IR 05000225/2005201

IR 05000225-05-201, on 02/06/2006 - 02/09/2006, and 02/28/2006, Rensselaer Polytechnic Institute

ML060650479
Person / Time
Site:	Rensselaer Polytechnic Institute
Issue date:	04/04/2006
From:	Thomas B E NRC/NRR/ADRA/DPR
To:	Winters G C Rensselaer Polytechnic Institute
Witt K, NRC/NRR/ADRA/DPR/PRT, 415-4075
References
50-225/2005-201, IR-06-201
Download: ML060650479 (25)

Text

April 4, 2006

Mr. Glenn C. Winters, DirectorReactor Critical Facility NUCLEAR ES 2nd FloorRensselaer Polytechnic Institute 110 8th Street Troy, NY 12181

SUBJECT: NRC INSPECTION REPORT NO. 50-225/2006-201

Dear Mr. Winters:

This letter refers to the inspection conducted on February 6 - 9 and 28, 2006 at the RensselaerPolytechnic Institute L. David Walthousen Critical Experimental Facility. The inspectionincluded a review of activities authorized for your facility. The enclosed report presents theresults of that inspection. Areas examined during the inspection are identified in the report. Within these areas, theinspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress. Based on the results of this inspection, no safety concerns or noncompliance with the U.S. Nuclear Regulatory Commission (NRC) requirements were identified. No response to this letter is required.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be made available electronically for public inspection in the NRC PublicDocument Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.Should you have any questions concerning this inspection, please contact Mr. Kevin M. Witt at301-415-4075.

Sincerely,/RA/

Brian E. Thomas, Branch ChiefResearch and Test Reactors Branch Division of Policy and Rulemaking Office of Nuclear Reactor RegulationDocket No. 50-225License No. CX-22

Enclosures:

NRC Inspection Report No. 50-225/2006-201cc w/encl: Please see next page Rensselaer Polytechnic InstituteDocket No. 50-225 cc:

Mayor of the City of SchenectadySchenectady, NY 12305Barbara YoungbergRadiation Section Chief New York State Department of Environmental Conservation 625 Broadway Albany, NY 12233-7255Dr. Tim Wei2052 JEC Rennselaer Polytechnic Institute 110 8th Street Troy, NY 12181Director, Bureau of Environmental Radiation Protection New York State Department of Health 547 River Street, Room 530 Troy, NY 12180-2216Dr. William VernetsonTest, Research and Training Reactor Newsletter Director of Nuclear Facilities University of Florida 202 Nuclear Science Center Gainesville, FL 32611-8300 April 4, 2006Mr. Glenn C. Winters, DirectorReactor Critical Facility NUCLEAR ES 2nd FloorRensselaer Polytechnic Institute 110 8th Street Troy, NY 12181

SUBJECT: NRC INSPECTION REPORT NO. 50-225/2006-201

Dear Mr. Winters:

This letter refers to the inspection conducted on February 6 - 9 and 28, 2006 at the RensselaerPolytechnic Institute L. David Walthousen Critical Experimental Facility. The inspectionincluded a review of activities authorized for your facility. The enclosed report presents theresults of that inspection. Areas examined during the inspection are identified in the report. Within these areas, theinspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress. Based on the results of this inspection, no safety concerns or noncompliance with the U.S. Nuclear Regulatory Commission (NRC) requirements were identified. No response to this letter is required.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be made available electronically for public inspection in the NRC PublicDocument Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.Should you have any questions concerning this inspection, please contact Mr. Kevin M. Witt at301-415-4075.

Sincerely,/RA/Brian E. Thomas, Branch ChiefResearch and Test Reactors Branch Division of Policy and Rulemaking Office of Nuclear Reactor RegulationDocket No. 50-225License No. CX-22

Enclosures:

NRC Inspection Report No. 50-225/2006-201cc w/encl: Please see next pageDistributionPUBLICPRT/R&TR r/fRidsNrrDprPrtaRidsNrrDprPrtb HNiehCGrimesGHill (2)RidsOgcMailCenter BDavis (cover letter only)(O5-A4)

NRR enforcement coordinator (Only IRs with NOVs, O10-H14)ACCESSION NO.: ML060650479 TEMPLATE #: NRR-106OFFICEPRT:RIPRT:LAPRT:PMPRT:BCNAMEKWitt*EHylton*DHughes:tls*BThomas:tls*DATE3/10 /2006 3/10/20063/13/064 /4/2006OFFICIAL RECORD COPY U.S. NUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONDocket No:50-225 License No:CX-22 Report No:50-225/2006-201 Licensee:Rensselaer Polytechnic Institute Facility:L. David Walthousen Critical Experimental FacilityLocation:Schenectady, NY Dates:February 6 - 9 and 28, 2006 Inspector:Kevin M. Witt Approved by:Brian E. Thomas, Branch ChiefResearch and Test Reactors Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation EXECUTIVE SUMMARYRensselaer Polytechnic InstituteReactor Critical FacilityNRC Inspection Report No. 50-225/2006-201The primary focus of this routine, announced inspection was the on-site review of selectedaspects and activities since the last NRC inspection of the licensee's Class II non-power reactorsafety programs including: organization and staffing, operations logs and records, procedures, operator requalification, surveillance and limiting conditions for operations, experiments,radiation protection program, design changes, committees, audits and reviews, emergency preparedness, maintenance logs and records, and fuel handling. The inspector also performed a follow-up on previous open items.The licensee's programs were acceptably directed toward the protection of public health andsafety, and in compliance with NRC requirements. Organization and Staffing

!The organization and staffing were consistent with Technical Specification requirements.Operations Logs and Records

!Operational activities were consistent with applicable Technical Specification andprocedural requirements.Procedures

!Procedural control and implementation generally satisfied Technical Specificationrequirements.Operator Requalification

!The Reactor Operator Requalification Program was implemented satisfactorily, theprogram was up-to-date, and plan requirements were met.Surveillance and Limiting Conditions for Operations

!The licensee's program for completing surveillance inspections and Limiting Conditionsfor Operation confirmations satisfied Technical Specification and licensee administrative controls.Experiments

!The approval and control of experiments met Technical Specification and applicableregulatory requirements.Radiation Protection Program

!Surveys were being completed and documented acceptably to permit evaluation of theradiation hazards present.

-2-!Postings met the regulatory requirements specified in 10 CFR Parts 19 and 20.

!Personnel dosimetry was being worn as required and doses were well within thelicensee's procedural action levels and NRC's regulatory limits.

!Radiation monitoring equipment was being maintained and calibrated as required.

!The Radiation Protection Program being implemented by the licensee satisfiedregulatory requirements.

!Effluent monitoring satisfied license and regulatory requirements and releases werewithin the specified regulatory and Technical Specification limits.Design Changes

!Based on the records reviewed, the inspector determined that the licensee's designchange program was being implemented as required.Committees, Audits and Reviews

!Review and oversight functions required by the Technical Specifications wereacceptably completed by the Nuclear Safety Review Board.Emergency Preparedness

!The emergency preparedness program was conducted in accordance with therequirements stipulated in the Emergency Plan.Maintenance Logs and Records

!Maintenance logs, records, and performance satisfied Technical Specification andprocedure requirements. Fuel Handling

!Fuel handling and inspection activities were completed and documented as required byTechnical Specification and facility procedures. Follow-up on Previous Open Items

!All open items identified in previous inspection reports were closed.

REPORT DETAILSSummary of Plant StatusThe licensee's research reactor, licensed to operate at a maximum steady-state thermal powerof 100 Watts (100 W), continues to be operated in support of operator training, surveillance, andminor utilization. During the inspection, the reactor was operated on Wednesday, February 8,2006, at 2.25 W for a student laboratory. The licensee indicated that transportation ofradioactive materials has not been conducted since the previous inspection. 1.Organization and Staffing a.Inspection Scope (Inspection Procedure (IP) 69001)The inspector reviewed the following regarding the licensee's organization andstaffing to ensure that the requirements of Section 6.1 of the Technical Specifications (TS), Amendment No. 11, dated September 7, 2004, were beingmet:*Rensselaer Polytechnic Institute (RPI) organizational structure and staffing*management responsibilities and staff qualifications*staffing requirements for the safe operation of the facility*Reactor Critical Facility (RCF) Reference Manual (RCFRM) Chapter 2:Facility Administration, undated*Operations Reports for the RPI RCF, dated April 28, 2004 and March 31, 2005b.Observations and FindingsThe RPI RCF organizational structure and the responsibilities of the reactormanagement and staff had not changed since the last inspection (see NRC Inspection Report No. 50-225/2004-201). All of the staff at the RCF are either part-time employees of RPI, faculty of RPI, or employees of the Knolls Atomic Power Laboratory (KAPL). The facility director (FD) does not possess a licenseto operate the reactor. Current licensed staff consisted of the reactor supervisor and two other facility staff members. All of these licensed staff members arequalified Senior Reactor Operators (SROs). Two of the operators are currently enrolled at RPI as full-time students. The Operations Supervisor (OS) is a professor at RPI and a researcher at KAPL in addition to the duties necessary for the OS position. During the inspection, the NRC staff conducted a licensingexamination for three SRO candidates that have been training at the facility forapproximately one year. A separate report will be sent to the licensee and thecandidates summarizing the results of the examination. The RCF staff's qualifications satisfied the training and experience requirementsstipulated in the TS. The operations log and associated records confirmed that shift staffing met the minimum requirements for duty personnel. Review of records verified that management responsibilities were administered as requiredby TS and applicable procedures.

-2-Review of records verified that management responsibilities were administered asrequired by TS, applicable procedures, and that transitions in the staff were properly managed. The 2004 and 2005 annual reports summarized the required information and was issued at the frequency specified in TS Section 6.5.1. No special reports were submitted pursuant to TS Section 6.5.2.c.ConclusionsThe organization and staffing were consistent with TS requirements.2.Operation Logs and Recordsa.Inspection Scope (IP 69001)The inspector reviewed the following to ensure that selected records weremaintained as required by TS Section 6.6:*RCFRM Chapter 4: Operations Procedures, undated*Pre-Startup Procedures, Rev. 6.0, dated March 18, 2005

• Pre-Startup Checklist, Version 2.1, undated

• Reactor Secured Checklist, Version 2.0, undated

• Operations Reports for the RPI RCF, dated April 28, 2004 and March 31, 2005*RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - present*Completed Pre-Startup Checklist forms, dated from January 5, 2004 topresent*Completed Reactor Secured Checklist forms, dated from January 5, 2004to presentb.Observations and FindingsReactor operations were carried out following written procedures and TSrequirements. The inspector verified that reactor operating characteristics, and other TS and procedure required entries, were logged in the operating log and cross-referenced with other logs and checklists as required. A review of the logs and records indicated that TS operational limits had not been exceeded. Operations records confirmed that shift staffing met the minimum requirements for duty personnel. The inspector determined that reactor operations were carried out following written procedures.Scrams that occurred during reactor operations were recorded in the back of thereactor operations log. There were no scrams that had occurred during the previous two years. The previous scrams that were recorded in the logbook were the result of faulty instrumentation that has been replaced. For these scrams, theSRO completed a root cause analysis before the resumption of operations. The inspector conducted observations of the reactor staff operating the reactor onFebruary 8, 2006, and reviewed the Pre-Startup Checklist, RCF Log Book and the

-3-Reactor Secured forms. The inspector noted that the licensed operators on dutywere knowledgeable and competent. Observation of operational activities also confirmed that reactor operations were carried out in accordance with written procedures and TS requirements.c.ConclusionsOperational activities were consistent with applicable TS and proceduralrequirements.3.Proceduresa.Inspection Scope (IP 69001)The inspector audited the following to ensure that the requirements of TS Section6.2 were being met concerning written procedures: *administrative controls*procedural implementation

• records for changes and temporary changes RCF Power Calibration Surveillance Test, dated September 15, 2005*Pre-Startup Procedures, Rev. 6.0, dated March 18, 2005b.Observations and FindingsThe inspector determined that written procedures were available for the activitiesdelineated in TS Section 6.2 and were approved by the Nuclear Safety Review Board (NSRB) before they were implemented. The clarity and detail in the procedures were acceptable. Temporary changes to the procedures that do not change their original intent can be authorized by the OS and must be subsequently reviewed by the NSRB. RCF staff members conducted TS activities in accordance with applicable procedures.Several procedures have changed since the previous inspection. One newprocedure describes a new process to calibrate the power channels. The NSRB reviewed this procedure before it was conducted and approved it for permanent use. The startup checklist was also changed from its previous version during the inspection period. The inspector confirmed that the OS reviewed the change and approved it on an interim basis. The licensee stated that this procedure is waiting to be reviewed by the NSRB due to other procedure changes that are planned. The inspector compared the current version of the pre-startup procedure to theprevious version and could not find any differences between the two documents.

Due to the previous OS leaving the facility, the licensee did not know why a new version of the procedure was issued with no changes. The two most recent versions of this procedure has the same changes written into it by pen, but a new version has not been issued. The inspector communicated to the licensee that procedural control is important for the safe operation of the facility and the currentmethod of having several procedure revisions in different places can be

-4-confusing. The inspector asked the licensee to create a procedure trackingsystem in order to ensure that all staff are using the most current and up to dateprocedures. This issue will be considered by the NRC as an Inspector Follow-upItem (IFI) and will be reviewed during the next inspection at the facility (IFI 50-225/2006-201-01).c.ConclusionsProcedural control and implementation generally satisfied TS requirements.4.Operator Requalification a.Inspection Scope (IP 69001)The inspector reviewed the following to verify compliance with the requirements in10 CFR Part 55:*status of operator licenses*operator active duty confirmation

• operator training and examination records

• operator physical examination records

• Reactor Operator Requalification Program (RORP), undated

• RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - presentb.Observations and FindingsThe licensee's requalification program is described in the program submitted tothe NRC. The inspector reviewed the requalification records of the three SROscurrently employed at the facility in addition to the previous OS whose SROlicense has recently been terminated. The OS is responsible for the implementation of the RORP and administers all tests. The inspector verified that all of the operators' licenses were current. Records showed that operators were given written examinations biennially and annual operations tests as required.

The inspector verified that physical examinations of the operators were conducted biennially as required. The inspector also verified that the operators were reviewing the contents of all abnormal and emergency procedures on an annual basis. The number of hours all the operators spent in the facility performinglicensed duties were tallied on a spreadsheet to ensure that all operators met the required minimum number of hours operating the reactor. The inspector confirmed that the RORP was being administered in a manner that sufficiently maintains the effectiveness of all licensed operators.After reviewing the records for the last quarter of 2005, the licensee noted thatone of the SROs did not maintain proficiency by performing licensed duties for a total of four hours. The licensee immediately placed the SRO on a remedial program and will supervise the operator for a total of six hours before the operatoris allowed to resume licensed duties. The inspector reviewed the situation and confirmed that the licensee was following all aspects of the requirements specified in the RORP and the regulations.

-5-c.ConclusionsThe Reactor Operator Requalification Program was implemented satisfactorily,the program was up-to-date, and plan requirements were met.5.Surveillance and Limiting Conditions for Operationa.Inspection Scope (IP 69001)The inspector reviewed the following to ensure that the surveillance requirementsand limiting conditions for operations (LCO) specified in TS Section 4.0 were met: *surveillance, calibration, and test data sheets and records*RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - present*RCF Surveillance Procedures, Version 3.0, dated February 2006

• RCF Power Calibration Surveillance Test, dated September 15, 2005

• Schedule of Periodic Requirements, Version, dated July 14, 2005

• RCF Semiannual Surveillances, completed forms from March 2004 -present*Area Radiation System Calibration Procedure, Version 2.0, dated May 2004b.Observations and FindingsThe inspector noted that selected daily, monthly, semiannual, and annual checks,tests, and/or calibrations for TS-required surveillance and LCO verifications werecompleted as required. The LCO verifications were completed on schedule and in accordance with licensee procedures. All of the recorded results were within the TS and procedurally prescribed parameters. The records and logs were noted to be complete and were being maintained as required. The licensee tracked all of the completed surveillances on a spreadsheet which is reviewed frequently by the Radiation Safety Officer (RSO) to ensure that there is effectiveoversight of facility operations. The procedures for each of the surveillancesprovided clear and concise direction and control of reactor operational tests and surveillances.The inspector observed the licensee completing part of the pre-startup checklistfor TS required items on February 8, 2006. All of the items on the checklist were carried out appropriately and the personnel conducting the tests 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.ConclusionsThe licensee's program for completing surveillance inspections and LCOconfirmations satisfied TS and licensee administrative controls.

-6-6.Experimentsa.Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance withTS Section 2.3:*experimental program requirements*experimental administrative controls and precautions

• RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - presentb.Observations and FindingsThere has been one type of experiment conducted at the RCF since the previousinspection, which is the routine irradiation of various materials. The most frequently used experimental facility is the central fuel pin irradiation position,which can either consist of a polyethylene pin with sample inserts or a fuel pin with samples taped to the outside. Samples can be loaded and unloaded from the sample irradiation position while the reactor is critical. Samples that have been irradiated at the RCF include gold foils, Thermal Luminescent Dosimeters (TLDs), and small amounts of boron. The OS approves all samples to be irradiated in accordance with the TS limitations. No new experiments had been initiated, reviewed, or approved since the previous inspection at the facility. If anynew experiments were to be initiated, they would be reviewed and approved by the NSRB. The inspector confirmed that all of the experiments conducted were in accordance with TS limits and procedural requirements.c.ConclusionsThe approval and control of experiments met TS and applicable regulatoryrequirements.7.Radiation Protection Programa.Inspection Scope (IP 69001)The inspector reviewed the following to verify compliance with 10 CFR Part 19and Part 20 and TS Sections 3.3 and 5.5: *Calibration Certificate for RCF Portable Monitor (Ludlum Model 5), datedSeptember 26, 2005 *Personnel and environmental dosimetry results for 2004 and 2005 Memorandum from Peter Caracappa to file, entitled, "Air emissioncompliance for 2004," dated March 24, 2005Completed Quarterly Radiation Safety Audits, Radioactive Materials Labfor the RCF, dated July 7, 2004 - January 17, 2006RCF Semiannual Surveillances, completed forms from January 2004 topresent

-7-Radiation Safety Training Presentation for Radiation Workers, undated*Radiation Safety Annual Report - 2004, dated June 2, 2005

• RCF and Public Safety personnel training records

• Calibration of RCF Co-60 Source, dated June 2, 2004

• Safety Evaluation Report related to the renewal of the operating licensefor the critical experiment facility of RPI, dated October 1983b.Observations and FindingsThe RSO applies the radiation protection program uniformly to the two licensedactivities on campus (broad scope and the reactor). The licensee's program for radiological health and safety related to the reactor license was evaluated during this inspection.(1)SurveysThe inspector reviewed quarterly radiation and contamination surveys ofthe licensee's controlled areas as well as radiation wipe surveys completed by the RSO. The surveys had been completed in accordance with the applicable procedure. The results were documented on the appropriate forms, evaluated as required, and corrective actions taken when readings or results exceeded set action levels. The survey also included a checklist of items to be verified such as the adequacy of warning signs and postings in the area. The number and location of survey points was adequate to characterize the radiological conditions.

Surveys by the RSO were conducted in accordance with the appropriate procedure and logged on the appropriate forms.(2)Postings and NoticesThe inspector reviewed the postings at the entrances to various controlledareas including the Reactor Bay, and radioactive material storage areas.

The postings were acceptable and indicated the radiation and contamination hazards present. The facility's radioactive material storage areas were noted to be properly posted. No unmarked radioactive material was found in the facility. A copy of current notices to workersrequired by 10 CFR Part 19 was posted at the entrance to the Reactor Cell as well.(3)DosimetryThe 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, awhole body film badge dosimeter is generally issued to each individual.

Records indicate that no abnormal readings were obtained.

-8-An examination of the records for the inspection period showed that allexposures were well within NRC limits and within licensee action levels. There are currently eight people at the RCF that are being monitored byTLDs. All of the personnel associated with the facility received an annualdeep dose exposure less than 20 millirem (mrem) for 2004. Currentexposure records for 2005 indicate no increased levels in exposures. The licensee investigates any dosimetry readings that indicate an exposure above background levels.(4)Radiation Monitoring EquipmentThe calibration of portable survey meters and friskers was typicallycompleted by a company that specializes in calibrations while fixed radiation detectors were calibrated at the facility using a portable source.

The calibration records of portable survey meters and fixed radiation detectors in use at the facility were reviewed. Calibration frequency metthe requirements established in the applicable procedures while records were being maintained as required. The inspector observed that proper precautions are always used to maintain doses for calibrations as low as reasonably achievable (ALARA).(5)Radiation Protection ProgramThe inspector verified that the radiation protection program was beingreviewed annually as required. No issues related to the radiation protection program at the RCF were identified in the review of the program.RPI requires that all personnel who work with radioactive materials receivetraining in radiation protection, policies, procedures, requirements, and the facilities prior to having unescorted access to the RCF. The RSO isresponsible for conducting the training and all of the training is typically conducted online. The RSO typically also conducts annual refresher training in a classroom setting. The training covered the topics required to be taught in 10 CFR Part 19 and the review of training materials indicated that the staff were instructed on the appropriate subjects.(6)Facility ToursThe inspector toured the RCF and the accompanying facilities. Control ofradioactive material and control of access to radiation and high radiation areas were acceptable. The postings and signs for these areas were appropriate. The inspector also determined that there was no measurable releases of gaseous or liquid radioactive material from the research reactor facility.(7)Environmental MonitoringThe licensee ensures compliance with NRC regulations for environmentalmonitoring by ensuring that all doses at the site boundary are less than

-9-the dose limits specified in 10 CFR 20.1301. Several TLDs arestrategically placed in several locations around the perimeter of the RCF.

Records for 2004 indicate that doses were well below the applicable requirements and typically measure at background levels. Current exposure records for 2005 indicate no increased levels in exposures. In addition to the measurements at the site boundary, radiation surveys of the reactor facility show that doses are less then the regulatory limit forenvironmental exposure rates.Records show that projected gaseous emissions from the reactor aregenerally minimal. The licensee uses a calculation provided in the Safety Evaluation Report from the RCF license renewal in 1983 to project a maximum annual release from the RCF and reduces the value by the ratio of actual versus projected usage of the reactor. The licensee uses this value as input to the Environmental Protection Agency computational code

"COMPLY," which shows that the licensee is in compliance with 10 CFR 20.1301(a)(1). The licensee releases primary coolant directly to the Mohawk River on alimited basis and one such release was conducted in August 2005. A review of measurements indicates that there was no measurable amount of radiation in the water released to the river. c.ConclusionsThe inspector determined that : (1) surveys were being completed anddocumented acceptably to permit evaluation of the radiation hazards present,(2) postings met the regulatory requirements specified in 10 CFR Part 19, (3)

personnel dosimetry was being worn as required and doses were well within the licensee's procedural action levels and NRC's regulatory limits, (4) radiationmonitoring equipment was being maintained and calibrated as required, (5) the Radiation Protection Program being implemented by the licensee satisfied regulatory requirements, and (6) effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits8.Design Changesa.Inspection Scope (IP 69001)In order to verify that any modifications to the facility were consistent with10 CFR 50.59, the inspector reviewed selected aspects of:*facility design changes and records for the past two years*facility configuration and associated records*RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - present*Letter from RPI to NRC entitled, "Proposed Change to TechnicalSpecifications (Removal of 400 Cycle Interlock)," dated July 14, 2004*Operations Reports for the RPI RCF, dated April 28, 2004 and March 31, 2005*Procedures

-10-b.Observations and FindingsThrough review of applicable records and interviews with licensee personnel, theinspector determined that no significant changes had been initiated and/orcompleted 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 inspector reviewed a change of the rod position indicators that had been previously approved by the NSRB prior to this inspection period. A related TS change, approved by Amendment No. 11 to the TSs, eliminated the interlock associated with the 400 Hz motor-generator set that provided power to the control rod position indicators.

The new system senses rod motion through an optical encoder mechanicallycoupled to the control rod. Position is determined by detecting the pulse train from the encoder in a digital counter. Position is displayed on the control console in inches withdrawn to the nearest 0.01 inch. A written test procedure was used to verify correct operation of all affected controls and indications. The licensee determined that this change did not constitute an unreviewed safety question and conducted operability checks of the new control rod position indicators to verifythat all of the applicable requirements would be met. Post installation verification testing of the system was thorough and adequately documented.Other changes to the facility that are currently being worked on or planned includea new mechanism of testing control rod drop times and a picoammeter test system. The licensee is also in the process of setting up the last electronic chart recorder that was previously mentioned in the last NRC inspection report. Thelicensee has evaluated all of these projects and does not plan on requesting NRC approval for the implementation. The NSRB has been fully briefed on these projects as indicated in the meeting minutes and is fully supportive of upgrades in reactor instrumentation. The inspector determined that these changes will help toincrease the utilization and safety of the RCF by implementing more currenttechnology.c.ConclusionsBased on the records reviewed, the inspector determined that the licensee'sdesign change program was being implemented as required.9.Committees, Audits, and Reviewsa.Inspection Scope (IP 69001)The inspector reviewed the following to ensure that the audits and reviewsstipulated in TS Section 5.2 and 10 CFR 50.59 were being completed by the NSRB:*Structure and Function of the NSRB, dated August 1988*RPI NSRB Membership Listing, dated November 2004, November 2005,and February 2006*Letter from Alan Cramb to Michael Podowski re: Confirmation ofAppointment as NSRB Chairman, dated February 8, 2006

-11-*RCF Audit Records, dated from January 2004 - present*NSRB meeting minutes for meetings held May 10, and November 29,2004, and May 12, and November 14, 2005 b.Observations and FindingsThe NSRB is defined in the TSs and a document describing the structure of theNSRB. The inspector verified that the committee is following all aspects of the TS requirements. The NSRB had semiannual meetings and a quorum was always present as required. Review of the minutes indicated the NSRB provided guidance, direction and oversight, and ensured suitable use of the reactor. The minutes provided an acceptable record of NSRB review functions and of NSRB safety oversight of reactor operations. Operations audits were performed and met the TS requirements. The auditsappeared to be acceptable, although it was difficult to ascertain what was discussed in the NSRB meetings regarding these audits, since documentation of the audit discussions was two sentences in the NSRB minutes.c.ConclusionsReview and oversight functions required by the TSs were acceptably completedby the NSRB.10.Emergency Preparednessa.Scope (IP 69001)The inspector reviewed selected aspects of:*Emergency Plan for the RPI Critical Experiment Facility (E-Plan), datedAugust 2004*RCFRM Chapter 6: Emergency Procedures, dated November 2002

• RCFRM Chapter 8: Notification Procedure, dated May 1, 1985

• RCF Emergency Notification List, dated February 8, 2006

• First Aid Kit Contents and Annual Inventory Checks List*Schedule of Periodic Requirements, version dated July 14, 2005

• Letters of Agreement (LOA) with support agencies

• Critiques of annual emergency drills held January 30, 2004 and August 1, 2005*emergency response facilities, supplies, equipment and instrumentation*offsite support agreements

• emergency drills and exercises*RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - presentb.Observations and FindingsThe inspector reviewed the E-Plan in use at the RCF and verified that the E-Planwas being properly implemented at the facility. The inspector reviewed the

-12-emergency facilities, instrumentation, and equipment and verified that the off-siteemergency response equipment was as described in the E-Plan. The inspector verified that LOA had been established with the Ellis Hospital, City ofSchenectady Police Department and Fire Department, and Mohawk Ambulance Service.Through direct observation, records review, and interviews with emergencyorganization personnel, the inspector determined that they were capable to respond, and knowledgeable of the proper actions to take in case of an emergency. The RCF staff is responsible for responding to an emergency during all hours and making initial assessment and corrective and protective actions.

The responsibility and authority for directing and coordinating emergencyresponse activities are assigned to the FD, acting as the emergency director. All RCF staff receive annual emergency response training. The inspector verified that the licensee reviewed the E-Plan on an annual basis, the E-Procedures on a biennial basis, conducted an inventory of the first aid kit annually, and checked the emergency siren annually.Emergency evacuation drills had been conducted annually as required by theE-Plan. The drill for 2004 and 2005 were both practical exercises and effectivelytested the notification of emergency personnel. Critiques were written and discussed following the drills to document any problems identified during theexercises. The licensee has conducted orientation tours for the RPI Department of Public Safety and the Schenectady Fire Department.The inspector called the Ellis Hospital in Schenectady, NY on February 28, 2006,and talked about the supplies and equipment at this support site that would be available in case of an emergency. The inspector confirmed that the hospital was well prepared to handle a variety of injuries that could happen at the RCF. There appeared to be slight confusion over who was in possession of the LOA between the hospital and RPI, yet the Ellis Hospital Emergency Preparedness (EP)director assured the inspector that any radiologically contaminated persons from the RCF would not be turned away. The EP director expressed interest in working with the RCF to develop procedures for an emergency situation in which Ellis Hospital would play a role. The inspector communicated this request to thelicensee and the licensee agreed to plan a meeting between the staff of RPI and the hospital. This issue will be considered by the NRC as an IFI and will bereviewed during the next inspection at the facility (IFI 50-225/2006-201-02). c.ConclusionsThe emergency preparedness program was conducted in accordance with therequirements stipulated in the Emergency Plan.11.Maintenance Logs and Recordsa.Inspection Scope (IP 69001)To verify that the licensee was complying with the applicable regulations, theinspector reviewed selected aspects of:

-13-*Operations Reports for the RPI RCF, dated April 28, 2004 and March 31, 2005*RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - presentb.Observations and FindingsThe inspector reviewed the maintenance records related to 2004 and 2005scheduled and unscheduled preventive and corrective maintenance activities.

Routine/preventive maintenance was controlled and documented in the Log Book. This review indicated that all maintenance activities were controlled and documented in the maintenance and/or operations log consistent with therequirements in 10 CFR 50.59.All maintenance of reactor systems were reviewed by the OS. Implementation ofchanges to equipment, systems, tests or experiments are generally done by anyof the staff at the facility. After all maintenance items are completed, systemoperational checks are performed to ensure the affected systems function beforereturning them to service. The inspector noted that one of the maintenanceentries was the change of the control panel layout to accommodate the new rodposition indicating devices and to consolidate other test controls. During a facilitytour, the inspector noted that Control Room and Reactor Room equipment wasoperational. No missing or malfunctioning equipment was noted. Equipment, and the facility in generally, appeared to be well maintained.c.ConclusionsMaintenance logs, records, and performance satisfied TS and procedurerequirements. 12.Fuel Handlinga.Inspection Scope (IP 69001)To verify that TS and procedural requirements were being met, the inspectorreviewed selected aspects of:*RPI RCF Log Books for the period May 22, 2002 - April 26, 2005 and April27, 2005 - present*fuel handling equipment and instrumentation

• fuel movement and inspection records

• RCFRM Chapter 4: Operations Procedures, undatedb.Observations and Findings RCFRM procedure 4.G - Fuel Handling describes the process the licensee usesfor fuel loading and unloading. The fuel in the core is generally unloaded during periods when the reactor will not be operated for a while or there are maintenanceactivities being conducted in the reactor tank. The inspector determined that the licensee was maintaining the records of the various fuel movements that had

-14-been completed and verified that the movements were conducted and recorded incompliance with procedure. All of the fuel in the core was last removed for storage on June 1, 2005, and has since been replaced in the core. Log entries in the log book in addition to the building access logs clearly identified, as required by procedure, that a minimum of two persons were present when fuel was being moved. The inspector determined that the procedures and the controls specifiedfor these operations were acceptable.The inspector observed a fuel movement on February 8, 2006, that wasnecessary to operate the reactor with a known fuel configuration. The staff member who moved the fuel performed the function in a safe and knowledgeable manner. The inspector reviewed the log book after the move and confirmed that the operator in training had performed the function in accordance with the procedures. The inspector also verified that the SRO on duty supervised the movement of the fuel.c.ConclusionsFuel handling and inspection activities were completed and documented asrequired by TS and facility procedures. 13.Follow-up on Previous Open Itemsa.Inspection Scope (IP 69001)The inspector reviewed the actions taken by the licensee following identification ofIFIs, Unresolved Items (URI) and Violations (VIO) during a previous inspection.b.Observations and Findings(1)VIO 50-225/2004-201-01 - Failure to follow the NRC-approved operatorrequalification planNRC Inspection Report No. 50-225/2004-201, dated February 11, 2004,outlined the situation. During that inspection, the inspector asked toreview records of exams administered to the licensed operators as required by the facility RORP. In reviewing the requalification records, theinspector found that one operator had not been administered a biennial comprehensive written exam as required by the RORP. The inspector noted that the FD immediately restricted the individual to performing reactor operations only under the direct supervision of the OS until a comprehensive written exam was administered as required by the RORP.During this inspection, the inspector confirmed that the licensee hadadministered a written examination to the individual operator that was lacking this requirement. The inspector also noted that the the licensee was thoroughly following all aspects of the RORP, and the operators were conducting their jobs in a safe and efficient manner. This issue is considered closed.

-15-(2)URI 50-225/2004-201-01 - NSRB to complete RCF audits by the spring2004 meetingNRC Inspection Report No. 50-225/2004-201, dated February 11, 2004,outlined the situation. During that inspection, the inspector asked toreview records of audits performed that are required to be completed by the TS 6.1.5.4. The inspector noted that the lack of an audit completedwas identified by the licensee during the NSRB meeting on December 1, 2003. The last safety and review audit was completed in early 2002. The NSRB minutes stated that the audits would be completed by the spring2004 meeting.During this inspection, the inspector confirmed that the licensee wasconducting the audits as required. The inspector also noted that the audit performed by the individual was focused on safety-related aspects of facility operations. This issue is considered closed.(3)IFI 50-225/2004-201-01 - Licensee to locate the certificate for the RAMcalibration source or re-calibrate the sourceNRC Inspection Report No. 50-225/2004-201, dated February 11, 2004,outlined the situation. During that inspection, the inspector reviewed thelicensee's program to follow the American National Standards Institute Standard N323, "Radiation Protection Instrumentation Test and Calibration." The inspector verified that, with one exception, the calibration and check sources were traceable to the National Institute of Standards and Technology and that the sources' geometry and energies matched those used in actual detection/analyses. The licensee stated that they would locate the source calibration certificate or have the source re-calibrated.During this inspection, the inspector confirmed that the licensee was inpossession of the calibration source traceability to NIST. This issue is considered closed.(4)IFI 50-225/2004-201-02 - Annual and biennial E-plan reviewdocumentation to be upgraded to allow positive verification of the reviewsNRC Inspection Report No. 50-225/2004-201, dated February 11, 2004,outlined the situation. During that inspection, the inspector reviewed thelicensee's biennial audit of the E-Plan as required by E-Plan Section 10.

The inspector determined that formal documentation of these reviews wassparse. The FD stated that documentation of the annual and biennialreviews would be upgraded to allow positive verification of the reviews.During this inspection, the inspector confirmed that the licensee wasformally documenting the annual review of the E-Plan and the Emergency Procedures on a biennial basis on a schedule of periodic requirements.

The licensee reviews this document frequently and the inspector verified that all surveillance requirements were completed in the required time.

This issue is considered closed.

-16-(5)IFI 50-225/2004-201-03 - The inoperative RCF emergency siren is to befixedNRC Inspection Report No. 50-225/2004-201, dated February 11, 2004,outlined the situation. During that inspection, the inspector reviewed thelicensee's maintenance of emergency equipment. At the time of the inspection, the RCF emergency signal, an outside mounted siren as described in E-Plan Section 8.2, was inoperative. The FD stated that thissituation would be addressed and corrected.During this inspection, the inspector confirmed that the licenseedetermined the cause of the problem with the emergency siren and immediately fixed the issue. The inspector verified that the emergencysiren works through a test of the alarm. This issue is considered closed.c.ConclusionsAll open items identified in previous inspection reports were closed. 14.Exit MeetingThe inspector presented the inspection results to licensee management at theconclusion of the inspection on February 9, 2006. A supplemental exit meeting was held with the FD on February 28, 2006. The licensee acknowledged the findings presented.

PARTIAL LIST OF PERSONS CONTACTEDP. Caracappa, Radiation Safety OfficerP. Collopy, Director, Environmental Health and Safety M. Delvecchio, Lt., Department of Public Safety M. Podowski, Moderator, NSRB P. Segovis, Ellis Hospital Emergency Preparedness DirectorT. Trumbull, Operations Supervisor G. Winters, Reactor DirectorINSPECTION PROCEDURES USEDIP 69001CLASS II NON-POWER REACTORS ITEMS OPENED, CLOSED, AND DISCUSSED Opened50-225/2006-201-01 IFIFollow-up to verify that the licensee creates a procedure trackingsystem in order to ensure that all staff are using the most current and up to date procedures50-225/2006-201-02 IFIFollow-up to verify that the licensee arranges a meeting with theEllis Hospital officials to discuss emergency proceduresClosed50-225/2004-201-01 VIOFailure to follow the NRC-approved operator requalification plan50-225/2004-201-01 URINSRB to complete RCF audits by the spring 2004 meeting 50-225/2004-201-01 IFILicensee to locate the certificate for the RAM calibration source orre-calibrate the source50-225/2004-201-02 IFIAnnual and biennial E-Plan review documentation to be upgradedto allow positive verification of the reviews50-225/2004-201-03 IFIThe inoperative RCF emergency siren is to be fixedLIST OF ACRONYMS USEDADAMSAgencywide Document Access and Management SystemALARAAs Low As Reasonably Achievable CFR Code of Federal Regulations E-PlanEmergency Plan EPEmergency Preparedness FDFacility Director IFIInspector Follow-up Item IPInspection Procedure LCOLimiting Condition for Operation NSRBNuclear Safety Review Board OSOperations Supervision

-2-RCFRMReactor Critical Facility Reference Manual RPIRensselaer Polytechnic Institute RSORadiation Safety Officer RORPReactor Operator Requalification Program SROSenior Reactor Operator TLDsThermal Luminescent Dosimeters TS Technical Specification URIUnresolved Item VIOViolations WWatts