IR 05000072/1990001
| ML20062G052 | |
| Person / Time | |
|---|---|
| Site: | 05000072, University of Utah |
| Issue date: | 11/02/1990 |
| From: | Beach A, Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20062G045 | List: |
| References | |
| 50-072-90-01, 50-407-90-01, 50-407-90-1, 50-72-90-1, NUDOCS 9011280371 | |
| Download: ML20062G052 (21) | |
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION'
REGION IV
NRC Inspection Report: 50-072/90-01 0perating Licen'ses:. R-25 50-407/90-01 -R-126:
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Dockets: 50-072 50-407 Licensee: University of Utah (VofU).
Salt' Lake City, Utah 84112 Facility Name: Nucler.r-Engineering Laboratory.(NEL)-
Inspection At: University of Utah, Merrill Engineering Building, Salt Lake City, Salt Lake County, Utah o Inspection Conducted: September 24-28, 1990 d
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Inspectors: JA .[ot[-[d J./B. Nicholas,.SenNor. Radiation. Specialist- Date Radiological Protection and Emergency Preparedness Section L
$h YA W M/M. Mendonca, Senibr Project Manager N 3~ 9e
.Date Non-Power Reactor Decommissioni_ng-and:
Environmental-Project Directorate Office of Nuclear Reactor Regulation.(NRR)-
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> > ( A1,1 AJAAtW 4urray, Chidi,'Radiolo@ical Protection and UN90 0(te /
l Emergency Preparedness ~Section t Approved: I 6 /9D A.~ B.- Beach,- Director, . Divi sion- of Radiation Date'
Safety and Safeguards Inspection Summary Inspection Conducted September 24-28, 1990 (Report 50-072/90-01'and 50-407/90-01)
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Areas Inspected: Routine, announced inspection;of the licensee's organization and management controls, training'and qualifications, reactor operations, ,
procedures, experiments, surveillances, radiological controls,; emergency
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preparedness, physical security and safeguards,-and notifications and report Results: Within the areas inspected, one apparent violation, (failure to 1 quantify the amount of byproduct material to be transferred to another license paragraph 14) was identified. One unresolved item was identified (see paragraph 10), and 4 open items were identified. No deviations were-identifie .
The VofU TRIGA reactor facility appeared to be well managed and adequately staffed to handle the present experiment irradiation workload The NEL had demonstrated good improvements in reactor operation and ' maintenance -since the previous NRC inspection in February 1988. The cleanliness and order of the reactor facility was greatly improved.- Reactor operators were qualified and .
training requirements had been met, Reactor operations were being performed in accordance with Technical. Specification-(TS). requirements. Audits were performed by the reactor safety committee-(RSC) and included the information required by TS. Surveillance and reporting requirements had been me .
The radiation protection program at the NEL was-considered' adequate; however, several items for program improvement'were identified-for the , licensee's,_
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evaluation. Confirmatory measurements performed by the inspectors did not identify any significant contamination or radiation level Personnel radiation exposures were generally minimal and were not in excess of-100 millirems per year. Radioactive effluent releases were minimal and were
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well within TS limits, i The licensee was implementing the physical security program and emergency -
response activities concerning emergency training and drills in'accordance,with the licensee's approved physical security' plan (PSP) and emergency plan (EP).
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DETAILS ( persons Contacted !
i Licensee
- J. J. Brophy, Vice President of Research, VofU~
- J. S. Bennion, Senior Reactor Operator'(SRO)-
- K._C. Crawford, Reactor Supervisor ,
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T. C. Gansauge, SR * K. Gehmlich, Reactor Administrator G. C. Gilbert, Lieutenant', Campus. Security' .
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- B. L. Hardy, Health Physicist,-Radiological-Health Department (RHD)" {
L. D. Larsen, Associate Administrator, General Services --
S._C. Palacios, Sergeant, Campus' Security J. W. Richins, Acting Supervisor,: Building Maintenance Key; Shop' ,
- G. M. Sandquist, Director, NEL-
- K. J. Schiager, Radiation' Safety Officer _(RS0),, RHD:
W. D. Shepherd, Chief, University Police- ,
J. Unsuh, Dispatcher, University Police '
- Denotes those present at the exit meeting on September 27, 1990.
L Licensee s Actions on Previously Identified Inspection ~ Findings
1 I (Closed).0penItem(407/8801-013): Current Reactor Modification Training - This item was previously discussed in NRC~ Inspection Report 50-407/88-01 and involved the NRC; concern regarding-training'of'
current reactor operators on the modifications to.the TRIGA reactor involving computerization of rod control functions'and: reactor pa_rameter displays. The inspectors examined the-licensees' actions-' committed to in their August 4, 1988, response-to'the:open item.. The inspectors'. reviewed- ,
the current ~TRIGA reactor operator's' requalification ~ training program and requalification examination given in 1989:and verified that TRIGA reactor )
modifications were included in thi biennial operator requalification training program. The licensee _'s completed 'requalification training of
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-the current TRIGA reactor operators appeared to be adequate to resolve.the NRC's. concerns in this are ' '
(Clused) Open Item (407/8801-016): Timeliness of Response to Reactor
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Safety Committee Audit Findings - Thist item .was previously discussed. i NRC Inspection Report 50-407/88-01 and involved.the apparent-excessive time taken to resolve RSC audit findings. .The inspectors examined the licensee's implementation of the steps committed to-in.their August-4,. ,
1988, response to the open ite The RSC had developed an' audit-findin t tracking system and all-audit findings'have been included as part of-the quarterly RSC meeting agenda. The audit findings are discussed at each-RSC meeting and remain on the tracking list until resolved and closed :'
during.a RSC meeting. The licensee's RSC-audit finding monitoring:and
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l tracking system appeared to be adequate to resolve the NRC's concerns-in this are (Closed) Open Item (407/8801-020): . Leaking Fuel Element Identification - 1 This. item was previously discussed in NRC Inspect _1on Report.50-407/88-01 i and involved the. licensee's investigation and testing of fuel elements for_
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i leaks. The inspectors reviewed the licensee's investigation and testing [
of TRIGA fuel elements for leaks. 'TRIGA operations logs indicated that i the licensee identified the fuel elements-which were indicating.possible- q 1eakage. The licensee'had' replaced'these fuel elements in the.TRIGA-reactor cor Since operation has resumed with-the TRIGA reactor,=the l licensee has monitored reactor water for further indication of fuel'
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leakage and no indication of. fuel leakage has been detected. The:
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licensee's replacement of-defective. fuel in the TRIGA core and the :
negative-analysis results from monitoring the_ reactor water following thei !
replacement of the leaking fuel elements was adequate to resolve the NRC's concerns in this are (Closed) Open Item (407/8801-025): Hiring of a Reactor Supervisor -'This item was'previously discussed in NRC Inspection Report _50-407/88-01'and ,
involved the licensee hiring an additional full-time faculty member at'the '
NEL to serve as reactor-supervisor. The' licensee hired an additional 4 full-time faculty member qualified as a SR0 on the VofU:TRIGA reactor t '
oversee the reactor facility operation and assume the duties and ;
responsibilities of the reactor supervisor. The ne~. w reactor supervisor
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assumed his duties at the-NEL on 0ctober 1, 1988. The licensee's hiring !
of a full-time facu.cy member to serve as the reactor supervisor resolved'
the NRC's concerns in this are .J (Closed) Violation (407/8601-03): Failure to Fully Implement.the Operato Requalification Program - This violation was previously discussed in NRC j
Inspection Reports 50-407/86-01 and 50-407/87-01 and--involved the licensee's failure to fully implement the NRC-approved TRIGA reacto operator requalification program. The inspectors reviewed-the TRIGA operator requalification records for:the four current TRIGA' reactor operator It was verified that all the requirements;of the NRC-approved requalification program were being documented satisfactorily including the q completion of an annual requalification examination, issuance of an annual- '
evaluation, and the completion of a biennial operator training program
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i record which. documented the completion of all.the_ operator training program requirements for each individua1LTRIGA reactor. operator. The d licensee's corrective actions appeared to be~ adequate to resolve.the NRC's 1 concerns in this are (Closed) Violation (407/8801-007): Decreasing the Effectiveness.of the Physical. Security Plan Without NRC Approval - This violation was ,
previously discussed in NRC Inspection- Report 50-407/88-01 and involved
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the liensee's implementation of Revision 2 to the NEL PSP without prior NRC approval per 10 CFR Part 50.54(p)(1). The licensee submitted Revision 2 to the NEL PSP, dated January'10, 1989,_to the NRC for approval. The inspectors reviewed the NRC's response to the' licensee's ;
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j submittal of the-PSP and determined thatiths licensee's PSP was: approved !
by the NRC in a letter dated July 10, 1989.. The licensee's corrective -
actions were satisfactory .to resolve' the NRC's: concerns in this are . Open Items Identified During This-Inspection-An open item is a matter that requires further review and. evaluation.by the inspectors. Open; items are used to document,: track,' and ensure _ .
adequate followup.on-matters of concern to.the inspectors. -The following open items were identified: ;
d Open Item Title . Paragrap ,
407/9001-01 Training Issue ;
j 407/9001-03 Argon-41 Ventilation Monitor- L 11 -
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407/9001-05 Emergency Plan Training . 17 4. Unresolved Item j An unresolved item is a matter about1which more information;is required to ascertain whether it is.an acceptable item, a deviation, or. a violation.
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1-The following unresolved item was identified:
Unresolved Item- Titl Paragraph l 407/9001-02 Thermal Power Calibration Calculation 10 ,
l S. Organization and Management Controls
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The inspectors reviewed the licensee's organization:and. staffing,to determine compliance with. Sections 6.1, 6.2,.6.5.1, 6.5.2, and-6.5.3 of
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the TRIGA TS and agreement with the commitments in the TRIGA Safety Evaluation Report (SER), NUREG-109 The inspectors verified that' the organizational -structure of the NEL for the TRIGA reactor operations was as defined in the SER:and:TS. The NEL staff assignments of responsibilities'were described in the NEL Operations Manual. All' organizational positions were filled with qualified !
, personne There had been one NEL: staff change in October-1988 si_nce the previous NRC inspection of the UofU NEL facility. The., licensee had hired an additional full-time faculty member to fill the position of; reactor supervisor and oversee the daily operations of the reactor facility. Th inspectors determined that-the NEL-director devoted approximately-25 percent of his time to TRIGA reactor' activities'and the' reactor supervisor devoted about 75 percent of his time:to directly overseeing TRIGA reactor. activities. The reactor' supervisor was supported b~y two SR0 graduate students:in conducting-the TRIGA. reactor program. The inspectors-
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,i verified that the supervisory control and reactor. program implementing 'i responsibili_ ties specified in the SER and-TS were being implemente ;
The RSC's charter and membership were reviewed. .-The'RSC membership was in accordance with the charter and TS requirements. The inspectors. reviewed selected RSC meeting-minutes and determined that the RSC. meetings Wre-being conducted at least quarterly during= the period October _1988' tirough September 1990 in accordance with the charter-and-TS requirements'. >
Additionally, the inspectors observed the conduct of.a quarterly RST 4 meeting on September 26, 1990,.-and noted-that.the meeting = met-theiT3- L requirements and dealt with reactor safety issues in a comprehensive l '
F manner. The RSC meeting agendas,. minutes, and conduct indicated thatLthet RSC was performing the required review .i No violations or deviations were identifie . ,1ualification and Training The inspectors reviewed the licensee's training program for NEL personnel and experimenters working in the NEL to determine. compliance ~with the requirements of TRIGA TS 6,3, 6.4, and'6.5.2; 10 CFR' Parts 19.12-and 55;. ;
and agreement with the Industry. Standard ANSI /ANS 15.'4-1988 and Regulatory i Guides 8.13, 8,27, and 8.2 '
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The inspectors reviewed the education and experience-of the'present NE8 staff and RSC members and determined that all' of the NEL staff and'RS'.,
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members mer, the qualifications required in"TS.and ANSI /ANS 15.4-198 The inspec'. ors reviewed the licensee's TRIGA operator requalification-program dated January 31, 1983. It,was noted that the>TRIGA operator requalification program had been approved by the-NRCiand.it conformed to-the requirements of 10 CFR Part 55, Appendix A. The TRIGA. operator l
regi'alification training procedure was reviewed and found to be ;
sr.c.isfactory to implement the operator:requalification: program. .-The l reactor operator requalification examinations for 1988 and 1989'were reviewed and the completed examinations had been included in tha training, records for the SR0s. The requalification. training-records for..the four-TRIGA-SR0s were reviewed and found~to contain all the documentation required by the approved TRIGA operator requalification program During the review of the TRIGA operator-requalification training progrem, the inspectors were concerned with the-formality of conducting and. documenting-the on-the-job training aspects of :the requalificat;on training program to'
assure operator familiarity with the annual matotenance, shutdown program,. =
control rod. worth measurements, fuel inspeM.1on, and fuel temperature y measurement system calibration. . Therefo.e the_ inspectors discussed these '
areas with the licensed operators. .The operators who were interviewed; 1 demonstrated' acceptable . familiarity with the -four items listed above; l although~, one SRO had to refer.to the~ appropriate procedure to assure an I accurate description of the fuel temperature measurement-system l: calibration. These discussions indicated that the. formality and-content H of.the~TRIGA operator requalification training program had been
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significantly improved since the-previous NRC inspection, However, the inspectors could-not readily determine.from review of the individual'
operator training program records as to how and when the on-the-job l ..
training of the four above listed items _wasLeonducted and completed. This-item was= discussed with the reactor supervisor. The licenseefagreed to" evaluate the inspectors' concerns and revise the biennial operator ,
training program record as' necessary to-thoroughly document- the' completion of the on the-job 4 requirements' listed injthe TRIGA operator'
requalification training progra ~
The inspectors reviewed the NEL' orientation training given.to ;
nonoperators, experimenters, andLstudents who work in the NEL. 'It was-
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noted-that the licensee did not have.a procedure which addressed the.NEL1 access _ requirements for. personnel working -in the NEL.- The'. orientation training material and examination were reviewed. .The results of th examinations taken by:four people-in-1989 and:nine people ~in_1990~were
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reviewed. Occasional workers in. the- NEL- were~-only receiving the ' ,
abbreviated orientation training conducted by the NEL' staff. Students:wh '
worked routinely in the NEL.as experimenters had -received radiation protection training offered each academic quarter by1 the VofU RHD. The training conducted by-the VofU RHD appeared to meet the requirements of ,
10 CFR Part 19.12 and included the material in-Regulatory Guides 8.13 and 8.29. However, the abbreviated orientation training conducted =by the _
NEL staff to occasional workers in .the-NEL-did :not include the material t presented in the two above listed Regulatory Guides. This' concern was: ,
discussed with the reactor supervisor; The. licensee agreed-to' review and evaluate the NEL orientation training program relative.to: including:th information contained _ in Regulatory: Guides 8.13' and 8.29. These training issues are considered an open. item pending-review of the licensee's evaluations (407/9001-01).
No violations or deviations were identifie . License Conditions and Special Nuclear Material'(SNM) Control and- '
Accountability L
The licensee's SNM control and accountability program was. reviewed t'o determine-compliance with 10 CFR Part 70 and TRIGA Operating License R-12 The inspectors reviewed SNM storage and. inventory for agreement _with TRIGA Operating. License R-126, Amendment'5,. dated April 17, 1985. License Condition 2.B(2) authorizes the possession;of a 5 curie sealed
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plutonium-beryllium neutron startup source and.up to 4.9_ kilograms of ,
uranium-235. The 1%;:ectors determined-that the licensee possessed !
105 grams of Pu-239 which is . equivalent to approximately 6.43 curie This amount of Pu-239-is divided between a 5 curie sealed plutonium-beryllium neutron ~ startup source stored in the TRIGA reactor .
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I tank and a Pu-239 foil of approximately 1.5 curies stored in. the NEL j Room'1205-B. The Pu-239 sources are licensed under the VofU's license -l fmm the State of Utah. The inspectors performed an inventory of the 'l i
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TRIGA fuel the licensee had on site. TheLinspectorsdeterminEdthatthe
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licensee had 5 spent TRIGA' fuel elements in the spent' fuel storage wells, ,
53 fuel elements in-the fuel storage ranks at the bottom and'on the inside-perimeter of the ret.ctor t'ank, and 77. fuel elements in the TRIGA cor i These values agreed with the licensae's inventory of 135 TRIGA-fuel-
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elements. Based on approximately-34 grams of U-235 per_ fuel-element,- the licensee's TRIGA fuel contains approximately 4.59 kilograms of U-235 which
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is less than the 4.9 kilograms of U-235 allowed by the TRIGA.0perating ,
License R-12 ,
No violations or deviations.were identifie . Reviews and Audits The inspectors reviewed the' licensee's reviev and audit programs conducted J'
by the RSC to determine agreement with commitments.in paragraph 13.4 of '
the TRIGA SER and compliance with the requirements in. Sections 6. and 6.5.5 of the TRIGA-T The inspectors determined that the RSC a Nits of operations and maintenance activities and radiation safety:were being performed semiannually as required by the TRIGA:TS. Audit reports' generated during the period January 1988 through. July 1990 were reviewed forLscope.to'
-ensure thoroughness of program-evaluation. The-RSC auditsLincluded-reviews of the TRIGA maintenance and operations logs, NEL procedurestfor reactor operations and maintenance, instrument calibration procedures,-
TRIGA operating records for TS compliance, unusual or abnormal events, and radiation safety. The inspectors determined that=the RSC audits were meeting the TRIGA TS audit requirements. Minutes ofsthe RSC meetings for the period January 1989 through July 1990.were reviewed. The RSC meeting- ;
, minutes indicated that the required RSC reviews listed.:in the TRIGA '>
L TS 6.5.4 were being completed. During the RSC.me'eting heldton'
September 26, 1990, and attended by the inspectors, it was.noted that the q RSC discussed the : development of:a review and= audit checklist to ensure that all required'RSC. reviews and audits wi11 be performed at-the required L frequencies. TheLlicensee had developed a calendar to'schedul_e'and track 3'
I all-the required training, administration, and' operations required activities. including reviews, audits, reports, and instrument-calibrations. The inspectors reviewed the-1990 calendar and determined-that the NEL and- RSC required activities were scheduled.in accordance~ with TRIGA TS requirements. The'RSC had developed an audit-finding tracking ;
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system which required all audit findings to be listed'on the.RSC meeting agenda'. The audit-findings were discussed at;each RSC meeting and-remained on the RSC tracking list until resolved and closed during.a RSC meeting and so documented ~in theiRSC meeting minute No violations or deviations were identifie .i C f i
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.g. . Logs-and Records Theinspectorsreviewedthelicensee'sprogramfordocumentationofth TRIGA reactor operations and maintenance. activities to-determine-compliance with Sections 4.35, 6.5.6, and 6.9 of the TRIGA T The inspectors reviewed the documentation of reactor-operations and maintenance for the,TRIGA. reactor for the period March'1988 through August 1990. The AGN-201 reactor was not operated during this period,
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The logs _and records documenting TRIGA reactor maintenance, . routine
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operation,-fuel inventory and storage,: fuel' inspection,. experiments, startup checklists, instrument checks and calibrations, radiation surveys, and personnel exposure were reviewed =. The inspectors det' ermined that the TRIGA reactor annual reports and; operations and maintenance history _ logs-adequately documented reactor operations and maintenance activities.-
-The inspectors. reviewed the facility maintenance logs. Major modifications which were reviewed included the addition-of:asfast flux irradiation unit and a nonsafety-related computer' monitoring system for monitoring certain reactor core parameter:. The' licensee hadfperformedL safety evaluations for tnese modifications in accordance with-10 CFR1 Part 50.59 requirements. -Their safety analyses were found acceptable and met the 10 CFR Part 50.59 requirement During discussions with the licensee, the inspectors were informed that the_ licensee had plans to replace the currentsTRIGA reactor control-console. The inspectors emphasized to.the. licensee the requirement to
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perform a thorough safety evaluation per 10 CFR Part 50.59 requirements prior to replacing the current TRIGA control console with' emphasis o assuring that the probability of an accident had been thoroughly considere No violations or deviations were identified,,
10, Procedures The inspectors reviewed the licensee's NEL Operations Manual.and TRIGA reactor operating procedures to determine agreement with commitments in1 paragraph 4.7 of the TRIGA SER and compliance'with'the requirements in Section 6.8 of the TRIGA T The licensee had written and approved' procedures, checklists, and data forms for safety-related and operational activities that' included reactor startup, operation, and shutdown; maintenance; and calibration of equipment and' instrumentation.- A review.of: selected procedures and data sheets, revised and approved since the previous NRC inspection in February 1988, indicated that-the licensee had made progress in developing programmatic procedures to meet the requirements of the TRIGA SER and TRIGA TS. The licensee's procedures were reviewed by the RSC and.their reviews were documented in the quarterly RSC meeting minutes, i
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calibration data / calculation sheet, Form NEL-012,_which was approved by-the RSC on May 25,.1988. The: inspectors'. review identified three
. potential discrepancies. The first potential discrepancy-involved:the? -l calculation of the water: volume:in the TRIGA. reactor tank for use in the .;
calorimetric calculation. Specifically, the licensee used for this: ?
calculation a circular cross-sectional area for the tank of 42,895 square-centimeters; however, for a nominal reactor _ tank diameter of 8 feet minus _ '
L piping and equipment volume, that reduces the cross-sectional area; the l inspectors calculated a cross-sectional-area-for the. reactor tank of about 4 46,500 square centimeters. This difference in reactor tank .
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cross-sectional-area could result-in<a nonconservative-calculational. error-in thermal power of greater than 8 percent. The second' potential discrepancy involved the_use of-a constant' specific. heat value in the; y thermal power calculation rather than ai temperature dependent' specific _ '
heat-value. The licensee used a specific ^ heat lvalueHthat corresponded:to _
a temperature of about'17'C. -The-inspectors notedLthat-the.TRIGA'reactorj water temperatures ranged between 10*C and 23 C during three-recent<
thermal power calibrations. The.use of acconstant specific heat.value-corresponding to a reactor water temperature of: about 179C was astimated to result in a possible error. of approximatelyO.2 percent' in thermal power when compared to the thermal power result. calculated using a-temperature dependent specific' heat value corresponding'to the-10 - 23 C temperature range. The third potential: discrepancy.was th licensee's use of a constant value of 2003 joules'per gram:for the latent heat of vaporization when calculating the thermal- power calibration as; compared to a thermal power calibration calculated'using a temperatu're dependent latent heat of vaporization-value. "The inspectors estimated i that the use.of a constant value-fornthe latent. heat'of vaporization :;
rather than a temperature dependent.value could result in an' error of '
approximately 0.5 percent in the thermal power calibratione 'These potential discrepancies in the TRIGA reactor thermal. power calibration =
calculation were-discussed with the licensee-during the' inspection and a .
the exit meeting.on September. 27, 1990. The licensee stated that th !
thermal power calibration : methodology would be evaluated and action taken to resolve these potential discrepancies. This' item lis considered to be an unresolved item pending further assessment-of-the adequacy of the 1 licensee's TRIGA reactor thermal power. calibration methodology (407/9001-02). !
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In conjunction'with the potential problem with the reactor ths. mal' power calibration calculation, the inspectors noted-that the reactor power. level had generally been limited'during ~ routine operation to a maximum. of about 90 percent to assure-that the licensed power level of 100-kilowatts thermal power had not been exceeded. However, the inspectors also noted ;
an entry in the TRIGA reactor-operations log, dated February 22, 1989, '
that indicated that the reactor = power monitoring instrumentation had been L
noncenservatively calibrated by:approximately 5-- 8' percent. This type of=
nonconservative reactor thermal power' instrument calibration has.the potential for causing the licenseesto exceed their. licensed power level;-
however, the safety concern:of this condition is not significant in that 3
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^-11-i the basis for TRIGA TS 3.1 indicates that TRIGA fuel can be, safely ,
operated up to power . levels of at -least 2.0 megawatts with natural '
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No violations'or. deviations:were identifie , ,
1 Reactor Operations The inspectors observed reactor operations and reviewedilogs and records 1 . '
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to determine compliance with. Sections 2.0,.3.0,'and 5'.0 of the TRIGA1T :AGN-201 The AGN-201 reactornis..being. decommissione The ieactorihas;notJbeen :
operated since February 1985t The licensee had' removed the bricks which7 surrounded the reactor as a radiation-shield and a physica10 security
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' barrier for-the-AGN fuel.' The bricks 'were surveyed for radioactive contamination. No radioactive: contamination.was found on 'the bricks and i they were released by the licensee for unrestricted use>and:were removed ,;
-from the NEL reactor facility. . The licensee'had removed the-AGN fuel from '
the reactor and had stored the fuel in the NEL facilityLspent' fuel ~ storage'.
wells waiting approval for shipment of the AGN! fuel to'the Oak ~ Ridg National Laboratory. The. inspectors verified-the SNM accountability'of l the AGN fuel and its' safe storage and control until it can!be shipped from the UofU reactor facility. . The licensee had submitted a decommissioning- 3'
plan for the AGN-201 reactor to the NRC for review and approva x TRIGA The inspectors inspected the licensee's facilities, operations and maintenance logs and records, RSC meeting minutes,. annual reports, an q experiments; interviewed TRIGA reactor operators; and observed;the '
licensee startup and operate the.'TRIGA reactor at low power levels to verify reactor protection-systems operation. 'The} licensee indicated that the TRIGA reactor was routinely operated approximatelys 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per week:
.for the purpose of laboratory teaching, reactor system tests,3 reactor '
surveillances, and sample irradiations.' The licensee initiated startup of the TRIGA reactor on September -26, 1990, and operated theLreactor'fo approximately 30 minutes at 10.-kilowatts steady-state power to: demonstrate to the inspectors the : operation of the reactor: protective systems, the-computer monitoring capability:of several = reactor parameters, and thec computer capability to maintain steady-state power leve The inspectors reviewed'TRIGA reactor operations logs and' records,to .
determine compliance with the reactor's license conditions and TS 1 requirements. .The licensee had-operated the TRIGA' reactor at thermal,
. power levels not in excess of'100 kilowatts in accordance with License Condition 2.C(1). The reactor safety limits for fuel element temperature-were verified to be in compliance with TS 2.1 and 2.2. The TRIGA T !
limiting conditions for operation were reviewed. The reactor shutdown :n margin was verified to be $0.93 on-August 22, 1990, during the semiannual- ;
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-12- 1 control rod worth determination. This' value was greater than $0.50 and .in ;
compliance with TS 3.2(1). The excess reactivity in:the reactor was'also 't determined-during.the latest semiannual control rod worth determination,to be $1.98 which was less than' 52.80 and in compliance with TS 3.2(4), All ether reactor reactivity limitations were: verified to be in compliance ,
with is 3.2. The reactor scram times'for.'the scramble control rods were t determined to be.in the range of.0.7 - 1.4_ seconds which'were less.than 2 seconds as required by TS 3.3.1. The. inspectors verified that alllthe-required reactor controlisystem instrument channels-required in TS 3. ,
were tested-and operable and included on the TRIGA Preliminary-Check'
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Sheet, Form NEL-001,'which had-been completed-prior to each,startup of-the- )
reactor. The reactor safety: systems listed in TS'3.3.3 were all. verified to be operable and included on the TRIGA Preliminary Check Sheet' The
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annual reports for 1989 and 1990-were reviewed and the. argon-41 discharge l limit of 4~ 0E-08 microcuries/ milliliter (pCi/ml) averaged over.1 year per -
TS 3.4 was not exceeded. Operation records indicated-that the ventilation system had operated as required per TS 3.5. A! review of TRIGA reacto ,
experiment authorization forms determined that TS:3.6 limitations on experiments were checked for each experiment configuration 1 prior to issuing experiment performance authorization. Effluent releases from the reactor facility tad been controlled and were minimal per TS 3.7 as described in the i.nnual reports. ' The' primary coolant chemistry conditions had been maintainad in accordance with TS.3.8.-
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The TRIGA design features for reactor fuel, reactor core, control .
elements, radia'. ion monitoring system, fuel _ storage, reactor building: .
ventilation system,.and reactor pool-water systems per;Section~5.0 of. the -
l TS were inspected and verified. The'TRIGA: reactor fuel'wasiverified to-be of the type and enrichment described in TS 5.1. .The inspectors. reviewed the current TRIGA reactor core configuration map and_ verified:that the fuel elements were positioned in the reactor grid plate in accordance with ,
the core map and in compliance with TS 5;2.- The_.three TRIGA reactor control elements were verified to have the~ required Jscram capability and contained the materials specified for standard TRIGA control elements 11n a compliance with TS 5.3. All fuel elements not positioned i_n'the TRIGA '
reactor core were' stored in the TRIGA reactor. pool in storage _ racks or in the NEL spent fuel storage. pits. The fuel elements were; stored in storage racks at the bottom of the reactor- pool. in an arrangement,where the K,ff _
had been calculated to be 1ess than 0.8 as per TS 5.5. :The. minimum free volume of the reactor room calculated by the licensee was. verified acceptable by the inspectors and satisfied the TS 5.6(1) requirement. The stack from the reactor facility appeared to:be of adequate height to meet .,
the TS 5.6(2) requirement of atileast 40 feet above the ground. , The l inspectors' verified that the reactor'coolingiwater systems were adequate j to meet'the requirements specified in TS.5.7. ~A' pool leve.1~ alarm wa provided to indicate a loss of reactor coolant if the reactor pool. level .'
l should drop more than 2 feet below the~ normal-leve A hole had been drilled-in the circulating water piping approximately 3 feet below.the-
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normal level of the reactor pool'to. prevent inadvertent siphoning-of the reactor pool to a level less than 18 feet of_' water above tt.e. top-of the-reactor core.
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Area radiation monitors were installed-in key locations throughout the- l reactor facility at the' surface;of-the TRIGA reactor pool, on the ceiling l
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directly over the reactor pool', and in the exhaust ventilation duc ,
These area radiation monitors.were, gamma-sensitive detectors which had'
been calibrated and alert _and alarm-setpoints had been. calculated to ,
initiate an alarm at activity' concentrations below maximum l permissible: j concentrations (MPC) and provided activity readout at' the: reactor. control console per TS 5.4(1). These. monitors were: verified to be operational and:' ,
provided the required alarm function at the reactor control.. console'during: '
the completion of the TRIGA Preliminary Check Sheetfpriori t . o the rwetor startup witnessed by the inspectors on:. September 26, 1990. The continuous: .
air radiation monitor was anuend-window Geiger-Mueller tube. detector o positioned in the reactor facility; exhaust-ventilation / duct tto measureLthe. c r concentration of radioactive particulate activity.in the reactor'pooliroomE collected on_a particulate filter assembly installed 1 .in.the reactor facility exhaust ventilation duct. This monitor had'been calibrated and-an alarm setpoint had beenl calculated at 50 percent.of1the'MPC'value for i any airborne radioactive material not containing alpha:emittors. ?The monitor initiated an alarm and provided antactivity readout lt t the-:reactori
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r control con' sole per TS 5.4(2).- TS.S.4(3) requires.an argon-41 stack monitor which is to monitor the-concentration of radioactiveL1ase including argon-41 in the building exhaust and provide an_ alaen and . .
activity readout at the reactor console. The radiation monito.' used=for-this TS requirement was the same end-window. Geiger,-Mueller tube detecto t installed in the facility exhaust ventilation duct andiused'as_the l continuous-air particulate radiation monito The Linspectorst discus' sed :
the use of this type of monitoring system as a stack argon-41 monitor:with-the licensee during the 1nspection. The current monitor appeared to be'
serving a multipurpose function-of' monitoring all airborne activityLin the- o reactor facility ventilation exhaust. including: argon-41'. lNo monitor had .]'
been installed to specifically monitor: argon-41 in the1 ventilation exhaust and the licensee agreed to. evaluate this-installation;for acceptabilit Not having a ventilation exhaust monitor specifically designed.and t calibrated to monitor argon-41 gaseous activityLis' considered an open item pending evaluation by the licensee'of'the, current ventilation gaseous monitoring system for argon-41 (407/9001-03),
t No violations or deviations were identified.
I 12. Technical Specification Surveillance Requirements The inspectors reviewed surveillance result's to determine compliance with Section 4.0 of the TRIGA T The inspectors verified that the-fuel element temperature measuring ,
channel had been calibrated'semiann'ually._per TS'4.2(2) and documented o '
i- Form NEL-011. The calibration'. records were reviewed for 1988,,1989, and 1990. The channel check for the fuel' element temperature measuring channel was made each time the' reactor was operated per TS 4.2(3) and documented on the TRIGA Preliminary Check Sheet, Form NEL-00 ,
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The ' inspectors verified that the. reactor shutdown margin had:been cetermined in conjunction with the semiannual control' rod worth determinations and documented on Form NEL-003. The results of these -
determinations were reviewed to determine compliance with TS 4.3.1(1). l Surveillance records' indicated that the control rods 'were visually '
inspected per TS.4.3.1(2) and documented on Form NEL-00 The inspectors verified that'the scram > times were less than 1 second and
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measured at least annually =in compliance'with:TS 4.3.2(1). LThe: scram:
. times were determined semiannually at the same time the control rod ~ worth
- determinations were performed. Channei checks;of each of' the- reactor safety system channels were performed before each day's) operation per-TS 4.3.2(2) and documented on the'TRIGA, Preliminary Check. Sheet, Form NEL-001. Channel . calibration of,the power. level monitoring channels i was performed semiannually in' compliance with TS 4 3.2(3) and documented
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on Form NEL-01 The inspectors reviewed the results-of the reactor power level instrument calibrations for 1988, 1989, and 1990. The-fuel j
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temperature measur4; channe, was' tested semiannually.during 1988s;1989 I l: and 1990.in compliance with TS 4.3.2(4). "
The inspectors verified that the required radiation monitoring systems _.
, were installed and operational. The~ licensee's records indicated thatithe I radiation monitoring systems were calibrated annually in compliance with TS 4.3.3 and documented on Form NEL-02 The inspectors; reviewed.the
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licensee's method of radiation monitor calibration for area radiatio !
monitors, the exhaust stack particulate monitor, and the exhaust stack argon-41 monito The inspectors noted that the 1.icensee was not using a certified calibration' source traceable to'the National'. Institute of Standards and Technology (NIST) to produce:a specific ' monitor response when placcd at a specific position from-the monitor. Instead the license was placing:a calibrated portable survey instrument next1to the area radiation monitor, placing a noncertified. cesium-137. source at various distances from the two detectors to produce varying dose rates at the detectprs, and comparing the area radiation monitor reading to.the
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calibrated portable survey instrument reading. If necessary; the area ;
radiation monitor's zero and gain adjustments were changed:to produce' '
results within 10 percent'of the calibrated portable. survey instrumen This secondary standard method of calibration of the area- radiation i monitors, which does not directly use.a certified calibration source, was '
discussed with the licensee during-the inspection and at.the exit-meetin on September 26, 1990. The inspectors expressed their conce'rn as to~this- ,
unusual method of monitor calibration and thef fact- that a primary certified calibration source traceable to.NIST was not being used. The
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licensee agreed to evaluate their area radiation monitor calibration !
method. This item is considered an open item pending,further review.by-the inspectors (407/9001-04).
The inspectors reviewed the TRIGA Preliminary Check ' Sheet, NEL-001, for selected reactor startups s';.g 1989 and 1990 and verified that the
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reactor room ventilation system was operational and that -a negative air pressure was maintained in the reactor pool room during reactor operatio i
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-15-l The air pressure differential between the reactor.po'ol-' room'and.the areas outside the reactor. pool room was: measured at 0.04 inches which was in compliance with-TS 4. .
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The inspectors reviewed several of-the' licensee's' completed TRIGA' reacto f experiment authorization. forms and determined that an analysis of- .
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irradiation experiments' had been performed by- the reactor supervisor and'
approved by the 'RSC, if required, :in: compliance: with TS '4. The inspectors reviewed the'results:of the biennial-fuel element j inspection performed on January 29 1990,Jand documented on Form;NEL-00 '
The licensee had performedia visua11 inspection: for damage or; deterioration of all: fuel elements.in thelTRIGA~ reactor lcorecandi1n storageLin ...
compliance with TS '4.4. > However, the;11censeer did not: perform physical measurements on'each of the fuel elements to. determine'any transverse bend'<
or elongation of the fuel element.:.-TS'414 . implied that these measurement should-be'done-during'each inspection ofreach fuel element along with the'
visual inspection'to determine fuel.elementidamage' severe enough to remove ;
the' fuel element fromofurther use in'the TRIGA reactor core.- The licensee ;
stated that they were of the understandica that the transverse bend and:
elongation measurements only had to be per b rmed as< confirmation of fuel element damage or deterioration if the-visual ;m pection should so-
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indicate. The licensee also stated that subjectina W.L fuel elements
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repeatedly to the transverse bend measuring device'couldiproduce physical damage to the aluminum clad fuel elements by scratching:the cladding. The-inspectors reviewed the licensee's TRIGA TS: dated September 30, 1975, and compared the fuel inspection requirements to'those in the licensee's TRIGA- ,
TS dated March 1985. -The fuel -inspection criteria- expressed in the?1975 TS stated that any fuel element which appeared damaged by.'the visual- t inspection shall be measured for bend.and length. This was the
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interpretation the licensee was also applying to their current fuel ,
-inspection TS. An interpretation of the current TS requirements'was 1 requested from the NRC staff in the Office of:NRR.and they stated that the- i licensee would not be required to ineasure each fuel eierent for transverse- -!
bend or elongation.during'each bienniallaspection unless visual damageLor !
deteriorationLwas indicated. Therefore,'it was, suggested thatLthe licensee apply for a TS amendment which'would be similar to'the.1975 TS requirement and clarify the specific requirements of the: biennial fuel ;
, inspectio The' licensee's records indicated that primaryicoolant water' conductivity and pH values were within TS 4.5 limit No violations or deviations were-identifie . Experiments i The inspectors reviewed the licensee's program.for control and conduct of-reactor experiments including evaluations, conduct, and documentation-of experiments to determine compliance with Sections'1.2,a3.2, 3.6, 4.3.5~, '
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and 6.5.4(1) of the TRIGA T ;
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L The inspectors reviewed selected TRIGA reactor experiment authorization-forms which documented the licensee's requirements regarding the evaluation, review, and approval of reactor experiments. _The inspectors determined that the licensee's- experiment authorization . form included the'-
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requirements in the TRIGA TS. It was noted.that'the reactor superviso .i o approved all experiments and the RSC1 reviewed al1~new and C1 ass II -f
, experiments. The TRIGA reactor had been primarily used for.-the
l' -irradiation of ore samples, biological' samples, and the: production of 1sotopes for medical tracer applications.
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No violations or deviations were identifie '
14. Transportation-of Radioactive Materials ;
a The inspectors reviewed the licensee's program for the transportation of, -'
radioactive materials to determine compliance with the TRIGA~ reactor i license condition requirements and_the requirements of-10 CFR Parts 2 and 30,41 '
The inspectors determined that the licensee t.ad not.made<any' shipmentsof-SNM or reactor components offsite since the last NRC' inspection.in February 1988. However, the licensee had transferred byproduct material-
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produced during the ir"radiati_on of samples in coniucting1 experiments to j other licensed personnel authorized'to receive,such: byproduct materia '
The inspectors reviewed selected TRIGA reactorfirradiationerequest= Land- '
performance data sheets, Form NEL-027, which.had been completed for each irradiation experiment. . This form documents the, sample and reactor data and material release survey data associated with each experiment. .It was 1 l noted.that'the form did not include the quantity of byproduct m&ter.ial being transferre CFR Part 30.41(c) requires, in part, that "Before transferring byproduct . material to a specific ' licensee of the Commission or an Agreement State :. . . , the licensee transferring,the material'shall L verify that the transferee's license authorizes the receipt of the type, I- form, and quantity of byproduct material to be transferred."
10 CFR Part 20.5 requires, in part, that the quantitycof radioactivity;for purposes of the regulations'shall be measured in termsLof_ disintegrations 7 l- per unit time.or in curie The inspectors'dettrmined;on September 25,' .
l 1990, that the licensee was not determining the ruantity (activity) of the H byproduct material .being transferred to another licensee ed documenting
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this isotopic quantity on Form NEL-027; therefore, indicating that1the ;
licensee had not verified that~ the transferee's license 'was authorized to- *
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receive that quantity-(activity) of byproduct material: generated by the l experiment'~nd a being-transferred. The_ f ailure 'to, determine the quntity i L of byproduct material being transferred and-verifyingithat the . ..
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l transferee's license was authorized to receive that quantity 'of byproduct material is considered an apparent violation of 10 CFR~30.41(c). After- >
discussing this matter, the licensee revised ' Form NEL-027 to specifically
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require the activity of each radionuclide in each sample be documented:on- :
the forma The revised Form NEL-027.also documents that the transferee's i
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license is authorized to receive that' quantity of-byproduct materia Therefore, in accordance with 10~ CFR Part 2, Appendix C, Section.V.A. of ,
the NRC's Enfo'rcement Policy, no Notice of Violation is being . issued ~for this violatio .1 No deviations were identifie '
1 Radiation Protectio '
The inspectors reviewed the licensee's radiction protection program t6;
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determine compliance with Sections 3.7, 4.3.3, and 5.4 of the TRIGA TS'.and 4 10 CFR Part 20-and agreement with the recommendations;of? Industr . ,
Standard ANSI /ANS-15.11-197 .
Radiation exposure ricords for NEL. personnel-were reviewed. It was note that not everyone whh worked in the reactor.. facility had been issued!
personal dosimetry. An example of this was that several students.from-Weber State College lad worked on?the new Berkley reactor console located in the' reactor room mithout being issued personal dosimetry. .The review
. of radiation survey data. indicated that personne1' working in the reactor area would not exceei 10 CFR Part 20.101-11mits,sbut the licensee stated that they planned tr review their personal dosimetry programjto ensure that procedures clearly' address workers that-areirequired to wear dosimetry device The inspectors also reviewed the. lice w ets: program for issuance of2 self-reading- pocket dosimeters (Gos). to' visitors or occasional, students working in the reactor facility. The ' licensee had-~several:
0-200 millirem-(mR) SRDs: stored on a rack behind the1 reactor control room door. These SRDs had not been calibrated nor drift checked and the licensee did not.have a calibration a'nd quality control _ progra established for.SRDs as recommended by. Regulatory Guide;8.4. The licensee informed the inspectors that these SRDs were issued-to students as educational tools'and were not intended for documenting; personne exposure. Therefore, the;1icensee had:no'officia1;means of issuing L temporary . personal dosimetry to occasional: visitors; or studentsiin the-
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reactor facility other than issuing a film badge from the-RHO.
L The inspectors _ reviewed selected monthly radiation'and-contamination i survey records for 1989-and.1990 performed by'both-the'UofU^RHD and.NEL personnel. The radiation . surveys appeared thorough and indicated _ very H
, little contamination. The . inspectors performed independent radiation
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surveys throughout the NEL and reactor facility on September 27, 1990,.and .)
found'very little indication of radiation or. contamination greater than : l background levels. The only radiation level- detected greater than' .
l background was in contact with'the. reactor water demineralizer resin-tank l'
which indicated approximately 2 mR per hour on con. tac The inspectors noted that the licensee had not established a personnel
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frisking station to identify possible contamination on individuals. exiting the reactor room. .The possibility of establishing a frisking station at the exit from the reactor room was discussed with the license . . _ .
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The inspectors noted that lhe licensee does not~ routinely perfo"m neutron surveys of the reactor facility during reactor operation. The li ensee c
indicated that the last neutron survey was performed in 1985 out.could not prcduce the results'of that surveyi Neutron: surveys were diseassed with:
the licensee.by the inspectors'who' indicated that although the reactor is operated at low power' levels, it might be prudent for the licensee to have documentation to , support the potential for or lack of neutron exposure as a result of reactor operatio During the-review of the RSC radiation safety audit performed August 8,~
1989, the inspectors noted that;the director of the NEL, Dr. G, M..Sandquist, had received a. neutron badge'readingiof 5.03 rem for
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November 1988 that had been investigated and determined to be~ erroneou The inspectors reviewed the investigation. report dated January 26, 1989, and concurred with the results of the investigation. The investigation'of, the high neutron badge reading was thorough and handled'.immediately'upon
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notification from the film badge vendor ^ The investigation. determined; ,
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that the neutron exposure.must have been erroneous =since theiTRIGA reactor was shut down, the neutron generator:was not operational,;and:the .
60 micrograms of californium-252 were stored in a 10-foot deep tankLof- *
shielding-water. Since the potential overexposure was' determined to be.
, erroneous by'the VofU RHD within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of being' notified.by the film'
l badge vendor, no notificat11n was required to' be made to the NRC. This matter was discussed with tie licensee. Even though no specific-violation of'10 CFR Part 20.403 occurred, the licensee revised their= personal exposure investigation proceiture and reporting ~ form to include notification of the NRC if a reported or potential' dose exceeds 5 times- -
the annual limit and is involved with the : reactor ' operation' .
No violations or deviations were identifie '
16. Radiological Effluent and Environmental. Monitoring The inspectors reviewed the licensee's radiological environmental a monitoring program-to determine agreement'with commitments in ..
paragraphs 12.6 and 12.7 of the TRIGA SER and compliance with the L requirements of Sections 3.4 and 3.7 of the TRIGA TS and.10 CFR Part 20.10 The inspectors reviewed the licensee's annual reports for the periods July 1, 1988, through June 30, 1989, and July 1,; 1989,?through June 30, 1990, concerning effluent releases and environmental monitoring. During the period July 1988 through June 1989 the total liquid waste radioactivity released to the environment was estimated to be 2.84 pCi,of
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cobalt-60. The average annual calculated concentration of' argon-41 generated during operations:was estimated to-be 1.6.3E-10 pC1/ml which was 3 0.4 percent of the MPC for argon-41~ The total amount of gaseous
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radioactivity relea' sed was estimated at 53.5 pC1. For the reporting
. period July 1989 through June 1990, the licensee reported.no release of liquid radioactive effluent. The average annual calculated concentration of argon-41 generated during this reporting period was estimated at
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jl y u 1.93E-10 uC1/ml which was approximately 0.5 percent of _the MPC for
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argon-41. The total amount of. argon-41' released was estimated at 63.4 pCi'. During 6 months of this reporting period, approximatel .42 millicuries (mci) of phosphorus-32/and other radionuclidestwere'
released from'the Vofu NEL as a result of processing sulfur foil- ,
dosimeters. The total amount of.all gaseous radioactivity released:
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between July 1989 and June 1990 was estimated to be.4.48 mci.-
The licensee's environmental monitoring-programiis primarily conducted by 1 operating and maintaining the air monitoring station located-outside the' '
reactor building for the U.S. Environmental Protection Agency. Th ..
measurementiresults from the-air. monitoring: station. for:the period July 1,.
-1988,fthrough June 30,--1990,-- indicated no unusual changes intradiatiom or:
radioactive material concentrations. The'VofU RHDl conducted quarterly i environmental radiological: surveys by positioning six thermoluminescent' O
, dosimeters in. the areas surrounding- the NEL located in the Merrill , l Engineering Building. No unusual dose rates were. detecte i No violations or deviations were identifie ,
1 Emergency Planning and-Preparedness'
The inspectors. reviewed the licensee's EP for the TRIGA-reactor and the NEL facility to determine agreement with commitments-inJparagraph 13.3 of-l the TRIGA SER and compliance with the requirements of 10 CFR' 1 Parts 50.54(q) and (r) and the recommendations of Regulatory; Guide 2.6 - 1983 and Industry Standard ~ ANSI /ANS-15'16-198 .
The inspectors reviewed the assignment of' responsibilities'during an emergency and emergency facilities and equipment. including medical facilities, communications, and rescue, fire, and radiation protection 'r
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equipment. The inspectors verified that the inventories of- emergency equipment and supplies agreed with the EP. The inspectors discussed with the Salt Lake City Fire Department and the~ UofU Medical Center their . ,
responsibilities in the event of a reactor accident.or' fire atsthe NE The inspectors reviewed the VofU proposed EP submitted to the NRC for approval on June 1, 1990. The inspectors noted~that1Section 4 defined the !
emergency classifications as specified ;in ANSI /ANS-15;16-1982- and endorsed in Regulatory Guide 2.6-1983.- Emergency classifications were defined according to potential radiation exposure _and emergency response.to each !
classification was detailed. Based on maximum hypothetical accident calculations, the external total body radiation. dose 'would be much less than 1 mR and the thyriod dose would be .less than 25 mR to the mos exposed person offsite. Therefore, it-had been. concluded by the NEL staff-that there were no accident scenarios that would lead to an emergency - '
which would be classified more severe than an '_' Unusual Event."
The inspectors reviewed selected NEL emergency procedures and the trainin outline used in conducting training for emergency support personne Annual training had been conducted in June 1988, August 1989, and-
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August 1990'. During discussions with campus imergency support personnel, 1 it was noted that campus security _ play an active role.in'the emergency response to a reactor accident scenario since they control.the keys and i access to the NEL. However, they had not been specifically: included in the annual training of campus personnel:for emergency response and had not !
been consulted during the development of the annual' emergency' drill ;
scenarios. This matter of including campus security personnel. inL the annual training and planning' for the annual reacto.r' emergency drill is considered an open-item pending' licensee evaluation-(407/9001-05).
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The licensee had conducted annual' emergency-drills on March 24, 1988,
. August 22, 1989,:and September 17, 1990. <The inspectors reviewed the-
critiques of the emergency drills conducted in 1989 i
and '1990 and found
! them to be detailed and complete; No violations or deviations were-identifie ,
t 1 Physical' Security The inspectors reviewed the licensee's physical security program to j determine compliance with the requirements of the_TRIGA Operating License 1
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Condition 2.C.(3) and 10 CFR Part 50.54(p) and'the PSP, Revision 2,: dated i January 10, 1989.
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The inspectors reviewed Revision 2 of the VofU PSP for the protection o SNM maintained at the NEL facility as submitted.on January _ 10, 1989. This PSP was approved by the NRC ir. a letter dated ~ July 10,:1989, and'was-currently being enforced. ine inspectors verified that;the. site and facilities were consister;. with the description given in-the PSP. The inspectors examined the use and storage of SNM within theicontrolled access areas and veri'ied that intrusion alarms; functioned properly. A announced test of tno VofU Police Department's response to an intrusion alarm was conductad. The appropriate intrusion alarms were observed on the campus-police dispatcher's control panel and the campus police dispatcher followed established . procedures in response to'the reactor building intrusion alarm. The inspectors reviewed the' security key, control program and determined it to be adequate,
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No violations or deviations were identified.
l-1 Reports and Notifications The inspectors reviewed the licensee's submittal of reports and notifications to the NRC to determine compliance with the requirements of-
-Section 6.10 of the TRIGA T The inspectors reviewed the reactor facility annual reports for the period July 1,1988, through June.30,1990. It was determined that the annual rep. orts met the TS requirements. No special-reports had been issued'to the NRC since the previous inspection 01 the Vofu NEL facility conducted in February 198 >
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No violations or deviations -were identifie . Independent Inspection Effort I i
The inspectors observed a reactor startup, steady-state operation, and
- shutdown. The inspectors also performed independent radiation surveys and
I collected smear samples'and a reactor pool water sample'for the purpose of'
I comparing-analyses results with the-licensee.. The results of the smear ,
. analyses showed no-detectable alpha' contamination-and'only ..
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91 disintegrations per minute beta gamma activity on'the.smearitaken on--
the reactor room floor near the: reactor poo11 water demineralizer. .All'
other smears indicated no detectable beta gamma smearable contamination..-
-Results of the' reactor pool-water. sample-taken at.'12:'30'p.m.-on September 26, 1990, following' reactor operation lare given'below:
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Sample Source NRC Results Licensee's: Re'sults .
,(pCi/ml)- :(pC1/ml) i Reactor Pool Water
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Co-60 7.58E-09 <MDA- 1 The discrepancies in the results were attributable'to. differences in-counting times, instrumentation, analytical techniques', and ' sample-geometry, but were- found generally acceptable for:this low. level! activity and for this type of facility. The: tritium (H-3) activity was determined-to be well below the-10 CFR Part 20,-Appendix.8,. Table II,' Column 12-
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release limit of 3.00E-03 pC1/ml. Gamma spectral analysis of the reactor pool water indicated radionuclide activity concentrations well'below the
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respective 10 CFR Part 20,. Appendix B release limits'.
i No violations or deviations were identified.-
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2 Exit Meeting- q The inspectors met with the licensee's representatives-identified in paragraph 1 of this report at the. conclusion of the inspection on
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September 27, 1990. The-inspectors summarized the scope and the results of the. inspection. .The. licensee. stated that-they,would evaluate the open items concerning. training, the' argon-41 ventilation monitor, the '.
calibration of the area radiation monitors, and EP training identified in-the report. The PSP reviewed.by the inspectors was identified as proprietary informatio o
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