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{{Adams
#REDIRECT [[IR 05000059/2006201]]
| number = ML060890431
| issue date = 06/29/2006
| title = Letter to Dr. William Burchill from Ho Nieh Grimes Sub: NRC Routine Inspection Report No. 50-059/2006-201 and Notice of Violation
| author name = Nieh H
| author affiliation = NRC/NRR/ADRA/DPR
| addressee name = Burchill W
| addressee affiliation = Texas A&M Univ
| docket = 05000059
| license number = R-023
| contact person = Witt K, NRC/NRR/ADRA/DPR/PRT, 415-4075
| document report number = IR-06-201
| document type = Inspection Report Correspondence, Letter, Notice of Violation
| page count = 20
}}
See also: [[see also::IR 05000059/2006201]]
 
=Text=
{{#Wiki_filter:June 29, 2006Dr. William E. BurchillHead of Nuclear Engineering
Texas A&M University
Zachry Bldg. Room 129
College Station, TX 77843-3133SUBJECT:  NRC ROUTINE INSPECTION REPORT NO. 50-059/2006-201 AND NOTICE OFVIOLATIONDear Dr. Burchill: 
This letter refers to the inspection conducted on March 7 and 15, and April 19, 2006, at theTexas A&M University AGN-201M research reactor.  The inspection included a review of
activities authorized for your facility.  The enclosed report presents the results of thatinspection.This inspection was an examination of activities conducted under your license as they relate tosafety and compliance with the Commission's 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, the NRC has determined that two Severity Level IVviolations of NRC requirements occurred.  These violations were evaluated in accordance withthe "General Statement of Policy and Procedure for NRC Enforcement Actions - EnforcementPolicy."  The current Enforcement Policy is included on the NRC's Web site at www.nrc.gov;select What We Do , Enforcement , then Enforcement Policy.  The violations are cited in theenclosed Notice of Violation (Notice) and the circumstances surrounding them are described indetail in the subject inspection report.  The violations are being cited in the Notice because:
1) they demonstrate a lack of attention to the reactor and emergency preparedness programs,
and 2) they were identified by the
NRC and not as a result of your own audit program.You are required to respond to this letter and should follow the instructions specified in theenclosed Notice when preparing your response.  The NRC will use your response, in part, todetermine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.  The NRC has concluded that some information has already beenprovided in a letter from you received by the NRC dated May 5, 2006.  You are required toprovide all of the information specified in the enclosed notice.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be made available electronically for public inspection in the NRC PublicDocument Room or from the NRC's document system (ADAMS), accessible from the NRC
Web site at http://www.nrc.gov/reading-rm/adams.html.  To the extent possible, your response 
Dr. Burchill -2- should not include any personal privacy, proprietary, or safeguards information so that it can bemade available to the Public without redaction. Should you have any questions concerning this inspection, please contact Mr. Kevin M. Witt at301-415-4075.Sincerely,/RA/Ho Nieh, Acting Division DirectorDivision of Policy and Rulemaking
Office of Nuclear Reactor RegulationDocket No. 50-059License No. R-23Enclosures:1. Notice of Violation2. NRC Inspection Report No. 50-059/2006-201
 
  ML060890431TEMPLATE #:  NRR-106OFFICEPRT:RIPRT:PMPRT:LAPRTA:BCPRTB:BCDPR:ADDNAMEKWitt*MMendonca*EHylton:tls*BThomas:tls*JEads*HNieh:tls*DATE04/20/2006
5/31/0604/05/20066/5/066/27/066/29/06
Texas A&M UniversityDocket No. 50-59
cc:
Mayor of the City of College StationCollege Station, TX  77843-3575Governor's Budget and  Planning Office
P.O. Box 13561
Austin, TX  78711Bureau of Radiation ControlState of Texas
1100 West 49
th StreetAustin, TX  78756Department HeadNuclear Engineering
129 Zachry Engineering Center
Texas A&M University
College Station, TX  77843-3133Dr. W.D. ReeceDirector, Nuclear Science Center
Texas A&M University
F.E. Box 89
College Station, TX  77843-3575Test, Research, and Training  Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 
32611
NOTICE OF VIOLATIONTexas A&M University Docket No. 50-059AGN-201M Research Reactor FacilityLicense No. R-23During an NRC inspection conducted on March 7, 2006, two violations of
NRC requirementswere identified.  In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions - Enforcement Policy," the violations are listed below: A.Technical Specification Section 6.4.3 states, "Audits of facility activities shall beperformed at least quarterly under the cognizance of the Reactor Safety Board but in no
case by the personnel responsible for the item audited.  These audits shall examine the
operating records and encompass but shall not be limited to the following: a) The
conformance of the facility operation to the Technical Specifications and applicablelicense conditions, at least annually; b) The Facility emergency plan and implementingprocedures, at least every two years, c) The Facility Security Plan and implementingprocedures, at least every two years."  Contrary to the above, no audits have been conducted since the reactor was lastoperable in 1999.  This is a Severity Level IV violation (Supplement VII).B.10 CFR 50.54(q) states, "A licensee authorized to possess and operate a researchreactor or a fuel facility shall follow and maintain in effect emergency plans which meetthe requirements in appendix E to this part."The Texas A&M University AGN-201M Emergency Plan (E-Plan) Section 10.1 states,"This evacuation drill is detailed in and performed in accordance with the AGN-201MMaintenance Procedures, annually, but at intervals not to exceed sixteen (16) months."
Additionally, the E-Plan also states, "The retraining and re-orientation of facilityemergency response personnel are to be included as part of the annual AGN-201M
requalification program for reactor operators."Contrary to this requirement, the licensee stated that emergency drills had not beenconducted annually.  The licensee had not conducted an emergency drill since thereactor was last operated in 1999.  The licensee also could not find documentation
indicating that the required retraining and re-orientation of facility emergency responsepersonnel was being completed.  The licensee indicated that this training had not been
conducted since the reactor was last operated in 1999.This is a Severity Level IV violation (Supplement VIII).Pursuant to the provisions of 10 CFR 2.201, Texas A&M University is hereby required to submita written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the responsible inspector,
within 30 days of the date of the letter transmitting this Notice of Violation (Notice).  This reply
should be clearly marked as a "Reply to a Notice of Violation" and should include for each
violation:  (1) the reason for the violation, or, if contested, the basis for disputing the violation orseverity level, (2) the corrective steps that have been taken and the results achieved, (3) the 
-2-corrective steps that will be taken to avoid further violations, and (4) the date when fullcompliance will be achieved.  Your response may reference or include previous docketedcorrespondence, if the correspondence adequately addresses the required response.  If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken.  Where good cause is
shown, consideration will be given to extending the response time.  The NRC has concluded that information regarding the reason for violation A, the correctiveactions taken and planned to correct the violations and prevent recurrence is already
adequately addressed on the docket in a letter from you received by the NRC dated May 5, 2006.  In that letter, you also provided information regarding part of the reason for
violation B.  You are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or
your position.  You are still required to provide the rest of the information specified in theprevious paragraph.If you contest this enforcement action, you should also provide a copy of your response, withthe basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001. Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the NRC's document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it shouldnot include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction.  If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of yourresponse that deletes such information.  If you request withholding of such material, you mustspecifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information
willcreate an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information).  If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.  In accordance with 10 CFR 19.11, you may be required to post this Notice within two workingdays. Dated at Rockville, Maryland this      day of 2006
U. S. NUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONDocket No.:50-059
License No.:R-23
Report No.:50-059/2006-201
Licensee:Texas A&M University
Facility:Texas A&M University AGN-201M Research ReactorLocation:College Station, TX
Dates:March 7 and 15, and April 19, 2006
Inspector:Kevin M. Witt
Approved by:Ho K. Nieh, Acting Division DirectorDivision of Policy and Rulemaking
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARYTexas A&M UniversityReport No:  50-059/2005-201The primary focus of this routine, announced inspection was the on-site review of selectedaspects of the licensee's non-power training reactor operation including: organization and
staffing; operations logs and records; requalification training; radiation protection; designchanges; committees, audits and reviews; emergency preparedness; and a follow-up on
previous open items.Organization and Staffing
!The licensee's organization and staffing remain in compliance with the requirementsspecified in the Technical Specifications.Operations Logs and Records
!The reactor has not been operated since August 25, 1999.  An inspector follow-up itemwas issued to request information regarding the status of the control console upgrades
and an unresolved item was issued for failure to submit annual reports.Requalification Training
!Operator requalification was not being conducted as required by the OperatorRequalification Program due to the long term shutdown of the reactor facility.  Aninspector follow-up item was issued to request information about the licensee's plan to
re-qualify the only licensed operator before the reactor is operated again.Radiation Protection Program
!Surveys were being completed and documented acceptably.
!Postings met the regulatory requirements specified in 10 CFR Parts 19 and 20.
!Personnel dosimetry was being worn as required and doses were well within thelicensee's procedural action levels and NRC's regulatory limits.
!Radiation monitoring equipment was being maintained and calibrated as required.
!The Radiation Protection Program being implemented by the licensee satisfiedregulatory requirements.
!Effluent monitoring satisfied license and regulatory requirements and releases werewithin the specified regulatory and Technical Specification limits.Design Change
s!No significant nor minor changes have been evaluated at the facility.  An inspectorfollow-up item was issued to ensure that the licensee conduct a 10 CFR 50.59 review on
the changes being made to the reactor control console.
-2-Committees, Audits, and Reviews
!Review and oversight functions required by the Technical Specifications were notcompleted by the Reactor Safety Board due to the reactor being maintained in an
extended shutdown condition.  A violation was issued for failure to complete audits of
facility operations, the facility emergency plan, and the facility security plan, as requiredby the Technical Specifications.Emergency Preparedness
!A violation was issued for not conducting emergency training and requalification as wellas annual emergency drills as required by the Technical Specifications.Follow-up on Previous Open Items
!The issue regarding the evaluation of whether to develop a procedure for evaluatingfacility changes remains open.
REPORT DETAILSSummary of Plant StatusThe licensee's five watt Aerojet General Nucleonics-201M (AGN) training reactor continues tobe maintained in an extended shutdown condition.  The licensee plans to upgrade the control
system to utilize current digital technologies.  During the inspection, the reactor was notoperated due to the lack of an operable control console.  Records show that the reactor has notbeen operated since August 25, 1999.  The licensee indicated that the main priority of thereactor staff has been to implement a new control system.  According to Technical Specification(TS) Section 4.0, Surveillance Requirements, "Actions specified in this section are not requiredto be performed if during the specified surveillance period the reactor has not been brought
critical or is maintained in a shutdown condition extending beyond the surveillance period."1.Organization and Staffinga.Inspection Scope (Inspection Procedure [IP] 69001)The inspector reviewed the following regarding the licensee's organization andstaffing to ensure that the requirements of the TS Sections 6.1 and 6.2 were beingmet:*organization and staffing*qualifications
*management responsibilities*administrative controlsb.Observations and FindingsThe inspector determined that the organizational structure at the facility had notchanged since the previous NRC inspection in September 1999 (NRC InspectionReport 50-059/1999-201).  The reactor supervisor (RS) who had been in the position
for many years has left the facility and the only other licensed operator has assumedthe duties of that position.  The current RS is a full time professor and the duties ofthe RS are conducted on an as needed basis.  Due to the constraints of staffing, the
department head has appointed a professor as the laboratory facilities m anager(LFM).  The LFM position is responsible for maintaining the administrative
requirements of the facility and for ensuring that the restart of the reactor is kept ona strict schedule. Through a review of résumés and discussions with personnel, the inspectordetermined that the staff members satisfied the TS qualification requirements.  Areview of reactor console records confirmed that the staffing requirements during
reactor operations were met.c.ConclusionsThe licensee's organization and staffing remain in compliance with the requirementsspecified in the TSs.
-2-1An Unresolved Item is a matter about which more information is required to determinewhether the issue in question is an acceptable item, a deviation, a nonconformance, or a
violation.2.Operations Logs and Recordsa.Inspection Scope (IP 69001)The inspector reviewed the following to ensure that selected records weremaintained as required by TS Section 6.10:*Reactor status updates*Annual Operating Report of the Texas A&M University AGN-201M TrainingReactor, dated June 1, 2001 - May 31, 2002b.Observations and FindingsThe AGN-201M reactor has been undergoing upgrades to different components ofthe reactor control system.  The last date of operation of the reactor was August 25,1999.  Currently, the licensee is reconfiguring the control console to have digital
outputs for power and period in addition to having analog scrams to conform to the
present safety analysis report.  The licensee sent a letter to the NRC on J une 16,2003 stating that the reactor would be ready for restart by September 15, 2003.  Dueto unforeseen complications, the work on the control console upgrade has been
delayed numerous times since the letter was sent to the NRC.  The licensee
committed to sending a letter to the NRC with an updated schedule of controlconsole upgrade milestones.  This issue will be considered by the NRC as anInspector Follow-up Item (IFI) and will be reviewed during the next inspection at thefacility (IFI 50-059/2006-201-01).During the review of reactor documentation, the inspector noted that there havebeen no operating logs since 1999 due to the inoperable reactor and there is no TS
or procedural requirement for the licensee to maintain a log book.  Annual operating
reports have not been prepared for the past several years due to the reactor being
shut down.  The licensee was able to provide the inspector with one annual report
for the period of June 1, 2001 - May 31, 2002.  The inspector noted that the licenseehad not submitted the Annual Reports to the NRC for June 1, 2002 - May 31, 2003,for June 1, 2003 - May 31, 2004 and for June 1, 2004 - May 31, 2005.  As specified
in TS 6.9.1, "Routine annual operating reports shall be submitted no later than ninety(90) days following the end of the operating year."  The licensee has stated that
since the reactor is not being utilized, there is no information that can be submitted
to the NRC.  The licensee was informed that failure to submit annual operatingreports required by the TSs was identified as an Unresolved Item
1 (URI) pendingcorrective actions and implementation of controls to prevent recurrence.  This issue
will be reviewed during a future inspection (URI 50-059/2006-201-02). 
-3-c.ConclusionsThe reactor has not been operated since August 25, 1999.  An IFI was issued torequest information regarding the status of the control console upgrades and a URI
was issued for failure to submit annual reports .3. Requalification Training a.Inspection Scope (IP 69001 & 69002)The inspector reviewed the following to verify compliance with the requirements in10 CFR Part 55:*"Requalification Program for Licensed Reactor Operators and Senior ReactorOperators - Texas A&M University," modified May 20, 1988*operator active license status
*training
*operator physical examination records
*reactivity manipulations
*written examination results
*operator active duty statusb.Observations and FindingsThe interim RS, who has a senior reactor operator (SRO) license, is currently theonly staff member authorized to operate the reactor.  The previous RS, who has
recently left the facility, also possessed a SRO license.  The licensee could not
provide the inspector with any requalification records for the interim RS or the
previous RS, both of whom have had their SRO licenses since the reactor was
previously operational.  The required annual written examination and a
demonstration of operator proficiency in reactor operation have not been completed.
The required medical examinations have not been completed.10 CFR 55.59(a) states, "Requalification requirements. Each licensee shall - (1) Successfully complete a requalification program developed by the facilitylicensee that has been approved by the Commission.  This program shall be
conducted for a continuous period not to exceed 24 months in duration.
(2) Pass a comprehensive requalification written examination and an annual
operating test."According to 10 CFR 55.59(b), "Additional training.  If the requirements ofparagraphs (a) (1) and (2) of this section are not met, the Commission may require
the licensee to complete additional training and to submit evidence to the
Commission of successful completion of this training before returning to licensed
duties."  The licensee committed to submitting a letter to the NRC summarizing their
plans to requalify the only licensed operator at the facility.  In this letter, the licenseewill provide a description of how the operator will become proficient in the operationof the AGN-201M reactor.  Currently, the only operator at the facility is notconsidered to have a valid license due to a lack of participation in the requalification
-4-program.  This issue will be considered by the NRC as an IFI
and will be reviewedduring the next inspection at the facility (IFI 50-059/2006-201-03).c.ConclusionsOperator requalification was not being conducted as required by the OperatorRequalification Program due to the long term shutdown of the reactor facility.  An IFIwas issued to request information about the licensee's plan to re-qualify the only
licensed operator before the reactor is operated again.4.Radiation Protection Programa.Inspection Scope (IP 69001)The inspector reviewed the following to verify compliance with 10 CFR Part 20: Radiological Safety Program Manual, revised March 2000Radiation Protection Program: 2004 Review, dated April 13, 2005*Contamination Survey Forms for the AGN Complex, dated from 2004 topresent*Personnel and area dosimetry results for 2004 to present
*Certificate of Completion for General Radiological Safety Training, datedSeptember 23, 2004b.Observations and Findings(1)SurveysThe inspector reviewed monthly wipe contamination surveys of the AGNreactor facility completed by campus Environmental Health and SafetyDepartment (EHSD) Health Physics (HP) personnel.  There were no timeliness
requirements for the HP personnel to conduct these surveys.  The results were
documented on the appropriate forms, evaluated as required, and corrective
actions taken when readings or results exceeded set action levels.  No
elevated readings were discovered during the inspection period.(2)Postings and NoticesThe inspector reviewed the postings at the entrances to the facility controlledareas.  The postings were acceptable and indicated the radiation hazards
present.  Other postings also showed the industrial hygiene hazards present in
the areas.  The facility's radioactive material storage areas were noted to beproperly posted.  No unmarked radioactive material was detected in the facility. Copies of current notices to workers required by 10 CFR Part 19 were posted
on the bulletin board in the hallway leading to the reactor facility.(3)DosimetryThe licensee used a National Voluntary Laboratory Accreditation program-accredited vendor, Landauer, to process personnel dosimetry.  Through direct
-5-observation, the inspector determined that dosimetry was acceptably used byfacility personnel.  For visitors to the facility, no dosimetry is issued formonitoring due to low background readings and no direct exposures to
sources.An examination of the records for the inspection period showed that allexposures were well within NRC limits and within licensee action levels.  Thereare currently two people at the facility that are being monitored.  The inspectoralso reviewed the dosimetry records of the previous RS who has recently left
the facility.  Monitoring is accomplished by using an optically stimulatedluminescence dosimeter (OSLD).  All of the personnel associated with the
facility received exposures that approximately equal the background radiationlevels.  For any whole body or extremity exposures that exceed 40 millirem(mrem) in a one month period or 120 mrem per quarter, the badge holder isdirectly notified requesting an explanation of possible reasons for the deviation.
There were no notifications issued to staff at the AGN facility during theinspection period.(4)Radiation Monitoring EquipmentThe calibration of portable survey meters and friskers was typically completedby an outside contractor.  There were no fixed radiation detectors installed at
the facility.  The calibration stickers of portable survey meters and friskers inuse at the facility were reviewed.  Calibration frequency met the requirementsestablished in the applicable procedures while records were being maintained
as required.(5)Radiation Protection ProgramThe licensee's Radiation Protection Program was established in an onlinedocument.  The program required that all personnel who had unescorted
access to work in a radiation area or with radioactive material receive training
in radiation protection, policies, procedures, requirements, and facilities prior toentry.  The inspector verified that licensee staff had received the required
radiation protection ("rad worker") training given by EHSD.  In addition, thestaff with unescorted access to the AGN facility supervise all new employees atthe facility until they are given unescorted access.The inspector also verified that the Texas A&M radiation protection programwas being reviewed annually as required.  No issues were identified in the
audit of the program.(6)Facility ToursThe inspector toured the Reactor Room and the accompanying laboratories. Control of radioactive material and control of access to radiation and high
radiation areas were acceptable.  The postings and signs for these areas were
appropriate.  The inspector also determined that there were no measurable
releases of gaseous or liquid radioactive material from the research reactor
facility.
-6-(7)Environmental MonitoringAn OSLD dosimeter is placed in the AGN Complex several feet from thereactor facility.  A dosimeter is also placed directly outside of the facility in a
controlled area.  Annual dosimetry records for 2004 show that there was anexposure of less than 1 rem to the AGN room and less than 200 mrem
exposure to the room directly outside of the AGN facility.  There were no liquid
or gaseous effluents discharged from the facility due to the reactor notoperating.c.ConclusionsThe inspector determined that:  (1) surveys were being completed and documentedacceptably, (2) postings met the regulatory requirements specified in 10 CFR Parts
19 and 20, (3) personnel dosimetry was being worn as required and doses were well
within the licensee's procedural action levels and NRC's regulatory limits, (4)radiation monitoring equipment was being maintained and calibrated as required, (5)
the Radiation Protection Program being implemented by the licensee satisfied
regulatory requirements, and (6) effluent monitoring satisfied license and regulatory
requirements and releases were within the specified regulatory and TS limits.5.Design Changesa.Inspection Scope (IP 69001)In order to verify that any modifications to the facility were consistent with10 CFR 50.59 and TS Section 6.4.2, the inspector reviewed:procedures requiring review of changes under 10 CFR 50.59b.Observations and FindingsThe inspector verified that administrative controls were in place that required theappropriate review and approval of all changes prior to implementation.  The LFM
communicated that a 10 CFR 50.59 review will be conducted on the changes madeto the control system prior to starting the reactor again.  Currently, the controlsystem is at the reactor facility and is connected to the control rods.  While testing ofthe control system is underway, the control rods and their drives are removed fromthe core, which makes the reactor inoperable.  The inspector confirmed with the
licensee the need for them to complete the 10 CFR 50.59 review in order to ensure
an acceptable design change prior to the restart of the AGN-201M reactor.  This
issue will be considered by the NRC as an IFI
and will be reviewed during the nextinspection at the facility (IFI 50-059/2006-201-04).
-7-c.ConclusionsNo significant nor minor changes have been evaluated at the facility.  An IFI wasissued to ensure that the licensee conducts a 10 CFR 50.59 review on the changes
being made to the reactor control console.6.Committees, Audits, and Reviewsa.Inspection Scope (IP 69001 & 69002)The inspector reviewed the following to ensure that the audits and reviews stipulatedin TS Section 6.4 were being completed:Reactor Safety Board (RSB) meeting minutes for December 12, 2002b.Observations and FindingsThe composition and meeting frequency of the RSB satisfied the TS requirements. Due to the small size of the AGN reactor, the RSB was responsible for the oversight
of the Texas A&M TRIGA Reactor (Docket No. 50-128) as well as the AGN reactor.
For a majority of the meeting minutes, little mention was made of the activities
conducted at the AGN reactor since the TRIGA Reactor had more activities being
conducted.  Issues brought up by the RSB were resolved in an appropriate time
frame and were noted in RSB meeting minutes. TS 6.4.3 states, "Audits of facility activities shall be performed at least quarterlyunder the cognizance of the Reactor Safety Board but in no case by the personnel
responsible for the item audited.  These audits shall examine the operating records
and encompass but shall not be limited to the following: a) The conformance of the
facility operation to the Technical Specifications and applicable license conditions, atleast annually; b) The Facility emergency plan and implementing procedures, atleast every two years, c) The Facility Security Plan and implementing procedures, atleast every two years."  It appeared that audits had not been conducted since the
reactor was last operable in 1999.  The licensee has stated that there is very little
purpose of conducting an audit of the facility operation conformance to the TSssince there are no licensed activities being conducted at the facility.  The licenseewas informed that failure to conduct audits of facility operations, emergencypreparedness, and security was a violation of TS Section 6.4.3 (VIO 50-059/2006-
201-05).c.ConclusionsMinimal review and oversight functions were being completed by the RSB due to thereactor being maintained in an extended shutdown condition.  A violation was issued
for failure to complete audits of facility operations, the facility E-Plan, and the facilitySecurity Plan, as required by the TSs.
-8-7.Emergency Preparednessa.Inspection Scope (IP 69001 & 69002)The inspector reviewed the following to verify the implementation of the EmergencyPlan:Emergency Plan for the Texas A&M University AGN-201M Reactor, datedOctober 1998b.Observations and FindingsThe Emergency Plan (E-Plan) in use at the AGN facility was the same as the versionmost recently approved by the NRC, dated October 1998.  The inspector verifiedthat the facility and emergency equipment were as described in the E-Plan.  Theinspector could not determine whether there were implementing procedures that areneeded to effectively implement the E-Plan.E-Plan Section 10.1 states, "This evacuation drill is detailed in and performed inaccordance with the AGN-201M Maintenance Procedures, annually, but at intervals
not to exceed sixteen (16) months."  Contrary to this requirement, the licensee
stated that emergency drills had not been conducted annually.E-Plan Section 10.1 states, "The retraining and re-orientation of facility emergencyresponse personnel are to be included as part of the annual AGN-201M
requalification program for reactor operators."  The licensee could not find
documentation indicating that this training for the reactor staff and emergency
responders was being completed. 10 CFR 50.54(q) states, "A licensee authorized to possess and/or operate aresearch reactor or a fuel facility shall follow and maintain in effect emergency planswhich meet the requirements in appendix E to this part."  The licensee was informed
that failure to conduct annual emergency drills and retraining and reorientation offacility emergency response personnel as required by E-Plan Section 10.1 was aviolation of 10 CFR 50.54(q) (VIO 50-059/2006-201-06).c.ConclusionsA violation was issued for not conducting emergency training and requalification aswell as annual emergency drills as required by the TSs.8.Follow-up on Previous Open Itemsa.Inspection Scope (IP 69001)The inspectors reviewed the actions taken by the licensee following identification ofInspector Follow-up Items during a previous inspection.
-9-b.Observations and Findings(1)IFI 059-98-201-02 - Follow-up on the licensee's evaluation of the need forformal written guidance to ensure that any facility change would be done under10 CFR 50.59 or license amendment as required by TS.NRC Inspection Report No. 50-059/98-201, dated May 12, 1998, outlined thesituation.  During that inspection, the inspector noted that unscheduledmaintenance or repairs were informally evaluated to decide that it was not a
facility change.  The Reactor Supervisor stated that they would evaluate theneed for formal written guidance.  During the inspection conducted on
September 27, 1999, the inspector reviewed the situation and found that thelicensee was still reviewing the changes to 10 CFR 50.59 requirements todetermine the need for formal written guidance to ensure that any facilitychange would be done under 50.59 or license amendment as required by TS.During this inspection, the inspector confirmed that the licensee had committedto developing a new procedure that would effectively instruct staff on
conducting 10 CFR 50.59 reviews.  This issue will still be considered by theNRC as an IFI
and will be reviewed during the next inspection at the facility. This issue will remain
open.c.ConclusionsThe issue regarding the evaluation of whether to develop a procedure for evaluatingfacility changes remains open.9.Exit InterviewThe inspection scope and results were summarized on March 7 and 15, and April 19, 2006, with members of licensee management.  The inspector described the areas
inspected and discussed in detail the inspection findings.  No dissenting comments were
received from the licensee. 
PARTIAL LIST OF PERSONS CONTACTEDLicenseeW. Burchill, Department Head, Nuclear EngineeringW. Charlton, Laboratories SupervisorD. Menchaca, Radiological Safety OfficerINSPECTION PROCEDURES USEDIP 69001Class II Research and Test ReactorsIP 69002Class III Research and Test ReactorsITEMS OPENED, CLOSED, AND DISCUSSED
Opened50-059/2006-201-01IFIFollow-up to verify that the licensee sends a letter to the NRCwith an updated schedule of control console upgrade
milestones. 50-059/2006-201-02URIFailure to submit annual operating reports in accordance withTS requirements.50-059/2006-201-03 IFIFollow-up to verify the licensee sends a plan to the NRCdescribing how the operator will become proficient in theoperation of the AGN. 50-059/2006-201-04IFIFollow-up to verify the licensee completes the 10 CFR 50.59review regarding the control console upgrade.50-059/2006-201-05VIOFailure to conduct audits.50-059/2006-201-06VIOFailure to conduct emergency drills and emergency training ClosedNone
Discussed50-059/1998-201-02IFIFollow-up on the licensee's evaluation of the need for formalwritten guidance to ensure that any facility change would bedone under 10 CFR 50.59 or license amendment as requiredby TS.LIST OF ACRONYMS USEDADAMSAgencywide Documents Access and Management SystemAGNAerojet General Nucleonics
CFRCode of Federal RegulationsE-PlanEmergency PlanEHSDEnvironmental Health and Safety Department
-2-HPHealth PhysicsIFIInspector Follow-up ItemIPInspection Procedure
LFMLaboratory Facilities M anagerMREMmilliremNRCNuclear Regulatory CommissionOSLDOptically Stimulated Luminescence Dosimeter
RSReactor Supervisor
RSBReactor Safety BoardSROSenior Reactor OperatorTSTechnical Specifications
URIUnresolved Item
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Latest revision as of 08:46, 18 September 2019

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