ML20199C115
| ML20199C115 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 01/23/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20199C091 | List: |
| References | |
| 50-288-97-202, NUDOCS 9801290135 | |
| Download: ML20199C115 (17) | |
See also: IR 05000288/1997202
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ENCLOSURE 2
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U S. NUCLEAR REGULATORY COMMISSION
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Docket No: 50-288
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License No: R 112
l - Report No: 50-288/97 202
i Licensee: Reed College
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Facility: Reed College Reactor Facility
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Location: 3203 S.E. Woodstock Boulevard .
Portland, OR 97202-8199
Date' December 15 18,1997
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Inspector: C. H. Bassett
-Senior Non-Power Reactor inspector
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Approved by: Seymour H. Weiss, Director
Non-Power Reactor and Decommissioning
Project Directorate
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9801290135 980123
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EXECUTIVE SUMMARY
Reed College
Report No: 50-288/97 202
The primary focus of this routine, announced inspection was the on site review of selected .
aspects of the licensee's Class 11 non-power reactor operation including: organization and l
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staffing; review and audit functions; procedures; radiation protection and ALARA programs; i
effluer;t and environmental monitoring; the shipment of radioactive mate *ial; the safeguards 1
and security program; and the material control and accounting program. '
Changes, Organization, and Staffino
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- The licensee's organization and staffing remain in co"1pliance with the requirements
j specified in the Technical Specifications.
Review and Audit Functions
- Aucits were being conducted by the Radiation Safety Committee (RSC) and the Reactor
Operations Committee (ROC)in compliance with the requirements specified in the
Technical Specifications (TS).
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- One violation was noted for failure of the RSC to meet twice yearly as required by the
TS.
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Procedures
e Facility procedures were acceptable and satisfied TS and administrative procedure
4 requirements for being revised by the licensee, and revier.ed and approved by the RSC.
l and the ROC.
- Radiation Protection Program.
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e An apparent violation with two examples was noted dealing with failure to follow
procedures.
- - Surveys were generally completed and documented acceptably to permit evaluation of
the radiation hazards that might exist.
- Postings met the regulatory requirements.
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- Personnel dosimetry was being worn as required and doses were well within the
licensee's procedural action levels, and NRC's regulatory limits.
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e Radiation monitoring equipment was being maintained and calibr ited as required.
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- The Radiation Protection and ALARA Programs satisfied regulatory requirements.
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Effluent and Environmental Monitoring
- Effluent monitoring satisfied license and regulatory requirements and releases were
within the specified regulatory and TS limits.
Transportation of Radioactive Materials
e An apparent violation was noted for f ailure properly to complete the required shipping
papers for eight shipments of radioactive material.
Safeguards and Security
- The NRC approved security program at the facility was acceptably carried out.
Material Control and Accountability
- One violation was identified for failure to submit material status reports withing the
time frame specified in the regulations.
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REDORT DETAILS
Summary of Plant Status
The licensee's two hundred and fifty-kilowatt (250 kW) TRIGA Mark l research reactor
continues to be operated in support of undergraduate instruction and laboratory
experiments, reactor operator training, and various types of research. During the
inspection, the reactor was not operated because it was " finals" week and students were
taking their final examinations.
1. Changes, Organization, and Staffing (69001)
a. Inspection Scope
The inspector reviewed the following regarding the licensee's organization and
staffing to ensure that the requirements of Technical Specification (TS) Sections
1.1.1,1.1.2, and 1.1.3 were being met:
. the organizational structure,
. management responsibilities, and
. staffing requirements for safe operation of the Reed Reactor Facility (RRF).
b. Observations and Findings
Through discussions with licensee representatives the inspector determined that
management responsibilities and the organization at the f acility had not changed
since the previous NRC inspection in December 1994 (Inspection Report
No. 50 288/94-01). The inspector determined that the Facility Director retained
direct control and overall responsibility for managerrent of the facility as specified
in the TS. The Facility Director reported to the President of Reed College through
the Dean of the Faculty.
Through review of records and logs and discussions with licensee personnel, the
inspector determined that the staffing at the facility was acceptable to support the
work and ongoing activities and met the requirements of the TS.
c. Conclusions
The licensee's organization and staffing remain in compliance with the
requirements specified in the Technical Specifications.
2. Review and Audit Functions (69001)
, a. inspection Scope
The inspector reviewed the following to ensure that the audits and reviews
stipulated in the requirements of TS 1.2 and 1.3 were being completed: 4
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Reactor Operations Committee (ROC) meeting minutes,
. Radiation Safety Committee (RSC) meeting minutes,
- RRF Administrative Procedures, and
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+ the TS duties specified for the ROC and the RSC including the committees'
review and audit functions.
The inspector nisn toured the licensee's facility to note any changes that may have
been made ant .aviewed the program established by the licensee to ensure that
activities at the facility were reviewed and audited as required,
b. Observations and Findings
Section 1.2 Of the TS requires that the Radiation Safety Committee meet at least
twice yearly to review safety aspects of f acility operation.
The inspector reviewed the ROC's and RSC's meeting minutes from January 1995
to the present. These meeting minutes showed that the ROC and the RSC had
considered the types of topics outlined by the TS. During the review, the
inspector noted that a meeting of the RSC had been c.alled in May 1997. The RSC
apparently met but a quorum was not present, no official actions could be taken,
and no meeting minutes were recorded. The RSC did meet again in September but
no second, formally documented meeting was convened to meet the requirements
of the TS.
The licensee was informed that failure of the RSC to meet twice yearly to review
safety aspects of the facility operation was an apparent violation of TS 1.2 (VIO
50-288/97 202-01).
The inspector noted that both committees completed audits of different but
complimentary aspects of the r0 actor facility operations and programs. The
inspector noted that, since the last NRC inspection, audits had been completed by
the ROC and the RSC in those areas outlined in the TS. The audits were varied so
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that all aspects of the licensee's safety program were reviewed every one, two, or
three years depending on the subject. The inspector noted that the audits and the
resulting findings were detailed and that the licensee's responses and corrective
actions were acceptable.
The inspector toured the control room, pool area, and selected supoort laboratories
and areas. Control of radioactive material and control of access to radiation areas
were acceptable.
c. Conclusions
4 One violation was notad for failure of the RSC to meet twice yearly as required by
the TS.
Audits were being conducted by the ROC and the RSC according to the
requirements specified in the Technical Specifications,
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3. Procedures (69001)
- a. Inspection Scope
The inspector reviewed the following to ensure that the requirements of TS Section
I were being met concerning written procedures:
-+ selected operations procedures,
+ selected safety procedures, and
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the process used by the licensee to revise, review, and approve all facility
procedures,
b. Observations and findinas
The inspector verified that written procedures were reviewed as required. Also,
revisions to procedures were presented by the licensee to the RSC and/or the ROC
for review and approval. The inspector verified that the latest revision to the RRF
Standard Operating Procedure (SOP) 20, Health Physics, had been reviewed and
approved by the RSC on January 1997. The revisions were acceptable and in
accordance with 10 CFR 20, TS, and RRF Administrative Procedures,
c. Conclusions
Facility procedures were acceptable and satisfied TS and administrative procedure -
requirements for being revised by the licensee, and reviewed and approved by the
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4. Radiation Protection Program (69001) ;
a. l_nmection Scope
The inspector reviewed the following to verify compliance with 10 CFR 20 and the
applicable licensee TS requirements and procedures:
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health physics (HP) and reactor surveillance survey records,
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radiological signs and posting,
+ dosimetry records,
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calibration records and periodic check records for radiation monitoring
instruments,
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the Radiation Protection Program, and
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the ALARA Program.
The inspector also observed the use of dosimetry and radiation monitoring
equipment during tours of the facility. Licensee personnel were interviewed as
well.
b. Observations and Findings
(1) Surveys
TS l.5 requires that written instructions shall be in effect.
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SOP 23, " Health Physics Wipe Tests," dated November 1997, requires in
Section 23.2 that wipe test shall be performed (inside the RRF) at least every
two weeks, not to exceed 18 days, and whenever activities involving
radioactive materiais require additional wipe tests.
The inspector noted through reviews of records that daily and weekly ,
contamination and/or radiation surveys were completed by the RRF staf f as
required by TS and licensee procedures. Results were evaluated and
corrective actions taken when readings or results exceeded set action levels.
However, a review cf the biweekly wipe tests showed that a wipe test had
been completed on April 11,1997 and not again until April 30, a period
exceeding 18 days. Also, following the wipe test on April 30,1997, the next
wipe test was not conducted until May 23, a second period exceeding the
18-day maximum allowable time The wipe tests are used by the licensee to
detect and determine the extent of removable contamination inside the RRF '
and to monitor exits from the facility to determine if contamination is being
spread outside the facility. During the period from April through May, routine
operations were being conducted. No unacceptable cont 6mination was
detected on subsequent wipe tests.
The licensee was informed that failure to perform the biweekly wipe tests
within the 18-day time frame allowed by procedure wes an apparent violation
of TS l.5 (VIO 50-288/97-202-02),
(2) Postings and Notices
10 CFR 19.11 requires the licensee to post current copies of various
documents including the regulations in 10 CFR 20, the f acility license,
procedures, and any notice of violation as applicable. If it is not practicable
to post such documents, the licensee may post a notice which describes the
document and states where it may be examined. The licensee is also required
to post e :urrent copy of NRC Form 3.
Postings at the entrances to the controlled areas, including the Reactor room,
were acceptable for the hazards present. The f acility's radioactive material
storage areas were properly posted. No unmarked radioactive material was
noted.
Copies of current notices to workers required by 10 CFR Part 19 were posted
in appropriate areas in the facility, Copies of NRC Form 3, although not the
most current, were also posted.
The licensee was informed that failure to post current copies of NRC Form 3
was an apparent violation of 10 CFR 19.11. However, this failure constitutes
a violation of minor significance and is being treated as a Non-Cited Violation
(NCV), consistent with Section IV of the NRC Enforcement Policy
(NCV 50-288/97-202-03).
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(3) Dosimetry
The licensee used a National Voluntary Laboratory Accreditation Program
(NVLAP) accredited vendor to process personnel thermoluminescent
dosimetry. An examination of the records for the past three years through
the date of the inspection showed that all exposures were well within NRC
limits and licensee action levels. Most of the records suggested no exposure
above background. Dosimetry was acceptably used by facility personnel.
(4) Radiation Monitoring Equipment
Selected radiction monitoring equipment had the acceptable up t&date
calihetion sticker attached. The calibration of portable survey meters was
typically completed by the Reactor HP, CLiibration frequency me' procedural
requirements and records were maintained as required.
(5) Radiation Protection Program
The licensee's Radiation Protection Program was established in the " Reed
Reactor Facility Radiation Protection Plan," dated August 1994. It had been
reviewed and approved by the RSC and the ROC. The program included
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requirements that al! personnel who had unescorted access to the RRF
receive training in radiation protection, policies, procedures, requirements,
and facilities. The program appeared to be acceptable.
No Respiratory Protection Program was required.
SOP 28, " Radiation Work Permits," dated August 1994, Section 28.3
requires that the Radiation Work Permit (RWP) shall be reviewed and
approved by the Director or the Associate Director prior to the operation.
The inspector reviewed the RWPs that had been written and used during the
past three years. It was noted that RWP #2, dated November 2,1996,
Part I, had been written by the Associate Director. The RWP had been
reviewed and approved by a Senior Reactor Operator (SRO) and the operation
completed. The RWP had not been reviewed by the Director prior to the
operation as required. The licensee indicated that this was en apparent
oversight by the staff.
The licensee was informed that failure to have RWP #2 reviewed and
approved by the Director prior to the operation was another example of an
apparent violation of TS l.5 (VIO 50 288/97-202-02).
(6) ALARA Program
The ALARA Program was also outlined and established in the licensee's
" Reed Reactor Facility Radiation Protection Plan," dated August 1994 and
emphasized in the " Reed College Radioactive faaterials Procedures Manual,"
and in the " Reed Reactor Facility Training Manual." The ALARA program
provided guidance for keeping doses as low as reasonably achievable and was
consistent with the guidance in 10 CFR 20.
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c. Conclusions
Two examples were noted concerning an apparent f allute to foilow procedures.
Surveys were generally completed and documented acceptably to permit evaluation
of the radiation hazards that might exist. Postings met regulatory requirements.
One NCV was identified for failure to post a current copy of NRC Form 3.
Personnel dosimetry was being worn as required and doses were well within the ;,
licensee's procedural action levels and the NRC's regulatory limits. Radiation
. monitoring equipment was being maintained and calibrated as required. The
Radiation Protection Program and the ALARA Program satisfied regulatory
requirements.
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5. Effluent and Environmental Monitoring (69001)
a. Inspection Scope
The inspector reviewed the following to verify compliance with the requirements of
10 CFR 20 and TS G.1-3:
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the licensee's environmental monitoring program,
+ annual reports,
+ release records, and
+ .:ounting and analysis records,
b. Observation and Findings
Gaseous releases were calculated as outlined in the licensee's approved methods -
and documented in the 1996-1997 Annual Report. The inspector noted that the
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gaseous releases documented in the 19951996 and the 19961997 Annuel
Reports were apparent discrepancies. The reports indicated a release in * mci"
(millicuries) as opposed to the typical "uCi" (microcuries) range, it was also noted
that the calculated release during the 1995-1996 period was reported as a 5.3 E-9
" mci"/ml (millicuries per milliliter) whereas the calculated release during the
1996 1997 period was 1.8 E 11 " mci"/ml. It was pointed out that the figure of
5.3 E 9 was probably a factor of 100 too high, based on the available data. The
licensee stated that these issues would be reviewed and corrected as needed.
The licensee was informed that their actions to review and correct the release data
- documented in the past two annual reports would be tracked by the NRC as an
- Inspector Follow-up Item (IFI) and reviewed during a subsequent inspection
(IFl 50-288/97 202-04). --
Based upon a review of the data, the re: eases during 1995-1996 and 1996-1997,
appeared to be well within the annual dose constr 'nt of 20.1101(d) and TS limits.
No liquid releases had occurred at the f acilit:
c. Conclusion
Effluent monitoring satisfied license and regulatory requirements and releases were
within the specified regulatory and TS limits.
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6. Transportation (86740)
a. Inspection Scope
The inspector interviewed licensee personnel and reviewed various records to
verify compliance with the requirements of 10 CFR 71.5 br shipments of licensed
material,
b. Ouservations and Findings
10 CFR 71.5(a) requires that a licensee, who delivers licensed material to a carrier
for transport, comply with the applicable requirements of the regulations
appropriate to the mode of transport of the Department of Transportation (DOT)in
49 CFR Parts 171 189.
49 CFR 171.2(a) prohibits any person from offering hazardous material for
transportation unless, among other requirements, the hazardous material is
properly classified, described, packaged, marked, labeled, and in condition for
shipment required or authorized under the Hozardous Material Regulations (49 CFR
171 177).
Through records reviews and discussions with licensee personnel, the inspector
determined that various shipments of licensed material had been made since the
last inspection. All shipment records had been completed and were being
maintained a required. The records showed that, in general, the material had been
properly described and classified, that ths correct labeling had been provided, and
that the contamination and radiation levels of th9 packages shipped had been
recorded acceptably. However, some discrepancies were noted on the shipping
papers as follows:
(1) Shipment Number (No.) 95-1, dated March 30,1995 - The shipping papers
did not list the chemical or physical form of the material being shipped. The
chemical form and physical form of the material are required to be listed on
, the shipping papers.
(2) Shipment No. 95-2, dated October 2,1995 - The shipping papers showed the
Transport Index (TI) as "O." The dose rate at one meter from the package
was 0.2 millirem per hour (mr/hr). Therefore, the correct Tl would have been
0.2.
(3) Shipment No. 96-2, dated May 17,1996 - The external radiation level of the
package was 1.5 mr/hr. According to the shipping papers, the package was
labeled with a Radioactive White Ilabel. With an external radiatio, level of
1.5 mr!hr, the package required a Radioactive Yellow 11 label.
(4) Shipment No. 96 3, dated December 16,1996 - The shipping papers
indicated the Tl as "0." The dose rate at one meter from the package was
0.2 mr/hr. Therefore, the correct Tl would have been 0.2. Also, the
chemical arid physical form of the material being shipped was not listed as
required.
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(5) Shipment No. 971, dated May 6,1997 The external radiation level of the
package was 1.0 mr/hr. According to the shipping papers, the package was
labeled with a Radioactive White I label. With an external radiatior level of
1.0 mr/hr, the package required a Radioactive Yellow 11 label.
(6) Shipment No. 97 2, dated July 11,1997 The total activity was not listed in
the International System of Units (SI units) or in both Si units and the
customary units (i.e., curies or mil:icuries, etc.). The listing of total activity in
SI units or both Si and customary units on the shipping papers was required
after April 1,1997.
(7) Shipment No. 97-3, dated December 1,1997 - The total activity was not
listed in the International System of Units (St units) or in both SI units and the
customary units. The listing of total activity in Si units or both Sl and
customary units on the shipping papers was requ' red after April 1,1997.
Also, the shipping papers showed the Transport index (TI) as ~0.5." The
dose rate at one meter from the package was less than 0.2 mr/hr or
background. Therefore, the correct Tl would have been 0.
The licensee was informed that f ailure to fill out the shipping papers according to
the regulations was an apparent violation of 10 CFR 71.5(a) (VIO 50-288/97-202-
05).
c. Conclusions
One apparent violation was nJted for feilure properly to comolete the required
shipping papers for eight shipments of radioactive material.
11. Physical Security (81401,81402,81431)
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a. Inspection Scope
, To verify compliance with the licensee's NRC-approved Physical Security Plan
(PSP) and to assure that changes, if any, to the plan had not reduced its overall
effectiveness, the inspector reviewed:
. logs, records, and reporn,
a the security organization,
. key control,
. Intruder detection and physical barriers,
. access controls, and
+ procedures.
. Observations and Findings
The inspector determined that the licensee's physical protection program
conformed to NRC requirements and the licensee's PSP and implementing
procedures.
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c. Conclusion
The NRC-approved security program at the facility was acceptably carried out. .
12. Material Control and Accounting (85102)
a. Inspection Scope
To verify compliance with 10 CFR 70, the inspector reviewed:
+ storage areas,
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procedures for tracking the quantity, identity, and locaCon of Special Nuclear
. Material (SNM),
+ assignment of responsiollitieJ,
+ annual inventory results, and
+ associated records and reports,
b. Observations and Sindings
The des 10n of item colitrol areas ensured that physical and administrative control-
of SNM would be maintained. Licensee procedures for tracking SNM were
acceptably implemented. Written stattments of responsibility and authority were 4
established for positions with respansibility for SNM. Records showed that
physicalinventories were conducted at least annually as required by 10 CFR
70.51(d).
10 CFR 74.13(1) requires that each licensee shall compile a report as of March 31
and Septembs 30 of each year and file it within 30 days after the end of the
period covered by the report.
Material Status Reports (DOE /NRC Form 742) had been submitted by the licenses
for the appropriate periods from October 1,1994, through September 30,1997, as
required by 10 CFR 70.53. However, the report covering the period from
October 1,1995, through March 31,1996, had not been submitted with 30 days
of the end of the reporting period but had been submitted on May 22,1996.
Similarly, the report for the period from April 1,1996, through September 30,
1996 had been submitted on November 20,1996. The report for the period from
October 1,1996, through March 31,1997, had been submitted May 13,1997.
The report for the period from April 1,1997, through September 30,1997, had
been submitted on November 4,1997.
The licensee was informed that failure to submit the reports within 30 days after
the end of the period covered by the reports was an apparent violation of 10 'i
74.13 (VIO 50-288/97-202-06).
Exhibits I and 11 (attached to this report) summarize the licensee's uranium and
plutonium material balances from October 1,1994 through September 30,1997.
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c. Conclusion
. One violation was identified for failure to submit material status reports within the
time frame specified in the regulations.
7. Exit interview
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The inspection scope and results were summarized on December 18.1997, with
members of licensee management. The inspector described the areas inspected and
discussed in detail the inspection findings.
No dissenting comments were received from the licensee. The licensee did not identify
as proprietary any of the material provided to or reviewed by the inspector,
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E/ RTIAL LIST OF PERSONS CONTACTED
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S.- Frantz, Director, Reactor Facility >
C. Melhus, Assistant Director, Reactor Facility
A. Meadenhall, Shift Supervisor, Community Safety
- T. Shaver, Shift Supervisor, Community Safety
P. Steinberger, Dean of the Faculty, Reed College l
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lNSPECTION PROCEDURES USED
IP 69001: Class 11 ilon Power Reactors
IP 81401: Plans, Procedures, and Reviews
IP 81402: Reports of Safeguards Events
IP 81431: Fixed Site Physical Protection of Special Nuclear Material of Low Strategic
Significance
IP 85102: Material Control and Accounting Reactors '
IP 8674C: Inspection of Transportation Activities _
ITEMS OPENED CLOSED. AND DISCUSSED
Ooened
50 288/97 202-01 VI Failure of the RSC to meet twice yesrly to review safety
aspects of the facility operation.
60-288/97 202-02 VI- Failure to follow procedure due to failure to perform the
biweekly wipe tests within the 18-aay time frame allowed by
procedure and f ailure to have RWP #2 reviewed and approved
by the Director.
50-288/97 202-03 NCV- Failure to post a current copy of NRC Form 3 as required by
50 288/97-202-01 IFl Follow-up on the licensee's actions to review and correct the
release data documented in the past two annual reports.
50 288/97-202-05 -VI Failure to fill out the shipping papers according to the 49 CFR
171-189 as required by 10 CFR 71.5(a).
50-288/97-202-06 VI Failure to submit the reports within 30 days after the end of
the period covered by the reports.
Closed
None
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UST OF ACRONYMS USED
ALARA As low as reasonably achievable
i- CFR Code of Federal ReCulations
IFl ' Inspector Follow up ltem
~iP - Inspection Procedure
. . kW kilowatt
NCV Non-Cited Violation
NRC- Nuclear Regulatory Commission
NVLAP National Voluntary Laboratory Accreditation Program
. POR Public Document Room
PSP Physical Security Plan
ROC Reactor Operations Committee
. RRF Reed Reactor Facility
RSC Radiation Safety Committee
RWP Radiation Work Permit
SOP' Standard Operating Procedure 1
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! .Tl Transportation Index
TS Technical Specification
VIO Violation
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EXHIBIT I
REED REACTOR FACILITY
Docket No. 50-288 License No. R-112
Material Balance for Period: October 1,1994 - September 30,1997
Report:ng Identification Symbol: ZSW Report Units: Grams
High Enriched Uranium Plutonium
Element isotope Element isotope
Beginning invento'y: 6 6 2 2
(October 1,1994)
Receipts:
From Flur Daniels
Hanford (HTA): 4 4 0 0
Production: 0 0 1 1
Material to Account for: 10 J 3 J
Removals:
Shipments: 0 0 0 0
Fission and
Transmutation: 0 0 0 0
Inventory Difference: 0 0 0 0
Decay: O O O O
Total Removals: 0 0 0 0
Ending inventory:
(September 30,1997) 10* 1Q* J' * 3**
- = Fission chambers
- * = Contained in the fuel (the licensee's PuBe suurces are maintainedIlicensed under a
State of Oregon license)
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EXHIBIT ll
REED REACTOR FACILITY
Docket No. 50 288 License No. R-112
Material Balance for Period: O_g,tober 1,1994 - September 30,1997
Reporting identification Symbol: ZSW Report Units: Grams
Low Enriched Uranium
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Element Isotope
Beginning inventory: 12596 2475
(October 1,1994)
Receipts: 0 0
Material to Account for: 12596 _217_Q
Removals:
Shipments: 0 0
Fission and
Transmutation: -5 -6
Inventory Difference: 0 0
Decay: 0 0
Total Removals: -5 -6
Ending Inventory:
(September 30, 1997) - 12591 2469
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