IR 05000005/2019201

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Pennsylvania State University - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000005/2019201
ML19130A101
Person / Time
Site: Pennsylvania State University
Issue date: 05/16/2019
From: William Schuster
Research and Test Reactors Oversight Projects Branch
To: Unlu K
Pennsylvania State Univ, University Park, PA
Schuster W, NRR/DLP, 415-1590
References
IR 2019201
Download: ML19130A101 (17)
v • d • e


Text

SUBJECT:

PENNSYLVANIA STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000005/2019-201

Dear Dr. Unlu:

From April 29 - May 1, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted a routine, announced safety inspection at the Pennsylvania State University Breazeale Reactor facility. The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection.

During the inspection, the NRC staff examined activities conducted under your license as they relate to public health and safety to ensure compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observation of activities, and interviews with personnel. Based on the results of this inspection, no findings of non-compliance were identified. No response to this letter is required.

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 electronically for public inspection in the NRC Public Document Room or from the NRCs 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 Mr. William Schuster at (301) 415-1590 or by electronic mail at William.Schuster@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No.50-005 License No. R-2 Enclosure:

As stated cc: See next page

Pennsylvania State University Docket No.50-005 cc:

Yuanqing Guo Manager of Radiation Protection The Pennsylvania State University 0201 Academic Project Bldg University Park, PA 16802 Dr. Neil A. Sharkey Vice President for Research The Pennsylvania State University 304 Old Main University Park, PA 16802 Director, Bureau of Radiation Protection Department of Environmental Protection P.O. Box 8469 Harrisburg, PA 17105 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Dr. Jeffrey Geuther Associate Director for Operations Radiation Science & Engineering Center Breazeale Nuclear Reactor Building University Park, PA 16802-1504

ML19130A101 *concurrence via e-mail NRC-002 OFFICE NRR/DPR/PROB/RI* NRR/DPR/PROB/LA* NRR/DPR/PROB/BC NAME WSchuster NParker AMendiola DATE 5/10/19 5/10/19 5/16/19

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-005 License No.: R-2 Report No.: 05000005/2019-201 Licensee: Pennsylvania State University Facility: Pennsylvania State University Breazeale Reactor Location: State College, PA Dates: April 29 - May 1, 2019 Inspector: William Schuster Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY The Pennsylvania State University Pennsylvania State University Breazeale Reactor NRC Inspection Report No. 05000005/2019-201 The primary focus of this routine, announced safety inspection included the on-site review of selected aspects of the Pennsylvania State University (PSU or the licensee) Class II research reactor facility program, including: (1) procedures; (2) experiments; (3) health physics; (4)

design changes; (5) committees, audits, and reviews; and (6) transportation since the last U.S.

Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety, and in compliance with NRC requirements.

Procedures

  • Procedural review, revision, control, and implementation satisfied technical specification (TS) requirements.

Experiments

  • The program for reviewing, approving, and conducting experiments satisfied TS and procedural requirements.

Health Physics

  • Surveys were being completed and documented acceptably.
  • Postings met regulatory requirements.
  • Personnel dosimetry was being worn as required and doses were within regulatory limits.
  • Radiation monitoring equipment was being maintained and calibrated as required.
  • Radiation protection training was being provided to facility personnel.
  • Calculations of effluents released from the facility satisfied license and regulatory requirements and releases were within the specified regulatory limits.

Design Changes

  • Changes to the facility were being evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests and experiments, and were reviewed and approved by the Reactor Safeguards Committee (RSC) as required.

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Committees, Audits, and Reviews

  • Review, audit, and oversight functions required by the TS were acceptably completed by the RSC.

Transportation

  • Radioactive material was being shipped in accordance with the applicable regulations.

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REPORT DETAILS Summary of Facility Status The PSU continues to operate the 1 megawatt research reactor in support of education, research, and service.

1. Procedures a. Inspection Scope (Inspection Procedure (IP) 69001, Section 02.03)

To verify compliance with the licensees TS requirements for procedures, the inspector reviewed selected aspects of the licensees program, including:

  • Technical Specifications for Pennsylvania State University Breazeale Reactor, dated November 2009
  • Annual Operating Report for the Penn State Breazeale Reactor (PSBR), for the period of July 1, 2016 through June 30, 2017
  • Annual Operating Report for the PSBR, for the period of July 1, 2017 through June 30, 2018
  • Select Administrative Procedures (AP), Standard Operating Procedures (SOP), Checks and Calibration Procedures (CCP), and Auxiliary Operating Procedures (AOP)
  • RSC Meeting Minutes, from June 2017 to November 2018 b. Observations and Findings The inspector reviewed facility procedures and the processes to review, approve, and change procedures. The inspector noted that the facility procedures had been developed as required by TS 6.3, Operating Procedures. The procedures were reviewed, approved, and changed in accordance with local processes and procedures, notably AP-12, Change, and CCP-18, Review of Procedures.

While not a TS requirement, biennial procedure reviews were previously performed in accordance with CCP-18. Numerous minor changes and updates were made to maintain procedures during the year and were not reported under 10 CFR 50.59. All procedures observed were approved and dated. During the inspection, the inspector observed facility personnel following procedures to complete tasks. Additionally, the procedures being used appeared to be up to date, effective, and able to be implemented for the intended purposes.

c. Conclusion Procedural review, revision, control, and implementation satisfied TS requirements.

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2. Experiments a. Inspection Scope (IP 69001, Section 02.06)

To verify compliance with the licensees TS requirements for experiments, the inspector reviewed selected aspects of the licensees program, including:

  • Technical Specifications for Pennsylvania State University Breazeale Reactor, dated November 2009
  • Annual Operating Report for the PSBR, for the period of July 1, 2016 through June 30, 2017
  • Annual Operating Report for the PSBR, for the period of July 1, 2017 through June 30, 2018
  • RSC Meeting Minutes, from June 2017 to November 2018
  • SOP-5, Experiment Evaluation and Authorization, Revision 4; dated November 16, 2004
  • Select records, SOP-5 Experimental Evaluation and Authorization forms numbered 2018-001 through 2019-015
  • PSBR Logbook 104 (2018-2)

b. Observations and Findings The inspector reviewed the experimental review and approval process at the facility. The inspector verified that experiments utilizing the reactor were evaluated in accordance with TS 3.7, Limitations of Experiments and SOP-5, Experimental Evaluation and Authorization. The inspector also verified that experiments not previously approved for the reactor were approved in accordance with TS 6.4, Review and Approval of Experiments. The inspector noted that no recent experimental authorizations required a 10 CFR 50.59 review and subsequent RSC review in accordance with TS 6.2.3, Review Function.

The inspector reviewed a sample of the 45 experiments approved for use from 2018 to present day. Based on a review of these records, the inspector determined that experiments being conducted at the facility met the reactivity limit, design, and material requirements in TS 3.7 and restrictions on production of Argon-41 in TS 4.6.2, Argon-41.

During the inspection, the inspector observed irradiation of samples based on previously approved experiment evaluation 2019-001, Neutron transmission and radioscopy/radiography. The inspector noted this irradiation was performed in accordance with the experiment authorization.

c. Conclusion The program for reviewing, approving, and conducting experiments satisfied TS and procedural requirements.

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3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)

To verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, Part 20, Standards for Protection against Radiation, TS requirements for health physics, and procedural requirements, the inspector reviewed selected aspects of the licensees program, including:

  • Technical Specifications for Pennsylvania State University Breazeale Reactor, dated November 2009
  • Annual Operating Report for the PSBR, for the period of July 1, 2016 through June 30, 2017
  • Annual Operating Report for the PSBR, for the period of July 1, 2017 through June 30, 2018
  • Rules and Procedures for Users of Radioactive Material at the Pennsylvania State University, dated May 2018
  • AP-18 Radiation Protection Program Review for 2018, dated January 17, 2019
  • Memorandum from Y. Guo, Calendar Year 2017 Clean Air Act Standards for Radionuclide Emissions Compliance Analysis, dated March 23, 2018
  • Memorandum from Y. Guo, Calendar Year 2018 Clean Air Act Standards for Radionuclide Emissions Compliance Analysis, dated February 8, 2019
  • Select records, completed AOP-4 Appendix A, Daily Contamination Check and Response Procedure, from May 2017 to present day
  • Select logbook entries, AOP-5, Water Collection and Analysis, from May 2017 to present day
  • Select records, completed CCP-8 forms, Calibration of Air Monitors, from May 2017 to present day
  • Select records, completed CCP-10 forms, Calibration of Area Radiation Monitors, from May 2017 to present day
  • Select records, completed CCP-12 forms, Calibration of Portable Survey Instruments and Pocket Dosimeters, from May 2017 to present day
  • Select records, completed Initial/Refresher Radiation Training for 2017-2018
  • Select records, Annual Dosimetry Report [NRC Form 5] from Pennsylvania State University for 2018
  • Select records, Radiation Dosimetry Report, for personnel and environmental from 2017-2018
  • Select records, Radiation/Radioactive Material Safety Audit, from May 2017 to present day
  • Select records, Radioactive Material Survey, for 2019
  • Master Portable Detector Inventory form
  • Select records, 2018 RSEC Pool Project
  • Select records, Uniform Low-Level Radioactive Waste Manifest (various NRC forms numbered 540, 540A, 541, 541A, 542)

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b. Observations and Findings (1) Surveys During the inspection, the inspector observed Radiation Science and Engineering Center (RSEC) staff perform a portion of a routine contamination survey in accordance with AOP-4. The survey readings indicated no contamination was present, consistent with expectations for that area in the reactor building. The inspector also reviewed select radiation and contamination surveys of the RSEC, performed by RSEC staff or Environmental Health & Safety (EHS) staff, from 2017 to the present day.

The results were documented on the appropriate forms and evaluated as required, comments were provided if readings were other than expected, and corrective actions were taken when readings or results exceeded set action levels. The surveys had been completed as required by procedures and in accordance with the requirements in Subpart F, Surveys and Monitoring, to 10 CFR Part 20.

(2) Postings and Notices During a tour of the facility, the inspector observed that signage, posting, and labels were used in accordance with requirements in Subpart J, Precautionary Procedures, to 10 CFR Part 20. Radioactive material storage areas were noted to be properly posted. Copies of notices to workers were posted in the facility, including a copy of the most recent revision of NRC Form 3, Notice to Employees, as required by 10 CFR 19.11, Posting of notices to workers.

(3) Dosimetry The inspector observed the use of dosimetry for whole body monitoring of beta, gamma, and neutron radiation exposure and finger ring dosimetry for extremity monitoring for beta and gamma radiation exposure. The dosimetry was supplied processed by a National Voluntary Laboratory Accreditation Program accredited vendor, Landauer. Most of the occupational doses received by RSEC staff are close to zero millirem, with the exception of a few staff that routinely conduct experiment irradiations or maintenance activities.

An examination of the dosimetry records for the past two years showed that the highest occupational doses were well below Subpart C, Occupational Dose Limits, to 10 CFR Part 20 limits of 5000 millirem/year (mr/yr) Total Effective Dose Equivalent. The inspector also verified that annual dosimetry reports (i.e. NRC Form 5), as required by 10 CFR 19.13, Notifications and reports to individuals, were provided to each employee who had received exposure greater than 100 millirem at the facility during 2017 and 2018. The inspector determined that the licensee was appropriately monitoring individuals in accordance with the requirements in 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose.

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(4) Radiation Monitoring Equipment During the inspection, the inspector observed storage and use of portable survey instrumentation at the facility. The inspector reviewed the records of selected meters, detectors, and air monitoring equipment. Annual calibration and monthly source check frequency of the portable detectors and fixed meters and monitors were consistent with manufacturers recommendations and appropriate calibration records were being maintained. Additionally, the inspector observed a reactor operator conducting a portion of the monthly inventory and operability check of portable detectors stored throughout the facility in accordance with SOP-4B, Safety Support Equipment. The inspector determined portable survey meters were being maintained as required by Subpart F to 10 CFR Part 20.

(5) Radiation Protection Training The inspector reviewed documentation of the initial and annual radiation protection training. The course documentation consisted of training material, evaluation (quiz), and attendance records. Through a review of records, the inspector verified that training was provided to new users as well as refresher training to users who had been at the University for over a year. The content of the training program satisfied the requirements in 10 CFR 19.12, Instruction to workers.

(6) Radiation Protection Program The inspector determined that the radiation protection program was established in university policies and procedures, as well as through the facility procedures. The facility conducted an annual audit to review program content and implementation in accordance with AP-18, Radiation Protection Program (RPP), as required by 10 CFR 20.1101(c). The inspector noted that the 2018 audit provided some comments on improving audit scope and guidance and indicated that overall RPP implementation remained effective to ensure compliance with 10 CFR Part 20.

(7) ALARA Policy A policy for maintaining radioactive exposure to personnel As Low As Reasonably Achievable (ALARA) was outlined and established in Rules and Procedures for Users of Radioactive Material at the Pennsylvania State University. RSEC implementation of the policy is as described in AP-16, PSBR Alara Procedure. The procedure discussed and set expectations for radiation safety culture and provided guidance for keeping doses ALARA, consistent with the requirements in 10 CFR 20.1101, Radiation Protection Programs, and TS 3.6.4, As Low As Reasonably Achievable (ALARA).

(8) Environmental Monitoring and Effluents The inspector reviewed the calibration records of the air monitors and area radiation monitors. These systems were channel checked daily, channel tested monthly, and calibrated annually in accordance with TS 4.6.1,

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Radiation Monitoring System and Evacuation Alarm. During the inspection, the inspector observed both of these systems operating while the reactor was in operation, as required.

The inspector reviewed the annual reports and records documenting solid, liquid, and gaseous releases to the environment. No uncontrolled solid releases occurred under the reactor license during the time period reviewed.

As discussed in the Transportation section of this report, the licensee contracted with a waste broker to ship various types of solid radioactive waste resulting from the 2018 RSEC Pool Project. The inspector noted that solid waste activity was adequately documented on the appropriate forms.

No planned or unplanned liquid releases occurred under the reactor license during the time period reviewed. The inspector noted that liquid radioactive waste from RSEC laboratories are controlled under the broad scope license and transferred for disposal with waste from other campus laboratories. The inspector determined that gaseous release activity continued to be calculated and the results were adequately documented. The releases were determined to be within the concentrations specified in Appendix B to 10 CFR Part 20, Annual limits on intake (ALIs) and Derived Air Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage. To demonstrate compliance with the annual dose constraints of 10 CFR 20.1101(d), the licensee used a methodology based on the National Council on Radiation Protection and Measurements Report No. 123, Screening Models for Releases of Radionuclides to Atmosphere, Surface Water, and Ground. The highest calculated dose that could be received by a member of the public as a result of gaseous emissions from reactor operations was determined to be 0.37 mr/yr for the 2017 calendar year and 0.35 mr/yr for the 2018 calendar year. This dose is well below the 10 mr/yr limit stipulated in 10 CFR 20.1101(d).

Environmental gamma radiation monitoring was conducted using dosimetry in accordance with the applicable procedures. The highest measured dose at the closest unrestricted area (i.e. fence line) was determined to be 22 mr/yr for the 2017 calendar year and 25 mr/yr for the 2018 calendar year. The data indicated that there were no radiation doses in unrestricted areas from operation of the reactor that would result in a member of the public exceeding the limit of 100 mr/yr in Subpart D, Radiation Dose Limits for Individual Members of the Public, to 10 CFR Part 20.

c. Conclusion Surveys were being completed and documented acceptably. Postings met regulatory requirements. Personnel dosimetry was being worn as required and doses were within regulatory limits. Radiation monitoring equipment was being maintained and calibrated as required. Radiation protection training was being provided to facility personnel. Calculations of effluents released from the facility satisfied license and regulatory requirements and releases were within the specified regulatory limits.

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4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)

To verify compliance with 10 CFR 50.59 and TS requirements for design changes, the inspector reviewed selected aspects of the licensees program, including:

  • Technical Specifications for Pennsylvania State University Breazeale Reactor, dated November 2009
  • Annual Operating Report for the PSBR, for the period of July 1, 2016 through June 30, 2017
  • Annual Operating Report for the PSBR, for the period of July 1, 2017 through June 30, 2018
  • RSC Meeting Minutes, from June 2017 to November 2018
  • AP-12, Change, Revision 6; dated June 17, 2011
  • AP-12 Work Package #2018-01, Tuning Blocks Update for West Bay Area Radiation Monitor
  • AP-12 Work Package #2018-02, Area Radiation Monitor (ARM) Tuning Blocks Update with New Calibration Test Points
  • AP-12 Work Package #2018-04, Core Loading 58A
  • AP-12 Work Package #2018-05, Reactor tower replacement
  • AP-12 Work Package #2018-06, Crescent D2O Tank installation
  • AP-12 Work Package #2018-07, Pool wall modification (Beam Ports)
  • AP-12 Work Package #2019-01, SOP-5, Revision 6
  • AP-12 Work Package #2019-02, SOP-1 Rev. 24
  • AP-12 Work Package #2019-04, Trip Setpoints Adjustment on Source Level Interlock b. Observations and Findings The inspector reviewed a sample of completed AP-12, Change forms and corresponding design change packages concerning facility changes since the last inspection in this area. Specifically, the RSEC conducted a major outage involving modifications to maximize utilization of the reactor through realignment of beam ports, installation of a crescent-shaped heavy water (i.e. deuterium oxide (D2O)) tank, and replacement of the reactor support structure (i.e. tower).

Based on the design change package reviews, the inspector determined that the facility design change evaluations were screened to determine if the change required prior NRC approval along with adequate supporting documentation and information. Additionally, the inspector verified that the RSC reviewed proposed changes in accordance with TS 6.2.3.a.

c. Conclusion Changes to the facility were being evaluated using the criteria specified in 10 CFR 50.59 and were reviewed and approved by the RSC as required.

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5. Committees, Audits, and Reviews a. Inspection Scope (IP 69001, Section 02.09)

To verify compliance with the TS requirements for review and audit, the inspector reviewed selected aspects of the licensees program, including:

  • Technical Specifications for Pennsylvania State University Breazeale Reactor, dated November 2009
  • Annual Operating Report for the PSBR, for the period of July 1, 2016 through June 30, 2017
  • Annual Operating Report for the PSBR, for the period of July 1, 2017 through June 30, 2018
  • RSC Meeting Minutes, from June 2017 to November 2018
  • Penn State Breazeale Reactor Safeguards Audit, dated October 2017
  • AP-6, Pennsylvania State Reactor Safeguards Committee Charter and Operating Procedure, Revision 4; dated April 20, 2006 b. Observations and Findings The composition of the RSC and the meeting frequency satisfied the requirements of TS 6.2.1, Safeguards Committee Composition, and TS 6.2.2, Charter and Rules. The minutes of these meetings demonstrated that the RSC provided the review required by TS 6.2.3. The inspector reviewed the RSC meeting minutes for the past two years and found that the RSC provided appropriate guidance and direction for reactor operations, and ensured acceptable use and oversight of the reactor. Additionally, audits of facility operations, requalification, corrective actions, and emergency planning were being performed, within specified periodicity, as required by TS 6.2.4, Audit.

c. Conclusion Review, audit, and oversight functions required by the TS were acceptably completed by the RSC.

6. Transportation a. Inspection Scope (IP 86740)

To verify compliance with the regulations in 10 CFR, Energy, 49 CFR, Transportation, and procedural requirements for transferring or shipping licensed radioactive material, the inspector reviewed selected aspects of the licensees program, including:

  • Select records, Training materials and certificates for authorized shippers
  • Select records, Radioactive material shipping paperwork
  • Select records, Uniform Low-Level Radioactive Waste Manifest (various NRC forms numbered 540, 540A, 541, 541A, 542)

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b. Observations and Findings Through records review and discussions with licensee personnel, the inspector determined that the licensee had shipped various types of radioactive material since the last previous inspection in this area. The inspector noted that the reactor facility staff performed low level (i.e. Limited Quantity) radioactive material shipping, typically of customer samples from approved experiment irradiations; other shipments were typically completed by EHS staff. Additionally, from the 2018 PSBR Pool Project outage, the inspector reviewed records from a waste shipment handled by a waste broker, Chase Environmental Group. The radioactive material shipping records and radioactive waste manifest indicated that the radioisotopes present were identified, quantities were calculated, and dose rates measured as required. The inspector noted that staff members had received training every two years and were certified for shipping radioactive material by EHS staff, as required by Subpart H of 49 CFR 172, Training. All radioactive material shipment records reviewed by the inspector had been completed in accordance with Department of Transportation and NRC regulatory requirements.

c. Conclusion Radioactive material was being shipped in accordance with the applicable regulations.

7. Exit Interview The inspection scope and results were summarized on May 1, 2019, with members of licensee management. The inspector described the areas inspected and discussed the inspection findings. The licensee acknowledged the results of the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee T. Daubenspeck Activation and Irradiation Specialist C. Davison Research and Education Specialist J. Geuther Associate Director, RSEC N. Osmond Reactor Operator S. Priya Associate Vice President for Research, Director of Strategic Initiatives B. Schmoke Senior Reactor Operator A. Tong Research and Development Manager Director, RSEC Other Personnel D. Bertocchi Health Physics Specialist, EHS D. Crandall Director, EHS Y. Guo Radiation Safety Officer, EHS G. Herman Health Physicist, EHS INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED None PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable AOP Auxiliary Operating Procedure AP Administrative Procedure CCP Checks and Calibrations Procedure EHS Environmental Health and Safety IP Inspection Procedure NRC U.S. Nuclear Regulatory Commission PSBR Penn State Breazeale Reactor Rev. Revision RPP Radiation Protection Program RSC Reactor Safeguards Committee RSEC Radiation Science and Engineering Center SOP Standard Operating Procedure TS Technical Specification(s)

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