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==SUBJECT:==
TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM, NUCLEAR SCIENCE CENTER - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-128/2018-201


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==Dear Dr. McDeavitt:==
From December 10-13, 2018, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection, at your Nuclear Science Center TRIGA Research Reactor Facility. The enclosed report documents the inspection results, which were discussed on December 13, 2018, with you and Mr. Jerry Newhouse, Associate Director.


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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.
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Code of Federal Regulations********
The inspector reviewed selected procedures and records, observed various activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.
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In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842 or by electronic mail at Craig.Bassett@nrc.gov.
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Sincerely,
*
/RA/
*****
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-128 License No. R-83 Enclosure:
As stated cc: See next page


Code of Federal Regulations
Texas A&M University  Docket No. 50-128 cc:
Mayor, City of College Station Mr. Scott Miller, Manager P.O. Box Drawer 9960  Reactor Operations College Station, TX 77840-3575 Texas A&M University Texas Engineering Experiment Station Governors Budget and  1095 Nuclear Science Road, MS 3575 Policy Office  College Station, Texas 77843 P.O. Box 12428 Austin, TX 78711-2428  Test, Research and Training Reactor Newsletter Dr. Dimitris C. Lagoudas, Deputy Director P.O. Box 118300 Texas Engineering Experiment Station University of Florida Texas A&M University System Gainesville, FL 32611 241 Zachry Engineering Center College Station, Texas 77843 State Energy Conservation Office Comptroller of Public Accounts Mr. Jerry Newhouse, Associate Director P.O. Box 13528 Nuclear Science Center  Austin, TX 78711-3528 Texas A&M University Texas Engineering Experiment Station 1095 Nuclear Science Road, MS 3575 College Station, Texas 77843 Radiation Program Officer Bureau of Radiation Control Dept. of State Health Services Division for Regulatory Services 1100 West 49th Street, MC 2828 Austin, TX 78756-9347 Technical Advisor Office of Permitting, Remediation &
Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087
 
ML18361A656 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME CBasett  NParker  AMendiola DATE 1/9/2019 1/8/2019 1/17/2019
 
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-128 License No.: R-83 Report No. 50-128/2018-201 Licensee: Texas Engineering Experiment Station/Texas A&M University System Facility: Nuclear Science Center Location: College Station, Texas Dates: December 10-13, 2018 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure
 
EXECUTIVE SUMMARY Texas A&M University Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center NRC Inspection Report No. 50-128/2018-201 The primary focus of this routine, announced inspection included onsite review of selected aspects of the Texas A&M University (the licensees) Class II research and test reactor safety programs including: (1) organization and staffing; (2) procedures; (3) health physics; (4) design changes; (5) committees, audits, and reviews, and (6) transportation of radioactive materials since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees safety program was acceptably directed toward the protection of public health and safety. No violations or deviations were identified.
 
Organization and Staffing Organization and staffing were consistent with the requirements outlined in Section 6 of the technical specifications (TSs).
 
Procedures Facility procedural review, revision, control, and implementation satisfied TS requirements.
 
Health Physics
* Periodic surveys were completed and documented as required by procedure.
 
* Postings and signs met regulatory requirements.
 
* Personnel dosimetry was being worn as required and recorded doses were within the NRC regulatory limits.
 
* Radiation survey and monitoring equipment was generally being maintained and calibrated as required.
 
* The facility Radiation Protection and as low as reasonably achievable (ALARA) programs satisfied regulatory requirements.
 
* Radiation protection training was acceptable.
 
* Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
 
Design Changes
* The licensees design change program was being implemented in accordance with the regulations.
 
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Committees, Audits and Review
* The Reactor Safety Board (RSB) completed the review, oversight, and audit functions required by TS Section 6.2.
 
Transportation
* Radioactive material was being shipped in accordance with the applicable regulations.
 
* The training of the staff members responsible for shipping the radioactive material met U.S.
 
Department of Transportation (DOT) requirements.
 
-3-
 
REPORT DETAILS Summary of Plant Status The Texas Engineering Experiment Station (TEES) Texas A&M University System (the licensee) Nuclear Science Center (NSC) TRIGA research reactor, licensed to operate at a maximum steady-state thermal power of 1 megawatt, continued to be operated in support of operator training, surveillance, research, and utilization involving neutron activation analysis.
 
During the inspection the reactor was operated each day at varying power levels up to 900 kilowatts to conduct sample irradiations and research. It should be noted that the licensee was in the process of refurbishing all the office and laboratory spaces in the administrative portion of the reactor building and constructing an addition onto the administrative portion as well.
 
1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)
The inspector reviewed selected aspects of the following regarding the licensees organization and staffing to ensure that the requirements specified in TS Section 6.1 were being met:
Appendix A to Facility Operating License Number (No.) R-83, Docket No. 50-128, Amendment No. 18, Technical Specifications, dated August 31, 2016 Organization and staffing for the Texas A&M NSC during operation of the research reactor Administrative controls and management responsibilities specified in the facility TSs TEES, Texas A&M University System, 2016 Annual Report, submitted to the NRC in April 2017 TEES, Texas A&M University System, 2017 Annual Report, submitted to the NRC in April 2018 NSC Standard Operating Procedure (SOP), Chapter I, Policy and Administrative Procedures, Section I-C b. Observations and Findings The structure and functions of the licensees organization at the TEES/Texas A&M University System NSC reactor facility had not changed since the last inspection (refer to NRC Inspection Report No. 50-128/2017-202). It was noted that the person who had been the radiation safety manager/radiation safety officer (RSO) for the facility had found other employment. Because of that fact, the facility Associate Director was temporarily filling the RSO position. A person, who was designated as the Safety Coordinator, was being trained to assume the Radiation Safety Manager position. The licensees organizational structure and assignment of responsibilities, as reported in the annual reports, were consistent with those specified in TS Section 6.1. All positions reviewed were filled with qualified personnel. Review of records verified that management responsibilities were administered as required.
 
-4-
 
c. Conclusion The licensees organization and staffing were in compliance with the requirements specified in TS Section 6.1 2. Procedures a. Inspection Scope (IP 69001, Section 02.03)
The inspector reviewed the following to ensure that the requirements of TS Section 6.4 were being met concerning written procedures:
* NSC SOP Chapter I, Policy and Administrative Procedures, Sections I-B, I-C, I-D, I-E, I-F, I-G, and I-H
* RSB Meeting Minutes for 2016, 2017, and to date in 2018 (RSB meeting Nos. 179 - 186)
* TEES, Texas A&M University System, 2016 and 2017 Annual Reports b. Observations and Findings Oversight and review of procedure implementation was provided by licensee management and the RSB. The procedures in use at the facility appeared to be generally acceptable although some had not been updated in several years. It was noted that minor procedure changes were accomplished using a procedure change notice (PCN) system. The PCN listed the procedure steps affected, the current wording, the new wording, and the reason for the change. These types of changes could be approved by NSC management, the RSO, and the Facility Director. All substantive changes were required to be approved by the Facility Director and the RSB. The inspector verified that this was the current practice.
 
During the inspection, the inspector observed various licensed activities and work evolutions. These were conducted in accordance with the applicable procedures. No problems were noted.
 
The inspector did note that the health physics procedure were in the process of being reviewed, revised, and reformatted. This should result in improved procedures that are of standard format and more easily understood and followed.
 
The licensee was informed that the completion of this effort will be tracked by the NRC as an Inspector Follow-up Item (IFI) and will be reviewed at a future date (50-128/2018-201-01).
 
c. Conclusion Procedure review, revision, adherence, and implementation satisfied TS requirements.
 
-5-
 
3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)
The inspector reviewed selected aspects of the following to verify compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigation, and 10 CFR Part 20, Standards for Protection against Radiation, and TS Sections 3.5, 4.5, 5.4, and 6.6:
* Personnel dosimetry records for 2016, 2017, and 2018
* RSB meeting minutes for 2016 through the present
* RSB completed audits and reviews from 2016 through the present
* Radiation Safety Program, TEES/NSC Revision (Rev.) 0, dated April 2018
* NSC Reactor (NSCR) Form 844, Radiation Work Permit (RWP), Rev. 0, (form dated April 30, 2010) for 2017 and 2018
* Effluent monitoring program results for 2017 and 2018
* Various gamma spectrum analyses for 2017 and 2018
* Counting and analysis records associated with airborne releases for the past 2 years
* Counting and analysis records associated with liquid releases for the past 2 years documented on NCSR Form 819b, Radioactive Liquid Waste Sewer Disposal Record (latest form revision dated September 8, 2008)
* TEES, Texas A&M University System, 2016 and 2017 Annual Reports, which included the effluent monitoring program results for those periods
* Various SOP Section VII Procedures including:
- Procedure A-1, Radiation Protection Program, Rev. 3;
- Procedure A-4, Health Physics Administration, Rev. 4;
- Procedure A-6, ALARA, Rev. 0;
- Procedure B-6, Quarterly Facility Air Monitoring Test, Rev. 4;
- Procedure B-7, Area Radiation Monitor, Rev. 3;
- Procedure B-8, Stack Particulate Monitor, Rev. 4;
- Procedure B-9, Stack Gas (Ar-41) Monitor, Rev. 4;
- Procedure B-9A, Stack Gas (Xe-125) Monitor, Rev. 1;
- Procedure B-12, Fission Product Monitor, Rev. 4;
- Procedure B-13, Portable Survey Instrument Calibration and Operability Check, Rev. 4;
- Procedure B-14, Personnel Dosimeters, Rev. 7;
- Procedure B-16, Calibration of Gas Flow Proportional Counter, Rev. 4;
- Procedure B-18, Environmental Surveillance Program, Rev. 2;
- Procedure C-9, Radioactive Liquid Waste Disposal, Rev. 4;
- Procedure C-11, Site Survey, Rev. 2;
- Procedure C-12, Facility Radiation Survey, Rev. 4;
- Procedure C-14, Facility Contamination Surveys, Rev. 4; and,
- Procedure E-1, Radiation Monitoring Devices and Exposure Control Guides, Rev. 0-6-
 
b. Observations and Findings (1) Surveys The inspector reviewed selected monthly and other periodic routine contamination and radiation surveys from 2016 through the present.
 
Non-routine surveys were also completed for emergent work and prior to the disposal of items that were no longer needed or of areas that were no longer used. The surveys had been completed by facility staff members as required, and were documented as required by procedures. If contamination was detected, the item or area was decontaminated and then resurveyed to demonstrate that they were radiologically free of contamination. No problems were noted.
 
(2) Postings and Notices During tours of the facility, the inspector observed that caution signs, postings, and barriers in the controlled areas were acceptable for the hazards involving radiation, high radiation, and contaminated areas and were posted as required by 10 CFR Part 20, Subpart J. Radiological signs were typically posted at the entrances to controlled areas. The facilitys radioactive material storage areas were noted to be properly posted. Through observations of licensee staff, the inspector confirmed that personnel complied with the signs, postings, and controls.
 
Copies of current notices to workers were posted in various areas in the facility, including the bulletin board in the hallway by each entrance to the facility and in the hallway of the Upper Research Level in the Reactor Building. Other postings also characterized the industrial hygiene hazards that were present in the areas as well.
 
(3) Dosimetry The inspector determined that the licensee used optically-stimulated luminescent (OSL) dosimeters for whole body monitoring of beta and gamma radiation exposure with an additional component to measure fast/thermal neutron radiation. The licensee used thermoluminescent dosimeter (TLD) finger rings for extremity monitoring. The inspector confirmed that dosimetry was being issued to staff and visitors as required procedure. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor.
 
Through direct observation the inspector determined that dosimetry was acceptably used by facility personnel. Also, exit frisking practices were in accordance with facility radiation protection requirements. An examination of the OSL and TLD results indicating exposures to radiation at the facility for the past 2 years showed that the highest occupational doses, as well as doses to the public, were within 10 CFR Part 20 limitations.
 
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The inspector also verified that NRC Form 5 equivalent forms had been prepared for those facility personnel who had received a dose greater than 100 millirem (mrem) during 2017. All those who should have received a notification of their 2017 exposure totals had been issued the appropriate form.
 
(4) Calibration and Maintenance of Radiation Monitoring Equipment (a) Calibration of Portable Survey Meters Calibration and periodic checks of the portable survey meters and fixed radiation monitors were performed by the licensees staff, Texas A&M calibration facilities, or certified contractors, depending upon the type of meter or monitor it was. The inspector confirmed that the licensees calibration procedures and frequencies satisfied TS Section 4.5 and 10 CFR 20.1501, General, paragraph (b) requirements.
 
The inspector reviewed selected NSC instrument calibrations completed during 2016, 2017, and to date in 2018, and confirmed that the calibration of the portable survey meters in use had been completed as required. All instruments checked had current calibrations appropriate for the types and energies of radiation they were used to detect and/or measure except for the one used to detect neutrons. The licensee was aware that that meter was out of calibration and was making arrangements to have it calibrated as required.
 
(b) Calibration of Area Radiation Monitors TS Section 4.5.1 requires that the area radiation monitoring system (ARM) and the FAM [facility air monitoring] system shall be calibrated annually, shall be channel tested weekly, and shall be channel checked prior to reactor operation.
 
Calibrations of the permanently installed ARMs and the FAM system monitors were generally completed in accordance with requirements specified in TS Section 4.5 and the applicable procedures. However, it was noted that some of the ARMs had not been calibrated since October 20, 2017.
 
The licensee was aware of this situation and indicated that the affected ARMs were to be calibrated during the week of December 17, 2018. The licensee was informed that failure to calibrate the ARMS annually as required by TS Section 4.5 was an apparent violation of the TSs. However, because of the disruption of the current construction work in progress and the resultant problems caused by relocation of all the various health physics files containing the calibration schedules, the issue of the annual calibration of the ARMs would be considered an-8-
 
Unresolved Item (URI) which would reviewed during the next inspection (50-128/2018-201-02).
 
(5) Radiation Protection Training The inspector reviewed documentation of the radiation protection training given to new employees by the NSC RSO entitled, Radiation Safety Training: General Awareness. The course consisted of a PowerPoint presentation given to the new personnel. The content of the course was found to be acceptable and the training program satisfied the requirements in 10 CFR 19.12, Instructions to workers. Through a review of selected training records, the inspector verified that newly hired licensee personnel had received initial training as required. Biennial refresher training was also required for, and being provided to, staff members who had been at the facility for over 2 years.
 
(6) Radiation Protection Program and ALARA The licensees Radiation Protection and ALARA programs were established in various documents including: (1) Radiation Protection Program, TEES, NCS, (2) Procedure A-6, ALARA, and (3) other related health physics procedures. The programs had been reviewed and approved as required. The Radiation Protection and ALARA programs contained instructions concerning organization, security, radiation protection fundamentals, and personnel responsibilities. The ALARA program provided objectives for keeping doses as low as reasonably achievable, which were consistent with the guidance in 10 CFR Part 20.
 
The licensee reviewed the programs at least annually, as required by 10 CFR 20.1101, Radiation protection programs, paragraph (c). Review and oversight was provided by the RSO and the Safety Coordinator, as well as the RSB. It was also noted that the HP procedures were reviewed annually, as required by procedure.
 
(7) Radiation Work Permits The inspector reviewed the RWPs that had been generated and used during 2018. It was noted that the controls specified in the RWPs were acceptable and applicable for the type of work being done. The RWPs had been initiated, reviewed, and approved as required.
 
(8) Environmental Monitoring and Effluents On-site and off-site gamma radiation monitoring was completed using the reactor facility stack effluent monitor and area monitors, and various environmental monitoring OSL dosimeters. The licensee conducted the on-site monitoring while the Texas Department of Health Services provided environmental results using OSL dosimeters in the unrestricted areas surrounding the NSC. Data indicated that there were no measurable doses above regulatory limits.
 
-9-
 
The inspector determined that gaseous releases continued to be monitored as required, were calculated according to established protocol, and were generally acceptably documented in the annual reports. The airborne concentrations of the gaseous releases were well within the annual dose constraints of 10 CFR Part 20, Appendix B concentrations, and TS limits. COMPLY code calculations indicated an effective dose equivalent to the public of 5.1 E-5 mrem per year (mrem/yr) for 2016 and 8.9 E-5 mrem/yr for 2017.
 
The RSO reviewed and approved the liquid effluent releases after analyses were completed to verify that the releases met regulatory requirements for discharge. The inspector reviewed radioactive liquid effluent sewer release data which indicated that the total activity released was below regulatory limits. The 2016 annual dose to the public calculated from liquid effluent was 0.64 mrem and 1.36 mrem for 2017.
 
The principles of ALARA were acceptably implemented to minimize radioactive releases. Monitoring equipment was acceptably maintained and calibrated.
 
While reviewing the various data concerning effluent releases contained in the 2016 and 2017 Annual Reports, the inspector noted some problems. It was determined that some of the values reported for 2016, concerning liquid and gaseous effluent releases, were incorrect. When the licensee was informed of this they indicated that they would review the data and issue a corrected revision to the report as needed. The issue of providing corrected values for the 2016 Annual Report, and possibly the 2017 Annual Report, concerning effluent releases was identified as an IFI and will be reviewed during a future inspection (50-128/2018-201-03).
 
c. Conclusion The inspector determined that the Radiation Protection and ALARA programs, as implemented by the licensee, satisfied regulatory requirements because:
(1) surveys were completed and documented acceptably to permit evaluation of the radiation hazards present, (2) postings met regulatory requirements, (3) personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits, (4) radiation survey and monitoring equipment was being maintained and calibrated as required, (5) the Radiation Protection program satisfied regulatory requirements, (6) effluent monitoring satisfied TS and regulatory requirements and releases were reportedly within the specified regulatory limits, and (7) the environmental monitoring program was acceptable.
 
4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)
To determine whether modifications to the facility, if any, were consistent with 10 CFR 50.59, Changes, tests and experiments, the inspector reviewed:
  - 10 -
 
* RSB meeting minutes for 2016 through the present
* NSC SOP, Chapter I, Policy and Administrative Procedures, Sections I-B and I-H
* TEES, Texas A&M University System, 2016 and 2017 Annual Reports b. Observations and Findings The inspector determined that changes to certain procedures, structures, systems, or components, and experiments at the NSCR facility required a facility staff review followed by approval by the Facility Director and an RSB review and subsequent approval. It was evident from the review of the licensees experiment and modification authorization process involving reviews and approvals, that the process was focused on safety and met licensee program requirements. The inspector found that no facility changes had been processed since the last NRC inspection.
 
However, following a review of the licensees change procedure, it was evident that the procedure was not up-to-date. The procedure referred to unreviewed safety questions which was language used in a previous version of the regulations. Also, there were no provisions in the procedure for screening changes to determine whether or not they required a full safety evaluation to be conducted. When the licensee was informed of this apparent problem, they indicated that they had developed separate documents to conduct screenings of changes and then complete evaluations if the change under consideration did not screen out. Upon review, the inspector found that the screening and evaluation process did reflect current regulatory requirements.
 
Nevertheless, the inspector indicated that the screening and evaluation process should be formalized in a procedure. The licensee was informed that the revision and updating of their change procedure or the development of a new procedure to reflect their current process would be tracked by the NRC as an IFI and would be reviewed during a subsequent inspection (50-128/2018-201-04).
 
c. Conclusion The licensees design change program was being implemented as required.
 
5. Committees, Audits, and Reviews a. Inspection Scope (IP 69001, Section 02.09)
To verify that the licensee had established and conducted reviews and audits as required in TS Section 6.2, the inspector reviewed:
* RSB Charter dated July 2015
* Completed health physics audits and reviews from 2016 thru 2018
* RSB Meeting Minutes for 2016, 2017, and 2018 to date (RSB meeting Nos. 179 - 186)
  - 11 -
 
* NSC SOP Chapter I, Policy and Administrative Procedures, Sections I-B and I-H
* TEES, Texas A&M University System, 2016 and 2017 Annual Reports b. Observations and Findings The inspector reviewed minutes of the last eight RSB meetings. The minutes showed that the committee met at least annually as required by the TSs and that a quorum was present for each meeting. The topics considered during the meetings were appropriate and as stipulated in the TSs. It was noted that the current RSB Charter required the board to meet three times per year.
 
The TSs required that the RSB or a subcommittee thereof audit reactor operations and various other programs on an annual or biennial basis depending upon the program. The inspector reviewed the documentation and results of the audits that had been conducted by the RSB of the NSC health physics program from 2016 through the present. The inspector confirmed that an annual audit of the radiation protection program had been conducted per TS requirements.
 
c. Conclusion The RSB acceptably completed review, audit, and oversight functions required by TS Section 6.2.
 
6. Transportation a. Inspection Scope (IP 86740)
The inspector reviewed the following documents to determine compliance with NRC and DOT regulations governing the transport of radioactive material as specified in 10 CFR Parts 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, as well as 49 CFR Parts 171-178:
* Licenses of shipment recipients
* Training records of those qualified to ship radioactive material
* Selected records of various types of radioactive material shipments documented on various forms, including NSCR Form 514, 852, and 854
* Various SOP Section VII Procedures including:
- Procedure C-2, Radioactive Materials Control, Rev. 3;
- Procedure C-3, Radioactive Materials Released From the NSC License, Rev. 2;
- Procedure C-5, Radioactive Material Received, Rev. 3;
- Procedure C-10, Radioactive Material Handling, Rev. 2; and,
- Procedure C-7, Radioactive Solid Waste Sorting, Rev. 4 b. Observations and Findings The inspector reviewed records of selected shipments of radioactive material made during 2016, 2017, and to date in 2018. Through this review and
  - 12 -
 
discussions with licensee personnel, the inspector determined that the licensee had shipped various types of radioactive material since the previous inspection in this area. The records indicated that the radioisotope types and quantities involved were calculated and dose rates measured as required. The records also indicated that the shipping containers were appropriate and had been labeled as required. The radioactive material shipping records reviewed by the inspector had been completed and maintained as required by NRC and DOT regulations.
 
The inspector verified that the licensee was maintaining copies of consignees radioactive material possession licenses as required. If the current copy of the license was not available at NSC, the licensee was aware that they were required to contact the consignee and obtain a current copy before a shipment could be made.
 
In addition, the inspector verified that the licensee staff members assigned to complete and/or review the shipping paperwork were trained and that refresher training was being completed. It was noted that DOT requires shippers to take refresher training triennially.
 
c. Conclusion Radioactive material was being shipped in accordance with the applicable NRC and DOT regulations. The training of the staff members responsible for shipping the radioactive material met DOT requirements.
 
7. Follow-up on Previously Identified Items a. Inspection Scope (IP 92701)
The inspector reviewed the actions taken by the licensee to address a previously identified IFI.
 
b. Observation and Findings 50-128/2017-202-01 - IFI - Follow-up on the issue of the licensee using or installing new equipment to prevent unintentional scrams, i.e., using new magnets for the control rods and installing a new air handling system.
 
(CLOSED)
During an inspection in December 2017, the inspector reviewed the Scram Log which detailed the unintentional shutdowns or scrams that occurred at the facility during reactor operations. The inspector acknowledged that the issue of scrams at a research reactor was not a safety concern but it was an inconvenience for the licensee and hindered timely completion of some experiments. It was noted that several of the scrams each year were due to magnet failure. When the magnet(s) failed, a control rod would drop and cause an unintentional shutdown.
 
In discussing these issues with the licensee representatives, they indicated that the problem with the magnet failures was apparently due to the practice of trying to refurbish and reuse the same magnets and electronics after they had failed.
 
- 13 -
 
The corrective action was to stop that practice and replace the problem items with new equipment. There was also a problem with the air handling system.
 
The current system was made up of antiquated equipment and needed to be replaced. The corrective action for the air handling system was to purchase a new air handling system. The inspector reviewed the scrams issue during this inspection. The licensee had been able to locate a vendor that manufactured the type and quality of magnets that were needed for their application. After establishing a steady supply of magnets, the licensee now replaces those that appear to be about ready to fail through monitoring their electronic signals on the control console. This practice, along with the installation and acceptance of a new air handling system, has significantly reduced the number of magnet failures and unintentional scram problems. This issue is considered closed.
 
c. Conclusion One IFI was reviewed and closed.
 
8. Exit Interview The inspector presented the inspection results to Texas A&M NSC management at the conclusion of the inspection on December 13, 2018. The inspector described the areas inspected and discussed in detail the inspection observations. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.
 
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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel C. Macdonnell Reactor Supervisor Director, Nuclear Science Center S. Miller Reactor Operations Manager J. Newhouse Associate Director D. Rios  Radiation Safety Supervisor INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors IP 92701 Follow-up on Previously Identified Items ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-128/2018-201-01 IFI Follow-up on the licensees efforts to complete the revision, updating, and reformatting of their health physics procedures.
 
50-128/2018-201-02 URI Follow-up on the licensees failure to calibrate the ARMs annually and the actions to expeditiously correct the problem.
 
50-128/2018-201-03 IFI Follow-up on the issue of providing corrected values for the 2016, and possibly 2017, Annual Report concerning effluent releases.
 
50-128/2018-201-04 IFI Follow-up on the licensees progress in revising and updating their change procedure to reflect current provisions in the regulations or in developing a new procedure.
 
Closed 50-128/2017-202-01 IFI Follow-up on the issue of the licensee of installing new equipment to prevent unintentional scrams, i.e., using new magnets for the control rods and a new air handling system.
 
Attachment
 
LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable ARM Area Radiation Monitor DOT Department of Transportation FAM Facility Air Monitoring (system)
IFI Information Follow-up Item IP Inspection Procedure mr Millirem No. Number NSC Nuclear Science Center NSCR Nuclear Science Center Reactor NRC U.S. Nuclear Regulatory Commission OSL Optically-Stimulated Luminescent (dosimeter)
PCN Procedure Change Notice RSB Reactor Safety Board RSO Radiation Safety Officer RWP Radiation Work Permit SOP Standard Operating Procedure TEES Texas Engineering Experiment Station TLD Thermoluminescent Dosimeter TSs Technical Specifications URI Unresolved Item-2-
}}
}}

Latest revision as of 07:39, 20 October 2019

Texas Engineering Experiment Station/Texas A&M University System, Nuclear Science Center - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 50-128/2018-201 (Cover Letter/Enclosure)
ML18361A656
Person / Time
Site: 05000128
Issue date: 01/17/2019
From: Anthony Mendiola
Research and Test Reactors Oversight Projects Branch
To: Mcdeavitt S
Texas A&M Univ
Bassett C, NRR/DLP, 240-535-1842
References
IR 2018201
Download: ML18361A656 (20)


Text

ary 17, 2019

SUBJECT:

TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM, NUCLEAR SCIENCE CENTER - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-128/2018-201

Dear Dr. McDeavitt:

From December 10-13, 2018, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection, at your Nuclear Science Center TRIGA Research Reactor Facility. The enclosed report documents the inspection results, which were discussed on December 13, 2018, with you and Mr. Jerry Newhouse, Associate Director.

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 various activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-128 License No. R-83 Enclosure:

As stated cc: See next page

Texas A&M University Docket No. 50-128 cc:

Mayor, City of College Station Mr. Scott Miller, Manager P.O. Box Drawer 9960 Reactor Operations College Station, TX 77840-3575 Texas A&M University Texas Engineering Experiment Station Governors Budget and 1095 Nuclear Science Road, MS 3575 Policy Office College Station, Texas 77843 P.O. Box 12428 Austin, TX 78711-2428 Test, Research and Training Reactor Newsletter Dr. Dimitris C. Lagoudas, Deputy Director P.O. Box 118300 Texas Engineering Experiment Station University of Florida Texas A&M University System Gainesville, FL 32611 241 Zachry Engineering Center College Station, Texas 77843 State Energy Conservation Office Comptroller of Public Accounts Mr. Jerry Newhouse, Associate Director P.O. Box 13528 Nuclear Science Center Austin, TX 78711-3528 Texas A&M University Texas Engineering Experiment Station 1095 Nuclear Science Road, MS 3575 College Station, Texas 77843 Radiation Program Officer Bureau of Radiation Control Dept. of State Health Services Division for Regulatory Services 1100 West 49th Street, MC 2828 Austin, TX 78756-9347 Technical Advisor Office of Permitting, Remediation &

Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087

ML18361A656 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME CBasett NParker AMendiola DATE 1/9/2019 1/8/2019 1/17/2019

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-128 License No.: R-83 Report No. 50-128/2018-201 Licensee: Texas Engineering Experiment Station/Texas A&M University System Facility: Nuclear Science Center Location: College Station, Texas Dates: December 10-13, 2018 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Texas A&M University Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center NRC Inspection Report No. 50-128/2018-201 The primary focus of this routine, announced inspection included onsite review of selected aspects of the Texas A&M University (the licensees) Class II research and test reactor safety programs including: (1) organization and staffing; (2) procedures; (3) health physics; (4) design changes; (5) committees, audits, and reviews, and (6) transportation of radioactive materials since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees safety program was acceptably directed toward the protection of public health and safety. No violations or deviations were identified.

Organization and Staffing Organization and staffing were consistent with the requirements outlined in Section 6 of the technical specifications (TSs).

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

Health Physics

  • Periodic surveys were completed and documented as required by procedure.
  • Postings and signs met regulatory requirements.
  • Personnel dosimetry was being worn as required and recorded doses were within the NRC regulatory limits.
  • Radiation survey and monitoring equipment was generally being maintained and calibrated as required.
  • The facility Radiation Protection and as low as reasonably achievable (ALARA) programs satisfied regulatory requirements.
  • Radiation protection training was acceptable.
  • Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

Design Changes

  • The licensees design change program was being implemented in accordance with the regulations.

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Committees, Audits and Review

  • The Reactor Safety Board (RSB) completed the review, oversight, and audit functions required by TS Section 6.2.

Transportation

  • Radioactive material was being shipped in accordance with the applicable regulations.
  • The training of the staff members responsible for shipping the radioactive material met U.S.

Department of Transportation (DOT) requirements.

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REPORT DETAILS Summary of Plant Status The Texas Engineering Experiment Station (TEES) Texas A&M University System (the licensee) Nuclear Science Center (NSC) TRIGA research reactor, licensed to operate at a maximum steady-state thermal power of 1 megawatt, continued to be operated in support of operator training, surveillance, research, and utilization involving neutron activation analysis.

During the inspection the reactor was operated each day at varying power levels up to 900 kilowatts to conduct sample irradiations and research. It should be noted that the licensee was in the process of refurbishing all the office and laboratory spaces in the administrative portion of the reactor building and constructing an addition onto the administrative portion as well.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)

The inspector reviewed selected aspects of the following regarding the licensees organization and staffing to ensure that the requirements specified in TS Section 6.1 were being met:

Appendix A to Facility Operating License Number (No.) R-83, Docket No. 50-128, Amendment No. 18, Technical Specifications, dated August 31, 2016 Organization and staffing for the Texas A&M NSC during operation of the research reactor Administrative controls and management responsibilities specified in the facility TSs TEES, Texas A&M University System, 2016 Annual Report, submitted to the NRC in April 2017 TEES, Texas A&M University System, 2017 Annual Report, submitted to the NRC in April 2018 NSC Standard Operating Procedure (SOP), Chapter I, Policy and Administrative Procedures, Section I-C b. Observations and Findings The structure and functions of the licensees organization at the TEES/Texas A&M University System NSC reactor facility had not changed since the last inspection (refer to NRC Inspection Report No. 50-128/2017-202). It was noted that the person who had been the radiation safety manager/radiation safety officer (RSO) for the facility had found other employment. Because of that fact, the facility Associate Director was temporarily filling the RSO position. A person, who was designated as the Safety Coordinator, was being trained to assume the Radiation Safety Manager position. The licensees organizational structure and assignment of responsibilities, as reported in the annual reports, were consistent with those specified in TS Section 6.1. All positions reviewed were filled with qualified personnel. Review of records verified that management responsibilities were administered as required.

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c. Conclusion The licensees organization and staffing were in compliance with the requirements specified in TS Section 6.1 2. Procedures a. Inspection Scope (IP 69001, Section 02.03)

The inspector reviewed the following to ensure that the requirements of TS Section 6.4 were being met concerning written procedures:

  • NSC SOP Chapter I, Policy and Administrative Procedures, Sections I-B, I-C, I-D, I-E, I-F, I-G, and I-H
  • RSB Meeting Minutes for 2016, 2017, and to date in 2018 (RSB meeting Nos. 179 - 186)
  • TEES, Texas A&M University System, 2016 and 2017 Annual Reports b. Observations and Findings Oversight and review of procedure implementation was provided by licensee management and the RSB. The procedures in use at the facility appeared to be generally acceptable although some had not been updated in several years. It was noted that minor procedure changes were accomplished using a procedure change notice (PCN) system. The PCN listed the procedure steps affected, the current wording, the new wording, and the reason for the change. These types of changes could be approved by NSC management, the RSO, and the Facility Director. All substantive changes were required to be approved by the Facility Director and the RSB. The inspector verified that this was the current practice.

During the inspection, the inspector observed various licensed activities and work evolutions. These were conducted in accordance with the applicable procedures. No problems were noted.

The inspector did note that the health physics procedure were in the process of being reviewed, revised, and reformatted. This should result in improved procedures that are of standard format and more easily understood and followed.

The licensee was informed that the completion of this effort will be tracked by the NRC as an Inspector Follow-up Item (IFI) and will be reviewed at a future date (50-128/2018-201-01).

c. Conclusion Procedure review, revision, adherence, and implementation satisfied TS requirements.

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3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)

The inspector reviewed selected aspects of the following to verify compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigation, and 10 CFR Part 20, Standards for Protection against Radiation, and TS Sections 3.5, 4.5, 5.4, and 6.6:

  • Personnel dosimetry records for 2016, 2017, and 2018
  • RSB meeting minutes for 2016 through the present
  • RSB completed audits and reviews from 2016 through the present
  • Radiation Safety Program, TEES/NSC Revision (Rev.) 0, dated April 2018
  • NSC Reactor (NSCR) Form 844, Radiation Work Permit (RWP), Rev. 0, (form dated April 30, 2010) for 2017 and 2018
  • Effluent monitoring program results for 2017 and 2018
  • Various gamma spectrum analyses for 2017 and 2018
  • Counting and analysis records associated with airborne releases for the past 2 years
  • Counting and analysis records associated with liquid releases for the past 2 years documented on NCSR Form 819b, Radioactive Liquid Waste Sewer Disposal Record (latest form revision dated September 8, 2008)
  • TEES, Texas A&M University System, 2016 and 2017 Annual Reports, which included the effluent monitoring program results for those periods
  • Various SOP Section VII Procedures including:

- Procedure A-1, Radiation Protection Program, Rev. 3;

- Procedure A-4, Health Physics Administration, Rev. 4;

- Procedure A-6, ALARA, Rev. 0;

- Procedure B-6, Quarterly Facility Air Monitoring Test, Rev. 4;

- Procedure B-7, Area Radiation Monitor, Rev. 3;

- Procedure B-8, Stack Particulate Monitor, Rev. 4;

- Procedure B-9, Stack Gas (Ar-41) Monitor, Rev. 4;

- Procedure B-9A, Stack Gas (Xe-125) Monitor, Rev. 1;

- Procedure B-12, Fission Product Monitor, Rev. 4;

- Procedure B-13, Portable Survey Instrument Calibration and Operability Check, Rev. 4;

- Procedure B-14, Personnel Dosimeters, Rev. 7;

- Procedure B-16, Calibration of Gas Flow Proportional Counter, Rev. 4;

- Procedure B-18, Environmental Surveillance Program, Rev. 2;

- Procedure C-9, Radioactive Liquid Waste Disposal, Rev. 4;

- Procedure C-11, Site Survey, Rev. 2;

- Procedure C-12, Facility Radiation Survey, Rev. 4;

- Procedure C-14, Facility Contamination Surveys, Rev. 4; and,

- Procedure E-1, Radiation Monitoring Devices and Exposure Control Guides, Rev. 0-6-

b. Observations and Findings (1) Surveys The inspector reviewed selected monthly and other periodic routine contamination and radiation surveys from 2016 through the present.

Non-routine surveys were also completed for emergent work and prior to the disposal of items that were no longer needed or of areas that were no longer used. The surveys had been completed by facility staff members as required, and were documented as required by procedures. If contamination was detected, the item or area was decontaminated and then resurveyed to demonstrate that they were radiologically free of contamination. No problems were noted.

(2) Postings and Notices During tours of the facility, the inspector observed that caution signs, postings, and barriers in the controlled areas were acceptable for the hazards involving radiation, high radiation, and contaminated areas and were posted as required by 10 CFR Part 20, Subpart J. Radiological signs were typically posted at the entrances to controlled areas. The facilitys radioactive material storage areas were noted to be properly posted. Through observations of licensee staff, the inspector confirmed that personnel complied with the signs, postings, and controls.

Copies of current notices to workers were posted in various areas in the facility, including the bulletin board in the hallway by each entrance to the facility and in the hallway of the Upper Research Level in the Reactor Building. Other postings also characterized the industrial hygiene hazards that were present in the areas as well.

(3) Dosimetry The inspector determined that the licensee used optically-stimulated luminescent (OSL) dosimeters for whole body monitoring of beta and gamma radiation exposure with an additional component to measure fast/thermal neutron radiation. The licensee used thermoluminescent dosimeter (TLD) finger rings for extremity monitoring. The inspector confirmed that dosimetry was being issued to staff and visitors as required procedure. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor.

Through direct observation the inspector determined that dosimetry was acceptably used by facility personnel. Also, exit frisking practices were in accordance with facility radiation protection requirements. An examination of the OSL and TLD results indicating exposures to radiation at the facility for the past 2 years showed that the highest occupational doses, as well as doses to the public, were within 10 CFR Part 20 limitations.

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The inspector also verified that NRC Form 5 equivalent forms had been prepared for those facility personnel who had received a dose greater than 100 millirem (mrem) during 2017. All those who should have received a notification of their 2017 exposure totals had been issued the appropriate form.

(4) Calibration and Maintenance of Radiation Monitoring Equipment (a) Calibration of Portable Survey Meters Calibration and periodic checks of the portable survey meters and fixed radiation monitors were performed by the licensees staff, Texas A&M calibration facilities, or certified contractors, depending upon the type of meter or monitor it was. The inspector confirmed that the licensees calibration procedures and frequencies satisfied TS Section 4.5 and 10 CFR 20.1501, General, paragraph (b) requirements.

The inspector reviewed selected NSC instrument calibrations completed during 2016, 2017, and to date in 2018, and confirmed that the calibration of the portable survey meters in use had been completed as required. All instruments checked had current calibrations appropriate for the types and energies of radiation they were used to detect and/or measure except for the one used to detect neutrons. The licensee was aware that that meter was out of calibration and was making arrangements to have it calibrated as required.

(b) Calibration of Area Radiation Monitors TS Section 4.5.1 requires that the area radiation monitoring system (ARM) and the FAM [facility air monitoring] system shall be calibrated annually, shall be channel tested weekly, and shall be channel checked prior to reactor operation.

Calibrations of the permanently installed ARMs and the FAM system monitors were generally completed in accordance with requirements specified in TS Section 4.5 and the applicable procedures. However, it was noted that some of the ARMs had not been calibrated since October 20, 2017.

The licensee was aware of this situation and indicated that the affected ARMs were to be calibrated during the week of December 17, 2018. The licensee was informed that failure to calibrate the ARMS annually as required by TS Section 4.5 was an apparent violation of the TSs. However, because of the disruption of the current construction work in progress and the resultant problems caused by relocation of all the various health physics files containing the calibration schedules, the issue of the annual calibration of the ARMs would be considered an-8-

Unresolved Item (URI) which would reviewed during the next inspection (50-128/2018-201-02).

(5) Radiation Protection Training The inspector reviewed documentation of the radiation protection training given to new employees by the NSC RSO entitled, Radiation Safety Training: General Awareness. The course consisted of a PowerPoint presentation given to the new personnel. The content of the course was found to be acceptable and the training program satisfied the requirements in 10 CFR 19.12, Instructions to workers. Through a review of selected training records, the inspector verified that newly hired licensee personnel had received initial training as required. Biennial refresher training was also required for, and being provided to, staff members who had been at the facility for over 2 years.

(6) Radiation Protection Program and ALARA The licensees Radiation Protection and ALARA programs were established in various documents including: (1) Radiation Protection Program, TEES, NCS, (2) Procedure A-6, ALARA, and (3) other related health physics procedures. The programs had been reviewed and approved as required. The Radiation Protection and ALARA programs contained instructions concerning organization, security, radiation protection fundamentals, and personnel responsibilities. The ALARA program provided objectives for keeping doses as low as reasonably achievable, which were consistent with the guidance in 10 CFR Part 20.

The licensee reviewed the programs at least annually, as required by 10 CFR 20.1101, Radiation protection programs, paragraph (c). Review and oversight was provided by the RSO and the Safety Coordinator, as well as the RSB. It was also noted that the HP procedures were reviewed annually, as required by procedure.

(7) Radiation Work Permits The inspector reviewed the RWPs that had been generated and used during 2018. It was noted that the controls specified in the RWPs were acceptable and applicable for the type of work being done. The RWPs had been initiated, reviewed, and approved as required.

(8) Environmental Monitoring and Effluents On-site and off-site gamma radiation monitoring was completed using the reactor facility stack effluent monitor and area monitors, and various environmental monitoring OSL dosimeters. The licensee conducted the on-site monitoring while the Texas Department of Health Services provided environmental results using OSL dosimeters in the unrestricted areas surrounding the NSC. Data indicated that there were no measurable doses above regulatory limits.

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The inspector determined that gaseous releases continued to be monitored as required, were calculated according to established protocol, and were generally acceptably documented in the annual reports. The airborne concentrations of the gaseous releases were well within the annual dose constraints of 10 CFR Part 20, Appendix B concentrations, and TS limits. COMPLY code calculations indicated an effective dose equivalent to the public of 5.1 E-5 mrem per year (mrem/yr) for 2016 and 8.9 E-5 mrem/yr for 2017.

The RSO reviewed and approved the liquid effluent releases after analyses were completed to verify that the releases met regulatory requirements for discharge. The inspector reviewed radioactive liquid effluent sewer release data which indicated that the total activity released was below regulatory limits. The 2016 annual dose to the public calculated from liquid effluent was 0.64 mrem and 1.36 mrem for 2017.

The principles of ALARA were acceptably implemented to minimize radioactive releases. Monitoring equipment was acceptably maintained and calibrated.

While reviewing the various data concerning effluent releases contained in the 2016 and 2017 Annual Reports, the inspector noted some problems. It was determined that some of the values reported for 2016, concerning liquid and gaseous effluent releases, were incorrect. When the licensee was informed of this they indicated that they would review the data and issue a corrected revision to the report as needed. The issue of providing corrected values for the 2016 Annual Report, and possibly the 2017 Annual Report, concerning effluent releases was identified as an IFI and will be reviewed during a future inspection (50-128/2018-201-03).

c. Conclusion The inspector determined that the Radiation Protection and ALARA programs, as implemented by the licensee, satisfied regulatory requirements because:

(1) surveys were completed and documented acceptably to permit evaluation of the radiation hazards present, (2) postings met regulatory requirements, (3) personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits, (4) radiation survey and monitoring equipment was being maintained and calibrated as required, (5) the Radiation Protection program satisfied regulatory requirements, (6) effluent monitoring satisfied TS and regulatory requirements and releases were reportedly within the specified regulatory limits, and (7) the environmental monitoring program was acceptable.

4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)

To determine whether modifications to the facility, if any, were consistent with 10 CFR 50.59, Changes, tests and experiments, the inspector reviewed:

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  • RSB meeting minutes for 2016 through the present
  • NSC SOP, Chapter I, Policy and Administrative Procedures, Sections I-B and I-H
  • TEES, Texas A&M University System, 2016 and 2017 Annual Reports b. Observations and Findings The inspector determined that changes to certain procedures, structures, systems, or components, and experiments at the NSCR facility required a facility staff review followed by approval by the Facility Director and an RSB review and subsequent approval. It was evident from the review of the licensees experiment and modification authorization process involving reviews and approvals, that the process was focused on safety and met licensee program requirements. The inspector found that no facility changes had been processed since the last NRC inspection.

However, following a review of the licensees change procedure, it was evident that the procedure was not up-to-date. The procedure referred to unreviewed safety questions which was language used in a previous version of the regulations. Also, there were no provisions in the procedure for screening changes to determine whether or not they required a full safety evaluation to be conducted. When the licensee was informed of this apparent problem, they indicated that they had developed separate documents to conduct screenings of changes and then complete evaluations if the change under consideration did not screen out. Upon review, the inspector found that the screening and evaluation process did reflect current regulatory requirements.

Nevertheless, the inspector indicated that the screening and evaluation process should be formalized in a procedure. The licensee was informed that the revision and updating of their change procedure or the development of a new procedure to reflect their current process would be tracked by the NRC as an IFI and would be reviewed during a subsequent inspection (50-128/2018-201-04).

c. Conclusion The licensees design change program was being implemented as required.

5. Committees, Audits, and Reviews a. Inspection Scope (IP 69001, Section 02.09)

To verify that the licensee had established and conducted reviews and audits as required in TS Section 6.2, the inspector reviewed:

  • RSB Charter dated July 2015
  • Completed health physics audits and reviews from 2016 thru 2018
  • RSB Meeting Minutes for 2016, 2017, and 2018 to date (RSB meeting Nos. 179 - 186)

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  • NSC SOP Chapter I, Policy and Administrative Procedures, Sections I-B and I-H
  • TEES, Texas A&M University System, 2016 and 2017 Annual Reports b. Observations and Findings The inspector reviewed minutes of the last eight RSB meetings. The minutes showed that the committee met at least annually as required by the TSs and that a quorum was present for each meeting. The topics considered during the meetings were appropriate and as stipulated in the TSs. It was noted that the current RSB Charter required the board to meet three times per year.

The TSs required that the RSB or a subcommittee thereof audit reactor operations and various other programs on an annual or biennial basis depending upon the program. The inspector reviewed the documentation and results of the audits that had been conducted by the RSB of the NSC health physics program from 2016 through the present. The inspector confirmed that an annual audit of the radiation protection program had been conducted per TS requirements.

c. Conclusion The RSB acceptably completed review, audit, and oversight functions required by TS Section 6.2.

6. Transportation a. Inspection Scope (IP 86740)

The inspector reviewed the following documents to determine compliance with NRC and DOT regulations governing the transport of radioactive material as specified in 10 CFR Parts 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, as well as 49 CFR Parts 171-178:

  • Licenses of shipment recipients
  • Training records of those qualified to ship radioactive material
  • Selected records of various types of radioactive material shipments documented on various forms, including NSCR Form 514, 852, and 854
  • Various SOP Section VII Procedures including:

- Procedure C-2, Radioactive Materials Control, Rev. 3;

- Procedure C-3, Radioactive Materials Released From the NSC License, Rev. 2;

- Procedure C-5, Radioactive Material Received, Rev. 3;

- Procedure C-10, Radioactive Material Handling, Rev. 2; and,

- Procedure C-7, Radioactive Solid Waste Sorting, Rev. 4 b. Observations and Findings The inspector reviewed records of selected shipments of radioactive material made during 2016, 2017, and to date in 2018. Through this review and

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discussions with licensee personnel, the inspector determined that the licensee had shipped various types of radioactive material since the previous inspection in this area. The records indicated that the radioisotope types and quantities involved were calculated and dose rates measured as required. The records also indicated that the shipping containers were appropriate and had been labeled as required. The radioactive material shipping records reviewed by the inspector had been completed and maintained as required by NRC and DOT regulations.

The inspector verified that the licensee was maintaining copies of consignees radioactive material possession licenses as required. If the current copy of the license was not available at NSC, the licensee was aware that they were required to contact the consignee and obtain a current copy before a shipment could be made.

In addition, the inspector verified that the licensee staff members assigned to complete and/or review the shipping paperwork were trained and that refresher training was being completed. It was noted that DOT requires shippers to take refresher training triennially.

c. Conclusion Radioactive material was being shipped in accordance with the applicable NRC and DOT regulations. The training of the staff members responsible for shipping the radioactive material met DOT requirements.

7. Follow-up on Previously Identified Items a. Inspection Scope (IP 92701)

The inspector reviewed the actions taken by the licensee to address a previously identified IFI.

b. Observation and Findings 50-128/2017-202-01 - IFI - Follow-up on the issue of the licensee using or installing new equipment to prevent unintentional scrams, i.e., using new magnets for the control rods and installing a new air handling system.

(CLOSED)

During an inspection in December 2017, the inspector reviewed the Scram Log which detailed the unintentional shutdowns or scrams that occurred at the facility during reactor operations. The inspector acknowledged that the issue of scrams at a research reactor was not a safety concern but it was an inconvenience for the licensee and hindered timely completion of some experiments. It was noted that several of the scrams each year were due to magnet failure. When the magnet(s) failed, a control rod would drop and cause an unintentional shutdown.

In discussing these issues with the licensee representatives, they indicated that the problem with the magnet failures was apparently due to the practice of trying to refurbish and reuse the same magnets and electronics after they had failed.

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The corrective action was to stop that practice and replace the problem items with new equipment. There was also a problem with the air handling system.

The current system was made up of antiquated equipment and needed to be replaced. The corrective action for the air handling system was to purchase a new air handling system. The inspector reviewed the scrams issue during this inspection. The licensee had been able to locate a vendor that manufactured the type and quality of magnets that were needed for their application. After establishing a steady supply of magnets, the licensee now replaces those that appear to be about ready to fail through monitoring their electronic signals on the control console. This practice, along with the installation and acceptance of a new air handling system, has significantly reduced the number of magnet failures and unintentional scram problems. This issue is considered closed.

c. Conclusion One IFI was reviewed and closed.

8. Exit Interview The inspector presented the inspection results to Texas A&M NSC management at the conclusion of the inspection on December 13, 2018. The inspector described the areas inspected and discussed in detail the inspection observations. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel C. Macdonnell Reactor Supervisor Director, Nuclear Science Center S. Miller Reactor Operations Manager J. Newhouse Associate Director D. Rios Radiation Safety Supervisor INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors IP 92701 Follow-up on Previously Identified Items ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-128/2018-201-01 IFI Follow-up on the licensees efforts to complete the revision, updating, and reformatting of their health physics procedures.

50-128/2018-201-02 URI Follow-up on the licensees failure to calibrate the ARMs annually and the actions to expeditiously correct the problem.

50-128/2018-201-03 IFI Follow-up on the issue of providing corrected values for the 2016, and possibly 2017, Annual Report concerning effluent releases.

50-128/2018-201-04 IFI Follow-up on the licensees progress in revising and updating their change procedure to reflect current provisions in the regulations or in developing a new procedure.

Closed 50-128/2017-202-01 IFI Follow-up on the issue of the licensee of installing new equipment to prevent unintentional scrams, i.e., using new magnets for the control rods and a new air handling system.

Attachment

LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable ARM Area Radiation Monitor DOT Department of Transportation FAM Facility Air Monitoring (system)

IFI Information Follow-up Item IP Inspection Procedure mr Millirem No. Number NSC Nuclear Science Center NSCR Nuclear Science Center Reactor NRC U.S. Nuclear Regulatory Commission OSL Optically-Stimulated Luminescent (dosimeter)

PCN Procedure Change Notice RSB Reactor Safety Board RSO Radiation Safety Officer RWP Radiation Work Permit SOP Standard Operating Procedure TEES Texas Engineering Experiment Station TLD Thermoluminescent Dosimeter TSs Technical Specifications URI Unresolved Item-2-