IR 05000225/2012201
| ML12289A004 | |
| Person / Time | |
|---|---|
| Site: | Rensselaer Polytechnic Institute |
| Issue date: | 10/25/2012 |
| From: | Gregory Bowman Research and Test Reactors Branch B |
| To: | Sreepada S Rensselaer Polytechnic Institute |
| Lichatz, Taylor 301-415-7128 | |
| References | |
| IR-12-201 | |
| Download: ML12289A004 (17) | |
Text
October 25, 2012
SUBJECT:
RENSSELAER POLYTECHNIC INSTITUTE - NRC ROUTINE INSPECTION REPORT NO. 50-225/2012-201 AND NOTICE OF VIOLATION
Dear Dr. Sreepada:
This refers to an inspection conducted from September 11 to 14, 2012, at the Reactor Critical Facility (Inspection Report No. 50-225/2012-201). The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection, which were discussed with you and members of your staff at a meeting held on September 26, 2012.
During this inspection, U.S. Nuclear Regulatory Commission (NRC or the Commission) staff examined activities conducted under your license as they relate to public health and safety to confirm 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, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because it constitutes a failure to meet a regulatory requirement that has more than minor safety significance and it was identified by the NRC.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with Title 10 of the Code of Federal Regulations 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure(s), and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction. Should you have any questions concerning this inspection, please contact Taylor Lichatz at 301-415-7128 or by email at Taylor.Lichatz@nrc.gov.
Sincerely,
/RA/
Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-225
License No. CX-22
Enclosures:
Inspection Report No. 50-225/2012-201 Notice of Violation
cc w/encls: See next page
Rensselaer Polytechnic Institute
Docket No. 50-225
cc:
Dr. Sastry Director, RCF JEC Room 2032 Department of Mechanical Aerospace & Nuclear Engineering, Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12181
Mayor of the City of Schenectady Schenectady, NY 12305
Radiation Section Chief New York State Department of Environmental Conservation 625 Broadway Albany, NY 12233-7255
State Liaison Officer Designee Senior Project Manager Radioactive Waste Policy &
Nuclear Coordination New York State Energy Research & Development Authority 17 Columbia Circle Albany, NY 12203-6399
Annette Chism, Director EH&S Rensselaer Polytechnic Institute 21 Union Street Gurley Building 2nd Floor Troy, NY 12180
Peter F. Caracappa, Ph.D, CHP Radiation Safety Officer NES Building, Room 1-10, MANE Dept Rensselaer Polytechnic Institute 110 8th St.
Troy, NY 12180-3590
Dr. Jason Thompson, Reactor Operations Supervisor, JEC Room 2049 Dept of Mechanical Aerospace and Nuclear Engineering, Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12181
Dr. David Rosowsky Dean, School of Engineering Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12181
Director, Bureau of Environmental Radiation Protection New York State Department of Health 547 River Street, Room 530 Troy, NY 12180-2216
Test, Research and Training Reactor Newsletter Director of Nuclear Facilities University of Florida 202 Nuclear Science Center Gainesville, FL 32611-8300 Should you have any questions concerning this inspection, please contact Taylor Lichatz at 301-415-7128 or by email at Taylor.Lichatz@nrc.gov.
Sincerely,
/RA/
Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-225
License No. CX-22
Enclosures:
Inspection Report No. 50-225/2012-201 Notice of Violation
cc w/encls: See next page
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GLappert, NRR Accession Number: ML12289A004 TEMPLATE #: NRC-002 OFFICE PROB:RI PROB:LA PROB:BC NAME TLichatz GLappert GBowman DATE 10/16/2012 10/15/2012 10/25/2012 OFFICIAL RECORD COPY
Rensselaer Polytechnic Institute
Docket No. 50-225 Reactor Critical Facility
License No. CX-22
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from September 11 to 14, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(q),
Emergency Plans, states, in part, that the holder of a license under 10 CFR Part 50, shall follow an emergency plan that meets the requirements in Appendix E to 10 CFR Part 50. Appendix E of 10 CFR Part 50 includes requirements associated with training and exercises involving offsite organizations.
Section 10 of Rensselaer Polytechnic Institute Critical Experiments Facilitys Emergency Plan, Emergency Preparedness Maintenance, states, in part, that an annual drill will be conducted that simulates an emergency and that these drills will involve notification of emergency personnel and support groups.
Contrary to 10 CFR 50.54(q), the licensee failed to follow an emergency plan that meets the requirements of Appendix E to 10 CFR Part 50. Specifically, prior to the NRCs September 2012 inspection, the licensee failed to include the notification of emergency support groups, such as hospital, police, and fire department personnel, in their emergency drills, as required by the licensees emergency plan.
This is a Severity Level IV violation (Section 6.6).
Pursuant to the provisions of 10 CFR 2.201, Rensselaer Polytechnic Institute is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001 with a copy to the NRC inspector for the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
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If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within 2 working days of receipt.
Dated this 25th day of October 2012
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No:
50-225
License No:
CX-22
Report No:
50-225/2012-201
Licensee:
Rensselaer Polytechnic Institute
Facility:
Reactor Critical Facility
Location:
Schenectady, NY
Dates:
September 11-14, 2012
Inspector:
Taylor Lichatz
Approved by:
Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
Rensselaer Polytechnic Institute Reactor Critical Facility NRC Inspection Report No. 50-225/2012-201
The primary focus of this routine, announced inspection was the onsite review of selected aspects of the Rensselaer Polytechnic Institutes (the licensees) 100 Watt Class II research reactor safety program including: 1) organizational structure and staff responsibilities, 2) radiation protection and environmental monitoring, 3) review and audit functions, 4) emergency preparedness, and 5) transportation of radioactive material since the last U.S.
Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety and generally in compliance with the NRC requirements. One Severity Level IV violation was identified.
Organization and Staffing
- The licensees organizational structure and staff responsibilities were in compliance with requirements specified in the Technical Specifications (TS).
Health Physics
- Surveys were being completed and documented acceptably to permit evaluation of the radiation hazards present.
- Postings met the regulatory requirements specified in Title 10 of the Code of Federal Regulations Parts 19 and 20.
- Personnel dosimetry was being worn as required and doses were well within the licensees procedural action levels and NRC regulatory limits.
- Radiation monitoring equipment was being maintained and calibrated as required.
- The radiation protection and As Low As Reasonably Achievable programs satisfied regulatory requirements.
- Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
Committees, Audits, and Reviews
- Audits and reviews were generally being conducted by designated individuals and reviewed by the Nuclear Safety Review Board in accordance with the requirements specified in TS 6.2.
- The emergency preparedness program was generally conducted in accordance with NRC requirements. One Severity Level IV violation was identified associated with failure to involve support organizations in emergency drills.
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Transportation of Radioactive Materials
- No radioactive material was transferred to or from the reactor since the last inspection.
REPORT DETAILS
Summary of Facility Status
The Rensselaer Polytechnic Institutes (RPIs or the licensees) Reactor Critical Facility (RCF)
Class II research reactor, licensed to operate at a maximum steady-state thermal power of 100 Watts, continued to be operated in support of academic instruction, operator training, surveillance, and research. During the inspection the reactor was not operated due to a linear power amplifier meter being out of service.
1.
Organization and Staffing
a.
Inspection Scope (Inspection Procedure (IP) 69001)
The inspector reviewed the following regarding the licensees organization and staffing to ensure that the requirements of Technical Specification (TS) 6.1 were being met:
- Organizational structure and management responsibilities
RPI Nuclear Safety Review Board (NSRB) meeting minutes for the past 2 years
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2009, dated February 1, 2010
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2010, dated March 7, 2011
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2011, dated March 6, 2012
RCF logbook entries for the past 2 years
b.
Observations and Findings
Through review of records and logs, and through discussions with licensee personnel, the inspector determined that the organizational structure and staff responsibilities observed at the Rensselaer Polytechnic Institute Reactor Critical Facility met the requirements stated in TS 6.1.
c.
Conclusion
The organizational structure and staffing were consistent with TS requirements.
2.
Health Physics
a.
Inspection Scope (IP 69001)
To verify compliance with Title 10 of the Code of Federal Regulations (10 CFR)
Parts 19 and 20 and TSs 3.7, 4.7, and 6.3, the inspector reviewed selected aspects of:
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Various calibration certificates for the portable survey instruments for the past 2 years
Dosimetry records for 2010, 2011, and to date in 2012
Routine surveys and monitoring for 2010, 2011, and to date in 2012
Rensselaer Polytechnic Institute Radiation Safety Manual, dated December 2008
Completed NSRB quarterly radiation safety audits for the RCF for 2010, 2011, and to date in 2012
Radiation and Nuclear Safety Committee radiation safety annual reports for 2010 and 2011
RCF and Public Safety personnel training records
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2010, dated March 7, 2011
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2011, dated March 6, 2012
b.
Observations and Findings
(1)
Surveys
The inspector reviewed quarterly radiation and contamination surveys of the licensees controlled areas as well as radiation wipe surveys completed by the Radiation Safety Officer (RSO). The surveys had been completed in accordance with the applicable procedure and logged on the appropriate forms. The results of these surveys were documented appropriately, evaluated as required, and corrective actions were taken when readings or results exceeded set action levels. The survey also included a checklist of items to be verified such as the adequacy of warning signs and postings in the area and training for radioactive material users.
(2)
Postings and Notices
The inspector reviewed the postings at the entrances to various controlled areas including the reactor bay and radioactive material storage areas.
The postings were acceptable and indicated the radiation and contamination hazards present. No unmarked radioactive material was found in the facility. A copy of the current NRC Form 3, Notice to Employees, required by 10 CFR Part 19, was posted in numerous areas in the RCF.
(3)
Dosimetry
The licensee used a National Voluntary Laboratory Accreditation Program-accredited vendor to process personnel dosimetry. Through direct observation, the inspector determined that dosimetry was used acceptably by facility personnel. For visitors to the facility, a whole body
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film badge dosimeter is generally issued to each individual. Records indicate that no abnormal readings were obtained.
An examination of the records for the inspection period showed that all exposures were within NRC limits and within licensee action levels.
Current exposure records for the past 2 years indicate no increased levels in exposures. The licensee investigates any dosimetry readings that indicate an exposure above background levels.
(4)
Radiation Monitoring Equipment
The use and calibration of radiation monitoring equipment was reviewed by the inspector. The calibration of portable survey meters and friskers was typically completed by a company that specializes in calibrations, while fixed radiation detectors were calibrated at the facility using a portable source. The calibration records showed that calibration frequency met the requirements established in the applicable surveillance procedures and records were being maintained as required. Through observation the inspector determined that the equipment was being used and maintained acceptably. It was noted that instruments awaiting repair and/or calibration, or those that were in storage and not calibrated, were removed from service to preclude inadvertent use.
(5)
Radiation Protection Program
The inspector verified that the radiation protection program was being reviewed annually as required. This review is performed by the RPI Radiation and Nuclear Safety Committee, which includes three members of the NSRB. The inspector also verified that the RSO was conducting the radiation worker training was being performed as required. No issues related to the radiation protection program at the RCF were identified in the review of the program.
(6)
Facility Tours
The inspector toured the RCF and the accompanying facilities. Control of radioactive material and control of access to radiation areas were acceptable. The postings and signs for these areas were appropriate.
(7)
Environmental Monitoring
The licensee ensures compliance with NRC regulations for environmental monitoring by ensuring that all doses at the site boundary are less than the dose limits specified in 10 CFR 20.1301. Several thermoluminescent dosimeters are placed in locations around the perimeter of the RCF.
Records for 2010 to the present indicate that doses were well below the applicable requirements and typically measure at background levels. In
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addition to the measurements at the site boundary, radiation surveys of the reactor facility show that doses are less than the regulatory limit for environmental exposure rates.
Records show that projected gaseous emissions from the reactor are generally minimal. The licensee uses the Environmental Protection Agency computational code COMPLY, which shows that the licensee is in compliance with 10 CFR 20.1301(a)(1).
The licensee reported one routine, planned liquid discharge for calendar year 2011. Specifically, the licensee discharged the core moderator and analyzed two samples for gross alpha and beta activity prior to the release. No activity above background was detected.
c.
Conclusion
Based on the observations made and the records reviewed, it was determined that, the radiation protection program being implemented by the licensee satisfied regulatory requirements because: 1) surveys were being completed and documented acceptably, 2) postings met regulatory requirements, 3) personnel dosimetry was being worn as required and doses were well within the NRCs regulatory limits, 4) radiation monitoring equipment was being maintained and calibrated as required, 5) training was being conducted as required, and, 6) effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
3.
Committees, Audits, and Reviews
a.
Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the audits and reviews stipulated in the requirements of TS 6.2 were being completed:
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2009, dated February 1, 2010
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2010, dated March 7, 2011
Operations Report for the Rensselaer Polytechnic Institute Reactor Critical Facility for 2011, dated March 6, 2012
RPI RCF Installation of Zircaloy Reflector Slabs, approval dated July 11, 2011
b.
Observations and Findings
The inspector verified that the NSRB conducted meetings at least annually, as required by TS 6.2. The inspector reviewed the NSRB meeting minutes for the
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past 4 years. Review of the board meeting minutes indicated that the NSRB provided appropriate guidance and direction for reactor operations and ensured acceptable use and oversight of the reactor.
Since the last inspection, the required audits of reactor facility activities and reviews of programs, procedures, equipment, and proposed tests or experiments had been completed and documented as required. The audits were completed by a designated individual and reviewed by the NSRB. The inspector noted that the annual review of the radiation protection program was being acceptably completed by the RPI Radiation and Nuclear Safety Committee, which consists of three members of the NSRB, in addition to other RPI-appointed members.
c.
Conclusion
NSRB review and audit functions required by the TS were being appropriately implemented and documented.
4.
a.
Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify compliance with the Emergency Plan (E-Plan) for the RPI Critical Experiment Facility, dated August 2004:
- RCF emergency notification list
Memoranda of understanding (MOU) with support agencies
Emergency response facilities, supplies, equipment, and instrumentation
RPI RCF logbooks for 2010, 2011, and to date 2012
b.
Observations and Findings
The inspector reviewed the E-Plan in use at the RCF and verified that the E-Plan was generally being properly implemented at the facility. The inspector reviewed the emergency facilities, instrumentation, and equipment and verified that the off-site emergency response equipment was as described in the E-Plan. The inspector verified that MOU had been established with the Ellis Hospital, City of Schenectady Police Department and Fire Department, and Mohawk Ambulance Service.
The inspector verified that RCF staff received annual emergency drill training.
The inspector verified that the licensee reviewed the E-Plan on an annual basis, the emergency procedures on a biennial basis, conducted an inventory of the first aid kit annually, and checked the emergency siren annually.
As required for the inspection, the inspector reviewed the implementation of emergency drills as stipulated in the E-Plan. Regulation 10 CFR 50.54(q),
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Emergency Plans, states, in part, that a holder of a license under this Part 50 shall follow an emergency plan that meets the requirements in Appendix E to 10 CFR Part 50. Appendix E of 10 CFR Part 50 includes requirements associated with training and exercises involving offsite organizations.
Rensselaer Polytechnic Institute Critical Experiments Facility Emergency Plan Section 10, Emergency Preparedness Maintenance, states, in part, that an annual drill will be conducted that simulates an emergency, and that these drills will involve notification of emergency personnel and support groups.
Contrary to the above, the inspector determined that the licensee had failed to include the notification of emergency support groups that would be involved in an emergency in emergency drills. The existing MOUs with support organizations and successful completion of periodic emergency preparedness exercises provide reasonable assurance that the emergency plan would be implemented in an actual emergency. However, the inspector determined that this issue represented a Severity Level IV violation of 10 CFR 50.54(q) because the lack of training and involvement of support groups could degrade the effectiveness and timeliness of response. The inspector will document and track this violation as VIO 50-225/2012-201-01.
c.
Conclusion
The emergency preparedness program was generally conducted in accordance with the requirements stipulated in the E-Plan.
5.
Transportation of Radioactive Materials
a.
Inspection Scope (IP 86740)
The inspector reviewed selected aspects of:
- Radioactive materials shipping procedures
Interviews with RCF staff
b.
Observations and Findings
No radioactive material was transferred from or to the reactor since the last inspection. If required, material would be passed to the university license and then packaged and shipped by Environmental Health and Safety personnel under the state license.
c.
Conclusion
No radioactive material was transferred from or to the reactor since the last inspection.
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6.
Exit Interview
The inspection scope and results were summarized in a telephone conference on September 26, 2012, with licensee representatives. The inspector discussed the findings for each area reviewed.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Reactor Critical Facility Director P. Caracappa Radiation Safety Officer J. Thompson Operations Supervisor E. Blain
Senior Reactor Operator M. Del-Vecchio Sergeant, Department of Public Safety
INSPECTION PROCEDURES USED
Class II Non-Power Reactors IP 86740
Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-225/2012-201-01 VIO Failure to involve the notification of emergency support groups during emergency drills.
Closed
None
LIST OF ACRONYMS USED
10 CFR
Title 10 of the Code of Federal Regulations ADAMS
Agencywide Document Access and Management System E-Plan
Inspection Procedure MOU
Memorandum of Understanding NOV
Nuclear Safety Review Board NRC
Nuclear Regulatory Commission RCF
Reactor Critical Facility RPI
Rensselaer Polytechnic Institute RSO
Radiation Safety Officer SRO
Senior Reactor Operator TS
Technical Specification