IR 05000186/2022201

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the Curators of the University of Missouri - U.S. NRC Routine Inspection Report No. 05000186/2022201
ML22137A321
Person / Time
Site: University of Missouri-Columbia
Issue date: 06/14/2022
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Robertson J
Univ of Missouri - Columbia
Bassett C
References
IR 2022201
Download: ML22137A321 (14)
v • d • e


Text

June 14, 2022

SUBJECT:

THE CURATORS OF THE UNIVERSITY OF MISSOURI - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000186/2022201

Dear Dr. Robertson:

From April 25-28, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a routine, announced inspection at the Missouri University Research Reactor facility. The enclosed report documents the results of that inspection.

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

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by electronic mail at Craig.Bassett@nrc.gov.

Sincerely, Digitally signed Travis L. Tate by Travis L. Tate Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-186 License No. R-103 Enclosure:

As stated cc: See next page

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

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

ML22137A321 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME CBassett NParker TTate DATE 5/19/2022 5/20/2022 6/14/2022

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-186 License No.: R-103 Report No.: 05000186/2022201 Licensee: The Curators of the University of Missouri Facility: Missouri University Research Reactor Location: Columbia, Missouri Dates: April 25-28, 2022 Inspector: Craig H. Bassett Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY The Curators of the University of Missouri University of Missouri-Columbia Research Reactor Inspection Report No. 05000186/2022201 The primary focus of this routine, announced inspection included the on-site review of selected aspects of the Missouri University Research Reactor (MURR) facility safety program, including:

(1) effluent and environmental monitoring; (2) review and audit and design change functions; (3) procedures; (4) emergency preparedness; (5) radiation protection; and (6) transportation activities. One U.S. Nuclear Regulatory Commission (NRC) previously identified item was also reviewed. The NRC staff determined the licensees program was acceptably directed toward the protection of the public health and safety and in compliance with NRC requirements.

Effluent and Environmental Monitoring

  • Effluent and environmental monitoring satisfied regulatory requirements and releases were within regulatory and technical specification (TS) limits.

Review and Audit and Design Change Functions

  • Review, oversight, and audit functions required by the TSs were completed by the Reactor Advisory Committee (RAC).
  • Changes to equipment, procedures, and experiments were evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments, and were reviewed and approved by the RAC as required by the TSs.

Procedures

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

Emergency Preparedness

Radiation Protection

  • The radiation protection program was implemented and met regulatory requirements.

Transportation Activities

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

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

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

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

  • memo to file, 2021 Dose to Individual Members of the Public
  • 2021 ALARA [As Low As Reasonably Achievable] review of effluents
  • results of the analyses of environmental vegetation, soil, and water samples
  • quarterly reports of environmental thermoluminescence dosimeter results for 2021 and to date in 2022
  • University of Missouri-Columbia Research Reactor Operations Annual Report January 1, 2021, through December 31, 2021 b. Observations and Findings (1) Gaseous and Liquid Releases The inspector confirmed that liquid releases to the environment were within the limits specified in 10 CFR Part 20, Appendix B, Table 3 as documented in the licensees annual operations reports. The inspector also verified that airborne concentrations of gaseous releases were within the concentration limits stipulated in 10 CFR Part 20, Appendix B, Table 2 and TS 3.7.b.

The inspector confirmed that the licensee used an occupancy factor and the Environmental Protection Agency computer code, COMPLY v1.6, to calculate the highest dose a member of the public could receive in an unrestricted area due to facility gaseous releases. The inspector found that the highest dose to a member of the public was calculated to be less than one millirem per year (mrem/yr) for 2021 which was well below the 10 mrem/yr dose constraint stipulated in 10 CFR 20.1101, Radiation protection programs, paragraph (d).

(2) Environmental Soil, Water, and Vegetation Samples The inspector confirmed that environmental samples in 2021 were collected as required and results of the sample analyses provided further verification that facility effluents were not measurably impacting the environment as required by TS 3.7.c.

(3) Environmental Radiation Monitoring The inspector noted that environmental monitoring of gamma radiation was conducted using dosimetry badges in accordance with applicable procedures. The-3-

inspector noted there were no radiation doses detected in uncontrolled areas from operation of the reactor at levels that would result in a member of the public exceeding the limits in 10 CFR Part 20, Subpart D, Radiation Dose Limits for Individual Members of the Public.

c. Conclusion The inspector determined the licensees effluent and environmental monitoring satisfied regulatory requirements, and gaseous and liquid releases were within regulatory and TS limits.

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

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

  • documentation of the licensees annual audits for 2021
  • various 50.59 Screen forms completed by the licensee
  • MURR reactor operations annual report for calendar year (CY) 2021
  • select RAC and subcommittee meeting minutes from 2020 to the present b. Observations and Findings Through records review, the inspector verified that the RAC provided independent oversight of reactor operations and the RAC and subcommittees fulfilled the review functions required by TS 6.2.a. The inspector also confirmed that the composition and meeting frequency of the RAC and subcommittees satisfied the requirements of TS 6.2.b.

The inspector verified that audits of facility operations, corrective actions, and emergency preparedness were performed within the periodicity required by TS 6.2.e. In addition, the inspector noted that audit results were assessed by the responsible manager and any actions required were placed in the MURR corrective action program to be followed until the corrective actions are complete.

The inspector reviewed recently completed 10 CFR 50.59 screen forms related to selected licensee changes. The inspector confirmed that the facility design change program was implemented in accordance with the regulations and the applicable licensee procedures. The inspector also verified that the RAC reviewed any proposed changes in accordance with TS 6.2.a.(1).

c. Conclusion The inspector determined the oversight, review, and audit functions required by the TS were completed by the RAC and subcommittees. The inspector also determined that-4-

changes to the facility, experiments, and procedures were evaluated using the criteria specified in 10 CFR 50.59.

3. Procedures a. Inspection Scope (IP 69008)

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

  • select health physics (HP), shipping, and calibration procedures
  • various reports and audits related to procedure revisions and required reviews b. Observations and Findings The inspector noted that the licensee developed procedures as required by TS 6.4.a - b.

The inspector reviewed the process used to change, review, and approve procedures.

All procedures reviewed by the inspector were reviewed by management and approved by the RAC as required by the TSs. The inspector also observed that licensee staff completed activities and operations in accordance with the applicable procedures.

c. Conclusion The inspector determined the procedure review, revision, and control program satisfied TS requirements.

4. Emergency Preparedness a. Inspection Scope (IP 69011)

To verify compliance with Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, and the licensees E-Plan, the inspector reviewed selected aspects of the licensees program, including:

  • select emergency implementing procedures
  • MURR annual on-site emergency drill and critique for 2021
  • competed forms documenting emergency locker inventories
  • letter from Office of City Manager reaffirming the support of the City of Columbia Fire Department for MURR
  • MURR E-Plan, dated January 3, 2019 b. Observations and Findings (1) Emergency Plan and Implementing Procedures The inspector verified that the latest revision of the facility E-Plan dated January 3, 2019, was in accordance with the requirements of 10 CFR 50.54(q), Emergency-5-

plans. The inspector verified that the E-Plan and implementing procedures were reviewed annually as required by the E-Plan.

(2) Emergency Equipment, Inventories, and Drills The inspector verified that emergency equipment lockers were maintained at the University of Missouri-Columbia Police Department Headquarters and in the MURR lobby storage room. The inspector confirmed that the emergency lockers were inventoried by reactor operations staff on a quarterly basis as required by the E-Plan.

The inspector also found that Emergency Call Lists were revised and updated as required in the E-Plan.

Through record reviews, the inspector determined that emergency drills were conducted annually and included the participation of off-site support groups on a biennial basis. The inspector noted that scenarios written for the drills were challenging and critiques were held following the drills.

(3) Training and Offsite Support The inspector confirmed that emergency training for operators was completed and tracked through the operator requalification program. The inspector verified that Facility Emergency Organization personnel participated in annual training as required by the E-Plan. The inspector also confirmed that emergency training for emergency support organizations was completed biennially.

During the inspection the inspector, Reactor Manager, and Interim Assistant Reactor Manager visited the University of Missouri-Columbia Hospital and met with the manager for Safety and Emergency Management. The inspector confirmed that the hospital would provide assistance to MURR in case of emergency and participated in emergency drills organized by MURR. The inspector also verified that the memorandum of understanding between the licensee and the City of Columbia was maintained as required by the E-Plan.

c. Conclusion The inspector determined that the emergency preparedness program was conducted in accordance with requirements in the E-Plan.

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

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

  • MURR personnel dosimetry records for 2020, 2021, and 2022 to date
  • select records documenting radiological surveys for 2021 and to date in 2022
  • MURR Policy, POL-3, MURR Radiation Protection Program, Revision 22
  • internal audit reports of the radiation protection and ALARA programs for 2021-6-
  • select records, FM-17, Radiation Work Permit, and associated Radiation Work Permit (RWP) log sheets issued in 2021 and to date in 2022
  • completed forms documenting calibration of various portable and installed meters/instruments and the stack monitors
  • select records documenting MURR facility initial and annual radiation worker refresher training for 2021 and 2022 to date
  • radiation and contamination surveys of select areas, rooms, and labs in the MURR facility from 2021 to the present b. Observations and Findings (1) Surveys, Postings and Notices The inspector verified that surveys were completed at the frequencies required by procedures and confirmed that results were documented and evaluated as required by procedure. During the inspection, the inspector accompanied a facility radiation protection technician during completion of a monthly survey and verified that the technician completed a thorough survey using the proper survey instrument and the appropriate survey techniques.

During tours of the facility, the inspector observed that signage, postings, and labels were used in accordance with requirements in 10 CFR Part 20. The inspector also confirmed that copies of notices to workers were posted in the facility as required by 10 CFR 19.11, Posting of notices to workers, including a copy of the most recent revision of NRC Form 3, Notice to Employees.

(2) Dosimetry and Radiation Monitoring Equipment The inspector verified that the licensee monitored individuals in accordance with the requirements in 10 CFR Part 20. The inspector examined dosimetry records for the past 2 years, and to date in 2022, which showed that occupational doses were below the regulatory limit. The inspector verified that annual dosimetry reports (i.e. NRC Form 5) were provided to each employee who received exposure greater than 100 mrem at the facility during 2021, as required by 10 CFR Part 19.

The inspector found that annual calibration of the portable meters was consistent with manufacturers recommendations and records were maintained. In addition, the inspector verified that area radiation monitoring equipment and stack monitors were source checked and calibrated as required by TS 4.7.a and b.

(3) Radiation Protection Training The inspector verified that records of training completion were retained, and that initial training was provided to new personnel and annual refresher training to personnel who worked at the MURR facility for over a year. The inspector confirmed that the content of the training satisfied the requirements in 10 CFR Part 19.

(4) Radiation Protection and ALARA Programs The inspector verified that the radiation protection and ALARA programs were established in MURR Policy, POL-3, Revision 22, MURR Radiation Protection Program, dated February 1, 2021, as well as through facility procedures. The-7-

inspector confirmed that the facility conducted an annual audit to review program content and implementation as required by 10 CFR 20.1101(c). The inspector noted that the ALARA program continued to produce dose and effluent reduction results through established goals and use of performance indicators. The inspector found that implementation of the ALARA program was consistent with the requirements in 10 CFR 20.1101(b).

(5) Radiation Work Permit Program The inspector reviewed the RWP program in place to control operations that could result in radiation safety hazards. The inspector noted that controls (e.g., various precautions, personal protective equipment, radiation monitoring) specified in the RWP were applicable for the type of work being done and the area being accessed.

The inspector found that reviews by management and HP personnel were completed as required by procedure.

c. Conclusion The inspector determined the licensees radiation protection program was implemented and met regulatory requirements.

6. Transportation Activities a. Inspection Scope (IP 86740)

To verify compliance with Titles 10 and 49 of the CFR, and procedural requirements for transferring or shipping licensed RAM, the inspector reviewed aspects of the licensees program, including:

  • selected records of RAM shipments made during 2021 and to date in 2022 including Type A and Type B shipments
  • records of licensee employee Department of Transportation shipping training
  • completed internal audits of various types of shipments b. Observations and Findings During the inspection, the inspector toured shipping and receiving areas and observed the preparation of various packages for shipment. The inspector noted that proper marking and labeling were placed on the packages and surveys were taken. The inspector verified that the licensee maintained on file copies of consignees licenses authorizing them to possess RAM as required by the regulations. The inspector also confirmed that the licensee verified consignee information prior to initiating a shipment.

The inspector noted that the licensee staff received training every 2 years and were certified for shipping RAM, as required by 49 CFR Part 172.

Through records review and observation, the inspector verified that, as required by 49 CFR Part 172: 1) shipping papers were completed; 2) packages were marked and labeled; and 3) conveyances were placarded when required. The inspector also confirmed that, as required by 49 CFR Part 173, radionuclides and mixtures of radionuclides were determined, identified, and quantified, and radiation and contamination surveys were performed to ensure compliance with regulatory limits.

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

7. Follow-up a. Inspection Scope (IP 69006, IP 92701)

The inspector reviewed the licensees actions taken in response to a previously identified Inspector Follow-up Item (IFI)05000186/2021202-01 - Follow-up on the issue of properly using and completing RWP forms as required by POL-03 and AP-HP-105.

  • AP-HP-105. Radiation Work Permit, Rev. 16
  • MURR Policy, POL-3, MURR Radiation Protection Program, Revision 22
  • select records, FM-17, Radiation Work Permit, and associated RWP log sheets for 2021 and 2022 b. Observations and Findings During an inspection in 2021, the inspector reviewed the RWP program established by the licensee. The inspector found that there were various deficiencies on the RWP forms involving, among other issues, missing surveys, work summaries not documented, and Section VII of the form (close out of the form) not completed. The inspector noted that the same issues were found during a licensee internal audit. The inspector confirmed that the licensee responded to the internal audit and took corrective actions which included training for all HP personnel and revising the RWP form to include a dose goal and total dose section, and a management review section to be completed by the HP supervisor. The inspector informed the licensee that proper implementation of the RWP program as required by procedure will be followed by the NRC as an IFI.

During this inspection the inspector confirmed that HP personnel were implementing the RWP program as outlined by the applicable procedure. No further problems were noted.

This issue is considered closed.

c. Conclusion The inspector determined that one IFI was addressed by the licensee and is now considered closed.

8. Exit Interview The inspector summarized the scope and results of the inspection on April 28, 2022, with members of licensee management and staff. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee acknowledged the results of the inspection.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel R. Astrino Reactor Manager M. Beach Radiation Protection Technician II D. Doenges Health Physics and Safety Manager M. Ell Radiation Protection Technician III S. Furst Shipping Technician IV E. Hudson Radiation Protection Technician III R, Hudson Interim Assistant Reactor Manager - Reactor Training L. Foyto Associate Director, Reactor and Facilities Operations T. Graham Health Physics Supervisor G. Korbeck Health Physicist and Interim CAP Coordinator K. Kutikkad Assistant Reactor Manager - Physics J. Matyas Access Control Manager J. Register Document Control/Records Management Manager Executive Director of MURR P. Williams Shipping Manager E. Weires Assistant Shipping Manager Other Personnel J. Reinke Manager, Safety and Emergency Management, University of Missouri Health Care INSPECTION PROCEDURES USED IP 69004 Class 1 Research and Test Reactor Effluent and Environmental Monitoring IP 69007 Class 1 Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class 1 Research and Test Reactor Procedures IP 69011 Class I Research and Test Reactor Emergency Preparedness IP 69012 Class 1 Research and Test Reactor Radiation Protection IP 86740 Inspection of Transportation Activities ITEMS OPENED, CLOSED, AND/OR DISCUSSED OPENED None.

CLOSED 05000186/2021202-01 - IFI - Follow-up on the issue of properly using and completing RWP forms as required by POL-03 and AP-HP-105.

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