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NRC INSPECTION MANUAL RNRP

INSPECTION PROCEDURE 69010

CLASS I RESEARCH AND TEST REACTOR SURVEILLANCE

PROGRAM APPLICABILITY: 2545

69010-01 INSPECTION OBJECTIVE

To determine if the licensee conducted its surveillance program as required by the

technical specifications (TS) and licensee commitments, since the last inspection.

69010-02 INSPECTION REQUIREMENTS

02.01 Surveillance Procedures. Verify that technical specification required surveillance

procedures can be used to perform their intended function for the as-built configuration of

the facility.

02.02 Surveillances. Verify that surveillances were performed in accordance with the

requirements in the TS.

02.03 Limiting Conditions of Operations. Verify that parameters identified in the TS, e.g.,

limiting conditions of operation (LCO), design features, or limiting safety system settings

(LSSS), or safety limits, that do not have an established surveillance frequency in the TS,

are maintained within the bounds assumed in the TS or the safety analysis report.

02.04 Records and Logs. Verify that the records and logs (including those of chart

recorders) are consistent with the results of the TS required surveillance records.

69010-03 INSPECTION GUIDANCE

General Guidance

This inspection procedure is to determine if the licensee has met the TS surveillance

requirements and maintained the facility within the bounds of safety analysis assumptions.
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Surveillance is the verification of set points and conditions required by the TS on both a

regular and an irregular basis. The types of items covered by this procedure include

reactivity measurements that may be required once or twice a year, certain conductivity

checks that may be weekly activities, and interlocks that must be checked before each

start-up.

This procedure also covers those values or conditions specified or assumed by the TS that

have no assigned surveillance frequency but have a definite bearing on safety. These

latter items would include such things as a required air flow for the Argon-41 exhaust

system.

General guidance may be found in the ANSI/ANS Section 15 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 after 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 unless the licensee has committed in writing to the NRC to use the specific

guidance document.

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. 

Specific Guidance

03.01 Surveillance Procedures. The review of no fewer than two or more than five of the

licensee’s surveillance procedures should provide an acceptable sample for this inspection

requirement. The procedures selected should be reviewed on a rotating basis. If practical,

the inspector should review the procedures before the onsite inspection and monitor work

in progress when onsite. 

The licensee should conduct surveillances associated with safety-related systems or

components in accordance with approved procedures as required by TS. For facilities with

experienced personnel and little turnover in personnel, activities that are within the skill of

qualified personnel do not require step-by-step delineation of work performance steps.

Whereas, for facilities with turnover, such as in student operators, more detailed

procedures would be appropriate.

If TSs do not require surveillance procedures, the inspector should consider the need for

such requirements based on the results of performance based inspection observations in

the conduct of this inspection. For example, if personnel do not have procedures, they

may calculate rod worth by the positive period method, then by rod drop, and then by the

1/M methods. Alternating methods in this way could produce widely varying results for the

same rod. Such wide variation could make the worth measurements meaningless because

the values may not result in a uniform basis to determine that core conditions had not

changed. Thus, finding inconsistent results that do not meet the intent of a requirement
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may establish the need for specific procedures. Such concerns should be raised to

appropriate management and the NRR project manager.

Descriptions in the TS, the Safety Evaluation Report (SER), the Safety Analysis Report

(SAR) and supporting documentation, including plan and instrument drawings should be

used during this evaluation. Any applicable design changes should be reflected in licensee

surveillance activities. The procedures should enable the licensee to accomplish the TS

required surveillance with the as-built system configuration and accuracy of the

instruments. A simple example of a potential problem is the surveillance of a float alarm

for reactor pool water level, in which operators manually depress the float. At a Research

and Test Reactor, this procedure would not give complete assurance that the float will

move when water level drops unless there is assurance that weight of the float assembly

will actuate the sensing relay. An alternative may be to slowly move the float device above

the water level or lower water level until the low level relay is actuated.

03.02 Surveillances. The observation of no fewer than two or more than five of the

licensee’s surveillances should provide an acceptable sample for this inspection

requirement. The inspector should if possible observe the use of the same procedures

reviewed in Section 03.01, above. The entire surveillance test need not be observed, but

only the selected portions that provide the inspector confidence that the item was

acceptably verified. When observation of surveillances in progress is not possible, the

inspector should perform a walk-through of selected surveillance activities with responsible

licensee personnel. Alternatively, the inspector may conduct discussions of the selected

surveillance activities, and obtain separate or simplified measurements to determine

compliance with the surveillance requirements. Respective licensee records should

demonstrate that all required surveillances have been completed as required.

The licensee should review and approve the conduct and results of TS required

surveillance activities in accordance with their administrative controls and procedures. For

example, some reactivity measurements are done as class projects by students. If the

licensee accepts these results to satisfy TS requirements, the results should be reviewed

and approved by the appropriate licensee personnel in accordance with administrative

control procedures.

03.03 Limiting Conditions of Operations. The review of two TS specified items for this

inspection requirement should provide an acceptable sample. This review should examine

parameters specified in TS that do not have specified surveillance. This inspection

requirement is to assure that the licensee has not changed the initial licensing

assumptions. If this is verified in the design change, or maintenance inspection activities

it need not be repeated here.

The inspector should review only matters having a bearing on safety. As an illustration,

if the descriptive information states that the exhaust stack is 33 feet high, it is generally not

worth measuring to precise accuracy. However, if the TS include limits on primary coolant

conductivity without including a specific frequency of measurement, the inspector should

determine the manner in which the licensee assures that the limits are maintained. The

verification need not include specific measurements of the parameter, but rather could be

established through related controls. For example, rather than actual conductivity

measurements, use of demineralizers with indication of spent resin capacity combined with
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fuel examinations may be an acceptable alternative. Another example could be limitations

on fuel temperature that may be established by maintaining the reactor within specified

power levels. Refer to TS bases, SAR and SER descriptions to ensure that the appropriate

safety significance is placed on the item.

While some surveillance may have frequencies established in more recent TS, older TS

may not have some surveillance frequency requirements. It is not the intent here to

establish surveillance frequencies at older facilities unless a real need is established, such

as by determining that the value or condition, that directly relates to safety, has significant

potential to not be met because of inadequate surveillance. Such discrepancies should

be brought to the attention of appropriate management and the assigned NRR Project

Manager.

03.04 Records and Logs. The review of no fewer than two or more than five of the TS

required surveillance records should provide an acceptable sample for this inspection

requirement. The observation of the records and logs for the observed surveillances above

would be preferred for this inspection requirement. Records should be accurate, complete,

and maintained. Charts should be marked on a regular frequency with the date, time, and

indication of the personnel as required by the licensee procedures. Recorder drives will

occasionally slip yielding readings that are not precise. The inspector should avoid looking

for small errors, but should focus on the consistency of facility conditions with the

surveillance results.

69010-04 RESOURCE ESTIMATE

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

is estimated as eight hours.

END