ML070820003

Kansas State University - Request for Additional Information and Assurance of Decommissioning Funding License R-88 Renewal

ML070820003
Person / Time
Site:	Kansas State University
Issue date:	03/29/2007
From:	Hughes D NRC/NRR/ADRA/DPR/PRTA
To:	Whaley M Kansas State University
Hughes, D, NRC/NRR/DRIP/RORP, 415-1631
References
TAC MC9031
Download: ML070820003 (7)

Text

March 29, 2007 Mr. Michael Whaley, Manager Nuclear Reactor Facility Department of Mechanical and Nuclear Engineering 112 Ward Hall Kansas State University Manhattan, KS 66506-5204

SUBJECT:

KANSAS STATE UNIVERSITY - REQUEST FOR ADDITIONAL INFORMATION AND ASSURANCE OF DECOMMISSIONING FUNDING RE: LICENSE R-88 RENEWAL (TAC NO. MC9031)

Dear Mr. Whaley:

We are continuing our review of your request for license renewal for the Kansas State University research reactor which you submitted on September 12, 2002. During our review of your license renewal request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information (RAI) within 30 days of the date of this letter.

In addition, your license renewal application included financial information pertaining to operation and decommissioning of the reactor. This letter does not satisfy the requirements for assurance of decommissioning funding for license renewal. The position of the NRC is that KSU has assurance from the State of Kansas for decommissioning funding under the current license, but updated assurance of decommissioning funding is required for license renewal.

Title 10 of the Code of Federal Regulations, Part 50.75(e)(iv) permits State licensees to provide assurance of decommissioning funding by a statement of intent containing a cost estimate for decommissioning, and indicating that funds for decommissioning will be obtained when necessary. The statement of intent must be signed by an official who has the authority to commit to spending the necessary funds to accomplish decommissioning, and it should be clearly asserted in the statement of intent that the signing official has that authority. In addition, the statement of intent should contain a statement that funding will be provided sufficiently in advance of decommissioning to prevent delay of required activities. If decommissioning funding is to continue to be assured by the State of Kansas, submit an updated statement of intent to this effect, signed by an appropriate State official. Otherwise, 10 CFR 50.75(e) provides alternate options for assurance of decommissioning funding. Please provide the necessary documentation within 30 days of the date of this letter.

Mr. Whaley In accordance with 10 CFR 50.30(b), your responses and the statement of intent must be executed in a signed original under oath or affirmation.

If you have any questions regarding this review, please contact me at 301-415-1631.

Sincerely,

/RA/

Daniel E. Hughes, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-188

Enclosure:

As stated cc w/ enclosure: Please see next page

Kansas State University Docket No. 50-188 cc:

Office of the Governor State of Kansas Topeka, KS 66612 Mayor of Manhattan P.O. Box 748 Manhattan, KS 66502 Thomas A. Conley, RRPJ, CHP, Section Chief Radiation and Asbestos Control KS Dept of Health & Environment 1000 SW Jackson, Suite 320 Topeka, KS 66612-1366 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

Mr. Whaley In accordance with 10 CFR 50.30(b), your responses and the statement of intent must be executed in a signed original under oath or affirmation.

If you have any questions regarding this review, please contact me at 301-415-1631.

Sincerely,

/RA/

Daniel E. Hughes, Project Manager Research and Test Reactors Branch A Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-188

Enclosure:

As stated cc w/ enclosure: Please see next page DISTRIBUTION:

PUBLIC PRTA r/f DHughes OGC MVoth MCase DCollins EHylton ADAMS ACCESSION NO: ML070820003 TEMPLATE #: NRR-088 OFFICE PRTA:PM PRTA:LA PRTA:BC PRTA:PM NAME DHughes:cah EHylton DCollins DHughes DATE 03/27/2007 03/29/2007 03/29/2007 03 /29/2007 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION KANSAS STATE UNIVERSITY RESEARCH REACTOR DOCKET NO. 50-188

1. Safety limit for aluminum-clad fuel, TS 2.1.3(2), is not discussed in SAR. The bases refer to SAR Section 3.5.1 but there is no discussion there for Al-clad. Please provide a basis statement.

2. The bases for TS 2.2.3(1) refers to a LSSS for power of 1,250 kW. If this is to be a scram setpoint, how then is the reactor operated at full licensed power of 1,250 kW?

(The LSSS is a scram setpoint that should take into account calibration error, instrument error, instrument response time, and scram time.)

3. TS 3.2.3(1) - Is operation above 1,250 kW prevented by this LCO as well as the LSSS in 2.2.3(1)?

TS 3.2.3(2) - Is the LCO of 250 kW if there are aluminum-clad fuel elements in the core.

Is this an administrative limit? Should this not be an LSSS also?

4. TS 3.2.3(2) - Is the application of air to the transient rod prevented by an interlock or is it administratively prevented? (See Table II of present TSs.)

5. TS 3.4.3(2) -The SAR describes the startup countrate interlock at 2 cps. Since the SAR is more conservative than the TS, justify the inconsistency. The conditions for allowing a bypassing of the interlock should be specified in the TS. (See Table II of the present TSs.) The description of neutron induced counts seems more precise since it assures that the signal and not the noise is observed.

6. TS 3.4.4G - Does a Startup Count rate < 1 cps mean the channel is not operating? The bases should describe why the 1 (or 2) cps is acceptable.

7. TS 3.5.3 - Table 2 indicates that the startup count rate interlock is a required safety system channel, but the startup channel is not listed as a required measuring channel (Table 1, TS 3.4.3). Please add this to the list of required measuring channels or, alternatively, provide a justification for not including this channel in TS 3.4.3, Table 1.

8. TS 3.5.3 - Table 2 does not include the simultaneous rod withdrawal interlock, the control rod position interlock (see last paragraph of TS 3.5.5), or the 10 kW pulse interlock. (See Table II of the present TSs.) The action statement, TS 3.5.4.C, includes the Transient Control Rod interlock. Is that the same as the control rod position interlock mentioned in the bases?

9. TS 3.5.5 - In the first paragraph, the fuel temperature safety limit stated as 1000EC is not consistent with specification TS 2.1.3 (1).

Second paragraph: Again, there is some confusion with regard to power level (1,250 kW) and LSSS.

ENCLOSURE

10. TS 3.6.5 - First paragraph references an exposure rate for Ar-41 of 1.84E-4 microcuries h/mL in SAR Chapter 11, Appendix A. We cant find this number (either in the original Appendix A or the March 2006 update.)

11. TS 3.7.5 refers to a fuel temperature LSSS. You have not specified a fuel temperature LSSS, in the TSs, only a power LSSS. Please provide a correct bases.

12. TS 3.9.4B has a typo. The water conductivity Condition statement should read ..shall be less than 5 micromho/cm and the Required Action statement B.2 should read Restore conductivity to less than 5 micromho/cm.

13. TS 3.9.3(3) reads: Water level above the core shall be at least 13 feet from the top of the core. Are you only taking credit for 13 ft of water for shielding during operation?

What Tsat are you using for the CHFR calculations? Is it based on 13 ft or 16 ft of water?

14. TS 3.9.4C -There is a number missing in the Condition statement.

15. TS 3.9.3 - It may well be true that, with 16 feet of water above the core, the contribution to pool surface dose rates from N-16 located below 13 feet of water is negligible. But what if there is only 13 feet of water above the core? Are the dose rates still negligible?

The 13 foot level needs to be justified.

16. TS 3.9.5 -There is a verb missing from the last sentence (.........the requirement

_verified prior.......).

17. TS 4.5.2 - The surveillances described in the Table do not include the simultaneous rod withdrawal interlock or the 10 kW interlock. Please add these surveillances to TS 4.5.2 or, alternatively, provide a justification for not including them.

18. TS 4.7.2 and TS 4.7.3 - Should the reactivity worth of $0.40 be an absolute value?

19. TS 4.9.2 - Does the requirement to measure pool water conductivity at least every 20 days also apply if the reactor is shut down? This is not clear from specification.

Provide a justification for not including a surveillance requirement for pool water activity to ensure that the total activity released can be determined if a release of pool water occurs.

20. TS 6.1a) -The SAR has undergone several versions. Please provide an organization chart to TS 6.1 or, alternatively, provide a justification for not including it?

21. TS 6.1a) and 6.1b) - One section refers to the University Radiation Safety Officer as URSO and the other refers to the same as RSO. Please make the TS consistent.

22. TS 6.2b)4 - The present version of 10 CFR 50.59 no longer talks about unreviewed safety questions. The wording should conform to 10 CFR 50.59(c)(1).

23. TS 6.4b)4 -Same comment as above.

24. TS 6.4c)2- Same comment as above.

25. TS 6.11c) - (Note typo, should be c, not d) Initial notification should also be made to Region, in accordance with 50.36(7)(ii). Also, TS 6.11(d) address should be changed to Director, Division of Policy and Rulemaking (ZIP 20555).

26. TS 3.8 does not allow a fuel element in the core with bend or elongation > 1/8 inch.

Please include surveillance in TS 4.8.3 to ensure that TS 3.8 is not violated.

27. TS 5.3.3 - Explain why Experiment Reactivity limits are not absolute values.

28. There should be a TS on fuel storage specifying < 0.9 Keff (see ANS 15.1, Sect.5.4).

Also see G.1 and G.2 of the present TSs.

29. TS 5.3 does not specify any limits on explosives (Section 2.d of Reg Guide 2.2). Please provide one or, alternatively, provide a justification for not including it.

30. TS 3.5.3 contains a typo (3" should be 2"). There is no action statement or basis for this specification. Please explain.

31. The thermal hydraulic analysis in the SAR uses 83 fuel elements, with the statement that this is conservative because more fuel elements will result in less heat production per element. If so, should there not be a TS specifying a minimum of 83 elements?

32. TS 6.4c)1 references section 3.8. Should this be sections 3.7, 4.7, and 5.3?

33. Are the equivalent of D.4 and D.5 of the present TSs in the new TSs?

34. Is there the equivalent of the last two sentences of D.6 of the present TSs in the new TSs?

35. Is there the equivalent of E.3 of the present TSs in the new TSs? How are the limits on pulsing handled if not by the maximum reactivity of the pulse rod?

36. Is there the equivalent of E.11.a of the present TSs in the new TSs?

37. Is there the equivalent of E.4 of the present TSs in the new TSs? TS 4.6.2 is not equivalent.

38. Are the equivalent of I.4 and I.5 of the present TSs in the new TSs?