IR 05000186/1996001

Insp Rept 30-32695/96-02 & 50-186/96-01 on 961104-08.No Violations Noted.Major Areas Inspected:Aspects of Organization,Periodic & Special Repts & Operations & Maint

ML20135F559
Person / Time
Site:	University of Missouri-Columbia, 03032695
Issue date:	12/06/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20135F549	List: IR 05000186/1996001 ML20135F547
References
30-32695-96-02, 30-32695-96-2, 50-186-96-01, 50-186-96-1, NUDOCS 9612130124
Download: ML20135F559 (23)

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U.S. NUCLEAR REGULATORY COMilSSION ,

REGION III ,

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Docket Nos: 50-186 j 030-36295

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i License Nos: R-103 '

24-00513-39 i

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Report Nos: 50-186/96001 (DNMS)

030-32695/96002 (DNMS)

Licensee

University of Missouri at Columbia Facility Name: University of Missouri at Columbia Research Reactor i Location: Columbia, Missouri November 4-8, 1996

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Dates:

Inspectors: T. D. Reidinger

J. L. Cameron T. M. Burdick Approved by

Gary L. Shear, Chief Fuel Cycle Branch

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9612130124 961206 PDR ADOCK 03032695 C PDR

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Executive Summary University of Missouri at Columbia Research Reactor Report Nos. 50-186/96001(DNHS)

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a 030-32695/96002(DNMS)

This routine, announced inspection included aspects of organization, periodic and special reports, and operations and maintenance (39745); operations and maintenance procedures (42745); requalification training (41745); surveillance (61745); experiments (69745); radiation controls (83743); environmental

protection (80745); design change, audit, and review (40745); emergency l preparedness (82745); fuel handling activities (60745); transportation activities (86740); review of licensee reports (90713); review of nonroutine 1

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events (92700); inspector identified follow up items (92701), and licensed l material program self-assessment and corrective action (87100).

Oraanization (39745)

e The organizational structure and assignment of responsibilities were as specified in Technical Specifications (T.S.). (Section 1.0) 1 Operations and Maintenance (39745) I e The reactor was operated and maintained in accordance with the reactor's i license conditions and T.S. requirements. (Section 2.0)

e The licensee's logs and records satisfactorily documented reactor operations and maintenance activities. (Section 2.0)

Procedures (42745)

e The licensee had approved procedures to safely conduct reactor operations, maintenance, experiments, surveillance testing and instrument calibrations in compliance with T.S. requirement (Section 3.0) l Reaualification Proaram (41745)

e The licensee proposed to administer future biennial requalification examinations that would not be authored or reviewed by those required to take the examinations in order to reduce administrative security requirements on the staff. (Section 4.0) ,

Surveillances (61745)

e Reactor surveillance tests had been completed and documented at the required frequen'.ies, and the surveillance test results met requirements. 'Section:5.0)

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Exoeriments (69745)

e Reactor experiments were conducted in accordance with properly reviewed and approved procedures and satisfactorily documented in the reactor operations log. (Section 6.0)

Radiation Control (83743)

e Weaknesses identified in the Health Physics (HP) training program included the lack of timeliness in the immediate notification of HP management regarding contamination events and implementation of decontamination strategies. (Section 7.0)

e The radiation protection program was effective in protecting the staff l and public. (Section 7.0)

Environmental Protection (80745)

e Airborne and liquid effluent releases were within the regulatory limit Radioactive waste accumulations were properly store (Section 8.0)

Audits and Reviews (40745)

e Reactor Advisory Committee (RAC) quarterly meetings were conducted within the specified time perio o Licensee audits addressed a variety of plant areas and processes and identified good issues. (Section 9.0)

Emeraency Preparedness (82745)

e Emergency Plan exercises and training were conducted satisfactoril (Section 10.0)

e The licensee discontinued the use of self-contained breathing apparatus (SCBA) until further review is completed. (Section 10.0)

Fuel Handlina (60745)

e Procedures for fue's handling were adequate for reactor operation (Section 11.0)

Periodic and Special Reports (90713)

e Required reports had been submitted to the NRC in accordance with requirements. (Section 12.0)

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Nonroutine Event Follow up (92700)

e The licensee's corrective actions for two reported events were comprehensive and the corrective actions implemented were adequate to prevent recurrence. (Section 13.0)

Missouri Safety Oversicht Committee (MSOC) (92701)

e The lack of additional safety issues (protected activities) either in response to solicitation by the NRC inspectors during the inspection or raised for resolution by the MSOC indicated an apparent absence of concerns regarding any potential or perceived " chilling" effects regarding protected activities on the MURR staff. (Section 14.0)

Transportation (86740)

e Radioactive material shipments were in accordance with Department of Transportation Regulations. (Section 15.0)

Part 30 License Self-Assessment and Corrective Action (87100)

e The licensee's corrective actions for a self-identified violation regarding a radioactive material shipment were comprehensive and appeared adequate to prevent recurrence. This will be handled as a Non-Cited Violation (NCV). (Section 16.0)

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DETAILS 1.0 Organization Insoection Scope (39745)

The inspectors reviewed Technical Specifications (T.S.) and the Safety Analysis Report (SAR) related to organization and staffin Observations and Findinas

The inspectors determined that the organizational structure and !

assignment of responsibilities were as specified in T.S. !

Mr. McKibben has been appointed as interim Director of the I facility. Dr. Rhyne (former Director) has been reassigned as l Program Coordinator for Neutron Material Science. The membership of the Reactor Advisory Committee (RAC) was in accordance with T.S. and the SA Through log reviews, the minimum staffing requirements were i verified to have been met during reactor operations and weekly I

refueling activitie Facility Tour The control room, pool floor, mezzanine levels, basement and tank rooms, pipe tunnel, cooling water towers, and the beam port floor ;

areas were adequately illuminated and generally clea Potentially contaminated tools and equipment were properly hagged and stored. Fire extinguishers in these areas and throughout the laboratory had appropriate pressures and current inspection date Conclusions Compliance with T.S. requirements and observed reactor facility material conditions were goo .0 Operations and Maintenance Activities Inspection Scope (39745)

The inspectors reviewed the reactor operations and maintenance logs and observed ongoing reactor operations to determine compliance with Operating License Condition 3.A. and the requirements in T.S. 2.0 and T.S. Qhservations and Findinas The licensee had operated the reactor at steady state thermal power levels in accordance with Operating License Condition The inspectors verified that the reactor safety limit had not been exceeded and was in compliance with T.S. .. . .. _ . _ ._. . _ _ . _ _ _ . _ _ _ . . ._ _ _ _ _ _ _ .

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! Selected reactor operator logs from November 1995 through September 1996 were reviewed. The operator logs were well maintained. The operators appeared proficient, demonstrated good procedural compliance, and made appropriate log entries for the observed evolutions. Reactor management oversight during an observed reactor startup was effective in assuring accurate prediction of the estimated critical rod position using the

1/M metho The inspectors accompanied operators conducting facility surveillance patrols and observed a safety conscious and professional attitude. The inspectors also observed insertion and removal of material into and out of the reactor experimental

facilities from the pool bridge. The operators were meticulous in

manipulations performe The inspectors noted that ongoing maintenance activity in the cooling towers appeared to be conducted in an acceptable manne The licensee developed and maintained a machinery history which included the events described in Section 13. The inspectors noted

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that the event reports submitted to the NRC were more detailed and i specific than the machinery history documentation.

The licensee is planning to develop a maintenance program for the i facility cranes in the near future.

' Conclusions The reactor was operated and maintained in accordance with the

! reactor's license conditions, safety limits and limiting i conditions for operation. The licensee's logs and records j satisfactorily documented reactor operations and maintenance activities. Operators were observant and systematic in both

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operations and maintenance activitie .0 Procedures Inspection Scope (42745)

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The inspectors reviewed the licensee's written procedures for i operating and maintaining the reactor, performing surveillance

. activities, conducting experiments, and shipping radioactive i materials to determine compliance with the requirements in

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T.S. Observations and Findinas The inspectors noted that some shipping procedures' text did not always provide definitive guidance. In some cases, the '

accompanying flow diagrams and check sheets adequately compensated for the text ambiguity. The licensee agreed to review their procedures for clarit i

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. Conclusions The licensee had approved procedures _to sufficiently conduct reactor operations, maintenance, experiments, surveillance testing, instrument calibrations, and shipping in compliance with T.S. requirement .0 Requalification Training Inspection Scope (41745)

The inspectors reviewed the reactor operator requalification training program to determine compliance with the requirements in 10 CFR 19.12 and 10 CFR 55.5 Observations and Findinas The program had established requirew nts for ensuring that operators maintain their licenses including attending training, ,

performing a required number of reactivity manipulations, and l passing biennial written examinations and annual operating

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evaluations, medical qualifications, and remedial training, if require !

Although the licensee approved program allowed for any single licensed MURR staff member to author any one of the examination sections, the licensee has committed to administer future examinations that had not been authored or reviewed by anyone required to take the examinations to reduce the administrative security burden of the operating staff. The licensee's proposed action will be reviewed in a future inspection (IFI 50-186/96001-01).

The licensee's required records were retained for six years which coincided with 10 CFR 55.59 requirements. However, their approved i program stated that only a two-year retention period was required. l The licensee agreed to change their program to be consistent with l their practice and the regulation I Conclusions An adequate training program was being conducted. Adequate training records were being maintained. One IFI was identified regarding the development of the requalification examination .0. Surveillances Inspection Scope (61745)

The inspectors reviewed selected surveillance test documentation and observed activities to determine compliance with the !

requirements in T.S. . _ __ _ _ _ _ _ __ . _ _ _ _ _ . . . _ .

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. Observations and Findinas Reactor safety related surveillances reviewed were conducted at the required periodicity. The inspectors observed surveillance SOP /A-8, Routine Patrol; SOP /A-6, Startup Nuclear Data; and SOP /A-5, Process Dat Conclusions Reactor surveillance tests had been completed and documented at 4 the required frequencies, and the surveillance test results met l T.S. requirement .0 Experiments Inspection Scooe (69745)

The inspectors reviewed the licensee's program to control and :

conduct experiments performed in the reactor to determine i compliance with the requirements in T.S. 3.6 and ; Observations and Findinas The inspectors observed the insertion and withdrawal of commercial silicone material from the irradiation facilit Experiments were conducted.in accordance with written procedures which were approved and properly documented as required by Conclusions Reactor experiments reviewed were conducted in accordance with I properly reviewed and approved procedures and satisfactorily 4 documented in the reactor operations lo .0 Radiation Control Inspection Scope (83743)

The inspectors reviewed the radiation protection program to determine compliance with the requirements in 10 CFR Part 20 and T.S. 3.4, 3.6, 3.7, 5.1, 5.4, and Observations and Findinas Area radiation monitors and portable instruments were calibrated as required, although the inspectors noted limitations on the capability of the stationary portal monitor and hand / foot monitor

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to detect low energy beta particles from calcium-45. The inspectors reviewed the documentation regarding a personnel contamination event that occurred during the week of May 6, 1996, that involved a broken quartz vial of Ca-45 (2.2 Curies) powde . - - - - - - - - - -.--.- - _ .-.. -- ----

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i' On May 7,1996, the hot cell operator opened a capsule containing

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a quartz vial and found that the vial was broken inadvertently either by irradiation or handling in the hot cell. The hot cell 4 operator conducted a decontamination cleanup in the cell. On May 8, 1996, the HP technician took smears (swipes) on the hot

' cell work surfaces and on the sample pigs removed from the hot !

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cell to an Eberline Model BC-4 beta counter. The sample pigs were '

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found to be contaminated and were subsequently decontaminate Follow-up smears from the sample pigs taken to the BC-4 instrument indicated no contamination evident. However, the HP technician

was concerned about the sensitivity of the BC-4 to measure the low 1

energy beta radiation from Ca-45. The HP technician then took the '

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smears from the basement to the HP counting room (located on the i first floor) which contained a more sensitive smear counting i instrument. The smears indicated significant contamination still l present on the sample pig ,

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Subsequently, the HP technician notified the assistant HP manager l who immediately directed the basement area to be roped off and !

initiated actions to perform personnel surveys on all individuals who were working in the basement. Contamination was found on i

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one individual's pant leg and on the wrist of another individua l 4 The highest dose (beta) analyzed was 6 Rems (.06 sievert) which was significantly less than the regulatory limits for extremities (50 Rems) (.50 sievert). The individuals were satisfactorily decontaminated. Decontamination efforts were satisfactorily

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conducted in the basement and hot cell.

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The licensee subsequently determined that the BC-4 instrument was j not sufficiently sensitive to Ca-45 due to the presence of a t plexi;bss shield (which significantly attenuated the low energy l' beta radiation) installed between the detector and the smears).

The licensee conducted an investigation regarding the installation of the plexiglass shield and the results were inconclusive on when it was installed and by whom. The plexiglass shield was ;

immediately removed from the BC-4 instrumen The inspectors asked whether the hand and foot monitor located at l the basement entry way on the first. floor detected any

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contamination on the two (contaminated) individuals who exited the basement on May 8, 1996. The licensee indicated that since the area of contamination on the underside of the wrist of one of the contaminated individuals was effectively outside the geometry of the detector in the hand portion of the hand and foot monitor, that in their opinion, no alarm would have sounded. In addition, the hand and foot counter could not detect the contamination on the pant leg because the monitor was designed for hand and foot contamination detection onl The NRC requested that the licensee conduct a test of the hand and i foot counter, in addition to a test of the exit portal monitor ;

located at the front door of the facility (lobby area) using the '

appropriate or equivalent source for Ca-45. The licensee determined that the hand and foot counter would detect a hand

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O contamint. tion due to the multiple detectors but would not detect a foot contamination. The licensee indicated that the efficiency of the foot monitors was approximately half that of the hand monitors. The portal monitor tested in the lobby could not detect Ca-45 contamination. The licensee's review of smears taken on May 7 and 8, 1996 indicated no contamination present in the lobby are The inspectors conducted a chronological review of the HP technician's actions after he mentally questioned the sensitivity and accuracy of the BC-4 beta counter. Although the recognition of the problem with the BC-4 counter appeared to be timely, the assistant HP manager was not aware of any perceived problem regarding the BC-4 counter until the HP technician exited the basement and counted the smears on a different counter. As a result, it appeared that between recognizing the counter problem on the smears and notifying management, a small amount of Ca-45 contamination (powder) was unknowingly being spread by different individuals working in the basement, resulting in some decontamination efforts. There was no contamination evident on the exit pathway used by the HP Technician to the first floor counting room from the basemen Although the doses received during the event and subsequent decontamination by the MURR HP staff were below regulatory limits, it appeared that'the ALARA. philosophy was challenged unnecessarily by the lack of recognition of the significance of the contamination even Weaknesses in the HP training program identified during this event review, which included the lack of timeliness in the immediate notification of HP management for a broken vial in the hot cell and potential decontamination strategy prior to exiting the affected area are identified as an inspection follow-up item (IFI No. 50-186/96001-02).

Postings, labeling, and surveys met regulatory requirements as observed on the tour of the reactor laborator The facility had identified and was attempting to correct a recurring problem with metal staples (used to close the bags containing topaz). They were inadvertently being commingled with ;

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topaz by the MURR topaz sorting staff, becoming irradiated during the topaz exposure process in the reactor, and then inadvertently getting placed into the clean trash by the topaz sorters'. The inspectors surveyed the clean trash stored outside the facility and found all readings at background levels. The facility has posted large caution signs in the topaz sorting area to place all foreign material into specially designated receptacles for HP ,

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The licensee employed a special beam port batch liquid disposal ;

procedure to ensure that the radioactive effluent drained from the !

beamports after maintenance and repair was under strict HP

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control. The liquid drainage was placed in properly stored

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be handled as radioactive waste.

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The inspectors observed good management corrective actions when

two university craft workers entered the cooling tower basement for maintenance without following proper radiological procedures for a posted radiation area.

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staff and public. A training deficiency was identified regarding

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the immediate notification of a contamination event and related cleanup activitie i Environmental Protection Inspection Scope (80745)

3 The inspectors reviewed the licensee's program for the discharge or removal of radioactive liquid, gases, and solids from the reactor laborator Observations and Findinas All sewer discharges reviewed were within regulatory limit Airborne effluent monitoring records reviewed for 1995-1996 indicated that the releases were within the regulatory limit The COMPLY code input data for radionuclide emissions from the reactor laboratory appeared to be within regulatory limit The licensee had a large backlog of stored solid radioactive waste due to the temporary Barnwell facility closure. The inspectors i determined that the solid radioactive waste was properly stored l and posted as required prior to the anticipated shipment to Barnwel Conclusions Airborne and liquid effluent releases and solid waste disposal were within the regulatory limit .0 Audit and Reviews Insoection Scope (40745)

The inspectors reviewed the meeting minutes, audits and reviews conducted by the Reactor Advisory Committee (RAC), Reactor Safety Subcommittee (RSS), and the Reactor Procedures Subcommittee (RPS)

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i 4 Observations and Findinas The inspectors reviewed one independent external safety review

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audit of the facility operation, and audits of the Radiation Protection Program, the Alara Program, the Type A Radioactive Material Shipping Program and the Type B Radioactive Material

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Shipping Program. In general, the audits were well documented and

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the responses to items identified in the audits appeared to have been addressed or were actively being processed accordingly. The external safety review audit conducted in May 1996 was initiated

by the licensee to evaluate reactor operations and HP program

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management. The licensee allowed the audit team a free hand to widen its scope and focus to include a diverse number of MURR

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staff topic areas. The licensee has planned to submit to the RAC and the RSS a management response to issues raised by the external safety review audit report. (See Section 14)

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RAC meetings were conducted as required by T.S. Licensee management provided external auditors' freedom to pursue all possible areas of concern and is taking steps to adopt resolutions where necessar .0 Emergency Preparedness Inspection Scope (82745)

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The inspectors reviewed the emergency plan for the reactor laboratory to determine compliance with the requirements in

10 CFR 50.54(q) and (r)..

! Observations and Findinas i The RAC review of the audit of the emergency plan and procedures l was appropriately documented in the RAC meeting minutes and met l

the requirements in T.S. !

. The inspectors reviewed the documentation related to an emergency i drill held in 1995. Concerns identified by the inspectors included the use of self-contained breathing apparatus (SCBA) for ;

fire mitigation and search and rescue operations by unqualified l MURR staff. Interviews with MURR staff indicated that they felt i that training for SCBA use could be improved, in addition, the '

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staff indicated that there was no medical certification required prior to their use of the equipment. Discussions with the I licensee indicated there was no training or fit-testing program ;

implemented at the facility. The licensee immediately l discontinued the use of.SCBA by MURR staff until they decide whether they will implement a training and fit-testing program for SCB !

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4 Record review by the inspectors verified that the operators were '

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trained in the emergency plan and procedures and had participated i in the dril l

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No significant changes in the Emergency Response Organization were

note c. Conclusions ll Review of emergency equipment and supplies, changes to the

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emergency plan, and documentation relating to emergency drills as well as interviews indicated that the licensee's emergency program

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was maintained in a state of operational readiness. The future I use of SCBA by MURR staff for fires will be reviewed by the license .0 Fuel Handling

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a. Inspection Scone (60745)

The inspectors reviewed the fuel handling procedures and records at the reactor laboratory to determine compliance with T.S. and 6.1, and DOT regulation b. Observations and Findinas The facility fuel handling program review included the verification of procedures for fuel handling and the technical

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adequacy in the areas of criticality safety and T.S.. Records review and discussions with personnel indicated that fuel handling operations had been carried out in conformance with the licensee's procedures. Log entries and fuel location maps for fuel handling activities were appropriately documente c. Conclusions Procedures for fuel handling were technically adequate for reactor operations. Fuel shuffles were conducted without inciden .0 Review of Periodic and Special Reports Inspection Scone (90713) l l

The inspectors reviewed the licensee's submittal of reports and notifications to the NRC to determine compliance with the requirements in T.S. 6.1.

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b. Observations and Findinas The 1995 annual report had been submitted in a timely manner and contained the information required by '

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4 Conclusions Required reports had been submitted to the NRC in accordance with T.S. requirements.

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13.0 Nonroutine Event Follow up j Insoection Scope (92700)

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The inspectors followed up on licensee actions to verify adequate determination of cause and corrective action.

{ Findinas and Observations  !

3 (Closed) Violation 50-186/95003-01: The failure to conduct

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contamination surveys on lead " pigs" prior to their unrestricted release. Corrective actions were adequat (Closed) LER 50-186/96-001: Regulating blade drive failure. The

! licensee's analysis and corrective action appeared to minimize the recurrence of premature bearing failures with a periodic bearing replacement progra <

(Closed) LER 50-156/96-002: Emergency diesel generator cooling '

water pump shaft failure. The licensee determined that premature  ;

failure occurred due to a defective shaft. Corrective actions were adequat ,

I Conclusions The licensee's approach to review, analysis and corrective action was appropriat .0 Missouri Safety oversight committee Organization Inspection Scope (92701)

The inspectors conducted a selective review of the MSOC organization; process controls; tracking system; management initiatives to support the MSOC; and feedback to employees on the  !

resolution of their concerns. In addition, the inspectors l followed up on the completed corrective actions and initiatives that were committed by the university to promote an environment i that would encourage the raising of safety issues and to ensure  ;

that corrective actions related to chilling effects were i implemented by the university in a timely manne ;

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.. Observations and Findinas MURR Safety Oversiaht Oraanization The MURR safety oversight organization consisted of a first

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tier Safety Concern Subcommittee (SCS) and a second tier

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MSOC. Generally, safety concerns were first submitted to the local SCS for resolution. Generic safety concerns that were clearly facility-wide in nature, were submitted

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directly to the MSOC for resolutio ;

Seven SCSs were established across all the reactor facility staff divisions with each SCS selecting a local representative who also served as a general member on the MSO Generally, the local representatives appeared

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proficient in responding to and dispositioning employee

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concerns and had sufficient training in order to accomplish their MSOC responsibilities. The local representatives also had the authority to obtain any information pertinent to investigating and dispositioning safety concerns and had access to any individual in the MURR organization for such information. Further, they had the authority to assign

, responsibilities for the investigation and disposition of employee concerns to any individual in the MURR organization. It was the expectation of MURR management

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that the MSOC would review and disposition employee

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discrimination challenges and complaints related to protected activities that were submitted. MURR management

provided train W to strengthen the safety oversight process to all MSOC representatives in the area of discrimination issues and protected activities.

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The system was designed to provide an anonymous reporting option, an evaluation of the employee's concern, and l resolution and feedback to affected personnel. The inspectors evaluated management support and initiatives to support implementation of the MSOC, process controls to

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disposition employee concerns and protect employees from retaliation, and feedback to employees on the status and ,

resolution of their concerns. During the inspection, the !

disposition and documentation of approximately seven employee concerns reported since the initiation of the MSOC i was reviewe . MSOC Process Controls  !

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Good administrative controls were in place to inform employees of the existence of and how to use the MSOC. The

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facility newsletter appeared to be a good initiative for i

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e communicating in a timely manner with the facility staf The newsletter discussed a number of topics such as research at the facility, staff changes, and policy issue Past newsletters discussed the formation of the MSOC and also ;

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informed on how they use the MSOC during initial MURR indoctrination. The purpose and workings of the MSOC process were reviewed by MURR facility employees during the annual MURR indoctrination session. Appropriate forms used to submit concerns to the MSOC were displayed at various locations at the MURR facility, i.e., bulletin board in the lobby of the reactor facilit Since late 1994, a revised indoctrination brochure that included a description of 10 CFR 50.7 regulations addressing protection from discrimination resulting from reporting safety concerns was mailed to each individual granted access to the MURR facilit The MSOC allowed employees to report concerns through personal interviews, by telephone and electronic mail, and by submitting concerns on forms that were available at accessible locations through designated drop boxes at the MURR facilit The local SCS representative determined the best method to investigate and resolve concerns. Investigations included determination of the validity of the concern, cause, and corrective action. The disposition of concerns was reviewed and approved by the SC Generally, employees received written responses on the disposition of their concerns and were given an opportunity to question or appeal the resolution. Controls were in place to protect the identity of employees who wished to remain anonymous. The SCS representatives used appropriate interviews and surveillance or audits that were already in process to investigate concerns so as not to draw attention to a particular topic and the identity of the employee raising the concern (fingerprinting). If an employee had no objection to being l identified, his or her identity may have been disclosed, if necessary, on a need-to-know basi . Manaaement Sucoort of MSOC MURR management was committed to maintaining a strong MSOC and actively supported the process. Since the establishment of the MSOC, MURR facility employees received either letters, memos from MURR management, or access to the Reactor Advisory Committee meeting minutes addressing the ,

regulations, policies and procedures regarding employee i concerns, why employee concerns should be identified and resolved, and methods available to raise concerns. Other pertinent communications from management to employees ;

included a restatement of management's policy of no !

tolerance for retaliation against employees for raising ;

safety concerns and informal periodic meetings where :

employees had the opportunity to discuss methods available to identify any safety concerns, and regulations and policies regarding protected activitie :

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1 5. MSOC Trackina System

Contacts between the university employees and their local '

representative resulted in approximately seven formally documented employee concerns since the inception of the committee. The employees identified the following general concerns: 1) audibility of the alarm system in certain areas of the facility; 2) use of respirators; 3) emergency procedures; 4) management evaluations; 5) smoking; 6) laboratory dress code; and 7) External Safety Review Committee report. All concerns appeared to have been addressed or were actively being processed accordingly except for the last concern. The MSOC was not kept informed in a timely manner regarding either the initiation of the safety review to be conducted by the External Safety Review Committee (ESRC) composed of three staff members from other non-power reactors or the ESRC issued report. MURR management made limited distribution of the ESRC report initially but once concerns were raised by MURR staff, the report was made available to all interested parties. The licensee has planned to provide a written response to address the recommendations made by the ESRC to the RAC and the RSS in December 199 . Timely Feedback to Emoloyees The SCS representatives formally acknowledged receipt of employee concerns and periodically updated the employees on !

the status of their concerns, irrespective of the period taken to resolve the concerns. They generally acknowledged (by letter) if the individuals were known or by posting the acknowledgment in the MURR facility display case in the event of an anonymous repor . Reaulatory Responsibilities of MURR Manaaers Interviews were conducted with selected MURR managers which determined that they fully understood their responsibilities under the NRC license, their obligation to perform their duties in compliance with NRC regulations and license requirements, and their responsibilities regarding the right of individuals to raise safety concerns without fear of retaliation or discriminatio . Corrective Actions (92702)

Review of the university corrective action initiatives indicated that all the corrective actions were essentially completed. .Some of the corrective actions included:

1) the use of outside consultants for the assessment of any potential " chilling effect" of personnel actions or any real

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2) revisions to the annual radiation indoctrination training that reinforced the importance of raising safety concerns

and how that can be done internally and externally.

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i Based on a review of selected areas of the MSOC program, the

! MSOC process was adequately implemented and was considered

! adequate in providing MURR facility employees a method to address general safety concerns while preventing potential retaliation. MURR management strengthened the MSOC process

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for addressing and dealing with discrimination challenges (protected activities) from MURR facility employees. In general, employee concerns were formally received and

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dispositioned. Process controls were established to provide

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employees timely feedback on the status of their concerns and formal guidance was established to ensure each safety

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concern received an independent review. In general, MURR managers understood their obligation to perform their duties in compliance with NRC regulations and license requirements regarding the right of individuals to raise safety concerns without fear of retaliation or discrimination. Although the willingness of employees to use the MSOC was not assessed, the lack of any other safety issues (protected. activities)

either identified by the NRC inspectors or submitted by the MURR staff during the inspection or raised for resolution by the MSOC indicated an apparent absence of concerns regarding any potential or perceived " chilling" effects regarding protected activities on the MURR staf .0 Transportation of Radioactive Materials Inspection Scone (86740)

The inspectors reviewed the licensee's radioactive materials shipping program for compliance with the requirements in Department of Transportation (DOT) and NRC regulations, 49 CFR Parts 170 through 177 and 10 CFR Part 71, respectivel Observations and Findinas The inspectors observed the reactor laboratory staff prepare various packages for_ shipping during all phases of preparation and handling without inciden Conclusion Radioactive shipments were conducted in accordance with D0T regulation . - - - - -- . --.

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I 16.0 Broad Scope Licensed Activity Insoection Scone (IP 87100)

The broad scope inspection included a review of the licensee's program for self-assessment of licensed activities and implementation of corrective actions for licensee-identified findings. The review focused on two active licensee

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authorizations, ML-4, " TRUMP-S, Transuranic Management by Pyropartitioning Separation" and ML-18, " Receipt of Radioactive

, Material . " The inspectors reviewed selected procedures and representative records, observed activities in progress, and interviewed licensee personnel. In addition to reviewing the '

two specific licensee authorizations, the inspectors reviewed a licensee-initiated external assessment utilizing radiation safety program personnel from two other Missouri University campuses, Rolla and Kansas Cit Observations and Findinas TRUMP-S (Transuranic Manaaement by Pyrocartitionina Separation). l

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In accordance with previous licensing commitments, the licensee !

performed quarterly evaluations of activities conducted under this ;

materials authorization. Based on the inspector's review of l recent review reports, those reviews appeared to focus on material

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accountability, changes in personnel assigned to the project, and

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selected HP procedures. The previous reviews have not typically resulted in the identification of any findings requiring licensee i follow up. However, during the last review, transmitted to the l Health Physics Manager on October 8,1996, the reviewer identified

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discrepancies in the material accountability logs maintained for l

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this project. The HP reviewer noted an apparent error in the ;

assigned activities of radioactive isotopes that were logged in a waste bag, No. T-144.

Prior to each investigational exercise, the researcher began with a small quantity of material (americium-241, neptunium-247,

plutonium-239, or uranium-238 of one gram or less, total) taken from a stock batch. During the experiment, the material was further divided into smaller quantities. The researcher had some idea of the quantities that went into each of the subdivided units, but there remained some experimental uncertainty.

Following completion of each experiment, the waste materials were i bagged, the quantities of each isotope were estimated and noted on a waste log, and the bagged wastes were placed into a waste dru l All of the wastes from one experiment did not necessarily go into the same ba Following the completion of one experiment, some wastes were placed in bag No. T-144 and the researcher estimated that the bag contained 61.3 nanocuries (2.39 kBq) of uranium-238. Bag

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No. T-144 was one of two shipments made to an analytical :

laboratory in Utah. The bag was sent to that laboratory for analysis of the hazardous, non-radioactive content, mainly cadmium and silver, in order to properly characterize it for a planned, future radioactive waste shipment for burial. From the l information contained in the researcher's log, the material was l prepared for shipment to the laboratory as an excepted package of '

limited quantity, in accordance with DOT regulation Following the identification of errors in the material accountability log, the HP reviewer notified the HP Manager, who then contacted the research project leader. From their investigation, the licensee determined that the package that was sent to the Utah laboratory on October 4,1996, actually contained ,

40 nanocuries (1.56 kBq) of uranium-238 and 80 microcuries l (3.12 MBq) of plutonium-239, or approximately 5 milligrams. The D0T limit for plutonium-239 in an excepted package of limited quantity was 5.41 microcuries (211 kBq). Because the amount of plutonium-239 in the package exceeded the limited quantity, the licensee was required to ship the material in a Type A package and meet all of the D0T requirements for shipping papers, marking and labeling of packages, and package certification and testing. The licensee's failure to properly prepare, describe and classify the package for shipment is identified as a violation of 49 CFR 17 l The actual safety impact to the public was minimal. The l pre-shipment surveys conducted by the licensee confirmed that external radiation levels were less than 0.5 millirem per hour (5pSv). When the licensee discovered that the package contained l plutonium-239, they immediately contacted the laboratory to whom the package had bean sent. Personnel at the laboratory indicated that the facility was authorized to possess plutonium-239 and that the amount in the shipment did not affect the way that the samples ;

were handle Following this incident, the licensee initiated corrective actions to prevent a recurrence. The main action implemented required that all wastes from a single experiment were to be placed in one waste bag. In that way, all materials that went into the experiment would come out together in the waste bag and

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experimental errors would not likely result in accountability errors. Because the licensee identified the violation for the improperly prepared shipment and because the licensee initiated

corrective actions that appeared to be adequate in scope and were i timely, this violation is being treated as a Non-Cited Violation (NCV), in accordance with the NRC Enforcement Policy, contained in NUREG-1600, c. Receiot of Radioactive Materials. ML-18 The inspectors reviewed the licensee self-assessments for the materials authorization that addressed the receipt of radioactive materials for use at the MURR facility. A majority of the materials received under this authorization consisted of gold-198

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and iridium-192, as seeds used in medical brachytherap Following receipt, the seeds were transferred to the research reactor licensee for further irradiation to increase their activity. The seeds were then returned to a supplier, who in turn i distributed the seeds to medical facilities for patient us Licensed activities conducted under this authorization were limited to the receipt of the package at the MURR loading dock and !

the conduct of receipt surveys. The seeds were then transferred ,

to the research reactor at the reactor bridge and further handling I

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was conducted under the license issued to the reacto i Reviews of this authorization had been conducted quarterly and l focused mainly on the processing of receipt records and the conduct of the receipt surveys. The reviews had not previously identified any significant findings requiring licensee follow u Conclusions The licensee's self-assessment program for activities conducted under the MURR materials broad scope appeared to be effectively implemented. The inspection identified one violation regarding an improperly prepared package that was shipped on October 4,199 However, through the self-assessment process, the violation had been identified by the licensee and timely and effective corrective actions implemented prior to this inspection. As such, this violation was identified as a Non-Cited Violation (NCV), in accordance with the NRC Enforcement Policy, NUREG-160 ;

17.0 Persons Contacted University of Missouri l Elaine Charlsen* University of Missouri Associate Provost I Charles McKibben* MURR Interim Director ,

Walt Meyer* MURR Reactor Manager !

John Ernst* MORR HP Manager Steve Gunn* MURR Services Manager The inspectors also contacted other supervisory, technical and administrative staff personne * Denotes those attending the exit meeting on November 11, 1996.

18.0 Exit Interview (30703)

The inspectors presented the inspection results to members of the licensee management at an exit meeting on November 11, 1996. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary. No proprietary information was identified.

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Inspection Procedures Used IP 39745 Class I Nonpower Reactors Organization, Logs, and Records IP 40745 Review and Audits IP 41745 Requalification Training IP 42745 Procedures IP 60745 Refueling IP 61745 Surveillance IP 69745 Experiments IP 80745 Environmental Protection IP 82745 Emergency Plan IP 83743 Health Physics IP 86740 Inspection of Transportation Activities IP 90713 Review of Periodic and Special Reports IP 92700 Review of Nonroutine Events IP 92701 Follow up on Inspectors Identified Problems IP 87100 Licensed Materials Program Items Opened and Closed Opened l 50-186/96001-01 IFI The licensee committed to administer written biennial requalification examinations that have not been reviewed or authored by the examinee /96001-02 IFI Weaknesses were identified in the HP training progra Closed 50-186/95003-01 VIO Failure to conduct contamination surveys prior to release of material for unrestricted use 50-186/96-001 LER Licensee corrective action on failure of a regulating blade drive mechanism 50-186/96-002 LER Licensee corrective action on failure of an emergency diesel generator water pump shaft i

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l List of Documents Reviewed Safety Analysis Report Safety Evaluation Report Reactor Operating License Technical Specifications Administrative Procedures Operating Procedures Maintenance Procedures Survcillance Procedures Shipping records and procedures Maintenance and Surveillance Records Emergency procedures Training Program Emergency Plan Dosimetry Records Training Records Various Reports List of Acronyms Used ALARA As Low as Reasonably Achievable CAL Confirmatory Action Letter CFR Code of Federal Regulations DNMS Division of Nuclear Materials and Safeguards ;

D0T Department of Transportation l HP Health Physics IP Inspection Procedure kBq Kilobecquerels MBq Megabecquerels MURR Research Reactor Facility NCV Noncited Violation NOV Notice of Violation NRC Nuclear Regulatory Comission PDR Public Document Room PM Preventive Maintenance RAC Reactor Advisory Comittee REM Radiation Equivalent Man RPS Reactor Procedures Subcomittee RSO Radiation Safety Officer RSS Reactor Safety Subcomittee SAR Safety Analysis Report TLD Thermal Luminescent Detector

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TRUMP-S Transuranic Management by Pyropartitioning Separation l Technical Specifications l pSv microSievert i

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