ML20153C451

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Insp Rept 50-252/88-01 on 880328-31.Violation Noted.Major Areas Inspected:Physical Security Plan,Organization,Maint & Operation Logs,Surveillance Requirements,Experiments, Radiation Protection & Emergency Planning
ML20153C451
Person / Time
Site: University of New Mexico
Issue date: 05/03/1988
From: Baer R, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153C429 List:
References
50-252-88-01, 50-252-88-1, NUDOCS 8805060233
Download: ML20153C451 (8)


See also: IR 05000252/1988001

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APPENDIX B

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U.S. NUCLEAR REGULATORY COMMISSION-

REGION IV

NRC Inspection Report:

50-252/88-01

License:

R-102

Docket:

50-252

Licensee:

University of New Mexico (UNM)-

Albuquerque, New Mexico 87131

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Facility Name:

AGN-201/M Reactor (5 Watts)

Inspection At:

UNM, Albuquerque, New Mexico

Inspection Conducted:

March 28-31, 1988

Inspector:

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R.'E. Baer, Senior Radiation Specialist

Date

Facilities Radiological Protection Section

Approved:

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B. Murray, Chief,

Rytiiological Protection

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and Safeguards Br&nch

Inspection Summary

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Inspection Conducted March 28-31, 1988 (Report 50-252/88-01)

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Areas Inspected:

Routine, unannounced inspection of the licensee's

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organization, operations and maintenance logs, licensee's internal review and

audit program, requalification program, operating procedures, surveillance

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requirements, experiments, radiation protection, environmental protection,

emergency planning, and physical security plan.

Results:

Within the areas inspected, one violation was identified (failure to

submit an annual report, paragraph 13).

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DETAILS

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1.

Persons Contacted

F. L. Williams, Chairman, Chemical and Nuclear Engineering Department

  • R. D. Busch, Reactor Supervisor
  • K. Carpenter, Senior Electronics Technician

R. Counsellor, Radiation Safety Manager

R. T. Raymond, Lieutenant, UNM Police Department

  • Denotes those present during the exit interview on March 31, 1988.

2.

Followup on Previously Identified Items

(Closed) Violation (252/8601-01):

Failure to implement operator

requalification program - This item was identified in NRC Inspection

Report 50-252/86-01 and involved the lack of operational recertification

and annual written examinations.

The licensee had implemented the

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operator and senior operator requalification program as submitted and

approved on April 12, 1987.

(Closed) Violation (252/8601-02):

Failure to perform adequate surveys -

This item was identified in NRC Inspection Report 50-252/86-01 and

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involved the lack of area radiation surveys with properly calibrated

radiation survey meters.

The licensee had implemented a calibration

program for radiation survey and measurement instrumentation.

All

radiation surveys were being performed with properly calibrated

instrumentation.

(Closed) Violation (252/8601-03):

Physical security plan - This item was-

identified in NRC Inspection Report 50-252/S6-01 and involved

implementation of the physical security plan.

The licensee had fully

implemented the physical security plan.

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(Closed) Unresolved Item (252/8601-05):

Radiation protection training -

This item was identified in NRC Inspection Report 50-252/86-01 and

involved the training provided to all personnel to satisfy the

requirements of Regulatory Guide 8.13, "Instruction Concerning Prenatal

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Radiation Exposure." The licensee includes training on Regulatory

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Guide 8.13 in "CHNE-431 - Nuclear Engineering Laboratory" and

"Introduction to Radiation Safety."

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3.

Inspector Observations

The following are observations the NRC inspector discussed with the

licensee during the inspection and at the exit interview on March 31,

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1988.

These observations are neither violations nor unresolved items.

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These items were recommended for licensee consideration for program

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improvement, but they have no specific regulatory requirement.

The

licensee stated that these observations would be evaluated for program

improvement.

Operating Procedures appeared weak'in addressing irradiations,

experiments, and maintenance that~could affect the safety of the reactor.

(paragraph 9)

Reactor Operation and Operator Trainin'g Manual did.not contain the current

technical specifications for the reactor facility.

(paragraph 9)

Annual Radiation Survey is not a comprehensive survey of the reactor room.

(paragraph 15)

4.

Organization and Management Control

.The NRC inspector reviewed the organization and management controls to

determine compliance with Technical Specification (TS) 6.1.

The current organization was verified to be consistent with Section II,

"Administration," of the AG-201M Reactor Operations and Operator Training

Manual, dated July 1984.

The NRC inspector reviewed the status of

licensed operators, membership and meetings of the Reactor Operations

Committee and Reactor Safeguards Advisory Committee (RSAC), and other

matters concerning supervision of the reactor facility.

The licensee had

increased the membership of the RSAC from four to five members.

The NRC

inspector noted RSAC membership listed in the June 1, 1986, through

June 30, 1987, annual report listed only four members.

No violations or deviations were identified.

5.

Operation and Maintenance Logs

The NRC inspector reviewed the following logs for the period May 1986

through March 1988 to determine compliance with TS 2.0, 3.0, 4.0, and

6.10.

Reactor Operations Log

Reactor Maintenance Log

Monthly Reactor Inspection Log

All maintenance and operation activities appeared to have been conducted

in a manner consistent with the TS requirements and administrative

procedures.

No violations or deviations were identified.

6.

Internal Audits and Reviews

The NRC inspector reviewed the minutes of meetings conducted by the RSAC

and verified the committee had met semiannually since the previous

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inspection and reviewed matters relating to operating the reactor.

It was

verified that records reflected attendance by designated committee

members.

The following items were routinely reviewed by the committee:

TS Requirements

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Maintenance, Operations, and Inspection Logs

Emergency Plan

Security Plan

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Equipment Performance

Procedure Changes

Radiation Surveys

The NRC inspector discussed with licensee representatives the planned

audit of the security plan. - The licensee stated this audit would be

conducted by members of the RSAC and submitted for approval at the next

RSAC meeting.

The RSAC will also review inspection reports to identify

areas of concern, violations of regulatory requirements, and corrective

actions.

No violations or deviations were identified.

7.

Reac, tor Operation

The reactor is used primarily for performing experiments associated with

the nuclear engineering teaching program.

These experiments involve

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sample irradiation, approach to critical, reactivity measurements, period

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measurements, neutron temperature measurements, power calibration, and

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flux distribution.

The reactor is also operated during demonstration

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courses and the operator requalification orogram.

On March 30, 1988, the NRC inspector witnessed startup, operation, and

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shutdown of the reactor during performance of a standard operator

requalification program demonstration.

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No violations or deviations were identified.

8.

Requalification Training

The licensee's NRC approved Reactor Operator and Senior _ Operator

Requalification Program dated April 12, 1987, was reviewed.

The program

is designed to meet the conditions as set forth in 10 CFR Part 50.54(i)

and 10 CFR Part 55, Appendix A.

The NRC inspector reviewed the individual licensed operators files and

concluded that the operator requalification program as described and

approved is being implemented.

No violations or deviations were identified.

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9.

Procedures

The NRC inspector reviewed the licensee's written procedures to determine

compliance with the requirements of TS 6.6.

The procedures associated

with the reactor are contained in-the manual, "AGN-201M Reactor Operation

and Operator Training Manual," dated July 1984.

The manual contains

procedures for the following categories:

General Design Features.

Administration

Operating Procedures

Maintenance and Inspections

Technical Specifications

The NRC inspector noted that the operating procedures appeared weak in the

area of conduct of irradiations and experiments that could effect the

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operation or safety of the reactor and preventative or corrective

maintenance which could affect the safety of the reactor.

The NRC

inspector also noted that the TS contained in the manual did not contain

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all the information included in the current TS.

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No violations or deviations were identified.

10.

Surveillance Requirements

The NRC inspector reviewed surveillance activities for reactivity limits,

control and safety systems, reactor structure, and radiation ronitoring

and control to determine compliance with TS 4.0.

The NRC inspector

verified that limits regarding excess reactivity, centrol and safety rods

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worth, scram capabilities, and safety systems were not exceeded.

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records of surveillance test results did not indicate any unusual

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conditions.

No violations or deviations were identified.

11.

Experiments

The NRC inspector reviewed the licensee's experiment records and reactor

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logs to determine compliance with TS 3.3.

The NRC inspector determined that the licensee had not introduced any new

experiments in the reactor since the previous inspection.

Experiments

which had been conducted were used with approved procedures under approved

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reactor conditions.

No violations or deviations were identified.

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12.

Fuel Handling Activities

The NRC inspector reviewed the licensee's fuel handling activities to

determine compliance with TS 4.1 and 4.2.

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The NRC inspector verified the licensee had approved procedures for fuel

handling activities and reviewed them for'their-technical adequacy in the

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areas of radiation protection and criticality' safety.

The NRC inspector

determined by record review and discussions with personnel that fuel-

handling operations and startup tests were carried out in conformance with

the licensee's approved procedures.

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No violations or deviations were identified.

13.

Changes-

The'NRC inspector discussed with. licensee representatives and reviewed

reactor maintenance and operation records and determined that no changes

were made since the previous inspection to the facility or procedures that

would require a safety evaluation pursuant to 10 CFR Part 50.59.

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No violations or deviations were identified.

14.

License Conditions

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The NRC inspector reviewed the following license conditions:

2.C.(1) - Maximum Power Level

P..C.(2) - Technical Specifications

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TS 6.9 - Reports

TS 6.10 - Records

TS 6.9.1 states, in part, a routine annual operating report shall be

submitted no later than 90 days following June 30 and provide a

comprehensive summary of the oparating experience.

The NRC inspector determined on March 28, 1988, that the annual operating-

report for the period July 1,1986, through. June 30, 1987, had not been

submitted.

The licensee reviewed their records and also concluded the

annual operating report had not been submitted.

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The failure to submit an annual operating report is considered an apparent

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violation of TS 6.9.1.

(252/8801-01)

15.

Radiation Protection

The NRC inspector reviewed the licensee's radiation protection program to

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determine compliance with 10 CFR Parts 19.11, 19.12, 19.13, 20.101,

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20.104, 20.201, 20.202,-20.203, 20.207, 20.401, 20,403, 20.405, 20.408,

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and 20.409, and TS 4.4.

The NRC inspector reviewed records, interviewed personnel, made

observations, and performed independent' surveys.

The NRC inspector discussed with licensee representatives the results of

the annual radiation survey requirements in TS 4.4.c.

The TS state that

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this survey is required to determine the location of radiation and high

radiation areas corresponding to reactor operating power levels.

The

licensee had performed a survey on December 2, 1987, with the reactor

operating at 3.4 watts and only documented the radiation levels at the six

specific locations which are routinely monitored.

The NRC inspector

stated the annual radiation survey should be a comprehensive survey of the

reactor room.

The licensee acknowledged the NRC inspector's concern and

stated that future radiation surveys would be more detailed.

The NRC inspector noted that all portable radiation survey instrumentation

assigned to the reactor facility including pocket dosimeters were being

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calibrated at an annual frequency in compliance with TS 4.4.a.

No violations or deviations were identified.

16.

Environmental Surveillance / Radioactive Releases

The licensee does not maintain a detailed environmental surveillance

program; e.g., collection and analysis of water, soil, vegetation samples.

There are no specific license requirements that such a program be

maintained.

A licensee representative stated that no liquid effluents have been made

since the last inspection.

The licensee's operations records indicate

that gaseous releases are within 10 CFR Part 20 limits.

No violations or deviations were identified.

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17.

Transportation (Fuel Shipments)

The NRC inspector verified that there had been no fuel shipments since the

previous operational inspection.

No violations or deviations were identified.

18.

Nuclear Materials Safeguards

The NRC inspector reviewed the nuclear material inventory program to

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determine compliance with License Condition 2.B.(2).

The NRC inspector reviewed the accountability procedures', practices, and

material status records.

The procedures, practices, and records were

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found to be well implemented.

Responsibilities and response requirements

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were defined clearly and understood, and appropriate test procedures were.

being used.

The licensee had not received or shipped any materials since

the previous inspection.

No violations or deviations were identified.

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19.

Emergency Planning

The NRC inspector reviewed the emergency preparedness program to determine.

compliance with the emergency plan requirements.

The emergency plan for the UNM AGN-201M reactor . facility had been. revised

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and submitted to the NRC as part of the application for renewal of

Operating License No. R-102, dated June 2,1986.

The licensee had conducte'd an emergency drill on March 13, 1987.

The NRC

inspector reviewed the results of this drill and the associated

evaluation.

No violations or deviations were identified.

20.

Physical Security

The NRC inspector reviewed the implementation of the licensee's physical'

security plan to determine compliance with 10 CFR Part 73.

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No violations or deviations were identified.

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21.

Exit Interview

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The NRC inspector met with licensee representatives' identified in

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paragraph I at the conclusion of the inspection on March 31, 1988.

The

NRC inspector summarized the scope and findings of the inspection.

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