ML23080A016
ML23080A016 | |
Person / Time | |
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Site: | Armed Forces Radiobiology Research Institute |
Issue date: | 03/10/2023 |
From: | Naeem M US Dept of Defense, Armed Forces Radiobiology Research Institute, Uniformed Services Univ. of the Health Sciences |
To: | Cindy Montgomery Office of Nuclear Reactor Regulation, Document Control Desk |
References | |
Download: ML23080A016 (14) | |
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UNIFORMED SERVICES UNIVERSITY OF THE HEALTH SCIENCES ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE 4301 JONES BRIDGE ROAD, BUILDING 42 BETHESDA, MARYLAND 20889-5648 www.usuhs.edu/afrri March 10, 2023 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Document Control Desk
Dear Ms. Cindy Montgomery,
Enclosed is the 2022 Annual Operating Report required by the Technical Specifications for the Armed Forces Radiobiology Research Institute (AFRRI) Facility Operating License No.
R-84, Docket 50-170.
Should you need any further technical information, please contact Mr. Andrew Smolinski at (301) 295-1288.
Digitally signed by NAEEM.MOHAM NAEEM.MOHAMMAD.124584638 MAD.1245846386 6 Date: 2023.03.20 11:51:22 -04'00' Mohammad Naeem, MD, FCCP, FACR Colonel, Medical Corps, US Army Director AFRRI
Enclosures:
As Stated Learning to Care for Those in Harms Way
Armed Forces Radiobiology Research Institute AFRRI TRIGA Reactor Facility 1 January 2022 - 31 December 2022 To satisfy the requirements of U.S. Nuclear Regulatory Commission License No. R-84 (Docket No. 50-170),
Technical Specification 6.6.a.
Prepared by Timothy Ayers and Andrew Smolinski Reactor Staff Submitted by Mohammad Naeem, MD, FCCP, FACR Colonel, Medical Corps, US Army Director, AFRRI Armed Forces Radiobiology Research Institute 4301 Jones Bridge Road, Building 42 Bethesda, MD 20889-5648
2022 ANNUAL REPORT TABLE OF CONTENTS Introduction General Information Section I Changes in the Facility Design, Performance Characteristics, Administrative Procedures, Operational Procedures, Results of Surveillance Tests and InspectionsSection II Energy Generated by the Reactor Core and the Number of Pulses $2.00 or Larger Section III Unscheduled ShutdownsSection IV Safety-Related Corrective Maintenance Section V Facility and Procedure Changes as Described in the Final Safety Analysis Report (FSAR),
Changes Made Pursuant to 10 CFR 50.59 and not Submitted for Commission Approval, and New Experiments or Tests Performed During the Year Section VI Summary of Radioactive Effluent Released Section VII Environmental Radiological SurveysSection VIII Exposures Greater Than 25% of 10 CFR 20 Limits
2022 ANNUAL REPORT INTRODUCTION The Armed Forces Radiobiology Research Institute (AFRRI) reactor facility was unavailable for normal operations in the first half of 2022, pending licensing of new Reactor Operators and NRC approval of a License Amendment Request involving Technical Specification changes related to installation of a new analog/digital control system. Operating licenses were received on 21 April 2022 for three Senior Reactor Operators and one Reactor Operator, and Amendment No. 26 to Reactor Operating License R-84 was granted on 27 June 2022. In the second half of 2022 all deferred surveillances and maintenance activities were completed, including: fuel and control rod inspection; core reloading; thermal power calibration; and determination of power coefficient.
The 2022 annual reactor audit required by the reactor technical specifications was conducted on 13-14 December 2022 by Luke Gilde and Michael Hottinger from the University of Maryland reactor facility. The audit report indicated no major discrepancies were found in reactor operations, maintenance, or documentation. The audit identified some minor findings and provided suggested changes.
A comprehensive NRC inspection of reactor facility operations was conducted by Mr.
Andrew Waugh and Mr. Juan Arellano from July 25-28, 2022, which included observation of the first and second startups of the reactor. The inspection resulted in no new violations or Inspection Follow-up Items (IFI), and the closure of one outstanding IFI.
There were two RRFSC membership changes during the year. There were two reactor staff arrivals and one staff departure during the year.
The remainder of this report is written in the format designated in the Technical Specifications for the AFRRI TRIGA Reactor Facility. Items not specifically required are presented in the General Information section. The following sections correspond to the required items listed in Section 6.6.a. of the Technical Specifications.
GENERAL INFORMATION Key AFRRI personnel (as of 31 December 2022) are as follows:
- 1. AFRRI Director - Mohammad Naeem, COL, MC, USA Radiation Sciences Department (RSD) Head - Andrew Cook (SRO)
Radiation Safety Officer - Jeffrey Sumlin 2 Reactor Facility Director (RFD) - Andrew Cook [Interim] (effective 24 April 2021)
- 3. Reactor operations personnel:
Reactor Operations Supervisor - Andrew Smolinski Training Coordinators - Harry H. Spence and Mathieu Brener (SRO)
Maintenance Specialist - MSG Benjamin Knibbe, USA Records Administration Specialist - Harry H. Spence
- 4. Other Reactor Operators:
Timothy Ayers (SRO)
Addison Guynn (RO)
- 5. Operator candidates:
Benjamin Knibbe, Justin Payer, Andrew Smolinski, CPT Balazs Bene, USA
- 6. Newly licensed operators:
Timothy Ayers (SRO), 21 April 2022 Mathieu Brener (SRO), 21 April 2022 Andrew Cook (SRO), 21 April 2022 Addison Guynn (RO), 21 April 2022
- 7. Additions to staff during 2022:
Andrew Smolinski, Chief, Sources Division MAJ Andrew Ng, USA
- 8. Departures during 2022:
- 9. There were two changes to the Reactor and Radiation Facilities Safety Committee (RRFSC) during 2022: Andrew Smolinski (AFRRI RSD) and Jere Jenkins (Texas A&M University) joined the RRFSC as voting members.
In accordance with the requirements set forth in Section 6.2.1.1 of the Technical Specifications for the AFRRI TRIGA Reactor Facility, the RRFSC consisted of the following members as of 31 December 2022.
Regular members are:
Radiation Safety Officer - Jeffrey Sumlin Additional Appointee - Andrew Smolinski Reactor Operations Specialist - Leo Bobek Health Physics Specialist - Joe Pawlovich Reactor Facility Director (Interim) - Andrew Cook Reactor Operations Specialist - Jere Jenkins RRFSC Chair and Director's Representative - LTC Jeffrey Brown, USA Recorder - Harry H. Spence Two meetings were held in 2022:
1 June 6 December
SECTION I Changes in the Facility Design, Performance Characteristics, Administrative Procedures, Operational Procedures, Results of Surveillance Tests and Inspections A summary of changes to the facility design, performance characteristics, administrative procedures, and operational procedures as well as the results of surveillance testing are provided in this section.
A. DESIGN CHANGES The NRC granted license amendment request (LAR) No. 26 for the AFRRI Triga Mark-F Operating License R-84 on 27 June 2022. The LAR included changes to the Technical Specifications related to installation of the new analog/digital control system.
Three facility modifications were performed that required 50.59 evaluations:
- 1. FM-001: Replacement of Soltec paper chart recorder for ventilation flow rates with Graphtec or Yokagawa digital recorders.
- 2. FM-002: Replacement of NP and NPP fission chambers with Uncompensated Ion Chambers
- 3. FSM-001: Reactor control system software modification to incorporate bug fixes identified during SAT-1 testing, improve human factors, and resolve software problems that caused two unscheduled reactor scrams.
B. PERFORMANCE CHARACTERISTICS Subsequent to the LAR approval, the core was reloaded to the same configuration used before being unloaded for securing during the LAR approval process. A full core fuel and control rod inspection was completed with no new degraded fuel or control rods identified. Thermal power calibration and power coefficient of reactivity surveillances performed in August 2022 confirmed that core performance was in agreement with previous operational data.
C. ADMINISTRATIVE PROCEDURES There were two new Administrative Procedures implemented in 2022:
- 1. 552 Facility Software Modifications
- 2. 553 Writing and Modifying Procedures It should be noted that in 2022 the reactor procedures were restructured and renumbered. A comprehensive review of all procedures identified those requiring updates prior to reactor restart, and new procedures such as 552 and 553 needed for completeness and uniformity. The changes do not adversely affect reactor operations or safety. The revised procedures were approved by the RFD and reviewed by the RRFSC.
D. OPERATIONAL PROCEDURES There were several updates to the Operational Procedures during 2022 including re-numbering and reformatting:
- 001 Reactor Startup Checklist
- 200 Fuel Movement and Inspection
- 002 Reactor Operations
- 201 Control Rods
- 003 Reactor Shutdown Checklist
- 202 Control Rod Calibration and Shutdown Margin
- 004 Scrams, Alarms and Abnormal Conditions
- 206 Square Wave Reference Curve Development
- 005 Logbook
- 215 Thermal Power Calibration and Power Coefficient
- 007 Reactor Room Safety
- 216 Low Source Interlock Test;
- 008 Movement of Core and Lead Doors
- 221 Primary Water RTD Test and Calibration
- 010 Conduct of Experiments
- 222 Pool Water Conductivity Test and calibration
- 011 Reactor Exposure Room Entry
- 223 Primary Water Level test and Calibration
- 100 MCSA Activities
- 253 Ventilation Flow Fault Damper Test
- 101 Weekly Checklist
- 260 Facility Interlock System Test
- 102 Monthly Checklist
- 103 Quarterly Checklist
- 292 Watchdog Scram Test
- 104 Semi-Annual Checklist
- 293 Auto Mode Characterization
- 105 Annual checklist The changes do not adversely affect reactor operations or safety. The revised procedures were approved by the RFD and reviewed by the RRFSC.
E. RESULTS OF SURVEILLANCE TESTS AND INSPECTIONS All maintenance and surveillance tasks during 2022 were accomplished as normally scheduled during the year, including those tasks involving the reactor fuel, instrumentation, control rod drives, and other related components that had been deferred during the instrumentation upgrade.
There was one reactor malfunction, and 28 corrective maintenance items identified during 2022. Refer to Section IV below.
The 2022 annual reactor audit required by the reactor technical specifications was conducted on 13-14 December 2022 by Luke Gilde and Michael Hottinger from the University of Maryland reactor facility. The audit report indicated no major discrepancies were found in reactor operations, maintenance, or documentation. There were six minor findings identified in the audit:
- 1. Signature or Initial lines should be filled out on all procedures and not left blank.
- 2. Fuel Inspection requirements should be included in the schedule of surveillance procedures.
- 3. When skipping steps in procedures, the relevant step should be crossed out and the change initialed along with a brief explanation to make it clear that it was not skipped accidentally.
- 4. Include a memo summarizing the changes made, methods, and results of the acceptance
testing in the documentation for future software modifications.
- 5. Document the testing performed to investigate scrams and unscheduled shutdowns.
- 6. Improve radiological control procedures for working in and around the Exposure Rooms.
Procedural changes to address all findings have been implemented.
A routine NRC inspection of reactor facility operations was conducted by Mr. Andrew Waugh and Mr. Juan Arellano from 25-28 July 2022. The inspection resulted in no new violations or Inspection Follow-up Items (IFI), and the closure of one outstanding IFI. The results of the inspection are documented in ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORTNO. 05000170/2022201, dated August 24, 2022.
SECTION II Energy Generated by the Reactor Core and the Number of Pulses $2.00 or Larger Month Kilowatt-Hours Jan 0.0 Feb 0.0 Mar 0.0 Apr 0.0 May 0.0 Jun 0.0 Jul 0.0 Aug 2,140.8 Sep 0.0 Oct 0.0 Nov 5,075.6 Dec 5,811.7 TOTAL 13,028.1 Total energy generated in 2022: 13028.1 kWh Total energy on fuel elements: 1,171,874.8 kWh Total energy on FFCRs*: 439,077.1 kWh Total pulses this year > $2.00: 0 Total pulses on fuel elements > $2.00: 4,219 Total pulses on FFCRs* > $2.00: 107 Total pulses this year: 0 Total pulses on fuel elements: 12,201 Total pulses on FFCRs*: 2,436
- Fuel-followed control rods
SECTION III Unscheduled Shutdowns There were 7 unscheduled shutdowns during 2022:
- 2. 24 Aug - Scram initiated by switching from auto to manual rod control (see Section IV)
- 4. 29 Aug - Scram initiated by switching from manual to auto rod control (see Section IV)
- 5. 5 Dec - Safety channel high power scram while moving core
- 6. 22 Dec - Reactor manually shut down due to control rod limit switch malfunction
- 7. 27 Dec - Facility Interlock System scram due to closing lead doors while operating None of the unscheduled shutdowns were reportable events, and no operating limits were exceeded. The AC power loss scrams were caused by a periodic self-test of the console UPS.
The scrams initiated by changing control rod modes were caused by a software deficiency that is described in the next section. The safety channel high scram was due to an artificially high (conservative) detector reading due to its placement in the reactor tank and core position, and did not result in an actual overpower condition. Power was approximately 80% (800kW) at the time of the scram.
SECTION IV Safety-Related Corrective Maintenance There was one reactor malfunction in 2022: on two occasions a software deficiency caused the reactor to scram when switching between manual and automatic rod control. The issue was addressed in Corrective Maintenance item CM 22-004 and corrected as part of a software update in October 2022.
There were 28 corrective maintenance items identified in 2022, 6 of which were safety-related.
- 1. CM 22-004: Spurious scrams occurred when switching between manual and auto rod control modes. The cause was traced to an unnecessary command in the ControlKeys.bas file. The file was edited to remove the command.
- 2. CM 22-011: Spurious de-energizing of the NPP scram relay during zero-power pulse testing, resulting in pulse data not being captured. Pulsing is procedurally restricted until a solution is found.
- 3. CM 22-015: During startup k-excess measurement was inconsistent with previous values.
Rod position indication for the Safety Rod was found to be off by 100 units. A set screw on the potentiometer drive gear was replaced, and a linearity check of rod position vs.
indication was completed satisfactorily.
- 4. CM 22-017: NPP indication 73% (high) while at 3 kW in core position 250. Installed a spacer and repositioned the NPP detector, and performed new thermal power calibration
and power coefficient determination in core positions 250 and 500.
- 5. CM 22-019: Transient Rod failed to move during performance of startup checks. The motor was disassembled and a set screw was found to be backed out. The set screw was tightened, the motor reassembled and tested satisfactorily.
- 6. CM 22-023: While performing scram tests during startup checks, the Pool Low scram would not clear. An acrid odor was detected in the reactor room, and investigation found a burned out spot on the scram logic board where a chip had overheated. The scram logic board was replaced with an identical board, and the system was tested by performing the Scram Tests from General Atomics Site Acceptance Tests (SAT-1).
SECTION V Facility and Procedure Changes as Described in the Final Safety Analysis Report (FSAR), Changes Made Pursuant to 10 CFR 50.59 and not Submitted for Commission Approval, and New Experiments or Tests Performed During the Year A. FACILITY CHANGES AS DESCRIBED IN THE FSAR There were three facility modifications were performed that required 50.59 evaluations:
- 1. FM-001: Replacement of Soltec paper chart recorder for ventilation flow rates with Graphtec or Yokagawa digital recorders.
- 2. FM-002: Replacement of NP and NPP fission chambers with Uncompensated Ion Chambers
- 3. FSM-001: Reactor control system software modification to incorporate bug fixes identified during SAT-1 testing, improve human factors, and resolve software problems that caused two unscheduled reactor scrams.
B. PROCEDURE
CHANGES AS DESCRIBED IN THE FSAR The reactor administrative and operating procedures were restructured and renumbered in 2022. A new procedure change form and formalized 10CFR50.59 screening process were introduced, aligned with recently NRC-endorsed NEI 21-06 Rev1 guidance, to ensure all procedure changes were properly reviewed, validated and approved by appropriate personnel, and that all procedure changes were screened for the necessity to perform a 10CFR50.59 safety evaluation. Procedure updates that were needed to complete deferred surveillances and maintenance, and all others needed for reactor restart were prioritized. A list of procedures put in force in 2022 under the new structure and screening process are listed in Sections 1.C and 1.D.
C. NEW EXPERIMENTS OR TESTS No new experiments or tests were performed during the reporting period that were not encompassed by the FSAR.
SECTION VI Summary of Radioactive Effluent Released A. Liquid Waste: The reactor produced no liquid waste during 2022.
B. Gaseous Waste: There were no particulate discharges in 2022.
The total activity of Argon-41 discharged in 2022 was 2.71 curies. The estimated effluent concentration from the release of Argon-41 represents 1.24% of the constraint limit for unrestricted areas (10 CFR 20.1101(d) and Table 2, Appendix B, 10 CFR 20).
Quarterly: Jan - Mar 2022 0.00 Ci Apr - Jun 2022 0.00 Ci Jul - Sep 2022 1.19 Ci Oct - Dec 2022 1.52 Ci C. Solid Waste: All solid radioactive waste material is transferred to the AFRRI byproduct license; none was disposed of under the R-84 reactor license.
SECTION VII Environmental Radiological Surveys All environmental sampling of soil and vegetation yielded radionuclide levels within the background range. The radionuclides that were detected were those expected from natural background and from long-term fallout from nuclear weapons testing.
The calculated annual dose, due to Argon-41 release to the environment for 2022, was 0.124 millirem (mrem) at the location of maximum public exposure. The maximum exposure is calculated at a location 91 meters from the release point as described in the FSAR. Exposure to the general population at the boundary of the Naval Support Activity Bethesda is significantly less due to the diffusion of Argon-41 in the atmosphere. The constraint limit for exposure to the public established under 10 CFR 20.1101(d) is 10 mrem per year. The exposure dose was calculated using COMPLY code, level 2, which is the most conservative level of COMPLY.
Emissions due to reactor operations were 0.124 mrem, or 1.24% of the 10 mrem constraint limit, for the entire year.
The reactor in-plant surveys, specified in Health Physics Procedure (HPP) 3-2, all resulted in readings that were less than the action levels specified in HPP 0-2.
SECTION VIII Exposures Greater than 25% of 10 CFR 20 Limits There were no doses to reactor staff personnel or reactor visitors greater than 25% of 10 CFR 20 occupational and public radiation dose limits.