IR 05000186/2005201

NRC Inspection Report No. 05000186-05-201, University of Missouri-Columbia, April 11-14, 2005

ML051250585
Person / Time
Site:	University of Missouri-Columbia
Issue date:	05/13/2005
From:	Madden P NRC/NRR/DRIP/RNRP
To:	Rhonda Butler Univ of Missouri - Columbia
Witt K, NRC/NRR/DRIP/RNRP, 415-4075
References
50-186/05-201 50-186/05-201
Download: ML051250585 (18)

Text

SUBJECT:

NRC INSPECTION REPORT NO. 50-186/2005-201

Dear Mr. Butler:

This letter refers to the inspection conducted on April 11-14, 2005, at your University of Missouri - Columbia Research Reactor facility. The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress. Based on the results of this inspection, no safety concerns or noncompliances of NRC requirements were identified.

No response to this letter is required.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions concerning this inspection, please contact Craig Bassett at 404-562-4712 or Kevin Witt at 301-415-4075.

Sincerely,

/RA/

Patrick M. Madden, Section Chief Research and Test Reactors Section New, Research and Test Reactors Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No. 50-186 License No. R-103 Enclosures: NRC Inspection Report No. 50-186/2005-201 cc w/enclosure: Please see next page

University of Missouri-Columbia Docket No. 50-186 cc:

University of Missouri Associate Director Research Reactor Facility Columbia, MO 65201 A-95 Coordinator Division of Planning Office of Administration P.O. Box 809, State Capitol Building Jefferson City, MO 65101 Mr. Ron Kucera, Director Intergovernmental Cooperation and Special Projects Missouri Department of Natural Resources May 13, 2005

SUBJECT:

NRC INSPECTION REPORT NO. 50-186/2005-201

Dear Mr. Butler:

This letter refers to the inspection conducted on April 11-14, 2005, at your University of Missouri - Columbia Research Reactor facility. The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress. Based on the results of this inspection, no safety concerns or noncompliances of NRC requirements were identified.

No response to this letter is required.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions concerning this inspection, please contact Craig Bassett at 404-562-4712 or Kevin Witt at 301-415-4075.

Sincerely,

/RA/

Patrick M. Madden, Section Chief Research and Test Reactors Section New, Research and Test Reactors Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No. 50-186 License No. R-103 Enclosure: NRC Inspection Report No. 50-186/2005-201 cc w/enclosure: See next page DISTRIBUTION:

PUBLIC RNRP/R&TR r/f AAdams CBassett PDoyle TDragoun WEresian SHolmes DHughes EHylton PIsaac WBeckner PMadden MMendonca KWitt PYoung RidsNrrDrip BDavis (Ltr only O5-A4) DBarss (MS O6-H2)

NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)

ACCESSION NO.: ML051250585 TEMPLATE #: NRR-106 OFFICE RNRP:RI RNRP:RI RNRP:LA RNRP:SC NAME KWitt CBassett EHylton PMadden DATE 5/11/2005 / /2005 5/11/2005 5/11/2005 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-186 License No.: R-103 Report No.: 50-186/2005-201 Licensee: Curators of the University of Missouri - Columbia Facility: University of Missouri - Columbia Research Reactor Location: Research Park Columbia, Missouri Dates: April 11-14, 2005 Inspectors: Craig Bassett Kevin Witt Approved by: Patrick M. Madden, Section Chief Research and Test Reactors Section New, Research and Test Reactors Program (RNRP)

Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY University of Missouri - Columbia Report No.: 50-186/2005-201 This routine, announced inspection included onsite review of various aspects of the licensee's programs concerning radiation protection, environmental monitoring, and transportation of radioactive material as they relate to the licensees 10 Megawatt, Class I Research Reactor.

The licensee's programs were directed toward the protection of public and facility worker health and safety and were in compliance with NRC requirements. No safety concerns or violations of regulatory requirements were identified.

Organization and Staffing

! The licensee's organization and staffing were in compliance with the requirements specified in Technical Specifications Section 6.1.

Review and Audit Functions

! Review and oversight functions required by Technical Specifications Section 6.1 were acceptably completed by the Reactor Advisory Committee.

Radiation Protection

! Surveys were completed and documented as outlined in the Annual Report.

! Postings met regulatory requirements.

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

! Radiation survey and monitoring equipment was being maintained and calibrated as required.

! The Radiation Protection and ALARA Programs satisfied regulatory requirements.

! Annual reviews of the Radiation Protection Program were being completed by the licensee as required by 10 CFR Part 20.

! Radiation protection training was being conducted and was acceptable.

Effluent and Environmental Monitoring

! Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and Technical Specifications limits.

Transportation of Radioactive Materials

! Radioactive material was generally being shipped in accordance with the applicable regulations.

REPORT DETAILS Summary of Plant Status The University of Missouri - Columbia Research Reactor (MURR) continued to be operated in support of isotope production, gemstone irradiation, reactor operator training, and various types of research. During the inspection, the reactor was started-up and operated continuously during the week to support laboratory experiments and product irradiation.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69006)

To verify that the staffing and organizational structure requirements were being met as specified in Technical Specifications (TS), Section 6.1, Amendment No. 33, dated January 29, 2004, the inspectors reviewed:

• current MURR organizational structure

• administrative controls and management responsibilities

• staffing requirements for safe operation of the facility b. Observations and Findings The inspectors noted that the organizational structure had not changed since the last inspection in the area of radiation protection (refer to NRC Inspection Report No.

50-186/2004-201). The Assistant Reactor Manager of Engineering position, which had been open since the last inspection, has been filled by a recent graduate in civil engineering. One health physics technician had also been hired since the last inspection. The individuals filling these positions have worked at the facility previously and were well qualified to assume their respective duties.

The organization and staffing at the facility, required for reactor operation, were as specified in the TS. Qualifications of the staff met program requirements. Review of records verified that management responsibilities were discharged as required by applicable procedures.

c. Conclusions The licensee's organization and staffing were in compliance with the requirements specified in TS Section 6.1.

2. Review and Audit 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 Section 6.1, the inspectors reviewed:

• MURR Reactor Advisory Committee (RAC) meeting minutes, and related documents, from July 2004 to the present

• Selected Subcommittee meeting minutes from February 2005 to the present including the Isotope Use Subcommittee, the Reactor Safety Subcommittee, and the Procedure Review Subcommittee

• Radiation Protection Plan Audit for 2004

• Annual MURR Type B Shipping Audit and Response for 2004

• Annual Review of MURR Type B Quality Assurance Program - Low Level Waste Shipping for 2004

• Audit of the Type A Radioactive Material Shipping Program at MURR for 2004

• Radiological Control Procedures Audit for 2004

• Selected audits and reviews completed by various management and Health Physics (HP) personnel b. Observations and Findings The inspectors reviewed the meeting minutes of the RAC and the meeting minutes of various subcommittees from July 2004 to the present. The minutes, and associated documents, indicated that the committee met at the required frequency and that a quorum was present. The topics considered during the meetings were appropriate and as stipulated in the TS.

A subcommittee of the RAC or other designated persons, including HP personnel, conducted audits and reviews as required and the full RAC reviewed the results.

The responses to the audits were written by the responsible personnel and ensured proper followup with issues identified in the audit. The inspectors noted that there were no significant issues discovered and that the licensee took appropriate corrective actions in response to the audit findings. The inspectors verified that the licensee had completed annual reviews of the Radiation Protection Program as required by 10 CFR Part 20. All aspects of the program had been reviewed. The inspectors 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. As part of the radiation protection program, an audit of the ALARA program is typically conducted on an annual basis. The licensee did not complete this audit for 2004 and is in the process of completing the document, which will be finished before the next inspection. This issue will be considered by the NRC as an Inspector Follow-up Item (IFI) and will be reviewed during the next inspection at the facility (IFI 50-186/2005-201-01).

c. Conclusions Review and oversight functions required by the TS were acceptably completed by the RAC.

3. Radiation Protection a. Inspection Scope (IP 69012)

The inspectors reviewed the following to verify compliance with 10 CFR Part 20 and the applicable licensee TS requirements and procedures:

• Selected radiation and contamination survey records for the past year

• Radiological signs and posting in various laboratories and in the Beam Port Floor area

• MURR dosimetry records for 2004

• Dose Report Review Forms for January 2004 - November 2004

• MURR Reactor Operations Annual Reports for 2004

• Calibration and periodic check records for selected radiation survey and monitoring instruments for the past year

• radiation protection training program records

• MURR Center Security, Emergency, and Health Physics Indoctrination Booklet last updated March 30, 2004

• MURR Corrective Action Program (CAP) reports concerning radiation protection for 2004 through the present

• Semi-Annual Calibration of the Eberline PING Stack Monitor, dated January 7, 2005

• Semi-Annual Calibration of the NMC-RAK Stack Monitor, dated March 24, 2005

• MURR Procedure AP-HP-105, Radiation Work Permit, Rev. 3, dated March 16, 2004, and the associated form, Form FM-17, Radiation Work Permit

• MURR Procedure AP-HP-117, MURR Initial Radiation Worker Training Program, Rev. 6, dated January 12, 2005, and the associated forms, Form FM-26, MURR Training Questionnaire, and Form FM-29, Initial Training Packet

• MURR Procedure AP-HP-125, Review of Unplanned Radiation Exposure, Rev. 0, dated January 31, 2003

• MURR Procedure IC-HP-300, Calibration - Radiation Survey Instruments, Rev. 3, dated March 3, 2005, and the associated form, Form FM-62, Radiation Instrument Certificate of Calibration

• MURR Procedure IC-HP-333, Calibration - Eberline BC-4 Beta Swipe Counter, Rev. 3, dated January 10, 2005

• MURR Procedure IC-HP-335, Calibration - Portal Monitor Gamma-60

- S/N 900644, Rev. 3, dated January 10, 2005

• MURR Procedure OP-HP-220, Tritium Bioassay, Rev. 2, dated April 28, 2004

• MURR Procedure RP-HP-100, Contamination Monitoring - Performing a Swipe, Rev. 3, dated February 4, 2005

• MURR Procedure RP-HP-120, Personnel Radioactive Contamination, Rev. 3, dated May 8, 2003, and the associated forms, Form FM-54, Report of Personnel Contamination, and Form FM-76, Personnel Contamination Log

• MURR Procedure SV-HP-119, Property Release, Rev. 1, dated April 8, 2003 The inspectors also toured the licensee's facility, conducted a radiation survey in laboratory areas of the reactor building, witnessed the use of dosimetry and survey meters, and observed the area where calibrations of radiation monitoring equipment are conducted. Licensee personnel were interviewed as well.

b. Observations and Findings (1) Surveys Daily, monthly, and other periodic contamination and radiation surveys, outlined in the licensees Reactor Operations Annual Report for 2004, were completed by HP staff members. Any contamination detected in concentrations above established action levels was noted and the area was decontaminated. Results of the surveys were typically documented on survey maps and posted at the entrances of the various areas surveyed so that facility workers would be knowledgeable of the radiological conditions that existed therein.

During the inspection the inspectors accompanied a health physics technician on a routine radiation survey of laboratory areas throughout the reactor building. The radiation levels noted were similar to those detected by the licensee and listed on survey maps of the areas. No anomalies were noted.

(2) Postings and Notices Copies of current notices to workers were posted in appropriate areas in the facility. Radiological signs and survey maps 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. 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 on the main bulletin board, in main hallways, and at the entrance to the Beam Port Floor area.

(3) Dosimetry The inspectors determined that the licensee used optically stimulated luminescent (OSL) dosimetry for whole body monitoring and thermoluminescent dosimeters (TLDs) in the form of finger rings and wrist badges for extremity monitoring. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor. An examination of the OSL 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. The records showed that approximately half of the facility personnel received occupational exposures of zero (0) to only a few millirem above background. The highest annual whole body exposure received by a single individual for 2004 was 1093 millirem. The highest annual extremity exposure for 2004 was 2690 millirem. Review of exposure records showed that the operations group received approximately 60% of the facilitys annual dose for 2004. The facility also collected and analyzed urine samples for Tritium bioassay purposes. The lowest attributable dose in 2004 for H-3 was 1.23 millirem.

Through direct observation the inspectors determined that dosimetry was acceptably used by facility and contractor personnel. The inspectors also verified that no unplanned single exposures (greater than 5% of any federal regulation limit) had occurred during the previous year.

(4) Radiation Monitoring Equipment Examination of selected radiation monitoring equipment indicated that the instruments had the acceptable up-to-date calibration sticker attached. The instrument calibration records indicated that the calibration of certain portable survey meters (friskers) was typically completed by licensee staff personnel.

Other instruments, such as high range ion chambers and neutron detectors that could not be calibrated by the licensee, were shipped to vendors for calibration.

Calibration frequency met procedural requirements and records were maintained as required. Area Radiation Monitors (ARMs) and stack monitors were also being calibrated as required. These monitors were typically calibrated by licensee staff personnel.

The inspectors reviewed weekly checks for the portal monitors throughout the facility. It was noted that a portion of the lobby portal monitor printouts that verify the weekly checks could not be located. Weekly diagnostic and source alarm checks were missing in between the dates of November 19, 2004 to December 2, 2004, January 21, 2005 to February 10, 2005 and March 2, 2005 to March 24, 2005. MURR Procedure IC-HP-335, Calibration - Portal Monitor Gamma-60 - S/N 900644, specifies that this check must be conducted on a weekly basis, not to exceed nine days. The licensee indicated that the checks had been made but that the forms were apparently missing. The inspectors noted that the completion of the checks was indicated on weekly assignment sheets which were initialed by the HP Technicians who had been assigned that responsibility during the weeks in question. Even though the checks were apparently completed, the issue of properly maintaining the lobby portal monitor printouts will be considered by the NRC as an Inspector Follow-up Item (IFI)

and will be reviewed during the next inspection at the facility (IFI 50-186/2005-201-02).

During the inspection, the inspectors visited the calibration range located in the MU Environmental Health and Safety Department building. A HP technician who conducts calibrations for non-licensee detectors described the equipment in the facility for the inspectors. The calibrations are typically conducted by two licensee employees, an Electronics Technician and an HP Technician. The calibration records reviewed were thorough and were completed using the appropriate techniques and according to procedure. The inspectors observed that proper precautions are used to maintain doses ALARA.

(5) Radiation Protection Program The licensees Radiation Protection and ALARA programs were established and described in the MURR Radiation Protection Program Manual dated March 1, 2004, and 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 inspectors 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, which was consistent with the guidance in 10 CFR Part 20, provided guidance for keeping doses as low as reasonably achievable.

The inspectors reviewed the licensees efforts to reduce the facilitys collective dose by challenging each work or support group to set a goal of reducing their annual exposure by two percent (2%). The goal of reducing annual exposure in 2004 is less then what it was in 2003 due to the increasing amount of facility operations. The licensee found it appropriate to still reduce the amount of dose received although it was not feasible to lower it by as much as last years goal of five percent (5%).

The licensee was persistent and aggressive in tracking doses on a monthly basis. Any doses that exceed certain limits for a monthly period are tracked and reviewed based on levels described in the licensees procedures. Each group in the facility receives a report on a monthly basis listing individuals doses and the collective dose for the group, as well as their performance compared to the goals set for the group. It was noted that approximately half of the groups at the facility had a net reduction in collective dose for 2004. The reduction was attributed largely to keeping everyone constantly aware of ALARA.

(6) Radiation Work Permit Program TS Section 6.1.b requires that written procedures shall be in effect for operations of the reactor, emergencies, radiological control, and the preparation of shipping and the shipping of byproduct material produced under the reactor license.

The inspectors reviewed all Radiation Work Permits (RWPs) that had been written, used, and closed out during the first part of 2005. It was noted that the instructions specified in MURR Procedure AP-HP-105, Radiation Work Permit, Rev. 2, dated October 28, 2003, Attachment 7.1, Form FM-17, Radiation Work Permit Instructions had been adequately followed. Appropriate review by management and health physics personnel had been conducted. The controls specified in the RWPs were acceptable and applicable for the type of work being done. Overall, the use of RWPs has helped to lower the amount of dose received to workers in situations that require careful planning and coordination.

(7) Radiation Protection Training The inspectors reviewed the training given to MURR staff members, to those who are not on staff but who are authorized to use the experimental facilities of the reactor, and to visitors. The training satisfied the requirements of 10 CFR Part 19 and the training program was acceptable. It was noted that the annual refresher training for all staff personnel had been conducted during the months of September through November 2004.

(8) Facility Tours The inspectors toured the Beam Port Floor area and selected support laboratories with licensee representatives on various occasions. The inspectors noted that facility radioactive material storage areas were properly posted. No unmarked radioactive material was noted. Radiation and High Radiation Areas were posted as required.

c. Conclusions The inspectors determined that the Radiation Protection and ALARA Programs, as implemented by the licensee, satisfied regulatory requirements because: 1) surveys were completed and documented acceptably to permit evaluation of the radiation hazards present; 2) postings 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; 5) the Radiation Protection Program was acceptable and was being reviewed annually as required; and, 6) the radiation protection training program was acceptable.

4. Effluent and Environmental Monitoring a. Inspection Scope (IP 69004)

The inspectors reviewed the following to verify compliance with the requirements of 10 CFR Part 20 and TS Section 3.7:

• the environmental monitoring program outlined through various procedures

• MURR Reactor Operations Annual Report for 2004

• annual effluent monitoring and environmental surveillance program reports

• 2004 Dose to Individual Members of the Public, letter from Ron Dobey, dated March 11, 2005

• Counting and analysis records contained in the Health Physics Computer Folder Environmental Reports

• MURR Procedure IC-HP-310, Calibration - Eberline Model PING 1A Stack Monitor - Particulate Channel, Rev. 3, dated February 10, 2005

• MURR Procedure IC-HP-311, Calibration - Eberline Model PING 1A Stack Monitor - Iodine Channel, Rev. 3, dated February 10, 2005

• MURR Procedure IC-HP-312, Calibration - Eberline Model PING 1A Stack Monitor - Gas Channel, Rev. 2, dated February 10, 2005

• MURR Procedure OP-HP-220, Air Sampling - Containment Building Tritium, Rev. 1, dated November 25, 2003

• MURR Procedure OP-HP-221, Environmental Sample - Analysis, Rev. 2, dated February 17, 2004

• MURR Procedure OP-HP-222, Air Sampling - Containment Building Ar-41, Rev. 1, dated December 15, 2003

• MURR Procedure OP-HP-353, Waste Tank Sample - Analysis, Rev. 1, dated February 17, 2004

• MURR Procedure SV-HP-121, Building Exhaust Stack Effluent - Ar-41 Monitoring, Rev. 0, dated March 20, 2002

b. Observations and Findings The inspectors determined that gaseous releases continued to be monitored as required, were acceptably documented, and were within the annual dose constraints of 10 CFR 20.1101 (d), Appendix B concentrations, and TS Section 3.7 limits as shown by COMPLY calculations. The main isotope being emitted from the facility stack was Argon-41, which is an activation product of air. The licensee set investigational levels for emitted isotopes at 85% of the annual TS limit to be reviewed on a monthly basis. The average concentration for Ar-41 release for several months last year exceeded these levels and the licensee analyzed it as required by procedure. Since the licensee cannot reduce this particular emission from the facility without affecting research and development, the licensee will continue investigating alternate methods of reducing Ar-41 emissions. This issue will be considered by the NRC as an Inspector Follow-up Item (IFI) and will be reviewed during the next inspection at the facility (IFI 50-186/2005-201-03). The liquid releases from the facility to the sanitary sewer were within the limits specified in 10 CFR 20, Appendix B, Table 3.

Environmental soil, water, and vegetation samples were collected, prepared, and analyzed consistent with procedural requirements. 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 as well. The inspectors reviewed the calculations for the annual environmental TLD summary and noticed that negative doses are being added into the year end doses.

General health physics practice dictates that assigning a negative number to a dose is unacceptable. The licensee was asked to consider assigning a dose of zero instead of a negative number to prevent any confusion on this subject. This issue will be considered by the NRC as an Inspector Follow-up Item (IFI) and will be reviewed during the next inspection at the facility (IFI 50-186/2005-201-04). The review of data indicated that there were no measurable doses above any regulatory limits. The highest unrestricted area dose rate was located on the University golf course near the 12th tee approximately 65 meters from the MURR stack and read 15.5 millirem for 2004.

The above results were acceptably reported in the Reactor Operations Annual Report for 2004. Observation of the facility by the inspectors found no new potential release paths.

c. Conclusion Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

5. Transportation a. Inspection Scope (IP 86740)

To verify compliance with regulatory and procedural requirements for transferring or shipping licensed radioactive material, the inspectors reviewed the following:

• selected records of various types of radioactive material shipments

• MURR CAP reports concerning transportation for 2004 through the present

• Certificate of Compliance documentation and test results for DOT 7A, Package Identification - MURR model 1220

• MURR Procedure AP-SH-001, Radioactive Materials Shipping, Rev. 3, dated April 4, 2005

• MURR Procedure BPB-SH-005, DOT 6M Packaging and Shipment of Type B Non-Waste Radioactive Material, Rev. 2, dated October 7, 2004

• MURR Procedure BP-SH-037, Packaging of Non-Waste Radioactive Material Using MURR Model 1220, Rev. 21, dated April 20, 2004

• MURR Procedure WM-SH-100, Radioactive Waste - Preparation and Storage, Rev. 2, dated March 4, 2004

• MURR Procedure WM-SH-300, Exclusive Use Shipment of LSA or SCO Radioactive Waste, Rev. 1, dated July 1, 2004 b. Observations and Findings Through records review and discussions with licensee personnel, the inspectors determined that 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. All radioactive material shipment records reviewed by the inspectors had been completed in accordance with Department of Transportation (DOT) and NRC regulations.

The inspectors verified that the licensee maintained copies of shipment recipients licenses to possess radioactive material as required and that the licenses were verified to be current prior to initiating a shipment. The training of the staff members responsible for shipping the material was also reviewed. The inspectors verified that the shippers training met DOT requirements.

The inspectors observed a shipment of radioactive waste from the facility as well as several radioisotopes. The shipment of radioactive waste was classified as limited surface activity and therefore was exempt from marking and labeling requirements as specified in 49 CFR 173.427(a)(6)(vi). The inspectors verified that this shipment was conducted as an exclusive use shipment and saw that the proper precautions were taken by the licensee and the carrier. During review of Attachment 10.1 to Procedure WM-SH-300, which is the procedural checklist for shipment of LSA radioactive waste, the inspectors noted that there were additional requirements (Section 3, Step 4.a) for labeling the package with the appropriate LSA number (i.e. LSA-I, LSA-II or LSA-III).

The inspectors noted that this is not required by the regulations nor is it practiced by the licensee. The licensee agreed to modify the procedure to accurately reflect what is currently practiced in accordance with Federal Transportation regulations. This issue will be considered by the NRC as an Inspector Follow-up Item (IFI) and will be reviewed during the next inspection at the facility (IFI 50-186/2005-201-05).

The inspectors also observed three shipments of radioisotopes. One shipment was classified as White-I and was contained in Type A packaging. The other two shipments were classified as Yellow-III packages and utilized Type B(U) packaging.

The inspectors verified that the shipping papers for all packages contained the appropriate information and that the appropriate markings were made on the outside of the packages. Documentation for MURR Type A packaging tests were successfully

conducted in 1991. Proper techniques were followed in conducting the surveys of the packages as well as the quality assurance checks of the shipments. The staff conducting these shipments were well-versed in thorough review of all documentation. The shipping staff paid careful attention to detail, utilized the STAR concept (Stop, Think, Act, Review) training, and made improvements in human performance and achieving excellence while minimizing human error. This item closes out IFI 50-186/2004-201-03).

c. Conclusions Radioactive material was generally being shipped in accordance with the applicable regulations.

6. Exit Interview The inspection scope and results were summarized on April 14, 2005, with members of licensee management and staff. The inspectors 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 inspectors during the inspection as proprietary. No dissenting comments were received from the licensee.

PARTIAL LIST OF PERSONS CONTACTED Licensee C. Allen, CAP Coordinator M. Ballew, Health Physics Technician R. Butler, Director of MURR M. Diaz de Leon, Health Physics Technician R. Dobey, Manager, Health Physics J. Ernst, Associate Director, Regulatory Assurance Group L. Foyto, Reactor Manager A. Gaddy, Document Control Coordinator J. Hemphill, Health Physicist S. Kelley, Health Physics Technician K. Kutikkad, Assistant Reactor Manager, Physics C. McKibben, Associate Director R. Maxey, Shipping Technician S. Meier, Manager, Radioactive Materials Shipping W. Meyer, Chief Operation Officer N. Pearson, Shipping Technician C. Roberts, Shipping Technician INSPECTION PROCEDURES USED IP 69004: Class 1 Research and Test Reactor Effluent and Environmental Monitoring IP 69006: Class 1 Research and Test Reactor Organization, Operations, and Maintenance Activities IP 69007: Class 1 Research and Test Reactor Review and Audit and Design Change Functions IP 69012: Class 1 Research and Test Reactor Radiation Protection IP 86740: Inspection of Transportation Activities OPENED, CLOSED, AND DISCUSSED Opened 50-186/2005-201-01 IFI Follow-up on the completion of an audit of the ALARA program for 2004 as described in the Radiation Protection Program Manual dated March 1, 2004.

50-186/2005-201-02 IFI Follow-up to ensure that diagnostic and source alarm checks for the facility portal monitors are conducted and properly documented on a weekly basis.

50-186/2005-201-03 IFI Follow-up on the development of alternate methods to reduce Ar-41 emissions below facility investigational levels.

-2-50-186/2005-201-04 IFI Follow-up to determine the licensees actions concerning assigning a value of zero instead of a negative number for the summation of the annual environmental TLD summary.

50-186/2005-201-05 IFI Follow-up on the removal of the requirement to label limited surface activity packages with the appropriate LSA number (i.e.

LSA-I, LSA-II or LSA-III) in MURR Procedure WM-SH-300, Exclusive Use Shipment of LSA or SCO Radioactive Waste, Rev. 1, dated July 1, 2004, Section 3, Step 4.a.

Closed 50-186/2004-201-03 IFI Follow-up on the subject of attention to detail, the STAR concept (Stop, Think, Act, Review) training, and potential improvements in human performance and achieving excellence while minimizing human error.

LIST OF ACRONYMS USED ARM Area Radiation Monitor ALARA As low as reasonably achievable CAP Corrective Action Program CFR Code of Federal Regulations DOE Department of Energy DOT Department of Transportation HP Health physics IFI Inspector Follow-up Item IP Inspection Procedure LSA Limited Surface Activity mCi Millicurie MURR University of Missouri - Columbia Research Reactor NCV Non-Cited Violation NRC Nuclear Regulatory Commission OSL Optically stimulated luminescent (dosimeter)

PSP Physical Security Plan PDR Public Document Room RAC Reactor Advisory Committee RWP Radiation Work Permit SNM Special Nuclear Material TLD Thermoluminescent dosimeter TS Technical Specification