IR 05000228/1987001
| ML20210A541 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 01/23/1987 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20210A462 | List: |
| References | |
| 50-228-87-01, 50-228-87-1, NUDOCS 8702060492 | |
| Download: ML20210A541 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-228/87-01 Docket No. 50-228
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License No. R-98 Licensee: Aerotest Operations, Inc.
3455 Fostoria Way San Ramon, California 94583 Facility Name: Aerotest Research Reactor Facility (ARRF)
Inspection at:
San Ramon, California Inspection Conducted:
January 5-0, 1987 Inspector:
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M. Cillis, Senior Radiation Specialist D&te Signed Approved by:
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G. P. ORylas, Chief
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D&te Signed Faciliti'es Radiological Protection Section Summary:
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Inspection on January 5-8, 1987 (Report No. 50-228/87-01)
Areas Inspected:
Routine unannounced inspection of ARRF operations, including
. organization, review and audit, experiments, reactor operator requalification training, environmental monitoring program, procedures, radiation protection activities, transportation activities, emergency preparedness program, a tour of the facilities'and discussions of relevant IE Information Notices and Generic letters.
Inspection procedures 30703, 39745, 40745, 40750, 61745, 69745, 82745, 83743, 86740 and 92701 were performed.
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Results:
Of the twelve areas inspected, two apparent violations were identified:
failure to perform monthly surveillance checks prescribed in the Technical Specifications, Sections 3.2 and 7.0 (see paragraph 2(e)) and failure to fully implement and maintain the Emergency Plan (see para 0raph 5).
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8702060492 870123 PDR ADOCK 05000228 G
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DETAILS 1).
Persons Contacted
- R. Newacheck, President Aerotest Operations
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Lamb, Reactor Supervisor
- R. Tsukimura, Radiation Safety Officer (RS0)
- P. Underhill, Sales Manager, Application Engineer S. Warren, Level II Neutron Radiographer T. Walter, Level II Neutron Radiographer A. Merens, Senior Reactor Operator
- Denotes those individuals attending the exit interview.
2).
Reactor Operations a). General The facility continues to be used for neutron radiography and short term irradiations for activation analysis.
There have been no unusual occurrences since the previous inspection.
The licensee reported that no changes in operations or modifications were made to the facility and/or equipment since the previous inspection.
The inspector witnessed several reactor operations involving reactor startup/ shutdown and neutron radiography.
The operations were performed in accordance with the licensee's Standard Operating Procedures (50P's).
The reactor has been operated for seven to eight hours per day at a power level of 250 kilowatts. A total of approximately 484,242 kilowatt-hours of reactor operations were logged for the period of June 1985 to June 1986.
This represents an approximate 10% increase over that logged during the preceding year.
l The Aerotest Operations staff was augmented with the addition of five additional personnel since the previous inspection.
No changes in the organizational structure has occurred since the previous inspection.
No violations or deviations were identified.
b).
Logs, Records and Documents The following logs, records and documents were reviewed:
Visitor log Reactor startup/ shutdown records
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Monthly, quarterly, semi-annual and annual surveillance records Training records such as:
(1) General Employee's Training (2) Emergency Plan Training (3) Explosive Training (4) Reactor operator, and Senior Reactor Operator requalification training Radiation survey records, such as direct radiation measurements, measurements made to determine radioactivity in air, water and on working surfaces (loose and fixed).
Environmental monitoring data
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Personnel monitoring records
Maintenance logs
Instrument (i.e. reactor and radiation detection instrument)
calibration records
Reactor Operator Requalification examinations
Transportation records
Explosive accountability records
The NRC approved Reactor Operator Requalification Program Reactor Safeguards Committee (RSC) meeting minutes and audit
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reports
The NRC approved Emergency Plan I
The results of the log, records and document review are discussed in the subsequent paragraphs of this report.
c).
Procedure The inspector reviewed all or portions of the following Standar3 Operating Procedures for compliance with the Technical Specifications, Section 12.?, " Procedures":
Procedure No.
Ti,tle I
Administrative Procedures II Operating Procedures III General Emergency Procedures IV Critical Assembly and Power Calibration Procedures V
Security Procedure VI Radiological Safety Procedures
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VII Experiment Review and Approval Procedures VIII Maintenance Procedure i
The review disclosed that the purpose and scope provided in Procedure No. VIII states that the maintenance program is designed
to assure that all surveillance and maintenance activities required
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by the license are carried out and documented.
The procedure
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includes requirements for performing daily, quarterly, semi-annual and annual surveillances that are required by Aerotest 50P's and/or
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by a license condition.
The inspector noted that the procedure does
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not include any instructions for performing the monthly surveillances prescribed under Sections 3.2 and 7.1 of the Technical Specifications (see paragraph 2(e), herein).
The inspector also r
noted that a monthly surveillance " form" for verifying monthly surveillances required by the T.S. has been developed and is being
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used; but, is not addressed in Procedure No. VIII.
This observation was brought to the licensee's attention.
The licensee informed the inspector that instructions telated to the use of the monthly
surveillance was important for assuring that the surveillance
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program is performed.
The licensee added that the form apparently
had been inadvertently deleted from the procedure during the.last i
revision that was made to the procedure.
The licensee added that Procedure No. VIII would be revised to include instructions addressing the monthly surveillance requirements.
No violations or deviations were identified.
(d) Opertor Requalification Training Program The in.pector verified that the licensed opeaator's requalification training program was consistent with the NRR approved Requalification Program for Aerotest Operations dated October 1974.
The verification in'cluded a review of training records, reactor reactivity manipulation lots, discussions with qualified operators and a review of the most recent senior reactor operator examinations.
The program appeared to be consistent with 10 CFR Part 55, Appendix A.
No violations or deviations were identified.
(e) Surveillances Recordt of surveillance checks conducted daily, monthly,ivelyquat*terly, semi-annually ant annually for 1985 and 1986 were select i
examined.
It should be noted that:
1)
Section 3.2 of the T.S. states:
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"An alarm system shall be installed to detect unauthorized entry into the reactor building.
The alarm system shall be monitored constantly and its annunciation shall be tested monthly."
2)
Section 7.1 of the T.S. states:
"A fixed gamma monitor employing Geiger tube detectors shall be located on the wall connecting the control room and the reactor room. This monitor shall serve as both an area radiation monitor and a criticality alarm and will annunciate through an automatic monitoring system to the San Ramon, California, Fire Department and actuate a siren within the reactor building on
high radiation level.
The monitor shall have a minimum range of 0 to 20 mr/hr.
The annunciation and the siren actuation shall be tested monthly."
The examination revealed that the monthly surveillance's prescribed in Sections 3.2 and 7.1 of the Technical Specifications were not documented for the following periods:
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January 18, 1985 to April 5, 1985 (the April 5th sign off was made to satisfy the monthly surveillance required for the month of March)
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April 29, 1985 to June 11, 1985 3).
April 3, 1986 to June 2, 1986.
The above observation was discussed with the Reactor Supervisor and at the exit interview.
The Reactor Supervisor stated that the required surveillances were probably missed.
The inspector informed the licensee that failure to perform the monthly checks prescribed in Section 3.2 and 7.1 of the T.S. was an apparent violation (87-01-01).
(f) E_xperiments A review of the experiments accomplished since the previous inspection was conducted.
The review disclosed that no new experiments had been conducted.
Those performed were consistent with the Technical Specifications and the licensee's Standard Operating Procedures.
No violations or deviations were identified.
(g) Review and Audit The licensee's review and audit functions assigned to the Reactor Safeguards Committee (RSC) were examined and found to be consistent with the regulatory requireuents prescribed in the Technical Specifications, Section 12.1.3.
RSC meeting minutes and audit reports for 1985 and 1986 were reviewed as part of the examinatio. - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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No violations or deviations were identified.
3)
Radiation Protection a.
Liquid and Solid Wastes No liquid or solid waste was generated from ARRF activities since the previous inspection.
No violations or deviations were identified.
b.
Radioactive Material Shipments and Receipt
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A review of radioactive material shipping and receiving records indicated that activities associated with the receipt and transportation of radioactive material were consistent with 10 CFR Part 20.205, 10 CFR Part 71 and Department of Transportation
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i regulations prescribed in 49 CFR Parts 173-178.
Transfers and/or shipments of radioactive materials are made through Aerotest's State of California radioactive material license, No vioiations or deviations were identified.
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c.
Posting The inspector verified that the licensee's posting practices were consistent with 10 CFR Part 19.11, " Posting of Notices to Workers."
No violations or deviations were identified.
d.
Personnel Monitoring The licensee's program for assuring compliance with 10 CFR Part 20.202 was examined and was found to be consistent with the regulatory requirements prescribed in 10 CFR Part 20.101 and 10 CFR Part 20.104.
No violations or deviations were identified.
e).
,5 rveys and Effluent Releases
The inspector verified that direct radiation surveys, contamination surveys, and survey for airborne particulates, liquids and gaseous effluents are performed on a routine schedule by the radiation protection staff.
The inspector concluded that the program is consistent with the regulatory requirements prescribed in 10 CFR Part 20.201 and 10 CFR Part 20.401.
The reactor pool water is routinely checked for temperature, water level, conductivity and pH as prescribed in the Technical Specifications.
The licensee also checks the pool water's radioactivity concentration on a routine schedul _
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Argon 41' releases were calculated to be 416 microcuries for 1985 and 384 microcuries for 1985. 'The daily particulate airborne surveys and contamination surveys did not reveal any levels of activity above background.
Radiation levels were consistent with levels identified from previous inspections.
The licensee has also established an Environmental Monitoring t
Program even though the need for a program is not prescribed in the Technical Specifications.
Controlled film badges are used to measure the direct radiation levels at the east and west fence line.
Other badges are located throughout the licensee's facility.
A review of the data obtained from the processing of the controlled badges did not reveal any abnormal readings.
The RSO stated that the licensee was considering the possibility of establishing a requirement for sampling drinking water as part of their environmental monitoring program.
No violations or deviations were identified.
(4). Facility Tour The inspector toured the facility to check the general state of housekeeping and to verify that radiation monitoring instrumentation was in calibration and operating properly.
Independent surveys were performed using an Eberline Model R02 fon chamber radiation detection instrument, NRC No. 008985, due for calibrotion on February 25, 1987.
The independent radiation measurements confirmed that the licensee's posting and labeling practices were consistent with 10 CFR Part 20.203,
" Caution signs, labels, signals and controls."
Work practices observed during the tour were consistent with the recommendations of 10 CFR Part 20.1(c) for maintaining personnel exposures "as low as is reasonably achievable" (ALARA).
All fixed and portable instrumentation observed were in current calibration.
Cleanliness, with the exception of the mezzanine and machine shop areas, was excellent.
During the tour, the inspector was unable to locate any of the radiation detector packets prescribed in Section 7.6 of the Technical Specification.
Section 7.6 requires that several detector packets containing a series of threshold detectors be placed at several locations within the reactor building for post-accident radiation analyses.
This observation'was discussed with the RSO who eventually located one of the threshold detectors in the Sales Manager's office.
The RSO stated that additional threshold detectors were available within the facility, however, he would have to search for them.
The inspector noted that the detectors were designed to be mounted on a wall or fixture.
It was also noted that the facilities Standard Operating Procedures or the Emergency Plan implementing procedures do not address the detectors.
The observation was discussed at the exit interview.
The licensee informed
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the inspector that the detectors would be mounted at several locations within the reactor building and would be addressed in the appropriate Standard Operating Procedure.
No violations or deviations were identified.
5).
Emergency Plan Implementation The licensee's capabilities for responding to emergencies as specified in the licensee's Emergency Plan of July 20, 1984, and for demonstrating compliance with 10 CFP Part 50.54(q) and 10 CFR Part 50, Appendix E were examined.
10 CFR Part 50.54(q) states in part:
...A licensee authorized to
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possess and/or operate a research reactor or fuel facility shall follow and maintain in effect emergency plans which meet the requirements in Appendix E in this part...."
Section IX, " Maintaining Emergency Preparedness" of the licensee's emergency plan includes the following requirements:
a)
...A training / refresher course shall be given on an annual basis
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and will be attended by all Aerotest Operations personnel...."
b).
" Drills shall be conducted on a randomly timed, twice yearly basis during the monthly tests of the various alarms."
c).
"The Emergency Plan shall be reviewed on a biennial basis."
The examination disclosed the following:
a).
No training was provided in 1985 and the training provided in 1986 did not include at least two of the permanent staff and two of the temporary staf f."
b).
Only one drill was conducted in each 1985 and 1986.
c).
The last review of the Emergency Plan was performed on July 20, 1984.
This represents a period of two and one half years
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The above observations were brought to the licensee's attention at exit interview.
The President acknowledged the inspector's observations by stating that immediate corrective actions will be implemented to prevent recurrence.
The inspector informed the licensee that failure to follow and maintain in effect the emergency plan was an apparent violation (87-01-02).
A further review of the Emergency Plan disclosed a contradictory statement.
The statement made under Section IX.B.2, " Communication and Notification Verification" states:
" Automatic alarm functions shall be checked on a quarterly basis."
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The above statement is not consistent with the T.S. Section 3.2 and 7.1 (see paragraph 2(e), herewith) or the statement under.Section IX.A. of the Emergency Plan which require that automatic alarm functions shall be checked on a monthly basis.
Nor is the statement consistent with the licensee's Monthly Surveillance form discussed in paragraph 2(e) which also requires that alarm functions shall be checked monthly.
The above observation was brought to the licensee's attention. The President of Aerotest acknowledged the inconsistency by stating that the statement will be changed to be consistent with the T.S.
6)
Information Notices (IN's) and Generic Letters (GL's)
The inspector verified that the licensee was receiving and evaluating IN's and GL's for applicability to ARRF activities.
Discussions with the President of Aerotest and a review of RSC committee mi::utes revealed that an evaluation of GL 86-11, " Distribution of Products Irradiated in Research Reactors" was performed.
The RSC minutes revealed that Aerotest does not plan to irradiate any gem stones for commercial or private use.
No violations or deviations were identified.
7).
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on January 8,1987.
The inspector summarized the scope and findings of the inspection..The licensee was informed of the violations in paragraphs 2 and 5.
The President acknowledged the violations, stating that there were no excuses and that immediate corrective actions would be implemented.
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