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{{#Wiki_filter:Code of Federal Regulations
{{#Wiki_filter:uly 3, 2019
/RA/


*********Code of Federal Regulations
==SUBJECT:==
**
MISSOURI UNIVERSITY OF SCIENCE AND TECHNOLOGY - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 50-123/2019-201


******
==Dear Mr. Taber:==
From June 3-5, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Missouri University of Science and Technology Reactor facility. The enclosed report documents the inspection results, which were discussed on June 5, 2019, with you, the Director of the Nuclear Reactor, the Director of the Environmental Health and Safety Department, who was also the campus Radiation Safety Officer, and a Senior Reactor Operator.


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


Code of Federal Regulations
Sincerely,
/RA/
Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-123 License No. R-79 Enclosure:
As stated cc: See next page
 
Missouri University of Science and Technology  Docket No. 50-123 cc:
Homeland Security Coordinator  Planning Coordinator Missouri Office of Homeland Security Missouri Department of Natural Resources P.O. Box 749  1101 Riverside Drive Jefferson City, MO 65102  Jefferson City, MO 65101 Planner, Dept of Health and Senior Services Section for Environmental Public Health 930 Wildwood Drive Jefferson City, MO 65102-0570 Deputy Director for Policy Department of Natural Resources 1101 Riverside Drive Fourth Floor East Jefferson City, MO 65101 A-95 Coordinator Commissioners Office Office of Administration P.O. Box 809 State Capitol Building, Room 125 Jefferson City, MO 65101 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 Dr. Ayodeji Alajo, Interim Program Director Missouri of Science and Technology Nuclear Engineering 222 Fulton Hall Rolla, MO 65409- 0630 Dr. Joseph Graham, Director Nuclear Reactor Facility Missouri University of Science and Technology Mining and Nuclear Engineering 228 Fulton Hall Rolla, MO 65409-0170
 
ML19177A008 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB/RI* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME CBassett  NParker  AMendiola DATE 7/1/2019  7/1/2019  7/3/2019
 
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-123 License No.: R-79 Report No.: 50-123/2019-201 Licensee: Missouri University of Science and Technology Facility: Missouri University of Science and Technology Reactor Facility Location: Rolla, MO Dates: June 3-5, 2019 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure
 
EXECUTIVE SUMMARY Missouri University of Science and Technology Nuclear Reactor Facility NRC Report No. 50-123/2019-201 The primary focus of this routine, announced inspection included onsite review of selected aspects of the Missouri University of Science and Technology (the licensee) Class II research reactor facility 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 since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees safety program was acceptably directed toward the protection of public health and safety. No violations or deviations were identified.
 
Organization and Staffing Organization and staffing were consistent with the requirements outlined in Section 6, Administrative Controls, of the facility technical specifications (TSs).
 
Staffing was at a minimum.
 
Procedures
* Written procedures were being maintained in accordance with TS requirements.
 
Health Physics
* Periodic surveys were completed and documented acceptably to permit evaluation of the radiation hazards present.
 
* Postings and signs met regulatory requirements.
 
* Personnel dosimetry was being worn as required and recorded doses were well within the NRCs regulatory limits.
 
* Radiation survey and monitoring equipment was being maintained and calibrated as required.
 
* The radiation protection training program was being implemented as stipulated by procedure.
 
* Gaseous effluent releases were within the specified TS levels and regulatory limits.
 
* The environmental protection program satisfied NRC requirements.
 
Design Changes
* The review and evaluation of changes satisfied NRC requirements specified in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, test and experiments.
 
-2-
 
Committees, Audits, and Reviews
* The Radiation Safety Committee (RSC) continued to perform independent oversight in accordance with TS requirements.
 
Transportation
* The licensee had not shipped any radioactive material under the Facility Operating License No. R-79 since the previous transportation inspection.
 
-3-
 
REPORT DETAILS Summary of Plant Status The Missouri University of Science and Technology (MS&T) 200 kilowatt (thermal) pool-type research reactor continued operation in support of graduate and undergraduate instruction, laboratory experiments, reactor operator training, and various forms of research. During the inspection, the reactor was not operated.
 
1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)
The inspector reviewed selected aspects of the following regarding the licensees organization and staffing to ensure that the requirements of Section 6.1, Organization, of the TSs (implemented as Appendix A to the Renewed Facility Operating License Number [No.] R-79, dated March 30, 2009) were being met:
* Contact phone number list, dated March 26, 2019
* Reactor Console Logbook No. 19, documenting operation from March 12, 2018 to the present
* Selected Missouri University of Science and Technology Reactor (MSTR)
Standard Operating Procedures (SOPs) including: SOP-102, Pre-Startup Checklist Procedure; SOP-105, Reactor Shutdown & Reactor Securing Procedures; SOP-107, Permanent Log, Hourly Log, and Operational Data; and, SOP-800, Annual Checklist
* MSTR Annual Progress Report for the Missouri University of Science and Technology Nuclear Reactor (facility annual report) for the period from April 1, 2017, to March 31, 2018, dated June 12, 2018
* MSTR Annual Progress Report for the Missouri University of Science and Technology Nuclear Reactor Facility for the period from April 1, 2018, to March 31, 2019, dated May 29, 2019
* RSC meeting minutes for 2017 through 2019 b. Observations and Findings The organizational structure had not changed since the last NRC inspection in this area (refer to NRC Inspection Report No. 50-123/2018-201). The MSTR staff responsibilities also remained unchanged. The facility was under the direct control of the Reactor Manager and he was responsible to the Nuclear Reactor Director for safe operation and maintenance of the reactor and its associated equipment. The Nuclear Reactor Director continued to report to the Chair of Mining and Nuclear Engineering Department (i.e., TS Level 1) as stipulated in the TSs.
 
Although the organizational structure had not changed, personnel changes had occurred. The inspector noted that the individual who had been serving as the Interim Reactor Manager (TS Level 3) had been replaced. A new Reactor Manager was appointed and took over on January 7, 2019. The licensee had submitted a report of this change to the NRC as required. It was noted that the-4-
 
person who had been Interim Reactor Manger subsequently left the facility and found other employment.
 
As of March 2019, there were three licensed senior reactor operators (SROs)
and two licensed reactor operators (ROs) at the MSTR facility. A review of the logs and records indicated that shift staffing was as required in the TSs. The inspector noted that each time the SRO or RO changed, an appropriate console log book entry was made.
 
It was noted that two of the three SROs had left the facility and the two ROs, who were students, had graduated and left the area. As of the date of the inspection, there was only one licensed operator at the facility (an SRO). Also, there had been no reactor operations since March.
 
c. Conclusion Organization was being maintained in accordance with TS Section 6.1. Staffing was at a minimum level.
 
2. Procedures a. Inspection Scope (IP 69001, Section 02.03)
To ensure that the requirements of TS Sections 6.2, Review and Audit, and 6.4, Operating Procedures, were being met, the inspector reviewed:
* Various MSTR SOPs including: SOP-600, General Health Physics; SOP-601, Handling of Radioactive Samples; SOP-602, Entry Into a High Radiation Area; SOP-604, Radioactive Waste Handling; SOP-615, Radiation Work Permits; SOP-621, Guidelines for Emergency Exposures; SOP-650, Radiation Area Survey; SOP-651, Contamination Survey; and, SOP-655, Radiation Area Monitor (RAM) Calibration
* MSTR Annual Progress Reports for the past two reporting periods
* RSC meeting minutes for the past two years b. Observations and Findings The inspector reviewed various MSTR procedures, including new revisions, and found that they met the requirements outlined in the TSs and that the RSC was reviewing changes as required. It was noted that there was a requirement for licensed operators to review and acknowledge new procedure revisions prior to operating the reactor or within one month of the revision. This was being done by the operators.
 
c. Conclusion Written procedures were being maintained in accordance with TS requirements.
 
-5-
 
3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)
To ensure that the requirements of 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, and TS Sections 3.6, Radiation Monitoring Systems and Radioactive Effluents, and 4.6, were being met, the inspector reviewed:
* Dosimeter calibration records for the past two years
* Survey meter calibration records for the past two years
* Documentation of various periodic surveys for the past 24 months
* Personal and environmental dosimetry records for the past two years
* Missouri S&T Annual Ar-41 Release Verification, dated October 27, 2014
* Missouri S&T Monthly Reactor Health Physics Audit, forms for the past three years
* Statement of Training and Experience for Use of Radiation Sources, release records for the past two years
* 2017 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 22, 2018
* 2018 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 18, 2019
* Various MSTR SOPs including: SOP-602, Entry Into a High Radiation Area; SOP-604, Radioactive Waste Handling; SOP-615, Radiation Work Permits; SOP-650, Radiation Area Survey; SOP-651, Contamination Survey; and, SOP-655, Radiation Area Monitor (RAM) Calibration
* MSTR Annual Progress Reports for the past two reporting periods b. Observations and Findings (1) Surveys Selected monthly, special, and other periodic radiation and/or contamination surveys were reviewed by the inspector. The surveys were typically completed by an Environmental Health and Safety (EH&S) student Health Physics (HP) technician, who had received the appropriate training to conduct surveys, and the campus Health Physicist. Any contamination detected in concentrations above established action levels was noted and the area or item was decontaminated. Following decontamination, the area or material was again surveyed to ensure that it was radiologically clean.
 
Results of the surveys were acceptably documented by HP staff personnel and reviewed by the campus Health Physicist and the campus Radiation Safety Officer (RSO).
 
During the inspection the inspector accompanied the campus Health Physicist and two student HP technicians during completion of a routine monthly radiation and contamination survey. Areas surveyed at the facility included the reactor bay and associated offices, hallways, the mezzanine, and the basement area. Various items in these areas were also surveyed.
 
The techniques used during the survey were adequate and the survey was-6-
 
conducted and documented in accordance with the guidance specified by procedure. The inspector conducted a radiation survey alongside the Health Physicist. The radiation levels noted by the inspector were comparable to those found by the Health Physicist and no anomalies were noted.
 
(2) Postings and Notices Radiological signs were typically posted at the entrances to controlled areas. Other postings also showed the industrial hygiene hazards that were present in the areas as well. Caution signs, postings, and controls for radiation areas were as required by 10 CFR Part 20, Subpart J, Precautionary Procedures. The inspector noted that licensee personnel observed the signs and postings and the precautions for access to radiation areas.
 
Copies of current notices to workers were posted in appropriate areas in the facility. The copy of NRC Form 3, Notice to Employees, noted at the facility was the latest issue and was posted as required by 10 CFR 19.11, Posting of notices to workers. The form was posted on the bulletin board in the hallway leading to the reactor bay.
 
(3) Dosimetry and Completed Copies of NRC Form 5 The inspector determined that the licensee used thermoluminescent dosimeters (TLDs) for whole body monitoring of beta and gamma radiation exposure. The TLDs also had a separate component to measure neutron radiation. The licensee also used TLD finger rings for extremity monitoring.
 
The TLD dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor, Mirion Technologies (GDS) Inc. On occasion the licensee also used digital direct-reading dosimeters for monitoring dose. This type of dosimeter was usually given to visitors. An examination of the TLD results indicating radiological exposures at the facility for the past three years showed that the highest occupational doses, as well as doses to the public, were well within 10 CFR Part 20 limitations. In fact, no person monitored by the licensee had received a dose in excess of 100 millirem (mrem) during any of those years.
 
Through direct observation the inspector determined that dosimetry was acceptably used by MSTR facility personnel and exit frisking practices were in accordance with facility radiation protection procedural requirements.
 
Individual copies of the NRC Form 5, Occupational Dose Record for a Monitoring Period, were not routinely issued to the licensee staff members.
 
This was because, as noted above, no one had received a dose of over-7-
 
100 mrem in a year. Forms could be requested if needed and were readily available at the EH&S office on campus. No problems were noted.
 
(4) Calibration of Radiation Survey and Monitoring Equipment Examination of selected meters in the facility, which were used for radiation monitoring, indicated that the instruments had the acceptable up-to-date calibration sticker attached. Review of the instrument calibration records for various meters and monitors indicated that the calibration of portable survey meters was typically completed on-site by licensee and EH&S personnel.
 
However, some of the high range instruments were shipped off-site to vendors for calibration. The inspector verified that the instruments were calibrated annually which met procedural requirements. Also, calibration records were maintained as required.
 
Radiation Area Monitors and the Continuous Air Monitor were also being calibrated annually as required. These various monitors were typically calibrated by licensee staff personnel as well.
 
(5) Radiation Protection Training The inspector reviewed the radiation worker and orientation training given to MSTR facility staff members, to those who were considered radioactive material users (rad mat users, or Users), and to students taking classes at the facility. The training program was outlined in the Missouri University of Science and Technology Handbook of Radiological Operations, and through facility procedures. It included initial radiation worker training for those who were new Users and new students just beginning the program. Annual refresher training was given to MSTR staff and students and to qualified Users and their assistants. It was noted that the Users were responsible for training those who worked with them on their research projects. The inspector reviewed the completed forms of various MSTR staff members and Users and verified that they had completed the appropriate training.
 
The training program was acceptable and consistent with the requirements outlined in 10 CFR Part 19 as well.
 
As noted above, initial training was provided when a person first started work or attending classes at the facility. Annual refresher training was being completed as required. The last refresher training for facility personnel and Users was completed during March and April 2019.
 
(6) Radiation Work Permit Program Radiation Work Permits (RWPs) were used infrequently at the facility. They were initiated for jobs that had the potential to produce an above average dose to the whole body and/or the extremities. In the past three years RWPs had only been issued for the task of control rod inspections.
 
The inspector reviewed the RWPs that had been written and used during 2016, 2017, and 2018. The inspector determined that the controls, precautions, and instructions specified in the RWPs appeared to be-8-
 
appropriate. It was also noted that the RWPs had been reviewed by the campus Health Physicist and had been closed out at the end of the job as required.
 
(7) Radiation Protection Program The licensees radiation protection and as low as reasonably achievable (ALARA) program was established and described in the Missouri University of Science and Technology Handbook of Radiological Operations, second edition, dated May 2003, and through associated HP procedures. The radiation protection program contained instructions concerning organization, training, monitoring, personnel responsibilities, audits, record keeping, reports, and maintaining doses ALARA. The ALARA portion of the handbook provided guidance for keeping doses ALARA which was consistent with the requirements in 10 CFR Part 20. The program, as established, appeared to be acceptable. The inspector verified that the radiation protection program was being reviewed annually as required by 10 CFR 20.1101, Radiation protection program, item (c).
 
The inspector noted that the licensee did not have a respiratory protection program or planned special exposure program. Neither program was required based on the current level of activity at the facility.
 
(8) Effluent and Environmental Monitoring Site gamma radiation monitoring was completed using three environmental monitoring station TLDs positioned at locations outside the reactor as required by the applicable procedure. Data indicated that there were no measurable doses above natural background radiation.
 
The inspector determined that gaseous releases continued to be calculated according to procedure. The airborne concentrations of the gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2. Also, the dose rate to the public as a result of the gaseous releases, was calculated to be 4.2 mrem per year which was well below the dose constraint specified in 10 CFR 20.1101(d) of 10 mrem per year. Records were current and acceptably maintained. Observation of the facility by the inspector indicated no new potential release paths.
 
The inspector inquired about the use of the Environmental Protection Agencys (EPAs) COMPLY code for calculating off site releases to demonstrate compliance. The licensee indicated that this had not been done in the past but that they would review the requirements and determine whether or not they needed to start using the code. The inspector indicated that the issue of using the EPAs COMPLY code or a later version known as CAP-88 would be identified as an Inspector Follow-up Item (IFI) and would be reviewed during a future inspection (IFI 50-123/2019-201).
 
The inspector reviewed the appropriate records and verified that no liquid effluent releases had been discharged from the MSTR facility to the sanitary sewer during 2017 and 2018.
 
-9-
 
The licensees program for monitoring, storing, and/or transferring radioactive liquid and solid waste was consistent with applicable procedural requirements. Liquid and solid radioactive waste was transferred to the MS&T Dangerous Materials Storage Facility (DMSF) under the Universitys Material License (#24-00513-40) for processing and disposal. This process was acceptably documented on the appropriate forms in accordance with the requirements of the EH&S Department. It was noted that a small amount of liquid radioactive waste was transferred to the campus DSMF during the 2017 - 2018 time period in accordance with procedure. Solid radioactive waste contained in three 55-gallon drums had been transferred during that time frame as well.
 
(9) Facility Tours The inspector toured the MSTR facility with licensee representatives and EH&S personnel on various occasions. The inspector noted that facility radioactive material storage areas were properly posted. No unmarked radioactive material was noted. Radiation areas were also posted as required.
 
c. Conclusion The inspector 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 well within the NRCs regulatory limits; (4) radiation survey and monitoring equipment was being maintained and calibrated as required; (5) the radiation protection training program was being implemented as stipulated by procedure; (6) gaseous effluent releases were within the specified TS levels and regulatory limits; and, (7) the environmental protection program satisfied NRC requirements.
 
4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)
To ensure that the requirements of 10 CFR 50.59 and the licensees administrative procedures were being met, the inspector reviewed:
* Reactor Console Logbook #19
* Facility Design Change Notebook
* RSC meeting minutes for the past two years
* MSTR Annual Progress Reports for the past two reporting periods
* 50.59 Screen and Evaluation of Installation of the Digital Recorders
* Paperless Temperature/CAM Recorder, No. 17-01, dated July 24, 2017
* MSTR SOP-310, Facility Modifications, most recently updated as of July 17, 2017
  - 10 -
 
b. Observations and Findings The most recent change at the facility involved changing and installing a digital recorder. The temperature and constant air monitor paper recorders were replaced with a digital recorder to eliminate the cost of paper. The inspector reviewed the 10 CFR 50.59, screening and evaluation and determined they were properly done. Testing was performed on August 10, 2017, as part of maintenance activities.
 
c. Conclusion The review and evaluation of changes satisfied NRC requirements specified in 10 CFR 50.59.
 
5. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)
To ensure that the requirements of TS Section 6.2 were being met, the inspector reviewed:
* Annual audits for 2017 and 2018
* RSC meeting minutes for the past two years
* Missouri S&T Monthly Reactor Health Physics Audit, forms for 2017, 2018, and to date in 2019
* MSTR Annual Progress Reports for the past two reporting periods
* 2017 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 22, 2018
* 2018 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 18, 2019
* Annual Independent Audit of the Missouri S&T Reactor, conducted by licensed operators from the University of Missouri Research Reactor (MURR), completed on December 6, 2017
* Annual Independent Audit of the Missouri S&T Reactor, conducted by licensed operators from MURR, completed on November 28, 2018 b. Observations and Findings The licensee used a single independent oversight safety committee, the RSC, to fill requirements for both the reactor license and the campus materials license.
 
The committee met quarterly to fulfill the requirements of their materials license but was only required to meet annually by reactor facility TS Section 6.2.2, Charter and Rules. The Reactor Manager briefed the committee each quarter on matters relating to reactor safety. The inspector reviewed the meeting minutes as well as the annual audits and found that the committee was performing its oversight duties appropriately.
 
To further enhance auditing and review of the facility, licensed ROs from the MURR typically conducted an annual review of the MS&T operations. This was a good practice and proved beneficial to both MS&T and MURR.
 
- 11 -
 
c. Conclusion The RSC continued to perform independent oversight in accordance with TS requirements.
 
6. Transportation a. Inspection Scope (IP 86740)
To ensure compliance with regulatory and procedural requirements for transferring or shipping licensed radioactive material, the inspectors reviewed the following:
* Liquid radioactive waste disposal records for the past two years
* Solid radioactive waste disposal records for the past two years b. Observations and Findings The inspector reviewed the file detailing radioactive shipments made under the reactor license No. R-79 and found that there were no shipments made since the previous inspection in the area of transportation. As noted above, the licensee typically transferred liquid and solid radioactive waste to the MS&T materials license for disposal. EH&S Department personnel were the ones who took possession of and removed the waste from the reactor facility.
 
It was noted that no one at the MSTR facility was designated as a radioactive material shipper and thus no one there was qualified to ship such material.
 
Those types of shipments were completed by EH&S personnel.
 
c. Conclusion The licensee did not ship any radioactive material under the reactor license No. R-79 since the previous transportation inspection.
 
7. Exit Interview The inspection scope and results were summarized on June 5, 2019, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the results of the inspection.
 
- 12 -
 
PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel A. Alchin Electronics Technician and Senior Reactor Operator J. Graham Director of the Nuclear Reactor Reactor Manager Other Personnel M. Bresnahan Director of Environmental Health and Safety and Campus RSO F. Al Falahi Campus Health Physicist INSPECTION PROCEDURE (IP) USED IP 69001 Class II Non-Power Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Open 50-123/2019-201 IFI Follow-up on the issue of whether or not the licensee should be using the EPAs COMPLY code or a later version known as CAP-88.
 
Closed None PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable EPA  Environmental Protection Agency DMSF Dangerous Materials Storage Facility EH&S Environmental Health and Safety (Department)
HP  Health Physics IP  Inspection Procedure MS&T Missouri University of Science and Technology MSTR Missouri University of Science and Technology Reactor MREM Millirem MURR University of Missouri Research Reactor No. Number NRC  U.S. Nuclear Regulatory Commission RO  Reactor Operator Attachment
 
RSC Radiation Safety Committee RSO Radiation Safety Officer RWP Radiation Work Permit SOP Standard Operating Procedure SRO Senior Reactor Operator TLD Thermoluminescent dosimeter TSs Technical Specification-2-
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Latest revision as of 17:39, 19 October 2019

Missouri University of Science and Technology - U.S. Nuclear Regulatory Commission Inspection Report No. 50 123/2019-201
ML19177A008
Person / Time
Site: University of Missouri-Rolla
Issue date: 07/03/2019
From: Anthony Mendiola
Research and Test Reactors Oversight Projects Branch
To: Taber E
Univ of Missouri - Rolla
Bassett C, NRRDLP, 240-535-1842
References
IR 2019201
Download: ML19177A008 (17)


Text

uly 3, 2019

SUBJECT:

MISSOURI UNIVERSITY OF SCIENCE AND TECHNOLOGY - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 50-123/2019-201

Dear Mr. Taber:

From June 3-5, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at the Missouri University of Science and Technology Reactor facility. The enclosed report documents the inspection results, which were discussed on June 5, 2019, with you, the Director of the Nuclear Reactor, the Director of the Environmental Health and Safety Department, who was also the campus Radiation Safety Officer, and a Senior Reactor Operator.

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

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-123 License No. R-79 Enclosure:

As stated cc: See next page

Missouri University of Science and Technology Docket No. 50-123 cc:

Homeland Security Coordinator Planning Coordinator Missouri Office of Homeland Security Missouri Department of Natural Resources P.O. Box 749 1101 Riverside Drive Jefferson City, MO 65102 Jefferson City, MO 65101 Planner, Dept of Health and Senior Services Section for Environmental Public Health 930 Wildwood Drive Jefferson City, MO 65102-0570 Deputy Director for Policy Department of Natural Resources 1101 Riverside Drive Fourth Floor East Jefferson City, MO 65101 A-95 Coordinator Commissioners Office Office of Administration P.O. Box 809 State Capitol Building, Room 125 Jefferson City, MO 65101 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 Dr. Ayodeji Alajo, Interim Program Director Missouri of Science and Technology Nuclear Engineering 222 Fulton Hall Rolla, MO 65409- 0630 Dr. Joseph Graham, Director Nuclear Reactor Facility Missouri University of Science and Technology Mining and Nuclear Engineering 228 Fulton Hall Rolla, MO 65409-0170

ML19177A008 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB/RI* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME CBassett NParker AMendiola DATE 7/1/2019 7/1/2019 7/3/2019

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-123 License No.: R-79 Report No.: 50-123/2019-201 Licensee: Missouri University of Science and Technology Facility: Missouri University of Science and Technology Reactor Facility Location: Rolla, MO Dates: June 3-5, 2019 Inspector: Craig Bassett Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Missouri University of Science and Technology Nuclear Reactor Facility NRC Report No. 50-123/2019-201 The primary focus of this routine, announced inspection included onsite review of selected aspects of the Missouri University of Science and Technology (the licensee) Class II research reactor facility 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 since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees safety program was acceptably directed toward the protection of public health and safety. No violations or deviations were identified.

Organization and Staffing Organization and staffing were consistent with the requirements outlined in Section 6, Administrative Controls, of the facility technical specifications (TSs).

Staffing was at a minimum.

Procedures

  • Written procedures were being maintained in accordance with TS requirements.

Health Physics

  • Periodic surveys were completed and documented acceptably to permit evaluation of the radiation hazards present.
  • Postings and signs met regulatory requirements.
  • Personnel dosimetry was being worn as required and recorded doses were well within the NRCs regulatory limits.
  • Radiation survey and monitoring equipment was being maintained and calibrated as required.
  • The radiation protection training program was being implemented as stipulated by procedure.
  • Gaseous effluent releases were within the specified TS levels and regulatory limits.
  • The environmental protection program satisfied NRC requirements.

Design Changes

  • The review and evaluation of changes satisfied NRC requirements specified in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, test and experiments.

-2-

Committees, Audits, and Reviews

  • The Radiation Safety Committee (RSC) continued to perform independent oversight in accordance with TS requirements.

Transportation

  • The licensee had not shipped any radioactive material under the Facility Operating License No. R-79 since the previous transportation inspection.

-3-

REPORT DETAILS Summary of Plant Status The Missouri University of Science and Technology (MS&T) 200 kilowatt (thermal) pool-type research reactor continued operation in support of graduate and undergraduate instruction, laboratory experiments, reactor operator training, and various forms of research. During the inspection, the reactor was not operated.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)

The inspector reviewed selected aspects of the following regarding the licensees organization and staffing to ensure that the requirements of Section 6.1, Organization, of the TSs (implemented as Appendix A to the Renewed Facility Operating License Number [No.] R-79, dated March 30, 2009) were being met:

  • Contact phone number list, dated March 26, 2019
  • Reactor Console Logbook No. 19, documenting operation from March 12, 2018 to the present
  • Selected Missouri University of Science and Technology Reactor (MSTR)

Standard Operating Procedures (SOPs) including: SOP-102, Pre-Startup Checklist Procedure; SOP-105, Reactor Shutdown & Reactor Securing Procedures; SOP-107, Permanent Log, Hourly Log, and Operational Data; and, SOP-800, Annual Checklist

  • MSTR Annual Progress Report for the Missouri University of Science and Technology Nuclear Reactor (facility annual report) for the period from April 1, 2017, to March 31, 2018, dated June 12, 2018
  • MSTR Annual Progress Report for the Missouri University of Science and Technology Nuclear Reactor Facility for the period from April 1, 2018, to March 31, 2019, dated May 29, 2019
  • RSC meeting minutes for 2017 through 2019 b. Observations and Findings The organizational structure had not changed since the last NRC inspection in this area (refer to NRC Inspection Report No. 50-123/2018-201). The MSTR staff responsibilities also remained unchanged. The facility was under the direct control of the Reactor Manager and he was responsible to the Nuclear Reactor Director for safe operation and maintenance of the reactor and its associated equipment. The Nuclear Reactor Director continued to report to the Chair of Mining and Nuclear Engineering Department (i.e., TS Level 1) as stipulated in the TSs.

Although the organizational structure had not changed, personnel changes had occurred. The inspector noted that the individual who had been serving as the Interim Reactor Manager (TS Level 3) had been replaced. A new Reactor Manager was appointed and took over on January 7, 2019. The licensee had submitted a report of this change to the NRC as required. It was noted that the-4-

person who had been Interim Reactor Manger subsequently left the facility and found other employment.

As of March 2019, there were three licensed senior reactor operators (SROs)

and two licensed reactor operators (ROs) at the MSTR facility. A review of the logs and records indicated that shift staffing was as required in the TSs. The inspector noted that each time the SRO or RO changed, an appropriate console log book entry was made.

It was noted that two of the three SROs had left the facility and the two ROs, who were students, had graduated and left the area. As of the date of the inspection, there was only one licensed operator at the facility (an SRO). Also, there had been no reactor operations since March.

c. Conclusion Organization was being maintained in accordance with TS Section 6.1. Staffing was at a minimum level.

2. Procedures a. Inspection Scope (IP 69001, Section 02.03)

To ensure that the requirements of TS Sections 6.2, Review and Audit, and 6.4, Operating Procedures, were being met, the inspector reviewed:

  • Various MSTR SOPs including: SOP-600, General Health Physics; SOP-601, Handling of Radioactive Samples; SOP-602, Entry Into a High Radiation Area; SOP-604, Radioactive Waste Handling; SOP-615, Radiation Work Permits; SOP-621, Guidelines for Emergency Exposures; SOP-650, Radiation Area Survey; SOP-651, Contamination Survey; and, SOP-655, Radiation Area Monitor (RAM) Calibration
  • MSTR Annual Progress Reports for the past two reporting periods
  • RSC meeting minutes for the past two years b. Observations and Findings The inspector reviewed various MSTR procedures, including new revisions, and found that they met the requirements outlined in the TSs and that the RSC was reviewing changes as required. It was noted that there was a requirement for licensed operators to review and acknowledge new procedure revisions prior to operating the reactor or within one month of the revision. This was being done by the operators.

c. Conclusion Written procedures were being maintained in accordance with TS requirements.

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3. Health Physics a. Inspection Scope (IP 69001, Section 02.07)

To ensure that the requirements of 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, and TS Sections 3.6, Radiation Monitoring Systems and Radioactive Effluents, and 4.6, were being met, the inspector reviewed:

  • Dosimeter calibration records for the past two years
  • Survey meter calibration records for the past two years
  • Documentation of various periodic surveys for the past 24 months
  • Personal and environmental dosimetry records for the past two years
  • Missouri S&T Annual Ar-41 Release Verification, dated October 27, 2014
  • Missouri S&T Monthly Reactor Health Physics Audit, forms for the past three years
  • Statement of Training and Experience for Use of Radiation Sources, release records for the past two years
  • 2017 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 22, 2018
  • 2018 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 18, 2019
  • Various MSTR SOPs including: SOP-602, Entry Into a High Radiation Area; SOP-604, Radioactive Waste Handling; SOP-615, Radiation Work Permits; SOP-650, Radiation Area Survey; SOP-651, Contamination Survey; and, SOP-655, Radiation Area Monitor (RAM) Calibration
  • MSTR Annual Progress Reports for the past two reporting periods b. Observations and Findings (1) Surveys Selected monthly, special, and other periodic radiation and/or contamination surveys were reviewed by the inspector. The surveys were typically completed by an Environmental Health and Safety (EH&S) student Health Physics (HP) technician, who had received the appropriate training to conduct surveys, and the campus Health Physicist. Any contamination detected in concentrations above established action levels was noted and the area or item was decontaminated. Following decontamination, the area or material was again surveyed to ensure that it was radiologically clean.

Results of the surveys were acceptably documented by HP staff personnel and reviewed by the campus Health Physicist and the campus Radiation Safety Officer (RSO).

During the inspection the inspector accompanied the campus Health Physicist and two student HP technicians during completion of a routine monthly radiation and contamination survey. Areas surveyed at the facility included the reactor bay and associated offices, hallways, the mezzanine, and the basement area. Various items in these areas were also surveyed.

The techniques used during the survey were adequate and the survey was-6-

conducted and documented in accordance with the guidance specified by procedure. The inspector conducted a radiation survey alongside the Health Physicist. The radiation levels noted by the inspector were comparable to those found by the Health Physicist and no anomalies were noted.

(2) Postings and Notices Radiological signs were typically posted at the entrances to controlled areas. Other postings also showed the industrial hygiene hazards that were present in the areas as well. Caution signs, postings, and controls for radiation areas were as required by 10 CFR Part 20, Subpart J, Precautionary Procedures. The inspector noted that licensee personnel observed the signs and postings and the precautions for access to radiation areas.

Copies of current notices to workers were posted in appropriate areas in the facility. The copy of NRC Form 3, Notice to Employees, noted at the facility was the latest issue and was posted as required by 10 CFR 19.11, Posting of notices to workers. The form was posted on the bulletin board in the hallway leading to the reactor bay.

(3) Dosimetry and Completed Copies of NRC Form 5 The inspector determined that the licensee used thermoluminescent dosimeters (TLDs) for whole body monitoring of beta and gamma radiation exposure. The TLDs also had a separate component to measure neutron radiation. The licensee also used TLD finger rings for extremity monitoring.

The TLD dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor, Mirion Technologies (GDS) Inc. On occasion the licensee also used digital direct-reading dosimeters for monitoring dose. This type of dosimeter was usually given to visitors. An examination of the TLD results indicating radiological exposures at the facility for the past three years showed that the highest occupational doses, as well as doses to the public, were well within 10 CFR Part 20 limitations. In fact, no person monitored by the licensee had received a dose in excess of 100 millirem (mrem) during any of those years.

Through direct observation the inspector determined that dosimetry was acceptably used by MSTR facility personnel and exit frisking practices were in accordance with facility radiation protection procedural requirements.

Individual copies of the NRC Form 5, Occupational Dose Record for a Monitoring Period, were not routinely issued to the licensee staff members.

This was because, as noted above, no one had received a dose of over-7-

100 mrem in a year. Forms could be requested if needed and were readily available at the EH&S office on campus. No problems were noted.

(4) Calibration of Radiation Survey and Monitoring Equipment Examination of selected meters in the facility, which were used for radiation monitoring, indicated that the instruments had the acceptable up-to-date calibration sticker attached. Review of the instrument calibration records for various meters and monitors indicated that the calibration of portable survey meters was typically completed on-site by licensee and EH&S personnel.

However, some of the high range instruments were shipped off-site to vendors for calibration. The inspector verified that the instruments were calibrated annually which met procedural requirements. Also, calibration records were maintained as required.

Radiation Area Monitors and the Continuous Air Monitor were also being calibrated annually as required. These various monitors were typically calibrated by licensee staff personnel as well.

(5) Radiation Protection Training The inspector reviewed the radiation worker and orientation training given to MSTR facility staff members, to those who were considered radioactive material users (rad mat users, or Users), and to students taking classes at the facility. The training program was outlined in the Missouri University of Science and Technology Handbook of Radiological Operations, and through facility procedures. It included initial radiation worker training for those who were new Users and new students just beginning the program. Annual refresher training was given to MSTR staff and students and to qualified Users and their assistants. It was noted that the Users were responsible for training those who worked with them on their research projects. The inspector reviewed the completed forms of various MSTR staff members and Users and verified that they had completed the appropriate training.

The training program was acceptable and consistent with the requirements outlined in 10 CFR Part 19 as well.

As noted above, initial training was provided when a person first started work or attending classes at the facility. Annual refresher training was being completed as required. The last refresher training for facility personnel and Users was completed during March and April 2019.

(6) Radiation Work Permit Program Radiation Work Permits (RWPs) were used infrequently at the facility. They were initiated for jobs that had the potential to produce an above average dose to the whole body and/or the extremities. In the past three years RWPs had only been issued for the task of control rod inspections.

The inspector reviewed the RWPs that had been written and used during 2016, 2017, and 2018. The inspector determined that the controls, precautions, and instructions specified in the RWPs appeared to be-8-

appropriate. It was also noted that the RWPs had been reviewed by the campus Health Physicist and had been closed out at the end of the job as required.

(7) Radiation Protection Program The licensees radiation protection and as low as reasonably achievable (ALARA) program was established and described in the Missouri University of Science and Technology Handbook of Radiological Operations, second edition, dated May 2003, and through associated HP procedures. The radiation protection program contained instructions concerning organization, training, monitoring, personnel responsibilities, audits, record keeping, reports, and maintaining doses ALARA. The ALARA portion of the handbook provided guidance for keeping doses ALARA which was consistent with the requirements in 10 CFR Part 20. The program, as established, appeared to be acceptable. The inspector verified that the radiation protection program was being reviewed annually as required by 10 CFR 20.1101, Radiation protection program, item (c).

The inspector noted that the licensee did not have a respiratory protection program or planned special exposure program. Neither program was required based on the current level of activity at the facility.

(8) Effluent and Environmental Monitoring Site gamma radiation monitoring was completed using three environmental monitoring station TLDs positioned at locations outside the reactor as required by the applicable procedure. Data indicated that there were no measurable doses above natural background radiation.

The inspector determined that gaseous releases continued to be calculated according to procedure. The airborne concentrations of the gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2. Also, the dose rate to the public as a result of the gaseous releases, was calculated to be 4.2 mrem per year which was well below the dose constraint specified in 10 CFR 20.1101(d) of 10 mrem per year. Records were current and acceptably maintained. Observation of the facility by the inspector indicated no new potential release paths.

The inspector inquired about the use of the Environmental Protection Agencys (EPAs) COMPLY code for calculating off site releases to demonstrate compliance. The licensee indicated that this had not been done in the past but that they would review the requirements and determine whether or not they needed to start using the code. The inspector indicated that the issue of using the EPAs COMPLY code or a later version known as CAP-88 would be identified as an Inspector Follow-up Item (IFI) and would be reviewed during a future inspection (IFI 50-123/2019-201).

The inspector reviewed the appropriate records and verified that no liquid effluent releases had been discharged from the MSTR facility to the sanitary sewer during 2017 and 2018.

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The licensees program for monitoring, storing, and/or transferring radioactive liquid and solid waste was consistent with applicable procedural requirements. Liquid and solid radioactive waste was transferred to the MS&T Dangerous Materials Storage Facility (DMSF) under the Universitys Material License (#24-00513-40) for processing and disposal. This process was acceptably documented on the appropriate forms in accordance with the requirements of the EH&S Department. It was noted that a small amount of liquid radioactive waste was transferred to the campus DSMF during the 2017 - 2018 time period in accordance with procedure. Solid radioactive waste contained in three 55-gallon drums had been transferred during that time frame as well.

(9) Facility Tours The inspector toured the MSTR facility with licensee representatives and EH&S personnel on various occasions. The inspector noted that facility radioactive material storage areas were properly posted. No unmarked radioactive material was noted. Radiation areas were also posted as required.

c. Conclusion The inspector 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 well within the NRCs regulatory limits; (4) radiation survey and monitoring equipment was being maintained and calibrated as required; (5) the radiation protection training program was being implemented as stipulated by procedure; (6) gaseous effluent releases were within the specified TS levels and regulatory limits; and, (7) the environmental protection program satisfied NRC requirements.

4. Design Changes a. Inspection Scope (IP 69001, Section 02.08)

To ensure that the requirements of 10 CFR 50.59 and the licensees administrative procedures were being met, the inspector reviewed:

  • Reactor Console Logbook #19
  • Facility Design Change Notebook
  • RSC meeting minutes for the past two years
  • MSTR Annual Progress Reports for the past two reporting periods
  • 50.59 Screen and Evaluation of Installation of the Digital Recorders
  • Paperless Temperature/CAM Recorder, No. 17-01, dated July 24, 2017
  • MSTR SOP-310, Facility Modifications, most recently updated as of July 17, 2017

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b. Observations and Findings The most recent change at the facility involved changing and installing a digital recorder. The temperature and constant air monitor paper recorders were replaced with a digital recorder to eliminate the cost of paper. The inspector reviewed the 10 CFR 50.59, screening and evaluation and determined they were properly done. Testing was performed on August 10, 2017, as part of maintenance activities.

c. Conclusion The review and evaluation of changes satisfied NRC requirements specified in 10 CFR 50.59.

5. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)

To ensure that the requirements of TS Section 6.2 were being met, the inspector reviewed:

  • Annual audits for 2017 and 2018
  • RSC meeting minutes for the past two years
  • Missouri S&T Monthly Reactor Health Physics Audit, forms for 2017, 2018, and to date in 2019
  • MSTR Annual Progress Reports for the past two reporting periods
  • 2017 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 22, 2018
  • 2018 Audit of the Missouri S&T Radiation Protection and ALARA Program, dated January 18, 2019
  • Annual Independent Audit of the Missouri S&T Reactor, conducted by licensed operators from the University of Missouri Research Reactor (MURR), completed on December 6, 2017
  • Annual Independent Audit of the Missouri S&T Reactor, conducted by licensed operators from MURR, completed on November 28, 2018 b. Observations and Findings The licensee used a single independent oversight safety committee, the RSC, to fill requirements for both the reactor license and the campus materials license.

The committee met quarterly to fulfill the requirements of their materials license but was only required to meet annually by reactor facility TS Section 6.2.2, Charter and Rules. The Reactor Manager briefed the committee each quarter on matters relating to reactor safety. The inspector reviewed the meeting minutes as well as the annual audits and found that the committee was performing its oversight duties appropriately.

To further enhance auditing and review of the facility, licensed ROs from the MURR typically conducted an annual review of the MS&T operations. This was a good practice and proved beneficial to both MS&T and MURR.

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c. Conclusion The RSC continued to perform independent oversight in accordance with TS requirements.

6. Transportation a. Inspection Scope (IP 86740)

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

  • Liquid radioactive waste disposal records for the past two years
  • Solid radioactive waste disposal records for the past two years b. Observations and Findings The inspector reviewed the file detailing radioactive shipments made under the reactor license No. R-79 and found that there were no shipments made since the previous inspection in the area of transportation. As noted above, the licensee typically transferred liquid and solid radioactive waste to the MS&T materials license for disposal. EH&S Department personnel were the ones who took possession of and removed the waste from the reactor facility.

It was noted that no one at the MSTR facility was designated as a radioactive material shipper and thus no one there was qualified to ship such material.

Those types of shipments were completed by EH&S personnel.

c. Conclusion The licensee did not ship any radioactive material under the reactor license No. R-79 since the previous transportation inspection.

7. Exit Interview The inspection scope and results were summarized on June 5, 2019, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the results of the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel A. Alchin Electronics Technician and Senior Reactor Operator J. Graham Director of the Nuclear Reactor Reactor Manager Other Personnel M. Bresnahan Director of Environmental Health and Safety and Campus RSO F. Al Falahi Campus Health Physicist INSPECTION PROCEDURE (IP) USED IP 69001 Class II Non-Power Reactors IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Open 50-123/2019-201 IFI Follow-up on the issue of whether or not the licensee should be using the EPAs COMPLY code or a later version known as CAP-88.

Closed None PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable EPA Environmental Protection Agency DMSF Dangerous Materials Storage Facility EH&S Environmental Health and Safety (Department)

HP Health Physics IP Inspection Procedure MS&T Missouri University of Science and Technology MSTR Missouri University of Science and Technology Reactor MREM Millirem MURR University of Missouri Research Reactor No. Number NRC U.S. Nuclear Regulatory Commission RO Reactor Operator Attachment

RSC Radiation Safety Committee RSO Radiation Safety Officer RWP Radiation Work Permit SOP Standard Operating Procedure SRO Senior Reactor Operator TLD Thermoluminescent dosimeter TSs Technical Specification-2-