ML19337A436

Reply to a Notice of Violation - 2019 NRC Annual Inspection of the Kansas State University Triga Mark II Nuclear Reactor (Facility License # R-88, Facility Docket# 50-188)

ML19337A436
Person / Time
Site:	Kansas State University
Issue date:	11/29/2019
From:	Cebula A Kansas State University, Manhattan
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19337A436 (2)

Text

3002 Rathbone Hall Kansas State University Manhattan, KS 66506 U.S. Nuclear Regulatory Commission ATTN:DocumentControlDesk Washington, OC 20555-0001 29 November 2019

Subject:

Reply to a Notice of Violation - 2019 NRC Annual Inspection of the Kansas State University TRIGA Mark II Nuclear Reactor (Facility License

1. R-88, Facility Docket# 50-188)

To Whom It May Concern:

(

This letter is in response to a Notice of Violation dated 30 October 2019. In accordance with the instructions in the Notice of Violation, the following paragraphs address the required topics.

(I) The reason for the violation: Surveillance items and corresponding performance frequencies are tracked in a monthly report. An error in frequency for environmental survey requirements was made in the tracking report which resulted in the environmental surveys being performed annually instead of semi-annually. Failure to submit the annual operating report for calendar year 2018 by 1 March 2019 resulted in a violation.

(2) Corrective steps that have been taken and the results achieved: The surveillance frequency and due date for the semi-annual environmental survey has been corrected in the monthly tracking report document. Additionally, all surveillance requirements were reviewed for accuracy in the monthly tracking report*

document. The tracking document was also revised to include a record of dates for previously performed surveillance. This will provide redundancy in the tracking document for checking compliance with meeting surveillance interval requirements. The next environmental survey has a due date corresponding to a semi-annual frequency to meet the appropriate interval requirement. A report dated 28 November 2019 has been submitted to correct failure to timely submit an annual report. Also, documentation has been improved to expedite data aggregation for use in future annual reports.

(3) Corrective steps that will be taken: Regarding the environmental survey finding, all reactor staff will attend a training session on surveillance requirements and Al>ZD

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frequency of surveillance. Staff will also be trained on the use of the revised surveillance tracking and reporting document focusing on appropriate due dates and the inclusion of previously performed surveillance dates. The most recent environmental survey was completed on 9 August 2019. To meet the semi-annual requirement, the next environmental survey will be completed by 5 February 2020. The timely annual report submission for calendar year 2019 will be completed by 29 February 2020.

(4) The date of full compliance: At the conclusion of staff training on surveillance requirements, all corrective actions will have been taken. Anticipated completion date for the staff training is 6 December 2019. Compliance will be maintained as the next surveillance completion dates are met.

Please contact me if additional information is required.

Sincerely,

/::;-: ~

Alan T. Cebula, Ph.D.

Nuclear Reactor Facility Manager Kansas State University Phone:(785)532-6657 Fax: (785) 532-7057 Email: alanc@ksu.edu Cc: Craig Bassett, Inspector, NRC Linh Tran, Project Manager, NRC