IR 05000188/1986002: Difference between revisions

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{{Adams
{{Adams
| number = ML20203P182
| number = ML20212E228
| issue date = 10/15/1986
| issue date = 12/24/1986
| title = Partially Withheld Insp Rept 50-188/86-02 on 860909-10. Violation Noted:Failure to Perform Semiannual Calibr of Listed Portable Survey Instruments & Written Instruction Not in Effect for Spectroscopy Sys
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-188/86-02
| author name = Murray B, Wise R
| author name = Gagliardo J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Faw R
| addressee affiliation =  
| addressee affiliation = KANSAS STATE UNIV., MANHATTAN, KS
| docket = 05000188
| docket = 05000188
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-188-86-02, 50-188-86-2, NUDOCS 8610270093
| document report number = NUDOCS 8701050278
| package number = ML20203P177
| title reference date = 11-17-1986
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO EDUCATIONAL INSTITUTION, OUTGOING CORRESPONDENCE
| page count = 8
| page count = 1
}}
}}


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I APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
  ., 4 DEC 2 41986 in Reply Refer To:
. REGION IV NRC Inspection Report: 50-188/86-02 License: R-88 Docket: 50-188 Licensee: Kansas State University (KSU)
Docket: 50-188/86-02 Kansas State University Department of Nuclear Engineering ATTN: Dr. R. E. Faw, Director Nuclear Reactor Facility Manhattan, Kansas 66505 Gentlemen:
Department of Nuclear Engineering Manhattan, Kansas 66505 Facility Name: Kansas State University Inspection At: Manhattan, Kansas Inspection Conducted: September 9-10, 1986 Inspector: <^="''-"=
Thank you for your letter of November 17, 1986, in response to our letter
  -
      /0//f/~ M Russell Wise, Radiation Specialist, Facilities Date Radiological Protection Section f
Approved:  jd)tATgf BaineMurray(,Lhief,F)cilitiesRadiologicalDate
_    ///[/ 9/h
      /
Protection Section /
Inspection Summar Inspection Conducted September 9-10, 1986 (Report 50-188/86-02)
Areas Inspected: Routine, unannounced inspection of the licensee's program including: (1) radiation protection, (2) emergency preparedness, (3) material accountability, and (4) physical securit Results- Within the areas inspected, three violations were identified (see paragraphs 3.a. 3.d, and 3.e).


FM.Af OVAL CF THE PAGES M ARKEO " SAFEGUARDS I pECONTROLS THE REMAINDER OF THIS DOCUMEN ,
and Notice of Violation dated October 20, 1986. We have reviewed your reply    l and find it responsive to the concerns raised in our Notice of Violation. We    l will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintai,ed.
8610270093 861020 PDR ADOCK 05000188 G  PDR


.
Sincerely, ORIGINAL SIGNED BY:
. DETAILS Persons Contacted
J. E. Gagliardo, Chief Reactor Projects Branch cc:
  *N. D. Eckhoff, Department Head, Nuclear Engineering
Kansas Radiation Control Program bec to DMB (IE06)
  *R. E. Faw, Director, Nuclear Reactor Facility (NRF)
bcc distrib. by RIV:
  *J. F. Higginbotham, Reactor Supervisor
RPB    Resident Inspector R. D. Martin, RA    R&SPB Section Chief (RPB/B)    D. Weiss, LFMB (AR-2015)
  *F. L. Ferguson, General Manager, Physical Facilities
RIV File    DRSP RSB    MIS SYSTEM RSTS Operator    Inspector Section Chief    W. L. Fisher R. L. Bangart    J. J. Dosa, NRR, Project Manager RIV:FRP C:FRPS  C:R&SPB  CRPB [
  *J. Lambert, Radiation Safety Of ficer
g    ,
  *G. Simonis, Professor
Wi se/j t BMurqay  WLFisher  JEGaghfrdo p to/ 86 y /gb/86  lg/jd/86  4,/Dj/86
  *J. Daniels, Reactor Operator
 
  * J. Whitfield, Reactor Operator R. Tout, M.D., Director, Student Health Center C. A. Beckom, Chief, KSU Police G. D. Westcott, Industrial Hygienist E. M. Hupe, Administrative Officer, Physical Facilities
e701050278 861224 PDR O
  * Denotes those present during the exit briefin . Inspector Observation The following are observations the NRC inspectors discussed with the licensee during the exit meeting on [[Exit meeting date::September 10, 1986]]. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requiremen Documentation of Instrumentation Calibration / Response Tests - Records of portable survey instrument calibrations and alarm setpoint tests did not indicate what calibration source was used or who had performed the calibratio (See paragraph 3.a.) Calibration of Area Monitor - The area radiation monitor which actuates the evacuation alarm is not currently calibrated above 100 mR/ (See paragraph 3.b.) Personnel Monitoring - Personnel monitoring devices were not approved by National Voluntary Laboratory Accreditation for Personnel i  Dosimetry (NVLAP).  (See paragraph 3.d.) Neutron Surveys - Neutron radiation levels had not been establishe (See paragraph 3.f.)
ADOCK 05000188 PDR
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' CFR Part 19.12 Training - Documentation of radiation worker
,
, training did not include all categories of instruction in
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10 CFR 19.1 (See paragraph 3.g.)
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Department of Nuclear Engineering ICAlqSAS  Ward Hall N
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November 17, 1986 U.S. Nuclear Regulatory Commission Region IV Attn: J. E. Gagliardo, Chief Reactor Projects Branch 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 Re: License R-88 Docket 50-188


, Emergency Equipment - A high range instrument was not available in an
==Dear Sirs:==
;  emergency ki (See paragraph 4.)
This is in response to your letter of 20 October 1986 and its attendant notice of violation. Our response is enclosed.


REMOVAL OF THE PAGES MARKED " "
Sincerely, et<f f hin V Richard E. Faw, Director KSU Nuclear Reactor Facility REF/cs Enclosure
DECONTROLS THE REMAINDER OF THIS DOCUMEN . . _ . - . - _ . , _ _ _ . . _ . . . . - _ _ . . . , _ -
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RESPONSE TO NOTICE OF VIOLATION
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Kansas State University (KSU)  Docket: 50-188/86-02 TRICA MkII Reactor  License: R-88 A. Failure to Perform Survey Instrument Calibration Reason for Violation This violation is admitted. The reasons are as follows: The Reactor Facility maintains and calibrates instruments for general use in the Nuclear Engineering Department. On some occasions, these general-purpose instruments are in use outside the Reactor Facility at the time of reactor-instrument calibratior.. Record keeping procedures hase been deficient in identification of those occasions.


3
Cprrective Steos Taken New record keeping procedures have been implemented. A master log of calibration dates has been instituted to supplement calibration logs for each instrument.
, Key Control - Documentation of personnel authorized access to the NRF was not curren (See paragraph 8.) Radiation Protection The licensee's radiation protection program was inspected to determine compliance with the requirements of Technical Specifications (TS) F and H; 10 CFR Parts 19 and 20; the KSU Emergency Plan; and the recommendations of NRC Regulatory Guide (RG) The NRC inspector reviewed records, interviewed personnel, made observations, and performed independent survey Radiation Measuring Instrumentation The NRC inspector reviewed calibration records for portable radiation survey instrumentation for 1983, 1984, 1985, and 1986. It was noted that calibration standards utilized for calibration and the' person who was performing the survey instrument calibration was not recorded on the data sheet. The licensee stated at the exit briefing on September 10, 1986, that this observation would be reviewe The NRC inspector noted that calibration of portable survey instrumentation was required to be performed in accordance with Section 10.5 of the KSV Emergency Plan, dated October 14, 1982, which
;  states, in part, that portable survey instruments will be calibrated i
semiannuall It was noted from the review of calibration records that the following five portable radiation monitoring instruments had been used to determine radiation levels, but had not been calibrated semiannuall Eberline Model E-120, Serial Number (S/N) 915, June 1984 -
July 1985 i
Eberline Model E-120,.S/N 940, January - December 1985
;  Eberline Model E-500B, S/N 968, January - December 1985
!
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Eberline Model E-500B, S/N 1021, January - September 1985 Eberline Model E-510, S/N 153, July 1985 - June 1986 The feilure to calibrate radiation monitoring instruments semiannually as required is an apparent violation of Secticn 10.5 of the KSU Emergency Pla (188-8602-01) Area Radiation Monitors (ARMS)
The NRC inspector reviewed the licensee's calibration programs for ARMS which are required to be function tested daily during operations, response tested quarterly, and calibrated annuall REMOVAL OF THE PAGES MARKED " "
DECONTROLS THE REMAINDER OF THIS DOCUMEN __ . _ _ - .


    .
Corrective Steos to be Taken At the time of the next calibration, those instruments not required for reactor surveillance are to be sequestered in their own storage location.
.


.
All instruments are to be tagged with identification of their use (reactor or non-reactor) and the calibration expiration date.
, The NRC inspector noted that documentation regarding calibration of the ARM consists of a label placed on the readout panel of the instrument: no other documentation was utilized to indicate what sources were used, who performed the calibration, or the ranges of operation at which the instrument was calibrate The NRC inspector noted that an area radiation monitor identified in Section 8.3.1 of the KSU Emargency Plan, which actuates the ,
evacuation alarm at an exposure rate of 5 R/h, is only calibrated at an upper radiation level of 100 mR/h The NRC inspector discussed the need to calibrate instrumentation over the ranges of operation addressed in the Emergency Pla Continuous Air Monitor (CAM)
The NRC inspector reviewed the licensee's program for monitoring airborne concentrations within the reactor bay to determine compliance with Sections F and H of the TS and Section 8.3.1 of the Emergency Pla Section 8.3.1 of the Emergency Plan states that the CAM is sensitive to radioiodine and alarms at maximum permissible air concentrations of Iodine-131 in restricted areas. The licensee stated that the instrument is calibrated with a Technetium-99 source, but tha.t no direct comparison results were available from the calibration results to indicate the instruments' response to Iodine-131 level The NRC inspector informed the licensee that Iodine-131 concentration might be difficult to verify because of the masking effect of the noble gases that are produced in the reactor bay during operation The NRC inspector noted that the calibration of the CAM is documented only on the current calibration label placed on the readout meter of the' instrument; no other documentation was utilized to indicate what sources were used, who performed the calibration, or what ranges of operation the instrument was calibrate d. Personnel Monitoring The NRC inspector reviewed the NRF personnel radiation exposure records for 1983, 1984, 1985, and 198 The personnel monitoring devices are provided by the KSU radiation safety department. Two separate badges are utilized at KSU, a beta gamma badge for researchers and a neutron gamma badge for NRF staf The NRC inspectors noted that the licensee had not conducted testing of dosimeters as recommended in ANSI N13.11-198 The NRC inspector noted that the licensee had not developed written calibration and operating procedures for use of the TLD monitoring l system which is utilized for determining personnel exposures at KSU.


l REMOVAL OF THE PAGES MARKED  TION" " SAFEGUARD DECONTROLS THE REMAINDER OF THIS DOCUME
Date of Full Compliance All instruments are now in calibration. The next round of calibration will take place in Decerber 1986 and January 1987.
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B. Failure to Develon Written Procedures Reason for Violation
  - .
The absence of certain written procedures is not admitted. That these prccedures have not been approved by the Reactor er Safeguards Committee is admitted. Vendor-supplied instruction manuals for the systems in question are followed in their use. Such manuals have not been submitted to the Reactor Safeguards Connittee for its endorsement.


.
Corrective Steps to be Taken ,
TS, Section H, Administrative Requirements, paragraph 1, states
Operating procedures incorporating, by reference, vendor's instruction manuals will be prepared and submitted to the Reactor Safeguards Committee for endorsement.
" written instructions, approved by the Reactor Safeguards Committee, shall be in effect for, but not limited to:" specific areas noted in Section H. The failure to develop written procedures for calibration and operation of the TLD personnel monitoring system is an apparent violation of TS, Section H.1. (188/8602-02)
The NRC inspector noted that the licensee had not participated in the NVLAP program. The NRC inspector discussed with the licensee the forthcoming 10 CFR Part 20 requirement that personnel monitoring devices will need to be NVLAP accredite The NRC inspector noted that self reading dosimeters (SRD) are calibrated semiannually with a radioactive sourc However, the licensee does not routinely, prior to calibration, perform testing on SRDs to determine leakage. The NRC inspector discussed with the licensee the recommendations of NRC RG 8.4 concerning testing and calibration of SRD. The licensee stated at the exit briefing on September 10, 1986, that the NRC inspector's observation would be reviewe e. Environmental Surveillance / Radioactive Releases The NRC inspector reviewed records of analysis on sump drain liquid which is performed with a gamma spectroscopy syste The NRC inspector noted that the licensee had not developed written calibration and operating procedures for use of the gamma spectroscopy system which is routinely used to analyze sump drain water prior to release to unrestricted area TS, Section H, Administrative Requirements, paragraph 1, states
" written instructions, approved by the Reactor Safeguards Committee, shall be in effect for, but not limited to:" specific areas noted in Section H. The failure to establish written procedures for calibration and operation of the gamma spectroscopy system is an apparent violation of TS, Section H.1. (188/8602-02)
Records indicated that all beta gamma radioactivity concentrations were below 10 CFR 20 limits. However, liquid effluent is not monitored for alpha activity. The NRC inspector noted that the Americium / Beryllium neutron startup source located in the reactor pool was not being routinely wipe tested for leakage and the potential exists for the release of alpha activity into unrestricted area CFR Part 20.201(b) states "each licensee shall make or cause to be made such surveys as: (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards REMOVAL OF THE PAGES MARKED " "
DECONTROLS THE REMAINDER OF THIS DOCUMEN _ ___ . _


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Date of Full Compliance
. March 1. 1987.    -
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that may be present." The failure to analyze liquid effluents for alpha activity is an apparent violation of 10 CFR 20.201(b).


(188/8602-03)
,
The licensee stated that gaseous effluents are not routinely released and that the normal pathway would be through an exhaust duct which has been sealed and the fan switch disconnected to prevent operatio Air intake to the reactor bay is from the outside with exhaust to the reactor bay area. The licensee stated that elevated airborne concentrations are present in the reactor bay atmosphere during operations; however, no analyses have been performed to determine the concentration The failure to analyze reactor bay atmosphere to determine if airborne concentrations exceeded 10 CFR 20 limits is an apparent violation of 10 CFR 20.201(b). (188/8602-03) Surveys The NRC inspector reviewed radiation and contamination survey records regarding surveys performed by the NRF staff to determine compliance with the requirements of 10 CFR Part 20 and the recommendations of industry standard ANSI /ANS-15.11-197 The NRC inspector noted that smears taken routinely to determine levels of contamination were analyzed on the radiation safety department's liquid scintillation counte The NRC inspector noted that procedures had not been developed by the licensee for calibration and operation of the liquid scintillation counte TS, Section H, Administrative Requirements, paragraph 1, states,
C. Failure to Survey Reason for Violation Failure to evaluate liquid effluents for alpha-particle activity is admitted.
" written instructions, approved by the Reactor Safeguards Committee, shall be in effect for, but not limited to:" specific areas noted in Section The failure to establish written procedures for calibration and operation of the liquid scintillation counter is an apparent violation of TS, Section (188/8602-02)
The NRC inspector performed independent contamination and direct radiation dose rate surveys in the NR The smears taken by the NRC inspector were analyzed on NRC Region IV laboratory counting instrumentation, with all results less than or equal to minimum detectable activities. Tne direct radiation survey results revealed no areas of radiation levels in excess of 10 CFR'20 limit The licensee's survey program had not included an evaluation of neutron levels with the reactor operating at full power. The NRC inspector stated that neutron radiation levels are not usually considered to be a problem at TRIGA facilities; however, surveys REMOVAL OF THE PAGES MARKED " "
DECONTROLS THE REMAINDER OF THIS DOCUMEN .


7
Failure to monitor adequately airborne activity in the reactor bay atmosphere is not admitted. The potential for fuel-element cladding failure and for escape of noble gas and iodine radionuclides was addressed in the Hazards Summary Report for the Kansas State University TRIGA Mk II Reactor and in the safety analysis submitted to the Atomic Energy Commission in application for operation of the reactor at 250 kWt.
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should be performed to establish that no significant neutron radiation levels exist. The licensee stated at the exit brief!ng on September 10, 1986, that the NRC inspector's observation would be reviewe Radiation Worker Training Personnel qualifications and training were reviewed and discussed with the licensee to determine compliance with the requirements of 10 CFR Part 19.12 and the recommendations of RGs 8.13 and 8.2 The NRC inspector noted that the licensee required all workers to attend radiation protection trainin However, documentation was not available that all topics required by 10 CFR 19.12 had been covere The licensee stated that the topics required by 10 CFR 19.12 were covered in training sessions, but they were not aware that documentation to that extent would be required, and that
;
documentation on all future training conducted in this area would be complete .'
The NRC inspector reviewed activity logs and determined that one
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female worked at the NRF and that instruction had not been provided'
to her and her co workers concerning the recommendations in NRC RG 8.1 . Emergency Planning and Preparedness The NRC inspector reviewed the implementation of the KSV Emergency
'
Plan (EP) approved by the NRC on August 13. 1984, to determine compliance with 10 CFR 50.54(r).


The NRC inspector reviesed assignment of responsibilities, emergency facilities, and equipment (first aid and medical facilities, communications, and radiation and contamination protection equipment).
In the Safety Evaluation by the Division of Reactor Licensing. Docket l
50-188, " Kansas State University Increase in Power Level " signed by D.J.


The NRC inspector discussed with the KSV Student Health Center Director their roles and responsibilities in the event of a reactor accident at the NR The NRC inspector reviewed the placement and inventories of the emergency equipmen The NRC inspector noted that the inventory of the l cabinet located in the basement of Ward Hall indicated that two survey
Skovholt on 26 June 68, it was stated by the AEC that:
; instruments, one high range and one low range instrument, would be
  ". .
! available for use. At the time of the inspection, only the low range l instrument was available for use. The licensee stated that the high range instrument was out-of service. The NRC inspector discussed with the licensee the need to provide a supplemental instrument to the kit to provide for adequate inventory. The NRC inspector noted that the actual
  . The applicant's analysis, with which we agree, indicates that such an accident [ loss of pool coolant water af ter prolonged high-power operation] would not cause damage to the fuel or result in the release of fission products. However, even if the cladding of a fuel element were to fail, permitting fission products to escape, the applicant's calcualtions, and our analysts indicate that doses to personnel within the building and in unrestricted areas outside the building would remain within acceptable limits."
; number and type of instruments and equipment are not specifically l identified in the KSV EP.


l
[ italics added]
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In view of this finding, attempts have not been made to identify specific noble gas radionuclides in the reactor building atmosphere. Instead, radiation exposure rates are monitored throughout the reactor building in recognition that significant noble gas releases would thus be detected.
The licensee had conducted emergency exercises on August 16, 1984, and
, August 7, 1986. The critiques of emergency exercises were on file and had l been reviewed by the Reactor Safeguards Committee (RSC) as required by the l KSV emergency plan.


('
Emergency Procedure No. 6 has been implemented in order that such l exposure rates could be translated conservatively into radionuclide l concentrations for use in accident assessment.  )
REMOVAL OF THE PAGES MARKED " "
In order to monitor lor potential fission product relee.se of long duration, a number of surveillance actions are taken: (1) Activity held
DECONTROLS THE REMAINDER OF THIS DOCUMEN _ _ . .  - -
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on pool-cleanup demineralizer resin is monitored each operating day.


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Unusual increase in ac tivity would provide an early qualitative warning of the presence of fission products in primary coolant. (2) Primary coolant is sampled monthly and analyzed for gross activity using a liquid scintillation system. If any activity were found, gansna-ray spectral analysis would be performed. This would provide a quantitative measure of fission product activity in primary coolant. (3) During reactor use, operation of a continuous air monitor is required. Except for periods of maintenance, the monitor is operated continuously (24-h per day). The monitor is set to alarm at radiation indication very conservatively 131 representative of I maximum permissible concentration in unrestricted areas. The potential for argon-41 release into the reactor building was also addressed in the Hazards Analysis Report and found not to present a significant risk. Notwithstanding this finding, the use of air as the
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The NRC inspector reviewed the biennial EP reviews conducted and approved by the RSC, and the annual requalification training required for the NRF staf The NRC inspector noted that documentation of annual qualification training was lacking as to specific subject matte l No violations or deviations were identifie I 5. Nuclear Materials Safeguards
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The NRC inspector reviewed the nuclear materials inventory program to determine compliance with License Conditions 2.B and The NRC inspector reviewed the accountability procedures and practice records and material status reports for the period January 1,1983, through September 1, 1986. The procedures, practices, and records were found to be well-implemented. Responsibilities and response requirements were defined clearly and understoo No violations or deviations were identified.
driver gas for the pneumatic transfer system has been discontinued, with its use replaced by that of helium. The highly unlikely, but potential venting of air from the rotary specimen rack has also been investigated.


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That event would certainly be detected, yet concentrations and potential personnel exposures would be within acceptable 10CFR20 limits.
6. Physical Security The material discussed here contains Safeguards Information as defined by 10 CFR 73.21 and is reported in Attachment to this report.


. 7. Exit Briefing The NRC inspector met with the licensee's representatives identified in paragraph 1 of this report at the conclusion of the inspection on September 10, 198 The NRC inspector summarized the scope and inspection findings.
Corrective Stens to be Taken A procedure for alpha monitoring of Reactor Facility liquid effluents is under preparation. No effluents will be released without such monitoring.


l REMOVAL OF THE PAGES MARKED " "
Aside from fuel material, whose presence would be indicated by fission-product activity, the only source of measurable artificial alpha activity in reactor effluents would be the Am/Be source used for reactor start-up. This source is encapsulated in stainless steel and contained within an aluminum housing. We are contemplating either seeking a method of direct determination of source leakage or appealing for relief from this :aonitoring requiren.ent under the provisions of 10CFR20.501.
!- DECONTROLS THE REMAINDER OF THIS DOCUMENT.


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Date of Full Compliance March 1, 1987
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Latest revision as of 22:44, 18 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-188/86-02
ML20212E228
Person / Time
Site: Kansas State University
Issue date: 12/24/1986
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Faw R
KANSAS STATE UNIV., MANHATTAN, KS
References
NUDOCS 8701050278
Download: ML20212E228 (1)


Text

. _ _ _ _ _ _ . _ _ . . _ _ _ _ _ . _ -_ _ _ _ _ _ _ _ _ _ . - - _ _ _ _ _ _ _ _ - _ _ - _ _ -____

., 4 DEC 2 41986 in Reply Refer To:

Docket: 50-188/86-02 Kansas State University Department of Nuclear Engineering ATTN: Dr. R. E. Faw, Director Nuclear Reactor Facility Manhattan, Kansas 66505 Gentlemen:

Thank you for your letter of November 17, 1986, in response to our letter

and Notice of Violation dated October 20, 1986. We have reviewed your reply l and find it responsive to the concerns raised in our Notice of Violation. We l will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintai,ed.

Sincerely, ORIGINAL SIGNED BY:

J. E. Gagliardo, Chief Reactor Projects Branch cc:

Kansas Radiation Control Program bec to DMB (IE06)

bcc distrib. by RIV:

RPB Resident Inspector R. D. Martin, RA R&SPB Section Chief (RPB/B) D. Weiss, LFMB (AR-2015)

RIV File DRSP RSB MIS SYSTEM RSTS Operator Inspector Section Chief W. L. Fisher R. L. Bangart J. J. Dosa, NRR, Project Manager RIV:FRP C:FRPS C:R&SPB CRPB [

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Wi se/j t BMurqay WLFisher JEGaghfrdo p to/ 86 y /gb/86 lg/jd/86 4,/Dj/86

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November 17, 1986 U.S. Nuclear Regulatory Commission Region IV Attn: J. E. Gagliardo, Chief Reactor Projects Branch 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 Re: License R-88 Docket 50-188

Dear Sirs:

This is in response to your letter of 20 October 1986 and its attendant notice of violation. Our response is enclosed.

Sincerely, et<f f hin V Richard E. Faw, Director KSU Nuclear Reactor Facility REF/cs Enclosure

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RESPONSE TO NOTICE OF VIOLATION

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Kansas State University (KSU) Docket: 50-188/86-02 TRICA MkII Reactor License: R-88 A. Failure to Perform Survey Instrument Calibration Reason for Violation This violation is admitted. The reasons are as follows: The Reactor Facility maintains and calibrates instruments for general use in the Nuclear Engineering Department. On some occasions, these general-purpose instruments are in use outside the Reactor Facility at the time of reactor-instrument calibratior.. Record keeping procedures hase been deficient in identification of those occasions.

Cprrective Steos Taken New record keeping procedures have been implemented. A master log of calibration dates has been instituted to supplement calibration logs for each instrument.

Corrective Steos to be Taken At the time of the next calibration, those instruments not required for reactor surveillance are to be sequestered in their own storage location.

All instruments are to be tagged with identification of their use (reactor or non-reactor) and the calibration expiration date.

Date of Full Compliance All instruments are now in calibration. The next round of calibration will take place in Decerber 1986 and January 1987.

B. Failure to Develon Written Procedures Reason for Violation

- .

The absence of certain written procedures is not admitted. That these prccedures have not been approved by the Reactor er Safeguards Committee is admitted. Vendor-supplied instruction manuals for the systems in question are followed in their use. Such manuals have not been submitted to the Reactor Safeguards Connittee for its endorsement.

Corrective Steps to be Taken ,

Operating procedures incorporating, by reference, vendor's instruction manuals will be prepared and submitted to the Reactor Safeguards Committee for endorsement.

Date of Full Compliance

. March 1. 1987. -

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C. Failure to Survey Reason for Violation Failure to evaluate liquid effluents for alpha-particle activity is admitted.

Failure to monitor adequately airborne activity in the reactor bay atmosphere is not admitted. The potential for fuel-element cladding failure and for escape of noble gas and iodine radionuclides was addressed in the Hazards Summary Report for the Kansas State University TRIGA Mk II Reactor and in the safety analysis submitted to the Atomic Energy Commission in application for operation of the reactor at 250 kWt.

In the Safety Evaluation by the Division of Reactor Licensing. Docket l

50-188, " Kansas State University Increase in Power Level " signed by D.J.

Skovholt on 26 June 68, it was stated by the AEC that:

". .

. The applicant's analysis, with which we agree, indicates that such an accident [ loss of pool coolant water af ter prolonged high-power operation] would not cause damage to the fuel or result in the release of fission products. However, even if the cladding of a fuel element were to fail, permitting fission products to escape, the applicant's calcualtions, and our analysts indicate that doses to personnel within the building and in unrestricted areas outside the building would remain within acceptable limits."

[ italics added]

In view of this finding, attempts have not been made to identify specific noble gas radionuclides in the reactor building atmosphere. Instead, radiation exposure rates are monitored throughout the reactor building in recognition that significant noble gas releases would thus be detected.

Emergency Procedure No. 6 has been implemented in order that such l exposure rates could be translated conservatively into radionuclide l concentrations for use in accident assessment. )

In order to monitor lor potential fission product relee.se of long duration, a number of surveillance actions are taken: (1) Activity held

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on pool-cleanup demineralizer resin is monitored each operating day.

Unusual increase in ac tivity would provide an early qualitative warning of the presence of fission products in primary coolant. (2) Primary coolant is sampled monthly and analyzed for gross activity using a liquid scintillation system. If any activity were found, gansna-ray spectral analysis would be performed. This would provide a quantitative measure of fission product activity in primary coolant. (3) During reactor use, operation of a continuous air monitor is required. Except for periods of maintenance, the monitor is operated continuously (24-h per day). The monitor is set to alarm at radiation indication very conservatively 131 representative of I maximum permissible concentration in unrestricted areas. The potential for argon-41 release into the reactor building was also addressed in the Hazards Analysis Report and found not to present a significant risk. Notwithstanding this finding, the use of air as the

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driver gas for the pneumatic transfer system has been discontinued, with its use replaced by that of helium. The highly unlikely, but potential venting of air from the rotary specimen rack has also been investigated.

That event would certainly be detected, yet concentrations and potential personnel exposures would be within acceptable 10CFR20 limits.

Corrective Stens to be Taken A procedure for alpha monitoring of Reactor Facility liquid effluents is under preparation. No effluents will be released without such monitoring.

Aside from fuel material, whose presence would be indicated by fission-product activity, the only source of measurable artificial alpha activity in reactor effluents would be the Am/Be source used for reactor start-up. This source is encapsulated in stainless steel and contained within an aluminum housing. We are contemplating either seeking a method of direct determination of source leakage or appealing for relief from this :aonitoring requiren.ent under the provisions of 10CFR20.501.

Date of Full Compliance March 1, 1987

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