IR 05000274/2023202
| ML23270B190 | |
| Person / Time | |
|---|---|
| Site: | U.S. Geological Survey |
| Issue date: | 11/13/2023 |
| From: | Tate L NRC/NRR/DANU/UNPO |
| To: | Mahan S US Dept of Interior, Geological Survey (USGS) |
| Kevin Roche, NRR/DANU | |
| References | |
| Download: ML23270B190 (14) | |
Text
November 9, 2023
SUBJECT:
U.S. GEOLOGICAL SURVEY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000274/2023202
Dear Ms. Mahan:
From August 21-24, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the U.S. Geological Survey TRIGA Research Reactor facility. The enclosed report documents the inspection results, which were discussed on August 24, 2023, with you and 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 inspectors reviewed selected procedures and records, observed various activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Kevin Roche at 301-415-1554, or by email at Kevin.Roche@nrc.gov.
Sincerely, Signed by Tate, Travis on 11/09/23 Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-274 License No. R-113 Enclosure:
As stated cc: GovDelivery Subscribers
ML23270B190 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME KRoche JArellano NParker TTate DATE 11/6/2023 11/7/2023 11/9/2023 11/9/2023
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-274 License No.: R-113 Report No.: 05000274/2023202 Licensee: U.S. Geological Survey Facility: U.S. Geological Survey TRIGA Research Reactor Location: Building 15, Denver Federal Center Denver, Colorado Dates: August 21-24, 2023 Inspectors: Kevin M. Roche Juan A. Arellano Approved by: Travis L Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure
EXECUTIVE SUMMARY U.S. Geological Survey U.S. Geological Survey TRIGA Research Reactor Inspection Report No. 05000274/2023202 The primary focus of this routine announced inspection was the on-site review of selected aspects of the U.S. Geological Survey (USGS or licensee) Class II research reactor facility safety program including: (1) procedures; (2) experiments, (3) health physics; (4) design changes; (5) committees, audits and reviews; and (6) transportation activities. The U.S. Nuclear Regulatory Commission (NRC) staff determined that the licensees program was acceptably directed toward the protection of public health and safety, and in compliance with NRC requirements.
Procedures
- The inspectors found that procedural review, revision, control, and implementation satisfied the technical specification (TS) requirements.
Experiments
- The inspectors found that experiments and irradiations were performed in accordance with TSs, the applicable experiment irradiation authorizations, and associated licensee procedures.
Health Physics
- The inspectors found that surveys, postings, and personnel dosimetry met regulatory requirements.
- The inspectors found that radiation monitoring equipment was maintained and calibrated as required by TSs.
- The inspectors found that calculations of effluents released from the facility satisfied license and regulatory requirements and releases were within the specified regulatory limits.
Design Changes
- The inspectors found that changes to the facility were evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests and experiments, and were reviewed and approved by the Reactor Operations Committee (ROC).
Committees, Audits and Reviews
- The inspectors found that review, audit, and oversight functions required by the TSs were acceptably completed by the ROC.
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Transportation Activities
- The inspectors found that radioactive material was shipped in accordance with the applicable regulations.
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REPORT DETAILS Summary of Facility Status The licensees 1 megawatt Training, Research, Isotopes, General Atomics (TRIGA) research reactor was operated in support of various types of irradiation projects. During the inspection, the reactor was shut down for fuel inspection activities.
1. Procedures a. Inspection Scope (Inspection Procedure (IP) 69001, Section 02.03)
The inspectors reviewed the following documents to verify compliance with the licensees TS requirements for procedures:
- procedural implementation by the reactor staff
- records of changes and temporary changes to procedures
- reactor operations manual (ROM) sections No. 4, Administrative Procedures, No. 5, Operating Procedures
- ROM Section 8, Radiation Protection Program"
- signed cover sheets for the following procedures:
o Geological Survey Test Reactor (GSTR) Procedure #25, "Procedure for visual verification of (1) aluminum-clad fuel element locations and (2)
number of elements in reactor core" o GSTR Procedure #26, "Procedure for calibration of water temperature instrument" o GSTR Procedure #28, "Procedure for testing and inspecting the transient rod"
- ROC meeting minutes for meetings held from October 2021 to the present b. Observations and Findings The inspectors reviewed the facility procedures and the processes to write, review, approve, and change procedures. The inspectors noted that facility procedures were developed as required by TS 6.4. The inspectors confirmed that procedures were written, reviewed, approved, and changed in accordance with TS 6.2.3.1 and the ROM. During the inspection, the inspectors observed licensee staff following procedures to complete tasks. Additionally, the inspectors found that the procedures used were effective and able to be implemented for the intended purposes.
c. Conclusion The inspectors determined that procedural review, revision, control, and implementation satisfied TS requirements.
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2. Experiments a. Inspection Scope (IP 69001, Section 02.06)
The inspectors reviewed the following to verify compliance with TS 3.8 and 6.4:
- experiment program requirements contained in ROM sections 4.5 through 4.8
- GSTR experiment authorization forms including Parts I, II, and III for Experiment Nos.: C-058, L-128, C-043
- selected GSTR radioisotope request and receipt forms which were completed during December 2019 through the present
- ROC meeting minutes for meetings held from October 2021 to present
- USGS TRIGA Reactor corrected annual report for the period from January 1, 2021, through December 31, 2021, dated March 31, 2022
- USGS TRIGA Reactor annual report for the period from January 1, 2022, through December 31, 2022, dated March 28, 2023
- selected experiment reports from 2021 - present b. Observations and Findings The inspectors found that the various experiments conducted at the facility were reviewed and approved in accordance with licensees procedures. The inspectors also noted that no new experiments were proposed in the past several years.
The inspector noted that irradiations were conducted under the cognizance of the Reactor Supervisor. The inspectors verified that irradiations were documented in the console logs. The inspectors also verified that the resulting radioactive material was transferred to an authorized user, disposed of as stipulated by procedure, or held for decay.
c. Conclusion The inspectors concluded that experiments were reviewed and performed in accordance with the TS requirements and the licensees written procedures.
3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)
The inspectors reviewed the following documents to verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, Standards for Protection against Radiation, and TS requirements for health physics:
- radiological signs and posting in various areas of the facility
- training records for GSTR staff and various support personnel
- health physics quarterly reports from 2021 to date
- routine periodic survey and monitoring records for the past 2 years documented on radiological survey maps
- maintenance and calibration records of radiation monitoring equipment for the past 2 years documented in the instrument calibration log
- GSTR radiation protection program as outlined in ROM, chapter 8, dated April 2020
- SP-20G-R00, "Radiation Monitoring Calibration," dated May 31, 2023
- completed form RP-20-F01, "Radiation Area Monitor Calibration," dated January 11, 2022
- SP-20E-R01, "Continuous Air Monitor Maintenance and Calibration," dated May 31, 2023
- completed, "CAM Calibration Form," dated March 24, 2023 b. Observations and Findings (1) Surveys The inspectors found radiation and contamination surveys were completed as required by procedures and in accordance with the requirements in Subpart F, Surveys and Monitoring, to 10 CFR Part 20.
During the inspection, the inspectors confirmed the radiation survey readings to verify that radiation levels were consistent with expected radiation levels.
(2) Postings and Notices The inspectors toured the facility and observed that signage, posting, and labels were used in accordance with requirements in Subpart J, Precautionary Procedures, to 10 CFR Part 20. The inspectors verified that radioactive material storage areas were properly posted. The inspectors also verified that no unmarked radioactive material was detected in the facility. The inspectors observed that copies of notices to workers were posted in the facility, including a copy of the most recent revision of NRC Form 3, Notice to Employees, as required by 10 CFR 19.11, Posting of notices to workers.
(3) Dosimetry The inspectors determined that the licensee monitored individuals for radiation exposure in accordance with the requirements in 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose. The inspectors confirmed that the highest occupational doses were within Subpart C, Occupational Dose Limits, to 10 CFR Part 20 limits and licensee action levels.
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(4) Radiation Monitoring Equipment The inspectors found that annual calibration and quarterly source check frequency of the portable and fixed meters and monitors were consistent with manufacturers recommendations and appropriate calibration records were maintained. The inspectors found that portable survey meters were maintained as required by TS 4.7, and Subpart F to 10 CFR Part 20.
The inspectors observed storage and use of portable survey instrumentation at the facility. The inspectors found that survey instrumentation capable of measuring exposure and dose rates were available and operable during times when the reactor was operating as required by TS 3.7.1.
(5) Radiation Protection Training The inspectors verified that radiation protection training was provided to new users as well as annually to staff members. The inspectors found the content of the training program satisfied the requirements in 10 CFR 19.12, Instruction to workers.
(6) Radiation Safety Program The inspectors found that the licensees radiation protection program was acceptably established in the ROM. The inspectors found that the health physicist reviewed the radiation safety program quarterly in accordance with licensee procedures. The inspectors confirmed that no deficiencies related to the radiation safety program at the GSTR were identified during reviews of the program.
(7) As Low as Reasonably Achievable Policy The inspectors found that a policy for maintaining radioactive exposure to personnel as low as reasonably achievable (ALARA) was outlined and established in the ROM. The inspectors confirmed that the policy discussed and set expectations for radiation safety culture and provided guidance for keeping doses ALARA, including local action levels for personnel radiation exposure doses, consistent with the requirements in 10 CFR 20.1101, Radiation protection programs.
(8) Environmental Monitoring and Effluents The inspectors found that the area radiation monitors, and gaseous effluent (or stack) monitor systems were routinely tested and calibrated annually in accordance with the requirements in TS 4.7. During the inspection, the inspectors observed these systems operating while the reactor was in operation, as required by TS 3.7.
The inspectors verified that no releases of solid radioactive material to the environment occurred and no liquid radioactive material releases from operation of the GSTR occurred during the period reviewed. The-7-
inspectors determined that gaseous radioactive material release activity continued to be calculated and the results were documented. The inspectors found that releases were determined to be within the concentrations specified in Appendix B, Annual Limits on intake (ALIs)
and Derived Air Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage, to 10 CFR Part 20, and TS limits. The inspectors found the highest calculated dose that could be received by a member of the public because of gaseous emissions from reactor operations was determined to be well below the requirements of 10 CFR 20.1101(d).
The inspectors verified that environmental gamma radiation monitoring was conducted using thermoluminescent dosimeters in accordance with the applicable procedures. The inspectors found the data indicated that there were no radiation doses in uncontrolled areas from operation of the reactor that would result in a member of the public exceeding the limits in Subpart D, Radiation Dose Limits for Individual Members of the Public, to 10 CFR Part 20.
c. Conclusion The inspectors determined that the radiation protection program implemented by the licensee satisfied regulatory requirements.
4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)
The inspectors reviewed the following documents to verify compliance with 10 CFR 50.59 and TS requirements for design changes:
- facility design change (10 CFR 50.59) records for the past 2 years
- ROC meeting minutes for meetings held from October 2021 to present
- ROM, section 3, Nuclear Center Organization, and section 4, Administrative Procedures
- USGS TRIGA Reactor corrected annual report for the period from January 1, 2021, through December 31, 2021, dated March 31, 2022
- USGS TRIGA Reactor annual report for the period from January 1, 2022, through December 31, 2022, dated March 28, 2023 b. Observations and Findings The inspectors found that the facility design change evaluations contained adequate supporting documentation and information required by procedure.
Additionally, the inspectors found that the ROC reviewed proposed changes in accordance with the requirement in TS 6.2.3.
c. Conclusion The inspectors determined that changes to the facility were evaluated using the 10 CFR 50.59 criteria and were reviewed and approved by the ROC.
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5. Committees, Audits and Review a. Inspection Scope (IP 69001)
The inspectors reviewed the following documents to verify compliance with the TS requirements for review and audit:
- ROC operational audits for the last 2 years
- safety review records and audit reports for the past 2 years
- ROC meeting minutes for meetings held from October 2021 to the present
- ROM, section 3, Nuclear Center Organization, and section 4, Administrative Procedures b. Observations and Findings The inspectors found that the composition of the ROC and the meeting frequency satisfied the requirements of TSs 6.2 and 6.2.2. The inspectors verified minutes of these meetings demonstrated that the ROC provided the review and conducted the audits required by the TSs 6.2.3 and 6.2.4. The inspectors found issues brought up by the ROC were resolved in an appropriate time frame and were noted in ROC meeting minutes. The inspectors found that the ROC had the correct number of members in accordance with TS.
c. Conclusion The inspectors found that review, audit, and oversight functions required by the TSs were completed by the ROC.
6. Transportation Activities a. Inspection Scope (IP 86740)
The inspectors reviewed the following documents to verify compliance with the regulations in 10 CFR Part 71, Packaging and Transportation of Radioactive Material, 49 CFR, Transportation:
- training records of staff members responsible for shipping and receiving licensed radioactive material
- select radioactive material shipping forms from 2022 - present
- select, "USGS G-5000W Standard Two Analysis Report," from 2022-present
- select shipping records and surveys from 2022 - present b. Observations and Findings The inspectors found that the licensee shipped various types of radioactive material since the last previous inspection in this area. The inspectors verified that the records indicated radioisotope types and quantities were calculated, and dose rates were measured. The inspectors noted that staff members received the required training and were certified for shipping radioactive material. All-9-
radioactive material shipment records reviewed by the inspectors were completed in accordance with Department of Transportation and NRC regulatory requirements.
c. Conclusion The inspectors determined that radioactive material was shipped in accordance with the applicable regulations and licensee procedures.
7. Exit Interview The inspection scope and results were summarized on August 24, 2023, with members of licensee management and staff. The inspectors described the areas inspected and discussed the inspection results.
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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel C. Farwell Senior Reactor Operator Reactor Administrator C. Manning Reactor Health Physicist and Senior Reactor Operator J. Wallick Reactor Supervisor INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors IP 86740 Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed Discussed Attachment