IR 05000186/1980004
| ML19347B119 | |
| Person / Time | |
|---|---|
| Site: | 03002278, University of Missouri-Columbia |
| Issue date: | 08/15/1980 |
| From: | Fisher W, Lovendale P, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347B112 | List: |
| References | |
| 30-02278-80-02, 30-2278-80-2, 50-186-80-04, 50-186-80-4, NUDOCS 8010010601 | |
| Download: ML19347B119 (12) | |
Text
. _ _ _ - _ _ - _. - _ _ _ _ _ _ -
.
. O U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTICN AND ENFORCEMENT
REGION III
Reports No. 50-186/80-04; 30-2278/80-02 Docket Nos. 50-186; 30-2278 Licenses No. R-103; 24-00513-32 Licensee: University of Missouri Research Park Columbia, MO 65201 Facility Name: Research Reactor Facility Inspection At: Research Reactor Site, Columbia, M0 Inspection Conducted: July 15-17, 1980
"
Inspectors:
Ehe w[tt/f 2. C. Lovendale
&
N
[9
-
-.
Approved By: W L Fish C ief
/.5' N' T/
Fuel Facility Projects and Radiation Support Section Inspection Summary Inspection on July 15-17, 1980 (Reports No. 50-186/80-04; 30-2278/80-02 Areas Inspected: Routine, unannounced inspection of radiation protection program and radwaste management program, including: qualifications; audits; training; radiation protection procedures; instruments and equipment; ex-posure control; posting, labeling, and control; surveys; notifications and reports; effluent releases; records of effluents; receipt and transfer of radioactive material; previous item of noncompliance and commitments; and IE Bulletin 79-19.
The inspection involved 44 inspector-hours onsite by
-
two NRC inspectors.
Results: Of the fifteen areas inspected under license R-103, no items of noncompliance or deviations were found in fourteen areas. Three apparent infractions were found in one area: fiCure to inform a worker as required by 10 CFR 19.12, (Paragraph 8a); fs ': ne to perform an adequate evaluation of an individual's exposure as rcw r d by 10 CFR 20.201(b), (Paragraph Ba);
failure to control access to : eba sdiation area required by 10 CFR 20.203 (c)(2), (Paragraph 8a). Of te ;,g e inspected under the broad license, two 80kO10 l
_ _ _
._
.-
.
.
.
..
items of noncompliance were found in two areas; infraction - failure to
-
pt: form air samples and/or bioassays required by 10 CFR 20.103(a)(3),
(Paragraph 8b); deficiency - failure to post a radiation area as required by 10 CFR 20.203(b), (Paragraph 9).
,
I
-
2-
,
~
"
+----w
-
r-
--
, ___ __
.
.
DETAILS
.
1.
Persons Contacted
- P.
Keenan, Assistant to the Vice President - Research
- R.
Brugger, Director, Research Reactor Facility
- 0. Olson, Manager, Reactor Health Physics
- J. Tolan, Campus Radiation Safety Officer
- N. Sunderland, Assistant Campus Radiation Safety Officer
- J. L. McKibben, Reactor Manager J. Naylor, Health Physics Technician J. Litton, Health Physics Technician S. Stewart, Health Physics Technician D. McGinty, Reactor Physicist The inspectors also interviewed other licensee employees, including chemistry technicians, licensed operators, and facility researchers.
- Denotes those present at the exit interview.
2.
General This inspection, which began with visual observation of facilities and equipment, posting, labeling, and access controls at 8:00 a.m. on July 15, 1980, was conducted to examine the routine operational radiation protection and radwaste management programs. During the initial and subsequent tours of the facility, the inspectors used licensee survey meters to perform surveys at selected locations. Posting and labeling of the areas conformed with regulatory requirements except as noted in Paragraph 9.
Areas visited during the tours included the Medi-Physics hot cell area, all levels of the containment building, and laboratories located throughout the Reactor Facility.
3.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-186/79-06): Failure to maintain records required by 10 CFR 71.62(a)(10). The licensee now maintains the re-quired records (See Paragraph 15).
(0 pen) Commitment (50-186/77-04): Evaluation of the collection effici-ency of the charcoal sampler due to high flow rate. A student research project to determine the efficiency at various flow rates continues.
4.
Organization The react,r health physics group (manager, three technicians, and one part time laboratory assistant) is responsible for health physics acti-vities under the reactor license. However, responsibility for broad license activities within the Research Reactor Facility is not clear.
-3-
._
__
_ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _
-
.
The Campus Radiation Safety Office has responsibility elsewhere on campus, but appears to have no jurisdiction within the Research Reactor Facility. The result is that broad license health physics activities there have not been well covered.
5.
Licensee Audits Reactor Advisory Committee meetings were held at the required frequency.
The inspector reviewed the minutes of these meetings and noted that very few health physics related items were discussed. The Director, Reactor
.
Facility, stated the minutes are brief notations of all items discussed and may not always reflect the subject matter.
In addition, he stated that the committee is concerned with reactor safety, as well as health physics matters.
The last audit performed by the University Radiation Safety Office was on February 6, 1979. This audit identified several potential health physics problems, some of which were acknowledged and responded to in writing by the Manager, Reactor Health Physics. During the exit inter-view, the licensee stated that due to manpower limitations the audits were not performed at the desired frequency, but that this should improve in the future.
No items of noncompliance weta identified.
6.
Training Training records indicate that the Manager, Reactor Health Physics, provides and documents radiation protection training for experimenters and other personnel new to the facility. The indoctrination is informal and tailored to meet the trainee's needs. Although this training is informal and somewhat unstructured, it appears that the requirements of 10 CFR 19.12 are met.
In addition to the oral presentation, written instruction concerning emergency procedures and laboratory conduct is issued to each trainee.
The licensee will offer video tape health physics presentations in the near future for all persons working in the reactor facility.
Health Physics Standard Operatine, Procedures are issued to research groups, reactor chemistry perscanel, reactor management, some engi-neers, and all health physics staff. Health physics technicians receive periodic individual training from the Manager, Reactor Health Physics. Records of this training are not maintained.
No items of noncompliance were identified.
-4-
,
_-
- _ - _ _ - - _ _ _ - _ _ _ _ - _
-
.
7.
Procedures The licensee has developed twenty-two Health Physics Standard Operating Procedures which are incorporated into the license by Technical Speci-fication 6.1.
The inspectors reviewed some of these procedures and pointed out at the exit interview that many of them are incomplete and loosely written. The Manager, Reactor Health Physics, stated he would review each procedure to ensure it meets the intent for the procedure.
A previous inspector 1 noted that HP-18 requires only a one point per scale calibration and discussed the desirability of two points per scale calibration for certain survey meters, to meet the recommendation of ANSI N323, 1978. The licensee reviewed this and determined that the one point calibration was adequate for their needs.
No items of noncompliance were identified.
8.
Exposure Control a.
External The vendor's film badge reports for the period August 1979 through March 1980 were reviewed. The highest whole body exposure was
,
1080 mrems which was recorded in the last quarter of 1979; however, this exposure is part of an unresolved item discussed below.
On November 8, 1979, during a reactor shutdown, two reactor operators and one health physics technician were performing a beam tube change on beam port F.
The health physics technician was providing health physics coverage and had the additional job of performing a radiation survey in the area when the reactor was restarted. During the beam tube change, some potentially contaminated water was spilled.
j The health physics technician left the area to get cleaning equipment with the understanding that when he returned the operators would assist him in cleaning up the spill. When he returned to beam port F the operators had apparently left. The health physics technician.
cleaned up the water and then proceeded to the control room to inform the operators that the spill had been cleaned up and that their assistance was not needed. He then noticed that the reactor was at 10 MW power and immediately checked his pocket dosimeter which was off-scale. A subsequent survey around beam port F
,
'
determined that the total dose rate in the area was about 2235 mrems/hr (1600 mrems/hr fast neutron, 500 mrems/hr gamma, 135 mrems/hr thermal neutron). No access controls were being used for i
this high radiation area.
Failure to inform the health physics technician of the reactor start-up and thereby of the changing radiological conditions is apparent noncompliance with 10 CFR 19.12.
1/ IE Inspection Report No. 50-186/79-06-5-
.
.
-
.
Failure to control access to the high radiation around beam port F is apparent noncompliance with 10 CFR 20.203(c)(2).
In addition to his pocket dosimeter, the technician was wearing a film badge containing NTA and beta / gamma films supplied by Landauer and also an albedo dosimeter (CaSO /Li-6 TLD) supplied by Teledyne.
Both badges were sent in for immediate evaluation. The licensee also estimated the technician's dose using dose rates determined in the survey and duration of exposure (22 minutes).
The doses from these separate determinations are compared in the following table.
,
Beta Neutron Gamma Whole Body Skin Dose (mrem)
(mrem)
Total (mrem)
(mrad)
Landauer Badge 180 750 930 320 Teledyne Badge 1700 480 2180 400 Survey 637 283 820 The licensee elected to use the Landauer film badge results as the actual whole body exposure to the technician, because they are the facility's normal supplier.
In making this decision, the licensee
,
apparently failed to evaluate the difference between the estimated gamma doses and, more importantly, apparently failed to evaluate the significant differences between their neutron dose equivelent estimated. The licensee has apparently used the neutron dose reported on the NTA film even though they were aware of fading problems associated with its use. This failure to perform an adequate evaluation to ensure compliance with the dose limits of 10 CFR 20.101 is apparent noncompliance with 10 CFR 20.201 (b).
The licensee stated that an additional evaluation of the exposure data and various neutron dosimeters in use will be made by September 30, 1980. This evaluation will also include the Landauer Track-Etch (polycarbonate foil) neutron dosimeter which the licensee has used starting July 1980. This evaluation will determine if 10 CFR 20.101 limits were exceeded. This is an unresolved item.
TLD finger badges are issued to all persons working in the reactor building and to others for special work functions. The highest quarterly extremity exposure for the period September 1979 to March 1980, was 2900 mrems.
b.
Internal The licensee routinely performs tritium analysis on urine samples collected from persons who work in containment. The results of
.
-6-
-
.
I these samples from September 1979 to date were reviewed; no problems were noted. Continuous air samples, daily tritium air samples, and contamination surveys are conducted in containment and are used to define any problem areas. Records of these indicators were reviewed; no problem: were noted.
The licensee stated that no routine air samples are performed for work under the broad license done in the laboratories of the Research Reactor Facility. The workers in these areas are also not covered by a bioassay program despite the use of millicurie quantities of radioactive material and the fact that sizable spills have occurred which have resulted in personnel contamination.
The inspectors conducted a contamination survey which included these areas (Paragraph 16) and found several areas with removable contamination.
The failure to perform routine air sampling in these laboratories and the apparent lack of a bioassay program for the workers in these laboratories is apparent noncompliance w th 10 CFR 20.103(a)(3).
c.
ALARA The Manager, Reactor Health Physics, stated that although no formal ALARA program exists, the facility management continually strives to reduce personnel exposures through increased use of shielding and improvements in procedures. No problems were noted.
9.
Posting, Labeling, and Control During facility tours, the inspectors reviewed the licensee's compliance with posting and labeling requirements specified in 10 CFR 19.11 and 10 CFR 20.203. While in laboratory #228 the inspectors surveyed the area using a licensee instrument (CP-44, serial number 402). The general area radiation level in front of the fume hood was 15 mR/hr. The laboratory was not posted as a radiation area. The Manager, Reactor Health Physics, had the source of the radiation removed from the hood.
Failure to post 1cboratory #228 as a radiation area is apparent non-compliance with 10 CFR 20.203(b).
Several radiation work permits (RWP's) were reviewed since September, 1979. The preface to the Health Physics Standard Operating Procedures specifies conditions and jobs which require issuance of an RWP. No problems were noted.
10.
Su rveys The inspectors selectively reviewed records of direct radiation, con-tamination, and air sample surveys conducted since the last radiation-7-l l
l
.
protection inspection. Observed results were comparable to those ob-tained during facility tours with the exception of the contamination levels found by the inspectors as discussed in Paragraph 16.
Containment air samples are taken and analyzed for tritium daily by the Health Physics and Radiochemistry Departments. Results of samples taken from January, 1980 to date were reviewed.
Concentrations normally ranged from 9.0E-8 to 5.0E-7 pCi/cc. The highest concentration noted was 8.6E-7 pCi/cc. Air samples are also counted for argon-41. The highest concentration noted was 2.5E-7 pCi/ce.
No items of noncompliance were identified.
11.
Instruments and Equipment a.
Portable Survey Instruments Records of instruments calibrated since September, 1979 were reviewed. The licensee logs the calibration dates on file cards maintained for each instrument and status charts posted in the health physics office. The records were satisfactory. However, the inspectors are concerned by the fact that the licensee does not check the instrument calibration near the end of each scale as indicated in ANSI N323-1978. This is an important step which is needed to check the instrument's linearity.
b.
Hand and Foot Monitors Hand and foot, monitors are utilized for detection of personnel contamination. One is located near the main entrance to the facility and another is located at the top of the stairs leading to the hot cell area.
Personnel are instructed to use the hand and foot monitors prior to eating or leaving the facility. Due to the number of side exits from the building, it is not possible to determine if personnel are using the monitors each time they exit the facility. This problem was previously identified in an audit conducted by the University Radiation Safety Office on February 6, 1979. This item was discussed during the exit interview and the licensee was encouraged to re-review this matter to determine if it is a significant problem.
c.
Respirators The licensee does not make allowance for using respirators in estimating exposures to individuals as indicated in 10 CFR 20.103(c).
Three full-face and eight half-face respirators are maintained for general use by the Health Physics Office. Two full-face and five half-face respirators are maintained for emergency use and are kept in the emergency equipment cabinet. The inspector noted that two of the half-face respirators in the emergency cabinet were-8-
. _ _ _ _ _ _ _ - _ -..
_ _ _ _ _ _ _ _ _ _ _ _
.
defectiva and that several others needed cleaning. During the exit interview, the inspectors pointed out the need for a well defined and detailed maintenance. program for respirators. The licensee stated that this problem would be reviewed. No other problems were found.
d.
Area Radiation Monitorings System (ARMS)
The seven area monitors are calibrated semiannually and are checked for operability and alarm response before reactor startup. A re-view of the calibration records was made. No problems were noted.
e.
Stack Monitoring System The particulate, gaseous, and iodine monitors were last calibrated in July, 1980. The calibration data was reviewed and no problems were found.
The gaseous monitor alarm setpoint calculations were reviewed.
- The inspectors noted that the setpoint was approximately equiva-lent to the calculated monitor response at the instantaneous technical specification limit for argon-41.
No items of noncompliance were identified.
12.
Primary Coolant Activity Records of primary coolant water sampling and analyses were reviewed from January, 1980 to date. The technical specification requirements for sampling frequency and maximum permissible concentrations were met.
No items of noncompliance were identified.
13.
Radwaste Management a.
Liquid Radwaste Isotopic analysis is performed on a sample of liquid radwaste before each discharge to either the sanitary sewer or the cooling tower basin. Liquids containing large quantities of tritium are discharged to the cooling tower. The blowdown from the cooling tower basin to the sanitary sewer is closed when these discharges are made. The tritium evaporates off from the cooling tower water. The cooling tower water is then resampled and if no tritium is detected the blowdown to the sanitary sewer is resumed. The remaining radionuclides are added to the total activity discharged to the sanitary sewer. Since July, 1979, there have been 73 releases to the sanitary sewer totaling 0.266 curies, and eleven releases to the cooling tower totaling 0.608 curies. No problems were noted.
-9-
.
.
b.
Gaseous Radwaste Grab samples are taken from the stack and analyzed for argon-41 on an almost daily basis. Records of the sample results were reviewed for January,1980 to date; none of which exceeded the instantaneous technical specification. The licensee's gaseous effluent monitor's strip chart would indicate any sudden increases in argon-41, from which a determination could be made of the concentrations and total release. The licensee does not have this capability for particulate and iodine products.
A review of the records covering the period from January, 1980 to date indicated the average annual concentration of argon-41 dis-charged to the environment was 62% of the technical specification limit for maximum concentration averaged over a year (350 MPC).
The licensee's method of calculation to determine average con-centrations consists of multiplying the average daily argon-41 concentration by the total volume of air discharged from the facility (based on a measured flow rate and actual hours of reactor operation).
No items of noncompliance were identified.
c.
Solid Radwaste The licensee has made two shipments of solid radwaste since the last inspection. A licensed contractor " broker" picks up the waste after being prepared for shipment by the licensee. The records of these shipments were reviewed and no problems were noted.
During a previous inspection, it was noted that there was a lack of radwaste storage spac:. Conditions are unchanged, but the licensee feels that the space they have is adequate at this time.
The licensee's response to IE Bulletin 79-19 " Packaging cf Low-Level Radioactive Waste for Transport and Burial" was rev;ewed.
Two significant problems were identified concerning the licensee's action required by this bulletin.
Item 4 in the bulletin requires that detailed instructions and operating procedures be provided to all personnel involved in the transfer, packaging, and transport
'
of low-level waste. The licensee's procedure is very broad in scope and not detailed in respect to specific packaging and trans-portation requirements of Nhc and DOT regulations.
Item 5 requires that training and periodic retraining in NRC and DOT regulatory requirements, the waste burial license requirements, and in your i
instructions and operating procedures be provided to all persons involved in the transfer, packaging, and transport of radioactive material. The licensee has not completed any training required by this item. These problems were discussed with the licensee during i
l
- 10 -
O
....
the exit interview and during phone conversations on July 21 and 24,
.980.
The licensee has agreed to complete the training required by item 5 and rewrite the procedure required by item 4 of Bulletin 79-19, prior to making any further radioactive waste shipments.
This matter will be reviewed during a future inspection.
The management controlled audit required by IE Bulletin 79-19 was performed by the Director, Research Reactor. The inspectors reviewed the audit and found that it consisted of a single page cursory review of the program and was generally a rehash of the licensee's response to Bulletin 79-19.
The audit was discussed during the exit interview and the licensee agreed to include radioactive waste transfer, packaging, and transport in the annual health physics audit. This audit will be reviewed during a future inspection.
No items of noncompliance were identified.
14.
Receipt and Transfer of Radioactive Material
.
The inspectors reviewed the licensee's records of transfer of licensed byproduct material from September 1979 to date. Material is transferred to both on and off campus users at a rate of at least two or three shipssois per day. For the period July, 1979 through May, 1980, 156 shipments were made off campus totaling 171,435 Ci and 96 shipments were made to on campus laboratories totaling 0.1 Ci.
One shipment of spent reactor fuel was made since September, 1979.
The shipment records were reviewed for compliance with 10 CFR 71 and 49 CFR requirements.
The inspectors reviewed the licensee's action on a previous item of noncompliance with the maintenance of records required by 10 CFR 71.62(a)(10). A review of the records of Type B shipments indicated that the licensee is maintaining the proper records.
l No items of noncompliance were identified.
15.
Notifications and Reports i
A review of records and discussions with licensee representatives indicated that the licensee has complied with 10 CFR 19 and 10 CFR 20 reporting requirements. No items of noncompliance were identified.
16.
Independent Measurements On July 16, 1980, the inspectors performed a contaminatica survey of the containment building, hot cell area, and laboratories in the Research Reactor Facility. The smear samples were counted on the licensee's equipment. Four areas surveyed exceeded the licensee's
- 11 -
.
.
- _____. _ _ _ _ _ _ _ _ _ _
_-
_ _ _ _ _ _ _ _ _ _.
....
limit for removable surface contamination. 2The highest level of contamination found was about 5000dpm/100cm. Three of the highest smear samples were recounted by a member of the NRC's Region III staff using NRC counting equipment. Similar results were obtained. The Manager, Reactor Health Physics, stated that he would instruct the technicians responsible for contamination surveys to intensify their efforts.
17.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviarions. An unresolved item disclosed during the inspection is discussel in Paragraph 8.
18.
Exit Interview
.
The scope and findings of the inspection were discussed with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on July 17, 1980, and further discussed with Mr. Olson on July 24, 1980. Specific items discussed were problems related to the exposure of the health physics technician (Paragraph 8a) and problems related to activities conducted under the broad license at the Research Reactor Facility (Paragraph 8b and 9).
On August 7,1980, Dr. Brugger and Dr. Keenan were informed of the three items of noncompliance and one unresolved item identified concerning the health physics technician exposure (Paragraph 8a),
and the two items of noncompliance related to activities at the Research Reactor Facility conducted under the broad license (Para-graph 8b and 9).
I
!
i l
l
)
- 12 -