IR 05000223/1990003

Insp Rept 50-223/90-03 on 900827-28.No Violations Noted. Major Areas Inspected:Radiation Protection Program,Including Status of Previously Identified Items,Staffing,External Exposure Controls & Contamination Controls

ML20059M713
Person / Time
Site:	University of Lowell
Issue date:	09/19/1990
From:	Dragoun T, Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059M711	List: IR 05000223/1990003 ML20059M709
References
50-223-90-03, 50-223-90-3, NUDOCS 9010050211
Download: ML20059M713 (6)

Text

. .

'

<

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /90 03 Docket N License N R-125 Priority - Category F Licensee: University of Lowell 1 University Avenue Lowell, Massachusetts 01854

.eacility Name: Lowell University Research Reactor Inspection At: Lowell, Massachusetts Inspection Conducted: A_ugust 27-28, 1990 Inspectors: .cw f-/J D Radiation Specialist date P.O'Connell,RadiationProtectionSection Facilities

./ -c tw /I 9b T. DragouMro ett Scientist, Effluents dat tion Section adi)iorr7ro Approved y/:_ wa 7!/)!76 P.astlak, Chief facilities Radiation ProtectionSection / dfte

!

Inspection Summary: Inspection conducted on August 27-28, 1990 (Report No. 50-223/90-03)

Areas Inspected: Routine, announced safety inspection of the radiation protection program, including: the status of previously identified items; staffing, external exposure controls, and contamination controls.

l Results: No violations were identified during this review.

l 9010050211 900919 PDR ADOCK 0500022 O PNV<

_

~

. -. . __ . - .

. -

,

.

,

'

.

,

L i DETAILS

'

1.0 Persons Contacted

• L. Beghian, Vice President for Academic Services and Technical Research

• W. Church, Radiation Safety Officer

• T. Wallace, Reactor Supervisor

• Attended the exit interview on 8/28/9 ;

Other licensee personnel were also contacted during the course of this inspectio .0 Purpose

The purpose of-this routine, announced inspection was to review the implementation of the licensee's Radiological Safety Program. The ,

following areas were included in this review:

l

- Status of Previously Identified Items

- Staffing

- External Exposure Controls

- Contamination Controls 3.0 Status of Previously Identified Items L(Closed) Unresolved icensee to improve Item (84-03-01)

plant cleanliness and storage of combustible

'

materials. A tour of the facility including the basement storage area indicated good attention to housekeeping and stora materials has been maintained. This item is closed. ge of combustible I (Closed) Inspector Followup Item

'

Two of the four Safety Analysis Re(86-03-01)

port communications systems were i inoperative. During this inspection the licensee demonstrated the operability of the following control room communications systems:

1 University tele hones (two lines).

2 Commercial tele hone Lone line).

l 3 Intercom connec ion wlth outside area of both airlock door Containment building intercom (8 lines).

, 5 Sound powered phone links to the pump room and reactor bridg Containment building public address syste Th s item is close .3 L(0 pen) review icensee Inspector Followup Item discrepancies between(88-02-01)hnical Tec Specifications- (TS) and plant design. The licensee stated that there is an error in TS Section 3.3. The interlock in this section which reads " regulating rod prohibit at less than or equal to a 15-second reactor period" should read

,

i . _ . -- - -

_ _ . _ _ .- -

,

.

.

'

)

-

a

'

3 I

!

' control blade inhibit at less than or equal to a 15-second reactor period". i The licensee will submit a TS correction to the NRC by 1/1/91. This matter ;

remains open until the.TS change is incorporate j

' (Closed Violation Failure)topostNRC(88-03-01) Form 3 in the Pinanski Building, which provides access j

,

to the reactor containment structure. The ins  ;

corrective actions specified in the licensee'pector verified that thes response letter d; 13 1988 had been completed. The corrective actions included posting copies ;

of, Form NRC-3 on each of the three levels of the Pinanski Building and )

insuring that all i Pinanski Building. This postings item are current during quarterly surveys of the is close j

. (Closed Violation i Failure)topostthe(8803-02) access to the reactor containment structure " Caution i Radioactive Materials". The inspector verified that the corrective action :

specified in the licensee's response letter dated July 13, 1988 had been ,

completed. The corrective actions included properly posting the access to  !

the reactor containment structure and insuring that.all postings are r current during quarterly surveys of the Pinanski Building. This item is  !

close L (Closed Violation (88-03-03  !

Failure)to conduct annual inv)entories of Co-60 strip sources as required by ;

procedure. The procedure revision at the time of Inspection 88-03 required ,

that the serial number of each strip be verified during the annual inventory. This was a very time intensive process and entailed a risk of dropping a strip to the bottom of the pool. The licensee revised procedure l R0-14, Co-60 Source Inventory and Activity", to require all the individual i Co-60 stri)s to be counted annually, without identifying individual serial numbers. Tie inspector verified that the 1989 and 1990 annual inventories ,

had been completed as required by the procedure. This item is close .7 (Closed Inspector Followup Item The lice)nsee did not )eriodically(88-03-04) calibrate or source check hand and foot 1 monitoring devices. Tie licensee initiated quarterly operational. checks of the hand and foot monitors. This item is close F i

4.0{taffing j Several months ago the full-time Haalth Physics (HP  !

There is no management effort to fill this position)due to aTechnician resigne i University-wide freeze on hiring. The Radiation Safety Officer (R50) stated -

that students have been trained and are performing some of.the HP i Technician duties. The inspector stated that the Updated Safety Analysis '

r Report RSO and (USAR)Pone H Technician. Use of students should only be temporary withSe!

good oversight by the RSO. The inspector also noted that the Radiation  !

Safety Council already expressed concerns regarding understaffing in 1988, !

1989, and 199 !

!

i

. - _ . .

. - . . . . . -

, - - ._ _ _ _ _ _ _ _ . _ _ _ .

q

.

j

~

l r

.

,

also resigned. This - !

More positionrecently is alsothe Chief Reactor

" frozen" with the0CR0 erator duties (CRO) temporarily performed by ,

the Reactor Supervisor. The CR0 position is specified by USAR section 1 !'

The-licensee had previously acknowledged the importance of maintaining this position filled during an Enforcement Conference with the NRC in April )

1988. In addition, there are now only two Senior Reactor Operators and one J part-time Reactor Operator. This is the minimum staffing required for )

reactor operations by TS Section 6.1 and licensee operating procedure During the Exit Interview the inspector stated that the facility staffing had reached a critical level and that management attention to filling 1

>ermanent positions is required. The associate Vice President-Technical

Research stated that this matter will be discussed with the University administratio .0 External Exposure Controls The ins)ector reviewed several monthly personnel exposure records and noted t1at personnel doses at the facility were well below regulatory limits.-The records reviewed indicated that the majority of individuals monitored at the facility did not receive measurable occupational doses. A few individuals had received doses of up to 200 millirem during some of the month-long monitoring periods. In instances where individuals received

, measurable occupational doses, the RSO had reviewed the dosimetry records '

! and had taken actions to minimize personnel exposures. The inspector .

verified that the contractor which the licensee uses to process their #

dosimeters is accredited under the National Voluntary Laboratory Accreditation Progra '

The inspector reviewed calibration records and rocedures for both the fixed position Radiation Monitoring System radiation surveying instruments. Calibration (RMS so theand forare RMS theconducted portable semiannually. The inspector reviewed several records of the daily operability checks of the RMS and continuous air monitors. These operability checks are conducted prior-to reactor startup and are used to verify the settings of the RMS and continuous air monitors alarm set points. Within the sco)e of this review no violations were noted, the '

licensee was meeting tie surveillance requirements for the area radiation  ;

monitoring equipment as specified in TS Section ,-

The inspector reviewed several surveys of the reactor containment  :

structure and independently verified general area dose rates with '

documented survey results. No discrepancies were noted in this area. The inspector noted that the licensee's program for access control and interlock system for the Gamma Cave, an area used for sample irradiation, were considered goo The inspector noted that there was no approval process for several of the licensee's radiation protection procedures. The licensee stated that, under their current program, only the radiation protection procedures which apply i

+

- -

.- _- - .- - -- . . . -

_ _ _ _ . _ . . _ - .- _ _ ___ _ - - -_ - _____ _ _ __- _ ____ __ - . _ _ _ _ _ _ _ _ ____ _ -

!

-

. l

.

l

to the reactor containment structure are ap exclusive Reactor Sa 1fetySubcommittee.Theseprocedurescoversuckrovedbythetopics as handI irradiated fuel, radiation monitoring equipment checkout, and movement of

'

Co-60 sources in the reactor pool. Currently, neither the Reactor Safety Subcommittee nor-any other advisory group approves radiation protection procedures which apply to both the reactor containment structure and the- l university laboratories using byproduct material. These procedures include  !

-

calibration of pocket dosimeters and portable surveying instruments, radiation survey procedures and counting room procedure!,. The licensee provided the inspector with,a copy of the meeting minutes for the June 21, 1990 Radiation Safety Committee decided that routine radiation sa(RSC) meetin fety office Durim) and procedures that subsequent meeting it was ,

'

major revisions to these procedures would be sent.to the appropriate  ;

subcommittee which would provide technical review for the R50. RSC approval l of these procedures will be reviewed during a future inspectio While reviewing procedures in the control room the inspector noted that some of the procedures in the control room were not the most up to date a revision. The licensee stated that the control room should-have the most up to date revision of the procedures and that they would review the procedures in the control room and ensure that current = revisions are located in the control roo The inspector conducted several tours of the facility and verified that-areas generally were properly posted for radiation protection purpose However, the inspector did note that both of the Step Off Pads-(SOPS)

examined had been installed backwards. The SOPS directed personnel to remove protective clothing prior to entering into posted contaminated areas and conversely directed personnel to put on protective clothing when leaving the posted contaminated area and entering a noncontaminated are The lack of a full time HP Technician discussed in Section 5.0 of this report appeared to have contributed to the. erroneous placement of the SOP ;

The RS0 stated that he would have the SOPS positioned correctly,  ;

6.0 Contamination Controls

'

The inspector reviewed several contamination surveys and toured'the reactor containment structure to observe posting and controlling potentially contaminated areas. The review of the surveys and the tours indicated that, at the present time there are only a few small areas posted as contaminated areas. These,few areas typically are posted a:

contaminated areas because they have the potential of becoming contaminated. While, at the time of the inspection it did not ap the licensee was experiencing contamination control difficulties, pear the that '

inspec'.or noted the following weaknesses which would make it difficult for the litwsee to promptly become aware of a contamination inciden l

l

!

a

r

,

'

.

,

.o

The inspector noted that the detector response on the hand and foot monitor, located outside the first level personnel access to the reactor containment structure, was set on slow response. Personnel use the hand and foot monitor to detect personnel contamination upon exiting the reactor containment structure. Normally the monitors operate in'the fast response mode. The detector monitors are set to slow response in order.to conduct the quarterly response check. A the last time the detector monitors were response checked,pparently,tely-approxima two months prior to the time of the inspection they had been left in the slow response mode. It is uncertain if the band and foot monitors would have been able to detect low levels of contamination during this time-perio The inspector noted that survey instruments used to survey for personnel contamination, are located at the exits of the posted contaminated areas in the reactor containment structure. The survey instrument at one of the exits did not have a thin windowed type detector used to detect beta contamination. Using a check source, the licensee noted only a slight response with this detector compared to the response of the detectors used at the other exits. Had a low level contaminati' on-incident occurred, it is uncertain how useful this detector would have been to alert the license The licensee immediately corrected these deficiencies. These two examples, as well as the improper placement of the SOPS described previously, indicate that the licensee needs to more closely monitor their-contamination control practices. These examples also further emphasize the need for the licensee to hire a full-time HP Technicia .0 Exit Meeting The inspector met with licensee representatives, denoted in Section 1.0 of this report on August 28, 1990. The inspector summarized the purpose of, i

scopeandfIndingsoftheinspectio l

,

l l

l l

l

-

., . - - . . , _- ,. .