T.S 6

Question 1

6 ADMINISTRATIVE CONTROL

6.1 Responsibility and Organization

Answer 1

1) The Washington State University research reactor shall be operated by the Nuclear Science Center of Washington State University. The organization of the research reactor facility management and operation shall be as shown in Figure 6.1. The responsibilities and authority of the Level 2, Level 3, and Level 4 operating staff shall be defined in writing in these Technical Specifications.
(2) The following organizational levels and responsibilities shall exist:
(a) Vice President for Research (Level 1): The Vice President for Research is the head of the WSU Office of Research.
(b) Director of the Nuclear Science Center (Level 2): The Director of the Nuclear Science Center shall report to the Vice President for Research. The Director is responsible for ensuring that regulatory requirements and implementation are in accordance with requirements of the U.S. Nuclear Regulatory Commission, the Code of Federal Regulations, the State of Washington, and Washington State University regulations and the requirements of the WSU Reactor Safeguards Committee.
(c) Reactor Supervisor (Level 3):
(i) The Reactor Supervisor shall report to the Director of the Nuclear Science Center and is responsible for guidance, oversight, and technical support of reactor operations.
(ii) The Reactor Supervisor shall report to the Director of the Nuclear Science Center and to the Reactor Safeguards Committee in matters of radiation protection.
(d) Reactor Operating Staff (Level 4): The reactor operating staff shall report to the Reactor Supervisor. Reactor operating staff shall include one or more licensed Senior Reactor Operator, Reactor Operator or Reactor Operator trainee.
(e) Radiation Protection
(i) Radiation protection activities shall be carried out by Level 3 or Level 4, with supervisory function performed by the Level 3, Reactor Supervisor.
(ii) The Reactor Safeguards Committee shall perform the review and audit function over the radiation protection activities within the facility.
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(iii) The University Radiation Safety Officer, as an ex-officio member of the Reactor Safeguards Committee, shall provide communication regarding radiation safety to the Director of the Nuclear Science Center.
(iv) The University Radiation Safety Officer shall have oversight, through the Reactor Safeguards Committee, of activities utilizing radioactive material.
(3) Responsibilities of one level may be assumed by higher levels or by alternates designated by a higher level, conditional upon meeting all requirements for the position.

Question 2

6. 2 Staffing

6. 2.1 Minimum Staffing Levels

Answer 2

1) When the reactor is not secured, the minimum staffing level shall consist of:
(a) a licensed Reactor Operator or Senior Reactor Operator in the control room;
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Audit Function
Level 4
Reactor Operating Staff (Health Physics and Reactor Operations)
(b) a second designated person present at the facility complex able to carry out written instructions;
(c) a designated Senior Reactor Operator who shall be readily available in the Dodgen Research Facility or on call.
(2) A Senior Reactor Operator who is “on call” shall be defined as an individual who:
(a) has been specifically designated and this designation is known to the Reactor Operator on duty;
(b) keeps the Reactor Operator on duty informed of where he/she can be rapidly contacted and the contact telephone number;
(c) is capable of getting to the reactor facility in less than 30 minutes and shall remain within a 15 mile radius of the facility;
(3) It is not necessary to have a Senior Reactor Operator on call if the Reactor Operator in the control room is a Senior Reactor Operator. If the Reactor Operator in the control room is a Senior Reactor Operator a second person shall be present in the facility as described in Section 6.2(1)(b).

Question 3

6.2.2 Contact Information

Answer 3

(1) A list of personnel including name and telephone number shall be readily available in the control room for use by the Reactor Operator. The list shall include:
(a) facility Director;
(b) Reactor Supervisor;
(c) all licensed Reactor Operators and Senior Reactor Operators.

Question 4

6.2.3 Events Requiring the Direction of an SRO

Answer 4

A licensed senior reactor operator shall be present at the facility for:

(1) Initial startup and approach to power;
(2) All fuel movement or relocation;
(3) All control rod relocations within the core region;
(4) Relocation of any in-core experiments or irradiation facilities with a reactivity worth greater than $1.00;
(5) Recovery from unplanned or unscheduled shutdown;
(6) Recovery from unplanned or unscheduled significant power reduction.

Question 5

6.3 Selection and Training of Personnel

Answer 5

The selection, training and requalification of each member of operations personnel shall meet or exceed the requirements of ANSI/ANS 15.4 – 2007, “Standard for the Selection and Training of Personnel for Research Reactors,” for comparable positions.

Question 6

6. 4 Reactor Safeguards Committee

6. 4.1 Function

Answer 6

The Reactor Safeguards Committee shall function to provide an independent review and audit of the Nuclear Science Center activities including:

1. reactor operations;
2. radiological safety;
3. general safety;
4. testing and experiments;
5. licensing and reports;
6. quality assurance.

Question 7

6.4.2

Composition and qualifications

Answer 7

(1) The Reactor Safeguards Committee shall be composed of at least five members knowledgeable in fields that relate to nuclear reactor safety.
(2) The members of the Committee shall include:
(a) one Senior Reactor Operator who may be the Director of the Nuclear Science Center. The presence of Nuclear Science Center staff members shall not be counted to constitute a quorum. Nuclear Science Center staff members shall not be voting members of the Committee.
(b) WSU faculty and staff members designated to serve on the Committee in accordance with the procedures specified by the WSU committee manual.
(3) The University Radiation Safety Officer shall be an ex-officio member of the Committee.
(4) The Reactor Safeguards Committee is a WSU Presidential Committee which performs reviews and audits of the WSU Nuclear Science Center. The Reactor Safeguards Committee reports to the WSU Vice President for Research.

Question 8

6.4.3 Reactor Safeguards Committee Operation

Answer 8

The Reactor Safeguards Committee shall operate in accordance with a written charter, including provisions for:

(1) semiannual meetings of the full committee;
(2) voting rules;
(3) quorums: the committee chair or a designate and two voting members;
(4) method of submission and content of presentations to the committee;
(5) use of subcommittees;
(6) review, approval and dissemination of minutes.

Question 9

6.4.4 Reviews

Answer 9

The responsibilities of the Reactor Safeguards Committee or designated subcommittee shall include the following:
(1) review
(2) review
(3) review
and approval of new experiments utilizing the research reactor;
and approval of proposed changes to the following:
(i) the operating license (R-76) by amendment;
(ii) Standard Operating Procedures;
(iii) Technical Specifications.
of the operation and operational records of the Nuclear Science Center;
(4) review of operating abnormalities or deviations from normal and expected performance of equipment with safety significance;
(5) review in accordance with 10 CFR 50.59 whether proposed changes in equipment, systems, tests, experiments or Standard Operating Procedures would be allowed without prior authorization by the U.S. Nuclear Regulatory Commission.
(6) review of reportable occurrences and the reports filed with the U.S. Nuclear Regulatory Commission for reportable occurrences;
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(7) biennial review and approval of all standard operating procedures and changes to the standard operating procedures;
(8) biennial review of the emergency plan and the security plan;
(9) annual review of the radiation protection program;
(10) review audit reports.

Question 10

6.4.5 Audits

Answer 10

1) The RSC or a subcommittee shall audit reactor operations semiannually. The semiannual audit shall include at least the following:
(a) review of the reactor operating records;
(b) inspection of the reactor operating areas;
(c) review of reportable occurrences;
(d) radiation exposures within and outside the facility;
(e) operations for conformance to the Technical Specifications and license conditions.
(2) The RSC or a subcommittee shall audit the following at biennial intervals:
(a) emergency plan and implementing procedures;
(b) retraining and requalification program;
(c) security plan.

Question 11

6.4.6 Records

Answer 11

The activities of the RSC shall be documented by the secretary of the Committee and distributed as follows:

(1) A written report of all audits performed under Section 6.4.5 shall be prepared and forwarded to Level 1 and Level 2 management within 3 months after the audit has been complete.
(2) A written report of all reviews performed under Section 6.4.4 shall be prepared and forwarded to the Level 1 and Level 2 management within 30 days following the completion of the review.
(3) The secretary of the Reactor Safeguards Committee shall maintain a file of the minutes of all meetings.

Question 12

6.4.7 Experiment Review and Approval

Answer 12

Approved experiments shall be carried out in accordance with established and approved procedures. The following provisions shall be stated in a Standard Operating Procedure for review and approval of experiments:
(1) All new experiments or classes of experiments shall be:
a. installed in the reactor or in its irradiation facilities only after a safety analysis has been performed;
and
b. reviewed and approved by at least 2 Senior Reactor Operators, including written approval by Level 2 or Level 3 management for compliance with the Technical Specifications;
and
c. reviewed and approved by the Reactor Safeguards Committee.
(2) Substantive Changes to previously approved experiments shall be made only after review by the Reactor Safeguards Committee and approved in writing by Level 2 or designated alternates. Minor changes that do not significantly alter the experiment may be approved by Level 3 or higher.
(3) An experiment shall not be installed in the reactor or in its irradiation facilities until after a safety analysis has been performed and reviewed for compliance with Section 3.6 by the Reactor Safeguards Committee in accordance with Section 6.4.7 of these Technical Specifications.

Question 13

6.5 Radiation Safety

Answer 13

(1) The Reactor Supervisor (Level 3) shall have responsibility for implementing the radiation protection program using guidelines of ANSI/ANS-15.11-1993 (R2004). The Reactor Supervisor shall report to Level 2 management and shall communicate with the Reactor Safeguards Committee on matters of radiation safety.
(2) Radiation Protection
(a) The Reactor Safeguards Committee shall have oversight responsibility as defined in Section 6.1(2)(e)(ii) and 6.1(2)(e)(iv).
(b) The Reactor Operating Staff (Level 4) shall conduct radiation protection procedures in licensed areas, and shall report to the Reactor Supervisor (Level 3).

Question 14

6.6 Action To Be Taken if a Safety Limit Is Exceeded

Answer 14

The following actions shall be taken if a safety limit is exceeded:

(1) The safety limit violation shall be reported within 24 hours by telephone to the U.S. Nuclear Regulatory Commission Operations Center.
(2) The reactor shall be shut down and reactor operation shall not be resumed until authorized by the U.S. Nuclear Regulatory Commission.
(3) The safety limit violation shall be promptly reported to Level 1 management or designated alternates, to Level 2 management or designated alternates, to Level 3 management and to the Chair of the Reactor Safeguards Committee.
(4) A safety limit violation report shall be prepared. The report shall describe the following:
(a) applicable circumstances leading to the violation, the cause and contributing factors;
(b) impact of the violation upon reactor facility components, systems, or structures and on the health and safety of personnel and the public;
(c) corrective action to be taken to prevent recurrence.
(5) The report shall be submitted to the Reactor Safeguards Committee for review.
(6) A report shall be submitted in writing, within 10 days, to the U.S. Nuclear Regulatory Commission Document Control Desk.

Question 15

6.7 Required Actions for Reportable Occurrences other than Safety Limit Violations

Answer 15

The following actions shall be taken as required by regulations or for a Reportable Occurrence, as defined in Section 1 for events that are reportable to the U.S. Nuclear Regulatory Commission within 24 hours. Reports are to be made to the U.S. Nuclear Regulatory Commission Operations Center for:

(1) Reactor conditions shall be returned to normal, or the reactor shall be shut down. If it is necessary to shut down the reactor to correct the occurrence, operation of the reactor shall not be resumed unless authorized by Level 2 or designated alternates and the Chair of the Reactor Safeguards Committee.
(2) The occurrence shall be reported to Level 1 management, Level 2 management or designated alternates.
(3) The occurrence shall be reviewed by the Reactor Safeguards Committee at its next scheduled meeting.
(4) An immediate report of the occurrence shall be made to the Chair of the WSU Reactor Safeguards Committee.
(5) A report shall be prepared that includes an analysis of the causes and extent of possible damage, efficacy of corrective action, and recommendations for measures to prevent or reduce the probability of recurrence. The report shall be submitted to the Reactor Safeguards Committee for review.
(6) A report shall be submitted in writing to the U.S. Nuclear Regulatory Commission Document Control Desk within 10 days.

Question 16

6.8 Standard Operating Procedures (don’t fully memorize)

Answer 16

1) Written procedures shall be prepared, reviewed, and approved prior to initiating any of the activities listed in this section. The procedures shall be reviewed by at least 2 Senior Reactor Operators. The procedures shall be reviewed and approved by the Reactor Safeguards Committee after approval by Level 2 management or designated alternates, and such reviews and approvals shall be documented.
(2) Written operating procedures shall be adequate to ensure the safe operation of the reactor, but shall not preclude the use of independent judgment and action if required to protect the health and safety of the public. Operating procedures shall be in effect for the following:
(a) startup, operation and shutdown of the reactor;
(b) fuel loading, unloading, and movement within the reactor;
(c) maintenance of major components of systems which could influence reactor safety;
(d) surveillance checks, calibrations, and inspections required by Technical Specifications or those that could have an influence on reactor safety;
(e) personnel radiation protection, consistent with applicable regulations or guidelines. The procedures shall include management commitment and programs to maintain exposures and releases as low as reasonably achievable in accordance with guidelines of ANSI/ANS-15.11-1993 (R2004).
(f) performing irradiations and experiments using the reactor;
(g) implementation of emergency and security plans;
(h) use, receipt, and transfer of radioactive material;
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(i) control rod removal and replacement;
(j) reactor power calibration;
(k) performing maintenance and/or calibration on the reactor and associated equipment.
(3) Substantive changes to the previous procedures shall be made effective only after documented review by the review group of the Reactor Safeguards Committee and approval by Level 2 or designated alternates or if necessary, by a review under the regulations established by 10 CFR 50.59. Modifications to the procedures that do not change their original intent may be made by Level 3 or higher, but the modifications shall be approved by Level 2 or a designated alternate. Minor changes, such as corrections of typographical errors, editing for clarity or formatting that do not change the execution of the procedure may be made by any Senior Reactor Operator but the modifications shall be approved by Level 2 or a designated alternate. Temporary deviations from the original procedures may be made by the responsible Senior Reactor Operator or higher individual present to deal with special or unusual circumstances or conditions. Such deviations shall be documented and reported within 24 hours to the Level 2 or designated alternate.

Question 17

6. 9 Facility Operating Records

6. 9.1 Five Year Record Retention

Answer 17

Records may be in the form of logs, data sheets, or other suitable forms. The required information may be contained in single or multiple records, or a combination of single or multiple records. In addition to the requirements of applicable regulations, records and logs shall be prepared for at least the following items and retained for the periods of time indicated in Sections 6.9.1, 6.9.2 and 6.9.3:

Records of the following shall be kept for at least five years:

(1) normal reactor operation, including supporting documents such as pre-startup checklists and reactor operating log sheets;
(2) principal maintenance operations;
(3) reportable occurrences;
(4) surveillance activities required by the Technical Specifications;
(5) experiments performed with the reactor;
(6) approved changes in operating procedures;
(7) facility radiation and contamination surveys;
(8) Reactor Safeguards Committee meeting records and audit reports.

Question 18

6.9.2 Life of the Facility Records Retention

Answer 18

Records of the following components or items shall be kept for the life of the facility:

(1) gaseous and liquid radioactive effluents released to the environs;
(2) off-site environmental monitoring surveys required by the Technical Specifications;
(3) radiation exposures for all personnel monitored;
(4) updated, corrected and as-built drawings of the reactor facility;
(5) fuel inventories, receipts, and shipments;
(6) reviews and reports of violations of Safety Limits;
(7) reviews and reports of violations of a Limiting Safety Systems Setting;
(8) reviews and reports of violations of a Limiting Condition of Operation.

Question 19

6.9.3 Training Records

Answer 19

Record of training, retraining and requalification of licensed personnel shall be maintained at all times the individual is employed or until the operator license is renewed.

Question 20

6. 10 Reports to the U.S. Nuclear Regulatory Commission

6. 10.1 Written Reports Due Within 10 Days

Answer 20

All reports in this Section shall be submitted to the U.S. Nuclear Regulatory Commission Document Control Desk.

Written reports of the following shall be submitted to the U.S. NRC within 10 days:

(1) A release of radioactivity above permissible limits in unrestricted areas whether or not the release resulted in property damage, personal injury, or exposure. The written report (and, to the extent possible, the preliminary telephone report) shall describe, analyze, and evaluate safety implications, and outline the corrective measures taken or planned to prevent recurrence of the event.
(2) a violation of a safety limit;
(3) a reportable occurrence as defined in Section 1, “Reportable Occurrence,” of these Technical Specifications.

Question 21

6.10.2 Written Reports Due Within 30 Days

Answer 21

Written reports of the following shall be submitted to the U.S. NRC within 30 days:

(1) a significant variation of measured values from a corresponding predicted or previously measured value of safety related operating characteristics occurring during operation of the reactor;
(2) a significant change in the transient or accident analysis as described in the Safety Analysis Report;
(3) permanent changes in the facility organization involving Level 1 or Level 2 management personnel.

Question 22

6.10.3 Written Report Due Within 60 Days

Answer 22

A report shall be submitted within 60 days after completion of startup testing of the reactor upon receipt of a new facility license or an amendment to the license authorizing an increase in reactor power level. The report shall describe the measured values of the operating conditions, including:

(1) an evaluation of facility performance in comparison with design predictions and specifications;
(2) a reassessment of the safety analysis submitted with the license application which discusses measured operating parameters when measurements indicate a substantial variation from prior analysis.

Question 23

6.10.4 Written Report to the U.S. NRC Within 60 days after June 30 of Each Year

Answer 23

The annual report shall provide the following information:
(1) a brief narrative summary of
(a) operating experience (including experiments performed),
(b) changes in facility design, performance characteristics, and operating procedures related to reactor safety and occurring during the reporting period, and
(c) results of surveillance tests and inspections;
(2) tabulation of the energy output (in megawatt-days) of the reactor, the number of hours that the reactor was critical, the cumulative total energy output since initial criticality, and number of pulses greater than $1.00;
(3) the number of emergency shutdowns and inadvertent scrams, including reasons for them and actions taken to prevent recurrence;
(4) discussion of the major maintenance operations performed during the period, including the effect, if any, on the safety of the operation of the reactor and the reasons for any corrective maintenance required;
(5) a brief description, including a summary of the safety evaluations of changes in the facility or in procedures and of tests and experiments carried out pursuant to 10 CFR 50.59;
(6) a summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or before the point of such release or discharge;
(7) liquid waste (summarized on a monthly basis):
(a) monthly radioactivity discharged;
(b) total estimated quantity of radioactivity released (in curies);
(c) an estimation of the specific quantity for each detectable radionuclide in the monthly release;
(d) fraction of 10 CFR 20 Table 3, Appendix B limit for each detectable
radionuclide taking into account the dilution factor from the total volume of sewage released by the licensee into the sewage system;
(e) sum of the fractions for each radionuclide reported above;
(f) total quantity of radioactive material released by the facility into the sewage system during the reporting period.
(8) gaseous waste (summarized on a monthly basis) radioactivity discharged during the reporting period, including:
(a) total estimated quantity of radioactivity released (in curies) determined by an appropriate sampling and counting method;
(b) total estimated quantity of 41Ar released (in curies) during the reporting period based on data from an appropriate monitoring system;
(c) estimated average atmospheric diluted concentration of 41Ar released during the reporting period in terms of μCi/mL and fraction of the applicable DAC value;
(d) total estimated quantity of radioactivity in particulate form with half-lives greater than 8 days (in curies) released during the reporting period as determined by an appropriate particulate monitoring system;
(e) average concentration of radioactive particulates with half-lives greater than 8 days released in μCi/mL during the reporting period;
(f) an estimate of the average concentration of other significant radionuclides present in the gaseous waste discharge in terms of μCi/mL and fraction of the applicable DAC value for the reporting period if the estimated release is greater than 20% of the applicable DAC.
(9) solid waste (summarized on an annual basis):
(a) total amount of solid waste packaged (in cubic feet),
(b) total radioactivity in solid waste in curies,
(c) the dates of shipment and disposal (if shipped off-site).
(10) an annual summary of the radiation exposure received by facility personnel and visitors in terms of the average radiation exposure per individual and the greater exposure per individual in the two groups. Each exposure in excess of the limits of 10 CFR 20 shall be reported, including the time and date of the exposure as well as the circumstances that led to the exposure.
(11) an annual summary of the radiation levels including contamination levels observed during routine surveys performed at the facility including a summary of the average and highest levels;
(12) an annual summary of environmental surveys performed outside the facility.

Question 24

6.11 Written Communications

Answer 24

All written communications with the U.S. Nuclear Regulatory Commission shall be made in accordance with the requirements of 10 CFR 50.4 “Written Communications.”