IR 05000054/1982003
| ML20055B663 | |
| Person / Time | |
|---|---|
| Site: | 05000054 |
| Issue date: | 07/08/1982 |
| From: | Keimig R, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055B655 | List: |
| References | |
| 50-054-82-03, 50-54-82-3, IEB-78-07, IEB-78-09, IEB-78-7, IEB-78-9, NUDOCS 8207220601 | |
| Download: ML20055B663 (11) | |
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k U. S. NUCLEAR REGULATORY COMMISSION REGION I d-Report No. 50-54/82-03 Docket N License N R-81 Pri ori ty_ _ --
Category F Licensee: Union Carbide Corporation P. O. Box 324 Tuxedo, New York 10987 Facility Name: Union Carbide Nuclear Reactor Inspection At: Tuxedo, New York 10987 Inspection Conducted: June 1-4, 1982 Inspectors: .
utbre<, 77 82 W. W. Kinney rojectI/spector 'Date i
Approved by: . . gs,,$p
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f-#-8J R.Keimip, Chief roject Branch #2 Date
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Inspection Summary: Inspection on June 1-4, 1982 (Report No. 50-54/82-03)
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Areas Inspected: Routine, unannounced inspection by a region based inspector i [25 hours)of: licensee action on previous inspection findings; radiation
- dose in unrestricted areas; facility operations; organization; logs and records; reviews and audits; and licensee action on bulletin and circular Results
0ie violation was identified (failure to consider I-133 contribution to total body dose to the critical individuals in unrestricted areas - Paragraph 3).
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8207220601 G20709 PDR ADOCK 05000054 G PDR __. ..__ _ _
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DETAILS 1. Persons Contacted J. J. McGovern - Business Manager, Radiochemicals M. H. Voth - Manager, Nuclear Operations
- J. Konnerth - Manager, Health, Safety & Environmental Affairs
- G. Ruzicka - Supervisor, Reactor
- L. C. Thelin - Supervisor, Health Physics S. E. Lupinski - Chief Reactor Operator The inspector also contacted five reactor operators during the course of the inspectio * denotes those present at the exit interview 2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (54/77-03-03): The licensee was to re-evaluate the reactivity worth of experiments installed in the reacto Section 2.b(2) of the Final Hazards Summary Report (FHSR) required that "The total reactivity worth of core experiments shall not be permitted to exceed 2.0*4Ak/k". During Inspections 50-54/77-03 and 50-54/78-04, the inspectors were concerned because the licensee appeared not to be using the most conservative values of the variables while determining the reactivity worth of the experiments in the reacto Since these inspections were conducted, new Technical Specifications have been incorporated into the license by Amendment No. 14, effective September 17, 197 Technical Specification 3.5.1.c.(1) states,
"The combined worth of all experiments which can add positive reactivity l
to the core due to a common-mode failure'shall not exceed 2% Ak."
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This Technical Specification does not limit the total reactivity worth of the experiments in the reactor. The licensee appears to be meeting the present specificatio (Closed) Unresolved Item (54/78-01-01): The inspector wanted to review additional licensee safety evaluations to determine if the licensee met the requirements of 10 CFR 50.5 During the present inspection, the inspector reviewed the safety evaluations performed by the Nuclear Safeguards Committee (NSC) from September 1979 through April 1982. The NSC evaluated proposed j changes in the facility, proposed changes in the procedures, and
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proposed tests and experiments and determined if regulatory requirements l would be violated or unreviewed safety questions would be caused by l the changes, tests, and experiments.
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c. (Closed) Unresolved Item (54/78-01-04): The licensee had not provided a set of license conditions in the training materials which allowed easy revie The inspector found that the licensee did organize the license conditions in a manner that allowed easier review by the trainee Subsequent to this action, Amendment No. 14, effective September 17, 1979, was issued and the complete set of applicable Technical Specifi-cations was provided by this Amendmen The inspector also verified that the licensee presently has all the training materials called for in the " Operator Requalification Program for the Union Carbide Research Reactor", dated May 1980, available to the reactor operator d. (Closed) Unresolved Item (54/78-01-06): The licensee was inserting experiments with reactivity worths greater than 0.15%Ak/k during reactor operation. The matter was to be clarified by changing the license or Technical Specification Amendment No. 14 to the license, effective September 17, 1979, included Technical Specifications 3.5.1.c(4) and 3.5.1.c(5) which addressed the movement of experiments in the reactor and resolved this item. Technical Specification 3.5.1.c.(5) states "An experiment worth more than 0.25%Ak but less than 0.5%Ak rnay be moved with the reactor subcritical by at least 0.75%Ak."
e. (Closed) Unresolved Item (54/78-04-01): The Production Manager was not performing the semi-annual review of procedures in accordance with Procedure RM-01, Regulations Manua ,
The inspecter determined that a periodic review of procedures is not- i now required by Technical Specifications or procedures. Procedures are to be followed until revised. When revised, the procedures are to be reviewed by the Nuclear Safeguards Committee and approved by a level 2 manage f. (Closed) Unresolved Item (54/78-04-02): The acceptance criteria for the calibration of the flow meter was given as both 1% and 3% in Procedure RS-39, Flow Meter Calibratio The inspector determined that Procedure RS-39 now requires the flow meter reading to be within 3% of the measured volume delivered over a specified time on three consecutive test g. (Closed) Infraction (54/79-01-01): The Nuclear Safeguards Committee failed to perform semi-annual reviews of facility operations, as called for by paragraph 4.E of licens . .
The review function of the Nuclear Safeguards Comm'ttee was redefined by Technical Specification 6.1.5.3, incorporated in the license by Amendment No. 14, effective September 17, 1979. The inspector examined the reviews performed by the Nuclear Safeguards Committee from September 1979 through April 1982. The NSC performed reviews in accordance with the Technical Specification during that time, b. (Closed) Unresolved Item (54/79-01-02): The Nuclear Safeguards Committee (NSC) Chairman and the Manager of Nucleonics did not attend three NSC meetings in 1978. The inspector discussed this apparent lack of management attention to NSC activities with'the license During this inspection, the inspector noted from minutes of meetings nos. 88-99 that the NSC Chairman was present at 6 of 11 meetings (attendance not given for meeting no. 94). The Manager of Nucleonics was present at 8 of 11 meetings. The 4 other committee members were present at 8, 9, 10, and 11 meetings, respectively. There was a quorum at each meeting in accord with Technical Specification 6.1.5. i. (Closed) Unresolved Item (54/79-01-03): The adequacy of the audits performed by the Nuclear Safeguards Committee dated May 15, 1978, and September 29, 1978, could not be evaluated because of lack of detail in the audit documentatio The inspector examined the audits performed in 1980 after Amendment No. 14 to the license became effective. The audit documentation was of sufficient detail to adequately describe the subjects and findings of the audi j. (Closed) Infraction (54/79-01-04): The Senior Reactor Operator was not present for the restart of the reactor after a scram caused by the pool water dropping below the low pool level reactor scram setpoin The previous license conditions and the present Technical Specifica-tions require the presence of a Senior Reactor Operator during recovery from unplanned or unscheduled shutdowns unless special conditions exist. Among the conditions not requiring the presence of a Senior Reactor Operator for the restart of reactor is an unplanned shutdown resulting from " false signals, which, in the opinion of the Senior Reactor Operator, were properly verified to be false and to have resulted from monitoring, experimental, or control equipment, or from personnel in advertence." The licensee stated that the dropping of the pool water level was caused by a valving error; the Senior Reactor Operator was properly notified; and the cause of the scram was well understood by all concerned. Therefore, the event met the intent of the false signal condition, and the presence of the Senior Reactor Operator, during restart of the reactor, was not require . .
During the present inspection, licensee management stated that they were aware of the requirement to have a Senior Reactor Operator present during restart after a scram caused by a real rather than a false signa k. (Closed) Infraction (54/79-01-06): The reactor operator was absent from line of sight of the controls for approximately 5 seconds while attempting to find the control room copy of the Technical Specifications for the inspecto During this inspection, the inspector found that procedure RM-04, Reactor Operation, dated May 1, 1980, states that the minimum staffing, when the reactor is not secured,is a licensed Reactor Operator in the control room at the controls. According to the licensee, the Reactor Operators understand that being at the controls means to have the controls in full vie . (Closed) Deficiency (54/79-02-01): The licensee had not properly labeled a 55 gallon drum containing radioactive materials to show it contained the materia During this inspection, the inspector noted that containers, such as the 55 gallon drums, were properly labeled " Caution-Radioactive Materials." (Closed) Infraction (54/79-02-02): The licensee had not properly roped off and posted an area which had removable contamination above the level requiring the area to be roped off and poste During the inspection, the inspector noted that areas with radioactive contamination were being controlled to require personnel to wear proper protective clothing while in the area n. (Closed) Infraction (54/79-02-03): The licensee performed an ion exchange filter replacement job without benefit of an evaluation of the radiation hazards involved in the jo During this inspection, the inspector verified that the licensee prepared a procedure for the ion exchange filter replacement which provided radiation protection precaution The inspector also reviewed a Health Physics Log entry, dated January 26, 1982, concerning Health Physics monitoring of a filter replacement. A sample of the breathing zone air was taken as the filter was removed from its holder and placed in a waste dru The sample showed no radioactivity in the breathing zone ai o. (Closed) Deficiency (54/79-03-04): The licensee had not determined the radiation dose received by an individual and had not recorded the information on the individual's exposure record . .
The licensee subsequently located the film badge report which provided the exposure information, and the licensee recorded the information in the exposure records. During this inspection, the inspector verified that the licensee is posting the radiation exposure data in the exposure records well within 3 months from the date of receipt of the dat p. (Closed) Infraction (54/79-02-05): The licensee was performing urinalyses on personnel working in the reactor building on an annual rather than on a semi annual basi The current Technical Specifications do not have a requirement for urinalyses of personnel working in the reactor building. The licensee has continued to perform urinalyses of reactor personnel on an annual basi q. (Closed) Infraction (54/79-02-06): The licensee failed to evaluate the concentration of I-133 in the 1977 and 1978 gaseous effluents, when the ratio of I-133 concentration in the effluent to the maximum permissible concentration (MPC), given in Appendix B, of 10 CFR 20, was greater than 0.1. The violation was based on the following gaseous effluent data for 1977 and 197 Curies Curies Year I-125 %MPC I-131 %MPC 1977 .0 37 1978 .8 28 Using the 0.4 ratio of I-133 concentration percentage of MPC to I-131 concentration percentage of MPC derived in paragraph 3.d of Inspection Report No. 50-54/77-04, the I-133 concentration percentage of MPC in the gaseous effluent during 1977 and 1978 was 15 percent and 11 percent, respectivel The licensee performed an evaluation of this ratio of I-133 concen-tration percentage of MPC to I-131 concentration percentage of MPC during September of 1977 and determined the ratio to be 0.52. Using this ratio and the gaseous effluent data for 1979, 1980, and 1981, the following percentage of MPC for I-133 .;:y be determine .
Curie Year I-131 %MPC %MPC for I-133 1979 0.14 .05 1980 1.52 .5 1981 3.43 .2
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The concentration of I-133 in the gaseous effluent during 1979, 1980, and 1982 was less than 10 percent of the MPC using the 2000 dilution factor allowed by the license prior to Amendment No. 1 Therefore, according to note 5 of Appendix B, 10 CFR 20, after 1978 the licensee could consider the I-133 as not present in the gaseous effluen T'le cause for the sharp reduction in the amount of iodine discharged from the facility was the installation of a better charcoal filter bank in the Hot Cell off gas ventilation syste . Radiation Dose in Unrestricted Areas The new Technical Specifications, incorporated into the license by Amendment No. 14, effective September 17, 1979, included new Technical Specification 3.8.2. Oose in Unrestricted Areas. Section a. of this Technical Specification requires the calculation and reporting of the total body dose due to noble gas releases and dose from radiciodines in gaseous effluents for the critical individuals in unrestricted areas. The Technical Specification gave limits for these allowable total body doses from noble gases and from radioiodines. The licensee was not considering I-133 in the calculation of the total body dose as called for in Technical Specification 3. As pointed out in the immediately preceding portion of this report, the licensee performed an evaluation of the I-133 to I-131 concentrations in the gaseous effluent. The concentrations were such that the I-133 concen-tration in the gaseous effluent would provide a dosage equivalent to 0.52 of the I-131 dosage. Thus, during 1980 and 1981, the calculated doses to a critical individual in the unrestricted area would have been as follows:
Dose Year I-125 I-131 1-133 1980 0.48 0.71 0.38 1981 0.34 0.73 0.38 Technical Specification 3.8.2 for radiation dose does not exclude any radiof odines on the basis of half-life as does Technical Specification 3.8.1 for radioactive release rate. Based on the ratio of I-133 to I-131 present in the gaseous effluent found by the licensee, the dosage from I-133 is a significant part of the total doce from radioiodine Failure to consider I-133 in the calculation of the total body dose to the critical
individuals in unrestricted areas is a violation (50-54/82-03-01). Facility Operations Upon arrival at the site on June 1, 1982, the inspector toured the accessible areas of the facility with a licensee representativ The inspector observed general housekeeping, radiation controls, and operational activi-tie _ - . __ __ __
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The level of housekeeping appeared acceptable except for the lower pump room. There were hoses on the floor and drums were positioned in the room haphazardly. The licensee indicated that they were working on an ion exchange resin change which created this situatio Radiation control activities were discussed previously in section 2 of this report. Waste drums containing radioactive waste were properly labele Contamination control areas were properly marke Shielding was provided for an operator performing work involving relatively high levels of radiation. The inspector noted that this operator was using a radiation survey instrument to determine radiation levels in his work are No violations were identifie . Organization The organizational positions and the incumbents of the positions providing the management levels described in the Technical Specifications are as follows:
Level Responsibility Position Incumbent 1 facility license and Business Manager, J. J. McGovern site administration Radiochemicals 2 reactor facility Manager, Nuclear M. H. Voth management Operations 3 daily reactor Reactor Supervisor W. G. Ruzicka operation This organization is as given in the 1981 Annual Operating Summary, and it complies with Technical Specification 6.1, Organizatio No violations were identifie . Logs and Records The inspector reviewed the licensee's Process System Data sheets for June 1, 1979, through May 31, 1981. These sheets showed the licensee had problems with pool water quality during January and November 1980. The specific resistivity of the water was below 200,000 ohm-cm but greater than 10,000 ohm-cm for periods approaching the 14 day Technical Speciff-cation limit. Data sheets during 1981 did not show any problems with pool nater qualit . .
The data sheets showed maintenance problems such as the belts on blowers being loose and low flow on a beam tube circulation system. The inspector inquired as to how maintenance personnel were informed of needed equipment repairs. The licensee representative stated that the Reactor Supervisor informs the Facility Engineer of any such needed equipment maintenanc The inspector reviewed the reactor operation logbook. Any unplanned or unschedulad shutdown was shown with a red ink stamp entry in the logboo These entries appeared to be filled out properl No violations were identifie . Reviews and Audits The inspector r eviewed the minutes of Nuclear Safeguards Committee meetings 88 through 99, which were held between September 11, 1979, and April 6, 1982. These minutes listed the reviews performed the committe The membership of the Nuclear Safeguards Committee is in accord with the Technical Specifications. The committee has more than 5 members. The chairman .eports to the Level 1 manager. The Level 1 manager is also a member of the committe The committee met five times in 1980 and four times in 1981. The committee has had one meeting thus far in 1982. The committee held meetings at least semi-annually. A quorum was present at each meetin During meetings 88 through 99, the committee reviewed nine proposed design chcnges for the reactor facility. The minutes indicated that the committee cm sidered the Technical Specifications and safety implications of the proposed changes during these reviews. The committee reviewed 47 procedures during these meetings. Most were accepted as written. Changes were requested in some instance It was noted that the Level 2 manager approved procedures prior to submission to the Nuclear Safeguards Committee for review. This was unusual since management approval of a procedure is generally conditional upon acceptance by the reviewing authority. The licensee indicated they would consider the sequence used in their procedure review and approval proces It was also noted that recently the committee has not been meeting as frequently, and months of delay between submission of procedures for, review and review by the committee have occurred. The inspector noted that more timely review could be achieved by using committee subgroups as allowed by the Technical Specification During the review of the minutes of the Nuclear Safeguards Committee meetings, the inspector noted that the minutes did not always show that actions called for by the committee have been accomplished. For instance,
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in the minutes for meeting No. 88, September-11, 1979, the Nuclear Safeguards Committee called for Health Physics to review the ventilation of a hot cell and for Reactor Operations to review the documentation of the reactivity worth of samples to satisfy a Nuclear Safeguards Committee audit, and subsequent meeting minutes didn't document that these actions were take The licensee indicated that committee members were personally aware that corrective actions were taken and the need to document this was not recognized. The inspector noted that such documentation is needed to provide a complete recor The records showed that since the current Technical Specifications became effective on September 7, 1979, the licensee has conducted the following audits:
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Two annual audits of conformance to Techni:al Specifications;
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One biennial audit of reactor operator retraining and requalification; and
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One annual audit of results of actions taken to correct deficiencies in reactor facility equipment, systems, structures, or operation No violations were identifie . Licensee Action on Bulletins and Circulars t Circular 77-14, Separation of Contaminated Water Systems from Non-Contaminated Systems The licensee found six places in the water system where potentially contaminated water systems were connected to non-contaminated water systems. The licensee provided an air gap in one case and provided double check valves in four cases to provide separation between the water system In one instance, a contaminated water system, no longer in use, was completely disconnected from the non-contaminated syste Bulletin 78-07, Protection Afforded by Air-Line Respirators and Supplies Air Hoods The licensee determined that the bulletin information was not applicable to their operation,since their respiratory protection program did not include the use of supplied-air hoods or air-line supplied respirators operated in the demand mode. Since the bulletin was not applicable, no response to the NRC was require . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
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11 Bulletin 78-09, Radiation Levels from Fuel Element Transfer Tubes The licensee's facility does not have a fuel element transfer tube and no parts of the facility were subject to the problem dis ussed in the bulletin. A transfer canal connects the reactor pool <nd the hot cells. Shielding of the canal is equivalent to the reactor pool shielding. No response to the NRC was require Circular 79-09, Occurrences of Split or Punctured Regulator Diaphragms in Certain Self-Contained Breathing Apparatus The licensee purchased diaphragm replacement kits from Scott Air Pak and installed them on their two self-contained breathing apparatus on February 27, 1981. This kit removed the problem being encountered with split or punctured regulator diaphragm . Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on June 4, 198 The inspector presented the scope and findings at the inspectio The inspector pointed out that the minutes of Nuclear Safeguards Committee meetings do not always show that actions called for by the committee are completed. The committee secretary indicated he would bear this point in mind while preparing the meeting agendas and minutes. (Paragraph 6.)
The inspector pointed out that the sequence for the review and approval of procedures appeared to be out of order, since the Level 2 manager approved procedures prior to the Nuclear Safeguards Committee revie The licensee indicated that the review was a condition to be satisfied prior to use of of the procedure so the order of the reviews and approval was not that important. However, the l1censee indicated they would consider the sequential order'of the process. (Paragraph 6.)
The inspector pointed out that recently there was quite a delay between the request for Nuclear Safeguards Committee review of procedures and the performance of the review. The licensee indicated this had not posed problem (Paragraph 6.)
The inspector indicated that the housekeeping in the lower pump room was not in the same state as the rest of the facility. The licensee indicated recent work activities and radiation levels were the reasons for this situatio They also indicated that the area would be put in order as soon as possiM (Paragraph 3.)