IR 05000188/1989001
| ML20247D106 | |
| Person / Time | |
|---|---|
| Site: | Kansas State University |
| Issue date: | 03/10/1989 |
| From: | Baer R, Chaney H, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247D104 | List: |
| References | |
| 50-188-89-01, 50-188-89-1, IEB-79-19, IEIN-83-05, IEIN-83-5, IEIN-86-090, IEIN-86-90, IEIN-88-022, IEIN-88-22, NUDOCS 8903300387 | |
| Download: ML20247D106 (11) | |
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APPENDIX B
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-188/89-01 License: R-88 Docket: 50-188 Licensee: Kansas State University (KSU)
Department of Nuclear Engineering Manhattan, Kansas 66506 Facility Name: Nuclear Reactor Fac.ility - (NRF) (Class II, TRIGA Mark II)
l Inspection At: NRF (Ward Hall), KSV Inspection Conducted: Februar 6-9, 1989
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Inspectors: i
/ S H. D. Chdney, Senior Radiati n Specialist Date Facilities Radiological Pr ection Section
/ Mu 4md L. RT'cketson fit, $adiation Specialist Y'Yl Date Facilitihs Radiological Protection Section Approved: /Ja' /f N .3//Dh.9
! R. 4. Baer, Chief, Facilities Radiological Date l Protection Section Inspection Summary l Inspection Conducted February 6-9, 1989 (Report 50-188/89-01)
Areas Inspected: Routine, unannounced inspection of the licensee's management i organization, reactor operations and maintenance logs, internal audit and review program, surveillance requirements, fuel handling, radiation protection program, emergency preparedness, radioactive material (RAM) transportation, special nuclear material accountability, and physical securit Results: Within the areas inspected, one violation (failure to establish ,
control over facility access keys, see the Attachment to this report) was identified. No deviations were identified. The NRC inspectors observed improvement to the radiation protection program by the addition of improved radiological surveys, instrument calibrations, and calibration procedure h33OO387g90321 -
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-2-DETAILS l persons Contacted
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Licensee (KSU)
- N. Eckhoff, Chairman, Reactor Safeguards Committee
- R. Faw, Director', Nuclear Reactor Facility
- J. Daniels, Reactor Supervisor
- J. Lambert Director, Public Safety and Radiation Safety Officer J. Schule, Physical Plant Lock Specialist D. Breymeyer, Physical Plant Key Custodian D. Whitfill, Reactor Operator C. DeWeese, Student C. Beckom, Chief of Police
- Indicates those present at the exit interview on February 9,198 . Follow-up on Previous inspection Findings (92701)
(Closed) Violation (188/8602-01): Calibration of Radiation Protection Instruments - This item was previously discussed in NRC Inspection Repert 50-188/86-02 and involved the licensee's failure to perform semiannual calibrations of various radiation protection survey instruments as required by the KSU Emergency Plan (EP). The NRC inspectors examined the licensee's implementation of the corrective actions committed to in their November 17, 1986, response to the violation. The licensee's implementation of corrective actions (new record keeping procedure and updating of all calibrations) appears to be adequate to prevent a recurrence of the violation in the futur (Closed) Violation (188/8602-02): Calibration Procedures - This item was previously discussed in NRC Inspection Report 50-188/86-02 and involved the licensee's failure to develop calibration procedures for personnel dosimetry, gamma spectroscopy system, and the liquid scintillation ;
counting syste The NRC inspectors examined the licensee's 1 implementation of the corrective ections committed to in their November 17, 1986, response to the violation. The licensee's implementation of corrective actions (development of specific calibration procedures for the noted equipment) appears to be adequate to prevent a i recurrence of the violation in the future. The licensee contracted a vendor meeting the qualifications set forth in 10 CFR Part 20.202(c),
to provide personnel dosimetry to reactor facility personne (Closed) Violation (188/8602-03): Failure to Survey - This item was previously discussed in NRC Inspection Report 50-188/86-02 and involved the licensee's failure to survey liquid effluent for alpha radioactivity l and perform airborne noble gas radioactivity measurements within the Enclosures contain PROPRIETARY INFORMATIO Decontrolled when separated from attachment ____________- __ __ _
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reactor facility. The NRC inspectors examined the licensee's implementation of the correc'tive actions committed to in their November 17, 1986, response to the violatio The licensee's corrective actions appear adequat (Closed) Deviation (188/8801-01): Equipment Failure Documentation - This item'was previously discussed in NRC Inspection Report 50-188/88-01 an involved the licensee's differing opinion than that of the inspectors,.'as to what reactor equipment failure required red highlighting when documented in the operations log. The NRC inspectors examined.the licensees implementation of the corrective actions committed to in their May 11, 1988, response to the deviatio The licensee's implementation of' corrective actions (clarification of the Hazards Summary Report and the Operations Manual concerning specific type of failures and planne operations that need to be highlighted) appears to be adequate to resnive this ite (Closed) Open Item (188/8801-02): Maintenance Procedures Not-Accurate -
This item was previously discussed in NRC Inspection' Report 50-188/88-01 i and involved the NRC inspectors' concerns that the biennial. reactor control rod inspection procedure did not adequately identify specific processe and parameters for . inspection of the control rods. The licensee had revised KSU TRIGA Mark II, Procedure #1, to include detailed inspection l J
criteria for performance of the biennial inspection of the reactor control '
rods. The licensee's action is considered adequate to' resolve this ite (Closed) Open Item (188/8801-06): Current Federal Regulations - This item was previously discussed in NRC Inspection Report 50-188/88-01 and
. involved the NRC inspectors' concern that the licensee did not subscribe to a commercially available set of "NRC Rules and Regulations" so they-tricensee) could keep current regulations on hand. The licensee had initiated a contract with a commercial updating service for _ federal 1 regulations. The licensee's action is considered' adequate to resolve this
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j ite . Open Items Identified During This Inspection ,
An open item is a matter that requires further review and evaluation by the NRC inspector. Open Items are used to document, track, and ensure adequate follow-up on matters of concern to the NRC inspector. The .;
following open items were identified:
Open Item Title See Section
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188/8901-02 10 CFR Part 19.12 Training /8901-03 Neutron Dosimetry /8901-04 Effluent Releases /8901-05 NRC Bulletin 79-19 Response 6 i
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. Inspector Observation An inspector observation is a matter discussed with the licensee during the exit interview. Observations are neither violations, deviations n unresolved item They have no specific regulatory requirement, but are suggestions for the licensee's consideration. The following is an inspector observation:
Posting of Current Facility Survey Results - The Licensee does not post current radiological survey results of the reactor facility at the upper and lower personnel entrances to the facilit See Section 5.f of this repor . Class II Operation and Procedures (40750) Background
, The KSU reactor was issued an operating licensee on July 31, 1968, l
for a period of 40 year The 250 kilowatt TRIGA reactor is used as a training, research, and isotope generator for undergraduate and graduate students enrolled in nuclear engineering and geology courses at KSU. The operating history for 1987 and 1988 are as follows:
YEAR OPERATING HOURS KILOWATT-HOURS 1987 33 .8 31236 Design Changes, Audits, and Committees The NRC inspectors reviewed the licensee's staffing, staff qualifications, written instructions, and activities of the Reactor Safeguards Committee (RSC) since the last inspection of this area (March 8-10, 1988; NRC Inspection Report 50-188/88-01). No changes in staffing were note The NRC inspectors reviewed the licensee's administrative, operating, operator requalification, maintenance, surveillance testing, equipment calibration, radiological protection, and emergency t procedures for the reactor facility. All procedures were found to be l of appropriate detail and approved by the RS The licensee conducts semiannual audits of reactor operations, emergency preparedness, and reactor maintenance. The audits completed during 1987 and 1988 were found to be timely and of sufficient depth and quality to adequately verify all operating parameters of the NRF Licens The NRC inspectors noted that the licensee utilized detailed checklists to conduct the audits. Audits
, and minutes of RSC meetings were routinely submitted and reviewed l within one day. The NRC inspectors noted that the RSC routinely l reviews NRC and industry informational papers.
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The NRC inspectors examined the licensee's reports submitted pursuant to 10 CFR Part 50.59(b) for 1987 and 1988. No significant changes in i facility design or operations were noted (only procedural changes and ]
testing of replacement area radiation monitors) that would involve an 1 unreviewed safety questio The licensee is replacing the old area {
radiation monitors with more modern units that have the same j performance parameters. There were no changes in reactor experiments identified in these report >
j Logs and Records The NRC inspectors examined the licensee logs and records concerning reactor operations during 1988 and 1989 to determine compliance with the requirements of Section 3.C of the Facility Licens Licensee checklists for 1988 and 1989 (daily, weekly, monthly, quartarly, semiannual, and biennial reactor facility operational activities)
were reviewed. Records were noted to be clear, concise, and legibl The licensee's 1989 results of the biennial inspection of control rods (Licensee Procedure #1) were reviewed. No problems were note In addition to measuring each rod's critical parameters, the licensee had radiographer and photographed each ro The licensee's entries in the 1988 and 1989 operations logs indicated a failure of the l reactor console backup battery powe supply and its subsequent replacement. The NRF experienced minor flooding (1 to 6 inches) of the reactor bay lower level when one of the steam heating lines for the facility failed (due to freezing weather) just prior to this ,
inspectio I Procedures l The NRC inspectors examined the licensee's procedures for the operation, maintenance, and surveillance testing of reactor equipment to determine compliance with Section H of Appendix A to the Facility License, " Technical Sped fications (TS)." The licensee's procedures available at the operating console were accurate and in current revision. The NRC inspectors noted that the licensee had provided the Reactor Supervisor with authority to make temporary changes to procedures if conditions warrante The NRC inspectors observed the licensee perform operations directed by the following procedures:
Number 9, " Entrance to the Reactor Bay - Visitor Control,"
Revision dated 10/24/80 Number 15, " Reactor Startup.," Revision dated 2/19/82 Number 16, " Reactor Shutdown," Revision dated 2/19/82 No problems were noted during performance of the procedure Enclosures contain PROPRIETARY INFORMATIO Decontrolled when separated from attachments.
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-6-1 Surveillance The NRC inspectors reviewed the licensee's TS surveillance results for the period January 1988 through January 1989 concerning the following surveillance:
TS Item Title Frequency
- Response Test of Radiation Area Monitors Quarterly E.11 Drop Times for Control Rods Semiannually Area Radiation Monitor Calibration Semiannually Inspection of Control Rods Biennially
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Review of Physical l Security Plan Biennially
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Review of Emergency Plan Biennially All surveillance were conducted within the period required and no anomalies were noted in the licensee's results. The licensee had not reached the TS D.6 limit on reactor pulses (100) requiring fuel element inspection since 1986. As of this inspection, the number reactor pulses totaled 6 Health Physics l l
The NRC inspectors examined exposure, survey, portable and laboratory instrument calibration, and effluent release records for compliance with the requirements of 10 CFR Parts 19.12, 20.5, 20.101, 20.102, 20.103, 20.202, 20.401, 20.407, 20.408, and 20.409; and the i requirements of Sections F.1, F.2., and F.3 of the T j The NRC inspectors noted that the licensee had procured personnel dosimetry services for NRF activities in November 1987 from a vendor with the accreditation required by 10 CFR Part 20.202(c). Facility personnel are monitored either by self reading pocket ion chambers that have been response checked in accordance with the guidance of NRC Regulatory Guide 8.4 and a film badge sensitive to beta gamma and neutron radiation; or in the case of visitors, just the pocket dosimeter for short duration reactor staff escorted entries. Finger ring dosimetry is available and used routinely as conditions warrant. The NRC inspectors discussed with the licensee (by telephone on March 9, 1989) the recommendations of NRC Regulatory Guide 8.14, " Personnel Neutron Dosimeters," concerning the Enclosures contain PROPRIETARY INFORMATIO Decontrolled when separated from attachments.
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-7-efficiency of Nuclear Track A type film for monitoring rea &
fission spectrum neutrons. The licensee agreed to evaluate their current neutron dosimetry in regards to the information and recommendations of NRC Regulatory Guide 8.14. This is considered an open item pending further NRC review. (188/8901-03)
The NRC inspectors examined the licensee's lesson plan and training aids for ensuring personnel that entered the NRF were provided adequate training in radiological protection matters and administrative requirements as requried by 10 CFR Part 19.12. The licensee provides the required training via two Nuclear Engineering Department courses: NE-550, " Radiation Protection Engineering" and NE-648, " Reactor Operations Laboratory". % WC inspectors interviewed one student that had just recently cumpleted the NE-550 course. The student was not familiar with exposure records that were available upon request by the student. The NRC inspectors also discussed with licensee representatives the need to ensure that records of personnel exposure were available at the control room for briefing of personnel on their allowable radiation exposure (whole
) body, skin, and extremities) prior to allowing entry. This part of the licensee's radiation protection program is weak and is considered an op.en item pending licensee improvements in radiation protection training for students. (188/8901-02)
The licensee's portable radiation monitoring 1. instrumentation calibration program appears to satisfy the recommendations of NRC Regulatory Guide 8.21 and ANSI Standard N323-1978. Calibration records were foand to be up to date and accurate. The licensee's practice of response checking (with a calibrated gamma source) the high range gamma monitor located above the reactor pool (22-foot level) at the 5 roentgens per hour alarm point is considered sufficient and ALARA. The NRC inspectors examined the licensee's continuous air monitor (CAM) operation and alarm settings. The CAM alarm is set at a value (typical for this type of CAM, less than 1000 net counts per minute) that will provide an alarm prior to exceeding '
the Iodine-131 or beta gamma concentration limits of Table 1, Column 1 of Appendix B to 10 CFR Part 2 Studies have shown that significant fission product gases would be detected by the continuous reactor coolant radiation monitors or the NRF area CAM prior to exceeding any 10 CFR Part 20 limits in the NRF, a 10 CFR Part 2 defined restricted are The NRC inspectors reviewed the licensee's on hand stock of portable radiation protection instruments, completed facility radiological surveys (1988), and conducted confirmatory measurements (beta gamma)
of radit. tion, contamination, and airborne radioactivity within the NR The licensee's surveys were found to be weil documented and accurat The NRC surveys (no abnormal levels noted) were in agreement with the licensee's most current result The NRC inspectors noted that the licensee had performed neutron surveys of Enclosures contair. PROPRIETARY INFORMATIO Decontrolled when separated from attachment , _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
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-8-the facility durirg various reactor power levels resolving an NRC observation made in the last inspection of this area (50-188/86-02).
No significant neutron radiation was noted by the licensee. The NRC inspectors discussed with the licensee the merits of posting maps, near reactor bay accesses, depicting current radiation survey results and RAM storage locations within the facility. This would provide workers and emergency response personnel information currently only accessible via a briefing with the RSO or reactor operator The NRC inspectors noted that the licensee's spare materials stock pile (miscellaneous pieces of plastic and metal pipe, rod, bar stock) within the NRF, contained a mixture of clean and activated (RAM) material. Some of the RAM (with contract radiation levels of less than 20 millirem per hour) were not identified as being radioactive and could be improperly handled due to the lack of radiological warning labels on individual items; even though appropriate 10 CFR Part 20.203 required warning signs, as to the presence of RAM in the NRF, were posted at entrances to the NRF. The Reactor Supervisor agreed that the activated material should be individually marked as RAM, and subsequently had a NRF staff member h perform a detailed survey of the stocked piled material, segregating clean and activated material, and appropriately attaching warning tags to RA The NRC inspectors reviewed the licensee sampling, analysis, and documenting of reactor sump liquid releases. Radioactive waste (radwaste) disposal records for 1987 and 1988 were also reviewe All analysis showed no detectable radioactivity in effluent sample The licensee currently performs gamma spectroscopy and alpha radiation analysis on all liquid samples. The licensee committed to performing alpha analysis of liquid effluent samples due to the possibility of the americium / beryllium neutron startup source, located in the reactor pool, developing a leak. The licensee expressed to the NRC inspectors, a desire to change their commitment concerning alpha analysis of liquid effluents to the performance of a periodic leak test (swipe type) of the neutron source to verify r,o alpha activity would be in effluent The NRC inspectors informed the licensee that they should notify the NRC Regional office in writing as to any proposed change in previous commitments. The NRC i in'spectors examined the licensee's counting laboratory and reviewed calibration procedures for both the beta scintillation and gamma spectroscopy system The licensee was currently preoperational testing, for development of operating and calibration procedures, a new laboratory counter that simultaneously measures both beta and alpha radioactivit ,
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l The NRC inspectors discussed with the licensee (by telephone on 1 March 9,1989) the need for the licensee ta evaluate their liquid effluent release program and procedures with the information and guidance contained in NRC Inspection and Enforcement Information Notices 83-05, " Obtaining Approval for Disposing of Very-Low Level Enclosures contain PROPRIETARY INFORMATIO Decontrolled when separated from attachment . .
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-9-l Radioactive Waste;" 86-90, " Request to Dispose of Very-Low Level i Radioactive Wastes Pursuant to-10 CFR 20.302;" and 88-22, " Disposal )
of Sludge From Onsite Sewage Treatment Facilities at Nuclear Power Plants." This is considered an open item pending further NRC review. (188/8901-04) Emergency Planning The NRC inspectors examined the implementation of the KSV EP approved by the NRC on August 13, 1984, to determine compliance with 10 CFR Part 50.54(r).
The NRC inspectors reviewed assignment of responsibilities, emergency facilities, and response equipment (first aid and medical facilities, communications, and radiation and contamination protection equipment / supplies). Letters of agreement with other KSU and area organizations that would provide assistance to the NRF during an emergency were examined and found to be current. The NRC inspectors examined the placement and inventories of the emergency equipmen The NRC inspectors found the emergency equipment kits to be well j stocked, maintained, and in agreement with the plan. The NRC inspectors noted that the licensee's extensive EP implementing i I procedures were well written, adequately reviewed, and updated l periodicall The licensee had provided EP implementing procedure training to off site support organizations that would respond to an emergency at the NRF during the August 11-13, 1987, period. The NRC inspectors reviewed the objectives and critiques of EP drills completed in 1988 and 1989, and the full scale exercises conducted in the years 1984 through 1988. The licensee had satisfied the Plan's requirement for exercising all aspects of the EP through yearly rotation of biennial exercise objectives. The RSC had reviewed the documented critiques of EP exercises and drills. The NRC inspectors verified that the EP was properly reviewed at a biennially frequency.
No violation or deviations were identifie . Transportation Activities (86740)
The NRC inspectors reviewed the licensee's program for preparation, loading, and shipping of RAM /radwaste for compliance with the requirements of 10 CFR Part 20.31], 71.5, and 49 CFR Parts 100-177. RAM is shipped by the RSO utilizing the Kansas State Byproduct License (38C00-11). The NRF does not have any procedures for implementing 49 CFR requirements.
l The NRC inspectors reviewed the licensee's collecti_on, processing, and l disposal of radwaste, and the licensee's September 25, 1979, response to NRC Bulletin 79-19, titled " Transport and Burial of Low-Level Radioactive Waste." The licensee had responded in a 1979 letter, that "The KSV TRIGA MkII Nuclear Reactor Facility does not generate low-level radwaste as Enclosures contain PROPRIETARY INFORMATIO Decontrolled when separated from attachments.
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described in the NRC Bulletin 79-19." The NRC inspectors determined that the KSU Reactor Facility does generate small quantities of radwaste (spent reactor coolant cleanup system resins and filters, and small amounts of ,
dry active waste) from reactor operations and experiments. However, this 1 radwaste is transferred on campus (within Ward Hall) to KSU's Kansas State Byproduct License where it is held by the University RSO, and is subsequently disposed by a licensed hazaraous waste broker. The Director of the Reactor Facility thought that since the radwaste was not processed or directly shipped under by the reactor Facility License (R-88) that the NRC Bulletin did not apply to their operation The NRC inspectors agreed ;
that the NRF does not process radwaste to the extent discussed in the NRC J bulletin, but a resubmittal of the response requested by NRC !
Bulletin 79-19 should be made so that KSU's generating and disposal methods are fully explained and documented. The Facility Director agreed to the NRC inspectors' request. This is considered an open item pending a review and resubmittal of the NRC Bulletin 79-19 requested informatio '
(188/8901-05)
No violations or deviation were identifie . Nuclear Materials Safeguard (85102)
The NRC inspectors reviewed the special nuclear materials inventory and accountability program to determine compliance with Facility License Conditions 2.B and 2.C, and the guidance contained in NUREG/BR-0006, Revision 2, " Instruction for Completing Nuclear Mcterial Transaction Reports." ,
The NRC inspectors verified (visually) the licensee's fuel element inventory (including the 2 curie americium / beryllium neutron startup source). The 7 curie polonium / beryllium source referenced in the Facility License has been returned to Monsanto Laboratories on January 7,1971, per licensee records. The fuel element inventory satisfied the values i submitted on Special Nuclear Material Status Forms 741, 742, and 742C for j the period April 1 through September 30, 1988. The licensee's procedures and records were found to be well implemented. The NRC inspectors also exam' d the October 27, 1986, special nuclear material transaction '
betwo the University of Kansas and KSU involving a fission chamber containing approximately 2 grams of uranium-235. No problems were noted 1 with KSU's part in the transaction which was handled under KSU's Kansas l State Byproduct Licens I Physical Security (81401 and 81431) i The material discussed here contains sensitive information concerning KSU's Physical Security Plan and is incorporated in an Attachment to this repor In accordance with 10 CFR Part 2.790(d), tne documentation in the Attachment is exempt from disclosure and shall not be made available to the publi Enclosures contain PROPRIETARY INFORMATIO Decontrolled d when separated from attachment l
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I Exit Briefing i
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The NRC inspectors met with the licensee's representatives identified in I paragraph 1 of this report at the conclusion of the inspection on February 9, 198 The NRC inspectors summarized the scope and findings ,
l of the inspection. The licensee committed to taking immediate end long i
, term correct ve action to resolve NRF access problems addressed in the i l l Attachment to ;51s report. Confirmatory Action Letter 89-06 was issued by the NRC Region l Administrator on February 14, 1989, confirming the licensee commitments.
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