IR 05000288/1997202

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Insp Rept 50-288/97-202 on 971215-18.Violations Noted. Major Areas Inspected:Organization & Staffing,Review & Audit Functions,Procedures,Radiation Protection & Safeguards & Security Program
ML20199C115
Person / Time
Site: Reed College
Issue date: 01/23/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20199C091 List:
References
50-288-97-202, NUDOCS 9801290135
Download: ML20199C115 (17)


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ENCLOSURE 2

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U S. NUCLEAR REGULATORY COMMISSION

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Docket No: 50-288

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4-License No: R 112 l - Report No: 50-288/97 202 i Licensee: Reed College

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Facility: Reed College Reactor Facility i

Location: 3203 S.E. Woodstock Boulevard .

Portland, OR 97202-8199 Date' December 15 18,1997

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Inspector: C. H. Bassett-Senior Non-Power Reactor inspector

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t Approved by: Seymour H. Weiss, Director Non-Power Reactor and Decommissioning Project Directorate i

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9801290135 980123 4 PDR ADOCK 05000288 G PDR .

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EXECUTIVE SUMMARY Reed College Report No: 50-288/97 202 The primary focus of this routine, announced inspection was the on site review of selected .

aspects of the licensee's Class 11 non-power reactor operation including: organization and l

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staffing; review and audit functions; procedures; radiation protection and ALARA programs; i effluer;t and environmental monitoring; the shipment of radioactive mate *ial; the safeguards 1 and security program; and the material control and accounting progra '

Changes, Organization, and Staffino

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  • The licensee's organization and staffing remain in co"1pliance with the requirements j specified in the Technical Specification Review and Audit Functions
  • Aucits were being conducted by the Radiation Safety Committee (RSC) and the Reactor Operations Committee (ROC)in compliance with the requirements specified in the Technical Specifications (TS).

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  • One violation was noted for failure of the RSC to meet twice yearly as required by the TS.

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Procedures e Facility procedures were acceptable and satisfied TS and administrative procedure 4 requirements for being revised by the licensee, and revier.ed and approved by the RSC.

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Radiation Protection Program.

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e An apparent violation with two examples was noted dealing with failure to follow procedure *- Surveys were generally completed and documented acceptably to permit evaluation of the radiation hazards that might exis * Postings met the regulatory requirements.

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  • Personnel dosimetry was being worn as required and doses were well within the licensee's procedural action levels, and NRC's regulatory limits.

s e Radiation monitoring equipment was being maintained and calibr ited as required.

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  • The Radiation Protection and ALARA Programs satisfied regulatory requirement e a

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Effluent and Environmental Monitoring

  • Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limit Transportation of Radioactive Materials e An apparent violation was noted for f ailure properly to complete the required shipping papers for eight shipments of radioactive materia Safeguards and Security
  • The NRC approved security program at the facility was acceptably carried ou Material Control and Accountability
  • One violation was identified for failure to submit material status reports withing the time frame specified in the regulations.

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REDORT DETAILS Summary of Plant Status The licensee's two hundred and fifty-kilowatt (250 kW) TRIGA Mark l research reactor continues to be operated in support of undergraduate instruction and laboratory experiments, reactor operator training, and various types of research. During the inspection, the reactor was not operated because it was " finals" week and students were taking their final examination . Changes, Organization, and Staffing (69001)

a. Inspection Scope The inspector reviewed the following regarding the licensee's organization and staffing to ensure that the requirements of Technical Specification (TS) Sections 1.1.1,1.1.2, and 1.1.3 were being met:

. the organizational structure,

. management responsibilities, and

. staffing requirements for safe operation of the Reed Reactor Facility (RRF).

b. Observations and Findings Through discussions with licensee representatives the inspector determined that management responsibilities and the organization at the f acility had not changed since the previous NRC inspection in December 1994 (Inspection Report No. 50 288/94-01). The inspector determined that the Facility Director retained direct control and overall responsibility for managerrent of the facility as specified in the TS. The Facility Director reported to the President of Reed College through the Dean of the Facult Through review of records and logs and discussions with licensee personnel, the inspector determined that the staffing at the facility was acceptable to support the work and ongoing activities and met the requirements of the T Conclusions The licensee's organization and staffing remain in compliance with the requirements specified in the Technical Specification . Review and Audit Functions (69001)

, inspection Scope The inspector reviewed the following to ensure that the audits and reviews stipulated in the requirements of TS 1.2 and 1.3 were being completed: 4

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Reactor Operations Committee (ROC) meeting minutes,

. Radiation Safety Committee (RSC) meeting minutes,

  • RRF Administrative Procedures, and

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+ the TS duties specified for the ROC and the RSC including the committees'

review and audit function The inspector nisn toured the licensee's facility to note any changes that may have been made ant .aviewed the program established by the licensee to ensure that activities at the facility were reviewed and audited as required, Observations and Findings Section 1.2 Of the TS requires that the Radiation Safety Committee meet at least twice yearly to review safety aspects of f acility operatio The inspector reviewed the ROC's and RSC's meeting minutes from January 1995 to the present. These meeting minutes showed that the ROC and the RSC had considered the types of topics outlined by the TS. During the review, the inspector noted that a meeting of the RSC had been c.alled in May 1997. The RSC apparently met but a quorum was not present, no official actions could be taken, and no meeting minutes were recorded. The RSC did meet again in September but no second, formally documented meeting was convened to meet the requirements of the T The licensee was informed that failure of the RSC to meet twice yearly to review safety aspects of the facility operation was an apparent violation of TS 1.2 (VIO 50-288/97 202-01).

The inspector noted that both committees completed audits of different but complimentary aspects of the r0 actor facility operations and programs. The inspector noted that, since the last NRC inspection, audits had been completed by the ROC and the RSC in those areas outlined in the TS. The audits were varied so

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that all aspects of the licensee's safety program were reviewed every one, two, or three years depending on the subject. The inspector noted that the audits and the resulting findings were detailed and that the licensee's responses and corrective actions were acceptabl The inspector toured the control room, pool area, and selected supoort laboratories and areas. Control of radioactive material and control of access to radiation areas were acceptabl Conclusions 4 One violation was notad for failure of the RSC to meet twice yearly as required by the T Audits were being conducted by the ROC and the RSC according to the requirements specified in the Technical Specifications, i

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3 Procedures (69001)

- Inspection Scope The inspector reviewed the following to ensure that the requirements of TS Section I were being met concerning written procedures:

-+ selected operations procedures,

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the process used by the licensee to revise, review, and approve all facility procedures, Observations and findinas The inspector verified that written procedures were reviewed as required. Also, revisions to procedures were presented by the licensee to the RSC and/or the ROC for review and approval. The inspector verified that the latest revision to the RRF Standard Operating Procedure (SOP) 20, Health Physics, had been reviewed and approved by the RSC on January 1997. The revisions were acceptable and in accordance with 10 CFR 20, TS, and RRF Administrative Procedures, Conclusions Facility procedures were acceptable and satisfied TS and administrative procedure -

requirements for being revised by the licensee, and reviewed and approved by the

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RSC and the RO . Radiation Protection Program (69001)  ; l_nmection Scope The inspector reviewed the following to verify compliance with 10 CFR 20 and the applicable licensee TS requirements and procedures:

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health physics (HP) and reactor surveillance survey records,

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radiological signs and posting,

+ dosimetry records,

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calibration records and periodic check records for radiation monitoring instruments,

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the Radiation Protection Program, and

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the ALARA Progra The inspector also observed the use of dosimetry and radiation monitoring equipment during tours of the facility. Licensee personnel were interviewed as wel Observations and Findings (1) Surveys TS l.5 requires that written instructions shall be in effec __-___-


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SOP 23, " Health Physics Wipe Tests," dated November 1997, requires in Section 23.2 that wipe test shall be performed (inside the RRF) at least every two weeks, not to exceed 18 days, and whenever activities involving radioactive materiais require additional wipe test The inspector noted through reviews of records that daily and weekly ,

contamination and/or radiation surveys were completed by the RRF staf f as required by TS and licensee procedures. Results were evaluated and corrective actions taken when readings or results exceeded set action level However, a review cf the biweekly wipe tests showed that a wipe test had been completed on April 11,1997 and not again until April 30, a period exceeding 18 days. Also, following the wipe test on April 30,1997, the next wipe test was not conducted until May 23, a second period exceeding the 18-day maximum allowable time The wipe tests are used by the licensee to detect and determine the extent of removable contamination inside the RRF '

and to monitor exits from the facility to determine if contamination is being spread outside the facility. During the period from April through May, routine operations were being conducted. No unacceptable cont 6mination was detected on subsequent wipe test The licensee was informed that failure to perform the biweekly wipe tests within the 18-day time frame allowed by procedure wes an apparent violation of TS l.5 (VIO 50-288/97-202-02),

(2) Postings and Notices 10 CFR 19.11 requires the licensee to post current copies of various documents including the regulations in 10 CFR 20, the f acility license, procedures, and any notice of violation as applicable. If it is not practicable to post such documents, the licensee may post a notice which describes the document and states where it may be examined. The licensee is also required to post e :urrent copy of NRC Form Postings at the entrances to the controlled areas, including the Reactor room, were acceptable for the hazards present. The f acility's radioactive material storage areas were properly posted. No unmarked radioactive material was note Copies of current notices to workers required by 10 CFR Part 19 were posted in appropriate areas in the facility, Copies of NRC Form 3, although not the most current, were also poste The licensee was informed that failure to post current copies of NRC Form 3 was an apparent violation of 10 CFR 19.11. However, this failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation (NCV), consistent with Section IV of the NRC Enforcement Policy (NCV 50-288/97-202-03).

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5 (3) Dosimetry The licensee used a National Voluntary Laboratory Accreditation Program (NVLAP) accredited vendor to process personnel thermoluminescent dosimetry. An examination of the records for the past three years through the date of the inspection showed that all exposures were well within NRC limits and licensee action levels. Most of the records suggested no exposure above background. Dosimetry was acceptably used by facility personne (4) Radiation Monitoring Equipment Selected radiction monitoring equipment had the acceptable up t&date calihetion sticker attached. The calibration of portable survey meters was typically completed by the Reactor HP, CLiibration frequency me' procedural requirements and records were maintained as require (5) Radiation Protection Program The licensee's Radiation Protection Program was established in the " Reed Reactor Facility Radiation Protection Plan," dated August 1994. It had been reviewed and approved by the RSC and the ROC. The program included

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requirements that al! personnel who had unescorted access to the RRF receive training in radiation protection, policies, procedures, requirements, and facilities. The program appeared to be acceptabl No Respiratory Protection Program was require SOP 28, " Radiation Work Permits," dated August 1994, Section 2 requires that the Radiation Work Permit (RWP) shall be reviewed and approved by the Director or the Associate Director prior to the operatio The inspector reviewed the RWPs that had been written and used during the past three years. It was noted that RWP #2, dated November 2,1996, Part I, had been written by the Associate Director. The RWP had been reviewed and approved by a Senior Reactor Operator (SRO) and the operation completed. The RWP had not been reviewed by the Director prior to the operation as required. The licensee indicated that this was en apparent oversight by the staf The licensee was informed that failure to have RWP #2 reviewed and approved by the Director prior to the operation was another example of an apparent violation of TS l.5 (VIO 50 288/97-202-02).

(6) ALARA Program The ALARA Program was also outlined and established in the licensee's

" Reed Reactor Facility Radiation Protection Plan," dated August 1994 and emphasized in the " Reed College Radioactive faaterials Procedures Manual,"

and in the " Reed Reactor Facility Training Manual." The ALARA program provided guidance for keeping doses as low as reasonably achievable and was consistent with the guidance in 10 CFR 2 _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _

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6 Conclusions Two examples were noted concerning an apparent f allute to foilow procedure Surveys were generally completed and documented acceptably to permit evaluation of the radiation hazards that might exist. Postings met regulatory requirement One NCV was identified for failure to post a current copy of NRC Form Personnel dosimetry was being worn as required and doses were well within the ;,

licensee's procedural action levels and the NRC's regulatory limits. Radiation

. monitoring equipment was being maintained and calibrated as required. The Radiation Protection Program and the ALARA Program satisfied regulatory requirement ..

5. Effluent and Environmental Monitoring (69001) Inspection Scope The inspector reviewed the following to verify compliance with the requirements of 10 CFR 20 and TS G.1-3:

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the licensee's environmental monitoring program,

+ annual reports,

+ release records, and

+ .:ounting and analysis records, Observation and Findings Gaseous releases were calculated as outlined in the licensee's approved methods -

and documented in the 1996-1997 Annual Report. The inspector noted that the

gaseous releases documented in the 19951996 and the 19961997 Annuel Reports were apparent discrepancies. The reports indicated a release in * mci" (millicuries) as opposed to the typical "uCi" (microcuries) range, it was also noted that the calculated release during the 1995-1996 period was reported as a 5.3 E-9

" mci"/ml (millicuries per milliliter) whereas the calculated release during the 1996 1997 period was 1.8 E 11 " mci"/ml. It was pointed out that the figure of 5.3 E 9 was probably a factor of 100 too high, based on the available data. The licensee stated that these issues would be reviewed and corrected as neede The licensee was informed that their actions to review and correct the release data

- documented in the past two annual reports would be tracked by the NRC as an

- Inspector Follow-up Item (IFI) and reviewed during a subsequent inspection (IFl 50-288/97 202-04). --

Based upon a review of the data, the re: eases during 1995-1996 and 1996-1997, appeared to be well within the annual dose constr 'nt of 20.1101(d) and TS limit No liquid releases had occurred at the f acilit: Conclusion Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limit _ _ _ _ _ _ _ _ _ _

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6. Transportation (86740) Inspection Scope The inspector interviewed licensee personnel and reviewed various records to verify compliance with the requirements of 10 CFR 71.5 br shipments of licensed material, Ouservations and Findings 10 CFR 71.5(a) requires that a licensee, who delivers licensed material to a carrier for transport, comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT)in 49 CFR Parts 171 18 CFR 171.2(a) prohibits any person from offering hazardous material for transportation unless, among other requirements, the hazardous material is properly classified, described, packaged, marked, labeled, and in condition for shipment required or authorized under the Hozardous Material Regulations (49 CFR 171 177).

Through records reviews and discussions with licensee personnel, the inspector determined that various shipments of licensed material had been made since the last inspection. All shipment records had been completed and were being maintained a required. The records showed that, in general, the material had been properly described and classified, that ths correct labeling had been provided, and that the contamination and radiation levels of th9 packages shipped had been recorded acceptably. However, some discrepancies were noted on the shipping papers as follows:

(1) Shipment Number (No.) 95-1, dated March 30,1995 - The shipping papers did not list the chemical or physical form of the material being shipped. The chemical form and physical form of the material are required to be listed on

, the shipping paper (2) Shipment No. 95-2, dated October 2,1995 - The shipping papers showed the Transport Index (TI) as "O." The dose rate at one meter from the package was 0.2 millirem per hour (mr/hr). Therefore, the correct Tl would have been (3) Shipment No. 96-2, dated May 17,1996 - The external radiation level of the package was 1.5 mr/hr. According to the shipping papers, the package was labeled with a Radioactive White Ilabel. With an external radiatio, level of 1.5 mr!hr, the package required a Radioactive Yellow 11 labe (4) Shipment No. 96 3, dated December 16,1996 - The shipping papers indicated the Tl as "0." The dose rate at one meter from the package was 0.2 mr/hr. Therefore, the correct Tl would have been 0.2. Also, the chemical arid physical form of the material being shipped was not listed as require _ __ _ _ _ _ _ _ _ _

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(5) Shipment No. 971, dated May 6,1997 The external radiation level of the package was 1.0 mr/hr. According to the shipping papers, the package was labeled with a Radioactive White I label. With an external radiatior level of 1.0 mr/hr, the package required a Radioactive Yellow 11 labe (6) Shipment No. 97 2, dated July 11,1997 The total activity was not listed in the International System of Units (SI units) or in both Si units and the customary units (i.e., curies or mil:icuries, etc.). The listing of total activity in SI units or both Si and customary units on the shipping papers was required after April 1,199 (7) Shipment No. 97-3, dated December 1,1997 - The total activity was not listed in the International System of Units (St units) or in both SI units and the customary units. The listing of total activity in Si units or both Sl and customary units on the shipping papers was requ' red after April 1,199 Also, the shipping papers showed the Transport index (TI) as ~0.5." The dose rate at one meter from the package was less than 0.2 mr/hr or background. Therefore, the correct Tl would have been The licensee was informed that f ailure to fill out the shipping papers according to the regulations was an apparent violation of 10 CFR 71.5(a) (VIO 50-288/97-202-05). Conclusions One apparent violation was nJted for feilure properly to comolete the required shipping papers for eight shipments of radioactive materia . Physical Security (81401,81402,81431)

, Inspection Scope

, To verify compliance with the licensee's NRC-approved Physical Security Plan (PSP) and to assure that changes, if any, to the plan had not reduced its overall effectiveness, the inspector reviewed:

. logs, records, and reporn, a the security organization,

. key control,

. Intruder detection and physical barriers,

. access controls, and

+ procedure . Observations and Findings The inspector determined that the licensee's physical protection program conformed to NRC requirements and the licensee's PSP and implementing procedure _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

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9 Conclusion The NRC-approved security program at the facility was acceptably carried ou .

12. Material Control and Accounting (85102) Inspection Scope To verify compliance with 10 CFR 70, the inspector reviewed:

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procedures for tracking the quantity, identity, and locaCon of Special Nuclear

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+ assignment of responsiollitieJ,

+ annual inventory results, and

+ associated records and reports, Observations and Sindings The des 10n of item colitrol areas ensured that physical and administrative control-of SNM would be maintained. Licensee procedures for tracking SNM were acceptably implemented. Written stattments of responsibility and authority were 4 established for positions with respansibility for SNM. Records showed that physicalinventories were conducted at least annually as required by 10 CFR 70.51(d).

10 CFR 74.13(1) requires that each licensee shall compile a report as of March 31 and Septembs 30 of each year and file it within 30 days after the end of the period covered by the repor Material Status Reports (DOE /NRC Form 742) had been submitted by the licenses for the appropriate periods from October 1,1994, through September 30,1997, as required by 10 CFR 70.53. However, the report covering the period from October 1,1995, through March 31,1996, had not been submitted with 30 days of the end of the reporting period but had been submitted on May 22,199 Similarly, the report for the period from April 1,1996, through September 30, 1996 had been submitted on November 20,1996. The report for the period from October 1,1996, through March 31,1997, had been submitted May 13,199 The report for the period from April 1,1997, through September 30,1997, had been submitted on November 4,199 The licensee was informed that failure to submit the reports within 30 days after the end of the period covered by the reports was an apparent violation of 10 'i 74.13 (VIO 50-288/97-202-06).

Exhibits I and 11 (attached to this report) summarize the licensee's uranium and plutonium material balances from October 1,1994 through September 30,199 . - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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10 Conclusion

. One violation was identified for failure to submit material status reports within the time frame specified in the regulation . Exit interview (

The inspection scope and results were summarized on December 18.1997, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector, e

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E/ RTIAL LIST OF PERSONS CONTACTED

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Licanun S.- Frantz, Director, Reactor Facility >

C. Melhus, Assistant Director, Reactor Facility A. Meadenhall, Shift Supervisor, Community Safety

- T. Shaver, Shift Supervisor, Community Safety P. Steinberger, Dean of the Faculty, Reed College l 4-lNSPECTION PROCEDURES USED IP 69001: Class 11 ilon Power Reactors IP 81401: Plans, Procedures, and Reviews IP 81402: Reports of Safeguards Events IP 81431: Fixed Site Physical Protection of Special Nuclear Material of Low Strategic Significance IP 85102: Material Control and Accounting Reactors '

IP 8674C: Inspection of Transportation Activities _

ITEMS OPENED CLOSED. AND DISCUSSED Ooened 50 288/97 202-01 VI Failure of the RSC to meet twice yesrly to review safety aspects of the facility operatio /97 202-02 VI- Failure to follow procedure due to failure to perform the biweekly wipe tests within the 18-aay time frame allowed by procedure and f ailure to have RWP #2 reviewed and approved by the Directo /97 202-03 NCV- Failure to post a current copy of NRC Form 3 as required by 10 CFR 19.1 /97-202-01 IFl Follow-up on the licensee's actions to review and correct the release data documented in the past two annual report /97-202-05 -VI Failure to fill out the shipping papers according to the 49 CFR 171-189 as required by 10 CFR 71.5(a).

50-288/97-202-06 VI Failure to submit the reports within 30 days after the end of the period covered by the report Closed None

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l UST OF ACRONYMS USED ALARA As low as reasonably achievable i- CFR Code of Federal ReCulations IFl ' Inspector Follow up ltem

~iP - Inspection Procedure

. . kW kilowatt NCV Non-Cited Violation NRC- Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program

. POR Public Document Room PSP Physical Security Plan ROC Reactor Operations Committee

. RRF Reed Reactor Facility RSC Radiation Safety Committee RWP Radiation Work Permit SOP' Standard Operating Procedure 1

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SNM Special Nuclear Material

! .Tl Transportation Index TS Technical Specification VIO Violation

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O EXHIBIT I REED REACTOR FACILITY Docket No. 50-288 License N R-112 Material Balance for Period: October 1,1994 - September 30,1997 Report:ng Identification Symbol: ZSW Report Units: Grams High Enriched Uranium Plutonium Element isotope Element isotope Beginning invento'y: 6 6 2 2 (October 1,1994)

Receipts:

From Flur Daniels Hanford (HTA): 4 4 0 0 Production: 0 0 1 1 Material to Account for: 10 J 3 J Removals:

Shipments: 0 0 0 0 Fission and Transmutation: 0 0 0 0 Inventory Difference: 0 0 0 0 Decay: O O O O Total Removals: 0 0 0 0 Ending inventory:

(September 30,1997) 10* 1Q* J' * 3**

  • = Fission chambers
  • * = Contained in the fuel (the licensee's PuBe suurces are maintainedIlicensed under a State of Oregon license)

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EXHIBIT ll REED REACTOR FACILITY Docket No. 50 288 License N R-112 Material Balance for Period: O_g,tober 1,1994 - September 30,1997 Reporting identification Symbol: ZSW Report Units: Grams Low Enriched Uranium e

Element Isotope Beginning inventory: 12596 2475 (October 1,1994)

Receipts: 0 0 Material to Account for: 12596 _217_Q Removals:

Shipments: 0 0 Fission and Transmutation: -5 -6 Inventory Difference: 0 0 Decay: 0 0 Total Removals: -5 -6 Ending Inventory:

(September 30, 1997) - 12591 2469 a

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