IR 05000142/1975001
| ML19275B607 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 02/11/1975 |
| From: | Book H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19275B603 | List: |
| References | |
| 50-142-75-01, 50-142-75-1, NUDOCS 7912190125 | |
| Download: ML19275B607 (11) | |
Text
,
._
w..
=
-
... - - -
--
-
-
,,,
,
.
.
.
(
U. S.(. tr, LEAR REGULATORY C0!StISSION
'
..
'
.'
'0FFICE OF INSPECTION AND ENFORCEMENT
'
RECION V
-
,
IE Inspection Report No.
050-1 a2 /75-01
Licensee IJnivarsity of California at Los Anceles Docket No. 050-142 f
I J
__ Los Anceles. California 900?4 License No. R-71 l}
.:]
Priority
]
'
Category F
j Facility Research Reactor
-
Location UCLA Camous Arconaut (100 KU)
Type of Facility Type of Inspection Routine Announced Dates of Inspection January 23-24, 1975 September 30 - October 2, 1974 Dates of Previous Inspection
,a
/ [7T Principal Inspector [
f,
.d (e-et
'Date F. A. Wenslawski, Radiation Specialist None Accompanying Inspectors Date
-
.
Date
.
'
Other Accompanying Personnel:
None
,
i al h4 I- // - 7 ~
h
-
d O'
2'
'
Reviewed by D te H. E. Book, Chief, Radiological and L
Environmental Protection Branch
.;
?'
-
an
.
Sf*
&
.
-
7912100
/p_ f
'
-
-
... -
.-
.-
...
.
.
.
,
.-
.-
.::,
n,
-
-.
~., -
-
-
..
.
(
(
.
.
.
-
-
SINMARY
,
Enforcenent Action i
C,"
The licensee had not calibrated the reactor room area radiation
'
A.
the nenitors and the radioactive gaseous effluent monitor at l
(Paragraph frecuency required by the Technical Specifications.
(
3.a. and 3.b. of Details.)
'.*en:11ation exhaust air from the reactor room was not being diluted k
L.
- 1,,0C0 CT:t and nc: being released at 125 feet above ground level
,
cs recuired by the Technical Specifications.
(Paragraph 2.a. (1) of
{
De ta ils. )
Licensee Action en Previcuslv Identified Enforcement Items The corrective actions identified in the licensee's letter of Novenber 4, 97-were exanined by the inspector. Although corrective actions de-in tiis le::ar have been inplenen:ed, the ventilation exhaust s c r i': e:
to meet the sjs:en fr;
- ha :aci ity required addi:icnal modifications re:uiranan:s of the Te:P.nica". Specif. cations.
(Paragraph 2.a. (1) of re:sils.)
Unususi 0: urrences None J:her Sienifican: Find int s A.
Curren: Tindings licensee has tentatively found an error in the calibration
-
T:e 1.
in curve of the gasecus ef fluent nonitor which would result previcusly recorded and repcrted discharge concentrations and cuantities being low by an approximate f actor of ten.
(Para-
-.
graph 3.b. of Details.) -
--- -
.
Extensive construction of new facilities around the reactor 2.
has resul:ed in a conditica which could conceiyably,have.
personnel inmersed in the discharge plume from the ventilation y
exhaust stack.
(?aragraph 2.a. (3) of Details. )
,
i Status of ?reviousiv Renorted Unresolved Items
<
S.
Status of This inspection was restricted to radiation protection.
B en the mangenent contrcl system as discussed in inspection
'
the ite:
report No. 050-142/74-01 and the October 15, 1974 Regional office
le :er to the licensee was not specifically examined.
,
..
.
z. ~._
_
_
_
.
.
.
_-
.~
~
.-.
,,
,
\\
\\
-..
2-
-
-s
'<anagement Interview
~~
At the conclusion of the inspection, the findings were discussed with Dr. T. E. Hicks, Director of NEL, Mr. N. C. Ostrander, Laboratory bl
.
Manager, and Mr. J. W. Hornor, NEL Health Physicist.
The following items were specifically discussed.
r
.
A.
The vcntilation exhaust f rom the reactor room is not diluted to the U
required 14,000 CFM and is not released at the required elevation
$
of 125 feet above ground level.
Paragraph 2.a.(1) of Details.
L G.
area radiaticn meni:::s and the radioactive
"'a - " ---- oc:
gaseous ef fluent monitor have not been calibrated at the required frequency.
(paragraph 3.a. and 3.b. of Details.)
C.
The method of particulate sample collection in the ventilation exhaust duct did not appear to assure the collection of a repre-sentative sample.
The licensee representative agreed to evaluate the cethod of sa=ple collection in light of ANSI S13.1-1969.
(Paragraph 3.c. of Details.)
3.
The inspector expressed an interpretation that sections II.B.4. and VIII.M.l.b. of the Technical Specifications did not appear to authorize averaging the discharge concentrations of gaseous re-leases from the facility. The licensee representatives stated that
,,,
they believed they were authorised.
A subsequent telephone call from the inspector to Licensing confirmed that averaging was authorized and the inspector notified the licensee of the results of this call.
(Paragraph 4. of Details.)
E.
The configuration of the ventilation exhaust stack and the immediately adjacent f acilities established cenditions which could expose personnel to various concentration of the gaseous effluent plume.
The licensee representative recognized this conce;n and agreed to perform an appropriate evaluation to estimate thq radiological effects.
(Paragraphs 2.a.(3) and 5.d. of Details.)
,
'
_
,
?
U
.
F,a V
-
.
...,
.,,
%,
g...-
.:
-
v.
c
..,.,
--
(
(
..
,
.
DETAILS 1.
Individuals Contacted T. E. Hicks, Director of Nuclear Energy Laboratory (NEL)
--
C. E. Ashbaugh, Reactor Supervisor
i N. C. Ostrander, Laboratory Manager j
{
J. W. Hornor, NEL Health Physicist
T. L. Zane, Sub-Critical Laboratory Supervisor y
A 2.
Radwaste Disposal
!
I a.
Gaseous Releases (1) Section 11.B.3. of the Technical Specifications requires that approximately 5000 CFM of air be drawn f rom the reactor room, be diluted to a flowrate of 14,000 CFM and exhausted to the atmosphere through an acceleration no::1c at 125 feet above ground 1cvel.
During the last inspection of this f acility (Report :;o. 74-01) the licensee was cited for not having the acceleration nozzle on the stack exhaust.
It was not determined during that inspection hether the release flowrate and height were in accordance with the tech spec.
As a result of the citation, the licensee installed an acceleration nozzle and attempted to balance the ventilation system.
The licensee determined that although 5000 CE:1 could be exhausted from the reactor room, the dilution flow was
caly 11,500 CF:: and the release height above ground level was 108 feet.
A memorandum from T. E.
Hicks to E. L.
Kriuch, ' Chairman, Dep'ait elit of-Energy "and~KiEet~ics~ dated 12/20/74 pointed out that the systen, was operating in violation of tech specs and requested necessary modi-
,
ficaYions to the system.
The licensee representative stated that to date no corrective action had been taken and that funding the codifications is a problem.
The
- licensee representative was unable to specify when the
>
.,
ventilation system would be modified to meet the tech
'
specs.
'
(2) Releases through the ventilation exhaust system of the
"
facility consist primarily of Argon-41 generated in and around the reactor core.
The licensee stated that during d
][
full power (100 KW) operation the equilibrium concentra-tion of Argon-41 discharged through the ventilation exhaust is 6.8x10 uci/cc.
At the time of the inspection g
i
-
-
~.
.,;.
.
~
..,
..
.
...
-
-
.
- -
-
.
,
-
~
,
.
,,
,
,
..
s (
(
-4-the licensee had just coopleted the annual repor t which stated that 2.39 Ci of Ar-41 were discharged during 1974.
7-The licensee stated that this value was derived by using
]*
,
the full power discharge concentration, the number of
' l ef f ective full power hours of operation and the ventila-
'
tion exhaust flowrate.
The licensee stated that the 2.39 value included a f actor of 10 correction for an error in
,
the calibration curve of the gaseous effluent monitor.
g (Paragraph 3.b. cf Details.)
[
-
T'.e licensee stated that trace quantities of particulates analyzed to be Carbon-14, Cobalt-60, and Antimony-124
'
were discharged through the ventilation system during a three-week period of maintenance operations in September-Octgger. The cor.centrations discharged were in order of
uci/cc. No particulate releases were detected during routine reactor operation.
(3) While touring the tooi of Boelter Hall-Math Science building coeple2, in which the reactor is located, the inspector noted that the discharge of the ventilation stack is somewhat lower than other portions of the roof and other levels of the building complex.
Construction of additional f acilities over the years has essentially encompassed the reactor facility.
Presently the ventila-tion stack extends about 15 feet above the eighth floor roof.
Other portions of the building complex extend to a partial ninth and tenth floor.
At one location readily accessible on the roof, it is possible to stand about 25 feet frcm the ventilation stack and look down upon the stack. Located on other portions of the roof are astro-
.
nemical observatories, a meteorological laboratory,'lI'-
seminar _ room and the upper portions of the math-science library. With the exception of the library, access to these facilities is via the roof top.
The inspector i
discussed with the licensee the possibility 'that the
'
I configuration of these facilities with respect to t'he l ventilation stack could result in personnel being exposed f
to various concentrations of the gaseous effluent plume.
h The licensee agreed that such exposures were conceivable
'
,
and stated that they had once considered making portions
-
of the roof a restricted area but rejected the concept because it was too impractical.
The licensee recognized
,
that increacing the height of the stack to the required s
elevation, 17 feet higher, and increasing the flowrate u,.
N
=%.
w e
-
...a.
.
-
~~ ~
E.
-
.
{
..
(
... s-5-will likely alleviate the condition but not necessarily it was the licensee's belief that eliminate it.
Howbeit, due to rapid atmospheric dispersion and limited occupancy
_
J times an exposure in excess of 10 CFR 20 limits could not
!
Other than relatively insensitive radiation
surveys (Paragraph 5.d), the licensee could not quanti-occur.
tatively demonstrate the actual radiological ef f ects.
i The inspector discussed the use of sensitive TLD measure-ments as a method of determining average long-term
,h The licensee stated that he had access to a exposure.
co:puter program which could model the atmospheric L,
dispersion characteristics peculiar to the situation.
an analysis of the situation was The licensee ag:ced thst appropriate and agreed to evaluate the exposure potential by a suitable means.
b.
Licuid Releases The principal source of liquid radwaste is primary coolant Uaste liquid is held in (1)
water and decontamination water.
a hold-up tank and discharged to the sewer on a batch Discharge flourate is 5-6 GPM with an equal Five batch discharges were made in 1974 basis.
dilution flow.
the maximum tetaling 1300 gallons.
Priortodi}ution, uci/cc and the discharge concentration was 4.3x10 7 uci/cc.
The average discharge concentration was 2.1x10Analysis of total quantity dischargee was 1.04 uci.
is perforced on a batch basis by discharge concentrations evaporating a 1200 ml sample to dryness, counting with an end window G'i tube calibrated with a Chlorine-36 source and subsequently perf orming a gamma spectrum analysis to The discharge qualitatively identif y the isotopes present.
restrictive isotope
-
is then controlled based on the most identified.
.
Sclid Waste c.
'
Solid radioactive waste is packaged in 55-gallon drums (1)
and transferred to the University storage, area for
.
ultimate disposal by the Office of Environmental Health
]p Five drums were transf erred to EH&S and Safety (f.H&S).
items of disnosal generally consisted of
'
during 1974, scrap metal and wood, graphite, gloves, shoe covers, rags, lead, paper, tools, m et and dirt.
A qualitative analysis u
of four of the drums indicated Co-60 to be the predominant tf
'
The maximum radiation level at the surface of L
isotope.
any of the drums was 200 mR/hr.
w
.
D g
.#-
g c,;..
-
.
':C
'
-.-:
-
...
(
...,
-6-Radiation Monitoring a.
Area Monitoring
'~
Section V.A. of the Technical Specifications requires that the reactor room be continuously monitored by at least two area
,
Ll radiation monitors.Section V.C. requires that these monitors (l be calibrated semiannually. The maintenance log states that these monitors were last calibrated January 17 and 22, 1975.
There was no other indication of prior calibrations in the
'
log, which covered a time span from thy 1, 1974 to the date of the inspection. As stated in the last inspection report, No.
!
74-01, the naintenance log prior to May 1 had been lost by the i
licenses.
The licensee representative stated that the area monitors were last calibrated about one year ago.
The repre-sentative was unaware of the requirement for semiannual calibration and was under the impression that the calibration frequency was the same as for nuclear instrumentation (annually).
b.
Caseous Effluent Monitoring Section V.3. of the Technical Specifications requires that exhaust air drawn from the reactor room be continuously monitored for gross concentration of radioactive gases.
Section V.C. also requires this monitor to be calibrated semiannually.
The maintenance log shows no record of this monitor being calibrated.
The licensee representative again stated he was unaware of the semiannual requirement of the tech spec and stated that the gaseous effluent monitor was last calibrated in April, 1974 and that he had scheduled another calibration in the near future.
The instrument used for gaseous ef fluent monitoring is a
~
Nuclear Chicago, Dynacon Model 6000, that utilizes an ion chamber detector.
A four liter per minute gas sample from the ventilation exhaust is continuously drawn through the detector and the signal generated is recorded in millivolts on a thart recorder.
A calibration curve on graph paper relates uci/cc to millivolts. The licensee stcted that calibration of the
-
instrument is done by replacing the detector chamber,with an identical, sealed, calibration detector chamber containing
~
,l Carbon-14 tagged CO gas.
When questioned about the validity l
of the calibration curve and the detector response to Ar-41
,
versus C-14, the licensee stated that the calibration curve
'
was experimentally generated years ago and that documentation no longer exists _which_shows.how the_ curve was developed or
,}
_
IiOa
.
.
-
.
,
.,
, * u g '.,,
,
.
.
....
,M
.
.
_
- g n
-
--
...
_
__
_
r.
,, *
'
.
(
(
-
>
.
7-
-
what error it may,have.
The licensee stated that a recent calculation pefformed to compare the expected response of Ar-41 to that of C-14 indicates that the existing calibration
~~
curve is in error by a factor of ten.
The licensee represen-tative further stated that he is convinced these calculations
are correct and that the discharge concentrations presently i s recorded in the operating log are low by a factor of ten and
}
that the quantities of Ar-41 reported discharged in previous
..
annual reports would also be low by a f actor of ten.
To d
confirm the correct calibration of the instrument, the licensee
stated that he plans to use a known concentration of Ar-41 to j
perform an absolute calibration of the detector and develop a j
r.re response curve. The licensee stated that since the Argon will be produced in the reactor, it will first be necessary to more accurately determine the neutron flux.
The licensee stated that to calibrate the neutron flux and the gases monitor would probably take until mid-March.
The inspector and the licensee agreed that the factor of ten increase in discharge concentrations would not have resulted in exceeding the release limits of 10CFR20 when allowance is made for averaging. The licensee noted that the annual report for 1974 included the factor of ten increase and that a log entry made January 24, 1975 instructed all operators to r.ultiply concentrations by a f actor of ten uhen using the existing response curve.
farticula:e::oritoring c.
Section 11.3.3. of the Technical Specifications requires that air exhausted f rom the reactor room be monitored for particu-late ccntanination.
The system of monitoring employed by the
~
licensee uses a 2.5 liter / min. flow through a particulate collectica filter.
The filter is removed and analyzed on a weekly basis.
The inspector observed that the filter holder is placed in the center of the ventilation exhaust duct with the filter paper facing the air flow.
The inspector questioned the representativeness of the sample and whether the system had been analyzed for anisokinetic samplin>; crrors or whether the guidance of ANSI N13.1-1969, " Guide to Sampling Airborne 5]
F.adioactive Materials in the Nuclear Facilities" had been
'l U
considered in designing the collection system. The licensee U
stated that he was unaware of the N13.1 standard and after a
,
description of its contents by the inspector, the licensee b
agreed to evaluate the particulate sampling system in light of
,
the ANSI standard.
L f,,
-
. *
v i.-
.
.. : ~;
.
m
.
' '
e.
- *.
,
>
...
k-8-Intercretation of Technical Specification Radioactive Release 4.
-
w
- imits bod inspector discussed with the licensee the interpretation of
and Vill.M.l.b. of the tech specs.
The inspector j,;
The sections 11.3.4 stated that 11.3.4. is vague with respect to allowing averaging of n
the reporting requirement of VIII.M.1.b.
i in-discharges and that averaging of discharge concentrations is not authorized.
.
The licensee stated that they have always considered averaging to d'
plies that he autherized end stated that the ner:ci full power discharge 6.Sx10 uci/cc of Ar-41, is well above the concen-concentraticn, tration limit of Appeac1x,s, Table 11,"10CFR20 and they would be
~
unable to cperate if they didn' t average concentrations over a
-
The inspector stated that he would discuss the matter with year.
Licensing as f ollowup action to the inspection.
A subsequent 27, 1975, from the inspector to the operat-telephone call, January ing reactor project manager in Licensing confirmed that averaging This information was telephoned was auth:rized by the tech specs.
to the licensee on the same day.
the in-to the clarification en averaging releases, S ub s equent spectoragaintelephonedthelicensee,fJanuary 31, 1975) to inquire how their alarm level setting of 2x10 uci/cc precluded the annual The average ccncentration f rem exceeding the limits of 10CFR20.
liccnsee explained that he computes the number of hours per year he say discharge at 2x10~ uci/cc by taking a ratio of the alarm limit g
(2x10 ' uci/cc) to the 12C (4x10 uci/cc).
The reactor is then operate at f ull power (100 KW) for this period of casidered ::
(175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br />) to compute the number of KW hours operation time authorized per year such that the average discharge concentration
-
doesn' t exceed the limits of 10CFR20.
A running total of KW hours of actual reactor operation is then kept and compared to the number authorized for the year. The licensee noted that the a9.tual dis-uci/ml, charge concentration at full power operation is 6.7x10 theref ore their control method is conservative.
The inspector
-
agreed that the approach provides reasonable assurance that an.
."'
average release concentration will not exceed 10CFR20' limits.
l u
fj 5.
Surveys
q a.
Radiation l
- 'eekly radiation surveys are perf ormed in commonly used areas
,
,
lj, of the facility as well surveys of equipment which is likely n
to have changing radiation levels or normally have higher
,-
,
,.
~.1 m
,
,
...
,
..
- ?e
.-
...,
(
(
9_
radiation levels associated with it.
Such equipment includes liquid filters, demineralizer, primary water dump tank and
'
,,
vacuum cleaners.
Special surveys are performed each time
,
irradiated material is removed from the reactor.
Total area 2,
surveys are performed twice per year or anytime the reactor i;
shielding has been altered. The total area surveys are per-f ormed with the reactor at full power.
Survey records in-J
.
dicate that at full power a.05 mR/hr gamma isodose line and j
J
.01 mrem /hr neutron isodose line are well uithin the restricted boundaries of the f acility.
j 1.
5.
Contcrination Weekly contamination surveys are performed at approximately nineteen locations. These locations include normal control points, general entryways, areas where contamination is ex-pected such as near irradia:1on " holes" and the rabbit room and at locations outside the restricted area such as the third level NEL patio, the roof of the math-science building and Westwood Soulevard. No contamination problems were noted in the survey records, c.
Airborne
';o routine surveys are performed for the purpose of controlling occupational exposure to airborne radioactivity.
The licensee stated that the nature of the operations as well as past operating experience has denonstrated that airborne exposure is not a problem at the facilitj and monitoring of the ventila-tion exhaust provides an indica lon of conditions in the ret: tor room.
Tne licensee stated that on occasions in the
,
pas: a poly bottle grab sample technique was used to sample the gaseous activity at various locations in the f acility during full power operation.
The licensee described the technique as somewhat crude and reliable within an a~pproximate factor of ten.
The licensee agreed that due to the' calibration dependency of this sampling method on the calibration of the gaseous effluent conitor, tha t the grab sample results were
,,
also Icw by a f actor of ten.
The inspector reviewed the results of all such samples taken (58 sgmples) and observed
[
the highest concentration to be 3.7x10 uci/ml of Ar-41.
The e
record indicated that this high sample was at the center of j
the vertical irradiation " hole".
The licensee stated that the t'
sample was taken right at the top of the " hole" during removal d
,
of an irradiated specimen and that the concentration in the 3.$
_
.
>
.
W
c..!
,.
(
(
.
,.
-... -
- 11 -
7.
A1AP The licensee was questioned with respect to action taken to meet
_
Section V.D. of the. Technical Specifications that release of
.
radioactivity f rom the reactor f acility shall be kept to as low a j
level as practical. The licensee stated that ef f orts in this pj behalf were primarily aimed at minimizing the possibility of q
generating Argon and attempting to preclude the release of Argon s
f rom the reactor.
Specific action taken includes physically N
'l removing the beam port in the shield tank thereby eliminating a void, keeping the core water level up thereby minimizing air in the y
core vent, sealing from atmosphere the seven side beam ports that i
ara no longer used, providing saals on the vertical irradiation
" hole" plugs to minimize Argon escape during sample irradiation and waiting as long as possible to remove an irradiated sample to allow decay of the Argon.
.
.
.
.
..
w b
f
,
-
.
.
...,.c
- -
..,a..'
'
-
.
- [. J.,y
.. -