IR 05000139/1981001
| ML20031A374 | |
| Person / Time | |
|---|---|
| Site: | 05000139 |
| Issue date: | 09/09/1981 |
| From: | Book H, Cillis M, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031A373 | List: |
| References | |
| 50-139-81-01, 50-139-81-1, NUDOCS 8109230425 | |
| Download: ML20031A374 (13) | |
Text
{{#Wiki_filter:- ' . . U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No. 50-139/81-01 Docket No. 50-139 License No. R-73 Licensee: University of Washington (Nuclear Engineering Laboratory) Seattle, Washington 98195 Facility Name: Nuclear Engineering Laboratory Reactor Inspection At: Seattle, Washington Inspection Conducted: August 5-7, 1981 [[ Inspectors: _ D4te Signed - M. Cillis, Radiation Specialist f /h/ Approved By: u2 w-o F. A. Wenslawski; Chief, Date Signed Reactor Radiation Protection Section J 6e Mn H. E. Book; Chief,, Date Signed Radiological Safety Branch , s, . Summary: Routine unannounced inspection of the Radiation-Protection, Environmental l Protection, and Emergency Planning' programs including radioactive material l transportation activities, 'a to'ur of the facility,', discussions with licensee representatives, and an examination'of personnel monitoring, survey,
material transfer, training, instrument calibration and audit records / reports.
The inspection involved,21: hours on site by one NRC inspector.
, No items of noncomplian'ce or devkations were identified.
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_ _ - - _ _ _ _ _ _ _ _ _ _ _ -. - , . DETAILS 1.
Persons Contacted
- Professor W. Chalk, Director Professor D. E. McFeron, Chairman, Reactor Facilities Advisory Coninittee
- Mr. D. Fry, Assistant Director for Facilities-Engineering Mr. Scott Swoope, Reactor Operator Mr. M. O'Brien, University of Washington Campus Radiation Safety Officer Mr. Carl Richie, Radiation Safety Monitor Mr. Jay MacLellan, University of Washington Hospital Health Physicist
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- Mr. Astor Rask, Supervisor, Electronic Engineering Mr. W. J. Munyon, University of Washington Health Physicist Battalion Chief W. R. Bartley, Seattle Fire Department Captain Snook, Seattle Fire Department, Fire Station 30 Captain Ormbrek, Seattle Fire Department, Fire Station 38 Lieutenant Ejeck, Seattle Fire Department, Fire Station 30 Assistant Chief Sterns, University of Washington Campus Police Department
- Mr. W. P. Miller, Associate Director for Reactor Operations, Reactor Supervisor
- Indicates presence at exit interview.
- Contacted by telephone.
2.
Organization, Logs, and Records The organizational structure and personnel responsible for reactor opera-tions, radiation protection program and administration of the University of Washington research reactor were unchanged from that previously reported.
The Associate Director for Reactor Operations who is also identified as the Reactor Supervisor (RS), was not present during the inspection. The RS remains assigned to the reactor and is responsible for reactor operations, reactor maintenance, emergency planning, and the radiological protection program. A part time assistant (10-20 hours per week) is assigned to assist the Assistant Director / Reactor Supervisor. The assistant performs routine tasks such as radiation and contamination surveys. The campus Radiation Safety Officer from the Environmental Hygiene and Safety group (EH&S) also provides assistance and acts as an advisor to the reactor supervisor.
Through discussions with licensee representatives and examinations of facility records, the inspector found that functions and responsibilities of licensee personnel, including members of the Reactor Advisory Committee, were consistent with the Hazards 3ummany Report and Technical Specification.
Changes in personnel assignments occupying these positions which have occurred during the past several years are not currently reflected in the administrative procedures. This concern was discussed at the exit interview.
Facility operation reports and records were examined and found to marginally document the performance of the environmental, emergency and radiation protection programs. Specific records, reports and administrative require-ments reviewed were as follows: . -
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-2-a.
Operation Logs b.
Daily reactor Startup and Shutdown Checklists c.
Survey records (radiation, contamination and effluent monitoring) d.
Instrument calibration (portable and fixed) e.
Personnel Training Records f.
Personnel Exposure Records g.
Audit Reports h.
Reactor Facility Advisory Comittee minutes i. Waste Shipping Records j. Visitor Sign-in log sheets k.
Implementing adminWrative procedures 1.
Emergency drill reports The review revealed the documentation of activities performed by the licensee was very informal, at times non-existent and portions of the implementing administrative procedures were found to be outdated. The specific problems identified are discussed in the subsequent sections of the inspection report.
No items of noncompliance were identified.
3.
Tour, General Operations The inspector toured the licensee's facility and discussed current and recent reactor operations with the staff members. Reactor operations l during the previous 12 month period were moderate. The reactor has been ' shut down since the latter part of June 1981 for the sumer school semester and routine maintenance. Resumption of reactor operations is not expected until October 1981 at the earliest.
During the tos, access control, posting and labeling, housekeeping and air sampling and area monitoring techniques were observed and discussed with the staff members. The tour revealed that posting and labeling although consis-tent with 10 CFR 20.203 and 10 CFR 20.204 appeared to be in nonconformance with paragraph 4.D.1 of the facilities operating procedures which discusses the tagging requirements for irradiated samples, reactor components, or experimental components having dose rates in excess of 5 millirem at one foot. Paragraph 4.D.1 requires that items should be stored in a shielded container and tagged.
Infonnation on the tag should include: (1)date (2) Dose rate at one foot (3) Major isotopes and (4) Estimated activity of istopes. Several shielded containers containing calibration sources did not contain the dose rates of the unshielded source or on contact with the shielded container. The licensee representative accompanying the inspector was not awara of what was stored in a shielded container located in the storage room of the reactor facility, nor was the representative aware of the radiation levels of the item, the isotope, estimated activity or the radiation level on contact with items stored within the container although the container was identified with a strip of radiation varning tape. The need to provide sufficient information to permit individuals handling or using the containers or working in the vicinity of the container to take necessary precautions to avoid or minimize their exposure consistent with
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. . -3-the "As Low as is Reasonably Achievable" (ALARA) concept was discussed with the representative. The need to provide sufficient information on containers and appraising all personnel as to the storage area of material during training provided to 10 CFR 19.12. " Instructions to Workers" require-ments was taken under advisement by the licensee during the exit interview.
During the tour it was noted that the control room, reactor room and associated facilities were defined as " restricted areas" in accordance with Paragraph II.A.2 of the T.S. and were under a locked security system as required by Paragraph II.B.6 of the T.S.
Paragraph 4.C.1 of UWNR operating procedures also define the aforementioned boundries as restricted areas for the purpose of protection of individuals from exposure to radiation and radioactive materials. The UWNR procedure requires personnel entering the re-stricted areas to wear dosimetry equipment for the purpose of measuring the dose received during occupancy times in the restricted areas. A discussion with licensee representatives revealed that dosimetry requirements were only being enforced in the reactor room. Dosimetry equipment is not currently required for entry to the control room or associated facilities such as the computer room and counting room. The licensee representative stated that the control room was defined as a restricted area for security purposes rather than for the protection of individuals from exposure to radiation and radioactive material. He also stated that the associate facilities which include the computer room and counting room were originally a part of the reactor room; however, they were subsequently separated from the reactor room by the installat5 af pennanent partitions and a locked entrance doorway. He added that the T.S. and procedures were never updated to reflect current conditions. A review of radiation surveys (beta-gamma) for the associated facilities during the period January 1981 through July 1981 revealed levels ranging from 0.02 mrem /hr to less than (()0.1 mrem /hr. Survey results for the control room ranged from 0.02 mrem /hr to a maximum of 1 mrem /hr on contact with the control room window facing the reactor while at full power operations.
The licensee representative was not aware of the neutron levels for these areas, nor could he locate any neutron survey records. The representative was also unaware of the radiation levels in the control room. During the exit the NRC inspector emphasized the need for either enforcing current administra-tive requirements or to update the T.S. and procedures to reflect current conditions. Also emphasized was the need to appraise individuals of site specific conditions during any training provided to show complianca with 10 CFR 19.12 requirenents.
Two portable alpha survey detection instruments were seen inside the restricted area that did not contain calibration labels. The licensee's calibration records did not reflect any recent calibration data for these instruments. This was brought to the attention of the licensee representa-tive. The representative stated that the instrument.s were not being used to perform surveys. The inspector recommended they be removed from the area so they are not inadvertently used.
An independent contamination check of the licensee's restricted and un-restricted areas was made by the inspector. The swipes were analyzed with .
. . -4-a NRC Model E520 Eberline survey meter, Serial-Number NRC004760, equipped with a thin window (beta-gama)- pancake probe which is due for talibration on October 9, 1981. No contamination was found.
No items of noncompliance or deviations were identified.
4.
Radioactive Material Transfers Examination of records of irradiations and of transfers of radioactive materials during the period July 1980 through July 1981 was conducted.
All transfers are made to or through the university's state license to university-researchers or outside activities. All transfers are approved by the Reactor Supervisor or:the RSO.i The RS0's group is responsible for . verifying that offsite institutions are authorized to possess radioactive materials and ensuring the transfers are accomplished in accordance with the regulations. Transfer records were well documented and appeared to be consistent with appropriate 10 CFR 20 and 49 CFR 173 regulations based upon the examination of records available at the liceasee's facilities.
No iters of noncompliance or deviations were identified.
5.
Environmental Monitoring + The licensee's environmental program which consisted of a series of film badges and TLD dosimeters at the outside perimeter of the reactor facility and on the four walls of the reactor room (as discussed in IE Inspection Report 50-139/80-04) has besn temporarily discontinued and is currently under re-evaluation by the Lampus RSO. Numerous environmental film badges and TLD dosimeters were reported as missing for the previous 12 month period. A preliminary evaluation by the campus RSO revealed that the environmental badges located external to the reactor facility were most likely confiscated by unknown individuals and as a result were net available for processing. The campus RS0 stated he has committed to re-establish the environmental program previously initiated upcn resolving the problem identified herein. No other environmental monitoring studies are performed or projected at this time.
The results of environmental records which were available during the inspection were examined. The range of doses reported at four locations within the reactor confines was from "less than minimum detectable" (10 millirem) to 40 mrem for a one month period. Results of environmental monitoring performed external to the reactor reported similar results for those months that records were available.
The need to re-establish the environmental program as committed by the RS0 and to show compliance with 10 CFR 20.105 was emphasized during the exit interview.
No items of noncompliance or deviations were identified.
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Emergency Planning ~ Drills- , ! m
,, The inspector reviewed available records associated with the licensee's , ' emergency plan. The licensee conducts emergency response drills as required by paragraph VIII.H.S of the T.S.s and provides> familiarization tours of the reactor facility for the University Police. -The last emergency drill-was held on October. 13, 1980 when emergency response times-and connunication systems for the Campus Radiation Safety Office, Hospital and Police Depart-ment were exercised.' The only~ verification available for the.10/13/80 drill
were some scribbled-notes'which were provided to the inspector by the ' Director, after a two hour search. -Subsequent discussions with the Reactor Supervisor revealed that the drills were 'not critiqued, nor were there any administrative policies defining the need for providing familiarization tours, providing training to various onsite~ and offsite activities such as the police, fire'or medical department. ~The reactor supervisor stated that-training is normally conducted on an informal basis and it may not be documented in all cases.
, The inspector held di:cussions with the campus RSO: Hospital Health Physicist, University of Washington Assistant Chief of Police and met with the local Seattle Fire Station Battalion Chief and Fire Department Captains closest to the licensee's facility.
Results from the discussions held with the Fire Departuent revealed that there is no direct interchange of information between the licensee and Fire Department except during the perfonnance of fire inspections which are conducted annually. The Fire ~ Department. attempts to assign different individuals to perform the annual inspettions so that they eventually all become familiar with the licensee's facilities. The information obtained during the inspections is passed on to remaining Fire Department personnel assigned to only one of the two fire stctions. The Fire Department maintains-records of the annual inspections.
It was apparent that there is no special effort to ensure all Fire Department personnel are provided with familiariza-tion tours of the licensee's facilities by the licensee.
A discussion held with the University of Washington Assistant Chief of Police . revealed the Police Department has a good working relationship with the - Reactor Facility. The discussion revealed that campus police personnel are provided with familiarization tours of the Reactor Facilities. Records of these tours are maintained by the Campus Police Department. The Police ._ Department has developed specific instructions for their personnel who may be required to respond.to reactor emergencies.
Documentation of these tours - are not maintained by the Reactor Facility.
A review of the Emergency Plan revealed that names and telephone numbers of response team personnel and offiste agencies identified in the Plan have not been t;pdated at any given frequency or as changes occur. Additionally, a, discussion held with the staff revealed that the Plan is not reviewed' at any giwn frequency to determine if any changes or improvements are necessary to. assure emergency preparedness is maintained. The inspector noted that sone changes in personnel ^ assignments have occurred which .. .. _ _ _ _ - _ - _ -_
. . -6-were not reflected ir. the Emergency Plan. The need to change the Plan and appraise experimenters and other involved personnel of any changes to the Plan was emphasized during the exit interview.
The inspector examined two cabinets located adjacent to the reactor room entrance which contained emergen-y equipment consisting of protective clothing, respiratory equipment and other miscellaneous items. The fact-that this emergency equipment is available is not discussed in tbc Pian nor are the cabinets conspicuously identified to alert personnel they contain emergency response equipment. The inspector discussed these concerns as possible recommendations for improving the Emergency Plan and emergency preparedness.
The reactor supervisor stated personnel are informally briefed to the Emergency Plan and on occasions the RS0 will con' ct seminars on eme-cency response; however, none of this is necessarily documented. A discussion with the staff revealed that emergency drills solely consist of testing communication, personnel evacuation (s) and response times of involved campus organizations. Drills have not been conducted to test the hospital's capabilities to handle a contaminated injured individual or response actions of the fire department. The discussions with the staff revealed that there is no effort to cross train personnel from the various onsite and offsite organizations. The oiscussions also revealed that there are no UWNR - administrative instructions / policies defining emergency preparedness training requirements.
The inspector attempted'to ascertain the status of changes to the licensee's Emergency Plan required by 10 CFR 50.54(r)-to show compliance with Appendix E of Part 50. The Director and Associate Director stated they were aware of the recent change to Part 50;.but,'as yet had not taken any steps to ascertain what impact it will have on their facility. Copies of the Part 50 change and Regulation Guide (R.G.) 2.6, " Emergency Planning For Research - Reactors" were provided to the licensec by the NRC inspector. The NRC inspector recommended to staff members the license'e should start action to evaluate the impact that changes required by Part 50 will have on their Facility. The licensee agreed.
No items of noncompliance or deviations were identified.
7.
Effluent Monitoring The reactor's ventilation system is designed to provide maximum assurance against exhausting any radioactive gaseous effluents and/or particulates to the environment. The exhaust air is filtered before it leaves the reactor room with a 10,000 CFM ventilation system which exhausts to the environment via a discharge stack. The stack is monitored continuously ror gaseous and particulate releases. Rate meter readouts for these monitors are located at the reactor console. The monitors are calibrated semi-annually in accordance with licensee's maintenance procedures. The last calibration was performed in May 1981.
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, , ' . -7-> The air in the reactor room is# onitored for particulate activity at four ' n (4) different locations in the reactor facilities.. restricted areas. One j-sample is changed daily ~and the others are changed and analyzed on a weekly l schedule.
, ) Argon-41 releases are monitored and quantified via the stack monitor. The
rate meter and an integrator.are located at the reactor console where the operator maintains surveillance during operations.
A review of particulate samples collected and analyzed during the_ past 12 ~ month period was conducted. Results showed levels averaging (2.x In-13
uCi/ml gross beta and <2 x 10-14 uCi/ml gross alpha activity during normal' reactor ope'ating periods.
i An examination of samples of Argon 41 releases indicated that the average ' dai y release during reactor shut down periods were on the average of(4 x 10-J uCi/ml to (3 x 10-8 uCi/ml when the reactor was operational. The - ' low end of the range is a conservative value which reflects the integrated value on days when no. reactor operations took place and is principally the i background counts that are not subtracted in the calculations. The average i release rate for the previous six to seven weeks have been on the order of (4 x 10-11 uCi/ml. The-calculated daily average concentrations do not-exceed the 10 CFR 20 limits.
l - Liquid effluents are collected in two holdup tanks (1440 gallon capacity tank) located immediately outside the reactor building. The holdup tank.
~ , contents are sampled and analyzed prior to being released to the sewer . system. The activity in the holdup; tanks-has been relatively low; in the 10-9 uCi/ml range. The holdup tanks receive effluents from the reactor ' i room and chemistry room drain systems. Sampling and analysis prior to- ! discharging to the holdup tanks is required by UWNR procedures.
i Paragraph 4.D.3 of the procedure does allow an experimenter tr 'ischarge cffluents to the sanitary sewerage system provided the activity levels , , will not exceed the limits specified in Appendix B, Table 1, Column 2 F of 10 CFR 20 or ten times the limits specified in Appendix C of-10 CFR 20. - l The procedure does not provide any additional instructions'to indicate,how b the experimenter is to perform the sample analysis and record the analysis !. results for tracking purposes to ensure subsequent releases will not result { in exceeding 10 CFR 20 limits. The NRC inspector discussed the matter in !- detail with the Director and Assista'nt Director For Facilities Engineering.
The NRC ' inspector informed the Director that effluent sampling is a responsibility that should be maintained solely by.the Radiation Protection-Group. The Director thought.the procedure was in error. A subsequent =
l discussion with the Associate Director For-Reactor Operations was conducted - ! by the NRC inspector. The Associate Director stated that although the procedure was not.' clear,- all effluent sampling and analysis was being i performed by himself or his part time Radiation Safety Technician. The L ' .NRC inspector discussed these concerns at.the exit interview recommending e '- that the' procedure be updated accordingly.
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_ _ _ _ - - _ _ _ . - . . , , -8-The two 1440 gallon holdup tanks were nearly full at the time of the inspection. The last release from these tanks was conducted on February 14, 1980 as reported in IE Inspection Report 50-139/80-04.
No items of noncompliance or deviations were identified.
I 8.
Radiation Protection Program a.
General Radiation Protection Organization The Assistant Director For Reactor Operations / Reactor Supervisor is responsible for day-to-day operations of the reactor, supervises the reactor operators, reactor maintenance, scheduling and approving experiments and the radiation protection program. A part time (10-20 hrs / week) Radiation Safety Monitor is assigned from the Campus Radiation Safety Office to perform routine and special surveys, perform analysis of air, water, and swipe survey samples, exchanging of dosimetry equipment and other routine"radiction safety functions in support of reactor operations.
The campus RSO who is a member of the Reactor Facility Advisory Comittee also has line responsibility for radiological safety at the reactor facility. The RSO has two full time health physicists under his control.
One of the health physicists is assigned full time as a hospital health physicist and the second, used as a backup, provides support as may'be deemed necessary tc the RSO.
An intensive in-depth audit of Reactor Operations was recently conducted by the back up health physicist.
The organization includes a Reactor Facility Advisory Comittee appointed by the Dean of College of Engineering. The campus RSO is included as a comittee member. The Advisory Comittee usually meets annually. A recent committee meeting.was held on June 1,1981 to evaluate the findings of an indepth audit report submitted by the RS0 for an audit conducted of Reactor Operations in April 1981.
The inspector reviewed the audit report and Committee meeting minutes.
The minutes addressed all audit findings; however, no specific assignments were made to perform a follow up to verify actions are completed. Nor do the minutes identify : expected completion dates for corrective actions agreed to during the comittee meeting.
b.
Personnel Monitoring and Transfer Records Personnel monitoring records were examined for the period June 1980 to June 1981. Records for the first six months of 1981 showed one individual with 20 mrem to date and the other five or six persons who are issued film badges are in the 0 to 10 mrem range.
Irradiated samples from neutron activation and radioisotope production are. surveyed upon removal from the reactor. Radiation levels of the removed samples, which are recorded in a log, indicated radiation levels . . . . . .. ... . .
l - . . , -9-ranging from tenths of milliren per hour to 1500 millirem at a foot.
The average radiation levels ranged from 100 to 300 millirem at one foot, and in other cases the readings were taken at either six inches or three (3)! feet. There was no evidence of extremity monitoring.
This same concern was identified in IE Inspection Report 50-139/80-04.
The RSL stated the,use of remote handling devices and shielding are employed during sample removal operations and the whole body film badge results did not show any significant exposures to warrant extremity monitoring. During a meeting with the staff, the inspector discussed the possible need for the licensee to verify that extremity-dosimetry was not warranted.
c.
Radiation and Contamination Surveys 1.
Radiation Surveys Routine radiation-surveys, routine contamination surveys and surveys for determining airborne radioactivity levels are conducted on daily and weekly schedules. The surveys for determining air-borne radioactivity levels was discussed in section 7 of this report.
Examination of samples of survey records performed in 1981 showed general radiation levels in the reactLr facility ranged from 0.1 to 14 mrem /hr beta-gamma. During the past six to seven week shut down period, radiation levels were less than 0.1 mrem /hr beta-gamma. Nonnally the radiation survey consists of general area surveys obtained at four to six randomly selected locations in the reactor room. Radiation surveys of the control room, computer room, counting room or around the external perimeter of Reactor Facility are very seldom obtained. Nor are such surveys scheduled to be conducted at any given frequency to verify the shielding integrity has not been altered except when a new experiment is initiated.
Neutron surveys associated with reactor operations are only obtained whenever a new experiment is initiated. The need for performing.
neutron surveys at any given frequency to verify the shielding integrity is not specified in UWNR implementing procedures. UWNR personnel contacted during the inspection were not aware of the beta-gamma or neutron dose rates in the computer room, counting room, control room and at the external perimeter of the reactor facility.
2.
Contamination Surveys Contamination surveys of.the reactor room are performed daily.
Generally four to six randomly selected locations are checked for contamination. All results are recorded on a standard survey form.
A review of contamination survey records for surveys performed during the past year revealed swipe surveys are not normally obtained in counting room, computer room, corridor leading ~to the reactor room or at the personnel frisking station to verify contamination has not inadvertently spread to these uncontrolled areas. The licensee representative stated that cont;aination surveys are taken during
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- . ,, -10-the removal of irradiated samples to' ensure loose surface contamina-tion is not inadvertently spread. The results of job specific swipe surveys are not normally docum.ented.
It'was also noted from a discussion with the staff that personnel ' frisking primarily consists of a hands and feet survey and that experimenters are allowed to survey tools, equipment and components removed from the reactor room.
The NRC inspector ~ discussed the contents of IE Circular No. 81-07, " Control of Radioactively Contaminated Materials" with the staff emphasizing that tools, equipment and components should only be surveyed for release by qualified personnel.
It was also recommended that contamination surveys should on occasions be obtained in uncontrol, led areas in order to verify that contamination control practices are. adequate.
Contamination levels reported in daily survey records range from less than minimum detectable activity (<MDA) to 3.8 x 10-b uCi/100 cm2 beta and MDA for alpha. The survey forms used to record con-tamination surveys indicate the results are required to be recorded in units of counts per minute (cpm). The inspector subsequently learned after discussion with the staff that the results reported were actually in units of microcuries per 100 cm2 (yCi/100 cm ). d The fact that the reported units were in uCi/100 cm' was not reflected on the survey records. The review of survey records revealed that some of the data was not legible and errors, e.g. a survey reported levels of 3.8 x 105 cpm when in fact it should have been 3.8 x 10-5 uCi/100 cm2 The inspector discussed these findings at the exit interview emphasizing the need to change the survey form and results of previously recorded surveys and the need to document the data in units that are consistent with 10 CFR 20.401(b), " Records of Surveys, radiation monitoring and disposal" and 10 CFR 20.5, " Units of Radioactivity."
d.
Fixed and Portable Radiation Detection Instruments The availability, calibration and use of portable and fixed radiation monitoring equipment were examined. The licensee maintains an ample supply of portable monitoring equipment for performing beta-gama, alpha and neutron surveys. Calibration of these instruments are normally performed quarterly by the Reactor Supervisor using appropri-ate radioactive-sources. The documentation of the calibrations was poor. Some records were not legible, serial numbers were not included in all cases and data for some quarters.were not available.
The licensee : 3rmally uses two Cesium-137 sources for the calibration of beta-gama n.onitoring equipment. One is approximately 15 millicuries (mci) and the other is in excess of 200 mci. A review of the-15 mci source certification papers received from.the vendor did not indicate if the source was traceable to National Bureau of Standards or Derived as recommended by Section 5 of ANSI N323-1978, " Radiation Protection Instrumentation Test and Calibration." The licensee did not have certification papers for the Cs-137 that was in excess of 200 mci.
A discussion with the staff revealed that at one time they checked - - _- _ _ _ [
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-11-the source with a Victoreen "R" Chamber and MDH survey meters which were calibrated to a traceable NBS standard.
Documentation to sub-stantiate that this was accor+1ished was not available.
It was learned that the MDH survey meters were last calibrated over one year ago. The need for improving the calibration program to be consistent with ANSI-N323 recommendations was discussed at the exit interview.
The Campus RS0 stated that he was working with the National Bureau of Standards to establish a calibration facility on the campus that will come under his responsibilities. The RSO indicated that the campus calibration facility would be implemented upon receipt of a J.S.
Shephard calibration source at which time his group would become responsible for calibration of the Reactor Facilities portable monitoring equipment.
Fixed area radihtion monitoring (ARM,s) equipment which continuously monitor the reactor room were also examined. The monitors have audible alarais and the outputs are continuously indicated in the control room.
The calibration and operational checks appeared to be well documented and in accordance with paragraph V.A of the T.S.
e.
Posting Posting parsuant to 10 CFR 19.11, " Posting of Notices to Workers" appeared to be adequate.
Forms NRC-3, " Notice to Employees" were observed at several locations throughout the licensee's facilities.
Posting pursucnt to 10 CFR 20.204 requirements appeared to be adequate.
f.
Training An examination of the licensee's training program was conducted to ascertain compliance with 10 CFR 19.12, " Instructions to Workers".
The examination re maled that there were no administrative policies that establish the requirements and/or ' criteria for the UWNR training program. Portions of the training is provided on a formal basis; however, most of the' training is provided on an informal basis by either the Reactor Supervisor and in some instances by the RSO.
Training outlines were not available and documentation of training was in some cases very nebulous. The reactor supervisor has recently established a policy which requires that graduate student experimenters sign a fonn certifying that they have received instructions in 12 areas i of interest. Briefly the student is certifying "at he/she has received instructions to: 10 CFR 19 and 10 CFR 20 regulr ans, the facilities emergency plan, radiological protection practices and several other areas. The student obtains part of this training by attending a class that is offered at the University. The class which is called the ME 506 is one semester in length. The remaining parts of the training
not covered by the class is provided by the reactor supervisor on an informal basis. The training provided to individuals other than students is not defined nor could any documentation be located.
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. - _ - - - _ ... ,. ,, -12-Visitors visiting the facility for official business are not provided any special training nor are tr..e any administrative policies defining how visitors are to be treated. They are required to be under escort . of a qualified UWNR individual. The visitor is required to sign in and I out of the facility and if the visitor enters the reactor room he is provided with a Pocket Dosimeter (PIC). Upon leaving the visitor is required to sign out and record the exposure he received as indicated on the PIC. The inspector noted that on two occassions during the past six months visitors have failed to reccPd their dose. The NRC inspector discussed this observation at the exit interview.
No items of noncompliance or deviations were identified.
9.
Exit Interview An exit interview was held with the Director, Assistant Director For Facilities Engineering and an administrative staff member at the conclusion of the inspection. The scope and findings of the inspection were reviewed.
The following items were stressed during the exit interview: a.
Although the observations of the inspection did not reveal any health and safety issues, it appeared that the radiation protection program was weak.
The numerous observations identified indicated the need for improving the overall radiation protection program.
b.
The need to: update procedures, establishing more administrative policies to better define the program, strenghtening contamination control practices, obtaining of detailed surveys, improving training provided to workers and for emergency preparedness, implementing an effective environmental program and instrument calibration program, and maintaining detailed documentation and accountability of their activities, c.
The multiple responsibilities of the Associate Director For Reactor Operations / Reactor Supervisor should be evaluated to ensure these responsibilities did not have an effect in the implementation of an effective radiation protection program. The need for providing the Reactor Supervisor with additional assistance or assigning an individual group to implement the radiation protection program should be determined.
No items of noncompliance or deviations were identified.
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