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| | number = ML20154J408 | | | number = ML20154J408 |
| | issue date = 05/11/1988 | | | issue date = 05/11/1988 |
| | title = Responds to NRC 880419 Ltr Re Violations Noted in Insp Rept 50-188/88-01.Corrective actions:10CFR55.53(f) Will Be Interpreted to Mean That Continuous Presence of Reactor Operator Required | | | title = Responds to NRC Re Violations Noted in Insp Rept 50-188/88-01.Corrective actions:10CFR55.53(f) Will Be Interpreted to Mean That Continuous Presence of Reactor Operator Required |
| | author name = Faw R | | | author name = Faw R |
| | author affiliation = KANSAS STATE UNIV., MANHATTAN, KS | | | author affiliation = KANSAS STATE UNIV., MANHATTAN, KS |
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| | contact person = | | | contact person = |
| | document report number = NUDOCS 8805260339 | | | document report number = NUDOCS 8805260339 |
| | | title reference date = 04-19-1988 |
| | document type = CORRESPONDENCE-LETTERS, EDUCATIONAL INSTITUTION TO NRC, INCOMING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, EDUCATIONAL INSTITUTION TO NRC, INCOMING CORRESPONDENCE |
| | page count = 5 | | | page count = 5 |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P6761999-10-26026 October 1999 Informs That Effective 991026,SW Holmes Will Be NRC Inspector for Kansas State Univ Nuclear Reactor Facility ML20138H3711999-10-25025 October 1999 Ack Receipt of ,Enclosing Rev to Kansas State Univ Triga Mk II Nuclear Reactor Emergency Plan Dtd March 1999. Based on Determination That Changes to Not Decrease Effectiveness of Plan,No NRC Approval Required ML20217A4521999-10-0404 October 1999 Forwards Proprietary Special Nuclear Matl Status Forms 741, 742 & 742C for Period 990401 to 990930 for Kansas State Univ Triga Mark II Nuclear Reactor Facility,Under Licenses R-88 & 38-C011-01.Proprietary Encls Withheld ML20216G6111999-09-24024 September 1999 Forwards Insp Rept 50-188/99-201 on 990830-0902.No Safety Concerns or Noncompliance to NRC Requirements Identified ML20210C2761999-07-14014 July 1999 Informs That Reactor Safeguards Committee Held Meeting to Evaluate Operation Under Plan,To Rept on Progress to Hire Permanent Replacement for Brendan & to Consider Whether Adjustments in Plan Were Appropriate ML20209C3471999-07-0101 July 1999 Informs That B Ryan Served as Reactor Supervisor & Facility Manager.Ryan Has Resigned Effective 990701,to Accept Position at Wolfcreek Npp.Until Replacement Found, Temporary Listed Changes Will Be Made ML20196A2521999-06-11011 June 1999 Discusses Initial Exam Conducted Wk of 990517.Findings Discussed with Staff & Identified in Encl Rept.Without Encl ML20204H0281999-03-22022 March 1999 Discusses Arrangements Made for Administration of Operator Licensing Exams at Kansas State Univ Scheduled for Week of 990517 & Requests Licensee Furnish One Set of Reference Matl Listed in Encl 1 ML20202C3711999-01-15015 January 1999 Informs of Change to Kansas State Univ Sar,Per Recent Telcon.Several Modifications to Reactor Own Ventilation Have Been Undertaken,In Order to Meet Intent of SAR ML20198K8021998-12-21021 December 1998 Forwards Amend 12 to License R-88 & Safety Evaluation.Amend Designates Dept Head of Mechanical & Nuclear Engineering Dept as Chairman of Reactor Safeguards Committee in TS H.2 ML20155C5111998-10-28028 October 1998 Forwards Amend 11 to License R-88 & Safety Evaluation.Amend Deletes License Condition 3.E,which Required That Physical Security Plan Be Maintained ML20154G1231998-10-0404 October 1998 Submits Listed Changes for Kansas State Univ Triga Mark II Nuclear Reactor for Period of 971001-980930,per 10CFR50.59(b) ML20237B4551998-08-13013 August 1998 Forwards New Copy of Kansas State Univ Triga Mark II Physical Security Plan W/Changes Highlighted,As follow-up to 980619 Submittal.Elimination of Licensee Physical Security Plan as Licensed Document,Requested.Encl Withheld ML20249B8421998-06-19019 June 1998 Forwards Revised Proprietary Copy of Physical Security Plan for Kansas State Univ Triga Mark II Nuclear Reactor.Current Changes Editorial in Nature.Proprietary Encl Withheld ML20247M7161998-05-20020 May 1998 Informs That HV Rectanus,SOP-70187,no Longer Performs Duties of Licensed SRO at Kansas State Univ ML20248L7751998-03-10010 March 1998 Transmits Four RO Candidates & 1 SRO Candidate for Operator License Certificates for Kansas State Univ ML20203H7841998-02-25025 February 1998 Forwards Results of Operator Initial Exam Conducted at Kansas State Univ on 980209-11.W/o Encl ML20199E8021997-11-12012 November 1997 Responds to Telcon Between W Eresian & BC Ryan Re Arrangements for Administration of Operator Licensing Exams at Kansas State Univ.Exams Scheduled for Week of 980209 ML20217H9151997-10-13013 October 1997 Informs That J Monzon No Longer Performs Duties of Licensed Reactor Operator at Kansas State Univ ML20138H5741997-05-0202 May 1997 Forwards Insp Rept 50-188/97-01 on 970407-11.No Violations Noted ML20134A3221997-01-24024 January 1997 Informs That BC Ryan Replaced R Faw as Official Representative for Facility.New Address as Submitted ML20134M6491996-11-21021 November 1996 Ack Receipt of from R Faw,Which Transmitted Changes to Emergency Plan for Kansas State Univ Triga Mk II Nuclear Reactor Facility,Submitted Under Provisions of 10CFR50.54(q) ML20134F1281996-10-30030 October 1996 Forwards Amend 10 to License R-88 & Safety Evaluation.Amend Revises Titles of Members of Reactor Safeguards Committee Due to Merger of Dept of Nuclear Engineering & Mechanical Engineering at Univ ML20128H4871996-10-0707 October 1996 Forwards Results of Operator Initial Exam Conducted at Kansas State Univ on 960924-25.W/o Encl ML20128H6391996-10-0707 October 1996 Forwards Results of Operation Initial Exam Conducted at Kansas State Univ on 960924-25.W/o Encl ML20129H1571996-10-0101 October 1996 Submits Changes Re Facility,Procedures & Tests and Experiments for Oct 1995-Sept 1996 ML20116J9931996-08-0606 August 1996 Re-affirms Intention of Ks State Univ to Apply for Extension of Operating License for 250-kW Pulsing Triga Reactor ML20093E8541995-10-0909 October 1995 Advises That No Changes in Facility,Procedures & Test & Experiments Made During Oct 1994-Sept 1995 ML20086A0771995-06-19019 June 1995 Advises NRC That Licensee Existing Control of Access to Radiation Beams Adequate to Protect Individuals from over- Exposure & to Assure Compliance w/10CFR20.1601 ML20070N3861994-04-21021 April 1994 Informs That on 940420,intrusion Alarm Sys for Facility Failed Due to Failure of Electrical Relay in Alarm Unit at Police Dept.Relay Replaced,Unit Returned to Service & Functional Performance Test Conducted ML20059H1611993-11-0202 November 1993 Informs That Listed Ref Matl Requested Prior to Administration of Operator Licensing Exams Scheduled for Wk of 930411 at Kansas State Univ Reactor ML20059M4191993-09-17017 September 1993 Responds to Submitted on Behalf of Constituent Kansas State Univ Re Commission Recent Decision to Assess Annual Fees to Nonprofit Educational Institutions Holding NRC Licenses or Other Approvals ML20056G6471993-08-27027 August 1993 Responds to Re NRC Assessment of Annual Fees to Kansas State Univ,Manhattan,Ks ML20056G6621993-08-23023 August 1993 Expresses Thanks for Extension of Deadlines for Payment of 1993 Annual Fees Announced in NRC Delineating Options Available to non-profit Licenses Re Biling for 1993 Annual Fees ML20059M4521993-08-17017 August 1993 Urges NRC Approval of Kansas State Univ Request for Exemption from Payment of Licensing Fees,Per 10CFR171.11(b) ML20056G6651993-08-10010 August 1993 Urges NRC to Favorably Consider Kansas State Univ Appeal for Exemption from Licensing Fees ML20029D5991993-08-0404 August 1993 Endorses 930727 Request for Individual Exemption from Payment of Annual Fees for Triga Mark II Reactor ML20046D3531993-08-0404 August 1993 Requests Exemption from Payment of Annual Fees for Triga Mark II Reactor ML20056D2691993-08-0303 August 1993 Forwards Rev to Physical Security Plan for Univ Triga Mark II Reactor Facility.Withheld Per 10CFR2.790 ML20029D5971993-08-0202 August 1993 Endorses 930727 Request for Individual Exemption from Payment of Annual Fees for Triga Mark II Reactor ML20046D3501993-08-0202 August 1993 Endorses 930727 Request for Exemption from Payment of Annual Fees for FY93 for Listed Reasons,W/Regard to Invoice AT-0464-93 ML20046D3551993-07-27027 July 1993 Requests Individual Exemption from Payment of Annual Fees for FY93,per 10CFR171.11(b) ML20029D5931993-07-27027 July 1993 Requests Individual Exemption from Payment of Annual Fees for Kansas State Univ Triga Mark II Nuclear Reactor ML20045G5861993-07-0606 July 1993 Forwards Response to 930616 Ltr Re Violations Noted in Insp Rept 50-188/93-01 on 930524-28.Encls Withheld ML20056C3581993-05-0707 May 1993 Forwards Requalification Exam Rept 50-188/OL-93-01 on 930428-29 ML20128G2041993-02-0808 February 1993 Accepts Changes to 920918 Ks State Univ Research Reactor Emergency Plan,Rev 2.Plan Maintains Compliance w/10CFR50, App E ML20127J6521993-01-13013 January 1993 Forwards Emergency Plan,Reflecting Items Stricken from Newest Rev as Advised by Univ Reactor Safeguards Committee. Memo Sent to Facility Director Outlining Mods Suggested by Newest Rev of EPA Protective Action Guides Also Encl ML20099F5501992-08-0606 August 1992 Advises That J Kirkland Replaces M Burger as Reactor Supervisor for Ks State Univ Triga Reactor Facility, Effective 920818 ML20081L0241991-06-18018 June 1991 Advises That Effective 910618,MJ Burger Will Replace Dj Whitfill as Reactor Supervisor for Univ Reactor ML20073E7331991-04-11011 April 1991 Forwards Proposed Rev to Physical Security Plan,Reflecting Change in Type of Intrusion Alarm.Rev Withheld 1999-09-24
[Table view] Category:EDUCATIONAL INSTITUTION TO NRC
MONTHYEARML20055H9571990-07-17017 July 1990 Forwards Preliminary Cost Estimate for Decommissioning Reactor.Cost Estimate Based on Methods Described in May 1989 NRC Draft Reg Guide on Assuring Availability of Funds for Decommissioning Nuclear Reactors ML20244B3091989-03-29029 March 1989 Responds to NRC Re Violations Noted in Insp Rept 50-188/89-01.Corrective Actions:Procedure Re Entrance to Reactor Bay Revised to Include Provisions for Key Control, Accountability & Compliance Audit ML20235X8281988-08-0101 August 1988 Notifies That Emergency Exercise Will Be Conducted on 880812,involving Notifications of Declarations of Unusual Event,Alert & Cancellation by Telephone ML20154J4081988-05-11011 May 1988 Responds to NRC Re Violations Noted in Insp Rept 50-188/88-01.Corrective actions:10CFR55.53(f) Will Be Interpreted to Mean That Continuous Presence of Reactor Operator Required ML20214L9071987-05-21021 May 1987 Advises That Effective on 870527,JL Daniels Appointed Reactor Supervisor for Univ of Kansas Triga MK-II Nuclear Reactor Facility.Daniels Replaces J Higginbotham ML20214P1281986-11-17017 November 1986 Forwards Response to Violations Noted in Insp Rept 50-188/86-02.Corrective Actions:At Time of Next Calibr, Instruments Not Required for Reactor Surveillance Will Be Sequestered in Storage Location ML20204E7651986-07-24024 July 1986 Advises of Emergency Exercise Scheduled for 860807 in Order to Meet Requirements of Emergency Plan.Nrc Will Be Notified on 860807 of Unusual Event,Alert & Closeout.Scenario Does Not Require Response from Offsite Agency ML20100A8631984-11-27027 November 1984 Advises That Emergency Plan Fully Implemented,Effective 841127 ML20096A4431984-08-20020 August 1984 Ack Receipt of 840813 Emergency Plan Evaluation Rept.Last Paragraph on Page 2 of Rept in Error.Operations Boundary Encompasses Reactor Facility Room 110 of Ward Hall,Per Paragraph 1.1 of Emergency Plan ML20092J8671984-06-20020 June 1984 Forwards Revised Emergency Plan for Kansas State Univ Triga Mark II Nuclear Reactor Facility, in Response to 840504 Request.List of Revs Encl ML20076G7721983-06-10010 June 1983 Advises of Appointment of J Higginbotham as Reactor Supervisor,Effective 830601 ML20049J3431982-03-0909 March 1982 Discusses Power Fluctuations of Triga Reactor Originally Reported 810813.Mods to Primary Coolant Diffuser Nozzle Eliminated Power fluctuations.Ni-16 Levels at Pool Surface Not Affected ML19350C2001981-03-26026 March 1981 Responds to Questions Re Power Fluctuations at Triga Mark Ii.Fluctuations Are Generic to Triga Reactors Cooled by Natural Convection ML19337B5821980-10-0202 October 1980 Submits Changes in Procedures & Facility for Oct 1979-Sept 1980.Includes Tests & Experiments Conducted W/O Prior NRC Approval ML19254E9931979-10-25025 October 1979 Submits Info Re Procedure Changes,Tests & Experiments Conducted W/O Prior NRC Approval & Changes in Facility for Jul 1978-Sept 1979 ML19260A0031979-10-23023 October 1979 Forwards Executed Amend 12 to Idemnity Agreement E-1 Modifying Prefatory Language Re Transportation of Radioactive Matl ML19210D3821979-09-25025 September 1979 Responds to IE Bulletin 79-19.Facility Does Not Generate Low Level Radwaste ML20071G6601979-05-17017 May 1979 Forwards Amend 11 to Indemnity Agreement E-1 ML20062A1101978-09-25025 September 1978 Forwards Changes in Procedures for Aug 1977-June 1978: Biennial Control Rod Insp,Fuel Element Insp & Reactor Startup W/Period Scram Bypassed 1990-07-17
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20210C2761999-07-14014 July 1999 Informs That Reactor Safeguards Committee Held Meeting to Evaluate Operation Under Plan,To Rept on Progress to Hire Permanent Replacement for Brendan & to Consider Whether Adjustments in Plan Were Appropriate ML20209C3471999-07-0101 July 1999 Informs That B Ryan Served as Reactor Supervisor & Facility Manager.Ryan Has Resigned Effective 990701,to Accept Position at Wolfcreek Npp.Until Replacement Found, Temporary Listed Changes Will Be Made ML20202C3711999-01-15015 January 1999 Informs of Change to Kansas State Univ Sar,Per Recent Telcon.Several Modifications to Reactor Own Ventilation Have Been Undertaken,In Order to Meet Intent of SAR ML20154G1231998-10-0404 October 1998 Submits Listed Changes for Kansas State Univ Triga Mark II Nuclear Reactor for Period of 971001-980930,per 10CFR50.59(b) ML20237B4551998-08-13013 August 1998 Forwards New Copy of Kansas State Univ Triga Mark II Physical Security Plan W/Changes Highlighted,As follow-up to 980619 Submittal.Elimination of Licensee Physical Security Plan as Licensed Document,Requested.Encl Withheld ML20249B8421998-06-19019 June 1998 Forwards Revised Proprietary Copy of Physical Security Plan for Kansas State Univ Triga Mark II Nuclear Reactor.Current Changes Editorial in Nature.Proprietary Encl Withheld ML20247M7161998-05-20020 May 1998 Informs That HV Rectanus,SOP-70187,no Longer Performs Duties of Licensed SRO at Kansas State Univ ML20217H9151997-10-13013 October 1997 Informs That J Monzon No Longer Performs Duties of Licensed Reactor Operator at Kansas State Univ ML20134A3221997-01-24024 January 1997 Informs That BC Ryan Replaced R Faw as Official Representative for Facility.New Address as Submitted ML20129H1571996-10-0101 October 1996 Submits Changes Re Facility,Procedures & Tests and Experiments for Oct 1995-Sept 1996 ML20116J9931996-08-0606 August 1996 Re-affirms Intention of Ks State Univ to Apply for Extension of Operating License for 250-kW Pulsing Triga Reactor ML20093E8541995-10-0909 October 1995 Advises That No Changes in Facility,Procedures & Test & Experiments Made During Oct 1994-Sept 1995 ML20086A0771995-06-19019 June 1995 Advises NRC That Licensee Existing Control of Access to Radiation Beams Adequate to Protect Individuals from over- Exposure & to Assure Compliance w/10CFR20.1601 ML20070N3861994-04-21021 April 1994 Informs That on 940420,intrusion Alarm Sys for Facility Failed Due to Failure of Electrical Relay in Alarm Unit at Police Dept.Relay Replaced,Unit Returned to Service & Functional Performance Test Conducted ML20056G6621993-08-23023 August 1993 Expresses Thanks for Extension of Deadlines for Payment of 1993 Annual Fees Announced in NRC Delineating Options Available to non-profit Licenses Re Biling for 1993 Annual Fees ML20059M4521993-08-17017 August 1993 Urges NRC Approval of Kansas State Univ Request for Exemption from Payment of Licensing Fees,Per 10CFR171.11(b) ML20056G6651993-08-10010 August 1993 Urges NRC to Favorably Consider Kansas State Univ Appeal for Exemption from Licensing Fees ML20029D5991993-08-0404 August 1993 Endorses 930727 Request for Individual Exemption from Payment of Annual Fees for Triga Mark II Reactor ML20046D3531993-08-0404 August 1993 Requests Exemption from Payment of Annual Fees for Triga Mark II Reactor ML20056D2691993-08-0303 August 1993 Forwards Rev to Physical Security Plan for Univ Triga Mark II Reactor Facility.Withheld Per 10CFR2.790 ML20029D5971993-08-0202 August 1993 Endorses 930727 Request for Individual Exemption from Payment of Annual Fees for Triga Mark II Reactor ML20046D3501993-08-0202 August 1993 Endorses 930727 Request for Exemption from Payment of Annual Fees for FY93 for Listed Reasons,W/Regard to Invoice AT-0464-93 ML20029D5931993-07-27027 July 1993 Requests Individual Exemption from Payment of Annual Fees for Kansas State Univ Triga Mark II Nuclear Reactor ML20046D3551993-07-27027 July 1993 Requests Individual Exemption from Payment of Annual Fees for FY93,per 10CFR171.11(b) ML20045G5861993-07-0606 July 1993 Forwards Response to 930616 Ltr Re Violations Noted in Insp Rept 50-188/93-01 on 930524-28.Encls Withheld ML20127J6521993-01-13013 January 1993 Forwards Emergency Plan,Reflecting Items Stricken from Newest Rev as Advised by Univ Reactor Safeguards Committee. Memo Sent to Facility Director Outlining Mods Suggested by Newest Rev of EPA Protective Action Guides Also Encl ML20099F5501992-08-0606 August 1992 Advises That J Kirkland Replaces M Burger as Reactor Supervisor for Ks State Univ Triga Reactor Facility, Effective 920818 ML20081L0241991-06-18018 June 1991 Advises That Effective 910618,MJ Burger Will Replace Dj Whitfill as Reactor Supervisor for Univ Reactor ML20073E7331991-04-11011 April 1991 Forwards Proposed Rev to Physical Security Plan,Reflecting Change in Type of Intrusion Alarm.Rev Withheld ML20055H9571990-07-17017 July 1990 Forwards Preliminary Cost Estimate for Decommissioning Reactor.Cost Estimate Based on Methods Described in May 1989 NRC Draft Reg Guide on Assuring Availability of Funds for Decommissioning Nuclear Reactors ML20244B3091989-03-29029 March 1989 Responds to NRC Re Violations Noted in Insp Rept 50-188/89-01.Corrective Actions:Procedure Re Entrance to Reactor Bay Revised to Include Provisions for Key Control, Accountability & Compliance Audit ML20235X8281988-08-0101 August 1988 Notifies That Emergency Exercise Will Be Conducted on 880812,involving Notifications of Declarations of Unusual Event,Alert & Cancellation by Telephone ML20154J4081988-05-11011 May 1988 Responds to NRC Re Violations Noted in Insp Rept 50-188/88-01.Corrective actions:10CFR55.53(f) Will Be Interpreted to Mean That Continuous Presence of Reactor Operator Required ML20214L9071987-05-21021 May 1987 Advises That Effective on 870527,JL Daniels Appointed Reactor Supervisor for Univ of Kansas Triga MK-II Nuclear Reactor Facility.Daniels Replaces J Higginbotham ML20214P1281986-11-17017 November 1986 Forwards Response to Violations Noted in Insp Rept 50-188/86-02.Corrective Actions:At Time of Next Calibr, Instruments Not Required for Reactor Surveillance Will Be Sequestered in Storage Location ML20204E7651986-07-24024 July 1986 Advises of Emergency Exercise Scheduled for 860807 in Order to Meet Requirements of Emergency Plan.Nrc Will Be Notified on 860807 of Unusual Event,Alert & Closeout.Scenario Does Not Require Response from Offsite Agency ML20100A8631984-11-27027 November 1984 Advises That Emergency Plan Fully Implemented,Effective 841127 ML20096A4431984-08-20020 August 1984 Ack Receipt of 840813 Emergency Plan Evaluation Rept.Last Paragraph on Page 2 of Rept in Error.Operations Boundary Encompasses Reactor Facility Room 110 of Ward Hall,Per Paragraph 1.1 of Emergency Plan ML20092J8671984-06-20020 June 1984 Forwards Revised Emergency Plan for Kansas State Univ Triga Mark II Nuclear Reactor Facility, in Response to 840504 Request.List of Revs Encl ML20076G7721983-06-10010 June 1983 Advises of Appointment of J Higginbotham as Reactor Supervisor,Effective 830601 ML20049J3431982-03-0909 March 1982 Discusses Power Fluctuations of Triga Reactor Originally Reported 810813.Mods to Primary Coolant Diffuser Nozzle Eliminated Power fluctuations.Ni-16 Levels at Pool Surface Not Affected ML19350C2001981-03-26026 March 1981 Responds to Questions Re Power Fluctuations at Triga Mark Ii.Fluctuations Are Generic to Triga Reactors Cooled by Natural Convection ML19337B5821980-10-0202 October 1980 Submits Changes in Procedures & Facility for Oct 1979-Sept 1980.Includes Tests & Experiments Conducted W/O Prior NRC Approval ML19254E9931979-10-25025 October 1979 Submits Info Re Procedure Changes,Tests & Experiments Conducted W/O Prior NRC Approval & Changes in Facility for Jul 1978-Sept 1979 ML19260A0031979-10-23023 October 1979 Forwards Executed Amend 12 to Idemnity Agreement E-1 Modifying Prefatory Language Re Transportation of Radioactive Matl ML19210D3821979-09-25025 September 1979 Responds to IE Bulletin 79-19.Facility Does Not Generate Low Level Radwaste ML20071G6601979-05-17017 May 1979 Forwards Amend 11 to Indemnity Agreement E-1 ML20062A1101978-09-25025 September 1978 Forwards Changes in Procedures for Aug 1977-June 1978: Biennial Control Rod Insp,Fuel Element Insp & Reactor Startup W/Period Scram Bypassed 1999-07-14
[Table view] |
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6 /ri. Department of Nuclear Engineering 9 g {g gg IQoGQISAS Ward Hall STATE unrvrasrry 9i>E*$.'*e"d*"***65 MAY I 81988 ,
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May 11, 19S8 U.S. Nuclear Regulatory Commission Division of Reactor Projects ATTN: L. J. Callan, Director Gil Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Re: License R-SS Docket 50-1SS/SS-01 i
! Centlemen:
This is in response to your letter of 19 Apr SS dealing with the inspection of 8-10 Mar SS conducted by Mssrs. G. A. Pick and R. J. Evans of your office. Responses to notices of violation and deviation are attached.
Sincerely, t ./0 Richard E. Faw, Director
! KSU Nuclear Reactor Faci!ity REF/cs i cc: Reactor Safeguards Committee t
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8805260339 880511 l f(j% hDR ADOCK 0500< 8 \
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Response to Notice of Violation Kansas State University Docket 50-188/88-01 Kansas State University Nuclear Reactor Facility License R-88 Notice The code of Federal Regulations, 10 CFR 55.53(e) requires that operators shall actively perform a minimum of 4 nours of licensed operator activities per calendar quarter at a research reactor. If this requirement is not met, 10 CFR 55.53(f) requires that before resumption of functions authorized by a license issued under this part, an authorized representative of the facility licensee shall certify the following:
(1) That the qualifications and status of the licensee are current and valid; and (2) That the licensee has completed a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The G hours must have included a complete tour of the plant and all required shif t turnover procedures.
Contrary to the above, during the third calendar quarter in 1987, t. licensed senior operator performed licensee functions for only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The senior operator during the fourth calendar quarter in 1987 performed active license functions without being under the direction of another licensed individual.
Response
It is admitted that a technical violation occurred despite good-faith ef ferts to meet requirements of new regulations and guidelines issued within and 'just '
prior to the time periods identified in the citation.
During the third calendar quarter of 1987, it was recognized that the license of one of our senior operators was not active, although all requalification requirements had been met. We were aware that meetings were held in April 1987 concerning revisions of 10CFR55, we were not aware of the date of effectiveness. Therefore we contacted the Region IV Office of the NRC on 31 Aug S7 to inquire about new requirements for license reactivation. Efforts were undertaken in the third and fourth calendar quarters of 1987 to reactivate the license. These efforts were not completed, and no claim was made that the license was active. Efforts were resumed in the first calendar quarter of 19S8 to reactivate the license and were successful.
As to the operations performed in the third calendar quarter of 1987, these l
were not considered by us to be "active license functions." Rather, they were based on our interpretation of 10CFR55.53(f), specifically the words, "... ,
under the direction of an operator or senior operator as appropriate." To us, appropriate direction of an operator at a research reactor facility, having met all requirements of the requalification program and seeking to reactivate an operator license, required supervision by but not the continuous presence of a senior reactor operator. Indeed, we were pleased that the newly issued i
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l Response to Notice of Violation (cont'd.J version of 10CFR55 seemed to give more flexibility to reactor facility management than did the older version of 10CFR55.
Reasons for the Violation Misinterpretation of the wording of 10CFR55.53(f).
Corrective Steps We now interpret 10CFR55.53(f) to mean that appropriate direction implies that continuous presence of a reactor operator is required.
Date of Full Compliance We are now in full compliance with 10CFR55.53(f).
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Response to Notice of Deviation Kansas State University Docket 50-188/88-01 Kansas State University Nuclear Reactor Facility License R-88 Notice The Hazard Summary Report,Section II.7.0, Operations logbook, Step 2, states "All scrams and their cause as well as malfunctions of equipment must be entered in the logbook in red."
In deviation from the above, the licensee was found to have highlighted in red only one of ten equipment malfunctions, between the dates May 19S6 through March 8, 1988. (188/8S01-01).
Response
We acknowledge a dif ference of opinion as to the intent of Section II.7,0, Step 2 of the Hazards Sunnary Report. We believe that the "red ink" feature of Step 2, taken not as an isolated sentence but in the context of the entire section, relates to unintentional scrams or equipment malfunctions during operation which challenge safety limits or limiting conditions for operation.
We assert that intentional scrams, often generated for operational
- or training purposes, need not be entered "in red." Further, we assert that there is a substantial distinction between malfunction of safety-related equipment during operation and circumstances of equipment, either redundant or not required for operation, being out of service awaiting repair or replacement.
Entering unintentional scrams "in red" has been very ef fective in alerting inspectors of potential problems in operations or indeed in identifying problems in equipment performance. So far as we can recall, intentional scrams have never been logged "in red" during the past twenty-five years of reactor operations. To have done so would have negated the intent of the Hazards Summary Report and prevented real problems from being identified.
Similar crguments can be made for not logging "in red" items of non-essential
, equipment "out of service." We urge that you reconsider your position on this l point. We suggest that the intent of the liazards Summary Report will be met l and that public safety will be served best if, in Section II.7.0, Step 2, the l term "scrams" be interpreted as "unintentional scrams" and the phrase "malfunctions of equipment" be interpreted as "operational malfunctions of essential equipment."
! *For many years, the only way of inserting the safety rod into the reactor l core was to perform an intentional scram.
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- Response to Inspection Report-Kansas State University Docket 50-188/88 Kansas State University Nuclear Reactor Facility License R88 Item: Losts and Records
Response
Monthly operations reports are documents prepared for internal use by the Facility management and the Reactor Safeguards Committee. They have been offered to NRC inspectors as a convenience to their activities. Reports are ,
prepared by the Reactor Supervisor or his designee and transmitted to the Facility Director.
Of the four "administrative errors" mentioned, one was a typographical error so obvious as to be ignored by the Director. Three were deliberate omissions on the part of the Supervisor, to signal that actions were called for by the Director. After the actions were completed, their dates of completion were recorded in the subsequent monthly reports, a process perfectly acceptable to us in conducting our internal business.
Item: Review and Audit l
Response
The statement that "The Facility Director . . . did not appear to have a working knowledge of 10CFR50.59" is unsupported and, we believe, ;
- unsupportable. It is a gratuitous indictment of the Facility management that '
- cannot be left unchallenged. If, indeed, the Facility Director is deficient l in .this knowledge, central to his responsibilities, then evidence should bc l
brought before University officials so that the evidence and its rebuttal could be considered objectively and, if appropriate, disciplinary action i taken.
Item: Experiments i Resoonse:
This concerns limits imposed by Experiment 1. To be sure, the experiment limits the mass of an unknown target to 100 mg and requires that calculations ,
l of estimated induced source strengths be recorded in the Byproducts Log (Form KSUTMII-4). Instructions in the Byproduct Log do indeed provide written guidance that samples of unknown composition not be irradiated for more than ,
one minute at 100 watts thermal power. That the staff choose to follow more !
l restrictive practices than required by the Safeguards Committee does not require that the more restrictive practices be "hardened" by their incorporation into a procedure. There are many instances of Safeguards
- Comi ttee requirements being more restrictive than NRC regulations or Technical Specification requirements. There seems to be no reason why operations staff cannot follow guidelines more restrictive than those imposed by the Reactor Safeguards Comittee.
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