IR 05000243/2017201

Oregon State University - U.S. Nuclear Regulatory Commission Inspection Report 05000243/2017201

ML17024A248
Person / Time
Site:	Oregon State University
Issue date:	02/09/2017
From:	Anthony Mendiola Research and Test Reactors Oversight Branch
To:	Reese S Oregon State University
Bassett C, NRR/DPR/PROB, 301-466-4495
References
IR 2017201
Download: ML17024A248 (21)

Text

ary 9, 2017

SUBJECT:

OREGON STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 50-243/2017-201

Dear Dr. Reese:

From January 8-12, 2017, the U.S. Nuclear Regulatory Commission (NRC or the Commission)

conducted an inspection at the Oregon State University Radiation Center training reactor and isotopes production, General Atomics (TRIGA) Mark-II reactor facility. The enclosed report documents the inspection results, which were discussed on January 12, 2017, with Todd Keller, Reactor Administrator and other members of your staff.

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

The inspector reviewed selected procedures and records, interviewed personnel, and observed activities in progress. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this inspection, please contact Craig Bassett at (301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA Michael Takacs acting for/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-243 License No. R-106 Enclosure:

As stated cc: See next page

Oregon State University Docket No.: 50-243 cc:

Mayor of the City of Corvallis Corvallis, OR 97331 Mr. Ken Niles Division Administrator Nuclear Safety Division Oregon Department of Energy 625 Marion Street NE Salem, OR 97301-3737 Dr. Cynthia Sagers Vice President for Research Oregon State University A312 Kerr Administrative Services Bldg Corvallis, OR 97331-5904 Dr. Todd Keller Reactor Administrator Oregon State University 100 Radiation Center, A-100 Corvallis, OR 97331-5903 Mr. Daniel Harlan, Chairman Reactor Operations Committee Oregon State University 100 Oak Creek Building Corvallis, OR 97331-5904 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611

ML17024A248; *concurred via e-mail NRC-002 OFFICE NRR/DPR/PROB* NRR/DPR/PROB* NRR/DPR/PROB NAME CBassett NParker AMendiola (MTakacs for)

DATE 2/10/17 2/9/17 2/9/17

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-243 License No: R-106 Report No: 50-243/2017-201 Licensee: Oregon State University Facility: TRIGA Mark-II Reactor Facility Location: Corvallis, OR Dates: January 9-12, 2017 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY Oregon State University TRIGA Mark-II Reactor Facility Report No. 50-243/2017-201 The primary focus of this routine, announced inspection included onsite review of selected aspects of the Oregon State University (the licensee) Class II research reactor safety program including: (1) organizational structure and staffing, (2) review and audit and design change functions, (3) radiation protection, (4) effluent and environmental monitoring, (5) procedures, 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 in compliance with NRC requirements.

Organizational Structure and Staffing

• The organizational structure and staffing were consistent with Technical Specification (TS)

requirements.

Review and Audit and Design Control Functions

• The review and audit program was being conducted acceptably and completed by the Reactor Operations Committee as stipulated in TS 6.2.

• Changes made at the facility since the last NRC inspection had been evaluated using the licensees Title 10 of the Code of Federal Regulations Section 50.59 safety evaluation process and had been reviewed and approved by the Reactor Operations Committee as required.

Radiation Protection

• Periodic surveys were completed and documented as required by procedure.

• Postings and signs met regulatory requirements.

• Personnel dosimetry was being worn as required and recorded doses were within the NRCs regulatory limits.

• Radiation survey and monitoring equipment were being maintained and calibrated as required.

• The radiation protection training program was acceptable and training was being completed as required.

• The radiation protection and as low as reasonably achievable programs satisfied regulatory requirements.

-2-Effluent and Environmental Monitoring

• Effluent monitoring satisfied license and regulatory requirements and releases were within the specified TS levels and regulatory.

• The environmental protection program satisfied NRC requirements.

Procedures

• The procedural change and control program satisfied the applicable TS and procedure requirements.

• Activities were conducted in accordance with the applicable procedures as required.

Transportation of Radioactive Material

• The program for transportation of radioactive materials satisfied NRC and Department of Transportation requirements.

• Training of staff members responsible for shipping radioactive materials was being conducted as required.

REPORT DETAILS Summary of Facility Status The Oregon State University (OSU or the licensee) continued to operate the 1.1 megawatt training reactor and isotopes production, General Atomics (TRIGA) Mark-II research reactor as needed in support of sample irradiations, laboratory testing, reactor system testing, and surveillance. During this inspection the licensees reactor was operated several hours per day at varying power levels for experiments and sample irradiations.

1. Organizational Structure and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001)

The inspector reviewed the following regarding the licensees organization and staffing to ensure that the requirements of Section 6 of the Technical Specifications (TSs), revised through Amendment No. 23 of the Facility Operating License No. R-106, dated January 13, 2016, were being met:

• Management responsibilities and administrative controls

• OSU Radiation Center facility organizational structure and staffing

• Administrative controls outlined in Oregon State TRIGA Reactor Operating Procedure (OSTROP) 6, Administrative and Personnel Procedures, Revision (Rev) LEU-3

• OSU Radiation Center and TRIGA Reactor Annual Report for the period from July 1, 2014, through June 30, 2015, submitted to the U.S. Nuclear Regulatory Commission (NRC) on October 9, 2015

• OSU Radiation Center and TRIGA Reactor Annual Report for the period from July 1, 2015, through June 30, 2016, submitted to the NRC on October 6, 2016 b. Observations and Findings The organizational structure with respect to the licensees health physics organization had not changed since the last inspection in the area of radiation protection (refer to NRC Inspection Report No. 50-243/2015-201). There was one Senior Health Physicist (SHP) position and one Health Physicist (HP)

position listed on the licensees organization chart. It was noted that the person who had been working as the facility HP had retired and a Nuclear Engineering student, who had worked part-time as a monitor at the facility in the past, was hired to fill the vacant position. There was also one student who worked part-time as a work study assistant/HP monitor completing routine surveys and other such tasks.

The reactor operations organizational structure remained unchanged as well.

However, the staffing level had changed with the recent addition of two new reactor operators (ROs) at the facility. It was noted that there were five senior reactor operators (SROs) and five ROs. The five SROs and one of the ROs were full-time staff members while the other four ROs were students employed on a part-time basis at the reactor facility.

Enclosure

-2-The organizational structure and staffing were consistent with the requirements of the TS. Review of records verified that management responsibilities were administered as required by the TS and applicable procedures.

c. Conclusion The organizational structure and staffing were consistent with TS requirements.

2. Review and Audit and Design Change Functions a. Inspection Scope (IP 69001)

In order to ensure that the audits and reviews stipulated in the requirements of TS Section 6.2 were being completed and that facility and procedure changes were evaluated prior to implementation as required, the inspector reviewed the following:

• Reactor Operations Committee (ROC) meeting minutes and records from February 2015 to the present

• ROC safety review and audit records from February 2015 to the present

• OSTROP 6, Administrative and Personnel Procedures, Rev. LEU-3

• Various changes completed during 2015 and 2016 and reviewed using the licensees safety evaluation process outlined in OSTROP 6, and documented on forms:

Figure 6.1, Oregon State TRIGA Reactor (OSTR) 10 CFR 50.59 Screen Form Figure 6.2, OSU TRIGA Reactor (OSTR) 10 CFR 50.59 Evaluation Form (3 pages)

• Radiation Center Health Physics Procedure (RCHPP) No. 1, Guidelines for the Radiation Protection Program at the OSU Radiation Center, Rev. 10 b. Observations and Findings (1) Review and Audit Functions ROC meeting minutes and associated records from February 2015 through the present were reviewed. The records showed that meetings were being held and safety reviews and audits were conducted by various members of the ROC or other designated persons as required and at the TS required frequency. Topics of these reviews were consistent with TS requirements to provide guidance, direction, and oversight, and to ensure acceptable use of the reactor and appropriate implementation of the radiation protection program. The inspector noted that the safety reviews and audits and the associated findings were acceptably detailed and that the licensee responded and took corrective actions as needed.

(2) Design Change Functions Through interviews with licensee personnel, the inspector determined that various changes had been initiated and/or completed at the facility since

-3-the last NRC inspection. The inspector reviewed the licensees Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59 screen forms numbered 15-01 through 15-11 and 16-01 through 16-06 and the licensees 10 CFR 50.59 evaluation forms numbered 15-01 through 15-04 for 2015. (No safety evaluations had been conducted in 2016.) It was noted that none of the screenings that had been completed required that an evaluation be conducted based on the criteria in 10 CFR 50.59. The evaluations that were conducted in 2015 were ones that were automatically required by licensee procedure OSTROP 6.

Review of these documents indicated that facility changes had been screened (i.e., analyzed and reviewed) and evaluated using the licensees 10 CFR 50.59 review process outlined in OSTROP 6. The appropriate forms had been completed as required. The screen forms had been reviewed and signed by all the SROs, the SHP, the Reactor Administrator, and the Director. The evaluation forms had been reviewed and signed by members and the Chair of the ROC as required. It was also noted that none of the changes required NRC review and approval prior to implementation.

c. Conclusion Review and oversight functions required by TS Section 6.2 were acceptably completed by the ROC. Changes made at the facility since the last NRC inspection had been reviewed using the facilitys 10 CFR 50.59 safety screening and evaluation process as required.

3. Radiation Protection a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Section 6.3, 10 CFR Parts 19 and 20, and licensee administrative requirements:

• OSU Radiation Center radiation protection program

• As low as reasonably achievable (ALARA) reviews

• Radiological signs and postings in various areas of the facility

• Maintenance and calibration of radiation survey and monitoring equipment

• Dosimetry/exposure records for January 2015 through November 2016

• Training records for Radiation Center staff, HP monitors, and facility users

• Radiation Center TRIGA Mark-II Reactor Facility Radiation Protection Program

• Occupational exposure records documented on forms entitled, Form 5:

Occupational Exposure Record for a Monitoring Period, for licensee employees for 2014 and 2015 (forms for 2016 were not yet available)

• Various HP notebooks entitled:

HP Notebook - Surveys, Volume I, Daily/Weekly/ Monthly/Neutron Generator/and Semi-Annual Floor Surveys

-4-HP Notebook - Surveys, Volume II, Special Surveys HP Notebook - Surveys, Volume IV, Work Surveillance Reports

• Routine periodic surveys documented on the following forms:

Form RCHPP-24A, Daily Routine Radiation Survey Record Form RCHPP-24B, Weekly Routine Radiation Survey Record Form RCHPP-24C, Monthly Routine Radiation Survey Record Form RCHPP-24D, Non-Routine (Special) Radiation Survey Record Form RCHPP-27, Attachment 1, Semi-Annual Floor Survey For Fixed and Removable Radiation Contamination - Part I Direct and Gross Floor Smear and Semi-Annual Floor Survey For Fixed and Removable Radiation Contamination - Part II Worksheet, and Form RCHPP-27, Attachment 2, Floor Survey Map

• Calibration records documented on the following forms:

Calibration Results for the Tracerlab Dual-Channel Reactor Facility Continuous Stack-Effluent Monitor Calibration Results for the NMC AM-22BF Dual-Channel Reactor Top Continuous Air Monitor (CAM)

Calibration Results for the Area Radiation Monitoring Systems Located Throughout the TRIGA Reactor Facility and in the Pneumatic Transfer (PT) Rabbit Laboratory Calibration Results for various portable instruments generated and maintained by the Development Engineer

• Various RCHPP Procedures including:

No. 1, Guidelines for the Radiation Protection Program at the OSU Radiation Center, Rev. 10 No. 18, Maintenance and Calibration Procedures for Radiation Protection Instrumentation (Including Operator Training Manual and Operating Procedures for the Radiation Center Gamma Instrument Calibration Facility), Rev. 11 No. 20, Radiation Survey Procedures for the Release of Items for Unrestricted Use, Rev. 3 No. 24, Procedures for Performing Routine (Daily, Weekly, Monthly, and Annual) Radiation Surveys and Non-Routine (Special) Radiation Surveys, Rev. 10 No. 27, Procedure for Performing the Semi-Annual Floor Survey for Fixed and Removable Radioactive Contamination, Rev. 7 No. 34, Orientation and Training Program for the OSU Radiation Center, Rev. 19 No. 37, Dosimetry, Rev. 3

• OSU TRIGA Reactor Annual Reports for the last two reporting periods b. Observations and Findings (1) Surveys Selected daily, weekly, monthly, semiannual, and annual radiation and/or contamination surveys were reviewed by the inspector. The surveys had been completed by HP staff members or student HP monitors who had received the appropriate training to conduct surveys. Any contamination detected in concentrations above established action levels was noted and

-5-the area or item was decontaminated. Following the decontamination, the area or material was again surveyed to ensure that it was clean.

Results of the surveys were acceptably documented by HP staff personnel and reviewed by the SHP.

During the inspection the inspector accompanied the facility HP during completion of a routine daily radiation and contamination survey. Areas surveyed at the facility included the reactor bay and associated laboratories, hallways, and the heat exchanger room. Various items in these areas were also surveyed. The techniques used during the survey were adequate and the survey was conducted and documented in accordance with the guidance specified by procedure. The inspector conducted a radiation survey along with the licensee HP. The radiation levels noted by the inspector were comparable to those found by the licensee and no anomalies were noted.

(2) Postings and Notices Radiological signs were typically posted at the entrances to controlled areas. Other postings also showed the industrial hygiene hazards that were present in the areas as well. Caution signs, postings, and controls for radiation areas were as required by 10 CFR Part 20, Subpart J. The inspector noted that licensee personnel observed the signs and postings and the precautions for access to radiation areas.

Copies of current notices to workers were posted in appropriate areas in the facility. The copies of NRC Form 3, Notice to Employees, noted at the facility were the latest issue and were posted in various areas throughout the facility as required by 10 CFR 19.11. These locations included on the main bulletin board in the hallway by the front office, in the corridor leading to the reactor building, and in the reactor control room.

(3) Dosimetry The inspector determined that the licensee used thermoluminescent dosimeters (TLD) for whole body monitoring of beta and gamma radiation exposure, as well as separate component to measure neutron radiation.

(On occasion the licensee also used pocket ion chambers for monitoring dose.) The licensee also used TLD finger rings for extremity monitoring.

The TLD dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor, Mirion Technologies. An examination of the TLD results indicating radiological exposures at the facility for the past three years showed that the highest occupational doses, as well as doses to the public, were within 10 CFR Part 20 limitations.

Through direct observation the inspector determined that dosimetry was acceptably used by facility personnel and exit frisking practices were in accordance with facility radiation protection procedural requirements.

-6-(4) Calibration of Radiation Survey and Monitoring Equipment Examination of selected meters in the Reactor Bay and adjacent areas which were used for radiation monitoring indicated that the instruments had the acceptable up-to-date calibration sticker attached. Review of the instrument calibration records for various meters and monitors indicated the calibration of portable survey meters was typically completed on-site by the facility Development Engineer. However, some instruments were shipped off-site to vendors for calibration. The inspector verified that the instruments were calibrated annually which met procedural requirements and calibration records were maintained as required. Area radiation monitors and stack monitors were also being calibrated annually as required. These monitors were typically calibrated by licensee staff personnel as well.

(5) Work Surveillance Report Program Through interviews with licensee personnel and records review, the inspector determined that no Work Surveillance Reports (WSRs) had been issued during 2015 or 2016. It was noted that WSRs were similar to radiation work permits used at other facilities, but were used by the licensee mainly in situations involving non-routine maintenance or other work being performed at the facility on highly contaminated structures, systems, or components (SSCs) or work on SSCs with elevated radiation levels. The inspector verified that, if WSRs were needed, they would be prepared in accordance with the requirements specified on the WSR form, including work controls, protective clothing requirements, and dose tracking and limits.

(6) Radiation Protection Training The inspector reviewed the Radiation Worker training given to Radiation Center staff members, to those who are not on staff but who are authorized to use the experimental facilities of the reactor, and to student assistants working as part-time HP monitors. The training program was outlined in RCHPP No. 34. It included initial Radiation Worker training for those new to the facility and refresher training for faculty and staff. It was noted that the appropriate training was required to be completed before a person was allowed unescorted access to various restricted areas of the Radiation Center. The type of initial training given was based upon the position and/or duties of the person. The inspector reviewed the completed forms of various staff members and verified that they had completed the appropriate training. The training program was acceptable.

As noted above, initial training was provided when a person first started work or classes at the facility. Refresher training was given on a 3-year cycle. The last Radiation Worker refresher training for Radiation Center personnel was completed during November and December 2013.

Because of this, the licensee was in the process of setting up a schedule

-7-for the refresher training that was due. The licensee anticipated completing this by the end of January.

The inspector attended a training class given to new RO trainees. The SHP presented Radiation Worker training Parts I, II, and III. The training included radiation safety and building security requirements, as well as the requirements for unescorted access to the Reactor Bay. An examination was given after each portion of the training to ensure that the trainees understood the material presented. The training appeared to be appropriate.

(7) Radiation Protection Program The licensees radiation protection and ALARA programs were established and described in the RCHPP No. 1 and through associated HP procedures. The radiation protection program contained instructions concerning organization, training, monitoring, personnel responsibilities, audits, record keeping, reports, and maintaining doses ALARA. The ALARA program provided guidance for keeping doses ALARA which was consistent with the requirements in 10 CFR Part 20. The programs, as established, appeared to be acceptable. The inspector verified that the radiation protection program was being reviewed annually as required by 10 CFR 20.1101(c).

The licensee did not have a respiratory protection program or planned special exposure program; neither program was required based on the current level of activity at the facility.

(8) Facility Tours The inspector toured the reactor bay, the heat exchanger room, and selected support laboratories with licensee representatives on various occasions. The inspector noted that facility radioactive material storage areas were properly posted. No unmarked radioactive material was noted. Radiation areas were also posted as required.

c. Conclusion The inspector determined that the radiation protection and ALARA programs, as implemented by the licensee, satisfied regulatory requirements. Specifically, (1) periodic surveys were completed and documented acceptably to permit evaluation of the radiation hazards present, (2) postings and signs 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 training program was being implemented as stipulated in procedure.

-8-4. Effluent and Environmental Monitoring a. Inspection Scope (IP 69001)

To determine that the licensee was complying with the requirements of the regulations and TS Section 6.7.1.e, the inspector reviewed selected aspects of:

• OSU Radiation Safety Radioactive Waste Tag forms for 2015 and 2016

• Environmental monitoring release records documented in various notebooks, including:

HP Notebook - Environmental Monitoring, Volume I, Airborne Gamma Emitters TLD Reports/Ion Chamber, and flow element Results HP Notebook - Environmental Monitoring, Volume II, Soil, Water, and Vegetation Data HP Notebook - Environmental Monitoring, Volume III, Solid and Liquid Waste, Hold-up Tank HP Notebook - Environmental Monitoring, Volume IV, Gaseous Waste Discharge Summary

• Selected forms documenting environmental data and analysis results completed in 2015 and 2016, including:

Environmental Soil, Water, and Vegetation Sample Report Monthly TRIGA Reactor Gaseous Waste Discharges and Analysis

• Records of waste transferred from the reactor facilitys NRC license to the State license for the past 2 years, documented on forms issued by the OSU Radiation Safety Office and entitled:

Oregon State University, Radiation Safety Radioactive Waste Tag for liquid radioactive waste Oregon State University, Radiation Safety Radioactive Waste Tag for solid radioactive waste Various RCHPP Procedures including:

No. 1, Guidelines for the Radiation Protection Program at the OSU Radiation Center, Rev. 10 RCHPP No. 8, Water Analysis, Rev. 6 RCHPP No. 13, Procedures for Collection and Biological Analysis of Environmental Soil, Water, and Vegetation Samples, Rev. 5 RCHPP No. 15, Operating Procedures for the Environmental Thermoluminescent Dosimetry (TLD) Program, Rev. 4 RCHPP No. 31, Procedure for Sampling and Pumping the Liquid Waste Hold-up Tank, Rev. 8 RCHPP No. 32, Stack Gas Effluent Analysis, Rev. 2

• OSU TRIGA Reactor Annual Reports for the last two reporting periods b. Observations and Findings Soil, water, and vegetation environmental samples were collected, prepared, and analyzed annually in accordance with procedural requirements. On-site and off-site gamma radiation monitoring was completed using the reactor stack effluent monitor and various environmental monitoring station TLDs as required by the applicable procedures as well. Data indicated that there were no measurable doses above natural background radiation.

-9-The inspector determined that gaseous releases continued to be monitored as required, were calculated according to procedure, and were acceptably documented in the annual reports. The airborne concentrations of the gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2. Also, the dose rate to the public as a result of the gaseous releases was well below the dose constraint specified in 10 CFR 20.1101(d) of 10 millirem per year (mrem/yr). This was acceptably demonstrated by the licensee through COMPLY code calculations. These calculations indicated an effective dose equivalent to the public of 6.3 mrem/yr for the year 2015 and 5.3 mrem/yr for the year 2016. The principles of ALARA were acceptably implemented to minimize radioactive releases. Monitoring equipment was acceptably maintained and calibrated. Records were current and acceptably maintained. Observation of the facility by the inspector indicated no new potential release paths.

The licensees program for monitoring, storing, and/or transferring radioactive liquid and solid waste was consistent with applicable procedural requirements.

Solid radioactive waste was transferred to the OSU waste processing facility under the State of Oregon broad-scope license (ORE-90005) for processing and disposal. This process was acceptably documented on the appropriate OSU Radiation Safety Office forms in accordance with the requirements of RCHPP No. 1. It was noted that no liquid radioactive waste was transferred to the OSU waste processing facility during the 2015-2016 time period. The inspector reviewed the liquid effluent releases discharged from the facility Hold Up Tank to the sanitary sewer in 2015 and 2016. Analyses of the various samples of the effluent indicated that the releases were well within the monthly average concentration limits established in 10 CFR Part 20, Appendix B, Table 3.

c. Conclusion Gaseous and liquid effluent releases were within the specified TS levels and regulatory limits. The environmental protection program satisfied NRC requirements.

5. Procedures a. Inspection Scope (IP 69001)

The inspector reviewed selected aspects of the following to verify compliance with TS Section 6.4:

• Procedural implementation

• Selected RCHPP procedures

• Records of changes to RCHPP procedures

• Records of ROC review and approval of procedures documented in the ROC meeting minutes for 2015 and 2016

• RCHPP No. 1, Guidelines for the Radiation Protection Program at the OSU Radiation Center, Rev. 10

- 10 -

b. Observations and Findings Administrative controls of changes to procedures and the associated review and approval processes were as stipulated by procedure. The inspector verified that substantive procedure changes were being reviewed and approved by the ROC as required by TS Section 6.4. Training of personnel on procedures and changes was acceptable. The inspector verified that licensee personnel conducted activities in accordance with applicable procedures. Records showed that procedures for handling incidents due to potential malfunctions (e.g.,

radioactive material ingestion and contaminations) were available for use as needed. The inspector also determined that all RCHPP procedures were being reviewed annually as required.

c. Conclusion The procedural change and control program satisfied the applicable TS and procedure requirements. Activities were conducted in accordance with the applicable procedures as required.

6. Transportation of Radioactive Material a. Inspection Scope (IP 86740)

To verify compliance with regulatory and procedural requirements for the transfer or shipment of licensed radioactive material, the inspector reviewed the following:

• Selected records of various types of radioactive material shipments completed in 2015 and 2016

• Radioactive waste records documented in HP Notebook - Environmental Monitoring, Volume III, Solid and Liquid Waste, Hold-up Tank

• Training records of staff members responsible for shipping licensed radioactive material

• Records of waste transferred from the reactor facilitys NRC license to the State license for the past 2 years documented on forms issued by the OSU Radiation Safety Office and entitled:

Oregon State University, Radiation Safety Radioactive Waste Tag for liquid radioactive waste Oregon State University, Radiation Safety Radioactive Waste Tag for solid radioactive waste

• Radioactive material transfer records documented in various notebooks including:

HP Notebook - Radioactive Material Transfer, Volume I, General Shipping Forms, Training Records, and Audit Records HP Notebook - Radioactive Material Transfer, Volume II, Shipping Container Tests HP Notebook - Radioactive Material Transfer, Volume III, Radioactive Material Transfer Records HP Notebook - Radioactive Material Transfer, Volume IV, Shipment Analysis

- 11 -

Various RCHPP Procedures including:

No. 1, Guidelines for the Radiation Protection Program at the OSU Radiation Center, Rev. 10 RCHPP No. 5, Procedures for Receipt Radiation Surveys and Unpacking of Packages Containing Radioactive Material, Rev. 6 RCHPP No. 6, OSU Procedures for Transfer, Packaging, and Transport of Radioactive Materials Other Than Radioactive Waste, Rev. 15 RCHPP No. 11, Procedures for Testing and Certification of OSU Radioactive Materials Shipping Containers, Rev. 4

• OSU TRIGA Reactor Annual Report for the last two reporting periods b. Observations and Findings As noted previously, records showed that radioactive liquid and solid waste was transferred to the OSU Radiation Safety Office for packaging, shipment, and disposal in accordance with licensee requirements and the applicable procedures. This program for radioactive material transfer was consistent with the requirements specified in RCHPP No. 1.

The transport of other types of radioactive material was also reviewed. Through records reviews and various discussions with licensee personnel, the inspector determined that the licensee had shipped various types of radioactive material to a number of different consignees 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 records also indicated that the shipping containers were appropriate and had been labeled as required. All radioactive material shipment records reviewed by the inspector had been completed in accordance with Department of Transportation (DOT) and NRC regulatory requirements.

The training of the staff members responsible for shipping the material was reviewed. Annual training had been conducted according to licensee procedure which exceeded the requirements specified in the regulations.

The inspector verified that the licensee maintained copies of the recipients licenses to possess radioactive material as required and that the licenses were verified to be current prior to initiating a shipment.

During the inspection, the inspector observed the preparation of two sets of samples of radioactive material for a shipment. The material was analyzed to determine the activity present and the shipment was determined to be a limited quantity shipment. The radiation levels for the shipment were measured on contact and at one foot from the material. The material was then properly packaged and placed in the appropriate shipping container. Then the applicable labels were filled out with the required information and these were attached to the shipping container. The shipping paperwork was completed in accordance with the regulatory requirements. No problems or deficiencies were noted.

- 12 -

c. Conclusion The program for transportation of radioactive materials satisfied NRC and DOT regulatory requirements.

7. Exit Interview The inspection scope and results were summarized with licensee representatives at the conclusion of the inspection on January 12, 2017. The inspector discussed the findings for each area reviewed. The licensee acknowledged the inspection findings and did not identify any material as proprietary.

PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel K. Combs Health Physicist T. Keller Reactor Administrator C. Kulah Reactor Operator S. Menn Senior Health Physicist C. Olney Reactor Supervisor Director, Radiation Center R. Schickler Reactor Engineer S. Smith Development Engineer Other Personnel D. Harlan Chair, Reactor Operations Committee INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened None.

Closed None.

LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable DOT Department of Transportation HP Health Physicist/ Physics IP Inspection Procedure mrem/yr millirem per year NRC U.S. Nuclear Regulatory Commission OSU Oregon State University OSTROP Oregon State University TRIGA Reactor Operating Procedure RCHPP Radiation Center Health Physics Procedure Rev Revision RO Reactor Operator ROC Reactor Operations Committee SHP Senior Health Physicist

-2-SRO Senior Reactor Operator SSCs Structures, Systems, and Components TLD Thermoluminescent Dosimeter TSs Technical Specifications TRIGA Training Reactor and Isotopes Production, General Atomics WSR Work Surveillance Report