IR 05000057/1983001
| ML20204F967 | |
| Person / Time | |
|---|---|
| Site: | University of Buffalo |
| Issue date: | 03/28/1983 |
| From: | Elsasser T, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20204F937 | List: |
| References | |
| 50-057-83-01, 50-57-83-1, NUDOCS 8305020332 | |
| Download: ML20204F967 (12) | |
Text
.,_
. .
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-57/83-01 Docket No. 50-57 License No. R-77 Priority -
Category F Licensee: State University of New York at Buffalo Rotary Road Buffalo, New York 14214 Facility Name: Nuclear Science and Technology Facility Inspection At: Buffalo, New York Inspection Conduct : F,ebrua ry3 14 - 17, 1983 Inspector: Os .3 /Z8 3 W. W. Kinhey( rojectI[spector / da(e Approved by: !, -
J[4f 3 T. C. ElsasseYf Chief, Reactor Projects date Section No. IB Inspection Summary: Inspection on February 14 - 17, 1983 (Report No. 50-57/
83-01)
Areas Inspected: Routine, unannounced inspection by a region-based inspector ( (32 hrs.) of licensee action on previous inspection findings, facility opera-tions, organization, reviews and audits, surveillance activities, experiments, logs and records, procedures, and operator requalification trainin Results: Three violations and one deviation were identified (failure of Nuclear Safety Committee (NSC) to review overall safety aspects of the Nuclear Science and Technology Facility and to meet at least two times a year since September
.
1981 paragraph 6.a; failure of the NSC to review and approve Operating Proce-l dure No. 41 paragraph 6.a; failure to calibrate secondary water temperature l' measuring instruments and primary water resistivity measuring instrument on a quarterly frequency paragraph 7; failure to document instruction of security force in radiation protection and to reinstruct security force annually as committed in a September 24, 1979, letter to Region I paragraph 2.).
8305020332 830418 PDR ADOCK 05000057 PDR g
L
,X- 4 rs Ji-- 4-,* w --+4- .e- .-_v
. .
,
i DETAILS Persons Contacted
L. G. Henry, Acting Director
P. M. Orlosky, Operations Manager i
M. A. Pierro, Radiation Protection Manager
- R. C. Kerns, Supervisor- _
R. L. Jones, Supervisor The inspector also interviewed reactor operators and the health physicist during the inspectio * Denotes those present at the exit intervie . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (78-01-02): The Nuclear Safety Committee (NSC) <
,
was to perform a nuclear safety review of the operation of the Nuclear Science and Technology Facility (NSTF). This reactor safety review was completed, and the results were documented in the July 10, 1979, lette (Closed) Inspector Follow-Up Item (78-01-04): An inspector was to review the disposal of contaminated primary ~ piping removed when the primary piping was replaced and rerouted in 1978. The licensee shipped the piping
- tY a licensed burial ground for burial.
! (Closed) Inspector Follow-Up Item (78-02-01): The licensee's Radiation
'
Protection Manual had not been updated since October 1963. The licensee reviewed and revised'the Radiation Protection Manual, and the current j revision is dated October 198 (Closed) Inspector Follow-Up Item (78-02-02): An inspector was to review l the status of the stack monitor calibration. The inspector reviewed the i records of the calibration of the stack monitors and found the stack gas
,
and particulate monitors were calibrated during 1980 through 198 l (Closed) Inspector Follow-Up Item (78-02-03): An inspector was to review the 1977 annual effluent release report for 197 The inspector reviewed the .1977,1978,1979,1980, and 1981 effluent release reports and found the effluents to be within the limits given in Technical Specification 0.4.h.(4).
(Closed) IE Circular (79-SC-07): IE Circular No. 79-09 informed certain licensees of the high rate of regulator diaphragm failures in the Scott Air Pak II/ IIA and Pressure Pak II/ IIA self-contained breathing apparatu The inspector provided a copy of the circular to the licensee for their appropriate action, since the licensee does have a Scott Air Pak self-
- contained breathing apparatu (Open) Infraction (79-01-01)
- The licensee had not provided adequate radiation protection instructions to members of the State University of
, - - , - - . - - ,- - ,-,- . .._ - - -.--- - - - - -.. - . _ - - _ ... - - - . . - - -.
.
New Ycrk (SUNY) at Buffalo security force as required by 10 CFR 19.1 The licensee prepared a comprehensive " Training Manual for Officers of the Department of Public Safety" and completed the training of these officers during late 1979, as committed in their September 24, 1979, letter to Region I. However, the licensee did not document this training, retrain all officers on an annual basis, or document this annual retrain-ing, as committed in this same letter. This failure to perform these actions is a deviation (83-01-01).
(Closed) Infraction (79-01-02): The licensee had not properly posted two radiation areas as required by 10 CFR 20.203(b). The inspector verified that the licensee prepared and circulated a memorandum to members of Operations, Research, and Radiation Protection Departments. The memo-randum explained the methods to be used to post and provide access control to radiation areas. Radiation areas were observed to be properly posted during the current inspectio (0 pen) Unresolved Item (79-01-04): The sampling of the stack gas for particulates was to be reviewed to determine if the sampling was iso-kinetic. The licensee determined the sampling might be improved. In November 1982 the licensee assigned the design of an isokinetic parti-culate stack gas sampler to an engineering student. The student has yet to submit the design for the sample (0 pen) Inspector Follow-Up Item (79-02-01): The licensee had no written verification that reactor operators had reviewed the memoranda issued to describe facility modification During this inspection, the inspector found that the licensee has issued memoranda describing facility modifica-tions to each operator. The licensee had not as yet obtained verification from the operators that they had read and understood the memoranda. The licensee indicated they would post a copy of each memorandum, when it is issued, for the operators to sign as verification of operator review of facility modificatio (Closed) Infraction (79-02-02): The Nuclear Safety Committee (NSC) had not reviewed NSTF operating procedures. The licensee had a member of "the Center for Nuclear Safety Research Technical Staff" review operating procedures and provide a facility audi The results of the audit were documented in a July 10, 1979, letter from the auditor to the NSTF Directo . Facility Tour Upon arrival at the site, the inspector toured the accessible areas of the NSTF with licensee representative The inspector noted that there was a sizable amount of combustible mater-ials stored in the containment vessel. The licensee has many cardboard boxes used in packaging radioisotopes stored.on the gamma deck and paraf-fin for neutron shielding stored on the neutron deck of the facility. The licensee also uses fiberboard drums as the collection containers for
. .
contaminated waste. This combustible load emphasizes the need for good housekeepin The inspector noted that the housekeeping in the containment vessel could be improved and resumption of the housekeeping inspections by the Opera-ting Committee would be beneficial. The licensee agreed that improvement could be made in the housekeeping of the facility. An example of the lack of housekeeping was an experimental setup in place in a laboratory room long after the experimental work was finished. The vault used for storage of special nuclear fuel was also being used for storage of miscellaneous boxes and supplie No violations were identifie . Facility Operation The licensee operates the reactor continuously from 4:00 p.m. on Sunday until shutdown on Friday.using a three shift per day schedule. Any necessary maintenance is performed on Friday, after shutdow The main work accomplished using the reactor is the irradiation of steel samples, the production of radioisotopes, the testing and calibration of neutron detectors, and the irradiation of samples for academic experi-menters. Students can take independent study courses involving the reactor to obtain academic credit toward their major fields of stud No violations were identifie . Organization The organization responsible for the safe operation of the Nuclear Science and Technology Facility (NSTF) is as follows:
Position Incumbent Vice-President for Research and Graduate Studies Dr. D. W. Rennie Acting Director L. G. Henry Radiation Protection Manager M. A. Pierro Operations Manager *P. M. Orlosky Supervisors *A. Adams, J *W. W. Elliott
- R. L. Jones
- R. C. Kerns Senior Operator *M. S. Adams Operators **B. Yager
- J. Bogdan
- K. Miller
- A. P. Vargas Chemical Technicians C. H. Wall N. Misso E. P. Tragash
--
. .
- Licensed Senior Reactor Operator
- Licensed Reactor Operator As required by Technical Specifications, at least two persons work on each shift. Three of the four supervisors work during the day shift (8:00 a.m. to 4:00 p.m.). One supervisor works during the evening shift (4:00 p.m. to 12:00 a.m.) on a permanent basis. University student licensed reactor operators work with this supervisor on a-part-time schedule so that one is always present during the evening shift. The senior operator and a reactor operator work during the morning shift (12:00 a.m. to 8:00 a.m.). Occasionally, a student licensed reactor operator will also work during the morning shif The Nuclear Safety Committee currently consists of the following members:
Dr. J. A. Marinsky, Chairman Mr. M. A. Pierro, Secretary Dr. A. K. Bruce Dr. L. B. Borst Mr. P. M. Orlosky Mr. L. G. Henry Dr. J. P. Roalsvig The Operating Committee, as required by Technical Specification, consists of the following members:
L. G. Henry, Acting Director M. A. Pierro, Radiation Protection Manager P. M. Orlosky, Operations Manager No violations were identifie . Reviews and Audits Reviews
- The Operating Committee and, to a limited extent, the Nuclear Safety
! Committee (NSC) are required by Technical Specifications to review and approve all experiments to be performed in the reactor, all operating procedures, and all reactor modifications. The extent of the involvement of the NSC in the foregoing matters depends upon the judgment of the Operating Committee, since this committee refers unusual experiments and reactor modifications to the NSC for review and approval.
i Examination of the meeting minutes and discussions with the licensee j disclosed that the NSC has not functioned since September 1981, which
.
has resulted in the following violation . .
,
Technical Specification N.I.e. requires that the NSC review the overall safety of operations of the' facility. Technical Speci-fication 0.2.a. requires that the NSC meet at the request of the Operating Committee or at least two times a year at approximately six-month intervals. The NSC has not reviewed the overall safety of operations of the facility and has not met since September 9, 198 This is a violation (83-01-02).
The Charter and Bylaws of the NSC were changed in December 197 The new Bylaws removed the requirement for the NSC to review NSTF operating procedures except for Operating Procedure No. 41, Experi-ments. According to the new Bylaws, Operating Procedure No. 41 is part of the Bylaws; therefore, any modifications of this procedure shall be subject to NSC review and approval. Operating Procedure N was revised in January 1982, and the Operating Committee reviewed and approved it. However, the Nuclear Safety Committee did not review and approve the revised Operating Procedure No. 41. This is a violation (83-01-03).
The Technical Specifications do not require the Operating Committee to meet at a specified time interval. The minutes for Operating
.
Committee meetings showed the Committee last formally met on January 5, 1982. Also, the last " quarterly walk-through" by the Operating Committee was also performed during January 1982. The inspector noted that reinstitution of these walk-through inspections,.with special attention to housekeeping, would be beneficia Audits
'
Dr. S. H. Levine, Director of The Pennsylvania State University Breazeale Reactor, arranged to trade audits of facilities with M P. M. Orlosky, Operations Manager of the NSTF. The audit of the NSTF was performed on June 28 - 29, 1982. Dr. Levine made five recommendations in the report to the Operations Manager. Although the actions taken concerning these recommendations were not docu-mented, the Operations Manager indicated that the items were consid-ered and appropriate actions take . Surveillance Activities The performance of the following surveillance requirements was reviewe Tech Spe Description Frequency Time Period
! 0. Test all instrument channels Quarterly 3/80 - 12/82 specified in Section H for proper trip point and calibration.
l l
l
'
__
.. - .. ..
. .
i6
.
" "
-
Primary coolant flow rate
-
Temperature of bulk pool
" "
water (Ty )
r
-
Temperature of water above
" "
core (T3 )
-
Differential Temperature
" "
Across Core
-
Temperature of primary
coolant entering heat exchanger (T3 ) " "
,
-
Temperature of primary coolant leaving heat exchanger (T ) " "
-
Temperature of secondary
'
coolant entering heat exchanger (TS ) " "
! -
Temperature of secondary coolant leaving heat exchanger (T6 ) " "
-
Resistivity of primary water leaving cleanup
,
demineralizer " "
0. Check area radiation monitors monthly 1/82 - 1/83 and effluent monitors /or operability and set point
!
" "
-
Hot cell interior
" "
-
Bridge i
l
-
Gross Activity of Reactor
" "
l Building Exhaust
-
Gaseous radioactivity in
" "
( Stack Exhaust l
l
-
Particulate radioactivity I in stack exhaust " "
l
'
According to the licensee, quarterly tests of instrument channels are performed us',g Operating Procedure (0P) No. 77, Quarterly Instrument Check, dated 'ebruary 1977 which requires the following for primary and secondary cooling waters:
<
l (
- . . , . - . - - . _ - - . - - - _ . - . _ . --- - - - . .
. .
-
checking the trip point of the demineralizer inlet water temperature switch;
-
checking the trip point of the core outlet water temperature switch;
-
testing the trip point of the bulk pool water temperature scram; and
-
calibrating the core differential temperature in accordance with Operating Procedure No. 7 Calibration of the core differential temperature includes the calibration of the resistance elements measuring the temperatures of the bulk pool water and water above the core (T 3
), the core outlet water (T2 ), the heat exchanger inlet water (T3 ), and heat exchanger outlet water (T4 ). How-ever, the resistance elements measuring the temperatures of the second-ary coolant entering and leaving the heat exchanger are not calibrated on a quarterly basi Examination of the Maintenance Log showed that these resistance elements were calibrated three times during the 12 quarters of 1980 through 198 Operating Procedure (0P) No. 77 calls for checking the trip point of the annunciator associated with the instrument measuring the resistivity of primary water leaving the cleanup demineralizer. However, the calibration of the measuring instrument is not being performed, nor does OP 77 require its calibration as specified in Technical Specification 0. The licensee's failure to perform quarterly calibration of the instruments measuring the temperatures of the secondary coolant water entering and leaving the heat exchanger and the resistivity of the primary coolant leaving the cleanup demineralizer is a violation (83-01-04).
8. Experiments Operating Procedure No. 41, Experiments, dated January 1982, details the method for requesting irradiation using the reactor, supplying all perti-nent information concerning the material to be irradiated, reviewing the request and information, and approving of the performance of the experiment using the reactor. The Operating Committee members review the request and pertinent information supplied on a " Service Request and Experiment Safety Analysis" form. Any comments and/or limitations concern-ing the experiment are listed on the for If the requested experiment involves unusual circumstances, the Operating Committee requests review and approval of the experiment by the Nuclear Safety Committee. As was pointed out in Section 6 of this report, the Nuclear Safety Committee has had no involvement with operation of the reactor since September 198 The inspector examined three completed " Service Request and Experiment Safety Analysis" forms. One of these forms appeared to have conflicting statements. The first statement was that the experiment could not exceed
._
. .
Technical Specification Reactivity limits. The second statement was that the estimated reactivity worth of the experiment was 0.0067 AK/K. The point of conflict involves Technical Specification 0.3.b(2), Limita-tions on Experiments, which states, "The absolute value of reactivity worth of any sample to be inserted or withdrawn while control rods are not fully inserted shall not exceed 0.003 AK/K." Therefore, if the experiment was inserted without having the control rods fully inserted, the reac-tivity limit given in Technical Specification 0.3.b.(2) not only could, but would, be exceede .
During the foregoing discussion, the licensee pointed out that they insert experiments with reactivity worth greater than 0.003 AK/K while the control rods are 30 percent withdrawn. Further, the licensee pointed out that they had declared this practice to the NRC in their April 3,1981, license renewal applicatio In this application, the licensee proposed Technical Specification 3.1.d. as follows: "The reactor shall be sub-critical by at least 3% AK/K during fuel manipulation or experiments manipulations involving activities greater than 0.3% AK/K." In their justification for this Technical Specification, the licensee included the following statements, "Past practice has been to load fuel and experiments with the rods at 30% withdrawn. For most loadings, this provides consider-ably more margin than 3%."
It is pertinent to the foregoing situation that Technical Specifications for non power reactors often call for control rods to be partially with-drawn while experiments are being inserted to provide the reactivity control afforded by the insertion of the control rod Considering this fact and the fact that the licensee has declared this practice to the NRC and has requested a new Technical Specification allowing the practice, this situation will be considered as unresolved pending Licensing approval of Technical Specification 3.1.d. (83-01-05).
No violations were identifie . Logs and Records
!
'
The inspector reviewed Reactor Log Books Nos. 70, 71, and 72 for the period from May 21, 1982, through February 14, 1983. The Log Books i contained pertinent reactor data such as power level, time of operation,
! -coolant temperatures, and experiments in the reactor. The Log Books also-contained a special section in which scrams were listed with causes and actions taken. Pertinent maintenance information was also recorded in the Log Books.
[ The inspector reviewed the Reactor Maintenance Log for 1978 through 1982. This log had very terse statements on maintenance performed. The
- replacement of the primary piping performed in 1978 was not reported in j the Maintenance Log. This information was recorded in the Reactor Log
'
Boo .
__
, .
No violations were identifie . Procedures Besides the review of Operating Procedure No. 41, Experiments; Operating
. Procedure No. 77, Quarterly Instrument Check; and Operating Procedure N , Reactor Power Calibration, previously discussed, the inspector also reviewed Operating Procedure No. 49, Use of Isotope Production Facili-ties, dated January 1982. After review of this procedure, the inspector observed the removal of the irradiated material from the pool, the carry-ing of the material to the fume hood on the gamma level, and the opening of the can holding the material in the fume hood behind shielding. The chemical technicians _used tongs and a long handled holder to provide distance between themselves and the irradiated material. The chemical technician called, " Hot Sample" as he transported the sample to warn people not to approach the irradiated material. The workers performed their tasks rapidly to avoid exposure. The work was performed in accordance
.
with the procedur A review of the latest revision date of procedures disclosed procedures dated in 1977. According to the licensee, procedures are reviewed annually. The inspector suggested that a means to document this review be considere No violations were identifie . Operator Requalification Training The licensee uses the "Pulstar Reactor (R-77) Requalification Program for Licensed Reactor Operators and Licensed Senior Reactor Operators," Revi-sion 5, dated March 12, 1975, which was approved by the NRC Operator Licensing Branch.
- The requalification training program consists of lectures and self-study, an annual examination, observation of operator performance, and provision of information to the operator The topics of the lectures, study, and examinations are:
-
Theory and principles of operation;
-
General and specific plant operating characteristics;
-
Plant instrumentation and control systems;
-
Plant design features and mechanical systems;
-
Normal, abnormal and emergency operating procedures;
-
Radiation control and safety;
, .
-
Technical specific and safety analysis;
-
Applicable portions of Title 10, Chapter 1, CFR;
-
Facility security and requalification program The Operations Manager administers the progra He assigns the responsi-bility for giving the lectures and preparing the questions to the licensed operator Each of the foregoing topics is assigned to a different opera-tor. The Radiation Protection Department provides the lecture and exam-ination questions for the radiation control and safety portion. The assignments are rotated from year to yea The lectures are given during a two-day period entirely devoted to the training effort. Attendance at the lectures was documente The inspector reviewed the 1980, 1981, and 1982 examinations, which were given to both the senior reactor operators and the reactor operator The questions were sufficiently comprehensive to adequately test the licensed operators. The inspector asked about the practice of giving the same examination to both groups of operators. The licensee stated that the grading of the examinations for the senior reactor operators was more rigorous. The records showed that operators passed the examination When an operator scored less than 80 percent in a specific topic, the operator restudied the topic and was given an oral exa The licensee also had records of the personnel performing reactor startups in compliance with the requirements given in Appendix A to 10 CFR Part 5 The 1981 and 1982 records had completed forms showing that there was an observation of each operator's performanc In order to inform operators of any changes in the license, procedures, or equipment, a memorandum was sent to each operator giving the pertinent information. The inspector reviewed nine of these memoranda. The informa-tion was appropriate. As previously mentioned in Section 2 of this report, the licensee indicated they would post a copy of each memorandum, upon issuance, for the operators to sign as verification of their review of tne information.
i No violations were identifie . Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on February 17, 1983. The inspec-tor presented the scope and findings of the inspection, including:
-
The violation concerning the failure of the NSC to review the overall safety of operation of the NSTF and to meet at least semi-annually since September 1981 (paragraph 6.a.);
g
. .
12
-
The violation concerning the failure of the NSC to review and approve the revised Operating Procedure No. 41 in January 1982 (paragraph 6.a.);
-
The violation concerning the failure to calibrate secondary water temperature measuring instruments and the primary water resistivity measuring instrument on a quarterly frequency (paragraph 7.);
-
The deviation concerning the failure to document the instruction of the security force in radiation protection and to reinstruct the security force on an annual basis as committed in a September 24, 1979, letter to Region I (paragraph 2.); and
-
The unresolved item concerning the insertion of exoeriment; with reactivity worth greater than 0.003 AK/K into the reactor with the control rods 30% withdrawn rather than fully inserted (paragraph 8.).
.