IR 05000059/1996001

Insp Rept 50-059/96-01 on 960930-1003 & 1024.Violations Noted.Major Areas Inspected:Maint,Engineering & Facility Support

ML20134G495
Person / Time
Site:	Texas A&M University
Issue date:	11/08/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20134G471	List: ML20134G469 ML20134G486 ML20134G495
References
50-059-96-01, 50-59-96-1, NUDOCS 9611130231
Download: ML20134G495 (23)

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-059 License No.: R-23 i i

l Report No.: 50-059/96-01 I

Licensee: Texas A&M University Facility: AGN-201 M Reactor Location: Zachry Engineering Center, Texas A&M University, College Station, Texas Dates: September 30 through October 3,1996, and October 24,1996 Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental information

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9611130231 961108 PDR 0 ADOCK 05000059 PDR

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-2-EXECUTIVE SUMMARY Texas A&M University AGN-201M Reactor Facility NRC Inspection Report 50-059/96-01 This routine, announced inspection reviewed the reactor operations, reactor maintenance, surveillance testing, experiments, reactor oversight, reporting, reactor operator requalification, radiation protection, emergency preparedness, and security program Operations

• Reactor operations were conducted well. No safety limits or limiting conditions for operation of the reactor were exceeded. The licensee's logs and records adequately documented reactor operations (Section 01.1).

• All Technical Specification surveillance requirements were properly performed

(Section 01.2).

• All reactor experiments were properly reviewed, authorized, and performed. The reactor experiments were satisfactorily documented in the reactor operations log (Section 01.3).

• The licensee's inventory and control of special nuclear material on site were properly maintained (Section 01.4).

• Operating procedures, maintenance procedures, and experiment procedures provided adequate guidance to ensure that reactor operations, surveillances, and experiments were conducted properly and consistently (Section 03.1).

• Excellent reactor operations logs and records were praperly maintained (Section 03.2).

• Annual operating reports for the reactor f acility met reporting requirements (Section 03.3).

• The senior reactor operators were knowledgeable of routine operating procedures and performed reactor operational manipulations properly and efficiently (Section 04).

• An excellent reactor operator requalification program was conducted as required (Section 05).

• The reactor f acility organizational structure and staffing and the Reactor Safety Board membership met requirements. All organizational positions were filled with qualified personnel. The reactor operational responsibilities were implemented as required (Section 06).

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The Reactor Safety Board met at least annually. However, the Reactor Safety i Board did not ensure that the required reviews and audits of the reactor facility )

j activities were performed. Quarterly audits were not conducted as required i j (Section 07).

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• A violation was identified involving the failure to perform required audits of reactor !

facility activities (Section 07).

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i Maintenance '

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i * Reactor maintenance activities were performed properly and in accordance with i approved procedures. The licensee's logs and records satisfactorily documented :

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reactor maintenance activities (Section M1). l l

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• There were no reactor design changes since the previous inspection (Section E2). ;

I Facility Sucoort i

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• Appropriate radiation protection practices were implemented. Minimal radiation I

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hazards were present with the reactor operated as observed. Radiation surveys met

- Technical Specification and regulatory requirements. Portable radiation survey ~

instruments assigned to the reactor facility were adequate and were calibrated 1

] properly (Section F.1).

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• A violation was identified involving the failure to perform annual reviews of the

, radiation protectior program (Section R1).

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• A good emergency preparedness program was maintained. Appropriate training i was provided to onsite and offsite emergency response personnel (Section P1).

• Generally, the approved physical security plan was properly implemented. The i Reactor Safety Board did not perform the required annual reviews of the physical

security plan (Section S1).

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j e A violation was identified involving the failure to perform annual reviews of the j physical security plan (Section S1).

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Report Details 1. Operations 01 Conduct of Operations 01.1 Reactor Operations Inspection Scope (40750)

Reactor operations logs and records were reviewed, and reactor operations were observed to determine compliance with reactor Operating License Conditions 2.C(1)

and 2.C(2) and the requirements in Technical Specifications 2.0 and Observations and Findinas The inspector observed the licensee start up and operate the reactor at 0.5 watts for approximately 30 minutes on October 2,1996, to observe operator activities and the operation of the reactor safety systems. The inspector noted that the reactor was operated approximately 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> during the 4 year period from June 1, 1992, through May 31,1996, for the purpose of laboratory teaching, reactor system testing, and reactor surveillance Based on the review of the reactor operations log, the inspector verified that between October 1992 and September 1996, that the licensee did not exceed a thermal power level of 5 watts as specified in reactor Operating License Condition 2.C(1).- The inspector verified that the reactor safety limits were not exceeded and were in compliance with Technical Specifications 2.1 and 2.2. The Technical Specification limiting conditions for operation of the reactor were reviewed. During the annual control rod reactivity worth determinations, the reactor shutdown margin and excess reactivity were verified to be within Technical Specification limits. The inspector verified that all of the required reactor control system instrument channels, safety circuits, and safety interlocks required by the Technical Specifications were tested and operable and were included as part of the reactor startup checklist which were completed prior to each startup of the reactor. The licensee's logs and records adequately documented reactor operation Conclusions Reactor operations were conducted well. No safety limits or limiting conditions for I operation of the reactor were exceeded. The licensee's logs and records adequately documented reactor operation I

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-5-01.2 Technical Specification Surveillance Reauirements inspection Scope (40750)

Reactor surveillance test results were reviewed to determine compliance with the requirements in Technical Specification Observations and Findinas The inspector verified that all required reactor surveillance tests were completed for 1993,1994, and 1995. The following Technical Specification required surveillance tests were verified to be completed according to approved maintenance procedures and at the required frequencie Comoletion Technical Soecification item Freauency Date 4.1.a Safety and Control Rod Annual 7/08/92 Reactivity Worth Determination 5/18/93 (Maintenance Procedure RCAL) 9/08/94 8/24/95 4.1.b Total Excess Reactivity and Annual 7/08/92 Shutdown Margin Determination 5/19/93 (Maintenance Procedure ROEX) 9/14/94 8/25/95 4.2.a Safety and Control Rod Scram Annual 7/01/92 Times Determination 5/18/93 (Maintenance Procedure RDTM) 9/08/94 8/31/95 Average Control Rod Reactivity Annual 6/30/92 Insertion Rate Determination 5/18/93 (Maintenance Procedure RITM) 9/08/94 8/28/95 4.2.b Safety and Control Rods and Biennial 3/12/91 Drives inspection 1/15/93 (Maintenance Procedure CRIS) 6/03/95

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4.2.d Channel Test of the Seismic Semiannual 6/05/92 )

Displacement Interlock 12/08/92

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(Maintenance Procedure EITL) 2/17/93 8/22/93 l 5/09/94 i 10/04/94 5/10/95 8/31/95 4.2.g Calibration of the Period, Annual 6/30/92 Count Rate, and Power Level 5/12/93 of the Measuring Channels 9/05/94 (Maintenance Procedures PD2M, 8/07/95 C1LT, C2LT, C2HT, and C3HT)

4.2.h Shield Tank Water Level Interlock Annual 6/30/92 (Maintenance Procedure WITL) 5/05/93 9/12/P I I

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Shield Water Temperature Interlock Annual 6/30/92 (Maintenance Procedure TITL) 5/19/93 9/14/94 8/29/95 4.3.b Shield Tank Visual Inspection Annual 6/30/92 (Maintenance Procedure SWTI) 5/05/93 9/12/94 8/28/95 4.4.a Portable Radiation Survey Annual 11/20/92 Instrument Calibrat%n 11/04/97, l (Maintenance Procec.ure RSIC) 12/08/94 !

12/20/95 4.4.c Radiation Survey of the Reactor Annual 7/16/92 Room, Reactor Control Room, and 5/27/93 Accelerator Room 9/06/94 (Maintenance Procedure RADS) 8/22/95 c. Conclusion All reactor surveillance tests were completed at the required frequencies, and the surveillance test results met Technical Specification requirement __a. , . aL,. .-. -

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01.3 Experiments Insoection Scoce (40750)

The program for control and conduct of the 10 approved reactor experiments including evaluations, authorizations, conduct, and documentation of experiments performed was reviewed to determine compliance with the requirements in Technical Specifications 3.3,6.6, and Observations and Findinas The inspector verified that each experiment procedure was reviewed and approved by the reactor supervisor, reactor administrator (head of the nuclear engineering department), and the chairman of the Reactor Safety Board as required by Technical Specifications, it was noted that all 10 reactor experiments were approved in January 1976 and that the licensee had not approved any new experiments for the

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reactor since that time.

l The reactor was used routinely as a research and instructional tool to suoport the requirements of several nuclear engineering courses and reactor operator training as well as performing preventive maintenance and operational surveillances required by the Technical Specifications. Experiments were performed in accordance with approved procedures under approved reactor conditions and were properly documented in the reactor operations lo Conclusion All reactor experiments were properly reviewed, authorized, and performed. The reactor experiments were satisfactorily documented in the reactor operations lo .4 License Conditions and Control and Accountability for Soecial Nuclear Material Inspection Scoce (85102)

License conditions for special nuclear material and the special nuclear material control and accountability program were reviewed. The storage and inventory of the licensee's special nuclear material were reviewed for compliance with the reactor Operating License R-23, Amendment 12, dated April 25,197 Observations and Findinas Reactor Operating License Condition 2.B(2) authorizes the possession of up to 700 grams of contained uranium-235, enriched to less than 20 percent in uranium

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dioxide embedded in radiation stabilized polyethylene, and up to 16 grams of plutonium-239 in the form of a sealed plutonium-beryllium neutron source, which i may be used for reactor startup. The inspector verified that the licensee possessed l

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a 1-curie plutonium-beryllium neutron startup source and that it was stored in the reactor tank for use in reactor startup. The inspector reviewed the licensee's inventory of the reactor fuelinstalled in the reactor. Based on the licensee's inventory, the reactor's fuel contained 666.5 grams of uranium-235, which was less than the 700 grams of uranium-235 allowed by the Reactor Operating Licens This uranium-235 was embedded in 26 fuel elements, two safety rods, and two control rods distributed in the reactor core. The inspector determined that there was no change in the quantity of reactor fuel since the previous NRC inspection conducted in October 199 Conclusion The licensee's inventory and control of special nuclear material on site were properly maintaine O3 Operations Procedures and Documentation 03.1 Procedures  ! inspection Scoce (40750)

The procedures listed in the attachment were reviewed to determine compliance with the requirements in Technical Specification Observations and Findinas The licensee had approved procedures, checklists, and data forms for safety-related and operational activities that included reactor startup, operation, and shutdown; reactor maintenance and surveillance testing; and calibration of reactor instrumentation. The inspector determined that the licensee had 9 approved operating procedures, 28 approved maintenance procedures for surveillance testing and calibration activities, and 10 approved experiment procedures. The inspector noted that the last revision to the reactor operating procedures was made in April 1986 and approved in August 1986. The reactor maintenance procedures were written and approved in October 1979, and various maintenance procedures had been revised since then with the latest revisions approved in February 1988. The experiment procedures were written and approved in January 1976 and had not been revised since that time. No procedures had been written or revised since the previous NRC inspection conducted in October 1992. The inspector verified tha'. all reactor facility procedures were reviewed and approved by the reactor supervisor, rearx administrator (Head of the Nuclear Engineering Department), and the Reactor Safety Board as required by the Technical Specification :

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9 Conclusion l Operating procedures, maintenance procedures, and experiment procedures provided adequate guidance to ensure that reactor operations, surveillances, and experiments were conducted properly and consistently to meet Technical l

Specification requirement .2 Ooerations Loas and Records 1 i Insoection Scope (40750)  ?

Documentation of reactor operations activities for the period November 1992 through September 1996 was reviewed to determine compliance with the i requirements in Technical Specification 6.1 Observations and Findinas -

Logs and records documenting reactor operation, experiment performance, reactor

startups, instrument checks and calibrations, radiation surveys, and personnel '

radiation exposure were reviewed. The inspector determined that the annual reactor operating reports and the operations logs and records adequately !

documented reactor operations activities. The monthly, semi-annual, annual, and biennial reactor surveillance checklists and surveillance test results for the period :

January 1993 through September 1996 were reviewed. The licensee's logs and l records were clear, concise, and legible. Reactor operations and testing were j satisfactorily docurnented in accordance with the Technical Specification ;

requirement ; Conclusion Excellent reactor operations logs and records were properly maintaine O3.3 Reports and Notifications I

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Reports and notifications to the NRC were reviewed to determine compliance with i the requirements in Technical Specification I I Observations and Findinas The licensee submitted the required annual reports of the reactor facility activities and operations for the time periods June 1,1992 through May 31,1993, June 1, 1993 through May 31,1994, June 1,1994 through May 31,1995, and June 1, i

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-10-1995 through May 31,1996. The inspector verified that these reactor facility annual reports met the Technical Specification requirements. No special reports l

were issued to the NRC since the last NRC inspection of the reactor facilit l

c. Conclusion Annual operating reports for the reactor facility met reporting requirement Operator Knowledge and Performance l

' Inspection Scope

The two senior reactor operators were interviewed, and a reactor startup and l showdown were observed. Operating procedures were reviewed as the senior reactor operator conducted reactor operations.

. Observations and Findinas No problems were identifie Conclusions

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The senior reactor operators were knowledgeable of routina operating procedures and performed reactor operational manipulations property and efficientl Operator Training and Qualification Insoection Scope l

The education and experience of the current reactor staff and the Reactor Safety l Board members were reviewe l The requalification training program for the senior reactor operators and the training program for nuclear engineering department students working in the reactor facility area were reviewed to determine agreement with recommendations in Industry Standard ANSl/ANS 15.4-1988 and Regulatory Guides 8.13 and 8.29 and compliance with the requirements in 10 CFR 19.12, operator requalification program, and Technical Specification Observations and Findinas The inspector determined that all of the reactor staff and Reactor Safety Board members met the qualifications per Technical Specification ,

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The inspector noted that the reactor operator requalification program, dated l May 20,1988, was approved by the NRC, and it conformed to the requirements of l 10 CFR Part 55.59. Lectures were conducted as required. Observations of l operator manipulations were documented. The lecture outline for the reactor

. l operator requalification program was comprehensive, and it included all the required l subject material. Comprehensive annual written examinations for 1993,1994, and i 1995 were given and successfully passed by the senior reactor operators. The I completed examinations were included in the senior reactor operators' individual training records as required. The requalification training records for the two senior reactor operators contained all of the documentation required by the approved operator requalification program. The licensee had developed good operator requalification record forms to track and document reactor operator requalification requirements. Annual medical examinations were satisfactorily passed by the two senior reactor operator The inspector reviewed the nuclear engineering department's orientation training given to students who work around the AGN-201M reactor. The student orientation training material and attendance records were reviewed. The students who worked routinely in the nuclear engineering department and around the reactor had received radiation protection and emergency training at the beginning of the academic year. The training conducted by the nuclear engineering department met the requirements of 10 CFR 19.1 Conclusions An excellent reactor operator requalification training program was being conducted and docurnented in accordance with a NRC approved program. Excellent reactor operator requalification training records wera being maintained. A good student j orientation program, which familiarized students working around the reactor facility l with radiation protection and emergency procedures, was implemente ;

06 Operations Organization and Administration , Scooe of Inspection (40750_)

The organization and staffing were reviewed to determine compliance with the requirements in Technical Specification Observations and Findinas The inspector verified that the organizational structure and assignment of responsibilities were as specified in Technical Specification 6.1. All organizational positions were filled with qualified personnel. The licensee had two senior reactor operators. There were no reactor operators. The licensee had several staffing changes since the last NRC inspection conducted in October 1992. Over the past four years, the Dean of the College of Engineering (Chairman of the Reactor Safety

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-12- I Board) changed three times. A new radiological safety officer was appointed. The inspector verified that the reactor operational responsibilities were implemented as '

specified in the Technical Specification The Reactor Safety Board's membership was in accordance with Technical Specification requirements. The inspector noted that the Reactor Safety Board had responsibility for both the AGN-201M (Docket No.50-059) and TRIGA (Docket N ) reactor facilities located at Texas A&M Universit c. Conclusions The reactor facility organizational structure and staffing met the Technical Specification requirements. All organizational positions were filled with qualified personnel. The reactor operational responsibilities were implemented as require The Reactor Safety Board membership met requirement Quality Assurance in Operations a. Scope of Inspection (40750)

The inspector reviewed the audits and reviews conducted to determine compliance with the requirements in Technical Specifications 6.1.6, 6.4.1, 6.4.2, and 6. Minutes of the Reactor Safety Board meetings from January 22,1993 to May 31,1996 were reviewe b. Observations and Findinas The inspector determined that Reactor Safety Board meetings were held at least annually as required by Technical Specification 6.4.1. However, the inspector noted that the agendas and minutes of the Reactor Safety Board meetings included very few entries concerning the AGN-201M reactor f acility. The required audits of reactor f acility activities and reviews of procedures, equipment changes, proposed !

tests or experiments, were not documented in the Reactor Safety Board minutes, if j performe During the previous inspection conducted in October 1992, the inspector observed, during the review of the quarterly audit reports, that it was sometimes difficult to always be certain that all of the requirements in Technical Specification 6.4.3.a and applicable operating license conditions were reviewed annually. This observation was discussed with the licensee during the inspection and along with the possibility of developing an audit checklist to ensure that all the items were reviewed and audited annually as required by Technical Specification 6.4.3.a. During the exit ,

meeting on October 2,1992, the licensee acknowledged the inspector's j

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! observation and agreed to evaluate their audit process and the use of an audit

, checklist as guidance in performing the reactor facility audits. However, the

, evaluation of the audit process was not performed, and an audit checklist was not j developed.

j j The inspector verified that biennial reviews of the emergency plan were conducted i on February 8,1991, January 22,1993, and August 25,1994. The reviews were

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performed by the Head of the Nuclear Engineering Department (Roactor Administrator for the AGN-201M reactor facility and member of the Reactor Safety l Board) who was responsible for the development and implementation of the

emergency plan and who was also the designated emergency director rather than an j individual not responsible for the item reviewed and audited. The inspector noted i that the review of the emergency plan performed on January 22,1993, was j documented in the reactor maintenance log but was not documented in the Reactor ( Safety Board minutes as being reviewed by the Reactor Safety Board. A biennial

review of the security plan was last conducted and documented in the Reactor

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Safety Board minutes on August 25,1994.

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Technical Specification 6.1.6 states, in part, "The Reactor Safety Board shall be a responsible for,.. . . conducting periodic audits of procedures, reactor operations

and maintenance, equipment performance, and records; . . . reporting all their findings and recommendations concerning the reactor facility to the Head of the

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Department of Nuclear Engineering."

l l Technical Specification 6.4.3 states, " Audits of f acility activities shall be performed

at least quarterly under the cognizance of the Reactor Safety Board but in no case

by the personnel responsible for the item audited. These audits shall examine the

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! The conformance of the facility operation to the Technical Specifications and l applicable license conditions, at least annually.

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i The Facility Emergency Plan and implementing procedures, at least every i two years.

i The Facility Security Plan and implementing procedures, at least every two years."  !

On October 1,1996, the inspector determined that quarterly audits to meet the

, requirements in Technical Specifications 6.4.2 and 6.4.3 were not conducted by i- members of the Reactor Safety Board since the second quarter of 1992. The i inspector also determined that the audits of the emergency plan and the security

! plan were performed by the Head of the Nuclear Engineering Department (Reactor

Administrator for the AGN-201M reactor facility) who was responsible for the j development and implementation of the emergency plan and security plan rather

than by someone not responsible for the items audited in accordance with Technical l

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Specification 6.4.3. The failure to ensure that quarterly audits of f acility activities and reactor operations were performed since the second quarter of 1992, the failure to ensure that biennial audits of the emergency plan and implementing procedures

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were performed by an individual who was not responsible for the audited item since February 8,1991, and the failure to ensure that biennial audits of the security plin i and implementing procedures were performed by an individual who was not responsible for the audited item since August 25,1994,i<; a violation of Technical i Specifications 6.1.6 and 6.4.3. (VIO 9601-01) Conclusions j

The Reactor Safety Board met at least annually. However, the Reactor Safety Board did not ensure that tha required reviews and audits of the reactor facility activities were performed. Quarterly audits were not conducted as required. A

violation was identified involving the failure to perform required audits of reactor facility activities and required reviews using an individual who was not responsible l for the audited ite l l

II. Maintenance M1 Conduct of Maintenance 2 Scoce of Inspection (40750)

Reactor maintenance logs and records were reviewe Observations and Findinas

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During the time period from June 1992 through May 1996, the licensee replaced several vacuum tubes, the 1.25-volt battery, the 10 -13 dashpot, both Keithley

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4102 relays, and the power transformer in Channel 2; and repaired several electrical connections in Channel 2. All of the components replaced during the performance of the preventive and corrective maintenance programs were identical replacements and did not involve any unreviewed safety questions. The safety-related corrective maintenance performed on the reactor and operations console was properly documented in the reactor's maintenance log and the licensee's annual reports of reactor operatio Conclusions Reactor maintenance activities were performed properly and in accordance with approved procedures. The licensee's logs and records satisf actorily documented reactor maintenance activitie Ill. Enaineerina

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There were no reactor design changes since the previous inspectio ,

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R1 Radiological Protection Controls (

a. Scope of Insoection

$ The radiation protection program was reviewed to determino compliance with the requirements in 10 CFR Part 20 and Technicd Specificatior s 3.4, 4.4, 5.3.d, 6.1.8, 6.10.1.e, and 6.10.2.d.

j The selected records were reviewed, personnel were interviewed, observations l were made, and independent radiation surveys of the reactor facility were performe The following documents were reviewed:

• Annual radiation dose summaries for 1993-1995 2 * Annual radiation and contamination surveys for 1993-1995

• Survey instrument calibration reccrds for 1993-1995 b. Observations and Findinas The inspector noted that all personnel who worked in the reactor facility had been issued proper whole body dosimetry which was sensitive to beta, gamma, and thermal neutron radiations. The inspector determined that the vendor who supplied and read the dosimeters was accredited in accordance with the requirements in 10 CFR 20.1601(c), Personnel exposure records for 1993,1994, and 1995 indicated met the limits of 10 CFR 20.1201 were not exceede The inspeuor determined that the licensee had implemented a proper radiation survey prognim. The required annual radiation surveys were thorough, included neutron surveys, and met Technical Specification and 10 CFR 20.1501(a)

requirements. The licensee had developed survey maps of the reactor room and accelerator room located directly above the reactor room which designated specific locations where radiation dose rate measurements were to be taken at specified reactor operation power levels. Annual radiation dose rate surveys conducted in 1993,1994, and 1995 were performed at nine specific locations designated on the reactor room map and at two specific locations designated on the accelerator room map. The dose rate surveys were performed at reactor operating power lesels of O,

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identified near the reactor was approximately 450 millirem per hour when the reactor was operating at a maximum of five watts thermal powe l The inspector performed an independent area radiation survey and confirmed that i radiation levels in unrestricted areas did not exceed the limits of 10 CFR -

l 20.1302(a)(2)while the reactor was operating at a maximum power level of 5 l l watts. The licensee had survey records as documentation of its radiation measurements, and the inspector's survey results compared very well with the l licensee's survey results. Restricted areas were posted in accordance with 10 CFR 20.190 The inspector reviewed the licensee's inventory of portable radiation survey '

instruments and found them to be adequate. Calibrated instruments were available ;

I at the time of inspection. Calibrations of the instruments used to perform radiation l l surveys were performed with radioactive sources traceable to national standard l

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l l 10 CFR 20.1101(c) states, " The licensee shall periodically (at least annually) ;

L review the radiation protection program content and implementation." The

! inspector determined on October 16,1996, while performing an in-office review of the licensee's audit and review program, that annual reviews of the radiation i

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protection program, in accordance with 10 CFR 20.1101(c),were not performed since the implementation of "new" 10 CFR Part 20 on January 1,1994. The l licensee's failure to perform annual reviews of the radiation protection program is a l

violation of 10 CFR 20.1101(c). (VIO 9601-02)

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c. Conclusions Appropriate radiation protection practices were implemented. Minimal radiation hazards were present and observed when the reactor was operated. Radiation surveys met Technical Specification and regulatory requirements. Portable radiation survey instruments assigned to the reactor f acility were adequate and were calibrated properly. A violation was identified involving the failure to perform annual reviews of the radiation protection program during 1994 and 199 P1 Conduct of Emergency Preparedness Activities Scope of Inspection i The inspector reviewed the emergency plan for the reactor facility to determine compliance with the requirements in 10 CFR 50.54(r) and in Technical Specifications 6.4.3.b and 6. ,

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• Emergency implementing procedures

• Exercise and drill scenarios l

• Emergency call lists

• Letters of agreement from local offsite support organizations

• Training records l

b. Observations and Findinas The inspector verified that there were no revisions to the emergency plan since the previous inspectio i The inspector verified that emergency call lists were accurate and posted in the l proper place l The licensee had conducted annual training for fire and police personnel in j conjunction with conducting the required emergency drills. The licensee had l conducted training of the emergency plan and emergency procedures for all pertinent nuclear engineering department personnel at the beginning of each academic year. The inspector also verified that emergency preparedness training was included in the annual requalification training for reactor operators as required by Technical Specification The inspector confirmed that exercises or drills were conducted January 15,1993, January 5,1994, January 13,1995, and January 10,1996. The frequency was in accordance with the commitments of the emergency plan. The inspector reviewed the licensee's documentation of the emergency exercises and the critiques and evaluations performed following the exercise l Letters of agreement with the City of College Station for ambulance and fire department services and Columbia Medical Center and St. Joseph Regional Health Center for medical services were maintained and current, j c. Conclusions A good emergency preparedness program was maintained. Appropriate training was provided to onsite and offsite emergency response personne . - - . . - . - . . - - - - - - . _ . - - - . - . ~ . . - - . - - .. -

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I S1 Conduct of Security and Safeguards Activities

Insoection Scope

The inspector reviewed the physical security plan to determine compliance with the {

! requirements in 10 CFR 50.54(p), Operating License Condition 2.D, and Technical 1 i Specifications 6.4.3.c and 6. ,

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j The inspector interviewed the reactor supervisor. Additionally, the inspector toured

the reactor facility and compared the reactor facility and security equipment with  !

j the description and requirements in the physical security pla Observations and Findinas The inspector verified that there were no revisions to the physical security plan since the previous inspectio The inspector verified that the site and facilities were as described in the physical security plan and that all physical barriers required by the physical security plan were installed and operational. The inspector verified that the security key control and combination lock control programs were implemented satisfactorily to maintain

. security of the reactor facility. Through interviews with the reactor supervisor and reviews of logs, the inspector determined that security for the facility was implemented as specified in the physical security plan. There had been no security problems or safeguards events since the previous inspectio License Condition 2.D states, "The licensee shall maintain in effect and fully implement all provisions of the NRC-approved physical security plan, . . . ."

Section 3.5 of the AGN-201M Reactor Facility Security Plan states, "The security '

program will be reviewed annually by the Reactor Safety Board described in the I license. The results of each meeting will be forwarded to the NRC with the annual report for the facility."

On October 1,1996, the inspector determined that the Reactor Safety Board did I not perform the required annual reviews of the physical security plan in accordance ,

with the requirements in Section 3.5 in the physical security plan since August 25, I 1994, and the results of the annual reviews were never forwarded to the NRC with the annual reports for the facility. The failure to perform annual reviews of the physical security plan and forward the results of the annual reviews to the NRC with the annual reports for the facility is a violation of License Condition 2.D and the physical security plan. (VIO 9601-03)

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-19- Conclusions Generally, the approved physical security plan was properly implemented. The However, the Reactor Safety Board did not perform the required annual reviews of the physical security plan. A violation was identified involving the failure to perform annual reviews of the physical security plan since August 25,1994, and never forwarding the results of the annual reviews to the NRC with the annual reports for the facilit V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to licensee representatives on October 3,1996. The licensee's representatives acknowledged the findings presented. The licensee identified the physical security plan as proprietary informatio A followup exit meeting was conducted telephonically on October 24,1996, to discuss a third violation dealing with the failure to perform annual reviews of the radiation protection program.

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ATTACHMENT SUPPLEMENTAL INFORM ATION PARTIAL LIST OF PERSONS CONTACTED

Licensee

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M. Adams, Assistant Professor, Member of Reactor Safety Board

R. Berry, Reactor Supervisor 1. Hamilton, Assistant Professor, Senior Reactor Operator J. Holste, Assistant Dean, College of Engineering, Chairman of Reactor Safety Board C. Meyer, Radiation Safety Officer J. Poston, Reactor Administrator, Head of Nuclear Engineering Department W. Reece, Associate Professor, Member of Reactor Safety Board LIST OF INSPECTION PROCEDURES USED IP 40750 Class ll Research and Test Reactors Operations Procedure IP 81401 Plans, Procedures, and Reviews IP 81403 Receipt of New Fuel at Reactor Facilities IP 81431 Fix Site Physical Protection of Special Nuclear Material of Low Strategic Significance IP 85102 Material Control and Accounting - Reactors IP 86740 Inspection of Transportation Activities  !

LIST OF ITEMS OPENED Opened

059/9601-01 VIO Quarterly Audits )

059/9601-02 VIO Annual Radiation Protection Program Reviews 059/9601-03 VIO Annual Physical Security Plan Rev:ews

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1 LIST OF DOCUMENTS REVIEWED Operatina Procedures 3.1, " General Operating Rules," August 15,1986 3.2, " Operational Information," August 15,1986 3.3, " Checkout Procedure," August 15,1986  :

3.4, "Startup Procedure," August 15,1986 j 3.5, " Operating Conditions," August 15,1986 '

3.6, " Shutdown," August 15,1986 '

3.7, "Other Conditions," August 15,1986 3.8, " Radiation Protection," August 15,1986  ;

3.9, " Reactor Maintenance," August 15,1986 i

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!e Maintenance Procedures

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CAPH, " Maintenance Procedure for Checking Suberitical Assembly Water Conductivity," September 7,1983  !

EITL, " Maintenance Procedure for Testing Earthquake interlock," October 11, 1979 l SWIT, " Maintenance Procedure for Conducting a Detailed Shield Water Tank *

Inspection," October 11,1979  ;

PWCL, " Maintenance Procedure for Power Calibration," October 11,1979 CH1P, " Maintenance Procedure for Setting Channel 1 High Voltage,"

February 3,1988 i CH2P, " Maintenance Procedure for Setting Channel 2 High Voltage," i February 3,1988 -

CH3P, " Maintenance Procedure for Setting Channel 3 High Voltage," i February 3,1988  !

SKMP, " Maintenance Procedure for Setting Skirt Monitor High Voltage," t October 11,1979 1 PD2M, " Maintenance Procedure to Calibrate Channel 2 Period Meter and to Verify l Short Period Trip," January 22,1986 '

C1LT, " Maintenance Procedure to Calibrate Channel 1 and Verify Low Trip,"

October 11,1979 C2LT, " Maintenance Procedure to Verify Channel 2 Low Trip," September 7,1983 C3LT, " Maintenance Procedure to Calibrate Channel 3 and Verify Low Trip,"

September 7,1983 C2HT, " Maintenance Procedure to Calibrate Channel 2 and Verify High Trip,"

October 11,1979 C3HT, " Maintenance Procedure to Calibrate Channel 3 and Verify High Trip,"

September 7,1983 ROEX, " Maintenance Procedure or Determining the Total Excess Reactivity,"

October 11,1979

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1 o-3-I RCAL, " Maintenance Procedure for Determining the Rer.ctivity Worth of Each Control Rod," October 11,1979 RDTM, " Maintenance Procedure for Measuring Rod Drop Times," January 28,1983

RITM, " Maintenance Procedure for Measuring Control Rod Reac*.svity insertion

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Rates," October 11,1979 TITL, " Maintenance Procedure for Testing Low Reactor Tank Temperature ,

Interlock," October 11,1979 l W1 TL, " Maintenance Procedure for Testing Shield Water Level Interlock," I January 31,1986 RSIC, " Maintenance Procedure for Calibrating Radiation Survey Instruments,"

October 11,1979 ~

RADS, " Maintenance Procedure for Counting a Radiation Survey of the AGN-201M Reactor Facility," October 11,1979 EVAC, " Evacuation Procedure Drill," July 20,1987 CRIS, " Maintenance Procedure for Conducting a Detailed Control Rod Inspection and Functional Check," October 11,1979 EPEX, " Emergency Plan Exercise," July 20,1987 Experiments RXEP-1, "Startup and Operation of the AGN-201M Reactor," January 27,1976 REXP-2, " Irradiation of Compounds Composed of Elements One Through Eighty-three in the Glory Hole or Access Port," January 27,1976 REXP-3, " Control Rod Calibration by the Rod Drop Method," January 27,1976 REXP-4, " Control Rod Calibration by Positive Period i4easurement," January 27,1976 REXP-5, " Reactivity Perturbations," January 27,1976 REXP-6, " Delayed Neutron Half-life Measurements," January 27,1976 REXP-7, " Transfer Function Measurement," January 27,1976 REXP-8, " Irradiation of Natural or Enriched Uranium in the AGN-201M Glory Hole," l January 27,1976 '

REXP-9, " Irradiation Experiments in the Thermal Column," January 27,1976 l REXP-10, "A Critical Experiment for the AGN-201M Reactor," January 27,1976 '

Operator Trainina Proaram

"Requalification Program for Licensed Reactor Operators and Senior Reactor Operators,"

May 26,1987 l

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Emeraency Plan and Procedures

AGN-201M Reactor Facility Emergency Plan, September 1984 l

l PE-1, " Personnel Injury," October 8,1984 ,

PE-2, " Personnel Injury involving Radioactive Contamination," October 8,1984 I PE-3, " Radioactive Contamination of Personnel or Spill of Radioactive Material Within the l Reactor Facility," October 8,1984 i PE-4, " Suspected Radiation Overexposure of Personnel," October 8,1984

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EA-1, " Reactor Facility Fire," March 14,1989 EA-2, " Bomb Threat," March 14,1989 EA-3, " Civil Disturbance," March 14,1989 l - EA-4, " Severe Natural Phenomena," March 14,1989 l EA-5, " General Emergency Alert," March 14,1989

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RE-1, " Reactor Emergency," August 15,1986 l

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Physical Security Plan and Procedures l

l AGN-201M Reactor Facility Security Plan, February 27,1991 SP-1, " Security Procedure for Access to the Nuclear Engineering Laboratory Areas,"

! October 5,1984 '

l SP-2, " Security Procedure for Access to the AGN-201M Reactor Room," October 5,1984 i

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SP-3, " Security Procedure for Access to the Accelerator Room," October 5,1984

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Annual Reports I Annual Operating Report for -lune 1,1992 - May 31,1993 j Annual Operating Report for June 1,1993 - May 31,1994

Annual Operating Report for June 1,1994 - May 31,1995

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Annual Operating Report for June 1,1995 - May 31,1996 l

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