IR 05000607/2019201

University of California-Davis - U.S. Nuclear Regulatory Commission Routine Inspection Report 05000607/2019201

ML19036A886
Person / Time
Site:	University of California-Davis
Issue date:	02/15/2019
From:	Anthony Mendiola Research and Test Reactors Oversight Projects Branch
To:	Frey W McClellan Nuclear Research Center
Bassett C, NRR/DLP/PROB, 240-535-1842
References
IR 2019201
Download: ML19036A886 (20)

Text

ary 15, 2019

SUBJECT:

UNIVERSITY OF CALIFORNIA-DAVIS - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 50-607/2019-201

Dear Dr. Frey:

From January 28-31, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at your University of California-Davis/McClellan Nuclear Research Center. The enclosed report documents the inspection results, which were discussed on January 30, 2019, with you and Mr. Guy Steingass, Operations Manager, and with Mr. David Reap, Radiation Safety Officer on January 31, 2019.

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 various personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Craig Bassett at (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. 50-607 License No. R-130 Enclosure:

As stated cc: See next page

University of California-Davis/McClellan Docket No. 50-607 cc:

Mr. David Reap, Radiation Safety Officer 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504 Mr. Walter Steingass, Reactor Supervisor 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504 California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814 Radiological Health Branch California Department of Public Health P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Dr.

College Park, MD 20742-2115

ML19036A886; *concurred via email NRR-002 OFFICE NRR/DLP/PROB/PM* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME CBassett NParker AMendiola DATE 2/9/2019 2/8/2019 2/15/2019

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No: 50-607 License No: R-130 Report No: 50-607/2019-201 Licensee: University of California-Davis Facility: McClellan Nuclear Research Center Location: McClellan Park Sacramento, California Dates: January 28-31, 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 University of California-Davis McClellan Nuclear Research Center NRC Inspection Report No. 50-607/2019-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the University of California-Davis (the licensees) 2 megawatts Class I research reactor safety program including: (1) effluent and environmental monitoring; (2) organization and operations and maintenance activities; (3) review and audit and design change functions; (4) procedures; (5) radiation protection; and, (6) inspection of transportation activities since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program was acceptably directed toward the protection of public health and safety and in compliance with NRC requirements.

Effluent and Environmental Monitoring

• Effluent and environmental monitoring satisfied license and regulatory requirements.

• Releases were within the limits specified in the regulations.

Organization and Operations and Maintenance Activities

• The organization and staffing were consistent with the requirements specified in Section 6 of the technical specifications (TSs).

Review and Audit Functions and Design Change Functions

• The Nuclear Safety Committee (NSC) was meeting at the required frequency, reviewing the topics outlined in TS Section 6.2, and conducting audits of facility programs as required.

• The design change and control program, including review, evaluation, and documentation of changes to the facility, satisfied NRC requirements.

Procedures

• The procedure review, revision, control, and implementation program generally satisfied TS requirements.

• Procedural compliance was acceptable.

Radiation Protection

• Surveys were being completed and documented acceptably to permit evaluation of the radiation hazards present.

• Postings met the regulatory requirements specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation.

-2-

• Personnel dosimetry was being worn as required and doses were within the licensees procedural action levels and NRCs regulatory limits.

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

• Acceptable radiation protection training was being provided to facility personnel.

Transportation of Radioactive Materials

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

-3-

REPORT DETAILS Summary of Facility Status The University of California-Davis (UCD) 2 megawatts Training, Research, Isotope, General Atomics (TRIGA) research reactor continued to be operated in support of neutron radiography, neutron tomography, experimental sample irradiation, and for tours of students and other members of the public. During the inspection the reactor was operated several hours per day at various power levels up to 1 megawatt to support neutron radiography, sample irradiation, and a tour.

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

The inspector reviewed the following to verify compliance with the requirements of 10 CFR Part 20 and Section 6.4.2(d) of the UCD/McClellan Nuclear Research Center (UCD/MNRC) TSs, Revision 13, dated March 28, 2003:

• Facility Procedure UCD/MNRC-0029-DOC-20, UCD/MNRC Radiation Protection Procedures, including:

- Section 3, Environmental Radiation Monitoring Procedures,

- Section 4, Radioactive Effluent Monitoring Procedures, and

- Section 17, Radioactive Waste Procedures

• Quarterly Environmental thermoluminescent dosimeters (TLDs) Reports for the last 2 years

• Radiochemical analysis data/results for 2018 of water samples taken from a ground water well near the facility

• UCD/MNRC 2016 Annual Report, submitted to the NRC on June 27, 2017

• UCD/MNRC 2017 Annual Report, submitted to the NRC on June 27, 2018 b. Observations and Findings The inspector determined that gaseous releases continued to be monitored, totals were acceptably calculated, and the results documented in the annual operating report as required. To ensure that airborne concentrations of gaseous releases were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2, the licensee monitored the effluents emitted from the stack and calculated the average concentration of material released. The average concentration was well within the regulatory effluent concentration limits. To demonstrate that the dose to the public from gaseous effluents as the result of reactor operations was below the dose constraint of 10 millirem per year specified in 10 CFR 20.1101, Radiation Protection Programs, paragraph (d),

the licensee completed a separate calculation. This calculation, which was based on the total amount of effluent released, was performed using the Environmental Protection Agencys computer code, CAP88-PC, Version 4.0.

The results indicated an annual dose to the public well below the regulatory limit.

The inspector verified that there were no liquid effluent releases from the facility during 2017 and 2018. It was also noted that, although many barrels of-4-

radioactive waste were being stored in various locations at the facility, no solid radioactive waste shipments had been made from the facility in 2017 or 2018.

Environmental water samples were collected, prepared, and sent to a vendor for analysis consistent with procedural requirements. The results of these analyses were all within regulatory limits. On-site and off-site gamma radiation monitoring was completed using various environmental Optically-Stimulated Luminescence (OSL) dosimeters in accordance with the licensees procedures as well. A review of these data indicated that any measurable doses were below regulatory limits.

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

2. Organization and Operations and Maintenance Activities a. Inspection Scope (IP) 69006 The inspector reviewed the following regarding the UCD/MNRC organization and staffing to ensure that the requirements of TS Section 6.1 were being met:

• Management responsibilities

• Current UCD/MNRC organizational structure and staffing

• Selected UCD/MNRC Operations Logs and UCD/MNRC Startup Checklists for 2018 documenting shift staffing

• Facility Procedure UCD/MNRC-0045-DOC-04, Quality Assurance Program for McClellan Nuclear Research Center (MNRC)

• UCD/MNRC Annual Reports for the last two reporting periods b. Observations and Findings The organization at the UCD/MNRC was as required by TS Section 6.0. The Vice Chancellor for Research was designated as the licensee for the university.

The UCD/MNRC facility was under the direct control of the UCD/MNRC Director/Reactor Administrator, who was accountable and reported to the Vice Chancellor for the safe operation and maintenance of the facility. Individuals at the facility in management positions, such as the Operations Manager/Reactor Supervisor and the Radiation Safety Officer (RSO), reported to the Director/Reactor Administrator and were responsible for implementing UCD/MNRC policies for operation of the facility, for safeguarding facility personnel and the public from undue radiation exposure, and for adhering to the operating license and TSs.

The staffing at the facility required for reactor operation was as specified in the TSs. The inspector noted that the person who was hired last year had been able to qualify as a radiographer. The licensee also planned to have this individual qualify as a reactor operator. The reactor staff was composed of five full-time-5-

personnel and one part-time staff member. Also, it was noted that five of the staff members were qualified senior reactor operators (SROs).

Review of various records demonstrated that management responsibilities were discharged as required by the TSs and applicable procedures.

c. Conclusion The organization and staffing were consistent with the requirements specified in TS Section 6.1.

3. Review and Audit and Design Change Functions a. Inspection Scope (IP 69007)

To verify that the required reviews and audits were being completed and that facility changes were controlled and evaluated as required in 10 CFR 50.59, Changes, tests, and experiments, and reviewed and approved as required by TS Section 6.2, the inspector reviewed selected aspects of:

• NSC meeting minutes for 2017 through the present

• MNRC UC Davis Audit, - the 2016 annual audit conducted by the Chair of the NSC on January 11, 2017

• MNRC UC Davis Audit, - the 2017 annual audit conducted by the Chair of the NSC on February 25, 2018

• 2017 MNRC Radiation Safety Program Review Report, - the annual radiation protection program review conducted on August 24, 2017, by the UCD Environmental Health and Safety (EH&S) Campus Associate RSO

• 2018 MNRC Radiation Safety Program Review Report, - the annual radiation protection program review conducted on October 30, 2018, by the UCD EH&S Research Safety Manager and the Campus Associate RSO

• UCD/MNRC Facility Modification Notebook containing the Facility Modification Log forms

• Selected Facility Modification Installation Authorization Forms and associated Facility Modification Checklist forms processed in the past

• Selected Facility Procedures including:

- UCD/MNRC-0043-DOC-04, Facility Modification Procedure, and,

- UCD/MNRC-0045-DOC-04, Quality Assurance Program for McClellan Nuclear Research Center (MNRC)

• UCD/MNRC Annual Reports for the last two reporting periods b. Observations and Findings (1) Review and Audit Functions Composition of the NSC and qualifications of committee members were as specified in TS Section 6.2.1. Minutes of the NSC meetings indicated that the committee continued to meet semiannually as required by TS Section 6.2.2 and provided review and oversight of the UCD/MNRC as specified in TS Section 6.2.3. Through records review the inspector-6-

determined that reviews were conducted by the NSC or designated representatives. Topics of those reviews were as required by the TSs and the reviews provided sufficient guidance, direction, and oversight to ensure safe and acceptable use of the reactor.

The inspector reviewed the results of the two most recent annual audits conducted at the facility. The inspector noted that these audits were appropriate and covered the activities specified in TS Section 6.2.4, including various aspects of the reactor facility operations and health physics programs. To help ensure timely completion of these audits, they had been added to the list of items in the licensees system used to track TSs required surveillances and other periodic items.

(2) Design Change Functions The regulatory requirements stipulated in 10 CFR 50.59, were implemented at the facility through Facility Procedure UCD/MNRC-0043-DOC-04, Facility Modification Procedure. The procedure was developed to address activities that affected changes to the facility as described in the safety analysis report (SAR), changes to MNRC procedures, and changes to or development of new tests or experiments not described in the SAR. The procedure adequately incorporated criteria provided by the regulations with additional requirements mandated by site-specific conditions.

The inspector reviewed the Facility Modification Log notebook to determine whether any entries had been made for 2017 and 2018. The notebook entries showed that no changes or modifications had been proposed or completed in the last 2 years.

c. Conclusion The NSC was meeting as required and reviewing the topics outlined in the TSs.

Audits of various reactor operations and programs were being conducted as required. The design change control program satisfied NRC requirements.

4. Procedures a. Inspection Scope (IP 69008)

To verify compliance with TS Section 6.4, the inspector reviewed selected portions of the following:

• MNRC Document List (Requiring 1 Year Review)

• Selected Document Review, forms completed by staff members

• MNRC Document List, showing all the licensees current documents and procedures including the date each was last reviewed

• Selected Facility Procedures including:

- UCD/MNRC-0005-DOC-09, MNRC Facility Document Control Plan,

-7-

- UCD/MNRC-0029-DOC-20, UCD/MNRC Radiation Safety Procedures, and,

- UCD/MNRC-0082-DOC-01, Environmental Compliance and Health and Safety Plan b. Observations and Findings According to TS Section 6.4, it was required that procedures be prepared and approved for the activities listed in that section. The procedures were required to be approved by the UCD/MNRC Director. Facility Procedure UCD/MNRC-0005-DOC-09 stipulated that the UCD/MNRC staff perform a biennial review of each active document to assure that it was current. The inspector determined that Operations and Health Physics procedures were typically being reviewed annually by licensee staff members, while maintenance and other procedures were generally reviewed biennially. It was noted that changes to procedures required the approval of the UCD/MNRC Director and all changes were required to be documented. The inspector also determined that no radiation protection procedural reviews were overdue for review at the time of the inspection.

The activities and operations observed by the inspector during this inspection were completed in accordance with the applicable procedures. These activities included reactor operations, handling radioactive material, and conducting surveys.

c. Conclusion The current procedure review, revision, control, and implementation program generally satisfied TS requirements. Procedural compliance was acceptable.

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

The inspector reviewed selected portions of the following regarding the licensees radiation protection program to ensure that the requirements of 10 CFR Part 19 and 10 CFR Part 20, and TS Sections 4.7 and 6.4.2 were being met:

• Calibration records of selected radiation detection and monitoring instruments

• List documenting all MNRC personnel who were authorized to handle radioactive material, dated October 16, 2017

• Monthly Occupational Radiation Exposure Reports for UCD/MNRC personnel for 2017 and 2018

• Individual NRC Form 5s, Occupational Exposure Record For A Monitoring Period, for UCD/MNRC personnel for 2016 and 2017 - (forms for 2018 were not yet available)

• 2017 MNRC Radiation Safety Program Review Report, completed by a member of the Campus EH&S Department and dated August 24, 2017

• 2018 MNRC Radiation Safety Program Review Report, completed by members of the Campus EH&S Department and dated November 6, 2018-8-

• Lesson plans, training objectives, and qualification cards for training of personnel by the RSO

• Selected daily, weekly, and quarterly contamination and radiation survey results for the past 2 years documented on forms entitled: RSO Daily Log, Radiological Survey (Weekly), and Radiological Survey (Quarterly)

• Facility Procedure UCD/MNRC-0029-DOC-20, UCD/MNRC Radiation Protection Procedures, (containing various Sections and Appendices which outlined the MNRC Radiation Protection Program) including:

- Section 5, Personnel Monitoring Procedures,

- Section 7, Radiation Survey Procedures,

- Section 9, Radiation Safety Training for UCD/MNRC Personnel,

- Section 12, Spill Procedure,

- Section 13, Procedures for Working with Radioactive Material,

- Section 16, Personnel Decontamination Procedures,

- Section 18, Radiation Work Permit Procedure, and,

- Section 20, ALARA Program Procedure

• Facility Procedure UCD/MNRC-0042-DOC-19, MNRC Health Physics Instrumentation and Test Procedures, containing various Addenda which specified equipment calibrations and tests

• UCD/MNRC Annual Reports for the last two reporting periods

• American National Standard Institute/American Nuclear Society-15.11-1993, Radiation Protection at Research Reactor Facilities, standard approval dated July 23, 1993 The inspector also toured the facility and observed the use of dosimetry and radiation monitoring equipment. In addition, the inspector conducted a radiation survey while accompanying the RSO as he completed a routine weekly survey.

Licensee personnel were interviewed and radiological signs and postings were observed as well.

b. Observations and Findings (1) Surveys The RSO daily log sheets and weekly, quarterly, and special radiation and contamination surveys were being completed by the RSO or other qualified staff members as required. A review of these records indicated that any contamination detected in concentrations above established action levels was noted on the appropriate form and the affected area or article was decontaminated. Results of the surveys were typically documented on survey maps and posted at the entrances of the various areas surveyed so that facility workers would be knowledgeable of the radiological conditions that existed in those areas prior to entry.

It was noted that all facility personnel had been trained to use radiation detection instruments. The inspector verified that various individuals, including radiographers, were performing limited radiation surveys using the appropriate meters (i.e., when the shield doors to the radiography bays were opened). The use of survey meters appeared to be adequate.

-9-

During the inspection, the inspector accompanied the facility RSO while he completed a weekly radiation and contamination survey. The inspector conducted a radiation survey alongside the RSO. Areas surveyed at the facility included the equipment room, the reactor room, and associated support areas. The RSO completed the survey using appropriate survey techniques. The radiation readings found by the inspector were comparable to those found by the RSO. No anomalies were noted.

(2) Postings and Notices Copies of current notices to workers were posted in appropriate areas of the facility. The required radiological signs were posted at the entrances to controlled areas. Other postings also showed the industrial hygiene hazards that were present in the areas as well. The copy of NRC Form 3 noted at the facility was the latest issue, as required by 10 CFR Part 19.

The form was posted on a bulletin board near the main entrance to the facility where visitors are required to sign in using the licensees visitors log.

(3) Dosimetry Personnel were observed to be wearing extremity and whole body dosimetry in the controlled areas in the appropriate manner and location.

The dosimetry being used consisted of OSL dosimeters and TLDs processed monthly by a National Voluntary Laboratory Accreditation Program certified vendor (Landauer). The OSL dosimeters were used for whole body monitoring and the TLDs were positioned in finger rings which were used for extremity monitoring. An examination of the OSL and TLD results, which documented the radiological exposures at the facility for the past 3 years, showed that the highest occupational doses, as well as doses to the public, were well within 10 CFR Part 20 limits.

Individual copies of NRC Form 5 that had been issued to the various staff members in 2016 and 2017 were reviewed. (Forms for 2018 were not yet available.) The forms accurately reflected the data reported in the individual exposure records. No problems were noted.

(4) Calibration of Radiation Monitoring Equipment Selected calibration records of portable survey meters, friskers, fixed radiation detectors, and air monitoring instruments in use at the facility were reviewed. The records showed that the meters and detectors were either calibrated by reactor staff or were sent off site to be calibrated by a contractor. The calibrations were tracked and documented as required.

The inspector confirmed that the frequency of these calibrations satisfied the requirements established in TS Section 4.7 and 10 CFR 20.1501, General, paragraph (b). All instruments checked by the inspector that were staged for use or that were in use at the facility had a current calibration sticker attached.

- 10 -

(5) Radiation Protection Program The radiation protection program was described and implemented by procedures and policies that were well documented as required by TS Section 6.4.2 and 10 CFR 20.1101(a). Annual audits of the radiation protection program had been completed by members of the Campus EH&S Department and documented in reports dated August 28, 2017, and November 6, 2018. These audits satisfied the periodic program review required by 10 CFR 20.1101(c). No significant issues were identified by the auditors but various recommendations for improvements were made.

(6) Personnel Training Personnel training required by 10 CFR 19.12, Instruction to workers, was provided by the RSO. In a graded approach, there were five levels or plans for training designated as A through E. The type of training provided to an individual was dictated by the type of visit conducted or the type of work to be performed and whether or not the person would be required to enter any controlled area and/or handle radioactive material.

The inspector determined that the appropriate training was being provided to individuals visiting the facility and to those working at the facility. It was noted that Lesson Plan A (for visitors) had recently been updated and could now be completed on-line prior to the visitor arriving at the facility.

The inspector reviewed the training given to various personnel, other than visitors, and noted that training was being completed as required.

Specific supplemental training was also provided as needed to ensure that personnel understood the subjects. An annual radiation safety review emphasizing the as low as reasonably achievable (ALARA)

principle was provided to all facility staff members as well. The training appeared to be adequate.

(7) Radiation Work Permit Program The inspector reviewed the radiation work permits (RWPs) that had been written and used during 2018. The inspector determined that the controls, precautions, and instructions specified in the RWPs appeared to be appropriate. It was also noted that the RWPs had been reviewed by the RSO as required. The 2018 RWPs had been closed out at the end of the year as required and new RWPs had been issued for 2019. The 2019 RWPs were similar to the ones issued for 2018 and typically covered routine maintenance work as well as experiment disassembly. The inspector determined that no special RWPs had been issued during 2018.

(8) Facility Tours The inspector toured the main staging or set-up area, the equipment room, the reactor room, and various support areas with licensee representatives on various occasions and observed on-going activities. It

- 11 -

was noted that facility radioactive material storage areas were properly posted. No unmarked radioactive material was noted. Radiation and high radiation areas were posted as required and properly controlled.

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 within the NRCs regulatory limits, (4) radiation survey and monitoring equipment was being maintained and calibrated as required, and (5) the radiation protection training program was being implemented as stipulated in procedure.

6. Transportation Activities a. Inspection Scope (IP 86740)

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

• Selected licenses of various UCD/MNRC consignees

• Records of the radioactive material shipments made during 2018 including completed radiological survey forms

• Training records for staff personnel authorized to ship hazardous material in accordance with the regulations specified by the Department of Transportation (DOT)

• Facility Procedure UCD/MNRC-0029-DOC-20, UCD/MNRC Radiation Protection Procedures, including:

- Section 11, Procedure for Receiving Radioactive Material,

- Section 21, Procedures for Shipping Radioactive Material, and,

- Section 21 Appendix 21-A, Limited Quantity of Class 7 (Radioactive)

Materials Checklist b. Observations and Findings Through records review and discussions with licensee personnel, the inspector determined that the licensee made six shipments of radioactive material during 2018. All the shipments had been designated as limited quantity shipments and had been shipped to various consignees including the Australian National University, University of California - Berkley Geochronology Center, and Texas Tech University. The records indicated that the radioisotope types and quantities were calculated and dose rates were measured as required. The radioactive material shipment records reviewed by the inspector had been completed in accordance with DOT and NRC regulations.

The inspector verified that the licensee maintained copies of shipment recipients licenses to possess radioactive material, or possession authorization letters for

- 12 -

Department of Energy customers, as required. The licenses were determined to be current or in timely renewal prior to initiating a shipment. The inspector also verified that the recipients were authorized to receive and possess the type and quantity of radioactive material shipped to them.

The inspector reviewed the training of MNRC staff members responsible for shipping radioactive material. The inspector verified that licensee personnel designated as shippers had received the appropriate training covering the specified requirements within the past 3 years as required by the regulations.

c. Conclusion Radioactive material was being shipped in accordance with the applicable NRC and DOT regulations.

7. Follow-up on Previously Identified Item a. Inspection Scope (IP 92701)

The inspector reviewed the licensees actions taken in response to a previously identified inspector follow-up item (IFI).

b. Observation and Findings IFI 50-607/2017-201-01 - Follow-up on the licensees actions to conduct the facility annual Emergency Drill for 2017.

During an inspection from January 8-11, 2018, the documentation of the drills conducted for 2015 and 2016 was reviewed. Through drill scenario and record reviews, and personnel interviews, off-site emergency responders were determined to be knowledgeable of the proper actions to take in case of an emergency. Emergency drills had been conducted annually and had included the participation of off-site support groups every other year as required by the Emergency Plan. The scenarios written for the drills and the critiques held thereafter were well documented. However, during the inspection it was also noted that no drill had been conducted for the calendar year 2017. The licensee was informed that the issue of completion of the 2017 Emergency Drill would be reviewed during a subsequent inspection.

During this inspection the inspector reviewed this issue with the licensee. It was noted that, in lieu of a staged drill, the licensee had taken credit for an actual event involving the response of the Sacramento County Fire Department to an alarm at the facility. The event occurred on the back shift of January 21, 2018.

The alarm was determined to be false after the entire facility was checked. The licensee subsequently held a critique following the event and conducted training in the proper response to such a problem as well. This issue is considered closed.

c. Conclusion One Inspector IFI was reviewed during this inspection. The item is closed.

- 13 -

7. Exit Interview The inspection scope and results were summarized on January 30 and 31, 2019, with members of licensee management and the RSO respectively. The inspector described the areas inspected and discussed the inspection findings. The licensee acknowledged the findings presented and did not identify as proprietary any of the material provided to or reviewed during the inspection.

- 14 -

PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel H. Bollman Radiography Supervisor and SRO C. Dresser Radiographer and Reactor Operator Trainee Facility Director and SRO T. Essert Electrical Engineer and SRO D. Reap Radiation Safety Officer, Security Officer, and SRO W. Steingass Associate Director for Reactor Operations, Operations Manager, and SRO INSPECTION PROCEDURES USED IP 69004 Class I Research and Test Reactor Effluent and Environmental Monitoring IP 69006 Class I Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class I Research and Test Reactor Procedures IP 69012 Class I Research and Test Reactor Radiation Protection IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 50-607/2018-201-01 IFI Follow-up on the licensees actions to conduct the facility annual Emergency Drill for 2017.

PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable DOT Department of Transportation EH&S Environmental Health and Safety IFI Inspector Followup Item IP Inspection Procedure MNRC McClellan Nuclear Research Center NRC U.S. Nuclear Regulatory Commission NSC Nuclear Safety Committee OSL Optically-Stimulated Luminescence RSO Radiation Safety Officer RWP Radiation Work Permit SAR Safety Analysis Report Attachment

SRO Senior Reactor Operator TLD Thermoluminescent dosimeter TSs Technical Specifications UCD/MNRC University of California-Davis/McClellan Nuclear Research Center-2-