IR 05000188/2021201
| ML21161A139 | |
| Person / Time | |
|---|---|
| Site: | Kansas State University |
| Issue date: | 07/14/2021 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Cebula A Kansas State University |
| Bassett C | |
| References | |
| IR 2021201 | |
| Download: ML21161A139 (15) | |
Text
July 14, 2021
SUBJECT:
KANSAS STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000188/2021201
Dear Dr. Cebula:
From June 1-3, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Kansas State University Nuclear Reactor Facility. The enclosed report documents the inspection results, which were discussed on June 3, 2021, with you, the Reactor Supervisor, and the campus Radiation Safety Officer.
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 selective procedures and records, observed various activities, and interviewed 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 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 Publicly Available Records component of NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at https://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
A . Cebula 2 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, Signed by Tate, Travis on 07/14/21 Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-188 License No. R-88 Enclosure:
As stated cc w/enclosure: See next page
Kansas State University Docket No. 50-188 cc:
Office of the Governor State of Kansas 300 SW 10th Avenue, Suite 212 S Topeka, KS 66612-1590 Kim Steves Radiation Control Section Kansas Department of Health and Environment 1000 SW Jackson, Suite 330 Topeka, KS 66612-1365 Mayor of Manhattan City Hall 1101 Poyntz Avenue Manhattan, KS 66502 Robert Seymour, Reactor Supervisor Kansas State University 117 Ward Hall Manhattan, KS 66506 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Department of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115
ML21161A139 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME CBassett NParker TTate DATE 06/14/2021 06/14/2021 07/14/2021
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No. 50-188 License No. R-88 Report No. 05000188/2021201 Licensee: Kansas State University Facility: Kansas State Nuclear Reactor Location: Manhattan, Kansas Dates: June 1-3, 2021 Inspector: Craig Bassett Accompanied by: Andrew Waugh, Inspector Trainee Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure
EXECUTIVE SUMMARY Kansas State University Kansas State Nuclear Reactor Inspection Report No. 05000188/2021201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the Kansas State University (KSU, the licensees) Class II research reactor facility safety program including: (1) organization and staffing; (2) procedures; (3) health physics (4) design changes; (5) committees, audits and reviews; and (6) transportation activities. The U.S. Nuclear Regulatory Commission (NRC) staff determined the licensees safety program was acceptably directed toward the protection of public health and safety and in compliance with NRC requirements.
Organization and Staffing Organization and staffing were consistent with the requirements outlined in Section 6 of the facility technical specifications (TSs).
Shift staffing met the minimum requirements for duty and on call personnel.
Procedures Written procedures were maintained in accordance with TS requirements.
Health Physics The radiation safety program was conducted in compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection against Radiation, requirements, the TSs, and licensee procedures.
Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
Design Changes The review and evaluation of changes to the facility and procedures satisfied NRC requirements as specified in 10 CFR 50.59, Changes, tests and experiments.
Committees, Audits and Reviews The Reactor Safeguards Committee provided the oversight required by the TSs.
Transportation Activities No shipments was made from the reactor facility under the reactor license during the past 2 years.
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REPORT DETAILS Summary of Facility Status The KSU 1,250-kilowatt reactor continued to be operated in support of the Universitys academic program in nuclear engineering laboratory instruction and research. During the inspection, the reactor was not operated.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)
The inspector reviewed the following to verify compliance with the organization and staffing requirements in TS Section 6.1:
KSU nuclear reactor organizational structure and staffing TSs for the KSU TRIGA (Training, Research, Isotopes, General Atomics)
Mark II Reactor, dated March 13, 2008, and amended April 2011 KSU TRIGA Mark II Reactor console logbooks covering operations from January 2019 to the present KSU TRIGA Mark II Reactor Daily Reactor Startup and Shutdown Checklist from January 2019 to the present 2019 Annual Operating Report for KSU TRIGA Mark II Nuclear Reactor Facility dated February 28, 2020 2020 Annual Operating Report for KSU TRIGA Mark II Nuclear Reactor Facility dated February 26, 2021 b. Observations and Findings The inspector noted that the organizational structure and the responsibilities of the reactor management and staff had not changed since the last inspection (NRC Inspection Report No. 50-188/2020-201). Review of pertinent records by the inspector verified that management responsibilities were administered as required by the TSs and applicable procedures. The inspector reviewed reactor operations and noted that the shift staffing satisfied the requirements indicated in the TSs. The inspector noted that there were three senior reactor operators and one reactor operator who were licensed to operate the research reactor at the facility.
c. Conclusion The inspector determined that the licensees organization and staffing complied with the requirements specified in TS Section 6.1. The inspector also determined that the operations log and associated records confirmed that shift staffing met the minimum requirements for duty and on call personnel.
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2. Procedures a. Inspection Scope (IP 69001, Section 02.03)
The inspector reviewed the following to ensure that the requirements of TS Section 6.3 were met concerning written procedures:
TSs for the KSU TRIGA Mark II Reactor KSU TRIGA Mark II Reactor Safeguards Committee (RSC) meeting minutes for 2019 through 2021 to date KSU TRIGA Mark II Operation, Test, and Maintenance Procedures, Procedure No. 5, Semi-Annual Minimum Interlock & SCRAM Checks b. Observations and Findings The inspector confirmed that oversight and review of procedure implementation was provided by licensee management and the RSC. All procedures reviewed by the inspector were reviewed and approved by the RSC and signed by the RSC Chairman as required by the TSs. During the inspection, the inspector noted procedure compliance by the reactor staff.
c. Conclusion The inspector verified that the licensee maintained and implemented written procedures in accordance with the TS requirements.
3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)
The inspector reviewed the following to verify compliance with 10 CFR Part 20 requirements:
results of periodic calibrations of air monitors and hand-held meters sump discharge calculations for 2019 and 2020 maintained in the waste disposal log notebook nuclear reactor facility monthly radiation and smear surveys for June 2019 to the present copies of the monthly the radiation dosimetry report for facility personnel for 2019, 2020, and 2021 KSU Nuclear Reactor Radiation Protection Program dated August 23, 2011 KSU, Environmental Health and Safety Department, Radiation Safety Manual dated August 2018 copies of various Semiannual Audit Report of Reactor Operations and Radiation Protection Program, from 2019 through 2021 various KSU TRIGA Mark II Operation, Test, and Maintenance Procedures including: Procedure No. 3, Annual Remote Area Monitor Calibration; Procedure No. 9, Entrance to the Reactor Bay; Procedure No. 13, General Radiation Detector Calibration and Efficiency Determination; and, Procedure No. 19, Gamma-Ray Assay of Reactor Samples-4-
last two Annual Operating Reports for KSU TRIGA Mark II Nuclear Reactor Facility b. Observations and Findings (1) Surveys The inspector reviewed selected monthly and other periodic and special radiation and/or contamination surveys. The inspector noted that any contamination detected in concentrations above established action levels was noted and the area or item was decontaminated. The inspector also verified that the results of the surveys were documented by staff personnel as required by procedure.
During the inspection the inspector accompanied the Reactor Supervisor (RS) during completion of a routine monthly radiation and contamination survey. The inspector noted that proper techniques were used during the survey and the survey was conducted and documented in accordance with the guidance specified by procedure. No anomalies were noted.
(2) Postings and Notices The inspector observed various radiological signs and noted that they were typically posted at the entrances to controlled rooms, or at the areas themselves (i.e., beam ports or experimental equipment). The inspector confirmed that caution signs, postings, and controls for radiation areas were as required by 10 CFR Part 20, Subpart J.
The inspector confirmed that copies of current notices to workers were posted in various areas in the facility. The copy of NRC Form 3, Notice To Employees, noted at the facility was the latest issue and was posted as required by 10 CFR 19.11, Posting of notices to workers.
(3) Dosimetry and Completed Copies of NRC Form 5 The inspector verified that the licensee used thermoluminescent dosimeters (TLDs) for whole body monitoring of beta and gamma radiation exposure. The inspector noted that the licensee also used TLD finger rings for extremity monitoring. The inspector confirmed that the dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor, Mirion Technologies Inc. The inspector examined the TLD results indicating radiological exposures at the facility for the past 3 years. The results showed that the highest occupational doses, as well as doses to the public, were well within 10 CFR Part 20 limits. Through direct observation the inspector determined that dosimetry was acceptably used by KSU reactor facility personnel.
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The inspector verified that individual copies of the NRC Form 5, Occupational Dose Record for a Monitoring Period, were routinely issued to each licensee staff member. No problems were noted.
(4) Calibration of Radiation Survey and Monitoring Equipment The inspector examined selected meters in the facility which were used for radiation monitoring. The inspector found that the instruments had the acceptable up-to-date calibration sticker attached. The inspector verified that the instruments were calibrated semi-annually which met procedural requirements. The inspector confirmed that area radiation monitors and the continuous air monitor were calibrated annually as required by the KSU Radiation Protection Program (RPP).
(5) Radiation Protection Training The inspector reviewed the radiation worker and orientation training given to KSU reactor facility staff members, to experimenters, and to students taking classes at the facility. The inspector noted that the training included initial radiation worker training for those who were new and just beginning the program. More extensive training was provided in the laboratory courses. The inspector reviewed the completed forms of various KSU reactor staff members and students and verified that they had the appropriate training. The inspector confirmed that the training program was consistent with the requirements outlined in 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations. Annual refresher training was required to be competed for licensee personnel.
(6) Radiation Protection Program The inspector confirmed that the licensees radiation protection and as low as reasonably achievable (ALARA) programs were established in the Kansas State University Nuclear Reactor Radiation Protection Program, booklet which was dated August 23, 2011, in conjunction with the KSU Environmental Health and Safety Department, Radiation Safety Manual dated August 2018. The inspector noted that the RPP contained instructions concerning organization, training, monitoring, record keeping, personal responsibilities, audits, emergency equipment, and maintaining doses ALARA. The ALARA portion of the booklet provided guidance for keeping doses ALARA which was consistent with the requirements in 10 CFR Part 20. The inspector verified that the RPP was reviewed annually as required by 10 CFR 20.1101, Radiation Protection Programs, paragraph (c).
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(7) Effluent and Environmental Monitoring (a) Environmental Radiation Monitoring The inspector noted that site radiation monitoring was completed using a TLD positioned outside one of the windows of the reactor dome.
Data indicated that there were no measurable doses above natural background radiation measured by this TLD.
(b) Effluent Releases The inspector verified that gaseous releases continued to be calculated and reported in the Semiannual Audit Report of Reactor Operations and Radiation Protection Program conducted by the Reactor Manager. The inspector confirmed that airborne concentrations of the gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2. The inspector also noted that the dose rate to the public because of the gaseous releases, was calculated to be 3.8 millirem (mrem) per year which was well below the dose constraint specified in 10 CFR 20.1101(d) of 10 mrem per year. This was documented in Chapter 11 of the facility Safety Analysis Report dated May 23, 2008.
(c) Liquid Releases The inspector reviewed the annual reports for 2019 and 2020. The inspector also reviewed all liquid discharges from the reactor bay sump to the sanitary sewer during that period. The inspector confirmed that all isotopic levels were below 10 CFR Part 20, Appendix B limits.
(d) Liquid and Solid Radioactive Waste The inspector reviewed the licensees program for monitoring, storing, and/or transferring radioactive liquid and solid waste. Liquid and solid radioactive waste was stored on-site awaiting disposal. The inspector interviewed the campus Radiation Safety Officer (RSO). The RSO indicated that the waste could not be transferred to the KSU Materials License due to restrictions enumerated in the license. The inspector noted that KSU held a State of Kansas Materials License No. 38-0011-01 for processing and disposal of all other campus radioactive waste.
(8) Facility Tours The inspector toured the facility to observe licensee personnel and practices regarding the use of dosimetry and radiation monitoring equipment, the placement of radiological signs and postings, and practices for handling and storing radioactive material or contaminated equipment. No problems were noted.
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c. Conclusion The inspector determined that the radiation safety program was conducted in compliance with 10 CFR Part 20 and TSs requirements, and licensee procedures.
4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)
The inspector reviewed the following to ensure that, if design changes were made, they were reviewed and approved in accordance with 10 CFR 50.59, the TS, and the licensees administrative procedures:
TSs for KSU TRIGA Mark II Reactor KSU TRIGA Mark II RSC meeting minutes for 2019 through 2021 to date KSU TRIGA Mark II Reactor console logbooks covering operations from January 2018 to the present last two Annual Operating Reports for KSU TRIGA Mark II Nuclear Reactor Facility b. Observations and Findings The inspector confirmed that, during 2020 and to date in 2021, the licensee performed a 10 CFR 50.59 review for one experimental method change. The inspector noted that the 10 CFR 50.59 review was submitted to the RSC for review. The RSC approved the change.
c. Conclusion The inspector determined that the review and evaluation of changes to facilities, experiments, and procedures satisfied NRC requirements specified in 10 CFR 50.59.
5. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)
The inspector reviewed the following to ensure that audits and reviews stipulated in the facilitys TS were conducted by the RSC:
TSs for KSU TRIGA Mark II Reactor KSU TRIGA Mark II RSC meeting minutes for 2019 through 2021 to date KSU TRIGA Mark II Reactor console logbooks covering operations from January 2019 to the present copies of the Semiannual Audit Report of Reactor Operations and Radiation Protection Program for 2019 through 2021 to date last two Annual Operating Reports for KSU TRIGA Mark II Nuclear Reactor Facility-8-
b. Observations and Findings The inspector verified that the RSC conducted meetings twice a year as required with a quorum present, pursuant to TS requirements. The inspector confirmed that the RSC conducted the required audits and reviewed and approved procedure and experiment changes and facility modifications. The inspector noted that the RSC provided direction and oversight for reactor operations.
c. Conclusion The inspector determined that the RSC conducted the reviews and audits required by the TSs.
6. Transportation Activities a. Inspection Scope (IP 86740)
Regarding the of transportation of radioactive material, the inspector reviewed the following:
RSC meeting minutes for 2019 through 2021 to date last two Annual Operating Reports for KSU TRIGA Mark II Nuclear Reactor Facility b. Observations and Findings The inspector interviewed licensee personnel and determined that no shipments of radioactive material were conducted under the Facility Operating License No.
R-88 since the last inspection in this area. The inspector noted that there were two individuals authorized to ship radioactive material at the university. These people both worked in the campus Radiation Safety Office. The inspector verified that, if the licensee needed to make any shipments of radioactive material, the individuals in the Radiation Safety Office would provide help.
c. Conclusion The inspector noted that although the licensee had not shipped any radioactive material, personnel and procedures were in place if the need to ship were to arise.
7. Follow-up on Previously Identified Items a. Inspection Scope (IP 92701)
The inspector reviewed the actions taken by the licensee to address a previously identified Inspector Follow-up Item (IFI).
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b. Observation and Findings 50-188/2019-201-02 - IFI - Follow-up on the need for the licensee to continue using the Environmental Protection Agencys (EPAs) COMPLY code or a later version known as CAP-88 for calculating off site releases to demonstrate compliance.
During the inspection in October 2019, the inspector inquired about the use of the EPAs COMPLY code for calculating off site releases to demonstrate compliance.
The campus RSO indicated that this was done in the past but that the results had always shown compliance at the lowest level. Therefore, neither the licensee nor the university was using the COMPLY code currently. The inspector indicated that the issue of continued use the EPAs COMPLY code or a later version known as CAP-88 would be identified as an IFI and would be reviewed during a future inspection.
During this inspection, the inspector again interviewed the RSO concerning the use of EPSs COMPLY code. The RSO indicated that KSU had calculated releases using the COMPLY code in the past and the amount released was minimal. Because the amount was so small, the RSO indicated that the university no longer reported the results to the EPA and that agency had not indicated that this was a problem. Since the NRC does not require the use of the code and only uses the COMPLY code results as a secondary demonstration of compliance with the dose constraint in 10 CFR 20.1101(d), the NRC does not consider the failure to report the results to the EPA a problem or violation. This issue is considered closed.
c. Conclusion The inspector determined that this issue is closed.
8. Exit Interview The inspection scope and results were summarized on June 3, 2021, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the observations presented and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.
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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel KSU Nuclear Reactor Facility Manager R. Seymour Reactor Supervisor and Senior Reactor Operator Other Personnel R. Bridges Campus Radiation Safety Officer, Environmental Health and Safety Department INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 50-188/2019-201-02 IFI Follow-up on the need for the licensee to continue using the EPAs COMPLY code or a later version known as CAP-88 for calculating off site releases to demonstrate compliance.
PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As low as reasonably achievable EPA Environmental Protection Agency IFI Inspector Follow-up Item IP Inspection Procedure KSU Kansas State University mrem Millirem NRC U.S. Nuclear Regulatory Commission RPP Radiation Protection Program RS Reactor Supervisor RSC Reactor Safeguards Committee RSO Radiation Safety Officer TLD Thermoluminescent dosimeter TRIGA Training, Research, Isotopes, General Atomics TSs Technical Specifications Attachment