IR 05000062/1990003
| ML20059N100 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 09/17/1990 |
| From: | Bassett C, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059N099 | List: |
| References | |
| 50-062-90-03, 50-396-90-03, 50-396-90-3, 50-62-90-3, NUDOCS 9010100103 | |
| Download: ML20059N100 (9) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
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101 MARIETTA STREET,N.W.
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ATLANTA.GEOR0l A 30323
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SEP 181990'
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Report Nos.:
50-62/90-00 nd 50-396/90-01 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 Reactor (UVAR) and CAVALIER Reactor l
Inspection Conducted: August 14 - 16, 1990 Inspectors: h a<rebk 9/
O C. H. Bassett D6te 41gned Approved by:
bM h_kys NI7 IO E. J. McAlpine, Chief Date Signed Radiation Safety Projec\\ts Section Nuclear Material Safety and Safeguards. Branch Division of Radiation Safety and Safeguards
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SUMMARY
Scope:
This routine, unannounced inspection involved onsite raview of
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radiation protection program activities including:
radiation control,
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I environmental surveillance and monitoring, transportation of radioactive
material, and review of licensee actions regarding previously identified
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issues.
Prior to the inspection a management meeting was held to discuss.the areas of health physics, general emergencytpreparedness, operations, and issues of common interest and concern.
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Results:
Within the areas inspected, no violations or deviations were
identified. The staffing and current organizational structure were adequate to i
meet Technical Specification (TS) requirements and to implement the licensee's
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radiation protection program.
The position of Radiation Safety Officer was vacant but the licensee anticipated' that' the position would be filled by. the beginning of the semester.
Training appeared to.be adequate to meet federal regulations.
Facility contamination levels and. radiation exposure to individuals were within the local administrative limits and exposures were well
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within federal regulatory limits.
The environmental monitoring program
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appeared to be adequate to meet TS requirements.
No transportation program
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inadequacies were noted.
9010100103 900918 PDR ADOCK 05000062 O
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REPORT DETAILS i
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Persons Contacted i
L Licensee Employees
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- P. Allaire, Chairman, Department of Nuclear Engineering and Engineering Physics (NEEP)
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- R. Allen, Chairman, Radiation Safety Committee
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- P. Benneche, Reactor Supervisor / Supervisor of Services
- J. Farrar, Reactor Supervisor / Reactor Administrator
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- R. Mulder, Director, University of Virginia Reactor Facility
- A. Reynolds, Designated Chairman, Reactor Safety Comittee Other Organizations
- G. Glennie, Radiation Safety Technician, University of Virginia (UVA) Environmental Health and Safety (EHS) Department
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- J. Gilchrist, Acting Radiation Safety Officer, UVA EHS Department
- A. Jackson, Reactor Health Physicist, UVA EHS Department
- D. Steva, Reactor Health Physicist, UVA EHS Department
- Attended Management Meeting
- Atte.ded Exit Interview 2.
Radiation Control (83743)
a.
Organization and Staffing Technical Specification (TS) Sections 6.1.1, 6.1.2, and 6.1.3 detail organizational structure, management responsibilities, and staffing requirements for safe operation of the UVAR facility.
l Through discussions with licensee representatives the inspector determined that the management responsibilities at the. facility had not cheg ed since the previous NRC inspection of radiation protection activities (Inspection Report No. 50-62/89-01).
However, the licensee had made a change in the organization structure as outlined in the TS.
The licensee had submitted a TS. change to' place the Reactor Health Physicist (RHP) in the NEEP Department.
Previously the RHP had been in the UVA EHS Department and had reported to the head of that department.
After this TS change had been made, circumstances changed and the licensee requested and received a TS change placing the position of RHP back in the UVA-EHS Department.
Another change was also implemented which allowed the licensee to have various people fill the position of RHP so that more than one person from the UVA EHS Department was familiar with the'UVAR-facility and operations.
This appears to have been a positive step in providing a broader base of support for the UVAR radiation protection program.
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The inspector reviewed with cognizant licensee representatives the current staffing available to conduct routine and nonroutine radiation protection activities at the facility.
The licensee currently has four licensed senior reactor operators (SR0s) and one licensed reactor operator (RO) who assist in minor radiation
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protection activities such as self monitoring and decontamination of
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areas found to be contaminated during routine surveys.
Additional assistance for the radiation protection program, as, noted in the previous paragraph, is provided by the UVA EHS Department.
The Radiation Safety Officer (RS0), the personnel. filling the RHP position, and radiation safety technicians are available to support the program.
The RSO provides oversight of the program while the RHPs assist in coordinating the program to ensure that all aspects of radiation protection are performed. The radiation safety technicians conduct routine contamination and radiation level surveys at the.
prescribed frequency. The RHPs and radiation safety technicians also provide coverage during certain nonroutine operations.
The inspector noted that the organization and staffing levels, utilizing UVAR operations personnel and UVA EHS Department personnel, appeared adequate to conduct routine and nonroutine radiation protection activities for the facility.
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Audits and Management Evaluations
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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 license.
TS 6.2.2 and 6.2.3 detail RSC membership and qualifications, and meeting and audit frequency.
The RSC is required to meet, at a minimum, semiannually, to approve untried experiments, changes to the reactor, amendments and changes to the facility license TS and Standard Operating Procedures (SOPS),_ to review reportable events and operating abnormalities, and to conduct annual audits of operational records.
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The inspector reviewed the composition 'of the RSC with the licensee.
The inspector determined that the composition of the RSC was as prescribed in the TS and that the members had the appr]priate technical background as required. - The inspector also reviewed the minutes of the RSC meetings held since the <ast inspection, f rom August 1989 through July 1990. The inspector noted that, duri.19 th's-time period, the RSC met TS requirements, corducting approximately nine meetings.
The meeting minutes indicated that the issues
discussed and reviewed during RSC meetings included such issues as TS
changes, S0.59 reviews, Low-Enriched Uranium (LEU) conversion a new criticality monitoring system, decommissioning of the CAVALIER reactor, license amendments, and consideration of various experiments to be conducted.
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l The inspector also reviewed the audit that had been conducted by the RSC. The audit dealt with the QA/QC program.
No problems were noted~
by the auditors but several suggestions were made on ways to improve the program, c.
Training I
10 CFR 19.12 requires the licensee to instruct all individuals -
working in or frequenting any' portion of the restricted area in haalth physics protection problems associated with exposure - to radioactive material or radiation, in precautions or procedures to minimize exposure.
nd. in the purposes and functions of protective devices employed, applicable provisions of Commission Regulations, individuals' responsibilities, and _the availability of radiation exposure reports.which workers may request pursuant to 10 CFR 19.13.
The inspector discussed, with cognizant licensee representatives, the
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training provided to personnel who frequent the UVAR facility.
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licensee indicated that, excluding visitors touring the facility, persons spending appreciable amounts of time in the UVAR restricted
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area included R0/SR0s, experimenters, and UVA EHS personnel.
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i licensee indicated that only persons who had received the appropriate l
tr61ning and who had been badged and received a dosimeter were.
l allowed unsupervised access to the facility.
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The training required for unescorted access to the facility regarding l
- Idiation protection is provided on an. annual basis.
The training
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ulso provides a review of security measures in effect at the facility, as well as certain operational aspects of the facility.
l The inspector reviewed and verified that all persons who frequented l
the facility had the required annual health physics ' training.
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Persons who had entered the program following the initial training were required to watch a video of the original training session.
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Facility Tours - Posting and Labeling j
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10 CFR 19.11 requires each licensee to conspicuously' post current copies of (1) 10 CTE Parts 19 and 20, (2) the license, (3) operating l
procedures, and (4) Form NRC-3, in sufficient places to permit
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individuals eqaged d licensed activities to observe them on the way
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to and from any 1.
sed activity location..
If posting of'the
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documents specifka is not practicable, the licensee may post a
.j notice which describes the documents and states where they may be-
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examined.
During tours of the facility, the inspector noced that the applicable
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documents and/or references to their locat19n wre posted at the j
entrance to the reactor control room.
The costed documentation
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indicated that copies of regulations and procedures were maintained'
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in the rea' tor supervisor for administration's office.
10 CFR 20.203 specifies the requirements for posting radiation areas, high radiation areas,- and.. labeling containers of radioactive materials.
Nsting of entrances Linto the restricted area and the labeling of Jatainers within the' restricted area were reviewed.
Postings of areas and labeling of radioactive material. appeared to be adequate and in compliance with applicable regulations.-.
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Surveys 10 CFR 20.201(b) re such surveys as'(1) quires the 1lcensee to make or cause to be mademay be regulations 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.
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S0P 10.4, Facility and~ Environmental Surveys, dated November 1970 (as revised), details radiological surveys to be conducted within-the UVAR restricted area.
L During a review of the various requirements specifiedtin the SOP,-the L
inspector noted that controlled areas.were required.to be surveyed on
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a-weekly basis.
Discussions with various licensee representatives as to the definition of what a controlled-area; was - revealed that-there -
were various interpretations-of.what this term meant. -Although the l
inspector did not note any problems due tof improper or inadequate-surveys that may 'have resulted '.from these apparent differing interpretations of the meaning of a controlled area, the licensee agreed to evaluate this issue and redefine the term as'needed.
The: inspector. reviewed sele
! UVAR. restricted area radiological survey -results.. Surface contamination levels were generally below the ' administrative limit of 50 disintegrations per' minute.per one-
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hundred square centimeters (dpm/100'cm2).
Wher. contamination levels.
above this limit was noted during routine surveys, an operator was assigned to clean the area.
Occasionally an experimenter was asked to clean the area he had been working in, which had apparently!become L
contaminated as a result of the experiment.. General area radiation levels were noted to be less than 0.5 milliRoentgens per hour-(mR/hr)
when the reactor was not operating'end ranged from less than 0.5 to
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approximately 5 mR/hr in the reactor ' room and in the ground level
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. area surrounding the reactor.
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Airborne particulate concentration survey resultis were also examined;.
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These levels'were generally well below twenty-fivei
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percent of a the Maximum Permissible - Concentration _ (MPC) limits
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specified in 10 CFR Part 20, Appendix B, Table 1, Column 1.
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External Exposure-10 CFR 20.101 delineates the quarte cadiation exposure limits to
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the whole body, skin of the whole oudy, and the extremities for-individuals'in restricted areas..
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The inspector rev'iewed-and discussed the' exposure records of persons
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working in the. UVAR restricted area-during 1989 and from January 1 through dune 30, 1990.- Personnel exposure measurements were made using thermoluminescent _ dosimeters (TLDs) provided by a vendor.
Vendor specifications reported a detection-limit' of 15 millirem i for the dosimetry provided.
The highest exposure reported fore
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as 155 mrem.
This had been received by 'a researcir scientiste i
engaged in a neutron activation analysis project.
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of the remaining annual cumulative ~ exposures for the other'
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UVAR aw.tions personnel and staff totaled less than 20 mrem each.
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Ducir" M90 through the end of June, the highest exposure was Tro rtely 76 prem,'again' received'by the person engaged in the-
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.i ar.tivation analysis project.
l Nn Whtions or dt.viations were-identified.
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F.n.c m mental Monitoring (80745)
Enviro" ental Reports
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. -ing' the activities of the reactor facility during the
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Each report shall include.a summary of the
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,id amount of radioactive gaseous, liquid and solid' effluents ed or discharged to the environs beyond.the effective control
>r ne licensee as measured or calculated at or prior to the point of
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sush release or discharge; environmental surveys performedeoutside l
the facility and exposures received by facility personnel and -
visitirs; and a sununary of radiation and contamination surveys perfo med within the facility.
The inspector verified that an annual report-was prepared and issued by the licensee in accordance with applicable TS: requirements.
Details of the report are discusced in subsequent sections of this paragraph.
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Ef'luent Releases
TS 3.4.21 requires that Lthe activity of liquids released beyond-the
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site boundary shall not~ exceed 10 CFR Part'20 limits.
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c% bete d 36 waste tank releases with an average radionuclide
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concentration of 2.2E-8 microcuries per milliliter (uC1/ml).
Total
" gross beta acib'ity released during the year was 550 uC1.
Total liquid volume releestd was 6,500,000 gallons.
Total Tritium activity
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released was 18 millicuries (mci) and the average Tritium release concentrat'on was 7.2E-7 uCi/ml.
The concentrations released were within the limits! specified in 10 CTR 20, Appendix B, Table II, Column ~2.
The inspector also verifico the analyses of. monthly environmental water samples collected ct selected upstream and downstream locations relative -to the VVAR' facility release ~ point.
j The results of these' analyses were within regulatory limits.
Gaseous effluent released was approximately 1.98 curies of Argon-41 i
(Ar-41).
For 1989, the licensee continued to rely on-a calculated-
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estimate of the maximum concentration of Ar-41 produced during normal operations.
The licensee informed the inspector that the Department -
of Energy had notified them that monies had been allocated for the purchase of a stack monitor for the facility.
This should enhance the licensee's environmental monitoring program.
No violations or deviations were identified.
4.
Class II Operations - CAVALIER Reactor Operations (40750)
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Logs, Procedures, Requalification-Training, and Experiments
l Through ' discussions with the licensee and review of the annual
. report, the inspector determined'that the licensee had decided not to operate the CAVALIER reactor in mid-1987. A dismantiing plan had been submitted to the NRC in November of.1937 and a possession only license applied for regarding the CAVALIER.
The licensee then l
proceeded to unload the core and partially dismantle the operating mechanisms involved.
The NRC, however, had not approved = this
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approach and requested that the licensee consider decommissioning the' reactor instead. =The. licensee -drafted a decommissioning plan which was reviewed and approved by the Reactor Safety Committee and forwarded to the NRC for-approval.
The plan has not.been approved by-the NRC to date.
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 s
training for the CAVALIER reactor operators was not being conducted because of the licensee's intention to ultimately decommission the
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reactor. LWith the core unloaded,- no experiments could be conducted and none had been; performed since.the end of 1987;
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Surveillances l
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-i 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 t_o, i
make these ~ surveillance requirements applicable: only-during time
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L periods when the CAVALIER core is loaded.
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March 3,1988, and that the reactor had not been' operated since '
November'1987.
The surveillances had been postponed in accordance
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with Change No. 5 of the TS.
No violations or deviations were identified.
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5.
Transportation of Radioactive Material (86740)
L 10- CFR 71.5 requires each licensee who transports. licensed ~ material outside the confines of its plant or-other place-of use-to comply with the
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applicable requirements of 'the Department of Transportation (00T)- in'
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l 49 CFR Parts 170 through 189.
The -inspector reviewed the shipping paperwork-and records ' for selected I
radioactive material shipments made since the last inspection. With a few
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minor exceptions, all shipment records were completed,as. required.
Re ords were apparently being maintained as required as well.
No violations or deviations were identified.
6.
Licensee Actions on Previous Enforcement Matters (92702)
a.
(Closed) Non-cited Violation (NCV.)' 50-62/89-01-02:
Failure'to Have Adequate Procedures for Use of Analytical' Measurement Instrumentation.
The inspector reviewed the licensee's new 1 procedure' used - for.
L calibrating detectors, Method For' Calibrating and Checking the
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Calibration of Germanium Detectors, Rev. O, -dated January 9,1990.
The procedure or method appeared to be adequate and.was scheduled to -
be reviewed by the Reactor Safety Committee at their next meeting.-
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(Closed) Violation (VIO) 50-62/88-02-04:
Failure to Conduct Adequate.
l Surveys of Environmental Airborne Effluents to Evaluate the Extent of i-Radiation Hazards Present.
The licensee's response, dated October 3,1989, was reviewed and implementation of the-corrective actions verified. ~The licensee is
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using longer sampling tika, and longer counting times in order to reduce the Lower Limit of. Detection (LLD) to the acceptable level, t
Also, the licensee evaluated; the airborne effluents from.the UVAR facility and determined that certain-specified ~ alpha-emitters _ and
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other nuclides were not present.- They, therefore, must comply with an LLD of'1E-11 uCi/ml.
A new UVA EHS procedure or method has been.
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L written addressing environmental' airborne sampling.
This-appeared to'
be adequate.
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Management Meeting i
Prior to the' inspection, the NRC Region. II Regional Admin'istrator! and'the i
Director, Division of Radiation Safety and. Safeguards met with licensee; personnel including the Director, UVAR, -the Chairman of Lthe Radiation
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the acting Radiation Safety Officer, and other staff' members.
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discussion of the licensee's performance in various, areas including health physics, emergency preparedness, and operations was held.: Other. issues
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were also ' discussed including below. regulatory 1 concern,' 00E funding, and operator training.
NRC representatives indicated that the test, research, and training reactor program was an important one'and that the:NRC would-work with such facilities to helpRthem and have as little1 impact upon:
their program as possible.
The licensee acknowledged 'that the NRC
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provides an important oversight role and that differences of opinion will-t occur, on occasion.
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The meeting was beneficial and provided for.a 'better' understanding of the'
issues discussed.
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Exit Interview The inspection scope and results were summarized on August 16, 1990, with
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those persons indicated in Paragraph'1.
The inspector described the areas.
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inspected and discussed in detail the inspection findings ' listed.below.
The licensee did not identify as proprietary any of the material provided
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to or reviewed by the inspector.
Dissenting comments were 'not' received from the licensee. Licensee management was informed that the violations discussed in Paragraph 6 were considered closed.
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