IR 05000059/1990001

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Insp Rept 50-059/90-01 on 900305-08.Licensee-identified Violation Involving Audits Noted.Major Areas Noted:Reactor Operations,Emergency Preparedness,Radiological Protection, Matl Accountability & Physical Security Plan
ML20034B780
Person / Time
Site: Texas A&M University
Issue date: 04/20/1990
From: Baer R, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20034B779 List:
References
50-059-90-01, NUDOCS 9005010002
Download: ML20034B780 (9)


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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION-

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REGION IV

NRC Inspection Report:

50-059/90-01 Operating License: R-23 i

Docket:

50-059

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Licensee: Texas A&M University (TAMV)

i Nuclear Engineering Department Mail Stop 3133 College Station, Texas 77843 Facility Name:

AGN-201M Reactar (5 Watt)

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Inspection At:

Zachry Engineering Center, TAMU, College Station, Texas Inspection Conducted: March 5-8, 1990 Inspector:

Tn 0$/]}A effn $O D hTTa r, adiatidn~5pecia st, Facilities (Tat'e / ~ , g Radiological Protection So tion [h8J168/-, M/ '/[94) Approved: <0 B aine Murray, Ctfief, F ities Radiological Date / Protection Section , Inspection Summary , Inspect 1on Conducted March 5-8,1990 (Report 50-059/90-01) Areas Inspected: Routina, unannounced inspection of the licensee's reactor operations, emergency preparedness, radiological protection, material accountability, and the physical security plan.

I l Results: The licensee's program for reactor operations, emergency I preparedness, radiological protection, 'a.terial accountability, and physical security for the AGN-201M reactor facility appears to be effectively l implemented, maintained, and documented.

! Within the.reas inspected, there was one licensee-identified violation l involving audits (see paragraph 7). No deviations were identified.

The i inspector identified three open items for followup (see paragraph 14). Two previously identified inspection findings were closed (see paragraph 2).

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DETAILS , 1.

Persons Contacted J. W. Poston, Head, Nuclear Engineering Department

  • F. D. Jennings, Director, Office of University Research, and Chairman,

Reactor Safety Board (RSB)

  • R. O. Berry, Senior Reactor Operator
  • M. E. McLain, Director, Radiation Safety Office, TAMU
  • C Meyer, Health Physicist, TAMU L. E. Pocaterra, Reactor Operator
  • P. S. Sandel, Health Physicist, TAMU
  • G. A. Schlapper, Associate Professor, Reactor Supervisor

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  • J. E. Simek, Assistant Director, Radiation Safety Office, TAMU R. Wiatt, Director, University Police, TAMU
  • Denote those individuals present at the exit interview on March 8, 1990.

2.

Followup on Previous 1v Identified Inspe_r.tlon Findings (Closed) Open Item 059/8701-01: Control of Maintenance and Test , Equipment - This item was previous,1y discussed in NRC Int.pection ' Report 50-059/87-01 and involves the control of maintenance and test equipment used when performing maintenance and surveillance activities on reactor components. The licensee had established a proper quality assurance program for maintenance and test equipment.

(Closed) Open Item 059/8701-02: Documentation of Maintenance and Test Equipment in Maintenance and Surveillance Documents - This item was l previously discussed in NRC Inspection Report 50-059/87-01 and involved lack of identification of specific equipment used for maintenance and surveillance activities and whether the equipment had been properly calibrated. The licensee documents in the maintenance log the specific equipment used during maintenance and surveillance activities and the ' calibration date, if required.

3.

Open Items identified During This Inspection

An open item is a matter that requires further review and evaluation by the inspector. Open items are used to document, track, and ensure adequate followup on matters of concern to the inspector. The following open items were identified: Number Title Paragraph 059/9001-01 Radiation Surveys During Reactor ' Operations

059/9001-02 Radiation Survey Lucet' a

l 059/9001-03 Personnel Monitoring Devices

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4.

Observations The following are observations the inspector discussed with the licensee during the exit interview on March 8,1990. These observations are not violations, deviations, unresolved items, or open items.

These observations were identified for licensee consideretion for program involvement, but the observations have no specific regulatory requirement.

  • The RSB audits of Technical Specification (TS) requirements do not always clearly indicate which requirements were reviewed.

(see paragraph 7)

The daily radiation survey for reactor operation would be more informative if performed at the highest planned power level for the day.

(see paragraph 14) 5.

Organization and Management control The licensee's organization and management control was inspected to determine compliance with TS 6.1.

The current organization and assignment of responsibilities was verified to be consistent with TS requirements. The senior reacter operator performs the duties of the reactor supervisur in his absence.

The inspector reviewed the status of licensed operators, membership and meetings of the RSB, and other matters concerning supervision of the AGN-201M reactor facility.

The inspector noted that the RSB has responsibility for both the AGN-201M (Docket No. 50-059) and the TRIGA (Docket No. 50-ing reactor f acilities.

As a result, the RSB meets significantly more tien than the required once each calendar year requirement of TS 6.4.1.

No violations or deviations were identified.

6.

Operation and Maintenacce Loos The inspector reviewed the reactor operation log, reactor maintenance log,- and surveillance records for the period January 1987 through February 1990 to determine compliance with the requirements of TS 2.0, 3.0, 4.0, and 6.10.

The inspector reviewed the licensee's activities regarding maintenance, modifications, upgrades, startup checklist, experiment records, reactor power levels, and personnel exposure and dosimetry logs. Maintenance records were also reviewed for 10 CFR 50.59 evaluations and RSB reviews of reactor modifications, upgrades, and component replacement.

The licensee maintains detailed records for all maintenance and operation activities. The inspector noted that occasionally the reactor operations log did not contain detailed sample irradiation data including the sampic .

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chemical composition and estimated reactivity.

However, the licensee was able to locate the missing data and included it as part of the operations log.

All maintenance and operation activities appeared to have been conducted in a manner consistent with TS requirements.

No violations or deviations were identified.

7.

Audits and Reviews The inspector reviewed the minutes of meetings conducted by the RSB to determine compliance with the requirements of TS 6.1 and 6.4.

TS 6.4.3 requires that audits of facility activities shall be performed at least quarterly under the cognizance of the RSB.

The inspector determined from the review of RSB meeting minutes and audit reports for the period January 1986 through February 1990 that the RSB satisfied the requirements for facility operation and program audits identified in TS 6.4.2 and 6.4.3, except as noted in the following paragraph: The licensee had determined in October 1989 that the quarterly audits for the third quarter of 1988 and the second quarter of 1989 were not performed. The licensee implemented the following corrective actions in October 1989:

The reactor supervisor will inform the RSB within the first 10 working days of the quarter that an audit was necessary.

  • The RSB will assign an auditor by end of the first month of the quarter to perform the audit.
  • This audit should be scheduled and performed during the second month of the quarter.
  • The reactor supervisor will follow up with the RSB if audit has not been scheduled by the tenth working day of the second month.

The licensee's corrective ac'.4c's were reviewed by the inspector on March 7,1990, and determine:. a be t.dequate to correct the self-identified violation and prevent recurrence. This matter would normally be considered a violation of TS 6.4.3 requirements. However, the NRC Enforcement Policy, 10 CFR Part 2, Appendix C (1989), states that a Notice of Violation will generally not be issued for violations identified by the licensee, if: (1) it was identified by the licensee; (2) it fits in Severity level IV or V; (3) it was reported, if required; (4) it was or will be corrected; and (5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective actions for a previous violation. This violation meets the criteria specified in 10 CFR I , i

.__ __ _- _ - _.. .. . - _ - - - - - - - - -. _ _ _ . . . - ., -5-Part 2, Appendix C (1989), and is considered a licensee-identified violation and no Notice of Violation will be issued concerning this matter, , The inspector observed that in reviewing the documentation of audits performed to satisfy TS 6.4.3.a. it was not always clear that the entire TS and applicable license conditions were reviewed annually. The licensee routinely performs this audit in two separate reviews. This was discussed with the licensee during the inspection and at the exit interview. The licensee acknowledged the inspector's observation and indicated that this area would be reviewed.

No deviations were identified.

8.

Reactor Operations The reactor is used primarily for performing experiments associated with the nuclear engineering teaching program and academic research. The experiments involve approach to critical, sample irradiation, reactivity measurements, power calibration, and flux distribution.

The reactor is also operated during demonstration courses and the operator requalification program.

On March 7, 1990, the inspector witnessed startup, operation at 0.5 watts and 1.0 watts, and shutdown of the reactor.

During these evolutions, the inspector observed radiological measurements being taken of the gamma, fast neutron, and thermal neutron fields. The results of these measurements are discussed in paragraph 14 of this report.

No violations or deviations were identified.

9.

Operator Requalifict. tion Training The licensee's reactor operator requalification training program was reviewed to determine compliance with'TS 6.3 and the operator requalification program, dated May 20, 1988.

The operator requalification program is designed to meet the conditions as set forth in 10 CFR Part 50.54(1) and 10 CFR Part 55, Appendix A.

The inspector reviewed the individual licensed operator files and concluded that the operator requalification program was being implemented properly. The inspector noted that the current requalification training and examination were scheduled to be performed during March 1990.

No violations or deviations were identified.

10.

Procedures The inspector reviewed the licensee's written procedures to determine compliance with the requirements of TS 6.6.

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The procedures associated with the reactor are contained in the reactor . operating procedures manual. The inspector noted that the last major i revision of procedures was made in 1986 and determined that they complied with the requirements of TS 6.6.

' No violations or deviations were identified.

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Surveillance Requirements The inspector reviewed the surveillance activities for safety channel calibrations; reactivity, control, and safety system responses; radiation monitor system; reactor fuel; and radioactive sealed sources to determine cornpliance with TS 3.4 and 4.0.

The inspector verified that limits regarding excess reactivity, control I and safety rods worth, scram capabilities, and safety systems were not exceeded. The review of the surveillance test record results did not . ' indicate any unusual conditions.

No violations or deviations were identified.

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Experiments The inspector reviewed the licensee's experiment records and reactor [ operation logs to determine compliance with the requirements of TS 3.3, 6.6, and 6.7.

The inspector determined that the licensee had not introduced any new experiments in the reactor since the previous inspection.

Experiments which had been conducted were used with approved procedures under approved reactor conditions.

No violations or deviations were identified.

13.

Fuel Handling Activities The inspector reviewed the licensee's fuel handling activities to determine compliance with the requirements of TS 5.2 and 6.10.2.c.

The inspector verified that the licensee maintained approved procedures for fuel handling activities and reviewed them for their technical adequacy in the areas of radiation protection and criticality safety. The inspector determined by record review and discussions with personnel that fuel handling operations and startup tests were performed in accordance - with the licensee's approved procedures.

No violations or deviations were identified.

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  • o-7-14. Radiation protection The inspector reviewed the licensee's radiation protection program to determine compliance with the requirements of 10 CFR Parts 19 and 20; and TS 3.4, 4.4, 5.3.d. 6.1.8, 6.10.e, and 6.10.2.d.

The inspector reviewed selected records and logs, interviewed personnel, made observations, and performed independent radiological surveys.of the facility.

' The bases for TS 3.4 state that the total gamma, thermal neutron, and f ast neutron radiation dose rate in the reactor room, at the closest approach to the reactor, is less than 100 mrem /hr at reactor power levels less than 1.0 watt. This condition was discussed with the NRC's Office of Nuclear Reactor Regulation and the inspector determined that the bases for the TS were not a regulatory commitment.

The inspector rl h radiation surveys that had been performed annually to meet the requirements of TS 4.4.c. 'The inspector noted that at one area, between the AGN-210M reactor and the graphite pile, the radiation levels exceeded 100 mrem /hr.

The latest annual survey conducted on May 11, 1989, by the radiation safety officer indicated a radiation level of 219 mrem /hr. This was composed of 200 mrem /hr fast neutrons, 7 mrem /hr thermal neutrons, and 12 mrem /hr gamma radiation. The licensee stated that they would evaluate the neutron spectrum and gamma levels around the reactor tank and actions necessary to reduce the level. The matter of radiation levels being greater than 100 mrem /hr was discussed with the licensee during the exit meeting on March 8, 1990, and will be considered open iter pending further NRC review of the licensee's evaluation of the existing radiation levels (059/9001-01).

The inspector discussed with licensee representatives observed differences in radiation levels. As discussed in the above paragraph, surveys conducted on May 11, 1989, indicated radiation levels at 219 mrem /hr.

A radiation survey performed on March 7, 1990, indicated a radiation level of 130 in the same general area at 1.0 watt and 99 mrem /hr with a reactor power level of 0.5 watt. The licensee does not make measurements in the

exact same location every time.

The licensee acknowledged the inspector's ' observation regarding differences in documented radiation levels. The licensee stated that specific locations would be designated so that future radiation surveys could be compared in order to track changing conditions.

This is considered an open item pending further NRC review of the reactor survey program (059/9001-02).

The inspector also discussed the radiation survey performed by the reactor operator prior to starting the reactor for the day. The inspector observed that a more meaningful radiation survey would be one that was made after reactor startup and operation at the highest planned power level for the day. Again, this survey should be made at designated locations around the reactor facility so that radiological conditions could be trended.

The licensec acknowledged that a radiation survey after reactor startup would provide more meaningful data.

+ '..,., .g.- l The inspector also discussed with licensee representatives that all licensed reactor operators were not being monitored for beta, gamma, and

neutron radiation exposure.

Some operators were issued personnel monitoring devices for beta, gamma radiation only. The licensee was relying on the area monitoring badges placed around the reactor room to i measure the neutron levels within the reactor room. The inspector did not , i identify any violations of 10 CFR 20.202 requirements; however, the licensee stated that licensed reactor operators would be furnished with radiation monitoring devices that will detect and measure beta, gamma, and

neutron radiations. This is considered an open item (059/9001-03) pending further NRC review of the licensee's personnel monitoring program.

I The inspector reviewed calibration and inventory records for portable radiation monitoring instruments, calibration and daily response tests for the area radiation monitor, and the radiation exposure history records for licensed reactor operators.

The licensee's documentation for these areas indicated the program was meeting regulatory requirements.

, , No violations or deviations were identified.

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Environmental Surveillance / Radioactive Releases , The licensee does not maintain a detailed environmental surveillance program; e.g., collection and analysis of water, soil, or vegetation samples.

There is no specific license requirement that such a program be maintained.

A licensee representative stated that no liquid effluents have been made or discharged since the last inspection, The licensee's operation records indicate that gaseous releases are within 10 CFR Part 20 limits.

No violations or deviations were identified.

' 16. Transportation (Fuel Shipments) The inspector verified that there had been no fuel shipments since the previous operational inspection.

No violations or deviations were identified.

' 17. Nuclear Materials Safeguards The inspector reviewed the nuclear material inventory program to determine compliance with License Condition 2.B.(2).

. The inspector reviewed the accountability procedures, practices, and material status records. The procedures, practices, and records were found to be well implemented.

Responsibilities and response requirements

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The licensee had not received or shipped any materials since the previous - inspection.

, No violations or deviations were identified.

18.

Emergency Plannino . The inspector reviewed the emergency preparedness program to determine l compliance with the emergency plan, dated September 24, 1984.

The emergency plan procedures were updated in March 1989 to include , changes in telephone numbers and emergency response.

The licensee had conducted training of fire and police personnel.

The inspector reviewed the letters of agreement with the city of College Station for. ambulance and fire department services and St.- Joseph Hospital and Humana Hospital for medical services.

The licensee had conducted the annual emergency drill on December 15,

1989. The inspector reviewed the results and associated evaluation ~ performed by the RSB.- ! No violations or deviations were identified.

r f 19, physical Security The inspector reviewed the implementation of the licensee's physical ', security plan, dated February 18, 1988, and determined it to be in compliance with 10 CFR Part 73.

! No violations or deviations were identified.

20.

Exit Interview i The inspector met with the licensee's representatives identified in paragraph 1 of this report at the conclusion of the inspection on March 8,

1990.

The inspector summarized the inspection findings as presented in this report, The licensee did not identify as proprietary any of the niaterials provided to, or reviewed by, the inspector during the inspection.

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