IR 05000288/2015201

Reed College NRC Routine Inspection Report No. 50-288/2015-201

ML15342A493
Person / Time
Site:	Reed College
Issue date:	12/17/2015
From:	Anthony Mendiola Research and Test Reactors Branch B
To:	Krahenbuhl M Reed College
Bassett C
References
IR 2015201
Download: ML15342A493 (18)

Text

ber 17, 2015

SUBJECT:

REED COLLEGE - NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-288/2015-201

Dear Dr. Krahenbuhl:

From November 16-18, 2015, the U.S. Nuclear Regulatory Commission (NRC, the Commission)

conducted an inspection at the Reed Research Reactor facility. The enclosed report documents the inspection results which were discussed on November 18, 2015, with you and members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspector reviewed selected procedures and records, observed various activities, and interviewed 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. Craig Bassett at 301-466-4495 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-288 License No. R-112 Enclosure:

As stated cc: w/enclosure: See next page

Reed College Docket No. 50-288 cc:

Mayor of the City of Portland 1220 Southwest 5th Avenue Portland, OR 97204 Dr. Nigel Nicholson, Dean of Faculty Reed College 3203 SE Woodstock Boulevard Portland, OR 97202-8199 John Kroger, President Reed College 3203 SE Woodstock Boulevard Portland, OR 97202-8199 Division Administrator Nuclear Safety Division Oregon Department of Energy 625 Marion Street NE Salem, OR 97301-3737 Program Director Radiation Protection Services Public Health Division Oregon Health Authority 800 NE Oregon Street, Suite 640 Portland, OR 97232-2162 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML15342A493; *concurred via e-mail NRC-002 OFFICE NRR/DPR/PROB* NRR/DPR/PROB* NRR/DPR/PROB NAME CBassett NParker AMendiola DATE 12/09/2015 12/09/2015 12/17/2015

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-288 License No: R-112 Report No: 50-288/2015-201 Licensee: Reed College Facility: Reed Research Reactor Location: 3203 S.E. Woodstock Boulevard Portland, OR Dates: November 16-18, 2015 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY Reed College TRIGA Mark-I Research Reactor Report No. 50-288/2015-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the Reed College (the licensees) Class II 250 kilowatt research reactor safety program including: (1) organization and staffing, (2) review and audit and design change functions, (3) radiation protection, (4) effluent and environmental monitoring, (5) procedures, and (6) transportation of radioactive material since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety and was generally in compliance with NRC requirements.

Organizational Structure and Staffing

• Facility organization and staffing were in compliance with the requirements specified in Section 6.1 of the Technical Specifications (TSs).

Review and Audit and Design Change Functions

• Reviews and audits were being conducted by the Reactor Operations Committee in compliance with the requirements specified in the TSs.

• Proposed changes at the facility had been analyzed using Title 10 of the Code of Federal Regulations Section 50.59, safety evaluation process.

Radiation Protection Program

• Signs, notices, and postings met the regulatory requirements.

• Personnel dosimetry was being worn as required and doses were well within the licensees procedural action levels and NRCs regulatory limits.

• Surveys were completed and documented acceptably to permit evaluation of the radiation hazards present.

• Radiation survey and monitoring equipment was being maintained and calibrated acceptably.

• Radiation protection training was acceptable and was being conducted as required.

• The Radiation Protection and the As Low As Reasonably Achievable Programs satisfied regulatory requirements.

-2-Environmental Monitoring Program

• Effluent monitoring satisfied licensee procedural and regulatory requirements and releases were calculated to be within the specified regulatory limits.

Procedures

• Facility procedures were acceptably reviewed, approved, and implemented.

Transportation of Radioactive Materials

• The program for shipping radioactive material satisfied regulatory requirements.

REPORT DETAILS Summary of Plant Status Reed Colleges (the licensees) Class II 250 kilowatt TRIGA Mark-I research reactor continued to be operated in support of undergraduate instruction, laboratory experiments, reactor operator training, and various types of research. During the inspection, the reactor was operated as needed for laboratory experiments and training.

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

To verify organization and staffing requirements specified in Technical Specifications (TS) Section 6.1, dated September 28, 2015, were being met, the inspector reviewed selected aspects of:

• Current facility organization and staffing

• Management responsibilities as outlined in the applicable procedures

• Reed Research Reactor (RRR) Administrative Procedures

• RRR Annual Report for the period from July 1, 2013, through June 30, 2014, submitted on July 23, 2014

• RRR Annual Report for the period from July 1, 2014 through June 30, 2015, submitted August 7, 2015 b. Observations and Findings The organizational structure had not changed since the last Nuclear Regulatory Commission (NRC) inspection, which occurred in December 2014 (Inspection Report No. 50-288/2014-202). The current Reactor Director remained in that position. A new individual had been hired to fill the position of Reactor Operations Manager. The Radiation Safety Officer was still in that position and was also the campus Director of Environment Health and Safety.

The radiation protection duties at the facility were completed by various individuals, including the Reactor Operations Manager and students who were also Reed College part-time employees. These individuals conducted surveys, completed instrument calibrations, and handled and counted samples. These activities were reviewed and approved by the Facility Director and the Radiation Safety Officer.

The organizational structure and staffing at the facility were as required by the TS. Review of records verified that management and staff responsibilities were carried out as required by the TS and applicable procedures.

c. Conclusion The licensees organization and staffing were in compliance with the requirements specified in the TS.

-2-2. Design Change and Review and Audit Functions a. Inspection Scope (IP 69001)

In order to ensure that the audits and reviews required by TS Section 6.2, were being completed, and to verify that any modifications to the facility were consistent with Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.59, the inspector reviewed the following:

• Corrective action reports for 2014 and to date in 2015

• Recent changes reviewed using the licensees RRR 10 CFR 50.59 screen forms

• Minutes of the meetings held by the Reactor Operations Committee (ROC) from October 2013 to the present

• Safety review and audit records for 2012-2013 and 2013-2014 as documented on RRR standard audit forms

• RRR Administrative Procedures

• RRR Standard Operating Procedure (SOP) 60, Logbook Entries

• RRR SOP 62, Changes, Tests, and Experiments

• RRR SOP 66, Corrective Action Report

• RRR Annual Reports for the last two reporting periods b. Observations and Findings (1) Review and Audit Functions The inspector reviewed the ROC meeting minutes from October 2013 to the present. These meeting minutes showed that the committee met as required by the TS with a quorum being present. Records showed that the safety reviews and audits conducted by the committee or designated individuals were completed at the TS-required frequency. Topics of these reviews were also consistent with TS requirements and provided guidance, direction, and oversight of the reactor.

The inspector noted that the safety reviews and audits that had been completed, as well as the associated findings, were acceptably detailed and that the licensee responded and took corrective actions as needed.

The inspector also reviewed the corrective action log. Various recommendations had been discussed and reviewed and a solution to each had been determined and subsequently implemented as needed.

(2) Design Change Through review of the ROC meeting minutes, and through interviews with licensee personnel, the inspector determined that no major changes had been initiated and/or completed at the facility since the last NRC inspection. Various 10 CFR 50.59 screens were completed in 2014 and had been completed to date in 2015. The inspector noted that the

-3-licensee used both 10 CFR 50.59 screen forms and Maintenance Log forms to conduct 10 CFR 50.59 screenings. It was also noted that, as a result of the screens being conducted, no evaluations were required to be completed in 2014 and none were required as of the date of the inspection in 2015. Because the licensee determined that the changes were minor in nature, they had been reviewed and approved by the Facility Director, but were not required to be approved by the ROC.

c. Conclusion Review, audit, and oversight functions required by TS Section 6.2, were acceptably completed by the ROC. Proposed changes at the facility had been analyzed using the 10 CFR 50.59 review process as required.

3. Radiation Protection Program a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with 10 CFR Parts 19 and 20, and TS Sections 3.5 and 4.5:

• Contamination Reports

• Radiological signs and posting

• Radiation work permit notebook

• Personnel Contamination Forms

• ROC Audits for 2013-2014 and 2014-2015

• Personnel dosimetry records for 2013, 2014, and to date in 2015

• Daily reactor startup and shutdown checklists for the past 12 months

• Routine surveys and monitoring records for 2014 and 2015, including weekly checklists, biweekly checklists, bimonthly checklists, and semiannual checklists

• Records of maintenance and calibration of radiation survey and monitoring instruments

• Reed Reactor Facility Radiation Protection Plan

• As Low As Reasonably Achievable (ALARA) Program, as described in the Radioactive Materials Policy and Procedures Manual

• Various RRR SOPs dealing with radiation monitors and health physics

• RRR Administrative Procedures

• Radioactive Materials Handling Study Guide

• Reed College Radioactive Materials Policy and Procedures Manual

• Reed Research Reactor Radiation Protection Program Annual Review for reporting periods 2013 - 2014 and 2014 - 2015

• RRR Annual Reports for the last two reporting periods The inspector also observed the use of dosimetry and radiation monitoring equipment during tours of the facility.

-4-b. Observations and Findings (1) Postings and Notices Copies of current notices to workers were posted inside the reactor control room at RRR. Radiological signs were typically posted at the entrances to controlled areas as well. The posted copies of NRC Form 3, Notice to Employees, observed at the facility were the latest issue, as required by 10 CFR 19.11, and were posted in the main hallway, in the reactor bay, and in the laboratory room.

Caution signs, postings, and controls for radiation areas were as required in 10 CFR Part 20, Subpart J. The inspector verified that licensee personnel observed the precautions for access to radiation areas.

(2) Dosimetry The inspector determined that the licensee used optically stimulated luminescent (OSL) dosimeters for whole body monitoring of beta and gamma radiation exposure. The licensee also used thermoluminescent dosimeter (TLD) finger rings for monitoring beta and gamma radiation exposure of the extremities. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor. An examination of the OSL and TLD results indicating radiological exposures at the facility for the past three years showed that the highest occupational doses, as well as doses to the public, were well within 10 CFR Part 20 limitations.

Through direct observation the inspector determined that dosimetry was acceptably used by facility personnel and exit frisking practices were in accordance with facility radiation protection requirements.

(3) Surveys Selected daily, weekly, and biweekly radiation and/or contamination surveys were reviewed by the inspector. The surveys had been completed by staff members as required. Any contamination detected in concentrations above the established action levels was noted and the area or items were decontaminated. Results of the surveys were documented so that licensee personnel would be knowledgeable of the radiological conditions that existed in the various areas of the facility.

(4) Radiation Monitoring Equipment Examination of selected radiation monitoring equipment indicated that the instruments had an acceptable up-to-date calibration sticker attached.

The instrument calibration records indicated that the calibration of portable survey meters was typically completed by reactor staff personnel. Some meters were exchanged with another Research and

-5-Test Reactor (RTR) for calibration so that each RTR could verify that their respective calibration procedures were appropriate. Calibration frequency met procedural requirements and records were maintained as required. Fixed location radiation area monitors and stack monitors were also being calibrated as required. These monitors were also typically calibrated by reactor staff personnel.

The inspector compared selected calibration records with reactor operations logs and startup and shutdown checklists for the past 18 months. The daily startup checklists typically contained a listing of portable monitors that were available during reactor operations. The inspector determined that the instruments that were available and ready for use in the reactor bay had been calibrated as required.

During the inspection the inspector visited the facilitys calibration range and discussed the calibration of survey meters with licensee personnel. It was noted that proper precautions and controls were implemented during calibration operations to maintain doses ALARA. Through discussions and records review, the inspector concluded that the calibration of instruments at the facility were completed using the appropriate techniques and according to procedure.

(5) Radiation Protection and ALARA Programs The licensees radiation protection and ALARA programs were established and described in the Reed College Radioactive Materials Policy and Procedures Manual, dated November 2014, and through associated SOPs that had been reviewed and approved. The programs contained instructions concerning organization, training, monitoring, personnel responsibilities, audits, record keeping, and reports. The ALARA program provided guidance for keeping doses as low as reasonably achievable and was consistent with the requirements in 10 CFR Part 20. These programs, as established, appeared to be acceptable.

The inspector determined that the licensee continued to complete annual reviews of the radiation protection program as required by 10 CFR 20.1101(c).

The licensee did not require or use a respiratory protection program or planned special exposure program.

(6) Radiation Work Permits (RWPs)

The inspector reviewed the RWP program that had been established as stipulated in RRR SOP 53. It was noted that no RWPs had been issued in 2014 or as of the date of the inspection in 2015. The controls specified in previously issued RWPs were generally acceptable and applicable for

-6-the types of work being done. Those RWPs had been initiated, reviewed, and approved as indicated on the forms.

(7) Radiation Protection Training The inspector reviewed the radiation worker training given to RRR staff members and Reed faculty, to student operators and other students who worked at the facility, and to other personnel such as maintenance workers. Each group received different training that was based upon their duties and activities. Refresher training was conducted every three years. The training program appeared to be acceptable.

The licensee indicated that radiation worker training for reactor staff members was given upon initial entry into the RRR program and then reiterated during operator requalification training. Training records showed that personnel were acceptably trained in radiation protection practices.

(8) Facility Tours and Inspector Observations The inspector toured the control room, the reactor bay, the mechanical room, the laboratory room, and the counting room at the facility. Control of radioactive material was acceptable, as was control of access to radiation areas.

c. Conclusion The inspector determined that the Radiation Protection and ALARA Programs, as implemented by the licensee, satisfied regulatory requirements because:

(1) postings met regulatory requirements, (2) personnel dosimetry was being worn as required and recorded doses were well within the NRCs regulatory limits, (3) surveys and associated checks were completed and documented acceptably to permit evaluation of the radiation hazards present, (4) radiation survey and monitoring equipment was being maintained and calibrated as required, and (5) the radiation protection training program was acceptable.

4. Environmental Monitoring Program a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with the requirements of 10 CFR Part 20 and TS Sections 3.5 and 4.5:

• Airborne release calculation records

• RRR Administrative Procedures

• ROC Audits for 2013-2014 and 2014-2015

• Environmental counting and analysis records

• Routine surveys and monitoring records for 2014 and 2015

-7-

• RRR SOP 52, Environmental Sampling and various other RRR SOPs

• RRR Annual Reports for the last two reporting periods b. Observation and Findings Environmental soil and water samples were collected, prepared, and analyzed generally every two months consistent with procedural requirements. Only naturally occurring radionuclides were detected in the soil samples and no tritium or carbon-14 were detected in the water samples during 2014 and to date in 2015.

Radiation monitoring inside the reactor bay and outside the facility was completed using TLDs placed in accordance with the applicable procedures.

The results were reported in the Annual Report as required. No doses above regulatory limits were noted.

The licensee calculated the airborne activity released to the environment using data from the continuous air monitor sampling. Licensee records and calculations indicated that the air emissions of radioactive material to the environment were well below the 10 millirem constraint specified in 10 CFR 20.1101(d). The inspector found no new potential release paths following observation of the facility.

The program for the monitoring, storage, or transferring of radioactive liquid, gases, and solids was consistent with applicable regulatory requirements. The principles of ALARA were acceptably implemented to minimize radioactive releases. Records were current and acceptably maintained and indicated that no radioactive liquid had been released from the reactor facility during 2014 or as of the date of the inspection in 2015. Monitoring equipment was acceptably maintained and calibrated as noted previously.

c. Conclusion Effluent monitoring satisfied procedural and regulatory requirements and releases were calculated to be within the specified regulatory and TS limits.

5. Procedures a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Section 6.4:

• Selected facility procedures

• Procedural implementation and compliance

• Recent minor and substantive procedural changes

• ROC and radiation safety committee meeting minutes for October 2013 through the present

-8-

• Administrative controls specified in RRR Administrative Procedures

• RRR SOP 61, Procedure Writing and Use b. Observations and Findings The inspector noted that facility procedures were no longer being reviewed biennially by the ROC; that requirement had been removed from the updated TS.

The Facility Director indicated that all procedures were typically reviewed annually by the Director and the Reactor Operations Manager. Administrative control of changes to procedures, and the associated review and approval process, were as stipulated by RRR SOP 61. Substantive changes to procedures were required to be reviewed and approved by the ROC. The inspector verified that this process was being followed.

Training of personnel on procedures and changes was acceptable. Through discussions with licensee personnel, the inspector verified that reactor operations were conducted in accordance with applicable procedures. Radiation and contamination surveys were completed as required. Observation and records review also showed that procedures for instrument calibration, reactor operation, maintenance, and emergency conditions were available as required.

c. Conclusion Facility procedures were acceptably reviewed, approved, and implemented.

6. Transportation a. Inspection Scope (IP 86740)

To verify compliance with 10 CFR 71.5 and procedural requirements for the transfer or shipment of licensed radioactive material, the inspector reviewed the following:

• Records of radioactive material shipments completed for 2014 and to date in 2015, including completed NRC Form 540, Uniform Low Level Radioactive Waste Manifest, Rev. 08-06, completed July 14, 2014

• RRR Administrative Procedures

• RRR SOP 54, Waste Handling and Disposal

• RRR SOP 84, Shipping Radioactive Material

• RRR Annual Reports for the last two reporting periods

• State of Washington, Department of Health, Site Use Permit for the Commercial Low-Level Radioactive Waste Disposal Site, Permit Number G2124, with an expiration date of February 29, 2016 b. Observations and Findings Through records reviews and discussions with licensee personnel, the inspector determined that the licensee had completed one shipment of licensed material

-9-since the last inspection of transportation in December 2013. The shipment consisted of two drums of solid radioactive waste. The necessary forms containing the appropriate information were completed as required. Appropriate procedures were in place for shipping various types of radioactive material.

The inspector noted that the licensee individual who was designated as a shipper had completed the appropriate training to become qualified to ship radioactive material.

c. Conclusion The program for shipping radioactive material satisfied regulatory requirements.

7. Follow-Up on Technical Specification Violation a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following related to a violation (VIO 50-288/2013-201-01). Failure to have a licensed operator in the Control Room when the key had not been removed from the console was a violation of the requirements of 10 CFR 50.54(k) and TS Section 6.1.3:

• RRR SOP 1, Reactor Operation

• Installation of the TRAKA Log Box

• Signage on the Reactor Console in the Control Room b. Observations and Findings 10 CFR 50.54(k) requires that an operator or senior operator licensed pursuant to 10 CFR Part 55 shall be present at the controls at all times during the operation of the facility.

TS Section 6.1.3, requires, in part, that the minimum staffing when the reactor is operating shall be a licensed reactor operator in the control room.

TS Section 1 defines the reactor as operating whenever it is not shut down or secured.

At approximately 11:00 a.m. (PST), on November 16, 2013, a reactor operator and a senior reactor operator, along with one other individual, were operating the reactor to complete a core excess determination. After the completion of a standard core excess, all rods were driven in to shut down the reactor.

Subsequently, the control room was locked and the three individuals left.

However, the reactor key was inadvertently left in the console and no key out and secured log entry was made in the console logbook. At approximately 12:11 p.m., on the same day, the Operations Supervisor entered the control room and noted that the key was in the console, contrary to 10 CFR 50.54(k) and TS Section 6.1.3.

- 10 -

The licensee investigated the event. It was determined that the key had apparently been left in the console due to an oversight by the operators (they were distracted by cleaning activities in the control room), and that this condition had existed for approximately 71 minutes before being discovered. The control room was locked the entire time and no one accessed that area until the Operations Supervisor arrived. The Director and Reactor Operations Manager also evaluated the problem to determine whether or not it was reportable and determined that it was a violation of the TS, as well as a violation of 10 CFR 50.54(k). In accordance with TS Section 6.7.2(a), at 4:25 p.m. (EST) on November 18, 2013, the licensee notified to the NRC Headquarters Operations Center.

The licensee took a number of corrective actions in response to the violation. A sign was immediately placed in the control room to remind people to take the key out following a reactor shut down and prior to leaving the control room. The operators who left the key in the console were given additional training by the Facility Director before being allowed to operate the reactor again. During the week of the inspection, the licensee was still considering whether additional administrative or engineering controls could be developed to prevent recurrence of the problem. Following the NRC inspection and review of the event, the licensee was issued a violation.

During this inspection the inspector again reviewed the event and the corrective actions. The licensees SOP 1 was revised to clarify that the operator of record must not get distracted from their assigned duties including operating the reactor and controlling/removing the console key following operation. Operator training and requalification training is also used to emphasize the responsibilities of the operator of record. It was noted that the licensee had placed permanent signage on the Reactor Console to remind the operator of record that the key must be removed before the operator can leave the Control Room. The inspector verified that a TRAKA Log Box had been installed. The Log Box was the location where the reactor console key is stored when not in use. It is installed next to the exit door of the Control Room as a reminder for operators to insert the console key, or any other key that was signed out, back into the Log Box prior to leaving.

These corrective actions appeared to be appropriate and this issue is considered closed.

c. Conclusions One previous violation for not having an operator in the control room while the reactor was not secured as required was reviewed and is considered closed.

8. Exit Interview The inspection scope and results were summarized on November 18, 2015, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. No proprietary material was reviewed by the inspector during the inspection.

PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel C. Barrett Reactor Operations Manager K. Fisher Radiation Safety Officer and Campus Environmental Health and Safety Director Director, Reed Reactor Facility N. Nicholson Dean of the Faculty, Reed College INSPECTION PROCEDURES USED IP 69001: Class II Non-Power Reactors IP 86740: Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 50-288/2013-201-01 VIO Failure to have a licensed operator in the Control Room when the key had not been removed from the console was a violation of the requirements of 10 CFR 50.54(k) and TS Section 6.1.3.

LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable IP Inspection Procedure NRC U.S. Nuclear Regulatory Commission OSL Optically-Stimulated Luminescent (dosimeter)

ROC Reactor Operations Committee RRR Reed Research Reactor RTR Research and Test Reactor RWP Radiation Work Permit SOP Standard Operating Procedure TLD Thermoluminescent Dosimeter TS Technical Specification