IR 05000288/2016202

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Reed College - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 50-288/2016-202 and Notice of Violation
ML16349A652
Person / Time
Site: Reed College
Issue date: 12/21/2016
From: Mendiola A J
Research and Test Reactors Oversight Branch
To: Krahenbuhl M
Reed College
Bassett C H
References
IR 2016202
Preceding documents:
Download: ML16349A652 (31)


Text

December 21, 2016

Dr. Melinda Krahenbuhl, Director Reed Reactor Facility

Reed College 3203 S.E. Woodstock Boulevard

Portland, OR 97202-8199 SUBJECT: REED COLLEGE - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-288/2016-202 AND NOTICE OF VIOLATION

Dear Dr. Krahenbuhl:

From October 31 to November 3, and November 28 to December 2, 2016, the U.S. Nuclear Regulatory Commission (NRC or the Commission) completed an inspection at the TRIGA Mark-I Reed Research Reactor facility. The enclosed report documents the inspection results, which were discussed on November 2, 2016, with you, Dr. Nigel Nicholson, Dean of the Faculty, and Christina Barrett, Reactor Operations Manager, and on December 1, 2016, with you and Dr. Nicholson.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspector reviewed selected procedures and records, observed activities in progress, and interviewed various personnel.

Based on the results of this inspection, the NRC has determined that two Severity Level IV violations of NRC requirements occurred. The violations were evaluated in accordance with the NRC Enforcement Policy, which can be found on the NRC's Web site at www.nrc.gov by selecting "What We Do," "Enforcement," and then "Enforcement Policy." The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. The violations are being cited in the Notice because they constitute the failure to meet regulatory requirements that have more than minor safety significance and they were identified by the NRC.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

In addition, based on the results of this inspection, the NRC has determined that one other Severity Level IV violation of NRC requirements occurred. This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.b of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. 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 electronica lly for public inspection in the NRC Public Document Room or from the NRC's 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 301-466-4495 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

Docket No. 50-288 License No. R-112

Enclosures: 1. Notice of Violation

2. NRC Inspection Report

No. 50-288/2016-202

cc: See next page

Reed College Docket No. 50-288 cc:

Mayor of City of Portland

1220 Southwest 5 th Avenue Portland, OR 97204

Dr. Nigel Nicholson, Dean of Faculty Reed College 3203 S.E. Woodstock Boulevard

Portland, OR 97202-8199

Mr. John Kroger, President Reed College 3203 S.E. Woodstock Boulevard

Portland, OR 97202-8199

Division Administrator Nuclear Safety Division Oregon Department of Energy 625 Marion Street, N.E.

Salem, OR 97310-3737

Program Director Radiation Protection Services Public Health Division Oregon Health Authority 800 NE Oregon Street, Suite 640 Portland, OR 97232-2162

Test, Research, and Training

Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML16349A652; *concurrence via e-mail NRC-002 OFFICE NRR/DPR/PROB* NRR/DPR/PROB* NRR/DPR/PROB NAME CBassett NParker AMendiola DATE 12/16/16 12/16/16 12/21/16 Enclosure 1 NOTICE OF VIOLATION Reed College Docket No. 50-288 Reed Research Reactor License No. R-112

During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from October 31 to November 3, 2016 and from November 28 to December 2, 2016, two violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violations are listed below:

1. Reed Research Reactor Technical Specification (TS) Section 3.2.2 requires that the reactor shall not be operated unless the reactor power measuring channels in Table 2 are operable. Table 2 lists the Percent Power Channel, the Linear Channel, and the Logarithmic Channel.

Contrary to this requirement, from October 6 to October 16, 2016, the reactor was operated or attempted to be operated when the Logarithmic Channel was not operable.

This has been determined to be a Severity Level IV violation (Section 6.1).

2. Title 10 of the Code of Federal Regulations (10 CFR) 50.59, "Changes, tests, and experiments," paragraph (c)(1) states, in part, that a licensee may make changes in the facility as described in the final safety analysis report without obtaining a license amendment pursuant to 10 CFR 50.90 only if: (i) a change to the technical specifications incorporated in the license is not required, and (ii) the change does not meet any of the criteria in 10 CFR 50.59(c)(2).

The regulation in 10 CFR 50.59(c)(2) requires, in part, that a licensee shall obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change would: (i) result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report; (ii) result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the final safety analysis report; (iii) result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report; (iv) result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report; (v) create a possibility for an accident of a diffe rent type than any previously evaluated in the final safety analysis report; (vi) create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report; (vii) result in a design basis limit for a fission product barrier as described in the FSAR being exceeded or altered; or (viii) result in a departure from a method of evaluation described in the FSAR used in establishing the design bases or in

the safety analyses.

The regulation in 10 CFR 50.59(d)(1) requires, in part, that the licensee shall maintain records of changes in the facility made pursuant to 10 CFR 50.59(c). These records

- 2 - must include a written evaluation which provides the bases for the determination that the change does not require a license amendment pursuant to 10 CFR 50.59(c)(2). The Reed Research Reactor safety analysis report (SAR) states in Chapter 7, Section 7.2.3.3, that the Percent Power channel has an associated Uncompensated Ion Chamber that provides indication for that channel.

Contrary to the above requirements, on October 5, 2016, the licensee made a change to the facility as described in the SAR without conducting an evaluation to determine whether or not the change would require a change to the TSs or should have required a license amendment. Specifically, the licensee replaced the detection chamber associated with the Percent Power channel with a fission chamber which was not as described in the SAR without performing an evaluation of the change using the criteria in 10 CFR 50.59(c)(1) and (2) to determine if the change would require a change to the TSs or should have required a license amendment.

This has been determined to be a Severity Level IV violation (Section 6.1).

Pursuant to the provisions of 10 CFR 2.201, "Notice of violation," Reed College is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with a copy to the responsible inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for each violation, or, if contested, the basis for disputing the violation or severity level; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is

shown, consideration will be given to extending the response time. If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

Because your response will be made available el ectronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRC's Agencywide Documents Access and Management System (ADAMS), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal

privacy or provide the information required by 10 CFR 2.390, "Public inspections, exemptions,

- 3 - requests for withholding," paragraph (b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21,

"Protection of Safeguards Information: Performance Requirements."

In accordance with 10 CFR 19.11, "Posting of notices to workers," you may be required to post this Notice within two working days.

Dated this 21st day of December

Enclosure 2 U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION

Docket No. 50-288

License No. R-112

Report No. 50-288/2016-202

Licensee: Reed College

Facility: Reed Research Reactor

Location: Portland, Oregon

Dates: October 31, 2016 - November 3, 2016 November 28, 2016 - December 2, 2016

Inspector: Craig Bassett

Accompanied by: Michele DeSouza, Examiner John Nguyen, Examiner Michael Takacs, Security Specialist

Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation EXECUTIVE SUMMARY Reed College Reed Research Reactor Facility NRC Report No. 50-288/2016-202 The primary focus of this routine, announced inspection included onsite review of selected aspects of the Reed College (the licensee) Class II research reactor safety program. This included a review of: (1) organization and staffing, (2) review and audit and design change functions, (3) conduct of operations, (4) operator requalification program, (5) fuel handling, (6) maintenance and surveillance, (7) procedures, (8) experiments, and (9) emergency preparedness. The licensee's program was acceptably directed toward the protection of public health and safety. Two apparent Severity Level IV violations and one Severity Level IV non-cited violation were identified.

Organization and Staffing

The organization and staffing remain in compliance with the requirements specified in Technical Specification (TS) Section 6.1.

Review and Audit and Design Change Functions

Review and oversight functions required by TS Section 6.2 were acceptably completed by the Reactor Operations Committee. Audits were being completed as required.

The design change program being implemented at the facility generally satisfied Nuclear Regulatory Commission requirements.

Conduct of Operations

Operations were generally being conducted in accordance with TS and procedural requirements.

Two apparent violations and one non-cited violation were identified involving the nuclear measuring channels of the reactor.

Operator Requalification Program

The operator requalification/training program was up-to-date and being acceptably implemented and documented.

Biennial medical examinations were being completed as required.

A one-time Alternate Requalification Plan was initiated due to the problems created by malfunctioning nuclear instrumentation.

- 2 - Fuel Handling

Reactor fuel movements and inspections were conducted and documented in accordance with procedure.

Twenty-five percent of the fuel elements were being inspected on an annual basis.

Maintenance and Surveillance Maintenance was being completed as needed.

The surveillance program, including calibration of equipment, was being completed in accordance with TS Sections 3 and 4.

Procedures

Facility procedures were available for the safe operation of the reactor as required by TS Section 6.4.

Experiments

The program for the control of experiments satisfied TS Sections 3.6, 4.6, and 6.5 and other regulatory requirements.

Emergency Preparedness

The Emergency Plan (E-Plan) and Emergency Implementation Procedures were being audited and reviewed annually as required.

Letters of Agreement documenting emergency support to be provided by offsite agencies were being maintained and periodically updated.

Annual drills were being held and documentation of the drills and the follow-up critiques was maintained. Subsequent corrective actions were taken as needed.

Emergency preparedness training for staff and offsite personnel was being conducted as stipulated in the E-Plan.

REPORT DETAILS Summary of Facility Status

The Reed College (the licensee's) 250 kilowatt TRIGA Mark I research reactor was typically operated in support of undergraduate instruction, laboratory experiments, reactor system testing, reactor surveillances, and operator training. During this inspection the reactor was not operated due to nuclear instrumentation issues.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001)

To verify the organization and staffing requirements specified in technical specifications (TSs) Section 6.1 were being met, the inspector reviewed selected aspects of the following:

Main (Reactor Console) Log - Numbers (Nos.) 86 - 89 Reed Research Reactor (RRR) facility organization and staffing during reactor operations Administrative controls and management responsibilities specified in the TS and facility procedures RRR Administrative Procedures, Section 1, "Personnel," and Section 3, "Reactor Operations" RRR Standard Operating Procedure (SOP) 60, "Logbook Entries" RRR Annual Report for the period from July 1, 2014, through June 30, 2015, submitted to the U.S. Nuclear Regulatory Commission (NRC) on August 7, 2015 RRR Annual Report for the period from July 1, 2015, through June 30, 2016, submitted to the NRC on July 27, 2016 b. Observations and Findings Through discussions with licensee representatives, the inspector determined that management responsibilities and the organizational structure at the RRR facility had not changed since the previous NRC in spection of licensee operations in December 2014 (Inspection Report No. 50-288/2014-202). The inspector determined that the Facility Director retained direct control and overall responsibility for management of the facility as specified in the TS. The Facility Director reported to the President of Reed College through the Dean of Faculty. This organization was consistent with that specified in the TS.

It was noted that since the last operations inspection in 2014, a new person had been hired to be the Reactor Operations Manager. Also, a new person had been hired to fill the position of campus Radiation Safety Officer/Director of Environmental Health and Safety.

- 2 - The licensee's current operational organization consisted of the Facility Director, a Reactor Operations Manager, a Radiation Safety Officer, an Operations Supervisor, a Training Supervisor, an Assistant Training Supervisor, a Projects Supervisor, and a Requalification Supervisor. The Facility Director, Reactor Operations Manager, and Radiation Safety Officer positions were full-time while

the rest were part-time positions filled by students. Except for the Radiation Safety Officer, the aforementioned individuals, in addition to their administrative duties, were qualified reactor operators (ROs) or senior reactor operators (SROs). It was noted that there were a total of 20 SROs and 19 ROs licensed to operate the RRR.

c. Conclusion Organization and staffing met the requirements specified in TS Section 6.1.

2. Review, Audit, and Design Change Functions a. Inspection Scope (IP 69001)

In order to verify that the licensee had established and conducted reviews and audits as required, and to determine whether facility modifications and change reviews were consistent with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, "Changes, tests and experiments," and TS Section 6.2, the inspector reviewed selected portions of the following:

Maintenance Log pages completed for unscheduled work Corrective Action Reports (CARs) for 2015 and to date in 2016 Design changes reviewed under 10 CFR 50.59 for 2015 and 2016 Reactor Operations Committee (ROC) meeting minutes from October 2014 through the present RRR Administrative Procedures, Section 1, "Personnel;" Section 2, "Reactor Review Committee;" and Section 9, "Record Retention" RRR SOP 62, "Changes, Tests, and Experiments," and SOP 69, "Corrective Action Report;" and associated forms, "Corrective Action Reports;" last revised August 26, 2014 RRR Annual Reports for the last two reporting periods b. Observations and Findings (1) Review and Audit Functions

The inspector reviewed ROC meeting minutes from October 2014 through the present. These meeting minutes showed that the committee was meeting at the required frequency and was considering the types of topics outlined by the TS.

The inspector noted that, since the last NRC inspection, the appropriate audits had been completed by the ROC and an external auditor in the

- 3 - various areas outlined in the TS. The audits were designed so that most aspects of the licensee's operations and safety programs were reviewed every year. Various facility documents, such as the Radiation Protection Program, the Emergency Plan (E-Plan), the Fire Plan, the Administrative Procedures, and the Requalification Plan comprised the material that was typically reviewed. The Reactor Experiments and various SOPs were also reviewed. The inspector noted that the audits and the resulting findings were detailed and that the licensee responded and took corrective actions as needed.

(2) Design Changes The inspector reviewed the licensee's 10 CFR 50.59 screening forms concerning changes or modifications that had been initiated at the facility for 2015 and to date in 2016. The results indicated that none of the screenings required further evaluation under 10 CFR 50.59. The inspector also reviewed the Maintenance Log pages that had been completed for unscheduled work associated with various systems. The forms contained a section which required a 50.59 Screen to be completed prior to initiating the work. None of the maintenance items reviewed required any further actions, such as a 50.59 evaluation, to be completed except as noted in Part 3, Section (3) below. None of the other changes reviewed by the inspector met any of the criteria of 10 CFR 50.59(c)(1) and (2), which would have required a TS change or a license amendment from the NRC.

c. Conclusion Review and oversight functions required by TS Section 6.2 were acceptably completed by the ROC. Audits were being completed as required. The

licensee's design change program gener ally satisfied NRC requirements.

3. Conduct of Operations The inspector reviewed selected aspects of the following to verify operation of the reactor in accordance with TS Sections 3, 4, and 6.1:

a. Inspection Scope (IP 69001)

Main (Reactor Console) Log Nos. 86 - 89 Various SCRAM Response Forms for 2015 and 2016 CARs for 2015 and to date in 2016 Maintenance Log pages completed for unscheduled work Selected Startup Checklist Forms for the period from January 2015 through the present Selected Shutdown Checklist Forms for the period from January 2015 through the present RRR Administrative Procedures, Section 3, "Reactor Operations"

- 4 - Various RRR SOPs and Appendices including SOP 1, "Reactor Operations;" SOP 20, "Startup Checklist;" SOP 20, Appendix A, "Startup Checklist Form;" SOP 21, "Same Day Startup Checklist;" SOP 21, Appendix A, "Same-Day

Startup Checklist Form;" SOP 22, "Shutdown Checklist;" SOP 22, Appendix A, "Shutdown Checklist Form;" SOP 23, "Biweekly Checklist;" SOP 23, Appendix A, "Biweekly Checklist Form;" SOP 24, "Bimonthly Checklist;"

SOP 24, Appendix A, "Bimonthly Checklist Form;" SOP 25, "Semiannual Checklist;" SOP 25, Appendix A, "Reed Research Reactor Semiannual Checklist;" SOP 26, "Annual Checklist;" SOP 26, Appendix A, "Annual Checklist Form;" SOP 33, "Nuclear Instruments;" SOP 34, "Control Rods;"

SOP 60, "Logbook Entries;" and, SOP 69, "Corrective Action Report" RRR Annual Reports for the last two reporting periods b. Observations and Findings (1) Routine Operations

The inspector reviewed selected reactor operating records from January 2015 through the present. These records included daily Startup Checklists, Shutdown Checklists, Experimental Startup and Shutdown Checklists, associated forms, Weekly Checklists, and the Main (reactor console) Logs. The records indicated that the activities were generally carried out in accordance with written procedures as required by TS Section 6.4, except as noted below. The checklists were completed and signed off by the appropriate personnel as required.

Through interviews with operators and review of logs and records, the inspector confirmed that shift staffing met the minimum requirements for duty and on-call personnel as required by TS Section 6.1.

Information on the operational status of the facility was generally recorded properly on the log sheets and/or checklists as required by procedure.

Scrams were identified in the logs and were reported and resolved as required before reactor operations were allowed to continue. However, it was noted that the logs were not totally complete in that they did not indicate who authorized operations to resume. The inspector indicated that the complete documentation of reactor operations should include not

only when and why a scram occurred, but who gave the authorization to resume operations as well. The licensee was informed that the issue of complete and accurate documentation of scram events and other operational events would be designated by the NRC as an Inspector Follow-up Item (IFI) and would be reviewed during future inspections (IFI 50-288/2016-202-01).

- 5 - (2) NRC-Identified Violation of TS Section 3.2.2 TS Section 3.2.2 requires that the reactor shall not be operated unless the reactor power measuring channels in Table 2 are operable. Table 2 lists the Percent Power Channel, the Linear Channel, and the Logarithmic

Channel.

On May 28, 2016, the licensee discovered that the facility reactor pool had overflowed due to a malfunction of the recently installed automatic fill system. On May 30, 2016, operators noticed that all reactor trips were illuminated. Because of this, the reactor was determined to be inoperable due to electronics problems. In mid-June, some of the electronic components of the power measuring channels, including the Logarithmic Channel pre-amp and the Percent Power Channel High Voltage (HV)

power supply, were removed and taken to Oregon State University (OSU)

by the electronics specialist from OSU where he worked to correct the problems. It was noted that the Linear Channel was not found to have been damaged.

During August 8 and 9, the OSU electronics specialist came to Reed College and installed the repaired pre-amp and HV power supply for the Log and Percent Power channels. After the electronics were installed, the licensee determined that the detector chambers associated with the Percent Power and Logarithmic Channels were not functioning properly. Licensee personnel then removed the assemblies for each channel from the reactor pool and began the process of trying to dry out the detectors.

On October 5, after the channel detectors were thought to be completely dry, the electronics specialist from OSU again came to Reed College to help test and reinstall the power channels. At that point the Log channel was determined to be functional but the Percent Power Channel shorted out and was not functional. Upon further investigation, the licensee found that the detector associated with the Percent Power Channel was not an UIC as stipulated in the SAR but a fission chamber operating in current mode. Because that fission chamber was not functioning, licensee staff and the OSU electronics specialist installed a spare fission chamber (one

that Reed had on hand) with the Percent Power Channel to see if it would operate. The channel appeared to be functioning properly and appeared to be giving the expected signals.

The following day, October 6, licensee staff attempted to adjust the detectors and conduct a core excess and power calibration of the reactor.

Although the power channels appeared to be working properly, the Percent Power Channel had repeated HV scrams. Licensee staff found a loose wire and corrected that problem. During the next few days licensee staff adjusted the Linear Power and Percent Power detector positions to adjust for power calibration. However, another HV Percent Power scram occurred, the cause of which could not be explained.

- 6 - On October 13, channel testing continued and core excess measurements were again attempted but to no avail and the Percent Power Channel was determined to be non-functional. On October 14, the OSU electronics specialist returned to Reed and installed a spare UIC (one that OSU had received from another university) to operate in the Percent Power Channel. On October 16, the licensee completed core excess and reactor power calibrations. They operated up to 150 kilowatt (kW) for training and operator requalification. Two days later operations were conducted for requalification but the Log channel was determined to be erratic, possibly due to electronic noise. Because the reactor had been operated for over an hour with a non-functional Logarithmic Channel, the reactor was scrammed. At that point, the Reactor Operations Manager declared the problem as an event and a report was made to the NRC (see Section (4) below). When the licensee investigated the problem, it was believed that the problem was due to an electronics "noise problem." After disconnecting, testing, and reconnecting the channel, they thought the problem (the noise issue) with the Logarithmic Channel was corrected. The following day, October 19, the Logarithmic Channel was tested and determined to be functional.

Core excess measurements were completed and the reactor was operated for requalification of operators. An inadvertent scram occurred but this was caused by operator error and operations were allowed to continue.

Because most of the student operators were out of qualification (due to the continuing problems with the nuclear instruments NI channels), reactor operations continued and were conducted on various occasions for requalification but problems persisted. Core excess measurements were completed each day and other activities were attempted such as measuring Regulating Rod worth. The licensee also completed Shim and Safety rod worth measurements but problems kept occurring with the Logarithmic Channel. On October 21, the licensee determined that the Logarithmic Channel detector was apparently working properly but the electronics were not. At that point the reactor was declared non-operational. The reactor has not been operated since that date.

The NRC reviewed the issues associated with the reactor power measuring channels. From October 6-16, licensee staff operated the reactor up to 150 kW for training and requalification. (It was noted that after October 16, the reactor was only operated at a power level of 5 watts (W) or less.) During that period when operating at 150 kW, the Linear Channel typically read 60 percent, the Percent Power Channel typically read 60 percent, but the Logarithmic Channel was reading from 90 to 100 percent. The inspector reviewed the console logs for the past two years. For that time frame, when operating at 150 kW, the Linear Channel typically read 60 percent, the Percent Power Channel typically read 60 percent, and the Logarithmic Channel typically read 60 percent.

- 7 - Therefore, from October 6 through 16, the Logarithmic Channel was not reading correctly because it was reading high and over responding, probably indicating that the channel detector was shorted out. The NRC concluded that the Logarithmic Channel was not operating properly and thus was not operational during this period. The licensee was informed that failure to have an operable Logarithmic Channel during reactor operation was an apparent violation of TS Section 3.2.2 (violation (VIO)

50-288/2016-202-02).

(3) NRC-Identified Violation of Regulatory Requirements The RRR safety analysis report (SAR) states in Chapter 7, Section 7.2.3.3, that the Percent Power Channel has an Uncompensated Ion Chamber that provides indication for that channel.

Regulation in 10 CFR 50.59 requires that licensees evaluate a change from what was described in the SAR to ensure that a TS change or a license amendment was not required in accordance with 10 CFR 50.59 pargraphs (c)(1)(i and ii) and (c)(2)(i-viii).

As noted above, the licensee had been experiencing various problems with the reactor power measuring channels. Because of these problems, the licensee tried repeatedly to make adjustments to the channel electronics and the positions of the associated detectors. On October 6, 2016, licensee staff attempted to adjust the detectors and conduct a core excess and power calibration of the reactor. Although the power channels appeared to be working properly, the Percent Power Channel had repeated HV scrams. Licensee staff found a loose wire and corrected that problem but other problems persisted. Finally on October 14, the OSU electronics specialist returned to Reed and installed a spare UIC (one that OSU had received from another university) into the Percent Power Channel. Licensee staff conducted a core excess measurement and performed testing of the electronics using the reactor at various power levels.

The NRC reviewed this situation and the problems with the Percent Power Channel. As stated above, it was noted that the licensee was not aware that the detector associated with the Percent Power Channel was a fission chamber (and not a UIC as stated in the SAR) prior to October 5, 2016. However, following that date, the licensee was fully aware of the situation. Nevertheless, the decision was made to replace the existing fission chamber with a spare fission chamber that the licensee had on hand.

- 8 - A fission chamber was not what the SAR stipulated as the detector to be operated with the Percent Power Channel. No attempt was made to conduct a 10 CFR 50.59 review as to whether or not such a detector should be used with the Percent Power Channel. The licensee was informed that failure to conduct a review in this situation was an apparent violation of 10 CFR 50.59 requirements (VIO 50-288/2016-202-03).

(4) Self-Reported Violation of the Requirements of TS Section 3.2.2

Section 3.2.2 of the RRR technical specifications requires that the reactor shall not be operated unless the reactor power measuring channels in Table 2 are operable. Table 2 lists the Percent Power Channel, the Linear Channel, and the Log Channel.

On October 18, 2016, a licensed reactor operator and another person operating under the operator's direction completed the Start Up Checklist had checked out properly and appeared to be functioning normally. They then inserted the key and began a check out of the reactor NIs prior to full power operation. They conducted the excess reactivity surveillance test at a power level below 5 W.

About an hour after the key was inserted into the console, the Reactor Operations Manager entered the Control Room and noted that one of the NIs, the Log channel was not tracking correctly, i.e., the Log channel was reading a constant number and not tracking with the power level. The reactor was immediately scrammed and secured.

The three individuals then began to investigate the problem and diagnose what had happened. Analysis showed that the Log channel pre-amp was picking up excessive noise due to its close proximity to other electrical components. Also, upon further investigation, a ground wire was found detached from its proper connection.

The loose ground wire was replaced and a test of the pre-amp was initiated. Testing of the pre-amp on a platform away from interference from other electronics indicated that it was then functioning properly.

Under these corrected conditions, the Log channel was tested and the reading appeared to return to normal. However, reactor operations were suspended until the channel could be more thoroughly tested. A CAR was initiated to document the issue. The NRC was notified of the event on October 19, 2016.

The NRC reviewed this issue and discussed the self-identified TS violation with the licensee and interviewed various reactor staff personnel.

The NRC confirmed that the licensee had, in fact, been in violation of TS Section 3.2.2. The circumstances of the event and the notifications were reviewed.

- 9 - The inspector verified that the licensee had taken what they thought were appropriate corrective actions once the issue was identified. Corrective actions included immediately shutting down the reactor, investigating the problem and making the repairs that they thought would repair the channel. Following repairs and discussion of the issue with the Reactor Director, the reactor was placed back in operation.

The licensee was informed that the failure to have all of required channels operable during reactor operation was a Severity Level IV violation of TS Section 3.2.2. However, the safety consequences were low because the reactor was operated at a power level less than 5 W and 2 of the 3 required channels were operable to provide any required reactor scram. The inspector determined that this particular problem had been identified by the licensee and promptly reported to the NRC. What the licensee thought were adequate corrective actions had been identified and implemented. As a result, the licensee was informed that this issue would be treated as a NCV, consistent with Section VI.A.8 of the NRC Enforcement Policy (NCV 50-288/2016-202-04).

This issue is considered closed.

(5) Reactor Pool Overfill Problem

As noted above, near the end of May, the licensee found that the reactor pool had overflowed. Upon investigation the licensee found that the problem had occurred due to a malfunction of the recently installed

automatic fill system. In the past, as part of a weekly checklist, staff members were tasked with checking the pool level and adding water if the pool level dropped below a certain mark. However, on occasion, the staff members forgot to shut the fill water off and the tank was nearly over filled. To correct that problem, under the auspices of the 10 CFR 50.59 program, the licensee installed an automatic fill control system.

Unfortunately, the automatic system failed on May 28, 2016, and the pool overfilled to the point that water entered the nuclear instrumentation tubes leading to the detectors. The Percent Power channel and the Log Channel were affected; the Linear Channel was not damaged.

The overfill caused problems that persisted with the two affected channels from June through October (as noted above). The licensee was informed that the issue of correcting the overfill problem would be designated by the NRC as an IFI and would be reviewed during future inspections (IFI 50-288/2016-202-05).

- 10 - c. Conclusion Reactor staffing, operations, and logs were generally acceptable. One apparent violation was identified for operating the reactor without the logarithmic channel being operable as required by TS Section 3.2.2. One apparent violation was identified for failure to conduct a 10 CFR 50.59 review. One non-cited violation was identified for operating the reactor without the logarithmic channel being operable as required by TS Section 3.2.2.

4. Operator Requalification Program a. Inspection Scope (IP 69001)

The inspector reviewed selected portions of the following regarding the RRR Requalification Plan to ensure that the requirements of the plan and 10 CFR 55.59, "Requalification," were being met:

Main (Reactor Console) Log Nos. 86 - 89 Active license status of all current operators Medical examination records for selected operators RRR Facility Requalification Program, dated July 2009 RRR Facility Alternate Requalification Plan, dated September 2016 Training lectures and records for the current training cycle NRC Form 398, "Personal Qualification Statement - Licensee" Written examinations given during 2014 and 2015 for selected operators RRR Facility Requalification Plan, dated July 2009 NRC Form 396, "Certification of Medica l Examination - by Facility Licensee" RRR Facility Requalification Meeting Agenda and Attendance Sheets for September 2014 through the present "Requalification Hours and Reactivi ty Manipulation" Sheets documenting reactivity manipulations for 2014 through the present for selected operators RRR Administrative Procedures, Section 9, "Record Retention" Various RRR SOPS including: SOP 63, "Requalification;" SOP 63 Appendix A, "Reactor Operator Physical Exam;" and SOP 63, Appendix B, "Accelerated Requalification Form" b. Observations and Findings (1) Routine Requalification Program - For the Period 2014 through June 2015 and for July 2015 through June 2016 As noted previously, there are currently 20 qualified SROs and 19 qualified ROs at the RRR facility. The inspector reviewed selected operators' licenses and noted that they were current.

- 11 - The inspector reviewed the requalification program for July 2014 through June 2015, and for July 2015 through June 2016, as well as the annual drill scenarios and attendance sheets. It was noted that operators typically made entries on the "Requalification Hours and Reactivity Manipulation Sheet" that was located in the control room. Through these actions the hours "on duty" and in what capacity (i.e., RO/SRO), as well

as the tasks performed, were documented. The inspector also reviewed the Requalification Meeting Agenda and Attendance Sheets for the period from September 2014 through the present. The inspector reviewed various individual operators' requalification records as well.

The review of the various logs and records noted above showed that training had been conducted in accordance with the licensee's requalification and training program until May 2016. Training reviews and examinations had been completed and documented as required. The records indicated that operators were completing the required activities, including reactivity manipulations and number of operating hours. Records indicated that annual operations tests and supervisory observations were being completed. Biennial written examinations were also being completed as required or credit was taken by the licensee for the exams administered by the NRC to satisfy the requalification cycle exam requirements when applicable.

Additionally, the inspector noted that operators were receiving the required biennial medical examinations within the required time frame. (2) Alternate Requalification Plan - For the period from July 2016 until the Reactor is Operational

As noted in Section 3 of this report, the RRR has been functional and operational only sporadically since May 2016. Because of this problem, operators have not been able to complete the operational requirements to remain fully qualified. The licensee recognized this and proposed an alternate requalification plan to the NRC in September. The alternate plan was reviewed and subsequently approved.

The Alternate Requalification Plan stipulated that two Reed College SROs would go to the OSU research reactor facility and complete two hours of reactor operation under direction of OSU personnel and two hours of supervision of the other Reed College operator. These two individuals would also complete one reactivity manipulation each while at OSU as well. This would suffice for the reactor operation requirements of the Reed Requalification Program and allow the two operators to return to Reed College and observe Reed operators to operate under their direction.

For the remainder of the operators at Reed who did not go to OSU and were out of qualification, the alternate plan required that each operator complete three hours of reactor operation and two reactivity manipulations under direction of one of the SROs who went to OSU.

- 12 - In addition, these operators would then need to meet the routine Reed Requalification Program requirements of four hours of reactor operation and two reactivity manipulations for the quarter. If any licensed individuals were not in compliance with other requirements outlined in 10 CFR 55.59, the operators would be required to meet the requirements of 10 CFR 55.53, "Conditions of licenses," paragraph (f)(2) of six additional hours of operation under direction.

The inspector reviewed the actions of the licensee to comply with the requirements of the Alternative Requalification Plan. The inspector verified that the two SROs who went to OSU had completed the required hours of operation and the required reactivity manipulations. They then returned to Reed and began observing other operators. It was noted that 4 SROs and 2 ROs had completed the requirements of the alternate requalification plan. However, it was also noted that only two SROs would be in compliance with the Routine Requalification Program if the Reed reactor remains shut down through the end of December (the end of the quarter). The licensee acknowledged that, if the reactor remains shut down through the end of the quarter, all operators who are not in compliance with the requalification program requirements will have to complete the Alternate Requalification Plan requirements as well as the regular Reed Requalification Program requirements before being considered qualified to operate the reactor.

(3) Access to the Reed Research Reactor Facility (RRRF) Controlled Access Area As noted above, the inspector reviewed the Reed Routine Requalification Program. During records review it was found the Reed Operations Manager was approving individuals' access to the facility Controlled Access Area (CAA), i.e., signing the access forms. Only the NRC approved reviewing official may grant unescorted access to the facility in accordance with 10 CFR 73.57, "Requirements for criminal history records checks of individuals granted unescorted access to a nuclear power facility, a non-power reactor, or access to Safeguards Information," paragraph (g). The NRC approved reviewing official is the RRRF Director as indicated in a letter from the NRC to the licensee. The licensee was informed that only the NRC approved reviewing official is authorized to approve individuals access. Any changes or request for changes must be submitted to the NRC for evaluation.

Because the decision to grant unescorted access to the CAA of the facility was always discussed between, and approved by, both the

Director and the Reactor Operations Manager, the Director subsequently countersigned all the access forms. The licensee agreed that only an approved Reviewing Official would sign the access forms in the future.

- 13 - c. Conclusion The requalification/training program was up-to-date and being acceptably maintained. Medical examinations were being completed biennially as required.

5. Fuel Handling a. Inspection Scope (IP 69001)

In order to verify adherence to fuel handling and inspection requirements specified in TS Section 4.1, the inspector reviewed selected aspects of the

following:

Fuel Element Inspection Cards Main (Reactor Console) Log Nos. 86 - 89 Fuel Element Inspection sheet maintained in the appropriate Fuel Inspection Binder RRR Administrative Procedures Section 6, "Fuel and Special Nuclear Material" Various RRR SOPs including: RRR SOP 35, "Fuel and Core;" SOP 35, Appendix A, "Core Diagram;" SOP 35, Appendix B, "Fuel Handling Checklist;" SOP 35, Appendix C, "Fuel Handling SRO Qualification;" and SOP 35, Appendix D, "Fuel Handling Receipt Form" b. Observations and Findings Through review of the main logs and interviews with licensee personnel, the inspector verified that fuel movements were conducted in compliance with procedure. The inspector also verified that the licensee was maintaining the required records of fuel movements as they were completed. The logs were being filled out properly to indicate which elements were moved and to what

locations.

Also through records review, it was noted that the reactor fuel was being inspected upon initial receipt and 25 percent of the fuel elements in the core were being inspected annually. This exceeded the percentage of fuel elements required to be inspected as stipulated by TS Section 4.1. The last annual fuel inspection was completed during January 11-27, 2016. The inspector verified that all fuel elements were inspected at least once every 5 years, including elements in storage and/or removed from service as required.

c. Conclusion Reactor fuel movements and inspections were completed and documented in accordance with procedure and the fuel was being inspected more frequently than required by TS Section 4.1.

- 14 - 6. Maintenance and Surveillance a. Inspection Scope (IP 69001)

To verify that operations, surveillance activities, and calibrations were being completed as required by the TS, the inspector reviewed selected portions of:

Main (Reactor Console) Log Nos. 86 - 89 Maintenance Log pages completed for unscheduled work Associated surveillance and calibration data and records for 2015-2016 "Other Checklists" Notebook which contained calibration forms, inspection forms, and various checklists Various RRR SOPs and Appendices including: SOP 23, "Biweekly Checklist;" SOP 23, Appendix A, "Biweekly Checklist Form;" SOP 24, "Bimonthly Checklist;" SOP 24, Appendix A, "Bimonthly Checklist Form;" SOP 25,

"Semiannual Checklist;" SOP 25, Appendix A, "Reed Research Reactor Semiannual Checklist;" SOP 26, "Annual Checklist;" SOP 26, Appendix A, "Annual Checklist Form;" SOP 34, "Control Rods;" SOP 34, Appendix A, "Control Rod Calibration Form;" SOP 34, Appendix B, "Control Rod Inspection Checklist;" SOP 34, Appendix C, "Control Rod Inspection Form;"

and, SOP 60, "Logbook Entries;" and associated Appendix A, "Maintenance

Log" forms RRR Annual Reports for the last two reporting periods b. Observations and Findings The licensee conducted various maintenance and surveillance activities which were then documented on the appropriate forms and checklists. The inspector verified that these activities were conducted within the time frame required and according to procedure. The inspector reviewed selected biweekly, bimonthly, semiannual, and annual forms and checklists. All the recorded results reviewed were within the TS and procedurally prescribed parameters. The records and logs reviewed appeared to be complete and were being maintained as required.

The inspector was not able to observe a Startup or Shutdown Checklist being performed during the inspection. However, previously completed Startup and Shutdown Checklists were reviewed. These activities appeared to have been conducted appropriately and in accordance with procedure.

A review of the RRRF Main Logs and current Maintenance Logbook showed that these records were also being completed as required and problems, if any, were being documented. Through observation and records review, the inspector also confirmed that maintenance was being conducted as needed, consistent with the

TS.

- 15 - c. Conclusion Maintenance was being completed as required. The program for surveillance was being carried out in accordance with TS requirements.

7. Procedures a. Inspection Scope (IP 69001)

To determine whether facility procedures met the requirements outlined in TS Section 6.4, the inspector reviewed portions of the following:

Procedural reviews and updates documented in the ROC meeting minutes RRR Administrative Procedures, Section 8, "Adoption and Revision of Operating Procedures," and Section 9, "Record Retention" Various RRR SOPs and Appendices including: SOP 60, "Logbook Entries;"SOP 61, "Procedure Writing and Use;" SOP 61, Appendix A, "Document Structure;" SOP 61, Appendix B, "Document Locations;" and SOP 61, Appendix C, "Temporary Procedure Change" b. Observations and Findings Procedures were in effect for those activities specified in TS Section 6.4 as required. RRR Administrative Procedures and SOPs were found to be acceptable for the current staffing level and status of the facility. The Administrative Procedures and SOPs specified the responsibilities of the various members of the staff. Substantive changes to procedures were being reviewed and approved by the ROC. The procedures were being audited, reviewed, and updated as needed.

The inspector reviewed the temporary procedure changes that had been promulgated during the past 12 months. The changes were written after minor problems with the procedures were noted. The temporary changes were typically incorporated in the referenced procedures if deemed appropriate by the licensee. Changes suggested as a result of the ROC and independent audits were also incorporated into the procedures if deemed appropriate.

c. Conclusion Facility procedures for the safe operation of the reactor were available as required by TS Section 6.4.

- 16 - 8. Experiments a. Inspection Scope (IP 69001)

In order to verify that experiments were being conducted within approved guidelines specified in TS Sections 3.6, 4.6, and 6.5, the inspector reviewed selected portions of the following:

Experiment review and approval by the ROC Selected Irradiation Request Forms for 2015 and 2016 Approved RRR Routine Experiments (REs), including: RE 1, "Irradiation with Neutrons;" RE 2, "Irradiation with Gammas;" RE 3, "Fuel, Graphite, or Source Material;" RE 4, "Reactor Power Measurement;" RE 5, "Control Rod Worth Measurement"; RE 6, "Pool Parameter Measurement;" RE 7, "Fuel Loading;"

RE 8, "Cerenkov Radiation Spectrum Acquisition;" RE 9, "Neutron Induced Auto-Radiography;" and RE 10, "Radial Flux Measurements" Approved RRR Special Experiment (SE), SE 4, "Core Temperature Measurements" RRR Administrative Procedures, Section 4, "Reactor Experiments;" and Section 9, "Record Retention" Various RRR SOPs and Appendices including: SOP 10, "Irradiation Preparation;" SOP 10, Appendix A, "Irradiation Request Form;" SOP 10, Appendix D, "Irradiation Request Log;" SOP 11, "Irradiation Analysis;" SOP 12, "Lazy Susan;" SOP 13, "Rabbit;" SOP 14, "Central Thimble;" SOP 15, "Beam;" SOP 15, Appendix A, "Beam Irradiation Request Form;"SOP 16, "Near Core;" and SOP 17, "Gamma Irradiations" b. Observations and Findings The inspector noted that the various experiments conducted at the facility, and revisions thereto, were being reviewed and approved as required. It was also noted that the two most recently proposed REs had been submitted by licensee staff and students and had been reviewed and approved by the Facility Director

and the ROC as required.

Through a review of console logs and various irradiation request forms, the inspector noted that irradiations were conducted under the cognizance of the Facility Director and the Reactor Supervisor as required. The irradiations were documented in the Main Log and the results of the experiments were documented on the Irradiation Request Forms as required. The resulting radioactive material was being transferred to an authorized user, disposed of as stipulated by procedure, or held for decay.

- 17 - c. Conclusion The license's program for the control of experiments generally satisfied TS Sections 3.6, 4.6, and 6.5 and other regulatory requirements.

9. Emergency Preparedness a. Inspection Scope (IP 69001)

To verify compliance with the RRRF, E-Plan, the inspector reviewed selected aspects of the following:

ERR E-Plan last revised August 2014 Emergency response training records for the past 2 years Emergency drills and exercises held during 2015 and 2016 Emergency response facilities, supplies, equipment and instrumentation ERR SOP 25, "Semiannual Checklist" ERR SOP 25, Appendix A, "Reed Research Reactor Semiannual Checklist" ERR E-Plan, Appendix a, "Emergency Implementation Procedures (EIPs)" ERR E-Plan, Appendix B, "Projected Doses for Bounding Accidents" ERR E-Plan, Appendix C, "Visible and Audible Alarms" b. Observations and Findings The E-Plan in use at the reactor had been updated, reviewed, and approved by the ROC. The licensee had determined that there was no decrease in effectiveness as defined in 10 CFR 50.54, "Conditions of licenses,"

paragraph (q). The licensee had submitted a letter to the NRC documenting this determination on August 18, 2014.

The E-Plan and EIPs were being audited and reviewed annually as required.

Supplies, instrumentation, and equipment staged for emergency use were being maintained, controlled, and inventoried semiannually as required in the E-Plan. It was noted that the Emergency Support Center was located in the RRRF Director's office in the Chemistry Building.

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. The inspector reviewed the Agreement Letters that had been signed with various emergency support organizations. These agreements were being maintained and updated as needed.

Communications capabilities were acceptable and had been tested and emergency information updated as stipulated in the E-Plan. It was noted that the Emergency Notification Call List, posted in various locations throughout the facility, was current and the most recent version was dated October 5, 2016. The inspector verified that training for staff and offsite support personnel was being provided annually as required.

- 18 - Training for staff was typically completed through the Operator Requalification Program. Training for representatives from the Portland Fire and Rescue Department (PF&RD) was conducted annually. Training for representatives from the Portland Police Bureau was offered but the police could not always commit to attend because of staffing level shortages.

Emergency drills had been conducted annually 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 exercises and to develop possible solutions to any problems identified. The results of these critiques were documented and reported to the Radiation Safety Committee/ROC. Drills involving off-site personnel were being conducted annually and documented as stipulated by the E-Plan.

The inspector and the Facility Director visited a PF&RD unit located several miles from the RRRF. The inspector and Director were given a tour of the facility and observed the equipment maintained by the unit for response to various types of emergencies. As a result of this visit, and following a review of the licensee's records documenting drills and training, the inspector verified that fire department personnel were well trained, properly equipped, and knowledgeable of the actions to take in case of an emergency at the reactor facility. The inspector determined that the licensee communicated with the PF&RD frequently and was maintaining a good working relationship with this support group.

c. Conclusion

The emergency preparedness program was conducted in accordance with the

E-Plan. 10. 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 IFI.

b. Observation and Findings 50-288/2014-202-01 - IFI - Follow-up on the licensee's actions to correct the inconsistencies between the E-Plan and the Implementing Procedures dealing with the "Alert" classification of various events. During an inspection in December 2014, the inspector reviewed of the E-Plan. It was noted that there were no accidents that could cause an "Alert" classification for the facility. However, certain security events would require an "Alert" Nevertheless, it was noted that there were various EIPs which indicated that, in certain accident situations, the classification for the event would be "Alert."

- 19 - The licensee acknowledged these inconsistencies and agreed to correct the problem. The licensee was informed that correcting these issues would be followed by the NRC as an IFI.

During this inspection, the inspector reviewed the actions taken by the licensee to resolve the inconsistencies between the E-Plan and the EIPs. It was noted that the procedures had been revised to indicate that accidents or events occurring in conjunction with security events require the "Alert" designation. Otherwise these events are classified as "Unusual Events." This issue is considered closed.

c. Conclusions One IFI was reviewed and this issue is considered closed.

11. Exit Interview The initial scope of the inspection were summarized on November 2, 2016, with the Facility Director, the Reactor Manager, and the Dean of Faculty. On November 3, 2016, the preliminary results were discussed with the Facility Director and the Reactor Manager. On December 1, 2016, the results of the inspection were discussed with the Facility Director and the Dean of Faculty. On December 2, 2016, the results of the inspection were reiterated with the Facility Director. The inspector discussed the findings for each area reviewed. The licensee acknowledged the findings and did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

PARTIAL LIST OF PERSONS CONTACTED Licensee C. Barrett Reactor Operations Manager S. Brodesser Training Supervisor T. Freeman Requalification Supervisor A. Karr Radiation Safety Officer and Campus Environmental Director J. Koh Operations Supervisor Director, Reed Reactor Facility M. McCarthy Projects Supervisor N. Nicholson Dean of the Faculty, Reed College M. Oxley Training Supervisor Other Personnel S. Christensen First Lieutenant, Portland Fire and Rescue, Training, Safety, and EMS Division, City of Portland B. Profit Training Lieutenant, Portland Fire and Rescue, Training, Safety, and EMS Division, City of Portland INSPECTION PROCEDURE USED IP 69001 Class II Non-Power Reactors

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 50-288/2016-202-01 IFI Follow-up on the licensee's actions to maintain logs which contain the accurate and complete documentation of scram events and other operational events.

50-288/2016-202-02 VIO Failure to have all of required channels operable during reactor operation as required by TS Section 3.2.2.

50-288/2016-202-03 VIO Failure to complete a review prior to installing a fission chamber instead of an uncompensated ion chamber with the Percent Power Channel (as stipulated in the facility SAR) as required by 10 CFR 50.59 (c)(1)(i and ii) and (c)(2)(i-viii).

50-288/2016-202-04 NCV Failure to have all of required channels operable during reactor operation as required by TS Section 3.2.2.

50-288/2016-202-01 IFI Follow-up on the licensee's actions to correct the reactor pool overfill problem caused by the automatic fill system installed by the licensee.

- 2 - Closed 50-288/2014-202-01 IFI Follow-up on the licensee's actions to correct the inconsistencies between the E-Plan and the Implementing Procedures dealing with the "Alert" classification of various

events. 50-288/2016-202-04 NCV Failure to have all of required channels operable during reactor operation was a Severity Level IV violation of

TS Section 3.2.2.

LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations CAA Controlled Access Area CAR Corrective Action Report E-Plan Emergency Plan EIP Emergency Implementation Procedures HV High Voltage IFI Inspector Follow-up Item IP Inspection Procedure kW Kilowatt NCV Non-Cited Violation No. Number NRC Nuclear Regulatory Commission OSU Oregon State University PF&RD Portland Fire and Rescue Department RE Routine Experiment RO Reactor Operator ROC Reactor Operations Committee RRR Reed Research Reactor RRRF Reed Research Reactor Facility SAR Safety Analysis Report SE Special Experiment SOP Standard Operating Procedure SRO Senior Reactor Operator SSC Structure, System, or Component TS Technical Specifications UIC Uncompensated Ion Chamber VIO Violation W Watt