IR 05000170/1990001
| ML20012E529 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 03/08/1990 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012E527 | List: |
| References | |
| 50-170-90-01, 50-170-90-1, NUDOCS 9004050342 | |
| Download: ML20012E529 (9) | |
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i U. S. NUCLEAR REGULATORY COMMISSION
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REGION I
Docket / Report No.: 50-170/90-01 l
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License No.:
R-84
Licensee:
Armed Forces Radiobiology Research Institute
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Bethesda, Maryland 20014 Facility Name:
Armed Forces Radiobiology Research Institute Inspection at:
Bethesda, Maryland i
Dates:
February 20-22, 1990 Inspector:
P. D. Kaufman, Project Engineer Approved By:
M 7-'8 "' P o 64. L. T. DoerflMn, Chief Date
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Reactor Projects Section 28 Division of Reactor Projects
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Summary:
Inspection on February 20-22, 1990 (Inspection Report
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No. 50-170/9F01)
Areas Inspected:
A routine announced safety inspection (21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />) by a region-based inspector of licensee's facility operations, actions on previous NRC findings, logs and records, operator requalification training program, experiments, and reporting.
Results: The inspector concluded that the reactor was being operated safely.
Fne unresolved item was identified in the area of operator requalification I
training (Section 6.0).
Although no violations were identified, there is a concern that when changes are made to Title 10 of the Code of Federal Regulations, adequate reviews are not being performed on a timely basis as noted in Section-6.0 and 8.0.
Licensee evaluations of the changes to Title 10 should be assessed sooner to determine the impact on the AFRRI facility (Technical Specifications (TS), procedures and programs).
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9004050342 900323 PDR ADOCK 05000r70 Q
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Details 1.0 Persons Contacted
i 1.1 Armed Forces Radiobiology Research Institute
- Col. G. W. Irving, III Director, AFRRI
- M. Moore Director, Reactor Facility
- Capt. C. Galley Chairman, Radiation Sources Department
- Lt. Col. A. Webb Head LINAC Division
- T. Wright Nuclear Engineer, Reactor Division
- First Lt. M Forsbacka Senior Reactor Operator Trainee
- W. Ting Senior Reactor Operator
- D. Ashby Chairman, SHD
- T. O'Brien Radiation Protection Officer, SHD Interviews and discussions were conducted with other members of the licensee staff during the inspection period.
1.2 U.S. Nuclear Regulatory Commission
- S. Weiss Project Director, PDNP
- A. Adams Project Manager, PDNP
- Denotes attendance at the exit interview conducted on February 22, 1990.
2.0 Licensee Action on Previous Inspection Findings (Closed) Violation (170/88-04-01):
Failure to Perform Safety Reviews.
Changes had been made to the AFRRI facility without performing written L
safety evaluations. The licensee has completed 10 CFR 50.59 reviews on l
both the digital voltmeter and Cerenkov detector and concluded no un-l reviewed safety question existed.
In addition, a procedure was developed specifically addressing facility modifications. The inspector reviewed the safety evaluations dated February 13, 1989 and found the licensee's I
findings acceptable.
(Closed) Violation (170/88-04-03):
Failure to Adhere to Procedural Requirements.
Based on procedural implementation observation by the inspector, as
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discussed in Section 4, 5, and 6 of this report, no deficiencies were
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identified with respect to procedural adherence.
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L (0 pen) Unresolved item (170/88-04-04): Adequacy and Appropriateness of
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i the Safety Evaluation for the New Reactor Console.
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The NRC Office of Nuclear Reactor Regulation (NRR) is in the process of reviewing the licensee's submittal on the new console.
This item will i
remain open pending NRR's acceptance and issuance of a Safety Evaluation Report (SER),
(0 pen) Unresolved item (170/88-04-05):
Clarification of Reactor
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Operations Supervisor Responsibilities.
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The proposed Section 6.1.2 Technical Specification change to clarify lines of responsibilities has not been reviewed by the licensee's Reactor and Radiation Facility Safety Committee (RRFSC). This item will remain open pending acceptance of the proposed change by the RRFSC and the technical specification change by the NRC.
(Closed) Violation (170/88-04-06):
Failure to Perform Operator Requalification Training Lectures and Ensure Proper Attendance at Required Lectures.
The three operators who missed certain requal lectures were subsequently given the required lectures.
The inspector reviewed the operator requal files to verify that the missed lectures were made-up and adequately completed.. The inspector also examined the recently developed tracking system for documenting and making individual operators accountable for documentation of requal training received. The new tracking method appears to be effective and more efficient. The six licensed SRO requal files were reviewed and found to be acceptable.
Further, it was easy to ascertain the training status of each operator.
(Closed) Unresolved Item (170/88-04-07): Omissions of Uncompleted Requalificatiot; Training Not Noted On NRC Form 398s for Licensee Renewals Associated with Three Licensed Operators.
Based on the 01 synopsis which is attached to this report, this item is considered resolved.
3.0 Operations Review (40750)
Facility Tour l
The inspector met with the AFRRI Director upon arrival on site to discuss i
the scope and purpose of the inspection. A tour of the facility was
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conducted immediately thereafter in company with the Facility Director.
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Subsequently, additional tours of the facility were conducted throughout the inspection period in company with licensee personnel.
Observation L
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tours included the following areas of the facility: Control Room, Reactor Room, Emergency Response Center, Upper & Lower Equipment Rooms,
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Exposure Room No. 1, Prep Area, and Warm Storage Room.
In general, the
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material condition of the facility was satisfactory. Housekeeping was
good. The inspector noted a small leak, which was corrected immediately, t
from a pressure guage located on the primary pump discharge line located i
on the second floor of the Equipment Room.
Required notices were
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properly posted.
The inspector identified several Form NRC-3s, " Notice
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to Employees," which did not have the new address for the Region I Office. However, the postings were in accordance with 10 CFR 19.11 requirements. The licensee has since replaced the old forms with current ones.
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The inspector observed the licensee conducting a surveillance audit on the inventory of material contained in the emergency box located in the Emergency Response Center. The audit consisted of a checklist of items required to be maintained in the box.
The audit was found to be
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acceptable and within the required surveillance interval, i
4.0 Facility Operations The facility is used primarily to conduct experimental biomedical research and to produce isotopes in support of the Department of Defense and the military services. The reactor is also used to train military personnel in reactor operations.
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Currently the licensee operates the reactor with a staff of six licensed Senior Reactor Operators (SR0s). The reactor is normally operated from 6:00 a.m. to 4:00 p.m. daily Monday through Friday. However, Wednesdays are set aside for operator training, including requalification lectures, that are held the third Wednesday of each month.
The inspector observed the startup and shutdown of the TRIGA reactor by an SRO trainee. While the trainee was manipulating the reactor console controls he was under the direct supervision of a licensed SRO.
The inspector judged the activity to be well controlled.
The inspector assessed the operators' communications and coordination with radiation protection personnel while performing experiments as exceptional and considered both strong aspects of the licensee's daily operations.
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The inspector concluded that facility operations, including the conduct t
of experiments, were adequately controlled in accordance with reactor operating procedures and technical specifications.
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5.0 Loos, Procedures, and Records The inspector examined a sample of logs, records, and procedures to
ensure that the licensee's administrative controls are properly conducted as required by Technical Specification Section 6.0, Administrative
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Requirements and ANS-15.8, Quality Assurance Program Requirements for l
Research Reactors.
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The control room operator's console Reactor Log Books Nos. 88, 89, and 90 as well as the Malfunction Log were reviewed for the period May 1989 through February 21, 1990.
The purpose of the review was to identify any events which might be reportable, to determine types of operations, and to ensure required information was recorded, signed, and audited. The inspector noted a discrepancy between the Reactor Log and Malfunction Log for January 23, 1990. The Malfunction Log described a problem associated with a printer ribbon on the Gas Stack Monitor (GSA).
However, the Reactor Log contained no specific entry about the GSA problem.
The inspector informed the licensee of this documentation inaccuracy.
The two logs were not yet due for routine audit by the Facility Director for this particular calendar quarter. The inspector had no further questions.
Reactor operator requalification training documentation records were reviewed as described in Section 6.0.
t The inspector witnessed the implementation of the following Reactor Operating Procedures (ROP)"
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R0P I,
" Conduct of Experiments" TAB A - Exposure Room Entry
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TAB B - Core Experiment Tube TAB C - Extractor System R0P VIII
" Reactor Operations" TAB A - Logbook Entry Checklist TAB B - Daily Operational Start-up Checklist TAB E - Steady State Operation (Mode I/IA)
TAB I - Daily Operational Shut-down Checklist The observed activities were accomplished in accordance with the above approved procedures. No unacceptable conditions were identified.
6.0 Requalification Training of Reactor Operators A review of the Reactor Operator Requalification Program was conducted to
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t ensure that it contained the eierrents required by 10 CFR Part 55.
The current requal program was approved by the NRC on October 31, 1989.
The licensee implemented the approved requal program in January 1990.
Upon examination of the requal program which is defined in Reactor Operator Requalification Program for the AFRRI TRIGA Reactor Facility, the
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inspector noted inconsistencies between the requal program, 10 CFR 55.59, p
and Technical Specifications with respect to the record retention require-
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ments for requalification training records. Currently the licensee's Technical Specification Section 6.7.2 and the requal program only require that requalification training records be retained for one complete two-year requalification training cycle.
10 CFR 55.59 (c)(5)(1) requires that these records be retained until the operator's license is renewed.
The currently approved requal program needs to be revised to eliminate this inconsistency with 10 CFR 55.59(c)(5)(1).
This item is considered an Unresolved Item (90-01-01) pending correction of this error.
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The inspector conducted a review of licensed operator requalification training records for the six operators currently holding Senior Reactor
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Operator licenses at the facility.
The operator training files contained documents for the last requal cycle between January 1,1988 and December 31, 1989 and the current cycle. The files consisted of the operator's license, graded written examination, requal training checklist, medical evaluation record, memorandum for training record, evaluation of oral /
reactor console examination, summary of strengths and weaknesses, progress checklist, quarterly operating requirements form, and lecture attendance form.
It appears that the licensee's improvements relative to the requal program documentation tracking method and personal accountability has
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been effective in resolving the identified deficiencies in NRC Inspection Report 50-170/88-04.
The inspector ascertained that the required records were being maintained adequately and no inadequacies were identified.
The inspector attended the requalification lecture, Radiation Control and Safety, and observed the individuals signing the Lecture Logbook denoting attendance at the required lecture. The lecture was found to be informative and conducted in a professional manner. The lecture was also being videotaped by the licensee.
The new approved requal program permits an operator who missed the original lecture to view the video as a make-up class process.
7.0 Experiments The inspector reviewed selected experiments conducted by the licensee by observation of on going reactor operation activities. The inspector
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observed animal science studies being conducted in exposure room 1 using the extractor tube system, which permits the quick insertion and withdrawl of samples.
The ability to quickly retrieve samples from the exposure room results in precision evaluations of radiation dose received by the samples. The experiment was performed using the steady-state mode of operations per procedure R0P VIII.
The inspector also observed an experiment conducted for the FBI.
The sample material being analyzed was loaded into the Core Experiment Tube and placed directly into the reactor core.
Neutron activation analysis is used to analyze the material.
The inspector observed a Health Physics technician taking radiation q
survey readings of the samples upon completion of the experiments.
The inspector examined the Activated Materials Log and Reactor Use Request forms for these experiments to ensure that the proper review, approval, and release of items was accomplished in accordance with licensee procedures.
No unacceptable conditions were identified. The inspector concluded that the experiments cnd irradiated materials were properly controlled.
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Reporting The inspector discussed with the licensee an event which occurred on January 26, 1990, involving the ventilation system reactor room sealing dampers. The licensee reported the event to Region I by telephone on January 30, 1990.
Subsequently, the licensee issued a Licensee Event Report dated February 7, 1990, addressed to the NRC Region I Office
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instead of the NRC Document Control Desk, i
The inspector informed the licensee of the January 5,1987 final rule, i
10 CFR 50.4 regarding written communications. Under the rule change, the l
licensee shall send the signed original of all Part 50 submittals to the NRC Document Control Desk with copies to the appropriate Regional Office and Resident Inspector.
The inspector requested that the licensee review their Part 50 submittals back to January 5,1987, determine which documents are affected, and submit those documents per the rule requirements.
The inspector noted that communication procedure changes were not being incorporated by the licensee into their technical specifications. AFRRI's Technical Specifications are currently being amended to reflect the 10 CFR Part 50.4 requirements.
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' 9.0 Unresolved Items i
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Unresolved items are items about which more information is required to
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ascertain whether they are acceptable, a violations, or deviations, t
Unresolved Items are discussed in section 6.0.
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10.0' Exit' Interview (
l The-inspector met with licensee representatives (denoted in paragraph 1)
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at the conclusion of the inspection on February 22, 1990. The inspector presented the preliminary findings of this inspection.
The licensee acknowledged the findings and indicated that corrective actions would be t
taken where appropriate.
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ENCLOSURE 2
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SYNOPSIS OnNovember4,1988,theOfficeofInvestigations(01),wasrequestedbythe Regional Administrator (RA)Ia,egion I, Nuclear Regulatory Comission (NRC R
King of Prussia Pennsylvan to initiate an investigation at the Armed ForcesRadiobiologyResearchInstitute(AFRRI)ReactorFacility,Bethesda, Maryland,leted by the AFRRI licensed operators; and (2) if NRC Form 398 to determine:
been comp been certified by AFRRI management personnel knowing that they contained false infonnation.
On October 27, 1988, the NRC conducted an inspection at AFRRI that resulted in a potential violation in the Licensed Operator Training Program at the AFRRI Facility. Specifically, en NRC Inspector upon reviewing a sample of licensed operator training records, and after discussions with the AFRRI Training Coordinator, observed that three of the five operators training records sampled indicated that the operators had not completed the required requalification training. Also,licenserenewalapplications(NRCForm398)
for those operators who had not completed requalification training had been certified by the Training Coordinator and Reactor Facility Director as having met requirements of the requalification program. When questioned, the Training Coordinator advised OI that several required requalification lectures were cancelled and few were ever rescheduled. He denied that he intentionally falsified any NRC Form 398s.
A former reactor operator advised O! that several required requalification l
1ectures were cancelled and never rescheduled. He also said that he I
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approached the Reactor Facility Director concerning the matter and was told to conduct the training during non-duty hours.
Four of the reactor operators advised 01 that many of the requalification lectures had been cancelled and few were ever rescheduled. Two of the reactor operators could not recall any lectures being cancelled. However, they all denied that they had falsified their NRC Form 398.
When questioned, the Reactor Facility Director, denied that any of the
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requalification lectures were cancelled. He additionally denied falsifying
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any NRC Form 398.
It is concluded that due to careless disregard for NRC regulations by the
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Training Coordinator and the Reactor Facility Director, the required requalification lectures were not completed, thereby causing incorrect
information to be submitted to the NRC on the NRC Form 398s. Also, it is concluded that there is insufficient evidence to determine if the Training Coordinator and the Reactor Facility Director, certified the NRC Form 398s knowing that they contained false information.
Case No. 1-88-019
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