ML16349A652
| ML16349A652 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 12/21/2016 |
| From: | Anthony Mendiola Research and Test Reactors Oversight Branch |
| To: | Krahenbuhl M Reed College |
| Bassett C | |
| References | |
| IR 2016202 | |
| Download: ML16349A652 (31) | |
See also: IR 05000288/2016202
Text
December 21, 2016
Dr. Melinda Krahenbuhl, Director
Reed Reactor Facility
Reed College
3203 S.E. Woodstock Boulevard
Portland, OR 97202-8199
SUBJECT: REED COLLEGE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE
INSPECTION REPORT NO. 50-288/2016-202 AND NOTICE OF VIOLATION
Dear Dr. Krahenbuhl:
From October 31 to November 3, and November 28 to December 2, 2016, the U.S. Nuclear
Regulatory Commission (NRC or the Commission) completed an inspection at the TRIGA
Mark-I Reed Research Reactor facility. The enclosed report documents the inspection results,
which were discussed on November 2, 2016, with you, Dr. Nigel Nicholson, Dean of the Faculty,
and Christina Barrett, Reactor Operations Manager, and on December 1, 2016, with you and
Dr. Nicholson.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities in progress, and
interviewed various personnel.
Based on the results of this inspection, the NRC has determined that two Severity Level IV
violations of NRC requirements occurred. The violations were evaluated in accordance with the
NRC Enforcement Policy, which can be found on the NRCs Web site at www.nrc.gov by
selecting What We Do, Enforcement, and then Enforcement Policy. The violations are
cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are
described in detail in the subject inspection report. The violations are being cited in the Notice
because they constitute the failure to meet regulatory requirements that have more than minor
safety significance and they were identified by the NRC.
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 part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
In addition, based on the results of this inspection, the NRC has determined that one other
Severity Level IV violation of NRC requirements occurred. This violation is being treated as a
non-cited violation (NCV), consistent with Section 2.3.2.b of the Enforcement Policy. The NCV
is described in the subject inspection report. If you contest the violation or significance of the
NCV, you should provide a response within 30 days of the date of this inspection report, with the
basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington DC 20555-0001, with copies to the Director, Office of Enforcement, United States
Nuclear Regulatory Commission, Washington, DC 20555-0001.
M. Krahenbuhl -2-
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public
inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your
response (if any) will be available electronically for public inspection in the NRC Public
Document Room or from the NRCs document system (Agencywide Documents Access and
Management System (ADAMS)). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, please contact Craig Bassett at
301-466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Anthony J. Mendiola, 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
Enclosures:
1. Notice of Violation
2. NRC Inspection Report
No. 50-288/2016-202
cc: See next page
Reed College Docket No. 50-288
cc:
Mayor of City of Portland
1220 Southwest 5th Avenue
Portland, OR 97204
Dr. Nigel Nicholson, Dean of Faculty
Reed College
3203 S.E. Woodstock Boulevard
Portland, OR 97202-8199
Mr. John Kroger, President
Reed College
3203 S.E. Woodstock Boulevard
Portland, OR 97202-8199
Division Administrator
Nuclear Safety Division
Oregon Department of Energy
625 Marion Street, N.E.
Salem, OR 97310-3737
Program Director
Radiation Protection Services
Public Health Division
Oregon Health Authority
800 NE Oregon Street, Suite 640
Portland, OR 97232-2162
Test, Research, and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
ML16349A652; *concurrence via e-mail NRC-002
OFFICE NRR/DPR/PROB* NRR/DPR/PROB* NRR/DPR/PROB
NAME CBassett NParker AMendiola
DATE 12/16/16 12/16/16 12/21/16
NOTICE OF VIOLATION
Reed College Docket No. 50-288
Reed Research Reactor License No. R-112
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from October 31 to
November 3, 2016 and from November 28 to December 2, 2016, two violations of NRC
requirements were identified. In accordance with the NRC Enforcement Policy, the violations
are listed below:
1. Reed Research Reactor Technical Specification (TS) Section 3.2.2 requires that the
reactor shall not be operated unless the reactor power measuring channels in Table 2
are operable. Table 2 lists the Percent Power Channel, the Linear Channel, and the
Logarithmic Channel.
Contrary to this requirement, from October 6 to October 16, 2016, the reactor was
operated or attempted to be operated when the Logarithmic Channel was not operable.
This has been determined to be a Severity Level IV violation (Section 6.1).
2. Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests, and
experiments, paragraph (c)(1) states, in part, that a licensee may make changes in the
facility as described in the final safety analysis report without obtaining a license
amendment pursuant to 10 CFR 50.90 only if: (i) a change to the technical
specifications incorporated in the license is not required, and (ii) the change does not
meet any of the criteria in 10 CFR 50.59(c)(2).
The regulation in 10 CFR 50.59(c)(2) requires, in part, that a licensee shall obtain a
license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change
if the change would: (i) result in more than a minimal increase in the frequency of
occurrence of an accident previously evaluated in the final safety analysis report;
(ii) result in more than a minimal increase in the likelihood of occurrence of a malfunction
of a structure, system, or component (SSC) important to safety previously evaluated in
the final safety analysis report; (iii) result in more than a minimal increase in the
consequences of an accident previously evaluated in the final safety analysis report;
(iv) result in more than a minimal increase in the consequences of a malfunction of an
SSC important to safety previously evaluated in the final safety analysis report; (v)
create a possibility for an accident of a different type than any previously evaluated in
the final safety analysis report; (vi) create a possibility for a malfunction of an SSC
important to safety with a different result than any previously evaluated in the final safety
analysis report; (vii) result in a design basis limit for a fission product barrier as
described in the FSAR being exceeded or altered; or (viii) result in a departure from a
method of evaluation described in the FSAR used in establishing the design bases or in
the safety analyses.
The regulation in 10 CFR 50.59(d)(1) requires, in part, that the licensee shall maintain
records of changes in the facility made pursuant to 10 CFR 50.59(c). These records
Enclosure 1
-2-
must include a written evaluation which provides the bases for the determination that the
change does not require a license amendment pursuant to 10 CFR 50.59(c)(2).
The Reed Research Reactor safety analysis report (SAR) states in Chapter 7,
Section 7.2.3.3, that the Percent Power channel has an associated Uncompensated Ion
Chamber that provides indication for that channel.
Contrary to the above requirements, on October 5, 2016, the licensee made a change to
the facility as described in the SAR without conducting an evaluation to determine
whether or not the change would require a change to the TSs or should have required a
license amendment. Specifically, the licensee replaced the detection chamber
associated with the Percent Power channel with a fission chamber which was not as
described in the SAR without performing an evaluation of the change using the criteria in
10 CFR 50.59(c)(1) and (2) to determine if the change would require a change to the
TSs or should have required a license amendment.
This has been determined to be a Severity Level IV violation (Section 6.1).
Pursuant to the provisions of 10 CFR 2.201, Notice of violation, 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 for each violation: (1) the reason for each 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 previously
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 Publicly Available Records component of the NRCs
Agencywide Documents Access and Management 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
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). 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, Public inspections, exemptions,
-3-
requests for withholding, paragraph (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,
Protection of Safeguards Information: Performance Requirements.
In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post
this Notice within two working days.
Dated this 21st day of December
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No. 50-288
License No. R-112
Report No. 50-288/2016-202
Licensee: Reed College
Facility: Reed Research Reactor
Location: Portland, Oregon
Dates: October 31, 2016 - November 3, 2016
November 28, 2016 - December 2, 2016
Inspector: Craig Bassett
Accompanied by: Michele DeSouza, Examiner
John Nguyen, Examiner
Michael Takacs, Security Specialist
Approved by: Anthony J. Mendiola, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Enclosure 2
EXECUTIVE SUMMARY
Reed College
Reed Research Reactor Facility
NRC Report No. 50-288/2016-202
The primary focus of this routine, announced inspection included onsite review of selected
aspects of the Reed College (the licensee) Class II research reactor safety program. This
included a review of: (1) organization and staffing, (2) review and audit and design change
functions, (3) conduct of operations, (4) operator requalification program, (5) fuel handling,
(6) maintenance and surveillance, (7) procedures, (8) experiments, and (9) emergency
preparedness. The licensees program was acceptably directed toward the protection of public
health and safety. Two apparent Severity Level IV violations and one Severity Level IV
non-cited violation were identified.
Organization and Staffing
The organization and staffing remain in compliance with the requirements specified in
Technical Specification (TS) Section 6.1.
Review and Audit and Design Change Functions
Review and oversight functions required by TS Section 6.2 were acceptably completed by
the Reactor Operations Committee. Audits were being completed as required.
The design change program being implemented at the facility generally satisfied Nuclear
Regulatory Commission requirements.
Conduct of Operations
Operations were generally being conducted in accordance with TS and procedural
requirements.
Two apparent violations and one non-cited violation were identified involving the nuclear
measuring channels of the reactor.
Operator Requalification Program
The operator requalification/training program was up-to-date and being acceptably
implemented and documented.
Biennial medical examinations were being completed as required.
A one-time Alternate Requalification Plan was initiated due to the problems created by
malfunctioning nuclear instrumentation.
-2-
Fuel Handling
Reactor fuel movements and inspections were conducted and documented in accordance
with procedure.
Twenty-five percent of the fuel elements were being inspected on an annual basis.
Maintenance and Surveillance
Maintenance was being completed as needed.
The surveillance program, including calibration of equipment, was being completed in
accordance with TS Sections 3 and 4.
Procedures
Facility procedures were available for the safe operation of the reactor as required by
Experiments
The program for the control of experiments satisfied TS Sections 3.6, 4.6, and 6.5 and other
regulatory requirements.
The Emergency Plan (E-Plan) and Emergency Implementation Procedures were being
audited and reviewed annually as required.
Letters of Agreement documenting emergency support to be provided by offsite agencies
were being maintained and periodically updated.
Annual drills were being held and documentation of the drills and the follow-up critiques was
maintained. Subsequent corrective actions were taken as needed.
Emergency preparedness training for staff and offsite personnel was being conducted as
stipulated in the E-Plan.
REPORT DETAILS
Summary of Facility Status
The Reed College (the licensees) 250 kilowatt TRIGA Mark I research reactor was typically
operated in support of undergraduate instruction, laboratory experiments, reactor system
testing, reactor surveillances, and operator training. During this inspection the reactor was not
operated due to nuclear instrumentation issues.
1. Organization and Staffing
a. Inspection Scope (Inspection Procedure (IP) 69001)
To verify the organization and staffing requirements specified in technical
specifications (TSs) Section 6.1 were being met, the inspector reviewed selected
aspects of the following:
Main (Reactor Console) Log - Numbers (Nos.) 86 - 89
Reed Research Reactor (RRR) facility organization and staffing during
reactor operations
Administrative controls and management responsibilities specified in the TS
and facility procedures
RRR Administrative Procedures, Section 1, Personnel, and Section 3,
Reactor Operations
RRR Standard Operating Procedure (SOP) 60, Logbook Entries
RRR Annual Report for the period from July 1, 2014, through
June 30, 2015, submitted to the U.S. Nuclear Regulatory Commission (NRC)
on August 7, 2015
RRR Annual Report for the period from July 1, 2015, through
June 30, 2016, submitted to the NRC on July 27, 2016
b. Observations and Findings
Through discussions with licensee representatives, the inspector determined that
management responsibilities and the organizational structure at the RRR facility
had not changed since the previous NRC inspection of licensee operations in
December 2014 (Inspection Report No. 50-288/2014-202). The inspector
determined that the Facility Director retained direct control and overall
responsibility for management of the facility as specified in the TS. The Facility
Director reported to the President of Reed College through the Dean of Faculty.
This organization was consistent with that specified in the TS.
It was noted that since the last operations inspection in 2014, a new person had
been hired to be the Reactor Operations Manager. Also, a new person had been
hired to fill the position of campus Radiation Safety Officer/Director of
Environmental Health and Safety.
-2-
The licensees current operational organization consisted of the Facility Director,
a Reactor Operations Manager, a Radiation Safety Officer, an Operations
Supervisor, a Training Supervisor, an Assistant Training Supervisor, a Projects
Supervisor, and a Requalification Supervisor. The Facility Director, Reactor
Operations Manager, and Radiation Safety Officer positions were full-time while
the rest were part-time positions filled by students. Except for the Radiation
Safety Officer, the aforementioned individuals, in addition to their administrative
duties, were qualified reactor operators (ROs) or senior reactor operators
(SROs). It was noted that there were a total of 20 SROs and 19 ROs licensed to
operate the RRR.
c. Conclusion
Organization and staffing met the requirements specified in TS Section 6.1.
2. Review, Audit, and Design Change Functions
a. Inspection Scope (IP 69001)
In order to verify that the licensee had established and conducted reviews and
audits as required, and to determine whether facility modifications and change
reviews were consistent with Title 10 of the Code of Federal Regulations
(10 CFR) Section 50.59, Changes, tests and experiments, and TS Section 6.2,
the inspector reviewed selected portions of the following:
Maintenance Log pages completed for unscheduled work
Corrective Action Reports (CARs) for 2015 and to date in 2016
Design changes reviewed under 10 CFR 50.59 for 2015 and 2016
Reactor Operations Committee (ROC) meeting minutes from
October 2014 through the present
RRR Administrative Procedures, Section 1, Personnel; Section 2, Reactor
Review Committee; and Section 9, Record Retention
RRR SOP 62, Changes, Tests, and Experiments, and SOP 69, Corrective
Action Report; and associated forms, Corrective Action Reports; last
revised August 26, 2014
RRR Annual Reports for the last two reporting periods
b. Observations and Findings
(1) Review and Audit Functions
The inspector reviewed ROC meeting minutes from October 2014
through the present. These meeting minutes showed that the committee
was meeting at the required frequency and was considering the types of
topics outlined by the TS.
The inspector noted that, since the last NRC inspection, the appropriate
audits had been completed by the ROC and an external auditor in the
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various areas outlined in the TS. The audits were designed so that most
aspects of the licensees operations and safety programs were reviewed
every year. Various facility documents, such as the Radiation Protection
Program, the Emergency Plan (E-Plan), the Fire Plan, the Administrative
Procedures, and the Requalification Plan comprised the material that was
typically reviewed. The Reactor Experiments and various SOPs were
also reviewed. The inspector noted that the audits and the resulting
findings were detailed and that the licensee responded and took
corrective actions as needed.
(2) Design Changes
The inspector reviewed the licensees 10 CFR 50.59 screening forms
concerning changes or modifications that had been initiated at the facility
for 2015 and to date in 2016. The results indicated that none of the
screenings required further evaluation under 10 CFR 50.59. The
inspector also reviewed the Maintenance Log pages that had been
completed for unscheduled work associated with various systems. The
forms contained a section which required a 50.59 Screen to be completed
prior to initiating the work. None of the maintenance items reviewed
required any further actions, such as a 50.59 evaluation, to be completed
except as noted in Part 3, Section (3) below. None of the other changes
reviewed by the inspector met any of the criteria of 10 CFR 50.59(c)(1)
and (2), which would have required a TS change or a license amendment
from the NRC.
c. Conclusion
Review and oversight functions required by TS Section 6.2 were acceptably
completed by the ROC. Audits were being completed as required. The
licensees design change program generally satisfied NRC requirements.
3. Conduct of Operations
The inspector reviewed selected aspects of the following to verify operation of the
reactor in accordance with TS Sections 3, 4, and 6.1:
a. Inspection Scope (IP 69001)
Main (Reactor Console) Log Nos. 86 - 89
Various SCRAM Response Forms for 2015 and 2016
CARs for 2015 and to date in 2016
Maintenance Log pages completed for unscheduled work
Selected Startup Checklist Forms for the period from January 2015 through
the present
Selected Shutdown Checklist Forms for the period from January 2015
through the present
RRR Administrative Procedures, Section 3, Reactor Operations
-4-
Various RRR SOPs and Appendices including SOP 1, Reactor Operations;
SOP 20, Startup Checklist; SOP 20, Appendix A, Startup Checklist Form;
SOP 21, Same Day Startup Checklist; SOP 21, Appendix A, Same-Day
Startup Checklist Form; SOP 22, Shutdown Checklist; SOP 22,
Appendix A, Shutdown Checklist Form; SOP 23, Biweekly Checklist; SOP
23, Appendix A, Biweekly Checklist Form; SOP 24, Bimonthly Checklist;
SOP 24, Appendix A, Bimonthly Checklist Form; SOP 25, Semiannual
Checklist; SOP 25, Appendix A, Reed Research Reactor Semiannual
Checklist; SOP 26, Annual Checklist; SOP 26, Appendix A, Annual
Checklist Form; SOP 33, Nuclear Instruments; SOP 34, Control Rods;
SOP 60, Logbook Entries; and, SOP 69, Corrective Action Report
RRR Annual Reports for the last two reporting periods
b. Observations and Findings
(1) Routine Operations
The inspector reviewed selected reactor operating records from
January 2015 through the present. These records included daily Startup
Checklists, Shutdown Checklists, Experimental Startup and Shutdown
Checklists, associated forms, Weekly Checklists, and the Main (reactor
console) Logs. The records indicated that the activities were generally
carried out in accordance with written procedures as required by TS Section 6.4, except as noted below. The checklists were completed and
signed off by the appropriate personnel as required.
Through interviews with operators and review of logs and records, the
inspector confirmed that shift staffing met the minimum requirements for
duty and on-call personnel as required by TS Section 6.1.
Information on the operational status of the facility was generally recorded
properly on the log sheets and/or checklists as required by procedure.
Scrams were identified in the logs and were reported and resolved as
required before reactor operations were allowed to continue. However, it
was noted that the logs were not totally complete in that they did not
indicate who authorized operations to resume. The inspector indicated
that the complete documentation of reactor operations should include not
only when and why a scram occurred, but who gave the authorization to
resume operations as well. The licensee was informed that the issue of
complete and accurate documentation of scram events and other
operational events would be designated by the NRC as an Inspector
Follow-up Item (IFI) and would be reviewed during future inspections
(IFI 50-288/2016-202-01).
-5-
(2) NRC-Identified Violation of TS Section 3.2.2
TS Section 3.2.2 requires that the reactor shall not be operated unless
the reactor power measuring channels in Table 2 are operable. Table 2
lists the Percent Power Channel, the Linear Channel, and the Logarithmic
Channel.
On May 28, 2016, the licensee discovered that the facility reactor pool
had overflowed due to a malfunction of the recently installed automatic fill
system. On May 30, 2016, operators noticed that all reactor trips were
illuminated. Because of this, the reactor was determined to be inoperable
due to electronics problems. In mid-June, some of the electronic
components of the power measuring channels, including the Logarithmic
Channel pre-amp and the Percent Power Channel High Voltage (HV)
power supply, were removed and taken to Oregon State University (OSU)
by the electronics specialist from OSU where he worked to correct the
problems. It was noted that the Linear Channel was not found to have
been damaged.
During August 8 and 9, the OSU electronics specialist came to Reed
College and installed the repaired pre-amp and HV power supply for the
Log and Percent Power channels. After the electronics were installed,
the licensee determined that the detector chambers associated with the
Percent Power and Logarithmic Channels were not functioning properly.
Licensee personnel then removed the assemblies for each channel from
the reactor pool and began the process of trying to dry out the detectors.
On October 5, after the channel detectors were thought to be completely
dry, the electronics specialist from OSU again came to Reed College to
help test and reinstall the power channels. At that point the Log channel
was determined to be functional but the Percent Power Channel shorted
out and was not functional. Upon further investigation, the licensee found
that the detector associated with the Percent Power Channel was not an
UIC as stipulated in the SAR but a fission chamber operating in current
mode. Because that fission chamber was not functioning, licensee staff
and the OSU electronics specialist installed a spare fission chamber (one
that Reed had on hand) with the Percent Power Channel to see if it would
operate. The channel appeared to be functioning properly and appeared
to be giving the expected signals.
The following day, October 6, licensee staff attempted to adjust the
detectors and conduct a core excess and power calibration of the reactor.
Although the power channels appeared to be working properly, the
Percent Power Channel had repeated HV scrams. Licensee staff found a
loose wire and corrected that problem. During the next few days licensee
staff adjusted the Linear Power and Percent Power detector positions to
adjust for power calibration. However, another HV Percent Power scram
occurred, the cause of which could not be explained.
-6-
On October 13, channel testing continued and core excess
measurements were again attempted but to no avail and the
Percent Power Channel was determined to be non-functional. On
October 14, the OSU electronics specialist returned to Reed and installed
a spare UIC (one that OSU had received from another university) to
operate in the Percent Power Channel. On October 16, the licensee
completed core excess and reactor power calibrations. They operated up
to 150 kilowatt (kW) for training and operator requalification.
Two days later operations were conducted for requalification but the
Log channel was determined to be erratic, possibly due to electronic
noise. Because the reactor had been operated for over an hour with a
non-functional Logarithmic Channel, the reactor was scrammed. At that
point, the Reactor Operations Manager declared the problem as an event
and a report was made to the NRC (see Section (4) below). When the
licensee investigated the problem, it was believed that the problem was
due to an electronics noise problem. After disconnecting, testing, and
reconnecting the channel, they thought the problem (the noise issue) with
the Logarithmic Channel was corrected. The following day, October 19,
the Logarithmic Channel was tested and determined to be functional.
Core excess measurements were completed and the reactor was
operated for requalification of operators. An inadvertent scram occurred
but this was caused by operator error and operations were allowed to
continue.
Because most of the student operators were out of qualification
(due to the continuing problems with the nuclear instruments NI
channels), reactor operations continued and were conducted on various
occasions for requalification but problems persisted. Core excess
measurements were completed each day and other activities were
attempted such as measuring Regulating Rod worth. The licensee also
completed Shim and Safety rod worth measurements but problems kept
occurring with the Logarithmic Channel. On October 21, the licensee
determined that the Logarithmic Channel detector was apparently working
properly but the electronics were not. At that point the reactor was
declared non-operational. The reactor has not been operated since that
date.
The NRC reviewed the issues associated with the reactor power
measuring channels. From October 6-16, licensee staff operated the
reactor up to 150 kW for training and requalification. (It was noted that
after October 16, the reactor was only operated at a power level of
5 watts (W) or less.) During that period when operating at 150 kW, the
Linear Channel typically read 60 percent, the Percent Power Channel
typically read 60 percent, but the Logarithmic Channel was reading from
90 to 100 percent. The inspector reviewed the console logs for the past
two years. For that time frame, when operating at 150 kW, the Linear
Channel typically read 60 percent, the Percent Power Channel typically
read 60 percent, and the Logarithmic Channel typically read 60 percent.
-7-
Therefore, from October 6 through 16, the Logarithmic Channel was not
reading correctly because it was reading high and over responding,
probably indicating that the channel detector was shorted out. The NRC
concluded that the Logarithmic Channel was not operating properly and
thus was not operational during this period. The licensee was informed
that failure to have an operable Logarithmic Channel during reactor
operation was an apparent violation of TS Section 3.2.2 (violation (VIO)
50-288/2016-202-02).
(3) NRC-Identified Violation of Regulatory Requirements
The RRR safety analysis report (SAR) states in Chapter 7, Section
7.2.3.3, that the Percent Power Channel has an Uncompensated Ion
Chamber that provides indication for that channel.
Regulation in 10 CFR 50.59 requires that licensees evaluate a change
from what was described in the SAR to ensure that a TS change or a
license amendment was not required in accordance with 10 CFR 50.59
pargraphs (c)(1)(i and ii) and (c)(2)(i-viii).
As noted above, the licensee had been experiencing various problems
with the reactor power measuring channels. Because of these problems,
the licensee tried repeatedly to make adjustments to the channel
electronics and the positions of the associated detectors. On
October 6, 2016, licensee staff attempted to adjust the detectors and
conduct a core excess and power calibration of the reactor. Although the
power channels appeared to be working properly, the Percent Power
Channel had repeated HV scrams. Licensee staff found a loose wire and
corrected that problem but other problems persisted. Finally on
October 14, the OSU electronics specialist returned to Reed and installed
a spare UIC (one that OSU had received from another university) into the
Percent Power Channel. Licensee staff conducted a core excess
measurement and performed testing of the electronics using the reactor
at various power levels.
The NRC reviewed this situation and the problems with the Percent
Power Channel. As stated above, it was noted that the licensee was not
aware that the detector associated with the Percent Power Channel was
a fission chamber (and not a UIC as stated in the SAR) prior to
October 5, 2016. However, following that date, the licensee was fully
aware of the situation. Nevertheless, the decision was made to replace
the existing fission chamber with a spare fission chamber that the
licensee had on hand.
-8-
A fission chamber was not what the SAR stipulated as the detector to be
operated with the Percent Power Channel. No attempt was made to
conduct a 10 CFR 50.59 review as to whether or not such a detector
should be used with the Percent Power Channel. The licensee was
informed that failure to conduct a review in this situation was an apparent
violation of 10 CFR 50.59 requirements (VIO 50-288/2016-202-03).
(4) Self-Reported Violation of the Requirements of TS Section 3.2.2
Section 3.2.2 of the RRR technical specifications requires that the reactor
shall not be operated unless the reactor power measuring channels in
Table 2 are operable. Table 2 lists the Percent Power Channel, the
Linear Channel, and the Log Channel.
On October 18, 2016, a licensed reactor operator and another person
operating under the operators direction completed the Start Up Checklist
had checked out properly and appeared to be functioning normally.
They then inserted the key and began a check out of the reactor NIs prior
to full power operation. They conducted the excess reactivity surveillance
test at a power level below 5 W.
About an hour after the key was inserted into the console, the Reactor
Operations Manager entered the Control Room and noted that one of the
NIs, the Log channel was not tracking correctly, i.e., the Log channel was
reading a constant number and not tracking with the power level. The
reactor was immediately scrammed and secured.
The three individuals then began to investigate the problem and diagnose
what had happened. Analysis showed that the Log channel pre-amp was
picking up excessive noise due to its close proximity to other electrical
components. Also, upon further investigation, a ground wire was found
detached from its proper connection.
The loose ground wire was replaced and a test of the pre-amp was
initiated. Testing of the pre-amp on a platform away from interference
from other electronics indicated that it was then functioning properly.
Under these corrected conditions, the Log channel was tested and the
reading appeared to return to normal. However, reactor operations were
suspended until the channel could be more thoroughly tested. A CAR
was initiated to document the issue. The NRC was notified of the event
on October 19, 2016.
The NRC reviewed this issue and discussed the self-identified TS
violation with the licensee and interviewed various reactor staff personnel.
The NRC confirmed that the licensee had, in fact, been in violation of
TS Section 3.2.2. The circumstances of the event and the notifications
were reviewed.
-9-
The inspector verified that the licensee had taken what they thought were
appropriate corrective actions once the issue was identified. Corrective
actions included immediately shutting down the reactor, investigating the
problem and making the repairs that they thought would repair the
channel. Following repairs and discussion of the issue with the Reactor
Director, the reactor was placed back in operation.
The licensee was informed that the failure to have all of required channels
operable during reactor operation was a Severity Level IV violation of
TS Section 3.2.2. However, the safety consequences were low because
the reactor was operated at a power level less than 5 W and 2 of the 3
required channels were operable to provide any required reactor scram.
The inspector determined that this particular problem had been identified
by the licensee and promptly reported to the NRC. What the licensee
thought were adequate corrective actions had been identified and
implemented. As a result, the licensee was informed that this issue would
be treated as a NCV, consistent with Section VI.A.8 of the NRC
Enforcement Policy (NCV 50-288/2016-202-04).
This issue is considered closed.
(5) Reactor Pool Overfill Problem
As noted above, near the end of May, the licensee found that the reactor
pool had overflowed. Upon investigation the licensee found that the
problem had occurred due to a malfunction of the recently installed
automatic fill system. In the past, as part of a weekly checklist, staff
members were tasked with checking the pool level and adding water if the
pool level dropped below a certain mark. However, on occasion, the staff
members forgot to shut the fill water off and the tank was nearly over
filled. To correct that problem, under the auspices of the 10 CFR 50.59
program, the licensee installed an automatic fill control system.
Unfortunately, the automatic system failed on May 28, 2016, and the pool
overfilled to the point that water entered the nuclear instrumentation tubes
leading to the detectors. The Percent Power channel and the Log
Channel were affected; the Linear Channel was not damaged.
The overfill caused problems that persisted with the two affected
channels from June through October (as noted above). The licensee was
informed that the issue of correcting the overfill problem would be
designated by the NRC as an IFI and would be reviewed during future
inspections (IFI 50-288/2016-202-05).
- 10 -
c. Conclusion
Reactor staffing, operations, and logs were generally acceptable. One apparent
violation was identified for operating the reactor without the logarithmic channel
being operable as required by TS Section 3.2.2. One apparent violation was
identified for failure to conduct a 10 CFR 50.59 review. One non-cited violation
was identified for operating the reactor without the logarithmic channel being
operable as required by TS Section 3.2.2.
4. Operator Requalification Program
a. Inspection Scope (IP 69001)
The inspector reviewed selected portions of the following regarding the RRR
Requalification Plan to ensure that the requirements of the plan and
10 CFR 55.59, Requalification, were being met:
Main (Reactor Console) Log Nos. 86 - 89
Active license status of all current operators
Medical examination records for selected operators
RRR Facility Requalification Program, dated July 2009
RRR Facility Alternate Requalification Plan, dated September 2016
Training lectures and records for the current training cycle
NRC Form 398, Personal Qualification Statement - Licensee
Written examinations given during 2014 and 2015 for selected operators
RRR Facility Requalification Plan, dated July 2009
NRC Form 396, Certification of Medical Examination - by Facility Licensee
RRR Facility Requalification Meeting Agenda and Attendance Sheets for
September 2014 through the present
Requalification Hours and Reactivity Manipulation Sheets documenting
reactivity manipulations for 2014 through the present for selected operators
RRR Administrative Procedures, Section 9, Record Retention
Various RRR SOPS including: SOP 63, Requalification; SOP 63 Appendix
A, Reactor Operator Physical Exam; and SOP 63,
Appendix B, Accelerated Requalification Form
b. Observations and Findings
(1) Routine Requalification Program - For the Period 2014 through
June 2015 and for July 2015 through June 2016
As noted previously, there are currently 20 qualified SROs and
19 qualified ROs at the RRR facility. The inspector reviewed selected
operators licenses and noted that they were current.
- 11 -
The inspector reviewed the requalification program for July 2014 through
June 2015, and for July 2015 through June 2016, as well as the annual
drill scenarios and attendance sheets. It was noted that operators
typically made entries on the Requalification Hours and Reactivity
Manipulation Sheet that was located in the control room. Through these
actions the hours on duty and in what capacity (i.e., RO/SRO), as well
as the tasks performed, were documented. The inspector also reviewed
the Requalification Meeting Agenda and Attendance Sheets for the period
from September 2014 through the present. The inspector reviewed
various individual operators requalification records as well.
The review of the various logs and records noted above showed that
training had been conducted in accordance with the licensees
requalification and training program until May 2016. Training reviews and
examinations had been completed and documented as required. The
records indicated that operators were completing the required activities,
including reactivity manipulations and number of operating hours.
Records indicated that annual operations tests and supervisory
observations were being completed. Biennial written examinations were
also being completed as required or credit was taken by the licensee for
the exams administered by the NRC to satisfy the requalification cycle
exam requirements when applicable. Additionally, the inspector noted
that operators were receiving the required biennial medical examinations
within the required time frame.
(2) Alternate Requalification Plan - For the period from July 2016 until the
Reactor is Operational
As noted in Section 3 of this report, the RRR has been functional and
operational only sporadically since May 2016. Because of this problem,
operators have not been able to complete the operational requirements to
remain fully qualified. The licensee recognized this and proposed an
alternate requalification plan to the NRC in September. The alternate
plan was reviewed and subsequently approved.
The Alternate Requalification Plan stipulated that two Reed College
SROs would go to the OSU research reactor facility and complete two
hours of reactor operation under direction of OSU personnel and two
hours of supervision of the other Reed College operator. These two
individuals would also complete one reactivity manipulation each while at
OSU as well. This would suffice for the reactor operation requirements of
the Reed Requalification Program and allow the two operators to return to
Reed College and observe Reed operators to operate under their
direction.
For the remainder of the operators at Reed who did not go to OSU and
were out of qualification, the alternate plan required that each operator
complete three hours of reactor operation and two reactivity
manipulations under direction of one of the SROs who went to OSU.
- 12 -
In addition, these operators would then need to meet the routine Reed
Requalification Program requirements of four hours of reactor operation
and two reactivity manipulations for the quarter. If any licensed
individuals were not in compliance with other requirements outlined in
10 CFR 55.59, the operators would be required to meet the requirements
of 10 CFR 55.53, Conditions of licenses, paragraph (f)(2) of six
additional hours of operation under direction.
The inspector reviewed the actions of the licensee to comply with the
requirements of the Alternative Requalification Plan. The inspector
verified that the two SROs who went to OSU had completed the required
hours of operation and the required reactivity manipulations. They then
returned to Reed and began observing other operators. It was noted that
4 SROs and 2 ROs had completed the requirements of the alternate
requalification plan. However, it was also noted that only two SROs
would be in compliance with the Routine Requalification Program if the
Reed reactor remains shut down through the end of December (the end
of the quarter). The licensee acknowledged that, if the reactor remains
shut down through the end of the quarter, all operators who are not in
compliance with the requalification program requirements will have to
complete the Alternate Requalification Plan requirements as well as the
regular Reed Requalification Program requirements before being
considered qualified to operate the reactor.
(3) Access to the Reed Research Reactor Facility (RRRF) Controlled Access
Area
As noted above, the inspector reviewed the Reed Routine Requalification
Program. During records review it was found the Reed Operations
Manager was approving individuals access to the facility Controlled
Access Area (CAA), i.e., signing the access forms. Only the NRC
approved reviewing official may grant unescorted access to the facility in
accordance with 10 CFR 73.57, Requirements for criminal history
records checks of individuals granted unescorted access to a nuclear
power facility, a non-power reactor, or access to Safeguards Information,
paragraph (g). The NRC approved reviewing official is the RRRF
Director as indicated in a letter from the NRC to the licensee. The
licensee was informed that only the NRC approved reviewing official is
authorized to approve individuals access. Any changes or request for
changes must be submitted to the NRC for evaluation.
Because the decision to grant unescorted access to the CAA of the
facility was always discussed between, and approved by, both the
Director and the Reactor Operations Manager, the Director subsequently
countersigned all the access forms. The licensee agreed that only an
approved Reviewing Official would sign the access forms in the future.
- 13 -
c. Conclusion
The requalification/training program was up-to-date and being acceptably
maintained. Medical examinations were being completed biennially as required.
5. Fuel Handling
a. Inspection Scope (IP 69001)
In order to verify adherence to fuel handling and inspection requirements
specified in TS Section 4.1, the inspector reviewed selected aspects of the
following:
Fuel Element Inspection Cards
Main (Reactor Console) Log Nos. 86 - 89
Fuel Element Inspection sheet maintained in the appropriate Fuel Inspection
Binder
RRR Administrative Procedures Section 6, Fuel and Special Nuclear
Material
Various RRR SOPs including: RRR SOP 35, Fuel and Core; SOP 35,
Appendix A, Core Diagram; SOP 35, Appendix B, Fuel Handling
Checklist; SOP 35, Appendix C, Fuel Handling SRO Qualification; and
SOP 35, Appendix D, Fuel Handling Receipt Form
b. Observations and Findings
Through review of the main logs and interviews with licensee personnel, the
inspector verified that fuel movements were conducted in compliance with
procedure. The inspector also verified that the licensee was maintaining the
required records of fuel movements as they were completed. The logs were
being filled out properly to indicate which elements were moved and to what
locations.
Also through records review, it was noted that the reactor fuel was being
inspected upon initial receipt and 25 percent of the fuel elements in the core were
being inspected annually. This exceeded the percentage of fuel elements
required to be inspected as stipulated by TS Section 4.1. The last annual fuel
inspection was completed during January 11-27, 2016. The inspector verified
that all fuel elements were inspected at least once every 5 years, including
elements in storage and/or removed from service as required.
c. Conclusion
Reactor fuel movements and inspections were completed and documented in
accordance with procedure and the fuel was being inspected more frequently
than required by TS Section 4.1.
- 14 -
6. Maintenance and Surveillance
a. Inspection Scope (IP 69001)
To verify that operations, surveillance activities, and calibrations were being
completed as required by the TS, the inspector reviewed selected portions of:
Main (Reactor Console) Log Nos. 86 - 89
Maintenance Log pages completed for unscheduled work
Associated surveillance and calibration data and records for 2015-2016
Other Checklists Notebook which contained calibration forms, inspection
forms, and various checklists
Various RRR SOPs and Appendices including: SOP 23, Biweekly Checklist;
SOP 23, Appendix A, Biweekly Checklist Form; SOP 24, Bimonthly
Checklist; SOP 24, Appendix A, Bimonthly Checklist Form; SOP 25,
Semiannual Checklist; SOP 25, Appendix A, Reed Research Reactor
Semiannual Checklist; SOP 26, Annual Checklist; SOP 26, Appendix A,
Annual Checklist Form; SOP 34, Control Rods; SOP 34, Appendix A,
Control Rod Calibration Form; SOP 34, Appendix B, Control Rod
Inspection Checklist; SOP 34, Appendix C, Control Rod Inspection Form;
and, SOP 60, Logbook Entries; and associated Appendix A, Maintenance
Log forms
RRR Annual Reports for the last two reporting periods
b. Observations and Findings
The licensee conducted various maintenance and surveillance activities which
were then documented on the appropriate forms and checklists. The inspector
verified that these activities were conducted within the time frame required and
according to procedure. The inspector reviewed selected biweekly, bimonthly,
semiannual, and annual forms and checklists. All the recorded results reviewed
were within the TS and procedurally prescribed parameters. The records and
logs reviewed appeared to be complete and were being maintained as required.
The inspector was not able to observe a Startup or Shutdown Checklist being
performed during the inspection. However, previously completed Startup and
Shutdown Checklists were reviewed. These activities appeared to have been
conducted appropriately and in accordance with procedure.
A review of the RRRF Main Logs and current Maintenance Logbook showed that
these records were also being completed as required and problems, if any, were
being documented. Through observation and records review, the inspector also
confirmed that maintenance was being conducted as needed, consistent with the
TS.
- 15 -
c. Conclusion
Maintenance was being completed as required. The program for surveillance
was being carried out in accordance with TS requirements.
7. Procedures
a. Inspection Scope (IP 69001)
To determine whether facility procedures met the requirements outlined in
TS Section 6.4, the inspector reviewed portions of the following:
Procedural reviews and updates documented in the ROC meeting minutes
RRR Administrative Procedures, Section 8, Adoption and Revision of
Operating Procedures, and Section 9, Record Retention
Various RRR SOPs and Appendices including: SOP 60, Logbook
Entries;SOP 61, Procedure Writing and Use; SOP 61, Appendix A,
Document Structure; SOP 61, Appendix B, Document Locations; and
SOP 61, Appendix C, Temporary Procedure Change
b. Observations and Findings
Procedures were in effect for those activities specified in TS Section 6.4 as
required. RRR Administrative Procedures and SOPs were found to be
acceptable for the current staffing level and status of the facility. The
Administrative Procedures and SOPs specified the responsibilities of the various
members of the staff. Substantive changes to procedures were being reviewed
and approved by the ROC. The procedures were being audited, reviewed, and
updated as needed.
The inspector reviewed the temporary procedure changes that had been
promulgated during the past 12 months. The changes were written after minor
problems with the procedures were noted. The temporary changes were
typically incorporated in the referenced procedures if deemed appropriate by the
licensee. Changes suggested as a result of the ROC and independent audits
were also incorporated into the procedures if deemed appropriate.
c. Conclusion
Facility procedures for the safe operation of the reactor were available as
required by TS Section 6.4.
- 16 -
8. Experiments
a. Inspection Scope (IP 69001)
In order to verify that experiments were being conducted within approved
guidelines specified in TS Sections 3.6, 4.6, and 6.5, the inspector reviewed
selected portions of the following:
Experiment review and approval by the ROC
Selected Irradiation Request Forms for 2015 and 2016
Approved RRR Routine Experiments (REs), including: RE 1, Irradiation with
Neutrons; RE 2, Irradiation with Gammas; RE 3, Fuel, Graphite, or Source
Material; RE 4, Reactor Power Measurement; RE 5, Control Rod Worth
Measurement; RE 6, Pool Parameter Measurement; RE 7, Fuel Loading;
RE 8, Cerenkov Radiation Spectrum Acquisition; RE 9, Neutron Induced
Auto-Radiography; and RE 10, Radial Flux Measurements
Approved RRR Special Experiment (SE), SE 4, Core Temperature
Measurements
RRR Administrative Procedures, Section 4, Reactor Experiments; and
Section 9, Record Retention
Various RRR SOPs and Appendices including: SOP 10, Irradiation
Preparation; SOP 10, Appendix A, Irradiation Request Form; SOP 10,
Appendix D, Irradiation Request Log; SOP 11, Irradiation Analysis;
SOP 12, Lazy Susan; SOP 13, Rabbit; SOP 14, Central Thimble;
SOP 15, Beam; SOP 15, Appendix A, Beam Irradiation Request
Form;SOP 16, Near Core; and SOP 17, Gamma Irradiations
b. Observations and Findings
The inspector noted that the various experiments conducted at the facility, and
revisions thereto, were being reviewed and approved as required. It was also
noted that the two most recently proposed REs had been submitted by licensee
staff and students and had been reviewed and approved by the Facility Director
and the ROC as required.
Through a review of console logs and various irradiation request forms, the
inspector noted that irradiations were conducted under the cognizance of the
Facility Director and the Reactor Supervisor as required. The irradiations were
documented in the Main Log and the results of the experiments were
documented on the Irradiation Request Forms as required. The resulting
radioactive material was being transferred to an authorized user, disposed of as
stipulated by procedure, or held for decay.
- 17 -
c. Conclusion
The licenses program for the control of experiments generally satisfied
TS Sections 3.6, 4.6, and 6.5 and other regulatory requirements.
a. Inspection Scope (IP 69001)
To verify compliance with the RRRF, E-Plan, the inspector reviewed selected
aspects of the following:
ERR E-Plan last revised August 2014
Emergency response training records for the past 2 years
Emergency drills and exercises held during 2015 and 2016
Emergency response facilities, supplies, equipment and instrumentation
ERR SOP 25, Semiannual Checklist
ERR SOP 25, Appendix A, Reed Research Reactor Semiannual Checklist
ERR E-Plan, Appendix a, Emergency Implementation Procedures (EIPs)
ERR E-Plan, Appendix B, Projected Doses for Bounding Accidents
ERR E-Plan, Appendix C, Visible and Audible Alarms
b. Observations and Findings
The E-Plan in use at the reactor had been updated, reviewed, and approved by
the ROC. The licensee had determined that there was no decrease in
effectiveness as defined in 10 CFR 50.54, Conditions of licenses,
paragraph (q). The licensee had submitted a letter to the NRC documenting this
determination on August 18, 2014.
The E-Plan and EIPs were being audited and reviewed annually as required.
Supplies, instrumentation, and equipment staged for emergency use were being
maintained, controlled, and inventoried semiannually as required in the E-Plan. It
was noted that the Emergency Support Center was located in the RRRF
Directors office in the Chemistry Building.
Through records review and interviews with licensee personnel, emergency
responders were determined to be knowledgeable of the proper actions to take in
case of an emergency. The inspector reviewed the Agreement Letters that had
been signed with various emergency support organizations. These agreements
were being maintained and updated as needed.
Communications capabilities were acceptable and had been tested and
emergency information updated as stipulated in the E-Plan. It was noted that the
Emergency Notification Call List, posted in various locations throughout the
facility, was current and the most recent version was dated October 5, 2016.
The inspector verified that training for staff and offsite support personnel was
being provided annually as required.
- 18 -
Training for staff was typically completed through the Operator Requalification
Program. Training for representatives from the Portland Fire and Rescue
Department (PF&RD) was conducted annually. Training for representatives from
the Portland Police Bureau was offered but the police could not always commit to
attend because of staffing level shortages.
Emergency drills had been conducted annually as required by the E-Plan.
Off-site support organization participation was also as required by the E-Plan.
Critiques were held following the drills to discuss the strengths and weaknesses
identified during the exercises and to develop possible solutions to any problems
identified. The results of these critiques were documented and reported to the
Radiation Safety Committee/ROC. Drills involving off-site personnel were being
conducted annually and documented as stipulated by the E-Plan.
The inspector and the Facility Director visited a PF&RD unit located several miles
from the RRRF. The inspector and Director were given a tour of the facility and
observed the equipment maintained by the unit for response to various types of
emergencies. As a result of this visit, and following a review of the licensees
records documenting drills and training, the inspector verified that fire department
personnel were well trained, properly equipped, and knowledgeable of the
actions to take in case of an emergency at the reactor facility. The inspector
determined that the licensee communicated with the PF&RD frequently and was
maintaining a good working relationship with this support group.
c. Conclusion
The emergency preparedness program was conducted in accordance with the
10. Follow-up on Previously Identified Items
a. Inspection Scope (IP 92701)
The inspector reviewed the actions taken by the licensee to address a previously
identified IFI.
b. Observation and Findings
50-288/2014-202-01 - IFI - Follow-up on the licensees actions to correct the
inconsistencies between the E-Plan and the Implementing Procedures dealing
with the Alert classification of various events.
During an inspection in December 2014, the inspector reviewed of the E-Plan. It
was noted that there were no accidents that could cause an Alert classification
for the facility. However, certain security events would require an Alert"
Nevertheless, it was noted that there were various EIPs which indicated that, in
certain accident situations, the classification for the event would be Alert.
- 19 -
The licensee acknowledged these inconsistencies and agreed to correct the
problem. The licensee was informed that correcting these issues would be
followed by the NRC as an IFI.
During this inspection, the inspector reviewed the actions taken by the licensee
to resolve the inconsistencies between the E-Plan and the EIPs. It was noted
that the procedures had been revised to indicate that accidents or events
occurring in conjunction with security events require the Alert designation.
Otherwise these events are classified as Unusual Events. This issue is
considered closed.
c. Conclusions
One IFI was reviewed and this issue is considered closed.
11. Exit Interview
The initial scope of the inspection were summarized on November 2, 2016, with the
Facility Director, the Reactor Manager, and the Dean of Faculty. On November 3, 2016,
the preliminary results were discussed with the Facility Director and the Reactor
Manager. On December 1, 2016, the results of the inspection were discussed with the
Facility Director and the Dean of Faculty. On December 2, 2016, the results of the
inspection were reiterated with the Facility Director. The inspector discussed the
findings for each area reviewed. The licensee acknowledged the findings and did not
identify as proprietary any of the material provided to or reviewed by the inspector during
the inspection.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
C. Barrett Reactor Operations Manager
S. Brodesser Training Supervisor
T. Freeman Requalification Supervisor
A. Karr Radiation Safety Officer and Campus Environmental Director
J. Koh Operations Supervisor
M. Krahenbuhl Director, Reed Reactor Facility
M. McCarthy Projects Supervisor
N. Nicholson Dean of the Faculty, Reed College
M. Oxley Training Supervisor
Other Personnel
S. Christensen First Lieutenant, Portland Fire and Rescue, Training, Safety, and EMS
Division, City of Portland
B. Profit Training Lieutenant, Portland Fire and Rescue, Training, Safety, and EMS
Division, City of Portland
INSPECTION PROCEDURE USED
IP 69001 Class II Non-Power Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-288/2016-202-01 IFI Follow-up on the licensees actions to maintain logs which
contain the accurate and complete documentation of scram
events and other operational events.
50-288/2016-202-02 VIO Failure to have all of required channels operable during
reactor operation as required by TS Section 3.2.2.
50-288/2016-202-03 VIO Failure to complete a review prior to installing a fission
chamber instead of an uncompensated ion chamber with the
Percent Power Channel (as stipulated in the facility SAR) as
required by 10 CFR 50.59 (c)(1)(i and ii) and (c)(2)(i-viii).
50-288/2016-202-04 NCV Failure to have all of required channels operable during
reactor operation as required by TS Section 3.2.2.
50-288/2016-202-01 IFI Follow-up on the licensees actions to correct the reactor pool
overfill problem caused by the automatic fill system installed
by the licensee.
-2-
Closed
50-288/2014-202-01 IFI Follow-up on the licensees actions to correct the
inconsistencies between the E-Plan and the Implementing
Procedures dealing with the Alert classification of various
events.
50-288/2016-202-04 NCV Failure to have all of required channels operable during
reactor operation was a Severity Level IV violation of
LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations
CAA Controlled Access Area
CAR Corrective Action Report
EIP Emergency Implementation Procedures
HV High Voltage
IFI Inspector Follow-up Item
IP Inspection Procedure
kW Kilowatt
NCV Non-Cited Violation
No. Number
NRC Nuclear Regulatory Commission
OSU Oregon State University
PF&RD Portland Fire and Rescue Department
RE Routine Experiment
RO Reactor Operator
ROC Reactor Operations Committee
RRR Reed Research Reactor
RRRF Reed Research Reactor Facility
SAR Safety Analysis Report
SE Special Experiment
SOP Standard Operating Procedure
SRO Senior Reactor Operator
SSC Structure, System, or Component
TS Technical Specifications
UIC Uncompensated Ion Chamber
VIO Violation
W Watt