ML12031A223
| ML12031A223 | |
| Person / Time | |
|---|---|
| Site: | Purdue University |
| Issue date: | 01/30/2012 |
| From: | Jenkins J H Purdue University |
| To: | Montgomery C D Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME1594 | |
| Download: ML12031A223 (15) | |
Text
PURDUEU N I V E R S I T Y SCHOOL OF NUCLEAR ENGINEERING30 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 D20
SUBJECT:
PURDUE UNIVERSITY -REQUEST FOR ADDITIONAL INFORMATION REGARDINGTHE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594),RESPONSES TO RAls DATED 6 JULY 2011 (ML101460429)
Dear Ms. Montgomery:
Enclosed please find the responses to the Request for Additional Information regarding the PurdueUniversity Reactor License Renewal dated 6 July 2011. Included with this submission are responses toquestions 3, 4, 7, 10, 17, 19, 20, 22, 24, 29, 34, and 40. This completes the question set included in theabove referenced letter, as summarized in the table below.Letter dated Questions addressed11/15/2011 1, 2, 5, 6, 8, 9, 14, 26, 32,01/04/2012 11, 12, 13, 15, 16,18, 21, 23, 25, 27, 28, 30, 31,33, 35, 36, 37, 38, 3901/30/2012 3, 4, 7, 10, 17, 19, 20, 22, 24, 29, 34, 40A revised version of the Technical Specifications with the changes required by these responses will besubmitted 7 February 2012.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 thiss.submission is tru correct to the best of my knowledge.D ct Radiation LaboratoriesAttachments: As described.Cc: Duane Hardesty, USNRC Project ManagerLeah Jamieson; Purdue University College of EngineeringJim Schweitzer, Purdue University REMAhmed Hassanein, Purdue NESchool of Nuclear EngineeringNuclear Engineering Building ra 400 Central Drive n West Lafayette, IN 47907-2017(765) 494-5739 13 Fax: (765) 494-9570 o https://engineering.purdue.edu/NE PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)REQUESTED ADDITIONAL INFORMATION IN RESPONSE TO RAIs DATED 6 JULY 2011(ML101460429)REGARDING THE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594)3 TS 1.32 and TS1.33: The Reactor secured and Reactor shutdown definitions provided in TS1.32 and TS 1.33 differ from the definitions the NRC has previously found acceptable. Thedefinitions for Reactor Secured and Reactor Shutdown are provided in ANSI/ANS- 15.1-2007,Section 1 as tailored by NUREG-1537. The following are definitions, from guidance provided inNUREG 1537, Appendix 14.1, deemed acceptable:Reactor secured: A reactor is secured when:1. Either there is insufficient moderator available in the reactor to attain criticality orthere is insufficient fissile material present in the reactor to attain criticality underoptimum available conditions of moderation and reflection;2. Or the following conditions exist:a. The reactor is shutdown, as required by TS 1.33, and;b. The requirements of the reactor secure procedure are met.Reactor shutdown: A reactor is shutdown when the following conditions exist:a. The minimum number of neutron absorbing control devices is fully inserted or othersafety devices are in shutdown position, as required by TS;b. The console key switch is in the off position, and the key is removed from the lock;c. No work is in progress involving core fuel, core structure, installed control rods, orcontrol rod drives unless they are physically decoupled from the control rods;d. No experiments are being moved or serviced that have, on movement, reactivityworth exceeding the maximum value allowed for a single experiment, or one dollar,whichever is smaller.Note: For subparagraph d., a single value should be chosen to specify the smaller value ofeither "one dollar" or "the maximum value allowed for a single experiment." Do not specifyboth options in the definition.Please evaluate PUR-1 TS 1.33 against the suggested definitions for Reactor secured andReactor shutdown and propose TS changes or justify your current definitions.The definitions for Reactor Secured and Reactor Shutdown are to be changed as follows (as suggestedin ANSI 15.1-2007 with some minor modifications for operations at PUR-1, none of which change theintent):1.32 Reactor secured: A reactor is secured when:a. Either there is insufficient moderator available in the reactor to attain criticality or there isinsufficient fissile material present in the reactor to attain criticality under optimumavailable conditions of moderation and reflection;b. Or the following conditions exist:The minimum number of neutron absorbing control devices is fully inserted orother safety devices are in shutdown position, as required by technicalspecifications;Page 1 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)ii. Electrical power to the control rod circuits is switched off via the console keyswitch, and the switch key is in proper custody.iii. No work is in progress involving core fuel, core structure, installed control rods,or control rod drives unless they are physically decoupled from the control rods;iv. No experiments are being moved or serviced that have, on movement, reactivityworth exceeding the maximum value allowed for a single experiment.1.33 Reactor shutdown: The reactor is shut down if it is subcritical by at least one dollar in thereference core condition with the reactivity worth of all installed experiments included.Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.4 TS 1.36 and TS 6.6.2: ANSI/ANS-15.1-2007, Section 6.7.2 provides a schedule of events thatrequire special reports. The Reportable Occurrence definition in PUR-1 TS 1.36 that addressesthese special reports does not appear to be consistent with the guidance in ANSIIANS-15.1-2007, Section 6.7.2. Additionally, per NUREG-1537, Appendix 14.1, TS 6.6.2 should state thatspecial written reports should be sent to the NRC document control desk and specialtelephone reports of events should be made to the NRC Operations Center. Please proposechanges to the TS or provide an explanation describing your reason(s) for not incorporatingthe changes.The definition of Reportable Occurrence is removed from the Technical Specifications, and left to T.S.6.6.2, which brings the TS into closer alignment with ANSI/ANS 15.1 and NUREG 1537.The following section will be added to the technical specifications:6.6.2 Non-Routine Reportsa. Special ReportsSpecial reports are used to report unplanned events as well as planned major facility andadministrative changes. The following schedule shall be incorporated in the specifications:(1) There shall be a report not later than the following working day by telephone andconfirmed in writing by facsimile or similar conveyance to licensing authorities, tobe followed by a written report to NRC Document Control that describes thecircumstances of the event within 14 days of any of the following:(a) operation with actual safety system settings for required systems lessconservative than the limiting safety system settings specified in thetechnical specifications,(b) operation in violation of limiting conditions for operation established inthe technical specifications unless prompt remedial action is taken aspermitted in Sec. 3,(c) a reactor safety system component malfunction that renders or couldrender the reactor safety system incapable of performing its intendedsafety function. If the malfunction or condition is caused by maintenance,then no report is required.Page 2 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)(d) an unanticipated or uncontrolled change in reactivity greater than 0.6%Ak/k,(e) abnormal and significant degradation in reactor fuel or cladding, or both,coolant boundary,(f) an observed inadequacy in the implementation of administrative orprocedural controls such that the inadequacy causes or could havecaused the existence or development of an unsafe condition with regardto reactor safety;Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.7 TS Section 3.0: NUREG-1537 states the content of the TSs follow ANSIIANS 15.1 guidance.ANSI/ANS-15.1-2007 Section 3.5 provides specifications for the ventilation systems. Section 3of the PUR-1 TSs does not contain Limiting Conditions for Operation of the VentilationSystems as referenced by ANSI/ANS-15.1-2007. Please propose TS changes for the ventilationsystem limiting conditions for operations (LCOs) or provide an explanation describing yourreason(s) for not incorporating the changes.The ventilation system for the reactor room is always on, except during maintenance and testing.Maintenance and testing do not generally occur during operations.The PUR-1 TS do contain an LCO for operation of the ventilation system, TS 3.4. The TS 3.4.a.1 waschanged in response to Q1 1, and is shown here.3.4 ConfinementApplicability -This specification applies to the integrity of the reactor room.Obiective -The objective is to limit and control the release of airborne radioactive material from thereactor room.Specification -a. During reactor operation the following conditions will be met:1. The reactor room will be maintained at a negative pressure of at least 0.05 inches ofwater with the operation of the room exhaust fan.10 TS 3.3: ANSI/ANS-15.1-2007, Section 3.3 provides a list of minimum operating equipment oroperating limits, or both, for the limiting conditions for operations for the coolant systems.PUR-1 TS 3.3 specifies the limiting conditions for operations for the water chemistry andcoolant level specifications. PUR-1 TS 3.3 does not contain specifications for the reactor poolcoolant system parameters listed in ANSIIANS 15.1, Section 3.3, such as pool temperature(core cooling) or leak or loss-of-coolant detection. Please propose TS changes to meet thespecification operating limits for the coolant system by ANSI/ANS 15.1, Section 3.3 or providean explanation describing your reason(s) for not incorporating the changes.Page 3 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)The appropriate items from ANSI 15.1-2007, Sec. 3.3 are included in the TS 3.3, namely pH andresistivity (as suggested in 3.3(9) of ANSI 15.1), and coolant level limits (as suggested in 3.3(3) of ANSI15.1). None of the other systems mentioned in ANSI 15.1-2007, Sec. 3.3 are applicable to PUR-1.As determined in NUREG-1283, the Safety Evaluation Report for PUR-1, Section 14.4,"The reactor pool is designed to prevent unintentional drainage. The pool is constructed of astainless steel liner and set in a second steel tank with the interstitial region filled with sand. Thetank rests on a concrete pad about 4.6 m below the floor of the reactor room, which is in thebasement of the building. The pool has no drains or coolant pipes that could open or break.Therefore, a sudden loss of coolant is considered to be extremely unlikely. Furthermore, if thepool drained instantaneously, while the reactor was operating, the loss of water (moderator)would shut down the reactor."The pool water level is checked at least weekly, and before every startup. And historical records ofmakeup water use are maintained. Substantive changes in makeup water volumes would be identifiedeach time makeup water is added, and compared to historical data. Therefore, a leak or loss-of-coolantdetection system is not required.No changes will be made to TS 3.3.17 TS Section 4.0: ANSI/ANS-15.1-2007, Section 4 states that for each surveillance requirement(SR), it should be specified if the surveillance activity can or cannot be deferred during reactorshutdown, as well as, guidance pertaining to deferred SR that must be performed prior toreactor operations.(a) a. Please identify those surveillances that may be deferred during reactor shutdown,and;(b) b. Identify systems and/or components that require surveillance after any addition,modification, or maintenance before declaring that system operational in accordancewith the original specifications to which the systems were designed and fabricated.This is already done in TS 4.1 and 4.2. For 4.3, the following changes are made:a. The pH of the primary coolant shall be recorded monthly, not to exceed six weeks. Thiscannot be deferred during reactor shutdown.b. The conductivity of the primary coolant shall be recorded monthly, not to exceed sixweeks. This cannot be deferred during reactor shutdown.c. The reactor pool water will be at or above the height of the skimmer trough whenever thereactor is operated.d. The primary coolant shall be sampled monthly, not to exceed six weeks, and analyzed forgross alpha and beta activity. This cannot be deferred during reactor shutdown.19 TS 4.3. TS 4.3(d) specifies a monthly primary coolant sampling requirement for gross alphaand beta activity. Please update the TS to indicate under which modes of reactor operationmonthly sampling is required. Also, consider whether a corresponding LCO for thissurveillance is required in TS 3.3This was already answered in the response to Q1 7. An LCO is not necessary.Page 4 of 731 January 2012 PUR-1: Responses to Part of RAls dated 6 July 2011 (ML101460429)20 TS 4.4(d): TS 4.4(d) specifies inspection requirements for the fuel cladding. Per the guidanceof ANSIIANS-15.1-2007, fuel inspections, if appropriate, are normally included as part ofreactor core parameters (Section 3.1 / Section 4.1). Please consider moving TS 4.4(d) forinspecting fuel assemblies into a separate TS from confinement surveillance. Additionally,please identify the Section 3 LCO that establishes the minimum performance level for thissurveillance or add an LCO, if needed.TS 4.4.d has been moved to TS 5.2.5, as recommended in ANSI 15.1 Sec 5.3.5.2 Fuel Assemblies5.2.5 Representative fuel assemblies shall be inspected annually for channel blockage or platedeformation, with no interval to exceed 15 months.22 ANSI/ANS-15.1-2007, Section 4.7.2 provides for dosimetry monitoring of effluents at theboundary of the facility and for environmental monitoring, e.g., sampling of soil, vegetation, orwater in the vicinity of the facility. TS 6.6.1.a.4. discusses results of surveillances required bythese TSs, but the PUR-1 TS do not appear to contain any such surveillance requirements.Please propose TSs to address these requirements, reference where the requirements exist,or provide an explanation describing your reason(s) for not incorporating the changes.PUR-1 is a small training reactor, and generates no effluents. The TS 6.6.1 discusses the annual reportrequirements, which is similar to the requirements outlined in ANSI 15.1-2007 6.7.2. The annual reportshave summarized that PUR-1 releases no effluents.24 TS 5.3. Guidance in ANSIIANS-15.1-2007, Section 5.3 states there should be requirements forperiodic fuel inspection and conditions for operation, as appropriate for operation of thereactor with damaged fuel. Please update the TS to establish surveillance for fuel conditionand limiting conditions for operation when and if the reactor can operate with damaged fuel(LCO) or justify why these are not required.A description for surveillance of the fuel condition is already provided for in 4.4.d (now 5.3.6) and 4.3.d.Based on the long successful history of fuel integrity at PUR-1, the excellent control of water chemistrywith no evidence of fuel degredation, and the fact that coolant water is tested monthly to verify fuelintegrity, PUR-1 does not see an LCO for operation with damaged fuel as necessary.29 TS 6.1.11, TS 6.1.14: ANSI/ANS-15.1-2007, Section 6.1.3(3) provides guidance for eventsrequiring the presence at the facility of the senior reactor operator. Please update PUR-1 TS6.1.11 and 6.1.14 for compliance with the requirements in ANSI/ANS-15.1- 2007, Section6.1.3(3) and 10 CFR 50.54(m)(1) or provide an explanation describing your reason(s) for notincorporating the changes.TS 6.1.11 and 6.1.14 have been moved to the new 6.1.2 (Staffing). Item (3) reads as follows:(3) Events requiring the presence at the facility of a senior reactor operator are(a) Initial startup and approach to power following a core change. The presence of an SROat the reactor facility is unnecessary for the initial daily start up, provided the coreremains unchanged from the previous run;(b) All fuel or control-rod relocations within the core region;Page 5 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)(c) Recovery from an unplanned or unscheduled shutdown except in instances whichresulting from the following(i) A verified electrical power failure or interruption exclusive of internal powersupply failures or interruption of the reactor instrumentation, control, and safetysystems;(ii) Accidental manipulation of equipment in a manner which does not affect thesafety of the reactor;(iii) A verified practice of the evacuation of the building initiated by persons exclusiveof 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.34 Section 5.1 Site and Facility Description. ANSI/ANS-15.1-2007, Section 5.1 provides guidanceto provide a general description of the site and facility including location and exclusion areas.Please update TS 5.1 to describe in detail which areas are under the jurisdiction of the reactorlicense (licensed area) and include a description of the facility location, as well as, the locationof exclusion and restricted areas, as appropriate.Section 5.1 of ANSI 15.1-2007 reads as follows:5.1 Site Description5.1.1 The reactor is located on the ground floor of the Duncan Annex of the ElectricalEngineering Building, Purdue University, West Lafayette, Indiana.5.1.2 The School of Nuclear Engineering controls approximately 5000 square feet of theDuncan Annex ground floor, which includes the reactor room. Access to the Nuclear Engineeringcontrolled area is restricted except when classes are held there.5.1.3 The licensed areas include the reactor room, and a fuel storage room. Both of theseareas are restricted to authorized personnel, or those escorted by authorized personnel.5.1.4 The reactor room remains locked at all times except for the entry or exit of authorizedpersonnel or those escorted by authorized personnel, equipment, or materials.5.1.5 The PUR-1 reactor room is a closed room designed to restrict leakage.5.1.6 The minimum free volume of the reactor room is approximately 15,000 cubic feet.5.1.7 The ventilation system is designed to exhaust air or other gases from the reactor roomthrough an exhaust vent at a minimum of 50 feet above the ground.5.1.8 Openings into the reactor room consist of the following:a. Three personnel doorsb. One door to a storage room with no outside access.c. Air intakePage 6 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)d. Air exhauste. Sewer ventThe information requested in this question is already provided in 5.1.3.40 TS 4.2(a) and Table Ill. The Reactor Safety System channels required to be tested before eachreactor startup following a shutdown in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> are provided in Table III asreferenced by TS 4.2(a). The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement for this specification has no basis. Pleaseprovide adequate justification for the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement or revise the TS to be consistent withNUREG-1537, Appendix 14.1, which requires surveillance only if the reactor is secured(assuming the updated definitions for reactor shutdown and reactor secured as tailored byNUREG-1537 (see RAI 3)). The following is an example revision based on NUREG 1537,Appendix 14.1 previously found acceptable to the NRC: a. A channel test of each of thereactor safety system channels listed in Table Ill shall be performed prior to reactor operation:L anytime the reactor has been placed in a secure condition, and ii. monthly, not to exceed 6weeks, since last channel test < LIST TABLE Ill SURVEILLANCES>We disagree with the definitions suggested in Q3, and have modified our existing definitions slightly to bemore consistent with ANSI 15.1. However, they were already similar to the ANSI 15.1 recommendeddefinitions for "reactor shutdown" and "reactor secure".The reactor can be placed in a secure shutdown condition by the removal of the key from the console keyswitch (which opens the circuit for the control rod electromagnets) without de-energizing any of the otherinstrumentation and control systems. This would allow for an operator to leave the room with other non-operating personnel present, then he can return and resume operations without performing a new start-upwith channel tests. This is of particular importance with a small operations staff such as the one at PUR-1.Furthermore, item (5) of NUREG 1537 Appendix 14.1 (see page 32 of Appendix 14.1) reads as follows:"(5) Scram and Power Measuring ChannelsChannel tests of all scram and power measuring channels required by technicalspecifications, including scram actions with safety rod release and interlocks, should beperformed before each reactor startup following a shutdown of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> orfollowing each secured shutdown. If the reactor operating schedule calls for no securedshutdowns, the channel tests should be performed at least quarterly."There appears to be some disparity between NUREG 1537 and ANSI 15.1 over what secured shutdownentails. Utilizing the present definition of "reactor secured" from ANSI 15.1 (see the answer to Q3), andthe reasoning described above which describes a condition where an operator may need to leave thereactor room temporarily with non-operations personnel present, we do not agree that a channel test isnecessary after every such secured shutdown, and the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is sufficient. Moreover, we feelthe 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is justified because: (1) the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement in the PUR-1 TS is moreconservative than the 24 suggested by NUREG 1537, (2) the reactor can be placed in a "securedshutdown" condition without de-energizing the I&C systems, (3) based on the operational experience atPUR-1 which indicates that the electronics are stable for periods of days. Therefore, we see no reason tomake any changes.Page 7 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)REQUESTED ADDITIONAL INFORMATION IN RESPONSE TO RAIs DATED 6 JULY 2011(ML101460429)REGARDING THE PURDUE UNIVERSITY REACTOR LICENSE RENEWAL (TAC NO. ME 1594)3. TS 1.32 and TS1.33: The Reactor secured and Reactor shutdown definitions provided in TS1.32 and TS 1.33 differ from the definitions the NRC has previously found acceptable. Thedefinitions for Reactor Secured and Reactor Shutdown are provided in ANSIIANS- 15.1-2007,Section 1 as tailored by NUREG-1537. The following are definitions, from guidance provided inNUREG 1537, Appendix 14.1, deemed acceptable:Reactor secured: A reactor is secured when:1. Either there is insufficient moderator available in the reactor to attain criticality orthere is insufficient fissile material present in the reactor to attain criticality underoptimum available conditions of moderation and reflection;2. Or the following conditions exist:a. The reactor is shutdown, as required by TS 1.33, and;b. The requirements of the reactor secure procedure are met.Reactor shutdown: A reactor is shutdown when the following conditions exist:a. The minimum number of neutron absorbing control devices is fully inserted or othersafety devices are in shutdown position, as required by TS;b. The console key switch is in the off position, and the key is removed from the lock;c. No work is in progress involving core fuel, core structure, installed control rods, orcontrol rod drives unless they are physically decoupled from the control rods;d. No experiments are being moved or serviced that have, on movement, reactivityworth exceeding the maximum value allowed for a single experiment, or one dollar,whichever is smaller.Note: For subparagraph d., a single value should be chosen to specify the smaller value ofeither "one dollar" or "the maximum value allowed for a single experiment." Do not specifyboth options in the definition.Please evaluate PUR-1 TS 1.33 against the suggested definitions for Reactor secured andReactor shutdown and propose TS changes or justify your current definitions.The definitions for Reactor Secured and Reactor Shutdown are to be changed as follows (as suggestedin ANSI 15.1-2007 with some minor modifications for operations at PUR-1, none of which change theintent):1.32 Reactor secured: A reactor is secured when:a. Either there is insufficient moderator available in the reactor to attain criticality or there isinsufficient fissile material present in the reactor to attain criticality under optimumavailable conditions of moderation and reflection;b. Or the following conditions exist:The minimum number of neutron absorbing control devices is fully inserted orother safety devices are in shutdown position, as required by technicalspecifications;Page 1 of 731 January 2012 PUR-A: Responses to Part of RAIs dated 6 July 2011 (ML101460429)ii. Electrical power to the control rod circuits is switched off via the console keyswitch, and the switch key is in proper custody.iii. No work is in progress involving core fuel, core structure, installed control rods,or control rod drives unless they are physically decoupled from the control rods;iv. No experiments are being moved or serviced that have, on movement, reactivityworth exceeding the maximum value allowed for a single experiment.1.33 Reactor shutdown: The reactor is shut down if it is subcritical by at least one dollar in thereference core condition with the reactivity worth of all installed experiments included.Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.4. TS 1.36 and TS 6.6.2: ANSI/ANS-15.1-2007, Section 6.7.2 provides a schedule of events thatrequire special reports. The Reportable Occurrence definition in PUR-1 TS 1.36 that addressesthese special reports does not appear to be consistent with the guidance in ANSI/ANS-15. 1-2007, Section 6.7.2. Additionally, per NUREG-1537, Appendix 14.1, TS 6.6.2 should state thatspecial written reports should be sent to the NRC document control desk and specialtelephone reports of events should be made to the NRC Operations Center. Please proposechanges to the TS or provide an explanation describing your reason(s) for not incorporatingthe changes.The definition of Reportable Occurrence is removed from the Technical Specifications, and left to T.S.6.6.2, which brings the TS into closer alignment with ANSI/ANS 15.1 and NUREG 1537.The following section will be added to the technical specifications:6.6.2 Non-Routine Reportsa. Special ReportsSpecial reports are used to report unplanned events as well as planned major facility andadministrative changes. The following schedule shall be incorporated in the specifications:(1) There shall be a report not later than the following working day by telephone andconfirmed in writing by facsimile or similar conveyance to licensing authorities, tobe followed by a written report to NRC Document Control that describes thecircumstances of the event within 14 days of any of the following:(a) operation with actual safety system settings for required systems lessconservative than the limiting safety system settings specified in thetechnical specifications,(b) operation in violation of limiting conditions for operation established inthe technical specifications unless prompt remedial action is taken aspermitted in Sec. 3,(c) a reactor safety system component malfunction that renders or couldrender the reactor safety system incapable of performing its intendedsafety function. If the malfunction or condition is caused by maintenance,then no report is required.Page 2 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)(d) an unanticipated or uncontrolled change in reactivity greater than 0.6%Ak/k,(e) abnormal and significant degradation in reactor fuel or cladding, or both,coolant boundary,(f) an observed inadequacy in the implementation of administrative orprocedural controls such that the inadequacy causes or could havecaused the existence or development of an unsafe condition with regardto reactor safety;Justification: To bring TS into alignment with ANSI/ANS-15.1-2007 and NUREG 1537.7. TS Section 3.0: NUREG-1537 states the content of the TSs follow ANSI/ANS 15.1 guidance.ANSI/ANS-15.1-2007 Section 3.5 provides specifications for the ventilation systems. Section 3of the PUR-1 TSs does not contain Limiting Conditions for Operation of the VentilationSystems as referenced by ANSI/ANS-15.1-2007. Please propose TS changes for the ventilationsystem limiting conditions for operations (LCOs) or provide an explanation describing yourreason(s) for not incorporating the changes.The ventilation system for the reactor room is always on, except during maintenance and testing.Maintenance and testing do not generally occur during operations.The PUR-1 TS do contain an LCO for operation of the ventilation system, TS 3.4. The TS 3.4.a.1 waschanged in response to Q1 1, and is shown here.3.4 ConfinementApplicability -This specification applies to the integrity of the reactor room.Obiective -The objective is to limit and control the release of airborne radioactive material from thereactor room.Specification -a. During reactor operation the following conditions will be met:1. The reactor room will be maintained at a negative pressure of at least 0.05 inches ofwater with the operation of the room exhaust fan.10. TS 3.3: ANSI/ANS-15.1-2007, Section 3.3 provides a list of minimum operating equipment oroperating limits, or both, for the limiting conditions for operations for the coolant systems.PUR-1 TS 3.3 specifies the limiting conditions for operations for the water chemistry andcoolant level specifications. PUR-1 TS 3.3 does not contain specifications for the reactor poolcoolant system parameters listed in ANSI/ANS 15.1, Section 3.3, such as pool temperature(core cooling) or leak or loss-of-coolant detection. Please propose TS changes to meet thespecification operating limits for the coolant system by ANSI/ANS 15.1, Section 3.3 or providean explanation describing your reason(s) for not incorporating the changes.Page 3of7 31 January 2012Page 3 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)The appropriate items from ANSI 15.1-2007, Sec. 3.3 are included in the TS 3.3, namely pH andresistivity (as suggested in 3.3(9) of ANSI 15.1), and coolant level limits (as suggested in 3.3(3) of ANSI15.1). None of the other systems mentioned in ANSI 15.1-2007, Sec. 3.3 are applicable to PUR-1.As determined in NUREG-1 283, the Safety Evaluation Report for PUR-1, Section 14.4,"The reactor pool is designed to prevent unintentional drainage. The pool is constructed of astainless steel liner and set in a second steel tank with the interstitial region filled with sand. Thetank rests on a concrete pad about 4.6 m below the floor of the reactor room, which is in thebasement of the building. The pool has no drains or coolant pipes that could open or break.Therefore, a sudden loss of coolant is considered to be extremely unlikely. Furthermore, if thepool drained instantaneously, while the reactor was operating, the loss of water (moderator)would shut down the reactor."The pool water level is checked at least weekly, and before every startup. And historical records ofmakeup water use are maintained. Substantive changes in makeup water volumes would be identifiedeach time makeup water is added, and compared to historical data. Therefore, a leak or loss-of-coolantdetection system is not required.No changes will be made to TS 3.3.17. TS Section 4.0: ANSI/ANS-15.1-2007, Section 4 states that for each surveillance requirement(SR), it should be specified if the surveillance activity can or cannot be deferred during reactorshutdown, as well as, guidance pertaining to deferred SR that must be performed prior toreactor operations.(a) a. Please identify those surveillances that may be deferred during reactor shutdown,and;(b) b. Identify systems and/or components that require surveillance after any addition,modification, or maintenance before declaring that system operational in accordancewith the original specifications to which the systems were designed and fabricated.This is already done in TS 4.1 and 4.2. For 4.3, the following changes are made:a. The pH of the primary coolant shall be recorded monthly, not to exceed six weeks. Thiscannot be deferred during reactor shutdown.b. The conductivity of the primary coolant shall be recorded monthly, not to exceed sixweeks. This cannot be deferred during reactor shutdown.c. The reactor pool water will be at or above the height of the skimmer trough whenever thereactor is operated.d. The primary coolant shall be sampled monthly, not to exceed six weeks, and analyzed forgross alpha and beta activity. This cannot be deferred during reactor shutdown.19. TS 4.3. TS 4.3(d) specifies a monthly primary coolant sampling requirement for gross alphaand beta activity. Please update the TS to indicate under which modes of reactor operationmonthly sampling is required. Also, consider whether a corresponding LCO for thissurveillance is required in TS 3.3This was already answered in the response to Q1 7. An LCO is not necessary.Page 4 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)20. TS 4.4(d): TS 4.4(d) specifies inspection requirements for the fuel cladding. Per the guidanceof ANSI/ANS-15.1-2007, fuel inspections, if appropriate, are normally included as part ofreactor core parameters (Section 3.1 / Section 4.1). Please consider moving TS 4.4(d) forinspecting fuel assemblies into a separate TS from confinement surveillance. Additionally,please identify the Section 3 LCO that establishes the minimum performance level for thissurveillance or add an LCO, if needed.TS 4.4.d has been moved to TS 5.2.5, as recommended in ANSI 15.1 Sec 5.3.5.2 Fuel Assemblies5.2.5 Representative fuel assemblies shall be inspected annually for channel blockage or platedeformation, with no interval to exceed 15 months.22. ANSIIANS-15.1-2007, Section 4.7.2 provides for dosimetry monitoring of effluents at theboundary of the facility and for environmental monitoring, e.g., sampling of soil, vegetation, orwater in the vicinity of the facility. TS 6.6. 1.a.4. discusses results of surveillances required bythese TSs, but the PUR-1 TS do not appear to contain any such surveillance requirements.Please propose TSs to address these requirements, reference where the requirements exist,or provide an explanation describing your reason(s) for not incorporating the changes.PUR-1 is a small training reactor, and generates no effluents. The TS 6.6.1 discusses the annual reportrequirements, which is similar to the requirements outlined in ANSI 15.1-2007 6.7.2. The annual reportshave summarized that PUR-1 releases no effluents.24. TS 5.3. Guidance in ANSI/ANS-15.1-2007, Section 5.3 states there should be requirements forperiodic fuel inspection and conditions for operation, as appropriate for operation of thereactor with damaged fueL Please update the TS to establish surveillance for fuel conditionand limiting conditions for operation when and if the reactor can operate with damaged fuel(LCO) or justify why these are not required.A description for surveillance of the fuel condition is already provided for in 4.4.d (now 5.3.6) and 4.3.d.Based on the long successful history of fuel integrity at PUR-1, the excellent control of water chemistrywith no evidence of fuel degredation, and the fact that coolant water is tested monthly to verify fuelintegrity, PUR-1 does not see an LCO for operation with damaged fuel as necessary.29. TS 6.1.11, TS 6.1.14: ANSI/ANS-15.1-2007, Section 6.1.3(3) provides guidance for eventsrequiring the presence at the facility of the senior reactor operator. Please update PUR-1 TS6.1.11 and 6.1.14 for compliance with the requirements in ANSI/ANS-15.1- 2007, Section6.1.3(3) and 10 CFR 50.54(m)(1) or provide an explanation describing your reason(s) for notincorporating the changes.TS 6.1.11 and 6.1.14 have been moved to the new 6.1.2 (Staffing). Item (3) reads as follows:(3) Events requiring the presence at the facility of a senior reactor operator are(a) Initial startup and approach to power following a core change. The presence of an SROat the reactor facility is unnecessary for the initial daily start up, provided the coreremains unchanged from the previous run;(b) All fuel or control-rod relocations within the core region;Page 5 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)(c) Recovery from an unplanned or unscheduled shutdown except in instances whichresulting from the following(i) A verified electrical power failure or interruption exclusive of internal powersupply failures or interruption of the reactor instrumentation, control, and safetysystems;(ii) Accidental manipulation of equipment in a manner which does not affect thesafety of the reactor;(iii) A verified practice of the evacuation of the building initiated by persons exclusiveof 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.34. Section 5.1 Site and Facility Description. ANSI/ANS-15.1-2007, Section 5.1 provides guidanceto provide a general description of the site and facility including location and exclusion areas.Please update TS 5.1 to describe in detail which areas are under the jurisdiction of the reactorlicense (licensed area) and include a description of the facility location, as well as, the locationof exclusion and restricted areas, as appropriate.Section 5.1 of ANSI 15.1-2007 reads as follows:5.1 Site Description5.1.1 The reactor is located on the ground floor of the Duncan Annex of the ElectricalEngineering Building, Purdue University, West Lafayette, Indiana.5.1.2 The School of Nuclear Engineering controls approximately 5000 square feet of theDuncan Annex ground floor, which includes the reactor room. Access to the Nuclear Engineeringcontrolled area is restricted except when classes are held there.5.1.3 The licensed areas include the reactor room, and a fuel storage room. Both of theseareas are restricted to authorized personnel, or those escorted by authorized personnel.5.1.4 The reactor room remains locked at all times except for the entry or exit of authorizedpersonnel or those escorted by authorized personnel, equipment, or materials.5.1.5 The PUR-1 reactor room is a closed room designed to restrict leakage.5.1.6 The minimum free volume of the reactor room is approximately 15,000 cubic feet.5.1.7 The ventilation system is designed to exhaust air or other gases from the reactor roomthrough an exhaust vent at a minimum of 50 feet above the ground.5.1.8 Openings into the reactor room consist of the following:a. Three personnel doorsb. One door to a storage room with no outside access.c. Air intakePage 6 of 731 January 2012 PUR-1: Responses to Part of RAIs dated 6 July 2011 (ML101460429)d. Air exhauste. Sewer ventThe information requested in this question is already provided in 5.1.3.40. TS 4,2(a) and Table Ill. The Reactor Safety System channels required to be tested before eachreactor startup following a shutdown in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> are provided in Table Ill asreferenced by TS 4.2(a). The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement for this specification has no basis. Pleaseprovide adequate justification for the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement or revise the TS to be consistent withNUREG-1537, Appendix 14.1, which requires surveillance only if the reactor is secured(assuming the updated definitions for reactor shutdown and reactor secured as tailored byNUREG-1537 (see RAI 3)). The following is an example revision based on NUREG 1537,Appendix 14.1 previously found acceptable to the NRC: a. A channel test of each of thereactor safety system channels listed in Table Ill shall be performed prior to reactor operation:i. anytime the reactor has been placed in a secure condition, and ii. monthly, not to exceed 6weeks, since last channel test < LIST TABLE III SURVEILLANCES>We disagree with the definitions suggested in Q3, and have modified our existing definitions slightly to bemore consistent with ANSI 15.1. However, they were already similar to the ANSI 15.1 recommendeddefinitions for "reactor shutdown" and "reactor secure".The reactor can be placed in a secure shutdown condition by the removal of the key from the console keyswitch (which opens the circuit for the control rod electromagnets) without de-energizing any of the otherinstrumentation and control systems. This would allow for an operator to leave the room with other non-operating personnel present, then he can return and resume operations without performing a new start-upwith channel tests. This is of particular importance with a small operations staff such as the one at PUR-1.Furthermore, item (5) of NUREG 1537 Appendix 14.1 (see page 32 of Appendix 14.1) reads as follows:"(5) Scram and Power Measuring ChannelsChannel tests of all scram and power measuring channels required by technicalspecifications, including scram actions with safety rod release and interlocks, should beperformed before each reactor startup following a shutdown of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> orfollowing each secured shutdown. If the reactor operating schedule calls for no securedshutdowns, the channel tests should be performed at least quarterly."There appears to be some disparity between NUREG 1537 and ANSI 15.1 over what secured shutdownentails. Utilizing the present definition of "reactor secured" from ANSI 15.1 (see the answer to Q3), andthe reasoning described above which describes a condition where an operator may need to leave thereactor room temporarily with non-operations personnel present, we do not agree that a' channel test isnecessary after every such secured shutdown, and the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is sufficient. Moreover, we feelthe 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement is justified because: (1) the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> requirement in the PUR-1 TS is moreconservative than the 24 suggested by NUREG 1537, (2) the reactor can be placed in a "securedshutdown" condition without de-energizing the I&C systems, (3) based on the operational experience atPUR-1 which indicates that the electronics are stable for periods of days. Therefore, we see no reason tomake any changes.Page 7 of 7 31 January2012Page 7 of 731 January 2012