ML12208A034

IR 05000607-12-203 on July 9-11, 2012 at the University of California-Davis - NRC Routine Inspection Report No. 50-607/2012-203 and Notice of Violation

ML12208A034
Person / Time
Site:	University of California-Davis
Issue date:	08/06/2012
From:	Mary Muessle Division of Policy and Rulemaking
To:	Klein B McClellan Nuclear Research Center
Bassett C
References
IR-12-203
Download: ML12208A034 (24)

See also: IR 05000607/2012203

Text

August 6, 2012

Dr. Barry M. Klein, Reactor Director

5335 Price Avenue, Bldg. 258

McClellan AFB, CA 95652-2504

SUBJECT: UNIVERSITY OF CALIFORNIA-DAVIS - NRC ROUTINE INSPECTION

REPORT NO. 50-607/2012-203 AND NOTICE OF VIOLATION

Dear Dr. Klein:

From July 9 to 11, 2012, the U.S. Nuclear Regulatory Commission (NRC or the Commission)

conducted an inspection at your University of California-Davis/McClellan Nuclear Research

Center. The enclosed report documents the inspection results, which were discussed on

July 12, 2012, with members of your staff, including Walter Steingass, Associate Director for

Reactor Operations, and David Reap, Radiation Safety Officer.

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 activities, and interviewed

personnel.

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

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

NRC Enforcement Policy included on the NRCs Web site at www.nrc.gov; select What We Do,

Enforcement, then Enforcement Policy. The violation is cited in the enclosed Notice of

Violation (Notice) and the circumstances surrounding it are described in detail in the subject

inspection report. The violation is being cited in the Notice because it constitutes a failure to

meet regulatory requirements that has more than minor safety significance and the licensee

failed to identify the violation.

You are required to respond to this letter within 30 days and should follow the instructions

specified in the enclosed Notice when preparing your response. The NRC will use your

response in part, to determine whether further enforcement action is necessary to ensure

compliance with regulatory requirements.

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

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

B. Klein -2-

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

(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Mary Muessle, Deputy Director

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

Docket No. 50-607

License No. R-130

Enclosures:

1. Notice of Violation

2. NRC Inspection Report No. 50-607/2012-203

cc: w/encls: See next page

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

cc:

Mr. David Reap, Radiation Safety Officer

5335 Price Avenue, Bldg. 258

McClellan AFB, CA 95652-2504

Mr. Walter Steingass, Reactor Supervisor

5335 Price Avenue, Bldg. 258

McClellan AFB, CA 95652-2504

California Energy Commission

1516 Ninth Street, MS-34

Sacramento, CA 95814

Radiological Health Branch

P.O. Box 997414, MS 7610

Sacramento, CA 95899-7414

Test, Research, and Training

Reactor Newsletter

University of Florida

202 Nuclear Sciences Center

Gainesville, FL 32611

B. Klein -2-

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

(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely,

/RA/

Mary Muessle, Deputy Director

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

Docket No. 50-607

License No. R-130

Enclosures:

1. Notice of Violation

2. NRC Inspection Report No. 50-607/2012-203

cc: w/encls: See next page

DISTRIBUTION:

PUBLIC RidsNrrDprPrta Resource RidsNrrDprPrtb Resource PROB r/f

AAdams, NRR MCompton (Ltr only O5-A4) MNorris (MS T3B46M) GLappert, NRR

CBassett, NRR

ACCESSION NO.: ML12208A034 *concurrence via e-mail TEMPLATE #: NRC-002

OFFICE PROB:RI * PRPB:LA PROB:BC DPR:DD

NAME CBassett GLappert GBowman MMuessle

DATE 7/19/2012 7/26/2012 8/6/12 8/6/12

OFFICIAL RECORD COPY

NOTICE OF VIOLATION

University of California-Davis Docket No. 50-607

McClellan Nuclear Research Center License No. R-130

During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted July 9-11, 2012, a

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

the violation is listed below:

Title 10 of the Code of Federal Regulations (10 CFR) Section 19.13(b) states that each licensee

shall make dose information available to workers as shown in records maintained by the

licensee under the provisions of 10 CFR 20.2106. The licensee shall provide an annual report

to each individual monitored under 10 CFR 20.1502 of the dose received in that monitoring year

if: (1) the individuals occupational dose exceeds 1 millisievert (mSv) (100 millirem (mrem)) total

effective dose equivalent or 1mSv (100 mrem) to any individual organ or tissue; or (2) the

individual requests his or her annual dose report.

10 CFR 20.1502 states that each licensee shall monitor exposures to radiation and radioactive

material at levels sufficient to demonstrate compliance with the occupational dose limits of this

part. As a minimum - (a) each licensee shall monitor occupational exposure to radiation from

licensed and unlicensed radiation sources under the control of the licensee and shall supply and

require the use of individual monitoring devices by - (1) adults likely to receive in 1 year from

sources external to the body, a dose in excess of 10 percent of the limits of 20.1201(a), (2)

minors . . ., (3) declared pregnant women . . ., and (4) individuals entering a high or very high

radiation area.

Contrary to the above requirements, the licensee did not provide an annual report to each

individual monitored under 10 CFR 20.1502 for 3 years. Specifically, three different staff

personnel, whose exposures to radiation and radioactive material were monitored in accordance

with Subparagraphs (1) and (4) of Paragraph (a) of 10 CFR 20.1502 and who received

exposures exceeding 100 mrem TEDE and/or 100 mrem to an individual organ or tissue, did not

receive an annual report containing their dose information for exposures received in 2009, 2010,

or 2011.

This has been determined to be a Severity Level IV violation (Section 6.7).

Pursuant to the provisions of 10 CFR 2.201, the University of California-Davis is hereby required

to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555-0001 with a copy to the responsible

inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include:

(1) the reason for the violation, or, if contested, the basis for disputing the violation or severity

level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective

steps that will be taken to avoid further violations, and (4) the date when full compliance will be

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

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

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

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

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

be given to extending the response time.

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

with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory

Commission, Washington, D.C. 20555-0001.

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

Public Document Room or from the Publicly Available Records component of the NRC=s

Agencywide Documents Access and Management System (ADAMS), to the extent possible, it

should not include any personal privacy, proprietary, or safeguards information so that it can be

made available to the public without redaction. ADAMS is accessible from the NRC Web site at

(the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html. If personal

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

provide a bracketed copy of your response that identifies the information that should be

protected and a redacted copy of your response that deletes such information. If you request

withholding of such material, you must specifically identify the portions of your response that

you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal

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

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

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

in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days.

Dated this 6th day of August, 2012

U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

Docket No: 50-607

Report No: 50-607/2012-203

Licensee: University of California-Davis

Facility: McClellan Nuclear Research Center

Location: McClellan Park

Sacramento, California

Dates: July 9-11, 2012

Inspector: Craig Bassett

Approved by: Gregory T. Bowman, Chief

Research and Test Reactors Oversight Branch

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

EXECUTIVE SUMMARY

University of California-Davis

McClellan Nuclear Research Center

Report No: 50-607/2012-203

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

aspects of the University of California-Davis (the licensees) Class I research and test reactor

safety program including: 1) organizational structure and staffing; 2) review, audit, and design

change functions; 3) procedures; 4) radiation protection; 5) environmental monitoring;

6) transportation of radioactive materials; and, 7) material control and accounting 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.

Organizational Structure and Functions

The organizational structure and staffing were consistent with the requirements specified

in Technical Specifications Section 6.

Review and Audit and Design Change Functions

The Nuclear Safety Committee was meeting at the required frequency, reviewing the

topics outlined in the Technical Specifications, and conducting audits of facility programs

as required.

The design change program, including review, evaluation, and documentation of

changes to the facility, satisfied NRC requirements.

Procedures

The procedure review, revision, control, and implementation program satisfied Technical

Specifications requirements.

Radiation Protection Program

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 Parts 19 and 20.

Personnel dosimetry was being worn as required and doses were well 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.

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One severity level IV violation was noted for failure to provide McClellan Nuclear

Research Center personnel with an NRC Form 5 for the past 3 years as required by

10 CFR 19.13.

Environmental Monitoring

Effluent monitoring satisfied license and regulatory requirements and releases were

within the specified Technical Specification and regulatory limits.

Transportation of Radioactive Materials

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

Material Control and Accounting

Special nuclear material was acceptably controlled and tracked as required by 10 CFR

Parts 70 and 74.

REPORT DETAILS

Summary of Plant Status

The University of California-Davis (UCD, the licensees) two megawatt (MW) TRIGA reactor

continued to be operated in support of neutron radiography, medical isotope production, neutron

tomography, and experimental sample irradiation. During the inspection, the reactor was

operated up to eight hours per day at a nominal power level of one MW to support neutron

radiography and sample irradiation.

1. Organization and Staffing

a. Inspection Scope (Inspection Procedure [IP] 69006)

The inspector reviewed the following regarding the University of

California-Davis/McClellan Nuclear Research Center (UCD/MNRC) organization,

staffing, and responsibilities to ensure that the requirements of Technical

Specification (TS) Section 6.1, Revision (Rev.) 13, dated March 28, 2003, were

being met:

• Management responsibilities

• Qualifications of facility personnel

• Current UCD/MNRC organizational structure and staffing

• Staffing requirements for safe operation of the research reactor facility

• Selected UCD/MNRC Operations Logs and UCD/MNRC Startup

Checklists for 2012 documenting shift staffing

• University of California, Davis/McClellan Nuclear Radiation Center 2010

Annual Report, submitted to the NRC on June 28, 2011

• University of California, Davis/McClellan Nuclear Research Center 2011

Annual Report, submitted to the NRC on June 25, 2012

• Facility Procedure UCD/MNRC-0004-DOC-13, Technical Specifications

for the McClellan Nuclear Research Center (MNRC) Reactor Facility,

Rev. 13, approval date March 28, 2003

• Facility Procedure UCD/MNRC-0045-DOC-01, Quality Assurance

Program for McClellan Nuclear Research Center (MNRC), Rev. 1,

approval date November 22, 1999

• American Nuclear Society Standard 15.4-1988, Selection and Training of

Personnel for Research Reactors, standard approval dated June 9, 1988

b. Observations and Findings

The organization at the UCD/MNRC was as required by TS Section 6. The Vice

Chancellor was the one designated as the licensee for the university. The

UCD/MNRC facility was under the direct control of the Reactor Director who

reported to and was accountable to the Vice Chancellor for the safe operation

and maintenance of the facility. Individuals at the facility in management

positions such as the Reactor Supervisor and the Radiation Safety Officer

reported to the Reactor Director and were responsible for implementing

UCD/MNRC policies, for operation of the facility, for safeguarding facility

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personnel and the public from undue radiation exposure, and for adhering to the

operating license and technical specifications.

As noted in NRC Inspection Report No. 50-607/2008-203, the licensees

organizational chart for the UCD/MNRC as shown in the TS indicated that the

chain of command included an Operations Manager who was to be in charge of

reactor operations. The chart also indicated a staff position of Health Physics

(HP) Supervisor. These two positions were no longer part of the facility

organizational structure. During a previous inspection, the inspector noted that

the licensee had initiated, reviewed, and approved a TS change to reflect the

current structure. The licensee indicated that the change had been submitted to

the NRC on July 15, 2011 and was thus awaiting NRC review.

The organization and staffing at the facility, required for reactor operation, were

as specified in the TS. Qualifications of the staff members met program

requirements. Review of records demonstrated that management responsibilities

were discharged as required by applicable procedures. It was noted that no staff

changes had been made since the last NRC inspection which occurred in

January 2012 (refer to NRC Inspection Report No. 50-607/2012-201).

c. Conclusion

With the recent TS change submitted to the NRC, the licensees current

organization and staffing were in compliance with the requirements specified in

the TS Section 6.

2. 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 reviewed and approved as required by TS Section 6.2, the

inspector reviewed selected aspects of:

• 2010 Annual Audit of the MNRC completed November 4, 2010

• 2011 Annual Audit of the MNRC completed December 9, 2011

• Nuclear Safety Committee meeting minutes for June 2011 through the

present

• UCD/MNRC Facility Modification Notebook containing the Facility

Modification Log forms

• Selected Facility Modification Installation Authorization Forms and

associated Facility Modification Checklist forms processed during 2011

and to date in 2012

• University of California, Davis/McClellan Nuclear Radiation Center 2010

Annual Report, submitted to the NRC on June 28, 2011

• University of California, Davis/McClellan Nuclear Research Center 2011

Annual Report, submitted to the NRC on June 25, 2012

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

Procedure, Rev. 4, approval dated January 8, 2008

• Facility Procedure UCD/MNRC-0045-DOC-01, Quality Assurance

Program for McClellan Nuclear Research Center (MNRC), Rev. 1,

approval dated November 22, 1999

b. Observations and Findings

(1) Review and Audit Functions

Composition of the Nuclear Safety Committee (NSC) and qualifications of

NSC 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 the reviews

and oversight specified in TS Section 6.2.3. Through records review the

inspector determined that reviews were conducted by the NSC or

designated representatives. Topics of those reviews were as required by

the TS and provided sufficient guidance, direction, and oversight to

ensure acceptable use of the reactor.

The inspector reviewed the two most recent annual audits conducted at

the facility. The audits were comprehensive and reviewed the activities

specified in TS Section 6.2.4, including various aspects of the reactor

facility operations and associated programs. No discrepancies were

found but several recommendations were made as a result of the audits.

(2) Design Change Functions

The regulatory requirements stipulated in Title 10 of the Code of Federal

Regulations (10 CFR) Section 50.59 Changes, tests, and experiments,

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

local conditions.

The inspector reviewed entries in the Facility Modification Log Notebook

for the period from 2011 and to date in 2012. The Notebook entries

showed that no modifications dealing with the radiation protection system

had been proposed since the last inspection.

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c. Conclusion

The NSC was meeting as required and reviewing the topics outlined in the TS.

Audits of various reactor operations and programs were being conducted as

required. The design change program satisfied NRC requirements.

3. Procedures

a. Inspection Scope (IP 69008)

To verify compliance with TS Section 6.4, the inspector reviewed selected

portions of the following:

• Selected Document Review forms completed by staff members

• UCD/MNRC Controlled Document Review and Approval Reference List

• MNRC Document List listing all the licensees current procedures and

the date each was last reviewed

• Various memoranda from the Reactor Supervisor to the staff indicating

document review assignments and responsibilities

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

Rev. 9, approval dated February 16, 2007

• Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation

Protection Procedures, Rev. 18, approval dated January 29, 2008

• Various of the Addenda located in Facility Procedure

UCD/MNRC-0042-DOC-9, MNRC Health Physics Instrumentation

Calibration and Test Procedures, latest reveiws of the addenda were

completed on January 13, 2011

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 stipulated that the UCD/MNRC staff perform a biennial review of each

active document to assure that it was current. The inspector noted that

Operations and Health Physics procedures were typically being reviewed

annually by the licensee while maintenance and other procedures were reviewed

biennially. Changes to the procedures required the approval of the UCD/MNRC

Director and all changes were required to be documented.

The inspector determined that the UCD/MNRC procedures were generally being

reviewed as required, that procedures were approved by the Director, and that

changes were documented as required as well. It was also noted that three of

four procedures that were assigned to be reviewed by the Experiment

Coordinator had not been reviewed within the two year time frame specified by

procedure. These procedures were: 1) Facility Procedure UCD/MNRC-0081-

DOC-00, Experiment Coordination Checklist, last review dated January 6,

2010, 2) Facility Maintenance Procedure UCD/MNRC-0058-OMM-00, Neutron

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Irradiator, last review dated December 18, 2009, and 3) Facility Maintenance

Procedure UCD/MNRC-00-OMM-01, Central Facility, last review dated

December 18, 2009. The licensee indicated that the former Experiment

Coordinator had not reviewed the procedures in a timely manner and the new

person hired for that position had not had sufficient time or experience to date to

conduct the review. The licensee was informed that this issue would be followed

by the NRC as an Inspector Follow-up Item (IFI) and would be reviewed during a

future inspection (IFI 50-607/2012-203-01)

c. Conclusion

The current procedure review, revision, control, and implementation program

satisfied TS requirements.

4. Radiation Protection

a. Inspection Scope (IP 69012)

The inspector reviewed selected portions of the following regarding the licensee's

radiation protection program to ensure that the requirements of 10 CFR Part 20

and TS Sections 4.7 and 6.4.2 were being met:

• Calibration of selected radiation monitoring instruments

• List documenting all MNRC personnel who were authorized to handle

radioactive material dated July 10, 2012

• The Self Inspection Checklist completed by the Radiation Safety Officer

(RSO) for 2010 and 2011

• Personal monthly dosimetry results for 2010, 2011, and through May

2012

• 2010 MNRC Radiation Safety Program Review Report, completed by

members of the NSC and dated December 6, 2010

• 2011 MNRC Radiation Safety Program Review Report, completed by

members of the NSC and dated November 28, 2011

• 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 two years

• Licensee Radiological Investigation Reports for 2011 and 2012 -

Numbers 11-01, 12-01, 12-02, and 12-03, as documented in the Special

Surveys Notebook

• University of California, Davis/McClellan Nuclear Radiation Center 2010

Annual Report, submitted to the NRC on June 28, 2011

• University of California, Davis/McClellan Nuclear Research Center 2011

Annual Report, submitted to the NRC on June 25, 2012

• Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation

Protection Procedures, Rev. 18, approval dated January 29, 2008

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• Facility Procedure UCD/MNRC-0042-DOC-9, MNRC Health Physics

Instrumentation Calibration and Test Procedures, which included:

Addendum No. 01, Beta Dose Rate Calibration Procedure,

Rev. 6, dated August 22, 2007

Addendum No. 29, Ludlum Model 177 Calibration Procedure,

Rev. 3, dated February 22, 1999

Addendum No. 30, Ludlum Model 177-54 Calibration Procedure,

Rev. 3, dated February 22, 1999

Addendum No. 31, Ludlum Model 3 Calibration Procedure,

Rev. 4, dated September 18, 2007

Addendum No. 34, RAM Calibration Procedure, Rev. 4, dated

June 8, 2009

Safety Analysis Report, Revision 4, dated December 1999, Chapter 11,

Radiation Protection and Waste Management Program, Revision 2,

dated April 3, 1998

• American National Standard ANSI/ANS-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, licensee personnel were interviewed

and radiological signs and postings were observed.

b. Observations and Findings

(1) Surveys

Daily checklists and weekly, quarterly, and special contamination and

radiation surveys, outlined in the licensees UCD/MNRC Radiation

Protection Procedures, were being completed by the RSO or other

qualified staff members as required. Any contamination detected in

concentrations above established action levels was noted and the

affected area 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 could check and be

knowledgeable of the radiological conditions that existed in those areas.

During the inspection the inspector accompanied a licensee

representative to observe the completion of a Weekly Radiation and

Contamination Survey. Areas surveyed at the facility included the

Equipment Room, the Reactor Room, and associated support areas. No

anomalies were noted.

(2) Postings and Notices

Copies of current notices to workers were posted in appropriate areas in

the facility. The required radiological signs were posted at the entrances

to controlled areas. Other postings also showed the industrial hygiene

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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,

and was posted on a bulletin board near the main entrance to the facility

where visitors are required to sign the Visitors Log.

(3) Dosimetry

Personnel were observed to be properly wearing extremity and whole

body dosimetry in the controlled areas. The dosimeters being used were

4-chip thermoluminescent dosimeters (TLDs) processed monthly by a

NVLAP certified vendor (Mirion Technologies (formerly Global Dosimetry

Solutions)). The TLDs were used for whole body monitoring and TLD

finger rings were used for extremity monitoring.

An examination of the TLD results indicating radiological exposures at the

facility for the past two years showed that the highest occupational doses,

as well as doses to the public, were within 10 CFR Part 20 limits. The

highest annual whole body exposure received by a single licensee

employee for 2010 was 169 millirem deep dose equivalent (DDE). The

highest annual extremity exposure for 2010 was 562 millirem shallow

dose equivalent (SDE) and the highest skin or other shallow dose was

171 mr SDE. The highest annual whole body exposure received by a

single person for 2011 was 50 millirem DDE. The highest annual

extremity exposure for 2011 was 106 millirem SDE and the highest skin

or other shallow dose was 96 mr SDE. Through May 2012, the highest

individual whole body exposure that had been received has been 35

millirem DDE; the highest extremity exposure has been 99 millirem SDE;

and, the highest skin or other shallow dose was 142 mr SDE.

(4) 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 the instruments were sent off site to be

calibrated by a contractor. The calibrations were tracked and

documented as required. The inspector confirmed that the frequencies of

the calibrations satisfied the requirements established in the

TS Section 4.7 and 10 CFR 20.1501(b). All instruments checked by the

inspector had a current calibration sticker attached.

(5) Radiation Protection Program

The radiation protection program was described and controlled 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 the RSO on July 6, 2011, and

June 18, 2012. These were documented in the form of a Self

Identification Checklist. Separate audits of the program were conducted

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by members of the NSC on December 6, 2010, and November 28, 2011.

These audits satisfied the periodic program review required by 10 CFR

20.1101(c). No problems were noted by the NSC audit team 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 work to be performed

and/or what controlled area(s) the person would be required to enter.

Plan A was training provided for visitors to the facility. Plan B was

training provided to staff personnel who were also considered Radiation

Workers. Plan C was initial training for reactor operators hired at the

facility. Subsequent training on this material was provided to operators

during their requalification training. Plan D was given annually to all

facility faculty and staff. Plan E was for ancillary personnel such as

custodial service workers.

The inspector reviewed the training given to various personnel. Three

individuals had received Plan B training, as well as job specific training,

and were to be involved in the Iodine-125 production program. One

individual who was hired as the facility Electronic Engineer had received

Plan C training. He was also participating in the Reactor Operator

training program at the facility. The inspector noted that training was

being completed as required and it appeared to be adequate.

(7) Radiation Work Permit Program

The inspector reviewed the Radiation Work Permits (RWPs) that had

been written, used, and closed out during 2011 and those issued to date

in 2012. It was noted that no Special RWPs had been issued recently.

Of those RWPs that had been written for 2011 and 2012, the inspector

determined that the controls, precautions, and instructions specified in the

RWPs appeared to be appropriate and were being followed. It was also

noted that the RWPs had been reviewed by the RSO as required.

(8) NRC Form 5

10 CFR 19.13(b) states that each licensee shall make dose information

available to workers as shown in records maintained by the licensee

under the provisions of 10 CFR 20.2106. The licensee shall provide an

annual report to each individual monitored under 10 CFR 20.1502 of the

dose received in that monitoring year if: (1) The individuals occupational

dose exceeds 1 mSv (100 mrem) TEDE or 1mSv (100 mrem) to any

individual organ or tissue; or (2) The individual requests his or her annual

dose report.

-9-

10 CFR 20.1502 states that each licensee shall monitor exposures to

radiation and radioactive material at levels sufficient to demonstrate

compliance with the occupational dose limits of this part. As a minimum -

(a) Each licensee shall monitor occupational exposure to radiation from

licensed and unlicensed radiation sources under the control of the

licensee and shall supply and require the use of individual monitoring

devices by - (1) Adults likely to receive in 1 year from sources external to

the body, a dose in excess of 10 percent of the limits of 20.1201(a),

(2) Minors . . ., (3) Declared pregnant women . . ., and (4) Individuals

entering a high or very high radiation area.

In Paragraph 4 of the Privacy Act Statement portion of NRC Form 5, it

states that the licensee must complete NRC Form 5 on each individual for

whom personal monitoring is required under 10 CFR 20.1502.

As noted above, during the inspection of the MNRC Radiation Protection

Program, the inspector reviewed the dosimetry records of those staff

members working at the facility. It was noted that in 2009, one individual

had received a dose to the skin, SDE, of 168 mrem. In 2010, two

individuals received a whole body dose, TEDE, greater than 100 mrem.

One person received a deep dose equivalent (DDE) of 114 mrem and the

other received a DDE of 169 mrem. In 2011, one individual received a

dose to the skin of 106 mrem. Because these doses exceeded the limit

established that required an NRC Form 5 to be issued, the inspector

asked to review the NRC Form 5 for these individuals. MNRC personnel

indicated that the last annual report of dose (NRC Form 5) that anyone

had received was the one for the year 2008.

The inspector was informed that the UC Davis Environmental Health and

Safety (EH&S) Department handled the dosimetry for the facility and

made arrangements (maintained a contract) with a vendor to issue and

process the dosimetry. The vendor would be the entity that would track

exposures and issue the NRC Form 5 information through the campus

EH&S Department. Therefore, the EH&S Department would be the group

responsible for requesting and then issuing the proper forms to MNRC

personnel. Monthly dosimetry results were generally forwarded from the

campus EH&S office to the MNRC RSO. However, the campus EH&S

office had decided not to request NRC Form 5 for the individuals at the

MNRC as a cost cutting measure. The licensee was informed that failure

to provide facility personnel with NRC Form 5 information for the past

three years was a violation (VIO) of 10 CFR 19.13 (VIO 50-607/

2012-203-02).

(9) 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

was noted that facility radioactive material storage areas were properly

- 10 -

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 As Low As

Reasonably Achievable (ALARA) Programs, as implemented by the licensee,

generally satisfied regulatory requirements because: 1) surveys were completed

and documented acceptably to permit evaluation of the radiation hazards

present; 2) postings at the facility 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 Program was

acceptable and was being reviewed annually as required; and, 6) acceptable

radiation protection training program was being provided to facility personnel.

One apparent violation was noted for failure to provide various MNRC personnel

with an NRC Form 5 for the past three years as required by 10 CFR 19.13.

5. Effluent and Environmental Monitoring

a. Inspection Scope (IP 69004)

The inspector reviewed the following to verify compliance with the requirements

of 10 CFR Part 20 and TS Section 6.4.2(d):

• Solid Radwaste Logbook

• Quarterly Environmental TLD Reports for 2010, 2011, and to date in 2012

• Radioactive Material Discharged Into Sanitary Sewer form maintained

and updated for 2010, 2011, and to date in 2012

• University of California, Davis/McClellan Nuclear Radiation Center 2010

Annual Report, submitted to the NRC on June 28, 2011

• University of California, Davis/McClellan Nuclear Research Center 2011

Annual Report, submitted to the NRC on June 25, 2012

• Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation

Protection Procedures, Rev. 18, approval dated January 29, 2008

• Facility Procedure UCD/MNRC-0042-DOC-9, MNRC Health Physics

Instrumentation Calibration and Test Procedures, which included:

Addendum No. 08, Stack CAM Alarm Setpoint Procedure,

Rev. 7, dated May 16, 2007

Addendum No. 12, Weekly Stack CAM Source Check

Procedure, Rev. 4, dated October 27, 2005

Addendum No. 16, Canberra 2404 Calibration Procedure,

Rev. 7, dated May 14, 2008

Addendum No. 48, Stack CAM Calibration Procedure, Rev. 2,

dated May 10, 2007

Addendum No. 49, Reactor CAM Calibration Procedure, Rev. 1,

dated May 16, 2007

- 11 -

Addendum No. 50, Bay CAM Calibration Procedure, Rev. 1,

dated May 21, 2007

b. Observations and Findings

The inspector determined that gaseous releases continued to be monitored as

required, were acceptably analyzed, and were documented in the annual

operating reports. To ensure that airborne concentrations of gaseous releases

were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table

2, below the dose constraint specified in 10 CFR 20.1101(d) of 10 millirem per

year, and within TS limits, the licensee completed a calculation of the dose to

members of the public as the result of reactor operations. This calculation was

performed using the Environmental Protection Agency (EPA) computer code,

CAP88-PC, Version 3.0. The results indicated an annual dose to the public of

1.33E-2 millirem for 2010 and 1.06E-2 millirem for 2011.

There were no liquid releases from the facility during 2010, 2011, and to date in

2012. It was also noted that no solid radioactive waste had been

released/shipped from the facility during 2010, 2011, and to date in 2012.

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 TLDs in accordance with the

applicable procedures as well. The review of data indicated that there were no

measurable doses above any regulatory limits. The highest unrestricted area

dose measured by an environmental TLD was 23 millirem for 2010 and

17 millirem for 2011.

c. Conclusion

Effluent monitoring satisfied license and regulatory requirements and releases

were within the specified TS requirements and regulatory limits.

6. Transportation

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

• Selected records of various types of radioactive material shipments

including completed radiological survey forms

• Selected training records for staff personnel authorized to ship hazardous

material in accordance with the regulations specified by the Department

of Transportation (DOT)

- 12 -

• Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation

Protection Procedures, Rev. 18, approval dated January 29, 2008

• Appendix A, Limited Quantity of Class 7 (Radioactive) Materials

Checklist, of Section 21 of Facility Procedure UCD/MNRC-0029-DOC-18

• NUREG-1660/RAMREG-002, U.S.-Specific Schedules of Requirements

for Transportation of Specified Types of Radioactive Material

Consignments, published November 1998

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 previous inspection in this area. The records indicated that the

radioisotope types and quantities were calculated and dose rates were generally

measured correctly. All 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 as required and that the licenses were

verified to be current prior to initiating a shipment. The inspector also 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 DOT, International Air

Transport Association (IATA), and International Civil Aviation Organization

(ICAO) requirements within the past three years.

c. Conclusion

Radioactive material was being shipped in accordance with the applicable

regulations.

7. Material Control and Accounting

a. Inspection Scope (IP 85102)

To verify compliance with Title 10 of the Code of Federal Regulations

(10 CFR) Parts 70 and 74 and TS Sections 5.3 and 5.4, the inspector reviewed:

• UCD/MNRC Present Element Location forms

• SNM Physical Inventory forms for 2011 through 2012

• Control of Special Nuclear Material (SNM) storage areas

• MNRC Core Configuration map dated December 20, 2010

• Fuel Handling Checklists for fuel handling in December 2011

• UCD/MNRC Fuel Transfer Forms for 2011 (none had been completed to

date in 2012)

• Core and Storage Boards located in the Control Room and in the Reactor

Room

- 13 -

• Selected entries in the Fuel Movement Notebook documenting the date

each element was received, fuel element movement, and current location

• Nuclear Material Transaction Reports (DOE/NRC Form 741) for the time

period from October 2010 through April 2012

• Material Balance Reports (DOE/NRC Form 742) for the time period from

October 2010 through April 2012

• Physical Inventory Listing forms (DOE/NRC Form 742C) for the time

period from October 2010 through April 2012

• Facility Procedure UCD/MNRC-0011-OMM-5240-05, Fuel, Rev. 5,

approval dated April 19, 2001

• Facility Procedure UCD/MNRC-0019-OMM-5220-04, Fuel Handling

Tools, Rev. 4, approval dated January 12, 2009

b. Observations and Findings

Records indicated that the licensee accounted for all SNM maintained under the

R-130 license. SNM material status and transaction reports, documenting what

the licensee possessed and what happened to the material in 2010, 2011, and

2012, had been completed and submitted to the appropriate regulatory agencies

in a timely manner and as required by 10 CFR 74.13(a). Physical inventories

were conducted annually as required.

The inspector toured the facility and verified that the licensee was using and

storing SNM in the designated areas as required by 10 CFR 70.41(a). Through

tours and records review, the inspector verified that the total amount of SNM in

use or in storage at the facility was within the possession limits specified in the

license.

The inspector also observed and verified that fuel elements were being stored in

the appropriate and approved locations. Because of the operations schedule,

the inspector was unable to observe an inventory and verify the serial numbers of

any irradiated fuel elements from the core. Fuel element locations designated on

various forms were cross referenced with the latest Core and Storage Map and

with the Core and Storage Boards in the Control Room and the Reactor Room.

All entries matched and were correct. No problems were noted.

c. Conclusion

The licensee was acceptably controlling and tracking SNM as required by

10 CFR Parts 70 and 74.

8. Exit Interview

The inspection scope and results were summarized on July 11, 2012, with members of

licensee management. 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 by the inspector during

the inspection. No dissenting comments were received from the licensee.

PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel

H. Bollman Facility Manager and Senior Reactor Operator (SRO)

T. Essert Electronics Engineer and RO Trainee

H. Egbert Radiography Supervisor and SRO

M. Lerche Associate Director for Research/Education Coordination and Experiment

Coordinator

B. Liu Research Support Engineer

D. Reap Radiation Safety Officer, Security Officer, and SRO

W. Steingass Associate Director for Reactor Operations and Reactor Supervisor

R. Walker Radiographer/Mechanic

INSPECTION PROCEDURES USED

IP 69004: Class I Research and Test Reactor Effluent and Environmental

Monitoring

IP 69006: Class I Research and Test Reactor Organization, 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 85102: Material Control and Accounting

IP 86740: Inspection of Transportation Activities

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50-607/2012-201-01 IFI Follow-up on the licensees actions to ensure that three

procedures are reviewed and revised as needed as soon as

possible and appropriate.

50-607/2012-201-02 VIO Failure to provide various MNRC facility personnel with NRC Form

5 information for the past three years as required by

10 CFR 19.13.

Closed

None

-2-

PARTIAL LIST OF ACRONYMS USED

10 CFR Title 10 of the Code of Federal Regulations

ALARA As low as reasonably achievable

DDE Deep dose equivalent

DOT Department of Transportation

EPA Environmental Protection Agency

HP Health Physics

IFI Inspector Follow-up Item

IP Inspection procedure

mrem millirem

mSv millisievert

MNRC McClellan Nuclear Research Center

MW megawatt

NRC U.S. Nuclear Regulatory Commission

NSC Nuclear Safety Committee

PDR Public Document Room

Rev. Revision

RSO Radiation Safety Officer

SRO Senior Reactor Operator

RWP Radiation Work Permit

SDE Shallow dose equivalent

TEDE Total Effective Dose Equivalent

TLD Thermoluminescent dosimeter

TS Technical Specifications

UCD University of California-Davis

VIO Violation