ML20214P128

Forwards Response to Violations Noted in Insp Rept 50-188/86-02.Corrective Actions:At Time of Next Calibr, Instruments Not Required for Reactor Surveillance Will Be Sequestered in Storage Location

ML20214P128
Person / Time
Site:	Kansas State University
Issue date:	11/17/1986
From:	Faw R KANSAS STATE UNIV., MANHATTAN, KS
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8612040083
Download: ML20214P128 (4)

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Department of Nuclear Engineering

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M Ward Hall gi[53 54 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<k$hdel Richard E. Faw, Director KSU Nuclear Reactor Facility REF/cs Enclosure ir -

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RESPONSE TO NOTICE OF VIOLATION

-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 Fadlity at the time of reactor-instrument calibration. -Record keeping procedures have been deficient in identification of those occasions.

Corrective Steps 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 December 1986 and January 1987.

B. Failure to Develon Written Procedures Reason for Violation The absence of certain written procedures is not admitted. That these procedures have not been approved by the Reactor or Safeguards Comittee 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 Committee 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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2' 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. 'Ihe 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 eubmitted to the Atomic Energy Conunission in application for operation of the reactor at 250 kWt.

In the Safety Evaluation by the Division of Reactor Licensing, Docket ,

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

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

. . . 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 l

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 exposure rates could be translated conservatively into radionuclide concer : rations for use in accident assessment.

In order to monitor for potential fission product release of long duration, a number of surveillance actions are taken: (1) Activity held 3 on pool-cleanup demineralizer resin is monitored each operating day.

Unusual increase in activity 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, gamma-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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s 3 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 10CFR2O limits. j .s Corrective Steos 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' art.Ificial alpha s activity in reactor effluents would be the Am/Be source used for reactor -

start-up. This source is encapsulated in stainless steel and contained 'L within an aluminum housing. We are contemplating either seeking a method of direct determination of source leakage o appealing for relief from this monitoring requirement under the previsions of 10CFR20.501. '

Date of Full Compliance -

March 1, 1987

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