ML20148F181
| ML20148F181 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 05/29/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148F119 | List: |
| References | |
| 50-128-97-01, 50-128-97-1, NUDOCS 9706040124 | |
| Download: ML20148F181 (19) | |
See also: IR 05000128/1997001
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j E31 CLOSURE ;
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U.S. NUCLEAR REGULATORY COMMISSION '
REGION IV l
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Docket No.: 50-128 i
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License No.: R-83 !
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- Report No.
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Licensee: Texas Engineering Experiment Station l
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! Facility: Nuclear Science Center i
Location: College Station, Texas
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Dates: March 17-21,1997 *
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Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist !
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Approved By: Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
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ATTACHMENT: Supplemental Information
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9706040124 970529
PDR ADOCK 05000128
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EXECUTIVE SUMMARY
Nuclear Science Ceriter
l NRC Inspection Report 50-128/97-01
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This routine, announced inspection reviewed reactor operations and maintenance, reactor !
operator requalification, reactor safety board activities, reactor and f acility modifications, j
health physics activities, emergency plan activities, and physical security plan I
implementation.
Operations
The reactor was operated safely and in accordance with Technical Specification
requirements (Section 01).
- Violations were identified because portions of the reactor operator requalification
program were not administered well. Lectures were not conducted or attended as i
required. Some reactor operators did not undergo physical examinations at the
required frequency (Section 05).
A violation was identified because audits by the reactor safety board were not
conducted as required by Technical Specifications. However, the most recent
audits were timely (Section 07). l
Enaineerina
- Modifications to the reactor and facilities were performed in accordance with
regulatory requirements (Section E1).
Plant Support
Most elements of the health physics program were properly implemented.
However, a violation was identified for failure to perform a radiation survey inside
the radioactive waste storage area and another violation was identified because the
licensee did not demonstrate compliance with the annual dose limits for members of
the public, in accordance with 10 CFR 20.1302(b), in 1995 and 1996. These
violations indicated a need for increased oversight of waste storage area
(Section R1).
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- Radiation protection procedures do not reflect all current regulatory requirements
- because they have not been revised to include the 10 CFR Part 20 revisions that
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were effective January 1,1994 (Section R3).
A license condition was violated when radioactive material was received for
purposes other than allowed by the f acility license (Section R8.1).
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The staff of the Nuclear Science Center demonstrated the ability to be self-critical j
and conducted good critiques following emergency drills. However, corrective !
actions were not implemented, and the failure to schedule and conduct an !
emergency drillin 1996 resulted in a violation of regulatory requirements !
(Section P1). j
The physical security plan was implemented as required and no problems were 3
identified (Section S1). 1
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Reoort Details I
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Summary of Plant Status -
The facility did not operate March 14-19,1997, because of a deformed transient rod. On
the afternoon of March 20,1997, the reactor was operated at 30 watts for testing. ;
1. Operations j
01 Conduct of Operations
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I a. Inspection Scope (40750) .
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The inspector interviewed the manager of operations, observed a reactor startup,
and reviewed surveillance records and operations logs.
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b. Observations and Findinas "
Most unplanned scrams resulted from a loss of site electrical power. No problems
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l Surveillances required by Technical Specification, Section 4, were performed as
l required. The inspector determined from selected reviews of operations logs that
operating lir7its were not exceeded and the reactor was maintained appropriately.
New or modified experiments were reviewed and approved in accordance with ;
Technical Specifications 3.6 and 6.4. :
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c. Conclusions l
The reactor was operated safely and in accordance with Technical Specification
requirements.
05 Operator Training and Qualification
a. inspection Scope (40750)
The inspector reviewed the following records:
- Lecture attendance . ;
- Operator evaluations i
- Console manipulations I
- Medical examinations
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b. Observations and Findinas 1
General:
The Nuclear Science Center had seven t<1ior reactor operators and five reactor
operators. All operator licenses were current. The first operator license to expire
will be on January 24,1998.
Lectures:
10 CFR 55.59(c) requires that facility licensee have a reactor operator
requalification program reviewed and approved by the Commission.
10 CFR 55.59(c)(2) requires that the opc ator requalification program include
lectures.
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"The Nuclear Science Center Reactor Operator and Senior Reactor Operator ;
Requalification Program," Revision lli (June 1979), states that one or more lectures !
l will be scheduled within a 4-month interval to cover a topic selected from a list
l included in the requalification plan. From the licensee's records, the inspector
determined that no lectures were given October 18,1995, to July 14,1996,a
l period of approximately 9 months. The inspector identified the failure to schedule
lectures within a 4-month interval as a failure to follow the operator requalification l
program and a violation of 10 CFR 50.54(c) (50-128/9701-01). l
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10 CFR 55.59(a)(1) requires that each licensee (operator) successfully complete a l
requalification program, developed by the facility licensee, that has been approved
by the Commission. 10 CFR 55.59(c)(2) requires that the requalification program
j include preplanned lectures on regular and continuing basis. According to personnel
j interviews and lecture attendance lists, some individuals did not attend alllectures
! that were part of the requalification program. Specific information is listed below:
Date of Lecture Lectura Topic Operators Not Attending
l July 15,1996 Emergency Plan A and B I
I August 1,1996 Reactor Design A l
August 12,1996 Radiation Safety and Control A and C
September 16,1996 Reactor Regulation A
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January 24,1997 Reactor Theory D
February 25,1997 Radiation Safety and Control A
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The licensee responded that the individuals relied on "self study." The inspector
noted that self-study was not an option addressed in the requalification program.
Licensee representatives stated that they would evaluate the need for an
amendment to the operator requalification program to allow the practice of self- ,
study. The inspector identified that the failure of individuals to attend I
requalification lectures as a violation of 10 CFR 55.59(a)(1)(50-128/9701-02).
Evaluations:
Section 3.2 of the operator requalification program requires that the licensee be
examined on the console by the Nuclear Science Center director or his designee, at I
least once a year. The evaluations were typically documented on unique forms.
The licensee's records were incomplete and 1996 evaluation records were not
available for three operators. However, through the use of operation logs and other l
records, the licensee war able to demonstrate that evaluations were performed on j
all reactor operators and penior reactor operators.
Console Manipulations:
Records of console manipulation were not current. However, licensee
representatives, through entries in the operations logs, were able to demoi strate 4
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that manipulations had been performed quarterly by all reactor operators ar.d senior
reactor operators.
Physical Examinations:
10 CFR 55.21 requires that a licensee (operator) have a physical examination every
2 years. Through a review of medical records, the inspector identified three
operators whose most recent physical examinations were performad more than
2 years previously. For one operator,43 months had passed since the last physical
examination. A fourth operator received a physical examination in December 1993
and again in January 1997. The inspector identified the failure of operators to have
physical examinations every 2 years as a violation of 10 CFR 55.21
(50-128/9701-03).
In response, the licensee scheduled physical examinations for operators not having
them within the last 2 years. The manager of operations stated that these
operators would not be allowed to operate the reactor until they had successfully
passed the physical examinations.
c. Conclusions
Violations were identified because portions of the reactor operator requalification
program were not administered well. Lectures were not conducted or attended as
required. Some reactor operators did not undergo physical examinations at the
required frequency.
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06 Operations Organization and Administration
The inspector interviewed the Nuclear Science Center director and assistant
director. An organization chart for the Nuclear Science Center, dated January
1997, was reviewed. The organization met Technical Specification requirements.
07 Quality Assurance in Operations
a. Inspection Scope (40750)
The inspector reviewed reactor safety board meeting minutes and audits performed
since the previous NRC inspection.
b. Observations and Findinas
Audits were good, generally. However, audit coverage and scheduling did not meet
rechnical Specification requirements. Technical Specification 6.2.4 states, "The
reactor safety board or a subcommittee thereof shall audit reactor operations and
radiation protection programs at least quarterly, but at intervals not to exceed four
months."
According to the licensee's records, no audits were performed during the first
quarter of 1995. The first audit of the year was performed May 1995. No audits
were performed during the first two quarters of 1996. The first audit of the year
was performed July 1996.
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Technical Specification 6.2.4(a) states that facility operations, including radiation
protection, shall be audited at least once per year, not to exceed 15 months.
An audit of reactor operations, specifically reviewing maintenance, surveillances,
and experiments, was performed August 23,1994. A similar audit was performed
again on December 15,1995. The interval between audits was 16 months.
Subsequently, the audit was performed on November 8,1996, a period of 11 ,
months. Audits of operations records were performed on July 12,1994,and '
December 20,1995. The interval between audits was 17 months. Subscauently,
the audit was performed on Octcher 31,1996, a period of 10 mentns from the
previous inspection.
Technical Specification 6.2.4(c) requires that the facility security plan and records
be audited at least once pe" calendar year, not to exceed 15 months.
Audits of the security plan were performed May 12,1995 and October 15,1996.
The interval between audits was 17 months. The inspector identified the failure to
pc-form audits quarterly and the f ailure to perform audits at intervals not exceeding
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15 months, as examples of violations of Technical Specification 6.2.4
, (50-128/9701-04).
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Responses to audit findings from the Nuclev Science Center to the reactor safety
board were sometimes not timely. The response to November 8,1996, operations /
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maintenance audit was dated February 6,1997. The response to the October 23,
1996, operator requalification audit was dated February 4,1997. The response to
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the October 15,1996, security audit was dated February 4,1997. The response to
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the May 12,1995, security plan audit was dated March 13,1996.
! Violations related to the reactor safety board audits were also identified in NRC
l ' Inspection Reports 50-128/92-02 and 50-128/94-01. Even though audits were not
conducted during the first and second quarters of 1996, as required, the intervals
t between 1995 and 1996 audits did not exceed 15 months.
l c. Conclusions
. Since the previous inspection, some audits by the reactor safety board were not
l conducted as required by Technical specifications. However, the most recent
audits were timely.
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08 Miscellaneous Operations issues
08.1 (Closed) Violation 50-128/9202-03: Failure to Review Chanaes in Accordance With
This item involved changes to the facility ventilation system, without determining if
the changes involved an unreviewed safety question. The inspector verified the
L corrective actions described in the licensee's response letter, dated December 7,
1992, were implemented. No similar problems were identified.
08.2 (Closed) Violation 50-128/9400 01: Failure to Conduct Audits in Accordance With
Technical Specifications
This item recurred. It is discussed in Section 07. The new item will be tracked by
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50-128/9701-04.
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111. Enaineerina
E1 Conduct of Engineering
a. Inspection Scope (40750)
The inspector reviewed the modification authorization logs.
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b. Observations and Findinas
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Since the previous inspection, Modification Authorizations MA-42 through MA-49
were approved. Modifications were reviewed in accordance with 10 CFR 50.59.
No unreviewed safety questions were identified,
c. Conclusions -
Modifications to the reactor and facilities were performed in accordance w;th
regulatory requirements.
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IV. Plant Support
R1 Radiological Protection and Chemistry Controls
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a. Inspection Scope (40750)
The inspector interviewed the health physics coordinator and reviewed records of
the following:
- 1995'and 1996 personnel exposure
- Instrument calibrations
- Pocket ion chamber calibrations ;
- Selected radiation and contamination surveys l
- Sealed source leak tests
! * 1994,1995, and 1996 annual reports
-*- Shipping documentation
- Consignee radioactive materiallicenses
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b. Observations and Findinas
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Exoosure Control:
l Personnel exposures were within regulatory limits. The highest single exposures in
1995 and 1996 were 650 millirems and 560 millirems, respectively. Total site
exposure was 3.43 person-rem in 1995 and 3.1 person-rem in 1996. Personnel
and extremity monitoring devices were provided and processed by a vendor.
The inspector observed licensee representatives removing radioactive samples from
the reactor. Good handling techniques and contamination controls were used. Two
, individuals were involved; both wore extremity radiation monitoring devices to
supplement their whole body exposure monitoring devices. No problems were
observed.
} During tours of the facility, the inspector confirmed that entrances and areas were
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posted properly,
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Calibrations. ;
The licensee performed calibrations on pocket ion chambers. The inspector
reviewed the licensee calibration technique and results and identified no problems.
Calibration of portable survey instruments was performed by a vener The ;
inspector confirmed that calibrations were performed at the required intervals or the I
instruments were taken out of service. The licensee performed daily response
checks on hand and foot monitors. Calibrations of facility air monitors and area j
l radiation monitors were performed as required by Technical Specification 4.5,
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Surveys:
Area radiation and contamination surveys were performed and documented as
required, in most cases. (See the discussion on the waste storage area.) Air
sampling was performed in the materials handling area when radioactive rnaterials i
were removed from the reactor or packaged for transport. The licensee had no l
procedural guidance linking airborne concentrations to internal dose assessments.
However, the licensee had never measured more than 0.1 derived air concentration
through air sampling, indicating that airborne radioactivity was typically not a
concern. There was no regulatory requirement for procedures related to this area.
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Sealed Source Leak Tests:
The facility license included no requirements for leak testing sealed sources.
Consequently, no leak tests were performed immediately following the transfer of
! the sources from the agreement state license. (See Section R8.1.) This period
extended from January 17,1994, to March 14,1995. At that time, prompted by
advice from university health physics personnel, the licensee established a
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surveillance program to leak test the sealed sources. Subsequently, leak tests were
performed regularly at 6-month intervals. The need for sealed source leak testing
requirements is an inspection followup item, pending further review by the P"tC
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Radioactive Waste Storaae and Handlina:
The inspector toured the radioactive waste storage building with the health physics
coordinator. The waste storage building housed bags of radioactive waste material
stored for decay. The inspector confirmed that the bags were labeled in accordance
with the requirements of 10 CFR 20.1904.
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The health physics coordinator stated that technicians performed surveys
periodically to segregate radioactive waste from nonradioactive waste. The
nonradioactive waste was then disposed to reduce volume. The health physics
coordinator stated that individual pieces of trash, not aggregated amounts such as
entire bags, were surveyed with Geiger Mueller instruments during the segregation
process. The inspector did not observe the segregation of waste and did not
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identify problems. However, the inspector stated that guidance for this type of
activity was provided in NRC Information Notice 85-92. The health physics
coordinator stated that the guidance in the information notice would be reviewed.
While performing radiation surveys in the waste storage area, the inspector
identified radiation levels on the west side of the waste storage building that were
significantly higher than the general area. The source of the increased radiation
levels was a group of bags lying away from the main waste storage area. Radiation
measurements performed by the health physics coordinator and the inspector
confirmed that radiation levels on contact with the bag were approximately
130 millirems per hour. Radiation levels at 30 centimeters did not exceed 100
millirems per hour; therefore, the area was not required to be posted as a high
radiation area. However, when the inspector attempted to verify that these
radiation levels were documented on the latest area surveys, the health physics
coordinator acknowledged that surveys had not been performed within the
radioactive waste storage builaing. 10 CFR 20.1501(a) requires each licensee to
make or cause to be made carveys that may be necessary for the licensee to
comply with the regulations in Part 20 and are reasonable under the circumstances ,
to evaluate the extent of radiation levels and the potential radiological hazards that
could be present. The inspector identified the failure to perform radiation surveys in
this area as a violation of 10 CFR 20.1501(a) (50-128/9701-05).
The health physics coordinator stated, during a telephone conversation on
March 27,1997, that the bags were taken from the main storage area when
storage shelves were built. It was intended that the bags be moved into a
higher-level radioactive waste storage area. However, the move of the material was
not completed. As immediate corrective action, licensee representatives moved the
bags of waste to the higher-level storage area and performed and documented a
radiation survey of the radioactive waste storage building.
In a related item, thermoluminescent dosimeters maintained on the perimeter of the
restricted area by the Texas Department of Health indicated doses in two locations
in unrestricted areas exceeded 100 millirems in 1996. A dose for the year in one
location was 198 millirems. In the other location, it was 117 millirems. This
finding was identified during an audit of the health physics program performed by a
reactor safety board representative in November 1996.
The thermoluminescent dosimeter measuring 198 millirems was located near the
radioactive waste storage building. The health physics coordinator determined the
cause was the improper storage of a bag of radioactive waste. The bag of waste
was not placed within the concrete block vault provided. The condition may have
existed since late July or early August 1996. At that time, the licensee finished
construction of scaffolding above the concrete block, waste storage area. The
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scaffolding was placed in order to support a waste segregation table and shelves for
l storage of lower dose rate radioactive waste. A bag of higher dose rate waste was
left on the segregating table or shelves, rather than behind the concrete blocks,
below. The failure to shield the bag of waste raised radiation levels in the
I unrestricted area outside the building. The 117 millirem dose at the second location
was caused by activated material stored within a building, too close to the
restricted area boundary
Reccros of thermoluminescent dosimeter results confirmed that the licensee
exceeded the allowable limit of 10 CFR 20.1301(a)(1) at the first location by the
i end of the third quarter of 1996. However, licensee representatives stated that
they were not aware of the problem until November 21,1996, the date the
thermoluminescent dosimeter results were received from the Texas Department of
Health and forwarded to the reactor safety board auditor. (The audit was initiated
on November 12,1996). Licensee representatives immediately identified the source
of the elevated dose rates and shielded the bag of waste. The fourth quarter
j thermoluminescent dosimeter results were received February 2,1997 and showed
l the extent to which the allowable limits were exceeded at the first location in 1996
l and also showed that the limits had been exceeded at a second location. The
licensee again took prompt action to reduce radiation levels in the second location.
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The following information, excerpted from the licensee's 1996 annual report, shows
the dose accrual for the two locations.
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Site # Location Quarterly Exposure Rate 1996
(in millirems) Exposure
i 6 300 feet N-NE of the 21.5 29.7 63.4 78.1 198
f reactor building, near
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18 375 feet NE of reactor 14.3 17.8 36.8 45.0 117.0
building
The inspector reviewed the licensee's 1995 annual report and identified another
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example in which the dose in an unrestricted area exceed 100 millirems. Site #3,
250 feet west, southwest of the reactor building, accrued a dose of 123 millirems
in 1995.
l 10 CFR 20.1301(a)(1) requires that each licensee conduct operations so that the
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total effective dose equivalent to individual members of the public from the licensed
operation does not exceed 0.1 rem (100 millirems)in a year, exclusive of the dose
contributed from background radiation. 10 CFR 20.1302(b) states that a licensee
shall show compliance with the annual dose limit in 10 CFR 20.1301 by
(1) demonstrating by measurement or calculation that the total effective dose
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l equivalent to the individual likely to receive the highest dose from the licensed
l operation does not exceed the annual dose limit; or (2) demonstrating that (i) the
annual concentrations or radioactive material released in gaseous and liquid
effluents at the boundary of the unrestricted area do not exceed the values
specified in Table 2 of Appendix B to Part 20; and (ii) if an individual were
l continuously present in an unrestricted area, the dose from external sources would
not exceed 0.002 rem in an hour and 0.05 rem in a year.
Even though this violation was identified by the licensee during an audit of the
health physics program, discretion is not being exercised in accordance with
Section Vll.B.1 of the NRC Enforcement Policy because the licensee's corrective
actions for the occurrence in 1995 could reasonably have been expected to have
prevented the occurrences in 1996. The failure to demonstrate compliance with
dose limits for individual members of the public is a violation of 10 CFR 20.1302(b)
(50-128/9701-06).
Licensee representatives noted that they did not have radiation detection
instrumentation capable of measuring radiation dose rates in the microrem per hour
range, at the time of the violation. One of the corrective actions taken by the
licensee was the initiation of the use of such instruments.
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Radioactive Effluents:
Liquid effluents did not exceed the limits in 10 CFR Part 20, Appendix 8. Gaseous
effluents, composed primarily of argon-41, did not exceed the limits of Technical
Specification 3.5.2 at the boundary of the restricted area. An environmental j
monitoring program conducted jointly with the Texas Department of Health '
confirmed that radioactive materials, in concentrations above regulatory limits, were .
not allowed to enter the environment. {
Transoortation of Radioactive Materials: ,
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Radioactive shipments were properly documented. Personnel interviews and i
shipping documentation indicated that the licensee primarily shipped normal form
material in Type A quantities, requiring White I, Yellow II, or Yellow Ill labels.
Shipments were largely repetitive and checklists provided appropriate guidance.
Health physics personnel were knowledgeable of recent changes in Department of
Transportation regulations and upcoming requirements for use of international units
on shipping documentation and labels. The inspector selectively verified that
current licenses of radioactive material consignees were maintained by the licensee.
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c. Conclusions
Most elements of the health physics program were properly implemented.
l However, a violation was identified for failure to perform a radiation survey inside
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the radioactive waste storage area and another violation was identified because the
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licensee did not demonstrate compliance with dose limits for individual members of
the public doses. These violations indicated a need for increased oversight of the
l waste storage area.
R3 Radiological Protection and Chemistry Procedures and Documentation
l The licensee was not required by the Technical Specifications to establish and
implement procedures related to radiation protection or health physics practices.
However, the licensee chose to implement such procedures. Section Vil of the
licensee's standard operating procedures were devoted to radiation protection and
health physics practices.
10 CFR Part 20 revisions were effective January 1,1994. Health physics
procedures incorporating the revisions of 10 CFR Part 20 had not been approved by
I the reactor safety board at the time of the inspection.
Implementing procedures in this area were an enhancement to the program because
thuy ensured that 10 CFR Part 20 requirements and management expectations were
implemented consistently. However, procedures that no longer reflected regulatory
requirements properly could lead to a failure to comply with the requirements.
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Nuclear Science Center representatives acknowledged the inspector's concern and
stated that they would attempt, again, to gain approval from the reactor safety
board for the revised procedures at the next reactor safety board meeting.
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l R5 Staff Training and Qualification
The incpector reviewed selected personnel training records and confirmed that
workers were provided proper instructions in radiation protection practices, in
accordance with 10 CFR 19.12.
R8 Miscellaneous Radiological Protection and Chemistry issues
R8.1 Receiot of Bvoroduct Material
a. Insoection Scope (40750)
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The inspector interviewed the site director, assistant director, and the
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health physics coordinator, in addition to licensing correspondence, the
inspector reviewed shipping documentation from Westinghouse Hanford Company
(February 23,1994).
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b. Observations and Findinas i
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- in a letter dated March 25,1993, the licensee requested a license amendment to
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allow the transfer of radioactive sources from the State of Texas license to the
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reactor license. The request was sought to improve administrative controls of
radioactive materials at the facility by eliminating the confusion potentially caused
by interacting with multiple licensing authorities. ;
Amendment 13 of the facility license was issued October 26,1993. Before the
issuance of Amendment 13, License Condition ll.B.(3), governing byproduct
material, addressed only the receipt, possession, and use of an encapsulated
plutonium-beryllium source and an encapsulated americium beryllium source.
Amendment 13 stated that the licensee was allowed to receive, possess, and use
any byproduct material without restriction to chemical or physical form, for analysis
or instrument calibration, but not to separate such byproduct material as may be i
produced by operation of the reactor.
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During a site tour, the inspector observed containers housing radioactive material l
and asked licensee representatives to identify the contents. Licensee i
representatives identified the contents as activated reactor components from a
Westinghouse Hanford TRIGA reactor. Receipt records confirmed that the items
were received on or about February 23,1994, approximately 4 months after the j
issuance of License Amendment 13. Shipping documentation showed that '
components contained 1.88 millicuries of cobalt-60. Licensee representatives
stated that the items were never used. The licensee had hoped to obtain the :
nuclear instruments that were originally included with the Westinghouse Hanford
TRIGA reactor. However, instead of the instrumentation, licensee representatives
received contaminated components, which they acknowledged they would never
use.
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Because the byproduct material was not: (1) produced within the Nuclear Science
l Center reactor, (2) among the _ byproduct material sources formerly possessed in
l accordance with the agreement state license, and (3) used for analysis or
calibration, the inspector identified this itern as a violation of License
Condition ll.B.(3) (50128/9701-07).
c. Conclusions
A license condition was violated when radioactive material was received for
purposes other than allowed by the f acility license,
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R8.2 (Closed) Violation 50-128/9202-01: Failure to Instruct Individuals Working in a ;
Restricted Area, in Accordance With 10 CFR 19.12.
l The inspector verified the corrective actions described in the licensee's response
l letter, dated December 7,1992, were implemented. No similar problems were [
i identified. i
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P1 Conduct of Emergency Preparedness Activities
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a. Inspection Scope (40750)
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The inspector interviewed the assistant director of the Nuclear Science Center and
reviewed:
- Emergency drill critiques ;
- Emergency plan training records :
I * Letters of agreement with offsite support agencies
- Readiness of emergency kits
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b. Observations and Findinas j
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10 CFR 50.54(q) requires that a licensee authorized to possess and/or operate a !
research reactor follow and maintain in effect emergency plans which meet the
requirements of 10 CFR Part 50, Appendix E.Section IV.F requires the plan to i
- provide for exercising by periodic drills. Section 10.2 of the " Emergency Plan for ]
the Nuclear Science Center," Revision 1 (September 1995), states that onsite l
l emergency drills will be conducted annually to test the adequacy of emergency l
l procedures and to ensure that emergency organization personnel are familiar with
their c,uties.
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The critique of the 1994 emergency evaluation drillidentified several short-comings.
One of the licensee's conclusions was that the lack of positive direction by.
- personnel indicated a need for more training. Another drill was proposed but not
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conducted.
The critique of the 1995 emergency drill, which simulated tornado response, )
concluded that overall response was " unsatisfactory." This was the last drill '
conducted.
- The inspector identified the failure to follow the emergency plan by not conducting l
an emergency drill in 1996 as a violation of 10 CFR 50.54(q) (50-128/9701-08).
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c. Conclusions
The staff of the Nuclear Science Center demonstrated the ability to be self-critical
and conducted good critiques following emergency drills. However, corrective
actions were not strong, and the failure to schedule and conduct an emergency drill j
in 1996 resulted in a violation of regulatory requirements. :
S1 Conduct of Security and Safeguards Activities t
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a. Insoection Scoce (81431)
The inspector observed the licensee conduct tests of the security system and
reviewed the following records: ,
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+ Security system tests documentation
- Security key issue
- Annual police training
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b. Observations and Findinas ,
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Licensee representatives tested the security system as required and the security
system worked as designed. The licensee accounted for all security keys, issued
and not issued. Police training was conducted as required.
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c. Conclusions I
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The physical security plan was implemented as required and no problems were
identified.
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V. Manaaement Meetinas i
X1 Exit Meeting Summary
The inspector presented the results of the inspection to members of licensee
management at the conclusion of the inspections on March 21,1997. The licensee
acknowledged the findings presented. No proprietary information was identified.
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ATTACHMENT !
SUPPLEMENTAL INFORMATION <
PARTIAL LIST OF PERSONS CONTACTED
Licensee !
B. Asher, Operations Manager
T. Fisher, Reactor Maintenance Supervisor
.
,
S. O' Kelly, Assistant Director, Nuclear Science Center .
L. Krisantis, Health Physics Coordinator
.
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D. Reece, Director, Nuclear Science Center
D. Russell, Deputy Director, Texas Engineering Experiment Station
A. Sanchez, Reactor Supervisor ;
INSPECTION PROCEDURES USED
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40750 Class 11 Non-Power Reactors
81431 Fixed Site Physical Protection of Special Nuclear Material of
Low Strategic Significance j
ITEMS OPENED AND CLOSED
Ooened
50-128/9701-01 VIO Failure to follow reactor requalification program
50-128/9701-02 VIO Failure to attend requalification lectures
50-128/9701-03 VIO Failure of reactor operators to have physical examinations
every 2 years
50-128/9701-04 VIO Failure to audit as required by Technical Specification
]
l 50-128/9701-05 VIO Failure to survey
50-128/9701-06 VIO Failure to demonstrate compliance with dose limits for
individual members of the public
t 50-128/9701-07 VIO Possession of radioactive material for an unlicensed activity
50-128/9701-08 VIO Failure to conduct an annual emergency drill
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50-128/9701-09 Scaled source leak testing requirements
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f Closed
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50-128/9202-01 VIO Failure to instruct individuals working in a restricted area l
in accordance with 10 CFR 19.12
50-128/9202-03 VIO Failure to review changes in accordance with 10 CFR 50.59
50-128/9401-01 VIO Failure to audit in accordance with Technical Specification
50-128/9701-06 NCV Rate of dose accrual above requirements of 10 CFR 20.1301
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