IR 05000170/2019201
| ML19057A199 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 03/14/2019 |
| From: | Anthony Mendiola Research and Test Reactors Oversight Projects Branch |
| To: | Gilstad J US Dept of Defense, Armed Forces Radiobiology Research Institute |
| Takacs M, NRR/DLP/PROB, 415-2042 | |
| References | |
| IR 2019201 | |
| Download: ML19057A199 (14) | |
Text
rch 14, 2019
SUBJECT:
ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000170/2019201
Dear Captain Gilstad:
From February 12-14, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Armed Forces Radiobiology Research Institute reactor facility. The enclosed report documents the inspection results which were discussed on February 14, 2019, with you and members of your staff.
The inspection examined activities conducted under your license as they relate to public health and safety, by confirming compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of this inspection, no findings of non-compliance 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 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 Michael Takacs at 301-415-2042 or by e-mail at Michael.Takacs@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. 50-170 License No. R-84 Enclosure:
As stated cc: See next page
Armed Forces Radiobiology Research Institute Docket No. 50-170 cc:
Director, Maryland Office of Planning 301 West Preston Street Baltimore, MD 21201 Montgomery County Executive 101 Monroe Street, 2nd Floor Rockville, MD 20850 Environmental Program Manager III Radiological Health Program Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd., Suite 750 Baltimore, MD 21230-1724 Director Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd., Suite 710 Baltimore, MD 21230 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Manager Nuclear Programs Maryland Department of Natural Resources Tawes B-3 Annapolis, MD 21401 Mr. Walter Dale Tomlinson Interim Reactor Facility Director Armed Forces Radiobiology Research Institute 4555 South Palmer Road, Building 42 Bethesda, MD 20889-5648
ML19057A199: *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB/SS* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME MTakacs NParker AMendiola DATE 2/26/2019 2/26/2019 3/14/2019
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-170 License No.: R-84 Report No.: 05000170/2019201 Licensee: Armed Forces Radiobiology Research Institute Facility: AFRRI Reactor Facility Location: Bethesda, MD Dates: February 12-14, 2019 Inspectors: Michael Takacs Kevin Roche Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure
EXECUTIVE SUMMARY Armed Forces Radiobiology Research Institute Research Reactor Facility NRC Inspection Report No. 05000170/2019201 The primary focus of this routine, announced inspection included the onsite review of selected aspects of the Armed Forces Radiobiology Research Institute (AFRRI or the licensee) Class II research reactor facility safety programs, including: (1) organization and staffing, (2) operations logs and records, (3) requalification training, (4) surveillance and limiting conditions for operation, (5) emergency planning, (6) maintenance logs and records, and (7) fuel handling logs and records. The licensees programs were acceptably directed toward the protection of public health and safety, and in compliance with U.S. Nuclear Regulatory Commission (NRC)
requirements.
Organization and Staffing
- The licensees organization and staffing were in compliance with the requirements specified in technical specification (TS) 6.1.
Operations Logs and Records
- Operational activities were consistent with the applicable TS and facility procedures.
Requalification Training
- Operator requalification was current and was being performed as required by AFRRIs reactor operator requalification program.
Surveillance and Limiting Conditions for Operation
- All surveillances were completed in accordance with TS 4.0 and the licensee was in compliance with limiting conditions for operations (LCOs) as specified in TS 3.0.
Emergency Planning
- The emergency preparedness program was generally conducted in accordance with the AFRRI emergency plan (EP).
Maintenance Logs and Records
- Maintenance activities were conducted in accordance with the applicable facility procedures.
Fuel Handling Logs and Records
- Fuel handling and inspection activities were completed and documented as required by the TS and facility procedures.
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REPORT DETAILS Summary of Facility Status The AFRRI 1.1 megawatt Training, Research, Isotopes, General Atomics (TRIGA) Mark F research reactor, located on the campus of the National Naval Medical Center, normally operated in support of the licensees mission of research, experiments, education, reactor operator training and periodic equipment surveillance. However, since March of 2018, the reactor has been in a shutdown status in support of the reactor console upgrade project.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001)
To verify that the licensees organization and staffing were in accordance with AFRRI TS 6.1, the inspector reviewed selected aspects of the following:
- Organizational structure
- Management responsibilities
- Staffing requirements for safe operation of the research reactor facility
- Reactor Logbook Number 139, December 1, 2016 to present b. Observations and Findings The licensees current organizational structure and assignment responsibilities were consistent with those specified in TS 6.1. However, there have been several staff changes in the organizational structure since the last inspection. By letter, dated March 13, 2018, the licensee notified the NRC that on April 2, 2018, the AFRRI Director (Level 1 management) had been replaced. Also, the licensee notified the NRC by letter, dated September 4, 2018, that the Reactor Facility Director (Level 2 management) had retired on August 31, 2018. The letter also stated that a new Reactor Facility Director had yet to be appointed and that the AFRRI reactor will not be operated until this position is permanently filled. These notifications are required by Section 6.6.b of the TS. In the interim, the AFRRI Reactor Operations Supervisor (Level 3 management), who currently holds a senior reactor operator (SRO) license, will be responsible for the safe status of the reactor facility. The inspector noted that in support of future reactor operations, there is currently only one qualified SRO and three reactor operator trainees. The inspector verified that all permanent staff positions were filled with qualified personnel. Review of records verified that management responsibilities were generally administered as required by TS 6.1.2 and applicable procedures.
c. Conclusion The licensees organization and staffing was in compliance with the requirements specified in TS 6.1.
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2. Operations Logs and Records a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify compliance with TS 2.0, 3.0, and 6.0 and applicable procedure requirements for operation:
- Reactor Logbook Number 139, December 1, 2016 to present
- AFRRI Operational Procedure 8, Reactor Operations, dated June 4, 1998
- AFRRI Operational Procedure 8, Tab A, Logbook Entry Checklist, dated March 13, 2001
- AFRRI Operational Procedure 8, Tab B, Daily Operational Startup Checklist, dated March 12, 2018
- AFRRI Operational Procedure 8, Tab I, Daily Operational Shutdown Checklist, dated March 12, 2018
- Daily Operational Startup and Shutdown Checklists, 2017 to present
- AFRRI 2017 Annual Report b. Observations and Findings The operating logs and records were well maintained and provided a clear indication of operational activities, changes in reactivity, and maintenance actions or malfunctions that had occurred. Logs and records also showed that operational conditions and parameters were consistent with license and TS requirements. Information on the operational status of the facility was recorded in logbooks and on checklists as required by procedure. Operational problems and events noted in the logs were reported, reviewed, and resolved as required.
Operations logs and records also documented that shift staffing met the minimum requirements.
c. Conclusion Operational activities were consistent with the applicable TS and procedural requirements.
3. Requalification Training a. Inspection Scope (IP 69001)
To verify that the licensee was complying with the requirements of the operator requalification program, the inspector reviewed selected aspects of:
- Reactor Operator Requalification Program for the Armed Forces Radiobiology Research Institute TRIGA Reactor Facility, revised September 12, 2016
- Effective dates of current operator licenses
- Operator training records maintained on Requalification Program Checklist, forms in individual folders for each operator
- Medical examination records for the past 2 years
- Operator requalification training lectures for 2018
- Facility written exam, administered in 2018-5-
b. Observations and Findings The inspector noted that the SRO was the only licensed operator on staff, and that there were three additional staff members who were reactor operator trainees. The inspector verified that the SRO had actively performed the functions of a senior licensed operator for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per calendar quarter. The inspector noted that operators were receiving the required biennial medical examinations.
A review of the logs and records showed that training was being conducted in accordance with the program. Requalification program data, such as attendance at training sessions and completion of written examinations and operation tests, was documented as required. The inspector noted that the required biennial written examination was administered in 2018 as required. Records of quarterly reactor operations, reactivity manipulations, and other operations activities were being maintained.
c. Conclusion Operator requalification was current and was being performed as required by the AFRRI reactor operator requalification program.
4. Surveillance and Limiting Conditions for Operation a. Inspection Scope (IP 69001)
To determine that LCOs were met and surveillances were completed as required by TS 3.0 and 4.0, the inspector reviewed selected aspects of the following:
- The 2017 AFRRI Annual Operating Report
- Malfunction Log from 2017 to present
- Reactor Logbook Number 139, December 1, 2016 to present
- Daily Operational Startup/Shutdown Checklist, 2017 to present
- Calibration procedures for the AFRRI reactor facility
- Maintenance procedures for the AFRRI reactor facility
- TRIGA Tracker Report b. Observations and Findings Daily, weekly, monthly, quarterly, semi-annual, and other periodic checks, tests, and verifications for the TS required LCOs were being completed as required.
The inspector verified that the ventilation system check was performed as required by TS 4.4, and the area radiation monitoring system check was also performed as required by TS 4.5.1. The inspector also reviewed selected portions of the environmental monitoring program records for the following:
(1) facility and environmental dosimetry, (2) external sampling of the surrounding soil, water, and vegetation, and (3) gaseous radioactive effluent releases. All environmental monitoring and sampling records indicated that they were analyzed quarterly in accordance with TS 4.5.2, and that all of the data indicated radiation doses to members of the public, in the uncontrolled areas, were within-6-
the limits specified under 10 CFR Part 20, Subpart D, Radiation Dose Limits for Individual Members of the Public.
The inspector reviewed a random sampling of operational logs and records and determined that they met the required LCOs. The licensee utilizes a computer database, the TRIGA Tracker Report, to track completion of the various required surveillance and LCO verifications. The inspector performed a random sampling of the database to ensure that there were no overdue requirements and cross-referenced the applicable TS to ensure all required surveillances were accounted for in the TRIGA Tracker Report. There were no issues noted.
c. Conclusion All surveillances were completed in accordance with TS 4.0 and the licensee was in compliance with the LCO requirements in TS 3.0.
5. Emergency Planning a. Inspection Scope (IP 69001)
The inspector reviewed the implementation of selected portions of the emergency preparedness program, including:
- AFRRI EP, dated December 2003
- AFRRI emergency drill conducted on December 12, 2018
- AFRRI emergency supplies
- AFRRI Emergency Response Guidebook (ERG), dated April 1996 b. Observations and Findings The inspector reviewed the AFRRI EP and noted that several documents referenced within the AFRRI EP were not the current versions (i.e., NRC Regulatory Guide 2.6, Emergency Planning for Research and Test Reactors, American National Standards Institute/American Nuclear Society (ANSI/ANS)-
15.16-2008, Emergency Planning for Research Reactors, and Environmental Protection Agency 400-R-92-001, Manual of Protective Action Guides and Protective Action for Nuclear Incidents.) The inspector also reviewed the AFRRI ERG and noted that this document contained the AFRRI emergency procedures as referenced in the AFRRI EP. The inspector noted that the AFRRI ERG had not been updated since April 1996 and that it contained, or potentially contained, outdated information. This information included: (1) various phone numbers for on-site and off-site emergency response support organizations, (2) reference to an AFRRI chemical inventory document, dated 1996, on page 43, (3) references to outdated or obsolete ANSI documents on page 2 of Appendix F, and (4)
reference to an Environmental Protection Agency decontamination procedure, dated 1985, on page 35. The updates to the AFRRI ERG by the licensee will be considered as an Inspection Follow-up Item (IFI) and will be reviewed during a subsequent inspection as IFI 05000170/2019201-01.
The inspector also noted that construction was currently being performed in the AFRRI N parking lot. Since this parking lot is depicted as part of the AFRRI-7-
diagram Emergency Evacuation Routes and Muster Locations on page A-3 of the AFRRI ERG, the licensee will continue to monitor the impact of the construction of the N parking lot and, if needed, revise the diagram in the AFRRI ERG and update its description in the AFRRI EP. The impact of the parking lot construction will also be considered as an IFI and will be reviewed during a subsequent inspection as IFI 05000170/2019201-02.
The inspector noted that the notification rosters in the control room and at the AFRRI guard desk were current and reviewed periodically in accordance with licensee procedure. The inspector verified that the four emergency supply boxes were inventoried quarterly and that their radiation survey meters were within their calibration period.
The inspector reviewed the 2018 annual drill report. The scenario was to exercise the licensees response to a contaminated, injured staff member. For this drill, AFRRI exercised its decontamination capability as specified in the AFRRI ERG. A post exercise review of the drill was conducted by all staff members involved, and all findings and recommendations from participants and drill observers were incorporated into the 2018 AFRRI drill report. This information was being appropriately tracked by the AFRRI Exercise Planner and would be applied to future emergency drills as appropriate.
c. Conclusion Emergency planning was generally conducted in accordance with the AFRRI EP.
The IFIs referenced above will be reviewed during the next scheduled inspection.
6. Maintenance Logs and Records a. Inspection Scope (IP 69001)
To determine that maintenance was being completed as required by the TS and applicable procedures, the inspector reviewed:
- AFRRI Malfunction Log from 2017 to present
- Reactor Logbook Number 139, December 1, 2016 to present
- Maintenance procedures for the AFRRI reactor facility
- TRIGA Tracker Report
- Annual Shutdown Maintenance Checklist b. Observations and Findings The inspector verified through select records that annual, semi-annual, quarterly, and monthly maintenance requirements were performed on their respective frequencies. Routine and preventive maintenance activities were adequately performed and documented in the TRIGA tracking system. Use of maintenance and malfunction logs satisfied procedural requirements. The inspector noted that when the pool water monitoring system failed its weekly alarm test, the licensee initiated appropriate and immediate compensatory measures until the component was repaired, tested, and returned to service.
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c. Conclusion Maintenance activities were conducted in accordance with the applicable procedures and were acceptable.
7. Fuel Handling Logs and Records a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with the procedural requirements in TS 6.3.e:
- AFRRI current stainless steel fuel element log book
- Control room reactor fuel inventory map
- Reactor Logbook Number 139, December 1, 2016 to present b. Observations and Findings The inspector noted that AFRRI maintains a current inventory record of all of their fuel elements. Information such as serial number, core position, and power history are adequately maintained and tracked. The inspector reviewed selected records for fuel movements and inspection results of the fuel elements. The inspector also verified that all fuel element locations, depicted on the control room reactor fuel inventory map, matched the information recorded in the fuel element log book.
c. Conclusion Fuel handling and inspection activities were completed and documented as required by the TS and facility procedures.
8. Followup a. Inspection Scope (IP 92701)
The inspector reviewed the actions taken in response to a previously issued NRC cited violation (VIO).
b. Observation and Findings VIO 50-170/2017-201-01 - Jurisdiction and control of the AFRRI N parking lot.
During a previous inspection in January 2017, the inspector noted that the licensee had implemented a change to eliminate AFRRIs jurisdiction and control of the AFRRI N parking lot without prior NRC approval. The licensee failed to document whether or not the change reduced the effectiveness of the AFRRI EP, and, if necessary, seek NRC approval for the change to the AFRRI EP. This resulted in a Severity Level IV violation to the licensee and was cited as VIO 50-170/2017-201-01.
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During this inspection, the inspector reviewed the actions taken by the licensee to resolve this issue. Based on the review of a letter submitted to the NRC from the licensee, dated April 25, 2017, and an interview with licensee, the inspector verified that full jurisdiction and control of parking lot N was restored to the licensee as originally described in the AFRRI EP.
c. Conclusion VIO 50-170/2017-201-01 is now considered resolved and closed.
9. Exit Interview The inspector presented the inspection results to licensee management at the conclusion of the inspection on February 14, 2019. The inspector described the areas inspected and discussed the inspection observations. The licensee acknowledged the findings presented and did not identify any of the material provided to or reviewed by the inspector as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel Director, AFRRI (Captain, U.S. Navy)
W. Tomlinson Interim Reactor Facility Director (SRO)
H. Spence Records Administration Specialist J. Molgaard Department Head, Radiation Sciences Department (Major, U.S. Army)
S. Moore Non-Commissioned Officer in Charge (Sergeant First Class, U.S. Army)
K. Wardlow Health Physics Technician (Petty Officer Second Class, U.S. Navy)
INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened IFI 05000170/2019201-01 The AFRRI ERG, dated April 1996, contains outdated information and needs to be updated.
IFI 05000170/2019201-02 Review the impact of the N parking lot construction to AFRRIs emergency evacuation routes and muster locations as referenced on page A-3 of the AFRRI ERG Closed VIO 50-170/2017-201-01 Jurisdiction and control of AFRRI N parking lot Discussed None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Documents Access and Management System AFRRI Armed Forces Radiobiology Research Institute EP Emergency Plan ERG Emergency Response Guidebook IFI Inspection Follow-up Item IP Inspection Procedure LCO Limiting Condition for Operation NRC U.S. Nuclear Regulatory Commission SRO Senior Reactor Operator TS Technical Specification(s)
TRIGA Training, Research, Isotopes, General Atomics VIO Violation Attachment