IR 05000192/1990001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-192/90-01

ML20059N352
Person / Time
Site:	05000192
Issue date:	10/01/1990
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Wehring B TEXAS, UNIV. OF, AUSTIN, TX
References
NUDOCS 9010120038
Download: ML20059N352 (2)

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OCT - I K00 in Reply Refer To:

Dockets: 50-192/90-01 Dr. Bernard W. Wehring, Director Nuclear Engineering Teaching Laboratory 10100 Burnet Road The University of Texas at Austin Austin, Texas 78758 Gentlemen:

Thank you for your letter of September 10, 1990, in response to our' letter and Notice of Violation dated August 6, 1990. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection ,

to determ ue that full compliance has been achieved and will be maintained. J

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Sincerely,

Original 9 ped By A,B. BEACH i

A. Bill Beach, Director Division of Radiation Safety and Safeguards ,

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Dr. Tom L. Bauer, Assistant Director Nuclear Engineering Teaching Lab.

10100 Burnet Road The University of Texas at Austin Austin, Texas 78758 Robert Woodard i Reactor Health Physicist Nuclear Engineering Teaching Lab. I 10100 Burnet Road The University of Texas at Austin Austin, Texas 78758 i

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Dr. Bernard W. Wehring -2-W. H. Bryant Radiation Safety Officer 2617 Speedway Room 104 Austin, Texas 78705 Radiation Control Program Director Bureau of Radiation Control Dept. of Health 1100 W. 49th Street Austin, Texas 78756-3189 Auburn Mitchell Office of the Governor P.O. Box 12428 Austin, Texas 78711 bec to DMB (IE01)

b Martin B. Murray A. Adams, NRR Project Manager.

udP Lisa Shea, RM/ALF RIV File MIS Coordinator RSTS Operator DRS B. Beach, DRSS L. Yandell, DRSS RPEPS-DRSS

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h DEPARTMENT OF MECHANICAL ENGINEERING

/d i THE UNIVERSITY OF TEXAS AT AUSTIN  !

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. NudarEyimeriq Tc.xhinisburator) 10100 Bmet %d* Austin, Tew 78738 '(3121471.5787 i

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September 10, 1990 tv-  ; .

Mr. Bill Beach  ! 'F '" -

Director, Division of Radiation Safety and Safeguards  ; .p I32 Region IV iit -

611 Ryan Plaza Dr., Suite 1000 iljd .JC Arlington, TX 76011 1 Re: August 6,1990

Dear Mr. Beach:

The following information is being provided in response to Region.IV inspection docket 50 192/90 01.

Routine surveys at the Taylor: Hall (docket 50192) reactor facility include weekly equipment checks of area radiation monitors (4 locations) and an air particulate monitor (1 location). I Reasons for Violation:

Routine records did not document adequately, periodic surveys of areas by routine checks or knowledge of personnel of the radiation -

levels. Prior to cessation of reactor. operation additional records were available as part of the startup checklist. However, the routine checks excluding the reactor operation checklist have not changed i subsequent to the cessation of reactor operation.

A low source check at approximately 0.1 mrem /hr. at each of the.

, four fixed locations sets a limit on the area radiation levels at four points in the facility. These four points' located in ;he vicinity of the reactor pool set limits on the radiation levels at 4 points in an area of about 2000 square feet. The levels are less than 0.1 mrem /hr .as demonstrated by weekly check records. A similar check of the air particulate monitor fixes the ambient air particulate activity.- Area-contamination swipes are done on a project by_ project basis. . Since the Taylor Hall facility has not operated the reactor since April- 30, 1988, the project activities in the facility average approximately one each ten to fourteen days.

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2-At this frequency, the equipment check records and less periodic swipe measurements were considered adequate to demonstrate the generally accessible areas of the facility did not have radiation levels in excess of 2 mrem /hr. Only the area above the reactor pool (5 mrem /hr) exceeds the 2 mrem /hr level. The room area is posted as

a radiation area. Access is limited to only staff personnel that have

knowledge of the location and types of hazards in the- facility.

Less frequent radiation measurements done by the radiation safety office provide both background at the facility boundary and

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confirmation that area surface contamination within the facility - are acceptable. These contamination levels although measurable at some-locations would be acceptable in non radiation areas-(typically less than 100 dpm/100cm3 The reporting in proper units for survey records are available in the files but not done on each record.

Corrective Actions Taken:

l At the time of the inspection, the licensee verbally committed to a change in operating procedures for radiation surveys. This was done prior to any knowledge regarding a violation of 10CFR 20.201 which requires subjective judgement on the frequency, type and number of ;

o accesses to the area. A survey by the H.P. of the facility staff at least once each two weeks, will document and post area radiation levels l and surface contamination on a simple schematic floor plan.

l The survey maps will provide current data including the correct unit references without any reference or dependence on the Safety Office records. A request has been made for the Safety Office to document the correct units on each record document for the docket 50-192 and docket 50 602 facilities, i

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The number of personnel with access to the area has been-immediately limited to only those with direct knowledge of the ;

status of the facility. Routine work with radioactive materials has j been moved from the area and made subject .to the procedures of the i TDH-6 485 license and docket 50-602 requirements. These procedures meet and in most cases exceed previous docket. 50-192 requirements.

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i 1 3-Corrective Steos to Avoid Future' Violations :  :

The additional measurement and documentation for radiation levels [

in the docket 50-192 facility are being implemented in a manner  ;

similar but not completely identical to those being applied at the

. docket 50 602 facility.

The future of radiation measurements at Taylor Hall for the docket 50192 facility is considered to be of limited duration. The licensee .

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plans to continue the present measurement procedures until facility  :

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decommissioning is initiated. The dismantling process' will reevaluate the monitoring requirements. Plans are to begin this

work within one year.

Date Of Full Compliancei The' licensee may not agree completely with all aspects of the - ,

violation but did not disagree that better procedures were desirable.

Full compliance was implemented prior to Aug. 31, 1990 by starting ,

a routine survey including measurement and documentation at an l

interval of at least once every other week.  ;

Sincerely,

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Thomas L. Bauer Assistant Director, NETL Approval:  ;

l Dehd RI. deh Bernard W. Wehring I Director, NETL TLB/ekt 4 cc: W. H. Bryant Bureau of Radiation Control A. Mitchell

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