ML20304A216

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University of Utah - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000407/2020201 and Notice of Violation - Cover Letter and Enclosure
ML20304A216
Person / Time
Site: University of Utah
Issue date: 05/07/2021
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Sjoden G
Univ of Utah, Salt Lake City
Bassett C, NRR/DANU/UNPO, 240-535-1842
References
Download: ML20304A216 (19)


See also: IR 05000407/2020201

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

May 7, 2021

Dr. Glenn E. Sjoden, Interim Director

Utah Nuclear Engineering

Program Professor

Energy Solutions Presidential Endowed

Chair Department of Civil

and Environmental Engineering

University of Utah

110 Central Campus Drive, Room 2000

Salt Lake City, UT 84112

SUBJECT: UNIVERSITY OF UTAH - U.S. NUCLEAR REGULATORY COMMISSION

ROUTINE INSPECTION REPORT NO. 05000407/2020201 AND NOTICE OF

VIOLATION

Dear Dr. Sjoden:

From October 13-23, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an

inspection at your University of Utah TRIGA Nuclear Reactor Facility. The enclosed report

documents the inspection results which were discussed on October 16 and 23, 2020, with you,

Dr. Michael Barber, Department Chair of Civil and Environmental Engineering, 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 inspector reviewed selected procedures and records, observed various activities, and

interviewed personnel.

Based on the results of this inspection, the NRC has determined that a Severity Level IV

violation of NRC requirements occurred. The violation was evaluated in accordance with the

NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at

https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in

the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in

detail in the subject inspection report. The violation is being cited in the Notice because it

constitutes a failure to meet regulatory requirements that has more than minor safety

significance and the licensee failed to identify the violation.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRC

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

G. Sjoden

2

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public

inspections, exemptions, and requests for withholding, a copy of this letter, its enclosures, and

your response will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records component of 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). To the extent possible, your response should not include any personal privacy

or proprietary information, so that it can be made available to the Public without redaction.

Should you have any questions concerning this inspection, please contact Craig Bassett at

(240) 535-1842, or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

for

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. 50-407

License No. R-126

Enclosures:

As stated

cc: w/enclosure: See next page

Philip B.

O'Bryan

Digitally signed by

Philip B. O'Bryan

University of Utah

Docket No. 50-407

cc:

Mayor of Salt Lake City

451 South State

Room 306

Salt Lake City, UT 84111

Dr. Andrew S. Weyrich

Vice President for Research

University of Utah

201 South Presidents Circle, Room 210

Salt Lake City, UT 84112-9011

Frederick A. Monette

Director and RSO

Environmental Health and Safety

75 S 2000 E, Room 322

University of Utah

Salt Lake City, UT 84112

Test, Research and Training

Reactor Newsletter

Attention: Ms. Amber Johnson

Dept. of Materials Science and Engineering

University of Maryland

4418 Stadium Drive

College Park, MD 20742-2115

Director, Division of Radiation Control

Dept. of Environmental Quality

195 North 1950 West

P.O. Box 14485

Salt Lake City, UT 84114-4850

Mr. Matthew Lund, Reactor Supervisor

Utah Nuclear Engineering Program

Joseph Merrill Engineering Building

50 S. Central Campus Drive, Room 1206

Salt Lake City, UT 84112

ML20304A216

NRC-002

OFFICE

NRR/DANU/UNPO/RI

NRR/DANU/UNPO/LA

NRR/DANU/UNPO/BC*

NAME

CBassett

NParker

TTate (POBryan for)

DATE

11/12/2020

11/12/2020

5/7/2021

Enclosure 1

NOTICE OF VIOLATION

University of Utah

Docket No. 50-407

University of Utah TRIGA Nuclear Reactor

License No. R-126

During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted October 13-23,

2020, a violation of NRC requirements was identified. In accordance with the NRC Enforcement

Policy, the violation is listed below:

University of Utah TRIGA Nuclear Reactor technical specifications (TSs) Section 6.1.3.3,

Specification 3.1, states, Events requiring the direction of the [Reactor Supervisor include]

Initial startup and approach to power of the day.

Contrary to the above, on September 2, 4, 14, 18, 21, 22, 23, and 24, 2020, and October 9,

2020, the reactor was started up without the Reactor Supervisor being present.

This is a Severity Level IV violation (Section 6.1).

Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.201,

Notice of violation, the University of Utah is hereby required to submit a written statement or

explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001, within 30 days of the date of the letter transmitting this Notice of

Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation, and

should include: (1) the reason for the violation, or, if contested, the basis for disputing the

violation or severity level, (2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will

be achieved. Your response may reference or include previous docketed correspondence, if

the correspondence adequately addresses the required response. If an adequate reply is not

received within the time specified in this Notice, an Order or a Demand for Information may be

issued as to why the license should not be modified, suspended, or revoked, or why such other

action as may be proper should not be taken. Where good cause is shown, consideration will

be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (Agencywide Documents Access

and Management System), accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or

safeguards information so that it can be made available to the public without redaction. If

personal privacy or proprietary information is necessary to provide an acceptable response,

then please provide a bracketed copy of your response that identifies the information that

should be protected and a redacted copy of your response that deletes such information.

2

If you request withholding of such material, you must specifically identify the portions of your

response that you seek to have withheld and provide in detail the bases for your claim of

withholding (e.g., explain why the disclosure of information will create an unwarranted invasion

of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request

for withholding confidential commercial or financial information). If safeguards information is

necessary to provide an acceptable response, please provide the level of protection described

in 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.

In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post

this Notice within two working days of receipt.

Dated this 7th day of May 2021

Enclosure 2

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

Docket No.:

50-407

License No.:

R-126

Report No.:

05000407/2020201

Licensee:

University of Utah

Facility:

University of Utah TRIGA Nuclear Reactor

Location:

Salt Lake City, Utah

Dates:

October 13 - 23, 2020

Inspector:

Craig Bassett

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

- 2 -

EXECUTIVE SUMMARY

University of Utah

University of Utah TRIGA Nuclear Reactor Facility

Inspection Report No. 05000407/2020201

The primary focus of this routine, announced inspection was the onsite review of selected

aspects of the University of Utah (the licensees) 100 kilowatts Class II research reactor safety

program, including: (1) organization and staffing; (2) procedures; (3) health physics; (4) design

changes; (5) committees, audits and reviews; and, (6) transportation of radioactive material.

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 the NRC requirements. However, one violation (VIO) and one unresolved item (URI) were

identified.

Organization and Staffing

The licensees organizational structure was in compliance with requirements outlined in the

technical specifications (TSs).

One VIO was noted for failure to have the Reactor Supervisor (RS) present during initial

startup and approach to power during various days in September and October 2020 as

required by TS Section 6.1.3.3.

Procedures

Facility procedural review, revision, control, and implementation satisfied TS requirements.

Health Physics

Surveys were completed and documented appropriately to permit evaluation of the radiation

hazards present.

Postings met regulatory requirements.

Personnel dosimetry was worn as required, and doses were well within the licensees

procedural action levels and NRC regulatory limits.

Radiation monitoring equipment was maintained and calibrated, as required.

The Radiation Protection and as low as reasonably achievable (ALARA) programs satisfied

regulatory requirements.

Training was provided to staff members in the area of radiation protection in accordance

with regulatory requirements.

Effluent monitoring satisfied license and regulatory requirements and releases were within

the specified regulatory and TS limits.

- 3 -

Design Changes

Change reviews were conducted in accordance with the requirements in Title 10 of the

Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments.

One 10 CFR 50.59 change review involving installation of a new reactor console was not

completed and would be submitted to the NRC for review prior to resumption of reactor

operations.

Committees, Audits and Reviews

The Reactor Safety Committee (RSC) met as required.

Audits and reviews were conducted by designated individuals and reviewed by the RSC in

accordance with the requirements specified in TS Section 6.2.

Transportation of Radioactive Material

The licensee transferred radioactive waste material to the campus Radiation Safety Office

(RSO) for disposal as needed.

The RSO would handle any shipments of radioactive material from the facility.

- 4 -

REPORT DETAILS

Summary of Facility Status

The University of Utah continued to operate the 100-kilowatts TRIGA Mark I research reactor as

needed in support of sample irradiation, reactor operator training, educational demonstrations,

preventive maintenance, and operational surveillance testing required by the TSs. While the

reactor was not operated during this inspection in preparation for the installation of a new

reactor console, it was typically operated one or two days a week at various power levels up to

90 kilowatts.

1.

Organization and Staffing

a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.01)

The inspector reviewed the following regarding the licensees organization and

staffing to ensure that the requirements of Section 6.1 of the TSs were met:

management responsibilities

qualifications of facility personnel

Utah Nuclear Engineering Program (UNEP) Procedure, P-001, Description

of Operations, Revision 1, (UNEP P-001R1), Section 1, Organization and

Responsibilities

amendment number (No.) 9 to Facility Operating License No. R-126, dated

December 12, 2011, which amended the TSs

University of Utah TRIGA Reactor (UUTR) annual operating report for the

period of July 1, 2018, through June 30, 2019

UUTR annual operating report for the period July 1, 2019, through

June 30, 2020

b.

Observations and Findings

(1)

Organization and Qualification

Through discussions with licensee representatives, the inspector

determined that there were no changes to management responsibilities and

the organizational structure at the UUTR facility since the last NRC

inspection in the area of radiation protection conducted in May 2018 (NRC

Inspection Report No. 50-407/2018-201).

The inspector found that the person who formerly was designated as the

Interim Facility Director took a position with a company in another state. A

new Facility Director was appointed. Because the former Interim Facility

Director was also the RS, an Assistant RS was appointed as well. The

inspector reviewed the qualifications of these individuals and determined

that the Facility Director met the requirements outlined in American National

Standards Institute/American Nuclear Society (ANS/ANSI)-15.4-1988;

R1999, Selection and Training of Personnel for Research Reactors as

required by TS Section 6.1.4. ANSI/ANS-15.4-1988 did not establish

requirements for the position of Assistant RS. It was noted that the

- 5 -

Assistant RS did not meet the qualifications outlined in ANS/ANSI-15.4 -

1988; R1999 for the position of Level 3, RS.

(2)

Staffing

TS 6.1.3.3, Specification 3.1, states, Events requiring the direction of the

RS [include] initial startup and approach to power of the day. Through

review of records and logs, and through discussions with licensee

personnel, the inspector determined that shift staffing at the UNEP TRIGA

Reactor Facility did not meet the requirements stated in Section 6.1.3.3,

Specification 3.1 of the TSs. The console operations log indicated that, on

September 2, 4, 14, 18, 21, 22, 23, and 24, and October 9, 2020, the

Assistant RS was present during reactor startup, not the RS as required.

As noted above, the Assistant RS did not meet the qualifications outlined in

ANS/ANSI 15.4 - 1988; R1999 for the position of Level 3, RS. The

licensee was informed that failure to have a qualified RS present during

initial startup of the reactor on various days in September and October was

an VIO of TS 6.1.3.3 (VIO 05000407/2020201-01).

c.

Conclusion

The inspector determined that the organizational structure was consistent with

TS requirements. The inspector noted one VIO for failure to have the RS present

during initial startup and approach to power of the day during various days in

September and October 2020.

2.

Procedures

a.

Inspection Scope (IP 69001, Section 02.03)

The inspector reviewed selected aspects of the following to verify that the

licensee complied with the requirements of TS Section 6.4:

records of procedure changes

various administrative and radiation protection procedures

related logs and records documenting procedure implementation

UNEP-035 R4, Audit and Review Program Checklist

RSC meeting minutes from December 2018 to the present

b.

Observations and Findings

The inspector noted that the licensee used procedures to conduct operations at

the facility as required and the procedures were available for those tasks and

items required by the TSs. The inspector determined that substantive changes

to the procedures were reviewed and approved by the RSC as required.

Training of personnel on procedures and the applicable changes was acceptable.

In the area of radiation protection, the licensee did not have facility-specific

procedures but was developing some for use at the reactor facility. In the

interim, reactor personnel made use of the procedures maintained by the

university RSO which were contained in the Radiological Procedures and

Records [RPR], and were available on-line at the RSO website. Those

- 6 -

procedures were reviewed and approved by the universitys Radiation Safety

Committee.

c.

Conclusion

The inspector determined that the procedural review, revision, control, and

implementation satisfied TS requirements.

3.

Health Physics

a.

Inspection Scope (IP 69001, Section 02.07)

To verify compliance with TS Sections 3.4, 3.7, 4.3, 4.7, 5.4, 6.3, and 6.7, as well

as 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection

and Investigations, and 10 CFR Part 20, Standards for Protection against

Radiation, requirements, the inspector reviewed selected aspects of:

radiological signs and postings at the facility

personnel dosimetry records for 2018, 2019, and to date in 2020

environmental dosimetry records for 2018, 2019, and to date in 2020

various procedures including: UNEP-020 R13, Monthly Inspection/

Surveillance Checklist; UNEP-023 R5, Annual Maintenance and Calibration

of the Area Radiation Monitors (ARMs) and Continuous Air Monitor (CAM);

and, UNEP-032, Liquid Effluent Discharge Authorization

various RSO RPR procedures and forms including: RPR No. 50A,

Laboratory Evaluation Checklist and Laboratory Evaluation Checklist

(cont); RPR No. 50B, Total Contamination Survey; RPR No. 50C,

Removable Contamination Survey; RPR No. 50D, Exposure Rate Survey;

and, No. 50E, Radionuclide Laboratory Evaluation Report;

RSC meeting minutes for the past 2 years which included a quarterly report

from the university Radiation Safety Officer

Assessment of Radiation Dose from Air Emissions of Radioactive Material,

Calendar Year 2019, which was completed by RSO personnel

UUTR annual operating reports for the last two reporting periods

b.

Observations and Findings

(1)

Surveys

The inspector reviewed monthly radiation and contamination surveys of

licensee-controlled areas within the UUTR for the past 2 years, which

were conducted by campus RSO personnel. The inspector also reviewed

the records documenting the monthly general area radiation and

contamination surveys of the reactor room and support areas which were

completed by licensee personnel from 2019 to present. The inspector

determined that the results of all these surveys were documented,

reviewed, and evaluated, as required, and corrective actions were taken

when readings or contamination results exceeded set action levels.

- 7 -

(2)

Postings and Notices

During tours of the facility, the inspector observed that caution signs and

postings in place and controls established for the controlled areas were

acceptable for the hazards involving radiation, high radiation, and

contamination, and were posted as required by 10 CFR Part 20,

Subpart J, Precautionary Procedures. The inspector confirmed that

personnel complied with the signs, postings, and controls.

Copies of notices to workers were posted in various areas in the facility.

Radiological signs were posted at the entrances to controlled areas. The

inspector verified that the copies of NRC Form 3, Notice to Employees,

were posted at the facility as required by 10 CFR 19.11, Posting of

notices to workers, were the current version. During the inspection the

licensee also posted signs to remind everyone of the Safety Conscious

Work Environment at the facility. All UUTR staff were aware that they

could raise safety concerns without fear of retaliation.

(3)

Dosimetry

The inspector determined that the licensee used ion chamber dosimeters

for whole body monitoring of radiation exposure. The licensee also used

thermoluminescent (TLD) finger rings for monitoring radiation exposure of

the extremities. The dosimetry was supplied and processed by a National

Voluntary Laboratory Accreditation Program accredited vendor. Through

direct observation the inspector determined that dosimetry use by facility

personnel was in accordance with the university radiation protection

requirements. Examination of the dosimetry results, indicating

radiological exposures at the facility for the past 2 years, showed that all

occupational doses were within 10 CFR Part 20 limits.

(4)

Radiation Monitoring Equipment Use and Calibration

The use and calibration of radiation monitoring equipment was reviewed

by the inspector. Portable survey meters and friskers were calibrated by

campus RSO personnel. Fixed radiation detectors and the CAM were

calibrated by licensee staff personnel. The inspector reviewed calibration

records maintained by the RSO and licensee personnel. Through this

review the inspector determined that records were maintained as required

and that calibration frequencies met the requirements established in the

applicable surveillance procedures. Through observations of activities at

the UUTR facility, the inspector determined that the monitoring equipment

was used in accordance with procedure.

- 8 -

(5)

Radiation Protection Program and ALARA Policy

The licensees Radiation Protection Program was established through

various University of Utah campus documents including: (1) the RSO

Radiological Procedures and Records; (2) The University of Utah

Radiation Safety Policy Manual; (3) The University of Utah Radiation

Protection Program; and (4) RPR No. 80, Utah Nuclear Engineering

Program (UNEP) Research (TRIGA) Reactor (UUTR). The program

stated that all personnel who had unescorted access to work in a

radiation area or who worked with radioactive material were required to

receive training in radiation protection policies, principles, procedures,

and requirements prior to starting work. The inspector also confirmed

that the university Radiation Protection Program was reviewed annually,

as required. The ALARA Policy was also outlined and established in the

manuals and RPR mentioned above. The ALARA program provided

appropriate guidance for keeping doses ALARA and was consistent with

the requirements in 10 CFR Part 20.

(6)

Radiation Worker Training

As noted above, the inspector determined that all university personnel

who worked in radiation areas or handled radioactive material, including

licensee staff, were required to receive training in radiation protection.

Completion of the required training by facility personnel was verified by

RSO personnel, as well as by the Reactor Administrator and/or the RS.

Upon completion of the course, reactor staff members were issued a

dosimeter and allowed to work under the direction of a Responsible User.

The inspector reviewed documentation of the training provided to

selected licensee staff members, including the certificates of completion.

The documents indicated that all current staff members received the

required training. The inspector determined that the personnel training

program satisfied requirements in 10 CFR 19.12, Instruction to workers.

The content and periodicity of training were also acceptable and in

accordance with the regulations.

(7)

Environmental and Effluent Monitoring

The inspector reviewed the ARMs and CAM calibration records. The

ARMs and CAM were calibrated annually by licensee staff in accordance

with procedures. The monthly setpoint and high radiation warning

verification records for the monitoring equipment were also reviewed.

Corrective actions, including recalibration, were completed if the setpoint

values were exceeded.

The inspector determined that gaseous releases continued to be

monitored as required. The releases were calculated by the RSO

according to established procedure, using the Environmental Protection

Agency COMPLY code. The dose rate to the public, as a result of the

gaseous releases, was well below the dose constraint of 10 millirem per

year specified in 10 CFR 20.1101, Radiation protection programs,

- 9 -

paragraph (d). The inspector noted that airborne concentrations of

gaseous releases were also calculated by the licensee. These

calculations showed that gaseous releases were well within the

concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2, and

TS limits. The results were appropriately documented in the facility

annual reports, as required.

The inspector verified that there were no liquid releases from the facility to

the sanitary sewer within the past 2 years. It was noted that no solid

waste was transferred from the facility to the campus RSO during the past

2 years.

Onsite and off-site gamma radiation monitoring was completed using

environmental TLDs in accordance with the applicable university

procedures. The data indicated that there were no unusual dose rates in

the areas surrounding the UUTR facility and that there were no

measurable doses above any regulatory limits. These results were also

appropriately reported in the facility annual reports.

(8)

Facility Tours

The inspector toured the control room, reactor room, and selected

support laboratories and offices. Control of radioactive material and

control of access to radiation and high radiation areas were acceptable

and in accordance with the regulations. As noted earlier, the postings

and signs for these areas were appropriate. No problems were noted.

c.

Conclusion

Based on the observations made and the records reviewed, the inspector

determined that the Radiation Protection Program that was implemented by the

licensee satisfied regulatory requirements.

4.

Design Changes

a.

Inspection Scope (IP 69001, Section 02.08)

The inspector reviewed the following to verify compliance with 10 CFR 50.59 and

TS Section 6.2:

RSC meeting minutes from December 2018 to the present

UNEP Job-Aid 002 R1, 10 CFR 50.59 Screening

Form UNEP-022 R4, Maintenance Log

UUTR Annual Operating Reports for the last two reporting periods

b.

Observations and Findings

The inspector noted that one review related to control rod drives and two reviews

related to nuclear instrumentation were conducted since the last inspection. The

screening reviews for these projects were completed by the licensee to verify that

- 10 -

10 CFR 50.59 evaluations were not needed. The inspector reviewed the

screening reviews and noted that they appeared to be adequate.

The inspector determined that the licensee was in the process of conducting a

10 CFR 50.59 review related to the installation of a new reactor console. The

review was not finalized at the time of the inspection. The inspector informed the

licensee that the review needed to be complete to determine if a full evaluation

was required. The inspector requested a copy of the 10 CFR 50.59 review,

along with all the associated documentation, prior to the resumption of operations

following the installation of the new reactor console. The licensee committed to

maintaining the UUTR shutdown until all 10 CFR 50.59 and related operations

procedures are updated and agreed to submit the material to the NRC for review.

This issue is an URI and will be reviewed further (URI 05000407/2020201-02).

c.

Conclusion

The inspector determined that the licensees design change control program was

implemented as required. One 10 CFR 50.59 change review involving

installation of a new reactor console was not complete and would be submitted to

the NRC for review prior to resumption of reactor operations.

5.

Committees, Audits and Reviews

a.

Inspection Scope (IP 69001, Section 02.09)

The inspector reviewed the following to ensure that the review and audit

requirements in TS Section 6.2 were met:

RSC meeting minutes from December 2018 to the present

radiation safety and ALARA audits completed during the past year and

licensee responses to the safety reviews and audits

form UNEP-035 R4, Audit and Review Program Checklist

UUTR annual operating reports for the last two reporting periods

b.

Observations and Findings

The inspector verified that the RSC met at least annually as required by the TSs.

It was noted that a subcommittee (or the full committee) held quarterly meetings

in addition to the TS-required annual meetings. The inspector reviewed the RSC

meetings minutes and determined that the minutes contained, among other

documents, quarterly or monthly reports from the Reactor Director, the RS, and

the university Radiation Safety Officer. Review of the committee meeting

minutes indicated that the RSC completed the required reviews as stipulated in

the TSs.

Since the last inspection, all required audits of reactor facility activities and

reviews of programs, procedures, equipment, and proposed tests or experiments

were completed and documented as required. The inspector determined that the

audits and the associated findings were appropriately detailed and that the

licensee responded and took corrective actions as needed. Additionally, the

annual reviews of the Radiation Protection Program and the Emergency Plan, as

- 11 -

well as the biennial review of the Security Plan, were conducted and

appropriately documented.

c.

Conclusion

The inspector determined the RSC was meeting at the required frequency. Audits

and reviews were conducted as required and reviewed by the RSC in accordance

with the requirements specified in TS Section 6.2.

6.

Transportation of Radioactive Material

a.

Inspection Scope (IP 86740)

The inspector reviewed selected aspects of:

UNEP-027 R6, TRIGA Reactor Irradiation Request and Performance

RPR Procedures including: No. 13, Radioisotope Acquisition and

Disposition; No. 14, Shipment of Limited Quantity of Radioisotopes; and

No. 55, Transportation of Radioactive Materials

Various forms including: Form RPR 13A, Radioisotope Package Arrival

Report; Form RPR 13B, Radioisotope Receipt and Verification; and, Form

RPR 13C, Radioisotope Disposition Record

b.

Observations and Findings

The inspector determined that records indicated that UUTR radioactive waste

designated for disposal was transferred from the reactor facility to the University

of Utahs broad scope license, Utah Department of Environmental Quality,

License No. 1800001, in accordance with RSO requirements. The inspector

verified that this process was still followed.

The inspector noted that none of the licensee personnel had the current training

required to ship radioactive material as required by the Department of

Transportation. Therefore, in any instances involving the shipment of radioactive

material, the paperwork and shipments would be completed by qualified RSO

personnel.

c.

Conclusion

The inspector determined that the licensee transferred radioactive waste material

to the campus RSO as needed. The RSO would handle any shipments of

radioactive material from the facility.

7.

Exit Meeting Summary

The inspection scope and results were summarized on October 16 and 23, 2020, with

university management and facility staff. The inspector discussed the findings for each

area reviewed. The licensee did not identify any of the material provided to or reviewed

by the inspector as proprietary.

Attachment

PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel

A. Allison

Student Operator Trainee

D. Feist

Lab Analyst and Student Operator Trainee

A. Foley

Senior Reactor Operator

L. Forster

Student Operator Trainee

E. Goodell

Student Operator Trainee

C. Olson

Student Operator Trainee

S. Pappas

Senior Reactor Operator and Assistant Reactor Supervisor

B. Saenz

Reactor Operator

G. Sjoden

UNEP Director and Reactor Administrator

V. Wang

Research Scientist and Operator Trainee

A. Weyrich

Vice President of Research

Other Personnel

M. Barber

Department Chair of Civil and Environmental Engineering, College of

Engineering, University of Utah

D. Dolan

Health Physicist, Radiation Safety Office, University of Utah

INSPECTION PROCEDURE (IP) USED

IP 69001:

Class II Non-Power Reactors

IP 86740:

Inspection of Transportation Activities

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 05000407/2020201-01

VIO

Failure to have the RS present during initial startup and

approach to power of the day during various days in

September and October of 2020.05000407/2020201-02

URI

Review the licensees completed 10 CFR 50.59 screening

and/or evaluation of the installation of a new reactor console.

Closed

None

PARTIAL LIST OF ACRONYMS USED

10 CFR

Title 10 of the Code of Federal Regulations

ALARA

As Low As Reasonably Achievable

ARMs

Area Radiation Monitors

CAM

Continuous Air Monitor

2

IP

Inspection Procedure

No.

Number

NRC

U.S. Nuclear Regulatory Commission

RPR

Radiological Procedures and Records

RS

Reactor Supervisor

RSC

Reactor Safety Committee

RSO

Radiation Safety Office

TLD

Thermoluminescent dosimeter

TSs

Technical Specifications

UNEP

Utah Nuclear Engineering Program

URI

Unresolved Item

UUTR

University of Utah TRIGA Reactor

VIO

Violation