IR 05000182/1999201

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Insp Rept 50-182/99-201 on 990412-15.No Violations Noted. Major Areas Inspected:Operations,Organizational Structure & Functions,Design Control,Review & Audit,Radiation Protection & Environ Protection Programs
ML20206K800
Person / Time
Site: Purdue University
Issue date: 05/06/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20206K798 List:
References
50-182-99-201, NUDOCS 9905140005
Download: ML20206K800 (19)


Text

{{#Wiki_filter:L .. r U. S. NUCLEAR REGULATORY COMMISSION Docket No: 50-182 License No: R - 87 Report No: 50-182/99 201 Licensee: Purdue University Facility: Purdue University PUR-1 Research Reactor Location: West Lafayette, Indiana Dates: April 12-15,1999 inspector: Thomas M. Burdick, Non-Power ReacJor inspector Approved by: Ledyard B. Marsh, Chief Events Assessment, Generic Communications and Non-Power Reactors Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation

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EXECUTIVE SUMMARY l

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This routine, announced inspection included onsite review of selected aspects of the: operations program, organizational structure and functions program, design control program, review and audit program, radiation protection program, environmental , protection program, operator requalification program, maintenance program, surveillance l program, fuel handling program, experimental program, procedural control program, emergency preparedness program, safeguards program, security program, and transportation program since the last NRC inspection of this progra l The licensee's programs were acceptably directed toward the protection of public health and safety, and in compliance with NRC requirement ORGANIZATIONAL STRUCTURE AND FUNCTIONS The laboratory director obtained an NRC reactor operator license and plans to pursue a senior reactor operator license later this yea OPERATIONS Operations were conducted intermittently at various power levels and in compliance with license requirement DESIGN CONTROL No design changes were performed since the last inspectio A new form was implemented to document 50.59 review The licensee had concluded that the reactor facility will not be impacted by the year 2000 computer problem since no microprocessors or computers were incorporated in the facility systems REVIEW AND AUDIT The licensee committed to using qualified persons who are not responsible for the programs being audited for future required audit RADIATION PROTECTION Only minor levels of exposure were recorded since the last inspectio Contamination has not been a problem due to conscientious licensee effor .;

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ENVIRONMENTAL PROTECTION No significant release occurred and minirral waste was generate OPERATOR REQUALIFICATIQN f'

 ~ The program was reestablished after mary years of exemptio MAINTENANCE '

s Facility maintenance was typically preventive and well documente Materiel conditions were significantly improve . SURVEILLANCE

 ' Surveillance was timely and satisfied operability requirement FUEL HANDLING p

Fuel handling was routine and well documente EXPERIMENTS' Nn new experiments were conducte PROCEDURES Proce'dures were acceptable. The licensee developed a new one for determining control rod wort EMERGENCY PREPAREDNESS Licensee drills and training ensured acceptable licensee readines SAFEGUARDS Safeguards for possession of special nuclear material were acceptabl SECURIT Facility security met program requirement /

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- TRANSPORTATION
,: The licensee had not conducted any transportation of licensed material since the last
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! Report Details Summary of Plant Status Since the last inspection the reactor had been operated intermittently at various power

' levels to support experiments, education, operator training, and surveillance. Materiel conditions had improved significantl . ORGANIZATIONAL STRUCTURE AND FUNCTIONS
      ; Scope (69001)

The inspector reviewed: e organization and staffing e qualifications e management responsibilities e administrative controls Observations and Findinos The organizational structure and staffing had changed since the last inspection. The reactor supervisor and laboratory diloctor were separated into two positions in January 1997. The laboratory director obtained a reactor operator license and plans to obtain a senior reactor operator license later this year. The former reactor supervisor / lab director had been working part time and will fully retire in May 199 The organizational structure and staffing at the facility and as reported in the Annual Report was as required by Technical Specificatio Two members of the Committee on Oversight of Reactor Operations (CORO) are scheduled for retirement this year. One of the CORO positions was required by technical specifications (TS) to be the Purdue University Director of Safety and Security. Due to reorganizations, title changes, and delegation of responsibilities, the CORO membership had not always been filled by the person holding that title or its equivalent. The licensee has recommended that the Chief / Director of the Purdue University Police Department (the equivalent person) hold that position in the future. The licensee plans to request a TS amendment to change the requiremen All incumbent members and their proposed replacements appeared to be qualified to sit on the COR Review of records verified that management responsibilities were administered as required by TS and applicable procedure i

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E*. A t-2- Conclusions The organizational functions satisfier' NRC requirement . OPERATIONS

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a;- Scope (69001) . The inspector reviewed: e operational logs and records -

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e- staffing for operations Le- selected operational, startup, or shutdown activities Observations and Findinas

 .The operating logs and records were legible and provided an indication of
 = operational activities. This included documentation of events, and resolution or tracking of events. The logs and records indicated that shift staffing including on- )

call personnel was as required by T '

 ' The inspector noted that the former reactor supervisor (working part-time until full l retirement in May' 1999), although holding a current license, had not obtained a )

physical examination 'since February 25,1997. The inspector reminded the { licensee that operators must have a physical examination biennially (includes a 30-day period after the anniversary date). The other licensed staff members had j current physical examinations. The licensee had. the schedule for physical l examinations in their surveillance tracking syste { t The licensee had noted that the TS staffing requirement'for startup following an unscheduled scram was less restrictive than the regulations in 10 CFR 50.54(m).

.The inspector verified through the licensee records that they had met the requirements of 50.54(m) which requires a senior reactor operator present in the

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 - facility during a reactor restart following an unscheduled shutdown. The licensee plans to establish that past practice in their operating procedur . .
 .The inspector noted that.the last two TS audits cited the requirement to log channel checks at four hour intervals. A review of the logs indicated that the j-intervals were stated as hourly. The licensee acknowledged that the logs need to )'
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   -3-Logs and records also showed that operational conditions and parameters were consistent with license and Technical Specification requirements. Discussion with the staff regarding operational activities further confirmed that these conditions and requirements were satisfied. No operations were conducted during the inspection, c. Conclusions The operational functions satisfied NRC requirement . DESIGN CONTROL
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a. ScoDe (69001) The inspector reviewed:

* facility design changes and records e facility configuration b. Observations and Findinas Through review of applicable records and observations of the facility, the inspector determined that changes initiated and/or completed at the facility had undergone an acceptable review in accordancs with 10 CFR 50.59 and applicable licensee administrative controls. None of the changes constituted an unreviewed safety question or required a change to the T The licensee had implemented a systematic method of documenting changes and their evaluation for unreviewed safety questions required by10 CFR 50.5 The licensee had concluded that the reactor facility will not be impacted by the year 2000 computer problem since no microprocessors or computers ware incorporated in the facility system c. Conclusions ,

The design change functinns satisfied NRC requirements.

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l 4 Scope (69001) The inspector reviewed - Safety review records - e- '. Audit records e Responses to safety reviews and audits Review and audit personnel qualifications

. Observations and Findinas Records showed that the safety reviews were conducted at the Technical
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SpeciNation required frequency. Topics of these reviews were also consistent

 - with Technical Specification requirements to pr. ovide guidance, direction, and oversight, and to ensure suitable use of the reacto The inspector noted'that the safety reviews and audits, and the associated findings
 . were acceptably detailed and that the licensee responded and took corrective actions as neede The safety review and audit personnel had not always met Technical Specification requirements and licensee administrative. controls. Both the Emergency Plan and the Security Plan had been audited by members of the staff who were directly responsible for the program implementation. The audits of these areas appe'ared acceptable in depth and scope. However, TS 6.2.6 required that the audits be conducted by persons other than those responsible for the program implementation. The number of personnel involved in the safety reviews and audits satisfied Technical Specification and licensee procedural requirements. The licensee committed to ensure that future audits will be conducted by qualified
 ' personnel who are not responsible for the program implementation. This failure was a violation of minor significance and,in accordance with NUREG/BR 0195 (Rev 2), NRC Enforcement Manual, Section 3.5.c, is not subject to formal enforcement action. It will be reviewed for corrective action in the future (50-182/99201-01). Conclusions   -

The review and audit function satisfied NRC requirements with one minor exception, e'

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I i-E: RADIATION PROTECTION l l Scope (69001) l The inspector reviewed selected aspects of: e the Radiation Protection Program o radiological signs and posting i e routine surveys and monitoring e dosimetry records e maintenance and calibration of radiation monitoring equipment ) e As Low As Reasonably Achievable (ALARA) reviews

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' The radiation protection program had not changed since the last inspection. The licensee's review of the radiation protection program at least annually in accordance with 10 CFR 20.1101(c) was not documented. The licensee  j committed to document its future reviews in the TS audit for the reactor. This will
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be reviewed in a future inspection (50-182/99201-02).

NRC Form 3, " Notice to Employees," was posted in accordance with 10 CFR 19.11. Caution signs, postings and controls to radiation areas were as required in 10 CFR 20, Subpart J. Licensee personnel observed the indicated ' precautions for access to the radiation area Use of dosimeters and exit surveying practices were in accordance with radiation protection requirements. The licensee used a National Voluntary Laboratory Accreditation Program (NVLAP)-accredited vendor to process dosimetr Radiological exposure records showed that occupational doses and doses to the public were within 10 CFR Part 20 limitations. Training records showed that personnel were acceptably trained in radiation protection practice Experiments were typically class experiments limited to predominantly solid form samples with short-lived isotopes at minimum exposure and low energy used repeatedly from class to class. This minimized the chances of contamination and exposur Radiation monitoring and survey activities were as required. Equipment usec for ,

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these activities were maintained, calibrated and used acceptably. The inspector conducted an independent random radiation survey that confirmed licensee finding _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ -

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   -6-ALARA reviews were acceptably performed as required. Documentation for one review of an extremity exposure was not available. The licensee indicated that the 440 millirem extremity exposure was most likely received at the broad-scope instrument calibration lab. The individual works there part-time and uses radioactive sources for calibration The licensee did not require a respiratory protection program or planned special exposure progra Conclusions The radiation protection program satisfied NRC requirement . ENVIRONMENTAL PROTECTION Scope (69001)-

The inspector reviewed selected aspects of: ' e the environmental monitoring program e annual reports e release records

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e counting and analysis program Observations and Findinas Environmental samples were collected, prepared, and analyzed consistently with the Technical Specification requirements. Laboratory equipment was maintained and calibrated acceptably. Data indicated that no measurable dose above background. This was acceptably documented in the Annual Reports. Observation of the facility found no new potential release paths. The licensee showed that the air emissions or radioactive material to the environment met the 10 millirem constraint specified in 10 CFR 20.1101(d).

The facility design minimizes release paths and sources of effluent The program for the monitoring and storage of radioactive liquid, gases, and solids was consistent with applicable regulatory requirements. Radioactive material was monitored and released when below acceptable limits or was acceptably transferred to the broad-scope license for disposition. The principles of As Low As Reasonably

. Achievable were acceptably implemented to minimize radioactive release Monitoring equipment was acceptably maintained and calibrated. Records were current'and acceptably maintained.

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   -7- Conclusions The environmental protection program satisfied NRC requirement . . OPERATOR REQUALIFICATlON Scoos (69001)

The inspector reviewed selected aspects of: e the Requalification Program e- operators licenses ' e-' operator training records e operator physical examination records-e operator examination records-e operator active duty status Observations and Findinas-The Requalification Program was reestablished last summer, after many years of exemptions as allowed in a letter from James R. Miller, dated March 23,198 Operators' licenses'were current. Records showed that operator training was consistent with the Requalification Program requirements. Physical examinations of

.the operators were conducted as required.' Records showed that written and operating examinations of the operators were : acceptably implemented. The-inspector.noted that the staff misunderstood their pro (,. m requirements for-examinations and discussed clarification of the issue with the staff. Logs showed that operators maintained active duty status as require Conclusions Operator requalification was conducted as required by tho Requalification Progra . MAINTENANCE Scope (69001)
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'- e maintenance procedures e equipment maintenance records l l

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   - 8- Observations and Findinas Logs indicated that corrective maintenance activities and problems were addressed as required by procedure.. Records showed that routine maintenance activities were conducted at the required frequency and in accordance with the TS, or the
. applicable procedure or equipment manual. Maintenance activities ensured that equipment remained consistent with the Safety Analysis Report and Technical Specification requirements. Further, maintenance activities were consistent with the requdaments of 10CFR50.5 The licensee had made significant improvement in the material condition of the facility by removing an unused machinery pedestal structure and wall insulation materials and recoating all concrete surface . Conclusions The maintenance program satisfied NRC requirement . SURVEILLANCE Scope (69001) .

The inspector reviewed selected aspects of: _ surveillance and calibration procedures, e surveillance, calibration and test data sheets and records Observations and Findinos Surveillance, test, and verifications and calibrations were completed on schedule and in accordance with licensee procedures. All the recorded results were within the TS and procedurally prescribed parameters. The records and logs reviewed were complete and were being maintained as required. Checks, tests, and calibrations were completed as required by T The licensee had meticulously verified the viability of determining control rod worth using subcritical multiplication before implementing a procedure for its use.

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i Conclusions The surveillance program satisfied Technical Specification requirement .: 10.- FUEL HANDLING Scope (69001). - l The inspector reviewed selected aspects of: f e fuel handling procedures i >

  .e- : fuel handling equipment and instrumentation e fuel handling and examination records I
 - : Observations and Findinas Fuel handling procedures provided a prescribed method to move and handle fuel consistent with the provision of the TS and the licensee safety analyses. Fuel movement and fuel examination records showed that the fuel was moved and
  - examined as required. Records also show that fuel handling and monitoring equipment and instrumentation was verified operable prior to use. Personnel were knowledgeable of the procedural and equipment requirements for criticality control and assurance of fuelintegrity. Radiological and security precautions were also met in accordance with applicable procedures, Conclusions The fuel hant' ling program satisfied licensee Technical Specification and procedural requirements .
 ' 1 EXPERIMENTS l Scope (69001)
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  ,e- experimental administrative controls and precautions I

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   -10- Observations and Findinas The experiments at the facility were routine procedures that had been in place for
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predominantly solid form samples with short-lived isotopes at minimum exposure l and low energy used repeatedly from class to class. No new or unknown type experiments had been initiated, reviewed, or approved since the last inspectio The experiments were completed with the cognizance of the Reactor Supervisor - and a Senior Reactor Operator and in accordance with Technical Specification requirements (e.g., reactivity limitations). The results of the experiments were documented in acceptable experimental logs, data sheets, or records. Engineering and radiation protection controls were implemented as required to limit exposure to radiatio Conclusions

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The program.for experiments satisfied Technical Specification and procedural requirement .- PROCEDUR Scope : (69001).. The inspector reviewed selected aspects of: e administrative controls - records for changes and temporary changes - e procedural implementation ' e logs and records i Observations and Findinas

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Administrative controls of changes and temporary changes to procedures, and

.associsted review and a'pproval processes were as required. Training of personnel on procedures and changes was acceptab!e. Personnel conducted activities in accordance with applicable procedures. Records 's howed that procedures for potential malfunctions (e.g., radioactive releases and contaminations, and reactor
.. equipment problems) were implemented as require LThe licensee had produced a new procedure for control rod worth measurement that had been carefully evaluated before implementatio ,
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The procedural control'and implementation program satisfied Technical . Specification requirement . EMERGENCY PREPAREDNESS

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The inspector reviewed selected aspects of: e the Emergency' Plan e implementing procedures e emergency response facilities, supplies, equipment and instrumentation l e training records e offsite support e emergency drills and exercises Observations and Findinas The Emergency Plan (E-Plan) in use at the reactor and emergency facilities was the same as the version most recantly approved by the NRC. The E-Plan.was audited i and reviewed as required. ' implementing procedures were reviewed and revised as needed to employ the E-Plan effectively. Facilities, sup' plies, instrumentation and . equipment were being maintained, controlled and inventoried as required in' the E-l Plan. Through records review and interviews with licensee personnel, emergency . responders were determined to be knowledgeable of.the proper actions to take in ] case of an emergency. Communications capabilities were acceptable with these j

 , support groups and had been tested as stipulated in the E-Plan. Emergency drills had been conducted as required by the E-Plan. Off-site support organization
 : participation was also as required by _the E-Plan. -Critiques were held following the
 . drills to discuss the strengths and weaknesses identified during the exercise and to develop possible solutions to any problems identified. The results of these critiques were documented and filed. Emergency preparedness and response training was being completed as required. Training for off-site and reactor staff personnel was crnducted and documented as stipulated by the E-Pla Conclusions The emergency preparedness program was conducted in accordance with the Emergency Pla l
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' 1 SAFEGUARDS Scope . (85102) .

> The lnspector reviewed selected aspects of: nuclear material inventory and locations . e accountability records Observations and Findinos The inventory of material was verified. The material control and accountability program tracked locations and content of fuel and fission detectors under the research reactor license. The possession and use of special nuclear material (SNM) were limited to the locations and purposes authorized under the license. The material control and accountability forms (DOE /NRC Forms 741 and 742) were prepared and transmitted as require Conclusions Special Nuclear Materials were acceptably controlled and inventorie . SECURITY Scope -(81401/81431) The inspector reviewed. selected aspects of: e the Physical Protection Plan e security systems, equipment and instrumentations , e implementation of the Physical Protection Plan '

. Observations and Findinas The Physical Protection Plan was the same as the latest revision approved by the NRC. Physi, cal protection systems (barriers ana alarms), equipment and 1
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instrumentation were as required by the Physical Protection Plan. Access control was as required. implementing procedures were consistent with the Physical

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Protection Plan. Acceptable security. response and training were demonstrated

 .through alarm response and drill response in accordance with procedure . Conclusions Security activities'and systems satisfied Physical Protection Plan requirement .

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L1 TRANSPORTATION Sggna (86740) The inspector reviewed ' selected aspects of:

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e- ~ radioactive materials shipping procedures e radioactive materials transportation and transfer records Observations and Findinas Records showed that the radioactive material for disposal was transferred to the broad scope license in accordance with licensee requirements. This program for radioactive material transport is consistent with license requirement The licensee had not transferred any radioactive material subject to Department of Transportation regulations since the last inspection, Conclusions The program for transportation of radioactive materials satisfied NRC requirement . 1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection. The licensee acknowledged the findings presente ..

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Licensee Staff Contacted -! i Edward Merritt . Reactor Supervisor l Robert Bean Laboratory Director

 . Jim Schweitzer Radiation Safety Officer
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Other members of.the licensee staff and management were also contacted during the inspectio inspection Procedures Used 11P 69001 . Class 11 Non; power Reactors IP 86740 Inspection of Transportation Activities IP 81401 Plans, Procedures, and Reviews IP 81431 Fixed Physical Security Protection IP 8510 Material Control and Accounting items Opened and Closed Open 99201-01 IFl Audits by persons not responsible for program implementation 99201-02 IFl . Annual radiation protection program review documentation

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List of Documents Reviewed Safety Analysis Report Emergency procedure Safety Evaluation Report Training Program

 . Reactor Operating License   Security Plan
 ; Technical Specifications ~   Emergency Plan Administrative Procedures -   Dosimetry Records Operating Procedures .   ' Training Records
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, Maintenance Procedures Various Reports Surveillance Procedures-

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I-2- I l List of Acronyms Used l l l ALARA As Low as Reasonably Achievable l CFR Code of Federal Regulations CORO Committee on Reactor Operations DO Department of Transportation HP- Health Physics NRC Nuclear Regulatory Commission ,

.PDR Public Document Room
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RSO Radiation Safety Officer SAR Safety Analysis Report SNM Special Nuclear Material TS Technical Specifications

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