ML20148E280
| ML20148E280 | |
| Person / Time | |
|---|---|
| Site: | 05000072, University of Utah |
| Issue date: | 03/21/1988 |
| From: | Chaney H, Robert Evans, Murray B, Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148E270 | List: |
| References | |
| 50-072-88-01, 50-407-88-01, 50-407-88-1, 50-72-88-1, NUDOCS 8803250050 | |
| Download: ML20148E280 (23) | |
See also: IR 05000072/1988001
Text
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APPENDIX A
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC' Inspection Report: 50-072/88-01 Operating Licenses: R-25
3 50-407/88-01 R-126
Docket 2: '50-072
50-407
Licensee: University of Utah (VofU)
Salt Lake City, Utah 84112
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Facility Name: Nuclear. Engineering Laboratory (NEL)
Inspection At: University of Utah, Merrill Engineering Building,
Salt Lake City, Salt Lake County, Utah
Inspection Conducted: February 16-19, 1988
Inspectors: \0; M
H. D. Chaney, Radiation Specialist, Facilities Date
Radi logical Protection Section
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j $ Evan$, Reactor Inspector, Operational Da'te i
Programs Section
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D. A. Powers, Enforcement Officer
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Approved: ; //d/(d//J
B. Murray, Chief, Facili ies Radiological
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i Protection Section
Inspection Summary
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Inspection Conducted February 16-19, 1988 (Report 50-072/88-01 and 50-407/88-01)
Areas Inspected: Special, unannounced team inspection of the licensee's
, reactor operation, emergency planning, physical security, and radiological
controls associated with the TRIGA reactor, and the physical security and
decommissioning status of the AGN-201 reactor.
8803250050 880322
PDR ADOCK 05000072
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Results: Within the areas inspected, 7 violations, 1 unresolved item,
1 deviation, and 15 open items were identified.
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DETAILS
1. Persons Contacted-
Licensee
- R. E. Stephenson, Reactor Administrator
- J. S. Bennion, Senior Reactor Operator (SR0)
- J. M. Byrne, Reactor Safety Committee (RSC) Member
- C. M. Fejer, Radiation Safety Analyst
- T. C. Gansauge, SR0
- G. M. Sandquist, Reactor Supervisor
K. J. Schlager, University of Utah (VofU), Radiation Safety Officer (RS0)
- N. L. Smith, Radiation Safety Analyst
- Denotes those present at the exit interview on February 19, 1988.
2. Open Items Identified During This Inspection
An open item is a matter.that requires further review and evaluation by
the NRC inspector. Open items are used to document, track, and ensure
adequate followup on matters of concern to tne NRC inspector. The
following open items were identified:
'Open Item Title See Paragraph
,
407/8801-10 Reactor Program Support 6
407/8801-11 Operator Requalification Tests 7
407/8801-12 Operator Requalification Program 7
Check-Lists
407/8801-13 Reactor Modifications Training 7
407/8801-14 Documentation of Scram Test Times 8
407/8801-15 Excess Reactivity Reference Value 8
407/8801-16 Response to RSC Audit Findings 9
407/8801-17 Pen and Ink Changes to Documents 10
407/8801-18 Procedure Control and Distribution 11
407/8801-19 Set Point Limits and Tolerances 11
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'407/8801-20 Leaking Fuel Element Followup 13
407/8801-21 Police Department Procedures 16
407/8801-22 Police Department Use of Area Radiation 17
Monitor (ARM)
407/8801-23 ARM and Intrusion Alarm Backup Power 17
Supply Batteries
407/8801-24 Fuel Inventory Review 19
3. Unresolved Items
An unresolved item is a matter about which more information is required in
order to determine whether it is in an acceptable item, a violation, or a
deviation. The following unresolved item was identified:
Unresolved Item Title See Paragraph
407/8801-08 Missing Documentation of Monthly 17
Intrusion Drill
4. Licensee Action on Previously Identified Inspection Findings
(0 pen) Violation 407/8601-06: Operator Requalification Program - This
item was discussed in NRC Inspection Report 50-407/86-01 and involved the
licensee's failure to fully implement the TRIGA reactor operator
requalification program (ORP). This item was reviewed in NRC Inspection
Report 50-407/87-01 and the requalification program was found to be
improved, but no personnel had successfully completed the operator
licensing program other than the Reactor Supervisor. Therefore, no
assessment of the implementation of the requalification program could be
made at that time. During.this inspection, the ORP was reviewed again,
and the NRC inspector determined that the operator requalification
examinations that were administered did not contain all of the topics
listed in 10 CFR 55.21 and 22. Topics listed in 10 CFR 55.21 and 22, but
not found on the examinations, include fuel handling procedures, reactor
theory, core alterations, and alarm setpoints. This item remains open
pending licensee evaluation and modification of the ORP.
5. Background
AGN-201 - The AGN reactor was being decommissioned. The reactor had not
been operated since February 1985. The licensee had performed periodic
surveillance on the integrity of the AGN core and shield water vessel.
The licensee-had removed the 25 tons of brick that were used both as a
radiation shield and a physical security barrier for protection of the AGN
fuel. The licensee had surveyed the bricks for radioactivity and the NRC
inspector performed confirmatory measurements on the bricks. The bricks
apparently did not contain any activated materials or radioactive
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contamination and have been released by the licensee for unrestricted use.
The licensee was currently evaluating the method to be employed for
removal and shipment of the AGN fuel to a Department of Energy repository.
Once the AGN fuel is removed, the licensee will submit a decommissioning
plan to the NRC for approval. At the time of the inspection, only
Dr. Sandquist was licensed to operate the AGN reactor.
TRIGA - The TRIGA reactor was being used for education and research
purposes. The reactor was operated for approximately 369 hours0.00427 days <br />0.103 hours <br />6.10119e-4 weeks <br />1.404045e-4 months <br /> during the
1985-1986 reporting period and approximately 142 hours0.00164 days <br />0.0394 hours <br />2.347884e-4 weeks <br />5.4031e-5 months <br /> during the
1986-1987 reporting period. The licensee had recently (December 1987)
' become aware of a fuel integrity problem with the current core
configuration and had been operating the reactor for short periods and
shuffling fuel in an attempt to locate the faulty fuel element. No
significant radiological problems have been observed, and the indicators
of leaking fuel are evident by small increases in the fission product
inventory within the reactor coolant (RC) and the RC cleanup
demineralizers. The licensee was limiting full power runs to short
periods of time since the fission product increases were only detected
after several hours of full power operation. At the time of the
inspection, Dr. Sandquist and two graduate students were licensed to
operate the TRIGA reactor.
6. Management Organization and Controls (40750)
The NRC inspectors reviewed the licensee's management organization to
determine compliance with the requirements of TRIGA Technical
Specification (TS) 6.1, 6.2, 6.5.1, 6.5.3, and 6.5.4 and agreement with
the TRIGA Safety Evaluation Report (SER/NUREG-1096).
The licensee's organization and assignment of responsibilities are
contained in the NEL Operations Manual. The NRC inspectors compared the
existing organization to the requirements in the TRIGA TS. Dr. Sandquist
was found to be filling TS Figure 6.1 positions of both Laboratory
Director and Reactor Supervisor. Dr. Sandquist was found to have a
teaching load that included seven courses per year and was currently
advisor to 12 graduate students. Dr. Sandquist devotes approximately 15
to 25 percent of his time to TRIGA/AGN reactor activities. The NRC
inspectors found very little support by the Reactor Administrator whose
only activity in regard to the TRIGA/AGN reactor programs was to chair the
RSC meetings. The TRIGA/AGN programs were, for the most part, carried out
by the two SR0 graduate students who were also pursuing advanced degrees
at the UofU. The NRC inspectors expressed their concern about the lack of
active support for the TRIGA/AGN reactor programs. This is considered an
open item pending licensee review of program support for the TRIGA/AGN
reactors. (407/8801-10)
The RSC's charter and membership were reviewed. The NRC inspectors also
reviewed NEL procedures. Since late 1986, the licensee had been
performing a detailed review of NEL operating procedures and developing a
master administrative plan for the operation and management of NEL
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activities related to the two reactors. The master plan was being
prepared by a graduate student as a thesis project.
No violations or deviations were identified.
7. Qualification and Training (40750)
Personnel qualification and training were reviewed to determine compliance
with the requirements of TRIGA TS 6.3, 6.4, and 6.5.2; Appendix A to
10 CFR Part 55; and agreement with industry standard ANSI /ANS-15.4-1977.
The NRC inspectors noted that previous requalification examinations
administered to the operators were almost identical each time an
individual took an examination. Several examinations answers were found
to be typed, and at least one examination q'uoted the TS word for word,
which indicated an open book examinations was given. NRC I&E Informatica
Notice (IEIN) 87-22 addressa the subject of take-home or open-book
examinations. IEIN 87-22 clearly indicates that take-home or open-book
examinations are not an acceptable means for certifying individual
performance. IEIN 87-22 states, in part, "The integrity of the
requalification examination is r.ssential because it is used to certify
that the operator's performance is adequate to warrant renewal of his or
her license." The examination process at the NEL TRIGA facility does not
ensure operator knowledge of the required material. This is considered an
open item pending licensee evaluation and action. (407/8801-11)
Part of the requalification training process, as stated in the
requalification program, includes lectures and on-the-job training. The
operator requalification training checklist /signoff sheet (this checklist
was developed to resolve NRC Violation 407/8601-03) was reviewed by the
NRC inspectors to ensure all items stated in the lectures and on-the-job
training sections of the approved rcqualification program were on the
checklist. The review indicated several subjects were not on the
checklists. In the lectures section of the checklist, the "Operational
Characteristics, Use, and Storage Locations of Existing and New Radiation
Safety Equipment" sections were not referenced. In the on-the-job
training section, the "Fuel Inspection," "Fuel Temperature Measurement,"
"Control Rod Worth Measurements," and "Annual Maintenance Shutdown
Program" sections were not referenced. This is considered an open itera :
pending licensee evaluation and action. (407/8801-12)
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During the inspection, licensee personnel were interviewed about a
December 28, 1987, letter that the licensee had submitted to NRC. The
letter commented on an examination answer that an SR0 candidate had given .
during a written examination administered by an NRC licensing examiner on
June 23, 1987. The particular examination was the second SRO examination
for the candidate. Although the candidate did not make a perfect score on
the second examination, the test score was a passing grade. In the
licensee's December letter, the licensee submitted for NRC consideration
an explanation as to why NRC should accept the candidate's answer to
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question number J.10, which the examiner had marked as incorrect.
Question number J.10 was as follows:
Asst. ming no operator action, what is the most likely cause of a
reactor scram during a continuous rod withdrawal at normal rod
speeds. INCLUDE THE SETPOINT OF THE TRIP.
The candidate's answer was as follows:
The nercent power trip at 120 percent of licensed power (120 kW).
The licensee's post-test comment (December letter) was as follows:
The percent power setpoint is presently set at 115 percent of
licensed power (115kW). However, the most likely cause of a reactor
scram would be the linear recorder which would actuate at 100 percent
of full scale and, therefore, scram slightly greater than 100 kW.
UU SER Section 7.3.1, P. 7-8 (Safety Evaluation Report, NUREG-1096)
states:
"If the power level increases to 100 percent of full scale of
the recorder on any power range, a linear power level scram
occurs."
The licensee's letter went on to say that they recommend acceptance of the
examinee's answer on the basis of actual operating conditions that
> presently exist.
The NRC inspectors determined tha'. the licensee's comment was confusing
because the licensee had previously reported to the NRC by letter dated
July 3, 1987, that the linear power channel scram circuit had been
disconnected in January 1986. Previously, the licensee had
self-identified, as a result of an RSC audit on June 3, 1987, that a
facility modification had disabled the linear power channel scram
resulting in a violation of the facility TS. This was because the reactor
no longer had the TS 3.3.3 required scram channels (2) set to a limit of
less than 120 percent of full power (e.g., 100 kW). The licensee
corrected this situation and reset the scram channels as required by the
TS. (See NRC Inspection Report 50-407/87-01, paragraph 5.a.) This
problem was not a repeat violation. Consequently, in NRC Inspection
Report 50-407/87-01, the licensee was not cited for a violation pursuant
to the provisions of the NRC Enforcement Policy for licensee identified
Severity Level IV and V violations.
When licensee personnel were questioned about the physical nature of the
scram circuitry, varying des.rees of understanding were evident.
Subsequent discussions with licensee personnel and a review of the scram
circuitry wiring schematics, along with a test demonstration of the
reactor, verified that the January 1986 facility modification had only
partially disabled the linear power scram channel. Specifically, scram
circuitry for the 1-watt power range, which initiates from signals on the
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fission chamber, was operable; however, when the power range selector
switch was. increased beyond the 1-watt power setting, scram signals
arising from'the uncompensated ion chamber were directed to a computer
console, thus not resulting in reactor scrams. Therefore, the SR0
candidate's answer to question J.10 and the licensee's December letter on
the candidate's answer were both based on an incorrect understanding of
the actual reactor control circuitry and were both incorrect. This
incident demonstrated a need for the licensee to improve management
controls on reactor modifications and the training of operators on the
full affects of such modifications. This is considered an open item
pending licensee evaluation and action. (407/8801-13)
No violations or deviations were identified.
8. Operations (40750)
The NRC inspectors reviewed the licensee's reactor operating program for
compliance with the TRIGA license and TS conditions requirements. The
licensee's operations were reviewed also for agreement with the
commitments contained in the licensee's application for a 20 year renewal
of the TRIGA operating license dated March 8, 1983, and subsequent
November 29, 1984, supporting documentation in response to NRC questions.
The NRC inspectors inspected the licensee's facilities; operational,
maintenance, and access logs; procedures; reactor safety committee meeting
minutes; experiments; interviewed reactor operators; and observed the
licensee operate the TRIGA reactor at low power levels to verify reactor
protection systems operation.
The NRC inspectors determined that, except for some confusion over the
technical details of the integrated computer console for monitoring
selected TRIGA reactor functions, the reactor operators were familiar with
the reactor and its support systems and demonstrated an adequate ability
to properly and safely operate the reactor.
An inspection of the TRIGA reactor TS surveillance requirements was
performed. The surveillance requirement specifications (TS 4.0) and
licensee documentation were examined to ensure TS surveillances were being
performed within the required time intervals. During the inspection, the
following problem areas were noted:
TS 4.5 requires the conductivity and pH of the primary coolant water
to be measured monthly. The current monthly checklist ensures that
the conductivity and pH are recorded on a monthly basis. Prior to
this checklist revision (November 16, 1987), verification of
performance of the required surveillances could not be established
for water pH. The water conductivity was recorded on the TRIGA
Preliminary Check Sheet each time a reactor startup was performed.
The water pH was not a checkoff item on the TRIGA Preliminary Check
Sheet and therefore was not recorded. This problem was
self-identified by the licensee during a June 6,1987 internal audit
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by the RSC. This audit finding resulted in the revision to the
Monthly Inspection Checklist.
The failure to perform monthly pH surveillances during the period of
April 17, 1985 (when TS were last revised Amendment 5) to
October 1987 (Monthly Inspection Checklist revised in November 1987)
would normally be considered an apparent violation of TS 4.5.
However, the licensee's actions satisfied the criteria in 10 CFR
Part 2, Appendix C for licensee-identified violations.
TS 4.2(3) requires a channel check of the fuel element temperature
measuring channel to be made each time the reactor is operated. This
is performed by comparing the indicated instrumented fuel element
temperature with previous values for the current core configuration
and power level.
Contrary to the above, the NRC inspectors determined on February 19,
1987, that the licensee had not fully implemented the requirements of
TS 4.2(3) in that a review of operation documents failed to verify
that TS 4.2(3) was being performed each time the reactor was being
operated. The licensee was only evaluating cold shut down
temperature and a partial evaluation of fuel temperature during power
operator. Additionally, no acceptance criteria for comparison of
various fuel temperature versus power levels was found to exist.
This apparent violation was also identified in a June 6,1987, RSC
audit. However, no action was taken to resolve the identified
violation.
The failure to implement adequate procedures and to perform the fuel
temperature comparison is an apparent violation of TS 4.2(3).
(407/8801-01)
TS 4.3.2(1) requires reactor control and safety system scram times to
be measured annually, but at intervals not to exceed 15 months. The
scram time measurements were being added to the "Procedure for
Semi-annual Control Rod Worth Determination" data sheets as a
handwritten step 7. The licensee relies on writing of the
TS 4.3.2(1) surveillance requirement each time the procedure is
performed. The handwritten step was not found on the procedure data
sheets dated October 8,1985, and February 12, 1986. However, the
scram time information was available on the scram graphic record
attached to the procedure data sheets.
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The performance and recording of the scram times should be a
permanent part of the "Procedure for Semi-annual Control Rod Worth
Determination" and should not be a handwritten step. This is
considered an open item pending evaluation and action by the
licensee. (407/8801-14)
During the review of the licensee surveillance documents, three data
sheets were found to reference an out-of-date TS value. The
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following forms referenced an excess reactivity TS value of $3.00:
(The TS limit is currently $2.80 as per the facility operating
license issued April 17, 1985.)
Control Rod Worth Calculation Sheet
Biennial Control Rod Check Sheet (This sheet also references
TS 4.2.c, which is not'a current TS paragraph number), and
Control Rod Movement or Repair Procedure
The. error in the excess reactivity value on the "Control Rod Movement
or Repair Procedure" was discussed in the RSC meeting minutes of
June 4, 1987. The NRC inspectors determined that the licensee had
not responded to the RSC input concerning the error on the Control
Rod Movement or Repair Procedure. A revision of the affected
procedures is required because the values on the data sheets are less
conservative than TS requirements. A review of recorded data
indicated that the $2.80 value was not exceeded. The licensee
revised the three documents during the inspection and they were to be
presented to the RSC for approval.
This is considered an open item pending approval of the forms by the
RSC. (407/8801-15)
In the TRIGA reactor license renewal documentation (licensee to NRC
1983 and 1984), the licensee stated in response to NRC question 46
that the low and high alarm setpoints for the three TRIGA facility
ARMS (TS 5.4) were 0.1 and 1.0 millire;n per hour (mr/hr),
respectively. The NRC inspectors determined during the approach to
criticality checkout of the TRIGA reactor on Februtry 19. 1988, that
the actual alarm setpoints for the ARMS were 1.0 and 10 mr/hr,
respectively. Neither the licensee's calibration nor operational
procedures address the required setpoints of the detectors. This
condition has existed for an indeterminate length of time. The
failure to maintain facility ARM setpoints is considered a deviation
from commitments made to the NRC in TRIGA licensing documentation
dated November 29, 1984. (407/8801-09)
l The NRC inspectors determined, during the review of operational logs,
that during the approach to criticality on January 4, 1988, the SR0
noted that the reactor became critical prematurely while withdrawing
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the regulating rod with the safety rod already withdrawn and latched.
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The SR0 expected the reactor to only become critical following full
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withdrawal of the regulating rod and subsequent partial withdrawal of
! the shim rod. The R50 manually tripped the reactor and conducted an
l investigation into the occurrence. The investigation was documented
l in the maintenance log and master operations log. The investigation
revealed that the trapezoidal heavy water (D2 0) reflector tank (see
Section 10.1.4 of the SER) was improper}y reassembled and replaced
into the core following biennial reactor core preventative
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maintenance. The improperly reassembled-tank resulted in an air
. space being replaced by heavy water which caused additional neutron
moderation and reflection, thus causing a premature criticality. The
improper reassembly and placement of the D 2 0 tank into the core
following maintenance is discussed as an apparent vidlation in
paragraph 10 of this report. The SR0's actions were considered
appropriate and well documented. Operation was continued following
removal of the 02 0 tank from the core and correcting its
configuration.
No other violations or deviations were identified.
9. Review and Audits (40750)
The licensee's review and audit program for the TRIGA and AGN-201 reactor -
facility was inspected to determine compliance with the requirements of
AGN-201 TS 6.4.2 and 6.4.3 and TRIGA TS-6.5.4 and 6.5.5.
The NRC inspectors determined that the RSC audits were being performed in
a detailed and thorough manner. Minutes of the RSC meetings for the
period of 1986 through 1988 were reviewed. The NRC inspectors determined
that the NEL staff's response to RSC audit findings were less than
adequate and that, due to the failure to respond to RSC audit findings,
there were several apparent violations and open items documented in this
report. The Reactor Supervisor indicated that the increased RSC oversight
has increased the operations staff's workload and that additional manpower
resources were not available to both maintain the facility and correct all
of the deficiencies promptly. The licensee's lack of adequate response to
and followup on audit deficiencies is considered an open item pending
licensee evaluation of the RSC audit process. (407/8801-16)
No violations or deviations were identified.
10. Logs and Records (40750)
The licensee's program for documentation of the TRIGA and AGN-201 reactor
activities was reviewed for compliance with the requirements of AGN-201
TS 6.4.5 and 6.10 and TRIGA TS 4.3.5, 6.5.6, and 6.9.
The NRC inspectors reviewed the documentation of reactor operation for the
TRIGA reactor for the period March 1985 to February 1988. The AGN-201
reactor was not operated during this period. The documents and records
associated with maintenance, fuel movement, fuel inspection, personnel
exposure, experiments, startup checklists, and instrument response checks
were reviewed. The NRC inspectors determined that the licensee maintained
legible operation and maintenance logs. However, many checkoff sheets for
documentation of maintenance activities and periodic surveillance showed
corrections that did not identify by whom and when the change / correction
had been made. The NRC inspectors discussed with the licensee the
standard industry practice of using a single line-out of an error, and the
placing of the initials (legible) of the individual making the change and
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the date of the correction near the item (s) corrected. This is considered
an open' item pending evaluation and action by the' licensee. (407/8801-17)
No violations or deviations were identified.
11. Procedures (4075J)
The licensee's reactor operating procedures were reviewed for compliance
with the requirements of TRIGA TS 6.8.
The NRC inspectors determined that the licensee does not have a method of
ensuring that only the most current RSC and/or NRC approved procedures,
plans, TS, data sheets, and other forms are maintained available in the
control room. This was evidenced-by an SR0's confusion over what revision
of the Emergency Plan was approved for use by both the RSC and the NRC.
Three different revisions were available and approved by the RSC. The
licensee did not have a formal document control and distribution program.
This is considered an oje_n item pending licensee actions to improve
document control and distribution. (407/8801-18)
TRIGA T5 6.8 states, in part, that "Written operating procedures shall be
adequate to ensure the safety of operation of the reactor . . Operathg
procedures shall be in effect for the following items: ...
(4) core changes and fuel movement . . .
(6) performing preventative maintenance . . . on the reactor and
associated equipment"
During the biennial fuel and control rod inspection, the trapezoidal heavy
water (D20) tank was removed from the core on December 29, 1987, for
inspection and maintenance. No reference was made to the use of a
procedure for this activity. The TRIGA reactor core was reassembled and
the 02 0 tank was replaced in its position at the outer periphery of the
core on or about January 4,1968. During the subsequent TRIGA resctor
approach to criticality on January 4, 1988, the reactor prematurely went
critical (see paragraph 7 for details). The ensuing investigation by the
NEL staff determined that the D2 0 tank had been installed without
replacing the dry experiment tube in the tank center which caused the
normal air space to be replaced with 02 0 water, thus increasing neutron
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moderation and reflection. (Paragraph 4.1 and 10.1.4 of the SER addresses
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functional design considerations of the D2 0 tanks.)
During a review of the maintenance log on February 18, 1988, the NRC
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inspector? could not verify that a procedure had been established and used
for the removal, inspection, disassembly, and reassembly of the D2 0 tank
prior to placing it back into the TRIGA core tank. The NRC inspectors
determined on February 19, 1988, that the failure to properly reassemble
the 02 0 tank was in part due to the lack of written procedure. The NRC
inspector noted that a member of the RSC was reviewing the maintenance log
entries on the same day as the NRC inspectors and that he also noted the
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problem. The' failure to develop and implement adequate procedures for
core alterations and reactor maintenance operations is considered an
apparent violation of TS 6.8(4) and (5). (407/8801-02)
The NRC inspectors reviewed the licensee's calibration of the fuel element
temperature thermocouple (T/C). The licensee used a written procedure
(Semiannual Thermocouple Calibration) for the T/C calibration. The
calibration was performed using properly calibrated reference equipment
and in-house laboratory prepared reference standards. The NRC inspectors
noted that the stated calibration tolerances were considerably less than ,
that which could be accurately determined from the fuel element
temperature readout meter. The reactor console fuel element temperature
readout is in increments of 5.0 C on the analog meter (0-500 C) and the ,
calibration procedure requires that the fuel temperature alarm / trip point
setting be within 10.5 C of the actual setting. A limitation of one-half
of the smallest scale division is normally taken as standard industry
practice when interpreting analog meter readings. The licensee's use of
0.5 C as a tolerance is approximately 5 times greater than what can
accurately be discerned from the fuel element temperature readout.
Discussions with licensee personnel about the overly restrictive tolerance
resulted in the reestablishing of the setpoint tolerance for this
particular activity at 15.0 C. The NRC inspectors noted that the licensee
did not in all cases include TS limit values and, in most cases,
setpoint/ calibration tolerances on instrument calibration and checkout
sheets. This is considered an open item pending the licensee's evaluation
and review of current calibration and surveillance check sheets.
'407/8801-19)
No violations or deviations were identified.
12. Experiments (40750)
The licensee's program for the control and conduct of experiments was
inspected to determine compliance with the requirements of TRIGA TS 1.2,
3.2, 3.6, and 6.5.4(1); agreement with the recommendations of NRC
Regulatory Guides (RG) 2.2 and 2.4; and agreement with industry standard
ANS-15.6/N401-1974.
The NRC inspectors reviewed the licensee's installation (as an experiment)
of a computerized monitoring system for the monitoring of certain core
parameters. The computer installation was reported to the NRC via the
July 1, 1986, through June 30, 1987, "TRIGA Reactor Annual Operating
Report." ibe licensee also included a 10 CFR Part 50.59(a) evaluation of
i
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the computer installation in the annual report. The NRC inspectors
verified that the computer console was installed as depicted in the annual
report. The licensee is treating the computer operation as a routine
Class 2 type experiment TS 1.2(2). The NRC inspectors verified that the
computer did not interfere with any reactor safety systems and had no
affect on the reactor's automatic scram actions or engineered safety
features. The computer monitors 11 reactor parameters. The licensee has
had frequent software problems with the computer. Currently, the licensee
_ . _. _ ____ __ _ _ _ _ _ _ _ _ _ _ _ _ _. __ _ _ ___ - _ . - _ _ _ _ _ _ _ _
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.does not possess sufficient documentation for evaluation of the computer
for permanent replacement of official core parameter monitoring circuitry.
The licensee had also installed a new rack and pinion control rod drive
mechanism (commonly used on TRIGA reactors) for replacement of the old
drum and cable system-(paragraph 4.1.2, 4.6.1, and 7.1.2 of the SER
'
address the existing control rod drive mechanism) now employed. The .
licensee has. connected the regulating control rod to the computer
'
controlled rod drive mechanisms and classified it as an experiment. Due
to the regulating rod's low reactivity worth (approximately $0.46), the
reactor staff, through the RSC, determined that the use of the regulating ;
rod in the experimental mode (with the rack and power system) would not '
cause an unreviewed safety question and approved its use in the computer
system experiment. This change was also reported to the NRC in the same
annual report.
No violations or deviations were identified.
13. Reactor Fuel Handling (40750)
4
The NRC inspectors reviewed the licensee's procedures and logs regarding ,
the handling and storage of TRIGA reactor fuel for compliance with the
requirements of TRIGA TS 4.4 and 5.5.
The licensee's biennial inspection of fuel for the period January 1985
through February 1988 were reviewed. The results of the 1985 fuel
inspection and identification of excessive corrosion were reported to the
NRC in the 1985-86 TRIGA Reactor Annual Report. The licensee's 1987
biennial fuel inspection did not identify any significant findings. An
instrumented fuel element (fuel temperature thermocouples) was changed out
due to failure of the thermocouples and excessive corrosion. The licensee i
had verified their suspicion that the core contained a leaking fLel
element by finding positive indications of fission products in the TRIGA
reactor core tank following a January 11, 1988, reactor run. Since that
time, the licensee has only operated the reactor for purposes of trying to
find the laaking fuel element following fuel shuffles. This is in
accordance with the requirements of TS 4.4(3) which allows short-term
operation of the reactor to aid in finding the leaking fuel element (s).
This is an open item pending further review by the NRC during future
inspections.
'
(407/8801-20)
No violations or deviations were identified.
14. Transportation of Radioactive Materials (86721)
No transportation of radioactive materials has been made by the licensee
since this area was last inspected in 1986. t
i
No violations or deviations were identified.
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15. Radiation Protection (40750)
The licensee's radiation protection program was inspected to determine
compliance with the requirements of the TRIGA TS.3.7, 4.3.3, 5.4, and
10 CFR Part 20 and agreement with the recommendations of industry standard
ANSI /ANS-15.11-1977.
The NRC inspectors reviewed current facility radiological surveys and
reports to the NRC concerning comprehensive NEL surveys, performed
independent confirmatory measurements of the loose surface contamination
and radiation levels, and inspected portable and fixed radiation
monitoring instrumentation within the NEL.
10 CFR Part 20.201(a) states, in part, that "As used in the regulations
... ' Survey' means an evaluation of the radiation hazards incident to
the . . . use, release, disposal, or presence of radioactive materials or
other_ sources of radiation under a specific set of conditions. When
appropriate, such evaluations include a physical survey of the locations
of materials . . . and measurements of levels of radiation . . present."
Part 20.201(b) requires, in part, that "Each licensee shall make or cause
to be made.such surveys as (1) may be necessary for the licensee to comply
with regulations . . . (2) are reasonable under the circumstances to
evaluate the extent of radiation hazards that may be present."
a. During the independent radiation surveys on February 17, 1988, the
NRC inspectors found.that a part of the TRIGA reactor pneumatic
sample transfer system (rabbit terminus) stored on the floor in the
AGN and TRIGA reactor room (1205-E, which is posted as a radiation
area) had gamma radiation levels at contact near one end of
approximately 120 mr/hr and approximately 10 mr/hr at 1 foot.
Licensee documentation showed that on February 1, 1988, the rabbit
terminus was removed from the reactor core and surveyed by an SR0.
The SR0 determined that the rabbit terminus had gamma radiation
levels of 18 mr/hr on contact and approximately 10 mr/hr at 1 foot.
. The SR0 tagged the rabbit terminus with a "Caution Radioactive
i Material" tag and annotated it with the contact dose reading. The
NRC inspectors determined that the rabbit terminus was improperly
surveyed and the posting failed to properly warn personnel of the
radiation hazards associated with handling the material. The
licensee on February 17, 1988, verified the NRC inspector's survey
'
results with their own surveys and posted the rabbit terminus with a
i "Caution Radiation Area" sign. This is similar to the inspection
l
findings referenced in NRC Inspection Report 50-407/86-01.
l b. The NRC inspectors determined on February 17, 1988, during loose
! surface contamination surveys (smear surveys), that the NEL exhaust
!
ventilation system (an engineered safety feature, paragraph 6.1 of
the SER) was contamin.ited internally to a level of approximately
3,000 disintegrations per minute per 100 square centimeters. This
contamination was found on the downstream side of the system's
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. filters and system radiation monitors (four). The licensee confirmed
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on February 17, 1988, by gamma spectrometry, that the contamination
was primarily composed of cobalt-60. The licensee had never
performed smear surveys of the interior of the ventilation ducting.
However, the licensee had known of the presence of cobalt-60 , 'l
contamination in the facility since initial core loading (1977).
Routine NEL area smear surveys have detected the presence of ,
cobalt-60 contamination throughout the facility on several previous
occasions. The contanination hsa resulted from the reactor fuel
being shipped to the licensee in fuel containers that were
contaminated with cobalt-f0.
( '
The NRC inspectors discussed with the licensee the nu d to,*eevaluate
the reactor facility's airborne effluer,t safety analysis in view of
the above findings and report the results in the next TRIGA annual
report.
The failure to adequately survey the rabbit terminus and the . ventilation
system internals is considered an apparent violation of 10 CFR
Part 20.201(b). (407/8801-03)
TRIGA TS 5.0, "Design Features," and TS 5.4, "Radiation Manitoring
System," -tate, in part, "This specification describes the functions an
essentia~, components of the . . . system for continuously ponitoring
airborne radioactivity . . . (2) Function of Continuous Air Radiation
(CAM) Honitor (beta , gamma-sensitive detector with particuinte collyction
capability): Monitor concentration of radioactive particulate activity in
the pool room, alarm and readout at control console."
The NRC inspectors determined on February 18, 1988, that tre airborne
monitors did not have the capability to collect or monitor' qualitatively-
or quantitatively particulate radioactivity. This item was also addressed
in an RSC audit performed ty the UofU Radiation Safety Officer on June 6
1987. The RS0 recommer.ded installation of a CAM in the f acility, but no 7
action had been taken to resolve the audit finding.
The failure to have installed and operating a continuous' airborne. '
,
monitoring with particulate collection capabilities'is considered an '
l
apparent violat.hn of TS 5.4(2). (407/8801-04)
No other violations er deviations were identified.
16. Emergency Planning and Preparedness (40750)
l
The licensee's imp) mentation of the NRC approved UofU Emergency
l Plan (E-Plan) for the AGN-201 and TRIGA reactors was reviewed for
compliance with the requirements of 10 CFR Part 50.54(q) and (r) and
agreement with the recommendations of NRC RG 2.6 and industry standard '
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,
l ANSI /ANS-15.16-1982.
!
'
The licensee,has not conducted an exercise of the E-Plan since June 12,
1986. NRC Itispection Report 50-407/86-01 addresses NRC observations and
,
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concerns identified by the inspectors during the 1986 exercise. The
licedsee has tentativd y scheduled an E-Plan exercise before June 1,1988.
'
T[e licensee is currently conducting training of staff and of fsite support
services on the requireme,ts of the E-Plan.
The NRC inspectors discuss d with the licensee the current status of the
revised E-Plan (December 1, 1986) submitted to the NRC Office of Nuclear
'
Regulation (NRR) for review and approval on oi- about May 21, 1987. The
NRC inspectors verified that the old E-Plan (3184) was still the E-Plan
being implemented. .
The NRC inspectors inventoried the contents of the E-Plan required
z
emergency supply kit located in the NEL. All items that are required were
j . found to be in the emergency kit (duffel bag) or were accessible during an
emergency.
,
,; The NRC inspectors determined on February 17, 1988, that the campus police
,
department dispatcher's office contained an outdated NEL emergency
a response procedure (Appendix 5A, dated May 30, 1986). An RSC revision to
Appendix 5A was issued / approved June 4, 19874 This is considered an
open item pending licensee actions to ensure that nonNEL organizations
which have emergency response responsibilitiL; have and will continue to
receive the latest revision to the emergency procedures. (407/8801-21)
s No violations or deviations were identified.
17. Physical Security (81431]
The NRC' inspectors verified the implementation of the Physical Security
Plan (PSP) by review of logs, observation of equipment, and discussions
with'Mcensee representatives responsible for implementation of the PSP.
An unannounced test of the Uofu police department's response to an
intrusion ala!m was conducted. The current PSP approved for
implementation by the licensee is addressed in Amendment No. 5 to the
facility license (R-H6). License Condition 2.C(3) of License R-126
t.tates, in part, that "The licensee shall maintain and fully implement all
provisions of the Commission-approved ptysical security plan, including
ar:endment and chanrfes made pursuant to the authority of 10 CFR 50.54(p).
The approved physical security plan coasists of documents . . . entitled
"University of Utah Physical Security Plan for Probction of SNM of Low
Strategic SigrJficance under Licenses R-25 and R-126 . . . Revision 1
dated July 28, 1980 ...
"
Chapter 3 of the PSP states, in part, "In every event of a violation of
the UNEL (University Nuclear Engineering Laboratory, also known as the
NEL) Intrusion Alarm System an armed campus police officer is dispatched
to the UNEL to inve.tigate the incident . Each campus police officer
receives annual faw;1iarization tours and instructions . . and incident
response procedures are given. The dispatcher's office.'s supplied with
written instructions for sequential actions . ...
"
Chapter 2 of the PSP
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.f D requires th4 Vne satisfactory operation of the entire intrdon alarm '
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( system be.va lfied monthly. ,
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Appendix SA of'the NEL Emergency Proceduras, RSC-approved May 30, 986,
and June 7, 1987, titled "NEL Em ngerc% Procedures.for.Non-NEL
P- Organizations," requires that upon M eipt of.an intrusion (NR) alarm.
_
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signal from the NEL the dispatcher (campus police) should imnediately
,'
T' dispatch one or more officers to Merrill Engineering Building (MEB). The
officer (s) responding to'an alarm from the NEi. shall first check the
'
,s exterior perimeter of the facility fcr physical damagn si/prj breach of
gy security. The entrances (old room No./new room No.) th e'evecked are:
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Exterior door to dom 1001/1205 MEB
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Exterior doo9tto room 1001- Y1205-G. No't: Mr'usstothisdooris
a through the Mest end of room'105UJ156
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3 Exterior windows (outdoors, west side of hEB) l
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Roll-up garage door (west side of MEB)
NOTE: Room numbers were revised in 1986. Room and door identifiers are
contained in Revision 1 to the PS!J and tFigure 4.1 of the SER.
Furthermore, one radiochemistry room is mislabeled in these documents;
1001-E shoald be labeled 1001-G.
.
On February 17, 1988, an unannounced security d-ill was conducted and was
"
initiated by tripping the intrusion alarm at roo.n ;G01 G/1205-G exterior
door'(enters into room 1156) to a radiochemistry rocm. An SR0 and an NRC
inspector were positioned at the open door. The campus police responded
to t @ event within 4 minutes. Howe /er, the NRC inspectors determined
a t;ht the responding police officer cntered MEB room 1001/1205 prior to
cheJking the perimeter of the facility. The responding officer then only
' checked on the status of the roon.;1305 0, exterior door af ter some coaching
, from a supervising p11 ice officer u the dispatcher's office.
, Ov.c 100lrG/1205-G wcs not tiiscovereO cpen until approximately 16 minutes
! af ter the jolice officer 's arrival at the. NEB /NEL. The officer's entry *
'
into the cessroom of room 1001/1205 could have prevented the police
, officer's efforts to determine if an intrusien had been made ana al?owaa
i the iatruder to make q exit )ia rcom 1056/E56 of the MEB. The
,
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responding officer strted tnat hc ud beca provided a imilia hica t9ur
- of the NEL during the hst 12 months. ,
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[. , The f rivre to follow the scquential renoiraments of the NEL emergency
responsa'hrocedures which impMment the W 'is an apparent violation of
'
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the PSP. Ti07/8801-05) s
The NRC inspectors determined during toe inspection that an area radiation
mnitor (ARM) located just inside and over the entrance door to
classroom 1001/1205 was not turried on for most of the time the NRC
irspectors were present in the room. The ARM was turned on prior to the .
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conducting of the intrusion test on February 17, 1988, but was again noted
by the NRC inspectors to be turned off on February 18-19, 1988.
Appendix 5A of the NEL Emergency Procedures requires, in part, that "the
security personnel observe area radiation monitor readout for dose rate
information when responding to an alarm. This is to be accomplished
before entering the NEL interior but after inspection of the perimeter
doors." The ARM to be used in this instance is located inside the NEL
over the entrance door to room 1001/1205. The responding police officer
did not know how to determine if the monitor was on or how to turn the
monitor on. When in the off mode, the monitor's radiation level indicator
reads zero (no radiation present). This could lead to a false assumption
by the responding officer that no radiation is present. The area
radiation monitor is not referenced in or required by the E-Plan.
This is considered to be an open item pending evaluating and action by the
licensee. (407/8801-22)
The NRC inspector's review of the NEL Monthly Inspection Checklist log
book found one monthly checklist missing (June 1987). The monthly
checklist was present for all other months reviewed (1985-1988). Part of
the monthly checklist concerns an intrusion alarm check. This security
drill is required on a monthly basis by the PSP. Failure tc perform the
PSP required monthly security drill is an apparent violation of the PSP.
However, the licensee believes the security check was performed and they
will conduct a search in order to locate the record. This is considered
an unresolved item pending further NRC review. (407/8801-08)
A test of the emergency power system was performed on February 17, 1988.
Emergency power (or back-up power) is supplied by a 12 Vdc battery to the
radiation monitors and intrusion detectors on a loss of building AC power.
To test the battery capacity, the trickle charge supply to the battery and
AC power to the TRIGA console were disconnected. The emergency power
system (batteries) dropped in voltage to 2-3 Vdc within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. At that
time, an automatic trouble alarm was received by the UofU police
department. The trouble alarm was responded to by the UofU maintenance
department. Prior to the maintenance person correcting the problem, the
SR0 attempted to activate the intrusion alarm by opening alarmed
- door 1001-E/1205-E. The intrusion alarm circuitry failed to actuate due
l to the low voltage condition of the discharged battery. The NRC
inspectors determined that the backup power system (batteries) failed to
maintain the radiation and intrusion alarms circuits operable.
The test indicated the batteries would fail to perform their intended
I function over a period of time if a real loss of AC power emergency event
had occurred. Additionally, a large crack was noted on one of the battery
'
j cells. The preventative mainte.1ance program for the batteries appears to
'
need more attention by the licensee. This is considered an open item
pending evaluation and action by the licensee. (407/8801-23)
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Chapter 1 of the PSP states that all Special Nuclear Material (SNM) for
the AGN-201 nuclear reactor is located within the core assembly of the
reactor. Access to this SNM requires the removal of approximately 25 tons
of dense concrete block and three other mechanical barriers to gain access
to the AGN fuel. Due to the time and heavy equipment needed to gain
access to the AGN fuel, this is considered an adequate barrier to prevent
unauthorized removal of the AGN fuel.
Further, the PSP states, in regard to the protection of TRIGA fuel, that
fuel elements within the reactor core tank are covered by 24 feet of water
and require a special tool (which is locked up when not in actual use) for
removal of the fuel elements from the tank.
The NRC inspectors determined on February 16, 1987, that the licensee
removed the 25 tons of concrete block from over and around the AGN-201
reactor. The licensee had started this removal in August 1987 and had
completed the removal about November 28, 1987. When questioned by the NRC
inspectors on the removal of the concrete bricks, licensee representatives
indicated that they thought of the concrete bricks only as a radiation
shield and not a required physical barrier to prevent removal of the AGN
fuel. The last review of the PSP by the RSC was conducted on or about
May 21, 1987. Removal of the concrete physical barrier was not approved
by the NRC. In addition, the NRC inspectors also determined that the
licensee was storing the TRIGA fuel handling tool in an unlocked cabinet
below the chemistry fume hood in room 1205-F (unlocked access door)
adjacent to the TRIGA/AGN reactor room (1205-E). This condition had
existed for an indeterminate amount of time. The NRC inspectors noted
that RSC audits do not appear to include PSP components or requirements.
The failures to properly implement the PSP regarding protection of SNM is
considered apparent violations of the PSP. (407/8801-06)
No other violations or deviations were identified.
18. Plans, Procedures, and Reviews (81401)
The licensee's control and maintenance of the PSP was reviewed to
determine compliance with the requirements of 10 CFR Part 50.54(p).
The NRC inspectors reviewed the current PSP (December 1, 1986) and
compared its contents against the previous PSP (July 28, 1980) to
determine that changes to the PSP have not decreased the overall
effectiveness of the plan and the implementing procedures are adequate to
,
satisfy the performance objectives of the regulations.
l
l License Condition 2.C(3) of License R-126 states, in part, that "The
licensee shall maintain and fully implement all provisions of the
Commission-approved physical security plan, including amendments and
changes made pursuant to the authority of 10 CFR 50.54(p)."
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10 CFR Part 50.54(p)(1) states that the licensee may make no change which
would decrease the effectiveness of a security plan prepared pursuant to
50.54(c). Furthermore, Part 50.54(p)(2) states that a licensee may make
changes to the plans referenced in Part 50.54(p)(1) without prior
Commission approval if the changes do not decrease the safeguards
effectiveness of the plan. When such changes are made, the licensee must
submit, as specified in Part 50.4, a report containing a description of
each change within 2 months after the change is made.
Revision 2 of the PSP (new plan) dated December 1, 1986, was reviewed and
approved by the RSC. The revised PSP was sent to the NRC for review on or
about May 21,1987, some 5 months following its apparent implementation.
The NRC inspectors determined on February 18, 1988, that Revision 2 to the
PSP decreased the plan's effectiveness in at least five areas and thus
decreased the overall effectiveness of the plan. NDTET Room numbers were
revised in 1986, but the old room numbers will be used in this discussion.
Room and door identifiers are contained in Revision 1 to the PSP and
Figure 4.1 of the SER. Furthermore, one radiochemistry room is mislabeled
1001-E in these documents and should be labeled 1001-G.
The five areas of decreased effectiveness are:
a. Old Plan - The two doors (4 and 5) leading to and between the two
chemistry rooms (1001-F and G) from the adjoining TRIGA/AGN reactor
room (1001-E) were both required to be secured by dead bolt lock.
These two chemistry rooms share a common false ceiling.
New Plan - Only requires that door 5 between rooms 1001-F and 1001-G
be the only door required to be dead bolt locked.
Discussion - Due to the existence of a common false ceiling (between
rooms 1001-F and G) over door 5 and the lack of a requirement for
dead bolting of door 4 (door leads directly into the TRIGA/AGN
reactor room (1001-E)). This effectively decreases access control to
room 1001-E.
b. Old Plan - States that door 3 (entrance to room 1001-E from 1001-D),
door 4 (entrance from 1001-E to 1001-F), and door 5 (entrance from
1001-F to 1001-G) are treated the same for security purposes.
New Plan - States that only doors 3 and 4 are treated the same for
security purposes.
Discussion - This is in line with the change made in paragraph 1
above. However, this does result in a lessening of the access
control plan for the facility,
c. Old Plan - States that there are four physical barriers to prevent
access and the removal of fuel from the AGN reactor. One of the
specified barriers is 25 tons of concrete blocks stacked over and
around the AGN reactor.
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New Plan - Has eliminated reference to the 25 tons of concrete blocks
Trom the plan.
Discussion - This decreases the physical security for the AGN fuel.
d. Old Plan - Stated that the NEL's intrusion alarm was tied into the
VofU's Radiation Safety Office as well as the campus police '
department and provides a visual as well as an oral alarm.
New Plan - Deletes reference to this secondary alarm location.
Discussion - The licensee was previously issued a Notice of Violation
(NRC Inspection Report 50-407/86-01) concerning the failure to
maintain this alarm at the Radiation Safety Office. The deletion of
the secondary alarm is considered a reduction in the PSP intrusion
alarm capabilities.
i
e. Old Plan - Chapter 3 required that the police dispatch in every event
of a violation of the NEL intrusion' alarm system an armed campus
police officer to the NEL to investigate the incident and to report
to the dispatcher the officer's findings. !
New Plan - Chapter 3 now states, "In every unresolved event of a
violation of the . . . intrusion alarm . . ."
,
Discussion - This change indicates that the dispatcher now makes an
evaluation of the alarm and decides on whether or not to dispatch an
officer. No guidance has been given the dispatcher on how they are
to accomplish this evaluation. The licensee indicated that the
dispatcher would try and contact someone at the NEL to confirm the
alarm as part of the evaluation. This reasoning does not provide for
the possibility that the person being contacted is under duress
(being forced to give a positive reply) and informing the dispatcher
that the alarm was a false alarm. This also decreases the
effectiveness of the PSP. t
The NRC inspectors determined that the effectiveness of the PSP had been
overall decreased by the combined changes in Revision 2 to the PSP. Even
j though some of the changes were warranted, the licensee and the RSC failed
.
'
to provide adequate documentation as to why the changes were being made,
and obtain NRC approval prior to making them.
The failure to submit the revised PSP to the NRC within 2 months after
implementation and the failure to obtain NRC approval before implementing
the revised PSP is considered an apparent violation of and 10 CFR
Part 50.54. (407/8801-07)
No deviations or other findings were noted in this area.
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19. Material Control and Accounting (85102)
The licensee's SNM control and accountability program was reviewed to
determine compliance with 10 CFR Part 70.
The NRC inspected the licensee's NRC Forms 741 and 742 to determine
compliance with inventory and reporting requirements. The licensee has
been reporting a combined SNM inventory of 5,498 grams in the routine
reports since 1985 to the NRC per 10 CFR Part 74.13.
The NRC inspectors performed a inventory of SNM including TRIGA fuel the
licensee had on site. Inventory balance for the TRIGA fuel showed that
based on SER values for SNM content of TRIGA fuel the licensee's reporting
values are lower than those calculated by the NRC inspectors. The NRC
inspectors did not consider burn up and only considered the inventoried
fuel elements to contain the original quantities of SNM. The licensee's.
TRIGA fuel element inventory by serial number is over 8 years old. The
NRC inspectors discussed the need to conduct a serial number inventory of
each fuel element and source containing SNM on site, including the AGN
fuel. The NRC inspectors determined the licensee had 5 spent TRIGA
elements in the spent fuel storage wells (4 in the south well, none in the
'
, center well, and 1 in the north well) ard 50 elements in 6 fuel storage
racks inside the reactcr tank, and 81 fuel elements in the TRIGA core.
These values agree with the licensee inventory of 136 fuel elements.
This is considered an open item pending the licensee's review of the SNM
accountability program. (407/8801-24)
No violations or deviations were identified.
20. Reports and Notifications
The NRC inspectors reviewed the licensee's submittal of reports and
notification to the NRC to determine compliance with AGN-201 TS 6.9.1 and
6.9.2, and TRIGA TS 6.10 requirements.
The NRC inspectors reviewed reactor facility annual reports since 1980,
'
30-day notifications concerning self-identified TS deficiencies, and
telephonic communications with NRC NRR and Regional staffs.
No violations or deviations were identified.
21. Ex*. Interview
The NRC inspectors met with the licensee's representatives identified in
paragraph 1 of this report on February 19, 1988. lhe NRC inspectors
summarized the scope and the results of the inspection. The NRC
inspectors emphasized to the licensee that the numerous violations
indicate a lack of management oversight and support.
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