ML24164A092

Kansas State University, License Requirements Exemption Request Supplemental Information

ML24164A092
Person / Time
Site:	Kansas State University
Issue date:	06/11/2024
From:	Cebula A Kansas State University
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML24164A092 (1)

Text

KANSAS STATE TRIGA Mk II Nuclear u N I v E R s I T y Reactor Laboratory Director of the Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555-0001

11 June 2024

Subject:

Kansas State University, License R-88, Docket 50-188, License Requirements Exemption Request Supplemental Information

Dear Mo Shams,

This letter provides additional information to the previously submitted exemption request dated 7 March 2024 (ML24085A808) and is provided based on discussion with representatives from the Nuclear Regulatory Commission (NRC) during conference calls on 16 May 2024, 28. May 2024, and 11 June 2024 and email communication from 29 May 2024 and 30 May 2024. Various questions discussed related to the part of the request describing completion of additional training at another facility before cancellation of an administrative restriction at the Kansas State University Research Reactor (KSURR):

"Before the administrative restriction on operations related to the fuel issue is cancelled, at least one senior reactor operator licensee shall acquire training and perform control manipulations as a trainee at University of Texas at Austin Research Reactor that demonstrate understanding and ability to perform 10CFR55.45(a)(2), (5), and (6). Results of the additional training will be included with the licensee requalification training records. Any operator who does not complete the training will become inactive and follow Requalification Program Section 3.3.1 or other requirements approved by the NRC before being reactivated."

Generally, NRC staff requested more details for [A] the administrative restriction on operations, [B] why University of Texas at Austin Research Reactor (UT ARR) was selected as a training site, and [C] available licensed operators that may participate in training at UTARR.

[A] The administrative restriction is implemented through the attached management order "SOMl Operational Limits and Special Administrative Controls." Per the order, the condition/limit log is reviewed prior to reactor operations to ensure compliance.

[B] Reasons for selecting the UTARR for completing additional training include:

1. Both facilities have similar license power (1100 kW UTARR, 1250 kW KSURR). Operations may be conducted at UT ARR between shutdown and designated power levels similar to KSURR.

2. Both facilities utilize TRIGA fuel and graphite reflection, hence operating behavior characteristics during control manipulations will have a similar response.

3. Based on verbal discussion with an administrator at UTARR, the training site has the capability and availability to provide the training.

[C] Possible participant(s) in the additional training at UTARR may be selected from the currently licensed senior reactor operators: Alan Cebula (Docket #055-70722), Amir Bahadori (Docket# 055-70720), Robert Seymour (Docket# 055-71404).

Additionally, NRC staff requested clarification of which regulations apply to the first two items of the exemption request:

"1. Requalification Program Section 3.2.1 Reactivity Manipulations and 10CFR55.59(c)3)(i)

2. Requalification Program Section 3.2.2 Proficiency as Operator at the Controls"

To specify the applicable regulation, the exemption request is amended to

1. Requalification Program Section 3.2.1 Reactivity Manipulations per 10CFR55.59(c)(3)(i)

2. Requalification Program Section 3.2.2 Proficiency as Operator at the Controls per 10CFR55.53(e)

NRC staff also asked for a statement that requests performing training at another facility. The training will be conducted at UTARR per 10CFR55.59(c)(6) as UTARR has an NRC approved requalification program. As discussed during conference calls, applicable portions of the operating exam regulations not exempted will be conducted at KSURR.

This supplemental information has been reviewed and approved by the KSURR Reactor Safeguards Committee.

Regards,

Alan T. Cebula Nuclear Reactor Facility Manager Alan Levin Department of Mechanical and Nuclear Engineering Kansas State University Manhattan, KS 66506

Attachment:

SOMl Operational Limits and Special Administrative Controls cc: Linh Tran, NRC Project Manager SOM1 Operational Limits and Special Administrative Controls Orig inal 5/04 Pa e 1 of 2

SCOPE

This management order describes temporary administrative limits or special conditions for operation of the KSU reactor

ATTACHMENTS

Attachment 1: Condition/Limit Log

DISCUSSION

The Condition/Limit Log may be used to guide the performance of a procedure or experiment, limit operational aspects of an operation, or impose special conditions.

PRECAUTIONS AND LIMITS

This management order shall not be used in place of a procedure, or to circumvent a procedure.

If a log entry conflicts with a procedural requirement, do not continue the operation until the conflict is resolved.

GUIDANCE OR POLICY

1. IF the reactor manager determines that a limit on operations is desired, the reactor manager SHALL INITIATE an entry in the Condition/Limit Log and WRITE

1.1. Date the entry is made

1.2. Dates for which the limit applies, if applicable

1.3. Condition or limit (alternately refer to an attached description) and the reason for the limit

1.4. Initials completing implementation of the log entry

2. Prior to reactor operations, the operator at the controls shall

2.1 . REVIEW the Condition/Limit Log

2.2. ENSURE compliance

2.3. NOTIFY OPERATION SUPERVISOR if an entry indicates date of applicability has passed without canceling the log entry SOM1 Operational Limits and Special Administrative Controls ~ riginal 5/04 Pa e2 of 2

3. During operations the reactor operator at the controls shall

3.1. ENSURE compliance with the condition/limit

3.2. SHUTDOWN the reactor if the condition/limit cannot be met

4. WHEN the limit or condition is no longer required, the reactor manager SHALL

4.1. WRITE the date of termination of the log entry

4.2. INITIAL cancellation

ACCEPTANCE CRITERIAOR EXIT CONDITIONS

Active management limits on operations are recorded and initialed

Management limits are initialed as completed when no longer desired

DEFINITIONS

OPERATION SUPERVISOR. Licensed Senior reactor operator designated as Reactor Supervisor or Reactor Manager who approves an operation, acting as the Reactor Supervisor on call

REFERENCES

Facility Operations Manual

TECHNICAL GUIDANCE

None

/ 10/07/19 1 A roved Date Rev#

Operational Limits and Special Administrative Controls Attachment 1: Condition/Limit Log

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