ML071370234
| ML071370234 | |
| Person / Time | |
|---|---|
| Site: | Rhode Island Atomic Energy Commission |
| Issue date: | 05/22/2007 |
| From: | Michael Case NRC/NRR/ADRA/DPR |
| To: | Tehan T State of RI, Atomic Energy Comm, Nuclear Science Ctr |
| Michael Case, NRR, 301-415-1004 | |
| References | |
| IR-07-201 | |
| Download: ML071370234 (22) | |
See also: IR 05000193/2007201
Text
May 22, 2007
Dr. T. Tehan, Director
Rhode Island Nuclear Science Center
Rhode Island Atomic Energy Commission
16 Reactor Road
Narragansett, RI 02882-1165
SUBJECT: RHODE ISLAND NUCLEAR SCIENCE CENTER - NRC ROUTINE INSPECTION
REPORT NO. 50-193/2007-201
Dear Dr. Tehan:
This letter refers to the inspection conducted on April 24-26, 2007, at the Rhode Island Nuclear
Science Center Research Reactor facility. The inspection included a review of activities
authorized for your facility. The enclosed report presents the results of this inspection.
This inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions in your license.
Within these areas, the inspection consisted of a 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 a Severity Level IV
violation of NRC requirements occurred. The violation was evaluated in accordance with the
NRC Enforcement Policy included on the NRCs Web site. The violation is cited in the enclosed
Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the
subject inspection report. The violation is of concern because it indicates a failure to follow
written operating procedures.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure(s), and your response, if you choose to provide one, will be made available
electronically for public inspection in the NRC Public Document Room or from the NRCs
document system (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/readingrm/adams.html. To the extent possible, your response should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the Public without redaction.
T. Tehan -2-
Should you have any questions concerning this inspection, please contact Mr. Kevin M. Witt at
301-415-4075.
Sincerely,
/RA by Jennifer M. Golder for Michael Case/
Michael J. Case, Division Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-193
License No. R-95
Enclosures:
1. Notice of Violation
2. NRC Inspection Report No. 50-193/2007-201
cc w/encl. Please see next page
Rhode Island Atomic Energy Commission Docket No. 50-193
cc:
Governor Donald Carcieri
State House Room 115
Providence, RI 02903
Dr. Stephen Mecca, Chairman
Rhode Island Atomic Energy Commission
Providence College
Department of Engineering-Physics Systems
River Avenue
Providence, RI 02859
Dr. Harry Knickle, Chairman
Nuclear and Radiation Safety Committee
University of Rhode Island
College of Engineering
112 Crawford Hall
Kingston, RI 02881
Dr. Andrew Kadak
253 Rumstick Road
Barrington, RI 02806
Dr. Bahram Nassersharif
Dean of Engineering
University of Rhode Island
102 Bliss Hall
Kingston, RI 20881
Dr. Peter Gromet
Department of Geological Sciences
Brown University
Providence, RI 02912
Dr. Alfred L. Allen
425 Laphan Farm Road
Pascoag, RI 02859
Mr. Jack Ferruolo, Supervising Radiological Health Specialist
Office of Occupational and Radiological Health
Rhode Island Department of Health
3 Capitol Cannon, Room 206
Providence, RI 02908-5097
Test, Research, and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
T. Tehan -2-
May 22, 2007
Should you have any questions concerning this inspection, please contact Mr. Kevin M. Witt at
301-415-4075.
Sincerely,
/RA by Jennifer M. Golder for Michael Case/
Michael J. Case, Division Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-193
License No. R-95
Enclosures:
1. Notice of Violation
2. NRC Inspection Report No. 50-193/2007-201
cc w/encl. Please see next page
DISTRIBUTION:
PUBLIC PRT r/f RidsNrrDprPrta RidsNrrDprPrtb
RidsNrrDpr RidsOeMailCenter RidsOgcMailCenter BDavis (cover letter only)(O5-A4)
ACCESSION NO.: ML071370234 TEMPLATE #: NRR-106
OFFICE PRTB PRTB:LA PRTB:BC DPR:DD
NAME KWitt EHylton JEads MCase
DATE 05/17/2007 05/17/2007 05/21/2007 05 / 22 /2007
OFFICIAL RECORD COPY
NOTICE OF VIOLATION
Rhode Island Atomic Energy Commission Docket No. 50-193
Rhode Island Nuclear Science Center License No. R-95
During an NRC inspection conducted on April 24-26, 2007, a violation of NRC requirements
was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Technical Specification 4.8 states, Experiments shall be reviewed, approved, and properly
installed and operational in accordance with written operating procedures. Operating
Procedure 12, Use of Pneumatic Irradiation Facilities, states, The authorization is provided by
the Assistant Director before the irradiations begin when he signs the irradiation request form.
Contrary to the above, on January 30, 2007, four experimental samples were irradiated in the
reactor pneumatic irradiation experimental facility that were not reviewed and approved in
accordance with the written operating procedures.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, the Rhode Island Atomic Energy Commission is
hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 and a copy to the
NRC Inspector of the facility that is the subject of this Notice, 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: (1) the reason for the violation, or, if
contested, the basis for disputing the violation or severity level, (2) the corrective steps that
have been taken and the results achieved, (3) the corrective steps that will be taken to avoid
further violations, and (4) the date when full compliance will be achieved. Your response may
reference or include previous docketed correspondence, 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.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Your response will be made available electronically for public inspection in the NRC Public
Document Room or from the NRCs document system (ADAMS), accessible from the NRC
Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, it
should not 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 your
Enclosure 1
-2-
response that deletes such information. If you request withholding of such material, you must
specifically 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 will
create 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 working
days.
Dated this 22 of May 2007
/RA by Jennifer M. Golder for Michael Case/
Michael J. Case, Division Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-193
License No: R-95
Report No: 50-193/2007-201
Licensee: Rhode Island Atomic Energy Commission
Facility: Rhode Island Nuclear Science Center
Location: Narragansett, Rhode Island
Dates: April 24-26, 2007
Inspector: Kevin M. Witt
Approved by: Michael J. Case, Division Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Enclosure 2
EXECUTIVE SUMMARY
Rhode Island Atomic Energy Commission
Rhode Island Nuclear Science Center Reactor
Inspection Report No. 50-193/2007-201
The primary focus of this routine, announced inspection included onsite review of selected
aspects of the licensee's Class I research and test reactor safety programs including:
organizational and staffing, effluent and environmental monitoring, experiments, design
changes, committees, audits and reviews, procedures, radiation protection, and transportation
activities.
The licensee's programs were acceptably directed toward the protection of public health and
safety, and in compliance with NRC requirements.
Organization and Staffing
! The licensees organization and staffing and assignment of responsibilities remained in
compliance with the requirements specified in Technical Specification Section 6.
Effluent and Environmental Monitoring
! Effluent monitoring satisfied license and regulatory requirements and releases were
within the regulatory limits.
Experiments
! The approval and control of experiments generally met Technical Specification and
applicable regulatory requirements. One violation was noted for failure to properly
review and approve experiment samples in accordance with written operating
procedures.
Design Changes
! Based on the records reviewed, the inspector determined that the licensee's design
change program was being implemented as required.
Committees, Audits, and Reviews
! The Nuclear and Radiation Safety Committee acceptably completed the review,
oversight, and audit functions required by Technical Specification Section 6.4.
Procedures
! The procedural review, revision, and implementation program satisfied Technical
Specification requirements.
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Radiation Protection
! Surveys were being completed and documented as required.
! Postings met regulatory requirements.
! Personnel dosimetry was being worn and recorded doses were within the NRCs
regulatory limits.
! Radiation monitoring equipment was being maintained and calibrated as required.
! The Radiation Protection Program satisfied regulatory requirements.
! The radiation protection training program was being administered as required.
Transportation
! No radioactive material shipments had been made under the auspices of the reactor
license within the past year.
REPORT DETAILS
Summary of Plant Status
The licensees nuclear science center reactor, licensed to operate at a maximum steady-state
thermal power of two megawatts (2 MW), continues to be operated in support of operator
training, surveillance, and utilization involving neutron activation analysis. During the inspection
the reactor was operated at two megawatts for an operator licensing examination. The reactor
was also operated on Tuesday and Thursday at full power to conduct sample irradiations.
1. Organization and Staffing
a. Inspection Scope (Inspection Procedure [IP] 69006)
The inspector reviewed the following to verify compliance with the staffing
requirements in Technical Specification (TS) Sections 6.1, 6.2 and 6.3:
- staff qualifications and management responsibilities
- staffing requirements for the safe operation of the reactor
- selected portions of the operations logbooks for the past twelve months
- Rhode Island Nuclear Science Center (RINSC) organizational structure and
staffing
- Rhode Island Atomic Energy Commission (RIAEC) meeting minutes, dated
November 6, 2006 and April 5, 2007
- RINSC Operating Procedures, Section 1, General Considerations, original
version - not revised to date
- RINSC Annual Report for July 1, 2005 through June 30, 2006
- TS for the RINSC, Amendment No. 29, dated December 28, 2004
b. Observations and Findings
The organizational structure and functions of the RINSC had not functionally changed
since the last inspection (refer to NRC Inspection Report No. 50-193/2006-204). The
licensees current operational organization and assignment of responsibilities, as
reported in the latest Annual Report, were consistent with those specified in the TS Sections 6.1, 6.2 and 6.3. All positions were filled with qualified personnel and a
review of the applicable records verified that staffing was as required by TS Section 6.1 and the licensees procedures. There have been no changes in the staffing since
the last inspection. The inspector noted that the staffing at the facility was acceptable
to support the ongoing activities. During the inspection, the NRC conducted a
licensing examination for one Senior Reactor Operator and one Reactor Operator. A
separate report will be sent to the licensee and the candidates summarizing the results
of the examination.
c. Conclusions
The licensees organization and staffing and assignment of responsibilities remained
in compliance with the requirements specified in TS Section 6.
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2. Effluent and Environmental Monitoring
a. Inspection Scope (IP 69004)
The inspector reviewed the following to verify compliance with the requirements of 10
CFR Part 20 and TS Sections 3.7.2, 4.7, and 6.8.4:
- the licensees environmental monitoring program
- counting and analysis records associated with airborne releases
- Completed Stack Monitor Air Particulate Detector Efficiency Check Forms, dated
July 27 and October 13, 2006
- Completed Stack Monitor Channel Test Forms, dated July 27 and October 13,
2006
- Completed RINSC Forms NSC-13, Stack Gas Monitor - Argon-41 Calibration
Factor Calculation Form, dated July 31 and October 17, 2006
- Radioassay Report of RINSC Retention Tank Water Prior to Sewer Discharge,
RINSC Form NSC-09, dated September 19, 2006
- Completed RINSC Forms NSC-3d, Weekly Gross Radioactivity Record for
Primary Water, dated from January 4, 2006 to present
- Quarterly isotopic analyses of primary coolant water samples, dated from
January 4, 2006 to present
- Weekly isotopic analyses of secondary coolant water samples, dated from
January 4, 2006 to present
- Monthly environmental dosimetry records for January 1, 2006 to present
- Comply calculations for gaseous effluents for the period July 1, 2005 to June 30,
2006, dated October 24, 2006
- RINSC Radiation Safety Office SOP 201, External Monitoring, Revision (Rev.)
0, dated March 23, 2000
- RINSC Annual Report for July 1, 2005 through June 30, 2006
b. Observations and Findings
The licensee ensures compliance with NRC regulations for environmental monitoring
by ensuring that all doses at the site boundary are less than the dose limits specified
in 10 CFR 20.1301. Several Optically Stimulated Luminescence Dosimeter (OSLD)
badges are strategically placed in several locations around the perimeter of the
reactor bay and outside of the building. Records for 2006 indicate radiation exposures
that are below the applicable requirements. The licensee also monitored primary and
secondary coolant radioactivity levels on a weekly basis. No abnormal readings were
discovered. The inspector also reviewed the licensees records for disposal of liquid
radioactive waste. One disposal of 600 gallons of liquid waste was disposed of to the
sanitary sewer system. The inspector verified that the monitoring of the disposal was
conducted in accordance with the applicable requirements.
To demonstrate compliance with the annual dose constraints of 10 CFR 20.1101(d),
the licensee calculated the amount of Argon-41 produced by experiments and the
operation of the reactor through measurement of gaseous exhaust. The results
indicated that the releases were well within 10 CFR Part 20 Appendix B, Table 2
-3-
concentrations, and TS limits. The highest dose calculated that could be received as
a result of gaseous emissions from reactor operations was less than 2.0 millirem
(mrem) per year. These doses were well below the limit set in 10 CFR 20.1101(d) of
10 mrem per year. The licensee has stated that the levels measured outside of the
facility are within the regulatory requirements.
c. Conclusions
Effluent monitoring satisfied license and regulatory requirements and releases were
within the regulatory limits.
3. Experiments
a. Inspection Scope (IP 69005)
The inspector reviewed selected aspects of the following in order to verify that
experiments were being conducted consistent with TS Sections 3.1, 3.8 and 4.8:
- potential hazards identification
- experimental administrative controls and precautions
- RINSC Operations Log Books No. 54, dated from December 6, 2005 to present
- Nuclear and Radiation Safety Committee (NRSC) meeting minutes dated
October 30 and December 14, 2006
- NRSC Draft meeting minutes dated March 8, 2007
- NRSC Charter, Rev. 0, dated November 14, 2005
- RINSC Operating Procedures, Section 1, General Considerations, original
version - not revised to date
- RINSC Operating Procedures, Section 8, Operations at Power and Adjustments
in Power Level, latest revision dated January 26, 1995
- RINSC Operating Procedures, Section 12, Use of Pneumatic Irradiation
Facilities, original version, - not revised to date
- RINSC Operating Procedures, Appendix P, Incore Irradiations, Rev. 0, dated
August 2, 2006
- Form NSC-7a, Neutron Irradiation Request Form - Short Irradiation, latest
revision dated September 1994
- Form NSC-7b, Pneumatic System Long Irradiation Request Form, latest revision
dated September 1994
- Form NSC-8, Gamma Irradiation Request Form, latest revision dated February
1994
- Form NSC-11, Shift Record Data Sheet, Rev. 2, dated March 28, 2003 -
associated with RINSC Operating Procedures, Section 8
- Form NSC-18, RINSC Reactor Operations Data, Rev. 0, dated March 28, 2003 -
associated with RINSC Operating Procedures, Section 8
- Form NSC-70, RINSC Irradiation Sample Tracking Summary Form, latest
revision dated September 1994
- Completed Forms NSC-7a, Neutron Irradiation Request Form [1-15 minute
irradiations], Rev. 0, dated from December 5, 2006 to present
-4-
- Completed Form NSC-73, RINSC Facility Use Request Form - Proposal entitled,
Sterilization of Sediments with Gamma Irradiation, dated June 15, 2006
- RINSC Annual Report for July 1, 2005 through June 30, 2006
b. Observations and Findings
One of the experiments routinely conducted at the RINSC is the irradiation of various
materials for the purpose of neutron activation analysis. The most frequently used
experimental facilities are the pneumatic irradiation facility and the in-core devices.
Samples that have been irradiated at RINSC include materials such as biological
tissues, geological samples, and various other materials. The SRO and HP approves
all routine samples to be irradiated in accordance with the TS limitations for each
sample to be irradiated in the core. No new experiments had been initiated, reviewed,
or approved since the previous inspection at the facility. If any new experiments were
to be initiated, they would be reviewed and approved by the NRSC. The inspector
confirmed that most of the experiments conducted were in accordance with TS limits
and procedural requirements. The inspector also verified that all of the experiment
authorizations were reviewed on an annual basis.
While conducting a review of the experiment sample irradiations conducted using the
pneumatic irradiation facility, the inspector noted that the review and approval forms
for several experiment samples could not be located. The licensees procedure for
reviewing and approving experiment samples is documented on form NSC-7a. The
purpose of this particular experiment was to provide a proof of principle. These
irradiations were conducted under the experiment authorization for general
irradiations. A total of four samples of geological material were irradiated in the
reactor on January 30, 2007, at a power level of 2 MW. The licensee noted that the
TS requirements for experiment conditions were met although the inspector could not
find any record indicating that a review and approval was completed before the
samples were irradiated. Some mitigating factors in the safety significance of this
issue include the mass of materials was much lower than what would normally be
used in an experimental sample, and this event was an isolated incident of which the
inspector did not note any other similar instances during this inspection.
TS 4.8 states, Experiments shall be reviewed, approved, and properly installed and
operational in accordance with written operating procedures. RINSC Operating
Procedure 12 §12.1 states, The authorization is provided by the Assistant Director
before the irradiations begin when he signs the irradiation request form. Contrary to
this requirement, the licensee irradiated four experiment samples without properly
completing the record of experiment review and approval in accordance with the
written operating procedure. The inspector communicated to the licensee the
importance of following the established procedures for review and approval of an
experiment. The licensee was informed that failure to review and approve
experiments in accordance with written operating procedures was an apparent
violation (VIO) of TS 4.8 (VIO 50-193/2007-201-01).
The inspector observed the licensee conduct operations for an experiment utilizing the
pneumatic irradiation facility on April 24, 2007. All of the procedures required for
loading and extracting the samples were strictly followed and the personnel
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conducting the operation did so in a safe and knowledgeable manner. The inspector
verified that all of the checks conducted were in compliance with TS required values
and parameters.
c. Conclusions
The approval and control of experiments generally met TS and applicable regulatory
requirements. One violation was noted for failure to properly review and approve
experiment samples in accordance with written operating procedures.
4. Design Changes
a. Inspection Scope (IP 69007)
In order to verify that any modifications to the facility were consistent with
10 CFR 50.59, the inspector reviewed selected aspects of:
- facility configuration documents
- proposed facility design changes for the past two years
- NRSC meeting minutes dated October 30 and December 14, 2006
- NRSC Draft meeting minutes dated March 8, 2007
- safety reviews and audits conducted by the committees and noted in the
respective committee and subcommittee meetings minutes
- NRSC Charter, Rev. 0, dated November 14, 2005
- RINSC Operating Procedures, Section 1, General Considerations, original
version - not revised to date
- RINSC Annual Report for July 1, 2005 through June 30, 2006
b. Observations and Findings
Through review of applicable records and interviews with licensee personnel, the
inspector determined that no significant changes requiring prior NRC approval had
been completed at the facility since the last inspection. The inspector verified that
administrative controls were in place that required the appropriate review and approval
of all changes prior to implementation. The Assistant Director for Reactor Operations
and the Reactor Supervisor normally determine whether change authorizations need
to be reviewed by the NRSC based on the complexity of the project and the relation to
the safety of the reactor. Letters describing facility changes are completed to inform
operations personnel of operating information and to document RINSC activities which
are not recorded in the operating log book. The inspector noted that 10 CFR 50.59
reviews and approvals conducted by the NRSC were focused on safety and met the
applicable TS and procedural requirements.
c. Conclusions
Based on the records reviewed, the inspector determined that the licensee's design
change program was being implemented as required.
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5. Committees, Audits, and Reviews
a. Inspection Scope (IP 69007)
In order to verify that the licensee had established and conducted reviews and audits
as required in TS Section 6.4 the inspector reviewed selected aspects of:
- Radiation Safety Records Review Form
- NRSC meeting minutes dated October 30 and December 14, 2006
- NRSC draft meeting minutes dated March 8, 2007
- safety reviews and audits conducted by the committees and noted in the
respective committee and subcommittee meetings minutes
- NRSC Charter, Rev. 0, dated November 14, 2005
- RINSC Operating Procedures, Section 1, General Considerations, original
version - not revised to date
- RINSC Annual Report for July 1, 2005 through June 30, 2006
b. Observations and Findings
The licensee has established the NRSC to review operations to assure that the facility
is operated in a manner consistent with public safety and within the terms of the facility
license as required by TS 6.4.1. A charter is established in licensee procedures for
the NRSC and the inspector verified that the NRSC is following all aspects of the
charter. The NRSC had meetings more frequently than required and a quorum was
always present as required. Review of the minutes indicated the NRSC provided
guidance, direction and oversight, and ensured suitable use of the reactor. The
minutes provided an acceptable record of appropriate review functions and safety
oversight of reactor operations.
The inspector noted that the NRSC charter had been revised to change the voting
eligibility of several committee members. The change removed the voting privileges
from all of the RINSC staff on the NRSC, including the Director, Assistant Director,
and Radiation Safety Officer. TS 6.4.4 states, A quorum of the NRSC shall consist of
not less than four (4) members and shall include the Radiation Safety Officer or
designee, the Director or the Assistant Director for Operations and the Chairman or
designee. The inspector noted that if all of the RINSC staff members did not have
voting privileges, it is possible for the chairman or designee to be the only voting
member during a committee meeting. ANSI/ANS-15.1-1990, The Development of
Technical Specifications for Research Reactors, states, there shall be a minimum of
three persons for review. The inspector communicated to the licensee the need for a
reliable and effective oversight committee with at least three voting members. The
licensee committed to fix the NRSC written charter before the next inspection to
require three NRSC voting members to be present for a NRSC meeting quorum. This
issue will be considered by the NRC as an Inspection Follow-up Item (IFI) and will be
reviewed during the next inspection at the facility (IFI 50-193/2007-201-02).
Audits required by TS Sections 6.2.4 and 6.2.5 were performed by NRSC members
and met the applicable requirements. The audits appeared to be acceptable. The
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inspector noted that the safety reviews and audits, and the associated findings, were
acceptably detailed and that the RINSC staff were supportive of the audits. During
review of the audits, the inspector noted that the licensee immediately corrected any
minor issues. The audits did not identify any issues related to the safe operation of
the RINSC.
c. Conclusions
The NRSC acceptably completed the review, oversight, and audit functions required
by TS Section 6.4.
6. Procedures
a. Inspection Scope (IP 69008)
To verify that facility procedures were being reviewed, revised, and implemented as
required by TS Section 6.5, the inspector reviewed selected aspects of:
- NRSC meeting minutes dated October 30 and December 14, 2006
- NRSC draft meeting minutes dated March 8, 2007
- NRSC Charter, Rev. 0, dated November 14, 2005
- RINSC Operating Procedures, Section 1, General Considerations, original
version - not revised to date
- RINSC Operating Procedures, Appendix Y, Facility Access for Visitors, latest
revision dated August 2, 2006
- RINSC Radiation Safety Office SOP 100, Standard Operating Procedures, Rev.
0, dated March 23, 2000
- RINSC Annual Report for July 1, 2005 through June 30, 2006
b. Observations and Findings
Procedures had been formulated for the safe, routine operation of the reactor.
Records showed that procedures for potential malfunctions (e.g., radioactive releases
and contaminations, and abnormal events) had also been developed and were
available to be implemented as required. The inspector noted that procedural
changes were being reviewed and approved by the NRSC as required by TS.
Training of personnel on procedures and changes was acceptable. Through
observation of various activities at the facility, including reactor operation and sample
handling, the inspector determined that licensee personnel conducted activities in
accordance with applicable procedures. The inspector observed the completion of a
reactor start-up, routine operation, and shut-down. It was noted that the required
checks, verifications, and actions were completed in accordance with the applicable
procedure.
c. Conclusions
The procedural review, revision, and implementation program satisfied TS
requirements.
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7. Radiation Protection Program
a. Inspection Scope (IP 69012)
The inspector reviewed the following to verify compliance with 10 CFR Parts 19 and
20, and the requirements outlined in TS Table 3.2 and Sections 3.7, 4.2, and 4.7:
- radiological signs and posting in various areas of the facility
- facility and equipment during tours
- organization and staffing
- radiation protection training records
- instrument calibration records
- RINSC Radiation Safety Office SOP 101, Radiation Safety Training, Rev. 0,
dated March 23, 2000
- RINSC Radiation Safety Office SOP 110, Radiation Protection Audits, Rev. 0,
dated March 23, 2000
- RINSC Radiation Safety Office SOP 201, External Monitoring, Rev. 0, dated
March 23, 2000
- RINSC Radiation Safety Office SOP 202, Bioassay, Rev. 0, dated March 23,
2000
0, dated March 23, 2000
- RINSC Radiation Safety Office SOP 204, Skin Exposures, Rev. 1, dated
April 29, 2002
- RINSC Radiation Safety Office SOP 220, Pocket Dosimeter Calibration, Rev. 0,
dated March 28, 2003
- RINSC Radiation Safety Office SOP 300, Routine Surveys, Rev. 1, dated
February 10, 2004
- RINSC Radiation Safety Office SOP 801, Instrument Calibration, Rev. 0, dated
November 6, 2000
- RINSC Radiation Safety Office SOP 802, Pocket Dosimeter Calibration, Rev. 0,
dated November 6, 2000
- facility weekly, monthly, quarterly, and other periodic contamination and area
radiation surveys from 2006 to present
- Quarterly dosimetry records for staff and researchers for January 1, 2006 to
present
- Survey Program Summary Data for January 1, 2006 to present
- RINSC Visitor Dosimetry Logbook
- calibration records for the Area Radiation Monitors, the Continuous Air Monitor
(CAM), and the Water Monitor from 2004 to present
- RINSC Survey Instrument Calibration Reports, dated from January 1, 2006 to
present
- Completed RINSC Forms NSC-12, Reactor Main Floor Particulate Air Monitor
Panel Meter Channel Test, dated July 28 and October 17, 2006
- Completed Main Floor Air Particulate Monitor Detector Calibration Forms, dated
July 27 and October 17, 2006
- RINSC Radiation Protection Special Audit, dated January 29-31, 2007
- Rhode Island Nuclear Science Center Radiation Safety Guide (RSG), Rev. 0
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b. Observations and Findings
(1) Surveys
The inspector reviewed weekly radiation and contamination surveys of the reactor
building, which were conducted by radiation safety personnel. The results were
documented on the appropriate forms, evaluated as required, and corrective
actions taken when readings or results exceeded set action levels. The number
and location of survey points was adequate to characterize the radiological
conditions. Surveys by the radiation safety personnel were conducted in
accordance with the appropriate procedure and logged on the appropriate forms.
The licensee has a tracking program for ensuring the surveys are completed in
the appropriate time frame. The inspector verified that the Radiation Safety
Officer (RSO) reviews all of the survey records. No abnormal readings were
discovered.
(2) Postings and Notices
The inspector reviewed the postings required by 10 CFR Part 19 at the entrances
to various controlled areas including the Reactor Bay, and radioactive material
storage areas. The postings were acceptable and indicated the radiation and
contamination hazards present. The facilitys radioactive material storage areas
were found to be properly posted. No unmarked radioactive material was found
in the facility.
(3) Dosimetry
The licensee used a National Voluntary Laboratory Accreditation Program-
accredited vendor to process personnel dosimetry. Through direct observation,
the inspector determined that dosimetry was used in an acceptable manner by
facility personnel. For visitors to the facility, a direct read pocket dosimeter is
issued to individuals for general tours. Records indicate that no abnormal
readings were obtained.
An examination of the records for the inspection period showed that all exposures
were well within NRC limits and within licensee action levels. All of the staff and
researchers associated with the facility wear OSLD badges and minimal doses
were recorded for 2006 through present. The licensee investigates any dosimetry
readings that indicate a monthly exposure above typical levels for a reactor staff
member. The as low as reasonably achievable (ALARA) goal specified in the
RSG is to keep deep dose exposures to less than 500 mrem per year and the
licensee consistently meets this goal.
(4) Radiation Monitoring Equipment
The calibration of portable survey meters and friskers was completed by radiation
safety personnel at the calibration lab while fixed radiation detectors, the CAM
and stack monitor were calibrated at the detector location. The calibration
records of portable survey meters, friskers, fixed radiation detectors, and air
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monitoring equipment in use at the facility were reviewed. Calibration frequency
met the requirements established in the applicable procedures while records were
being maintained as required. These systems had been calibrated semi-annually
as required by procedure. The daily set point verifications for the monitoring
equipment were completed as required. CAM filters were changed and analyzed
monthly as required. No activity above the lower limit of detection was detected
on the air filters. The inspector reviewed the licensees tracking system for
ensuring the instrument calibrations are completed on time and found it to be
useful.
During the inspection, the inspector visited the calibration range located in the
basement of the laboratory building. The radiation safety personnel described the
equipment in the facility for the inspector. The calibration records reviewed were
thorough and were completed using the appropriate techniques and according to
procedure. The inspector observed that proper precautions are always used to
maintain doses ALARA.
(5) Radiation Protection Program
The licensees RSG provides the licensees policy on the safe use of radioactive
materials around the reactor facility. The ALARA program provides guidance for
keeping doses as low as reasonably achievable and is consistent with the
guidance in 10 CFR Part 20. The inspector verified that the radiation protection
program was being reviewed annually as required by 10 CFR 20.1101(c). No
safety related issues were identified in the review of the program. The NRSC
reviews radiation protection documents during the NRSC meetings, and the RSO
has provided an additional audit of the overall implementation of the Radiation
Protection Program.
The RSG requires that all personnel who work with radioactive materials receive
training in radiation protection, policies, procedures, requirements, at the facilities
prior to having unescorted access at the facility. The radiation safety personnel is
responsible for conducting the training and all of the training is typically conducted
with the RSO. A test is administered at the end of the training to verify that the
individuals understood the material presented. The training covered the topics
required to be taught in 10 CFR Part 19 and the review of training materials and
tests indicated that the staff was instructed on the appropriate subjects.
(6) Facility Tour
The inspector toured the reactor facility, the radiation detector calibration room
and accompanying facilities. Control of radioactive material and control of access
to radiation and high radiation areas were observed to be acceptable. The
postings and signs for these areas were appropriate. Licensee personnel
followed the indicated precautions for access to controlled areas.
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c. Conclusions
The inspector determined that: (1) surveys were being completed and documented as
required, (2) postings met regulatory requirements (3) personnel dosimetry was being
worn and recorded doses were within the NRCs regulatory limits, (4) radiation
monitoring equipment was being maintained and calibrated as required, (5) the
radiation protection program satisfied regulatory requirements, and 6) the radiation
protection training program was being administered as required.
8. Transportation Activities
a. Inspection Scope (IP 86740)
To verify compliance with regulatory and procedural requirements for transferring or
shipping licensed radioactive material, the inspector reviewed the following:
C selected records of various types of radioactive material shipments
C RINSC Radiation Safety Office SOP 501, Radioactive Waste Packaging, Rev. 0,
dated November 6, 2000
C RINSC Radiation Safety Office SOP 512, BioPAL Wastes, Rev. 1, dated
March 26, 2004
b. Observations and Findings
Through records review and discussions with licensee personnel, the inspector
determined that the licensee had not shipped any radioactive material since the
previous inspection in this area.
c. Conclusions
No radioactive material shipments had been made under the auspices of the reactor
license during the past year.
9. Exit Interview
The inspector presented the inspection results to licensee management at the
conclusion of the inspection on April 26, 2007. The inspector described the areas
inspected and discussed in detail the inspection observations. No dissenting
comments were received from the licensee. The licensee acknowledged the findings
presented and did not identify as proprietary any of the material provided to or
reviewed by the inspector during the inspection.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
H. Bicehouse, Radiation Safety Officer and Assistant Director for Reactor Safety
J. Davis, Reactor Supervisor
M. Damato, Health Physics Technician and Reactor Operator Trainee
D. Johnson, Health Physicist
B. MacGregor, Reactor Operator and Facility Engineer
M. Middleton, Assistant Director for Reactor Operations
T. Tehan, Director, Rhode Island Nuclear Science Center
INSPECTION PROCEDURES USED
IP 69004 Class 1 Research and Test Reactor Effluent and Environmental Monitoring
IP 69005 Class 1 Research and Test Reactor Experiments
IP 69006 Class 1 Research and Test Reactors Organization, Operations, and Maintenance
Activities
IP 69007 Class 1 Research and Test Reactor Review and Audit and Design Change
Functions
IP 69008 Class 1 Research and Test Reactor Procedures
IP 69012 Class 1 Research and Test Reactors Radiation Protection
IP 86740 Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-193/2007-201-01 VIO Failure to review and approve experiments in accordance with
written operating procedures
50-193/2007-201-02 IFI Follow-up to verify the licensee changes the NRSC written
charter to require three outside voting members to be present
for a NRSC meeting quorum
Closed
None
LIST OF ACRONYMS USED
ADAMS Agencywide Documents Access and Management System
ALARA As Low As Reasonably Achievable
CAM Continuous Air Monitor
CFR Code of Federal Regulations
IFI Inspection Follow-up Item
IP Inspection Procedure
mrem millirem
MW Megawatt
NRC Nuclear Regulatory Commission
NRSC Nuclear and Radiation Safety Committee
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Rev. Revision
RIAEC Rhode Island Atomic Energy Commission
RINSC Rhode Island Nuclear Science Center
RSG Radiation Safety Guide
RSO Radiation Safety Officer
TS Technical Specifications
VIO Violation