IR 05000160/1989001
| ML20235U718 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 02/17/1989 |
| From: | Gloersen W, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235U714 | List: |
| References | |
| 50-160-89-01, 50-160-89-1, NUDOCS 8903090345 | |
| Download: ML20235U718 (11) | |
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'f NUCLEAR REGULATORY COMMISSION REGION ll j 101 MARIETTA ST., '#
eo,e ATLANTA, GEORGIA 30323 FEB 211989 Report'Nos.: 50-160/89-01 -
Licensee: Georgia Institute of Technology 225 North Avenu Atlanta, GA 30332
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DockE.t No.: 50-160 License No.: R-97 Facility Name: Georgia Institute of Technology Research Reactor Inspection Conducted: Januar 25-30, and February 16, 1989 Inspector: /l l , NV-C'>d A/N/8Y
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Dat6 Signed Approved t;y: IM O [9 R O h m fl67 M J. P. Pqtter, Chief Date g gned Facility Radiation Protection Section Emergency and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of radiation control, . environmental radiation dose, allegation followup, and action on previous inspection finding Results: .In the areas inspected, violations or deviations were not identifie The licensee' had made significant progress in proceduralizing radiation protection practices and in the health physics program. A weakness was observed, however, in the licensee's prograr for evaluating environmental radiation dose. Licensee management was made aware of this weakness. One unresolved ~1 tem was identified involving the evaluation and substantiation of these environmental radiation dose data (Paragraph 3). Additionally, an oral licensee commitment was made to remove radioactive materials from the storage shed located near the southeast corner of the restricted area perimeter fence by September 1,1989 (Paragraph 3).
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REPORT DETAILS Persons Contacted Licensee Employees
- R. Karem, Director, Neely Nuclear Research Center (NNRC)
- R. MacDonald, Associate Director, NNRC
- B. Revsin, Manager, Office of Radiation Safety'
J. Taylor, Senior Radioisotope Lab Specialist Other licensee _ employees contacted _ during this inspection 11ncluded -
operators, technicians, and administrative personne * Attended exit interview Radiation Control (83743) , Surveys-10 CFR 20.201(b) requires that the licensee perform such surveys as may be necessary and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen The inspector reviewed the following procedures:
9250, Facility Contamination Surveys, Rev. 1, September'9, 1988 9304, Routine Facility Radiation Surveys, Rev. O. September 9, 1988 These procedures were thorough and clearly specified the frequency and_ location of the surveys to be performed. The inspector reviewed selected records of the daily, twice weekly, fortnightly, and monthly contamination and radiation surveys performed in the Reactor Control Zone (RCZ) and the ' offices and laboratories of the Neely Nuclear Research Center (NNRC) covering the period September 9,1988, to January 20, 198 In general, both radiation and contamination survey results were well below any action points specified by the procedures. Additionally, the- various records were well organized and maintaine No violations or deviations were identified, Personnel Monitoring 10 CFR 20.202 requires that appropriate personnel monitoring devices be worn by personnel likely to receive exposure in excess of
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25 percent (%) of the limits specified in 10 CFR 20.101 or who enter !
high radiation area l For routine personnel exposure monitoring, the licensee revised portions of Section V.D., Personnel Monitoring, of the Radiation Safety Manual in order to bring the radiation protection practices at the facility more closely into conformance with standard industry practices. The following revisions were approved by the Nuclear Safegucrds Committee on September 9, 1988:
(1) For routine personnel monitoring, the licensee required radiation workers to wear a single monitoring device, that is, a film badge, which constituted the official record of personnel exposure at Georgia Tec (2) For day-to-day dose control, the licensee required the use of a pocket ionization chamber (PIC).
(3) The licensee's film badge exchange frequency was changed from monthly to quarterl (4) The licensee established an annual exposure limit equal to the federal regulatory limit of five rems per yea (5) The licensee required visitors to wear either a thermoluminescent dosimeter (TLD) (provided by a vendor) or a PI During tours of the facility, the inspector observed personnel wearing film badges which were supplied by a National Voluntary Laboratory Accreditation Program approved vendor. Beta, gamma, and neutron radiation was measured by these devices. The inspector examined selected personnel exposure records from January 1,1988 to September 30, 1988, and verified that exposures were below any regulatory limit The maximum individual (hot cell operator) dose was 190 millire No violations or deviations were identified, Posting 10 CFR 20.203 specifies the requirements for posting radiation areas, high radiation areas, and radioactive material areas. During tours of the facility, the inspector noted the posting of radiation areas and radioactive material areas was in accordance with the regulations and Procedure 9310, Posting of Radiological Control Areas and Materials, Rev. O, October 14, 198 No violations or deviations were identifie _ _ _ _ _ _ _ _ _
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f' q Respiratory Protection l 10 CFR 20.103(c)' states that a licensee may make allowance for use of ;
respiratory protective equipment in estimating exposures' of
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individuals to radioactive material in air provided that the licensee maintains and implements a respiratory protection program that
, includes, as a minimum, surveys and bioassays as. appropriate t evaluate actual exposures; written procedures. regarding selection,
. fitting, and maintenance of respirators, and testing of respirators .l for operability immediately prior to each use; written procedures j regarding supervision and training of personnel and issuance of '
records; and determination by a physician prior to initial use of l respirators and at ' least every 12 months thereafter, .that .the '
individual user is physically able to use the respiratory. protective equipmen The ' inspector noted that the licensee had two self-contained breathing apparatuses (SCBA) for use during emergency situation These SCBAs were not intended for routine use. The SCBAs were 1 located in the machine shop in the basement of the NNRC. The inspector reviewed the annual medical examination records and noted that two individuals had been medically qualified to wear a l respirato These two individuals had also received training on the- '
proper use of respirators on September 2, 19884 The inspector also ;
reviewed Procedure 9300, Respiratory Protection, Rev. O, August 6, j 1980,' which described an air sampling program that was used to determine if respiratory hazards from airborne radioactive material existe Additionally, Procedure 9308, Airborne Radioactivity Surveys, Rev. O, September 9,1988, provided guidance on the air sample locations and frequency of collecting air samples. The inspector reviewed selected air sample collection records covering the period January 5, 1988 to December 21, 1988, and noted that all results were below the regulatory limits specified in 10 CFR 20.10 The licensee indicated that airborne radioactivity was seldom generated and therefore not a problem at the facilit The inspector also reviewed Procedure 9038, Bioassasy Program, Rev. O, October 14, 1988, which describes the tritium analysis and gamma isotopic analysis program for routine bioassays. The routine bioassay program described in the procedure consisted of:
(1) beginning employment bioassy; (2) a yearly bioassay; (3) an employment termination bioassay; and (4) additional bioassays as i determined by the Manager, Office of Radiation Safety. It was observed that the licensee had not fully initiated the routine bicassay program since Procedure 9038 had been issued, however, the licensee was committed for program commencement within the next mont It was also noted that urine samples were not distilled prior to tritium analysis. The inspector informed licensee representatives that this area would be reviewed during a subsequent inspectio Currently, this area was tracked by a previously issued inspector followupitem(IFI) 50-160/88-02-0 I
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No violations or deviations were identifie . Annual 0:)erating Report (80745)
Technical Specification 6.7.a requires an annual operating report covering the previous year to be submitted to the Office of the Regional Administrator, Region 11, with a copy to the Director, Office of Nuclear Reactor Regulation, by March 1 of each year. In addition to operational information, the licensee was required to report information pertaining to radioactive liquid and gaseous effluent releases, environmental monitoring, and occupational personnel radiation exposure. Technical Specification 6.7.a(7)(e) requires the licensee to report the maximum cummulative radiation dose (millirem per year (mrem /yr)) which could have been received by an individual continuously present in an unrestricted area during reactor operation from: (1) direct radiation and gaseous effluents, and (2) liquid effluent The inspector reviewed selected portions of the Annual Operating Report for calender years 1982 through 1987. The annual dose due to direct radiation and gaseous effluents for the following years were as follows:
TABLE 1 Year Maximum Cumulative Radiation Dose (mrem /yr)
1982 20 1983 16 1984 10 1985 12 1986 25 1987 17 After discussions with licensee representatives, it was determined that the methodology for calculating the dose estimates could not be provide The licensee agreed to reevaluate the appropriate gaseous effluent release data and direct radiation data to either substantiate or revise the annual radiation dose estimates since 198 Since at the time of this inspection, the environmental radiation dose data from Table 1 could not be substantiated, the methodology for calculating the dose was identified as an unresnived item * (URI 50-160/89-01-01). The inspector informed licensee representatives that this area would be reviewed during the next inspectio Additionally, the inspector noted that the doses as measured by TLD at direct radiation environmental monitoring station number 9 were greater than 100 mrem /yr for calender years 1985-1987. Station number 9 was located on the southeast corner of the restricted area perimeter fence
- Unresolved items are matters about which more information is required to determine whether they are a .ceptable or may involve violations or deviation !
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adjacent to a shed containing radioactive material The licensee's direct radiation environmental monitoring program was accomplished by using both TLDs and film badges. The licensee stated that the dose as measured by Station Number 9 was not from Georgia Tech Research Reactor l (GTRR) operations but rather from sealed sources used for calibration of l health physics (HP) instruments. The licensee also indicated that the shed contained radioactive materials collected from the various laboratories at the University. The direct radiation doses as measured by TLDs and/or film badges for Station Number 9, calendar years 1984 - 1987 were as follows:
i TABLE 2 TLD Dose Film Bad e Calender Year (mrem /yr) (mrem /yr 1984 170 118 1985 130 111 1986 130 111 1987 540 365 It should be noted that Station Number 9 was approximately 180 from the predominant downwind sector. The inspector and the licensee discussed how additional information should be provided in the annual operating report regarding the relatively higher doses as measured by Station Number 9 and the unlikelihood of an individual occupying an area near Station Number The licensee agreed to evaluate this are Additionally, during a February 16, 1989 telephone conversation with a licensee representative, a commitment was made to minimize and ultimately remove by September 1, 1989, the radioactive materials, mainly byproduct material, being stored in the shed. This commitment was identified as IFI 50-160/89-01-0 . Allegation Followup (99014) Allegation (RII-87-A-0090)
The alleger stated that a " Campus Radiation Logbook" was withheld by the management of the GTR Discussion and Findings The inspector discussed the above concern with the Director of the NNRC and the Manager of the Office of Radiation Safety. The only information the alleger provided about the logbook was that it contained data on campus surveys and leak tests. Based on the information provided to the inspector concerning the description of the suspect logbook, licensee management provided what appeared to be the " Campus Radiation Logbook." According to the licensee, this logbook appeared to contain the personal notes of a former employee of the NNRC. The licensee considered this logbook the property of
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the University since the notes and data were documented in a logbook owned by the University. The logbook was secured in the safe located in the Office of the Director, NNR The Administrative Secretary was responsible for the logbook as well as maintaining other records of the facilit The licensee indicated that the logbook was not an official record of the University. Official forms from procedures were used for documenting campus surveys and leak test Conclusion The allegation was partially substantiated in that the 6pparent
" Campus Radiation Logbook" was secured and matitained in a safe located in the Office of the Director of the NNRC. However, the logbook was not being withheld by the licensee. It was available for review. just as any other record providing that the proper administrative controls are followed when records are removed from the Director's office. Additionally, it appeared that the logbook in question was an unofficial record documenting various campus activities since Technical Specification 6.5.b did not require a
" Campus Radiation Logbook" to be maintaine No violations or deviations were identifie . Action on Previous Inspection Findings (92702) (Closed) Violation 50-160/87-02-02: Failure to have approved operational procedures for sampling of low-level liquid waste tank prior to and during effluent release The inspector reviewed the licensee's response provided in a letter from R. A. Karem (Ga Tech) to L. A. Reyes (NRC) dated April 7, 198 Since the implementation cf the licensee's corrective actions for the aforementioned violation, Technical Specification 3.5., which specifies the sampling requirements concentration limits before the release of liquid radioactive was , was revised on July 12, 1988 (Amendment 7). The inspector reviewed Prccedure 3800, Liquid Waste Disposal, Rev. O, September 2, 1988, and Procedure 9040, Liquid Waste Tank Analysis, Rev. 2, October 21, 1988 which implemented Technical Specification 3.5.a. Representative records of liquid waste releases had been reviewed previously in Inspection Report No. 50-160/88-0 The inspector concluded that Procedures 3800 and 9040 had adequately implemented Technical Specification 3.5.a. The item is considered closed, (Closed) Violation 50-160/87-03-01: Failure to label containers holding samples of radioactive materia The inspector reviewed the licensee's response provided in a letter from R. A. Karem (Ga Tech) to J. N. Grace (NRC) dated June 15, 198 Additionally, the inspector reviewed Procedure 9310, Posting of L______-_-_____-_-_-__--_-________--_-_-___--_________--_-_-__-_______-_-_-_--________________ _________-__1
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Radiological Control Areas, Rev. O, October 14, 1988. Step specified the labeling requirement Step 4.2.4.2 stated that containers within the RCZ when they are attended by an individual who takes the precautions necessary to prevent the exposure of any individual to radiation or radioactive materials in excess of the limits established by 10 CFR 20 are not required to be labeled. The inspector had no further questions. This item is considered closed, (Closed) Violation 50-160/87-03-02: Failure to survey an activated indium foil upon arrival at a rabbit receiving station and failure to frisk when exiting the vestibule doors at the back of the RC The inspector reviewed the licensee's response provided in a letter from R. A. Karem (Ga Tech) to J. N. Grace (NRC) dated June 15, 198 In addition, the inspector reviewed Procedure 3107, Sample Handling, April 6, 1988. Step II.b specifies that surveys will be conducted to determine the radiation dose levels of the rabbit. The dose rate of the irradiated samples that are pneumatically delivered to the Neutron Activation Laboratory were limited to approximately 100 mrem /hr at two inches from the rabbit's surface. The inspector also reviewed Procedure 9280, Personnel Monitoring. Rev. 1, October 21, 1988. Step 6.2.1 specifies that personnel surveys of the hands and feet, at a minimum, shall be performed at the exit to the RCZ (either from the vestible to the outside or from the change room area to the NNRC building). NNRC personnel have been trained on the use of the direct reading survey instruments for performing personal frisks. This item is considered closed, (Closed) Violation 50-160/87-03-03: Failure to wear protective clothing and personnel monitoring devices; and failure to follow a radiation work permit (RWP).
The inspector reviewed the licensee's response provided in a letter from R. A. Karem (Ga Tech) to J. N. Grace (NRC) dated June 15, 198 The inspector also reviewed Procedure 9302, Protective Clothing Requirements, Rev. O September 9,198 Step III.B specifies that personnel will normally remove protective clothing at the step-off pad exit of a designated contaminated are Radiation Safety Manual (RSM), July 1987, Step V.F.1.b states that protective clothing appropriate to the conditions shall be worn at all times when working with loose radioactive materials. During tours of the facility, the inspector observed personnel properly wearing protective clothin Additionally, the inspector reviewed the revisions to the RSM approved by the Nuclear Safeguards Committee dated September 9, 1988, which contained the facility's requirements for wearing personnel monitoring devices. The revised portion of the RSM required that for routine personnel monitoring, radiation workers shall wear a single monitoring device (film badge), which shall constitute the official record of personnel exposure at Georgia Tec Only in cases where l there is overwhelming evidence that this value is incorrect, shall other means of assigning personnel exposure be utilized. The revised
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! RSM also specified the use of the PIC for day-to-day dose control.
l Additionally, at a minimum, personnel monitoring is required when it
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is anticipated that an individual will accrue 25% of the quarterly
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exposure limit of 1.25 re Finally, the inspector reviewed Procedure 9306, Preparation and Maintenance of RWPs, Rev. O, September 9, 1988, and observed how ii addressed the concerns in the violation for failure to perform HP monitoring of a job from start to finish as required by RWP 635 Step III.B.5 specifies that continuous HP coverage shall be established for high risk work or work with unknown risk (eg. removal of experiments from the reactor).
Additionally, the procedure required routine coverage to be established for work with relatively well established risk factor Routine coverage consisted of a HP staff person periodically checking the work in progress, or at predetermined critical steps or hold points. This item is considered close e. (Closed) Violation 50-160/87-03-04: Failure to use authorized beam ports; failure to specify experimental changes on check list; failure to obtain experimental approval; and failure to survey rabbit on removal from reacto The inspector reviewed the licensee's response provided in a letter from R. A. Karem (Ga Tech) to J. N. Grace (NRC) dated June 15, 198 Additionally, the inspector reviewed Procedure 3100, Experimental Approval Form, Rev. 5, October 21, 1988, and Procedure 3102, Quality Assurance for Experiments, Rev. 2, October 21, 1988. Procedure 3100 contained an operator certification form, which stated that reactor operations has reviewed the experiment and certified it complied with the description of the experiment and was suitable for irradiatio Step 5.4 of Procedure 3102, Conduct of Experiment, states that prior to the beginning of the experiment, Reactor Operations shall review the physical construction and the experimenter's plan of operation to assure that it conforms to the approved Experiment Descriptio Additionally, it was required that the Reactor Operator's Certification be added to Procedure 3100, Experimental Approval For Also, this step required that Reactor Operations certify that the experiment was conducted as planned and to note any deviation These procedural requirements should preclude similar violations from occurring. The inspector also reviewed Procedure 3107, Sample Handling, dated April 6,1988. Step II.b requires that two persons be present when irradiated containers of radioactive materials are opened in the fume hood. The procedure required one person to open the container, while the second person conducts the surveys to determine radiation dose levels and whether or not there is loose contaminatio The procedure stated that the two person requirement did not apply to opening rabbit samples in the fume hood of the Neutron Activation Laboratory. The activities of irradiated samples that are pneumatically delivered to the Neutron Activation Laboratory were limited to 100 mrem /hr at two inches from the rabbit surfac This item is considered close _ _ _ - - - - - _ - _ _ _ _ _
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9- (Closed)' Violation 50-160/87-03-05: Failure to evacuate the NNRC at the sounding of a criticality alarm on May 1,198 The inspector reviewed the licensee's response provided in a-letter dated June 15, 198 Additionally, the inspector res Ysed Procedure 6010, General Rules and Guides for Handling' Emergencies,
'Rev. 1, December 30, 1988. Step 5.2.5 specifies that an individual's response to a sounding. siren, fire alarm, or verbal . command declaring an emergency on the public address system shall be:
Immediate evacuation by the safest rout Assembling in the northwest corner of the parking lot for accountabilit *
Providing to the Emergency Director, any information about the emergenc In addition Emergency Procedures, Part IX, Procedure for Personnel-Monitoring, dated September 13, 1985, described 'the current accountability procedure. The procedure listed NNRC personnel plus other. contractors occupying several laboratories within the facilit The inspector observed that the present accountability list wa obsolete since. many persons on the list no longer occupied the facility'and newly hired employees were not included on the list. At-the time of this inspection, the licensee was in the process of approving an updated accountability procedure. The licensee expected to complete the revision of the accountability list for approval by the Nuclear Safeguards Comittee which was scheduled to meet on February 3, 1989. This item is considered close . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on January 30, 1989. Additionally, the inspector discussed with a licensee representative an oral commitment made to the NRC concerning the removal of byproduct materials from a shed during' a telephone conversation on February 16, 1989. The inspector summarized the scope and findings of the inspection, including the UR The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietary. Dissenting comments were not received from the licensee. Licensee management was informed that the six violations discussed in Paragraph 5 were considered closed.
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Item Number Description and Reference 50-160/89-01-01 URI - Reevaluate the appropriate gaseous effluent release data and direct radiation environmental-data to substantiate the annual environmental radiation dose estimates since 1985 (Paragraph 3).
50-160/89-01-02 IFI - Followup on licensee commitment made to the NRC to remove the byproduct materials from the shed located near the southeast corner of the restricted area perimeter fence (Paragraph 3),
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