IR 05000002/1985003

Insp Rept 50-002/85-03 on 851002-04.Violations Noted:Release of Matl Not Readily Soluble or Dispersible to Sanitary Sys & Failure to Complete Quarterly Effluent Repts

ML20138L393
Person / Time
Site:	University of Michigan
Issue date:	10/25/1985
From:	Greger L, Nicholson N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138L386	List: IR 05000002/1985003 ML20138L387
References
50-002-85-03, 50-2-85-3, NUDOCS 8510310294
Download: ML20138L393 (7)

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-2/85003(DRSS)

Docket No. 50-2 License No. R-28 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, Ann Arbor,- MI Inspection Conducted: October 2-4, 1985 Inspector: N. A. Nicholson /0/2MB5'

Date Approved By: L. reger, Chief /0/zs/Bf Facilities Radiation Protection Date Section Inspection Summary Inspection on October 2-4, 1985 (Report No. 50-2/85003(DRSS))

Areas Inspected: Routine, announced inspection of the radiation control program, including: liquid release practices and effluents; selected instrument calibration; internal and external controls; organization and qualifications; and licensee action on previously identified item The inspection involved 21 inspector-hours onsite by one NRC inspecto Results: Two violations were identified: (1) 10 CRF 20.303(a) - release of material not readily soluble or dispersible to the sanitary system, (Section 8); and (2) Technical Specification 6.4.8 - failure to complete quarterly effluent reports in accordance with licensee procedures, (Section 9).

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DETAILS Persons Contacted

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E.'Birdsall, Engineering Technician

-*R. 'R. -Burn, Reactor Manager

'*M. Driscoll, North Campus Health Physicist

• M..McDani'el, Health Physics Technician

~* Solari,' Director, Radiation Control Services

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Additional-operation, administrative, and laboratory personnel were contacted during'this inspectio * Attended the October 4, 1985 exit meetin . ~ General-

-This' inspection, which. began:at 12:30 p.m., October 2, 1985, was conducted to review the radiation _ protection program. The 1985 liquid releases to the sanitary sewer and release practices were specifically reviewed in response to a licensee notification that elevated releases occurred because of a nonfunctioning filter. . A.tcur of the facility was made during full

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-power operations. Independent readings with an NRC survey instrument were

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lin general agreement with licensee value ' Licensee Action on Previously Ide~tified n Items

'(Closed) Violation 30-1988/85001-01: Verify recipients are authorized to receive radioactive material. The licensee has updated an administrative file of tr'nsferees

a licenses;~ the license is reviewe'd before material is transferred. The licensee has implemented a program to routinely update the fil An abbreviated index of transferee's licensee numbers and expiration ~' dates is maintained, also, at the pool floor and hot cells for

. programmatic: reference; The_ inspector verified that the licensee had requested an updated license from a transferee with an expired license on file and that no material had been transferred in accordance with licensee procedure (0 pen) Open Item 50-002/85002-01: Change manual' or procedures to reflect

policy changes. The manual and procedures are being reviewed and update This item remains ope ~

4. --Qualifications and Organization

- The FNR/PML Health Physics organization continues to report to the Director, Radiation Control Service (RCS) in accordance with Technical Specifications 6.1.e. A staff change was noted. . The former North Campus health physicist (HP) was dismissed by the University on July 19, 1985 (Section 10). This position was filled July 22, 1985, with the current HP, who previously held this position from 1977 through 198 The current HP has three years experience at a commercial nuclear reactor.and an architectural / engineering firm, and earned a' masters

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degree in Radiological Health from the University. A former FNR licensed senior operator fills the HP technician position, as previously describe No apparent violations were' identifie . Audits The annual audit, as required by TS 6.2.g., was conducted July 25-27, 198 The same auditor conducted the previous seven years' audits. Numerous audit findings in the radiological protection program were identified for correction. The auditor attributed most findings to failings of the former H A program has been initiated to implement corrective actions and recommendations presented in the repor Followup action has been taken for approximately 25% of the findings, according to the current HP. These actions were selectively verified by the inspector. In accordance with the current NRC enforcement policy, no regulatory action will be taken since these-findings were licensee identifie No apparent violations were identifie . Personal Monitoring Dosimetry records for whole body and extremity exposures were reviewed for 1985. Exposures were below 10 CFR 20.101 limits. The highest monthly whole body exposure, 700 mrem, is under investigation. Preliminary indications suggest the film was inadvertently damaged by hea Two unassigned whole body badges, reporting 3.02 mrem and 240 mrem, respectively, during June, were identified. Further investigation revealed the badges were worn during medical radiation treatments by the former HP, and thus, do not reflect occupational exposures from licensed activitie Licensee representatives plan to document their investigation findings in the dosimetry fil The 1984 annual exposure report, per 10 CFR 20.407, was reviewed. No regulatory limits were exceeded; the highest annual whole body exposure was 960 mrem, with an average of 93 mrem. No problems were identifie No apparent violations were identifie . Bioassays According to licensee records, the 1.0 MPC tritium threshold level for urinalyses bioassay has not been exceeded during CY 1985. No bioassays were required in accordance with procedure HP 104, nor have any been conducted. -The highest tritium airborne value noted was 6.64% MPC during a heavy water transfe No apparent violations were identifie Inspection Report No. 50-2/8500 _ . . __ . _ _ - _ _ .

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" Liquid Effluents-On September 20,'1985, licensee representatives notified Region III that t elevated activities of licensed material from the retention tanks had

~.been released to the sanitary sewer during 1985, because of an inoperable

, filter. The elevated activity was concentrated in the unfiltered partic-ulate matter released, primarily resin fines. All releases were within

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applicable 10 CFR 20, Appendix B concentration limits, as verified during 1 this inspection.-

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'In~ addition to the Appendix B concentration limits, 10 CRF 20.303 limits-

! sanitary sewerage disposals to one-curie per year per licensee. .Apparently L due to an. error by the former HP,- no cumulative total of activity released i du' ring the year was maintained. Initial CY 1985 cumulative totals calcu-lated. September 19, 1985, indicated 1.344 curries had been released from

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the FNR/PML and main campus, with the majority from the FNR/PM Upon

reviewing the matter,. licensee representatives determined the initial analytical results of two heavily sedimented samples- had been overly conservative. The licensee' noted that particulate matter settled on.the i bottom of the 500 ml sample bottle during the routine 1000 second gamma ,

spectroscopic analysis even though the sample was mixed well before a counting.l This; counting geometry was not representative of the'homogenous

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solution calibration geometry used for liquid analysis and resulted in an '

overestimation of the two. samples activities. Reanalysis of these two samples, using agitation methods to minimize settling, resulted.in a revised CY 1985 cumulative total of 0.931 curies, within the 10 CFR 20.303 e -limit of one curie per year allowable release to the sanitary sewerage system.

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l . The inspector reviewed the reanalysis methods and calculations; no problems were identified. Calibrations of the germanium detector used for.this analysis were reviewed; frequencies and methods were in accordance with procedure HP 211. Calibrations of the detector were

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conducted with-an NBS. traceable sourc'e as per Regulatory Guide-4.15, Revision- 'According to licensee investigation findings, the high particulate levels released were the result of a missing gasket that normally seals the five

. micron filter to_its housing on the effluent release line. Water flow

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a through the filter, and the associated filtration efficiency, were greatly

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reduced because of the poor seal between the housing and filter. The

. missing ~ gasket was found in the retention: tank area.on September 19, 1985,

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by the-current HP who was inspecting the release line and filters to i determine the source of the.high particulate activity. The gasket was inspected for' damage and reinstalled into the housing. -Licensee-representatives believe the five micron filter had been replaced and l' ~the gasket removed around October 1984 since the initial increase in release concentrations correlated to that period. Licensee representatives further speculate the two series 25 micron filters upstream of the five micron filter likewise may not have been functioning

, effectively because of a fitting deficiency between the filters that may have interfered with water flow. To maximize filter efficiency, the

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licensee plans to replace.the two series filters with one 25 micron filter of the'same cumulative lengt In an attempt to reduce the particulate activity introduced into the retention tank, the licensee intends to recharge the deionizers annually as opposed to the quarterly

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frequency previously conducte The high concentration of particulate matter in the two representative samples indicated the licensed material released to the sanitary sewer was not readily dispersible or. soluble, in violation of 10 CFR 20.303(a).

(Violation 50-002/85003-01) The particulate matter in both these samples was clearly visible and formed ~ aggregates if not agitate One apparent violation was identifie . Reports

~The 1984 annual exposure report was prepared per 10 CFR 20.40 Quarterly effluent reports were not completed for the fourth quarter of 1984 and the first and second quarters of 1985. This is an apparent violation of Technical Specification 6.4.8 which requires adherence to licensee radia-tion protection procedures. Procedure HP 207, Section 2.3 requires

. effluent reports be prepared on a quarterly basis by the HP staf (Violation 50-002/85003-02) Had these reports been prepared for routine review by the FNR/PML and RCS staffs, the elevated liquid release activities should have been identified earlier. Although the FNR and RCS staffs were aware the identified reports were overdue, no aggressive followup action was taken to assure the reports' completio One apparent violation was identifie . Gaseous Air Detector Calibrations Calibrations and instrument checks of the gaseous air detectors (GAD's)

monitoring effluent from the FNR and FNR/PML stock were reviewe Several observations were mad On June 17, 1985, licensee representatives notified Region III that the stack GAD calibration was three months overdue, and that the FNR GAD calibration was one week overdue. Both GAD's were subsequently calibrated June 19, 1985. Because of FNR/PML staff questions concerning quantifi-cation of the gaseous source used for the stack GAD calibration, the Director of Radiation Control Services requested the calibration be repeated. The second calibration was performed June 20, 1985. A review by the FNR/PML and.RCS. staffs of the June 19 and 20 stack GAD calibration data led to the conclusion that the June 19 data had been falsified by the former H Primarily as a result of this falsification, the former HP was dismissed from the university on July 19, 1985. Although the June 19 calibration data were apparently falsified, the monitor continued to be operable since no adjustments to the monitor were made based on the calibrations performed June 19 or 20. The June 19 and June 20 calibration

. data were consistent with previous (1984) data. A calibration update sheet identifying the due dates for all instruments is currently maintained to minimize instances of overdue calibration _

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Weekly GAD source checks required by Procedure HP 113 were reviewe As identified in the_ licensee audit, a lapse during the first quarter was noted because the source holder was inadvertently misplaced. The holder is currently maintained by the HP staff. Results reviewed indicate readings were taken from both the meter (cpm) and scaler (counts), an inconsistent practice which introduces difficulty in tracking monitor performanc The current practice is to record meter readings; this practice will be reflected in the procedural revision. No problems were noted with the GAD responses since the June calibration No apparent vic,lations were identifie . Instrumentation Calibrations were reviewed for laboratory equipment and the Moving Air Particulate:'(MAPS). The' MAPS, 1;auid scintillation counter, and gaseous proportional counter have been calibated at the designated frequencies by applicable procedures and Technical Specifications. An over response of the stack and beam port MAPS was identified during the August calibra-tion; these monitors have since been adjusted. The liquid scintillation counter was recalibrated August 28, 19P5, in response to a licensee audit finding that not all calibration points were used in the previous calibration. No problems were identified during the August calibration, since the counter responded appropriately. Quarterly calibrations in 1985 for neutron meters were reviewed; responses were appropriate. A linearity check. indicated no problems. Based on a comparative review of survey and calibration data, calibration data for instrument range did not reflect levels normally encountered during surveys of the vertical beam of the reactor. The licensee agreed to evaluate the neutron. flux and verify the instruments were calit. rated for the flux encountered during routine surveys (0 pen Item 50-002/85003-03)-

No apparent violations were identifie . Surveys

~The inspector selectively reviewed results of monthly direct radiation surveys for 1985 in accordance with procedure HP 10 No problems were note No apparent violations were identifie . FNR Tours During tours of the FNR, the inspector made the following observations:

• The gasket was properly installed in the five micron filter on the liquid release line to the sanitary sewe * Retention tank samples collected October 2, 1985, were visibly free of sedimen * . Retention tank #3 was being cleaned to remove residual sludge and sedimen _

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• Indepe'ndent survey readings with an NRC survey instrument were in general agreement with licensee dat * The material transfer log documenting transfer of activated material to on campus users and offsite licensees was current with applicable licenses and expiration date * Portable survey equipment was operable and calibrate * Area postings were in accordance with applicable regulation No apparent violations were identifie . Exit Meeting The inspector met with licensee representatives noted in Section 1 on October 4, 1985, to discuss the findings and scope of the inspectio The inspector discussed the likely information:* content of the inspection regarding documents or processes reviewed. The licensee did not identify such documents / processes as proprietary. In response to the inspector's comments, the licensee: Acknowledged the two violations (Sections 8 and 9). Agreed to evaluate the neutron calibration spectrum (Section 11).

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