IR 05000128/2022201

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Tees/Tamu, NSC U.S. NRC Routine Inspection Report No. 050000128/2022201
ML23031A255
Person / Time
Site: 05000128
Issue date: 02/02/2023
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Joel Jenkins
Texas A&M Univ
References
IR 2022201
Download: ML23031A255 (1)


Text

February 2, 2023

SUBJECT:

TEXAS A&M ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000128/2022201

Dear Mr. Jenkins:

From November 28 - December 1, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection, at your Texas Engineering Experiment Station/Texas A&M University System Nuclear Engineering and Science Center facility. The enclosed report documents the inspection results, which were discussed on December 1, 2022, with you, Rich Waer, Associate Director - Operations and Research, Abby Kurwitz, Radiation Safety Officer, and Dr. Lisa Akin, Texas Engineering Experiment Station Director - designee.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspector observed various activities in progress, interviewed personnel, and reviewed selected procedures and records. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by email to Craig.Bassett@nrc.gov.

Sincerely, Signed by Tate, Travis on 02/02/23 Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-128 License No. R-83 Enclosure:

As stated cc: See next page

Texas A&M University Docket No. 50-128 cc:

Mayor, City of College Station State Energy Conservation Office P.O. Box Drawer 9960 Comptroller of Public Accounts College Station, TX 77840-3575 P.O. Box 13528 Austin, TX 78711-3528 Governors Budget and Policy Office PO Box 12428 Austin, TX 78711-2428 Scott Miller, Reactor Operations Manager Texas A&M University Nuclear Engineering and Science Center Texas Engineering Experiment Station 1095 Nuclear Science Road, MS 3575 College Station, TX 77843 Dr. Dimitris C. Lagoudas, Deputy Director Texas A&M University Texas Engineering Experiment Station 241 Zachry Engineering Center College Station, TX 77843 Radiation Program Officer Bureau of Radiation Control Department of State Health Services Division for Regulatory Services 1100 West 49th Street, MC 2828 Austin, TX 78756-3189 Ashley Forbes, Director Radiation Materials Division, MC 233 Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

ML23031A255 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME CBassett NParker TTate DATE 2/1/2023 2/2/2023 2/2/2023

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-128 License No.: R-83 Report No. 05000128/2022201 Licensee: Texas A&M Engineering Experiment Station/Texas A&M University System Facility: Nuclear Engineering & Science Center Location: College Station, Texas Dates: November 28 - December 1, 2022 Inspector: Craig Bassett Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Texas A&M Engineering Experiment Station/Texas A&M University System Nuclear Engineering & Science Center Inspection Report No. 05000128/2022201 The primary focus of this routine, announced inspection included onsite review of selected aspects of the Texas Engineering Experiment Station/Texas A&M University System (TEES/TAMU, the licensees) Class II research and test reactor safety programs including:

(1) organization and staffing; (2) procedures; (3) health physics; (4) design changes; (5) committees, audits and reviews, (6) transportation activities since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas; and (7) follow-up on previously identified items. The NRC staff determined the licensees safety program was acceptably directed toward the protection of public health and safety.

Organization and Staffing Organization and staffing were consistent with the requirements outlined in Section 6 of the technical specifications (TSs).

Procedures Facility procedural review, revision, control, and implementation satisfied TS requirements.

Health Physics The facility Radiation Protection and as low as reasonably achievable (ALARA) programs satisfied regulatory requirements.

Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

Design Changes Changes to the facility were evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments, and were reviewed and approved as required.

Committees, Audits and Review The Reactor Safety Board (RSB) completed the review, oversight, and audit functions required by TS.

Transportation Activities Radioactive material was shipped in accordance with the applicable regulations.

Inspection Follow-up Items One Unresolved Item and one Inspection Follow-up Item (IFI) were reviewed and closed.

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REPORT DETAILS Summary of Facility Status The TEES/TAMU System Nuclear Engineering & Science Center (NESC) TRIGA nuclear research reactor, licensed to operate at a maximum steady-state thermal power of 1 megawatt, continued operation in support of operator training, surveillance, research, and utilization involving neutron activation analysis. During the inspection, the reactor operated as needed at various power levels up to 900 kilowatts to conduct sample irradiations and research.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)

The inspector reviewed selected aspects of the following regarding the licensees organization and staffing to ensure that the requirements specified in TS Section 6.1 were met:

current facility TSs administrative controls and management responsibilities specified in the TSs TEES/TAMU 2020 annual report, submitted to the NRC on December 31, 2020 TEES/TAMU 2021 annual report, submitted to the NRC on December 31, 2021 NESC standard operating procedure (SOP), chapter I, Policy and Administrative Procedures b. Observations and Findings The inspector determined that the structure and functions of the licensees organizational structure at the TEES/TAMU NESC research reactor facility changed since the last inspection (refer to NRC Inspection Report No. 50-128/2021-201). The NESC Director title was changed to Reactor Facilities Director and a new person appointed to fill that position. The position of Associate Director - Facilities & Research was changed to Associate Director - Operations & Research and a new person was appointed to fill that position. The position of Manager of Operations was eliminated and the person filling that position was now the Reactor Supervisor. A new person was appointed as the Radiation Safety Officer. The inspector found the licensees organizational structure and assignment of responsibilities, as reported in the annual reports, were consistent with those specified in TS section 6.1. The inspector verified that all positions were staffed with qualified personnel. The inspector confirmed that management responsibilities were administered.

c. Conclusion The inspector confirmed that the licensees organization and staffing were in compliance with the requirements specified in TS section 6.1.

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2. Procedures a. Inspection Scope (IP 69001, Section 02.03)

The inspector reviewed the following to ensure that the requirements of TS section 6.4 were met concerning written procedures:

NESC SOP chapter I, Policy and Administrative Procedures RSB meeting minutes for 2021 through the present (RSB meeting Nos. 192 - 199)

TEES/TAMU 2018 and 2019 annual reports b. Observations and Findings The inspector determined that oversight and review of procedures, and the implementation thereof, was completed by licensee management and the RSB. The inspector reviewed the implementation of the procedure change process at the facility and determined that it was followed. During the inspection, the inspector noted that the licensee is in the process of reviewing and revising many of the older procedures that are still in use at the facility.

c. Conclusion The inspector determined that procedure review, revision, and implementation satisfied TS requirements.

3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)

The inspector reviewed selected aspects of the following to verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, and TS sections 3.5, 4.5, 5.4, and 6.6:

TEES/TAMU 2020 and 2021 annual reports the revised Radiation Safety Program manual RSB meeting minutes for 2021 through the present effluent monitoring program results for 2021 and 2022 personnel dosimetry records for 2020, 2021, and to date in 2022 RSB completed audits and reviews from 2021 through the present selected NESC instrument calibrations for 2021 through the present various sections in SOP chapter VII, Radiation Protection Procedures counting and analysis records associated with liquid and airborne releases for the past 2 years selected monthly and other periodic routine contamination and radiation surveys for 2021 through the present-4-

b. Observations and Findings (1) Surveys The inspector confirmed that periodic contamination and radiation surveys were completed in accordance with radiation protection procedures, and that survey results were documented and posted so that facility personnel could maintain their doses ALARA.

(2) Postings and Notices The inspector verified that the current version of NRC Form 3, Notice to Employees, was prominently posted as required by 10 CFR 19.11, Posting of notices to workers. The inspector confirmed that radiological signs were also posted as required by 10 CFR 20.1902, Posting requirements.

During a tour of the reactor building, the licensee and inspector found an unposted high radiation area in the lower research level. The licensee took immediate action by cordoning off the area and placing the proper signs around the area. An area beyond a door leading to the outside the facility was posted with a no entry sign at the edge of the area which had a reading of 2 millirem per hour so that no unmonitored person could gain access. A Stand Down was ordered by the Facility Director to investigate the problem, conduct training, and reiterate/emphasize the safety conscious work environment concept.

(3) Dosimetry The inspector observed that dosimetry use was in accordance with facility procedures and doses to workers were within 10 CFR Part 20 limits.

(4) Calibration and Maintenance of Radiation Monitoring Equipment The inspector found that installed and portable radiation monitoring equipment was calibrated in accordance with facility procedures and at the frequencies required by the TSs.

(5) Radiation Protection Training The inspector reviewed the radiation protection training given to staff members, authorized experimenters, students, and visitors, and found that training was in accordance with facility procedures and regulatory requirements.

(6) Environmental Monitoring and Effluents The inspector determined that on-site and off-site gamma radiation monitoring was completed using the reactor facility stack effluent monitors, area monitors, and various environmental monitoring optically stimulated luminescence dosimeters. The inspector reviewed that data and verified that there were no measurable doses above regulatory limits.

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The inspector determined that gaseous releases continued to be monitored as required by regulations, were calculated according to established protocol, and were documented in the annual reports. The inspector confirmed that airborne concentrations of the gaseous releases were well within the annual dose constraints of 10 CFR Part 20, Appendix B concentrations, and TS limits.

The inspector reviewed radioactive liquid waste sewer release data which indicated that the total activity released was below regulatory limits.

c. Conclusion The inspector determined that the Radiation Protection Program, as implemented by the licensee, satisfied regulatory requirements.

4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)

To determine whether modifications to the facility, if any, were consistent with 10 CFR 50.59 the inspector reviewed:

RSB meeting minutes for 2021 through the present NESC SOP, chapter I, Policy and Administrative Procedures TEES/TAMU 2020 and 2021 annual reports b. Observations and Findings The inspector confirmed that, if the licensee proposed changes to certain structures, systems, or components, and experiments at the NESC reactor facility, such changes would be reviewed by a staff member followed by approval by the Facility Director and an RSB review. The inspector found that the process was focused on safety and met licensee program requirements. The inspector noted that no 50.59 screens or reviews performed at the facility required an evaluation.

c. Conclusion The inspector determined that the licensees design change program was implemented as required by procedure and regulatory requirements.

5. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)

To verify that the licensee established and conducted reviews and audits as required in TS section 6.2, the inspector reviewed:

RSB meeting minutes for 2021 through the present completed health physics audits and reviews from 2020 through 2022 NESC SOP chapter I, Policy and Administrative Procedures TEES/TAMU 2020 and 2021 annual reports-6-

b. Observations and Findings (1) Reactor Safety Board (RSB)

The inspectors review of the RSB meeting minutes indicated that the committee met at least annually as required by the TSs and that a quorum was present for each meeting. The inspector determined that the topics considered during the meetings were as stipulated in the TSs.

(2) Reviews and Audits The inspector found that the requirements involving review and approval of facility changes stipulated in 10 CFR 50.59, were implemented at the facility through a new facility procedure entitled Change Management. The inspector confirmed that the procedure incorporated criteria provided by the regulations with additional requirements mandated by site-specific conditions. The inspector confirmed that no changes or modifications were completed which required anything other than the completion of a screen form.

c. Conclusion The inspector determined that the RSB completed review, audit, and oversight functions required by TS section 6.2.

6. Transportation Activities a. Inspection Scope (IP 86740)

The inspector reviewed the following documents to determine compliance with NRC and Department of Transportation (DOT) regulations governing the transport of radioactive material as specified in 10 CFR Parts 20 and 10 CFR Part 71, Packaging and Transportation of Radioactive Material, as well as 49 CFR Parts 171-178:

licenses of shipment recipients training records of those qualified to ship radioactive material selected records of various types of radioactive material shipments documented on various forms during 2021 and to date in 2022 various sections in SOP chapter VII, Radiation Protection Procedures b. Observations and Findings The inspectors review of documents and discussions with licensee personnel showed that the licensee shipped various types of radioactive material during the past 2 years.

The inspector confirmed that the radioisotope types and quantities of material involved in the shipments were calculated and dose rates measured as required by regulations. The inspector also confirmed that the shipping containers used were appropriate and were labeled as required by regulations. The radioactive material shipping records reviewed by the inspector were completed and maintained as required by NRC and DOT regulations.

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The inspector verified that the licensee maintained copies of consignees licenses which authorized those entities to possess radioactive material as required. If the current copy of the license was not available at NESC, the inspector verified that the licensee was aware that they were required to contact the consignee and obtain a current copy before a shipment could be made.

In addition, the inspector verified that the licensee staff members assigned to complete and/or review the shipping paperwork were trained and that refresher training was completed.

c. Conclusion The inspector determined that radioactive material was shipped in accordance with the applicable NRC and DOT regulations.

7. Follow-up on Previously Identified Items a. Inspection Scope (IP 92701)

The inspector reviewed the actions taken by the licensee to address a previously identified Unresolved Item (URI) and an IFI.

b. Observation and Findings (1) 50-128/2018-201-02 - URI - Follow-up on the licensees failure to calibrate the area radiation monitors (ARMs) annually and the actions to expeditiously correct the problem. (CLOSED)

During an inspection in December 2018, the inspector reviewed the calibrations of permanently installed ARMs. The inspector determined that many of the calibrations were completed in accordance with requirements specified in TS section 4.5 and the applicable procedures. However, it was noted that some of the ARMs was not calibrated since October 20, 2017. The licensee was informed that failure to calibrate the ARMS annually as required by TS section 4.5 was an apparent violation of the TSs. However, because of the disruption caused by the construction work that was in progress at that time, the issue of the annual calibration of the ARMs would be considered a URI and would be reviewed during a future inspection.

During this inspection, the inspector again reviewed the calibrations of ARMs. The inspector found that the licensee acquired new ARMs and installed them next to the old ones. The new ARMs were operated in conjunction with the old ones but were not integrated into the reactor alarm and control system. The only ARM that was required for reactor operation by TSs was the one mounted on the reactor bridge.

The licensee indicated that only the old ARMS were used for the official records.

The inspector verified that the old ARM installed on the reactor bridge was calibrated annually. The other old ARMS were calibrated annually as well. This issue is considered closed.

(2) 50-128/2018-201-04 - IFI - Follow-up on the licensees progress in revising and updating their change procedure to reflect current provisions in the regulations or in developing a new procedure. (CLOSED)

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During the inspection in December 2018 mentioned above, following a review of the licensees change procedure, it was evident that the licensees change procedure was out of date. The procedure referred to unreviewed safety questions which was language used in a previous version of the regulations. Also, there were no provisions in the procedure for screening changes to determine whether or not they required a full safety evaluation to be conducted. The licensee was informed that the revision and updating of their change procedure or the development of a new procedure to reflect their current process would be tracked by the NRC as an IFI and would be reviewed during a subsequent inspection.

During this inspection the inspector determined that the licensee revised and updated their change procedure. The inspector noted that the licensee developed forms to screen proposed changes and separate forms to use in conducting reviews and a full evaluation if it was determined that one was needed. The inspector verified that the licensee was following the correct process and revised their procedure to include the stipulations outlined in 10 CFR 50.59. This issue is considered closed.

c. Conclusion One URI and one IFI were reviewed and closed.

8. Exit Interview The inspector presented the inspection results to TAMU NESC management at the conclusion of the inspection on December 1, 2022. The inspector described the areas inspected and discussed in detail the inspection observations. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel Reactor Facilities Director, Nuclear Engineering & Science Center A. Kurwitz Radiation Safety Officer R. Waer Associate Director - Operations and Research INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors IP 92701 Follow-up on Previously Identified Items ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 50-128/2018-201-02 URI Follow-up on the licensees failure to calibrate the ARMs annually and the actions to expeditiously correct the problem.

50-128/2018-201-04 IFI Follow-up on the licensees progress in revising and updating their change procedure to reflect current provisions in the regulations or in developing a new procedure.

Attachment