IR 05000284/2010202

IR 05000284-10-202 on 08/02/10 - 08/05/10 for Idaho State University

ML102290226
Person / Time
Site:	Idaho State University
Issue date:	08/31/2010
From:	Johnny Eads Research and Test Reactors Branch B
To:	Kunze J Idaho State University
Schoenebeck G, NRR/DPR, 415-6345
References
IR-10-202
Download: ML102290226 (22)

Text

ust 31, 2010

SUBJECT:

NRC INSPECTION REPORT NO. 50-284/2010-202

Dear Dr. Kunze:

On August 2-5, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Idaho State University AGN-201M Research Reactor Facility. The enclosed report documents the inspection results, which were discussed on August 4, 2010, with you, members of your staff, and members of the Reactor Safety Committee.

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 activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 Exemptions, inspections, requests for withholding of the NRCs, Rules of Practice, 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 Publicly Available Records component of NRCs 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 Greg Schoenebeck at 301-415-6345 or by electronic mail at Greg.Schoenebeck@nrc.gov.

Sincerely,

/RA/

Johnny H. Eads, Jr., Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-284 License No. R-110 Enclosure: NRC Inspection Report No. 50-284/2010-202 cc w/encl: See next page

ML102290226 *concurrence by e-mail NRC-002 OFFICE PROB:RI* PRPB:LA PROB:BC NAME GSchoenebeck GLappert JEads (CHawes for)

DATE 8/13/2010 8/23/2010 8/31/2010

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-284 License No: R-110 Report No: 50-284/2010-202 Licensee: Idaho State University Facility: AGN-201M Reactor Facility Location: Pocatello, Idaho Dates: August 2-5, 2010 Inspectors: Gregory M. Schoenebeck Craig Bassett Approved by: Johnny H. Eads, Jr., Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

Idaho State University Docket No. 50-284 cc:

Idaho State University ATTN: Adam Mallicoat Reactor Supervisor Campus Box 8060 Pocatello, ID 83209-8060 Idaho State University ATTN: Dr. George Imel, Dean College of Science and Engineering Campus Box 8060 Pocatello, ID 83209-8060 Idaho State University ATTN: Dr. Richard R. Brey Radiation Safety Officer Physics Department Box 8106 Pocatello, ID 83209-8106 Toni Hardesty, Director Idaho Dept. of Environmental Quality 1410 North Hilton Boise, ID 83606 Test, Research and Training Reactor Newsletter 202 Nuclear Sciences Center University of Florida Gainesville, FL 32611

EXECUTIVE SUMMARY Idaho State University AGN-201M Research Reactor Facility NRC Inspection Report No.: 50-284/2010-202 The primary focus of this routine, announced inspection included onsite review of selected aspects of Idaho State University (the licensees) Class II research reactor safety program including: organizational structure and staffing, review and audit and design control functions, procedures, radiation protection, environmental protection, and transportation of radioactive materials since the last U. S. Nuclear Regulatory Commission (NRC) inspection of these areas.

The licensees programs were acceptably directed toward the protection of public health and safety and in compliance with NRC requirements.

Organizational Structure and Staffing

• The facility organization and staffing remain in compliance with the requirements specified in the Technical Specifications (TS).

Review and Audit and Design Control Functions

• The review and audit program was being conducted acceptably by the Reactor Safety Committee.

• The last changes that had been completed at the facility were reviewed by the Reactor Safety Committee using the criteria specified in Title 10 of the Code of Federal Regulations, Section 50.59, Changes, tests, and experiments, and were determined to be acceptable.

Procedures

• Facility procedural review, revision, control, and implementation satisfied TS requirements.

Radiation Control

• Surveys were being completed and the results documented acceptably.

• Postings met the regulatory requirements.

• Personnel dosimetry was being worn as required and doses were well within NRC regulatory limits.

• Radiation monitoring equipment was being maintained and calibrated as required.

• Acceptable radiation protection training was being provided to staff members.

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• The Radiation Protection and As Low As Reasonably Achievable Programs were being acceptably implemented.

Effluent and Environmental Monitoring

• Effluent monitoring satisfied license and regulatory requirements.

• Releases were within the specified regulatory and TS limits.

Transportation of Radioactive Materials

• No radioactive material had been shipped from the reactor facility under the reactor license during the past several years.

Requalification Training

• The licensee was generally meeting the requalification program requirements to ensure the effectiveness of all licensed operators.

Design Changes

• Based on the records reviewed, the inspector determined that the licensee's design change program was being implemented as required.

Experiments

• Experiments were being reviewed in accordance with procedures and standard practice Follow-up

• The facility was generally resolving the follow-up items from previous inspections

REPORT DETAILS Summary of Plant Status The Idaho State University (ISU, the licensees) Aerojet General Nucleonics-201M (AGN-201M)

Research Reactor Facility, licensed to operate at a maximum steady-state thermal power of 5 Watts, continued to be operated in support of operator training, surveillance, experiments, and laboratory work. During the inspection the reactor was operated for demonstration purposes.

1. Organizational Structure and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001)

The inspector reviewed the following regarding the licensee's organization and staffing to ensure that the requirements of Technical Specifications (TS) Sections 6.1 and 6.2 were being met:

• Organization and staffing for reactor operation

• Administrative controls and management responsibilities

• ISU AGN-201M Reactor Facility Master Log Numbers 4 and 5

• TS for ISU AGN-201M Reactor, Amendment No. 6, approval dated August 14, 2006

• ISU AGN-201M General Rules, Revision (Rev.) 4, dated September 19, 1994

• ISU AGN-201M Operating Procedures No. 1 (OP-1), Rev. 3, dated April 26, 1994

• ISU AGN-201M Operating Procedures No. 2 (OP-2), Rev. 3, dated April 26, 1994

• ANS 15.4-1988, Standards for Selection and Training of Personnel for Research Reactors b. Observations and Findings Through discussions with licensee representatives the inspector determined that management responsibilities and the organization at the ISU AGN-201M Research Reactor Facility had not changed since the previous NRC inspection (Inspection Report No. 50-284/2009-201). The inspector determined that the Reactor Administrator retained direct control and overall responsibility for management of the facility as specified in TS Section 6.1. The Reactor Administrator reported to the designated University Officer at ISU who was the University Vice President.

The licensees current operational organization consisted of the Reactor Administrator, the Reactor Supervisor, an Engineer, and three Reactor Operators (ROs). The Reactor Supervisor and the ROs were licensed to operate the reactor. The inspector confirmed that the Reactor Administrator and Supervisor met the qualifications specified in TS Section 6.2. It was noted

-2-that the ROs and others were employed on a part-time basis. This organization was consistent with that specified in Figure 1 of TS Section 6.1.

c. Conclusion The licensees staffing and organization met the requirements specified in TS Sections 6.1 and 6.2.

2. Review and Audit and Design Control Functions a. Inspection Scope (IP 69001)

To verify that the licensee had established and conducted reviews and audits as required in TS Section 6.4 and to verify that modifications to the facility were being reviewed in accordance with the stipulations in Code of Federal Regulations (10 CFR) Section 50.59 and reviewed and approved as required by TS Section 6.5, the inspector reviewed:

• ISU Reactor Safety Committee Charter

• ISU AGN-201M Reactor Facility Master Log

• Completed audits and reviews since June 2008

• Reactor Safety Committee meeting minutes since July 2008

• TS for ISU AGN-201M Reactor, Amendment No. 6, approval dated August 14, 2006 b. Observations and Findings (1) Review and Audit Functions The inspector reviewed the Reactor Safety Committee (RSC) meeting minutes from July 2008 to the present. These meeting minutes showed that, as required by TS Section 6.4.1, the committee met at least once per calendar year and that a quorum was present. The topics considered during the meetings were appropriate and as stipulated in TS Section 6.1.8.

Through review of the RSC minutes the inspector confirmed that the RSC reviewed proposed changes in the license, audit reports, and any reported violations as required by TS Section 6.4.2. The inspector also noted that, since the last NRC inspection, members of the safety committee had completed audits of various aspects of the reactor facility operations, programs, and procedures as required by TS Section 6.4.3.

The audits were structured so that the various aspects of the licensee's operations and safety programs and plans were reviewed annually. The inspector noted that the audit findings were acceptable and that the licensee responded and took corrective actions as needed. It was also noted that two audits that were scheduled to be conducted by the end of

-3-July 2010 had not been completed. The licensee indicated that these audits would be completed within two weeks.

(2) Design Change Function Various changes were being considered for implementation at the facility; the most ambitious was one involving the installation of a new reactor console. The 50.59 Review Package for that project had been finalized and the licensee determined that the changes did not meet any of the criteria specified in 10 CFR 50.59 (c) (2) Paragraphs (i) - (viii). The changes were then reviewed by the RSC and found to be acceptable and an amendment had been submitted to the NRC as a result. The decision from the NRC was still pending.

Records and observations showed that the other changes that had been proposed at the facility were acceptably reviewed in accordance with applicable administrative controls. The licensee determined that these changes also did not meet any of the criteria specified in 10 CFR 50.59 (c) (2) Paragraphs (i) - (viii). The changes were then reviewed by the RSC and found to be acceptable. None of the changes constituted a safety question or required a change to the TS. The change review and approval process appeared to be acceptable.

c. Conclusion The review and audit program was being conducted acceptably by the RSC. The last changes completed by the licensee were reviewed using the criteria specified in 10 CFR 50.59, reviewed by the RSC, and determined to be acceptable.

3. Procedures a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify that the licensee was complying with the requirements of TS Sections 6.5 and 6.6:

• Selected forms and checklists

• ISU AGN-201M Reactor Facility Master Log

• Selected maintenance and surveillance procedures

• Selected Operations Procedures and Radiation Protection Procedures

• ISU AGN-201M General Rules, Rev. 4, dated September 19, 1994

• TS for ISU AGN-201M Reactor, Amendment No. 6, approval dated August 14, 2006

• AGN-201 OP-1

• Form ROL-101 Rev. 3, April 26, 1994

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• Reactor Power as a function of Channel No. 3 Detector Current, March 28, 1996

• List of Authorized Operators, October 26, 2009

• Rod Calibration Curve, July 23, 1993 b. Observations and Findings The licensees procedures were found to be acceptable for current facility operations and the current staffing level. It was noted that the procedures specified the responsibilities of the various members of the staff. The inspector determined that the various facility procedures were being updated as needed and that substantive revisions to procedures, checklists, and forms were presented to the RSC for review and approval as required by TS. It was also noted that procedures for potential malfunctions and emergencies (e.g.,

radioactive releases, contaminations, and reactor equipment problems) had been developed and were implemented as required.

During the inspection, the inspector observed a reactor startup to 4.5 W. The operator followed the procedures and was very knowledgeable with regards to facility operations. The inspector did noted several observations during the startup:

1) When calculating an estimate of the excess reactivity and the critical rod height, the operator was using rod worth curves which had last been verified by a Reactor Supervisor in 1993. When the inspector followed-up on why newer curves had not been generated based on the data obtained from the Annual Surveillance of Safety and Control Rod reactivity rod worths, in accordance with TS 4.1.a, it was unclear to what extent the surveillance is being performed. Since the inspector was not performing the Surveillance module during this inspection, the inspector has left this item as an Inspector Follow-up Item (IFI) 50-284/2010-201-01.

Additionally, it was noted that there is no guidance for calculating the excess reactivity values and in several cases when the inspector reviewed various Form ROL-101s, it was noted that several arithmetic errors occurred, where changes appeared to have been made to the estimated position when the actual critical position deviated more than what was expected. Additionally, the inspector noted that during calculations, the value for the moderator temperature coefficient for reactivity provided for the operators in the Table of Reactivity Changes for the AGN-201 Reactor Experimental Facilities, updated August 15, 2007, has a value of -0.020 %k/k which deviates from the value of -

0.025%k/k which is found in the facilities Safety Analysis Report.

2) During operation it was noted that there is not a step in the procedure which addresses when the reactor source is withdrawn from the Glory

-5-3) Hole and where it is to be placed and with any precautions. This is an item which was discussed during the Non-Routine Inspection (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML100321367) and which the facility committed to resolving guidance in their procedures. Since the corrective action has not occurred, the inspector has left this as an IFI 50-284/2010-201-02.

4) When the reactor power was increasing in power to 4.5 W, it was noted that the operator was using a table of values, Reactor Power Level as a Function of Channel No. 3 Detector Current which was created in March 28, 1996. When the inspector asked the facility management why they are using an out-of-date table to cross-reference data, it was unclear how the power calibration data from the annual surveillance is incorporated into tables used for operator guidance. Since the inspector was not performing the Surveillance module during this inspection, the inspector has left this item as an IFI 50-284/2010-201-03 c. Conclusion

• Procedural review, revision, control, and implementation satisfied TS requirements.

4. Radiation Protection a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with 10 CFR Parts 19 and 20, and TS Sections 3.4 and 4.4.c:

Radiological signs and posting ISU AGN-201M Reactor Facility Master Log Personnel dosimetry records for 2008 to present ISU Radiation Protection Program and As Low As Reasonably Achievable (ALARA) Policy ISU Radiation Safety Policy Manual, Rev. 8, dated August 17, 2009 Contamination and radiation survey records for reactor from July 2009 to present Records documenting the maintenance and calibration of radiation monitoring equipment from 2008 to present Annual Operating Report for the Idaho State University AGN-201M Reactor, License No. R-110; Docket No. 50-284, for calendar year 2008, dated August 14, 2009 AGN-201 Operations Log, Form ROL-101, Rev. 3, dated April 26, 1994, for the period from January 28, 2009, to the present documenting Pre-Start checks, surveys, and reactor operations TS for ISU AGN-201M Reactor, Amendment No. 6, approval dated August 14, 2006

-6-ISU AGN-201M General Rules, Rev. 4, dated September 19, 1994 ISU AGN-201M OP-1, Rev. 3, dated April 26, 1994 ISU AGN-201M OP-2, Rev. 3, dated April 26, 1994 ISU AGN-201M Visitor Log and Register for Organized Groups and Tours ISU AGN-201M Experimental Plan No. 8, Health Physics Survey, Rev.

1, dated May 3, 1979 ISU Technical Safety Office (TSO) Radiation Procedures Manual (RPM),

Procedure Number TSO-08-01-Rev 1, 100 mrem Report, effective date September 1, 2008, approval dated May 19, 2009 ISU TSO RPM Procedure Number TSO-08-02-Rev 2, Dosimetry, effective date September 1, 2009, approval dated September 1, 2009 ISU TSO RPM Procedure Number TSO-08-08-Rev 1, Radionuclide Laboratory Evaluations, effective date September 1, 2008, approval dated May 19, 2009 ISU TSO RPM Procedure Number TSO-08-12-Rev 1, Calibrations, effective date September 1, 2008, approval dated May 19, 2009 The inspector also toured the licensee's facility and observed the use of dosimetry and radiation monitoring equipment. Licensee personnel were interviewed as well.

b. Observations and Findings (1) Surveys Various periodic and Prestart-Up contamination and radiation surveys were completed by reactor staff and TSO personnel. Through records reviews and interviews with reactor and TSO staff members, the inspector determined that the contamination and radiation surveys were performed as required by TS Section 4.4.c and Radiation Safety procedures. The inspector also verified that results were evaluated and corrective actions taken and documented as required when contamination levels exceeded the established limits. Radiation survey results were used to verify the location of radiation and high radiation areas and ensure 10 CFR 20.1902 postings were accurate.

(2) Postings and Notices During tours of the facility, the inspector observed that caution signs and postings in place and controls established for the controlled areas were acceptable for the hazards involving radiation, high radiation, and contamination and were posted as required by 10 CFR Part 20, Subpart J. Through observations of and interviews with licensee staff, the inspector confirmed that personnel complied with the signs, postings, and controls. The facilitys radioactive material storage areas were noted to be properly posted. No unmarked radioactive material was detected in the facility.

-7-Copies of current notices to workers were posted in various areas in the facility. Radiological signs were typically posted at the entrances to controlled areas. Other postings also characterized the industrial hygiene hazards that were present in the areas as well. During one facility tour, the inspector noted that various copies of NRC Form-3, Notice to Employees, which were posted at the facility as required by 10 CFR Part 19.11, were the current version. With the current version of NRC Form 3 posted, notices, caution signs, postings, and controls for radiation areas were as required in 10 CFR Parts 19 and 20.

(3) Dosimetry The licensee was provided dosimetry by the ISU TSO. The TSO used a National Voluntary Laboratory Accreditation Program accredited vendor, Landauer, to process the whole body optically stimulated thermoluminescent (OSL) dosimeters supplied to facility personnel. It was noted that facility personnel had not been issued extremity dosimeters. Through direct observation, the inspector determined that dosimetry was acceptably used by facility personnel.

An examination of the OSL dosimeter results, indicating exposure to radiation at the facility for the past two years, showed that the highest occupational doses, as well as doses to the public, were within 10 CFR Part 20 limits. The records showed that the highest annual whole body exposure received by a single individual for 2008 was 21 millirem (mr) deep dose equivalent (DDE). The highest skin or other shallow dose received during 2008 was 26 mr shallow dose equivalent (SDE). The highest annual whole body exposure received by a single person for 2009 was 4 mr DDE and the highest skin or other shallow dose was 7 mr SDE.

The records indicated that, through the first quarter of 2010, the highest annual whole body exposure received by a single person was 2 mr DDE and the highest skin or other shallow dose was 4 mr SDE.

(4) Radiation Monitoring Equipment Examination of selected survey meters indicated that the instruments had the acceptable up-to-date calibration sticker attached. The instrument calibration records indicated calibration of portable survey meters was typically completed by TSO personnel. On occasion, survey meters were sent to a contractor for calibration. Calibration frequency met the specified TS requirements and records were maintained as required.

Area radiation monitors were also being calibrated as required.

-8-(5) Radiation Protection Program The licensees Radiation Protection Program was established in the Idaho State University Radiation Safety Policy Manual, Revision 8, with approval by the Radiation Safety Committee dated August 17, 2009. The program included requirements that all personnel who worked with radioactive materials receive training in radiation protection, policies, procedures, requirements, and facilities. Completion of this training was verified by each persons supervisor and by TSO personnel. The program appeared to be acceptable and was being reviewed annually as required by the Radiation Safety Officer.

(6) ALARA Program The ALARA Program was outlined and established in Radiation Safety Policy Manual Section 3.1. The ALARA program provided guidance for keeping doses as low as reasonably achievable and was consistent with the guidance in 10 CFR Part 20.

(7) Radiation Protection Training The inspector reviewed the radiation worker (or rad worker) training given to reactor staff members, to those who were not on staff but who were authorized to use the experimental facilities of the reactor, and to student assistants working at the facility on a part-time basis. The inspector verified that rad worker training was given upon initial employment and refresher training was required annually thereafter. The documents of the training provided to licensee staff members indicated that all current staff members had received the required training. The inspector determined that the personnel training program satisfied requirements in 10 CFR 19.12.

(8) Facility Tours The inspector toured the Reactor Room, adjacent laboratories, and support areas. Control of radioactive material and control of access to radiation areas was acceptable. No problems were noted.

c. Conclusion The inspector determined that the Radiation Protection and ALARA Programs satisfied regulatory requirements because: 1) surveys were being completed and documented acceptably, 2) postings met regulatory requirements, 3)

personnel dosimetry was being worn as required and doses were well within the NRCs regulatory limits, 4) radiation monitoring equipment was being maintained and calibrated as required, and, 5) acceptable radiation protection training was being provided.

-9-5. Effluent and Environmental Monitoring a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with the requirements of 10 CFR Part 20 and TS Sections 3.4, 4.2.3, 5.4, 6.6, and 6.7.2:

Records of selected airborne releases Records documenting the maintenance and calibration of radiation monitoring equipment from 2006 to present Annual Operating Report for the Idaho State University AGN-201M Reactor, License No. R-110; Docket No. 50-284, for calendar year 2008 dated August 14, 2009 AGN-201 Operations Log, Form ROL-101, Rev. 3, dated April 26, 1994, for the period from January 28, 2009, to the present, documenting Pre-Start checks, surveys, and reactor operations ISU TSO RPM, Procedure Number TSO-08-01-Rev 1, 100 mrem Report, effective date September 1, 2008, approval dated May 19, 2009 ISU TSO RPM Procedure Number TSO-08-02-Rev. 2, Dosimetry, effective date September 1, 2009, approval dated September 1, 2009 ISU TSO RPM Procedure Number TSO-08-08-Rev. 1, Radionuclide Laboratory Evaluations, effective date September 1, 2008, approval dated May 19, 2009 ISU TSO RPM Procedure Number TSO-08-12-Rev. 1, Calibrations, effective date September 1, 2008, approval dated May 19, 2009 b. Observation and Findings The inspector reviewed the records documenting airborne releases to the environment for the past two years. The inspector determined that gaseous releases continued to be calculated as required by procedure and were adequately documented. The releases were determined to be within the annual dose constraints of 10 CFR 20.1101(d), 10 CFR Part 20, Appendix B concentrations, and TS limits. The inspector confirmed that there had been no liquid or solid waste radioactive releases from the reactor facility during the past two years. Through observation of the facility, the inspector found no new potential release paths.

On-site gamma radiation monitoring was completed using various TLDs placed around the facility in accordance with the applicable procedures. The data indicated that there were no measurable doses to the public above any regulatory limits.

c. Conclusion Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

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6. Transportation a. Inspection Scope (IP 86740)

The inspector reviewed the following to verify compliance with regulatory and procedural requirements for shipping or transferring licensed material:

Annual Operating Report for the Idaho State University AGN-201M Reactor, License No. R-110; Docket No. 50-284, for calendar year 2008, dated August 14, 2009 AGN-201 Operations Log, Form ROL-101, Rev. 3, dated April 26, 1994, for the period from January 28, 2009, to the present documenting Pre-Start checks, surveys, and reactor operations ISU TSO RPR 13, Radioisotope Acquisition and Disposition ISU TSO RPR 14, Radioisotope Limited Quantity Checklist ISU TSO RPM Procedure Number TSO-00-55-Rev. 0, Transportation of Radioactive Material, effective date March 2, 2010, approval dated March 2, 2010 b. Observations and Findings Through records review and discussions with licensee personnel, the inspector determined that the licensee had not shipped any radioactive material from the facility under the reactor license. It was noted that radioactive material produced in the reactor was either transferred to the campus broadscope license (ISU Type A Broadscope Radioactive Materials License 11-27380-01) and shipped under the auspices of that license, or transferred to other authorized users on campus, or maintained at the reactor facility for use in laboratories in accordance with procedure c. Conclusion No radioactive material had been shipped from the reactor facility under the reactor license during the past several years.

7. Requalification Training a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with the requirements of 10 CFR 55.59

• Idaho State University Nuclear Engineering Laboratory Requalification Program Progress Checklist, various operators

• Reactor Console Logs, December 7, 2009, to present

• Certified Observer Qualification Exams various operators

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• ISU TSs, Rev. 6, August 14, 2006 b. Observations and Findings The inspector followed-up on the Non-Cited Violation (NCV) 50-284/2007-201-01 (NRC Report 50-284/2007-201, ADAMS Accession No. ML072390213) regarding an Senior Reactor Operator (SRO) not meeting the requirements of 10 CFR 55.59. During this inspection it was noted that a second SRO had an inactive license, neither of which were actively participating in a requalification program.

Per 10 CFR 55.53(h) it states that the licensee shall complete a requalification program as described by 10 CFR 55.59. However, it was noted during the exit that the facility intended to provide in writing a request to the NRC to terminate the operating licenses. The inspector had noted that the new progress checklist used to track the individual operators was being successfully implemented and has noticeably improved the facility requalification program. The tracking log was an action which was a follow-up to NCV 50-284/2007-201-01. Therefore, the inspector has closed item NCV 50-284/2007-201-01. The inspector has opened Unresolved Item1 (URI) 50-284/2010-202-01 to follow-up on the termination of the two operator licenses who were in non-compliance with 10 CFR 55.53(h).

c. Conclusion The licensee was generally meeting the requalification program requirements to ensure the effectiveness of all licensed operators.

8. Experiments a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with the requirements of 10 CFR 50.59

• Closed Loop Oscillator Basis for 10 CFR 50.59 b. Observations and Findings The facility does not frequently conduct new experiments. During the inspection the inspector reviewed the safety analysis for a closed loop oscillator system.

The system is mounted on the North Wall and pushes an aluminum tube containing sample material through a beam port. The purpose of the oscillator is to cancel out the effects of an oscillating sample moving through the glory hole (open loop oscillator). The samples to be pushed through the aluminum tube are cadmium which is a negative reactivity addition.

The review process for the experiment was in accordance with the requirements of 10 CFR 50.59. The review identified potential hazards, experiment constraints, accounts for irradiated material, and determination of reactivity worth for the experiments.

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c. Conclusion Experiments were being reviewed in accordance with procedures and standard practice 9. Design Changes a. Inspection Scope (IP 69001)

The inspector reviewed the following to verify compliance with the requirements of 10 CFR Part 50.59

• Summary Review of 10 CFR 50.59 Analysis of the Changeover to the new solid state reactor console b. Observations and Findings The facility has not made any design changes to the facility since the last inspection. However, the facility is intending to begin testing and operation with the newer solid state reactor console which is currently under review by the NRC.

The inspector reviewed the screening analysis required under the stipulations of 10 CFR 50.59 to ensure that design changes do not alter the safety functions as described by the facility SAR. The screening process and administrative process that the facility uses to review and approve changes in accordance with 10 CFR 50.59 c. Conclusion Based on the records reviewed, the inspector determined that the licensee's design change program was being implemented as required.

10. Follow-up on Previously Identified Issue a. Inspection Scope (IP 92701)

The inspector followed up on the NCV 50-284/2007-201-01 (NRC Inspection Report No. 50-284/2007-201, ADAMS Accession No. ML072390213) regarding an SRO not meeting the requirements of 10 CFR Part 55 and continuing to perform licensed actions without oversight.

b. Observations and Findings NCV 50-284/2007-201-01 The inspector followed-up on the NCV 50-284/2007-201-01 (NRC Report 50-

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284/2007-201, ADAMS Accession No. ML072390213) regarding an SRO not meeting the requirements of 10 CFR 55.59. During this inspection it was noted that a second SRO had an inactive license, neither of which were actively participating in a requalification program. Per 10 CFR 55.53(h) it states that the licensee shall complete a requalification program as described by 10 CFR 55.59.

However, it was noted during the exit that the facility intended to provide in writing a request to the NRC to terminate the operating licenses. The facility director sent a written request via electronic e-mail on August 11, 2010, to terminate said SRO licenses.

Additionally, the inspector followed-up on the committed actions by the licensee with regards to tracking hours of licensed activities and training in accordance with the requalification program. The inspector had noted that the new progress checklist used to track the individual operators was being successfully implemented and has noticeably improved the facility requalification program.

The tracking log was an action which was a follow-up to NCV 50-284/2007-201-01. Therefore, the inspector has closed item NCV50-284/2007-201. The inspector has opened URI50-284/2010-201 to follow-up on the termination of the two operator licenses who were in non-compliance with 10 CFR 55.53(h).

IFI 50-284/2009-201-01 The inspector followed-up on the IFI 50-284/2009-201-01 (NRC Report 50-284/2009-201, ADAMS # ML0925103331). Through the review of logs and pre-start-up check off lists, (i.e., Form ROL-101) the inspector noted on several occasions that facility staff and those that are in training were signing into the logbook as a Certified Observer and performing reactor operations that were outside the constrains of TS 1.2, which states a Certified Observer is an individual certified by the Reactor Supervisor as qualified to activate manual scram and initiate emergency procedures. Upon further discussion with the licensee, it appears that it is a nomenclature error as the operators should be identified as Authorized Operators. TS 1.1 states that, an Authorized Operator is an individual authorized by the Reactor Supervisor to operate the reactor controls and who does so with the knowledge of the Reactor Supervisor and under the direct supervision of a Reactor Operator.

The licensee corrected this issue by addressing it during the annual requalification program training and initial certification exam. Additionally, the current operating logs better define who are the Certified Observers and Authorized Operators during operation. Therefore, IFI 50-284/2009-201-01 is considered closed.

c. Conclusion The NCV 50 -284/2007-201-01 is closed with URI 50-284/2010-201 to follow-up on a potential violation with regards to 10 CFR 55.53(h).

The IFI 50-284/2009-201-01 was closed.

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10. Exit Meeting Summary The inspection scope and results were summarized on August 4, 2010, with licensee representatives. The inspector discussed the findings for each area reviewed. No dissenting comments were received from the licensee.

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PARTIAL LIST OF PERSONS CONTACTED Licensee A. Mallicoat Reactor Supervisor G. Imel Dean, College of Science and Engineering Reactor Administrator and Interim Chair, Nuclear Engineering Department Other Personnel R. Acha Radiation Safety Technician, TSO, ISU K. Bunde Radiation Safety Committee member R. Brey Radiation Safety Officer and Director, TSO, ISU F. Just Chair, Reactor Safety Committee M. McAnulty Mechanical Engineer, Advanced Test Reactor, U.S. Department of Energy Idaho Branch Operations Office INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED OPENED:

URI 50-284/2010-202-01 Follow-up to potential violation of 10 CFR 55.53(h) for failure to complete a requalification program for two licensed SROs.

CLOSED:

NCV 50 -284/2007-201-01 Follow-up to the non-cited violation for an SRO not meeting the requirements of 10 CFR 55 and continuing to perform licensed actions without oversight.

IFI 50-284/2009-201-01 Follow-up to Certified Observer and Authorized Operator performing operations which deviate from TS definitions.

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LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Documents Access and Management System AGN-201M Aerojet General Nucleonics-201M ALARA As Low As Reasonably Achievable DDE Deep dose equivalent IFI Inspection Follow-up Item IP Inspection Procedure ISU Idaho State University mr millirem mr/hr millirem per hour NRC Nuclear Regulatory Commission NCV Non-cited Violation OP Operating Procedure OSL Optically Stimulated Thermoluminescent Rev. Revision RPM Radiation Procedures Manual RO Reactor Operator RPR Radiation Safety Procedure RSC Reactor Safety Committee RSM Radiation Safety Policy Manual SDE Shallow Dose Equivalent SRO Senior Reactor Operator TLD Thermoluminescent Dosimeter TS Technical Specification TSO Technical Safety Office URI Unresolved Item