ML20058M565
| ML20058M565 | |
| Person / Time | |
|---|---|
| Site: | Idaho State University |
| Issue date: | 09/20/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058M569 | List: |
| References | |
| 50-284-93-01, 50-284-93-1, NUDOCS 9310060216 | |
| Download: ML20058M565 (13) | |
See also: IR 05000284/1993001
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
Inspection Report:
50-284/93-01
License: R-110
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Licensee:
Idaho State University
Pocatello, Idaho 83209
Facility Name:
Lillibridge Engineering Laboratory
Inspection At:
Idaho State University Campus
Pocatello, Idaho
Inspection Conducted: August 2-6, 1993
Inspectors:
L. T. Ricketson, P.E., Senior Radiation Specialist
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Facilities Inspection Programs Section
A. D. Gaines, Radiation Specialist
Facilities Inspection Programs Section
Ll4L86 /
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Approved:
[ flat '
'es Inspection
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B. hurray, Chief,'Facil
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Programs Section
Inspection Summarv
Areas Inspected:
Routine, announced inspection of the licensee's organization
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and management controls, training and qualifications, reactor operations and
maintenance, procedures, experiments, surveillances, internal audit and review
program, radiation protection program, emergency preparedness, special nuclear
material accountability, and physical security and safeguards.
Results:
The organization and staffing conformed to Technical Specification
requirements (Section 1).
Personnel allowed access to the reactor facility were instructed in
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accordance with 10 CFR 19.12 requirements (Section 2).
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Two apparent violations were identified in the operator requalification
program.
Operators had not been observed annually or tested annually by
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the Reactor Safety Committee (Section 2).
An apparent violation was identified involving an operator who had not
had a medical examination at the required interval (Section 2).
9310060216 930923
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The reactor was operated within Technical Specification limits
(Section 3).
An apparent violation was identified involving the failure to have a
written 10 CFR 50.59 safety evaluation for a new experiment (Section 5).
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An apparent violation was identified concerning the failure to keep
records for byproduct material transfers (Section 5).
An apparent violation was identified regarding the. transfer of byproduct
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material to unauthorized personnel (Section 5).
Surveillance activities were conducted as required (Section 6).
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Apparent violations were identified involving the failure to perform
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surveys and the failure to maintain the results of surveys.
In general,
area radiation surveys were conducted as required and areas were
properly posted. Radiological controls were generally good (Section 7).
The Security Plan was properly implemented (Section 8).
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An apparent violation was identified involving the failure of the
reactor administrator to receive training as required by the Emergency
Plan (Section 9).
An apparent violation was identified involving four-examples where the
Reactor Safety Committee did not perform required audits .(Section 10).
Annual reports were submitted as required (Section 11).
An apparent deviation from a previous commitment involving emergency
support services was identified (Section 13.4)
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Summary of Inspection Findinas:-
Apparent Violation 284/9301-01 was opened (Section 2).
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Apparent Violation 284/9301-02 was opened (Section 2).
Apparent Violation 284/9301-03 was opened (Section 5).
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Apparent Violation 284/9301-04 was opened (Section 5).
Apparent Violation 284/9301-05 was opened (Section 5).
Apparent Violation 284/9301-06 was opened (Section 7).
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Apparent Violation 284/9301-07 was opened (Section 7).
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Apparent Violation 284/9301-08 was opened (Section 9).
Apparent Violation 284/9301-09 was opened (Section 10).
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Violation 284/9101-01 was closed (Section 13.1).
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Violation 284/9301-02 was closed (Section 13.2).
Violation 284/9301-03 was closed (Section 13.3).
Inspection Followup Item 284/9101-04 remains open (Section 13.4).
Apparent Deviation 284/9301-10 was opened (Section 13.4).
Attachment:
Persons Contacted and Exit Meeting
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DETAILS
1 ORGANIZATION AND MANAGEMENT CONTROLS (40750)
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The inspectors reviewed the licensee's organization and staffing to determine
compliance with Technical Specification 6.0.
The organizational structure conformed to the Technical Specification
requirements. All positions were staffed. The Dean of the College of
Engineering served as the reactor administrator. A new reactor supervisor was
appointed in March 1993. There was or,e other senior reactor operator ~in
addition to the reactor supervisor.
There were no reactor operators included
as part of staff at the time of the inspection.
2 TRAINING AND QUALIFICATIONS (40750)
The inspectors reviewed the licensee's training program and operator
requalification program to determine compliance with the requirements of
Technical Specification 6.2 and 10 CFR Parts 19.12 and 55.59.
The inspectors verified that instructions concerning radiological hazards were
given to all individuals working in or frequenting the reactor facility that
satisfied 10 CFR 19.12 requirements. The inspectors noted that the radiation
safety office had implemented a training program for selected personnel.
Appropriate training records were maintained in the personnel files.
The new reactor supervisor met the qualification requirements of. Technical
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Specification 6.2.
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Technical Specification 6.3 requires that all licensed reactor operators
participate in the requalification program.
Section 4.a of the licensee's
NRC-approved reactor operator requalification program requires that an annual
written examination covering the entire area of reactor operations for the
AGN-201 reactor will be administered to all operators and senior reactor
operators by the Reactor Safety Committee. The reactor supervisor informed
the inspectors on August 3,1993, that the University was in violation of this
requirement. The inspectors reviewed records of the licensee's operator
requalification program and confirmed that the Reactor Safety Committee had
not administered tests to a senior reactor operator and two reactor operators
from November 1991 to the time of this inspection. The failure to administer
annual tests to the senior reactor operator and the reactor operators was
identified as an apparent violation of Technical Specification 6.3 (284/9301-
01). This item was also identified as a violation during the previous
inspection (284/9101-01).
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Section 4.b of the licensee's NRC-approved reactor operator requalification
program requires that a member or members of the Reactor Safety Committee
observe the operation of the reactor by each licensed operator or senior
operator at least once during each calendar year.
The inspectors determined
that members of the Reactor Safety Committee did not observe the operation of
the reactor by two senior operators and two operators during 1992. The
failure of the Reactor Safety Committee to observe reactor operators is a
second example to comply with Technical Specification 6.3 (284/9301-01).
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10' CFR 55.21 requires that an applicant for a license have a medical
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examination by a physician every 2 years to determine if the applicant or
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. licensee meets the requirements of 10 CFR 55.33(a)(1). The' reactor supervisor
informed the inspectors on August 3,1993, that the University had not
complied with this requirement for all individuals. The inspectors confirmed
that one senior operator did not have a medical examination by a ~ physician
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between April 24, 1990, and January 21, 1993. The operator was certified by a
physician on January 21, 1993, as being medically sound. The inspectors noted
that, according to the operations log, the senior operator continued to
operate the reactor after the 2-year period had expired. The inspectors noted
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that the individual had operated the reactor on November 4, 9, and 11, 1992,_
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and January 12, 13, and 15, 1993. The failure of the senior reactor operator
to have a medical examination was identified as an apparent violation of
10 CFR 55.21 (284/9301-02).
3 REACTOR OPERATIONS (40750)
The inspectors reviewed logs and records and observed reactor operations to
determine compliance with License Condition 2.0 and Technical Specifications 2.0 and 3.0.
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The reactor was operated 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br /> in 1991 and 147 hours0.0017 days <br />0.0408 hours <br />2.430556e-4 weeks <br />5.59335e-5 months <br /> in 1992.
It was used
for reactor demonstrations and the conducting of laboratory experiments,
including sample irradiation. There were no significant maintenance or
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operational problems; however, electronic noise in the control console did
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cause occasional scrams of the reactor.
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The inspectors reviewed operation logs for the period of December 1991 through
June 1993 and determined that the reactor had not been operated at power
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levels in excess of 5 watts and that reactor safety limits had not been
exceeded.
Power calibration was last performed in December 1992.
4 PROCEDURES (40750)
The inspectors reviewed the licensee's procedures for operating and
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maintaining the reactor, conducting surveillances and calibrations, and
conducting experiments to determine compliance with the requirements of
Technical Specifications 6.5 and 6.6.
There were only two changes to the facility procedures. Operating Procedure
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OP-1, " Reactor Operating Procedure," Revision 2, and Experiment
Procedure EP-19, " Sample Transfer by Pneumatic Tube," Revision 1, were
implemented February 17, 1993. The procedures were properly approved by the
Reactor Safety Committee, Reactor Administrator, and the Reactor Supervisor.
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5 EXPERIMENTS (40750)
The inspectors reviewed the reactor experiment program to determine compliance
with Technical Specification 3.3.
The inspectors reviewed Experiment Procedure 21, " Automatic Reactivity Control
System," and noted that its purpose was "to maintain a constant reactor power
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level during experiments. The system automatically compensates for reactivity
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changes produced during experiments or by a temperature change by moving a
graphite plug located in a reflector port." The inspectors observed the drive
mechanism attached to the reactor.
Licensee representatives stated that the
device was installed and used in 1983-1984 and then removed. According to
operations log entries and Reactor Safety Committee meeting minutes, it was
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reinstalled again in 1989. The operations log disclosed that the last two
uses of the equipment were on September 13,1991 (operating at I watt) and
November 1,1992 (operating at 0.01 watt). The inspectors determined that the
installation of the experiment equipment constituted a modification to the
reactor.
10 CFR 50.59, " Changes, Tests, and Experiments," states, in part,
that a licensee may make changes to the facility and experiments not described
in the Safety Analysis Report (Hazards Summary Report) without NRC approval,
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unless the proposed change involves an unreviewed safety question. A proposed
change shall be deemed to involve an unreviewed safety question if a
possibility for an accident or malfunction of a different type than any
evaluated previously in the Safety Analysis Report may be created. Records
must include a written safety evaluation which provides the basis for the
determination that the change, test, or experiment does not involve an
unreviewed safety question. The licensee acknowledge that a formal review had
not been conducted to de .armine if the modification resulted in an unreviewed
safety question and ther: vas no written record of a safety evaluation. The
failure to have a writte-
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unreviewed safety questit ' :s considered an apparent violation of 10 CFR 50.59
(284/9301-03).
Some of the licensee's experimer,ts involved the irradiation of samples for
researchers (Experiment 6, 7, and 19). The operations log indicated when
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these experiments were performed. Through interviews with licensee personnel,
the inspecto~ determined that samples., in some cases, were transferred from
the reactor fa ility to other departments. Transfer records were not included
in the operations log. Examples of these transfers occurred on or shortly-
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after the experiments were performed on March 3, May 21, and June 4, 1992.
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The inspectors determined that records of these transfers were not available.
10 CFR 30.51, " Records," requires that each person who receives byproduct
material shall keep records showing the receipt, transfer, and disposal of the
byproduct material. The failure to keep records of byproduct material
transfers is considered an apparent violation of 10 CFR 30.51 (284/9301-04).
The inspectors further determined that the individuals receiving the
irradiated samples were not authorized by the University's NRC broad scope
license to possess and use byproduct material.
10 CFR 30.41, " Transfer of
Byproduct Material," states, in part, that no licensee shall transfer
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byproduct material unless the licensee transferring the material has verified
that the transferee's licensee authorizes the receipt of the type, form, and
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quantity of byproduct material to be transferred. The inspectors determined
that the licensee had not verified that the individuals receiving byproduct
material were authorized. The failure to verify that persons receiving
byproduct material were authorized to receive such material is considered an
apparent violation of 10 CFR 30.41 (284/9301-05).
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6 SURVEILLANCES (40750)
The inspector reviewed records and logs regarding reactor surveillances to
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determine compliance with Technical Specification 4.0.
The inspectors determined that all surveillance activities had been conducted
as required and noted the following had been performed since the previous
inspection:
TECHNICAL
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SPECIFICATION-
tFREQUENCYJ
4.1 a - Safety Control Rod Reactivity Worth
Annual
10/92
Determination
4.1.b - Excess Reactivity and Shutdown Margin
Annual
10/92
Determination
4.2.a - Safety and Control Rod Scram Time Measurement
Annual
9/92
4.2.b - Safety and Control Rod and Drive Inspections
Biennial
9/92
4.2.h - Shield Tank Water Level Interlock, Shield Water
Annual
2/92
Temperature Interlock, and Seismic Displacement
4/92
Safety Channel Interlock Calibrations
4.4.c - Radiation Survey of Reactor Room Annual and
Annual
5/92
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Reactor Control Room
5/93
7 RADIOLOGICAL CONTROLS
The inspectors reviewed the licensee's radiation protection program to
determine compliance with the requirements of 10 CFR Part 20 and Technical
Speci fications 3.4, 4.2.i . and 4.4.
The documented radiation surveys were performed by the campus radiation safety
office. These surveys included measurements of radiation levels (for neutron
and gamma) and contamination. The inspectors determined that the licensee
complied with Technical Specification 4.4.c which required annual radiation
surveys of the reactor room.
The inspectors performed independent surveys during reactor operation. The
results of the inspectors' surveys were in agreement with the licensee's. The
inspectors determined that areas were properly posted and radiation levels
outside the reactor facility were within allowable limits for an unrestricted
area.
Portable survey instrumentation was available in the reactor room, and reactor
operators were qualified in the use of the instruments. The reactor
supervisor stated that radiation surveys were performed on samples taken from
the reactor to determine radiation levels and to identify removable
contamination. liowever, no records of these surveys were kept.
Examples of
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dates when samples were removed from the reactor are discussed in Section 5.
10 CFR 20.401(b), " Records of Surveys, Radiation Monitoring and Disposal,"
requires that each licensee shall maintain records of surveys required by
The failure to maintain radiation survey results is
considered an apparent violation of 10 CFR 20.401(b) (284/9301-06).
The inspectors noted that a radiation detector used in association with
Experiment 21 was placed in the thermal column of the reactor, but not
surveyed when removed. The purpose of the survey would have been to determine
if activation products presented a radiological hazard to persons handling the
detector. According to the operations log, Experiment 21 was last performed
on November 11, 1992, when the reactor was operating at 0.01 watts. Prior to
this time, the experiment was performed on September 13, 1991, with the
reactor operating at I watt.
The reactor supervisor stated that the detector
was not immediately removed from the reactor, and it may not have been handled
until the activation products had decayed; however, he had no knowledge of
what the radiation levels were.
10 CFR 20.201(b), " Surveys," requires that
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each licensee shall make such surveys as may be necessary for the licensee to
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evaluate the extent of radiation hazards that may be present. The failure to
perform surveys of irradiated material removed from the reactor is considered
an apparent violation of 10 CFR 20.201(b) (284/9301-07).
The inspectors noted that the procedure for the experiment directed that the
guidelines for Experiment 8 be followed for posting and survey requirements if
the detector "is placed in a reflector port." However, there were no
applicable instructions if the detector were placed in the thermal column
which was the " preferred location." The function of the detector remained the
same regardless of location.
Except for neutron survey instruments, the radiation detection / measurement
instruments were calibrated by the radiation safety office. Neutron survey
instruments were sent to a vendor for calibration. The inspectors determined
through a review of selected instruments that the instrument calibration
intervals had been maintained as required.
Personnel monitoring was provided to all persons working in the reactor
facili ty.
Pocket dosimeters were issued to visitors. The inspectors reviewed
radiation exposure records and determined that licensee personnel had not
exceeded 10 CFR 20.101 limits.
There were no measureable radioactive effluents as a result of the operation
of the reactor.
No radioactive material was transferred from the campus of the university.
8 PHYSICAL SECURITY / SAFEGUARDS / MATERIAL CONTROL AND ACCOUNTING
(81401,
81402,81431,81510,85102)
The inspectors examined the implementation of the Physical Security Plan,
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Revision 3, dated February 23, 1990, to determine compliance with the
requirements of Section 2.C(3) of the Facility Operating License, Technical
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Specifications 5.2 and 5.3, and the requirements of 10 CFR 50.54(p).
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The inspectors verified that the site and facilities were as described in the
Physical Security Plan.
Keys to access doors were held only by persons designated in the Security
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Plan.
The facility was patrolled by campus security, as required.
The inspectors verified that there had been no safeguards events.
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Haterial was stored only in controlled access areas. The licensee maintained
photographs of radioactive material, including extra fuel. An inventory was
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performed every 6 months to ensure that all material was still in the
licensee's possession. Material balance sheets were completed as required.
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The amount of material possessed did not exceed licensed quantities.
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9 EMERGENCY PREPAREDNESS (40750)
The inspectors reviewed the licensee's emergency preparedness program to
determine compliance with Technical Specifications 6.4.3.d and 6.6.f;
Revision 4, of the approved Emergency Plan; and 10 CFR Parts 50.54(q) and (r).
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The inspectors verified that current notification rosters were maintained by
the reactor supervisor and campus security. Radiation detection and personnel
monitoring devices were available, as described.
Emergency supplies were
maintained and inventoried as required.
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The licensee conducted an emergency drill on August 4,1992, fulfilling the
requirement of the Emergency Plan.
10 CFR 50.54(q), " Condition of Licenses," requires that a licensee authorized
to operate a research reactor shall follow and maintain in effect emergency
plans which meet the requirements in Appendix E to 10 CFR Part 50.
Section 6
of the NRC-approved Emergency Plan, Revision 4, states that the training of
university personnel pho are responsible to act under the emergency plan is
the responsibility of the Radiation Safety Officer.
It further states that
the Radiation Safety Officer will provide a training program at least once a
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year to train other university personnel who may be called upon to assist in
the event of a nuclear incident.
In discussions with the inspectors, the
radiation safety officer stated that he had provided training in radiation
safety but had not provided training related to individual responsibilities as
required in the Emergency Plan. The reactor superviso" stated that he
provided training for the health physics technician so.ae time during the
summer of 1993. However, no records of this training were available.
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addition, the inspectors determined that the reactor administrator had not
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received emergency training. The reactor administrator was identified in the
Emergency Plan as an individual who would be responsible to act in the event
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of an emergency. The failure of the radiation safety officer to provide
training to the reactor administrator was identified as an apparent violation
of the approved Emergency Plan (284/9301-08).
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10 00P9iITTEE MEETINGS AND MINUTES, AUDITS AND REVIEWS (40750)
The inspectors examined the licensee's audits and activities of the Reactor
Safety Committee to determine compliance with the requirements of Technical
Speci fications 6.4, 6.7, 6.C, and 6.10.2(i) .
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The inspectors reviewed the Rea. tor Safety Committee minutes and determined
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that the meeting frequency complied with the yearly requirement of Technical
Speci fication 6.4.1.
On August 3,1993, the reactor supervisor informed the inspectors that the
University had not complied with the provisions of Technical Specification 6.4.3.
Technical Specification 6.4.3.b requires that the licensee audit the
conformance of facility operations to the Technical Specification and
applicable license conditions at least once every 12 months. The inspectors
determined that an audit of this area was not performed between May 1990 and
January 1993. The failure of the Reactor Safety Committee to audit facility
operations is considered an apparent violation of Technical Specification 6.4.3.a (284/9301-09). This item was identified as a violation
during the previous inspec;.sn (284/9101-03).
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Technical Specification 6.4.3.c requires that the licensee audit the
performance, training, and qualifications of the entire facility staff at
least once per 24 months.
The inspectors determined that an audit of this
area was not performed between May 1990 and December 1992. The failure to
audit the performance, training, and qualifications of the facility staff is
considered an apparent violation of Technical Specification 6.4.3.b
(284/9301-09). This is the second example regarding the failure to complete
audit requirements.
Technical Specification 6.4.3.e requires that the license audit the results of
all actions taken to correct deficiencies occurring in facility equipment,
structures, systems or method of operation that affect nuclear safety at least
once per calendar year. The inspectors determined that an audit of this area
was not performed during 1991 and 1992. The failure to perform corrective
action audits is considered an apparent violation of Technical Specification 6.4.3.c (284/9301-09) . This is the third example regarding the
failure to perform required audits.
Technical Specification 6.4.3.e requires that the licensee audit the Facility
Security Plan and implementing procedures at least once per 24 months. The
inspectors determined that an audit of this area was not performed between
May 1990 and February 1993. The failure to audit the Security Plan and
implementing procedures is considered an apparent violation of Technical
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Specification 6.4.3.e (284/9301-09) . This is the fourth example regarding the
failure to perform required audits.
The licensee arranged for a peer review of its reactor program by technical
experts from other facilities. The audit was conducted on April 7,1993. The
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licensee had implemented some of the recommendations made by the peer review
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by the time of this inspection.
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RECORDS, NOTIFICATIONS, AND REPORTS (40750)
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The inspectors reviewed the licensee's submittal of reports and notifications
to NRC to determine compliance with Technical Specification 6.9.1.
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The inspectors deterniined that the annual reports conformed to Technical
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Specification requirements. No special reports have been required since the
previous inspection.
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12 INDEPENDENT INSPECTION EFFORTS (40750)
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The inspectors observed as the reactor supervisor parformed a reactor startup,
steady-state operation,.and reactor shutdown. The inspectors noted the.
operator used an approved prestnt checklist and operating procedure. During
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steady-state operations, the inspectors performed the confirmatory radiation
surveys discussed in Saction 7.
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13 FOLLOWUP
13.1 LClosed) Violation 284/9101-01: Failure of the Reactor Safety Committee
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to Administer Annual Written Examinations to Operators
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This item was identified as a repeat violation (Section 10). This item is
closed and the repeated violation will be tracked by 284/9301-01.
13.2
(Closed) Violation 284/9101-02: Failure to Conduct an Annual Emeroency
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Drill
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" The inspectors determined that an emergency drill was conducted August 4,1992
(Section 9).
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13.3
(Closed) Violation 284/9101-03: Failure of the Reactor Safety Committee
to Perform Reouired Audits
During the previous inspection, the inspectors determined that the Peactor
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Safety Committee had not audited the reactor program to establish its
conformance with the Technical Specifications, at least once per 12 months.
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During this inspection, the inspectors identified the failure of the Reactor
Safety Committee to perform audits in several areas, including this one.
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item is closed,- and the repeated apparent violation will be tracked by
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284/9301-09.
13.4
(0 pen) Inspection Followup Item 284/9101-04:
Letters of Agreement with
Emeraency Support Oraanizations
During the previous inspection, the inspectors noted that the licensee had not
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established letters of agreement with the local police department, fire
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department, and medical center and they noted that the licensee's Emergency
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Plan contained no provisions for obtaining such agreements.
Footnote 2 of
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10 CFR Part 50, Appendix E, states that Regulatory Guide 2.6 will be used as
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guidance for the acceptability of research and test reactor emergency response
plan.
Section C of Regulatory Guide 2.6 endorses the requirements in
ANSI /ANS 15.16-1982, " Emergency Planning for Research Reactors," as a means
for complying with the requirements in Section 50.54 and in Appendix E to
10. CFR Part 50, " Emergency Planning and Preparedness for Protection and
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Utilization Facilities," as related to research and test reactors, subject to
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certain clarifications. One clarification is that the emergency plan should
describe arrangements and agreements among the licensee and the local, State,
or Federal agencies expected to respond.
ANSI /ANS 15.16 further states in Section 3.8.3 that agreements with these
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agencies shall be confirmed in writing where appropriate or governmental
agencies radiological emergency response plans may be referenced to the extent
that they apply to the facility.
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At the exit meeting on December 12, 1991, licensee representatives committed
to establishing forical letters of agreement. This commitment was documented
in NRC Inspection Rep 7rt 50-284/91-01 dated January 9, 1992. Minutes of the
meeting of the Reactor Safety Committee conducted February 4,1992, stated
that the reactor admir,istrator inforned the committee that letters of
agreement will be sent cut.
The inspectors determined that letters of agreement were not obtained.
Licensee personnel initially stated that they had reconsidered their
commitment and felt that letters of agreement were not necessary and were not
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required. However, at the exit meeting on August 6,1993, the reactor
administrator stated they would obtain the letters of agreement. This item
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was identified as an apparent deviation from a commitment made to obtain
letters of agreement with offsite response organizations (284/9301-10).
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ATTACHMENT
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1 PERSONS CONTACTED
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Licensee Personnel
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- V. H. Charyulu, Dean, College of Engineering and Reactor Administrator
- R. D. Clovis, Reactor Supervisor
M. Gallagher, Vice President
T. Gessell, Radiation Safety Officer
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- F. H. Just, Chairman, Reactor Safety Committee
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1.2 Others
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'A. Stone, Acting Captain, Campus Security
D. Furu, Training Coordinator, Pocatello Police Department
F. Eaton, Administrator, Bannock Regional--Medical Center
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J. Hunt, Patient Services Director, Bannock Regional Medical Center
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1.2 NRC Personnel
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- B. Murray, Chief, Facilities Inspection Program Section
- Denotes personnel that attended the exit meeting.
In addition to t',9e
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personnel listed, the inspectors contacted other personnel during this
inspection period.
2 EXIT MEETING
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A meeting was conducted on August 5, 1993, with the Vice President to discuss
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the findings of the inspection to that point. An exit meeting was conducted-
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on August 6, 1993. . During this meeting, the inspecto
reviewed the scope and
findings of the report. The licensee did not identifi as proprietary, any
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information provided to, or reviewed by the -inspectors.
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