IR 05000005/2023201

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the Pennsylvania State University - U.S. Nuclear Regulatory Commission Routine Safety Inspection Report No. 05000005/2023201
ML23240A005
Person / Time
Site: Pennsylvania State University
Issue date: 11/17/2023
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Unlu K
Pennsylvania State Univ
References
IR 2023201
Download: ML23240A005 (16)
v • d • e


Text

November 17, 2023

SUBJECT:

PENNSYLVANIA STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000005/2023201

Dear Dr. Unlu:

From July 31 to August 3, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at The Pennsylvania State University Breazeale Reactor facility. The enclosed report presents the inspection results, which were discussed on August 3, 2023, with you and members of your staff, including members of the Environmental Health and Safety staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspector reviewed selected procedures and records, observed various activities, and interviewed personnel.

Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. However, since Pennsylvania State University has satisfied all of the criteria in paragraph 2.3.2.b. of the NRC Enforcement Policy, the violation is being treated as a non-cited violation (NCV). The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

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 website at https://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this inspection, please contact Michael Balazik at (301) 415-2856, or by email at Michael.Balazik@nrc.gov.

Sincerely, Signed by Tate, Travis on 11/17/23 Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No.50-005 License No. R-2 Enclosure:

As stated cc w/enclosure: GovDelivery Subscribers

ML23240A005 NRC-002 OFFICE NRR/DANU/UNPL/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME MBalazik NParker TTate DATE 9/11/2023 9/12/2023 11/17/2023

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-005 License No.: R-2 Report No.: 05000005/2023201 Licensee: Pennsylvania State University Facility: Penn State Breazeale Reactor Location: University Park, PA Dates: July 31- August 3, 2023 Inspector: Michael F. Balazik Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Pennsylvania State University Penn State Breazeale Reactor Inspection Report No. 05000005/2023201 The primary focus of this routine announced safety inspection included the on-site review of selected aspects of Pennsylvania State University (PSU, 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 activities. The U.S. Nuclear Regulatory Commission (NRC) staff determined the licensees program was acceptably directed toward the protection of public health and safety, and in compliance with NRC requirements.

One Severity Level IV non-cited violation (NCV) was identified.

Procedures

  • The inspector found that the program for procedural review, revision, control, and implementation was maintained as required by the technical specification (TS) and licensee procedures.

Experiments

  • The inspector found that the program for reviewing, approving, and conducting experiments satisfied TS and procedural requirements.

Health Physics

  • The inspector found that radiation surveys were completed and documented in accordance with the radiation protection program and satisfied regulations.
  • The inspector found that postings met regulatory requirements.
  • The inspector found that personnel dosimetry was worn to measure radiation dose and that radiation doses were within regulatory limits. However, the inspector determined that, contrary to Tile 10 of the Code of Federal Regulations (10 CFR) 20.1502, Conditions requiring individual monitoring of external and internal occupational dose, one Severity Level IV violation occurred and is treated as an NCV.
  • The inspector found that radiation monitoring equipment was maintained and calibrated as required by the TS.
  • The inspector found that radiation protection training was provided to facility personnel in accordance with the radiation protection program.
  • The inspector found that calculations of effluents released from the facility satisfied license and regulatory requirements and releases were within the specified regulatory limits.

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Design Changes

  • The inspector found that the licensee reviewed, evaluated, and documented changes to the facility using the criteria specified in 10 CFR 50.59, Changes, tests and experiments, in accordance with NRC regulatory, TS requirements, and licensee procedures.

Committees, Audits and Reviews

  • The inspector found that the review, audit, and oversight functions required by the TS were acceptably completed by the Reactor Safeguards Committee (RSC).
  • The inspector found that the RSC met as required by the TSs.

Transportation Activities

  • The inspector found that radioactive material was shipped in accordance with the applicable regulatory and procedural requirements.

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REPORT DETAILS Summary of Facility Status The PSU continues to operate the Penn State Breazeale Reactor (PSBR), a 1-megawatt Training, Research, Isotopes, General Atomics (TRIGA) 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 the Pennsylvania State University Breazeale Reactor, dated November 2009 up to Amendment No. 41
  • annual operating report for the PSBR for the period of July 1, 2020, through June 30, 2021
  • annual operating report for the PSBR for the period of July 1, 2021, through June 30, 2022
  • select administrative procedures (AP), standard operating procedures (SOP), checks and calibration procedures (CCP), auxiliary operating procedures (AOP), and special procedures
  • RSC meeting minutes from October 27, 2021, to May 9, 2023
  • PSBR Logbook 2022-1, 2022-2, and 2023-1
  • PSBR electronic maintenance logbook b. Observations and Findings The inspector observed facility personnel following procedures to complete tasks, such as SOP-2, Daily Checkout Procedure, Revision 31. The inspector found that the procedures were developed and approved in accordance with TS 6.3, Operating Procedures, and were of acceptable clarity and detail. The procedures were also revised, reviewed, and approved in accordance with CCP-18, Review of Procedures, Revision 9, and the inspector verified that operators review the training on new and revised procedures. The inspector verified that procedures in use were current and approved versions by comparing the procedures in the control room with the procedure maintained by the Associate Director of the Radiation Science and Engineering Center (RSEC). The inspector found that operating staff review updated procedures.

The inspector verified that the RSC reviewed and approved new and major revisions of procedures as required by TS 6.2.3 Review Function.

c. Conclusion The inspector determined that procedural review, revision, control, and implementation program satisfied the 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 the Pennsylvania State University Breazeale Reactor, dated November 2009 up to Amendment No. 41
  • annual operating report for the PSBR for the period of July 1, 2020, through June 30, 2021
  • annual operating report for the PSBR for the period of July 1, 2021, through June 30, 2022
  • RSC meeting minutes from October 27, 2021, to May 9, 2023
  • SOP-5, Experiment Evaluation and Authorization, Revision 7
  • SOP-11, Reactor Operation at the Beam Ports, Revision 4
  • select records, SOP-5, Experiment Evaluation and Authorization forms numbered in calendar year (CY) 2022 and 2023
  • PSBR Logbook 2022-1, 2022-2, and 2023-1
  • a sample of the experiments approved for use in CY 2022 and 2023 b. Observations and Findings The inspector verified that experiments utilizing the reactor were evaluated in accordance with TS 3.7, Limitations of Experiments, and SOP-5. 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 verified the reactor operator documented adequate information on each sample irradiated in the PSBR. The inspector verified that new experiments are reviewed and approved by the RSC as required by TS 6.2.3.

c. Conclusion Based on a review of these records, the inspector determined that experiments 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. Therefore, the inspector determined that the program for reviewing, approving, and conducting experiments implemented by the licensee satisfied TS and procedural requirements.

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, 10 CFR 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:

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  • Technical Specifications for the Pennsylvania State University Breazeale Reactor, dated November 2009 up to Amendment No. 41
  • annual operating report for the PSBR for the period of July 1, 2020, through June 30, 2021
  • annual operating report for the PSBR for the period of July 1, 2021, through June 30, 2022
  • AP-18 Radiation Protection Program Review, for 2021 and 2022
  • select records, completed AOP-4 appendix A, Daily Contamination Check and Response Procedure, from 2022 and 2023
  • select records, completed CCP-8 forms, Calibration of Air Monitors, from May 2019 from 2022 and 2023
  • select records, completed CCP-10 forms, Calibration of Area Radiation Monitors, from 2022 and 2023
  • select records, completed CCP-12 forms, Calibration of Portable Survey Instruments and Pocket Dosimeters, from 2021, 2022, and 2023
  • select records, completed Initial/Refresher Radiation Training for 2021-2022
  • select records, Annual Dosimetry Report [NRC Form 5] from Pennsylvania State University, for 2021 and 2022
  • select records, Radiation Dosimetry Report, for personnel and environmental for 2021 and 2022
  • select radiation and contamination surveys of the RSEC from 2022 to 2023 b. Observations and Findings (1) Surveys During the inspection, the inspector observed Environmental Health and Safety (EHS) staff perform radiation surveys in accordance with AOP-11 as a result of the movement of biological shielding in the Neutron Beam Laboratory. The inspector verified the results were documented on the appropriate forms and evaluated as required by procedure. The inspector verified that surveys were 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 tours of the facility, the inspector observed that postings and controls are established for radiation, high radiation, and radioactive storage areas and met the requirements of 10 CFR Part 20, Subpart J, Precautionary Procedures. The inspector confirmed that personnel complied with the signs, postings, and controls and 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-6-

The inspector observed the use of appropriate dosimetry for monitoring personnel radiation dose. The inspector verified that the dosimetry is regularly processed by an accredited vendor and that the processing technology can provide the Radiation Safety Officer with timely results. In reviewing the dosimetry records for the past 2 years, the inspector noted that the highest occupational doses were well below the limits of Subpart C, Occupational Dose Limits, to 10 CFR Part 20. 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 received exposure greater than 100 millirem (mrem) at the facility during 2021 and 2022. The inspector found that the licensee is appropriately monitoring individuals in accordance with the requirements in 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose.

Contrary to 10 CFR 20.1502, the licensee failed to monitor occupational workers for neutron dose from July 2019 to October 2022. In July 2019, the licensee changed vendors that process personnel dosimetry for the facility.

In September 2022, the licensee identified that dosimeters obtained from the new vendor that were provided to the workers only measure gamma radiation dose and lack the ability to monitor neutron radiation dose. In October 2022, the licensee assigned workers in the Neutron Beam Laboratory dosimetry that monitors gamma, beta, and neutron radiation dose. The inspector verified that several workers conducted activities in the Neutron Beam Laboratory from 2019 to 2023. In reviewing the quarterly personnel dosimetry records from 2019, 2022, and 2023, the inspector found that a few workers in the Neutron Beam Laboratory received tens of mrem per quarter, with one individual receiving 60 mrem in a quarter. The licensee assigned neutron dose to several workers exposure records, who conducted activities in the Neutron Beam Laboratory during the period of July 2019 to October 2022, based on a review of historical personnel dose records. The licensee discussed this issue with the RSC in October 2022.

The inspector determined that this violation to be a Severity Level IV violation because the lack of neutron monitoring for certain workers and the length of time the workers were unmonitored was indicative of a radiation protection program barrier. The inspector also determined that since this violation was non-willful, non-repetitive, and the licensee identified and appropriately corrected, it will be treated as a NCV, consistent with section 2.3.2 of the NRC Enforcement Policy. This violation is dispositioned as NCV 05000005/2023201-01.

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(4) Radiation Monitoring Equipment During the inspection, the inspector observed storage and use of portable survey instrumentation at the facility. During tours of the facility, the inspector verified several portable survey instruments were within the required calibration timeframe. The inspector reviewed the calibration records of the area radiation monitors, portable survey instruments, and air monitoring equipment to verify the requirements of TS 3.6.1, Radiation Monitoring Information, and TS 4.6.1, Radiation Monitoring System and Evacuation Alarm, were met. The inspector determined portable survey meters were maintained as required by Subpart F to 10 CFR Part 20.

(5) Radiation Protection Training The inspector found the initial and annual radiation protection training 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 were 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 inspector verified that 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, Radiation protection programs, paragraph (c). The inspector verified that RSEC implementation of the policy is as described in AP-16, PSBR ALARA Procedure. The inspector also noted that the procedure discussed and set expectations for radiation safety culture and provided guidance for keeping doses as low as is reasonably achievable (ALARA), consistent with the requirements in 10 CFR 20.1101 and TS 3.6.4, As Low As Reasonably Achievable (ALARA).

(7) Environmental Monitoring and Effluents The inspector verified the continuous air monitor and area radiation monitor systems were channel tested monthly and calibrated annually in accordance with TS 4.6.1. During the inspection, the inspector observed both of these systems operating while the reactor was in operation, as required by TS 3.6.1.

The inspector found no uncontrolled solid releases occurred under the reactor license during the time period reviewed. The inspector noted that liquid radioactive waste from RSEC laboratories is controlled under the broad scope license and transferred to PSU EHS for disposal with waste from other campus laboratories. The inspector verified that gaseous release-8-

activity continued to be calculated and that the results were below the 10 mrem per year limit as required by 10 CFR 20.1101(d).

The inspector verified environmental gamma radiation monitoring was conducted using dosimetry in accordance with the applicable procedures.

As a result of expansion of the Neutron Beam Laboratory, the inspector noted that three additional dosimeters were added to the fence line surrounding the facility and numerous other dosimeters were added internal to the facility. The inspector observed that environmental monitoring devices were located outside the facility, uniquely identifiable, securely mounted, and protected from the weather elements. The inspector noted the highest measured dose at the unrestricted area (i.e.,

West fence line) was determined to be 28 mrem per year for the 2021 CY and 32 mrem per year for the 2022 CY. These doses are reported in PSBR annual report to the NRC. The inspector verified that the data indicated no radiation doses in unrestricted areas from reactor operation would result in a member of the public exceeding the limit of 100 mrem per year in Subpart D, Radiation Dose Limits for Individual Members of the Public, to 10 CFR Part 20.

c. Conclusion The inspector determined that the radiation protection and ALARA programs implemented by the licensee satisfied regulatory requirements and TSs.

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 the Pennsylvania State University Breazeale Reactor, dated November 2009 up to Amendment No. 41
  • annual operating report for the PSBR for the period of July 1, 2020, through June 30, 2021
  • annual operating report for the PSBR for the period of July 1, 2021, through June 30, 2022
  • RSC meeting minutes from October 27, 2021, to May 9, 2023
  • AP-12, Change, Revision 6
  • various AP-12 work packages conducted in 2021, 2022, and 2023-9-

b. Observations and Findings Based on the design change package reviews, the inspector determined that the facility design change evaluations were screened and evaluated per 10 CFR 50.59 to determine if the change required prior NRC approval along with adequate supporting documentation and information. The inspector found that applicable procedures and drawings were updated with the design change. Additionally, the inspector verified that the RSC reviewed changes in accordance with TS 6.2.3, specification a.

c. Conclusion The inspector determined that changes at the facility were reviewed by the licensee in accordance with NRC regulations and applicable licensee administrative controls.

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 the Pennsylvania State University Breazeale Reactor, dated November 2009 up to Amendment No. 41
  • annual operating report for the PSBR for the period of July 1, 2020, through June 30, 2021
  • annual operating report for the PSBR for the period of July 1, 2021, through June 30, 2022
  • RSC meeting minutes from October 27, 2021, to May 9, 2023
  • PSBR audit performed in accordance with TS 6.2.4, Audit dated December 22, 2020
  • RCS Member Designation Letters for 2023
  • PSBR audit performed in accordance with TS 6.2.4 dated December 23, 2022
  • AP-6 Pennsylvania State Reactor Safeguards Committee Charter and Operating Procedure, Revision 5 b. Observations and Findings The inspector found the RSC meeting minutes demonstrated consistency with the committee composition, rules, and review function of TS 6.2.1, Safeguards Committee Composition, TS 6.2.2, Charter and Rules, and TS 6.2.3. The inspector verified the meeting minutes were also consistent with the requirements of the RSC charter and operating procedure, AP-6. The inspector verified that the Dean of the College of Engineering designated all members of the current members of the RSC. The inspector reviewed the audits of the facilitys conformance to procedures, requalification program, corrective actions, and emergency plan and implementing procedures were performed, within the specified periodicity and by a qualified person, in

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accordance with TS 6.2.4.

c. Conclusion The inspector determined that the RSC met once per CY, reviewed the topics outlined in the TSs, and conducted annual audits of facility programs as required by TSs.

6. Transportation Activities 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
  • annual review of the Radiation Protection Program 2022 and 2023
  • RPO-SHIP-01, Radioactive Material Receipt and Shipment Procedure, Revision 01 b. Observations and Findings Through records review and discussions with licensee personnel, the inspector determined that the licensee shipped various types of radioactive material in 2022 and 2023. 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, such as Type A shipping packages, were completed by EHS staff. The inspector verified radioactive material shipping records indicated that the radioisotopes present were identified, quantities were calculated, dose rates measured, and contamination checks performed, as required. The inspector also verified that the licensee retained the consignees possession license on file. The inspector noted that staff members received training every 2 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 were completed in accordance with the Department of Transportation and NRC regulatory requirements.

c. Conclusion The inspector determined that radioactive material was shipped in accordance with the applicable regulations and licensee procedures.

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7. Exit Interview The inspection scope and results were summarized on August 3, 2023, 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 J. Geuther Associate Director of Operations, RSEC E. Kunz Senior Reactor Operator K. Ünlü Director, Radiation Science and Engineering Center J. Crandall Director, Environmental Health and Safety (EHS)

D. Bertocchi Health Physics Specialist, EHS A. Wilmont Radiation Safety Officer, EHS J. Macatangay Assistant Radiation Safety Officer, EHS INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened NCV 05000005/2023201-01 The licensee failed to monitor certain occupational workers for neutron radiation dose from July 2019 to October 2022.

Closed NCV 05000005/2023201-01 The licensee failed to monitor certain occupational workers for neutron radiation dose from July 2019 to October 2022.

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