IR 05000027/2019201

Washington State University - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 50-027/2019-201

ML19203A182
Person / Time
Site:	Washington State University
Issue date:	08/30/2019
From:	Anthony Mendiola Research and Test Reactors Oversight Projects Branch
To:	Keane C Washington State Univ
Bassett C, NRR/DLP, 240-535-1842
References
IR 2019201
Download: ML19203A182 (20)

Text

ust 30, 2019

SUBJECT:

WASHINGTON STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-027/2019-201

Dear Dr. Keane:

From July 8 - 11, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at your Washington State University TRIGA [Training, Research, Isotopes, General Atomics] research reactor located in the Nuclear Science Center. The enclosed report documents the inspection results which were discussed on July 11, 2019, with you, Dr. Geeta Dutta, Assistant Vice President for Research Advancement and Partnerships, and Corey Hines, Interim Director of the Nuclear Science Center.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. The inspector reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of noncompliance were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this inspection, please contact Craig Bassett at 240-535-1842 or electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No.50-027 License No. R-76 Enclosure:

As stated cc: See next page

Washington State University Docket No.50-027 cc:

Director Division of Radiation Protection Department of Health 7171 Cleanwater Lane, Bldg #5 P.O. Box 47827 Olympia, WA 98504-7827 Mike Kluzik, Director Washington State University Radiation Safety Office P.O. Box 641302 Pullman, WA 99164 1302 Mike Kluzik, Interim Chair Washington State University Reactor Safeguards Committee Nuclear Radiation Center P.O. Box 641300 Pullman, WA 99164 1300 Mr. Corey Hines, Associate Director Washington State University Nuclear Radiation Center P.O. Box 641300 Pullman, WA 99164 1300 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Mr. Corey Hines, Interim Director Washington State University Nuclear Radiation Center 50 Roundtop Drive Pullman, WA 99164 1300 SUBJECT: WASHINGTON STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-027/2019-201 DATE: AUGUST 30, 2019 DISTRIBUTION:

PUBLIC RidsNrrDlpProb NParker, NRR PROB r/f CBassett NRR GCasto, NRR RidsNrrDlpPrlb AMendiola, NRR DHardesty, NRR ADAMS Accession No. ML19203A182 concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME CBassett NParker AMendiola DATE 8/1/2019 8/1/2019 8/30/2019 OFFICIAL RECORD

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-027 License No.: R-76 Report No.: 50-027/2019-201 Licensee: Washington State University Facility: Nuclear Science Center Location: Pullman, WA Dates: July 8 - 11, 2019 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Washington State University Nuclear Science Center NRC Report No. 50-027/2019-201 The primary focus of this routine, announced inspection was the on-site review of selected aspects of the Washington State University (the licensees) Class II research and test reactor safety program including: (1) organization and staffing, (2) operations logs and records, (3) procedures, (4) requalification training, (5) surveillance and limiting conditions for operation (LCOs), (6) experiments, (7) design changes, (8) committees, audits, and reviews (9) emergency preparedness, (10) maintenance logs and records, and (11) fuel handling logs and records, since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensee's program was acceptably directed toward the protection of public health and safety and in compliance with NRC requirements.

Organization and Staffing The organizational structure and staffing levels were consistent with the requirements specified in Sections 6.1 and 6.2. of the facility technical specifications (TSs).

Personnel changes in some key positions of the organization had occurred.

Operations Logs and Records Operational activities were consistent with applicable TS and procedural requirements.

Procedures The procedural review and implementation program was acceptably controlled and maintained and met TS requirements.

Requalification Training The requirements of the Operator Requalification Program were being met.

The program was being acceptably implemented and was up to date.

Medical examinations were being completed biennially as required.

Surveillance and Limiting Conditions for Operations The program for tracking and completing surveillance checks and complying with LCOs satisfied TS requirements.

Experiments Conduct and control of experiments and irradiations met the requirements specified in the TSs, the applicable experiment irradiation authorizations, and associated procedures.

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Design Changes The only changes made in the past two years which required the licensee to use the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments, were changes to the Standard Operating Procedures (SOPs) which were subsequently reviewed and approved by the Reactor Safeguards Committee (RSC).

Committees, Audits, and Reviews The review and audit program were being conducted by the RSC.

The composition of the committee and the meeting frequency satisfied requirements specified in the TSs.

Emergency Preparedness The Emergency Plan (E-Plan) and Implementing Procedures were being reviewed biennially and updated as required.

Emergency response facilities and equipment were being maintained as required and responders were knowledgeable of proper actions to be taken in case of an emergency.

Off-site support was acceptable and communications capabilities were adequate.

Annual drills were being conducted and critiques were being held as required by the E-Plan.

Maintenance Logs and Records Maintenance logs, records, performance, and reviews satisfied TSs and procedural requirements.

Fuel Handling Fuel handling activities and documentation were in compliance with the requirements specified in the TSs and procedures.

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REPORT DETAILS Summary of Facility Status The Washington State University (WSU) 1 megawatt (MW) Modified TRIGA research reactor, located in the Nuclear Radiation Center, continued normal, routine operations. A review of the applicable records indicated that the reactor was operated as needed in support of education, operator training, and irradiation of various materials. During the inspection, the reactor was operated at levels up to 1 MW and in accordance with applicable procedures to support ongoing irradiation activities.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)

The inspector reviewed the following regarding the licensees organization and TSs, implemented as Appendix A to the Facility Operating License Number (No.) R-76, dated September 30, 2011, were being met:

Management responsibilities Selected facility Reactor Operating Log sheets for the period from 2017 to the present WSU Nuclear Radiation/Science Center (NSC) organizational structure and staffing WSU Annual Report entitled, Annual Operations Report for the Washington State University TRIGA Reactor, for the period from July 1, 2016, through June 30, 2017, dated August 22, 2017 WSU Annual Report entitled, Annual Operations Report: Washington State University TRIGA Reactor, for the period from July 1, 2017, through June 30, 2018, dated August 20, 2018 WSU NSC Administrative Procedure No. 1, Responsibilities and Authority of Reactor Operating Staff b. Observations and Findings The inspector noted that the organizational structure at the WSU Nuclear Radiation Center (currently known as the NSC) and the responsibilities of the reactor staff had not changed since the last inspection. The Director of the NSC continued to report to the Vice President for Research. The Director was responsible for ensuring the implementation of the applicable regulatory requirements. The NSC Reactor Supervisor continued to report to the Director and was responsible for guidance, oversight, and technical support of reactor operations.

Also, as required by TS Section 6.2, a senior reactor operator (SRO) or reactor operator (RO) was present in the control room during reactor operations. If the SRO on duty was also the RO on duty then a second person was available at the facility. The licensee documented this by individual log entries. At the time of the inspection, there were two licensed SROs and one licensed RO employed at the facility. The two SROs were full-time staff and the RO was a student employee.

It was also noted that seven students had recently taken their NRC operator-4-

licensing examinations and were awaiting official notification of the results. Two of these students were working at the facility during the summer months while the others had left for summer break.

Although the organizational structure had not changed, the inspector noted that personnel changes had occurred. The individual who had been serving as the facility Director (TS Level 2) had left WSU and was now employed at the University of Florida. A new Director has yet to be approved but, in the meantime, the former Assistant Director (and Reactor Supervisor) was appointed as the Interim Director and took over on June 15, 2019. A new Reactor Supervisor had also been appointed as well. The licensee had submitted a report of this change to the NRC as required. The inspector verified that those newly appointed to the aforementioned positions were qualified as specified in TS Section 6.3.

c. Conclusion The organizational structure and staffing levels were consistent with the requirements specified in TS Sections 6.1 - 6.3. Personnel changes in some key positions of the organization had occurred.

2. Operations Logs and Records a. Inspection Scope (IP 69001, Section 02.02)

The inspector reviewed selected aspects of the following to verify compliance with the requirements of TS Section 6.2 and the applicable procedures:

• Observation of selected operations activities

• Scram Summary Log (S.1) entries for the period from 2017 to the present

• Pulsing Summary Log (S.2) entries for the period from 2017 to the present

• WSU, NSC Maintenance Log (O.8) for the period from 2017 to the present

• Various Reactor Operating Log sheets for the period from 2017 through the present, NSC Form No. 22 entitled, WSU Nuclear Science Center O.1 Reactor Log

• Selected entries on Reactor Start-Up Check-off (O.3) forms for the period from 2017 through the present, WSU NSC Form No. 34, entitled, WSU Reactor Start-Up Check-off

• WSU NSC Administrative Procedure No. 1, Responsibilities and Authority of Reactor Operating Staff

• WSU NSC SOP No. 1, Standard Procedure for Use of the Reactor

• WSU NSC SOP No. 2, Standard Procedure for Startup, Operation, and Shutdown of the Reactor

• WSU Annual Reports for the two most recent reporting periods b. Observations and Findings The inspector observed reactor operations including startup, routine operation, and shutdown each day during the inspection. Reactor operations were carried out following written procedures and in accordance with TS requirements. Shift-5-

staffing satisfied the minimum requirements for duty and on-call personnel.

Quarterly audits of operations were conducted by RSC personnel. Required logs were being maintained and the inspector noted accurate correlation between reactor logs, scram logs, pulse logs, and maintenance logs. Equipment problems and events were well documented and resolved, with SRO approval, if required, for restart of the reactor.

c. Conclusion The operational activities were found to be consistent with applicable TS and procedural requirements.

3. Procedures a. Inspection Scope (IP 69001, Section 02.03)

The inspector reviewed selected aspects of the following to verify that the licensee was complying with the requirements of TS Section 6.8:

Required Reading Notebook (O.15)

Selected administrative and SOP Related logs and records documenting procedure implementation Records documenting procedure changes and temporary changes Administrative controls as outlined in WSU NSC Administrative Procedure No. 2, Approval, Revision, and Review of Standard Operating Procedures b. Observations and Findings Procedures were available for those tasks and activities specified in the TS.

Records showed that procedures for potential malfunctions (e.g., radioactive releases, contaminations, and reactor equipment problems) had been developed and were being implemented as required. If procedure changes were needed, they were reviewed and approved by the RSC as required. The SOPs were reviewed biennially as required by TS Section 6.8. It was noted that all the operating procedures at the facility had been revised and updated in 2017 to reflect current operational activities Training of personnel on procedures and the applicable changes was acceptable.

The licensee maintained a notebook entitled, Required Reading, that was used to keep staff members informed of current issues at the facility including changes to procedures. The inspector verified that licensee personnel were reading the material in the notebook and signing off to document that they had completed the required review.

Through observation of reactor operations, the inspector also verified that personnel conducted TS activities in accordance with applicable procedures.

c. Conclusion Procedural review, revision, control, and implementation satisfied TS requirements.

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4. Operator Requalification Program a. Inspection Scope (IP 69001, Section 02.04)

The inspector reviewed the following in order to determine that operator training and requalification activities were conducted as required and that medical requirements were met:

• Biennial written examination records for 2016 through the present

• Operator medical examination records from 2016 to the present

• Operator license status and effective dates of current operator licenses

• WSU NSC Reactor Staff Requalification Program, last revised May 15, 2010

• Active duty status and Annual Reactor Operating Test results noted and maintained in the Operator Requalification Schedule forms (A.3)

• Logs and records of reactivity manipulations maintained in the Quarterly RO/SRO Activity Report (O.14) Notebook and documented on forms entitled, Quarterly Operations Summary Checklist b. Observations and Findings As noted above, there were two licensed SROs and one licensed RO working at the facility. The inspector noted that the licenses of the operators were current.

A review of the logs and records showed that the training and requalification program was being followed and that biennial written examinations had been completed as required. An annual operating test had been conducted for each operator by the Reactor Supervisor or the Assistant Facility Director as required by the program. The inspector verified that a quarterly operations certification was completed for each operator as required by the program. The quarterly certification helped ensure that each operator had completed the required number of hours of reactor operation and reactivity manipulations as stipulated in the Requalification Program.

The inspector noted that operators who failed to perform the minimum operations in a calendar quarter were considered to be unqualified. In order to be requalified, an individual was required to complete an operating test and conduct reactor operations for six hours under supervision. The inspector verified that this condition of the program was being implemented.

The inspector also reviewed records documenting the completion of physical examinations for selected operators. It was noted that licensed operators were receiving biennial medical examinations as required.

The inspector verified that the licensee was maintaining the files and records of former operators for a period of more than three years.

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c. Conclusion The requalification and training program was current and being acceptably maintained. Medical examinations for each operator were being completed biennially as required.

5. Surveillance and Limiting Conditions for Operation a. Inspection Scope (IP 69001, Section 02.05)

To verify compliance with TS Sections 3 and 4, the inspector reviewed selected aspects of:

• Control Element Inspection Log (O.5) for 2017 through the present

• Monthly Core Reactivity Parameters Log (O.7) for 2017 through the present

• Preventative Maintenance Checklists (O.2) for 2017 through the present

• Power Calibration Log forms (also in O.2) for 2017 through the present

• RSC meeting minutes for 2016 to the present

• Monthly Console and Auxiliary Equipment Checklist Log (O.9) containing documentation of equipment maintenance as indicated on the WSU NSC Form No. 40, entitled, Console Auxiliary Equipment Maintenance Checklist

• Reactor Operating Log (O.1) sheets for the period from 2018 through the present, NSC Form No. 22 entitled, WSU Nuclear Science Center Reactor Log

• Various WSU NSC SOPs including: SOP No. 11, Standard Procedure for Maintenance of the Control Elements; No. 20, Standard Procedure for Performing Power Calibrations; No. 23, Standard Procedure for Annual Fuel Inspection; No. 24, Standard Procedure for Fuel Burnup Calculation; and, No. 25, Standard Procedure for Core Changes and Fuel Movement

• WSU Annual Reports for the two most recent reporting periods b. Observations and Findings The Inspector determined that the daily, weekly, monthly, semiannual, annual, and other periodic checks, tests, and verifications for TS required LCOs were being completed as required. Extensive checklists were used to track completion of the various required surveillances and LCO verifications. The checklists included the date and initials or signature of the person confirming that each activity was completed as required. All recorded results observed by the inspector were within prescribed TSs and procedural parameters and in close agreement with the previous surveillance results.

c. Conclusion The surveillance logs, records, performance, and reviews satisfied TSs and procedure requirements. The program for tracking and completing surveillance requirements was detailed and thorough.

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6. Experiments a. Inspection Scope (IP 69001, Section 02.06)

To verify compliance with the licensees program for conducting experiments and irradiations as outlined in TS Sections 3.6, 4.6, and 6.4.7 and in various procedures, the inspector reviewed selected aspects of:

• WSU NSC Irradiation Data Log sheets for the period from 2017 to the present

• WSU NSC Reactor Operating Log (O.1) sheets for the period from 2017 to the present

• Recent experiment approvals documented on WSU NSC Form No. 1, entitled, Project Initiation Request Form, with the associated experiment overviews, safety reviews and analyses, isotope production data, accident analyses, and approvals

• Various WSU NSC SOPs including: No. 1, Standard Procedure For Use Of The Reactor; No. 2, Standard Procedure For Startup, Operations and Shutdown of The Reactor; and, No. 3, Standard Procedure For Performing Experiments Using The Reactor b. Observations and Findings No new experiments had been proposed since the last inspection. The inspector verified that any recent modifications or revisions to existing experiments were minor in nature and had been reviewed and approved by an SRO and the Assistant Facility Director or the Facility Director. Established experiments had been approved by the RSC as required. The inspector also verified that, when the experiments were conducted, they were completed under the supervision of the SRO on duty and in accordance with procedural and TS requirements.

The inspector reviewed the existing experiment and irradiation authorization documents, Irradiation Data Log sheets, and Reactor Operating Log sheets, and interviewed staff members as well. It was noted that irradiation request forms (WSU NSC Form 1) and any addenda did not have an expiration date assigned.

However, if the experiment was to be performed, the form was only valid for the core number and letter specified (e.g. Core 35A) for which the experiment was reviewed. If a new core designation was involved, the experiment had to be reevaluated and recalculated with new flux numbers to determine the new irradiation times and to ensure that no new safety questions had arisen as a result.

The inspector determined that the information typically entered on the Irradiation Data Log sheets was now being entered into a data base developed by facility personnel. The appropriate data was recorded, and the radioactive material produced as a result of the irradiations was handled and controlled as required.

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c. Conclusion The conduct and control of experiments and irradiations met the requirements specified in the TSs, the experiment irradiation authorizations, and applicable procedures.

7. Design Changes a. Inspection Scope (IP 69001, Section 02.08)

The inspector reviewed the following to verify compliance with 10 CFR 50.59 regarding design change control:

• RSC meeting minutes for 2016 to the present

• Safety review and audit records for the past two years

• Selected Reactor Operating Log sheets for 2018 and 2019 to present RSC Facility Records Quarterly Audits for 2016 to the present documenting reviews of operations records, summary records, and administrative records WSU NSC Administrative Procedure No. 3, Approval and Review of Facility Modifications and Special Tests or Experiments

• WSU Annual Reports for the two most recent reporting periods b. Observations and Findings The inspector reviewed the records and observed that no changes to facility design or performance characteristics had been made at the facility from 2017 to the present. It was noted that the SOPs had been revised in 2017 and had been presented to the RSC for review and approval on May 9, 2017, as required.

The inspector reviewed the licensees procedure dealing with changes and verified that it appropriately incorporated the criteria included in 10 CFR 50.59.

Prior to implementing substantive changes, the licensee was required to submit them to the RSC where they were reviewed and, if determined to be acceptable, approved by the committee. The inspector noted that the facility modification procedure had been followed in the past and an evaluation was completed if required.

c. Conclusion The only changes made in the past two years which required the licensee to use the criteria specified in 10 CFR 50.59 were changes to the SOPs which were subsequently reviewed and approved by the RSC.

8. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)

In order to verify that the licensee had established and conducted reviews and audits as required in TS Section 6.4, the inspector reviewed selected aspects of:

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• Current RSC Charter dated July 2018

• WSU RSC meeting minutes for 2016 and to the present

• Safety review and audit records documented on WSU NSC forms entitled, Reactor Safeguards Committee Facility Records Quarterly Audit, for the period from March 2016 through the present

• WSU Annual Reports for the two most recent reporting periods b. Observations and Findings The RSC membership satisfied TS requirements and the Committee's procedural rules. The RSC, or a subcommittee thereof, was required to hold semi-annual meetings each year. It was noted that three committee meetings were held in 2016, 2017, and 2018, and one committee meeting had been held to date in 2019.

Review of the committee meeting minutes indicated that the RSC provided appropriate guidance and direction for reactor operations. Additionally, the annual review of the radiation protection program and the biennial reviews of the SOPs, the E-Plan, and the security plan had been conducted and documented.

Since the last inspection, audits of reactor facility records, radiation exposures and dose records, and conformance to TS and license conditions had been completed and documented. Biennial audits of the Emergency Plan and implementing procedures, Operator Requalification Plan, and Security Plan had also been completed. The inspector noted that many audits were typically conducted during the meetings held by the RSC.

c. Conclusion The review and audit program was being completed acceptably by the RSC.

9. Emergency Preparedness a. Inspection Scope (IP 69001, Section 02.10)

To ensure that the licensee was acceptably implementing the various aspects of their emergency preparedness program, as stipulated in the E-Plan for the WSU NSC dated May 21, 2015, the inspector reviewed selected aspects of:

• Emergency drills and exercises for the past two years

• Administrative Requirements Schedule Log (A.4) sheets

• Training records for licensee staff and support personnel

• Emergency response facilities, supplies, equipment, and instrumentation

• Offsite support as documented in the Letter of Agreement with the Pullman Regional Hospital

• WSU NSC SOPs No. 14, Standard Procedure in the Event of an Emergency Situation, and, No. 15, Standard Procedure for Action in the Event of an Alarm

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b. Observations and Findings The E-Plan in use at the facility, entitled, Emergency Preparedness Plan for the Nuclear Science Center, Washington State University, was being reviewed biennially by the RSC and updated as required by the TSs.

Emergency facilities, instrumentation, and equipment were being maintained and controlled as required. Emergency supplies were being inventoried monthly which was more frequently than required in the E-Plan. The inspector verified that the supplies were in place as indicated by accompanying licensee personnel as they inventoried the emergency supply kit located in the front office.

Communications capabilities with the various campus, city, county and other off-site support groups, were verified to be acceptable and in accordance with the E-Plan. The inspector verified that the alarm system had been tested weekly and monthly as stipulated in the E-Plan.

The inspector determined that the emergency drills were being conducted as required by the E-Plan. Critiques were written following the drills and they addressed problems noted during the conduct of the drill with assigned corrective actions. Emergency exercises were also typically completed semiannually.

The Inspector determined through records review and through interviews with licensee personnel that emergency responders were knowledgeable of the proper actions to take in case of an emergency. The agreement with the Pullman Regional Hospital, which had been updated May 25, 2018, was noted to be in effect until 2020.

Various crews and/or personnel from off-site support organizations such as the Fire Department, the Pullman Regional Hospital, and the Whitman County Emergency Management center visited the facility periodically and received training provided by the licensee annually on a rotating basis. As a result of the training, they were familiar with the facility and what would be required during a response. Emergency preparedness and response training for staff was also being completed annually as required.

The inspector, accompanied by the Reactor Supervisor and a Reactor Operator trainee, visited the Pullman Regional Medical Center and observed the room that had been designed for response to an emergency at the NSC. From this observation, and as a result of reviewing the licensees records documenting drills and training, the inspector verified that medical support personnel were well trained, properly equipped, and knowledgeable of the actions to take in case of an emergency at the reactor facility. The inspector determined that the licensee was maintaining a good working relationship with this support group.

c. Conclusion The emergency preparedness program was conducted in accordance with the requirements stipulated in the E-Plan.

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10. Maintenance Logs and Records a. Inspection Scope (IP 69001, Section 02.11)

To verify compliance with TS Sections 3, 4, and 5, the inspector reviewed selected aspects of:

• Maintenance Log, Volume 1 (O.8)

• Reactor Operations Summary Sheets for 2017 and to date in 2019

• Control Element Inspection Log (O.5) for 2017 and to date in 2019

• Monthly Core Reactivity Parameters Log (O.7) for 2017 and to date in 2019

• Preventative Maintenance Checklists (O.2) for 2017 and to date in 2019

• RSC meeting minutes for 2016 to date in 2019

• Power Calibration Log forms (also in O.2) for 2017 and to date in 2019

• Monthly Console and Auxiliary Equipment Checklist Log (O.9) containing documentation of equipment maintenance as indicated on the WSU NSC Form No. 40, entitled, Console Auxiliary Equipment Maintenance Checklist

• WSU NSC Reactor Operating Log (O.1) sheets from January 2017 to date in 2019

• WSU NSC Administrative Procedure, Section No. 5, entitled, Surveillance Documentation Review

• WSU NSC Administrative Procedure, Section No. 6, entitled, Performance of Maintenance Activities

• Various WSU NSC SOPs including: No. 5, Standard Procedure for Performing Preventive Maintenance; No. 6, Standard Procedure for Maintenance of the Area Radiation Monitors; No.10, Standard Procedure for Maintenance of the Reactor Pool Facilities; and, No. 11, Standard Procedure for Maintenance of the Control Elements

• WSU Annual Reports for the two most recent reporting periods b. Observations and Findings The Inspector noted that routine and preventive maintenance was controlled by, and documented in, the maintenance or reactor operations logs and the monthly Console Auxiliary Equipment Maintenance Checklists consistent with the TSs and licensee procedures. Unscheduled maintenance or equipment repair, which was documented in the Maintenance Log, was reviewed to determine if the work required a 10 CFR 50.59 evaluation. Following that determination (and evaluation if necessary), the unscheduled maintenance issue was resolved.

Verifications and operational systems checks were performed following completion of the maintenance to ensure system operability before the equipment was returned to service.

c. Conclusion The maintenance logs, records, performance, and reviews satisfied TSs and procedure requirements.

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11. Fuel Handling Logs and Records a. Inspection Scope (IP 69001, Section 02.12)

The inspector reviewed selected aspects of the following to ensure that the licensee was complying with TS Sections 4.1.6 and 5.2:

• Core Change Log (O.6) through July 2019

• Fuel handling equipment and instrumentation

• Control Element Inspection Log (O.5) for 2018 and 2019

• Monthly Core Reactivity Parameters Log (O.7) for 2018 and 2019

• Selected Reactor Operating Log sheets from 2018 through the present

• WSU special nuclear material Physical Inventory Log sheets dated March 21, 2012, from 2018 through the present

• WSU NSC Administrative Procedure, Section No. 9, entitled, Special Nuclear Material Accountability Plan

• WSU NSC SOPs No. 23, Standard Procedure for Annual Fuel Inspection, and, No. 11, Standard Procedure for Maintenance of the Control Elements b. Observations and Findings Procedures for refueling, fuel movement, and TSs required surveillances ensured controlled operations for the licensees fuel maintained in the current core designated as Core 35-A. A detailed plan for performing fuel movement was required to be developed prior to each fuel movement operation. The inspector verified that the fuel handling equipment was securely stored as required.

The inspector noted that the data recorded for fuel movements were acceptable and were cross referenced in the operations logs as required. Log entries, indicating fuel movements, were completed under the direct supervision of a SRO as required.

Through records review and interviews with licensee personnel, the inspector determined that various fuel movement operations had been conducted since the last inspection in this area. The most significant fuel movement involved removing fuel bundles from the core to allow for fuel inspection. The inspector verified that twenty percent of the fuel elements were inspected each year such that all elements were inspected within a five-year period as required. The lasted fuel inspection occurred in January 2019. The inspector also verified that a detailed plan had been completed for the fuel movement activities as required.

The plan had been reviewed and approved by the Assistant Facility Director and the Facility Director as required.

c. Conclusion Fuel handling activities and the documentation thereof were as required by facility TSs and procedures.

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8. Exit Interview The inspection scope and results were summarized on July 11, 2019, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the inspection results presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel H. Bennett Reactor Supervisor and Senior Reactor Operator G. Dutta Assistant Vice President for Research Advancement and Partnerships, WSU M. Heine Reactor Operator trainee (awaiting licensed status notification)

C. Hines Interim Director, Nuclear Science Center C. Jackson Administrative Assistant Vice President for Research, WSU B. Tanner Reactor Operator trainee (awaiting licensed status notification)

Other Personnel H. Kimball Corporate Compliance, HIPPA, and Safety Coordinator, Pullman Regional Hospital S. Knewbow Director of the Emergency Department, Pullman Regional Hospital INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations E-Plan Emergency Preparedness Plan IP Inspection Procedure LCO Limiting Conditions for Operation MW Megawatt No. Number NRC U.S. Nuclear Regulatory Commission NSC Nuclear Science Center RO Reactor Operator RSC Reactor Safeguards Committee SOP Standard Operating Procedure SRO Senior Reactor Operator TSs Technical Specifications WSU Washington State University Attachment