IR 05000225/2020201

U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000225/2020201

ML20261H594
Person / Time
Site:	Rensselaer Polytechnic Institute
Issue date:	10/20/2020
From:	Travis Tate NRC/NRR/DANU/UNPO
To:	Ji W Rensselaer Polytechnic Institute
Takacs M, NRR/DANU/UNPO, 301-415-2042
References
IR 2020201
Download: ML20261H594 (13)

Text

October 20, 2020

SUBJECT:

RENSSELAER POLYTECHNIC INSTITUTE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000225/2020201

Dear Dr. Ji:

From August 25-27, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a routine, announced inspection at the Rensselaer Polytechnic Institute Critical Experiments Facility. The enclosed report documents the inspection results, which were discussed on August 27, 2020, with you, members of your staff, and Dr. Shekhar Garde, Dean for the School of Engineering.

The inspection 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, no findings of significance 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/

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. 50-225 License No. CX-22 Enclosure:

As stated cc: See next page

Rensselaer Polytechnic Institute Docket No. 50-225 cc:

Mayor of the City of Schenectady Test, Research and Training Schenectady City Hall Reactor Newsletter 105 Jay Street Attention: Ms. Amber Johnson Schenectady, NY 12305 Dept. of Materials Science and Engineering University of Maryland Dr. Shekhar Garde 4418 Stadium Drive Dean, School of Engineering College Park, MD 20742-2115 Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12180-3590 Reactor Operations Supervisor JEC Room 2049 Department of Mechanical Aerospace and Nuclear Engineering Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12180-3590 Chief, Radiation Section Division of Environmental Remediation NY State Dept. of Environmental Conservation 625 Broadway Albany, NY 12233-7255 Radiation Safety Officer NES Building, Room 1-10, MANE Department Rensselaer Polytechnic Institute 110 8th Street Troy, NY 12180-3590 Annette Chism, Director EH&S Rensselaer Polytechnic Institute 21 Union Street Gurley Building 2nd Floor Troy, NY 12180 State Liaison Officer Designee Senior Project Manager Radioactive Waste Policy and Nuclear Coordination New York State Energy Research &

Development Authority 17 Columbia Circle Albany, NY 12203-6399

ML20261H594 *concurrence via e-mail NRC-002 OFFICE NRR/DANU/UNPO/SS* NRR/ DANU/UNPO/LA* NRR/DANU/UNPO/BC*

NAME MTakacs NParker TTate DATE 9/21/2020 9/18/2020 10/20/2020

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-225 License No.: CX-22 Report No.: 05000225/2020201 Licensee: Rensselaer Polytechnic Institute Facility: Critical Experiments Facility Location: Schenectady, NY Dates: August 25-27, 2020 Inspector: Michael Takacs 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 Enclosure

EXECUTIVE SUMMARY Rensselaer Polytechnic Institute Critical Experiments Facility Inspection Report No. 05000225/2020201 The primary focus of this announced, routine inspection was the onsite review of selected aspects of the Rensselaer Polytechnic Institutes (RPI, licensee) 100 watt research reactor safety program including: (1) organization and staffing, (2) operations logs and records, (3) requalification training, (4) surveillance and limiting conditions for operation (LCO),

(5) emergency planning, (6) maintenance logs and records, and (7) fuel handling logs and records. The U.S. Nuclear Regulatory Commission (NRC) staff determined that the licensees program was acceptably directed toward the protection of public health and safety and in compliance with NRC requirements. One previous inspection follow-up item (IFI) was closed and one unresolved item (URI) remained open.

Organization and Staffing

• Organizational structure and staffing were consistent with technical specification (TS)

requirements.

Operations Logs and Records

• Operational activities were consistent with TS and procedural requirements.

Operator Requalification

• Operator requalification was conducted as required by the Requalification Program and Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators Licenses.

Surveillance and LCO

• LCO and surveillances required by TS were met.

Emergency Preparedness

• The emergency preparedness program was conducted in accordance with NRC requirements. One URI remained open regarding the inner and outer fence modifications surrounding the facility and the associated dose calculations.

Maintenance Logs and Records

• No maintenance activities were conducted in the past year.

Fuel Handling Logs and Records

• Fuel handling activities were conducted in accordance with licensee procedure.

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REPORT DETAILS Summary of Facility Status The RPI Critical Experiments Facility, Class II research reactor, although licensed to operate at a maximum steady-state thermal power of 100 watts, is limited to a maximum thermal power of 15 watts as specified by the licensees operating procedure. The reactor is only operated in order to maintain licensed operator proficiency and perform TS required surveillance activities.

The reactor is no longer used to support academic programs at RPI. During the inspection, the reactor was shutdown.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Section 6.1, Organization:

• organizational structure and management responsibilities

• RPIs annual report to the NRC for 2019

• reactor operations logbook entries from August 28, 2019, to the present b. Observations and Findings Through review of logs and records, and discussions with the reactor operations supervisor, the inspector determined that the organizational structure and staff responsibilities met the requirements stated in Section 6.1 of the TS. The inspector noted that a new reactor operations supervisor was appointed on February 15, 2020. The inspector verified that the newly assigned reactor operations supervisor met the minimum required number of years of nuclear experience and possessed a senior reactor operator (SRO) license for the RPI reactor, as specified in the TS. As part of the records review, the inspector noted that the annual report to the NRC for the calendar year 2019 was not submitted by March 1, 2020, as required by TS. The licensee agreed to provide timely submittals of the annual report for all future submittals as specified in TS.

c. Conclusion The inspector determined that the organizational structure and staffing were consistent with TS requirements.

2. Operations Logs and Records a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Section 6.9, Operating Records:

• reactor operating procedures, version 3.0, dated July 2013

• reactor operations logbook entries from August 28, 2019, to the present-3-

• completed pre-start checklists from August 28, 2019, to the present

• completed reactor secured checklists from August 28, 2019, to the present b. Observations and Findings The inspector verified, through review of the licensees reactor operations logbook and pre-startup checklists, that the proper shift staffing for reactor operation was maintained and consistent with TS requirements. The inspector noted that the licensee never exceeded reactor thermal power of 15 watts as specified by the licensees operating procedure, and that the reactor water temperature recorded for each reactor operation was maintained above the minimum temperature for reactor operation as specified by the TS. The inspector also noted that for all reactor operations, the licensee documented in the reactor operations logbook (as required by licensee operating procedure) the purpose for reactor operation, core loading, rod positions, and reactor power.

c. Conclusion The inspector determined that operational activities were consistent with the TS and procedural requirements.

3. Requalification Training a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with the NRC approved requalification program and 10 CFR Part 55 requirements:

• NRC-approved RPI requalification program, dated May 9, 2011

• licensed operator training records

• reactor operations logbook entries from October 24, 2019, to the present b. Observations and Findings The inspector verified that all operator licenses were current and that operators were in compliance with the NRC-approved RPI requalification program and had completed the minimum required hours of reactor operation per quarter. The inspector noted that all four operators were licensed SROs; two SROs were RPI part time employees and the other two SROs were volunteers. The volunteer SROs consisted of an RPI student and a former RPI student. The inspector noted that one of the volunteer SROs biennial medical examination had expired in October of 2019, and that the operator had not completed his medical exam until January of 2020. The inspector determined, through a review of the reactor operations logbook and discussions with the reactor operations supervisor, that the operator did not perform the functions of an SRO or was assigned responsibilities in support of reactor operations during his expired medical exam period. Although the licensee restricted the operator from performing duties involving reactor operations, the licensee also informed the inspector that they interpreted biennial to mean an allowed frequency of up to 2 1/2 years to complete-4-

a biennial requirement as defined in American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007 (R2013) The Development of Technical Specifications for Research Reactors. The inspector informed the licensee that ANSI/ANS-15.1-2007 (R2013) only applies to the performance of reactor TS surveillances, and that biennial medical exams are required by regulations to be completed within the 2-year period. The licensee acknowledged its understanding that biennial medical exams are to be completed within the 2-year period for all licensed operators.

c. Conclusion The inspector determined that operator requalification was conducted as required by the NRC-approved RPI training program and 10 CFR Part 55.

4. Surveillance and Limiting Conditions for Operation a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Section 3, Limiting Conditions for Operation, and TS Section 4, Surveillance Requirements:

• reactor surveillance procedures, version 4.1, dated August 2018

• reactor operations logbook entries from October 24, 2020, to the present b. Observations and Findings The inspector reviewed the reactor operations logbook and verified that TS required surveillances were performed within their specified surveillance frequencies. The inspector also noted that the LCO regarding minimum reactor water temperature was consistently maintained above 50 degrees as required during reactor operations. The inspector, along with the reactor supervisor, performed a walk-through of three TS surveillance procedures: (1) rod drop timing, (2) start-up channel calibration, and (3) continuous air monitor and area radiation monitor checks. The inspector found no issues regarding the walk-through of these TS surveillance procedures.

c. Conclusion The inspector determined that surveillances and LCOs were properly implemented and maintained as required by the TS.

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5. Emergency Planning a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with the licensees emergency preparedness program:

• reactor emergency plan (EP), dated November 2016

• reactor emergency procedures, dated June 2016

• emergency contact list posted in the control room, dated August 2019

• licensed operator training records b. Observations and Findings The inspector noted that the Nuclear Safety Review Board reviewed the reactor EP and emergency procedures annually. The inspector also noted that the most recent annual emergency response drill was conducted on June 26, 2019, which focused on a simulated electrical fire in the console. The inspector had the reactor supervisor test the reactor building emergency audible alarm to verify its functionality. The inspector also noted that all the required emergency equipment checks were inspected and documented according to the licensees emergency procedure. The inspector determined that the emergency call list was current and posted in the control room. The inspector reviewed all operator training records and verified that operators were current with their emergency preparedness training in accordance with the NRC-approved RPI requalification program.

c. Conclusion The inspector determined that the emergency preparedness program was conducted in accordance with NRC requirements.

6. Maintenance Logs and Records a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS requirements:

• reactor operations logbook entries from August 28, 2019, to the present

• RPI annual report to the NRC for 2019

• reactor maintenance procedures, version 1.0, dated December 11, 2013 b. Observations and Findings Through a review of the reactor operations logbook and discussion with the reactor supervisor, the inspector noted that no maintenance activities have occurred in the past year. The inspector determined that the lack of maintenance activities is supported by the fact that there is very limited use of the reactor-6-

(averaging 1 or 2 days a month) along with the size of the facility and the limited number of support systems.

c. Conclusion The inspector determined that no maintenance activities were conducted in the past year.

7. Fuel Handling Logs and Records a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Sections 3 and 4:

• reactor operations logbook entries from October 28, 2019, to the present

• reactor operating procedures, Section K, Fuel Handling, Storage, and Movement, version 3.0, dated July 2013

• reactor surveillance procedures,Section I, Fuel Inventory, version 4.1, dated August 2018 b. Observations and Findings Through a review of the reactor operations logbook and a discussion with the reactor supervisor, the inspector noted that only one fuel handling evolution (i.e.,

unloading and reloading of the core) occurred during the past year. The inspector also noted that the fuel handling evolution was well documented and conducted in accordance with the licensees fuel handling procedure.

c. Conclusion The inspector determined that fuel handling activities were completed and documented as required by the licensees procedure.

8. Follow-up on previously identified items a. Inspection Scope (IP 92701)

The inspector reviewed the licensees actions taken in response one IFI and one URI that were identified from previous inspections.

b. Observation and Findings 1) IFI 50-225/2016-201-02 was opened in a previous inspection (i.e., October 2016)

to address the need to update the EP to include the emergency classification designation of Notice of Unusual Event (NOUE) emergency action level. The inspector reviewed the latest version of the EP, dated November 2016, which was submitted to the NRC in October of 2018, and verified that it includes the emergency classification of NOUE. Therefore, IFI 50 225/2016-201-02 is now resolved and closed.

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2) URI 05000225/2018201-01 was opened in a previous inspection (i.e.,

September 2018) which noted physical changes to the inner and outer fence dimensions surrounding the reactor building. The inspector indicated to the licensee in the previous inspection, that the fence dimensions needed to be accurately measured and a new 10 CFR 50.59, Changes, tests and experiments, analysis would need to be performed in order to verify that the dose calculations to individual members of the public in the unrestricted areas do not exceed the limits specified under 10 CFR 20.1301, Dose limits for individual members of the public. The inspector noted that the licensee submitted a license amendment request (LAR) to the NRC in July 2019 regarding the new fence dimensions along with dose calculations. The NRC is currently reviewing the LAR. Therefore, URI 05000225/2018201-01 will remain open until the NRC has completed its review of the LAR or the issue is resolved in another process.

c. Conclusion The inspector determined that IFI 50-225/2016-201-02 is resolved and is now closed, and that URI 05000225/2018201-01 will remain open until the NRC completes its review of the LAR regarding the new fence dimensions and the associated dose calculations or the issue is resolved in another process.

9. Exit Interview The inspector presented the inspection results to licensee management and staff at the conclusion of the inspection on August 27, 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.

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LIST OF PERSONS CONTACTED Licensee S. Garde Dean, School of Engineering Reactor Critical Facility Director H. Kang Nuclear Safety Review Board Chair J. Thompson Reactor Critical Facility Operations Supervisor A. Chism Director of Environmental, Health, Safety & Risk Management M. Arha Radiation & Bio Safety Officer INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed IFI 50-225/2016-201-02 Follow-up on the licenses update to the EP.

Discussed URI 05000225/2018201-01 Follow-up on licensee resolution of issue regarding changes to inner and outer fence dimensions along with dose calculations.

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