IR 05000607/2017201
| ML17044A258 | |
| Person / Time | |
|---|---|
| Site: | University of California-Davis |
| Issue date: | 03/03/2017 |
| From: | Anthony Mendiola Research and Test Reactors Oversight Branch |
| To: | Frey W McClellan Nucleaer Research Center, Univ of California |
| Bassett C, NRR/DPR/PROB, 301-466-4495 | |
| References | |
| 50-607/2017-201 | |
| Download: ML17044A258 (18) | |
Text
March 3, 2017
SUBJECT:
UNIVERSITY OF CALIFORNIA-DAVIS - NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-607/2017-201
Dear Dr. Frey:
From January 30 - February 2, 2017, the U.S. Nuclear Regulatory Commission (NRC or the Commission) conducted an inspection at your University of California-Davis/McClellan Nuclear Research Center. The enclosed report documents the inspection results, which were discussed on February 1 and 2, 2017, 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 various 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 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). If 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/
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
Docket No. 50-607 License No. R-130
Enclosure:
As stated
cc: See next page
University of California-Davis/McClellan
Docket No. 50-607
cc:
David Reap, Radiation Safety Officer 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504
Mr. Walter Steingass, Reactor Supervisor 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504
California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814
Radiological Health Branch California Department of Public Health P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414
Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611
ML17044A258; *concurred via email
NRR-002 OFFICE NRR/DPR/PROB*
NRR/DPR/PROB*
NRR/DPR/PROB NAME CBassett NParker AMendiola DATE 3/2/17 3/2/17 3/3/17
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No:
50-607
License No:
R-130
Report No:
50-607/2017-201
Licensee:
University of California-Davis
Facility:
McClellan Nuclear Research Center
Location:
McClellan Park Sacramento, California
Dates:
January 30 - February 2, 2017
Inspectors:
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
University of California-Davis McClellan Nuclear Research Center Inspection Report No. 50-607/2017-201
The primary focus of this routine, announced inspection was the onsite review of selected aspects of the University of California-Davis (the licensees) two Megawatt Class I research reactor safety program including: (1) organizational structure and staffing; (2) review and audit and design control functions; (3) radiation protection program; (4) effluent and environmental monitoring; (5) procedures; and (6) transportation of radioactive materials 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 in compliance with NRC requirements.
Organizational Structure and Staffing
- The organizational structure and staffing were consistent with the requirements specified in Section 6 of the Technical Specifications (TSs).
Review and Audit Functions and Design Control Functions
- The Nuclear Safety Committee was meeting at the required frequency, reviewing the topics outlined in TSs Section 6.2, and conducting audits of facility programs as required.
- The design change and control program, including review, evaluation, and documentation of changes to the facility, satisfied NRC requirements.
Radiation Protection Program
- Surveys were being completed and documented acceptably to permit evaluation of the radiation hazards present.
- Postings met the regulatory requirements specified in Title 10 of the Code of Federal Regulations Parts 19 and 20.
- Personnel dosimetry was being worn as required and doses were within the licensees procedural action levels and NRCs regulatory limits.
- Radiation survey and monitoring equipment was being maintained and calibrated as required.
- Acceptable radiation protection training was being provided to facility personnel.
Environmental Monitoring
- Effluent monitoring satisfied license and regulatory requirements and releases were within the specified TSs levels and regulatory limits.
- Releases were within the specified TSs levels and regulatory limits.
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Procedures
- The procedure review, revision, control, and implementation program satisfied TSs requirements.
- Procedural compliance was acceptable.
Transportation of Radioactive Materials
- Radioactive material was being shipped in accordance with the applicable regulations.
Enclosure
REPORT DETAILS
Summary of Facility Status
The University of California-Davis (UC Davis, or the licensee) two Megawatt training reactor and isotopes production, General Atomics reactor continued to be operated in support of neutron radiography, medical isotope production, neutron tomography, and experimental sample irradiation. During the inspection the reactor was operated several hours per day at power levels varying up to one megawatt to support neutron radiography and sample irradiation.
1.
Organizational Structure and Staffing
a.
Inspection Scope (Inspection Procedure (IP) 69006)
The inspectors reviewed the following regarding the University of California-Davis/McClellan Nuclear Research Center (UCD/MNRC) organization, staffing, and responsibilities to ensure that the requirements of Technical Specifications (TSs) Section 6.1, Revision 13, dated March 28, 2003, were being met:
- Management responsibilities
Current UCD/MNRC organizational structure and staffing
Selected UCD/MNRC Operations Logs and UCD/MNRC Startup Checklists for 2016 documenting shift staffing
UCD/MNRC 2014 Annual Report, submitted to the U.S. Nuclear Regulatory Commission (NRC) on June 29, 2015
UCD/MNRC 2015 Annual Report, submitted to the NRC on June 29, 2016
Facility Procedure UCD/MNRC-0045-DOC-01, Quality Assurance Program for McClellan Nuclear Research Center (MNRC)
b.
Observations and Findings
The organization at the UCD/MNRC was as required by TSs Section 6. The Vice Chancellor for Research was designated as the licensee for the university. The UCD/MNRC facility was under the direct control of the UCD/MNRC Reactor Director, who was accountable and reported to the Vice Chancellor for the safe operation and maintenance of the facility. Individuals at the facility in management positions, such as the Reactor Supervisor and the Radiation Safety Officer, reported to the Reactor Director and were responsible for implementing UCD/MNRC policies for operation of the facility, for safeguarding facility personnel and the public from undue radiation exposure, and for adhering to the operating license and TSs.
The organization and staffing at the facility required for reactor operation were as specified in the TSs. The inspectors noted that the staff was composed of four full-time personnel and one part-time staff member. Also, it was noted that all staff members were qualified Senior Reactor Operators.
Review of records demonstrated that management responsibilities were discharged as required by the TSs and applicable procedures.
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c.
Conclusion
The organizational structure and staffing were consistent with the requirements specified in TSs Section 6.
2.
Review and Audit and Design Control Functions
a.
Inspection Scope (IP 69007)
To verify that the required reviews and audits were being completed and that facility changes were controlled and evaluated as required in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests, and experiments, and reviewed and approved as required by TSs Section 6.2, the inspectors reviewed selected aspects of:
- Nuclear Safety Committee (NSC) meeting minutes for 2016 through the present
MNRC UC Davis Audit, - the 2015 annual audit conducted by the Chair of the NSC on February 27, 2015, and a partial audit conducted on October 28, 2015
MNRC UC Davis Audit, - the 2016 annual audit conducted by the Chair of the NSC on January 11, 2017
2015 MNRC Radiation Safety Program Review Report, - the annual radiation protection program review conducted on December 3, 2015, by the UC Davis Campus Associate Radiation Safety Officer
2016 MNRC Radiation Safety Program Review Report, - the annual radiation protection program review conducted on October 28, 2016, by the UC Davis Environmental Health and Safety Research Safety Manager and Campus Radiation Safety Officer
UCD/MNRC Facility Modification Notebook containing the Facility Modification Log forms
Selected Facility Modification Installation Authorization Forms and associated Facility Modification Checklist forms processed during 2015 and 2016
Selected facility procedures including:
-
UCD/MNRC-0043-DOC-04, Facility Modification Procedure, and,
-
UCD/MNRC-0045-DOC-01, Quality Assurance Program for McClellan Nuclear Research Center (MNRC)
UCD/MNRC Annual Reports for the last two reporting periods
b.
Observations and Findings
(1)
Review and Audit Functions
Composition of the NSC and qualifications of NSC members were as specified in TSs 6.2.1. Minutes of the NSC meetings indicated that the committee continued to meet semiannually as required by TSs 6.2.2 and provided review and oversight of the UCD/MNRC as specified in TSs 6.2.3. Through records review the inspectors determined that reviews were conducted by the NSC or designated representatives.
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Topics of those reviews were as required by the TSs and the reviews provided sufficient guidance, direction, and oversight to ensure safe and acceptable use of the reactor.
The inspectors reviewed the results of the two most recent annual audits conducted at the facility. The inspectors noted that these audits were adequate and covered the activities specified in TSs 6.2.4, including various aspects of the reactor facility operations and programs. To better ensure timely completion of these audits, they were added to the list of items in the licensees system used to track TSs required surveillances and other periodic items.
(2)
Design Control Functions
The regulatory requirements stipulated in 10 CFR 50.59, were implemented at the facility through Facility Procedure UCD/MNRC-0043-DOC-04, Facility Modification Procedure. The procedure was developed to address activities that affected changes to the facility as described in the safety analysis report (SAR), changes to MNRC procedures, and changes to or development of new tests or experiments not described in the SAR. The procedure adequately incorporated criteria provided by the regulations with additional requirements mandated by site-specific conditions.
The inspectors reviewed entries in the Facility Modification Log, notebook for 2016. The notebook entries showed that no changes or modifications had been proposed since the last inspection.
c.
Conclusion
The NSC was meeting as required and reviewing the topics outlined in the TSs.
Audits of various reactor operations and programs were being conducted as required. The design change control program satisfied NRC requirements.
3.
Radiation Protection Program
a.
Inspection Scope (IP 69012)
The inspectors reviewed selected portions of the following regarding the licensees radiation protection program to ensure that the requirements of 10 CFR Part 20, Standards for Protection against Radiation, and TSs Sections 4.7 and 6.4.2 were being met:
- Calibration records of selected radiation detection and monitoring instruments
List documenting all MNRC personnel who were authorized to handle radioactive material, dated January 12, 2017
Monthly Occupational Radiation Exposure Reports for UCD/MNRC personnel for 2015 and 2016
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Individual NRC Form 5s, Occupational Exposure Record For A Monitoring Period, for UCD/MNRC personnel for 2014 and 2015 (2016 records not yet available)
2015 MNRC Radiation Safety Program Review Report, completed by members of the NSC and dated December 3, 2015
2016 MNRC Radiation Safety Program Review Report, completed by members of the NSC and dated October 28, 2016
Lesson plans, training objectives, and qualification cards for training of personnel by the Radiation Safety Officer (RSO)
Selected daily, weekly, and quarterly contamination and radiation survey results for the past 2 years
Selected facility procedures including:
-
UCD/MNRC-0029-DOC-19, UCD/MNRC Radiation Protection Procedures, containing various Sections and Appendices which outlined the MNRC Radiation Protection Program, and
-
UCD/MNRC-0042-DOC-16, MNRC Health Physics Instrumentation and Test Procedures, containing various Addenda which specified equipment calibrations and tests
SAR, Revision 4, dated December 1999, Chapter 11, Radiation Protection and Waste Management Program, Revision 2, dated April 3, 1998
UCD/MNRC Annual Reports for the last two reporting periods
American National Standard Institute/American Nuclear Society-15.11-1993, Radiation Protection at Research Reactor Facilities, standard approval dated July 23, 1993
The inspectors also toured the facility and observed the use of dosimetry and radiation monitoring equipment. One inspector conducted a radiation survey while accompanying the RSO as he completed a routine weekly survey. In addition, licensee personnel were interviewed and radiological signs and postings were observed.
b.
Observations and Findings
(1)
Surveys
The RSO daily log sheets and weekly, quarterly, and special contamination and radiation surveys were being completed by the RSO or other qualified staff members as required. A review of these records indicated that any contamination detected in concentrations above established action levels was noted on the appropriate form and the affected 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 could check and be knowledgeable of the radiological conditions that existed in those areas.
It was noted that all facility personnel had been trained to use radiation detection instruments. The inspectors verified that these individuals were performing limited radiation surveys using the appropriate meters while the shield doors to the radiography bays were opened. The use of survey meters appeared to be adequate.
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During the inspection, one inspector accompanied the facility RSO and observed the completion of a weekly radiation and contamination survey.
The inspector conducted a radiation survey alongside the RSO. Areas surveyed at the facility included the equipment room, the reactor room, and associated support areas. The RSO completed the survey using appropriate survey techniques. No anomalies were noted.
(2)
Postings and Notices
Copies of current notices to workers were posted in appropriate areas of the facility. The required radiological signs were posted at the entrances to controlled areas. Other postings also showed the industrial hygiene hazards that were present in the areas as well. The copy of NRC Form 3 noted at the facility was the latest issue, as required by 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and was posted on a bulletin board near the main entrance to the facility where visitors are required to sign the visitors log.
(3)
Dosimetry
Personnel were observed to be wearing extremity and whole body dosimetry in the controlled areas in the appropriate manner and location.
The dosimetry being used consisted of Optically-Stimulated Luminescent (OSL) dosimeters and thermoluminescent dosimeters (TLDs) processed monthly by a National Voluntary Laboratory Accreditation Program certified vendor. The OSL dosimeters were used for whole body monitoring and the TLDs were in finger rings which were used for extremity monitoring.
An examination of the OSL and TLD results which documented the radiological exposures at the facility for the past 2 years showed that the highest occupational doses, as well as doses to the public, were well within 10 CFR Part 20 limits. Individual copies of NRC Form 5 that had been issued to the various staff members in 2014 and 2015 were reviewed. (Forms for 2016 were not yet available.) No problems were noted.
(4)
Calibration of Radiation Monitoring Equipment
Selected calibration records of portable survey meters, friskers, fixed radiation detectors, and air monitoring instruments in use at the facility were reviewed. The records showed that the meters and detectors were either calibrated by reactor staff or the instruments were sent off site to be calibrated by a contractor. The calibrations were tracked and documented as required. The inspectors confirmed that the frequency of these calibrations satisfied the requirements established in TSs Section 4.7 and 10 CFR 20.1501, General, paragraph (b). All instruments checked by the inspectors that were currently in use at the facility had a current calibration sticker attached.
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(5)
Radiation Protection Program
The radiation protection program was described and controlled by procedures and policies that were well documented as required by TSs 6.4.2 and 10 CFR 20.1101, Radiation protection programs, paragraph (a). Annual audits of the radiation protection program had been completed by members of the NSC and documented in reports dated December 3, 2015, and October 28, 2016. These audits satisfied the periodic program review required by 10 CFR 20.1101(c). No significant issues were identified by the NSC audit team but various recommendations for improvements were made.
(6)
Personnel Training
Personnel training required by 10 CFR 19.12, Instruction to workers, was provided by the RSO. In a graded approach, there were five levels or plans for training designated as A through E. The type of training provided to an individual was dictated by the type of work to be performed and whether or not the person would be required to enter any controlled area and/or handle radioactive material.
The inspectors reviewed the training given to various personnel and noted that training was being completed as required. Specific supplemental training was also provided as needed to ensure that personnel understood the subjects. An annual radiation safety review emphasizing the As Low As Reasonably Achievable (ALARA) principle was provided to all facility staff members as well. The training appeared to be adequate.
(7)
Radiation Work Permit Program
The inspectors reviewed the radiation work permits (RWPs) that had been written and used during 2016. It was noted that no special RWPs had been issued during that period. The inspectors determined that the controls, precautions, and instructions specified in the RWPs appeared to be appropriate. It was also noted that the RWPs had been reviewed by the RSO as required. The 2016 RWPs had been closed out at the end of the year as required and new RWPs had been issued for 2017. The 2017 RWPs were similar to the ones issued for 2016 and typically covered routine maintenance work as well as experiment disassembly.
(8)
Facility Tours
The inspectors toured the main staging or set-up area, the equipment room, the reactor room, and various support areas with licensee representatives on various occasions and observed on-going activities. It was 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 and properly controlled.
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c.
Conclusion
The inspectors 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.
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 TSs Section 6.4.2(d):
- Facility Procedure UCD/MNRC-0029-DOC-19, UCD/MNRC Radiation Protection Procedures, including:
-
Section 3, Environmental Radiation Monitoring Procedures,
-
Section 4, Radioactive Effluent Monitoring Procedures, and
-
Section 17, Radioactive Waste Procedure
Quarterly Environmental TLD Reports for the last 2 years
Radiochemical analysis data/results for the last year to check samples from the Radiography Bay 1 and the primary system water for tritium
UCD/MNRC Annual Reports for the last two reporting periods
b.
Observations and Findings
The inspectors determined that gaseous releases continued to be monitored as required, were acceptably analyzed, and were documented in the annual operating reports. To ensure that airborne concentrations of gaseous releases were: (1) within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2; (2) below the dose constraint specified in 10 CFR 20.1101(d) of 10 millirem per year; and (3) within TSs levels, the licensee completed a calculation of the dose to members of the public as the result of reactor operations. This calculation, which was based on the concentration of effluent released from the stack, was performed using the Environmental Protection Agencys computer code, CAP88-PC, Version 3.0. The results indicated an annual dose to the public within the regulatory limits.
The inspectors verified that there were no liquid effluent releases from the facility during 2015 and 2016. It was also noted that, although radioactive waste was being stored in various locations at the facility, no solid radioactive waste shipments had been made from the facility in 2016.
Environmental water samples were collected, prepared, and sent to a vendor for analysis consistent with procedural requirements. The results of these analyses
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were all within regulatory limits. On-site and off-site gamma radiation monitoring was completed using various environmental TLDs in accordance with the licensees procedures as well. A review of these data indicated that measurable doses were all below regulatory limits.
c.
Conclusion
Effluent monitoring satisfied license and regulatory requirements and releases were within the specified TSs levels and regulatory limits.
5.
Procedures
a.
Inspection Scope (IP 69008)
To verify compliance with TSs Section 6.4, the inspectors reviewed selected portions of the following:
- Selected Document Review, forms completed by staff members
UCD/MNRC Controlled Document Review and Approval Reference List
MNRC Document List, listing all the licensees current procedures and the date each was last reviewed
Various memoranda from the Reactor Supervisor to the staff indicating document review assignments and responsibilities
Selected facility procedures including:
-
UCD/MNRC-0029-DOC-19, UCD/MNRC Radiation Safety Procedures, and,
-
UCD/MNRC-0082-DOC-01, Environmental Compliance and Health and Safety Plan
b.
Observations and Findings
According to TSs Section 6.4, it was required that procedures be prepared and approved for the activities listed in that section. The procedures were required to be approved by the UCD/MNRC Director. Facility Procedure UCD/MNRC-0005-DOC stipulated that the UCD/MNRC staff perform a biennial review of each active document to assure that it was current. The inspectors noted that Operations and Health Physics procedures were typically being reviewed annually by the licensee, while maintenance and other procedures were reviewed biennially. Changes to the procedures also required the approval of the UCD/MNRC Director and all changes were required to be documented.
The inspectors determined that the UCD/MNRC procedures were being reviewed as required, that procedures were approved by the Director, and that changes were approved and documented as required as well. No procedure reviews concerning radiation protection were overdue at the time of the inspection.
The activities and operations observed by the inspectors during this inspection were completed in accordance with the applicable procedures. These activities and operations included reactor operation checkouts, handling radioactive material, and, conducting surveys.
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c.
Conclusion
The current procedure review, revision, control, and implementation program satisfied TSs requirements. Procedural compliance was acceptable.
6.
Transportation of Radioactive Materials
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 licenses of various UCD/MNRC consignees
Records of the radioactive material shipments made during 2016 including completed radiological survey forms
Training records for staff personnel authorized to ship hazardous material in accordance with the regulations specified by the Department of Transportation (DOT)
Facility Procedure UCD/MNRC-0029-DOC-19, UCD/MNRC Radiation Protection Procedures, including:
-
Section 21, Procedures for Shipping Radioactive Material, and,
-
Section 21 Appendix A, Limited Quantity of Class 7 (Radioactive)
Materials Checklist
b.
Observations and Findings
Through records review and discussions with licensee personnel, the inspectors determined that the licensee made 8 shipments of radioactive material during 2016. All the shipments had been designated as Limited Quantity shipments.
The records indicated that the radioisotope types and quantities were calculated and dose rates were measured as required. The radioactive material shipment records reviewed by the inspectors had been completed in accordance with DOT and NRC regulations.
The inspectors verified that the licensee maintained copies of shipment recipients licenses, or possession authorization letters for Department of Energy customers, as required. The licenses were determined to be current or in timely renewal prior to initiating a shipment. The inspectors also verified that the recipients were authorized to receive and possess the type and quantity of radioactive material shipped to them.
The inspectors also reviewed the training of MNRC staff members responsible for shipping radioactive material. The inspectors verified that licensee personnel designated as shippers had received the appropriate training covering the specified requirements within the past three years as required by the regulations.
c.
Conclusion
Radioactive material was being shipped in accordance with the applicable NRC and DOT regulations.
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7.
Exit Interview
The inspection scope and results were summarized on February 1 and 2, 2017, with members of licensee management. The inspectors described the areas inspected and discussed the inspection findings. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed during the inspection.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
H. Bollman Radiography Supervisor and SRO Facility Director and SRO T. Essert Electrical Engineer and SRO D. Reap Radiation Safety Officer, Security Officer, and SRO W. Steingass Associate Director for Reactor Operations, Operations Manager, and SRO
INSPECTION PROCEDURES USED
IP 69004 Class I Research and Test Reactor Effluent and Environmental Monitoring IP 69006 Class I Research and Test Reactor Organization, Operations, and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class I Research and Test Reactor Procedures IP 69012 Class I Research and Test Reactor Radiation Protection IP 86740 Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
PARTIAL LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable DOT Department of Transportation IP Inspection Procedure MNRC McClellan Nuclear Research Center NRC U.S. Nuclear Regulatory Commission NSC Nuclear Safety Committee RSO Radiation Safety Officer RWP Radiation Work Permit SAR Safety Analysis Report TLD Thermoluminescent dosimeter TSs Technical Specifications UCD/MNRC University of California-Davis/McClellan Nuclear Research Center