IR 05000062/1989001
| ML20247B488 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 08/30/1989 |
| From: | Bassett C, Kuzo G, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20247B469 | List: |
| References | |
| 50-062-89-01, 50-62-89-1, IEIN-87-003, IEIN-87-031, IEIN-87-3, IEIN-87-31, IEIN-88-032, IEIN-88-100, IEIN-88-32, IEIN-89-002, IEIN-89-013, IEIN-89-027, IEIN-89-13, IEIN-89-2, IEIN-89-27, NUDOCS 8909130047 | |
| Download: ML20247B488 (12) | |
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- MCEI UNITED STATES NUCLEAR REGULATORY COMMISSION
./ o REGION il fg 7 y 101 MARIETTA STREET,N.W.
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'AU8 301989 Report No.: 50-62/89-01 Licensee: University of Virginia Charlottesville, VA 22901
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Docket No.: 50-62 License No.: R-66 Facility Name: University of Virginia Reactor (UVAR)
Inspection Conducted: July 11-13, 1989 Inspectors: [,d 8/JO/87 i. Bassett, Radiation Specialist Difte 54gned OWN G. B. Kuzo, Senior Radition Specialist 30 !O7 Date Signed Approved by: 8/30/89 E. J. McAlpine, Chief \ Date Signed Radiation Safety Projects Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection involved onsite review of radiation protection program- activities, including radiation control activities, environmental surveillance and monitoring, transportation, and review of licensee actions concerning NRC Information Notices (ins).
Results:
The staffing and current organizational structure were adequate to meet Technical Specification (TS) requirement and to implement the licensee's radiation protection program. The positions of Reactor Health Physicist (HP)
and Radiation Safety Officer (R50) were vacant but were being filled temporarily by p;rsonnel from the University of Virginia Environmental Health and Safety (EHS) departmen Training appeared to be adequate to meet federal 4 regulations and to implement an effective radiation control progra Facility i I
radioactive contamination levels and radiation exposure to personnel were apparently well within the local administrative limits, as well as within federM regulatory limits. The licensee demonstrated timely response to NRC ,
initiatives including improvements to procedures and methodologies for
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radiation control activities. Weaknesses were identified in the areas of .
responding to internal audits, environmental air sampling and reporting all exposure received as whole body dos :909130047 890830 PDR ADOCK 05000062 i Q PDC l l
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The following violations were identified during the inspection:
-- Failure to conduct adequate surveys of environmental airborne effluents in unrestricted areas to evaluate the extent of radiation hazards present, an apparent violation of 10 CFR 20.201(b) requirement Failure to have adequate procedures for use of analytical measurement instrumentation, non-cited violation (NCV) due to meeting NRC Enforcement Criteria for licensee identified and corrected problem An unresolved item (URI) was also identified during the inspection involving the failure to report possible neJtron exposure as whole body dose in the licensee's exposure record i
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REPORT DETAILS Persons Contacted Licensee Employees
- B.-Copeutt, Former Radiation Safety Officer
- J. Farrar, Reactor Administrator
- J. Gilchrist, Acting Radiation Safety Officer G. Glennie, Radiation Safety Technician
- A. Jackson, Acting Reactor Health Physicist
- R. Mulder, Director, University of Virginia Reactor Facility L. Scheid, Reactor Operator
- T. Williamson, Chairman, Department of Nuclear Engineering Other licensee employees contacted included operators, Radiation Control (RC) student assistants, and office personnel.
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- Attended exit interview Radiation Control (83743) Organization and Staffing Technical Specification (TS) Sections 6.1.1, 6.1.2, and 6.1.3 detail organizational structure, management responsibility and staffing requirements for safe operation of the UVAR facilit From discussions with licensee representatives, the inspector verified that the facility management responsibilities and organizational structure had not changed since the previous NRC inspection of radiation protection activities (Inspection Report No.50-62/88-03). However, due to the recent resignations of the RSO and the Reactor HP, the licensee was using personnel from the University of Virginia (UVA) EHS department temporarily until permanent replacements can be found. The licensee indicated that persons were being considered for each of the positions and that it was anticipated that the positions would be filled by the start of the coming school yea The inspector detennined that the licensee h3d submitted a proposed change to the TS concerning the person to whom the Reactor HP reptets. The TS requires the Reactor HP to report to the head of. the e OVA EHS department as a means of keeping the " regulatory" function of health physics separate from the operations portion of the Nuclear Engineering and Engineering Physics (NEEP) department. The licensee indicated that the change would require the Reactor HP to report to the NEEP department head; however, the position of Reactor HP would continue to be funded through the EHS department as it is currentl This would allow the Reactor HP to be outside the direct control of
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i the operations group and yet remain available to continually support reactor operation The inspector reviewed and discussed with cognizant licensee representatives the current staffing detailed to conduct routine and nonroutine radiation protection activities at the UVAR. The licensee currently has four licensed senior reactor operators (SR0s) and one licensed reactor operator (RO) who assist in minor radiation protection activities such as decontamination of areas found to be contaminated during routine survey Additional assistance to conduct radiation protection program activities is provided by personnel detailed from the UVA EHS Radiation Safety Office. Two people from the EHS department are available to support routine operations including the Reactor HP, as previously mentioned, and a Radiation Safety Technician. The Reactor HP assists in coordinating the radiation protection program at the facility to ensure that surveys are performed as required and provides support for other activities such as shipment of radioactive materia The Radiation Safety Techincian conducts routine contamination and radiation surveys on a prescribed frequenc The inspector noted that the organization and staffing levels, utilizing UVAR operations personnel and UVA EHS Radiation Safety Office personnel, appeared adequate to conduct routine and nonroutine radiation protection activities for the facility, b. Audits and Management Evaluations TS 6.2 requires the Reactor Safety Committee (RSC) to review and audit reactor operations to ensure that the facility is operated in a manner consistent with public safety and within the terms of the facility licens TS sections 6.2.2 and 6.2.3 detail RSC member composition and qualifications, and meeting and audit frequencie The RSC is required to meet, at a minimum, semiannually, to approve untried experiments, changes to the reactor, admendments to the facility license, TS and Standard Operating Procedures (SOPS); to review reportable events, operating abnormalities; and to conduct annual audits of operational record The inspector reviewed and discussed the RSC composition with the licensee. The inspector determined that the composition of the RSC was as prescribed in the TS and that the members had the appropriate technical background as required. The inspector reviewed the minutes of the RSC meetings conducted from November 21, 1988 through July 7, 1989. The inspector noted that during this time period the RSC met TS requirements, conducting approximately six meetings to review applicable items affecting operation of the L ilit The meeting minutes indicated that the majority of issues discussed and reviewed included, usage of the Rotating Irradiation Facility (RIF),
conversion to using low enriched uranium (LEU) fuel in the UVAR
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reactor, decommissioning of the CAVALIER reactor, license amendments, and consideration of various experiments to be conducte The inspector also reviewed the audits conducted by the RSC. One audit addressed the compliance of UVAR procedures and methods with Section 7 of the Standard Operating Procedures (SOP) regarding calibration and maintenance. The audit found that some calibrations were performed without procedures. The RSC auditors suggested that there should be a procedure for every type of calibration. Another audit reviewed the adequacy of radiation and contamination surveys being performed at the facility, transfers of radioactive material,.
and personnel dosimetry records. No problems were noted with the surveys or radioactive material transfers but the RSC auditors noted that no lifetime dose was listed for individuals on the forms provided by a vendor who had been hired recently to track individual exposure. The licensee indicated that no followup actions on any of these findings had been completed to dat c. Training 10 CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portion of the restricted area in health physics protection problems associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed, applicable provisions of Commission Regulations, individuals responsibilities and tne availability of radiation exposure reports which workers may request pursuant to 10 CFR 19.1 The inspector discussed, with cognizant licensee representatives, training provided to personnel frequenting the UVAR facility. The licensee indicated that, excluding visitors touring the facility, persons spending appreciable time within the UVAR restricted area included operators, experimenters, workers performing repairs on the roof, and UVA EHS personnel. The licensee indicated that only those I persons who have received the appropriate training and who have been I
badged and received a dosimeter are allowed unsupervised access to the facilit Training regarding radiation protection activities required for unescorted UVAR facility access is provided on an annual basis. The training provided reviews of both the security and health physics aspects pertinent to facility operatio Personnel who handle radioactive materials within the facility are required to attend the
" Restricted Ustrs" course provided by the UVA EHS departmen The inspector reviewed and verified training for all construction workers who performed maintenance activities on the facility roo Initial training, conducted December 8,1988, included Security, .
i Emergency Response, and Health Physics informatio In addition, t I training was provided to personnel on June 26, 198 During the
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review of training records the inspector noted delays in finding documentation verifying completion of the required trainin Licensee representatives attributed the delays and confusion to ~the resignation of the Reactor HP who previously was responsible for training records. Following discussion of the inspector's concerns regarding maintenance of adequate training records, licensee representatives' agreed that requirements for all personnel should be outlined and the appropriate records maintained on. file at the UVAR office to facilitate required training updates and review, d. Facility Tours - Posting and Labeling Requirements 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 procedures; and (4) Form NRC-3; in sufficient places to' permit individuals engaged in licensed activity to observe them on the way to and . from any licensed activity location. If posting of the documents specified in (1), (2), and (3) is not practicable, the licensee may post a notice which describes the documents and states where they may be exam;ne During tours of the facility the inspector noted that the applicable documents and/or references to their location were posted at the entrance to the reactor control room. The posted documentation indicated that copies of regulations and procedures were maintained in the reactor administrator's offic CFR 20.203 specifies the requirements for posting radiation areas, high radiation areas and labeling containers of radioactive material Posting of entrances into the' restricted area and the labeling of containers were reviewed and discussed with licensee representative Postings of areas and labeling of radioactive material appeared to be adequate and in compliance with applicable regulation e. Surveys 10 CFR 20.201(b) re such surveys as (1) quires the licensee to make or cause to be mademay be ne regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen ;
TS 6.3 requires radiation control procedures to be maintained and
made available to all operations personne S0P 10.4, Facility and Environmental Surveys, dated November 1970 and !
revised February 1989, details radiological surveys conducted within !
the UVAR restricted area to meet the applicable TS surveillance i
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requirements. The inspector reviewed this section of the 50P and it appeared to be adequat The inspector also selectively reviewed the UVAR restricted arec radiological survey results. Surface contamination levels were generally below the administrative limit of 50 disintegrations per minute per one hundred square centimeters (dpm/100cm2).
Infrequently, routine surveys indicated selected areas of. elevated surface activity greater than the limit. The inspector noted that all areas indicating greater than 50 dpm/100 cm2 were immediately
. decontaminated by operations personne Airborne particulate concentrations were below twenty-five percent (%) of the maximum permissible concentration (MPC) as specified in 10 CFR Part 20, Appendix B. Table 1 Column 1. General radiation dose rates were less than 0.5 millirem per hour (mr/hr) when the reactor was not operating and ranged from 0.5 to approximately 5 mr/hr in the reactor room and on' the bridge over the pool while-the reactor was operating at 100% powe TS 4.4 requires operation of radiation monitoring equipment and the position of their associated alarm set points to be verified daily
'during periods when the reactor is in operation. Calibration is required to be performed on a semiannual basi The inspector observed various radiation monitoring devices throughout the facility and verified that the alarm set points were set properly and had been verified on a daily basis. The instruments had also been calibrated at the required frequenc External Exposure Reviews 10_ CFR 20.101 delineates the quarterly radiation exposure limits to the whole body, skin of the whole body, and the extremities for individuals in restricted area The inspector reviewed and discussed the exposures recorded for persons working or visiting the UVAR facility from January 1,1989 ;
through April 30, 198 Personnel exposure measurements are conducted using thermoluminescent dosimeters (TLDs) provided by a ;
National Voluntary Laboratory Accreditation Program (NVLAP)
accredited vendor. Vendor specifications reported a detection limit of 15 mrem for the provided dosimetry. Highest reported exposure for the period reviewed was approximately 82 mrem assigned to an experimenter. The exposure resulted from activities associated with activation analyses, handling rabbt transfers, and counting sample a The majority of the remaining annual cumulative exposures for other l UVAR operations personnel totaled less than 20 mrem for each individua The highest cumulative extremity expos tre was 115 mrem to the left hand of one of the operations personnel. This was measured by finger ring TL '
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During the review of the exposure records supplied tc the licensee by the vendor, the inspector noted that neutron exposure was indicated for some of the individuals listed. In reviewing the total whole body exposures for these individuals, the insrector noted that the neutron exposures had not been included in the whole body exposure totals. The licensee indicated that they had recently contracted with a .new vendor to provide TLDs and track exposure. Licensee-representatives also indicated that they had other questions concerning what the vendor was reporting (see paragraph 2.b) and would inquire as to the reason why neutron exposures apparently were not being included in the whole body exposure totals. The licensee was informed that this item would be considered as an unresolved item (URI) pending final resolution by the licensee / vendor and would be ,
reviewed during a future NRC inspection (50-62/89-01-01).
No violations or deviations were identifie . Environmental (80745)
' Environmental Reports TS 6.6.2 requires a routine annual report, to be submitted by March 31, covering ~ the activities of the reactor facility during the previous calendar year. .Each report shall include a summary of the nature and amount of radioactive gaseous, liquid and solid effluents released or discharged to the environs beyond the effective control of the licersee as measured or calculated at or prior to the point of such release or discharge; environmental surveys performed outside the facility, and exposures received by facility personnel and visitors; and a summary of radiation and contamination surveys performed within the facilit The inspector verified that an annual report was prepared and issued by the licensee in accordance with applicable TS requirement ,
Details of the report are discussed in subsequent sections of this {
paragrap Effluent Releases TS 3.4.2 requires that the activity of liquids released beyond the site boundary shall not exceed 10 CFR Part 20 limit From January 1, 1988 through December 31, 1988, the licensee conducted 13 waste tank liquid releases, with average radionuclides d
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concentraticas ran milliliter (uti/ml)ging from 0.2 E-7 to 0.5 E-7 microcuries perA calculated total
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gross beta-gamma activity were released .iuring 198 In addition, the inspector verified the analysis of monthly environmental water samples collected at selected downstream and upstream locations }
relative to the UVAR facility release poin The concentrations '
i released were within limits specified in 10 CFR 20, Appendix B,
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Table II, Column 2. The. inspector noted that the reported data were similar to values specified in previous annual report Gaseous eff1 tent release monitoring was discussed with' licensee representatives. For 1988, the . licensee continued to rely on 'a calculated estimate of.the maximum concentration of Argon-41 (Ar-41)
produced during normal . operations to determine gaseous effluent releases. For 1988, the licensee estimated a total release of 1.31 Ci of Ar-41 during facility operation During discussions regarding verification of the gaseous effluent calculation methodology, licensee representatives stated that if possible, actual measurements of gaseous effluents may be conducted in the future. However, present staffing and equipment limitations -
currently prevented completion of such a task. The inspector noted that direct measurement verification of gaseous effluent concentrations was not required by either Technical Specifications or 10 CFR Part 20 regulation c. Analytical Measurement Capability 10 CFR 20.201(b) re such surveys as (1) quires the. licensee to make or cause to be mademay regulations in this part and (2)are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen CFR 20.106 requires each licensee to limit the concentrations of radioactive effluent material released to unrestricted areas from exceeding the limits specified in 10 CFR 20, Appendix B, Table I S0P 10.4, Facility and Environmental Surveys, dated November 1970 and revised February 1989, requires particulate air samples to be collected and analyzed on a monthly basis at predetermined locations outside the Facilit The inspector reviewed and discussed with cognizcnt licensee representatives the licensee's analytical radionuclides measurement program. The following issues were reviewed and discussed in detai Radionuclides Measurement Cross Check Progra Licensee representatives stated that recent Environmental Protection Agency (EPA) cross check samples were received but not all radionuclides ' analysis of the samples had been conducte The resignation of the Reactor Health Physicist has limited performance of this activity. However, licensee representatives stated that continued participation in the EPA cross check program would be considered an important item for the facility radiological effluent monitoring progra The inspector noted that participation in the program was not required by Technical I
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Specifications nor 10 CFR Part 20 requirements, but would enhance the licensee's analytical measurement capabilit Analytical Quality Control Programs. The inspector verified that the radiation standards used to calibrate the counting equipment were traceable to the National Institute of Standards and Technology (formerly National Bureau of Standards).
However, the frequency of instrument calibrations, limits of quality control checks and review of the instrument performance were not outlined in approved procedures. For example, during review of quality control checks conducted for tritium measurements required for liquid waste releases, the inspector noted that for one QC sample, the measured results were 30 percent less than the expected values. This non-conservative bias was reported without any corrective action being take The inspector noted that a similar issue, regarding failure to have adequate procedures for analytical instrument calibration was identified previously during a licensee audit (Paragraph 2.b). Licensee representatives stated that this issue would be addressed. as part of their corrective action to the audit findings but that no action had yet been taken. Based on review of licensee audit findings and discussion of the proposed corrective actions, the inspector informed licensee representatives, that this issue was considered a licensee identified violation (50-62/89-01-02). Furthermore, this licensee identified violation was considered a non-cited violation (NCV) because criteria specified in Section V.G.1 of the NRC Enforcement Policy to encourage and support licensee initiative for self-identification and correction of problems were satisfie Lower Limit of Detection (LLD) calculation The inspector reviewed the LLDs for analytical environmental measurements required by the Technical Specifications. For liquid effluent measurements conducted from January 1988 through June 1989, the calculated LLD was below the applicable liquid maximum permissible concentration (MPC) listed in 10 CFR 20, Appendix B, for release to unrestricted areas. However, for environmental airborne particulate sample analyses conducted from January 1, i
1988, to June 30, 1989, the the inspector noted that the LLDs, values ranging from 7.11 E -11 microcuries per milliliter (uCi/ml) to 2.9 E -11 uti/ml for selected analyses, exceeded j
ine airborne MPC for gross beta-gamma activity (2.00 E -14 uCi/ml) allowed for release to unrestricted areas by 10 CFR 20, Appendix B, Note 2.c., Table II, Column 1. The inspector noted l
' that the failure to conduct adequate surveys to evaluate the hazards present was an apparent violation of 10 CFR 20.201(b)
requirements (50-62/89-01-03).
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I 4. Transportation (86750)
10 CFR 71.5 requires each licensee who transports licensed material (
outside the confines of its plant or other place of use to comp y with the !
applicable requirements of the Department of Transportation DOT) in l'
l 10 CFR Parts 170 through 18 Processing and shipping of radioactive waste, and other materials activated and/or stored at the UVAR were discussed with licensee representatives. Guidance for these activities is provided by the QA/QC Program for the University of Virginia Reactor Facility, revised December 198 The inspector reviewed the QA/QC Program and noted that improvements could be made in the checklists used for shipping radioactive material and in maintaining all shipping documentation in one locatio The licensee indicated that they would review the checklists and revise them and their recordkeeping system as require No shipments had been made since the last inspection but preparations were being made to ship irradiated iridium seeds to a company in Californi The inspector reviewed the material prepared to date to ship the irradiated seed It appeared that adequate preparations were being made for the shipmen No violations or deviations were identifie . Followup Items (92701)
The inspector determined that the following NRC Information Notices (ins)
had been received by the licensee, reviewed for applicability, and distributed to appropriate personne '
IN 87-03 Segregation of Hazardous and Low-level Radioactive Wastes, dated January 15, 198 A IN 87-31 Blocking, Bracing, and Securing of Radioactive Materials Packages in Transportation, dated July 10, 198 IN 88-32 Prompt Reporting to NRC of Significant Incidents Involving Radioactive Material, dated May 25, 198 IN 88-100 Memorandum of Understanding between NRC and OSHA Relating to NRC-licensed Facilities (53 FR 43950, October 31, 1988) dated December 23, 198 IN 89-02 Criminal Prosecution of Licensec's Former President for ,
Intentional Safety Violations, dated January 9,198 IN 89-13 Alternative Waste Management Procedures in Case of Denial of Access to Low-level Waste Disposal Sites, dated February 8, '
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i 10 IN 89-27 Limitations on the Use of Waste Forms and High Integrity Containers for the Disposal of Low-level Radioactive' Waste,
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dated. March 8, 198 . ExitInt'erview(30703)
L The inspection scope'and findings were summarized on July'13, 1989, with those persons indicated in Paragraph I. abov The_ inspector discussed and detailed the findings for each area reviewed. Licensee representatives acknowledged the inspector's comments. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector .
'during this. inspectio Item Number Description and Reference 50-62/89-01-01 URI concerning failure to report possible neutron exposure as whole body dose in licensee exposure records (Paragraph 2.f).
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50-62/89-01-02 NCV concerning failure to have adequate procedures for use of analytical measurement instrumentation (Paragraph 3.c, not cited due to meeting NRC Enforcement Criteria for licensee identified violation).
50-62/89-01-03- VIO concerning failure to conduct adequate surveys of environmental airborne effluents to evaluate the extent of radiation hazards present (Paragraph 3.c, violation of 20.201(b) requirements).
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