IR 05000062/1987002
| ML20215K534 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 06/08/1987 |
| From: | Hosey C, Kuzo G, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215K506 | List: |
| References | |
| 50-062-87-02, 50-62-87-2, NUDOCS 8706250357 | |
| Download: ML20215K534 (8) | |
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UNITED STATES '
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. NUCLEAR REGULATORY COMMISSION.
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REGION 11
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101 M ARIETTA STREET, N.W.'
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ATLANTA, GEORGI A 30323
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JUN 0 81987
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(ReportNo.: '50-62/87-02 Licensee: ! University.;of Virginia Charlottesville, VA 22901
. Docket No.:
50-62 License No.:
R-66
Facility Name:. Pool Reactor
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Inspection Conducted:
ay 26-28, 1987 Inspectdrs:
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B. K. Revsin Date Signed W]m 1/5/77-i 1G. B. Kdzo
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Date. Signed
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Approved by:
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d/T/JT C.,M. Hosey', Sectipn Chief.
Date Signed i
Divisionof.RadiationSafetyandSafeguards
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SUMMARY
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Scope:- This routine, unannounced inspection involved onsite inspection in the
- areas of radiation ' control, environmental protection, transportation of radioactive materials and followup on previous enforcement issues.
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Results: 'No violations or deviations were identified, j
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8706250357 870608 PDR ADOCK 05000062?
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REPORT DETAILS d
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- Persons Contacted Licensee Employees j
'*Tp G.VWilliamson, Chairman, Department of Nuclear. Engineering
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c R. iU. Mulder, Director,. Reactor Facility
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- B. Copeutt,' Radiation Safety _0fficer
- P.- E. Benneche, Reactor Operations Supervisor L*0. Hale,~'. Reactor Health Physicist
- J. 'P. Farrar, Reactor Administrator
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B. Hosticka~, Research Scientist-
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- Attended exit! interview i
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Exit Interview.
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The Linspection scope and ; findings were summarized on May 28, 1987, with lthose; persons indicated in Paragraph 1. above..
One unresolved item *-
concerning-effluent measurements for liquid releases to unrestricted areas (Paragraph 6.c); was discussed'in ' detail.
The licensee' acknowledged the
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-inspection findings and took-no exceptions.
The licensee did.not identify as Jproprietary any of the materials provided to or reviewed' by the.
inspector during this inspection.
3.
Licensee Action on Previous. Enforcement Matters-(Closed) Violation-(50-62/86-01-01) Radiological surveys of representative offices, and - classrooms.
The inspector reviewed the licensee's response-dated September 4,1986, and verified that the corrective action spec.ified'
in the ' response had been implemented.
.(Closed) Violation- (50-62/86-01-02) Use of uncalibrated instruments for radiological surveys.
The inspector reviewed the licensee's response dated September 4,1986, and verified that the corrective action specified'
j in the response had been implemented.
(Closed) Violation (50-62/86-01-03) External radiation and contamination levels.on packages in transport.
The inspector reviewed the licensee's response dated September 4,1986, and verified that the corrective action specified in the response had been implemented.
(Closed) Violation (50-62/86-01-04) Written procedures for activities
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affecting quality in the transportation of licensed material. The t.
- An Unresolved Item is a matter about which more information is required to
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deteriiiine whether it is acceptable or may involve a violation or deviation.
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inspector reviewed the licensee's responses datcd September 4,1986, and October 28, 1986, and verified that the corrective actions specified in the response had been implemented.
4.
Radiation Control (83743)
a.
10 CFR 20.202 requires that appropriate personnel monitoring devices be worn by personnel likely to receive exposures in excess of 25 percent of the limits specified by 10 CFR 20.101 or who enter a high radiation area, and to require the use of such devices.
During tours of the facility, the inspector observed personnel wearing film badges as required.
Tho inspector also verified by examination of selected exposure records for 1986 and 1987, and discussions with personnel, that extremity dosimetry was provided and worn by individuals handling experiments after irradiation.
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No violations or deviations were identified.
b.
10 CFR 20.101 delineates the quarterly radiation expos 4re limits to i
the whole body, skin of the whole body, and the extremities.
i The inspector verified by examination of selected exposure records for 1986 and 1987,.and through discussion with licensee representatives that exposures were being maintained below applicable limits.
For 1986, the highest whole body dose was 160 millirem and through March 31, 1987, the highest whole body dose was 40 millirem.
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No violations or deviations were identified.
c.
10 CFR 20.203 presents the requirements for posting radiation areas, high radiation areas and radioactive materials areas.
During tours of the facility, the inspector noted the posting of the radiological areas and materials and verified by independent measurement that such areas were adequately posted.
The inspector noted that considerable attention had been given to decontamination and general cleaning of the facility. At the time of the inspection, entry into all parts of the reactor room in street clothes was possible.
Additionally, moderately high level waste which had been j
stored onsite since 1983 had been shipped for burial which resulted in a significant lowering of the background radiation level.
No violations or deviations were identified.
d.
10 CFR 20.103(a)(1) states that no licensee shall possess, use or
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transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for t-
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13 weeks at uniform concentrations of radioactive material in air specified in 10 CFR 20, Appendix B. Table 1, Column 1.
Standard Operating Procedure (S0P) 10.4.B.5 specifies that particulate air samples shall be collected in the reactor (UVAR) room
of the facility on a weekly basis.
The inspector examined records of the weekly air samples from January 1 to April 24, 1987, and found that generally, airborne radioactivity in the UVAR room was below the concentration specified in 10 CFR 20, Appendix B, Table 1, Column 1.
S0P 10.4.C states that samples of air shall be collected and analyzed
monthly at predetermined locations outside the facility.
The inspector reviewed selected air sample records between January 1 and May 1, 1987, and found that airborne radioactivity outside the facility approached natural background levels and was a small fraction of the concentration specified in 10 CFR 20, Appendix B,
Table 2, Column 1.
No violations or deviations were identified.
e.
10 CFR 20.201(b) requires the licensee to perform such surveys as may be necessary and are reasonable under the circumst'ances to evaluate the extent of the hazards that may be present.
S0P 10.4 requires performance of (1) weekly contamination and radiation level surveys in working and material storage areas of laboratories, (2) weekly surveys of all controlled areas and adjacent corridors, (3) daily surveys of uncontrolled areas of-the UVAR room and (4) monthly radiation level surveys around the outside of the i
building.
The inspector reviewed the records of the above surveys between January 1 and April 29, 1987.
In general, removable contamination was minimal, i.e., less than 50 counts per minute per 100 square centimeters, and radiation levels were low, i.e., less
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than 0.2 millirem per hour.
No violations or deviations were identified, f.
10 CFR 19.11 requires each licensee to conspicuously post current copies of (1) 10 CFR Parts 19 and 20; (2) the license; (3) operating j
procedures; and (4) Form NRC-3, in sufficient places to permit j
individuals engaged in licensed activity to observe them on the way to and from any licensed activity location.
If posting the documents
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specified in (1), (2), and (3) is not practicable, the licensee may post a notice which describes the document and states where they may be examined.
During tours of the facility, the inspector observed the posting of
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the Form NRC-3 and a notice stating the location of the remainder of the documents. The postings were conspicuous.
No violations or deviations were identified.
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5.
Transportation (86740)
10 CFR 71.5(a) requires that each licensee who transports licensed
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material outside the confines of its plant or other place of use to 9mply with the applicable requirements of the Department of Transportatio.. (DOT)
i in 49 CFR Parts 170 through 189.
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Since the previous inspection, six shipments of radioactive waste had been
made. One shipment was waste which was shipped offsite to a land disposal facility, and the other five shipments were materials irradiated in the i
reactor.
The waste shipment, March 17, 1987, consisted of 24 55-gallon drums containing 853.8 millicuries of activity shipped as Class A
Unstable.
Classification was determined from an isotopic analysis of each
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drum for content of gamma emitting radionuclides.
The inspector reviewed the shipping papers for each of the six shipments.
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No violations or deviations were identified.
6.
Environmental Protection (80745)
a.
Technical Specification '(TS) 3.4 details release limits for
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radioactive effluents released from reactor operations.
The inspector toured the UVAR laboratory facilities, and reviewed and discussed capabilities and quality assurance controls for radiological analytical measurements with respect to effluent releases.
The laboratory area and equipment were clean and l
adequately maintained.
Instrumentation utilized for effluent reasurements included four gamma spectroscopy systems, a beta-gamma proportional counter, and a liquid scintillation counter.
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inspector noted that sources having the proper geometry and
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appropriate energy characteristics were utilized to calibrate
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detectors for radionuclide analyses of normal effluents.
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selected gamma spectroscopy analytical measurements, where the exact density for the calibration source was not available, attenuation corrections were adequate to ensure conservative measurements.
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i following issues which could affect the accuracy of analytical effluent measurements were discussed in detail.
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l The licensee utilizes a standard self-absorption curve l
.(Radiological Health Handbook) for corrections of gross beta-gamma analyses.
Licensee representatives agreed to develop i
a new self-absorption curve for th~e actual radionuclides and
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media sampled.
The' licensee does not distill liquid samples prior to conducting
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liquid. scintillation counting (LSC) tritium (H-3) sample l
analyses.
Distillation removes any radionuclides which could,
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if present, add a positive bias to the H-3 analyses.
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other radionuclides are analyzed by the beta-gamma proportional counting.
The licensee agreed to evaluate the potential for radionuclide interferences with H-3 analyses of undistilled liquids.
l The licensee had not determined the lower limit of detection (LLD) for all radiological analytical measurements.
The licensee provided LLD determinations for selected effluent analyses.
For H-3 analyses the inspector noted that the LLD was
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not adequate to ensure compliance with regulatory limits. Where necessary, adjustments to counting techniques should be made to ensure that analysis LLDs are lower than required regulatory limits for effluent releases.
This item is discussed further in Paragraph 6.c.
Quality Assurance (QA) methodology for effluent radiological
measurements was discussed and reviewed with licensee
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representatives. A Quality Control (QC) and/or calibration source is
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analyzed with each batch of effluent samples.
Also, the licensee participates in the Environmental Protection Agency (EPA)
environmental sample cross-check program.
Analysis results for EPA samples were reviewed and discussed with licensee representatives.
For gross beta-gamma activity, licensee concentrations were comparable to the known values, although.bf ssed high (ranging from approximately 7-45% above reported EPA values).
Although the j
licensee had conducted cross-check EPA H-3 analyses, results were not
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available for review.
Licensee representatives stated that use of
the EPA cross-check program would continue as part of their quality
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assurance program for effluent measurements.
No violations or deviations were identified.
b.
TS 3.4.1 states that exposure to the public resulting from the release of Ar-41 and other airborne effluents from UVAR will be below the limits of 10 CFR 20 for unrestricted areas.
The inspector
reviewed and discussed calculations for Ar-41 production at the UVAR
facility.
Worst case estimates of Ar-41 concentrations at the unrestricted boundary area was approximately 2.5 E-9 uCf/cm3 These results have not been verified by quantitative measurements.
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inspector informed licensee representatives that measured data regarding Ar-41 concentrations within the reactor room would corroborate the present calculations.
Licensee representatives agreed to review records regarding any completed studies of Ar-41 concentrations for the UVAR facility.
No violations or deviaticns were identified.
c.
TS 3.4.2 states that the exposure to the public resulting from the release of radioactive liquid effluents from the UVAR will be below 10 CFR limits for unrestricted areas.
50P 10.5.B.2 states that all pond water releases shall be in accordance with 10 CFR 20,10 CFR 20 Appendix B, or Note to Appendix B.
The inspector discussed release j
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procedures and reviewed the release authorization forms with cognizant licensee representatives.
10 CFR 20 Note 3.b to Appendix.B requires the total activity released to unrestricted areas to be less i
than 1.0 E-7 uCi/ml.
From discussion with cognizant licensee
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representatives, the inspector noted that H-3 concentrations were not included in the release authorization calculations.
-Licensee representatives stated that H-3 concentrations in the ' pond and effluent water were below the LSC analysis-detection limit of approximately 1 E-6 uC1/m1, and thus were not. included in the i
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evaluations..._The inspector noted that minimum detection limits;for H-3 should. be established to meet or exceed the required release
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limit of 1 E-7 uCi/ml.
The failure to properly analyze liquids for
H-3 - at or below effluent release limits,. potentially may have l
resulted in the release of total activity greater than 1 E-7 uC1/ml in'11guids from the UVAR facility.
The inspector informed licensee E
representatives that this issue would be considered an unresolved l
item pending licensee evaluation of general H-3 concentrations in
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pond water used for normal dilution and also effluents subsequently
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released from UVAR and comparing the results to regulatory, limits (50-62/87-02-01).
-Licensee representatives acknowledged the
' inspector's comments and agreed to evaluate the H-3 analyses and provide-data regarding this concern.
On June 2.,1987, during a telephone call-between UVAR and US NRC Region II representatives, preliminary data concerning gross activities released in liquid from the-UVAR facility were detailed.
Based on concentrations of H-3 in the waste holdup tanks and specified dilution factors, licensee calculations indicated that regulatory release limits were not exceeded. The inspector informed licensee representatives that these evaluations will be reviewed during a subsequent inspection, q
No violations or deviations were identified.
d.
TS 6.6.2(6) requires a routine report to be made by March 31 of each year to the Director, Division of Reactor Licensing, US NRC, D.C.
20555, with a copy to the Commission, Region II Office of Inspection j
and Enforcement, providing a summary of the nature and amount of
radioactive gaseous, liquid, and solid effluents released or l
discharged to the environs beyond the effective control of the l
licensee as measured or calculated at or prior to the point of'such
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release or discharge.
Excluding 1984 data, the inspector reviewed effluent release data in the above referenced reports for 1982 through 1986. No anamolous data were reported and average values for airborne and water concentrations, of approximately 2 E-12 uCi/cc and i
1 E-8'uC1/m1, respectively, were below 10 CFR 20 limits.
Noted j
decreases in the calculated annual Ar-41 activity released between j
1983 and 1985, from approximately 8 C1 to 1 C1, resulted from
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decreased reactor operating hours at the UVAR facility.
The inspector discussed reporting of effluent and environmental data in the referenced reports.
Discussions included the reporting of
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standard deviatio'ns with concentration data values, thereby allowing-
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objective comparisons of values for samples collected from various sample and background areas.
Also discussed with the licensee was
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the reporting of a single average value to represent concentration
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data in low activity environmental samples which could be misleading l
in. that a few anamolous data points could significantly bias the
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results.
Reporting an average value in conjunction with the range
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distribut ion would provide a more realistic representation of _ the
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data. Licensee representatives agreed to evaluate these areas during
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preparation of future reports.
i No violations or deviations were identified.
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