ML20206E256
| ML20206E256 | |
| Person / Time | |
|---|---|
| Site: | 05000072, University of Utah |
| Issue date: | 11/09/1988 |
| From: | Baer R, Chaney H, Everett R, Joseph Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206E250 | List: |
| References | |
| 50-072-88-03, 50-407-88-03, 50-407-88-3, 50-72-88-3, CAL-88-06, CAL-88-6, EA-88-064, EA-88-64, NUDOCS 8811180021 | |
| Download: ML20206E256 (9) | |
See also: IR 05000072/1988003
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-072/88-03 Operating License: R-25
50-407/88-03 R-126
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Dockets: 50-072
50-407
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Licensee: Or. James J. Brophy
Vice President of Research
University of Utah
Salt Leke City, Utah 84112
Facility Name: Nuclear Engineering Laboratory (NEL) i
Inspection At: University of Utah (VofU), Merrill Engineering Building,
Salt Lake City, Salt Lake County, Utah
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Inspection Conducted: October 5-6, 1988
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Inspectors: O
H. D. Chaniy, Senior Radiat lon Specialist Date
Facilities Radiological Propection Section
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_S - b C> t( b b
Jf A. elly, Senior Securitylpeptabt Date
Skuri y and Emergency Preparedness Section
Approved: , // v M
. E. Baer, CTief, facilities Radiological Date
Protection Section
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LtlY lllfl68
R. J. Everett, Chief, Security and Emergency Date
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Preparedness Section
Inspection Sumary
Inspection Conducted October 5-6, 1988 (Report 50-072/88-03: 50-40'/88-03) t
Areas Inspected: Reactise, announced inspection of the corrective actions
taken in response to the inspection findings discussed in NRC Inspection
Reports 50-072/88-01 and 50-407/88-01, and the July 8, 1988, Order and
Notices of Violation and Deviation (EA 88-64).
Results: Within the area inspected, no violations or deviations were
identified.
8811180021 881114
PDR ADOCK 05000072
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DETAILS
1. Persons Contacted
VofU
- D. K. Gehmlich, Reactor Administrator
"G. M. Sandquist, Director, Nucitar Engineering Laboratory
- K. C. Crawford, NEL, Reactor Supervisor
W. Shepard, Chief of Police
- J, S. Bennion, Senior Reactor Engineer
- T. C. Gansauge, Senior Reactor Operator (SRO)
K. J. Schiager, Radiation Safety Officer (RS0)
D. Bird, Police Officer
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J. Reyes, Police Officer in Training
S. Jensen, Police Officer in Training
W. Witbeck, Carpentry and Key Shop Supervisor
- Denotes those present at the exit interview on October 6, 1988.
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2. Background
AGN-201 - The AGN reactor is being decomnissioned. The reactor has not
been operated since February 1985 due to the lack of replacement parts for
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the reactor operating console. The licensee performs periodic
surveillance on the integrity of the AGN core and shield water vessel.
The licensee has removed the 25 tons of brick that was used as radiation
shielding and a physical security barrier for protection of the AGN fuel.
The licensee has surveyed the bricks for radioactivity and the NRC has
also performed confirmatory measurements on the bricks. The bricks
apparently do not contain any radioactive materials or induced radioactive
contamination and have been released by the licensee for unrestricted use,
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The licensee is currently evaluating the method to be employed for removal
and shipment of the AGN fuel to the Department of Energy repository. Once
the AGN fuel is removed, the licensee will submit a decommission plan to
- the NRC for approval. Currently, only Dr. Sandquist is licensed to
operate the AGN reactor.
TRIGA - As of the dstes of the inspection, this reactor was not being
operated by the licensee due to a commitment to the NRC not to operate the
reactor urtti written permission to do so is issued by the Regional
Administrator. Confirmatory Action Letter 88-06 issued by the Region
confirmed this agreement. Prior operating history of the TRIGA reactor
was previously discussed in NRC Inspection Report 50-407/88-01. ;
, 3. NRC Inspectors Observation *
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The NRC inspectors observation is a matter discussed with the licensee
during the exit interview. Observations are neither violations,
deviations, nor unresolved items. They have no specific regulatory
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requirement, but are suggestions for tne licensee's consideration.
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Frequency of Audits - The licensee's Operating Plan does not properly
distinguish between the more often conducted (every 6 months to i year) [
l performance based audits of a program that is important to safety and a l
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required biennial programmatic review of an entire program. Currently, l
the Emergency Plan and the Physical Security Plan (PSP) are only reviewed
, on a biennial basis with no in between performance based audits of
individual segments of the two plans.
4. Followup on Order Modifying the Licensee's Licenses _
On July 8,1988, the NRC issued an Order Modifying Licenses to the
licensee requiring that an individual with at least 1 year of reactor
operating experience be retaineo to serve as the reactor supervisor.
Furthermore, this individual must devote at least three quarters of his
time to reactor activities. i
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The NRC inspectors reviewed the licensee's commitments contained in a
letter to the NRC dated August 20, 1988; examined the qualifications of '
j the individual retained as reactor supervisor; and examined the employment
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contract (3 year contract) agreed to by the individual retained. The NRC ,
- inspectors determined that the licensee had met the Order's stipulations. !
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5. Licensee's Actions on Previously Identified Inspaction Findings ;
(Closed) Violation (407/8801-01): Failure to Perform Fuel Element '
Temperature Comparisons - This item was previously discussed in NRC i
Inspection Report 50-407/88-01 and involved the licensee's failure to i
properly perform tne Technical Specification (TS) requir:-d comparison of i
fuel element temperatures with previous operational dati invo',ving the l
- same core configuration and power level. The NRC inspectors examined the
- licensee's implemeatetten of corrective acci- committed to in their L
- April 8 and August 4, 1988, responses to .he vic'ation. The Itcensee's l
corrective actions (Facility Operacing Manual (FM] instructions and r
a documentation of fuel temperature comparisons on reactor operation f
i checklist) appear to be adequate to prevent a recurrence of the violation ;
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in the future. l
(Closed) Violation (407/8801-02): premature Criticality During :
Start-Up - This item was previously discussed in NRC inspection '
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Report 50-407/88-01 and involved the licensee's failure to have in effect '
procedures or instructions requiring reactor operators to review logs and .
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reactor core modifications prior to starting up the TRIGA reactor. The
i tiRC inspectors examined the licensee's implementation of corrective i
actions committed to in their April 8, August 4, and August 25, 1988,
responses to the violation. The licensee s corrective actions (FOM j
instructions and checklists for start-up) appear to be adequate to r
prevent a future recurrence of the violation.
, (Closed) Violation (407/8S01-03): Radiation and Contamination Surveys - l
! This item was previously discussed in NRC Inspection Report 50-407/88-01
and involved the licensee's failure to properly perform radiation
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surveys on components removed from the TRIGA reactor and a failure to
survey and identify loose surface contamination within the facility's
exhaust ventilation duct work. The NRC inspectors examined the
licensee's implementation (documentation of NEL surveys and NRC conducted
independent radiation and contamination surveys within the NEL) of
corrective actions ommitted to in their April 8. August 4, and
August 25, 1988, responses to the violation. The licen we's corrective
actions (FOM instructions on the conduct of radiation surveys, the
RadiationSafetyOfficer(RS0)procedureonconductofroutiresurveys,
and personnel training) appear to be adequate to prevent a future
recurrence of the violation.
(Closed) Violation (407/8801-04): Failure to Install Continucus Airborne
Radioactivity Monitor (CAM) - This item was previously discussed in NRC
Inspection Report 50-407/88-01 and involved the licensee's failure to
install a CAM in accordance with Technical Specification (TS) 5.4
requirements. The NRC inspectors examined the licensee's implementation
of corrective actions committed to in their April 8 and August 4, 1988,
responses to the violation. The licensee's corrective actions which
included the installation of a licensee constructed air monitoring
system that provides continuous particulate and/or iodine sample
collection and monitoring, periodic sample removal and laboratory
analysis, data logging, alarm capability, and safety system actuation
appears to be adequate to prevent a future recurrence of the violation.
(Closed) Violation (407/8801-05): Failure to Foilaw Procedures - This
item was previously discussed in NRC Inspection Report 50-407/88-01 and
involved the failure of a University Policeman to follow mandatory
instructions when responding to an NEL alarm. The NRC inspectors examined
the licensee's implementation of corrective actions (observed training
of police officers and conducted an unannounced security response drill)
committed to in their April 8 and August 4,1988, resportses to the
violation. The licensee's corrective actions appear to be adequate to
prevent a future recurrence of the violation.
(Closed) Violation (407/6801-06): Failure to Properly Secure Fuel
Handling Tool - This item was previously discussed in NRC Inspection
Report 50-407/88-01 and involved the licensee's storage of the TRIGA fuel
handling tool in an unlocked cabinet. The NRC inspectors examined the
licensee's implementation of corrective actions committed to in their
April 8 and August 4,1988, responses to the violation. The licensee's
corrective actions, including locking of the cabinet and installing a
lock on the tool that disables it functionally, appear to be adequate to
prevent a future recurrence of the violation.
(0 pen) Violation (407/8801-07); Decreasing the Effectiveness of the
PSP Without NRC Approval - This item was previously discussed in NRC
Inspection Report 50-072/88-01 and 50-407/88-01 and involved the
licensee's implementation of Revision 2 to the NEL PSP (a revision that
decreases the effectiveness of the PSP in several cases of AGN and TRIGA
reactor security) without prior NRC approval / review per 10 CFR
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Part 50.54(p)(1). The NRC inspectors examined the licensee's petition for
denial of the violation as set forth in their April 8 and August 4, 1988,
responses to the violation. The NRC inspectors informed the licensee that
the violaticn will stand as written and that further revisions to the PSP
are necessary to ensure that: (1) police response procedures are properly
control'ed (2) instructions on submittal and review of PSP revisions are
provided, and (3) instructions for the control of and changing of locking
a devices are addressed. This item will remain open pending licensee
submittal cf a revised PSP to the NRC for review and approval.
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(Cicsed) Unresolved Item (407/8801-08): Monthly Security Response Drill -
This item was previously discussed in NRC Inspection Report 50-407/88-01
and involved the licensee's failure to provide documentation that a monthly
University Police Department response drill was performed for June 1987.
1 The licensee provided the NRC inspectors with acceptable documentation
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verifying that the "squired drill had been performed on June 19, 1987.
(Closed) Deviation (407/8801-09): Area Radiation Monitor Set Points -
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This item was previously discussed in NRC Inspection Report 50-407/88-01
l and involved the licensee's deviation from a commitment in the TRIGA
license renewal application stating that area radiation monitors ( ARM)
low and high alarm set points would be maintained at 0.1 millirem per
. hour (9 rem /hr) and 1.0 mrem /hr, respectively. The NRC inspectors examined
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the '.icensee's implementation of corrective actions (submitting 10 CFR
Part 50.59 justification for changing the ARM alarm set points to 1 and
10 mrem /hr for the low and high alarms, respectively, as committed to in
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their August 4,1988 response to the deviation). The licensee's
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corrective actions (FOM instructions on proper ARM set points) appear to
be adequate to prevent a future recurrence of the deviation.
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(Closed) Open Ite9 (407/8801-10): NEL Reactor Program Support - This item
was previously discussed in NRC Inspection Report 50-407/88-01 and
involved the apparent lack of management support in providing oversight
- and adequate staffing for the NEL reactor programs. The NRC inspectors
examined the licensee's implementation of corrective actions including
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assignment of a new Reactor Administrator, retaining an additional
employee to serve as Reactor Supervisor, and filling of the vacant TS
)' position of Director of NEL committed to in their August 4, 1988, response
The licensee's corrective actions appear to be adequate
l to the open item.
1 to resolve the NRC's concerns in this area,
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(Closed) Open Item (407/8801-11): Reactor Ooerator Requalification
Tests - This item was previously discussed In NRC Inspection
l Report 50-407/88-01 and involved the content and method that tests were
administered for requalification of reactor operators. The NRC inspectors
i examined the licensee's implementation of the corrective actions
including the development and administering of new requalification tests
j to one operator, committed to in their August 4, 1988, response to the
' open item. The licensee's corrective actions appear to be adequate to
resolve the NRC's concerns in this area.
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(Closed) Open Item (407/8801-12): Operator Requalification Program
Checklist - This item was pre.iously discussed in NRC Inspection
Report 50-407/88-01 and involved the checklist's subjects. The NRC
inspectors examined the licensee's implementation of the corrective
actions including the inclusion of all requalification program
subjests/ areas of interest into the checklist, committed to in tt.eir
August 4, 1988, response to the open item. The licensee's corrective
actions appear to be adequate to resolve the NRC's concerns in this area. ;
(0 pen) Open Item (407/8801-13): Current Reactor Modification Training -
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This item was previously discussed in NRC Inspection Report 50-407/88-01
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and insclved the NRC concern regarding training of current reactor
a operators on the modifications to the reactor involving computerization of
< rod control functions and reactor parameter displays. The NRC inspectors
) examined the licensee's corrective actions committed to in their August 4 !
- 1988, response to the open item. With the addition to the staff of the '
i person responsible for the computer interface modifications and scheduled
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requalification training, the licensee's corrective actions appear to be
adequate to resolve the NRC's concerns in this area. This item will
remain open pending licensee completion of staff requalification training.
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(Closed) Open Item (407/8801-14): Documentation of Reactor SCRAM Times - r
- This item w s previously discussed in NRC Inspection Report 50-407/88-01
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snd involved the lack of specific notations as to be SCRAM times for
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control rods. The NRC inspectors examined the licensee's implemantation ,
of the corrective actions (Form 003 has been revised to reflect SCRAM test
- times) committed to in their August 4, 1988, response to the open item.
) The licensee's corrective actions (FOM instructions on SCRAM tests and
j documentation of times) appear to be adequate to resolve the NRC's
concerns in this area.
(Closed) Open Item (407/8801-15): Erroneous Reactivity Limit Values
Referenced - This item was previously discussed in NRC Inspection l
, Report 50-407/88-01 and involved the referencing, on forms, of incorrect I
! reactivity values for reactor operation. The NRC inspectors examined the i
l licensee's implementation of the corrective actions committed to in their l
J August 4, 1988, response to the open item. The licensee's corrective l
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actions which were to revise Forms 002, 003, and 014 to reflect the proper i
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reactivity value, appear to be adequate to resolve the NRC's concerns in !
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this area.
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(0 pen) Open Item (407/8801-16): Timeliness of Response to Reactor Safety ,
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Committee (RSC) Audit ~indings - This item was previously discussed in NRC l
Inspection Report 50-407/88-01 and involved the apparent excessive time i
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taken to resolve RSC audit findings. The NRC inspectors examined the
I licensee's implementation of the corrective actions committed to in their !
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August 4, 1988, response to the open item. The licensee's corrective
actions (RSC development of an audit-finding tracking system and the
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monitoring of audit finding responses) appear to be adequate to resolve !
l the NRC's concerns in this area. This item will remain open pending l
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development of the RSC's audit finding monitoring system and NRC :
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i evaluation of the NEL staff's responsiveness to audit findings during
future inspections.
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(Closed) Open Item (407/8801-17): Temporary Pen / Ink Changes to Official
Documents / Procedures - This item was previously discussed in NRC :
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Inspection Report 50-407/88-01 and involvecl the unstructured method that !
. changes (permanent and temporary) to licensee logs and documents were :
made. The NRC inspectors examined the licensee's implementation of the .
i corrective actions including the inclusion of instructions in the FOM cn I
approved methods for making document changes and training of NEL staff on l
these methods committed to in their August 4,1988, response to the ope: }
j item. The licensee's corrective actions appear to be adequate to resolve i
the NRC's concerns in this area.
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(Closed) Open Item (407/8801-18): NEL Procedure Control and
Distribution - This item was previously discussed in NRC Inspection
Report 50-407/88-01 and involved the licensee's lack of a procedure
control and distribution system. The NRC inspectors examined the i
a licensee's implementation of the corrective actions (establishing an index !
1 of NEL documents and their current revision date) committed to in their [
August 4, 1988, response to the open item. The licensee's corrective "
actions (inclusion of the official document index in the FCM) appear to te .
) adequat to resolve the NRC's concerns in this area. <
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l U bsed) Open Item (407/8801-19): Set Point !.imits and Tolerances - This ,
item was previously discussed in NRC Inspection Report 50-407/88-01 and
involved the calibration of L e fuel element thermocouple and the analog I
meter on the console that could not reference the desired set points ,
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conservatively enough. The NRC inspectors examined the licensee's [
} implementation of the corrective actions (modifying the NEL Form 011 to
i reference appropriate values for the thermocouple limits) committed to in
their August 4, 1988, response to the open item. The licensee's
corrective actions appear to be adequate to resolve the NRC's concerns in
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(0 pen) Open Item (407/8801-20): Leaking Fuel Element Identification -
I This item was previously discussed in NRC Inspection Report 50-407/88-01
! and involved the licensee's investigation and testing of fuel elements for
- leaks. The NRC inspectors examined thr: licensee's imolementation of the
] corrective actions committed to in their August 4, 1938, response to the
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open item. This item will remain open pending further NRC review of the
licensee's orogress in identifying any leaking fuel elements in the TRIGA
l core and their corrective actions.
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(Closed) Open Item (407/8801-21): Outdated Police Department NEL Res, e
Procedures - This item was previously discussed in NRC Inspection
Report 50-407/88-01 ami involved the use by the police department of
outdated NEL security response procedures. The NRC inspectors examined
, the licensee's implementation of the corrective actions committed to in
their August 4, 1988, response to the open item. The licensee's
corrective actions, which included providing current procedures to the
police department and a telephonic verification of receipt for future
transmittal of review procedures to all recipients, appear to be adequate
to resolve the NRC's concerns in this area,
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(Closed) Open Item (407/8801-22): Use of ARM - This item was previously
discussed in NRC Inspection Report 50-407/88-01 and involved the apparent
inoperability of an ARM over the entrance door to the NEL and the apparent
lack of knowledge possessed by police department personnel on its use
during an NEL response. The NRC inspectors examined the licensee's
implementatian of thi corrective actions including the calibration and
repair of t!.e ARM ano instruction of police department personnel on its
proper use and limitations as committed to in their August 4, 1988,
r3sponse to the open i\em. The licensee's corrective actions (NRC
1rispectors interviewed police department personnel and observed an
unannouticed drill invohing the ARM) appear to be adequate to resolve the
NRC's concerns in tnis a ea.
(Closed) Open Item (407/8801-23): Backup Power Supply Batteries - This
l item was previously discussed in NRC Inspection Report 50-407/88-01 and
- j involved the lack of battery test procedures and the batteries appeared to
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be damaged. The NRC inspectors examined the licensee's implementation of
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the corrective actions (development of inspection procedures and
i replacement of the batteries with new ones) committed to in their
l August 4, 1988, response to the open item. The licensee's corrective
actions appear to be adequate to resolve the NRC's :encerns In this area.
(Closed) Open Item (407/8801-24): TRIGA Fuel Inventory Review - This item
was previously discussed in NRC Inspection Report 50-407/88-01 and
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involved the NRC inspectors desire to have the licensee reverify the
serial number of each TRIGA fuel element. The NRC inspectors examined the
licensee's August 4, 1988, response tc the open item where the licensee
indicated that it would not be feasible, and that the current inventory is
accurate. The licensce's corrective actions appear to be adequate, since
some fuel elements do rot apparently have visible serial numbers on them,
to resolve the NRC's concerns in this area.
(Closed) Violation (407/8601-07): Maintenance of Facility and Equipment -
This item was previously discussed in NRC Inspection Reports 50-407/86~01
and 50-407/87-01 and involves the removal of a remote ARM alarm from the
R50's office. This item is being closed and further tracking will be via
the licensee's response to Violation 407/8801-07.
(Open) Violation (407/8601-03): Failure to Fully Implement Operator
Requalification Program - This item was previously discussed in NRC
Inspection Reports 50-407/86-01 and 50-407/87-01 and involved the
licensee's failure to fully implement the NRC approved reactor operator
requalification program. Tne NRC inspectors informed the licensee that
the current practice of making short and unsigned notations on the
requalification checklist did w t satisfy the requirements of the
NRC-approved requalification program for documenting the annual evaluation
of reactor operators. This item remains open pending licensee
implementation of the requalification program requirement for issuance of
an annual evaluation, in the form of a letter to the individual's file,
for each reactor operator.
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6. Reactor Operations (40750)
The NRC inspectors determined that tl.a licensee had accomplished
sufficient improvement to facility management oversight (compliance with
the Confirmatory Order) and satisfactorily resolved all NRC identified
violations and deviations associated with operations of the TRIGA reactor
(the AGN is currently not operable) to warrant recommendations for
removal of CA' 88-64 restrictions on NEL operations to the Regional
Administrator.
7. Exit Interview
The NRC inspectors reviewed the scope and findings of the inspection with
licensee representatives noted in paragraph 1 of this report at the
conclusion of the inspection on October 6, 1988.
In response to the NRC inspectors comments, the licensee agreed to the
, following commitments:
a. When the NRC imposed restrictions on operation of NEL reactors are
removed, the reactors will only be operated after approval is granted
by the Reactor S.fety Committee during a scheduled meeting of the
full committee.
5 The licensee will provide to the NRC a revised PSP for approval,
within 60 days of the date of this 'etter, incorporating the
following:
(1) Positive identification of all changes made to Revision 1 (dated
July 28, 1980) of the PSP.
(2) Reasons and justification for all changes made.
(3) Instructions on control of security response plans and
procedures.
(4) Instructions on key control and pe.*tedic lock / key changeout.
(5) Instructions on the periodic auditing of the PSP implerrentation
practices.
c. Current NEL door lock systems will be immediately changed out and all
keys will be issued and controlled by the university key shop. This
is due to the licensee loss of key control as discussed in NRC
Inspection Report 50-407/86-01 and Notice of Violation 407/8601-Or.