IR 05000228/1989001
| ML20245D675 | |
| Person / Time | |
|---|---|
| Site: | Aerotest |
| Issue date: | 04/11/1989 |
| From: | North H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20245D673 | List: |
| References | |
| 50-228-89-01, 50-228-89-1, NUDOCS 8905010098 | |
| Download: ML20245D675 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION V i
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l Report No. 50-228/89-01 t
Docket'No. 50-228 !
-1 License No. R-98 Licensee: Aerotest Operations, In Fostoria Way San Ramon, California 94583 Facility Name: .Aerotest Radiography and Research Reactor (ARRR)
Inspection at: San Ramon, California-Inspection Conducted: March 27-30,1989 Inspector: ! 7/f9 H. S. North, Senior Radiation Specialist Dhts Signed Approved by: Mph. M O Y//M E. M. Garcia, Acting Chief Date Signed Facilities Radiological Protection Section l
Summary:
Inspection on March 27-30,1989 (Report No. 50-228/89-01)
Areas Inspected: Routine unannounced inspection of ARRR operations, including organization, review and audit, experiments, reactor operator requalification training, environmental monitoring program, procedures, radiation protection activities, transportation activities, emergency preparedness program and drills, a tour of the facilities and discussions of relevant Information Notices and Generic Letter Inspection procedures 30703, 40750, 86740, 90713, 92701 and 92702 were addresse Results: In the areas inspected, the licensee's programs were fully capable of meeting their safety objective No violations or deviations were identifie ~
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I 8905010098 890412 PDR ADOCK 05000228 g PDC
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DETAILS ' Persons Contacted
- H. G. Simens; President', Aeroteht Operations (AO)
- I. E. Lamb, Reactor Supervisor, Manager Reactor Operations (SRO)
- R. Tsukimura, Radiation Safety Officer (RS0)-
D. Willett, Senior Reactor Operator ~(SRO)
R. Newacheck, Chairman, Reactor Safeguards Committee (RSC)
(*) Denotes those individuals'present at the the exit intervie In addition to the individuals identified above.the inspector met and'
held discussions with other members of the licensee's staf . Follow-up on Items of Noncompliance and Deviations (Closed) 87-01-01: Related te the licensee's failure to conduct required survie11ance tests of.the unauthorized entry alarm system and gamma radiation' monitoring instrument annunciation and siren actuation system at monthly intervals, and;
- Closed) 87-01-02
- Related to the licensee's failure to fully implement all aspect'of the approved emergency plan < , <.
The inspection established, with respect to the items identified above,
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that the licensee had completed the. corrective actions specified in'their ..,
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timely letter dated February 13, 1987,- and that no subsequent' failures
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- Followup '
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,3 Discussion with the licensee's staff established that the following .
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Generic Letter 86-11 Distribution of-Products Irradiated in Research' ,'
1 , / Reactors;.Information Notice No. 87-22 Operator Licensing Requalification
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Examinations at Nonpower Reactors; and Information Notice No. 89-09 -
J Credit for Control Rods Without Scram Capability in the Calculation of the Shutdown Margi With respect to Information Notice No. 89-09 the' *
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licensee stated that all rods, safety, shim and regulating, were magnetically coupled and scram (apabl ' Organization and Administration L The organization was found to be consistant with the description contained in Section 12.1.1 of the Technical Specifications (TS). The former president Aerotest Operations (AO) had retired and assumed the position of chairman of the RSC. The incumbent President is a candidate for an SR0 licens _ . - - _ _ -
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The RSO reviewed and approved.all procedures,and experiments involving radiological safety concerns and performed routine radiation surveys ,
consistant with Section 12.1.2~of the TS..,
The Reactor Safeguards Committee (RSC) consisted of six members, only I three of whom were members of the operating organization (Reactor l Supervisor, RSO and Manager of Production). The other three included I individuals skilled in radiation protection, explosives technology and the committee Chairman, the former president of A0, and an SR Through discussions with personnel and review of records'it was verified that the RSC was discharging the responsibilities specifically identified in Subsections 12.1.3.1 through 12.1.3.6 of TS Section 12.1.3. The minutes of RSC meetings were examined. The minutes were detailed and provided a list of attendees and a summary of the topics discusse Meetings were held on January 22 and July 23, 1987, and September 9 and December 20, 198 Audits by members of the RSC were conducted on February 13 and November 5,1987, and January 8 and November 3,1988. The audits addressed reactor operations, the results of the last NRC inspection and radiation protection including surveys, reactor pool water, radioactive material shipments and personnel exposure record The qualifications of the Reactor Supervisor and RSO, specified in Sections 12.1.4 and 12.1.5 of the TS, were not examined since they have occupied those positions for an extended period covering several inspection The licensee's representatives confirmed that there have been no unusual events or occurences since the last inspectio Discussion with licensee staff members established that no new experiments had been performe Reactor operations have been limited to neutron radiography and sample irradiations' . Inspection Report 50-228/87-01 noted that a total of 484,242 Kwh operations were logged in the year ending June 1986. During 1987 and 1988 a total of 516,241 and 564,102 Kwh of operation achieved. During this period the licensee's staff increase from approximately 20 to 30 employee The licensee's organization and administrative controls appeared capable of safely directing facility operation No violations or deviations were identifie . Records Review The following logs, records and documents were reviewed:
- ARRR Operational Log- 1/2/87 to 3/10/87, 12/1/87 to 12/31/87, 1/4/88 to 2/17/88, 5/23/88 to 7/19/88,,11/12/88 to 12/30/8 * ARRR Experiment Log- Identified five, reviewed and approved' experiments:
No. 114- Neutron Radiography; j No. 116- Crude Oil Activation Analysis .A);
No. 117- Iodine and Silver AA; ,
No. 120- Irradiation of Plastic Slides;
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No. 123- Irradiation of Fission Detector All the above experiments were reviewed and approved between January 1969 and July 197 Discussion with licensee personnel and review of
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Annual Reports for 1987 and 1988 established that only experiment Nos. 114, 116 and 120 had been performe * Operations Request Forms (ORF)- From 87/343, January 5, 1987, to 89/369, January 5, 198 * Administrative Procedures- Including: -RSC Charter; March 17, 1987;
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I. Administrative Procedures; II. Operating Procedures; III. General Employee Procedures; IV. Critical Assembly and Power Calibration Procedures; V. Security Procedures; .
VI. Radiological Safety Procedures; VII. Experiment Review and Approval; and VIII. Maintenance Procedure Surviellance. Records- Monthly, Quarterly, Semiannual and Annua * Training Records- General Employee Training; Emergency Plan Training; Explosives. Training; and Reactor Operator and SRO Requalification Trainin Radiation Survey Records- Including: Direct radiation and contamination, and radioactivity in air and wate Personnel Monitoring Records Explosives accountability records NRC approved Emergency Plan
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Annual Summary of Changes, Tests and Experiments for the periods ending
, 6/30/87 and 6/30/88
- Annual Exposure Reports for 1987 and 1988
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The results of the review of the above documents are discussed in
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following report paragraphs. The documents reviewed appeared to meet regulatory and TS requirements. No violations or deviations were
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6. Facility Changes and Refueling In the past the licensee experienced problems in maintaining the reactor pool water temperature below the TS limit of 130 This problem occasionally required that the reactor be shut down to permit the cooling I tower and heat exchanger to catch up. The original cooling tower was rated at 100 Kw. A later cooling tower rateu at 1 Mw was installed
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however this was in poor condition and contributed to heat exchanger foulin The licensee had recently completed installation of a new cooling tower rated at 300 Kw, expandable to 500 Kw. This combined with an effective biocide treatment system and a cleaned heat exchanger has been effective in controlling' pool temperatur In the past two years the licensee has replaced two fuel elements due to element swelling which exceeded the limit Because of difficulty-in assuring that fuel elements were properly located and inserted in the support plate, the licensee used an under water video camera to observe fuel positioning during a complete core unloadin Facility changes and refueling activities were. consistent with safe operation No violations or deviations were identifie . Surviellance Records '
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In response to the Notice of Violation (NOV) resulting from the last .
inspection (50-228/87-01) the licensee had developed a computerized !
listing of all surviellance items which'was used to generate monthly listings of required activitie Such a list, in use as a checklist, was observed in the control room. The preparation of such a list was one of the corrective actions' identified in the licensee's response to the NO The Monthly Alarm Check List was' examine It was verified that all required alarm tests had been completed. In addition the Quarterly Maintenance Check List was examined. It was verified that all required tests and checks had been accomplished. It was noted that the quarterly rod withdrawal and drop times had been measured and were within the 600 msec maximum limit rod drop times specified in Section 5.3.3 of the T In addition the water temperature interlock had been verified to be more conservative than the value specified in Section 4.1 of the T The l surviellance program appeared to be adequate for safe operatio No violations or deviations were identifie . Training Records Examination of the training records established that training had been provided in the following areas: Security- January 1987, 1988 and 1989; Emergency Plan and Procedures- January 1987 and 1988; Explosives Safety-l July and November 1987; Fire Safety Demonstration- March 1987 and 1989; Safety- December 1988; and Radiation Safety- August 1987 and Neutron Radiography Technician training, including radiation protection, from March through July 1988. A copy of Regulatory Guide 8.13 was provided to each new employee during orientation trainin The training program appeared to be adequate for safe operatio No violations or deviations were identifie . Requalification Training The Operator Training Manual, under revision at the time of the i inspection, and the results of the operator requalification examinations l were examine Examinations given in November 1987 and 1988 appeared to !
be challenging and graded criticall While the final scoring was not f complete it appeared that all grades were 85% or bette The requirements of 10 CFR 55.53(e) were discusse The licensee i
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representatives stated that each licensed individual functions as an operator or senior operator for at least four hours per quarter. The operator requalification program appeared to meet the requirements for safe operation. No violations or deviations were identifie . Radiation Protection In accordance with procedures facility surveys are performed on a monthly basis. A total of 17 locations are surveyed on a routine basis including measurements at the facility perimeter. Perimeter dose rates ranged from
< 0.1 to < 0.3 mr/hr. The highest radiation levels inplant ranged from 10-30 mr/hr. During a plant tour, the inspector observed a dose rate o .
250 mr/hr at contact with the primary water demineralized. The demineralized was shielded and located in a locked area and posted as a high radiation are L' Swipe (smear) samples are collected quarterly. Results were recorded in units of pC1/100 cm sq. For the period December 1987 to March 1989 a and p6 count rates of SE-7pCi/100 cm sq. were measure .
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Portable survey instruments, two ion chamber types and one GM, were
, observed to be in calibratio In addition the licensee had~available a r ; neutron rem meter, two alpha survey meters as well as one additional ion chamber and one GM instrumen Calibration status of the additional instruments was not determined. The survey program and the available
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instruments appeared to be appropriate for this activit No violations or deviations were identifie . Personnel Exposures The licensee uses film badges and finger rings supplied by a National Voluntary Laboratory Accreditation Program (NVLAP) certified laborator Visitors are provided with pocket dosimeter The vendors exposure report data is transferred to a computerized record which meets the requirements of 10 CFR 20.401(a). In addition occupational exposure history information is recorded which satisfies the requirements of 10 CFR 20.10 The supplied badges contain neutron films, however the licensee does not rely on the information provided by the vendo The licensee explained that they had found the vendors results to be suspec The suspicion centers on the fact that when a new vendor supplies badges neutron resuits a e reported, however as time passes the reported neutron exposures declir. ultimately resulting in minimal reported exposure As a result the licensee has elected to increase all gamma doses by a factor of 8%. The use of this factor is based on the results of neutron surveys of the facilit Exposure records for 1987 and 1988 were examined. It was noted that the high exposures approach 5 rem per year. The licensee explained that the principal exposure results from contact with the aluminum trays and fixtures used to transport the radiographic work into the neutron bea Reportedly the highest exposures are received by conscientious supervisors who are meticulous in preparing material for radiograph The licensee is exploring methods to reduce these exposures as well as l
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cautioning workers in proper techniqu Exposures were within the limits specified in 10 CFR 20.101(a).
Personnel exposures and e.xposure controls were adequate for' safe operation. .No violations or deviations were identifie .- . Explosives Accountability
The 1icensee maintains daily explosives inventory records, in units of TNT equivalent, to assure that the limits of Section 9.11 of'the TS are
'not exceeded. Examination of the inventory records established that the
. limits had not been exceeded. The accountability program appeared to provide adequate control of explosive No violations or deviations were
~ identifie . Effluents and Waste Disposal Liquid waste resulting from reactor pool overfill, heat exchanger or demineralized. leakage is collected in a tan A 250 m1 sample from the tank is counted for 6000 sec with a NaI detector. analyzer system. No activity has been, identified in the liquid wast Following analysis the contents of the tank'are discharged to the sanitary sewerage system.' The licensee formerly had a chemistry laboratory which had a drain leading to the waste storage tank. The laboratory has been removed, the chemicals are being disposed of, and the drain was being relocated to the sanitary drain syste Solid wastes originate principally from'the demineralized, When depleted the expended demineralized.is' exchanged with a recharged unit and the expended unit is allowed,to decay. _-When sufficiently decayed the resin is drained and the resin is placed in a 55. gallon drum. The licensee recently disposed of approximately 10" years of accumulated solid waste, principally resin, contained in four 55 gallon drums by. transfer to U. ' Ecology. The transfer was made under the-California State license issued to the license . J Gaseouseffluentreleas'esarecalculated;sincethehighbaymonitoris _
unable to detect the Ar-41' generated due to dilution., Daily air samples are collected and alpha and beta gamma counted the following week. Air sample records for the periods January 25, through June 21, 1987, and July 17, 1988 through March 19,.1989 were examine All -results were in the E-15 to E-16 pCi/ml range'.' ,
The licensee's effluent control and waste dis'posal programs were consistant with safe operation. No violations or deviations were identifie . Emergency Plan Implementation Emergency Plan training was conducted on January 27, 1987, and January 8, 198 In addition specific individual training was provided to new employees as a part of the new employee orientation trainin Response ,
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to unannounced alarms were checked on a twice yearly basis during 1987 and 1988 and once in 1989. In addition several unannounced fire drills i
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had been conducte The licensee had reconfirmed the arrangement with a local hospital to treat exposed or contaminated employee The implementation of the Emergency Plan was consistant with safe operation. No violations or deviations were identifie . Facility Tour The inspector toured the lacility with an SR The tour included the following areas; shipping and receiving area, explosives storage vault, radiography preparation area, darkroom, viewing room, cooling towers, heat exchanger room, demineralized and air sample pump room, shop and control room. An ion chamber type survey instrument, NRC 022906, due for calibration September 14, 1989, was used to perform surveys during the tou It was noted that areas were properly posted as required by 10 CFR 20.203 and that postings required by 10 CFR 19.11 were on an employee bulletin boar It was noted that the housekeeping was good although the radiography work load was high. No violations or deviations were identifie . Exit Interview The inspector met with the licensee's representatives denoted in l paragraph 1 at the conclusion of the inspectio The scope and' findings I of the inspection were summarize The licensee was informed that no 4 violations or deviations were identifie ,. 4 l
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