ML031410415
| ML031410415 | |
| Person / Time | |
|---|---|
| Site: | Washington State University |
| Issue date: | 05/29/2003 |
| From: | Beckner W NRC/NRR/DRIP/RORP |
| To: | Petersen J Washington State Univ |
| Bassett C, NRR/DRIP/RORP, 404-562-4899 | |
| References | |
| IR-03-201 | |
| Download: ML031410415 (26) | |
See also: IR 05000027/2003201
Text
May 29, 2003
Dr. James N. Petersen
Vice Provost for Research
Washington State University
Pullman, WA 99164-1030
SUBJECT:
NRC INSPECTION REPORT NO. 50-027/2003-201, NOTICE OF VIOLATION
AND NOTICE OF DEVIATION
Dear Dr. Petersen:
This refers to the inspection conducted on May 5-8, 2003, at your Washington State University
TRIGA research reactor in the Nuclear Radiation Center. The enclosed report presents the
results of that inspection.
Various aspects of your reactor operations and security programs were inspected, including
selective examinations of procedures and representative records, interviews with personnel,
and observations of the facility. Based on the results of this inspection, the NRC has identified
two violations of NRC requirements and a deviation from a commitment made to the NRC. The
violations are cited in the enclosed Notice of Violation and the deviation is cited in the enclosed
Notice of Deviation. The circumstances surrounding the violations and deviation are described
in detail in the subject inspection report. The violations are of concern because they would
have been prevented if you had followed your Emergency Plan.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notices when preparing your response. The NRC will use your response in
accordance with its policies to determine whether further enforcement action is necessary to
ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading
Room) http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning this inspection, please contact Craig Bassett at
404-562-4712.
Sincerely,
/RA/
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No.50-027
License No. R-76
Enclosures:
2. Notice of Deviation
3. NRC Inspection Report No. 50-027/2003-201
cc w/enclosures: Please see next page
Washington State University
Docket No. 50-27
cc:
Dr. Dwight Hagihara
Chair, Reactor Safeguards Committee
Washington State University
P.O. Box 641300
Pullman, WA 99164 - 1300
Stephanie Sharp
Reactor Supervisor, Nuclear Radiation Center
Washington State University
P.O. Box 641300
Pullman, WA 99164 - 1300
Dr. Len Porter
Director, Radiation Safety Office
Washington State University
P.O. Box 641302
Pullman, WA 99164 - 1302
Dr. Gerald Tripard
Director, Nuclear Radiation Center
Washington State University
P.O. Box 641300
Pullman, WA 99164 - 1300
Test, Research, and Training Reactors
Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
Dr. James N. Petersen
May 29, 2003
Vice Provost for Research
Washington State University
Pullman, WA 99164-1030
SUBJECT:
NRC INSPECTION REPORT NO. 50-027/2003-201, NOTICE OF VIOLATION
AND NOTICE OF DEVIATION
Dear Dr. Petersen:
This refers to the inspection conducted on May 5-8, 2003, at your Washington State University
TRIGA research reactor in the Nuclear Radiation Center. The enclosed report presents the
results of that inspection.
Various aspects of your reactor operations and security programs were inspected, including
selective examinations of procedures and representative records, interviews with personnel,
and observations of the facility. Based on the results of this inspection, the NRC has identified
two violations of NRC requirements and a deviation from a commitment made to the NRC. The
violations are cited in the enclosed Notice of Violation and the deviation is cited in the enclosed
Notice of Deviation. The circumstances surrounding the violations and deviation are described
in detail in the subject inspection report. The violations are of concern because they would
have been prevented if you had followed your Emergency Plan.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notices when preparing your response. The NRC will use your response in
accordance with its policies to determine whether further enforcement action is necessary to
ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading
Room) http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning this inspection, please contact Craig Bassett at
404-562-4712.
Sincerely,
/RA/
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No.50-027
License No. R-76
Enclosures:
2. Notice of Deviation
3. NRC Inspection Report No. 50-027/2003-201
cc w/enclosures: Please see next page
DISTRIBUTION:
PUBLIC
RORP/R&TR r/f
AAdams
CBassett
WBeckner
PDoyle
TDragoun
WEresian
FGillespie
SHolmes
DHughes
EHylton
PMadden
MMendonca
BDavis (Ltr only O5-A4)
NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML031410415
TEMPLATE #: NRR-106
OFFICE
RORP:RI
RORP:LA
RORP:SC
RORP:PD
NAME
CBassett:rdr
EHylton
PMadden
WBeckner
DATE
05/ /2003
05/ 28 /2003
05/ 29 /2003
05/ 29 /2003
C = COVER
E = COVER & ENCLOSURE
N = NO COPY
OFFICIAL RECORD COPY
ENCLOSURE 1
Washington State University
Docket No.: 50-027
Nuclear Radiation Center
License No.: R-76
During an NRC inspection conducted on May 5-8, 2003, two violations of NRC requirements
were identified. In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," NUREG-1600, the violations are listed below:
Section 6.8(3) of the Technical Specifications requires that the licensee have written operating
procedures for emergency situations including provisions for building evacuation, earthquake,
radiation emergencies, fire or explosion, personal injury, civil disorder, and bomb threat.
A.
Section 3.1.12 of the Emergency Plan requires that an annual training program,
including principles of radiation safety and contamination control, be conducted for the
emergency room staff of the (Pullman Memorial) hospital.
Section 10.1 of the Emergency Plan requires that, among other support groups,
Memorial Hospital emergency room personnel be trained on an annual basis in radiation
safety and Nuclear Radiation Center emergency procedures.
Contrary to the above, during 2001, 2002, and to-date in 2003, the Nuclear Radiation
Center had not provided training in radiation safety and Nuclear Radiation Center
emergency procedures for Pullman Memorial Hospital emergency room personnel.
This is a Severity Level IV violation (Supplement VIII).
B.
Section 8.4 of the Emergency Plan requires that written agreements with respect to
arrangements for hospital, medical, and other emergency services shall be updated on
a biennial basis.
The agreement between the licensee and the hospital, entitled Emergency Service
Agreement in the Event of a Radiological Incident at the Washington State University
(WSU) Nuclear Radiation Center, in effect from April 1, 2000 through March 31, 2002,
and the one currently in effect, states that Pullman Memorial Hospital has been provided
with a copy of the WSU Nuclear Radiation Center Emergency Plan and the associated
implementing procedures. The agreement further states that Pullman Memorial Hospital
agrees to participate in annual training sessions for the individuals who will provide the
support services as well as an annual drill exercise.
Contrary to the above, during an interview on May 8, 2003, representatives of the
Pullman Memorial Hospital stated that they had not been provided with a copy of the
WSU Nuclear Radiation Center Emergency Plan and the associated implementing
procedures. Also, during the years 2001, 2002, and to-date in 2003, no annual drill
exercises have been conducted by the WSU Nuclear Radiation Center with the Pullman
Memorial Hospital.
This is a Severity Level IV violation (Supplement VIII).
Pursuant to the provisions of 10 CFR 2.201, the Washington State University is hereby required
to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the responsible
inspector, 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 for
each violation: (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 to avoid further violations, 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 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, D.C. 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of the
NRCs document system (ADAMS), 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. ADAMS is accessible from the NRC Web site at (the Public Electronic
Reading Room) http://www.nrc.gov/reading-rm/adams.html. 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 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 2.790(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.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated at Rockville, Maryland
this 29th day of May 2003.
ENCLOSURE 2
NOTICE OF DEVIATION
Washington State University
Docket No.: 50-027
Nuclear Radiation Center
License No.: R-76
During an NRC inspection conducted on May 5-8, 2003, a deviation from your commitment to
the NRC to revise your Emergency Plan was identified. In accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the deviation
is listed below:
Following an inspection in May 2002, the licensee made a commitment to the NRC to revise the
Nuclear Radiation Center Emergency Plan to reflect actual training practices at the facility. The
revision was to reflect the practice of providing training for support personnel (i.e., police, fire
department and hospital personnel) on a triennial rather than on an annual basis.
Contrary to the above, during a review on May 8, 2003, it was noted that no revision of the
training requirements or practices had been made of the Emergency Plan in use by the Nuclear
Radiation Center.
Please provide to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555, with a copy to the responsible inspector, a reply in writing within
30 days of the date of this Notice. This reply should be clearly marked as a Reply to a Notice
of Deviation and should include: (1) the reason for the deviation, or if contested, the basis for
disputing the deviation, (2) the corrective steps that have been taken and the results achieved,
(3) the corrective steps that will be taken to avoid further deviations, and (4) the date when your
corrective action will be completed. 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, D.C. 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of the
NRCs document system (ADAMS), 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. ADAMS is accessible from the NRC Web site at (the Public Electronic
Reading Room) http://www.nrc.gov/reading-rm/adams.html. 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 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 2.790(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.
Dated at Rockville, Maryland
this 29th day of May 2003.
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No:
50-027
License No:
R-76
Report No:
50-027/2003-201
Licensee:
Washington State University
Facility:
Nuclear Radiation Center
Location:
Pullman, WA
Dates:
May 5-8, 2003
Inspector:
Craig Bassett
Approved by:
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
This routine, announced inspection involved onsite review of selected programs and activities
since the last NRC inspection including: Organizational Structure and Staffing, Review and
Audit Functions and Design Control, Operation of the Reactor, Experiments, Fuel Handling,
Surveillance, Maintenance, Procedures, and Emergency Preparedness.
Organizational Structure and Staffing
The operations organizational structure and responsibilities were consistent with
Technical Specifications requirements.
Shift staffing met the minimum requirements for current operations.
Review and Audit Functions and Design Control
The review and audit program was being conducted acceptably by the Reactor
Safeguards Committee.
No design changes had been proposed or completed since the previous NRC inspection
at the facility.
Operations
Operational activities were consistent with applicable Technical Specifications and
procedural requirements.
Experiments
Conduct and control of experiments and irradiations met the requirements specified in
the Technical Specifications, the applicable experiment and irradiation authorizations,
and associated procedures.
Fuel Handling
Fuel handling activities and documentation were as required by Technical Specifications
and facility procedures.
Surveillance
The program for tracking and completing surveillance checks and Limiting Conditions
for Operation verifications satisfied Technical Specifications requirements and licensee
administrative controls.
Maintenance
Maintenance logs, records, performance, and reviews satisfied Technical Specifications
and procedure requirements.
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Procedures
Facility procedural review, revision, control, and implementation satisfied Technical
Specifications requirements.
The emergency response program was generally conducted in accordance with the
requirements stipulated in the facility Emergency Plan.
Two violations were identified for failure to provide training to the emergency room staff
at the Pullman Memorial Hospital and failure to conduct an annual drill with the hospital
as required by the Emergency Plan.
A deviation was noted for failure to revise the Emergency Plan as committed during an
inspection in May 2002.
REPORT DETAILS
Summary of Plant Status
The licensees one megawatt Research and Test Reactor continued to be operated in support
of education, operator training, irradiation of various materials, and experiments involving Boron
Neutron Capture Therapy work. During the inspection, the reactor was started up, operated,
and shut down as required and in accordance with applicable procedures to support these
ongoing activities.
1.
Organizational Structure 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 Sections 6.1-6.3 of Technical Specifications (TS),
Amendment No. 17, dated April 3, 1998, were being met:
Washington State University (WSU) Nuclear Radiation Center organizational
structure and staffing
staff qualifications
management responsibilities
staffing requirements for the safe operation of the facility
WSU Nuclear Radiation Center Reactor Log sheets from May 2002 through May
2003
WSU Nuclear Radiation Center Administrative Procedure Number (No.) 1,
Responsibilities and Authority of Reactor Operating Staff, (not dated)
b.
Observations and Findings
The Nuclear Radiation Center organizational structure and the responsibilities of the
reactor staff had not changed since the last inspection. However, staffing levels had
changed. One Senior Reactor Operator (SRO), who previously worked at the facility,
had found other employment, while another individual had taken the NRC examination
to become a Reactor Operator (RO) and had received his license. One RO position
was open but the licensee had made an offer to an individual who was scheduled to
begin work at the facility in June 2003.
The inspector determined that the reactor operations staff satisfied the training and
experience requirements stipulated in the TS. In addition, the operations log and
associated records confirmed that shift staffing met the minimum requirements for
duty and on-call personnel.
c.
Conclusions
The operations organizational structure and responsibilities were consistent with TS
requirements. Shift staffing met the minimum requirements for current operations.
-2-
2.
Review and Audit Functions and Design Control
a.
Inspection Scope (IP 69001)
In order to verify that the licensee had established and conducted reviews and audits
as required in TS Section 6.5, the inspector reviewed selected aspects of:
Reactor Safeguards Committee (RSC) meeting minutes for 2002 to date
safety review and audit records documented on WSU Nuclear Radiation Center
forms entitled, Reactor Safeguards Committee Facility Records Quarterly Audit,
for the period from April 2002 through the present
responses to the safety reviews and audits
WSU Nuclear Radiation Center Administrative Procedure No. 3, Approval and
Review of Facility Modifications and Special Tests or Experiments, (not dated)
b.
Observations and Findings
The RSC membership satisfied TS requirements and the Committee's procedural
rules. The RSC had quarterly meetings as required and a quorum was present.
Review of the committee meeting minutes indicated the RSC provided appropriate
guidance and direction for reactor operations, and ensured suitable use and oversight
of the reactor.
Since the last inspection, all required audits of reactor facility activities and reviews of
programs, procedures, equipment changes, and proposed tests or experiments, had
been completed and documented. Additionally, the biennial reviews of the emergency
and security plans had been conducted and acceptably documented.
Through records review and interviews with licensee personnel, the inspector
determined that no design changes had been proposed or completed since the last
NRC inspection at the facility in May 2002 (refer to NRC Inspection Report
No. 50-027/2002-201, ADAMS Accession Number ML021350266.
c.
Conclusions
The review and audit program was being conducted acceptably by the Reactor
Safeguards Committee. No design changes had been proposed or completed during
the past twelve months.
3.
Operations
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify compliance with TS Section 6.2 and the applicable procedures:
WSU Nuclear Radiation Center Reactor Log sheets from May 2002 through
May 2003
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selected entries on forms entitled WSU Nuclear Radiation Center Form No. 34,
WSU Reactor Start-Up Checkoff, Revision March 5, 2002
Scram Summary Log entries from January 2002 through May 2003
Pulsing Summary Log entries from January 2002 through May 2003
staffing for operations as recorded on the Reactor Log sheets
observation of selected startup, operations, and shutdown activities on May 6, 7,
and 8, 2003
the licensees reports entitled Annual Report on the Operation of the Washington
State University TRIGA Reactor for July 1, 2000 through June 30, 2001, and
July 1, 2001 through June 30, 2002
WSU Nuclear Radiation Center SOP No. 1, Standard Procedure for Use of the
Reactor, dated November 29, 1995
WSU Nuclear Radiation Center SOP No. 4, Standard Procedure for Startup,
Operation, and Shutdown of the Reactor, dated November 29, 1995
b.
Observations and Findings
Reactor operations were carried out following written procedures and TS
requirements. Information on the operational status of the facility was recorded in log
books and on checklists as required by procedures and TS. Use of maintenance and
repair logs satisfied procedural requirements. Operational problems and events noted
in the operations log were reported, reviewed, and resolved as required by TS and
administrative procedures. Scrams were identified in the logs and records, reported
as required, and their cause(s) resolved before the resumption of operations under the
authorization of an SRO.
The inspector verified that TS and procedure required items were logged and cross
referenced with other logs and/or forms, as required, and that TS operational limits
had not been exceeded.
As noted previously, operations logs and records confirmed that shift staffing met the
minimum requirements for duty and on-call personnel.
c.
Conclusions
The Operational activities were found to be consistent with applicable TS and
procedural requirements.
4.
Experiments
a.
Inspection Scope (IP 69001)
To verify compliance with the licensees program for conducting experiments and
irradiations as outlined in TS Sections 3.10 and 6.5.4 and in various procedures, the
inspector reviewed selected aspects of:
WSU Nuclear Radiation Center Reactor Log sheets and irradiation records from
May 2002 through May 2003
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experiment approvals documented on WSU Nuclear Radiation Center Form
No. 2, entitled Experiment Request Form, form dated December 1972, with the
associated WSU Nuclear Radiation Center Form No. 4, entitled Experiment
Authorization Form, form dated August 1975
annual reviews documented in RSC meeting minutes
irradiation approvals documented on WSU Nuclear Radiation Center Form No. 1,
entitled Irradiation Request Form, dated October 1992, with the associated
WSU Nuclear Radiation Center Form No. 3, entitled Irradiation Authorization
Form, form dated October 1980
Irradiation Data Log sheets for the period from May 2002 to the present
WSU Nuclear Radiation Center SOP No. 1, Standard Procedure for Use of the
Reactor, dated November 29, 1995
WSU Nuclear Radiation Center SOP No. 2, Standard Procedure for Performing
Irradiations Using the Reactor, dated April 24, 2001
WSU Nuclear Radiation Center SOP No. 3, Standard Procedure for Performing
Experiments Using the Reactor, dated February 2, 1995
b.
Observations and Findings
The inspector reviewed in detail an irradiation request form and the associated
authorization form that had been approved since the last inspection. That request
form for Commercial Users, C-5, approved April 15, 2003, involved generation of short
lived fission products to measure coincidence radionuclide analysis systems. The
request form contained the appropriate information and had been reviewed and
approved as required by TS and procedure.
c.
Conclusions
The conduct and control of experiments and irradiations met the requirements
specified in the TS and the applicable experiment and irradiation authorizations and
procedures.
5.
Fuel Handling
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to ensure that the licensee
was complying with TS Sections 4.4, 5.1, 5.2, and 6.9:
WSU Nuclear Radiation Center Reactor Log sheets from 2001 through the
present
fuel handling equipment and instrumentation
Core Change Log
WSU Nuclear Radiation Center SOP No. 7, Standard Procedure for Core
Changes and Fuel Movement, dated February 17, 1995
WSU Nuclear Radiation Center SOP No. 8, Standard Procedure for Control
Element Maintenance, Removal, and Replacement, dated February 17, 1995
-5-
b.
Observations and Findings
Procedures for refueling, fuel movement, and TS required surveillances ensured
controlled operations for Core 33X, which was a mixed core of FLIP and standard fuel
elements. A detailed plan for performing fuel movement was required to be developed
prior to each fuel movement operation.
The inspector noted that the data recorded for fuel movements that had been
conducted in the past were acceptable and were required to be cross referenced in
the operations logs. Log entries indicated fuel movements were completed under the
direct supervision of an SRO as required. Through records review and interviews with
licensee personnel, the inspector determined that no fuel movements had been
conducted since the last NRC inspection at the facility in May 2002.
c.
Conclusions
The fuel handling activities and documentation were as required by facility TS and
procedures.
6.
Surveillance
a.
Inspection Scope (IP 69001)
To verify compliance with TS Sections 3 and 4, the inspector reviewed selected
aspects of:
Preventative Maintenance Checklists for 2002 and to date in 2003
Power Calibration Log for 2001 through the date of the inspection
Control Element Inspection Log
Control Element Calibration Log
other related surveillance, calibration, and test data sheets and records
WSU Nuclear Radiation Center Administrative Procedure No. 5, Surveillance
Documentation Review, (not dated)
WSU Nuclear Radiation Center SOP No. 13, Standard Procedure for Performing
Power Calibrations, dated May 3, 1994
WSU Nuclear Radiation Center SOP No. 14, Standard Procedure for Calibration
of Pulse Instrumentation, dated April 24, 2001
WSU Nuclear Radiation Center SOP No. 15, Standard Procedure for Alignment
of the Fuel Temperature System, dated March 1, 1992
WSU Nuclear Radiation Center SOP No. 16, Standard Procedure for Control
Element Calibration, dated February 20, 1995
b.
Observations and Findings
The Inspector determined that the daily, weekly, monthly, semiannual, and other
periodic checks, tests, and verifications for TS required Limiting Conditions for
Operations (LCOs) were being completed as required. In addition, all surveillance and
LCO verifications reviewed were completed on schedule as required by TS and in
accordance with licensee procedures. Extensive checklists were used to track
-6-
completion of the various required surveillances and LCO verifications. The checklists
included the date the activity was completed and by whom. These checklists provided
acceptable documentation of the results and proper control of reactor operational tests
and surveillances. Some of the daily and periodic checks of equipment operability
included recording system parameters such as temperature, pressure, and flow. All
recorded results observed by the inspector were within prescribed TS and procedure
parameters and in close agreement with the previous surveillance results.
c.
Conclusions
The program for tracking and completing surveillance checks and LCO verifications
satisfied TS requirements and licensee administrative controls.
7.
Maintenance
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of:
equipment maintenance as documented in the WSU Nuclear Radiation Center
Form No. 40, entitled Console Auxiliary Equipment Maintenance Checklist, form
dated May 2000 and in the Maintenance Log
Preventative Maintenance Checklists for 2002 and to date in 2003
WSU Nuclear Radiation Center Reactor Log sheets from 2001 through the
present
RSC meeting minutes for the past two years
WSU Nuclear Radiation Center Administrative Procedure No. 6, Performance of
Maintenance Activities, (not dated)
WSU Nuclear Radiation Center SOP No. 5, Standard Procedure for Performing
Preventive Maintenance on the Reactor and Associated Equipment, dated
April 24, 2001
WSU Nuclear Radiation Center SOP No. 8, Standard Procedure for Control
Element Maintenance, Removal, and Replacement, dated February 17, 1995
WSU Nuclear Radiation Center SOP No. 25, Standard Procedure for Purification
System Resin and Filter Change, dated December 28, 1982
WSU Nuclear Radiation Center SOP No. 28, Standard Procedure for Removal
and Installation of the Reactor Pool Room Ventilation System Absolute Filters,
dated December 5, 1995
WSU Nuclear Radiation Center Temporary Operating Procedure No. 1,
Procedure for Cooling System Cutout Switch Maintenance, dated January 26,
2001
b.
Observations and Findings
The Inspector observed that routine and preventive maintenance was controlled by
and documented in the maintenance or reactor operations logs and the monthly
Console Auxiliary Equipment Maintenance Checklists consistent with the TS and
licensee procedures. Unscheduled maintenance or repairs were reviewed to
-7-
determine if they required a 50.59 evaluation. Verifications and operational systems
checks were performed to ensure system operability before return to service.
c.
Conclusions
The maintenance logs, records, performance, and reviews satisfied TS and procedure
requirements.
8.
Procedures
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify that the licensee
was complying with the requirements of TS Sections 6.5.4 and 6.8:
selected administrative and standard operating procedures
records of procedure revision or review documented on licensee forms entitled,
Procedure Approval and Review Form
observation of procedure implementation
administrative controls as outlined in WSU Nuclear Radiation Center
Administrative Procedure No. 2, Standard Procedure for the Approval, Revision,
and Review of Standard Operating Procedures, (not dated)
b.
Observations and Findings
The Inspector found the operations procedures were available for those tasks and
activities required by the TS and facility directives and that written changes were
reviewed and approved by the RSC as required. In addition, the SOPs were reviewed
biennially as required by TS Section 6.5.4 with the last review having been completed
November 8, 2001.
Through observation of reactor operations and experiment handling, the inspector
verified that licensee personnel conducted TS activities in accordance with applicable
procedures. Training of personnel on procedures and changes was determined to be
acceptable.
c.
Conclusions
The review, revision, control, and implementation of procedures by the licensee
satisfied TS requirements.
9.
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of:
Emergency Plan and implementing procedures
emergency response facilities, supplies, equipment, and instrumentation
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training records for licensee staff and support personnel
offsite support as documented in the Letter of Agreement with the hospital
emergency drills and exercises for the past two years
WSU Nuclear Radiation Center SOP No. 6, Standard Procedure in the Event of
an Emergency Situation, dated February 17, 1995
WSU Nuclear Radiation Center SOP No. 32, Standard Procedure for Security
and Emergency Plan Training for Nuclear Radiation Center, Radiation Safety
Office, and Campus Police Personnel, dated November 18, 1997
b.
Observations and Findings
(1) Emergency Plan Implementation
The Emergency Plan (E-Plan) in use at the Nuclear Radiation Center was the
same as the version most recently approved by the NRC dated June 19, 1994.
The E-Plan was audited and reviewed biennially as required. Implementing
procedures were reviewed and revised as needed to effectively implement the
E-Plan. Emergency facilities, instrumentation, and equipment were being
maintained and controlled, and supplies were being inventoried quarterly as
required in the E-Plan.
The Inspector determined through records review and through interviews with
licensee personnel, emergency responders were determined to be knowledgeable
of the proper actions to take in case of an emergency. The agreement with the
Pullman Memorial Hospital had been updated and maintained as necessary.
Communications capabilities were acceptable with these support groups and had
been tested weekly and monthly as stipulated in the E-Plan. Off-site support for
the facility was verified to be acceptable and in accordance with the E-Plan.
In addition, the Inspector determined that the emergency drills were generally
being conducted as required by the E-Plan. In one instance, credit was taken for
an actual event which required the response of the emergency organization.
Critiques were written following the drills and/or the event to document any
strengths and weaknesses identified and to develop possible solutions to any
problems noted.
(2) Problems Noted with Plan Implementation
Section 6.8(3) of the TS requires that the licensee have written operating
procedures for emergency situations including provisions for building evacuation,
earthquake, radiation emergencies, fire or explosion, personal injury, civil
disorder, and bomb threat.
Section 3.1.12 of the E-Plan requires that an annual training program, including
principles of radiation safety and contamination control, be conducted for the
emergency room staff of the (Pullman Memorial) hospital. In addition,
Section 101 of the E-Plan requires that, among other support groups, Memorial
Hospital emergency room personnel be trained on an annual basis in radiation
safety and Nuclear Radiation Center emergency procedures.
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The inspector reviewed the training that the licensee had provided to various
support organizations for the past three years. During 2001, 2002, and to date in
2003, annual training had been provided to WSU Police Department personnel.
Records indicated that some training had also been provided to WSU Fire
Department personnel during that period. However, during 2001, 2002, and to
date in 2003, the inspector determined that no training had been provided by the
Nuclear Radiation Center for Memorial Hospital emergency room personnel in
radiation safety and Nuclear Radiation Center emergency procedures.
The licensee was informed that failure to conduct training for Memorial Hospital
emergency room personnel in radiation safety and Nuclear Radiation Center
emergency procedures was an apparent violation (VIO) of TS Section 6.8(3)
(VIO 50-027/2003-201-01).
Section 8.4 of the Emergency Plan requires that written agreements with respect
to arrangements for hospital, medical, and other emergency services shall be
updated on a biennial basis.
The support agreement between the licensee and the hospital entitled,
Emergency Service Agreement in the Event of a Radiological Incident at the
WSU Nuclear Radiation Center, in effect from April 1, 2000 through March 31,
2002, and the one currently in effect states that Pullman Memorial Hospital has
been provided with a copy of the WSU Nuclear Radiation Center Emergency Plan
and the associated implementing procedures. The Agreement further states that
Pullman Memorial Hospital agrees to participate in annual training sessions for
the individuals who will provide the support services as well as an annual drill
exercise, implying that drills are to be conducted annually.
The inspector toured the Pullman Memorial Hospital with hospital representatives
on May 8, 2003. During the tour the inspector asked hospital personnel about
their response capabilities and what the Nuclear Radiation Center could do to
help the hospital personnel fulfill their role of providing support medical services
for the reactor facility. The hospital representatives stated that they had not been
provided with a copy of the WSU Nuclear Radiation Center Emergency Plan and
the associated implementing procedures. They also indicated that they would like
to have the Nuclear Radiation Center provide annual training for emergency
response staff and would like to have an annual drill with the Nuclear Radiation
Center. The hospital staff members indicated that the last drill involving them was
held in 1996. The inspector subsequently checked the records of exercises and
drills at the reactor facility. The licensee records indicated that, during the years
2001, 2002, and to date in 2003, no annual drill exercises had been conducted by
the WSU Nuclear Radiation Center with the Pullman Memorial Hospital. The
most recent drill held by the licensee with the hospital was apparently on
February 24, 1997.
The licensee was informed that failure to provide the hospital with a copy of the
WSU Nuclear Radiation Center Emergency Plan and the associated
implementing procedures and failure to conduct annual drill exercises with the
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Pullman Memorial Hospital was another apparent violation of TS Section 6.8(3)
(VIO 50-027/2003-201-02).
c.
Conclusions
The emergency response program was generally conducted in accordance with the
requirements stipulated in the Emergency Preparedness Plan. Two violations were
noted with respect to implementation of the Plan.
10. Follow-up on Previously Identified Issues
a.
Inspection Scope
The inspector reviewed the actions taken by the licensee following identification of
Inspector Follow-up Items (IFI) during an inspection in May 2002, and documented in
NRC Inspection Report No. 50-027/2002-201, dated May 30, 2002.
b.
Observations and Findings
(1) IFI 50-027/2002-201-02 - Follow-up on the clarification of the last step in the
Reactor Startup Checkout.
During the inspection in May 2002, the inspector reviewed a report sent to the
NRC on August 7, 2000. The report detailed a licensee-identified monitoring
failure that occurred during the month of June 2000. The radionuclide content of
the reactor pool water was required to be monitored monthly at an interval not to
exceed six weeks in order to detect a significant leak in the sources stored in the
reactor pool. Due to personnel error, this monitoring was not performed in June.
The oversight was detected July 31, 2000, at which time a pool water sample was
obtained and analyzed. The water sample showed no abnormal radionuclide
levels. One of the licensees corrective items was to add an item to the Reactor
Startup Checkout to ensure that all operations, i.e., all required surveillances,
were completed before reactor operation. During the 2002 inspection it was
noted that an item had been added to the Checkout sheet but it was unclear as to
what it directed the operators to do.
The inspector checked on the clarification of this step in the Reactor Startup
Checkout. To date the licensee had not added any further guidance to the final
step in the Startup Checkout sheet but indicated that this would be done by the
end of the week.
This item remains open pending final clarification of the Reactor Startup Checkout
procedure.
(2) IFI 50-027/2002-201-03 - Follow-up on the issue of revising the E-Plan to reflect
actual training practices currently in use at the facility.
During the inspection in May 2002, the inspector noted that the training was not
being conducted annually for all groups specified in the E-Plan. The licensee
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stated that the emergency response training had always been given to the
Campus Police, WSU Fire Department and Ambulance Service personnel, and
Memorial Hospital on a rotating basis so that all groups received training about
every three years. Because of this interpretation of the E-Plan by the licensee,
the inspector indicated that something would need to be changed. Either the
training would need to be conducted or the E-Plan should be changed to require
triennial training of support groups. As a result, the licensee made a commitment
to the inspector to change the E-Plan language to conform with the actual
practice.
The inspector reviewed the issue of revising the E-Plan to reflect actual training
practices involving support groups. No revision had been completed as of the
date of the inspection. The licensee was informed that failure to revise the E-Plan
was a deviation (DEV) from a commitment made to the NRC (DEV 50-027/2003-
201-03). This IFI is considered closed.
c.
Conclusions
The licensee had not completed a change to the Reactor Startup Checkout procedure
that would provide clarification for the last step. Also, the licensee failed to fulfill a
commitment made to the NRC during the last inspection in May 2002 which resulted in
a deviation.
11. Exit Interview
The inspection scope and results were summarized on May 8, 2003, with members of
licensee management. The inspector described the areas inspected and discussed in
detail the inspection findings. No dissenting comments were received from the licensee.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
E. Corwin
Reactor Technician (RO)
K. Fox
Project Associate and SRO
S. Sharp
Reactor Supervisor
G. Tripard
Director, Nuclear Radiation Center
Other Personnel
D. Hagihara
Chairman, Reactor Safeguards Committee
L. Porter
Director, WSU Radiation Safety Office
INSPECTION PROCEDURES USED
Class II Research and Test Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-027/2003-201-01
Failure to conduct training for Memorial Hospital emergency
room personnel in radiation safety and Nuclear Radiation
Center emergency procedures as required by the Emergency
Plan.
50-027/2003-201-02
Failure to provide the hospital with a copy of the WSU Nuclear
Radiation Center Emergency Plan and the associated
implementing procedures and failure to conduct annual drill
exercises with the Pullman Memorial Hospital.
50-027/2003-201-03
DEV
Failure to fulfill a commitment made to the NRC concerning
revision of the Emergency Plan to reflect actual training
practices.
Closed
50-027/2002-201-03
IFI
Follow-up on the issue of revising the E-Plan to reflect actual
training practices currently in use at the facility.
Discussed
50-027/2002-201-02
IFI
Follow-up on the clarification of the last step in the Reactor
Startup Checkout.
PARTIAL LIST OF ACRONYMS USED
Agencywide Documents and Management System
CFR
Code of Federal Regulations
DEV
Deviation
IFI
Inspector Follow-up Item
IP
Inspection Procedure
LCO
Limiting Conditions for Operation
NRC
Nuclear Regulatory Commission
Publicly Available Records
Reactor Safeguards Committee
Standard Operating Procedure
Senior Reactor Operator
Reactor Operator
TS
Technical Specifications
Violation
WSU
Washington State University