IR 05000113/1982002
| ML20028F267 | |
| Person / Time | |
|---|---|
| Site: | 05000113 |
| Issue date: | 01/11/1983 |
| From: | Book H, Garcia E, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20028F262 | List: |
| References | |
| 50-113-82-02, 50-113-82-2, NUDOCS 8301310327 | |
| Download: ML20028F267 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-113/82-02 Docket No. 50-113 License No.
Safeguards Group Licensee: University of Arizona College of Engineering Tucson, Arizona 85721 Facility Name: University of Arizona Research Reactor, TRIGA Mark 1 Inspection at: Tucson, Arizona Inspection conducted: December 13-15, 1982
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Inspectors:
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/ / #3 E. M. Garcia, Radiation Specialist Dat'e Signed Approved by:
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//// P3 en F. A. Wenslawski, Chief, Reactor Radiation D&te' Signed Protect on Section Approved by:
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H. E. Book, Chief, Radiological Safety Branch Date Signed Summary:
Inspection on December 13-15, 1982 (Report No. 50-113/82-02)
Areas Inspected:
Routine unannounced inspection by a regionally based inspector of the radiation control program including posting and labeling, surveys, personnel radiation dosimetry, training of non-licensed personnel, instrument calibration; effluent monitoring; emergency planning. The inspection included a facility tour and a radiation / contamination survey. This inspection involved 17.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> onsite by one inspector.
Results: Of nine areas inspected, no item of noncompliance was identified in eight areas. Two items of noncompliance were identified in one area; failure to perform surveys of non-penetrating radiation and failure to maintain records of routine surveys in the same units as Part 20 (Paragraph 2.b).
8301310327 830111 PDR ADOCK 05000113 O
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DETAILS 1.
Persons Contacted
- R. H. Gallagher, Dean, College of Engineering
- R. L. Seale, Head, Department of Nuclear and Energy Engineering
- B. O. Ganapol, Reactor Committee Chainnan B. Westerman, Director Radiation Control Office
- G. W. Nelson, Reactor Director
- M. C. Young, Assistant Director Radiation Control Office
- H. J. Doane, Reactor Supervisor
- C.
K. Irwin, Radiation Control Officer B. B. Piner, Chief Radiation Control Technician
- Denotes the individuals present at the exit interview.
2.
Radiation Control a.
Posting and Labeling The inspector reviewed the licensee's compliance with posting and labeling requirements.
10 CFR 19.11 specifies certain documents that must be available for the workers to examine. That section also requires the posting of Form NRC-3, " Notice to Employees". A copy of Form NRC-3 and tte documents listed in 10 CFR 19.11 are posted on the control room bulletin board.
The inspector toured the facility and conducted an independent radiation and contamination survey. The results of the survey are described in Paragraph 5 below.
10 CFR 20.203 states requirements for the posting and labeling of radiation areas, high radiation areas and radioactive matt.ials. Although during the inspector's tour no radiation areas were identified, it appears that some may develop under certain conditions. The staff from the Radiation Control Office (RCO) conducts monthly radiation and contamination surveys. These surveys are discussed in paragraph 2.b.
Records of these surveys and discussions with the licensee's staff indicate that on some occasions radiation areas (as defined in 10 CFR 20.202(b)(2)) occur and may not be posted as required by 10 CFR.20.203(b). This situation is discussed further in paragraph 2.b below.
Since no unposted
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radiation area existed at the time of the inspection, noncompliance
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could not be clearly established. The licensee intends to review their procedures and practices in light of the inspector's connents.
This matter was discussed at the exit interview.
No items of noncompliance or deviations were identified.
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b.
Surveys 10 CFR 20.201 " Surveys" states in part that the licensee shall make or cause to be made such surveys as:
(1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may
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t-2-be present. 20.401 " Records of surveys, radiation monitoring, and
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disposal" states in part that the licensee shall maintain records
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in the same units used in part 20, showing the' results of surveys
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j required by.20,201(b).
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The inspector reviewed the licensee's survey program. The University Radiation Control Office (RC0) provides health physics support ser. vices to the reactor facility. The reactor facility is operated by the Department of Nuclear and Energy Engineering.
RC0's staff'
conduct monthly radiation and contamination surveys.
Records
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of the surveys of February 1981 to November 1982 were examined by the inspector..No written procedure exists for conducting and recording these surveys. The contamination survey consists of sampling twenty-one preselected locations. The samples are counted in a liquid scintillation counter, with a wide window setting and using a conservative efficiency. The radiation survey is made with a Geiger-Mueller (GM) type survey meter. The GM instrument was selected because of it's good sensitivity, although the RC0 staff recognizes the GM's limitation as to linear energy response.
Because of the lack of linear energy res are recorded in counts per minutes (cpm)ponse, results of these surveys After the survey is
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completed by a technician, the record is reviewed by a senior member of the RC0 staff.
From review of records and from discussions with the licensee' staff it appears that on some circumstances radiation areas may develop and be detected by monthly surveys. However, because the surveys are done with a GM and recorded as cpm the RC0 staff has failed to recognized the areas as radiation areas.
Failure to maintain survey records in the units used in part 20 represents noncompliance with 10 CFR 20.401(b).
(_50-113/82-02-01)
UARR-110 " Procedure for Performing Irradiations in the Irradiation Facilities or in the Water Outside the Reactor Core" requires that irradiated samples be surveyed for dose rate at a foot. The procedure does not specify if the survey should include non-penetrating dose rates. A form entitled _"TRIGA Irradiation Request and Material Transfer,"
Revision 2/78 calls for the Reactor Laboratory Personnel to complete part of the form. One of the items to be noted is the surface radiation reading at time of release for beta and gamma.
On December 6, 1982 a titanium sample was irradiated, identified by irradiation request #1027 sample 0002. A cadmium liner was used to prevent the activation of'Ti-51. The irradiation request does not note the contact reading for beta emissions and according to the licensee staff non-penetrating does rates were not measured.
The inspector's survey on December 14, 1982 (see Paragraph 5 below)
indicates dose rates of 1.3 mr/hr penetrating and 420 mrad /hr non-penetrating at approximately one inch. The much greater non-penetrating dose rate appears to be due to the beta emission's from Cd-115 and Cd 115m, maximum beta energies of 1.11 Mev and 1.62 Mev respectively.
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Failure to survey for non-penetrating radiation represents noncompliance with 10 CFR 20.201(b).
(50-113/82-02-02)
c.
Personnel Radiation Dosimetry
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10 CFR 20.202 establishes the requirements for providing personnel
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radiation dosimetry monitoring devices.
10 CFR 20.101 and 10 CFR 20.104 establish the requirements for maximum permissible external radiation exposures of radiation workers. The licensee has a program to meet these requirements. Permanent employees, students and other facility users are monitored with film badges.
Monthly film badges are used to measure x-ray, beta and gamma exposures and NTA film for neutron exposures.
Individuals handling irradiated samples are provided with thermoluminscent dosimeters
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(TLDs) finger rings to monitor their extremity exposure.
Radiation Detection Company is the contractor providing the dosimetry service.
Direct reading pocket dosimeters are available to users and visitors.
The pocket dosimeters used at the reactor facility are not periodically tested for response and leak rate. The RC0 has a test program for their dosimeters. The licensee's representative stated that the reactor's pocket dosimeters would be added to the test program. The RC0 test program, although incorporating a response test and a leak rate test, does not include rejection criteria. The inspector suggested that the RC0 review their program and consider the recommendations in Regulatory Guide 8.4, " Direct-Reading and Indirect-Reading Pocket Dosimeters" and American National Standards Institute (ANSI) Standard N13.5 1972 " Performance Specifications for Direct Reading and Indirect Reading Pocket Dosimeters". This matter was discussed at the exit interview.
The inspector reviewed personnel dosimetry records for the period of January 1980 to October 1982.
The exposures recorded for the whole body, extremity and skin of whole body are within the regulatory limits as specified in 10 CFR 20.101(a) and 10 CFR 20.104.
The matter of the test and calibration of pocket dosimeters was discussed at the exit interview.
No items of noncompliance or deviations were identified.
d.
Training 10 CFR 19.12 describes the instructions that must be provided to individuals frequenting the restricted area. The core of the licensee's training program for non-licensed personnel is a memorandum from the Reactor Director to all reactor users. This memorandum is provided when individuals are issued personnel dosimetry. The memorandum which is referred to as the " March 16, 1981 Memo" describes the potential for radiation exposure in the reactor facility, the individual's rights and responsibilities and some technical and administrative aspects about the dosimetry. According to the Reactor Director the infennation on the memo is supplemented by material presented in the courses the students participate in.
Females are provided with copies of Regulatory Guide 8.13. " Instruction Concerning Prenatal Radiation Exposure". The training program appears to meet the requirements of 10 CFR 19.12.
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-4-No items of noncompliance were identified.
Portable Instruments Calibration e.
10 CFR 20.201, " Surveys", requires' that the licensee perfonn evaluations of the radiation hazard that may be present.
Further, it requires that when appropriate such evaluations include measurements of levels of radiation. Although not specifically required, good practice suggests that instruments used for measure-ments be calibrated. ANSI N-323-1979 " Radiation Protection Instrumentation Test and Calibration" makes. recomendations for a calibration program. The RCO calibrates portable instruments for the reactor facility. A section of the University's radioactive materials license from the State of Arizona describes the prograat.
The section is entitled " Method, Frequency and Standards Used in Calibrating Instruments". The main points of this document are:
(1) Calibration internal not to exceed twelve months; (2) first pulse calibration, (3) calibrate at three points per scale using NBS traceable cesium-137 standard, (4) If instrument reading after adjustment is greater than 20% of the known value instrument is returned to the
" owner" with a recommendation that the instrument be repaired or replaced. According to the Director RC0 this recommendation is made in a formal letter. The inspector noted that the calibration program does not encompass a number of the recommendations 'of ANSI-N3231978 including: calibration factors for non-penetrating radiation, instrument response to an identified check source, and date that calibration is again required. The inspector recomended
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that the RC0 review ANSI N323-1978 for its applicability to the
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i University's portable instrument calibration program. This matter I
was discussed at the exit interview.
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No items of noncompliance were identified.
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Fixed Instrumentation a
The University of Arizona license requires that the reactor.be
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operated in accordance with Technical Specifications (TS) attached
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to the license. Technical Specification 3.4 " Reactor Instrumentation" states in part that the reactor shall not be operated unless two area radition monitors, the continuous air radiation monitor.
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and the reactor water monitor are operable. Technical Specification 4.4
" Radiation Monitoring Equipment" is applicable to the radiation.
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monitors listed in Technical Specification 3.4.nd requires that
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the alann set points for these instruments shail be verified prior to each day's run and the instrumentation calibrexed annually but at=
intervals not to exceed 16 months. Technical Specification 1.20-defines Channel Calibration - A channel calibration consists of comparing a measured value from the measuring channel with a corresponding known value of the frameter so that the measuring channel output can be adjusted ta,espond, with acceptable range and accuracy, to known values of the parameter which the channel measures.
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-5-The reactor staff has the responsibility for calibrating the above named monitors. The following procedures for the control of the calibration of these monitors were reviewed by the inspector:
Procedure No Title UARR 101 Procedure for calibration of area monitors UARR 104 Procedure for calibration of particulate air monitor UARR 106 Procedure for calibration of the water monitor Records indicate that the licensee serviced the radiation monitors in accordance with these procedures in 1981 and 1982. The above named procedures require only single point calibration and only single point calibrations were performed. The inspector discussed the problems with assuring acceptable responce with a single point calibration. The licensee agreed to review their procedures and practices in light of the inspector's comment. This item was discussed at the exit interview.
The reactor supervisor described what was done to " verify the alarm set points" on the radiation monitors. This action described by the reactor supervisor is basically a channel test as defined in Technical Specification 1.12, "A channel test is the introduction of a signal into the channel to verify that it is operable." The inspector commented that this verification may not assure the adequate operation of the monitors. A channel check as define in Technical Specification 1.18 would provide verification of the whole channel including the detector, something that is not currently being done.
Since the words, verify the alarm set points, are not explicitly defined, the matter was not considered to be noncompliance.
This matter was discussed at the exit interview.
No items of noncompliance were identified.
3.
Effluent Monitorina (Closed) (50-114/79-03-01) Unresolved item involving the licensee's method for evaluating the facility's gaseous releases.
The licensee conducted an experiment to determine the " worst case" concentrations and build up of Argon-41, the principal airborne radionuclide released.
The study determined that after six hours of full power 9.6 x 10-7(UCi/cc. normal operational day) the Ar-41 concentration was operation
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This concentration is about 50 percent of the limits in 10 CFR 20 Appendix B, Table 1, Column 1.
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and atmospheric dispersion are considered the concentrations released to unrestricted areas are below the maximum permissible concentration.
The inspector also noted that the conditions of the study are conservative and that the actual concentrations of Ar-41 are unlikely to reach the levels of the study. The licensee is using the data from the study
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-6-to estimate their Argon-41 releases as reported in their annual report.
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This matter was discussed at the exit interview. The inspector has no further questions regarding this matter.
No items of noncompliance or deviations were identified.
4.
Emergency Planning The inspector was provided with a copy of the recently submitted (to NRC) emergency plan. This revised plan was submitted to fulfill the requirement of 10 CFR 50.54(r). This plan will be reviewed and approved by the NRC. The licensee has established
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cooperative agreements with the RC0, the University Hospital and the University Police.
Plans are underway for a coordinated drill in early 1983. The inspector reviewed a critique of a drill conducted on January 11, 1982. This critique was submitted to the Reactor Committee.
It identified a number o# weaknesses and recomended remedial actions. The emergency preparedness of the licensee appears to be adequate for the potential hazard.
No items of noncompliance or deviations were identified.
5.
Facility Tour and Radiation / Contamination Survey The inspector conducted an independent radiation and contamination survey. Radiation levels measured were generally less than 1 mr/hr, except in the vicinity of the sample " cave" where at approximately an inch from some samples the penetrating dose rate measured was 1.3 mr/hr. Non-penetrating dose rate at the same location was determined to be 420 mrad /hr. The inspector used NRC's Eberline Ion Chamber Model R0-2 serial number 897. This instrument was calibrated on October 6,1982 and is due for calibration on January 6,1983.
The non-penetrating dose rate was determined using a calibration correction factor of 3.5.
This factor was established using the dose rate from NBS traceable depleted Uranium slab serial number S2728.
Surface smears were measured on NRC's Nuclear Measurement Corporation PC-55 windowless gas proportional counter serial number 77-2712-05.
The instrument's efficiencies for Pu-239 (41%) and Tc-99 (25%)
were used in determining the activity. No contamination above background was detected.
The identification of the 420 mrad /hr non-penetrating dose rate resulted in an item of noncompliance as discussed in paragraph 2.b.
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Exit Interview The inspector met with the individuals denoted in Paragraph 1.
The extent and findings of the inspection were presented including noncompliance associated with the recording of improper units. Other specific areas discussed are described in Paragraphs 2a, 2b, 2c, 2e, 2f and 3.
The Reactor Director was informed by telephone on January 5, 1983 of the noncompliance associated with failure to performed surveys pursuant to 10 CFR 20.201.
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