IR 05000062/1989003
| ML19351A372 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 10/04/1989 |
| From: | Bassett C, Belisle G, Burnett P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19351A371 | List: |
| References | |
| 50-062-89-03, 50-396-89-01, 50-396-89-1, 50-62-89-3, NUDOCS 8910200132 | |
| Download: ML19351A372 (12) | |
Text
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...e - , , ' Report Nos.: 50-62/89-03 and 50-396/89-01 . Licensee: University of Virginia Charlottesville,. VA - 22901 Docket Nos.: 50-62 and 50-396 License Nos.: R-66 and R-123 Facility Name::. University of Virginia UVAR and CAVALIER , m Inspection Conducted: September 18 to 21, 1989 d.
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Inspector:- Em o Date<51gned 'P.
T. Burnett " ' /0[4-[89
Inspector: C. H. Bassett \\ Date Signed , L.
Approved by: c4 /([d[CT G. A. Belisle, Chief Date / Signed ~ Test Programs Section . Engineering Branch Division of Reactor Safety ' Y,,
. . <' SUMMARY - '
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(' This routine, unannounced inspection addressed the areas of the annual operations, s , !. /, ' inspection of a Class I research reactor (UVAR), onsite review of radiation ,
. , 1,2 3. 1. t - protection' program activities. involving the licensee's Class II research' , ,' . reactor (CAVALIER), transportation of radioactive waste and a review. of
. ,, . i . . ' licensee actions regarding previously identified issues.
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, , , ~~ W Results: e i.y u t g ., - Om The staffing and current organizational structure were adequate to meet - g Technical-Specification requirements and to implement the licensee's ~ radiation: f, j,h - protection program.
The positions of Reactor Health Physicist.and' Radiation .
" ' ', ' Safety Officer were vacant but were being filled temporarily by personnel from.
' , , the. Environmental Health and Safety Department.
Two unresolved items were identified during the UVAR inspection: Reactor Safety Comittee audits of the operations logbook and irradiation logbook have not been performed since 1985.
TS 6.2,3.(6) requires a Comittee audit of operational records at least once per year.
Whether the other, useful, semi-annual audits conducted by the Comittee meet the ' intention of this specification is unresolved, and the issue will be discussed with NRR prior to making a determination - paragraph 3.
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Completion of the current licensed-operator-requalification lecture series and administration of requalification examination have slipped about eleven weeks from the procedurally required schedule.
Whether this slippage in completing the requalification cycle is acceptable is current-ly unresolved pending discussion between Region II'and NRR - paragraph 4.
Aside from these two items, the Reactor Safety Committee is performing $ts review and oversight activities diligently and requalification training appears to be adequate to meet requirements of the approved requalification training program.
Facility radiation and contamination levels were well within the local administrative limits and radiation levels were within federal regulatory limits as well.
The licensee demonstrated timely response to NRC initiatives including i improvements to procedures and methodologies for calculating and monitoring i shutdown margin and core visual inspections - paragraph 10.
No violations or deviations were identified.
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J REPORT DETAILS '1.
Persons Contacted j Licensee Employees l '
- P. Benneche, Reactor Administrator
- J. Farrar, Supervisor, Reactor Operations J. Gilchrist, Acting Radiation Safety Officer
A. Jackson, Acting Reactor Health Physicist
- R. Mulder, Director, Reactor Facility L. Scheid, Reactor Operator
- T. Williamson, Chairman, Department of Nuclear Engineering and Engineering Pnysics Other licensee employees contacted included faculty members and office personnel.
- Attended the exit interview on September 21, 1989.
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Acronyms and initialisms used throughout this report are defined in the final paragraph.
2.
Organization, Logs, and Records (39745) a.
Organization ! The organization of the reactor facility is as described in TS 6.1.
The reactor HP position shown on the recently amended organization chart is currently filled by a HP on loan from the EHS Department, but recruitment of a permanent staff member is underway.
b.
Review of Operations Logs
UVAR Log #28 was reviewed for the period 28 July 1989 to 15 September , 1989, inclusive.
Most routine data entries were facilitated by the ' 1-use of rubber-stamp entry forms to assure all requinsd data were entered.
Typical stamp forms included the startup checklist, power l checklist, irradiation data, and shutdown margin.
The latter was l.
revised in July 1989 to ensure that the withdrawn worth of the L unscrammable regulating rod was not included in the calculation of l shutdown margin.
No unusual or ramarkable irradiation or experimen- ' tal activities were noted.
, The last two pages of the logbook record the reactor scrams.
In the , l period given above, there were 35 scrams.
Most were due to instru-ment noise, which is not unusual with a protective system that does not require coincident signals to initiate a trip.
Some trips came from the loss of utility service.
None were indica.tive of operator error.
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UVAR Operations Notebook The UVAR Operations Notebook was reviewed as an adjunct to the operations and Irradiations log.
It contains a list of authorized users of the various irradiation facilities.
The list is approved
and signed by the director.
The last update was for core loading i ! 25-A on August 29, 1989. There is also a list of the three permanent staff members authorized to handle materials producing more than 1 R/hr at one foot.
The notebook also contains the most recently measured values of significant parameters such as the integral worth of each control rod, minimum permissible critical rod position, and
excess reactivity. The contents also include the measured reactivity worths of incore or core-adjacent experimental facilities and the ' mass limits for the amount of boron or cadmium absorber to be used in each facility.
d.
Review of Reactor Irradiations The Irradiation Log for the period was reviewe, along with some of the more recent Routine Irradiation Request Forms.
No need for additional review of these activities was identified, e.
Maintenance Activities
Maintenance activities were reviewed in concert with the review of a surveillance activities; since they are in common files, and are addressed in paragraph 6.
No violations or deviations were identified.
3.
ReactorSafetyCommitteeReviewandAuditActivities(40745) Review of the minutes and audits of the RSC showed that the RSr ="t eight times during the review period.- Reports of required semi-annt Mits by subcommittees were submitted to the RSC on December 15, 1988. i y 16,
' 1989.
The first, although described as an operational audit, did not include a review of the operations logbooks for the UVAR. That audit was, l however, a cogent and useful review of instrument calibration procedures l and methods and produced recommendations for improvements in calibrations.
l The second audit was of the reactor health physics program. The inspectors' review of licensee records indicates that a RSC audit of the operations l l logbook and irradiation logbook has not been performed since 1985.
TS I 6.2.3.(6) requires a RSC audit of operational records at least once per year.
Whether these other, useful reviews meet the intention of this specification is unresolved, and the issue will be discussed with NRR prior to making a determination (UNR 50-062/89-03-01).
It should be noted L that prior to this inspection the published agenda for the RSC meeting , i scheduled for September 26, 1989 included an item on RSC audit requirements.
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The reactor administrator, secretary to the RSC, does conduct a pe* iodic review of the operations logbook.
That review is documented by a signed, stamped entry in the logbook.
' The records of facility correspondence with the RSC and the minutes of the meetings of the RSC indicate that the RSC was kept fully informed of
' facility activities including proposed experiments, modifications of experiments and experimental equipment, proposed procedure changes and . proposed facility modifications.
Progress reports were submitted to the RSC as appropriate.
RSC review of these proposals appeared to be thorough and thoughtful. Modifications completed during the review period included: a.
New, inde,. nt control rod magnet current meters were installed on the reactor ' sole.
Rod drop times were measured immediately after the modific6, and were found acceptable, b.
Shielding changes were made to the southeast access facility.
An acceptable radiation survey was obtained after the modification.
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The liquid level monitoring system for underground waste tank I was I-modified so that both tank 1 and 2 will activate a level warning I light regardless of pump status. This modification provides an early l warning of decreasing tank levels.
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A fresh water makeup purification system was added. Water enters the pool through a standpipe, which provides anti-syphon protection.
' The RSC meeting minutes and correspondence reflect a labor-intensive and continuing involvement in the review of the conversion of UVAR to LEU.
No violations or deviations were identified.
4.
ReactorOperatorRequalificationTraining(41745) l The approved Operator Requalification Program for the UVAR requires a specific minimum series of lectures once per year with an examination at the end of the series.
The facility Procedure for Implementing the Requalification of Program for' Operators and Senior Operators specifies a yearly cycle running from 1 July to 30 June of each year. For the current training cycle, all the required lectures had been scheduled, and all but the lecture on radiation, contamination control, and ALARA had been completeo.
That lecture was scheduled for September 22, 1989, with the l ! requalification examination to follow later that day.
Whether this slippage in completing the requalification cycle is acceptable is currently unresolved pending discussion between Region II and NRR (UNR 50-062/89-03-02).
The inspectors reviewed the requalification examinations for 1987, 1988, and 1989 and concluded they demanded a reasonable amount of knowledge about the operation of the UVAR.
However, the health physics sections seemed to emphasize theory at the expense of the practical aspects of handling radioactive material produced by the irradiations or of the radiation hazards present in the experimental facilities.
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) h i h No violations or deviations were identified.
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Procedures (42745) ! The inspector reviewed the following SOPS: a.
4.1 Daily Checklist b.
4.2 Startup Checklist ' c.
4.3 Power Checklist d.
4.4 Completion of Operations Checklist e.
4.5 Extended Operation checklist f.
5.1 Procedures for Reactor Startup ' g.
5.3 Procedures to Shut Down or Secure the Reactor h.
5.7 Core Visual Inspections and Prescribed Corrective Actions 1.
11. Abnormal Conditions All of the procedures reviewed appeared to provide sufficient detail, with steps in logical order, to accomplish the activities or problems addressed.
No violations or deviations were identified.
6.
SurveillanceandMaintenanceActivities(61745) ' Control rod worth measurements were completed on August 24, 1989, follow-ing assembly of core 25-A and in response to the requirements of TS 4.1(2).
After the rod worth measurements, the licensee measured the reactivity worth of core-adjacent experimental f acilities and confirmed that the limiting amount of absorber, boron or cadmium, in these facili- ! ties had minimal reactivity effect.
The results of these measurements were entered in the UVAR Operations Notebook and were reported to the RSC.
i l The semi-annual rod drop time tests, required by TS 4.1.(1), and annual l visual rod inspections, required by TS 4.1.(3), were carried out satisfac-l torily and with acceptable frequency during the review period.
l l The semi-annual instrument calibrations of instruments listed in TS Table 3.1, required by TS 4.2.(3), were inspected for the following instrument , l channels: l Bridge radiation monitor, i-Pool water level monitor, Pool temperature and delta-T RTDs ( One burned out connector was replace during the pet iod inspected, and the appropriate recalibra-tion was performed.), Power range neutron channels (One detector was replaced in June 1989.), <
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.. l Intermediate range monitor and period meter (Maintenance was per-formed on September 5,1989 to clean contacts and improve ground-ing.),and Source range monitor and countrate interlock.
All of the channels listed above had been calibrated with the required , semi-annual periodicity for the past two years. Other instrument channels listed in TS Table 3.1 require no calibration and are tested on the daily check list.
These include the manual, power-to-the-primary-pump, and air-pressure-to-the-header scrams.
In addition to the calibrations listed above, the power range monitors were calibrated weekly against a heat balance whenever there was extended operation above one kilowatt.
The heat-balance calibration was performed in all but two weeks of the period reviewed.
ECCS flow measurements are required annually by TS 4.3.
A successful test , was last performed on September 26, 1988, using SOP-7.8, Emergency Spray ) System.
The calibrations of area radiation monitors (core gamma monitor, reactor i room constant air monitor, reactor fato radiation monitor, hot cell, and ' demineralizer) were performed with the frequency required by TS 4.4.
There appeared to be little drift between calibrations in these and the bridge radiation monitor calibrated under TS 4.2.
'l i TS 4.6.(4) requires a verification of the confinement building leak rate ' whenever fueled experiments generating more than one watt of power are i performed and the interval since the last verification is greater than
twelve months.
No fueled experiments have been performed in over ten ' l, ears.
Hence, it has been about that long since a leakrate test was performed.
Because of that long duration, the licensee is planning to perform a leakrate test during the fall of 1989.
' Primary water conductivity and pH measurements were part of the daily checklist, which exceeds the frequency requirements of TS 4.9.
The frequency of conductivity meter calibrations is not specified in the TS, but calibrations have been performed with semi-annus1 periodicity.
The most recent maintenance performed on the demineralizer system was the replacement of front and rear pump-motor bearings on October 17, 1988, i On January 17, 1989, the biennial full-scale emergancy drill was conducted with participation by outside agencies. Acceptable results were reported to the RSC.
No violations or deviations were identified.
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Experiments (69745) j No new kinds of experiments were conducted during the review period.
The routine irradiation experiments, a major portion of facility activity, are discussed.in paragraph 2.d above.
Special testing was performed on and procedures written and approved for the operation of the rotating irradiation facility.
, No violations or deviatinns were identified.
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Class II Operations - CAVALIER Reactor Operations (40750) a.
Logs, Procedures, Requalification Training, and Experiments Through discussions with the licensee, the inspector determined that the licensee had decided not to operate the CAVALIER reactor in a ' mid-1987.
A dismantling plan had been submitted to the NRC in November of 1987 and a possession only license applied for regarding the CAVALIER.
The licensee then proceeded to unload the core and . partially dismantle the operating mechanisms involved.
The NRC, however, had not approved this approach and had requested that the licensee consider decommissioning the reactor instead. The licensee was in the process of drafting a decomissioning plan during this inspection.
Due to the unloading of the CAVALIER core, logs for the reactor were no longer being maintained.
Procedures were being maintained but no changes were needed and none were being processed.
Requalification training for the CAVALIER reactor operators was not being conducted because of the licensee's intention to ultimately decommission the reactor.
With the core unloaded, no experiments could be conducted
and none had been performed sirice the end of 1987.
b.
Surveillances l TS 4.1, 4.2, 4.3, 4.4, and 4.5 specify certain surveillances that are required to be performed.
The licensee, however, had applied for a TS change, Change No. 5 and had received approval from the NRC to make these surveillance requirements applicable only during time periods when the CAVALIER core is loaded.
The inspector verified that the CAVALIER core had been unloaded March 3,1988, and that the reactor had not been operated since November 1987. The surveillances had been postponed in accordance with Change No. 5 of the TS.
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Organization and Staffing 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 University of Virginia CAVALIER facility.
, From discussions with licensee representatives, the inspector veri-fied that the facility management responsibilities remained as outlined in the TS and that the organizational structure was as i ' shown in Figure 6.1.
However, due to the recent resignations of the RSO and the reactor HP earlier this year, the licensee was using personnel from the EHS Office to fill those positions until permanent i replacements could be found.
The licensee indicated that persons were being considered for each position.
The inspector reviewed a change to the TS the licensee had submitted concerning the person to whom the reactor HP reports.
This change had been approved by the NRC on July 20, 1989. The licensee indicated that the position of reactor HP would still be funded through the EHS , department but would report to the NEEP department head. This would J allow the reactor HP to be independent of the operations group and yet remain available to continually support reactor operations. The ' licensee also indicated that this decision to place the reactor HP under the NEEP department head was being reconsidered.
Another TS change may be submitted to place the reactor HP back under the control of the EHS Office and to reword the TS to allow more than one person to be trained in the reactor HP position and become knowledgeable of the reactor facility and related requirements for operation.
The inspector reviewed and discussed with cogniz6nt licensee representatives the current staffing detailed to conduct routine and nonroutine radiation protection and operational activities at the facility.
The licensee currently has five SR0s and one R0 for the UVAR.
Additional assistance to conduct radiation protection program activities is provided by personnel detailed from the UVA EHS department.
Two people from the EHS are available to support routine operations including the reactor HP and a radiation safety technician.
The inspector noted that the organization and staffing levels, utilizing UVA operations personnel and EHS Radiation Safety Office , personnel, appeared adequate to conduct routine and nonroutine radiation protection and operations activities for the CAVALIER facility.
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 . - . , . . _ _ _ _
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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 examined.
During tours of the facility the inspector noted that the applicable documents or references to their location were posted at the entrance l to the reactor control room. The posted documentation indicated that copies of regulations and procedures were maintained in the reactor administrator's office.
10 CFR 20.203 specifies the requirements for posting radiation areas, high radiation areas and labeling containers of 'radfoactive materi-als.
Posting'of entrances into the restricted area and the labeling of containers were reviewed and discussed with licensee representa-tives.
Postings of areas and labd W of radioactive material appeared to be adequate and in complia'nce with applicable regulations.
e.
Surveys 10 CFR 20.201(b) requires the licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with regulations in this part and (2) are reasonable under the circumstances to evaluate . the extent of radiation hazards that may be present.
TS 6.3 requires radiation control procedures to be maintained and made available to all operations personnel.
Section 9.2 of the SOPS for the CAVALIER, dated September 20, 1974, , and revised January 10, 1975, details radiological surveys required within the CAVALIER control room and around the reactor tank in , addition to those in the UVAR restricted area to meet the applicable < TS surveillance requirements.
The inspector reviewed this section of the S0P and it appeared to be adequate.
The inspector also selectively reviewed the results of radiological surveys conducted in the UVAR and CAVALIER restricted areas. Surface contaminatioq, levels were generally below the administrative limit of 50 dpm/100cm. 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/100cm were immediately decontaminated by operations personnel.
Airborne . " particulate concentrations were below 25% of the MPC specified in 10 CFR Part 20, Appendix B Table 1, Column 1.
General radiation dose rates were less than 0.5 mrem /hr in the CAVALIER area.
No violations or deviations were identified.
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Transportation (86750) > 10 CFR 71.5 requires that each licensee who transports licensed material outside the confines of its plant or other place of use to comply with the applicable requirements of the USDOT in 49 CFR Parts 170 through 189.
, Processing and shipping of radioactive waste, and other materials activat-ed and/or stored at the facility were discussed with licensee representatives.
Guidance for these activities is provided by the QA/QC Program for the UVAR Facility, revised December 1987.
The licensee indicated that no shipments of CAVALIER-related material had been made since the CAVALIER reactor had been defueled and that none were anticipated until the decommissioning of the reactor was completed.
No violations or deviations were identified.
10. Followup of Open Items (92701) (Closed) Inspector followup item 50-062/88-04-01: Make the CVE part of a procedure and provide acceptance criteria for the examination.
50P 5.7, Core Visual Inspection and S0P 11.V Foreign Material on Core, were added to the procedures. These additions satisfy the concerns raised.
(Closed) Inspector followup item 50-062/88-04-02: Change the shutdown r margin procedure to assure reactivity from experiments is always treated ' conservatively.
S0P 5.5.8, Determination of Shutdown Margins and Excess
Reactivities, was revised appropriately on November 21, 1988.
In addition. TS amendment 17 was issued to clarify that the unscrammable regulating rod is not included in shutdown margin calculations.
In addition, the stamp used in the operations logbook for the SDM/ Excess Reactivity Calculation, has been revised to implement the TS and procedur-al changes. This item is closed.
11. Exit Interview The inspection scope and findings were summarized on September 21, 1988, with those persons indicated in paragraph 1 above.
The inspectors de-scribed the areas inspected and discussed in detail the inspection find-ings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
The following unresolved items were discussed: UNR 50-062/89-03-01: RSC audit of the operations logbook and irradia-tion logbook has not been perfonned since 1985.
Whether other, useful reviews meet the intention of TS 6.2.3.(6) is unresolved, and Region II will discuss the issue with NRR prior to making a determination.
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UNR 50-062/89-03-02: Whether slippage in completing the operator requalification cycle is acceptable is currently unresolved pending discussion between Region II and NRR.
12. Acronyms and Initialisms Used in This Report ALARA-as low as reasonably achievable (with respect to radiation exposure of personnel) CFS - Code of Federal Regulations centimeter squared em - core visual examination CVE - deltaT-differential temperature disintegrations per minute dpm - ECCS - emergency core cooling system Environmental Health and Safety (Department) EHS - health physics or health physicist HP - low-enriched uranium LEU - maximum permissible concentration (of radioactive material) MPC - mrem - milliroentgen equivalent man
NEEP - Nuclear Engineering and Engineering Physics ' (US)NuclearRegulatoryCommission . NRC - i (Office of) Nuclear Reactor Regulation NRR - parts hydrogen pH - quality assurance QA - quality control QC - R/hr - roentgen per hour (licensed) reactor operator RO - Reactor Safety committee j RSC - RSO Radiation Safety Officer ' resistance temperature device RTD - shutdown margin SDM - standard operating procedure 50P - (licensed) senior reactor operator SRO - technical specifications TS - unresolved item-UNR , - USDOT-US Department of Transportation i University of Virginia l UVA - UVAR - University of Virginia Reactor l ! !
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