IR 05000326/1997201
| ML20217E946 | |
| Person / Time | |
|---|---|
| Site: | University of California - Irvine |
| Issue date: | 03/26/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217E942 | List: |
| References | |
| 50-326-97-201, NUDOCS 9803310226 | |
| Download: ML20217E946 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50 326 License No: R-116 Report No: 50-326/97-201 Licensee: University of California, Irvine Facility: Department of Chemistry Nuclear Reactor Facility Location: Department of Chemistry University of California, Irvine Irvine, CA 92697-2025 Dates: December 811,1997 Inspector: Stephen W. Holmes, Reactor inspector Approved by: Marvin M. Mendonca, Acting Director Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management /NRR 9803310226 980326 PDR ADOCK 05000326 G PDR .
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EXECUTIVE SUMMARY This routine, announced inspection consisted of the review of selected conditions and records since the last inspection, verification of corrective actions previously committed to by the licensee, an't related discussions with licensee personnel. The inspection was conducted following the guidance of NRC Inspection Manua The reactor was being maintained and op0 ated as required by the license and applicable regulations. Reactor staff positions satis 11ed Technical Specification (TS) requirement Two non-cited violations were issued, one for failure to perform inspections of reactor fuel and control rods within the TS required intervals, and the other for failure to follow calibration and survey procedures. The licensee made a number of commitments to enhance tracking of surveillance requirements, for updating and following procedures, and to evaluate support staffin F
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Report Detaus Summary of Plant Status
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- The reactor was being operated a few days per week in support of research and training program . Operations 01 Conduct of Operations 01.1 Reactor Staffing a. . Insoection Scoos (Insoection Procedure 69001)
The inspector reviewed reactor staff qualifications, operations logs and records, selected events, and interviewed staf Observations and Findinas Licensed staff consinted of the Reactor Supervisor (RS), and one other Senior Reactor Operator (SHO) professor. The reactor staff satisfied the training and experience required by the Technical Specifications (TS). Operation logs and records confirmed that shift staffing met the minimum requirements for duty and on-call personnel. Since December 1995 direct support staff had consisted of one quarter time temporary technician. This was a replacement for the long time halftime permanent position that was vacated December 199 With teaching and research duties the time dedicated to reactor operations and maintenance was limited. Additionally, technician support was half of what it historically had been, with a period of almost four years with no suppor Conclusions The operations staffing of the research reactor satisfied TS requirement The inspector discussed with the RS and the Chair of Chemistry Dept. that, although the licenced reactor staff meet TS and is adequate for the present operation workload, the staffing might need to be augmented if operations increase. Also, as shown by the time and type of Non-Cited Violations (NCV)
issued in this report, the lack of technical support from December 1991 to 1995 may be a factor to the violations. Therefore, returning technical staffing support to the pro December 1991 levels should be considere .2 Control and Performance of Exnariments Insoection Scoon (Insoection Procedure 69001)
The inspector reviewed approved experiment records, reactor logs, experimental data, Reactor Operations Committee (ROC) minutes, observed experimental runs, and interviewed staff and experimenter ,
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2- Observations and Findinos Experiments and changes to approved experiments had been revhwed and approved as required by T Review of the experiment data in the reactor log and observation by the inspector of two experimental runs verified that experiments were constrained as required by the TS and experiment authorization. The experiments were also installed, performed, and removed as outlined in the experiment authorization and licensee's procedure Conclusions License control and performance of experiments met TS and licensee requirement .3 Reactor Ooerations and Fuel Handlino Insoection Scoos (Insoection Procedure 69001)
The inspector interviewed staff, reviewed reactor operations and fuel logs, and periodic checkout, start-up and shutdr wn checklists. The inspector observed a full start-up, shutdown, and observed several experimental irradiations from insertion to retrieva Observations and Findinos Reactor operations were carried out following written procedures and T Information on operational status was recorded in log books and checklists as required by procedures and TS. Use of maintenance and repair logs complied with procedures and satisfied regulatory and licensee requirement Fuel movement and handling was infrequent. Data recorded for fuel movement was clear. Fuel movement, inspection, log keeping, and recording followed the facility's procedure Conclusions Reactor operations conformed to TS and licensee procedural requirements. Fuel handling, record maintenance, and datumentation were accomplished as required by TS and licensee procedures. No safety concerns were identifie .
03 Operations Procedures and Documentation Insoection Scone (Insoection Procedure 69001)
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The inspector reviewed operating procedures and updates, reactor operating
. records and logs, and ROC minute '
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-3-E : Observations and Findings Written procedures required by the TS were available and used by the staff. Use'-
~ of and adherence to the procedures was acceptable. Procedure changes had .
- been reviewed and approved as require Records of power level, operating periods, unusual events, calibration and'
maintenance procedures, installed experiments, and start-up and shutdown checks were being kept._ Also, a record of SRO evaluations of unanticipated / unscheduled scrams was being kept as require Conclusions Facility operational procedures satisfied TS requirements. Reactor operating records and logs were being' maintained as required by T Operator Training and Qualificatfori *rogram Inanaction Senna (Insoection Procedure 69001)
The inspector reviewed requalification program records, NRC licenses, training records and interviewed staf . Observations and Findings Currently licensed operators were participating in the ongoing training as required by the NRC-approved requalification plan. Review of records showed that performance and competence evaluations of the operators had been given as required. Past test questions covered the material prescribed by the program and demonstrated technical depth. Required quarterly operation hours were being
. tracked. Biennial medical exams had been done as require The current requalification program exempts individuals who prepare and give sections of the exam from taking those portions. Records show that the reactor supervisor had normally prepared and given the exams in the past and thus had been exempt from taking the txam. In discussion with the reactor supervisor-about this provisions affect with a staff of two, the reactor supervisor stated that the staff.would alternate writing and administering the required written and operational exam c.- Conclusions The requalification program was being acceptably set up. TS and NRC-approved
- requalification plan requirements were me ,
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-4-06 Organization and Administration Insnaction Scone (Insnaction Procedure 69001)
The inspector reviewed organization, staffing and administrative controls and interviewed management and staf Observations and Findinos Since the last inspection no functional changes in the management ' organization or administrative controls had been mad Conclusions Organizational and administrative controls remain consistent with TS and license requirements and commitment Quality Assurance in Operations Insoection Scoos (Insoection Procedure 69001)
The inspector reviewed ROC minutes, annual reviews, audits, interviewed staff and attended the December 11,1997 ROC meeting, Observations and Findinos i
't Membership satisfied TS requirements and the Committee's procedural rule l Attendance at the meeting and review of the minutes showed that the committee l I
provided guidance, direction and oversight, and ensured suitable use of the reactor. The meeting minutes provided a record of the safety oversight of reactor operation ,
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Although the committee provided adequate oversight of reactor operations, the inspector could not determine, because of quorum number requirements, if meeting times satisfied TS requirements. This will be reviewed during a future inspection as Inspection Follow-up Item (IFl 50-326-97-201-01). Conclusions ;
The ROC carried out its safety duties as required by license, TS, and administrative criteri l
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ll. Maintenance M1 Conduct of Maintenance M1.1 Surveillances and Limitino Conditions for Onaration insnaction Scone (Insoection Procedure 69001)
The inspector observed several tests, and reviewed selected surveillance records, data sheets and records of tests, licensee procedures, reactor logs, checklists, periodic reports, and interviewed staf Observations and Findinos Daily and other periodic checks, tests, and verifications for TS required limiting conditions for operations (LCO) were completed as required. Most surveillance and LCO verifications were completed on schedule as required by TS and following licensee procedures. All were within prescribed TS and procedure i parameter As reported by the licensee in correspondence dated November 29,1997, five related TS required surveillances were not accomplished within the prescribed time constraint l TS 4.1 and 4.2 require the measurement of fuel rods and the inspection of )
control rods at intervals not to exceed 36 months. TS 4.2a,4.2b, and 4.3d require control rod reactivity worth and rod drop time determinations, and a calorimetric power calibration at intervals not to exceed 18 months. Contrary to these provisions the interval for the last fuel and control rod measurements and mechanicalinspection was 58 months while the rod worth, rod drop times, and power calibration interval was 19 month The RS stated that there had been a rnisunderstanding in the minds of their personnel that the fuel and control rod inspection interval was five rather than -
three years. The RS stated that the tracking system will be upgraded to insure -
required surveillances would be done within the correct time .
The inspector noted that NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Section 4.1(6) on fuel
> states that for pulsing TRIGAs with fewer than 10 pulses a year the annual inspection requirement may be relaxed. It also states that the interval for non-pulsing TRIGAs should be on at least a 5-year cycle. The reactor had not pulsed since October 25,1993 and its annual critical operation did not exceed 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> or .20 megawatt hours total thermal power outpu i
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m-6-The inspector confirmed that when the licensee realized they would be unable to accomplish the rod worth, rod drop times, and power calibration within the TS required 18 month interval, they cease power operations October 11,1997 (18 months since last surveillance) and did not resume running until they accomplished the surveillances November 13-14,199 The inspector noted that NUR5G-1537, Section 4. Surveillance Requirements, states that if a surveillance is not required for safety while the reactor was shut down, it may be deferred, but must be done before reactor statup. The licensee stated that they would submit a TS amendment bringing them in line with current guidance in NUREG-1537. This will be reviewed during a future inspection as inspection Follow up item (IFl 50-326-97-201-02)
The inspector confirmed that all required surveillances had been done by November 15,1997 and that all were within prescribed TS and procedure parameters and in close agreement with the previous surveillance result Conclusions Except for the licensee reported deficiencies, the facility's program for surveillance and LCO confirmations satisfied TS requirement Based on the safety significance and corrective action by the licensee, the licensee identified and corrected violations for failure to performed measurements of fuel rods and inspections of control rods at intervals not to exceed 36 months is being treated as an NCV (NCV 50-326-97-201-0), consistent with Section Vill.B.1 of the NRC Enforcement Polic The failure to measure control rod reactivity worth and rod drop times and perform a caterimetric power calibration at intervals not to exceed 18 months is being left as an unresolved item (URI 50-326-97-201-01) until receipt of the licensee's TS amendment bringing them in line with current guidance in NUREG 1537 M2 Maintenance and Material Condition of Facilities and Equipment Insoection Scone (Insoection Procedure 69001)
The inspector reviewed maintenance and reactor logs, ROC minutes, repair records, and observed facility and equipment during an accompanied tour, Observations and Findinos Though previously noted in its own logbc,ok, reactor maintenance was now consolidated in the reactor, health physics (HP) or monthly logs. The RS stated that the administrative procedures would be updated to show thi Routine / preventative maintenance was controlled and documented. Unscheduled maintenance or repairs were informally evaluated to decide that it did not cross over into being a facility change or if it did that it was approved under 50.59
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. criteria. The'AD stated that they would evaluate the need for formal written guidance to insure that any facility change would be done under 50.59 or license amendment as' required by TS. This will be reviewed during a future inspectio as an inspection Follow-up Item (IFl 602-97-201-02). Conclusions Maintenance logs, records, performance, and maintenance reviews satisfied TS and procedure requirement Ill. Engineering E1 Conduct of Engineering, Design Changes Insnaction Scone (Insnaction Procedure 69001)
- The inspector reviewed procedures, logs, records, and ROC files. The inspector also interviewed staff, b. ' Observations and Findinos No' design changes had been made since the last inspectio Conclusions Design changes satisfied TS and regulatory requirement IV. Plant Support
l R1 Radiologic'al Protection and Chemistry Controls R1.1 Badl# tion Protection Postinos Scone (Insnaction Procedure 69001)
The inspector reviewed radiological signs and postings, routine radiation surveys and observed the facility and equipment during accompanied tour . b .- Observations and Findings Postings were acceptable for the hazards involved. The f acility and radioactive o material storage were secured and properly posted. No unmarked or unsecured radioactive materials were evident. NRC Forms-3 were posted in appropriate areas in the facility as were current notices to workers required by.10 CFR 1 .
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-8- Conclusions Radiological postings satisfied regulatory requirement l R1.2. Effluent Monitoring and Release Econe (Insoection Procedura 69001)
The inspector reviewed annual reports, release records, counting, and analysis
" results, Observations and Findings Gaseous Releases were calculated as outlined licence procedures, adequately -
documented, and well within the annual dose constraint of 20.1101(d),
Appendix B concentrations and TS limit Liquid wastes from use of by-product material are disposed through an University
. contract. The waste is transferred to the custody of the Campus Environmental Health and Safety Office. Records from the last inspection through December 1997 confirmed there were no liquid effluent releases or transfers from the reacto Conclusions Effluent monitoring and releases satisfied license and regulatory requirement R1.3 Radiation Protection Survavs a. ' Scona finanaction Procedura 69001)
The inspector observed a number HP contamination and radiation area surveys, reviewed procedures and survey records, and interviewed staf Observations and Findings Weekly, quarterly, and other periodic contamination or radiation surveys were done by reactor and HP staffs as required by.TS and licensee procedure Results were evaluated and corrective actions taken and documented when readings /results exceeded set action icvels. With one exception all followed the
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- current licensee procedure. . This f ailure to follow the procedure for conducting the annual and semiannual neutron / gamma power surveys is discussed in section R3 of this inspection, c. -Ccaciusions With the one exception noted, all surveys were conducted and documented as .
required by .10 CFR 20, TS, and licensee procedures.-
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' The inspector reviewed dosimetry records, licensee procedures, observed
. issuance of dosimetry, and interviewed staf Observations and Findings The licensee used a National Voluntary Laboratory Accreditation Program-accredited vendor to process personnel thermoluminescent dosimetry. The
' licensee's dosimetry program for declared pregnant women satisfied 10 CFR 20.1208 requirements. An examination of records for the past three years showed that all exposures were within NRC limits, with most having no exposure above backgroun Conclusions Doses were in conformance with licensee and 10 CFR 20 limit R2' Status of Radiation Protection and Control (RP&C) Facilities and Equipment
.a. c Scone (Insoection Procedure 69001)
The inspector reviewed calibration, periodic checks, quality control, and test source certification records for radiation monitoring and counting lab instruments and interviewed HP staf Observations and Findings The calibration of the portable survey meters was performed in-house by the licensee reactor and HP staffs and by certified outside vendors. Calibration frequency met TS and licensee directives. Procedures were consistent with
' American National Standards institute or the manufacturers' recommendation Calibration and check sources were traceable to the National Institutes of Standards and Technology. With one exception, radiation monitoring and counting lab instruments were also calibrated as recommended by ANSI or the manufacture The :iquid scintillation counter is a newer model whose's manufacturer's user
- Manuel lists no calibration other than a computer controlled daily start-up
= check / verification. Although these daily and actual counting results were consistent, the inspector could not determine if, as with other new computer controlled counters, this check along with the manufactures annual servicing of s the unit satisfied 10 CFR 20.1501(b). The RS stated that they would contact the manufacturer and obtain the information on the recommended calibratio This will be reviewed during a future inspection as an inspection Follow-up Item -
(IFl 50-326/97-201-01).
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, . In reviewing records and in discussion with licenses staff the inspector found that the licensee had modified a few calibration processes and frequencies but
- had not changed the written procedures. This failure to follow procedures i . discussed in section R3 of this repor : All instruments checked. wore in calibration. Calibration records were in orde c.- Conclusions With the exceptions noted above RP&C equipment was being maintained .
- according to industry and equipment manufacturer standards. Calibrations satisfied TS requirement .
R3- RP&C Procedures and Documentation Scone (Inspection Procedure 69001)
The inspector reviewed Radiation Protection Program (RPP) documentation and various HP procedures and interviewed HP staf . Observations and Fmdings HP procedures were available for those tasks and items required by the TS, license, and f,acility directives. Written changes were reviewed and approved as required. Oversignt and review were provided by the reactor and university' staffs
. as required by TS and licensee procedure As noted in earlier section of this report, severalinstrument calibrations and HP surveys were not being done as outlined in the current written procedure. This failure to follow procedures is a violation of TS and licensee managemen directives requiring conformance with such written instruction The radiation area monitors were no longer calibrated on the higher scales as an ALARA measure. The licensee stated that these ranges serve little practical monitoring purposes at a low power research reactor and would cause personnel to receive more dose during such high range calibrations then they would in a )
- whole year of standard reactor operation The annual voltage plateau adjustment portion of the CAM calibration had not been done according to the written procedure. The licensee stated that this sensitive calibration of the CAM calibration is needed only if the voltage drifts or
- the detector tube deterioratas.' Therefore it was being done only when the other =I
' portions of t' he calibration failed to bring the CAM within specifications; )
' The annual an'd semiannual neutron and Damma area surveys had not been done l l since October 1991'as there had been no changes in core configuration, power i leval, or facility structures. The licensee stated that historical records 'show that
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. without such changes the neutron and gamma radiation fields do not chang i
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-11-Although the monthly dose and drift checks were being performed, the formal semiannual calibration / response check of the pocket charnbers had not been done since the departure of the previous reactor technicia The pocket chamber calibration / response checks and the samlannual neutron and gamma area surveys were done before the end of this inspection. All dosimeters passed and the neutron / gamma survey readings agreed with previous result The RS and health physicist stated that the procedures would be updated to reflect the current calibration or survey methodology, or the procedure would be followed as presently writte Conclusions The RPP satisfied the requirements of 10 CFR 20.1101. HP procedures and documentation were acceptabl Based on the minimal safety significance and the immediate and committed corrective action by the licensee, the inspector and licensee identified violation for failure to follow written procedures as required by TS and licensee management directives, is being treated as an NCV (NCV 50-326-97-201-02),
consistent with Section Vill.B.1 of the NRC Enforcement Polic R6. RP&C Oraantration and Administration Scone (Insoection Procedure 69001)
The inspector reviewed radiation protection program documentation, the Final Safety Analysis Report and the TS and interviewed staf Observations and Findinos The campus consists of the Director, Radiation Safety Office, an Assistant Director. four HP technicians, and students. They provided support to the reactor as well for being responsible for the state license. Coordination of HP activities between the HP and reactor staffs was acceptable with little or no difficulties b6 tween the reactor's NRC license requirements and the Nuclear Research Center's state license constrainment Conclusions HP staffing met TS, regulatory requirements and licensee commitment R8 Radioactive Material Transfer / Disposal Insoection Scone (Insoection Procedure 69001)
The inspector reviewed transfer checklists, shipping and disposal records, and interviewed staf $. <
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' Observations and Findinas i Production of radioactive waste at the facility was minimal.' The small amount produced was handled under the campus waste disposal program. All transfers were recorded on the appropriate forms. Transfer documentation was kept on file as require c., Conclusions Radioactive material transferred and disposed of in accordance with licensee procedures, TS, and 10 CFR 20 requirement .
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v. Management unennes X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on December 11,1997. The licensee acknowledged the findings presente PARTIAL LIST OF PERSONS CONTACTED Licensee R. Chamberlin Chair, Department of Chemistr F. Feher Chemistry Vice-Chair for Facilities and instrumentation F. Gallagher lil Radiation Safety Ofiicer, Environmental Health and Safety G. Miller : Reactor Supervisor-W. Nabor Health Physicist O. Nalcioglu Professor, Radiological Science P.J. Rogers Senior Reactor Operator INSPECTION PROCEDURE (IP) USED IP 69001: CLASS ll NON-POWER REACTORS IP 86740: INSPECTION OF TRANSPORTATION ACTIVITIES l
i ITEMS OPENED, CLOSED, AND DISCUSSED Opened IFl 50-326-97 201-01 Licensee to check on liquid scintillation counter's recommended calibratio IFl 50-326-97 201-02 The licenses to submit a TS amendment on deferred surveillances bringing them in line with current guidance in )
NUREG 153 IFl 50 326-97-201-03 The licensee to evaluate the need for formal written guidance for reviewing unscheduled maintenance for 50.59 applicatio URI 50-326-97-201-01 Determine if ROC meeting times satisfied TS requirements Closed NCV 50-326-97-201-01 Failure to performed measurements of fuel rods and inspections of control rods at intervals not to exceed 36 month NCV 50-326-97-201-02 ' Failure to follow written procedures as required by TS and licensee management directive ..
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-e PARTIAL LIST OF ANACHRONISMS USED HP Health Physics LCO Limiting Conditions for Operations NCV Non-Cited Violation NRC Nuclear Regulatory Commission RO Reactor Operator-ROC Reactor Operations Committee RS - Reactor Supervisor SRO- Senior Reactor Operator TS Technical Specifications
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