ML16349A652

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:	Anthony Mendiola Research and Test Reactors Oversight Branch
To:	Krahenbuhl M Reed College
Bassett C
References
IR 2016202
Download: ML16349A652 (31)

See also: IR 05000288/2016202

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.

M. Krahenbuhl - 2 -

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

M. Krahenbuhl 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