ML041140249
| ML041140249 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 05/06/2004 |
| From: | Lyons J NRC/NRR/DRIP/RNRP |
| To: | Hyland D Texas A&M Univ |
| Bassett C, NRR/DRIP/RNRP, 404-562-4899 | |
| References | |
| 50-128/2004-201 IR-04-201 | |
| Download: ML041140249 (22) | |
See also: IR 05000128/2004201
Text
May 6, 2004
Dr. David C. Hyland, Deputy Director
Texas Engineering Experiment Station
Texas A&M University
1095 Nuclear Science Road
College Station, TX 77843-3575
SUBJECT:
NRC INSPECTION REPORT NO. 50-128/2004-201 AND NOTICE OF VIOLATION
Dear Dr. Hyland:
This letter refers to the inspection conducted on April 12-15, 2004, at your Nuclear Science
Center Reactor Facility. The inspection included a review of activities authorized for your
facility. The enclosed report presents the results of that inspection.
Based on the results of this inspection, the NRC has identified a violation of NRC requirements.
The violation is cited in the enclosed Notice of Violation (Notice). The circumstances
surrounding it are described in detail in the subject inspection report. The violation is of
concern because it was identified by the NRC and not by your own internal review.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice 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 2.390 of the NRCs "Rules of Practice," a copy of this letter and its
enclosure 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/
James E. Lyons, Program Director
New, Research and Test Reactors Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No. 50-128
License No. R-83
Enclosures:
2. NRC Inspection Report No. 50-128/2004-201
cc w/encl.: Please see next page
Texas A&M University System
Docket No. 50-128
cc:
Mayor, City of College Station
P.O. Box Drawer 9960
College Station, TX 77840-3575
Governors Budget and
Planning Office
P.O. Box 13561
Austin, TX 78711
Texas A&M University System
ATTN: Dr. Warren D. Reece, Director
Nuclear Science Center
Texas Engineering Experiment Station
F. E. Box 89, M/S 3575
College Station, Texas 77843
Texas State Department of Health
Radiation Control Program Director
Bureau of Radiation Control
Dept. of Health
1100 West 49th Street
Test, Research and Training
Reactor Newsletter
202 Nuclear Sciences Center
University of Florida
Gainesville, FL 32611
May 6, 2004
Dr. David C. Hyland, Deputy Director
Texas Engineering Experiment Station
Texas A&M University
1095 Nuclear Science Road
College Station, TX 77843-3575
SUBJECT:
NRC INSPECTION REPORT NO. 50-128/2004-201 AND NOTICE OF VIOLATION
Dear Dr. Hyland:
This letter refers to the inspection conducted on April 12-15, 2004, at your Nuclear Science
Center Reactor Facility. The inspection included a review of activities authorized for your
facility. The enclosed report presents the results of that inspection.
Based on the results of this inspection, the NRC has identified a violation of NRC requirements.
The violation is cited in the enclosed Notice of Violation (Notice). The circumstances
surrounding it are described in detail in the subject inspection report. The violation is of
concern because it was identified by the NRC and not by your own internal review.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice 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 2.390 of the NRCs "Rules of Practice," a copy of this letter and its
enclosure 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/
James E. Lyons, Program Director
New, Research and Test Reactors Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No. 50-128
License No. R-83
Enclosures:
2. NRC Inspection Report No. 50-128/2004-201
cc w/encl.: Please see next page
DISTRIBUTION:
PUBLIC
RNRP\\R&TR r/f
AAdams
CBassett
PDoyle
TDragoun
WEresian
SHolmes
DHughes
EHylton
JLyons
PMadden
MMendonca
KWitt
PYoung
RidsNrrDrip
DBarss (MS O6-H2)
BDavis (Ltr only O5-A4)
NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML041140249
TEMPLATE #: NRR-106
OFFICE
RNRP:RI
RNRP:LA
RNRP:SC
RNRP:PD
NAME
CBassett:rdr
EHylton:rdr
PMadden
JLyons
DATE
04/ 29 /2004
04/ 28 /2004
05/ 03 /2004
05/ 05 /2004
C = COVER
E = COVER & ENCLOSURE
N = NO COPY
OFFICIAL RECORD COPY
ENCLOSURE 1
Texas A&M University
Docket No.: 50-128
Texas A&M Nuclear Science Center Research Reactor
License No.: R-83
During an NRC inspection conducted on April 12-15, 2004, a violation of NRC requirements
was identified. In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," NUREG-1600, the violation is listed below:
Section 6.3.f of the Technical Specifications requires that the licensee have written and
approved procedures to assure the safe operation of the reactor.
Nuclear Science Center Standard Operating Procedure Section VII-C-12, "Facility Radiation
Survey," Revision 3, dated August 19, 2003, requires in Step C.1 that a facility radiation survey
shall be performed each calendar month; and in Step C.2 that the survey data be recorded in
appropriate radiation units (microrem per hour or millirem per hour) on the floor plan of the area
being surveyed, HP Forms 824A-O.
Nuclear Science Center Standard Operating Procedure Section VII-C-14, "Facility
Contamination Surveys," Revision 3, dated December 4, 1997, requires in Step A that a smear
survey of the Nuclear Science Center facility will be performed each month.
Contrary to the above, during the year 2003: (1) no radiation or contamination survey was
completed of the Bridge (Upper Research Level) during August; and, (2) four instances were
noted when no radiation survey data was recorded on the floor plan of the area being surveyed.
This is a Severity Level IV violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, Texas A&M 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. 20555-0001 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 2.390 (b) to support a request for withholding confidential
commercial or financial information). If safeguards information is necessary to provide an
acceptable response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated at Rockville, Maryland
this 6th day of May 2004.
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No:
50-128
License No:
R-83
Report No:
50-128/2004-201
Licensee:
Texas A&M University
Facility:
Texas Engineering Experiment Station
Nuclear Science Center
Location:
College Station, TX
Dates:
April 12-15, 2004
Inspector:
Craig Bassett
Approved by:
James E. Lyons, Program Director
New, Research and Test Reactors Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
Texas A&M University
Texas Engineering Experiment Station
Inspection Report No. 50-128/2004-201
The primary focus of this routine, announced inspection was the onsite review of selected
aspects of the licensees Class II research reactor safety programs including: organization and
staffing, review and audit and design change functions, procedures, radiation protection,
environmental protection, security, material control and accounting, and transportation of
radioactive material since the last NRC inspection in these areas. The licensees programs
were directed toward the protection of public health and safety and were generally in
compliance with NRC requirements. One apparent violation was identified for failure to follow
Health Physics procedures.
Organization and Staffing
The licensees organization and staffing met requirements specified in Technical Specification Section 6.0.
Review and Audit, and Design Change Functions
The Reactor Safety Board acceptably completed review, oversight, and audit functions
required by Technical Specification Section 6.2.
The licensee's design change program was in accordance with 10 CFR 50.59 and was
being implemented as required.
Procedures
The procedural control and implementation program was determined to be satisfying
Technical Specification requirements.
Radiation Protection
Periodic surveys were generally completed and documented as required by procedure
with the exception that an apparent violation was identified for failure to follow procedure
for completing monthly contamination and radiation surveys.
Postings and signs met regulatory requirements.
Personnel dosimetry was being worn as required and recorded doses were within the
NRCs regulatory limits.
Radiation survey and monitoring equipment was being maintained and calibrated as
required.
The Radiation Protection and ALARA Programs satisfied regulatory requirements.
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Radiation protection training was acceptable.
Environmental Protection
Effluent monitoring satisfied license and regulatory requirements and releases were
within the specified regulatory and Technical Specification limits.
Security
The Nuclear Science Center security system equipment, tests, and procedures satisfied
the Physical Protection Plan requirements.
Material Control and Accounting
Special Nuclear Material was being acceptably controlled and inventoried as required.
Transportation
Radioactive material was being shipped in accordance with the applicable regulations.
REPORT DETAILS
Summary of Plant Status
The licensees one megawatt, pool-type TRIGA research and test reactor continued to be
operated in support of education, operator training, irradiation of various materials, laboratory
experiments, and various types of research. During the inspection, the reactor was started,
operated, and shut down as required and in accordance with applicable procedures to support
these ongoing activities.
1. Organization and Staffing
a. Inspection Scope (Inspection Procedure [IP] 69001)
The inspector reviewed selected aspects of the following regarding the licensees
organization and staffing to ensure that the requirements specified in Section 6.1 of
Technical Specifications (TS), Amendment No.15, dated November 1, 1999, were being
met:
organization and staffing for the Texas A&M Nuclear Science Center (NSC)
administrative controls and management responsibilities specified in the TS Section 6.0
2003 Annual Report for the Texas A&M University Nuclear Science Center
NSC Standard Operating Procedure (SOP), Section I-C, Administration, Revision
(Rev.) 0, dated March 6, 1990
b. Observations and Findings
The organizational structure and functions of the Texas Engineering Experimental
Station (TEES), NSC Reactor Facility had not functionally changed since the last
inspection (refer to NRC Inspection Report No. 50-128/2003-201). The licensees
current operational organization structure and assignment of responsibilities, as
reported in the Annual Report, were consistent with those specified in the TS Section 6.1.1. All positions were filled with qualified personnel. Review of records verified that
management responsibilities were administered as required by TS Section 6.1.2 and
applicable procedures.
However, there had been changes in the staffing. The Associate Director had left the
organization, as had a Health Physics (HP) Technician. No one had been hired to
replace the Associate Director but a person was in training to replace the technician.
The workload of the Associate Director had been divided among other staff members,
principally the Manager of Reactor Operations and the Radiation Safety Officer (RSO).
c.
Conclusions
The licensees organization and staffing were in compliance with the requirements
specified in TS Section 6.
-2-
2. Review and Audit, and Design Change Functions
a. Inspection Scope (IP 69001)
To verify that the licensee had established and conducted reviews and audits as
required in TS Section 6.2 and to determine whether modifications to the facility, if any,
were consistent with 10 CFR 50.59, the inspector reviewed:
Reactor Safety Board meeting minutes from 2001 through the present
completed audits and reviews from 2002 through 2003
design changes reviewed under 10 CFR 50.59 for 2002 and 2003
2003 Annual Report for the Texas A&M University Nuclear Science Center
Modification Authorization Number M-54, Safety Channel and Scram Circuit
Replacement, dated May 24, 2001, and final approval dated December 10, 2001
NSC SOP, Section I-H, Reactor Safety Board, dated March 6, 1990
b. Observations and Findings
(1) Review and Audit Functions
The inspector reviewed minutes of the last five Reactor Safety Board (RSB)
meetings. The minutes showed that the committee met more frequently than once
per calendar year as required by TS Section 6.2.2.a and that a quorum was present
for each meeting. The topics considered during the meetings were appropriate and
as stipulated in TS Section 6.2.3. The RSB conducted audits and reviews of the
ALARA program, the emergency preparedness and security plans, and the
licensees conformance of operations and maintenance items to the TS, as required
by TS Section 6.2.4 and 6.2.5. Results of the audits were reviewed and
recommendations for improvement were made. The inspector determined that the
audit findings and licensee actions taken in response to the findings were
acceptable.
(2) Design Change
The inspector determined that design changes at the NSC Reactor facility required a
facility staff review followed by an RSB review and subsequent approval. Only one
design change had been processed during the past several years. It involved
replacing the old Safety Power Measuring Channel with a functionally equivalent
new one. The inspector reviewed the records and determined that the staff review
had been performed as required and also that it had been reviewed and approved
by the RSB. Training was conducted on the modification and the system was
checked out prior to resumption of reactor operations. From the review, the
inspector also determined that 10 CFR 50.59 reviews and approvals were focused
on safety and met licensee program requirements. No safety significant issues were
noted during the review and the modification did not involve a change to the TS.
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c.
Conclusions
The RSB acceptably completed review, oversight, and audit functions required by TS Section 6.2. Based on the records reviewed, the inspector determined that the
licensees design change program was being implemented as required.
3. Procedures
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify compliance with TS Section 6.3 concerning facility procedures:
RSB meeting minutes from 2001 through the present
NSC SOP, Section I-D, Format, Rev. 3, dated February 25, 2002
NSC SOP, Section I-E, Origination, Rev. 1, dated February 25, 2002
NSC SOP, Section I-F, Review and Approval, Rev. 1, dated February 25, 2002
NSC SOP, Section I-G, Distribution and Binding, Rev. 0, dated July 31, 1986
NSC SOP, Section I-I, Software Controls, Rev. 0, dated March 17, 1997
NSC SOP Section VII-A-5, Annual Review of SOP Section VII (HP Procedures),
Revision 2, dated October 3, 1990
NSC Form 595, Procedure Change Notice (PCN), form dated June 10, 2003
b. Observations and Findings
The inspector reviewed various NSC SOP Sections and selected procedures. These
SOP Sections and procedures provided guidance for the administrative, operations, and
health physics functions of the facility. The inspector confirmed that written procedures
were available for those tasks and items required by TS Section 6.3. The licensee
controlled changes to procedures and the RSB conducted the review and approval
process as required.
After review of the 2003 training records and interviews with staff, the inspector
determined that the training of personnel on procedures was adequate. During tours of
the facility, the inspector observed that personnel performed facility operations and
tasks in accordance with applicable procedures.
c.
Conclusions
Based on the procedures and records reviewed and observations of staff during the
inspection, the inspector determined that the procedural control and implementation
program was acceptably maintained.
-4-
4. Radiation Protection Program
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify compliance with
10 CFR Parts 19 and 20 and TS Sections 3.5, 4.5, 5.4, and 6.6 requirements:
RSB meeting minutes from June 1, 2002, through the present
RSB completed audits and reviews from 2002 through the present
Personnel dosimetry records for 2001 to 2003
2003 Annual Report for the Texas A&M University Nuclear Science Center
various forms associated with the procedures mentioned below from 2003 to 2004
NSC SOP Section VII-A-1, Radiation Protection Program, Rev. 3, dated
December 4, 1997
NSC SOP Section VII-A-6, ALARA, Rev. 0, dated February 25, 2002
NSC SOP Section VII-B-3, Daily Building Integrity Check, Rev. 3, dated
December 4, 1997
NSC SOP Section VII-B-6, Monthly Facility Air Monitoring, Rev. 3, dated
August 25, 1984
NSC SOP Section VII-B-7, Area Radiation Monitor, Rev. 3, dated August 25, 1984
NSC SOP Section VII-B-13, Portable Survey Instrument Calibration and Operability
Check, Rev. 4, dated September 3, 1999
NSC SOP Section VII-B-14, Personnel Dosimeters, Rev. 6, dated October 15,
1999
NSC SOP Section VII-C-6, Radioactive Material Storage, Rev. 2, dated
December 19, 1997
NSC SOP Section VII-C-10, Radioactive Materials Handling, Rev. 2, dated
December 19, 1997
NSC SOP Section VII-C-11, Site Survey, Rev. 2, dated September 3, 1999
NSC SOP Section VII-C-12, Facility Radiation Survey, Rev. 3, dated August 19,
2003
NSC SOP Section VII-C-13, Special Radiation or Activity Surveys, Rev. 3, dated
December 19, 1997
NSC SOP Section VII-C-14, Facility Contamination Surveys, Rev. 3, dated
December 4, 1997
NSC SOP Section VII-D-1, Health Physics Training, Rev. 0, dated October 3, 1990
NSC SOP Section VII-E-1, Personnel Dosimetry, Rev. 0, April 13, 1995
b. Observations and Findings
(1) Surveys
The inspector reviewed selected monthly and other contamination and radiation
surveys since January 2003. The surveys had generally been completed by HP staff
members as required and were documented as required by procedures except as
noted in the following paragraph. Results were evaluated and corrective actions
taken when readings/results exceeded the licensees established limit of three times
background. During the inspection the inspector conducted a radiation survey along
-5-
side a licensee representative in the Upper Research Level of the Reactor Building.
Proper techniques were used during the survey. The radiation levels noted by the
inspector were comparable to those found by the licensee and no anomalies were
noted.
Section 6.3.f of the Technical Specifications requires that the licensee have written
and approved procedures to assure the safe operation of the reactor.
Nuclear Science Center Standard Operating Procedure Section VII-C-12, Facility
Radiation Survey, Revision 3, dated August 19, 2003, requires in Step C.1 that a
facility radiation survey shall be performed each calendar month; and in Step C.2
that the survey data be recorded in appropriate radiation units (microrem per hour or
millirem per hour) on the floor plan of the area being surveyed, HP Forms 824A-O.
Nuclear Science Center Standard Operating Procedure Section VII-C-14, Facility
Contamination Surveys, Revision 3, dated December 4, 1997, requires in Step A
that a smear survey of the NSC facility will be performed each month.
During a review of the radiation and contamination surveys conducted during 2003
the inspector noted various discrepancies. A review of surveys of the Bridge (Upper
Research Level) in the Reactor Building, documented on HP Form 824H, indicated
that no radiation or contamination survey was completed of that area during August.
Further, a review of surveys conducted during 2003 of the Upper Research Level
(South) in the Reactor Building, documented on HP Form 824B, indicated that no
radiation survey data was recorded on the floor plan of this area during surveys
conducted on June 23 and December 8. Also, a review of surveys of the Upper
Research Level Mezzanine in the Reactor Building, documented on HP Form 824D,
indicated that no radiation survey data was recorded on the floor plan of this area
during surveys conducted on September 3 and October 9.
The licensee was informed that, during 2003: 1) not completing a radiation or
contamination survey of the Bridge (Upper Research Level) during August; and,
2) not recording survey data on the floor plan of the area being surveyed on four
occasions were examples an apparent violation of TS Section 6.3 for failure to follow
procedures (VIO 50-128/2004-201-01).
(2) Postings and Notices
During tours of the facility, the inspector observed that caution signs, postings and
controls in the controlled areas were acceptable for the hazards involving radiation,
high radiation, and contaminated areas and were posted as required by 10 CFR 20,
Subpart J. Through observations of and interviews with licensee staff, the inspector
confirmed that personnel complied with the signs, postings, and controls. The
facilitys radioactive material storage areas were noted to be properly posted. No
unmarked radioactive material was detected in the facility.
-6-
Copies of current notices to workers were posted in appropriate areas in the facility.
Radiological signs were typically posted at the entrances to controlled areas. Other
postings also characterized the industrial hygiene hazards that were present in the
areas as well. All but one of the copies of NRC Form-3, Notice to Employees,
noted at the facility were the latest issue, as required by 10 CFR Part 19.11, and
were posted in various areas throughout the facility. These locations included the
bulletin board in the hallway by each entrance to the facility, in the hallway of the
Upper Research Level in the Reactor Building, and in the Lower Research Level of
the Reactor Building. (The out-dated Form-3 was immediately replaced by the
licensee.) Caution signs, postings, and controls for radiation areas were as required
in 10 CFR Part 20.
(3) Dosimetry
The inspector determined that the licensee used Optically Stimulated Luminescence
(OSL) dosimeters for whole body monitoring of beta and gamma radiation exposure
with an additional component to measure fast/thermal neutron radiation. The
licensee used thermoluminescent dosimeter (TLD) finger rings for extremity
monitoring. The inspector confirmed that dosimetry was being issued to staff and
visitors as required by NSC SOP Section VII-E, Personnel Dosimetry. The
dosimetry was supplied and processed by a National Voluntary Laboratory
Accreditation Program accredited vendor. An examination of the OSL and TLD
results indicating exposures to radiation at the facility for the past two years showed
that the highest occupational doses, as well as doses to the public, were within
10 CFR Part 20 limitations. The records showed that the highest annual whole body
exposure received by a single individual for 2002 was 927 millirem (mr) deep dose
equivalent (DDE). The highest annual extremity exposure for that year was 3260 mr
shallow dose equivalent (SDE). For 2003, the highest annual whole body exposure
received by a single individual was 779 mr DDE and the highest annual extremity
exposure was 2750 mr SDE.
Through direct observation the inspector determined that dosimetry was acceptably
used by facility personnel and exit frisking practices were in accordance with facility
radiation protection requirements.
(4) Radiation Monitoring Equipment
The calibration and periodic checks of the portable survey meters and radiation
monitoring instruments were performed by the licensees staff, Texas A&M
calibration facilities, or certified contractors. The inspector confirmed that the
licensees calibration procedures and frequencies satisfied TS Section 4.3 and
10 CFR 20.1501(b) requirements, or the instruments manufacturers'
recommendations. The inspector verified that the calibration and check sources
used were traceable to the National Institute of Standards and Technology.
The inspector reviewed the NSC instrument calibrations done since January 2003,
and confirmed that the calibration of the portable survey meters in use had been
completed as required. All instruments checked had current calibrations appropriate
-7-
for the types and energies of radiation they were used to detect and/or measure.
Calibrations of the permanently installed radiation area monitors and the facility air
monitors were completed in accordance with requirements specified in TS Section 4.5 and the applicable procedures.
During the inspection the inspector observed the calibration range at the facility.
The calibration range appeared to be adequate. During a demonstration of an
instrument calibration, the appropriate techniques were followed as outlined in the
applicable procedures.
(5) Radiation Protection Program
The licensees Radiation Protection and ALARA programs were established in NSC
SOP Section VII-A-1, Radiation Protection Program, NSC SOP VII-A-6, ALARA,
and through various related HP procedures. The programs had been reviewed and
approved as required. The Radiation Protection and ALARA programs contained
instructions concerning organization, training, monitoring, personnel responsibilities,
audits, record keeping, and reports. The ALARA program provided specific
objectives for keeping doses as low as reasonably achievable which was consistent
with the guidance in 10 CFR Part 20. The programs, as established, appeared to be
acceptable.
It appeared that the programs had not appreciably changed since the last NRC
inspection. The licensee reviewed the programs at least annually as required by
10 CFR 20.1101(c). Review and oversight was provided by the RSO with the
assistance of the RSB.
The licensee did not require or have a respiratory protection program.
(6) Radiation Protection Training
The inspector reviewed the radiation worker (or rad worker) training given to staff
members, to those who are not on staff but who are authorized to use the
experimental facilities of the reactor, and to part-time assistants such as students.
Training, and refresher training, for reactor staff and other rad workers, including
students, was given annually generally in conjunction with the Reactor Operator
Requalification training program.
The initial and refresher training covered the topics specified in 10 CFR Part 19 as
required. Training records showed that personnel were acceptably trained in
radiation protection practices. The training program was acceptable.
c.
Conclusions
The inspector determined that the Radiation Protection and ALARA Programs, as
implemented by the licensee, satisfied regulatory requirements because: 1) surveys
were generally completed and documented acceptably to permit evaluation of the
radiation hazards present; 2) postings met regulatory requirements; 3) personnel
-8-
dosimetry was being worn as required and recorded doses were within the NRCs
regulatory limits; 4) radiation survey and monitoring equipment was being maintained
and calibrated as required; 5) the Radiation Protection Program satisfied regulatory
requirements, and 6) the radiation protection training program was being acceptably
implemented. However, one apparent violation was identified for failure to follow
procedure for completing monthly contamination and radiation surveys.
5. Environmental Protection
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with the requirements of
10 CFR Part 20 and TS Sections 3.5, 3.7, 4.5, 5.4, and 6.6:
2003 Annual Report for the Texas A&M University Nuclear Science Center with the
effluent monitoring program results for that period
counting and analysis records associated with airborne releases
various forms associated with the procedures mentioned below from 2003 to 2004
NSC SOP Section VII-B-8, Stack Particulate Monitor, Rev. 3, dated October 15,
1999
NSC SOP Section VII-B-9, Stack Gas (Ar-41) Monitor, Rev. 3, dated September 3,
1999
NSC SOP Section VII-B-9A, Stack Gas (Xe-125) Monitor, Rev. 0, dated May 10,
2000
NSC SOP Section VII-B-10, Reactor Building Particulate Monitor, Rev. 5, dated
October 15, 1999
NSC SOP Section VII-B-11, Reactor Building Gas Monitor, Rev. 4, dated
September 3, 1999
NSC SOP Section VII.B.18, Environmental Surveillance Program, Rev. 2, dated
September 3, 1999
NSC SOP Section VII-C-8, Radioactive Liquid Waste System, Rev. 3, dated
May 10, 2000
NSC SOP Section VII-C-9, Radioactive Liquid Waste Disposal, Rev. 3, dated
May 10, 2000
b. Observation and Findings
On-site and off-site gamma radiation monitoring was completed using the reactor facility
stack effluent monitor and area monitors, and various environmental monitoring TLDs, in
accordance with the applicable procedures. Data indicated that there were no
measurable doses above any regulatory limits.
The inspector determined that gaseous releases continued to be monitored as required,
were calculated according to established protocol, and were acceptably documented in
the annual reports. The airborne concentrations of the gaseous releases were well
within the annual dose constraints of 10 CFR 20.1101 (d), Appendix B concentrations,
and TS limits. COMPLY code calculations indicated an effective dose equivalent to the
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public of 0.3 mr for 2002 and 0.077 mr for 2003. Observation of the facility by the
inspector indicated no new potential release paths.
The licensee had released liquid from the Radioactive Liquid Waste Holding Tank on
various occasions during the past two years. The Radiological Safety Officer reviewed
and approved the releases after analysis proved that the releases met regulatory
requirements for discharge. The principles of ALARA were acceptably implemented to
minimize radioactive releases. Monitoring equipment was acceptably maintained and
calibrated. Records were current and acceptably maintained.
c.
Conclusion
Effluent monitoring satisfied TS and regulatory requirements and releases were within
the specified regulatory limits. The environmental monitoring program was acceptable.
6. Physical Security
a. Inspection Scope (IPs 81401, 81402, 81403, 81431, and 81810)
To verify that the licensee was complying with security requirements specified in TS Section 5.8, the inspector reviewed selected aspects of:
RSB meeting minutes 2001 through the present
key and code controls
security system including equipment, intruder detection system, and physical
barriers
facility access controls and procedures
security audits and responses
listing of individuals authorized unescorted access to the facility documented on
NSC Form 116, form dated March 25, 1997
completed alarm testing documented on the appropriate forms
Key Notebook documenting physical inventories of keys and the list of individuals
authorized to possess security keys and codes
Security System Log Notebook and Security Incidents Report Folder
NSC SOP, Section VIII-D, NSC Access Control Procedure, Rev. 2, dated March 2,
2001
NSC SOP, Section VIII-G, Protection of Reactor Safeguards Information, Rev. 0,
dated April 13, 1995
NSC SOP, Section VIII-H, Self-Protection Program, Rev. 0, dated April 13, 1995
b. Observations and Findings
The licensees Physical Security Plan (PSP) entitled, Texas A&M University System,
Nuclear Science Center Reactor Security Plan, Rev. 1, dated January 1995 , was the
same as the latest revision approved by the NRC. The inspector noted that the plan
was being reviewed annually as required. It was also noted that the licensee was
properly controlling and protecting the PSP and other safeguards information as
required by the regulations.
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The inspector toured the facility and scrutinized the physical protection systems (barriers
and alarms), equipment, and instrumentation that were installed for security. The
inspector confirmed that the security checks, tests, verifications, and periodic audits
were performed and tracked as required by the PSP. Access control was implemented
as required by the PSP through the applicable procedures. Response rosters were
current and posted as required.
Through records review and interviews with licensee personnel, the inspector verified
that there had been no safeguards events at the facility since the last inspection. Also,
when new fuel recently was received by the licensee, proper controls were established
to protect the fuel and other Special Nuclear Material.
Members of the Texas A&M Police Department typically provided periodic patrols and
initial response to incidents at the reactor. The inspector met with the Texas A&M
Police Department Associate Director, the Interim Assistant Director for CID, a
Lieutenant, and a dispatcher. They were very knowledgeable of the reactor and of their
responsibilities in case of an emergency at the NSC. The inspector also noted an
excellent working relationship between the NSC and Police Department staff members.
c.
Conclusions
Based on observations and the records reviewed, the inspector found that the physical
security system equipment and procedures of the NSC satisfied the PSP requirements.
7. Material Control and Accounting
a. Inspection Scope (IP 85102)
To verify compliance with 10 CFR Part 70, the inspector reviewed:
nuclear material inventories (DOE/NRC Forms 741 and 742) for the past two years
accountability records and fuel storage locations
Special Nuclear Material inventory data documented on NSC Form 500, 501, and
502
Megawatt hours of operation data
NSC SOP Section III-Q, Special Nuclear Materials (SNM) Accountability, dated
October 31, 1984
The inspector also participated in a physical inventory of an irradiated fuel bundle being
maintained in storage.
b. Observations and Findings
The inspector determined that possession and use of SNM was limited to those areas
and purposes authorized by the license. The inspector verified that the licensee
maintained an amount of SNM that was equal to or less than that authorized by the
license. Fuel burn-up and related measurements and calculations were found to be
acceptable and properly documented. Fuel inspection and movement forms maintained
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in the NSC Fuel Notebooks were properly prepared. The records also showed that the
licensee was maintaining control of SNM storage areas as required.
Physical inventories were conducted at least annually as required by 10 CFR 70.51(d).
Nuclear Material Transaction Reports (DOE/NRC Form 741) and Material Status
Reports (DOE/NRC Form 742) had been completed semiannually and submitted by the
licensee to the appropriate regulatory agencies in a timely manner and as required by
During the inspection, the inspector toured the facility, examined the SNM and fuel
storage areas, and verified that the licensee was using and storing SNM in those areas
designated for such use in the PSP. The inspector also observed an inventory and
verified the serial number of an irradiated fuel bundle that was maintained in storage.
This demonstrated that the fuel and other SNM were in the locations specified and that
records documenting the storage and transfers of SNM were accurate.
c.
Conclusions
SNM was being acceptably controlled and inventoried as required.
8. Inspection of Transportation Activities
a. Inspection Scope (IP 86740)
The inspector interviewed licensee personnel and reviewed the following records to
verify compliance with regulatory and procedural requirements for shipping licensed
radioactive material:
selected records of various types of radioactive material shipments documented on
various forms including NSC Form 514, 852, and 854
training records of those qualified to ship radioactive material
NSC SOP, Section VII-C-1, Radioactive Material Inventory, Rev. 3, dated
September 3, 1999
NSC SOP, Section VII-C-2, Radioactive Materials Released Off-Site, Rev. 2, dated
December 20, 1994
NSC SOP, Section VII-C-3, Radioactive Materials Released From the NSC
License, Rev. 2, dated December 12, 1997
NSC SOP, Section VII-C-5, Radioactive Material Received, Rev. 3, dated
December 19, 1997
NSC SOP, Section VII-C-7, Radioactive Solid Waste Sorting, Rev. 4, dated
May 10, 2000
b. Observations and Findings
Through records review and discussions with licensee personnel, the inspector
determined that the licensee had shipped various types of radioactive material since the
previous inspection in this area. A review of the records of selected shipments indicated
that the radioisotope types and quantities were calculated and dose rates measured as
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required. All radioactive material shipment records reviewed by the inspector had been
completed in accordance with the applicable Department of Transportation (DOT) and
NRC regulations.
The inspector verified that the licensee maintained copies of shipment recipients
licenses to possess radioactive material as required and that the licenses were verified
to be current prior to initiating a shipment. The training of the staff members
responsible for shipping the material was also reviewed. The inspector verified that the
shippers training met DOT requirements. The training program appeared to be
extensive and conducted properly.
c.
Conclusions
Radioactive material was being shipped in accordance with the applicable regulations.
9. Exit Interview
The inspection scope and results were summarized on April 15, 2004, with licensee
representatives. The inspector discussed the findings for each area reviewed. 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 except the Physical
Security Plan.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
B. Asher
Senior Reactor Operator
D. Bagley
Reactor Supervisor
T. Fisher
Supervisor, Reactor Maintenance
B. Pack
Health Physics Technician
D. Reece
Director, Nuclear Science Center
J. Remlinger
Manager, Reactor Operations
L. Vasudevan
Radiation Safety Officer
Other Personnel
A. Beamer, Lieutenant, Texas A&M University Police Department
B. Kretzschmar
Interim Director for CID, Texas A&M University Police Department
E. Schneider
Associate Director for Security, Texas A&M University Police Department
INSPECTION PROCEDURE USED
Class II Research and Test Reactors
Plans, Procedures, and Reviews
Report of Safeguards Events
Receipt of New Fuel at Reactor Facilities
Fixed Site Protection of Special Nuclear Material of Low Strategic Significance
Protection of Safeguards Information
Material Control and Accounting - Reactors
Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-128/2004-201-01 VIO
Failure to follow procedures during 2003 in that: 1) no radiation or
contamination survey was completed of the Bridge (Upper
Research Level) during August; 2) survey data was not recorded
on the floor plan of the area being surveyed on four occasions.
Closed
None
LIST OF ACRONYMS USED
As low as reasonably achievable
CFR
Code of Federal Regulations
Health Physics
IP
Inspection Procedure
Nuclear Science Center
NRC
Nuclear Regulatory Commission
mr
millirem
Optically stimulated luminescence
Physical Security Plan
Radiation Safety Officer
RSB
Reactor Safety Board
Shallow dose equivalent
Senior Reactor Operator
Thermoluminescence dosimeter
TS
Technical Specifications
TEES
Texas Engineering Experiment Station
Violation