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NRC INSPECTION MANUAL RNRP

INSPECTION PROCEDURE 69009

CLASS I RESEARCH AND TEST REACTOR FUEL MOVEMENT

PROGRAM APPLICABILITY: 2545

69009-01 INSPECTION OBJECTIVE

To determine whether fuel was inspected, handled and maintained as required, since the

last inspection.

69009-02 INSPECTION REQUIREMENTS

02.01 Fuel Handling Procedures. Determine whether the licensee’s fuel handling

procedures are adequate to perform intended functions.

02.02 Fuel Handling and Inspection. Determine whether fuel is moved and inspected

consistent with the requirements of the TS and the licensee’s procedures.

02.03 Radiological Controls. Determine whether fuel handling activities are conducted

in accordance with 10 CFR Part 20 and the licensee’s procedures and programs for

radiation protection.

02.04 Security Plan. Determine whether the licensee satisfied security plan requirements

for fuel movement activities.

02.05 Fuel Movement Problem Resolution. Determine whether significant fuel movement

or inspection problems are identified and resolved in accordance with the licensee’s

procedural controls.

02.06 Tests and Checks. Determine whether the licensee was within TS limits and met

procedural requirements before resuming normal operation after fuel movement.
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69009-03 INSPECTION GUIDANCE

General Guidance

Be aware of the facility’s plans and schedules for refueling or other major fuel movement.

 It is not necessary to directly observe the entire fuel movement activity. However,

observation of a portion of the fuel movement activities is desirable. Under no

circumstances is the licensee to adjust schedules for these activities to fit the inspection

schedule. At some facilities, the licensee may move fuel only once a year, which

emphasizes the need to know the licensee’s plans and schedules. Review the safety

analysis report (SAR) or as-built facility descriptions, the TS, the licensee’s procedure(s),

and the Security Plan for fuel design information, fuel movement methods, and

requirements. If practical, these documents may be reviewed prior to the onsite inspection.

During the onsite inspection, be alert for significant differences in the SAR, or the TS

descriptions of fuel and equipment as compared to the actual fuel and equipment. If such

differences are identified, design change review and approval is required in accordance

with 10 CFR 50.59 and the licensee’s procedures. If differences are found, are they

reflected in the as-built description of the facility?

For guidance on new, plate-type fuel refer to ANSI/ANS-15.2, "Quality Control for Plate

Type Uranium Aluminum Fuel Elements," 1974, and Regulatory Guide 2.3, "Quality

Verification for Plate-type Uranium-Aluminum Fuel Elements for Use in Research

Reactors." General guidance may be found in the ANSI/ANS Standards listed in Appendix

B to Inspection Procedure 69001, "Class II Research and Test Reactors." Additional

general guidance may be found in the Division 2 Regulatory Guides, and the "Other

Regulatory Guides of Possible Interest to Division 2 Recipients" listed in the Division 2

Regulatory Guides Table of Contents. Reference to this guidance is to aid in the technical

evaluation of licensee programs and is not to be used as requirements unless the licensee

has committed to them in writing.

The sample sizes in this inspection procedure are provided for broad planning purposes

and to define the typical depth of the inspection. They are not intended to be rigid

requirements on the inspector.

Specific Guidance

03.01 Fuel Handling Procedures. The licensee’s fuel movement activities are governed

by the licensee’s procedures. These procedures may be written when needed rather than

being standard procedures at facilities where refueling is infrequent or where the core

configuration changes with each fuel movement. The use of approved procedures are

required in accordance with TS and security plan requirements.

03.02 Fuel Handling and Inspection. Facilities use varying types of fuel, different fuel

handling methods, and different tools. The observation of one fuel movement activity is

an acceptable sample for this inspection requirement. If direct observation of a fuel

movement activity is not possible at the time of inspection, verification of the final fuel

location, the review of respective records, and discussions with personnel involved in the

most recent fuel movement activity will provide an acceptable sample for inspection. Is the

final location of the fuel consistent with that specified in the licensee’s records?
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Safe fuel handling includes assurance that the fuel is not damaged, that accidental

criticality does not occur, and that radiation and contamination hazards are minimized. 

The failure of a fuel element can be dramatic. For example, a blister on a TRIGA fuel

element of about 3⁄4 of an inch in diameter developed a crack about 1⁄2 of an inch long at

one facility. The first indication of this failure was a high air particulate alarm that required

evacuation of the facility. Radioactivity in the water activity rose to about 0.2 microcuries

per milliliter and airborne particulate activity was substantial.

The licensee is required to handle fuel in accordance with the TS and applicable

procedures during refueling, fuel shuffling, and fuel inspection. It is important for

participants to be trained and understand their tasks. Dry runs may be necessary for

operations of potential safety concern or of an unusual nature. The dry runs normally

include discussion of actions needed to avert or mitigate accidents. The licensee's fuel

handling tools are required to be consistent with TS requirements and licensee

procedures. 

Fuel handling activities and procedures normally provide for:

a. Fuel transfer into a core configuration, or to racks or containers that have been

designed to prevent accidental criticality. The threat of inadvertent criticality varies

from facility to facility. Many Research and Test reactors are designed to be near

the optimum size. This means that if the core had a greater or lesser number of

fuel assemblies per unit volume, the shutdown margin would increase. However,

the design may be such that additional moderation increases multiplication. 

Normally, removing fuel would provide more shutdown margin, but on a highly

under moderated core, the water replacing the removed fuel rod adds more

reactivity than the fuel removal takes away. While minimum critical volume varies

considerably, the specific moderation, enrichment, poison and core structure may

allow much less than a cubic yard of typical fuel and water to have a critical mass.

For example, four fuel bundles in a line could be touching. Even under optimum

moderation conditions this would present no problem, yet the same four bundles

in a square matrix do pose a problem. Usually these concerns are minimized by

transferring fuel to storage pits, racks, or containers that have been designed for

the purpose, or by removing only one bundle at a time to be inspected underwater

and then replaced before proceeding. The licensee's procedures generally require

either the calculation of the minimum number of fuel bundles for a critical mass

with optimum moderation, or that the bundles simply be separated by the use of

fuel racks designed for this purpose.

b. Is neutron monitoring accomplished as required? When the licensee is changing

the core configuration, procedures generally specify requirements for monitoring

changes in the level of neutron flux. For example, when 1/M calculations are

required, they are usually performed independently by more than one person.

c. The licensee is required to inspect fuel and control rods in accordance with the TS

and their procedures. Some licensees may have TS requirements for the

frequency of inspection based on time or pulsing criteria and some may have

specific acceptance criteria such as fuel bow or elongation. The TS normally

require the licensee to periodically inspect the fuel and visually determine its
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integrity. The facility may or may not have specific acceptance criteria. If there are

no specific acceptance criteria for fuel inspection, the literature from the fuel

supplier or the SAR may contain the information.

It is important for the licensee to check the control rods to determine their capability

to continue to function. In most cases, if the rod or its linkage broke, it would fall

in a safe position. However, some vane-type control blades might fall out of the

core if broken. Since the rods are all roughly of the same design in a facility, a

failure in one could indicate that another might fail by the same mechanism.

Therefore, it is imperative that the licensee investigate and resolve such failures

to insure that control rods perform their intended function to shut down the reactor.

 The observation of this type of problem resolution will satisfy the requirements of

Section 02.05 above.

If an installed neutron source is removed during refueling, it is also important for

the licensee to have provisions to inspect it for leakage paths such as splitting or

pitting.

03.03 Radiological Controls. The observation of radiological controls during one fuel

movement activity is an acceptable sample for this inspection requirement. If direct

observation is not possible at the time of inspection, the review of radiation protection

records and discussions with responsible personnel for the most recent fuel movement

activity will provide an acceptable sample for inspection. Fuel movement can cause

significant radiological hazards. A single fuel element can easily emit radiation at levels

above 100 rem per hour at one foot. Radiation levels are related to power history and the

decay time after shutdown. The movement of fuel also includes the requirement, in part,

to maintain occupational doses as low as reasonably achievable (ALARA).

Completion of this portion of the inspection procedure does not supersede all of the

requirements to examine the radiation controls in other inspection procedures. However,

inspection effort in this area is not to be duplicated in other Class I Research and Test

reactor inspection procedures. Credit may be taken for meeting respective requirements

in Inspection Procedure 69012 “Class I Research and Test Reactors Radiation Protection”

by performing this portion of the inspection.

Radiological controls during fuel handling activities include, but are not limited to, the

following:

a. Monitoring or sampling for airborne radioactive particulate matter. Grab samples

may substitute for continuous air monitors to verify compliance with 10 CFR Part

20 and the TS. Grab sampling is to be performed in accordance with approved

licensee procedures.

b. Monitoring exits from controlled areas in accordance with the 10 CFR Part 20 and

the licensee's procedural requirements. A Geiger Muller (GM) detector is normally

used for exit surveys. If area radiation levels are so high that a difference of about

0.2 millirem per hour (mr/hr) cannot be detected, the detector area may need

shielding or the controlled area should be extended to a low radiation area. An

increase of 0.2 mr/hr generally represents contamination that would normally be
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considered gross contamination. 10 CFR Part 20, Subpart F requires surveys and

ANSI/ANS 15.11, 1993 provides additional guidance in the section on

"Radioactive Contamination Monitoring." 10 CFR Part 20, Subpart J provides the

posting and labeling requirements for several radiation areas. Licensee

procedures provide specific guidance for each facility.

c. Surveys for contamination are required to be performed in accordance with

licensee procedures. The frequency for the performance of the surveys is

specified in the licensee’s procedures and is normally based on the potential

hazard associated with fuel handling activities and the contamination levels of

handled objects. It is also prudent for the licensee to consider the amount of traffic

into and out of the controlled area. For example, if personnel enter the controlled

area in the morning and do not leave until noon, it would be meaningless to

perform surveys at the work exit area every two hours. However, if people are

continuously entering and exiting the area to observe the work, it is necessary to

check the work exit area for contamination when each one leaves. Are licensee

personnel, tools and equipment surveyed for contamination upon exit of the work

area?

d. Radiation areas are to be monitored in accordance with Subpart F of 10 CFR Part

20, the TS and the licensee’s procedural requirements. Most facilities have

continuous area radiation monitors with pre-set alarm set points. While these may

be helpful, they may be an unnecessary nuisance by being set so low that

procedures would require evacuation during even a well controlled situation.

However, if the set point is too high, the potential exists for the overexposure of

workers without the benefit of a warning. Acceptable set points and monitoring

help the licensee to comply with 10 CFR Part 20 exposure limits and are consistent

with ALARA requirements. Does the licensee survey periodically to determine

whether actual radiation levels are consistent with area radiation monitors to avoid

unnecessary or excessive exposures to individuals?

e. Personnel dosimetry is required by 10 CFR 20.1502 and is to be used as specified

by the licensee’s procedures. Licensee personnel are normally instructed to check

direct reading dosimeters frequently. Are personnel monitoring devices, such as

film badges, TLDs, direct reading dosimeters and extremity monitors, worn

correctly and appropriate for expected radiation fields and the type of work to be

done?

03.04 Security Plan. The observation of security controls during one fuel movement

activity is an acceptable sample for this inspection requirement. If direct observation is not

possible at the time of inspection, the review of records, and discussions with responsible

personnel for the most recent fuel movement activity will provide an acceptable sample for

this portion of the inspection.

The structural integrity of some reactors may be a required security barrier. While the

reactor is dismantled during fuel movement, the defined security area and patrols is

specified in the facility the security plan. Generally, new fuel is required to be kept in the

security area and locked in a fuel vault or in some way secured so that it cannot not be
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carried away by hand. Spent fuel is normally controlled in storage racks in a spent fuel

pool or in the reactor pool.

03.05 Fuel Movement Problem Resolution. The observation of the resolution of one fuel

movement problem is an acceptable sample for this inspection requirement. If direct

observation is not possible at the time of the inspection, problem areas may be identified

by the review of the licensee’s logs and records, and discussions with responsible

personnel for the most recent fuel movement activity. The licensee is required to resolve

identified problems (e.g., fuel integrity) to meet TS requirements.

03.06 Tests and Checks. The observation of one reactor startup, after fuel movement,

is an acceptable sample for this inspection requirement. If direct observation is not

possible at the time of inspection, the review of respective licensee logs and records, and

discussions with responsible personnel for the most recent fuel movement activity will

provide an acceptable sample for this inspection requirement. If the detailed records of the

tests and checks were covered under the Inspection Procedure on "Class I Research

and Test Reactor Surveillance", it need not be repeated here. Changes to core

configuration may require calibration of control rods, and determination of excess reactivity

and shutdown margin.

69009-04 RESOURCE ESTIMATE

For planning purposes, the direct inspection effort to complete this inspection procedure

is estimated to be four hours. Actual inspection at any facility may require more or less

effort depending on past inspection history, conditions at the facility, and safety

significance of the inspection findings.

END