IR 05000225/2017201

Reactor Facility Routine Safety Inspection Report 05000225/2017201

ML17290A039
Person / Time
Site:	Rensselaer Polytechnic Institute
Issue date:	12/05/2017
From:	Anthony Mendiola Research and Test Reactors Oversight Projects Branch
To:	Caracappa P Rensselaer Polytechnic Institute
Takacs M, NRR/DLP, 415-7871
References
IR 2017201
Download: ML17290A039 (12)

Text

ber 5, 2017

SUBJECT:

RENSSELAER POLYTECHNIC INSTITUTE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-225/2017-201

Dear Dr. Caracappa:

From September 26-28, 2017, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Rensselaer Polytechnic Institute. The inspection included a review of activities authorized for your facility. The enclosed report documents the inspection result which were discussed on September 28, 2017, with you and members of your staff.

The inspection examined activities conducted under your license as they relate to public health and safety to confirm compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of this inspection, no findings of non-compliance 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 Mr. Michael Takacs at (301) 415-2042 or electronic mail at Michael.Takacs@nrc.gov.

Sincerely,

/RA/

Anthony Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-225 License No. CX-22 Enclosure:

As stated cc: See next page SUBJECT: RENSSELAER POLYTECHNIC INSTITUTE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-225/2017-201 DATED: DECEMBER 5,2017 DISTRIBUTION:

PUBLIC PROB R/F PRLB R/F MTakacs, NRR XYin, NRR MCompton, NRR LTran, NRR RidsNrrDpr Resource NParker, NRR ADAMS ACCESSION NO.: ML17290A039 NRC-002 OFFICE NRR/DLP/PROB/ NRR/DLP/PROB/LA NRR/DLP/PROB/BC NAME MTakacs NParker AMendiola DATE 11/7/17 11/2/17 12/5/17

Rensselaer Polytechnic Institute Docket No. 50-225 cc:

Mayor of the City of Schenectady State Liaison Officer Designee Schenectady City Hall Senior Project Manager 105 Jay St. Radioactive Waste Policy and Nuclear Schenectady, NY 12305 Coordination New York State Energy Research &

Dr. Shekhar Garde Development Authority Dean, School of Engineering 17 Columbia Circle Rensselaer Polytechnic Institute Albany, NY 12203-6399 110 8th Street Troy, NY 12180-3590 Test, Research, and Training Reactor Newsletter Reactor Operations Supervisor P.O. Box 118300 Rensselaer Polytechnic Institute University of Florida JEC Room 2049 Gainesville, FL 32611 Department of Mechanical Aerospace and Nuclear Engineering 110 8th Street Troy, NY 12180-3590 Chief, Radiation Section Division of Environmental Remediation NY State Dept. of Environmental Conservation 625 Broadway Albany, NY 12233-7255 Radiation Safety Officer Rensselaer Polytechnic Institute 21 Union Street Gurley Building 2nd Floor Troy, NY 12180 RCF Supervisor Rensselaer Polytechnic Institute NES Building, Room 1-10, MANE Department 110 8th St.

Troy, NY 12180 Annette Chism, Director EH&S Rensselaer Polytechnic Institute 21 Union Street Gurley Building 2nd Floor Troy, NY 12180

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-225 License No: CX-22 Report No: 50-225/2017-201 Licensee: Rensselaer Polytechnic Institute Facility: Reactor Critical Facility Location: Schenectady, NY Dates: September 26-28, 2017 Inspector: Michael Takacs Approved by: Anthony Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY Rensselaer Polytechnic Institute Reactor Critical Facility NRC Inspection Report No. 50-225/2017-201 The primary focus of this announced safety inspection was the onsite review of selected aspects of the Rensselaer Polytechnic Institutes (RPIs or the licensees) 100 Watt Class II research reactor safety program including: (1) procedures, (2) experiments, (3) radiation protection and environmental monitoring, (4) design changes, (5) committee audits and reviews, (6) transportation of radioactive material since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety and generally in compliance with the NRC requirements.

One inspector follow-up item was opened.

Procedures

• Procedural control and implementation satisfied technical specification (TS) requirements.

Experiments

• Existing experiments are being conducted as previously approved.

Radiation Protection and Environmental Monitoring

• Postings and control to radiation areas were acceptable.

• The radiation protection program, including dosimetry and surveillances, was generally being implemented appropriately

• Effluent monitoring satisfied license and regulatory requirements and no releases were performed.

Design Changes

• Records indicated that the licensees design change program was being implemented as required.

Committee Audits and Reviews

• Audits and reviews were generally being conducted by designated individuals and reviewed by the Nuclear Safety Review Board in accordance with the requirements specified in TS Section 6.2, Review and Audit.

Transportation of Radioactive Material

• No radioactive material was transferred to or from the reactor since the last inspection.

REPORT DETAILS Summary of Facility Status The Rensselaer Polytechnic Institutes (RPIs) Reactor Critical Facility (RCF) Class II research reactor, licensed to operate at a maximum steady-state thermal power of 100 Watts, continued to be operated in support of academic instruction, operator training, surveillance, and research.

During the inspection, the reactor was operated for operator training purposes.

1. Procedures a. Inspection Scope (Inspection Procedure (IP) 69001)

The inspector reviewed the following to ensure that the requirements of technical specification (TS) Section 6.4, Procedures, were being met concerning written procedures:

• RCF Pre-Startup Checklist, v. 8.3; dated April 2015

• RCF Secure Procedures and Checklist, v. 3.2; dated April 2015

• RCF Surveillance Procedures, v. 4.0; dated September 2014

• RCF Operating Procedures, v. 3.0; dated July 2013

• RCF Emergency Procedures, dated June 2016 b. Observations and Findings The inspector determined that written procedures were available for the activities delineated in TS Section 6.4. The licensee updated the emergency plan and emergency procedures. They were approved by the Nuclear Safety Review Board (NSRB) before they were implemented. The inspector reviewed the updated procedures and found them to be acceptable.

The inspector observed the operators performing the pre-startup checks for reactor startup which was followed up by the reactor startup. During reactor operation, the inspector also observed the surveillance procedure for positive reactor period measurements. RCF staff members conducted TS activities in accordance with applicable procedures.

c. Conclusion Procedural control and implementation satisfied TS requirements.

2. Experiments a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Section 3.8, Experiments, and TS Section 6.5, Experiment Review and Approval:

• Experimental administrative controls and precautions Enclosure

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• RCF logbook entries

• A Manual of Experiments, MANE-4440, dated 2017

• Operations Report for the RPI RCF for 2016, dated April 28, 2017 b. Observations and Findings The majority of the use of the RCF consisted of classroom training and performance of previously-approved experiments and one new experiment. The inspector reviewed the safety analysis and procedures associated with the one new experiment since the last inspection: RPI RCF Heated Fluid Loop Experiments, dated May 2017. The inspector found that although the new experiment had been approved by the NSRB, the requirement under TS Section 6.5 to document the Title 10 of the Code of Federal Regulations (10 CFR) 50.59(c)(2) analysis information had not been incorporated into the safety analysis document. The inspector discussed this matter with the RCF Director. The RCF Director was later able to provide the associated 10 CFR 50.59(c)(2) analysis information for the new experiment and agreed to incorporate this information into the above mentioned safety analysis document, as well as include this type of information into all future safety analysis reports.

The inspector opened IFI 50-225/2017-201-01 to follow-up on the 10 CFR 50.59(c)(2) analysis requirements. This would be reviewed during a subsequent inspection.

Through review of the experiment procedures, the reactor logbook, and interviews with staff, the inspector determined that for new experiments, the review process and approval would be conducted as required by the TS and in accordance with the regulations.

c. Conclusion Existing experiments are being conducted as previously approved.

IFI 50-225/2017-201-01 would be reviewed during a subsequent inspection regarding the 10 CFR 50.59(c)(2) analysis requirements.

3. Radiation Protection and Environmental Monitoring a. Inspection Scope (IP 69001)

To verify compliance with 10 CFR Parts 19 and 20 and TS Section 3.7, Radiation Monitoring, TS Section 4.7, Radiation Monitoring, and TS Section 6.3, Radiation Safety, the inspector reviewed selected aspects of:

• Dosimetry records 1st quarter of 2016 to present

• Various calibration certificates for the portable survey instruments for the past year

• Completed NSRB quarterly radiation safety audits

• Radiation and Nuclear Safety Committee (RNSC) radiation safety annual reports

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• Radiation training records

• Operations Report for the RPI RCF for 2016, dated April 28, 2017 b. Observations and Findings (1) Facility Tour, Postings and Notices The inspector toured the RCF. Control of radioactive material and control of access to radiation areas were acceptable. The postings at the entrances to various controlled areas including the reactor bay and radioactive material storage areas were acceptable and indicated the radiation and contamination hazards present. No unmarked radioactive material was found in the facility. A copy of the current U.S. Nuclear Regulatory Commission (NRC) Form 3, Notice to Employees, required by 10 CFR Part 19, was posted.

(2) Radiation Protection Program, Dosimetry, and Surveillances The inspector verified that the radiation protection program was reviewed annually as required. This review was performed by the RPI RNSC. Annual radiation worker training was conducted online or classroom led by the radiation safety officer (RSO), as required.

The inspector observed that dosimetry was used acceptably by facility personnel.

The licensee used a National Voluntary Laboratory Accreditation Program-accredited vendor to process personnel dosimetry. An examination of the records for the inspection period showed that all exposures were within NRC limits and within licensee action levels.

The inspector reviewed the surveillances for the radiation monitoring equipment for the inspection period which include checks and calibration. Survey meters are sent to an outside company called Radiation Safety & Control Systems, for calibration, with some being currently out. The inspector determined that the licensee is adhering to TS Section 4.7.

(3) Environmental Monitoring The inspector reviewed environmental monitor dosimetry records for the inspection period. Several thermoluminescent dosimeters were placed in locations around the perimeter of the RCF. Records for 2016 to the present indicate that doses were well below the applicable regulatory requirements and were typically measured at background levels. The inspector observed the RSO performing the required quarterly radiation surveys and the inventory and leak testing of all sealed sources.

The licensee used the Environmental Protection Agency computational code COMPLY, to calculate gaseous emissions from the reactor. Records show that the licensee was in compliance with applicable regulatory requirements. No discharge has occurred since the last inspection.

-4-c. Conclusion Based on the observations made and the records reviewed, it was determined that the licensee generally satisfied regulatory requirements regarding radiation safety. Specifically, (1) postings and control to radiation areas were acceptable, (2) the radiation protection program, including dosimetry and surveillances, was generally being implemented appropriately, and (3) effluent monitoring satisfied license and regulatory requirements and no releases were performed.

4. Design Changes a. Inspection Scope (IP 69001)

To ensure that facility changes were reviewed and approved as required by TS Section 6.2, Review and Audit, and 10 CFR 50.59, the inspector reviewed selected aspects of:

• Operations Report for the RPI RCF for 2016, dated April 28, 2017 b. Observations and Findings Through review of applicable records and interviews with licensee personnel, the inspector verified that since the last inspection, the 327-pin core with zirconium (Zr) reflectors was altered to return to a previous 332-pin core without Zr reflectors. The inspector verified that administrative controls were in place that required the appropriate review and approval of all changes prior to implementation and previous changes had been performed in accordance with regulatory requirements.

c. Conclusion Records indicated that the licensees design change program was being implemented as required.

5. Committees, Audits, and Reviews a. Inspection Scope (IP 69001)

The inspector reviewed the following to ensure that the audits and reviews stipulated in TS Section 6.2 were being completed:

• RPI NSRB meeting minutes for December 8, 2016, and May 8, 2017

• NSRB Audit Forms 1-4 for 2017

• Operations Report for the RPI RCF for 2016, dated April 28, 2017 b. Observations and Findings The inspector verified that the NSRB conducted meetings at least semiannually, as required by TS Section 6.2. The inspector reviewed the NSRB meeting minutes since the last inspection and discussed certain topics of interest with the

-5-licensee and determined that the NSRB provided appropriate guidance and direction for reactor operations and ensured acceptable use and oversight of the reactor.

Since the last inspection, the required audits of reactor operations and records, procedures, equipment, and emergency preparedness had been completed and documented as required. The audits were completed by a designated individual and reviewed by the NSRB.

c. Conclusion Audits and reviews were generally being conducted by designated individuals and reviewed by the NSRB in accordance with the requirements specified in TS Section 6.2.

6. Transportation of Radioactive Material a. Inspection Scope (IP 86740)

The inspector reviewed selected aspects of:

• Radioactive material shipping procedures

• Interviews with RCF staff b. Observations and Findings No radioactive material was transferred from or to the reactor since the last inspection. If needed, material would be passed to the university license and then packaged and shipped by Environmental Health and Safety personnel under the state license.

c. Conclusion No radioactive material was transferred from or to the reactor since the last inspection.

7. Exit Interview The inspection scope and results were discussed on September 28, 2017, with licensee representatives. The inspector discussed the findings for each area reviewed. The licensee acknowledged the inspection findings and did not identify any material as proprietary.

-6-PARTIAL LIST OF PERSONS CONTACTED Licensee Reactor Critical Facility Director G. Winters Reactor Critical Facility Operations Supervisor W. Ji NSRB Chair A. Chism Environmental Health and Safety Director M. Arha Radiation Safety Officer INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors IP 86740 Inspection of Transportation Activities (N/A for this inspection)

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-225/2017-201-01 IFI Follow-up on licensees action to incorporate the analysis requirements under 10 CFR 50.59(c)(2) into the safety analysis document for all new experiments.

Closed None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations IP Inspection Procedure NSRB Nuclear Safety Review Board NRC Nuclear Regulatory Commission RCF Reactor Critical Facility RPI Rensselaer Polytechnic Institute RSO Radiation Safety Officer TS Technical Specification