IR 05000184/2013202

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IR 05000184-13-202, on November 18-22, 2013 at the National Institute of Standards and Technology-NRC Routine Inspection Report
ML13336A631
Person / Time
Site: National Bureau of Standards Reactor
Issue date: 12/05/2013
From: Gregory Bowman
Research and Test Reactors Licensing Branch
To: Dimeo R
US Dept of Commerce, National Institute of Standards & Technology (NIST)
Bassett C
References
IR-13-202
Download: ML13336A631 (25)
v • d • e


Text

ber 5, 2013

SUBJECT:

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY - NRC ROUTINE INSPECTION REPORT NO. 50-184/2013-202

Dear Dr. Dimeo:

From November 18 to 22, 2013, the U.S. Nuclear Regulatory Commission (NRC or the Commission) conducted an inspection at the National Institute of Standards and Technology Center for Neutron Research facility (Inspection Report No. 50-184/2012-204). The inspection included a review of activities authorized for your facility. The enclosed report documents the inspection results, which were discussed on November 21, 2013, with Sean OKelly, Chief, Reactor Operations and Engineering and various other members of your staff, and on November 22, 2013, with Dan Hughes, Chief, Reactor Operations.

This 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 observed various activities in progress, interviewed personnel, and reviewed selected procedures and representative records.

Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements has occurred. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2.b of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, and 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 NRCs document system (Agencywide Document 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). Should you have any questions concerning this inspection, please contact Craig Bassett at (301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA P. Isaac Acting for/

Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-184 License No. TR-5 Enclosure:

NRC Inspection Report No. 50-184/2013-202 cc: See next page

National Institute of Standards and Technology Docket No. 50-184 cc:

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, Department of State Planning 301 West Preston Street Baltimore, MD 21201 Director, Air & Radiation Management Adm.

Maryland Dept of the Environment 1800 Washington Blvd., Suite 710 Baltimore, MD 21230 Director, Department of Natural Resources Power Plant Siting Program Energy and Coastal Zone Administration Tawes State Office Building Annapolis, MD 21401 President Montgomery County Council 100 Maryland Avenue Rockville, MD 20850 Dr. David Sean OKelly, Chief Reactor Operations and Engineering NIST Center for Neutron Research National Institute of Standards and Technology U.S. Department of Commerce 100 Bureau Drive, Mail Stop 8561 Gaithersburg, MD 20899-8561 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML13336A631 * concurrence via e-mail NRC-002 OFFICE NRR/DPR/PROB NRR/DPR/PROB NAME CBassett* P. Isaac for GBowman DATE 12/ 5 /2013 12/ 5 /2013

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-184 License No: TR-5 Report No: 50-184/2013-202 Licensee: National Institute of Standards and Technology (NIST)

Facility: NIST Center for Neutron Research (NCNR)

NCNR National Bureau of Standards Reactor Location: Gaithersburg, MD Dates: November 18-22, 2013 Inspector: Craig Bassett Approved by: Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation ENCLOSURE

EXECUTIVE SUMMARY National Institute of Standards and Technology Center for Neutron Research National Bureau of Standards Reactor NRC Inspection Report No. 50-184/2013-202 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the National Institute of Standards and Technology (the licensees) Class I 20 megawatt test reactor facility safety program including: (1) organization and staffing, (2) review and audit and design change functions, (3) reactor operations, (4) operator requalification, (5) maintenance and surveillance, (6) fuel movement, (7) experiments, (8) procedures, and (9) emergency preparedness since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees safety program was acceptably directed toward the protection of public health and safety and was in compliance with NRC requirements. No violations or deviations were identified.

Organization and Staffing

  • Staffing levels at the facility were adequate for the current level of operations.

Review and Audit and Design Change Functions

  • The Safety Evaluation Committee was meeting as required and reviewing the topics outlined in the Technical Specifications.
  • The Safety Audit Committee was conducting annual audits as required.
  • The design change program being implemented at the facility satisfied NRC requirements.

Reactor Operations

  • Acceptable operations shift staffing was being maintained.
  • Adequate shift turnover briefings were being conducted and each operating crew was appropriately cognizant of facility conditions.

Operator Requalification

  • Operator requalification was being conducted and completed as required by the requalification program and the program was being maintained current.
  • Physical examinations for the operators were being completed every 2 years as required.

-2-Maintenance and Surveillance

  • The maintenance program was being conducted in accordance with applicable procedural requirements.
  • The surveillance program was being completed in a timely manner and as specified in the facilitys Technical Specifications.

Fuel Handling

  • Fuel movement was accomplished in accordance with Technical Specifications and procedural requirements.

Experiments

  • The program for experiment review and approval satisfied Technical Specification and procedural requirements.

Procedures

  • The procedure revision, control, and implementation program satisfied Technical Specification requirements.

Emergency Preparedness

  • The Emergency Plan and Emergency Instruction Manual (or implementing procedures) were being audited and reviewed biennially as required.
  • Drills and exercises were being held and follow-up critiques were conducted to identify corrective actions that could be taken as needed.
  • Adequate offsite emergency support was being provided by various agencies as required.

REPORT DETAILS Summary of Facility Status The National Institute of Standards and Technology (NIST or the licensee) NIST Center for Neutron Research (NCNR) reactor, a 20 megawatt test reactor commonly known as the National Bureau of Standards Reactor (NBSR), continued to be operated in support of laboratory experiments and various types of research. During the inspection the reactor was operated on a normal 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day schedule and was shutdown on Thursday evening for routine refueling and maintenance.

1. Organizational Functions and Staffing a. Inspection Scope (Inspection Procedure (IP) 69006)

To verify that the licensee was complying with the responsibilities, staffing, and training requirements specified in NBSR Technical Specification (TS) Section 6.1, Organization, the inspector reviewed selected aspects of the following:

  • Current NBSR organization and staffing
  • NBSR Console Logbooks Nos. 144 through 148
  • Qualifications of various management and supervisory personnel
  • Execution of management and staff responsibilities outlined in the TS
  • NBSR Administrative Rules (AR) 1.0, Responsibilities of Operations Personnel, issued July 30, 2009
  • NBSR AR 2.0, Personnel Requirements, issued July 30, 2009 b. Observations and Findings Through discussions with licensee personnel and review of pertinent documents, the inspector determined that the licensees organizational structure had not changed since the last inspection in the area of reactor operations (refer to NRC Inspection Report No. 50-184/2012-204) and that the organizational structure remained consistent with the requirements of TS Section 6.1 and Figure 6.1. The inspector also found that the various management and supervisory personnel in the Reactor Operations Group exceeded the minimum qualifications specified in the TS with regard to education and experience.

In discussing staffing with management personnel, the inspector noted that there were 20 qualified senior reactor operators (SROs) at the facility who were either in management positions or assigned to various operating crews. Through interviews with operations personnel, the inspector determined that there were four operating crews at the facility who worked rotating shifts. Additionally, there was a fifth day shift crew that typically only worked during the weekdays, but also provided coverage on occasions when individuals from the other crews were unavailable. Each crew was typically staffed with three or four individuals who were, as noted above, licensed SROs. This provided an adequate number of operators for the current level of operations at the facility.

-2-Through a review of the console logbooks for the period from January 2013 to the present and through interviews with operations personnel, the inspector verified that staffing during routine reactor operation was as required. It was also noted that a list of reactor facility personnel by name and telephone number was available to the reactor operators in the control room and was updated at least annually as required by TS Section 6.1.3. The list was last checked and updated on June 27, 2013.

c. Conclusion The organizational structure and supervisory qualifications were consistent with TS 6.1 requirements and the operations staffing level appeared to be adequate for the current level of operations.

2. Review and Audit and Design Change Functions a. Inspection Scope (IP 69007)

The inspector reviewed the following to ensure that the requirements of TS Section 6.2, Review and Audit, and Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, were being implemented effectively:

  • Safety Evaluation Committee (SEC) meeting minutes for September 2012 through the present (Meeting Nos. 374 through 376)
  • NBSR Procedure No. NBSR-0007-DOC-04, Engineering Manual, Rev. 4 dated June 2009, which included procedures and instructions for completing changes at the facility
  • 2012 reactor audit conducted in accordance with TS 6.2.4(1-4) by the NCNR Audit Subcommittee of the SEC, dated August 28,
  • 2013 reactor audit conducted in accordance with TS 6.2.4(1-4) by the NCNR Audit subcommittee of the SEC, dated September 31, 2013
  • 2012 Annual [Audit] Report of the Safety Assessment Committee, audit conducted November 28 to December 4, 2012
  • NCNR Safety Evaluation Committee Charter, approval dated June 28, 2012
  • NBSR Engineering Change Request/Engineering Change Notice (ECR/ECN) No. 613, C-100 to G-100 Line of Sight Wall Penetrations, ECR Level II review, approval dated November 3, 2010, and ECN Level II review and approval dated June 9, 2011 (with the associated 50.59 Evaluation); implementation close out dated April 29, 2013
  • NBSR ECR/ECN No. 730, Developing a Manufacturing Procedure and Fabrication Specifications for Shim Safety Rods for NIST Reactor, ECR Level II review, approval dated June 12, 2012, and ECN Level II review and approval dated July 17, 2012
  • NBSR ECR/ECN No. 757, Replacement Valve for DWV-19 Located on the Suction Loop of the Primary Water System, ECR Level II review and

-3-approval dated February 12, 2013, and ECN Level II, Revision 2, review and approval dated June 17, 2013

  • NBSR ECR/ECN No. 805, Temporary Core Fuel Configuration, ECR Level I review and approval dated October 25, 2013, and ECN Level I review and approval dated October 25, 2013; implementation and close out dated October 28, 2013
  • Operations Report No. 64, NBSR Annual Report, for the period from January 1, 2011, through December 31, 2011, issued March 28, 2012
  • Operations Report No. 65, NBSR Annual Report, for the period from January 1, 2012, through December 31, 2012, issued March 28, 2013 b. Observations and Findings (1) Review and Audits Functions The inspector reviewed the charter of the SEC required by the TS. It was noted that the charter delineated the committees membership, organization, and responsibilities, as well as quorum and meeting requirements. The charter also authorized the formation of subcommittees to assist the SEC. Three subcommittees had been organized for that purpose, including the Audit Subcommittee, the Beam Experiment Subcommittee (BES), and the Irradiation Subcommittee. A charter had been developed for each subcommittee and the various charters had been reviewed and approved by the SEC.

Records of the meetings held by the SEC from September 2012 through the date of the inspection were reviewed. The meeting minutes showed that meetings were held at least semiannually as required by the SEC Charter and reviews of proposed changes and experiments were completed by the SEC or by a designated subcommittee. The minutes also indicated that the SEC provided appropriate guidance and direction for reactor operations and ensured suitable use and oversight of the reactor.

A review of audit records indicated that the Audit Subcommittee of the SEC conducted an annual audit of the safety program at the facility in accordance with TS 6.2.4. The audits were reviewed by the full SEC and licensee management responded to the subcommittees findings and recommendations and took corrective actions as needed.

Other records reviewed by the inspector showed that the Safety Assessment Committee had conducted an annual independent audit as required by TS 6.2.5. For 2012 the licensee used the audit conducted by the International Atomic Energy Agencys (IAEAs) Operations and Maintenance Assessment of Research Reactors (OMARR) mission to fulfill the requirement. Upon completion of the assessment, the OMARR representatives presented their findings to facility management and a complete formal audit report was provided in March 2013. The OMARR

-4-made various recommendations and the licensee was taking actions to address the comments made.

(2) Design Change Functions The inspector reviewed selected requests for changes to the facility (i.e.,

changes to structures, systems, or components (SSCs)) that had been proposed within the last 2 years. At NIST these change proposals were designated as Engineering Change Requests (ECRs). Each ECR documented what was proposed to be changed, the facility drawings that would need to be changed, the procedures that would require revision, and any tests or measurements that would need to be completed following the change. In order to track the change requests, they were numbered sequentially during the year. These were screened to determine whether or not a 10 CFR 50.59 review would be required.

Based on the safety significance and the 10 CFR 50.59 screen results, the changes were classified as either Level I (Minor) or Level II (Major).

All Level II ECRs required a 50.59 review which often resulted in the completion of a 50.59 evaluation.

Once an ECR was approved, indicating that the change project could move forward, an Engineering Change Notice (ECN) was developed which contained various sections. The sections detailed the design description, safety considerations and analysis, a safety evaluation, and the 10 CFR 50.59 screening criteria results.

A review of selected ECRs and ECNs demonstrated that changes were acceptably documented and reviewed in accordance with NRC requirements and the licensees guidelines and that the work and the required document revisions were being completed as necessary. It was noted that the changes were being tracked to completion by the licensee.

None of the changes reviewed by the inspector met any of the criteria of 10 CFR 50.59(c)(2), but it was noted that one was being considered that would require a TS change. Documentation of that change was being prepared to be submitted to the NRC for review and approval.

c. Conclusion The SEC was meeting as required and reviewing the topics outlined in the TSs and an independent SAC was conducting an annual audit as required. The licensees design change program satisfied NRC requirements.

-5-3. Reactor Operations a. Inspection Scope (IP 69006)

To verify that the licensee was operating the reactor and conducting operations in accordance with TS Sections 2 and 3 and procedural requirements, the inspector reviewed selected portions of the following:

  • NBSR Console Logbook Nos. 144 through 148
  • Various NIST reactor control room log sheets
  • Selected NIST reactor area inspection log sheets
  • Shift supervisors instructions and special log sheets
  • NBSR Reactor Shift Supervisor Logbook Nos. 38 and 39
  • Selected reactor operations shift turnover log notebook entries
  • Associated reactor operations records from October 2012 to the present
  • NBSR AR 2.0, Personnel Requirements, issued July 30, 2009
  • NBSR AR 9.0, Reactor Startup and Operation, issued July 30, 2009
  • Selected NBSR Operating Instructions (OIs) (i.e., operating procedures)
  • Operations Report No. 64, NBSR Annual Report, for the period from January 1, 2011, through December 31, 2011, issued March 28, 2012
  • Operations Report No. 65, NBSR Annual Report, for the period from January 1, 2012, through December 31, 2012, issued March 28, 2013 b. Observations and Findings The inspector observed reactor operations on various shifts. Operations were being conducted in accordance with facility procedures as required. The inspector reviewed various operations logs and related records. The logs and records were clear and provided an indication of ongoing activities. The records demonstrated that shift staffing during reactor operation and during maintenance periods was being maintained as required by TS 6.1.3.

The records reviewed also showed that operational conditions and parameters were consistent with TS and procedural requirements and that these conditions and requirements were satisfied. Reactor startup procedure, NBSR OI 1.1, required verification of each of the limiting conditions for operation specified in TS 3.1 through 3.11 prior to startup. These verifications were being completed and recorded as required. The inspector noted that various other procedural requirements were also being met.

Through logbook review and through direct observation, the inspector also verified that shift turnover briefings were held prior to each shift change. In addition, it was noted that activities of the previous shift, and events or job evolutions scheduled for the upcoming shift, were discussed in detail. A status board was also maintained in the Control Room. The records kept and the briefings that were given ensured that the operators were aware of the current conditions in the facility and the status of any changes being made.

-6-c. Conclusion Acceptable shift staffing was being maintained. Adequate shift turnover was being conducted and each operating crew was cognizant of facility conditions.

4. Operator Requalification a. Inspection Scope (IP 69003)

To verify compliance with the operator requalification program for the NBSR, which was last updated March 2009, the inspector reviewed:

  • NBSR Console Logbooks Nos. 144 through 148
  • Medical examination records from 2010 through 2013
  • Current status of selected qualified operators licenses
  • NBSR requalification examinations (biennial) for 2010 and 2012
  • NBSR 2012-2013 requalification program, consisting of training provided in the areas of: reactor theory, radiation protection, emergency plan and actions, Fukushima accident, safety systems, physical security, reactor systems, TS requirements, and the latest licensee-identified TS violations
  • Operator training records for the years 2011, 2012, and 2013 to date, documented on forms entitled, Requalification Program Documentation Review and Reactivity Changes, no revision date
  • Supervisors annual operator evaluations documented on forms entitled, Operator Evaluation, form revised November 2009 b. Observations and Findings As mentioned previously, there were 20 qualified SROs employed at the facility.

It was noted that one of the SROs was nearing retirement. It was also noted that one person who had recently been hired was in training to become a qualified operator. Through a review of various requalification and training documents, the inspector verified that the operators licenses were current and records of every licensed operators requalification status were being maintained as required.

A review of program records also showed that operator training was consistent with the NBSR requalification program requirements. The inspector verified that all operators had completed the requalification training and had taken the written biennial requalification examination. Additional training on various plant systems and industrial hygiene/safety was also provided. NBSR console logbooks and requalification records showed that operators maintained active duty status by participating in the reactivity manipulations and document reviews as outlined and required in the requalification program. The inspector also confirmed that the operators had been given annual operating evaluations as required.

The inspector verified that each qualified operator was receiving a biennial physical examination as well.

-7-c. Conclusion Operator requalification was being conducted and completed as required by the licensees requalification program. Physical examinations for each operator were being completed every 2 years as required.

5. Maintenance and Surveillance a. Inspection Scope (IP 69006 and IP 69010)

To ensure that maintenance activities were being completed and to determine that surveillance activities and calibrations were being completed as required by TS Section 4, the inspector reviewed selected aspects of:

  • NBSR Console Logbooks Nos. 144 through 148
  • Reactor Technical Specification Log Book, Volume 2
  • Selected TS surveillance schedules for each month for the period from January to November 2013, which indicated which surveillance activities were due for completion during that month
  • Selected NIST reactor area inspection log sheets (completed every shift during routine operation) for the past 12 months
  • Selected NIST reactor control room log sheets (data taken every hour during routine operation) for the past 12 months
  • Selected NBSR Instrument Test Procedures and TS Procedures
  • Operations Report No. 64, NBSR Annual Report, for the period from January 1, 2011, through December 31, 2011, issued March 28, 2012
  • Operations Report No. 65, NBSR Annual Report, for the period from January 1, 2012, through December 31, 2012, issued March 28, 2013 b. Observations and Findings (1) Maintenance Activities No maintenance activities were in progress or scheduled during this inspection. Nevertheless, a review of various maintenance records, console logbooks, and data sheets indicated that routine maintenance activities were conducted at the required frequency and in accordance with the applicable procedure or equipment manual. Maintenance activities ensured that equipment remained consistent with the Safety Analysis Report and TS requirements.

(2) Surveillance Activities The inspector reviewed the TS-required procedures for the conduct of surveillances and calibrations. These procedures included checklists and tables for recording data which were being used to document completion of the required surveillance activities. The frequency that these activities were to be performed was specified in the TS.

-8-The completion and results of the surveillances and calibrations were tracked by the Chief of Reactor Operations, as well as by operations personnel. Tracking was done by means of the TS surveillance schedule, which was updated as the tasks were completed and then revised, and a new surveillance schedule issued monthly. A review of the monthly surveillance schedules, console logbooks, and related data recorded on the appropriate forms indicated that the surveillances and calibrations were completed at the frequency specified in the TS and in accordance with procedure. If a surveillance activity could not be completed within the established time frame, the reason for the delay was typically documented in the logs or records. All results reviewed by the inspector were within TS or procedurally prescribed parameters.

c. Conclusion The maintenance program was being conducted and documented as required by procedure. The surveillance program was being conducted as specified by TS requirements.

6. Fuel Handling a. Inspection Scope (IP 69009)

The inspector reviewed selected aspects of the following to verify that fuel movement and handling was being conducted as required by TSs 3.9 and 5.3:

  • NBSR Console Logbook No. 148
  • NBSR Reactor Shift Supervisor Logbook No. 39
  • Current core configuration, designated as Core No. 614
  • Pool Log No. 3 and fuel transfer records from July 2012 to the present
  • Core reload/refuel and core defuel/refuel verification and sign-off sheets for Core Nos. 609 through 614
  • NBSR AR 6.0, Refueling Operations, issued August 22, 2006
  • NBSR Reference Procedure, Ref 62, Reloading Fuel From Pool, with Known Shims and Known Core, last reviewed September 19, 2011 b. Observations and Findings Licensee procedures and operator instructions provided approved methods to move and handle fuel consistent with the provisions of the TS and the licensee safety analysis. The inspector reviewed the core loading and fuel handling records for the most recent refueling cycles and found them to be complete and properly documented. Fuel movement, fuel loading/reloading, and fuel examination records documented that fuel was moved and controlled as required. The records also showed that the fuel movements were verified by various individuals as required and that fuel elements were in the designated locations. Records further showed that fuel handling and monitoring equipment

-9-was operable. Personnel were knowledgeable of the procedural requirements that ensured criticality control and fuel integrity.

During a review of the records it was noted that there had been a problem during the last refueling operation. The refueling system failed after 3 spent fuel elements were offloaded from the core during a routine end of cycle refueling operation (typically 4 elements are offloaded). After considering the problem, the licensee decided to leave the fourth spent fuel element in the core and adjust their normal fuel shuffle plan to accommodate this. Brookhaven National Laboratory (BNL) had performed simulations of the licensees core and possible accident scenarios for the relicensing in 2009. Therefore the licensee contacted BNL and asked them to perform calculations using the core loading with one spent fuel element instead of a fresh fuel element. This was done and the calculations indicated that there would be no problems leaving the one spent element in the core. There would be a slight loss of excess reactivity relative to a normal core which would result in a shorter operating cycle. This was deemed acceptable and the licensee proceeded. No problems were noted.

c. Conclusion The licensee maintained and followed procedures which effectively implemented TS requirements for fuel handling.

7. Experiments a. Inspection Scope (IP 69005)

To ensure that the requirements of TS 3.8, 4.8, and 6.5, and licensees administrative procedures were being met governing the experimental program, the inspector reviewed selected aspects and/or portions of:

  • Beam Experiment Subcommittee report to the SEC dated September 13, 2013
  • Experimental control procedures for various instruments located in the C 100 area and the guide hall
  • Rabbit request list, listing irradiation requests that have been authorized for the pneumatic system
  • Experimental Proposal Approval Sheet, No. 488, Commissioning of the Multi-Axis Crystal Spectrometer (MACS-II) at BT-9, approval dated March 5, 2013
  • Experimental Proposal Approval Sheet, No. 490, Neutron Spin Echo Spectrometer at NG-Al, approval pending b. Observations and Findings Experiments at the NBSR included: (1) irradiation experiments - those conducted in a pneumatic tube or in any other NBSR irradiation facility inside the thermal shield, and (2) beam experiments - those experiments which were

- 10 -

conducted in or with experimental instruments outside the reactor thermal shield.

Beam experiments were typically conducted in the C-100 area or the guide hall.

For irradiation experiments, the reactivity worth and other criteria were delineated in the TS; no criteria were listed in the TS for beam experiments. Depending upon the type of experiment being proposed, either the Irradiation Subcommittee or the BES reviewed the experimental proposal as required and provided recommendations.

Since the TS did not include criteria for beam port experiments, the licensee developed administrative guidelines to extend the review and approval requirements in TS 6.5 to include the beam port and guide hall experiments. The inspector interviewed the Chairman of the BES. He explained the procedure followed for experiment approval and discussed two recent experiments that were reviewed by his committee. The inspector reviewed the approval procedure and package for two beam experiments and noted that the BES and the facilitys Hazards Review Committee had reviewed these experiments as well. The inspector verified that the beam experiment proposals were forwarded to the SEC for review and subsequently to the Director for approval. The inspector also noted that the approved beam experiment documentation required specific engineering and radiation protection controls that were required to be implemented to limit radiation exposure to personnel conducting the experiments.

c. Conclusion The program for experiment review and approval satisfied TS and procedural requirements.

8. Procedures a. Inspection Scope (IP 69008)

The inspector reviewed the following to ensure that the requirements of TS 6.4 were being met concerning written procedures:

  • Procedure change, review, and approval process
  • NBSR AR 5.0, Procedures and Manuals, issued June 5, 2010
  • SEC meeting minutes for September 2012 through the present (Meeting Nos. 374 through 376)
  • Operations Report No. 64, NBSR Annual Report, for the period from January 1, 2011, through December 31, 2011, issued March 28, 2012
  • Operations Report No. 65, NBSR Annual Report, for the period from January 1, 2012, through December 31, 2012, issued March 28, 2013 b. Observations and Findings Written procedures for the activities listed in TS 6.4 were available as required.

Those activities included normal reactor operations, abnormal operations,

- 11 -

emergency conditions involving the potential or actual release of radioactivity, radiation protection, site emergency actions, and fuel handling. The inspector verified that the official, approved copies of reactor operations procedures were kept in the control room as stipulated by procedure. The inspector also verified that the procedures were reviewed by the SEC and approved by the Chief of Reactor Operations, as specified in the TS.

During the procedure review, the inspector noted that the licensee was in the process of reformatting all procedures so that they would all be in a standard format. Once this was completed the licensee planned to conduct a review of each procedure and ensure that it was correct, reflected current practice, and was in accordance with the TS. In the past some tasks were completed by the operators (who were fully aware of the correct process to follow) while the procedures had not been revised to reflect the practice. These issues will all be addressed by the procedure reformatting and review process. The licensee was also in the process of developing guidance on how to write a new procedure, properly revise an existing procedure, and how to control and disseminate the new or revised procedures. Because this was a project that would take a great deal of time and effort to complete, the licensee was informed that the issue of reformatting and revising the existing procedures and developing guidance on writing and revising procedures would be followed by the NRC as an Inspector Follow-up Item (IFI) and would be reviewed during subsequent inspections (IFI 50-184/2013-202-01).

c. Conclusion The procedure revision, control, and implementation program satisfied TS requirements.

9. Emergency Preparedness a. Inspection Scope (IP 69011)

In order to verify compliance with the NBSR Emergency Plan (E-Plan) dated December 2008, with the latest revision submitted May 17, 2012, the inspector reviewed selected aspects of:

  • Selected NIST reactor area inspection log sheets for the past 12 months
  • Support provided by support groups (i.e., NIST Fire Department (FD) and NIST Police Department (PD))
  • Records documenting annual evacuation drills and the latest biennial emergency exercise
  • Documentation of inventories of emergency response supplies, equipment, and instrumentation
  • Emergency Instruction (EI) Manual (containing the E-Plan implementing procedures)

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  • EI Procedure 0.2, Emergency Organization Phone Numbers, latest revision/change dated December 10, 2012
  • EI Procedure 0.3, Emergency Classification and Criteria, latest revision/change dated December 10, 2012 b. Observations and Findings The E-Plan in use at the reactor and support facilities was the same as the latest version approved by the NRC. The E-Plan was being audited and reviewed biennially as required. Implementing procedures, contained in the Emergency Instruction Manual, were reviewed and revised as needed to effectively implement the E-Plan. The inspector verified that operators understood their duties in response to emergency conditions.

Records showed that radio communications with the NIST PD were checked weekly. Other communications capabilities were checked periodically and phone numbers for the various support organizations were verified annually, as stipulated in the TS. The inspector conducted an onsite tour of the licensees Emergency Support Center and determined that communication equipment, radiological response supplies, and detection equipment was functional.

The most recent biennial emergency exercise was conducted on December 11, 2012. A critique was held following the exercise to discuss the strengths and weaknesses identified and to develop possible solutions to any problems identified. The results of the exercise critiques were documented and filed. It was noted that the next biennial emergency exercise was scheduled for the November/December 2014 timeframe.

The most recent emergency drill was conducted on July 15, 2013. The inspector had the opportunity to observe the drill. It was challenging and provided good training for all the various NCNR responders and NIST support groups who were involved. A critique was held following the drill to discuss those things that were done well and how to correct the problems identified.

Emergency preparedness and response training for NBSR personnel was being completed as required. This was accomplished through the initial training for incoming personnel and the refresher training provided for all NCNR employees.

The licensees health physics group conducted biennial emergency response training for the NIST FD and PD, as well. The inspector verified that the last training for these groups had been conducted on December 11, 2012.

The inspector reviewed the results of selected emergency equipment inventories required by Section 8.5 of the E-Plan. It was noted that the emergency equipment in the lockers located in the A-wing front lobby/break area, in Basement Level 2, and in the C-200 area had been inventoried more frequently than required.

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The inspector verified that the agreement with the Walter Reed National Military Medical Center for medical support in case of an emergency, originally signed December 22, 1983, remained in effect and was acceptable. It was noted that other hospitals in the vicinity of NIST were also equipped to handle emergencies involving a contaminated injured person if needed.

On Friday during the inspection, the inspector, the NCNR Chief, Reactor Operations, and a NCNR Senior Health Physicist visited the Shady Grove Adventist Hospital, which was one of the area hospitals that might be called upon to provide support for the NCNR in case of emergency. Through interviews with emergency management personnel, it was determined that the hospital emergency response personnel were trained to respond to a radiological accident and the hospital had the appropriate equipment and facilities to handle such a situation. Everyone involved was made aware of the agreements for assistance that had been established between NIST, Montgomery County, and the local support agencies.

c. Conclusion The emergency preparedness program was being conducted in accordance with the E-Plan.

10. Follow-up on Licensee Identified TS Violation a. Inspection Scope (IP 92701)

The inspector reviewed the following in response to a licensee identified failure to comply with TS requirements:

  • NBSR Console Logbook Nos. 147 through 148
  • Various NIST Reactor Control Room Log sheets
  • Selected NIST Reactor Area Inspection Log sheets
  • Shift Supervisors Instructions and Special Log sheets
  • NBSR Reactor Shift Supervisor Logbook Nos. 37 and 38
  • Associated reactor operations records from 2012 to the present
  • NBSR Reference Procedure 20 (RP-20), Reloading Plan After Installation of New Shims, Rev. A, approval dated July 17, 2013
  • Copies of Exams given to all operators concerning the TS requirements and the recent licensee-identified TS violations
  • Letter from the licensee to the NRC dated August 23, 2013, reporting the NCNR Violation of Limiting Conditions of Operation
  • Minutes of the Hazards Evaluation Committee for 1980
  • Copy of the original TS for National Bureau of Standards Reactor dated July 31, 1970, including TS Section 8.1
  • Operations Report No. 40 for the National Bureau of Standards Reactor dated March 28, 1987
  • Various entries made in NBSR Console Logbooks from 1980, 1987, 1995, 2000, 2004, and 2008

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b. Observation and Findings TS 3.1.3 states that the reactor shall not be operated unless all grid positions are filled with full length fuel elements or thimbles.

TS 3.3.1(1) states that the reactor shall not be operated unless the reactor vessel coolant level is no more than 25 inches below the overflow standpipe.

TS 3.9.2.1 requires that, following handling of fuel within the reactor vessel, the reactor shall not be operated until all fuel elements that have been handled are inspected to determine that they are locked in their proper positions in the core grid structure.

The NIST research reactor uses four shim arms to control reactivity. These shim arms contain cadmium metal as the poison material which is clad in an aluminum alloy. During reactor operation the cadmium is depleted by neutron absorption and the shim arms lose negative reactivity worth. About every four years the shim arms must be replaced. Replacing all four shim arms at one time requires the reactor core to be fully unloaded and the fuel placed into the storage pool.

After the shim arms are replaced, the reactor is reloaded with the previously stored and partially spent fuel elements. To assure safe core loading and monitor for anomalous conditions, the reactor is loaded using a procedure called the inverse-multiplication (1/M) experiment. In this operation the subcritical neutron multiplication of the reactor is monitored while fuel is sequentially added to the core.

On August 7, 2013, the licensee began the process of reloading the reactor core following normal shim arm replacement. The licensee used an approved procedure, RP-20, Reloading Plan After Installation of New Shims. Due to equipment problems the reactor was partially loaded on August 7 and the procedure was completed on August 8. Following the steps specified in the procedure, the reactor went critical on Step 7 and Step 9 on August 8, 2013. The reactor grid plate was partially loaded at Step 7 and fully loaded at Step 9.

During the shift turnover on August 9, it was mentioned to the Chief of Reactor Operations that the reactor could be considered to be in an operating condition when it went critical the day before and not all grid positions were filled. The Chief of Reactor Operations informed the Chief of Reactor Operations and Engineering. After a discussion of the situation, it was agreed that the Limiting Condition of Operation (LCO) specified in TS Section 3.1.3 had been violated.

When this issue was found, the Chief of Reactor Operations notified the Chief of Reactor Operations and Engineering and upper management. The licensee initiated an investigation into the problem and notified the NRC of the situation by a phone call on August 9, 2013. (The initial phone notification of the NRC was followed up by a written notification submitted on August 23, 2013.)

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Upon further review of the event during the weekend of August 10 and 11, it was noted that, not only had the reactor had been operated when all of the grid positions were not filled with fuel elements, but the reactor vessel coolant level was more than 25 inches below the overflow standpipe and the fuel elements had not been locked in their positions in the core grid. Therefore, three LCOs had been violated during completion of Procedure RP-20.

The licensee subsequently conducted an extensive investigation into the problem and found that this situation, or a variation thereof, had existed possibly since the first time the shim arms were replaced in early 1980. The cause of the problem was thought to have been the use of a revision of the provisional TS that had been issued during initial reactor startup. The provisional TS contained a section that allowed fuel loading and low power reactor physics testing by waiving some of the LCOs that applied during normal operation. The licensee found that a portion of the provisional TS may have been used to create a procedure essentially repeating an inverse multiplication test from the 1967 AEC-approved nuclear testing program. Thus, since 1980, one or more of the TS LCOs may have been violated during various reactor reload and start-up operations following shim arm replacement operations that occurred in the past.

After an investigation and review of the problem, the licensee developed various corrective actions. All licensed reactor operators and reactor line management were briefed on the circumstances of the violation and the apparent root cause.

All licensed operators were to be given a written test on the current TS with an emphasis on Limiting Conditions for Operations. The licensee also began a review of all frequently or routinely used procedures prior to their use. This was done by the Chief of Reactor Operations or the Chief of Reactor Operations and Engineering. The review was completed to verify that the procedures did not violate any TR-5 TS conditions. The licensee also initiated the process to review and revise the written guidance/procedure that governs the preparation, review, and approval of procedures at the NCNR. All written procedures required by TS 6.4 will eventually be re-reviewed under this new guidance and will include the review and approval of the NBSR Safety Evaluation Committee.

The inspector reviewed the event and the findings of the licensee, as well as the corrective actions. The inspector found that documentation appeared to indicate that the problem originated many years ago. The inspector noted that the licensed operators had received a briefing on the violation and the root cause and all operators were given a written test on the current TS and the LCOs. All frequently or routinely used procedures were in the process of being reviewed prior to use. The licensee was also in the process of developing written guidance that would govern the preparation, review, and approval of procedures. Because all this actions were still ongoing during the inspection, the licensee was informed that the NRC will follow these ongoing corrective actions concerning review and revision of procedures as an Inspector Follow-up Item (see Section 8 of this report).

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The inspector determined that the problem had been identified and reviewed by the licensee and reported to the NRC. Corrective actions had been identified and were in the process of being completed as well. As a result, the licensee was informed that this non-repetitive, licensee-identified and corrected violation would be treated as a Non-Cited Violation (NCV), consistent with section VI.A.8 of the NRC Enforcement Policy (NCV 50-184/2013-202-02). This issue is considered closed.

c. Conclusions One licensee-identified NCV was noted for failure to follow certain LCOs of the TS during shim arm replacement and reactor restart operations. This issue was reviewed and is considered closed.

11. Exit Interview The inspection scope and results were summarized on November 21, 2013, with members of licensee management. The inspector described the areas inspected and discussed the inspection findings. The inspection results were also discussed briefly on November 22, 2013, with the Chief, Reactor Operations, following a visit to the Shady Grove Adventist Hospital.

PARTIAL LIST OF PERSONS CONTACTED Licensee P. Brand Chief, Reactor Engineering and Chair, Hazards Review Committee R. Clement Senior Health Physicist Director, NIST Center for Neutron Research D. Hughes Chief, Reactor Operations R. Ibberson Chair of the Beam Experiment Subcommittee M. McDonald Reactor Supervisor/Senior Reactor Operator W. Mueller Reactor Supervisor/Senior Reactor Operator S. OKelly Chief, Reactor Operations and Engineering R. Strader Quality Assurance Program Manager R. Sprow Reactor Supervisor/Senior Reactor Operator Other Personnel M. Feist Director, Adventist HealthCare Emergency Management, Shady Grove Adventist Hospital M. Oxenford Director of Emergency Services, Shady Grove Adventist Hospital INSPECTION PROCEDURES USED IP 69003: Class 1 Research and Test Reactor Operator Licenses, Requalification, and Medical Activities IP 69005: Class 1 Research and Test Reactors Experiments IP 69006: Class 1 Research and Test Reactors Organization, Operations, and Maintenance Activities IP 69007: Class 1 Research and Test Reactors Review and Audit and Design Change Functions IP 69008: Class 1 Research and Test Reactor Procedures IP 69009: Class 1 Research and Test Reactors Fuel Movement IP 69010: Class 1 Research and Test Reactors Surveillance IP 69011: Class 1 Research and Test Reactors Emergency Preparedness IP 92701 Follow-up on Open Items ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-184/2013-202-01 IFI Follow-up on the licensees actions to reformat existing procedures, review and revise the procedures, and develop written guidance on procedure writing and revision.

50-184/2013-202-02 NCV Failure to the LCOs contained in Section 3.1.3, 3.3.1, and 3.9.2.1 of the TS during shim arm replacement and reactor restart operations which occurred in August 2013.

-2-Closed 50-184/2013-202-02 NCV Failure to the LCOs contained in Section 3.1.3, 3.3.1, and 3.9.2.1 of the TS during shim arm replacement and reactor restart operations which occurred in August 2013.

LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Document Access Management System AR Administrative Rule BES Beam Experiment Subcommittee ECN Engineering Change Notice ECR Engineering Change Request EI Emergency Instruction E-Plan Emergency Plan IP Inspection Procedure IR Inspection Report NBSR National Bureau of Standards Reactor NCNR NIST Center for Neutron Research NIST National Institute of Standards and Technology NRC U.S. Nuclear Regulatory Commission OI Operating Instruction OMARR Operations and Maintenance Assessment of Research Reactors SAC Safety Audit Committee SEC Safety Evaluation Committee SRO Senior Reactor Operator SSC Structures, Systems, and Components TS Technical Specification

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