a check valve.5.2.4 Primary Coolant Chiller System -The chiller is designed with three loops. Pool waterpasses through the primary loop, a Freon refrigerant is in the secondary loop, and waterfrom the building water supply is used to remove heat, which is then discharged to thebuilding sewer system. The heat-removal capacity of the heat exchanger is 10.5 kW. Itwas designed to maintain the reactor pool temperature at 750F during continuousoperation at 10 kW.5.3 Reactor Core and Fuel5.3.1 The fuel assemblies shall be MTR type consisting of aluminum clad plates enriched up to20% in the U-235 isotope.5.3.2 A standard fuel assembly shall consist of up to 14 fuel plates containing a maximum of180 grams of U-235.5.3.3 A control fuel assembly shall consist of up to 8 fuel plates containing a maximum of 103grams of U-235.5.3.4 Partially loaded fuel assemblies in which some of the fuel plates are replaced byaluminum plates containing no uranium may be used.5.3.5 The core configuration shall consist of 13 standard fuel assemblies as described in 5.3.2,and 3 control fuel assemblies as described in 5.3.3, and two shim-safety rods and oneregulating rod.5.3.6 Representative fuel assemblies shall be inspected annually, with no interval to exceed 15months.The ventilation system is described in TS 5.1.7.25. TS 6.2.4, TS 6.2.5: Guidance in ANSI/ANS-15.1-2007 states there should be an individual orgroup responsible for implementing the radiation protection program at PUR-1 and anindividual or group that performs periodic audits of the program. In TS 6.2.4 and TS 6.2.5there is no mention of who is responsible for the radiation protection program at PUR-1 orwho performs the periodic audits. Please propose changes to TS or provide an explanationdescribing your reason(s) for not incorporating the changesPUR-1 ResponsePUR-1 has operated under the Purdue University Radiation Safety Program since its early development,which is under the responsibility of the University Radiation Safety Officer and the Institution RadiationSafety Committee. This was mentioned in 6.1.5 of the submitted TS, and 6.1.1 .d of the revision submittedwith these answers. It was also described in 6.1.7 of the original submission, which is now 6.1.4 of therevision. Audits of the Radiation Safety Program are carried out annually by the Radiation Safety Officer.9NII33NIDN3 IV31)flN JO 10OHS A I I S 11 A A I N flHfl(ufflrdPage 4 of 11 4 January 2012 PUR-A: Responses to Part of RAIs dated 6 July 2011 (ML101460429)27. TS 6.2.4(c): ANSI/ANS-15.1-2007, Section 6.2.3 provides guidance for the review function forexperiments as well as other activities. PUR-1 TS 6.2.4(c) indicates that the Committee onReactor Operations (CORO) shall review and approve "proposed tests or experiments whichare significantly different from previous approved tests or experiments." Please explain whatis meant by "significantly different" and propose a quantitative, less subjective, revision toPUR-1 TS 6.2.4.c. that incorporates CORO review for all of the items outlined in ANSI/ANS-15.1-2007, Section 6.2.3 or provide an explanation describing your reason(s) for notincorporating the changes.PUR-1 Response6.2.4(c) as written is very similar to ANSI 15.1-2007 6.5(2), which reads:6.5 Experiments review and approvalApproved experiments shall be carried out in accordance with established andapproved procedures. The following provisions shall be stated:(1) All new experiments or class of experiments shall be reviewed by the reviewgroup (see Sec. 6.2.3) and approved in writing by Level 2 or designated alternatesprior to initiation;(2) Substantive changes to previously approved experiments shall be made onlyafter review by the review group and approved in writing by Level 2 or designatedalternates. Minor changes that do not significantly alter the experiment may beapproved by Level 3 or higher.The details to be reviewed as discussed in TS 6.2.4 a-c are similar to the requirements of ANSI 15.1-2007 Sec. 6.2.3(1-3), and the use of "substantive changes" in to ANSI 15.1-2007 6.5(2) is similar to theuse of "significantly different" in TS 6.2.4c. The critical concept required to be reviewed is the safetysignificance of the changes.28. The regulations in 10 CFR 20.1101 require that each licensee develop, document, andimplement a radiation protection program. NUREG-1537, Chapter 12.1 states that theorganization should meet the non-power reactor standard ANSI/ANS-15.1-2007. ANSIIANS-15.1, Section 6.3 states that the facility shall implement a radiation protection program inaccordance with the guidelines in ANSI/ANS-15.1. However the radiation protection programis not presented or discussed in the PUR-1 TS 6.0. Please provide a TS to meet the criteria in10 CFR 20.1101 and ANSI/ANS-15.1, Section 6.3 or provide an explanation describing yourreason for not incorporating the change.PUR-1 ResponsePUR-1 has operated under the Purdue University Radiation Safety Program since its early development,which is under the responsibility of the University Radiation Safety Officer and the Institution RadiationSafety Committee. This was mentioned in 6.1.5 of the submitted TS, and 6.1.1 .d of the revision submittedwith these answers. It was also described in 6.1.7 of the original submission, which is now 6.1.4 of therevision.Page 5 of 114 January 2012 3N/npea'npnd'6u jaaui6uall:sd4q N OLS6-t6t7 (S9L) :Xe s 6ELS-t,6, (S9L)PUR-1: Responses to Part of RAIs dated ~ a^IJ(] leIJlu) 00t, n 6u!pI!fn 6uijaau!6U3 jeapnN3u!uaau!,8u wValinN jo lootps30. TS 6.6.2: ANSI/ANS-15.1-2007, Section 6.6.2 and 6.7.2(1) provide guidance on licensee actionsfollowing a reportable occurrence. It is not specified in the PUR-1 TS 6.6.2 who can authorizerestart of the reactor after a reportable occurrence where the reactor was shut down. Pleaseclarify this authority.PUR-1 ResponseThe following changes have been made to the TS:TS 6.3 was moved to TS 6.6 as 6.6.1 to more closely align with ANSI 15.1-2007, and the suggested textfrom ANSI 15.1-2007 Sec 6.6.2 was added to clarify the authority to restart, as shown below:6.5 Required ActionsThe following actions shall be taken relating to the types of events listed in Secs. 6.6.1 and 6.6.26.5.1 The following actions shall be taken in the event the Safety Limit is violated:(1) The reactor will be shut down immediately and reactor operation will not beresumed without authorization by the Commission.(2) The Safety Limit Violation shall be reported to the Director of the appropriateNRC Office of Inspection and Enforcement (or designee), the Laboratory Directorand to the CORO not later than the next work day.(3) A Safety Limit Violation Report shall be prepared. The report shall be reviewedby the CORO. This report shall describe (1) applicable circumstances precedingthe violation, (2) effects of the violation upon facility components, systems orstructures, and (3) corrective action taken to prevent recurrence.(4) The Safety Limit Violation Report shall be submitted to the Commission, theCORO and the Reactor Supervisor within 14 days of the violation, in support of arequest to the Commission for authorization to resume operations.6.5.2 The following actions are to be taken in the event of reportable occurrence as defined in1.36.(1) Reactor conditions shall be returned to normal, or the reactor shall be shut down.If it is necessary to shut down the reactor to correct the occurrence, operationsshall not be resumed unless authorized by Level 2 or designated alternates;(2) Occurrence shall be reported to Level 2 or designated alternates and tochartering or licensing authorities as required;(3) Occurrence shall be reviewed by the review group at its next scheduled meeting.31. ANSI/ANS-15.1-2007, Section 6.7.2(2) provides guidance for a TS requirement to provide awritten report to the NRC within 30 days of permanent changes in the PUR-1 organizationinvolving Level I or 2 personnel and significant changes in transient or accident analyses asdescribed in the SAR. This requirement does not seem to appear in TS 6.6. Please amendPUR-1 TS 6.6 to include these requirements, provide reference to wh~refhiesreguigm~ny9NIN3=NI9N3 HV31DnN JO 10OHDSanaunuPage 6 of 11 4 January 21 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)exist in the TS, or provide an explanation describing your reason(s) for not incorporating thechanges.PUR-1 ResponseThe following was added as TS 6.6.2(2)(2) There shall be a written report within 30 days to the chartering or licensing authorities of thefollowing:(a) Permanent changes in the facility organization involving Level 1 or 2 personnel(b) significant changes in the transient or accident analysis as described in the SafetyAnalysis Report.33. Section 5.0 Design Features -This section of the TS requires applicability, objective andbases statements per 10 CFR 50.36. Please update the PUR-1 TS to satisfy this regulatoryrequirement.PUR-1 ResponsePUR-1 does not agree with this question, since the words "applicability" and "objective" do not appear in10 CFR 50.36. Furthermore, ANSI 15.1 does not suggest the necessity of Applicability or Objectivestatements or bases for Sec. 5 (see ANSI 15.1, Sec. 1.2.2), they are only required for Secs. 2, 3, and 4.Furthermore, 10 CFR 50.36 (a)(1) states:"Each applicant for a license authorizing operation of a production or utilization facility shallinclude in his application proposed technical specifications in accordance with therequirements of this section. A summary statement of the bases or reasons for suchspecifications, other than those covering administrative controls, shall also be included in theapplication, but shall not become part of the technical specifications."Since PUR-1 has a long operating history of safe operation, in addition to the fact that the facility hasbeen licensed previously with these technical specifications approved, no further bases are required.35. TS 6.1.8 states that a qualified operator is required at the operating console unless thereactor is shutdown. ANSI/ANS-15.1-2007, Section 6.1.3 (1) requires a licensed operator at thecontrols unless the reactor is secured. Please update the PUR-1 TS to be consistent withANSI/ANS-15.1-2007 or justify why a qualified operator is not required at the controls whenthe reactor is shutdown per PUR-1 TS 1.33.PUR-1 ResponseANSI 15.1-2007, Section 6.1.3(1) requires "a licensed reactor operator in the control room", not a licensedoperator "at the controls" as suggested by Question 35. Since the controls for the reactor sit adjacent tothe reactor pool, there is no "control room" per se. The intent of ANSI 15.1-2007, Section 6.1.3(1) is metin TS 6.1.8, as written.Page 7 of 11 4 January 2012Page 7 of 114 January 2012 3N/npa'anpJndb6ujaau!ual//:sduq w 0LS6-t06 (S9L) :xel m 6ELS-t6i (S9L)PUR-1: Responses to Part of RAIs dated I aAuJ(] leIua:) 00t7 , 6u!p!n 6uf!Juaau!fiu jeapnNUW1U!.ddu.1'uZt JovdpnN oOOWS36. Staffing -The minimum requirements for staffing the reactor in Section 6 of the PUR-1 TSsand not readily clear. ANSI/ANS-15.1-2007, Section 6.1.3 provides guidance for minimumstaffing as tailored by NUREG-1537. The following wording for minimum staffing as providedin NUREG 1537, Appendix 14.1 was previously deemed acceptable by the NRC: Staffingrequirements 1. The minimum staffing when the reactor is operating shall be: a. A licensedreactor operator or senior reactor operator in the control room, b. A second designatedperson present at the facility complex able to carry out prescribed written instructions. Theinstructions may, for more complex and higher-power reactors, require initiating the firststages of the emergency plan including evacuation and initial notification procedures.Unexpected absence for as long as 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to accommodate a personal emergency may beacceptable provided immediate action is taken to obtain a replacement, c. A designatedsenior reactor operator shall be present at the facility or readily available on call. "ReadilyAvailable on Call" means an individual who: i. has been specifically designated and thedesignation known to the operator on duty, ii. can be rapidly contacted by phone, by theoperator on duty, iii. is capable of getting to the reactor facility within a reasonable timeunder normal conditions (e.g., 30 minutes or within a 15-mile radius); 2. The minimum staffingwhen the reactor is shutdown shall be a licensed reactor operator or senior reactor operatorin the licensed facility. 3. No licensed reactor operator or senior reactor operator shall berequired within the licensed facility if the reactor is secure.PUR-1 ResponseMany of these requirements already existed in the PUR-1 TS, but they were not organized asrecommended by ANSI 15.1, since they were written before ANSI 15.1 existed. The technicalspecifications have been reorganized and modified slightly as shown below, to more closely match theANSI 15.1 format.6.1.2 Staffing(1) The minimum staffing when the reactor is not secured shall be(a) A licensed reactor operator in the reactor room,(b) The minimum crew for operating the reactor shall consist of 2 (two) persons, oneof whom must be an NRC licensed member of the PUR-1 operations staff, thesecond crew member must be instructed as to how to shut down the reactor inthe event of an emergency.(c) A designated senior reactor operator (unless the operations staff consists of onlyone senior reactor operator, and that individual is operating the reactor) shall bepresent or readily available on call at any time that the reactor is operating."Readily Available on Call means an individual who(i) Has been specifically designates and the designation is known to theoperator on duty,(ii) Can be rapidly contacted by phone or other method by the operator onduty,(iii) Is capable of getting to the reactor facility within a reasonable time under9N, 33N19NY r8'i&? A I I S U A I N flH tcfi~~firPage 8 of 114 January 2012 PUR-A: Responses to Part of RAIs dated 6 July 2011 (M L101460429)(2) No licensed reactor operator or senior reactor operator shall be required within thelicensed facility if the reactor is secure.(3) Events requiring the presence at the facility of a senior reactor operator are(a) Initial startup and approach to power following a core change. The presence ofan SRO at the reactor facility is unnecessary for the initial daily start up, providedthe core remains unchanged from the previous run;(b) All fuel or control-rod relocations within the core region;(c) Recovery from an unplanned or unscheduled shutdown except in instanceswhich resulting from the following(i) A verified electrical power failure or interruption exclusive of internalpower supply failures or interruption of the reactor instrumentation,control, and safety systems;(ii) Accidental manipulation of equipment in a manner which does not affectthe safety of the reactor;(iii) A verified practice of the evacuation of the building initiated by personsexclusive of reactor operations personnel.The SRO shall be notified of the shutdown and shall determine its cause. If due to one of the enumeratedreasons above, he shall decide if his presence is necessary for a subsequent start up.37. PUR-1 Organization: Neither Figure 6.1 nor TS 6.1.5 clearly indicate the organizational level ofthe Head of Nuclear Engineering. Please update the figure and/or TS to reflect the level ofauthority for the Head of the school of Nuclear Engineering or justify why it is not required.PUR-1 ResponseThe NE department head was in the original organization chart from the 1988 license, which predated thelicensee levels specified in ANSI 15.1. Since the organization has been changed to reflect the ANSI 15.1style license levels, we have removed the NE department head from the organization chart, and TS 6.1.5has been modified as follows:In all matters pertaining to the operation of the reactor and the administrative aspects of these technicalspecifications, the Laboratory Director (Level 2) [or the Reactor Supervisor (Level 3) in the absence of theLaboratory Director] shall report to and be directly responsible to the Level 1 Licensee, the Dean of theCollege of Engineering. In all matters pertaining to radiation safety they shall be responsible to theRadiation Safety Committee.Figure 6.1 has been modified to reflect that change.Page 9 of 11 4 January 2012Page 9 of 114 January 2012 3N/npeeanpind6u!jaau!6ua//:sdPL a OLS6-t'6V (S9L) :xeJ a 6ELS-Kt?6 (S9L)PURA1: Responses to Part of RAls dated1flGftd9MN( WtW (U4%f46OiU9# I( lPdiGJua) O0t, a 6u!pI!ng 6u!J~a~u!u3 jealpfN.9uua,9u!3uj ivapnN Jo looqiSIVice Presidentfor ResearchIIRadiationSafetyCommitteeIRadiationSafety Officer~~~~~1IItiCommittee OnI- ReactorOperations-Primarily Administration---Primarily SafetyFIGURE 6.1: PUR-1 Organization38. TS 6.1.6. Please review TS 6.1.6 and correct the typographical error associated with referenceto ANSIIANS-15.4.PUR-1 ResponseMinimum Qualifications of Reactor Personnel -The minimum qualifications should be consistent with theAmerican National Standard for the Selection and Training of Personnel for Research Reactors,ANSI/ANS 15.4, and include the following:Justification of the change is to correct a typo.DNIH33Nl9N3 NV31JfN JO 100HDSA I I S U 3 A I N n2flUHfldPage 10 of 114 January 2012

_PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)FURDUErds to be retained for tl~jt i egj0qpO(#jRR rlity. Theregulatonsr ing10 C .36 require that reviews of exceeding the safety limit (10 CFR50.36(c)(1)(i)(A)), reviews of the failure of the automatic safety system that protects thelimiting safety system settings (LSSSs) (10 CFR 50.36(c)(1)(ii)(A)) and reviews of not meetinglimiting conditions for operation (10 CFR 50.36(c)(2)(i)) be retained until the Commissionterminates the license. Please add these items to section 6.5 of the TSs.PUR-1 ResponseThe technical specifications have been changed as shown:6.5.2 The following records and logs shall be prepared and retained for the life of the facility:a. Gaseous and liquid waste released to the environs.b. Offsite environmental monitoring surveys.c. Radiation exposures for all PUR-1 personnel.d. Updated, corrected, and as-built facility drawings.e. Annual operating reports.f. Reviews of instances where the safety limit was exceeded.g. Reviews of failure of the automatic safety system that protects the limiting safety systemsettings (LSSSs).h. Reviews of instances where limiting conditions of operation were not met.Justification of the change is to bring the Technical Specifications into compliance with 10 CFR 50.36.School of Nuclear EngineeringNuclear Engineering Building s 400 Central Driv4#PsjlLaJ*tVe, IN 47907-2017(765) 494-5739 a Fax: (765) 494-9570 a https://engineering.purdue.edu/NE4 January 2012 PURDUETemplate:tes\Normal.dotmTitle:Subject:Author:Keywords:Comments:Creation Date:Change Number:Last Saved On:Last Saved By:Total Editing Time:Last Printed On:2012-01-04_RAI An~t]qd0J&XNUCLEAR ENGINEERINGS:\REACTOR\RE-LICENSING-2008\RAIs\SUMBITTED\\helios.ecn.purdue.edu\jere\pchome\.pcprefs\AppData\Microsoft\Tem plajere1/4/2012 1:08:00 PM41/4/2012 1:50:00 PMjere35 Minutes1/4/2012 1:58:00 PMAs of Last Complete PrintingNumber of Pages: 11Number of Words: 3,797 (approx.)Number of Characters: 21,648 (approx.)School of Nuclear EngineeringNuclear Engineering Building a 400 Central Drive a West Lafayette, IN 47907-2017(765) 494-5739 a Fax: (765) 494-9570 a https://engineering.purdue.edu/NE