ML12208A034
| ML12208A034 | |
| Person / Time | |
|---|---|
| Site: | University of California-Davis |
| Issue date: | 08/06/2012 |
| From: | Mary Muessle Division of Policy and Rulemaking |
| To: | Klein B McClellan Nuclear Research Center |
| Bassett C | |
| References | |
| IR-12-203 | |
| Download: ML12208A034 (24) | |
See also: IR 05000607/2012203
Text
August 6, 2012
Dr. Barry M. Klein, Reactor Director
5335 Price Avenue, Bldg. 258
McClellan AFB, CA 95652-2504
SUBJECT: UNIVERSITY OF CALIFORNIA-DAVIS - NRC ROUTINE INSPECTION
REPORT NO. 50-607/2012-203 AND NOTICE OF VIOLATION
Dear Dr. Klein:
From July 9 to 11, 2012, the U.S. Nuclear Regulatory Commission (NRC or the Commission)
conducted an inspection at your University of California-Davis/McClellan Nuclear Research
Center. The enclosed report documents the inspection results, which were discussed on
July 12, 2012, with members of your staff, including Walter Steingass, Associate Director for
Reactor Operations, and David Reap, Radiation Safety Officer.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, the NRC has determined that a Severity Level IV
violation of NRC requirements occurred. The violation was evaluated in accordance with the
NRC Enforcement Policy included on the NRCs Web site at www.nrc.gov; select What We Do,
Enforcement, then Enforcement Policy. The violation is cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding it are described in detail in the subject
inspection report. The violation is being cited in the Notice because it constitutes a failure to
meet regulatory requirements that has more than minor safety significance and the licensee
failed to identify the violation.
You are required to respond to this letter within 30 days and should follow the instructions
specified in the enclosed Notice when preparing your response. The NRC will use your
response in part, to determine whether further enforcement action is necessary to ensure
compliance with regulatory requirements.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public
inspections, exemptions, and requests for withholding, a copy of this letter, its 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).
B. Klein -2-
Should you have any questions concerning this inspection, please contact Craig Bassett at
(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Mary Muessle, Deputy Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-607
License No. R-130
Enclosures:
1. Notice of Violation
2. NRC Inspection Report No. 50-607/2012-203
cc: w/encls: See next page
University of California - Davis/McClellan MNRC Docket No. 50-607
cc:
Mr. David Reap, Radiation Safety Officer
5335 Price Avenue, Bldg. 258
McClellan AFB, CA 95652-2504
Mr. Walter Steingass, Reactor Supervisor
5335 Price Avenue, Bldg. 258
McClellan AFB, CA 95652-2504
California Energy Commission
1516 Ninth Street, MS-34
Sacramento, CA 95814
Radiological Health Branch
P.O. Box 997414, MS 7610
Sacramento, CA 95899-7414
Test, Research, and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
B. Klein -2-
Should you have any questions concerning this inspection, please contact Craig Bassett at
(301) 466-4495 or by electronic mail at Craig.Bassett@nrc.gov.
Sincerely,
/RA/
Mary Muessle, Deputy Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Docket No. 50-607
License No. R-130
Enclosures:
1. Notice of Violation
2. NRC Inspection Report No. 50-607/2012-203
cc: w/encls: See next page
DISTRIBUTION:
PUBLIC RidsNrrDprPrta Resource RidsNrrDprPrtb Resource PROB r/f
AAdams, NRR MCompton (Ltr only O5-A4) MNorris (MS T3B46M) GLappert, NRR
CBassett, NRR
ACCESSION NO.: ML12208A034 *concurrence via e-mail TEMPLATE #: NRC-002
OFFICE PROB:RI * PRPB:LA PROB:BC DPR:DD
NAME CBassett GLappert GBowman MMuessle
DATE 7/19/2012 7/26/2012 8/6/12 8/6/12
OFFICIAL RECORD COPY
NOTICE OF VIOLATION
University of California-Davis Docket No. 50-607
McClellan Nuclear Research Center License No. R-130
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted July 9-11, 2012, a
violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy,
the violation is listed below:
Title 10 of the Code of Federal Regulations (10 CFR) Section 19.13(b) states that each licensee
shall make dose information available to workers as shown in records maintained by the
licensee under the provisions of 10 CFR 20.2106. The licensee shall provide an annual report
to each individual monitored under 10 CFR 20.1502 of the dose received in that monitoring year
if: (1) the individuals occupational dose exceeds 1 millisievert (mSv) (100 millirem (mrem)) total
effective dose equivalent or 1mSv (100 mrem) to any individual organ or tissue; or (2) the
individual requests his or her annual dose report.
10 CFR 20.1502 states that each licensee shall monitor exposures to radiation and radioactive
material at levels sufficient to demonstrate compliance with the occupational dose limits of this
part. As a minimum - (a) each licensee shall monitor occupational exposure to radiation from
licensed and unlicensed radiation sources under the control of the licensee and shall supply and
require the use of individual monitoring devices by - (1) adults likely to receive in 1 year from
sources external to the body, a dose in excess of 10 percent of the limits of 20.1201(a), (2)
minors . . ., (3) declared pregnant women . . ., and (4) individuals entering a high or very high
radiation area.
Contrary to the above requirements, the licensee did not provide an annual report to each
individual monitored under 10 CFR 20.1502 for 3 years. Specifically, three different staff
personnel, whose exposures to radiation and radioactive material were monitored in accordance
with Subparagraphs (1) and (4) of Paragraph (a) of 10 CFR 20.1502 and who received
exposures exceeding 100 mrem TEDE and/or 100 mrem to an individual organ or tissue, did not
receive an annual report containing their dose information for exposures received in 2009, 2010,
or 2011.
This has been determined to be a Severity Level IV violation (Section 6.7).
Pursuant to the provisions of 10 CFR 2.201, the University of California-Davis is hereby required
to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555-0001 with a copy to the responsible
inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include:
(1) the reason for the violation, or, if contested, the basis for disputing the violation or severity
level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective
steps that will be taken to avoid further violations, and (4) the date when full compliance will be
achieved. Your response may reference or include previous docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
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action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response,
with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, D.C. 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records component of the NRC=s
Agencywide Documents Access and Management System (ADAMS), to the extent possible, it
should not include any personal privacy, proprietary, or safeguards information so that it can be
made available to the public without redaction. ADAMS is accessible from the NRC Web site at
(the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html. If personal
privacy or proprietary information is necessary to provide an acceptable response, then please
provide a bracketed copy of your response that identifies the information that should be
protected and a redacted copy of your response that deletes such information. If you request
withholding of such material, you must specifically identify the portions of your response that
you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated this 6th day of August, 2012
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-607
Report No: 50-607/2012-203
Licensee: University of California-Davis
Facility: McClellan Nuclear Research Center
Location: McClellan Park
Sacramento, California
Dates: July 9-11, 2012
Inspector: Craig Bassett
Approved by: Gregory T. Bowman, Chief
Research and Test Reactors Oversight Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
University of California-Davis
McClellan Nuclear Research Center
Report No: 50-607/2012-203
The primary focus of this routine, announced inspection was the onsite review of selected
aspects of the University of California-Davis (the licensees) Class I research and test reactor
safety program including: 1) organizational structure and staffing; 2) review, audit, and design
change functions; 3) procedures; 4) radiation protection; 5) environmental monitoring;
6) transportation of radioactive materials; and, 7) material control and accounting since the last
U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The licensees program
was acceptably directed toward the protection of public health and safety and in compliance
with NRC requirements.
Organizational Structure and Functions
The organizational structure and staffing were consistent with the requirements specified
in Technical Specifications Section 6.
Review and Audit and Design Change Functions
The Nuclear Safety Committee was meeting at the required frequency, reviewing the
topics outlined in the Technical Specifications, and conducting audits of facility programs
as required.
The design change program, including review, evaluation, and documentation of
changes to the facility, satisfied NRC requirements.
Procedures
The procedure review, revision, control, and implementation program satisfied Technical
Specifications requirements.
Radiation Protection Program
Surveys were being completed and documented acceptably to permit evaluation of the
radiation hazards present.
Postings met the regulatory requirements specified in Title 10 of the Code of Federal
Regulations Parts 19 and 20.
Personnel dosimetry was being worn as required and doses were well within the
licensees procedural action levels and NRCs regulatory limits.
Radiation survey and monitoring equipment was being maintained and calibrated as
required.
Acceptable radiation protection training was being provided to facility personnel.
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One severity level IV violation was noted for failure to provide McClellan Nuclear
Research Center personnel with an NRC Form 5 for the past 3 years as required by
Environmental Monitoring
Effluent monitoring satisfied license and regulatory requirements and releases were
within the specified Technical Specification and regulatory limits.
Transportation of Radioactive Materials
Radioactive material was being shipped in accordance with the applicable regulations.
Material Control and Accounting
Special nuclear material was acceptably controlled and tracked as required by 10 CFR
Parts 70 and 74.
REPORT DETAILS
Summary of Plant Status
The University of California-Davis (UCD, the licensees) two megawatt (MW) TRIGA reactor
continued to be operated in support of neutron radiography, medical isotope production, neutron
tomography, and experimental sample irradiation. During the inspection, the reactor was
operated up to eight hours per day at a nominal power level of one MW to support neutron
radiography and sample irradiation.
1. Organization and Staffing
a. Inspection Scope (Inspection Procedure [IP] 69006)
The inspector reviewed the following regarding the University of
California-Davis/McClellan Nuclear Research Center (UCD/MNRC) organization,
staffing, and responsibilities to ensure that the requirements of Technical
Specification (TS) Section 6.1, Revision (Rev.) 13, dated March 28, 2003, were
being met:
- Management responsibilities
- Qualifications of facility personnel
- Current UCD/MNRC organizational structure and staffing
- Staffing requirements for safe operation of the research reactor facility
- Selected UCD/MNRC Operations Logs and UCD/MNRC Startup
Checklists for 2012 documenting shift staffing
- University of California, Davis/McClellan Nuclear Radiation Center 2010
Annual Report, submitted to the NRC on June 28, 2011
- University of California, Davis/McClellan Nuclear Research Center 2011
Annual Report, submitted to the NRC on June 25, 2012
- Facility Procedure UCD/MNRC-0004-DOC-13, Technical Specifications
for the McClellan Nuclear Research Center (MNRC) Reactor Facility,
Rev. 13, approval date March 28, 2003
- Facility Procedure UCD/MNRC-0045-DOC-01, Quality Assurance
Program for McClellan Nuclear Research Center (MNRC), Rev. 1,
approval date November 22, 1999
- American Nuclear Society Standard 15.4-1988, Selection and Training of
Personnel for Research Reactors, standard approval dated June 9, 1988
b. Observations and Findings
The organization at the UCD/MNRC was as required by TS Section 6. The Vice
Chancellor was the one designated as the licensee for the university. The
UCD/MNRC facility was under the direct control of the Reactor Director who
reported to and was accountable to the Vice Chancellor for the safe operation
and maintenance of the facility. Individuals at the facility in management
positions such as the Reactor Supervisor and the Radiation Safety Officer
reported to the Reactor Director and were responsible for implementing
UCD/MNRC policies, for operation of the facility, for safeguarding facility
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personnel and the public from undue radiation exposure, and for adhering to the
operating license and technical specifications.
As noted in NRC Inspection Report No. 50-607/2008-203, the licensees
organizational chart for the UCD/MNRC as shown in the TS indicated that the
chain of command included an Operations Manager who was to be in charge of
reactor operations. The chart also indicated a staff position of Health Physics
(HP) Supervisor. These two positions were no longer part of the facility
organizational structure. During a previous inspection, the inspector noted that
the licensee had initiated, reviewed, and approved a TS change to reflect the
current structure. The licensee indicated that the change had been submitted to
the NRC on July 15, 2011 and was thus awaiting NRC review.
The organization and staffing at the facility, required for reactor operation, were
as specified in the TS. Qualifications of the staff members met program
requirements. Review of records demonstrated that management responsibilities
were discharged as required by applicable procedures. It was noted that no staff
changes had been made since the last NRC inspection which occurred in
January 2012 (refer to NRC Inspection Report No. 50-607/2012-201).
c. Conclusion
With the recent TS change submitted to the NRC, the licensees current
organization and staffing were in compliance with the requirements specified in
the TS Section 6.
2. Review and Audit and Design Change Functions
a. Inspection Scope (IP 69007)
To verify that the required reviews and audits were being completed and that
facility changes were reviewed and approved as required by TS Section 6.2, the
inspector reviewed selected aspects of:
- 2010 Annual Audit of the MNRC completed November 4, 2010
- 2011 Annual Audit of the MNRC completed December 9, 2011
- Nuclear Safety Committee meeting minutes for June 2011 through the
present
- UCD/MNRC Facility Modification Notebook containing the Facility
Modification Log forms
- Selected Facility Modification Installation Authorization Forms and
associated Facility Modification Checklist forms processed during 2011
and to date in 2012
- University of California, Davis/McClellan Nuclear Radiation Center 2010
Annual Report, submitted to the NRC on June 28, 2011
- University of California, Davis/McClellan Nuclear Research Center 2011
Annual Report, submitted to the NRC on June 25, 2012
-3-
- Facility Procedure UCD/MNRC-0043-DOC-04, Facility Modification
Procedure, Rev. 4, approval dated January 8, 2008
- Facility Procedure UCD/MNRC-0045-DOC-01, Quality Assurance
Program for McClellan Nuclear Research Center (MNRC), Rev. 1,
approval dated November 22, 1999
b. Observations and Findings
(1) Review and Audit Functions
Composition of the Nuclear Safety Committee (NSC) and qualifications of
NSC members were as specified in TS Section 6.2.1. Minutes of the
NSC meetings indicated that the committee continued to meet
semiannually as required by TS Section 6.2.2 and provided the reviews
and oversight specified in TS Section 6.2.3. Through records review the
inspector determined that reviews were conducted by the NSC or
designated representatives. Topics of those reviews were as required by
the TS and provided sufficient guidance, direction, and oversight to
ensure acceptable use of the reactor.
The inspector reviewed the two most recent annual audits conducted at
the facility. The audits were comprehensive and reviewed the activities
specified in TS Section 6.2.4, including various aspects of the reactor
facility operations and associated programs. No discrepancies were
found but several recommendations were made as a result of the audits.
(2) Design Change Functions
The regulatory requirements stipulated in Title 10 of the Code of Federal
Regulations (10 CFR) Section 50.59 Changes, tests, and experiments,
were implemented at the facility through Facility Procedure UCD/MNRC-
0043-DOC-04, Facility Modification Procedure. The procedure was
developed to address activities that affected changes to the facility as
described in the Safety Analysis Report (SAR), changes to MNRC
procedures, and changes to or development of new tests or experiments
not described in the SAR. The procedure adequately incorporated criteria
provided by the regulations with additional requirements mandated by
local conditions.
The inspector reviewed entries in the Facility Modification Log Notebook
for the period from 2011 and to date in 2012. The Notebook entries
showed that no modifications dealing with the radiation protection system
had been proposed since the last inspection.
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c. Conclusion
The NSC was meeting as required and reviewing the topics outlined in the TS.
Audits of various reactor operations and programs were being conducted as
required. The design change program satisfied NRC requirements.
3. Procedures
a. Inspection Scope (IP 69008)
To verify compliance with TS Section 6.4, the inspector reviewed selected
portions of the following:
- Selected Document Review forms completed by staff members
- UCD/MNRC Controlled Document Review and Approval Reference List
- MNRC Document List listing all the licensees current procedures and
the date each was last reviewed
- Various memoranda from the Reactor Supervisor to the staff indicating
document review assignments and responsibilities
- Facility Procedure UCD/MNRC-0005-DOC-09, Document Control Plan,
Rev. 9, approval dated February 16, 2007
- Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation
Protection Procedures, Rev. 18, approval dated January 29, 2008
- Various of the Addenda located in Facility Procedure
UCD/MNRC-0042-DOC-9, MNRC Health Physics Instrumentation
Calibration and Test Procedures, latest reveiws of the addenda were
completed on January 13, 2011
b. Observations and Findings
According to TS Section 6.4 it was required that procedures be prepared and
approved for the activities listed in that section. The procedures were required to
be approved by the UCD/MNRC Director. Facility Procedure UCD/MNRC-0005-
DOC stipulated that the UCD/MNRC staff perform a biennial review of each
active document to assure that it was current. The inspector noted that
Operations and Health Physics procedures were typically being reviewed
annually by the licensee while maintenance and other procedures were reviewed
biennially. Changes to the procedures required the approval of the UCD/MNRC
Director and all changes were required to be documented.
The inspector determined that the UCD/MNRC procedures were generally being
reviewed as required, that procedures were approved by the Director, and that
changes were documented as required as well. It was also noted that three of
four procedures that were assigned to be reviewed by the Experiment
Coordinator had not been reviewed within the two year time frame specified by
procedure. These procedures were: 1) Facility Procedure UCD/MNRC-0081-
DOC-00, Experiment Coordination Checklist, last review dated January 6,
2010, 2) Facility Maintenance Procedure UCD/MNRC-0058-OMM-00, Neutron
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Irradiator, last review dated December 18, 2009, and 3) Facility Maintenance
Procedure UCD/MNRC-00-OMM-01, Central Facility, last review dated
December 18, 2009. The licensee indicated that the former Experiment
Coordinator had not reviewed the procedures in a timely manner and the new
person hired for that position had not had sufficient time or experience to date to
conduct the review. The licensee was informed that this issue would be followed
by the NRC as an Inspector Follow-up Item (IFI) and would be reviewed during a
future inspection (IFI 50-607/2012-203-01)
c. Conclusion
The current procedure review, revision, control, and implementation program
satisfied TS requirements.
4. Radiation Protection
a. Inspection Scope (IP 69012)
The inspector reviewed selected portions of the following regarding the licensee's
radiation protection program to ensure that the requirements of 10 CFR Part 20
and TS Sections 4.7 and 6.4.2 were being met:
- Calibration of selected radiation monitoring instruments
- List documenting all MNRC personnel who were authorized to handle
radioactive material dated July 10, 2012
- The Self Inspection Checklist completed by the Radiation Safety Officer
(RSO) for 2010 and 2011
- Personal monthly dosimetry results for 2010, 2011, and through May
2012
- 2010 MNRC Radiation Safety Program Review Report, completed by
members of the NSC and dated December 6, 2010
- 2011 MNRC Radiation Safety Program Review Report, completed by
members of the NSC and dated November 28, 2011
- Lesson plans, training objectives, and qualification cards for training of
personnel by the RSO
- Selected daily, weekly, and quarterly contamination and radiation survey
results for the past two years
- Licensee Radiological Investigation Reports for 2011 and 2012 -
Numbers 11-01, 12-01, 12-02, and 12-03, as documented in the Special
Surveys Notebook
- University of California, Davis/McClellan Nuclear Radiation Center 2010
Annual Report, submitted to the NRC on June 28, 2011
- University of California, Davis/McClellan Nuclear Research Center 2011
Annual Report, submitted to the NRC on June 25, 2012
- Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation
Protection Procedures, Rev. 18, approval dated January 29, 2008
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- Facility Procedure UCD/MNRC-0042-DOC-9, MNRC Health Physics
Instrumentation Calibration and Test Procedures, which included:
Addendum No. 01, Beta Dose Rate Calibration Procedure,
Rev. 6, dated August 22, 2007
Addendum No. 29, Ludlum Model 177 Calibration Procedure,
Rev. 3, dated February 22, 1999
Addendum No. 30, Ludlum Model 177-54 Calibration Procedure,
Rev. 3, dated February 22, 1999
Addendum No. 31, Ludlum Model 3 Calibration Procedure,
Rev. 4, dated September 18, 2007
Addendum No. 34, RAM Calibration Procedure, Rev. 4, dated
June 8, 2009
Safety Analysis Report, Revision 4, dated December 1999, Chapter 11,
Radiation Protection and Waste Management Program, Revision 2,
dated April 3, 1998
- American National Standard ANSI/ANS-15.11-1993, Radiation
Protection at Research Reactor Facilities, standard approval dated July
23, 1993
The inspector also toured the facility and observed the use of dosimetry and
radiation monitoring equipment. In addition, licensee personnel were interviewed
and radiological signs and postings were observed.
b. Observations and Findings
(1) Surveys
Daily checklists and weekly, quarterly, and special contamination and
radiation surveys, outlined in the licensees UCD/MNRC Radiation
Protection Procedures, were being completed by the RSO or other
qualified staff members as required. Any contamination detected in
concentrations above established action levels was noted and the
affected area was decontaminated. Results of the surveys were typically
documented on survey maps and posted at the entrances of the various
areas surveyed so that facility workers could check and be
knowledgeable of the radiological conditions that existed in those areas.
During the inspection the inspector accompanied a licensee
representative to observe the completion of a Weekly Radiation and
Contamination Survey. Areas surveyed at the facility included the
Equipment Room, the Reactor Room, and associated support areas. No
anomalies were noted.
(2) Postings and Notices
Copies of current notices to workers were posted in appropriate areas in
the facility. The required radiological signs were posted at the entrances
to controlled areas. Other postings also showed the industrial hygiene
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hazards that were present in the areas as well. The copy of NRC Form-3
noted at the facility was the latest issue, as required by 10 CFR Part 19,
and was posted on a bulletin board near the main entrance to the facility
where visitors are required to sign the Visitors Log.
(3) Dosimetry
Personnel were observed to be properly wearing extremity and whole
body dosimetry in the controlled areas. The dosimeters being used were
4-chip thermoluminescent dosimeters (TLDs) processed monthly by a
NVLAP certified vendor (Mirion Technologies (formerly Global Dosimetry
Solutions)). The TLDs were used for whole body monitoring and TLD
finger rings were used for extremity monitoring.
An examination of the TLD results indicating radiological exposures at the
facility for the past two years showed that the highest occupational doses,
as well as doses to the public, were within 10 CFR Part 20 limits. The
highest annual whole body exposure received by a single licensee
employee for 2010 was 169 millirem deep dose equivalent (DDE). The
highest annual extremity exposure for 2010 was 562 millirem shallow
dose equivalent (SDE) and the highest skin or other shallow dose was
171 mr SDE. The highest annual whole body exposure received by a
single person for 2011 was 50 millirem DDE. The highest annual
extremity exposure for 2011 was 106 millirem SDE and the highest skin
or other shallow dose was 96 mr SDE. Through May 2012, the highest
individual whole body exposure that had been received has been 35
millirem DDE; the highest extremity exposure has been 99 millirem SDE;
and, the highest skin or other shallow dose was 142 mr SDE.
(4) Radiation Monitoring Equipment
Selected calibration records of portable survey meters, friskers, fixed
radiation detectors, and air monitoring instruments in use at the facility
were reviewed. The records showed that the meters and detectors were
either calibrated by reactor staff or the instruments were sent off site to be
calibrated by a contractor. The calibrations were tracked and
documented as required. The inspector confirmed that the frequencies of
the calibrations satisfied the requirements established in the
TS Section 4.7 and 10 CFR 20.1501(b). All instruments checked by the
inspector had a current calibration sticker attached.
(5) Radiation Protection Program
The radiation protection program was described and controlled by
procedures and policies that were well documented as required by TS Section 6.4.2 and 10 CFR 20.1101(a). Annual audits of the radiation
protection program had been completed by the RSO on July 6, 2011, and
June 18, 2012. These were documented in the form of a Self
Identification Checklist. Separate audits of the program were conducted
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by members of the NSC on December 6, 2010, and November 28, 2011.
These audits satisfied the periodic program review required by 10 CFR
20.1101(c). No problems were noted by the NSC audit team but various
recommendations for improvements were made.
(6) Personnel Training
Personnel training required by 10 CFR 19.12, Instruction to Workers,
was provided by the RSO. In a graded approach, there were five levels
or plans for training, designated as A through E. The type of training
provided to an individual was dictated by the type of work to be performed
and/or what controlled area(s) the person would be required to enter.
Plan A was training provided for visitors to the facility. Plan B was
training provided to staff personnel who were also considered Radiation
Workers. Plan C was initial training for reactor operators hired at the
facility. Subsequent training on this material was provided to operators
during their requalification training. Plan D was given annually to all
facility faculty and staff. Plan E was for ancillary personnel such as
custodial service workers.
The inspector reviewed the training given to various personnel. Three
individuals had received Plan B training, as well as job specific training,
and were to be involved in the Iodine-125 production program. One
individual who was hired as the facility Electronic Engineer had received
Plan C training. He was also participating in the Reactor Operator
training program at the facility. The inspector noted that training was
being completed as required and it appeared to be adequate.
(7) Radiation Work Permit Program
The inspector reviewed the Radiation Work Permits (RWPs) that had
been written, used, and closed out during 2011 and those issued to date
in 2012. It was noted that no Special RWPs had been issued recently.
Of those RWPs that had been written for 2011 and 2012, the inspector
determined that the controls, precautions, and instructions specified in the
RWPs appeared to be appropriate and were being followed. It was also
noted that the RWPs had been reviewed by the RSO as required.
(8) NRC Form 5
10 CFR 19.13(b) states that each licensee shall make dose information
available to workers as shown in records maintained by the licensee
under the provisions of 10 CFR 20.2106. The licensee shall provide an
annual report to each individual monitored under 10 CFR 20.1502 of the
dose received in that monitoring year if: (1) The individuals occupational
dose exceeds 1 mSv (100 mrem) TEDE or 1mSv (100 mrem) to any
individual organ or tissue; or (2) The individual requests his or her annual
dose report.
-9-
10 CFR 20.1502 states that each licensee shall monitor exposures to
radiation and radioactive material at levels sufficient to demonstrate
compliance with the occupational dose limits of this part. As a minimum -
(a) Each licensee shall monitor occupational exposure to radiation from
licensed and unlicensed radiation sources under the control of the
licensee and shall supply and require the use of individual monitoring
devices by - (1) Adults likely to receive in 1 year from sources external to
the body, a dose in excess of 10 percent of the limits of 20.1201(a),
(2) Minors . . ., (3) Declared pregnant women . . ., and (4) Individuals
entering a high or very high radiation area.
In Paragraph 4 of the Privacy Act Statement portion of NRC Form 5, it
states that the licensee must complete NRC Form 5 on each individual for
whom personal monitoring is required under 10 CFR 20.1502.
As noted above, during the inspection of the MNRC Radiation Protection
Program, the inspector reviewed the dosimetry records of those staff
members working at the facility. It was noted that in 2009, one individual
had received a dose to the skin, SDE, of 168 mrem. In 2010, two
individuals received a whole body dose, TEDE, greater than 100 mrem.
One person received a deep dose equivalent (DDE) of 114 mrem and the
other received a DDE of 169 mrem. In 2011, one individual received a
dose to the skin of 106 mrem. Because these doses exceeded the limit
established that required an NRC Form 5 to be issued, the inspector
asked to review the NRC Form 5 for these individuals. MNRC personnel
indicated that the last annual report of dose (NRC Form 5) that anyone
had received was the one for the year 2008.
The inspector was informed that the UC Davis Environmental Health and
Safety (EH&S) Department handled the dosimetry for the facility and
made arrangements (maintained a contract) with a vendor to issue and
process the dosimetry. The vendor would be the entity that would track
exposures and issue the NRC Form 5 information through the campus
EH&S Department. Therefore, the EH&S Department would be the group
responsible for requesting and then issuing the proper forms to MNRC
personnel. Monthly dosimetry results were generally forwarded from the
campus EH&S office to the MNRC RSO. However, the campus EH&S
office had decided not to request NRC Form 5 for the individuals at the
MNRC as a cost cutting measure. The licensee was informed that failure
to provide facility personnel with NRC Form 5 information for the past
three years was a violation (VIO) of 10 CFR 19.13 (VIO 50-607/
2012-203-02).
(9) Facility Tours
The inspector toured the main Staging or Set-Up area, the Equipment
Room, the Reactor Room, and various support areas with licensee
representatives on various occasions and observed on-going activities. It
was noted that facility radioactive material storage areas were properly
- 10 -
posted. No unmarked radioactive material was noted. Radiation and
High Radiation Areas were posted as required and properly controlled.
c. Conclusion
The inspector determined that the Radiation Protection and As Low As
Reasonably Achievable (ALARA) Programs, as implemented by the licensee,
generally satisfied regulatory requirements because: 1) surveys were completed
and documented acceptably to permit evaluation of the radiation hazards
present; 2) postings at the facility met regulatory requirements; 3) personnel
dosimetry was being worn as required and recorded doses were well within the
NRCs regulatory limits; 4) radiation survey and monitoring equipment was being
maintained and calibrated as required; 5) the Radiation Protection Program was
acceptable and was being reviewed annually as required; and, 6) acceptable
radiation protection training program was being provided to facility personnel.
One apparent violation was noted for failure to provide various MNRC personnel
with an NRC Form 5 for the past three years as required by 10 CFR 19.13.
5. Effluent and Environmental Monitoring
a. Inspection Scope (IP 69004)
The inspector reviewed the following to verify compliance with the requirements
of 10 CFR Part 20 and TS Section 6.4.2(d):
- Solid Radwaste Logbook
- Quarterly Environmental TLD Reports for 2010, 2011, and to date in 2012
- Radioactive Material Discharged Into Sanitary Sewer form maintained
and updated for 2010, 2011, and to date in 2012
- University of California, Davis/McClellan Nuclear Radiation Center 2010
Annual Report, submitted to the NRC on June 28, 2011
- University of California, Davis/McClellan Nuclear Research Center 2011
Annual Report, submitted to the NRC on June 25, 2012
- Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation
Protection Procedures, Rev. 18, approval dated January 29, 2008
- Facility Procedure UCD/MNRC-0042-DOC-9, MNRC Health Physics
Instrumentation Calibration and Test Procedures, which included:
Addendum No. 08, Stack CAM Alarm Setpoint Procedure,
Rev. 7, dated May 16, 2007
Addendum No. 12, Weekly Stack CAM Source Check
Procedure, Rev. 4, dated October 27, 2005
Addendum No. 16, Canberra 2404 Calibration Procedure,
Rev. 7, dated May 14, 2008
Addendum No. 48, Stack CAM Calibration Procedure, Rev. 2,
dated May 10, 2007
Addendum No. 49, Reactor CAM Calibration Procedure, Rev. 1,
dated May 16, 2007
- 11 -
Addendum No. 50, Bay CAM Calibration Procedure, Rev. 1,
dated May 21, 2007
b. Observations and Findings
The inspector determined that gaseous releases continued to be monitored as
required, were acceptably analyzed, and were documented in the annual
operating reports. To ensure that airborne concentrations of gaseous releases
were within the concentrations stipulated in 10 CFR Part 20, Appendix B, Table
2, below the dose constraint specified in 10 CFR 20.1101(d) of 10 millirem per
year, and within TS limits, the licensee completed a calculation of the dose to
members of the public as the result of reactor operations. This calculation was
performed using the Environmental Protection Agency (EPA) computer code,
CAP88-PC, Version 3.0. The results indicated an annual dose to the public of
1.33E-2 millirem for 2010 and 1.06E-2 millirem for 2011.
There were no liquid releases from the facility during 2010, 2011, and to date in
2012. It was also noted that no solid radioactive waste had been
released/shipped from the facility during 2010, 2011, and to date in 2012.
Environmental water samples were collected, prepared, and sent to a vendor for
analysis consistent with procedural requirements. The results of these analyses
were all within regulatory limits. On-site and off-site gamma radiation monitoring
was completed using various environmental TLDs in accordance with the
applicable procedures as well. The review of data indicated that there were no
measurable doses above any regulatory limits. The highest unrestricted area
dose measured by an environmental TLD was 23 millirem for 2010 and
17 millirem for 2011.
c. Conclusion
Effluent monitoring satisfied license and regulatory requirements and releases
were within the specified TS requirements and regulatory limits.
6. Transportation
a. Inspection Scope (IP 86740)
To verify compliance with regulatory and procedural requirements for transferring
or shipping licensed radioactive material, the inspector reviewed the following:
- Selected licenses of various UCD/MNRC consignees
- Selected records of various types of radioactive material shipments
including completed radiological survey forms
- Selected training records for staff personnel authorized to ship hazardous
material in accordance with the regulations specified by the Department
of Transportation (DOT)
- 12 -
- Facility Procedure UCD/MNRC-0029-DOC-18, UCD/MNRC Radiation
Protection Procedures, Rev. 18, approval dated January 29, 2008
- Appendix A, Limited Quantity of Class 7 (Radioactive) Materials
Checklist, of Section 21 of Facility Procedure UCD/MNRC-0029-DOC-18
- NUREG-1660/RAMREG-002, U.S.-Specific Schedules of Requirements
for Transportation of Specified Types of Radioactive Material
Consignments, published November 1998
b. Observations and Findings
Through records review and discussions with licensee personnel, the inspector
determined that the licensee had shipped various types of radioactive material
since the previous inspection in this area. The records indicated that the
radioisotope types and quantities were calculated and dose rates were generally
measured correctly. All radioactive material shipment records reviewed by the
inspector had been completed in accordance with DOT and NRC regulations.
The inspector verified that the licensee maintained copies of shipment recipients
licenses to possess radioactive material as required and that the licenses were
verified to be current prior to initiating a shipment. The inspector also reviewed
the training of MNRC staff members responsible for shipping radioactive
material. The inspector verified that licensee personnel designated as shippers
had received the appropriate training covering the DOT, International Air
Transport Association (IATA), and International Civil Aviation Organization
(ICAO) requirements within the past three years.
c. Conclusion
Radioactive material was being shipped in accordance with the applicable
regulations.
7. Material Control and Accounting
a. Inspection Scope (IP 85102)
To verify compliance with Title 10 of the Code of Federal Regulations
(10 CFR) Parts 70 and 74 and TS Sections 5.3 and 5.4, the inspector reviewed:
- UCD/MNRC Present Element Location forms
- SNM Physical Inventory forms for 2011 through 2012
- Control of Special Nuclear Material (SNM) storage areas
- MNRC Core Configuration map dated December 20, 2010
- Fuel Handling Checklists for fuel handling in December 2011
- UCD/MNRC Fuel Transfer Forms for 2011 (none had been completed to
date in 2012)
- Core and Storage Boards located in the Control Room and in the Reactor
Room
- 13 -
- Selected entries in the Fuel Movement Notebook documenting the date
each element was received, fuel element movement, and current location
- Nuclear Material Transaction Reports (DOE/NRC Form 741) for the time
period from October 2010 through April 2012
- Material Balance Reports (DOE/NRC Form 742) for the time period from
October 2010 through April 2012
- Physical Inventory Listing forms (DOE/NRC Form 742C) for the time
period from October 2010 through April 2012
- Facility Procedure UCD/MNRC-0011-OMM-5240-05, Fuel, Rev. 5,
approval dated April 19, 2001
- Facility Procedure UCD/MNRC-0019-OMM-5220-04, Fuel Handling
Tools, Rev. 4, approval dated January 12, 2009
b. Observations and Findings
Records indicated that the licensee accounted for all SNM maintained under the
R-130 license. SNM material status and transaction reports, documenting what
the licensee possessed and what happened to the material in 2010, 2011, and
2012, had been completed and submitted to the appropriate regulatory agencies
in a timely manner and as required by 10 CFR 74.13(a). Physical inventories
were conducted annually as required.
The inspector toured the facility and verified that the licensee was using and
storing SNM in the designated areas as required by 10 CFR 70.41(a). Through
tours and records review, the inspector verified that the total amount of SNM in
use or in storage at the facility was within the possession limits specified in the
license.
The inspector also observed and verified that fuel elements were being stored in
the appropriate and approved locations. Because of the operations schedule,
the inspector was unable to observe an inventory and verify the serial numbers of
any irradiated fuel elements from the core. Fuel element locations designated on
various forms were cross referenced with the latest Core and Storage Map and
with the Core and Storage Boards in the Control Room and the Reactor Room.
All entries matched and were correct. No problems were noted.
c. Conclusion
The licensee was acceptably controlling and tracking SNM as required by
10 CFR Parts 70 and 74.
8. Exit Interview
The inspection scope and results were summarized on July 11, 2012, with members of
licensee management. The inspector described the areas inspected and discussed the
inspection findings. The licensee acknowledged the findings presented and did not
identify as proprietary any of the material provided to or reviewed by the inspector during
the inspection. No dissenting comments were received from the licensee.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
H. Bollman Facility Manager and Senior Reactor Operator (SRO)
T. Essert Electronics Engineer and RO Trainee
H. Egbert Radiography Supervisor and SRO
M. Lerche Associate Director for Research/Education Coordination and Experiment
Coordinator
B. Liu Research Support Engineer
D. Reap Radiation Safety Officer, Security Officer, and SRO
W. Steingass Associate Director for Reactor Operations and Reactor Supervisor
R. Walker Radiographer/Mechanic
INSPECTION PROCEDURES USED
IP 69004: Class I Research and Test Reactor Effluent and Environmental
Monitoring
IP 69006: Class I Research and Test Reactor Organization, Operations, and
Maintenance Activities
IP 69007: Class I Research and Test Reactor Review and Audit and Design
Change Functions
IP 69008: Class I Research and Test Reactor Procedures
IP 69012: Class I Research and Test Reactor Radiation Protection
IP 85102: Material Control and Accounting
IP 86740: Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-607/2012-201-01 IFI Follow-up on the licensees actions to ensure that three
procedures are reviewed and revised as needed as soon as
possible and appropriate.
50-607/2012-201-02 VIO Failure to provide various MNRC facility personnel with NRC Form
5 information for the past three years as required by
Closed
None
-2-
PARTIAL LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations
ALARA As low as reasonably achievable
DOT Department of Transportation
EPA Environmental Protection Agency
HP Health Physics
IFI Inspector Follow-up Item
IP Inspection procedure
mrem millirem
mSv millisievert
MNRC McClellan Nuclear Research Center
MW megawatt
NRC U.S. Nuclear Regulatory Commission
NSC Nuclear Safety Committee
PDR Public Document Room
Rev. Revision
RSO Radiation Safety Officer
SRO Senior Reactor Operator
RWP Radiation Work Permit
SDE Shallow dose equivalent
TEDE Total Effective Dose Equivalent
TLD Thermoluminescent dosimeter
TS Technical Specifications
UCD University of California-Davis
VIO Violation