IR 05000027/2023201
| ML23137A414 | |
| Person / Time | |
|---|---|
| Site: | Washington State University |
| Issue date: | 06/13/2023 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Hines C Washington State Univ |
| Bassett C | |
| References | |
| IR 2023201 | |
| Download: ML23137A414 (16) | |
Text
June 13, 2023
SUBJECT:
WASHINGTON STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE SAFETY INSPECTION REPORT NO. 05000027/2023201
Dear Mr. Hines:
From March 27 - 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Washington State University Modified TRIGA [Training, Research, Isotopes, General Atomics] Reactor located in the Nuclear Science Center of the Dodgen Research Center. The enclosed report presents the results of that inspection that were discussed on March 30, 2023, with you and the reactor supervisor.
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 inspectors reviewed selected procedures and records, observed various activities, and interviewed personnel. Based on the results of this inspection, no findings of non-compliance with NRC requirements were identified. No response to this letter is required.
In accordance with Title 10 of the Code of Federal Regulations 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 Publicly Available Records component of NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC website at https://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 by email to Craig.Bassett@nrc.gov.
Sincerely, Signed by Tate, Travis on 06/13/23 Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No.50-027 License No. R-76 Enclosure:
As stated cc: GovDelivery Subscribers
ML23137A414 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/RI OE/AT/TL NAME CBassett AWaugh DWillis DATE 5/18/2023 5/18/2023 5/19/2023 OFFICE NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME NParker TTate DATE 5/24/2023 6/13/2023
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-027 License No.: R-076 Report No.: 05000027/2023201 Licensee: Washington State University Facility: Washington State University Modified TRIGA Reactor Location: Pullman, Washington Dates: March 27-30, 2023 Inspectors: Craig Bassett, Reactor Inspector Andrew Waugh, Reactor Inspector Dori Willis, Headquarters Allegation Team Lead Molly Keefe-Forsyth, Safety Culture Program Manager Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure
EXECUTIVE SUMMARY Washington State University Washington State University Modified TRIGA Reactor Inspection Report No. 05000027/2023201 The primary focus of this routine, announced safety inspection was the onsite review of selected aspects of the Washington State University (WSU, the licensees) Class II 1,000 kilowatt research reactor safety program, including: (1) organization and staffing; (2) operations logs and records, (3) requalification training; (4) surveillance and limiting conditions for operation (LCOs);
(5) experiments; (6) design changes; (7) committees, audits and reviews; (8) emergency planning; (9) maintenance logs and records; (10) fuel handling logs and records; and safety-conscious work environment. The U.S. Nuclear Regulatory Commission (NRC) staff determined the licensees program was acceptably directed toward the protection of public health and safety, and in compliance with the NRC requirements. Additionally, the inspectors determined that the WSUs Nuclear Science Center (NSC) staff members felt free to raise safety concerns to management.
Organization and staffing Organizational structure and staffing were consistent with technical specification (TS)
requirements.
Operation Logs and Records The operation logs and records were maintained in accordance with facility procedures and TSs.
Requalification and Training The requalification program was conducted consistent with the TSs, licensee procedures, and regulations.
Surveillance and Limiting Conditions for Operation The surveillance program and supporting procedures met TS requirements and operations met the LCO and surveillance requirements.
Experiments Experiments and irradiations were performed in accordance with TSs, the applicable experiment irradiation authorizations, and associated licensee procedures.
Design Changes The evaluation, and documentation of changes to the facility satisfied NRC requirements.
Committees, Audits and Reviews The review and audit program were completed by the Reactor Safeguards Committee
(RSC) as stipulated in the TSs.
Emergency Planning The emergency plan (E-Plan) oversight, drills, and training were implemented as required by facility procedures and regulations.
Maintenance Logs and Records Records documenting principal maintenance activities were maintained in compliance with TS requirements and facility procedures.
Fuel Handling Logs and Records The licensee conducted and documented fuel handling activities in accordance with TS requirements and facility procedures.
Safety-Conscious Work Environment The inspectors determined that there were no identifiable issues of concern regarding facility safety culture or a safety-conscious work environment.
REPORT DETAILS Summary of Facility Status The licensees Class II 1,000 kilowatt Modified Training, Research, Isotopes, General Atomics (TRIGA) research reactor was operated in support of undergraduate instruction, laboratory experiments, reactor operator training, and various types of research. During the inspection, the reactor was started up, operated, and shut down as needed in accordance with applicable procedures to support ongoing activities.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)
The inspectors reviewed the following to verify compliance with the organization and staffing requirements in TS 6.1 and 6.2:
facility organizational structure and shift staffing current copy of the TSs for the WSU TRIGA reactor daily reactor startup and shutdown checklists for 2021 to the present completed sheets of WSU Nuclear Science Center (NSC) Form No. 22, WSU Nuclear Science Center O.1, Reactor Log, for 2021 to the present b. Observations and Findings The inspectors verified that management responsibilities were administered as required by TS and applicable procedures. The inspectors confirmed that licensee shift staffing met the minimum requirements for duty and on call personnel. The inspectors noted that there were two licensed senior reactor operators, five licensed reactor operators (ROs),
and five operator trainees on staff at the facility.
c. Conclusion The inspectors determined that the organizational structure and the responsibilities of the reactor management and staff have not changed since the last inspection and shift staffing met the minimum requirements for duty and on call personnel.
2. Operations Logs and Records a. Inspection Scope (IP 69001-02.02)
To ensure that the requirements of TS 6.9 were met, the inspectors reviewed the following:
scram summary log (S.1) from 2021 to the present standard operating procedure (SOP)-1, Use of the Reactor SOP-2, Standard Procedures for Startup, Operation, and Shutdown of the Reactor completed WSU NSC Forms No. 22 (Reactor Log) for 2021 to the present requests for operation
pre-start and post-shutdown forms WSU annual report entitled, Annual Operations Report: Washington State University TRIGA Reactor, for the period from July 1, 2020, through June 30, 2021 WSU annual report entitled, Annual Operations Report: Washington State University TRIGA Reactor, for the period from July 1, 2021, through June 30, 2022 b. Observations and Findings The inspectors observed that logbook entries were maintained in accordance with approved procedures. The inspectors review determined that logs and records are maintained as required by the licensee's administrative procedures. The inspectors verified that records also showed that operational conditions and parameters were consistent with the license and TS requirements.
c. Conclusion The inspectors determined the licensees logbook records and record keeping programs were maintained as required by WSU procedures and met the retention requirements of the TSs.
3. Requalification Training a. Inspection Scope (IP 69001-02.04)
The inspector reviewed the following aspects of the licensees requalification program to verify compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators Licenses, and the licensees NRC-approved operator requalification program:
medical records for select licensed operators Reactor Staff Requalification Program, dated August 2, 2018 select annual reactor operation exams from 2021 to the present select biennial written requalification exams from 2021 to the present requalification records for select licensed operators from 2021 to the present b. Observations and Findings The inspectors found that the licensees training was conducted and documented in accordance with their NRC-approved requalification and training program, and that the licensed operators requalification training and medical records were maintained.
c. Conclusion The inspector determined that the operator requalification program was conducted and completed in accordance with the NRC-approved program and that the medical evaluations were completed in accordance with regulatory requirements.
4. Surveillance and Limiting Conditions for Operation a. Inspection Scope (IP 69001-02.05)
To ensure that various requirements of TSs 3 and 4 were met, the inspectors reviewed the following:
SOP-20, Standard Procedure for Reactor Power Calibrations power calibration log forms (also in O.2) for 2021 through the present monthly core reactivity parameters log (O.7) from 2021 to the present SOP-5, Standard Procedure for Performing Preventative Maintenance completed WSU NSC Forms No. 22 (Reactor Log) for 2021 to the present WSU NSC Administrative Procedure - 5, Surveillance Documentation Review b. Observations and Findings The inspectors selected a sample of the TS-required surveillances to verify implementation and determined that the frequency and results met TS requirements.
The inspectors also verified surveillance results were retained as required by TS 6.8.1 and licensees procedural requirements.
c. Conclusion The inspectors determined that operations followed the LCOs, and surveillance requirements as stated in the TSs.
5. Experiments a. Inspection Scope (IP 69001-02.06)
The inspectors reviewed the following to verify compliance with TS 3.6 and 4.6:
WSU NSC irradiation data log sheets for the period from 2021 to the present completed WSU NSC Forms No. 22 (Reactor Log) for 2021 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 SOP-4, Standard Procedure for High Activity or Long Duration Experiments b. Observations and Findings The inspectors found that the various experiments conducted at the facility were reviewed and approved. The inspectors also noted that recently a new experiment was proposed, and it was reviewed and approved by the RSC as required by the TSs. The inspectors noted that irradiations were conducted under the cognizance of the Reactor Supervisor. The inspectors verified that irradiations were documented in the console logs and the resulting radioactive material was transferred to an authorized user, disposed of as stipulated by procedure, or held for decay.
The inspectors also reviewed the circumstances surrounding a failure of an aluminum can used for an in-core experiment which occurred in December 2022. The inspectors noted that the licensee routinely placed samples in aluminum cans (tuna cans) to be irradiated in the reactor. In December 2022, the wrong sample was placed in the tuna can and irradiated in the reactor. The intended sample was to be irradiated for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day for 5 days. As a result of the wrong sample being placed into the tuna can, it failed while being irradiated, and radioactive material was released into the reactor pool.
The inspectors found that, by procedure, tuna cans were durable and could be irradiated for up to 45 Megawatt hours without degradation. The inspectors noted that the experiment in the tuna can would have been irradiated for up to 60 Megawatt hours if no problems had developed. The inspector also noted the licensee performed a study on the tuna cans and determined that the cans could be irradiated up to 200 Megawatt hours without damage. After a review of the study done by the licensee, the inspectors found that the licensee performed a proper analysis for the planned irradiation activity.
However, the inspectors questioned the licensee about updating the procedure to reflect the results of the study. The licensee indicated that revisions to the procedure were not yet completed. The inspectors informed the licensee that updating the procedure would be considered by the NRC as an Inspector Follow-up Item (IFI) and would be reviewed during the next inspection of the facility (IFI 05000027/2023201-01).
c. Conclusion The inspectors concluded that experiments were reviewed and performed in accordance with the TS requirements and the licensees written procedures. The failed experiment was not a violation because no radiological limits were exceeded.
6. Design Changes a. Inspection Scope (IP 69001, Section 02.08)
The inspectors reviewed the following to ensure that proposed design changes were reviewed and approved in accordance with 10 CFR 50.59, Changes, tests and experiments, TS 6.4.4, and the licensees administrative procedures:
RSC meeting minutes for 2021 through the present current copy of the TSs for the WSU TRIGA Mark-I Reactor completed WSU NSC Forms No. 22 (Reactor Log) for 2021 to the present annual operating reports for the WSU TRIGA reactor facility for 2021 and 2022 b. Observations and Findings The inspectors confirmed that the licensee performed 10 CFR 50.59 screenings for two facility modifications since the last inspection and that the screenings indicated no need to complete full evaluations for the proposed changes. The inspectors verified that the licensees design change process met the requirements of 10 CFR 50.59.
c. Conclusion The inspectors determined that the facilitys design change program satisfied NRC
requirements specified in 10 CFR 50.59.
7. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)
The inspectors reviewed the following to ensure that audits and reviews stipulated in the facilitys TS 6.4 were conducted:
RSC meeting minutes for 2021 through the present current copy of the TSs for the WSU TRIGA Mark-I Reactor audit reports completed by the reactor supervisor and submitted to the RSC annual operating reports for the WSU TRIGA reactor facility for 2021 and 2022 b. Observations and Findings The inspectors verified that the RSC conducted meetings at the required frequency with a quorum present pursuant to TS requirements and reviewed and approved procedures and experiments and provided oversight of reactor operations. The inspectors also confirmed that the RSC reviewed and audited facility operations as required in the TSs and that the audit frequency met the requirements of the TSs.
c. Conclusion The inspectors determined that the RSC provided the oversight required by the TSs.
8. Emergency Planning a. Inspection Scope (IP 69001-02.10)
To verify compliance with the WSU NSC E-Plan, the inspectors reviewed selected aspects of the following:
WSU NSC E-Plan, dated April 2020 training records for licensee staff and support personnel WSU NSC implementing procedures, dated March 2021 2021 emergency drill final report, dated November 22, 2021 2022 emergency drill final report, dated December 6, 2022 offsite support as documented in the letter of agreement with the Pullman Regional Hospital b. Observations and Findings The inspectors verified the E-Plan and implementing procedures were current, approved by management, and readily available in several locations for use as required by the E-Plan. The inspectors verified that semi-annual equipment checks were completed for the emergency supply cabinets located in the facility which ensured the availability and operability of emergency equipment.
The inspectors confirmed that the licensee continued to maintain a current
memorandum of understanding with the Pullman Regional Hospital to support both onsite and offsite emergency response. The inspectors verified reactor staff training was completed annually, as required by the E-Plan. Additionally, the inspectors verified that annual emergency drills, required by the E-Plan, were conducted for the past 2 years and included participation of offsite organizations.
An inspector and the reactor supervisor visited the Pullman Regional Hospital and noted that the hospital was equipped to handle any type of emergency that might occur and the WSU NSC. The inspector noted a good working relationship between the hospital staff and reactor personnel.
c. Conclusion The inspectors determined that the licensee met the requirements of the approved E-Plan.
9. Maintenance Logs and Records a. Inspection Scope (IP 69001-02.11)
To ensure that the maintenance requirements of TSs 6.8.(2) and 6.9.1 were met, the inspectors reviewed the following:
reactor operations summary sheets from 2021 to the present control element inspection log (O.5) from 2021 to the present preventative maintenance checklists (O.2) from 2021 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 completed WSU NSC Forms No. 22 (Reactor Log) for 2021 to the present Observations and Findings The inspectors determined that the selected significant maintenance items reviewed were documented and resolved as required by the licensees administrative procedures.
Additionally, the inspectors verified by document review that maintenance records were retained for at least 5 years as required by TS 6.9.1.
b. Conclusion The inspectors determined the licensee kept records documenting maintenance activities in compliance with TS requirements.
10. Fuel Handling Logs and Records a. Inspection Scope (IP 69001-02.12)
To ensure that the requirements of TSs 3.1.6 and 4.1.6 were met, the inspectors reviewed the following:
control element inspection log (O.5) from 2021 to the present SOP 23, Standard Procedure for Annual Fuel Inspections core 35-a cumulative inspection summary, dated April 29, 2022 core 35-a cumulative inspection summary, dated March 27, 2023 Administrative Procedure-7, Material Control & Accountability Plan, Revision 0.1 completed WSU NSC Forms No. 22 (Reactor Log) for 2021 to the present fuel movement and surveillance records b. Observations and Findings The inspectors determined that two fuel inspections have occurred since this module was previously inspected. The inspectors confirmed that during the fuel inspections, approximately 20 percent of the fuel elements were inspected in accordance with TS 4.1.6. The inspectors reviewed the results and verified that all fuel elements met the criteria specified in TS 3.1.6. In addition, the inspectors reviewed core configuration changes and verified that they were documented and followed established procedures.
c. Conclusion The inspectors determined that the licensee conducted and documented fuel handling activities in accordance with TS requirements and licensee procedures.
11. Safety-Conscious Work Environment Issue of Concern Follow-up a. Inspection Scope (IP 93100)
To assess the facility safety culture (SC) and safety-conscious work environment (SCWE),
the inspectors interviewed various staff members and reviewed the following:
various WSU NSC policies and procedures reactor operations and experiments b. Observations and Findings The purpose of this portion of the inspection was to conduct an assessment the SCWE and leadership safety values and action attributes of WSU NSC safety culture. The inspectors assessed the environment at WSU NSC using Inspection Procedure 93100, Safety-Conscious Work Environment Issue of Concern Follow-up.
The NRC safety culture policy statement (76 FR 34773; June 14, 2011), sets forth the Commission's expectation that licensees establish and maintain a positive SC commensurate with the safety and security significance of their activities and the nature and complexity of their organizations and functions. The NRC defines nuclear SC as the core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals to ensure protection of people and the environment. A SCWE is defined by the NRC as an environment in which employees are encouraged to raise safety concerns, are free to raise concerns to both their management and NRC without fear of retaliation, where concerns are promptly reviewed, given the appropriate priority, and are appropriately resolved, and where timely feedback is provided and is one trait of a strong safety culture. NRC Regulatory
Issue Summary 05-018, Guidance for Establishing and Maintaining a Safety-Conscious Work Environment, dated August 25, 2005, further describes the NRCs expectations in this area.
The primary focus of this inspection was to determine WSU NSC staffs: (1) knowledge of methods to raise safety concerns within WSU NSC; (2) willingness to raise safety concerns to their management without fear of retaliation; (3) managers ensure reactor priorities are aligned to reflect nuclear safety as the overriding priority; and (4)
procedural use and adherence. To make this assessment of the environment, the inspectors conducted interviews with WSU NSC staff members having responsibilities related to reactor operation, observed activities of reactor operations, and reviewed procedures. The inspectors accessed the SC by interviewing 16 of 17 employees with responsibilities regarding reactor operations and the radiation safety officer.
The inspectors found that all the WSU NSC staff members interviewed felt free to raise safety concerns to management. The WSU NSC staff reported that a new web-based program was recently implemented and made it easier to report concerns directly to reactor management. In addition, the new program allowed for anonymous reporting of concerns. All WSU NSC staff stated that they had stop work authority and that management would support them if they felt uncomfortable proceeding with scheduled work activities due to safety concerns. With respect to procedural use and adherence, the WSU NSC staff stated that they felt that procedures were able to be followed and stated that it was the expectation that they follow the procedures. In addition, the WSU NSC staff stated that procedures were expected to be in the hand of the WSU NSC staff during operation or at least nearby for reference. When questioned about making mistakes, the WSU NSC staff stated that mistakes were seen as learning opportunities and punitive actions were not normally taken by management. In addition, when questioned about whether they were asked to act differently if the NRC was onsite, all WSU NSC staff stated no, and they were even specifically told that no preparation was required for the NRCs visit.
Although WSU did not have a formal SCWE or SC policy that provides staff with the expectations for an environment where employees are free to raise safety concerns without fear of retaliation, the WSU NSC staff were able to communicate appropriate expectations concerning SCWE.
The inspectors noted that turnover of WSU NSC staff was seen as a challenge for the facility but that recent hiring of new employees and multiple students training as ROs were positive steps to alleviate staffing challenges.
c. Conclusion The inspectors determined that there were no identifiable issues of concern regarding facility SC or a SCWE.
12. Exit Interview The inspectors reviewed the inspection results with members of licensee management at the conclusion of the inspection on March 29 and 30, 2023. The licensee acknowledged the results and conclusions presented by the inspectors.
PARTIAL LIST OF PERSONS CONTACTED Licensee D. Adams Student Reactor Operator Z. Beadle Reactor Operations Engineer H. Bennett Reactor Supervisor and Senior Reactor Operator Z. Cardenas Student Reactor Operator A. DeFord Student RO Trainee C. Filip Reactor Operations Engineer C. Fitzpatrick Student Reactor Operator Facility Director and Senior Reactor Operator I. Kleditz Student RO Trainee D. Lionetti Student RO Trainee I. McDonald Student RO Trainee R. McGehee University Radiation Safety Officer R. Nielsen Student RO Trainee INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 93100 Safety-Conscious Work Environment Issue of Concern Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000027/2023201-01 IFI Review the licensees actions to revise SOP No. 4 concerning the length of time tuna cans can be irradiated.
Closed None Discussed None Attachment