IR 05000057/1990003

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Insp Rept 50-057/90-03 on 901022-25 & 1108.No Violations Noted.Major Areas Inspected:Status of Licensee Plans & Activities Re Repair & Mod of Reactor Tank
ML20058K402
Person / Time
Site: University of Buffalo
Issue date: 12/05/1990
From: Austin M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058K393 List:
References
50-057-90-03, 50-57-90-3, NUDOCS 9012170211
Download: ML20058K402 (8)


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U. S. NUCLEAR REGULATORY. COMMISSION

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REGION I

Report No.

50-57/90-03 Docket'No.

50-57 License No. R-77 Category

Licensea: State University of New York at Buffalo Rotary Road, South Campus Buffalo, New York 14260 Facility Name:

Buffalo Materials Researen Center

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Inspection At:

Buffalo, New York Inspection Conducted: October 22-25'and November 8, 1990 Inspector:

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k. A. Austin, Radiation SpeE:ialist,

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Ef fluents Radiation Protection Section, Facilities Radiological Safety and Safeguards Branch, Divisi n of Radiation Safety and Safeguards l

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Approyed by:

12. Ip.7/9@

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R..J. Bo Ws, Chief, date Effluents Radiation Protection Section.

I Facilities Radiological Safety

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and Safeguards Branch, Division of Radiation Safety and Safeguards p

Inspection Summary:

Inspection Conducted on October 22-25 and November 8, 1990 Areas Inspected:

Special inspection by one region-based inspector to review the status of the licensee's plans and activities pertaining..to the repair and modification of the reactor tank.

Results: No violations were identified..The. licensee was effectively using outside consultants to plan the reactor tank repair activities, The lack of.

qualified individuals in key positions was' identified as' a concern that could l

become more significant after repairs were completed and restart of the reactor was being considered'(Section 2.0),

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9012170211 901209

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DETAILS 1.0 Individuals Contacted

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    • L. Henry, General Manager, Buf falo Material Research Center (BMRC) ~
  • M. Adams, Acting Operations Manager, BMRC
  • J. Slawson, Acting Senior Health Physicist, BMRC D. Sullivan, Reactor Engineer, BMRC R. Jones, Reactor Operator A. Bloomquist, H.alth Physics Technician
    • D Dooley, Consultant
  • C Thomas, Consultant
  • Denotes those present at the October 25 exit. interview.

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    • Denotes those present at both the October 25 and= November 8 exit interviews.

The inspector also. interviewed other ' licensee employees during the inspection.

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2.0 Organization

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q The inspector interviewed the General Manager ofithe Buffalo Materials.

Research Center (BMRC), who has over fif teen years of operating' experience; at the facility, to determine.the current status of staffing ~within the licensee's organization. The inspector was informed that the; individual

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who had been assigned to=be the Director of BMRC had returned to his:

previous position as Reactor Engineer, and this individual had recently announced his intention to resign from BMRC by the end-of calendar year

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1990. Also, the Operations Manager, an individual-with over thirty years.

experience at BMRC, had resigned about.one month prior to-the current inspection.

The inspector also noted that the; individual.in'the position of Senior Health Physicist had resigned.in February 1990.

The inspector determined that currently no individuals'had been identified

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as permanent replacements to fill the vacated positions of Director,and Senior Health Physicist.

The inspector observed'that individuals with

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apparently limited knowledge and/or experience were-being utilized in an l

acting capacity.

The General Manager indicated.that an effort was underway to recruit a qualified health physicist and a' reactor engineer for these positions.

The inspector noted that BMRC was currently utilizing consultants', under the direct supervision of the General Manager of BMRC, to assist in'the.

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planning and preparation for the upcoming outage activities relating to

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reactor tank repairs.

The inspector encouraged the continued use'.of-

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consultants during the outage repairs.

The inspector stated -that the' lack of qualified individuals who were permanently assignedito key positions

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could become a more significant concern after the repairs were completed and restart'of routine reacto.r operations ~ began.

The General' Manager acknowledged the inspector's comments and reiterated his intention to -

recruit the personnel necessary to appropriately staff the BMRC organizatio r

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3.0 Operations The inspector toured the facility to observe the current stati.s of licensee activities in preparation for the outage repairs to the reactor-tank.

The licenst was in the process of draining.the reactor tank to the shelf level above the core. The inspector reviewed a " Pool Drainage Authorization" that was issued by the Operations supervisor to document and control the drainage based on either a total allowable decrease-in tank water level or a maximum allowable millirem / hour level.

The inspector observed that.the drainage rate and the~ radiation dose rate.in the reactor tank were constantly monitored by the shift Reactor. Operator.-

When the reactor tank was drained to'a level just below the shelf level, the licensee planned to remove certain equipment (e.g., fuel racks, beam tubes, etc.) that were still underwater..Following this underwater equipment removal, the remainder of the tank was planned to be drained, and the remaining equipment would be removed-using cutting torches'or grinding tools, as necessary. After all the equipment in the tank was removed and the ',ank drained, the licensee planned to weld the crack that

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had caused the leak. The-tank bottom and walls below the shelf level will then be lined with aluminum plate.

The dismantlement and' removal of..

equipment within the reactor tank and the repairs to the tank were planned to be done by a combination of BMRC and outside contractor personnel, depending upon which special-skills (e.g., welding) were required.

While the licensee was planning the details of the upcoming repairs-and modifications to the reactor tank, the inspector observed that adequete management controls were being implemented to assure safe drainage of the reactor tank water. No deviations or violations were identified.

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4.0 Re_spiratory Protection (RP) Program

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The inspector reviewed the licensee's newly developed Respiratory Protection Program to determine how it was being implemented for the i

outage repair ac*'vities.

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l 4.1 Program Manual The: inspector reviewed the BMRC RP Program Manual during an interview with the acting Senior. Health Physicist.(SHP).

The acting SHP was the principal author of the Program Manual and was the coordinator of-the Program implementation. 'The inspector determined:that the.

Program Manual met the minimum NRC requirements for an acceptable RP program in compitance with 10 CFR 20.103(c)(2)&(3),

The final draft of this Program Manual had been completed just a few weeks' prior to the current-inspection, and the inspector reviewed a letter: from the

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BMRC to the NRC Document Control Desk, dated October 8, 1990, which notified the NRC of the licensee's intention to-use respiratory-protective equipment under the provisions of 10 CFR 20.103.

Based upon a review of records and discussions with the acting SHP and General Manager of BMRC, the inspector determined that, prior._to establishing this_ formal RP program, the licensee had mainly used respiratory protective equipment for Hot-Cell entries. During these Hot Cell entries, the licensee had used respiratory protective equipment as a precaution to keep personnel exposures _ as -low as reasonably achievable (ALARA), and no-credit had been_taken.for'the protection factor provided by the equipment'being worn by the worker.

All Hot Cell entries had been done under the conditions'of a Radiation Work Permit (RWP).

The inspector reviewed some of the most recent RWps for Hot Cell entries, which were done in_' August-1989.

The licensee had taken surveys for removable contamination

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for these Hot Cell entries, and the results indicated that airborne contamination due to resuspension of loose surface contamir.ation should not be a concern.

However,'the licensee had not collected-any air samples during these' Hot Cell entries to confirm-that airborne radioactivity levels we" not a concern.

The inspector suggested that continuous, repre>entative air. samples be collected during future Hot Cell entries to confirm that respiratory-protection is being used only for ALARA purposes and is not being used to ensure compliance with 10 CFR 20.103(b)(2).-

The acting SHP acknowledged the inspector's comment and committed'to collect air samples in future Hot Cell entries for this purpose.

No violations or deviations were identified.

4.2 Records The inspector was informed that the Director of Health Services, who was a medical doctor, performed the physical examinations.of the BMRC employees in the licensee's respiratory protection program.

The inspector examined reports maintained by the acting SHP, which documented the physician's determination that selected individuals were able to use respiratory protective equipment.

The inspector examined records of baseline in-vivo body counts of'

BMRC employees involved in the respiratory protection program.

The acting SHP stated that in-vivo body counting was the primary bioassay measurement technique planned to be used, and that baseline and post-outage in-vivo coun'.; were planned for all individuals using respirators during the outage repair activities.

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The inspector reviewed a written form RPP-1 developed by the licensee that is used for each individual-in.the respiratory protection program. This form consolidates the completion dates for medical examinations, training, respirator fit testing and in-vivo counts into one document. 'The inspector observed-that the licensee used this form as an effective administrative control to assure.each individual had satisfied all the various requirements of.

the respiratory protection program.

No vioh tions or deviations were identified.

4.3 Training On October 22, 1990, the inspector attended a portion of the BMRC.

Operator and Health Physics Requalification Training sessions, which included a segment on the Respiratory Protection Program. The inspector ot,aerved that the training for use of respiratory protection equipment in emergency conditions was complete and'well done, however, the use of respiratory protection equipment for extended periods during planned, non-routine operations was given relatively less time at the end of the session.

Because the upcoming reactor tank repairs would require such planned, extended use of respiratory protection, the. inspector questioned.why more-attention had not been given to this activity.

The General Manager stated that this annual retraining on the use of respiratory.

j protection would be supplemented by more job-specific training before the reactor tank repair activities began.

4.4 Use of protection Factors The inspector observed that three of the Reactor Operators (R0s),

who were receiving the training-in use of respiratory protection equipment, had beards.

The training session attc @ d by the inspector only addressed the use and handling of full-face ma:,ks.

l The inspector noted that the Protection Factor./PF) given in i

Appendix A of 10 CFR 20 for any-particular resp rator is applicable to only shaven faces where'nothing interferes vith.the seal of

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tightfitting facepieces against the skin; hoods and suits are l

excepted, The inspector was informed that if any of the bearded R0s used respiratory protection equipment for the reactor tank repairs, they would~use hoods or suits, and the use of this equipment would be covered in the above-mentioned job-specific training before the repairs began.

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4.5 Contractor Participation

The inspector stated that all contractor personnel. employed by.the licensee and using-respiratory protection during the planned outage l

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repair activities would be subject to the respiratory protection program requirements in 10 CFR 20.103.

The inspector stated that proper documentation was required to document that'such outside

contractor personnel had satisfied all minimum requirements,'such as i

medical examinations and training, before they used respiratory protection to perform.the outage repairs.- The General Manager

acknowledged the inspector's comments and stated that a two-day training session was planned for all contractor personnel, which t

would include training in the use of respiratory protective equipment.

5.0 Radiological Controls The inspector reviewed selected elements of the licensee's radiological control program to determine how it would be inplemented during the outage repair activities.

5.1 Procedures The inspector reviewed Draft #5 of Health Physics Procedure (HPP):

  1. 15, dated 10/90, entitled " Reactor Tank Entry".

The inspector was:

informed that HPP #15 was patterned after.an established procedure'

for Hot Cell entrie.. The HPP #15 draft reviewed by the inspector appeared to address most of-the radiological controls,'however, the inspector stated that the optional, five-minute high-volume " grab" air sample described in the procedure was not adequate.

The-inspector stated that, in compliance with 10 CFR 20.103(a)(3), the licensee must "use suitable measurements of concentrations of.

.l radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas".

Because.the licensee planned.

to employ individuals using respirators in potentially high airborne radioactivity conditions for extended time periods (e.g.', hours),

the proposed " grab" sample was not considered " suitable".

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in:pector stated some type of continuous and more representative air sampling would be required during these repair activities inside the'

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The licensee representatives acknowledged this and stated.the

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procedure vould be revised to reflect a more appropriate air sampling method.

5.2 Exposure Control and Monitoring The licensee planned to use grinding, cutting or welding equipment,.

as appropriate, to remove equipment from the reactor. tank after all the water was drained and the tank.was dry.

The inspector noted that this planned activity had~the potential ~to create elevated-levels of airborne-contamination surrou'nding the workers at the.

bottom of the reactor tank.

The inspector' asked what additional-ventilation, if any, would be used during this phase of th.e

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. equipment removal.

The licensee replied that. equipment was in place-

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that would allow a flexible duct to be lowered into the reactor tank.

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to provide localized ventilation and reduce airborne radioactivity

levels in the area surrounding the worker._ The licensee planned to-use this temporary ventilation system, as necessary, when equipment was being removed from the dry reactor tank.-

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The inspector reviewed the licensee's plans for monitoring external I

radiktion levels inside the reactor tank after it was.. dry.= The L

licensee planned to lower an ion chamber,'. wrapped in plastic, L to

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the reactor tank to monitor radiation levels before the first entry.

In addition, workers entering the reactor tank would have a i

plastic-bagged survey rneter for use during their activities.

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licensee planned to. remove any debris from the tank that contributed

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to elevated radiation levels and perform a thorough dose rate survey inside the reactor tank before outside contractor _ personnel made their first entry, i

The inspector examined various forms that the licensee had prepared-and planned to use to document and: track' personnel exposures during the tank repair activities.

The licensee had developed a

"High-Volume Air Sample Screening" form to record the results of

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high-volume baseline and grab samples collected during the work.

The licensee planned to use an " Air Sample Filter Daily Evaluation-

Record" to document the results of low-voiume (20!11ters/ minute) air

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samples that would be collected while work was being performed.

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I licensee planned to use a " Personnel MPC-HR Tracking Log", which

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included an allowance for Protection Factors for respiratory i

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l protection, to document internal exposures; and, a " Daily Dose Tracking Record" would be used to document external exposures.

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inspectur determined that the licensee had established a good

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documentation system to monitor and control personnel exposures i

during the planned reactor tank repair activities.

  • No violations or deviations were identified.

6.0 Status of Previously Identified Items

'.P 6.1 (Closed) Violation (50-57/83-01-02) Failure of the Nuclear Safety Committee (NSC) to meet at least semi-annually; (Closad) Violation (50-57/83-03-01) Failure of the NSC to exist and function properly.

The inspector interviewed the General Manager of BMRC and reviewed t

the documented meeting minutes of the NSC from 19881to the time of.

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The inspector determined that the NSC does currently exist and effectively function,- and that the NSC ut twice j

in 1988, five times in 1989, and three times in 1990, -These itemst are closed.

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'I 6.2 (Closed) Violation (50-57/83-03-02) Fa11ure of the Reactor Radiation, j

Safety Function to report to the Manager of the<Radiat_ ion Protection.

Department.

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.l The inspector reviewed Amendment No. 20lto the licensee's Facility.-

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i Operating License No~. R-77, which,was approved by the NRC in a

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letter, dated August. 19. 1985.

The-inspector confirmed that thisL

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. amendment approved the assignment of the. Reactor. Health Physics j

Department to the Director of BMRC ;and the BMRC staff was currently

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organized in. compliance with this amendment'. !This'1 tem is closed.:

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7.0 Exit Interview

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The inspector met with the licensee personnel: den'oted in Section 1.0 on.

i October 25 and November 8, 1990.

The. scope and findings of the j

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inspection were discussed at that time.

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