IR 05000186/1993001
| ML20035C777 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 04/02/1993 |
| From: | Alexander Adams, Cox C, David Nelson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20035C773 | List: |
| References | |
| 50-186-93-01, 50-186-93-1, NUDOCS 9304090078 | |
| Download: ML20035C777 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-186/93001(DRSS)
Docket No. 50-186 License No. R-103 Licensee: University of Missouri Columbia Facility Name: Missouri University Research Reactor (MURR)
Inspection At: Research Reactor Facility, Columbia, Missouri Inspection Conducted: March 9-11, 1993 Inspectors:
C N97 Non-Power Reactor Inspector Date
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Radiation Specialist Date Accompanied By: A A s
RR Dat'e
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.W.McCormicflarg%q'1 er, Chief 4lA/43 Approved By:
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Emergency Preparedness and Date Non-Power Reactor Section Inspection Summary
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Inspection on March 9-11. 1993 (Recort No. 50-186/93001(DRSS))
Areas Inspected:
Reactive, announced inspection to followup on corrective
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actions for violations (92702).
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Results: One unresolved item and one inspection followup item was identified.
The licensee identified a problem in their program for irradiation target identification that led to shipping papers and labels on packages not accurately indicating isotopic mixes and curie contents. Corrective actions appear to be in place that would prevent shipping errors to recur. However, this item is considered an unresolved item pending further review by NRC
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staff. An inspection followup item was identified concerning the licensee developing an administrative method to ensure that Reactor Use Request (RUR)
summary sheets are controlled to ensure they reflect the latest revision to the RUR.
i 9304090078 930402 PDR ADOCK 05000186
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-Persons Contacted-j University of Missouri-Columbia -
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' G.'Ehnhardt, Chairman, Isotope Use Committee
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- S. Gunn,. Manager, Services Applications
"C. McKibben, Associate Director, MURR
- W. Meyer, Reactor Manager, MURR 9;
W. Feilly, Assistant Director, MURR
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- J. Rhyne, Director, MURR
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- J. Schuh, Health Physicist
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- T. Seeger, Chief Research Electronic Technician-
Additional technical, operational, and-administrative personne1' were contacted by the inspectors during the course of the inspection.
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- Denotes those attending the exit meeting on March 9, 1993.
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General
This inspection, which was held on March 9-11, 1993, was conducted to follow-up'on concerns about irradiation target = identification and the-i accuracy of shipping papers and labels in identifying, curie' content and -
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radioisotopes identified in a January 15, 1993 letter from J. Charles.
a McKibben, Associate Director, University of Missouri-Columbia Research
Reactor Facility.(MURR) addressed to the Director,-Office of
Enforcement, NRC. That letter was a written response to a Demand for.
Information.from the December 2.1992 US NRC Region III Notice of'
3 Violation and Proposed Imposition:of Civil Penalty-$625 and Demand for i
Information [NRC Inspection Report No'. 50-186/92002 (DRSS)].-
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The inspection consisted of reviewing committee meeting minutes,
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reviewing Service Applications group records and procedu_res,
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interviewing MURR personnel, reviewing 'other corrective _ actions from the -
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violations identified in the December 2,1992 NRC~ letter.,: and
observation of on-going activities.
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Followup on Corrective Actions for Violations and Deviations (92702)
!i (0 pen)-Violation (50-186/92002-01 and -02):
" Failure to follow shipping and labeling requirements "
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-l As part of the response to the violations identified in the' December 2, 1992 NRC letter,' a Shipping. Task Force (STF) was established by the.
.i-licensee. The STF's charter was to conduct a global. review of MURR's
shipping. activities to determine if there were generic weaknesses in the_
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program that had contributed.to the previous violations. The-
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Irradiation' Subcommittee (IS), a. subcommittee:of the STF, was formed-in'
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December 1992 when concerns were. raised by task force members about the
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accuracy of. irradiation target identification and the accuracy of the i
shipping papers and package labels in identifying isotopes and curie
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contents in the packages. A preliminary STF and IS progress ' report was
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made in the January 15, 1993 letter from J. Charles McKibben. That report confirmed that the Service Applications Isotopes (SAI) group had problems in irradiation target identification and accurate reporting of isotopes and curie contents in shipping and labeling,of packages.
Members of the IS identified that a shipment of 16 mci of Ytterbium-169 -
(Yb-169), made on December 16, 1992 to Amersham Corporation, failed to identify a by-product of possibly up to 5 Ci of Ytterbium-175 (Yb-175)
on the shipping papers and package labels. The SAI group had-received-the target material with an irradiation request from Amersham Corporation. This routine irradiation request described the target material as "16 Yb metal wire in Ti".
The irradiation-request further identified the isotopes produced and estimated'sctivity on ship date as-Yb-169 ~ l mci per seed. That amounted to the 16 mci identified on the shipping papers. The standard practice by the SAI group would be to verify that the requester (Amersham) had a valid license to receive the requested isotope and the quantity requested. They would then compare the information on the irradiation request with a Reactor Use Request
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(RUR) summary sheet to see if a valid RUR would cover the safety analysis for the material-in the irradiation request. The RUR summary-
.3 sheet was a summary of pertinent data from the RUR. Such data included a description of allowable target and encapsulation material but did not include a list of all-expected isotopes produced by irradiation of that i
target and encapsulation material which was identified in the RUR. The
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material would then be irradiated and packaged for return shipment. The i
radioisotopes and curie contents identified on the shipping papers and labels would be the information provided in the irradiation request.
The problem identif'ed in the Yb-169 shipment was a generic problem with
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the SAI policy of relying on the irradiation request provided by the
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customer to identify all isotopes produced and the estimated curie
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content. While the RUR identified the by-products that would be produced, the summary sheet and the irradiation ~ request did not.
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Therefore the shipping papers and labels would not identify all the-i isotopes produced and their associated curie content.
Further investigation of the generic issue by the IS identified approximately 17 other routinely produced isotopes where SAI policy would fail to identify all the isotopes and curie contents on the shipping papers and labels. The SAI group contacted customers involved in receiving shipments of the 17 isotopes and determined that the customers were aware of the impurities in the shipments.
The problem of target identification identified by the IS was addressed by a change in SAI policy regarding the irradiation requests. MURR began requiring customers to accurately describe the target material in their irradiation requests.
In an effort to formalize the new policy, the IS was in the process of approving a target certification form that would require the. customers' Radiological Safety Officer to certify that the target and encapsulation material description on the irradiation request was accurate.
The SAI group also changed its policy of accepting the identification of isotopes and curie content listed on the irradiation request.
The SAI group began verifying the information on the irradiation request form through independent calculations.
Continuing work was being conducted
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to develop a computer. program that would accurately predict the isotopic
mix and curie content of target material to aid the SAI group. An-
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additional precaution was taken by MURR to ensure proper identification
of isotopes in packages sent from the facility with a final survey of
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the package by a Nal detector. The detector would provide an isotopic j
spectrum that would identify unexpected isotopes.
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Review of the minutes from the STF and IS meetings by the inspectors
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indicated that the scope of the committecs' reviews were appropriate.
Safety concerns were appropriately being raised by committee members and
actions were taken or were ongoing to address those concerns. Actions taken by the committees indicated that the committees had management
support to identify and correct problems.
Interviews with committee members and other plant personnel generally supported that indication.
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The inspectors encouraged MURR management to continue to support the
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open and frank discussions held during the meetings.
It was such
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discussions by members of the IS that lead to the self-identification of the target identification problem and resolution of the problem without regulatory imposition.
The inspectors reviewed the corrective actions that had been implemented
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at the time of the inspection and found them adequate:to address the concerns of repeat shipping errors. However, the inspectors expressed a
concern that the target certification request appeared to be an attempt to place the responsibility of accurate target identification on the
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customer. MURR management assured the inspectors that they understood
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that MURR had the ultimate responsibility for any material placed in the i
reactor.
While accurate and full target identification was identified
by MURR as being a problem, the review of licenses along with the irradiation requests and the size of the samples placed in the reactor by the SAI group provided reasonable assurance that the potential-to
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insert material in the reactor was net a threat to the core.
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The inspectors expressed a concern about the use of RUR summary sheets
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to verify if an irradiation request meet the safety requirement of an RUR. The current practice had no administrative mechanism in place to ensure that the latest revision of an RUR was reflected by the summary
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sheet. MURR concurred with that concern and committed to develop a i
mechanism to ensure updates in RURs would be reflected in the summary'
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sheets. This will tracked as an inspection followup item (Inspection Followup Item 50-186/93001-01).
failure to identify all of the isotopes produced in the irradiation of
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the Yb wire and the associated curie contents on the shipping papers and
package label for the December 16, 1992 shipment and the shipments associated with the 17 other isotopes identified by the Irradiation-
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Subcommittee is considered an unresolved item pending further review of i
NRC policy by the regional and headquarters staff (Unresolved Item No.
50-186/93001-02).
4.
Exit Interview (30703)
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The inspectors met with the licensee representatives denoted in
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Paragraph I at the conclusion of the inspection on November 5, 1992.
The inspectors summarized the scope and results of the inspection and
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g discussed the likely content of this inspection report. The licensee j
acknowledged the information and did not indicate that any of the
information disclosed during the inspection could be considered..
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proprietary in nature.
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