IR 05000059/2018201

Texas A&M University - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 50-059/2018-201

ML18270A136
Person / Time
Site:	Texas A&M University
Issue date:	10/19/2018
From:	Anthony Mendiola Research and Test Reactors Oversight Projects Branch
To:	Mcdeavitt S Texas A&M Univ
Bassett C, NRR/DLP, 415-1842
References
Download: ML18270A136 (17)

Text

ber 19, 2018

SUBJECT:

TEXAS A&M UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-059/2018-201

Dear Dr. McDeavitt:

From September 17-20, 2018, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection of the Aerojet General Nucleonics Model 201 Modified Research Reactor located at your Texas A&M University Nuclear Science Center facility. The enclosed report documents the inspection results which were discussed on September 20, 2018, with you and Mr. Jerry Newhouse, Associate Director, Nuclear Science Center.

The 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 reviewed selected procedures and records, observed facilities, and interviewed various personnel. 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 (10 CFR) 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be 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). Should you have any questions concerning this inspection, please contact Craig Bassett at 240-535-1842 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No.50-059 License No. R-23 Enclosure:

As stated cc: See next page

Texas A&M University Docket No.50-059 cc:

Mayor, City of College Station Dr. Yassin Hassan, Department Head P.O. Box Drawer 9960 Texas A&M University College Station, TX 77840-3575 Nuclear Engineering Department 3133 TAMU Governors Budget College Station, Texas 77843-3133 and Policy Office PO BOX 12428 Jerry Newhouse, Assistant Director Austin, TX 78711-2428 Nuclear Science Center Texas A&M Engineering Experiment Station Jerry Newhouse, Interim Supervisor 3575 TAMU AGN-201M Reactor Supervisor College Station, TX 77843-3575 Texas A&M University Nuclear Engineering Department Radiation Program Officer 3133 TAMU Bureau of Radiation Control College Station, TX 77843-3133 Dept. of State Health Services Division for Regulatory Services Test, Research and Training 1100 West 49th Street, MC 2828 Reactor Newsletter Austin, TX 78756-3189 P.O. Box 118300 University of Florida Technical Advisor Gainesville, FL 32611-8300 Office of Permitting, Remediation &

Registration Radiological Safety Officer Texas Commission on Environmental Texas A&M University Quality Environmental Health and Safety P.O. Box 13087, MS 122 1111 Research Parkway Austin, TX 78711-3087 College Station, TX 77843-4472

ML18270A136 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB NRR/DLP/PROB/LA NRR/DLP/PROB/BC NAME CBassett NParker AMendiola DATE 10/5/2018 10/3/2018 10/19/2018

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-059 License No.: R-23 Report No.: 50-059/2018-201 Licensee: Texas A&M University Facility: AGN-201M Research Reactor Location: College Station, TX Dates: September 17-20, 2018 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Texas A&M University AGN-201M Research Reactor NRC Inspection Report No: 50-059/2018-201 The primary focus of this routine, announced inspection was on-site review of selected aspects of the Texas A&M University (the licensee) Class III Aerojet General Nucleonics Model 201 Modified (AGN-201M) research reactor safety program, including: (1) staffing and audits; (2) operator requalification and active license status; (3) radiological surveys; (4) surveillance; and, (5) emergency preparedness since the last U.S. Nuclear Regulatory Commission (NRC)

inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety. No deviations or violations of significance were identified.

Staffing and Audits

• The AGN-201M research reactor was shut down for various reasons on June 21, 2013, and there were no staff permanently assigned to the reactor.

• No audit of conformance of facility operation to the technical specifications (TSs) or audit of the current Emergency Plan (E-Plan) had been conducted.

Operator Requalification and Active License Status

• There were no facility staff who were licensed to operator the AGN-201M research reactor.

• The operator requalification program was inactive.

Radiological Surveys

• Surveys were being completed and documented acceptably.

• Postings met the regulatory requirements specified in Title 10 of the Code of Federal Regulations (10 CFR) Parts 19 and 20.

• Personnel dosimetry was being worn as required and doses were well within the licensees procedural action levels and NRCs regulatory limits.

• Radiation monitoring equipment was being calibrated as required.

• One minor violation was identified for failure to conduct surveys of the reactor components storage areas during the last quarter of 2016 and the first two quarters of 2017 as required by TS Section 4.5.

Surveillance

• The various AGN-201M reactor components were stored in the Accelerator Building and the Cargo Container as required.

• The AGN-201M fuel was stored in a locked storage area as required.

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• Annual Operation Reports were to be submitted by the licensee in accordance with the TSs.

Emergency Preparedness

• A copy of the current version of the AGN-201M research reactor E-Plan should be submitted to the NRC.

• Emergency offsite support appeared to be adequate.

• Notification procedures were as required by the E-Plan.

• Decontamination facilities were available as required.

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REPORT DETAILS Summary of Plant Status Texas A&M University (TAMU) 5 watts AGN-201M research reactor was shut down by the licensee for various reasons on June 21, 2013. The reactor and all related components were subsequently removed from the Zachry Engineering Complex (ZEC) and moved to the Texas Engineering Experiment Station (TEES) Nuclear Science Center (NSC). The reactor was being maintained in a possession-only status at the NSC.

1. Staffing and Audits a. Inspection Scope (Inspection Procedure (IP) 69002, Section 02.01)

To verify compliance with the facility TSs (which were included as Appendix A to the TAMU AGN-201M Facility Operating License, R-23) Section 6.0, the inspector reviewed selected portions and/or aspects of:

• Reactor Safety Board (RSB) meeting minutes from May 28, 2015, to the present

• Discussions with the NSC Director and the NSC Associate Director

• Annual Report for the TAMU AGN-201M Training Reactor for the periods from June 1, 2014, to May 31, 2015, dated July 24, 2015 (which was the most recent one submitted by the licensee)

b. Observations and Findings (1) Staffing As noted above, the last date the reactor was operated was June 21, 2013. Although one nuclear engineering graduate student had obtained a senior reactor operator (SRO) (fuel handling only) license in the past for this reactor, there currently were no permanently assigned reactor staff for AGN-201M research reactor.

(2) Audits It was noted that the TSs required an audit of conformance of the facility operation to the TSs. There had been no operation since the last NRC inspection so no audits were conducted (or needed) in this area.

The inspector noted that the currently approved E-Plan had been revised in October 2016. It was revised to take into account the fact that the fuel, fueled control rods, and Plutonium-Beryllium (Pu-Be) start-up source had been removed from the reactor and transferred to the licensees TRIGA reactor license (R-83). The reactor tank and other components remained on the AGN-201M reactor license (R-23). The revised E-Plan was reviewed and approved by the RSB on October 10, 2016.

The AGN-201M E-Plan stipulated in Section 10 that the RSB was required to examine the plan to ensure that it was updated as needed.

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TS Section 6.4.3 required that the Facility Emergency Plan, as well as the implementing procedures, be audited every two years. Because the plan had been approved by the RSB in October 2016, no audit had been performed to date. (See Paragraph 5 below.)

c. Conclusion There were no staff personnel permanently assigned to the AGN-201M research reactor. No audit of conformance of facility operation to the TSs or audit of the current E-Plan, which had been revised, reviewed, and approved in October 2016, had been conducted.

2. Operator Requalification and Active License Status a. Inspection Scope (IP 69002, Section 02.02)

• RSB meeting minutes from May 28, 2015, to the present

• Discussions with the NSC Director, and the NSC Associate Director, b. Observations and Findings There were no SROs or reactor operators at the facility who were licensed to operate the AGN-201M research reactor. As mentioned above, one individual had obtained a SRO (fuel handling only) license. However, this individual no longer worked at the facility.

The AGN-201M operator requalification program was inactive. The inspector noted, and the licensee acknowledged, that before any fuel reloading of the AGN-201M research reactor could occur or any operations thereof, individuals would need to receive the appropriate training, take an NRC operator examination, and become licensed to operate the reactor. Also the Operator Requalification Program would need to be reactivated. The Requalification Program will need to include emergency response actions in addition to all the other required subjects.

c. Conclusion There were no staff members at the facility who were licensed to operate the AGN-201M research reactor and the operator requalification program was inactive.

3. Radiological Surveys a. Inspection Scope (IP 69002, Section 02.03)

The inspector reviewed the following to verify compliance with 10 CFR Part 19 and 10 CFR Part 20, as well as Section 4.5 of the TSs:

• Personnel dosimetry results for 2016 through the date of the inspection

• Radiological signs and postings in various areas of the facility-5-

• Calibration records of selected radiation monitoring equipment

• NSC Health Physics AGN Storage survey forms documenting quarterly contamination and radiation surveys of the designated storage areas of the AGN-201M reactor components for the period from 2017 through the date of the inspection

• RSB meeting minutes from May 28, 2015, to the present

• Discussions with the Director, NSC, and the Associate Director, NSC b. Observations and Findings (1) Surveys TS Section 4.5.a.2 required that once a quarter a radiation and contamination survey shall be conducted around the exterior of the stored AGN-201M reactor components to verity that contamination is not migrating from the contained reactor components. TS Section 4.5.b.2 required that once a quarter a radiation and contamination survey shall be conducted of the exterior of the cargo container to verify that contamination is not migrating from the contained components.

The inspector reviewed quarterly radiation and contamination surveys of the areas where components of the AGN-201M reactor were stored. The surveys of these areas had been completed by NSC staff personnel. The results were documented on the appropriate forms and evaluated as required. No elevated contamination levels or radiation levels were noted during the surveys.

The inspector noted that the AGN-201M reactor components had been moved from the ZEC to the NSC during October 2016. However, no surveys had been conducted during the last quarter of 2016 and none were conducted during the first two quarters of 2017. The first survey of the reactor components storage areas had been conducted on July 28, 2017. Failure of the licensee to conduct surveys of the reactor components storage areas during the last quarter of 2016 and the first two quarters of 2017 was noted as a violation of TS Section 4.5.

However, the inspector noted that the reactor components being stored in the Accelerator Building and the Cargo Container were only slightly radioactive and contained only low levels of contamination. Therefore, the NRC determined that this issue constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section 2 of the Enforcement Policy.

(2) Postings and Notices During tours of the NSC, the inspector reviewed the postings around the various storage areas and at the entrances to various controlled areas.

The postings indicated the radiation hazards present. Other postings also showed the industrial hygiene hazards present in the areas. Copies of the notice to workers required by 10 CFR Part 19 were posted on the door outside the hallway leading to the reactor area.

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(3) Dosimetry Because the AGN-201M research reactor fuel and components were being stored at the NSC, the inspector reviewed the dosimetry records of all NSC personnel. The licensee used a National Voluntary Laboratory Accreditation Program-accredited vendor to process personnel and area dosimetry. Through direct observation, the inspector determined that dosimetry was acceptably used by facility personnel.

An examination of the records for the past 2 years showed that monitoring was accomplished by using whole body and finger ring dosimeters. Examination of the dosimetry results indicating radiological exposures at the facility showed that the highest occupational doses were within 10 CFR Part 20 limitations.

(4) Radiation Monitoring Equipment The calibration of portable survey meters and friskers was typically completed by an outside contractor. The calibration of the portable survey meter typically used to conduct the AGN-201M storage area surveys was reviewed. Calibration frequency met the requirements established in the applicable procedures and records were being maintained as required.

(5) Facility Tours The inspector toured the storage areas in the NSC Accelerator Building and the Cargo Container. The fuel storage area was also entered and observed. Control of access to these areas, control of access to radiation areas, and control of radioactive material were acceptable. The inspector conducted a radiation survey of the storage areas using an NRC-supplied instrument and a licensee-provided survey meter. No anomalies were noted and all readings were similar to ones annotated on the licensee survey maps.

c. Conclusion The radiation protection program was adequate in that: (1) surveys were generally being completed and documented acceptably, (2) postings met the regulatory requirements specified in 10 CFR Part 19 and 10 CFR Part 20, (3) personnel dosimetry was being worn as required and doses were well within the licensees procedural action levels and NRCs regulatory limits, (4) radiation monitoring equipment was being maintained and calibrated as required, and, (5) areas were posted and controlled as required.

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4. Surveillance a. Inspection Scope (IP 69002, Section 02.04)

To determine whether the surveillance activities required by TS Sections 3.5, 4.5, and 5.2 were being completed, the inspector reviewed:

• RSB meeting minutes from May 28, 2015, to the present

• Discussions with the Director, NSC, and the Associate Director, NSC

• NSC Health Physics AGN Storage survey forms documenting quarterly contamination and radiation surveys of the designated storage areas of the AGN-201M reactor components for the period from 2017 through the date of the inspection

• Annual Report for the TAMU AGN-201M Training Reactor for the periods from June 1, 2014, to May 31, 2015, dated July 24, 2015 (which was the most recent one submitted by the licensee)

• Texas A&M University, Texas A&M Engineering Experiment Station, AGN-201M (Serial Number 106), Facility License R-23, Facility Docket Number 50-59, Quality Assurance Work Package, TAMU/TEES AGN-03, Revision 2, dated September 26, 2016 b. Observations and Findings (1) Relocation of the AGN-201M Research Reactor to the TEES NSC Because TAMU had developed plans for the ZEC which did not include the AGN-201M research reactor, the reactor, the fuel, and all the component parts, had to be moved from the ZEC and relocated to the NSC. The NSC Director was designated as the individual directly responsible for that project.

The inspector reviewed documents associated with the relocation of the AGN-201M. It was noted that a Quality Assurance Work Package had been developed to ensure that the appropriate and required steps be taken for the movement of the reactor fuel from the ZEC to the NSC. The inspector reviewed the package which contained quality assurance (QA)

forms to document the entire process. The QA program ensured that the correct packaging was used and that the required inspections, verifications, and precautions were established to prepare, package, ship, and ultimately receive and unload the special nuclear material (SNM).

The inspector also noted that the reactor components had been shipped to the ZEC as Exempt Quantity material meaning that the components were below the radiation and contamination specified exempt material activity concentration limits specified in the regulations. No inadequacies were noted concerning the relocation activities.

(2) Storage of Reactor Components As noted previously, the inspector toured the Accelerator Building and the Cargo Container which housed the AGN-201M reactor components. The-8-

inspector verified that the AGN-201M Shield tank, Reactor Tank, Core Tank, associated internal components, the reactor control panel and associated electronic equipment were stored inside a secured fenced area in the Accelerator Building. The reactor components not stored in the Accelerator Building were stored in a secured Cargo Container with a tamper proof seal affixed. No problems were noted.

(3) Quarterly Inspections and Verifications TS Section 4.5.a.1 required that once a quarter the fenced area in the Accelerator Building shall be inspected to verify all reactor components are present and no indications of tampering exist. TS Section 4.5.b.1 required that once a quarter a survey of the cargo container is required to verity that the tamper proof seal has not been broken.

The inspector inquired about the documentation of these required surveillances. The licensee indicated that there was no actual documentation of the completion of these requirements. The areas were checked when a survey was performed but that was not documented on the survey form or any logs. No records existed of the completion of the required inspections and verifications.

As noted above, the AGN-201M reactor components had been moved from the ZEC to the NSC during October 2016. Since no surveys of the storage areas (Accelerator Building or Cargo Container) had been conducted during the last quarter of 2016 and none were conducted during the first two quarters of 2017, there was no indication that the areas were inspected to verify that all components were present and no verification that the tamper proof seal on the Cargo Container was intact.

The first survey of the reactor components storage areas had been conducted on July 28, 2017.

Failure of the licensee to inspect the Accelerator Building to verify all the reactor components were present and to verify that the tamper proof seal had not been broken during the last quarter of 2016 and the first two quarters of 2017 was noted as a violation of TS Section 4.5. However, the inspector noted that those facilities are located inside a larger fenced area (on the NSC site) with positive controls in place. The accepted method to gain entrance to the NSC site is through the main vehicle gate.

Licensee personnel gain admittance by entering an access code to activate the vehicle gate. Visitors must contact someone at the Reception Desk or in the Control Room for access. No one is allowed inside the fenced area who does not have specific authorization.

Therefore, the NRC determined that this issue constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section 2 of the Enforcement Policy.

(4) Fuel Storage As noted above, the AGN-201M reactor fuel had been transferred from AGN Facility Operating License, No. R-23, in the ZEC on the TAMU-9-

campus to the TRIGA Facility Operating License, No. R-83, in the NSC.

The material was being stored in a SNM storage location using appropriate criticality controls. Additional details related to the transfer can be found in Amendment Nos. 15 and 16 to Facility Operating License No. R-23.

As indicated above, the inspector toured various areas at the NSC including the fuel (SNM) storage area. The area was locked and posted as required. Upon entry, the inspector noted that the fuel was stored in two drums. The inspector verified that the AGN-201M reactor fuel, as well as the fueled control rods, and Pu-Be start-up source, were stored there as required by TS Section 5.2. The inspector reviewed the serial numbers of the seals on the storage drums and verified that the numbers matched the numbers documented in the transfer records.

(5) Annual Operating Reports The inspector reviewed the Annual Operating Reports for the AGN-201M research reactor. It was noted that no reports had been submitted to the NRC since July 2015. TS Section 6.9.1 requires that an operating report be submitted annually to the NRC. The inspector indicated that, even though no reactor operations had occurred since that time, it was a requirement to submit a report annually. The licensee indicated that they would meet the requirement and submit the reports. The inspector informed the licensee that the issue of submitting the annual operating reports for the AGN-201M research reactor would be identified as an Inspector Follow-up Item (IFI) and would be reviewed during a future inspection (IFI 50-059/2018-201-01).

c. Conclusion The various AGN-201M reactor components were stored in the Accelerator Building and the Cargo Container as required. The AGN-201M fuel was stored in a locked storage area as required. Annual Operation Reports were to be submitted by the licensee in accordance with the TSs.

5. Emergency Preparedness a. Inspection Scope (IP 69002, Section 02.05)

The inspector reviewed the following to verify the implementation of the Emergency Plan:

• RSB meeting minutes from May 28, 2015, to the present

• Postings of emergency information and phone numbers for the NSC

• Discussions with the Director, NSC, and the Associate Director, NSC

• Emergency response facilities, supplies, equipment, and instrumentation

• Offsite support and annual reconfirmation letters of agreement between NSC and the Baylor Scott & White Medical Center College Station and between NSC and the College Station Fire Department

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• TAMU AGN-201M Research Reactor Facility E-Plan, Revision 4, dated October 11, 2016, which included the following Implementing Procedures PE-1, Personnel Injury, approval dated October 2016 PE-2, Personnel Injury Involving Radioactive Contamination, approval dated October 2016 PE-3, Radioactive Contamination of Personnel or Spill of Radioactive Material Within the Reactor Facility, approval dated October 2016 PE-4, Suspected Radiation Overexposure of Personnel, approval dated October 2016 EA-1, Reactor Facility Fire, approval dated October 2016 EA-2, Bomb Threat, approval dated October 2016 EA-3, Civil Disturbance, approval dated October 2016 EA-4, Severe Natural Phenomenon, approval dated October 2016 EA-5, General Emergency Alert, approval dated October 2016 RE-1, Reactor Emergency, approval dated October 2016 b. Observations and Findings (1) Current E-Plan for the AGN-201M Research Reactor The inspector noted that the E-Plan in use by the licensee concerning the AGN-201M research reactor was not the same as the version on file with the NRC. The inspector informed that licensee that a copy of the current E-Plan for the AGN-201M research reactor should be submitted to the NRC. The licensee agreed that this should be done. The inspector informed the licensee that the issue of submitting a current version of the AGN-201M E-Plan to the NRC would be identified as an IFI and would be reviewed during a future inspection (IFI 50-059/2018-201-02).

Using the revised version in effect at the facility, the inspector verified that the various provisions pertaining to the AGN-201M reactor were as described in the E-Plan. The implementing procedures appeared to be sufficient to effectively implement the revised E-Plan. It was noted that the revised plan had been updated to reflect the current status of the AGN-201M research reactor (currently in possession only). It was noted that the revised E-Plan had been reviewed and approved by the RSB on October 11, 2016.

(2) Offsite Support Through records review, and interviews with licensee personnel, the inspector determined that emergency responders were knowledgeable of the proper actions to take in case of an emergency. Agreements with outside response organizations had been updated annually and were being maintained as required.

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(3) Emergency Notification To ensure appropriate emergency response personnel were notified in the event of an emergency, the Emergency Notification Roster was updated and verified quarterly. The inspector checked various phones at the facility and verified that an Emergency Notification Roster was located at or near each phone as required by E-Plan Section 7.1.

(4) Decontamination Facilities Section 8 of the E-Plan indicated that decontamination of personnel would be handled by NSC personnel. The plan also indicated that hot (contaminated) sinks and showers were available at the NSC for emergencies. The inspector toured the TRIGA Reactor Building and verified that sinks and showers were available to handle contaminated individuals as needed.

c. Conclusion A copy of the current version of the AGN-201M research reactor E-Plan should be submitted to the NRC. Emergency offsite support, notifications, and facilities were as required by the E-Plan. Decontamination facilities were available as required.

6. Exit Interview The inspection scope and results were summarized on September 20, 2018, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the results of the inspection and did not identify any information to be withheld from public disclosure.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Director, NSC J. Newhouse Associate Director and Radiation Safety Officer, NSC S. Miller TRIGA Reactor Manager D. Rios Safety Coordinator Other Personnel L. Vasudesan Manager and Radiological Safety Officer, Environmental Health and Safety Department, Texas A&M University INSPECTION PROCEDURES USED IP 69002 Class III Research and Test Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-059/2018-201-01 IFI Follow-up to ensure that the licensee submits the annual operating reports for the AGN-201M research reactor for the period from June 2015 to the present as required.

50-059/2018-201-01 IFI Follow-up to ensure that the licensee submits a current version of the AGN-201M research reactor E-Plan to the NRC.

Closed None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations AGN-201M Aerojet General Nucleonics-201 Modified E-Plan Emergency Plan IFI Inspector Follow-up Item IP Inspection Procedure NRC Nuclear Regulatory Commission NSC Nuclear Science Center Pu-Be Plutonium-Beryllium QA Quality Assurance RSB Reactor Safety Board SNM Special Nuclear Material TAMU Texas A&M University TEES Texas Engineering Experiment Station TSs Technical Specifications ZEC Zachry Engineering Complex Attachment