ML24085A808

Kansas State University 10 CFR 55.59 License Requirements Exemption Request

ML24085A808
Person / Time
Site:	Kansas State University
Issue date:	03/07/2024
From:	Cebula A Kansas State University
To:	Mohamed Shams Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML24085A808 (1)

Text

Director of the Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555-0001

7 March 2024

Subject:

Kansas State University, License R-88, Docket 50-188, License Requirements Exemption Request

Dear Mo Shams,

The Kansas State University TRIGA Mark II research reactor (KSURR) has been under an extended shutdown to address a fuel issue identified during routine fuel inspection. As a result, the ability to complete components of the operator requalification program and meet certain requirements of 10CFR55 have been limited. This request is being made to allow maintenance activities, including fuel cleaning and inspections, to continue and provide a pathway for resuming normal operations.

KSURR facility requests exemption from the following license requirements for operator licensees:

1. Requalification Program Section 3.2.1 Reactivity Manipulations and 10CFR55.59(c)3)(i)

2. Requalification Program Section 3.2.2 Proficiency as Operator at the Controls

3. Certain portions of 10CFR55.59(a)(2)(ii) affecting the annual operating test that are applicable to the facility, specifically:

a. 10CFR55.45(a)(2) Manipulate the console controls as required to operate the facility between shutdown and designated power levels.

b. 10CFR55.45(a)(5) Observe and safely control the operating behavior characteristics of the facility.

c. 10CFR55.45(a)(6) Perform control manipulations required to obtain desired operating results during normal, abnormal, and emergency situations.

Annual operator exams will be conducted with applicable items from 10CFR55.45(a) that can be performed and are not included in the exemption request. Quarterly operator proficiency will continue to be met by the licensee performing the functions of a senior operator by directing fuel movements during fuel cleaning and inspections. Recurring lectures will continue to address the requirements of the Requalification Program Section 5.1.1. Additional actions to be performed by the licensee during the exemption period include:

1. Monthly refresher training sessions that maintain familiarity with procedures.

2. Biweekly performance of Procedure No. 12 - Instrument Checkout to maintain familiarity with controls and systems.

Before the administrative restriction on operations related to the fuel issue is cancelled, at least one senior reactor operator licensee shall acquire training and perform control manipulations as a trainee at University of Texas at Austin Research Reactor that demonstrate understanding and ability to perform 10CFR55.45(a)(2), (5), and (6). Results of the additional training will be included with the licensee requalification training records. Any operator who does not complete the training will become inactive and follow Requalification Program Section 3.3.1 or other requirements approved by the NRC before being reactivated.

This exemption request has been reviewed and approved by the KSURR Reactor Safeguards Committee.

If approved by the NRC, the exemption will be in effect until 30 days following the cancellation of the administrative restriction on operations related to the fuel issue.

Regards,

Alan T. Cebula Nuclear Reactor Facility Manager Alan Levin Department of Mechanical and Nuclear Engineering Kansas State University Manhattan, KS 66506

cc: Linh Tran, NRC Project Manager