IR 05000123/1990001

Insp Rept 50-123/90-01 on 900813-14.Violation Noted But Not Cited.Major Areas Inspected:Followup on Previous Insp Items, Organization,Logs & Records,Review & Audit,Functions, Requalification Training,Procedures & Emergency Planning

ML20059F726
Person / Time
Site:	University of Missouri-Rolla
Issue date:	08/30/1990
From:	Dunlop A, Grant W, Jackiw I, Mendonca M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059F721	List: IR 05000123/1990001 ML20059F717
References
50-123-90-01, 50-123-90-1, NUDOCS 9009110330
Download: ML20059F726 (12)

Text

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U.S. NUCLEAR REGULATORY COMMISSION ~

1. i REGION III ,

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  ,. Report No. 50-123/90001(DRP)    * -
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Docket No. 50-123 -License No. R-79: j LLicensee:l University Of Missouri - Rolla ,

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  . Facility Name: Rolla Reactor
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TInspection.At: Reactor Building, Rolla, Missouri j

Inspection' Conducted: August.13-14, 1990~  ! Inspector: 6%L 6J/ A. Dunlop,'J Date

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W. B. Grant 154*he .i Date

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  : Approved By: I..N. Jackiw, Chief d    O ?#-fe Reactor Projects Section-3A'   Date  1
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Inspection' Summary

Inspection on August 13-14, 1990 (Report No.'50-173/90001(DRP);

  ' Areas-Inspected: Routine, unannounced inspection to review actions ^on:'. r followup on. previous..in'spection items (9P701); organization, logs, and   !
. records; review and audit functions; requalification training; procedures;   *
  ; radiation surveillance;.' experiments; controls;  fuel' handling 40750);

radwaste management (activities; emergency activities transportation planning;

 . .(86740); and periodic and special reports (90713). 1
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  >Results: Of'the 13. areas inspected, one non-cited violation was identifie 'This pertained to the failure to perform a surveillance test on the reactor   .i-period scram safety channel prior to each day the reactor was operated (see   4
  'Paragraah 8). .The facility is being properly maintained and operated'in an
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9009110330 900s3o PDR

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y  ; DETAILS 3 Persons Contacted

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University of Missouri - Rolla

  *A. E. Bolon, Reactor Director
  *D. W. Freeman,-Reactor Manager
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L*R. Bono, Director, Environmental Health / Risk Management and  ! " Health Physicist- .

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  *C. Barton, Electronic Technician / Senior Operator
  .*L. Pierce, Senior Secretary
  * Denotes those attending the exit meeting on August 14, 1990.  ;
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n, 2; j neral (40750) l This inspection', which began on August 13, 1990, was conducted to examine the research reactor program at the University of Missouri

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  - Rolla. The facility was toured shortly after arrival. The ceneral -

housekeeping of the facility is goo ~ . it -

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The: reactor is used for classroom instruct % , training, research, and irradiation service. The licensee provides tours of the facility -

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to-over 2,000 visitors a year. The fa';ility intends to convert,to low

  , enriched uranium (LEU) fuel when fund *, from the Department of Energy ,

become available (scheduled 1991). , No-violationsfor deviations were identifie . Action on Previous Inspection Items (90701) . (Closed) Open Item (123/85002-01):- Requalification training +

  . evaluations not performed in'accordance with approved progra . Senior Operators (S0s) were performing thel operator evaluations ^
  .where'es the Requalification Trainina Program required the Reactor Supervisor or Training Cocrdinator to do the evaluations. The
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licensce has revised the program to state that the evaluation can-.

'   be performed by an f,0. This item is close ,
 , . (Closed) Open Itcm (123/87001-01): No prior NRC approval on changes to the operator Requalification Training Progra r Region III ;equested guidance from the Office of Nuclear Reactor a  Regulations (NRR) as to whether the changes to the program

• identified by the inspector required prior NRC approval before being implemented. Per an NRC memorandum, J. N. Hannon to W. D. Shafer, dated. February 19, 1988, NRR determined that the changes in question did not require prior NRC approval per 10 CFR 50.54 (1-1). As such, this item is close ,

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f =- 4 m - y c.- '(Closed) Violation (123/87001-02):- Failure to follow Standard Operating- Procedures- (SOP)' 600, Laboratory. Rules', (Technical . -l Specification' 6.3~ violation) regarding not- eating, drinking, and , smoking in the reactor bay area or the counting room :or while i handling radioactive materials and bypassing the frisker station L

'. when leaving <the bay area. The licensee has made certain additions and changes to SOP-600'in order to clarify the purpose of the rules, >

 *:;hich prohibit eating, drinking, and smoking in_the reactor bay and r the counting room and to add a section about use of-the frisking-station.- The ins)ectors reviewed the revised SOP and made observations in tie licensee's facility which indicate the  i corrective actions have been effective. . See Paragraph 13 for  :

additional discussion. This item is close r (Closed) Open Item (123/87001-3): Desirability of h'aving 3 independent audits performed of-reactor health physics activitie ; and that written responses be made to audit findings / recommendation '

 'The inspectors reviewed the most recent' audit of the facility that ;

was conducted April 3,1990, by members of the Columbia Research Reactor staff. Written responses to the audit findings / recommendations .

 -have been completed. The Rolla Reactor Manager stated that this policy .!

will continue. This item is close ,

       ! (Closed) Open Item (123/87001-04): Licensee does not verif ventilation system flow rates listed in Technical Specification 3.5 (4,500 cfm), which requires a ventilation fan to be operating when-the reactor is at full power. Technical Specification 4.5 n surveillance testing for the ventilation: system only requires e l        ;

i visual: monthly check for proper operation. The licensee reviewed

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' the' design specifications of the three reactor building ventilation * fans and verified that each fan is rated greater than the 4,500 cfm ;

 , requirement. It is not a Technical Specification' requirement to l" verify the flow rates on a periodic basis, nor ,does'it appear necessary based on the ratings of.the three fans and procedural  -

r quirement to have a fan operating. ;This item is closed.

L ' '(Closed) Open Item (123/87001-05): Use of the facility portal J L 1

 ' ronitor should be improved and its. operability checked on a routine t basis. Tee location of the portal monitor has~been changed so that-workers must pass through the-monitor in order to exit the facilit Procedures for the correct use of the portal monitor heve been  .
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visibly posted at the entrance to the monitor. In addition,'the instrument is routinely source checked for operability by the Senior Electronics Technician. This item is closed.

i o (Closed) Open Item (123/87001-06): The licensee should evaluate the need for extremity dosimetry. TLD ring badges have been purchased for extremity dose evaluation of reactor personnel who

 . perform sample irradiations and reactor maintenance. This item  '

is closed.

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 ' (Closed) Open Item (123/87001-07): Desirability of collecting and  '

analyzing the constant air monitor (CAM) filter media on a routine E basis. The licensee changes the particulate filter on the CAM when ,

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particulate buildup _on.the filter reduces the air flow.- The' filters-ar'e analyzed for isotopic content and no significant activity, other - than naturally occurring isotopes have been detected.. This item is closed, s No violations or deviations were identifie . Organization, t.ogs, and Records (40750)

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 -The facility organization was reviewed and verified to be consistent with the Technical Specifications and Safety Analysis Report (SAR). The minimum
-  staffing requirements were verified to be met during reactor operation, and-fuel handling or refueling' operation The reactor logs and. records were reviewed to verify that: Records were available for inspection, Required entries were mad Significa'nt problems or incidents were documented, d.- The facility was being maintained properl The previous Reactor Manager resigned from his position at the facility in August of 1989. The position was filled in May'1990 and the new manager'
 :is'in-.the process of qualifying for an 50 license. He previously held an S0 license-at the University of Virginia reacto The inspectors reviewed operator logs, pre-startup checklists (SOP-102),
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hourly operating logs >(SOP-104),1and' secure checklists (SOP-105). The logs were' complete and of sufficient detai 'No violations or deviations were identified.' . Reviews and Audits (40750)

 -The licensee's review and audit program records were examined by the inspector to verify that: Reviews of facility changes, operating.and maintenance procedures, design changes, and unreviewed experiments were performed by the Radiation Safety Comittee as required by Technical Specifications or'SA ,r The safety committee and/or subcommittee were composed of qualified
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members-and that quorum requirements and frequency of meetings had been me , Reouired' safety audits had been conducted in accordance with Tedhnical Specification requirements and that identified problems were resolve . . - - . _ . 5 ' ., n - W _. <m . fe- =

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The Radiation Safety Committee met on a quarterly basis and reviewed appropriate issues (e.g., new experiments, NRC-submittels, conversion to-

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1.EU fuel documents). An independent audit was performed in-April 1990 by personnel from the Missouri University Research Reactor at Columbi Several comments and recomendations were made'in their report. The-license; adequately addressed these issues in a June 1990 mem ,, No violations or-deviations were identified.

( Requalification Training (40750)

  :The inspectors reviewed procedures, logs, and training records; and interviewed personnel to verify that the requalification training program
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was being carried out in conformance with the facility's approved plan and NRC regulations. The inspectors reviewed the licensee's Requalification Training Program dated May 1988 . Revision 2. The inspectors verified through documentation review that the licensee's 1989 program was complete, including ? forms for the conduct of on-the-job training, requalification examination - results, and operator assessments. 'The licensee is in the process of-completing the 1990 requalification program. No problems were noted.-

  -No violations or deviations were identifie . Procedures-(40750)

The inspectors reviewed the licensee's procedures to determine if procedures were issued, reviewed, changed or updated, and approved in accordance with Technical Specifications and SAR requirement , This review also verified:.

  - .That procedure content was adequate to safely operate, refuel, and-maintain the facilit b.- That responsibilities were clearly defined.- That required checklists and forms were use The inspector determined that the required procedures were available
  ,-to the operators and the contents of selected procedures were found'

adequate. Procedures are reviewed on an annual basis and revised as require NoLviolations or deviations were identifie '

 ' Surveillance (40750)
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h The' inspectors reviewed procedures, surveillance test schedule and test records and discussed the surveillance and preventive maintenance program with responsible personnel to verify: That procedures were available and adequate to perform tests, That tests were completed within the required cime schedul !

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* Test records were availabl The inspectors reviewed selected Technical Specification surveillence requirements and verified adequate testing was being conducted in all but one case. Technical Specification 4.2.2(1) requires a channel test of each reactor safety system channel be performed each day before the reactor is operated. The inspector noted that the reactor period scram channel (less than 5 seconds) was not being tested on the pre-startup checklist (SOP-10?). The licensee informed the inspectors that during a training lecture for the Requalification Training Program, the same deficiency was noted and a revision to SOP-10? was in progress to include this testin The licensee addressed this issue with the operators and informed them that this test should be performed prior to a reactor startup and documented in the log book as an interim process until the procedure was revised. The licensee has been in a maintenance outage and no reactor startups have been performed since the oeficiency was identifie Although the licensee had not been performing this test as required by Technical Specifications (daily), the test was being performed on a weekly basis with no identified problems. As such, there is no apparent safety significance to this issue since the chance of the channel failing to perform its intended safety function was minimized due to the weekly test Prior to the inspectors leaving the facility, the license had completed the revision to 50P-10? to include the required testing of the period scram function. This revision was reviewed by the inspectors and determined to be adequate corrective actio The failure to perform the reactor period scram channel test prior to each day of reactor operations is a violation (123/90001-01) of Technical Specification 4.2.2(1). This licensee-identified violation is not being cited because the criteria specified in Section V.G of the Enforcement Policy v.m satisfied. This item is close The licensee is in the process of establishing a schedule board that will list tests, reviews, reports, and other items with the date scheduled and date previously performed. Although meeting schedule dates has not been a problem, this will allow operators and managars to be more aware of dates for scheduled item One non-cited violation was identifie . Experiments (40750)

The inspectors verified by reviewing experiment records and other reactor logs that: Experiments were conducted using approved procedures and under approved reactor condition New experiments or changes in experiments were properly reviewed and approve . . . . . _ _ _ _ _ _ . _ _ _ _ _ _ _

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Ml ? .The experiments did not: involve an unreviewed safety. question, i 1.e..710 CFR 50.5 a bm * ,

.  - Experiments involving potential hazards or reactivity changes were identified in procedure ; Reactivity limits were not or could not have been exceeded-
,   during an experimen The inspectors reviewed the licensee's 700 series SOPS that control-requests and conduct of experiments. The reviewed records indicated that e   approvals and conduct.of exper % nts'were performed-in accordance with the procedural requirements in c11 but a few isolated cases. Several'

forms did not indicate that samples were surveyed for radiation levels

   las required. Based on the type of experiments and. associated measurements s  on' previous similar. samples, there a) pears to be no safety significanc The licensee comitted-to evaluate t1ese findings and take action,' e.g.,

staff briefing, to assure attention to detail in the completion of: required . information. The inspectors concluded this action is acceptable'and=no further action is warrante f L' No vio15tions or deviations were identified.

h l10. . Fuel Handling-(40750) h The facility fuel handling. program was reviewed by the: inspector The review included the verification of approved procedures for' fuel l

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, handling and-their-technica1' adequacy in the areas of radiation . l '; protection, critic 611ty safety; Technical Sperifications, and security plan' requirements. The inspector determined by records review and R discussions with personne1'that fuel handling operations were carried out in conformance-to procedures. The licensee moves fuel for.the

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annual control rod inspections; no concerns were identifie '

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No' violations or deviations were identifie . 11.. Emergency Planning'(40750)

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  . The' inspectors reviewed records and interviewed personnel to determine that the approved emergency plan was being carried out by verifying:
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b .- That required drills were conducted and evaluate !9 That required training-had been conducted.

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  .The inspectors reviewed the licensee's Emergency Plan dated May 15, 1989, Revision 3 and verified that the licensee complies with the plan's E ,  requirements. Specifically, the licensee performs a building evacuation

' drill'at the start of each school semester. Annual training on emergency , preparedness is provided to the operators as part of the Requalification

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 , -Tra'ning Program Environmental Health / Risk Management providen training-to campus health physicists and other local agencies (police, fire, and
=<  hospital personnel) required to respond to an event at the reacto :No violations or deviations were identifie ..y'

12. Transportation Activities (86740)

  -The-inspectors reviewed the' licensee's shipping pregram for compliance with the requirements in Department of Transportation (DOT) and NRC regulations, 49 CFR Parts 172 & 173 and 10 CFR Part 71, respectivel Material is occasionally irradiated in the reactor and transferred
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to on-campus users (normally less than ten transfers per year).

Irradiated-samples are held at the reactor facility to allow short-lived isotopes to decay, then surveyed (direct and smear) prior to being released to users. Samples for use in. laboratories on:the. university campus are transferred to NRC Byproduct Material

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License No. 24-00513-3?. Procedure SOP-604, " Release of Byproduct-Material on Campus," provides guidelines-for such transfers.-

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Records of transfers were selectively reviewed for 1989 and 1990-to date; no problems were note . .

 ' No violations or deviations were identified, a

13. Radiation Control (40750) The inspectorsireviewed-the radiation protection activities since t ~the last inspectio1.- Records were reviewed, personnel were interviewed, and observations were 'made ic verif" that radiation controls were being carried out in accordance with license and NRC-regulation Indoctrination Training All reactor-related' personnel are giver in indoctrination in radiation safety before they assume their work re gonsibilities. Additional radiation safety. instructions are provided to those who will be working

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directly with radiation or radioactive materials. Students-and new employees' receive training pursuant to 10 CFR 19.12 by viewing a video tape. . Individuals sign a form attesting to their understanding of the material presented in the tape. The video tape was viewed by the

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inspectors; no problems were noted. In addition, employees are provided

  'and instructed to review Regulatory Guides 8.13 " Instruction Concerning
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Prenatal Radiation Exposure," and 8.29, " Instruction Concerning Risks

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From Occupational Radiation Exposure," and they are tested on their understanding'of them. They are also instructed in the licensee's SOP-600, " Laboratory Rules."

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Instruments and Equipment Portable Survey Instruments The licensee appears to have an adequate supply of appropriate portable survey instruments capable of measuring beta, gamma, and neutron radiation. Most portable survey instruments are calibrated by the campus health physicist as authorized by NRC Material License No. 24-00513-32. Beta /gama measuring instruments are calibrated semiannually using a nominal 100 millicurie Cs-137 source. High range instruments (ionization chambers) are returned to the manufacturer for calibration. The two neutron measuring instruments are typically calibrated by the manufa-turer and response checked by the licensee using their 5 curie Pu-Be source. Calibration records for 1990 were reviewed; no problems were noted. The inspectors examined several instruments maintained in the reactor facility; each instrument was operable and had a current calibration sticke Area Radiation Monitors In accordance with Technical Specifications, the f acility has operable area radiation monitors located on the reactor bridge, at the demineralizer, and in the experiment room. Operability and alarm setpoints are checked daily using internal check sources; performance of these checks were confirmed by a selective review of daily operational checklists for 1990 to date. In situ monitor calibrations are normally performed semiannually using the aforementioned Cs-137 standar Frisking Station and Portal Monitor A hand held frisker is located at the reactor bay egress leading to the counting room. An area posting and laboratory rules instruct workers to frisk prior to leaving the bay area if they have been working with radioactive materials. Frisker operabi'lity is periodically verified using a check source; calibration is performed using a Cs-137 source. The licensee has one walk-through portal the facility. The monitor monitor located in the hallway contains nine conventional G.M. tubes exiting (three on each side, one for each foot, and one above the head) linked to an analog displa Personnel normally walk through the monitor when leaving the bay area, counting room, or control room to leave the facilit Personnel are ini,tructed to pause for a few seconds in the monitor and to observe the analog display. The portal monitor is routinely checked for cperability using a Cs-137 source, Air Particulate Monitor The reactor facility has one continuous air particulate monitor (CAM) located in the reactor bay. The CAM is electronically pulse checked periodicall . . . . . . . . . - - - - - - - - . . . .

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"  . Exposure Controls i

The personnel dosimetry services of- R.S. Landauer, Jr., and Co any are utilized by the licensee on a bimonthly. exchange basis. Al { nuclear retctor facility staff. members are provided with whole body

 : film badges capable of-detecting beta, gamma, fast and thermal neutron ,

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 .Self-reading dosimeters are provided to visitors, temporary workers, and .f
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 'other personnel as warranted. Extremity TLD dosimeters are provided to ;
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licensee will evaluate extremity exposure data in jeder to determine the-l future need for the dosimeters.

' I [- The-vendor's whole body dosimetry reports were reviewed for 1989 and 199 l o to date for reactor-facility workers. All annual whole body exposures were i less than 50 mrem.

L i L Pool Sampling 1 1; Pool water samples are collected every month and analyzed for tritium 1 content. The most recent tritium analysis of pool water showed a J concentration of about 3 E-6 uCi/ml; similar concentrations were determined for previob: samples. Based on this analysis and typical l pool-water usage (evaporation), less than 0.05 mil 11 curies of tritium L is released from evaporation of reactor pool water per year.

l Surveys i b' Area Surveys- l

,   Direct radiation surveys'and smear sampling are performed i j
,.  .various-reactor building areas on a. monthly basis by the he 7th '

physics staff. Special surveys are performed as needed to .aluate new or changing experiments; thermal column and beam port experiments j

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are surveyed after any modifications.- The licensee relies on their area monitors for indications of unexpected radiation-levsi j l- The inspectors reviewed records of: smear and direct surveys for.1989 l ' and 1990 to date. Smears-are counted on the licensee's gas flow proportional counter; removable contamination is rarely detected.

. L No problems were noted,

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It Air samples The f acility's CAM also functions as an air sampler. The 11 ' licensee analyses the CAM filter media on a routine basis, no ' significant activity other than naturally occurring isotopes p have been' detecte No violations or deviations were identified.

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L14. Radwas'te' ManagementJ (40750) - l

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t The" principle gaseous effluents produced are Ar-41 and neutron i activated dust particles. These are produced by the irradiation i k of the reactor pool water and to a lesser extent, air and airborne

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particles in the thermal column and the beam port. The air is swept , from the reactor bay and the experimental areas by three exhaust fans located in the roof of the reactor building. Technica ! Specifications require a ventilation fan with a capacity of at:

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least 4,500 cfm to be operable when the-reactor is at full powe ) i Each of the three fans are rated for this capacit l The licensee collects a reactor bay gas sample.with the reactor at' full power on an annual basis. .The Ar-41 concentration in the reactor i ' i bay.at full power was determined by the licensee to be-less than 2 E-B uCi/ml. TM licensee evaluates airborne releases monthly by  ; comparing opera * W ttaes of building exhaust fans and reactor power-

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to annual measta d air activity at full reactor power. The inspectors t reviewed pontM/ relenAe data for 1990 to.date. The maximum activity released was 3B v D1tcuries in May'1990 at a concentration of less-than 2 E-7 uCi/e9 tless than 50% of Technical Specification /10 CFR 20 concentration' limits) . , l Liquid-Radwaste e f All drains in the reactor bay and equipment areas lead to the I

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basement sum Thelarpstvolumeofliquidradwasteisproducedby

  : regeneration.of the dem.neralizer. Resin regenerations are initia11y' .

s - discharged into two 3N-gallon retention tanks' and allowed to decay; I '

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The contents'of the'i:anks are eventually released to the basement sump,. pumped-to.t5.e mid-level' sump, and released to the sanitary sewer system 'i analysis shows that concentrations are within-10 CFR , "; 20.303 limits. Licensee records show there were ten liquid-releases-from July 1989 through June 1990 totaling about 250 uti (gross

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y> 1 o activity) in about'6000 gallon ' g Solid Radwaste > U U The licensee generates very little solid radwaste. The wast'e-- K consists primarily'of spent resins and filters which are stored for- ! , eventual shipment to a licensed disposal facility. According to the F L licensee there are nine'55-gallon drums containing less than 4 mci "

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of Co-60/Cs-137 in storage awaiting shipment at this time. Solid , short-lived radwaste is held for decay, surveyed, and disposed of-in the sanitary landfil ' No violations or deviations were identifie f

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.$  15.' Review of Periodic and Special Reports (90713)   ;

e The inspector reviewed the following annual reports for timeliness of g submittal and adequacy of information submitted:

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Progress Report.1987-88 Progress Report-1988-89 Progress Report 1989-90

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The reports contained the information required per Technical '

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Specification 6.6.1 with the exception of several rundowns that were 4 not listed. This appears to be a problem in transcribing the information ! from the log books into-the yearly reports. The licensee does evaluat all-scrams and rundowns and documents causes in the log boo No violations or deviations were identified.,

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o 1 Violations for Which a " Notice of Violation" Will Not be Issued [ The NRC uses the Notice of Violation (NOV) as a standard method for formalizing the existence of a violation of a legally binding requiremen However, because the NRC wants to encourage and support licensees' initiatives for self-identification and correction of problems, the NRC-will not generally issue a NOV for a violation that meets the-tests of-

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10 CFR 2 Appendix C, Section V.G.1. These tests are: (1) the violation was identified by the licensee; (2) the violation would have been-

  -categorized as Severity Level IV or V; (3) the violation was reported
  .to the'NRC, if required; (4) the Violation will be corrected, including-

!z  : measures to prevent recurrence, within a reasonable time period; (5) it l1 1

  'was.not a violation that could reasonably be expected to have been  ,

1: prevented.by the licensee's corrective action for a previous violation.' ? A violation of regulatory requirements identified during the inspection '

>  for which a NOV will not be issued is discussed in Paragraph *

17. ' Exit Interview (30703) zThe inspectors met with licensee representatives denoted in Paragraph 1 during~and at the~ conclusion of the inspection on August 14, 1990. The- '

  : inspector. summarized the scope and results of the inspection and discussed the likely content:of this inspection report. 'The licensee acknowledged the'information and did not indicate that any of the information disclosed during the inspection could-be considered proprietary in natur '

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