IR 05000139/1987001

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Insp Rept 50-139/87-01 on 870727-28.Violations Noted. Major Areas Inspected:Reactor Operations Program,Including Organization,Audits & Reviews,Experiments,Health Physics Program,Environ Monitoring & Emergency Preparedness Program
ML20238D773
Person / Time
Site: 05000139
Issue date: 08/25/1987
From: Cillis M, Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20238D753 List:
References
50-139-87-01, NUDOCS 8709110386
Download: ML20238D773 (10)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-139/87-01 Docket No. 50-139 License No. R-73 Licensee: University of Washington Seattle, Washington 98195 Facility Name: University of Washington Research Reactor Inspection at: Seattle, Washington Inspection Conducted: July 27-28, 1987 Inspector: ))/ , kbl,' FIcI~/

M. Cillis, Senior Radiation Specialist Date Signed Approved by: Shkh G.P.(Yuh(s,ChibT M.2g/8'/

Date Signed Facilit4e4/ Radiological Protection Section Summary:

Inspection on July 27-28, 1987 (Report No. 50-139/87-01)

Areas Inspected: Routine unannounced inspection by a regionally based inspector of reactor operations program; including organization, audits and reviews, experiments, health physics program, environmental monitoring program, emergency preparedness program, procedures, reactor operator requalification program, transfer and shipment of radioactive material, a tour of the facility and open items consisting of Information Notice evaluations, Generic Letters and followup items, and a review of the annual repor Inspection Procedures 30703, 39745, 40745, 40750, 41745, 42745, 61745, 69745, 82745, 83743, 86740, 90713, 92701 and 92702 were addresse Results: Of the fourteen areas inspected: two apparent violations were identified: failure to make notification and written reports of abnormal occurrences (see paragraph 2.G); and failure to fully implement and maintain the Emergency Plan (see paragraph 4),

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DETAILS

- Persons Contacted

  • Dr. M. A. Robkin, Director, Nuclear Engineering Laboratory
  • W. Miller, Associate Director, Nuclear Engineering Laboratory
  • D. Fry, Senior Reactor Operator R. M. Kleiven, Captain, Campus Security Department F. Moore, Jr., Sgt., Campus Security. Department Dr. A. L. Babb, Chairman, Reactor Facility Advisory Committee M. McGee, Radiation Technician II
  • Denotes those ' individuals attending the exit intervie . Reactor Operations General The inspection disclosed that reactor operations were consistent with the information provided in the licensee's annual reports of 1985 and 198 Organization The organizational structure for operation and administration of the TRIGA reactor facility remains unchanged from that previously reporte The organization was found to be consistent with Section VIII of the Technical Specifications (TS).

No violations or deviations were identifie I Experiments The licensee's experiment program has remained unchanged over the past several year Experiments performed have consisted of activation analyses in support of various research projects and I classroom laboratory wor No new experiments had been performed since the previous inspectio No violations or deviations were identifie l

- Procedures l The inspection disclosed that the licensee maintains a copy of the standard operating procedures (SOP) at the control console. A review of sclected procedures in the 50P manual was conducte The review disclosed that the manual does not contain a copy of the Emergency Plan. Procedures in the manual were issued as early as l 1971. A copy of 10 CFR Parts 19 and two copies of 10 CFR Part 20, which were also included in the manual, were dated 1965, 1968, and 1969, respectivel ! I l

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Discussions with the Associate Director disclosed that several procedures in the manual could be deleted because they are no longer performe The above observations were brought to the licensee's attention at the exit intervie No violations or deviations were identifie Changes Discussions with the licensee's staff disclosed that no changes were

made to the facility or in procedures that would require a safety evaluation be made pursuant to 10 CFR Part 50.5 No violations or deviations were identified.

" Reactor Operator Requalification Program-The implementation of the licensee's approved Reactor Operator'(RO)

and Senior Reactor Operator (SRO) requalification plan, date October 9, 1974, was examine The examination included a review of R0/SRO requalification examinations that were administered by the facility Director in 1985, 1986 and 1987. Additionally, discussions of recent changes made to 10 CFR Part 55 and of Information Notice 87-22, " Operator Licensing Requalification Examination at Nonpower Reactors," were held with the' licensee's staf The facility Director stated that IN 87-22 had just recently been receive The examination disc'losed that the licensee is working on a proposal for obtaining NRC approval for a new " Reactor Operator Requalification Program." In the interim period, the licensee plans to implement the approved requalification program dated 0ctober 9, 197 The Director stated that future reactor operators'

examinations would be administered in accordance with IN 87-2 The October 9, 1974, approved requalification program requires that a score of less than 80% in any category will require that individuals attend preplanned lectures in the relevant subject ,

areas. Additionally, the approved requalification' program requires'

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that schedules of preplanned lectures be maintained for a period of five year The examination disclosed that an SR0 failed to obtain a score of 80% in all of the required categories for examinations administered in 1985 (i.e., three categories) and again in 1987 (i.e., four categories). The individual was subsequently retested in the -

deficient categories in both 1985 and 1987. Records were available to verify the individual received personal counseling in the deficient areas following the 1985 examination; however, no records of preplanned lectures were maintained for the subsequent retesting administered in 198 In 1987, the individual was retested within i

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eight days of taking the original tes Discussions with the individual revealed he was informed of the deficient areas and was told.to use a study guide to prepare for the re-examination. The licensee's staff informed the inspector that a program has not been established to provide the preplanned lectures prescribed in their approved RO requalification progra The inspector discussed the above observations at the exit interview. The licensee stated that they did not have the time or resources to conduct preplanned lectures. The inspector informed the licensee that a violation would not be considered since the involved SRO had passed the make up test without attending preplanned lectures. The inspector added that future examinations should be administered in accordance with the requalification plan or that the plan should be change G. Surveillance The inspector examined selected records associated with the performance of surveillance activities that are prescribed in Sections III, IV and V of the T The parameters selected included control blade drop tests, power calibration checks, determination of reactivity worth of each control blade, determination of shutdown margin and the reactivity insertion rate of each control rod, operability tests of the interlocks listed in Table I and channel checks and calibration prescribed in Tables III, IV and in TS, Section The examination disclosed that the surveillance were p rformed at the frequencies specified in the T ;

The review of control blade drop test data for the period 1986 through.1987 indicated rod drop times in excess of the "one second" limit allowed by TS, Table II were observed by the licensee staf Discussions with the licensee's staff disclosed the licensee had been experiencing problems in meeting the drop times for Shim Rod No, three (SR)-3 and the Regulating Rod (RR) for the past several years. Drop times as high as five (5) seconds were estimated on July 14, 198 The Associate Director stated that a policy had been established to perform the rod drop tests prior to each reactor operatio tie added that at no time was the reactor operated with drop times in excess of the one second limit prescribed in the T This was ,

verified by the NRC inspecto A recent licensee study performed between mid-June 1987 and July 22, 1987, disclosed the bearings in the RR Control Rod Mechanism were i defective. The bearings were replaced and subsequent RR drop times have been less than 400 millisecond The licensee stated that an 0.019 inch copper shim was added to the SR-3 stanchion on which the control drive mechanism rests. The l _____________a

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i stanchion is used to connect and align the Shim Rod shaft and control drive mechanism. The subsequent rod drop time for Shim Rod ,

No. 3 have been on the order of'800 milliseconds or less. The licensee believes the shim has helped to align the Shim Rod and control drive mechanis The licensee informed the inspector that they plan to continue 1 performing the rod drop time verification prior to each reactor operatio The inspector noted that TS,Section VIII.J.1 requires that any abnormal occurrence be reviewed by the Reactor Facility Advisory-Committee, and a report of the occurrence shall be prepared, including an evaluation of the cause(s) and recommendation for appropriate action to prevent the probability of recurrenc Section VIII.J.3(d) identifies that a safety system component malfunction or other system or component malfunction which renders or threaten to render the safety system incapable of performing its intended safety function as an abnormal occurrence. Technical Specifications, Section K(1), requires a report not later than the following working day be made to the NRC Region V office and a written report within 10 days of any abnormal occurrences as defined in TS,Section VII The inspector verified that an evaluation was performed by the Reactor Facility Advisory Committee; however, the licensee did not notify the Region V office by telephone or letter and nor did the licensee's annual reports for 1985 and 1986 reflect the proble The inspector informed the licensee that failure to make the required notification and to provide a written report was an apparent violation (87-01-02).

3. Radiation Protection Liquid and Solid Wastes No liquid or solia wastes were generated from activities performed at the reactor since the previous inspectio No violations or deviations were identifie Posting The inspector verified that the licensee's posting practices are consistent with 10 CFR Part 19.11, " Posting of Notices to Workers."

No violations or deviations were identifie Personnel Monitoring The licensee's program for assuring compliance with 10 CFR Part

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20.202, " Personnel Monitoring" was found to be acceptable. A review I

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of personnel exposure records'for 1985 to 1987 did not disclose any abnormal exposure No violations or deviations were identifie i General Employee Training I The7 11censee'sl General Employee's Training (GET) program, for--

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' assuring compliance with 10 CFR.Part 19.12,'" Instructions to j

. Workers," was examined.

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The examination included the review of the' training lesson plans, hand out material and attendance' record oy .

.The examination disclosed that the licensee's GET program met 10 CFR

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19;12 requirements.

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No. violations or deviations were identifie Surveys The inspector verified that direct' radiation surveys, contamination surveys, special. surveys and surveys for airborne particulate, gaseous.-and liquid effluents are performed on a routine schedul Survey records for the period January 1985 through March 1987 were reviewe The results were consistent with the levels reported in the 1985 and 1986 annual report No abnormal results were identifie The inspector concluded that the licensee's radiological monitoring program was consistent with 10 CFR Parts 20.201 and 20.40 No violations or deviations were identifie Particulate and Gaseous Effluent Releases The principal airborne radionuclides released from the facility is Argon (Ar)-4 . Region V Inspection Reports 50-139/83-01 and 50-139/82-02 describe the licensee's program for monitoring airborne releases. The program has not changed significantly from what was described in the previous inspection reports.

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A review of airborne monitoring records for the period of 1985 through March 1987 disclosed the following:

Ar-41 releases for 1985 were reported as 28.6 curies and for 1986 releases totalled 31.8 curie "

No radioactivity in particulate form with half lives' greater than eight days had been release ._______ _____ ____ - ___ -

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6-r The licensee's staff calculated that the percent of the Maximum Permissible Concentration of Ar-41 released at approximately 10% of the limit prescribed in 10 CFR Part 20,. Appendix B. . The calculations were based on the annual average. It also considered the dilution factor of 45 allowed by the TS,Section II.B(3).

No violations or deviations were identified.

I 4. Emergency-Plan Implementation The licensee's capabilities for responding to emergencies as specified in the licensee's Emergency Plan of April 24, 1984, and for demonstrating compliance.with 10 CFR Part 50.54(q) and 10 CFR Part 50, Appendix E, was examine CFR Part 50.54(q) states in part: "

...A licensee authorized to possess and/or operate a research reactor or fuel facility shall follow and maintain in effect emergency plans which meet the requirements in Appendix E in this part...."

Chapter 10, " Maintenance of Emergency Procedures," of the licensee's emergency plan states: "The University Police training in basic radiation protection will be through a course administered by Radiation Safet The University Police will become familiar with the facility by either an onsite tour or a VCR presentation."

Discussions with the licensee's security and reactor staff disclosed that a VCR presentation prepared in 1984 for training the University Police Department staff was inadvertently erased by the Police Department staff sometime during the first half of 198 The event was never reported to the reactor staf The licensee estimated that at least eleven patrolmen had not received the training since the tape was erased. Additionally, no records of the training conducted between 1984 and the time that the VCR tape was erased were retained by licensee. The University Police were unable to state why the reactor's Associate Director was not informed of the even The inspector also noted that the licensee's internal review and audit program (see paragraph 9) does not include provisions for assuring the emergency plan is being properly implemented. A recent review of the plan was conducted by a Reactor Facility Advisory Committee audit that was completed on May 15, 198 The above observation was brought to the licensee's attention at the exit interview. The inspector informed the licensee that failure to follow and maintain in effect the emergency plan was an apparent violatio (87-01-03)

The inspector verified that the emergency supplies identified in the plan were being maintained and that the annual drills were conducted as specified in the pla i

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5. Information Notices (ins) and Generic Letters (GLs)

The inspector verified that the licensee's staff were receiving and I evaluating IN's and GL's for applicability to activities performed at the research reacto A review licensee's evaluation of GL 86-11, " Distribution of Products Irradiated in Research Reactors," revealed that the licensee does not plan.to irradiate any gemstones for commercial use. The Associate Director stated that the NRC would be informed of any future decisions' to irradiate gemstones for commercial and/or' private us No violations or deviations were identifie . Facility Tour The inspector toured the licensee's facility to check the general state of housekeeping and to verify that posting and labeling was consistent with 10 CFR Part 20.203 and that radiation monitoring instrumentation was in current calibration and were operating properl Independent radiation measurements were parformed using an Eberline, Model R0-2 ion chamber survey instrument, S/N 1694, that is due for calibration on October 21, 198 All fixed and portable radiation monitoring instruments were in current calibration and plant cleanliness was excellen No violations or deviations were identifie . Open Items (Closed) Enforcement Items (85-01-01, 85-01-02 and 85-01-03). An examination was conducted to determine if the corrective actions provided in the licensee's timely response, dated October 4, 1985, had haen implemente The examination included a review of appropriate records and procedures discussed in other portions of this report and discussion with the license's staf The enforcement items were related to failure to administer an annual SR0 j written examination, failure to review the emergency plan and failure to conduct the 1984 evacuation drill. The examination disclosed that the {

i corrective actions identified in the October 1985 response had been J implemente These matters are closed (85-01-01, 85-01-02 and 85-01-03).

8. Radioactive Material Shipments and Receipt A review of radioactive material shipping and receipt records revealed that activities associated with the transportation and receipt of 4 radioactive material were consistent with 10 CFR Part 20, 10 CFR Part 61, j 10 CFR Part 71 and Department of Transportation 49 CFR Parts 173-17.8.

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Shipments of radioactive materials are made through the licensee's State of Washington radioactive material licens No violations or deviations were identifie '

9.- Review and Audit- hl

% 'S The licensee's review And audit program prescribed in TS,Section VIII.Gy was examine "

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- The examination ihcluded discussions with the Chairman of the Reactor ,

Facility Advisory Committee (RFAC) and a review of RFAC meeting minutes" and audit reports for 1985, 1986 and 1987 to dat ""

q The examination disclosed that all of the audits of reactor operatioh's for 1985,'1986 and 1987 have been performed by'the same individual, the

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Radiation Safety Officer, even though other RFAC members are availabl .The inspector emphasized the importance for assuring quality assurance functions have the organizational freedom and independence as recommended'

in ANSI 15.8/N401-1976, " Quality Assurance Program Requirements for Research Reactors."

The inspector personally discussed the findings of this inspection with the RFAC Chairma The. inspector informed the Chairman and licensee staff attending the exit committee that RFAC review and audit activities do not appear to be effective in surfacing the types of problems identified from this inspectio No violations or deviations were identifie . Exit Interview The inspector met with the licensee representatives (denoted in paragraph  ;

'1) at the conclusion of the inspection on July 18, 198 The inspector '

summarized the' scope and findings of the inspection. The apparent violations discussed in paragraphs 2.G and 4 were brought to the licensee's attentio The need for improving the effectiveness of internal "FAC review and audit functions were emphasize l

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