IR 05000057/1979001
| ML19253C808 | |
| Person / Time | |
|---|---|
| Site: | University of Buffalo |
| Issue date: | 06/06/1979 |
| From: | Donaldson D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19253C794 | List: |
| References | |
| 50-057-79-01, 50-57-79-1, NUDOCS 7912120158 | |
| Download: ML19253C808 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
'80 97/79 01 Docket No.
50-57 License No.
R-77 Priority
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Category F
Licensee:
State University of New York at Buffalo Rotary Road Buffalo, New York 14214 Facility Name:
Nuclear Science and Technology Facility (NSTF)
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Inspection at:
Buffalo, New York Inspection conducted: February 26-28, 1979 Inspectors:
A JrfA Ah 3.7.o-79 D. Donaldson, Radiation Specialist date signed date signed date signed
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~2 dr Approved by:
e J./P. stohr, Chief, Environmental and
'date 'si gn'ed Special Projects Section
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Inspection Summary Inspection on February 26 - 28, 1979 (Report No. 50-57/79-01)
Areas Inspected:
Routine, unannounced inspection of the environmental protec-tion, emergency planning, and radiation control programs including:
under environmental protection; airborne effluents, liquid effluents, and solid waste:
under emergency planning; emergency plan verification, outside agency coordination, training and drills, and emergency equipment:
and under radiation control; posting and labeling, personnel monitoring, instrument calibration, and radiation and contamination surveys. In addition, a liquid sample was collected for subse-quent comparative analysis and the licensee's actions on unresolved and noncompli-ance items were reviewed.
The inspection involved 20 inspector-hours on site by one regional based NRC inspector.
Results: Of the 13 areas inspected, two apparent items of noncompliance were identified in one area (Infraction - failure to provide notice to radiation workers, Detail 3.b; Infraction - failure to post radiation areas, Detail 3.c).
538 299 y Region I Fonn 12 (Rev. April 77)
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- Dr. W. Chon, Acting Director, Science and Technology Facility
- Dr. A. Bruce, Radiation Safety Officer
- Mr. M. Pierro, Manager, Radiation Protection Department
- Mr. P. Orlosky, Operations _ Manager Other Personnel
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- Mr. H. Prins, New York State Department of Environmental Conservation
- denotes those present at the exit interview.
2.
Licensee Action Previous Inspection Findings (Closed) (Jnresolved Item (77-02-03) Procedures for emergency medical treatment.
The inspector reviewed procedure OP #52 dated September 77, Medical Emergency Procedures.
The inspector noted that the procedure had been distributed to the appropriate personnel and that persons responsible for implementing the procedure were familiar with the contents.
(Closed) Noncompliance (78-03-01) Failure to perform quarterly radiation monitor calibrations and monthly radiation survey instrument operational checks.
The inspector held discussions with licensee to verify that the aforementioned instruments were properly checked and calibrated.
The inspector determined that all required maintenance had been performed since the original citation and that the licensee's corrective action was consistent with that outlined in a letter to the NRC dated September 7, 1978.
3.
Radiation Control a.
Posting, Labeling and Access Control The inspector toured the licensee's facility to observe the general aspects of the licensee's radiation control program with regard to posting, labeling and access control.
The inspector noted that:
the posting of notices to workers was consistent with the requirements of 10 CFR 19.11; A hand and foot monitor was available and operable at the main egress from the facility; and personnel were observed to be wearing personnel dosimetry (film, thermoluminescent, ring badges and pocket chambers) to measure any exposure to ionizing radiation. All entrances to the confinement building were controlled via 1538 300
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key cards issued to personnel employed at the facility.
The inspector also noted that various areas within the facility exhibited posting of radiation, high radiation and contaminated areas.
No items of noncompliance or deviations were identified during the facility tour.
During a later portion of the inspection, the inspector identified an item of noncompliance with the posting requirements of 10 CFR 20.203(b) (see Paragraph 3.c fordetails).
b.
Training The inspector held discussions with licensee personnel and reviewed available documentation of training programs and records of personnel training to verify that all individuals who work in or frequent the licensees facility had been instructed in the health protection problems associated with radiation and the radiation safety procedures to be observed while at the licensees facility.
Volume II of the State University of New York (SUNY) at Buffalo Radiation Protection Department Procedures (Nuclear Science and Technology Facility Radiation Protection Procedures, dated December 1978 and issued January 1979) represents the means by which individuals receive indoctrination training in the above areas.
Each individual is provided with a copy of the manual and required to acknowledge familiarity with the contents and their resposibilities via return of a signed record.
Additional training is provided to individuals whenever any non-routine activities or procedures are scheduled to be performed.
During discussions with licensees representatives, the inspector determined that members of the campus security police make unescorted entries into the confinement building and other areas of the facility in which radioactive materials are stored or used.
These entries are made during periods when the facility is otherwise unoccupied (i.e., weekends).
Further discussion indicated that members of the security force had not been instructed in the health protection problems associated with radiation, the precautions or procedures to be observed while in areas of the facility where radioactive materials and/or radiation are present.
The licensee representative stated that training was limited to instructing guards to wear a film badge and dosimeter when entering the facility.
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The inspector informed the licensee that the failure to provide adequate instructions to the members of the SUNY at Buffalo security force constituted noncompliance with the requirements of 10 CFR 19.12 regarding instructions to workers. (79-01-01)
c.
Radiation and Contamination Surveys The inspector held discussions with licensee representatives, reviewed available records and performed independent measurements to review the licensee's established program for surveying direct radiation levels, for monitoring the presence of radio-active contamination, and for proper posting of existing areas.
The inspector reviewed the licensee's contamination survey records covering the period January 1978 through January 1979.
The inspector noted that surveys were conducted on weekly and monthly bases in all areas of the facility.
The inpsector's review of the licensee's records indicated no detectable activity in areas other than the neutron deck of the confinement building. (During the tour of the facility, the inspector noted that this area was locked to control access and the entrance to tha area was posted as a contaminated area.)
The inspector also reviewed licensee records of routine weekly and monthly direct radiation surveys performed during calendar
year 1978.
In addition to the above, the inspector accompanied a licensee health physics technician during the performance of a contamina-tion and radiation survey.
During this portion of the inspection, the inspector noted that two areas on the gamma deck exhibited radiation dose rates in excess of 5 millirems per hour.
The area above the reactor pool, to include the forward area of the control bridge over the pool, exhibited radiation levels of from 2 to 20 millirem / hour.
A second area, used for storage of a pool vacuum cleaner and filter, exhibited radiation levels from 5 millirem / hour at a distance of 10 feet up to 25 millirem at approximately 6" from contact.
The inspector observed that the areas near the reactor pool which exhibited radiation in excess of 5 millirem / hour were neither posted as a radiation areas nor were.there any indica-tions of the several area dose rates posted in the areas.
While a sign on the filter and vacuum indicated that dose rates as high as 15 millirem per hour, the limits of the radiation area created by the presence of the equipment were not posted, nor was the existing sign readily visible.
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The inspector informed the licensee that the failure to properly post the two areas described, constituted noncompliance with the requirements of 10 CFR 20.203(b) concerning the posting of radiation areas.
(79-01-02)
d.
Personnel Exposures The inspector reviewed personnel exposure records covering calendar year 1978.
During this review, the inspector noted that one individual has received a whole body dose of 1.413 rem during the month of June.
Further review of this exposure indicated that the individual was in charge of various maintenance activities during the month.
On July 19, 1978, the licensee's Operating Comittee met to discuss the causes of the higher than normal exposure and investigate the circumstances surrounding the exposure. As a result of this meeting, a memorandum was issued from the Committee to the individual, restricting the scope and extent of his allowable work in and around radiation.
The inspector noted that the individual's exposure history was current, that the exposure did not cause his permissable accumulative dose to be exceeded, and that the quarterly upper limit of 3 rem whole body had not exceeded.
The licensee representative stated that this was an unusual occurrence and received intensive management attention and prompt remedial action.
Further review of the licensee records indicated that the quarterly whole body, extremity and skin exposures to individuals were < 20% of the 10 CFR 20.101 limits. The inspector further noted that exposure records and exposure histories were maintained in a form and manner consistent with 10 CFR 20.102 and 20.401.
No items of noncompliance were identified.
e.
Calibration of Ht.alth Physics Instrumentatig The inspector held discussions with licensee personnel to verify that a program for routine calibration of personnel dosimeters and radiation survey instruments was established.
The inspector determined that the licensee performs radiation survey instrument calibrations monthly.
The inspector noted that while ionization chambers and sodium iodide detectors were calibrated with a reference source, Geiger-Muller (GM)
instruments were only pulser checked.
The inspector discussed 1538 303
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the adequacy of such checks serving as a calibration.
The licensee representative stated that the method of calibrating G-M tube instruments would be reviewed and appropriate provision would be made to calibrate the instruments with a reference source while the instruments were in operational configuration.
The inspector informed the licensee that this item would be reviewed upon implementation of this change (79-01-03).
The inspector also reviewed records and methods of calibrating and checking area radiation and effluent monitors.
The inspector determined that all required checks and calibrations had been performed.
During the tour of the facility, the inspector noted that the stack gas monitor was in a state of alarm.
Discussion with licensee personnel indicated that this condition was constant due to the fact that the technical specifications establish an alarm set point (1 X 10-6 uCi/ml) that is slightly below the characteristic level of the stack effluent during operation (approximately 6 X 10-5 uCi/ml).
Both the monitor set point and the normal levels of gaseous effluent discharged from the
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stack are much lower than the maximum ~ allowable instantaneous release rate concentration (4.3 X 10-3 uCi/ml) and the maximum allowable yearly average release rate concentration (4.2 X 10-4 uCi/ml) permitted by section H.4. of the technical specifications.
The licensee further stated that the monitor set point had originally been determined using the alarm sensitivity factor supplied by the instrument vendor.
Since then, the alarm sensitivities of the vendor were found to be incorrect, and adjustment of the set point in accordance with the measured sensitivity created a constant alarm condition.
The licensee concluded by stating that this set point anomaly would be corrected in a new set of technical specifications being developed as part of a license renewal application.
The inspector had no further questions at this time.
4.
Environmental Protection The inspector reviewed the licensee's effluent monitoring and environmental protection in the following areas:
a.
Airborne Effluents The inspector noted that the facility stack and the building vent were the only airborne effluent release paths to the environment.
The licensee monitors the stack for noble gases and particulates and the building air for noble gases.
During the discussions involving the various sampling methods, the 1538 304
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inspector noted that the sampling for stack particulates appeared to be anisokinetic.
Approximate calculations performed by the inspector indicated that the linear flow of the effluent stream was approximately 3395 feet / minute and 597 feet / minute for the sampling stream. The inspector discussed the effect of anisokinetic particulate sampling upon the adequacy of resulting measurements, and informed the licensee that the failure to sample isokintically could result in erroneous measurements of stack particulate activity releases.
The licensee representative stated that the particulate sampling would be reviewed to ascertain whether or not the sampling was being performed isokinetically and that appropriate action would be pursued if the sampling were in fact anisokinetic.
The inspector stated that this item would be unresolved pending the outcome of the licensee's review.
(79-01-04)
The inspector reviewed the licensee's gaseous effluent release records for 1978 and noted that all required sampling had been performed. As of the date of the inspection, the licensee had not totaled the activity released for the year nor figured the yearly average concentrations. These results will be reported in the licensee annual report and will be reviewed during a subsequent inspection.
The inspector did, however select a sampling of data to ascertain the general trend of the licensee's gaseous effluents releases in comparison with the release limits of the technical specifications.
This review indicated releases for the stack and building vent were within the technical specification limits.
b.
Liquid Effluents Liquid radioactive waste is collected in two 250 or two 600 gallon tanks. The waste in these tanks is then transferred to a 10,000 gallon tank where it is recirculated, sampled and analyzed for gross beta-gamma and gamma isotopic activity prior to discharge to the sanitary sewer system.
During calendar year 1978, the licensee discharged a total volume of 51,822 gallons of liquid waste having a total activity of approximately.034 Curies.
A review of liquid effluent discharge records indicated that all releases of liquid waste to the sanitary sewer system were below 10 CFR 20 limits.
A more detailed summary of the licensee's 1978 liquid effluents will be prepared as part of the annual operation report.
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c.
Solid Waste Solid waste is shipped offsite by a commercial contractor.
Three solid waste shipments were made in 1978 having a total
volume of 3,187 ft.
These shipennts represent solid radioactive waste from the entire SUNY at Buffalo compus. Of the total waste shipped, approximately 150 ft3 were generated by the reactor facility.
The total activity of the waste will be reported by the licensee in the 1978 annual operating report.
No items of noncompliance were identified.
d.
Split Samples A pool water sample was taken by the licensee and split with the inspector for the comparison of analytical results.
Samples will be analyzed for gross beta-gamma, gamma isotopic emitters and tritium by the licensee and the NRC contracting laboratory (Department of Energy Radiological and Environmental Services Laboratory). Due to the recent failure of the licensee's Ge(Li) detector, the licensee will perform the gamma isotopic analyses via chemical separation methods.
This will represent a non-routine method for the licensee which is being used during the period while awaiting arrival of a new Ge(Li)
detector. Joint analysis of actual samples and subsequent comparison of results determines the licensee's capability to measure radioactivity in samples.
The results of these analyses will be reported in a subsequent inspection report.
5.
Environmental Monitoring The inspector noted that while the licensee had no formal require-ment to implement an environmental monitoring program, thermo-luminescent dosimeters (TLDs) are placed at 10 locations in the environment. The inspector reviewed TLD reports and noted that environmental radiation levels were all in the range of normal background.
No items of noncompliance were identified.
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6.
Emergency Planning a.
General The inspector noted that the licensee's existing requirements relative to emergency planning were limited to the need for procedures. Discussion with licensee representatives indicated that an emergency plan and full set of emergency plan implementing procedures were being prepared for submittal to the NRC as part of a licensee renewal application.
At the licensee's request, the inspector reviewed a draft emergency plan and discussed general considerations for emergency plans and procedures at research reactors.
b.
Verification of Emergency Planning and Procedures The inspector discussed the methods of handling a postulated incident with several licensee employees.
These discussions indicated that individuals could recognize an emergency situation.
respond in a coordinated fashion, and contact appropriate individuals.
No items of noncompliance were identified.
c.
Outside Agencies The inspector noted that emergency medical procedures existed in coordination with Roswell Park Memorial Institute and the Veterans Administration Hospital.
In addition, the New York State Department of Health is included to provide support in other areas in the event of an emergency.
d.
Monitoring Systems / Alarms /Emercency Equicment The inspector examined the effluent radiation monitoring systems and emergency alarm and verified that they were operable and had been calibrated and tested on a routine basis.
(Paragraphs 3.e. and 4.a) The inspector also examined an emergency kit maintained in the locker room.
No items of noncompliance were identified.
e.
Training & Drills The inspector noted that an emergency drill had been conducted on Feburary 7,1979.
Training was performed concurrently with this drill.
No items of noncompliance were identified.
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7.
Unresolved Item Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved Items disclosed during the inspection are discussed in Paragraph 4.a.
8.
Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on. February 28, 1979. The inspector summarized the scope and findings of the inspection.
In reply to the inspection findings, licensee management acknowledged the items of noncompliance and stated that the unresolved item concerning stack particulate sampling would be reviewed.
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