IR 05000193/2013202

IR 05000193-13-202, on September 16-19, 2013, Rhode Island Atomic Energy Commission

ML13276A487
Person / Time
Site:	Rhode Island Atomic Energy Commission
Issue date:	11/07/2013
From:	Gregory Bowman Research and Test Reactors Licensing Branch
To:	Goodwin C State of RI, Atomic Energy Comm, Nuclear Science Ctr
Bassett C
References
IR-13-202
Download: ML13276A487 (21)

Text

November 7, 2013 Dr. C. Goodwin, Director, Director Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 SUBJECT: RHODE ISLAND ATOMIC ENERGY COMMISSION - NRC ROUTINE INSPECTION REPORT NO. 50-193/2013-202 The U.S. Nuclear Regulatory Commission (NRC or the Commission) conducted an inspection from September 16-19, 2013, at the Rhode Island Nuclear Science Center Reactor facility (Inspection Report No. 50-193/2013-202). The enclosed report documents the inspection results, which were discussed on September 19, 2013, with you and members of your staff, as well as three members of the Rhode Island Atomic Energy Commission, and during a subsequent telephone call on October 23, 2013, with you and members of your staff to discuss digital instrumentation and control upgrades.

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 inspectors 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 Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

C. Goodwin -2-Should you have any questions concerning this inspection, please contact Craig Bassett at 301-466-4495 or by electronic mail at Craig.Bassett@nrc.go

Sincerely,

/RA/

Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-193 License No. R-95 Enclosure:

NRC Inspection Report No. 50-193/2013-202 cc: Please see next page

Rhode Island Atomic Energy Commission Docket No. 50-193 cc:

Governor Dr. Nancy E. Breen 222 State House Room 115 Marine and Natural Sciences Building 226 Providence, RI 02903 Roger Williams University One Old Ferry Road Dr. Stephen Mecca Bristol, RI 02809 Rhode Island Atomic Energy Commission Providence College Dr. Bahram Nassersharif Department of Engineering-Physics Dean of Engineering Systems University of Rhode Island River Avenue 102 Bliss Hall Providence, RI 02859 Kingston, RI 20881 Dr. Clinton Chichester, Chairman Dr. Peter Gromet Rhode Island Atomic Energy Commission Department of Geological Sciences College of Pharmacy Brown University Pharmacy Building Providence, RI 02912 7 Greenhouse Road Kingston, RI 02881 Supervising Radiological Health Specialist Office of Occupational and Radiological Dr. Jack Breen, Chairman Health Nuclear and Radiation Safety Committee Rhode Island Department of Health Providence College 3 Capitol Hill, Room 206 Department of Chemistry and Biochemistry Providence, RI 02908-5097 549 River Avenue Providence, RI 02918 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML13276A487 * via e-mail TEMPLATE #: NRC-002 OFFICE NRR/DPR/PROB* NRR/DPR/PROB NRR/DPR/PROB NAME CBassett OFont GBowman DATE 10/ 3 /13 10/ 3 /13 10/ 7 /13

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-193 License No: R-95 Report No: 50-193/2013-202 Licensee: Rhode Island Atomic Energy Commission Facility: Rhode Island Nuclear Science Center Research Reactor Location: Narragansett, Rhode Island Dates: September 16-19, 2013 Inspectors: Craig Bassett Ossy Font Approved by: Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY Rhode Island Atomic Energy Commission Rhode Island Nuclear Science Center Reactor Facility NRC Inspection Report No. 50-193/2013-202 The primary focus of this routine, announced operations inspection was the onsite review of selected aspects of the Rhode Island Atomic Energy Commission (the licensees) two megawatt Class I research reactor safety program including: (1) organizational structure and functions, (2) review and audit and design change functions, (3) reactor operations, (4) operator requalification, (5) maintenance and surveillance, (6) fuel handling, (7) experiments, (8) procedures, and (9) emergency preparedness. The review covered the period of time from the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas to the present.

The licensees program was acceptably directed toward the protection of public health and safety and was generally in compliance with the NRC requirements. One Severity Level IV non-cited violation was identified.

Organizational Structure and Staffing

• The organization structure and staff functions were observed to be generally in accordance with Technical Specification (TS) requirements.

• The position of facility Radiation Safety Officer was vacant.

Review and Audit and Design Change Functions

• The Nuclear and Radiation Safety Committee was meeting as required and reviewing the topics outlined in the TS. Audits were being completed as required.

• Design changes were being completed in accordance with the requirements specified in Title 10 of the Code of Federal Regulations Section 50.59.

• One unresolved item was identified associated with digital instrumentation and control modifications to the facility.

Reactor Operations

• Reactor operations, as well as operator cognizance of facility conditions during startup and routine operation, were acceptable.

Operator Requalification

• Operator requalification was being completed as required by the licensees Requalification Program and the program was being maintained up-to-date.

• Operators were receiving their biennial physical examinations as require Maintenance and Surveillance

• The program established and implemented by the licensee was being used to effectively complete maintenance activities at the facility.

• The surveillance program currently in use by the licensee satisfied TS requirements.

Fuel Handling

• Fuel movements were conducted in accordance with TS and procedural requirements.

• Fuel inspections were being completed as required.

Experiments

• The program for reviewing, authorizing, and conducting experiments satisfied TS and procedural requirements.

Procedures

• The procedural review, revision, and implementation program satisfied the requirements of TS Section 6.5, Operating Procedures.

Emergency Preparedness

• The licensee maintained an effective emergency preparedness program through effective implementation of the Emergency Plan and the associated implementing procedures.

Self-Reported Violation of the Technical Specifications

• One non-cited violation was identified because the former Radiation Safety Officer did not have the required educational background specified in TS 6. REPORT DETAILS Summary of Facility Status The Rhode Island Atomic Energy Commissions (RIAEC or the licensee) Rhode Island Nuclear Science Center (RINSC) two megawatt Class I research reactor continued to be operated in support of research, service, education, training, and surveillance. During the inspection, the reactor was operated to irradiate samples. Organizational Structure and Staffing Inspection Scope (Inspection Procedure (IP) 69006 The inspectors reviewed the following regarding the licensees organization and staffing to ensure that the requirements of Sections 6.1, Organization and Management, and 6.2, Qualification of Personnel, of the RINSC Technical Specifications (TS) were being met:

• Resume of the current Facility Director

• RINSC organizational structure and staffing

• RINSC Annual Report for the period from July 1, 2011, through June 30, 2012, submitted to the NRC on August 30, 2012

• RINSC Annual Report for the period from July 1, 2012, through June 30, 2013, submitted to the NRC on August 29, 2013 Observations and Findings The inspectors reviewed facility staffing. It was noted that since the last inspection in the area of operations, the individual who had held the position of Facility Director had retired and a new person was selected to fill that positio The inspectors reviewed the background of the newly hired individual to verify this individual had the experience required by TS 6. It was also noted that the person who had been serving as the Assistant Director for Radiation and Reactor Safety/Radiation Safety Officer (RSO) had left the facility. At the time of the inspection, the position of RSO was vacant and RIAEC was in the process of searching for a person with the proper educational credentials and work experience to fill that positio Conclusion The organizational structure and staffing were observed to be in general accordance with TS requirements. At the time of the inspection, the RSO position was vacan . Review and Audit and Design Change Functions Inspection Scope (IP 69007)

The inspectors reviewed the review and audit and design change functions and selected aspects of the following to ensure compliance with TS Section 6.4, Review and Audit:

• Nuclear and Radiation Safety Committee (NRSC) Charter, Rev. 2, approval dated February 2012

• NRSC meeting minutes from February 2012 through the date of this inspection

• 50.59 screen/review forms for the following modifications or changes dealing with digital instrumentation and control:

- Reactor Rod Control Equipment Change, NRSC approval dated June 14, 2007

- Installation of Digital Instrumentation and Control for the Reactor Cooling System, NRSC approval dated April 25, 2011

- Installation of Digital Instrumentation and Control, NRSC approval dated February 22, 2012

- Reversing the Logic of the Scram and Alarm circuits of the Neutron Flux Monitor Non-Op system to allow for proper operation with upgraded equipment and additional safeguards, NRSC review and approval dated February 22, 2012

- Neutron Flux Monitor modification to make detector HV supply variable, run the low HV scram through the alarm relay, set the non-operate relay trip at 830VDC, and tie the relay trip to the Inst Trouble annunciator indication, NRSC approval dated December 15, 2004

- Neutron Flux Monitor Non-Operate indicator light problem, NRSC approval dated April 19, 2006

- Neutron Flux Monitor, NRSC approval dated April 25, 2011

• 50.59 screen/review forms for the following modifications or changes dealing with the Rabbit Irradiation System: Rabbit Transportation System Upgrade, NRSC approval via electronic mail

• RINSC Operating Procedures, AP-03, Facility Modifications, Rev. 0, NRSC approval dated March 1, 2013

• RINSC Annual Report for the period from July 1, 2011, through June 30, 2012, submitted to the NRC on August 30, 2012

• RINSC Annual Report for the period from July 1, 2012, through June 30, 2013, submitted to the NRC on August 29, 2013 Observations and Findings (1) Review and Audit Functions The inspectors reviewed the NRSC meeting minutes and associated records from February 2012 through the present. The records showed that meetings were being held and safety reviews and audits were conducted by various members of the NRSC or other designated persons

-3-as required and at the TS-required frequency. Topics of these reviews and audits were consistent with TS requirements to provide guidance, direction, and oversight for the facility, and acceptable use of the reacto (2) Design Change Functions Through interviews with licensee personnel, the inspectors determined that various changes had been initiated and/or completed at the facility since the last NRC inspection. The inspectors reviewed the Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59 review process used at the facility. It was noted that the licensee had developed a new procedure to provide guidance during the 10 CFR 50.59 review and evaluation process. The inspectors noted that the recent reviews that had been conducted had been presented to the NRSC for review and approva During this review, it was noted that various 10 CFR 50.59 reviews dealt with digital instrumentation and control modifications made at the facilit The licensee had reviewed these changes under the requirements in 10 CFR 50.59, and concluded that the changes did not require prior NRC approval. The design change review had been conducted as directed by procedure and had been reviewed and approved by the NRS However, during the inspection, the inspectors discussed with the licensee whether the modification had introduced the possibility of a common cause failure and whether the newly installed equipment was of high quality. This issue was also discussed during a conference call with the licensee and other NRC staff members on October 23, 2013. The licensee was informed that this issue will be tracked as an unresolved item and that it will be reviewed and dispositioned during a future inspection (URI 50-193/2013-202-01). Conclusion The NRSC was meeting as required and reviewing the topics outlined in the T Audits were being completed as required. An unresolved item was identified concerning design changes associated with the reactors instrumentation and control system.

3. Reactor Operations Inspection Scope (IP 69006)

The inspectors reviewed selected portions of the following documents to verify that the licensee was operating the reactor and documenting activities in accordance with TS Sections 6.1 and 6.2 and procedural requirements:

• Reactor Logbook No. 59, covering the period from December 6, 2011, through the present

• Periodic Maintenance Notebook containing the documentation of maintenance items

-4-

• Reactor Operating Procedure OP-01, Reactor Operation Request, Re , NRSC approval dated December 4, 2009

• Reactor Operating Procedure OP-02, RINSC Pre-Start Checkout, Re , NRSC approval dated April 25 2011

• Reactor Operating Procedure OP-03, Reactor Power Changes, Rev. 5, NRSC approval dated March 1, 2013

• Reactor Operating Procedure OP-04, Abnormal Procedures, Rev. 3, NRSC approval dated March 1, 2013

• Procedure AP-05, Acting Facility RSO, Rev. 0, NRSC approval dated April 25, 2013

• RINSC Annual Report for the period from July 1, 2011, through June 30, 2012, submitted to the NRC on August 30, 2012

• RINSC Annual Report for the period from July 1, 2012, through June 30, 2013, submitted to the NRC on August 29, 2013 Observations and Findings The inspectors reviewed and observed reactor operations and procedures including the pre-start checkout and reactor start-up. The procedures require that the acting RSO be on site during operation of the reactor. The inspectors confirmed that the licensee generally followed these procedure A senior reactor operator (SRO) and the Reactor Supervisor (also an SRO) were interviewed about the operation of the facility. Both appeared knowledgeable and were cognizant of facility conditions. The inspectors also reviewed portions of the most recent reactor logbook to verify compliance with the staffing requirements of TS 6.1.2 and 6. Conclusion Reactor operations, as well as operator cognizance of facility conditions during startup and routine operation, were acceptable.

4. Operator Requalification Inspection Scope (IP 69003)

The inspectors reviewed selected aspects of the following to ensure compliance with the licensees operator requalification program outlined in RINSC Administrative Procedure (AP) AP-02, Reactor Operator Requalification, NRSC approval dated June 29, 2005:

• Reactor Logbook No. 59, covering the period from December 6, 2011 through the present

• Individual reactor operator (RO) and SRO requalification files containing copies of the following:

- Operator Requalification Program Checklist

- Annual Operational Requalification Exam forms

- Biennial Operator Requalification Examinations

-5-

- Letters from the NRC to the licensed operators documenting the issuance of an RO or SRO license

• Copies for each individual of their respective NRC Form 396, Certification of Medical Examination by Facility Licensee

• American National Standards Institute/American Nuclear Society 15.4-2007, Selection and Training of Personnel for Research Reactors, Section 7, Medical Certification and Monitoring of Certified Personnel Observations and Findings There were four qualified SROs on staff at the facility. A review of the logs and records showed that training was being conducted in accordance with the licensees requalification and training program. Procedure reviews and examinations had been documented as required. Information regarding facility changes and other relevant information had been routed under the Crew Review process and licensed operators acknowledged their review of this informatio The inspectors verified that quarterly reactor operations, reactivity manipulations, other required operations activities, and Reactor Supervisor activities were being completed as required and the appropriate records were being maintaine Records indicating the successful completion of the annual operations tests and supervisory observations were also maintained. The program was being maintained up-to-dat Biennial written examinations were being completed by the operators as required. The inspectors reviewed the last biennial requalification examinatio It was noted that the exam was similar in its level of difficulty as compared to NRC-administered examination The inspectors also noted that all operators were receiving biennial medical examinations within the allowed time frame as require Conclusion Operator requalification was being conducted in accordance with the licensees operator requalification program. Operators were receiving their biennial physical examinations as required.

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

The inspectors reviewed the following to verify compliance with TS Section 3.0, Limiting Conditions for Operation, and to determine if the periodic surveillance tests on safety systems were performed as stipulated in TS Section 4.0, Surveillance Requirements:

• RINSC Maintenance 2013 Rev. 0 (spreadsheet)

• Instrumentation Calibration Notebook and associated documents

• Maintenance Notebook and associated documents including:

- Calibration Procedure CP-04, Rev. 7, dated July 29, 2013

-6-

- Form NSC-1A

• Secondary Water Analysis Notebook and associated documents including:

- Maintenance Procedure MP-04

- Form NSC-3A

• Confinement System Notebook and associated documents including:

- Maintenance Procedure MP-10

- Form NSC-14B

• RINSC Annual Report for the period from July 1, 2011, through June 30, 2012, submitted to the NRC on August 30, 2012

• RINSC Annual Report for the period from July 1, 2012, through June 30, 2013, submitted to the NRC on August 29, 2013 b. Observations and Findings (1) Maintenance The inspectors reviewed licensees tracking mechanism for maintenance and surveillance activities. The inspectors observed a secondary water sample survey, evacuation alarm system test, and an annual inspection of the reactor building foundation wall. The inspectors verified that these activities were completed in accordance with TS and licensee procedures, and that the results met NRC requirement The maintenance records indicated that problems were addressed and preventive maintenance operations completed as required by procedur Records showed that routine maintenance activities were conducted at the required frequencies and in accordance with the TS and/or the applicable procedur (2) Surveillance The inspectors reviewed surveillance records, including nuclear instrumentation calibration and alarm, scram, and interlock check sheet The data recorded in the reactor logbooks and on the surveillance records indicated that the verifications and calibrations had generally been completed on schedule and in accordance with licensee procedures. The results reviewed by the inspectors were noted to be within the TS and procedurally-prescribed parameters. Maintenance and surveillance activities ensured that equipment remained consistent with the Safety Analysis Report and TS requirements.

c. Conclusion The program for conducting maintenance and for completing surveillance activities was being carried out in accordance with TS and procedural requirement . Fuel Handling and Movement Inspection Scope (IP 69009)

The inspectors reviewed the following to verify compliance with TS 4.9.b and 6.9.1.g, which require visual inspection of fuel elements every 5 years on a rotating basis and maintenance of record associated with fuel inventories and transfers, respectively:

• Reactor Logbook No. 59, covering the period from December 6, 2011, through the present

• Inspection Procedure IP-01, Core Element Movement and Inspection, Rev. 0, NRSC approval dated December 4, 2009

• Reactor Data Notebook; fuel element inspection sheet and 10 year forecast Observations and Findings The inspectors reviewed the fuel movement process and verified that fuel was moved according to established procedure and inspected in accordance with a specific inspection schedule. The inspectors reviewed selected fuel movement sheets and interviewed facility staff about the process. The sheets had been developed and used for core refueling and performing inspections of fuel elements. It was noted that fuel inspections had been completed and that the inspection documents contained descriptions of fuel conditions, as well as any discolorations and marking The inspectors also compared the location of fuel elements in the reactor core with the information maintained on the fuel status board in the control room, on the current RINSC fuel status map, and on the fuel movement sheet for the latest core. No problems or anomalies were note Conclusion The licensee has made recent reactor fuel movements and has made additional changes to ensure fuel removed from the core was returned to previous or required locations. The licensee followed written procedures that met TS requirements.

7. Experiments Inspection Scope (IP 69005)

The inspectors reviewed selected aspects of the following to verify that the licensee was in compliance with TS Sections 3.1, 3.8, 4.1, and 4.8:

• Reactor Logbook No. 59, covering the period from December 6, 2011, through the present

• Experimental administrative controls and precautions

-8-

• Operating Procedure OP-01, Reactor Operation Request, Rev. 2, NRSC approval dated December 4, 2009

• Operating Procedure XP-01, Reactor Experiment Request

• Operating Procedure XP-02, Reactor Experiment Approval

• Operating Procedure XP-03, Rabbit Irradiations, Rev. 1, NRSC approval dated February 22, 2012

• Operating Procedure XP-04, Incore Irradiations, Rev. 1, NRSC approval dated December 4, 2009

• Operating Procedure XP-10, Dry Irradiation Facility Irradiations, Rev. 0, NRSC approval dated November 2, 2011

• Operating Procedures XP-12, Gamma Tube Irradiations, Rev. 1, NRSC approval dated December 4, 2009 Observations and Findings The majority of the experiments conducted at the facility were ones that have been in place for several years. However, since the last inspection in this area, two new experiments had been reviewed and approved. The experiments involved activation of various materials. The inspectors verified that the experiment proposal included a discussion of the proposed experiment, as well as the hazards involved and the anticipated results. The experiments had been reviewed and approved by the reactor staff and were subsequently reviewed and approved by the NRSC as require The inspectors verified that the appropriate irradiation request forms for the various operations were completed and approved as required. The inspectors also noted that the experiments that had been conducted were completed using approved methods and with the cognizance of the SRO in charge and the acting RSO, in accordance with TS and procedural requirements. The experiments were documented on the appropriate forms and in the operations log as require Engineering and radiation protection controls were implemented as required to limit exposure of the workers handling the irradiated experiment sample Conclusions The program for reviewing, authorizing, and conducting experiments satisfied TS and procedural requirements.

8. Procedures Inspection Scope (IP 69008)

To verify that facility procedures were being prepared, reviewed, revised, and implemented as required by TS Section 6.5, Operating Procedures, the inspectors reviewed selected aspects of:

• Reactor Logbook No. 59, covering the period from December 6, 2011, through the present

• Operating Procedure AP-03, Facility Modifications, Rev. 0, NRSC approval dated March 1, 2013

-9-

• Operating Procedure, AP-05, Acting Facility RSO, Rev. 0, NRSC approval dated April 25, 2013

• NRSC meeting minutes from July 2011 through the date of this inspection Observations and Findings Procedures had been developed for the safe, routine operation of the reacto Records showed that procedures for potential malfunctions (e.g., radioactive releases and contaminations, and abnormal events) had also been developed and were available. The inspectors noted that procedural changes were being reviewed and approved by the NRSC as required by TS. Through observation of various activities at the facility, including reactor operation and sample handling, the inspectors determined that licensee personnel conducted activities in accordance with applicable procedure During the review of two recently developed procedures, the inspectors noted that some issues needed to be clarified or revised in these document Specifically, Procedure AP-03, Facilities Modifications, inappropriately excluded all procedure changes from the scope of review under 10 CFR 50.5 Additionally, Procedure AP-5, Acting Facility RSO, required the acting RSO to be present during certain activities, such as surveillance testing, when this hadnt been the licensees intent when the procedure was develope During the inspection, the licensee indicated that they intend to review these two procedures and make revisions to address these issues, if appropriate. The licensee was informed that the revision of procedures AP-03 and AP-05 would be followed up by the NRC as an inspector follow-up item and would be reviewed during a future inspection (IFI 50-193/2013-202-02). Conclusions The procedural review, revision, and implementation program satisfied TS Section 6.5 requirements.

9. Emergency Preparedness Inspection Scope (IP 69011)

The inspectors reviewed the following documents and visited the support organizations discussed below to verify compliance with regulatory requirements and the RINSC Emergency Plan, Rev. 4:

• RINSC Emergency Procedure EP-01, Emergency Plan Implementing Procedures, Rev. 2, dated July 29, 2013

• Documentation of [Emergency] Communication Tests conducted with various support agencies

• Forms documenting the completion of annual Emergency Equipment Inventories

- 10 -

• Letter of Agreement between Narragansett Police Department and RINSC, signed by Mr. M. J. Davis and by Chief Hoxie on December 22, 2011

• Letter of Agreement for Medical Services, from John B. Murphy MD, Vice President of Medical Affairs, Rhode Island Hospital, to Mr. T. Tehan, RIAEC, dated February 11, 2012

• Letter of Agreement between Narragansett Fire Department and RINSC, signed by Mr. M. J. Davis and Chief J. Cotter dated December 16, 2011

• Rhode Island Hospital Emergency Department Procedures for Incidents with the Potential for Radiological Contamination b. Observation and Findings The inspectors reviewed the Emergency Plan in use at the reactor and verified that it was reviewed biennially as required. The inspectors reviewed the associated implementing procedures, as well, and noted that they were also reviewed biennially and revised as neede Through records review and interviews with staff personnel (e.g., emergency responders), the inspectors determined that they were knowledgeable of the proper actions to take in case of an emergency. Training for these individuals was accomplished annually through evacuation and emergency drill participatio Training for support organization personnel was provided whenever those organizations were available and/or requested such trainin The inspectors verified that the letters of agreement that had been established between the RINSC facility and the Narragansett Police and Fire Departments remained in effect. These agreements stipulated that the Police and Fire Departments would be available during an emergency and would provide support for the facility. The inspectors also verified that the agreement between the reactor facility and the Rhode Island Hospital remained in effect. That agreement indicated that the hospital would provide RINSC personnel with needed support in case of any event involving a medical emergenc Communications capabilities with support groups were acceptable and the various items of equipment (e.g., telephones and the building public address system) were in use daily. Portable radios were also available for use as needed and were checked annually. Emergency call lists had been revised and updated as needed and were available in the control room and in the various areas around the facility as required. The inspectors also verified that emergency equipment, including decontamination material, was available and was being inventoried at least annually as required by the Emergency Pla The documentation of the training and drills conducted during the past 2 years was reviewed. Through drill scenarios and records review, and personnel interviews, off-site emergency responders were determined to be knowledgeable of the proper actions to take in case of an emergency. Emergency and evacuation drills had been conducted annually as required by the Emergency Plan. Critiques following each drill had been conducted as required and the results documente The inspectors visited the facilitys Emergency Support Center and observed the emergency supplies, instruments, and information maintained in the locker located there in accordance with the Emergency Plan. An inventory of the items in the locker demonstrated that the stipulated items were there. The licensee maintained records indicating that the emergency supplies were inventoried on an annual basis as part of the surveillance program required by the Emergency Pla The inspectors visited the Rhode Island Hospital to verify their ability to handle the types of radiological emergencies that could occur at RINSC. The inspectors determined that there were adequate supplies and equipment available at the hospital to handle a radiation emergency. Through discussion with the hospitals medical staff, the inspectors noted that the personnel had the appropriate training and procedures were in place to handle the potential hazard Conclusion The licensee maintained an effective emergency preparedness program through effective implementation of the Emergency Plan and the associated implementing procedures.

10. Self-Reported Violation of the Technical Specifications Inspection Scope (IP 69006)

The inspectors reviewed the licensees actions taken in response to a self-identified violation of the TS 6. Observations and Findings TS 6.2.2.requires that the RSO have a masters degree in health physics or radiological health and 3 years of applied health physics experience in a program with radiation safety problems similar to those in the program to be manage During a phone call to the NRC Operations Center on April 24, 2013, the licensee informed the NRC that the individual who had been selected to serve as the facilitys RSO following the departure of the previous RSO did not have the educational credentials required by TS 6.2.2. Specifically, the individual did not have a masters degree in either health physics or radiological health, and this condition had existed for several months before it was identifie During the inspection, the inspectors discussed the self-identified TS violation with the licensee and interviewed various reactor staff personnel and confirmed that the licensee had, in fact, been in violation of TS 6.2.2. The circumstances of the event and the notifications were reviewed, and the inspectors verified that the licensee had taken appropriate corrective actions once the issue was identifie Specifically, the licensee shutdown the reactor and maintained it in that condition until a new individual meeting the educational and experience requirement was selecte The licensee was informed that the failure to have an RSO with the TS-required educational background was a Severity Level IV violation of TS 6.2.2. However, because of the individuals previous work experience and the short duration of the violation, the potential safety consequences of this issue were low. As indicated above, the inspectors determined that the problem had been identified by the licensee and promptly reported to the NRC, and corrective actions had been identified and implemented, as appropriate. As a result, the licensee was informed that this issue would be treated as a non-cited violation (NCV),

consistent with Section VI.A.8 of the NRC Enforcement Policy (NCV 50-193/2013-202-03). This issue is considered close Conclusion One NCV was identified associated with the licensees failure to have an RSO with the TS-required educational background as required by TS 6.2.2.

11. Exit Interview The inspectors presented the inspection results to licensee management at the conclusion of the inspection on September 19, 2013, and during a subsequent telephone conference call on October 23, 2013. The inspectors described the areas inspected and discussed in detail the inspection observations. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspectors during the inspectio PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel N. Breen Commissioner, Rhode Island Atomic Energy Commission C. Chichester Chairman, Rhode Island Atomic Energy Commission M. Damato Health Physics Technician and Principle Reactor Operator M. Davis Assistant Director, Rhode Island Nuclear Science Center C. Goodwin Director, Rhode Island Nuclear Science Center B. MacGregor Facility Engineer/Senior Reactor Operator S. Mecca Commissioner, Rhode Island Atomic Energy Commission Z. Richards Reactor Supervisor/ Senior Reactor Operator Other Personnel N. Jacob Certified Health Physicist, Office of Radiation Safety, Rhode Island Hospital R. Sciamacco Registered Nurse, Clinical Manager, Rhode Island Hospital INSPECTION PROCEDURES USED IP 69003 Class 1 Research and Test Reactor Operator Licenses, Requalification, and Medical Examinations IP 69006 Class 1 Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions 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 ITEMS OPENED, CLOSED, AND DISCUSSED Opened IR-50-193/2013-202-01 URI Follow-up on the issue of digital instrumentation and control modifications to the facility.

IR-50-193/2013-202-02 IFI Follow-up on the licensees efforts to revise and clarify facility procedures AP-03, Facility Modifications, and AP-05, Acting Facility RSO.

IR-50-193/2013-202-03 NCV The individual filling the Radiation Safety Officer position at the facility did not possess a masters degree in health physics or radiological health as required by TS 6. Closed IR-50-193/2013-202-03 NCV The individual filling the Radiation Safety Officer position at the facility did not possess a masters degree in health physics or radiological health as required by TS 6. LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Document Access Management System IFI Inspector Follow-up Item IP Inspection Procedure NCV Non-Cited Violation NRC U.S. Nuclear Regulatory Commission NRSC Nuclear and Radiation Safety Committee NSC Nuclear Science Center RIAEC Rhode Island Atomic Energy Commission RINSC Rhode Island Nuclear Science Center RO Reactor Operator RSO Radiation Safety Officer SRO Senior Reactor Operator TS Technical Specification URI Unresolved Item