IR 05000407/2020201

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University of Utah - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000407/2020201 and Notice of Violation - Cover Letter and Enclosure
ML20304A216
Person / Time
Site: University of Utah
Issue date: 05/07/2021
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Sjoden G
Univ of Utah, Salt Lake City
Bassett C, NRR/DANU/UNPO, 240-535-1842
References
Preceding documents:
Download: ML20304A216 (19)


Text

May 7, 2021

SUBJECT:

UNIVERSITY OF UTAH - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000407/2020201 AND NOTICE OF VIOLATION

Dear Dr. Sjoden:

From October 13-23, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at your University of Utah TRIGA Nuclear Reactor Facility. The enclosed report documents the inspection results which were discussed on October 16 and 23, 2020, with you, Dr. Michael Barber, Department Chair of Civil and Environmental Engineering, and members of your staff.

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, 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. The current Enforcement Policy is included on the NRCs Web site at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. 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 and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also 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 enclosures, and your response will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of 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). To the extent possible, your response should not include any personal privacy or proprietary information, so that it can be made available to the Public without redaction.

Should 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, for Philip B. Digitally signed by O'Bryan Philip B. O'Bryan Travis L. 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. 50-407 License No. R-126 Enclosures:

As stated cc: w/enclosure: See next page

University of Utah Docket No. 50-407 cc:

Mayor of Salt Lake City 451 South State Room 306 Salt Lake City, UT 84111 Dr. Andrew S. Weyrich Vice President for Research University of Utah 201 South Presidents Circle, Room 210 Salt Lake City, UT 84112-9011 Frederick A. Monette Director and RSO Environmental Health and Safety 75 S 2000 E, Room 322 University of Utah Salt Lake City, UT 84112 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 Director, Division of Radiation Control Dept. of Environmental Quality 195 North 1950 West P.O. Box 14485 Salt Lake City, UT 84114-4850 Mr. Matthew Lund, Reactor Supervisor Utah Nuclear Engineering Program Joseph Merrill Engineering Building 50 S. Central Campus Drive, Room 1206 Salt Lake City, UT 84112

ML20304A216 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC*

NAME CBassett NParker TTate (POBryan for)

DATE 11/12/2020 11/12/2020 5/7/2021

NOTICE OF VIOLATION University of Utah Docket No. 50-407 University of Utah TRIGA Nuclear Reactor License No. R-126 During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted October 13-23, 2020, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

University of Utah TRIGA Nuclear Reactor technical specifications (TSs) Section 6.1.3.3, Specification 3.1, states, Events requiring the direction of the [Reactor Supervisor include]

Initial startup and approach to power of the day.

Contrary to the above, on September 2, 4, 14, 18, 21, 22, 23, and 24, 2020, and October 9, 2020, the reactor was started up without the Reactor Supervisor being present.

This is a Severity Level IV violation (Section 6.1).

Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.201, Notice of violation, the University of Utah is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, 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, 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, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, 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. 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.

Enclosure 1

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, Protection of Safeguards Information: Performance Requirements.

In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post this Notice within two working days of receipt.

Dated this 7th day of May 2021

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-407 License No.: R-126 Report No.: 05000407/2020201 Licensee: University of Utah Facility: University of Utah TRIGA Nuclear Reactor Location: Salt Lake City, Utah Dates: October 13 - 23, 2020 Inspector: Craig Bassett Approved by: Travis L. 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 2

EXECUTIVE SUMMARY University of Utah University of Utah TRIGA Nuclear Reactor Facility Inspection Report No. 05000407/2020201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the University of Utah (the licensees) 100 kilowatts Class II research reactor safety program, including: (1) organization and staffing; (2) procedures; (3) health physics; (4) design changes; (5) committees, audits and reviews; and, (6) transportation of radioactive material.

The U.S. Nuclear Regulatory Commission (NRC) staff determined that the licensees program was acceptably directed toward the protection of public health and safety, and in compliance with the NRC requirements. However, one violation (VIO) and one unresolved item (URI) were identified.

Organization and Staffing The licensees organizational structure was in compliance with requirements outlined in the technical specifications (TSs).

One VIO was noted for failure to have the Reactor Supervisor (RS) present during initial startup and approach to power during various days in September and October 2020 as required by TS Section 6.1.3.3.

Procedures Facility procedural review, revision, control, and implementation satisfied TS requirements.

Health Physics Surveys were completed and documented appropriately to permit evaluation of the radiation hazards present.

Postings met regulatory requirements.

Personnel dosimetry was worn as required, and doses were well within the licensees procedural action levels and NRC regulatory limits.

Radiation monitoring equipment was maintained and calibrated, as required.

The Radiation Protection and as low as reasonably achievable (ALARA) programs satisfied regulatory requirements.

Training was provided to staff members in the area of radiation protection in accordance with regulatory requirements.

Effluent monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits.

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Design Changes Change reviews were conducted in accordance with the requirements in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments.

One 10 CFR 50.59 change review involving installation of a new reactor console was not completed and would be submitted to the NRC for review prior to resumption of reactor operations.

Committees, Audits and Reviews The Reactor Safety Committee (RSC) met as required.

Audits and reviews were conducted by designated individuals and reviewed by the RSC in accordance with the requirements specified in TS Section 6.2.

Transportation of Radioactive Material The licensee transferred radioactive waste material to the campus Radiation Safety Office (RSO) for disposal as needed.

The RSO would handle any shipments of radioactive material from the facility.

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REPORT DETAILS Summary of Facility Status The University of Utah continued to operate the 100-kilowatts TRIGA Mark I research reactor as needed in support of sample irradiation, reactor operator training, educational demonstrations, preventive maintenance, and operational surveillance testing required by the TSs. While the reactor was not operated during this inspection in preparation for the installation of a new reactor console, it was typically operated one or two days a week at various power levels up to 90 kilowatts.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001, Section 02.01)

The inspector reviewed the following regarding the licensees organization and staffing to ensure that the requirements of Section 6.1 of the TSs were met:

management responsibilities qualifications of facility personnel Utah Nuclear Engineering Program (UNEP) Procedure, P-001, Description of Operations, Revision 1, (UNEP P-001R1), Section 1, Organization and Responsibilities amendment number (No.) 9 to Facility Operating License No. R-126, dated December 12, 2011, which amended the TSs University of Utah TRIGA Reactor (UUTR) annual operating report for the period of July 1, 2018, through June 30, 2019 UUTR annual operating report for the period July 1, 2019, through June 30, 2020 b. Observations and Findings (1) Organization and Qualification Through discussions with licensee representatives, the inspector determined that there were no changes to management responsibilities and the organizational structure at the UUTR facility since the last NRC inspection in the area of radiation protection conducted in May 2018 (NRC Inspection Report No. 50-407/2018-201).

The inspector found that the person who formerly was designated as the Interim Facility Director took a position with a company in another state. A new Facility Director was appointed. Because the former Interim Facility Director was also the RS, an Assistant RS was appointed as well. The inspector reviewed the qualifications of these individuals and determined that the Facility Director met the requirements outlined in American National Standards Institute/American Nuclear Society (ANS/ANSI)-15.4-1988; R1999, Selection and Training of Personnel for Research Reactors as required by TS Section 6.1.4. ANSI/ANS-15.4-1988 did not establish requirements for the position of Assistant RS. It was noted that the-4-

Assistant RS did not meet the qualifications outlined in ANS/ANSI-15.4 -

1988; R1999 for the position of Level 3, RS.

(2) Staffing TS 6.1.3.3, Specification 3.1, states, Events requiring the direction of the RS [include] initial startup and approach to power of the day. Through review of records and logs, and through discussions with licensee personnel, the inspector determined that shift staffing at the UNEP TRIGA Reactor Facility did not meet the requirements stated in Section 6.1.3.3, Specification 3.1 of the TSs. The console operations log indicated that, on September 2, 4, 14, 18, 21, 22, 23, and 24, and October 9, 2020, the Assistant RS was present during reactor startup, not the RS as required.

As noted above, the Assistant RS did not meet the qualifications outlined in ANS/ANSI 15.4 - 1988; R1999 for the position of Level 3, RS. The licensee was informed that failure to have a qualified RS present during initial startup of the reactor on various days in September and October was an VIO of TS 6.1.3.3 (VIO 05000407/2020201-01).

c. Conclusion The inspector determined that the organizational structure was consistent with TS requirements. The inspector noted one VIO for failure to have the RS present during initial startup and approach to power of the day during various days in September and October 2020.

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

The inspector reviewed selected aspects of the following to verify that the licensee complied with the requirements of TS Section 6.4:

records of procedure changes various administrative and radiation protection procedures related logs and records documenting procedure implementation UNEP-035 R4, Audit and Review Program Checklist RSC meeting minutes from December 2018 to the present b. Observations and Findings The inspector noted that the licensee used procedures to conduct operations at the facility as required and the procedures were available for those tasks and items required by the TSs. The inspector determined that substantive changes to the procedures were reviewed and approved by the RSC as required.

Training of personnel on procedures and the applicable changes was acceptable.

In the area of radiation protection, the licensee did not have facility-specific procedures but was developing some for use at the reactor facility. In the interim, reactor personnel made use of the procedures maintained by the university RSO which were contained in the Radiological Procedures and Records [RPR], and were available on-line at the RSO website. Those-5-

procedures were reviewed and approved by the universitys Radiation Safety Committee.

c. Conclusion The inspector determined that the procedural review, revision, control, and implementation satisfied TS requirements.

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

To verify compliance with TS Sections 3.4, 3.7, 4.3, 4.7, 5.4, 6.3, and 6.7, as well as 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, requirements, the inspector reviewed selected aspects of:

radiological signs and postings at the facility personnel dosimetry records for 2018, 2019, and to date in 2020 environmental dosimetry records for 2018, 2019, and to date in 2020 various procedures including: UNEP-020 R13, Monthly Inspection/

Surveillance Checklist; UNEP-023 R5, Annual Maintenance and Calibration of the Area Radiation Monitors (ARMs) and Continuous Air Monitor (CAM);

and, UNEP-032, Liquid Effluent Discharge Authorization various RSO RPR procedures and forms including: RPR No. 50A, Laboratory Evaluation Checklist and Laboratory Evaluation Checklist (cont); RPR No. 50B, Total Contamination Survey; RPR No. 50C, Removable Contamination Survey; RPR No. 50D, Exposure Rate Survey; and, No. 50E, Radionuclide Laboratory Evaluation Report; RSC meeting minutes for the past 2 years which included a quarterly report from the university Radiation Safety Officer Assessment of Radiation Dose from Air Emissions of Radioactive Material, Calendar Year 2019, which was completed by RSO personnel UUTR annual operating reports for the last two reporting periods b. Observations and Findings (1) Surveys The inspector reviewed monthly radiation and contamination surveys of licensee-controlled areas within the UUTR for the past 2 years, which were conducted by campus RSO personnel. The inspector also reviewed the records documenting the monthly general area radiation and contamination surveys of the reactor room and support areas which were completed by licensee personnel from 2019 to present. The inspector determined that the results of all these surveys were documented, reviewed, and evaluated, as required, and corrective actions were taken when readings or contamination results exceeded set action levels.

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(2) Postings and Notices During tours of the facility, the inspector observed that caution signs and postings in place and controls established for the controlled areas were acceptable for the hazards involving radiation, high radiation, and contamination, and were posted as required by 10 CFR Part 20, Subpart J, Precautionary Procedures. The inspector confirmed that personnel complied with the signs, postings, and controls.

Copies of notices to workers were posted in various areas in the facility.

Radiological signs were posted at the entrances to controlled areas. The inspector verified that the copies of NRC Form 3, Notice to Employees, were posted at the facility as required by 10 CFR 19.11, Posting of notices to workers, were the current version. During the inspection the licensee also posted signs to remind everyone of the Safety Conscious Work Environment at the facility. All UUTR staff were aware that they could raise safety concerns without fear of retaliation.

(3) Dosimetry The inspector determined that the licensee used ion chamber dosimeters for whole body monitoring of radiation exposure. The licensee also used thermoluminescent (TLD) finger rings for monitoring radiation exposure of the extremities. The dosimetry was supplied and processed by a National Voluntary Laboratory Accreditation Program accredited vendor. Through direct observation the inspector determined that dosimetry use by facility personnel was in accordance with the university radiation protection requirements. Examination of the dosimetry results, indicating radiological exposures at the facility for the past 2 years, showed that all occupational doses were within 10 CFR Part 20 limits.

(4) Radiation Monitoring Equipment Use and Calibration The use and calibration of radiation monitoring equipment was reviewed by the inspector. Portable survey meters and friskers were calibrated by campus RSO personnel. Fixed radiation detectors and the CAM were calibrated by licensee staff personnel. The inspector reviewed calibration records maintained by the RSO and licensee personnel. Through this review the inspector determined that records were maintained as required and that calibration frequencies met the requirements established in the applicable surveillance procedures. Through observations of activities at the UUTR facility, the inspector determined that the monitoring equipment was used in accordance with procedure.

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(5) Radiation Protection Program and ALARA Policy The licensees Radiation Protection Program was established through various University of Utah campus documents including: (1) the RSO Radiological Procedures and Records; (2) The University of Utah Radiation Safety Policy Manual; (3) The University of Utah Radiation Protection Program; and (4) RPR No. 80, Utah Nuclear Engineering Program (UNEP) Research (TRIGA) Reactor (UUTR). The program stated that all personnel who had unescorted access to work in a radiation area or who worked with radioactive material were required to receive training in radiation protection policies, principles, procedures, and requirements prior to starting work. The inspector also confirmed that the university Radiation Protection Program was reviewed annually, as required. The ALARA Policy was also outlined and established in the manuals and RPR mentioned above. The ALARA program provided appropriate guidance for keeping doses ALARA and was consistent with the requirements in 10 CFR Part 20.

(6) Radiation Worker Training As noted above, the inspector determined that all university personnel who worked in radiation areas or handled radioactive material, including licensee staff, were required to receive training in radiation protection.

Completion of the required training by facility personnel was verified by RSO personnel, as well as by the Reactor Administrator and/or the RS.

Upon completion of the course, reactor staff members were issued a dosimeter and allowed to work under the direction of a Responsible User.

The inspector reviewed documentation of the training provided to selected licensee staff members, including the certificates of completion.

The documents indicated that all current staff members received the required training. The inspector determined that the personnel training program satisfied requirements in 10 CFR 19.12, Instruction to workers.

The content and periodicity of training were also acceptable and in accordance with the regulations.

(7) Environmental and Effluent Monitoring The inspector reviewed the ARMs and CAM calibration records. The ARMs and CAM were calibrated annually by licensee staff in accordance with procedures. The monthly setpoint and high radiation warning verification records for the monitoring equipment were also reviewed.

Corrective actions, including recalibration, were completed if the setpoint values were exceeded.

The inspector determined that gaseous releases continued to be monitored as required. The releases were calculated by the RSO according to established procedure, using the Environmental Protection Agency COMPLY code. The dose rate to the public, as a result of the gaseous releases, was well below the dose constraint of 10 millirem per year specified in 10 CFR 20.1101, Radiation protection programs,

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paragraph (d). The inspector noted that airborne concentrations of gaseous releases were also calculated by the licensee. These calculations showed that gaseous releases were well within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table 2, and TS limits. The results were appropriately documented in the facility annual reports, as required.

The inspector verified that there were no liquid releases from the facility to the sanitary sewer within the past 2 years. It was noted that no solid waste was transferred from the facility to the campus RSO during the past 2 years.

Onsite and off-site gamma radiation monitoring was completed using environmental TLDs in accordance with the applicable university procedures. The data indicated that there were no unusual dose rates in the areas surrounding the UUTR facility and that there were no measurable doses above any regulatory limits. These results were also appropriately reported in the facility annual reports.

(8) Facility Tours The inspector toured the control room, reactor room, and selected support laboratories and offices. Control of radioactive material and control of access to radiation and high radiation areas were acceptable and in accordance with the regulations. As noted earlier, the postings and signs for these areas were appropriate. No problems were noted.

c. Conclusion Based on the observations made and the records reviewed, the inspector determined that the Radiation Protection Program that was implemented by the licensee satisfied regulatory requirements.

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

The inspector reviewed the following to verify compliance with 10 CFR 50.59 and TS Section 6.2:

RSC meeting minutes from December 2018 to the present UNEP Job-Aid 002 R1, 10 CFR 50.59 Screening Form UNEP-022 R4, Maintenance Log UUTR Annual Operating Reports for the last two reporting periods b. Observations and Findings The inspector noted that one review related to control rod drives and two reviews related to nuclear instrumentation were conducted since the last inspection. The screening reviews for these projects were completed by the licensee to verify that-9-

10 CFR 50.59 evaluations were not needed. The inspector reviewed the screening reviews and noted that they appeared to be adequate.

The inspector determined that the licensee was in the process of conducting a 10 CFR 50.59 review related to the installation of a new reactor console. The review was not finalized at the time of the inspection. The inspector informed the licensee that the review needed to be complete to determine if a full evaluation was required. The inspector requested a copy of the 10 CFR 50.59 review, along with all the associated documentation, prior to the resumption of operations following the installation of the new reactor console. The licensee committed to maintaining the UUTR shutdown until all 10 CFR 50.59 and related operations procedures are updated and agreed to submit the material to the NRC for review.

This issue is an URI and will be reviewed further (URI 05000407/2020201-02).

c. Conclusion The inspector determined that the licensees design change control program was implemented as required. One 10 CFR 50.59 change review involving installation of a new reactor console was not complete and would be submitted to the NRC for review prior to resumption of reactor operations.

5. Committees, Audits and Reviews a. Inspection Scope (IP 69001, Section 02.09)

The inspector reviewed the following to ensure that the review and audit requirements in TS Section 6.2 were met:

RSC meeting minutes from December 2018 to the present radiation safety and ALARA audits completed during the past year and licensee responses to the safety reviews and audits form UNEP-035 R4, Audit and Review Program Checklist UUTR annual operating reports for the last two reporting periods b. Observations and Findings The inspector verified that the RSC met at least annually as required by the TSs.

It was noted that a subcommittee (or the full committee) held quarterly meetings in addition to the TS-required annual meetings. The inspector reviewed the RSC meetings minutes and determined that the minutes contained, among other documents, quarterly or monthly reports from the Reactor Director, the RS, and the university Radiation Safety Officer. Review of the committee meeting minutes indicated that the RSC completed the required reviews as stipulated in the TSs.

Since the last inspection, all required audits of reactor facility activities and reviews of programs, procedures, equipment, and proposed tests or experiments were completed and documented as required. The inspector determined that the audits and the associated findings were appropriately detailed and that the licensee responded and took corrective actions as needed. Additionally, the annual reviews of the Radiation Protection Program and the Emergency Plan, as

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well as the biennial review of the Security Plan, were conducted and appropriately documented.

c. Conclusion The inspector determined the RSC was meeting at the required frequency. Audits and reviews were conducted as required and reviewed by the RSC in accordance with the requirements specified in TS Section 6.2.

6. Transportation of Radioactive Material a. Inspection Scope (IP 86740)

The inspector reviewed selected aspects of:

UNEP-027 R6, TRIGA Reactor Irradiation Request and Performance RPR Procedures including: No. 13, Radioisotope Acquisition and Disposition; No. 14, Shipment of Limited Quantity of Radioisotopes; and No. 55, Transportation of Radioactive Materials Various forms including: Form RPR 13A, Radioisotope Package Arrival Report; Form RPR 13B, Radioisotope Receipt and Verification; and, Form RPR 13C, Radioisotope Disposition Record b. Observations and Findings The inspector determined that records indicated that UUTR radioactive waste designated for disposal was transferred from the reactor facility to the University of Utahs broad scope license, Utah Department of Environmental Quality, License No. 1800001, in accordance with RSO requirements. The inspector verified that this process was still followed.

The inspector noted that none of the licensee personnel had the current training required to ship radioactive material as required by the Department of Transportation. Therefore, in any instances involving the shipment of radioactive material, the paperwork and shipments would be completed by qualified RSO personnel.

c. Conclusion The inspector determined that the licensee transferred radioactive waste material to the campus RSO as needed. The RSO would handle any shipments of radioactive material from the facility.

7. Exit Meeting Summary The inspection scope and results were summarized on October 16 and 23, 2020, with university management and facility staff. The inspector discussed the findings for each area reviewed. The licensee did not identify any of the material provided to or reviewed by the inspector as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel A. Allison Student Operator Trainee D. Feist Lab Analyst and Student Operator Trainee A. Foley Senior Reactor Operator L. Forster Student Operator Trainee E. Goodell Student Operator Trainee C. Olson Student Operator Trainee S. Pappas Senior Reactor Operator and Assistant Reactor Supervisor B. Saenz Reactor Operator UNEP Director and Reactor Administrator V. Wang Research Scientist and Operator Trainee A. Weyrich Vice President of Research Other Personnel M. Barber Department Chair of Civil and Environmental Engineering, College of Engineering, University of Utah D. Dolan Health Physicist, Radiation Safety Office, University of Utah INSPECTION PROCEDURE (IP) USED IP 69001: Class II Non-Power Reactors IP 86740: Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000407/2020201-01 VIO Failure to have the RS present during initial startup and approach to power of the day during various days in September and October of 2020.05000407/2020201-02 URI Review the licensees completed 10 CFR 50.59 screening and/or evaluation of the installation of a new reactor console.

Closed None PARTIAL LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ALARA As Low As Reasonably Achievable ARMs Area Radiation Monitors CAM Continuous Air Monitor Attachment

IP Inspection Procedure No. Number NRC U.S. Nuclear Regulatory Commission RPR Radiological Procedures and Records RS Reactor Supervisor RSC Reactor Safety Committee RSO Radiation Safety Office TLD Thermoluminescent dosimeter TSs Technical Specifications UNEP Utah Nuclear Engineering Program URI Unresolved Item UUTR University of Utah TRIGA Reactor VIO Violation 2