IR 05000607/2020202
| ML20183A312 | |
| Person / Time | |
|---|---|
| Site: | University of California-Davis |
| Issue date: | 08/03/2020 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Frey W McClellan Nuclear Research Center |
| Craig Bassett, NRR/DLP/UNPO, 415-1842 | |
| References | |
| IR 2020202 | |
| Download: ML20183A312 (22) | |
Text
ust 3, 2020
SUBJECT:
UNIVERSITY OF CALIFORNIA-DAVIS - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000607/2020202
Dear Dr. Frey:
During June 15 - 18, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the University of California-Davis/McClellan Nuclear Research Center. The enclosed report documents the inspection results discussed on June 18, 2020, with you; Mr. Walter Steingass, Reactor Supervisor; and, Mr. 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 various activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.
In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Travis Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-607 License No. R-130 Enclosure:
As stated cc: See next page
University of California-Davis/McClellan Docket No. 50-607 cc:
David Reap, Radiation Safety Officer 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504 Mr. Walter Steingass, Reactor Supervisor 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504 California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814 Radiological Health Branch California Department of Public Health P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115 Dr. Prasant Mohapatra Vice Chancellor for Research Department of Computer Science University of California Davis, CA 95616
ML20183A312 *concurred via e-mail NRC-002 OFFICE NRR/DANU/UNPO/PM* NRR/DANU/UNPO/LA* NRR/DANU/UNPO/BC*
NAME CBassett NParker TTate DATE 7/6/2020 7/6/2020 8/3/2020
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No. 50-607 License No. R-130 Report No. 05000607/2020202 Licensee: University of California-Davis Facility: McClellan Nuclear Research Center Location: McClellan Park Sacramento, California Dates: June 15 - 18, 2020 Inspector: Craig Bassett Approved by: Travis Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure
EXECUTIVE SUMMARY University of California-Davis McClellan Nuclear Research Center Inspection Report No. 05000607/2020202 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the University of California-Davis (the licensees) 2 megawatt Class I research reactor safety program, including: (1) operator licenses, requalification, and medical examinations; (2) experiments; (3) organization and operations and maintenance activities, (4) review and audit and design change functions; (5) procedures; (6) fuel movement; (7) surveillance; and, (8) emergency preparedness since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The NRC staff determined the licensees program was acceptably directed toward the protection of public health and safety and in compliance with NRC requirements.
Operator Licenses, Requalification, and Medical Examinations
- Operator requalification was conducted as required by the Operator Training and Requalification Program and the program was maintained up-to-date.
- Medical examinations were completed biennially for each operator as required.
Experiments
- The licensees program for reviewing, approving, and conducting experiments satisfied procedural and technical specification (TS) requirements.
Organization and Operations and Maintenance Activities
- The organizational structure and staffing were consistent with TS requirements.
- Reactor operations were conducted in accordance with procedures and the appropriate logs were maintained.
- The preventive maintenance system was used effectively to ensure that maintenance activities were completed in a timely manner.
Review and Audit, and Design Change Functions
- The facility Nuclear Safety Committee (NSC) met semiannually, reviewed the topics outlined in the TSs, and conducted annual audits of facility operations as required.
- The review, evaluation, and documentation of changes to the facility satisfied NRC requirements.
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Procedures
- The procedure review, revision, control, and implementation program satisfied TS requirements.
Fuel Movement
- Fuel movement and handling was conducted in accordance with procedural requirements and fuel inspections were completed annually as required by the TSs.
Surveillance
- Surveillance activities at the facility were completed within the TS-prescribed time frames as required.
- The emergency preparedness program was conducted in accordance with the Emergency Plan (E-Plan).
- Emergency response equipment was maintained and alarms were tested as required.
- The memoranda of understanding (MOU) between the licensee and various support agencies were maintained.
- Emergency drills were conducted annually as required by the E-Plan.
- Emergency preparedness training for operations personnel was completed.
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REPORT DETAILS Summary of Facility Status The University of California-Davis (UCD) 2 megawatt Class I Training, Research, Isotope, General Atomics (TRIGA) Mark-II research reactor continued to operate in support of neutron radiography, medical isotope production, neutron tomography, and sample/product irradiation.
During the inspection the reactor operated up to eight hours per day at varying power levels up to 1 megawatt to support neutron radiography and sample irradiation.
1. Operator Licenses, Requalification, and Medical Examinations a. Inspection Scope (Inspection Procedure (IP) 69003)
The inspector reviewed selected aspects of the following to verify compliance with the UCD/McClellan Nuclear Research Center (MNRC) Operator Training and Requalification Program outlined in Procedure UCD/MNRC-0009-DOC-04, Selection and Training Plan for Reactor Personnel, and Section 6.1.4 of the UCD/MNRC TSs, Revision 13, dated March 28, 2003:
- status of all qualified operators licenses
- selected operator physical examination records for the past 3 years
- training schedule for maintenance of qualifications for senior reactor operators (SROs) for the May 2016 - April 2018 and May 2018 - April 2020 requalification cycles
- operator active duty status documented on MNRC personnel reactivity manipulations and active duty performance record forms for 2016 through 2019, and to date in 2020
- operator training and lecture attendance records documented on MNRC training attendance record forms and on the computer data base for 2016 through 2019, and to date in 2020
- selected records of UCD/MNRC reactor facility annual operating tests for SROs and reactor operators (ROs) and MNRC SRO requalification written examinations for 2016 through 2019, and to date in 2020
- current memorandum for the training coordinator from Dr. Wesley Frey, UCD/MNRC Director, dated February 11, 2020, specifying those individuals who had completed the requalification program and were certified to continue operating the reactor and those who were in training
- various entries documented on UCD/MNRC operations log pages from Log Books Nos. 177 through 182 UCD/MNRC 2017 annual report, submitted to the NRC on June 28, 2018
- UCD/MNRC 2018 annual report, submitted to the NRC on June 27, 2019
- American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.4-1988, Selection and Training of Personnel for Research Reactors, approved June 9, 1988-4-
b. Observations and Findings There were five qualified SROs and no ROs on staff at the facility. The inspector verified that all operators licenses were current. The inspector also reviewed various forms and records documenting the status of the qualification program.
MNRC Personnel Reactivity Manipulations and Active Duty Performance Records and operations logs showed that operators were maintaining active duty status as required. A review of the logs and records also showed that training was conducted in accordance with the approved requalification and training program. Procedure reviews and examinations were completed and documented as required.
Through records review, the inspector determined that all operators completed the required quarterly reactor operations and reactivity manipulations, other operations activities, and Reactor Supervisor activities. The inspector also determined that annual operating tests were administered and supervisory observations were completed as required. Biennial written examinations were completed by the operators as well.
The inspector also reviewed medical records for the operators and verified that they received the biennial medical examinations required by the program in accordance with ANSI/ANS-15.4-1988. Through records review and interviews with various operators, the inspector verified that the Operator Training and Requalification Program was implemented and maintained as required.
c. Conclusion The inspector determined the operators requalification was completed, and training maintained up-to-date as required by the licensees Requalification Program. The inspector also determined medical examinations were completed biennially for each licensed operator as required by Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators' Licenses.
2. Experiments a. Inspection Scope (IP 69005)
The inspector reviewed selected aspects of the following to verify compliance with the licensees program for conducting experiments outlined in Procedure UCD/MNRC-0033-DOC-05, University of California, Davis/McClellan Nuclear Research Center Research Reactor Facility Experiment Review and Authorization Process, and TS Sections 3.8, 4.8, and 6.5:
- selected facility use authorization forms
- most recent UCD/MNRC irradiation summary forms
- selected UCD/MNRC experimenter certification forms
- listing of approved experiments and authorized experimenters
- various UCD/MNRC irradiation request forms for 2019 and to date in 2020
- selected UCD/MNRC irradiation tracking sheets for 2019 and to date in 2020-5-
- various entries documented on UCD/MNRC operations log pages from Log Books Nos. 177 through 182
- procedure UCD/MNRC-0081-DOC-00, UCD/MNRC Experiment Coordination Checklist
- the two most recent annual reports for UCD/MNRC submitted to the NRC in June 2018 and June 2019 b. Observations and Findings The inspector reviewed the experiment review and approval process at the facility. It was noted that no new Facility Use Authorizations had been approved since the previous NRC inspection conducted in August 2019. Also, no new experiments had been proposed or approved since that inspection. The inspector verified that the experiments conducted at the facility had been previously reviewed and approved by the NSC as required by procedure UCD/MNRC-0033-DOC-05.
The inspector noted that the experiments conducted at the facility were completed under the cognizance of the Reactor Supervisor and the SRO, and in accordance with TS requirements (e.g., reactivity limitations). The results of the experiments were documented on the appropriate irradiation request forms which listed the conditions of the irradiation and the radiological survey results of the material when removed from the reactor. The inspector found the radiation levels of the irradiated material were usually below detectable limits and the material was free-released. If the radiation level of the irradiated material was above the release limit, the material was transferred back to the group which submitted it after the licensee verified that the organization had a license which allowed possession of such material. The irradiation request forms reviewed by the inspector were filled out properly with the appropriate information included.
c. Conclusion The inspector determined that the licensees program for reviewing, approving, and conducting experiments satisfied TSs and procedural requirements.
3. Organization and Operations and Maintenance Activities a. Inspection Scope (IP 69006)
The inspector reviewed the following regarding the UCD/MNRC organization, staffing, staff responsibilities, reactor operations, and Preventive Maintenance Program to ensure that the requirements of TS Sections 3.0, 6.1, and 6.8 were met:
- management responsibilities
- qualifications of facility personnel
- current UCD/MNRC organizational structure
- staffing requirements for safe operation of the research reactor facility
- ANSI/ANS-15.4-1988, Selection and Training of Personnel for Research Reactor, approved June 9, 1988-6-
- various UCD/MNRC startup checklist forms for 2019 and to date in 2020
- selected UCD/MNRC shutdown checklist forms for 2019 and to date in 2020
- various UCD/MNRC facility rounds log forms for 2019 and to date in 2020
- selected entries listed on UCD/MNRC operations log pages contained in Log Books Nos. 177 through 182
- procedure UCD/MNRC-0004-DOC-13, Technical Specifications for the University of California, Davis/McClellan Nuclear Radiation Center (UCD/MNRC)
- procedure UCD/MNRC-0007-DOC-05, Maintenance Procedures
- procedure UCD/MNRC-0016-DOC-12, UCD/MNRC Operating Instructions
- preventive maintenance system database maintained on the control room computer which included entries denoting equipment history
- MNRC preventive maintenance system - twelve month schedule for the period from March 2019 through April 2020
- selected MNRC work order forms documenting various completed and pending maintenance tasks for 2019 and to date in 2020
- the two most recent annual reports for UCD/MNRC submitted to the NRC in June 2018 and June 2019 b. Observations and Findings (1) Organization and Staffing The inspector reviewed the operations organization at the facility. The Vice Chancellor for Research was designated as the licensee for the UCD/MNRC. The facility was under the direct control of the MNRC Director who was accountable to the Vice Chancellor for the safe operation and maintenance of the facility. Individuals in the management organization (e.g., Operations Manager, Reactor Supervisor, Health Physics Supervisor or Radiation Safety Officer) were responsible for implementing MNRC policies for operation of the facility, for safeguarding the public and facility personnel from undue radiation exposure, and for adhering to the operating license and TSs. The organization was as stipulated in TS Section 6.1.
The subject of facility staffing was reviewed by the inspector. The current organization consisted of nine individuals: (1) UCD/MNRC Director, (2) Associate Director for Reactor Operations/Reactor Supervisor, (3) Radiography/Facility Manager, (4) Radiation Safety Officer (RSO)/Security Manager, (5) Electronics Engineer, (6) and (7) two Level III Radiographers, (8) Radiographer trainee, and (9) a person who was hired to develop the radiographs. It was noted that the Electronics Engineer worked at the reactor facility half-time and at another facility on the main campus for the remainder of the time. Through interviews with the Facility Director, the inspector learned that the Radiography/Facility Manager was due to retire at the end of June. In addition, the inspector found that two new people had been hired to help at the MNRC but, due to the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE), they had yet to start work.
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It was noted that five of the nine individuals mentioned above were licensed SROs. This number included the Radiography/Facility Manager who was retiring. Nevertheless, the inspector found staffing requirements for safe operation of the research reactor facility as required by the TSs were met.
(2) Operations The inspector reviewed selected UCD/MNRC startup and shutdown forms, rounds log sheets, and operations log entries dating from 2019 through the date of this inspection. The operating logs and checklists were complete and provided an indication of operational activities. The inspector found that logs and checklists showed that operational conditions and parameters were consistent with license and TS requirements and indicated that operational limits were not exceeded.
The logs were also used by the licensee to record problems with equipment and abnormal events or anomalies. Unplanned shutdowns and inadvertent scrams were also noted in the logs, in addition to being documented in the licensees monthly reports and reported in annual reports submitted to the NRC.
The inspector observed facility activities including a routine reactor start-up, operations on various occasions, a shutdown, and handling of an experimental irradiator and radioactive material. The inspector found operations were conducted in accordance with the applicable procedures and the actions were documented in the required logs.
(3) Maintenance Activities The inspector reviewed the preventive maintenance system that the licensee developed to schedule and track maintenance activities and surveillance items. A computer program was designed to produce periodic work schedules for maintenance activities and was set up to generate MNRC work order forms (MWOs). The MWOs were used to complete and document the required maintenance and/or surveillance activities. The data from each completed MWO was entered into the computerized tracking system by the Radiography Supervisor/Building Manager. The inspector verified that the licensee conducted the various maintenance activities at the frequencies required by their program.
c. Conclusion The inspector determined the licensees organization and staffing were in compliance with the requirements specified in TS Section 6.1. The inspector also determined the reactor and related operations were conducted in accordance with procedures and the appropriate logs were maintained. The facility preventive maintenance system was used effectively by the licensee to ensure completion of maintenance activities in a timely manner.
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4. Review and Audit and Design Change Functions a. Inspection Scope (IP 69007)
To verify that the required reviews and audits were completed by the licensee and to ensure that facility changes were reviewed and approved as required by the licensees change process outlined in procedure UCD/MNRC-0043-DOC-05, Facility Modification Procedure, and TS Section 6.2, the inspector reviewed selected aspects of:
- annual audits conducted for 2018 and 2019
- NSC meeting minutes for January 2018 through the present
- UCD/MNRC facility modification notebook containing facility modification log forms
- selected facility modification installation authorization forms and the associated facility modification checklist forms processed during 2015 through the present
- procedure UCD/MNRC-0045-DOC-04, Quality Assurance Program for McClellan Nuclear Research Center (MNRC)
- the two most recent annual reports for UCD/MNRC, submitted to the NRC in June 2018 and June 2019
- Charter of the Nuclear Safety Committee (NSC) for the University of California, Davis/McClellan Nuclear Research Center (UCD/MNRC),
Revision 3 b. Observations and Findings (1) Review and Audit Functions The inspector determined that the composition of the NSC and qualifications of NSC members were as specified in TS Section 6.2.1.
Minutes of NSC meetings demonstrated that the committee met 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 safety reviews were conducted by the NSC or a designated representative. Topics of those reviews were as required by the TSs and provided sufficient guidance, direction, and oversight to ensure acceptable use of the reactor.
The inspector noted that the annual operations audit for 2018 was conducted on February 20, 2019, by the Chair of the NSC. The inspector determined the audit was adequate and covered the activities specified in TS Section 6.2.4, including various aspects of the reactor facility operations and other functions. The operations audit for 2019 was also conducted by the Chair of the NSC and was completed on August 29, 2019. The inspector also found this audit was adequate. No problems were noted in the audits by the inspector and no recommendations were made.
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(2) Change Control Functions To satisfy the regulatory requirements stipulated in 10 CFR 50.59, Changes, tests and experiments, the licensee implemented procedure UCD/MNRC-0043-DOC-05, 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, tests or experiments not described in the SAR. The inspector found the procedure adequately incorporated criteria provided by the regulations.
The inspector determined that no change requests were issued and no facility changes were made within the past four years. Nevertheless, the inspector verified that, as required by procedure, all proposed facility modification packages processed in the past were presented to a Modification Review Committee for screening and classification. In addition to that committees screening, the packages were required to be reviewed by the Reactor Supervisor and a health physics representative, and then approved by the Facility Director. The inspector determined that safety significant changes and modifications (designated by the facility as Class I and II changes) were reviewed and approved by the NSC as required by TS Section 6.2.
c. Conclusion The inspector determined that the NSC met semiannually, reviewed the topics outlined in the TSs, and conducted annual audits of facility programs as required.
The facility design change program satisfied NRC requirements.
5. Procedures a. Inspection Scope (IP 69008)
To verify compliance with TS Section 6.4, the inspector reviewed selected portions of the following:
- MNRC document list, including the procedure number, title, individual responsible for reviewing the procedure, and date of the last review
- procedure UCD/MNRC-0005-DOC-09, Document Control Plan
- procedure UCD/MNRC-0043-DOC-05, Facility Modification Procedure b. Observations and Findings TS Section 6.4 requires 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. Changes to the procedures also required the approval of the UCD/MNRC Director, and all changes were required to be documented.
The inspector noted that facility procedures were developed for the activities and were approved by the Director as required by the TSs. The inspector verified that recent changes to the procedures were approved by the Director.
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The inspector noted that various members of the facility staff were required to perform periodic reviews of the procedures to assure that they were current. The completion of these reviews continued to be tracked by the Reactor Supervisor.
The inspector determined that biennial reviews of the maintenance procedures and annual reviews of the other types of procedures were completed as required by TSs.
c. Conclusion The inspector determined the current procedure review, revision, control, and implementation program satisfied the TS requirements.
6. Fuel Movement a. Inspection Scope (IP 69009)
To ensure that the licensee was following the requirements of TS Sections 3.2.4, 4.2.4, and 5.3, the inspector reviewed selected aspects of the following:
- selected UCD/MNRC fuel transfer forms
- various fuel inspection sheets for 2019 and to date in 2020
- selected UCD/MNRC present element location forms
- fuel handling checklists for fuel handling in 2019 and to date in 2020
- various fuel movement sheets developed prior to, and used for, fuel movements during the past 24 months
- selected UCD/MNRC fuel element tracking information log sheets
- various entries in the UCD/MNRC fuel measurement log notebook detailing fuel element measurements
- selected UCD/MNRC operations log pages from Log Books Nos. 177 through 182
- core fuel status and storage boards located in the control room and in the reactor room indicating current fuel element locations
- procedure UCD/MNRC-0019-OMM-04, 5220, Fuel Handling Tools
- procedure UCD/MNRC-0011-OMM-04, 5240, Fuel b. Observations and Findings The inspector reviewed the fuel movement process used by the licensee and verified that fuel was moved according to an established procedure and in conjunction with specific fuel movement sheets. These sheets were developed by an SRO for each evolution and approved by the Facility Director or the Reactor Supervisor. The sheets were used not only for fuel movement, which included transferring fuel from the core to storage and from storage to the core, but for fuel inspections as well. A review of recent fuel movement sheets indicated that the licensee was following the approved procedural process.
It was noted that, during the last annual facility shut down for maintenance which was completed on August 8, 2019, the licensee also completed inspections of those fuel elements specified in the TSs. The inspector reviewed selected fuel inspection sheets and noted that the inspections were completed annually in
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compliance with TS Sections 3.2.4 and 4.2.4. The inspector verified that fuel handling tools were properly maintained and were adequately controlled and secured when not in use.
The inspector compared the current location of selected fuel elements in the reactor core (as illustrated by a printed core configuration map) with the information maintained on the Fuel Status Boards in the Control Room and the Reactor Room, and on the fuel movement sheets. The inspector found fuel was used and stored in the locations as indicated and no problems were noted. The licensees current core was designated as core 30B.
c. Conclusion The inspector determined that fuel movements and inspections were conducted in accordance with the TS and procedural requirements.
7. Surveillance a. Inspection Scope (IP 69010)
To verify that the licensee was complying with TS Section 4.0, the inspector reviewed selected aspects of:
- selected UCD/MNRC Operations Log pages from Log Books Nos. 177 through 182
- preventive maintenance system database maintained on the control room computer which included entries denoting equipment history
- MNRC preventive maintenance system - twelve-month schedule for the period from March 2019 through April 2020
- selected MWOs documenting various completed and pending maintenance tasks for 2019 and to date in 2020
- procedure UCD/MNRC-0007-DOC-05, Maintenance Procedures
- procedure UCD/MNRC-0030-DOC-05, MNRC Tag-Out Procedure
- the two most recent annual reports for UCD/MNRC submitted to the NRC in June 2018 and June 2019 b. Observations and Findings The inspector reviewed the MNRC preventive maintenance program and found that routine maintenance work and surveillance activities were typically completed on Mondays during the weekly routine scheduled reactor shutdown.
Major maintenance and surveillance items were completed during the licensees annual maintenance shutdown which typically lasted for one or two weeks. The inspector reviewed selected data recorded in the system database and on the MWOs for various TS required surveillances including calibrating the stack and reactor continuous air monitor, measuring control rod reactivity worths, and verifying the shutdown margin. The records indicated that the required tests, checks, verifications, and calibrations were completed on schedule and in accordance with licensee procedures. The results reviewed by the inspector were found to be within the TS and procedurally prescribed parameters.
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c. Conclusion The inspector determined that the MNRC preventive maintenance system was used to effectively complete surveillance activities at the facility in a timely manner in accordance with the program and TSs.
8. Emergency Preparedness a. Inspection Scope (IP 69011)
The inspector reviewed selected aspects of the following documents and records to verify compliance with the UCD/MNRC-0001-DOC-08, Emergency Plan for the University of California, Davis - McClellan Nuclear Research Center (UCD/MNRC), approved by the NSC Chairman dated June 12, 2006:
- documentation of the 2018 and 2019 emergency drills and critiques
- MOU with the UCD Medical Center, dated May 1, 2006
- MOU between the County of Sacramento and the Sacramento Metropolitan Fire District and McClellan Airport and Park, dated November 23, 2004, concerning fire protection services
- MOU with the Sacramento County Sheriffs Department, dated December 18, 2000
- training schedule for maintenance of qualifications for SROs for the 2016-2018 and 2018-2020 requalification cycles
- procedure UCD/MNRC-0018-DOC-07, University of California, Davis/McClellan Nuclear Research Center Emergency Procedures
- procedure UCD/MNRC-0078-DOC-02, UCD/MNRC Emergency Procedures for Emergency Response Personnel - Class 0 Emergency-Personnel and Operation Events
- procedure UCD/MNRC-0079-DOC-02, UCD/MNRC Emergency Procedures for Emergency Response Personnel - Class I Emergency-Notification of Unusual Events
- procedure UCD/MNRC-0080-DOC-02, UCD/MNRC Emergency Procedures for Emergency Response Personnel - Class II Emergency-Alert b. Observations and Findings (1) Emergency Plan The inspector reviewed the E-Plan in use at the reactor and verified that it was reviewed and updated biennially as required by the E-Plan. Activities associated with the E-Plan (e.g., training, drills, etc.) were reviewed annually by the NSC. The inspector reviewed the UCD/MNRC emergency procedures associated with the E-Plan. The inspector found procedures were also typically reviewed annually and revised as needed to ensure effective implementation of the E-Plan.
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(2) Support Agreements with Offsite Agencies The inspector verified that the MOU between the County of Sacramento and McClellan Park remained in effect. The memorandum stipulated that the Sacramento Metropolitan Fire Department (SMFD) would be available during an emergency and would provide support for the facility. The inspector also verified that the MOU between the UCD/MNRC facility and UCD Medical Center was valid. That memorandum indicated that the UCD Medical Center would provide the MNRC with needed support in case of an event involving a medical emergency. The licensee also maintained a current MOU with the Sacramento County Sheriffs Department. That MOU stipulated that Sheriffs Department Deputies would provide the MNRC with immediate support in case of a security event at the facility.
(3) Training Through records review and interviews with SRO personnel, the inspector determined that they were knowledgeable of the proper actions to take in case of an emergency. Training for all facility personnel had been conducted but it was not readily apparent what the training consisted of and that it was recorded properly. The training was not extensive or include enough detail for facility personnel. The licensee was informed that clarifying the emergency training given to facility personnel and clearly documenting it would be identified as an inspector follow-up item (IFI) which would be reviewed during a future inspection (IFI 05000607/2020202-01).
Training for support organization personnel was provided whenever those organizations schedules would permit. This included walk-through and familiarization tours of the facility for new Fire Department and Sheriffs Department personnel.
(4) Emergency Equipment and Inventories The inspector reviewed communications capabilities with support groups and found the equipment acceptable and various items of this equipment (e.g., telephones and the building public address system) were in use daily. Portable public address devices were also available for use as needed and were checked semiannually. Emergency call lists had been revised and updated, as needed, and were available in the control room and in the various emergency cache kits as required. The inspector also verified that emergency equipment, including personal protective equipment and decontamination materials, was available and inventoried semiannually as required by the E-Plan.
(5) Drills The documentation of the drills conducted during the past 2 years was reviewed by the inspector. Through drill scenario and record reviews and personnel interviews, emergency responders were determined to be
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knowledgeable of the proper actions to take in case of an emergency.
Emergency drills were conducted annually and included the participation of off-site support groups every other year as required by the E-Plan. The scenarios written for the drills and the critiques held thereafter were well documented.
The inspector determined that the most recent drill held June 5, 2019, involved adult and pediatric patients with simulated injuries and contamination. The drill was conducted in conjunction with the UCD Medical Center. The drill provided a challenging scenario for the facility and the hospital. It was noted that a critique was held following the drill to identify areas for improvement and staff strengths as well.
It was noted that no drill had been conducted for 2020. The licensee assisted the UCD Medical Center with the Centers annual Radiation Exposure exercise but did not participate (e.g., did not send simulated casualties to the Medical Center, etc.). The licensee plans to hold a drill with the SMFD later in the summer when COVID-19 PHE restrictions are relaxed. The licensee was informed that the issue of holding a drill within the allowed time frame for the current year would be identified as an Unresolved Item (URI). This will be followed during the next operations inspection at the facility (URI 05000607/2020202-02).
(6) Visit to Offsite Support Groups The inspector did not visit any of the offsite support facilities due to the COVID-19 PHE. During this inspection, the licensee indicated that the support groups commitment to assist MNRC during an emergency remained in effect.
c. Conclusion The inspector determined that the licensees emergency preparedness program was conducted in accordance with the facility E-Plan.
9. Follow-up on Previously Identified Item a. Inspection Scope (IP 92701)
The inspector reviewed the licensees actions taken in response to a previously identified IFI concerning Procedure UCD/MNRC-0043-DOC-04, Facility Modification Procedure.
b. Observation and Findings 50-607/2020-201-01 - IFI - Follow-up on the issue of the licensee revising their modification procedure to include a screening process so that minor changes and modifications can be properly documented.
During an inspection in January 2020, the inspector noted that the licensees modification procedure did not mention a process allowed by the regulations
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called screening which provided a method to consider a change which might be rather minor in nature and, therefore, did not require any further review or evaluation. Such a change could then be screened out but the process would provide documentation that the licensee had considered issues involved and had concluded that nothing further was required. The licensee was informed that the issue of revising the modification procedure to include a screening process would be considered an IFI.
During this inspection the inspector reviewed this issue with the licensee. It was noted that the licensee had reviewed their change procedure and had included a section to allow for screening of changes to the facility, procedures, or experiments. If the change were minor, the item or issue could be screened out if the proper justification was provided. The new version of the change procedure was Revision 5. All personnel received training on Revision 5 to the change procedure on June 19, 2020. This issue is considered closed.
c. Conclusion One IFI was reviewed and closed.
10. Exit Interview The inspection scope and results were summarized on June 18, 2020, with the Facility Director, the Associate Director for Reactor Operations, and the RSO. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the findings presented.
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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel H. Bollman Radiography Supervisor and SRO C. Dresser Radiographer, Level III and Reactor Operator Trainee Facility Director and SRO T. Essert Electrical Engineer and SRO B. Mehciz Radiographer Trainee and Technical Assistant D. Reap Radiation Safety Officer, Security Officer, and SRO T. Slattery Radiographer Helper and Processor W. Steingass Associate Director for Reactor Operations, Operations Manager, and SRO S. Warren Radiographer, Level III and Reactor Operator Trainee Other Personnel None INSPECTION PROCEDURE USED IP 69003 Class I Research and Test Reactor Operator Licenses, Requalification, and Medical Examinations IP 69005 Class I Research and Test Reactor Experiments IP 69006 Class I Research and Test Reactor Organization and Operations, and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class I Research and Test Reactor Procedures IP 69009 Class I Research and Test Reactor Fuel Movement IP 69010 Class I Research and Test Reactor Surveillance IP 69011 Class I Research and Test Reactor Emergency Preparedness IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000607/2020202-01 IFI Follow-up on the issue of the licensee clarifying the emergency training given to facility personnel and clearly documenting the training.05000607/2020202-02 URI Follow-up on the issue of the licensee holding a drill within the allowed time frame for the year 2020.
Closed 50-607/2020-201-01 IFI Follow-up on the issue of the licensee revising their modification procedure to include a screening process so that minor changes and modifications can be properly documented.
Attachment
PARTIAL LIST OF ACRONYMS USED ANSI/ANS American National Standards Institute/American Nuclear Society COVID-19 Coronavirus Disease 2019 EH&S Environmental Health and Safety E-Plan Emergency Plan IFI Inspector Follow-up Item IP Inspection Procedure MNRC McClellan Nuclear Research Center MOU Memorandum of Understanding NRC U.S. Nuclear Regulatory Commission NSC Nuclear Safety Committee PHE Public Health Emergency RO Reactor Operator RSO Radiation Safety Officer SAR Safety Analysis Report SMFD Sacramento Metropolitan Fire Department SRO Senior Reactor Operator TSs Technical Specifications UCD University of California-Davis URI Unresolved Item-2-