IR 05000002/1980005
| ML19290G709 | |
| Person / Time | |
|---|---|
| Site: | 03001998, University of Michigan |
| Issue date: | 11/03/1980 |
| From: | Fisher W, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19290G707 | List: |
| References | |
| 30-01988-80-02, 30-1988-80-2, 50-002-80-05, 50-2-80-5, NUDOCS 8012180408 | |
| Download: ML19290G709 (7) | |
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U.S. NUCLEAR REGULATORY C0!!!!ISS10N OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-002/80-05; 30-1988/80-02 Docket Nos.50-002; 30-b88 Licenses No. R-28; 21- 00215-04 Licensee: University of Michigan Michigan Memorial - Phoenix Project Phoenix Memorial Laboratory Ann Arbor, MI 48105 Facility Name:
Ford Nuclear Reactor Inspection At:
Ford Nuclear Reactor Site Ann Arbor, MI Ii:spection conducted:
October 6-8, 1980 ffj w 0-
Inspector:
R'. A. ?c u l A >3/ J 6 Wmh-f, q i _),&f(%
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Approved By:
W. L. Fisher, Chief
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Fuel Facility Projects and Rad.ation Support Section Inspection Summary Inspection on October 6-8, 1980 (Report No.50-002/80-05; 30-1988/80-02))
Areas Inspected:
Routine, unannounced inspection of radiation protection and radioactive waste programa, including:
qualifications; audits; training; radiation protection procedures, instruments and equipment; exposure control; posting, labeling, and control; survey ; notifications and reports; effluent releases; records of effluents; effluent control instrumentation; transporation activities;and IE bulletins and circulars.
The inspection involved 20 inspector-hours on site by one NRC inspector.
Results: Of the fourteen areas inspected, no items of noncompliance or deviations were identified in thirteen areas. One apparent item of noncom-pliance was found in one area (severity IV - a complete certification and supporting analysis for a specification 7A package not maintaraed on file -
Paragraph 17)
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DETAILS 1.
Persons Contacted W. Kerr, Director of Phoenix Project hR. Burn, Hr. actor Manager
- G. Cook, Assistant Reactor Manager J. Jones, Radiation Laboratory Manager
- M.
Driscoll, Health Physicist A. Solari, Campus RSO
- V. Pegot, Health Physics Technician The inspector also contacted other members of the licensee's staff.
hDenotes those attending the exit meeting.
2.
General This inspection, which began at 10:30 a.m. on October 6, 1980, was conducted to examine the routine radiation protection and radwaste management programs. An initial tour of the iacility was made at about 1:00 p.m. when the reactor was not operating. Radiation control appeared to be adequate, housekeeping was satisfactory, and access control and posting met regul atory requirements.
3.
Organization The Nuclear Reactor staf f consists of the Director, Reactor Manager, Assistant Reactor Manager, ine senior operators, and two operators.
Responsibility for radiation protection surveillance is assumed by the North Campus aealth physicist and a technician, both of whom report to the University Radi1 tion Safety offisc.
Other university health physicists are available to provide additional health physics expertise, if needed.
4.
Training Radiation protection instructions are provided to personnel upon initial entry to the Phoenix Memorial Laboratory (PML) - Ford Nuclear Reactor (FNR) Facility in the form of an instruction sheet and booklet.
Because of some concern expressed by the inspector, the licensee will modify the instruction sheet, to ensure compliance with 10 CFR 19.12, by expanding the section covering the training concerning health protection problems associated with exposure to radiation. This matter will be reviewed at a future inspection. Requalification retraining records of certain reactor operators were selectively reviewed for 1980.
No discrepancies were identified. Additional radiation protection training provided experimenters, reactor operators, and health physics personnel is tailored for their specific work.
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The licensee does not have a formal ALARA program. However, their surveillance program is such that they are aware of radiation and airborne activity areas.
Precautions are taken to prevent unnecessary personal exposure.
No it.>ms of noncompliance or deviations were identified.
5.
Review and Audit Records of an audit required by Technical Specification 6.2.g and conducted on July 24 and 25, 1980, were reviewed. This audit included procedure compliance and technical review of several health physics procedures. This audit identified certain health physics procedure weaknesses, which were reccanized and being correcte6 by the health physicist. No items requiring corrective actions were identified by the auditor.
Minutes of the Safety Review Committee were reviewed for the period December 1979 through July 1980.
No significant safety findings had been noted by the Safety Committee.
No items of noncompliance or deviations were identified.
6.
Radiation Protection Procedures The Health Physicist is currently revising several of the 27 health physics procedures with the intent of making them more specific, better written, and more comprehensive. Revised procedures 101 through 106 and 111 rcriewed by the inspector were found to adequately address the subjects.
The health physicist will attempt to revise all proce-dures and develop new ones where necessary.
No items of noncompliance or deviations were identified.
7.
Instruments and Equipment The licensee hat portable survey instruments capable of measuring beta pamma and neutron radiation fields.
Calibration records for 1980 did not 'dentify discrepancies from the calibration frequency specified in the licensee's Health Physics Manual.
Seven fixed NaI radiation detectors are utilized to provide warning (alarm) and display (local and remote) of facility rautation levels.
One monitor, the FNR exhaust monitor, initiates a reactor scram and ventilation isolation when radiatior levels exceed one mR/hr.
Records for 1980 show no dis-crepancies from the technical specification requirements for operability, setpoints, actuating functions, or calibration of these monitors.
Gaseous air detectors (GAD), calibrated fo r argon-41, cortinuously monitor the FNR ventilation exhaust and the FNR-PML stack No. 2 ev haust.
Moving airborne particulate monitors (MAP) continuously monitot the beam port and pool floors and the combined discharges of the four-3-
FNR-PML stacks.
Calibration and operational check record.c for the N1P's and GAD's were selectively reviewed for 1980 to date.
No dis-crepancies from the technical specification requirements for oper-ability, testing, or calibrations were identified.
The inspector noted that the argon-41 being used tc calibrate GAD's is measured in a Capintec well counter. The inspector asked whether the standard used to calibrate this well counter for argon-41 wau similar to the size and configuration of the actua argon-41 being sampled to calibrate the GAD's.
The licensee stated that arrangements had been made to verify calibration of the well counter with the GeLi det ector and, if necessary, make adjustments on the well counter. The IIealth Physicist will develop a writter. procedure for this particular verification method.
No items of noncompliance or deviations were identified.
8.
Personal Monitoring Beta, gamma, and neutron dosimeters are worn routinely by all personnel entering the reactor facility. The whole body and finger ring badges are exchanged monthly and biweekly, respectively.
Film badge records reviewed for the fourth quarter 1979 and the first eight mont!.s of 1980 showed the highest whole body and extremity doses to be 870 mrems and 2240 mrems, respectively, for 1979 and 490 mrems and less than one rem, respectively, through August 1980.
Forms NRC-4 are not maintained. The licensee uses the vendor's personal dosimetry reports as official records.
During the last inspection, the licensee stated they would explore available methods of neutron dosimetry to determine the best method to evaluate whole body exposures. The evaluation has been in progresu for several months, using three types of neutron dosimetry near the beam ports. The results of the measurements are inconclusive, and the evaluation will continue until sufficient information is gathered to make an evaluation. This matter will be revirved during a future inspection.
No items of noncompliance or deviations were identified.
9.
Bioassay Licensee procedures require urinalysis if the airborne tritium concen-tration exceeds one MPC during heavy water transfers. Airborne tritium survey records for heavy water transfers conducted since the previous radiation protection inspection reveal no tritium concentrations ex-ceeding 5% of the occupational MPC. The licensee had, however, conducted tritium urinalysis on several individuals int lved in heavy water transfers.
Urinalysis records show that the highest trittum concentration was 4 pCi/ml.
No items of noncompliance or deviations were identified.
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10.
Respiratory Protection
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The licensee does not have an approved (10 CFR 20.103.e) respiratory protectiet. program and, therefore, is tot authorized to take credit for the protection afforded by respiratory equipment in estimating exposure of individuals to oirborne concentrations of radioactive material. Resniratory protection equipment is not used routinely but is available for emergency use.
No items of noncompliance or deviations were identified.
11.
Surveys The inspector selectively reviewed records of direct radiation, surface contamination, and airborne activit3 surveys conducted during 1980 in accordance with licensee procedures HP-101 through 104.
No problems with frequency or extent of surveys were identified.
12.
Airborne Effluents Airborne activity from the FNR is released through FNR-PML stack No. 2 and the FNR ventilation exhaust stack.
Both release paths are equipped with gaseous monitors and iodine and particulate samplers for quantifi-cation of airborne releases.
The inspector selectively reviewed the licensee's airborne effluent analyses and release calculations for 1980 to date.
The dilution factor allowed by the technical specifications (400) is not necessary to satisfy the release limits for iodines or particulates but is necessary for gaseous releases. Using the allowable dilution factor, gaseous releases were less than 10% of the technical specification limit.
13.
Liquid Effluents Liquid wastes continue to be released to the sanitary sewer through two series five-micron filters. Wastes are collected and held in three 2800 gallon retention tanks.
Gamma isotopic, tritium, and gross beta analyses are performed before discharge.
Liquid effluent analyses and release calculations for 1980 to date were reviewed.
No discrepancies from the limits specified in 10 CFR 20.303 or the technical specifications for surveillance or release concentrations or quantities were ncted.
14.
Ef fluent Report Quarterly radioactive effluent releases reported for the first three quarters of 1980 were reviewed. Selective comparison of the reported radioactive effluents with the analysis records did not identify any discrepancies in the data.
Due to the shared radwaste facilities utilized by PML and FNR, the reported ef fluents include a portion of the PML effluents in addition ".; those originating from FNR.
No items of noncompliance or deviations were identified.
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15.
Pool Witer Chemistry and Heavy Water Reflector rank Tritium
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decords through June 1980 show that pool water radioactivity analyses (gamma isotopic and gross aeta) were conducted at least weekly and heavy water reflector taak t.ritium analysis were conducted at least quarterly. Tritium content of the heavy water reflector tank remained less than 50 curies. No abnormal activity or trends were noted.
No items of noncompliance or deviations were identified.
16.
Posting, Labeling, and Control The inspector toured the licensee's facilities in the company of a licensee representative.
General housekeeping and control of radiation hazards appeared
.quate.
Rmdiation caution postings and control of high radiation art _s were observed to comply with regulatory requirements.
17.
Materials Receipt and Trarsfer Radioactive material removed from the FNR is transferred to the Univer-sity Radiation Control Services organization for use at the University, transfer to other licensees, and solid wasta disposal.
The licensee shipped spent fuel to the Savannah River Laboratory on several occasions in March 1980.
Shipment records were found to be in compliance with 10 CFR 71 and 49 CFR requirements. The licensee's Quality Assurance Plan was approved by the Transportation Certification Branch, Division of Fuel Cycle and Material Safety on February 22, 1980.
The licensee ships radioactive material in specification 7A containers.
The containers were manufactured at the FNR in accordance with ORNL specifications several years ago; how2ver, they did not maintain a complete supporting safety analysis demonstrating that the construction methods, packaging design, and materials of construction comply with the specification.
This is in noncomp1m ance with 49 CFR 173.395(a)(1).
Because the licensee had not maintained the safety analysis on file, they agreed to perform those tests required in 49 CFR 173.393(a) and 173.398(b).
The licensee notified the inspector on October 16, 1980, that all tests required by 49 CFR regulations had been completed and the results doc-umented. The inspector replied that test results would be reviewed at the next inspection and that no written response to the item of noncom-pliance would be necessary.
01.e item of noncompliance was identified.
18.
Independent Measurements Gurma and neutron surveys were made by the inspector and reactor health physicist in the reactor facility on October 8, 1980, while the reactor-6-
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sis operating at two megawatts.
Radiation fields were found to be cc.wensurate with the readings posted in each area.
19.
Review of Nonroutine Events The inspector reviewed the licensee's actions with revpect to radiological aspects of Reportable Occurrence 80-09, " Unplanned Bromine-82 Release (3/13/80)."
Discussions with licensee personnel and a review of records did not reveal any significant discrepancies in the report. No items of noncompliance or deviations were identified.
20.
Notifications and Reports Leview of records and discussion with the licensee indicated no problems regarding compliance with NRC reporting requirements.
21.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on October 8, 1980.
The following matters were discussed:
The purpose and scope of the inspection.
a.
b.
The item of nnntompliance (Paragraph 17).
The licensee agreed to:
Perform required tests on Type A containers used f c shipments of a.
radioactive material and to maintain documentation.
(Paragraph 17)
b.
Develop procedures for calibration of the Capintec well counter for argon-41 standards used to calibrato the gaseous air detectors.
(Paragraph 7)
Revise the " Radiation Safety and Security Instructions" handout c.
used to comply with 10 CFR 19 requirements.
(F iragraph 4)
d.
Continue to evaluate alterrete methods of personal neutron dosimetry.
(Paragraph 8)
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