ML24261B239
| ML24261B239 | |
| Person / Time | |
|---|---|
| Site: | University of Utah |
| Issue date: | 01/21/2025 |
| From: | Tony Brown NRC/NRR/DANU/UNPO |
| To: | Allison A Univ of Utah |
| References | |
| IR 2024201 | |
| Download: ML24261B239 (1) | |
See also: IR 05000407/2024201
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001
Mr. Andrew Allison, Reactor Supervisor
and Interim Facility Director
Utah Nuclear Engineering Program
Joseph Merrill Engineering Building
110 Central Campus Drive, Room 2000
Salt Lake City, UT 84112
SUBJECT:
UNIVERSITY OF UTAH - U.S. NUCLEAR REGULATORY COMMISSION
ROUTINE INSPECTION REPORT NO. 05000407/2024201 AND NOTICE OF
VIOLATION
Dear Mr. Allison:
From July 8-11, 2024, 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 July 11, 2024, with you, Dr. Glenn
Sjoden, Director, Utah Nuclear Engineering Program, Dr. Tong Qiu, Chair, Department of Civil &
Environmental Engineering, and Edward Goodell, Senior Reactor Operator. The results of the
inspection were discussed further with you on September 4, 2024.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed various activities, and
interviewed personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV
violation of NRC requirements has occurred. The violation was evaluated in accordance with the
NRC Enforcement Policy. The current enforcement policy is included on the NRCs website 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.
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 enclosures, 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 website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
January 21, 2025
A. Allison
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Should you have any questions concerning this inspection, please contact Craig Bassett at
(240) 535-1842, or via email at Craig.Bassett@nrc.gov.
Sincerely,
Tony Brown, 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: GovDelivery Subscribers
Signed by Brown, Tony
on 01/21/25
OFFICE
NRR/DANU/UNPO/RI
NRR/DANU/UNPO/RI
NRR/DANU/UNPO/LA
NRR/DANU/UNPO/BC
NAME
CBassett
JBraisted
NParker
TBrown
DATE
09/17/2024
09/17/2024
09/18/2024
01/21/2025
Enclosure 1
University of Utah
Docket No. 50-407
University of Utah TRIGA Reactor
License No. R-126
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from July 8-11,
2024, a violation of NRC requirements was identified. In accordance with the NRC Enforcement
Policy, the violation is listed below:
Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and
experiments, paragraph (c)(1)(i) states, in part, that a licensee may make changes in
the facility as described in the final safety analysis report (as updated) without obtaining
a license amendment pursuant to Sec. 50.90 only if [a]n amendment to the technical
specifications incorporated in the license is not required.
Contrary to the above, on September 21, 2023, the licensee made a change to the
facility as described in the final safety analysis report (as updated) without obtaining a
license amendment when the change in the facility involved a change to a parameter
associated with the function of a system as specified in the technical specifications
incorporated in the license. Specifically, the licensee made a change to the reactor tank
water level monitor by lowering the water level to about ten feet below the top of the
tank.
Technical specification 4.3 (1) which requires a monthly channel check of the reactor
tank water level monitor (float switch alarm). The objective of the channel check is to
assure that the water level monitoring system is operating and to verify appropriate
settings. This system is designed to indicate loss of coolant (water) by alarming (and
automatically notifying the licensee) when water level decreases more than 15.5 inches
from the top of the tank. Because the water level in the tank was lower than the alarm
setpoint, the alarm was always activated (outside of the surveillance) and would mask
any actual loss of coolant. Since the water level monitor cannot perform its design
function at the lowered level, the monitoring system settings were not appropriate.
Consequently, the inspectors determined that the 50.59 evaluation was inadequate and
a change to the technical specifications was required.
This has been determined to be a Severity Level IV violation (section 6.1).
Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section
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
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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 website at https://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. 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 21st day of January 2025.
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.:
50-407
License No.:
R-126
Report No.:
Licensee:
University of Utah
Facility:
University of Utah TRIGA Reactor
Location:
Salt Lake City, Utah
Dates:
July 8-11, 2024
Inspector:
Craig Bassett
Accompanied by:
Jonathan Braisted, RTR Inspector Trainee
Approved by:
Tony Brown, Chief
Non-Power Production and Utilization Facility
Oversight Branch
Division of Advanced Reactors and Non-Power
Production and Utilization Facilities
Office of Nuclear Reactor Regulation
Enclosure 2
EXECUTIVE SUMMARY
University of Utah
University of Utah TRIGA Nuclear Reactor Facility
Inspection Report No. 05000407/2024201
The primary focus of this routine announced inspection was the onsite review of selected
aspects of the University of Utah (the licensees) 100-kilowatt Class II research reactor safety
program, including: (1) organization and staffing; (2) procedures; (3) health physics; (4) design
changes; (5) committees, audits and reviews; (6) emergency planning; and (7) transportation
activities. The U.S. Nuclear Regulatory Commission (NRC) staff determined that the licensees
program was acceptably directed toward the protection of public health and safety and in
compliance with the NRCs requirements.
Organization and Staffing
The licensees organizational structure complied with requirements outlined in the technical
specifications (TSs).
Procedures
The facility procedural review, revision, control, and implementation satisfied the TS
requirements.
Health Physics
The radiation safety program was conducted in compliance with Title 10 of the Code of
Federal Regulations (10 CFR) Part 20, Standards for Protection against Radiation,
requirements, TSs, and licensee procedures.
Design Changes
Changes made at the facility during the past 2 years were completed in accordance
with 10 CFR 50.59, Changes, tests and experiments, and applicable licensee procedures
with one exception that was determined to be a violation of NRC requirements.
Committees, Audits and Reviews
The Reactor Safety Committee (RSC) met and conducted audits and reviews in accordance
with the requirements specified in TS section 6.2.
Emergency Planning
The emergency preparedness program was conducted in accordance with the Emergency
Plan (E-Plan) and implementing procedures.
Transportation Activities
The licensee transferred radioactive waste material to the campus Radiation Safety (Rad
Safety) Office for disposal as needed and the Rad Safety Office handled any shipments of
radioactive material from the facility.
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REPORT DETAILS
Summary of the Facility Status
The University of Utah continued to operate the 100-kilowatt Training, Research, Isotope,
General Atomics (TRIGA) Mark I research reactor (UUTR) as needed for sample irradiation,
reactor operator training, educational demonstrations, preventive maintenance, and operational
surveillance testing required by the TSs. During this inspection, the reactor was not operated
due to planned maintenance to repair a reactor tank leak.
1.
Organization and Staffing
a.
Inspection Scope (Inspection Procedure (IP) 69001, Section 02.01)
The inspectors reviewed the following regarding the licensees organization and
staffing to ensure that the requirements of TS section 6.1, were met:
current facility TSs
qualifications and responsibilities of the facility personnel
UUTR Annual Operating Reports for the periods of July 1, 2021, through
June 30, 2022, and July 1, 2022, through June 30, 2023, submitted to the NRC
on July 29, 2022, and June 30, 2023, respectively
American National Standards Institute/American Nuclear Society
(ANSI/ANS)-15.4-2007, Selection and Training of Personnel for Research
Reactors
b.
Observations and Findings
Through discussions with licensee representatives, the inspectors confirmed that
there were no changes to management responsibilities or the organizational
structure since the last NRC inspection of this area conducted in July 2022 (NRC
Inspection Report No. 50-407/2022-201). The inspectors noted that the previous
Director for the Utah Nuclear Engineering Program (designated by the licensee
as the reactor administration Level 2) took another position at the university since
the last inspection and another individual was assigned as the Facility Director.
The inspectors noted that the licensee notified the NRC staff of this change as
required by the TS via letter dated October 6, 2023 (ML23313A09), and that the
person met the requirements of ANSI/ANS-15.4-2007.
c.
Conclusion
The inspectors determined that the organizational structure was consistent with
the TS requirements.
2.
Procedures
a.
Inspection Scope (IP 69001, Section 02.03)
The inspectors reviewed the selected aspects of the following to verify that the
licensee complied with the requirements of TS section 6.4:
records and logs of procedure changes and implementation
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various administrative and radiation protection procedures
RSC meeting minutes from March 2022 to the present
b.
Observations and Findings
The inspectors noted that the licensee conducted operations in accordance with
approved procedures and the procedures were available for tasks and items
required by the TSs. The inspectors confirmed that substantive changes to the
procedures were reviewed and approved by the RSC. The inspectors found that
reactor personnel also made use of the procedures maintained by the Rad
Safety Office which were contained in the Radiological Procedures and Records
[RPR] manual. Those procedures were reviewed and approved by the Rad
Safety Committee.
c.
Conclusion
The inspectors determined that the procedural review, revision, control, and
implementation has 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 requirements, the inspectors reviewed
the following selected aspects of:
radiological signs and postings in various areas of the facility
RSC meeting minutes from March 2022 to the present
various facility and Rad Safety Office RPR procedures and forms
personnel dosimetry records for 2022, 2023, and to date in 2024
environmental dosimetry records for 2022, 2023, and to date in 2024
selected radiation and contamination surveys conducted by licensee and Rad
Safety Office personnel for the past 2 years
Assessment of Radiation Dose from Air Emissions of Radioactive Material,
Calendar Year 2023, which was completed by Rad Safety Office personnel
UUTR annual operating reports for the last two reporting periods
calibration records
b.
Observations and Findings
(1)
Surveys, Postings and Notices
The inspectors noted that the results of radiation and contamination
surveys were documented, reviewed, and evaluated, as required by
facility procedures, and corrective actions were taken when radiation
readings or contamination results exceeded set action levels.
During tours of the facility, the inspectors confirmed that the caution
signs, postings, and controls established for the controlled areas were in
- 4 -
place as required by 10 CFR Part 20, Subpart J, Precautionary
Procedures. The inspectors also found that copies of NRC Form 3,
Notice to Employees, were posted at the facility as required by
10 CFR 19.11 and were the current version.
(2)
Dosimetry and Radiation Monitoring Equipment Use and Calibration
The inspectors verified that the licensee used thermoluminescent
dosimeters (TLDs) for whole body radiation monitoring and finger ring
TLDs for monitoring radiation exposure of the extremities. The inspectors
confirmed that individual dosimetry results for the past 2 years since the
last inspection of this area showed all occupational doses were within
regulatory limits.
The inspectors confirmed that calibration frequencies met the
requirements established in the TSs. The inspectors noted that the
monitoring equipment was used in accordance with the procedural
guidelines.
(3)
Radiation Protection Program and ALARA Policy
The inspectors confirmed that the licensees Radiation Protection
Program and the as low as is reasonably achievable (ALARA) Policy
were established through various University of Utah campus documents
including: (1) the Rad Safety Office RPRs, (2) The University of Utah
Radiation Safety Policy Manual; and, (3) The University of Utah
Radiation Protection Program. The inspectors also confirmed that the
Radiation Protection Program was reviewed annually. The inspectors
found that the ALARA Policy provided guidance for keeping doses as low
as possible and was consistent with the requirements in 10 CFR Part 20.
(4)
Radiation Worker Training
The inspectors noted that all university personnel who worked in radiation
areas or handled radioactive material, including licensee staff, were
required to receive training in radiation protection. The inspectors
confirmed that the reactor staff members completed the required training
and were then issued a dosimeter. The inspectors noted that the
personnel training program satisfied requirements in 10 CFR 19.12,
Instruction to workers, and that the content and periodicity of the training
were in accordance with the regulations.
(5)
Environmental and Effluent Monitoring
The inspectors confirmed that gaseous releases continued to be
monitored as required. The inspectors noted that the doses resulting from
the releases were calculated by the Rad Safety Office according to
established procedures, using the Environmental Protection Agency
COMPLY code. The dose rate to the public was well below the dose
constraint of 10 millirem per year specified in 10 CFR 20.1101, Radiation
protection programs, paragraph (d). The inspectors found that the
concentrations of airborne gaseous releases were also calculated by the
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Rad Safety Office. The inspectors confirmed that the concentrations of
gaseous releases were well within those stipulated in 10 CFR Part 20,
Appendix B, Table 2, and TS limits. The results were documented in the
facility annual reports, as required by the TSs.
The inspectors found that there were no liquid releases from the facility to
the sanitary sewer within the past 2 years since the last inspection of this
area and no solid waste was transferred from the facility to the campus
Rad Safety Office during that period.
The inspectors confirmed that onsite and off-site gamma radiation
monitoring was completed using environmental TLDs in accordance with
university procedures. The inspectors found that the data indicated no
measurable doses above any regulatory limits in the areas surrounding
the UUTR facility. These results were also reported in the facilitys annual
reports.
c.
Conclusion
The inspectors determined that the Radiation Protection Program, as
implemented by the licensee, satisfied the regulatory requirements.
4.
Design Changes
a.
Inspection Scope (IP 69001, Section 02.08)
The inspectors reviewed the following to verify compliance with 10 CFR 50.59
and TS section 6.2:
RSC meeting minutes from March 2022 to the present
Utah Nuclear Engineering Program (UNEP) Job-Aid 002 R1, 10 CFR 50.59
Screening
UNEP Job-Aid 003 R1, 10 CFR 50.59 Evaluation
UNEP Procedure AP-001 R1, Guidelines for 10 CFR 50.59 Evaluations
various forms designated as form UNEP-022 R4, Maintenance Log which
were used in conjunction with the design change process
UUTR Annual Operating Reports for the last two reporting periods
b.
Observations and Findings
The inspectors noted that various 10 CFR 50.59 reviews were conducted since
the last inspection. The inspectors identified one violation of NRC requirements
as described below.
Section 50.59, Changes, test and experiments, paragraph (c)(1)(i) states, in
part, that a licensee may make changes in the facility as described in the final
safety analysis report (as updated) without obtaining a license amendment
pursuant to Sec. 50.90 only if [a]n amendment to the technical specifications
incorporated in the license is not required.
- 6 -
Contrary to the above, on September 21, 2023, the licensee made a change to
the facility as described in the final safety analysis report (as updated) without
obtaining a license amendment when the change in the facility required an
amendment to the TSs incorporated in the license.
Specifically, on September 18, 2023, the licensee observed that the water level
in its aluminum reactor tank was abnormally low and determined that it had an
active leak in its tank. To facilitate tank repairs, the licensee approved further
lowering the water level in the reactor tank based upon the results of a 10 CFR
50.59 evaluation. This evaluation determined that a license amendment was not
required. Subsequently, the licensee partially defueled the core and lowered the
water level to about ten feet below the top of the tank, leaving about twelve feet
of water above the core. The normal water level is six to ten inches below the top
of the tank. The licensees TS surveillance requirements may be deferred during
reactor shutdown, except for TSs 4.3 (1) and (5). TS 4.3 (1) which requires a
monthly channel check of the reactor tank water level monitor (float switch
alarm). The objective of the channel check is to assure that the water level
monitoring system is operating and to verify appropriate settings. This system is
designed to indicate loss of coolant (water) by alarming (and automatically
notifying the licensee) when water level decreases more than 15.5 inches from
the top of the tank.
During the July 2024 inspection, the NRC inspectors observed that the licensee
continued to perform the surveillance after lowering the water level, but they did
not change the setpoint at which the water level monitor would alarm. Because
the water level in the tank was lower than the alarm setpoint, the alarm was
always activated (outside of the surveillance) and would mask any actual loss of
coolant. Since the water level monitor cannot perform its design function at the
lowered level, the inspectors concluded that the monitoring system settings were
not appropriate. Consequently, the inspectors determined that the 50.59
evaluation was inadequate and a change to the TSs was required. Therefore, the
licensee needed to obtain a license amendment prior to lowering the water level
in its tank. The licensee was informed that failure to obtain a license amendment
prior to implementing a change in the facility that required an amendment to the
TSs incorporated in the license was a violation of 10 CFR 50.59(c)(1)(i) (VIO 05000407/2024201-01).
c.
Conclusion
The inspectors concluded that changes made at the facility during the
past 2 years were completed in accordance with 10 CFR 50.59 and applicable
licensee procedures with one exception that resulted in a violation of NRC
requirements.
5.
Committees, Audits and Reviews
a.
Inspection Scope (IP 69001, Section 02.09)
The inspectors reviewed the following to ensure that the review and audit
requirements in TS section 6.2 were met:
RSC meeting minutes from March 2022 to the present
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radiation safety and ALARA reviews and audits completed during the
past 2 years and licensee responses to the reviews and audits
UUTR annual operating reports for the last two reporting periods
b.
Observations and Findings
The inspectors found that the RSC met at least annually as required by the TSs.
The inspectors confirmed that all required audits of reactor facility activities and
reviews of programs, procedures, equipment, and proposed tests or experiments
were completed and documented. The inspectors noted that the audits and the
associated findings were detailed, and the licensee responded and took
corrective actions when needed. Additionally, the annual reviews of the Radiation
Protection Program and the E-Plan were conducted and documented.
c.
Conclusion
The inspectors determined that the RSC met at the required frequency and that
audits and reviews were conducted as required and in accordance TS section 6.2.
6.
Emergency Planning
a.
Inspection Scope (IP 69001, Section 02.10)
To verify that the licensee complied with the University of Utah, Utah Nuclear
Engineering Program (UNEP) Emergency Plan for NRC License R-126: TRIGA
Nuclear Reactor, Revision 8, dated July 20, 2011, the inspectors reviewed the
following selected aspects of:
selected emergency (implementing) procedures
emergency response supplies, equipment, and instrumentation
documentation of emergency drills and critiques for calendar years 2022,
2023, and 2024
UNEP Annual Emergency Training Attendance Record forms and related
records for staff and support personnel for calendar years 2022 and 2023
various UNEP forms including UNEP-015R4, Emergency Kit Check;
UNEP-021R28, UNEP Emergency Call List; and, UNEP-037, Radiological
Emergency Classification Checklist
letter of agreement with Gold Cross Services, Inc., dated October 22, 2021, for
ambulance transport
b.
Observations and Findings
The inspectors noted that the RSC audited the E-Plan annually, and the last
audit was completed on September 28, 2023. Implementing procedures were
reviewed and revised as needed.
The inspectors found that semiannual inventories of the various first aid kits and
other equipment were conducted and that the supplies, instrumentation, and
equipment were maintained as required in the E-Plan. The inspectors confirmed
that training for the reactor staff and the off-site support personnel was
- 8 -
conducted and documented. The inspectors also noted that the UNEP
Emergency Call List was up to date with the current revision dated
February 12, 2024.
The inspectors confirmed that emergency drills were conducted annually, and
critiques were held following each drill documenting strengths and areas for
improvement. The inspectors found drills to be challenging and the critiques
appropriate. The inspectors also reviewed the agreement between the licensee
and a local company to provide transportation services for a person or persons
injured at the facility and verified that it was maintained. The inspectors also
noted that communications capabilities with the various support groups were in
place and were tested periodically.
c.
Conclusion
The inspectors determined that the emergency preparedness program was
implemented as required by the E-Plan.
7.
Transportation Activities
a.
Inspection Scope (IP 86740)
The inspectors reviewed selected aspects of:
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 inspectors noted that the shipping 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 Rad Safety Office
requirements. The inspectors found that this shipping process was followed.
The inspectors noted that none of the licensee personnel has the current training
required to ship radioactive material as required by the Department of
Transportation. Therefore, in any instance involving the shipment of radioactive
material, the paperwork and shipments would be completed by qualified Rad
Safety Office personnel.
c.
Conclusion
The inspectors determined that the licensee transferred radioactive waste
material to the campus Rad Safety Office as needed and the Rad Safety Office
handled any shipments of radioactive material from the facility.
- 9 -
8.
Follow-up on Previous Items
a.
Inspection Scope (IP 92702)
The inspectors reviewed the following licensees actions taken in response to
previously identified items.
b.
Observation and Findings
(1)
Inspector Follow-up Item (IFI) 50-407/2019-202-01 - (Open) - Follow-up
on the licensees actions to complete the revision of the E-Plan and have
it reviewed and approved by the RSC.
10 CFR 50.34, Contents of Applications, Technical Information, requires
in Section (b)(6)(v) that each application for an operating license shall
include a final safety analysis report. The final safety analysis shall
include . . . plans for coping with emergencies . . .
The University of Utah, Utah Nuclear Engineering Program (UNEP)
Emergency Plan, dated June 2011, requires in Section 10.4, Emergency
Plan Review and Update, requires that the RS (Reactor Supervisor)
shall periodically revise and update the Emergency Plan . . . and the RSC
(Reactor Safety Committee) shall review and approve the overall UNEP
Emergency Plan to ensure that the Plan is adequate and current, and
shall specifically review and approve any revisions to the Emergency Plan
that affect implementation procedures.
In August 2019, an inspector noted that the RSC did not complete a
biennial review of the E-Plan. This was because a revision of the E-Plan
to incorporate suggested changes was not finished. The licensee
indicated that the revision was in progress and would be ready for review
by the December meeting of the RSC. The licensee was informed that the
revision of the E-Plan, and review and approval by the RSC, would be
designated as an IFI. During subsequent inspections it was noted that the
E-Plan was still being revised and, because of the ongoing revisions, the
RSC had not reviewed the plan.
During this inspection, the inspectors reviewed the issue and found that
the E-Plan was revised various times since 2019 and a review by the
RSC was still pending. Because there have been numerous changes in
the Facility Director and Reactor Supervisor positions since the issue was
first noted, the licensee has not followed this issue properly and no review
by the RSC has occurred as required. This issue is noted as a violation of
an administrative requirement in the Emergency Plan and does not
adversely affect the public health and safety. This failure to comply with
the University of Utah Emergency Plan, Section 10.4 constitutes a minor
violation that is not subject to enforcement action in accordance with the
NRC Enforcement Policy. However, this issue remains open.
(2)
IFI 05000407/2021201-02 - (Open) - Follow-up on the licensees actions
to revise procedure UNEP-002R4, Biennial Fuel/Tank/Control
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Rod/Reflector Element Inspection, to include maintenance actions
needed during control rod inspection.
In 2021, the inspector reviewed the circumstances surrounding a Special
Report issued by the licensee, dated April 2, 2020, documenting a
component malfunction.
On March 30, 2020, facility personnel completed the routine monthly
inspection of various reactor components and systems and initiated a
standard reactor startup and termination checklist to test all systems. The
licensee staff noted that the safety rod did not drop as expected.
Troubleshooting showed that the safety rod was not responding as
required and the Reactor Supervisor (RS) terminated the operation. The
safety rod was disassembled, and rust and calcium deposits were noted
and subsequently removed. Following these corrective actions, the safety
rod was inspected, reassembled, and reinstalled in the core. Testing and
calibration of the safety rod indicated that the malfunction was resolved,
and the rod functioned properly.
The licensee submitted a letter to the NRC concerning the component
malfunction in which the licensee indicated that the procedure involving
the inspection of the control rods, UNEP-002R4, Biennial Fuel/Tank/
Control Rod/Reflector Element Inspection, would be revised to include
checking for debris, binding, rubbing, or misalignment of the control rod
drives that might prevent the control rods from dropping. The licensee
was informed that the issue would be considered an IFI. During an
inspection in July 2023, this issue was reviewed, and the inspector found
that no action was taken on the procedure to that point.
During this inspection, the inspectors found that, since the inspection in
2020, changes occurred in the RS position at the facility and operators
who were aware of the situation. Consequently, the current RS and
operators have not completed the revision to the procedure. This issue
remains open.
(3)
IFI 05000407/2023201-02 - (Open) - Follow-up on the reactor tank repair
and the complete stoppage of tank water loss due to leakage.
The inspector reviewed the circumstances surrounding the notification
made by the licensee on March 31, 2023, to the NRC regarding a reactor
pool leak at the UUTR. The UUTR staff personnel noted the reactor tank
developed a leak of approximately 24 gallons per day (gals/day). The
licensee noted that there was no indication of leakage to the environment
and the leakage did not reach or exceed any reporting criteria. However, a
few days later the licensee noted that the leak rate increased to about
50 gallons a day. Water samples taken when the leak rate increased
continued to show there were no activity levels that reached any reporting
criteria or above any regulatory limit.
The licensee determined the most probable leak site would be a
degraded weld presumably toward the bottom of the circumference of the
tank (the point of highest pressure). To resolve the leak problem, the
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licensee hired a contractor to apply two-part epoxy sealant material to the
weld areas around the bottom three sections of the tank. During an
inspection in July 2023, the inspector observed the repair work on the
tank. At the completion of the inspection, the inspector noted that leak
appeared to have stopped but that the success of the repair project would
need to be evaluated further during a future inspection. The licensee was
informed that the issue of the reactor tank repair and the complete
stoppage of tank water loss due to leakage would be considered an IFI.
During this inspection the inspectors noted that the original problem with
a leak at a weld seam was resolved. However, following approximately
one month, a new leak developed, and the licensee is currently taking
action to repair the reactor tank a second time. This will involve removing
the reactor fuel from the tank and draining the tank so that an epoxy
coating can be applied to the entire interior surface of the tank. As a
result, this IFI will remain open.
(4)
URI 05000407/2023201-03 - (Closed) - Follow-up on the possible impact
the tank leak may have had on the facility and/or the surrounding.
environment and any potential violations that may have occurred as a
result.
As a result of the tank leak mentioned above, the NRC determined that
an Unresolved Item (URI) was warranted to follow up on the possible
impact the tank leak may have had on the facility and/or the surrounding
environment and any potential violations that may have occurred as a
result (URI 05000407/2023201-03).
During this inspection the inspectors discussed the reactor tank leak with
personnel from the Rad Safety Office and reviewed the extensive
documentation of sampling that they conducted following the initial
reactor tank leak. The inspectors noted that Rad Safety personnel
sampled numerous locations around the reactor facility and down-stream
from the reactor. None of the samples indicated radioisotopes in
concentrations that would be reportable to the NRC. Also, the sampling
showed that the concentration of tritium in the water in the area was
below the levels considered safe for drinking by the Environmental
Protection Agency (EPA). The sampling is continuing. The Rad Safety
Office is also coordinating their efforts with the State of Utah EPA and
keeping that office informed of all their findings. Based upon the findings
during this inspection discussed above, this issue is closed.
c.
Conclusion
The inspectors determined that one URI was closed and three IFIs remain open.
9.
Exit Meeting Summary
The inspection scope and results were summarized on July 11, 2024, with university
management and facility staff. The inspectors discussed the findings for each area
reviewed. The licensee did not identify any of the material provided to or reviewed by the
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inspectors as proprietary. The inspectors presented the re-exit meeting inspection
results through a video conference call on September 4, 2024, to Mr. Andrew Allison.
Attachment
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
A. Allison
Reactor Supervisor and Interim Facility Director
T. Goodell
Senior Reactor Operator
G. Sjoden
Director, Utah Nuclear Engineering Program
Other Personnel
M. Beitollahi
Health Physicist and Adjunct Associate Professor, Radiation Safety Office,
Environmental Health and Safety Department, University of Utah
J. Cunningham
Specialist, Hazardous Materials Team, Station No. 14, Salt Lake City Fire
Department
F. Monette
Radiation Safety Officer and Director of Environmental Health and Safety
Department, University of Utah
C. Olson
Health Physicist, Radiation Safety Office, Environmental Health and Safety
Department, University of Utah
T. Qiu
Chair, Department of Civil & Environmental Engineering, University of Utah
INSPECTION PROCEDURE (IP) USED
IP 69001:
Class II Non-Power Reactors
IP 86740:
Inspection of Transportation Activities
Follow-up on Previously Identified Items
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000407/2024201-01 VIO Failure to obtain a license amendment for a required change to
technical specifications incorporated in the license.
Closed
05000407/2023201-03 URI Follow-up on the possible impact the tank leak may have had on
the facility and/or the surrounding environment.
Discussed
50-407/2019-202-01
IFI
Follow-up on the licensees actions to complete the revision of the
Emergency Plan and have it reviewed and approved by the RSC.05000407/2021201-02 IFI
Follow-up on the licensees actions to revise procedure UNEP-
002R4, Biennial Fuel/Tank/Control Rod/Reflector Element
Inspection, to include maintenance actions needed during control
rod inspection.05000407/2023201-02 IFI
Follow-up on the reactor tank repair and the complete stoppage
of tank water loss due to leakage.