IR 05000225/2023201
| ML23296A247 | |
| Person / Time | |
|---|---|
| Site: | Rensselaer Polytechnic Institute |
| Issue date: | 12/12/2023 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Ji W Rennselaer Polytechnic Institute |
| References | |
| IR 2023201 | |
| Download: ML23296A247 (10) | |
Text
December 12, 2023
SUBJECT:
RENSSELAER POLYTECHNIC INSTITUTE - NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000225/2023201
Dear Dr. Ji:
From September 18 - 20, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a routine inspection at the Rensselaer Polytechnic Institute Critical Experiments Facility. The enclosed report documents the inspection results which were discussed on September 20, 2023, with you and members of your staff, as well as Ginger Caravalho, Radiation and Laser Safety Officer.
The inspection examined activities conducted under your license as they relate to public health and safety to confirm compliance with NRC 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 website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by email at Craig.Bassett@nrc.gov.
Sincerely, Signed by Tate, Travis on 12/12/23 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 Enclosures:
As stated cc: GovDelivery Subscribers SUBJECT: RENSSELAER POLYTECHNIC INSTITUTE - NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000225/2023201 DATED: DECEMBER 12, 2023 DISTRIBUTION:
PUBLIC TTate, NRR CBassett, NRR HCruz, NRR NParker, NRR AWaugh, NRR XYin, NRR JBowen, NRR JBorroomeo, NRR DTifft, RGN-I RidsDanuUnpo Resource ADAMS ACCESSION NO.: ML23296A247 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME CBassett NParker TTate DATE 10/31/2023 10/31/2023 12/12/2023 OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-225 License No.: CX-22 Report No.: 05000225/2023201 Licensee: Rensselaer Polytechnic Institute Facility: Critical Experiments Facility Location: Schenectady, NY Dates: September 18 - 20, 2023 Inspector: Craig H. Bassett 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. 05000225/2023201 The primary focus of this announced safety inspection was the onsite review of selected aspects of the Rensselaer Polytechnic Institutes (RPIs, the licensees) 100-watt, Class II Critical Experiments Facility safety program including: (1) procedures; (2) experiments; (3) health physics; (4) design changes; (5) committees, audits and reviews; and (6) transportation activities. The licensees safety program was acceptably directed toward the protection of public health and safety and in compliance with the U.S. Nuclear Regulatory Commission (NRC) requirements.
Procedures
- Written procedures were maintained in accordance with technical specification (TS)
requirements.
Experiments
- The experiment review and approval process was functioning as required by the facility TSs.
Health Physics
- The licensees radiation protection program satisfied regulatory and TS requirements.
Design Changes
- Since the last inspection, no equipment, procedure, or experiment changes occurred that would be subject to the requirements of Title 10 of the Code of Federal Regulations (10 CFR)
50.59, Changes, tests and experiments.
Committees, Audits and Reviews
- Audits and reviews were conducted by designated individuals and reviewed by the Nuclear Safety Review Board (NSRB) in accordance with the requirements specified in TS section 6.2, Review and Audit.
Transportation Activities
- No radioactive material was transferred to/from the facility.
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REPORT DETAILS Summary of Facility Status The Rensselaer Polytechnic Institute (RPI) Critical Experiments Facility (RCF) Class II research reactor, licensed to operate at a maximum steady-state thermal power of 100 watts, is currently operated primarily to maintain operator proficiency and complete reactor surveillance activities.
During the inspection, the reactor was not operated.
1. Procedures a. Inspection Scope (Inspection Procedure (IP) 69001, Section 02.03)
The inspector reviewed the following to ensure that the requirements of TS section 6.4, Procedures, were met concerning written procedures:
- various RCF procedures including Pre-Startup Procedures/Checklist, Version 8.3; Operating Procedures, Version 3.0; Secure Procedure and Checklist, Version 3.2; Surveillance Procedures, Version 4.0; and Maintenance Procedures, Version 1.0
- reactor operations logbook entries from October 2021 to the present
- NSRB meeting minutes from September 2021 to the present b. Observations and Findings The inspector confirmed that written procedures were approved and available for the activities required in TS section 6.4. The inspector noted that the licensee updated the facility procedures as needed and they were reviewed and approved by the Facility Director and NSRB, as required by TS section 6.4.
c. Conclusion The inspector determined that procedure review and approval satisfied TS requirements.
2. Experiments a. Inspection Scope (IP 69001, Section 2.06)
The inspector reviewed selected aspects of the following to verify compliance with TS section 3.8, Experiments, and TS section 6.5, Experiment Review and Approval:
- reactor operations logbook entries from October 2021 to the present
- annual operating reports for 2020, 2021, and 2022 b. Observations and Findings Through records review and interviews with licensee staff, the inspector verified that the review and approval process for new experiments was conducted as required by TS section 6.5. The inspector noted that no new experiments were proposed or approved since the last inspection.
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c. Conclusion The inspector determined that the experiment review and approval process was functioning as required by the facility TSs.
3. Health Physics a. Inspection Scope (IP 69001, Section 2.07)
To verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, Standards for Protection against Radiation, and TS sections 3.7, Radiation Monitoring, 4.7, Radiation Monitoring, and 6.3, Radiation Safety, the inspector reviewed selected aspects of:
- dosimetry records from 2021 to the present
- radiation training records and presentation material
- calibration certificates and records for portable survey instruments for 2021 to 2023
- surveillance and calibration records for area radiation and continuous air monitors
- various reports for 2021, 2022, and 2023 including Radiation Safety Annual Reports and quarterly radiation surveys
- radiation safety manual, dated June 2019 b. Observations and Findings (1) Postings and Notices During tours of the facility, the inspector observed postings required by 10 CFR Parts 19 and 20 at the entrances to various controlled areas including the reactor room and storage areas. The inspector found that areas of the facility were posted as required, and that no unmarked radioactive material was found in the facility.
The inspector verified a copy of the current NRC Form 3, Notice to Employees, was posted.
(2) Dosimetry The inspector confirmed that dosimetry was used by facility personnel and verified that the licensee used a National Voluntary Laboratory Accreditation Program accredited vendor to process personnel dosimetry. The inspector verified that the quarterly occupational doses were within 10 CFR Part 20 limits.
(3) Radiation Monitoring Equipment The inspector reviewed the surveillance and calibration records for portable radiation detection, area radiation monitors, and air monitoring equipment for the inspection period. The inspector noted that survey meters are sent to an outside company for calibration. The inspector confirmed that the portable survey meters, area radiation monitors, and air monitoring equipment were calibrated within the calibration frequency as required by TS section 4.7.
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(4) Radiation Protection Program and Training The inspector verified that the radiation protection program was evaluated by the Radiation Safety Officer annually as required by TS. The inspector found that licensed operators were tested on principles of health physics as well as reactor operations. The inspector confirmed that annual training was provided to RCF staff members, and all current staff completed the required training.
(5) Environmental Monitoring During a tour of the exterior of the RCF, the inspector observed six thermoluminescent dosimeters placed around the perimeter fences. The inspector found that all dosimeters were present, at a sufficient level about the ground, and secured to the fence. The inspector verified that recorded doses were well below the applicable regulatory limits. The inspector confirmed that these results were also reported in the facility annual reports. The inspector verified that there were no effluent releases from the RCF to the environment during the past 3 years.
(6) Surveys Upon reviewing the quarterly radiation and contamination surveys conducted at the RCF, the inspector verified that the results of these surveys were reviewed and evaluated by the Radiation Safety Officer as required by procedure.
c. Conclusion The inspector determined that the licensees radiation protection program satisfied regulatory and TS requirements.
4. Design Changes a. Inspection Scope (IP 69001, Section 2.08)
To ensure that facility changes were reviewed and approved as required by TS section 6.2 and 10 CFR 50.59, the inspector reviewed selected aspects of:
- annual operating reports for 2020, 2021, and 2022
- reactor operations logbook entries from October 2021 to the present
- NSRB meeting minutes from September 2021 to the present b. Observations and Findings Through review of applicable records and interviews with licensee personnel, the inspector verified that no changes, tests, or experiments, subject to 10 CFR 50.59 requirements, were initiated since the last inspection.
c. Conclusion The inspector determined that no equipment, procedure, or experiment changes have occurred since the last inspection.
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5. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 2.09)
The inspector reviewed the following to ensure that the audits and reviews stipulated in TS section 6.2 were completed:
- NSRB charter dated July 25, 2008
- NSRB audit forms 1-4 for 2021 and 2022
- annual operating reports for 2020, 2021, and 2022
- NSRB meeting minutes from September 2021 to the present b. Observations and Findings The inspector noted that an NSRB quorum was present for the semiannual meetings and the required audits of reactor operations, procedures, equipment, and emergency preparedness were completed, documented, and reviewed by the NSRB as required by TS section 6.2.
c. Conclusion The inspector determined that audits and reviews were conducted by designated individuals and reviewed by the NSRB in accordance with the requirements specified in TS section 6.2.
6. Transportation Activities a. Inspection Scope (IP 86740)
The inspector reviewed selected aspects of:
- reactor operations logbook entries from October 2021 to the present b. Observations and Findings Through document review and interviews with RCF and RPI staff, the inspector confirmed that no radioactive material was transferred to or from the reactor since the last inspection. The inspector verified that, if needed, material to be shipped from RCF would be transferred to the universitys radioactive materials license issued by the State, and then packaged and shipped by RPI Environmental Health and Safety personnel.
c. Conclusion The inspector determined that no radioactive material was transferred to or from the RCF since the last inspection.
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7. Previously Identified Inspection Follow-up and Unresolved Items a. Inspection Scope (IP 92701)
To verify the corrective actions taken by the licensee to address a violation of requirements regarding testing and calibrating monitoring equipment specified in TS section 4.7 (VIO 50-225/2021201-01), the inspector reviewed the following:
- surveillance and calibration records for area radiation monitors and the continuous air monitor (CAM)
- various reports for 2021, 2022, and 2023 including radiation safety annual reports and quarterly radiation surveys b. Observation and Findings During a previous inspection in October of 2021 (Inspection Report No.
05000225/2021201), an inspector found that the licensee failed to test the CAM and area radiation monitors within the monthly surveillance interval specified and failed to calibrate the CAM within the semiannual surveillance interval required by TS section 4.7.
The licensee responded to the violation by letter dated January 5, 2022, in which the licensee outlined the problem and the corrective actions taken. The problem occurred with the onset of the COVID-19 pandemic and the RPI administrations directive to minimize RCF operations. An exacerbating factor was the staffs misinterpretation of TS Section 4.2 listing of various surveillances required to ensure that all reactor control and safety systems are operable. The eighth specification in the TS Section 4.2 list states that, Requirements 1 through 6 may be waived when the instrument, component, or system is not required to be operable, but a channel test shall be performed on the instrument, component or system prior to being declared operable.
Several surveillances were safely postponed during the period from March 2020 until August 2021. However, RCF staff incorrectly applied this criterion to TS Section 4.7 which applied to checking the CAM [continuous air monitor] and area radiation monitors monthly and calibrating these instruments semiannually.
The licensee took various corrective actions including revision of the checklist to clearly indicate which surveillances can be postponed and which must be completed regardless of operation status. This checklist is stored in the RCFs dual-verification-secured RPI BOX system which can be accessed by all staff members. In addition, all staff members reviewed the changes and discussed the importance of complying with the requirements stated in the TSs. This checklist revision and the return to a normal operation schedule have resulted in consistency in compliance.
The inspector reviewed the testing and calibration intervals of the CAM and area radiation monitors for the past 2 years during this inspection. The inspector verified that the test and calibration intervals were as specified in the TSs. Because RPI tested and calibrated the monitors within the time frames required by the TSs, the inspector noted that this issue was appropriately corrected to mitigate recurrence.
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c. Conclusion The inspector determined that a previous violation (VIO 50-225/2021201-01) is closed.
8. Exit Interview The inspector summarized the scope and results of the inspection on September 20, 2023, with members of licensee management and staff. The inspector described the areas inspected and discussed the inspection findings. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.
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PARTIAL LIST OF PERSONS CONTACTED Licensee C. Blake Senior Reactor Operator G. Caravalho RPI Radiation and Laser Safety Officer K. Cook Senior Reactor Operator RCF Director, and Professor, Department of Mechanical, Aerospace, and Nuclear Engineering P. Kowal RCF Operations Supervisor INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Inspection of Transportation Activities IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 50-225/2021201-01 VIO Violation of TS 4.7, Radiation Monitoring, Due to Failure to Test and Calibrate Radiation Monitoring Equipment Within the Required Frequency Attachment