ML13361A183
| ML13361A183 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 01/14/2014 |
| From: | Gregory Bowman Research and Test Reactors Branch B |
| To: | Krahenbuhl M Reed College |
| Basset C, 301-466-4495 | |
| References | |
| IR-13-201 | |
| Download: ML13361A183 (23) | |
See also: IR 05000288/2013201
Text
January 14, 2014
Dr. Melinda Krahenbuhl, Director
Reed Reactor Facility
Reed College
3203 S.E. Woodstock Boulevard
Portland, OR 97202-8199
SUBJECT:
REED COLLEGE - NRC ROUTINE INSPECTION REPORT NO.
50-288/2013-201 AND NOTICE OF VIOLATION
Dear Dr. Krahenbuhl:
This refers to the inspection conducted from December 16-19, 2013, at your Reed Research
Reactor facility (Inspection Report No. 50-288/2013-201). The enclosed report documents the
inspection results which were discussed with Dr. Nigel Nicholson, Dean of the Faculty; Kathleen
Fisher, Radiation Safety Officer and Campus Environmental Director; Brian Fairchild, Reactor
Operations Manager; and you on December 19, 2013.
During this inspection, the U.S. Nuclear Regulatory Commission (NRC) staff examined activities
conducted under your license as they relate to public health and safety to confirm compliance
with the Commissions rules and regulations and with the conditions of your license. Within
these areas, the inspection consisted of selected examination of procedures and representative
records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has determined that a Severity Level IV
violation of NRC requirements occurred. This violation is cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding it are described in detail in the subject
inspection report. The violation is being cited in the Notice because it is repetitive as a result of
inadequate corrective actions. A similar violation occurred on February 6, 2012, and corrective
actions for that violation were inadequate to prevent recurrence.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRC
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements
In accordance with Title 10 of the Code of Federal Regulations Section 2.390 of the NRCs
Rules of Practice, a copy of this letter, its enclosure, and your response will be available
electronically for public inspection in the NRC Public Document Room or from the NRCs
Agencywide Documents Access and Management System, accessible from the NRC
Dr. Krahenbuhl
- 2 -
Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
To the extent possible, your response should not include any personal privacy or proprietary
information so that it can be made available to the Public without redaction.
Sincerely,
/RA/
Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-288
License No. R-112
Enclosure:
NRC Inspection Report 50-288/2013-201
cc w/encl.: Please see next page
Reed College Docket No. 50-288
cc:
Mayor of the City of Portland
1220 Southwest 5th Avenue
Portland, OR 97204
Reed College
ATTN: Dr. Nigel Nicholson,
Dean of the Faculty
3203 S.E. Woodstock Boulevard
Portland, OR 97202-8199
Reed College
ATTN: John Kroger, President
3203 S.E. Woodstock Boulevard
Portland, OR 97202-8199
Oregon Department of Energy
ATTN: David Stewart-Smith, Director
Division of Radiation Control
625 Marion Street, N.E.
Salem, OR 97310
Test, Research, and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
Dr. Krahenbuhl
- 2 -
Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
To the extent possible, your response should not include any personal privacy or proprietary
information so that it can be made available to the Public without redaction.
Sincerely,
/RA/
Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-288
License No. R-112
Enclosure:
NRC Inspection Report 50-288/2013-201
cc w/encl.: Please see next page
DISTRIBUTION:
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ACCESSION NO.: ML13361A183
- concurred via e-mail
OFFICE
NRR/DPR/PROB*
NRR/DPR/PROB
NAME
CBassett
GBowman
DATE
1/6/2014
1/14/2014
OFFICIAL RECORD COPY
Reed College
Docket No. 50-288
Reed Research Reactor
License No. R-112
During an NRC inspection conducted from December 16-19, 2013, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
Title 10 of the Code of Federal Regulations (10 CFR) Paragraph 50.54(k) requires that
an operator or senior operator licensed pursuant to 10 CFR Part 55 shall be present at
the controls at all times during the operation of the facility.
Technical Specification (TS) Section 6.1.3 requires, in part, that the minimum staffing
when the reactor is operating shall be a licensed reactor operator in the control room.
TS Section 1 defines the reactor as operating whenever it is not shut down or secured.
Contrary to the above requirements, on November 16, 2013, a licensed operator or
senior operator was not present in the control room when the reactor was in operation.
Specifically, the on-shift reactor operator and senior reactor operator left the control
room while the reactor key was still in the console, leaving the control room unattended
with the reactor in an unsecured and, therefore, an operating condition.
This has been determined to be a Severity Level IV violation (Section 6.1).
Pursuant to the provisions of 10 CFR 2.201, Reed College 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: (1) the reason for the
violation, or, if contested, the basis for disputing the violation or severity level; (2) the corrective
steps that have been taken and the results achieved; (3) the corrective steps that will be taken;
and (4) the date when full compliance will be achieved. Your response may reference or
include previous docketed correspondence, if the correspondence adequately addresses the
required response. If an adequate reply is not received within the time specified in this Notice,
an order or 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, U.S. 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 NRCs document system, accessible from the NRC Web
site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include
any personal privacy, proprietary, or safeguards information so that it can be made available to
the public without redaction. If personal privacy or proprietary information is necessary to
provide an acceptable response, then please provide a bracketed copy of your response that
identifies the information that should be protected and a redacted copy of your response that
- 2 -
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 this 14th day of January 2014.
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No:
50-288
License No:
R-112
Report No:
50-288/2013-201
Licensee:
Reed College
Facility:
Reed Research Reactor
Location:
3203 S.E. Woodstock Boulevard
Portland, OR
Dates:
December 16-19, 2013
Inspector:
Craig Bassett
Approved by:
Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
Reed College
TRIGA Mark-I Research Reactor
Report No: 50-288/2013-201
The primary focus of this routine, announced inspection was the onsite review of selected
aspects of the Reed College (the licensees) Class II 250 kilowatt research reactor safety
program including: (1) organization and staffing, (2) review and audit and design change
functions, (3) radiation protection, (4) effluent and environmental monitoring, (5) procedures,
and (6) transportation of radioactive material since the last U.S. Nuclear Regulatory
Commission (NRC) inspection of these areas. The licensees program was acceptably directed
toward the protection of public health and safety and was generally in compliance with NRC
requirements. One Severity Level IV violation was identified.
Organizational Structure and Staffing
Facility organization and staffing were in compliance with the requirements specified in
Section 6.1 of the Technical Specifications.
Review and Audit and Design Change Functions
Reviews and audits were being conducted by the Reactor Operations Committee in
compliance with the requirements specified in the Technical Specifications.
Proposed changes at the facility had been analyzed using Title 10 of the Code of
Federal Regulations Section 50.59 safety evaluation process.
Radiation Protection Program
Signs, notices, and postings met the regulatory requirements.
Personnel dosimetry was being worn as required and doses were well within the
licensees procedural action levels and NRCs regulatory limits.
Surveys were completed and documented acceptably to permit evaluation of the
radiation hazards present.
Radiation survey and monitoring equipment was being maintained and calibrated
acceptably.
Radiation protection training was acceptable and was being conducted as required.
The Radiation Protection and the As Low As Reasonably Achievable Programs satisfied
regulatory requirements.
-2-
Environmental Monitoring Program
Effluent monitoring satisfied licensee procedural and regulatory requirements and
releases were calculated to be within the specified regulatory limits.
Procedures
Facility procedures were acceptably reviewed, approved, and implemented.
Transportation of Radioactive Materials
The program for shipping radioactive material satisfied regulatory requirements.
Follow-up on a Violation
One Severity Level IV violation was identified for the failure to have an operator in the
control room while the reactor was not secured, as required.
REPORT DETAILS
Summary of Plant Status
Reed Colleges (the licensees) Class II 250 kilowatt TRIGA Mark-I research reactor continued
to be operated in support of undergraduate instruction, laboratory experiments, reactor operator
training, and various types of research. During the inspection, the reactor was operated as
needed for laboratory experiments and training.
1.
Organizational Structure and Staffing
a.
Inspection Scope (Inspection Procedure (IP) 69001)
To verify organization and staffing requirements specified in Technical
Specifications (TS) Section 6.1, dated April 25, 2012, were being met, the
inspector reviewed selected aspects of:
Current facility organization and staffing
Management responsibilities as outlined in the applicable procedures
Reed Research Reactor (RRR) Administrative Procedures, dated May
2012
RRR Annual Report for the period from July 1, 2011, through June 30,
2012, submitted on August 7, 2012
RRR Annual Report for the period from July 1, 2012 through June 30,
2013, submitted August 7, 2013
b.
Observations and Findings
The organizational structure had not changed since the last NRC inspection,
which occurred in December 2012 (Inspection Report No. 50-288/2012-201).
The current Reactor Director remained in that position. A new individual had
been hired to fill the position of Reactor Operations Manager.
The radiation protection duties at the facility were completed by various
individuals, including the Reactor Operations Manager and students who were
also Reed College part-time employees. These individuals conducted surveys,
completed instrument calibrations, and handled and counted samples. These
activities were reviewed and approved by the Facility Director and the Radiation
Safety Officer.
The organizational structure and staffing at the facility were as required by the
TS. Review of records verified that management and staff responsibilities were
carried out as required by the TS and applicable procedures.
c.
Conclusion
The licensees organization and staffing were in compliance with the
requirements specified in the TS.
- 2 -
2.
Design Change and Review and Audit Functions
a.
Inspection Scope (IP 69001)
In order to ensure that the audits and reviews required by TS Section 6.2 were
being completed, and to verify that any modifications to the facility were
consistent with Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.59, the inspector reviewed the following:
Corrective action reports for 2012 and to date in 2013
Recent changes reviewed using the licensees RRR 10 CFR 50.59
screen forms
Minutes of the meetings held by the Reactor Operations Committee
(ROC) from November 2011 to the present
Safety review and audit records for 2011-2012 and 2012-2013 as
documented on RRR standard audit forms
RRR Administrative Procedures, dated May 2012
RRR Standard Operating Procedure (SOP) 60, Logbook Entries, dated
April 14, 2010
RRR SOP 62, Changes, Tests, and Experiments, dated May 27, 2010
RRR SOP 69, Corrective Action Report, dated August 5, 2010
RRR Annual Report for the period from July 1, 2011, through June 30,
2012, submitted on August 7, 2012
RRR Annual Report for the period from July 1, 2012 through June 30,
2013, submitted August 7, 2013
b.
Observations and Findings
(1)
Review and Audit Functions
The inspector reviewed the ROC meeting minutes from November 2011
to the present. These meeting minutes showed that the committees met
as required by the TS with a quorum being present. Records showed that
the safety reviews and audits conducted by the committee or designated
individuals were completed at the TS-required frequency. Topics of these
reviews were also consistent with TS requirements and provided
guidance, direction, and oversight of the reactor.
The inspector noted that the safety reviews and audits that had been
completed, as well as the associated findings, were acceptably detailed
and that the licensee responded and took corrective actions as needed.
The inspector also reviewed the corrective action log. Various
recommendations had been discussed and reviewed and a solution to
each had been determined and subsequently implemented as needed.
(2)
Design Change
Through review of the ROC meeting minutes, and through interviews with
licensee personnel, the inspector determined that no major changes had
- 3 -
been initiated and/or completed at the facility since the last NRC
inspection. Nine 10 CFR 50.59 screens were completed in 2012 and
three have been completed to date in 2013. It was also noted that, as a
result of the screens being conducted, no evaluations were required to be
completed in 2012 and none were required as of the date of the
inspection in 2013. Because the licensee determined that the changes
were minor in nature, they had been reviewed and approved by the
Facility Director, but were not required to be approved by the ROC.
c.
Conclusion
Review, audit, and oversight functions required by TS Section 6.2 were
acceptably completed by the ROC. Proposed changes at the facility had been
analyzed using the 10 CFR 50.59 review process as required.
3.
Radiation Protection Program
a.
Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with 10 CFR Parts 19
and 20, and TS Sections 3.5 and 4.5:
Radiological signs and posting
Radiation work permit notebook
ROC Audits for 2011-2012 and 2012-2013
Personnel dosimetry records for 2011, 2012, and to date in 2013
Daily reactor startup and shutdown checklists for the past 12 months
Routine surveys and monitoring records for 2012 and 2013, including
weekly checklists, biweekly wipes, and bimonthly checklists
Records of maintenance and calibration of radiation survey and
monitoring instruments
Reed Reactor Facility Radiation Protection Plan, dated August 2006
As Low As Reasonably Achievable (ALARA) Program, as described in
the Radioactive Materials Policy and Procedures Manual, dated April
2013
RRR Administrative Procedures, dated May 2012
Various RRR SOPs
Radioactive Materials Handling Study Guide, dated July 2004
Reed College Radioactive Materials Policy and Procedures Manual,
dated April 2013
Reed Research Reactor Radiation Protection Program Annual Review
2012-2013
RRR Annual Report for the period from July 1, 2011, through June 30,
2012, submitted on August 7, 2012
RRR Annual Report for the period from July 1, 2012 through June 30,
2013, submitted August 7, 2013
- 4 -
The inspector also observed the use of dosimetry and radiation monitoring
equipment during tours of the facility.
b.
Observations and Findings
(1)
Postings and Notices
Copies of current notices to workers were posted inside the reactor
control room at RRR. Radiological signs were typically posted at the
entrances to controlled areas as well. The posted copies of NRC Form 3,
Notice to Employees, observed at the facility were the latest issue, as
required by 10 CFR Part 19.11, and were posted in the reactor bay, and
in the laboratory room.
Caution signs, postings, and controls for radiation areas were as required
in 10 CFR Part 20, Subpart J. The inspector verified that licensee
personnel observed the precautions for access to radiation areas.
(2)
Dosimetry
The inspector determined that the licensee used optically stimulated
luminescent (OSL) dosimeters for whole body monitoring of beta and
gamma radiation exposure. The licensee also used thermoluminescent
dosimeter (TLD) finger rings for monitoring beta and gamma radiation
exposure of the extremities. The dosimetry was supplied and processed
by a National Voluntary Laboratory Accreditation Program accredited
vendor. An examination of the OSL and TLD results indicating
radiological exposures at the facility for the past two years showed that
the highest occupational doses, as well as doses to the public, were well
within 10 CFR Part 20 limitations.
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.
(3)
Surveys
Selected daily, weekly, and biweekly radiation and/or contamination
surveys were reviewed by the inspector. The surveys had been
completed by staff members as required. Any contamination detected in
concentrations above the established action level was noted and the area
was decontaminated. Results of the surveys were documented so that
licensee personnel would be knowledgeable of the radiological conditions
that existed in the various areas of the facility.
(4)
Radiation Monitoring Equipment
Examination of selected radiation monitoring equipment indicated that the
instruments had an acceptable up-to-date calibration sticker attached.
- 5 -
The instrument calibration records indicated that the calibration of
portable survey meters was typically completed by reactor staff personnel
and/or the Reactor Health Physicist (RHP). Calibration frequency met
procedural requirements and records were maintained as required. Fixed
location radiation area monitors and stack monitors were also being
calibrated as required. These monitors were also typically calibrated by
reactor staff personnel and/or the RHP.
The inspector compared selected calibration records with reactor
operations logs and startup and shutdown checklists for the past 18
months. The daily startup checklists typically contained a listing of
portable monitors that were available during reactor operations. The
inspector determined that the instruments that were available and ready
for use in the reactor bay had been calibrated as required.
During the inspection it was noted that the air particulate monitor, which
had not been operational for over a year, had been repaired, calibrated,
and placed back in service. It was also noted that a problem with a
kinked tygon tubing line which led to the constant air monitor had been
corrected through replacement of the tygon tubing with semi-rigid nylon
tubing designed to handle increased air pressure and resist collapsing.
(5)
Radiation Protection and ALARA Programs
The licensees radiation protection and ALARA programs were
established and described in the Reed College Radioactive Materials
Policy and Procedures Manual, dated April 2013, and through associated
SOPs that had been properly reviewed and approved. The programs
contained instructions concerning organization, training, monitoring,
personnel responsibilities, audits, record keeping, and reports. The
ALARA program provided guidance for keeping doses as low as
reasonably achievable and was consistent with the requirements in
10 CFR Part 20. These programs, as established, appeared to be
acceptable.
The inspector determined that the licensee continued to complete annual
reviews of the radiation protection program as required by
The licensee did not require or use a respiratory protection program or
planned special exposure program.
(6)
Radiation Work Permits (RWPs)
The inspector reviewed the RWP program that had been established as
stipulated in RRR SOP 53. It was noted that no RWPs had been issued
in 2012 or as of the date of the inspection in 2013. The controls specified
in previously issued RWPs were generally acceptable and applicable for
- 6 -
the types of work being done. Those RWPs had been initiated, reviewed,
and approved as indicated on the forms.
(7)
Radiation Protection Training
The inspector reviewed the radiation worker training given to RRR staff
members and Reed faculty, to student operators and other students who
worked at the facility, and to other personnel such as maintenance
workers. Each group received different training that was based upon their
duties and activities. Refresher training was conducted every three
years. The training program appeared to be acceptable.
The licensee indicated that radiation worker training for reactor staff
members was given upon initial entry into the RRR program and then
reiterated during operator requalification training. Training records
showed that personnel were acceptably trained in radiation protection
practices.
(8)
Facility Tours and Inspector Observations
The inspector toured the control room, the reactor bay, the mechanical
room, the laboratory room, and the counting room at the facility. Control
of radioactive material was acceptable, as was control of access to
radiation areas.
During the inspection the inspector also visited the calibration range at
the facility and discussed the calibration of survey meters with the RHP.
It was noted that the range had been reconfigured so that the radiation
beam produced by the calibration source was directed at a rear wall. This
was an appropriate application of the ALARA principle. The inspector
concluded that the calibrations of instruments at the facility were
completed using the appropriate techniques and according to procedure.
Proper precautions were in place.
(9)
Radiation Safety Committee (RSC) Meeting Observations
The inspector had the opportunity to attend and observe a Reed College
RSC meeting. It was noted that the appropriate subjects were
addressed.
c.
Conclusion
The inspector determined that the Radiation Protection and ALARA Programs, as
implemented by the licensee, satisfied regulatory requirements because:
(1) postings met regulatory requirements, (2) personnel dosimetry was being
worn as required and recorded doses were well within the NRCs regulatory
limits, (3) surveys and associated checks were completed and documented
acceptably to permit evaluation of the radiation hazards present, (4) radiation
- 7 -
survey and monitoring equipment was being maintained and calibrated as
required, and (5) the radiation protection training program was acceptable.
4.
Environmental Monitoring Program
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 and 4.5:
ROC Audits for 2011-2012 and 2012-2013
Environmental counting and analysis records
Routine surveys and monitoring records for 2012 and 2013
Release calculation records
RRR Administrative Procedures, dated May 2012
RRR SOP 52, Environmental Sampling, dated June 13, 2013
Various other RRR SOPs
RRR Annual Report for the period from July 1, 2011, through June 30,
2012, submitted on August 7, 2012
RRR Annual Report for the period from July 1, 2012 through June 30,
2013, submitted August 7, 2013
b.
Observation and Findings
Environmental soil and water samples were collected, prepared, and analyzed
generally every two months consistent with procedural requirements. Only
naturally occurring radionuclides were detected in the soil samples and no tritium
or carbon-14 were detected in the water samples during 2012 and to date in
2013.
Radiation monitoring inside the reactor bay and outside the facility was
completed using TLDs placed in accordance with the applicable procedures.
The results were reported in the Annual Report as required. No doses above
regulatory limits were noted.
The licensee calculated the airborne activity released to the environment using
data from the continuous air monitor sampling. Licensee records and
calculations indicated that the air emissions of radioactive material to the
environment were well below the 10 millirem constraint specified in
10 CFR 20.1101(d). The inspector found no new potential release paths
following observation of the facility.
The program for the monitoring, storage, or transferring of radioactive liquid,
gases, and solids was consistent with applicable regulatory requirements. The
principles of ALARA were acceptably implemented to minimize radioactive
releases. Records were current and acceptably maintained and indicated that no
radioactive liquid had been released from the reactor facility during 2012 or as of
the date of the inspection in 2013. Monitoring equipment was acceptably
maintained and calibrated as noted previously.
- 8 -
c.
Conclusion
Effluent monitoring satisfied procedural and regulatory requirements and
releases were calculated to be within the specified regulatory and TS limits.
5.
Procedures
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify compliance
with TS Section 6.4:
Selected facility procedures
Procedural implementation and compliance
Recent minor and substantive procedural changes
ROC and RSC meeting minutes for November 2011 through the present
Administrative controls specified in RRR Administrative Procedures,
dated May 2012
RRR SOP 61, Procedure Writing and Use, dated October 6, 2011
b.
Observations and Findings
The inspector noted that facility procedures were no longer being reviewed
biennially by the ROC; that requirement had been removed from the updated TS.
The Facility Director indicated that all procedures are reviewed annually by the
Director and the Reactor Operations Manager. Administrative control of changes
to procedures, and the associated review and approval process, were as
stipulated by RRR SOP 61. Substantive changes to procedures were required to
be reviewed and approved by the ROC. The inspector verified that this was
being done.
Training of personnel on procedures and changes was acceptable. Through
discussions with licensee personnel, the inspector verified that operations and
radiological surveys were conducted in accordance with applicable procedures.
Observation and review also showed that procedures for instrument calibration,
reactor operation, maintenance, and emergency conditions were available as
required.
c.
Conclusion
Facility procedures were acceptably reviewed, approved, and implemented.
- 9 -
6.
Transportation
a.
Inspection Scope (IP 86740)
To verify compliance with 10 CFR 71.5 and procedural requirements for the
transfer or shipment of licensed radioactive material, the inspector reviewed the
following:
Records of radioactive material shipments completed for 2012 and to
date in 2013, including completed NRC Form 540, Uniform Low Level
Radioactive Waste Manifest, Rev. 08-06, completed July 25, 2012
RRR Administrative Procedures, dated May 2012
RRR SOP 54, Waste Handling and Disposal, dated June 13, 2013
RRR SOP 67, Shipping Radioactive Material, dated October 6, 2009
RRR Annual Report for the period from July 1, 2011, through June 30,
2012, submitted on August 7, 2012
RRR Annual Report for the period from July 1, 2012 through June 30,
2013, submitted August 7, 2013
b.
Observations and Findings
Through records reviews and discussions with licensee personnel, the inspector
determined that the licensee had completed one shipment of licensed material
since the last inspection of transportation in December 2011. The shipment
consisted of one drum of solid radioactive waste. The necessary forms
containing the appropriate information were completed as required. Appropriate
procedures were in place for shipping various types of radioactive material.
The inspector noted verified that the licensee individual who was designated as a
shipper had completed the appropriate training to become qualified to ship
radioactive material.
c.
Conclusion
The program for shipping radioactive material satisfied regulatory requirements.
7.
Follow-Up on Technical Specification Violation
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following related to a licensee
report describing a condition contrary to the requirements of 10 CFR 50.54(k)
and TS 6.1.3.
Corrective Action Report 13-01, Key Left in Console, initiated
November 18, 2013
Control room reactor console logbook for the period from May 21-
November 21, 2013
Letter from Reed College to the NRC concerning the event, submitted
- 10 -
November 25, 2013
b.
Observations and Findings
10 CFR 50.54(k) requires that an operator or senior operator licensed pursuant
to 10 CFR Part 55 shall be present at the controls at all times during the
operation of the facility.
TS Section 6.1.3 requires, in part, that the minimum staffing when the reactor is
operating shall be a licensed reactor operator in the control room.
TS Section 1 defines the reactor as operating whenever it is not shut down or
secured.
At approximately 11:00 a.m. (PST), on November 16, 2013, a reactor operator
and a senior reactor operator, along with one other individual, were operating the
reactor to complete a core excess determination. After the completion of a
standard core excess, all rods were driven in to shut down the reactor.
Subsequently, the control room was locked and the three individuals left.
However, the reactor key was inadvertently left in the console and no key out
and secured log entry was made in the console logbook. At approximately
12:11 p.m., on the same day, the Operations Supervisor entered the control
room and noted that the key was in the console, contrary to 10 CFR 50.54(k) and
The licensee investigated the event. It was determined that the key had
apparently been left in the console due to an oversight by the operators (they
were distracted by cleaning activities in the control room), and that this condition
had existed for approximately 71 minutes before being discovered. The control
room was locked the entire time and no one accessed that area until the
Operations Supervisor arrived. The Director and Reactor Operations Manager
also evaluated the problem to determine whether or not it was reportable and
determined that it was a violation of the TS, as well as a violation of 10 CFR
50.54(k). In accordance with TS Section 6.7.2(a), at 4:25 p.m. (EST) on
November 18, 2013, the licensee notified to the NRC Headquarters Operations
Center.
The licensee took a number of corrective actions in response to the violation. A
sign was immediately placed in the control room to remind people to take the key
out following reactor shut down and prior to leaving the control room. The
operators who left the key in the console were given additional training by the
Facility Director before being allowed to operate the reactor again. During the
week of the inspection, the licensee was still considering whether additional
administrative or engineering controls could be developed to prevent recurrence
of the problem.
The inspector reviewed the event. It was noted that the licensee identified the
problem, evaluated the cause, and took some corrective actions. The NRC was
notified as well. The inspector verified that the corrective actions initiated to date
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had been completed by the licensee. However, the inspector noted that a similar
problem had occurred in 2012. Corrective actions from the previous violation
had focused on training for the operators at the facility at the time, but were not
sufficient to prevent recurrence of the issue. As such, the inspector concluded
that this problem was repetitive as a result of inadequate corrective actions from
the previous violation, and that this issue should be treated as a cited violation,
consistent with Section 2.3.2 of the NRC Enforcement Policy.
The licensee was informed that failure to have a licensed operator in the control
room when the key had not been removed from the console was a violation of
the requirements of 10 CFR 50.54(k) and TS Section 6.1.3, and that this issue
represented a Severity Level IV violation (VIO 50-288/2013-201-01).
c.
Conclusions
One violation was identified for not having an operator in the control room while
the reactor was not secured as required.
8.
Follow-Up on Previously-Identified Item
a.
Inspection Scope
The inspector reviewed the licensees actions taken in response to a previously-
identified inspector follow-up item (IFI).
b.
Observation and Findings
IFI 50-288/2011-203-01 (Closed) - Review the results of the elimination of the
facility RHP position, the completion of the RHP duties by staff members and/or
students, and the completion of an annual audit of the Radiation Protection
Program by someone from outside the facility, such as a certified health physicist
(CHP).
Prior to 2011, the radiation protection duties at the facility were completed by
various individuals who were Reed College part-time employees. They filled the
position at the RRR facility designated as the RHP. Recently, after discussions
among Reed College management and staff, it was decided that the RHP
position was not needed and that the College would be better served by having
staff members and/or students complete the radiation protection duties at the
RRR facility. Because the facility TS still required that there be an RHP on
various committees, the Reactor Director was assigned as the interim RHP.
Reed College management also decided that a CHP would be retained once
each year to conduct an audit of the campus radiation protection program. It was
noted that the campus Environmental Director continued to fill both that position
and the position of Radiation Safety Officer for the campus. The licensee was
informed that the elimination of the facility RHP position, the completion of the
RHP duties by staff members and/or students, and the completion of an annual
audit of the radiation protection program by someone from outside the facility,
such as a CHP, would be reviewed during a subsequent inspection.
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During this inspection the inspector reviewed this issue with the licensee. It was
noted that, since the time of the previous inspection, the TS had been revised
and the position of RHP was eliminated. As noted above, the radiation protection
duties at the facility are now completed by various individuals, including the
Reactor Operations Manager and students who were also Reed College part-
time employees. These activities were reviewed and approved by the Facility
Director and the Radiation Safety Officer and were being completed consistent
with regulatory requirements. This IFI is considered closed.
c.
Conclusion
One IFI identified during a previous inspection was reviewed during this
inspection was closed.
9.
Exit Interview
The inspection scope and results were summarized on December 19, 2013, with
members of licensee management. The inspector described the areas inspected and
discussed in detail the inspection findings. No proprietary material was reviewed by the
inspector during the inspection.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
C. Barrett
Reactor Operations Supervisor
K. Fisher
Radiation Safety Officer and Campus Environmental Director
M. Krahenbuhl
Director, Reed Reactor Facility
B. Fairchild
Reactor Operations Manager
N. Nicholson
Dean of the Faculty, Reed College
INSPECTION PROCEDURES USED
IP 69001:
Class II Non-Power Reactors
IP 86740:
Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-288/2013-201-01 VIO
Failure to have a licensed operator in the Control Room when the
key had not been removed from the console was a violation of the
requirements of 10 CFR 50.54(k) and TS Section 6.1.3
Closed
50-288/2011-203-01 IFI
Review the results of the elimination of the facility RHP position,
the completion of the RHP duties by staff members and/or
students, and the completion of an annual audit of the Radiation
Protection Program by someone from outside the facility.
LIST OF ACRONYMS USED
10 CFR
Title 10 of the Code of Federal Regulations
As Low As Reasonably Achievable
CHP
Certified Health Physicist
IFI
Inspector Follow-Up Item
IP
Inspection Procedure
NRC
U.S. Nuclear Regulatory Commission
Optically-Stimulated Luminescent (dosimeter)
RHP
Reactor Health Physicist
Reactor Operations Committee
RRR
Reed Research Reactor
Radiation Safety Committee
Radiation Work Permit
Standard Operating Procedure
Thermoluminescent Dosimeter
TS
Technical Specification