IR 05000170/2021202
| ML21202A433 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 08/24/2021 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Cook A US Dept of Defense, Armed Forces Radiobiology Research Institute |
| O'Bryan P | |
| References | |
| IR 2021202 | |
| Download: ML21202A433 (12) | |
Text
August 24, 2021
SUBJECT:
ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000170/2021202
Dear Mr. Cook:
From July 12 - 14, 2021, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Armed Forces Radiobiology Research Institute (AFRRI) reactor facility. The enclosed report documents the inspection results which were discussed on July 14, 2021, with you and AFRRI staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV, non-cited violation of NRC regulatory requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The violation is described in detail in the enclosed inspection report.
In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Mr. Phil OBryan at 301-415-0266, or by electronic mail at Phil.OBryan@nrc.gov.
Sincerely, Signed by Tate, Travis on 08/24/21 Travis Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-170 License No. R-84 Enclosure:
As stated cc: See next page
Armed Forces Radiobiology Research Institute Docket No. 50-170 cc:
Director, Maryland Office of Planning 301 West Preston Street Baltimore, MD 21201 Montgomery County Executive 101 Monroe Street, 2nd Floor Rockville, MD 20850 Environmental Program Manager III Radiological Health Program Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd., Suite 750 Baltimore, MD 21230-1724 Director Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd., Suite 710 Baltimore, MD 21230 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Manager Nuclear Programs Maryland Department of Natural Resources Tawes B-3 Annapolis, MD 21401 Colonel Mohammad Naeem, Director Armed Forces Radiobiology Research Institute 4301 Jones Bridge Road Bethesda, MD 20814
ML21202A433 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME POBryan NParker TTate DATE 07/26/2021 07/28/2021 08/24/2021
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-170 License No.: R-84 Report No.: 05000170/2021202 Licensee: Armed Forces Radiobiology Research Institute Facility: Armed Forces Radiobiology Research Institute TRIGA Reactor Location: Bethesda, MD Dates: July 12 - 14, 2021 Inspector: Phil OBryan Approved by: Travis Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure
EXECUTIVE SUMMARY Armed Forces Radiobiology Research Institute Research Reactor Facility NRC Inspection Report No. 05000170/2021202 The primary focus of this routine, announced inspection included the onsite review of selected aspects of the Armed Forces Radiobiology Research Institute (AFRRI, the licensee) research reactor facility safety programs, including: (1) organization and staffing; (2) operations logs and records; (3) requalification training; (4) surveillance and limiting conditions for operation (LCO);
(5) emergency planning; (6) maintenance logs and records; and (7) fuel handling logs and records. The U.S. Nuclear Regulatory Commission (NRC) staff determined that the licensees programs were acceptably directed toward the protection of public health and safety, and generally in compliance with NRC requirements.
Organization and Staffing As noted in section 1, AFRRI does not have a licensed reactor operator and, therefore, is currently unable to meet Technical Specification (TS) 6.1.3 requirements for organization and staffing. However, AFRRI maintains the reactor shutdown and has submitted a proposal for staff licensing to the NRC and is awaiting approval.
Operations Logs and Records Operational activities were consistent with the applicable TS and facility procedures.
However, AFRRI has suspended reactor operations pending licensing of reactor operators.
Requalification Training There are currently no licensed reactor operators at AFRRI. Training for the most recently qualified reactor operator complied with the AFRRI requalification plan.
Surveillance and Limiting Conditions for Operation All surveillances were completed in accordance with TS 4.0 and the licensee complied with LCOs as specified in TS 3.0.
Emergency Planning The emergency preparedness program was conducted in accordance with the AFRRI emergency plan (EP).
Maintenance Logs and Records Maintenance activities were conducted in accordance with the applicable facility procedures.
Fuel Handling Logs and Records Fuel handling and inspection activities were completed and documented as required by the TS and facility procedures.
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REPORT DETAILS Summary of Facility Status The AFRRI 1.1 megawatt Training, Research, Isotopes, General Atomics (TRIGA) Mark F research reactor, located on the campus of the National Naval Medical Center, normally operates in support of the licensees mission of research, experiments, education, reactor operator training and periodic equipment surveillance. However, since March of 2018, the reactor has been shut down pending a reactor console modification.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001.02.01)
To verify that the licensees organization and staffing were in accordance with AFRRI TS 6.1, the inspector reviewed selected aspects of the following:
organizational structure management responsibilities staffing requirements for safe operation of the research reactor facility reactor Logbooks b. Observations and Findings (1) Observations.
The inspector found that the licensee maintains the reactor shutdown and has not operated the reactor since March 2018. The inspector found that the licensee currently has sufficient staff to perform routine maintenance while the reactor is shutdown, but, as described below, they do not meet TS requirements (TS 6.1.3) due to there being no current or former licensed reactor operators on the full-time AFRRI staff.
(2) Non-Cited Violation 50-170/2021202-01, AFRRI Does Not Meet Staffing Requirements of Technical Specification 6.1.3.
AFRRI TS 6.1.3.1.b, Reactor Facility Director, requires that the Reactor Facility Director (RFD) shall have held a USNRC Senior Reactor Operator License on the AFRRI reactor for at least one year before appointment to this position. TS 6.1.3.1.c, Reactor Operations Supervisor, requires that the Reactor Operations Supervisor shall have one year of experience as a USNRC licensed Senior Reactor Operator at AFRRI or at a similar facility before the appointment to this position.
Contrary to these requirements, the current interim AFRRI RFD has not been licensed at AFRRI and the Reactor Operations Supervisor position is vacant.
The inspector found that the licensees current organizational structure and assignment responsibilities did not meet the TS requirements (TS 6.1.3) due, in part, to a recent unexpected departure of the facilitys RFD and only licensed operator. The departure left AFRRI with no-3-
licensed, or previously licensed, reactor operators. Thus, AFRRI is unable to meet the TS requirements for the RFD or Reactor Operations Supervisor. An interim RFD, who has been licensed as Senior Reactor Operator at another research reactor, has been appointed. The Reactor Operations Supervisor position is vacant. However, a retired, previously licensed Senior Reactor Operator at AFFRI has be contracted on a part-time basis to assist in reactor oversight. AFRRI is also pursuing NRC approval of an alternate qualification plan for several individuals as a permanent corrective action. Therefore, the licensee is credited with identification and formulation of adequate corrective actions for this issue. Since the issue is not repetitive or willful, it is being dispositioned as a non-cited violation in accordance with section 2.3.2.b of the NRC Enforcement Policy. This is a Severity Level IV non-cited violation (Section 6.1) and is designated NCV 50-170/2021202-01.
c. Conclusion The inspector found that the licensee is in the process of filling TS required positions and is pursuing NRC approval for an alternate licensing plan for personnel.
2. Operations Logs and Records a. Inspection Scope (IP 69001.02.02)
The inspector reviewed selected aspects of the following to verify compliance with TS 2.0, 3.0, and 6.0 and applicable procedure requirements for operation:
reactor logbooks AFRRI weekly shutdown checklists b. Observations and Findings The inspector found that logs and records showed that reactor parameters were consistent with license and TS requirements. The inspector verified that information on the reactor status was recorded in logbooks and on checklists as required by procedure.
c. Conclusion The inspector found that activities were consistent with the applicable TS and procedural requirements.
3. Requalification Training a. Inspection Scope (IP 69001.02.04)
To verify that the licensee was complying with the requirements of the operator requalification program, the inspector reviewed selected aspects of:
Reactor Operator Requalification Program for the Armed Forces-4-
Radiobiology Research Institute TRIGA Reactor Facility operator training records maintained on Requalification Program Checklist, forms in individual folders for former operators medical examination records for former operators b. Observations and Findings The inspector found that there are currently no licensed operators at AFRRI. The inspector verified that the most recently licensed former staff member met requalification requirements when he was on staff.
c. Conclusion The inspector found that operator requalification requirements were met when AFRRI had at least one licensed operator on staff.
4. Surveillance and Limiting Conditions for Operation a. Inspection Scope (IP 69001.02.05)
To determine that LCOs were met and surveillances were completed as required by TS 3.0 and 4.0, the inspector reviewed selected aspects of the following:
malfunction log reactor logbooks weekly shutdown checklists calibration procedures for the AFRRI reactor facility maintenance procedures for the AFRRI reactor facility TRIGA Tracker TS surveillance reports b. Observations and Findings The inspector found that TS required surveillance and LCO requirements were met. The inspector observed the performance of a weekly shutdown checklist, which is used to perform most surveillances while the reactor is in long-term shutdown. The inspector verified that AFRRI properly deferred most surveillances, as allowed by TS, since the reactor was in long-term shutdown.
The inspector reviewed a random sampling of operational logs and records and determined that they met the required LCOs. The inspector verified that the licensee utilizes a computer database, the TRIGA Tracker, to track completion of the various required surveillance and LCO verifications. The inspector performed a random sampling of the database to ensure that there were no overdue requirements and cross-referenced the applicable TS to ensure all required surveillances were accounted for in the TRIGA Tracker Report.
c. Conclusion The inspector found that all surveillances were completed in accordance with TS 4.0 and the licensee was in compliance with the LCO requirements in TS 3.0.
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5. Emergency Planning a. Inspection Scope (IP 69001.02.10)
The inspector reviewed the implementation of selected portions of the emergency preparedness program, including:
AFRRI EP AFRRI emergency drills since 2019 AFRRI emergency supplies AFRRI Emergency Response Guidebook (ERG)
b. Observations and Findings The inspector found that EP training was conducted, drills were performed, emergency response call lists were maintained and posted, and emergency equipment was maintained and available as required by the EP and licensee procedures.
The inspector found that the ERG was recently updated and that the concern noted in Inspector Follow-up Item (IFI)05000170/2019201-01, AFRRI ERG, dated April 1996, contains outdated information and needs to be updated, was resolved. This IFI is closed.
The inspector also found that the concern noted in IFI 05000170/2019201-02, Review the impact of the N parking lot construction to AFRRIs emergency evacuation routes and muster locations as referenced on page A-3 of the AFRRI ERG, was also properly addressed and adequate evacuation routes and muster locations existed. This IFI is closed.
c. Conclusion The inspector found that emergency planning was conducted in accordance with the AFRRI EP.
6. Maintenance Logs and Records a. Inspection Scope (IP 69001.02.11)
To determine that maintenance was completed as required by the TS and applicable procedures, the inspector reviewed:
AFRRI malfunction log reactor logbooks maintenance procedures for the AFRRI reactor facility TRIGA Tracker report shutdown maintenance checklists b. Observations and Findings The inspector verified maintenance requirements were met. The inspector found-6-
that routine and preventive maintenance activities were adequately performed and documented in the TRIGA tracking system. The inspector confirmed that use of maintenance and malfunction logs satisfied procedural requirements.
c. Conclusion The inspector found that maintenance activities were conducted in accordance with the applicable procedures and were acceptable.
7. Fuel Handling Logs and Records a. Inspection Scope (IP 69001.02.12)
The inspector reviewed the following to verify compliance with the procedural requirements in TS 6.3.e:
AFRRI fuel element logbook control room reactor fuel inventory map reactor logbooks b. Observations and Findings The inspector noted that AFRRI maintains a current inventory record of fuel elements and information such as serial number, core position, and power history are maintained and tracked. The inspector also verified that all fuel element locations, depicted on the control room reactor fuel inventory map, matched the information recorded in the fuel element logbook.
c. Conclusion The inspector found that fuel handling and inspection activities were completed and documented as required by the TS and facility procedures.
8. Exit Interview The inspector presented the inspection results to licensee management at the conclusion of the inspection on July 14, 2021. The inspector described the areas inspected and discussed the inspection observations. The licensee acknowledged the findings presented and did not identify any of the material provided to or reviewed by the inspector as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel M. Naeem Director, AFRRI (Colonel, U.S. Army) Interim Reactor Facility Director (SRO)
H. Spence Records Administration Specialist B. Knibbe Operations INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed NCV 05000170/2021202-01 AFRRI Does Not Meet Staffing Requirements of Technical Specification 6.1.3 Closed IFI 05000170/2019201-01 The AFRRI ERG, dated April 1996, contains outdated information and needs to be updated.
IFI 05000170/2019201-02 Review the impact of the N parking lot construction to AFRRIs emergency evacuation routes and muster locations as referenced on page A-3 of the AFRRI ERG.
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