IR 05000186/2020201

University of Missouri-Columbia - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000186/2020-201 - Cover Letter and Enclosure

ML20168A846
Person / Time
Site:	University of Missouri-Columbia
Issue date:	07/10/2020
From:	Travis Tate NRC/NRR/DANU/UNPO
To:	Robertson J Univ of Missouri - Columbia
Bassett C, NRR/DANU/UNPO, 240-535-1842
References
IR 2020201
Download: ML20168A846 (21)

Text

July 10, 2020

SUBJECT:

UNIVERSITY OF MISSOURI-COLUMBIA - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000186/2020-201

Dear Dr. Robertson:

From June 1-4, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a routine, announced inspection at the University of Missouri-Columbia Research Reactor facility.

The enclosed report documents the inspection results discussed on June 4, 2020, with you; Mr. Les Foyto, Associate Director, Reactor and Facilities Operations; Mr. D. Doenges, Health Physics and Safety Manager; and others on your staff.

The inspection examined activities conducted under your license as they relate to public health and safety to ensure compliance with the Commissions rules and regulations and with the conditions of your license. The inspector reviewed selected procedures and representative records, observed various activities, and interviewed personnel. Based on the results of this inspection, no findings of non-compliance were identified. No response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). 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 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. 50-186 License No. R-103 Enclosure:

As stated cc: See next page

University of Missouri-Columbia Docket No. 50-186 cc:

Les Foyto, Associate Director Reactor and Facilities Operations University of Missouri - Columbia Research Reactor Center 1513 Research Park Drive Columbia, MO 65211 Homeland Security Coordinator Missouri Office of Homeland Security P.O. Box 749 Jefferson City, MO 65102 Planner, Dept. of Health and Senior Services Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102 Deputy Director for Policy Department of Natural Resources 1101 Riverside Drive Fourth Floor East Jefferson City, MO 65101 A-95 Coordinator Commissioners Office Office of Administration P.O. Box 809 State Capitol Building, Room 125 Jefferson City, MO 65101 Planning Coordinator Missouri Department of Natural Resources 1101 Riverside Drive Jefferson City, MO 65101 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept. of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

ML20168A846 *concurred via e-mail NRC-002 OFFICE NRR/DANU/UNPO* NRR/DANU/UNPO/LA* NRR/DANU/UNPO/BC*

NAME CBassett NParker TTate DATE 7/10/2020 6/23/2020 7/10/2020

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-186 License No.: R-103 Report No.: 05000186/2020-201 Licensee: The Curators of the University of Missouri Facility: University of Missouri-Columbia Research Reactor Location: Columbia, Missouri Dates: June 1-4, 2020 Inspector: Craig H. 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

EXECUTIVE SUMMARY The Curators of the University of Missouri University of Missouri-Columbia Research Reactor Inspection Report No. 05000186/2020-201 The primary focus of this routine, announced inspection included the on-site review of selected aspects of the University of Missouri-Columbia Research Reactor (MURR) facility safety program, including: (1) effluent and environmental monitoring; (2) review and audit and design change functions; (3) procedures; (4) radiation protection; and (5) transportation. Various U.S.

Nuclear Regulatory Commission (NRC) previously identified items were also reviewed. The NRC staff determined the licensees programs were acceptably directed toward the protection of the public health and safety and in compliance with NRC requirements.

Effluent and Environmental Monitoring

• Effluent and environmental monitoring satisfied license and regulatory requirements.

• Releases were within the specified regulatory and technical specification (TS) limits.

Review and Audit and Design Change Functions

• Review, oversight, and audit functions required by the TSs were acceptably completed by the Reactor Advisory Committee (RAC).

• Changes to the facility were evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.59, Changes, tests and experiments, and were reviewed and approved by the RAC as required.

Procedures

• The procedure review, revision, control, and implementation program satisfied TS requirements.

• Procedure compliance was acceptable.

Radiation Protection

• Surveys were completed and documented acceptably.

• Postings met regulatory requirements.

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

• Radiation monitoring equipment was maintained and calibrated as required.

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• Radiation protection training was provided to facility personnel.

Transportation of Radioactive Material

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

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REPORT DETAILS Summary of Facility Status MURR continued to operate in support of isotope production, silicon irradiation, reactor operator training, and various types of research. During the inspection, the reactor operated continuously, following the weekly maintenance shutdown, to support laboratory experiments and product irradiation.

1. Effluent and Environmental Monitoring a. Inspection Scope (Inspection Procedure (IP) 69004)

The inspector reviewed the applicable licensee TS requirements for effluents and environmental monitoring and the following procedures and reports to verify compliance with 10 CFR Part 20, Standards for Protection against Radiation:

• quarterly reports of environmental thermoluminescence dosimeter results

• memo to file, 2019 Dose to Individual Members of the Public

• quarterly environmental dosimetry results for 2019 and to date in 2020

• results of the analyses of environmental vegetation, soil, and water samples

• December 2019 ALARA [As Low As Reasonably Achievable] review for effluents

• selected monthly effluent ALARA environmental review summaries for 2019 and to date in 2020

• liquid batch release review forms for 2019 associated with the monthly effluent ALARA environmental review summaries

• University of Missouri-Columbia Research Reactor, Reactor Operations Annual Report, January 1, 2019 through December 31, 2019, submitted to the NRC on February 19, 2020

• Technical Specifications for The University of Missouri Research Reactor, contained in Appendix A as Amendment Number 39, dated May 26, 2020, to Renewed Facility Operating License No. R-103 b. Observations and Findings (1) Gaseous and Liquid Releases The inspector reviewed the annual report and various records documenting liquid and gaseous releases to the environment. The liquid releases from the facility to the sanitary sewer continued to be monitored as required, were acceptably analyzed, and were documented in the annual reports. The inspector reviewed the analyses of the liquid that were released and noted that the releases were within the limits specified in 10 CFR Part 20, Appendix B, Table 3. The inspector determined that gaseous releases continued to be monitored as required, were acceptably analyzed, and were documented in the annual operating reports. Airborne concentrations of gaseous releases were noted to be within the concentration limits stipulated in 10 CFR Part 20, Appendix B, Table 2 and TS 3.7.b.

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The licensee used COMPLY v1.6, an Environmental Protection Agency computer code, to calculate the highest dose a member of the public could receive in an unrestricted area due to gaseous releases. According to the licensees calculations, the highest dose that could be received by a member of the public as a result of gaseous emissions from facility operations was determined to be 1.1 millirem per year (mrem/yr) for 2018 and 1.42 mrem/yr for 2019. These radiation doses were well below the 10 mrem/yr dose constraint stipulated in 10 CFR 20.1101, Radiation protection programs, paragraph (d).

(2) Environmental Soil, Water, and Vegetation Samples The inspector reviewed the annual report and the applicable records documenting the results of the environmental soil, water, and vegetation samples that were collected, prepared, and analyzed during 2019 and to date in 2020. The inspector noted that environmental samples were taken as required and provided further verification that facility effluents are not measurably impacting the environment as required by TS 3.7.c.

(3) Environmental Radiation Monitoring Environmental gamma radiation monitoring was conducted using dosimetry badges in accordance with the applicable procedures. The data indicated that radiation doses were consistent with background levels. As a result, there were no radiation doses in uncontrolled areas from operation of the reactor that would result in a member of the public exceeding the limits in 10 CFR Part 20, Subpart D.

c. Conclusion The inspector determined the licensees effluent and environmental monitoring satisfied license and regulatory requirements and releases were within the specified regulatory and TS limits. Airborne and liquid releases were monitored, collected, and analyzed in accordance with procedures and required programs.

Radiation doses were appropriately monitored, and results were maintained.

2. Review and Audit and Design Change Functions a. Inspection Scope (IP 69007)

To verify compliance with 10 CFR 50.59 and TS requirements for review and audit and design change functions, the inspector reviewed selected aspects of the licensees change program, including:

• select committee and subcommittee meeting minutes from April 2019 to the present, including: RAC, Reactor Safety Subcommittee, Reactor Safety Procedure Review Subcommittee, Isotope Use Subcommittee, and Isotope Use Procedure Review Subcommittee

• memo to file, Documentation of the Annual Audit of Facility Operations for calendar year [CY] 2019 as required by Technical Specification 6.2.e.(1)i, dated February 18, 2020-5-

• memo to file, Documentation of Annual Review of Operator Requalification Program for calendar year 2019 as required by Section 3.1 of the Program, dated January 30, 2020

• memo to file, Documentation of Annual Audit of Corrective Action Items Associated with Reactor Safety for calendar year 2019 as required by Technical Specification 6.2.e.(1)iii, dated February 3, 2020

• memo to file, Documentation of Annual Review of Emergency Plan Implementing Procedures for calendar year 2019 as required by administrative Technical Specification 6.4.c, dated February 3, 2020

• various 50.59 Screen forms completed by the licensee concerning new or established Reactor License Projects and changes to procedures

• most recent version of the MURR TSs

• latest MURR Annual Report for CY 2019 b. Observations and Findings The inspector determined the composition and meeting frequency of the RAC and subcommittees satisfied the requirements of TS 6.2.b. The meeting minutes demonstrated that the RAC and subcommittees provided the review functions required by TS 6.2.a. Furthermore, based on the review of meeting minutes for the past year, the inspector found that the RAC and subcommittees provided appropriate guidance and direction for reactor operations, and ensured acceptable use and oversight of the reactor.

The inspector determined audits of facility operations, reactor operator requalification, corrective actions, and emergency planning were performed, within the specified periodicity as required by TS 6.2.e. Audit results were assessed by the responsible manager and any actions required as a result of the audit findings were placed in the MURR Corrective Action Program. While not required by TS, the inspector noted that internal audits are also conducted in other program areas by the facility.

The inspector reviewed recently completed 50.59 Screen forms related to selected new or established Reactor License Projects and changes to procedures. None of the screenings resulted in the completion of a more extensive evaluation because the projects screened out meaning that they did not meet the criteria for further review. Based on the forms reviewed, the inspector determined the facility design change program was implemented in accordance with the regulations and the applicable licensee procedures. As noted above, the inspector also verified that the RAC reviewed the proposed change in accordance with TS 6.2.a.(1).

c. Conclusion The inspector determined the review, oversight, and audit functions required by the TS were acceptably completed by the RAC and subcommittees. Changes to the facility, programs, and procedures were evaluated using the criteria specified in 10 CFR 50.59 and were reviewed and approved by the RAC as required.

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3. Procedures a. Inspection Scope (IP 69008)

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

• various reports related to procedure revisions and required reviews

• select procedures from MURR Health Physics Control of RAM & Support Procedures Manual

• select procedures from MURR Health Physics Instrumentation & Reactor Chemistry Procedures Manual

• memo to file, Documentation of Annual Review of Reactor Operations Procedures for calendar year 2019 as required by administrative Technical Specification 6.4.c

• instrument Calibration Procedure IC-HP-371, Calibration - Protean ASC-950 Swipe Counter, Revision 0, date issued July 15, 2019

• MURR Project RL-92, Project Application for Utilization of Radioactive Material/Radiation Under MURR Reactor License, Revision 0, date issued January 29, 2018

• MURR Policy POL-03, Radiation Protection Program, Revision 19, date issued October 16, 2019

• most recent version of the MURR TSs

• latest MURR Annual Report for CY 2019 b. Observations and Findings The inspector reviewed selected facility health physics (HP) and other procedures and the processes employed to change, review, and approve procedures. The inspector noted that required procedures were in effect as required by TS 6.4.a. The procedures were changed, reviewed, and approved in accordance with local processes and procedures. Radiological control and shipping procedures were in effect as required by TS 6.4.b. Annual procedure reviews were conducted by management as required by TS 6.4.c. All procedures reviewed by the inspector were reviewed and approved by the licensee as required. During the inspection, the inspector observed facility personnel using procedures to complete tasks. The activities and operations observed by the inspector were completed in accordance with the applicable procedures.

c. Conclusion The inspector determined the procedure review, revision, control, and implementation satisfied TS requirements. Procedural compliance was acceptable.

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4. Radiation Protection a. Inspection Scope (IP 69012)

To verify compliance with 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, TS requirements, and HP procedures, the inspector reviewed selected aspects of the licensees program, including:

• 2019/2020 Radiation Work Permit (RWP) log sheets

• 2019 and 2020 Monthly ALARA reviews for personnel

• MURR personnel dosimetry records for 2018, 2019, and to date in 2020

• select records, FM-17, Radiation Work Permit

• select records, FM-62, Radiation Instrument Certificate of Calibration

• completed Internal Audit Form, Radiation Protection Program: Personnel Protection for the period July 2018 through December 2019

• MURR Administrative Policy, POL-3, MURR Radiation Protection Program, Revision 19, issued October 16, 2019

• AP-HP-123, Visitor Dosimetry - Reception Desk, Revision 14, dated March 20, 2019

• completed RM-HP-101, Stack Monitor Preventative Maintenance Check Sheet, for June and December 2019

• completed IC-HP Forms, Impex Stack Monitor Calibration Datasheets, for September 2019 and March 2020

• select records, 2019/2020 MURR Initial/Annual/Renewal facility radiation worker training

• select records pertaining to radiation and contamination surveys by area/room for 2019 and to date in 2020

• most recent version of the MURR TSs

• latest MURR Annual Report for CY 2019 b. Observations and Findings (1) Surveys The inspector reviewed radiation and contamination surveys of select areas, rooms, and labs in the MURR facility from 2019 to the present. The results were documented on the appropriate forms and evaluated as required.

Comments were provided if readings were higher than expected and corrective actions were taken when readings or results exceeded set action levels. Any contamination detected in concentrations above established action levels was noted, access to the areas was limited, and the area or item was decontaminated. The inspector determined that surveys were completed as required by procedures and in accordance with the requirements in 10 CFR Part 20, Subpart F.

During the inspection, the inspector accompanied a facility HP technician while he completed a monthly radiation and contamination survey of an active laboratory. The inspector, using an NRC-supplied meter, conducted a radiation survey alongside the HP technician. The HP technician completed-8-

the survey using appropriate survey techniques. The radiation readings found by the inspector were comparable to those found by the HP technician.

No anomalies were noted.

(2) Postings and Notices During tours of the facility, the inspector observed that signage, postings, and labels were used in accordance with requirements in 10 CFR Part 20, Subpart J. Radioactive material storage areas were noted to be properly posted. The inspector noted current copies of survey maps were posted at the entrances to controlled areas. Copies of notices to workers were posted in the facility, including a copy of the most recent revision of NRC Form 3, Notice to Employees, as required by 10 CFR 19.11, Posting of notices to workers.

(3) Dosimetry The inspector observed the use of dosimetry badges for whole body monitoring and finger ring dosimetry for extremity monitoring. The dosimetry was processed monthly by a National Voluntary Laboratory Accreditation Program accredited vendor, Mirion Technologies, (GDS) Inc. Examination of the dosimetry records for the past two years, and to date in 2020, showed that the highest occupational doses were well below 10 CFR Part 20, Subpart C limits of 5,000 mrem/yr total effective dose equivalent. Extremity doses were also below the regulatory limit. The inspector also verified that annual dosimetry reports (i.e. NRC Form 5), as required by 10 CFR 19.13, Notifications and reports to individuals, were provided to each employee who had received exposure greater than 100 mrem at the facility during 2019.

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

(4) Radiation Monitoring Equipment During the inspection, the inspector observed storage and use of portable survey instrumentation at the facility. The inspector reviewed the records of selected meters, detectors, area radiation monitors, and stack air monitoring equipment. Annual calibration and monthly source check frequency of the portable detectors and fixed meters and monitors were consistent with manufacturers recommendations and appropriate calibration records were maintained. The inspector verified that radiation monitoring equipment was maintained as required by TS 4.7.a and TS 4.7.b. The inspector determined portable survey meters were maintained as required by 10 CFR Part 20, Subpart F.

(5) Radiation Protection Training The inspector reviewed documentation of the initial and annual refresher training for licensee staff personnel. The course documentation consisted of training material and an evaluation (quiz). Record of training completion was-9-

maintained in individual training records stored in Document Control.

Through a review of records, the inspector verified that training was provided to new personnel as well as refresher training to personnel who were at the MURR facility for over a year. The content of the training program satisfied the requirements in 10 CFR 19.12, Instruction to workers.

(6) Radiation Protection Program The inspector determined that the radiation protection program was established in MURR Administrative Policy, POL-3, Revision 19, MURR Radiation Protection Program, dated October 16, 2019, as well as through the facility procedures. The programs contained instructions concerning organization, control of radioactive material and radiation sources, training, monitoring, personnel responsibilities, and audits. The inspector verified that the facility conducted an annual audit to review program content and implementation as required by 10 CFR 20.1101(c).

(7) ALARA Program A program for maintaining radiation exposure to personnel ALARA was outlined and established in MURR Administrative Policy, POL-3. MURR implementation of the ALARA program is well organized and established through various HP procedures that discuss and set expectations for radiation safety culture. The program continued to produce dose and effluent reduction results through established ALARA goals and use of performance indicators. The inspector noted that MURR conducted monthly reviews and, through established investigation levels, implemented administrative controls to further reduce individual doses or effluents. The inspector found that implementation of the ALARA program is consistent with the requirements in 10 CFR 20.1101(b).

(8) Radiation Work Permit Program The inspector reviewed the RWP program in place to control operations that could result in radiation safety hazards. The inspector reviewed a sample of the over 200 RWPs opened for use from 2019 to the present, including one that was in use during the inspection (i.e. RWP #20-069, Loading of Fuel Cask). The inspector noted that the instructions specified in procedures and those on the associated RWP form were followed. Review by management and HP personnel were completed, as required. The controls (e.g.

precautions, personal protective equipment, radiation monitoring) specified in the RWP were appropriate and applicable for the type of work being done and the area being accessed. A good practice was noted concerning the establishment of a dose goal for the work covered by the RWP. This encouraged facility personnel to be aware of, and limit, their exposure.

c. Conclusion The inspector determined surveys were completed and documented acceptably.

Postings met regulatory requirements. Personnel dosimetry was worn as required and radiation doses were within regulatory limits. Radiation monitoring

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equipment was maintained and calibrated as required. Radiation protection training was provided to facility personnel.

5. Transportation a. Inspection Scope (IP 86740)

To verify compliance with the regulations in 10 CFR and 49 CFR, and procedural requirements for transferring or shipping licensed radioactive material, the inspector reviewed selected aspects of the licensees program, including:

• selected records of radioactive material shipments made during 2019 and to date in 2020

• selected quality assurance Type B shipping procedures, MURR Type program material specification sheet, Type B shipping forms, record and report forms

• completed Internal Audit Form, Type B Quality Assurance Program Audit for June 1, 2018, through December 31, 2019

• memo to file, Documentation of Annual Audit of the Shipping Quality Assurance Program for Type B Shipping Casks - Hazardous Waste for calendar year 2019

• records of licensee employee Department of Transportation/International Air Transportation Administration shipping training b. Observations and Findings During the inspection, the inspector toured shipping and receiving areas and observed the preparation of several packages of Lutetium-177 for shipment. The inspector also reviewed selected records of various types of radioactive material shipments for 2019 and to date in 2020. The inspector verified that the licensee maintained on file copies of consignees licenses to possess radioactive material as required. The licensee verified consignee information (i.e., possession of a license to receive radioactive materials, address, and contact information) prior to initiating a shipment.

Based on observations of packages prepared for shipment during the inspection and review of selected past records, the inspector determined that: 1) shipping papers were completed as required by Subpart C of 49 CFR 172; 2) packages were appropriately marked as required by Subpart D of 49 CFR 172; 3) packages were appropriately labeled as required by Subpart E of 49 CFR 172; 4) conveyances were placarded when required by Subpart F of 49 CFR 172; 5) radionuclides and mixtures of radionuclides were appropriately determined and identified as required by 49 CFR 173.433; and, 6) surveys were performed to ensure compliance with limits as required by 49 CFR 173.441 and 49 CFR 173.443. Additionally, the inspector determined the licensee was appropriately identifying and quantifying the radioisotopes and selected the proper packaging for the materials transported.

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The inspector noted that staff members had received general and function-specific training every two years and were certified for shipping radioactive material, as required by 49 CFR 172, Subpart H.

c. Conclusion The inspector determined radioactive material was shipped in accordance with the applicable regulations.

6. Follow-up (on Previously Identified Items)

a. Inspection Scope (IP 92701)

The inspector reviewed the licensees actions taken in response to previously identified issues including three Violations (VIOs) and an Unresolved Item (URI).

b. Observations and Findings (1) 50-186/2014-201-01 - VIO - Failure to control and post a high radiation area as required (Closed).

During an inspection in March 2014, an inspector accompanied an HP technician during completion of a radiation and contamination survey of the laboratory building basement area. The survey was conducted appropriately.

The following day, the inspector conducted an independent radiation survey of the laboratory building basement general area as well. Based on the results of this survey, an unexpected high radiation reading was identified in a corner of the basement. A tray was found to have a radiation dose reading of approximately 1,800 mrem/hour on contact and approximately 98 mrem/hour at a distance of 30 centimeters. The area was not posted or controlled as a high radiation area as required by 10 CFR 20.1601, Control of access to high radiation areas, and 20.1902(b) Posting of high radiation areas.

Therefore, the licensee was issued a VIO.

During this inspection, the inspector reviewed this issue with the licensee. It was noted that the licensee investigated the incident and determined the root cause of the problem. As a result of the investigation, the licensee took various corrective actions including re-training the entire HP staff regarding the need to perform adequate radiation surveys. They also developed a procedure for tagging radioactive material destined for storage or re-use which complimented the existing procedure associated with tagging waste.

Additionally, based on the physical space where the item was discovered in the corner of the basement, it was determined that no substantial potential existed for exposures in excess of the applicable limits in 10 CFR 20.1001 - 20.2401. This issue is considered closed.

(2) 50-186/2016-202-01 - VIO - Failure to request a TS amendment as required by 10 CFR 50.59 (Closed).

During an inspection in March 2016, the inspector found that the licensee conducted an experiment without obtaining a license amendment when a TS

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change was required. Specifically, the experiment involved the production of iodine-131 radiochemical sodium iodine solution and TS changes were needed to impose controls necessary to allow irradiation and processing of non-fueled experiments to produce iodine-131. Failure to obtain a license amendment was determined to be a VIO.

As documented in NRC Inspection Report (IR) 50-186/2016-202, an inspector determined that the licensee identified the root cause of the problem and took appropriate corrective actions as a result. The inspector also indicated that the issue was identified as having low safety significance due to the circumstance surrounding the problem. (Refer to IR 50-186/2016-202 for further details.) During this inspection, the inspector reviewed the actions taken by the licensee (i.e., applying for and obtaining a license amendment) and found them to be appropriate and effective. This issue is considered closed.

(3) 50-186/2016-202-02 - URI - Follow-up on the licensees actions involving failure to comply with the Certificate of Compliance for the Type B shipping cask Safkeg-HS (Closed).

During the inspection noted in Paragraph (2) above, an inspector also reviewed a letter dated March 4, 2016, in which the licensee had submitted a written report in accordance with 10 CFR 71.1, Communications and records, as required by 10 CFR 71.95, Reports, paragraph (b) regarding conditions in the certificate of compliance (COC) that were not met during shipment of shipping cask Safkeg-HS 3977A, USA/9338/B(U)-96.

Specifically, contrary to Section 5(b)(2) of the COC, mixtures of nuclides were shipped where the sum of proportionate amounts of each nuclide with respect to quantities shown in Section 5(b)(2)(i) Table 1 exceeded unity. This issue was identified as an URI to allow additional time for NRC staff to review this reported event.

During this inspection the inspector reviewed this issue and the actions taken by the licensee to resolve the problem. It was noted that the licensee had reviewed the issue and determined that the root cause of the problem was that no one person at MURR was assigned responsibility to maintain a document, known as Amendment 7, up to date with the appropriate information. Amendment 7 is a spreadsheet that is used as a reference to ensure that the appropriate activity limits for each isotope are listed based on all current COCs available for the various casks used for shipments.

Amendment 7, which is critical for confirmation of activities for shipping purposes, was found to be in error and these had not been corrected. As part of the corrective actions for this issue, the ownership of the document, Amendment 7, was assigned to the Shipping Manager. The Shipping Manager is responsible to ensure that Amendment 7 is correct and kept current.

After a licensee evaluation of Amendment 7, which indicated that some nuclides listed values were in error, corrections were made, and a program was established to routinely check the document and ensure that it was up-to-date for each COC involved. The corrections were then verified by an

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appropriate independent person. The inspector found reviews and updates of Amendment 7 have continued and any needed changes have been made.

No problems have been noted with respect to shipments involving shipping casks and their respective COC limits since the corrections were made. This issue is considered closed.

(4) 50-186/2017-202-01 - VIO - Failure to meet operability requirements of TS 3.10, Iodine-131 Processing Hot Cell, related to charcoal filter bank efficiency (TS 3.10.d) (Closed).

On February 17, 2017, the licensee submitted a licensee event report (LER)

describing an event which occurred on February 3, 2017. The report documented that the exhaust ventilation stack effluents from an iodine-131 process the day prior exceeded the maximum controlled instantaneous release concentration limit for particulates and halogens with half-lives greater than 8 days by 7 percent for idione-131, as specified in TS 3.7.b. The licensee stated that, based on analysis, the maximum hypothetical dose received by any member of the public for this event would be 0.0005 mrem or less than 0.001 percent of the limits specified by 10 CFR 20.1301, Dose limits for individual members of the public, paragraph (a)(1).

On May 16, 2017, the licensee submitted a supplement to the LER concerning the February 3, 2017, event. In this supplement, the licensee stated that continued investigations into this event identified that the root cause was installation of deficient filters that contained substandard quality media and had a significant potential for internal filter bypass. The licensee stated that the combination of substandard filter media and potential flow bypass in the filters resulted in the iodine processing hot cell charcoal filter banks being inoperable during the duration of the release. TS 3.10.d states, At least three (3) charcoal filter banks each having an efficiency of 99 % or greater shall be operable when processing iodine-131 in the iodine-131 processing hot cells. This issue was determined to be a VIO.

As documented in NRC IR 50-186/2017-202, an inspector reviewed the licensees actions regarding this event as documented in letters dated February 17, 2017, and May 16, 2017. These letters identified the root cause, corrective actions, and safety analysis for the February 3, 2017, event (Refer to IR 50-186/2017-202 for further details.). During this inspection, the inspector reviewed the effectiveness of the licensees corrective actions and found them to be adequate and appropriate. No further action is required.

This issue is considered closed.

c. Conclusion The inspector reviewed one URI and three VIOs during this inspection. The inspectors review determined that corrective actions implemented are appropriate. These follow-up items are closed.

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7. Exit Interview The inspection scope and results were summarized on June 4, 2020, with members of licensee management and staff. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the results of the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Dobey Technical Advisor D. Doenges Health Physics and Safety Manager B. Fairchild Assistant Health & Safety Manager - Training L. Foyto Associate Director, Reactor and Facilities Operations K. Kutikkad Assistant Reactor Manager - Physics J. Matyas Access Control Coordinator B. Meffert Reactor Manager D. Rathke Document Management Coordinator Executive Director C. Schnieders Health Physics Supervisor P. Williams Shipping Manager INSPECTION PROCEDURES USED IP 69004 Class 1 Research and Test Reactor Effluent and Environmental Monitoring IP 69005 Class 1 Research and Test Experiments IP 69007 Class 1 Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class 1 Research and Test Reactor Procedures IP 69012 Class 1 Research and Test Reactor Radiation Protection IP 86740 Inspection of Transportation Activities IP 92701 Follow-up (on Previously Identified Items)

ITEMS OPENED, CLOSED, AND/OR DISCUSSED OPENED None CLOSED 50-186/2014-201-01 - VIO - Failure to control and post a high radiation area as required.

50-186/2016-202-01 - VIO - Failure to request a TS amendment as required by 10 CFR 50.59.

50-186/2016-202-02 - URI - Follow-up on the licensees actions involving failure to comply with the Certificate of Compliance for the Type B shipping cask Safkeg-HS.

50-186/2017-202-01 - VIO - Failure to meet operability requirements of TS 3.10, Iodine-131 Processing Hot Cell, related to charcoal filter bank efficiency (TS 3.10.d).

Attachment

LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations 49 CFR Title 49 of the Code of Federal Regulations ALARA As low as reasonably achievable COC Certificate of Compliance CY Calendar Year HP Health Physics IFI Inspector Follow-up Item IP Inspection Procedure MURR University of Missouri Research Reactor mrem/yr Millirem per year NRC U.S. Nuclear Regulatory Commission RAC Reactor Advisory Committee RWP Radiation Work Permit TSs Technical Specifications URI Unresolved Item VIO Violation-2-