IR 05000252/1997201
| ML20211N948 | |
| Person / Time | |
|---|---|
| Site: | University of New Mexico |
| Issue date: | 10/09/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20211N933 | List: |
| References | |
| 50-252-97-201, NUDOCS 9710170177 | |
| Download: ML20211N948 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION Docket No:
50-252
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License No:
R 102 r
Report No:
50 252/97201 (DRPM)
Licensee:
University of New Mexico l
Facility Name:
AGN 201M Reactor (5 watts)
Location:
Albuquerque, New Mexico
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Dates:
September 15-18,1997 Inspector:
T. M. Burdick Approved by:
Seymour H. Weiss, Director Non Power Reactor and Decommissioning Project Directorate
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9710170177 971009
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PDR ADOCK 05000252 O
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Executive Summary AGN 201M Reactor
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Report No. 50 252/97201(DRPM)
This routine, announced inspection included aspects of organization, operations, and procedures; requalification training; surveillance; experiments; radiation controls and environmental protection; design change; audit and review; emergency preparedness; maintenance; and fuel handling activities (69001); fixed s.ite physical protection of special
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nuclear material (SNM) of low strategic significance (81431); material centrol and accounting of SNM (85102); protection of se' 'uards information (81810); reports of safeguards events (81402); plans, procedures, eviews (81401); review of licensee reports (90713); and followup of items of noncompnance (92702).
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Oraanization and Staffina (69001)
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The AGN Reactor staffing has been stable since the last inspection, in March 1997 the
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j licensee identified that two of the three licensed senior operators had their licenses expire
in May 1995. Both operators continued to perform licensed duties during the period that their licenses were expired. This is a Non Cited Violation. (Section 1.0)
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Ooerations, Procedures. Exoeriments. Maintenance. and Fuel Handlina (69001)
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- No concerns were identified.
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Beaualification Program
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The licensee failed to ensure that the three licensed senior operators maintained proficiency e
by performing licensed duties for a minimum of four hours per calendar quarter. This is a violation, o The licensee's NRC approved requalification program did not include an annual evaluation of operator performance as required by 10 CFR 55.59 but the licenw committed to revise the program to include the requirement.
(Section 4.0)
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Surveillance and Limitina Conditions for Ooeration (69001)
The licensee failed to measure total scram time annually for scrammable rods as required.
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This is a violation. (Section 5.0)
Radiation Control and Environmental Protectinn (G9001)
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e The exposures to employees, students, researchers, and members of the public did not
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exceed regulatory limits. (Section 7.0)
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Desion Channes (69001)
lie NRC ppproved Technl.:al Specification changes for the replacement of two safety
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iJadear instrument channels prior to !mplementation. (Section 8.0)
Audits and Reviews Audits by the Reac*or Safety Advisory Committee (RSA.) identified noncompliances that
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occurred during the period inspected. This is a Non-Cited Violation.
. e The licensee had not clearly documented their audit and review reports but initiated an improvement effort.
(Section 9.0)
Emeroenev Preoaredness (69001)
e ;The licensee had no record of drill evaluations for two of the last threo years reviewed by the inspector.
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Periodic and Soecial Reoorts(90713)
The licensee's annJa! reports did not always address required topics in sufficient detail for e
NRC review and assessment. (Section 13.0)
Ehesical P aictction (81431): Plyt Procedures. and Reviews (81401) Reoorts of Sateauard J
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Events. (B1402): Protection of Safeauards information (81810): and Material Control add i
Accountino (S5102)
- - Access control to' the nuclear engineering lab was not always carried out as required. This is a vic:ation.
The licensee's TS requirements for storing fuel conflicted with the Physical Security Plan
(PS?). (Section 14.0)
Follow-un (92702)
The licensee's corrective action 'or previcusly identified violations was acceptable. (Section u
15.0)
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DETAILS Plant Summary The AGN Reactor at the University of New Mexico continues to support teaching in the graduate and undergraduate programs. The reactor was out of service from July 1994 until December 1995 due to the process of obtaining Technical Specification (TS) revision approval and the replacement of Safety Channel 2, 1.0 Organization a.
Inspection Scope f69001)
The inspector reviewed TS, and the Safety Analysis Report (SAR), and Safety Evaluation Report (SER) related to organization and staffing and compared the requirements with current conditions.
b. Observations and Findinog The inspector determined that the organizational structure and assignment of responsibilities were as specified in TS 6.0.
The licensee identified in February 1997 that two of their three senior reactor oporators'
licenses had expired in May of 1995. The cause was the lack of a system ta track the dates. They immediately curtailed any licensed duties for the two individuals and applied for new licenses. The two udividuals' performance, experience and activities demonstrated there was no significant safety concem and new licenses were issued in March 1997. The licensee established an improved system of identifying license renewal dates.
This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consisient with Section Vll.B.1. of the NRC Enforcement Policy.
Membership of the RSAC was made up of qualified people from outside the university.
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Conclusions The licensee organization was as required except that two of three operators continued to operate when their licenses expired.
2.0 Operations Activities a.
Inspection Scope (69001)
- The inspector reviewed the reactor operations logs and records to determine compliance with Operating License Condition 2.C, TS 3.0 and 6.10, and applicable implementing procedures.
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b. Observations and Findinas The licensee had operated the reactor intermittently at various tharmal power levels in accordance with Operating License Condition 2.C.
Selected reactor operat.r logs from June 1994 through August 1997 were reviewed.
The logs were acceptat ie.
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c. Conclusions The licensee operated and maintained the reactor in accordance with the reactor's license conditions, safety limits and limiting conditions for operation. The licensee's logs and records uocumented reactor operations.
3.0 Procedures
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l a. Insoection Scoce (69001)
The inspector reviewed the licensee's written procedures and their use for operating and maintaining the reattor, perforrning survei' lance activi+iss, and conducting
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expetiments to determine compliance with the requirements in TS 6.6 and 6.7 and related administrative procedures.
b. Observations and Findinas The inspector had difficulty verifying that procedures were reviewed by the licensee as required due to the unclear record of RSAC meeting minutes. The licensee recently began to improve their documentation of reviews.
c. Conclusic,as The licensee had procedures sufficient to conduct reactor operations, maintenance, experiments, surveillance testing, and instrument calibrations according to TS requirements.
4.0 Requalification Training a. Insoection Scooe (69001)
The inspector reviewed the reactor operators' requalification training program and records to determine compliance with the requirements in 10 CFR 55.59, TS 6.3, and 6.10.g and the NRC approved requalification program.
b. Observations and Findinas The licensee's last three annual written exams were acceptable. Each licensed operator had a current license and physical examination. Operators were aware of the required physical examinations every two years.
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-3-The three licensed operators were all senior operators.
The inspector noted that, folinwing the long reactor outage from July 1994 to December 1995, they went through retraining in preparation for operation in 1996.
Title 10, Part 55, Section 53(e) requires each licensed operator to conduct at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of licensed activity per calendar quarter to maintain sufficient proficiency, if that cannot be met, Section 53(f) requires restoration of their active license by performing at least 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of licensed duties under the direction of another individual with an active license prior to resuming licensed duties.
During the first quarter of 1996 two of the three operators conducted at least four hours of licensed activities. In the second quarter of 1996 one of the two active licensed operators conducted at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of licensed activities. During the third quarter none of the operators conducted 'icensed activities. In the final quarter of 1996 all three operators conducted operation of the reactor but only one had operated during the previous quarter for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Failure to perform the minimum required number of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per calendar quarter or to operate Jnder the direction of another qualified individual for at least 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> before resumption of licensed duties is a violation (50 252/9720101).
The licensee stated that they were unaware that the regulation 3 required the performance of a minimum number of hours of licensed duties to maintain their operators' licenses active. Instead, they had understood that a minimum number of reactivity manipulations were required.
The licensee committed to ensure that the three operators conduct the minimum required hours to maintain or restore their active licenses, as appropriate, in the future.
Two of the three operators currently met the requirements for the third quarter 1997 and all three were being scheduled the necessary hours to qualify for the next calendar quarter at the end of the inspection.
The inspector identified that the licensee's program did not include a requirement to cenduct annua' operating tests as required by 10 CFR 55.59. A review of the licensee's March 1987 SER showed that the NRC had approved the current program.
The licensee proposed to submit a revised program for NRC approval that includes annual operating evaluation of the operators. This is an inspector Followup item (50-252/97201-04),
c. Conclusions The inspector identified one violation. The licensee has committed to revise their program to provide additional assurance that NRC requirements will be met.
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I 5.0. Surveillance and Limiting conditions for Operation a. insoection Scooe (69001)
The inspector reviewed selected surveillance test documentation to determine compliance with the requirements in TS 3.0 and 4.0.
I b. Observations and Findinos TS 3.2.b requires that total scram time for both safety rods and the coarse control rod be less than one second. TS 4.2.a. requires that scram times for the three rods be measured annually, The inspector identified that the licensee had not measured the scram time for rods in the past but had observed the rod drop within a test fixture
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outside the core. The licensee estimated that the rod took less than one second to
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drop from the top to the bottom of the test fixture.
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l The licensee had taken credit for a measured prompt drop time of nuclear power between 300-400 milliseconds during rod worth testing. This does not, however, t
account for all time delays from initiation of the scram signal to completion of rod travel. This is a violation. (50-252/97231-02)
The licensee had been evaluating the possibility of methods for measuring scram time prior to the inspection but had not determined the best method by the end of the inspection, c. Conclusions The inspector identified a violation of requirements to measure the scram times of control rods.
6.0 Experiments a. Insoection Scoce (69001)
The inspector reviewed the licensee's program to control and conduct experiments performed in the reactor to determine compliance with the requirements in TS 3.1,3.3 and 6,7 and related licensee procedures.
b. Observations and Findinos The inspector reviewed a sampling of experiments. All experiments were well-established procedures for student teaching purposes.
c. Conclusings Those reactor experiments reviewed by the inspector were conducted in accordance with properly reviewed and approved procedures and satisfactorily documented in the reactor oper.dions lo *
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-5-7.0 Radiation Control and Environmental Protection a. Insoection Scoce (69001)
The inspector reviewed the radiation protection program and records and interviewed personnel to determine compliance with the requirements in 10 CFR Part 20 and TS 3.4 and 4.4 and related licensee proceduros.
The inspector reviewed the licensee's program for the discharge or removal of radioac+ive liquid, gases, and solids from the reactor laboratory.
b. Observations and Findinas All badged reactor personnel exposures were below 10 CFR 20.1201 limits and generally less than detectable.
Because of the reactor design, there were no gaseous or liquid effluents. Only minor amounts of solid waste were generated and transferred to the campus safety office for disposal.
c. Conclusions The licensee's radiation protection program and environmental monitoring were acceptable.
8.0. Design Changes a. Insoection Scoce (69001)
The inspector reviewed design changes, if any, to determine that the licensee reviewed and approved them as required by 10 CFR 50.59 and licensee procedures; whether modified equipment performance met regulatory and procedural requirements or licensee commitments; the licensee reviewed and approved procedures affected by
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the modifications; and whether the licensee changed affected drawings as required.
o. Observations and Findinas The licensee installed two rep!acement nuclear instrument channels after obtaining NRC approval of the TS changes needed to proceed.
The upgraded equipment appeared to have been installed correctly and operated properly. Procedures were modified accordingly.
c. Conclusions The replacement nuclear instrumentation met the TS requirements as accepted by the NR. _ _ -
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Thu.nspector reviewed the RSAC meetings, audits, and reviews to determine compliance with the requirements in TS 6.4.1,6.4.2, and 6.4.3.
b. Observations and Findings They normally held RSAC meetings at the required 7-1/2 month intervals, The licensee identified one instance when the meeting was delayed longer than the TS required interval due to a lack of a quorum. They also identified that the meeting minutes were sometinies distributed to the required perties later than the maximum TS limit of ten weeks. Lastly, they identified that the 1995 annual report to the NRC was submitted late.
i The licensee had taken actions to correct these problems by adding an additional member to the RSAC; obtaining support from the administrative staff to record and prepare the meeting minutes; and by pursuing a better system of tracking issues and requirements.
These licensee-identified and corrected violations are being treated as a Non-Cited Violation, consistent with Section Vll.B.1. of the NRC Enforcement Poliev.
The inspector found it difficult to verify that the licensee had met all requirements for review and audit because of the unclear record of meeting minutes kept until the recent changes cited above.
c. Conclusions Improvements in the licensee's approach to conducting their RSAC meetings, staffing the committee, and recording their minutes may correct the self-identified problems.
10.0 Emergency Preparedness a. Insoection Scoce (69001)
The inspector reviewed the emergency plan, procedures, and drill records for the reactor laboratory; interviewed licensee employees; and inventoried storage lockers to determine compliance with the requirements in 10 CFR 50.54(q) and (r), TS 6.4.3 and 6.7.h.
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The inspector verified that the 1997 drill had been conducted and evaluated as required. Records of the previous drill evaluations ware unavailable for review.
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The inspector found no requirement to retain the drills or evaluations as records.
The licensee's emergency facility equipment and supplies were in storage and readily available for use.
- Personnel were aware of their responsibilities.
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The licensee's Emergency Plan was functional.
lL-11.0 Maintenance Logs and Records a. Insoection Scone (69001)
, The inspector reviewed the maintenance program to verify that logs and records were maintained as required; significant problems and events, if any, were identified by.
review of the logs and records and reported as required; and that maintenance was conducted as required.
b. Observations and Findinos No concerns were identified.
. c. Conciusi;tDA The licensee's program was acceptable.
12.0 Fuel Handling a. Insoection Secoe (69001)--
The inspector reviewed the fuel handling proce: lures and records at the reactor laboratory, and interviewed employees.
b. Observations and Findinas
' Fuel handling was cond_ucted annually for an experimental demonstration in an approach-to-critical lab.. The procedure has been well established over the years with no changes. All movements were recorded in the operations log book.
c.: - Conclusions The licensee's procedures and documentation for fuel movement were acceptable.
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13.0 Review of Pe; iodic and Special Reports a. insoection Scooe (90713)
The inspector reviewed the licensee's submittal of repor1s and notifications to the NRC to determine compliance with the requirements in TS 6.9.
b. Observations and Findinas
- The inspector found that the last three annual reports usually reflected actual conditions and status of the reactor laboratory.
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Some of the TS required topics in the reports were not clearly addressed in the reports including radiation dose summaries and unplanned reactor scrams. The licensee L
proposed amending their recent 19961997 report to include those areas, l
c. Conclusions The licensee had submitted required reports to the NRC in accordance with TS requirements and committed to make al amended report for 1996-1997.
14.0 PhysicalSecurity and Material Accounting Programs a.1.
insoection Scone (81401. 81402. 81810. and 81431)
The inspector reviewed the licensee's plan to assure that changes, if any, have not reduced the overall effectiveness of the plan; that the implementation procedures were edequate to meet regulations; that the licensee reported all safeguards events if any, as required; that safeguards information was protected as required against unauthorized disclosure; that the licensee's physical protectivn system would minimize the potential for unauthorizea removal of SNM; and would facilitate the location and recovery of missing SNM.
b.1. Observations and Findinos A new improved intrusion monitoring system had been installed. The UNM police force showed that they can provide response as required.
The inspf.ctor identified one instance where the licensee failed to carry out the access control procedure as required over an extended '.ime period. _ Section 3.2.2.1 of the PSP required that unescorted access to the nuclear engineering lab be restricted to those students who were cualified as Radiation Supervisors, had work associated with the lab, and had signed a written agreement to comply with the PSP
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requirements before receiving the revised access codes each semester. One student identified by the inspector had access to the lab until his departure in
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February 1997. However, the inspector verified that student had not been a
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qualified Radiation Supervisor and he had not signed a written security agreement sinc 6 the 1994 Fall semester. This is a violation (50-252/97201-03).
The student's name had been removed from the unescorted access list in early (
September 1997.
I lhe licensee acknowledged the access control problem and was considering I
methods to prevent recurrence at the end of the inspectica The inspector also identified a conflict between TS 5.2 and the PSP Section 3.3 regarding the storage of reactor fuel. The 1+ensee committed to take steps to eliminate the conflict.
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c.1. Conclusions One violation was identified by the inspector.
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a.2. hsoection Scoce (85102)
The inspector reviewed the licensee's material and accounting program to assure that the possession and use of SNM were limited to the location and purpose authorized by the license; and that the licensee implemented an adequate and effective program to account for and control the SNM in his possession, b.2. Observations and Findings No concerns were identified.
c.2. Conclusions The material accountability of authorized SNM was acceptable.
15.0 Followup on items of Noncompliance a.
Insoection Scoce (92702)
The inspector followed up on two violations identified in inspection report No.
50-252/94-01. Review included licensee evaluation, immediate corrective actions, and long term actions to prevent future recurrence.
b. Observations and Findings 1. Violation 50-252/94-01-01(Closedt failure to notify the NRC of Emergency Plan changes. The inspector verified the corrective actions described in the licensee's June 30.1994, response letter to be reasonable and complete. No similar problems were identified.
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Violation 50-252/94-01-02 (Closed): failure to notify the NRC of Security Plan changes.- The inspector verified the corrective %ilons described in the licensee's June 30,1994, response letter to be reasonable and complete. No similar problems were identified.
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Conclusions The licenses acceptably addressed the items of non-compliance that were reviewed by the inspector.
- 16.0 Exit interview (30703)
l The inspector presented the inspection results to members of the licensee management at
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- an exit meeting on September 18,1997. The licensee acknowledged the findings presented. The inspector asked the licensee whether any material examined during the inspection should be considered proprietary. The licensee identified the PSP as proprietary information.-
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_ Persons Contacted _
University of New Mexico
- N. Roderick Reactor Administrator -
- R. Busch Chief Reactor Supervisor
- J. Graham Radiation Safety Officer
- K. Carpenter Senior Reactor Operator The inspector also contacted other technical and administrative staff personnel during the inspection.
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- Denotes those attending the exit meeting on September 18,1997.
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Insoection Procedures Used
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IP 69001 Class h Non-Power Reactors l
IP 90713 Review of Periodic and Special Reports IP 92702 Followup Up on items of Noncompliance IP 81431--
Fixed Site Physical Protection of SNM of Low Strategic Significance IP 81401 Plans, Procedures, and Reviews j_
IP 81402 Reports of Safeguards Events
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Protection of Safeguards information IP 85102 Material Control and Accounting items Ooened and Closed
- 09f1D 50-252/97201-01 VIO '
Failure to maintain operator proficiency-50-252/97201-02 VIO Failure to measure rod scram times 50-252/97201-03 VIO Failure to control access 50-252/97201-04 IFl.
Licensee commitment to annual operating tests Closed 50-252/94-01-01 VIO Failure to report Emergency Plan changes 50-252/94-01-02 VIO Failure to report Security Plan changes List of Dacuments Reviewed Administrative Procedures Dosirnetry Records Emergency Plan Emergency procedures Experiment Procedures
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2 Maintenance and Surveillance Records (
. Maintenance Procedures Operating Procedures Physical Security Plan Reactor Operating License Safety Evaluation Report Safety Analysis Report SNM Inventory Records Surveillance Procedures Technical Specifications Training Program
- Training Records Various Reports List of Acronyms Used CFR.
Code of Federal Regulations
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DRPM Division of Reactor Project Management NRC-Nuclear Regulatory Commission PDR Public Document Room PSP Physical Security Plan-RSAC_-
Reactor Safety Advisory Committee b \\R Safety Analysis Report SER Safety Evaluation Report SNM Special Nuclear Material-TS Technical Specifications
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INSPECTION FOLLOW-UP SYSTEM (IFS)
SPEED CLOSEOUT / UPDATE FORM
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DOCKET RESPONSIBLE !NDIVIDUAL: T Burdick (T18)
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FACILITY: University of New Mexico AGN-201M Reactor AFFECTED UNITS ITEM ITEM REPORTNL8NBER SEO.
QDSEA.HRTEIBORT INSPECTION ITEM (%/3)
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ISSUE DATE l STATUS *
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(FOR ESCALATED ITEMS ONLY)
AFFECTED UNITS ITEM EA NUMBER NOV ID NUMBER QDSEDUT E70RThD.
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TYPE g l
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