IR 05000062/1985001

Insp Rept 50-062/85-01 on 850722-26.Violation & Deviation Noted:Failure to Establish & Adhere to Radiation Control Procedures & Failure to Replace Survey Instrument W/Audible Rate Indicating Survey Meter

ML20134J625
Person / Time
Site:	University of Virginia
Issue date:	08/07/1985
From:	Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134J569	List: IR 05000062/1985001 ML20134J566 ML20134J591 ML20134J602
References
50-062-85-01, 50-62-85-1, NUDOCS 8508290428
Download: ML20134J625 (8)

Text

F- ~

.

,

,,.

>

.

• . -

ma Moti UNITED STATES

.f NUCLEAR RE!ULAT!RY COMMISSION

-[ o,$ REGION li g j ,

101 MARIETTA STREET, * * ATLANTA, GEORGI A 30323

^*%*****/ AU6131985 Report No.: 50-62/85-01 (University of VA Reactor)

Licensee: Univer.sity of Virginia Charlottesville, VA 22901 Docket No.: 50-62 (University of VA Reactor) License Nos.: R-66 Facility Name: University of Virginia Inspection Conducted: July 22-26, 1985 Inspector: /h 'TLui k7[J T B. K. Revsfp j ~

Date Signed Approved by: bT I w^~ \ 8/~)[f b

'C.M.Hosey', Sectio) Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection entailed 19 inspector-hours onsite

.in the areas of radiation control, environmental protection, transportation and follow-up of licensee action on previous enforcement matter Re sul ts : One violation was identified - Failure to establish and adhere to radiation control procedure A deviation from a commitment to the NRC to replace a survey instrument with an audible rate indicating survey meter was

'

identifie .

8508290428 850813 PDR ADOCK 05000062 G PDR .

m

.

.

. .

REPORT DETAILS 1. - Persons Contacted Licensee Employees R. U. Mulder, Director, Reactor Facility B. Copcutt, Radiation Safety Officer R. Allen, Chairman, Radiation Safety Committee J. ' E. Henderson, Reactor Health Physicist J. P. Farrar, Reactor Supervisor P. E.'Benneche, Senior Reactoe Operator /Research Engineer J. R. Gilchrist, Radiation Safety Specialist A. A. Turley, Health Physics Technician Exit Interview The inspection scope and findings were summarized on July 24, 1985, with those persons indicated in paragraph 1 above. An apparent violation for failure to establish and adhere to radiation control procedures

~(paragraph 4.b) and an unresolved item * (URI) concerning calibration of instrumentation used to perform surveys (paragraph 4.g) were discussed in detail. The inspector' described the areas inspected and discussed in detail the inspection finding Licensee management acknowledged the inspection findings, taking exception only with the URI to which the licensee expressed the opinion that their instrument calibration techniques were consistent with applicable codes and standard The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors

,

during this inspectio Licensee management was notified in a telephone conversation on July 26, 1985, between D. M. Collins of the NRC Region II staff and R. U. Mulder, Director of the University of Virginia Reactor Facility that the URI would be considered closed. The licensee was also informed that their calibration practices were contrary to accepted industry practices and did not encompass

, the parameters described by ANSI N323-197 During the above conversation the licensee was informed that failure to fulfill their commitment in response to Violation 50-62/84-01-01

'

(paragraphs 3 and 4.a) would be considered a deviation from a written commitment made to the NR *An Unresolved Item is a matter about which more information is required to

-

determine whether it is acceptable or may involve a violation or deviation.

l f

!

r

.

. . .

3 .

t

' Licensee Action on Previous Enforcement Matters (Closed) Violation 84-01-01 Radiation survey The inspector reviewed the licensee's response dated February 20, 1985, and verified that the corrective action specified in the response had been taken with the-exception of replacing the previous survey meter with an audible rate indicating survey meter. This will be considered a deviation from a written commitment to the NRC (paragraph.4.a).

(Closed) Violation 84-01-02 Placarding ' yellow label III shipments. The inspector reviewed the licensee's response dated February 20, 1985, and verified that the corrective action specified had been implemente (Closed) Violation 84-01-03 Adherence to procedures. The inspector reviewed the licensee's response dated February 20, 1985, and verified that the corrective actions had been implemente (Closed) Violation 84-01-04 Posting of radioactive material areas. The inspector reviewed the licensee's response dated Feburary 20, 1985, and verified that the corrective actions had been implemente (Closed) Deviation 84-01-05 Maintenance of records. The inspector reviewed the licensee's response dated February 20, 1985, and verified that the corrective actions had been implemente . Radiation Control (83743) CFR 20.201(b) required that the licensee perform such surveys as may be necessary and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen The inspector reviewed the following records of licensee surveys for the periods indicated:

Daily Contamination Survey, January 1 through June 30, 1985 Weekly Contamination and Radiation Survey, January 1 through June 30, 1985 The inspector accompanied the facility health physics (HP) technician on. a weekly rautation and contamination survey. The inspector performed independent radiation surveys and compared readings using NRC equipment with readings obtained by the license No significant difference between the licensee and the inspector results were note The licensee had committed in a letter to Region II on February 20,

-1985, in response to Notice of Violation issued with Inspection Report 50-62/85-01 that an audible rate indicating survey meter would be purchased to replace the original instrument used for performing surveys. Examination of survey records revealed that the original survey instrument was still in us Although an audible rate i

.J

r

.,

. . .

indicating meter had been purchased, it had not be placed in servic Conversation with licensee representatives revealed that the audible rate instrument had been found difficult to use and its suitability for performing surveys questioned. Consequently, the instrument had never been put into use. The licensee committed to the inspector to have the audible rate instrument operational and in use by September 1, 198 In a telephone conversation (paragraph 2) the licensee was informed that failure to use the audible rate indicating survey meter would be considered a deviation from a written commitment to the NRC (50-62/85-01-01).

No violations or deviations were identifie b. Technical Specification 6.3 required that radiation control procedures be maintaine (1) University of Virginia Reactor (UVAR) Standard Operating Procedure (50P), " Radiation Control Procedure," paragraph 10.4.B.3 stated that due to the possibility of the spread of contamination, the uncontrolled areas in the UVAR Room shall be surveyed daily by the Reactor Health Physicist or his designee to determine the contamination and exposure levels presen The inspector was informed by the Reactor Health Physicist that while daily contamination surveys had been performed as required, daily radiation surveys to determine exposure levels had not been performed. A review of survey records from January to June 30, 1985, confirmed the Reactor Health Physicist's statement. Failure to perform radiation surveys in the uncontrolled areas of the UVAR

'

Room was identified as an apparent violation of Technical Specification 6.3. (50-62/85-01-02).

(2) On a toun of the facility, the inspector observed that a portion of the UVAR Room was maintained as a contamination controlled area. The method used to evaluate the release of materials and personnel from the controlled UVAR Room was discussed with licensee representative The licensee informed the inspector that the Reactor Facility informally endorsed the release criteria elaborated by the Radiation Safety Guide, 1971, a manual promulgated by the University Radiation Safety Committe The Reactor Facility is exempt from the requirements of this guid The inspector observed the monitoring equipment used for release of material and personnel from the UVAR Room and informed licensee representatives that detection of personnel release values stated in the Radiation Safety Guide would not be probable, i.e., the personnelfrisker at the exit point would not ce capable of detecting 500 disintegrations per minute (dpm) in a general background of approximately 1000 counts per minute (cpm) for the frisker. The

,

~

. .

. . . . .

5-inspector. stated that present SOPS .had not addressed criteria for

. release of material and equipment from controlled areas and that failure to establish a procedure for the release of material and personnel from the controlled area would.-bo . considered a second example of. an apparent violation of Technical Specification (50-62/85-01-02).

(3)~ UVAR -(SP) S0P 10.5.A.1 dealing with radioactive wr. ate required that each area in the Facility in which radioactive wastes are routinely generated shall have a dry waste cor.cainer which shall be conspicuously marked as " Radioactive Wasce" 'and shall have an attached report form on which depositione above minimum levels (as specified on the form) are recorde On tours of the UVAR Room, the inspector noted that three of four waste containers did not have an attached report form. Failure to attach a form for recording the deposition of material on the waste containers as required by SOP 10.5.A.1 was identified as a third example of an apparent violation of Technical Specification 6.3 (50-62/85-01-02).

c. 10 CFR 20.202 required that appropriate personnel monitoring devices be worn by personnel likely to receive exposures in excess of 25 percent of the limits specified in 10 CFR 20.101 or who enter a high radiation are During tours of the facility, the inspector observed personnel monitoring devices being wor No violations.or. deviations were identified, d. 10 CFR 20.101 stated the quarterly radiation exposure limits to the whole body, skin of the whole body and extremitie '

The inspector verified by examination of selected exposure records from Jar.ua ry 1 to May 31, ,1985, and through discussion's with licensee representatives that exposures were being maintained below applicable

~

limit For 1984, the highest whole body exposure was 420 mrem and for ,

1985, the highest whole body exposure through the month of May was 300 mre {

No violations or deviations were identifie e. 10 CFR 19.12 requires that each employee who works in or frequents the licensee restricted area be given instruction in radiation protection commensu ste with their duties and potential hazar The inspector reviewed the radiation worker course outline and lesson plan, Selected records of personnel training were also reviewed.

[ No violations or deviations were identified.

i m

_

_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ -

'

. .' *

.

f. 10 CFR 20.203 stated the requirements for posting radiation areas, high radiation areas and radioactive materials are During tours of , the facility, the inspector noted the posting of radiological areas and material and verified by independent survey that such areas were adequately poste No violations or deviations were identifie g. UVAR (SP) S0P 10.6.A stated that portable radiatior, monitoring instruments required for reactor operations and surveys at the facility shall be calibrated by the Reactor Health Physicist or his designee at least quarterly or whenever maintenance is performed on the instrumen The licensee informed the inspector that portable instruments were calibrated against a National Bureau of Standards traceable 104 mci Cs-137 source. When calibration was due, the instrument was brought to the Health Physics laboratory and exposed tc the source at four or five points on each scale of the instrument. The instrument was considered calibrated if the reading, when exposed to the source, had an error factor no greater than 220 percent of the full scale reading. The inspector stated that such a wide acceptance range was not consistent with the recommendation of ANSI N323-1978, " Radiation Protection Instrumentation Test and Calibration" which specified that instrument readings shall be within 10 percent of known radiation values or that

,

i 120% of the known radiation value shall be acceptable if a calibration chart or graph is prepared and made available with the instrument. The inspector stated to the licensee that such a practice constituted an instrument source check rather than a calibratio A licensee representative stated that when an instrument was found to ve out of calibration on one scale, rather than perform internal

'

adjustments to bring the instrument 'uack into calibration on that scale, the instrument was affixed with a sticker limiting its use on that scale. In examining calibration records for two Keithley Model 36100 ionization chambers, and observing the of the two instruments themselves, it was noted that neither instrument had been calibrated for use on the highest (20 R/hr) scale, that the middle scale (2 R/hr)

for both instruments exceeded a 20 percent error from known radiation values, while only the lowest (200 mR/hr) scale exhibited a less than a 20 percent error for all values tested on that scal Radiation survey records examined by the inspector showed that all surveys performed by - these instruments had been on the 200 mR/hr scale and consequently, it would appear that these instruments were adequately calibrated for performing low level radiation survey At the exit interview the instrument calibration issue was left as an i

URI pending further study by the NRC technical staf No violations or deviations were identifie _ _ _ _ _ _ _ _ _ _ _ - - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _

.

"

.

-

.'. .

-

f h Transportation (86740)

. CFR 71.5 required that each licensee who transports licensed

"

material outside of the confines of its plant or other place of use shall comply with the applicable requirements of the regulations of DOT

in 49 CFR, Parts 170 through 18 '

The inspector reviewed the waste manifests for shipment #51872, May 26, 1985, and shipment #51872, June 27,1985. The material shipped was low specific activity waste and was transferred in a university owned vehicle to a control area on the campus for transfer to a disposal site by a private contractor. It was determined thtt the contractor did not 2 repackage waste received from the reactor facilit For these intra-universiti shipments, copies of a shipping manifest form had been reproduced and was being used by the reactor facility. Although, the required information was present on the manifests, the inspector noted that the shipping number was not unique for each shipmen CFR 20.3011(d) required that any waste generating licensee who

!

transfers radioactive was'te to a land disposal facility or a licensed waste collector shall comply with requirements concerning waste classification according to le CFR 61.55 and waste and characterization according to 10 CFR 61.5 The inspector . reviewed the two waste shipments described in paragraph l 5.a for classification and characterization compliance and determined that the appropriate information had been obtained and presented on the shipping manifest. It was also determined that the licensee shipped only class A wast CFR 20.311(d)(3) required the licensee to conduct a quality control program to assure compliance with 10 CFR 61.55 and 61.56 and that this program must include managsment evaluation of audit The inspector determined that at least once per calendar year, the

'

University Radiation Safety Officer or other member of the University Radiation Safety Committee performs an audit of the university waste management program. The December 7, 1984, audit report was reviewed by the inspecto No violations or deviations were identifie . Environmental Protection (80745)

Technical Specification 3.4.2 required that the activity of liquids released beyond the site boundary shall not exceed 10 CFR 20 limit For the months of January - March,1985 and for June 1985, the inspector reviewed the holding pond monthly sampling and analysis program and verified that samples required by UVAR S0P 10.5.B.2 had been obtained and processed as required and that the average activity of three pre-release pond samples

, . , . . . .. ..

. .. - _ _ _ _ _ _ _ _ . . _ _ _ _ _ - -- - - - - - - - - - - - - . - . - - - -

.

_ , _ _ . _ _ _ _ - _ _ -

- ,

e

' *

p

• ,,, ,,

.

-

, .

.

'

d'id not exceed specified limits. for additional analyses. Records for holding tank and pond releases for the first quarter of -1985 were reviewed and found to contain all the data required by S0P 10.5. No violations 'o: deviations were identifie . .

t

e J

,

'

L- - .g-

-

- .. , ...... . . . . , - .

. ,

, . , ,