ML20117L081

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Univ of Missouri Research Reactor Operations Monthly Summary for Dec 1995
ML20117L081
Person / Time
Site: University of Missouri-Columbia
Issue date: 12/31/1995
From:
MISSOURI, UNIV. OF, COLUMBIA, MO
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ML20117K785 List:
References
FOIA-96-249 NUDOCS 9609120309
Download: ML20117L081 (3)
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UNIVERSITY OF MISSOURI RESEARCH REACTOR

= OPERATIONS MONTHLY

SUMMARY

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i December 1995 Prepared by:

Operations Staff

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December 1995 The reactor operated continuously in December with the following exceptions: four. shutdowns for scheduled maintenance and refueling; four unscheduled shutdowns.

On December 26, a spurious wide range monitor (nuclear instrument channel #4) high power rod run-in occurred during a normal startup. Reactor power was less than 50 kW at the time. No actual high power condition was indicated on any instrumentation. The rod run-in was reset and observation of allinstrumentation indicated no abnormalities. A reactor startup was subsequently completed and the reactor returned to normal operation.

On December 27, a manual rod run in was initiated by the Shift Supervisor when he suspected that the regulating blade was not operating properly. Electronics technicians discovered a bad bearing and a missing pin in the gearbox input shaft coupling. The bearing and pin were replaced and the regulating blade was tested satisfactorily and returned to normal operation. A Licensee Event Report was written regarding this failure. The Technical Specification definition of" operable" leaves any degraded condition of the regulating blade a technical specification violation.

On December 30, a spurious reactor loop high temperature scram occurred. No actual reactor high temperature was indicated on any instrumentation; all reactor loop temperatures ina3cd normal at the time. The scram source isolation monitor indicated a green leg primary high temperature scram from RTD 980A or B--even though operators observed normal temperature on the 980 A & B indications. The scram most likely was the result of a momentary dimming of the filaments in one of the 980 trip unit bulbs. The 980 A/B trip units utilize a photo transistor switch that provides a trip if the light source intensity decreases or is intermittent. Electronics technicians replaced the bulbs in each of the photo trip units. A satisfactory compliance check on 980A and 980B was completed and no further problems of this type have occurred.

During the subsequent startup the Shift Supervisor initiated a manual rod run in, while the reactor was suberitical, after noting small fluctuations (1-3%)in the wide range monitor (channel #4) indication. Electronics technicians reseated the wide range monitor drawer voltage regulator and picoammeter modules, and removed and cleaned the range switch. The drawer was returned to service and no further problems of this type have occurred.

Major maintenance items for the month included: removing the 6D wedge and installing 60 wedge in the graphite reflector position #6; replacing pool flow (detector) element 921A; removing 50 plates from the pool heat exchanger; replacing the uninterruptible power supply (UPS) battery bank; replacing the secondary water make-up float valve; replacing a bearing and a roll pin in the gearbox input drive shaft coupling of the regulating blade; replacing the photo trip unit bulbs in primary temperature indications 980A & 980B.

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t , l UNSCHEDULED SHUTDOWNS Date Number Tvoe Cause 12/26/95 1042 Rod run-in Spurious channel #4 high p~ower 12/27/95 1043 Manual rod run in Regulating blade drive mechanism in degraded operating condition j 12/30/95 1044 Scram Spurious reactor loop high temperature 12/31/95 1045 Manual rod run in Spurious channel #4 fluctuations l

OPERATION

SUMMARY

HOURS OPERATED THIS PERIOD 670 TOTAL HOURS OPERATED 192,919 HOURS AT FULL POWER THIS PERIOD 667 g TOTAL HOURS AYFULL POWER 189,921 INTEGRATED POWER THIS PERIOD 278 MWD TOTAL INTEGRATED POWER 73,281 MWD MAINTENANCE ACTIVITIES l 12/4/95 Refueled - removed core _95 52, loaded core 95-53. Removed the 6D wedge and installed the 6C wedge in the graphite reflector position #6.

12/11/95 Refueled - removed core 95 53, loaded core 95-54. Replaced pool flow (detector) element 921A. Removed 50 plates from the pool heat exchanger.

12/18/95 Refueled - removed core 95-54, loaded core 95-55. Replaced the UPS battery bank.

12/26/95 - Refueled - removed core 95-55, loaded core 95-56. Replaced the secondary water make-up float valve. I 12/27/95 Refueled - removed core 95 56, loaded core 95-57. Replaced a bearing and a pin the I gearbox input shaft coupling of the regulating blade. I 12/30/95 Refueled - removed core 95 57, loaded core 95-58. Replaced the photo trip unit bulbs in primary temperature indications 980A and 980B.

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Cotun'nia %ssoun 652' 4 Telcove (314) 882 42' FAX 1314] 882234 3 UNIVERSITY OF MISSOURI-COLUMBIA Lc fjlg December 18,1995 Cynthia D. Pederson, Director Division of Nuclear Materials Safety U.S. Nuclear Regulatory Commission, Region III 801 Warrenville Road Lisle, Illinois 60532-4351

Subject:

Extension of the Implementation Date for the Procedures Replacing the Current CAI-R111-95 004 Control Governing the Activities in Room 267.

Ref: University of Missouriletter to NRC-Director Cynthia D. Pederson dated November 17, 1995

Dear Ms. Pederson:

In our November 17,199btter, we listed on page 3 aew controls that would be in place Decemb- 1 1995 to replace the controls given in the CAL-RIII-95-004 (CAL). The implementation of these ne controls is being delayed. We will continue to operate in compliance with the commitments as given in the CAL until the new procedures are implemented. The delay will allow time to  ;

incorporate suggested changes to the draft procedures. We need to make the revisions and re This review may take longer due to the holiday .

the procedures again before implementing them. 18,1996. l period; however, the new controls will be implemented before January l The proper control of MURR irradiated by product material in Room 267 can be valida  ;

an inspection under the control and documentation procedures being used and the new pro will maintain this capability. If there are any questions, please call Charles McKibben (314-882-5204) or John Ernst (314 882-5226).

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J. Charles McKibben Associate Director xc: J. McCormick J. Rhyne J. Ernst S.Gunn

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December 20,1995 Director of Nuclear Reactor Regulation U.S. Nuclear . Regulatory Commission Attn: Document Control Desk Mail Station P1-37 Washington, DC 20555

Reference:

Docket 50-186 University of Missouri Research Reactor License R-103

Subject:

Notification at changes to the University of Missouri Research Reactor (MURR) Emergency Plan as required by NRC Memoranda and Orders CLI-95-01, CLI-95-08, CLI-95-11 and CLI-95-17.

Enclosed are the December 20,1995, revisions to the Emergency Plan for the University of Missouri Research Reactor (MURR). These changes were required by NRC Memoranda and Orders CLI-95-01 dated February 28,1995; CLI-95-08 dated June 22,1995; CLI-95-11 dated August 22,1995; and CLI-95-17 dated December 14, 1995.

We agree with the NRC determination in CLI-92-11 that the site boundary is the critical distance from the MURR to consider off-site consequences to classify a Site Area Emergency. We do not agree with the determination in CLI-95-11 that the critical distance from MURR to consider off-site consequences for an Alert classification is some arbitrary distance from MURR (150 meters) within'the MURR site boundary. RTM-93, pp. A-32 and A-33, clearly tie both classifications to off-site consequences (i.e., the site boundary).

Nevertheless, we are willing to incorporate the requirements of the above Memoranda

& Orders, understanding that NRC response criteria for research reactors and materials licenses may vary slightly.

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Letter to Director of Nuclear Reactor Regulation December 20,1995 Page two CLI-95-11 requires a protective evacuation to beyond 150 meters for a fire involving TRUMP-S materials. This distance is beyond MURR's current EPZ which was based on the generic EPZ size (100 meters) prescribed in ANSI-ANS-15.16, Emercency Planning for Research Reactors and in NUREG-0849, Standard Review Plan for Review and Evaluation of Emercency Plans for Research and Test Reactors. This distance is also beyond the 100 meter protective action distance recommended in NUREG-1140, pp.103 and 104, for an accident involving five times more material than evaluated in CLI-95-01. We are, however, changing our EPZ to 150 meters for additional conservatism and consistency between research reactor and materials license facility response criteria. We believe our emergency plan will be more effective with the same EPZ for reactor emergencies as the EPZ specified for the Materials License accident evaluated in CLI-95-01.

If you have any questions please contact me or J. Charles McKibben at (314) 882-4211.

Sincerely, C (khi f Walt A. Meyer, Jr.

Reactor Manager  !

ENDORSEMENT: j Reviewed and Approved  !

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J. Charles McIGbben Associate Director enclosure xc w/ encl: Regional Administrator, U.S. NRC, Region III T. Reidinger, U.S. NRC, Region III bA /),rf lYht  %

CHRISTINE M. ERRANTE Notary Public - Notary Seal STATE OF MISSOURI Boone County My Commission Expires: April 14.1999 l

( ( I EMERGENCY PLAN UNIVERSITY OF MISSOURI RESEARCH REACTOR i l

l 1.0 INTRUDUCTION This emergency plan applies to the University of Missouri Research Reactor Facility (MURR). MURR is licensed pursuant to Title 10 Code of Federal Regulations, Chapter 1, Part 50, as a research and utilization reactor (class 104), Facility Operating License No. R-103, (Docket No. 50-186). The MURR ]

has its own Materials License No. 24-00513-39, which among other uses,]

controls experiments in the Alpha Laboratory. ] I MURR is a 10 MW predurized water moderated pool type reactor with the reactor located in a containment building. It is located on a University of 1 Missouri owned low population density 550-acre tract ofland in Columbia, Missouri (Figure I). MURR provides research, education and service to the four campuses of the University of Missouri, other universities, government, and industry.

The plan contains a description of the elements of advance planning to cope with emergency situations connected with the operation of MURR and the ]

conduct of experiments at MURit The plan focuses primarily on handling ]

of situations that may cause or may threaten to cause radiological hazards affecting the health and safety of University of Missouri staff or the public. It outlines the objectives to be met by the emergency procedures and defines the authority and responsibilities to achieve these objectives. Unusual or 1

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1 unanticipated conditions in an emergency may prevent carrying out certain l actions described in this plan or may require different types of actions than those described.

Many terms that are unique to MURR or that have particular connotations in the context of this emergency plan are defined in Section 9.

This plan was written to conform with 10CFR50, Appendix E, following ]

i the guidance provided by Revision I to Regulatory Guide 2.6 (for comment)

Emergency Planning for Research and Test Reactors. March 1982, and l

ANSI /ANS-15.16, Emergency Planning for Research Reactors draft II, November 29,1981. Revisions of the plan have been made to accodio- ]

l date criteria specific to Materials License Emergency Response as ]

required by NRC Memoranda and Orders CLI 95-01 (Feb. 28,1995); ]

CLI 95 08 (June 22,1995); and CLI 95-11 (Aug. 22,1995). ]

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3.0 CLASSIFICATION OF EMERGENCY CONDITIONS 3.1 Bases for Emercency Classifications MURR's EPZ is based on ANS 15.16 (Table II) as modified by the ]

NRC evaluation of a worst case TRUMP-S materials accident in ]

Memorandum & Order CLI 95 01 dated Feb. 28,1995. It is the area ]

bounded by a 150 meter radius from the MURR exhaust stack which lies ]

completely within the site boundary. There are no credible accidents identified for the MURR facility that would result in radiological efIluents exceeding PAG at EPZ boundary or exceeding Alert action levels listed in ]

Table I at the site boundary.

However, the emergency plan describes three standardized classes of emergency situations grouping the accidents according to the severity of off-site radioldal consequences: (1) Notification of Unusual Events, (2) Alert; and (3) Site Area Emergency. The latter classification is ]

included to be conservative and to provide for consultation with off-site authorities and handling ofinformation for the public through off-site authorities. I MURR recognizes emergencies oflesser consequences than the Notification of Unusual Events classification. These include physical occurrences within the facility requiring Facility Emergency Organization response. The initial assessment should indicate that it is unlikely that an I 1

off-site hazard will be created. Protective evacuations orisolations of i certain areas within the facility may be necessary.

l Response to these emergencies oflesser consequence than the J

Notification of Unusual Events classification are detailed in MURR Standard Operating Procedures. They are based on the recognition of inunediate need for on-site staff to implement emergency measures to provide aid to affected persons or to mitigate the consequences of damage to equipment; coupled with assessing radiological monitors to determine if the possibility of a more serious emergency is present. Procedures will be written for other identifiable emergencies as the need is recognized.

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4 3.2 Notification of Unusual Events i

j .A Notification of Unusual Events condition may exist as a result of either f man made events or natural phenomena that can be recognized as creating a 1

l. hazard potential that was previously nonexistent. There is usually time
available to take precautionary and corrective steps to prevent the escalation of l an accident or to reduce the consequences should it occur. No releases of

!. . radioactive materialiequiring off site responses are expected. Although the 2

situation may not have caused damage to the reactor,it may warrant the j; immediate shutdown of the reactor or the interruption of non-essential routine

, functions.

j Situations that may lead to this class include:

1. Threats to or breaches of security, such as bomb threats or civil . ,

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disturbances directed toward the reactor.

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2. Severe natural phenomena such as earthquakes, tornadoes, etc.

l 3. Facility emergencies, such as prolonged fires not involving TRUMP-S ]

1 materials (americium, neptunium, plutonium) or significant fuel ] 4

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j damage indicated by high coolant fission product activity.

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3.3 Alert ,

An Alert condition may exist when an accident within the MURR facility requires notification and response of the emergency organization to a serious radiological hazard. Substantial modification of reactor operating status is a high probable corrective action. Protective evacuations of all public and ] ,

non emergency personnel to outside thaEPl shall be performed. ]

Isolation of certain areas within the site boundary will be necessary. Situations that maylead to this class include:

1. A fuel handling accident outside the core which releases significant  !

radioactive materials to containment.

2. Significant releases of radioactive materials as a result of experiment failures.

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' fuel cladding or of fueled experiments when primary and

.ndaries exist to reduce releases. )

3ases of radioactive material as a result of fire ]

. DIP-S materials (americium, neptunium, ]

.). ]

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E 'ergency condition may exist when events such as major 2.no occurred with actual or eminent failure of primary system

. :11 'nmentintegrity. Monitoring at the site boundary should be y.jc'.le need for off-site protective actions. Protectivqp id the nearest site boundary (400 m) shall be ]

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5.2.2 Assessment Actions Containment, laboratory building and site boundary airborne radioactivity and radiation levels shall be determined by stack monitor, area radiation monitors and portable monitoring equipment by members of the Emergency Organization. The Emergency Director shall use this information and Table I to determine that the emergency is appropriately classified.

5.2.3 Corrective Actions A reactor shutdown shall be considered by the Emergency Director.

Physical barriers to contain the radioactivity shall be maintained or implemented where necessary, Installed cleanup systems may be used to reduce the release of radioactive material. Specific corrective actions shall be provided in the implementing procedure for this emergency class.

5.2.4 Soecific Protective Actions The Protective Actions shall be provided in the implementing procedure for this emergency class and shallinclude protective evacuation of all ] ,

. public and non emergency personnel to outside the EPZ. ] :

i 5.2.5 Subseauent Actions  !

Notifications that an Alert has occurred shall be made to the NRC, l American Nuclear Insurers (ANI) and the State Emergency Management  ;

Agency (SEMA) as specified in Site Emergency Procedures (SEP-3) for '

Alerts.

5.3 Site Area Emergency 5.3.1 Emergency Action Levels The Emergency Director shall determine if a Site Area Emergency condition exists and shall respond te the emergency by implementing the appropriate procedures (Appendix B). Site Area Emergency would exist if one of the conditions listed in Table I existed.

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i 5.3.1 Emergency Action IAvels - Cont'd ]

Site Area Emergency conditions may require evacuation of non-essential personnel to bevond the site boundary, and shall require providing emergency .

notification and status information to off-site organizations and the public.  !

5.3.2 Assessment Actions Containment, laboratory building and site boundary airborne radio-activity and radiation levels shall be determined by stack monitor, area radiation monitors and portable monitoring equipment by members of the emergency organization. The Emergency Director shall use this information and Table I te determine release and contamination magnitudes and to  !

estimate projected exposures to on-site and off-site population.

5.3.3 Corrective Actions The reactor shall be shutdown. Physical barriers to contain the radio-activity shall be maintained or implemented where necessary. Installed cleanup systems may be used to reduce the release of radioactive material.  ;

Specific corrective actions shall be provided in the implementing procedure for this emergency class.

5.3.4 Suecific Protective Actions The Protective Actions shall be provided in the implementing procedure for this emergency class and shallinclude evacuation of public and ]

non-emergency personnel from the area bounded by 400 m radius ]

(the nearest site boundary) from the MURR exhaust stack. ]

5.3.5 Subseauent Actions Notifications that a Site Aren Emargoney has occurred shall be made to the NRC, American Nuclear Insurerm (ANI), and the State Emergency Management Agency (SEMA), as specified in Site Emergency Procedure (SEP-4) for Site Area Emergencies.

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9.8 Emergency Planning Zone (EPZ)

Area for which emergency planning is performed to assure that prompt  !

and effective actions can be taken to protect the public in the event of an '

accident. MURR's EPZ is the area bounded by a 150 meter radius from the ]

MURR exhaust stack and lies completely within the site boundary.

9.9 Emergency Procedures Emergency procedures are the documented instructions that detail the implementation actions and methods required to achieve the objectives of this l emergency plan.

9.10 MURR .

I i University of Missouri Research Reactor located in Columbia, Missouri, i

1 l 9.11 Nearest Site Boundary The site boundary east-southeast of the MURR exhaust stack that l represents the shortest distance between the exhaust stack and any site

, boundary for emergency planning purposes (approximately 400 meters).

j 9.12 Offsite

The geographic area that is beyond the site boundary.

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9.13 Onsite

] The part of the University of Missouri owned and controlled grotmds that

!' lie within the following site boundaries: south of Stadium Boulevard; west of Route K (Providence Road); north of Hinkson Creek; east of the former MKT railroad bed. The University of Missouri owned and controlled grounds extend

! beyond these bounicies but are not included in our ddinitica of"on .L'.

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. . l 5 ( j 9.19 Site Boundarv 1 The site boundary is that boundary listed in the on-site definition, not having restrictive barriers, surrounding the operations boundary wherein the reactor administrator may diredtly initiate emergency activities. The area  !

within the site boundary may be frequencted by people unacquainted with the l reactor operations.

] l 9.20 Shall. Should and May l l

The word "shall" is used to denote a requirement; the word "should" to i

, denote a recommendation; and the word "may" to denote permission, neither a

requirement nore a recommendation.

i 9.21 Standard Ooerating Procedures (SOP) 4 There are Standard Operating Procedures for Reactor Operations, Health l

Physics, and Reactor Chemistry which contain detailed procedures for carrying out their respective responsibilities in handling routine and emergency events.

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!- 9.22 Surveillance Team j The person or person appointed by the Emergency Coordinator to ensure j that all personnel have evacuated the facility or a specific part of the facility.

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4 In the event of a Reactor Isolation or Facility Evacuation, the Duty Operators will perform the surveillance team function in the containment building as per l

FEP-1, Facility Evacuation, and FEP-2, Reactor Isolation.  ;

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9.23 TRUMP-S Materials  ;

j Transuranic isotopes listed on the MURR Materials License ] l

! #24-00513 39 for use in TRUMP-S experiments. This incudes ] l l americium-241, plutonium 239/240, and neptunium-237 in use in the ]

i Alpha Lab or being transferred into or out of the Alpha Lab. It does . ]

not include material stored in containment either as waste or raw ]

material. ]

, 9.24 UMHC - University of Missouri Hosoital and Clinics ]

A 400 bed hospitallocated within a five minuto diive from ?.1URR.

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TABLE I EMERGENCY CLASSES l Emergency Class Action Levels Purnose Notification of 1) Report or observation of 1) To assure the first Unusual Events severe natural phenomenon. step in any response later found to be ,

2) Threats to or breaches of necessary has been i security, carried out;
3) Concentration of airborne 2) bringoperatingstaff 1 radioactivity at the stack handling ofunusual  !

monitor exceeding 20,000 events information.

AEC* averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 3) provide systematic handling of t wual

4) The projected concentration events information.

of airborne radiological effluents at the distance corresponding to the nearest site boundary exceeding 15 mrem whole body accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ,

l

5) Prolonged fire or explosion l within the facility that does ]

not involve TRUMP-S ]

materials (americium, ]

neptunium, plutonium). ]

6) Other plant conditions exist that warrant assuring emergency personnel are available to respond to an emergency to prevent exposures of1 rem whole body or 5 rem thyroid to the public or staff.

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TABLE I (Cont'd)

EMERGENCY CLASSES Emergency Class Action Levels Purnose Alert 1) Concentration of airborne 1) Assure that emer-radioactivity at the stack gency organization is monitor exceeding 100,000 ready to respond if AEC* averaged over 24 situation becomes hours. more serious;

2) The projected concentration 2) to perform con-ofairborne radiological firmatory radiation effluent at the distance monitoring; corresponding to the nearest site boundary exceeding 75 3) provide communi-mrem whole body cations link to offsite

_ accumulated in 24 ho ,rs. authority.

3) Radiation levels at the distance corresponding to the nearest site boundary of 20 mrem /hr for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> whole body or 100 mrem thyroid dose.
4) Loss of physical control of the facility.
5) Fire in which up to . ]

3 grams of TRUMP S ]

materials (americium, ]

neptunium, plutonium) ]

are involved. ]

6) Other plant conditions exist with a level ofsignificance of a major failure of fuel cladding but primary and containment boundaries exist to reduce releases.

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TABLE I (Cont'd)

EMERGENCY CLASSES Emergency Class Action Levels Purnose Site Area 1) Concentration of airborne 1) Assure emergency ,

Emergency radioactivity at the stack organization monitor exceeding 500,000 manned; AEC* averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 2) assure monitoring teams dispatched;

2) The projected concentration 4 of airborne radiological 3) provide commum-effluent at the distance cation with offsite corresponding to the nearest authorities; ,

site boundary exceeding 375  ;

mrem whole body 4) provideinformation accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. to the public through offsite authoritis#- ,

3) Radiation levels at the l distance correspondir.g to the nearest site boundary of 100 mrem /hr for 1 hcur whole-body or 500 mrem thyroid dose.
4) Fire in which more than ]

3 grams of TRUMP-S ]

materials (americium, ]

neptunium, plutonium) ]

are involved. ]

5) Other plant conditions exist with a level of significance of a major fuel damage and conditions thatindicate actual or imminent failure of containment integrity and primary system integrity.

'AEC-Air Efiluent Concentration 10CFR20 Appendix B Table 2 Column 1 27 Rev.12/20/95

December 27, 1995 Gerald Brouder, Provost The Curators of the University of Missouri University of Missouri - Columbia Columbia, MO 65211

SUBJECT:

CONFIRMATORY ACTION LETTER FOLLOWUP INSPECTION

Dear Dr. Brouder:

This refers to the special safety inspection conducted by Mark Mitchell of this office on November 1-3, 1995, with continuing review through November 27, 1995, of activities authorized by NRC License Nos. R-103 and 24-00513-36E, and to the discussion of our findings with Dr. John McCormick and other members of your staff at the wnclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

One area of concern was identified regarding the handling of irradiated topaz.

Specifically, irradiated topaz releasable for international shipment under 10 CFR Part 110, was given to a customer of the University for sorting, storage and/or preparation for shipment. Prior to the implementation of the actions listed in the University's amended letter of September 21, 1995, to NRC, the customer performed these functions independent of the University in a room that was leased from the Missouri University Research Reactor. This being the case, it appeared that the University was transferring irradiated topaz to an unauthorized individual (the customer). An October 6, 1995, Confirmatory Action Letter formalized our understanding of the actions you committed to take to ensure the irradiated topaz was properly controlled.

These actions were reviewed during this inspection and it was determined that their implementation did not alleviate our concern that the byproduct material was being inappropriately transferred to the customer. A written response to this concern was received in a letter dated November 17, 1995. Acceptable interim measures were listed in the letter and were implemented to ensure the University had appropriate control of the irradiated topaz. In addition, acceptable long term control measures were proposed for future implementation.

Therefore, no further reply to this concern is required.

No violations of NRC requirements were identified during the course of this inspection.

bO(O1C MI

1 G. Brouder In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of j this letter, the enclosed report and its attachments will be placed in the NRC 1 Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, Original Signed By James L. Caldwell for Cynthia Pederson, Director Division of Nuclear Materials Safety '

License Nos. R-103, 24-00513-36E Docket Nos. 050-186, 030-30162

Enclosure:

Inspection Report Nos.:

050-186/95004(DNHS); 24-00513-36E/95004(DNHS) cc w/ enc 1: Jim Ryhne, Director bec w/ encl: PUBLIC i

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December 27, 1995 Gerald Brouder, Provost The Curators of the University of Missouri University of Missouri - Columbia Columbia, MO 65211

SUBJECT:

CONFIRMATORY ACTION LETTER FOLLOWUP INSPECTION

Dear Dr. Brouder:

This refers to the special safety inspection corducted by Mark Mitchell of this office on November 1-3, 1995, with continiing review through November 27, 1995, of activities authorized by NRC License Nos. R-103 and 24-00513-36E, and l to the discussion of.our findings with Dr. John McCormick and othogmembers of your staff at the tnclusion of the inspection. "

The enclosed copy of our inspection report identifies areas examined during i the inspection. Within these areas, the inspection consisted of a selective l examination of procedures and representative records, observations, and i interviews with personnel.

One area of concern was identified regarding the handling of irradiated topaz.

Specifically, irradiated topaz releasable for international shipment under 10 CFR Part 110, was given to a customer of the University for sorting, storage and/or preparation for shipment. Prior to the implementation of the actions listed in the University's amended letter of September 21, 1995, to NRC, the customer performed these functions independent of the University in a room that was leased from the Missouri University Research Reactor. This being the case, it appeared that the University was transferring irradiated topaz to an unauthorized individual (the customer). An October 6, 1995, Confirmatory Action Letter formalized our understanding of the actions you committed to take to ensure the irradiated topaz was properly controlled.

These actions were reviewed during this inspection and it was determined that their implementation did not alleviate our concern that the byproduct material was being inappropriately transferred to the customer. A written response to this concern was received in a letter dated November 17, 1995. Acceptable interim measures were listed in the letter and were implemented to ensure the University had appropriate control of the irradiated topaz. In addition, acceptable long term control measures were proposed for future implementation.

Therefore, no further reply to this concern is required.

No violations of NRC requirements were identified during the course of this inspection.

/h r m

't w v n 5 r3 3 t t) n NLu utw ]iin

.. j G. Brouder In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of i1 this letter, the enclosed report and its attachments will be placed in the NRC Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, I Original Signed By i James L. Caldwell for Cynthia Pederson, Director i

Division of Nuclear Materials Safety License Nos. R-103, 24-00513-36E-Docket Nos. 050-18,6, 030-30162 .

Enclosure:

Inspection Report Nos.:

050-186/95004(DNMS); 24-00513-36E/95004(DNMS) i cc w/ encl: Jim Ryhne, Director i bec w/ encl: PUBLIC '

DOCUMENT NAME: G:\INSPRPTS\MTLS\030\03032695.951 To receive a copy of this document, indicate in the box: "C" = Copy without oncdoeures

  • See Previous Concurrences
  • E* = Copy with ehres *N* = No copy 0FFICE DNMS/RIII
  • DNMS/RIII l*

l DNMS/RIII l* NRR l6 LONMG 'RIII l E.

NAME MMITCHELL:brt TJK0ZAK DATE JMcCormick WEISS 7E/or. Db)4jon 12/ /95 12/ /95 12/ /95 12/ Z G/955s. 197 D /95 ua E n.I

G. Brouder We will gladly discuss any questions you have concerning this inspection.

Sincerely, Cynthia Pederson, Director Division of Nuclear Materials Safety License Nos. R-103, 24-00513-36E Docket Nos. 050-186,.030-30162

Enclosure:

Inspection Report No. 050-186/95004(DNMS) cc w/ enc 1: Jim Ryhne, Director bec w/ enc 1: PUBLIC DOCUMENT NAME: G:\lNSPRPTS\MTLS\030\03032695.951 To neolve a copy of tNo document, Indicete in the box: *C* = Copy without enclosures

  • E" = Copy with endosures "N* = No copy 0FFICE DNMS/RIII l6 DNMS/RIII ( DNMS/P.III lt MCB l DNMS/RIII l NAME MMITCHELL:brt W TJK0ZAK 7 E- JMcCormick m @ WEISS CPederson DATE 12/ to /95 _4y_. 12/ 2o/95 F' 12/f)/95 12/ /95 12/ /95

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4 0FFICIAL RECORD COPY U.S. NUCLEAR REGULATORY COMMISSION REGION III Report Nos. 050-186/95004(DNHS); 24-00513-36E(DNMS) 1 Docket Nos. 050-186, 030-30162 License Nos. R-103, 24-00513-36E-2 Licensee: The Curators of the University of Missouri i

l.

Facility Name: Missouri University Research Reactor (MURR) l

Inspection Conducted

November 1-3, 1995, with continuing review through 7 November 27, 1995 l l

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Inspector: h k@

i Mark'W. $tchell' Date Radiation Specialist i 1

l' Approved By: Mu /Y YT Thomas J.0Kozak, Chief Date i Nuclear Materials Inspection )

Branch 2 j

j Inspection Summary Inspection on November 1 to 3. 1995 with continuina review throuah November i

27. 1995 (Recort Nos. 05-186/95004 (DNMS): 24-00513-36E/95004(DNMS))

Areas Insoected: This was a special unannounced safety inspection to assess the actions taken by the licensee in response to a Confirmatory Action Letter which was issued to the licensee on October 6.1995.

Results: One unresolved item concerning the possible transfer of byproduct

}

material to an unauthorized individual was identified. A written response

Acceptable interim control measures were listed in the letter and were implemented to ensure the irradiated topaz was appropriately controlled. In addition, acceptable long term controls were proposed for future j implementation. .

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DETAILS 1.1 Persons Contacted University of Missouri-Columbia

  • John McCormick, Vice Provost for Research and Graduate Studies

+ James Rhyne, Director, MURR

+* Charles McKibben, Associate Director, MURR

+* Jim Schuh, Health Physicist, MURR

+* Steve Gunn, Service Manager, MURR

+ John Ernst, RSO, Health Physics Manager, MURR

  • Matthew R. Sanford, Reactor Services Project Specialist
  • Ronita Dinger, Information Specialist
  • Tony Schoone, MURR Reactor Operations

+ Walt Meyer, Manager, MURR Reactor Operations

+ Bruce Hoskins, University Counsel

+ Kelly Mescher, University Counsel

  • Clarence Jett, Internal Auditor, University of Missouri ,

l Nuclear Reaulatory Commission I

    • Cynthia Pederson, Director, Division of Nuclear Materials Safety (DNMS)
    • Jim McCormick-Barger,- Chief, Decommissioning Branch
    • Bruce Berson, Regional Counsel, Region III i
    • Charles. Weil, Enforcement Specialist, Region III
    • Timothy Reidinger, Sr. Inspector, DNMS, Region III
    • Seymour Weiss, NRR
    • Marvin Mendonca, NRR
    • George Pangburn, NMSS

+* Robert Marsh, Sr. Investigator, Region III Field Office

+* Harold Walker, Sr. Investigator, Region III Field Office

+* Mark Mitchell, Radiation Specialist Additional technical, operational, and administrative personnel were contacted by the inspector during the course of the inspection.

+ Denotes those attending the entrance meeting on November 1, 1995.

  • Denotes those attending the exit meeting on November 3, 1995.
    • Denotes those attending the exit meeting on November 3, 1995 via teleconference.

1.2 Purpose of Inspection This inspection was conducted to assess the licensee's actions taken as a result of the commitments made to the NRC in the amended letter of September 21,1995 (Attachment 1) from Mr. S. Gunn, Manager of Service Applications, MURR, to Mr. R. Marsh, Senior Investigator, Chicago Field Office, NRC, and a subsequent Confirmatory Action Letter issued to the licensee on October 6,1995 (Attachment 2).

2

I The inspection was limited in scope and focused on security and accountability of byproduct material (irradiated topaz) which is stored and processed in Room 267 of the Missouri University Research Reactor facility (HURR). The inspection consisted of interviews' with licensee personnel, a review of records and observations of activities conducted in Room 267.

1.3 Topaz 1rradiation Proaram The University of Missouri Research Reactor (MURR) is a research reactor located in Missouri.

Columbia, an academic environment at the University of Missouri, In addition to the academic and~ research uses for the reactor, the licensee irradiates topaz for commercial distribution.

The Service Applications Group is responsible for the topaz irradiation program. The Services Manager reports to the Director, HURR.

The University leased Room 267 of the MURR facility to a customer of the topaz program. Once the University had determir hat the irradiated topaz was releasable for international shipment unaer 10 CFR Part 110, it was given to the customer in Room 267 for sorting, storage and/or preparation for shipment. Prior to the implementation of "

$ctions listed in the University's amended letter of September 21, 1995, to NRC, the customer signed a document listing the carat weight of the topaz that was received and processed the material independent of the University. Topaz with activity levels above the domestic limit in License No. 24-00513-36E was usually included in the material given to the customer. ,

l When the customer was ready to make an international topaz shipment, the 1 University was informed of the weight and contents of the packages that had been prepared for shipment. The University indicated that they did notthe of perform packages.an independent verification of the actual contents or weight l In addition, the MURR staff did not have an accurate  !

inventory of the topaz in Room 267 up to September 20, 1995.

i The circumstances surrounding the handling and shipping of irradiated  !

topaz indicate that the University may have been transferring byproduct material to an unauthorized individual (the customer). This is an l unresolved item (URI No. 050-186/95004-01; 24-00513-36E/95004-01). This  ;

concern 1995.

was initially developed during an investigation September 19-21, '

A letter from the University to NRC, as amended on September 21, j 1995, listed actions that would be taken to improve the University's  :

control of irradiated topaz. An October 6,1995, Confirmatory Action Letter (CAL) to the University formalized NRC's understanding of the actions planned to ensure the irradiated topaz was properly controlled.

i One Unresolved Item was identified.

1.4 Confirmatory Action Item Review A review of the actions taken by the licensee to meet the commitments 3

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listed in the CAL was performed. The specific items outlined in the CAL i and the licensee's act4 ans are discussed below. )

$ Item 1: Padlock the inner door to the dark room (Room 267) and place i

two keys to the room under the control of Mr. John Ernst or his designee and Mr. Matt San.oro or his designee.

Discussion: The licensee completed their comunitment in this item on September 20, 1995. It appeared that key control was l

maintained at all times between September 20, 1995 and the date of the inspection. There appeared to be no opportunity for the keys to be duplicated prior to the transfer to the designated individuals. The padlock packages were opened from the manufacturer's packaging in the presence of the controlling individuals.

l Item 2: Until further notice the University of Missouri Research Reactor (MURR) will have a MURR employee present in a 4

supervisory role when any work is performed in this space.

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Discussion The space referred to in this item is Room 267. Starting on aeptember 20, 1995, tne licensee ensured a MURR employee was j

present at all times when the customer or employees of the customer were in the room. Through a review of recent shipments and interviews with personnel assigned to oversee activities in Room 267, it was determined that the individuals had no formal guidelines for their duties, kept no formal inventory or log of materials entering and leaving i the room, and were not aware of the origin of packages i shipped by the customer. One shipment contained eight

! packages, three of which did not originate from Room 267.

However, the oversight personnel thought all of the material

+

originated from Room 267. This indicated that the supervision of the activities in Room 267 was not effective 2

in ensuring that the licensee was in positive control of the-transfer of material into and out of the room. This area of concern was adequately addressed in a November 17, 1995, i letter (Attachment 3) from the licensee and there are no further questions regarding the supervision of activities in Room 267.

Item 3: The licensee will conduct an audit of the material contained in the room under the direction of Mr. Jim Schuh.

Discussion: The licensee inventory found 26,049.8 carat weight of topaz that was not known to be in the room. The licensee determined that this material should have been in their vault as it was for other MURR customers. The material was apparently placed in the room without following the normal material transfer procedure. The inventory also initially revealed that approximately 1,000,000 carat weight of topaz 4

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I was not in the room as expected. Mr. Jett of the  !

University's Internal Auditing Department was contacted to )

reconcile the inventory. Data transfer errors were found by Mr. Jett and once the reconciliation was complete, the physical inventory was within 3.37 percent of the expected value. This was considered by the licensee to be a reasonable agreement.

)

Item 4: i The licensee will ensure that no material is transferred  !

into or out of this room until the inventory has been  !

reconciled under the oversight of Clarence Jett of the University of Missouri Internal Auditing Department. l Discussion: It appears that no material left the Room 267 until Mr. Jett had reconciled the inventory.

Item 5: After the inventory is complete and until further notice, the licensee will ensure that a MURR eployee supervises all material transfers into and out of the dark room (Room 267). l Discussion: As of the date of this inspection, a member of tt 11URR staff continued to be physically present in the room during

] all operations.

In summary, our review indicated that items 1, 3, 4, and 5 were adequately completed. However, the action taken for item 2 did not alleviate our concern that irradiated topaz was being inappropriately transferred to the customer. The need for positive control of the  ;

material was discussed at the exit meeting and, as agreed to at the '

meeting, a written response to this concern was received in a letter dated November 17, 1995. The letter was discussed with the licensee on November 27, 1995, to ensure the intent of the listed actions was  !

mutually understood. Acceptable interim measures were listed in the letter and were implemented to ensure the University had appropriate control of the irradiated topaz. In addition, acceptable long term control measures were proposed for future implementation. The long term i 4

control measures will be reviewed during a future inspection.

1.5 Exit Meetina On November 3, 1995, an exit meeting was held with licensee personnel listed in Section 1 to discuss the preliminary findings of the inspection. The NRC expressed the concern that MURR did not have a'

positive control of the topaz irradiated at MURR until it was shipped internationally in compliance with 10 CFR 110 or domestically under the requirements of NRC 1.icense No. 24-00513-36E for exempt distribution.

The licensee agreed to respond to this concern in writing. The response was received on November 17, 1995 and was discussed with the licensee on s

November 27, 1995. It appeared that acceptable interim measures were implemented to enhance the control of topaz until the proposed procedures containing long term controls were developed.

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U~niversity of Missouri-Columbia Research Reactor Center rhooc i314) 8s 2-5273 Research

  • Education
  • Service Columbia, MO 65211

)

fax (314) sa2 3443 Robert Marsh SeniorInvestigator September 20,1995 U.S. Nuclear Regtdatory Commission Arnended September 21,1995 l

Office ofInvestigations '

Chicago Field Office Dear Mr. Marsh I The following actions have been taken to address your concerns Topaz in our Non-Licepsed Accounts (NLA). e regard (1) A padlock was purchased this date at Walmart and placedo on the l

keys or.:xist, Sanford one under the control of John Ernst, or his designee, and on his designee. -

2 (2) Until funher notice, the Licensee (MURR) will insure thatnaa MURR emp supervisory role when any work is perforrned in this space. j (3) An audit of the material contained in the room has been started ofJim Schuh. on und

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(4) No material will be transferred into or out of this room until the inventory 9/2U95 Clarer.ce Jett ofthe University ofMissourtInternal Auditing Depart reconcillation.

(5) Until further notice, the Licensee (MURR) will insure that a MURR empl mate-ial transfers into and out of this room.

Sincerely, '

.,kh.vu. u-Stew: Gunn Manager, Service Applications CC:

J!sn Rhyne, Charlie McKibben. John Ernst, Walt Meyer, Steve Morris, Ji 9/2H95 ClarenceJctt ,

ATTACHMENT 1 h

. 'WN Ocotber 6,' 1995 CAL No. RIII-95-004 l

The Curators of the University of Missouri ATTN: Jim Rhyne, Ph.D., Director Research Ret.ctor Center Columbia, H0 65211

SUBJECT:

CONFIRMATORY ACTION LETTER

Dear Dr. Rhyne:

This letter refers to NRC concerns with the control of radioactive topaz at your facility identified by Mr. R. Marsh during an investigation on September 19 and 20,1995.

Pursuant to Mr. Steve Gunn's letter to Mr. Marsh dated September 20, 1995, as  ;

amended on September 21, 1995, it is our understanding that you will: 1 (1) padlock the inner door to the dark room and place two keys to the i room under the control of Mr. John Ernst or his designee and Mr. Matt Sanford or his designee, (2) until further notice, have a University of Missouri Research l Reactor (MURR) employee present in a supervisory role ~ when any work is performed in this space, (3) conduct an audit of the material contained in the room under the direction of Mr. Jim Schuh, (4) ensure no material is transferred into or out of this room until the inventory has been reconciled under the oversight of Clarence .

Jett of the University of Missouri Internal Auditing Department, and -

(5) once the inventory is complete and un'til further notice, ensure a MURR employee supervises all material transfers into and out of the dark room.

Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:

1) Notify me immediately if your understanding differs from that set forth above; 1

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ATTACHMENT 2

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. .1-~.

The Curators of the University' of Missouri

2) Notify me if for any reason you cannot complete the actions within the specified schedule and advise me in writing of your modified schedule in advance of the change; and
3) Notify me in writing when you have completed the actions addressed '

in this Confirmatory Action Letter.

Issuance of this Confirmatory Action Letter does not preclude issuance of an 1 order formalizing the above commitments or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this

} Confirmatory Action Letter may result in enforcement action.

4 The responses directed by this letter are not subject to the clearance '

procedures of the Office of Management and Budget as required by the Paperwork p-Reduction Act of 1980, Pub. L. No.96-511.

In accordance with 10 CFR 2.790 of th NRC's " Rules of Practice," a cop,_y of

' this letter, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal i

privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support s

your request for withholding the information from the public.

Sincerely,,'

i

. i i

Cynthia D. Pederson, Director i

]

Division of Nuclear Materials Safety j l Docket No.: 030-30162 License No.: 24-00513-36E t

cc w/ltr dated 9/20/95: H. Thompson, OED0

J. Lieberman, OE

' J. Goldberg, 0GC D. Cool, NMSS C. Jones, HMSS i H. Miller, Rlli State of Missouri, SLO i l 1

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UNIVERSITY OI: MISSOURI.CCI.UMSIA Ncvember 17,1995 Cynthin D. Pederson, Director Division of Nuclear Materials Safety U.p. Lelear Regulatory Commission, Region !!I 801 Warrenville Road Lide, Elinois 60532 4351 St.bject: Reply to Confirmatory Action Letter CAL No. Rill.95-04 and Concerni Patised During Exit Interview November 3,1995

Dear Ms. Pederson:

This ictteris our notification to you that we have completed the actions addressed m your C,:nfirmatory Action Letter CAL-RIII-95-004. Specifically:

(D On September 20,1995, the inner door of Room 267 (Dark Roon:) was padiocked and the two keys were pisLd under the controi of Mr. John Ernst er his designoe and Mr. Matt Sanford or his designee.

(2) Since September 20,1995, a University of Missouri Research F.eactor (MURR) employee has been present in a supervisory role v/nen any work is performed in Room 267.

(3) Conducted on the evening cf September 20,1995, an audit of the byproduct material contained in licom 267 was conducted under the direction of Mr. Jim Schuh.

(4) The inve::tcry was reconciled under the ove. sight of Mr. Clarence Jett of:he University cf MissouriInternal Auditing Department on September 21,1595. No

naterial was transferred into or out of Room 267 until September 22,1995.

(5) A University of Missouri Research Reac:or employee has supervised all byproduct material transfers into end out of Room 267. The first transfer of byproduct material was a transfer into Room 267 on Sep9rnher 22,1995. The first transfer out was a shipeent on September 25,1995.

During the investigation conducted on Septernber 20-21,1995, we understood Mr. Robert Marsh had zejor concerns about ho'w we were handling the byproduct materialin Room 267. We do not believe that the University viointed any regulations regarding the possession and use of the byproduct material in Room 267. When we asked Mr. Marsh what NRC regulation he feit we were notin cornpilance with. concerning Room 267, no specific answer was given. Therefore in an attempt to ve ek n va jg,gg>m cot.UMBIA KANSAS CITY ROLLA ST. tC U'S D .,_...,.,,..,..,.;,

ATTACHMENT 3

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?c:s 2 R<;i.y u Con.%moe y A: e i Lmer C/d No, Riii.f.5N I

continue t.o snett appropricte program needs while alleviating nonspecific conce:ns, Mr. Ste l

Gunn committed to take the actions in his September 20.19951etter farnended Sep. embe MUER is in compliance with CA1 Rill.95 004  !

M2xt. we wish to address theissues raised in the Novernber 3.1995 exit i!

exnpi tnce inspection. We unders:and thet you are concerned that our supervir. ion of non.

Univerrity ernployees working wi:h byproduct material is insufficient to preclude l i

\ unauthorized release in the United States. Speci5eally, that allowing non. University e uoeswned access to byproduct tope materialin Re:m 2c7 and being inv:>lvediointly uith MU empk;.ut in delivenng the matarial to the carrier in St. Louis does not provide a suffic.i!

to pr< vent this topaz from bring tsi;ched with nonbyproduct topaz. You suggestnthat this pro{ i o7portunity for byproduct topaz to be released in the U.S. without going through the a;;propri

vnt,rols of en exempt gemstone license.

We have implemented the following cos:rols to provide the barrier and documentation for regulations:to validate that the byproduct topaz is only released in compliance with 10CFR irgec:.fon i

W We have restHc:  !

4d the ecchnies in Room 257 to storage, cleaning, heat treating and sorting of.MURR irradiated byproduct material that has been sppr6ed by de Gemstone QA program for non.U.S. release. No nonbyproduct topaz will be allowed in Rece 267.

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(2) All transfers into and cut of the Room 267 are documented by MURR employees w n Ic; the date, type of transfer and mass cf the transfer.

(3)

MUFJt employeu will peekage all shipments of byproduct top 2z leaving the Center efter weighirg and documenting the weights. The packages will be sealetl and marked to electly differentiete them from any other packages and make .

.uneuthorized opening easily ddtectable.  !

(4)

MURR employees will keep packages in their custody during the transfer to the air carrier and will obicia document.ation of this transfer. Only MURR irradiated byproduct material will be ellowed in these shipments.

It !s our position that properly trained radiation workers can be relied cn to follow proce obey regulations. The gemstone meterial being hendled in Room 2G7 has all bee ennesive QA program to ensure that each individual stone does not exceed a concentration of Bc/g (2 nCi/g). In practica the concentrations are significantly below the . .

74 Bq/g "imit Small batches of gemstones having these very low radioactive concentrations can be surv typical GM survey instrument with no increase in count. rate detected We believe that the h ic'.cl of byproduct material that has been certified to have a specific activity of les induding pe rsonnel. beta activity does not justify constant surveillance or physical search of trained

e' , t,*

?a;:o 3 Rep?y to Cor.firmotory .A: .:c- Lt".,r CAL 'in. E1 19 ~,.04 We prepose implemes:tirg the following controls goveming the activitin in Roten 267 to addren the issues rcised during the ins section hovember 1-3, IL895. These controh eli be in 71 ace December 18,

1095 nad will replace
he controls given in the CAI Rill-95-004.-

'1; Limit by procedure the activities in Room 267 to the storace, ch aning. heat treadng.

l eorting and h:tndling of byproduct snaterial that has been certified for nor. domestic j release by the MURR Gemstone QA program.

4 GI Uy procedure, requite that all transfers of byproduct meterial int cnd out of Reem 267 will be supervised by a MURR employee.

i

} i35 By precedure, require that the date, type of transfer and mass er all :.ransfers of j

i l'yproduct materialinto and out ofRoom 267 be logged by a MURR empicye-e.

i I4) BV Prxedure, requ! e that biURR employees perform or supervire the pacxaging of

} all tapaz hypnwiir.t tapar laaving the cantar.

15) By procedure, cquire that shipments of byproduct material from Rcom 267 v.ill ba

{ restricted to bmroduct materia} only, and that MURR employees will keep the packsges in their custody during transfer to the air carrier used will obtain i

do:umentation of this transfer.

?

[ (6' Complian:e with the control procedures will be documented by conducting an i annual audit of the physical inventory and records of the matedal balanc< in 1

Room 267.

These stape will snhanes the level of control over byproduct estarial laut.d S Reorn 267 cf MIJRRJ s

We believe that this enhanced level of control will address the issues you raised ud more than i

=6t>4ust:ly protect the public trum any potendul hazards as>ociated with this byproduct material. No f r.hipm6nts of byproduct topez have been mcde since the November 3,1995 exit. % will make thipments as needed meetir.g the ebove policies, but do not anticipats shipping'ue:il after

! N.wember 26,1995. If there are any additional questions, please call John Ernst(314-882 5226) or Charles McKibben (314-882 6204).

2 i Sincerely, , ,.

,.y - -- r b - -

y

.m ,

g J. Charles McKibben James J. Rhyne !

{. Associate Directer Director, MU Research Reactor end Professor of Physics 1

n: J. McCormick S. Weiss, NW./' NRR/ONDB J. Ernst

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