IR 05000002/1988002

Insp Rept 50-002/88-02 on 880720-22.No Violations Noted. Major Areas Inspected:Records,Logs & Organization,Radiation Protection,Radwaste Mgt Control & Transportation Activities

ML20151R516
Person / Time
Site:	University of Michigan
Issue date:	08/03/1988
From:	Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151R491	List: IR 05000002/1988002 ML20151R489
References
50-002-88-02, 50-2-88-2, NUDOCS 8808120204
Download: ML20151R516 (8)

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U.S. NUCLEAR REGULATORY COMISSION REGION.III

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Report No. 50-002/88002(DRSS) ,

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-Docket No.50-002 License No. R-28 Licensee: University of Michigan Phoenix Memorial Laboratory Ann Arbor, MI 48105  :

Facility Name: Ford Nuclear Reactor

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Inspection-At: . Ford Nuclear Reactor, Ann Arbor. Michigan

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Inspection Conducted: July 20-22, 1988 Inspector:

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R.A.Paulja 8,j3/88 Dat~e '

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Approved By: L. R. Greger, Chief ek 3 M Facilities Radiation ~Datd

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Protection Section Aspection Sumary Inspection on July 20-22, 1988 (Report No. 50-002/88002(DRSS))

Areas Inspected: Routine, announced inspection of records, logs, and organization; radiation protection; radwaste management control; transportation activities; and follow-up actions relative to previous open inspection item Results: No violations or significant safety issues were identified in the '

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DETAILS Persons Contacted R. Burn, Reactor Manager F. Conway, North Campus Healch Physicist G. Cook, Assistant Reactor Manager The above individuals attended the exit meeting on July 22, 1988. General This inspection was conducted to examine the research reactor program at the University of Michigan. The facility was toured during full power operations. The general housekeeping of the facility was satisfactor . Licensee Action on Previously Identified Items (Closed) Unresolved Item (002/86001-03): Weaknesses with the thyroid counting program concerning the licensee's ability to adequately evaluate MPC-hours. This unresolved item was reviewed during an inspection of Byproduct Material License No. 21-00215-04 conducted in 1987 and documented in Inspection Report No. 87001, dated August 18, 1987. The review indicated the licensee had strengthened certain weaknesses in the thyroid counting program (improved counting techniques), and found the licensee was able to adequately evaluate MPC-hour (Closed)OpenItem(002/87003-01): Establish that reported iodine releases through the reactor building stack were the result of iodine intakes into the reactor building from adjacent building ventilation systems, and not as a result of iodine released from the reactor. The licensee installed a continuous reactor building intake air sampler; low levels of iodine produced in the adjacent Phoenix Laboratory are found on the samples. The inspector verified the samples are taken, and reviewed the sample result (Closed)OpenItem(002/87003-02): Method to ensure that radioactive material produced in the reactor is transferred to the Byproduct Material License (BPML) before the material is transferred from the facility. The health physics log used to document irradiated pool samples retrieved from the reactor has been revised to officially document transfer of the material to the BPML; the adequacy of the log entries were verified by the inspecto i Qualification and Organization The FNR/PML Health Physics organization is described in Inspection Report No. 50-002/87003; no significant changes have been made. The inspector I was informed that the Director, Radiation Control Services intends to periodically rotate reactor HPs (about every two years) to provide more HPs familiar with reactor health physics responsibilities, and to broaden their experience. The inspector cautioned the Reactor Manager that during i

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rotation occurrences, the licensee should provide sufficient training and overlap to ensure that continuity and stability are maintained in the reactor radiological control progra No violations or deviations were identifie . Audits The 1987 annual audit required by TS 6.2 9 conducted in July 1987 by a non-licensee auditor was reviewed by the inspector. Audit findings were related to deficiencies associated with the Health Physics Manual and Procedures. Corrective actions were reviewed by the inspector; no problems were noted. The 1988 audit was in process during the inspection; the results of this audit will be reviewed during a future inspectio Minutes of the Safety-Review Comittee (SRC) were selectively reviewed for the period May 1987 to date. SRC members included representatives from FNR and Radiation Control Services. In accordance with TS 6.2.f, the SRC reviewed the following: experimenter requests and qualification, proposed technical specifications, and selected procedures. Frequencies were in accordance with TS 6.2.c. No problems were note No violations or deviations were identified by the inspecto . Training Although most maintenance work is performed by permanent reactor personnel who may not receive radiation protection job coverage when working in a High Radiation Area (HRA), the licensee makes a special effort to provide-adequate training to ensure those persons are qualified to perform such activities. During this inspection it was noted that non-reactor maintenance personnel were performing maintenance activities in a HR The inspector questioned these workers concerning the training they received before comencing their work. Based on this discussion, it appears the licensee provided specific instructions comensurate with the radiological ha::ards associated with the job. In addition, radiation protection job coverage was provided during their stay in the HR No violations or deviations were identifie . Instrumentation and Equipment  !

The inspector reviewed selected calibration records for gaseous detectors (GADS, Procedure No. HP-209), moving air particulate monitors (MAPS, Procedure No. HP-208), and the Capintec Ionization Chamber, (Procedure No. HP-210), for the period June 1987 through May 1988. Calibration and frequencies were in accordance with applicable technical specifications and procedures; no discrepancies were found. The two GADS are calibrated for argon-41 and continuously monitor ventilation exhaust from the FNR and the FNR-PML stack No. 2; the MAPS monitors stack effluents, the pool floor and beam port floor. The Capintec is used during the calibration of the GADS. Operators verify building exhaust and area alarm setpoints once per shift, in addition to routine MAP operational check .

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Calibration records of laboratory counting instruments were reviewe The gas proportional counter was calibrated in accordance with Procedure No. HP-211 on a quarterly basis. The Geli system is calibrated semi-annually with a multi-nuclide NBS traceable liquid standard. Records reviewed revealed no significant problems. Also, a selective review cf the calibration records of seven fixed Nal radiation detectors, (Procedure No. OP-901) utilized to provide alarm of facility and FNR exhaust radiation levels, was made. No problems were identifie During facility tours, portable survey instruments were observed to be calibrated and operable. Calibration records reviewed for portable survey instruments (Procedure No. HP-203) and neutron survey instruments (Procedure No. HP-204) indicated the licensee is calibrating the detectors in accordance with requirements. However, it was noted that the calibration frequency of the higher ranges of some portable instruments have somewhat exceeded the nominal six months frequency because the stronger sources required for the higher ranges are shared by other University personnel and are nct always available. In response to inspector concerns, the licensee stated that increased efforts would be made to meet the nominal calibration schedule No violations or deviations were identifie . Personal Monitoring The licensee continues to use vendor whole-body film and extremity badges which are issued monthly to reactor personnel and experimenters. Records indicated the highest yearly whole-body and extremity doses for 1987 were 1520 mrem and 6970 mrem, respectively, which are both below 10 CFR 20.101 limits. It was noted that for 1987 there was a general' increase in whole body and extremity exposures, caused as a result of increased sample irradiations and radioactive material shipments. The licensee is cognizant of the general increase and has taken steps to implement ALARA. These steps include use of audible dose-rate dosimetry (chirpers) to make personnel more cognizant of radiation fields when handling samples, distributing radiation producing jobs between staff and operators, and evaluating methods to handle sampica more efficiently. The effect of these steps will be reviewed during a future inspection. This matter was discussed at the exit meeting. (0 pen Item: 002/88002-01)

No violations or deviations were identifie . Bioassays Licensee procedures require tritium urinalysis bioassays if the airborne tritium concentration exceeds one MPC during heavy water transfer According to licensee records, three tritium urinalyses of reactor personnel were conducted from July 1987 to date because of this procedural l requirement; no significant results were found. During this same period the licensee had no indication of reactor personnel being exposed to iodine, therefore, no thyroid counts were performe No violations or deviations were identifie .

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10. Posting, Labeling and Control Area posting, reviewed during facility tours, was in accordance with 10 CFR 20.203. Access control of high radiation areas met regulatory requirements. General housekeeping and control of radiation hazards appeared adequat No violations or deviations were identifie . Surveys Direct radiation surveys (gamma and neutron) of the entire facility are conducted in accordance with the requirements of Procedure No. HP-10 Additional direct radiation surveys are conducted each shift at selected locations and upon removal of pool equipment and experiments. Survey results for calendar year 1988 to date were selectively reviewed. The highest radiation areas noted are located in the FNR basement, which is controlled as a High Radiation Area. Access to this area is adequately controlle Contamination surveys are conducted in accordance with Procedure No. HP-10 The inspector selectively reviewed the licensee's contamination survey records for calendar year 1988, to date. Contamination levels are lo No violations or deviations were identifie . Airborne Effluents Airborne activity from the FNR is released through FNR-PML stack No. 2 ar ~ the FNR ventilation exhaust stack. Both release paths are equipped wita gaseous monitors and iodine and particulate samplers for quatification of airborne release The inspector selectively reviewed the licensee's airborne effluent analyses and release calculations for 1987. Using the allowed dilution factor of 400, gaseous effluents were less than 5% of the technical specification limit. The dilution factor is not necessary to satisfy the release limits for todines and particulates; certain of the calculations used to deterrine gaseous releases were verified to be correct by the inspecto The inspector noted that the rated fan flows for the reactor building ;

stack and Phoenix laboratory stack No. 2 have not been verified since about 1980. The rated fan flow from these stacks is used to determine the total combined air flow, which in turn is used to calculate the yearly average gaseous effluent concentration; the concentrations are then compared to the TS limits. This matter was discussed at the exit meeting and will be reviewed further during a future inspectio (0 pen Item: 002/88002-02)

No violations or deviations were identifie .

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13. Liquid Effluents Liquic wastes are collected in three retention tank Liquid effluents are discharged to the sanitary sewer on a batch basis. Before discharge, tank contents are recirculated, filtered, and sampled. Samples are analyzed for gross beta, tritium, and isotopic gama activities. Records reviewed indicate 1987 release concentrations were well within 10 CFR 20 limits using-the approved 300 dilution factor. Calculational methods were reviewed; no problems were note No violations or deviations were identifie . Material Transfer There have been two spent nuclear fuel shipments since October 1987. The shipments included forty-six elements. All stored fuel has been removed from the facility. Selected sections of DOE /NRC Form 741" Nuclear Material Transportation Report," QA audits, shipping papers, and Procedure No. AP-16

"Spent Fuel Data Sheet" were reviewed. Based on this review, it appears the shipments were made in accordance with regulatory requirement Twenty-four new fuel elements were received by the licensee during 198 A review of the receipt papers was made by the inspector and it appeared the new elements were transferred and received in accordance with regulatory requirement Irradiated and waste material removed from the FNR is transferred to the University Radiation Control Services Organization for use at the University, transfer to off-campus recipients, or disposal. The licensee maintains copies of the recipients' licenses on file to verify the recipients are authorized to receive the material. The inspector selectively reviewed the licensee's survey and transfer records for such material; no problems were note No violations or deviations were note . Reports The inspector reviewed the radioactive effluent releases reported in the licensee's Report on Reactor Operations for 1987. Selective comparison of the reported radioactive effluents with the licensee's analysis records did not identify any discrepancies in the 1987 data. Due to the shared radwaste facilities utilized by PML and FNR, the reported effluents include a portion of the PML effluents in addition to those originating from FN . Pool Water Chemistry and Heavy Water Reflector Tank Tritium Selected gama isotopic results i f pool water samples, taken twice )

weekly, were reviewed for last months of 1987 through 1988 to dat Samples are also reanalyzed two weeks post-collection. Quarterly tritium i

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analyses of the heavy water tank indicated the tritium inventory remained less than 50 curies, as required by TS 3.5.b. No abnormal activity or trends were note No violations or deviations were identifie . Reactor Pool Water Leakage Pool reactor levels are measured weekly and the amount of makeup water has been about the same for several years of operation. Most of the water loss is calculated to be from pool evaporation (about 150 gallons per day), with a lesser amount from primary penetrations and hairline cracks in the reactor wall (estimated to be about 50 gallor,s per day). The licensee has for many years been aware of leakage from one of two primary penetrations leading to the reactor basement, from beam port penetrations located on the beam port floor, and from hairline cracks in the reactor wall. Water proofing contractors have been periodically hired to repair hairline cracks and caulk leaks at primary penetration About two-thirds of the reactor pool is surrounded by a three to six-foot concrete wall / floor and physically located over the reactor building basement. The only two piping penetrations into the bottom of the reactor lead to the basement; leakage from these penetrations is collected in the radwaste retention tanks. The other one-third of the reactor pool is located over an unexcavated area, has no piping penetrations, and an 18-foot concrete wall / floo Although the licensee has been aware of reactor pool water leakage, no recent attempt has been made to quantify the water loss caused by evaporation and by known leakage, nor has an evaluation been made to determine if possible contaminated reactor water could migrate into the unexcavated areas under the reactor. This matter was discussed at the exit meeting and will be reviewed further at a future inspectio (0penItem: 002/86002-03)

1 Information Notices The inspector noted that pertinent Information Notices addressed to research reactor licensees are received and maintained. The Notices are reviewed by the reactor manager for final resolution, which is recorde . Exit Meeting The inspector met with licensee representatives noted in Section 1 on July 22, 1988, to discuss the findings and scope of the inspection. The inspector discussed the likely informational content of the inspection regarding documents or processes reviewed. The licensee did not identify such documents / processes as proprietary. The following matters were discussed specifically by the inspecto l l

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a. Inspector concerns regarding maintenance of a stable health physics program at the reactor during rotation of reactor health physicist (Section4)

b. The general increase in radiation exposures. The licensee. indicated steps have been taken to implement ALARA measures where practicabl (Section8)

c. The desirability of verifying the rated fan flows for the reactor building and Phoenix laboratory stack The licensee committed to test the for flow rates for each stac (Section12)

d. The lack of recent evaluations to quantify reactor water loss, and

~ determination of possible contaminated water leakage into the unexcavated area under the reactor. The licensee stated that evaluations will be made to determine evaporation rates and leakage rates from visible leaks. In addition, selective smears of-evaporated leak spots and water leakage will be measured for radioactivity. The results of this information will aid in determining the possibility for contaminated water entering the unexcavated area under the reacto (Section 17)

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