ML022690754
| ML022690754 | |
| Person / Time | |
|---|---|
| Site: | University of California - Irvine |
| Issue date: | 10/01/2002 |
| From: | Beckner W NRC/NRR/DRIP/RORP |
| To: | Gottfredson S University of California - Irvine |
| References | |
| IR-02-001 | |
| Download: ML022690754 (22) | |
See also: IR 05000326/2002201
Text
October 1, 2002
Dr. S. Gottfredson
Executive Vice Chancellor
University of California, Irvine
Irvine, CA 92697-2025
SUBJECT: NRC INSPECTION REPORT NO. 50-326/2002-201 AND NOTICE OF VIOLATION
Dear Dr. Gottfredson:
This letter refers to the inspection conducted on September 16-19, 2002, at the University of
California, Irvine (UCI) Nuclear Reactor Facility. The enclosed report presents the results of
that inspection.
Areas examined during the inspection are identified in the report. Within these areas, the
inspection consisted of selective examinations of procedures and representative records,
interviews with personnel, and observations of activities in progress.
Based on the results of this inspection, the Nuclear Regulatory Commission (NRC) has
identified a violation of NRC requirements. The violation is cited in the enclosed Notice of
Violation (Notice). The circumstances surrounding it are described in detail in the subject
inspection report. The violation is of concern because it shows a weakness in the
transportation of radioactive material program.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response in
accordance with its policies to determine whether further enforcement action is necessary to
ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading
Room) http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning this inspection, please contact Craig Bassett at
(404) 562-4712.
Sincerely,
/RA by Terrence Reis Acting for/
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No. 50-326
License No. R-116
Enclosures: 1. Notice of Violation
2. NRC Inspection Report No. 50-326/2002-201
cc w/ enclosures: Please see next page
University of California at Irvine Docket No. 50-326
cc:
Dr. Richard Chamberlain, Chair
Department of Chemistry
University of California, Irvine
Irvine, CA 92697-2025
Mr. Steve Hsu
Radiological Health Branch
State Department of Health Services
P.O. Box 9442732
Sacramento, CA 94234-7320
Dr. George E. Miller
Department of Chemistry
516 Physical Sciences 1
University of California, Irvine
Irvine, CA 92697-2025
Test, Research, and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
October 1, 2002
Dr. S. Gottfredson
Executive Vice Chancellor
University of California, Irvine
Irvine, CA 92697-2025
SUBJECT: NRC INSPECTION REPORT NO. 50-326/2002-201 AND NOTICE OF VIOLATION
Dear Dr. Gottfredson:
This letter refers to the inspection conducted on September 16-19, 2002, at the University of
California, Irvine (UCI) Nuclear Reactor Facility. The enclosed report presents the results of
that inspection.
Areas examined during the inspection are identified in the report. Within these areas, the
inspection consisted of selective examinations of procedures and representative records,
interviews with personnel, and observations of activities in progress.
Based on the results of this inspection, the Nuclear Regulatory Commission (NRC) has
identified a violation of NRC requirements. The violation is cited in the enclosed Notice of
Violation (Notice). The circumstances surrounding it are described in detail in the subject
inspection report. The violation is of concern because it shows a weakness in the
transportation of radioactive material program.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response in
accordance with its policies to determine whether further enforcement action is necessary to
ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading
Room) http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning this inspection, please contact Craig Bassett at
(404) 562-4712. Sincerely,
/RA by Terrence Reis Acting for/
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No. 50-326
License No. R-116
Enclosures: 1. Notice of Violation
2. NRC Inspection Report No. 50-326/2002-201
cc w/enclosures: Please see next page
DISTRIBUTION:
PUBLIC RORP/R&TR r/f AAdams CBassett WBeckner
LBerg PDoyle TDragoun WEresian FGillespie
SHolmes DHughes EHylton PIsaac PMadden
MMendonca AVelazques-Lozada BDavis (Ltr only O5-A4)
NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML022690754 TEMPLATE #: NRR-106
OFFICE RORP:RI RORP:LA RORP:SC RORP:PD
NAME CBassett:rdr EHylton PMadden WBeckner
DATE 10/ 01 /2002 09/ 30 /2002 10/ 01 /2002 10/ 01 /2002
ENCLOSURE 1
NOTICE OF VIOLATION
University of California, Irvine (UCI) Docket No. 50-326
UCI Nuclear Reactor Facility License No. R-116
During an NRC inspection conducted on September 16-19, 2002, a violation of NRC
requirements was identified. In accordance with the "General Statement of Policy and
Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
1. Title 10 of the Code of Federal Regulations (CFR) Section 71.5(a) requires that a
licensee who delivers licensed material to a carrier for transport comply with the
applicable requirements of the regulations appropriate to the mode of transport of the
Department of Transportation (DOT) in 49 CFR Parts 171-189.
2. Section 171.2(a) of 49 CFR prohibits any person from offering hazardous material for
transportation unless, among other requirements, the hazardous material is properly
classified, described, packaged, marked, labeled, and in condition for shipment required
or authorized under the Hazardous Material Regulations (49 CFR 171-177).
Contrary to the above, various items of information and/or signatures were not present on some
of the licensees shipping papers, there was no documentation concerning radiation and
contamination levels on certain packages, and one package was labeled incorrectly as follows:
1. The shipping papers for shipments made on the following dates in 2001 did not list the
chemical or physical form of the radioactive material being shipped as required by
49 CFR 172.203(d)(3): January 18 and 19; February 1 and 14; March 2, 16, and 27;
April 24; May 3 and 22; June 14, 26, and 27; July 11; and August 23.
2. The shipping papers for shipments made on the following dates in 2001 (and on one
date in 2002 as indicated) did not list the name of each radionuclide and the activity
contained in each package of radioactive material being shipped as required by
49 CFR 172.203(d)(2) and (4): January 18 and 19; February 1 and 14; March 2, 16,
and 27; April 24; May 3 and 22; June 14, 26, and 27; July 11; August 23; and March 26,
2002.
3. The shipping papers for shipments made on the following dates in 2001 (and on one
date in 2002 as indicated) did not list the activity contained in each package of
radioactive material being shipped as required by 49 CFR 172.203(d)(4): January 10;
May 22 (a second shipment - different from the shipment mentioned in 2. above);
December 4; and June 25, 2002.
4. Documentation of shipments made on the following dates in 2001 did not indicate that
the contamination levels present on the external surfaces of the packages offered for
transport were below the acceptable levels indicated in 49 CFR 173.443: January 18;
February 1; March 27; April 24; May 3 and 22; June 14, 26, and 27; July 11; and
August 23.
-2-
5. The shipping papers for shipments made on the following dates in 2001 did not list the
Transport Index (TI) of the radioactive material being shipped as required by
49 CFR 172.203(d)(6): January 10; May 3 and 22; June 14; November 15; and
December 4.
6. The shipping papers for shipments made on the following dates were not signed or
certified by anyone to indicate or verify that the shipments were acceptable for shipment
as required by 49 CFR 172.204: January 19, 2001 and June 25, 2002.
7. The shipping papers for shipments made on the following dates in 2001 did not list an
Emergency Telephone number on the form as required by 49 CFR 172.202 and
172.604: July 12 and November 15.
8. Documentation of the shipment made on November 15, 2001, did not indicate that the
radiation levels at any point on the external surface of the package offered for transport
were within the acceptable levels indicated in 49 CFR 173.441.
9. The shipping papers for the shipment made on June 25, 2002, indicated that a Yellow II
label had been used for the shipment instead of a Yellow III label, which would have
been the correct label according to the TI listed as required by 49 CFR 172.403.
This is a Severity Level IV violation (Supplement V).
Pursuant to the provisions of 10 CFR 2.201, the University of California, Irvine, 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 with a copy to the
cognizant 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 for each violation: (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 a Demand for Information may be issued as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, 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 (PDR) or from the Publicly Available Records (PARS) component of the
NRCs 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
-3-
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 2.790(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 at Rockville, Maryland
this 1st day of October, 2002
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-326
License No: R-116
Report No: 50-326/2002-201
Licensee: The Regents of the University of California
Facility: UCI Nuclear Reactor Facility
Location: Department of Chemistry, UCI
Irvine, CA
Dates: September 16-19, 2002
Inspector: Craig Bassett
Approved by: William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
ENCLOSURE 2
EXECUTIVE SUMMARY
University of California, Irvine
UCI Nuclear Reactor Facility
NRC Inspection Report No. 50-326/2002-201
The primary focus of this routine, announced inspection was the onsite review of selected
activities at the UCI Nuclear Reactor Facility. The facility is a two hundred and fifty kilowatt
(250 kW) research reactor facility. The activities audited during this inspection included aspects
of the following: organizational structure and staffing, review and audit functions, radiation
protection program, environmental protection program, procedures, emergency preparedness
program, transportation of radioactive materials, security, and material control and accounting.
The licensees programs were found to be acceptably directed toward the protection of public
health and safety, and, with one exception, in compliance with NRC requirements.
Organizational Structure and Staffing
The operations organizational structure and responsibilities were consistent with
Technical Specification requirements, but, currently, two reactor operator positions are
vacant.
Shift staffing met the minimum requirements for current operations.
Review and Audit
The review and audit program was being conducted acceptably by the Reactor
Operations Committee.
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 10 CFR 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 monitoring equipment was being maintained and calibrated as required.
The Radiation Protection Program being implemented by the licensee satisfied
regulatory requirements.
Effluent and Environmental Monitoring
Effluent monitoring satisfied license and regulatory requirements and airborne releases
were within the specified regulatory and Technical Specification limits.
-2-
Procedures
Facility procedural review, revision, and implementation satisfied Technical Specification
requirements.
The emergency response program was conducted in accordance with the requirements
stipulated in the Emergency Preparedness Plan.
Transportation of Radioactive Materials
A violation was noted for failure to comply with the program for transportation of
radioactive material with respect to preparing packages for shipment and completing
shipping papers.
Security
Security facilities, equipment, and procedures satisfied the Physical Security Plan
requirements.
Material Control and Accounting
Special nuclear material was acceptably controlled and tracked as required by
REPORT DETAILS
Summary of Plant Status
The licensees TRIGA Mark I research reactor, licensed to operate at a maximum steady-state
thermal power of two hundred and fifty kilowatts (250 kW), continues to be operated in support
of education, operator training, surveillance, and sample irradiations. However, during this
inspection, the reactor was not operated.
1. Organizational Structure and Staffing
a. Inspection Scope (Inspection Procedure [IP] 69001)
The inspector reviewed the following regarding the licensees organization and staffing
to ensure that the requirements of Section 6.1 of Technical Specifications (TS),
Amendment No. 6, dated November 17, 2000, were being met:
- University of California, Irvine Nuclear Reactor Facility (UCINRF) organizational
structure and staffing
- staff qualifications
- management responsibilities
- staffing requirements for the safe operation of the facility
- selected portions of the operations log for the past year through the present
- UCINRF Standard Operating Procedure (SOP) Number (No.) 3, Personnel,
Revision (Rev) 3, approved March 2000
b. Observations and Findings
The licensees organizational structure and staffing had not functionally changed since
the last inspection. The reactor staff consisted of one permanent half-time staff member
(who was the Reactor Supervisor and also a licenced Senior Reactor Operator), one
licenced Senior Reactor Operator (who only provided coverage during routine reactor
operations), and support staff consisting of a series of quarter-time temporary students.
Because all the aforementioned individuals have various ongoing duties and activities
besides those related to the reactor, the time dedicated to reactor operation and
maintenance is quite limited.
The campus health physics (HP) staff consisted of the Radiation Safety Officer, two
Health Physicists, and three technical staff members. In addition to having responsibility
for the Universitys broad scope byproduct state license and other material licenses,
they provided support to the reactor staff when requested and performed specific
monthly and quarterly inspections/surveys of the reactor conforming to the campus
safety program. The reactor staff performed most HP functions at the reactor.
Coordination of radiation protection activities between the HP staff and the reactor staff
was acceptable.
The reactor operations staff satisfied the training and experience requirements
stipulated in the TS. The operations log and associated records confirmed that shift
staffing met the minimum requirements for duty and on-call personnel. However, the
-2-
inspector noted that the licenced reactor staff, together with current health physics
support, appeared significantly challenged for the present operation workload, even
though that workload was limited. Consideration should be given to hiring one or two
part-time individuals who could augment support for the operation and, perhaps,
eventually assume the responsibilities of the current Reactor Supervisor and the Senior
Reactor Operator.
c. Conclusions
The organizational structure and functions were consistent with TS requirements.
2. Review and Audit
a. Inspection Scope (IP 69001)
The inspector reviewed the following regarding the licensees organization and staffing
to ensure that the requirements of TS Section 6.2 and UCINRF SOP No. 1 were being
met:
- Reactor Operations Committee (ROC) meeting minutes from December 2000 to
date
- safety review and audit records for the past two years
- UCINRF SOP No. 1, Introduction, Rev 3, approved March 2000
b. Observations and Findings
The ROC membership satisfied TS requirements and the licensee's procedural rules.
The ROC had semiannual meetings as required with a quorum being present at those
meetings. Review of the committee meeting minutes indicated the ROC provided
appropriate guidance and direction for reactor operations, and ensured suitable use and
oversight of the reactor.
The review function of the ROC stipulated in TS Section 6.2 was fulfilled by Office of
Environmental Health and Safety (EH&S) personnel as they conducted their surveys
and walk through tours of the facility. This was reported to the ROC through the EH&S
Report given during the semiannual ROC meetings. Since the last inspection, all
required audits of reactor facility activities and reviews of programs, procedures, and
facility operations had been completed and documented.
c. Conclusions
The review and audit program was being conducted acceptably by the ROC.
3. Radiation Protection Program
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with 10 CFR Parts 19 and 20
and TS Sections 3.3 and 4.5 requirements:
-3-
- radiation and contamination survey records documented on the forms in accordance
with the guidance contained in UCINRF SOP No. 5, Radiological Safety Program
- radiation and contamination surveys completed by EH&S personnel and
documented on the forms in accordance EH&S procedures
- Nuclear Reactor Facility dosimetry records for 2000 through the first six months of
2002
- calibration and periodic check records for radiation monitoring instruments
documented on the applicable nuclear reactor facility (NRF) and EH&S forms
- UCINRF SOP No. 5, Radiological Safety Program, Rev 3, approved March 2000
The inspector also toured the facility, conducted a radiation survey using NRC
equipment, and observed the use of dosimetry and radiation monitoring equipment.
Licensee personnel were interviewed and radiological signs and postings were observed
as well.
b. Observations and Findings
(1) Surveys
The inspector reviewed monthly radiation and contamination surveys of the
licensee-controlled areas conducted by the licensee staff and monthly radiation and
quarterly wipe surveys completed by campus Office of Environmental Health and
Safety HP personnel. The inspector also reviewed the triennial gamma and neutron
surveys of the interior and exterior of the facility with the reactor operating at full
power. The surveys had been completed in accordance with UCINRF SOP No. 5.
The results were documented on the appropriate forms, evaluated as required, and
corrective actions taken when readings or results exceeded set action levels.
(2) Postings and Notices
The inspector reviewed the postings at the entrances to the facility-controlled areas
including the Control Room, the Reactor Room, and the two laboratories in the NRF.
The postings were acceptable and indicated the radiation hazards present. Other
postings also showed the industrial hygiene hazards present in the areas. The
facilitys radioactive material storage areas were noted to be properly posted. No
unmarked radioactive material was detected in the facility. Copies of current notices
to workers required by 10 CFR Part 19 were posted on the bulletin board in the
Outer Office/Counting Room leading to the Control Room.
(3) Dosimetry
The licensee used a National Voluntary Laboratory Accreditation program-accredited
vendor (Radiation Detection Company) to process personnel dosimetry. Through
direct observation, the inspector determined that dosimetry was acceptably used by
facility personnel.
An examination of the records for the past two years, through June of 2002, showed
that all exposures were well within NRC limits and within licensee action levels.
Extremity monitoring, accomplished through the use of finger rings, also showed
-4-
relatively low doses to the hands of staff members. The highest annual whole body
exposure received by a single individual for the past two years was less than 130
millirem. The highest annual extremity exposure for the past two years was less
than 470 millirem.
(4) Radiation Monitoring Equipment
The calibration of portable survey meters and friskers was typically completed by
EH&S personnel while fixed radiation detectors and air monitoring instruments were
generally calibrated by licensee personnel. The calibration records of portable
survey meters, friskers, fixed radiation detectors, and air monitoring equipment in
use at the facility were reviewed. Calibration frequency met the requirements
established in the applicable SOPs and records were being maintained as required.
(5) Radiation Protection Program
The licensees Radiation Protection Program was established in the UCI Nuclear
Reactor Facility SOP No. 5, Radiological Safety Program, Rev 3, approved March
2000. The program was further explained in the campus document entitled, UCI
Radiation Safety Handbook, dated 1987, Revised 1995, as well as in the campus
document UCI Radiation Safety Manual, Rev 3.2, dated December 1997. The
program required that all personnel who had unescorted access to work in a
radiation area or with radioactive material receive training in radiation protection,
policies, procedures, requirements, and facilities prior to entry. The inspector
verified that licensee staff had received the required radiation protection (rad
worker) training given by the UCI Office of Environmental Health and Safety.
The inspector also verified that the UCI NRF radiation protection program was being
reviewed annually as required.
(6) ALARA Policy
The ALARA Policy was also outlined and established in the UCI Nuclear Reactor
Facility SOP No. 5, Radiological Safety Program, Rev 3, approved March 2000,
and in the other campus documents. The ALARA program provided guidance for
keeping doses as low as reasonably achievable and was consistent with the
guidance in 10 CFR Part 20.
(7) Facility Tours
The inspector toured the Control Room, the Reactor Room, the Pneumatic Tube
Laboratory and the Preparation Laboratory within the NRF. Control of radioactive
material and control of access to radiation and high radiation areas were acceptable.
The postings and signs for these areas were appropriate.
As noted above, during a tour of the facility the inspector conducted a radiation
survey of the Reactor Room and the two adjacent laboratories and compared the
readings noted with those found by the licensee. The results detected by the
-5-
inspector were comparable to those found by the licensee. No discrepancies were
noted.
c. Conclusions
The inspector determined that, because: (1) surveys were being completed and
documented acceptably, (2) postings met regulatory requirements, (3) personnel
dosimetry was being worn as required and doses were well within the NRCs regulatory
limits, and (4) radiation monitoring equipment was being maintained and calibrated as
required, the Radiation Protection Program being implemented by the licensee satisfied
regulatory requirements.
4. Effluent and Environmental Monitoring
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with the requirements of
10 CFR Part 20 and TS Sections 3.3 and 3.5:
- airborne release records documented in the UCINRF Annual Reports for the period
from July 1, 2000 through June 30, 2001, and July 1, 2001 through June 30, 2002
- liquid release records also documented in the UCINRF Annual Reports for the
period from July 1, 2000 through June 30, 2001, and July 1, 2001 through June 30,
2002
- reactor pool water sample analyses documented on the applicable NRF forms
- UCINRF SOP No. 5, Radiological Safety Program, Rev 3, approved March 2000
b. Observation and Findings
Gaseous releases were monitored as required by TS, calculated as prescribed by
procedure, and acceptably documented. The results indicated that the releases were
well within 10 CFR Part 20 Appendix B, Table 2 concentrations, and TS limits. To
demonstrate compliance with the annual dose constraints of 10 CFR 20.1101(d), the
licensee used the computational method specified in UCINRF SOP No. 5, Section 5.6.
The highest calculated dose that could be received as a result of gaseous emissions
from reactor operations was less than 0.33 millirem for the period from July 1, 2000
through June 30, 2001, and less than 0.5 millirem for the period from July 1, 2001
through June 30, 2002. These doses were well below the limit set in 10 CFR 20.1101(d)
of 10 millirem per year.
The licensee had released liquid from the facility, but only by transferring it to the
Campus EH&S Office under the State of California Radioactive Material License. Solid
radioactive waste was also released to the Campus EH&S Office. The liquid and solid
waste was then stored, handled, and/or disposed of in accordance with the State license
requirements.
-6-
c. Conclusion
Effluent monitoring satisfied license and regulatory requirements and airborne releases
were within the specified regulatory and TS limits.
5. Procedures
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify that the licensee was
complying with the requirements of TS Sections 6.2, 6.3, and 6.7:
- records of procedure changes
- observation of procedure implementation
- administrative controls as outlined in UCINRF SOP No. 1, Introduction, Rev 3,
approved March 2000
b. Observations and Findings
Operations procedures were available for those tasks and items required by the TS and
facility directives. Written changes were reviewed and approved by the ROC as
required. The SOPs were reviewed as necessary with the last review dated March
2000.
Training of personnel on procedures and changes was acceptable. Through
observation of surveys and experiment handling, the inspector verified that personnel
conducted TS activities in accordance with applicable procedures. Records showed that
procedures for potential malfunctions (e.g., radioactive releases, contaminations, and
reactor equipment problems) had been developed and were implemented as required.
c. Conclusions
Procedural review, revision, and implementation satisfied TS requirements.
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to ensure that the licensee was
following the requirements stipulated in the Emergency Plan of the UCINRF, Rev 3.0,
dated May 2000:
- emergency response facilities, supplies, equipment, and instrumentation
- training records for licensee staff and support personnel
- offsite support as documented in Letters of Agreement
- emergency drills and exercises for the past two years
- UCINRF SOP No. 6, Emergency Procedures, Rev 3, approved March 2000
-7-
b. Observations and Findings
The Emergency Plan (E-Plan) in use at the NRF was the same as the version most
recently approved by the NRC. Implementing procedures were reviewed and revised as
needed to effectively implement the E-Plan. Emergency facilities, instrumentation, and
equipment were being maintained and controlled, and supplies were being checked
weekly, but documentation of an inventory conducted on a routine basis as required by
Section 8.6 of the E-Plan was not available. This is an area for improvement.
Section 10.0 of the E-Plan states that a meeting of senior personnel shall be held each
year to review the plan and establish a schedule for training and exercises. The
licensee acknowledged that no meetings of senior personnel had been held during the
past several years, but that an annual drill was held and a planning meeting was held for
that purpose. The E-Plan was being audited and reviewed as needed. The licensee
was informed that the lack of documented meetings of senior personnel to review the
E-Plan and schedule training is an area for improvement.
Through records review and through interviews with licensee and EH&S personnel,
emergency responders were determined to be knowledgeable of the proper actions to
take in case of an emergency. An agreement letter had been updated and maintained
as required with the Western Medical Center for medical support in case of a major
emergency. Communications capabilities were acceptable with these support groups
and had been tested as stipulated in the E-Plan. Off-site support for the NRF was
verified to be in accordance with the E-Plan.
Emergency drills had been conducted as required by the E-Plan. Critiques were written
following the drills and the event to document the strengths and weaknesses identified
during the exercises and to develop possible solutions to any problems noted.
The inspector verified that emergency preparedness and response training for reactor
staff was being completed and documented. The inspector also visited the Orange
County Fire Authority, Station No. 4, to observe the support that was available in the
event of a fire at the NRF.
c. Conclusions
The emergency response program was conducted in accordance with the requirements
stipulated in the Emergency Preparedness Plan.
7. Transportation
a. Inspection Scope (IP 86740)
The inspector reviewed the following to verify compliance with regulatory requirements
for shipping licensed material:
- records of radioactive material shipments for 2001 and to date
- UCINRF SOP No. 5, Radiological Safety Program, Rev 3, approved March 2000
-8-
The inspector also interviewed licensee personnel.
b. Observations and Findings
Title 10 CFR Section 71.5(a) requires that a licensee who delivers licensed material to a
carrier for transport comply with the applicable requirements of the regulations
appropriate to the mode of transport of the Department of Transportation (DOT) in 49
CFR Parts 171-189.
Section 171.2(a) of 49 CFR prohibits any person from offering hazardous material for
transportation unless, among other requirements, the hazardous material is properly
classified, described, packaged, marked, labeled, and in condition for shipment required
or authorized under the Hazardous Material Regulations (49 CFR 171-177).
The inspector reviewed the various documents prepared in support of shipments made
during 2001 through the date of the inspection. Many of the shipping papers and some
of the supporting documentation lacked necessary and required items of information as
required by 49 CFR Parts 171 through 177. Other problems were noted as well. The
problems noted with the shipping papers and/or the supporting documentation included:
(1) failure to list the chemical and physical form of the radioactive material, (2) failure to
list the major isotopes and the total activity present in the packages of radioactive
material being shipped, (3) failure to indicate that the shipping packages complied with
the requirements for external radiation and contamination levels, (4) failure to note the
Transport Index (TI) for certain shipments, (5) failure to sign the shipping papers and
certification, (6) failure to list an Emergency Telephone number on the shipping papers,
and (7) placing the wrong label on a shipment.
The details for each of the above problems are as follows:
(1) The shipping papers for shipments made on the following dates in 2001 did not list
the chemical or physical form of the radioactive material being shipped as required
by 49 CFR 172.203(d)(3): January 18 and 19; February 1 and 14; March 2, 16,
and 27; April 24; May 3 and 22; June 14, 26, and 27; July 11; and August 23.
(2) The shipping papers for shipments made on the following dates in 2001 (and on one
date in 2002 as indicated) did not list the name of each radionuclide and the activity
contained in each package of radioactive material being shipped as required by
49 CFR 172.203(d)(2) and (4): January 18 and 19; February 1 and 14; March 2, 16,
and 27; April 24; May 3 and 22; June 14, 26, and 27; July 11; August 23; and
March 26, 2002.
(3) The shipping papers for shipments made on the following dates in 2001 (and on one
date in 2002 as indicated) did not list the activity contained in each package of
radioactive material being shipped as required by 49 CFR 172.203(d)(4):
January 10; May 22 (a second shipment on this date - different from the shipment
mentioned in (2) above), December 4; and June 25, 2002.
(4) Documentation of shipments made on the following dates in 2001 did not indicate
that the contamination levels present on the external surfaces of the packages
-9-
offered for transport were below the acceptable levels indicated in 49 CFR 173.443:
January 18; February 1; March 27; April 24; May 3 and 22; June 14, 26, and 27;
July 11; and August 23.
(5) The shipping papers for shipments made on the following dates in 2001 did not list
the TI of the radioactive material being shipped as required by 49 CFR
172.203(d)(6): January 10; May 3 and 22; June 14; November 15; and December 4.
(6) The shipping papers for shipments made on the following dates were not signed or
certified by anyone to indicate or verify that the shipments were acceptable for
shipment as required by 49 CFR 172.204: January 19, 2001 and June 25, 2002.
(7) The shipping papers for shipments made on the following dates in 2001 did not list
an Emergency Telephone number on the form as required by 49 CFR 172.202 and
172.604: July 12 and November 15.
(8) Documentation of the shipment made on November 15, 2001, did not indicate that
the radiation levels at any point on the external surface of the package offered for
transport were within the acceptable levels indicated in 49 CFR 173.441.
(9) The shipping papers for the shipment made on June 25, 2002, indicated that a
Yellow II label had been used for the shipment instead of a Yellow III label. The
Yellow III label would have been the correct label according to the TI listed on the
shipping papers, as required by 49 CFR 172.403.
The licensee was informed that failure to include the required information and/or
signatures on the shipping papers, failure to demonstrate that certain packages were in
compliance with the radiation and contamination levels required for shipment, and failure
to label one shipment correctly were examples of an apparent violation (VIO) of
10 CFR 71.5(a) (VIO 50-326/2002-201-01).
c. Conclusions
One violation was identified for failure to comply with the requirements on
10 CFR 71.5(a) regarding shipments of radioactive material.
8. Security
a. Inspection Scope (IPs 81402 and 81431)
To verify compliance with the licensees NRC-approved Physical Security Plan (PSP)
and to assure that changes, if any, to the plan had not reduced its overall effectiveness,
the inspector reviewed:
- security systems, equipment and instruments
- logs, records, and reports concerning security
- alarm system checks documented on UCINRF Monthly Maintenance Checklists
-10-
- access and key control
- UCINRF SOP No. 4, Normal Operating Procedures, Rev 3, approved March 2000
- UCINRF SOP No. 7, Security Response Procedures, Rev 3, approved March 2000
b. Observations and Findings
The PSP in effect at the facility, the revision dated May 2000, was the same version as
the one approved for use by the NRC. UCI Police Department (UCIPD) personnel
provided security as required by the plan. Physical protection systems (barriers, alarms,
equipment, and instrumentation) were as required by the PSP. Security checks, tests,
and verifications were performed at the required frequencies and tracked as required.
Corrective actions were taken when problems with security or the equipment were
noted. Access controls were implemented as required by the PSP and licensee
procedures. Periodic training was provided to the NRF staff and familiarization tours
were given to UCIPD personnel. Response rosters were current and posted as required
in the NRF. The inspector also verified that the UCIPD had the most current roster for
reference. Communication between the reactor staff and the UCIPD was acceptable
and checked periodically.
c. Conclusions
Security facilities, equipment, training, and procedures satisfied PSP requirements.
9. Material Control and Accounting
a. Inspection Scope (IP 85102)
To verify compliance with 10 CFR Part 70, the inspector reviewed:
- control of Special Nuclear Material (SNM) storage areas
- Semiannual fuel inventory results documented on the UCINRF Fuel Inventory
Checklist forms
- Nuclear Material Transaction Reports for the time period from October 2000 through
March 2002
- UCINRF SOP No. 4, Normal Operating Procedures, Rev 3, approved March 2000
b. Observations and Findings
Through records review and direct observation, the inspector verified that licensed SNM
was stored only in designated areas and that the licensee was maintaining control of
those storage areas as required. Records also showed that physical inventories were
conducted at least annually as required by 10 CFR 70.51(d). Nuclear Material
Transaction Reports (DOE/NRC Form 741) and Material Status Reports (DOE/NRC
Form 742) had been completed semi-annually and submitted by the licensee to the
appropriate regulatory agencies in a timely manner and as required by 10 CFR 74.13(1).
-11-
c. Conclusions
The licensee was acceptably controlling and tracking SNM as required by
10. Follow-up on Previously Identified Issues
a. Inspection Scope
The inspector reviewed the actions taken by the licensee following identification of an
Inspector Follow-up Item (IFI) during an inspection in May 2001, and documented in
NRC Inspection Report No. 50-326/2001-201, dated August 10, 2001.
b. Observations and Findings
IFI 50-326/2001-201-02 - Written procedures would be updated to match present
practices or activities would be performed as in current procedures.
During the inspection in May 2001, it was noted that there were a number of
mismatches between certain written procedures and the manner and frequencies in
which required operations/surveillance activities were performed. It appeared that some
older (pre-1990) licensee procedures had not been formally updated when newer
practices were implemented. When this issue was brought up, the Reactor Supervisor
and the Dean of Physical Science stated that the written procedures would be updated
to match actual practices or the activities would be performed as outlined in the written
procedures.
During this inspection the inspector verified that the procedures had been updated and
now reflect current practices as performed. This issue is considered closed.
c. Conclusions
One IFI identified during an inspection in May 2001 was closed.
11. Exit Interview
The inspection scope and results were summarized on September 19, 2002, 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.
The Physical Security Plan, and related subject matter, were identified as proprietary
information.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
G. Miller Reactor Supervisor
W. Parker Vice Chancellor for Research
P. Rogers Senior Reactor Operator
J. Stern Dean, Physical Sciences
K. Wolonsky Associate Dean, Physical Sciences
Other Personnel
L. Ferrari-McCoy Dispatcher, UCIPD
R. Freight Supervisor, UCI Key Shop
F. Gallagher III Radiation Safety Officer, UCI EH&S
K. Harkness Principal Health Physics Technologist, UCI EH&S
S. Quan Sargent, UCIPD
INSPECTION PROCEDURES USED
IP 69001 Class II Research and Test Reactors
IP 81402 Reports of Safeguards Events
IP 81431 Fixed Site Physical Protection of Special Nuclear Material of Low Strategic
Significance
IP 85102 Material Control and Accounting - Reactors
IP 86740 Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-326/2002-201-01 VIO Failure to include the required information and/or signatures on
the shipping papers, failure to demonstrate that certain packages
were in compliance with the radiation and contamination levels
required for shipment, and failure to label one shipment correctly
as required.
Closed
50-326/2001-201-02 IFI Written procedures to be updated to match present survey
practices or the surveys would be performed as outlined in the
written procedures.
PARTIAL LIST OF ACRONYMS USED
ALARA As Low As Reasonably Achievable
CFR Code of Federal Regulations
EH&S (Office of) Environmental Health and Safety
HP Health Physics
IFI Inspector Follow-up Item
IP Inspection Procedure
NRC Nuclear Regulatory Commission
NRF Nuclear Reactor Facility
PD Police Department
PSP Physical Security Plan
ROC Reactor Operations Committee
SOP Standard Operating Procedure
SRO Senior Reactor Operator
TI Transport Index
TLD Thermoluminescent dosimeter
TS Technical Specifications
UCI University of California, Irvine
UCINRF University of California, Irvine Nuclear Reactor Facility
UCIPD University of California, Irvine Police Department