IR 05000407/1998201
| ML20248M269 | |
| Person / Time | |
|---|---|
| Site: | University of Utah |
| Issue date: | 06/11/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20248M250 | List: |
| References | |
| 50-407-98-201, NUDOCS 9806150225 | |
| Download: ML20248M269 (18) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
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l Docket No: 50-407 License No: R-126 Report No: 50-407/98-201 Licensee: University of Utah i
Facility: Center for Excellence in Nuclear Technology, Engineering, and Research (C.E.N.T.E.R.), University of Utah l l
Location: Merrill Engineering Building I j
Salt Lake City, Utah
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Dates: January 12-16,1998 Inspector: Stephen W. Holmes, Reactor inspector
. Approved by: Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation 9906150225 980611 7 PDR ADOCK O G ENCLOSURE
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EXECUTIVE SUMMARY This routine, announced inspection consisted of the review of selected conditions and records since the last inspection, verification of corrective actions previously committed to by the licensee, and related discussions with licensee personnel. Additionally, the inspector observed a reactor critical operation frorn start-up to shutdown and calibrations of reactor instrumentation and accompanied health physics staff performing a routine survey. The inspection was conducted following the guidance of NRC Inspection Manua The reactor was being maintained and operated as required by the license and applicable
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regulations. The licensee decided to make a number of enhancements in the calibration of l counting instrumentation and documentation of contamination survey results. A mismatch was identified between a Technical Specification (TS) required calibration interval and the interval stated in the TS basis. The licensee committed to investigate the discrepancy and submit an appropriate TS change to correct the mismatch. An unresolved item was opened concerning the ability for the current continuous air monitor / stack gas monitor to detect radioactive particulate activity in the pool room as noted in TS I l
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Summary of Plant Status Reactor operations were continuing to support research, reactor operator training and educational demonstrations, as well as performing preventive maintenance and operational surveillance required by the Technical Specifications. No safety concerns were note '
l. Operationg 01 Conduct of Operations 01.1 Reactor Staffina a. Insoection Scoce (Insoection Procedu e 69001)
The inspector reviewed reactor staff qualifications, operations logs and records, selected events, and interviewed staff, Observations and Findings Licensed staff consisted of the Reactor Administrator (RA), who also temporally filled the Reactor Supervisor (RS) position and five other Senior Reactor Operators (SRO). The facility anticipated hiring one or more of the P candidates permanent upon their graduation to fill the RS and other open positions. The reactor staff satisfied the training and experience required by the Technical Specifications (TS). Operation logs and records confirmed that shift staffing met the minimum requirements for duty and on-call personne Conclusions The operations staffing of the research reactor satisfied TS requirement .2 Control and Performance of Experiments Insoection Scoce (Insoection Procedure 69001)
The inspector reviewed apcroved reactor experiments, reactor logs, documentation of experiments performed, experimental data, Reactor Safety Committee (RSC) minutes, observed an experimental run, and interviewed staf Observations and F;ndinas The inspector verified that each routine or modified experiment had been reviewed and approved by the RS, SROs, or referred to the RSC as required by TS. Review of the experiment procedures and reactor log books, interviews with staff and observation by the inspector verified that experiments were l constrained as required by the TS and experiment authorization. The l experiments were also installed, performed and removed as outlined in the experiment authorization and licensee's procedures.
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2- Conclusions License control and performance of experiments met TS and licensee requirement .3 Reactor Ooerations and Fuel Handlina Insoection Scone (Insoection Procedure 69001)
The inspector interviewed staff, reviewed reactor operations and fuel logs, and periodic checkout, start-up and shutdown checklists. The inspector also observed a start-up, steady state power operation and shutdow Observations and Findinas Reactor operations were carried out following written procedures and T Information on operational status was recorded in log books and checklists as required by procedures and TS. Use of maintenance and repair logs satisfied regulatory and licensee requirement Fuel movement and handling war infrequent. Data recorded for fuel movement was clear. Fuel movement, inspection, log keeping and recording followed the facility's procedure Conclusions Reactor operations conformed to TS and licensee procedural requirements. Fuel handling, record maintenance, and documentation were accomplished as required by TS and licensee procedures. No safety concerns were identifie Operational Status of Facilities and Equipment insuection Scone (Insoection Procedure 69001)
The inspector reviewed reactor equipment, evaluated the physical plant, and observed the facility and equipment during a tour, Observations and Findinas Equipment was accessible with little extraneous clutter. All required equipment and facilities observed by the inspector were operationa Conclusions Reactor and support facilities were operational as required.
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-3-03 Operations Procedures and Documentation Insoection Scone finsoection Procedure 69001)
The inspector reviewed operating procedures and updates, reactor operating records and logs, RSC minutes and interviewed staf Observations and Findinos Written procedures required by the TS were available and used by the staff. Use of and adherence to the procedures was acceptable. The inspector verified that the reactor facility procedures had been approved by the RSC and reviewed at least annually as required by T Records of power level, operating periods, unusual events, calibration and maintenance procedures, installed experiments and start-up and shutdown checks were being kept. The licensee's logs and records were clear, concise,
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and legible. The inspector determined that the annual reactor operating reports, logs and records acceptably documented reactor operations activities. Reactor l
operations and testing.were documented as required by the T i The inspector traced three scrams (a manual, a range switch and an electrical I power spike) identified in the logs and records and verified that they were reported and resolved as required before the resumption of operations under the '
authorization of a SR Conclusions j Facility operational procedures satisfied TS requirements. Reactor operating records and logs were being maintained as required by TS. Significant problems and events identified in the logs and records were reported and resolved as require Operator Training and Qualification Program insoection Scoce (Insoection Procedure 69001)
The inspector reviewed requalification program records, NRC licenses, training records, SRO operational hours and interviewed staf i f
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-4- Observations and Findinas Currently licensed operators were participating in the ongoing training as required by the NRC-approved requalification plan. Lectures were conducted as require The lecture outline for the reactor operator requalification program included appropriate subject material and a comprehensive written examination, which had been given and successfully passed by the senior reactor operator Requalification training records contained the documentation required by the approved operator requalification program. Biennial medical exams had been performed as require SRO operational hours were tracked to insure the personnel met the performance requirements of 10 CFR 55 as SRO Conclusions The reactor operator requalification training program was being conducted and documented in accordance with the NRC approved program. Reactor operator requalification training records were being acceptably maintained. TS and NRC-approved requalification plan requirements were me Organization and Administration Insoection Scoce (Insoection Procedure 69001)
The inspector reviewed organization, staffing and administrative controls and interviewed management and staf f Observations and Findinas Since the last inspection no functional changes in the management organization or admin;strative controls had been mad Conclusions Organizational and administrative controls remain consistent with TS and license requirements and commitment Quality Assurance in Operations Insoection Scooe finsoection Procedure 69001)
i The inspector reviewed RSC minutes, annual reviews, audits, the audit and review program checklist, and interviewed staff.
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l RSC membership satisfied TS requirements and the Committee's procedural
rules. Review of the minutes showed that the committee provided guidance, direction and oversight, and ensured suitable use of the reactor. The full l committee normally met quarterly exceeding the TS semiannual requiremen The meeting minutes provided a record of the safety oversight of reactor operation Since the last inspection all required audits of reactor facility activities and reviews of procedures, equipment changes, proposed tests or experiments, had been performed and documented. Additionally the reviews of the emergency and security plans had been co iducted and acceptably documented. The use of audit and program checklists is noteworthy, Conclusions The RSC meeting frequency sa isfied TS requirements. Audits were conducted as required. The RSC carried o it its safety duties as obligated by license, TS and administrative criteri . Maintenance M1 Conduct of Maintenance / Surveillance and Limiting Conditions for Operation
! Insoection Scoce (Insoection Procedure 69001)
The inspector reviewed selected surveillance records, data sheets and records of tests, licensee procedures, reactor logs, checklists, periodic reports and interviewed staf Observations and Findinas Daily and other periodic checks, tests, and verifications for TS required limiting conditions for operations (LCO) were completed as required. Surveillance and LCO verifications were completed on schedule as required by TS and following licensee procedures. All were within prescribed TS and procedure parr s i and in close agreement with the previous surveillance results. A r ..y of the
- surveillance were performed at more frequent intervals then requied by T In reviewing the surveillance the inspector identified a mismatch between a TS required calibration interval and the interval stated in the TS basis. TS 4. specifies that the continuous air monitoring (CAM) system shall be calibrated l
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-6-bienniallv and operationally verified monthly. However, the basis states that monthly verification in conjunction with annual calibration is adequate for this type system. The licensee, who has been doing annual calibrations of the CAM,
' committed to investigate the discrepancy and submit an appropriate TS change to correct the mismatch. This will be reviewed during a future inspection as an inspection Follow-up Item (IFI) 50-407/201-01-0 The inspector identified a few places where an obsolete term, MPC, was still used. The licensee stated that they would review the procedures, checklists, 3 logs, etc. and update them to use the current terminolog l Conclusions
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The facility's program for surveillance and LCO confirmations satisfied TS requirements. The licensee's program of performing numerous surveillance at intervals more frequent than required is recognize M2 Maintenance and Material Condition of Facilities and Equipment Insoection Scone ilnsoection Procedure 69001)
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The inspector reviewed maintenance and reactor logs, RSC minutes, repair records, and observed facility and equipment during an accompanied tou Observations and Findinas Routine / preventative maintenance was controlled and documente Unscheduled maintenance or repairs were reviewed to determine if it were a facility change requiring a 50.59 evaluation. An operations check out and a QA evaluation were performed prior to a SRO signing off on the completed maintenance or repai Conclusions Maintenance logs, records, perforrnance and maintenance reviews satisfied TS and procedure requirement ,
l 111. Engineering E1 Conduct of Engineering, Design Changes
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i The inspector reviewed procedures, logs, records, RSC fites and interviewed staff. The inspector also reviewed the change packages for the installation of a new CAM and modification of the reactor ventilation system. The inspector also reviewed the FSAR and TS basis.
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The packages for design changes were kept in the " Authorization for l Modification to Reactor Facility" book. Changes were rigorously controlled (
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approval. Questions from the committee and replies from the Reactor and HP
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staffs were documented and incorporated into the modification packages. An i upgrade verification checklist (containing tasks and tests) was also prepared including drawings / diagrams as neede The inspector reviewed the packages for the new CAM and the modification to the ventilation systern. The evaluations were extensive with supporting documentation and information. The verification testing of the systems was comprehensive and detailed. Procedure and drawing changes were included and were consistent with the observations of the inspecto )
While reviewing the change package for the new CAM and ventilation system (
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the inspector identified a possible TS conflict. Although the new CAM more !
than meets the analytical performance of the old unit, as it is installed in conjunction with the new ventilation system, there appears to be a conflict with .
TS Section 5.4 (2). This TS section indicates that the function of the l continuous air radiation monitor includes monitoring the concentration of radioactive particulate activity in the pool room, and includes alarm capabilit During normal operations the old ventilation system exhausted the reactor room air directly up the stack with no filtration. The new system continuously {
exhausts through a high efficiency particulate (HEPA) filter before being vented
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up the stack. Therefore the CAM, which pulls its air sample from the stack, will j no longer be able to monitor " particulate activity" in the pool rnom air as the air j has already gone through a HEPA filte )
However, in reviewing the final safety analysis report (FSAR) and TS on the I functioning of the original CAM and ventilation, the inspector found that the CAM was not used to initiate any protective actions in the event of airborne particulate activity. The radiation area monitor over the pool provided, and still does, the alarm that switches the ventilation from direct exhaust to venting through a HEPA filter. Therefore, the original CAM that pulled its air sample from the stack, could not have monitored " particulate activity" or alar )
Since the CAM still can monitor radioactive gases and iodines in the pool room !
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air and as continuous filtering is inherently safer and conforms with the '
regulation to use engineered safety features as much as practical to reduce exposures, the system capability and basis to monitor the pool room air for particulate activity and alarm may no longer be valid.
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descriptions, and present facility operation and submit an appropriate TS change for the system or modify it to meet the current TS I
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8-This is being left as an unresolved item, URI 50-407/201-01-01, and will be reviewed on a recurring basis, Conclusions The licensee's design changes were reviewed, approved, implemented, tested, and controlled as required by TS, licensee procedures and pertinent regulation IV. Plant Sunoort R1 Radiological Protection and Chemistry Controls R1.1 Radiation Protection Postinos Scoce (Insoection Procedure 690011 l
The inspector reviewed radiological signs and postings, routine radiation surveys and observed the facility and equipment during accompanied tour Observations and Findinos Postings were acceptable for the hazards involved. The facility and radioactive material storage were secured and properly posted. No unmarked or unsecured radioactive materials were evident. NRC Forms-3 were posted in appropriate areas in the facility as were current notices to workers required by 10 CFR 1 ,
I Conclusions Radiological postings satisfied regulatory requirement R1.2 Gaseous and Liould Effluent Monitorina and Release Scoce (Insoection Procedure 69001)
The inspector reviewed annual reports, release records, counting and analyses resul The inspector interviewed reactor and HP staff Observations and Findinos Gaseous releases were calculated from integrated power. Releases were acceptably documented and well within the annual dose constraint of 20.1101(d) and the Appendix B concentration limits, t
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. Liquid releases were minimal consisting of water from routine maintenance operations. These were analyzed by the Radiological Health Department before release. Records confirmed that releases met 10 CFR Part 20.2003 and Appendix B limits, Conclusions Effluent monitoring and releases satisfied license and regulatory requirement R1.3 Radiation Protection Survevs Scoce (Insoection Procedure 69001)
The inspector reviewed procedures and survey records and interviewed staf Observations and Findinas Monthly and other periodic contamination and radiation surveys were performed by reactor and HP staffs as required by TS and licensee procedures. Results were evaluated and corrective actions taken and documented when I rearings/results exceeded set action level d Survey results verified that contamination in the facility was infrequent and both contamination and radiation levels were well below regulatory and licensee limit s when identifie The inspector noted that some results showing no radiation or contamination levels did not indicate the lower limit or minimal detectable activity associated with the analyses including the margin of error. The licensee stated that they would change their way of recording survey results to be consistent with standard reportin Conclusions i
Surveys were performed and documented in a manner appropriate and suf ficient ;
to evaluate, as required by 10 CFR 20, the radiation hazards that might exis TS and licensee requirements were me R1.4 - Personnel Dosimetry Scooe (Insoection Procedure 69001)
The inspector reviewed dosimetry records, licensee procedures, and interviewed staff, i
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The licensee used a National Voluntary Laboratory Accreditation Program-accredited vendor to process personnel thermoluminescent dosimetry. An examination of records for the past two years showed that all exposures were within NRC limits, with most having no exposure above background. Records were reviewed by the RSO. ALARA and declared pregnancy programs were in effec Conclusions Doses were in conformance with licensee and 10 CFR 20 limits. The dosimetry i program was conducted in accordance with 10 CFR 20.1501,20.1502 and licensee procedure R2 Status of Radiation Protection and Control (RP&C) Facilities and Equipment Scone finsoection Procedure 69001)
The inspector reviewed the licensee's inventory, calibration, and periodic checks of portable radiation survey and laboratory instruments, and interviewed HP staff.
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Calibrated instruments were available at the time of inspection. Calibrations of the instruments used to perform radiation surveys were done with radioactive sources traceable to national standards. Calibration frequencies satisfied TS requirements. The licensee had a generic calibration procedure with individual calibration " checklists" for the specific meter Laboratory instruments were calibrated individually on a nonstandard basis, some formally others informally as needed. Calibrations generally followed ANSI standards or the specific manufacturers' recommendations. In discussion the licensee stated that they would formalize the calibration of the GeLi multi-channel analyzer (equivalent to that done on the mass spec unit) and evaluate I the need to perform more rigorous calibrations on liquid scintillation and gas flow proportional counters. This will be reviewed during a future inspection as an inspection Follow-up item (IFI) 50-407/201-01-02. All instruments checked were in calibration. Calibration records were in orde '
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{ RP&C equipment was being maintained according to industry and equipment manuf acturer standards. Calibrations satisfied TS requirement (
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The inspectcr reviewed Radiation Protection Program (RPP) documentation and variouc HP procedures and interviewed HP and reactor staffs.
( Observations and Findinas HP procedures were available for those tasks and items required by the TS, license, and facility directives. Changes were reviewed and approved as
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The RPP was formally documented and had been audited by the RSC annually as
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required. The inspector determined, while performing an in-office review of the licensee's audit and review program, that annual review of the radiation protection program, in accordance with 10 CFR 20.1101(c), had been performed, Conclusions The RFP satisfied the requirements of 10 CFR 20.1101. Oversight and review were provided by the RSC and the reactor and HP staffs as required by TS and licensee procedures. HP procedures met T R RP&C Organization and Administration I Scooe (Insoection Procedure 69001)
The inspector reviewed radiation protection program documentation, and interviewed staff, Observations and Findinas The Radiation Safety Office provided support to the reactor as well as being responsible for the state license. Coordination of HP activities between the HP and reactor staffs was acceptabl Conclusions HP staffing and radiation protection program documentation met TS, regulatory requirements, and licensee commitments.
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-12-R7 Quality Assurance in RP&C Activities Insoection Scoce (Insoection Procedure 69001)
The inspector reviewec Radiation Safety Committees' minutes and licensee procedure Observations and Findinas The meeting schedule and membership satisfied licensee requirement Examination of records confirmed that the committee was reviewing HP operation of the whole campus and thus that of the reactor as required. The committee provided appropriate guidance, direction, and oversight to the radiation safety progra Conclusions Oversight of the radiation safety program by the committee satisfied licensee requirement R8 . Radioactive Material Transfer / Disposal Insoection Scone (Insoection Procedure 69001)
The inspector reviewed transfer checklists, shipping and disposal records, and interviewed staf Observations and Findinas
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Production of radioactive waste at the facility was minimal. The small amount produced was handled under the campus waste disposal program. All transfers were recorded on the appropriate forms. Transfer documentation was kept on file as require l Material transferred to other authorized persons was adequately documented and -
satisfied campus and regulatory requirement Conclusions !
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Radioactive material was transferred and disposed of in accordance with licensee precedures, TS, and 10 CFR 20 requirements, i
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-13-P1 Conduct of EP Activities and Staff Training I Insoection Scoce (Insoection Procedure 69001)
The inspector reviewed the emergency plan (EP) procedures, training and drill records for the reactor and interviewed licensee employees to determine compliance with regulatory, TS and licensee requirement Observations and Findings The drill documentation consisted of a scenario and checklist of the time line of events for the exercise, a description of the emergency responders' actions as noted by the designated observers and a summary of the critique of the exercise by the participants and observers. This adequately documented the drill. The exercise was conducted in accordance with, and fulfilled the requirements stipulated in the Emergency Plan. Key licensee emergency response personnel demonstrated that they could respond to emergencies as required. Offsite response by security, law enforcement, and other responders were appropriate for the scenario involve Training records verified that acceptable training had been provided to in-house staff and outside responder Conclusions The licensee's emergency plan was effectively implemented as required. EP drills and training were conducted as require P2 Status of EP Facilities, Equipment, and Resources Insoection Scone (Insoection Procedure 69001)
The inspector reviewed inventory records, checked EP facilities, equipment, and supplies, and interviewed staf Observations and Findinas Equipment and supplies were as required by the EP and inventory record Support facilities and communications were as state Conclusions EP facilities, equipment, and resources satisfied the approved plan requirements.
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.. P3 EP Procedures and Documentation Insoection Scone (Insoection Procedure 69001)
The inspector reviewed the EP documents and implementing procedures and interview staff.
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The procedures were current, approved and were readily available for use by
'esponse personnel. They adequately addressed classification, notification, and protective actions required during an emergency to protect the health and safety of the rublic, implementing procedures were consistent with the EP
' requirements. Emergency phone and on-calllists were also readily available and up to dat Conclusions EP procedures and documentation were as required by the NRC approved EP and licensee requirement V. Management Meetings X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on January 16,1998. The licensee acknowledged the findings presente i
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e PARTIAL LIST OF PERSONS CONTACTED Licensee
'D. Slaughter Reactor Administrator
' Thompson Radiation Safety Officer, Environmental Health and Safety
- M. Krahenbuhl Senior Reactor Operator
- K. Weaver Senior Reactor Operator
' Attended Out Briefing INSPECTION PROCEDURE (IP) USED IP 69001: CLASS ll NON-POWER REACTORS ITEMS OPENED, CLOSED, AND DISCUSSED Opened IFl 50-407-98 201-01 The licensee will investigate the discrepancy between annual and biennial calibrations of the CAM stated in TS 4.3.3 and submit an appropriate TS change to correct the mismatc IFl 50-407-98-201-02 Licensee will formalize the calibration of the GeLi multi-channel analyzer (equivalent to that done on the mass spec unit) and evaluate the need to perform more rigorour calibrations on liquid scintillation and gas flow proportional counter URI 50-407-98-201-01 The licensee stated that they would evaluate the TSs, FSAR facility operation descriptions, and present facility operation of the CAM / ventilation system and submit an appropriate TS change for the system or modify it to meet the current TS Cleatd NONE l
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e PARTIAL LIST OF ACRONYMS USED CAM Continuous Air Monitoring FSAR Final Safety Analysis Report HEPA High Efficiency Particulate HP Health Physics LCO Limiting Conditions for Operations NRC Nuclear Regulatory Commission RPP Radiation Protection Program
! RS Reactor Superviso RSC l Reactor Safety Committee l
.SRO Senior Reactor Operator
'TS Technical Specifications
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