ML20151R311
| ML20151R311 | |
| Person / Time | |
|---|---|
| Site: | Kansas State University |
| Issue date: | 04/18/1988 |
| From: | Gagliardo J, Greg Pick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151R283 | List: |
| References | |
| 50-188-88-01, 50-188-88-1, NUDOCS 8804270293 | |
| Download: ML20151R311 (8) | |
See also: IR 05000188/1988001
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APPENDIX C
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report: 50-188/88-01
Operating License:
R-88
Docket: 50-188
Licensee:
Department of Nuclear Engineering
L. ;
Manhattan, Kansas 66505
Facility Name: KSU Nuclear Reactor Facility
Inspection At: Manhattan, Kansas
Inspection Con ucted: March 8-10, 1988
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' Inspector:
[OO
G. S Pick, Reactor Inspector, Operational
pate'
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Programs Section, Division of Reactor Safety
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Accompanying
Personnel:
R. J. Evans, Reactor Inspector, Operational
Programs Section
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Approved:
i qE. Gagliardo, Chief, Operational Programs
pate
Sectioli, Division of Reactor Safety
Inspection Sumary
Inspection Conducted March 8-10, 1988 (Report 50-188/88-01)
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Areas Inspected:
Routine, unannounced inspection of organization, logs and
records, procedures, surveillance, requalification training, review and audit,
and experiments.
Results: Within the six areas inspected, one violation (paragraph 5) and one
deviation were identified (paragraph 2).
~8804270293 880419
ADOCK 05000188
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DETAll/l
1.
Persons Contacted
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- N. D. Eckhoff, Head of Nuclear Engineering Department
- R. E. Faw, Director, Nuclear Reactor Facility
H. C. Moser, Chemistry Professor
P. Richard, Director, J. R. Mcdonald Laboratory
- J. L. Daniels, Reactor Supervisor
D. Whitfill, Senior Reactor Operator
- Denotes those attending the exit interview.
2.
Logs and Records
(39745)
The KSV facility logs and records were inspected to ensura compliance with
regulatory, license, and procedural requirements.
The review of logs was
also performed to ensure maintenance and surveillances were completed
within the time intervals required by Technical Specifications (TS) and
facility procedures.
The Operations Manual, Section 6.0, and Hazard Summary Report,Section II.7.0,
Operations Logbook, Step 2 states, "All scrams and their cause as well as
malfunctions of equipment must be entered in the logbook in red."
Contrary
to this requirement, only one equipment malfunction out of ten recorded
was written in red; however, all unintentional scrams were recorded in red
in the operating logs as required.
The nine other examples of equipment
malfunctions were documented in dark ink, but they should have been
entered in red.
The period observed was between May 1986 and Marcli 1988.
The highlighting (in red) of unintentional scrams and equipment malfunctions
can be significant to safety because on a shift or staff turnover, an
equipment malfunction or failure could be missed if not properly highlighted
in the operations logbook.
The failure to record all equipment malfunctions in red is a deviation
from procedural requirements and Hazard Summary Report commitments.
(188/8801-01)
The monthly operations reports which consisted of the Monthly Maintenance
and Surveillance Report Checklists were reviewed to ensure all required
items were completed in a timely manner for the period May 1986 to
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February 1988.
The checklists were generated from data found in the
various control room logs over the past month.
Four administrative errors
were found in the monthly operationf, reports reviewed.
In three cases,
the checklist items were performed but were not recorded on the monthly
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operations report.
The fourth item was an incorrect transfer of data from
the logs to the monthly operations report. The NRC inspectors concluded
that the licensee needs to take a more rigorous approach to the monthly
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operations report.
The inspector verified that the followup activities or commitments made by
the licensee in NRC Inspection Report 50-188/86-01, were completed.
NRC
Inspection Report 50-188/86-01 did not specifically list by item number any
open items, deviations, or violations against the licensee's operational
program.
The items verified complete included:
a.
Th6 water temperature 1imit in TS was listed in degrees F, while the
tenperature meter read in degrees C.
The licensee calculated what
degrees C equaled the degrees F TS limit and added a label to the
temperature meter that listed the TS limit in degrees C.
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b.
The conductivity meter had three unlabeled scales.
A label was
added to the meter to identify and differentiate each of the three
scales.
c.
The checkoff item "Check Lower Door" on the daily checklist was being
performed on a daily basis.
One deviation was identified in the review of this program area.
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3.
Procedures
(42745)
The KSV facility procedures were reviewed to ensure compliance with TS,
operational requirements and administrative requirements.
The NRC
inspectors observed a reactor startup, performed by the Reactor Supervisor
who maintains a senior reactor operators (SRO) license. All required
checks and procedural steps were observed to be performed. The Reactor
Supervisor was knowledgeable and competent throughout the startup.
During the review of the facility procedures, the NRC inspector could not
verify the performance of TS Section E.2.
TS E.2 requires a control rod
inspection for significant distortion or deterioration at least once every
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2 years.
The licensee's Reactor Test Procedure No. 1, "Biennial Control
Rod Inspection," does not reference TS E.2.
Procedure No.1 does perf orm
a control rod inspection, but not specifically for "significant distortion
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or deterioration." Procedure No. 1, Basis Section, states, "This
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procedure is designed to compliment existing Reactor Experiment No. 20,
Control Rod Inspection." However, Experiment No. 20 was deleted in
October 1982 at Reactor Safeguards Committee Meeting No. 102. A revision
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of Procedure No. 1, "Biennial Control Rod Inspection," is required in
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three areas:
a.
delete reference to Experiment No. 20 in the Basis section;
b.
add TS E.2 to the Purpose section; and
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c.
add TS E.2 inspection requirements to the Control Rod Inspection
section.
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This area is considered an open item until Procedure No. 1 is revised and
past performance of TS E.2 is verified (0 pen Item 188/8801-02).
The Table of Contents page of the Reactor Test Procedures book was noted
to be out of date. Of 21 procedures, the revision dates for 6 procedures
were incorrect and dates were missing for 4 other procedures.
Additionally, the Emergency Procedures were listed in the Table of
Contents but were not found in the procedures book. Maintaining an
up-to-date Table of Contents page is necessary to help ensure that the
procedures in the book are the most current ones available. The use of
the correct procedure revision by the operators is critical to maintaining
reactor safety. The updating of the Table of Contents page is considered
an open item (188/8801-03).
As an observation, the current system at the KSU facility does not allow
temporary changes to be made to procedures. The Reactor Supervisor should
be allowed to make temporary changes to procedures, provided:
a,
changes do not alter the original intent of the procedure;
b.
the supervisor is an SR0;
c.
a note of the change is noted in the operating log, or equivalent;
d.
all licensed individuals are infermed of the change; and
e.
the change is reviewed and approved by the Reactor Safeguards
Committee (RSC) at the earliest possible time.
No violations or deviations were identified in this program area.
4.
Surveillance (61745)
A review of the licensee's surveillance program was conducted to ensure
cot.pliance with TS requirements.
Surveillance records reviewed were
complete and tests were performed on a timely basis. A comparison of
selected recorded parameters versus TS requirements was performed, with no
discrepancie!. noted.
No violations or deviations were identified in the review of this program
area.
5.
Requalification Training
(41745)
The NRC inspector verified that activities related to requalification of
licensed operators were conducted in accordance with the KSU approved
Requalification Program, Revision 2, dated October 8, 1974. The NRC
inspector reviewed, for the period May 1986 through February 1988, the
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monthly operations reports, which documented reactor manipulations that
created reactivity changes and the~ hours credited the operator for being
at the console.
If an SR0 license holder has spent hours supervising
console activities, his activities were credited.
Also verified for the years 1986, 1987, and 1988 was that licensed
individuals, except for the Reactor Supervisor who administers the test,
had requalification tests and answers in the requalification binder.
In
addition, the requalification binder lists the course dates and subjects
presented to licensed individuals. All lecture material required by the
Requalification Program was covered in the courses presented.
The record of attendance at the lectures prior to 1987 consisted of the
signed examinations; however, for 1987 and 1988, attached to the course
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syllabus, there was a signed statement that all 10 CFR 50.59 changes had been
reviewed and understood. Also there was an attendance matrix formed by
listing the attendees top-to-bottom and the lecture sessions
left-to-right. Attendance at specific lectures by individuals was
documented by a checkmark in the appropriate matrix location.
The records
showed that all licensed individuals had attended all lectures. The NRC
inspector commented that the present way of documenting attendance at the
requalification lecture sessions was a good practice and should be
continued with one modification.
The preferred method for documentation
of attendance at lectures would be for each individual to initial and date
the matrix blocks instead of using checkmarks, since anyone could
checkmark the blocks. This is an open item awaiting verification of
licensee activities concerning this issue by the NRC during a subsequent
inspection (188/8801-04).
The NRC inspector determined from review of the monthly operations reports
for the third calendar quarter of 1987 that Mr. J. K. Shultis, SRO,
operated the reactor for only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; therefore, he failed to operate the
reactor for the required minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by 10 CFR 50.53(e).
This placed the license holder in an inactive status. Mr. Schuitis should
have been under the direction, which includes direct observation, of
another licensed individual whose operators license was active during the
fourth calendar quarter of 1987.
Instead, the SR0 in question conducted
active licensed operator duties at the console during the fourth quarter
of 1987 totaling 3.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> which does not meet the minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
under direction as required by 10 CFR 55.53(f). This is an apparent
violation of 10 CFR 55.53(f) as applicable to research reactors (188/8801-05).
From the discussions with the Facility Director and review of documentation,
the inspector determined that the personnel were knowledgeable about the
changes to 10 CFR 55 in August 1987; however, the rule was published in
the Federal Register in March 1987 and effective in May 1987 which allowed
two months to alter their policies and procedures.
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The NRC inspector informed the KSV staff that it is their responsibility
to keep current with the regulations and to alter requirements as
appropriate.
The NRC inspector questioned them on whether they had the
large loose leaf "NRC Rules and Regulations" of Title 10.
They did not
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have a set and could iiot recall whether they ever had a' set.
It was
suggested that, they should find a means to keep current with regulatory
changes. One possibility would be to subscribe to the "NRC Rules and
Regulations." jThis is an open item (188/8801-06) awaiting licensee
actions to ens >re that they keep current with regulatory changes and
verification during a subsequent inspection.
Within this area one violetion was identified.
6.
Review and Audit (40745)
The NRC inspector verified that the review and audit activities of the
Reactor Safeguards Committee were consistent with regulatory requirements
and that changes to the facility were made consistent with the
requirements of 10 CFR 50.59 and TS.
The NRC inspector reviewed the meeting minutes for the following RSC
meetings: Meeting Nos. 111, 112, 113, and 114. The meetings lasted from
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. A quorum was present each meeting. The semiannual
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audit report, prepared by the Facility Director, was reviewed as were the
control room logs for content and adequacy.
Because of the small size of the KSV Nuclear Reactor Facility all portions
of the semiannual audit could not be independently audited; hence, the
Facility Director had to audit himself and his activities relating to
The minutes documented that any changes to the facility and/or procedures
were reviewed to determine whether an unreviewed safety question existed
as required by 10 CFR 50.59.
Also reviewed by the inspector were the 10 CFR 50.59(b) reports. These
reports accurately reported the changes in the facility which occurred
during the 1986 calendar year and until October of 1987.
The NRC inspector interviewed several of the RSC members.
Two were
university staff members outside of the Department of Nuclear Engineering,
another was the RSC Chairman, and the final person interviewed was the
Facility Director who serves as a Nuclear Engineering (NE) Department
member. The results of the reviews are summarized below:
The two staff members outside the NE Department have no knowledge of
reactor operations nor any knowledge about what constitutes an
unreviewed safety question.
The first member interviewed had
expertise in nuclear physics and had an understanding of the dangers
associated with exposure to radiation; however, the person depended
on the Radiation Safety Officer for hazard determinations in this
area.
The second member interviewed had knowledge about
radiochemistry.
Both members stated that the Facility Director and
Reactor Supervisor provided the majority of the information presented
at the RSC meetings including the affect and extent of any procedure
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and/or design changes. -The other person who had a key role in the
RSC meetings was the Radiation Safety Officer.
He is relied upon, in
addition to the Facility Director and Reactor Supervisor, to
determine changes which have the potential for increasing radiation
safety hazards.
The RSC Chairinan had some general knowledge of what constitutes an
unreviewed safety question but not in the detail expected of a person
in this position.
The RSC Chairman informed the inspector that he
had been a qualified reactor operator at the KSV Nuclear Reactor
Facility; therefore, he has operating knowledge of this facility.
The Facility Director, when questioned about what constitutes an
unreviewed safety question, did not appear to have a working knowledge
of 10 CFR 50.59. The Facility Director maintains an acti"e SRO
license and has detailed understanding of reactor operations.
The NRC inspector informed the KSU staff that the RSC met their minimum
requirements and responsibilities for the types of changes and experiments
which occurred during the period inspected. This conclusion has the
qualifier that the nature of the experiments at this time do not significantly
affect safety nor do radiological hazards exist.
However, if the program
were to become more active or the experiments were to be such that the
reactor was operated closer to TS limits (the experiments become more
hazardous), then this committee's performance would be inadequate to
determine unsafe conditions in the form of an unreviewed safety question.
The NRC inspector was also concerned that the review comittee was
required to review changes and experiments for an unreviewed safety
question, but the members did not all appear to know what constituted an
unreviewed safety question.
No violations or deviations were identified.
7.
Experiments
(69745)
The NRC inspector reviewed this area to determine whether experiments were
conducted safely and in accordance with TS and regulatory requirements.
The NRC inspector reviewed the Progress Reports developed for 00E for the
following periods: July 1, 1985, through June 30, 1986; and July 1, 1986,
through June 30, 1987, to identify the types of experiments being conducted
and what substances were irradiated.
The experiments conducted were
neutron activation analysis via the rotary specimen rack and/or the
central thimble, irradiation to produce isotopes, and classroom teaching
experiments. Also reviewed were the Form-2s which were requests for
experiments.
The Form-2s reviewed were for the entire inspection period.
They specify what is to be irradiated, the quantity of material, and the
desired power level.
The forms corroborated what was reported to the D0E.
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FromdiscussionswiththeFacilityDirectorandtheR$actorSupervisor,
the NRC inspector determined that they had detailed understanding of the
limits stated in the TS.
The experimenters utilized approximately six
preapproved experiments. All experiments conducted during this period
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were within the limits set by TS.
Experiment No. I had an administrative limit of not irradiating more than
100 milligrams (mg) of an unknown substance.
From discussions with the
Facility Director and the Reactor Supervisor, the NRC inspector learned
-that, in addition to the 100 mg limit, the power level is maintained at or
below 100 watts for 1 minute or less. The NRC inspector could not find
the 100 watt nor the 1 minute or less criteria; therefore, this is an open
item (188/8801-07) awaiting incorporation into a procedure the above
requirements and subsequent inspection by the NRC.
No violations or deviations were identified.
8.
Exit Interview
The NRC inspectors summatized the inspectinn scope and findings on
March 10, 1988, with those people identified in paragraph 1.
The licensee
stated that none of the material reviewed by, nor provided to, the NRC
inspectors was proprietary.
The NRC inspector identified his concern that for the present status of
facility operations, the review process was minimally adequate; however,
if any program expansion occurs then the committee members need a detailed
familiarity with what constitutes an unreviewed safety question.
The licensee disagreed with the NRC inspectors' interpretation of the
Hazard Report Summary, Step 11.7.2.
The licensee believed only equipment
malfunctions that result in an unintentional scram should be recorded in
red in the operating log.
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