IR 05000160/1993002

Insp Rept 50-160/93-02 on 930923-30.Violations Noted.Major Areas Inspected:Organization & Staffing,Radiation Control, Environ Surveillance & Monitoring & Transportation

ML20059K675
Person / Time
Site:	Neely Research Reactor
Issue date:	10/29/1993
From:	Bassett C, Curtis Rapp, Rogers W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059K649	List: IR 05000160/1993002 ML20059K644 ML20059K656
References
50-160-93-02, 50-160-93-2, NUDOCS 9311160140
Download: ML20059K675 (20)

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NUCLEAR REGULATORY COMMISSION y *t REGloN 11 g- A '.S 101 MARIETTA STREET, N.W.. SUITE 2900

.% ;p ATLANTA. GEORGIA 303234199

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. Report No.: 50-160/93-02 Licensee: Georgia Institute of Technology  !

225 North Avenue Atlanta, GA 30332 Docket Nos.: 50-160 License No.: R-97 ;

Facility Name: Georgia Institute of Technology Research Reactor Inspection Conducted: September 23-24 and 27-30, 1993  ;

P Inspector: f-- /0M9/93 l Curt J. Rapp( fleactor Inspector DateSidn6d' ,

Inspector: d&h

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8 9 M2 Craig H. Bassett, Senior Radiation Specialist D(te Signed .

Approved: I Y' 8 Walter G. Rogers // Acting Chief Dgt'e i'gned ,

Operational Propam Sections / >

Operations Branch 4 Division of Reactor Safety .,

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SUMMARY

Scope: This routine, announced inspection involved onsite review of radiation protection and operational program activities for Class I research reactors including organization and staffing, radiation control, environmental surveillance and monitoring, and transportation. This inspection also involved review of licensee <

actions concerning Inspector Follow-up Item .j Results: The staffing and current organizational structure met Technical .

Specification requirements and was. adequate to implement the ?

licensee's radiation protection and operational' programs. Since the last inspection, the position of Manager, Office of Radiatio :

Safety has been filled.. The Nuclear Safeguards Committee'1s .'

functioning as required; however, a violation in the" area of-audits was identified. The licensee completed revising two radiation protection procedures concerning respiratory protection '

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9311160140 931101 PDR ADOCK0500gO G

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and environmental monitoring. Strengths in the licensee's '

radiation protection program were noted concerning external and internal exposure control through maintaining low radioactive contamination levels in the facility and low radiation exposure to personnel. An open item was identified relating to not maintaining the SSB minimum angle during SSB calibration testing as required by TS 3.1.d. No analysis or test exception addressed this method of testing. Additional observations in the licensee's operational program were noted in the.following areas, e The procedure for reactor startup contained-" unclear" guidance for monitoring of period meters or recorder during approach to criticalit e Two LPG fueled fork trucks were stored in the reactor bay near reactor safet e Records were not consistently maintained in a readily retrievable locatio e There were several discarded batteries in the area of the emergency lighting generator. Also, the firehose sections to be used in an emergency, were found lying on the floor in standing wate e Descriptions of experiment's reactivity effects were unclear as to how previous Jxperiments related to the experiment

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Within the areas inspected, three apparent violations were note One invo'.ved failure to follow procedures for performing radiation ,

level nd contamination level surveys and for completing and maintaining shipping papers for radioactive material shipment ;

Another dealt with failure to follow 49 CFR Part 172 requirements '

for listing the chemical form and including a 24-hour monitored '

emergency telephone number on the shipping papers of shipments of ,

radioactive materials. Also, the NSC was not auditing the ;

operator requalification program as required by TS 6.2.e(ll). ;

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REPORT DETAILS

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. Persons Contacted Licensee Employees ,

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W. Downs, Senior Reactor Operator

• R. Ice, Manager, Operational Radiation Safety

• E. Jawo'eh, Health Physicist R. Karam, Director Neely Nuclear Research Center

• D. Parker, Senior Reactor Operator

• B. Statham, Manager of Reactor Operations J. Taylor, Senior Safety Engineering Assistant Other licensee employees contacted included office personne NRC Personnel

• Rogers, Reactor Inspector-DRS

• C. Rapp, Reactor Inspector-DRS

• C. Bassett, Radiation Specialist-DRSS

• Attended exit interview on February 21, 199 A list of acronyms and initialisms used throughout this report is provided in te n p . Organization, Logs, and Facility Tour (39745) Organization and Staffing Technical Specification 6.1 deta",s the organizational structure, position responsibilities, mir nm qualifications of key supervisory personnel, and the reporting " in of command at the GTRR. The inspectors reviewed and discussed with licensee personnel, the current staffing involved in conducting routine and non-routine activities at the GTR The inspectors noted that, since the previous NRC inspection, the position of the MORS had been filled. The individual who accepted the position began work full-time at the GTRR in October 1992. The staff performing HP duties at the GTRR and reporting to the MORS consisted of two full-time individuals, a Senior Safety Engineering Assistant and a Health Physicist, and three part-time student technicians. The inspectors determined that the current staffing was adequate to ,

conduct routine and non-routine radiation protection activities at the :

GTR .,

Operational staffing consisted of one full-time and two part-time -

licensed SR0s. The inspectors determined this staffing was sufficient 4 to conduct current operations activities. The inspectors also found

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that three individuals were in training for R0 licenses. These additional licensed operators should provide for more flexible scheduling of reactor operations and surveillance Review of Operations Logs  !

The inspectors reviewed the control room log books to verify they were adequately maintained. Entries were made for changes.in reactor status or significant facility problem Experiments inserted _or remaining in the reactor were noted on a daily basis. =However, it was not clearly documented when experiments were removed. The licensee said they.would more clearly document when experiments were removed, Facility Tour .

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The inspectors toured the reactor bay, control room, basement, and ;

emergency lighting generator room. During this tour, the inspectors - t observed personnel performing various tasks including surveying the containment building and operating the reactor. The individuals were noted to be practicing good ALARA techniques and were observed wearing monitoring devices as required. Housekeeping was generally acceptable; however, some deficiencies were note (1) Reactor Bay and Control Room The reactor bay rea floor was clean and free of unnecessary clutter. The inspectors observed that two LPG fueled fork trucks were being stored in the reactor bay near ECCS piping and components. The inspectors questioned if a fire or explosion hazards review had been conducted. The licensee said that'such a review was not required. During the exit meeting, the licensee stated they would designate a storage area in the reactor bay for these fork trucks that would not be near equipment essential to reactor safety. Use of the designated storage area will be '

reviewed during future inspections and is identified as IFI 50-160/93-02-01, "Use of the Designated Storage Location for Fork ..

Trucks." The inspectors did not observe any deficiencies in '

control room housekeepin (2) Basement The basement area was well maintained. The floor area around the

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D2 0 and primary cooling pumps was clean. The inspectors noted the indicator needle for primary cooling water pressure was- !

substantially bent from vertical, evidently due to overrangin The accuracy of this indicator was questionable but no tag or-work request was present. Water in the piping gallery from a leak in the Bismuth Shield Cooling System could exacerbate the spread of contaminated floor space. The licensee had recognized i

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Report Details 3 this hazard and placed a single step-off pad at the entry to the-piping gallery. The licensee stated this leak would be repaired during a planned, but as yet not approved, modification to the Bismuth Shiel >

(3) Emergency Lighting Generator Room This area was significantly neglected for routine housekeepin ;

For example, several unused and leaking batteries were stored in -

the area of the emergency lighting generator. Two firehose sections, used for backup water supply in an er?rgency, were lying on the floor in standing water. The licensee stated they intended to remove the old batteries and modify the backup water-supply so that only a single firehose section was needed. This single firehose section would be kept in a rack above the floo ,

Cleaning of this area and modification of the backup water supply

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will be reviewed during future inspections and is identified as IFI 50-160/93-02-02, " Emergency Lighting Generator Room

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Housekeeping and Backup Water Supply Modification."

No violations or deviations were identifie ,

3. Nuclear Safeguards Committee Review and Audit Activities (40745)

Technical Specification 6.2, details the composition of the NSC,

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qualifications of its members, its responsibilities and authority, and the '

meeting frequency of the NSC. The inspectors reviewed the _ qualifications-of the NSC members, as reported in the 1992 annual report, and concluded the qualifications of the NSC members met the requirements of TS 6.2. -The inspectors noted that two NSC members had been replaced. The replacement members had essentially the same qualifications as the previous member The inspectors attended a meeting of the NSC and also reviewed the minutes of the meetings held by the NSC since the last inspection. The inspectors noted that the meetings were being held at the frequency required by TS 6.2. The inspectors verified that the committee was functioning as outlined in TS 6.1, and that issues reviewed and discussed were appropriate. Some of the issues discussed during NSC meetings included:

(1) modifications to procedures, (2) experiments to be performed, (3)

Safeguards _ & Security and Emergency Preparedness Plan reviews, (4)

facility modification requests, (5) the results of NRC inspections, and (6) assignments for the members of the NSC during the annual audit of-facility operation ,

Technical Specification Section 6.2.e requires that the NSC audit the safety aspects of reactor facility operations in order to provide management with an independent review of these aspects. This section also i

. requires the NSC to review and approve proposed changes to procedure :

The inspectors reviewed the audits conducted by the NSC during 1992 and !

1993. The auditors found various discrepancies which mainly involved procedural problems and minor non-compliances with the procedures. The ,

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NNRC management prepared adequate responses which addressed the audit findings and the actions that had been completed to correct the problems found. In the areas covered, the audits were adequate; however, the inspectors found that auditing of the licensed operato requalification program was not being conducted by the NSC. The NSC had delegated this audit function to the MORS and directed this audit be performed annually and submitted to the NSC for review. The MOR3 was not a member of the NSC described in the 1992 annual report. Technical Specification 6.2.e(11) :

requires the NSC to audit the licensed operator requalification program ;

biennially and did not allow for the NSC audit function to be delegated _to non-NSC members. Failure of the NSC to perform the required licensed >

operator requalification program audit is identified as VIO 50-160/93-02-03, " Failure to Conduct Biannual Licensed Operator Requalification Program Audit."

One violation was identifie t 4. Training (41745) -

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The inspectors reviewed control room log books, licensed operator requalification examinations, the NRR-approved licensed operator requalification program, and other selected records to verify licensee commitments were met. The inspectors found the program was adequately conducted. The licensed operators were meeting the regulatory requirements for active license Requalification examinations were given annually as required by the NRR-approved requalification program. This examination consisted of a written examination and practical demonstration. The practical demonstrations were comprehensive and included an oral discussion of abnormal and emergency event response. However, during a review of.the requalification written examinations, the inspectors noted'the technical content of the section concerning regulatory oversight was weak (e.g.,

applications of 100FR50 and 55 requirements).

Training on procedural changes was acceptable, but there was no training-on facility modifications. The inspectors discussed this with the licensee and was told that, due to the small staff, training on facility modifications was not necessary. During further discussion at the exit-meeting, the licensee stated they would document training on facility modifications similar to training for procedural change $

The. inspectors reviewed licensed operator medical records to verify the two year medical examinations required by 10 CFR 55.21 had been performe Initially, two med! cal examinations were not found in the licensed operator file The licensee later produced these examinations from the personnel files. Maintaining licensed operator records in a reasonably retrievable records management system will be reviewed during future inspections and is identified as IFI 50-160/93-02-04," Maintenance _of Facility Records." The inspectors questioned how the medical examinations were scheduled. The licensee stated recurring activities were entered-

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into the work order system. Whenever the activity was due, a work order was generated and issued to the responsible individual. However, the two year medical examinations were not found on the work order system. The ,

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inspectors concluded the two year operator medical examinations were conducted as required by 10 CFR 55.21. The inspectors did determine the possibility extsted for this requirement to be missed because this activity was not tracked on the work order syste L

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No violations or deviations were identifie . Procedures (42745)

The inspectors reviewed the procedures listed in Appendix A. The inspectors determined the procedures were generally clear in direction, and the actions accomplished the intent of the procedur Operations Procedures The procedures used to control reactor operations were adequat However, Procedure 2002 was unclear about indications to be monitored ,

during approach to critical. During a routine reactor startup on September 28, 1993, the reactor automatically scrammed on high positive period. The operator at the controls properly withdrew and banked the SSBs at 8*, 10*, and 15*, as required by Procedure 200 'l However, as the operator was withdrawing the SSBs to 20*, the reactor i automatically scrammed on high positive period. The setpoint for the high positive period was s 15 seconds. During SSB withdrawal, the operator monitored the period recorder but did not recognize the recorder pen was not responding. The operator did not check other

! control room indications such as the period meter. Procedure 2002 i directed the operator to monitor the power level recorder and to I maintain reactor period greater than 20 seconds. However, the procedure was not clear if these directions applied during the approach to critical. Also, the procedure did not direct the operator

to monitor the period meters or recorde The inspectors discussed l these procedural weaknesses with the licensee. The licensee agreed ;

with the inspectors and stated Procedure 2002 would be modifie l

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These modifications will be reviewed during future inspections and is !

identified as IFI 50-160/93-02 05, " Modification of Procedure 2002 i Guidance During Reactor Startup." Health Physics Procedure Revision and Review

The inspectors discussed the status of the program to review and l revise the HP procedures with licensee personnel. During the previous ;

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inspection, the inspectors noted that Procedure 9300 and Procedure !

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9400 needed to be revised to bring them up-to-date and provide more- !

complete guidance for licensee personnel. The inspectors noted that i these procedures have been revised in terms of both format and

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cont'ent. The inspectors reviewed the revised procedures and determined that they had been reviewed by the NSC and were adequat j The inspectors informed licensee management that IFI 50-160/92-03-0 i is close No violations or deviations were identifie ,

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6. Surveillance Procedures and Records (61745)

The inspectors reviewed the surveillance procedures listed. in Appendix- A and selected completed surveillances. The licensee was using.the work-  :

order system to schedule the surveillances. A' fixed number of. days wa ,

used as the basis for the due date of a surveillances. During review of j completed surveillances, the inspectors found instances where the  ;

surveillance was performed substantially past the due date. No . l explanation of limiting factors (i.e. facility conditions, unavailability ,

of personnel, etc.) that would impact performance of the surveillance wa ,

noted in the comments section. Additionally, only- one completed minimum ,

SSB angle determination for 1990 was found in the surveillance. record .

This was an annual surveillance and-Procedure 7247 designated this- l surveillance as a life-time record. The licensee was able to produce  ;

completed surveillance for 1991 and 1992. The inspectors asked if any ,

additional completed surveillances were available. The licensee stated j they had recently changed the records retention period for this particular '

procedure and no other records were available. Maintaining surveillance a records in a readily retrievable records management system will be  :

reviewed during future inspections as part of IFI 50-160/93-02-0 On September 29, 1993, the inspectors witnessed reactivity worth.~ l measurement of the SSBs. This activity was controlled by Procedure 724 j In preparation for these measurements, the reactor was taken critical by ,

withdrawal of the SSBs. Procedure 7246 directed that each SSB be '

successively fully inserted and then withdrawn as the regulating rod was 1 inserted to maintain a constant flux. This process was repeated until the -

SSB was fully withdrawn. Technical Specification 3.2.1 required the SSBs' q be positioned above the minimum angle prior to critical. The safety basis 1 for the minimum angle was that a negative period scram would be generated ..

before a positive reactivity insertion occurred-if the SSB were to free l fall past full insertion. There was' no test exception or analysis that 1 addressed the SSBs being inserted below the minimum angle during this j test. .The inspectors discussed this with the licensee. The licensee- 1 stated they interpreted TS 3.2.1 as requiring the minimum SSB angl l whenever the reactor was critical. Therefore, because-the reactor was 1 maintained .subtritical during the test,- TS 3.2.1 did not apply. Procedure j 7246 directed the reactor-be made subcritical before fully inserting the !

SSB. During this test, the reactor was maintained subcritical by E 0.28hk/k. Furthermore, the licensee contended that a negative period .. ,

scram would not occur from a subcritical condition even if the' SSB was to i

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free fall from fully withdrawn. The inspectors questioned whether the licensee had fully considered the safety basis for minimum SSB angle when

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Report Details 7 making this TS interpretation. This evaluation is identified as IFI 50-160/93-02-06, " Safety Evaluation of Minimum Angle During SSB Calibration."

No violations or deviations were identifie . Experiments (69745)

The inspectors reviewed-selected experiments performed during 1993 before :

this inspection and the procedures used to control experiments using the l GTRR. The inspectors determined experiments were well controlled and '

personnel adhered to established procedures. However, when reviewing the- .

description for experiment 93-24, the inspectors noted that experiment '

93-18 was used as a reference for reactivity effects determination Experiment 93-24 was the irradiation of a Lutetium foil, and Experiment 93-18 was the irradiation of a Nickel foil with a Cadmium cover. The inspectors questioned how experiment 93-18 could be referenced for experiment 93-24 because they were differe:t in materials and configuration. The licensee- stated experiment 93-18 had a much higher

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absorption cross-section because of the Cadmium cover and, therefore, was -

a very conservative comparison. The licensee stated they were attempting -

to improve experiment descriptions to more clearly describe the expected i effects on reactor operatio No violations or deviations were identifie . External Exposure Review - Radiation Control (83743)

, Exposure Control

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10 CFR 20.101 delineates the quarterly radiation exposure limits to -

the whole body, skin of the whole body, and the extremities for'

individuals in restricted areas. 10 CFR 20.202 requires that appropriate personnel monitoring devices be worn by personne The inspectors reviewed and discussed, with licensee representatives, the exposure records for persons assigned to work at the NNRC for the #

periods April I through December 31, 1992 and from January 1 through July 31, 1993. It was noted that the licensee used film badges, '

supplied by a National Voluntary Laboratory Accreditation Program approved vendor, for measuring official whole body dose and .

thermoluminescent dosimeters to measure extremity exposure. Vendor- '

specifications reported a detection limit of 10 mrem for the. dosimetry supplie .

The highest quarterly whole body dose received durin.g any quarter in 1992 was 50 mrem and during 1993 (to date) was 20 mies. The highest accumulated individual exposure for the year 1992 was 150 mrem. So far during 1993, the highest total accumulated individual exposure was

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40 mrem. The licensee indicated that the majority of this exposure was attributable to the handling of experiments and to the work involved in the irradiation of specimen ! Radiation Work Permit Program

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The inspectors reviewed selected RWPs used during 1992 and to date during 1993. The RWPs dealt with various activities including insertion and removal of experiments from beam ports, various maintenance activities, verification of Emergency Core Cooling System flow, fuel element self-protection measurement and inspection, removal of shield blocks from the Bio-medical Shutter, and radioactive waste compaction in the NNRC " Barn." Through paperwork review and  :

discussions with licensee representatives, the inspectors determined that the RWPs used were appropriate to control _ work, keep exposures as low as reasonable, and eliminate or control contaminatio The radiation protection requirements specified by the RWPs, including dosimetry, surveys, protective clothing, air sampling, and HP coverage of the jobs, appeared to be adequat No violations or deviations were identifie . Internal Exposure Review - Radiation Control (83743)

10 CFR 20.103 establishes the limits for exposure of individuals to concentrations of radioactive materials in air in restricted area Section 20.103 also requires that suitable measurements of concentrations of radioactive material in air be performed to detect and evaluate the airborne radioactivity in restricted areas and that appropriate bioassays- '

be performed to detect and assess individual intakes of radioactivity.- Bioassay Program  ;

The inspectors reviewed selected results of the bioassay analyses that had been performed to date during 1993. All the results had been reviewed by the individual assigned oversight responsibility, as well as by the MORS. During that period the highest intake for a seven consecutive day period was calculated to have been 1.8 microcuries of tritiu This exposure had occurred during cleanup of cooling water-that had leaked from around the Bismuth block filter at the Bio-medical Port of the reacto As a result of this exposure, a total of 0.3 MPC-hrs were assigned to the individual. The licensee indicated that MPC-hrs were not tracked i formally but were tracked informally by those reviewing the results of _ l the analyses and that any problems would be noted by those responsible for the progra i

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Report Details 9 i Air Sampling

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The inspectors discussed the air sampling program with licensee representatives. The program involves continuous air sampling :

performed by air samplers located on top of the reactor, on the main floor of the reactor building, and in the basement of the reactor .

building. The filters from each of these air samplers are changed weekly and analyzed to determine the concentration. of alpha and beta-gamma radioactivity in the ai The program also includes air sampling performed as required by RWP -

during specific work evolutions. The filters collected as a result of these jobs are also analyzed to determine airborne radioactive

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contamination and the results used to assign MPC-hrs as neede t

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The inspectors reviewed the results of selected air sample analyses :

since the last . inspection. The results indicated that the airborne concentration had not been above 25 percent of the MPC of the radionuclides specified in 10 CFR 20, Appendix B, Table 1, Column Airborne concentrations were generally in the range of 10~,' to 10-12 microcuries per milliliter beta-gamma and lower for alph No violations or deviations were identifie . Surveys, Posting, and Contamination Control - 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 inspectors performed radiation level surveys of various areas in I the reactor building using NRC instrumentation. The inspectors '

verified that the radiation levels indicated on licensee surveys were representativ (1) Radiation Surveys TS Section 6.4.b(6) requires that the procedures be provided and utilized for radiation and radioactive contamination contro Procedure 9250,-Facility Contamination Surveys, Rev. 4, dated August. 13, 1992, establishes the guidelines used by the licensee for conducting and documenting the routine radiation survey program for the NNRC. Step 5.2.8 of the procedure requires that routine neutron radiation surveys shall be performed in the general areas of the reactor building when the reactor is operating at a level of 2: 1 MW. In the reactor building, neutron measurements shall also be made during insertion and removal of experiments in the reactor. Appendix A of the procedure ;

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Report Details 10 specifies a requirement that a semi-annual neutron radiation :

survey be conducted in the containmen The inspectors reviewed the routine radiation surveys that had been conducted during 1993 and selected radiation surveys performed in support of RWPs. Generally the licensee was '

completing all the surveys required by procedure. However, the inspectors noted that no routine neutron radiation' surveys were taken when the reactor was operating at a level of 2: 1 MW. Also, neutron measurements were usually taken when experiments were inserted or removed from the horizontal beam ports but not when experiments were inserted or removed from the vertical beam ports. No semi-annual neutron radiation surveys were note '

When these issues were discussed with the licensee personnel, they indicated that routine neutron radiation surveys were not taken, that neutron measurements were only taken when using the ;

horizontal beam ports, and that no semi-annual neutron radiation surveys were being performe The inspectors informed licensee representatives that the failure to perform the surveys required by the procedure was an apparent violation of TS Section 6.4.b requirements and is identified as VIO 50-160/93-02-07, " Failure to Follow Procedure." l (2) Contamination Surveys TS Section 6.4.b(6) requires that the procedures be provided and utilized for radiation and radioactive contamination contro ll Procedure 9304, " Routine Facility Radiation Surveys, Rev. 2,"' l dated June 25, 1992, specifies the frequency and location of the ;

contamination surveys to be performed. Appendix A of the .l procedure specifies that contamination surveys at a frequency of i twice per week are to be performed of the entry / exit points in -

the RCZ, of all containment step-off-pads, of all containment J building pathways, and of the top of the reacto l The inspectors reviewed the records of twice weekly, weekly, and monthly contamination surveys performed in the RCZ. The survey-results were discussed with licensee representatives. All the i required contamination surveys had been performed except the j first of the two required twice weekly surveys during weeks when ;

a holiday fell on a Monday. During those weeks, only the second ;

contamination survey was performed. When this was discussed with '

licensee representatives, they indicated that they generally !

performed the first of the twice weekly surveys on Monday and, if- 1 that happened to be a holiday, the survey was skipped and not i performed on a Tuesday or another da l The inspectors informed licensee representatives that the failure to perform the surveys requited by the procedure was another l

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i example of an apparent violation of TS Section 6. ,

requirement j

, Posting 10 CFR 20.203 specifies the requirements for posting radiation areas, f high radiation areas, and radioactive material area l, Posting of entrances into the controlled area and' labeling of !'

containers were observed and discussed with licensee representative The postings appeared to be adequate. The labeling of radioactive material also appeared to be in compliance with the regulation l Personnel Contamination Control i

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Procedure 9280, Personnel Monitoring, Revision 1, dated October 21, 1988, requires in Part 6.2 that, at the exit to the Reactor Control ;

Zone or when exiting a potentially contaminated area as designated by the presence of a step-off pad, hands and feet, at a minimum, shall be '

monitore l Following tours of the RCZ and after observing work activities, the l inspectors noted that all personnel observed exiting the contro11ed'

area performed an adequate personal surve l One violation was identified as noted abov . Environmental Protection (80745) ,

10 CFR 20.106(a) requires that the licensee not possess, use, or transfer +

licensed material so as to release to an unrestricted area radioactive material in concentrations which exceed the limits specified in 10 CFR 20, Appendix B, Table II, except as authorized pursuant to 20.302 or ,

20.106(b). ,

Technical Specification 6.7.a requires the licensee to submit an annual l operating report covering the previous year to the NRC which outlines the- i quantities of radioactive effluents reluned from the plant and provides ,

estimates of the likely resultant exposure to individuals and population ;

groups in areas surrounding the facilit i Gaseous Effluents -l J

The inspectors reviewed the licensee's Annual Operating Report :)

covering the period from January 1, 1992 through December 31, 1992, to ascertain whether releases of liquid and gaseous radioactive material j

to the environment were within regulatory limits. The licensee's only measurable gaseous waste release was argon-41 (Ar-41). i The following table summarizes the amount'of Ar-41 released during 1992:

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Average Release Instantaneous ,

Total Concentration Release Rate % Tech !

Quarter Release (Ci) (microcuries/cc) (microcuries/sec) Spec * ;

1 21.810 1.857x10" 475 81.19 i

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2 11.324 9.643x104 228 38.97 ,

3 2.686 2.287x10* 9 .24 l 4 3.653 3.111x10 4 6 .72

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• TS 3.5.b(1) The Maximum Instantaneous Release Rate limit equals 585 microcuries/se i There were no measurable amounts of gaseous tritium released ar,d no measurable amounts of iodine or particulates release I

< Liquid Effluents  !

The predominant nuclides released via the licensee's liquid effluent pathway included tritium and Cobalt-60. [The presence of Cobalt-60 was not the result of reactor operations but was attributable to material stored in the spent fuel storage pool that falls under the State of Georgia Radioactive Materials License No. 147-1.] There were no fission products released via the liquid effluent pathway. In addition, there were no measurable quantities of gross alpha radioactivity reported by the license The quantities of radioactive material released via the liquid '

effluent pathway are summarized below:

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(1) Cobalt-60 .

Average Release Quarter Rel (Ci) (m ro ur es cc)* Se  !

l 0.000016 8. 00x10~" <1 -

2 0.000027 1.35x10 <1 i 3 0.000048 2. 40x10~" <1  !

4 0.000017 8. 50x10~" <1  ;

(2) Tritium Average Release Total Concentration % Tech  ;

Quarter Release (Ci) (microcuries/cc)* Spec 1 1 0.00123 6.15x10~" <1 "

2 0.00485 2.43x10* <1  !

3 0.01841 9.21x10 4 <1 1 4 0.00494 2.47x10* <1 l l

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• Average release values were based on a Georgia Tech campus water '

discharge rate of 2.00x10" ml/ quarte Environmental Monitoring The licensee's environmental monitoring program consisted of measuring direct radiation from the . facility and from gaseous effluents by means ,

of a system of 30 film badges positioned around the perimeter fence and at other locations on campus, typically downwind from the facility. The film badges used for this purpose have a lower limit of detection of approximately 10 mre A review of the exposures of the 30 environmental film badges indicated that none showed radiation exposure above background due to reactor operations during 1992. Nevertheless, several badges showed '

radiation exposure above background levels. One such badge was located on the roof of the NNRC building and two others were located near the " barn" behind the reactor containment building. However, the '

licensee determined that exposures registered on the badge located on

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the NNRC building were attributable to environmental damage; e.g.,

rain or excess heat. The exposures registered on the badges located i near the " barn" were due to the presence of Radium-226 sources stored in that building. The licensee subsequently consolidated the sources for shipment and they were disposed of as radioactive wast ,

The highest, lowest, and annual average levels of radiation for.the sampling point with the highest average radiation exposure due to reactor operations were all less than 10 mre No violations or deviations were identifie . Transportation (86740) i

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10 CFR 71.5 requires each licensee who transports licensed material outside the confines of its plant or other place of use to comply with the applicable requirements of the Department of Transportation (DOT) in 49 CFR Parts 170 through 18 Chemical Form Description 49 CFR 172.203(d)(3) requires.that the shipping papers for a shipment' i of radioactive material contain a description of the physical and chemical form of the material being shipped. The inspectors reviewed the paperwork associated with the various radioactive material shipments that had been made during 1993 to dat The shipping papers routinely listed the physical form of the material but none listed the chemical for The inspectors informed licensee representatives that the failure to list the chemical form of the radioactive material being shipped was

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an apparent violation of 49 CFR 172 requirements and is identified as !

VIO 50-160/93-02-08, " Failure to Comply with 49 CFR 172 Requirements." l 1 Emergency Response Telephone Number

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49 CFR 172.604 requires that a person (organization) who offers a hazardous material for transportation must provide a 24-hour emergency response telephone number (including the area code) for use in the event of an emergency involving the hazardous material. The  !

inspectors reviewed the shipping papers of the various radioactive !

material shipments that had been made during 1993 to date. The number 1 listed by the licensee on the shipping papers as the emergency I telephone was that of the reactor control room. When asked about this, the licensee indicated that the telephone is only monitored' l during normal working hours, generally 8:00 a.m. until 4:00 _

The inspectors informed licensee representatives that the failure to provide a 24-hour emergency response telephone number for use in the i event of an emergency was another example of an apparent violation of .l 49 CFR 172 requirement !

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Technical Specification Section 6.4.b(6) requires that the procedures i be provided and utilized for radiation and radioactive contamination l control. Procedure 9310, " Radioactive Material Shipment, Rev. 0," i dated March 21, 1991, requires in Step 5.2.2.4 that Form RS-87 be '

completed appropriately. Upon reviewing the shipping papers (Forms RS-87) of the various radioactive material shipments that had been _

made during 1993 to date, the inspectors noted that certain Forms had been completed but contained incorrect information. Shipment 93-05 listed the material being shipped as being Radioactive Material, 'i N.O.S.,; however, the material was shipped as Radioactive Material, ;

Limited Quantity, N.0.S. Shipments 93-08 and 93-10 listed the I material being shipped as being Radioactive Material, Limited Quantity, N.O.S., UN2911; the proper identification number was UN291 The inspectors informed licensee representatives that the failure to !

complete the RS-87 Forms appropriately as required by procedure-was another example of an apparent violation of TS Section 6. i reouirement .i

! Package Surveys .i Technical Specification Section 6.4.b(6) requires that the procedures be provided and utilized for radiation and radioactive contamination :

control. Procedure 9510, " Radioactive Material Shipment, Rev. 0,"

dated March 21, 1991, requires in Step 5.2.8.5 that radiation level readings for each package and the vehicle shall be documented on Form RS-28. Step 5.2.9.1 requires that contamination control data be ;

documented on Form RS-2 Step 6.2 requires that Forms RS-28 and RS-

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35 which contain the survey data for the shipments shall be maintained i along with the shipping papers for the life of the facility. During i the review of the shipping papers of the various radioactive material .

shipments that had been made during 1993 to date, the inspectors noted that there were no documented surveys showing the radiation level readings for the packages for shipments 93-01, 93-04, and 93-05. The ;

shipping papers had been completed using information from surveys that ,

were apparently performed, but the survey maps, Forms RS-28, were not :

located with the shipping paper ]

The inspectors informed licensee representatives that the failure to ,

maintain the survey information with the shipping papers was another i example of an apparent violation of TS Section 6.4.b requirement ,

13. Action on Previous Inspection Findings (92701)

(Closed) Inspectors Follow-up Item (IFI) 92-03-01: Follow-up on the I Licensee's Revisions to Procedure 9300, " Respiratory Protection, and Procedure 9400, Environmental Monitoring." During a previous inspection, the licensee had agreed that the two procedures concerning respiratory protection and environmental monitoring needed to be revised. During this inspection, the inspectors reviewed the revisions that had been made to these procedures (see Paragraph 2.d above). The revised procedures had been reviewed by the NSC and were adequat . Exit Interview (30703)

The inspection scope and results were summarized on September 30, 1993, with the licensee representatives indicated in Paragraph 1 above. The inspectors discussed the findings for each area reviewed. The licensee's organizational controls and staffing in the area of radiation protection appeared to be adequat Internal and external exposure controls employed by the licensee have been effective in maintaining exposures to individuals as low as practicable. Posting and labeling of radioactive ;

material throughout the facility appeared to be adequate. The '

environmental protection program also appeared to be effective in maintaining releases to the environment below required limit No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by )

the inspectors during this inspection. Licensee management was informed i that IFI 50-160/92-03-01 is close l l

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Item Number Status Description (paracraph) i 50-160/92-03-01 CLOSED IFI - Follow-up on the Licensee's !

Revisions to Procedure 9300, !

Respiratory Protection, and Procedure 9400, Environmental Monitoring (5.b) R 50-160/93-02-01 OPEN IFI - Evaluation and designation of I storage location inside the reactor i bay for LPG fueled fork trucks (2.c(1)). l 50-160/93-02-02 OPEN IFI - Removal of batteries' and j cleaning of emergency lighting generator room and modification of backup water supply-(2.c(3)) !

50-160/93-02-03 OPEN VIO - Failure of the NSC to conduct-the biennial audit of the licensed ;

operator requalification program as required by Technical Specification :

6.2.e(ll) (3.)

50-160/93-02-04 OPEN IFI - Haintaining facility records in a common records management system (4.,6.) ,

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50-160/93-02-05 OPEN IFI - Enhance operator guidance in j Procedure 2002 to direct monitoring of period meters and recorder during ;

approach to critical (5.a)

50-160/93-02-06 OPEN URI - Evaluation for reactor l operations with SSBs below the I minimum angle required by Technical- 1 Specification 3.2.1 during SSB reactivity. worth calibration (6.).

50-160/93-02-07 OPEN VIO - Failure to follow procedurc ,

(10.a,12.c,.12.d).

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50-160/93-02-08 OPEN VIO - Failure to comply with 49 CFR_' I 172 requirements (12.a and 12.b).

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1 Acronyms and Initialisms ALARA As low As Reasonably Achievable CFR Code of Federal Regulations ;

ECCS Emergency Core Cooling System ,

GTRR Georgia Tech Research Reactor IFI Inspector Follow-up Item LPG Liquid Propane Gas .

MORS Manager, Operational Radiation Safety ,

MPC Maximum Permissible Concentration mrem millirem l MW megawatt l NNRC Neely Nuclear Research Center :

N. Not Otherwise Specified  :

NSC Nuclear Safeguards Committee ,

RCZ Reactor Control Zone i R0 Reactor Operator RWP Radiation Work Permit  :

SR0 Senior Reactor Operator SSB Shim Safety Blade ,

TS Technical Specifications ,

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.,.i Appendix A Procedure 2002, Reactor Operations - Precritical Startup Checklist and Shift Supervisor Approval, Revision 08, approved 08/13/92 Procedure 2006, Reactor Shutdown Checklist, Revision 06, approved 08/13/92

' Procedure 3100, Instructions for Preparation of GTRR Experiments Approval and Report Form, Revision 06, approved 08/08/98-Procedure 2601, Response to a Reactor Scram Initiated by a Safety System, Revision 00, approved 06/27/91 Procedure 4200, Changes in GTRR Design, Revision 00, approved 04/28/89' ...

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Procedure 7246, Control Element Reactivity Worth Measurement, approved !

10/30/87  :

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Procedure 3109, Instructions for Experiment Approvals, Revision 01, approved ;

09/26/91 Procedure 2020, Reactor Restart After Scram, Revision 00, approved 11/15/90 ;

Procedure 3101, Definition of Experiment Categorier, Revision 01, approved 10/21/88 Procedure 7247, Determination of Minimum SSB Angle to Generate Negative Trip, >

Revision 00, approved 01/26/90 Procedure 7211, Emergency Core Cooling System Fuel Element Flow Verification, Revision 01, approved 02/10/89 1 Procedure 7270, Flux Amplifier Calibration, Revision 00, approved 02/15/90 Procedure 4950, Tagging of Equipment Out of Service, Revision 01, approved

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12/17/92 Procedure 0010, How to Modify Procedures, Revision 01, approved 02/15/90 Procedure 2015, Reactor Power Calibration, Revision 01, approved 08/01/91

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