IR 05000186/2014201
| ML14118A076 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 05/01/2014 |
| From: | Gregory Bowman Research and Test Reactors Branch B |
| To: | Rhonda Butler Univ of Missouri - Columbia |
| J Eads, 919-219-9128 | |
| References | |
| IR-14-201 | |
| Download: ML14118A076 (23) | |
Text
May 1, 2014
SUBJECT:
UNIVERSITY OF MISSOURI - COLUMBIA RESEARCH REACTOR - NRC ROUTINE INSPECTION REPORT NO. 50-186/2014-201
Dear Mr. Butler:
From March 31 through April 3, 2014, the U.S. Nuclear Regulatory Commission (NRC or the Commission) completed an inspection at the University of Missouri - Columbia Research Reactor (Inspection Report No. 50-186/2014-201). The enclosed report documents the inspection results, which were discussed on April 3, 2014, with members of your 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 of activities, and interviewed personnel.
Based on the results of this inspection, the NRC has determined that two Severity Level IV violations of NRC requirements occurred. These violations were evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The first violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because it constitutes a failure to meet regulatory requirements that has more than minor safety significance and the violation was identified by the NRC. The NRC has concluded that information regarding: (1) the reason for this violation, (2) the corrective actions that have been taken and the results achieved, and (3) the date when full compliance will be achieved is adequately addressed in the subject inspection report. Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
The second violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. This NCV is also described in the subject inspection report. If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: (1) the Director, Office of Nuclear Reactor Regulation; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) the inspector assigned to your facility. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure(s), and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the public without redaction.
Should you have any questions concerning this inspection, please contact Johnny Eads at 301-415-0136 or by electronic mail at johnny.eads@nrc.gov.
Sincerely,
/RA/
Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
Docket No. 50-186 License No. R-103
Enclosures:
1. Notice of Violation 2. NRC Inspection Report No. 50-186/2014-201
cc w/encl: See next page
University of Missouri - Columbia Research Reactor Docket No. 50-186
cc:
University of Missouri Associate Director Research Reactor Facility Columbia, MO 65201
Homeland Security Coordinator Missouri Office of Homeland Security P.O. Box 749 Jefferson City, MO 65102
Planner, Dept of Health and Senior Services Section for Environmental Public Health 930 Wildwood Drive, P.O. Box 570 Jefferson City, MO 65102-0570
Deputy Director for Policy Department of Natural Resources 1101 Riverside Drive Fourth Floor East Jefferson City, MO 65101
A-95 Coordinator Division of Planning Office of Administration P.O. Box 809, State Capitol Building Jefferson City, MO 65101
Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure(s), and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the public without redaction.
Should you have any questions concerning this inspection, please contact Johnny Eads at 301-415-0136 or by electronic mail at johnny.eads@nrc.gov.
Sincerely,
/RA/
Gregory T. Bowman, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
Docket No. 50-186 License No. R-103
Enclosures:
1. Notice of Violation 2. NRC Inspection Report No. 50-186/2014-201
cc w/encl: See next page
DISTRIBUTION:
PUBLIC PRTB r/f RidsNrrDprPrta Resource RidsNrrDprPrtb Resource MCompton
ACCESSION NO.: ML14118A076
NRC-002 OFFICE NRR/DPR/PROB:RI NRR/DPR/PROB:BC NAME JEads GBowman DATE 4/29/2014 5/1/2014 OFFICIAL RECORD COPY
Enclosure 1 NOTICE OF VIOLATION
University of Missouri - Columbia
Docket No. 50-186 Columbia Research Reactor
License No. R-103
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted March 31 through April 3, 2014, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Title 10 of the Code of Federal Regulations Section 20.1003, Definitions, states that high radiation area means an area, accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving a dose equivalent in excess of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates.
10 CFR 20.1601, Control of access to high radiation areas, states that the licensee shall ensure that each entrance or access point to a high radiation area has one or more of the following features: (1) a control device that, upon entry into the area, causes the level of radiation to be reduced below that level at which an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates; (2) a control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; or (3) entryways that are locked, except during periods when access to the areas is required, with positive control over each individual entry.
10 CFR 20.1902(b), Posting of high radiation areas, states that the licensee shall post each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words CAUTION, HIGH RADIATION AREA or DANGER, HIGH RADIATION AREA.
Contrary to the above requirements, on May 1, 2014, the licensee failed to properly post and control access to a high radiation area. Specifically, the NRC inspector identified a tray used for Iridium seed processing which had been removed from the hot cell and bagged and placed in the corner of the laboratory building basement. This tray was found to have a radiation dose reading of approximately 1,800 milliRem/hour (mR/hr) on contact and approximately 98 mR/hr at a distance of 30 centimeters. Combined with other radioactive sources stored in the same corner of the basement, the dose rate in this area was determined to be in excess of the high radiation area criteria of 0.1 Rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. The area was not being controlled or posted as a high radiation area as required.
This has been determined to be a Severity Level IV violation (Section 6.7).
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report No. 50-186/2014-201. However, you are required to submit a written statement or
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explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a Reply to a Notice of Violation and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Director, Office of Nuclear Reactor Regulation, and a copy to the NRC inspector for the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
In accordance with 10 CFR 19.11, you are required to post this Notice within 2 working days.
Dated this 1st day of May 2014
Enclosure 2 U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.:
50-186
License No.:
R-103
Report No.:
50-186/2014-201
Licensee:
Curators of the University of Missouri - Columbia
Facility:
University of Missouri - Columbia Research Reactor
Location:
Research Park
Columbia, Missouri
Dates:
March 31 through April 3, 2014
Inspector:
Approved by:
Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
University of Missouri - Columbia University of Missouri - Columbia Research Reactor Report No.: 50-186/2014-201
The primary focus of this routine, announced inspection was the onsite review of selected aspects of the University of Missouri - Columbia (the licensees) 10 Megawatt Class I research reactor safety program, including: (1) effluent and environmental monitoring, (2) experiments, (3) review and audit and design change functions, (4) procedures, (5) radiation protection, and (6) transportation of radioactive material since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety and was generally in compliance with the NRC requirements.
Effluent and Environmental Monitoring
- Effluent monitoring satisfied license and regulatory requirements.
- Releases were within the specified regulatory and Technical Specifications (TS) limits.
Experiments
- The program for reviewing and conducting experiments satisfied TS and current procedural requirements.
- Changes/amendments to existing experiments were reviewed and approved as required.
Review and Audit and Design Change Functions
- The Reactor Advisory Committee acceptably completed the review, audit, and oversight functions required by TS 6.1.
- Design changes were reviewed and approved in accordance with TS requirements and the licensees written procedures.
Procedures
- The procedure review, revision, control, and implementation program satisfied TS requirements.
Radiation Protection
- Surveys were completed and documented as specified by procedure and were outlined in the Annual Report.
- Postings and notices generally met regulatory requirements. One violation was identified related to the control and posting of a high radiation area.
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- Staff personnel were wearing dosimetry as required and recorded doses were within the regulatory limits.
- Radiation survey and monitoring equipment was being maintained and calibrated as required.
- The Radiation Protection and As Low As Reasonably Achievable Programs satisfied regulatory requirements.
- Annual reviews of the Radiation Protection Program were being completed by the licensee as required by Title 10 of the Code of Federal Regulations Part 20.
Transportation of Radioactive Materials
- Radioactive material was generally being shipped in accordance with the applicable regulations. One non-cited violation was identified related to marking of a radioactive material shipment.
REPORT DETAILS
Summary of Plant Status
The University of Missouri - Columbia (the licensee) Research Reactor (MURR) continued to be operated in support of isotope production, silicon irradiation, reactor operator training, and various types of research. During the inspection, the reactor was operated continuously, following the weekly maintenance shutdown, to support laboratory experiments and product irradiation.
1.
Effluent and Environmental Monitoring
a.
Inspection Scope (Inspection Procedure (IP) 69004)
The inspector reviewed the following to verify compliance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Technical Specification (TS) 3.7, and the environmental monitoring program outlined in various procedures:
- Quarterly reports of environmental thermoluminescent dosimeter (TLD)
results
Results of the analyses of environmental vegetation, soil, and water samples
Liquid batch release review forms for 2013 associated with the monthly effluent as low as reasonably achievable (ALARA) environmental review summaries
MURR Reactor Operations Annual Report for the period from January 1, 2013, through December 31, 2013
b.
Observations and Findings
(1)
Gaseous and Liquid Releases
The inspector determined that gaseous releases continued to be monitored as required, were acceptably analyzed, and were documented in the annual operating reports. Airborne concentrations of gaseous releases were noted to be within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2, and the limits stipulated in the TS.
The dose rate to the public as a result of the gaseous releases was below the dose constraint specified in 10 CFR 20.1101(d).
The liquid releases from the facility to the sanitary sewer also continued to be monitored as required, were acceptably analyzed, and were documented in the annual reports. The inspector reviewed the analyses of the liquid that had been released and noted that the results indicated that the releases were within the limits specified in 10 CFR Part 20, Appendix B, Table 3.
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(2)
Environmental Soil, Water, and Vegetation Samples
The inspector reviewed the results of the environmental soil, water, and vegetation samples that were collected, prepared, and analyzed during 2013. These samples had all been collected and analyzed as required and within the timeframe established by procedure. No problems were noted.
(3)
Environmental Monitoring Using TLDs
On-site and off-site gamma radiation monitoring was completed using the reactor facility stack effluent monitor and various environmental TLDs in accordance with the applicable procedures. Review of the data indicated that there were no measurable doses above any regulatory limits.
c.
Conclusion
Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.
2.
Experiments
a.
Inspection Scope (IP 69005)
The inspector reviewed the licensees program for conducting experiments and selected aspects of the following to verify compliance with TSs 3.6 and 6.1.f:
- Listing of current experiments
Current list of reactor utilization requests (RURs)
MURR Procedure AP-RO-135, Reactor Utilization Requests, Rev. 2, issued October 24, 2012
MURR Reactor Operations Annual Report for the period from January 1, 2013, through December 31, 2013
b.
Observations and Findings
The experiments conducted at the facility were required to be evaluated and reviewed using MURR administrative procedure AP-RO-135, Reactor Utilization Requests. The procedure required that all experiments be reviewed and approved by the Reactor Manager and the Reactor Health Physics (HP)
Manager. An individual proposing a new experiment was required to evaluate the irradiation of the target material to determine that, if performed within the limitations stated in the RUR safety evaluation, the irradiation experiment would remain within the TS limits for experiments. The safety evaluation included a review of: (1) thermal effects, (2) possible sample decomposition and pressure effects, (3) experiment failure, (4) loss of coolant flow, (5) failure of other experiments, (6) corrosive effects of the sample, and (7) possible explosive
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potential. The evaluation was also required to address post-irradiation sample handling procedures, detection of radioactivity produced, radiation hazards, and reactivity worth. If the experiment under review did not involve a new class of experiment and met the criteria in 10 CFR 50.59 for being conducted without prior approval of the U.S. Nuclear Regulatory Commission (NRC), the Reactor Manager would then approve the RUR. Any RURs involving a new class of experiment or not meeting the criteria in 10 CFR 50.59 were required to be reviewed by the Reactor Safety Subcommittee. These RURs were then reviewed and, if properly analyzed and found to be acceptable, approved by the Reactor Advisory Committee (RAC).
The inspector noted that the RURs most commonly used at the facility were for product or sample irradiation. The inspector reviewed various recently approved RURs or amendments to previously approved RURs that had been submitted for review and approval. The experiments had been evaluated in accordance with TS requirements and the accompanying data sheets indicated that they were within reactivity limits. The safety analysis for each had been performed and the reviews and approvals completed.
The inspector noted that the experiments in progress during the inspection were conducted with the cognizance of the Reactor Manager and the senior reactor operator and in accordance with TS requirements (e.g., reactivity limitations).
The experiments reviewed by the inspector were being conducted in accordance with procedure and the materials produced were handled and transferred as required.
c.
Conclusion
The program for reviewing and conducting experiments satisfied TS and procedural requirements. Changes/amendments to existing experiments were reviewed and approved as required.
3.
Review and Audit and Design Change Functions
a.
Inspection Scope (IP 69007)
In order to verify that the licensee had established and conducted reviews and audits as required by 10 CFR Part 20 and TS 6.1, the inspector reviewed:
- 2013 dose to target charts
Radiation Protection Program/materials license audits for 2013
Other selected audits and reviews completed by management and HP personnel
Selected subcommittee meeting minutes from April 2013 to the present, including the Isotope Use Subcommittee, the Reactor Safety Subcommittee, and the Reactor Procedure Review Subcommittee
MURR RAC meeting minutes and related documents, from April 2013 to
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the present
MURR Administrative Policy, POL-3, MURR Radiation Protection Program, Rev. 13, issued December 9, 2013
MURR Reactor Operations Annual Report for the period from January 1, 2013, through December 31, 2013
b.
Observations and Findings
The inspector reviewed the meeting minutes of the RAC from April 2013 to the present and the meeting minutes of various subcommittees from April 2013 to the present. The minutes and associated documents indicated that the RAC met at the required frequency and that a quorum was present. The topics considered during the committee meetings and during the subcommittee meetings were appropriate and as stipulated in the TS.
The inspector reviewed the 2013 audit of the licensees Radiation Protection Program. No significant issues were identified during the audit, but several areas for improvement were noted. The inspector also reviewed the HP Managers response to the audit findings to address each of the areas for improvement.
The audits and responses to the audits appeared to be acceptable.
The inspector also reviewed the dose to target charts and ALARA reviews for 2013. These were prepared by the HP Manager and provided an annual review of the Radiation Protection Program and an overview of the dosimetry results and exposure goals for each separate group working at MURR. The data was also used to establish new exposure goals for the various groups. The charts and reviews illustrated and documented the licensees continued efforts to reduce personnel dose and maintain doses ALARA.
The licensee had an established design change review function implemented at the facility through MURR procedures AP-RR-003 and AR-RO-115. The procedures address changes to the facility Hazards Summary Report, modifications to the facility, changes to MURR procedures, new tests or experiments not described in the report, revisions to NRC-approved analysis methodology, and/or proposed compensatory actions to address degraded or non-conforming conditions. It included the screening and safety review of changes, tests, or experiments to determine if, pursuant to 10 CFR 50.59, a change required NRC approval prior to being implemented. The inspector found procedures in place to control the review process and evidence of adherence to the procedures. The inspector reviewed design changes completed and approved from April 2013 to the present and found that the changes were made in accordance with the licensees procedures.
c.
Conclusion
Review, oversight, audit functions required by the TS were acceptably completed by the RAC. Design changes were reviewed and approved in accordance with TS requirements and the licensees written procedures.
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4.
Procedures
a.
Inspection Scope (IP 69008)
To verify compliance with TS 6.1.b and 6.1.c, the inspector reviewed selected portions of the following:
- MURR Procedure AP-HP-119, High Radiation Area Access, Rev. 5, issued February 7, 2013
MURR Procedure RP-HP-125, Radiation Monitoring - Performing and Documenting a Survey, Rev. 0, issued August 5, 2013
MURR Procedure WM-SH-100, Radioactive Waste - Preparation and Storage, Rev. 7, issued July 26, 2013
MURR Procedure IC-HP-300, Calibration - Radiation Survey Instruments, Rev. 7, issued July 11, 2013
MURR Administrative Policy, POL-18, Procedure Writers Guide, Rev. 8, issued January 29, 2013
MURR Reactor Operations Annual Report for the period from January 1, 2013, through December 31, 2013
b.
Observations and Findings
TS 6.1.c required that the RAC review safety significant procedure changes. The Reactor Procedure Review Subcommittee was established and chartered to act on behalf of the RAC to fulfill this requirement. The inspector verified that the subcommittee was meeting as required to review current procedure revisions and changes. Following a review by the Reactor Procedure Review Subcommittee, the full RAC reviewed and approved the subcommittees actions regarding the various procedural changes and reviews.
The inspector reviewed a letter from the HP Manager to the Supervisor of Document Control dated March 18, 2014. The letter documented that the annual review of the radiation protection and shipping procedures had been completed for 2013 as required by the TS 6.1.b.
During a previous inspection, an Inspector Follow-up Item (IFI)
50-186/2013-201-01 was initiated to follow-up on an inspector observation that there was no procedure detailing how to conduct and document a radiation/contamination survey. Because of some minor issues noted by the inspector during a review of selected survey maps, the licensee determined that such a procedure was needed. On August 5, 2013, the licensee issued MURR Procedure RP-HP-125, Radiation Monitoring - Performing and Documenting a Survey, Rev. 0. The new procedure describes the conduct and documentation of a radiation/contamination survey. Based on the issuance of this procedure, IFI 50-186/2013-201-01 is closed.
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c.
Conclusion
The procedure review, revision, control, and implementation program satisfied TS requirements.
5.
Radiation Protection
a.
Inspection Scope (IP 69012)
The inspector reviewed the following to verify compliance with 10 CFR Parts 19 and 20 and the applicable licensee TS requirements and procedures:
- MURR dosimetry records for 2013 and 2014 to date
Dose report review forms for 2013
Selected radiation and contamination survey records for the past year
Radiological signs and posting in various facility laboratories and in the laboratory building basement area
Calibration and periodic check records for selected radiation survey and monitoring instruments for the past 2 years
MURR Procedure IC-HP-300, Calibration - Radiation Survey Instruments, Rev. 7, issued July 11, 2013
MURR Administrative Policy, POL-3, MURR Radiation Protection Program, Rev. 13, issued December 9, 2013
MURR Reactor Operations Annual Report for the period from January 1, 2013, through December 31, 2013
The inspector also toured the MURR facility and observed the use of dosimetry and survey meters.
b.
Observations and Findings
(1)
Surveys
Daily, monthly, and other periodic contamination and radiation surveys, outlined in the licensees Reactor Operations Annual Report for 2013, were completed by HP staff members. Any contamination detected in concentrations above established action levels was noted and the area or item was decontaminated. Results of the surveys were typically documented on survey maps and posted at the entrances to the various areas surveyed so that facility workers and visitors would be aware of the radiological conditions that existed therein.
The inspector accompanied an HP technician during completion of a radiation and contamination survey of the laboratory building basement area. The survey appeared to be conducted appropriately. The following day, the inspector conducted an independent radiation survey of the
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laboratory building basement general area as well. Based on the results of this survey, the inspector questioned the HP staff regarding an unexpected high radiation reading identified in a corner of the basement.
Upon further investigation by the licensee, the cause of the unexpected high radiation readings was determined to be a tray used for Iridium seed processing which had been removed from a nearby hot cell in the previous month. This tray was found to have a radiation dose reading of approximately 1,800 milliRem/hour (mR/hr) on contact and approximately 98 mR/hr at a distance of 30 centimeters.
10 CFR 20.1003, Definitions, states that high radiation area means an area, accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving a dose equivalent in excess of 0.1 Rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates. Combined with other radioactive sources stored in the same corner of the basement, the dose rate in this area was determined to be in excess of the high radiation area criteria.
10 CFR 20.1601, Control of access to high radiation areas, states that the licensee shall ensure that each entrance or access point to a high radiation area has one or more of the following features: (1) a control device that, upon entry into the area, causes the level of radiation to be reduced below that level at which an individual might receive a deep-dose equivalent of 0.1 Rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates; (2) a control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; or (3) entryways that are locked, except during periods when access to the areas is required, with positive control over each individual entry.
10 CFR 20.1902(b), Posting of high radiation areas, states that the licensee shall post each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words CAUTION, HIGH RADIATION AREA or DANGER, HIGH RADIATION AREA.
Contrary to the above requirements the licensee failed to properly post and control access to a high radiation area. Specifically, as discussed above, the NRC inspector identified a tray used for Iridium seed processing which had been removed from the hot cell and bagged and placed in the corner of the laboratory building basement. Between this tray and other sources in the area, dose rates in the area were determined to be in excess of the high radiation area criteria of 0.1 Rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source, but the area was not being controlled or posted as a high radiation area as required.
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Following questioning from the inspector, the tray was immediately removed from the area and stored in the isotope closet. The area of basement where the material was discovered was then roped off with an appropriate radiation warning sign. Hot cell personnel were contacted to remove other unwanted radioactive material in the area and place them into the designated radioactive waste storage area.
The licensee completed an investigation and determined that the root cause of the issue was the failure to perform an adequate survey of the tray in question upon its removal from the hot cell. This contributed to the failure to properly label the bag with its contents, and thus identify the potential to create a higher than expected radiation field. These factors were a contributing cause to the high radiation area identified. In response to this finding, the licensee re-trained the entire HP staff regarding the need to perform adequate radiation surveys. The licensee also initiated an action to develop a procedure for the tagging of radioactive material destined for storage or re-use, which will complement existing procedures associated with tagging waste. As an interim measure while the procedure is being completed and approved through the MURR procedure review process, a standing order was developed and issued to address the problem.
Based on the narrow physical space where this item was discovered in the corner of the basement, the inspector determined that no substantial potential existed for exposures in excess of the applicable limits in 10 CFR 20.1001-20.2401.
This has been determined to be a Severity Level IV violation (VIO),
consistent with Section 6.7 of the NRC Enforcement Policy (VIO 50-186/2014-201-01).
(2)
Postings and Notices
Copies of current notices to workers were posted in appropriate areas in the facility. The copies of NRC Form 3 noted at the facility were the latest issue, as required by 10 CFR Part 19, and were posted in various areas throughout the facility, such as the main bulletin board, the main hallways, and at the entrance to the beam port floor area. The inspector determined that appropriate radiological signs, as well as current copies of the survey maps (as noted above), were typically posted at the entrances to controlled areas. Other postings also showed the industrial hygiene hazards that were present in the areas. As discussed above, one example of a failure to post a high radiation area was identified.
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(3)
Dosimetry Use and Results
Through direct observation the inspector determined that dosimetry was acceptably used by facility and contractor personnel. The inspector determined that the licensee used optically stimulated luminescent (OSL)
dosimetry for whole body monitoring and TLDs in the form of finger rings and wrist badges for extremity monitoring. An examination of the OSL and TLD results indicating radiological exposures at the facility for the past year showed that the highest occupational doses, as well as doses to the public, were within 10 CFR Part 20 limits.
(4)
Radiation Monitoring Equipment
Examination of selected radiation monitoring equipment indicated that the instruments had the acceptable up-to-date calibration sticker attached. A review of selected instrument calibration records indicated that the calibration of swipe counters and portal monitors was typically completed by licensee staff personnel. Other instruments, such as portable survey meters, friskers, and neutron detectors, were shipped to vendors for calibration. Calibration frequency met procedural requirements and records were maintained as required. The inspector noted that area radiation monitors, as well as air monitors and stack monitors, were also being calibrated as required. These monitors were also typically calibrated by licensee staff personnel.
(5)
Radiation Protection Program
The licensees Radiation Protection and ALARA Programs continued to be established and described in the MURR Administrative Policy, POL-3, MURR Radiation Protection Program, and implemented through the various HP procedures that had been reviewed and approved. The programs contained instructions concerning organization, training, monitoring, personnel responsibilities, and audits. The programs, as outlined and established, appeared to be acceptable. The inspector verified that annual reviews of the Radiation Protection Program were being completed by the licensee as required by 10 CFR Part 20. The ALARA Program provided instructions and guidance for keeping doses ALARA and was consistent with the guidance in 10 CFR Part 20.
(6)
Radiation Work Permit Program
The inspector reviewed selected radiation work permits that had been written, used, and closed out during 2013, and those issued to date in 2014. It was noted that the instructions specified in MURR Procedure AP-HP-105, Attachment 7.1, and those on the associated forms (e.g.,
Form FM-17, Radiation Work Permit Instructions) had been followed.
Appropriate review by management and HP personnel had been completed. The controls specified in the radiation work permits were
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acceptable and applicable for the type of work being done.
(7)
The MURR management ALARA efforts are well organized and continue to produce dose reduction results. ALARA goals were set and performance indicators were established. Each group in the MURR organization has an established ALARA goal for the year and the facility dose is tracked by group, as well as for each individual.
The total cumulative dose for 2013 was 32.3 Rem. MURR management and staff continue their efforts to maintain personal doses ALARA.
(8)
Facility Tours
On various occasions during the inspection, the inspector toured the hot cell area and selected support laboratories with licensee representatives.
With the exception of the violation discussed above, no anomalies were noted. The inspector noted that facility radioactive material storage areas were generally properly posted. Radiation and high radiation areas were generally posted and properly controlled as required, except as described in the violation discussed above.
c.
Conclusion
The inspector determined that the Radiation Protection and ALARA Programs, as implemented by the licensee, generally satisfied regulatory requirements because: (1) surveys were generally completed and documented acceptably to permit evaluation of the radiation hazards present with the exception of the violation discussed above, (2) postings generally met regulatory requirements, (3) personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits, (4) radiation survey and monitoring equipment was being maintained and calibrated as required, and (5) the Radiation Protection Program was acceptable and was being reviewed annually as required. One violation was identified associated with control and posting of a high radiation area.
6.
Transportation
a.
Inspection Scope (IP 86740)
To verify compliance with regulatory and procedural requirements for transferring or shipping licensed radioactive material, the inspector reviewed the following:
- Selected records of various types of radioactive material shipments for 2013 and to date in 2014
Selected training records for staff personnel authorized to ship radioactive material
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b.
Observations and Findings
During the inspection the inspector observed the preparations for three shipments. Each shipment was made in a Type B shipping container.
Throughout the process the inspector noted adherence to procedures and attention to maintaining radiation doses ALARA. Shipping personnel reviewed the irradiation records and the contents of the packages were verified using gamma spectroscopy. Shipping papers were prepared by one person and reviewed for accuracy and completeness by a second staff member. The licensee verified consignee information (i.e., possession of a license to receive radioactive materials, address, and contact information). Also, appropriate labels were completed and applied to the shipping containers. The inspector verified that the shipping papers contained all required information and that the appropriate labels were correct and applied to the packaging. An HP technician was also involved to review the shipment paperwork. Other quality assurance checks were also adequate and completed as required. Throughout the shipping process, it was noted that MURR staff members where knowledgeable of their duties and conducted a thorough review of all documentation.
The inspector verified that the licensee maintained on file copies of consignees licenses to possess radioactive material as required. As noted above the license of each specific consignee was verified to be current prior to initiating a shipment and the amount of radioactive material was compared to that amount authorized by the license. The inspector also verified that the licensee staff members who were designated as shippers had received training within the last 3 years.
The records of various types of shipments were reviewed, including the records of a shipment of radioactive waste. Through records review and discussions with licensee personnel, the inspector determined that, in addition to medical isotopes and radioactive waste, the licensee had shipped spent fuel and other types of radioactive material since the previous inspection in this area. The records indicated that the radioisotope types and quantities were calculated and dose rates measured as required. The radioactive material shipment records reviewed by the inspector had been completed in accordance with Department of Transportation and NRC regulations.
During a review of the corrective action program, the inspector noted that the licensee initiated an item related to an improperly labeled shipment. During the licensees investigation, they identified that a radioactive shipment of Iridium-192 was shipped with an incorrect shipping label.
On November 13, 2013, a shipping package of Iridium-192 was incorrectly labeled as a Yellow-II shipment when, based on the dose reading, it should have been labeled as Yellow-III. The dose rate limit for a Yellow-II shipment is less than 1 mR/hour. This package was measured and labeled with a dose rate of 1.6 mR/hr. Prior to shipping the package, the facility properly identified the dose rate value and recorded this on the package label, but then inadvertently affixed
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the wrong label to the package and shipped it. It was subsequently returned to the licensee by the shipping company.
The licensees investigation identified the cause as human error on the part of the shipper. Corrective actions included relabeling the package for shipment, discussion of the incident with all facility shippers, and enhancements to the licensees shipping procedures. The licensee self-identified this violation during an investigation within their corrective action program.
The licensee was informed that failure to properly label a radioactive package for shipment was a violation of regulatory requirements. However, as indicated above, the inspector determined that the problem had been identified and appropriately reviewed by the licensee. Adequate corrective actions had been identified and completed as well. As a result, the licensee was informed that this non-repetitive, licensee-identified, and corrected violation would be treated as a non-cited violation (NCV), consistent with Section 2.3.2.b of the NRC Enforcement Policy (NCV 50-186/2014-201-02). This issue is considered closed.
c.
Conclusion
Radioactive material was generally being shipped in accordance with the applicable regulations. One non-cited violation was identified.
7.
Exit Interview
The inspection scope and results were summarized on April 3, 2014, with members of licensee management and staff. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee did not identify any of the material provided to or reviewed by the inspector during the inspection as proprietary.
The licensee acknowledged the results of the inspection.
PARTIAL LIST OF PERSONS CONTACTED
Licensee MURR Facility Director R. Dobey
Health Physics Manager J. Ernst Associate Director, Regulatory Assurance Group K. Foley Associate Director, Regulatory Affairs J. Fruits
Reactor Manager A. Gaddy
Compliance Specialist E. Graham
Health Physics Technician J. Hemphill
Health Physicist, Special Projects Coordinator L. Juengermann Shipping Manager M. Kraus
Safety Associate and Corrective Action Program Coordinator J. Mitchell
Health Physics Technician II D. Nickolaus Health Physics Technician II D. Rathke
Access Control Coordinator M. Sanford
Associate Director, Products and Services C. Schnieders Health Physics Technician
INSPECTION PROCEDURES USED
IP 69004 Class 1 Research and Test Reactor Effluent and Environmental Monitoring IP 69005 Class 1 Research and Test Experiments IP 69007 Class 1 Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class 1 Research and Test Reactor Procedures IP 69012 Class 1 Research and Test Reactor Radiation Protection IP 86740 Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND/OR DISCUSSED
Opened
50-186/2014-201-01 VIO Failure to control and post a high radiation area as required
50-186/2014-201-02 NCV Failure to properly label a radioactive shipment
Closed
50-186/2013-201-01 IFI Follow-up on the issue of developing a procedure
concerning the proper conduct and documentation
of radiation and contamination surveys at MURR.
50-186/2014-201-02 NCV Failure to properly label a radioactive shipment
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LIST OF ACRONYMS USED
ALARA As Low As Reasonably Achievable 10 CFR Title 10 of the Code of Federal Regulations HP Health physics IFI Inspector Follow-up Item IP Inspection Procedure mR/hr milliRem per hour MURR University of Missouri - Columbia Research Reactor NCV Non-Cited Violation NRC U.S. Nuclear Regulatory Commission OSL Optically stimulated luminescent (dosimeter)
RAC Reactor Advisory Committee RUR Reactor Utilization Request TLD Thermoluminescent Dosimeter TS Technical Specifications VIO Violation