IR 05000156/2020202
| ML20260H076 | |
| Person / Time | |
|---|---|
| Site: | University of Wisconsin |
| Issue date: | 11/16/2020 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Agasie R Univ of Wisconsin - Madison |
| Bassett C,NRR/DANU/UARL,2405351842 | |
| References | |
| IR 2020202 | |
| Download: ML20260H076 (18) | |
Text
November 16, 2020
SUBJECT:
UNIVERSITY OF WISCONSIN - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000156/2020202
Dear Mr. Agasie:
During August 31 - September 2, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the University of Wisconsin Nuclear Reactor Laboratory. The enclosed report documents the inspection results discussed on September 2, 2020, with you, the Reactor Supervisor, and members of College of Engineering management.
This 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 activities, and interviewed various personnel. Based on the results of this inspection, no findings of significance 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). If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
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. 50-156 License No. R-74 Enclosure:
As stated cc: See next page
University of Wisconsin Docket No. 50-156 cc:
Mayor of Madison City Hall 210 Martin Luther King Jr. Boulevard Room 403 Madison, WI 53703 Chairman, Public Service Commission of Wisconsin 610 North Whitney Way Madison, WI 53707-7854 Paul Schmidt, Manager Radiation Protection Section Division of Public Health Wisconsin Dept of Health Services P.O. Box 2659 Madison, WI 53701-2659 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 Jason Timm, Assistant Director
& Radiation Safety Officer University of Madison - Wisconsin Department Environmental Health & Safety Environmental Protection and Safety Bldg.
30 E. Campus Mall Madison, WI 53715
ML20260H076 *concurred via e-mail NRC-002 OFFICE NRR/DANU/UNPO/PM* NRR/DANU/UNPO/LA* NRR/DANU/UNPO/BC*
NAME CBassett NParker TTate DATE 9/16/2020 9/16/2020 11/16/2020
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-156 License No.: R-74 Report No.: 05000156/2020202 Licensee: University of Wisconsin Facility: University of Wisconsin Nuclear Reactor Location: Madison, WI Dates: August 17 - September 2, 2020 Inspector: Craig Bassett 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 University of Wisconsin Nuclear Reactor Laboratory Inspection Report No. 05000156/2020202 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the University of Wisconsin (UW, licensee) 1 megawatt Class II research reactor safety program including: (1) organization and staffing; (2) procedures; (3) health physics, (4) design changes; (5) committees, audits and reviews; and, (6) transportation activities since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The NRC staff determined that the licensees program was acceptably directed toward the protection of public health and safety, and in compliance with NRC requirements.
Organization and Staffing The facility organization was in compliance with the requirements in the technical specifications (TSs) and staffing was adequate to support present operations.
Procedures Procedural control, review, revision, and approval satisfied the requirements specified in Section 6.4, Procedures, of the TSs.
Health Physics Surveys were completed and documented acceptably to permit evaluation of the radiation hazards present.
Postings met the regulatory requirements.
Personnel dosimetry was worn as required and doses were well within NRC regulatory limits.
Radiation monitoring equipment was maintained and calibrated as required.
Acceptable radiation protection training was provided to staff members.
The Radiation Protection and the as low as reasonably achievable (ALARA) Programs were acceptably implemented.
Effluent monitoring satisfied license and regulatory requirements.
Releases were within the specified regulatory and TS limits.
Design Changes The Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments, modification process at the facility was followed as required and no recent changes required NRC approval.
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Committees, Audits and Reviews The review and audit functions required by TS Section 6.2, Review and Audit, were acceptably completed by the Reactor Safety Committee (RSC).
Transportation Activities Radioactive materials produced in the reactor were either transferred to the campuss broad scope license and shipped under the auspices of that license or transferred to other authorized users on campus.
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REPORT DETAILS Summary of Facility Status The UW continued to operate their 1 megawatt TRIGA conversion reactor as needed in support of laboratory and lecture courses, research in the area of neutron irradiation, and the Reactor Sharing Program. During this inspection the reactor was not operated due to the current public health emergency restrictions.
1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)
To verify that the organization and staffing requirements specified in TS Section 6.1, Organization, and associated procedures were met, the inspector reviewed:
management responsibilities stipulated in the TSs staffing requirements for operation of the reactor facility organizational structure for the Nuclear Reactor Laboratory selected Operations Log Sheets, checklists, and associated forms and records for 2019 and to date in 2020 UW Nuclear Reactor (UWNR) Procedure Number (No.) 001, Standing Operating Instructions, Revision (Rev.) 18 The University of Wisconsin Nuclear Reactor Laboratory Fiscal Year 2017 - 2018 Annual Operating Report, for the period from July 2017 through June 2018, submitted to the NRC on July 16, 2018 The University of Wisconsin Nuclear Reactor Laboratory Fiscal Year 2018 - 2019 Annual Operating Report, for the period from July 2018 through June 2019, submitted to the NRC on December 6, 2019 b. Observations and Findings Through discussions with licensee representatives, the inspector determined that management responsibilities and the organizational structure at the UWNR Laboratory had not changed since the previous NRC inspection of radiation protection in April 2018 (Inspection Report No. 50-156/2018-202). The Reactor Director was responsible for all activities at the facility as stipulated in the TSs.
The Reactor Supervisor retained direct control and overall responsibility for safe operation and maintenance of the reactor. The Reactor Director reported to the Chancellor of UW-Madison through the Chair of the Engineering Physics Department as indicated in the TSs. The inspector confirmed that there were currently two full-time staff members working at the facility, the Reactor Director and the Reactor Supervisor. The inspector verified there were also four students working part-time at the facility as Auxiliary Operators and reactor operator trainees. The inspector noted they had recently taken the NRC license examinations and were awaiting the results.
Through review of records and logs and through discussions with licensee personnel, the inspector determined that the staffing at the facility was-4-
acceptable to support the current workload and ongoing activities and shift staffing was as stipulated in the TSs.
c. Conclusion The inspector verified that the licensees organization and staffing were in compliance with the requirements specified in the TSs.
2. Procedures a. Inspection Scope (IP 69001, Section 02.03)
To determine whether facility procedures met the requirements outlined in TS Section 6.4, the inspector reviewed:
selected operating and administrative procedures selected forms and checklists associated with current procedures procedure reviews and updates as documented in RSC meeting minutes UWNR Procedure No. 005, UWNR Administrative Guide, Rev. 61 the two most recent annual operating reports issued by the facility b. Observations and Findings The inspector determined that the licensee had developed procedures for the operations, tasks, and conditions listed in Section 6.4 of the TSs. The procedures were audited and/or reviewed annually and were updated as needed.
The inspector determined that the licensees procedures and checklists were acceptable for the current facility status, staffing, and level of operations.
The inspector confirmed that minor changes to procedures were reviewed and approved by two senior reactor operators (SROs) prior to implementation. These types of changes were subsequently presented to the RSC for information and were reviewed by that committee. The inspector verified that major changes to the procedures were required to be reviewed and approved by the RSC prior to implementation. The inspector determined that substantive revisions to checklists and forms were also routinely presented to the RSC for review and approval. The inspector verified that the latest revisions of selected procedures and forms went through review and approval process.
c. Conclusion The inspector verified that facility procedures satisfied TS Section 6.4 requirements and procedure reviews were completed annually.
3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)
The inspector reviewed the following to verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, and as well as-5-
with TS Sections 3.7, Radiation Monitoring Systems and Effluents, and 4.7, Radiation Monitoring Systems and Effluents:
UWNR dosimetry records for 2018 through the present radiological signs and posting in various areas of the facility Monthly Operation Summary Reports for 2018 through the present Monthly Health Physics Nuclear Reactor Audits and Reports for 2018 through the present which included survey maps annual ALARA/annual radiation safety audits, dated January 19, 2018, February 20, 2019, and January 29, 2020 calibration and periodic check records for radiation monitoring instruments UW Environmental Health and Safety (EH&S) department manual entitled Radiation Safety for Radiation Workers, 2005 Edition (available online)
various UWNR Procedure Forms including: No. 031 Procedure for Facility Familiarization, Rev. 6; and, No. 100, Surveillance Activities, Rev. 58 various UWNR Procedures including: No. 100C, Procedure for Gross Gamma Counting of Water Samples, Rev. 24; No. 109, Procedure for Liquid Waste Disposal, Rev. 28; No. 117, Air Monitor Operating Procedure, Rev. 24; No. 118, Area Radiation Monitor Operating Checks, Rev. 2; No. 171, Air Monitor Calibration and Records, Rev. 32; and, No. 177, Procedure for Use and Calibration of Health Physics Instruments, Rev. 30 liquid release records for the period from 2018 through the present airborne release records documented in the UWNR laboratory monthly operations summary reports provided to the RSC for the period from November 2018 to the present documentation of atmospheric dose calculations using the Environmental Protection Agency COMPLY program version 1.6, dated June 15, 2007, revised September 13, 2007 UWNR annual operating reports for the past 2 years b. Observations and Findings (1) Surveys The inspector reviewed monthly audits and radiation and contamination surveys of licensee-controlled areas completed by UW EH&S department personnel. The inspector also reviewed various weekly monitor checks and monthly general area radiation and contamination surveys conducted by reactor staff personnel. The inspector verified that these periodic contamination and radiation surveys were completed within the prescribed time frame required by procedure. The inspector also toured the licensees facility and interviewed staff members as well. Survey results were evaluated to ensure that established action levels was not exceeded. The inspector determined that, if items or areas were found to be contaminated, they were decontaminated and resurveyed as required.
The inspector also accompanied reactor staff members during routine radiation and contamination surveys of the controlled areas of the facility.
The inspector conducted an independent radiation survey of these areas.
The radiation levels noted by the inspector were comparable to those found by licensee staff personnel. No anomalies or problems were noted.
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(2) Postings and Notices During tours of the facility, the inspector observed that caution signs and postings were in place. The inspector determined that restrictions established for the controlled areas were acceptable for the hazards involving radiation, high radiation, and contamination and were posted as required by 10 CFR Part 20, Subpart J, Precautionary Procedures.
The inspector determined that copies of current notices to workers were posted conspicuously in various areas in the facility. The copies of NRC Form 3, Notice to Employees, noted at the facility were verified to be the latest issue and were posted as required by 10 CFR 19.11, Posting of notices to workers.
(3) Dosimetry The inspector determined that the licensee used optically-stimulated luminescent dosimeters (OSLs) for whole body monitoring of beta and gamma radiation exposure with an additional component to measure neutron radiation. The licensee also used thermoluminescent dosimeter (TLD) finger rings for monitoring beta and gamma radiation exposure of the extremities. The inspector confirmed that dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor. Through direct observation the inspector determined that dosimetry was acceptably used by facility personnel and was in accordance with facility radiation protection requirements. Through an examination of the OSL and TLD results indicating radiological exposures at the facility for the 3 past years, the inspector verified that the highest occupational doses were well within 10 CFR Part 20 limits.
(4) Radiation Monitoring Equipment The inspector determined that calibration frequency of radiation monitoring equipment met procedural and/or TS requirements and records were maintained as required. The inspector verified that the instruments that were stationed for use in the Reactor Bay and in adjacent labs was calibrated and were within the allowed calibration interval.
(5) Radiation Protection and ALARA Programs The inspector determined that the licensees Radiation Protection Program was set forth in the UW EH&S Department manual entitled Radiation Safety for Radiation Workers, 2005 Edition. The manual was available in hard copy form, as well as on-line. The inspector verified that the program included requirements that all personnel who performed work in association with radioactive material received training in radiation protection, policies, procedures, requirements, and facilities.
The inspector confirmed that the ALARA Program was also outlined and established in the aforementioned UW EH&S Department manual,
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Radiation Safety for Radiation Workers, and in various UWNR Laboratory guidance documents and procedures. The ALARA program provided guidance for keeping doses as low as possible and was consistent with the guidance in 10 CFR Part 20.
(6) Radiation Protection Training The inspector verified that people who handled radioactive material, including licensee personnel, were required to receive training in radiation protection as noted above. This was accomplished by staff members watching a video, attending a class, and successfully passing a written examination. The inspector confirmed that completion of this training by reactor staff personnel was verified by EH&S Department personnel as well as by the Reactor Director and/or the Reactor Supervisor. Radiation protection refresher training was conducted annually. The inspector verified that all reactor staff members had completed the initial and all subsequent training as required.
(7) Effluent and Environmental Monitoring The inspector reviewed the calibration records of the area radiation monitors and the stack monitoring system and verified that these systems were calibrated annually according to procedure. The weekly start-up check records for the monitoring equipment were also reviewed. The inspector determined that checks were completed as required by procedure.
The inspector reviewed the records documenting liquid releases to the sanitary sewer for the past 2 years. The inspector determined that an SRO approved liquid releases only after analyses indicated that the releases would meet regulatory requirements for discharge. The inspector also reviewed the records documenting the disposal of solid waste for the past 2 years. The inspector confirmed that solid waste was surveyed, characterized, and transferred to the UW EH&S Radiation Safety Unit for disposal. The releases and transfers were accomplished in accordance with procedure and the results of the releases and waste transfers were acceptably documented in the operating log records as well as in the Annual Operating Reports as required.
The inspector determined that on-site and off-site gamma radiation monitoring was accomplished using various environmental OSL dosimeters in accordance with the applicable procedures. The inspector verified that OSL dosimetry data indicated that doses to the public did not exceed any regulatory limits. These results were also acceptably reported in the Annual Operating Reports for fiscal years 2017-2018 and 2018-2019, as required by TSs.
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(8) Tours of the Facility During the inspection, the inspector toured the licensees facility and observed the use of dosimetry and radiation monitoring equipment. The areas were well maintained and no problems were noted.
c. Conclusion The inspector determined that the Radiation Protection and ALARA Programs satisfied regulatory requirements because: (1) surveys were completed and documented acceptably, (2) postings met regulatory requirements, (3) personnel dosimetry was worn as required and doses were well within the NRCs regulatory limits, (4) radiation monitoring equipment was maintained and calibrated as required, (5) initial and refresher radiation protection training was provided to reactor staff personnel, (6) effluent and environmental monitoring satisfied license and regulatory requirements, and (7) releases were within the specified regulatory and TS limits.
4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)
In order to verify that the reviews required by TS Section 6.2 were completed by the RSC, and to determine whether modifications to the facility were consistent with 10 CFR 50.59 guidance, the inspector reviewed:
RSC meeting minutes from November 2018 through the present records of changes and/or modifications to the facility and facility procedures documented on forms entitled, UWNR Modification Checklist, Safety Screening, and Safety Evaluation UWNR Procedure No. 005, UWNR Administrative Guide, Rev. 61 UWNR Procedure No. 019, Changes, Tests, and Experiments, Rev. 4 UWNR Procedure No. 020, UWNR Modification Checklist, Rev. 2 various Experiment Modification Questionnaire forms documenting proposed changes to experiments UWNR annual operating reports for the past 2 years b. Observation and Findings Through review of applicable records and interviews with licensee personnel, the inspector determined that various modifications and new or modified experiments were forwarded to the RSC for approval since the last NRC inspection. The inspector verified that the licensee was following their established change control and modification program and that the required reviews and approvals of the changes or modifications were completed by the RSC prior to implementation.
The licensee determined that, although three of the proposed changes had required a safety evaluation, none met the criteria of 10 CFR 50.59(c)(2)
paragraphs (i) through (viii) which would require NRC approval of the changes.
The inspector concurred with this determination.
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c. Conclusion The inspector determined that the licensees 10 CFR 50.59 process for reviewing and approving changes at the facility was followed and no recent changes required NRC approval.
5. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)
In order to verify that the reviews and audits required by TS Section 6.2 were completed by the RSC, the inspector reviewed:
RSC meeting minutes from August 2018 through the present records of changes and/or modifications to the facility, experiments, and procedures audits completed by Radiation Safety Office staff personnel documented in monthly reports submitted to the RSC entitled Nuclear Reactor Audit and Report, for 2018, 2019, and 2020 audits completed by operations staff personnel documented in monthly reports submitted to the RSC entitled Monthly Operations Summary, for 2018, 2019, and 2020 annual ALARA/Annual Radiation Safety Audits of the facility Radiation Protection Program for the past 2 years completed by personnel delegated that responsibility by the RSC UWNR annual operating reports for the past 2 years b. Observations and Findings The inspector reviewed the minutes of the RSC meetings from August 2018 to the present. These meeting minutes demonstrated that the RSC had met at the required frequency and that a quorum was present. The minutes also indicated that the RSC, or a designated subcommittee, was completing reviews of those items and documents required by the TS. Through review of the meeting minutes, the inspector noted that the RSC was providing appropriate oversight and direction for the reactor.
The inspector noted that various audits were conducted of the facility in the areas of reactor operations, radiation protection, emergency preparedness, security, requalification of operators, and procedures. The inspector determined that the RSC reviewed the results of these audits as required. The radiation protection and operations audits were structured so that various aspects of the licensee's radiation protection and safety programs were reviewed on a monthly basis. The other areas mentioned above, as well as major facility documents and plans, were reviewed annually. The inspector verified that the audits and the resulting findings were adequately documented and that the licensee responded and took corrective actions to the findings as needed.
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c. Conclusion The inspector verified that the review and audit functions required by TS Section 6.2 were acceptably completed by the RSC.
6. Transportation Activities a. Inspection Scope (IP 86740)
The inspector reviewed the following to verify compliance with regulatory and procedural requirements for shipping or transferring licensed material:
selected records of radioactive material transfers for 2018 to the present various UWNR Procedures including: No. 005, UWNR Administrative Guide, Rev. 61; No. 023, Procedure for Receipt of Radioactive Material Shipments, Rev. 6; No. 100 B, Solid Waste Disposal Record, Rev. 4; and, No. 131, Production of Radioisotopes in Nuclear Reactor, Rev. 21 various UWNR Procedure Forms including: No. 100B, Solid Waste Disposal Record, Rev. 4; No. 130, Request for Isotope Production, Rev. 17; and, No. 134, Request and Authorization for Services of the UW Reactor, Rev. 3 b. Observations and Findings Through records review, the inspector determined that the radioactive material which was produced in the reactor and destined to be shipped off site, was transferred to the campus Radiation Safety Officer in the UW EH&S Department.
Material transfers were documented on UWNR Procedure Form No. 130, Request for Isotope Production, and on another form. The inspector verified that this radioactive material was then shipped by the reactor staff but under the campuss State broad scope license which was State of Wisconsin Department of Health and Family Services, Radioactive Materials License No. 25-1323-01, Amendment No. 44, expiration date July 31, 2024. The inspector reviewed the shipping forms for various shipments and determined that they were filled out correctly.
If radioactive waste was to be shipped from the reactor, the material was transferred to the UW EH&S Office of Radiation Safety and then shipped by that group under the broad scope license for disposal.
The inspector verified that both the Reactor Director and the Reactor Supervisor were qualified shippers. The inspector also verified that they had received the appropriate training and the training was current.
c. Conclusion The inspector determined that radioactive material produced in the reactor to be shipped offsite was transferred to the campus broad scope license and shipped under the auspices of that license. On occasion the material was retained at the reactor facility for use in laboratories in accordance with procedure.
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7. Exit Meeting Summary The inspection scope and results were summarized on September 2, 2020, with various members of licensee management. The inspector discussed the findings for each area reviewed. The licensee acknowledged the results of the inspection.
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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel Reactor Director N. Bolling Auxiliary Operator/RO Candidate A. Boyd Auxiliary Operator/RO Candidate C. Edwards Reactor Supervisor Z. Helgert Auxiliary Operator/RO Candidate B. Johnson Auxiliary Operator/RO Candidate Other Personnel J. Decker Senior Administrative Program Specialist and Director of Safety, Engineering Research Center Department, College of Engineering, UW D. Henderson Chair, Reactor Safety Committee, and Professor, Engineering Physics Department, College of Engineering, UW J. Rusch Environmental Health Specialist, Environmental, Health, and Safety Department, Facilities Planning and Management Division, UW O. Schmitz Associate Dean for Research, College of Engineering, UW P. Wilson Chair, Engineering Physics Department, College of Engineering, UW INSPECTION PROCEDURES USED IP 69001 Class II Research and Test Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable EH&S Environmental Health and Safety IP Inspection Procedure No. Number NRC U.S. Nuclear Regulatory Commission OSL Optically-stimulated luminescent Rev. Revision RSC Reactor Safety Committee SRO Senior Reactor Operator Attachment
TLD Thermoluminescent dosimeter TSs Technical Specifications UW University of Wisconsin UWNR University of Wisconsin Nuclear Reactor-2-