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{{#Wiki_filter:Jeffrey Geuther, Ph.D.Nuclear Reactor Facility Manager3002 Rathbone HallKansas State University 66506US NRCAttn: Document Control DeskWashington, DC 20555-0001 13 January 2016
{{#Wiki_filter:Jeffrey Geuther, Ph.D.Nuclear Reactor Facility Manager 3002 Rathbone Hall Kansas State University 66506 US NRC Attn: Document Control Desk Washington, DC 20555-0001 13 January 2016  


==Subject:==
==Subject:==
 
2015 Annual Operating Report for the Kansas State University TRIGA Mark II Nuclear Reactor (Facility License # R-88, Facility Docket # 50-188)To Whom It May Concern: This document serves as the annual operating report for the Kansas State University (KSU) nuclear reactor. This document satisfies requirements in facility Technical Specifications (TS) 6.11 .e.The report is divided into paragraphs addressing specific items listed as requirements in the Technical Specifications.
2015 Annual Operating Report for the Kansas State University TRIGAMark II Nuclear Reactor (Facility License # R-88, Facility Docket # 50-188)To Whom It May Concern:This document serves as the annual operating report for the Kansas State University (KSU) nuclear reactor.
Sincerely, Jeffrey A. Geuther, Ph.D.Nuclear Reactor Facility Manager Kansas State University Attachments:
This document satisfies requirements in facility Technical Specifications (TS) 6.11 .e.The report is divided into paragraphs addressing specific items listed as requirements inthe Technical Specifications.
: 1. Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 2. 10CFR50.59 Screening Forms Cc: Spyros Traiforos, Project Manager, NRC Michael Morlang, Inspector,NRC ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 Introduction The Kansas State University Nuclear Reactor Technical Specifications (TS) require a routine written report to be transmitted to the US Nuclear Regulatory Commission within 60 days after completion of the first calendar year of operating, and at intervals not to exceed twelve months thereafter, providing the following information:
Sincerely, Jeffrey A. Geuther, Ph.D.Nuclear Reactor Facility ManagerKansas State University Attachments:
: 1. Kansas State University TRIGA Mark II Reactor Annual Report, CY 20152. 10CFR50.59 Screening FormsCc: Spyros Traiforos, Project Manager, NRCMichael Morlang, Inspector,NRC ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTKansas State University TRIGA Mark II Reactor AnnualReport, CY 2015Introduction The Kansas State University Nuclear Reactor Technical Specifications (TS) require aroutine written report to be transmitted to the US Nuclear Regulatory Commission within60 days after completion of the first calendar year of operating, and at intervals not toexceed twelve months thereafter, providing the following information:
TS.6.11.e.1  
TS.6.11.e.1  
-TS.6.11.e.2  
-TS.6.11.e.2  
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-TS.6.11l.e.6  
-TS.6.11l.e.6  
-TS.6.11 .e.7 -TS.6.11.e.8  
-TS.6.11 .e.7 -TS.6.11.e.8  
-A brief narrative summary of operating experience (including experiments performed),
-A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.
changes in facility design, performance characteristics, and operating procedures related to reactor safetyoccurring during the reporting period; and results of surveillance testsand inspections.
A tabulation showing the energy generated by the reactor (in megawatt-hours).The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of 10.CFR.50.59.
A tabulation showing the energy generated by the reactor (in megawatt-hours).The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.Discussion of the major maintenance operations performed during theperiod, including the effects, if any, on the safe operation of the reactor,and the reasons for any corrective maintenance required.
A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.
A summary of each change to the facility or procedures, tests, andexperiments carried out under the conditions of 10.CFR.50.59.
A description of any environmental surveys performed outside the facility.A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facilty.This information is transmitted in this report, in sections separated by TS clause. This report covers January 2015 -December 2015.Page 1 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT TS.6.11I .e.1 -A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.
A summary of the nature and amount of radioactive effluents released ordischarged to the environs beyond the effective control of the licensee asmeasured at or before the point of such release or discharge.
The KSU reactor operated for its usual purposes in CY2O015. Two reactor operations laboratory classes and a reactor theory laboratory class were supported, along with approximately 10 other courses with less frequent need of the reactor. 2214 visitors received access to the facility for various outreach activities, classes, and research experiments.
A description of any environmental surveys performed outside thefacility.
Typical experiments included prompt gamma neutron activation analysis (PGNAA), neutron activation analysis (NAA), neutron detector testing at beam ports, and gamma irradiation with decay gammas from the reactor core. In CY 2014, Experiment 52 -Fuel Element Reactivity Measurement was approved.
A summary of radiation exposures received by facility personnel andvisitors, including the dates and time of significant  
It had not been performed during CY20 14, but was performed for the first time in CY 2015. Experiment 52 allows for the measurement of integral fuel element worth using the positive period method with all rods out in a configuration in which the reactor can barely go supercritical prior to the addition of the test element.The NRC routine annual inspection was completed from June 22 -25t% 2015. No violations or inspector follow-up items were reported. (See Inspection Report No. 50-188/2015-201).
: exposure, and a briefsummary of the results of radiation and contamination surveys performed within the facilty.This information is transmitted in this report, in sections separated by TS clause. Thisreport covers January 2015 -December 2015.Page 1 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTTS.6.11I  
During the last quarter of 2015 the rate of water makeup to primary was noted to be higher than usual by approximately 70 gallons per week. The reactor staff identified a trickle of primary coolant water emanating from the thermal column and collecting in the reactor sump. As a result of the leak, a very small (< 1 mCi) amount of tritium was discharged from the facility.
.e.1 -A brief narrative summary of operating experience (including experiments performed),
The leak has been repaired by sealing the thermal colunmn with a gasketed aluminum plate.TS.6.I11.e.2  
changes in facility design,performance characteristics, and operating procedures related toreactor safety occurring during the reporting period; and results ofsurveillance tests and inspections.
-A tabulation showing the energy generated by the reactor (in megawatt-hours).
The KSU reactor operated for its usual purposes in CY2O015.
The monthly total energy generated by the KSU reactor is recorded in Table 1. The same data is shown as a bar chart in Figure 1. The total MWh of operation increased slightly from the prior year, from 48.2 MWh to 55.9 MWh.Page 2 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Table 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.Month MWh Burnup January February March April May June July August September October November December 1.4 2.1 7.2 9.1 1.8 10.3 8.5 3.4 0.7 4.6 5.8 1.0 TOTAL 55.9 Monthly Burnup (MWh), CY2O15 0.0 2,0 4.0 6.0 8.0 10.0 12,0 January February March April May June July August September October November December Figure 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.The reactor operated for a total of 635.2 hours during 2015, at an average power of 88 kW. Figure 2 shows the percentage of hours of reactor operation for various purposes, i.e., research support, training, education, etc. The percentage of hours for training appears small, because operator training was often performed when the reactor was being operated for another purpose, such as research support. The plot demonstrates that the reactor is operated in accordance with our stated primary functions:
Two reactor operations laboratory classes and a reactor theory laboratory class were supported, along withapproximately 10 other courses with less frequent need of the reactor.
education; research support (e.g., irradiation);
2214 visitorsreceived access to the facility for various outreach activities,  
operator training; and demonstration (e.g., tours). The percentage of time spent supporting experiments approximately doubled from 2014 (from 25% to 49%).Page 3 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Reactor Operations Hours by Purpose 2% 3%49%24%10%* Research U Tours *iClasses Maintenance 1Training 1Testing Figure 2 -KSU reactor hours, CY20 15, based on purpose of operation.
: classes, and researchexperiments.
Typical experiments included prompt gamma neutron activation analysis (PGNAA),neutron activation analysis (NAA), neutron detector testing at beam ports, and gammairradiation with decay gammas from the reactor core. In CY 2014, Experiment 52 -FuelElement Reactivity Measurement was approved.
It had not been performed duringCY20 14, but was performed for the first time in CY 2015. Experiment 52 allows for themeasurement of integral fuel element worth using the positive period method with allrods out in a configuration in which the reactor can barely go supercritical prior to theaddition of the test element.The NRC routine annual inspection was completed from June 22 -25t% 2015. Noviolations or inspector follow-up items were reported.  
(See Inspection Report No. 50-188/2015-201).
During the last quarter of 2015 the rate of water makeup to primary was noted to behigher than usual by approximately 70 gallons per week. The reactor staff identified atrickle of primary coolant water emanating from the thermal column and collecting in thereactor sump. As a result of the leak, a very small (< 1 mCi) amount of tritium wasdischarged from the facility.
The leak has been repaired by sealing the thermal colunmnwith a gasketed aluminum plate.TS.6.I11.e.2  
-A tabulation showing the energy generated by thereactor (in megawatt-hours).
The monthly total energy generated by the KSU reactor is recorded in Table 1. The samedata is shown as a bar chart in Figure 1. The total MWh of operation increased slightlyfrom the prior year, from 48.2 MWh to 55.9 MWh.Page 2 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTTable 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.Month MWh BurnupJanuaryFebruaryMarchAprilMayJuneJulyAugustSeptember OctoberNovemberDecember1.42.17.29.11.810.38.53.40.74.65.81.0TOTAL55.9Monthly Burnup (MWh), CY2O150.02,04.06.08.010.012,0JanuaryFebruaryMarchAprilMayJuneJulyAugustSeptember OctoberNovemberDecember Figure 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.The reactor operated for a total of 635.2 hours during 2015, at an average power of 88kW. Figure 2 shows the percentage of hours of reactor operation for various purposes, i.e., research  
: support, training, education, etc. The percentage of hours for trainingappears small, because operator training was often performed when the reactor was beingoperated for another purpose, such as research support.
The plot demonstrates that thereactor is operated in accordance with our stated primary functions:
education; researchsupport (e.g., irradiation);
operator training; and demonstration (e.g., tours). Thepercentage of time spent supporting experiments approximately doubled from 2014 (from25% to 49%).Page 3 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTReactor Operations Hours by Purpose2% 3%49%24%10%* Research U Tours *iClasses Maintenance 1Training 1TestingFigure 2 -KSU reactor hours, CY20 15, based on purpose of operation.
TS.6.11I.e.3  
TS.6.11I.e.3  
-The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any,taken.The following table documents the inadvertent S CRAMS and emergency shutdowns forCY 2015 at the KSU reactor.
-The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.The following table documents the inadvertent S CRAMS and emergency shutdowns for CY 2015 at the KSU reactor. Note that many SCRAMS were caused by problems with the NMP-1000 multirange linear power channel, which was eventually replaced with a spare on loan from WSU.Inadvertent S CRAMS adEe n hton 2/12/2015 Linear power No apparent cause_________scram 31162015Linar pwer NMP 1000 did not go to AUTO range when button 3/162015Linar pwer was pressed; scram occurred at ~1.1 W when scram switched between 100 mW range and 1 W range.3/1205Linear power Problem with NMP 1000, possibly a microscopic scram crack in a board (Faircloth Eng).4/7205Linear power NMP 1000 was in autorange, but tripped reactor scram when going between ranges.Low HV Scram Due to staff member moving a wire on back of 42/05(NPP 1000) control console.4/23/2015 Period scram No apparent cause 4/3205Linear power NMP 1000 was in autorange, but tripped when scram going between ranges Page 4 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT NMP 1000 caused trip when placed in 10 kW 4/9205Linear power range. Instrument was not responding to power 42/05scram changes. Trip was not repeatable.
Note that many SCRAMS were caused by problems withthe NMP-1000 multirange linear power channel, which was eventually replaced with aspare on loan from WSU.Inadvertent S CRAMS adEe n hton2/12/2015 Linear power No apparent cause_________scram 31162015Linar pwer NMP 1000 did not go to AUTO range when button3/162015Linar pwer was pressed; scram occurred at ~1.1 W whenscram switched between 100 mW range and 1 W range.3/1205Linear power Problem with NMP 1000, possibly a microscopic scram crack in a board (Faircloth Eng).4/7205Linear power NMP 1000 was in autorange, but tripped reactorscram when going between ranges.Low HV Scram Due to staff member moving a wire on back of42/05(NPP 1000) control console.4/23/2015 Period scram No apparent cause4/3205Linear power NMP 1000 was in autorange, but tripped whenscram going between rangesPage 4 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTNMP 1000 caused trip when placed in 10 kW4/9205Linear power range. Instrument was not responding to power42/05scram changes.
10/20/2015 Period scram Operator error 10/27/2015 Period scram Operator error by trainee 11/5/2015 Period scram Operator error by trainee 11/19/2015 Period scram Operator error by trainee 11/20/2015 Period scram Operator error by trainee TS.6.11I.e.4  
Trip was not repeatable.
-Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.No major maintenance operations affected the safe operation of the reactor. The following major maintenance activities occurred:* Replaced the NMP-1000 multi-range linear power channel with a spare unit on loan from Washington State University.
10/20/2015 Period scram Operator error10/27/2015 Period scram Operator error by trainee11/5/2015 Period scram Operator error by trainee11/19/2015 Period scram Operator error by trainee11/20/2015 Period scram Operator error by traineeTS.6.11I.e.4  
-Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safeoperation of the reactor, and the reasons for any corrective maintenance required.
No major maintenance operations affected the safe operation of the reactor.
Thefollowing major maintenance activities occurred:
* Replaced the NMP-1000 multi-range linear power channel with a spare unit onloan from Washington State University.
* Replaced the regulating and shim rod drive assemblies.
* Replaced the regulating and shim rod drive assemblies.
* Repaired automatic flux control system.* Remote range switch installed on NMP-1000.
* Repaired automatic flux control system.* Remote range switch installed on NMP-1000.* Digital board in WSU NMP-1000 replaced with digital board from KSU NMP-1000.* Replacement of the manual winch used to operate the thermal column door with two electrical winches.* Began work on water leak repair in thermal column. (Work completed on 1/8/2016).
* Digital board in WSU NMP-1000 replaced with digital board from KSU NMP-1000.* Replacement of the manual winch used to operate the thermal column door withtwo electrical winches.* Began work on water leak repair in thermal column. (Work completed on1/8/2016).
TS.6.11I .e.5 -A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of I0CFR-50.59.The following change was carried out under 10CFR-50.59:
TS.6.11I  
The manual winch which operated the thermal column door was replaced with two electrical winches. The 50.59 screening form used to evaluate this change is enclosed with this report.TS.6.11I .e.6 -A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.
.e.5 -A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of I0CFR-50.59.The following change was carried out under 10CFR-50.59:
Per procedure, the radioisotope inventory and concentration were calculated prior to discharge, showing both to be well below the limits in 10CFR-20: Page 5 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Avg. Limit* Total Concentration (lpCi / Volume Total Activity Isotope (Ci / mL) mE) (mL) Released (Ci)Alpha-emitters 6.11E-11 N/A 5.OE-2 3 H 7.01E-12 1.00E-02 1.47E7 2.8E-4 14 5.57E-12 3.00E-04 8.3E-5 3 2 p 3.70E-12 9.00E-05 4.8E-5*10CFR-.20, App.B The only other discharges beyond the facility boundary were HVAC condensate discharges to the samitary sewer. Since the Kansas State University average water usage is 750,000 gallons per day, it is nearly impossible to exceed 10OCFR20 limits for effluent concentration at the KSU reactor. HVAC condensate water is never circulated through or near the reactor core and historically radiation levels in HVAC condensate are near background levels.TS.6.11I .e.7 -A description of any environmental surveys performed outside the facility.Monthly radiation surveys are performed within the facility to verify that radiation levels remain safe when at full-power operation.
The manual winch which operated the thermal column door was replaced with twoelectrical winches.
These surveys indicate that the dose rate at the inside surface of the reactor dome does not exceed the hourly dose limit to members of the public of 2 mR / h, as set forth in 10CFR-20, which indicates that the outside dose cannot exceed this limit.TS.6.11I .e..8 -A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facility.A table showing the number of workers receiving given amounts of dose is presented below. The total is given through the end of November, since the dosimetry results for December have not been received yet. Note that no worker received a shallow dose equivalent, deep dose equivalent, or lens dose equivalent in excess of 100 mrem. This shows that the facility radiation protection program has continued to be successful in keeping occupational doses as low as reasonably achievable.
The 50.59 screening form used to evaluate this change is enclosedwith this report.TS.6.11I  
Table 2 -Summary of total occupational dose received by KSU reactor workers from 1/1/2015 -11/30/2015. (Data for December 2015 is not yet available).
.e.6 -A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of suchrelease or discharge.
mrem DDE LDE SDE (0, 10] 2 2 2 (10, 201 0 0 0 (20, 30] 4 3 3 (30, 40] 4 5 4 (40, 50] 3 2 2>50 3 4 5>100 0 0 0 Page 6 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Visitor dose at the KSU TRIGA reactor facility is measured using Civil Defense self-indicating pocket dosimeters, with an indication range from 0-200 mR. Self-indicated pocket dosimeter readings suffer from imprecision due to parallax error, sometimes resulting in negative values or readings above the true value.2015 Visitor Exposure Records 10000'S as I C 1000 100 10 1 Exposure [mR]Figure 3 -Visitor exposure records from CY 2015.All radiation surveys and contamination surveys conducted at the facility in 2015 were nominal.This concludes the 2015 Annual Report for the Kansas State University TRIGA Mark II Nuclear Reactor.Page 7 of 7 SOM 5 ATTACHMENT 2 Onia 7/05/06 Evaluation of Change, Program Effectiveness I Page 1 of 3 TITLE Replace Thermal Column DATE 12/23/2015 Winch DESCRIPTION Replace manual winch with two 3.5 HP 12 VDC winches SCREENING:
Per procedure, the radioisotope inventory and concentration were calculated prior todischarge, showing both to be well below the limits in 10CFR-20:
The following guidance provides criteria to screen the proposed change from further assessing need for NRC review. If the change does not affect (1) a design function of SSC, (2) a method of performing or controlling design function, (3) evaluation for demonstrating the design function will be accomplished, then it is not necessary to continue the evaluation.
Page 5 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTAvg. Limit* TotalConcentration (lpCi / Volume Total ActivityIsotope (Ci / mL) mE) (mL) Released (Ci)Alpha-emitters 6.11E-11 N/A 5.OE-23H 7.01E-12 1.00E-02 1.47E7 2.8E-414 5.57E-12 3.00E-04 8.3E-532p 3.70E-12 9.00E-05 4.8E-5*10CFR-.20, App.BThe only other discharges beyond the facility boundary were HVAC condensate discharges to the samitary sewer. Since the Kansas State University average water usageis 750,000 gallons per day, it is nearly impossible to exceed 10OCFR20 limits for effluentconcentration at the KSU reactor.
HVAC condensate water is never circulated through ornear the reactor core and historically radiation levels in HVAC condensate are nearbackground levels.TS.6.11I  
.e.7 -A description of any environmental surveys performed outside the facility.
Monthly radiation surveys are performed within the facility to verify that radiation levelsremain safe when at full-power operation.
These surveys indicate that the dose rate at theinside surface of the reactor dome does not exceed the hourly dose limit to members ofthe public of 2 mR / h, as set forth in 10CFR-20, which indicates that the outside dosecannot exceed this limit.TS.6.11I  
.e..8 -A summary of radiation exposures received by facilitypersonnel and visitors, including the dates and time of significant
: exposure, and a brief summary of the results of radiation andcontamination surveys performed within the facility.
A table showing the number of workers receiving given amounts of dose is presented below. The total is given through the end of November, since the dosimetry results forDecember have not been received yet. Note that no worker received a shallow doseequivalent, deep dose equivalent, or lens dose equivalent in excess of 100 mrem. Thisshows that the facility radiation protection program has continued to be successful inkeeping occupational doses as low as reasonably achievable.
Table 2 -Summary of total occupational dose received by KSU reactor workers from 1/1/2015  
-11/30/2015.  
(Data for December 2015 is not yet available).
mrem DDE LDE SDE(0, 10] 2 2 2(10, 201 0 0 0(20, 30] 4 3 3(30, 40] 4 5 4(40, 50] 3 2 2>50 3 4 5>100 0 0 0Page 6 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTVisitor dose at the KSU TRIGA reactor facility is measured using Civil Defense self-indicating pocket dosimeters, with an indication range from 0-200 mR. Self-indicated pocket dosimeter readings suffer from imprecision due to parallax error, sometimes resulting in negative values or readings above the true value.2015 Visitor Exposure Records10000'SasIC1000100101Exposure
[mR]Figure 3 -Visitor exposure records from CY 2015.All radiation surveys and contamination surveys conducted at the facility in 2015 werenominal.This concludes the 2015 Annual Report for the Kansas State University TRIGA Mark IINuclear Reactor.Page 7 of 7 SOM 5 ATTACHMENT 2 Onia 7/05/06Evaluation of Change, Program Effectiveness I Page 1 of 3TITLE Replace Thermal Column DATE 12/23/2015 WinchDESCRIPTION Replace manual winch with two 3.5 HP 12 VDC winchesSCREENING:
The following guidance provides criteria to screen the proposed change fromfurther assessing need for NRC review. If the change does not affect (1) a design function ofSSC, (2) a method of performing or controlling design function, (3) evaluation for demonstrating the design function will be accomplished, then it is not necessary to continue the evaluation.
SSC Affected ISSC Design function IFailure Mode(s) IAccident scenario(s)
SSC Affected ISSC Design function IFailure Mode(s) IAccident scenario(s)
SAFETY ANALY}SIS  
SAFETY ANALY}SIS  
& A CCIDENT RESPONSE/MITIGA TION YES NODecrease SSC design function reliability when failure would initiate an accident
& A CCIDENT RESPONSE/MITIGA TION YES NO Decrease SSC design function reliability when failure would initiate an accident ____ X Decrease SSC design function reliability when failure would mitigate accident ____ X Reduce redundancy, reliability or defense in depth ____ X Add or delete an automatic or manual design function of an SSC ____ X HUMAN INTERFACE YES NO Convert an automatic feature to manual or vice versa X ___Adversely affect ability to perform required actions _ __ X Adversely affect time response of required actions ____ X INTERFACE OUTSIDE THE PROPOSED CHANGE YES NO Degrade seismic or environmental qualification X Affect method of evaluation used to establish design basis or safety analysis X Introduce an unwanted or previously unreveiwed system or material interaction X (Not described in SAR) indirect effects on electrical distribution X (Not described in SAR) indirect effects structural integrity
____ XDecrease SSC design function reliability when failure would mitigate accident
____ X (Not described in SAR) indirect effects on environmental conditions X (Not described inSAR) indirect effects on other SAR design functions X COMMENTS: PERFORMED BY: ___Geuther DATE 12/23/2015 If any of the above answers are YES, then proceed to the EVALUATION section.
____ XReduce redundancy, reliability or defense in depth ____ XAdd or delete an automatic or manual design function of an SSC ____ XHUMAN INTERFACE YES NOConvert an automatic feature to manual or vice versa X ___Adversely affect ability to perform required actions _ __ XAdversely affect time response of required actions ____ XINTERFACE OUTSIDE THE PROPOSED CHANGE YES NODegrade seismic or environmental qualification XAffect method of evaluation used to establish design basis or safety analysis XIntroduce an unwanted or previously unreveiwed system or material interaction X(Not described in SAR) indirect effects on electrical distribution X(Not described in SAR) indirect effects structural integrity
SOM 5 ATT-ACHMENT 2 On Oiinal 7/05/06 Evaluation of Change, Program Effectiveness Page 2 of 3 Evaluation
____ X(Not described in SAR) indirect effects on environmental conditions X(Not described inSAR) indirect effects on other SAR design functions XCOMMENTS:
[Result in more than a minimal increase in the frequency of occurrence of an Yes No accident previously evaluated inl the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivit Addition LOCA Fuel Handling Result in more than a minimal increase in the likelihood of occurrence of a YYes No malfunction in a structure, system, or component (SSC) important to safetyX-previously evaluated in the final Safety Analysis Report AFFECTED SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION Result in more than a minimal increase in the consequences of an accident Yes No previously evaluated in the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivity Addition _____________________________
PERFORMED BY: ___Geuther DATE 12/23/2015 If any of the above answers are YES, then proceed to the EVALUATION section.
SOM 5 ATT-ACHMENT 2 On Oiinal 7/05/06Evaluation of Change, Program Effectiveness Page 2 of 3Evaluation
[Result in more than a minimal increase in the frequency of occurrence of an Yes Noaccident previously evaluated inl the final Safety Analysis Report xACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivit AdditionLOCAFuel HandlingResult in more than a minimal increase in the likelihood of occurrence of a YYes Nomalfunction in a structure, system, or component (SSC) important to safetyX-previously evaluated in the final Safety Analysis ReportAFFECTED SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION Result in more than a minimal increase in the consequences of an accident Yes Nopreviously evaluated in the final Safety Analysis Report xACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivity Addition
_____________________________
LOCA ___________________
LOCA ___________________
Fuel Handling__
Fuel Handling__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Result in more than a minimal increase in the consequences of a malfunction in a Ys Nstructure, system, or component (SSC) important to safety previously evaluated inr ixthe final Safety Analysis ReportAFFECTED SSCAFFECTD SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION SOM 5 ATTACHMENT 2 On na 7/05/06Evaluation of Change, Program Effectiveness
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Result in more than a minimal increase in the consequences of a malfunction in a Ys N structure, system, or component (SSC) important to safety previously evaluated inr ix the final Safety Analysis Report AFFECTED SSC AFFECTD SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION SOM 5 ATTACHMENT 2 On na 7/05/06 Evaluation of Change, Program Effectiveness
_[ Page 3 of 3Create a possibility for an accident of a different type than any previously Yes Noevaluated in the final Safety Analysis Report L xNEW /DIFFERENT TYPE OF ACCIDENT (INCLUDING LIKELIHOOD AND[Create a possibility for a malfunction of an SSC important to safety with a IYes Nodifferent result than any previously evaluated in the final Safety Analysis Report I xACCIDENT AFFECTED SSC__________
_[ Page 3 of 3 Create a possibility for an accident of a different type than any previously Yes No evaluated in the final Safety Analysis Report L x NEW /DIFFERENT TYPE OF ACCIDENT (INCLUDING LIKELIHOOD AND[Create a possibility for a malfunction of an SSC important to safety with a IYes No different result than any previously evaluated in the final Safety Analysis Report I x ACCIDENT AFFECTED SSC__________
Reactivity Addition__
Reactivity Addition__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _LOCA__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Fuel Handling__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _LOCA__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Fuel Handling__
_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Other__ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Result in design basis limit for fission product barrier as described in the SAR IYsNbeing exceeded or altered I X_____________REFERENCE I//TEXT I VALUEDesign Basis Limit _____________________
_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Other__ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Result in design basis limit for fission product barrier as described in the SAR IYsN being exceeded or altered I X_____________REFERENCE I//TEXT I VALUE Design Basis Limit _____________________
_____________________
Analysis
_____________________
_____________________
Analysis _____________________
_____________________
_____________________
~Approach to Limit_ _ __ _j_ _ _ _ _Result in a departure from a method of evaluation described in the SAR used in YsNestablishing design bases or in the safety analyses I xREFERENCE I//TEXT VALUEDesign Basis Limit _____________
~Approach to Limit_ _ __ _j_ _ _ _ _Result in a departure from a method of evaluation described in the SAR used in YsN establishing design bases or in the safety analyses I x REFERENCE I//TEXT VALUE Design Basis Limit _____________
New Analysis________
New Analysis________
_____Coinparison
_____Coinparison
____________
____________
Jeffrey Geuther, Ph.D.Nuclear Reactor Facility Manager3002 Rathbone HallKansas State University 66506US NRCAttn: Document Control DeskWashington, DC 20555-0001 13 January 2016
Jeffrey Geuther, Ph.D.Nuclear Reactor Facility Manager 3002 Rathbone Hall Kansas State University 66506 US NRC Attn: Document Control Desk Washington, DC 20555-0001 13 January 2016  


==Subject:==
==Subject:==
 
2015 Annual Operating Report for the Kansas State University TRIGA Mark II Nuclear Reactor (Facility License # R-88, Facility Docket # 50-188)To Whom It May Concern: This document serves as the annual operating report for the Kansas State University (KSU) nuclear reactor. This document satisfies requirements in facility Technical Specifications (TS) 6.11 .e.The report is divided into paragraphs addressing specific items listed as requirements in the Technical Specifications.
2015 Annual Operating Report for the Kansas State University TRIGAMark II Nuclear Reactor (Facility License # R-88, Facility Docket # 50-188)To Whom It May Concern:This document serves as the annual operating report for the Kansas State University (KSU) nuclear reactor.
Sincerely, Jeffrey A. Geuther, Ph.D.Nuclear Reactor Facility Manager Kansas State University Attachments:
This document satisfies requirements in facility Technical Specifications (TS) 6.11 .e.The report is divided into paragraphs addressing specific items listed as requirements inthe Technical Specifications.
: 1. Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 2. 10CFR50.59 Screening Forms Cc: Spyros Traiforos, Project Manager, NRC Michael Morlang, Inspector,NRC ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 Introduction The Kansas State University Nuclear Reactor Technical Specifications (TS) require a routine written report to be transmitted to the US Nuclear Regulatory Commission within 60 days after completion of the first calendar year of operating, and at intervals not to exceed twelve months thereafter, providing the following information:
Sincerely, Jeffrey A. Geuther, Ph.D.Nuclear Reactor Facility ManagerKansas State University Attachments:
: 1. Kansas State University TRIGA Mark II Reactor Annual Report, CY 20152. 10CFR50.59 Screening FormsCc: Spyros Traiforos, Project Manager, NRCMichael Morlang, Inspector,NRC ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTKansas State University TRIGA Mark II Reactor AnnualReport, CY 2015Introduction The Kansas State University Nuclear Reactor Technical Specifications (TS) require aroutine written report to be transmitted to the US Nuclear Regulatory Commission within60 days after completion of the first calendar year of operating, and at intervals not toexceed twelve months thereafter, providing the following information:
TS.6.11.e.1  
TS.6.11.e.1  
-TS.6.11.e.2  
-TS.6.11.e.2  
Line 127: Line 87:
-TS.6.11l.e.6  
-TS.6.11l.e.6  
-TS.6.11 .e.7 -TS.6.11.e.8  
-TS.6.11 .e.7 -TS.6.11.e.8  
-A brief narrative summary of operating experience (including experiments performed),
-A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.
changes in facility design, performance characteristics, and operating procedures related to reactor safetyoccurring during the reporting period; and results of surveillance testsand inspections.
A tabulation showing the energy generated by the reactor (in megawatt-hours).The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of 10.CFR.50.59.
A tabulation showing the energy generated by the reactor (in megawatt-hours).The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.Discussion of the major maintenance operations performed during theperiod, including the effects, if any, on the safe operation of the reactor,and the reasons for any corrective maintenance required.
A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.
A summary of each change to the facility or procedures, tests, andexperiments carried out under the conditions of 10.CFR.50.59.
A description of any environmental surveys performed outside the facility.A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facilty.This information is transmitted in this report, in sections separated by TS clause. This report covers January 2015 -December 2015.Page 1 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT TS.6.11I .e.1 -A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.
A summary of the nature and amount of radioactive effluents released ordischarged to the environs beyond the effective control of the licensee asmeasured at or before the point of such release or discharge.
The KSU reactor operated for its usual purposes in CY2O015. Two reactor operations laboratory classes and a reactor theory laboratory class were supported, along with approximately 10 other courses with less frequent need of the reactor. 2214 visitors received access to the facility for various outreach activities, classes, and research experiments.
A description of any environmental surveys performed outside thefacility.
Typical experiments included prompt gamma neutron activation analysis (PGNAA), neutron activation analysis (NAA), neutron detector testing at beam ports, and gamma irradiation with decay gammas from the reactor core. In CY 2014, Experiment 52 -Fuel Element Reactivity Measurement was approved.
A summary of radiation exposures received by facility personnel andvisitors, including the dates and time of significant  
It had not been performed during CY20 14, but was performed for the first time in CY 2015. Experiment 52 allows for the measurement of integral fuel element worth using the positive period method with all rods out in a configuration in which the reactor can barely go supercritical prior to the addition of the test element.The NRC routine annual inspection was completed from June 22 -25t% 2015. No violations or inspector follow-up items were reported. (See Inspection Report No. 50-188/2015-201).
: exposure, and a briefsummary of the results of radiation and contamination surveys performed within the facilty.This information is transmitted in this report, in sections separated by TS clause. Thisreport covers January 2015 -December 2015.Page 1 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTTS.6.11I  
During the last quarter of 2015 the rate of water makeup to primary was noted to be higher than usual by approximately 70 gallons per week. The reactor staff identified a trickle of primary coolant water emanating from the thermal column and collecting in the reactor sump. As a result of the leak, a very small (< 1 mCi) amount of tritium was discharged from the facility.
.e.1 -A brief narrative summary of operating experience (including experiments performed),
The leak has been repaired by sealing the thermal colunmn with a gasketed aluminum plate.TS.6.I11.e.2  
changes in facility design,performance characteristics, and operating procedures related toreactor safety occurring during the reporting period; and results ofsurveillance tests and inspections.
-A tabulation showing the energy generated by the reactor (in megawatt-hours).
The KSU reactor operated for its usual purposes in CY2O015.
The monthly total energy generated by the KSU reactor is recorded in Table 1. The same data is shown as a bar chart in Figure 1. The total MWh of operation increased slightly from the prior year, from 48.2 MWh to 55.9 MWh.Page 2 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Table 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.Month MWh Burnup January February March April May June July August September October November December 1.4 2.1 7.2 9.1 1.8 10.3 8.5 3.4 0.7 4.6 5.8 1.0 TOTAL 55.9 Monthly Burnup (MWh), CY2O15 0.0 2,0 4.0 6.0 8.0 10.0 12,0 January February March April May June July August September October November December Figure 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.The reactor operated for a total of 635.2 hours during 2015, at an average power of 88 kW. Figure 2 shows the percentage of hours of reactor operation for various purposes, i.e., research support, training, education, etc. The percentage of hours for training appears small, because operator training was often performed when the reactor was being operated for another purpose, such as research support. The plot demonstrates that the reactor is operated in accordance with our stated primary functions:
Two reactor operations laboratory classes and a reactor theory laboratory class were supported, along withapproximately 10 other courses with less frequent need of the reactor.
education; research support (e.g., irradiation);
2214 visitorsreceived access to the facility for various outreach activities,  
operator training; and demonstration (e.g., tours). The percentage of time spent supporting experiments approximately doubled from 2014 (from 25% to 49%).Page 3 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Reactor Operations Hours by Purpose 2% 3%49%24%10%* Research U Tours *iClasses Maintenance 1Training 1Testing Figure 2 -KSU reactor hours, CY20 15, based on purpose of operation.
: classes, and researchexperiments.
Typical experiments included prompt gamma neutron activation analysis (PGNAA),neutron activation analysis (NAA), neutron detector testing at beam ports, and gammairradiation with decay gammas from the reactor core. In CY 2014, Experiment 52 -FuelElement Reactivity Measurement was approved.
It had not been performed duringCY20 14, but was performed for the first time in CY 2015. Experiment 52 allows for themeasurement of integral fuel element worth using the positive period method with allrods out in a configuration in which the reactor can barely go supercritical prior to theaddition of the test element.The NRC routine annual inspection was completed from June 22 -25t% 2015. Noviolations or inspector follow-up items were reported.  
(See Inspection Report No. 50-188/2015-201).
During the last quarter of 2015 the rate of water makeup to primary was noted to behigher than usual by approximately 70 gallons per week. The reactor staff identified atrickle of primary coolant water emanating from the thermal column and collecting in thereactor sump. As a result of the leak, a very small (< 1 mCi) amount of tritium wasdischarged from the facility.
The leak has been repaired by sealing the thermal colunmnwith a gasketed aluminum plate.TS.6.I11.e.2  
-A tabulation showing the energy generated by thereactor (in megawatt-hours).
The monthly total energy generated by the KSU reactor is recorded in Table 1. The samedata is shown as a bar chart in Figure 1. The total MWh of operation increased slightlyfrom the prior year, from 48.2 MWh to 55.9 MWh.Page 2 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTTable 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.Month MWh BurnupJanuaryFebruaryMarchAprilMayJuneJulyAugustSeptember OctoberNovemberDecember1.42.17.29.11.810.38.53.40.74.65.81.0TOTAL55.9Monthly Burnup (MWh), CY2O150.02,04.06.08.010.012,0JanuaryFebruaryMarchAprilMayJuneJulyAugustSeptember OctoberNovemberDecember Figure 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.The reactor operated for a total of 635.2 hours during 2015, at an average power of 88kW. Figure 2 shows the percentage of hours of reactor operation for various purposes, i.e., research  
: support, training, education, etc. The percentage of hours for trainingappears small, because operator training was often performed when the reactor was beingoperated for another purpose, such as research support.
The plot demonstrates that thereactor is operated in accordance with our stated primary functions:
education; researchsupport (e.g., irradiation);
operator training; and demonstration (e.g., tours). Thepercentage of time spent supporting experiments approximately doubled from 2014 (from25% to 49%).Page 3 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTReactor Operations Hours by Purpose2% 3%49%24%10%* Research U Tours *iClasses Maintenance 1Training 1TestingFigure 2 -KSU reactor hours, CY20 15, based on purpose of operation.
TS.6.11I.e.3  
TS.6.11I.e.3  
-The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any,taken.The following table documents the inadvertent S CRAMS and emergency shutdowns forCY 2015 at the KSU reactor.
-The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.The following table documents the inadvertent S CRAMS and emergency shutdowns for CY 2015 at the KSU reactor. Note that many SCRAMS were caused by problems with the NMP-1000 multirange linear power channel, which was eventually replaced with a spare on loan from WSU.Inadvertent S CRAMS adEe n hton 2/12/2015 Linear power No apparent cause_________scram 31162015Linar pwer NMP 1000 did not go to AUTO range when button 3/162015Linar pwer was pressed; scram occurred at ~1.1 W when scram switched between 100 mW range and 1 W range.3/1205Linear power Problem with NMP 1000, possibly a microscopic scram crack in a board (Faircloth Eng).4/7205Linear power NMP 1000 was in autorange, but tripped reactor scram when going between ranges.Low HV Scram Due to staff member moving a wire on back of 42/05(NPP 1000) control console.4/23/2015 Period scram No apparent cause 4/3205Linear power NMP 1000 was in autorange, but tripped when scram going between ranges Page 4 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT NMP 1000 caused trip when placed in 10 kW 4/9205Linear power range. Instrument was not responding to power 42/05scram changes. Trip was not repeatable.
Note that many SCRAMS were caused by problems withthe NMP-1000 multirange linear power channel, which was eventually replaced with aspare on loan from WSU.Inadvertent S CRAMS adEe n hton2/12/2015 Linear power No apparent cause_________scram 31162015Linar pwer NMP 1000 did not go to AUTO range when button3/162015Linar pwer was pressed; scram occurred at ~1.1 W whenscram switched between 100 mW range and 1 W range.3/1205Linear power Problem with NMP 1000, possibly a microscopic scram crack in a board (Faircloth Eng).4/7205Linear power NMP 1000 was in autorange, but tripped reactorscram when going between ranges.Low HV Scram Due to staff member moving a wire on back of42/05(NPP 1000) control console.4/23/2015 Period scram No apparent cause4/3205Linear power NMP 1000 was in autorange, but tripped whenscram going between rangesPage 4 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTNMP 1000 caused trip when placed in 10 kW4/9205Linear power range. Instrument was not responding to power42/05scram changes.
10/20/2015 Period scram Operator error 10/27/2015 Period scram Operator error by trainee 11/5/2015 Period scram Operator error by trainee 11/19/2015 Period scram Operator error by trainee 11/20/2015 Period scram Operator error by trainee TS.6.11I.e.4  
Trip was not repeatable.
-Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.No major maintenance operations affected the safe operation of the reactor. The following major maintenance activities occurred:* Replaced the NMP-1000 multi-range linear power channel with a spare unit on loan from Washington State University.
10/20/2015 Period scram Operator error10/27/2015 Period scram Operator error by trainee11/5/2015 Period scram Operator error by trainee11/19/2015 Period scram Operator error by trainee11/20/2015 Period scram Operator error by traineeTS.6.11I.e.4  
-Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safeoperation of the reactor, and the reasons for any corrective maintenance required.
No major maintenance operations affected the safe operation of the reactor.
Thefollowing major maintenance activities occurred:
* Replaced the NMP-1000 multi-range linear power channel with a spare unit onloan from Washington State University.
* Replaced the regulating and shim rod drive assemblies.
* Replaced the regulating and shim rod drive assemblies.
* Repaired automatic flux control system.* Remote range switch installed on NMP-1000.
* Repaired automatic flux control system.* Remote range switch installed on NMP-1000.* Digital board in WSU NMP-1000 replaced with digital board from KSU NMP-1000.* Replacement of the manual winch used to operate the thermal column door with two electrical winches.* Began work on water leak repair in thermal column. (Work completed on 1/8/2016).
* Digital board in WSU NMP-1000 replaced with digital board from KSU NMP-1000.* Replacement of the manual winch used to operate the thermal column door withtwo electrical winches.* Began work on water leak repair in thermal column. (Work completed on1/8/2016).
TS.6.11I .e.5 -A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of I0CFR-50.59.The following change was carried out under 10CFR-50.59:
TS.6.11I  
The manual winch which operated the thermal column door was replaced with two electrical winches. The 50.59 screening form used to evaluate this change is enclosed with this report.TS.6.11I .e.6 -A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.
.e.5 -A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of I0CFR-50.59.The following change was carried out under 10CFR-50.59:
Per procedure, the radioisotope inventory and concentration were calculated prior to discharge, showing both to be well below the limits in 10CFR-20: Page 5 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Avg. Limit* Total Concentration (lpCi / Volume Total Activity Isotope (Ci / mL) mE) (mL) Released (Ci)Alpha-emitters 6.11E-11 N/A 5.OE-2 3 H 7.01E-12 1.00E-02 1.47E7 2.8E-4 14 5.57E-12 3.00E-04 8.3E-5 3 2 p 3.70E-12 9.00E-05 4.8E-5*10CFR-.20, App.B The only other discharges beyond the facility boundary were HVAC condensate discharges to the samitary sewer. Since the Kansas State University average water usage is 750,000 gallons per day, it is nearly impossible to exceed 10OCFR20 limits for effluent concentration at the KSU reactor. HVAC condensate water is never circulated through or near the reactor core and historically radiation levels in HVAC condensate are near background levels.TS.6.11I .e.7 -A description of any environmental surveys performed outside the facility.Monthly radiation surveys are performed within the facility to verify that radiation levels remain safe when at full-power operation.
The manual winch which operated the thermal column door was replaced with twoelectrical winches.
These surveys indicate that the dose rate at the inside surface of the reactor dome does not exceed the hourly dose limit to members of the public of 2 mR / h, as set forth in 10CFR-20, which indicates that the outside dose cannot exceed this limit.TS.6.11I .e..8 -A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facility.A table showing the number of workers receiving given amounts of dose is presented below. The total is given through the end of November, since the dosimetry results for December have not been received yet. Note that no worker received a shallow dose equivalent, deep dose equivalent, or lens dose equivalent in excess of 100 mrem. This shows that the facility radiation protection program has continued to be successful in keeping occupational doses as low as reasonably achievable.
The 50.59 screening form used to evaluate this change is enclosedwith this report.TS.6.11I  
Table 2 -Summary of total occupational dose received by KSU reactor workers from 1/1/2015 -11/30/2015. (Data for December 2015 is not yet available).
.e.6 -A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of suchrelease or discharge.
mrem DDE LDE SDE (0, 10] 2 2 2 (10, 201 0 0 0 (20, 30] 4 3 3 (30, 40] 4 5 4 (40, 50] 3 2 2>50 3 4 5>100 0 0 0 Page 6 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Visitor dose at the KSU TRIGA reactor facility is measured using Civil Defense self-indicating pocket dosimeters, with an indication range from 0-200 mR. Self-indicated pocket dosimeter readings suffer from imprecision due to parallax error, sometimes resulting in negative values or readings above the true value.2015 Visitor Exposure Records 10000'S as I C 1000 100 10 1 Exposure [mR]Figure 3 -Visitor exposure records from CY 2015.All radiation surveys and contamination surveys conducted at the facility in 2015 were nominal.This concludes the 2015 Annual Report for the Kansas State University TRIGA Mark II Nuclear Reactor.Page 7 of 7 SOM 5 ATTACHMENT 2 Onia 7/05/06 Evaluation of Change, Program Effectiveness I Page 1 of 3 TITLE Replace Thermal Column DATE 12/23/2015 Winch DESCRIPTION Replace manual winch with two 3.5 HP 12 VDC winches SCREENING:
Per procedure, the radioisotope inventory and concentration were calculated prior todischarge, showing both to be well below the limits in 10CFR-20:
The following guidance provides criteria to screen the proposed change from further assessing need for NRC review. If the change does not affect (1) a design function of SSC, (2) a method of performing or controlling design function, (3) evaluation for demonstrating the design function will be accomplished, then it is not necessary to continue the evaluation.
Page 5 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTAvg. Limit* TotalConcentration (lpCi / Volume Total ActivityIsotope (Ci / mL) mE) (mL) Released (Ci)Alpha-emitters 6.11E-11 N/A 5.OE-23H 7.01E-12 1.00E-02 1.47E7 2.8E-414 5.57E-12 3.00E-04 8.3E-532p 3.70E-12 9.00E-05 4.8E-5*10CFR-.20, App.BThe only other discharges beyond the facility boundary were HVAC condensate discharges to the samitary sewer. Since the Kansas State University average water usageis 750,000 gallons per day, it is nearly impossible to exceed 10OCFR20 limits for effluentconcentration at the KSU reactor.
HVAC condensate water is never circulated through ornear the reactor core and historically radiation levels in HVAC condensate are nearbackground levels.TS.6.11I  
.e.7 -A description of any environmental surveys performed outside the facility.
Monthly radiation surveys are performed within the facility to verify that radiation levelsremain safe when at full-power operation.
These surveys indicate that the dose rate at theinside surface of the reactor dome does not exceed the hourly dose limit to members ofthe public of 2 mR / h, as set forth in 10CFR-20, which indicates that the outside dosecannot exceed this limit.TS.6.11I  
.e..8 -A summary of radiation exposures received by facilitypersonnel and visitors, including the dates and time of significant
: exposure, and a brief summary of the results of radiation andcontamination surveys performed within the facility.
A table showing the number of workers receiving given amounts of dose is presented below. The total is given through the end of November, since the dosimetry results forDecember have not been received yet. Note that no worker received a shallow doseequivalent, deep dose equivalent, or lens dose equivalent in excess of 100 mrem. Thisshows that the facility radiation protection program has continued to be successful inkeeping occupational doses as low as reasonably achievable.
Table 2 -Summary of total occupational dose received by KSU reactor workers from 1/1/2015  
-11/30/2015.  
(Data for December 2015 is not yet available).
mrem DDE LDE SDE(0, 10] 2 2 2(10, 201 0 0 0(20, 30] 4 3 3(30, 40] 4 5 4(40, 50] 3 2 2>50 3 4 5>100 0 0 0Page 6 of 7 ATTACHMENT 1KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORTVisitor dose at the KSU TRIGA reactor facility is measured using Civil Defense self-indicating pocket dosimeters, with an indication range from 0-200 mR. Self-indicated pocket dosimeter readings suffer from imprecision due to parallax error, sometimes resulting in negative values or readings above the true value.2015 Visitor Exposure Records10000'SasIC1000100101Exposure
[mR]Figure 3 -Visitor exposure records from CY 2015.All radiation surveys and contamination surveys conducted at the facility in 2015 werenominal.This concludes the 2015 Annual Report for the Kansas State University TRIGA Mark IINuclear Reactor.Page 7 of 7 SOM 5 ATTACHMENT 2 Onia 7/05/06Evaluation of Change, Program Effectiveness I Page 1 of 3TITLE Replace Thermal Column DATE 12/23/2015 WinchDESCRIPTION Replace manual winch with two 3.5 HP 12 VDC winchesSCREENING:
The following guidance provides criteria to screen the proposed change fromfurther assessing need for NRC review. If the change does not affect (1) a design function ofSSC, (2) a method of performing or controlling design function, (3) evaluation for demonstrating the design function will be accomplished, then it is not necessary to continue the evaluation.
SSC Affected ISSC Design function IFailure Mode(s) IAccident scenario(s)
SSC Affected ISSC Design function IFailure Mode(s) IAccident scenario(s)
SAFETY ANALY}SIS  
SAFETY ANALY}SIS  
& A CCIDENT RESPONSE/MITIGA TION YES NODecrease SSC design function reliability when failure would initiate an accident
& A CCIDENT RESPONSE/MITIGA TION YES NO Decrease SSC design function reliability when failure would initiate an accident ____ X Decrease SSC design function reliability when failure would mitigate accident ____ X Reduce redundancy, reliability or defense in depth ____ X Add or delete an automatic or manual design function of an SSC ____ X HUMAN INTERFACE YES NO Convert an automatic feature to manual or vice versa X ___Adversely affect ability to perform required actions _ __ X Adversely affect time response of required actions ____ X INTERFACE OUTSIDE THE PROPOSED CHANGE YES NO Degrade seismic or environmental qualification X Affect method of evaluation used to establish design basis or safety analysis X Introduce an unwanted or previously unreveiwed system or material interaction X (Not described in SAR) indirect effects on electrical distribution X (Not described in SAR) indirect effects structural integrity
____ XDecrease SSC design function reliability when failure would mitigate accident
____ X (Not described in SAR) indirect effects on environmental conditions X (Not described inSAR) indirect effects on other SAR design functions X COMMENTS: PERFORMED BY: ___Geuther DATE 12/23/2015 If any of the above answers are YES, then proceed to the EVALUATION section.
____ XReduce redundancy, reliability or defense in depth ____ XAdd or delete an automatic or manual design function of an SSC ____ XHUMAN INTERFACE YES NOConvert an automatic feature to manual or vice versa X ___Adversely affect ability to perform required actions _ __ XAdversely affect time response of required actions ____ XINTERFACE OUTSIDE THE PROPOSED CHANGE YES NODegrade seismic or environmental qualification XAffect method of evaluation used to establish design basis or safety analysis XIntroduce an unwanted or previously unreveiwed system or material interaction X(Not described in SAR) indirect effects on electrical distribution X(Not described in SAR) indirect effects structural integrity
SOM 5 ATT-ACHMENT 2 On Oiinal 7/05/06 Evaluation of Change, Program Effectiveness Page 2 of 3 Evaluation
____ X(Not described in SAR) indirect effects on environmental conditions X(Not described inSAR) indirect effects on other SAR design functions XCOMMENTS:
[Result in more than a minimal increase in the frequency of occurrence of an Yes No accident previously evaluated inl the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivit Addition LOCA Fuel Handling Result in more than a minimal increase in the likelihood of occurrence of a YYes No malfunction in a structure, system, or component (SSC) important to safetyX-previously evaluated in the final Safety Analysis Report AFFECTED SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION Result in more than a minimal increase in the consequences of an accident Yes No previously evaluated in the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivity Addition _____________________________
PERFORMED BY: ___Geuther DATE 12/23/2015 If any of the above answers are YES, then proceed to the EVALUATION section.
SOM 5 ATT-ACHMENT 2 On Oiinal 7/05/06Evaluation of Change, Program Effectiveness Page 2 of 3Evaluation
[Result in more than a minimal increase in the frequency of occurrence of an Yes Noaccident previously evaluated inl the final Safety Analysis Report xACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivit AdditionLOCAFuel HandlingResult in more than a minimal increase in the likelihood of occurrence of a YYes Nomalfunction in a structure, system, or component (SSC) important to safetyX-previously evaluated in the final Safety Analysis ReportAFFECTED SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION Result in more than a minimal increase in the consequences of an accident Yes Nopreviously evaluated in the final Safety Analysis Report xACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivity Addition
_____________________________
LOCA ___________________
LOCA ___________________
Fuel Handling__
Fuel Handling__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Result in more than a minimal increase in the consequences of a malfunction in a Ys Nstructure, system, or component (SSC) important to safety previously evaluated inr ixthe final Safety Analysis ReportAFFECTED SSCAFFECTD SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION SOM 5 ATTACHMENT 2 On na 7/05/06Evaluation of Change, Program Effectiveness
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Result in more than a minimal increase in the consequences of a malfunction in a Ys N structure, system, or component (SSC) important to safety previously evaluated inr ix the final Safety Analysis Report AFFECTED SSC AFFECTD SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION SOM 5 ATTACHMENT 2 On na 7/05/06 Evaluation of Change, Program Effectiveness
_[ Page 3 of 3Create a possibility for an accident of a different type than any previously Yes Noevaluated in the final Safety Analysis Report L xNEW /DIFFERENT TYPE OF ACCIDENT (INCLUDING LIKELIHOOD AND[Create a possibility for a malfunction of an SSC important to safety with a IYes Nodifferent result than any previously evaluated in the final Safety Analysis Report I xACCIDENT AFFECTED SSC__________
_[ Page 3 of 3 Create a possibility for an accident of a different type than any previously Yes No evaluated in the final Safety Analysis Report L x NEW /DIFFERENT TYPE OF ACCIDENT (INCLUDING LIKELIHOOD AND[Create a possibility for a malfunction of an SSC important to safety with a IYes No different result than any previously evaluated in the final Safety Analysis Report I x ACCIDENT AFFECTED SSC__________
Reactivity Addition__
Reactivity Addition__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _LOCA__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Fuel Handling__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _LOCA__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Fuel Handling__
_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Other__ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Result in design basis limit for fission product barrier as described in the SAR IYsNbeing exceeded or altered I X_____________REFERENCE I//TEXT I VALUEDesign Basis Limit _____________________
_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Other__ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Result in design basis limit for fission product barrier as described in the SAR IYsN being exceeded or altered I X_____________REFERENCE I//TEXT I VALUE Design Basis Limit _____________________
_____________________
Analysis
_____________________
_____________________
Analysis _____________________
_____________________
_____________________
~Approach to Limit_ _ __ _j_ _ _ _ _Result in a departure from a method of evaluation described in the SAR used in YsNestablishing design bases or in the safety analyses I xREFERENCE I//TEXT VALUEDesign Basis Limit _____________
~Approach to Limit_ _ __ _j_ _ _ _ _Result in a departure from a method of evaluation described in the SAR used in YsN establishing design bases or in the safety analyses I x REFERENCE I//TEXT VALUE Design Basis Limit _____________
New Analysis________
New Analysis________
_____Coinparison
_____Coinparison
____________}}
____________}}

Revision as of 16:40, 8 July 2018

Kansas State University - Transmittal of 2015 Annual Operating Report
ML16032A165
Person / Time
Site: Kansas State University
Issue date: 01/13/2016
From: Geuther J A
Kansas State University
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML16032A165 (11)


Text

Jeffrey Geuther, Ph.D.Nuclear Reactor Facility Manager 3002 Rathbone Hall Kansas State University 66506 US NRC Attn: Document Control Desk Washington, DC 20555-0001 13 January 2016

Subject:

2015 Annual Operating Report for the Kansas State University TRIGA Mark II Nuclear Reactor (Facility License # R-88, Facility Docket # 50-188)To Whom It May Concern: This document serves as the annual operating report for the Kansas State University (KSU) nuclear reactor. This document satisfies requirements in facility Technical Specifications (TS) 6.11 .e.The report is divided into paragraphs addressing specific items listed as requirements in the Technical Specifications.

Sincerely, Jeffrey A. Geuther, Ph.D.Nuclear Reactor Facility Manager Kansas State University Attachments:

1. Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 2. 10CFR50.59 Screening Forms Cc: Spyros Traiforos, Project Manager, NRC Michael Morlang, Inspector,NRC ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 Introduction The Kansas State University Nuclear Reactor Technical Specifications (TS) require a routine written report to be transmitted to the US Nuclear Regulatory Commission within 60 days after completion of the first calendar year of operating, and at intervals not to exceed twelve months thereafter, providing the following information:

TS.6.11.e.1

-TS.6.11.e.2

-TS.6.11.e.3

-TS.6.11.e.4

-TS.6.11.e.5

-TS.6.11l.e.6

-TS.6.11 .e.7 -TS.6.11.e.8

-A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.

A tabulation showing the energy generated by the reactor (in megawatt-hours).The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of 10.CFR.50.59.

A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.

A description of any environmental surveys performed outside the facility.A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facilty.This information is transmitted in this report, in sections separated by TS clause. This report covers January 2015 -December 2015.Page 1 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT TS.6.11I .e.1 -A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.

The KSU reactor operated for its usual purposes in CY2O015. Two reactor operations laboratory classes and a reactor theory laboratory class were supported, along with approximately 10 other courses with less frequent need of the reactor. 2214 visitors received access to the facility for various outreach activities, classes, and research experiments.

Typical experiments included prompt gamma neutron activation analysis (PGNAA), neutron activation analysis (NAA), neutron detector testing at beam ports, and gamma irradiation with decay gammas from the reactor core. In CY 2014, Experiment 52 -Fuel Element Reactivity Measurement was approved.

It had not been performed during CY20 14, but was performed for the first time in CY 2015. Experiment 52 allows for the measurement of integral fuel element worth using the positive period method with all rods out in a configuration in which the reactor can barely go supercritical prior to the addition of the test element.The NRC routine annual inspection was completed from June 22 -25t% 2015. No violations or inspector follow-up items were reported. (See Inspection Report No. 50-188/2015-201).

During the last quarter of 2015 the rate of water makeup to primary was noted to be higher than usual by approximately 70 gallons per week. The reactor staff identified a trickle of primary coolant water emanating from the thermal column and collecting in the reactor sump. As a result of the leak, a very small (< 1 mCi) amount of tritium was discharged from the facility.

The leak has been repaired by sealing the thermal colunmn with a gasketed aluminum plate.TS.6.I11.e.2

-A tabulation showing the energy generated by the reactor (in megawatt-hours).

The monthly total energy generated by the KSU reactor is recorded in Table 1. The same data is shown as a bar chart in Figure 1. The total MWh of operation increased slightly from the prior year, from 48.2 MWh to 55.9 MWh.Page 2 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Table 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.Month MWh Burnup January February March April May June July August September October November December 1.4 2.1 7.2 9.1 1.8 10.3 8.5 3.4 0.7 4.6 5.8 1.0 TOTAL 55.9 Monthly Burnup (MWh), CY2O15 0.0 2,0 4.0 6.0 8.0 10.0 12,0 January February March April May June July August September October November December Figure 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.The reactor operated for a total of 635.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> during 2015, at an average power of 88 kW. Figure 2 shows the percentage of hours of reactor operation for various purposes, i.e., research support, training, education, etc. The percentage of hours for training appears small, because operator training was often performed when the reactor was being operated for another purpose, such as research support. The plot demonstrates that the reactor is operated in accordance with our stated primary functions:

education; research support (e.g., irradiation);

operator training; and demonstration (e.g., tours). The percentage of time spent supporting experiments approximately doubled from 2014 (from 25% to 49%).Page 3 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Reactor Operations Hours by Purpose 2% 3%49%24%10%* Research U Tours *iClasses Maintenance 1Training 1Testing Figure 2 -KSU reactor hours, CY20 15, based on purpose of operation.

TS.6.11I.e.3

-The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.The following table documents the inadvertent S CRAMS and emergency shutdowns for CY 2015 at the KSU reactor. Note that many SCRAMS were caused by problems with the NMP-1000 multirange linear power channel, which was eventually replaced with a spare on loan from WSU.Inadvertent S CRAMS adEe n hton 2/12/2015 Linear power No apparent cause_________scram 31162015Linar pwer NMP 1000 did not go to AUTO range when button 3/162015Linar pwer was pressed; scram occurred at ~1.1 W when scram switched between 100 mW range and 1 W range.3/1205Linear power Problem with NMP 1000, possibly a microscopic scram crack in a board (Faircloth Eng).4/7205Linear power NMP 1000 was in autorange, but tripped reactor scram when going between ranges.Low HV Scram Due to staff member moving a wire on back of 42/05(NPP 1000) control console.4/23/2015 Period scram No apparent cause 4/3205Linear power NMP 1000 was in autorange, but tripped when scram going between ranges Page 4 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT NMP 1000 caused trip when placed in 10 kW 4/9205Linear power range. Instrument was not responding to power 42/05scram changes. Trip was not repeatable.

10/20/2015 Period scram Operator error 10/27/2015 Period scram Operator error by trainee 11/5/2015 Period scram Operator error by trainee 11/19/2015 Period scram Operator error by trainee 11/20/2015 Period scram Operator error by trainee TS.6.11I.e.4

-Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.No major maintenance operations affected the safe operation of the reactor. The following major maintenance activities occurred:* Replaced the NMP-1000 multi-range linear power channel with a spare unit on loan from Washington State University.

  • Replaced the regulating and shim rod drive assemblies.
  • Repaired automatic flux control system.* Remote range switch installed on NMP-1000.* Digital board in WSU NMP-1000 replaced with digital board from KSU NMP-1000.* Replacement of the manual winch used to operate the thermal column door with two electrical winches.* Began work on water leak repair in thermal column. (Work completed on 1/8/2016).

TS.6.11I .e.5 -A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of I0CFR-50.59.The following change was carried out under 10CFR-50.59:

The manual winch which operated the thermal column door was replaced with two electrical winches. The 50.59 screening form used to evaluate this change is enclosed with this report.TS.6.11I .e.6 -A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.

Per procedure, the radioisotope inventory and concentration were calculated prior to discharge, showing both to be well below the limits in 10CFR-20: Page 5 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Avg. Limit* Total Concentration (lpCi / Volume Total Activity Isotope (Ci / mL) mE) (mL) Released (Ci)Alpha-emitters 6.11E-11 N/A 5.OE-2 3 H 7.01E-12 1.00E-02 1.47E7 2.8E-4 14 5.57E-12 3.00E-04 8.3E-5 3 2 p 3.70E-12 9.00E-05 4.8E-5*10CFR-.20, App.B The only other discharges beyond the facility boundary were HVAC condensate discharges to the samitary sewer. Since the Kansas State University average water usage is 750,000 gallons per day, it is nearly impossible to exceed 10OCFR20 limits for effluent concentration at the KSU reactor. HVAC condensate water is never circulated through or near the reactor core and historically radiation levels in HVAC condensate are near background levels.TS.6.11I .e.7 -A description of any environmental surveys performed outside the facility.Monthly radiation surveys are performed within the facility to verify that radiation levels remain safe when at full-power operation.

These surveys indicate that the dose rate at the inside surface of the reactor dome does not exceed the hourly dose limit to members of the public of 2 mR / h, as set forth in 10CFR-20, which indicates that the outside dose cannot exceed this limit.TS.6.11I .e..8 -A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facility.A table showing the number of workers receiving given amounts of dose is presented below. The total is given through the end of November, since the dosimetry results for December have not been received yet. Note that no worker received a shallow dose equivalent, deep dose equivalent, or lens dose equivalent in excess of 100 mrem. This shows that the facility radiation protection program has continued to be successful in keeping occupational doses as low as reasonably achievable.

Table 2 -Summary of total occupational dose received by KSU reactor workers from 1/1/2015 -11/30/2015. (Data for December 2015 is not yet available).

mrem DDE LDE SDE (0, 10] 2 2 2 (10, 201 0 0 0 (20, 30] 4 3 3 (30, 40] 4 5 4 (40, 50] 3 2 2>50 3 4 5>100 0 0 0 Page 6 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Visitor dose at the KSU TRIGA reactor facility is measured using Civil Defense self-indicating pocket dosimeters, with an indication range from 0-200 mR. Self-indicated pocket dosimeter readings suffer from imprecision due to parallax error, sometimes resulting in negative values or readings above the true value.2015 Visitor Exposure Records 10000'S as I C 1000 100 10 1 Exposure [mR]Figure 3 -Visitor exposure records from CY 2015.All radiation surveys and contamination surveys conducted at the facility in 2015 were nominal.This concludes the 2015 Annual Report for the Kansas State University TRIGA Mark II Nuclear Reactor.Page 7 of 7 SOM 5 ATTACHMENT 2 Onia 7/05/06 Evaluation of Change, Program Effectiveness I Page 1 of 3 TITLE Replace Thermal Column DATE 12/23/2015 Winch DESCRIPTION Replace manual winch with two 3.5 HP 12 VDC winches SCREENING:

The following guidance provides criteria to screen the proposed change from further assessing need for NRC review. If the change does not affect (1) a design function of SSC, (2) a method of performing or controlling design function, (3) evaluation for demonstrating the design function will be accomplished, then it is not necessary to continue the evaluation.

SSC Affected ISSC Design function IFailure Mode(s) IAccident scenario(s)

SAFETY ANALY}SIS

& A CCIDENT RESPONSE/MITIGA TION YES NO Decrease SSC design function reliability when failure would initiate an accident ____ X Decrease SSC design function reliability when failure would mitigate accident ____ X Reduce redundancy, reliability or defense in depth ____ X Add or delete an automatic or manual design function of an SSC ____ X HUMAN INTERFACE YES NO Convert an automatic feature to manual or vice versa X ___Adversely affect ability to perform required actions _ __ X Adversely affect time response of required actions ____ X INTERFACE OUTSIDE THE PROPOSED CHANGE YES NO Degrade seismic or environmental qualification X Affect method of evaluation used to establish design basis or safety analysis X Introduce an unwanted or previously unreveiwed system or material interaction X (Not described in SAR) indirect effects on electrical distribution X (Not described in SAR) indirect effects structural integrity

____ X (Not described in SAR) indirect effects on environmental conditions X (Not described inSAR) indirect effects on other SAR design functions X COMMENTS: PERFORMED BY: ___Geuther DATE 12/23/2015 If any of the above answers are YES, then proceed to the EVALUATION section.

SOM 5 ATT-ACHMENT 2 On Oiinal 7/05/06 Evaluation of Change, Program Effectiveness Page 2 of 3 Evaluation

[Result in more than a minimal increase in the frequency of occurrence of an Yes No accident previously evaluated inl the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivit Addition LOCA Fuel Handling Result in more than a minimal increase in the likelihood of occurrence of a YYes No malfunction in a structure, system, or component (SSC) important to safetyX-previously evaluated in the final Safety Analysis Report AFFECTED SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION Result in more than a minimal increase in the consequences of an accident Yes No previously evaluated in the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivity Addition _____________________________

LOCA ___________________

Fuel Handling__

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Result in more than a minimal increase in the consequences of a malfunction in a Ys N structure, system, or component (SSC) important to safety previously evaluated inr ix the final Safety Analysis Report AFFECTED SSC AFFECTD SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION SOM 5 ATTACHMENT 2 On na 7/05/06 Evaluation of Change, Program Effectiveness

_[ Page 3 of 3 Create a possibility for an accident of a different type than any previously Yes No evaluated in the final Safety Analysis Report L x NEW /DIFFERENT TYPE OF ACCIDENT (INCLUDING LIKELIHOOD AND[Create a possibility for a malfunction of an SSC important to safety with a IYes No different result than any previously evaluated in the final Safety Analysis Report I x ACCIDENT AFFECTED SSC__________

Reactivity Addition__

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _LOCA__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Fuel Handling__

_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Other__ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Result in design basis limit for fission product barrier as described in the SAR IYsN being exceeded or altered I X_____________REFERENCE I//TEXT I VALUE Design Basis Limit _____________________

_____________________

Analysis _____________________

_____________________

~Approach to Limit_ _ __ _j_ _ _ _ _Result in a departure from a method of evaluation described in the SAR used in YsN establishing design bases or in the safety analyses I x REFERENCE I//TEXT VALUE Design Basis Limit _____________

New Analysis________

_____Coinparison

____________

Jeffrey Geuther, Ph.D.Nuclear Reactor Facility Manager 3002 Rathbone Hall Kansas State University 66506 US NRC Attn: Document Control Desk Washington, DC 20555-0001 13 January 2016

Subject:

2015 Annual Operating Report for the Kansas State University TRIGA Mark II Nuclear Reactor (Facility License # R-88, Facility Docket # 50-188)To Whom It May Concern: This document serves as the annual operating report for the Kansas State University (KSU) nuclear reactor. This document satisfies requirements in facility Technical Specifications (TS) 6.11 .e.The report is divided into paragraphs addressing specific items listed as requirements in the Technical Specifications.

Sincerely, Jeffrey A. Geuther, Ph.D.Nuclear Reactor Facility Manager Kansas State University Attachments:

1. Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 2. 10CFR50.59 Screening Forms Cc: Spyros Traiforos, Project Manager, NRC Michael Morlang, Inspector,NRC ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Kansas State University TRIGA Mark II Reactor Annual Report, CY 2015 Introduction The Kansas State University Nuclear Reactor Technical Specifications (TS) require a routine written report to be transmitted to the US Nuclear Regulatory Commission within 60 days after completion of the first calendar year of operating, and at intervals not to exceed twelve months thereafter, providing the following information:

TS.6.11.e.1

-TS.6.11.e.2

-TS.6.11.e.3

-TS.6.11.e.4

-TS.6.11.e.5

-TS.6.11l.e.6

-TS.6.11 .e.7 -TS.6.11.e.8

-A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.

A tabulation showing the energy generated by the reactor (in megawatt-hours).The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of 10.CFR.50.59.

A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.

A description of any environmental surveys performed outside the facility.A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facilty.This information is transmitted in this report, in sections separated by TS clause. This report covers January 2015 -December 2015.Page 1 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT TS.6.11I .e.1 -A brief narrative summary of operating experience (including experiments performed), changes in facility design, performance characteristics, and operating procedures related to reactor safety occurring during the reporting period; and results of surveillance tests and inspections.

The KSU reactor operated for its usual purposes in CY2O015. Two reactor operations laboratory classes and a reactor theory laboratory class were supported, along with approximately 10 other courses with less frequent need of the reactor. 2214 visitors received access to the facility for various outreach activities, classes, and research experiments.

Typical experiments included prompt gamma neutron activation analysis (PGNAA), neutron activation analysis (NAA), neutron detector testing at beam ports, and gamma irradiation with decay gammas from the reactor core. In CY 2014, Experiment 52 -Fuel Element Reactivity Measurement was approved.

It had not been performed during CY20 14, but was performed for the first time in CY 2015. Experiment 52 allows for the measurement of integral fuel element worth using the positive period method with all rods out in a configuration in which the reactor can barely go supercritical prior to the addition of the test element.The NRC routine annual inspection was completed from June 22 -25t% 2015. No violations or inspector follow-up items were reported. (See Inspection Report No. 50-188/2015-201).

During the last quarter of 2015 the rate of water makeup to primary was noted to be higher than usual by approximately 70 gallons per week. The reactor staff identified a trickle of primary coolant water emanating from the thermal column and collecting in the reactor sump. As a result of the leak, a very small (< 1 mCi) amount of tritium was discharged from the facility.

The leak has been repaired by sealing the thermal colunmn with a gasketed aluminum plate.TS.6.I11.e.2

-A tabulation showing the energy generated by the reactor (in megawatt-hours).

The monthly total energy generated by the KSU reactor is recorded in Table 1. The same data is shown as a bar chart in Figure 1. The total MWh of operation increased slightly from the prior year, from 48.2 MWh to 55.9 MWh.Page 2 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Table 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.Month MWh Burnup January February March April May June July August September October November December 1.4 2.1 7.2 9.1 1.8 10.3 8.5 3.4 0.7 4.6 5.8 1.0 TOTAL 55.9 Monthly Burnup (MWh), CY2O15 0.0 2,0 4.0 6.0 8.0 10.0 12,0 January February March April May June July August September October November December Figure 1 -Energy generated by the KSU Triga Mark II reactor by month for CY 2015.The reactor operated for a total of 635.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> during 2015, at an average power of 88 kW. Figure 2 shows the percentage of hours of reactor operation for various purposes, i.e., research support, training, education, etc. The percentage of hours for training appears small, because operator training was often performed when the reactor was being operated for another purpose, such as research support. The plot demonstrates that the reactor is operated in accordance with our stated primary functions:

education; research support (e.g., irradiation);

operator training; and demonstration (e.g., tours). The percentage of time spent supporting experiments approximately doubled from 2014 (from 25% to 49%).Page 3 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Reactor Operations Hours by Purpose 2% 3%49%24%10%* Research U Tours *iClasses Maintenance 1Training 1Testing Figure 2 -KSU reactor hours, CY20 15, based on purpose of operation.

TS.6.11I.e.3

-The number of emergency shutdowns and inadvertent scrams, including the reason thereof and corrective action, if any, taken.The following table documents the inadvertent S CRAMS and emergency shutdowns for CY 2015 at the KSU reactor. Note that many SCRAMS were caused by problems with the NMP-1000 multirange linear power channel, which was eventually replaced with a spare on loan from WSU.Inadvertent S CRAMS adEe n hton 2/12/2015 Linear power No apparent cause_________scram 31162015Linar pwer NMP 1000 did not go to AUTO range when button 3/162015Linar pwer was pressed; scram occurred at ~1.1 W when scram switched between 100 mW range and 1 W range.3/1205Linear power Problem with NMP 1000, possibly a microscopic scram crack in a board (Faircloth Eng).4/7205Linear power NMP 1000 was in autorange, but tripped reactor scram when going between ranges.Low HV Scram Due to staff member moving a wire on back of 42/05(NPP 1000) control console.4/23/2015 Period scram No apparent cause 4/3205Linear power NMP 1000 was in autorange, but tripped when scram going between ranges Page 4 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT NMP 1000 caused trip when placed in 10 kW 4/9205Linear power range. Instrument was not responding to power 42/05scram changes. Trip was not repeatable.

10/20/2015 Period scram Operator error 10/27/2015 Period scram Operator error by trainee 11/5/2015 Period scram Operator error by trainee 11/19/2015 Period scram Operator error by trainee 11/20/2015 Period scram Operator error by trainee TS.6.11I.e.4

-Discussion of the major maintenance operations performed during the period, including the effects, if any, on the safe operation of the reactor, and the reasons for any corrective maintenance required.No major maintenance operations affected the safe operation of the reactor. The following major maintenance activities occurred:* Replaced the NMP-1000 multi-range linear power channel with a spare unit on loan from Washington State University.

  • Replaced the regulating and shim rod drive assemblies.
  • Repaired automatic flux control system.* Remote range switch installed on NMP-1000.* Digital board in WSU NMP-1000 replaced with digital board from KSU NMP-1000.* Replacement of the manual winch used to operate the thermal column door with two electrical winches.* Began work on water leak repair in thermal column. (Work completed on 1/8/2016).

TS.6.11I .e.5 -A summary of each change to the facility or procedures, tests, and experiments carried out under the conditions of I0CFR-50.59.The following change was carried out under 10CFR-50.59:

The manual winch which operated the thermal column door was replaced with two electrical winches. The 50.59 screening form used to evaluate this change is enclosed with this report.TS.6.11I .e.6 -A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge.

Per procedure, the radioisotope inventory and concentration were calculated prior to discharge, showing both to be well below the limits in 10CFR-20: Page 5 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Avg. Limit* Total Concentration (lpCi / Volume Total Activity Isotope (Ci / mL) mE) (mL) Released (Ci)Alpha-emitters 6.11E-11 N/A 5.OE-2 3 H 7.01E-12 1.00E-02 1.47E7 2.8E-4 14 5.57E-12 3.00E-04 8.3E-5 3 2 p 3.70E-12 9.00E-05 4.8E-5*10CFR-.20, App.B The only other discharges beyond the facility boundary were HVAC condensate discharges to the samitary sewer. Since the Kansas State University average water usage is 750,000 gallons per day, it is nearly impossible to exceed 10OCFR20 limits for effluent concentration at the KSU reactor. HVAC condensate water is never circulated through or near the reactor core and historically radiation levels in HVAC condensate are near background levels.TS.6.11I .e.7 -A description of any environmental surveys performed outside the facility.Monthly radiation surveys are performed within the facility to verify that radiation levels remain safe when at full-power operation.

These surveys indicate that the dose rate at the inside surface of the reactor dome does not exceed the hourly dose limit to members of the public of 2 mR / h, as set forth in 10CFR-20, which indicates that the outside dose cannot exceed this limit.TS.6.11I .e..8 -A summary of radiation exposures received by facility personnel and visitors, including the dates and time of significant exposure, and a brief summary of the results of radiation and contamination surveys performed within the facility.A table showing the number of workers receiving given amounts of dose is presented below. The total is given through the end of November, since the dosimetry results for December have not been received yet. Note that no worker received a shallow dose equivalent, deep dose equivalent, or lens dose equivalent in excess of 100 mrem. This shows that the facility radiation protection program has continued to be successful in keeping occupational doses as low as reasonably achievable.

Table 2 -Summary of total occupational dose received by KSU reactor workers from 1/1/2015 -11/30/2015. (Data for December 2015 is not yet available).

mrem DDE LDE SDE (0, 10] 2 2 2 (10, 201 0 0 0 (20, 30] 4 3 3 (30, 40] 4 5 4 (40, 50] 3 2 2>50 3 4 5>100 0 0 0 Page 6 of 7 ATTACHMENT 1 KANSAS STATE UNIVERSITY TRIGA MARK II REACTOR ANNUAL REPORT Visitor dose at the KSU TRIGA reactor facility is measured using Civil Defense self-indicating pocket dosimeters, with an indication range from 0-200 mR. Self-indicated pocket dosimeter readings suffer from imprecision due to parallax error, sometimes resulting in negative values or readings above the true value.2015 Visitor Exposure Records 10000'S as I C 1000 100 10 1 Exposure [mR]Figure 3 -Visitor exposure records from CY 2015.All radiation surveys and contamination surveys conducted at the facility in 2015 were nominal.This concludes the 2015 Annual Report for the Kansas State University TRIGA Mark II Nuclear Reactor.Page 7 of 7 SOM 5 ATTACHMENT 2 Onia 7/05/06 Evaluation of Change, Program Effectiveness I Page 1 of 3 TITLE Replace Thermal Column DATE 12/23/2015 Winch DESCRIPTION Replace manual winch with two 3.5 HP 12 VDC winches SCREENING:

The following guidance provides criteria to screen the proposed change from further assessing need for NRC review. If the change does not affect (1) a design function of SSC, (2) a method of performing or controlling design function, (3) evaluation for demonstrating the design function will be accomplished, then it is not necessary to continue the evaluation.

SSC Affected ISSC Design function IFailure Mode(s) IAccident scenario(s)

SAFETY ANALY}SIS

& A CCIDENT RESPONSE/MITIGA TION YES NO Decrease SSC design function reliability when failure would initiate an accident ____ X Decrease SSC design function reliability when failure would mitigate accident ____ X Reduce redundancy, reliability or defense in depth ____ X Add or delete an automatic or manual design function of an SSC ____ X HUMAN INTERFACE YES NO Convert an automatic feature to manual or vice versa X ___Adversely affect ability to perform required actions _ __ X Adversely affect time response of required actions ____ X INTERFACE OUTSIDE THE PROPOSED CHANGE YES NO Degrade seismic or environmental qualification X Affect method of evaluation used to establish design basis or safety analysis X Introduce an unwanted or previously unreveiwed system or material interaction X (Not described in SAR) indirect effects on electrical distribution X (Not described in SAR) indirect effects structural integrity

____ X (Not described in SAR) indirect effects on environmental conditions X (Not described inSAR) indirect effects on other SAR design functions X COMMENTS: PERFORMED BY: ___Geuther DATE 12/23/2015 If any of the above answers are YES, then proceed to the EVALUATION section.

SOM 5 ATT-ACHMENT 2 On Oiinal 7/05/06 Evaluation of Change, Program Effectiveness Page 2 of 3 Evaluation

[Result in more than a minimal increase in the frequency of occurrence of an Yes No accident previously evaluated inl the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivit Addition LOCA Fuel Handling Result in more than a minimal increase in the likelihood of occurrence of a YYes No malfunction in a structure, system, or component (SSC) important to safetyX-previously evaluated in the final Safety Analysis Report AFFECTED SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION Result in more than a minimal increase in the consequences of an accident Yes No previously evaluated in the final Safety Analysis Report x ACCIDENT POTENTIAL IMPACT ON ACCIDENT FREQUENCY Reactivity Addition _____________________________

LOCA ___________________

Fuel Handling__

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Result in more than a minimal increase in the consequences of a malfunction in a Ys N structure, system, or component (SSC) important to safety previously evaluated inr ix the final Safety Analysis Report AFFECTED SSC AFFECTD SSC POTENTIAL IMPACT ON LIKELIHOOD OF MALFUNCTION SOM 5 ATTACHMENT 2 On na 7/05/06 Evaluation of Change, Program Effectiveness

_[ Page 3 of 3 Create a possibility for an accident of a different type than any previously Yes No evaluated in the final Safety Analysis Report L x NEW /DIFFERENT TYPE OF ACCIDENT (INCLUDING LIKELIHOOD AND[Create a possibility for a malfunction of an SSC important to safety with a IYes No different result than any previously evaluated in the final Safety Analysis Report I x ACCIDENT AFFECTED SSC__________

Reactivity Addition__

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _LOCA__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Fuel Handling__

_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Other__ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _Result in design basis limit for fission product barrier as described in the SAR IYsN being exceeded or altered I X_____________REFERENCE I//TEXT I VALUE Design Basis Limit _____________________

_____________________

Analysis _____________________

_____________________

~Approach to Limit_ _ __ _j_ _ _ _ _Result in a departure from a method of evaluation described in the SAR used in YsN establishing design bases or in the safety analyses I x REFERENCE I//TEXT VALUE Design Basis Limit _____________

New Analysis________

_____Coinparison

____________