IR 05000297/2010201

IR 05000297-10-201; North Carolina State University; 02/1-4/2010; Pulstar Nuclear Reactor Facility; NRC Announced Routine Inspection Report

ML100490659
Person / Time
Site:	North Carolina State University
Issue date:	03/01/2010
From:	Johnny Eads Research and Test Reactors Branch B
To:	Hawari A North Carolina State University
DONOHUE J, NRC/NRR/DPR/PRTB 415-3163
References
IR-10-201
Download: ML100490659 (16)

Text

rch 1, 2010

SUBJECT:

NORTH CAROLINA STATE UNIVERSITY - NRC ANNOUNCED ROUTINE INSPECTION REPORT NO. 50-297/2010-201

Dear Dr Hawari:

The U.S. Nuclear Regulatory Commission (NRC) conducted an inspection on February 1-4, 2010, at your North Carolina State University (Inspection Report No. 50-297/2010-201). The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress.

Based on the results of this inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial , to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington DC 20555-0001.

In accordance with Title 10 of the Code of Federal Regulations Part 2.390 Public inspections, exemptions, and requests for withholding a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (Agencywide Document Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions concerning this inspection, please contact Jack Donohue at 301-415-3163 or electronic mail at Jack.Donohue@nrc.gov.

Sincerely,

/RA by Patrick Isaac Acting For/

Johnny H. Eads, Jr., Chief Research and Test Reactors Oversight Branch rch 1, 2010

SUBJECT:

NORTH CAROLINA STATE UNIVERSITY - NRC ANNOUNCED ROUTINE INSPECTION REPORT NO. 50-297/2010-201

Dear Dr Hawari:

The U.S. Nuclear Regulatory Commission (NRC) conducted an inspection on February 1-4, 2010, at your North Carolina State University (Inspection Report No. 50-297/2010-201). The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress.

Based on the results of this inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial , to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington DC 20555-0001.

In accordance with Title 10 of the Code of Federal Regulations Part 2.390 Public inspections, exemptions, and requests for withholding a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (Agencywide Document Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions concerning this inspection, please contact Jack Donohue at 301-415-3163 or electronic mail at Jack.Donohue@nrc.gov.

Sincerely,

/RA by Patrick Isaac Acting For/

Johnny H. Eads, Jr., Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-297 License No. R-120 Enclosure: As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC PRTB/rf RidsNrrDprPrta RidsOgcMailCenter JDonohue, NRR DHardesty, NRR RidsNrrDprPrtb MCompton (Ltr only O13-C5M)

GLappert, NRR Accession Number: ML100490659 TEMPLATE #: NRC-002 OFFICE PROB:RI PRPB:LA PROB:BC NAME JDonohue GLappert JEads (GMorlang for) (PIsaac for)

DATE 3/ 1 /2010 3/ 1 /2010 3/ 1 /2010 Official Record Copy

North Carolina State University Docket No.: 50-297 cc:

Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Dr. Yousry Azmy, Head Nuclear Engineering Department North Carolina State University P.O. Box 7909 Raleigh, NC 27695-7909 Beverly Hall, Section Chief Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 3825 Barrett Drive Raleigh, NC 27609-7221 Dr. Louis Martin-Vega Dean of Engineering North Carolina State University 113 Page Hall Box 7901 - NCSU Raleigh, NC 27695-7901 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611 Andrew Cook Manager, Engineering and Operations Department of Nuclear Engineering North Carolina State University P. O. Box 7909 Raleigh, NC 27695-7909

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-297 License No: R-120 Report No: 50-297/2010-201 Licensee: North Carolina State University Facility: PULSTAR Nuclear Reactor Facility Location: Raleigh, NC Dates: February 1 to 4, 2010 Inspector: Jack Donohue Approved by: Johnny H. Eads, Jr., Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY North Carolina State University PULSTAR Reactor Facility NRC Inspection Report No. 50-297/2010-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the North Carolina State University (the licensee) Class II research reactor facility safety programs including organization and staffing; operations logs and records; experiments; health physics; committees, audits and reviews; transportation; and follow up on previously identified items. The licensee=s programs were acceptably directed toward the protection of public health and safety, and were in compliance with U. S. Nuclear Regulatory Commission requirements.

Organization and Staffing

• Organizational structure and responsibilities were consistent with Technical Specification requirements. Shift staffing met the minimum requirements for current operations.

Operations Logs and Records

• Operation logs and record keeping program conformed to Technical Specification requirements.

Experiments

• Experiments appeared to be reviewed and performed in accordance with Technical Specification requirements and the licensees written procedures.

Health Physics

• The inspector verified that the licensees radiation protection program was effective in minimizing radiation doses to individuals through training, notices to workers, radiation monitoring and surveys, and calibrated equipment.

Effluent and Environmental Monitoring

• Effluent releases, effluent monitoring, and environmental monitoring satisfied license and regulatory requirements.

Committees, Audits, and Reviews

• The Radiation Safety Committee and Reactor Safety and Audit Committee provided the oversight required by the Technical Specifications.

-2-Transportation

• Radioactive material shipments were made according to procedures and regulatory requirements.

Follow-up of Previously Identified Items

• The Inspector Follow-up Item 50-297/2009-201-01 issue identified on the previous inspection is closed.

REPORT DETAILS Summary of Facility Status The North Carolina State University (NCSU, the licensee) Nuclear Reactor Program (NRP)

PULSTAR research reactor continued to be operated in support of graduate and undergraduate research and laboratory instruction, service irradiations, reactor operator training, and periodic surveillance. During the inspection, the reactor was operated in support of ongoing work and research.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001-02.01)

The inspector reviewed the following regarding the licensees organization and staffing to ensure that the requirements of Section 6.1 of Technical Specifications (TS), Amendment No. 17, dated September 8, 2008, were being met:

• Organizational structure

• Management responsibilities

• Staffing requirements for safe operation of the research reactor facility

• PULSTAR Reactor Logbook, April 8, 2009 to February 4, 2010

• Procedure NRP-OP-103, Reactor Operation, Rev. 2, dated April 15, 2009 b. Observations and Findings NCSU organization had not changed since the last U. S. Nuclear Regulatory Commission (NRC) inspection (refer to Inspection Report No. 50-297/2009-201).

The minimum staffing required when the reactor is not secured is specified in TS 6.1.3. The inspector reviewed the console records for the period covering April 2009 to February 2010 and determined that staffing requirements were met.

c. Conclusions The licensee's organization and staffing were in compliance with the requirements specified in TS Section 6. The operations log and associated records confirmed that shift staffing met the minimum requirements for duty and on-call personnel.

-2-2. Operations Logs and Records a. Inspection Scope (IP 69001-02.02)

The inspector reviewed selected maintenance and reactor operations records to ensure that the requirements of TS Section 6.8 Retention of Records were being met:

• Procedure NRP-OP-103, Reactor Operation, Rev. 2, dated April 15, 2009

• NCSU PULSTAR Reactor Logbook, April 8, 2009 to February 3, 2010 b. Observations and Findings Reactor Operations were carried out following written procedures and TS requirements. The inspector conducted observations of the reactor staff performing pre-startup checks and a startup.

The reactor operations logbook, an official record of reactor operations, was used as a chronological account of operations. The use of multicolor pens, black (routine entries), red (unscheduled scrams/shutdowns), and green (for scram clearance, and authorization for continued operations) enhances the subsequent reviews by management. Hourly readings from operating equipment are recorded in the Operating Parameters Log. This data was used for preemptive maintenance to prevent equipment failures during operation. In addition, equipment maintenance records contained detailed information regarding equipment failures, the failure mode, repairs, calibrations, and operational testing prior to return to service. A rubber stamp was used to document all of the factors used to calculate the Estimated Critical Position (ECP) of the control rods when the reactor was critical. For the records included in this review, the licensees administrative requirements were met.

c. Conclusions Within the scope of this review, the licensees record keeping program conformed to TS requirements.

3. Experiments a. Inspection Scope (IP 69001-02.06)

The inspector reviewed the following to verify compliance with TS Sections 3.7, Limitations on Experiments, 3.8, Operation with Fueled Experiments, and 6.4, Review of Experiments:

• Experiment Logbook

• Procedure NRP-OP-104, Reactor Experiments, dated December 15, 2009

• Experiment Records, 2008 and 2009

-3-b. Observations and Findings The licensee maintained an Experiment Logbook consisting of two sections. The first section consisted of completed forms entitled Appendix A to Procedure NRP-OP-104, Reactor Utilization Request. It contained approved experiments for miscellaneous reactor utilization and experiments for neutron activation analysis, neutron irradiation, and neutron flux mapping. These experiments had been approved throughout the life of the NRP by the Radiation Safety Committee (RSC) or the Reactor Safety and Audit Committee (RSAC) in accordance with TS Section 6.2, Review and Audit. The approvals were written and approved pursuant to TS Section 6.4, Review of Experiments, as new or untried experiments; they were written to provide an umbrella for subsequent applications, with minor variations, as tried experiments approved by the Reactor Operations Manager (ROM) and the Reactor Health Physicist (RHP) pursuant to TS 6.4.

The second section of the Experiment Logbook consisted of forms entitled Appendix B to Procedure NRP-OP-104, Reactor Sample Irradiation History.

Each time a tried experiment was performed one line of data was added to this form, indicating the type of material irradiated, the quantity, the irradiation time, power level, etc. The ROM and RHP indicated that they reviewed each tried experiment prior to giving their approval to place it in the reactor.

The inspector reviewed data for approximately 300 experiments performed during 2009. The experiments consisted of 50 percent research, 2 percent education and 48 percent services.

c. Conclusions Experiments appeared to be reviewed and performed in accordance with TS requirements and the licensees written procedures.

4. Health Physics a. Inspection Scope (IP 69001-02.07.a-d & g-p)

The inspector reviewed the following to verify compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 20 and TS Sections 3.5 and 4.4, Radiation Monitoring Equipment, requirements:

• Procedure Health Physics (HP) 1, Radiation Protection Program, dated April 17, 2009

• Procedure HP 3, Radiological Surveys, dated July 1, 2004

• PULSTAR Nuclear Reactor Radiation Protection Program 2008

• Self-Assessment, G. Wicks, dated March 31, 2009

• File of Monthly HP Trends for 2009

• File of Radiation Work Permits (per Procedure HP 8) for 2008 and 2009

-4-

• PULSTAR Nuclear Reactor Annual Report for 2008 and 2009

• Procedure HP 8, Radiation Work Permits, dated November 8, 2004

• Procedure HP 9, Respirator Use and Bioassay, dated November 8, 2004

• Procedure HP 10, Calibration, Operation, and Maintenance of Radiation Surveys and Chemistry Controls, dated July 4, 2004

• File of Medical Examinations for Respiratory Device Use for 2008 and 2009

• Landauer Personnel Dosimetry Reports for 2008 and three quarters of 2009

• File of Monthly Contamination Surveys (HP 3 Attachment 1) for 2008 and 2009

• File of Monthly Radiation Surveys (HP 3 Attachment 1) for 2008 and 2009

• File of Monthly Reactor Bay Continuous Air Monitor Particulate Filter Measurements for 2008 and 2009

• File of Monthly Reactor Bay Continuous Air Monitor Iodine Cartridge Measurements for 2008 and 2009

• Surveillance Procedure PS 6-17-1:A1, Area Radiation Monitor Calibration, dated June 17, 2002, and surveillance files for 2008 and 2009

• Surveillance Procedure PS 6-17-2:A1, Process Radiation Monitor Channel Calibration, dated April 6, 2005, and surveillance files for 2008 and 2009

• File of 2008 and 2009 PULSTAR Nuclear Reactor Examination Answer Sheets for HP Training b. Observations and Findings The inspector toured the facility, finding practices regarding the use of dosimetry, radiation monitoring equipment, placement of radiological signs and postings, use of protective clothing, and the handling and storing of radioactive material or contaminated equipment to be in accordance with regulations and the licensees written Radiation Protection Program. The licensee had performed and documented annual self-assessments of the program as a tool in assuring effective implementation of As Low As Reasonably Achievable (ALARA)

practices.

The inspector reviewed records of radiation surveys of the nuclear reactor facility (NRF), performed by a HP Specialist from the Department of Environmental Health and Safety (EHS), and found them to be generally low and in line with facility postings and instrument readings. No unmarked radioactive material was found in the facility. A copy of the current NRC Form 3 notice to radiation workers required by 10 CFR Part 19 was posted at the entrance to the Control Room and Reactor Bay.

The inspector reviewed respiratory training records and bioassay data for NRF personnel. Medical records indicate a clinical evaluation was completed on Reactor Operations Personnel.

-5-Dosimetry results were reviewed by the inspector, indicating doses to most NRF occupants to be minimal. The inspector noted that the dosimetry records for an individual for the last two quarters of 2008 were 715 millirem. Although the total yearly dose was < 1 rem (<20percent of the limit) and the ALARA limit is 10 percent of the regulatory limit, the immediate action was delayed due in part to the normal delay in receiving reports from Landauer (December 4, 2009). The RHP/EHS personnel determined that the high exposure was due to leakage from the positron to personnel working in a power affected area. Administrative controls were added including contacting RHP prior to entry into power affective areas and additional shielding was added resulting in overall exposure reductions. As a continued part of an ALARA reduction effort, electronic dosimeters were ordered and are expected to be in place by February 2010.

Radiation monitoring devices were found to be calibrated within the frequencies specified in procedures. The NRF personnel calibrated in-line process instrumentation while the EHS calibrated all portable instruments.

The inspector noted from records that training was provided for radiation workers assigned to the NRF and individuals were not issued dosimetry or given access until the training was successfully completed.

c. Conclusions The inspector verified that the licensees radiation protection program (RPP) was effective in minimizing radiation doses to individuals through training, notices to workers, radiation monitoring and surveys, and calibrated equipment. The RPP met TS requirements.

5. Effluent and Environmental Monitoring a. Inspection Scope (IP 69001-02.07.e, f, & q)

The inspector reviewed the following to verify compliance with 10 CFR Part 20 and TS Sections 3.5 and 4.4, Radiation Monitoring Equipment, requirements regarding effluents, and environmental monitoring:

• PULSTAR Nuclear Reactor Annual Report for 2008

• PULSTAR Reactor Environmental Radiation Surveillance Report for 2008

• File of Monthly Reactor Stack Particulate Filter Measurements for 2008 and 2009

• Surveillance Procedure PS 6-17-2:A1, Process Radiation Monitor Channel Calibration, dated April 6, 2005, and surveillance files for 2008 and 2009

• Sampling, Analysis and Assessment of Liquid Effluent and Airborne Effluent data, for 2008 and 2009

• Reportable Event 44991; Violation of Limiting Conditions of Operations in Technical Specification 3.5B and actions take and planned to prevent recurrence dated April 23, 2009

-6-b. Observation and Findings (1) Review Functions The annual report referenced above describes the gaseous, liquid and solid waste generated at the NRF during the year 2008, Argon-41 (Ar-41)

produced by the irradiation of atmospheric air being the only one of significance. The report presents the model, input data, assumptions, and summary of calculations for Ar-41 emissions. The inspector reviewed this information and concurred with the reported results. A total of 397 microcuries of liquid waste, primarily tritium, was released to the sanitary sewer. Solid waste from the reactor, consisting of 6.96 millicurie of radioactivity in 88 cubic feet of dry solid material, was transferred to the broad byproduct material (state) license for disposal at a licensed waste facility along with other low level radioactive waste from the remainder of the campus.

The licensee also reported the results of thermoluminescent dosimeters (TLDs) placed at eight locations around the NRF as environmental radiation monitors. In all cases the TLDs indicated no significant difference from background radiation levels. Surface water and vegetables were analyzed for indications of environmental impacts and likewise showed no significant difference from background levels. While only the first three quarters of the 2009 environmental data had been compiled at the time of the inspection, the Environmental Health Physicist performing the analysis noted that results available from 2009 show no significant difference from those of 2008.

(2) Licensee Reported TS Violation concerning loss of power to the exhaust stack sample pump during reactor operations TS Section 3.5b requires that the reactor shall not be operated unless the particulate and gas building exhaust monitors continuous sample air in the facility exhaust stack with the required set points listed in Table 3.5-1.

The inspector reviewed the completed actions taken to prevent recurrence. The actions include the addition of an audible alarm on a loss of power and a display of the sample flow rate in the control room. This event was reviewed with reactor operators. These actions appear to have corrected the problem. The licensee was informed that this non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A.8 of the NRC Enforcement Policy (NCV 50-297/2010-201-01).

c. Conclusions Effluent releases, effluent monitoring, and environmental monitoring satisfied license and regulatory requirements.

-7-6. Committees, Audits, and Reviews a. Inspection Scope (IP 69001-02.09)

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

• RSAC Appointment, dated July 24, 2009

• RSAC Minutes of meeting held April 17, 2009, September 30, 2009 and January 22, 2010 (unpublished)

• 2008 RSAC Audit Summary, dated June 2, 2009

• RSC Minutes of meeting held July 24, 2009 and September 23, 2009

• Annual Report for 2008, dated March 27, 2009

• PULSTAR Nuclear Reactor Radiation Protection Program 2008 Annual

• Self Assessment, Gerald Wicks, CHP dated March 31, 2009 b. Observations and Findings The composition of the RSC and RSAC were as specified in the TS. A review of records indicated that both committees met at the prescribed frequency and provided the oversight and reviews of the reactor programs as required by the TS.

c. Conclusions The RSC and RSAC provided the oversight required by the TS.

7. Transportation a. Inspection Scope (IP 86740)

The inspector interviewed personnel and reviewed the following to verify compliance with regulatory and procedural requirements for transferring licensed material.

• File of Radioactivity Material Receipts for 2008 and 2009

• File of Radioactivity Material Shipments for 2008 and 2009

• File of Licenses for recipients of Radioactive Material Shipments

• Procedure HP 6, Transportation of Radioactive and Hazardous Material, dated September 25, 2003 b. Observations and Findings The inspector reviewed the papers for approximately 30 shipments of radioactive material. All of the shipments were low quantities of radioactivity. Many contained fractional gram quantities of special nuclear material that had been irradiated; others were radionuclides produced at the reactor for on-campus and off-campus researchers. The licensee had reviewed licenses of receivers to

-8-verify that they held current licenses to receive the material being shipped. In all cases, the shipping papers were found in order.

c. Conclusions Radioactive material shipments were made according to procedures and regulatory requirements.

8. Follow-up previous open items a. Inspection Scope (IP 92701)

The inspector reviewed actions taken by the licensee following identification of inspector follow-up items (IFIs), during previous inspections.

b. Observations and findings IFI 50-297/2009-201-01 follow-up to verify the licensee approval process of design changes and procedure changes had a consistent process for making sure that all operators are aware of such changes. Changes have been incorporated into appropriate procedures and training of reactor personnel has been completed. The IFI 50-297/2009-201-01 issue is closed.

c. Conclusion The issue identified in previous inspection reports is closed.

9. Exit Interview The inspector presented the inspection results to licensee management at the conclusion of the inspection on February 4, 2010. The inspectors described the areas inspected and discussed in detail the inspection observations. No dissenting comments were received from the licensee. The licensee acknowledged the findings presented and did not identify as proprietary and of the material provided to or reviewed by the inspector during the inspection.

-2-PARTIAL LIST OF PERSONS CONTACTED Licensee L. Broussard Chief Reactor Operator A. Cook Manager, Nuclear Reactor Program and Reactor Operations Manager Director, Nuclear Reactor Program K. Kincaid Chief of Reactor Maintenance G. Wicks Reactor Health Physicist INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-297/2010-201-01 NCV Licensee Reported TS Violation concerning loss of power to the exhaust stack sample pump during reactor operations.

Closed 50-297/2009-201-01 IFI Review and approval of design changes and procedure changes does not have a consistent process for making sure that all operators are aware of such changes.

50-297/2010-201-01 NCV Licensee Reported TS Violation concerning loss of power to the exhaust stack sample pump during reactor operations.

-2-PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Document Access and Management System ALARA As Low As Reasonably Achievable Ar-41 Argon-41 ECP Estimated Critical Position EHS Department of Environmental Health and Safety HP Health Physics IFI Inspection Follow-up Item IP Inspection Procedure NCSU North Carolina State University NCV Non-Cited Violation NRC U. S. Nuclear Regulatory Commission NRF Nuclear Reactor Facility NRP Nuclear Reactor Program PARS Publicly Available Records Rev. Revision RHP Reactor Health Physicist RO Reactor Operator ROM Reactor Operations Manager RPP Radiation Protection Program RSAC Reactor Safety and Auditing Committee RSC Radiation Safety Committee SRO Senior Reactor Operator TLD Thermoluminescent dosimeters TS Technical Specifications