IR 05000193/1999201

Insp Rept 50-193/99-201 on 990322-26.No Violations Noted. Major Areas Inspected:Licensee Programs Re Operations,Health Physics & Security

ML20205L110
Person / Time
Site:	Rhode Island Atomic Energy Commission
Issue date:	04/07/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20205L104	List: IR 05000193/1999201 ML20205L099
References
50-193-99-201, NUDOCS 9904140144
Download: ML20205L110 (20)

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION I

Docket Nos: 50-193 License Nos: R-95 Report Nos: 50-193/99 201 Licensee: Rhode Island Atomic Energy Commission j Facility: Rhode Island Nuclear Science Center l University of Rhode Island (URI)

Location: Reactor Road Narragansett, Rhode Island Dates: March 22 - 26,1999 Inspector: Craig Bassett, Senior Non-Power Reactor inspector -

Approved by: Ledyard B. Marsh, Chief Events Assessment, Generic Communications, and Non-Power Reactors Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation l

9904140144 990407 PDR ADOCK 05000193

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EXECUTIVE SUMMARY

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This routine, announced inspection included onsite review of various aspects of the licensee's programs concerning operations, health physics, security, and transportation of radioactive material as they relate to the licensee's 2 Megawatt (Mw) Class 1 research reactor. The licensee's programs were directed toward the protection of public health and safety and were in compliance with NRC requirements. No safety concerns or violations of regulatory requirements were identifie Chanaes, Oraanization, and Staffina e The licensee's organization and staffing remain in compliance with the requirements specified in the Technical Specification Review and Audit Functions

• Review and oversight functions required by Technical Specifications Section were acceptably completed by the Nuclear and Radiation Safety Committe Ooerations

• The operations program satisfied License and Technical Specification requirement Desian Control e The design change program satisfied 10 CFR 50.59 requirement Surveillance

• The surveillance program satisfied Technical Specification requirement Fuel Handlina e The fuel handling and examination program satisfied Technical Specification and licensee procedural requirement Exoeriments e The program for experiments satisfied Technical Specification and procedural requirements.

l Procedures e Health physics procedures were in the process of being reviewed and updated as needed.

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Radiation Protection Proaram o Surveys were completed within the time frame prescribed by the Technical Specification e Postings met regulatory requirement e Personnel dosimetry was being worn as required and recorded doses were within the licensee's procedural action levels, and NRC's regulatory limits, o Radiation monitoring equipment was being maintained and calibrated as require * The Radiation Protection and ALARA Programs satisfied regulatory requirement e rhe radiation protection training program was being revised and upgrade Effluent and Environmental Monitorina e Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and Technical Specifications limit Transportation of Radioactive Materials e Radioactive material was shipped in accordance with the applicable regulation S3f eauards and Security -

e . Security activities and systems satisfied Physical Protection Plan requirement Material Control and Accountability

• Special Nuclear Materials were acceptably controlled and inventorie Year 2000 Concerns Review e No Year 2000 (Y2K) problems had been identified concerning reactor operation Y2K issues in the area of counting potentially contaminated samples were being addressed. The licensee was obtaining verification of Y2K compliance from the security vendor.

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I REPORT DETAILS Summary of Plant Status The licensee's two megawatt (2 MW) non-power reactor (NPR) continues to be operated in support of laboratory experiments, reactor operator training, and various types of

- research. During the inspection, the reactor was started-up, operated, and shut down as required to support laboratory experiments and a tour by high school student . NPA Oraanization (Inspection Procedure flPI 39745)  ; Inspection Scope l

To verify staffing, reporting, and record keeping requirements specified in Technical Specifi stions (TS) 6.0 were being met, the inspector reviewed:

l e organization and staffing for the facility, i

e administrative controls, e the reactor console logs, and

• the facility annual reports.

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l Observations and Findinos The licensee's current operational organization consisted of a Director, an Assistant i Director for Reactor Operations (a licensed Senior Reactor Operator), a licensed Reactor Operator, and a Radiation Safety Officer. This organization was consistent with that specified in the TS. Other positions were listed on the organizational l chart but the responsibilities for those positions were not specified by the TS. It

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was noted that the Director was a qualified Senior Reactor Operator but was not l

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maintaining his license in an active status. Because the former Reactor Suparvisor j l had left to take another job, another person had been hired and was in training for j that positio As had been noted in a previous report, the inspector again found that the position !

of Facility Engineer, a position that had been filled by a Professional Engineer (PE),

l remained vacant and has been for more than three years. Due to budget constraints, no replacement has been hired. Although tNs pc,sition is specified in the organizational diagram in TS 6.0, it is not one required to be filled by the TS for

' facility operation. However, it was noted that the licensee is currently in the process of revising facility documents and upgrading facility equipment in order to increase their authorized power level for the reactor from two to five megawatt This effort is being reviewed, and must be approved, by the NRC, it was noted that other facilities have found it beneficial to have a facility engineer on the staff in order to e> pedite such efforts.

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The inspector noted that annual reports summarized the required information ard .

were issued at the frequency specified in the T )

c. Conclusions Organization and staffing met the requirements specified in TS . NPR Review and Audit Functions (IP 40745)

a. Insoection Scope In order to verify that the licensee had established and conducted reviews and {

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audits as required in TS 6.4, the inspector reviewed:

• Nuclear and Radiation Safety Committee meeting minutes, e Nuclear and Radiation Safety Subcommittee meeting minutes, and e audits and reviews, b. Observations and Findinas Minutes of the Nuclear and Radiation Safety Committee (NRSC) showed that the comrnittee met at the required frequency and that a quorum was present. The I topics considered during the meetings were appropriate and as stipulated in the T A subcommittee of the NRSC and/or persons from other institutions conducted audits and reviews as required and the full NRSC reviewed the results. Problems noted during audits were discussed and recommendations for improvement were made. The licensee implemented the improvements as necessar c. Conclusions .

Review and oversight functions required by TS 6.4 were acceptably completed by the NRS . Operations (IP 39745)

a. Scope l The inspector reviewed selected aspects of:

e operational logs and records, e staffing for operations, and e operational, startup, or shutdown activitie ,

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b. Observations and Findinas The operating logs and records were clear and provided an acceptable indication of operational activities (e.g., critical rod configurations, times of operations, power levels, experimental irradiations). This included documentation of events, and resolution or tracking of events (e.g., startup counter high voltage change).

The logs and records indicated that shift staffing, including on-call personnel, was as required by the TS and acceptable for operating activities (currently one licensed Reactor Operator and one licensed Senior Reactor Operator).

Reactor startup and operational observations showed that operational conditions and parameters were consistent with license and TS requirements. Logs and records for the observed reactor startup and operations were accurately kept. The reactor operator was intimately familiar with all aspects for reactor stnrtup, and was extremely proficient in conducting startup activitie The Assistant Director for Reactor Operations maintained and issued a 6-month schedule for reactor operations, maintenance, and surveillance activities. This practice kept the staff aware of upcoming activities and helped ensure administrative control over operational aspects of the facilit c. Conclusions The operations program satisfied License and TS requirement . Deslan Control (IP 40745)

a. Scope The inspector reviewed selected aspects of:

e facility design changes and records and e facility configuratio b. Observations and Findinas Records and observations showed that changes at the facility were acceptably reviewed in accordance with 10 CFR 50.59 and applicable licensee administrative controls (e.g., temperature indicators and primary coolant inlet valve changes).

None of the changes constituted an unreviewed safety question or required a change to the TS.

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4 Conclusions The design change program satisfied 10 CFR S0.59 requirement . Surveillance (IP 61745) Scope The inspector reviewed selected aspects of:

e surveillance and calibration procedures, and e surveillance, calibration and test data sheets, and records.

a Observations and Findinas Surveillance, test, and limiting conditions for operation verifications and calibrations for shutdown margin, and excess reactivity were completed on se' edule and in accordance with licensee procedures. All the recorded results were within the TS and procedurally prescribed parameters. Associated records and logs were complete and were being maintained as require Conclusions The surveillance program satisfied TS requirement . Fuel Handlina (IP 60745) Scone (69001)

The inspector reviewed selected aspects of:

e fuel-handling procedures, e fuel handling equipment and instrumentation, and e fuel handling and examination records, Observations and Findinas Fuel-handling procedures provided a prescribed method to move and handle fuel consistent with the provisions of the TS and the licensee safety analyses. Fuel movement and fuel examination records showed that the fuel was moved and examincd as required. Records also showed that fuel-handling, monitoring equipment, and instrumentation were operable prior to use. Personnel were knowledgeable of the procedural and equipment requirements for criticality control and assurance of fuel integrit ,

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5 Conclusions The fuel handling and examination program satisfied TS and licensee procedural requirement . Experiments (IP 69745) Scope The inspector reviewed selected aspects of:

o experimental program requirements, e precedures, e logs and records, and e experimental administrative controls and precaution Observations and Findinas The observed experiments at the facility were routine procedures (i.e., irradiation of environmental samples). The experiment authorization verified type of material, expected radiation levels, and precautions, and was approved by reactor facility management, and health physics management. The experiment was completed with the cognizance of the reactor operator. The conduct of the experiments was documented in appropriate experimental records. Engineering and radiation protection controls were implemented as required to limit and monitor exposure to radiatio Conclusions The program for experiments satisfied TS and procedural requirement . NPR Procedures (IP 42745) Insoection Scope To determine whether facility proce'iures met TS requirements, the inspector reviewed selected aspects of:

e health physics procedures, e administrative procedures, and a procedural reviews and update _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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b. Observations and Findinos Health physics procedures were acceptable for the facility and the current staffing level. However, the licensee acknowledged that the health physics procedures needed to be reviewed and upgraded. This project was in progress during the inspection. The licensee was informed that the NRC would follow the revision and upgrade of the health physics procedures as an inspector Follow-up item (IFI) and would review the issue during a future inspection (IFl 50-193/99-201-01).

Health physics surveys and activities were observed during the inspectica and adherence to procedure was noted with one exception. When the individual who typically completes the rc _ tine surveys at the facility is absent for some reason, there have been occasions when no one has filled in to perform the surveys or document the fact that no survey was necessary because no reactor operations occurred during that day. The licensee acknowledged this situation and indicated that a system had been established to provide a " backup" as needed. Since this

" backup" system was not functioning properly, the licensee was considering further steps to correct the problem. This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation (NCV), consistent with Section IV of the NRC Enforcement Policy (NCV 50-193/99-201-02).

c. Conclusions Health physics procedures were in the process of being reviewed and updated as neede . Radiation Protection Program (83743)

a. Insoection Scoce The inspector reviewed the following to verify compliance with 10 s FR 20 and the applicable licensee TS requirements and procedures:

• radiation and contamination survey records, e radiological signs and posting, e do:imetry records (personnel and environmenta;),

e calibration and periodic check records for radiation monitoring instruments, e the Radiation Protection Program, e the ALARA Program, e the Bioassay Program, and e the Radiation Protection Training Program.

- The inspector also toured the licensee's facility and observed the use of dosimetry and radiation monitoring equipment. Licensee personnel were interviewed as wel I n

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b. Observations and Findinas (1) Surveys Daily, weekly, and monthly contamination and radiation surveys were completed by a reactor operator who also had the recponsibility of and training to perform health physics duties as required by TS and licensee procedures. Another staff member, a Health Physicist, peiformed these duties on occasion. Results were evaluated and corrective actions taken when readings or results exceeded set action level (2) Postings and Notices Copies of current notices to workers required by 10 CFR Part 19 were posted in appropriate areas in the facility. With one exception, copies of NRC Form-3 posted at the facility were the latest issue. The one exception was I brought to the attention of the licensee and a current form was immediately posted. This failure constitutes a violation of minor significance and is being '

treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Polic_y (NCV 50-193/99-201-03).

(3) Dosimetry The licensee used a National Voluntary Laboratory Accreditation Program (NVLAP) accredited vendor to process personnel film badge /thermoluminescent dosimetry. An examination of the records for the past two years through the date of the inspection showed that all exposures were well within NRC limits. Dosimetry was readily available and acceptably used by facility personne (4) Radiation Monitoring Equipment Examination of selected radiation monitoring equipment demonstrated that the instruments had the acceptable up-to-date calibration sticker attache The calibration of portable survey meters was typically completed by on-site personnel. Calibration frequency met procedural requirements and records were maintained as require (5) Radiation Protection Program The licensee's Radiation Protection Program was established and described in a document entitled " Radiation Safety Guide," Revision March 1995. The program contained instructions concerning audits, personnel responsibilities, and ALARA, and appeared to be acceptabl .

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The licensee did not routinely use respirators for radiological work. However, the licensee was aware that respirators might be needed for some upcoming

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projects at the facility, if it were to become necessary to use respiratory protective devices at the facility, the licensee was aware that they would need to establish an appropriate Respiratory Protection Program, that training would need to be conducted, that bicassays would need to be completed, that annual personnel physicals would need to be conducted, and that the equipment would need to be checked and maintaine (6) ALARA Program As noted above, the ALARA Program was outlined and established in the

" Radiation Safety Guide," Revision March 1995. The ALARA program provided guidance for keeping doses as low as reasonably achievAle and was consistent with the guida,ce in 10 CFR 2 (7) Facility Tours The inspector toured the control room, selected support laboratories, and other areas with a licensee representative on various occasions. The inspecto' :oted that the facility's radioactive material storage areas were l properly posted. No unmarked radioactive material was noted. Radiation and High Radiation Areas were posted as required.

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(8) Bioassays

, The inspector inquired about the licensee's bioassay program at the facilit l l

It was noted that the licensee does not currently have a bioassay program, if one is required to support operations in the future, the licensee is aware that an effective program will need to be developed and implemente l (9) Radiation Protection Training The inspector reviewed the training given to RINSC staff members and those who are authorized to use the experimentai facilities of the reactor. The training program was being revised and upgraded so that authorized users and all radiation workers, including RINSC staff, will be required to receive biennial training. The inspector noted that currently all staff members have received the required trainin The licensee was informed that the NRC would follow the revision and upgrade of the training program as an inspector Follow-up Item (IFI) and would review the issue during a future inspection (IFl 50-193/99-201-04).

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Conclusions Surveys were completed within the time frame prescribed by TS. Posbni,s met regulatory requirements. Personnel dosimetry was being worn as required and recorded doses were within the licensee's procedural action levels and the NRC's regulatory limits. Radiation nonitoring equipment was being maintained and calibrated as required. The Radiation Protection Program and the ALARA Program satisfied regulatory requirements. The radiation protection training program was beirg revised and upgrade . Effluent and Environmental Monitoring (80745) Inspection Scope The inspector reviewed the following to verify compliance with the requirements of 10 CFR 20 and TS Sections 4.7 s id 6.8.4

• the licensee's environmental monitoring program, e annual effluent monitoring and environmental surveillance program reports, i and

• counting and analysis record Observation and Findinos i

The inspector determined that gaseous releases continued to be monitored as required, were acceptably documented, and were well within the annual dose constraint of 10 CFR 20.1101 (d), Appendix B concentrations, and TS limits. The liquid releases from the facility to the sanitary sewer were within the limits specified in 10 CFR 20, Appendix B, Table 3.

I I Conclusion Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limit . Transportation (86740) Insoection Seone i

The inspector interviewed licensee personnel and reviewed various records to verify compliance with regulatory and procedural requirements for transferring / shipping licensed materia ___

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Through records reviews and discussions with licensee personnel, the inspector determined that the licensee had shipped solid waste in accordance with the requirements specified in the regulations. The training of the staff members responsible for shipping the material met the minimum requirements specified in the regulation Conclusions Radioactive material was shipped in accordance with the applicable regulation . Physical Security (81401, 81402,' 81431) Insoection Scope To verify compliance with the licensee's NRC-approved Physical Security Plan and to assure that changes, if any, to the plan had not reduced its overall effectiveness, the inspector reviewed

e logs, records, and reports, e securit'/ systems, equipment, and instruments, and o' implementation of the Physical Security Pla Observations and Findinas The Physical Security Plan (PSP) was the same as the latest revision approved by the NRC. The offsite support letter of agreement with the local police department was current and police pert.onnel understood their responsibilities. Physical protection systems (barriers and alarms), equipment, and instrumentation were as required by the PSP. The access controls implemented at the facility were as required. Implementing procedures and practices were consistent with the PS Acceptable security response and support in accordance with procedures and training were demonstrated through alarm response record Conclusions Security activities and systems satisfied Physical Security Plan requirement . Material Control and Accounting (85102) inspection Scope

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To verify compliance with 10 CFR 70, the inspector reviewed:

e nuclear material inventory and locations, and e accountability record Observations and Findinas The material control and accountability program tracked locations and content of ful and fission detectors under the research reactor licerise. The inventory of material was verified to be consistent with material accountability record Possession and use of special nuclear material (SNM) were limited to the locations and purposes authorized under the license. The latest material control and accountability forms (DOE /NRC Forms 741 and 742) had been prepared and transmitted as require Conclusions Special Nuclear Materials were acceptably controlled and inventorie . Year 2000 Concerns Review Insoection Scone ,

To determine the status of the licensee's preparations to deal with the potential problems caused by the Year 2000 (Y2K), the inspector reviewed:

e the licensea's operating system, e the licensee's security system, e the co~unting system used at the facility, and e the Rhode Island and URI approach to the proble Observations and Findings The licensee had reviewed their operations, counting, and security system Nothing had been identified that would pose a problem to the reactor operations and no instances were identified that could pose a threat to public health and safety. The licensee did identity a problem concerning Y2K in the counting system used at the facility. In order to correct the problem, the licensee had purchased new computer equipment and new counting software from the vendor, Canberr The licensee had asked the security system vendor to supply them with a letter .

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1 documenting that the security system.was Y2K compliant. As of the date of the

inspection the security system had not been verified as Y2K compliant but the l licensee was continuing efforts to obtain such a statement from the security vendor, ADT Security Services, Inc. The State of Rhode iciand government and j URI had also analyzed the Y2K status state and campus-wide and were taking I actions as needed.

l l l The licensee was informed that the NRC would follow the issue of obtaining verification of Y2K compliance from the security vendor as an IFl and would review the ;ssue during a future inspection (IFl 50-193/99-201-05). Conclusions No problems had been identified concerning reactor operations. Y2K issues in the area of counting potentially contaminated samples were being addresse . Exit interview The inspection scope and results were summarized on March 26,1999, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector.

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Clement, Radiation Protection Officer J. Cunningham, Reactor Operator / Health Physics Technician J. Davis, Reactor Supervisor-in-Training

.D. Johnson, Health Physicist W. Simoneau, Assistant Director for Reactor Operations T. Tehan, Director, Rhode Island Nuclear Science Center Other Personnel J. Favreau, Sergeant, Narragansett Police Departmen H. Knickle, Chairman, Nuclear and Radiation Safety Committee M. Levinson, ADT Security Services, In B. Mosher, Research Scientist, University of New Hampshire F. Pascale, Lieutenant, University of Rhode Island Campus Police V. Rose, Chairman, Rhode island Atomic Energy Commission INSPECTION PROCEDURES USED IP 39745: Class 1 Non-Power Reactors Organization, Operations, and Maintenance Activities IP 40745: Class 1 Non-Power Reactors Review and Audit and Desirjn Change Functions IP 42745: Class 1 Non-Power Reactor Procedures IP 60745 Class 1 Non-Power Reactors Fuel Handling

'IP 61745 Class 1 Non-Power Reactors Surveillance IP 69745 Class 1 Non-Power Reactors Experiments IP 80745: Class 1 Non-Power Reactor Environmental Protection IP 83743: Class 1 Non-Power Reactor Health Physics

. IP 81401: . Plans, Procedures, and Reviews IP 81402: Reports of Safeguards Events f IP 81431: Fixed Site Physical Protection of Special Nuclear Material of Low Strategic Significance IP 85102: Msterial Control and Accounting - Reactors IP 86740: Inspection of Transportation Activities

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ITEMS OPENED, CLOSED, AND DISCUSSED Onened

50-193/99-201-01 IFl Follow-up on the licensee's efforts to revise and upgrade the I facility health physics procedures.

! 50-193/99-201-02 NCV Failure to perform a survey or document the fact that no survey was necessary because no reactor operations occurred during that da /99-201-03 NCV Failure to post the latest copy of NRC Form-3 at one location in the facilit /99-201-04 IFl Follow-up on the licensee's program to revise and upgrade the radiation protection training progra /99-201-05 IFl Follow-up on the issue of the licensee obtaining verification of Y2K compliance from the security vendo Closed 50-193/99-201-02 NCV Failure to perform a survey or document the f act that no survey was necessary because no reactor operations occurred during that da /99-201-03 NCV Failure to post the latest copy of NRC Form-3 at one location in the facilit LIST OF ACRONYMS USED ALARA As low as reasonably achievable CFR Code of Federal Regulations HP Health physics (FI Inspector Follow-up Item IP inspection Procedure Mw Mewawatt NCV Non-Cited Violation NPR Non-Power Reactor NRC Nuclear Regulatory Commission NRSC Nuclear and Radiation Safety Committee NVLAP National Voluntary Laboratory Accreditation Program PDR Public Document Room i

PE Professional Engineer RIAEC Rhode Island Atomic Energy Commission RINSC Rhode Island Nuclear Science Center SNM Special Nuclear Material TS Technical Specification

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