IR 05000224/1987001

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Insp Rept 50-224/87-01 on 870713-16.Violations Noted.Major Areas Inspected:Environ Monitoring & Emergency Preparedness Programs,Reactor Operator Requalification Program,Audits & Reviews,Experiments & Health Physics Program
ML20237H355
Person / Time
Site: Berkeley Research Reactor
Issue date: 07/28/1987
From: Cillis M, Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20237H311 List:
References
50-224-87-01, 50-224-87-1, GL-86-11, IEIN-87-022, IEIN-87-22, NUDOCS 8708170162
Download: ML20237H355 (9)


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U. S. NUCLEAR REGULATORY COMMISSIO REGION V ,

Report No. 50-224/87-01 )

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Docket No. 50-224 I

License No. R-101 '

Licensee: University of California .

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. Berkeley, California 94720  ;

Facility Name: TRIGA, Mark III Inspection at: Etcheverry Hall, Berkeley,. California

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! Inspection Conducte Jul 13-16, 1987 Inspectors: / pp 7/2# 7 M. Cillis, Senior Radiation Specialist

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Date Signed Approved by: 7hl'7 G. . P. Yuhas, Chief, Facilities Radiological Date' Signed Protection Section Summary:

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Inspection on July 13-16, 1987 (Report No'. 50-224/87-01)

Areas Inspected: Routine unannounced inspection by a regionally based inspector of reactor operations program; including organization, audits and reviews, experiments, health physics program, environmental monitoring program, emergency preparedness program, procedures, reactor operator requalification program, transfer and shipment of radioactive material, a tour of.the' facility and open. items consisting of Information Notice evaluations, Generic Letters and followup items, and a review of the annual repor Inspection Procedures 30703, 39745, 40745, 40750, 41745, 42745, 61745,~69745, 82745, 83743, 86740, 90713, and 92701 were addresse Results: Of the fourteen areas inspected, two apparent violation's were 'I identified in one area: failure of the Reactor Hazards Committee (RHC) to

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perform quarterly audits (see Paragraph 2(c) and failure to submit a 30-day written report as prescribed in Technical Specifications, Section 6.7(c)(4)

(see Paragraph 2(c)). l l

8708170162 870729 PDR ADDCM 05000224 0 PDR

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DETAILS l

i Persons Contacted

  • Professor T. H. Pigford, Reactor Administrator
  • Dr. T. Lim, Reactor Supervisor
* Professor V. E. Schrock, Assistant Reactor Administrator

! *A. Peterson, Radiation Safety Officer (RS0)

Professor M. Christensen, Reactor Hazards Committee (RHC), Chairman

  • P. Vernig, Reactor Health Physicist M. Denton, Chief Reactor Operator J. Harrell, Senior Reactor Operator
  • Denotes those' individuals attending the exit interview.

! Reactor Operations i l

l General  !

i The inspection disclosed that reactor operations were consistent with the information provided in the licensee's annual reports of 1985 and 198 The licensee's facility continues to provide support for irradiation -

and teaching program ! Organization j i

The organizational structure for operation and administration of the )

TRIGA reactor facility remains unchanged from that previously reporte The organization was found to be consistent with Section i 6.1 of the Technical Specifications (TSs). ]

l No violations or deviations were identifie Review and Audit The licensee's review and audit activities assigned to the Reactor Hazards Committee (RHC) pursuant to Sections 6.1 and 6.5 of the TSs were examined during the inspectio It should be noted that TSs, Section 6.2(c) states: "The RHC or a Subcommittee thereof shall audit reactor operations at least quarterly but at intervals not to exceed four months."

Additionally, TSs, Section 6.7(c)(4) requires a 30-4sy written l report for any observed inadequacies in the implementation sf administrative or procedural controls prescribed under TSs, Sect ne 6.0, " Administrative Controls."

The examination included discussions with the RHC Chairman, RHC Secretary and Reactor Supervisor. The RHC meeting minutes, RHC Bylaws and audit report files were examine _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The Reactor Supervisor informed the inspector at'the onset'of this-

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portion of the inspection that audits for two successive quarters were not conducted at their scheduled time. He added that the required audits were subsequently performed at a later date, i

The record review disclosed that RHC audits were not conducted for

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the period of November 1985 through September 1986,.a period of slightly over ten months. The reasons provided are as follows:

  • I One individual went out of the country and failed to conduct the audit before leavin <

Another individual had too many conflicting duties and failed to conduct the audit. This individual has been deleted from l

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the RHC.

l The two audits that were originally scheduled for the first and l second quarters of 1986 were subsequently performed in December 1986 l

and February 198 The RHC meeting minutes did not discuss the missed audits in any great detail and no thirty (30) day written report was submitted to ,

the NRC pursuant to TSs, Section 6.7(c)(4) as of July 13, 1987. The licensee's staff was unaware of the 30-day reporting requirement (

until it was brought to their attention by the NRC inspecto '

Remaining RHC functions were found to be consistent with TS j requirement l l

The inspector brought these observations to the licensee's staff attending the exit intervie The inspector informed the licensee that failure to perform the 1986 first and second quarter ' audits was an apparent violation of TS, Section 6.2(c) (87-01-01).

The inspector also informed the licensee that failure to make a l 30-day written report to identify the missed audits was an apparent violation of TSs, Section 6.7(c)(4) (87-01-02).

The licensee acknowledged the inspector's observations by stating l that appropriate corrective action will be implemented to prevent their recurrenc Experiments The inspection disclosed that ten new experiments were performed since the previous inspectio Tiie experiments were reviewed and approved by the Reactor Supervisor, Health Physicist and Reactor Hazards Committee in accordance with the TSs and reactor operating procedure No violations or deviations were identifie _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _

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! Changes ,

i Discussions with the licensee's staff disclosed that no changes were 'l made to the facility or in procedures that would require a safety 1 evaluation be made pursuant to 10 CFP Dart 50.5 i

'No violations or deviations were ident ed.' 'q Procedures j

The inspection disclosed that the licensee's reactor operating procedures in TSs, Section 6.5 remain in.effec ;

The inspector reviewed the licensee's operating procedures. .The l procedures appeared to provide thorough instructions. The inspector i noted that the procedures are reviewed on a routine schedule or I whenever changes occur that may require revision No violations or deviations were identifie Reactor Operator Requalification Program j i

The licensee's NRC approved Reactor Operators.(RO) and Senior ,

Reactor Operators (SRO) requalification program dated November 13, !

1974 was examined. The program is designed to meet the conditions as set forth in 10 CFR Part 50.54(i) and 10 CFR Part 55, Appendix Selected training records, R0 and SR0 reactor operations logs and annual R0/SR0 examinations for the period of;1985 through March 1987 were examine ;

No violations or deviations were identified, Surveillance The inspector examined selected records associated with the ;

performance of surveillance activities prescribed in Section 4'of the TS !

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The parameters selected included: Rod drop times, excess reactivity, reactor pool water conductivity checks,, temperature measuring calibration checks, fuel element temperature channel

checks, radiation monitoring instrumentation calibration checks and )

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power calibration check The inspector concluded that the licensee had complied with the applicable requirement No violations or deviations were identified.

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4= Radiation Protection General Employee Training l The licensee's General Employee's Training (GET) program, for I assuring compliance with 10 CFR Part 19.12, " Instructions to l Workers," was examine The examination included the review of the training lesson plans, hand-out material and attendance record The inspector observed that significant improvements in the licensee's GET were implemented since the previous inspections. The

, RSO stated that the GET is being revised. The revision will. include- q a provision for providing GET retraining every three year j i

The examination disclosed that the licensee's GET program met or i exceeded 10 CFR 19.12 requirement No violations or deviations were identifie )

1 Posting {

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The inspector verified that the licensee's posting practices are [

consistent with 10 CFR Part 19.11, " Posting of Notices to Workers."

No violations or deviations were identifie Personnel Monitoring The licensee's program for assuring compliance with 10 CFR Part 20.202 was examined and was found to be acceptable. Personnel monitoring records for the period of January 1985 through 1987 were reviewed. No abnormal exposures were identifie No violations or deviations were identifie Solid Wastes and Liquid Releases Licensee solid wastes and liquid release records for the period of January 1985 through June 1987 were reviewe Approximately ten cubic feet of solid waste (e.g.., spent resins)

were transferred to the licensee's Radiation Safety Office for disposal. Disposal is made through the licensee's State of California licens All liquids are sampled prior to each releas Two liquid releases, totalling 5551 gallons, were discharged to sewer system during the period. The sample results were well within 10 CFR Part 2 Appendix 8 limit No violations or deviation: were identifie _ _ - _ , - - . . . .

i e.- Surveys The inspector verified that di' rect radiation surveys, contamination-surveys, special surveys and surveys for airborne particulate, q gaseous, and liquid effluents are performed.on a routine schedul J Survey records for the period January 1985 through March 1987.were

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reviewe The results were consistent with the levels reported-in-the 1985 and 1986 annual report No abnormal results were-identifie The RSO stated a. program.for sampling the reactor pool water on a routine basis wasigoing to be implemented. The RSO also: stated that'

an'RHC audit had made the recommendation to.. resume'the sampling '

program which had'been stopped several years ago because the analysis'never showed any activity. The inspector commended the

, licensee's staff for making this decision.

l The inspector concluded that the licensee's radiological monitoring program was consistent with 10 CFR Parts 20,201 and 20.40 No violations or deviations were. identifie '

' Particulate and Gaseous Effluent Releases

'The principal airborne radionuclides released from the. facility is Argon (Ar)-41.'

Region V Inspection Report 50-224/83-01 describes the licensee's program for monitoring airborne releases.. The program has not ,

changed significantly from what was described in the inspection '

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repor A review of airborne monitoring' records for the period of 1985 >

through March 1987 disclosed the following: I

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Argon (Ar)-41 releases for the period of July'1985 through June 1986 were 5.8 Curies and.for the period of July 1986 through June 1987 Ar-41 releases totalled 3.84 Curie .No radioactivity in particulate form with half lives greate than eight days had been release I

.The percent of the Maximum Permissible Concentration of Ar-41 is a

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i small fraction of the limits prescribed in 10 CFR Part' 20, Appendix i The inspector concluded that the. licensee's program to maintain releases.as low as possible is consistent with'the ALARA concept prescribed in 10 CFR Part 2 i No violations.or deviations were identifie j I

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6 Environmental Monitoring Program The licensee has continued to maintain the radiation environmental monitoring program described in Inspection Report 50-224/83-01.

l Selected environmental monitoring reports for the period of January 1985 through June 1987 were reviewed.

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The inspector concurred with the licensee's observations which essentially concludes that there has been no detectable or meaningful increases of radioactivity in the environs as a result of reactor operation No violations or deviations were identifie . Radioactive Material Shipments and Receipt A review of radioactive material shipping and receipt records revealed that activities associated with the transportation and receipt of radioactive material were consistent with 10 CFR Part 20, 10 CFR Part 61, 10 CFR Part 71 and Department of Transportation (00T) 49 CFR Parts 173-17 Shipments of radioactive materials are made through the licensee's State of California radioactive material license. The licensee's radioactive material transportation activities were well documente No violations or deviations were identifie . IE Information Notices (ins)

Licensee's evaluations of ins received between June 1985 and March 1987 were reviewed and discussed with the licensee's staf he review disclosed that the licensee was not receiving all of the in Those that were received had been appropriately evaluated by the licensee's staff. A copy of IN 87-22 was provided to the licensee's staff during the inspectio The Reactor Supervisor informed the inspector that he would call the appropriate NRC office to determine why the ins were not being receive No violations or deviations were identifie , Generic Letter The information provided in Generic Letter 86-11, " Distribution of Products Irradiated in Research Reactors," was discussed with the Reactor Superviso The inspector was informed that the licensee does not have any current plans to irradiate any gem stones for commercial use. The Reactor Supervisor stated that the NRC would be informed of any future decisions to irradiate gem stones for commercial and/or private use.

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l No violations or deviations were identifie )

1 Emergency Preparedness The licensee's capabilities for responding to emergencies as described in l their Emergency Plan of July 1984 and for demonstrating compliance with 10 CFR Part 50.54(q) were examine The inspector concluded through discussions, review of emergency procedures, training records, memorandums of understanding, and other 4 related documents, that the licensee met the commitments provided in j

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their emergency plan.

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The Reactor Supervisor stated that he was revising the Emergency Plan 4 l

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Training Program to include a provision for. retraining. Laboratory Users and some support groups. The Supervisor added that the Emergency Plan ..

Training Program includes provisions for retraining remaining activities.

,. The retraining program for Laboratory Users will be given whenever major a l

l changes occur or at a three year frequency. The inspector commended the supervisor for his decisio The examination revealed that evacuation drills and other full scale drills involving offsite agencies were conducted at the frequencies l prescribed in the emergency pla No violations or deviations were identifie . Open Items (Closed) Followup Item 83-01-01 - This item identified that the licensee had agreed to calibrate instruments for non penetrating radiation and to develop a program for evaluating non penetrating radiation, to develop a program for evaluating non penetrating radiation exposure, either by means of special surveys or by modification of routinely performed survey An examination was conducted to determine the status of this ite The inspector was informed that an instrument would be calibrated for l measuring non penetrating radiation. This matter is closed (83-01-01). Facility Tour The inspector toured the licensee's facility to check the general state of housekeeping and to verify that posting and labeling was consistent with 10 CFR Part 20.203 and that radiation monitoring instrumentation was in current calibration and were operating properl Independent radiation measurements were performed using an Eberline, Model R0-2 ion chamber survey instrument, S/N 2691, that was due for calibration on July 21, 198 All fixed and portable radiation monitoring instruments were in current calibration and plant cleanliness was excellen _ - _ _ _ _ _ _ _ _ - .

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The independent measurements confirmed that the licensee's postings and I labeling practices were consistent with 10 CFR Part 20.20 No violations or deviations were identifie j 10. Exit Interview I The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on July 16, 1987. The inspector summarized the scope and findings of the inspection. The licensee was informed of the apparent violations in Paragraph The licensee acknowledged the violations, stating that immediate-l corrective actions would be implemente l l

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