IR 05000288/2020201
| ML20237F406 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 09/02/2020 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Frantz S Reed College |
| Roche K, NRR/DANU/UNPO, 301-415-1554 | |
| References | |
| IR 2020201 | |
| Download: ML20237F406 (21) | |
Text
September 2, 2020
SUBJECT:
REED COLLEGE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE AND CONFIRMATORY ORDER FOLLOW-UP INSPECTION REPORT NO. 05000288/2020201 AND NOTICE OF VIOLATION
Dear Mr. Frantz:
From July 20-24, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Reed Research Reactor facility. The enclosed report presents the results of that inspection, which were discussed on July 24, 2020, 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 inspectors reviewed selected procedures and records, observed various activities, and interviewed personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC regulatory requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding the violation is described in detail in the subject inspection report. The violation is being cited in the Notice because it constitutes a failure to meet regulatory requirements that has more than minor safety significance and the licensee failed to identify the violation.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
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). To the extent possible, your response should not include any personal privacy or proprietary information, so that it can be made available to the public without redaction. If you have any questions concerning this inspection, please contact Kevin Roche at (301) 415-1554, or by electronic mail at Kevin.Roche@nrc.gov.
Sincerely,
/RA/
Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-288 License No. R-112 Enclosures:
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. Kathryn C. Olsen, Dean of Faculty Reed College 3203 SE Woodstock Boulevard Portland, OR 97202-8199 Dr. Audrey Bilger, President Reed College 3203 SE Woodstock Boulevard Portland, OR 97202-8199 Ken Niles, Assistant Director for Nuclear Safety Oregon Department of Energy 550 Capitol Street N.E., 1st Floor Salem, OR 97301 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 Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115
ML20237F406 *concurred via e-mail NRC-002 OFFICE NRR/DANU/UNPO* NRR/DANU/UNPO/LA* NRR/DANU/UNPO/BC*
NAME KRoche NParker TTate DATE 8/25/2020 8/25/2020 9/2/2020
NOTICE OF VIOLATION Reed College Docket No. 50-288 Reed Research Reactor License No. R-112 During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted July 20-24, 2020, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is described below:
Reed Research Reactor technical specifications (TS) Section 3.4, Ventilation System, requires that the reactor not be operated unless the ventilation system is operable in the normal or isolation mode. On May 25, 2018, ventilation system isolation damper V-11 failed to close during ventilation surveillance system testing due to a failed actuator.
Since V-11 failed to close during surveillance testing, the ventilation system was not operable. The V-11 actuator was replaced and retested successfully on July 26, 2018.
However, the reactor was operated regularly from May 25, 2018, through July 26, 2018.
Therefore, contrary to TS 3.4, from May 25, 2018, through July 26, 2018, the Reed Research Reactor was operated without the ventilation system being operable.
The inspectors determined this violation was a Severity Level IV violation (Section 6.1).
Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.201, Notice of violation, Reed Research Reactor facility is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation, and should include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the Enclosure 1
portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.
In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post this Notice within two working days of receipt.
Dated this 2nd day of September, 2020
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-288 License No.: R-112 Report No.: 05000288/2020201 Licensee: Reed College Facility: Reed Research Reactor Location: Portland, OR Dates: July 20-24, 2020 Inspectors: Kevin Roche Phil OBryan Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure 2
EXECUTIVE SUMMARY Reed College Reed Research Reactor Inspection Report No. 05000288/2020201 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) procedures, (3) health physics, (4) design changes, (5) committees, audits and reviews, (6) transportation activities (7) and confirmatory order follow-up, since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The NRC staff determined that the licensees program was acceptably directed toward the protection of public health and safety and was in compliance with NRC requirements.
Organization and Staffing
- Facility organization and staffing followed the requirements specified in Section 6.1 of the technical specifications (TS).
Procedures
- Facility procedures were acceptably reviewed, approved, and implemented.
Health Physics
- Surveys were accurately completed and documented to permit evaluation of the radiation hazards present.
- Postings met the regulatory requirements specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 19, Notices, Instructions and Reports To Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation.
- Personnel dosimetry was worn as required and doses were within the licensees procedural action levels and NRCs regulatory limits.
- Radiation monitoring equipment was maintained and calibrated as required.
- Radiation protection training was provided to staff personnel as specified by the radiation protection program.
- The radiation protection program was implemented by the licensee and satisfied regulatory requirements.
- Effluent monitoring satisfied licensee and regulatory requirements.
- Releases were within the specified regulatory and TS limits and documented in the annual report as required.
Design Changes
- The latest changes completed by the licensee were reviewed using the criteria specified in 10 CFR 50.59, Changes, tests and experiments, determined to be acceptable, and reviewed and approved by the Reactor Safety Committee (RSC). The licensee incorrectly implemented the design change process in one instance. See the report details below for additional information.
Committees, Audits and Reviews
- The review and audit program was conducted by the RSC as required.
- The RSC composition and meeting frequency satisfied requirements specified in the TSs.
Transportation Activities
- The program for shipping radioactive material satisfied regulatory requirements.
Confirmatory Order Follow-up
- Ensure Reed College implemented the corrective actions agreed to in NRC Order EA-19-071, Confirmatory Order Modifying License.
REPORT DETAILS Summary of Facility Status The licensees Class II 250-kilowatt Training, Research, Isotopes, General Atomics Mark-I research reactor is operated in support of undergraduate instruction, laboratory experiments, reactor operator (RO) training, and various types of research. During the inspection, the reactor was not operated.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001)
The inspectors verified organization and staffing requirements specified in the licensees TS Section 6.1 were met. The inspectors reviewed following:
- current facility organization and staffing
- management responsibilities as outlined in the applicable procedures
- selected Reed Research Reactor (RRR) Procedures including standard operating procedure (SOP) 1, Reactor Operation
- RRR reactor logbooks (2018 to the present)
b. Observations and Findings The inspectors found the licensees functional organization changed since the last NRC inspection in this area. Mr. Stephen Frantz was named the Interim Reactor Director and the licensee was in the process of finding a permanent Reactor Director. The minimum staffing required when the reactor is not secured is specified in TS Section 6.1. The inspectors reviewed the console records for the period covering January 2018 to the present and determined that staffing requirements were met.
c. Conclusion The inspectors concluded the licensees organization and staffing met the requirements specified in the TS.
2. Procedures a. Inspection Scope (IP 69001)
The inspectors reviewed the following to verify compliance with TS Section 6.4:
- selected RRR facility procedures
- procedural implementation and compliance
- recent minor and substantive procedural changes
- administrative controls specified in RRR Procedures including SOP 61, Procedure Writing and Use
b. Observations and Findings The inspectors verified administrative control of changes to procedures, and the associated review and approval process, were stipulated by RRR SOP 61.
Substantive changes to procedures were required to be reviewed and approved by the ROC. The inspectors verified that this process was followed and that training of personnel on procedures and changes was appropriately completed.
c. Conclusion The inspectors determined that facility procedures were reviewed, approved, and implemented in accordance with RRR SOP 61.
3. Health Physics a. Inspection Scope (IP 69001)
The inspectors verified compliance with 10 CFR Parts 19 and 20, and TS Sections 3.5 and 4.5 and reviewed the following:
- radiological signs and posting
- contamination reports and personnel contamination forms
- personnel dosimetry records for 2018, 2019, and 2020 to date
- daily reactor startup and shutdown checklists for 2019 and 2020 to date
- external audits of the radiation safety program conducted for the ROC and RSC for the academic years 2017-2018, and 2019-2020
- selected routine surveys and monitoring records for 2018, 2019, and 2020 to date including biweekly, bimonthly, and semiannual checklists records of maintenance and calibration of radiation survey and monitoring instruments
- the as low as reasonably achievable (ALARA) program, as described in the Radioactive Materials Policy and Procedures Manual
- various RRR SOPs dealing with radiation monitors, health physics, and radiation work permits
- Reed College Radioactive Materials Policy and Procedures Manual, dated June 2016
- RRR annual reports for the last two reporting periods
- airborne release calculation records
- environmental counting and analysis records
- various RRR SOPs dealing with environmental sampling and radioactive waste handling and disposal
- ROC minutes for 2018 through April 2020
- selected routine surveys and monitoring records for 2018, 2019, and 2020 to date b. Observations and Findings The inspectors toured the facility and observed maintenance activities. The inspectors also observed the use of dosimetry and radiation monitoring equipment. The inspectors found practices regarding the use of dosimetry, radiation monitoring equipment, placement of radiological signs and postings,
use of protective clothing, and the handling and storing of radioactive material or contaminated equipment was in accordance with regulations and the licensees written radiation protection program. The inspectors also verified that the licensee performed and documented annual self-assessments of the program as a tool for assuring that radiation exposure was maintained ALARA.
The inspectors reviewed records of radiation surveys and performed additional surveys during the inspection of the nuclear reactor facility and found them within the limits specified by the facility postings. The inspectors did not observe any unmarked radioactive material in the facility. The licensee posted a copy of the current NRC Form 3, Notice to Employees, required by 10 CFR Part 19 at the entrance to the control room and reactor bay. The inspectors reviewed dosimetry results and determined that doses to facility occupants was minimal and below regulatory limits. The inspectors found that radiation monitoring devices were calibrated within the frequencies specified in procedures.
The inspectors noted from records that training was provided for radiation workers assigned to the facility and individuals were not issued dosimetry or given access until the training was successfully completed. The annual reports referenced above described the gaseous, liquid, and solid waste generated at the facility, with gaseous Argon-41 produced by the irradiation of atmospheric air was the most significant isotope noted. The licensee also reported the results of air sampling and thermoluminescent dosimeters placed at locations around the facility as environmental radiation monitors. Surface water and vegetation were analyzed by the licensee for indications of environmental impacts and the inspectors verified they showed no significant difference from background levels.
c. Conclusion The inspectors determined that the radiation protection program implemented by the licensee satisfied regulatory requirements.
4. Design Changes a. Inspection Scope (IP 69001)
The inspectors reviewed the following to verify compliance with 10 CFR 50.59, regarding design change control:
- recent changes initiated by the licensee using the licensees RRR 10 CFR 50.59 screen forms
- various RRR procedures including SOP 60, Logbook Entries, SOP 62, Changes, Tests, and Experiments, and SOP 66, Corrective Action Report
- RRR annual reports for the last two reporting periods
- RRR biweekly checklists
- RRR maintenance log b. Observations and Findings
(1) Observations The licensee completed several 10 CFR 50.59 screens since the last inspection.
10 CFR 50.59 screen forms were used to determine whether a full evaluation of a change was needed. The inspectors noted that no evaluations were required to be completed. However, the inspectors noted that one screening was completed incorrectly and should have resulted in a full 10 CFR 50.59 evaluation (see finding details below).
(2) Reactor Operation Without Ventilation System Operable During a review of licensee design change and maintenance documents, inspectors identified that on May 25, 2018, the normal supply fan inlet isolation damper (V-11) failed to shut automatically when a ventilation isolation signal was generated from the control room during surveillance testing. The licensee determined that the V-11 actuator failed and initiated a work order to replace the actuator. The actuator was replaced and retested successfully on July 26, 2018.
However, the licensee considered the ventilation system to be operable during this timeframe and continued to operate the reactor.
RRR TS defines operable to mean that a system or component is capable of performing its intended function. As stated in RRR TS Section 5.4, one of the ventilation system TS design functions is to be equipped with isolation dampers capable of ventilation system isolation when actuated from the control room.
Therefore, since V-11 is a designated ventilation system isolation damper and it was incapable of shutting from the control room, the ventilation system was inoperable from May 25, 2018, through July 26, 2018.
The licensee completed a 10 CFR 50.59 screening (screen number 18-1) for this ventilation system configuration and concluded that all system functions were essentially the same as when V-11 was fully functional. The inspectors concluded that this screen should have recognized that the degradation to the ventilation system rendered it incapable of providing isolation and a full 10 CFR 50.59 evaluation should have been performed. Further, 10 CFR 50.59(c)(1)(i) states that a licensee may not implement a change to its facility without NRC approval if that change requires a change to the TS incorporated in the facility license. TS Section 3.4, Ventilation System, requires that the reactor not be operated unless the ventilation system is operable in the normal or isolation mode. Therefore, the inspectors determined that the operation of the RRR reactor without the ability to isolate the ventilation system from the control room would have required a change to RRR TS. Additionally, contrary to RRR procedures, the inspectors found that the 10 CFR 50.59 screen 18-1 was only signed by one person (the former RRR director) on November 7, 2018, several months after the condition existed.
c. Conclusion Except the condition described above, the inspectors verified that the proposed changes at the facility were analyzed using the 10 CFR 50.59 review process as required.
5. Committees, Audits and Reviews a. Inspection Scope (IP 69001)
In order to verify that the licensee had an oversight committee that conducted reviews and audits as required in TS Section 6.4, the inspectors reviewed the following:
- safety review and audit records for academic years 2017-2018, and 2019-2020
- various RRR procedures including SOP 60, Logbook Entries, SOP 62, Changes, Tests, and Experiments, and SOP 66, Corrective Action Report
- RRR annual reports for the last two reporting periods b. Observations and Findings The inspectors reviewed the ROC and the RSC meeting minutes from 2018 to the present. The inspectors confirmed that the ROC met as required by the TS and a quorum was present. The inspectors confirmed that the safety reviews and audits conducted by the committee or designated individuals were completed at the TS-required frequency and topics of these reviews were also consistent with TS requirements and provided guidance, direction, and oversight of the reactor.
c. Conclusion The inspectors concluded that the ROC and RSC provided the oversight required by the TS.
6. Transportation Activities a. Inspection Scope (IP 86740)
The inspectors reviewed the following records to verify compliance with 10 CFR 71.5, Transportation of licensed material, and procedural requirements for the transfer or shipment of licensed radioactive material:
- records of radioactive material shipments completed for 2018 and to date in 2020
- various RRR procedures including SOP 54, Waste Handling and Disposal, and SOP 84, Shipping Radioactive Material
- RRR annual reports for the last two reporting periods b. Observations and Findings The inspectors found that the licensee appropriately documented shipments of radioactive material made from 2018 to 2020.
c. Conclusion The inspectors determined that the program for shipping radioactive material satisfied regulatory requirements.
7. Confirmatory Order Follow-up a. Inspection Scope (IP 92703)
The inspectors conducted various interviews and reviewed meeting minutes, e-mail responses, and procedures to verify compliance with NRC Order EA-19-071. The Order requirements the licensee and NRC agreed to are specified in Section V of the Order.
b. Observations and Findings 1)Section V.A - Results of physicals be sent to psychologist who interprets Minnesota Multiphasic Personality Inventory (MMPI) test results and/or interviews applicants for mental fitness.
The inspectors reviewed Reed SOP 68, Reactor Employment Progression, dated May 8, 2020. Section 68.6.2.6 specifies that a trainee must complete several items to become a RO including the current version of the MMPI. Section 68.6.2.10 directs that the results of the MMPI test be sent to a forensic psychologist to determine if the trainee has a disqualifying condition.
2)Section V.B(i) - Amend SOP 64, "Work Environment," to ensure that the NRC-approved reviewing official is notified when any such person takes a leave of absence (LOA).
Section V.B(ii) - Amend SOP 64 to automatically suspend the facility and controlled area (CA) access of any such person who is on a LOA.
Section V.B(iii) - Amend SOP 64 to provide e-mail notice to other RRR personnel with unescorted access or licensed operators identifying any such person who is on a LOA and specifying their change in status.
Section V.B(iv) - Amend SOP 64 to require any such person returning from a LOA to pass both a new physical and a new psychological examination before their facility and CA access status is renewed. If absent for more than one year under favorable conditions, Federal Bureau of Investigation (FBI) fingerprint and background checks will be conducted. If LOA is for unfavorable conditions, FBI fingerprinting and background checks will be conducted regardless of length of LOA.
Reasons for removal from unescorted access status must be documented and retained for three years after such persons status change.
Section V.B(v) - Reed will make additional changes to SOP 64 to change the terminology so that it is the NRC-approved reviewing official who will be empowered to impose an administrative hold on operator access to
the facility for various reasons, including changes in medical prescriptions.
The inspectors reviewed SOP 64 dated May 8, 2020. The inspectors confirmed that the licensee added the required instructions to Section 64.12 as specified in Order EA-19-071 Section V.B. The inspectors noted that SOP directs that all students who go on a LOA will be required to be reinvestigated regardless of termination circumstances, which is more conservative than the Order requirements.
3)Section V.C - Amend SOP 65, Security and Visitors, to include provisions similar to those in SOP 64 terminating the facility access of persons with unescorted access and licensed operators who have taken an administrative leave and giving the NRC-approved reviewing official discretion to impose an administrative hold on unescorted access to the facility.
The inspectors reviewed SOP 65 revised June 8, 2020 and found that the licensee revised the procedure to include provisions like SOP 64 as described in the Order requirement V.C above.
4)Section V.D - Amend SOP 65 to provide that the Controlled Access List (CAL) and Facility Access List (FAL) shall be reviewed for accuracy, updated as necessary, and re-posted in a hardcopy format that is signed and dated by the NRC-approved reviewing official at least once every thirty (30) days. In addition, Reed will amend Section 65.7.1 (General Security Guidance) of SOP 65 to specifically require that personnel will not be issued keys to the CA or Facility unless they are currently on the CAL or FAL, and to require that keys be properly logged in and out no matter how short the duration for which the key is used. SOP 65 will be modified to require a new physical and psychological evaluation for operators returning from a LOA, consistent with SOP 64 and Section V.B of the Order.
The inspectors reviewed SOP 65 revised June 8, 2020. The inspectors verified that SOP 65 directs the NRC approved reviewing official to review, update and re-post a signed and dated copy of the FAL and CAL.
During a facility tour, the inspectors confirmed the posted lists were signed and dated within the last 30 days in accordance with the updated procedure. The inspectors found that SOP 65 was revised to provide the specific guidance outlined in the Order requirement V.D related to the use of security keys. Additionally, the inspectors determined the licensee revised SOP 65 consistent with SOP 64 and Section V.B of the Order as described above. The inspectors noted that no students had returned from a LOA since the procedures were revised.
5) The President of Reed will engage in the following:
Section V.E.1.a - Review all outside audits and NRC inspections and meet with the Dean of Faculty, the Vice President and Treasurer, and the
(facility) Director to identify and ensure implementation of appropriate corrective actions.
Section V.E.1.b - Meet on a quarterly basis with the Dean of the Faculty to ensure compliance with any outstanding corrective actions and to identify, discuss, and take appropriate measures to address any existing operational, security, or regulatory concerns regarding the RRR Program.
The inspectors reviewed the 2020 version of Administrative Procedures which outlines the requirements and responsibilities for the President, Dean of Faculty and the facility Director. The inspectors found that Section 1.1.1 was updated to include the above direction. The inspectors reviewed quarterly meeting minutes with the president, and the with the Dean of Faculty from May 28, 2020. During the meeting, the attendees reviewed facility status and the Order corrective actions.
6) The Dean of Faculty shall:
Section V.E.2.a - Receive copies of and review all correspondence between the Director and the NRC.
Section V.E.2.b - Review all outside audits and NRC inspections of the reactor program.
Section V.E.2.c - Ensure the receipt and transmission to the Director of responses for the required quarterly inquiries regarding the fitness for duty of each student allowed unescorted access to the facility that are made to supervisory health and counseling center personnel, Director of Community Safety, or appropriate faculty members; document the responses to these e-mails from each department that receives such required inquiries; and document actions taken as a result of these responses.
Section V.E.2.d - Meet on a monthly basis with the Director to ensure compliance with any outstanding corrective actions and to identify, discuss, and take appropriate measures to address any existing operational, security, or regulatory concerns regarding the RRR Program.
The inspectors reviewed the April 2020 CAL & FAL list summary of potential operator concerns from the respective faculty advisors. The list is coordinated by the Dean of Facultys administrative assistant and provides faculty last name, student full name and annotates any concerns and date of e-mail response. Community Safety, and the Health Care Center also responded via e-mail and did not have any concerns. The inspectors also noted that the Reed Security Plan was updated to reflect requirements related to the CAL and FAL. The inspectors reviewed monthly meeting minutes that from April 3, 2020, and June 25, 2020, meetings with the Dean of Faculty and the facility Director which outlined several topics discussed. As discussed above, the May 28, 2020, meeting was with the Dean of the Faculty, the President, the Treasurer and the Reactor Director. The inspectors interviewed the Dean of Faculty
and found that the Dean was aware of the status of the corrective actions, including the completion letter and the facility status in general.
7)Section V.F.1 - Director will meet with each licensed operator who is on campus for the current semester regarding the facts and lessons learned from the events that gave rise to the Order.
The inspectors reviewed a PowerPoint presentation that the Director used to discuss the events that lead to the Order. The presentation contained a brief description of the events leading up to the issues, described the violations in detail, discussed corrective actions, and outlined lessons learned going forward. The inspectors reviewed a checklist of the operators and denoting which operators and trainees the Director had discussed the presentation. Because of the ongoing pandemic, these discussions were done remotely since most operators were not on campus since mid-March.
8)Section V.F.2 - Reed will incorporate training (read and sign training) on reporting physical or mental health conditions, and any changes in conditions or treatment, into RO applicant training and requalification training.
The inspectors confirmed that form 63C, Annual Read and Sign, dated June 8, 2020, describes the importance of procedural adherence, reporting physical and mental health conditions, and any changes to the NRC. The inspectors verified that Section 63.12 of SOP 63,
"Requalification," dated May 8, 2020, outlines the annual "read and sign,"
requirement about reporting mental and physical health concerns. Lastly, SOP 68 dated May 8, 2020, Section 68.6.2.11 outlines read and sign requirement. The inspectors reviewed various operator records and found that they all included a recently signed copy of form 63C.
9)Section V.F.3 - Reed will conduct training for all professional staff in the health and counseling center (HCC) on the physical and mental health condition requirements and the reporting obligations for ROs.
The previous Director conducted training with the HCC staff in March of 2020. The training was documented with a sign in, sheet. During the training, the Director and HCC management reviewed, Reactor Protocol of HCC Providers/Staff, which provides discussion of American National Standards Institute/American Nuclear Society-15.4-1999 and talks about licensed operator conditions. The presentation was followed by a question and answer session. The inspectors also interviewed the HCC management. During the interview, HCC management described the on-boarding, process for new employees, and that it will include training on the Reactor Protocol. They also stated that refresher training will be given to the HCC staff at the start of the school year, possibly at the start of each semester.
10)Section V.F.4 - Reed will submit a presentation for consideration to be included in the annual National Organization of Test, Research, and Training Reactors (TRTR) conference to be held in 2020 Section V.F.5 - By June 1, 2020, Reed will submit an article to be considered for inclusion in the TRTR newsletter.
The inspectors were copied on the e-mail from the Interim Director to the Director, Division of Advanced Reactors and Non-power Production and Utilization Facilities, submitting both the article and presentation to the NRC staff for review, and the subsequent NRC response confirming receipt and providing comments. The inspectors reviewed an e-mail dated May 20, 2020, from the Interim Director to the TRTR submitting the presentation and abstract to TRTR for consideration at the next annual meeting. The Interim Director e-mailed the article on May 13, 2020, for TRTR newsletter consideration. Both e-mail copies included confirmation from the TRTR acknowledging receipt of both the presentation and the article.
11) SOP 68 shall include:
Section V.G.1 - The formation of a review committee of appropriate personnel, including the Director, Reactor Operations Manager, Radiation Safety Officer, and one non-Reed member of the ROC, to review and evaluate documents submitted to the NRC to ensure that each RO license application (whether for initial qualification or requalification of a RO or senior reactor operator license) is complete and fully supported by the required documentation.
Section V.G.2 - The preservation of documents supporting each RO license application.
Section V.G.3 - The succinct and accurate documentation of the reasons underlying any determinations to limit facility or CA access of staff or licensed operators in connection with a LOA or administrative hold and whether and why the NRC was or was not notified of the determination.
Section V.G.4 - Read and sign training materials on reporting physical or mental health conditions, and any changes in conditions or treatment, as noted in Section V.F of this Order.
The inspectors reviewed SOP 68, dated May 8, 2020, and confirmed that Section 68.8 describes the License Application Review Committee, specifies members, responsibilities and references Appendix B form for review committee signature. This section also specifies that documentation must be maintained. Section 68.4.4 contains a precaution to maintain documentation of reason for limiting/terminating facility access. Section 68.6.2.11 describes the training that everyone should receive related to reporting physical and mental reporting. The inspectors reviewed various operator records and found that the documents were
reviewed and signed by the review committee in accordance with SOP 68.
12)Section V.H - Reed will also expand its existing external audit procedures so that, starting in the audit year 2020, each such audit will include a review of all RO medical and psychological records and the reporting of those records to the NRC.
Dr. Cameron Goodwin (Director Rhode Island Nuclear Science Center)
conducted the 2020 Audit on March 3, 2020. She reviewed NRC Form 396 and 398 from last five years and found one minor error, but the student has since graduated, and their license was terminated.
c. Conclusion The inspectors concluded the licensee met the requirements of Order EA-19-071. However, as the staff noted on multiple occasions, various Order requirements are part of the RRR license, and the licensee must continue to comply with these requirements in the future. The inspectors noted that the licensee was in the process of modifying procedures to ensure that the Order requirements are annotated in some manner so future RRR personnel do not modify those procedural requirements specified in the Order.
Exit Interview The inspection scope and results were summarized on July 24, 2020, with members of licensee management. The inspectors described the areas inspected and discussed in detail the inspection findings. No proprietary material was reviewed by the inspectors during the inspection.
PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel C. Baldwin-Sayre Associate Dean of Students for Health T. Ellis Reactor Operations Manager Interim Director, Reed Research Reactor Facility N. Nicholson Former Dean of Faculty, Reed College K. Oleson Dean of the Faculty, Reed College T. Rochon Medical Services Director S. Vendor Senior Reactor Operator INSPECTION PROCEDURES USED IP 69001: Class II Non-Power Reactors IP 86740: Inspection of Transportation Activities IP 92701: Issue Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-288/2020-201-01 VIO Reactor Operation Without Ventilation System Operable Closed None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low as Reasonably Achievable CA Controlled Area CAL Controlled Access List FAL Facility Access List FBI Federal Bureau of Investigation HCC Health and Counseling Center IP Inspection Procedure LOA Leave of Absence MMPI Minnesota Multiphasic Personality Inventory NRC U.S. Nuclear Regulatory Commission RO Reactor Operator ROC Reactor Operations Committee RRR Reed Research Reactor RSC Radiation Safety Committee RSO Radiation Safety Officer TRTR Test, Research, and Training Reactors SOP Standard Operating Procedure TSs Technical Specification Attachment