IR 05000027/1999201
| ML20217B273 | |
| Person / Time | |
|---|---|
| Site: | Washington State University |
| Issue date: | 10/06/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217B261 | List: |
| References | |
| 50-027-99-201, NUDOCS 9910120198 | |
| Download: ML20217B273 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF NUCLEAR REACTOR REGULATION
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i Docket No:
50-027-
. License' No:
R 76 Report No:
50-027/99-201 Licensee:
Washington State University -
Facility:
Washington State University TR!GA Reactor Location:
Nuclear Radiation Center Roundtop Dr.
Pullman, Washington 99164 A' gust 17-20,1999 -
Dates:
u Inspector:-
Stephen W. Holmes, Reactor inspector Approved by:
Ledyard B. Marsh, Chief -
Events Assessment, Generic Communications -
and Non-Power Reactors Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation y
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i EXECUTIVE SUMMARY '
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~ This routine, an'nounced inspection included onsite review of selected aspects of the
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following:[ Organizational Structure and Functions Program, Design Control Program,
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Review and Audit Program, Radiation Protection Program, Radiation Protection Postings,
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L Radiation Protection Surveys, Personnel Dosimetry, Calibration of Radiation Monitoring and
. Equipment, Effluent Monitoring and Release, Environmental Protection' Program, Maintenance Program, Procedures Program, Emerge _ncy Preparedness Program, Safeguards Program, and Transportation Program since the last NRC inspection in these areas.
The licen'see's programs were acceptably directed toward the protection of public health ;
"and safety, and in compliance _with NRC requirements.
' ORGANIZATIONAL STRUC1URE AND FUNCTIONS The, organizational structure and functions were consistent with Technical Specification-(TS) requirements.
DESIGN CONTROLT The' design change program satisfied NRC requirements.
MyjEW AND AUDIT
. The review and audit program satisfied TS requirements.
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RADIATION PROTECTION PROGRAM
.The radiation protection program (RPP) satisfied the requirements of 10 CFR 20.1101.
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RADIATION PROTECTION POSTINGS o
Radiological postings satisfied regulatory requirements.
RADIATION PROTECTION SURVEYS-Surveys with'one exception were perforrned and documented as required by 10 CFR Part 20. The one exception'was a violation of facility procedures to perform smear and area radiation surveys daily. This violation was of minor safety significance and'was corrected by the licensee. Therefore, it is being treated as a Non-Cited Violation,
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consistent with Section Vll.B.1 of the NRC Enforcement Policy (no reply is required).
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PERSONNEL DOSIMETRY
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The personnel dosimetry program was acceptably implemented and doses were in
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CALIBRATION OF RADIATION MONITORING AND EQUIPMENT
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_ Portable survey meters, radiation monitoring,' and counting lab instruments were being
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maintained accordind to industry and equipment manufacturer standards. Calibrations
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"' atisfied TS requirements.
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. EFFLUENT MONITORING'AND RELEASE
.The effluent monitoring and release program' satisfied NRC requirements
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ENVIRONMENTAL PROTECTION
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Environmental monitoring ' satisfied the RPP' requirements.
MAINTENANCE ~
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The maintenance program satisfied NRC requirements.
PROCEDURES'
The procedural control and implementation program satisfied TS requirements.
The emergency preparedness program was conducted and implemented in accordance.
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with the E-Plan.
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. SAFEGUARDS -
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The licensee was in compliance with the possession and use limits of the research reactor and had acceptably controlled and invetitoried special nuclear material (SNM) as required.
. TRANSPORTATION Radioactive material was transferred and disposed of in accordance with licensee
. procedures, TS,10 CFR 49 and 10 CFR 20 requirements.
BEACTOR COOLING TO~WER AND HEAT EXCHANGER REPLACEMENT and REPAIR AND
= REllNING OF THE REACTOR POOL The licensees actions regarding these activities were acceptable.
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V Report Details
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f Summary of Plant' Status
' During the inspection the reactor was shut down while the reactor cooling tower and heat exchanger were being replaced and the reactor pool concrete was repaired and relined.
Under normal conditions the reactor operated several days a week to support education,
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l operator training, surveillance, service work, and experiments.
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ORGANIZATIONAL STRUCTURE AND FUNCTIONS a.
Scope (69001)
l The inspector reviewed selected aspects of:
organization and staffing e-e qualifications e
management responsibilities -
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- administrative controls b.'
. Qbservations and Findinas.
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, The health physics (HP) organizational structure and staffing had not functionally l
. changed since the last inspection. The campus HP staffing consisted of the Director, Radiation Safety Office, an Assistant Director, four HP technicians, and students. They provided support to the reactor as well as having responsibility for the state license. The reactor staff performed most the HP functions at the reactor. Coordination of HP
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activities between the staff was acceptable with no conflicts between the reactor's NRC license requirements and the Nuclear Radiation Center's state license commitments.
Staffing was as reported in the Annual Report and as required by TS. Qualifications of =
the staff met TS requirements. Review of records verified that management
' responsibilities were administered as required by TS and applicable procedures.
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Conclusions '
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- The organizational structure and functions were consistent with TS requirements.
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DESIGN CONTROL a.
Scope (69001)
-The inspector reviewed selected aspects of:
e facility design changes and ' records l
e1 facility configuration e.
work in progress on the reactor pool and heat exchanger / cooling tower system b,'
' Observations and Findinas l
(During the inspection the facility w'as in the process of replacing the reactor cooling tower and heat exchanger, and repairing and relining the reactor pool concrete
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. tank. The 10 CFR 50.59 change package included new diagrams, the
. manufacture's manual for the cooling tower and heat exchanger, documentation on
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the repair of the concrete tank, and information on the new tank lining material as
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well as the review and approval by the reactor safeguards committee (RSC).
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Records and observations sho.ved_that changes at the facility were acceptably reviewed in accordance with 10 CFR 50.59 and applicable licensee administrative controls. The RSC had contint,ing oversight of the changes through recurring
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reports from the Reactor Director and the Facilities Development work project representative, c.
. Conclusions
'The design change prograni satisfied NRC requirements.
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BEyJEW AND AUDIT a.
Scone (69001)
The' inspector reviewed selected aspects of:
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e audit records e:
responses to safety reviews and audits e
review and audit personnel qualifications b.
Observations and Findinas
' Records showed that the safety reviews were conducted at the TS required frequency. Topics of these reviews were also consistent with TS requirements to provide guidance, direction, and oversight, and to ensure acceptable us,e of the reactor.
The audit records showed that audits had been completed in those areas outlined in the TS and at the required frequency.
. The inspector noted that the safety reviews and audits and associated findings were acceptably detailed and that the licensee responded and took corrective actions as needed.. The safety review and audit personnel qualifications were consistent with licensee administrative controls, c.
Conclusiens The review and audit program satisfie' d TS requirements.
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RADIATION PROTECTION PROGRAM a.
Scope (69001)
The inspector reviewed selected aspects of:
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_ the Radiation Protection Psogram (RPP)
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. As Low As Reasonably Achievable (ALARA) reviews i
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Observations and Finding
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The RPP.had not changed since the last inspection. The licensee reviewed the RPP at least annually in accordance with 10 CFR 20.1101(c). This review and oversight were provided by the reactor and university staffs as required by TS and licenses j
procedures. The review included all areas and no weaknesses were reported.
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Conclusions:
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The RPP satisfied the requirements of 10 CFR 20.1101.
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RADIATION PROTECTION POSTINGS
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Scope (69001)
The inspector reviewed selected aspects of:
radiological signs and posting o
facility and equipment during tours e.
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Observations and Findinas Caution signs, postings and controls to radiation areas at Nuclear Radiation Center reactor were acceptable for the hazards involved and were as required in 10 CFR 20, Eubpart J. Licensee personnel observed the indicated precautions for access to the radiation areas. NRC Forms 3 were posted in appropriate areas in the facility as were current notices to workers required by 10 CFR 19.
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- Conclusions Radiological postings satisfied regulatory requirements.
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RADIATION PROTECTION SURVEYS a.
Scooe (Inspection Procedure 69001)
The inspector reviewed selected aspects of:
.e-routine surveys and monitoring e
survey and monitoring procedures b.
' Observations and Findinas With one exception, weekly, quarterly, and other periodic contamination and radiation surveys were performed as required by TS and Nuclear Radiation Center procedures. These were conducted by reactor and university staff. Results were evaluated and corrective actions taken and documented when readings /results exceeded set action levels.
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The inspector observed that although ' procedurally one survey had been broken down into individual daily sets, all the areas were being smeared'on a single day.
. Additionally, in the last six months, four individual daily sets of the area beta / gamma survey portion were not performed.. The licensee stated and the j
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inspector confirmed that the survey had been a weekly one separated into daily
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segments to spread out the workload. The staff had discovered however that
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i performing the smear portion on one day was more efficient. Moreover, based on the typeisize, and workload at the facility a single comprehensive weekly radiation
- area survey would satisfy regulatory requirements. The inspector verified that
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' subsequent surveys of the missed areas found no contamination. This minor and
licensee corrected violation is being treated as a Non-Cited Violation consistent l
with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 60-027/99-201-01 Failure to perform smear and area radiation surveys daily as required by facility procedures.)L
.The licensee held a RSC meeting, attended by the inspector, and reviewed and
' approved changes to the procedures instructing that a full smear and gamma survey be preformed at least weekly.. The licensee stated that other procedures would be' reviewed as to frequency and kind of surveys needed for the iacility's
. type, size, and workload.
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Conclusions
' With one exception as noted, surveys were performed and documented as required by 10 CFR 20, TS and licensee administrative controls.
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PERSONNEL DOSIMETRY a.
' Scooe (69001))
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i The inspector reviewed selected aspects of:
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- licensee procedures l-e dosimetry records.
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Observations and Findinas Use of dosimeters and exit frisking practices were in accordance with radiation protection requirements. Issuance to and use of specific dosimetry by workers during the cooling tower and heat exchanger replacement, and the repair and relining of the reactor pool was good.
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accredited vendor to process personnel thermoluminescent dosimetry (TLD). The
licensee's dosimetry program for declared pregnant women satisfied 10 CFR L
20.1208 requirements. Radiological exposure records showed that occupational doses and doses to the public were within 10 CFR 20 limitations Prior to starting work on repairing and relining the reactor pool concrete tank, the
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L licensee developed a respiratory protection program to be implemented if required
during these operations. The plan was reviewed and approved for use by the RSC if needed and the NRC was notified as required by 10 CFR 20.
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Conclusions -
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j The personnel dosimetry program was acceptably implemented and doses were in conformance with licensee and 10 CFR 20 limits.
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Call 8 RATION OF RADIATION MONITORING AND EQUIPMENT a.
S.pooe (69001)
The inspector reviewed selected aspects of:
maintenance and calibration of radiation monitoring equipment o
e-periodic checks, quality control, and test source certification records b.
Observations and Findinos The calibration and periodic checks of the portable survey meters, radiation munitoring, and counting leb instruments were performed in-house by the licensee staffs and offsite by certified contractors. With one exception calibration frequency met TS and licensee directives. Calibration procedures were consistent with American National Standards Institute or the manufacturers'
recommendations. Calibration and check sources were traceable to the National Institutes of Standards and Technology. The sources' geometry matched those used in actual analyses The portable neutron meter was being calibrated semiannually by a contractor. All other portable meters were calibrated quarterly as prescribed by license procedure.
The inspector could not determine from the users manual what the manufacturers recommended calibration frequency was. Current industry standards range from semiannual to annual calibrations for most radiation monitoring instrumentation.
The licensee stated that they would contact the manufacturers and obtain the information on the recommended calibration frequencies and implement calibration frequencies appropriate for this facility. This will be reviewed during a future inspection as an Unresolved item (Ul 50-027/97-201-01).
Allinstruments checked were in calibration. Calibration records were in order.
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Conclusions With the one exception noted above portable survey meters, radiation monitoring, and counting lab instruments were being maintained according to industry and equipment manufacturer standards. Calibrations satisfied TS requirements.
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EFFLUENT MONITORING AND RELEASE a.
Scone (69001)
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The inspector reviewed selected aspects of:
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counting and analysis program e
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Observations and Findinas The program for the monitoring, storage and release of radioactive liquid and gases was consistent with applicable regulatory requirements. Gaseous releases were monitored and calculated as outlined in the Final Safety Analysis Report, the EPA
COMPLY code, or license procedures. Records were acceptable and showed gaseous releases well within the annual dose constraint of 20.1101(d), Appendix B concentrations and TS limits.
Radioactive liquid was monitored and released when below acceptable limits.
Records through July 1999, confirraed that releases met 10 CFR 20.2003 and Appendix B limits. The principles of As Low As Reasonably Achievable were acceptably implemented to minimize radioactive releases. Monitoring equipment was acceptably maintained and calibrated. Records were current and acceptably maintained.
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_ Conclusions
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The effluent monitoring and release program satisfied NRC requirements.
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ENVIRONMENTAL PROTECTION a.
Insoection Scope (6S001)
The inspector reviewed selected aspects of:
e the environmental monitoring program o
environmental records e
procedures e
annual reports b.
Observations and Findinos The environmental monitoring consists of direct radiation measurements at selected locations adjacent to and background location 400 meters or greater from the Nuclear Radiation Center. TLD results in unrestricted areas were not statistically different from background readings and the annual exposure at the closest off-site extended occupancy satisfied TS requirements.
c; Conclusions Environmental monitoring satisfied the radiation protection program requirements.
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MAINTENANCE
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Scope (69001)
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The inspector reviewed selected aspects of:
o maintenance procedures e
equipment maintenance records equipment work in progress on the reactor pool and heat exchanger / cooling e
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I tower system.
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Observations and Findinas l
Reactor maintenance was noted in a maintenance log and the reactor logbook as required by procedures. Logs indicated that corrective maintenance activities and problems were addressed as required by procedure. Records showed that routine (
maintenance activities were adequately controlled, documented, and conducted at the required frequency in accordance with the TS, applicable procedure or equipme'nt manual. Maintenance activities ensured that equipment remained consistent with the Safety Analysis Report and TS requirements. Further, maintenance activities were routinely evaluated by use of a checklist to verify that they were consistent with the requirements of 10 CFR 50.59.
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Conclusions The maintenance program satisfied NRC requirements.
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PROCEDURES
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Scoce (69001)
The inspector reviewed selected aspects of:
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's administrative controls l
records for changes and temporary changes e
procedural implementation e
logs and records b.
Observations and Findinas HP procedures were available for those tasks and items required by the TS, license, j
and facility directives. Administrative controls of changes and temporary changes j
to procedures, and associated review and approval processes were as required.
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Training of personnel on procedures and changes was acceptable. Personnel conducted activities in accordance with app!icable procedures. Records showed that procedures for potential malfunctions (e.g., radioactive releases and contaminations, and reactor equipment problems) were implemented as required.
Observation of the RSC meeting confirmed that procedures were reviewed and approved as required by TS.
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The procedural control and implementation program satisfied TS requirements.
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Scone (69001)
L The' inspector reviewed selected aspects of:
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e; the Emergency Plan e-implementing procedures
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emergency response facilities, supplies, equipment and instrumentation e
training records
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offsite support e.
emergency drills and exercises b.
Observations and Findinas
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.The Emergency Plan (E-Plan) in use at the reactor and emergency facilities was the same as the version most recently approved by the NRC. The E-Plan was audited and reviewed as required. Implementing procedures were reviewed and revised as needed to employ the E-Plan effectively. Facilities, supplies, instrumentction and
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l equipment were being maintained, controlled and inventoried as required by the E-l Plan.' Through records review and interviews with licensee personnel, emergency L
responders were determined to be knowledgeable of the proper actions to take in l:
case of an emergency. Agreements with outside resoonse organizations had been
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updated and maintained as necessary.. Communications capabilities were i
acceptable with these support groups and had been tested as stipulated in the E-j l
Plan'.- Emergency' drills had been conducted as required by the E-Plan. Off-site support organization participation was also as required by the E-Plan. Critiques l
were held following the drills to discuss the strengths and weaknesses identified I
during the exercise and to develop possible solutions to any problems identified.
The results of these critiques were documented and filed. Emergency preparedness and response training was being completed as required. Training for off-site and reactor staff personnel was conducted and documented as stipulated by the E-Plan.
The licensee response earlier this summer to an exten'ied emergency power outage l
caused by severe weather was commendable. The license implemented the E-Plan l
quicklyf efficiently, and according to written guidance. The NRC, as well as other L
agencies were notified as required and remedial actions taken until power was rest. ed.' This confirmed that the license was able to implement the E Plan as
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required.
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Conclusions The emergency preparedness program was conducted and implemented in
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SAFEGUARDS
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Scope (85102)
l The inspector reviewed selected aspects of:
nuclear material accountability program e
o nuclear material inventory and locations e
accountability records and reports b.
Observations and Findinos The semiannualinventory of material was reviewed and verified. The material control and accountability program tracked locations and content of fuel and other SNM under the research reactor license. Fuel burn-up related measurements and calculations were acceptably performed and documented. The possession and use of SNM were limited to the locations and purposes authorized under the license.
The material control and accountability forms (DOE /NRC Forms 741 and 742) were prepared and transmitted as required. Fuelinventory and movement records were cross referenced and matched.
The facility representative located and the inspector verified randomly selected items listed on the SNM inventory.
The Reactor Director stated they were aware that, although tracking fuel burn-up and production on a total core basis was acceptable for operations, for shipping spent fuel, individual element isotopic inventories could be required.
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Conclusions The licensee was in compliance with the possession and use limits of the research reactor and had acceptably controlled and inventoried SNM as required.
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TRANSPORTATION a.
Scope (86740)
The inspector reviewed selected aspects of:
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o radioactive materials shipping procedures e
radioactive materials transportation and transfer records b.
Observations and Findinas Production of solid radioactive waste at the facility was minimal. The small amount produced was handled under the campus waste disposal program. All transfers were recorded on the appropriate forms. Transfer documentation was kept on file as required and was acceptabl.
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j Radioactive materials produced by the reactor for use by the university staff or
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outside organizations were handled and documented as required. Records showed that the radioisotope type and quantities were calculated and dose rates were measured. The reactor staff properly packaged, surveyed, and released materials to on-campus investigators, and to entities outside the university in accordance with DOT and NRC requirements.
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Conclusions Radioactive material was transferred and disposed of in accordance with licensee procedures, TS,10 CFR 49 and 10 CFR 20 requirements.
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REACTOR COOLING TOWER AND HEAT EXCHANGER REPLACEMENT a.
Scoce(92701)
The inspector reviewed selected aspects of:
e facility design changes and records e
facility configuration a
work in progress on the reactor tower system.
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Observations and Findings During the inspection the facility was in the process of replacing the reactor cooling tower and heat exchanger.
The old tower and heat exchanger had been removed, the heat exchanger room modified to accommodate the new system, and the new cooling tower was nearing completion. Oversight, coordination and control of the work by the university facilities representative and reactor staff were good.
l Review of the system drawings and observation of the construction confirmed that the new system would meet Final Safety Analysis and TS requirement.
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Conclusions The licensees actions regarding the reactor cooling tower and heat exchanger replacement were acceptable.
REPAlR AND RELINING OF THE REACTOR POOL a.
Scoce (92701)
The inspector reviewed selected aspects of:
e facility design changes and records e
facility configuration a
work in progress on the reactor pool e
HP survey, analyses, and evaluation records
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' Observations and Findinasc During the inspection the facility was in the process of repairing and relining the reactor pool concrete tank.
One side of the pool had been drained, decontaminated, its surface prepared, and the first of two layers of epoxy coating were near completion. During this process radiological surveys, analyses, and evaluations of the radiological hazards were performed on a continuing basis. Liquid and solid wastes were collected for analyses and evaluation prior to disposal. The inspector reviewed airborne concentration, smear, radiation area, entrance and exit, decontamination, and other radiological surveys. The inspector verified the licensee evaluation that respiratory protection to control dose was not required, that workers exposures were well under regulatory and licencee limits, and that standard radiological and industrial controls were in place.
Besides performing gross airborne surveys, which showed no statistical difference between outside background levels and those in the concrete tank during surface preparation operations (scrabbling and grinding of the old coating), the licensee also performed specific gamma analyses of the air sample filters. These results, confirmed by the inspector, demonstrated that airborne radioactive material levels were well below regulatory requirements.
Oversight, coordination and control of the work by the university facilities representative and reactor staff were good.
Review of the coating specifications and observation of its application confirmed that it would meet Final Safety Analysis and TS requirements.
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. Conclusions The licensees actions in regards to the repair and relining of the reactor pool were acceptable.
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EXIT MEETING SUMMARY (30703)
The inspector presented the inspection results to members of licensee management et the conclusion of the inspection on August 20,1999. The licensee acknowledged the findings presented and did not identify as propriety any of the material provided to or reviewed by the inspector during the inspectio f I
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
l G. Hedge.
Vice Provost Research
' J. Becker Manager Facilities Engineering K. Bloom Building Constructor Specialist, Facilities Development B. Bunce Senior Reactor Operator -
S. Eckberg Assistant Director, Radiation Safety Offica J. Elleston Neutron Activation Technician l
R. Philby Professor Radiochemistry K. Fox Reactor Operator K. Johnson Radiation Safety Technician M. Miles Chairman, Reactor Safeguards Committee J. Neidiger Reactor Supervisor -
L. Porter Director, Radiation Safety Office
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G. Tripard Director, Nuclear Radiation Center INAPECTION PROCEDURE (IP) USED IP 30703 ENTRANCE, EXIT INTERVIEWS
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IP 69001 CLASS ll NON-POWER REACTORS
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lP 85102 MATERIAL CONTROL AND ACCOUNTING lP 86740 TRANSPORTATION ACTIVITIES j
IP 92701 FOLLOWUP ON INSPECTOR IDENTIFIED PROBLEMS.
ITEMS OPENED. CLOSED. AND DISCUSSED Ooened i
NCV O27-99-201-01 Failure to perform smear and area radiation surveys daily as j
required by facility procedures.
' UI 50-027/97-201-01 The manufacturers recommended calibration frequency for the neutron monitor could not be determined. The licensee would contact the manufacturers and obtain the information on the recommended calibration frequency and implemer 4 that appropriate for this facility.
Closed NCV 027 99-201-01 Failure to perform smear and area radiation surveys daily as required by facility procedures.
PARTIAL LIST OF ANACHRONISMS USED ALARA As Low As Reasonably Achievable
- E-Plan Emergency r lan e
RSC Reactor Safeguards Committee l
RPP Radiation Protection Program TLD Thermoluminescent Dosimetry TS Technical Specifications SNM Special Nuclear Material l
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