IR 05000297/1987001
| ML20206D427 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 03/27/1987 |
| From: | Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20206D366 | List: |
| References | |
| 50-297-87-01, NUDOCS 8704130333 | |
| Download: ML20206D427 (8) | |
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UNIT E*) STATES fgn perug'o NUCLEAR REGULATORY COMMISSION y -
o REGION 11 g j 101 MARIETTA STREET. * '
s ATLANTA. GEORGI A 30323
.....* APR 0 21987 Report No.: 50-297/87-01 Licensee: North Carolina State University Raleigh, NC 27607 Docket No.: 50-297 License No.: R-120 Facility Name: North Carolina State University Pulstar Reactor Inspection Conducted: March 16-18, 1987 Inspector: . Q2rRn 3/027/87 (Da'te Signed)
B. K./Revsin q L Approved by: h 3/2'? /d'/
C. M. Hosey, Sectiof Chief (Date Signed)
Division of Radiation Safety and Safeguards SUMMARY Scope: This routine unannounced inspection involved onsite inspection in the area of radiation protection and included: external exposure control and assessment; internal exposure control; control of radioactive materials and contamination, surveys and monitoring; and transportation of radioactive material Results: Three violations - (1) failure to post required documents, (2) failure to comply with Department of Transportation (DOT) requirements for transportation of radioactive materials; and (3) failure to verify that the intended recipient of licensed material was authorized to receive the materia PDR ADOCK 05000' 7
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REPORT DETA,ILS 1. Persons Contacted Licensee Emplopes B. W. Wehring, Director, Nuclear Reactor Program K. V. Mani, Reactor Health Physicist T. C. Bray, Reactor Operations Manager I G. D. Miller, Associate Director, Nuclear Reactor Program I T. L. Brackin, Reactor Safety Specialist 2. Exit Interview The inspection scope and findings were summarized on March 18, 1987, with those persons in Paragraph 1 above. Three violations, failure to post required documents (Paragraph 4.e), failure to adhere to D0T requirements for transportation of radioactive materials (Paragraph e.b), and failure to verify that the intended recipient of shipments of licensed material was authorized to receive the material (Paragraph 5.c), were discussed in detail. Licensee management acknowledged the findings and took no exceptions. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcenent Matters This subject was not addressed in the inspectio . Radiation Control (83743) CFR 20.201(b) requires the licensee to perform such surveys as may be necessary and are reasonable under the circumstances to evaluate the extent of the radiation hazards that may be presen Procedure HP-20-14, Radiation and Contamination Survey Pulstar Bay, Revision 1 January 1,1986, required that contamination surveys be performed twice weekly and direct radiation surveys be performed monthly. The inspector reviewed the results of the twice weekly contamination surveys taken in the Puistar Bay from July 1986 through February 198 In general, removable contamination was reported as less than the Lower Limit of Detection (LLD) of the proportional counter used for counting smear The inspector also reviewed the results of the monthly direct radiation surveys. Surveys for both ganma and neutron radiation were reported. The licensee stated that all surveys were performed after the reactor had been brought to 100 percent power for at least 30 minutes. These surveys taken between April 1986 and February 1987 identified one area, vent plug TB-3, where dose rates routinely exceeded dose rates observed at other plugs (i.e.,150 to 350
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millirem per hour ganina radiation). Investigation showed that the plug had undergone disintegration. The plug was replaced and dose rates at power were reduced to 25 to 50 millirem per hou No violations or deviations were identifie b. 10 CFR 20.202 required that appropriate personnel monitoring devices be worn by personnel likely to receive exposure in excess of 25 percent of the limits specified in 10 CFR 20.101 or who enter high radiation area CFR 20.101 stated the quarterly radiation exposure limits to the whole body, skin of the whole body and extremitie During tours of the facility, the inspector observed personnel monitoring devices being worn. The licensee used film badges supplied by a National Voluntary Laboratory Accreditation Program (NVLAP) approved vendor for measuring official dose. The inspector reviewed selected personnel records from July 1, 1985, through June 30, 1986, and verified that exposures were being maintained below applicable limits. For the academic year, the highest exposure was 390 millirem and the second highest exposure was 100 millire The licensee stated that the 390 millirem dose was incorrect and the actual estimated exposure was 21 millirem. Although the 390 millirem recorded by film badge was well within regulatory limits, the licensee determined that the individual in question should not have received that amount and therefore an investigation was undertake The licensee determined that when not worn, the individual kept his badge clipped to a distribution basket in his offic A survey of the office revealed the presence of a piece of activated aluminum alloy, measuring approximately 10 millirem / hour contact, in the distribution basket. The alloy had not been activated in the Pulstar reactor but had come to the individual through the mail, shipped as nonradioactive materia Once the activity of the object was determined it was removed to a source storage room and a memo was issued to all faculty reminding them to keep film badges in designated racks when not being worn. Since the individually normally sat 3.5 feet from where the activated metal was located, it was estimated that an exposure of 21 millirem was appropriat No violations or deviations were identifie c. 10 CFR 20.203 specifies the requirements for posting radiation areas, high radiation areas and radioactive material area During tours of the facility, the inspector observed the posting of radiological areas and material and verified by independent survey using NRC equipment that such areas were adequately poste No violations or deviations were identified.
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3 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in 10 CFR 20, Appendix B, Table 1. Column Continuous air sampling by a sampler located on the reactor bridge by the poolside was perfonned. Filters are changed and counted for radioactivity dail The inspector reviewed air sampling results from August 1986 through March 1987. Filters were routinely counted inirediately upon collection, three to four hours later, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later to permit radon decay. For the time under consideration all activity froglicensed material was shown to be minimal, i.e., less than 3 X 10- microcuries per millilite No violations or deviations were identifie CFR 19.11 requires each licensee to conspicuously post current copies of (1) 10 CFR Parts 19 and 20; (2) the license; (3) operating procedures; and (4) Form NRC-3, in sufficient places to permit individuals engaged in licensed activity to observe them on the way If posting the docurrents to and from specified in any ) licensed (1, (7) and (3)activity locatio is not practicable, the licensee may post a notice which describes the document and states where they may be examine During tours of the facility, the inspector did not observe any of the above documents to be conspicuously posted so that they might be observed by workers passing to and from a licensed activity locatio Discussions with licensee representatives disclosed that these required documents had been posted at one time, but had been removed when the facility had bean painte Reposting of the docurrents had been overlooke Failure to post the documents specified b 10 CFR 19.11 or a notice describing the documents identified in (y), 1 (2) and (3), and the location where they might be examined was identified as an apparent violationof10CFR19.11(50-297/87-01-01).
5. Transportation (86740) The inspector determined that the licensee generated small amounts of waste from the reactor facility so that only 1-2 shiprrents were made each year for burial purposes. The most hazardous waste generated was spent resin whose main contaminant was Ag-110m. Some decay time was permitted prior to disposal. Waste generated by the licensee was picked up at the reactor site by representatives of the campus wide Radiation Control Office who acted as the final shipper and l
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classifier of the waste based on data provided by the licensee as to isotope identity and quantity.
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No violations or deviations were identified, b. 10CFR71.5(a) requires each licensee who transports licensed materials outside the confines of its plant or other place of use to comply with the applicable requirements of the regulations of DOT in 49 CFR Parts 170 through 18 CFR 172.200, Subpart C, requires each person who offers a hazardous material for transportation to describe the hazardous material on shipping papers as specified in Subpart CFR 173.421(b) states that radioactive material whose activity per i package does not exceed the limited quantity amounts specified in 49 CFR 173.423 are excepted from the specification packaging, shipping paper and certification marking, and labeling requirements of 49 CFR if the radiation level at any point on the external surface of the package does not exceed 0.5 millirem per hou CFR 173.421-1 states that a limited quantity radioactive material prepared for shipment under the provisions of 49 CFR 173.421 and 173.423 must be certified as being acceptable for transportation by having a notice enclosed in or on the package, included with the packing list or otherwise forwarded with the package which must i include the name of the consignor or consignee and the statemen "This package conforms to the conditions and limitations specified in 49 CFR 173.421 for excepted radioactive material, limited quantity, n.o.s., UN2910."
The inspector reviewed the records of selected radioactive materials (RAM) shipments made in 1984 through 1986. It was noted that the shipping papers did not specify all of the information required by 00T in 49 CFR 172.200, Subpart C for transportation of hazardous materials. Deficiencies included failure to list proper shipping name, hazard class, identification number, total quantity, type of packaging and physical and chemical form. Dates of the deficient shipments were December 19, and December 20, 1984; January ll, January 12 and January 15, 1965, and February 7,1985. The licensee stated that these shipments were made by private car within the State of North Carolina and that they had not realized that 00T regulations were applicable. The inspector stated that any movement of licensed material outside the confines of its plant were subject to DOT requirenent Failure to prepare shipping papers in accordance with 00T requirements was identified as an apparent violation of 10CFR71.5(a)(50-297/07-01-02).
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On June 6,1986, a shipment of irradiated gemstones was made as a Radioactive Material, Limited Quantity, n.o.s., UN2910 shipraent. The package contained 0.1 millicurie of Sc-46 and 0.1 millicurie of Cs-134 and had a dose rate on the surface of the package recorded on the shipping manifest as 0.9 millirem per hour. The inspector informed the licensee that while the amount of radioactive material contained in the package met the criteria specified in 49 CFR 173.423 for a limited quantity shipment, the dose rates on the external surface of the package exceeded the permissible limit of 0.5 millirem per hou Failure to comply with 00T requirements for limited quantity shipments of RAM was identified as a second example of an apparent violationof10CFR71.5(a)(50-297/87-01-02).
Further discussions with the licensee concerning the June 6, 1986, shipment of irradiated gemstones as well as an April 7, 1986, limited quantity shipment of the same material revealed that certifications of the packages as being acceptable for transportation by enclosure of a notice on or in the package in addition to the packing list or otherwise forwarded with the package listing the name of the consignor or consignee as well as the certification statement of 49 CFR 173.421-1 had not been performe Failure to certify the two limited quantity shipments in accordance with 49 CFR 173.421-1 was identified as an additional example of an apparentviolationof10CFR71.5(a)(50-297/87-01-02).
c. 10 CFR 30.41(c) states that before transferring byproduct material to a specific licensee of the Comission or an Agreement State or to a general licensee who is required to register with the Commission or with an Agreenent State prior to receipt of the byproduct material, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form and quantity of by product material to be transferre On September 10, 1985, the licensee made the first in a series of eight shipments of irradiated gemstones to a client. The stones had been received as nonradioactive material by the licensee, and after irradiation in the reactor, were returned to the client via two limited quantity shipments and six exempt quantity (per DOT regulations) shipments. The owner of the stones had inforned the licensee in a letter dated July 11, 1985, that they possessed the necessary license to receive and store the radioactivity contained in the stones. The letter did not specify the infonnation required by 10CFR30.41(d)(2) in order for the licensee to transfer the byproduct material, i.e. , written certification as to type, form and quantity authorized by the license as well as the license or registration number, issuing agency and expiration dat . .
Subsequent to the client's letter, the licensee received a copy of the client's license, but was unable to recall the exact date the license had been received. The best memory of one licensee representative was that they were in receipt of the license prior to the February 25, 1986, or sixth shipment which was the first of the two limited quantity shipments. The client's license authorized possession of byproduct material with atomic numbers 3-83 inclusive as contaminated reactor components but no other form of radioactive materia The inspector informed the licensee that meeting the DOT criteria for exempt quantities for transportation purposes pursuant to 49 CFR 173.403(y) did not ensure that the radioactive material met the exemption criteria for concentrations and quantities for transfer of byproduct material specified in 10 CFR 30.70 and 30.7 Examination of the shipping documentation showed that four of the eight irradiated gemstone shipments exceeded the limitations for exempt concentrations as specified in 10 CFR 30.70. These shipments were performed on October 4,1985, February 25,1986 April 7,1986, and Jung 6,1986, and exceeded the permiss1ble limit for Sc-46 of, 2.3 X 10~
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and 1.8micr X 10~gcuries per microcuries per gram gram by 1.2 X 10"3 respectivel ,
In discussions with the licensee concerning the procedure used to verify that the transferee's license authorized receipt of the type, form and quantity of material being transferred, the licensee stated that the usual practice was to obtain a copy of the intended recipient's license prior to first shipment or to obtain written certification that receipt of the material was covered by an appropriate licens In the case of the irradiated gemstone shipments, the licensee stated that even though a copy of the license was on file, that all transfers were complete before it was realized that the client was not authorized to receive radioactive material in the form of irradiated gemstone The licensee stated that no further shipments would be made to this client until appropriate licensing activity had been completed by the clien The inspector reviewed selected licenses of other transferees who had received material irradiated in the Pulstar reactor and found these selected shipments to be appropriate as to type, form and quantit Failure to verify that the recipient was authorized to receive the form of byproduct material transferred was identified as an apparent violationof10CFR30.41(c)(50-297/87-01-03).
6. Followup on IE Dulletin 78-07(92703)
(Closed) This Bulletin required the licensee to describe anticipated actions planned to assure proper protection of personnel when using full facepiece respirators used with air-line equipment that is operated in the demand mod .
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4 The inspector reviewed the respiratory protection equipment onsite and l found that only a self contained breathing apparatus (SCBA) fell into the
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category of equipment described by IEB 78-07. The licensee stated that the SCBA had been returned to the manufacturer for cenversion from demand mode to positive pressure operation. The licensee further stated that respiratory protective devices were not routinely worn but were available i for use in case of an emergency. The licensee had no plans to take protective factor credit for respirators, i
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