ML20245C753

Advises That WE Wilson Retiring Effective 890701

ML20245C753
Person / Time
Site:	Washington State University
Issue date:	03/10/1989
From:	Wilson W WASHINGTON STATE UNIV., PULLMAN, WA
To:	Alexander Adams Office of Nuclear Reactor Regulation
References
NUDOCS 8904270372
Download: ML20245C753 (15)

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[l Washington StateUniversity Nuclear Radiation Center, Pullman, Washington 99164-1300 / 509-335-8641 March 10, 1989 Alexander Adams, Jr.

Project Manager Standardization 6 Non-Power Reactor Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission MS WF1-11H3 Washington, DC 20555

Dear Mr. Adams:

Over the past year since Dr. Roy Filby resigned as Director of the Radiation Center to'become Chairman of the Department of Chemistry and Dr. David Barbec of the Vet School was appointed Interim Director, a number of problems have occurred at the Radiation Center. My health is deteriorating due to a medical problem that is significantly exacerbated by stress and thus I will be retiring on 7/1/89.

ItisnotcleartomeatthispointintimewhatresponsgilitiesIhavein relation to the requirements of T.S. 6:10(3)C 6 D. The Co source and other i problems may be viewed as being directly related to the manner in which the Center is now being managed. You might want to call Dr. Filby at 509-335-3331 before calling me at 509-335-8317 with any advice. He can give you his view of the situation. He is now a member of the Reactor Safeguards Committee.

Sincerely, h (W&

W.E. Wilson Associate Director Enclosure WEW: crc 8904270372 890310 m PDR ADOCK 05000027 '

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Washington StateUniversity Nuclear Radiation Center, Pullman, Washington 99164-1300 / 509-335-8641 MEMORANDUM

.TO: David Barbee, R.V. Smith and Reactor Safeguards Committee FROM: Bill Wilson #/ K d #/V,d 4

DATE: March 9, 1989

SUBJECT:

My retirement and its impact on the Radiation Center My position at the Radiation Center has been one involving long hours and lots of pressure and stress over a long period of time due to the nature of a nuclear reactor operation. The impact of the job over a 20-year period, especially the increased stress over the past two years, has had a significant impact on my health and my wife and family have prevailed upon me to retire from full-time employment on July 1, 1989.

For many years I have been arranging things so that I could retire on or after 10/1/86 when my service to the State, plus military service, equaled 30 years. I spent ten years in various management positions at the University of Washington reactor and the past 20 years in a management position at the Washington State University TRIGA reactor. I have been eligible to retire under pERS I since 10/1/86. I was considering retirement in 1988 but late in the winter of 1987 I elected to continue my employment at the Radiation Center in deference to, the impact my retirement would have upon the staff of the Center (overriding my personal interests) due to the eminent possibility of decommissioning or refueling. It is now apparent that these activities will not take place for I a few years beyond the time I am willing to work full-time f because of health and personal considerations. Accordingly, I l intend to retire from full-time employment as previously  !

stated above at the end of June, 1989.

I will consider helping to lessen the impact of my retirement on the Radiation Center by working part-time as is permitted under the State Retirement System regulations. The maximum that I would be allowed to work is 40% (two days a week) and I would not desire to do even this for more than about a year, 1 depending on my health. Such an arrangement should allow my i replacement to be hired and qualified while still meeting all the staffing requirements of the reactor license.

( Barbee, Smith & Safeguards Committee

) March 9, 1989 Page 2 WSU and the Radiation Center have one of two formidable tasks which must be completed in the near future. The fuel in the reactor must be changed from HEU to LEU fuel or, if the Administration so chooses, the facility decommissioned.

Either of these options will require a very experienced and )

SRO licensed reactor management person in addition to the j Reactor Supervisor. These operations will require a thorough l understanding of the Federal regulations as well as the l requirements in the facility license and will involve quality l assurance considerations, safety analysis of each major operation and criticality considerations. Recently, the ]'

Federal government made changes in the regulations concerning decommissioning planning for all non-power reactors. Before July 26, 1990, WSU must submit a preliminary decommissioning 1 plan, including: 1) a cost estimate for decommissioning, 2) a l statement indicating the method by which the funds will be

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provided, and 3) a method of periodically adjusting the cost '

estimate. The government is essentially forcing all non-power reactor owners to realistically look at the costs of decommissioning and to set up a mechanism or fund to cover the cost of this possible eventuality. I recently received a cost proposal for decommissioning the WSU reactor from the Nuclear and Advanced Technology Division of Westinghouse that will l enable WSU to file the required information. '

Historically, the Director of the WSU Radiation Center has been an faculty member with a PhD in physical science and with a number of years experience in nuclear science research. The i

i ANSI ctandard for the selection and training of personnel at l research reactors does not give specific requirements for the '

Level 1 person or director but indicates that he should be a very experienced senior person. One of the unwritten rules in dealing with the Nuclear Regulatory Commission is that they will never, . never let you decrease a specified requirement or self-imposed one once established. Thus, I am not certain how the Commission will view the permanent appointment of a director who is not a senior faculty member with a PhD and a number of years of nuclear science experience.

Another point that must be taken into consideration is that in 1969 when I came to work at the WSU reactor there were also two other nuclear engineers on the staff of the facility.

Thus, the number of professionally trained nuclear engineers with extensive research reactor experience has dropped from three to one and is about to drop to zero. Obviously, this will not be acceptable to the Commission and probably will be viewed as a violation of the facility license. A professionally trained nuclear engineer with research reactor I

Barbee, Smith, Safeguards Committee March 9, 1989 Page 3 experience thus must be hired to replace me as soon as is possible.

The problem that WSU will encounter in hiring someone to replace me is that the pool of qualified people with the requisite academic training and research reactor experience is very, very small. I doubt very much that WSU will find a qualified person to replace me who will come to work at WSU unless WSU offers that person the director's position. The number of people entering nuclear engineering programs has significantly- declined in the past ten years and the demand for experienced nuclear people at nuclear power plants has risen recently. There are numerous open faculty positions in the Nuclear Engineering programs of various schools and the University for of Texas has had a hard time obtaining a director their new TRIGA reactor facility.. Thus, I highly recommend that consideration be seriously tven to collapsing the functions of the Director and Associat Director into one full-time position and that an appropriately qualified person be hired for the combined job. Such a person would need to be qualified and experienced in the areas of reactor physics, reactor operations and neutron activation analysis. This person would also need to obtain an SRO license for the WSU TRIGA reactor and meet the experience requirements of the ANSI standard for such positions. Also, this person should have good managerial skills and get along with the staff of the Center.

The need for both a director and associate director no longer and the exists at the Center since the size of the operation number of faculty and staff at the Center has decreased by about a factor of two over the past ten years.

A nuclear reactor is not a toy but rather a very complex system and refueling the core with a new type of fuel is. a complicated task. The design of a new core is not a task for reactor operators or senior reactor operators but requires an experienced nuclear engineer. The original TRIGA core was installed by General Atomics and I have redesigned the core arrangement a number of times since then, including shifting to a mixed core of Standard and FLIP fuels. Over the years I have task.

developed a computer code system to simplify the design )

However, it takes someone experienced in nuclear reactor physics and core design at least at the MS level to operate the code and to understand its output. The seven neutron energy group two-dimensional neutronic code that is used to simulate the WSU TRIGA reactor requires 200K of memory space on the University IBM mainframe computer to run and produces a pile of output one inch thick. A new library of cross-section data will need to be added to the code for the

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1 Barbee, Smith, Safeguards Committee j March 9, 1989 Page 4 new LEU type fuel and calculated on a new core made with this new data. The reactor license contains a number of constraints on the reactor core related to safety that must be evaluated for each new core. The computer code significantly helps evaluate the safety-related parameters as well as predicting the performance of the core.

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&E,30,3A,gD_U_g TO: Reactor Operating Staff r

• FROM: Roy H. Filby, Director (

. DATE: October 6,1981

SUBJECT:

Administrative' Procedures

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The management policies of the WSU Nuclear Radiation Center _ relating to the administration and operation of the WSU TRIGA reactor are set forth

'in'the attached Administrative Procedures. The administrative procedures are designed to supplement the Standard Operating Procedures and are in-tended to clearly define the administrative requirements, responsibilities, and authority within *,he Reactor Operating Group.

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W.S.U. NUCLEAR RADIATION CENTER Administrative Procedure RESPONSIBILITIES AND AUTHORITY OF REACTOR OPERATING STAFF I. Ultimate Responsibility The ultimate responsibility for the safe operation of the WSU TRIGA Reactor located at the Radiation Center is the Licensee, which is Washington State University. The university administration delegates this responsi-bility through the Graduate School to the management of the Radiation Center. Changes in the management of the Radiation Center shall be reviewed by the WSU Reactor Safeguards Committee. The responsibility of the Radiation Center management shall include, but not be limited to:

1) assuring the safe operation and maintenance of the W.S.U. TRIGA Reactor and associated ecuipment.

2) assuring that the facility is operated in accordance with all appli-cable state and federal regulations as well as the facility license, and

3) assuring the enforcement of rules for the protection of personnel from excessive exposure to radiation.

The responsibility and authority delegated to the Radiation Center Management for the safe operation of the reactor is vested in the most senior licensed member of the Center Management. At the WSU Radiatier Center, this individual is the Associate Director.

II- Associate Director The Associate Director shall be a licensed senior reactor operator, shall assist the Director in the general direction of the Nuclear Radiation Center and assume the responsibilities of the Director in his absence and .

shall have the following listed responsibilities and authority:

1) managing the reactor operations group and administrative group,  !

2) being responsible for assuring the safe operation of the W.S.U. Reactor in accordance with applicable state and federal regulations and the facility license. I

. W.S.U./NRC. I Administrative Procedure Page 2

3) approving all procedures and changes of procedures, f

4) reviewing and approving the procurement of equipment and supplies for the operation of the reactor,

5) recommending to the Director the hiring and promotion of personnel  !

as required,

6) functioning as the training coordinator and assuring that the proper training is conducted, that the staff is properly qualified as speci-fied by the requalification plan, and assuring that the required training records are maintained,

7) handling all correspondence with the U.S. Nuclear Regulatory Commis-sion,

8) maintaining a Special Nuclear Materials inventory system to meet the requirements of federal regulations and the facility license.

This includes the preparation and submission of Material Status Reports and S.N.M. transfer reports,

9) approving all physical changes in or modifications to the reactor core, reactor instrumentation, or other reactor related facilities and equipment,

10) reviewing and approving the safety analysis for proposed 50.59 changes and forwarding them to the Reactor Safeguards Committee for their review,

11) taking part in the designing of experiments for the reactor to ensure that they will be operable, safe, and will not interfere with the operation of the reactor,

12) developing and submitting special plans required by state and fed- -

eral regulations including 1) physical security plan, 2) reactor operator requalification plan, and 3) emergency response plan, ,

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. . W.S.U./NRC.

Administrative Procedure Page 3 ,

13) submitting renewal requests to the N.R.C. for reactor operators and senior operators, and

14) preparing applications for facility license amendments and changes to the Technical Specifications of the reactor.

III. Reactor Supervisor The Reactor Supervisor shall be a licensed senior operator and shall have the following listed responsibilities and authority:

1) supervising all the personnel in the reactor operations group,

2) developing and ma[ntaining operating procedures for assuring the I safe operation and maintenance of the W.S.U. reactor in accordance with applicable state and federal regulations and facility adminis-l trative procedures and assuring that the applicable procedures are 1

adhered to,

3) reviewing Health Physics surveys for adequacy and initiating addi-l tional surveillance as required, 1

4) maintaining and assuring facility security in accordance with the the physical security plan, including _ security training for staff and police,

5) assuring that R.O. and S.R.0. operational and supervisory requali-fication requirements are met,

6) developing and maintaining a record system on reactor operations )

as required by Facilities License R-76 and the facility administra-  ;

tion procedures as listed below:

a) Reactor operating records, including power levels and periods of operation at each power level l o L _----_ _ - - _ - - - - _ - - - _ _ - - - - - _ - - - - - _ - _ _ - _ - - - _ - - - - - _ _ _ _ _ _ _

'. WSo Te c L, Spec 7 (7) offsite inventories and transfers (8) fuel inventories and transfers (9) facility radiation and contamination surveys (10) ra'diation exposures for all personnel (11) updated, corrected, and as-built drawings of the facility Reporting Requirements In addition to the requirements of applicable regulations, and in no way sub-stituting for those requirements, reports shall be made to the NRC as follows:

(1) A report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and telegraph to the Region V Office of Inspection and Enforcement with a copy to the Director of Reactor Licensing, of (a) Any accidental release of radioactivity above permissible limits in unrestricted areas whether or not the release resulted in property damage, personal injury, or exposure; (b) Any violation of the safety limit; (c) Any reportable occurrence as defined in Section 1.1, " Reportable Occurrence," of these specifications.

(2) A report within 10 days in writing to the Director, Office of Nuclear Reactor Regulation USNRC, Washington, D.C. 20555, with a copy to the NRC Region V Office of Inspection and Enforcement, of (a) Any accidental release or radioactivity above permissible limits in unrestricted areas whether or not the release resulted in property damage, personal injury, or exposure. The written report (and, to the extent possible, the preliminary telephone or telegraph report) shall describe, analyze, and evaluate safety implications, and out-line the corrective measures taken or planned to prevent reoccurrence of the event, (b) Any violation of a safety limit, (c) Any reportable occurrence as defined in Section 1.1, " Reportable Occurrence," of these specifications.

(3) A report within 30 days in writing to the Director, Office of Nuclear Reactor Regulation, USNRC, Washington, D.C. 20555, with a copy to the NRC Region V Office of Inspection and Enforcement, of (a) Any significant variation of measured values from a corresponding predicted or previously measured value of safety-connected operating characteristics occurring during operation of the reactor, (b) Any significant change in the transient or accident analysis as described in the Safety Analysis Report, (c) AnyJignificant changes in facility organization, 34

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(d). Any observed inadequacies in the implementation of adminiittative or

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pretiidural controls.

(4) A report.within 60 days after completion of startup testing of the reactor (in writing to the Director, Office of Nuclear Reactor Regulation, USNRC, Washington, D.C. 20555) upon receipt of a new facility license or an amendment to the license authorizing an increase in reactor power level describing the measured values of the operating conditions including:

'(a) An evaluation of facility performance to date in comparison with desige Predictions and specifications, (b) A reassessment of the safety analysis submitted with the license application in light of measured operating characteristics when such measurements indicate that there may be substantial variance from prior analysis.  !

(5) An annual report within 60 days following the 30th of June of each year (in writing to the Director, Division of Licensing, USNRC, Washington, D. C. 20555) with a copy to the NRC Region V Office of Inspection and Enforcement providing the following information:

(a) A brief narrative summary of (i) operating experience (including experiments performed), (ii) changes in facility design, performance characteristics, and operating procedt.res related to reactor safety and occurring during the reporting period, and (iii) results of sur-veillance tests and inspections; (b) Tabulation of the energy output (in megawatt-days) of the reactor, hours :eactor was critical, the cumulative total energy output since initial criticality, and number of pulses greater than 1.005; (c) The number of emergency shutdowns and inadvertent scrams, including reasons for them; (d) Discussion of the major maintenance operations performed during the period, including the effect, if any, on the safety of the operation of the reactor and the reasons for any corrective maintenance required; (e) A brief description, including a summary of the safety evaluations of changes in the facility or in procedures and of tests and experiments carried out pursuant to 10 CFR 50.59; (f) A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge:

Liouid Waste (summarized on a monthly basis)

(i) radioactivity discharged during the reporting period total estimated quantity of radioactivity released (in curies),

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1 6.5.2 Composition and Qualifications The RSC shall be composed of at least five members knowledgeable in fields that relate to nuclear reactor safety. The members of the committee shall include one facility Senior Reactor Operator and WSU faculty and staff members designa- i ted to serve on the committee in accordance with the procedures specified by the WSU committee manual, The university's Radiaiton Safety Supervisor shall i

be an exofficio member of the committee.

i 6.5.3 Operation The Reactor Safeguards Committee shall operate in accordance with a written charter, including provisions for (1) meeting frequency: the full committee shall meet at least semiannually and a subcommittee thereof shall meet at least semiannually (2) voting rules (3) quorums: chairman or his designate and two members (4) method of submission and content of presentations to the committee (5) use of subcommittees (6) review, approval, and dissemination of minutes 6.5.4 Reviews The responsibilities of the RSC or designated Subcommittee thereof shall include, but is not limited to, the following:

(1) review and approval of all new experiments utilizing the reactor facility (2) review and approval of all proposed changes to the facility license by amendment, and to the Technical Specifications s  !

(3) review of the operation and operational records of the facility (4) review of significant operating abnormalities or deviations from normal and expected performance of facility equipment that affect nuclear safety (5) review and approval of all determinations of whether a proposed change, test, or experiment would consititute a change in the Technical Specifi-cations or on unreviewed safety question as defined by 10 CFR 50 '

(6) review of reportable occurrences and the reports filed with the Commissions for said occurrences (7) review and approval of all standard operating procedures and changes thereto (8) biennial review of all standard procedures, the facility emergency plan, and the facility security plan 31

, , @g; km YlL MV-Washington StateUniversity Office of the Vice Provost for Research and Dean of the Graduate school Pullman, Washington 99164-1030 / 509-335-3535 February 22,1989 Director, Nuclear Reactor Regulation United States Nuclear Regulatory Commission MS Pl 137 Washington, D. C. 20555

Dear Sir:

This is to request that the application of January 30,1989 from Washington State University to amend the Technical Specifications to Facility License No.

R-76 be withdrawn. The proposed amendments did not receive the proper University administrative approval before they were submitted.

Sincerely, W !.' QV;L W. E. Wilson

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Associate Director Nuclear Radiation Center App ed:

Robert V. Smith Vice Provost for Research and Dean of the Graduate School l

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. Washington State University Nuclear Radiation Center, Pullman, Washington 99164-1300 / 509 335-8641 January 30, 1989 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission MS P1-137 Washington, DC 20555

Dear Sir:

Under the provisions of Section 5.90 of 10 CFR 50 and in accordance with recent changes to the federal regulations concerning decommissioning, in light of the recent facility problem with sealed sources in the reactor pool and to more specifically define the operation of the facility in relation to the organization chart contained in the facility Technical Specifications, application is hereby submitted to amend the Technical Specifications of Facility License No. R-76. The specific purposes of these changes are: 1) to ensure timely compliance to the recent changes to the regulations concerning decommissioning by the addition of new Section 6.12; 2) to preclude any future problem concerning sealed sources in the reactor pool by the addition of new Section 6.11; and, 3) to more specifically define the operation of the facility within this university administration and to replace Sections 6.1 to 6.4 and 6.5.6(1) of the Technical Specifications with appropriate wording to fulfill the requirements of 10 CFR 50.36.

The new proposed wording for Sections 6.1 to 6.4 and 6.5.6(1) of the Technical Specifications are attached. The proposed wording is to entirely replace the present wording of Sections 6.1 to 6.4 and 6.5.6 (1) . Additional wording to 6.8 (1) is also I proposed to clarify the review requirements for this specific I procedure.

Sincerely, l

h {. $f W.E. Wilson Associate Director 1

Approved:

G.S. Collins, Chair {

Reactor Safeguards Committee

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November 9,1988 Robert Smith', Dean-The Graduate School.

Washington State. University

. Pullman, Washington 99163

Dear Dean Smith:

The. purpose of this letter is to confirm our telephone conversation with your Radiation Safety. Officer, B. Srinivasan, on November 4, 1988, ordering Washington' State University to immediately cease further manufacture and distribution of Professor Brian t.amb's~ atmospheric gas chromatography, cease further receipt 'of: sealed sources for use in the pool irradiator,- and to ensure that the Tritium neutron generator will not be used for. research until

-appropriate procedures are submitted to our office ,for evaluation. Dr.

Srinivasan's verbal statement of intent to comply with this order is hereby acknowledged. These actions have been taken for the following reasons:

.t. On February 25, ,1986, the University requested-permission .to conduct research and development work on Professor Brian Lamb's atmospheric gas chromatograph.. Authorization was granted by t.eo Walnhouse of this of fice.. with the stipulation that this office would be notified prior to -

any distribution, and that NRC Fuel Cycle Directive 84-22. would be followed before distributing the GC units. _

Contrary to the above, seven i gas chromatography have been manufactured and distributed, two of which were sent out of the country to the People's Republic of China.

2. -

The radioactive sources received from J. L. Shepherd & Associates for placement in your pool irradiator are of unknown construction. Although 3 a (

safety evaluation was performed by Dr. Srinivasan prior to receipt of these sources, he was unable to aseure us that the sources were evaluated )

for water immersion. Therefore, we have serious concerns for the poten-tial contamination of the pool, the pool reactor, and the containment ,

building. Sealed sources used in Category 3 pool irradiators must meet ANSI Standard N542-1977. Furthermore, Todd Tillinghast of Vallecitos i Nuclear Center stated that the 5,001 curie GE source, serial number GEC-JCS-9147, which they encapsulated prior to delivery to you, was not evaluatedfo{compliancewiththeANSIstandard.

13. Contrary.tokyourRadiationSafetyOffice's agreement with us that no research work would be conducted with the Tritium neutron generator until the proper procedures had been received and approved by our office, our recent intpartion af the liniversity thawod that rataarch work had been ,

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Robert Smith, Dean Page Two i

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Other items of concern from our compliance inspection of October 10-13, 1988, will be documented in a formal compliance letter to follow within the next 20 days; however, pursuant to this letter, I am requesting that the University provide the following material to me no later than the close of business, November 18, 1988: 4

1. An inventory of all sealed sources received from J. L. Shepherd & Associ-ates and placed in your reactor pool, listing the man'ufacturer, model number, activity, and serial number, where applicable.

2. A copy of the Radiation Safety Officer's safety evaluation for all the above sealed sources. '

3. A list of all the firms which received Professor Lamb's gas chromato-graphs, and copies of their current radioactive materials licenses. ,

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4. Copies of all Radiation Safety Committee meeting minutes in which the manufacture and distribution of the gos chromatograph units, acquisition of sealed sources for the pool irradiator, and/or use of the Tritium neutron generator for research were discussed.

The issues we hava raita<t in niir October 10-13, 1969 inspection of your license, and in this letter concerning additional issues, are most serious, requiring an immediate followup inspection and review of , radiation safety practices and the activities of the University's Radiation Safety Committee.

My staff will be in touch with you regarding acceptable dates for our return visit.

If you have ouestions, feel free to contatt me at (206) 753-3468, or Gary Robertson of my staff at (206) 753-3351.

Sincerely,

. R. St ng, Chief ;

TRS:kf OfficeofRadiationProtec{ ion 1

cc: B. Srinivasan Radiation Safety Officer M 4/E- W3 -3?'

• U.S. NRC, Region V i

Richard McCartan Assistant Attorney General

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