IR 05000150/2018201

Ohio State University - U.S. Nuclear Regulatory Commission Safety Inspection Report 05000150/2018201

ML18361A646
Person / Time
Site:	Ohio State University
Issue date:	01/09/2019
From:	Anthony Mendiola Research and Test Reactors Oversight Projects Branch
To:	Cao L Ohio State University
Schuster W, NRR/DLP, 415-1590
References
IR 2018201
Download: ML18361A646 (18)

Text

ary 9, 2019

SUBJECT:

OHIO STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000150/2018-201

Dear Dr. Cao:

From November 27-29, 2018, the U.S. Nuclear Regulatory Commission (NRC) conducted an announced safety inspection at the Ohio State University Nuclear Reactor Laboratory facility.

The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection.

During the inspection, the NRC staff examined activities conducted under your license as they relate to public health and safety to ensure compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of this inspection, no findings of non-compliance 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). Should you have any questions concerning this inspection, please contact Mr. William Schuster at 301-415-1590 or by electronic mail at William.Schuster@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. 50-150 License No. R-75 Enclosure:

As stated cc: See next page

Ohio State University Docket No. 50-150 cc:

Chief Ohio Department of Health Bureau of Environmental Health and Radiation Protection 246 North High Street Columbus, OH 43215 Radiological Branch Chief Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235 2206 Andrew Kauffman, Associate Director Nuclear Reactor Laboratory Ohio State University 1298 Kinnear Road Columbus, OH 43212 David B. Williams, Dean College of Engineering Ohio State University 142A Hitchcock Hall 2070 Neil Ave.

Columbus, OH 43210-1278 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611

ML18361A646 *concurrence via e-mail NRC-002 OFFICE NRR/DPR/PROB/PM* NRR/DPR/PROB/LA* NRR/DPR/PROB/BC NAME WSchuster NParker AMendiola DATE 1/2/2019 12/28/2018 1/9/2019

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-150 License No.: R-75 Report No.: 05000150/2018-201 Licensee: Ohio State University Facility: Nuclear Reactor Laboratory Location: Columbus, Ohio Dates: November 27-29, 2018 Inspector: William Schuster Approved by: Anthony Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY Ohio State University Nuclear Reactor Laboratory NRC Report No. 05000150/2018-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the Ohio State University (OSU or the licensee) 500-kilowatts (kWs) Class II research reactor facility safety program, including: (1) procedures; (2) experiments; (3) health physics; (4) design changes; (5) committees, audits, and reviews; and (6) transportation of radioactive materials since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees programs were acceptably directed toward the protection of public health and safety, and in compliance with NRC requirements.

Procedures

• Procedural review, revision, control, and implementation satisfied technical specification (TS) requirements.

Experiments

• The program for reviewing, approving, and conducting experiments satisfied TS and procedural requirements.

Health Physics

• Surveys were being completed and documented acceptably.

• Postings met regulatory requirements.

• Personnel dosimetry was being worn as required and doses were within regulatory limits.

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

• Radiation protection training was being provided to facility personnel.

• Calculations of effluents released from the facility satisfied license and regulatory requirements and releases were within the specified regulatory limits.

Design Changes Changes to the facility were being evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests and experiments, and were reviewed and approved by the Reactor Operations Committee (ROC) as required.

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Committees, Audits, and Reviews

• Review, audit, and oversight functions required by the TSs were acceptably completed by the ROC.

Transportation of Radioactive Materials

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

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REPORT DETAILS Summary of Facility Status The OSU 500 kWs open pool-type reactor continued to be operated in support of undergraduate instruction, laboratory experiments, and various types of irradiation projects. During the inspection, the reactor was started up, operated, and shut down as required to support these ongoing activities.

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

To verify compliance with the licensees TS requirements for procedures, the inspector reviewed selected aspects of the licensees program, including:

• Appendix A to Renewed Facility Operating License No. R-75, Technical Specifications and Bases for The Ohio State University Pool-Type Nuclear Reactor, Columbus, Ohio, Docket No. 50-150, dated June 2008.

• Select procedures, The OSU Nuclear Reactor Laboratory (NRL) Operating Procedures

• Various tables listing effective procedures, revision numbers, revision dates, ROC review, and last NRL review b. Observations and Findings The inspector reviewed the facility procedures and the processes to write, review, approve, and change procedures. The inspector noted that facility procedures had been developed as required by TS 6.3.1, Reactor Operating Procedures, and TS 6.3.2, Administrative Procedures. The procedures were written, reviewed, approved, and changed in accordance with TS 6.3.1 and Administrative Procedure (AP)-06, Format for Writing, Revising, and Approving Procedures. All procedures were reviewed biennially (between January 2017 and October 2018) as recommended by AP-06. During the inspection, the inspector observed NRL staff following procedures to complete tasks.

Additionally, the procedures being used appeared to be effective and able to be implemented for the intended purposes.

c. Conclusion Procedural review, revision, control, and implementation satisfied TS requirements.

2. Experiments a. Inspection Scope (IP 69001, Section 02.06)

To verify compliance with the licensees TS requirements for experiments, the inspector reviewed selected aspects of the licensees program, including:

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• Appendix A to Renewed Facility Operating License No. R-75, Technical Specifications and Bases for The Ohio State University Pool-Type Nuclear Reactor, Columbus, Ohio, Docket No. 50-150, dated June 2008.

• The Ohio State University Research Reactor Annual Report for [Fiscal Year (FY)] 2017/2018, dated September 2018.

• Select procedures, The OSU NRL Operating Procedures

• Select records, completed AP-03 Attachment, Request for Reactor Operation, numbered NRL 17-01 through NRL 18-12.

• ROC Meeting Agenda and Minutes, dated July 27, 2018

• Select pages from [Ohio State University Research Reactor] OSURR Operations Logbook[s], from the time period 2017-2018

• Select records, The Ohio State University Research Reactor Pre-Startup and Post-Shutdown Checkout Form, from the time period 2017-2018 b. Observations and Findings The inspector reviewed the experiment review and approval process at the facility. The inspector verified that experiments utilizing the reactor were evaluated in accordance with TS 6.4.2, Approved Experiments. The inspector also verified that experiments not previously approved for the reactor were reviewed and approved by the ROC in accordance with TS 6.4.3, New Experiments. The inspector reviewed more than 20 Requests for Reactor Operation from 2017 to present day. Based on review of these records, the inspector determined that experiments being conducted at the facility met the reactivity limit, design, and material requirements in TS 3.7, Experiments.

During the inspection, the inspector observed irradiation of a previously approved experiment. The inspector noted this activity was performed by two senior reactor operators (SRO) and followed the procedure developed for the approved experiment in the request for Reactor Operation.

c. Conclusion The program for reviewing, approving, and conducting experiments satisfied TS and procedural requirements.

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

To verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and Part 20, Standards for Protection against Radiation, TS requirements for health physics, and procedural requirements, the inspector reviewed selected aspects of the licensees program, including:

• Appendix A to Renewed Facility Operating License No. R-75, Technical Specifications and Bases for The Ohio State University Pool-Type Nuclear Reactor, Columbus, Ohio, Docket No. 50-150. dated June 2008.

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• The Ohio State University Research Reactor Annual Report for FY 2017/2018, dated September 2018.

• OSU Radiation Safety Culture and ALARA. Excerpt from The Ohio State University Radiation Safety Standard, dated February 2018.

• Personnel Monitoring Programs. Excerpt from The Ohio State University Radiation Safety Standard, dated February 2018.

• Select Radiation Safety (RS) procedures, The OSU NRL Operating Procedures

• Select records, completed RS-08 Attachment A, Reactor Building Smear Survey Form, from the time period 2017-2018

• Select records, completed RS-04 Attachment A, Particulate Air Sample Data Sheet, from the time period 2017-2018

• Select records, completed RS-09 Attachment A, Reactor Building Area Radiation Survey, from the time period 2017-2018

• Select records, completed RS-17 Attachment A, Ar-41 Weekly Release Record, from the time period 2017-2018

• Select records, Calibration of radiation monitoring instruments

• Select records, Personnel dosimetry results, from the time period 2017-2018

• Select records, Environmental dosimetry results, from the time period 2017-2018

• Memorandum to file. 2018 Lab-Specific Radiation Safety Training, dated January 17, 2018

• Completed RS-6 form, Annual Training of Approved Users, dated January 10 and 12, 2018 (NRL Staff)

• OSU-NRL Visitor Logbook Page for Tour Groups, dated January 26, 2018

• Completed RS-6 form, dated January 26, 2018 (Faculty & Users)

• Memorandum to file, 2018 NRL Irradiator Supervisor Training, dated January 17, 2018

• Completed form, 2018 Irradiator Training Log, dated January 10, 2018

• Memorandum to file, 2017 Lab-Specific Radiation Safety Training, dated January 11, 2017

• Completed RS-6 form, dated January 11 and 27, 2017

• Memorandum to file, 2017 NRL Irradiator Supervisor Training, dated January 11, 2017

• Completed form, 2017 Irradiator Training Log, dated January 4, 2017 b. Observations and Findings (1) Surveys The inspector reviewed selected radiation and contamination surveys of the NRL from 2017 to the present day. The results were documented on the appropriate forms and evaluated as required, comments were provided if readings were higher than expected, and corrective actions were taken when readings or results exceeded set action levels. The surveys had been completed as required by procedures and in accordance with the requirements in Subpart F, Surveys and Monitoring, to 10 CFR Part 20. The licensee also received radiological support from the OSU Office of Environmental Health and Safety (EH&S)

Radiation Safety group. The OSU EH&S Radiation Safety group-6-

performed specific monthly and quarterly inspections and surveys of the reactor and the licensees controlled areas conforming to the campus radiation safety program.

During the inspection, the inspector accompanied an SRO during the completion of a routine radiation survey of the reactor building in accordance with RS-09, Area Radiation Surveys. The readings were consistent with expected radiation levels for each area in the reactor building.

(2) Postings and Notices During a tour of the facility, the inspector observed that signage, posting, and labels were used in accordance with requirements in Subpart J, Precautionary Procedures, to 10 CFR Part 20. Radioactive material storage areas were noted to be properly posted. No unmarked radioactive material was detected in the facility.

Copies of notices to workers were posted in the facility, including a copy of the most recent revision of NRC Form 3, Notice to Employees, as required by 10 CFR 19.11, Posting of notices to workers.

(3) Dosimetry The inspector determined that the licensee was monitoring individuals in accordance with the requirements in 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose.

The licensee used thermoluminescent dosimetry (TLD) for whole body monitoring of beta, gamma, and neutron radiation exposure. The licensee also used TLD finger rings for extremity monitoring for beta and gamma radiation exposure. The dosimetry was supplied through the OSU EH&S Radiation Safety group and processed by a National Voluntary Laboratory Accreditation Program accredited vendor, Mirion.

An examination of the dosimetry records for the past 2 years showed that the highest occupational doses were within Subpart C, Occupational Dose Limits, to 10 CFR Part 20 limits and licensee action levels.

The inspector verified that NRC Form 5 or equivalent reports, as required by 10 CFR 19.13, Notifications and reports to individuals, had been completed and provided to each employee who had received exposure at the facility during 2017 and 2018 by the OSU EH&S Radiation Safety group. Additionally, the NRL maintained copies of exposure records for the past few years that could be provided upon request.

(4) Radiation Monitoring Equipment The inspector reviewed the records of selected meters, detectors, and air monitoring equipment in use at the facility. The calibration of portable survey meters and friskers were typically completed by the OSU EH&S Radiation Safety group while fixed radiation detectors and air monitoring instruments were calibrated by OSURR personnel at the facility. Annual-7-

calibration and quarterly source check frequency of the portable and fixed meters and monitors were consistent with manufacturers recommendations and appropriate calibration records were being maintained. Portable survey meters were maintained as required by TS 4.6.3, Portable Survey Instrumentation, and Subpart F to 10 CFR Part 20.

During the inspection, the inspector observed storage and use of portable survey instrumentation at the facility. Portable survey instrumentation capable of measuring beta, gamma, and neutron exposure and dose rates were available and operable during times when the reactor was operating as required by TS 3.6.1.(3).

(5) Radiation Protection Training The inspector reviewed documentation of the initial and annual radiation protection training given to staff and users entitled, OSU-NRL Lab-Specific Radiation Safety Training. The course documentation consisted of a presentation, evaluation (quiz), and attendance records.

Through a review of records, the inspector verified that training was provided to new users as well as staff members who had been at the facility for over a year. The content of the training program satisfied the requirements in 10 CFR 19.12, Instruction to workers.

(6) Radiation Protection Program The licensees radiation protection program was acceptably established in the OSU Radiation Safety Standards, as well as through the facility procedures. Part of the annual OSU NRL audit ensured that the radiation protection program at the facility was being conducted as required by the applicable procedures. No deficiencies related to the radiation protection program at the OSU NRL were identified during audits of the program.

(7) ALARA Policy A policy for maintaining radioactive exposure to personnel as low as reasonably achievable (ALARA) was outlined and established in the OSU Radiation Safety Standard. The policy discussed and set expectations for radiation safety culture and provided guidance for keeping doses ALARA, including local action levels for personnel radiation exposure doses, consistent with the requirements in 10 CFR 20.1101, Radiation protection programs.

(8) Environmental Monitoring and Effluents The inspector reviewed the calibration records of the area radiation monitors and the gaseous effluent (or stack) monitor. These systems were calibrated annually in accordance with the requirements in TS 4.6.1, Effluent Monitor and TS 4.6.2, Area Radiation Monitors. The inspector also reviewed selected records from the past 2 years of the daily channel test for both of these systems. During the inspection, the inspector-8-

observed both of these systems operable and operating while the reactor was in operation, as required by TS 3.6.1.(1) and TS 3.6.1.(2).

The inspector reviewed the records documenting solid, liquid, and airborne releases to the environment. The inspector reviewed the method the licensee used to handle solid radioactive waste. The inspector noted that the licensees solid radioactive material continued to be transferred to the EH&S for storage and/or disposal. No releases of solid radioactive material to the environment occurred. No liquid releases from operation of the OSURR during the time period reviewed. The inspector determined that gaseous release activity continued to be calculated and the results were adequately documented. The releases were determined to be within the concentrations specified in Appendix B to 10 CFR Part 20, Annual Limits on intake (ALIs) and Derived Air Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage, and TS limits. To demonstrate compliance with the annual dose constraints of 10 CFR 20.1101(d), the licensee used COMPLY v1.7, an Environmental Protection Agency computer code. The highest calculated dose that could be received by a member of the public as a result of gaseous emissions from reactor operations was determined to be 0.09 millirem per year (mr/yr) for the period from July 2017 through June 2018. These doses were well below the 10 mr/yr limit stipulated in 10 CFR 20.1101(d).

Environmental gamma radiation monitoring was conducted using TLDs in accordance with the applicable procedures. The data indicated that there were no radiation doses in uncontrolled areas from operation of the reactor that would result in a member of the public exceeding the limits in Subpart D, Radiation Dose Limits for Individual Members of the Public, to 10 CFR Part 20.

c. Conclusion Surveys were being completed and documented acceptably. Postings met regulatory requirements. Personnel dosimetry was being worn as required and doses were within regulatory limits. Radiation monitoring equipment was being maintained and calibrated as required. Radiation protection training was being provided to facility personnel. Calculations of effluents released from the facility satisfied license and regulatory requirements and releases were within the specified regulatory limits.

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

To verify compliance with 10 CFR 50.59, Changes, tests and experiments, and TS requirements for design changes, the inspector reviewed selected aspects of the licensees program, including:

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• Appendix A to Renewed Facility Operating License No. R-75, Technical Specifications and Bases for The Ohio State University Pool-Type Nuclear Reactor, Columbus, Ohio, Docket No. 50-150, dated June 2008.

• The Ohio State University Research Reactor Annual Report for FY 2017/2018, dated September 2018.

• Select procedures, The OSU NRL Operating Procedures

• Select records, OSURR Facility Modifications, Numbered 76-81, from time period dated 2017-2018

• Select records, completed AP-14 Attachment A, OSURR Modification Request

• Select records, completed AP-16 Attachment A, 10 CFR 50.59 Screening Form b. Observations and Findings The inspector reviewed OSURR Modification Request forms, the associated 10 CFR 50.59 screening, and the corresponding design change packages concerning the latest facility changes since the last inspection in this area. From these reviews, the inspector determined that the facility design change evaluations contained adequate supporting documentation and information.

Additionally, the inspector found that the ROC reviewed proposed changes in accordance with the requirement in TS 6.2.3.(1).

c. Conclusion Changes to the facility were being evaluated using the 10 CFR 50.59 criteria and were reviewed and approved by the ROC as required.

5. Committees, Audits and Review a. Inspection Scope (IP 69001)

To verify compliance with the TS requirements for review and audit, the inspector reviewed selected aspects of the licensees program, including:

• Appendix A to Renewed Facility Operating License No. R-75, Technical Specifications and Bases for The Ohio State University Pool-Type Nuclear Reactor, Columbus, Ohio, Docket No. 50-150, dated June 2008.

• The Ohio State University Research Reactor Annual Report for FY 2017/2018, dated September 2018.

• Reactor Operations Committee Meeting Agenda and Minutes, dated March 21, 2017, July 25, 2017, and July 27, 2018

• Audit of the NRL Operations for calendar year 2016 and calendar year 2017, dated December 21, 2016 and December 18, 2017 respectively

• Letter from D. Williams to A. Kauffman regarding membership of the Reactor Operations Committee, dated February 28, 2017

• AP-08, NRL Audit, Revision 6, January 12, 2017

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b. Observations and Findings The composition of the ROC and the meeting frequency satisfied the requirements of TS 6.2.1, Composition and Qualifications of the Reactor Operations Committee, and TS 6.2.2, Reactor Operations Committee Meetings. The minutes of these meetings demonstrated that the ROC provided the review and conducted the audits required by the TS 6.2.3, Review Function, and TS 6.2.4, Audit Function. Issues brought up by the ROC were resolved in an appropriate time frame and were noted in ROC meeting minutes. The ROC provided adequate oversight and direction for the safe operation of the facility.

c. Conclusion Review, audit, and oversight functions required by the TSs were acceptably completed by the ROC.

6. Transportation a. Inspection Scope (IP 86740)

To verify compliance with the regulations in 10 CFR Part 71, Packaging and Transportation of Radioactive Material, 49 CFR, Transportation, and procedural requirements for transferring or shipping licensed radioactive material, the inspector reviewed the following:

• Select records, completed RS-11 Attachment A, Shipping Paper, from the time period 2017-2018

• Select records, completed RS-08 Attachment B, Shipping Smear Survey Form, from the time period 2017-2018

• Select records, Hazmat Worker Training Certification

• Select records, copies of radioactive materials licenses or permits for purposes of verification prior to shipments b. Observations and Findings Through records review and discussions with licensee personnel, the inspector determined that the licensee had shipped various types of radioactive material since the last previous inspection in this area. The records indicated that the radioisotope types and quantities were calculated and dose rates measured as required. The inspector determined that the licensee maintained copies of the recipients license to possess radioactive material as required and that the licenses were verified to be current prior to initiating a shipment. The inspector noted that staff members had received the required training and were certified for shipping radioactive material by the OSU EH&S Radiation Safety group. All radioactive material shipment records reviewed by the inspector had been completed in accordance with Department of Transportation and NRC regulatory requirements.

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c. Conclusion Radioactive material was shipped in accordance with the applicable regulations and licensee procedures.

7. Exit Interview The inspection scope and results were summarized on November 29, 2018, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel Director, Nuclear Reactor Laboratory A. Kauffman Associate Director, Nuclear Reactor Laboratory and SRO K. Herminghuysen SRO S. White SRO Other Personnel D. Konate RSO, Facilities Operation and Development, EH&S W. Benedetti Facilities Operation and Development, EH&S L. Everman Facilities Operation and Development, EH&S INSPECTION PROCEDURES USED IP 69001 Class II Non-Power Reactors IP 86740 Transportation ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed IFI 50-150/2016-201-01 Follow up on the measurement of the exhaust fan rate required in TS 3.5, Specification (1).

Attachment

LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable AP Administrative Procedure EH&S Office of Environmental Health and Safety FY Fiscal Year IP Inspection Procedure kW Kilowatt mr/yr millirem per year NRC U.S. Nuclear Regulatory Commission NRL Nuclear Reactor Laboratory OSU Ohio State University OSURR Ohio State University Research Reactor RS Radiation Safety Procedure ROC Reactor Operations Committee SRO Senior Reactor Operator TLD Thermoluminescent Dosimetry-2-