ML20236A257
| ML20236A257 | |
| Person / Time | |
|---|---|
| Site: | 05000148 |
| Issue date: | 03/10/1989 |
| From: | Baer R, Chaney H, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236A250 | List: |
| References | |
| 50-148-89-01, NUDOCS 8903170011 | |
| Download: ML20236A257 (7) | |
See also: IR 05000148/1989001
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-148/89-01 License: R-78
Docket: 50-148 q
Licensee: University of Kansas (KU)
Lawrence, Kansas 66045-2223
Facility Name: Nuclear Reactor Center - (Defueled Bendix pool type reactor)
Inspection At: Nuclear Reactor Center (Burt Hall), KU
Inspection Conducted: February 9-10, 1989
Inspectors: M 'O
H. D. Chaney, Senior fladiation Specialist, Date
Facilities Radiologic 41 Protection Section *
e
& AD Sfl0 b'?
L. Ricke on, , Radiation Specialist Date
Faciliti di log ila1 Protection Section
Approved: // // 8
R( E. Baer, Chisf, Facilities Radiological Date
Protection Section
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Inspection Summary
Inspection Conducted February 9-10, 1989 (Report 50-148/89-01)
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Areas Inspected:
Routine, unannounced inspection of the licensee's radiation protection, special
nuclear materials accountability, radioactive material (RAM) transportation,
and surveillance associated with Amendment 15 to the Facility Operating
License that implements a possession-only status for the reactor.
Results: Within the areas inspected, one violation (failure to transfer
special nuclear material in accordance with the requirements of 10 CFR Part 70)
and no deviations were identified. The reactor is being maintained in a
defueled condition. Radiological survey and reactor facility surveillance
appear to be adequate.
8903170011 890310 i
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DETAILS
1. Persons Contacted
Licensee (KU)
'*H. Rosson, Reactor Director
- B. Friesen, -Radiation Safety Officer (RS0)
M. Lemon, Assistant RSO.
- Indicates those present at the exit interview on February 10, 1989.
2. Follow-up on Previous Inspection Findings (92701)
(Closed) Violation (148/8601-01): Unauthorized Dismantling of the' Reactor.
and Initiating Decommissioning Activities - This item was previously
' discussed in NRC Inspection Report 50-148/86-01 and' involved.the
licensee's defueling and partial dismantling of the reactor and reactor
support systems without NRC approval per 10 CFR Part 50.59(a). The NRC
inspectors examined the licensee's implementation.of the corrective
actions committed to in their January 13, 1987, response to the violation.
The licensee's implementation of corrective actions (administrative
controls: the University through the Nuclear Reactor Committee will inform
the NRC prior to conducting any further disassembly for assessment of
reactor component neutron activation and byproduct contamination) appears
to be well implemented and adequai.e to prevent a recurrence of the
violation in the future.
(Closed) Violation (148/8601-02): Failure to Perform Safety Analysis
' Prior to Reactor Disassembly - This item was previously discussed in NRC
Inspection Report 50-148/86-01 and involved the. licensee's failure to
perform a 10 CFR Part 50.59 safety analysis prior to the February 1986
disassembly of the reactor and support systems. A previous (1983) 10 CFR
Part 50.59 safety analysis for disassembly of the reactor for maintenance
purposes was deemed satisfactory for determining whether or not any
unreviewed safety questions would be created by the reactor disassembly.
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This violation was cancelled.
- (Closed) Violation (148/8601-03): Failure to Post 10 CFR Part 19.11
Required Documents - This item was previously discussed in NRC Inspection
i Report 50-148/86-01 and involved the licensee's failure to post documents
I (10 CFR regulations, facility license, operating procedures, and NRC
Form 3) or indicate where they may be viewed. The NRC inspectors examined
the licensee's implementation of the corrective actions committed to in
l- their January 13, 1987, response to the violation. The licensee's
l- implementation of corrective actions (posting of NRC Form 3 and post of
information where the other documents could be viewed) appears to be well
implemented and adequate to prevent a recurrence of the violation in the
future.
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(Closed) Violation (148/8601-04): Failure to Properly Identify
Radioactive Material - This item was previously discussed in NRC
Inspection Report 50-148/86-01 and involved the licensee's failure to
properly tag or label a fission chamber as containing RAM. The NRC
inspectors examined the licensee's implementation of the corrective
actions committed to in their January 13, 1987, response to the violation.
The licensee's implementation of corrective actions (labeling the item
identified by the NRC inspectors) appears to be well implemented and
adequate to prevent a recurrence of the violation in the future. During
this inspection, no other violations of this type were noted and only the
reactor itself is left under the license and was properly labeled as
RAM.
(Closed) Violation (148/8601-05): Failure to Properly Implement the
Physical Security Plan - This item was previously discussed in NRC
Inspection Report 50-148/86-01 and involved the licensee's failure to
maintain the security alarm system. The NRC inspectors examined the
licensee's implementation of the corrective actions committed to in their
January 13, 1987, response to the violation. Currently, no intrusion
alarm system is in operation and the licensee is not required to have or
maintain a Physical Security Plan per Amendment 15 to the Facility
Operating License, dated January 28, 1987.
3. Class II Operation and Procedures (40750)
a. Background
The KU reactor defueling, source and special nuclear material
shipping, and reactor support system disassembly were previously
discussed, in detail, in NRC Inspection Report 50-148/86-01.
Currently, only the reactor vessel (including the cement support and
shielding structure around it) and internal components associated
with the thermal column and four irradiation beam ports remain
intact. Several nonradioactive control rod movement / support
components remain within the facility at Burt Hall. Activated
control rod sheaths and other core components are stored in the
shielded hot laboratory within Burt Hall. The NRC issued
Amendment 15 to Facility Operating License R-78, on January 28, 1987,
converting the license to a possession-only (the licensee cannot
operate the reactor nor install fuel or experiments within the
reactor core or core area) type license. This amendment also deleted
the necessity for the licensee to maintain either an Emergency Plan
or a Physical Security Plan. Technical Specifications (TS) were
modified to ensure the radiological safety of the f acility is
maintained.
The licensee is working closely with the NRC Headquarters Project
Manager on development of disassembly experiments for assessing the
degree of radioactivity in/on remaining reactor internal components.
A formal decommissioning plan has not been submitted by the licensee.
The licensee intends on completing radioactivity assessments before
deciding on a decommissioning method.
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b. Organization and Responsibilities
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The NRC inspectors reviewed the licensee's organizational structure l
and staffing to determine compliance with the requirements of
TS 6.1.1, 6.1.2, and 6.1.4.
The NRC inspectors determined that the licensee had in place an
organization comprised of the Reactor Director, RSO, Assistant RSO,
i and a five-member Nuclear Reactor Committee that adequately meet the
requirements of the amended Facility Operating License. The
composite qualification of the Nuclear Reactor Committee satisfies
the requirements of TS 6.1.4.1.
c. Training and Qualifications
i The NRC inspectors verified that the RS0's qualifications are being
maintained in accordance with the requirements of TS 6.1.3. The RSO
has been involved in research reactor activities at KU since their
inception,
d. Review and Audits
The licensee had assigned the Assistant RSO the responsibility of
auditing the reactor facility and performing surveillance as
required by the license and TS 6.1.5.
The NRC inspectors examined audits performed by the licensee turing
the period of January 1987 through January 27, 1988, and January 28,
1988, through December 1988. Audits were presented to the Nuclear
Reactor Committee and reviewed by them within the 90 days established
by TS 6.1.5.1 and 6.1.5.2. Audits were thorough and sufficient to
identify programmatic and operational problems.
e. Safety Systems
The NRC inspector examined the licensee's program for control and
calibration of portable radiation protection instrumentation to
determine compliance with TS 4.1(c) and (d) requirements.
The NRC inspectors determined that the licensee routinely
(semiannually) calibrates and response checks beta / gamma radiation
exposure measurement instruments.
The NRC inspectors also noted that the licensee had implemented
labeling of instruments to indicate calibration data and who
calibrated the instrument, and separates noncalibrated instruments
from out of service instruments. This resolves a concern of the NRC
discussed in NRC Inspection Report 50-148/86-01.
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f. Surveillance
The NRC inspectors examined the licensee's records for determining
compliance with the reactor area surveillance requirements of
TS 4.2(c).
.The NRC inspectors examined licensee surveillance verification
checklists, radiological survey records, and annual reports;
performed a facility walkdown; verified that'all accesses to the
reactor vessel / core area were padlocked and that appropriate
radiological surveys had been performed. The NRC inspectors
performed confirmatory radiation, loose surface contamination, and
airborne radioactivity surveys of the facility. The surveys agreed
with the results the licensee had.been obtaining.
Licensee Identified Violation
TS 4.2(c)(1) requires, in part, that "The operational condition of
the fire alarm shall be tested on an annual basis." TS 1.0,
" Definitions," defines an annual surveillance interval as not
exceeding a 15-month duration.
In the January 12, 1989, Annual Report (required by TS 6.4.1), the
licensee identified a failure to perform the annual fire alarm test
within the. required 15-month period. The surveillance was last
performed on April 27, 1987, and then again on November 3,.1988. A
period of 18 months elapsed between surveillance. The licensee
identified the root cause of the missed surveillance as a failure to
' include the fire alarm testing on the master checklist for all types
of surveillance. The licensee took immediate action to revise the
administrative checklist (Form ss.rf 387) to include the fire alarm
testing every November. The licensee's final corrective actions were
reviewed during the inspection and were determined to be adequate to
prevent a future recurrence of the problem.
This matter would normally be considered to be a violation requiring
response to the NRC. However, the licensee's actions in t. king
prompt remedial measures, making a full and a comprehensive
evaluation and report, and instituting long-term corrective actions
to prevent a recurrence met the criteria of the NRC enforcement
policy delineated in 10 CFR Part 2, Appendix C (1988) for a
licensee-identified violation and no further enforcement action or
follow-up action is required.
g. Design Features
The'NRC inspectors verified that the licensee had disposed of all ion
exchange resin, the control console had been disconnected from the
reactor, and the graphite thermal column and the four beam ports
were locked shut. The licensee had also placed a large wooden cover
over the top of the reactor vessel and padlocked it shut.
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h. Procedures
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The NRC inspectors reviewed the licensee's procedures for the l
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performance of reactor inspections (partial disassembly) to assess
the degree of structure / component activation and contamination.
These procedures were of sufficient detail to ensure the safety and
ALARA considerations of TS 6.2.
1. Routine and Special Reports
The NRC inspectors examined the licensee's reports submitted to the
NRC in accordance with TS 6.4, 6.4.1, 6.4.2, and 6.4.3.
The licensee was noted to have submitted an annual report for the
period January 28 through December 31, 1987, on January 15, 1988, and
the next annual report on January 12, 1989, for the period January 1
through December 31, 1988. The licensee has submitted several
reports concerning proposed special experiments concerning reactor
inspections to ascertain reactor component activation status. No
reportable occurrences have been identified by the licensee since the
last inspection of this area (September 1986).
J. Records
The NRC inspectors reviewed the licensee's preparation and storage of
records required by TS 6.5.1 and 6.5.2. No problems were identified
in this area.
No violations or deviations were identified.
4. Transportation Activities (86740)
The NRC inspectors examined the licensee's records and report concerning
the preparation, packaging, radiological surveying, labeling, and delivery
to a shipper of RAM to determine compliance with the requirements of
10 CFR Part 71 and those of 49 CFR Parts 100 through 177.
The NRC inspectors reviewed the licensee's records for the shipment of
radioactive and special nuclear materials (components and waste) made on
October 21 and 24, 1986. The licensee's records were satisfactory in
detail to determine compliance with the NRC and Department of
Transportation regulations.
No violations or deviations were identified.
5. Special Nuclear Material (85102)
The NRC inspectors reviewed the licensee's inventory and accountability
program for special nuclear materials to determine compliance with the
requirements of 10 CFR Part 70 and and Facility Operating License
(Amendment 14), Conditions 1.I and 2.C; and the guidance contained in
NUREG/BR-0006, Revision 2, " Instructions for Completing Nuclear Material
Transaction Reports."
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The licensee's.special n~uclear status forms (741, 742, and 742C) were
reviewed and found satisfactory. Currently, the licensee does not have
any special nuclear material onsite associated with the R-78 license. The
licensee's last two transactions involved the transfer of natural uranium
plates, rods, and scrap to a licensed hazardous waste broker _(NRC I
Docket 30-17490) for disposal, and an fission chamber containing
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.approximately 2 grams of uranium-235 to Kansas State University (KSU).
Both transactions took place.in October 1986. The license's records
included a copy of the hazardous waste brokers byproduct license, but not
a license for KSU. These transfers were reported to the NRC on or about
November 5, 1986.
Seci. ion 1.I of Amendment 14 to the Facility Operating License (which was !
in effect at this time), states, in part, that "The receipt, possession
and use of the . . . special, nuclear materials as authorized by the
amended license will be in accordance with the Commission's regulations in
10 CFR Parts 30 and 70 . . . ." Section 2.0 of the license establishes !
that the licensee is subject to the conditions specified in 10 CFR
Parts 20, 30, 40, and,70. Paragraph (c) of 10 CFR Part 70.42, " Transfer
of Special Nuclear Material," states, in part, that "Before transferring I
special nuclear material to a . . . licensee of an Agreement State . . .
the licensee transferring the material shall verify that the transferee's
license authorizes receipt of the type, form, and quantity of special
nuclear material to be transferred." Paragraph (d) identifies five :
different physical methods of verifying that the transferee's license
authorizes such possession. Only in emergency shipments / transfers is the
transferer authorized to accept the oral verification by the transferee as l
to license conditions.
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The NRC inspectors determined on February 10, 1989, that on or about
October 24, 1986, approximately 2 grams of encapsulated (special form)
special nuclear material (uranium-235) was transferred, in Kansas City,
Kansas, by the licensee to the KSV RSO. KSV holds a Kansas State
Byproduct License (38c00-11), issued by the state of Kansas in accordance
with 10 CFR Part 150. The licensee (KU) failed to physically verify that
the KSV license authorized KSU's receipt of this type, form, and quantity
of special nuclear material. This shipment was not deemed an emergency
shipment as defined by 10 CFR Part 70.42. This is considered a violation
of the requirements of 10 CFR Part 70.42. (148/8901-01)
6. Exit Briefing
The NRC inspectors met with the licensee's representatives identified in
paragraph 1 of this report at the conclusion of the inspection on
February 10, 1989. The NRC summarized the scope and findings of the
inspection. The NRC inspectors requested that the licensee split, with
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the NRC Region IV office, any material samples they obtained for the
purpose of determining the activation or contamination status of reactor
components / support structures. The licensee agreed to provide the ,
Region IV office with samples for confirmatory analysis purposes. '
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