ML16027A126
ML16027A126 | |
Person / Time | |
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Site: | University of California - Irvine |
Issue date: | 12/22/2015 |
From: | Miller G E University of California - Irvine |
To: | Balazik M F Office of Nuclear Reactor Regulation |
References | |
Download: ML16027A126 (62) | |
Text
UNIVERSITY OF CALIFORNIA, IRVINEBERKELEY *DAVIS *IRVINE. LOS ANGELES *RIVERSIDE *SAN DIEGO *SAN FRANCISCO I SANTA BARBARA *SANTA CRUZGeorge E. MillerSenior Lecturer EmeritusDepartment of Chemist.'y andSupervisor, Nuclear Reactor FacilityIRVINE, CA 92697-2025(949) 824-6649 or 824-6082FAX: (949) 824-8571email :gemiller@uci.eduDecember 22nd 2015US Nuclear Regulatory CommissionDocument Control DeskWashington DC 20555-0001Attention: Michael Balazik, Project ManagerRe: Docket 50-326. License R-1 16Re: ML14135A503
Dear Mr. Balazik,
Please find enclosed the response regarding the referenced technical RAIs(dated July 15, 2014). There are also two attachments to the response.I declare under penalty of perjury that the foregoing and the attached are true.and correct.Executed on December 22nd 2015Dr. George B. MillerSupervisorcc. Prof. A.J. Shaka, Director, UCI Nuclear Reactor FacilityJ. T. Wallick, Associate Reactor SupervisorG. L. Bosgraaf, UCI Radiation Safety Officer%p UCI RAI from July 15, 2014 response revised December 18th 2015RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION DATED July 15 2014REGARDING LICENSE RENEWALFOR THE UNIVERSITY OF CALIFORNIA. IRVINE NUCLEAR REACTOR FACILITYLICENSE NO. R-116DOCKET NO. 50-326The U. S. Nuclear Regulator'y Commission (NRC) is continuing its review of the University ofCalifornia, Irvine (UCI) application for the renewal of Facility Operating License No. R-1 16 for theUCI Nuclear Reactor Facility (UCINRF), dated October 18, 1999 (a redacted version of theapplication is available on the NRC's public Web site at www.nrc..iov under AgencywideDocuments Access and Management System (ADAMS) Accession No. ML0831 10112), assupplemented. The NRC staff re view of your safety analysis report (SAR) and proposed technicalspecifications (TSs) identified the following items which need additional clarification or information.Your responses are requested within 30 days from the date of this letter.This request for additional information (RAI) is, in part, based on a comparison of the UCINRF safetyanalysis report and the proposed TSs with NUREG-1537, "Guidance for Preparing and ReviewingApplications for the Licensing of Non-Power Reactors," dated February 1996 and the AmericanNuclear Standards Institute/American Nuclear Society (ANSI/ANS)-15. 1-200 7, "The Development ofTechnical Specifications for Research Reactors."1) In NUREG-1537, Part 1, Section 1.4, "Shared Facilities and Equipment," it states that"[c]omplete descriptions and any safety implications that result from sharing facilities orsystems should be evaluated in and referenced to the appropriate chapter of the SAR."a) The UCINRE RAI response dated August 1, 2011 (ADAMS Accession No. ML1 1255A073),Section 3.6, "Ventilation System, "pages 6-9, describes the UCINRF ventilation systemand Section 13.2, "Maximum Hypothetical Accident,"pages 12-19, expands thedescription by predicting doses during a maximum hypothetical accident. During normaloperations argon-41 is produced and released. The UCINRF ventilation system sharescomponents with the chemistry building exhaust system.i) Could airborne radioactive material being exhausted from the reactor room duringaccident or normal conditions be discharged into public spaces because of systemfailures? We believe no backflow into public spaces is possible.ii) If not, explain why not.As indicated in the diagrams presented earlier, the shared system does not integrate until the rooflevel of Rowland Hall. Three main fans there run continuously with only one required to providesufficient flow for normal building exhaust and prevent back-flow. Positive flow is thus assured fromall directions at the mixing point. The limiting conditions for reactor operation require that ventilationoperation meets flow criteria. Thus reactor operation would be halted or not begin if ventilationfailure occurred. Furthermore, the ventilation system operation is monitored continuously for flowand pressure (24/7) by UCI Central Plant. In the event of an alarm or failure condition, Central Plantcalls the facility. In the event of no response, investigation and repair proceeds and if access isneeded, the UCIPD will call the reactor call list for assistance. This is evidenced by the need for thePage 1 UCI RAI from July 15, 2014 response revised December 18th 2015facility staff to notify Central Plant if a door is opened for more than a couple of minutes, creating analarm condition in the pressure differential monitor at the facility and at Central Plant.iii) If this back flow is possible, what are potential doses to members of the public?None is anticipated, see above.iv) As airborne radioactive material is discharged through the ventilation system ductingduring accidents or normal operation, could members of the public adjacent to the ductingbe exposed to radiation?Public exposure is minimal from portions of the ducts leading to the roof. This is unchangedfrom the earlier design. Normal operations result in only minimal exposures within the facilityand even less to anyone in adjacent laboratories or areas adjacent to the ventilation ducts.TLD dosimeters placed at facility and ventilation systems perimeters confirm this byexhibiting little or no exposure above background (or even below!) within quarterlymeasurement limits. These have been reported in annual reports.In the revised SAR, Sections 13.2.5 and 13.2.7 exposures to building occupants in adjacentlaboratories were discussed. The same arguments pertain to those adjacent to theventilation ducts but with a lower source term. SAR 13.2.7 (November 2011) states:"There is no pathway for airborne activities to reach the adjacent areas of the building, so that thedeep dose rates established in 13.2.5 for individuals within the facility may be utilized. Suchindividuals will not be immersed in an infinite cloud of radioactive volatiles, so the facility may beconsidered as a single source. Further only gamma-ray exposures would be experienced since thewalls and windows are thick enough to absorb all beta radiation. There are no doors directlyopening from the facility to adjacent building areas, so no leakage to interior building areas isanticipated."The ventilation duct contains only a fraction of the source term so any exposure is muchreduced. In any accident release situation, the purge exhaust passes a small fraction of theeffluent gases only (there is a particulate filter) through the duct in passing occupied rooms.In such event the building will be evacuated ASAP so occupancy will be eliminated quickly.Areas nearby the ducts are mostly of low occupancy level (e.g., research labs andstockroom).v) If not, explain why not. If exposure to radioactive material is possible, what are thepotential doses to members of the public?See above. Again this is not new and the situation has existed since the original license.SAR Section 13.2.7 statesPage 2 UCl RAI from July 15, 2014 response revised December 18th 2015"Section 13.2.5 established a maximum dose rate to an individual within the facility of about 50mrem/hr. Since this is an immersion calculation, it is reasonable to assume a distance factorbefore estimating the dose rate through a wall. The closest a person can stand outside the facilityis in the adjacent hallway at the "window' wall. Assuming a whole body distance on each side ofthe wall, and including the wall thickness, it is reasonable to credit a distance factor of 5 feet.Making a further assumption that the source is an effective point source inside the facility, thiscould provide a distance factor of 52 or 25. Thus the external dose rate estimate is reduced by50/25 or to 2 mrem/hr. making no allowances for attenuation by air or wall materials, This is at theacceptable rate1 for public individuals over short time periods. In such an accident, the buildingwill be cleared within less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the accident so that extensive exposure at this rate(which would need to exceed 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to attain the 50 mrem annual limit2) would not be realized.Since there is no internal exposure, this exposure is the TEDE estimate. As it is so low, even ifthere are large uncertainties in the estimate, this appears to be entirely acceptable. Anyone at afurther distance, such as in nearby laboratories or offices, would receive less as a result ofadditional distance factors and absorption reductions. It is important to emphasize that thebuilding ventilation design is such that no mechanism exists for mixing of air between the reactorarea and adjacent rooms, so no internal exposure can result from the MHA except to persons inthe facility.The above estimates were presented for adjacent laboratories based on the reactor room(volume 6.6 E8 cm3) as a source. A passing duct is a more limited source. Assuming a ductof 1.5 feet diameter and 10 feet high passing a space, the source volume is now 5E5 cm3.Assuming the same radioactivity concentration as the reactor room with the sameintervening wall shielding and personnel proximity assumptions, exposures to personnel inrooms near the ducts would be (conservatively) only 1/1 000 of the 2 mr/h estimated for thelabs.b) The UCINRF RAI response dated January 27, 2010 (ADAMS Accession No.ML 100290365), Attachment C, SAR Chapter 5, "Reactor Coolant System," "pages 43-47, provides an updated SAR describing the water cooling system and waterpurification system. The UCI chilled water system supplies cooling water for the shellside of the heat exchanger.i) Discuss the radiological impact of a leak in the heat exchanger. Is leakage flowfrom the chilled water side into the primary side of the heat exchanger under alloperating conditions of both the primary system and chilled water system?Leakage flow within the heat exchanger is from secondary into the primary as establishedby pressure differentials under all conditions. The facility has recently installed pressuresensors in both primary and secondary systems to enable ongoing verification of thisclaim.ii) If not, what is the maximum radiological impact of primary coolant entering thechilled water system?S10CFR20. 1302(2)(ii)2 10CFR20. 1302(2)(ii)Page 3 UCI RAI from July 15, 2014 response revised December 18th 2015None is anticipated (see above)2) In NUREG-1537, Part 1, Section 4.3, "Reactor Tank or Pool, "it states that "the applicantshould assess the possibility of uncontrolled leakage of contaminated primary coolant andshould discuss preventive and protective features."a) The UCINRE RAI response dated July 14, 2010 (ADAMS Accession No. ML 101970039),Section 13.4, "Loss of Reactor Pool Water (Coolant), " pages 6-12, describes pool waterleakage. The response states that rain and irrigations of areas outside the reactorbuilding forced the drilling of wells adjacent to Rowland Hall. There seems to be adiscrepancy in two statements: (1) that automatic sump pumps are used to drain thesewells and (2) that samples are taken of the water being removed and are assayed bygamma-ray spectrometry. Clarify how the process exists for sampling radioactivecontaminants in the discharge of the automatic sump pump system prior to returningwater to the campus sewage system.Sampling is done on a scheduled (monthly) basis as a check on potential leakage, not priorto any release. Use of the pump would cease if reactor contaminated water were detected.As the reactor pool water is itself also checked monthly and found to be only very lowcontamination, the degree of contamination after soil filtering would be so low that modestrelease of water would be well below allowable sewer discharge levels.b) Previous annual reports identified that ground water has been observed in fuel elementstorage pits in the floor of the reactor room. Confirm whether or not these pits are usedto store fuel. If they are or will be used to store fuel, discuss actions that would be takento prevent water ingress prior to using the pits to store fuel and consider modifying TSsto reflect these actions, or explain why leakage into the storage pits would not makethem unsuitable for fuel element storage. Alternatively, consider incorporating a TS thatstates, 'Tuel storage shall be limited to in pool storage only."These pits were originally designated for either wet or dry storage in very low criticalityarrangements. Fuel stored in them will be secured in racks designed to limit reactivity aswell as to raise the elements above any potential ground water levels. Off the five pits, onlytwo have ever been subject to water incursion, and these would be used for fuel only as alast resort. In addition the pumping out of adjacent ground water will reduce the probabilityof future incursion. We do wish to be able continue use the pits as they provide additionalsecurity for new fuel, as well as options for used fuel.c) The UCINRF RAI response dated July 14, 2010, Section 13.4.1, "Mechanisms and Rateof Loss of Coolant," estimates that it would take 19.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to drain the pool.i) What is the maximum water loss that can occur without detection; that is, if the pool* started leaking after the reactor staff left for the night, what is the maximum amount ofpool water that could be lost without staff becoming aware?The pool alarm is set at just less than 12 inches below the tank rim. The normal waterlevel is maintained at about 6 inches below the tank rim. Each inch corresponds toapproximately 80 gallons of water. 6 x 80 = 480 gallons before an alarm would bereported to staff. This is less than 2% of the water (25,000).Page 4 UCI RAI from July 15, 2014 response revised December 18th 2015ii) How many gallons per week would be the minimum detectable leakage ratebased on UCINRF historical primary, makeup rates for normal operations?Normal loss rate based on history since we included a pool water level measurement gaugeis taken to be between 10 and 30 gallons per week with a mean value of 20 gallons/week.The value varies with operating schedules and temperature variations. Data for pool level isrecorded on each daily start-up check sheet, and rates of loss are calculated monthly. A rateof 1 inch drop in 1 week, or four times that mean value would be considered highly abnormaland cause for investigation. The pool water at this facility has a very low level of residual(long-lived) radioactivity, and ground-water in this area is not utilized in any way for publicconsumption, so that a slow leakage rate does not present a significant risk to the public.Requirements for checks and calibrations of the pool water level monitoring system havebeen incorporated in the revised Technical Specifications.It can be noted that a loss of 1 foot of water above the core results in a negligible increase indirect radiation level in any rooms over the reactor. SAR 13.3 shows that 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> or morewill elapse after an alarm condition before dose rates become of concern.3) In NUREG-1537, Part 1, Section 4.5.1, "Normal Operating Conditions," it requiresestablishment of a limiting core configuration. According to ANSI/ANS-I5. 1-200 7, thereference core should consider Xenon and other poisons in calculating a shutdown margin(SDM). The UCINRF proposed TS 3.1.2, "Shutdown Margin," states, '[t]he shutdown marginprovided by the control rods shall be greater than $0.55 .... " Given the reference corecondition established in RAl response dated June 7, 2011 (ADAMS Accession No.ML 111950452), the resulting SDM reactivity could be at least $0.30 less. Provide justificationfor this variance or revise proposed TS 3.1.2 to reflect a $0.85 SDM to support the inclusionof Xenon in the definition of reference core condition or consider incorporating the definitionReference Core Condition: The reference core condition is the condition of the core whenit is at ambient temperature (cold) and the reactivity worth of xenon is negligible.Reference Core Condition has been revised to eliminate the ($0.30) modifier.4) NUREG-1537, Part 1, Section 11.1.1.1, "Airborne Radiation Sources, " states that the SARshould discuss the production of airborne particles, aerosols, vapors, and nitrogen- 16 (N- 16)or other radionuclides. Describe the change or difference in radiation fields within theconfinement space with the N-16 diffuser ON versus with the N-16 diffuser OFF or state thetransport time of N- 16 with and without the diffuser in operation.The following radiation levels in mr/h have been measured within the facility with the reactorat 250 kilowatts steady state power level:Location With diffuser Without diffuserImmediately over pool 1.6 20Ceiling over pool 0.8 1.8At facility corridor wall 0.03 0.3Background --reactor OFF 0.03 0.03Page 5 UCI RAI from July 15, 2014 response revised December 18th 20155) NUREG-1 537, Part 1, Section 11.1.1.2, "Liquid Radiation Sources," states that the applicantshould discuss compliance with the applicable sections of Title 10 of the Code of FederalRegulations (10 CFR) Part 20, "Standards for Protection Against Radiation." There are twoplaces in the UCINRF proposed TSs that discuss liquid effluent, proposed TS 3.7. 2,"Effluents," Specification b. and proposed TS 4.7, "Radiation Monitoring Systems andEffluents," Specification e. The regulations in 10 CFR 20.2003 require that liquid effluentsdisposed of by release into sanitary sewerage be readily soluble. There is no mention in thePAl responses or Bases discussions that these propose TSs limit releases to readily solubleradionuclides. Confirm that these proposed TSs limit release to readily soluble radionuclides,or pro vide justification as to why not.Yes all references to liquids are to soluble radionuclides. Others are disposed as "drywaste". The appropriate TS sections have been revised to require demonstration ofso lub ility.6) In NUREG-l 53 7, Part 1,-Section 11.1.4, "Radiation Monitoring and Surveying, "itrequires a description of all radiation monitoring equipment.a) State the set points of the radiation area monitors and continuous air radiation monitor(CAM) listed in UCINRF proposed TS 3. 7.1, "Radiation-Monitoring Systems," and providethe bases for these set points.Set points for the radiation monitors and CAM areas follows:Instrument Alert Alarm Count rateRadiation Area Monitors (2) 2 mr/h 10 mr/h noneContinuous Air Particulate Monitor none *1 E-8 #Ci/ml 5000 cpmBases: RAM -2 mr/h is the normal standard for short -term exposures to the public.10 mr/h alarms at more serious but still safe for short term use. It alsofunctions in after-hours as an .alarm for inappropriate activity within thefacility.CAM -Based on instrument manufacturer recommendations. *DAC is frommanufacturer recommendation for 1-131. This is a factor of 2 lower than the 10 CFR 20Appendix B, Table 2 limit value of DAC for 1-131 for occupancy situations of 2E-8 1iCi/ml. Asthe ventilation system provides for dilution in normal mode of x 100, and emergency node ofx 1600, this provides an alarm level below the public release limit (Table 2) of 2E-10 ptCi/ml.b) The use of the acronym CAM is inconsistent. In the UCINRF proposed TS 3. 5.1,"Ventilation System, " and proposed TS 3.5.2, "Ventilation During EmergencySituations," it is defined as "continuous particulate air monitor" while proposed TS3.7.1, "Radiation Monitoring Systems," defines it as "continuous air radiation monitor."Provide consistent nomenclature.The acronym CAM has now been identified as Continuous Air Particulate Monitor in TS3.7.1., and utilized throughout the TS.Page 6 UCI RAI from July 15, 2014 response revised December 18th 20157) NUREG- 1537, Part 1, Section 13.1.2, "Insertion of Excess Reactivity," lists insertion-of-excess-reactivity events which includes a ramp insertion of reactivity by drive motion of the mostreactive control or shim rod, or ganged rods. Provide details of the ramp insertion analysis includingthe reactor trips in order to demonstrate the protection of the safety limit.The TRIGA core has been analyzed for a pulse excess reactivity insertion of up to $3.00within 100 milliseconds using the ATR and FTR control rods. A ramp rate of $30 per secondis the average in such an operation. Periods in the range of milliseconds are predicted andexperienced.Maximum fuel temperatures of 350 00 -well within the safety limit were projected and havebeen confirmed by measurements. Fuel temperatures in the pulse are also below theproposed scram setting (425 00). In the original safety analysis, Chapter 7, and therelicense submittal (Section 13.3), model analysis suggests a fuel temperature conditionfollowing a pulse insertion of $3.00 in an accident situation at a steady state power level of250 kw at a maximum of 570 00. (240 °C steady state fuel temperature + 330 00 additionalfrom the pulse). At UCI an accident of that magnitude is impossible as significant reactivityfrom the $3.00 license TS limit would be utilized in reaching 250 kilowatts, leaving only areduced amount for accidental insertion.While a slower ramp might be expected to produce higher fuel surface temperatures in afuel with smaller or slower negative temperature feedback, these are not of concern for ahomogeneous TRIGA fuel which has a safety limit based on fuel meat temperature.Wherever and whenever the fuel meat is hot the negative feedback will occur, reducingpower density rapidly at that location.However, in response to this request a slow drive ramp insertion analysis has beenconducted and the results are presented and discussed in an attachment to this document.The following RAIs are based on a review of the proposed UCINRE TSs, as provided in your RA!response dated March 1, 2012 (ADAMS Accession No. ML12087A215), and follow up RAIresponse dated September 11, 2012 (ADAMS Accession No. ML12256A897).8) 10 CFR Part 50.36(a)(1) states, in part, that the bases are not part of the TSs. Provide a TSstatement to support the requirement of 10 CFR 50.36 (a)(1), or justify why one is notrequired. An example of TS statements that have been approved by the NRC staff includethe following; "Included in this document are the Technical Specifications and the 'Bases' forthe Technical Specifications. These bases, which provide the technical support for theindividual Technical Specifications, are included for informational purposes only. They arenot part of the Technical Specifications, and they do not constitute limitations or requirementsto which the licensee must adhere."We have included the above statement verbatim on our introductory page.9) The UCINRF proposed TS 1.0O, "Definitions," "provides a definition for CHANNELCALIBRATION that is not consistent with the guidance found in NUREG-1537 andANSI/ANS-15. 1-2007. Revise the proposed TS definition of CHANNEL CALIBRATION tobe consistent with the guidance in NUREG- 1537 and ANSI-I 15.1, or provide a justificationfor the proposed definition.This has been revised.Page 7 UCI RAI from July 15, 2014 response revised December 18th 201510) The UCINRF proposed TS 1.0, "Definitions," contains a formatting inconsistency underCONTROL ROD, where the subparts are not spaces or indented, similar to other parts ofthe proposed TSs. Provide justification for formatting the subparts or revise forconsistency.This has been corrected.11) The UClNRF proposed TS 1.0, "Definitions, " CONTROL ROD contains an inconsistency inwhich subpart, "c. Adjustable Transient (A TR)," describes how control rod position is adjustedusing an electric motor drive, while subpart, "d. Fast Transient (FTR)," does not have anequivalent description of how control rod position is adjusted. The SAR describes the use ofpneumatic control for the FTR. Provide a justification for this difference or revise thedefinition of FTR.The descriptions have been revised to better parallel the other rods.12) The UCINRF proposed TS 1.0, "Definitions," INITIAL STARTUP states, "...be fore operationduring the day at steady-state power level above 1 kilowatt, or by pulsing the reactor."Clarification is required on the significance of 1 kilowatt. Explain the purpose for the 1kilowatt threshold or provide a basis describing the reason why 1 kilowatt is included in thisproposed TS definition. Include in your discussion the need to have a senior reactoroperator (SRO) present during the initial startup as required by 10 CFR 50.54(m)(1) ifpower does not reach 1 kilowatt.This has been revised to read:"INITIAL STARTUP is the first start-up from reactor secured condition on any day when thereactor is to be operated in order to verify core excess and other instrumentparameters."The need for a senior operator remains in accordance with the regulations.13) The UCINRF proposed TS 1.0, "Definitions, "REACTOR SECURED, subpart (2)(d) states, "Noexperiments are being moved or serviced that have a reactivity worth exceeding the maximumvalue allowed for a single experiment, or $1.00." Based on this definition, the exact reactivitylimit is not clear. Only the most conservative, or that, which is applicable to the UCI reactorshould constitute this definition (i.e., either $1.0O0 or the maximum value allowed for a singleexperiment). Provide justification for the proposed TS or revise the definition to identify only onecondition.The REACTOR SECURED definition has been revised accordingly.14) The UCINRF proposed TIS 1.0, "Definitions," SCRAM TIME states, "is the elapsed timebetween the initiation of a scram signal and a specified movement of a control or safetydevice." This definition is not clear as applied to the UCI reactor. As applicable to the UCIreactor, describe the specified movement (i. e., 85 percent of reactivity, all rods on the bottom,etc.) that constitutes this definition. For example, SCRAM TIME is the elapsed time betweenreaching a limiting safety system set point and the instant the slowest scrammable controlrod reaches its fully-inserted position or SCRAM TIME is the elapsed time from the initiationof a scram signal to the time the slowest scrammable control rod is fully inserted. Also definePage 8 UCI RAI from July 15, 2014 response revised December 18th 2015the control or safety device specific to the UCI reactor. Provide justification for the proposedTS or revise the definition to identify one specific movement of a control or safety device.The definition of SCRAM TIME has been revised accordingly.15) The UCINRF proposed TS 1.0, "Definitions," SUBSTANTIVE CHANGES may causeconfusion in implementing 10 CFR 50. 59, "Changes, tests, and experiments." Providejustification as to why this definition is required and is consistent with 10 CFR 50.59 ordelete the definition.This definition has been removed, based on discussions on February 5th 2015 with NRCpersonnel.16) The UCINRF proposed TS 1.0O, "Definitions," section does not include a definition forMOVEABLE EXPERIMENTS as endorsed in the ANSI/ANS-I5. 1-200 7. The term"moveable" can mean "unsecured," but not all "unsecured" experiments are "moveable."Provide a definition of moveable experiments, and include this definition in UCINRFproposed TS 3.8.1, "Reactivity Limits," or provide justification as to why this definition shouldnot be included.This has been included within the definition of EXPERIMENT.17) The UCINRF proposed TS 3.1.1, "Steady-state Operation, "Applicability section,contains a typographical error in which a period is missing. Clarify or correct thetypographical error. Also, review your proposed TSs for typographical or formattingerrors and propose corrections as needed.This has been attempted through use of an "external" reviewer.18) NUREG-1537, Appendix 14.1, Section 3.1.6, "Fuel Element Inspection Parameters,"Specification b., identifies limits on TRIGA fuel, including burnup. The UCINRF proposedTS 3.1.6 does not include a burnup limit. Provide a TS limit for fuel element burnup orprovide a justification as to why this limitation should not apply to the UCINRE reactor.A burn-up limit has been included as requested as TS 3.1.6.e. The basis is NUREG 1282.19) The UCINRF proposed TS 3.2.3, "Reactor Safety System," "Table 2. Minimum ReactorSafety Channels, "requires clarification as identified below.a) Second column, first row titled, "Function and trip level maximum setting," may bemisinterpreted. Provide clarity for this table by adjusting the title to read, "Function and triplevel settings," and labeling corresponding set points using universal symbols <, >, >, <orprovide justification for the use of the proposed labeling system.These changes have been incorporated as requested.b) Second column, third row lists, "Scram-425°C (IFE)" but does not indicate the range ofacceptability. Identify if this should read "Scram <_ 425°C (IFE)," or provide justification for proposedlabeling system.See above.Page 9 UCI RAI from July 15, 2014 response revised December 18th 2015c) Second column, fourth row listing, "Scram-I110% of 250kw" should identify "Scram-<110% of 250kw (275kw(t))," or provide justification for proposed labeling system.See above.d) Second column, eighth row listing, "Scram-if motion of 3% g (0. 03g) is exceeded"should identify, "Scram-if motion of < 3% g (0. 03g)," or provide justification forproposed labeling system.See above.20) The UCINRF proposed TS 3. 2. 3, "Reactor Safety System," "Table 3. Minimum Interlocks,"first column, fifth row lists the interlock, "REG, SHIM, A TR Control Rod Drives" and thesecond column, fifth row lists the function, "Prevent movement of REG and SHIM rods inpulse mode." Confirm that there is no interlock for the A TR control rod drive that prevents itsmovement in pulse mode or make the appropriate corrections to the table?A revision has been made to clarify the interlocks present in the pulse mode.21) The UCINRF proposed TS 3.3.1, "Pool Water Level," Specification b., requiresclarification for the following:a) The use of the term ". ..shall operate 24/7..." is colloquial and may be misinterpreted.Provide clarity to this requirement by stating, ".....shall operate continuously. .." or providea justification for the use of the proposed language.This revision has been made as requested.b) The condition states, "Visual checking of water level shall be substituted every 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />sduring periods when the alarm is found to be inoperable and no substitute level devicehas been implemented." How long can visual checking every 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> exist before thepool water level alarm is restored to operation? How long can a substitute level devicebe implemented? Justify your proposed time periods.Since observation is decidedly painful, the restoration will be important. Depending on theavailability of spares and delivery thereof, we expect the restoration to be completed with 7working days at the outside, and hopefully within 1-2 days.22) The UCINRF proposed TS 3. 8. 2., "Materials," Specification b., states, "Explosive materialsshall not be irradiated in quantities greater than 25 milligrams of TNT equlivalent. Explosivematerials in lesser quantities may be..." Clarification is required because a legal loop holeexists in this statement that does not specify the requirements for exactly 25 milligrams ofTNT. The TS should identify, ".... Explosive materials in the amount of 25 milligrams orlesser quantities may be..." Pro vide justification for the proposed language, or modify theproposed TS to conform to current NRC guidance.This change has been made as requested.23) The UCINRF proposed TS 3.8.2., "Materials," Specification b., requires that the pressure ofaccidental detonation of explosive material has been calculated and/or experimentallyPage 10 UCI RAI from July 15, 2014 response revised December 18th 2015determined to be less than half the design pressure of the container the explosive isirradiated in. Provide calculations of the design of an example container to demonstrate thecapability to meet the requirements of TS 3.8.2., Specification b.This would be a requirement of the experimenter proposing such a device, and would verifythis by use of outside consultants who have expertise in this arena.Calculators of thickness of sealed containers to meet ASME design pressures can be foundon-line at such sites as http://www.checalc.com/calc/vesselThick.htmlAs to explosive analysis, for combustibles, NRC 1805 provides a calculator. For others thetype and design of the containment are crucial, and DOT guidance is helpful.A useful general reference for explosives seems to be http://fas.orgq/man/dod-101 /navy/docs/es3 10/chemistry/chemistry. htmThere is minor disagreement in the literature as to the proper equation to be used forexplosion of TNT. This depends on oxygen availability. Using the conservative value of 11mol of gas per mol (227.13g) of TNT, we find that 23 mg of TNT (1/10,000 mol) would yield,on explosion, 11 x 1/10,000 x 24.6 L of gas at NTP = 0.027 L = 27 mL, assuming ideal gasconditions. Confined to a volume of 10 mL (for the purpose of analysis), this would resultconservatively, in a pressure of 27/10 x I atm or 2.7 atm. Confining a pressure of >= 5.4atm would be required to meet the specification. However this ignores any heating effect.TNT releases 2175 J/g, so 23 mg will release only 50 J. Assuming a steel capsule of mass100~g and 0.5 J/g-K for specific heat, this would yield a temperature rise of only 1 K. Sucheffect is minimal. Even a 100°C rise would only raise the calculated pressure from 2.7 to 3.7atm, for a required strength of 7.4 atm.24) The UCINRE proposed TS 3.8. 2, "Materials," Basis section references a letter datedDecember 2, 2011, which describes the dose limits in terms of total effective dose equivalent (TEDE)and thyroid individual organ doses. Some confusion exists in that the dose limits should only be interms of TEDE for this licensing action. Consider removing the individual organ dose references inthe bases, or justify how this limit is applicable to establishing the TS limit.These revisions have been made as requested.25) The UCINRE proposed TS 3.8.3, "Failure or Malfunction," requires clarification. The wordingof the specification is not standard and results in some confusion. Provide justification forthe proposed language, or modify the proposed TS to conform to current NUREG-i 537guidance. An example TS reads as follows:TS 3.8.3 Experiment Failure and MalfunctionsSpecificationsWhere the possibility exists that the failure of an experiment under (a) normaloperating conditions of the experiment or the reactor (b) credible accident conditionsin the reactor or (c) possible accident conditions in the experiment could releasePage 11 UCI RAI from July 15, 2014 response revised December 18th 2015radioactive gases or aerosols to the reactor room or the unrestricted area, thequantity and type of material in the experiment shall be limited in activity such thatexposures of the reactor personnel to the gaseous activity or radioactive aerosols inthe reactor room or control room will not exceed the occupational dose limits inIOCFR 20.1201. Additionally, exposures to members of the public to these releasesin the unrestricted areas will not exceed the dose limits in 1OCFR 20. 1301, assumingthat:a. 100% of the gases or aerosols escape from the experiment;b. If the effluent from an experimental facility exhausts through a holdup tank, which closesautomatically on high radiation levels, the assumption shall be used that 10% of the gaseous activityor aerosols produced will escape;c. If the effluent from an experimental facility exhausts throulgh a filter installation designed forgreater than 99% efficiency for 0.3 micron particles, the assumption shall be used that 10% of theaerosols produced escape;d. For materials whose boiling point is above 55°C and where vapors formed by boiling this materialcould escape only through an undisturbed column of water above the core, the assumption shall beused that 10% of these vapors escape; ande. If an experiment container fails and releases material which could damage the reactor fuel orstructure by corrosion or other means, physical inspection shall be performed to determine theconsequences and the need for corrective action.These revisions have been made as requested.26) The UCINRF proposed TS 4.2, "Reactor Control and Safety Systems," Specification e., states,"On each day that pulse mode operation of the reactor is planned, a functional performance check ofthe transient (pulse) rod system..." Functional performance check is not a defined term. Is this achannel check? If so, use the properly defined term, or define and justify the term functionalperformance check.TS 4,2 has been rewritten to utilize the term "OPERABLE" which has been defined.27) The UCINRF proposed TS 4.2, Reactor Control and Safety Systems," Specification h., states,"A channel check of the pool water temperature measuring channel..." Confirm that achannel check is appropriate as this surveillance. The NUREG-1537 guidance identifies acalibration of measuring channels. Explain the use of a channel check versus a calibrationor modify the proposed TS to conform with NRC guidance.An annual calibration requirement for the pool water temperature measuring channel hasbeen included in TS.4.2, replacing the daily "check". In addition, the requirement foran annual calibration of the pool water level measuring channel, has been movedfrom 4.3 to 4.2 to better cluster the "annual calibration" requirements. The pooltemperature "alarm" is advisory, as it alerts operators to a procedural requirementnot directly connected to safety, and provides no automatic scram, or outsideagency notifications.28) The UCINRF proposed TS 4.3, "Reactor Pool Water," Specification b., is not included in the listPage 12 UCI RAI from July 15, 2014 response revised December 18th 2015of surveillances that cannot be deferred, found in TS 4.0, "General," Specification a., whichstates "Surveillance requirements may be deferred during prolonged (periods greater than 1month) reactor shutdown (except Technical Specifications 4. 3. a, 4. 3. c, 4.3. e, 4.3. f and4.3.g)." Why is TS 4.3, Specification b. allowed to be deferred for long term shutdown?Provide justification for this deferral, or modify the proposed TS to include TS 4.3,Specification b. on this list of exceptions.This has been revised as requested and to acknowledge other changes made in numberingitems.29) The UCINRF proposed TS 6.1.2, "Responsibilites," "Figure 1. UCI Reactor Organization Chart,"requires clarification. The solid-line and dashed-line relationships are not identified in aleger or within TS description. Confirm and indicate what these connections mean.This has been included as requested.30) The UCINRF proposed TS 6.1.3, "Staffing, "item a. 1., states, "The minimum staffing when thereactor is not secured shall include: 1. a licensed operator with direct access to the reactorcontrols." Does this statement mean a licensed operator must be present in the controlroom? If so, confirm and modify the proposed TS to reflect that a licensed operator must bepresent in the control room, or provide justification as to why not.This has been revised as requested.31) The UCINRF proposed TS 6.1.3, "Staffing," item d., states, "...Restart following any unplannedor unscheduled shutdown, or significant power reduction." The use of ". .. or significant powerreduction, "is unclear and may cause confusion in implementing the proposed TS. Modify theproposed TS to remove this phrase, define and justify what significant means, or providejustification why this terminology cannot be misunderstood.Wording has been changed to clarify this concern.32) The UCINRF proposed TS 6.2.4, "ROC Audit function," is missing two conditionsprescribed by ANSI/ANS-15. 1-200 7. Modify the proposed TS to include the belowsections, or provide justification to deviate from guidance.e. The audit shall be performed by one or more persons appointed by the ROC. At least one of theauditors shall be familiar with reactor operations. No person directly responsible for any portion ofthe operation of the facility shall audit that operation; andf. Any deficiencies that may affect reactor safety shall be immediately reported to ROC Chair, Level1, and a written full report of the audit shall be submitted to the ROC within three months of the audit.These revisions have been made as requested.33) The UCINRF proposed TS 6.3, "Radiation Safety," states, "As delineated in section6.1.2.e, the UCI... The program shall use the guidelines of ANSI/ANS-15.11-2004."The NRC has accepted a "should" statement.This revision has been made.Page 13 UCI RAI from July 15, 2014 response revised December 18th 201534) The proposed UCINRF TS 6.4, "Operating Procedures," states, "Written procedures, reviewedand approved by the ROC, shall be in effect and implemented..." The NUREG-1537guidance recommends the facility director be included for review and approval (e.g., "Writtenprocedure, reviewed and approved by the ROC and facility director, shall be in effect andimplemented..."). Provide justification for this deviance from guidance, or modify theproposed TS to conform with the guidance.This revision has been made as requested.35) The UCINRF proposed TS 6.4, "Operating Procedures," final paragraph states, "Substantivechanges to procedures.. .but shall be reported to the RSO within 30 days." The definition ofsubstantive changes may cause confusion and misinterpretation about what needs to beconsidered under 10 CFR 50.59. Provide justification why this cannot be misinterpreted ormodify the proposed TS to meet the requirements of 10 CFR 50.59.This has been revised as requested.36) The UCINRF proposed TS 6.5, "Experimental Review and Approval," item b., states,"Substantive changes to existing experiments or classes shall be made only after review bythe ROC and RSO or their designees. Minor changes that do not significantly... (SRO)."The definition of substantive changes may cause confusion and misinterpretation aboutwhat needs to be considered under 10 CFR 50.59. Provide justification for the use of thisterm, or modify the proposed TS to remove the section on substantive changes and minorchanges to read, "Changes to existing experiments or classes shall be made only afterreview by the ROC and RSO or the RSO designee."This has been revised as requested.37) The UCINRF proposed TS 6.6.1, "Actions To Be Taken in Case of a Safety Limit Violation,"items b. and c. are inconsistent. In TS 6. 6. 1, item b. there is a requirement to report theevent immediately while TS 6.6.1, item c. specifies that this event shall be reported within24 hours. Provide justification for the non-congruency, or modify the proposed TS to beconsistent.TS 6.6 has been revised by moving material from 6.7.2 into this section. We believe thisclarifies the action and reporting requirements to accord with 10OCFR 50.36 as requested38) The UCINRF proposed TS 6.7.1, "Annual Operating Report, "states, ".....each 12-month period forst thoperations for the preceding year's activities between July 1 through June 30 ."In addition,specify, when the report is actually due (e.g., "An annual report shall be created andsubmitted, by the Facility Director, to the Document Control Desk, U.S. NRC, Washington,thDC, 20555, by September 30 of each year').Revisions have been made as requested.39) The UCINRF proposed TS 6. 7.1, "Annual Operating Report," item d., differs slightly from theNUREG-1 537 guidance, which states that a tabulation of changes in the reactor facility andprocedures, and tabulation of new tests or experiments, including a summary of the analyses leadingto the conclusions that they are allowed without prior authorization by the NRC and that 10 CFR50. 59 was applicable. The proposed TS is not as precise. Provide an explanation as to why thisPage 14 UCI RAI from July 15, 2014 response revised December 18th 2015deviation is justifiable or revise the proposed TS accordingly.This has been revised as requested.40) The UCINRE proposed TS 6.8.3, "Records to be retained for the lifetime of the reactor facility," ismissing a condition prescribed by ANSI/ANS-15. 1-200 7. Modify the proposed TS to includethe below section or provide justification to deviate from guidance.1) Reviews and reports pertaining to a violation of the safety limit, the limiting safetysystem setting, or a limiting condition of operation.This has been revised as requested.41) Provide updated proposed TSs, including the revisions requested in e-mail datedSeptember 11, 2012 (ADAMS Accession No. ML12256A897).These revisions have been incorporated as requested.ADDITIONAL REVISIONS.Based on discussions with NRC personnel on February 5th 2015, we arerequesting removal of former TS 3.3.4 Pool Water pH as an un-neededspecification for an open pool reactor, with adequate monitoring of waterconductivity and temperature. This has been done in the latest TS version.References to this specification in TS 4.0 and 4.3 have also been removed.Further editorial revisions to the Technical Specifications have been made as aresult of exchanges with NRC licensing personnel in the period February 2015through November 2015. An updated version of the TS, dated December 18th,2015 is submitted herewith as an attachment.Page 15 APPENDIX AToFaci-ity License R-1 :50-326Technical Specificationsfor theU. C. IrvineTRIGA Mark I Nuclear ReactorDecember t18, 2015 TABLE OF CONTENTSDEFINITIONS1SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS2.1 Safety Limit -Fuel Element Temperature 52.2 Limiting Safety System Setting 5LIMITING CONDITIONS FOR OPERATION3.1 Reactor Core Parameters 63.2 Reactor Control and Safety Systems 93.3 Coolant Systems 123.4 (Blank) 143-.5. Ventilation Systems 143.6 (Blank) 153.7 Radiation Monitoring Systems and Effluents 163.8 Limitations on Experiments 173.9 (Blank) 19SURVEILLANCE REQUIREMENTS4.0 General 204.1 Reactor Core Parameters 214.2 Reactor Control and Safety System 224.3 Reactor Pool Water 234.4 (Blank) 234.5 Ventilation Systems 244.6 (Blank) 244.7 Radiation Monitoring Equipment and Effluents 254.8 Experiment Limits 25DESIGN FEATURES5.1 Site and Facility Description 265.2 Reactor Coolant System 265.3 Reactor Core and Fuel 275.4 Fuel Storage 285.5 Ventilation System 29ADMINISTRATIVE CONTROLS6.1 Organization and Str'ucture 306.2 Review and Audit 336.3 Radiation Safety 356.4 Operating Procedures 356.5 Experiment Review and Approval 356.6 Required Actions 366.7 Reports 386.8 Records 39Note: Included in thifs document are the Technical Specifications and the "bases" for the TechnicalSpecifications. These bases, which provide the technical support for the individual TechnicalSpecifications, are included for infornational puroposes only. They are not part of the TechnicalSpecifications, and they do not constitute limitations or requirements to which the licensee must adhere.
- 1. DEFINITIONSThe following frequently used termas are defined to aid in the uniform interpretation of thesespecifications.AUDIT is an examination of records, logs, procedures, or other documents to ascertain that appropriatespecifications, and guidelines are being followed in practice. An audit report is written to detailfindings and make recommendations.CHANNEL is a combination of sensor, lines, amplifier and output device which are connected for thepurtpose of measuring the value of a parameter.CHANNEL CALIBRATION is an adjustment of the channel such that its output corresponds withacceptable accuracy to knaown values of the parameter that the channel measures. Calibration shallencompass the entire channel, including equipment actuation, alarm or trip, and shall be deemed toinclude a channel test.CHANNEL CHECK is a qualitative verification of acceptable performance by observation of channelbehavior. Thfis verification, where possible, shall include comparison of the channel with otherindependent channels or systems measuring the same variable.CHANNEL TEST is an introduction of a signal into the channel to verify that it is operable.CLOSE-PACKED ARRAY is a fuel loading pattern in which the fuel elements are arranged in the coreby filling the inner rings first.CONFINEMENT is the en:closur'e of the overall facility designed to limit release of effluents betweenthe enclosure and the external environment thr-ough controlled or defined pathways.dONTROL ROD is a device fabricated from neutron absorbing material or fuel or both which is usedto establish neutron flux changes and to compensate for routine reactivity changes. A control rodmay be coupled to its drive unfit allowing it to performn a safety function when the coupling isdisengaged. Types of control rods shall include:a. Regu~lating (RiEG): a rod having electric motor drive and scram capabilities. Its position may bevaried manually or by an electronic controller. It shall have a fueled-follower section.b. Shim (SHIM): a rod having electric motor drive and scram capabilities. Its position shall bevaried manually. It shall have a fueled-follower section.c. Adjustable Transient (ATR): a rod with scram capabilities that can be rapidly ejected from thereactor core using a pneumatic drive to produce a pulse. It has an electric motor drive to adjustits position or length of travel. It shall have a void follower.d. Fast Transient (FTR): a rod with scram capabilities that can be rapidly ejected from the reactorcore using a pneumatic drive to produce a pulse. Only fully UP or DOWN positions areavailable. It shall have a void follower.;I Teclmical Snecifications Page 1 Revision 2015-12-18UC..... j.
CORE CONFIGURATION is a particular arrangement of fuel, control rods, graphite reflectorelements, and experimental facilities inserted within the core grid plates.CORE LATTICE POSITION is defined by a particular hole in the top grid plate of the core designed tohold a standard fuel element. It is specified by a letter, indicating the specific ring in the grid plateand a number indicating a particular. position within that ring.EXCESS REACTIVITY is that amount of reactivity that would exist if all control rods were moved tothe maximum reactive condition from the point where the reactor is exactly critical (keff =1) atreference core conditions.EXPERIMENT is any operation, hardware or target (excluding devices such as detectors or foils)which is designed to investigate non-routine reactor characteristics or which is intended forirradiation within an irradiation facility. Hardware rigidly secured to a core or shield structure so asto be part of their design to carry out experiments is not normally considered an experiment.Specific experiments shall include:a. SECURED EXPERIMENT is any experiment or component of an experiment that is held inl astationary position relative to the reactor by mechanical means. The restraining forces must besubstantially greater than those to which the experiment might be subjected by hydraulic,pneumatic, buoyant, or other forces which are normal to the operating environment of theexperiment, or by forces which can arise as a result of credible malfunctions.b. UNSECURED EXPERIMENT is any experiment or component of an experiment that does notmeet the definition of a secured experiment.c. MOVEABLE EXPERIMENT is any experiment where it is intended that the entire experimentmay be moved inl or near the core or into or out of the core while the reactor is operating.FUEL ELEMENT is a single TRIGA fuel rod.INITIAL STARTUP is the first start-up from reactor secured condition on any day when the reactor isto be operated in order to verify core excess and other instrument parameters.INSTRUMENTED FUEL ELEMENT is an element in which one or more thermocouples areembedded for the purpose of measuring fuel temlperature dur'ing reactor operation.IRRADIATION FACILITIES are pneumatic transfer systems, central tube, rotary specimlen rack, andthe in-core facilities (including single element positions, three-element positions, and the sevenelement position) and any other facilities in the tank designed to provide locations for neutron orgamma ray exposure of materials.MEASURED VALUE is the value of a parameter as it appears on the output of a channel.OPERABLE means a component or system is capable of perfonning its intended function.OPERATING means a component or system is performing its intended function.UCI Technical Specifications Pg eiin21-21Page 2Revision 2015-12-18 OPERATIONAL CORE is a core configuration that meets all license requirements, includingTechnical Specifications.PULSE MODE is any operation of the reactor with the mode switch in the PULSE position thatsatisfies all instrumaentation and license requirements, including technical specifications, for pulseoperation of the reactor.REACTIVITY WORTH OF AN EXPERIMENT is the value of the reactivity change that results fromthe experiment being inserted into or removed from its intended position.REACTOR FACILITY is the physical area defined by rooms B64, B64A, B54, B54A, and B54B in theservice level of Rowland Hall on the campus of the University of California Irvine.REACTOR OPERATING is any time at which the reactor is not secured or shutdown.REACTOR SAFETY SYSTEMS are those systems, including their associated input channels that aredesigned to initiate automatic reactor scram or to provide information for the manual initiation of ascram for thle purpose of returning the reactor to a shutdown condition.REACTOR SECURED is when:Either(1) there is insufficient moderator available in the reactor to attain criticality or thaere is insuffilcientfissile material present in the reactor to attain criticality under optimum available conditions ofmoderation and reflection;Or(2) the reactor is shutdown and the following conditions exist:a. all neutron-absorbing control rods are fully inserted; andb. the console key switch is in the OFF position and the key is removed from the console lock;andc. no work is in progress involving fuel, core structure, installed control rods, or control roddrives unless they are physically decoupled fr'om the control rods; andd. no experiments are being moved or serviced that have a reactivity worth exceeding $1.00.REACTOR SHUTDOWN is when the reactor is subcritical by at least $1.00 in the reference corecondition with the reactivity worth of all installed experiments included.REFERENCE CORE CONDITION is when the core is at ambient temperature (cold) and the reactivityworth of xenon is zero.REVIEW means a qualitative examination of audits, reports and records, procedures or otherdocuments from which appropriate recommendations for improvements are made.UCI Technical Specifications Pg eiin21-21Page 3Revision 2015-12-18 RING is one of six concentr-ic bands in the grid plate locations surrounding the central opening of thecore. The rings are designated by the letters B through G, with the letter B used to designate theinnermost band.SAFETY CHANNEL is a measuring channel in the reactor safety system.SCRAM TIME is the elapsed time between the initiation of a scram signal and all control rods reachingtheir bottom limit.SEVEN ELEMENT POSITION is a hexagonal section which can be removed fr'om the upper grid platefor insertion of specimens up to 4.4 in. in diameter after relocation of all six B-ring elements andremoval of the central tube irradiation facility.SHALL, SHOULD and MVAY. The word shall is used to denote a requirement; the word should is usedto denote a recommendation; and the word may is used to denote permission, neither a requirementnor a recommendation.SHUTDOWN MARGIN refers to the minimum shutdown reactivity necessary to provide confidencethat the reactor can be made subcritical by means of the control and safety systems starting fromany permissible operating condition and with the most reactive rod in its most reactive position, andwill remain subcritical without further operator action.STEADY-STATE MODE is whenever the reactor is operating with the mode selector switch in theSTEADY-STATE position.SURVEILLANCE INTERVALS that are permitted are established as follows:a. Quinquennial -interval not to exceed 6 yearsb. Biennial -interval not to exceed 2-1/2 yearsc. Annual -interval not to exceed 15 monthsd. Semi-annual -interval not to exceed 7-1/2 monthse. Quarterly -interval not to exceed 4 monthsf. Monthly -interval not to exceed 6 weeksg. Daily -each day when the reactor is to be operated or before any operation extending more thanone dayTHREE ELEMENT POSITION is one of two triangular-shaped removable sections of the upper gridplate, one encompassing core lattice positions D5, E6 and E7 and the other D14, E18 and E!9,designed to accommodate experiments. When fuel elements are placed in these locations, a specialfixture shall be inserted to provide lateral support.UCI Technical Specifications Pg eiin21-21Page 4Revision 2015-12-18
- 2. SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS2.1 Safety Limit -Fuel Element TemperatureApplicability. This specification applies to the fuel element temperature.Objective. The objective is to define the maximum fuel element temperature that can be permittedwith confidence that no fuel element cladding damage will result.Specification(s). The temperature in a stainless steel clad, high hydride fuel element shall notexceed 1000°C under any condition of operation.Basi__s. The important paramaeter for a TRIGA reactor is the fuel element temperature, since it canbe measured. The loss in the integrity of the fuel element cladding could arise from an excessivebuild-up of pressure in the fuel element. The safety limit for high hydride TRIGA fuel is based ondata including the experimental evidence obtained during high performance reactor tests of thisfuel. These data indicate that the stress will remain below the ultimate stress provided the fueltemperature does not exceed 11 50°C and the fuel cladding is water cooled.The safety limit for the stainless steel clad, high hydride (ZrHll.7) fuel element is based on NRCaccepted limits in NUR{EG 1537 section 14.1 which also indicates that the stress in the cladding dueto the hydrogen pressure from the dissociation of the zirconfium hydride will remain below the yieldstress provided the temperature of the fuel does not exceed 11 50°C and the fuel cladding is watercooled.2.2 Limiting Safety System SettingsApplicability. This specification applies to the scram setting for the fuel element temperature*channel.Objective. The objective is to prevent the safety limit fr'om being reached.Specification(s). For a core composed entirely of stainless steel clad, high hydride fuel elements, alimiting safety system setting applies to the standard instrumented fuel element (IPFE) which shallbe located in the B- or C-ring as indicated in the following table:Location Limiting Safety System SettingCore lattice positions B2, B4, C5, C6, or C7 < 425°CBasi___s. Fuel temperature is measured by a fuel element designed for thfis purpose (IFE) in a systemdesigned to initiate a reactor scram if a limit is exceeded. The limiting setting is conservativelychosen for five possible core positions that calculations in the SAIR, as supplemented by letter datedJune 7th 2011, indicate are similar in expressing the highest power density and thus the highest fueltemperatures attained in the core. In addition, the maximum recorded temperatures for the UCIreactor IFE for the period since 1969 are 250°C at steady state power operation, and 350°C forpulse operation. The LSSS is extremely conservative compared to the fuel temperature safety limit.UCT Technical Specifications Pg eiin21-21Page 5Revision 2015-12-18
- 3. LIMITING COINDITIONS FOR OPERATION3.1 Reactor Core Parameters3.1.1 Steady-state OperationApplicability. This specification applies to the energy generated in the reactor durfing steady-stateoperation.Objective. The objective is to assure that the fuel temperature safety limit is not exceeded.Specification(s). The reactor power level in steady-state operation shall not exceed 250 kilowatts.Basis. Calculations have been performed which show that for operation at 250 kW, the maximumfuel temperature is 253°C and the minimum DNB ratio is greater than 7.27. In addition, experienceat other TRIGA reactors and thermal and hydraulic calculations for this core (SAR, assupplemented by letter dated June 7m 2011) indicates that these power levels can be safely usedwith natural convection cooling of the fuel elements in the designed core configuration.3.1.2 Shutdown MarginApplicability. These specifications apply to reactivity condition of the reactor and the reactivityworths of the control rods and experiments. They apply for all modes of operation.Objective. The objective is to assure that the reactor can be shut down at all times.Specification(s). The reactor shall not be operated unless the shutdown margin provided by thecontrol rods is greater than $0.55 with:a. irradiation facilities and experiments in place and the total worth of all unsecured experimentsin their most reactive state; andb. the most reactive control rod fully withdrawn; andc. the reactor in the reference core condition.Basis. The value of the shutdown margin and limits on experiments assure that the reactor can beshut down from any operating condition even if the most reactive control rod should remain in thefully-withdrawn position.UCI Technical Specifications Pg eiin21-21Page 6Revision 2015-12-18 3.1.3 Core Excess ReactivityApplicability. These specifications apply to reactivity condition of the reactor and the reactivityworth of the control rods and experiments. They apply for all modes of operation.Objective. 'The objective is to assure that the reactor can be shut down at all times and to assure thatthe fuel temperature safety limit shall not be exceeded.Specification(s). The maximum available core excess reactivity based on the reference corecondition shall not exceed $3.00.Basis. An excess reactivity limit of $3.00 allows for flexibility in operating the reactor in steadystate mode while limiting the reactivity addition for pulse operation. Computations presented in theSAR (Chapter 13.3) establish that a sudden insertion of $3.00 results in a fuel temperature ofapproximately 350°C, well below the established safety limit for this fuel (Technical Specification2.1). Such calculations are conservcative, being based on a purely adiabatic model. Thespecifications assure that no insertion of reactivity above this value shall be possible, even undernon-normaal operating conditions.3.1.4 Pulse Mode OperationApplicability. These specifications apply to fuel temperatures generated in the reactor as a result ofa pulse inser~tion of reactivity.Objective. The objective is to assure that the fuel temperature safety limit shall not be exceeded.Specification(s). The reactor shall not be operated in the pulse mode unless in addition to therequirements of Technical Specification 3.1.2 and 3.1.3:a. the steady-state power level of the reactor is less than 1 kilowatt; andb. the total reactivity worth of the two transient control rods (ATR + FTR) is measured to notexceed $3.00.Basis. The fuel temperature rise during a pulse transient has been calculated conservatively using anadiabatic model. Pulse reactivity insertion with the power level below 1 kW assures that the startingtemperature for a pulse rise is below 25°C. The temperature rise from a $3.00 reactivity insertionpulse is thus calculated to bring the peak fuel temperature to less than 400°C, well below the safetylimit and well below the recommended rnaxinmum fuel temperature limit of 830°C.(GA Report, A16613, 1981.)3.1.5 This section intentionally left blank.UCI Teclmical Specifications Pg eiin21-21Page 7Revision 2015-12-18 3.1.6 Fuel Element Inspection ParametersApplicability. The specifications apply to all fuel elements, including fuel follower control rods.Objective. The objective is to maintain integrity of fuel element cladding._Specification(s). The reactor shall not be operated with any fuel element identified to show damage.An exception is made for operation up to a power level at which a leak becomes detectable solely inorder to be able to identify the leaking element. A fuel element shall be identified as showingdamage and be removed from core if:a. the transverse bend exceeds 1/16" inches (0.0625 in) over the length of the element; orb. the growth in length over original measurements exceeds 1/8fli inch (0.125 in); orc. a cladding defect is suspected by a finding of release of any fission products; ord. visual inspection identifies unusual pitting, bulging, or corrosion; ore. burn-up of the element is estimated to exceed 50%.Basis. These criteria are established by NUREG 1537 section 14.1. NUREG 1282 describesexperiments indicating TRIGA fuel can safely be used to at least 50% burn-up.3.1.7 Core ConfiguirationApplicability. This specification applies to the configuration of fuel and in-core experiments.Objective. The objective is to assure that provisions are made to restrict the arrangement of fuelelements and experiments so as to provide assurance that excessive power densities will not beproduced.Specification(s).a. The core shall be an a-rangement of TRIGA 8.5/20 Low Enriched Uranium (LEU) fuel.b. The core fuel elements shall include at least one 8.5/20 LEU fuel element with embeddedthennocouples to enable monitoring of fuel element temperature.c. The core fuel elements shall be kept in a close-packed array except for control rods, single- orthr-ee-element or" seven-element positions occupied by in-core experiments, irradiation facilities(including transfer system tennini), and a central dry tube.d. The reflector, excluding experiments and experim~ental facilities, shall be graphite or acombination of graphite and water.e. A control rod shall not be manually removed fr'om the core unless calculations show that thecore will be subcritical by >: $0.55 excluding the worth of the rod being worked on and theworth of the most reactive remaining control rod.UCI Technical Specifications Page 8 Revision 2015-12-18 Basis.a. TRIGA cores have been in use for years and their characteristics are well documented. LEUcores including 8.5/20 fuel have also been operated successfully at many facilities. In addition,analysis indicates that the low uraniumn loading, LEU 8.5/20 core will safely satisfy alloperational requirements. See chapters 4 and 13 of the SAR as supplemented by letter datedJune 7th 2011.b. The IFE provides a signal to the fuel temperature safety channel.c. Inner core lattice positions contain experiments or" an experimental facility to prevent accidentalfuel additions to the reactor core. Vacancies are permitted only on the periphery of the core,where reactivity worths are lower.d. Graphite and water reflectors are used for neutron economy and the enhancement ofexperimental facility radiation char'acteristics.e. Manual manipulation of control rods wilt be allowed only when a single manipulation cannotresult in inadvertent criticality.3.2 Reactor Control and Safety Syrstems3.2.1 Control RodsApplicability. This specification applies to the function of control rods.Objective. To assure control rods are operable and that prompt reactor shut down following a scramis accomplished.Specification(s). The reactor shall not be operated unless the REG, SHIM and ATR control rods areoperable. Control rods shall not be considered operable if:a. dam~age or deterioration is apparent to any rod or drive assembly that could affect operation; orb. the scram time for any control rod is greater than 1 second for 90% reactivity insertion; orc. the total reactivity worth of the two transient control rods (ATR and FTR) is greater than $3.00.Basis. Experience has shown that rod movement is assured inl the absence of damage and that scramatimes of less than 1 second are more than adequate to reduce reactivity and fuel temperaturesrapidly to assure safety in view of known transient behavior of TRIGA reactors. The FTR rod isnot vital to safe scram as a result of its low worth value (less than $1.00) and can remaln in core ifnot needed for pulsing. The total worth of the two transient rods is limited so as to restrict the pulsesize.UCI Technical Specifications Pg eiin21-21Page 9Revision 2015-12-18 3.2.2 Reactor Measuring ChannelsApplicability. This specification applies to the information which shall be available to the reactoroperator during reactor operation.Objective. To specify that minimum number of measuring channels that shall be available to theoperator to assulre safe operation of the reactor.Specification(s). The reactor shall not be operated in the specified mode unless the measuringchannels described in Table 1 are operable.Table 1. Minimum Measuring ChannelsMeasuring Channel Operating ModeSteady-state PulseFuel Element Temperature 1 1Linear Power Level 1ILog Power Level 1-Power Level (%) 1 1 (peak power)nvt circuit (integrated pulse -1energy)Note 1. Any single power level channael may be inoperable while the reactor is operating solelyfor the purpose of calibration and/or channel tests or checks on that channel.Note 2. Any single power level channel that is not required for safety scram purpose by TS3.2.3 and ceases to be operable during reactor operation shall be returned to operatingcondition within 5 minutes or the reactor shall be shut downa. For channels required by TS3.2.3 the reactor shall be shut down immediately if the channel becomes inoperable.Basis. The fuel temperature displayed at the control console gives continuous information on theparameter which has a specified safety limit. The power level monitors assure that measurements ofthe reactor power level are adequately covered at both low and high power ranges in appropriatemodes. Notes 1 and 2 allow for necessary tests for resolving of problems or recalibration whilemaintaining sufficient informnation for safe operation.UCI Technical SpecificationsPae1Rvion25--8Page 10Revision 2015-12-18 3.2.3 Reactor Safety SystemApplicability. This specification applies to the reactor safety system channels.Objective. To specify the mininmum number of reactor safety system channels that shall be operablein order to assure that the fuel temperature safety limit is not exceeded.Specification(s). The reactor shall not be operated unless the safety system channels described inTable 2 and the interlocks described in Table 3 are operable in the appropriate operating modes.Table 2. Minimum Reactor Safety ChannelsSafety Channel Function and trip level setting Operating ModeSteady-state PulseFuel Element Scram -_<425°C (lFE) I 1TemperatureReactor Power level Scram -<110% of 250 kw~t) 2 -(< 275 kw)Loss of HV and/or Scram 1 1signal on any requiredchannel _____Manual Bar Scram 1 1Preset Timer Scram pulse rods < 15 seconds -1after pulseSeismic Switch Scram -if motion of >3% g 1 1(< 0.03g)Pool Water Manual Scram 1 1Temperature if> 25°C_____________Table 3. Minimum InterlocksOperating ModeInterlock Function Steady- PulsestateWide Range Power Prevent control rod withdrawal when power level is < 1 1 -Level Channe (Log) x 10o-7 % of full power ___REG, SHIM, ATR Prevent application of air to fast transient rod when all 1-Control Rod Drives other rods are not fully insertedREQ, SH-IM, ATR Prevent simultaneous withdrawal of more than one rod 1REG, SHIM, ATR Prevent mnovement of REG and SHIM rods and ATR -1Control Rod Drives drive in pulse modeATR Cylinder Drive Prevent application of air to adjustable transient rod 1-_________________unless cylinder is fully downWide Range Linear Prevent ATR or FTR withdrawal unless power level _< 1 -. 1Power Channel kilowattUCI Technical SpecificationsPae1Rvion25-28Page 11Revision 2015-12-18 Basis.S crams. The fuel temperature scram provides the protection to assure that if a condition resultsin which the safety limit is approached, an immediate shutdown will occur to keep the fueltemperature well below. The justification basis is described in Technical Specification 2.2. Thepower level scrams are provided as added protection against abnormally high fuel temperature.The manual scram allows the operator to shut down the system if an unsafe or abnormalcondition occurs. A high voltage scram on each channel assures that detector response isoperating at all times. The seismic switch will scram the reactor if earth movement in anydimension exceeds 3% g (0.03g) in case the operator is prevented from operating the manualscram at the time. This level corresponds to movement noticeable by most persons, but (by MMscale) results in no damage to structures. The preset timer" scram provides pulse "clipping" toreduce energy production at the tail of a pulse. The pooi water level temperature limit is thevalue used for the thennal hydraulic analysis input coolant temperature in the SAR assupplemented by letter dated June 7th 2011, and also is designed to reduce stress between thealuminum tank liner and its concrete surround.Interlocks. The interlock to prevent startup of the reactor with less than 10o-7 % power indicationassures that indication of neutron multiplication is present as reactivity is inserted. Theinterlocks on control rod drives are provided to prevent withdrawal of more than one control rodat a time avoiding multiple simultaneous reactivity insertions by operators. The interlockswhich prevent the firing of the transient rods in the steady-state mode or if the power level isgreater than 1 kilowatt prevent inadvertent pulses or pulsing when fuel temperature is too high.3.3 Coolant Systems3.3.1 Pool Water LevelApplicability. These specifications apply to the water level in the reactor pool at all times.Objective. To assure there is sufficient water in the reactor pool to provide cooling and shielding forradiation fr'om the core, and to check for potential pool leakage.Specification(s).a. The reactor shall not be operated unless the pool water level is at least 24 feet above the tankfloor (1 foot below the tank edge).b. An audible alarm, with reporting to a monitored remote location if not locally silenced by anoperator, shall operate continuously to alert personnel if the water level in the reactor pool fallsbelow the above limit. Visual checking of water level shall be substituted every 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> duringperiods when the alarmn is found to be inoperable and no substitute level device has beenimplemented.c. Records shall be main~tained of the date, time and quantity of all make up water added to thepool.Basis. Facility design calculations and subsequent measurements show that these water levels aresufficient to reduce full power operational radiation levels to acceptable levels within the facilityand in any occupied areas above or surrounding the reactor. This is also true for shut down levels.The alarm will notify appropriate responders well before any increase in radiation levels to theUCI Technical Specifications Page 12 Revision 2015-12-18 surroundings occurs. The alarm and the operational make up water records will, ifit occursunusually frequently, alert operators to the possibility that pooi leakage might be occurring. Thepool level is normally maintained at approximately 10 inches below the tank edge. Thus the alarmlevel is at 2 inches below the normal level corresponding to evaporation or leakage of only 160gallons (640 liters, or 0.6% of total pool water). The maximumr water leak rate calculated (SAR)indicates that the water would be at a sufficient level over the core for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to preventunsafe release of radiation to the surrounding areas. Procedures call for a substitute pool level alarmsystem to be implemented during any extended period of failure.3.3.2 Pool Water TemperatureApplicability. This specification applies to the water temperature in the reactor pool at all times.Objective. To assure the water in the reactor pool stays within limits that provide sufficient coolingof the fuel and that minimizes stresses to the tank and reactor components.Specification(s). The pooi water temperature shall be maintained between 17°C and 25°CBasis. These temperature limits are easily maintained using the available cooling system and guardagainst temperatu-es that might produce undue stresses on tank components or water purificationsystems. The thermal hydraulic analysis was based on an inlet core temperature of 25°C.3.3.3 Pool Water ConductivityApplicability. This specification applies to the conductivity of water in the reactor pool at all times.Objective. To assure the water in the reactor pool is mainltained at high purity to minimize potentialcorrosion of reactor components.Specification(s). The pool water conductivity level shall be maintained less than 3 micromhos/cm.Make-up water shall meet this specification before being added to the pool.Basis. Experience at other reactor facilities indicates that maintaining the conductivity within 5micromhos/cm is adequate to provide acceptable control of corrosion (NUJREG 1537). Anadditional mar-gin of assur~ance is provided by this lower specification. Degradation fr-om thisconductivity also aids in assessing possible leakage of treated secondary coolant water into theprimary coolant water.3.3.4 Pool Water RadioactivityApplicability. This specification applies to the radioactivity of water in the reactor pool at all times.Objective. To assure the water in the reactor pool is maintained at high purity.Specification(s). The average pool water radioactivity level shall be maintained within limits forsewer disposal as established by 10 CFR § 20, Appendix B, Table 3 for radionuclides with half-lives longer than 24 hourns.Basis. Maintenanlce at this level will assure that any disposal of pool water, either planned orinadvertent, will be withfin appropriate and significant radioactivity limits. It also will provideverification of absence of fission product leakage.UCI Teclmical SpecificationsPage 13Revision 2015-12-18 3.4 This section intentionally left blank3.5 Ventilation Systems3.5.1 Ventilation System.Applicability. This specification applies to the operability and operation of the facility ventilationsystem.Objective. To assure that the ventilation system is operable to mitigate the consequences of possiblereleases of radioactive materials resulting from reactor operation.Specification(s).a. The reactor shall not be operated unless the ventilation system is operating as indicated by:i. a minimum of 0.10 inches of water negative pressure difference between the reactorroom and the control room and between the reactor room and the air outside thebuilding; andii. a minimum total exhaust flow rate from the reactor room area of 3600 cubic feet perminute (cfln) is present.Note: The ventilation system may be inoperable for periods of time not to exceed two hours toallow repair, maintenance or testing of the system. During such an exception, no pulses shall befired..b. The reactor shall not be operated unless it is verified that the ventilation system goes into theemergency mode upon manual actuation or a signal of high radiation activity from a ContinuousAir Particulate Monitor (CAM) measuring air from above the pool as described in TechnicalSpecification 3.5.2. Verification shall be by observing the emergency flow rate is at least 240cubic feet per minute (cfmn), the absence of regular exhaust flow, and the pressure differentialreading between the reactor room and the outside is negative.c. Radioactive by-product materials shall not be handled in the facility unless the ventilationsystem is operating as described in Technical Specifications 3.5.1 .a. and 3.5.1 .b. above.Basis. Through a combination of inflow danlipers and outflow exhaust, facility design establishesand exceeds these pressure differentials and flows. The differential pressure assists in confinementof radioactive materials. The SARl establishes that norm~al operation effectively dilutes 41At levelsbelow 10 CFR § 20 limits and as detailed in facility annual reports. An automatic emergency modewith a small filtered purge exhaust is provided to limit release of radioactivity to the environment.Operation of the normal system adequately dilutes the 41A released during experimentaloperations. The two hour exemption should not diminish the effectiveness of the CAM in detectingany release of radioactivity. The requirement not to pulse while the ventilation system isunmdergoing repair reduces the likelihood of fuel element failure during such times. The ventilationsystem should be required for by-product handling activities to reduce potential impact of release ofvolatile chemicals.UCI Technical SpecificationsPae1Rviin25-28Page 14Revision 2015-12-I 8 3.5.2 Ventilation During Emergency SituationsApplicability. This specification applies to the ventilation system provided for emergencysituations.Objective. To assure there is confinement of radioactive releases by closing of normal ventilationand establishing emergency ventilation.Specification(s). A signal of high radiation activity alarm from a Continuous Air ParticulateMonitor (CAM) measuring air fr'om above the pool or manual operation from the control room shallcarry out the following functions:a. close off inflow air by closing dampers; andb. close off outflow ai" by closing dampers in exhaust ducts and removing power from relevantexhaust fans and fume hood; andc. remove power from pneumatic transfer system so it can no longer operate to tr'ansfer air throughany core region; andd. open outflow damper in a small "purge" exhaust duct system equipped with a IIEPA filter.Basis. These actions will result in confinement of any released radioactive materials, whilebeginning to purge contaminated air through a high grade filter. Experience has shown that fissionproduct release from fuel elements is most rapidly detected by a CAM operating in this manner.The SAR establishes that the emergency purge system will, in the event of a radioactive gas release,be effective in limiting release to the environament and also providing personnel with sufficient timeto evacuate before experiencing serious exposure. It is shown in Chapter 13 of the SAR, assupplemented by letter dated Dec 2nd 2011, that operation of the emergency exhaust system reducesoff-site doses to below 10 CFR § 20 limits in the event of a TRIGA fuel element failure. It isshown also that, if the reactor were to be operating at full steady-state power, fuel element failurewill not occur even if all the reactor tank water were to be lost immediately.3.6 This section intentionally left blankUCI Technical SpecificationsPae1Rvion21128Page 15Revision 2015-12-18 3.7 Radiation Monitoring Systems and Effluents3.7.1 Radiation Monitoring SystemsApplicability. This specification applies to monitoring of radiation levels.Objective. To assure information is available to provide assurance of radiological safety ofpersonnel at the facility, and of the absence of excessive releases beyond the facility.Specification(s).a. The reactor shall not be operated unless the following minimum radiation monitoringinstruments are operating:Minimum NumberOperatingRadiation Area Monitors (RAM) 2Continuous Air Particulate Monitor (CAM) 1b. Environmental monitoring dosimeter packs, exchanged at least quarterly, shall be in place at theprimary exhausts of the facility at all times, except when undergoing exchange. Additionalpacks shall be located in adjacent buildings, and in a more remote control location forcomparison.Basis. These instruments through warnings and alarms will provide adequate notification ofabnormal levels that could result in exposures or uncontrolled releases. The CAM provides a signalto actuate the ventilation emergency mode (Technical Specifications 3.5.1 .b, 3.5.2, and 5.5.e). TheCAM alarm set point is based on limiting air concentrations to below the DAC level for 1- 131 aslisted in Appendix B of 10 CFR § 20. The environmental dosimeters provide information that canbe used to track long term trends that might need attention.UCI Technical SpecificationsPae1Rvion25--8Page 16Revision 2015-12-18 3.7.2 EffluentsApplicability. This specification applies to the release rate of 41Ar gas and liquid effluents.Objective. To assure that concentration of 41Ar in air and any liquid effluents released to accessibleunrestricted areas shall be below the applicable limits of 10 CFR § 20.Specification(s).a. The annual average concentration of 41Ar released to the environment shall notexceed 1 x 10-8 microcuries per milliliter (giCi/mL).b. The quantity of radioactivity in liquid effluents released from the facility to the sewer systemshall be soluble and not exceed the limits of 10 CFR § 20, Appendix B, Table 3.Basis. ,a. The analysis presented in Chapter 13.2 of the SAR, as supplemented by letter dated Oct 3rd2011, concludes that the building exhaust and room ventilation system normally provides adilution factor of 100 at the point of external release for airborne concentrations in the facilityarea. Under extremely unlikely conditions involving system failures, it provides a dilutionfactor of at least 30, reducing the facility room concentration predicted from calculations andmeasurements as a result of normal reactor operation to be well below 10 CFR § 20 AppendixB, Table 2 requirements (1 x 10-8 pgCi/mL). This will be further assured since releases arepermitted to be averaged over a one year period. The exposure risk to the public is reducedsince the discharge plume is at a high level above the roof. Annual reports from this facilityhave shown that levels released have been well below this value.b. This specification establishes assurance that any release of radioactive materials contained inliquids released to the sewer system does not exceed the limits required by regulations.3.8 Limitations on Experiments3.8.1 Reactivity LimitsApplicability. This specification applies to experiments placed in the reactor and its experimnentalfacilities.Objective. The objective is to prevent damage to the reactor or excessive release of radioactivematerials in the event of an experiment failure._Specification(s). The reactor shall not be operated unless the following conditions governingreactivity worths exist:a. the reactivity worth of any unsecured or moveable experiment shall not exceed $1.00; andb. the reactivity worth of an individual experiment shall not exceed $3.00; andc. the sum of the absolute values of reactivity worths of all experiments shall not exceed $3.00.UCI Technical SpecificationsPae1Rvion21--8Page17Revision 2015-12-18 Basis. The limit on an unsecured experiment is to prevent an inadvertent pulse, and to maintainshutdown margin limitations. The insertion of $3.00 pulses has been analyzed as a safe operatingcondition for this reactor (SAR Chapter 13). Limitation of experiments such that a pulse larger thanthis value could not occur is prudent and stays well within safe limits. The limitations also assurethat achievement of margins for shutdown is assured.3.8.2 MaterialsApplicability. This specification applies to experiments placed in the reactor and its experimentalfacilities.Objective. To prevent damage to the reactor and to minimize excessive release of radioactivematerials in the event of an experlinent failure.Specification(s). The reactor shall not be operated unless the following conditions governingexperiments exist:a. fueled experiments shall be limited such that the total inventory of iodine isotopes 131 through135 in the experiment is not greater than 0.02 curies, and the strontium-90 invento1ry does notexceed 1 microcurie; andb. explosive materials in the amount of 25 milligrams of TNT (or equivalent) or lesser quantitiesmay be irradiated provided that the pressure produced upon accidental detonation of theexplosive has been calculated and/or experimentally determined to be less than halft the designpressure of the container; andc. experiments containing col'osive materials shall be doubly encapsulated. The failure of anencapsulation of material that could damage the reactor shall result in removal of the sampleand physical inspection of potentially damaged components.Basis. In specification a, an assumption is made that complete release of volatile material (iodine)from a fueled experiment is possible. It is shown in the SAR, Chapter 13, as supplemented by letterdated Dec. 2fld 2011, that a release of 0.02 curies of iodine activity would result in a maximum doseto a person in the facility who evacuates in 5 minutes of 0.4 rem, or less than 1/75th of the 50 remlimit in 10 CFR § 20. An individual directly exposed in the exhaust in an unrestricted area underhighfly unlikely conditions would receive (TEDE) less than 0.54 mrem. The maximumn projectedTEDE to a person in the nearest living area will be less than 0.22 mrem, far" less than the 100 mremlimit in 10 CFR § 20. These computations are extremely conservative as they assume no pool wateris present. In the event of a failed experiment the pool water would be present to absorb/dissolvehalogens and reduce the airborne concentrations.Specifications b and c reduce the likelihood of damage to reactor components resulting fromexperiment failure and use information from NRC Reg. Guide 2.2.UCI Technical Specifications Pg 8Rvso 0 -21Page 18Revision 2015-12-18 3.8.3 Failures or MalfunctionsApplicability. This specification applies to experiments placed in the reactor and its experimentalfacilities.Objective. To prevent damage to the reactor as well as to minimize release of radioactive materialsin the event of an experimaent failure.Specification(s).a. Where the possibility exists that the failure of an experiment under (a) normal operatingconditions of the experiment or the reactor, (b) credible accident conditions in the reactor, or (c)possible accident conditions in the experiment could release radioactive gases or aerosols to thereactor room or anly unrestricted area, the quantity and type of material in the experiment shallbe limited in activity such that exposures of the reactor personne to the gaseous activity orradioactive aerosols in the reactor room or control room will not exceed the occupational doselimits in 10 CFR § 20.1201. Additionally, exposures to members of the public to these releasesin the unrestricted area will not exceed the dose limaits in 10 CFR § 20.1301. hn calculatingpotential consequences, one or more of the following assumptions shall be made, as applicable:i. 100% of the gases or aerosols escape from the experiment.ii. If the effluent from an experimental facility exhausts through a hold-up tank, whichcloses automatically on high radiation levels, 10% of the gaseous activity or aerosolswill escape.iii. If the effluent from an experimental facility exhausts through a filter installationdesigned for greater than 99% efficiency for 0.3 micron particles, 10% of the aerosolswill escape.iv. For materials whose boiling point is above 550C and where vapors formed by boilingthis material are radioactive and could escape only through an undisturbed column ofwater above the core, 10% of these vapors escape.b. If an experiment container fails and releases material which could damage reactor fuel orstructure by corrosion or other means, physical inspection shall be performed to determine theconsequences and the need for corrective action before further operation of the reactor.Basis.a. This specification is intended to assist experiment review and design in meeting the goals of 10CFR § 20 by reducing the likelihood of excessive facility personnel or public exposure by gasesor aerosols as a result of experiment failure.b. This specification is intended to assure that any facility damage as a result of experimnent failureis appropriately corrected before operations are resumed.3.9 This section intentionally left blank.UCI Technical SpecificationsPae1Rvion25--8Page 19Revision 2015-12-18
- 4. SURVEILLANCE REQUIREMENTS4.0 GeneralApplicability. Thfis specification applies to surveillance requirements of any system related toreactor safety.Objective. To assure the proper operation of any system related to reactor safety.Specification(s).a. Surveillance requirements may be deferred during prolonged (periods greater than 1 month)reactor shutdown (except Technical Specifications 4.2.j, 4.3.a, 4.3.b, 4.3.d, and 4.3.e). However,they shall be completed prior to reactor start-up unless reactor operation is required forperformance of the surveillance. Such surveillance shall be performed as soon as practicableafter reactor start-up. Scheduled surveillance which cannot be performed with the reactoroperating may be deferred until a planned reactor shutdown.b. All replacements, modifications, and changes to systems having a safety related functionincluding the ventilation system, the core and its associated support structure, the pool, the poolcoolant system, the control rod drive mechanisms, and the reactor safety system shall meet orexceed the requirements of the original system or component. A safety system shall not beconsidered operable until it has been properly tested to meet specifications.Basis. Changes or maintenance can affect reactor operation parameters. This specification willassure that safety systems function according to established criteria before any reactor operation.UCI Technical SpecificationsPae2Rvion05-21Page 20Revision 2015-12-18 4.1 Reactor Core ParametersApplicability. This specification applies to the surveillance requirements for reactor coreparameters.Objective. To verify that the reactor does not exceed authorized limits for power, shutdown margin,core excess reactivity, specifications for fuel element condition, and verification of total reactivityworth of each control rod.Specification(s).a. The total reactivity worth of each control rod shall be measured annually or" following anysignificant change (>$0.25) in core configuration.b. The core excess reactivity shall be determined using control rod position data prior to eachday's operation, or prior to each operation extending more than one day, or following anysignificant change (>$0.25) in core configuration.c. The shutdown margin shall be determined at each day's startup, or following any significantchange (>$ 0.25) in core configuration.d. All core fuel elements shall be inspected (unader water) to assure compliance with TechnicalSpecifications 3.1 .6.a through 3.1 .6.d quinquennially, but at intervals separated by not morethan 500 pulses of magnitude greater than $1.00 of inserted reactivity. Fuel follower controlrods shall be visually inspected and measured for bend at the same time interval. Suchsurveillance shall also be performed for elements in the B and C rings in the event that there isindication that fuel temperatures greater than the limiting safety system setting on temperaturemay have been exceeded.e. Prior to resumption of routine pulse mode operations following a period of no pulse modeoperations for more than 1 year, a test of pulsing performance with a pulse insertion of $1.50shall be performed to assure pulsing power and fuel temperature response is as predicted fromprior experience.f. Full core, fuel and control rod surveillance shall be conducted before further reactor operation ifsignificant changes are observed in any measured parameters such that it could be concludedthat fuel element or control rod integrity has been compromised or fuel element or control roddamage has occurred.Basis. Experience has shown that the identified frequencies are more than adequate to ensureperformmance and operability for this reactor. The value of significant change is measureable andwill assure sufficient shutdown margin even taldng into account decay of poison.For fuel elements, the most severe stresses induced in the fuel elements result from pulse operationof the reactor, during which differential expansion between the fuel and the cladding occurs and thepressure of the gases within the elements increases shar~ply. The sm-weillance interval is selectedbased on the past history of more frequent, uneventful, inspections for over 40 years at this facilityand experience at other TRIGA~ facilities with similar power levels, fuel type, and operationalmodes. It is also designed to reduce thle possibilities of mechanical failur-es as a result of handlingelements, and to minimize potential radiation exposures to personnel.UCI Technical SpecificationsPae2Rvion05121Page 21Revision 2015-12-18 4.2 Reactor Control and Safety SystemsApplicability. This specification applies to the surveillance requirements for the reactor control andsafety systems.Objective. The objective is~to verify performance and operability ofthose systems and componentswhich are directly related to reactor safety.Specification(s).a. A channel calibration shall be made of the power level monitoring channels by the calorimetricmethod annually or immediately following any significant (>$O.25) core configuration change.b. Control rod scram times for all four control rods shall be determined annually or for individualrods immediately following any maintenance work involving that control rod or drivemechanism that may have affected rod scram performance.c. All control rods shall be visually inspected for deterioration quinquennially.d. The transient (pulse) rod pneumatic cylinders and the associated air supply systems shall beinspected annually, and cleaned and lubricated if necessary.e. On each day that pulse mode operation of the reactor is planned, the transient (pulse) rod systemshall be verified to be operable before pulse operation is initiated.f. A channel test of each of the reactor safety system channels and interlocks in TechnicalSpecification 3.2 Tables 2 and 3, except for the pool water temperatture measuring channel, shall*be performed prior to each day's operation .or pr:ior to each operation extending more than oneday.g. A channel check of the functions of the seismic switch shall be performled annually or as soonas possible after an observed seismic event or one reported to be of sufficient magnitude to tripthe switch.h. A calibration of the pool water temperatture measuring channel shall be performed annually toinclude verification of the alarm set point.i. A calibration of the fuel temperature measuring channel shall be performed annually.j. A calibration of the pool water level measuring chmannel shall be performed annually to includeverification of the alarm set point.Basis. The control rods are inspected and scram times checked to assure safe scram operations. Thesurveillance intervals for those and the channel surveillances are selected based on the past historyfor over 40 years at this facility and are adequate to correct for long term dr-ifts and other instrumentproblems. The manufacturer of the seismic switch makces no recommendation for recalibration andbelieves the accelerometer settings remain effective for the life of the device. The channel test ofthe seismic switch involves simulation of a seismic event by tapping the switch to initiate a reactorscram, establishing operational functionality.UCI Technical SpecificationsPae2Rvion21--8Page 22Revision 2015-12-18 4.3 Reactor Pool WaterApplicability. This specification applies to the surveillance requirements for the reactor pool water.Objective. The objective is to assure that the reactor pool water level channel is operable, that alarmsettings are verified and alarm reporting is functional. In addition, that the water level and purity isbeing maintained within acceptable limits.Specification(s).a. A channel check of the pool water level measuring channel shall be performed monthly toinclude channel verification of the alarm reporting system.b. The pool water conductivity shall be measured at the end of each operating day or at shutdownfor a period of operation extending more than one day. For periods of extended shutdown theconductivity measurement shall be made monthly.c. The pool water temperature shall be monitored each hour during reactor operation.d. The pool water radioactivity shall be mneasured quarterly.e. The pool water loss rate shall be evaluated on each occasion when make-up water is added tothe pool. Any unusual increase in loss rate shall be investigated as a possible pool leak beforeany further reactor operation.Basis. These verifications will assure that a continued warning system for an unexpected loss ofpool water is maintained, and that any perturbation of pool water quality noted then allows forcorrective action to minimize corrosion, or build-up of radioactivity in the water. The frequentcheck on conductivity monitors possible leakage into the pooi from the secondary water system.Temperature measurrements will assure the pool water is maaintained within operating limits.Radioactivity measurements will enable assessments of long term impacts of pool leaks and/orfission product leaks from a fuel element.4.4 This section intentionally left blank.UCI Technical SpecificationsPae2Rvion01--8Page 23Revision 2015-12-18 4.5 Ventilation SystemsApplicability. This specification applies to the surveillance requirements for the reactor roomventilation system.Objective. To verify~ performance is adequate to provide for normal and emergency modeventilation for the facility to control and confine releases of airborne radioactive materials.Specification(s).a. A channel check of the existence of negative air pressure between the reactor room and thecontrol room, and the reactor room and the outside air in both normal and emergency modesshall be performed daily.b. A channel check of the exhaust flow rates from the reactor area in both normal and emergencymodes shall be performed daily, to demonstr'ate that the ventilation system is operable in bothnormal and emergency modes by observation of flow rates, and valve/damper action.c. A channel test of the function of the Continuous Air Particulate Monitor (CAM) alarm and thecontrol room manual switch to properly set the ventilation system into emergency mode shall beperformed daily.Basis. Based on experience, these surveillances will assure that the ventilation system is functioningas specified. (Technical Specification 3.5).4.6 This section intentionally left blank.UCI Teclmical SpecificationsPae2Rvion01-28Page 24Revision 2015-12-18 4.7 Radiation Monitoring System and EffluentsApplicability. This specification applies to the surveillance requirements for the radiationmonitoring instrumentation required by Technical Specification 3.7.1l.a and the effluent releasesspecified by Technical Specification 3.7.2.Objective. The objective is to assure that the radiation monitoring system is operating properly andto verify the appropriate alarm settings and amounts of radioactivity in effluent releases.Specification(s).a. A channel test of the area radiation monitoring systems required by Technical Specification3.7.1.a shall be perfon~ned monthly. This shall include verification of the alarm set points.b. A channel check of the Continuous Air Particulate Monitor (CAM) required by TechnicalSpecification 3.7.1 .a shall be performed daily. This shall include verification of the alann setpoint.c. A channel calibration of the radiation monitoring systems required by Technical Specification3.7.1 .a shall be performed annually.d. The environmental monitoring dosimeters required by Technical Specification 3.7.1 .b includingthose monitoring exhaust effluents, shall be evaluated quarterly.e. Any liquid effluents to be released to the sewer system from the facility shall be verified tocontain only soluble materials and analyzed for radioactive content prior to release.Basis. Surveillance of the equipment and effluents will assure that sufficient protection againstexcessive radiation or release of excessive radioactive materials is available. Past experience hasshown that these practices and frequencies are adequate to assure proper operation.4.8 Experiment LimitsApplicability. This specification applies to the surveillance requirements for experiments placed inthe reactor and its experimental facilities.Objective. The objective is to assure that experiments to be conducted do not damage the reactor orrelease excessive amounts of radioactive materials as a result of experiment failnre.Specification(s).a. No experiment shall be installed in the reactor unless a safety analysis has been performed andreviewed in accordance with Technical Specifications 3.8 and 6.5.b. The reactivity worth of a new experiment shall be verified at a power level less than 2 watts,before reactor operation at higher power with the experiment.Basis. Past experience has shown that adherence to requirements described in TechnicalSpecifications 3.8 and 6.5 are adequate to assure safe experimaentation at this facility.UCI Technical Specifications Page 25 Revision 2015-12-18v
- 5. DESIGN FEATURES5.1 Site and Facility DescriptionSpecification(s).The site shall be the reactor facility as described below.The reactor facility shall be a restricted access area consisting of a main area, two associatedlaboratory areas, and a control room on a single level in the basement of Rowland Hall, on theUniversity of California Irvine campus. The minimum free air volume of the reactor area includingthe two associated laboratories shall be 23,000 cubic feet. Normal entry to these areas shall berestricted to a single doorway from the control room. Large doors shall be provided to the adjacentloading dock to provide emergency egress and/or access for incoming or outgoing large items. Fullvisibility shall be provided between the control room and the reactor area.The reactor shall be housed in a closed area designed to restrict leakage.Basis. The extent of the site and facility is specified to define the controlled access area and themeans of access. The closed area is designated to assist in mitigation of potential radioactivereleases.5.2 Reactor Coolant SystemSpecification(s).a. The reactor core shall be cooled by natural convection water flow.b. All piping and other equipment for pool water systems shall be above normal pool level. Inletand outlet pipes that lead to the heat exchanger or demineralizer shall be equipped with siphonbreaks not less than 14 feet above the upper core grid plate, unless those pipes end more than 14feet above the upper core grid plate.c. A pool water level indication is provided at the control console with an alarm at the controlconsole and an alarm to a central monitoring station.d. A pool water temaperature indication shall be provided at the control console.e. A pool water conductivity measurement instrument shall be provided in the reactor room.f. Gamma and beta radiation spectrometry equipment shall be provided for water sampleradioactivity assay.Basis. Pool water quantity and quality is controlled so as to limit radiation and/or radioactivityrelease, and corrosion of components. Information is necessary to provide staff with indications ofchange in pool water characteristics.UCI Technical SpecificationsPae2Rvion01-28Page 26Revision 2015-12-18 5.3 Reactor Core and Fuel5.3.1 Reactor Core.Specification(s).a. The core assembly shall consist of TRIGA standard 8.5/20 stainless steel clad fuel elements.b. The core fuel shall be kept in a close-packed array in core lattice positions except for controlrods, single- or three-element or seven-element positions occupied by in-core experiments,irradiation facilities (including transfer system termini), graphite dummy elements, and a centraldry tube.c. Reflection of neutrons shall be provided by combinations of graphite and water, with thegraphite in sealed containlnent with aluminum cladding, either in the form of rods occupyinggrid positions, or in a larger reflector structure sur~rounding the core.d. An Am-Be neutron source shall be provided in one of two specific locations provided in theupper grid plate to provide start-up neutrons. It may be removed for maintenance purposes.Basis. Standard TRIGA fuel and reactor core design has a long and successful history of use.Model calculations in the SAR as supplemented by letter dated June 7th 2011, indicate acceptableneutronic and thermal hydraulic conditions for the core design under extended use and burn-up. TheAm-Be source is in a sealed capsule and has a long useful life.5.3.2 Control Rods.Speciflcation(s).a. The SHIM and REG rods shall be motor driven with scram capability and solid boroncompounds in a poison section, with fuel followers of standard TRIGA~ fuel meeting the samnespecifications as in Technical Specification 5.3.3.b. The ATR transient rod shall be motor and pneumatically driven, have scram capability, andcontain solid boron compounds in a poison section. The ATR shall have an adjustable uppertravel limit to provide variable pulse insertion capability. The FTR transient rod shall bepneumatically driven and have scram capability, and contain solid boron compounds in a poisonsection. The ATR and FTR shall incorporate air filled followers.Basis. These control rods have been shown by model calculations and a history of use to beeffective for assuring prompt shut-down and control of the reactor.UCI Technical SpecificationsPae2Rvion25128Page 27Revision 2015-12-18 5.3.3 Reactor FuelSpecification(s). Standard TRIGA fuel elements shall have the following characteristics:a. The total uranium content shall be nominally 8.5 % by weight, enriched to less than 20% 235U.b. The hydrogen to zirconium atom ratio in the zirconium hydride shall be a nominal 1.65hydrogen atoms to 1.0 zirconium atom.c. The cladding shall be 304 stainless steel, nominally 0.020 inches thick.d. An upper fitting with an engraved unique serial number shall be designed to fit a latching toolfor fuel movement.Basis. TRIGA fuel elements meeting these manufacturer's specifications have a long history ofsuccessful use with minimal failures. Minor deviations about these levels due to manufacturingvariations are not to be considered violations of this specification.5.4 Fuel StorageSpecification(s).a. All fuel elements shall be stored in a geometrical array where the keiis less than 0.80 for allconditions of moderation and reflection.b. Irradiated fuel elements and fueled devices shall be stored in an array which will permitsufficient natural convection cooling by water or" air such that the fuel element or fueled devicetemperature will not exceed 80°C.c. Fuel showing evidence of damage (see Technical Specification 3.1.6) shall be stored separatelyfr'om fuel not suspected to be damaged, and shall be checked for fission product leakage.Basis. These specifications establish a sufficient reactivity margin to guard against accidentalcriticality of elements in storage, and that heat dissipation does not create excess corrosion or" otherproblems. Damaged fuel is more likely to have or develop fission product leakage and so must bemonitored and kept separately.UCI Technical SpecificationsPae2Rvion05-28Page 28Revision 2015-12-18 5.5 Ventilation SystemSpecification(s).a. The ventilation system shall operate in either normal or emergency mode. The ventilationsystem shall consist of ducts, blowers, dampers, flow and pressure measurement devices, andexhaust points above the roof of Rowland Hall.b. During normal operations, the ventilation system shall be capable of exhausting air or othergases from the reactor area at a minimum rate of 3600 cubic feet per minute (cfm).c. During normal operation the ventilation system shall be capable of maintaining a minimutm of0.10 inches of water pressture differential between the reactor area and the control room, andbetween the reactor area and the outside air.d. During emergency situations involving release of radioactive materials into the air, anemergency exhaust with a high efficiency particulate arrestance (HBPA) filter shall be providedto exhaust a minimtum of 240 cfin fr'om the reactor area.e. Shutdown of the normal reactor area exhaust system and start-up of the emergency exhaustsystem shall be initiated by a high radioactive particulate count rate alarm signal originating inthe reactor room, or a manual switch in the control room.f. During all modes of operation, the ventilation system shall exhaust at a minimum height of 90feet above ground level.Basis. The ventilation system assists in mitigating the effects of radioactive reeases to theenvironment by providing dilution and control of such releases either during normal or emergencycircumstances.UCI Technical SpecificationsPae2Rvion25--8Page 29Revision 2015-12-18
- 6. ADMINISTLRATIVE CONTROLS6.1 Organization and Structure6.1.1 Structure.The reactor facility is housed in the School of Physical Sciences of the University of California,Irvine. The reactor is related to the University structure of positions shown in the organization chart,Figure 1, where solid lines represent direct reporting responsibility, dashed lines indicate workingrelationships.6.1.2 Responsibilities.a. The licensee of the reactor is the Board of Regents of the University of California, which hasdelegated authority for license matters to the Provost and Executive Vice Chancellor (Level 1)of the University of California, Irvine.b. The reactor facility is under the direction of a Reactor Director (Level 2) who shall be a tenuremember of thle University of California Irvine faculty. The Reactor Director shall report to theChair of the Chemistry Departm'ent (Level 1), who, in turn, shall be responsible to thle Dean ofthe School of Physical Sciences.c. Operations shall be supervised by the Reactor Supervisor (Level 3) who shall hold a valid senioroperator's license for the facility. This position shall be responsible for assuring that alloperations are conducted in a safe manner and within the limits prescribed by the facilitylicense, the provisions of the Reactor Operations Committee and the provisions of the RadiationSafety Colmmittee.d. Reactor operators (Level 4) shall be responsible for operation of the reactor and performingneeded maintenance and surveillance, including radiological safety and necessary supervision ofexperimenters. Senior reactor operators shall assume duties for supervision of operators asrequired by thle US Nuclear Regulatory Commission (NRC) inl Part 55 of 10 CFR, andTechnical Specification 6.1.3.e. There shall be a University of California, Irvine campus Radiation Safety Officer (RSO)responsible for the safety of operations from the standpoint of radiation protection. This positionreports to the Office of Environmental Health and Safety which is an organization independentof the reactor operations organization as shown in Figure 1. An independent campus-wideRadiation Safety Colmmittee (RSC) is responsible for establishmlent and review of all policiesinvolving radiation and radioactivity. Routine radiological safety requirements within thereactor facility shall be carried out by reactor operators and/or individual experimenters, all ofwhom shall be required, by regulations, to have received training in radiological safety and beauthorized for radiation use by the campus Radiation Safety Officer.f. in the event of absence, or during filling of appointments to specific positions, temporary dutiesand responsibilities may be carried out by the person next higher or lower in line in theorganization chart, provided the individual meets the basic qualifications for both positions.UCI Teclmical Specifications Pg 0Rvso 01-21Page 30Revision 2015-12-18 Figure 1. UCI Reactor Organization ChartUCI Technical SpecificationsPae3Rvion21121Page 31Revision 2015-12-18 6.1.3 a. The minimum staffing when the reactor is not secured shall include:i. a licensed operator present in the control room; andii. a second designated individual present withfin Rowland Hall able to carry out prescribedinstructions and with the ability to check on the safety of the licensed operator and toact in the event of emergency; andiii. a licensed Senior Operator (SRO) readily available on call. Readily available Onl callmeans the SRO has been specifically designated, the designation is known to theoperator on duty, the SRO can be rapidly contacted by phone by the operator on duty,and the SRO is capable of arriving at the reactor facility within 30 minutes under normalconditions.b. A list of reactor facility personnel and other persons responsible for radiological safety andsecurity on campus shall be kept in the reactor control room for use by an operator orexperimenter. The list shall include telephone numbers of the Reactor Director, the ReactorSupervisor, the campus Radiation Safety Officer and other back-up radiological safetypersonnel, reactor operators, senior reactor operators, and personnel with responsibilities formaintenance in Rowland Hall.c. Experimenters using the facility shall be certified by the campus Radiation Safety program astrained and authorized to use radioactive materials. The training shall include both generalradiological training, including features of the ALARA program and specialized training inprocedures for using reactor atuxiliary experimental equipment (such as transfer systems),carrying out necessary surveys and record-keeping necessary for proper handling of radioactivematerials within the reactor facility. Experimenters so trained and authorized are responsible fortheir own personal and sample/apparatus monitoring.d. The following events require the presence in the facility of a licensed Senior Reactor Operator.1. Initial start-up and approach to power and final daily shutdown.ii. Fuel or control-rod relocations within the core region.iii. Insertion, removal, or relocation of any experiment worth more than $1.00.iv. Restart following any unplanned or unscheduled shutdown, or unexpected powerdecrease of >10%.6.1.4 Selection and Training of PersonnelThe selection, training, and requalification of operations personnel shall meet the requirements ofANSI/ANS- 15.4 -2007.UICI Technical Specifications Pg 2Rvso 01-21Page 32Revision 2015-12-18 6.2 Review and AuditA Reactor Operations Committee (ROC) shall review reactor operations to assure that the facility isoperated in a manner consistent with public safety and within the terms of thle facility license.Review and audit of radiological safety at the facility shall be carried out by the Radiation SafetyCommittee (RSC).6.2.1 ROC Composition and QualificationsThe ROC shall have at least five voting members, at least one of whom shall be a health physicistdesignated by the Office of Environmental Health and Safety of the University. The Committee as awhole shall be knowledgeable in nuclear science and issues reated to reactor and/or radiologicalsafety. The membership shall include at least two members who are not associated with theDepartment of Chemistr. Approved alternates may serve in the absence of regular members.Members and alternates and a chairperson for the committee shall be appointed by the Chair of theDepartment of Chemistry (Level 1) or higher authority. The Reactor Director and ReactorSupervisor shall be non-voting members of the committee.6.2.2 ROC Charter and RulesThe following responsibilities constitute the charter of the ROC.a. Meeting at least annually, with provision for additional meetings when circumstances warrant toassure safety at the facility.b. A quortum shall consist of not less than a majority of the voting members and shall include thechairperson or his/her designee. A quorum shall not consist of a majority of operations staff.c. Review and audit of facility staff and operations as indicated in Technical Specifications 6.2.3and 6.2.4.d. Designation of indivduals to perform audits of facility operations and records.e. Preparation, approval, and dissemination of minutes of meetings.f. Preparation and dissemination of findings and other reports as needed to assure safe operationsof the reactor.g. Approval of individuals for the supervision and operation of the reactor.UCI Technical Specifications Pg 3Rvso 01-21Page 33Revision 2015-12-18 6.2.3 ROC Review FunctionThe following review functions shall be the responsibility of the ROC.a. Review and approval of all proposed changes to the facility, its license, procedures, ROCcharter, and Technical Specifications, including those made under provisions of 10 CFR §50.59, and the determinations leading to decisions relating to 10 CFR § 50.59 approvals.b. Review and approval of new or changed procedures, experiments, components, or"instrumentation having safety significance.c. Review of the quality assurance program implementation applicable to the reactor components.d. Review of new experiments or changes in experiments that could have reactivity or safetysignificance.e. Review of violations of technical specifications, license, or violations of procedures orinstructions having safety significance.f. Review of operating abnormalities that have safety significance.g. Review of actions and reports listed in Technical Specifications 6.6.1, 6.6.2, or 6.7.2.h. Review of audit reports, including reports from the campus Radiation Safety Officer, regardingthe radiation protection program.6.2.4 ROC Audit FunctionThe ROC shall perform autdits or review audits performed by designated individuals on its behalf atleast annually. The autdit shall include, but not be limited to, the following items.a. Facility operations for conformance to the Technical Specifications and applicable licenseconditions.b. Retraining and requalification of operators according to the Requalification Plan.c. The result of action taken to correct those deficiencies that may occur in the reactor facilityequipment, systems, structures, procedures or methods of operation that affect reactor safety.d. The facility Emergency Plan (EP) and implementing procedures including written reports of anydr'ills or" exercises carried out.e. At least one of the auditors shall be familiar with reactor operations but not directly responsiblefor any portion of reactor operations.f. Any deficiencies identified in an audit that affect reactor safety shall be immediately reported tothe chairperson of ROC, and to the Level 1 administrator. A written fufll report shall besubmitted to ROC within 3 months of any audit.UCI Technical SpecificationsPae3Rvion25--8Page 34Revision 2015-12-18 6.3 Radiation SafetyAs delineated in Technical Specification 6.1.2.e, the campus Radiation Safety Officer (RSO) isresponsible for implementation of the radiological safety program at the reactor facility inaccordance with applicable federal and state of California standards and regulations. The programshould use the guaidelines of ANSI/ANS 15.11-2004.The RSO shall be responsible for an annual audit of the radiation safety program.6.4 Operating ProceduresWritten procedures, reviewed and approved by the ROC and the Reactor Director, shall be in effectand implemented for the following listed items. The procedures shall be adequate to assure thesafety of the reactor but not preclude the use of independent judgment and action should thesituation require such. Any changes to procedures shall be made in accordance with therequirements of 10 CFR § 50.59.a. Startup, operation, and shutdown of the reactor.b. Installation or removal of fuel elements, control rods, experiments, and experimental facilities.c. Maintenance of major components of systems that could have an effect on reactor safety.d. Surveillance checks, calibrations and inspections required by the technical specifications or thatcould have an effect on reactor safety.e. Personnel radiation protection, including provisions to maintain personnel exposures as low asreasonably achievable (ALARA).f. Administrative contr'ols for operations and maintenance, and for the conduct of irradiations orexperiments that could affect reactor safety.g. Implementation of required plans including Emergency (EP) and Physical Security (PSP) plans.h. Use, receipt and transport of by-product materials.6.5 Experiment Review and ApprovalApproved experiments shall be carried out in accordance with established and approved procedures.Procedures for experiment review and approval shall include the following requirements.a. All new experiments or class of experiment shall be reviewed and approved by the ROC andapproved in writing by the Reactor Director. The review shall include analysis by the RSO orother designated radiation safety personnel.b. Changes to existing experiments or classes shall be made only after review by the ROC andRSO or the RSO designee, following performance of a 10 CFR § 50.59 evaluation and theconclusion that the proposed changes do not require prior NRC approval.UCI Technical SpecificationsPae3Rvion211-8Page 35Revision 2015-12-18 6.6 Reqiuired ActionsThis specification is intended to assure compliance with requirements of 10 CFR § 50.36.6.6.1 Actions to Be Taken in Case of a Safety Limit ViolationIn the event the safety limit on fuel temperature is exceeded:a. the reactor shall be shut down and the event reported immediately to the Reactor Director, theROC chairperson, and the RSO. Reactor operation shall not be resumed until authorized by theNRC; andb. the event shall be reported within the next working day to the NRC Headquarters OperationsCenter; andc. a follow-up written r~eport sent shall be reviewed by the ROC and sent within 14 days to theNRC (according to provisions of Technical Specification 6.7) describing:i. applicable circumstances leading to the violation including, where kcnown, the cause andcontr'ibuting factors; andii. effects of the violation upon reactor facility components, systems, or structures, and onthe health and safety of personnel and the public; andiii. the basis for corrective action taken to preclude recurrence.UCI Teclmical SpecificationsPae3Rvion21--8Page 36Revision 2015-12-18 6.6.2 Actions to Be Taken in the Case of Events Other than a Safetyr Limit ViolationIn the event of an occurrence of the type listed in items 1-7 below:a. the reactor shall be secured and the Reactor Director and Supervisor notified; andb. operation shall not be resumed until authorized by the Reactor Director and the ROC; andc. a follow-up written report shall be reviewed by the ROC and sent within 14 days to the NRC(according to provisions of Technical Specification 6.7) describing:i. applicable circumstances leading to the violation including, where known, the cause andcontributing factors; andii. effects of the violation upon reactor facility components, systems, or structures, and onthe health and safety of personnel and the public; madiii. the basis for corrective action takcen to preclude recurrence.1. Release of radioactivity from the site above allowed limits.2. Operation with actual safety system settings for required systems less conservative than thelimiting safety system settings in these specifications.3. Operation in violation of limiting conditions for operation unless prompt remedial action is*taken as permitted in Technical Specification section 3.4. A required reactor safety system component malfunction that renders or could render the safetysystem incapable of performning its intended safety function. If the malfunction or condition is* caused by maintenance, then no report is required.5. Ant unanticipated or uncontrolled change in reactivity greater than one dollar. Reactor tripsresulting from known cause are excluded.6. Abnormal or significant degradation in reactor fuel or cladding, or both, coolant boundary, orconfinement boundary (excluding minor leaks) where applicable.7. An observed inadequacy in implementation of administrative or procedural controls such thatthe inadequacy causes or could have caused the existence or development of an unsafe conditionwith regard to reactor operations.UCI Technical SpecificationsPae3Rvion25-21Page 3 7Revision 2015-12-18 6.7 ReportsIn addition to the requirements of applicable regulations, and in no way substituting for them,reports shall be made to the NRC as listed below. All writt en reports shall be directed to theDocument Control Desk, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555-0001.6.7.1 Annual Operating ReportA routine written annual report shall be submitted by the Reactor Director to the NRC, bySeptember 3 0th each year regarding operations for the preceding academic year (July 1st throughJune 30Oth). The report shall include, but not be limited to:a. a brief narrative summary of operating experience (including experiments performed) and atabulation showing the energy generated by the reactor (in megawatt hours), the amount ofpulse operation, and the number of hourns the reactor was critical; andb. the number of unplanned shutdowns and inadvertent scrams, including the reasons therefore,and corrective actions taken (if any) to reduce recurrence; andc. a tabulation of major preventive and corrective maintenance operations having safetysiguificance; andd. a tabulation of changes in the reactor facility and procedures, and tabulations of newexperiments, including a summary of the analyses leading to the conclusions that they areallowed without prior auth~orization by NRC and that 10 CFR § 50.59 was applicable; ande. a summary of the nature and amount of radioactive effluents released or discharged to theenvirons beyond the effective control of the facility as measured at or prior to the point of suchrelease or discharge. The summary shall include, to the extent practicable, an estimate ofindividual radionuclides present in the effluent. If the estimated average release after dilution ordiffusion is less than 25% of the concentration allowed, a statement to this effect is sufficient;andf. a summarized result of environmental surveys performed outside the facility; andg. a summary of radiation exposures received by facility personnel and visitors, where suchexposures are greater than 25% of that allowed.UCI Technical SpecificationsPae3Rvion211-8Page 38Revision 2015-12-18 6.7.2 Special ReportsIn addition to reports required according to Technical Specification 6.6, a report shall be made inwriting to the Document Control Desk, U.S. Nuclear Regulatory Commission, Washington, D.C.,20555-000 1 within 30 days of:a. permanent changes in facility organization involving Level 1 or Level 2 personnel; andb. significant changes in the transient or accident analyses as described in the SAR.6.8 RecordsIn addition to the requirements of applicable regulations, and in no way substituting therefore,records and logs shall be prepared and retained for periods as described here. Records may be in avariety of fonnats.6.8.1 Records to Be Retained for a Period of at Least 5 Years or for the Life of the Component InvolvedIf Less than 5 Years.a. Normaal reactor facility operation, but not including supporting documentation such aschecklists, log sheets, etc., which shall be retained for one year.b. Principal maintenance activities.c. Reportable occurrences.e. Surveillance activities required by the Technical Specifications.f. Reactor facility radiation and contamination surveys.g. Experiments performed with the reactor.h. Fuel inventories, receipts and shipments.i. Approved changes in operating procedures.j. ROC records of meetings and audit repolrtS.6.8.2 Records to Be Retained for at Least One Certification CycleRecords of retraining and requalification of all licensed operators shall be retained at all times eachindividual has duties as an operator or until his or her license is renewed.UCI Technical SpecificationsPae3Rvion25-28Page 39Revision 2015-12-18 6.8.3 Records to Be Retained for the Lifetime of the Reactor FacilityThe following records shall be retained for the lifetime of the facility. Applicable annual reportscontaining this information may be used as records.a. Reviews and reports pertaining to a violation of a safety limit, the limiting safety system setting,or a limiting condition for operation as described in Technical Specification 6.6.b. Gaseous and liquid radioactive effluents released to the environs.c. Results of off-site environmental monitoring surveys.d. Radiation exposures for all personnel that were monitored.e. Drawings of the reactor facility and safety related components.UCI Techanical SpecificationsPae4Rvion01--1Page 40Revision 2015-12-18 UCI TRIGA Reactor Reactivity RAMP Insertion Simulation.J. T. Wallick, Associate Reactor SupervisorG. E. Miller, Reactor SupervisorDecember 2015ConclusionsParameters of interest achieved the following values during the simulation:* Maximum reactor power was 1,118,874 watts.* Peak fuel temperature was 40.24 °C.dk*Highest core reactivity was 7.87 E-03 --* Shortest positive reactor period was 1.52 E-03 seconds.* Prompt criticality was never achieved.* Total energy released was 0.39 kWh.Overall, the transient behaved as expected given the conditions and accident analyzed. It provides fairlyconclusive evidence that a reactor designed for far harsher transients, such as rod ejections using compressed airachieving transient times on the order of milliseconds, can withstand an excessively conservative uncontrolledcontinuous rod withdrawal scenario.Methodology.The program used was developed in spreadsheet software. The methodology used in modeling the reactor'spredicted behavior during this transient is calculated in an iterative fashion as follows:1. Given input parameters for the simulation:a. Effective delayed neutron precursor decay constant (2ft is held constant at 0.1 sec-1.b. Temperature coefficient of reactivity (3ka) is -1.00 E-04 .7/acc. Effective delayed neutron fraction (f3eff) is 0.0079d. Prompt neutron generation lifetime (j*) is 9.85 F-OS secd /se. Reactivity addition rate of the 5) is 4.80 E-04 k/ecf. Initial reactor power is 1.5 watts.g. Initial reactor fuel temperature is 25.0 °C.h. Single element total heat capacity is 1088 c + 1.5
- Fuel Temp Wse~ci.Number of fuel elements in core is 80.j. The total fuel element heat capacity is 87040 + 120
- Fuel Temp w~secC Ck. A high power scram will occur one second after power reaches 110% power (275 kW) to allow forinstrumentation response time.I. The scram will insert all rods except the highest worth rod, which will stop outward motion.m.The total negative reactivity insertion of the scram will be 1.9039 E-02.7, which will be inserted over thecourse of one second.
- 2. Reactor parameters are calculated every iteration in the following manner:a. Time is incremented in 100 i~sec steps, equal to the prompt neutron lifetime in the University ofCalifornia, Irvine TRIGA Mk I Reactor as calculated by General Atomics.b. Power is calculated based on the previous power, difference in time, and previous reactor period.P= P *e~tc. Reactivity change of the control rods is added to the core.d. Energy generated is calculated based on reactor power and difference in time.E=P~te. Temperature change is calculated based on energy generated, total fuel element heat capacity, andprevious fuel temperature.Ef. Current temperature is calculated based on the temperature change and previous temperature.r= AT + rog. Reactivity change of the temperature coefficient of reactivity is calculated based on the temperaturechange and the temperature coefficient of reactivity.= AT
- ah. Current core reactivity is calculated based on the previous core reactivity, rod reactivity change, andreactivity change of the temperature coefficient of reactivity.6kcurr~ent = Skprevious + A~krods + ASkai.Period is calculated using the traditional in-hour equation and the current core reactivity.P '2eff*P-ij. Calculations repeat in this manner over the course of 30 seconds.k. Discontinuities arise as parame~ters switch negative to positive changes, prompt vs. delayed "switchover" and no allowance being made for "down power" effective delayed neutron precursor decayconstant.The attached graphs show:1. Power, Energy, Fuel Temperature, Reactivity and Period over the 30 second time of a RAMP.2. Power and period changes determined over the significant time period 16-17 seconds into the RAMP.3. An annotated plot of the simulation results over the "excursion" time period of the event from 15.0 to 20.0 seconds.4. A detail of power and period through the predicted scram at 17.42 seconds into the RAMP.
aRamp Analysis..-, owe[ (WI -l'otal (W-seC) -Temp (C) -Core React Period (seel)100000001000000-tc-13000001Q00010001005040302010-*020130-40-501030,0020.00 25.0010.00 15.005.00 Time in Seconds0.00Power Excursion-- -Po e IW) .... Period (sec)1000.0010000000100000010000010000100.0010.000100-c0a)0-i-ia)00,110000.0110016.0016.1016.20 16.30 16.40 16.50Time in Seconds16.6016.7016.80 16.90 SILiertICrossing the Point of Addilng Heat, wherethe Negativ Temnperature Coefficien ofR~eacti-vit begins taking effectirocessing tm',e afer power is detected to have exceeded110% of 250 kWIThe SCRAM finished reactivity insertionI iWhre the Negativ TemperatureCoetffcient of Reactivit has addedenough negative reactvt to trensitortthe core from suprrtc'to subcritcaHummg behavior indicative of not trantsitioningthe Effective Deiayed Neutron Precursor DecayConstant from 0.1 sec to 0.05 sec from Up-Power transen to Down-Power trnmsient_Calcujatior error.Scram Occurrs--Power (W) -,--- Period Isee)100(0000001000OOO00-10-20-30-40ci-50 C)-60-70-80-90-10017.7010000017.1017.2017.3017.40 17.50 17.60Time in Seconds UNIVERSITY OF CALIFORNIA, IRVINEBERKELEY *DAVIS *IRVINE. LOS ANGELES *RIVERSIDE *SAN DIEGO *SAN FRANCISCO I SANTA BARBARA *SANTA CRUZGeorge E. MillerSenior Lecturer EmeritusDepartment of Chemist.'y andSupervisor, Nuclear Reactor FacilityIRVINE, CA 92697-2025(949) 824-6649 or 824-6082FAX: (949) 824-8571email :gemiller@uci.eduDecember 22nd 2015US Nuclear Regulatory CommissionDocument Control DeskWashington DC 20555-0001Attention: Michael Balazik, Project ManagerRe: Docket 50-326. License R-1 16Re: ML14135A503
Dear Mr. Balazik,
Please find enclosed the response regarding the referenced technical RAIs(dated July 15, 2014). There are also two attachments to the response.I declare under penalty of perjury that the foregoing and the attached are true.and correct.Executed on December 22nd 2015Dr. George B. MillerSupervisorcc. Prof. A.J. Shaka, Director, UCI Nuclear Reactor FacilityJ. T. Wallick, Associate Reactor SupervisorG. L. Bosgraaf, UCI Radiation Safety Officer%p UCI RAI from July 15, 2014 response revised December 18th 2015RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION DATED July 15 2014REGARDING LICENSE RENEWALFOR THE UNIVERSITY OF CALIFORNIA. IRVINE NUCLEAR REACTOR FACILITYLICENSE NO. R-116DOCKET NO. 50-326The U. S. Nuclear Regulator'y Commission (NRC) is continuing its review of the University ofCalifornia, Irvine (UCI) application for the renewal of Facility Operating License No. R-1 16 for theUCI Nuclear Reactor Facility (UCINRF), dated October 18, 1999 (a redacted version of theapplication is available on the NRC's public Web site at www.nrc..iov under AgencywideDocuments Access and Management System (ADAMS) Accession No. ML0831 10112), assupplemented. The NRC staff re view of your safety analysis report (SAR) and proposed technicalspecifications (TSs) identified the following items which need additional clarification or information.Your responses are requested within 30 days from the date of this letter.This request for additional information (RAI) is, in part, based on a comparison of the UCINRF safetyanalysis report and the proposed TSs with NUREG-1537, "Guidance for Preparing and ReviewingApplications for the Licensing of Non-Power Reactors," dated February 1996 and the AmericanNuclear Standards Institute/American Nuclear Society (ANSI/ANS)-15. 1-200 7, "The Development ofTechnical Specifications for Research Reactors."1) In NUREG-1537, Part 1, Section 1.4, "Shared Facilities and Equipment," it states that"[c]omplete descriptions and any safety implications that result from sharing facilities orsystems should be evaluated in and referenced to the appropriate chapter of the SAR."a) The UCINRE RAI response dated August 1, 2011 (ADAMS Accession No. ML1 1255A073),Section 3.6, "Ventilation System, "pages 6-9, describes the UCINRF ventilation systemand Section 13.2, "Maximum Hypothetical Accident,"pages 12-19, expands thedescription by predicting doses during a maximum hypothetical accident. During normaloperations argon-41 is produced and released. The UCINRF ventilation system sharescomponents with the chemistry building exhaust system.i) Could airborne radioactive material being exhausted from the reactor room duringaccident or normal conditions be discharged into public spaces because of systemfailures? We believe no backflow into public spaces is possible.ii) If not, explain why not.As indicated in the diagrams presented earlier, the shared system does not integrate until the rooflevel of Rowland Hall. Three main fans there run continuously with only one required to providesufficient flow for normal building exhaust and prevent back-flow. Positive flow is thus assured fromall directions at the mixing point. The limiting conditions for reactor operation require that ventilationoperation meets flow criteria. Thus reactor operation would be halted or not begin if ventilationfailure occurred. Furthermore, the ventilation system operation is monitored continuously for flowand pressure (24/7) by UCI Central Plant. In the event of an alarm or failure condition, Central Plantcalls the facility. In the event of no response, investigation and repair proceeds and if access isneeded, the UCIPD will call the reactor call list for assistance. This is evidenced by the need for thePage 1 UCI RAI from July 15, 2014 response revised December 18th 2015facility staff to notify Central Plant if a door is opened for more than a couple of minutes, creating analarm condition in the pressure differential monitor at the facility and at Central Plant.iii) If this back flow is possible, what are potential doses to members of the public?None is anticipated, see above.iv) As airborne radioactive material is discharged through the ventilation system ductingduring accidents or normal operation, could members of the public adjacent to the ductingbe exposed to radiation?Public exposure is minimal from portions of the ducts leading to the roof. This is unchangedfrom the earlier design. Normal operations result in only minimal exposures within the facilityand even less to anyone in adjacent laboratories or areas adjacent to the ventilation ducts.TLD dosimeters placed at facility and ventilation systems perimeters confirm this byexhibiting little or no exposure above background (or even below!) within quarterlymeasurement limits. These have been reported in annual reports.In the revised SAR, Sections 13.2.5 and 13.2.7 exposures to building occupants in adjacentlaboratories were discussed. The same arguments pertain to those adjacent to theventilation ducts but with a lower source term. SAR 13.2.7 (November 2011) states:"There is no pathway for airborne activities to reach the adjacent areas of the building, so that thedeep dose rates established in 13.2.5 for individuals within the facility may be utilized. Suchindividuals will not be immersed in an infinite cloud of radioactive volatiles, so the facility may beconsidered as a single source. Further only gamma-ray exposures would be experienced since thewalls and windows are thick enough to absorb all beta radiation. There are no doors directlyopening from the facility to adjacent building areas, so no leakage to interior building areas isanticipated."The ventilation duct contains only a fraction of the source term so any exposure is muchreduced. In any accident release situation, the purge exhaust passes a small fraction of theeffluent gases only (there is a particulate filter) through the duct in passing occupied rooms.In such event the building will be evacuated ASAP so occupancy will be eliminated quickly.Areas nearby the ducts are mostly of low occupancy level (e.g., research labs andstockroom).v) If not, explain why not. If exposure to radioactive material is possible, what are thepotential doses to members of the public?See above. Again this is not new and the situation has existed since the original license.SAR Section 13.2.7 statesPage 2 UCl RAI from July 15, 2014 response revised December 18th 2015"Section 13.2.5 established a maximum dose rate to an individual within the facility of about 50mrem/hr. Since this is an immersion calculation, it is reasonable to assume a distance factorbefore estimating the dose rate through a wall. The closest a person can stand outside the facilityis in the adjacent hallway at the "window' wall. Assuming a whole body distance on each side ofthe wall, and including the wall thickness, it is reasonable to credit a distance factor of 5 feet.Making a further assumption that the source is an effective point source inside the facility, thiscould provide a distance factor of 52 or 25. Thus the external dose rate estimate is reduced by50/25 or to 2 mrem/hr. making no allowances for attenuation by air or wall materials, This is at theacceptable rate1 for public individuals over short time periods. In such an accident, the buildingwill be cleared within less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the accident so that extensive exposure at this rate(which would need to exceed 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to attain the 50 mrem annual limit2) would not be realized.Since there is no internal exposure, this exposure is the TEDE estimate. As it is so low, even ifthere are large uncertainties in the estimate, this appears to be entirely acceptable. Anyone at afurther distance, such as in nearby laboratories or offices, would receive less as a result ofadditional distance factors and absorption reductions. It is important to emphasize that thebuilding ventilation design is such that no mechanism exists for mixing of air between the reactorarea and adjacent rooms, so no internal exposure can result from the MHA except to persons inthe facility.The above estimates were presented for adjacent laboratories based on the reactor room(volume 6.6 E8 cm3) as a source. A passing duct is a more limited source. Assuming a ductof 1.5 feet diameter and 10 feet high passing a space, the source volume is now 5E5 cm3.Assuming the same radioactivity concentration as the reactor room with the sameintervening wall shielding and personnel proximity assumptions, exposures to personnel inrooms near the ducts would be (conservatively) only 1/1 000 of the 2 mr/h estimated for thelabs.b) The UCINRF RAI response dated January 27, 2010 (ADAMS Accession No.ML 100290365), Attachment C, SAR Chapter 5, "Reactor Coolant System," "pages 43-47, provides an updated SAR describing the water cooling system and waterpurification system. The UCI chilled water system supplies cooling water for the shellside of the heat exchanger.i) Discuss the radiological impact of a leak in the heat exchanger. Is leakage flowfrom the chilled water side into the primary side of the heat exchanger under alloperating conditions of both the primary system and chilled water system?Leakage flow within the heat exchanger is from secondary into the primary as establishedby pressure differentials under all conditions. The facility has recently installed pressuresensors in both primary and secondary systems to enable ongoing verification of thisclaim.ii) If not, what is the maximum radiological impact of primary coolant entering thechilled water system?S10CFR20. 1302(2)(ii)2 10CFR20. 1302(2)(ii)Page 3 UCI RAI from July 15, 2014 response revised December 18th 2015None is anticipated (see above)2) In NUREG-1537, Part 1, Section 4.3, "Reactor Tank or Pool, "it states that "the applicantshould assess the possibility of uncontrolled leakage of contaminated primary coolant andshould discuss preventive and protective features."a) The UCINRE RAI response dated July 14, 2010 (ADAMS Accession No. ML 101970039),Section 13.4, "Loss of Reactor Pool Water (Coolant), " pages 6-12, describes pool waterleakage. The response states that rain and irrigations of areas outside the reactorbuilding forced the drilling of wells adjacent to Rowland Hall. There seems to be adiscrepancy in two statements: (1) that automatic sump pumps are used to drain thesewells and (2) that samples are taken of the water being removed and are assayed bygamma-ray spectrometry. Clarify how the process exists for sampling radioactivecontaminants in the discharge of the automatic sump pump system prior to returningwater to the campus sewage system.Sampling is done on a scheduled (monthly) basis as a check on potential leakage, not priorto any release. Use of the pump would cease if reactor contaminated water were detected.As the reactor pool water is itself also checked monthly and found to be only very lowcontamination, the degree of contamination after soil filtering would be so low that modestrelease of water would be well below allowable sewer discharge levels.b) Previous annual reports identified that ground water has been observed in fuel elementstorage pits in the floor of the reactor room. Confirm whether or not these pits are usedto store fuel. If they are or will be used to store fuel, discuss actions that would be takento prevent water ingress prior to using the pits to store fuel and consider modifying TSsto reflect these actions, or explain why leakage into the storage pits would not makethem unsuitable for fuel element storage. Alternatively, consider incorporating a TS thatstates, 'Tuel storage shall be limited to in pool storage only."These pits were originally designated for either wet or dry storage in very low criticalityarrangements. Fuel stored in them will be secured in racks designed to limit reactivity aswell as to raise the elements above any potential ground water levels. Off the five pits, onlytwo have ever been subject to water incursion, and these would be used for fuel only as alast resort. In addition the pumping out of adjacent ground water will reduce the probabilityof future incursion. We do wish to be able continue use the pits as they provide additionalsecurity for new fuel, as well as options for used fuel.c) The UCINRF RAI response dated July 14, 2010, Section 13.4.1, "Mechanisms and Rateof Loss of Coolant," estimates that it would take 19.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to drain the pool.i) What is the maximum water loss that can occur without detection; that is, if the pool* started leaking after the reactor staff left for the night, what is the maximum amount ofpool water that could be lost without staff becoming aware?The pool alarm is set at just less than 12 inches below the tank rim. The normal waterlevel is maintained at about 6 inches below the tank rim. Each inch corresponds toapproximately 80 gallons of water. 6 x 80 = 480 gallons before an alarm would bereported to staff. This is less than 2% of the water (25,000).Page 4 UCI RAI from July 15, 2014 response revised December 18th 2015ii) How many gallons per week would be the minimum detectable leakage ratebased on UCINRF historical primary, makeup rates for normal operations?Normal loss rate based on history since we included a pool water level measurement gaugeis taken to be between 10 and 30 gallons per week with a mean value of 20 gallons/week.The value varies with operating schedules and temperature variations. Data for pool level isrecorded on each daily start-up check sheet, and rates of loss are calculated monthly. A rateof 1 inch drop in 1 week, or four times that mean value would be considered highly abnormaland cause for investigation. The pool water at this facility has a very low level of residual(long-lived) radioactivity, and ground-water in this area is not utilized in any way for publicconsumption, so that a slow leakage rate does not present a significant risk to the public.Requirements for checks and calibrations of the pool water level monitoring system havebeen incorporated in the revised Technical Specifications.It can be noted that a loss of 1 foot of water above the core results in a negligible increase indirect radiation level in any rooms over the reactor. SAR 13.3 shows that 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> or morewill elapse after an alarm condition before dose rates become of concern.3) In NUREG-1537, Part 1, Section 4.5.1, "Normal Operating Conditions," it requiresestablishment of a limiting core configuration. According to ANSI/ANS-I5. 1-200 7, thereference core should consider Xenon and other poisons in calculating a shutdown margin(SDM). The UCINRF proposed TS 3.1.2, "Shutdown Margin," states, '[t]he shutdown marginprovided by the control rods shall be greater than $0.55 .... " Given the reference corecondition established in RAl response dated June 7, 2011 (ADAMS Accession No.ML 111950452), the resulting SDM reactivity could be at least $0.30 less. Provide justificationfor this variance or revise proposed TS 3.1.2 to reflect a $0.85 SDM to support the inclusionof Xenon in the definition of reference core condition or consider incorporating the definitionReference Core Condition: The reference core condition is the condition of the core whenit is at ambient temperature (cold) and the reactivity worth of xenon is negligible.Reference Core Condition has been revised to eliminate the ($0.30) modifier.4) NUREG-1537, Part 1, Section 11.1.1.1, "Airborne Radiation Sources, " states that the SARshould discuss the production of airborne particles, aerosols, vapors, and nitrogen- 16 (N- 16)or other radionuclides. Describe the change or difference in radiation fields within theconfinement space with the N-16 diffuser ON versus with the N-16 diffuser OFF or state thetransport time of N- 16 with and without the diffuser in operation.The following radiation levels in mr/h have been measured within the facility with the reactorat 250 kilowatts steady state power level:Location With diffuser Without diffuserImmediately over pool 1.6 20Ceiling over pool 0.8 1.8At facility corridor wall 0.03 0.3Background --reactor OFF 0.03 0.03Page 5 UCI RAI from July 15, 2014 response revised December 18th 20155) NUREG-1 537, Part 1, Section 11.1.1.2, "Liquid Radiation Sources," states that the applicantshould discuss compliance with the applicable sections of Title 10 of the Code of FederalRegulations (10 CFR) Part 20, "Standards for Protection Against Radiation." There are twoplaces in the UCINRF proposed TSs that discuss liquid effluent, proposed TS 3.7. 2,"Effluents," Specification b. and proposed TS 4.7, "Radiation Monitoring Systems andEffluents," Specification e. The regulations in 10 CFR 20.2003 require that liquid effluentsdisposed of by release into sanitary sewerage be readily soluble. There is no mention in thePAl responses or Bases discussions that these propose TSs limit releases to readily solubleradionuclides. Confirm that these proposed TSs limit release to readily soluble radionuclides,or pro vide justification as to why not.Yes all references to liquids are to soluble radionuclides. Others are disposed as "drywaste". The appropriate TS sections have been revised to require demonstration ofso lub ility.6) In NUREG-l 53 7, Part 1,-Section 11.1.4, "Radiation Monitoring and Surveying, "itrequires a description of all radiation monitoring equipment.a) State the set points of the radiation area monitors and continuous air radiation monitor(CAM) listed in UCINRF proposed TS 3. 7.1, "Radiation-Monitoring Systems," and providethe bases for these set points.Set points for the radiation monitors and CAM areas follows:Instrument Alert Alarm Count rateRadiation Area Monitors (2) 2 mr/h 10 mr/h noneContinuous Air Particulate Monitor none *1 E-8 #Ci/ml 5000 cpmBases: RAM -2 mr/h is the normal standard for short -term exposures to the public.10 mr/h alarms at more serious but still safe for short term use. It alsofunctions in after-hours as an .alarm for inappropriate activity within thefacility.CAM -Based on instrument manufacturer recommendations. *DAC is frommanufacturer recommendation for 1-131. This is a factor of 2 lower than the 10 CFR 20Appendix B, Table 2 limit value of DAC for 1-131 for occupancy situations of 2E-8 1iCi/ml. Asthe ventilation system provides for dilution in normal mode of x 100, and emergency node ofx 1600, this provides an alarm level below the public release limit (Table 2) of 2E-10 ptCi/ml.b) The use of the acronym CAM is inconsistent. In the UCINRF proposed TS 3. 5.1,"Ventilation System, " and proposed TS 3.5.2, "Ventilation During EmergencySituations," it is defined as "continuous particulate air monitor" while proposed TS3.7.1, "Radiation Monitoring Systems," defines it as "continuous air radiation monitor."Provide consistent nomenclature.The acronym CAM has now been identified as Continuous Air Particulate Monitor in TS3.7.1., and utilized throughout the TS.Page 6 UCI RAI from July 15, 2014 response revised December 18th 20157) NUREG- 1537, Part 1, Section 13.1.2, "Insertion of Excess Reactivity," lists insertion-of-excess-reactivity events which includes a ramp insertion of reactivity by drive motion of the mostreactive control or shim rod, or ganged rods. Provide details of the ramp insertion analysis includingthe reactor trips in order to demonstrate the protection of the safety limit.The TRIGA core has been analyzed for a pulse excess reactivity insertion of up to $3.00within 100 milliseconds using the ATR and FTR control rods. A ramp rate of $30 per secondis the average in such an operation. Periods in the range of milliseconds are predicted andexperienced.Maximum fuel temperatures of 350 00 -well within the safety limit were projected and havebeen confirmed by measurements. Fuel temperatures in the pulse are also below theproposed scram setting (425 00). In the original safety analysis, Chapter 7, and therelicense submittal (Section 13.3), model analysis suggests a fuel temperature conditionfollowing a pulse insertion of $3.00 in an accident situation at a steady state power level of250 kw at a maximum of 570 00. (240 °C steady state fuel temperature + 330 00 additionalfrom the pulse). At UCI an accident of that magnitude is impossible as significant reactivityfrom the $3.00 license TS limit would be utilized in reaching 250 kilowatts, leaving only areduced amount for accidental insertion.While a slower ramp might be expected to produce higher fuel surface temperatures in afuel with smaller or slower negative temperature feedback, these are not of concern for ahomogeneous TRIGA fuel which has a safety limit based on fuel meat temperature.Wherever and whenever the fuel meat is hot the negative feedback will occur, reducingpower density rapidly at that location.However, in response to this request a slow drive ramp insertion analysis has beenconducted and the results are presented and discussed in an attachment to this document.The following RAIs are based on a review of the proposed UCINRE TSs, as provided in your RA!response dated March 1, 2012 (ADAMS Accession No. ML12087A215), and follow up RAIresponse dated September 11, 2012 (ADAMS Accession No. ML12256A897).8) 10 CFR Part 50.36(a)(1) states, in part, that the bases are not part of the TSs. Provide a TSstatement to support the requirement of 10 CFR 50.36 (a)(1), or justify why one is notrequired. An example of TS statements that have been approved by the NRC staff includethe following; "Included in this document are the Technical Specifications and the 'Bases' forthe Technical Specifications. These bases, which provide the technical support for theindividual Technical Specifications, are included for informational purposes only. They arenot part of the Technical Specifications, and they do not constitute limitations or requirementsto which the licensee must adhere."We have included the above statement verbatim on our introductory page.9) The UCINRF proposed TS 1.0O, "Definitions," "provides a definition for CHANNELCALIBRATION that is not consistent with the guidance found in NUREG-1537 andANSI/ANS-15. 1-2007. Revise the proposed TS definition of CHANNEL CALIBRATION tobe consistent with the guidance in NUREG- 1537 and ANSI-I 15.1, or provide a justificationfor the proposed definition.This has been revised.Page 7 UCI RAI from July 15, 2014 response revised December 18th 201510) The UCINRF proposed TS 1.0, "Definitions," contains a formatting inconsistency underCONTROL ROD, where the subparts are not spaces or indented, similar to other parts ofthe proposed TSs. Provide justification for formatting the subparts or revise forconsistency.This has been corrected.11) The UClNRF proposed TS 1.0, "Definitions, " CONTROL ROD contains an inconsistency inwhich subpart, "c. Adjustable Transient (A TR)," describes how control rod position is adjustedusing an electric motor drive, while subpart, "d. Fast Transient (FTR)," does not have anequivalent description of how control rod position is adjusted. The SAR describes the use ofpneumatic control for the FTR. Provide a justification for this difference or revise thedefinition of FTR.The descriptions have been revised to better parallel the other rods.12) The UCINRF proposed TS 1.0, "Definitions," INITIAL STARTUP states, "...be fore operationduring the day at steady-state power level above 1 kilowatt, or by pulsing the reactor."Clarification is required on the significance of 1 kilowatt. Explain the purpose for the 1kilowatt threshold or provide a basis describing the reason why 1 kilowatt is included in thisproposed TS definition. Include in your discussion the need to have a senior reactoroperator (SRO) present during the initial startup as required by 10 CFR 50.54(m)(1) ifpower does not reach 1 kilowatt.This has been revised to read:"INITIAL STARTUP is the first start-up from reactor secured condition on any day when thereactor is to be operated in order to verify core excess and other instrumentparameters."The need for a senior operator remains in accordance with the regulations.13) The UCINRF proposed TS 1.0, "Definitions, "REACTOR SECURED, subpart (2)(d) states, "Noexperiments are being moved or serviced that have a reactivity worth exceeding the maximumvalue allowed for a single experiment, or $1.00." Based on this definition, the exact reactivitylimit is not clear. Only the most conservative, or that, which is applicable to the UCI reactorshould constitute this definition (i.e., either $1.0O0 or the maximum value allowed for a singleexperiment). Provide justification for the proposed TS or revise the definition to identify only onecondition.The REACTOR SECURED definition has been revised accordingly.14) The UCINRF proposed TIS 1.0, "Definitions," SCRAM TIME states, "is the elapsed timebetween the initiation of a scram signal and a specified movement of a control or safetydevice." This definition is not clear as applied to the UCI reactor. As applicable to the UCIreactor, describe the specified movement (i. e., 85 percent of reactivity, all rods on the bottom,etc.) that constitutes this definition. For example, SCRAM TIME is the elapsed time betweenreaching a limiting safety system set point and the instant the slowest scrammable controlrod reaches its fully-inserted position or SCRAM TIME is the elapsed time from the initiationof a scram signal to the time the slowest scrammable control rod is fully inserted. Also definePage 8 UCI RAI from July 15, 2014 response revised December 18th 2015the control or safety device specific to the UCI reactor. Provide justification for the proposedTS or revise the definition to identify one specific movement of a control or safety device.The definition of SCRAM TIME has been revised accordingly.15) The UCINRF proposed TS 1.0, "Definitions," SUBSTANTIVE CHANGES may causeconfusion in implementing 10 CFR 50. 59, "Changes, tests, and experiments." Providejustification as to why this definition is required and is consistent with 10 CFR 50.59 ordelete the definition.This definition has been removed, based on discussions on February 5th 2015 with NRCpersonnel.16) The UCINRF proposed TS 1.0O, "Definitions," section does not include a definition forMOVEABLE EXPERIMENTS as endorsed in the ANSI/ANS-I5. 1-200 7. The term"moveable" can mean "unsecured," but not all "unsecured" experiments are "moveable."Provide a definition of moveable experiments, and include this definition in UCINRFproposed TS 3.8.1, "Reactivity Limits," or provide justification as to why this definition shouldnot be included.This has been included within the definition of EXPERIMENT.17) The UCINRF proposed TS 3.1.1, "Steady-state Operation, "Applicability section,contains a typographical error in which a period is missing. Clarify or correct thetypographical error. Also, review your proposed TSs for typographical or formattingerrors and propose corrections as needed.This has been attempted through use of an "external" reviewer.18) NUREG-1537, Appendix 14.1, Section 3.1.6, "Fuel Element Inspection Parameters,"Specification b., identifies limits on TRIGA fuel, including burnup. The UCINRF proposedTS 3.1.6 does not include a burnup limit. Provide a TS limit for fuel element burnup orprovide a justification as to why this limitation should not apply to the UCINRE reactor.A burn-up limit has been included as requested as TS 3.1.6.e. The basis is NUREG 1282.19) The UCINRF proposed TS 3.2.3, "Reactor Safety System," "Table 2. Minimum ReactorSafety Channels, "requires clarification as identified below.a) Second column, first row titled, "Function and trip level maximum setting," may bemisinterpreted. Provide clarity for this table by adjusting the title to read, "Function and triplevel settings," and labeling corresponding set points using universal symbols <, >, >, <orprovide justification for the use of the proposed labeling system.These changes have been incorporated as requested.b) Second column, third row lists, "Scram-425°C (IFE)" but does not indicate the range ofacceptability. Identify if this should read "Scram <_ 425°C (IFE)," or provide justification for proposedlabeling system.See above.Page 9 UCI RAI from July 15, 2014 response revised December 18th 2015c) Second column, fourth row listing, "Scram-I110% of 250kw" should identify "Scram-<110% of 250kw (275kw(t))," or provide justification for proposed labeling system.See above.d) Second column, eighth row listing, "Scram-if motion of 3% g (0. 03g) is exceeded"should identify, "Scram-if motion of < 3% g (0. 03g)," or provide justification forproposed labeling system.See above.20) The UCINRF proposed TS 3. 2. 3, "Reactor Safety System," "Table 3. Minimum Interlocks,"first column, fifth row lists the interlock, "REG, SHIM, A TR Control Rod Drives" and thesecond column, fifth row lists the function, "Prevent movement of REG and SHIM rods inpulse mode." Confirm that there is no interlock for the A TR control rod drive that prevents itsmovement in pulse mode or make the appropriate corrections to the table?A revision has been made to clarify the interlocks present in the pulse mode.21) The UCINRF proposed TS 3.3.1, "Pool Water Level," Specification b., requiresclarification for the following:a) The use of the term ". ..shall operate 24/7..." is colloquial and may be misinterpreted.Provide clarity to this requirement by stating, ".....shall operate continuously. .." or providea justification for the use of the proposed language.This revision has been made as requested.b) The condition states, "Visual checking of water level shall be substituted every 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />sduring periods when the alarm is found to be inoperable and no substitute level devicehas been implemented." How long can visual checking every 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> exist before thepool water level alarm is restored to operation? How long can a substitute level devicebe implemented? Justify your proposed time periods.Since observation is decidedly painful, the restoration will be important. Depending on theavailability of spares and delivery thereof, we expect the restoration to be completed with 7working days at the outside, and hopefully within 1-2 days.22) The UCINRF proposed TS 3. 8. 2., "Materials," Specification b., states, "Explosive materialsshall not be irradiated in quantities greater than 25 milligrams of TNT equlivalent. Explosivematerials in lesser quantities may be..." Clarification is required because a legal loop holeexists in this statement that does not specify the requirements for exactly 25 milligrams ofTNT. The TS should identify, ".... Explosive materials in the amount of 25 milligrams orlesser quantities may be..." Pro vide justification for the proposed language, or modify theproposed TS to conform to current NRC guidance.This change has been made as requested.23) The UCINRF proposed TS 3.8.2., "Materials," Specification b., requires that the pressure ofaccidental detonation of explosive material has been calculated and/or experimentallyPage 10 UCI RAI from July 15, 2014 response revised December 18th 2015determined to be less than half the design pressure of the container the explosive isirradiated in. Provide calculations of the design of an example container to demonstrate thecapability to meet the requirements of TS 3.8.2., Specification b.This would be a requirement of the experimenter proposing such a device, and would verifythis by use of outside consultants who have expertise in this arena.Calculators of thickness of sealed containers to meet ASME design pressures can be foundon-line at such sites as http://www.checalc.com/calc/vesselThick.htmlAs to explosive analysis, for combustibles, NRC 1805 provides a calculator. For others thetype and design of the containment are crucial, and DOT guidance is helpful.A useful general reference for explosives seems to be http://fas.orgq/man/dod-101 /navy/docs/es3 10/chemistry/chemistry. htmThere is minor disagreement in the literature as to the proper equation to be used forexplosion of TNT. This depends on oxygen availability. Using the conservative value of 11mol of gas per mol (227.13g) of TNT, we find that 23 mg of TNT (1/10,000 mol) would yield,on explosion, 11 x 1/10,000 x 24.6 L of gas at NTP = 0.027 L = 27 mL, assuming ideal gasconditions. Confined to a volume of 10 mL (for the purpose of analysis), this would resultconservatively, in a pressure of 27/10 x I atm or 2.7 atm. Confining a pressure of >= 5.4atm would be required to meet the specification. However this ignores any heating effect.TNT releases 2175 J/g, so 23 mg will release only 50 J. Assuming a steel capsule of mass100~g and 0.5 J/g-K for specific heat, this would yield a temperature rise of only 1 K. Sucheffect is minimal. Even a 100°C rise would only raise the calculated pressure from 2.7 to 3.7atm, for a required strength of 7.4 atm.24) The UCINRE proposed TS 3.8. 2, "Materials," Basis section references a letter datedDecember 2, 2011, which describes the dose limits in terms of total effective dose equivalent (TEDE)and thyroid individual organ doses. Some confusion exists in that the dose limits should only be interms of TEDE for this licensing action. Consider removing the individual organ dose references inthe bases, or justify how this limit is applicable to establishing the TS limit.These revisions have been made as requested.25) The UCINRE proposed TS 3.8.3, "Failure or Malfunction," requires clarification. The wordingof the specification is not standard and results in some confusion. Provide justification forthe proposed language, or modify the proposed TS to conform to current NUREG-i 537guidance. An example TS reads as follows:TS 3.8.3 Experiment Failure and MalfunctionsSpecificationsWhere the possibility exists that the failure of an experiment under (a) normaloperating conditions of the experiment or the reactor (b) credible accident conditionsin the reactor or (c) possible accident conditions in the experiment could releasePage 11 UCI RAI from July 15, 2014 response revised December 18th 2015radioactive gases or aerosols to the reactor room or the unrestricted area, thequantity and type of material in the experiment shall be limited in activity such thatexposures of the reactor personnel to the gaseous activity or radioactive aerosols inthe reactor room or control room will not exceed the occupational dose limits inIOCFR 20.1201. Additionally, exposures to members of the public to these releasesin the unrestricted areas will not exceed the dose limits in 1OCFR 20. 1301, assumingthat:a. 100% of the gases or aerosols escape from the experiment;b. If the effluent from an experimental facility exhausts through a holdup tank, which closesautomatically on high radiation levels, the assumption shall be used that 10% of the gaseous activityor aerosols produced will escape;c. If the effluent from an experimental facility exhausts throulgh a filter installation designed forgreater than 99% efficiency for 0.3 micron particles, the assumption shall be used that 10% of theaerosols produced escape;d. For materials whose boiling point is above 55°C and where vapors formed by boiling this materialcould escape only through an undisturbed column of water above the core, the assumption shall beused that 10% of these vapors escape; ande. If an experiment container fails and releases material which could damage the reactor fuel orstructure by corrosion or other means, physical inspection shall be performed to determine theconsequences and the need for corrective action.These revisions have been made as requested.26) The UCINRF proposed TS 4.2, "Reactor Control and Safety Systems," Specification e., states,"On each day that pulse mode operation of the reactor is planned, a functional performance check ofthe transient (pulse) rod system..." Functional performance check is not a defined term. Is this achannel check? If so, use the properly defined term, or define and justify the term functionalperformance check.TS 4,2 has been rewritten to utilize the term "OPERABLE" which has been defined.27) The UCINRF proposed TS 4.2, Reactor Control and Safety Systems," Specification h., states,"A channel check of the pool water temperature measuring channel..." Confirm that achannel check is appropriate as this surveillance. The NUREG-1537 guidance identifies acalibration of measuring channels. Explain the use of a channel check versus a calibrationor modify the proposed TS to conform with NRC guidance.An annual calibration requirement for the pool water temperature measuring channel hasbeen included in TS.4.2, replacing the daily "check". In addition, the requirement foran annual calibration of the pool water level measuring channel, has been movedfrom 4.3 to 4.2 to better cluster the "annual calibration" requirements. The pooltemperature "alarm" is advisory, as it alerts operators to a procedural requirementnot directly connected to safety, and provides no automatic scram, or outsideagency notifications.28) The UCINRF proposed TS 4.3, "Reactor Pool Water," Specification b., is not included in the listPage 12 UCI RAI from July 15, 2014 response revised December 18th 2015of surveillances that cannot be deferred, found in TS 4.0, "General," Specification a., whichstates "Surveillance requirements may be deferred during prolonged (periods greater than 1month) reactor shutdown (except Technical Specifications 4. 3. a, 4. 3. c, 4.3. e, 4.3. f and4.3.g)." Why is TS 4.3, Specification b. allowed to be deferred for long term shutdown?Provide justification for this deferral, or modify the proposed TS to include TS 4.3,Specification b. on this list of exceptions.This has been revised as requested and to acknowledge other changes made in numberingitems.29) The UCINRF proposed TS 6.1.2, "Responsibilites," "Figure 1. UCI Reactor Organization Chart,"requires clarification. The solid-line and dashed-line relationships are not identified in aleger or within TS description. Confirm and indicate what these connections mean.This has been included as requested.30) The UCINRF proposed TS 6.1.3, "Staffing, "item a. 1., states, "The minimum staffing when thereactor is not secured shall include: 1. a licensed operator with direct access to the reactorcontrols." Does this statement mean a licensed operator must be present in the controlroom? If so, confirm and modify the proposed TS to reflect that a licensed operator must bepresent in the control room, or provide justification as to why not.This has been revised as requested.31) The UCINRF proposed TS 6.1.3, "Staffing," item d., states, "...Restart following any unplannedor unscheduled shutdown, or significant power reduction." The use of ". .. or significant powerreduction, "is unclear and may cause confusion in implementing the proposed TS. Modify theproposed TS to remove this phrase, define and justify what significant means, or providejustification why this terminology cannot be misunderstood.Wording has been changed to clarify this concern.32) The UCINRF proposed TS 6.2.4, "ROC Audit function," is missing two conditionsprescribed by ANSI/ANS-15. 1-200 7. Modify the proposed TS to include the belowsections, or provide justification to deviate from guidance.e. The audit shall be performed by one or more persons appointed by the ROC. At least one of theauditors shall be familiar with reactor operations. No person directly responsible for any portion ofthe operation of the facility shall audit that operation; andf. Any deficiencies that may affect reactor safety shall be immediately reported to ROC Chair, Level1, and a written full report of the audit shall be submitted to the ROC within three months of the audit.These revisions have been made as requested.33) The UCINRF proposed TS 6.3, "Radiation Safety," states, "As delineated in section6.1.2.e, the UCI... The program shall use the guidelines of ANSI/ANS-15.11-2004."The NRC has accepted a "should" statement.This revision has been made.Page 13 UCI RAI from July 15, 2014 response revised December 18th 201534) The proposed UCINRF TS 6.4, "Operating Procedures," states, "Written procedures, reviewedand approved by the ROC, shall be in effect and implemented..." The NUREG-1537guidance recommends the facility director be included for review and approval (e.g., "Writtenprocedure, reviewed and approved by the ROC and facility director, shall be in effect andimplemented..."). Provide justification for this deviance from guidance, or modify theproposed TS to conform with the guidance.This revision has been made as requested.35) The UCINRF proposed TS 6.4, "Operating Procedures," final paragraph states, "Substantivechanges to procedures.. .but shall be reported to the RSO within 30 days." The definition ofsubstantive changes may cause confusion and misinterpretation about what needs to beconsidered under 10 CFR 50.59. Provide justification why this cannot be misinterpreted ormodify the proposed TS to meet the requirements of 10 CFR 50.59.This has been revised as requested.36) The UCINRF proposed TS 6.5, "Experimental Review and Approval," item b., states,"Substantive changes to existing experiments or classes shall be made only after review bythe ROC and RSO or their designees. Minor changes that do not significantly... (SRO)."The definition of substantive changes may cause confusion and misinterpretation aboutwhat needs to be considered under 10 CFR 50.59. Provide justification for the use of thisterm, or modify the proposed TS to remove the section on substantive changes and minorchanges to read, "Changes to existing experiments or classes shall be made only afterreview by the ROC and RSO or the RSO designee."This has been revised as requested.37) The UCINRF proposed TS 6.6.1, "Actions To Be Taken in Case of a Safety Limit Violation,"items b. and c. are inconsistent. In TS 6. 6. 1, item b. there is a requirement to report theevent immediately while TS 6.6.1, item c. specifies that this event shall be reported within24 hours. Provide justification for the non-congruency, or modify the proposed TS to beconsistent.TS 6.6 has been revised by moving material from 6.7.2 into this section. We believe thisclarifies the action and reporting requirements to accord with 10OCFR 50.36 as requested38) The UCINRF proposed TS 6.7.1, "Annual Operating Report, "states, ".....each 12-month period forst thoperations for the preceding year's activities between July 1 through June 30 ."In addition,specify, when the report is actually due (e.g., "An annual report shall be created andsubmitted, by the Facility Director, to the Document Control Desk, U.S. NRC, Washington,thDC, 20555, by September 30 of each year').Revisions have been made as requested.39) The UCINRF proposed TS 6. 7.1, "Annual Operating Report," item d., differs slightly from theNUREG-1 537 guidance, which states that a tabulation of changes in the reactor facility andprocedures, and tabulation of new tests or experiments, including a summary of the analyses leadingto the conclusions that they are allowed without prior authorization by the NRC and that 10 CFR50. 59 was applicable. The proposed TS is not as precise. Provide an explanation as to why thisPage 14 UCI RAI from July 15, 2014 response revised December 18th 2015deviation is justifiable or revise the proposed TS accordingly.This has been revised as requested.40) The UCINRE proposed TS 6.8.3, "Records to be retained for the lifetime of the reactor facility," ismissing a condition prescribed by ANSI/ANS-15. 1-200 7. Modify the proposed TS to includethe below section or provide justification to deviate from guidance.1) Reviews and reports pertaining to a violation of the safety limit, the limiting safetysystem setting, or a limiting condition of operation.This has been revised as requested.41) Provide updated proposed TSs, including the revisions requested in e-mail datedSeptember 11, 2012 (ADAMS Accession No. ML12256A897).These revisions have been incorporated as requested.ADDITIONAL REVISIONS.Based on discussions with NRC personnel on February 5th 2015, we arerequesting removal of former TS 3.3.4 Pool Water pH as an un-neededspecification for an open pool reactor, with adequate monitoring of waterconductivity and temperature. This has been done in the latest TS version.References to this specification in TS 4.0 and 4.3 have also been removed.Further editorial revisions to the Technical Specifications have been made as aresult of exchanges with NRC licensing personnel in the period February 2015through November 2015. An updated version of the TS, dated December 18th,2015 is submitted herewith as an attachment.Page 15 APPENDIX AToFaci-ity License R-1 :50-326Technical Specificationsfor theU. C. IrvineTRIGA Mark I Nuclear ReactorDecember t18, 2015 TABLE OF CONTENTSDEFINITIONS1SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS2.1 Safety Limit -Fuel Element Temperature 52.2 Limiting Safety System Setting 5LIMITING CONDITIONS FOR OPERATION3.1 Reactor Core Parameters 63.2 Reactor Control and Safety Systems 93.3 Coolant Systems 123.4 (Blank) 143-.5. Ventilation Systems 143.6 (Blank) 153.7 Radiation Monitoring Systems and Effluents 163.8 Limitations on Experiments 173.9 (Blank) 19SURVEILLANCE REQUIREMENTS4.0 General 204.1 Reactor Core Parameters 214.2 Reactor Control and Safety System 224.3 Reactor Pool Water 234.4 (Blank) 234.5 Ventilation Systems 244.6 (Blank) 244.7 Radiation Monitoring Equipment and Effluents 254.8 Experiment Limits 25DESIGN FEATURES5.1 Site and Facility Description 265.2 Reactor Coolant System 265.3 Reactor Core and Fuel 275.4 Fuel Storage 285.5 Ventilation System 29ADMINISTRATIVE CONTROLS6.1 Organization and Str'ucture 306.2 Review and Audit 336.3 Radiation Safety 356.4 Operating Procedures 356.5 Experiment Review and Approval 356.6 Required Actions 366.7 Reports 386.8 Records 39Note: Included in thifs document are the Technical Specifications and the "bases" for the TechnicalSpecifications. These bases, which provide the technical support for the individual TechnicalSpecifications, are included for infornational puroposes only. They are not part of the TechnicalSpecifications, and they do not constitute limitations or requirements to which the licensee must adhere.
- 1. DEFINITIONSThe following frequently used termas are defined to aid in the uniform interpretation of thesespecifications.AUDIT is an examination of records, logs, procedures, or other documents to ascertain that appropriatespecifications, and guidelines are being followed in practice. An audit report is written to detailfindings and make recommendations.CHANNEL is a combination of sensor, lines, amplifier and output device which are connected for thepurtpose of measuring the value of a parameter.CHANNEL CALIBRATION is an adjustment of the channel such that its output corresponds withacceptable accuracy to knaown values of the parameter that the channel measures. Calibration shallencompass the entire channel, including equipment actuation, alarm or trip, and shall be deemed toinclude a channel test.CHANNEL CHECK is a qualitative verification of acceptable performance by observation of channelbehavior. Thfis verification, where possible, shall include comparison of the channel with otherindependent channels or systems measuring the same variable.CHANNEL TEST is an introduction of a signal into the channel to verify that it is operable.CLOSE-PACKED ARRAY is a fuel loading pattern in which the fuel elements are arranged in the coreby filling the inner rings first.CONFINEMENT is the en:closur'e of the overall facility designed to limit release of effluents betweenthe enclosure and the external environment thr-ough controlled or defined pathways.dONTROL ROD is a device fabricated from neutron absorbing material or fuel or both which is usedto establish neutron flux changes and to compensate for routine reactivity changes. A control rodmay be coupled to its drive unfit allowing it to performn a safety function when the coupling isdisengaged. Types of control rods shall include:a. Regu~lating (RiEG): a rod having electric motor drive and scram capabilities. Its position may bevaried manually or by an electronic controller. It shall have a fueled-follower section.b. Shim (SHIM): a rod having electric motor drive and scram capabilities. Its position shall bevaried manually. It shall have a fueled-follower section.c. Adjustable Transient (ATR): a rod with scram capabilities that can be rapidly ejected from thereactor core using a pneumatic drive to produce a pulse. It has an electric motor drive to adjustits position or length of travel. It shall have a void follower.d. Fast Transient (FTR): a rod with scram capabilities that can be rapidly ejected from the reactorcore using a pneumatic drive to produce a pulse. Only fully UP or DOWN positions areavailable. It shall have a void follower.;I Teclmical Snecifications Page 1 Revision 2015-12-18UC..... j.
CORE CONFIGURATION is a particular arrangement of fuel, control rods, graphite reflectorelements, and experimental facilities inserted within the core grid plates.CORE LATTICE POSITION is defined by a particular hole in the top grid plate of the core designed tohold a standard fuel element. It is specified by a letter, indicating the specific ring in the grid plateand a number indicating a particular. position within that ring.EXCESS REACTIVITY is that amount of reactivity that would exist if all control rods were moved tothe maximum reactive condition from the point where the reactor is exactly critical (keff =1) atreference core conditions.EXPERIMENT is any operation, hardware or target (excluding devices such as detectors or foils)which is designed to investigate non-routine reactor characteristics or which is intended forirradiation within an irradiation facility. Hardware rigidly secured to a core or shield structure so asto be part of their design to carry out experiments is not normally considered an experiment.Specific experiments shall include:a. SECURED EXPERIMENT is any experiment or component of an experiment that is held inl astationary position relative to the reactor by mechanical means. The restraining forces must besubstantially greater than those to which the experiment might be subjected by hydraulic,pneumatic, buoyant, or other forces which are normal to the operating environment of theexperiment, or by forces which can arise as a result of credible malfunctions.b. UNSECURED EXPERIMENT is any experiment or component of an experiment that does notmeet the definition of a secured experiment.c. MOVEABLE EXPERIMENT is any experiment where it is intended that the entire experimentmay be moved inl or near the core or into or out of the core while the reactor is operating.FUEL ELEMENT is a single TRIGA fuel rod.INITIAL STARTUP is the first start-up from reactor secured condition on any day when the reactor isto be operated in order to verify core excess and other instrument parameters.INSTRUMENTED FUEL ELEMENT is an element in which one or more thermocouples areembedded for the purpose of measuring fuel temlperature dur'ing reactor operation.IRRADIATION FACILITIES are pneumatic transfer systems, central tube, rotary specimlen rack, andthe in-core facilities (including single element positions, three-element positions, and the sevenelement position) and any other facilities in the tank designed to provide locations for neutron orgamma ray exposure of materials.MEASURED VALUE is the value of a parameter as it appears on the output of a channel.OPERABLE means a component or system is capable of perfonning its intended function.OPERATING means a component or system is performing its intended function.UCI Technical Specifications Pg eiin21-21Page 2Revision 2015-12-18 OPERATIONAL CORE is a core configuration that meets all license requirements, includingTechnical Specifications.PULSE MODE is any operation of the reactor with the mode switch in the PULSE position thatsatisfies all instrumaentation and license requirements, including technical specifications, for pulseoperation of the reactor.REACTIVITY WORTH OF AN EXPERIMENT is the value of the reactivity change that results fromthe experiment being inserted into or removed from its intended position.REACTOR FACILITY is the physical area defined by rooms B64, B64A, B54, B54A, and B54B in theservice level of Rowland Hall on the campus of the University of California Irvine.REACTOR OPERATING is any time at which the reactor is not secured or shutdown.REACTOR SAFETY SYSTEMS are those systems, including their associated input channels that aredesigned to initiate automatic reactor scram or to provide information for the manual initiation of ascram for thle purpose of returning the reactor to a shutdown condition.REACTOR SECURED is when:Either(1) there is insufficient moderator available in the reactor to attain criticality or thaere is insuffilcientfissile material present in the reactor to attain criticality under optimum available conditions ofmoderation and reflection;Or(2) the reactor is shutdown and the following conditions exist:a. all neutron-absorbing control rods are fully inserted; andb. the console key switch is in the OFF position and the key is removed from the console lock;andc. no work is in progress involving fuel, core structure, installed control rods, or control roddrives unless they are physically decoupled fr'om the control rods; andd. no experiments are being moved or serviced that have a reactivity worth exceeding $1.00.REACTOR SHUTDOWN is when the reactor is subcritical by at least $1.00 in the reference corecondition with the reactivity worth of all installed experiments included.REFERENCE CORE CONDITION is when the core is at ambient temperature (cold) and the reactivityworth of xenon is zero.REVIEW means a qualitative examination of audits, reports and records, procedures or otherdocuments from which appropriate recommendations for improvements are made.UCI Technical Specifications Pg eiin21-21Page 3Revision 2015-12-18 RING is one of six concentr-ic bands in the grid plate locations surrounding the central opening of thecore. The rings are designated by the letters B through G, with the letter B used to designate theinnermost band.SAFETY CHANNEL is a measuring channel in the reactor safety system.SCRAM TIME is the elapsed time between the initiation of a scram signal and all control rods reachingtheir bottom limit.SEVEN ELEMENT POSITION is a hexagonal section which can be removed fr'om the upper grid platefor insertion of specimens up to 4.4 in. in diameter after relocation of all six B-ring elements andremoval of the central tube irradiation facility.SHALL, SHOULD and MVAY. The word shall is used to denote a requirement; the word should is usedto denote a recommendation; and the word may is used to denote permission, neither a requirementnor a recommendation.SHUTDOWN MARGIN refers to the minimum shutdown reactivity necessary to provide confidencethat the reactor can be made subcritical by means of the control and safety systems starting fromany permissible operating condition and with the most reactive rod in its most reactive position, andwill remain subcritical without further operator action.STEADY-STATE MODE is whenever the reactor is operating with the mode selector switch in theSTEADY-STATE position.SURVEILLANCE INTERVALS that are permitted are established as follows:a. Quinquennial -interval not to exceed 6 yearsb. Biennial -interval not to exceed 2-1/2 yearsc. Annual -interval not to exceed 15 monthsd. Semi-annual -interval not to exceed 7-1/2 monthse. Quarterly -interval not to exceed 4 monthsf. Monthly -interval not to exceed 6 weeksg. Daily -each day when the reactor is to be operated or before any operation extending more thanone dayTHREE ELEMENT POSITION is one of two triangular-shaped removable sections of the upper gridplate, one encompassing core lattice positions D5, E6 and E7 and the other D14, E18 and E!9,designed to accommodate experiments. When fuel elements are placed in these locations, a specialfixture shall be inserted to provide lateral support.UCI Technical Specifications Pg eiin21-21Page 4Revision 2015-12-18
- 2. SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS2.1 Safety Limit -Fuel Element TemperatureApplicability. This specification applies to the fuel element temperature.Objective. The objective is to define the maximum fuel element temperature that can be permittedwith confidence that no fuel element cladding damage will result.Specification(s). The temperature in a stainless steel clad, high hydride fuel element shall notexceed 1000°C under any condition of operation.Basi__s. The important paramaeter for a TRIGA reactor is the fuel element temperature, since it canbe measured. The loss in the integrity of the fuel element cladding could arise from an excessivebuild-up of pressure in the fuel element. The safety limit for high hydride TRIGA fuel is based ondata including the experimental evidence obtained during high performance reactor tests of thisfuel. These data indicate that the stress will remain below the ultimate stress provided the fueltemperature does not exceed 11 50°C and the fuel cladding is water cooled.The safety limit for the stainless steel clad, high hydride (ZrHll.7) fuel element is based on NRCaccepted limits in NUR{EG 1537 section 14.1 which also indicates that the stress in the cladding dueto the hydrogen pressure from the dissociation of the zirconfium hydride will remain below the yieldstress provided the temperature of the fuel does not exceed 11 50°C and the fuel cladding is watercooled.2.2 Limiting Safety System SettingsApplicability. This specification applies to the scram setting for the fuel element temperature*channel.Objective. The objective is to prevent the safety limit fr'om being reached.Specification(s). For a core composed entirely of stainless steel clad, high hydride fuel elements, alimiting safety system setting applies to the standard instrumented fuel element (IPFE) which shallbe located in the B- or C-ring as indicated in the following table:Location Limiting Safety System SettingCore lattice positions B2, B4, C5, C6, or C7 < 425°CBasi___s. Fuel temperature is measured by a fuel element designed for thfis purpose (IFE) in a systemdesigned to initiate a reactor scram if a limit is exceeded. The limiting setting is conservativelychosen for five possible core positions that calculations in the SAIR, as supplemented by letter datedJune 7th 2011, indicate are similar in expressing the highest power density and thus the highest fueltemperatures attained in the core. In addition, the maximum recorded temperatures for the UCIreactor IFE for the period since 1969 are 250°C at steady state power operation, and 350°C forpulse operation. The LSSS is extremely conservative compared to the fuel temperature safety limit.UCT Technical Specifications Pg eiin21-21Page 5Revision 2015-12-18
- 3. LIMITING COINDITIONS FOR OPERATION3.1 Reactor Core Parameters3.1.1 Steady-state OperationApplicability. This specification applies to the energy generated in the reactor durfing steady-stateoperation.Objective. The objective is to assure that the fuel temperature safety limit is not exceeded.Specification(s). The reactor power level in steady-state operation shall not exceed 250 kilowatts.Basis. Calculations have been performed which show that for operation at 250 kW, the maximumfuel temperature is 253°C and the minimum DNB ratio is greater than 7.27. In addition, experienceat other TRIGA reactors and thermal and hydraulic calculations for this core (SAR, assupplemented by letter dated June 7m 2011) indicates that these power levels can be safely usedwith natural convection cooling of the fuel elements in the designed core configuration.3.1.2 Shutdown MarginApplicability. These specifications apply to reactivity condition of the reactor and the reactivityworths of the control rods and experiments. They apply for all modes of operation.Objective. The objective is to assure that the reactor can be shut down at all times.Specification(s). The reactor shall not be operated unless the shutdown margin provided by thecontrol rods is greater than $0.55 with:a. irradiation facilities and experiments in place and the total worth of all unsecured experimentsin their most reactive state; andb. the most reactive control rod fully withdrawn; andc. the reactor in the reference core condition.Basis. The value of the shutdown margin and limits on experiments assure that the reactor can beshut down from any operating condition even if the most reactive control rod should remain in thefully-withdrawn position.UCI Technical Specifications Pg eiin21-21Page 6Revision 2015-12-18 3.1.3 Core Excess ReactivityApplicability. These specifications apply to reactivity condition of the reactor and the reactivityworth of the control rods and experiments. They apply for all modes of operation.Objective. 'The objective is to assure that the reactor can be shut down at all times and to assure thatthe fuel temperature safety limit shall not be exceeded.Specification(s). The maximum available core excess reactivity based on the reference corecondition shall not exceed $3.00.Basis. An excess reactivity limit of $3.00 allows for flexibility in operating the reactor in steadystate mode while limiting the reactivity addition for pulse operation. Computations presented in theSAR (Chapter 13.3) establish that a sudden insertion of $3.00 results in a fuel temperature ofapproximately 350°C, well below the established safety limit for this fuel (Technical Specification2.1). Such calculations are conservcative, being based on a purely adiabatic model. Thespecifications assure that no insertion of reactivity above this value shall be possible, even undernon-normaal operating conditions.3.1.4 Pulse Mode OperationApplicability. These specifications apply to fuel temperatures generated in the reactor as a result ofa pulse inser~tion of reactivity.Objective. The objective is to assure that the fuel temperature safety limit shall not be exceeded.Specification(s). The reactor shall not be operated in the pulse mode unless in addition to therequirements of Technical Specification 3.1.2 and 3.1.3:a. the steady-state power level of the reactor is less than 1 kilowatt; andb. the total reactivity worth of the two transient control rods (ATR + FTR) is measured to notexceed $3.00.Basis. The fuel temperature rise during a pulse transient has been calculated conservatively using anadiabatic model. Pulse reactivity insertion with the power level below 1 kW assures that the startingtemperature for a pulse rise is below 25°C. The temperature rise from a $3.00 reactivity insertionpulse is thus calculated to bring the peak fuel temperature to less than 400°C, well below the safetylimit and well below the recommended rnaxinmum fuel temperature limit of 830°C.(GA Report, A16613, 1981.)3.1.5 This section intentionally left blank.UCI Teclmical Specifications Pg eiin21-21Page 7Revision 2015-12-18 3.1.6 Fuel Element Inspection ParametersApplicability. The specifications apply to all fuel elements, including fuel follower control rods.Objective. The objective is to maintain integrity of fuel element cladding._Specification(s). The reactor shall not be operated with any fuel element identified to show damage.An exception is made for operation up to a power level at which a leak becomes detectable solely inorder to be able to identify the leaking element. A fuel element shall be identified as showingdamage and be removed from core if:a. the transverse bend exceeds 1/16" inches (0.0625 in) over the length of the element; orb. the growth in length over original measurements exceeds 1/8fli inch (0.125 in); orc. a cladding defect is suspected by a finding of release of any fission products; ord. visual inspection identifies unusual pitting, bulging, or corrosion; ore. burn-up of the element is estimated to exceed 50%.Basis. These criteria are established by NUREG 1537 section 14.1. NUREG 1282 describesexperiments indicating TRIGA fuel can safely be used to at least 50% burn-up.3.1.7 Core ConfiguirationApplicability. This specification applies to the configuration of fuel and in-core experiments.Objective. The objective is to assure that provisions are made to restrict the arrangement of fuelelements and experiments so as to provide assurance that excessive power densities will not beproduced.Specification(s).a. The core shall be an a-rangement of TRIGA 8.5/20 Low Enriched Uranium (LEU) fuel.b. The core fuel elements shall include at least one 8.5/20 LEU fuel element with embeddedthennocouples to enable monitoring of fuel element temperature.c. The core fuel elements shall be kept in a close-packed array except for control rods, single- orthr-ee-element or" seven-element positions occupied by in-core experiments, irradiation facilities(including transfer system tennini), and a central dry tube.d. The reflector, excluding experiments and experim~ental facilities, shall be graphite or acombination of graphite and water.e. A control rod shall not be manually removed fr'om the core unless calculations show that thecore will be subcritical by >: $0.55 excluding the worth of the rod being worked on and theworth of the most reactive remaining control rod.UCI Technical Specifications Page 8 Revision 2015-12-18 Basis.a. TRIGA cores have been in use for years and their characteristics are well documented. LEUcores including 8.5/20 fuel have also been operated successfully at many facilities. In addition,analysis indicates that the low uraniumn loading, LEU 8.5/20 core will safely satisfy alloperational requirements. See chapters 4 and 13 of the SAR as supplemented by letter datedJune 7th 2011.b. The IFE provides a signal to the fuel temperature safety channel.c. Inner core lattice positions contain experiments or" an experimental facility to prevent accidentalfuel additions to the reactor core. Vacancies are permitted only on the periphery of the core,where reactivity worths are lower.d. Graphite and water reflectors are used for neutron economy and the enhancement ofexperimental facility radiation char'acteristics.e. Manual manipulation of control rods wilt be allowed only when a single manipulation cannotresult in inadvertent criticality.3.2 Reactor Control and Safety Syrstems3.2.1 Control RodsApplicability. This specification applies to the function of control rods.Objective. To assure control rods are operable and that prompt reactor shut down following a scramis accomplished.Specification(s). The reactor shall not be operated unless the REG, SHIM and ATR control rods areoperable. Control rods shall not be considered operable if:a. dam~age or deterioration is apparent to any rod or drive assembly that could affect operation; orb. the scram time for any control rod is greater than 1 second for 90% reactivity insertion; orc. the total reactivity worth of the two transient control rods (ATR and FTR) is greater than $3.00.Basis. Experience has shown that rod movement is assured inl the absence of damage and that scramatimes of less than 1 second are more than adequate to reduce reactivity and fuel temperaturesrapidly to assure safety in view of known transient behavior of TRIGA reactors. The FTR rod isnot vital to safe scram as a result of its low worth value (less than $1.00) and can remaln in core ifnot needed for pulsing. The total worth of the two transient rods is limited so as to restrict the pulsesize.UCI Technical Specifications Pg eiin21-21Page 9Revision 2015-12-18 3.2.2 Reactor Measuring ChannelsApplicability. This specification applies to the information which shall be available to the reactoroperator during reactor operation.Objective. To specify that minimum number of measuring channels that shall be available to theoperator to assulre safe operation of the reactor.Specification(s). The reactor shall not be operated in the specified mode unless the measuringchannels described in Table 1 are operable.Table 1. Minimum Measuring ChannelsMeasuring Channel Operating ModeSteady-state PulseFuel Element Temperature 1 1Linear Power Level 1ILog Power Level 1-Power Level (%) 1 1 (peak power)nvt circuit (integrated pulse -1energy)Note 1. Any single power level channael may be inoperable while the reactor is operating solelyfor the purpose of calibration and/or channel tests or checks on that channel.Note 2. Any single power level channel that is not required for safety scram purpose by TS3.2.3 and ceases to be operable during reactor operation shall be returned to operatingcondition within 5 minutes or the reactor shall be shut downa. For channels required by TS3.2.3 the reactor shall be shut down immediately if the channel becomes inoperable.Basis. The fuel temperature displayed at the control console gives continuous information on theparameter which has a specified safety limit. The power level monitors assure that measurements ofthe reactor power level are adequately covered at both low and high power ranges in appropriatemodes. Notes 1 and 2 allow for necessary tests for resolving of problems or recalibration whilemaintaining sufficient informnation for safe operation.UCI Technical SpecificationsPae1Rvion25--8Page 10Revision 2015-12-18 3.2.3 Reactor Safety SystemApplicability. This specification applies to the reactor safety system channels.Objective. To specify the mininmum number of reactor safety system channels that shall be operablein order to assure that the fuel temperature safety limit is not exceeded.Specification(s). The reactor shall not be operated unless the safety system channels described inTable 2 and the interlocks described in Table 3 are operable in the appropriate operating modes.Table 2. Minimum Reactor Safety ChannelsSafety Channel Function and trip level setting Operating ModeSteady-state PulseFuel Element Scram -_<425°C (lFE) I 1TemperatureReactor Power level Scram -<110% of 250 kw~t) 2 -(< 275 kw)Loss of HV and/or Scram 1 1signal on any requiredchannel _____Manual Bar Scram 1 1Preset Timer Scram pulse rods < 15 seconds -1after pulseSeismic Switch Scram -if motion of >3% g 1 1(< 0.03g)Pool Water Manual Scram 1 1Temperature if> 25°C_____________Table 3. Minimum InterlocksOperating ModeInterlock Function Steady- PulsestateWide Range Power Prevent control rod withdrawal when power level is < 1 1 -Level Channe (Log) x 10o-7 % of full power ___REG, SHIM, ATR Prevent application of air to fast transient rod when all 1-Control Rod Drives other rods are not fully insertedREQ, SH-IM, ATR Prevent simultaneous withdrawal of more than one rod 1REG, SHIM, ATR Prevent mnovement of REG and SHIM rods and ATR -1Control Rod Drives drive in pulse modeATR Cylinder Drive Prevent application of air to adjustable transient rod 1-_________________unless cylinder is fully downWide Range Linear Prevent ATR or FTR withdrawal unless power level _< 1 -. 1Power Channel kilowattUCI Technical SpecificationsPae1Rvion25-28Page 11Revision 2015-12-18 Basis.S crams. The fuel temperature scram provides the protection to assure that if a condition resultsin which the safety limit is approached, an immediate shutdown will occur to keep the fueltemperature well below. The justification basis is described in Technical Specification 2.2. Thepower level scrams are provided as added protection against abnormally high fuel temperature.The manual scram allows the operator to shut down the system if an unsafe or abnormalcondition occurs. A high voltage scram on each channel assures that detector response isoperating at all times. The seismic switch will scram the reactor if earth movement in anydimension exceeds 3% g (0.03g) in case the operator is prevented from operating the manualscram at the time. This level corresponds to movement noticeable by most persons, but (by MMscale) results in no damage to structures. The preset timer" scram provides pulse "clipping" toreduce energy production at the tail of a pulse. The pooi water level temperature limit is thevalue used for the thennal hydraulic analysis input coolant temperature in the SAR assupplemented by letter dated June 7th 2011, and also is designed to reduce stress between thealuminum tank liner and its concrete surround.Interlocks. The interlock to prevent startup of the reactor with less than 10o-7 % power indicationassures that indication of neutron multiplication is present as reactivity is inserted. Theinterlocks on control rod drives are provided to prevent withdrawal of more than one control rodat a time avoiding multiple simultaneous reactivity insertions by operators. The interlockswhich prevent the firing of the transient rods in the steady-state mode or if the power level isgreater than 1 kilowatt prevent inadvertent pulses or pulsing when fuel temperature is too high.3.3 Coolant Systems3.3.1 Pool Water LevelApplicability. These specifications apply to the water level in the reactor pool at all times.Objective. To assure there is sufficient water in the reactor pool to provide cooling and shielding forradiation fr'om the core, and to check for potential pool leakage.Specification(s).a. The reactor shall not be operated unless the pool water level is at least 24 feet above the tankfloor (1 foot below the tank edge).b. An audible alarm, with reporting to a monitored remote location if not locally silenced by anoperator, shall operate continuously to alert personnel if the water level in the reactor pool fallsbelow the above limit. Visual checking of water level shall be substituted every 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> duringperiods when the alarmn is found to be inoperable and no substitute level device has beenimplemented.c. Records shall be main~tained of the date, time and quantity of all make up water added to thepool.Basis. Facility design calculations and subsequent measurements show that these water levels aresufficient to reduce full power operational radiation levels to acceptable levels within the facilityand in any occupied areas above or surrounding the reactor. This is also true for shut down levels.The alarm will notify appropriate responders well before any increase in radiation levels to theUCI Technical Specifications Page 12 Revision 2015-12-18 surroundings occurs. The alarm and the operational make up water records will, ifit occursunusually frequently, alert operators to the possibility that pooi leakage might be occurring. Thepool level is normally maintained at approximately 10 inches below the tank edge. Thus the alarmlevel is at 2 inches below the normal level corresponding to evaporation or leakage of only 160gallons (640 liters, or 0.6% of total pool water). The maximumr water leak rate calculated (SAR)indicates that the water would be at a sufficient level over the core for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to preventunsafe release of radiation to the surrounding areas. Procedures call for a substitute pool level alarmsystem to be implemented during any extended period of failure.3.3.2 Pool Water TemperatureApplicability. This specification applies to the water temperature in the reactor pool at all times.Objective. To assure the water in the reactor pool stays within limits that provide sufficient coolingof the fuel and that minimizes stresses to the tank and reactor components.Specification(s). The pooi water temperature shall be maintained between 17°C and 25°CBasis. These temperature limits are easily maintained using the available cooling system and guardagainst temperatu-es that might produce undue stresses on tank components or water purificationsystems. The thermal hydraulic analysis was based on an inlet core temperature of 25°C.3.3.3 Pool Water ConductivityApplicability. This specification applies to the conductivity of water in the reactor pool at all times.Objective. To assure the water in the reactor pool is mainltained at high purity to minimize potentialcorrosion of reactor components.Specification(s). The pool water conductivity level shall be maintained less than 3 micromhos/cm.Make-up water shall meet this specification before being added to the pool.Basis. Experience at other reactor facilities indicates that maintaining the conductivity within 5micromhos/cm is adequate to provide acceptable control of corrosion (NUJREG 1537). Anadditional mar-gin of assur~ance is provided by this lower specification. Degradation fr-om thisconductivity also aids in assessing possible leakage of treated secondary coolant water into theprimary coolant water.3.3.4 Pool Water RadioactivityApplicability. This specification applies to the radioactivity of water in the reactor pool at all times.Objective. To assure the water in the reactor pool is maintained at high purity.Specification(s). The average pool water radioactivity level shall be maintained within limits forsewer disposal as established by 10 CFR § 20, Appendix B, Table 3 for radionuclides with half-lives longer than 24 hourns.Basis. Maintenanlce at this level will assure that any disposal of pool water, either planned orinadvertent, will be withfin appropriate and significant radioactivity limits. It also will provideverification of absence of fission product leakage.UCI Teclmical SpecificationsPage 13Revision 2015-12-18 3.4 This section intentionally left blank3.5 Ventilation Systems3.5.1 Ventilation System.Applicability. This specification applies to the operability and operation of the facility ventilationsystem.Objective. To assure that the ventilation system is operable to mitigate the consequences of possiblereleases of radioactive materials resulting from reactor operation.Specification(s).a. The reactor shall not be operated unless the ventilation system is operating as indicated by:i. a minimum of 0.10 inches of water negative pressure difference between the reactorroom and the control room and between the reactor room and the air outside thebuilding; andii. a minimum total exhaust flow rate from the reactor room area of 3600 cubic feet perminute (cfln) is present.Note: The ventilation system may be inoperable for periods of time not to exceed two hours toallow repair, maintenance or testing of the system. During such an exception, no pulses shall befired..b. The reactor shall not be operated unless it is verified that the ventilation system goes into theemergency mode upon manual actuation or a signal of high radiation activity from a ContinuousAir Particulate Monitor (CAM) measuring air from above the pool as described in TechnicalSpecification 3.5.2. Verification shall be by observing the emergency flow rate is at least 240cubic feet per minute (cfmn), the absence of regular exhaust flow, and the pressure differentialreading between the reactor room and the outside is negative.c. Radioactive by-product materials shall not be handled in the facility unless the ventilationsystem is operating as described in Technical Specifications 3.5.1 .a. and 3.5.1 .b. above.Basis. Through a combination of inflow danlipers and outflow exhaust, facility design establishesand exceeds these pressure differentials and flows. The differential pressure assists in confinementof radioactive materials. The SARl establishes that norm~al operation effectively dilutes 41At levelsbelow 10 CFR § 20 limits and as detailed in facility annual reports. An automatic emergency modewith a small filtered purge exhaust is provided to limit release of radioactivity to the environment.Operation of the normal system adequately dilutes the 41A released during experimentaloperations. The two hour exemption should not diminish the effectiveness of the CAM in detectingany release of radioactivity. The requirement not to pulse while the ventilation system isunmdergoing repair reduces the likelihood of fuel element failure during such times. The ventilationsystem should be required for by-product handling activities to reduce potential impact of release ofvolatile chemicals.UCI Technical SpecificationsPae1Rviin25-28Page 14Revision 2015-12-I 8 3.5.2 Ventilation During Emergency SituationsApplicability. This specification applies to the ventilation system provided for emergencysituations.Objective. To assure there is confinement of radioactive releases by closing of normal ventilationand establishing emergency ventilation.Specification(s). A signal of high radiation activity alarm from a Continuous Air ParticulateMonitor (CAM) measuring air fr'om above the pool or manual operation from the control room shallcarry out the following functions:a. close off inflow air by closing dampers; andb. close off outflow ai" by closing dampers in exhaust ducts and removing power from relevantexhaust fans and fume hood; andc. remove power from pneumatic transfer system so it can no longer operate to tr'ansfer air throughany core region; andd. open outflow damper in a small "purge" exhaust duct system equipped with a IIEPA filter.Basis. These actions will result in confinement of any released radioactive materials, whilebeginning to purge contaminated air through a high grade filter. Experience has shown that fissionproduct release from fuel elements is most rapidly detected by a CAM operating in this manner.The SAR establishes that the emergency purge system will, in the event of a radioactive gas release,be effective in limiting release to the environament and also providing personnel with sufficient timeto evacuate before experiencing serious exposure. It is shown in Chapter 13 of the SAR, assupplemented by letter dated Dec 2nd 2011, that operation of the emergency exhaust system reducesoff-site doses to below 10 CFR § 20 limits in the event of a TRIGA fuel element failure. It isshown also that, if the reactor were to be operating at full steady-state power, fuel element failurewill not occur even if all the reactor tank water were to be lost immediately.3.6 This section intentionally left blankUCI Technical SpecificationsPae1Rvion21128Page 15Revision 2015-12-18 3.7 Radiation Monitoring Systems and Effluents3.7.1 Radiation Monitoring SystemsApplicability. This specification applies to monitoring of radiation levels.Objective. To assure information is available to provide assurance of radiological safety ofpersonnel at the facility, and of the absence of excessive releases beyond the facility.Specification(s).a. The reactor shall not be operated unless the following minimum radiation monitoringinstruments are operating:Minimum NumberOperatingRadiation Area Monitors (RAM) 2Continuous Air Particulate Monitor (CAM) 1b. Environmental monitoring dosimeter packs, exchanged at least quarterly, shall be in place at theprimary exhausts of the facility at all times, except when undergoing exchange. Additionalpacks shall be located in adjacent buildings, and in a more remote control location forcomparison.Basis. These instruments through warnings and alarms will provide adequate notification ofabnormal levels that could result in exposures or uncontrolled releases. The CAM provides a signalto actuate the ventilation emergency mode (Technical Specifications 3.5.1 .b, 3.5.2, and 5.5.e). TheCAM alarm set point is based on limiting air concentrations to below the DAC level for 1- 131 aslisted in Appendix B of 10 CFR § 20. The environmental dosimeters provide information that canbe used to track long term trends that might need attention.UCI Technical SpecificationsPae1Rvion25--8Page 16Revision 2015-12-18 3.7.2 EffluentsApplicability. This specification applies to the release rate of 41Ar gas and liquid effluents.Objective. To assure that concentration of 41Ar in air and any liquid effluents released to accessibleunrestricted areas shall be below the applicable limits of 10 CFR § 20.Specification(s).a. The annual average concentration of 41Ar released to the environment shall notexceed 1 x 10-8 microcuries per milliliter (giCi/mL).b. The quantity of radioactivity in liquid effluents released from the facility to the sewer systemshall be soluble and not exceed the limits of 10 CFR § 20, Appendix B, Table 3.Basis. ,a. The analysis presented in Chapter 13.2 of the SAR, as supplemented by letter dated Oct 3rd2011, concludes that the building exhaust and room ventilation system normally provides adilution factor of 100 at the point of external release for airborne concentrations in the facilityarea. Under extremely unlikely conditions involving system failures, it provides a dilutionfactor of at least 30, reducing the facility room concentration predicted from calculations andmeasurements as a result of normal reactor operation to be well below 10 CFR § 20 AppendixB, Table 2 requirements (1 x 10-8 pgCi/mL). This will be further assured since releases arepermitted to be averaged over a one year period. The exposure risk to the public is reducedsince the discharge plume is at a high level above the roof. Annual reports from this facilityhave shown that levels released have been well below this value.b. This specification establishes assurance that any release of radioactive materials contained inliquids released to the sewer system does not exceed the limits required by regulations.3.8 Limitations on Experiments3.8.1 Reactivity LimitsApplicability. This specification applies to experiments placed in the reactor and its experimnentalfacilities.Objective. The objective is to prevent damage to the reactor or excessive release of radioactivematerials in the event of an experiment failure._Specification(s). The reactor shall not be operated unless the following conditions governingreactivity worths exist:a. the reactivity worth of any unsecured or moveable experiment shall not exceed $1.00; andb. the reactivity worth of an individual experiment shall not exceed $3.00; andc. the sum of the absolute values of reactivity worths of all experiments shall not exceed $3.00.UCI Technical SpecificationsPae1Rvion21--8Page17Revision 2015-12-18 Basis. The limit on an unsecured experiment is to prevent an inadvertent pulse, and to maintainshutdown margin limitations. The insertion of $3.00 pulses has been analyzed as a safe operatingcondition for this reactor (SAR Chapter 13). Limitation of experiments such that a pulse larger thanthis value could not occur is prudent and stays well within safe limits. The limitations also assurethat achievement of margins for shutdown is assured.3.8.2 MaterialsApplicability. This specification applies to experiments placed in the reactor and its experimentalfacilities.Objective. To prevent damage to the reactor and to minimize excessive release of radioactivematerials in the event of an experlinent failure.Specification(s). The reactor shall not be operated unless the following conditions governingexperiments exist:a. fueled experiments shall be limited such that the total inventory of iodine isotopes 131 through135 in the experiment is not greater than 0.02 curies, and the strontium-90 invento1ry does notexceed 1 microcurie; andb. explosive materials in the amount of 25 milligrams of TNT (or equivalent) or lesser quantitiesmay be irradiated provided that the pressure produced upon accidental detonation of theexplosive has been calculated and/or experimentally determined to be less than halft the designpressure of the container; andc. experiments containing col'osive materials shall be doubly encapsulated. The failure of anencapsulation of material that could damage the reactor shall result in removal of the sampleand physical inspection of potentially damaged components.Basis. In specification a, an assumption is made that complete release of volatile material (iodine)from a fueled experiment is possible. It is shown in the SAR, Chapter 13, as supplemented by letterdated Dec. 2fld 2011, that a release of 0.02 curies of iodine activity would result in a maximum doseto a person in the facility who evacuates in 5 minutes of 0.4 rem, or less than 1/75th of the 50 remlimit in 10 CFR § 20. An individual directly exposed in the exhaust in an unrestricted area underhighfly unlikely conditions would receive (TEDE) less than 0.54 mrem. The maximumn projectedTEDE to a person in the nearest living area will be less than 0.22 mrem, far" less than the 100 mremlimit in 10 CFR § 20. These computations are extremely conservative as they assume no pool wateris present. In the event of a failed experiment the pool water would be present to absorb/dissolvehalogens and reduce the airborne concentrations.Specifications b and c reduce the likelihood of damage to reactor components resulting fromexperiment failure and use information from NRC Reg. Guide 2.2.UCI Technical Specifications Pg 8Rvso 0 -21Page 18Revision 2015-12-18 3.8.3 Failures or MalfunctionsApplicability. This specification applies to experiments placed in the reactor and its experimentalfacilities.Objective. To prevent damage to the reactor as well as to minimize release of radioactive materialsin the event of an experimaent failure.Specification(s).a. Where the possibility exists that the failure of an experiment under (a) normal operatingconditions of the experiment or the reactor, (b) credible accident conditions in the reactor, or (c)possible accident conditions in the experiment could release radioactive gases or aerosols to thereactor room or anly unrestricted area, the quantity and type of material in the experiment shallbe limited in activity such that exposures of the reactor personne to the gaseous activity orradioactive aerosols in the reactor room or control room will not exceed the occupational doselimits in 10 CFR § 20.1201. Additionally, exposures to members of the public to these releasesin the unrestricted area will not exceed the dose limaits in 10 CFR § 20.1301. hn calculatingpotential consequences, one or more of the following assumptions shall be made, as applicable:i. 100% of the gases or aerosols escape from the experiment.ii. If the effluent from an experimental facility exhausts through a hold-up tank, whichcloses automatically on high radiation levels, 10% of the gaseous activity or aerosolswill escape.iii. If the effluent from an experimental facility exhausts through a filter installationdesigned for greater than 99% efficiency for 0.3 micron particles, 10% of the aerosolswill escape.iv. For materials whose boiling point is above 550C and where vapors formed by boilingthis material are radioactive and could escape only through an undisturbed column ofwater above the core, 10% of these vapors escape.b. If an experiment container fails and releases material which could damage reactor fuel orstructure by corrosion or other means, physical inspection shall be performed to determine theconsequences and the need for corrective action before further operation of the reactor.Basis.a. This specification is intended to assist experiment review and design in meeting the goals of 10CFR § 20 by reducing the likelihood of excessive facility personnel or public exposure by gasesor aerosols as a result of experiment failure.b. This specification is intended to assure that any facility damage as a result of experimnent failureis appropriately corrected before operations are resumed.3.9 This section intentionally left blank.UCI Technical SpecificationsPae1Rvion25--8Page 19Revision 2015-12-18
- 4. SURVEILLANCE REQUIREMENTS4.0 GeneralApplicability. Thfis specification applies to surveillance requirements of any system related toreactor safety.Objective. To assure the proper operation of any system related to reactor safety.Specification(s).a. Surveillance requirements may be deferred during prolonged (periods greater than 1 month)reactor shutdown (except Technical Specifications 4.2.j, 4.3.a, 4.3.b, 4.3.d, and 4.3.e). However,they shall be completed prior to reactor start-up unless reactor operation is required forperformance of the surveillance. Such surveillance shall be performed as soon as practicableafter reactor start-up. Scheduled surveillance which cannot be performed with the reactoroperating may be deferred until a planned reactor shutdown.b. All replacements, modifications, and changes to systems having a safety related functionincluding the ventilation system, the core and its associated support structure, the pool, the poolcoolant system, the control rod drive mechanisms, and the reactor safety system shall meet orexceed the requirements of the original system or component. A safety system shall not beconsidered operable until it has been properly tested to meet specifications.Basis. Changes or maintenance can affect reactor operation parameters. This specification willassure that safety systems function according to established criteria before any reactor operation.UCI Technical SpecificationsPae2Rvion05-21Page 20Revision 2015-12-18 4.1 Reactor Core ParametersApplicability. This specification applies to the surveillance requirements for reactor coreparameters.Objective. To verify that the reactor does not exceed authorized limits for power, shutdown margin,core excess reactivity, specifications for fuel element condition, and verification of total reactivityworth of each control rod.Specification(s).a. The total reactivity worth of each control rod shall be measured annually or" following anysignificant change (>$0.25) in core configuration.b. The core excess reactivity shall be determined using control rod position data prior to eachday's operation, or prior to each operation extending more than one day, or following anysignificant change (>$0.25) in core configuration.c. The shutdown margin shall be determined at each day's startup, or following any significantchange (>$ 0.25) in core configuration.d. All core fuel elements shall be inspected (unader water) to assure compliance with TechnicalSpecifications 3.1 .6.a through 3.1 .6.d quinquennially, but at intervals separated by not morethan 500 pulses of magnitude greater than $1.00 of inserted reactivity. Fuel follower controlrods shall be visually inspected and measured for bend at the same time interval. Suchsurveillance shall also be performed for elements in the B and C rings in the event that there isindication that fuel temperatures greater than the limiting safety system setting on temperaturemay have been exceeded.e. Prior to resumption of routine pulse mode operations following a period of no pulse modeoperations for more than 1 year, a test of pulsing performance with a pulse insertion of $1.50shall be performed to assure pulsing power and fuel temperature response is as predicted fromprior experience.f. Full core, fuel and control rod surveillance shall be conducted before further reactor operation ifsignificant changes are observed in any measured parameters such that it could be concludedthat fuel element or control rod integrity has been compromised or fuel element or control roddamage has occurred.Basis. Experience has shown that the identified frequencies are more than adequate to ensureperformmance and operability for this reactor. The value of significant change is measureable andwill assure sufficient shutdown margin even taldng into account decay of poison.For fuel elements, the most severe stresses induced in the fuel elements result from pulse operationof the reactor, during which differential expansion between the fuel and the cladding occurs and thepressure of the gases within the elements increases shar~ply. The sm-weillance interval is selectedbased on the past history of more frequent, uneventful, inspections for over 40 years at this facilityand experience at other TRIGA~ facilities with similar power levels, fuel type, and operationalmodes. It is also designed to reduce thle possibilities of mechanical failur-es as a result of handlingelements, and to minimize potential radiation exposures to personnel.UCI Technical SpecificationsPae2Rvion05121Page 21Revision 2015-12-18 4.2 Reactor Control and Safety SystemsApplicability. This specification applies to the surveillance requirements for the reactor control andsafety systems.Objective. The objective is~to verify performance and operability ofthose systems and componentswhich are directly related to reactor safety.Specification(s).a. A channel calibration shall be made of the power level monitoring channels by the calorimetricmethod annually or immediately following any significant (>$O.25) core configuration change.b. Control rod scram times for all four control rods shall be determined annually or for individualrods immediately following any maintenance work involving that control rod or drivemechanism that may have affected rod scram performance.c. All control rods shall be visually inspected for deterioration quinquennially.d. The transient (pulse) rod pneumatic cylinders and the associated air supply systems shall beinspected annually, and cleaned and lubricated if necessary.e. On each day that pulse mode operation of the reactor is planned, the transient (pulse) rod systemshall be verified to be operable before pulse operation is initiated.f. A channel test of each of the reactor safety system channels and interlocks in TechnicalSpecification 3.2 Tables 2 and 3, except for the pool water temperatture measuring channel, shall*be performed prior to each day's operation .or pr:ior to each operation extending more than oneday.g. A channel check of the functions of the seismic switch shall be performled annually or as soonas possible after an observed seismic event or one reported to be of sufficient magnitude to tripthe switch.h. A calibration of the pool water temperatture measuring channel shall be performed annually toinclude verification of the alarm set point.i. A calibration of the fuel temperature measuring channel shall be performed annually.j. A calibration of the pool water level measuring chmannel shall be performed annually to includeverification of the alarm set point.Basis. The control rods are inspected and scram times checked to assure safe scram operations. Thesurveillance intervals for those and the channel surveillances are selected based on the past historyfor over 40 years at this facility and are adequate to correct for long term dr-ifts and other instrumentproblems. The manufacturer of the seismic switch makces no recommendation for recalibration andbelieves the accelerometer settings remain effective for the life of the device. The channel test ofthe seismic switch involves simulation of a seismic event by tapping the switch to initiate a reactorscram, establishing operational functionality.UCI Technical SpecificationsPae2Rvion21--8Page 22Revision 2015-12-18 4.3 Reactor Pool WaterApplicability. This specification applies to the surveillance requirements for the reactor pool water.Objective. The objective is to assure that the reactor pool water level channel is operable, that alarmsettings are verified and alarm reporting is functional. In addition, that the water level and purity isbeing maintained within acceptable limits.Specification(s).a. A channel check of the pool water level measuring channel shall be performed monthly toinclude channel verification of the alarm reporting system.b. The pool water conductivity shall be measured at the end of each operating day or at shutdownfor a period of operation extending more than one day. For periods of extended shutdown theconductivity measurement shall be made monthly.c. The pool water temperature shall be monitored each hour during reactor operation.d. The pool water radioactivity shall be mneasured quarterly.e. The pool water loss rate shall be evaluated on each occasion when make-up water is added tothe pool. Any unusual increase in loss rate shall be investigated as a possible pool leak beforeany further reactor operation.Basis. These verifications will assure that a continued warning system for an unexpected loss ofpool water is maintained, and that any perturbation of pool water quality noted then allows forcorrective action to minimize corrosion, or build-up of radioactivity in the water. The frequentcheck on conductivity monitors possible leakage into the pooi from the secondary water system.Temperature measurrements will assure the pool water is maaintained within operating limits.Radioactivity measurements will enable assessments of long term impacts of pool leaks and/orfission product leaks from a fuel element.4.4 This section intentionally left blank.UCI Technical SpecificationsPae2Rvion01--8Page 23Revision 2015-12-18 4.5 Ventilation SystemsApplicability. This specification applies to the surveillance requirements for the reactor roomventilation system.Objective. To verify~ performance is adequate to provide for normal and emergency modeventilation for the facility to control and confine releases of airborne radioactive materials.Specification(s).a. A channel check of the existence of negative air pressure between the reactor room and thecontrol room, and the reactor room and the outside air in both normal and emergency modesshall be performed daily.b. A channel check of the exhaust flow rates from the reactor area in both normal and emergencymodes shall be performed daily, to demonstr'ate that the ventilation system is operable in bothnormal and emergency modes by observation of flow rates, and valve/damper action.c. A channel test of the function of the Continuous Air Particulate Monitor (CAM) alarm and thecontrol room manual switch to properly set the ventilation system into emergency mode shall beperformed daily.Basis. Based on experience, these surveillances will assure that the ventilation system is functioningas specified. (Technical Specification 3.5).4.6 This section intentionally left blank.UCI Teclmical SpecificationsPae2Rvion01-28Page 24Revision 2015-12-18 4.7 Radiation Monitoring System and EffluentsApplicability. This specification applies to the surveillance requirements for the radiationmonitoring instrumentation required by Technical Specification 3.7.1l.a and the effluent releasesspecified by Technical Specification 3.7.2.Objective. The objective is to assure that the radiation monitoring system is operating properly andto verify the appropriate alarm settings and amounts of radioactivity in effluent releases.Specification(s).a. A channel test of the area radiation monitoring systems required by Technical Specification3.7.1.a shall be perfon~ned monthly. This shall include verification of the alarm set points.b. A channel check of the Continuous Air Particulate Monitor (CAM) required by TechnicalSpecification 3.7.1 .a shall be performed daily. This shall include verification of the alann setpoint.c. A channel calibration of the radiation monitoring systems required by Technical Specification3.7.1 .a shall be performed annually.d. The environmental monitoring dosimeters required by Technical Specification 3.7.1 .b includingthose monitoring exhaust effluents, shall be evaluated quarterly.e. Any liquid effluents to be released to the sewer system from the facility shall be verified tocontain only soluble materials and analyzed for radioactive content prior to release.Basis. Surveillance of the equipment and effluents will assure that sufficient protection againstexcessive radiation or release of excessive radioactive materials is available. Past experience hasshown that these practices and frequencies are adequate to assure proper operation.4.8 Experiment LimitsApplicability. This specification applies to the surveillance requirements for experiments placed inthe reactor and its experimental facilities.Objective. The objective is to assure that experiments to be conducted do not damage the reactor orrelease excessive amounts of radioactive materials as a result of experiment failnre.Specification(s).a. No experiment shall be installed in the reactor unless a safety analysis has been performed andreviewed in accordance with Technical Specifications 3.8 and 6.5.b. The reactivity worth of a new experiment shall be verified at a power level less than 2 watts,before reactor operation at higher power with the experiment.Basis. Past experience has shown that adherence to requirements described in TechnicalSpecifications 3.8 and 6.5 are adequate to assure safe experimaentation at this facility.UCI Technical Specifications Page 25 Revision 2015-12-18v
- 5. DESIGN FEATURES5.1 Site and Facility DescriptionSpecification(s).The site shall be the reactor facility as described below.The reactor facility shall be a restricted access area consisting of a main area, two associatedlaboratory areas, and a control room on a single level in the basement of Rowland Hall, on theUniversity of California Irvine campus. The minimum free air volume of the reactor area includingthe two associated laboratories shall be 23,000 cubic feet. Normal entry to these areas shall berestricted to a single doorway from the control room. Large doors shall be provided to the adjacentloading dock to provide emergency egress and/or access for incoming or outgoing large items. Fullvisibility shall be provided between the control room and the reactor area.The reactor shall be housed in a closed area designed to restrict leakage.Basis. The extent of the site and facility is specified to define the controlled access area and themeans of access. The closed area is designated to assist in mitigation of potential radioactivereleases.5.2 Reactor Coolant SystemSpecification(s).a. The reactor core shall be cooled by natural convection water flow.b. All piping and other equipment for pool water systems shall be above normal pool level. Inletand outlet pipes that lead to the heat exchanger or demineralizer shall be equipped with siphonbreaks not less than 14 feet above the upper core grid plate, unless those pipes end more than 14feet above the upper core grid plate.c. A pool water level indication is provided at the control console with an alarm at the controlconsole and an alarm to a central monitoring station.d. A pool water temaperature indication shall be provided at the control console.e. A pool water conductivity measurement instrument shall be provided in the reactor room.f. Gamma and beta radiation spectrometry equipment shall be provided for water sampleradioactivity assay.Basis. Pool water quantity and quality is controlled so as to limit radiation and/or radioactivityrelease, and corrosion of components. Information is necessary to provide staff with indications ofchange in pool water characteristics.UCI Technical SpecificationsPae2Rvion01-28Page 26Revision 2015-12-18 5.3 Reactor Core and Fuel5.3.1 Reactor Core.Specification(s).a. The core assembly shall consist of TRIGA standard 8.5/20 stainless steel clad fuel elements.b. The core fuel shall be kept in a close-packed array in core lattice positions except for controlrods, single- or three-element or seven-element positions occupied by in-core experiments,irradiation facilities (including transfer system termini), graphite dummy elements, and a centraldry tube.c. Reflection of neutrons shall be provided by combinations of graphite and water, with thegraphite in sealed containlnent with aluminum cladding, either in the form of rods occupyinggrid positions, or in a larger reflector structure sur~rounding the core.d. An Am-Be neutron source shall be provided in one of two specific locations provided in theupper grid plate to provide start-up neutrons. It may be removed for maintenance purposes.Basis. Standard TRIGA fuel and reactor core design has a long and successful history of use.Model calculations in the SAR as supplemented by letter dated June 7th 2011, indicate acceptableneutronic and thermal hydraulic conditions for the core design under extended use and burn-up. TheAm-Be source is in a sealed capsule and has a long useful life.5.3.2 Control Rods.Speciflcation(s).a. The SHIM and REG rods shall be motor driven with scram capability and solid boroncompounds in a poison section, with fuel followers of standard TRIGA~ fuel meeting the samnespecifications as in Technical Specification 5.3.3.b. The ATR transient rod shall be motor and pneumatically driven, have scram capability, andcontain solid boron compounds in a poison section. The ATR shall have an adjustable uppertravel limit to provide variable pulse insertion capability. The FTR transient rod shall bepneumatically driven and have scram capability, and contain solid boron compounds in a poisonsection. The ATR and FTR shall incorporate air filled followers.Basis. These control rods have been shown by model calculations and a history of use to beeffective for assuring prompt shut-down and control of the reactor.UCI Technical SpecificationsPae2Rvion25128Page 27Revision 2015-12-18 5.3.3 Reactor FuelSpecification(s). Standard TRIGA fuel elements shall have the following characteristics:a. The total uranium content shall be nominally 8.5 % by weight, enriched to less than 20% 235U.b. The hydrogen to zirconium atom ratio in the zirconium hydride shall be a nominal 1.65hydrogen atoms to 1.0 zirconium atom.c. The cladding shall be 304 stainless steel, nominally 0.020 inches thick.d. An upper fitting with an engraved unique serial number shall be designed to fit a latching toolfor fuel movement.Basis. TRIGA fuel elements meeting these manufacturer's specifications have a long history ofsuccessful use with minimal failures. Minor deviations about these levels due to manufacturingvariations are not to be considered violations of this specification.5.4 Fuel StorageSpecification(s).a. All fuel elements shall be stored in a geometrical array where the keiis less than 0.80 for allconditions of moderation and reflection.b. Irradiated fuel elements and fueled devices shall be stored in an array which will permitsufficient natural convection cooling by water or" air such that the fuel element or fueled devicetemperature will not exceed 80°C.c. Fuel showing evidence of damage (see Technical Specification 3.1.6) shall be stored separatelyfr'om fuel not suspected to be damaged, and shall be checked for fission product leakage.Basis. These specifications establish a sufficient reactivity margin to guard against accidentalcriticality of elements in storage, and that heat dissipation does not create excess corrosion or" otherproblems. Damaged fuel is more likely to have or develop fission product leakage and so must bemonitored and kept separately.UCI Technical SpecificationsPae2Rvion05-28Page 28Revision 2015-12-18 5.5 Ventilation SystemSpecification(s).a. The ventilation system shall operate in either normal or emergency mode. The ventilationsystem shall consist of ducts, blowers, dampers, flow and pressure measurement devices, andexhaust points above the roof of Rowland Hall.b. During normal operations, the ventilation system shall be capable of exhausting air or othergases from the reactor area at a minimum rate of 3600 cubic feet per minute (cfm).c. During normal operation the ventilation system shall be capable of maintaining a minimutm of0.10 inches of water pressture differential between the reactor area and the control room, andbetween the reactor area and the outside air.d. During emergency situations involving release of radioactive materials into the air, anemergency exhaust with a high efficiency particulate arrestance (HBPA) filter shall be providedto exhaust a minimtum of 240 cfin fr'om the reactor area.e. Shutdown of the normal reactor area exhaust system and start-up of the emergency exhaustsystem shall be initiated by a high radioactive particulate count rate alarm signal originating inthe reactor room, or a manual switch in the control room.f. During all modes of operation, the ventilation system shall exhaust at a minimum height of 90feet above ground level.Basis. The ventilation system assists in mitigating the effects of radioactive reeases to theenvironment by providing dilution and control of such releases either during normal or emergencycircumstances.UCI Technical SpecificationsPae2Rvion25--8Page 29Revision 2015-12-18
- 6. ADMINISTLRATIVE CONTROLS6.1 Organization and Structure6.1.1 Structure.The reactor facility is housed in the School of Physical Sciences of the University of California,Irvine. The reactor is related to the University structure of positions shown in the organization chart,Figure 1, where solid lines represent direct reporting responsibility, dashed lines indicate workingrelationships.6.1.2 Responsibilities.a. The licensee of the reactor is the Board of Regents of the University of California, which hasdelegated authority for license matters to the Provost and Executive Vice Chancellor (Level 1)of the University of California, Irvine.b. The reactor facility is under the direction of a Reactor Director (Level 2) who shall be a tenuremember of thle University of California Irvine faculty. The Reactor Director shall report to theChair of the Chemistry Departm'ent (Level 1), who, in turn, shall be responsible to thle Dean ofthe School of Physical Sciences.c. Operations shall be supervised by the Reactor Supervisor (Level 3) who shall hold a valid senioroperator's license for the facility. This position shall be responsible for assuring that alloperations are conducted in a safe manner and within the limits prescribed by the facilitylicense, the provisions of the Reactor Operations Committee and the provisions of the RadiationSafety Colmmittee.d. Reactor operators (Level 4) shall be responsible for operation of the reactor and performingneeded maintenance and surveillance, including radiological safety and necessary supervision ofexperimenters. Senior reactor operators shall assume duties for supervision of operators asrequired by thle US Nuclear Regulatory Commission (NRC) inl Part 55 of 10 CFR, andTechnical Specification 6.1.3.e. There shall be a University of California, Irvine campus Radiation Safety Officer (RSO)responsible for the safety of operations from the standpoint of radiation protection. This positionreports to the Office of Environmental Health and Safety which is an organization independentof the reactor operations organization as shown in Figure 1. An independent campus-wideRadiation Safety Colmmittee (RSC) is responsible for establishmlent and review of all policiesinvolving radiation and radioactivity. Routine radiological safety requirements within thereactor facility shall be carried out by reactor operators and/or individual experimenters, all ofwhom shall be required, by regulations, to have received training in radiological safety and beauthorized for radiation use by the campus Radiation Safety Officer.f. in the event of absence, or during filling of appointments to specific positions, temporary dutiesand responsibilities may be carried out by the person next higher or lower in line in theorganization chart, provided the individual meets the basic qualifications for both positions.UCI Teclmical Specifications Pg 0Rvso 01-21Page 30Revision 2015-12-18 Figure 1. UCI Reactor Organization ChartUCI Technical SpecificationsPae3Rvion21121Page 31Revision 2015-12-18 6.1.3 a. The minimum staffing when the reactor is not secured shall include:i. a licensed operator present in the control room; andii. a second designated individual present withfin Rowland Hall able to carry out prescribedinstructions and with the ability to check on the safety of the licensed operator and toact in the event of emergency; andiii. a licensed Senior Operator (SRO) readily available on call. Readily available Onl callmeans the SRO has been specifically designated, the designation is known to theoperator on duty, the SRO can be rapidly contacted by phone by the operator on duty,and the SRO is capable of arriving at the reactor facility within 30 minutes under normalconditions.b. A list of reactor facility personnel and other persons responsible for radiological safety andsecurity on campus shall be kept in the reactor control room for use by an operator orexperimenter. The list shall include telephone numbers of the Reactor Director, the ReactorSupervisor, the campus Radiation Safety Officer and other back-up radiological safetypersonnel, reactor operators, senior reactor operators, and personnel with responsibilities formaintenance in Rowland Hall.c. Experimenters using the facility shall be certified by the campus Radiation Safety program astrained and authorized to use radioactive materials. The training shall include both generalradiological training, including features of the ALARA program and specialized training inprocedures for using reactor atuxiliary experimental equipment (such as transfer systems),carrying out necessary surveys and record-keeping necessary for proper handling of radioactivematerials within the reactor facility. Experimenters so trained and authorized are responsible fortheir own personal and sample/apparatus monitoring.d. The following events require the presence in the facility of a licensed Senior Reactor Operator.1. Initial start-up and approach to power and final daily shutdown.ii. Fuel or control-rod relocations within the core region.iii. Insertion, removal, or relocation of any experiment worth more than $1.00.iv. Restart following any unplanned or unscheduled shutdown, or unexpected powerdecrease of >10%.6.1.4 Selection and Training of PersonnelThe selection, training, and requalification of operations personnel shall meet the requirements ofANSI/ANS- 15.4 -2007.UICI Technical Specifications Pg 2Rvso 01-21Page 32Revision 2015-12-18 6.2 Review and AuditA Reactor Operations Committee (ROC) shall review reactor operations to assure that the facility isoperated in a manner consistent with public safety and within the terms of thle facility license.Review and audit of radiological safety at the facility shall be carried out by the Radiation SafetyCommittee (RSC).6.2.1 ROC Composition and QualificationsThe ROC shall have at least five voting members, at least one of whom shall be a health physicistdesignated by the Office of Environmental Health and Safety of the University. The Committee as awhole shall be knowledgeable in nuclear science and issues reated to reactor and/or radiologicalsafety. The membership shall include at least two members who are not associated with theDepartment of Chemistr. Approved alternates may serve in the absence of regular members.Members and alternates and a chairperson for the committee shall be appointed by the Chair of theDepartment of Chemistry (Level 1) or higher authority. The Reactor Director and ReactorSupervisor shall be non-voting members of the committee.6.2.2 ROC Charter and RulesThe following responsibilities constitute the charter of the ROC.a. Meeting at least annually, with provision for additional meetings when circumstances warrant toassure safety at the facility.b. A quortum shall consist of not less than a majority of the voting members and shall include thechairperson or his/her designee. A quorum shall not consist of a majority of operations staff.c. Review and audit of facility staff and operations as indicated in Technical Specifications 6.2.3and 6.2.4.d. Designation of indivduals to perform audits of facility operations and records.e. Preparation, approval, and dissemination of minutes of meetings.f. Preparation and dissemination of findings and other reports as needed to assure safe operationsof the reactor.g. Approval of individuals for the supervision and operation of the reactor.UCI Technical Specifications Pg 3Rvso 01-21Page 33Revision 2015-12-18 6.2.3 ROC Review FunctionThe following review functions shall be the responsibility of the ROC.a. Review and approval of all proposed changes to the facility, its license, procedures, ROCcharter, and Technical Specifications, including those made under provisions of 10 CFR §50.59, and the determinations leading to decisions relating to 10 CFR § 50.59 approvals.b. Review and approval of new or changed procedures, experiments, components, or"instrumentation having safety significance.c. Review of the quality assurance program implementation applicable to the reactor components.d. Review of new experiments or changes in experiments that could have reactivity or safetysignificance.e. Review of violations of technical specifications, license, or violations of procedures orinstructions having safety significance.f. Review of operating abnormalities that have safety significance.g. Review of actions and reports listed in Technical Specifications 6.6.1, 6.6.2, or 6.7.2.h. Review of audit reports, including reports from the campus Radiation Safety Officer, regardingthe radiation protection program.6.2.4 ROC Audit FunctionThe ROC shall perform autdits or review audits performed by designated individuals on its behalf atleast annually. The autdit shall include, but not be limited to, the following items.a. Facility operations for conformance to the Technical Specifications and applicable licenseconditions.b. Retraining and requalification of operators according to the Requalification Plan.c. The result of action taken to correct those deficiencies that may occur in the reactor facilityequipment, systems, structures, procedures or methods of operation that affect reactor safety.d. The facility Emergency Plan (EP) and implementing procedures including written reports of anydr'ills or" exercises carried out.e. At least one of the auditors shall be familiar with reactor operations but not directly responsiblefor any portion of reactor operations.f. Any deficiencies identified in an audit that affect reactor safety shall be immediately reported tothe chairperson of ROC, and to the Level 1 administrator. A written fufll report shall besubmitted to ROC within 3 months of any audit.UCI Technical SpecificationsPae3Rvion25--8Page 34Revision 2015-12-18 6.3 Radiation SafetyAs delineated in Technical Specification 6.1.2.e, the campus Radiation Safety Officer (RSO) isresponsible for implementation of the radiological safety program at the reactor facility inaccordance with applicable federal and state of California standards and regulations. The programshould use the guaidelines of ANSI/ANS 15.11-2004.The RSO shall be responsible for an annual audit of the radiation safety program.6.4 Operating ProceduresWritten procedures, reviewed and approved by the ROC and the Reactor Director, shall be in effectand implemented for the following listed items. The procedures shall be adequate to assure thesafety of the reactor but not preclude the use of independent judgment and action should thesituation require such. Any changes to procedures shall be made in accordance with therequirements of 10 CFR § 50.59.a. Startup, operation, and shutdown of the reactor.b. Installation or removal of fuel elements, control rods, experiments, and experimental facilities.c. Maintenance of major components of systems that could have an effect on reactor safety.d. Surveillance checks, calibrations and inspections required by the technical specifications or thatcould have an effect on reactor safety.e. Personnel radiation protection, including provisions to maintain personnel exposures as low asreasonably achievable (ALARA).f. Administrative contr'ols for operations and maintenance, and for the conduct of irradiations orexperiments that could affect reactor safety.g. Implementation of required plans including Emergency (EP) and Physical Security (PSP) plans.h. Use, receipt and transport of by-product materials.6.5 Experiment Review and ApprovalApproved experiments shall be carried out in accordance with established and approved procedures.Procedures for experiment review and approval shall include the following requirements.a. All new experiments or class of experiment shall be reviewed and approved by the ROC andapproved in writing by the Reactor Director. The review shall include analysis by the RSO orother designated radiation safety personnel.b. Changes to existing experiments or classes shall be made only after review by the ROC andRSO or the RSO designee, following performance of a 10 CFR § 50.59 evaluation and theconclusion that the proposed changes do not require prior NRC approval.UCI Technical SpecificationsPae3Rvion211-8Page 35Revision 2015-12-18 6.6 Reqiuired ActionsThis specification is intended to assure compliance with requirements of 10 CFR § 50.36.6.6.1 Actions to Be Taken in Case of a Safety Limit ViolationIn the event the safety limit on fuel temperature is exceeded:a. the reactor shall be shut down and the event reported immediately to the Reactor Director, theROC chairperson, and the RSO. Reactor operation shall not be resumed until authorized by theNRC; andb. the event shall be reported within the next working day to the NRC Headquarters OperationsCenter; andc. a follow-up written r~eport sent shall be reviewed by the ROC and sent within 14 days to theNRC (according to provisions of Technical Specification 6.7) describing:i. applicable circumstances leading to the violation including, where kcnown, the cause andcontr'ibuting factors; andii. effects of the violation upon reactor facility components, systems, or structures, and onthe health and safety of personnel and the public; andiii. the basis for corrective action taken to preclude recurrence.UCI Teclmical SpecificationsPae3Rvion21--8Page 36Revision 2015-12-18 6.6.2 Actions to Be Taken in the Case of Events Other than a Safetyr Limit ViolationIn the event of an occurrence of the type listed in items 1-7 below:a. the reactor shall be secured and the Reactor Director and Supervisor notified; andb. operation shall not be resumed until authorized by the Reactor Director and the ROC; andc. a follow-up written report shall be reviewed by the ROC and sent within 14 days to the NRC(according to provisions of Technical Specification 6.7) describing:i. applicable circumstances leading to the violation including, where known, the cause andcontributing factors; andii. effects of the violation upon reactor facility components, systems, or structures, and onthe health and safety of personnel and the public; madiii. the basis for corrective action takcen to preclude recurrence.1. Release of radioactivity from the site above allowed limits.2. Operation with actual safety system settings for required systems less conservative than thelimiting safety system settings in these specifications.3. Operation in violation of limiting conditions for operation unless prompt remedial action is*taken as permitted in Technical Specification section 3.4. A required reactor safety system component malfunction that renders or could render the safetysystem incapable of performning its intended safety function. If the malfunction or condition is* caused by maintenance, then no report is required.5. Ant unanticipated or uncontrolled change in reactivity greater than one dollar. Reactor tripsresulting from known cause are excluded.6. Abnormal or significant degradation in reactor fuel or cladding, or both, coolant boundary, orconfinement boundary (excluding minor leaks) where applicable.7. An observed inadequacy in implementation of administrative or procedural controls such thatthe inadequacy causes or could have caused the existence or development of an unsafe conditionwith regard to reactor operations.UCI Technical SpecificationsPae3Rvion25-21Page 3 7Revision 2015-12-18 6.7 ReportsIn addition to the requirements of applicable regulations, and in no way substituting for them,reports shall be made to the NRC as listed below. All writt en reports shall be directed to theDocument Control Desk, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555-0001.6.7.1 Annual Operating ReportA routine written annual report shall be submitted by the Reactor Director to the NRC, bySeptember 3 0th each year regarding operations for the preceding academic year (July 1st throughJune 30Oth). The report shall include, but not be limited to:a. a brief narrative summary of operating experience (including experiments performed) and atabulation showing the energy generated by the reactor (in megawatt hours), the amount ofpulse operation, and the number of hourns the reactor was critical; andb. the number of unplanned shutdowns and inadvertent scrams, including the reasons therefore,and corrective actions taken (if any) to reduce recurrence; andc. a tabulation of major preventive and corrective maintenance operations having safetysiguificance; andd. a tabulation of changes in the reactor facility and procedures, and tabulations of newexperiments, including a summary of the analyses leading to the conclusions that they areallowed without prior auth~orization by NRC and that 10 CFR § 50.59 was applicable; ande. a summary of the nature and amount of radioactive effluents released or discharged to theenvirons beyond the effective control of the facility as measured at or prior to the point of suchrelease or discharge. The summary shall include, to the extent practicable, an estimate ofindividual radionuclides present in the effluent. If the estimated average release after dilution ordiffusion is less than 25% of the concentration allowed, a statement to this effect is sufficient;andf. a summarized result of environmental surveys performed outside the facility; andg. a summary of radiation exposures received by facility personnel and visitors, where suchexposures are greater than 25% of that allowed.UCI Technical SpecificationsPae3Rvion211-8Page 38Revision 2015-12-18 6.7.2 Special ReportsIn addition to reports required according to Technical Specification 6.6, a report shall be made inwriting to the Document Control Desk, U.S. Nuclear Regulatory Commission, Washington, D.C.,20555-000 1 within 30 days of:a. permanent changes in facility organization involving Level 1 or Level 2 personnel; andb. significant changes in the transient or accident analyses as described in the SAR.6.8 RecordsIn addition to the requirements of applicable regulations, and in no way substituting therefore,records and logs shall be prepared and retained for periods as described here. Records may be in avariety of fonnats.6.8.1 Records to Be Retained for a Period of at Least 5 Years or for the Life of the Component InvolvedIf Less than 5 Years.a. Normaal reactor facility operation, but not including supporting documentation such aschecklists, log sheets, etc., which shall be retained for one year.b. Principal maintenance activities.c. Reportable occurrences.e. Surveillance activities required by the Technical Specifications.f. Reactor facility radiation and contamination surveys.g. Experiments performed with the reactor.h. Fuel inventories, receipts and shipments.i. Approved changes in operating procedures.j. ROC records of meetings and audit repolrtS.6.8.2 Records to Be Retained for at Least One Certification CycleRecords of retraining and requalification of all licensed operators shall be retained at all times eachindividual has duties as an operator or until his or her license is renewed.UCI Technical SpecificationsPae3Rvion25-28Page 39Revision 2015-12-18 6.8.3 Records to Be Retained for the Lifetime of the Reactor FacilityThe following records shall be retained for the lifetime of the facility. Applicable annual reportscontaining this information may be used as records.a. Reviews and reports pertaining to a violation of a safety limit, the limiting safety system setting,or a limiting condition for operation as described in Technical Specification 6.6.b. Gaseous and liquid radioactive effluents released to the environs.c. Results of off-site environmental monitoring surveys.d. Radiation exposures for all personnel that were monitored.e. Drawings of the reactor facility and safety related components.UCI Techanical SpecificationsPae4Rvion01--1Page 40Revision 2015-12-18 UCI TRIGA Reactor Reactivity RAMP Insertion Simulation.J. T. Wallick, Associate Reactor SupervisorG. E. Miller, Reactor SupervisorDecember 2015ConclusionsParameters of interest achieved the following values during the simulation:* Maximum reactor power was 1,118,874 watts.* Peak fuel temperature was 40.24 °C.dk*Highest core reactivity was 7.87 E-03 --* Shortest positive reactor period was 1.52 E-03 seconds.* Prompt criticality was never achieved.* Total energy released was 0.39 kWh.Overall, the transient behaved as expected given the conditions and accident analyzed. It provides fairlyconclusive evidence that a reactor designed for far harsher transients, such as rod ejections using compressed airachieving transient times on the order of milliseconds, can withstand an excessively conservative uncontrolledcontinuous rod withdrawal scenario.Methodology.The program used was developed in spreadsheet software. The methodology used in modeling the reactor'spredicted behavior during this transient is calculated in an iterative fashion as follows:1. Given input parameters for the simulation:a. Effective delayed neutron precursor decay constant (2ft is held constant at 0.1 sec-1.b. Temperature coefficient of reactivity (3ka) is -1.00 E-04 .7/acc. Effective delayed neutron fraction (f3eff) is 0.0079d. Prompt neutron generation lifetime (j*) is 9.85 F-OS secd /se. Reactivity addition rate of the 5) is 4.80 E-04 k/ecf. Initial reactor power is 1.5 watts.g. Initial reactor fuel temperature is 25.0 °C.h. Single element total heat capacity is 1088 c + 1.5
- Fuel Temp Wse~ci.Number of fuel elements in core is 80.j. The total fuel element heat capacity is 87040 + 120
- Fuel Temp w~secC Ck. A high power scram will occur one second after power reaches 110% power (275 kW) to allow forinstrumentation response time.I. The scram will insert all rods except the highest worth rod, which will stop outward motion.m.The total negative reactivity insertion of the scram will be 1.9039 E-02.7, which will be inserted over thecourse of one second.
- 2. Reactor parameters are calculated every iteration in the following manner:a. Time is incremented in 100 i~sec steps, equal to the prompt neutron lifetime in the University ofCalifornia, Irvine TRIGA Mk I Reactor as calculated by General Atomics.b. Power is calculated based on the previous power, difference in time, and previous reactor period.P= P *e~tc. Reactivity change of the control rods is added to the core.d. Energy generated is calculated based on reactor power and difference in time.E=P~te. Temperature change is calculated based on energy generated, total fuel element heat capacity, andprevious fuel temperature.Ef. Current temperature is calculated based on the temperature change and previous temperature.r= AT + rog. Reactivity change of the temperature coefficient of reactivity is calculated based on the temperaturechange and the temperature coefficient of reactivity.= AT
- ah. Current core reactivity is calculated based on the previous core reactivity, rod reactivity change, andreactivity change of the temperature coefficient of reactivity.6kcurr~ent = Skprevious + A~krods + ASkai.Period is calculated using the traditional in-hour equation and the current core reactivity.P '2eff*P-ij. Calculations repeat in this manner over the course of 30 seconds.k. Discontinuities arise as parame~ters switch negative to positive changes, prompt vs. delayed "switchover" and no allowance being made for "down power" effective delayed neutron precursor decayconstant.The attached graphs show:1. Power, Energy, Fuel Temperature, Reactivity and Period over the 30 second time of a RAMP.2. Power and period changes determined over the significant time period 16-17 seconds into the RAMP.3. An annotated plot of the simulation results over the "excursion" time period of the event from 15.0 to 20.0 seconds.4. A detail of power and period through the predicted scram at 17.42 seconds into the RAMP.
aRamp Analysis..-, owe[ (WI -l'otal (W-seC) -Temp (C) -Core React Period (seel)100000001000000-tc-13000001Q00010001005040302010-*020130-40-501030,0020.00 25.0010.00 15.005.00 Time in Seconds0.00Power Excursion-- -Po e IW) .... Period (sec)1000.0010000000100000010000010000100.0010.000100-c0a)0-i-ia)00,110000.0110016.0016.1016.20 16.30 16.40 16.50Time in Seconds16.6016.7016.80 16.90 SILiertICrossing the Point of Addilng Heat, wherethe Negativ Temnperature Coefficien ofR~eacti-vit begins taking effectirocessing tm',e afer power is detected to have exceeded110% of 250 kWIThe SCRAM finished reactivity insertionI iWhre the Negativ TemperatureCoetffcient of Reactivit has addedenough negative reactvt to trensitortthe core from suprrtc'to subcritcaHummg behavior indicative of not trantsitioningthe Effective Deiayed Neutron Precursor DecayConstant from 0.1 sec to 0.05 sec from Up-Power transen to Down-Power trnmsient_Calcujatior error.Scram Occurrs--Power (W) -,--- Period Isee)100(0000001000OOO00-10-20-30-40ci-50 C)-60-70-80-90-10017.7010000017.1017.2017.3017.40 17.50 17.60Time in Seconds