IR 05000193/2020201
| ML20078L009 | |
| Person / Time | |
|---|---|
| Site: | Rhode Island Atomic Energy Commission |
| Issue date: | 04/15/2020 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Goodwin C Rhode Island Nuclear Science Center |
| Takacs M, NRR/DANU/UNPO, 415-2042 | |
| References | |
| IR 2020201 | |
| Download: ML20078L009 (18) | |
Text
April 15, 2020
SUBJECT:
RHODE ISLAND ATOMIC ENERGY COMMISSION - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT
NO. 05000193/2020201
Dear Dr. Goodwin:
From March 3 - 6, 2020, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Rhode Island Nuclear Science Center research reactor facility. The enclosed report documents the inspection results which were discussed on March 6, 2020, with you, members of your staff, and 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, compliance with the Commissions rules and regulations, and compliance 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, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. However, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described in the subject inspection report. No response to this letter is required, however, 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.
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. 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/
Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities 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 University of Rhode Island Department of Physics 2 Lippitt Road, East Hall Kingston, RI 02881
Dr. Nancy E. Breen, Commissioner Roger Williams University Marine and Natural Science Building 226 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/DANU/UNPO/SS*
NRR/DANU/UNPO/LA*
NRR/DANU/UNPO/BC NAME MTakacs NParker TTate DATE 03/19/20 03/19/20 04/15/20
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 3 - 6, 2020
Inspector:
Approved by:
Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
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EXECUTIVE SUMMARY
Rhode Island Atomic Energy Commission Rhode Island Nuclear Science Center Inspection Report No. 05000193/2020201
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, (5) transportation activities, and (6) follow-up on a reportable occurrence. 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. One inspection follow-up item (IFI) was opened and one Severity Level IV non-cited violation (NCV)
was identified.
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 Section 50.59, Changes, tests and experiments.
- One IFI was opened regarding updating audit records to include the complete list of items required to be audited as specified under TS 6.2.4
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.
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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.
- The licensee maintained an effective emergency preparedness program through implementation of the emergency plan (EP) and the associated emergency 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.
Follow-up on a Reportable Occurrence
- One NCV was identified regarding the licensees failure to perform the required TS annual surveillance on the drop times for the reactor shim safety blades.
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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 shutdown for routine maintenance.
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, dated September 11, 2017
NRSC meeting minutes for May and December of 2019
RINSC Operating Procedure, AP-03, Facility Modifications, Revision 2
RINSC Annual Report dated July 26, 2019
RINSC Radiation Safety Annual Review performed by the Radiation Safety Officer (RSO) for 2019
RINSC Radiation Safety and Operations Record Audits for May and December of 2019
b. Observations and Findings
(1) Review and Audit Functions
The inspector reviewed the NRSC meeting minutes and associated records for May and December of 2019. 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 mostly consistent with the TS requirement, which is to provide guidance, direction, and oversight for the facility, and acceptable use of the reactor. However, the inspector noted that not all facility audits, as specified under TS 6.2.4, were documented in the NRSC meeting minutes, Section 13, Review Radiation Safety and Operations Records Audit. Specifically, EPs and implementing procedures (TS 6.2.4.3) and the radiation safety program (TS 6.2.4.5) need to be added to Section 13 of this list in the meeting minutes. As a result, the inspector opened IFI 05000193/2020201-01 to track this item.
(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
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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.
c. Conclusion
The NRSC was meeting as required and reviewing the topics outlined in the TS.
design change procedures and records were maintained up to date as required by the TS. Record keeping of facility audits needs to be updated as specified under TS 6.2.4 and is being tracked as IFI 05000193/2020201-01.
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 Report for 2019
RINSC Radiation Safety Annual Review performed by the RSO for 2019
RINSC Radiation Safety and Operations Record Audits for May and December of 2019
Copies of NRC Form 3, Notice to Employees, posted at the facility
Personnel dosimetry records for 2019
RINSC Radiation Safety Office Radiation Safety Manual, dated 2019
Selected facility survey and wipe test records for 2019
Selected calibration records of area radiation monitors (ARMs) for 2019
Survey meter calibration files documenting the calibration of various portable survey instruments for 2019
b. Observations and Findings
(1)
Surveys
The inspector reviewed selected radiation and contamination surveys. The surveys were completed by trained licensee staff 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 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 licensee 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 year 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, Occupational Dose Record for a Monitoring Period, 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 radioactive source material calibrations. The inspector verified that the survey instruments were calibrated annually as required and the appropriate calibration records were maintained.
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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: (1) RINSC staff members, (2) personnel who were not on staff but who were authorized to use the experimental facilities of the reactor, and (3) 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 July 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 does 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 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. These areas
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included: (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 2019
Form MP-03, Primary water Analysis
Form MP-04, Secondary Water Analysis
RINSC Radiation Safety and Operations Record Audits for May and December of 2019
RINSC Radiation Safety Annual Review performed by the RSO for 2019
RINSC Annual Report for 2019
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.
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 specified in 10 CFR 20.1101, Radiation protection programs, paragraph (d). This was acceptably demonstrated by the licensee through the COMPLY code calculations.
Additionally, observations of the interior and exterior of the facility by the inspector indicated no new potential release paths.
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(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 the review and authorization of each batch release. 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 licensee staff and reviewed various documents to verify compliance with regulatory requirements and the RINSC EP, Revision 7:
- RINSC EP, Revision 7
Emergency Preparedness Notebook containing documentation of various activities including:
- Completion of the annual emergency supply inventories documented on RINSC form NSC-83 (Inventory Sheet)
- Emergency training and drills conducted in 2019
- Emergency communication tests conducted with various support agencies in 2019
RINSC Emergency Procedure-01, Emergency Plan Implementing Procedures, Revision 5, dated May 2019
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- Letter of Agreement (LOA) between Narragansett Police Department and RINSC, signed by Mr. M. J. Davis and by Chief S. Corrigan, dated December 31, 2019
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 November 7, 2019
LOA between Narragansett Fire Department and RINSC, signed by Mr. M. J. Davis and Chief S. Partington on December 20, 2019
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. Through records review, including the recent annual drill report referencing the drill conducted on December 16, 2019, 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 the event 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.
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
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10 CFR Part 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and in 49 CFR Parts 171-178.
- RAM shipping records for 2019
- Training records for those designated as shippers
- RINSC Radiation Safety Annual Review performed by the RSO for 2019
- 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
- RINSC procedure, RAM Packaging, Shipping, and Receiving, dated July 2017
b. Observations and Findings
Through records review and discussions with the RSO, the inspector noted that the licensee had made both Exempt quantity and Excepted quantity shipments of RAM in 2019. However, no Type A shipments were performed since the last NRC inspection in March of 2019. 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.
In 2019, the licensee successfully coordinated with Idaho National Laboratory (under contract with the U.S. Department of Energy), a Type B shipment of spent reactor fuel elements. The inspector reviewed the Bill of Lading for the incoming empty shipping cask and the Bill of Lading for the outgoing fully loaded shipping cask with spent reactor fuel. Both documents indicated the required information including: (1)
the names of the shipper and the consignee, (2) the type of package and its contents, (3) the proper RAM labeling of the package and the vehicle placarding, and (4) the signatures of both the shipper and the carrier. The inspector also reviewed the survey and wipe test records for the initial receipt of the transport vehicle and the empty shipping cask, as well as the loaded shipping cask and transport vehicle in preparation for its departure from the licensees facility. The inspector noted that the survey and wipe test results were adequate with no unexpected or unusual values.
The inspector reviewed the training of licensee staff responsible for routinely shipping RAM. The inspector verified that the three staff members, who are each 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.
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.
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6.
Follow-up on Reportable Occurrence
a. Inspection Scope (IP 92701)
The inspector interviewed licensee staff and reviewed various records regarding the reportable occurrence that occurred on December 4, 2019.
- RINSC reportable occurrence notification to NRC - Event Number54419, dated December 4, 2019
RINSC written report to NRC regarding the reportable occurrence (EN 54419),
dated December 4, 2019
b. Observation and Findings
On December 4, 2019, the licensee notified the NRC that a reportable occurrence had been identified at their facility as defined by TS 1.31.4. Specifically, RINSC TS requires that the surveillance test for the drop times of all the shim safety blades is to be measured annually with an interval not to exceed 15 months. Based on a review of the licensees maintenance records, this 15 month interval end date was November 15, 2019. Upon further review, the inspector verified with the licensee that reactor operations did occur after November 15, 2019. The inspector noted that on Decemebr 4, 2019, in recognition of the delay of this TS surveillance test, the licensee initiated a corrective action by performing drop time tests of all shim safety blades. The results of the tests indicated that all of the drop times of the shim safety blades were within TS requirements. The inspector also noted that as a result of this issue, the licensee has implemented a permanent modification to its maintenance status board by providing a specific column highlighting due dates for all maintenance and surveillance activities. This is expected to increase licensee awareness of all the required completion dates for all surveillance and maintenance activities, and prevent a recurrence of this issue.
Based on a review of the licensees records and interviews with licensee staff, the inspector has determined that this event constitutes a Severity Level IV violation consistent with Section 6.1.d.1 of the NRC Enforcement Policy. However, the inspector noted that all of the criteria under Section 2.3.2, Non-Cited Violation, of the NRC Enforcement Policy were satisfied. As a result, the inspector informed the licensee that this Severity Level IV violation would be treated as a NCV and will be identified as NCV 05000193/2020201-01.
c. Conclusion
NCV 05000193/2020201-01 was identified by the inspector and discussed with the licensee. The inspector determined that this issue is resolved and now closed.
7.
Exit Interview
The inspector presented the inspection results to licensee management and staff at the conclusion of the inspection on March 6, 2020. 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 Director, Rhode Island Nuclear Science Center J. Davis Assistant Director for Operations P. Martin Reactor Supervisor S. Nam Assistant Director for Radiation and Reactor Safety/Radiation Safety Officer J. McCullah 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 IP 92701 Followup
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
IFI 05000193/2020201-01 Update audit records in the Nuclear and Radiation Safety Committee meeting minutes to include the complete list of facility audits as specified by TS 6.2.4.
NCV 05000193/2020201-01 Failure to perform the TS required drop time surveillance of the shim safety blades within the required annual interval.
Closed
Discussed
None
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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 EN Event Number EP Emergency Plan IFI Inspection follow-up item IP Inspection Procedure LOA Letter of Agreement NCV Non-cited violation NRC U.S. Nuclear Regulatory Commission NRSC Nuclear and Radiation 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