IR 05000072/1993001
| ML20034H818 | |
| Person / Time | |
|---|---|
| Site: | 05000072, University of Utah |
| Issue date: | 03/12/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034H814 | List: |
| References | |
| 50-072-93-01, 50-407-93-01, 50-407-93-1, 50-72-93-1, NUDOCS 9303220108 | |
| Download: ML20034H818 (28) | |
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APPENDIX'-
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E U.S. NL AR REGULATORY-. COMMISSION
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REGION IV
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.. Inspection Report:
50-072/93-01
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50-407/93-01 Operating' License:
R-25 R-126 Licensee: University of Utah Salt ~ Lake City, Utah 84112 Facility Name: Nuclear. Engineering Laboratory Inspection At:. University of Utah, Merrill Engineering Building,.
-Salt Lake City, Utah
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Inspection Conducted: February'8-12, 1993 Inspectors:
J. Blair Nicholas, Ph.D., Senior. Radiation lSrecialist Facilities Inspection Programs Section
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D. Blair Spitzberg, Ph.D.,. Emergency Preparedness' Analyst
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Facilities Inspection Programs Section
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Approved:
deb h/ftEr
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Blaine Murra'y,- Chi
, Facilities Inspection'
Date Programs Sectio
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Inspection Summary
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Areas Inspected: Routine, announced inspection of the licensee's organization and management controls, qualifications and training, special; nuclear material and accountability, reviews and audits, logs and records, procedures,--reactor operations, surveillances, experiments, transportation of radioactivel materials, radiation protection, radiological effluents and environmental monitoring, emergency preparedness, physical security, and reports and '
notifications.
Results:
The licensee's organization and staffing met requirements. A'll
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organizational positions were filled with qualified personnel;
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DOCUMENT CONTAINS PROPRIETARYINFORMATION DECONTROLLED WHEN SEPARATED FROM ATTACHMENT 2 9303220108 930312
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Supervisory controls and reactor implementing responsibilities were
being implemented as required (Section 1.1).
The Reactor Safety. Committee membership met requirements'and performed
its required duties (Section 1.1).
The nuclear engineering laboratory maintained a well qualified staff.
- The Reactor Safety Committee membership met qualification requirements
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(Section 2.1).
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An approved requalification training program"for reactor. operators was
being implemented (Section 2.1).
Two noncited violations. dealing with the reactor operator biennial ~
operator requalification period requirements were identified (Section 2.1).
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The nuclear engineering laboratory's orientation and radiation safety -
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training programs met regulatory requirements (Section 2.1).
The licensee's inventory ~and control of-special nuclear material on site
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met the conditions of the TRIGA Operating License (Section-3.1).
Comprehensive audits and required safety reviews were performed by the-
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Reactor Safety Committee (Section 4.1).-
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The Reactor Safety ;cmmittee had implemented an excellent audit finding'
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tracking system (Section 4.1).
Detailed TRIGA reactor maintenance and operations logs were maintained
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Safety evaluations on the modifications to the reactor. facility:and' o'n
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the installation of the new TRIGA reactor Mark III control console met regulatory requirements (Section 5.1).
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The licensee maintained 'well written approved procedures,. checklists,.
and data forms for reactor safety-related operational and surveillance activities. 'The licensee's program for review and approval 'of '
procedures improved from previous' inspections '(Section-6.1).
The AGN-201 reactor had not been operated since February 1985 and was
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being' decommissioned in accordance with an' approved decommissioning plan (Section 7.1.1).
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The TRIGA reactor was.being operated in accordance with ~0perating -
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License and' Technical Specification requirements (Section 7.1.2).
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. DOCUM ENT CO'NTAINS' PROPRIETARY INFORM ATION
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-3-A new ventilation exhaust stack continuous air monitor was-purchased and:
. Waiting reactor facility design modification a'pproval prior to installation (Section 7.1.2).
The. licensee had performed all-Technica' ' Specification surveillance l
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requirements (Section 8.1).
Reactor experiments had been reviewed and authorized in accordance with
Technical Specification requirements (Section 9.1).
Shipment of special nuclear material met applicable transportation and
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regulatory requirements (Section 10.1).
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The radiation protectio'n program had been effectively implemented;
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(Section 11.1).
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Routine neutron surveys of the reactor facility had not~ been performed.--
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Such surveys were planned using.a newly purchased neutron survey _
instrument (Section 11.1).
No radioactive liquid waste had been released from the reactor-facility.
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Radioactive gaseous releases from the reactor facility met Technical Specification requirements (Section.12.1).
.q An environmential monitoring program was maintained around the reactor l
e facility (Section 12.1).
The licensee's' emergency equipment, instrumentation,'and supplies were
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maintained in a state of operational readiness.
Licensee staff and -
support: organization personnel had been trained and demonstrated knowledge of the emergency plan and emergency procedures
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(Section 13.1.2).
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A weakness was identified for the licensee's' failure to demonstrate the
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e capability to promptly classify emergency events.according to:thejactual
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or projected radiological consequences.specified in the emergency action'
t level scheme (Section 13.1.2).
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A weakness was identified for the absence of. agreements between the i
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licensee and privately owned ambulance companies (Section 13.1.3).
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The licensee was implementing an approved Physical Security Plan f
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(Section14.1).
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Annual operating reports for the TRIGA reactor included the required
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information. A violation.regarding the time of submittal of one of_ the annual reactor. operating reports was self-identified by the licensee:
(Section 15.1).
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A safeguards event report was ' submitted as required -(Section 15.1)..
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Reactor pool water samples will be analyzed by the NRC and compared.to..
licensee's results. The results of this: comparison will. be transmitted
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atalaterdate.(Section.16.1).
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Summarv of Inspection Findinos:
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A noncited violation was identified (Section 2.1).
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A noncited violation was identified (Section 2.1).
e-A self-identified noncited violation was identified (Section 15.1).-
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Weakness 407/93-01 was opened (Section'13..l.2).
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Weakness 407/93-02 was opened (Section 13.1.3).
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Open Item 407/9001-01 was closed s.iection 17.1).
e Unresolved Item 407/9001-02 was closed (Section 17.2).
- 0 pen Item 407/9001-03 was reviewed but not closed (Section 17.3).
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-Open Item'407/9001-04 was closed (Section 17.4).
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Open Item 407/9001-05 was closed -(Section 17.5).
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Attachments:-
Attachment 1 - Persons Contacted and Exit Meeting
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Attachment 2 - Physical Security Plan - PROPRIETARY INFORMATION-
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DETAILS 1 ORGANIZATION AND MANAGEMENT CONTROLS (40750)
The inspector reviewed the organization, management controls, and. staffing to E
determine agreement with the commitments in the TRIGA Safety Evaluation Report, NUREG-1096,- and compliance with Technical Specifications 6.1, 6.2,
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6.5.1, 6.5.2, and 6.5.3.
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1.1 Discussion E
The inspector verified that' the organizational structure of the nuclear engineering laboratory for. the reactor operations.was as. defined 'in the Safety i
Evaluation Report and _ Technical Specifications. The nuclear engineering
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laboratory staff assignments' of responsibilities were described in the L
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Operations Manual. All' organizational positions were filled with' qualified personnel. There'had been one nuclear engineering laboratory staff change int
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September 1992 since the previous NRC. inspection conducted in September 1990.-
A new full-time faculty member had been hiredito fill the. position of reactor.
I supervisor and oversee the. daily operations of the reactor facility., = The-
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reactor supervisor was supported'by'three senior reactor. operators.in conducting the reactor program. The' inspector. verified that the supervisory.
control and reactor implementing responsibilities.were being implemented in accordance with Safety Evaluation Report and Technical Specifications.
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The inspector reviewed the Reactor Safety Committee's charter.and membership.
t The Reactor. Safety-Committee membership wastin.accordance with' the-charter and Technical Specification requirements. The inspector verified that-selected'
Reactor Safety Committee meeting minutes were being conducted at least'
O quarterly during the period September 1990 through December 1992 in.accordance with the charter and Technical. Specification. requirements. The-Reactor Safety Committee meeting agendas and minutes indicated that the-Reactor Safety Committee performed the required reviews.
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1.2 Conclusions
- The licensee's organization and staffing met requirements. All organizational
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positions were filled with qualified personnel. Supervisory controls-and
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reactor implementing responsibilities were being implemented as required..The Reactor Safety Committee membership met requirements and performed its
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required duties.-
2 ' QUALIFICATIONS AND TRAINING (40750)
The -inspector reviewed the training and qualification programs for nuclear engineering laboratory personnel and experimenters working'in the nuclear engineering laboratory to determine agreement with the Industry Standard
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h V-6-ANSI /ANS 15.4-1988 and Regulatory Guides 8.13, 8.27, and 8.29 and compliance with Technical Specifications 6.3, 6.4, and 6.5.2 and 10 CFR 19.12 and 55.
2.1 Discussion L
The inspector reviewed the education and experience of the present nuclear-
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O engineering laboratory staff and Reactor Safety Committee members'and determined that all of the nuclear engineering laboratory staff and the
Reactor Safety Committee members met the qualifications required in the Technical Specifications and ANSI /ANS 15.4-1988.
The inspector reviewed the reactor operator requalification program dated June 5, 1991.
It was noted that the reactor operator requalification program had been approved by the NRC, and it conformed to the requirements of 10 CFR Part 55, Appendix A.
The reactor operator training manual was reviewed and found to be satisfactory to implement the TRIGA reactor operator requalification program. Reactor operator requalification examinations.for.
i 1990 and 1991 were reviewed and the completed examinations were included in the training records for the TRIGA reactor operators except for_one a
individual.Section V.A of the licensee's approved TRIGA reactor operator requalification training program requires that each licensed operator satisfactorily pass a written examination annually. Contrary to_the above,
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the inspector determined on February 9, 1993, that one of.the licensed TRIGA senior reactor operators had not taken the annual operator written
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requalification examination during 1992. This particular licensed TRIGA senior reactor operator was no longer a full-time' employee at:the University-of_ Utah but was still associated with the University through research
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activities. The individual was unavailable at the-time the 1992 annual written requalification examination was given.: Reactor. operations' records indicated the individual operated the TRIGA _ reactor infrequently and_.only.
enough to maintain his on-the-job training qualifications and his senior operator's license operator functions qualifications on the licensee's TRIGA reactor. This individual had not operated the licensee's TRIGA~ reactor since
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the expiration of his biennial' operator requalification period on December 31, 1992. The licensee took immediate corrective action by indicating in his 1992
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written performance evaluation prepared on February 10, 1992, that:he had not.
taken the 1992 written requalification examination and, therefore, had not satisfactorily completed his biennial. operator requalification requirements-i for the period January 1,1991, through December 31, 1992. The written evaluation, which was sent to the individual by certified mail on' February 10, i
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1993, also informed him that his operator privileges for the TRIGA reactor.
- located at the University of Utah were suspended until he had completed and
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satisfactorily passed the reactor operator's written requalification
examination. Because this violation was an isolated _ occurrence,.the
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individual had not operated the TRIGA reactor since thelexpiration'date of his; biennial requalification; training period,Jandlthe fact that the licensee took-
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prompt corrective action to not allow the individual. to operate the _TRIGA
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reactor until his operator requalification training requirements had been.
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satisfactorily completed. The violation is not being cited because the _ _
criteria specified in:Section VII.B.1 of Appendix C to 10 CFR Part _2 have been
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The requal'ification t' raining: records for the five TRIGA-senior reactbr-operators were reviewed and found to contain most of,the documentation required by the approved TRIGA reactor operator requalification training-'
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program except1for, the 1992 annual written evaluations and a biennial' medical examination for one.of the TRIGA senior reactor operators. The: licensee.
promptly prepared the 1992 annual written evaluations, for the TRIGA senior-reactor operators and placed them in the five individualisenior reactor operator's requalification training.reccrds on February '10,1992. -
10 CFR 55.53(i) requires all licensed reactor operators to have a biennial medical examination, and Section VII of.the licensee's approved TRIGA reactor operator requalification training program requires the licensee to maintain for each licensed operator a copy of his biennial medical examinati~on results.
Contrary to the above, the' inspector determined on February 9, 1993, that one-of the licensed TRIGA senior reactor operators could not provide documentation indicating that he~ had satisfactorily completed a medical examination during -
his biennial. operator requalification period, January 1,1991',.' through -
December 31, 1992. The licensee took prompt corrective action and suspended.
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the individual from operating the TRIGA reactor until-he-had satisfactorily passed a medical examination. The individual satisfactorily passed a medical examination on February'12,1993, prior to'the completion of the inspection'-
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- and a copy of his medical examination results 'were placed on file.in the.
individual's training records. The individual was reinstated to perform his senior reactor operator duties and responsibilities.: The violation was an -
isolated occurrence a'nd the licensee took prompt corrective action >to not allow the individual to operate the TRIGA reactor until he had ~ satisfactorily -
passed.the required medical examination.
The licensee had revised the biennial TRIGA reactor operator training program-record form to thoroughly document'_a licensed reactor operator's completion of his requalification training program requirements.
The inspector reviewed the nuclear engineering -laboratory. orientation.and radiation safety training programs 'given to _ visitors, experimenters, and.
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students who work in the nuclear engineering laboratory and reactor facility.
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The orientation and radiation safety training materials and examinations were reviewed. The results of the orientation examinations-taken by the: current ~
personnel working in the nuclear engineering laboratory along with the radiation safety examination records of 14 personnel currently working in the'
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nuclear engineering laboratory were reviewed. ' The orientation and: radiation
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-safety tr ining conducted by the nuclear' engineering laboratory staff and'the -
university's radiological health department met.:the requirements-of
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10 CFR 19.12 and included material from Regulatory Guides: 813_ and 8.29.
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The nuclear engineering-laboratory maintained a well qualified staff.- The Reactor Safety Committee membership met qualification requirements.
An approved requalification training program for reactor operators was being.-
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implemented.
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Two noncited violations dealing with the reactor operator biennial operator requalification period requirements were identifted.
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The nuclear engineering laboratory's orientation and radiation safety training programs met regulatory requirements.
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3 LICENSEE CONDITIONS AND SPECIAL NUCLEAR MATERIAL CONTROL AND ACCOUNTABILITY-i (85102)
t The licensec's special nuclear material and accountability program was reviewed to determine compliance with 10 CFR Part 70 and TRIGA Operating-
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License R-126.
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3.1 Discussion The inspector reviewed the storage and inventory of-the licensee's special nuclear material. for compliance with the TRIGA reactor Operating -
License R-126, Amendment 5, dated April 17, 1985. License Condition 2.B(2)..
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authorizes the possession of a 5 curie (Ci) sealed plutonium-beryllium neutron startup source and up to 4.9 kilograms of uranium-235.. The-inspector.-
determined that the licensee possessed 105 grams 'of plutonium-239 which ~is
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equivalent to approximately-6.43 Ci. This' amount of. plutonium-239 was divided between a 5 Ci sealed plutonium-beryllium-neutron.startup source stored in thel TRIGA reactor tank and a plutonium-239 foil'of approximately-1.5 C1Estored in Room 1205-B of the nuclear engineering. laboratory. The plutonium-239 sources
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were licensed under the. university's radioactive materials license issued by-the State of Utah. The inspector performed an inventory of_ the -TRIGA' fuel on site. It was' determined that the' licensee had 5 spent fuel elements:in the spent fuel storage wells, 57 fuel elements in the fuel storage racks at the -
bottom and on the inside perimeter of the reactor tank, and 77 fuel; elements-in the reactor core. This was an increase of four fuel elements since~the previous NRC inspection, and these values agreed with the licensee's' inventory of 139 fuel elements on site ~ performed January 19,1993.
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approximately 34 grams of uranium-235 per fuel element, the licensee's TRIGA
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fuel contained approximately-4.73 kilograms. of uranium-235 which was less than 4.9 kilograms of uranium-235 allowed by the TRIGA Operating License.
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-g-3.2 Conclusion The licensee's inventory and control of special nuclear material on site met the conditions of the TRIGA Operating License.
4 REVIEWS AND AUDITS (40750)
The inspector reviewed the' review and audit programs conducted by the Reactor
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Safety Committee to determine agreement with commitments in Section'13.4 of
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the TRIGA Safety Evaluation Report, NUREG-1096, and' compliance with Technical Specifications 6.5.4, 6.5.5, and 6.5.6.
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4.1 Discussion The inspector determined that the Reactor Safety Committee audits of operations and maintenance activities and radiation safety were being performed semiannually as required by the Technical Specifications. Audit repnrts generated during the period July 1990 through December 1992 were reviewed for scope to ensure thoroughness of program evaluation. The audits included reviews of the reactor maintenance and operations logs; procedures-for reactor operations and maintenance; instrument calibration procedures;
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reactor operating, testing, and surveillance records; experiment:
authorizations; reactor modification authorizations; unusual or abnormal events; and radiation safety. The Reactor. Safety Committee audits met the:
Technical Specification audit requirements. The inspector reviewed a proposed audit and review plan for the reactor facility which was designed. to ensure.
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that all required Reactor Safety Committee reviews and audits be performed at the required frequencies and reported uniformly. This audit and review plan, was revised:on March 15,'1991, but had not been approved'for.use.by'the Reactor Safety Committee. The inspector also reviewed an audit of the.
university's radiation safety program performed in November '1992 by an-independent certified health physicist.
Agendas and minutes of the Reactor Safety Committee meetings. held during the period October 1990 though December 1992 were reviewed. The Reactor Safety:
Committee meeting minutes indicated that the required Reactor Safety Committee.
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cviews were completed. The inspector reviewed the nuclear engineering labo,atory annual schedule which was developed to schedule and track the required administrative, training, operations, surveillance, and instrument.
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calibration activities including reviews, audits, and reports and determined that the nuclear engineering laboratory and Reactor Safety Committee required
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activities were scheduled in accordance with. Technical Specification requirements. The Reactor Safety Committee had developed an audit finding tracking system which listed all audit findings requiring corrective action'on
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the Reactor Safety Committee meeting agendas. The audit findings were discussed at each Reactor Safety Committee meeting and remained on the Reactor
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Safety Committee meeting agenda until resolved and closed during a Reactor Safety Committee meeting and so documented in the Reactor Safety Committee -
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meeting. minutes..This was considered a strength in the licensee's audit and.
review program.'
4.2 Conclusions Comprehensive audits and required safety reviews were performed by.the. Reactor Safety Committee.
A proposed audit and review plan had not been approved for use by the Reactor-Safety Committee.
The Reactor Safety Committee had implemented an excellent audit finding
. tracking system.
5 LOGS AND RECORDS (40750)
The inspector reviewed the licensee's program for documentation of the reactor.
operations and maintenance activities to determine compliance with Technical Specification 6.9.
5.1 Discussion The' inspector reviewed the documentation of TRIGA reactor maintenance and.
operations for the period September 1990 through January 1993. The AGN-201
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reactor was not operated during this time period.. The logs and records documenting TRIGA reactor maintenance,- routine operation, -fuel inventory and storage, fuel inspection experiment authorization and performance, reactor
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startup checklists, instrument. checks and calibrations, radiation surveys, and'
personnel radiation exposure.were reviewed. The inspector determined that the; annual TRIGA reactor operating reports'and the maintenance and. operations history logs and records adequately documented reactor maintenance and operations activities.
The inspector reviewed.the TRIGA reactor maintenance log.- The major modification which was reviewed was the installation, testing, and. operation-of the ~new TRIGA' reactor Mark III' control console. ~ The licensee had performed safety evaluations for the entire control console modification.and for each
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phase of the control. console installation and testing 1n'accordance with 10 CFR 50.59 requirements. The safety evaluations were acceptable 'and met'
-10 CFR 50.59. requirements. The inspector reviewed the procedures.for the installation and testing of the Mark III control console and the ' completed testing and quality control checklists. The installation ~and testing documentation was satisfactory.
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5.2 Conclusions'
Detailed'TRIGA reactor maintenance and operations logs were maintained.
Safety evaluations on the modification 1 to the reactor facility? and on the installation of the new TRIGA reactor Mark III control console met regulatory requirements.
6 PROCEDURES- (40750)
The inspector reviewed the nuclear engineering laboratory Operations Manual o
and reactor operating procedures to determine agreement'with commitments-in Section 4.7 of the TRIGA Safety Evaluation Report, NUREG-1096, and compliance'
with Technical Specification 6.8.
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The licensee had written and approved procedures, checklists, and data forms'
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for safety-related operational and surveillance activities that included <
reactor startup, operation, and shutdown; maintenance; and checks 'and
calibration of equipment and instrumentation. A review of' selected procedures
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and data forms,. revised and approved since the previous NRC inspection in-
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September _1990, indicated that progress had been made in developing andt updating programmatic procedures. The procedures were reviewed by the Reactori Safety. Committee and the reviews were documented in the quarterly Reactor
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6.2 Conclusions The licensee maintained well written approved procedures, checklists, and data-'
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forms for reactor safety-related ' operational and surveillance activities. The-licensee's program for review and approval of procedures improvedifrom previous inspections.
7 REACTOR OPERATIONS - (40750)
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The inspector observed TRIGA reactor operations and reviewed logs and' records to determine compliance with Technical-Specifications 2.0, 3.0, and 5.0.
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7.1 Discussion 7.1.1 AGN-201 Reactor-The AGN-201 reactor had not been._ operated since February 1985. Th'e AGN-201-reactor is being decommissioned. : TheLinspector reviewed the AGN-201
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Decommissioning Plan which was submitted to;the NRC for. approval:on.
July'17 1990. The AGN-201 Decommissioning Plan was. approved by.the-NRC on
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August 1, 1991,fand an_ Order.was issued by the NRC on that same date'to
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-12-authorize the University of Utah to commence decommissioning the. AGN-201 reactor. The bricks, which had surrounded the reactor as a radiation shield
- and a physical security barrier _for the reactor _ fuel,' had been removed, surveyed, released for unrestricted use, and removed from the nuclear-engineering laboratory reactor facility. The AGN-201 reactor fuel was removed i
from the reactor and was shipped to Oak Ridge National Laboratory in February
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1992. The licensee was in the process of continuing with the. decommissioning-activities including dismantling the reactor components,. performing' radiation.
j-surveys of these reactor components in preparation for removal from the nuclear engineering laboratory, and shipment of these reactor components off site.
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e 7.1.2 TRIGA Reactor The inspector inspected the licensee's reactor facilities; reviewed' operations
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and maintenance logs and records, annual reports, and records of experiment performance; and observed the startup and operation of the reactor at low
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power to verify reactor protection systems operation. The licensee stated that the reactor was routinely operated approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per week for
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the purpose of laboratory instruction, re&ctor system tests, reactor surveillances, and sample irradiations. The licensee initiated.startup of the-
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reactor on February 11, 1993,- and' operated the reactor'for_approximately 30 minutes at 10 kilowatts steady-state power to demonstrate to the inspector-the operation of the reactor protective systems and the' capability of the new y
computerized control console to monitor reactor parameters and maintain.a i
steady-state power level.
The inspector reviewed the reactor's operations logs and records _ to determine
compliance with the Operating License and Technical Specification -
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- requi rements. The licensee had operated the reactor at thermal power levels less than 100 kilowatts in compliance with Operating License Condition 2.C.(1)
and Technical Specification 3.1.
The reactor safety limits for fuel element -
temperature were verified-to be in compliance with Technical Specifications 2.1 and 2.2.
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Technical Specification limiting conditions for operation were.. reviewed. -The
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reactor shutdown margin was verified to be $1.30 on January 26,1993, during the latest semiannual control rod worth determination. This value was greater than 50.50 and in compliance with Technical Specification 3.2(1). The excess--
reactivity in the reactor was also determined during the latest semiannual-control rod worth determination to be 50.58 which was less than $2.80 and in
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compliance with Technical Specification 3.2(4). All other reactor reactivity limitations were verified to be in compliance with Technical
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Specification 3.2.
The reactor control and safety requirements were reviewed. The reactor scram times for the scramble control rods were verified to be in the-' range.
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of 0.6 - 0.7 seconds which were less than 2 seconds as required by Technical i
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The inspector verified that all of the reactor control'
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system instrument channels required in Technical Specification 3.3.2 were
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tested and operable and were included on the TRIGA Prestart Checklist Form NEL-001, Revision 4, which had been completed prior to each startup of the
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reactor. The reactor safety systems listed in. Technical Specification 3.3.3
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were all verified to be operable and included on the TRIGA Prestart Checklist._
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The annual reports for 1991 and 1992 were reviewed and the argon-41 discharge
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limit of 4.0E-08 microcuries per milliliter (pCi/ml) averaged over 1 year per
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Technical Specification 3.4 was not exceeded. Operation records indicated
that the ventilation system had operated as required in Technical Specification 3.5.
A review of reactor experiment authorization forms
determined that Technical Specification 3.6 limitations on experiments were checked for each experiment configuration prior to issuing an experiment y
performance authorization. Effluent releases from the reactor facility had been controlled and were as low as reasonably achievable (ALARA)-and met t
Technical Specification 3.7 requirements. The primary reactor coolant chemistry conditions were maintained in compliance with Technical Specification 3.8 requirements.
The TRIGA design features for reactor fuel, reactor core, control rod i
elements, radiation monitoring system, fuel storage, reactor building ventilation system, and reactor pool water systems per Technical Specification - 5.0 were inspected and verified. The reactor fuel was verified to be of the
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type and enrichment described and required in Technical Specification 5.1.
The inspector reviewed the current reactor core configuration map- (No. 22) and
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verified that the fuel elements were positioned in the reactor grid plate in'
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accordance with the current core map and in compliance with Technical Specification 5.2.
The three reactor control elements were verified to have
the required scram capabilities and contained the materials specified for
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standard TRIGA control elements in compliance with Technical Specification l
5.3.
All fuel elements not positioned in the reactor core were stored in the
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reactor pool in storage racks or in the spent fuel storage pits. The fuel elements stored in the' reactor pool were stored in racks at the bottom of the reactor pool in an arrangement where the K,y had been calculated to be less
than 0.8 per Technical Specification 5.5.
The minimum free volume-of the reactor room calculated by the licensee was verified by the inspector and found to meet the Technical Specification 5.6(1) requirement. The ventilation stack from the reactor facility appeared to be of adequate height' to meet the Technical Specification 5.6(2) requirement of at least 40 feet above the
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ground. The inspector verified that the reactor cooling water system met the
requirements in Technical Specification 5.7(1). A hole had been drilled in i
the circulating reactor water piping approximately 3 feet below the normal level of the reactor pool to prevent inadvertent siphoning of the reactor. pool to a lev'el less than 18 feet of water above the top of the reactor core which
met the requirements in Technical Specifications 5.7(2) and 5.7(4). A pool i
level alarm was provided to indicate a loss of reactor coolant if the reactor
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I-14-pool level dropped more than 2 feet below the normal level in compliance with'
Technical Specification 5.7(3).
Area radiation monitors were installed in key locations throughout the reactor-L facility at the surface of the reactor pool, on the ceiling directly over the E
- reactor pool,-and in the exhaust ventilation duct. These area' radiation monitors were gamma-sensitive detectors which were calibrated.. and alert and -
alarm setpoints were calculated and set to initiate an alarm at activity-concentrations below the maximum permissible concentrations and provided an _
activity readout at the reactor control console in compliance with Technical'
Specification 5.4(1). These radiation monitors'were verified to be operational and provided the required alarm function:at the reactor control console during the completion of the TRIGA Prestart Checklist prior to the reactor startup witnessed'by the inspector on February 11, 1993., The'
continuous air radiation monitor was an end-window Geiger-Mueller tube....
detector positioned in the reactor facility exhaust ventilation duct to detect and measure the concentration of radioactive particulate activity in the reactor pool room ^ collected on a particulate filter assembly also installed in-the reactor facility exhaust ventilation duct. This monitor was calibrated and an alarm setpoint was calculated at 50 percent of. the maximum permissible-concentration value for any airborne radioactive material not containing alpha-emitters. The radiation monitor initiated an alarm and provided an activity; readout at the reactor control console:in compliance with Technical'
Specification 5.4(2).- Technical Specification 5.4(3) requires an argon-41 stack monitor which is to monitor.the' concentration of radioactive gases,.
specifically argon-41, in the reactor' facility ventilation exhaust' and provide-an alarm and activity readout at.the reactor' contro1~ console. The radiation monitor used for compliance with Technical. Specification 5.4(3) was"the same end-window Geiger-Mueller tube detector used as the continuous air particulate-
. radiation monitor.- The inspector had discussed the use of this~ type of'
radiation monitoring system as a ventilation exhaust stack argon-41 monitor with the licensee during the previous' NRC inspection. The current monitor was serving a multipurpose function and was' not calibrated specifically to monitor argon-41. This matter was the subject of Open Item 407/9001-03 which remains-cpen pending the installation and calibration of a new' continuous air monitor in the reactor facility ventilation exhaust stack. The new continuous air.
monitor had been' purchased and delivered to the nuclear engineering laboratory, and the design modification to the. reactor facility including its installation was in the review process.
It is expe'cted to be installed in 1993. The inspector discussed the design and operation of the new continuous air monitor and understood that it incorporated three independent detectors.-
which monitor three separate channels for particulates, iodines, and argon-41 in the reactor facility ventilation exhaust stack.
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k-15-7.2-Conclusions The AGN-201 reactor _had not been operated since February.1985 and was being=
decommissioned in accordance with an-approved decommissioning. plan.
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The TRIGA reactor was being operated in accordance with Operating, Lice'nse.and -
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Technical Specification requirements..
A new ventilation exhaust stack continuous air monitor was' purchased 'and was waiting reactor facility design. modification approval; prior to installation.
8 TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS ' (40750)
The inspector reviewed reactor. surveillance results to determine compliancei
with Technical Specification 4.0.
8.1 -Discussioll j
y The inspector verified that the fuel element temperature measuring channel was:
calibrated semiannually in compliance with Technical Specification ;4.2(2) and'
documented on' Form NEL-Oll, Revision 1.
The calibration records were reviewed
. for 1991,1992, and 1993.
The channel check for the fuel element'. temperature
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measuring channel was made each time ~ the reactor was operated in compliance
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with Technical Specification -4.2(3) and documented on theLTRIGA:Prestart '
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Checklist. The inspector verified that the re' actor shutdown margin was_
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determined in conjunction'with the semiannual control rod worth determinations.
y and documented on Form NEL-003, Revision 1.
The results f of these.
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determinations were reviewed and determined to be in compliance.with Technical Specification 4.3.l(1). Surveillance records indicated thatzthe reactor
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control _ rods were visually inspected bienniallyas: required in-Technical
Specification' 4.3.l(2) and were ' documented 'on Form NEL-002,: Revision. l.
The
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inspector verified that the scram times were less thanL 1:second and measured.
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at least annually in: compliance with Technical Specification 4.3.2(1).;- lThe scram times were determined-semiannually at the same time the control-' rod.
worth determinations were. performed. Channel' checks of each of the reactor
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safety channels were performed before each day's operation 'as required by-Technical' Specification 4.3.2(2) and documented on the TRIGA Prestart:
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Checklist. Channel calibration of-the. power level monitoring channels:was
performed semiannually in compliance with Technical Specification.4.3.2(3) and.
documented on Form NEL-012,: Revision 1.
The inspector reviewed the results: ofi-
the reactor' power level instrument calibrations for 1991', 1992, and 1993. The:
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fuel temperature measuring channel was tested semiannually during 1991,11992,..
l and:1993 in compliance with Technical Specification 4.3.2(4) and documented on -
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Form NEL-011.
The inspector verified that the required radiation monit'oring systems.were-
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installed and operational.. The licensee's records indicated that the.
radiation monitoring systems were= calibrated = annually:in compliance with:
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' Technical Specification 4.3.3 and documented on Form NEL-023, Revision 1.
The-inspector verified that the. licensee was using a certified calibration source-traceable to the National Institute of Standards;and Technology to produce a
. specific monitor response when placed at specific positions from the; detector.
The inspector reviewed the TRIGA Prestart Checklist, NEL-001, for. selected reactor startups during 1991,1992, and 1993 and verified that the reactor room ventilation system was operational and that' a negative air pressure was maintained in the' reactor pool room during reactor, operation. The air pressure differential between the reactor poo1~ room and the areas outside the
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reactor pool _ room was measured at 0.05 inches which was in compliance with.
Technical Specification 4.3.4.
The inspector reviewed several. of the licensee's' completed experiment-E authori::ation forms and determined that an analysis of irradiation experiments
had been performed by the reactor supervisor and app' roved by the' Reactor
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Safety Committee, if required, in compliance with Technical Specification 4,3.5.
The licensee performed a visual inspection for damage or ' deterioration of all i
fuel elements in the reactor core and in storage:as required in Technical'
Specification 4.4.
The inspector reviewed the results cf the biennial fuel element inspection performed December 23, 1991, and documented on
Form NEL-004, Revision 0.
The licensee's records indicated that the primary coolant water. conductivity and pH values were within Technical Specification 4.5 limits.
8.2 Conclusion
The licensee had performed all Technical Specification surveillance requirements.
9 EXPERIMENTS (40750)
l The inspector reviewed the program for control and conduct of reactor
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experiments including evaluations, authorizations, conduct, and documentation of experiments performed to determine compliance with Technical Specifications 1.2, 3.2(5), 3.6, 4.3.5, and 6.5.4(1).
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9.1 Discussion The inspector reviewed selected reactor experiment authorization forms generated during 1991,-1992, and 1993 which documented the licensee's compliance with the Technical Specification requirements regarding-the evaluation, review, and approval of reactor experiments. 'The inspector i
verified that the experiment authorization form included all of the Technical Specification requirements '~regarding experiments performed in' the reactor.
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t-17-was noted.that the reactor supervisor approved all experiments and that the'
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Reactor Safety Committee. reviewed all-new Class II experiments. The inspector also reviewed selected reactor irradiation request and performance' forms-(NEL-27) which were completed during the performance of. reactor irradiation experiments. The selected reactor irradiation request and performance forms reviewed were for the performance of the reactor experiments which were -
authorized by the reactor experiment authorization forms which were reviewed.
The reactor experiments primarily involved the_ irradiation of ore samples, biological samples, and the production of radioactive isotopes for medical--
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applications.
9.2 Conclusion Reactor experiments had been reviewed and authorized in accordance with Technical Specification requirements.
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10 TRANSPORTATION OF RADI0 ACTIVE MATERIALS (86740)
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The inspector reviewed the licensee's program for the transportation of radioactive materials and special nuclear materials to determine compliance with-the requirements in the TRIGA reactor Operating License, Technical Specifications,10 CFR Part 71, and 49 CFR Parts 172-189.
10.1 Discussion The inspector determined that the licensee had made two shipments of special.
nuclear material (AGN-201 reactor fuel) to the Y-12 Plant.at Oak Ridge National Laboratory, Oak Ridge, Tennessee, on. February 5,1991. The licensee
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used two 55-gallon drums (Department of Transportation Specification ~ 7A,-
Type A, Spec, _17H) for the shipment of the special nuclear material. : Two
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exclusive use vehicles supplied by-Tri-State Motor Transit were used to
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transport the shipment. The inspector verified that the licensee had
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procedures and checklists'for the preparation of the radioactive material
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shipment. The procedures provided for visual inspection of the container prior to filling, instructions for closing and sealing the container, marking
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and labeling requirements, and determining compliance with radiation and
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contamination limits. The inspector reviewed the checklist used.by the
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licensee to assure that procedures were followed and that'the containers were-prepared properly for shipment in accordance with NRC,' Department of
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Transportation,- state, 'and consignee requirements. :The inspector reviewed the
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records and shipping papers for the radioactive material shipment and determined that the licensee had prepared the appropriate bill of lading and shipping papers which included the required information to comply with
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regulatory requirements.
j The licensee had transferred radioactive byproduct material produced during
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the irradiation of samples in ' conducting experiments to other licensed-
personnel authorized to receive such byproduct material. The inspector _'
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-18-reviewed selected TRIGA Reactor Irradiation Request and Performance data-sheets, Form NEL-027, Revision 1, which were completed for each irradiation.
experiment performed. Form NEL-027 documents the sample and reactor data and radioactive material release survey data associated with each experiment.= The form also included the specific isotopic activity of radioactive byproduct material which was transferred and documented the transferee's license number authorizing the transferee' to receive that quantity of radioactive byproduct material.
10.2 Conclusion Shinnnt of special nuclear material met applicable transportation and r gulatory requirements.
e 11 RADIATION PROTECTION (40750)
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The inspector reviewed the licensee's radiation protection program to
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determine agreement with the recommendations of Industry Standard
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ANSI /AN5-15.ll-1977 and compliance with Technical Specifications 3.7, 4.3.'
and 5.4, and 10 CFR Part 20.
11.1 Discussion
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Radiation exposure records for nuclear engineering laboratory personnel were -
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reviewed.
It was noted that personnel with ' duties in the' nuclear engineering laboratory and reactor facility on either a regular or occasional' basis were
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issued a personal dosimeter on a monthly basis by the university's Department __
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of Radiological Health. During the period July 1,1990, through June-30,.
1991, a total of 11 nuclear engineering laboratory personnel ~ were badged and the average monthly dose received was 15 millirem with the~ highest measured exposure being 50 millirem. During the period. July 1, 1991, through-June 30,1992, 'a total of 21 nuclear engineering laboratory-personnel were-badged and the average dose received was < 10 millirem with the highest'
measured exposure being 20 millirem. Over _the 2 year reporting: period (July 1, 1990, through June 30, 1992) 885 visitors toured the nuclear engineering laboratory under the Department of Energy's Reactor Sharing Program. 'No visitor received a measurable dose.
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The inspector reviewed selected monthly radiation and contamination survey.
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records for 1991 and 1992 performed by ioth the university's Department'of Radiological Health and the nuclear engineering laboratory personnel. The
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radiation surveys were thorough and some indicated minor localized removable _
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contamination which was immediately cleaned. The radiation-surveys did not-
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indicate any unusual radiation levels over previous years.
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The inspector noted that the licensee had established' a personnel frisking
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station to~ identify'possible contamination on individuals exiting.the _ reactor
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room. The licensee had'also purchased a hand and foot monitor which was'
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J operational and positioned near the exit from the nuclear engineering laboratory.
The inspector l noted that the licensee had not performed routine' neutron surveys of the reactor _ facility during reactor operation ~ since 1985. This matter was discussed with the licensee during the previous NRC' inspection conducted in September 1990. Since that NRC inspection, the-licensee had positioned 'six-neutron dosimeters around the reactor tank and in the reactor-g
- room and two neutron. dosimeters in the reactor control' room in an attempt. to-monitor neutron. exposure. Exposure records fo'r these neutron dosimeters did not indicate measurable neutron doses. The inspector noted that the licensee had recently purchased a neutron survey meter which was currently calibrated.
The licensee' stated that neutron surveys were-planned to be incorporated'into the routine radiation surveys performed by the nuclear engineering laboratory personnel as soon as possible.
11.2 Conclusions The radiation protection program had been effectively implemented.
Routine neutron surveys of the reactor facility had not been performed.
Such surveys were planned using a newly purchased neutron 1 survey instrument.
12 RADIOLOGICAL EFFLUENTS AND ENVIRONNENTAL' MONITORING (40750)
The inspector reviewed the radiological effluent and environmental programs-to determine agreement commitments in Sections 12.6 and-12.7 'of the.TRIGA Safety-Evaluation Report, NUREG-1068, and compliance with Technical Specifications 3.4 and 3.7 and 10 CFR 20.106.
12.1 Discussion The inspector reviewed the annual reactor operating reports for the periods July 1, 1990, through June 30, 1991,- and July 1, 1991, through' June _30, 1992, concerning effluent and environmental monitoring activities. ' During the.
period July.1990 through June 1992, there was no radioactive ' liquid waste
- released from the reactor facility. For the reporting period July -1990 through June 1991, the average annual calculated concentration of argon-41 generated during operations was estimated to be 1.53E-10 pCi/ml which was approximately 0.4 percent of the maximum permissible concentration for argon-41. The total amount of gaseous radioactivity from argon-41-released was estimated'at 50.3 pCi. During 4 months of this reporting period, approximately 1.2 millicuries (Mci) of phosphorus-32 were released from the-nuclear engineering laboratory as r. result of processing sulfur foil-dosimeters.- The-total amount ofA11 gaseous radioactivity released between July 1990 and June'1991 was estimated to be 1.25 Mci. For'the reporting.
period July-1991-through June 1992, the average annual-calculated-concentration of argon-41. generated operations was estimated' to be DOCUMENT CONTAINS PROPRIETARY INFORMATION:
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't-20-1.79E-10 pCi/ml which was approximately 0.5 percent of the maximum permissible concentration for argon-41. No phosphorus-32 was released. The _ total amount of argon-41 released between July 1991 and June 1992 was estimated to be 58.7 pCi.
The licensee maintains an air monitoring station located outside the reactor building which is operated by the U.S. Environmental Protection Agency. The measurement results from the air monitoring station for the period July 1, 1990, through June 30, 1992, indicated no unusual changes in radiation or radioactive material concentrations. Environmental monitoring was conducted by the university's Radiological Health Department by positioning six thermoluminescent dosimeters in the area surrounding the Merrill Engineering Building which houses the reactor facility. The thermoluminescent dosimeters were exchanged and analyzed quarterly. No unusual dose rates were detected.
12.2 Conclusions No radioactive liquid waste had been released from the reactor facility.
Radioactive gaseous releases from the reactor facility met Technical Specification requirements.
An environmental monitoring program was maintained around the reactor facili ty.
13 EMERGENCY PLANNING AND PREPAREDNESS (40750)
The inspector reviewed emergency equipment and supplies, changes to the emergency plan and emergency procedures, and documentation related to emergency preparedness to determine if the licensee's emergency preparedness program had been maintained in a state of operational readiness. The inspector met with' licensee personnel responsible for implementing the emergency plan and emergency procedures to determine whether the licensee's staff was trained and prepared to respond to emergency, conditions.
13.1 Discussion 13.1.1 Changes to the Emergency Plan and Implementing Procedures The inspector reviewed the emergency plan and determined:that no changes had been implemented since the previous NRC inspection conducted in September 1990. The currently approved emergency plan was approved by the NRC on June _28, 1984. A revised emergency plan was submitted to the NRC for approval on May 21, 1987._ Revisions to the emergency plan were also proposed in a
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memorandum to the NRC dated June 11, 1990. Following review by the NRC's Office of Nuclear Reactor Regulation, these proposed revisions either decreased the effectiveness of the approved emergency plan, or they did~not meet the emergency planning. requirements of 10 CFR Part 50, Appendix E..
Therefore, these proposed changes were not approved. Licensee representatives DOCUMENT CONTAINS PROPRIETARY INFORMATION -
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t-21-stated that the' currently approved. emergency ' plan needed revision in several areas in order to reflect changes made in the emergency preparedness program since 1984.. The licensee's representatives were unaware of the provisions of 10 CFR 50.54(q) which authorizes the licensee to make changes in the emergencyi plan without-NRC approval provided the changes do not decrease the effectiveness of the emergency plan. Based on the discussions with the-licensee,.it appeared that many of the licensee's proposed changes to the ~
approved emergency plan could be implemented pursuant to 10_ CFR 50.54(q).
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The inspector reviewed the licensee's emergency procedures contained in Section 5 of the Facility Operations Manual dated August 1988. - No changes had been implemented in the emergency procedures since the previous.NRC -
inspection. Licensee representatives stated that no formal document control mechanism existed to ensure that only current copies of the emergency plan and-emergency procedures-were available for use. The director of the nuclearc j
engineering laboratory indicated that he had hand delivered updated revisions-J of the emergency call list to the university's safety service dispatcher.
The
inspector found current copies of the emergency plan, emergency procedures, and emergency call list located in the reactor control reem.
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13.1.2 Emergency Preparedness Program Implementation
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The inspector conducted a tabletop discussion with licensee representatives to determine if personnel ~ who would be expected to respond during an emergency-were trained on the emergency plan and could demonstrate this knowledge and
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the capability to implement it properly. The tabletop discussion included the~
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director of the nuclear engineering laboratory, reactor administrator,-reactor-supervisor, reactor operators,. personnel from the university's Departmenti of Public Safety, and the university's radiation safety officer. Those participating in the tabletop discussion are noted in the attachment to this report.
The tabletop discussion included an evaluation of th'e. licensee's understanding of organizational responsibilities for emergency response activities, the.
classification and notification of emergencies, and the implementation of emergency procedures.
Several hypothetical accident scenarios were discussed-to evaluate the licensee's~ anticipated responses.
Licensee representatives demonstrated good knowledge.of organizational.
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responsibilities for emergency response and the notification process.. Reactor operators and safety service dispatcher representatives had a consistent understanding of the emergency notification calls that would.be made during an
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emergency and which individuals would make the emergency notification calls.
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However, it was noted that Section 5.8.of the emergency procedure did not-assign specific responsibility for making the. emergency. notification calls.
In addition, the inspector found that Section 5.8 of the emergency procedure-
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referred to a notification scheme depicted in Table 5.1.. However,.the procedure.did not contain Table'5.1. Table 5.1lwas later supplied to'the
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inspector.and was noted to be an emergency call list which was no longer current and in use.
r-The licensee's emergency action level classification scheme outlined in_ the
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emergency plan mimicked the generic research reactor emergency' action levels recommended in ANSI /ANS 15.16-1982, " Emergency Planning for Research Reactors." This emergency classification scheme categorized radiological
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emergencies according to effluent levels measured _or projected at the' site boundary. Regulatory Guide' 2.6, " Emergency Planning for Research and Test
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a Reactors," endorsed ANSI /ANS-15.16 with clarification, in. part, on the emergency action levels. According to Regulatory Guide:2.6, the emergency
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action levels specified in ANSI /ANS-15.16 are adequate provided that.-
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appropriate emphasis is-also given to developing emergency action levels. that relate directly to facility. parameters.
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During the tabletop discussion, it was determined that the licensee had not'
developed emergency action levels-that related to any facility parameter or prompt monitoring capability.
Because of this, none of the reactor operators interviewed could classify the hypothetical emergency scenarios presented according to the radiological emergency action levels. The senior reactor operators, radiation safety officer, and licensee management ' agreed that.they would not be able to promptly classify accident conditions corresponding to their Unusual Event or Alert emergency action levels except for bomb threats
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or severe natural phenomenon (i.e.- earthquakes). The licensee's failure to demonstrate the capability to promptly classify emergency. events according to the actual or projected radiological consequences specified in the emergency ~
action level scheme was identified as' a. weakness (407/9301-01).
The inspector toured the reactor facility to determine if adequate emergency response ' equipment and -instrumentation were 'available. Survey instruments and monitoring equipment specified in~ Section 8.3 of. the emergency procedure were-maintained and kept in calibration. First aid and dedicated emergency'
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contamination control supplies were found located.outside the reactor control.
room as indicated in the emergency plan. ' The inspector' observed that the emergency battery power supply had been maintained.
Records of monthly.
operability checks of emergency instrumentation and the backup power supply were found to be complete.
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13.1.3 Offsite Support The inspector visited.the dispatch facility of the university's Department of Public Safety. The facility is continuously staffed and_ would be responsible for dispatching security, police, and fire personnel in response to
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emergencies-at the nuclear. engineering laboratory..-The inspector found that
current copies of the licensee's emergency call list and emergency procedures-
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were on file as well as safety service's contingency protocols for responses.
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y-The inspector toured the university hospital. and found that equipment,. survey
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instruments, and approved procedures were available:to respond to the arrival-
of. potentially contaminated. injury victims.
'A decontamination receiving y
l-facility was on standby at the hospital's~ emergency entrance.. Hospital staff
had been trained. in. response' measures ~ for potentially contaminated injury
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victims, and demonstrated knowledge of the procedures.:
The inspector found that no letters of agreement were on file to identify
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support agreements with.offsite organizations..According to the licensee,.
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support organizations, such as university safety service, the university l
hospital, local fire department, hazardous' material response teams, etc. all
fell under the authority of the State of Utah.
In the tabletop discussions, it was determined that ambulance service for individuals who could be injured a
at the licensee's facility was provided by privately owned companies.. The:
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radiation safety officer stated that it was unclear whether these ambulance?
i companies would transport known contaminated victime in the' event' of an accident at the nuclear engineering laboratory. The absence of agreements-between the licensee and privately owned ambulance companies was identified as
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a weakness (407/9301-02).
T 13.1.4 Emergency Alarms q
The inspector reviewed documentation of monthly checks of: radiation-and.-
- i intrusion alarms from the nuclear engineering laboratory-and found. these -
records to be'in order.
Independent tests of one intrusion alarm and one radiation alarm were performed.
Receipt of the alarms was verified in the;
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university's safety. service dispatch facility.
13.1.5 Emergency Preparedness Exercises and Drills:
The inspector reviewed. documentation of emergency drills' and exercises
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conducted since the. previous NRC inspection. Emergency exercises had been
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conducted approximately'every 12 months. The exercise scenarios involved credible emergencies such as bomb threats, contaminated injury victims' and
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earthquakes. The exercise scenarios involved good challenges forf emergency
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response personnel. Critiques were performed following^ each exercise, and
critique recommendations were documented. There was some documentation of
followup actions taken in response to critique' findings, but it was not clear j
in all cases what actions were planned or completed.
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13.1.6. Training
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Reactor operators had been trained in. the emergency plan and emergency procedures during the course of initial operator training and annual',
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requalification operator-training..The inspector reviewed documentation of-radiation safety training'given to response personnel employed by' outside response' organizations. The training materials supplied to response'personnelz included information regarding site-specific. hazards.and emergency procedures.
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Attendance at the training sessions included appropriate organizational
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representation from the university's Department of Public Safety, police, and city fire departments.
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13.2' Conclusions
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The licensee's emergency equipment, instrumentation, and supplies were'
' maintained in a state of operational readiness. Licensee staff and support.
organization personnel had been trained and demonstrated knowledge of the emergency plan and emergency procedures.
i A weakness was identified for the licensee's failure to demonstrate the capability _ to promptly classify emergency events according -to the actual or
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projected radiological consequences specified in the emergency action level scheme. Another weakness was identified for the absence of agreements between the licensee and privately owned atbulance companies.
14 PHYSICAL SECURITY (81401,81402,81403,81431,and81810)
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The inspector reviewed the physical security program to determine compliance with the TRIGA Operating License Condition 2.C.(3),10 CFR 50.54(p), and Physical Security Plan, Revision 3, dated February 19, 1992.
In accordance with 10 CFR Part 2.790(d), the material 'concerning-the Physical Security Plan is exempt from disclosure. Therefore, this material is.
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discussed in Attachment 2 to this Appendix and will not be placed in the'
Public Document Room.
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15 REPORTS AND NOTIFICATIONS (40750)
t The inspector reviewed the licensee's submittal of reports and notifications-to the NRC to determine compliance with Technical Specification 6.10 and 10CFR'73.71(c).
15.1 Discussion
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The inspector reviewed the licensee's two annual reactor operating reports for the period July 1,1990, through June 30, 1992.
It was determined that the-
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annual' reactor operating reports contained all of the information required by Technical Specification 6.10(5). - Technical Specification 6.10(5) requires that the annual reactor. operating reports be issued within 60 days following.
the 30th of June of each year to the Document Control Center, U.S.N.R.C.,
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Washington, D.C., with -a copy to the Regional Administrator, Region. IV. -
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Contrary to this, the licensee's annual reactor operating report for the -
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period. July 1,1990, through June 30, 1991, was submitted to the NRC on
September 20, 1990, and, therefore, was submitted after the 60-day deadline
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following the 30th of June and was. technically ~ in violation of Technical Specification 6.10(5)'. The licensee self-identified this violation _in' the i
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-25-cover letter to the report and stated that the reasnn-for the delay in submitting the report was _to allow for the Reactor Safety Committee, which convened on. September 18,.1990, to review,. discuss, and approve'the report before it was submitted to the NRC because of the significant facility medification that occurred with the installation and implementation of the
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TRIGA Mark III. control console during the report time period. The incident
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was low safety significance, an isolated incident, and-the' licensee
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self-identified the violation. This violation will not be subject to enforcement action, because the licensee's efforts in -identifying and
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correcting the violation meet the criteria specified in Section VII B.2 of'
Appendix C to 10 CFR-Part 2.
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No special reports were issued to the NRC since the previous NRC. inspection'of the nuclear engineering laboratory conducted in September 1990. The inspector
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reviewed one safeguards event report submitted to the NRC for the period!_
January-March 1991 and in accordance with 10 CFR 73.71(c) at the end of the
calendar quarter in which it occurred. The event involving a bomb threat to the nuclear engineering laboratory reactor facility occurred on February 21, e'
1991, and was originally reported to the NRC under the 1-hour notification requirement. After investigation no bombs were found and the threat was determined to be unsubstantiated.
15.2 Conclusions
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The annual operating reports for the TRIGA reactor included the required information. A violation regarding the time of submittal of one of the' annual reactor operating reports was self-identified by the licensee. A safeguards event report was submitted as required.
- 16 INDEPENDENT INSPECTION EFFORT (40750)
The inspector performed an independent inspection of the reactor pool water radioactivity content.
16.1 Discussion The inspector collected and split with the licensee a reactor pool mater sample' for the purpose of comparing isotopic analysis results with. the a-licensee. The results of this comparison will be-transmitted by separate.
correspondence'at a later date.
16.2 Conclusions-Reactor pool water samples will be analyzed by the'NRC and compared to
licensee's _ results. The results of this comparison will be transmitted at.a l
later date.
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-26-17 FOLLOWUP (92701)
17.1 (Closed) Open Item 407/9001-01: Trainina Issues This item was discussed in NRC Inspection Report 50-407/90-01'.and involved the lack.of an orientation training program and radiation safety training program for visitors, students, or experimenters touring or working in the nuclear engineering laboratory which included the radiation protection information
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contained in Regulatory Guides 8.13 and 8.29.
The. inspector reviewed the licensee's revised orientation training program ' instructional outline,' student handout, and a copy of the examination administered following the training and verified that the orientation training program. included the appropriate radiation protection information. The inspector also reviewed the_ revised Radiation Safety Policy Manual used by the university's Department of Radiological Health to conduct the radiation safety training for students'and experimenters working routinely or occasionally in' the nuclear engineering laboratory or reactor facility. The Radiation Safety Policy Manual contained the appropriate radiation protection information including information from.
Regulatory Guides.8.13 and 8.29.
The inspector determined that the licensee's orientation and radiation safety training programs presented the required information.
17.2 (Closed) Unresolved item 407/9001-02: Thermal Power Calibration Calculation This item was discussed in NRC Inspection Report 50-407/90-01 and involved possible erroneous assumptions or measurements which could result in-calculational errors in the performance of the semiannual TRIGA reactor's thermal power calibration. The licensee had evaluated their methodology for measuring and calculating the reactor's thermal power calibration anu had reviewed the validity of the measurements. performed and the various parameter values used in the calculation as presented on the revised calculation data sheet, Form NEL-012, Revision 1, approved March 19, 1992. The' licensee documented on Form NEL-012 the sources of the various parameter values used in the thermal power calibration calculations. The. licensee was in the process of evaluating.and purchasing a more precise instrument for measuring the level of the reactor pool water in the reactor tank which is-a critical parameter in the reactor's thermal powar calibration calculations. The inspector reviewed the revised reactor thermal power calibration calculation methodologies and
. determined them to be satisfactory to resolve this matter.
17.3 (0 pen) Open Item 407/9001-03: Aroon-41 Ventilation Monitor This item was discussed in.NRC Inspection Report 50-407/90-01 and involved-the.
lack of an independent detector located in the reactor facility's ventilation exhaust stack specifically calibrated to monitor the concentration.of argon-41 in the reactor room and ventilation exhaust. stack. The licensee evaluated.
their present system of monitoring the concentration of. argon-41 in the DOCUMENT CONTAINS PROPRIETARY INFORM ATION DECONTROLLED WHEN SEPARATED FROM ATTACHMENT 2 g
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- reactor. facility's. ventilation exhaust stack and decided to. modify the nuclear.
engineering laboratory's ventilation. system to enhance hood operation, improve ventilation capability,< and provide a~ continuous air monitoring system for particulates, iodines, and argon-41 in the reactor room and ventilation exhaust stack. The. licensee had designed a modification to the nuclear-engineering laboratory's ventilation. system which was being re' viewed. A new continuous air monitor had been. purchased and delivered to the~ nuclear engineering laboratory and was waiting installation following the design modification approval. The new continuous air monitor incorporates threei independent detectors for measurement of particulates,' iodines, and argon-41; in the reactor facility's ventilation exhaust-stack. The completion of the.
design modification approval and installation of the new continuous air monitor is expected in 1993.
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17.4 (Closed) Open Item 407/9001-04: Area Radiation Monitor Calibration :
b This item was discussed in NRC Inspection Report 50-407/90-01 and, involved the
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unsatisfactory methodology used to calibrate the area radiation monitors-and the ventilation exhaust stack monitor and the lack of. a primary certified calibration source traceable to the National Institute of Standards and
Technology to produce a specific monitor response when placed at a specific-
location relative to the detectors. The licensee evaluated their area and-ventilation exhaust stack monitor calibrations and revised their calibration
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methodology to use a primary certified calibration source traceable to the.
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National Institute of Standards and Technology.when performing the required annual monitor calibrations.; The inspector reviewed the, latest area radiation
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monitor. calibrations documented on the revised Form NEL-023, Revision 1
approved on May 29, 1991. The inspector determined that the.new method of calibration of the area' radiation monitors and the ventilation exhaust stack monitor was satisfactory to resolve this item.
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17.5 (Closedi Open item 407/9001-05: Emeraency Plan Trainina
.This item was discussed in NRC Inspection Report 50-407/90-01-and involvedLthe lack of involvement of the campus safety services personnel in,the emergency training for the support-organizations which might be requested to. respond to.
an emergency or participate in the. annual emergency exercises held at the nuclear engineering laboratory reactor facility;as required by the licensee's
Emergency Plan. The inspector' reviewed the attendance lists for the-annual
-!1 emergency training held September 25-26, 1991, and November 17-18,;1992, for students and personnel. representing support organizations which might be; i-required to respond. to an emergency at thel nuclear. engineering : laboratory.
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The inspector = determined that personnel from campus, safetyLservices, university police,- and.the. city fire department were in attendance at.the-
. annual; training sessions conducted in 1991 and ~1992.
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ATTACHMENT 1 i
1 PERSONS CONTACTED
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1.1 Licensee Personnel f*D. Gehmilich, Reactor Administrator
- J. Bennion, Senior Reactor Operator
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tJ. Gallagher, Dispatcher Supervisor, University Department of Public Safety.
D. Hall, Radiation Analyst, University Department of Radiological Health
- K. Mease, Administrative Assistant tH. Moeller, Reactor 0perator
tC. Odum, Senior Reactor Operator (Trainee).
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f t*G. Sandquist, Director, Nuclear Engineering Laboratory t*K. Schiager, University Radiation Safety.0fficer tM. Shaub, Manager. Environmental Health and Sa#ety
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f*D. Slaughter, Reactor Supervisor
tR. Smith,Reacto'r0perator(Trainee)
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tM. Taheri, Reactor Operator
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tIndicates those present at the emergency' preparedness-tabletop discussion on February 10, 1993.
- Indicates those present at the exit meeting on February 12, 1993.
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2 EXIT MEETING
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An exit meeting was conducted on February 12, 1993.- During this meeting, the:
inspector reviewed the scope and findings of the report. The' licensee identified the physical security plan, which was provided to and reviewed by:
the inspector, as proprietary information..
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