IR 05000193/2019202
| ML19084A013 | |
| Person / Time | |
|---|---|
| Site: | Rhode Island Atomic Energy Commission |
| Issue date: | 03/26/2019 |
| From: | Anthony Mendiola Research and Test Reactors Oversight Projects Branch |
| To: | Goodwin C Rhode Island Nuclear Science Center |
| Takacs M, NRR/DLP/PROB, 415-2042 | |
| References | |
| IR 2019202 | |
| Download: ML19084A013 (17) | |
Text
March 26, 2019
SUBJECT:
RHODE ISLAND ATOMIC ENERGY COMMISSION - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT
NO. 05000193/2019202
Dear Dr. Goodwin:
From March 12-14, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Rhode Island Nuclear Science Center reactor facility. The enclosed report documents the inspection results which were discussed on March 14, 2019, with members of your staff, as well as Dr. Clinton Chichester, Chairman, Rhode Island Atomic Energy Commission.
The inspection examined activities conducted under your license, as they relate to public health and safety, by confirming compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of this inspection, no findings of non-compliance were identified. No response to this letter is required.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the 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). Should you have any questions concerning this inspection, please contact Mr. Michael Takacs at (301) 415-2042 or electronic mail at Michael.Takacs@nrc.gov.
Sincerely,
/RA/
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation
Docket No. 50-193 License No. R-95
Enclosure:
As stated
cc: See next page
Rhode Island Atomic Energy Commission
cc:
Governor 222 State House Room 115 Providence, RI 02903
Howard Chun, Commissioner Cranston High School East 899 Park Avenue Cranston, RI 02910
Dr. Clinton Chichester, Chairman Rhode Island Atomic Energy Commission College of Pharmacy Pharmacy Building 7 Greenhouse Road Kingston, RI 02881
Dr. John Breen, Chairman Nuclear and Radiation Safety Committee Providence College Department of Chemistry and Biochemistry 1 Cunningham Square Providence, RI 02918
Dr. Nitin Padture, Commissioner School of Engineering, Brown University 184 Hope Street, Box D Barus & Holley Building, Room 608 Providence, RI 02912
Dr. Yana K. Reshetnyak, Commissioner Department of Physics University of Rhode Island 2 Lippitt Road, East Hall Kingston, RI 02881
Dr. Nancy E. Breen, Commissioner Marine and Natural Science Building 226 Roger Williams University One Old Ferry Road Bristol, RI 02809
Docket No. 50-193
Supervising Radiological Health Specialist Office of Occupational and Radiological Health Rhode Island Department of Health 3 Capitol Hill, Room 206 Providence, RI 02908-5097
Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115
- concurred via e-mail
NRC-002 OFFICE NRR/DLP/PROB/SS*
NRR/DLP/PROB/LA*
NRR/DLP/PROB/BC NAME MTakacs NParker AMendiola DATE 3/25/19 3/25/19 3/26/19
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.:
50-193
License No.:
R-95
Report No.:
Licensee:
Rhode Island Atomic Energy Commission
Facility:
Rhode Island Nuclear Science Center Research Reactor
Location:
Narragansett, Rhode Island
Dates:
March 12 -14, 2019
Inspector:
Approved by:
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation
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EXECUTIVE SUMMARY
Rhode Island Atomic Energy Commission Rhode Island Nuclear Science Center Reactor Facility NRC Inspection Report No. 05000193/2019202
The primary focus of this announced, routine inspection was the onsite review of selected aspects of the Rhode Island Atomic Energy Commissions (RIAEC or the licensees) Class I, 2 megawatt research reactor safety program including: (1) review and audit and design change functions, (2) radiation protection, (3) effluent and environmental monitoring, (4) emergency preparedness, and (5) transportation activities. The review covered from the date of 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 in compliance with NRC requirements.
Review and Audit and Design Change Functions
- The review and audit program was being conducted acceptably and completed by the Nuclear and Radiation Safety Committee (NRSC), as stipulated in the facilitys technical specification (TS) Section 6.2.
- Changes made at the facility were being reviewed using guidance in the licensees Facility Modification Procedure, AP-03, and Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.59, Changes, tests, and experiments.
Radiation Protection
- Periodic surveys were completed and documented as required by procedure.
- Postings and signs met regulatory requirements.
- Personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits.
- Radiation survey and monitoring equipment was being maintained and calibrated as required.
- The radiation safety training program was acceptable and training was being completed as required.
- The exposure to radiation was kept as low as reasonably achievable (ALARA) and satisfied regulatory requirements.
Effluent and Environmental Monitoring
- Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
- The environmental protection program satisfied NRC requirements.
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- The licensee maintained an effective emergency preparedness program through implementation of the emergency plan (EP) and the associated implementing procedure.
Transportation Activities
- The shipments of radioactive material (RAM) made under the reactor license were in compliance with NRC and Department of Transportation (DOT) regulations.
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REPORT DETAILS
Summary of Facility Status
The licensees Rhode Island Nuclear Science Center (RINSC) Class I, 2 megawatt research reactor continued to be operated in support of research, development, education, training, and surveillance. During the inspection, the reactor was operated for research and development.
1.
Review and Audit and Design Change Functions
a. Inspection Scope (Inspection Procedure (IP) 69007)
The inspector reviewed selected aspects of the following with respect to the review and audit program and design change activities to ensure compliance with TS Section 6.2 and 10 CFR 50.59
- NRSC Charter, Revision 5, approval dated September 11, 2017
NRSC meeting minutes for 2018
RINSC Operating Procedure, AP-03, Facility Modifications, Revision 2
RINSC Annual Reports for 2017 and 2018
RINSC Radiation Safety Annual Review performed by the Radiation Safety Officer (RSO) for 2018
RINSC Radiation Safety and Operations Record Audits for 2018
Nuclear Safety Committee (NSC) forms NSC-24, 10 CFR 50.59 screen and NSC-51, 10 CFR 50.59 review for modifications or changes to the facility and/or procedures
b. Observations and Findings
(1) Review and Audit Functions
The inspector reviewed the NRSC meeting minutes and associated records for May and December of 2018. The minutes and records showed that meetings were being held and safety reviews and audits were conducted by various members of the NRSC or other designated persons as required, and at the required frequency. Topics of these reviews and audits were consistent with the TS requirement, which is to provide guidance, direction, and oversight for the facility, and acceptable use of the reactor.
(2) Design Change Functions
The inspector reviewed the 10 CFR 50.59 review process used at the facility. It was noted that the licensees procedure governing design changes provided guidance concerning the review of facility modifications and changes to procedures using the 10 CFR 50.59 review and evaluation process. Also, screening forms were used to determine whether or not a full 10 CFR 50.59 review and evaluation was required for any change being contemplated.
Through review of records and interviews with licensee personnel, the inspector determined that no changes had been proposed for the facility.
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c. Conclusion
The NRSC was meeting as required and reviewing the topics outlined in the TS.
Audits were being completed as required. Design change procedures and records were maintained up to date as required by the TS.
2.
Radiation Protection
a. Inspection Scope (IP 69012)
The following documents were reviewed to determine compliance with 10 CFR Part 19, Notices, Insturctions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, and with TS Sections 3.7.1 and 4.7.1 requirements regarding radiation protection:
- Radiation Safety training modules and records
RINSC Annual Reports for 2017 and 2018
RINSC Radiation Safety Annual Review performed by the RSO for 2018
RINSC Radiation Safety and Operations Record Audits for 2018
Copies of NRC Form 3, Notice to Employees, posted at the facility
Quarterly dosimetry reports for facility personnel from January 2017 through December 2018
RINSC Radiation Safety Office Radiation Safety Manual, dated February 2019
Selected survey program summary data and the associated survey reports for 2017 through the date of this inspection
Selected calibration records of area radiation monitors (ARMs) for the past 2 years
Survey meter calibration files documenting the calibration of various portable survey instruments for the past 2 years
b. Observations and Findings
(1)
Surveys
The inspector reviewed selected weekly, monthly, quarterly, and semi-annual radiation and contamination surveys. The surveys, which had been completed by trained staff members, were completed in a timely manner. Some areas/items were noted during these surveys with slightly elevated radiation levels, but all areas or materials were properly controlled. Results of the surveys were acceptably documented and posted as noted below.
During the inspection, the inspector accompanied the Reactor Health Physicist (RHP) during the performance of a routine weekly radiation and contamination survey of the reactor bay, control room, and the basement area within the confinement building, as well as several areas outside of the confinement building. The inspector noted that the techniques used by the RHP during the survey were proper and the survey was conducted and documented as required.
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(2) Postings and Notices
Radiological signs were posted at the entrances to controlled areas. Other postings also showed the industrial hygiene hazards that were present in the areas. Caution signs, postings, and controls for radiation areas and high radiation areas were posted as required in 10 CFR Part 20, Subparts G and J.
The inspector noted that licensee personnel observed the signs and postings and the precautions for access to the various controlled areas in the facility.
The inspector verified that copies of current notices to workers were posted in appropriate areas in the facility. The copies of NRC Form 3, Notice to Employees, noted at the facility were the latest issue and were prominently posted as required by 10 CFR 19.11, Posting of notices to workers. The locations where these forms were posted included on the main bulletin board in the hallway by the Radiation Safety Office, in the control room, and in the lunch room.
(3) Dosimetry Reports/Personnel Exposure
The inspector determined that the licensee used thermoluminescent dosimeters (TLDs) for staff and designated users whole body monitoring of beta, gamma, and neutron radiation exposure. The licensee also used TLD finger rings for extremity monitoring. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor. An examination of the TLD results indicating radiological exposures at the facility for the past 2 years showed that all of the occupational doses for facility personnel, as well as doses to the public, were within 10 CFR Part 20 limits. Through direct observation, the inspector determined that dosimetry was acceptably used by facility personnel. It was noted that the licensee provided dosimeters for monitoring the radiation exposure of tour groups and other visitors.
Copies of each licensee monitored individuals exposure information was maintained by the RSO. If an individual received greater than the licensees administrative level of 100 millirem occupational exposure, a report with the pertinent information (NRC Form 5 equivalent) was provided to the person as required by 10 CFR Part 19.
(4) Maintenance and Calibration of Radiation Monitoring Equipment
Examination of selected items of radiation monitoring equipment indicated that the instruments had the acceptable up-to-date calibration sticker attached.
Review of the instrument calibration records for various meters indicated the calibration of portable survey meters was completed by both licensee staff and contractor personnel depending on the type of calibration that was required.
The licensee typically conducted electronic calibrations while the vendor conducted source range calibrations. The inspector observed the RHP perform the electronic calibration of a survey meter. The RHP followed the proper calibration procedure and successfully completed and documented the calibration results. The inspector verified that the survey instruments were
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calibrated annually as required and the appropriate calibration records were maintained.
The inspector also reviewed the calibration and maintenance records of various ARMs. It was noted that the ARMs were being calibrated annually as required and were typically calibrated by licensee staff personnel. Records were current and acceptably maintained.
(5) Radiation Safety Training
The inspector reviewed the licensees radiation safety training program. It was noted that training was given to RINSC staff members, to those who were not on staff but who were authorized to use the experimental facilities of the reactor (Authorized Users), and to students taking classes at the facility. The training was typically given by the RSO at the facility. Initial radiation worker training was provided for those new to the facility. Following initial training, refresher training was required to be completed on an annual basis.
The initial training consisted of various subjects including: radiation safety, radiation detection, personnel dosimetry, ALARA, and radioactive waste management. Refresher training consisted of those subjects mentioned above as well as a review of the facility license, TSs, and procedures and NRC regulations. The inspector noted that refresher training also included any personnel contamination and/or higher than normal exposure issues that occurred during the past year, along with the preventive and corrective actions taken. The subjects covered during training appeared to be appropriate.
(6) Radiation Protection Program
The licensees Radiation Protection and ALARA programs were established and described in the RINSC Radiation Safety Office Radiation Safety Manual, dated February 2019. The programs were also outlined in, and implemented through, the RINSC facility radiation safety procedures that had been reviewed and approved. The programs contained instructions concerning organization, training, monitoring, personnel responsibilities, handling RAM, and maintaining doses under the ALARA concept. The program, as established, appeared to be acceptable and satisfied regulatory requirements.
The licensee did not have a respiratory protection program or planned special exposure program; neither program was required based on the current level of activity at the facility.
(7) Facility Tours
The inspector toured the facility with licensee representatives on various occasions and observed areas including the reactor bay, control room, the basement area, and selected support laboratories. The inspector noted that
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facility RAM storage areas were properly posted. No unmarked RAM was noted.
c.
Conclusion
The inspector determined that the Radiation Protection and ALARA programs, as implemented by the licensee, satisfied regulatory requirements. Specifically, (1) periodic surveys were completed and acceptably documented to permit evaluation of the radiation hazards present; (2) postings and signs met regulatory requirements; (3) personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits; (4) radiation survey and monitoring equipment was being maintained and calibrated as required; and (5) the radiation safety training program was being implemented as stipulated by procedure.
3.
Effluent and Environmental Monitoring
a. Inspection Scope (IP 69004)
The inspector reviewed the following to verify that the requirements of TS Sections 3.7.2 and 4.7.2 were being met:
- Stack continuous air monitor records
Environmental dosimetry records for 2017 through the present
Form MP-03, Primary water Analysis
Form MP-04, Secondary Water Analysis
RINSC Radiation Safety and Operations Record Audits for 2018
RINSC Radiation Safety Annual Review performed by the RSO for 2018
RINSC Annual Reports for 2017 and 2018
b. Observations and Findings
(1)
Environmental Radiation Monitoring
Environmental radiation monitoring was accomplished using TLDs placed at different monitoring stations. Since the areas monitored had limited public access, the licensee adjusted the readings by using an occupancy factor to approximate annual dose. After applying the annual occupancy factor, the results at those locations indicated dose rates less than the regulatory limit for members of the general public.
(2)
Gaseous Effluent Releases
The inspector determined that gaseous releases continued to be monitored as required, calculated according to procedure, and acceptably documented in the annual reports. The predominant environmental release from the facility was Argon-41 resulting from activated air entrained in the reactor pool water, present in beam tubes, and used for cooling pneumatic transfer tubes. The airborne concentrations of the gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2.
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Also, the dose rate to the public as a result of the gaseous releases was well below the dose constraint of 10 millirem per year (mrem/yr) specified in 10 CFR 20.1101, Radiation protection programs, paragraph (d). This was acceptably demonstrated by the licensee through COMPLY code calculations.
Additionally, observations of the interior and exterior of the facility by the inspector indicated no new potential release paths.
(3) Liquid Effluent Releases
A review of the liquid effluent releases from the facility to the sanitary sewer indicated that proper methods were followed prior to the releases. This included recirculation and sampling of the liquid, analyses of samples taken, and review and authorization of each batch. The releases were well within the monthly average concentration limits established in 10 CFR Part 20, Appendix B, Table 3.
(4) Effluent Monitoring Equipment Calibration and Maintenance
The inspector reviewed the calibration and maintenance records of the normal and backup stack monitors. It was noted that the stack monitors were being calibrated annually as required and were typically calibrated by licensee staff personnel. Records were current and acceptably maintained.
(5) Water Chemistry Analysis
During the inspection, the inspector accompanied the Principal Reactor Operator (PRO) to the primary coolant sampling area. The inspector noted that the PRO was knowledgeable on the primary coolant analysis system and the process for sampling and analyzing primary coolant. As required by TS Section 4.3.1.2, the primary coolant activity was analyzed monthly and the records of these results were properly maintained. No elevated levels of Cesium-137 or Iodine-131 were observed by the inspector.
c.
Conclusion
Effluent releases were within the specified regulatory and TS limits. The environmental protection program satisfied NRC requirements. Primary coolant analysis was being implemented as stipulated by TS.
4.
a. Inspection Scope (IP 69011)
The inspector interviewed staff members and reviewed various documents to verify compliance with regulatory requirements and the RINSC EP, Revision 6:
- Emergency Preparedness Notebook containing documentation of various activities including:
- Fire Alarm Tests
- Completion of annual emergency supply inventories documented on Form NSC-83
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- Emergency training and drills conducted during the past year
- Emergency communication tests conducted with various support agencies
RINSC Emergency Procedure-01, Emergency Plan Implementing Procedures, Revision 4, dated January 17, 2017
Letter of Agreement (LOA) between Narragansett Police Department and RINSC, signed by Mr. M. J. Davis and by Chief S. Corrigan, dated December 6, 2017
LOA for Medical Services, signed by L. Sivaprasad, MD, Vice President of Medical Affairs and Chief Medical Officer, Rhode Island Hospital, addressed to Dr. C. Goodwin, RIAEC, dated October 4, 2018
LOA between Narragansett Fire Department and RINSC, signed by Mr. M. J. Davis and Chief S. Partington on December 6, 2017
b. Observation and Findings
The inspector reviewed the EP in use at the reactor and verified that it was being reviewed and updated biennially as required. The inspector also reviewed the associated emergency procedure and noted that it was also reviewed biennially and revised as needed.
Through records review, including the recent annual drill report referencing the drill conducted on November 16, 2018, as well as interviews with licensee personnel, the inspector determined that staff were knowledgeable of the proper actions to take in case of an emergency. Training for licensee personnel was accomplished annually, typically following the evacuation and emergency drill. Emergency and evacuation drills were conducted annually as required by the EP. Training for offsite support organizations (i.e., police and fire departments) was provided whenever those organizations were available and/or when requested by the organization.
The inspector verified that the LOAs between the RINSC facility and the Narragansett Police Department and Narragansett Fire Department remained in effect. These agreements stipulated that police and fire personnel would respond during an emergency and would provide support for the facility. The inspector also verified that the agreement between the reactor facility and Rhode Island Hospital was current. That agreement ensured that the hospital would provide RINSC personnel with needed support in case a staff member became contaminated and needed emergency medical care.
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 were available in the control room and in various areas around the facility as required, as well as in the Emergency Support Center. The call list was being updated annually as required.
c. Conclusion
The licensee maintained an effective emergency preparedness program through implementation of the EP and the associated emergency procedure.
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5.
Transportation Activities
a. Inspection Scope (IP 86740)
The inspector reviewed the following documents to determine compliance with NRC and DOT regulations governing the transportation of RAM as specified in 10 CFR Part 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and in 49 CFR Parts 171-178.
- RAM shipping papers and related records for 2018
- Training records for those designated as shippers
- RINSC Radiation Safety and Operations Record Audits for 2018
- Licenses of those persons or entities receiving a RAM shipment from the licensee
- Test report for a Type A package
- Form NSC-56, DOT shipping check list - Exempt and Excepted quantity materials only
- Form NSC-6, DOT shipping check list - Type A quantity only
b. Observations and Findings
Through records review and discussions with the RSO, the inspector determined that the licensee had made both Exempt quantity and Type A quantity shipments of RAM in 2018. The records indicated that the shipments had been surveyed as required by regulations and licensee procedure. The RAM shipments had been completed in accordance with DOT and NRC regulations. The inspector verified that the licensee was maintaining a copy on file of each recipients license to possess RAM as required. The licenses were verified to be current prior to initiating a shipment.
The inspector reviewed the training of RINSC staff members responsible for shipping RAM. The inspector verified that the three staff members, who are currently designated as a shipper, had received the appropriate training within the last 3 years, covering the requirements under the DOT, NRC, and the International Air Transport Association. The inspector also reviewed the Type A package test report on file with the licensee. Through further discussions with the RSO, the inspector noted that the RSO thoroughly described the process for preparing a Type A package for shipment.
c. Conclusion
The licensee shipments of RAM under the facilitys reactor license were verified to have been completed in accordance with NRC and DOT requirements.
6.
Exit Interview
The inspector presented the inspection results to licensee management and staff at the conclusion of the inspection on March 14, 2019. The inspector reiterated the areas inspected and discussed the inspection observations. The licensee acknowledged the results of the inspection and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.
Attachment PARTIAL LIST OF PERSONS CONTACTED
Licensee
J. Davis Assistant Director for Operations P. Martin Reactor Supervisor S. Nam Assistant Director for Radiation and Reactor Safety/Radiation Safety Officer A. Olson Reactor Health Physicist M. Marrapese Principle Reactor Operator
Other Personnel
C. Chichester Chairman, Rhode Island Atomic Energy Commission
INSPECTION PROCEDURES USED
IP 69004 Class 1 Research and Test Reactor Effluent and Environmental Monitoring IP 69007 Class 1 Research and Test Reactor Review and Audit and Design Change Functions IP 69011 Class I Research and Test Reactor Emergency Preparedness IP 69012 Class 1 Research and Test Reactors Radiation Protection IP 86740 Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
None
LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable ARM Area Radiation Monitor DOT Department of Transportation EP Emergency Plan IP Inspection Procedure LOA Letter of Agreement NRC U.S. Nuclear Regulatory Commission NRSC Nuclear and Radiation Safety Committee
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NSC Nuclear Safety Committee PRO Principal Reactor Operator RAM Radioactive Material RHP
Reactor Health Physicist RIAEC Rhode Island Atomic Energy Commission RINSC Rhode Island Nuclear Science Center RSO
Radiation Safety Officer TLD
Thermoluminescent Dosimeter TS
Technical Specification