IR 05000193/2021201

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Rhode Island Atomic Energy Commission U.S. Nuclear Regulatory Commission Routine Inspection Report 05000193/2021201 Cover Letter and Enclosure
ML21126A112
Person / Time
Site: Rhode Island Atomic Energy Commission
Issue date: 06/01/2021
From: O'Bryan P
NRC/NRR/DANU/UNPO
To: Goodwin C
Rhode Island Nuclear Science Center
Bassett C
References
IR 2021201
Download: ML21126A112 (16)


Text

June 1, 2021

SUBJECT:

RHODE ISLAND ATOMIC ENERGY COMMISSION - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000193/2021201

Dear Dr. Goodwin:

From April 26-29, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Rhode Island Nuclear Science Center research reactor facility. The enclosed report documents the inspection results which were discussed on April 29, 2021, with you and members of your staff, as well as Dr. Clinton Chichester, Chairman, Rhode Island Atomic Energy Commission.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspector reviewed selected procedures and records, observed various activities, and interviewed various personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely, Digitally Philip B. signed by for O'Bryan Philip B.

O'Bryan Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-193 License No. R-95 Enclosure:

As stated cc: See next page

Rhode Island Atomic Energy Commission Docket No.59-193 cc:

Governor Test, Research and Training 222 State House Room 115 Reactor Newsletter Providence, RI 02903 Attention: Amber Johnson Dept of Materials Science and Engineering Howard Chun, Commissioner University of Maryland Cranston High School East 4418 Stadium Drive 899 Park Avenue College Park, MD 20742-2115 Cranston, RI 02910 Dr. Clinton Chichester, Chairman Rhode Island Atomic Energy Commission College of Pharmacy Pharmacy Building 7 Greenhouse Road Kingston, RI 02881 Dr. John Breen, Chairman Nuclear and Radiation Safety Committee Providence College Department of Chemistry and Biochemistry 1 Cunningham Square Providence, RI 02918 Dr. Yana K. Reshetnyak, Commissioner Department of Physics University of Rhode Island 2 Lippitt Road, East Hall Kingston, RI 02881 Dr. Nancy E. Breen, Commissioner Marine and Natural Science Building 226 Roger Williams University One Old Ferry Road Bristol, RI 02809 Supervising Radiological Health Specialist Office of Occupational and Radiological Health Rhode Island Department of Health 3 Capitol Hill, Room 206 Providence, RI 02908-5097

ML21126A112 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME CBassett NParker TTate(POBRYAN for)

DATE 5/6/2021 5/6/2021 6/1/2021

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-193 License No.: R-95 Report No.: 05000193/2021201 Licensee: Rhode Island Atomic Energy Commission Facility: Rhode Island Nuclear Science Center Location: Narragansett, Rhode Island Dates: April 26-29, 2021 Inspectors: Craig Bassett Michael Tackas Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Rhode Island Atomic Energy Commission Rhode Island Nuclear Science Center Facility Inspection Report No. 05000193/2021201 The primary focus of this announced, routine inspection was the onsite review of selected aspects of the Rhode Island Atomic Energy Commissions (the licensees) Class I, 2 megawatt research reactor safety program including: (1) effluent and environmental monitoring; (2)

organization and operations and maintenance activities; (3) review and audit and design change functions; (4) emergency preparedness; (5) radiation protection; and, (6) transportation activities. The review covered from the date of the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas to the present. The NRC staff determined the licensees program was acceptably directed toward the protection of public health and safety and in compliance with NRC requirements.

Effluent and Environmental Monitoring The environmental protection program satisfied NRC requirements.

Organization and Operations and Maintenance Organizational structure and staffing were consistent with technical specification (TS)

requirements.

Review and Audit and Design Change Functions The review and audit program was conducted and completed by the Nuclear and Radiation Safety Committee (NRSC), as stipulated in the facilitys TS Section 6.2.

Changes made at the facility were reviewed using guidance in the licensees Facility Modification Procedure, AP-03, and Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.59, Changes, tests and experiments.

Emergency Preparedness The licensee maintained an effective emergency preparedness program through implementation of the emergency plan (E-Plan) and the associated implementing procedure.

Radiation Protection The inspector determined that the Radiation Protection and as low as reasonably achievable (ALARA) programs, as implemented by the licensee, satisfied regulatory requirements.

Transportation Activities Shipments of radioactive material (RAM) made under the reactor license were in compliance with NRC and Department of Transportation (DOT) regulations.

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REPORT DETAILS Summary of Facility Status The licensees Class I Rhode Island Nuclear Science Center (RINSC) 2-megawatt research reactor continued to be operated in support of experiments, research, education, training, and surveillance. During the inspection, the reactor was operated for research and development.

1. Effluent and Environmental Monitoring a. Inspection Scope (IP 69004)

The inspector reviewed the following to verify that the requirements of 10 CFR Part 20, Standards for Protection Against Radiation, Appendix B and TS Sections 3.7.2 and 4.7.2 were met:

stack continuous air monitor records environmental dosimetry records for 2019 through the present various Nuclear Science Center (NSC) forms including: NSC-03A, Secondary Water Analysis; NSC-03B, Primary Water Chemistry; NSC-09, Sewer Discharge Report; and NSC-78, Monthly Information Sheet Annual Radiation Safety Program Reviews performed by the radiation safety officer (RSO) for 2019 and 2020 RINSC Annual Report for the period from July 1, 2018, through June 30, 2019, submitted to the NRC on July 26, 2019 RINSC Annual Report for the period from July 1, 2019, through June 30, 2020, submitted to the NRC on July 13, 2020 b. Observations and Findings (1) Environmental Radiation Monitoring The inspector noted that environmental radiation monitoring was accomplished using thermoluminescent dosimeters (TLDs) placed at different monitoring stations. The inspector found that the licensee adjusted the readings by using an occupancy factor to approximate annual dose. After applying the annual occupancy factor, the inspector confirmed that the results at those locations indicated dose rates less than the regulatory limit for members of the general public.

(2) Gaseous Effluent Releases The inspector verified that gaseous releases continued to be monitored, calculated according to procedure, and documented in the annual reports. The inspector noted that the predominant gaseous release from the facility was Argon-41. The inspector confirmed that airborne concentrations of the gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2. The inspector also found that the dose rate to the public as a result of the gaseous releases was well below the dose constraint of 10 millirem per year (mrem/yr) specified in 10 CFR 20.1101, Radiation protection programs,

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paragraph (d). The inspector confirmed that this was demonstrated by the licensee through COMPLY code calculations.

(3) Liquid Effluent Releases The inspector confirmed through a review of the liquid effluent releases from the facility to the sanitary sewer that proper methods were followed prior to the releases. The inspector verified that releases were within the monthly average concentration limits established in 10 CFR Part 20, Appendix B, Table 3.

(4) Effluent Monitoring Equipment Calibration and Maintenance The inspector reviewed the calibration and maintenance records of the normal and backup stack monitors. The inspector noted that the stack monitors were calibrated annually and were calibrated by licensee staff personnel.

c. Conclusion The inspector determined that effluent releases were within the specified regulatory and TS limits and the environmental protection program satisfied NRC requirements.

2. Organization and Operations and Maintenance Activities a. Inspection Scope (IP 69006)

To verify that the licensee complied with the requirements for organization, staffing, and operations activities (as specified in TS Sections 2.0, 3.0, 6.1, and procedural requirements), the inspector reviewed selected aspects of the following:

reactor logbook Nos. 64, 65, and 66 RINSC organizational structure and staffing various notebooks, documents, and procedures reactor operations documents maintained in operating data notebooks for 2020 and 2021 b. Observations and Findings (1) Organization The inspector reviewed the facility organization and staffing. The inspector noted that the person who was Reactor Supervisor (RS) at the facility for several years retired during the interim since the last NRC inspection. The individual who was the Principle Reactor Operator was selected to fill the RS position. The inspector verified that the new RS has the qualifications listed in TS 6.1. The inspector confirmed that the organizational structure at the facility was in compliance with the TSs.

(2) Operations The inspector reviewed various forms that were required to be completed to document reactor operations. The inspector reviewed reactor logbook entries-5-

concerning staffing requirements as specified in TS 6.1.2 and 6.1.3 and verified that shift staffing during reactor operations met those requirements.

c. Conclusion The inspector determined that the organizational structure and shift staffing were in compliance with TS requirements.

3. Review and Audit and Design Change Functions a. Inspection Scope (Inspection Procedure (IP) 69007)

The inspector reviewed selected aspects of the following with respect to the review and audit program and design change activities to ensure compliance with TS Section 6.2 and 10 CFR 50.59 NRSC meeting minutes for 2019 through 2021 Annual Radiation Safety Program Reviews for 2019 and 2020 NRSC Charter, Revision 5, approval dated September 11, 2017 RINSC Annual Reports submitted to the NRC in 2019 and 2020 RINSC Administrative Procedure, AP-03, Facility Modifications, Revision 2 various NSC forms including: NSC-24, 10 CFR 50.59 Screen and NSC-51, 10 CFR 50.59 Review for modifications or changes to the facility and/or procedures b. Observations and Findings (1) Review and Audit Functions The inspector reviewed the NRSC meeting minutes and associated records for 2019 through 2021. The inspector verified that meetings were held, and safety reviews and audits were conducted by various members of the NRSC or other designated persons and at the required frequency. The inspector verified that topics of those reviews and audits were consistent with TS requirements.

(2) Design Change Functions The inspector reviewed the design change program used at the facility. The inspector noted that the licensees procedure governing design changes provided guidance concerning the review of facility modifications and changes to procedures using the 10 CFR 50.59 review and evaluation process. The inspector confirmed that the facility design change program was implemented in accordance with the regulations and the licensee procedure.

c. Conclusion The inspector determined that audits were completed and that the NRSC was meeting, and reviewed the topics outlined in the TS. The inspector also determined that changes to the facility, programs, and procedures were evaluated using the criteria specified in 10 CFR 50.59.

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4. Emergency Preparedness a. Inspection Scope (IP 69011)

The inspector interviewed staff members and reviewed various documents to verify compliance with regulatory requirements and the RINSC E-Plan, Revision 7:

emergency preparedness notebook containing documentation of various activities including:

- fire alarm tests

- emergency training and drills conducted during the past year

- emergency communication tests conducted with various support agencies

- completion of annual emergency supply inventories RINSC Emergency Procedure, EP-01, Emergency Plan Implementing Procedure, Revision 5 letters of agreement (LOA) between RINSC and the Narragansett Police Department (NPD), the Rhode Island Hospital, and the Narragansett Fire Department (NFD)

b. Observation and Findings The inspector reviewed the E-Plan in use at the reactor and verified that it was reviewed and updated biennially. The inspector also reviewed the associated emergency procedure and noted that it was reviewed biennially and revised as needed.

Through records review, including the report referencing the most recent drill conducted on November 19, 2020, and interviews with licensee personnel, the inspector found that staff were knowledgeable of the proper actions to take in case of an emergency. The inspector confirmed that emergency and evacuation drills were conducted annually as required by the E-Plan. The inspector found that training for licensee personnel was accomplished annually, in conjunction with the evacuation and emergency drill. The inspector verified that training for offsite support organizations (i.e., police and fire departments) was provided whenever those organizations were available and/or whenever requested.

The inspector confirmed that the LOAs between the RINSC facility and the NPD and the NFD remained in effect. These agreements stipulated that police and fire personnel would respond during an emergency and would provide support for the facility. The inspector also verified that the LOA between the facility and Rhode Island Hospital was current. That agreement ensured that the hospital treat RINSC personnel in case of injury.

The inspector reviewed the communications capabilities with support groups and found that the various items of equipment (e.g., telephones and the building public address system) were functional and in use daily. Portable radios were also available for use as needed and were checked annually. The inspector confirmed that the emergency call list was revised and copies were available in the control room and in various areas around the facility, as well as in the Emergency Support Center. The call list was updated annually as required by the E-Plan.

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c. Conclusion The inspector determined that the licensee maintained an effective emergency preparedness program through implementation of the E-Plan and the associated emergency procedure.

5. Radiation Protection a. Inspection Scope (IP 69012)

The following documents were reviewed to determine compliance with 10 CFR Part 19, Notices, Insturctions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20 and with TS Sections 3.7.1 and 4.7.1 requirements regarding radiation protection:

radiation safety training modules and records RINSC radiation safety office radiation safety manual Annual Radiation Safety Program Reviews for 2019 and 2020 RINSC Annual Reports submitted to the NRC in 2019 and 2020 copies of NRC Form 3, Notice to Employees, posted at the facility quarterly dosimetry reports for facility personnel from January 2019 through December 2020 selected survey program summary data and the associated survey reports for 2020 through the date of this inspection selected calibration records of portable survey instruments, area radiation monitors (ARMs), and stack air monitors for the past 2 years b. Observations and Findings (1) Surveys The inspector reviewed selected weekly, monthly, quarterly, and semi-annual radiation and contamination surveys. The inspector noted that surveys were completed by trained staff members at the frequency required by procedure. The inspector found that results of the surveys were documented, and the records maintained as stipulated by procedure.

During the inspection, the inspector accompanied the Reactor Health Physicist (RHP) during the performance of a routine weekly radiation and contamination survey of the reactor bay and control room within the confinement building. The inspector noted that the techniques used by the RHP during the survey were proper and the survey was satisfactorily conducted and documented.

(2) Postings and Notices The inspector verified that caution signs and postings were posted and controls for radiation areas and high radiation areas were enforced as required in 10 CFR Part 20, Subparts G and J. The inspector noted that licensee personnel followed the directions of the signs and postings and the precautions for access to the various controlled areas in the facility.

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The inspector verified that copies of current notices to workers were posted in various areas in the facility. The copies of NRC Form 3 noted at the facility were the latest issue and were prominently posted as required by 10 CFR 19.11, Posting of notices to workers.

(3) Dosimetry Reports/Personnel Exposure The inspector verified that the licensee used TLDs to monitor staff and designated users whole body exposure to beta, gamma, and neutron radiation.

The inspector verified that the licensee also used TLD finger rings for extremity monitoring. The inspector noted that dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor.

Through direct observation, the inspector confirmed that dosimetry was used by facility personnel as required by procedure. An examination of the TLD results by the inspector for the past 2 years showed that all the occupational doses for facility personnel, as well as doses to the public, were within 10 CFR Part 20 limits.

The inspector confirmed that copies of each licensee monitored individuals exposure information was maintained by the RSO. The inspector verified that, if an individual received greater than 100 mrem occupational exposure, a report with the pertinent information (NRC Form 5, Occupational Dose Record for a Monitoring Period, equivalent) was provided to the person as required by 10 CFR Part 19.

(4) Maintenance and Calibration of Radiation Monitoring Equipment The inspector examined selected items of radiation monitoring equipment and noted that the instruments were up-to-date with calibration stickers attached.

Through a review of selected instrument calibration records for various meters, the inspector verified that the licensees survey instruments were calibrated annually as required by procedure and the appropriate calibration records were maintained.

The inspector also reviewed the calibration and maintenance records of various ARMs. It was noted by the inspector that the ARMs were calibrated annually as required by procedure and were typically calibrated by licensee staff personnel.

The inspector verified that records were current and maintained as required by procedure.

(5) Radiation Safety Training The inspector reviewed the licensees radiation safety training program. The inspector noted that training was given to RINSC staff members, to those who were not on staff but who were authorized to use the experimental facilities of the reactor (Authorized Users), and to students taking classes at the facility. The training was given by the RSO at the facility. The inspector confirmed that initial radiation worker training was provided for those new to the facility. Following initial training, refresher training was required to be completed on an annual basis. The inspector confirmed that the subjects covered during training satisfied the requirements in 10 CFR 19.12.

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(6) Radiation Protection Program The inspector noted that the licensees Radiation Protection and ALARA programs were established and described in the RINSC Radiation Safety Office Radiation Safety Manual. The programs were also outlined in, and implemented through, the RINSC facility radiation safety procedures that were reviewed and approved. The inspector confirmed that the programs contained instructions concerning organization, training, monitoring, personnel responsibilities, handling RAM, and maintaining doses under the ALARA concept. The inspector noted that the program satisfied regulatory requirements.

(7) Facility Tours The inspector toured the facility with licensee representatives on various occasions and observed areas including the reactor bay, control room, the basement area, and selected support laboratories. The inspector noted that facility RAM storage areas were properly posted. No unmarked RAM was noted.

c. Conclusion The inspector determined that the Radiation Protection and ALARA programs, as implemented by the licensee, satisfied regulatory requirements.

6. Transportation Activities a. Inspection Scope (IP 86740)

The inspector reviewed the following documents to determine compliance with NRC and DOT regulations governing the transportation of RAM as specified in 10 CFR Part 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and in 49 CFR Parts 171-178.

training records for those designated as shippers of RAM Annual Radiation Safety Program Reviews for 2019 and 2020 RAM shipping papers and related records for 2020 through 2021 licenses of those persons or entities receiving a RAM shipment from the licensee various forms including: NSC-56, DOT shipping check list - Exempt and Excepted quantity materials only, and NSC-06, DOT shipping check list - Type A quantity only b. Observations and Findings Through records review and discussions with the RSO, the inspector found that the licensee made no RAM shipments in 2020 but made shipments in 2021. The inspector verified that the shipments were completed in accordance with DOT and NRC regulations. The inspector also verified that the licensee maintained a copy on file of each recipients license to possess RAM as required by the regulations.

The inspector reviewed the training of RINSC staff members responsible for shipping RAM. The inspector verified that the staff members, who are currently designated as

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shippers, received the appropriate training within the last 3 years, covering the requirements of the DOT and the NRC.

c. Conclusion The inspector determined that licensee shipments of RAM made under the facilitys reactor license were completed in accordance with NRC and DOT requirements.

7. Exit Interview The inspector presented the inspection results to licensee management and staff at the conclusion of the inspection on April 29, 2021. The inspector discussed the areas inspected and the inspection observations. The licensee acknowledged the results of the inspection and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee J. Davis Assistant Director for Operations Facility Director M. Marrapese Reactor Supervisor J. McCullah Reactor Health Physicist S. Nam Assistant Director for Radiation and Reactor Safety/Radiation Safety Officer B. Sirr Facility Engineer Other Personnel C. Chichester Chairman, Rhode Island Atomic Energy Commission S. Partington Fire Chief, Narragansett Fire Department, Town of Narragansett INSPECTION PROCEDURES USED IP 69004 Class I Research and Test Reactor Effluent and Environmental Monitoring IP 69006 Class I Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69011 Class I Research and Test Reactor Emergency Preparedness IP 69012 Class I Research and Test Reactors Radiation Protection IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable ARM Area Radiation Monitor DOT Department of Transportation E-Plan Emergency Plan IP Inspection Procedure LOA Letter of Agreement NRC U.S. Nuclear Regulatory Commission NRSC Nuclear and Radiation Safety Committee Attachment

NFD Narragansett Fire Department NPD Narragansett Police Department NSC Nuclear Science Center RAM Radioactive Material RHP Reactor Health Physicist RINSC Rhode Island Nuclear Science Center RS Reactor Supervisor RSO Radiation Safety Officer TLD Thermoluminescent Dosimeter TSs Technical Specifications-2-