ML24281A032
| ML24281A032 | |
| Person / Time | |
|---|---|
| Site: | Kansas State University |
| Issue date: | 10/04/2024 |
| From: | Cebula A Kansas State University |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML24281A032 (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 4 October 2024 KANSAS STATE TRIGA Mk II Nuclear U N I v E R s I T y Reactor Laboratory
Subject:
Kansas State University (KSU), License R-88, Docket 50-188, License Requirements Exemption Request Additional Supplemental Information
Dear Mo Shams,
This letter provides additional information to the previously submitted supplemental information letter dated 11 June 2024 (ML24164A092), and exemption request dated 7 March 2024 (ML24085A808). This information is a response to discussion with and questions from representatives of the Nuclear Regulatory Commission (NRC) during a conference call and email communication on 20 September 2024. Summary of the clarification needed was provided in email as the four following items:
- 1. NRC: "The Commission may, upon application by an interested person, grant specific exemptions in accordance with 10 CFR 55.11 from the requirements in Part 55, "Operators' Licenses/' if it determines they are authorized by law and will not endanger life or property and are otherwise in the public interest. The KSU exemption request (Agencywide Documents Access and Management System Accession No. ML24085A808), as supplemented (ML24164A092),
does not describe how granting the exemption will not endanger life or property and is in the public interest. Provide justification, to include the specifics on the reason for the KSU exemption request, for how granting this exemption will not endanger life or property and is in the interest of the public."
KSU Response:
KSU is requesting the exemptions to allow maintenance activities involving fuel movement, fuel cleaning, and fuel inspection to resume as soon as possible. This exemption will not endanger life or property because it will allow persons experienced with typical licensed activities involving fuel movement to resume inspections and cleaning with the reactor shutdown. In the interest of the public, the exemption will allow for surveillance activities, which require licensed operators such as fuel inspections, to continue. These activities are important for assuring the public that the reactor and all associated components are safe, even when shut down.
Only a portion of the requalification program related to reactor operations is not able to be met at KSU during the administrative restriction on operations. Before the restriction on reactor operations is cancelled, additional training at an alternative facility will be completed, which provides a pathway for returning to normal operations. Alternative training will be conducted under the instruction of licensed persons at a facility with an NRC approved requalification program and similar operating characteristics as previously described (ML24164A092).
Finally, the KSU TRIGA reactor is the only research reactor in the state of Kansas and one of a few in the central United States. Returning the KSU reactor to operational status through fuel cleaning, required surveillance, and alternative reactor operator requalification will restore an essential research, teaching, and outreach resource to the public.
- 2. NRC: "The regulations in 10 CFR 55 establish qualification requirements, to include requalification requirements, for reactor operators and senior reactor operators. The KSU exemption request, as supplemented, states that "the ability to complete components of the operator requalification program and meet certain requirements of 10 CFR 55 have been limited," and requests exemption from several license requirements for operator licensees.
Further, the supplement states, "Possible participant(s) in the additional training at UT ARR
[University of Texas at Austin Research Reactor] may be selected from the currently licensed senior reactor operators." For the personnel and activities to be exempted, identify the following:
- a. The Senior Reactor Operators by name and docket to which the KSU exemption request will apply, and provide the following information for each operator:
(1)
For the Commission approved requalification requirements under 10 CFR 55.59(c), identify any additional exemptions from specific regulations that are needed for the requalification program, to generally conform to the requalification program requirements outlined in paragraphs (c)(l) through (c)(6). (Note: exemptions are to regulations not to the licensee's requalification plan)"
KSU Response:
The exemption requests apply to the following Senior Reactor Operators:
Alan Cebula, Docket# 055-70722 Amir Bahadori, Docket# 055-70720 Robert Seymour, Docket# 055-71404 In addition to the previously requested exemptions for:
Regulation Reason for request 10CFR55.53(e)
Unable to perform operations (Supplemental letter ML24164A092) 10CFR55.59(c)(3)(i)
Unable to complete all plant control manipulations (Supplemental letter ML24164A092)
KSU also requests exemption to the following regulations:
Regulation Reason for request 10CFR55.53(f)(2)
Unable to perform operations under direction of operator or senior operator during the administrative restriction on operations 10CFR55.53(h)
Unable to complete all items of requalification program during the administrative restriction on operations 10CFR55.59(a)(l)
Unable to complete all items of requalification program during the administrative restriction on operations
Unable to complete comprehensive sample of items specified in 10CFR55.45(a)(2) through (13) inclusive as applicable to the facility for the annual operating test during the administrative restriction on operations (Note: written examinations continue) 10CFR55.59(c)(4)(i)
Unable to complete comprehensive sample of items specified in 10CFR55.45(a)(2) through (13) inclusive as applicable to the facility for annual operating test evaluation during the administrative restriction on operations
- b.
NRC: "Provide additional information on the proposed requalification plan KSU will use to meet the requalification program requirements described in paragraphs 10 CFR 55.59(c)(l) through (c)(5), including any requirements met by requalification programs conducted by persons other than the facility licensee (e.g. UT ARR). As part of the discussion please include:
(1)
Identify each operator to which the plan will apply and the dates of applicability of the plan until requalification is resumed under the full KSU operator qualification and training plan.
(2)
As part of the exemption request, KSU stated, "additional [training]
actions would be performed by the licensee during the requested exemption period." Provide details on the content, type, frequency, and records for this training."
KSU Response:
The existing KSU Requalification Plan will continue to be used for items that can be completed at KSU for dates covered by the exemption period and applies to each of the following Senior Reactor Operators:
Alan Cebula, Docket# 055-70722 Amir Bahadori, Docket# 055-70720 Robert Seymour, Docket# 055-71404 The following summarizes how 10CFR55.59(c)(l) through (5) will be met for each of the previously identified Senior Reactor Operators:
Requalification Exemption Requalification Frequency Regulation Requested?
Program 10CFR55.59(c)(l)
No KSU Continuous 2-year program cycle Schedule 10CFR55.59(c)(2)
No KSU Preplanned, monthly lectures that cover lectures subjects 10CFR55.59(c)(2)(i) through (iv) and (vi) through (ix) inclusive and include review of operating and emergency procedures 10CFR55.59(c)(2)(v) Engineered safety systems is not applicable
10CFRSS.59(c)(3)(i)
Yes KSU Conducted during annual operating test, On-the-job training typically completed between August-
-Control November to accommodate academic manipulations calendar The test will cover items that can be completed during administrative restriction on operation. Emergency or abnormal conditions that are simulated will be documented with senior operator training records and include a description of the scenario and a summary of the simulated response including any procedures simulated.
See response to NRC information request
- 3 in this letter for additional detail.
10CFRSS.59(c)(3)(i)
Yes UTARR Training before administrative restriction On-the-job training on operations is cancelled.
-Control manipulations See response to NRC information request
- 3 in this letter for details on content.
10CFRSS.59(c)(3)(ii)
No KSU Conducted during annual operating test, On-the-job training typically completed between August-November to accommodate academic calendar Demonstrate understanding of apparatus and mechanisms associated with control manipulations and procedures Procedures covered in monthly lectures 10CFRSS.59(c)(3 )(ii)
No KSU additional Biweekly performance of Procedure No.
On-the-job training training 12 - Instrument Checkout during exemption period 10CFRSS.59( c) (3) (iii)
No KSU Continuous updates On-the-job training Changes in facility design, procedures, and facility license recorded in logbook and communicated to licensed operators 10CFRSS.59(c)(3)(iv)
No KSU Annual emergency procedure review On-the-job training typically completed between August-November to accommodate academic calendar Monthly normal and emergency procedure lectures.
10CFRSS.59(c)(3)(v)
N/A Not applicable On-the-job training 10CFRSS.59(c)(4)
Yes-KSU Annual written examination and Evaluation 10CFRSS.59( c)(4)(i) operating exam typically conducted August-November to accommodate academic calendar. Emergency or abnormal conditions that are simulated will be documented with senior operator training records and include a description of the scenario and a summary of the simulated response including any procedures simulated.
Monthly review of operations daily checkout logbooks Monthly lecture quiz results KSU Requalification Program 4.3 will be followed for evaluation.
10CFRSS.59(c)(4)
Yes-UTARR Training before administrative restriction Evaluation 10CFRSS.59(c)(4)(i) on operations is cancelled.
Evaluated as Satisfactory/Unsatisfactory by the trainer.
See response to NRC information request
- 3 in this letter for details on content 10CFRSS.59(c)(S)
No KSU Annual examinations including answers Records and evaluation Monthly lecture materials, attendance, and quiz Operation and daily checkout logbooks 10CFRSS.59(c)(S)
No UTARR Additional training before administrative Records restriction on operations is cancelled.
Copy of relevant operations logbook records, training materials, and evaluation.
- 3. NRC: "The KSU is requesting an exemption from "Requalification Program Section 3.2.1 Reactivity Manipulations and 10 CFR SS.59(c)(3)(i)." Provide detailed information about which aspects of 10 CFR SS.59(c)(3)(i) cannot be performed during the administrative restriction on operation, how they will be met at the alternative training program, or any related requirements for which KSU seeks an exemption."
KSU Response:
The following describes aspects of control manipulations from 10CFRSS.59(c)(3)(i) and operating test items from 10CFRSS.4S(a)(2) through (13) inclusive to the extent applicable to the facility as required by 10CFRSS.59(a)(2)(ii) that cannot be performed during the administrative restriction
- on operation and how they will be met at the alternative training program:
Control Manipulation / Test Alternative Training Item 10CFRSS.59(c)(3)(i)(A) Plant or Lecture over procedures and instrumentation.
reactor startups to include a range that reactivity feedback Perform 5 reactor startups to greater than 10 kW with integrated from nuclear heat addition is significant (>=10 percent) power changes in manual rod control noticeable and heatup rate is to 600 kW (current max power at KSU).
established.
10CFRSS.59(c)(3)(i)(B) Plant Lecture over procedures and instrumentation.
shutdown.
Perform 5 reactor shutdowns.
10CFRSS.59(c)(3)(i)(E)
Lecture over procedures and instrumentation.
Significant (>=10 percent) power changes in manual rod control Perform 5 reactor startups to greater than 10 kW with integrated or recirculation flow.
significant (>=10 percent) power changes in manual rod control to 600 kW (current max power at KSU).
10CFRSS.45(a)(2) Manipulate Perform 5 reactor startups to greater than 10 kW with integrated the console controls as required significant (>=10 percent) power changes in manual rod control to operate the facility between to 600 kW (current max power at KSU).
shutdown and designated power levels.
10CFRSS.4S(a)(S) Observe and Perform 5 reactor startups to greater than 10 kW with integrated safely control the operating significant (>=10 percent) power changes in manual rod control behavior characteristics of the to 600 kW (current max power at KSU).
facility.
10CFRSS.4S(a)(6) Perform Lecture over procedures and instrumentation.
control manipulations required to obtain desired operating Perform 5 reactor startups to greater than 10 kW with integrated results during normal, significant (>=10 percent) power changes in manual rod control abnormal, and emergency to 600 kW (current max power at KS_U).
situations.
Emergency or abnormal conditions that are simulated will not be conducted as part of the alternative training since it will be completed at KSU.
The following aspects of 10CFRSS.59(c)(3)(i) involve emergency or abnormal conditions and will be performed at KSU as simulations in accordance with/as provided by 10CFRSS.59(c)(4)(iv) and described in response to NRC information request #2 in this letter:
Control Manipulations and Plant Evolutions 10CFR55.59(c)(3)(i)(G) Loss of coolant, including-(3) Large and small, including leak-rate determination 10CFR55.59(c)(3)(i)(H) Loss of instrument air (if simulated plant specific).
10CFR55.59(c)(3)(i)(I) Loss of electrical power (or degraded power sources).
10CFR55.59(c)(3)(i)(J) Loss of core coolant flow/natural circulation.
10CFR55.59(c)(3)(i)(Q) Loss of protective system channel.
10CFR55.59(c)(3)(i)(R) Mispositioned control rod or rods (or rod drops).
10CFR55.59(c)(3)(i)(S) Inability to drive control rods.
10CFR55.59(c)(3)(i)(U) Fuel cladding failure or high activity in reactor coolant or offgas.
10CFR55.59(c)(3)(i)(W) Malfunction of an automatic control system that affects reactivity.
10CFR55.59(c)(3 )(i)(Y) Reactor trip.
10CFR55.59(c)(3)(i)(AA) A nuclear instrumentation failure.
The following aspects of 10CFR55.59(c)(3)(i) are not applicable to the KSU facility plant design and are not performed:
Control Manipulations and Plant Evolutions Not Applicable 10CFR55.59(c)(3)(i)(C) Manual control of steam generators or feedwater or both during startup and shutdown.
10CFR55.59(c)(3)(i)(D) Boration or dilution during power operation.
10CFR55.59(c)(3)(i)(F) Reactor power change of 10 percent or greater where load change is performed with load limit control or where flux, temperature, or speed control is on manual (for HTGR).
10CFR55.59(c)(3)(i)(G) Loss of coolant, including -
(1) Significant PWR steam generator leaks (2) Inside and outside primary containment (4) Saturated reactor coolant response (PWR).
10CFR55.59(c)(3)(i)(K) Loss of feedwater (normal and emergency).
10CFR55.59(c)(3)(i)(L) Loss of service water, if required for safety.
10CFR55.59(c)(3)(i)(M) Loss of shutdown cooling.
10CFR55.59(c)(3)(i)(N) Loss of component cooling system or cooling to an individual component.
10CFR55.59(c)(3)(i)(O) Loss of normal feedwater or normal feedwater system failure.
10CFR55.59(c)(3)(i)(P) Loss of condenser vacuum.
10CFR55.59(c)(3)(i)(T) Conditions requiring use of emergency boration or standby liquid control system.
10CFR55.59(c)(3)(i)(V) Turbine or generator trip.
10CFR55.59(c)(3)(i)(X) Malfunction of reactor coolant pressure/volume control system.
10CFR55.59(c)(3)(i)(Z) Main steam line break (inside or outside containment).
A comprehensive sample of the following items from 10CFR55.45(a) will be evaluated at KSU as part of the annual operating exam during the administrative restriction on operations:
Item 10CFRSS.45(a)(3) Identify annunciators and condition-indicating signals and perform appropriate remedial actions where appropriate.
10CFRSS.45(a)(4) Identify the instrumentation systems and significance of facility instrument readings.
10CFRSS.45(a)(7) Safely operate the facility's heat removal systems, including primary coolant, emergency coolant, and decay heat removal systems, and identify the relations of the proper operation of these systems to the operation of the facility.
10CFRSS.45(a)(8) Safely operate the facility's auxiliary and emergency systems, including operation of those controls associated with plant equipment that could affect reactivity or the release of radioactive materials to the environment.
10CFRSS.4S(a)(9) Demonstrate or describe the use and function of the facility's radiation monitoring systems, including fixed radiation monitors and alarms, portable survey instruments, and personnel monitoring equipment.
10CFRSS.45(a)(10) Demonstrate knowledge of significant radiation hazards, including permissible levels in excess of those authorized, and ability to perform other procedures to reduce excessive levels of radiation and to guard against personnel exposure.
10CFRSS.45(a)(ll) Demonstrate knowledge of the emergency plan for the facility, including, as appropriate, the operator's or senior operator's responsibility to decide whether the plan should be executed and the duties under the plan assigned.
10CFRSS.45(a)(12) Demonstrate the knowledge and ability as appropriate to the assigned position to assume the responsibilities associated with the safe operation of the facility.
10CFRSS.45(a)(13) Demonstrate the applicant's ability to function within the control room team as appropriate to the assigned position, in such a way that the facility licensee's procedures are adhered to and that the limitations in its license and amendments are not violated.
- 4.
NRC: "The exemption request, as supplemented, provided a requested end date of "30 days following the cancellation of the administrative restriction on operation related to the fuel issue." As written, this exemption has the potential to remain open for an indeterminate amount of time. Provide the maximum expected duration for this exemption request."
KSU Response:
Based on an estimated time to complete maintenance activities and additional training at another facility, the expected maximum duration for this exemption request is 120 days beyond the date the exemption is granted.
KSU requests the NRC issue exemption no later than 1 November 2024 for KSU to conduct Technical Specification required surveillance for inspecting core fuel and to continue fuel cleaning activities. This additional supplemental information has been reviewed and approved by the KSU Reactor Safeguards Committee.
- 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 Andrew Miller, NRC Project Manager