IR 05000188/1986002

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-188/86-02

ML20212E228
Person / Time
Site:	Kansas State University
Issue date:	12/24/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Faw R KANSAS STATE UNIV., MANHATTAN, KS
References
NUDOCS 8701050278
Download: ML20212E228 (1)

Text

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., 4 DEC 2 41986 in Reply Refer To:

Docket: 50-188/86-02 Kansas State University Department of Nuclear Engineering ATTN: Dr. R. E. Faw, Director Nuclear Reactor Facility Manhattan, Kansas 66505 Gentlemen:

Thank you for your letter of November 17, 1986, in response to our letter

and Notice of Violation dated October 20, 1986. We have reviewed your reply l and find it responsive to the concerns raised in our Notice of Violation. We l will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintai,ed.

Sincerely, ORIGINAL SIGNED BY:

J. E. Gagliardo, Chief Reactor Projects Branch cc:

Kansas Radiation Control Program bec to DMB (IE06)

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RPB Resident Inspector R. D. Martin, RA R&SPB Section Chief (RPB/B) D. Weiss, LFMB (AR-2015)

RIV File DRSP RSB MIS SYSTEM RSTS Operator Inspector Section Chief W. L. Fisher R. L. Bangart J. J. Dosa, NRR, Project Manager RIV:FRP C:FRPS C:R&SPB CRPB [

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November 17, 1986 U.S. Nuclear Regulatory Commission Region IV Attn: J. E. Gagliardo, Chief Reactor Projects Branch 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 Re: License R-88 Docket 50-188

Dear Sirs:

This is in response to your letter of 20 October 1986 and its attendant notice of violation. Our response is enclosed.

Sincerely, et<f f hin V Richard E. Faw, Director KSU Nuclear Reactor Facility REF/cs Enclosure

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RESPONSE TO NOTICE OF VIOLATION

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Kansas State University (KSU) Docket: 50-188/86-02 TRICA MkII Reactor License: R-88 A. Failure to Perform Survey Instrument Calibration Reason for Violation This violation is admitted. The reasons are as follows: The Reactor Facility maintains and calibrates instruments for general use in the Nuclear Engineering Department. On some occasions, these general-purpose instruments are in use outside the Reactor Facility at the time of reactor-instrument calibratior.. Record keeping procedures hase been deficient in identification of those occasions.

Cprrective Steos Taken New record keeping procedures have been implemented. A master log of calibration dates has been instituted to supplement calibration logs for each instrument.

Corrective Steos to be Taken At the time of the next calibration, those instruments not required for reactor surveillance are to be sequestered in their own storage location.

All instruments are to be tagged with identification of their use (reactor or non-reactor) and the calibration expiration date.

Date of Full Compliance All instruments are now in calibration. The next round of calibration will take place in Decerber 1986 and January 1987.

B. Failure to Develon Written Procedures Reason for Violation

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The absence of certain written procedures is not admitted. That these prccedures have not been approved by the Reactor er Safeguards Committee is admitted. Vendor-supplied instruction manuals for the systems in question are followed in their use. Such manuals have not been submitted to the Reactor Safeguards Connittee for its endorsement.

Corrective Steps to be Taken ,

Operating procedures incorporating, by reference, vendor's instruction manuals will be prepared and submitted to the Reactor Safeguards Committee for endorsement.

Date of Full Compliance

. March 1. 1987. -

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C. Failure to Survey Reason for Violation Failure to evaluate liquid effluents for alpha-particle activity is admitted.

Failure to monitor adequately airborne activity in the reactor bay atmosphere is not admitted. The potential for fuel-element cladding failure and for escape of noble gas and iodine radionuclides was addressed in the Hazards Summary Report for the Kansas State University TRIGA Mk II Reactor and in the safety analysis submitted to the Atomic Energy Commission in application for operation of the reactor at 250 kWt.

In the Safety Evaluation by the Division of Reactor Licensing. Docket l

50-188, " Kansas State University Increase in Power Level " signed by D.J.

Skovholt on 26 June 68, it was stated by the AEC that:

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. The applicant's analysis, with which we agree, indicates that such an accident [ loss of pool coolant water af ter prolonged high-power operation] would not cause damage to the fuel or result in the release of fission products. However, even if the cladding of a fuel element were to fail, permitting fission products to escape, the applicant's calcualtions, and our analysts indicate that doses to personnel within the building and in unrestricted areas outside the building would remain within acceptable limits."

[ italics added]

In view of this finding, attempts have not been made to identify specific noble gas radionuclides in the reactor building atmosphere. Instead, radiation exposure rates are monitored throughout the reactor building in recognition that significant noble gas releases would thus be detected.

Emergency Procedure No. 6 has been implemented in order that such l exposure rates could be translated conservatively into radionuclide l concentrations for use in accident assessment. )

In order to monitor lor potential fission product relee.se of long duration, a number of surveillance actions are taken: (1) Activity held

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on pool-cleanup demineralizer resin is monitored each operating day.

Unusual increase in ac tivity would provide an early qualitative warning of the presence of fission products in primary coolant. (2) Primary coolant is sampled monthly and analyzed for gross activity using a liquid scintillation system. If any activity were found, gansna-ray spectral analysis would be performed. This would provide a quantitative measure of fission product activity in primary coolant. (3) During reactor use, operation of a continuous air monitor is required. Except for periods of maintenance, the monitor is operated continuously (24-h per day). The monitor is set to alarm at radiation indication very conservatively 131 representative of I maximum permissible concentration in unrestricted areas. The potential for argon-41 release into the reactor building was also addressed in the Hazards Analysis Report and found not to present a significant risk. Notwithstanding this finding, the use of air as the

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driver gas for the pneumatic transfer system has been discontinued, with its use replaced by that of helium. The highly unlikely, but potential venting of air from the rotary specimen rack has also been investigated.

That event would certainly be detected, yet concentrations and potential personnel exposures would be within acceptable 10CFR20 limits.

Corrective Stens to be Taken A procedure for alpha monitoring of Reactor Facility liquid effluents is under preparation. No effluents will be released without such monitoring.

Aside from fuel material, whose presence would be indicated by fission-product activity, the only source of measurable artificial alpha activity in reactor effluents would be the Am/Be source used for reactor start-up. This source is encapsulated in stainless steel and contained within an aluminum housing. We are contemplating either seeking a method of direct determination of source leakage or appealing for relief from this :aonitoring requiren.ent under the provisions of 10CFR20.501.

Date of Full Compliance March 1, 1987

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