IR 05000297/2018201
| ML18234A482 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 08/31/2018 |
| From: | Anthony Mendiola Research and Test Reactors Oversight Projects Branch |
| To: | Hawari A North Carolina State University |
| Eads J | |
| References | |
| IR 2018201 | |
| Download: ML18234A482 (18) | |
Text
ust 31, 2018
SUBJECT:
NORTH CAROLINA STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-297/2018-201
Dear Dr. Hawari:
From May 29-31, 2018, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at your North Carolina State University Reactor. The enclosed report presents the results of that inspection, which were discussed on March 31, 2018, with 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 selective 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 Publicly Available Records component of 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. Johnny H. Eads at (301) 415-0136 or by electronic mail at Johnny.Eads@nrc.gov.
Sincerely,
/RA/
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-297 License No. R-120 Enclosure:
As stated cc: w/enclosure: See next page
North Carolina State University Docket No. 50-297 cc:
Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Dr. Kostadin Ivanov, Head Department of Nuclear Engineering North Carolina State University Campus Box 7909 Raleigh, NC 27695-7909 W. Lee Cox, Section Chief Department of Health and Human Services Division of Health Service Regulation Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645 Dr. Louis Martin-Vega, Dean College of Engineering North Carolina State University 113 Page Hall Campus Box 7901 Raleigh, NC 27695-7901 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611
ML18234A482 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB/PM* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME JEads NParker AMendiola DATE 8/29/2018 8/24/2018 8/31/2018
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-297 License No.: R-120 Report No: 50-297/2018-201 Licensee: North Carolina State University Facility: PULSTAR Nuclear Reactor Facility Location: Raleigh, NC Dates: May 29-31, 2018 Inspector: Johnny Eads Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure
EXECUTIVE SUMMARY North Carolina State University PULSTAR Reactor Facility NRC Inspection Report No. 50-297/2018-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the North Carolina State Universitys (NCSU, or the licensees) Class II research reactor safety programs including: (1) organization and staffing; (2) operating logs and records; (3) procedures; (4) requalification training; (5) surveillance and limiting conditions for operation (LCO); (6) experiments; (7) health physics; (8) design changes; (9) committees, audits and review; (10) emergency planning; (11) maintenance logs and records; (12) fuel handling logs and records; and (13) transportation of radioactive materials procedures. The licensees programs were acceptably directed toward the protection of public health and safety, and in compliance with the U.S. Nuclear Regulatory Commission (NRC) requirements.
Organization and staffing
- Organizational structure and staffing were consistent with technical specification (TS)
requirements.
Operations Logs and Records
- Operations Logs and records were maintained in accordance with procedures and TSs.
Procedures
- The program for changing, controlling, and implementing facility procedures was acceptably maintained as required by the TSs and the applicable procedures.
Requalification Training
- Operator requalification was conducted as required by the Operator Requalification Plan Surveillance and Limiting Conditions for Operation
- The inspector found that the surveillance program and supporting procedures met TS requirements.
- Operations met the TS LCO and surveillance requirements.
Experiments Experiments were reviewed and approved as required by TS.
Health Physics
- Surveys were being completed and documented as required.
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- Postings met regulatory requirements.
- Personnel dosimetry was being worn and recorded doses were within the NRCs regulatory limits.
- Radiation monitoring equipment was being maintained and calibrated as required.
- The radiation protection program satisfied regulatory requirements.
- The radiation protection training program was being administered as required.
- Environmental monitoring satisfied license and regulatory requirements.
Design Changes
- The review, evaluation, and documentation of changes to the facility satisfied NRC requirements.
Committee Audits and Reviews
- The review and audit program was being conducted acceptably by the Reactor Safety Review Subcommittee as stipulated in TS.
Emergency Planning The emergency preparedness program was conducted in accordance with the Emergency Plan.
Maintenance Logs and Records
- Maintenance logs, records, reviews, and performance satisfied TS and procedure requirements.
Fuel Handling Logs and Records Fuel handling and inspection activities were completed and documented as required by TS and facility procedures.
Transportation of Radioactive Materials
- The program for shipping radioactive material satisfied regulatory requirements.
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REPORT DETAILS Summary of Facility Status The NCSU Nuclear Reactor Program (NRP) PULSTAR research reactor has been operated in support of graduate and undergraduate research and laboratory instruction, service irradiations, reactor operator training, and periodic surveillance. During the inspection, the reactor was operated in support of ongoing work and research.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001)
The inspector reviewed the following regarding the licensees organization and staffing to ensure that the requirements of TS Section 6.1 and Amendment No. 18, dated June 27, 2016, were being met:
- Organizational structure
- Management responsibilities
- Staffing requirements for safe operation of the research reactor facility
- PULSTAR Reactor Logbook, January 2017 through present
- Procedure NRP-OP-103, Reactor Operation, Revision 3, dated July 3, 2013 b. Observations and Findings The licensees functional organization had not changed since the last NRC inspection in this area. The minimum staffing required when the reactor is not secured is specified in TS Section 6.1.3. The inspector reviewed the console records for the period covering January 2017 through present and determined that staffing requirements were met.
c. Conclusion The licensees organization and staffing were in compliance with the requirements specified in TS Section 6.1. The operations log and associated records confirmed that shift staffing met the minimum requirements for duty and on call personnel.
2. Operations Logs and Records a. Inspection Scope (IP 69001)
The inspector reviewed selected maintenance and reactor operations records to ensure that the requirements of TS Section 6.8 were being met:
- Procedure NRP-OP-103, Reactor Operation, Revision 3, dated July 3, 2013
- NCSU PULSTAR Reactor Logbook, January 2017 through present-4-
b. Observations and Findings Reactor operations were carried out following written procedures and TS requirements. The inspector conducted observations of the reactor staff performing pre-startup checks and a startup.
The reactor operations logbook, an official record of reactor operations, was used as a chronological account of operations. The use of multicolor pens, black (routine entries), red (unscheduled scrams/shutdowns), and green (for scram clearance and authorization for continued operations) facilitated subsequent reviews by management. Hourly readings from operating equipment were recorded in the Operating Parameters Log. This data was used for preemptive maintenance to prevent equipment failures during operation. In addition, equipment maintenance records contained detailed information regarding equipment failures, the failure mode, repairs, calibrations, and operational testing prior to return to service. The factors used to calculate the estimated critical position of the control rods during reactor startup were also recorded appropriately. For the records included in this review, the licensees administrative requirements were met.
c. Conclusion The licensees record keeping program conformed to TS requirements.
3. Procedures a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the requirements of TS Section 6.4 were being met:
- NRP-OP-301, Reactor Fuel Handling, Revision 2, dated November 1, 2014
- NRP-OP-104, Reactor Startup and Shutdown, Revision 10, dated October 1, 2015
- Special Procedure (SP) 2.6, Operator Requalification Program, Revision 6, dated January 19, 1995
- PULSTAR Emergency Procedures (EP), specifically procedures:
EP-1, Emergency Plan Activation, Response, and Actions, Revision 19, EP-4, Emergency Classification, Revision 7
- PULSTAR Nuclear Reactor Emergency Plan, Revision 10 dated March 29, 2017 b. Observations and Findings The inspector observed that the licensee maintained written procedures covering the areas specified in TS Section 6.4. A systematic approach was being used to update and reissue procedures. New procedures and major changes were reviewed and approved by the Reactor Safety and Audit Committee (RSAC) and the Radiation Safety Committee (RSC), in accordance with a written procedure on document control. Minor changes did not require committee approval but-5-
were reviewed by the committees; the reviews and approvals were documented in the minutes of the respective committee meetings.
c. Conclusion The licensee was maintaining and implementing written procedures in accordance with TS requirements.
4. Requalification Training a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify that the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 55 and the licensees Operator Requalification Program were being met:
- Requalification Written Examination administered during the 2017-2018 requalification cycle.
- SP 2.6, PULSTAR Operator Requalification Program, dated January 19, 1995
- Individual requalification training records, 2017 - 2018 b. Observations and Findings The licensees reactor operator staff consisted of four NRC licensed senior reactor operators, all held by full time staff members, and eight reactor operators.
The licensees requalification program included the regulatory requirement for an annual operating test and a biennial written examination. The inspector verified that both examinations were administered at the specified frequency and that the level of difficulty was comparable to that of NRC-administered examinations.
The inspector reviewed the content of the written and oral examinations used for the 2017-2018 requalification cycle and found them adequate. The inspector reviewed the training and medical records for the 12 licensed operators. The inspector reviewed documentation indicating that all operators had performed the required number of reactor manipulations at the frequency specified in the requalification program.
c. Conclusion Operator requalification was conducted as required by the Requalification Program and NRC regulations.
5. Surveillance and Limiting Conditions of Operation a. Inspection Scope (IP 69001)
The inspector reviewed the following to determine if the LCO specified in TS Section 3.0 was being effectively implemented and if the periodic surveillance-6-
tests on safety systems were being performed in accordance with TS Section 4.0:
- Procedure SP-2.5, PULSTAR Reactor Surveillance, Revision 1, dated February 1, 1989
- PULSTAR Surveillance and Maintenance File
- PULSTAR Surveillance Master Schedule
- NCSU PULSTAR Reactor Logbooks #13, #14 and #15 covering the period 2017 to present b. Observations and Findings Surveillances were completed on schedule and in accordance with licensee procedures. The protocols and techniques were effective in verifying the performance of the safety equipment. All the recorded results were within the TS and procedurally prescribed parameters. The records and logs were complete and were being maintained as required. Checks and calibrations were completed as required by TS.
c. Conclusion The LCO and surveillances required by TS were being properly implemented.
6. Experiments a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with TS Section 3.7, TS Section 3.8, and TS Section 6.5 requirements:
- Experiment Logbook
- Procedure NRP-OP-104, Reactor Experiments, Revision 4, dated August 1, 2015
- Experiment Records, 2017 and 2018 to date b. Observations and Findings The licensee maintained an Experiment Logbook consisting of two sections. The first section consisted of completed forms entitled Appendix A to Procedure NRP-OP-104, Reactor Utilization Request. It contained approved experiments for miscellaneous reactor utilization and experiments for neutron activation analysis, neutron irradiation, and neutron flux mapping. These experiments had been approved throughout the life of the NRP by the RSC or the RSAC in accordance with TS Section 6.2. The approvals were written and approved pursuant to TS Section 6.5 as new or untried experiments; they were written to provide an umbrella for subsequent applications, with minor variations, as tried experiments approved by the Reactor Operations Manager (ROM) and the Reactor Health Physicist (RHP) pursuant to TS Section 6.5.
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The second section of the Experiment Logbook consisted of forms entitled Appendix B to Procedure NRP-OP-104, Reactor Sample Irradiation History.
Each time a tried experiment was performed, one line of data was added to this form, indicating the type of material irradiated, the quantity, the irradiation time, power level, etc. The ROM and RHP indicated that they reviewed each tried experiment prior to giving their approval to place it in the reactor.
c. Conclusion Experiments were reviewed and performed in accordance with TS requirements and the licensees written procedures.
7. Health Physics a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with 10 CFR Part 20 and TS Section 3.5 and TS Section 4.4 requirements:
- PULSTAR Nuclear Reactor Annual Report for 2017
- PULSTAR Nuclear Reactor Radiation Protection Program 2017 Annual Self-Assessment
- Landauer Personnel Dosimetry Reports for 2017 to 2018 to date
- File of Weekly Contamination Surveys for 2017 to 2018 to date
- File of Monthly Radiation Surveys for 2017 to 2018 to date
- PULSTAR Reactor Environmental Radiation Surveillance Report for 2017 b. Observations and Findings The inspector toured the facility and observed maintenance activities. The inspector 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 to be in accordance with regulations and the licensees written radiation protection program. The licensee had performed and documented annual self-assessments of the program as a tool for assuring radiation exposure was maintained as low as reasonably achievable.
The inspector reviewed records of radiation surveys of the nuclear reactor facility (NRF), performed by a HP specialist from the Department of Environmental Health and Safety (EHS), and found them to be generally low and in line with facility postings and instrument readings. No unmarked radioactive material was found in the facility. A copy of the current NRC Form 3 notice to radiation workers required by 10 CFR Part 19 was posted at the entrance to the control room and reactor bay.
Dosimetry results were reviewed by the inspector, indicating doses to most NRF occupants to be minimal.
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Radiation monitoring devices were found to be calibrated within the frequencies specified in procedures. The NRF personnel calibrated in-line process instrumentation, while the EHS calibrated all portable instruments.
The inspector noted from records that training was provided for radiation workers assigned to the NRF and individuals were not issued dosimetry or given access until the training was successfully completed.
The annual report referenced above described the gaseous, liquid, and solid waste generated at the NRF during the year 2017, with Argon-41 produced by the irradiation of atmospheric air being the only one of significance. The report presented the model, input data, assumptions, and summary of calculations for Argon-41 emissions. The inspector reviewed this information and concurred with the reported results. The inspector confirmed that liquid and solid radioactive waste was disposed of properly and in accordance with NRC requirements.
The licensee also reported the results of air sampling and thermoluminescent dosimeters (TLDs) placed at locations around the NRF as environmental radiation monitors. In all cases, the survey readings and TLDs indicated that the license continued to comply with NRC requirements associated with releases of radioactivity to the environment. Surface water and vegetables were analyzed for indications of environmental impacts and showed no significant difference from background levels.
c. Conclusion The inspector verified that the licensees radiation protection program was effective in minimizing radiation doses to individuals through training, notices to workers, radiation monitoring and surveys, and calibrated equipment. The program met regulatory requirements. Effluent releases, effluent monitoring, and environmental monitoring satisfied license and regulatory requirements.
8. Design Changes a. Inspection Scope (IP 69001)
In order to verify that any modifications to the facility were consistent with 10 CFR 50.59, the inspector reviewed selected aspects of:
- SP 2.1, Review and Approval of Documents, dated September 15, 2008
- PULSTAR Annual Operating Report for 2017, dated March 29, 2018 b. Observations and Findings Through review of applicable records and interviews with licensee personnel, the inspector determined that no changes requiring prior NRC approval had been initiated and/or completed at the facility since the last NRC operations inspection.
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The inspector review records for Change #830, Relocation of Original Flow Annubar and Installation of an Additional Flow Annubar, approved November 20, 2017.
The licensee completed the 10 CFR 50.59 screenings and evaluation as required.
c. Conclusion Records indicated that changes at the facility were acceptably reviewed in accordance with 10 CFR 50.59 and applicable licensee administrative controls.
9. Committees, Audits and Review a. Inspection Scope (IP 69001)
The inspector reviewed the following to ensure that the audits and reviews stipulated in TS Section 6.2 were being completed:
- RSC Membership, dated August 21, 2017
- RSAC Membership, dated August 21, 2017
- RSAC Minutes of meetings held during 2017 and 2018 to date
- RSC Minutes of meetings held during 2017 and 2018 to date
- 2017 RSAC Audit Summary dated March 30, 2018 b. Observations and Findings The composition of the RSC and RSAC were as specified in the TS. A review of records indicated that both committees met at the prescribed frequency and provided the oversight and reviews of the reactor programs as required by the TS.
c. Conclusion The RSC and RSAC provided the oversight required by the TS.
10. Emergency Preparedness a. Inspection Scope (IP 69001)
The inspector reviewed the emergency preparedness program and its implementation through the following:
- PULSTAR Nuclear Reactor Emergency Plan, Revision 10, dated March 29, 2017
- EP 1, Emergency Plan Activation, Response and Actions, Revision 19
- EP 2, Off-Site Notification, Revision 21
- EP 4, Emergency Classification, Revision 7
- EP 7, Training, Revision 6
- Training Records of Emergency Support Groups
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- PULSTAR Nuclear Reactor Drill Summary and Critique, for the drill conducted November 20, 2017
- Letter of Agreement with City of Raleigh Fire Department, dated January 6, 2015
- Letter of Agreement with State of North Carolina Division of Emergency Management, dated December 15, 2014
- Letter of Agreement with Wake County Emergency Management, dated January 1, 2015
- Letter of Agreement with Rex Healthcare Hospital, dated April 22, 2015 b. Observations and Findings The inspector reviewed the licensees emergency preparedness program as defined in the above-referenced emergency plan and implementing procedures.
The inspector also reviewed documentation related to an annual drill conducted August 8, 2014, the critique of the drill and lessons learned.
The inspector found that letters of agreement with support agencies were available and current.
The EP 6 training, specifies that training for support agency personnel be offered every 2 years. Training records indicated that it was offered annually on multiple days to accommodate shift workers schedules.
c. Conclusion The emergency preparedness program was conducted in accordance with the Emergency Plan and implementing procedures.
11. Maintenance Logs and Records a. Inspection Scope (IP 69001)
The inspector reviewed the following selected maintenance and reactor operation records to ensure that the requirements of TS Sections 6.8 were being met:
- PULSTAR Maintenance Log and History Report
- PULSTAR Reactor Logbook, Logbooks #14 and #15 covering the period 2017 to present b. Observations and Findings The inspector reviewed the maintenance records related to scheduled and unscheduled preventive and corrective maintenance activities that had occurred during the inspection period. The inspector reviewed maintenance records and interviewed personnel regarding maintenance completed on the Log N Channel replacement.
Routine and preventive maintenance was controlled and documented in the appropriate logs. These documents indicated that all maintenance activities
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were in accordance with the requirements in licensee administrative controls.
The inspector verified that all maintenance was conducted in accordance with the requirements of TS Section 4.0, and system operational checks were performed before returning them to service.
c. Conclusion Maintenance was performed and logs and records maintained consistent with TS and licensee procedure requirements.
12. Fuel Handling Logs and Records a. Inspection Scope (IP 69001)
The inspector reviewed the following records to verify implementation of the requirements of TS Section 4.1:
- Procedure NRP-OP-301, Reactor Fuel Handling, Revision 2, dated November 1, 2014, Appendix A, Confirmations of fuel movement and Appendix B, Fuel Movements Schedule during the period 2017 to 2018 to date
- Core Map Records of Fuel Element Locations b. Observations and Findings The inspector found the procedures used for fuel handling provide for the safe handling of fuel elements. The data sheets and the Core Map Records adequately documented the location of fuel elements at all times.
c. Conclusion Fuel movements were performed safely in accordance with TS requirements and licensee procedural requirements.
13. Transportation of Radioactive Materials a. Inspection Scope (IP 86740)
The inspector interviewed personnel and reviewed the following to verify compliance with regulatory and procedural requirements for transferring licensed material:
- File of Radioactivity Material Shipments for 2017 to 2018 to date
- Procedure HP 6, Transportation of Radioactive and Hazardous Material, Revision 1, dated September 25, 2003
- Hazardous Material Transfer and Shipment Summary (HP 6, Revision 1, Attachment 2) for material shipped in 2017 to 2018 to date
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b. Observations and Findings The inspector reviewed documentation for shipments of radioactive material made in 2017 to 2018 to date. All of the shipments were low quantities of radioactivity. Many contained fractional gram quantities of special nuclear material that had been irradiated; others were radionuclides produced at the reactor for on-campus and off-campus researchers. The licensee had reviewed licenses of receivers to verify that they held current licenses to receive the material being shipped. In all cases, the shipping papers were found in order.
c. Conclusion Radioactive material shipments were made according to procedures and regulatory requirements.
14. Exit Interview The inspector presented the inspection results to licensee management at the conclusion of the inspection on May 31, 2018. The inspector described the areas inspected and discussed in detail the inspection observations. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.
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PARTIAL LIST OF PERSONS CONTACTED Licensee A. Cook Manager, Nuclear Reactor Program and Reactor Operations Manager G. Gibson Reactor Engineer Director, Nuclear Reactor Program K. Kincaid Chief of Reactor Maintenance G. Wicks Reactor Health Physicist INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened:
None Closed:
None Discussed:
None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations EHS Department of Environmental Health and Safety EP Emergency Procedures HP Health Physics IP Inspection Procedure NCSU North Carolina State University NRC U.S. Nuclear Regulatory Commission NRF Nuclear Reactor Facility NRP Nuclear Reactor Program OP Operating Procedures RHP Reactor Health Physicist ROM Reactor Operations Manager RSAC Reactor Safety and Audit Committee RSC Radiation Safety Committee SP Special Procedure TLD Thermoluminescent dosimeters TS Technical Specification Attachment