IR 05000142/1989001
| ML20236A155 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 02/27/1989 |
| From: | Fish R, Garcia E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20236A149 | List: |
| References | |
| 50-142-89-01, 50-142-89-1, NUDOCS 8903160421 | |
| Download: ML20236A155 (7) | |
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.. a U. S.' NUCLEAR REGULATORY COMMISSION L REGION V 1
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f l-Report No. 50-142/89-01 i
Docket No.'.50-142 Former Licensee: University of California at Los Angeles Los Angeles, California 90024 Facility Name: UCLA Research Reactor Site Inspection at: 'UCLA Campus
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Inspection Conducted: . January 31 through February 1, 1989 Inspected by:
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- M M E. M. Garcia, Emergency Response Coordinator
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Date Signed Appr'oved by; 'r
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4!A7f87 R. F. Fish, Chief Ddte Signsd
. . Emergency Preparedness Section
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sSummary- ,
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, . . Areas' Inspected: .,Special announced inspection to confirm that UCLA has met ., ,
S ,3 i the requirements of Section 2.5 of the Settlement Agreement between the i i c p University,' the Cadipus Committee to Bridge the Gap, and the NRC staff. The ' '
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inspection,also examined'the status of selected commitments in the
_' , Decommissioning Plan-Phase 1 and the radiation control program. The guidance '
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in inspection procedure 83743B was use '
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- . At'the time of the inspection the University may not have completely ?
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complied with Section 2.5 of the Settlement Agreement, although this
[ l conclusion _is subject to the interpretation of the' requirements of Section ,
' 2.5. .The records maintained.by the University to document their decommis-
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sioning effort and instrument calibrations were less than sufficient to
- .l substantiate the work performed. The University programs did appear to meet
/ their safety objectives. No violations were identifie I j
8903160421 890:227 PDR ADOCK 05000142 g PDC
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e i oQ ! DETAILS n,
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< Persons Contacted'
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- J. Mc Laughlin, Director, Radiation Safety . .
- Richard Sessions, Executive Officer,' School of Engineering and Applied Science
, *J. Kleck,. Health Physicist
- A. Huda, Reactor Health Physicist
. *C. Aschbauch, Facility. Supervisor -i N. C. Ostrander, former Manager Nuclear Engineering Laboratory.(Retired) ;
D. J.,Krueger,'former Reactor Health Physicist (contacted by telephone)' <
- Denotes those individuals present at the exit intervie . 'Section 2.5'of the Settlement Agreement On September 30, 1985 the Regents of the University of California, the Campus Committee to Bridge the Gap and the staff of the NRC entered into a settlement agreement (hereinafter the " Settlement Agreement"). The conditions of the Settlement Agreement were' approved by an Atomic Safety 1 and Licensing Board Oraer issued on November 8,198 l Section 2.5 of the Settlement Agreement states:
"By September 30, 1989,. all radioactive or contaminated components, equipment, materials and parts associated with or formerly'used in connection with the Reactor facility or otherwise formerly licensed under License R-71 shall have been decontaminated or disposed of or transferred to another qualified licensee other than the University such that there shall be no radioactivity or contamination at UCLA associated with the former Reactor facility or License R-71 in excess of the levels identified in Section 2.6, except for the concrete building structure and concrete biological shield and any components so affixed to or embedded in that' concrete structure that they cannot be readily removed without demolition of the concrete, and except for _ the hold-up tank, primary water pump, sump pump, compressor. system, floor drains, decontamination sinks, and the fuel ,
storage pits." )
Section 2.6 specifies that for purposes of the Settlement Agreement, an 'j item is radioactive or contaminated if it emits radiation of 5 microrem i or greater per hour above background at one meter from its surface, '
r..oritains surface contamination in excess of that, specified in Table 1 of Regulatory Guide 1.86, or a byproduct materials license is required for its possessio Based on' observations during a facility tour, on a review of records, and on discussions with University staff, it appears that the requirements of
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Section 2.5 of Settlement Agreement had been met with one exception:
there remains in the. possession of the University approximately 5250
. pounds of slightly radioactive lea The University has estimated that
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there is approximately 4000 pounds of' lead shot in'two drums and approximately 1250 pounds of lead bricks used as shielding in the reactor pedesta The total aggregate activity for all identified radionuclides-in the lead is approximately 115 microcuries. The University's gamma spectrum analysis identified Cobalt-60 (Co-60), Silver-10Sm (Ag-108m) and Silver-110m (Ag-110m) in the lea The University staff. stated that they currently posses this radioactive lead under Amendment 98 to their California Radioactive Material License Number 1335-7 i i
The inspector asked for the University's interpretation of Section 2.5 of the Settlement Agreement in light of the possession of the radioactive lead. The' Director Radiation Safety stated that there were three factors t to consider:.(1) the parties that prepared the Settlement Agreement did not take into account other radioactive materials licenses the University holds, their interest was with the reactor license; (2) a letter dated ;
~Janua ry 26 1989 has been submitted to the NRC Office of Nuclear Reactor Regulation'(NRR) that explains the University's intention to keep control of the' lead under the California license due to the problem with disposal ,
of waste that is both controlled for radioactivity and other hazardous l
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properties; and (3) the possession of the lead under the California i license, where it would.not be used for this or any other reactor, is'in
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. the spirit of the Settlement Agreemen In conclusion the University !
believes that the Settlement Agreement permits possession of the !
radioactive lead by the University under their California licens The inspector stated that their interpretation of Section 2.5 of the Settlement Agreement would be brought to NRR's attentio This subject was discussed at the exit intervie . Decommissioning Plan - Phase 1 l l
On July 14, 1986 an NRC Order authorizing Phase I of the dismantling of the facility.and disposition of component parts was issue The Safety Evaluation (SE) in support of this Order states "The principal concerns raised by the dismantlement plan are (1) personnel exposure and (2) safe j handling, shipping, and disposal of radioactive materials".
In the SE it was noted that the estimated collective dose equivalent was not to exceed 10 person-rem during Phase I of the projec To determine if this goal had been met, the inspector examined Radiation Work Permits (RWPs) and exposure records for individuals that worked under the RWP The University issued a total of 8 RWPs related to Phase These RWPs were issued during the period of March 11, 1986 to September 26, 198 No RWPs were in effect outside of this period, although other records indicate that work was perform before and after those dates. However, it appears that the majority of the tasks with major radioactive exposure potential occurred under the RWPs. For the years 1985, 1986 and 1987 the collective dose equivalent for individuals identified in the RWPs is q 3.370 person-rem, with the highest individual exposure in a quarter being l l
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?880 mre The collective dose equivalent goal of 10 person-rem specified in the SE appears to have been me The SE also'specified certain components that would be removed and dispose These components were identified as (1) the reactor core reflector, (2) the graphite thermal column, (3) the shield tank, (4)
peripheral equipment, (5) fuel boxes, (6) control blade system components and (7) protruding pipin In a letter from the University Director of Radiation. Safety to the NRC Project Manager, NRR, dated December 7, 1988, the University states that the component parts of the reactor have been dismantled and disposed. To determine the history of the disposal of these components the inspector examined available records, interviewed personnel, and toured the facilit The tour of the facility disclosed that the major reactor components had been dismantled. The fuel boxes, graphite moderator, shield. tank, contro1' blade' system components, protruding piping and some of the-concrete shield blocks had been removed. Remaining equipment included the sump pump, some shield blocks, hold-up. tanks, the reactor concrete pedestal and lead brick Review of the RWPs, selected shipping documents, and selected memorandums to file indicated that the reactor was dismantled, components analyzed for radioactive contamination or activation and materials disperse Radioactive materials were shipped to Texas A and M University, or the US Ecology radiological waste disposal site in the State of Washington, or kept by the University under their State of California Radioactive Materials License No. 1335-70. Records also indicate that 22 concrete blocks that were determined to be "non-radioactive" were given to a Wildlife Waystation in San Fernando California. From interviews with members of the University staff it was determined that additional components or portions of components that were found not to be contaminated or activated were recycled for University use, provided to a metal recycler or given to the Wildlife Waystatio With the exception of the records of the cencrete blocks transferred to the Wildlife Waystation, it was not possible to determined the specific disposition of the component Shipping documents identified the basic material,re.g. graphite or stainless steel, but no records were found q
that related a specific component to a specific shipping container or shipment. Even when comparing weights or specific activities it was not , ,
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possible to locate components to shipping container Although this y practice makes it difficult to trace the disposal of specific components l it does 'not' appears. to violate any regulation or commitments.
With the exception of the lead discussed in section 2 of this report, the
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inspector concludes that it is probable, as stated in the University's letter to NRR of December 7, 1988, the University has dismantled and
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properly disposed of the component parts of the reacto This matter was discussed at the exit intervie <
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4. Radiation Control (837438)
The inspector toured the facility to examine radiation control practice Access to the outer portion of the facilty was controled by locked door The doors to the reactor room were also locked. Radiation and High Radiation areas were properly posted and controlled. A container that had been used for storing radioactive materials, but was now empty, had a radioactive material label on it. The inappropriateness of this practice was discussed with the Reactor Health Phycist. .The label was promptly removed. Personnel entering the reactor room wore personal monitoring devices (either film badges or pocket ion chambers). No protective clothing'was required or worn. A hand and foot monitor was located by the door from the control room to the reactor room. All personnel currently working at the facility are health phycists or former reactor operators and are familiar with the health protection problems associated with radiatio During the. tour of the facility exposure rates were measured by the inspector and by the Reactor Health Physicist at various location The University readings were within 10% of those made by the inspecto These measurements were comparable with the most recent radiation survey conducted by the University staf The NRC measurements were made with a Keithly, model 36100 ion chamber (NRC property number 008917). This instrument was calibrated on October 26, 1988 and will be due for recalibration on April 26, 198 The University's calibration program for radiation survey instrument is discussed in Section 5 belo Personnel radiation exposure records for the period of October 1, 1985 to December 31, 1987 were reviewe Monthly film badge service was provided by the R. S. Landauer, Jr. Company. As noted in Section 3 above, the highest recorded individual whole body quarterly radiation exposure was 880 mrem. The University's program eppears to be consistent with the requirements of 10 CFR 20.101, 20.104 and 20.20 Monthly radiation and contamination survey records for the period of March 1986 to July 1987 were examined. The University appeared to have i had an adequate survey program during Phase 1. After July 1987 radiation
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and contamination surveys are only performed when activities in the reactor room could change the radiation or contamination level As noted on Section 3 above, the most recent survey (January 18-19 1989)
indicated radiation levels consistent with those measured by the inspecto . Radiation Survey Instrument Calibrations (83743B 4.)
The calibration procedures of selected instruments and records of specific calibrations were examined. The University has one Ludlum, model 3, survey meter with a shielded " pancake" GM detector. The calibration procedure for this instrument requires that an electronic calibration be performed with a pulse generator and the detector efficiency determined with a set of Technicium-99 beta sources. These sources are traceable to the National Bureau of Standards (NBS). If l
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I adjustments are required on the electronic portion of the calibration
- - such adjustments are to:be'noted on the calibration form. .The first-avialable.calibrationtrecord for this instrument was dated November 7, 19P he 2 Pi efficiency for the source with the least activity was determined to be 20%.
- A University document titled "NEL Release Criteria," dated January 15, t 1986, describes how this efficiency, the detector area and the applicable limit from Table 1 of Regulatory Guide 1.86 were ,used to calculate net count rate that would meet the contamination. criteria for release'for unrestricted use. ' Forty counts per minute.(cpm) above_ background was determined to be the appropriate value. To be conservative the document'
recommended that a net 20 cpm be used as the acceptable release leve Based on this determination, a procedure was developed titled " Release of Material for Unrestricted Use." This procedure was-issued on January 1986 as RS OP 09-05. This procedure specifies the use of the Ludlum model 3 survey meter with.the shielded " pancake" GM and sets the. release level at a net 40 cp Subsequent recalibrations on July 1,1986 and February 4,1987 generated efficiencies of 8% and 6% respectably. However, the University continued to use procedure RS OP 09-05 without modification. Calibrations conducted on March 8, 1988 and January 13, 1989 did determine the efficiency to be 20%. In all calibrations no electronic adjustments had been require In order to resolve the apparent discrepancies a telephone called was made to the former Reactor Health Physicist, who is no longer employed by the Universit The former Reactor Health Physicist, as he could best recall believed that the procedure was sufficiently conservative that the change in detector efficiency was not significan Also, since the instrument had not changed in its apparent behavior the recorded' changes
'in efficiency were believe not to be meaningful and therefore they were
' ignored. Also, although not ^ written in the procedure, when surveying material to be release, if any radioactive was detected. .the material was not released and disposed as radioactive wast The current Health Physicist provided a reasonable explanation for the discrepancies. The:Tc-99 source are attached to a gig designed for a
different detector holder than the Ludlum shielded prob In order to get a true 2 Pi geometry with the Ludlum shielded probe, the source must first be removed from this gig. This was the way the original and last
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two calibrations were conducted. The former Reactor Health Physicist did I not recall removing the sources from their gig when conducting his calibration The calibration procedure does not state whether the source is to be removed from the gig or not and calibration results are not reviewed and approved by University management. Similar problems with the calibration procedures and their implementation of the Eberline R0-2 Ion Chamber were noted by the inspector.
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a sufficient.to document this fact. These problems'were discuss with the , J ,. ,
/"e l University ~ staff'and at the exit intervie The inspector suggested that
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theiUniversity review American National Standards Institute (ANSI) '
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-i - publication N323-1978, "American National Standard Radiation Protectio '
, )? Instrumentation Test and Calibration" for its applicability to their )
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[, r- 3 instrument calibration progra ,
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, Exit Interview
.i At the conclusion of the inspection on February 1,1989, the inspector met with the University representatives denoted in Section 1. The inspector summarized the scope and findings of the' inspection. . The inspector'c wilderstanding of the University's interpretation of Section 2.5 of tb4 Settlement Agreement was discussed. The quality..of component-disposal racords, calibration procedures and calibration records were also discussed. The University was informed that no violations, or safety concerns had been identified.
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