ML20237B455

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Forwards New Copy of Kansas State Univ Triga Mark II Physical Security Plan W/Changes Highlighted,As follow-up to 980619 Submittal.Elimination of Licensee Physical Security Plan as Licensed Document,Requested.Encl Withheld
ML20237B455
Person / Time
Site: Kansas State University
Issue date: 08/13/1998
From: Ryan B
KANSAS STATE UNIV., MANHATTAN, KS
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9808180290
Download: ML20237B455 (1)


Text

(( '/ M 13 August 1998 I STME

- Kansas State University .

Department of Mechonical and Nudear Engineering 302 Rothbone Hall U.S. Nuclear Regulatory Commission vanhanan.xs 665o6-5204 Document Control Desk 785 532 56io

' ". 785 532 7o57 Washington, D.C. 20555 i

To whom it may concern:

This letter is to follow up concerns with the Kansas State University TRIGA Mark II (License R-88) Physical Security Plan transmitted to you on 19 June 1998. A new copy with the changes highlighted is provided. The two editorial changes were simply replacing the title "Direstor" with the title "Miiiisir", as provided by 10CFR50.59. I do not believe these changes to be substantive in any manner.

To simply the reporting requirements of the current plan, I request the elimination of our Physical Security Plan as a licensed document. In doing so, we will not abandon the current plan nor its upkeep. I simply believe that a formal Physical Security Plan is not required by 10CFR73 for our operation because:

235

1. Our license R-88 way allows possession of 3.98 kg of U at enrichments less than 20% and 0.02 kg at higher enrichments (for fission chambers). This should place us in the dermition oflow strategic significance, or Category III, and is significantly less than a formula quantity.
2. We are subject to the exemptions of Section 6. Additionally we are not bound by Sections 21,50, and 55-57, as we do not possess a formula quantity, nor are we a power reactor.
3. The additional non-power reactor requirements of Section 60 only apply for 235 U > 5 kg, which we can not even possess by our license.
4. As designed, this leaves us still covered by Section 67 for low strategic significance. In Section 67, I believe that we meet the requirements of(b)(1)(i),

as the bulk of our fuel has been significantly irradiated. In any case, our existing system certainly exceeds the requirements of(f), which does apply in our case. '

I!

If you have any questions regarding this matter, please feel free to contact me directly.

'b Again these matters are exempt from public disclosure per 10CFR2.790(d), as is the enclosed copy of our Physical Security Plan.

f' Sincerely, -

/ / ,

ss ,n&. G - d,'n.

Brendan C. Ryan, Manager KSU Nuclear Reactor Facility

/'

9808100290 980813 f' l jl PDR ADOCK 05000188 F PDR Fax: (785)532-6952 E-Mait ibryan@ne.ksu edu Phone:(785)532-6657 112 Ward Hall. Manhattan, KS 66506-2503