IR 05000228/1979002

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IE Insp Rept 50-228/79-02 on 791015-17.Noncompliance Noted: Failed to Adequately Evaluate Neutron Exposures
ML19260C275
Person / Time
Site: Aerotest
Issue date: 11/13/1979
From: Baird J, Book H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19260C268 List:
References
50-228-79-02, 50-228-79-2, NUDOCS 7912260139
Download: ML19260C275 (8)


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U. S. NUCLEAR RECULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCE!'ENT IGGION V Report No.

50-228/79-02 R-98

License No.

Priority category Licensee:

Aerotest Operations 3455 Fostoria Way San Ramon, California 94583 Facility Name:

Aerotest Research Reactor Facility Inspection att San Ramon, California October 15-17, 1979 Inspection conducted:

Inspectors:

b b G2 sf j)lf}r) q J. M Baird, Radiation Specialist Date Signed Date Sicned Date Signed Aoproved by:

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21vJ dit w

//[f3/Jp MH. E. Book, Chief, Fuel Facility and Materials D' ate signed

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Safety Branch Sum:rary :

Insoection on October 15-17,1979 (Report flo. 50-228/79-02)

Areas Inspected:

Routine, unannounced inspection of radiation control,- emergency planning and environnental protection including: organization, general oper-ations; personnel monitoring; instrumentation; surveys; waste disposal; emergency plans; effluent and environmental monitoring. The inspection also included independent radiation measurements by the inspector and a followuo of action on IE Bulletin 79-19.

The inspection involved 13 insoector-hours by one llRC inspector.

Results: Of the areas inspected, no deviations were identified; one apparent item of noncompliance (Infraction - failure to adequately evaluate neutron exposures - paragraph 3.a.) was identified in one area.

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IE:V Form ?19(1)

7912 260 iN

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DETAILS 1.

Persons Contacted

  • R. Newacheck, President, Aerotest J. Haskins, flanager, Reactor Operations I. Lamb, Manager, cuality Assurance P. Underhill, Sales Manager
  • R. Tsukinura, Radiation Safety Officer A. Starzee, Fire Marshall, San Ramon Fire Department
  • Denotes those present at Exit Interview.

2.

Reactor Operations - General a.

The Aerotest Radiography and Research Reactor is a pool type, 250 Kw TRIGA fueled reactor. The principal use is as a source of thermal neutrons for routine and developmental neutron radiography.

Some neutron irradiation experiments are performed on a contract basis for activation analysis and radioactive tracer production.

A new experiment for calibration of power reactor fission chamber detectors was initiated in September. The reactor operation dVerages about 4.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per day, five days per week.

b.

The licensee's organization has changed since the last inspection with the appointment of J. Haskins as the Reactor Supervisor.

Four SRO licenses are currently in effect at the facility.

flo items of noncompliance or deviations were identified.

3.

Radiation Safety Program Radiation control records and procedures were examined and discussed with licensee representatives.

Rr. cords examined included a selected sampling of the following:

Personnel Monitoring Results (staff and visitors)

Area Survey Records (Radiation level and contamination)

Reactor Experiment logs and survey records Radioactive Material Transfer and disposal records a.

Personnel Monitoring Film badge records for eight full time and two part time employees were reviewed back to the last inspection. The dosimeter log for visitors was also reviewed. Film badge exposure reports were in the range of 10 to 790 mrem garna radiation per quarter. TLD ring dosineters were initiated in January 1979, and exposures range 1616 278

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-2-from 10 to 1160 mrem per quarter, fleutron dosimetry was ended April 30, 1979.

Visitor dosimeter logs indicate that visitor exposure is normally zero with infrequent exposures up to 10 mR in a day. The inspector discussed the licensee's procedures for estimating the neutron dose to personnel in the restricted area.

It was noted that survey data and job study information had been used to estimate a neutron dose component for N-ray radiographers based on 8 percent of the reported gamma dose.

A notice from the RSO is circulated with the film badge reports each month stating that 8 percent of the gama should be added to the individuals dose. This neutron dose component is incor-porated in the licensee's annual personnel exposure report.

Based on independent measurements taken during the inspection, see paragraph 8, the inspector determined that the neutron dose component could be significantly larger than 8 percent of the gamma dose for personnel other than radiographers.

For example, measurements at the reactor console during routine radiography indicated dose rates of 2nR/hr gamma and about 1 mrem /hr neutron.

For an estimated 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> per quarter of operation in this mode, the dose to the reactor operator could be 350 mrem gama and 175 mrem neutron; a neutron dose component of 50 percent of the gama.

This was discussed with the licensee and they stated that only the radiographer exposure had been considered significant. The inspector stated that the failure to adequately evaluate neutron exposure potential for personnel other than radiographers was considered to be in apparent noncompliance with 10 CFR 20.201(b)

(Infraction 79-02-01). A licensee representative stated that an appropriate evaluation would be conducted and the neutron dose component documented in personnel dosimetry records, b.

Surveys Radiation level and contamination level surveys are performed monthly or more frequently if needed. Tieter surveys, taken with beta-gamma sensitive ion chamber instruments and with a Bonner sphere type neutron survey meter, indicate radiation levels at nine locations in and around the high ay housing the reactor.

Levels vary greatly and are deoendent upon the location and the neutron radiography exposure conditions. Maximum levels indicated for areas within the high bay were 55 mrem /hr neutron and 120 mRon/hr gama. These levels are not typical of those existing during actual exposure and the locations are not routinely occu-pied by personnel.

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-3-In September 1979, two health physicists from Lawrence Livermore Laboratory (LLL) conducted an extensive neutron survey at the facility.

The survey utilized various types of neutron dosireters and neutron detection instrumentation.

From analysis of detector response the neutron energy spectrun was obtained and the re-sponses of the various detectors and dosimeters tabulated. The report of the survey notes that the neutrons are predoninately low energy and that a Hankins type albedo dosimeter would be useful for neutron dosimetry.

The licensee is investigating the availability of albedo dosimeters but has not found a vendor who would provide the service.

Film badges containing beta-gamma and neutron sensitive film and a selection of materials for accident criticality evaluation are placed at 10 locations in and around the facility.

Results for 1978 range from 20 to 2320 mrem, the higher value being in the ti-radiography area. Results for 1979 through July range from 10 to 1770 mrem.

Contamination surveys taken nonthly at five locations on floor sur-faces indicate that renovable surface contamination is at back-ground levels.

Particulate air samples are taken at two locations.

One sample is taken from the chemical hood exhaust duct and the second from a location r. ear the west wall of a balcony over the control room.

Samples are exchanged daily, checked for unusual activity and counted in a laboratory counter the following week.

Particulate air samples are additionally taken at two more locations when the power reactor fissien chambers are irradiated. A review of the air sample counting since the last inspection indicates background activity levels were present.

Samples of pcol water are routinely taken and counted for activity.

The results indicated activity in the range of 2 to 8 x 10-6 Gamna spectrum of the samples indicate the existence of antimony-124 due to activation of some metal ions leached from the aluminum liner, reactor structure or possibly the lead shutter. The pool water is circulated in a closed loop from the pool through filters and an ion exchange resin bed, a heat exchanger and back to the cool.

Any minor leakage losses are confined and monitored before release.

c.

Area Posting-Access Control 1616 280

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-4-The inspection revealed that signs and barriers are used as re-quired in 10 CFR 20.203 to identify radiation areas, high radia-tion areas and radioactive materials. The facility is enclosed by a high chain link fence with a locked gate.

Access to the high bay area is controlled by the reactor supervisor during reactor operations.

Exit monitoring is not required. Survey meters are available.

d.

Radioactive Material Control The licensee does contract irradiations for outside organiza-tions which involve the transfer of radioactive material.

Records of transfer shipments indicate that in 1978 and 1979 a total of 140 shipments were made.

The Radiation Safety Officer ascertains that the outside organization is authorized to receive radioactive materials and copies of authorizing documents and licenses are kept on file.

Radiation levels associated with the shipments were up to 150 mrem /hr at the surface and 2 mrem /hr at one meter; within limits set by D0T regulations.

fio significant surface contamination was detected on any shipment.

No deviations were identified. One iten of apparent noncompliance (Infraction 79-02-01) was identified.

4.

Emergency Planning The Aerotest reactor facility has an emergency plan to establish lines of authority and communication, to initiate notification of emergency situations, request action for necessary support activities, and to ensure prompt action and effective use of supplies, equipment and personnel in the event of an emergency at the facility, A copy of the latest revision (August 1976) has been ma d available to IE:V.

Fire alarms and radiation alarms for the facility are monitored in the San Ramon Fire Station approximately one mile away.

The function of all facility alarms is checked monthly and docuinented in the log. The inspector visited the fire station and discussed the fire department's emergency response with respect to the Aerotest Emergency Plan.

Communication with the Fire Marshall indicated that the San Ramon Fire District was providing a well coordinated and properly trained emergency response support group for the facility.

No items of noncompliance or deviations were identified.

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Audit and Procram Review A semi-annual program review is conducted by the Reactor Safeguards Cormittee and an annual audit of radiological safety is perfomed by an outside consultant.

The inspector discussed management's commit-ment to ALARA principals of dose reduction to facility personnel and the environment, and reviewed documentation of ALARA reviews.

It was noted that consideration is being given to improving beam catcher and tunnel shielding and some shielding material has been tested.

It was also noted that the licensee estimates that exposures in the set-up area will be reduced by 50 percent when the planned new building is constructed.

NO items of noncompliance or deviations were identified.

6.

Radioactive Waste Reactor coerations generate small quantities of low activity solid and liquid wastes. The solid wastes are collected and transferred to a comercial waste disposal contractor for ultimate disposal.

Liquic' wastes are collected in a storage tank and sampled and, depend-ing upon the activity, disposed of via release to the sanitary sewer.

Records indicate that two batches of about 1500 gallons of liquid were released to the sewer after gama counting and spectral analysis indicated that the activity was at background levels.

The inspector reviewed the licensee's response to IE Bulletin 79-19,

" Packaging of Low-Level Radioactive Waste for Transport and Burial",

and verified that the actions required by the bulletin had been taken with respect to activities related to the transfer, packaging and shipment of low-level radioactive waste.

No items of noncompliance or deviations were identified.

7.

Environmental flonitoring There are no Technical Specification requirements for an environ-mental monitoring program. The licensee has placed integrating radiation detectors (film badges) at two locations on the fenced perimeter and reviews the monthly radiation levels indicated. The badge results ranged from 140 to 470 mrem for 1979, and 10 to 210 mrem through July 1979, within the limits set by 10 CFR 20.105.

Relocation of the east fence line out to the property line this month is expected to reduce the higher values above by 10 to 20 percent in the future.

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-6-As required by Technical Specification 7.2, a gas monitor draws air from the space over the reactor pool or samples the gas leaving the building via the ventilator in the high bay. The alarm level of 2 mR/hr in the gas stream is annunciated at the reactor control panel.

A progran of soil sampling at four locations around the facility has been carried out for a number of years.

The samples are not counted but are stored in case of litigation. They would be counted to es-tablish levels of long half-lived activity over time.

The licensee does not feel that an active monitoring program is warranted since there is no evidence of airborne activity and operation involving dispersable radioactive materials are minimal.

8.

Indeoendent Measurements The inspector made independent and comparative radiation measurements during typical radiographic operations.

A Xetex model 303 A GM survey meter, SN 4035 (calibration due December 1979) and an Eberline model PRS-2 neutron Rem-meter, SN 133 (calibration due February 1980) were used to measure gamma and neutron dose rates, respectively. The inspector's measurements, sumarized below, were in general agreement with measurements made with licensee instrumentation and the data from the LLL survey.

Dose Rate, mrem /hr 9"/3" sphere Area Neutron *

Gamma,

Ratio Control Room 1.2 2.0

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(shutter closed)

0.2 0.1 Radiography, setup 4.0 0.1 0.15 Radiography, Tray 22.6 18.0 0.13 Tunnel Quality Control 4.0 2.5

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(shutterclosed)

0.2 0.1

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East Fence 0.5 0.3

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  • Neutron dose rate corrected by factor of 1.7 for LLL estimate of 9" sphere over response.

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Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on October 17, 1979.

The scope and findings of the inspection were sumarized including the item discussed in Paragraph 3.a.

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