IR 05000284/1991001
| ML20087C749 | |
| Person / Time | |
|---|---|
| Site: | Idaho State University |
| Issue date: | 01/08/1992 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20087C739 | List: |
| References | |
| 50-284-91-01, 50-284-91-1, NUDOCS 9201150019 | |
| Download: ML20087C749 (13) | |
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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSIGN
REGION IV
NRC Inspection Report:
50-284/91-01 Operating License:
R-110 Docket: 50-284 Licensee:
Idaho State University (ISU)
Pocatello, Idaho 83209 Facility Name:
ISU Lillibridge Engineering Laboratory - AGN 201-M(5 Watt)
Inspection At:
ISU Campus, Bannock County, Pocatello, Idaho-Inspection Conducted:
December 9-12, 1991
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Inspectors:
A. D. Gaines, Radiation Specialist L. Wilborn, Radiation Specialist
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Approved:
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$laina Murray, Chief,]FcilitiesInspection Dhte /
Programs Section i
Inspection Summary-Inspection Conducted December 9-12, 1991-(Report 50-284/91-011:
Areas Inspected:
Routine, announced inspection of the licensee's management organization,-training and qualifications, reactor operations.and maintenance, procedures, experiments, surveillances,-internal audit and review program, radiation-protection program, emergency preparedness, "adioactive material transportation, special nuclear material accountability,--and physical security and safeguards.
Results: Within the areas inspected. three violations were identified.
These violations involved:
(1) failure to implement the reactor operator requalification program (paragraph 5), (2) failure to implement _ the Radiological Emergency Plan (paragraph 12), anc (3) failure to perform audits (paragraph 13). One open item involving-letters of agreements with emergency
. support organizations was identified (paragraph 12).
No deviations were identified.
The_ licensee's overall program was good witn no significant programmatic weaknesses identified. The inspectors noted that improvements were made regarding the concerns identified during the previous inspection.
The violations identified in this inspection appeared to be the result of the lack of a comprehensive self-audit program.
Enclosure contains PROPRIETARY INFORMATION Decontrolled when separated from attachment.
9201150019 920:09 PDR -ADOCK 05000284 G
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2-DET Ali 5, 1.
Persons Contacted I S__U
- V. Charyulu,-Dean College of Engineering, Reactor Administrator
- A.. Wilson, Reactor Supervisor, Senior Reactor Operator
- F.' Just, Chairman, Reactor Safety Committee
- T. Gesell, Professor, Healtn Physics D.'Levinskas,-Senior Reactor Operator S. Cunningham, Health Physicist, Reactor Operator
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Others S._Chatterton, Olrector, ISU Campus Security M._Stayner, Captain, Pocatello Police Department S. Simmons, Pocatello Fire Department
.P. Carlson, Nuclear Medicine Technologist, Bannock Regional
. Medical Center E
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- B. Murray, Chief, Facilities Inspection Programs Section
- Denotes.those present at the exit meeting on December 12, 1991.
2.
~ Followup on Previous ~ Inspection Findings- (92701)
-(Closed) Violation'(284/8901-01): _ Licensed Operator Requalification--
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This violation was discussed in NRC Inspection Report 50-284/89-01 and involved the failure of.a member of the Reactor Safety Committee to perform observations of one senior reactor'cperator and one reactor-
- operator at least once each calendar year.
The inspectors examined the.
licensee's correctivt. actions in their April 24, 1989, response to the violation.
The inspectors. reviewed the requalification-program and associated records for 1989, 1990,- and 1991=and found observations were
_ performed and documented'in accordance_with_requiremen_ts.
The licensee's-corrective' actions were; adequate to close this-violation.
(Closed) Violation _(284/8901-02):
Emergency-Plan Implementation - This
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violation was discussed in NRC Inspection Report ~ 50-284/89-01 and consisted of two_ items: _ (1) _ the failure-to conduct an annual drill of.the ISU Emergency Plan, and;(2);the failure to audit'the ISU Emergency-Plan
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every 2 years._.-The inspectors examined the licensee's corrective actions committed to'in'their-April-24 and May 24, 1989, responses to the violation, The inspectors reviewed the Emergency Plan implementation and associated records for 1989,-1990, and 1991 and found that the licensee failed to-conduct a-drill-'of=the-Emergency Plan during 1990,- but the-
-licensee had audited the Emergency plan every two years. The licensee's corrective actions e re adequate-to close Item 2 of the violation, but Enclosure contains PROPRIETARY INFORMATION Decontrolled when separated from attachment.
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were not sufficient to prevent Item 1 from recurring.
This violation is considered closed, and the repeat violation of Item 1 is discussed in paragraph 12.
(Closed) Violation (284/8901-03):
Physical Security Plan Revision - This violation was discussed in NRC Inspection Report 50-284/89-01 and.rvolved changes, without prior NRC approval, to the Physical Security Plan whicn would have decreased the effectiveness of the plan and not submitting a report to the NRC of changes in the Physical Security Plan.
The inspectors examined the licensee's actions committed to in their April 24 and May 24, 1989, responses to the violation.
The inspectors reviewed the implementation of the Physical Security Plan and associated records for
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1939, 1990, and 1991 and found the licensee had submitted to NRC for prior approval revisions to the Physical Security Plan.
The licensee's corrective actions were adequate to close this violation.
(Closed) Open Item (284/8901-04): Tracking Annual and Quarterly Operator Activities - This item was discussed in NRC Inspection Report 50-284/89-01 and involved the development of administrative controls over the Operator Reaualification Program files and implementation of an operator matrix that would identify coLpletion of each item in the Ooerator Requalification Program.
The inspectors reviewed the Operator Requalification Program and noted that a new form had been established that documents euch item in the operator recualification program.
This item is considered closed.
(Closed) Open Item (284/8901-05): Operator Reaualification Tests - Tnis item was discussed in NRC Inspection Report 50-2e4,'S9-01 and involved the evaluation of requalification tests for subject comprenensiveness.
The licensee implemented a test orogram that utilizes the test question bank maae up of NRC administered cperator and senior operator test cuestions.
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The inspectors reviewed the operator recualification tests administered by the licensee since the last inspection and notea that they consisted of questions made up from the NRC bank of questions.
This item 15 considered closed.
(Closed) Open Item (284/E901-06):
Experiment Acproval Documentation -
This item was discussed in NRC Insoection Report 50-234/89-01 anc involved the need for the licensee to provide, on each experiment procedure, the revision, date, and signature of the approving authority.
The inspectors reviewed the licensee's experiment procedures and noted that they included the revision, date, ana signature of the approving authority.
This item is considered closed.
(Closed) Open Item (284/8901-07): Neutron Dosimetry - This item was discussed in NRC Inspection Report 50-284/89-01 and involved the evaluation of personnel neutron dosimetry and its insensitivity to low energy neutrons.
The inspectors noted that the licensee had evaluated
their neutron dosimetry and had obtained new dosimetry which is sensitive to low energy neutrons.
This item is considered closed.
Enclosure contains PROPRIETARY INFORMATION
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(Closed) Open item (284/8901-08):.NRC Form 5 - This item was discussed in
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NRC-Inspection Report 50-284/89-01 and involved the evaluation of the l
personnel-exposure record system. The inspectors. determined that the licensee evaluated their dosimetry record systems and updated the information provided by their_ dosimetry vendor to ensure that the exposure data adequately represented an NRC Form 5 equivalent.
This item is considered closed.
(Closed)-Openitem(284/8901-09):
Reactor Safety Committee Audits - This-i item was discussed in NRC-Inspection Report 50-284/89-01 and involved self
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audits to verify compliance with the Facility Operating License and Technical Specifications, and the applicable reauirements of 10 CFR Parts 19, 20, 50, and 55.
The NRC inspectors identified several violatient during this inspection,.one of which was a= repeat violation, which should have been identified as part of the licensee's self-audit program. The licensee stated that they-plan to develop:a comprehensive audit program including detailed checklists in order to make improvements in this area.
This item is closed.
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(Closed)OpenItem(284/8901-10):
Reactor. Laboratory Fire Protection -
This item was discussed in NRC Inspection Report _50-284/89-01 and involved the evaluation of the fire protection program for the reactor laboratory.
The inspectors noted that the licensee had installed a smoke detector _in the reactor laboratory'that would alert the Pocatel;o Fire Department.
This item is considered closed.
_(Closed) Open Item (284/8901-11):
Access Key and Material Controls - This
' item was discusseo in NRC Inspection Report 50-284/89-01 and involved the securityLof fuel fragments-and controls for access area keys.
The inspectors.noted that_the licensee added a lock to the container of fuel fragments-and instituted a control program for access area keys.. This item is considered closed.
3.
Inspection Followuo items-Identified During This Inspection _-
An inspection followup item' is a' matter that requires f urther _ review and -
-evaluation.
The" are used to document, track,-and ensure adequate followup on matters,of concern to the inspectors.
The following inspection followup item was.-i_dentified:
Inspection Followup.
Title Paragraph 284/9101-04:
Letters'of Agreement
4.:
Organization and Management Controls -(40750)
The inspectors-reviewed the licensee's organization and staffina to determine compliance with Technical Specification (TS' 5.0.
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The inspectors verified that the organizational structure was as specified in the TS. All organizational' positions were staffed by qualified Enclosure contains PROPRIETARY INFORMATION Deccatrolled-when separated from attachment.
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. personnel.
The. licensee had several staffing changes since the last NRC inspection.
In June 1989 the Dean o' the College of Engineering became the Reactor _ Administrator.
The most notable change occurred in August 1990 when the person who held both the Reactor Supervisor and the Radiation. Safety Officer posi.tions'torminated employment.
The Reactor Supervisors position was filled by a person who-had previously held the'
position.- Three different indisiduals had held the position of Radiation
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Safety-Officer since August 199C.
The inspectors discussed the importance of Radiation Safety _ Officer oversight to ensure that a proper reactor radiation' protection program is Iaintained.
No violations or deviations were identified.
5.
-Trainino-and Qualifications (40750)
The-inspectors _ examined the-licensee's training programs for laboratory / reactor-workers and requalification of reactor operctors to determine compliance with the requirements of 10 CFR Parts 19,12 and 55.59.
On December __10, 1991, the inspectors coserved as one of the :enior reactor
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operators-performed a~ reactor startup, Experiment No. 3C, steady state.
operations and reactor-shutdown.
The senior reactor operator performed
~the'above' operations in accordance with all applicable procedures and license conditions.
The inspectors noted that the licensee's radiological safety training for personnel frequenting the reactor laboratory was implemented by attending
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specified courses.
The inspectors determined that the courses satisfied-the1recuirements of-10 CFR Part 19.12.
The' licensee currentlyLhas five licensed operators (two operators and three-' senior reactor. operators).
'The inspectors reviewed the _ licensee's documentation of-the two senior
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reactor operators participation in the NRC approved (February 1974)
Operator Requalification Program. The licensee had developed a-good form to track and document operator requalification_ requirements.
However, i t
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was noted that some of the forms where incomplete, but the inspectors were-able to find the_ missing information,in other_ documents.
The inspectors discussed with the licensee the effectiveness of-the new form and the need to ensure that it was kept up to date.
The licensee's Ope-ator Requalification Program requires that a member.of~the Reactor Safety 1 Committee observe annual.ly the operation of the reactor by each _ licensed operator. A review of records indicated that a member of the Reactor Safety' Committee observed both licensed senior reactor operators operate the reactor in 1989, 1990, and 1991.
The licensee's requalification tests given to two senior reactor operators were reviewed. 'The comprehensiveness of tests was improved from that noted during the last inspection.
This improvement was in part due to the Enclosure contains PROPRIETARY INFORMATION Decontrolled when separated from attachment.
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licensee utilizing the-test question bank made up of NRC administered =
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operator and senior reactor operator licensing test questions.
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I The inspectors noted that operator requalification tests were.given to the-two ser.ior reactor operators in September 1989 and October 1991, but none were administerad in 1990.
10 CFR Part 55.59(c) requires that a facility licensee _shall-have a reactor operator requalification program reviewed and approved by the Commission.
Technical Specification 6.3 of the ISU-Facility _ Operating License, Amendment 4 requires that all licensed-reactor = operators shall participate it requalification training as set-A forth_in 10 CFR Part-55.
Section 4.a o# the licensee's NRC approved reactor operator' requalification program requires that an annual written examination covering the entire area of reactor operations for the AGN-201 reacto'r will be administered to all operators and senior operatrrs by-the Reactor Safety Committee'at Idaho State University.
The inspectors determined on December 12, 1991, that.the licensee's Reactor Safety Committee had not administered an annual written
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-examination to-two senior: reactor operators-in 1990.
The failure of the Reactor _ Safety Committee to administer a written examination to senior
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reactor operators '.n 1990 is considered an apparent violation of-10 CFR-Part-55.59(c)(284/9101-01).
One violation and no-deviations were identified.
6.
Reactor' Operations- (40750).
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The inspectors reviewed logs and records, and' observed reactor operatiora to determine-compliance with License Conditions 2.C.) and 2.C.2 and TS 2.0
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and 3.0.
LThe. inspectors inspected'the-licensee's facilities;and observed licensee startup,Loperation, and shutdown ofithe reactor-to verify reactor?
protection. systems operation.
The inspectors noted that'the reactor;was operated approximately.157 hours0.00182 days <br />0.0436 hours <br />2.595899e-4 weeks <br />5.97385e-5 months <br /> in 1990 for the purpose of. laboratory
--experiments, reactor system tests,. reactor surveillances, and sample
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teradiations. The licensee initiated startup of the reactor on
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December 10, 1991,_and operated the reactor at 4.5' watts _ steady-state-power to demonstrate to-the inspectors the operation of the reactor protective systems.
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The inspectors reviewed _ reactor operations-logs and records =to determine t
compliance with the license conditions and TS requirements.
The-licensee
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had not operated.the reactor at thermal power levels in excess of-5 watts.
The. inspectors verified that. reactor safety limits had not-been exceeded.
- In the.last annual control' rod worth determinations, the reactor shutdown margin and excess reactivity were-verified to be within TS limits.
The inspectors. verified that all the required reactor control system-instrument channels, safety circuits, and safety interlocks required by 15
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were tested and operable and were included as part of the reactor startup
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checklist. The area radiation monitor was checked and verified to be-Enclosure contains PROPRIETARY INFORMATION Decontrolled when-separated from attachment.
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operational prior to reactor startup.
The licensee's logs and records adequately documented reactor. operations and required maintenance.
i No violations or deviations were identified.
7.
Procedures (40750)
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The inspectors reviewed the licensee's. procedures for operating and maintaining the-reactor, conducting surveillances and calibrations, and-conducting experiments-to determine compliance with the requirements of TS 6.5 and 6.6.
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The inspectors determined that the licensee had developed a set of general
-cperating rules, 3 reactor operating procedures,.9; surveillance,
. maintenance, and calibration-procedures,- ano 21 experiment procedures.
One operating, one maintenance, and one experiment procedure had been
.added since the-lart inspection.
A review of selected procedures
. including new procedures or those revised and approved since the last NRC inspection.in March 1989, indicated that'the licensee-had sufficient procedures to meet TS requirements.
The following new and revised-procedures were examined by the inspectorsi AGN-201 Opera' ting Procedure No 1, Revision 2, 2/23/90
AGN-201_0perating Procedure No. 2, Revision 2, 2/23/90
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' Test Procedure AGN-201 Automatic Reactivity Control System, Operating Procedure No.-3,. Revision 0, 2/23/90
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'Open Core Tank,-MP-2, Revision 0, 5/2/89
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- -Reactor Demonstration, EP-1,' Revision 2, 2/23/90
Reactor Control Rod Calibration, EP-3, Revision 3,- 2/23/90 Effects of Materials on Reactor 0peration, EP-9, Revision 2,
2/23/90
Flux Determination of a Reflector Port Neutron Beam, EP-10, Revision 2, 2/23/90
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Dose Rate Determination-in Experimental Ports, EP-11, Revision 2,
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Reactivity Oscillator for the AGN-210, EP-12, Revision 2, 2/23/90-Evaluation of Shielding Materials, EP-14, Revision 2, 2/23/90
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Determination of Neutron Binding Energies, EP-16, Revision 2, 2/23/90 L
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Automatic Reactivity Control System Operation, EP-21, Revision 0,-
2/23/90 The procedures examined by the inspectors had been reviewed and approved by the Reactor Safety Committee and their reviews were documented in the-Reactor Safety Committee meeting minutes.
The licensee maintained a procedures master notebook to consolidate the most recent revisions of operating rules, operating procedures, maintenance procedures, surveillance procedures, the Physical Security Plan, and the Emergency Plan. The licensee also kept control room copies of the above procedures at the control console for use by reactor
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operators. The inspectors ietermined that the control room copy of-procedures contained Revision 1 of the " General Operating Rules," while
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the master notebook contained the original copy. Also, the control room copy contained Revision 2 of MP-1, " Control Rod Maintenance," whereas the procedures in'the master notebook contained Revision 4 The inspectors discussed with-the licensee the importance of maintaining up-to-date
procedures-in the control room.
The licensee stated that they would
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review the-operator procedure maintained at the control console to ensure operators-have access to current procedures.
The inspectors reviewed the control ioom copies of the experiment
. procedures used by the reactor operators.
The inspectors noted that the
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control room copies of proc,Jures EP-3, EP-5, and EP-9 contained numerous-handwritten changes.
The licensee stated that these changes had not been formally adopted. -The inspectors discussed with the licensee the need to formally incorporate the handwritten changes in the' control room copies of the experiment procedures.
The licensee stated that they would update their exp?riment procedures to ensure that all changes are formally reviewed and approved.
No violations or-deviations were identified.
8.
Experiments (40750)
Tha inspectors examined the _ reactor experiment program to determine compliance with TS-3.1, 3.2(a through h), and 3.3.
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The inspectors reviewed 21 approved experiments and observed the-licensee-conduct one experiment involving reactor operations.
The inspectors-determined that each experiment procedure contained the revision, date, and approval signature.
The licensee had approved one new experiment
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since the last NRC-inspection. :The new experiment-was -properly reviewed and approved.
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No violations or deviations were identified, i
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Surveillances-(40750)_
The inspectors reviewed records and logs describing the conduct of reactor
_surveillances to determine.compilance with TS 4.0.
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The licensee's records. indicated that all required surveillenfes (preoperational, daily, semiannual, annual, and biennial) were completed for 1989, 1990,Jand 1991.
The following Techrical Specification required -
surveillances were reviewed:
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Completion
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Technical Specification Item Frecuency Date 4.1.a, Safety and Control Rod Annual 12/89
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Reactivity Worth-Determination 9/90 11/91 4.1.6, Excess Reactivity and Annual 12/89 Shutdown llargin Determination 9/90 11/91
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'4.2.a, Safety'and Control Rod Scram Annual 12/89
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Times'
9/90 11/91'
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-4,2.b, Control Rods and Drive Biennial 9/89 Inspection 9/90 11/91 4.2.h, Tank Water - Level. Interlock, -
Annual 10/89
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. Shield Water Temperature 11/90
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Interlock, and Seismic Displacement 12/91.
Safety Channel Calibrations 4.4.c,. Radiation Survey of Reactor Annual 1/89 Room and Reactor Control Room 2/90 9/91 No violations or deviations were identified.
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Radiological Controls' (40750and86740}
The: licensee's radiation protection program was reviewed to determine-
- compliance with the reouirements of 10 CFR Part 20, and TS 3.4, 4.2.1, and 4.4.
- The inspectors reviewed selected records and logs, interviewed personnel, made observations, and performed independent radiological surveys.
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Radiation exposure records for reactor personnel were reviewed.
It was l
noted that everyone who worked in the reactor f acility had been issued l
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I proper personnel dosimetry, The i ' ansee had acquired perssnnel dosimetry
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l-that Tus sensitive to beta, gamma, and low energy neutrons radiation. The
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L vendor that provided the dosimeters was determined to be accredited in j
j accordance with the requirements of 10 CFR Part 20.202(c).
The review of
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exposure records indicated that. reactor personnel had not exceeded 10 CFR l
i-Part 20_101 limits.
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The inspectors determined that the licensee had implemented a proper i
L radiation surveys program. The radiation surveys were thorough and
.l included neutron surveys. 'The inspectors performed independent radiation
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l surveys of the. reactor facility and the results were found to be comparable to the licensee's surveys.
It was noted that wiLh the reactor
operating at 5 watts, the. maximum dose rate identified near the reactor i;
was-approximately 500 millirem per hour.
Radiation surveys of irradiated
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i samples taken from the reactor ranged from 10 to 50 millirem per hour.
The inspectors reviewed the licensee's inventory _of portable radiation
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survey instruments.
The instruments were adequate and properly i
calibrated,
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i-The licensee had-not made any radiological effluent releases or any-
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shipments of radioactive material since the last inspection.
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No~. violations or deviations were identified.
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11.
Physical Security, Safeguards, and Material Control and Accounting
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_bi401,-81810,81431,and85102).
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i-The inspectors examined the licensee's implementation of the Physical t
b Security Plan, Revision 3, dated February 23, 1990, to deterrine j'
compliance with the requirements of Section 2.C(3) of -the Facility
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Operating. License, TS 5.2 av.d 5.3 and 10 CFR Part 50.54(p),
i l-In accoraance with 10 CFR Part 2.790(d), the material concerning the Physical Security Plar 's exempt from disclosure.
Therefore, this
-material-is-discussed i the Attachment to th.s Appendix and will not be.
placed in-the Public R cument Room.
No violations or deviations-were identified.
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_ 12., Emeroency Precaredness (40750)
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The licensee's mergency preparedness program for ISU was examined to
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determine compliance with TS 6.4.3 and 6.6 and Revision 4 to the NRC j.
approved ISU. Emergency Plan; and 10 CFR Parts 50.54(q) and (r),
r The inspectors reviewed the results of the biennial audit of the Emergency Plan. The_ inspectors noted that the licensee revised the Emergency Plan in May 1989 and properly reviewed and adopted the revision.
The licensee
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conducted a biennial. audit in April 1991 in conjunction with the Reactor
Safety Committee meeting. An apparent violation involving the failure to conduct emergency drills is discussed-below.
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a-11-The inspectors reviewed records of the annual Emergency Plan drills.
The insp2ctors were only able to located records for an April 1991 drill. The licensee stated that they remember conducting a drill in 1989 but not in 1990.- -Subsequent talks by the inspectors with campus security also indicated thero was a driil in 1989.
10-CFR Part 50.54(ql requires that a licensee authorized to possess and/or operate a research reactor shall follow and maintain in effect emergency plans.
Sectica 6 of the NRC approved. Emergency Plan (Revision 4) for che ISU nuclear f acility, dated May 2;.1989, requires that university personnel who would be involved in a nuclear incident will be tested by annual drills.
The inspector determined on December 12, 1991, that the licensee did'not conduct a drill of-the ISU Emergency Plan during 1990. The failure to conduct a drill of the' Emergency Plan annually was identified as a repeat apparent violatior. of 10 CFR Part 50.5M q) (284/9101-02).
The inspectors i_nterviewed persontil at Campus Security, the Pocatello Police Department, the Pocatello fire.Depzrtment, and Bannock Regional-Medical Center.
It was noted by the inspectors that the licensee had not established letters of agreement with the above organizations. -Even though the organizations were aware of their responsibilities in an emergency. The in:,pectors discussed the need to establish formal agreements with their support organizations. During the visits to the support agenries, the inspectors also found it-difficult to interf ace with the organizations due.to_the lack of the licensee having a designated
. liaison-person within these organizations. The licensee stated at the
. exit. meeting on December 12, 1991. that they would commit to establish a formal letter of' agreement-with emergency support organizations.
This is considered an inspection followup item pending the review of the letters
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of agreements-(284/9101-04).
The inspectors examined the training of emergency response personnel and
, maintenance of emergency response equipment. The training-of university personnel was adequate and the equipment was stored, and periodically inventoried.
The inspectors also noted that the licensee had installed a fire and smoke alarm in the reactor laboratory that was mo"itored by a security agency.
The inspectors reviewed the ISU Emergency P %n, Revision 4, dated May 2.
1989. The plan appeared-to address emergency response adequately.
The inspectors discussed the need for the licensee to review the entire Emergency Plan.
The plan references the responsibilities of the state of Idaho's Radiation Protection Department which has undergone major changes
-due:to the recent change of agreement status within NRC.
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A review of records indicated that the licensee had to respond to a L
criticality alarm in the subtritical laboratory on September 28, 1991.
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'The report indicated that it was a false alarm. The inspectors discussed L-the incident with personnel who responded to the event and it appeared that the situation was properly handled in accordance with the Emergency
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Plan.
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One-violation and no deviations were identified.
13. Committee Meetings and Minutes, Audits, and Reviews (40750)
The inspectors examined the licensee's audits and activities of the
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Reactor Safety Committee to determine compliance with the requirements of TS 6.4, 6.7(b), 6.8, and 6-10.2(i).
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The inspectors reviewed the Reactt' Safety Committee meeting minutes dated-May--2, 1989;-February 23, 1990s and April 11. 1991. The inspectors determined that the meetings wert held annually as required and that the
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business conducted at the meetings adequately satisfied TS.
The inspectors reviewed the required audits and determined that n
conformance of facility operation to TS and applicable license conditions had not been audited in 1991. License Condition 2.C.(2) of Amenoment No.
4 toLthe'ISU_ Amended Facility Operating _ License requires that the licensee shall operate the facility in accordance with the TS.
TS 6.4.3.a requires Ethat the_ licensee audit the conformance of f acility operation to the TS
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and applicable license conditions at least once per 12 months.
The inspectors determined on-December 12, 1991, that the conformance af f acility operation to the TS and applicable license conditions was not
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audited once per 12 months,1in that no audit had been performeo since the last audit in May 1990. -The failure to audit the conformance of facility 1-Joperation:to the-TS and applicable license conditions was-identified as an apparent-violation of TS 6.4.3.a-(284-9101-03).
The inspectors discussed with the licensee at the exit meeting on Decemoer 12, 1991, their concern that the finoings addresseo in this
= report indicate that facility-audits were not comprehensive enough to-verify-licensee compliance with applicable requirements. This concern'was
also addressed as an open. item in the last hRC inspection. The licensee
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stated that they would discuss this-matter at their next Reactor Safety
- Committee:in order to make improvements inEthis area-Ore-violation and no deviations were ioentifiec.
14. Records. Notifications, and Reports -(40750 and 81402)
The inspectors reviewed the M.ensee's submittal of' reports and notifications:to the NRC to-de;crmine compliance with TS 6.9.1.
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-The licensee had submitted.the-required annual reports of facility:
activities and operations for 1988, 1989, and 1990.
It was determined
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that-the annual reports met the facility license requirements.
No special
1 report; had been issued to the NRC since the previous inspection.
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No viola ions or deviations were identified.
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15. ]nspecterIndepender'_ Inspection _ Efforts _(40750)
During the inspection, tha inspectors observed a reactor startup, steady-state opt + ation, and shutdown, The inspectors also performed independent radiation sury:*ys and collected contamination smear samples for the purpose of comparing analvses results with the licensee.
The results of the reactor radiation surveys performed by the inspectors showed comparable results to those of the licensee.
The results of the smear surveys taker by the inspectors showed nu detectable alpha and beta gamma removable :adiological contaminatinu.
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Exjt Meeting- (307031 The inspectors met with the licensee's repres ntatives denoted in paragrapt e on December 12, 1991, and summarized the scope and findings of the inspection,as presented in this report.
The Physical Security Plan was identified as priprietary information.
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