IR 05000139/1985001
| ML20135G024 | |
| Person / Time | |
|---|---|
| Site: | 05000139 |
| Issue date: | 08/29/1985 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20135F973 | List: |
| References | |
| 50-139-85-01, 50-139-85-1, IEIN-82-49, NUDOCS 8509180066 | |
| Download: ML20135G024 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION V- -
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Report N /85-01 Docket N License N R-73 i
Licensee: University of Washington Seattle, Washington 98195 Facility Name: University of Washington.Research Reactor Inspection at: Seattle, Washington Inspection conducted: July 17-19, 1985 and the telephone discussion of
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August 8, 1985
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Inspector: 6 9 MW M 'd/29/t[
M. Cill Radiatio (fipecialist D5te Signed Approved By: d h dok g)d9/th G. P. (udps, Chief Date Signed Facilitlob Radiological Protection Section Summary:
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Inspection on July 17-19, 1985 and the telephone discussion'of August 8, 1985 (Report No.-50-139/85-01) .
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Areas Inspected: -Routine unannounced inspection by'a regionally based-inspector of facility operations, radiation protection program, environmental monitoring program, emergency preparedness program, review and audits, standard operating procedures, training, surveys, operating logs and records,'
transportation activities, reactor operator and senior reactor. operator ,
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requalification program, surveillances, experiments, organization,.Information Notices (ins), enforcement followup items, and a tour of the fac'ility. During this-inspection, Inspection Procedures 40750, 41745, 42745, 61745,'69745, 82745, 83743, 86740, 92702 and 92717'were performed. The inspection involved 17 hourg of onsite time by one ' inspecto j
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Results: Of the sixteen areas inspected; two apparent violations were
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' identified. Failure to conduct. the 1984 evacuation drill (paragraph 9(b)),
'and failure to implement the-licensed operators requalification program (see paragraph 3).
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DETAILS
, Persons Contacted ,
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K. Garland, Chairman, Reactor Faculty Advisory Committee M. O'Brien, Radiation Safety Officer (RS0)'
,*Dr. Maurice A. Robkin, Director, Nuclear Engineering Laboratory
- W. Miller, Associate Director, Nuclear Engineering Laboratory j
- D. Fry, Assistant Director, Nuclear' Engineering Laboratory M. McGee, Radiation Technician R. M. Kleiven, Captain Patrol Division D. Smith, Reactor Operator '
S.-Hoffman, Reactor Operator 1
- Denotes'those individuals attending the exit intervie l Organization Records and Logs ;
i The University of Washington (U of W) Nuclear Engineering Laborator organizational structure was examined. Additionally, on a sampling basis, the inspector examined the following logs and records completed sin-e the last inspection: Reactor Operations Log Book , Facility Maintenance Log Book l Reactor Startup Check Sheets Reactor Operating Record Sheets and 1984 Annual Reports I Radiation Monitoring Records l Review and Audit Reports ' Reactor Systems Calibration Records j Training Records ; Reactor Operator Requalification Program Records' l Operating Procedures i Experiment Review and Approval Records CFR Part 50.59 Safety Evaluation Reports The results of' the log and record reviews.are provided in other paragraphs of this inspection repor j The licensee's organizational structure has remained unchanged since the
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last inspection except for reactor operator turnove Presently there are three Senior Reactor Operators (SR0s) and three reactor operators (R0s). Reactor Operators Requalification Program Discussions were held with the licensee's staff and records related to reactor operators requalification program, including periodic and annual
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examinations, were examined to verify the program is being implemented in
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accordance with the program approved by the NRC on October 9, 197 l
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, -r The program is designed to meet the requiremeats set forth in 10 CFR Part 50.54 (i-1) " Conditions of License" and 10 CFR Part 55, Appendix A,"
Requalification Programs for Licensed Operators of Production and
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, Utilization Facilities."
The approved requalification program requires the Director of the facility to prepare and administer a written examination for all R0s and SR0s in the first quarter of each year. -The approved program also requires:
On-the-job training, in that licensed SR0s are required to supervise a minimum of 10 reactor checkouts, reactor startups and shutdowns during the term of their licens In addition, each SR0 is required to actually perform a reacter startup and shutdown at least once per year under the direct surveillance of the Director or his delegated representativ *
Each licensed R0 and SR0 is required to review all abnormal and emergency procedures at least once per yea The licensee's operating staff consists of three Senior Reactor Operators (SR0s) and three Reactor Operators (R0s). The following observations were noted:
' One SR0 who had received his license on May 2, 1984, has not performed an actual startup or shutdown since he received his licens At least two R0s failed to certify their review of the facilities emergency plan and emergency procedures in 1984. The inspector was unable to determine if the plan had been reviewe The annual examination for 1985 was not prepared by the facility Director as required by the approved requalification program. An open book written examination was prepared by one of the other two SR0s sometime during the first quarter of 1985. Discussions with the licensee's staff revealed that none of the written examinations had been completed and graded as of the conclusion of this inspection on July 19, 1985. As of July 19, 1985, one SR0 had the examination since the latter part of March 1985 had not started it, another R0 had completed approximately 50 percent of the examination, and another SR0 who had prepared the exam had completed it; however, the examination had not been graded as'of July 19, 198 The above observations were brought to the licensee's attention during the inspection and at the exit interview. The facility Director informed
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the inspector that the requalification program requirements would be enforce 'The. inspector informed the licensee that failure to' administer the R0s and SR0s written examination during the first quarter of 1985 was an apparent violation'(50-139/85-01-01).
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' 4. Review and Audit The inspector examined the licensee's review and audit program required
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by the Technical Specifications,Section VIII.G. Review and audit functions of reactor activities are accomplished by the Reactor Facility -
Advisory Committee (RFAC).
Discussions related to this topic were held with the Chairman of the RFAC. Committee minutes and audit reports covering the period between 1982 and 1985 were also reviewe The examination disclosed that the licensee's review and audit program was consistent with the Technical Specifications. Methods for improving the effectiveness of the program were brought to the licensee's attention during the exit intervie No violations or deviations were identifie . Surveillances The inspector selected surveillance procedures and records: of completed surveillance to verif their. adequacy and conformance.with the Technical Specifications ,Section III, " Reactor. Systems". 'and'Section V, Radiation Monitoring System". The following .TS related surveillance parameters were reviewed: operability tests of interlock systems (identified in Table I of the TS, control blade' drop time' tests, reactivits. insertion
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rate and reactivity worth of each control bl'ade; saf' tye pystem operability tests identified in Table IV of the,TS,_and,ca'libration checks of'the radiation monitoring systems identified'in Section V of the, T *
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.;,.4I* s From this examination, the inspecto'r-concluded that,no limiting conditions for operation, design. dondition', ogilimiting safety settings were exceede ,
No violations or deviations were identifie ~
6. Experiments
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The licensee's reactor -experiment program has' remained essentially unchanged since the previous inspection. No new or special experiments had been performed since- the previous inspection. Selected records were examined and were found to be consistent with approved experiment
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procedures by cognizant licensee personne No violations or deviations were identifie . Procedures Technical Specifications,Section VIII.(H) requires that the U of W reactor facility be operated and maintained in accordance with approved written procedure ,
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The inspector verified that the types of procedures identified in the TS were available for use by the licensee staff. The inspector also verified that the review and approval of procedures were accomplished in accordance with the T The inspector reviewed on a selected bases, the following procedures: Startup Operations Fuel Handling Radiological Controls 4 Maintenance Experiments . Emergency Plan -
The procedures appeared to comply with all of the applicable requirement No violations or deviations were identifie . Radiation Protection Program + Surveys The lio'nsee's health physics monitoring (surveys) program associated with reactor operations was examine Direct radiation measurements, contamination, and airborne survey records for the period January 1983 through June 1985 were reiiewe The inspection disclosed that the health physics monitoring program
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at the Argonant reactor is accomplished by the Campus Radiation Safety Office staff. Surveys consisting of, direct radiation measurements, contaaination (swipe) checks, and for airborne concentrations are performed on a daily schedul The review of survey records disclosed that radiation, contamination and airborne concentration levels were consistent with the levels identified in the licensee's annual report The inspector noted that the survey records were not being reviewed in accordance with the licensee's administrative policies. None of the review signatures on the survey records had been signed by the licensee's staf Insignificant mathematical errors in the determination of Argon-41 airborne concentrations were observe The above observations were brought to the' attention of the licensee's staff and was discussed at the exit intervie In discussions with the Campus Radiation Safety Officer and licensee's staff attending the exit interview, the inspector described specific areas for improvement. The inspector was informed that the licensee's staff would evaluate the inspector's
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observations for the purpose of improving their health physics monitoring progra The inspector concluded that the licensee's health physics monitoring program appeared to be consistent with 10 CFR Part 20.201, " Surveys" and 10 CFR Part 20.401, Records of Surveys, Radiation Monitoring and Disposa No violations or deviations were identified, b. Personnel Monitoring The inspector verified that the licensee's personnel monitoring program is consistent with 10 CFR Part 20.101, " Radiation Dose Standards in Restricted Areas; 10 CFR Part 20.103, " Exposures of Individuals...in Air In Restricted Areas", 10 CFR Part 20.104,
" Exposures of Minors, and 10 CFR Part 20.1, " Purpose" (e.g., ALARA).
A review of personnel monitoring records for the period of January 1983 through March 1985 was conducted. The review disclosed that no one one the licensee's staff has received any exposure for the period involve No violations or deviations were identifie c. Posting and Labeling The inspector verified that the licensee's posting and labeling practices were consistent with 10 CFR Part 19.11, " Posting of Notices to Workers" and 10 CFR 20.203, " Caution Signs, Labels, Signals and Control '
No violations or deviations were identifie d. Training The licensee's training program for assuring compliance with 10 CFR Part 19.12, " Instruction to Work'ers" was examined. Training lesson plans and training attendance records were reviewed as part of the examinatio The inspector concluded that the 1 densee's' training . program for non-licensed personnel is consistent with the regulatory progra Noviolationsordeviationswereidentifde e. Transportation' Activities The licensee transfers possession of any material to be shipped to the University's State of Washington by-product material license prior to shipment. All such shipments from the reactor facility are accomplished under the cognizance of the Campus Radiation Safety Offic !
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No violations or deviations were identifie Environmental Monitoring Program The licensee's environmental monitoring program for. assuring compliance with 10 CFR Part:20.106, " Radioactivity in Effluents to Unrestricted Areas" was examine o AnArgonmonitorisprovided'a'nd[usedasrequiredby-the-Technical
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Specification, Section Additionally, all liquid effluents are sampled prior to their release to'the'U of'W sanitary sewer syste Additional' environmental. checks of7 direct radiation measurements are made..with an array of eight' sets of.thermolumin~escent dosimeters (TLDs) that-are positioned around the facility on the plaza and
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promenade deck Licensee records related to Argon-41 and liquid effluent releases, and direct radiation measurements were reviewe The examination disclosed that the data was consistent with
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information provided in the licensee's annual reports for 1982,,1983 and 1984. Argon-41 releases for 1985Jto_date was 14.534 Curies. A
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total of 1440 gallons of liquid effluents, having a total of 0.04 microcuries of activity was released to'the environs in'198 The^1icensee concluded that the environmental monitoring program gave no evidence of changes in the environs due to reactor operation '
~ Portable Instrument Calibration-An examination of the licensee's program established for the calibration of portable radiation detection instruments was
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conducted. Appropriate calibration records selected instruments that'were available for use were reviewe ~
The inspection disclosed-that the licensee's calibration program appears to be consistent with ANSI N323-1978, " Radiation Protection
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Instruments Test and Calibrations".
No violations or deviations were identifie h' . Solid Was'te:
' Solid radioactive waste l generated at the facility are kept to a minimum. Radioactive solid wastes are transferred to the
' University's State of Washington license for ' disposal through the campus = Radiation Safety Office.- -
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No violations or deviations were identified)
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9. Emergency Preparedness ) - Emergency Plan -
The licensee's capabilities for responding to emergencies as described in its Emergency Plan of July 3, 1984, and for demonstrating compliance with 10 CFR 50.54(q) and Appendix E of 10 CFR Part 50 was examine The examination included a review of the plan and the plans implementing procedures, review of applicable records, discussions with the campus security and reactor staff, and a visual inspection of the emergency equipment identified in the plan was conducte ,
The examination disclosed that the licensee conducted an annual drill on March 28, 1985,- pursuant to Section 10.0, " Maintenance of Emergency Preparedness" of the approved emergency plan. The results of the drill were critiqued as required by the pla A video tape was prepared by the reactor staff for the purpose of providing emergency preparedness training to University Police Department staff. Additionally, the plan commits the licensee to have at least two members of the staff trained in CPR ar,d first-ai Other commitments with respect to training of the reactor staff and of fsite personnel are identified in Section 10.0 of the plan. The
' inspector observed that the licensee has not established a system for assuring that the training commitments identified in the plan are adhered to. It was fortuitous that two members of the reactor staff had current CPR and first-aid trainin The inspector brought the above observations to the licensee's attention at the exit intervie No violations or deviations were identifie Technical Specification Required Drills Technical Specifications, Section-VIII.H.5 requires that annual evacuation drills for facility personnel shall be conducted to assure that facility personnel are familiar with the emergency pla Discussions with the facility staff were held and an examination of licensee's records related to this topic were conducte The examination disclosed.that an annual evacuation drill was not
. conducted-in 198 o The inspector informed the licensee that failure to conduct annual evacuation drills pursuant to Section VIII.H.5 of the TS was an apparent violation (50-139/85-01-03).
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10. Licensee Action on Previous Inspection Findings Enforcement Item (Closed) (50-139/83-01-01) Inspection Report 50-139/83-01 identified that tha licensee had failed to calibrate the flow measuring device on the Argon-41 gaseous effluent monitor as required by the TS. The licensee's actions described in their
- response of November 9,1983, was examined and found to be satis factory. The inspector was informed that the procedure used for performing the calibration was in the process of being revised to inclede the method and frequency for accomplishing the calibrations. This matter is closed (83-01-01).
~ Follow-up Item (Closed) (50-139/83-01-02) Inspector concerns related to the adequacy of procedures used for accomplishing the calibration (s) of all effluent monitors was identified in Inspection Report 50-139/83-01-02. Actions taken by'the. licensee with respect to this item were reviewed and found. to be satisfactory. This matter is
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closed (83-01-02). -
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No violations or deviations were identifie s -
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11. Licensee Evaluation of Information. Notices' (ins) +, ,
, t An examination was accomplished for the purpose of' determining ~of IE Information Notices were routinely evaluated lby-the lichnsee's s'taff for applicability of activities conducted at the' U 'o f W research reacto . +
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The examination disclosed that the licensee'h'a's not established a system for tracking and documenting their evaluations of ins. No records were maintained to reflect which ins were received and.p reviewe ,
For example, paragraph 2 of Inspection Report 50-139/83-01 identified that a Copy of IE IN 82-49, " Correction for Sample Conditions..." was provided to the licensee for evaluation. A discussion hel <ith the licensee's staff with respect to this IN, revealed that.thece was na documentation available to reflect if the IN.had been evaluate The inspector informed the licensee's staff of the purpose for issuing ins and the importance for determining whether or not the generic _
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information provided applied with the operation and administration of activities at the reactor. Thel inspector'added that the NRC would expect licensee's to implement appropriate corrective actions to circumvent a similar problem from occurring at their facilit The licensee informed the inspector that a system for tracking and documenting their evaluations would be develope .
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No violations or deviations were identified. -
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12 '. ' Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on July.19, 1985. .T he
. inspector summarized the. scope and findings of the inspection. The apparent violations discussed in paragraphs 3 and 9 were brought to the licensee's attentio The inspector informed.the licensee that the following areas were in need of improvement:
~ Reactor operators and Senior Reactors Operators requalification program (see paragraph 3). 'EmergencyPreparednesstraining[ program (see' paragraph 9(a)).
' Radiation monitoring, e.g. , surveys. (see paragraph 8(a)), Review of IE Information Notices '(see. paragraph.11).
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