ML20215J850
| ML20215J850 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 10/08/1986 |
| From: | Bragdon P REED COLLEGE, PORTLAND, OR |
| To: | Cillis M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8610270211 | |
| Download: ML20215J850 (9) | |
Text
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,. 1 RifnVED REED COLLEGE /brt/aA/.0f>regm c2o2 Qc~t)hR5J 8 ,198 3l l
Mr. Michael Cillis E6*N V E l Radiation Specialist USNRC, Region V 1350 Maria Lane, Suite 210 WalnutCreek,Califomia 94596
Dear Mr. Cillis:
This letter is in response to USNRC Inspection Report 50-288/85-01 and details the measures taken to remedy situations found in the March 1985 NRC inspection of the Reed Reactor Facility. Reference is made to the Report in the information that follows. Formal response to the Notice of Noncompliance was submitted in a timely manner. Those items discussed in the inspection report that were not items of noncompliance, but that were deemed necessary for RRF to address are presented below with the response. The items have been addressed by RRF Management, Facility Management, and Oversight Committees.
~ 1) Persons Contacted No response is required.
- 2) Oreanization and Resnonsibilities The examination disclosed that the administrative procedures have not changed since 1974.
A draft of the Technical Specifications for the Reed Reactor Facility, dated June 1986,' has been submitted to the NRC, Office of Nuclear Reactor Regulation, Wash. D.C. This document contains a completely revised section on Administration written in ANSI 15.1 format. Upon approval, a new set of administrative procedures based on the Technical Specifications will be implemented. The new Administration Section contains Committee Charters and delineates oversight responsibilities--two items requested in discussions with NRC personnel.
- There were founeen NRC licensed operators and senior operators. Seven are undergraduate students at Reed College while the remaining seven are from outside organizations. The Reactor Supervisor is an undergraduate student.
No response is required.
The IIcalth Physicist is from an outside organization. He Reactor Supervisor informed the inspector that the IIcalth Physicist has not performed the functions of a health physicist, as defined in the Administrative Procedure, since he was appointed the position of reactor supervisor (e.g. approximately 2 1/2 years ago). He Supervisor stated that the Health Physicist did attend the RSC and ROC meetings.
The Director of RRF confirmed the Reactor Supervisor's observations, stating that he and/or the operators performed most of the health physics functions.
Dr. Marshall Parrott has been retained by RRF Management as Reactor Health Physicist. His contract calls for a specific amount of time to be spent at RRF and in interaction with RRF personnel.
The Director of RRF has other major responsibilities. Dey are: Reed College Radiation Safety Officer, Chairman of tne Reed College Isotopes Committee, Ex-officio member of the ROC and RSC, Reed College Instructor, and Implementation of the RRF Emergency Plan, reactor operators / senior reactor operators training and requalification programs.
8610270211 861008 PDR ADOCK 05000288 ) [ !
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. T Mr. Michael Cillis October 8,1986 Page 2 Reed College recognizes that additional staffing will have to be provided to operate the mactor in the long term. We have contracted with Dr. Lawrence Ruby who will serve as a consultant to the facility until September 1987 at which time he will assume the position of Director. As an interim measure, J. Michael Pollock has been himd as Acting Director of the Reed Reactor Facility. Mr.
Pollock's position is not full time; on the other hand, he will not have the responsibilities ofInstructor or campus RSO Marshall Parrott has been mtained as campus Radiation Safety Officerin addition to his position as Reactor Health Physicist. When Dr. Lawrence Ruby joins the college in September 1987, it is the intention of the Reed Management to mtain Mr. Pollock on the facility staff, probably as Reactor Supervisor, for a period of at least 6 months while a long term solution to the manpower problem is being sought consonant with the financial realities of a small liberal arts college.
- 3) Lon and Records
. Approximately 20% of the check lists contained omissions. In most instances the Reactor Supervisor's and Reactor Director's reviews (certified by their signature) of the checklists were made anywhere from two to seven months after the check list items were completed.
A review of the status of all checklists will be a regular agenda item at meetings between the Supervisor and Director. These meetings will be held at least once each month.
. None of the check lists clearly distinguish Technical Specification requirements.
'Ihe phrase "*Starmd items are Technical Specification Requirements and must be within normal limits" has been applied to Technical Specifications Surveillance items on existing editions of check lists and will be included on all future editions.
. The supply of" typed" copies of the bi-monthly check lists was depleted in January 1984. He form, which contains 8 line items that must be verified every two months, has been hand written since January 1984. The licensee's staff still includes the need for performing the portable monitor calibrations on this form even though the calibration frequency had been changed to every six months.
. Verification of Technical Specification, Section D.2 (e.g. weekly sampling of pool water) might be found I on any one of three different mcords.
A bi-monthly check list has been revised to reflect the fact that portable monitor calibrations are done on a semi-annual basis. A weekly checklist has been instituted to reflect Technical Specification requirements. All checklists have been revised to mflect the Technical Specification requirements and will be evaluated again upon approval of the proposed Technical Specifications.
i l . The Environmental Monitoring Img book for 1985 did not indicate that environmental samples were l taken in January of 1985. De reactor supervisor in'ormed the inspector that the January 1985 sampling l was conducted but not documented.
l The July 1984 environmental soil sample results had not been documented in either the Health Physics or Environmental log even though the sample analysis had been completed in the latter part of IF4.
. The Reactor Safety Committee has scheduled an audit of the environmental sampling program. This audit will address possible modifications to procedures as w eli as past monitoring compliance.
. Dates and times were not included in Reactor Operator's Records.
. Reactor Operator's Records are not being maintained as require 1 by a policy that was established by the l Reac or Director. Specifically some operators are not recording reactivity manipulations.
, . Numerous log entries were unsigned.
l . Log entries are written in pencil and are illegible in some cases.
. The " procedures review" verifications are not being recorded by operators as required by an unwritten policy that was established by the Rextor Director.
. There were several occasions where samples were placed in the com and removed from the core where no log book entries were made as required by SOP-51 " Running Rabbits."
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_ SOP-10 " Writing in log Books" requires that any entry of consequence should be signed by the person marking that entry. The inspector noted that most entries (>50%) are initialed rather than signed.
The foregoing items wem addmssed in an operators' meeting with specific instructions. The term "IAg" as used in these critiques applies to all facility records written by operations staff. Checklists are included in the generic term.
l The care with which the main log is written must be extended to cover all logs.
The question of operator education is being addressed through meetings and over
! the long run by the revision of SOPS as they are reviewed on a two year cycle.
t The Operators' Img is an item scheduled for audit this fall and proposed for routine review and audit by the Reactor Safety Committee in the new Technical Specifications. Review and signing of the Procedure Change Notice Log is a part of the procedure for instituting such changes. All logs including checklists
' will be reviewed by the Director and the Supervisor to be held at least monthly.
These meetings will be documented.
4). Renctor Onerations a) Onerarnr Reaualification Pronram
. Each RO and SRO are required to maintain their own personal" Reactor Operator's Records" current, describing the dates, times and number of reactivity control manipulations they perform.
- (Operators are required) To sign the procedure change log, as an acknowledgement that they have reviewed all procedures that were changed since they last performed reactivity control manipulations at RRF.
l = (Operators are required) To acknowledge in the control console log that they have reviewed all entries in the log since they last performed reactivity control manipulations.
These items have been addressed through reactor operators' meetings and written
, instructions to operators.
. The inspector noted that at least nine of the currently licensed RO's and SRO's had special conditions stipulated in their respective operators licenses. The conditions required (restrictions enumeratedin Report). Neither the reactor director or reactor supervisor were aware of the licensed conditions that were stipulated in the licenses issued to the RRF staff.
He Director has prepared and will maintain a list of operators and license conditions. Operators are responsible for complying with conditions of their licenses. The status of operators licenses and license conditions will be audited by the ROC.
The reactor director was confident that the license conditions were being met because of the policies established in the RRF administrative procedures; however, there was no way for verifying this because the name of the second (or backup person) individual in attendance at the rextor facility is not normally documented in the licensee records. Nor is the second individual made aware of any special conditions that may be included in an operator's license.
The second (or backup person) individual in the facility signs the purpose stamp and status stamp just below the bottom line. New stamps will be obtained when the revised Technical Specifications are in effect and will reflect any changes and will also have a space for the second individual to sign.
. The reactor supervisor stated he found it extremely difficult trying to schedule rextor operations in a manner that would assure that the qualifications and/or recertification of the RO's and SRO's were maintained in accordance with 10 CFR Part 55.31. The rextor supervisor stated he was no longer attempting to schedule the activities of RO's and SRO's that are from outside organizations.
Qualification will be audited and administrative action taken if not curmnt--same actions for operators not up to date in the requalification program.
Only a fe.v of the RO's and SRO's maintain the " Reactor Operator's Records" current.
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Mr. Michael Cillis October 8,1986 Page 4
. Only a few of the RO's and SRO's verify that they have reviewed all procedure changes that were issued since they last operated the reactor.
Only a few of the RO's and SRO's verified that they have reviewed the entries in " reactor console log" since they last operated the reactor.
Operator education was addressed in comments pertaining to section 3. These logs will be reviewed regularly by the Supervisor and audited by the Operations Committee.
. At least one SRO (Docket No. given in Report) has not taken a yearly SRO examination since May 1983.
This item was addressed in the letter of response to the Notice of Violation, addressed to Mr. Scarano, and dated 30 May 1985.
. Two operators did not maintain their reactor operator license (Docket Nos. given in Report) current. RO, Docket No. given in Report, did not perform reactor control manipulations since receiving his license on September 6,1983 while SRO, Docket No. given in Report, did not operate the reactor since May 14, 1984. He Reactor Director did not become aware of this problem until January 1985, at which time he felt they were no longer qualified as operators. One of the individuals decided not to renew his license while the other is in the process of requalifying.
This item was addressed in the letter of response to the Notice of Violation, addressed to Mr. Scarano, and dated 30 May 1985.
. The inspector found portions of at least two requalification examinations that were not graded. This same observation was made in Inspection Report 50-288/83-01.
1985 Requalification examination was held, graded, and deficiencies addressed.
The 1986 Requalification Examination will be held, graded, and deficiencies addressed prior to considering operators up-to-date and capable of unmstricted operations of the mactor. The examination will concentrate on major changes to the documentation of the facility such as the new Emergency Plan and Emergency Implementation Procedures.
Semi. annual (once every six months) meetings of the RO's and SRO's were not held between the period of November 1984 through January 1985. He reactor supervisor informed the inspector that he has never attended a meeting in which there was 100% attendance by the facilities licensed RO's and SRO's.
One SRO informed the inspector that he had never attended any mcetings during a two year period that he was a licensed oprator.
Provision is made to communicate results of meetings to all licensed operators through notices and records of meetings. The audit function willinspect to assure attendance or documented receipt of meeting record.
At least two reactor operators (Docket Nos. given in Report) did not perform at least 10 reactivity control manipulations per year. Docket No. given in Report made only mode 3 reactivity control manipulations in 1983 and No. given in Report only made 5 reactivity control manipulations in 1984. Both individuals made the required amount of reactivity changes in the preceding and subsequent years This item was addmssed in the letter of response to the Notice of Violation, addressed to Mr. Scarano, and dated 30 May 1985.
. There was no indication that an overview (audit) of the reactor operator requalification program was performed by either the Reactor Operations Committee or Radiation Safety Committee.
'Ihe Reactor Operations Committee has scheduled an audit of the Operator Requalification program. Provision is included in the proposed Technical Specifications to continue this audit in the future.
b) Conditions of Licentec
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Mr. Michael Cillis October 8,1986 Page 5 Four individuals, identified as Docket Nos. given in Report were allowed to perform reactivity control manipulations of the Reed Reactor Facility even though they had not performed the functions of a reactor operator for a penod of four months or greater. None of the individuals were recertified by an authorized licensee representative nor did they demonstrate to the commission that their underwanding and knowledge of facility operations were satisfactory. De individuals and respective dates involved are as follows:
given in Report This item was addressed in the letter of response to the Notice of Violation, addressed to Mr. Scarano, and dated 30 May 1985.
c) Ernerimenk No response is required.
d) Standard Ooeratino Pr.. e ..s
. Discussions with the Director of RRF and the Reactor Supervisor disclosed that new emergency procedures were being developed. De Director of RRF did not expect that these procedures would be approved by May 1985 as previously committed to NRC Region V staff on November 11,1984.
The Reed Reactor Facility Emergency Plan has been approved by the NRC. A set of Emergency Implementation Procedures has been written and reviewed by the Reactor Safety and Reactor Operations Committees. The rest of the Emergency Plan is being implemented in a timely manner. Notification ofimplementation has been sent to the NRC. Compliance will be audited by the Reactor Safety Committee.
. The Reactor Supervisor expressed some concern with the review and approval process of SOP's. He Reactor Supervisor stated that seven procedure revisions made in early 1984 were submitted to the Reactor Operations Committee in July 1984 and still had not been approved at the time of this inspection. De reactor supervisor stated that such delays were not unusual bcsause of the infrequent meetings of ROC.
The Committee structure has been mvised in the Lew Technical Specifications.
Until they are appmved, the current ROC and RSC have been meeting at intervals more frequent than quarterly and have been actively involved in the process of pmparing for resumption of operations. A standard operating procedum for the preparation, myiew and approval of SOP's was requested by the committees in their meeting on September 16,1986.
. Some SOP's reviewed failed to provide specific instructions regarding the frequency for performing certain actions and where to record the data. An Example is SOP-20," Environmental Monitoring." He procedure fails to identify the frequency for obtaining soil and water samples and where to record the sample analysis results. Discussions with the Reactor Director and Reactor Supervisor indicated that water samples are normally obtained in January of each year while soil samples are obtained in July of each year. The fact that the samples are taken is recorded in the Environmental Log book; however, the sample analysis results are recorded in the Health Physics Log bock.
All existing SOPS are currently being converted to a standard format which makes explicit fmquency and logging requirements. An audit of SOP-20 has been scheduled by the Reactor Safety Committe. Revisions will include specific sampling frequencies and will require maintenance of all environmental sampling, analysis, data reduction, interpretation, and final results in the same log book.
A SOP for the calibration of portable instruments is not yet available even though the licensee's staff agreed such a procedure was necessary in 1982 and again in 1984. Discussions related to this topic are provided in Region V Inspection Report 50-288/82-02 and the Reactor Operations Committee meeting minutes of November 15,1984.
SOP-22: Calibration and Maintenance of Portable Radiation Monitors, has been established to track calibration and maintenance of all portable radiation monitors
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>- Mr.MichaelCillis October 8,1986 Page 6 at RRF. All issues raised in'the inspection repott are addressed in the procedure.
While not as extensive as the power reactor procedures, it will ensure that only calibrated and operable instruments are used and will mcord all outages and maintenance.
- 5) Review and Audit
. The only Reed member having voting privileges on either committee is the Chairman of the ROC.
Remaining members of both committee's are from outside organizations. 'Ihe Reactor Supervisor stated that the ROC makeup has resulted in delays in review and approval of facility bus: ness.
The new Technical Specifications address the composition and qualification of the committees. With the limited range of expertise available on the Reed faculty, outside members of the committees will continue to be requimd. The current committees have been revised to contain additional members from the Reed faculty and staff.
. The ROC's charter references 10 CFR Part 20 as the governing regulatory requirement for performing reviews / evaluations of any problems that may be constituted as an unreviewed safety question.10 CFR 50.59 is the correct regulatory reference.
This has been corrected in the new charter.
Neither committee charter describes what, if any, audit function they are responsible for performing.
. Neither committee tracks the status of audit findings.
Both committees have, over the past two years, been attempting to redefine their responsibilities. As a result, the committee's surveillance and audit activities have become less frequent and affairs requiring immediate attention have suffered, e.g. such as approval of the revised Emergency Plan. .
. The inspector observed that the ROC has not been fully utilized as an effective tool in assuring that the RRF operations are performed in accordance with the appropriate regulatory requirements and facility policies. 'Ihe inspector observed that the effectiveness of the RSC was also in need ofimprovement.
The structure of the review and audit function has been revised in Section 6 of the proposed Technical Specifications, and will be implemented in a new r.et of Administrative Procedures when the Technical Specifications are approved. The new structure delineates responsibilities for review and audit functions and gives l
explicit instruction for oversight of those functions. The effectiveness of the committees is expected to improve with more responsibility for meeting and initiation of action given to the committee and with more of the committee drawn from the Reed faculty and staff.
. The inspector noted that several ROC meeting minutes held over the past two years failed to indicate who was present.
Meeting minutes will include a list of attendees.
- 6) IE Inforentlan Notices (IN) i Discussions with the Reactor Supervisor disclosed that he had evaluated IN 84-12 " Inadequate Shutdown Margin." SOP-40 has been revised to require a rod calibration following fuel inspection. SOP-33:
Control Rod Calibration has been revised to require calculation of shutdown margin following control rod calibration.
The Supervisor stated that he had concluded that the concems described in the IN applied to the RRF.
The Supervisor's evaluation and recommendations were provided to the Radiation Safety Committee in July 1984 for resolution. The Radiation Safety Committee assigned another member of the Committee and Director of the RRF to resolve the Supervisor's evaluation.
A discussion was held with the Director of the RRF for the purpose of determining the status of the recommendations made by Reactor Supervisor with respect to the IN. The Director stated that he was not
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'. . Mr. Michael Cillis October 8,1986 Page 7 sure whether he agreed with the Reactor Supervisor's evaluation of the IN; howevei, neither he or the other committee member had completed their actions for resolving this matter.
The Information Notice has been reviewed both by the Reactor Operations Committee and by the Reactor Safety Committee. On their recommendation, SOP-40: Fuel Inspection and Control Rod Inspection, will be revised to require a rod calibration following fuel inspection, and SOP-33: Control Rod Calibration, will be revised to require calculation of shutdown margin following control rod calibration.
- 7) Transnortation Activities No response is required.
- 8) Emereency Prenaredness Discussions were held with the licensee's staff for the purpose of determining the status of their emergency plan which was submitted to the NRC November 1,1983 for approval pursuant to 10 CFR Part 50.54(r).
The Reed Reactor Facility Emergency Plan, dated 15 September 1986 was approved by the NRC in February 1986. A set of Emergency Implementation Procedures, dated April 1986, has been adopted.
- 9) Facilifv Tour The inspector noted that copies of FORM NRC-3 were posted throughout the facility; however, information related to the locations of the documents specified in 10 CFR Part 19.11(a), " Posting of Notices to Workers" were not posted as required by 10 CFR Part 10.11(b) and/or 10 CFR Part 19.11(d).
This item was addressed in the letter of response to the Notice of Violation, addressed to Mr. Scarano, and dated 30 May 1985.
- 10) Radiation Protection Proeram a) Surveys
. Contamination surveys were obtained at frequencies ranging from every two weeks to intervals of up to six weeks.
. Only five swipes are normally taken. In a few exceptions as many as seven swipes may be taken and in most instances (greater than 96%) the swipes are taken in the same locations. No contamination surveys are performed during special evolutions such as fuel inspection or control rod inspections. Nor are contamination surveys taken at the rabbit hood or in the counting room, e.g. during the handling of irradiated samples.
. The swipes are analyzed on an instrument (GM-counter) that is calibrated with a known standard at no set frequency (approximately once per year). 'Ihe inspector noted that a performance check of the counting system is not performed prior to counting the swipes to confirm that the instrument response has not drifted from its initial calibration parameters. ANSI N323-1978, " Radiation Protection Instrumentation Test and Calibration," paragraph 4.7.3 recommends that source checks be made prior to each use, during intermitted use and at least several times a day during continuous use.
. The inspector noted that the licensee's contamination surveys were recorded in units (e.g. counts per minute) that are not consistent with that prescribed in 10 CFR Part 20.401(b), " Records of Surveys, Radiation Monitoring, and Disposal" or as defined in 10 CFR Part 20.5, " Units of Radioactivity."
These points are addressed by the new SOP-02. Specifically, frequency of wipe tests is clearly stated. Ten locations must be swiped every time the tests are done, including the rabbit cage, the main counting room, and other areas outside the reactor bay. The total number of swipes, which will be greater than or equal to ten, depends on the level of facility use. The GM-counter is checked with a9 0Sr
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.. Mr. Michael Cillis October 8,1986 Page 8 source befom every set of wipe test data is taken. The results of contamination surveys are now recorded in units of Ci/100 cm2, In several instances, the inspector noted that the radiation levels recorded for the Ion Exchange Tank read lower upon reactor shutdown than it did at reactor startup. De Director of RRF and Reactor Supervisor, who are responsible for reviewing the data, stated the readings on the tank should always read higher at shutdown. Hey had not i&ntified the apparent inconsistency in their review process.
The reading obained when monitoring the ion exchange tanks is greatly affected by where the survey meter is held. While it is generally true that tank readings should be higher after shutdown this may not be the case. The reading . . . is held.
Procedure SOP-18,"The Health Physics ofIligh Radiation Areas," 5/14/81, requires that only the Director of the RRF or Health Physicist are the individuals authorized to work in a high radiation area.
The inspector noted that work performed at the rabbit area on November 19,1984, having radiation levels of 150 millirem / hour, was performed by an unauthcrized individual. The Director of the RRF was not aware of the occurrence until it was brought to his attention by the inspector.
Procedures for dealing with rabbits which result in high radiation areas are in place and require an individual who encounters such a situation to leave and report it immediately to the operator and health physicist.
b) Gaseous and Lianid EfUnent Releases No response is required.
c) Personnel R adiation Dosimetry No response is required.
d) General Emnloyee's Trainine (GET)
No response is required.
e) Environmental Monitorine No response is required.
- 11) Instrument Calibration a) Portable Instruments
. A SOP for calibration of portable survey instruments has not been established. The calibration methods described in the Monitor Log book were not performed in a consistent manner. Nor were the calibrations performed at a level that is commensurate with the recommendations provided in ANSI N323-1978.
SOP-22: Calibration and Maintenance of Portable Radiation Monitors, has been established to track calibration and maintenance of all portable radiation monitors at RRF. While not as extensive as the power reactor procedures (to provide the level of calibration recommended in ANSI N323-1978, RRF would have to contract with an outside organization to perform the calibrations), it will ensure calibrated and operable instruments are used and will record all outages and maintenance.
The licensee does not calibrate any instrument for measuring non-penetrating radiation.
Possible means of calibrating survey instruments for non-penetrating radiation are being evaluated by the Reactor Health Physicist.
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'. : Mr. MichaelCillis October 8,1986 Page 9 b) Fixed instrumentntion The examination disclosed that the procedures for performing the calibrations required by the Technical Specifications were significantly different from one another even though the monitors were essentially the same. The differences, as provided in SOP-30, " Calibration of the CAM" and SOP-32, " Particulate Stack Monitor" were brought to the attention of the Director of the RRF and the Reactor Supervisor and were discussed at the exit interview.
The two SOPS in question, SOP-30 and SOP-32, are currently under review.
- 12) Fult Interview No response is required.
It is my hope that this letter adequately addresses your concerns. Michael Pollock and Marshall Cronyn will be in touch with you in the near future to schedule a m 1tig as you have 2ested.
Siacerely, i O P[ident es M -
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