ML070820003

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

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

Text

March 29, 2007Mr. Michael Whaley, ManagerNuclear Reactor FacilityDepartment of Mechanical and Nuclear Engineering112 Ward HallKansas State UniversityManhattan, KS 66506-5204

SUBJECT:

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

Dear Mr. Whaley:

We are continuing our review of your request for license renewal for the Kansas StateUniversity research reactor which you submitted on September 12, 2002. During our review ofyour license renewal request, questions have arisen for which we require additional informationand clarification. Please provide responses to the enclosed request for additional information(RAI) within 30 days of the date of this letter. In addition, your license renewal application included financial information pertaining tooperation and decommissioning of the reactor. This letter does not satisfy the requirements forassurance of decommissioning funding for license renewal. The position of the NRC is thatKSU has assurance from the State of Kansas for decommissioning funding under the currentlicense, but updated assurance of decommissioning funding is required for license renewal. Title 10 of the Code of Federal Regulations, Part 50.75(e)(iv) permits State licensees toprovide assurance of decommissioning funding by "a statement of intent containing a costestimate for decommissioning, and indicating that funds for decommissioning will be obtainedwhen necessary." The statement of intent must be signed by an official who has the authority tocommit to spending the necessary funds to accomplish decommissioning, and it should beclearly asserted in the statement of intent that the signing official has that authority. In addition,the statement of in tent should cont ain a statement that funding will be provided sufficiently inadvance of decommissioning to prevent delay of required activities. If decommissioning fundingis to continue to be assured by the State of Kansas, submit an updated statement of intent tothis effect, signed by an appropriate State official. Otherwise, 10 CFR 50.75(e) providesalternate options for assurance of decommissioning funding. Please provide the necessarydocumentation within 30 days of the date of this letter.

Mr. Whaley In accordance with 10 CFR 50.30(b), your responses and the statement of intent mustbe executed in a signed original under oath or affirmation.If you have any questions regarding this review, please contact me at 301-415-1631.Sincerely,/RA/Daniel E. Hughes, Project ManagerResearch and Test Reactors Branch ADivision of Policy and RulemakingOffice of Nuclear Reactor RegulationDocket No. 50-188

Enclosure:

As stated cc w/ enclosure: Please see next page Kansas State UniversityDocket No. 50-188 cc:Office of the GovernorState of KansasTopeka, KS 66612 Mayor of ManhattanP.O. Box 748Manhattan, KS 66502Thomas A. Conley, RRPJ, CHP, Section Chief Radiation and Asbestos Control KS Dept of Health & Environment 1000 SW Jackson, Suite 320Topeka, KS 66612-1366 Test, Research, and Training Reactor NewsletterUniversity of Florida202 Nuclear Sciences CenterGainesville, FL 32611 Mr. Whaley In accordance with 10 CFR 50.30(b), your responses and the statement of intent mustbe executed in a signed original under oath or affirmation.If you have any questions regarding this review, please contact me at 301-415-1631.Sincerely,

/RA/Daniel E. Hughes, Project ManagerResearch and Test Reactors Branch ADivision of Policy and RulemakingOffice of Nuclear Reactor RegulationDocket No. 50-188

Enclosure:

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

PUBLICPRTA r/fDHughesOGCMVothMCaseDCollinsEHyltonADAMS ACCESSION NO: ML070820003 TEMPLATE #: NRR-088OFFICEPRTA:PMPRTA:LAPRTA:BCPRTA:PMNAMEDHughes:cahEHyltonDCollinsDHughesDATE03/27/200703/29/200703/29/200703 /29/2007OFFICIAL RECORD COPY REQUEST FOR ADDITIONAL INFORMATIONKANSAS STATE UNIVERSITY RESEARCH REACTORDOCKET NO. 50-1881.Safety limit for aluminum-clad fuel, TS 2.1.3(2), is not discussed in SAR. The basesrefer to SAR Section 3.5.1 but there is no discussion there for Al-clad. Please provide abasis statement.2.The bases for TS 2.2.3(1) refers to a LSSS for power of 1,250 kW. If this is to be ascram setpoint, how then is the reactor operated at full licensed power of 1,250 kW?(The LSSS is a scram setpoint that should take into account calibration error, instrumenterror, instrument response time, and scram time.) 3.TS 3.2.3(1) - Is operation above 1,250 kW prevented by this LCO as well as the LSSS in2.2.3(1)?TS 3.2.3(2) - Is the LCO of 250 kW if there are aluminum-clad fuel elements in the core. Is this an administrative limit? Should this not be an LSSS also?4.TS 3.2.3(2) - Is the application of air to the transient rod prevented by an interlock or is itadministratively prevented? (See Table II of present TSs.)5.TS 3.4.3(2) -The SAR describes the startup countrate interlock at 2 cps. Since the SARis more conservative than the TS, justify the inconsistency. The conditions for allowing abypassing of the interlock should be specified in the TS. (See Table II of the presentTSs.) The description of "neutron induced" counts seems more precise since it assuresthat the signal and not the noise is observed.6.TS 3.4.4G - Does a Startup Count rate < 1 cps mean the channel is not operating? Thebases should describe why the 1 (or 2) cps is acceptable. 7.TS 3.5.3 - Table 2 indicates that the startup count rate interlock is a required safetysystem channel, but the startup channel is not listed as a required measuring channel(Table 1, TS 3.4.3). Please add this to the list of required measuring channels or,alternatively, provide a justification for not including this channel in TS 3.4.3, Table 1.8.TS 3.5.3 - Table 2 does not include the simultaneous rod withdrawal interlock, thecontrol rod position interlock (see last paragraph of TS 3.5.5), or the 10 kW pulseinterlock. (See Table II of the present TSs.) The action statement, TS 3.5.4.C, includesthe Transient Control Rod interlock. Is that the same as the control rod position interlockmentioned in the bases?9.TS 3.5.5 - In the first paragraph, the fuel temperature safety limit stated as 1000C is notconsistent with specification TS 2.1.3 (1).Second paragraph: Again, there is some confusion with regard to power level (1,250kW) and LSSS.

ENCLOSURE 10. TS 3.6.5 - First paragraph references an exposure rate for Ar-41 of 1.84E-4 microcuriesh/mL in SAR Chapter 11, Appendix A. We can't find this number (either in the originalAppendix A or the March 2006 update.)11.TS 3.7.5 refers to a fuel temperature LSSS. You have not specified a fuel temperatureLSSS, in the TSs, only a power LSSS. Please provide a correct bases. 12.TS 3.9.4B has a typo. The water conductivity Condition statement should read "..shall beless than 5 micromho/cm" and the Required Action statement B.2 should read "Restoreconductivity to less than 5 micromho/cm."13.TS 3.9.3(3) reads: "Water level above the core shall be at least 13 feet from the top ofthe core." Are you only taking credit for 13 ft of water for shielding during operation? What Tsat are you using for the CHFR calculations? Is it based on 13 ft or 16 ft ofwater?14.TS 3.9.4C -There is a number missing in the "Condition" statement.

15.TS 3.9.3 - It may well be true that, with 16 feet of water above the core, the contributionto pool surface dose rates from N-16 located below 13 feet of water is negligible. Butwhat if there is only 13 feet of water above the core? Ar e the dose rates still negligible? The 13 foot level needs to be justified.16.TS 3.9.5 -There is a verb missing from the last sentence (".........the r equirement_verified prior.......").17.TS 4.5.2 - The surveillances described in the Table do not include the simultaneous rodwithdrawal interlock or the 10 kW interlock. Please add these surveillances to TS 4.5.2or, alternatively, provide a justification for not including them.18.TS 4.7.2 and TS 4.7.3 - Should the reactivity worth of $0.40 be an absolute value?

19.TS 4.9.2 - Does the requirement to measure pool water conductivity at least every 20days also apply if the reactor is shut down? This is not clear from specification.Provide a justification for not including a surveillance requirement for pool water activityto ensure that the total activity released can be determined if a release of pool wateroccurs.20.TS 6.1a) -The SAR has undergone several versions. Please provide an organizationchart to TS 6.1 or, alternatively, provide a justification for not including it?21.TS 6.1a) and 6.1b) - One section refers to the University Radiation Safety Officer asURSO and the other refers to the same as RSO. Please make the TS consistent.22.TS 6.2b)4 - The present version of 10 CFR 50.59 no longer talks about unreviewedsafety questions. The wording should conform to 10 CFR 50.59(c)(1).23.TS 6.4b)4 -Same comment as above. 24.TS 6.4c)2- Same comment as above.

25.TS 6.11c) - (Note typo, should be "c", not "d") Initial notification should also be made toRegion, in accordance with 50.36(7)(ii). Also, TS 6.11(d) address should be changed toDirector, Division of Policy and Rulemaking (ZIP 20555).26.TS 3.8 does not allow a fuel element in the core with bend or elongation > 1/8 inch. Please include surveillance in TS 4.8.3 to ensure that TS 3.8 is not violated.

27.TS 5.3.3 - Explain why Experiment Reactivity limits are not absolute values.28.There should be a TS on fuel storage specifying < 0.9 Keff (see ANS 15.1, Sect.5.4). Also see G.1 and G.2 of the present TSs.29.TS 5.3 does not specify any limits on explosives (Section 2.d of Reg Guide 2.2). Pleaseprovide one or, alternatively, provide a justification for not including it.30.TS 3.5.3 contains a typo ("3" should be "2"). There is no action statement or basis forthis specification. Please explain.31.The thermal hydraulic analysis in the SAR uses 83 fuel elements, with the statement thatthis is conservative because more fuel elements w ill result in less heat production perelement. If so, should there not be a TS specifying a minimum of 83 elements?32.TS 6.4c)1 references section 3.8. Should this be sections 3.7, 4.7, and 5.3?

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

34.Is there the equivalent of the last two sentences of D.6 of the present TSs in the newTSs?35.Is there the equivalent of E.3 of the present TSs in the new TSs? How are the limits onpulsing handled if not by the maximum reactivity of the pulse rod?36.Is there the equivalent of E.11.a of the present TSs in the new TSs?

37.Is there the equivalent of E.4 of the present TSs in the new TSs? TS 4.6.2 is notequivalent.38.Are the equivalent of I.4 and I.5 of the present TSs in the new TSs?