**NRC INSPECTION MANUAL** RNRP

INSPECTION PROCEDURE 69002

CLASS III RESEARCH AND TEST REACTORS

PROGRAM APPLICABILITY: 2545

69002‑01 INSPECTION OBJECTIVE

To determine if activities at Class III research and test reactors were
conducted safely and in accordance with regulatory requirements and
licensee commitments, since the last inspection.

69002‑02 INSPECTION REQUIREMENTS

02.01 [Staffing and Audits]{.underline}. Determine if required staffing
was maintained and that required audits were conducted in accordance
with the technical specifications (TS) requirements.

02.02 [Operator Requalification and Active License Status]{.underline}.
Determine if the requalification records were maintained as required by
the licensee\'s NRR‑approved requalification training program and that
operators have continued to maintain active license status.

02.03 [Radiological Surveys]{.underline}. Determine if required
radiological surveys are performed in accordance with approved licensee
procedures.

02.04 [Surveillance]{.underline}. Determine if surveillance activities
were completed as required by technical specifications.

02.05 [Emergency Preparedness]{.underline}

a.  Determine if the licensee completed emergency preparedness exercises
    and drills as required by the emergency plan.

b.  Determine if the licensee has completed emergency preparedness
    training in accordance with the emergency plan commitments.

69002‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}

This procedure applies to Class III research and test reactors. It
includes inspection of reactors in a long‑term shutdown status or with a
possession only license. If the licensee is conducting activities, such
as, fuel movements, maintenance, or a major modification, with the
intent of starting up operations, this procedure should not be applied.
That is, a facility shall be considered to be in an operating status if
the work associated with the reactor is the reason for it being
shutdown, e.g., refueling, design changes, or testing. For facilities in
operating status, the applicable Class I or II research and test reactor
inspection procedures should be used.

If safety concerns are identified as a result of this inspection, the
inspector may determine that additional inspection is warranted. If the
facility operated for several months and was then shut down with the
intention of remaining in long‑term shutdown, the inspector may conclude
that additional inspection is also needed to assess safety significant
events or conditions. If additional inspection is needed, the inspector
should consult appropriate management and the NRR project manager to
establish the extent of inspection effort to be applied. If in this
consultation it is determined that additional inspection activity is
needed, the inspector should use applicable portions of the procedures
specified in Inspection Manual Chapter 2545.

The inspector should establish through TS review all shutdown
requirements before conducting the inspection. If the TS do not allow
the flexibility to suspend unnecessary items until needed, the licensee
may request a TS change through NRR.

General guidance may be found in the ANSI/ANS Section 15 Standards.
Additional general guidance may be found in the Division 2 Regulatory
Guides, and the \"Other Regulatory Guides of Possible Interest to
Division 2 Recipients\" attached to the Division 2 Regulatory Guides
Table of Contents. The reference to this guidance is to aid the
inspector in technical evaluation of licensee programs and is not to be
used as requirements on the license unless the licensee has committed in
writing to use the specific guidance document.

Whenever practical, the inspector should observe actual work in
progress, such as changes in required functions due to maintenance or
design change activities during long‑term shutdown conditions.

The sample sizes and resource estimates suggested in the inspection
procedure is provided for broad planning purposes and to define the
typical depth of the inspection. It is not intended to be a rigid
requirement on the inspector. Actual inspection at any facility may
require more or less effort depending on past inspection history,
conditions at the facility, and [safety significance]{.underline}.

[Specific Guidance]{.underline}

03.01 [Staffing and Audits]{.underline}. Requirements for facility
staffing and the conduct of licensee audits may be found in the
Administrative Section of the TS. Audits should include review of major
maintenance or design change activities by management and the safety
review committee.

03.02 [Operator Requalification and Active License Status]{.underline}.
The verification of records for two operators should be an acceptable
sample for this inspection requirement. These records should verify that
the licensee has continued to meet the requirements of the NRR‑approved
requalification training program.

If the facility is in a long‑term shutdown, the licensee should
understand that the facility operators must satisfy the requirements of
the requalification program and 10 CFR 55.53(e) in order to maintain an
active license. The requirement for maintaining an active operator
license is independent of plant status. Operator duties to comply with
active license status requirements do not solely relate to operating the
reactor, but can be considered to include other reactor related
activities that apply to the specific condition of the reactor facility,
such as, reactor checkouts and fuel movement. If the provisions of 10
CFR 55.53(e) can not be satisfied, the facility is required to meet
those of 10 CFR 55.53(f). If none of these requirements can be met, a
specific exemption should be pursued by the licensee as specified in 10
CFR 55.11. The inspector should ensure that the licensee understands
these requirements.

If the facility is not to return to reactor operations and all fuel has
been removed from the facility, there may be no need to maintain the
requalification plan. The licensee should request exemption from NRR
before they discontinue implementation of the operator requalification
plan. If the licensee has not met operator requalification plan
requirements, the inspector should discuss this problem with appropriate
management and the NRR project manager.

03.03 [Radiological Surveys]{.underline}. The observation of one
radiation and contamination survey, and radiological control area exit
survey should provide an acceptable sample for this inspection
requirement. The licensee\'s procedures for routine surveys may require
personnel to perform such actions as checking sealed sources for rupture
or checking for the spread of contamination from irradiated material
from either the core or experiments. If it is not practical to observe
surveys, the inspector should perform independent surveys of several
areas using either NRC or licensee survey instruments. The results of
the inspector\'s survey should be comparable with the most recent
licensee surveys.

03.04 [Surveillance]{.underline}. The verification of records for two TS
required surveillances should provide an acceptable sample for this
inspection requirement. The activities to satisfy inspection requirement
02.03, above, may suffice for one surveillance verification if the
survey was required by the TS.

03.05 [Emergency Preparedness]{.underline}. If the facility is not to
return to reactor operations and all fuel has been removed from the
facility, there may no need to maintain the emergency plan. The licensee
should request exemption from NRR before they discontinue implementation
of the plan.

a.  Verification of the conduct of the last required emergency exercise
    or drill should provide an acceptable sample for this inspection
    requirement. Emergency preparedness exercises and drills that the
    licensee is required to conduct may be found in the facility
    specific emergency plan.

b.  Verification of training for two persons with emergency response
    responsibilities should provide an acceptable sample for this
    inspection requirement. Individuals with emergency response
    responsibilities should have participated in an exercise or drill
    and training as required by the emergency plan and operator
    requalification plan.

69002‑04 RESOURCE ESTIMATE

For planning purposes, the direct inspection effort to complete this
inspection procedure is estimated to be 16 hours.

END