ML041180308
| ML041180308 | |
| Person / Time | |
|---|---|
| Site: | 05000083 |
| Issue date: | 05/11/2004 |
| From: | Lyons J NRC/NRR/DRIP/RNRP |
| To: | Vernetson W Univ of Florida |
| Bassett C, NRR/DRIP/RNRP, 404-562-4899 | |
| References | |
| IR-04-201 | |
| Download: ML041180308 (23) | |
See also: IR 05000083/2004201
Text
May 11, 2004
Dr. William G. Vernetson
Director of Nuclear Facilities
Department of Nuclear and
Radiological Engineering
P. O. Box 11830
University of Florida
Gainesville, FL 32611
SUBJECT: NRC INSPECTION REPORT NO. 50-083/2004-201 AND NOTICE OF DEVIATION
Dear Dr. Vernetson:
This letter refers to the inspection conducted on April 19-22, 2004, at your University of Florida Test Reactor
facility. The inspection included a review of activities authorized for your facility. The enclosed report
presents the results of that inspection.
Areas examined during the inspection are identified in the report. Within these areas, the inspection
consisted of selective examinations of procedures and representative records, interviews with personnel,
and observations of activities in progress. Based on the results of this inspection, no safety concern or
noncompliance of NRC requirements was identified. No response to this letter is required.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will
be available electronically for public inspection in the NRC Public Document Room or from the Publicly
Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from
the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html.
Based on the results of this inspection, the NRC has determined that a deviation from your commitment to
the NRC to issue two overdue Annual Reports was identified. The deviation is cited in the enclosed Notice
of Deviation (Notice) and the circumstances surrounding this deviation is described in the subject inspection
report.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice
when preparing your response. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
Should you have any questions concerning this inspection, please contact Craig Bassett at 404-562-4712.
Sincerely,
/RA/
James E. Lyons, Program Director
New, Research and Test Reactors Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No.50-083
License No. R-56
Enclosures:
1. Notice of Deviation
2. NRC Inspection Report No. 50-083/2004-201
cc w/enclosures: Please see next page
University of Florida
Docket No.50-083
cc:
Dr. Ali Haghighat, Chairman
Nuclear and Radiological Engineering
Department
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
Administrator
Department of Environmental Regulation
Power Plant Siting Section
State of Florida
2600 Blair Stone Road
Tallahassee, FL 32301
State Planning and Development
Clearinghouse
Office of Planning and Budgeting
Executive Office of the Governor
The Capitol Building
Tallahassee, FL 32301
William Passetti, Chief
Bureau of Radiation Control
Department of Health
4052 Bald Cypress Way
Tallahassee, FL 32399-1741
May 11, 2004
Dr. William G. Vernetson
Director of Nuclear Facilities
Department of Nuclear and
Radiological Engineering
P. O. Box 11830
University of Florida
Gainesville, FL 32611
SUBJECT: NRC INSPECTION REPORT NO. 50-083/2004-201 AND NOTICE OF DEVIATION
Dear Dr. Vernetson:
This letter refers to the inspection conducted on April 19-22, 2004, at your University of Florida Test Reactor
facility. The inspection included a review of activities authorized for your facility. The enclosed report
presents the results of that inspection.
Areas examined during the inspection are identified in the report. Within these areas, the inspection
consisted of selective examinations of procedures and representative records, interviews with personnel,
and observations of activities in progress. Based on the results of this inspection, no safety concern or
noncompliance of NRC requirements was identified. No response to this letter is required.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will
be available electronically for public inspection in the NRC Public Document Room or from the Publicly
Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from
the NRC Web site at (the Public Electronic Reading Room) http://www.nrc.gov/reading-rm/adams.html.
Based on the results of this inspection, the NRC has determined that a deviation from your commitment to
the NRC to issue two overdue Annual Reports was identified. The deviation is cited in the enclosed Notice
of Deviation (Notice) and the circumstances surrounding this deviation is described in the subject inspection
report.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice
when preparing your response. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
Should you have any questions concerning this inspection, please contact Craig Bassett at 404-562-4712.
Sincerely,
/RA/
James E. Lyons, Program Director
New, Research and Test Reactors Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No.50-083
License No. R-56
Enclosures:
1. Notice of Deviation
2. NRC Inspection Report No. 50-083/2004-201
cc w/enclosures: Please see next page
DISTRIBUTION:
PUBLIC
RNRP\\R&TR r/f
AAdams
CBassett
PDoyle
TDragoun
WEresian
SHolmes
DHughes
EHylton
JLyons
PMadden
MMendonca
Kwitt
PYoung
RidsNrrDrip
DBarss (MS O6-H2)
BDavis (Ltr only O5-A4)
NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML041180308
TEMPLATE No.: NRR-106
OFFICE
RNRP:RI
RNRP:LA
RNRP:SC
RNRP:PD
NAME
CBassett:rdr
EHylton
PMadden
JLyons
DATE
04/ /2004
05/ 05 /2004
05/ 05 /2004
05/ 07 /2004
C = COVER
E = COVER & ENCLOSURE
N = NO COPY
OFFICIAL RECORD COPY
ENCLOSURE 1
NOTICE OF DEVIATION
University of Florida
Docket No.: 50-083
University of Florida Training Reactor
License No.: R-56
During an NRC inspection conducted on April 19-22, 2004, a deviation from your commitment to
the NRC to issue two overdue Annual Reports was identified. In accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the deviation is
listed below:
During an inspection in January 2003, the licensee made a commitment to the NRC to complete
and issue Annual Reports for the facility for the 1999-2000 and the 2000-2001 reporting periods
that had not been issued as of January 16, 2003.
Contrary to the above, during a review on April 22, 2004, it was noted that the Annual Reports for
the facility for those time periods had not been completed or issued as the licensee had indicated.
Please provide to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555, with a copy to the responsible inspector, in writing within 30 days of the
date of this Notice, (1) the reason for the deviation, or if contested, the basis for disputing the
deviation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective
steps that will be taken to avoid further deviations, and (4) the date when your corrective action will
be completed. Where good cause is shown, consideration will be given to extending the response
time.
If you contest this enforcement action, you should also provide a copy of your response, with the
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, D.C. 20555-0001.
Because your response will be made available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of the NRCs
document system (ADAMS), to the extent possible, it should not include any personal privacy,
proprietary, or safeguards information so that it can be made available to the public without
redaction. ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room)
http://www.nrc.gov/reading-rm/adams.html. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.730(b) to support a request for withholding confidential commercial or financial information). If
safeguards information is necessary to provide an acceptable response, please provide the level of
protection described in 10 CFR 73.21.
Dated at Rockville, Maryland
this 11th day of May 2004.
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No:
50-083
License No:
R-56
Report No:
50-083/2004-201
Licensee:
University of Florida
Facility:
University of Florida Training Reactor
Location:
Gainesville, FL
Dates:
April 19-22, 2004
Inspector:
Craig Bassett
Approved by:
James E. Lyons, Program Director
New, Research and Test Reactors Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
University of Florida
University of Florida Training Reactor
Inspection Report No.: 50-083/2004-201
The primary focus of this routine, announced inspection was the onsite review of selected aspects
of the licensees Class II research reactor safety programs including: organizational structure and
staffing, review and audit and design change functions, procedures, radiation protection, effluent
and environmental monitoring, transportation of radioactive materials, security, and material control
and accounting since the last NRC inspection of these areas. The licensees programs were
acceptably directed toward the protection of public health and safety, and in compliance with NRC
requirements.
Organizational Structure and Staffing
The operations organizational structure and responsibilities were consistent with Technical Specifications Sections 6.2.1 - 6.2.4 requirements.
Review and Audit and Design Change Functions
The review and audit program was being conducted acceptably by the Reactor Safety Review
Subcommittee as stipulated in Technical Specifications Section 6.2.5.
The design control program was being implemented as required.
Procedures
Facility procedural review, revision, control, and implementation satisfied Technical
Specification requirements.
Radiation Protection Program
Surveys were being completed and documented acceptably to permit evaluation of the
radiation hazards present.
Postings met the regulatory requirements specified in 10 CFR Parts 19 and 20.
Personnel dosimetry was being worn as required and doses were well within the NRCs
regulatory limits.
Radiation monitoring equipment was being maintained and calibrated as required.
The Radiation Protection Program being implemented by the licensee satisfied regulatory
requirements.
-2-
Effluent and Environmental Monitoring
Effluent monitoring satisfied procedural and regulatory requirements and releases were within
the specified regulatory and Technical Specification limits.
Transportation of Radioactive Materials
Transfer of radioactive material from the University of Florida Training Reactor to the State of
Florida (Agreement State) License was completed and documented in accordance with
licensee procedural requirements.
Security
Security facilities, equipment, procedures, and controls satisfied the Physical Security Plan
requirements.
Material Control and Accounting
Special nuclear material was acceptably controlled and tracked as required by 10 CFR Part 70.
REPORT DETAILS
Summary of Plant Status
The licensees one hundred kilowatt modified Argonaut-UTR type research and test reactor
continued to be operated in support of education, operator training, surveillance, contract or service
work, and experiments. During the inspection, the reactor was not operated.
1.
Organizational Structure and Staffing
a. Inspection Scope (Inspection Procedure [IP] 69001)
The inspector reviewed selected aspects of the following regarding the licensees
organization and staffing to ensure that the requirements of Sections 6.2.1 - 6.2.4 of
Technical Specifications (TS), Amendment No. 23, dated December 28, 2001, were being
met:
organizational structure for the University of Florida Training Reactor (UFTR)
current staff qualifications
management responsibilities as outlined in the TS
selected portions of the UFTR Operating Log pages for the past year through the
present
b. Observations and Findings
The operations organizational structure had not functionally changed since the last NRC
inspection (refer to NRC Inspection Report 50-083/2003-201). The operations staff was
comprised of two Senior Reactor Operators (SROs), which included the Facility Director,
and two people in training to become licensed SROs. TS Section 6.2.4 specifies that the
training and qualification criteria contained in the ANSI/ANS (American National Standards
Institute) Standard 15.4-1977, Standards for Selection and Training of Personnel for
Research Reactors, are required to be met by UFTR personnel. The inspector verified that
the education, training, and experience of the operations staff met ANSI/ANS 15.4-1977
requirements. Staffing, during reactor operation, was as required. UFTR staff continued to
receive HP support from the University Radiation Control Officer and his staff. Review of
records verified that management responsibilities were administered as required by the TS
and applicable procedures.
c.
Conclusions
The operations organizational structure and staffing were consistent with TS Section 6.2.
Shift staffing met the minimum requirements for current operations.
2. Review and Audit and Design Change Functions
a. Inspection Scope (IP 69001)
In order to verify that the licensee had established and conducted reviews and audits as
required in TS Section 6.2.5, the inspector reviewed selected aspects of:
Reactor Safety Review Subcommittee (RSRS) meeting minutes from October 2001
through 2004
-2-
safety review and audit records for the past two years and licensee responses to the
reviews and audits
facility design changes and records for the past two years
UFTR Standard Operating Procedure (SOP)-0.1, Operating Document Controls,
Revision (Rev) 3, dated September 2003
UFTR SOP-0.2, Control of Maintenance, Rev 4, dated May 1987
UFTR Form SOP-0.2A, UFTR Work Assignment and Maintenance Log, Rev 4, dated
May 1987
UFTR SOP-0.3, Control of Documentation of UFTR Modifications, Rev 1, dated
October 1999
UFTR Form SOP-0.3A, QA Document Checklist for Modification Packages, Rev 1,
dated October 1999
UFTR SOP-0.4, 10 CFR 50.59 Evaluation and Determination, Rev 2, dated July 2000
UFTR Form SOP-0.4A, 10 CFR 50.59 Evaluation and Determination, Rev 2, dated
July 2000
UFTR Form SOP-0.4B, Supporting Material for 10 CFR 50.59 Determination, Rev 2,
dated July 2000
UFTR SOP-0.5, UFTR Quality Assurance Program, Rev 2, dated July 1991
UFTR Form SOP-0.5B1Procurement Document Package Coversheet, Rev 2, dated
July 1991
UFTR Form SOP-0.5E, Annual QA Audit Checklist, Rev 3, dated February 2003
b. Observations and Findings
(1) Review and Audit Functions
The RSRS committee met 23 times during the period from October 2001 to January
2004. At least one meeting was held each quarter at intervals not to exceed four
months as required by TS Section 6.2.5 (2). The membership also satisfied the charter
requirements stipulated in the TS. Review of the minutes indicated that the committee
provided guidance and direction to ensure suitable oversight of reactor operations. The
RSRS committee minutes and audit records also showed that safety reviews and
individual audits had been completed at the required frequency and submitted to the
Dean of the College of Engineering within three months of completion for the functional
areas specified by TS Section 6.2.5(4). The audits appeared to be comprehensive and
well documented. The inspector noted that the licensee took appropriate corrective
actions in response to the audit findings when appropriate. Committee records
documented that procedure changes were reviewed as required as well.
(2) Design Change Functions
The inspector reviewed the 10 CFR 50.59 evaluations and corresponding design
change packages for selected changes for 2003. From these reviews, the inspector
determined that the evaluations had adequate supporting documentation and
information. Additionally, the inspector found that the 10 CFR 50.59 reviews and
approvals were focused on safety and met TS and UFTR procedure requirements. Post
installation verification testing of systems or equipment that had been changed was
completed and adequately documented. Procedure and drawing changes were
included in the change packages and were consistent with TS and UFTR requirements
for facility changes. None of the changes posed a safety question or required a change
to the TS.
-3-
c.
Conclusions
Audits and reviews were being conducted by the RSRS in accordance with the
requirements specified in TS Section 6.2.5. The licensees design change program was
being implemented as required.
3. Procedures
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to ensure that the requirements of
TS Section 6.3 were met:
administrative controls for changing procedures
records of changes and temporary changes
RSRS meeting minutes for 2001 through 2004
UFTR SOP-0.1, Operating Document Controls, Rev 3, dated September 2003
UFTR Form SOP-0.1A, Cover Sheet/Change Request Form, Rev 3, dated September
2003
UFTR SOP-0.5, UFTR Quality Assurance Program, Rev 3, dated February 2003
b. Observations and Findings
Procedures were available for those tasks and items required by TS Section 6.3. The
procedures were adequate to perform the reactor and other operations which they covered.
The inspector reviewed changes and temporary changes to selected procedures. The
licensee implemented changes and temporary changes to procedures, and the associated
review and approval processes, by use of administrative procedures UFTR SOP-0.1 and -
0.5. The changes and temporary changes had been controlled, and approved and reviewed
by the RSRS committee as required.
The inspector reviewed training records and interviewed the staff, and determined that the
training of personnel on procedures and subsequent changes to procedures was effective.
Personnel were also observed performing maintenance activities and a weekly survey in
accordance with applicable procedures. The inspector determined that use of and
adherence to the procedures were acceptable.
c.
Conclusions
The inspector determined that the procedural change, control, and implementation program
was acceptably maintained as required by TS and the applicable procedures.
4. Radiation Protection Program
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with 10 CFR Parts 19 and 20 and
TS Sections 3.4.1 and 4.2.4:
-4-
radiation and contamination survey records for 2003 to date
UFTR facility dosimetry records for 2002 through 2003
calibration and periodic check records for radiation monitoring instruments documented
on the applicable forms for 2002 to date
University of Florida Radiation Control Guide last issued February 1997
ALARA Policy as outlined the UFTR ALARA Program, Rev 0, dated December 1993
University of Florida (UFL) Radiation Control Committee meeting minutes for December
2003 and March 2004
4th Quarter ALARA Report of the UFL Radiation Control and Radiological Services
Department for the Radiation Control Committee
UFTR SOP-D.1, UFTR Radiation Protection and Control, Rev 5, dated December
1993 and Temporary Change Notice (TCN) dated October 2001
UFTR Form SOP-D.1A, UFTR Radiation Weekly Survey, Rev 5, dated December
1993
UFTR Form SOP-D.1B, UFTR Swipe Survey Results, Rev 5, dated December 1993
UFTR SOP-D.2, Radiation Work Permit, Rev 10, dated March 1987
UFTR Form SOP-D.2A, Radiation Work Permit, University of Florida Training Reactor,
Rev 10, dated March 1987 and TCN dated January 1999
UFTR SOP-D.3, Primary Equipment Pit Entry, Rev 4, dated October 2001
UFTR SOP-D.4, Removing Irradiated Samples from UFTR Experimental Ports, Rev 7,
dated October 2001
UFTR Quarterly #2 (Q-2 Surveillance), Calibration Check of Area and Stack Radiation
Monitors, Rev 3, dated February 2003
UFTR Quarterly #4 (Q-4 Surveillance), Unrestricted Area Indoor/Outdoor Radiation
Survey, Rev 3, dated February 2003
UFTR Quarterly #5 (Q-5 Surveillance), Restricted Area Radiation Survey, Rev 3, dated
February 2003
UFTR Quarterly #9 (Q-9 Surveillance), Quarterly Calibration of Air Particulate
Detector, Rev 2, dated July 1991
The inspector also toured the facility, conducted a radiation survey of selected areas, and
observed the use of dosimetry and radiation monitoring equipment. Radiological signs and
other postings were observed as well.
-5-
b. Observations and Findings
(1) Surveys
The inspector reviewed weekly radiation and contamination surveys conducted by
reactor staff personnel. These were surveys of facility controlled areas including the
Radiochemistry Laboratory (Lab) and classroom, the NAA (Neutron Activation Analysis)
Lab, the Control Room, and the Reactor Cell from 2003 to date. The inspector also
reviewed quarterly general area radiation surveys of restricted and unrestricted areas
completed by the licensee and UFL Environmental Health and Safety (EH&S)
Department personnel. The results were documented on the appropriate forms and
were evaluated and reviewed as required. No readings or results were noted that
exceeded set action levels but the licensee indicated that corrective action would be
taken if a problem were detected.
During the inspection, the inspector conducted a radiation survey of the Radiochemistry
and NAA Labs and the Reactor Cell and compared the readings detected with those
found by the licensee. The results were comparable and no anomalies were noted.
(2) Postings and Notices
The inspector reviewed the postings at the entrances to various controlled areas
including the Control Room, the Reactor Cell, and the Radiochemistry Lab in the UFTR
facility. The postings were acceptable and indicated the radiation and contamination
hazards present. Other postings also showed the industrial hygiene hazards present in
the areas. The facilitys radioactive material storage areas were noted to be properly
posted. No unmarked radioactive material was detected in the facility. Copies of
current notices to workers required by 10 CFR Part 19 were posted in various locations
throughout the facility, including on a bulletin board in the Control Room.
(3) Dosimetry
The licensee used a National Voluntary Laboratory Accreditation Program- accredited
vendor (Landauer) to process personnel dosimetry. Through direct observation, the
inspector determined that dosimetry was acceptably used by facility personnel.
The inspector determined that the licensee used Optically Stimulated Luminescent
(OSL) dosimeters for whole body monitoring of beta and gamma radiation exposure
with an additional component to measure fast/thermal neutron radiation. The licensee
used thermoluminescent dosimeter (TLD) finger rings for extremity monitoring as
needed. An examination of the OSL and TLD results for the past two years showed that
the highest occupational doses, as well as doses to the public, were within
10 CFR Part 20 limitations. The records showed that the highest annual whole body
exposure received by a single individual for 2002 was 43 millirem (mr) deep dose
equivalent (DDE). The highest annual extremity exposure for that year was 44 mr
shallow dose equivalent (SDE). For 2003, the highest annual whole body exposure
received by a single individual was 4 mr DDE and the highest annual extremity exposure
was 21 mr SDE.
(4) Radiation Monitoring Equipment
-6-
The calibration records of portable survey meters, friskers, fixed radiation detectors, and
air monitoring instruments in use at the facility were reviewed. The records showed that
the calibrations were completed by either reactor staff or campus EH&S Division
personnel. The calibrations were tracked and controlled using a Microsoft Access
database. The inspector confirmed that the frequencies of the calibrations, completed
quarterly or semiannually, satisfied the requirements established in the TS Section 4.2.4
and 10 CFR 20.1501(b). All instruments checked by the inspector had a current
calibration sticker attached. The inspector also verified that the calibration and check
sources geometry and energies matched those used in actual detection or analyses.
(5) Radiation Protection Program
The licensees Radiation Protection Program was established in the University of Florida
Radiation Control Guide dated February 1997 and the UFTR SOPs. The program
required that all personnel who had unescorted access to work in a radiation area or
with radioactive material receive training in radiation protection, policies, procedures,
requirements, and facilities prior to entry. The program was being reviewed annually as
required. The ALARA Policy was also outlined and established in the Radiation Control
Guide, in Section 7 of the TS, and in the UFTR ALARA Program, dated December
1993. The ALARA Policy provided guidance for keeping doses as low as reasonably
achievable and was consistent with the guidance in 10 CFR Part 20.
(6) Radiation Work Permit Program
The inspector reviewed selected Radiation Work Permits (RWPs) that had been written
and used during 2003 as stipulated in UFTR SOP-D.2. It was noted that the controls
specified in the RWPs were acceptable and applicable for the type of work being done.
The RWPs had been initiated, reviewed, and approved as required. Following
completion of the work covered by the various RWPs, they had been terminated as
required.
(7) Radiation Protection Training
The inspector reviewed the radiation worker (rad worker) training given to staff members
and to part-time assistants such as students. Initial training included attending the UFL
EH&S Divisions Radiation Safety Short Course. Refresher training for licensee
personnel was given every two years, basically through the Reactor Operator
Requalification Program.
The initial and refresher training covered the topics specified in 10 CFR Part 19 as
required. Training records showed that personnel were acceptably trained in radiation
protection practices. The training program was acceptable.
(8) Facility Tours
The inspector toured the Control Room, Reactor Cell, and other selected support
laboratories and offices. Control of radioactive material and control of access to
radiation and high radiation areas were acceptable. As noted earlier, the postings and
signs for these areas were appropriate.
c.
Conclusions
-7-
The inspector determined that the Radiation Protection Program being implemented by the
licensee satisfied regulatory and TS requirements because: 1) surveys were being
completed and documented acceptably; 2) postings met regulatory requirements;
3) personnel dosimetry was being worn as required and doses were well within the NRCs
regulatory limits; 4) radiation monitoring equipment was being maintained and calibrated as
required; and, 5) the radiation protection training program was acceptable.
5. Effluent and Environmental Monitoring
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with the requirements of
10 CFR Part 20 and TS Sections 3.4.2 - 3.4.6 and 4.2.4:
data on environmental releases and effluent monitoring contained in the licensees
Monthly Utilization and General Activities Reports for 2002 to date
results of the analyses of air samples taken from the Reactor Room and the stack
results of the analyses of liquid samples taken from the primary system, the secondary
system, and the shield tank
UFTR SOP-D.1, UFTR Radiation Protection and Control, Rev 5, dated December
1993
UFTR Form SOP-D.1C, Portable Air Sample Activity and LLD Calculation, Rev 5,
dated December 1993
UFTR Form SOP-D.1D, Liquid Sample Activity and LLD Calculation, Rev 5, dated
December 1993
UFTR SOP-D.7, Circulation, Sampling, Analysis, and Discharge of Holdup Tank
Wastewater, Rev 1, dated April 2002
UFTR Form SOP-D.7A, Liquid Sample Activity and LLD Calculation, Rev 1, dated April
2002
UFTR Form SOP-D.7B, UFTR Waste Water Holdup Tank Release Authorization,
Rev 1, dated April 2002
b. Observation and Findings
The inspector reviewed the calibration records of the area and stack monitoring systems.
These systems had been calibrated quarterly as required by TS Section 4.2.4.
The inspector reviewed the records documenting liquid and airborne releases to the
environment for the past two years. The inspector determined that gaseous releases
continued to be calculated as required by procedure and were adequately documented.
The releases were determined to be within the annual dose constraints of 10 CFR 20.1101
(d), 10 CFR Part 20 Appendix B concentrations, and TS limits. This was documented in the
licensees Monthly Utilization and General Activities Reports issued for information and
review by the RSRS. COMPLY code calculations conducted by the UFL EH&S Division for
the UFTR indicated an effective dose equivalent to the public of 0.4 mr for 2002 and 0.5 mr
for 2003. Observation of the facility by the inspector found no new potential release paths.
Liquid releases were approved by the Facility Director or Reactor Supervisor and the
Radiation Control Officer after analyses indicated that the releases would meet regulatory
requirements for discharge into the sanitary sewer.
-8-
c.
Conclusions
Effluent monitoring satisfied procedural and regulatory requirements and releases were
within the specified regulatory and TS limits.
6. Transportation
a. Inspection Scope (IP 86740)
The inspector reviewed the following to verify compliance with procedural requirements for
transferring licensed material:
records of radioactive material transfers from the reactor license to the State of Florida
materials license for 2002 and to date
UFTR SOP-D.4, Removing Irradiated Samples from UFTR Experimental Ports, Rev 7,
dated October 2001
UFTR Form SOP-D.4A, Record of Sample Irradiation and Disposition, Rev 7, dated
October 2001
UFTR SOP-D.5, UFTR Reactor Waste Transfer, Rev 2, dated June 2002
UFTR Form SOP-D.5A, Radioactive Reactor Waste Transfer Checklist, Rev 2, dated
June 2002
UFTR Form SOP-D.5B, Radioactive Reactor Waste Container Inventory, Rev 2, dated
June 2002
UFTR Form SOP-D.5C, Swipe Samples Analysis Report, Rev 2, dated June 2002
UFTR Form SOP-D.5D, Radioactive Waste Container Radiation Survey, Rev 2, dated
June 2002
UFTR SOP-D.6, Control of UFTR Radioactive Material Transfers, Rev 1, dated April
2000
UFTR Form SOP-D.6A, University of Florida Training Reactor/University of Florida
Radioactive Material Transfer Record, Rev 1, dated April 2000
UFTR Form SOP-D.6B, University of Florida/University of Florida Training Reactor
Radioactive Material Transfer Record, Rev 1, dated April 2000
UFTR Form SOP-D.6C, University of Florida Training Reactor/University of Florida
Activated Foil Transfer Record, Rev 1, dated April 2000
UFTR Form SOP-D.6D, University of Florida Training Reactor/University of Florida
Neutron Radiography Film Cassette Transfer Record, Rev 1, dated April 2000
UFTR Form SOP-D.6E, University of Florida Training Reactor/University of Florida
Rabbit System Sample Package Transfer Record, Rev 1, dated April 2000
b. Observations and Findings
Through records review and discussions with licensee personnel, the inspector determined
that the licensee had transferred radioactive material and solid waste produced by reactor
operations to the University of Floridas State of Florida license (Agreement State License),
License No. 356-1, expiration date February 28, 2005, for possession, shipment, or
disposal. All transfers were recorded on the appropriate and applicable forms. Transfer
documentation was kept on file as required.
c.
Conclusions
-9-
Transfer of radioactive material from the UFTR to the State of Florida (Agreement State)
License was completed and documented in accordance with facility procedural
requirements.
7. Security
a. Inspection Scope (IPS 81401, 81402, 81403, 81431, and 81810)
To verify compliance with the licensees NRC-approved Physical Security Plan (PSP) and to
assure that changes, if any, to the plan had not reduced its overall effectiveness, the
inspector reviewed:
security systems, equipment, and instrumentation
logs, records, and reports concerning security
audits of security and responses to the audits
access, key, and lock control documented in various key logs
Memorandum (Munroe to Vernetson), Authorization to Carry Reactor Cell Key, dated
December 22, 2003
UFTR SOP-F.1, Physical Security Controls, Rev 1, dated May 1984
UFTR Form SOP-F.1A, Security Information Form, Rev 1, dated May 1984
UFTR SOP-F.7, Security Plan Response Procedure Controls, Rev 3, dated April 2002
UFTR SOP-F.8, UFTR Safeguards Reporting Requirements, Rev 1, dated December
1997 and TCN dated October 1999
UFTR Form SOP-8.B, Log of UFTR Safeguards Events, Rev 1, dated December 1997
UFTR Quarterly #8 (Q-8 Surveillance), Log of Safeguards Events, Rev 1, dated
December 1997
UFTR Semiannual #6 (S-6 Surveillance), Key Inventory, Rev 2, dated January 2000
UFTR Semiannual #7 (S-7 Surveillance), Semiannual Check (Replacement) of Security
System Batteries, Rev 2, dated January 2000
UFTR Annual #6 (A-6 Surveillance), Physical Inventory of Locks/Cores, Rev 2, dated
January 2000
b. Observations and Findings
The PSP was the same as the latest revision approved by the NRC, Revision 14, dated
September 25, 1997. The PSP response procedures and various UFTR procedures were
consistent with, and adequately implemented, the PSP. The inspector verified that the PSP
was being reviewed annually as required. It was also noted that the licensee was properly
controlling and protecting the PSP and other safeguards information as required by the
regulations.
Through records review and interviews with licensee personnel, the inspector verified that
there had been no safeguards events at the facility since the last inspection. Also, although
no new fuel had been received by the licensee recently, the PSP contained provisions to
establish and maintain protection of such fuel and other SNM.
The inspector toured the facility and confirmed that the physical protection systems,
equipment, and instrumentation were as required by the PSP. The inspector confirmed that
security checks, tests, verifications, and periodic audits were performed and tracked as
required. Corrective actions were taken when problems with security or the equipment were
noted. Access control was implemented as required by the PSP and licensee procedures.
-10-
Periodic training was provided to both the UFTR staff and the university campus police.
Response rosters were current and posted as required. Communication between the
reactor staff and the university police was acceptable and checked periodically.
The inspector contacted the UFL Police Department. UFL police personnel provided
security for the UFTR as required by the PSP including periodic patrols and initial response
to events at the facility. The inspector interviewed one supervisor and a dispatcher and
determined that they were knowledgeable of the reactor facility and their responsibilities in
case of a security event. The inspector determined that a current response roster was
being maintained at the police dispatch office as required. The inspector also noted a good
working relationship between the UFTR and UFL Police Department staff members.
The inspector also visited the Campus Key Shop. The inspector interviewed a specialist
there and determined that proper control was being maintained over access to facility keys
and the key making process.
c.
Conclusions
Security facilities, equipment, training, and procedures satisfied PSP requirements.
8. Material Control and Accounting
a. Inspection Scope (IP 85102)
To verify compliance with 10 CFR Part 70, the inspector reviewed:
control of Special Nuclear Material (SNM) storage areas
annual fuel inventory results and accountability forms, records, and reports
Nuclear Material Transaction Reports for the time period from October 2001 through
September 2003
Special Nuclear Material (SNM) accountability program
data on SNM handling contained in the licensees Monthly Utilization and General
Activities Reports for 2002 to date
UFTR Operating Log pages for January 2003 through the present
UFTR SOP-C.1, Irradiated Fuel Handling, Rev 4, dated February 1985 and TCN dated
October 1999
UFTR SOP-C.3, Fuel Inventory Procedure, Rev 4, dated August 1997
UFTR Form SOP-C.3A, Fuel Safe Inventory Verification Form, Rev 4, dated August
1997
UFTR Form SOP-C.3B, Storage Pit Inventory Verification Form, Rev 4, dated August
1997
UFTR Form SOP-C.3C, Inventory and Burnup Determination for Material Status
Report, Rev 4, dated August 1997
UFTR Semiannual #3 (S-3 Surveillance), Semiannual Inventory of Special Nuclear
Material, Rev 4, dated August 1997
b. Observations and Findings
The inspector determined that, in accordance with licensee procedure UFTR SOP-C.3, the
licensees material control and accountability program tracked locations and content of
irradiated and unirradiated fuel elements and plates, fission detectors, and other special
-11-
nuclear material (SNM) maintained under the R-56 license. The inspector verified that the
licensee maintained an amount of SNM that was equal to or less than that authorized by the
license. Fuel burn-up related measurements and calculations were found to be acceptable
and properly documented. Fuel inventory and movement forms maintained in the UFTR
Fuel Inventory folder were properly prepared. These transactions of material control and
accountability were cross referenced in the appropriate Operating Log pages.
The records reviewed by the inspector showed that the licensee was maintaining control of
SNM as required and that possession and use of SNM was limited to those purposes
authorized by the license. The records also showed that the licensee was maintaining
control of SNM storage areas as required. The appropriate Nuclear Material Transaction
Reports (DOE/NRC Form 741) and Material Status Reports (DOE/NRC Form 742) had
been completed semiannually and submitted by the licensee to the appropriate regulatory
agencies in a timely manner and as required by 10 CFR 74.13(1). The inspector also
verified that physical inventories were conducted at least annually as required by 10 CFR 70.51(d).
During the inspection, the inspector toured the facility, examined the SNM and fuel storage
areas, and verified that the licensee was using and storing SNM in those areas designated
for such use in the PSP. The inspector also observed an inventory and verified the serial
numbers of four unirradiated fuel plates, observed the containers of fuel samples, and
verified the locations of irradiated fuel elements that were being maintained in storage as
indicated on the applicable licensee records. This demonstrated that the fuel and other
SNM were in the locations specified and that records documenting the storage and
transfers of SNM were accurate.
c.
Conclusions
The licensees program for controlling and tracking SNM as required by 10 CFR Part 70
was being implemented acceptably.
9. Operations
a. Inspection Scope (IP 69001)
The inspector reviewed the following to determine the licensee's actions taken in response
to a self-identified problem:
Letter submitted by the licensee to the NRC dated May 14, 2003, detailing the potential
TS Violation
Reactor Safety Review Subcommittee (RSRS) meeting minutes from 2002 through
2004
selected portions of the UFTR Operating Log pages for the past year through the
present
UFTR SOP-E.4, UFTR Nuclear Instrumentation Calibration Check, Rev 3, dated March
2001 and TCN dated June 2003
UFTR Quarterly #1 (Q-1 Surveillance), Check of Scram Functions, Rev 3, dated
February 2003 and TCN dated December 2003
UFTR Annual #2 (A-2 Surveillance), UFTR Nuclear Instrumentation Calibration Check
and Calorimetric Heat Balance, Rev 3, dated March 2001 and TCN dated September
2002
-12-
b. Observation and Findings
(1) Self-identified Problem
On January 3, 2003, the licensee conducted a quarterly scram check (UFTR Quarterly
- 1 (Q-1 Surveillance)). This involved checking and verifying that the Wide Range
Detectors circuit tripped at an 8.5% voltage drop. (The trip set point is set at 8.5% to
preclude a TS violation which requires a trip at 10% loss of high voltage, a Limiting
Safety System Setting). On February 26, 2003, the trip was adjusted in a
nonconservative direction, per UFTR SOP-E.4, UFTR Nuclear Instrumentation
Calibration Check, Step 7.2.17, for the annual surveillance check (UFTR Annual #2, (A-
2 Surveillance)). The procedure did not mention any readjustment of the trip set point
until Step 7.4.20. Due to the procedure or some other problem, adjustment of the trip
set point back to the original conservative 8.5% setting was apparently overlooked and
not changed by personnel performing the surveillance.
On May 2, 2003, during performance of the next required quarterly scram checks (Q-1
Surveillance), it was discovered that the 10% reduction in high voltage power supplied to
the wide range detectors failed to cause a trip as required. The actual setting was
determined to be at over a 19% voltage drop on May 6, 2003.
On May 14, 2003, the licensee submitted a letter to the NRC detailing the potentially
promptly reportable occurrence involving the operation of the reactor with an LSSS less
conservative than specified in the TS. The problem was characterized as a potential
violation of the TS Section 3.2.3 which specifies the reactor control and safety systems
measuring channels and Table 3.1 which specifies that reactor safety system trips at
10% loss of chamber high voltage.
As a result of the problem noted, the licensee readjusted the trip set point so that the
reactor tripped at an 8.5% voltage drop. The need for careful verbatim compliance with
procedures to avoid overlooking required steps was reiterated to all operations staff
members during a training session. Also, UFTR SOP-E.4 was revised to correct Step
7.2.17 and Step 7.4.20 to ensure that the trip setting was changed when the high
voltage on the detector was changed to preclude recurrence of such an event.
(2) Evaluation of Corrective Actions
In reviewing the UFTR Operating Log pages for the time from February 26 through May
2, 2003, the inspector noted that the loss of high voltage trip was never challenged
during reactor operation. It was also noted that the licensee identified the problem and
corrected it during surveillance activities conducted at shutdown conditions. In addition,
it was noted that other trips were available and, in most cases, the loss of high voltage
would have been sufficient to produce a trip, even if 20% loss of high voltage were
required. The inspector also reviewed UFTR SOP-E.4 and found that the procedure
was revised to ensure that the trip setting was readjusted when the high voltage on the
detector was changed.
The licensee was informed that this licensee-identified and corrected violation (involving
operation of the reactor with an LSSS less conservative than specified in the UFTR TS)
is being treated as a Non-Cited Violation (NCV), consistent with Section VII.B.1 of the
NRC Enforcement Policy (NCV 50-083/2004-201-01).
-13-
c.
Conclusions
The licensee took proper corrective actions in response to a self-identified problem
concerning operating the reactor with a non-conservative trip setting for loss of high voltage
to the Wide Range Detectors.
-14-
10. Follow-up on Previous Inspection Items
a. Inspection Scope (IP 69001)
The inspector reviewed the following to determine the licensees actions taken in response
to a previously identified Inspector Follow-up Item:
Reactor Safety Review Subcommittee (RSRS) meeting minutes from 2002 through
2004
the most recently available Annual Reports
b. Observation and Findings
(Closed) IFI 50-083/2003-201-01 - During an NRC inspection in January 2003, the inspector
reviewed the RSRS meeting minutes. The inspector noted that the RSRS had been
informed that the licensee had not submitted the Annual Reports to the NRC for
September 1, 1999 - August 31, 2000 and for September 1, 2000 - August 31, 2001 as
required. When questioned about this issue, the licensee stated that the reports had not
been issued (as of January 16, 2003). The licensee indicated that the reports were being
prepared and made a commitment to issue the 1999-2000 Annual Report by January 24,
2003 and the 2000-2001 Annual Report by February 10, 2003.
During this inspection the issue of completing the Annual Reports was reviewed again. The
licensee indicated that, although a person had been hired to complete the annual reports,
they were not finished as of the date of the inspection. The licensee was informed that
failure to complete the Annual Reports (by the dates indicated above) was an apparent
deviation from a commitment made to the NRC (DEV 50-083/2004-201-02). This issue will
be reviewed during a subsequent inspection.
c.
Conclusions
Appropriate actions were not taken by the licensee concerning a commitment made to the
NRC resulting in a deviation.
11. Exit Meeting Summary
The inspector reviewed the inspection results with members of licensee management at the
conclusion of the inspection on April 22, 2004. The licensee acknowledged the findings
presented and did not identify as proprietary any of the material provided to or reviewed by the
inspector during the inspection except for certain documents pertaining to security.
PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
A. Haghighat
Chairman, Nuclear and Radiological Engineering Department
B. Shea
Senior Reactor Operator
W. Vernetson
Facility Director
Other Personnel
D. Munroe
Radiation Control Officer, Radiation Control and Radiological Services
Department, EH&S Division, University of Florida
W. McColskey
Maintenance Specialist, Key Shop, Physical Plant Division, University of Florida
D. Smith
Dispatcher/Communications, University Police Department, University of Florida
M. Welsh
Lieutenant, University Police Department, University of Florida
INSPECTION PROCEDURE (IP) USED
Class II Research and Test Reactors
Plans, Procedures, and Reviews
Reports of Safeguards Events
Receipt of New Fuel at Reactor Facilities
Fixed Site Physical Protection of Special Nuclear Material of Low Strategic
Significance
Protection of Safeguards Information
Material Control and Accounting
Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-083/2004-201-01
Operation of the reactor with an LSSS less conservative than
specified in the UFTR TS.
50-083/2004-201-02
DEV
Failure fulfill a commitment to the NRC to complete the UFTR
Annual Report for 1999-2000 by January 24, 2003 and the UFTR
Annual Report for 2000-2001 by February 10, 2003.
Closed
50-083/2004-201-01
Operation of the reactor with an LSSS less conservative than
specified in the UFTR TS.
50-083/2003-201-01
IFI
Follow-up to verify that the licensee issued the 1999-2000 Annual
Report by January 24, 2003 and the 2000-2001 Annual Report by
February 10, 2003.
PARTIAL LIST OF ACRONYMS USED
ANSI
American National Standards Institute
As Low As Reasonably Achievable
CFR
Code of Federal Regulations
DEV
Deviation
EH&S
Environmental Health and Safety Department
Health Physics
IFI
Inspector Follow-up Item
Lower Limit of Detection
mr
millirem
NAA
Neutron Activation Analysis
Non-Cited Violation
NRC
Nuclear Regulatory Commission
Optically Stimulated Luminescent (dosimeters )
RSRS
Reactor Safety Review Subcommittee
Radiation Work Permit
Physical Security Program
Shallow dose equivalent
Standard Operating Procedure
Senior Reactor Operator
TS
Technical Specifications
UFTR
University of Florida Test Reactor