IR 05000128/2005201
| ML050830356 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 04/01/2005 |
| From: | Beckner W NRC/NRR/DRIP/RNRP |
| To: | Maldanado T Texas A&M Univ |
| Bassett C, NRR/DRIP/RNRP, 404-562-4712 | |
| References | |
| IR-05-201 | |
| Download: ML050830356 (27) | |
Text
April 1, 2005
SUBJECT:
NRC INSPECTION REPORT NO. 50-128/2005-201 AND NOTICE OF VIOLATION
Dear Dr. Maldonado:
March 22, 2005
SUBJECT:
NRC INSPECTION REPORT NO. 50-128/2005-201 AND NOTICE OF VIOLATION
Dear Dr. Maldonado:
This letter refers to the inspection conducted on February 14-17, and March 22, 2005, at your Nuclear Science Center Reactor Facility. The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection.
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress. Based on the results of this inspection, the NRC has identified a violation of NRC requirements. The violation is cited in the enclosed Notice of Violation (Notice). The circumstances surrounding the violation are described in detail in the subject inspection report. The violation is of concern because it shows inattention to detail concerning program management.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response in accordance with its policies to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning this inspection report, please contact Craig Bassett at 404-562-4712.
Sincerely,
/RA/
William D. Beckner, Program Director New, Research and Test Reactors Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No. 50-128 License No. R-83 Enclosures: 1. Notice of Violation 2. NRC Inspection Report No. 50-128/2005-201 cc w/encls.: Please see next page DISTRIBUTION:
PUBLIC RNRP/R&TR r/f AAdams CBassett KWitt WBeckner PDoyle TDragoun WEresian PYoung FGillespie MMendonca DHughes EHylton CNagel PMadden DBarss (MS O6-H2)
PIsaac BDavis (Ltr only O5-A4)
NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML050830356 TEMPLATE #: NRR-106 OFFICE RNRP:RI RNRP:LA RNRP:SC RNRP:PD NAME CBassett EHylton PMadden WBeckner DATE
/ /2005 3/ 30 /2005 3/ 31/2005 4/ 1 /2005 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
ENCLOSURE 1 NOTICE OF VIOLATION Texas A&M University Docket No.: 50-128 Texas A&M University Nuclear Science Center License No.: R-83 During an NRC inspection conducted on February 14-17, 2005, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR 55.3 states a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator as defined in this part.
Contrary to the above, on September 22, 2004 from 1402 to 1559 hours0.018 days <br />0.433 hours <br />0.00258 weeks <br />5.931995e-4 months <br />, the reactor was operating under the direct supervision of an individual who did not have a senior reactor operator license because his license had expired.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Texas A&M University is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555-0001 with a copy to the responsible inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001.
Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have
-2-withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.
Dated at Rockville, Maryland this 1st day of April 2005
U. S. NUCLEAR REGULATORY COMMISSION Docket No:
50-128 License No:
R-83 Report No:
50-128/2005-201 Licensee:
Texas A&M University Facility:
Texas Engineering Experiment Station Nuclear Science Center Location:
College Station, TX Dates:
February 14-17, 2005 Inspectors:
Craig Bassett Kevin Witt Approved by: William D. Beckner, Program Director New, Research and Test Reactors Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY Texas A&M University Texas Engineering Experiment Station Nuclear Science Center Inspection Report No. 50-128/2005-201 The primary focus of this routine, announced inspection included onsite review of selected aspects of the licensee's Class II research and test reactor safety programs including:
organizational structure and staffing, review and audit and design change functions, operator requalification, facility procedures, reactor operations, fuel handling, maintenance and surveillance, experiments, and emergency preparedness since the last NRC inspection of these areas. The licensee's programs were generally directed toward the protection of public health and safety and were in compliance with NRC requirements. However, a violation of regulatory requirements was identified.
Organization and Staffing
!
The licensees organization and staffing remained in compliance with the requirements specified in Technical Specifications Section 6.0.
Review, Audit, and Design Change Functions
!
The Reactor Safety Advisory Committee acceptably completed the review, oversight, and audit functions required by Technical Specifications Section 6.2.
!
The licensee's design change program was being implemented as required.
Operator Licenses, Requalification, and Medical Activities
!
The Requalification Program was being completed as required and records were being maintained.
!
One violation was identified involving an individual performing licensed activities without a current senior operator license as required by 10 CFR 55.3.
Procedures
!
Facility procedures and document reviews satisfied Technical Specifications Section 6.3 requirements.
!
Procedural compliance was acceptable Operations Activities
!
Operational activities were generally consistent with applicable Technical Specifications and procedural requirements.
-2-Fuel Handling and Movement
!
Fuel handling activities and documentation were as required by Technical Specifications and facility procedures.
Maintenance and Surveillance
!
The program for Surveillance and Limiting Conditions for Operations confirmations was generally being implemented in accordance with Technical Specifications Sections 3.0 and 4.0 requirements.
!
Maintenance was being completed as required.
Experiments
!
The program for the control of experiments satisfied regulatory requirements and license commitments.
!
The Emergency Plan and Emergency Implementing Procedures were generally being audited and reviewed annually as required.
!
Letters of Agreements documenting emergency support to be provided by offsite agencies were being maintained and updated as required.
!
Emergency facilities, instrumentation, and equipment were being maintained and controlled as required.
!
Annual drills were being held as required and documentation was maintained concerning the follow-up critiques and subsequent corrective actions if needed.
REPORT DETAILS Summary of Plant Status The licensees one megawatt (1 MW) Research and Test Reactor (RTR) continued to be operated in support of laboratory experiments, various research projects, operator training, and irradiation of various materials. During the inspection, the RTR was started, operated, and shut down as required and in accordance with applicable procedures to support these ongoing activities.
1.
Organization and Staffing a.
Inspection Scope (Inspection Procedure [IP] 69001)
To verify that the licensees organization and staffing were as stated in Section 6.1 of the Technical Specifications (TS) for the Texas Engineering Experimental Station, Texas A&M University System Nuclear Science Center Reactor Facility, Amendment No.15, dated November 1, 1999, the inspectors reviewed:
organization and staffing for the Texas A&M University (TAMU) Nuclear Science Center (NSC)
administrative controls and management responsibilities specified in the NSC TS
Texas A&M University NSC 2002 Annual Report, dated March 31, 2003, and Texas A&M University NSC 2003 Annual Report, dated March 26, 2004
NSC Standard Operating Procedure (SOP), Chapter I, Policy and Procedures, Section I-C, Administration, Revision (Rev.) 0, dated March 6, 1990
NSC SOP, Chapter II, Reactor Operations, Section II-A, General Organization and Responsibilities, Rev. 1, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-A, General, Rev. 1, dated February 9, 2000
NSC SOP, Chapter VI, Maintenance and Surveillance of Support Systems, Section VI-A, General, Rev. 0, dated February 1, 1985 b.
Observations and Findings The organizational structure and functions of the Texas Engineering Experimental Station (TEES), NSC Reactor Facility had not functionally changed since the last inspection (refer to NRC Inspection Report No. 50-128/2004-201). The licensees current operational organization and assignment of responsibilities, as reported in the latest Annual Report, were consistent with those specified in the TS Sections 6.1.1 and 6.1.2. All positions were filled with qualified personnel and a review of the applicable records verified that staffing was as required by TS Section 6.1.3 and the licensees procedures.
However, there had been changes in the staffing. The former Reactor Supervisor had left the organization, as had the Associate Director. No one had been hired to replace the Associate Director but a person who was a Senior Reactor Operator (SRO) was designated as the Reactor Supervisor. The inspectors noted that the SRO had served as the Reactor Supervisor in the past. The workload of the Associate Director had
-2-been divided among other staff members, principally the Manager of Reactor Operations and the Radiation Safety Officer.
c.
Conclusions The licensees organization and staffing and assignment of responsibilities remained in compliance with the requirements specified in TS Section 6.
2.
Review, Audit, and Design Change Functions a.
Inspection Scope (IP 69001)
To verify that the licensee had established and conducted reviews and audits as required in TS Section 6.2 and to determine whether modifications to the facility, if any, were consistent with 10 CFR 50.59, the inspectors reviewed:
completed audits and reviews for 2003 and 2004
Reactor Safety Board meeting minutes for 2003 through the present
program for design changes reviewed in accordance with 10 CFR 50.59
Texas A&M University NSC 2002 Annual Report, dated March 31, 2003, and Texas A&M University NSC 2003 Annual Report, dated March 26, 2004
NSC SOP, Chapter I, Policy and Procedures, Section I-H, The Reactor Safety Board, Rev. 1, dated August 19, 2003 b.
Observations and Findings (1)
Review and Audit Functions The inspectors reviewed minutes of the last three Reactor Safety Board (RSB)
meetings. The minutes showed that the committee met once per calendar year as required by TS Section 6.2.2.a and that a quorum was present for each meeting. The topics considered during the meetings were appropriate and as stipulated in TS Section 6.2.3. The RSB generally conducted audits and reviews of the ALARA program, the emergency preparedness and security plans, and the licensees conformance of operations and maintenance to the TS, as required by TS Sections 6.2.4 and 6.2.5. However, in reviewing the RSB audits, it was noted that some specific audits were not completed in a timely manner as required by the TS. These audits, and the delay in their completion, are discussed below in Sections 3 and 9 of this inspection report.
The inspectors reviewed the results of the audits including recommendations for improvement and/or concerns. It was determined that the audit findings and licensee actions taken in response to the findings were acceptable.
(2)
Design Change The inspectors determined that no Experiment Authorizations (EA) or Modification Authorizations (MA) had been processed during the past two years at the NSC
-3-Reactor facility. Some changes had been made to enhance security but these did not require a 10 CFR 50.59 review. The inspectors verified that a system was in place that required modifications to be analyzed by the staff and reviewed and approved by the RSB.
c.
Conclusions The RSB acceptably completed the review, oversight, and audit functions required by TS Section 6.2. Based on the records reviewed, the inspectors determined that the licensee's design change program was being implemented as required.
3.
Operator Licenses, Requalification, and Medical Activities a.
Inspection Scope (IP 69001, 92701)
To verify that operator requalification activities and training were conducted as required in the licensees Reactor Operator Requalification Program, Rev. 4, dated April 1997, and that medical requirements were met, the inspectors reviewed:
medical examination records
active license status of all current operators
written examinations given to operators for 2003 and 2004
NSC Reactor Operations Log Books for 2004 through the present
logs and records of reactivity manipulations for 2003 through the present
training lectures and records for selected individuals for the current and previous training cycles documented on:
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NSC Form 521, Reactor Operations Two-Year Training Cycle, latest revision dated August 19, 1999
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NSC Form 522, Reactor Operator Two-Year Training Records, latest revision dated January 31, 2005
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NSC Form 523, NSC Reactor Operator Requalification/Training Lecture, latest revision dated February 3, 2005
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NSC Form 524, SRO and RO Requalification Exam Cover Sheet, latest revision dated July 17, 2001
Radiation Safety Board Reactor Requalification Program Audits dated June 20, 2003, and February 8, 2005
NSC SOP, Chapter X, Reactor Operator Requalification Program, Rev. 2, dated March 2, 2001 b.
Observations and Findings (1) Operator Licenses, Requalification, and Medical Activities The facility had seven qualified, licensed SROs, four Reactor Operators (ROs),
and a number of trainees. As of the date of the inspection, all of the operators licenses were current.
-4-A review of the training records showed that training had been conducted in the areas outlined in the licensees NRC approved requalification program. Records reviewed verified that annual operational examinations were being administered as required. Written examinations were administered within the time frame as required. The inspectors noted that the licensee was tracking and documenting hours and reactor manipulations to ensure that the operators met the requalification program requirements and those stipulated in 10 CFR 55.53(e) to maintain operating licenses in an active status. In order to comply with the requirement for actively performing their operator functions for a minimum of four hours per calendar quarter, the licensee included time spent on the reactor console, supervisory functions, and maintenance, as appropriate. This was consistent with 10 CFR Part 55 requirements.
Medical exams for the various qualified operators were performed biennially as required.
(2) Lack of a Licensed Operator On Duty 10 CFR 55.3 states a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator as defined in this part.
The inspectors reviewed the NSC Reactor Operations Log Books and noted that the licensee had operated the reactor under the supervision of an individual who did not possess a senior reactor operator (SRO) license. The SRO license of this individual expired on September 16, 2004, in accordance with 10 CFR 55.55. On September 22, 2004, the individual had taken over SRO duties halfway through operations for the day and was in charge while the reactor was at power from 1402 to 1559 hours0.018 days <br />0.433 hours <br />0.00258 weeks <br />5.931995e-4 months <br />. NRC Operator Licensing staff (NRR/DRIP/RNRP) had contacted the individual about the status of the license approximately 60 days prior to its expiration but the individual did not reply. Immediately after notification from the NRC that the individuals license had expired, the licensee verbally communicated that the individual had performed licensed duties after the license was expired. After reviewing the circumstances surrounding this incident, it was determined that the licensee had failed to ensure that the individual was current in the requalification program and this ultimately resulted in the lapse of a qualified SRO on duty. The licensee had implemented a new planning calendar to help ensure that timeliness requirements were met. The inspectors verified that several dates for requalification activities were already placed on the calendar.
The licensee was informed that allowing an individual to direct licensed activities of other licensed operators without a senior operator license was a violation of 10 CFR 55.3 (VIO 50-128/2005-201-01).
(3) Operator Requalification Program Audits Section 6.2.4 of the Technical Specifications requires that the Radiation Safety Board conduct audits of several programs at the facility. TS 6.2.4(b) states that
-5-1An Unresolved Item is a matter about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation.
audits concerning the retraining and requalification program for the operating staff shall be conducted at least once per calender year, interval not to exceed 15 months.
The inspectors reviewed the Requalification Program Audits conducted by a member of the RSB. One of the items in the audit concerned the failure to conduct the audits in a period not to exceed 15 months. The audits for the requalification program were conducted 19 months apart on June 25, 2003 and February 8, 2005. The licensee had implemented the use of a new planning calendar in an attempt to prevent any future occurrences of this type.
The licensee was informed that failure to failure to conduct an annual audit of the Requalification Program was identified as an Unresolved Item1 (URI) pending corrective actions and implementation of controls to prevent recurrence. This issue will be reviewed during a future inspection (URI 50-128/2005-201-02).
c.
Conclusions The Requalification Program was generally being completed as required and records were being maintained. One violation was identified involving operation of the reactor under the direct supervision of an individual who did not have a senior reactor operator license because his license had expired. An URI was noted for failure to conduct an annual audit of the Operator Requalification Program.
4.
Procedures and Procedural Compliance a.
Inspection Scope (IP 69001)
To verify that facility procedures were being reviewed, revised, and implemented as required by TS Section 6.3, the inspectors reviewed selected aspects of:
selected forms and checklists
procedural reviews and updates
selected operating and administrative procedures and logs
Reactor Safety Board meeting minutes for 2004 through the present
selected entries on the following facility forms:
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NSC Form 595, entitled Procedure Change Notice (PCN), latest revision dated January 26, 2005
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NSC Form 597, entitled Procedure Change Notice (PCN) Update Checklist, latest revision dated January 26, 2005
NSC SOP, Chapter I, Policy and Procedures, Section I-D, Format, Rev. 3, dated February 25, 2002
NSC SOP, Chapter I, Policy and Procedures, Section I-E, Origination, Rev. 1, dated February 25, 2002
-6-
NSC SOP, Chapter I, Policy and Procedures, Section I-F, Review and Approval, Rev. 1, dated February 25, 2002
NSC SOP, Chapter I, Policy and Procedures, Section I-G, Distribution and Binding, Rev. 1, dated July 31, 1986 b.
Observations and Findings The licensees procedures were found to be acceptable for the current facility status and staffing level. The inspectors noted that the procedures specified the responsibilities of the various members of the staff as well as the RSB. The procedures were being audited/reviewed periodically (generally annually) and were updated as needed. It was also noted that substantive revisions to forms and procedures were routinely presented to the RSB for review and approval as required by TS. The inspectors verified that the latest revisions to various procedures and forms had been through this review and approval process as required.
The inspectors observed the completion of a reactor start-up, routine operation, and shut-down. It was noted that the required checks, verifications, and actions were completed in accordance with the applicable procedure.
c.
Conclusions Facility procedures and document reviews satisfied TS Section 6.3 requirements.
Procedural compliance was acceptable.
5.
Operations a.
Inspection Scope (IP 69001)
The inspectors reviewed selected aspects of the following to verify compliance with TS Sections 2, 3, and 6 and the applicable procedures:
Scram Log
Irradiation Cell Log
staffing for operations as recorded on the reactor log sheets
NSC Reactor Operations Log Books Numbers 178 - 186
selected entries on the following facility forms:
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NSC Form 531, entitled Morning Facility Checklist - Daily, latest revision dated June 26, 2003
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NSC Form 532, entitled TRIGA Reactor Pre-startup Checklist, latest revision dated January 8, 2005
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NSC Form 533, entitled Reactor Operations Facility Checklist - Daily Surveillance, latest revision dated March 11, 2003
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NSC Form 534, entitled Facility Security Shutdown Checklist - Daily Surveillance, latest revision dated October 5, 2004
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NSC Form 573, entitled Irradiation Cell Entry Log, latest revision dated August 2, 2001
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NSC Form 574, entitled Irradiation Cell Operations Checklist, latest revision dated August 2, 2001
-7-
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NSC Form 590, entitled Unscheduled Scram Recovery Checklist, latest revision dated October 5, 2004
Texas A&M University NSC 2002 Annual Report, dated March 31, 2003, and Texas A&M University NSC 2003 Annual Report, dated March 26, 2004
selected TAMU NSC Daily SRO Checklists for 2003 and 2004
NSC SOP, Chapter II, Reactor Operations, Section II-A, General Organization and Responsibilities, Rev. 1, dated February 9, 2000
NSC SOP, Chapter II, Reactor Operations, Section II-B, Operations Records, Rev. 3, dated February 9, 2000
NSC SOP, Chapter II, Reactor Operations, Section II-C, Reactor Startup, Rev. 5, dated August 19, 2003
NSC SOP, Chapter II, Reactor Operations, Section II-D, Steady State Mode Operation, Rev. 1, dated September 3, 1999
NSC SOP, Chapter II, Reactor Operations, Section II-F, Reactor Shutdown, Rev. 0, dated December 15, 1993
NSC SOP, Chapter II, Reactor Operations, Section II-I, Reactor Core Manipulation, Rev. 4, dated February 9, 2000
NSC SOP, Chapter II, Reactor Operations, Section II-M, Response to Alarms, Rev. 1, dated February 9, 2000
Memorandum from W. D. Reece, Director, to M. Spellman, Associate Director, Change to Minimum Staff Requirements for Reactor Start-Up (SOP II-C), dated April 24, 2003 The inspectors also observed selected startup, steady state operations, and shutdown activities on February 15 and 16, 2005.
b.
Observations and Findings 1)
Reactor Operations Reactor operations were carried out following written procedures and TS requirements. Information on the operational status of the facility was recorded in log books and on checklists as required by procedure. Use of maintenance and repair logs satisfied procedural requirements. Operational problems and events noted in the appropriate logs were reported, reviewed, and resolved as required.
Scrams were generally identified in the logs and their cause(s) resolved before the resumption of operations under the authorization of an SRO.
The inspectors verified that required items were logged and cross referenced with other logs and forms, as required, and that TS Sections 2 and 3 operational limits had not been exceeded. Operations logs and records also documented that shift staffing met the minimum requirements for duty and on-call personnel as authorized by the NSC Director in a Memorandum dated April 24, 2003.
The inspectors conducted observations of the reactor staff on February 15 and 16, 2005, and reviewed Reactor Operations Log Books and associated records and logs. The inspectors noted that the licensed reactor operators were knowledgeable and competent. Observation of operational activities also
-8-confirmed that reactor operations were carried out in accordance with written procedures and TS requirements.
2)
Emergency Shutdowns and Inadvertent Scrams TS Section 6.6.1.c) requires that an annual report covering the operation of the reactor facility during the previous calendar year shall be submitted to the NRC prior to March 31 of each year providing, among other items of information, the number of emergency shutdowns and inadvertent scrams, including the reasons therefore.
The inspectors reviewed the Scram Log maintained by the licensee. This log indicated the dates when shutdowns or scrams occurred and what actions were taken by the licensee before the reactor was restarted. The inspectors noted that, following each shutdown or scram, the Duty SRO and/or the Reactor Supervisor reviewed the circumstances of the problem, as well as the corrective actions taken as a result, and then approved the restart of the reactor as required. It was also noted that, in 2003, shutdowns or scrams occurred on January 14, April 15, June 11, 13, and 24, September 3, October 15, and December 11. However, the information for each scram was not listed in the TAMU NSC 2003 Annual Report. All the appropriate data was given for the aforementioned scrams except for those that occurred on October 15 and December 11.
The licensee was informed that failure to list the information in the annual report for all shutdowns and scrams that occurred during 2003 was identified as an URI pending corrective actions and implementation of controls to prevent recurrence.
This issue will be reviewed during a future inspection (URI 50-128/2005-201-03).
c.
Conclusions Operational activities were generally consistent with applicable TS and procedural requirements. One URI was noted for failure to list in the Annual Report all information concerning scrams during 2003 as required by TS Section 6.6.1.c).
6.
Fuel Handling and Movement a.
Inspection Scope (IP 69001)
To verify adherence to TS Sections 4.2, 5.1, 5.2, 6.1, 6.7 and licensee fuel handling and inspection requirements, the inspectors reviewed:
Fuel Maintenance Schedule
fuel handling equipment and instrumentation
NSC Reactor Operations Log Books Numbers 178 - 186
fuel bundle FB 27 and FB II DOT/FE 7487 movement records
selected fuel data and records for 2003 and 2004 documented on the following facility forms:
-9-
-
NSC Form 576, entitled Fuel Bundle Assembly Log, latest revision dated October 4, 1999
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NSC Form 577, entitled Fuel Element Location Log, latest revision dated October 4, 1999
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NSC Form 578, entitled Fuel Element Measurement and Inspection History, latest revision dated October 4, 1999
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NSC Form 581, entitled Fuel Element Transfer Storage Basket Log, latest revision dated October 4, 1999
NSC SOP, Chapter II, Reactor Operations, Section II-H, Fuel Manipulations, Revision 7, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-H, Fuel Element Surveillance and Inspection, Revision 3, dated March 2, 2001
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-Q, Special Nuclear Materials Accountability, Revision 0, dated October 31, 1984 b.
Observations and Findings Procedures for refueling, fuel movement, and TS Section 4.2.4 required surveillances ensured controlled operations for the reactor core. All fuel movements were recorded in the reactor log and on individual fuel element log sheets. The inspectors noted that the current core, designated as Core VIII-A, had been in use since March 1986.
The inspectors noted that the data recorded for fuel was acceptable and was cross referenced in the operations logs. Log entries verified that fuel movements were completed under the direct supervision of an SRO as required. Through records review and interviews with licensee personnel, the inspectors determined that fuel movements were conducted in accordance with TS Section 6.1 and licensee procedures Through records review and interviews with licensee personnel, the inspectors confirmed that acceptable radiological and criticality controls were established and implemented for fuel movements as required.
c.
Conclusions The fuel handling activities and documentation were as required by facility TS and procedures.
7.
Maintenance and Surveillance a.
Inspection Scope (IP 69001)
To determine that surveillances and Limiting Conditions for Operations (LCOs)
verifications were being completed as required by TS Sections 3.0 and 4.0, the inspectors reviewed:
Tagout Log
NSC Shift Change Logbook
NSC Reactor Operations Log Books Numbers 178 - 186
surveillance and calibration data and records for 2003 and 2004 documented on the following facility forms:
-10-
-
NSC Form 539, entitled Weekly Ventilation and Scram Surveillance, latest revision dated January 14, 2005
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NSC Form 541, entitled Quarterly Transient Rod Drive Maintenance, latest revision dated October 4, 1999
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NSC Form 546, entitled Semiannual Fuel Element Temperature Measuring Channel Maintenance, latest revision dated April 17, 2000
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NSC Form 548, entitled Semiannual Log Power Measuring Channel Maintenance, latest revision dated August 20, 2003
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NSC Form 549, entitled Semiannual Reactor Pulse Power Surveillance, latest revision dated October 15, 1999
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NSC Form 550, entitled Semiannual Transient Rod Drive Maintenance, latest revision dated October 4, 1999
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NSC Form 551, entitled Semiannual Scram Circuit Surveillance, latest revision dated August 20, 2003
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NSC Form 552, entitled Semiannual Evacuation Horn System Surveillance, latest revision dated October 4, 1999
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NSC Form 557, entitled Annual Reactor Maintenance and Surveillance Schedule, latest revision dated October 4, 1999
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NSC Form 558, entitled Annual Transient Rod Drive Maintenance, latest revision dated October 4, 1999
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NSC Form 559, entitled Annual Control Rod Drive Maintenance, latest revision dated October 4, 1999
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NSC Form 560, entitled Annual Reactor Bridge and Pool Light Maintenance, latest revision dated October 4, 1999
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NSC Form 561, entitled Annual Control Rod Scram Time Surveillance, latest revision dated October 4, 1999
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NSC Form 562, entitled Annual Control Rod Calibration and Shutdown Margin Determination, latest revision dated October 4, 1999
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NSC Form 563, entitled Annual Control Rod Calibration Data Sheet -
Positive Period/Positive Period-Differential Worth Methods, latest revision dated October 4, 1999
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NSC Form 564, entitled Annual Control Rod Calibration Data Sheet - Rod Drop Method, latest revision dated October 4, 1999
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NSC Form 565, entitled Annual Calorimetric and Linear Power Measuring Channel Maintenance, latest revision dated October 4, 1999
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NSC Form 566, entitled Annual Pulse Power Measuring Channel Maintenance, latest revision dated September 30, 2002
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NSC Form 567, entitled Annual Safety Power Measuring Channel Maintenance, latest revision dated September 13, 2002
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NSC Form 568, entitled Control Rod Inspection, latest revision dated September 2001
-
NSC Form 569, entitled Biennial Control Rod Drive Location and Height Measurements, latest revision dated October 4, 1999
NSC SOP, Chapter II, Reactor Operations, Section II-J, Power Calibration, Rev. 1, dated May 10, 2000
NSC SOP, Chapter II, Reactor Operations, Section II-K, Control Rod Calibration, Rev. 1, dated March 17, 1997
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-A, General, Rev. 1, dated February 9, 2000
-11-
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-B, Fuel Element Temperature Measuring Channel Maintenance and Surveillance, Rev. 1, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-C, Linear Power Measuring Channel Maintenance and Surveillance, Rev. 3, dated August 19, 2003
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-I, Scram Circuit Surveillance, Rev. 2, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-J, Transient Rod Drive Maintenance and Surveillance, Rev. 2, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-K, Control Rod Inspection, Rev. 2, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-L, Control Rod Drive Maintenance, Rev. 2, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-M, Annual Control Rod Calibration and Determination of Shutdown Margin, Rev. 1, dated February 9, 2000
NSC SOP, Chapter III, Reactor Maintenance and Surveillance, Section III-O, Reactor Pool Maintenance, Rev. 1, dated March 17, 1997
NSC SOP, Chapter VI, Maintenance and Surveillance of Support Systems, Section VI-B, Ventilation System Maintenance and Surveillance, Rev. 1, dated September 3, 1999
NSC SOP, Chapter VI, Maintenance and Surveillance of Support Systems, Section VI-C, Electrical Power Failure, Rev. 1, dated February 25, 2002
NSC SOP, Chapter VI, Maintenance and Surveillance of Support Systems, Section VI-D, System Tagout Procedure, Rev. 2, dated August 19, 2003
Texas A&M University NSC 2002 Annual Report, dated March 31, 2003, and Texas A&M NSC 2003 Annual Report, dated March 26, 2004 b.
Observations and Findings 1)
Maintenance Activities A review of the reactor console and maintenance logs showed that they were being maintained as required and problems, if any, were being documented. This review also demonstrated that maintenance was being conducted consistent with the TS and applicable procedures. Maintenance activities ensured that equipment remained consistent with the Safety Analysis Report and TS requirements.
2)
Surveillance Activities The inspectors determined that selected daily, monthly, annual, other periodic checks, tests, verifications, and calibrations for TS-required surveillances and LCOs were completed as stipulated. Surveillances, LCOs, and calibration reviews were completed on schedule and performed in accordance with licensee procedures. All the recorded results were within the TS and procedurally prescribed parameters and in close agreement with the previous surveillance
-12-results. The records and logs reviewed were accurate, complete, and being maintained as required. All values checked by the inspectors satisfied the limits/parameters listed in the procedure or checklist.
3)
Weekly Ventilation and Scram Surveillance TS Section 4.4 requires that it shall be verified weekly that the ventilation system is operable.
The inspectors reviewed the records of the weekly checks and verifications of the ventilation system documented on NSC Form 539, entitled Weekly Ventilation and Scram Surveillance, latest version dated January 14, 2005. It was noted that, although the reactor was operated during each of the weeks listed, all of the weekly verification forms of the ventilation system checks had been not been completed as required for the period from October through December of 2003.
During that time, a weekly verification form had been completed on September 26 for the work week beginning on September 22 but none had been completed during the next week beginning September 29. Likewise, a weekly verification form had been completed on October 10 for the work week beginning on October 6 but none had been completed during the next week beginning October 13. A weekly verification form had been completed on October 24 for the work week beginning on October 20 but none had been completed during the next week beginning October 27 and none had been completed during the following week beginning November 3. A weekly verification form had been completed on November 12 for the work week beginning on November 10 but none had been completed during the next week beginning November 17 and none had been completed during the following week beginning November 24. A weekly verification form had been completed on December 3 for the work week beginning on December 1 but none had been completed during the next week beginning December 8 and none had been completed during the following week beginning December 15.
When the inspectors reviewed the NSC Reactor Operations Log Books for the time period from June 2003 through December 2003, it was noted that there was a log entry during each of the aforementioned weeks that indicated that a scram check had been conducted at some point in time during the weeks in question.
The licensee indicated that the ventilation checks were typically completed when the scram checks were done. The licensee was informed that, although the proper forms documenting the weekly ventilation checks were missing, the log book entries concerning weekly scram checks would be accepted as verification that the weekly ventilation checks, required by the TS, had also been completed.
c.
Conclusions Maintenance was being completed as required. The program for surveillance and LCOs confirmations was generally being implemented in accordance with TS Sections 3.0 and 4.0 requirements.
-13-8.
Experiments a.
Inspection Scope (IP 69001)
The inspectors reviewed selected aspects of the following in order to verify that experiments were being conducted within approved guidelines:
control of irradiated items
potential hazards identification
NSC Reactor Operations Log Books Numbers 178 - 186
selected entries on the following facility forms:
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NSC Form 511, entitled Experiment Request, latest revision dated March 27, 1998
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NSC Form 512, entitled New Experiment Review and Approval, latest revision dated March 27, 1998
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NSC Form 514, entitled Request for Services, latest revision dated January 6, 2005
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NSC Form 515, entitled Extended Irradiation Time Sheet, latest revision dated February 25, 2003
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NSC Form 518, entitled Experiment Authorization, latest revision dated March 14, 2000
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NSC Form 701, entitled Laboratory Operations Request for Irradiation, latest revision dated October 30, 2002
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NSC Form 702, entitled Laboratory Operations Experimenter Release Form, latest revision dated March 5, 2002
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-A, Experiment Review and Approval, Rev. 1, dated January 25, 2002
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-B, Sample Handling Procedures, Rev. 0, dated February 15, 1984
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-C, Pneumatic System Operation, Rev. 0, dated February 8, 1991
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-D, Beam Port Experiments, Rev. 2, dated September 3, 1999
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-E, Irradiation Cell Experiments, Rev. 1, dated March 2, 2001
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-F, Neutron Radiography Beam Port #4, Rev. 4, dated March 22, 1990
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-G, In-Pool Irradiations, Rev. 0, dated May 2, 1984
NSC SOP, Chapter IV, Procedures for Use of Experimental Procedures, Section IV-H, Thermal Column Film Irradiation, Rev. 0, dated January 22, 1993
Texas A&M University NSC 2002 Annual Report, dated March 31, 2003, and Texas A&M NSC 2003 Annual Report, dated March 26, 2004 b.
Observations and Findings The inspectors noted that the experiments currently being conducted at the facility were those classified as new, routine or modified routine. The routine experiments
-14-had been reviewed and approved by the Duty Health Physicist and SRO on duty as required and were conducted under the cognizance of the Reactor Supervisor as well.
The results of the experiments were documented on the NSC Reactor Log sheets and on the irradiation request forms.
No new experiments had been initiated, reviewed, or approved since the last inspection. The main experiments being conducted during the inspection were the Noble Gas Fission Product Generator and the Multiple Rotisserie Irradiation Device.
One of the more recent experiments approved, Iodine-125 Processing, had not been conducted recently and it was unlikely that the licensee would be utilizing it in the future.
It was noted that the TS and the applicable procedural guidance required that the RSB review and approve any experiment classified as new. Licensee representatives stated that this was the process that has been and would continue to be followed.
c.
Conclusions The license's program for the control of experiments satisfied regulatory requirements and license commitments.
9.
Inspection Scope (IP 69001)
To verify compliance with TS Section 6.2 and the licensees Emergency Plan (E-Plan)
for the Texas Engineering Experimental Station, Texas A&M University System NSC Reactor Facility, Revision 2, dated December 14, 1999, the inspectors reviewed selected aspects of:
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-A, Emergency Classification Guide, Rev. 3, dated May 10, 2000
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-B, Evacuation Procedures, Rev. 1, dated December 19, 1997
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-C-1, Operational Events: Implementing Procedure for a Personnel Injury, Rev. 1, dated September 14, 1995
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-C-2, Operational Events: Implementing Procedure for a Minor Fire, Rev. 2, dated December 4, 1997
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-C-3, Operational Events: Implementing Procedure for an Explosion Non-Specific to Reactor, Rev. 1, dated September 14, 1995
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-C-4, Operational Events: Implementing Procedure for a Facility Air Monitor Alarm (FAM CH# 1,3,4 and 6), Rev. 1, dated September 14, 1995
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-C-5, Operational Events: Implementing Procedure for a Xe-125 Monitor Alarm, Rev. 0, dated May 10, 2000
-15-
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-D-1, Notification of Unusual Events: Implementing Procedure for a Major Fire, Rev. 2, dated December 4, 1997
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-D-2, Notification of Unusual Events: Implementing Procedure for an Explosion Involving Reactor or Radioactive Material, Rev. 1, dated September 14, 1995
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-D-3, Notification of Unusual Events: Implementing Procedure for a Tornado, Rev. 2, dated March 2, 2001
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-D-4, Notification of Unusual Events: Implementing Procedure for a Pool Level Alarm-Leak Not Exceeding Make-Up Capacity, Rev. 2, dated February 25, 2002
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-D-5, Notification of Unusual Events: Implementing Procedure for a Facility Air Monitor Alarm (FAM Ch#2), Rev. 1, dated September 14, 1995
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-D-6, Notification of Unusual Events: Implementing Procedure for a Xe-125 Monitor Alarm, Rev. 0, dated May 10, 2000
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-E-1, Alerts:
Implementing Procedure for an Unisolable Pool Leak, Rev. 1, dated September 14, 1995
NSC SOP, Chapter IX, Emergency Preparedness, Section IX-E-2, Alerts:
Implementing Procedure for a Xe-125 Monitor Alarm, Rev. 0, dated May 10, 2000
annual training records for the College Station Fire Department, the Texas A&M Environmental Health and Safety Department, and the College Station Medical Center
offsite support and annual reconfirmation of letters of agreement between NSC and the College Station Fire Department and the College Station Medical Center
emergency drills and exercises for 2003 and 2004
emergency response facilities, supplies, equipment and instrumentation
RSB meeting minutes from 2003 through the present
Texas A&M University NSC 2002 Annual Report, dated March 31, 2003, and Texas A&M University NSC 2003 Annual Report, dated March 26, 2004
summaries of annual emergency drills written by Jim Remlinger, dated December 17, 2003 and October 1, 2004
summary of emergency biennial drill involving off-site participation written by Jim Remlinger, dated December 7, 2004
Radiation Safety Board Emergency Plan Audits, dated June 23, 2003 and February 8, 2005 b.
Observations and Findings (1) Emergency Preparedness Program The E-Plan in use at the reactor and emergency facilities was the same as the version most recently submitted to the NRC. The licensee staff and the RSB audited and reviewed the E-Plan and Implementing procedures to effectively execute the E-Plan at least annually, except as noted below.
-16-Through records review, and interviews with licensee personnel, the inspectors determined that emergency responders were knowledgeable of the proper actions to take in case of an emergency. Agreements with outside response organizations had been updated and maintained as necessary. Communications capabilities with these support groups were tested during the biennial off-site drill December 3, 2004 and were acceptable.
Emergency facilities, instrumentation, and equipment were being maintained and inventoried as required by E-Plan Sections 10.4 and 10.5. To ensure appropriate emergency response personnel are notified in the event of an emergency, the emergency notification roster was updated and verified quarterly as required by E-Plan Section 8.5.
The inspectors reviewed documentation of the latest off-site emergency response drill. The biennial drill required by the E-Plan had been conducted on December 3, 2004. The drill was conducted to test the existing alarms system.
Various local law enforcement agencies participated in the drill. A critique was held following the drill to discuss the strengths and weaknesses identified during the exercise and to develop possible solutions to any problems identified. The results of the critique were documented.
The inspectors verified that emergency preparedness and response training was being completed as required and that training for off-site and reactor staff personnel was conducted and documented as stipulated by the E-Plan except as noted below.
(2) Emergency Plan Audits Section 6.2.4(d) of the Technical Specifications requires that the Radiation Safety Board conduct audits of the reactor facility emergency plan and implementing procedures at least once per calender year, interval not exceed 15 months The inspectors reviewed the Emergency Plan Audits conducted by a member of the Radiation Safety Board. The audits for the emergency plans were conducted 19 months apart on June 20, 2003 and February 8, 2005. While conducting the audits, the licensee did not discover the apparent violation of the Technical Specifications. The licensee plans to use the new planning calendar to help prevent any future occurrences of this type.
The licensee was informed that failure to audit the emergency plan at least once per calender year (interval not to exceed 15 months) was identified as an URI pending corrective actions and implementation of controls to prevent recurrence.
This issue will be reviewed during a future inspection (URI 50-128/2005-201-04).
(3) Emergency Response Training 10 CFR 50.54(q) states that a licensee authorized to possess and/or operate a research reactor or a fuel facility shall follow and maintain in effect emergency plans which meet the requirements in appendix E to this part. The Texas A&M
-17-University TRIGA Reactor Emergency Plan requires training be conducted for the College Station Medical Center on an annual basis.
The inspectors reviewed the emergency training conducted by the licensee for the College Station Medical Center. The training for the medical center staff was conducted 27 months apart on January 18, 2001 and April 21, 2003. While conducting the emergency plan audit on June 20, 2003, the licensee did discover the violation of the emergency plan requirement. In corrective actions for this audit item, the licensee planned to conduct additional training sometime in the fall of 2003. Further investigation revealed that the licensee did not conduct this training in the fall of 2003. The licensee plans to use the new planning calendar to help prevent any future occurrences of this type.
The licensee was informed that failure to conduct training for the College Station Medical Center annually was identified as a URI pending corrective actions and implementation of controls to prevent recurrence. This issue will be reviewed during a future inspection (URI 50-128/2005-201-05).
c.
Conclusions The emergency preparedness program was generally conducted in accordance with the Emergency Plan. One URI was identified involving the failure to audit the emergency plan and implementing procedures during an interval not to exceed 15 months. A separate URI was identified involving the failure to conduct training for the College Station Medical Center on an annual basis.
10. Exit Interview The inspection scope and results were summarized on February 17, 2005, with licensee representatives. The inspectors discussed the findings for each area reviewed. The licensee acknowledged the findings and did not offer any dissenting comments.
Following a review by the NRC of the issues involved in this inspection, a second Exit Interview was held by telephone on March 22, 2005, with licensee representatives. The NRC summarized and characterized the findings noted during the inspection. The licensee acknowledged the findings and did not offer any dissenting comments.
PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel T. Fisher Supervisor, Reactor Maintenance A. Heinrich Senior Reactor Operator J. Hernandez Reactor Operator D. Reece Director, Nuclear Science Center J. Remlinger Manager, Reactor Operations B. Smith Reactor Supervisor L. Vasudevan Radiation Safety Officer Other Personnel A. Moore Centrex Radio Supervisor, University Telecommunications, Physical Plant, Texas A&M University E. Schneider Interim Director, Police Department, Texas A&M University R. Zalobny Lieutenant, College Station Fire Department INSPECTION PROCEDURES USED IP 69001:
Class II Non-Power Reactors IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-128/2005-201-01 VIO The licensee allowed an individual to direct licensed activities of other licensed operators without possessing a senior operator license (his license had expired).
50-128/2005-201-02 URI Failure to conduct audits of the operator requalification program within the 15 month time frame stipulated by the TS.
50-128/2005-201-03 URI Failure to list the information for all shutdowns and scrams that occurred during 2003 in the 2003 Annual Report as required by TS Section 6.6.1.c).
50-128/2005-201-04 URI Failure to conduct audits of the emergency plan within the 15 month time frame stipulated by the TS.
50-128/2005-201-05 URI Failure to conduct annual training for the College Station Medical Center Staff as required.
Closed None
-2-LIST OF ACRONYMS USED ALARA As low as reasonably achievable CFR Code of Federal Regulations E-Plan Emergency Plan FBI Federal Bureau of Investigation IP Inspection Procedure LCO Limiting Condition for Operations NCV Non-Cited Violation NSC Nuclear Science Center NRC Nuclear Regulatory Commission RSB Reactor Safety Board RTR Research and Test Reactor RO Reactor Operators SOP Standard Operating Procedure SRO Senior Reactor Operator TAMU Texas A&M University TEES Texas Engineering Experiment Station TS Technical Specifications VIO Violation