ML041690561
| ML041690561 | |
| Person / Time | |
|---|---|
| Site: | Washington State University |
| Issue date: | 06/28/2004 |
| From: | Lyons J NRC/NRR/DRIP/RNRP |
| To: | Peterson J Washington State Univ |
| Bassett C, NRR/DRIP/RNRP 404-562-4899 | |
| References | |
| 50-027/2004-201 IR-04-201 | |
| Download: ML041690561 (25) | |
See also: IR 05000027/2004201
Text
June 28, 2004
Dr. James N. Petersen
Vice Provost for Research
Washington State University
Pullman, WA 99164-1030
SUBJECT: NRC INSPECTION REPORT NO. 50-027/2004-201 AND NOTICE OF VIOLATION
Dear Dr. Petersen:
This refers to the inspection conducted on June 7-10, 2004, at your Washington State University
TRIGA research reactor in the Nuclear Radiation Center. 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, the NRC has identified two violations of NRC requirements. These violations are
cited in the enclosed Notice of Violation (Notice). The circumstances surrounding them are
described in detail in the subject inspection report. The violations are of concern because they
should have been identified by your own review of the documents involved.
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 accordance
with its policies to determine whether further enforcement action is necessary to ensure
compliance with regulatory requirements.
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.
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.50-027
License No. R-76
Enclosures: 1. Notice of Violation
2. NRC Inspection Report No. 50-027/2004-201
cc w/enclosure: Please see next page
Washington State University
Docket No. 50-27
cc:
Dr. Dwight Hagihara
Chair, Reactor Safeguards Committee, Nuclear Radiation Center
Washington State University
P.O. Box 641300
Pullman, WA 99164-1300
Stephanie Sharp
Reactor Supervisor, Nuclear Radiation Center
Washington State University
P.O. Box 641300
Pullman, WA 99164-1300
Dr. Len Porter
Director, Radiation Safety Office
Washington State University
P.O. Box 641302
Pullman, WA 99164-1302
Dr. Gerald Tripard
Director, Nuclear Radiation Center
Washington State University
P.O. Box 641300
Pullman, WA 99164-1300
Test, Research, and Training
Reactor Newsletter
University of Florida
202 Nuclear Sciences Center
Gainesville, FL 32611
June 28, 2004
Dr. James N. Petersen
Vice Provost for Research
Washington State University
Pullman, WA 99164-1030
SUBJECT: NRC INSPECTION REPORT NO. 50-027/2004-201 AND NOTICE OF VIOLATION
Dear Dr. Petersen:
This refers to the inspection conducted on June 7-10, 2004, at your Washington State University
TRIGA research reactor in the Nuclear Radiation Center. 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, the NRC has identified two violations of NRC requirements. These violations are
cited in the enclosed Notice of Violation (Notice). The circumstances surrounding them are
described in detail in the subject inspection report. The violations are of concern because they
should have been identified by your own review of the documents involved.
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 accordance
with its policies to determine whether further enforcement action is necessary to ensure
compliance with regulatory requirements.
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.
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.50-027
License No. R-76
Enclosures: 1. Notice of Violation
2. NRC Inspection Report No. 50-027/2004-201
cc w/enclosure: See next page
DISTRIBUTION:
PUBLIC
RNRP/R&TR r/f
AAdams
CBassett
KWitt
PDoyle
TDragoun
WEresian
FGillespie
PYoung
SHolmes
DHughes
EHylton
DBarss (MS O6-H2)
JLyons
PMadden
MMendonca
CNagel
NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML041690561
TEMPLATE #: NRR-106
OFFICE
RNRP:RI
RNRP:LA
RNRP:SC
RNRP:PD
NAME
CBassett:vxj
EHylton:vxj
PMadden
JLyons
DATE
6/ /2004
6/ 24 /2004
6/ 24 /2004
6/ 25 /2004
C = COVER
E = COVER & ENCLOSURE
N = NO COPY
OFFICIAL RECORD COPY
ENCLOSURE 1
Washington State University
Docket No.50-027
Nuclear Radiation Center
License No. R-76
During an NRC inspection conducted on June 7-10, 2004, two violations of NRC requirements
were identified. In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," NUREG-1600, the violations are listed below:
A.
10 CFR Part 71.5(a) requires that each licensee, who delivers licensed material to a
carrier for transport, shall comply with the applicable requirements of the Department of
Transportation (DOT) regulations in 49 CFR Parts 170 through 189 appropriate to the
mode of transport.
49 CFR Part 172.203(d)(6) requires that the description for a shipment of a Class 7
(radioactive) material must include, on the shipping papers, the transport index assigned
to each package in the shipment bearing Radioactive Yellow II or Radioactive Yellow III
labels. (49 CFR 173.403 defines Transport Index [TI] as the dimensionless number
(rounded up to the next tenth) placed on the label of a package to designate the degree
of control to be exercised by the carrier during transportation.)
Contrary to the above, during the period from June 2002 to June 2004, no Transport
Index was listed on the shipping papers of 28 shipments of packages of radioactive
material bearing Yellow II labels made to various recipients.
This is a Severity Level IV violation (Supplement V).
B.
10 CFR Part 71.5(a) requires that each licensee, who delivers licensed material to a
carrier for transport, shall comply with the applicable requirements of the DOT
regulations in 49 CFR Parts 170 through 189 appropriate to the mode of transport.
49 CFR Part 172.403(b) specifies that the proper label to affix to a package of Class 7
(radioactive) material is based on the radiation level at the surface of the package and
the Transport Index (TI). Also, the label to be applied must be the highest category
required for any of the two determining conditions for the package. 49 CFR Part
172.403(c) requires that the category of label to be applied to radioactive material
packages be Radioactive Yellow II if the TI is greater than 0 but not more than 1, or if the
maximum radiation level at any point of the external surface is greater than 0.5 millirem
per hour (mrem/hr) but less than or equal to 50 mrem/hr. (Footnote 2 to Paragraph (c)
states that, if the measured TI is not greater than 0.05, the value may be considered to
be zero. Also, 49 CFR 173.403 defines TI as the dimensionless number (rounded up to
the next tenth) placed on the label of a package to designate the degree of control to be
exercised by the carrier during transportation. For nonfissile material packages, the
number is the maximum radiation level from the external surface of the package in
millirem per hour at one meter.)
Contrary to the above, during the period from June 2002 to June 2004, 12 shipments
were classified as White I instead of Yellow II even though the radiation levels measured
at one meter from the surface of the packages being shipped read 0.06 millirem per hour
or above, indicating a TI of 0.1 or greater, using the rounded up to the next tenth rule.
This resulted in packages being shipped without the proper label attached and without
the appropriate TI being designated.
-2-
This is a Severity Level IV violation (Supplement V).
Pursuant to the provisions of 10 CFR 2.201, Washington State University is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555-0001, with a copy to the responsible
inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for
each violation: (1) the reason for the violation, or, if contested, the basis for disputing the
violation or severity level, (2) the corrective steps that have been taken and the results achieved,
(3) the corrective steps that will be taken to avoid further violations, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or Demand for
Information may be issued as to why the license should not be modified, suspended, or revoked,
or why such other action as may be proper should not be taken. 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, U.S. 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 2.390(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.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated at Rockville, Maryland
this day of
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No:
50-027
License No:
R-76
Report No:
50-027/2004-201
Licensee:
Washington State University
Facility:
Nuclear Radiation Center
Location:
Pullman, WA
Dates:
June 7-10, 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
Washington State University
Nuclear Radiation Center
Report No.: 50-027/2004-201
The primary focus of this routine, announced inspection included onsite review of selected
aspects of the licensees Class II research reactor safety programs including: organizational
structure and staffing, design control and review and audit functions, procedures, radiation
protection, environmental protection, and transportation of radioactive materials since the last
NRC inspection of these areas. The licensees programs were acceptably directed toward the
protection of public health and safety, however, two apparent violations were noted in the area of
transportation.
Organizational Structure and Staffing
The organizational structure and responsibilities were consistent with Technical Specification
Section 6 requirements.
Review and Audit and Design Control Functions
The review and audit program was being conducted acceptably by the Reactor Safeguards
Committee.
The latest change completed by the licensee was reviewed using the criteria specified in 10 CFR 50.59, determined to be acceptable, and approved 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 licensees
procedural action levels and NRCs regulatory limits.
Radiation monitoring equipment was being maintained and calibrated as required.
Acceptable radiation protection training was being provided to staff personnel.
The Radiation Protection Program being implemented by the licensee satisfied regulatory
requirements.
-2-
Effluent and Environmental Monitoring
Effluent monitoring satisfied license and regulatory requirements.
Releases were within the specified regulatory and Technical Specification limits.
Transportation of Radioactive Materials
Two apparent violations were noted: failure to properly complete shipping papers and failure
to affix the proper labels to packages during the review of radioactive material shipments
made by the licensee.
REPORT DETAILS
Summary of Plant Status
Washington State Universitys one megawatt research and test reactor continued to be operated
in support of irradiation work for various organizations, operator training, surveillance, and
experiments involving Boron Neutron Capture Therapy (BNCT). During the inspection, the
reactor was started up, operated, and shut down as required and in accordance with applicable
procedures to support these ongoing activities.
1.
Organizational Structure and Staffing
a.
Inspection Scope (Inspection Procedure [IP] 69001)
The inspector reviewed the following regarding the licensees organization and staffing
to ensure that the requirements of Sections 6.1-6.3 of Technical Specifications (TS),
Amendment No. 18, dated April 26, 2002, were being met:
Washington State University (WSU) Nuclear Radiation Center organizational
structure and staffing
staff qualifications
management responsibilities
WSU Nuclear Radiation Center Administrative Procedure Number (No.) 1,
Responsibilities and Authority of Reactor Operating Staff, (not dated)
b.
Observations and Findings
The Nuclear Radiation Center organizational structure and the responsibilities of the
reactor staff had not changed since the last inspection. However staffing levels had
changed and licensed reactor staff consisted of the Director, Nuclear Radiation Center,
the Reactor Supervisor, and a Reactor Technician. All of these individuals were Senior
Reactor Operators (SROs). Another person, working at the facility, was also an SRO
but was actually funded by another program. Although the staff was of limited size, the
organizational structure and staffing at the facility were as required by TS.
Qualifications of the staff met TS requirements. Review of records verified that
management responsibilities were administered as required by TS and applicable
procedures.
c.
Conclusions
The organizational structure and functions were consistent with TS Section 6
requirements.
2.
Review and Audit and Design Control Functions
a.
Inspection Scope (IP 69001)
In order to verify that the licensee had established and conducted reviews and audits
as required in TS Sections 6.5.4 and 6.5.5 and to verify compliance with 10 CFR 50.59,
the inspector reviewed selected aspects of:
2
Reactor Safeguards Committee (RSC) meeting minutes for 2003 through 2004 to
date
RSC Facility Records Quarterly Audits for 2003 through 2004 to date documenting
reviews of operations records, summary records, and administrative records
safety review records for the past two years
responses to the safety reviews and audits
the most recent facility design change concerning upgrade of reactor power
monitoring channels
facility configuration
WSU Nuclear Radiation Center Administrative Procedure No. 3, Approval and
Review of Facility Modifications and Special Tests or Experiments, (not dated)
b.
Observations and Findings
(1)
Review and Audit Functions
The inspector verified that RSC membership satisfied TS requirements and that
the RSC had quarterly meetings as required. Review of the committee meeting
minutes indicated that the RSC provided appropriate guidance and direction for
reactor operations, and ensured suitable use and oversight of the reactor.
Since the last inspection all required audits of reactor facility activities and reviews
of programs, procedures, equipment changes, and proposed tests or experiments,
had been completed and documented. Additionally, the annual review of the
Radiation Protection Program and the biennial reviews of the emergency and
security plans had been conducted and acceptably documented.
(2)
Design Change
Records and observations showed that changes made during 2003 and to date at
the facility were acceptably reviewed in accordance with 10 CFR 50.59 and
applicable administrative controls. Prior to implementing the changes, the licensee
submitted them to the RSC and they were reviewed, determined to be acceptable,
and approved as required. None of the changes constituted a safety question or
required a change to the TS.
The latest modification completed since the last inspection involved replacing the
facility pendulum-style seismometer with a new three-axis digital seismometer.
The licensees facility modification procedure was followed and an evaluation was
completed as required. The licensee considered the criteria included in the
revised 10 CFR 50.59 and concluded that the change was an acceptable change
under the regulations. Although not required by procedure, a review by the RSC
was requested and conducted, and the RSC approved the change. The change,
review, and approval appeared to be acceptable.
c.
Conclusions
The review and audit program was being conducted acceptably by the Reactor
Safeguards Committee. The latest change completed by the licensee was reviewed
3
using the criteria specified in 10 CFR 50.59, determined to be acceptable, and
approved as required.
3.
Procedures
a.
Inspection Scope (IP 69001)
The inspector reviewed selected aspects of the following to verify that the licensee was
complying with the requirements of TS Sections 6.5.4 and 6.8:
records for procedure changes and temporary changes
observation of procedure implementation
related logs and records documenting procedure implementation
administrative controls as outlined in WSU Nuclear Radiation Center Administrative
Procedure No. 2, Approval, Revision, and Review of Standard Operating
Procedures, (not dated)
selected administrative and standard operating procedures
b.
Observations and Findings
Procedures were available for those tasks and items required by the TS and facility
directives. Written changes were reviewed and approved by the RSC as required. The
Standard Operating Procedures (SOPs) were reviewed biennially as required by TS Section 6.5.4 with the last review being completed December 2, 2003.
Training of personnel on procedures and the applicable changes was acceptable.
Through observation of reactor operations and experiment handling, the inspector
verified that personnel conducted TS activities in accordance with applicable
procedures. Records showed that procedures for potential malfunctions (e.g.,
radioactive releases, contaminations, and reactor equipment problems) had been
developed and were implemented as required.
c.
Conclusions
Procedural review, revision, control, and implementation satisfied TS requirements.
4.
Radiation Protection Program
a.
Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with 10 CFR Parts 19 and 20,
TS Sections 3.7, 5.4, and 6.8, and procedural requirements:
radiation and contamination survey records documented on the appropriate forms in
accordance with WSU Nuclear Radiation Center SOP No. 10
Nuclear Radiation Center dosimetry records for 2002 through the first three months
of 2004
calibration and periodic check records for radiation monitoring instruments
documented on the applicable forms
4
Preventative Maintenance Checklists for 2003 and 2004
Radiation Monitor Calibration Schedule Forms for 2003 and 2004
Radiac Calibration Forms for specific instruments
WSU Nuclear Radiation Center SOP No. 10, Standard Procedure for Health
Physics Surveys, last revised August 18, 1999
WSU Nuclear Radiation Center SOP No. 17, Standard Procedure for Checkout and
Calibration of the Area Radiation Monitors, last revised December 4, 2003
WSU Nuclear Radiation Center SOP No. 23, Standard Procedure for Portable
Survey Instrumentation Check and Calibration, last revised December 4, 2003
WSU Nuclear Radiation Center SOP No. 27, Standard Procedure for RM-14 Check
and Calibration, last revised December 4, 2003
WSU Nuclear Radiation Center Administrative Procedure, Radiation Protection
Program last reviewed August 2001
Washington State University Radiation Protection Program Manual dated March 15,
1994
ALARA Policy as outlined the Radiation Protection Program
The inspector also toured the facility to note any changes that may have been made
and observed the use of dosimetry and radiation monitoring equipment. Licensee
personnel were interviewed and radiological signs and postings were observed as well.
b.
Observations and Findings
(1)
Surveys
The inspector reviewed weekly general area radiation and contamination surveys
and semiannual neutron surveys of the Pool Room and the Beam Room from
2003 to date. The surveys had been completed by licensee personnel as required
by WSU Nuclear Radiation Center SOP No. 10. The results were documented on
the appropriate forms and evaluated as required, and corrective actions taken
when readings or results exceeded set action levels.
During the inspection, the inspector conducted a radiation survey of the Pool
Room, the Heat Exchanger/Pump Room, Radiochemistry Laboratory, and
Computer/Analyzer Room, 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 Pool Room, the Beam Room, and various
laboratories in the Nuclear Radiation Center. 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 on various bulletin
boards throughout the facility including one in the stairway leading to the Control
Room and one in the Conference Room as well.
5
(3)
Dosimetry
The licensee used a National Voluntary Laboratory Accreditation Program
accredited vendor (Landauer) to process the optically stimulated luminescense
(OSL) whole body dosimeters and extremity thermoluminescent dosimeters (TLDs)
supplied to staff personnel. Through direct observation, the inspector determined
that dosimetry was acceptably used by facility personnel and exit frisking practices
were in accordance with radiation protection requirements.
An examination of the records for the past two years, through March 2004, showed
that all whole body exposures were within NRC limits and within licensee action
levels. Extremity monitoring, accomplished through the use of finger ring TLDs,
also generally showed low doses to the hands of staff members. The highest
annual whole body exposure received by a single individual for 2002 was 56
millirem deep dose equivalent (DDE). The highest annual extremity exposure for
2002 was 70 millirem shallow dose equivalent (SDE). The highest annual whole
body exposure received by a single individual in 2003 was 78 millirem DDE. The
highest annual extremity exposure for 2003 was 310 millirem SDE.
(4)
Radiation Monitoring Equipment
The calibration of portable survey meters, friskers, fixed radiation detectors, and
air monitoring instruments were typically completed by licensee personnel. The
calibration records of selected portable survey meters, friskers, fixed radiation
detectors, and air monitoring equipment in use at the facility were reviewed.
Calibrations were completed according to the procedure given in the
manufacturers technical manual using NIST traceable calibration sources.
Calibration frequency met the requirements established in the applicable manuals
and records were being maintained as required.
(5)
Radiation Protection Program
The licensees Radiation Protection Program was established in the WSU Nuclear
Radiation Center Administrative Procedure of the same name dated August 2001.
The program was further explained in the campus document entitled, WSU
Radiation Protection Program Manual, dated March 15, 1994. 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. As noted previously, the
program was being reviewed annually as required.
(6)
ALARA Policy
The ALARA Policy was also outlined and established in the WSU Nuclear
Radiation Center Administrative Procedure, Radiation Protection Program. The
ALARA program provided guidance for keeping doses as low as reasonably
achievable and was consistent with the guidance in 10 CFR Part 20.
6
(7) Radiation Protection Training
The inspector reviewed documentation of the training given to new employees by
the WSU Radiation Safety Office entitled, Radiation Safety Course. The content
of the course given was acceptable and the training program generally satisfied
requirements in 10 CFR 19.12.
(8)
Facility Tours
The inspector toured the Control Room, Pool Room, Heat Exhanger/Pump Room,
Beam Room, and 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
The inspector determined that the Radiation Protection Program being implemented by
the licensee satisfied regulatory 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) acceptable radiation protection training was being
provided.
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 3.7-3.9, 3.12, 5.6, and 6.10:
airborne release records documented in the Average Monthly Concentration of Ar-41
Released section of the Reactor Operations Summary Log for the period from 2002
to the present
liquid release records also documented in the Reactor Operations Summary Log
and calculated on the appropriate forms in the Liquid Waste Tank Release Data Log
for the period from 2002 to date in 2004
Radiation Monitor Calibration Schedule Forms for 2003 and 2004
licensee Annual Reports for reporting periods: July 2001 - June 2002, and July 2002
- June 2003
WSU Nuclear Radiation Center SOP No. 11, Standard Procedure for Analysis of
Liquid Waste Samples, last revised December 4, 2003
WSU Nuclear Radiation Center SOP No. 18, Standard Procedure for Ar-41 Monitor
Checkout and Calibration, last revised December 4, 2003
WSU Nuclear Radiation Center SOP No. 21, Standard Procedure for Environmental
Monitoring, last revised December 4, 2003
WSU Nuclear Radiation Center SOP No. 22, Standard Procedure for TLD
Environmental Monitoring Program, last revised December 4, 2003
7
WSU Nuclear Radiation Center SOP No. 26, Standard Procedure for Continuous
Air Monitor Check and Calibration, last revised December 4, 2003
WSU Nuclear Radiation Center SOP No. 29, Standard Procedure for Continuous
Air Monitor Filter Analysis, last revised December 4, 2003
b.
Observation and Findings
The inspector reviewed the calibration records of the area and stack monitoring
systems. These systems had been calibrated annually according to procedure. The
weekly setpoint verification records for the monitoring equipment were also reviewed.
Corrective actions, including recalibration, were completed if the setpoint values were
exceeded.
The inspector also reviewed the records documenting liquid and airborne releases to
the environment for the past two years. The inspector determined that gaseous
release activity continued to be calculated as required by procedure and the results
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. Liquid release activity was calculated as required and releases were
approved by the Reactor Supervisor or an SRO after analyses indicated that the they
met regulatory requirements for discharge into the sanitary sewer.
On-site and off-site gamma radiation monitoring was completed using environmental
TLDs in accordance with the applicable procedures. The data indicated that there were
no measurable doses above any regulatory limits. These results and those above were
acceptably reported in the Reactor Operations Annual Report for 2002 and 2003.
Through observation of the facility, the inspector did not identify any new potential
release paths.
c.
Conclusions
Effluent monitoring satisfied license 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 shipments for June 2002 and to date in 2004
WSU Nuclear Radiation Center SOP No. 33, Standard Procedure for Off-Site
Shipment of Radioactive Material, last revised October 30, 1995
WSU Nuclear Radiation Center SOP No. 35, Standard Procedure for Receiving and
Opening Packages Containing Licensed Materials, last revised December 4, 2003
8
b.
Observations and Findings
(1) General Shipping Results
Through records review and discussions with licensee personnel, the inspector
determined that the licensee had shipped various types of radioactive material
since the previous inspection in this area. The records indicated that the
radioisotope types and quantities were calculated and dose rates measured as
required. All radioactive material shipment records reviewed by the inspector had
been completed in accordance with Department of Transportation and NRC
requirements except as noted in the two paragraphs below.
(2) Licensee-Generated Shipping Papers
10 CFR Part 71.5(a) requires that each licensee, who delivers licensed material to
a carrier for transport, shall comply with the applicable requirements of the
Department of Transportation (DOT) regulations in 49 CFR Parts 170 through 189
appropriate to the mode of transport.
49 CFR Part 172.203(d)(6) requires that the description for a shipment of a Class
7 (radioactive) material must include, on the shipping papers, the transport index
assigned to each package in the shipment bearing Radioactive Yellow II or
Radioactive Yellow III labels. (49 CFR 173.403 defines Transport Index [TI] as the
dimensionless number [rounded up to the next tenth] placed on the label of a
package to designate the degree of control to be exercised by the carrier during
transportation.)
In reviewing the shipping papers prepared by the licensee for the period from June
2002 to the present, the inspector noted certain discrepancies with the shipping
papers prepared for various shipments of packaged radioactive material labeled as
Radioactive Yellow II. On various occasions, when the licensee had prepared
shipping papers for specific individuals and had not used a common carrier, such
as FedEx for example, the shipping papers did not contain all the required
information. (In those instances when a common carrier was used, the licensee
generated additional shipping papers, usually as required by the carrier.) When
the licensee used only the internally generated documents as the formal shipping
papers used to accompany the shipment, no TI was listed. A one meter radiation
level reading, listed in millirem per hour (mrem/hr), was entered on the shipping
papers but nothing was listed indicating the TI and no dimensionless number was
given.
The following instances were noted. The shipping papers documenting shipments
of radioactive material labeled as Yellow II to R. Donelick did not include a TI for
shipments made on: June 4, 2002, September 26, 2002, December 11, 2002,
January 15 and 21, 2003, February 10, 2003, March 20, 2003, April 16 and 24,
2003, May 1, 2003, June 12, 2003, December 18 and 22, 2003, January 16, 2004,
March 18, 2004, April 13, 15, and 20, 2004, May 17, 2004, and June 10, 2004.
The shipping papers documenting shipments of radioactive material labeled as
Yellow II to Kiddy and/or Cartwright did not include a TI for shipments made on:
December 18, 2002, January 2, 17, and 30, 2003, and March 4 and 11, 2003. The
9
shipping papers documenting a shipment of radioactive material labeled as Yellow
II to C. W. Thomas did not include a TI for the shipment made on December 23,
2002. The shipping papers documenting a shipment of radioactive material
labeled as Yellow II to J. Kimerling did not include a TI for the shipment made on
March 12, 2004.
The licensee was informed that failure include the applicable TI on the shipping
papers involving shipments of radioactive material labeled as Yellow II was an
apparent violation of 49 CFR 172.203(d)(6) (VIO 50-027/2004-201-01).
(3) White I versus Yellow II Designated Shipments
10 CFR Part 71.5(a) requires that each licensee, who delivers licensed material to
a carrier for transport, shall comply with the applicable requirements of the DOT
regulations in 49 CFR Parts 170 through 189 appropriate to the mode of transport.
49 CFR Part 172.403(b) specifies that the proper label to affix to a package of
Class 7 (radioactive) material is based on the radiation level at the surface of the
package and the TI. Also, the label to be applied must be the highest category
required for any of the two determining conditions for the package. 49 CFR Part
172.403(c) requires that the category of label to be applied to radioactive material
packages be Radioactive Yellow II if the TI is greater than 0 but not more than 1,
or if the maximum radiation level at any point of the external surface is greater
than 0.5 mrem/hr but less than or equal to 50 mrem/hr. Footnote 2 to Paragraph
(c) states that, if the measured TI is not greater than 0.05, the value may be
considered to be zero. Also, 49 CFR 173.403 defines TI as the dimensionless
number [rounded up to the next tenth] placed on the label of a package to
designate the degree of control to be exercised by the carrier during
transportation. For nonfissile material packages, the number is the maximum
radiation level from the external surface of the package in millirem per hour at one
meter.
In reviewing the shipping papers prepared by the licensee for the period from June
2002 to the present, the inspector also noted various discrepancies when certain
packages of radioactive material were shipped and a White I label was applied to
the package. On various occasions radiation readings, taken one meter from the
external surface of the radioactive material package being shipped, yielded results
of 0.06 mrem/hr or greater. This would have yielded a TI of 0.1, using the
rounded up to the next tenth rule stated in 49 CFR 173.403 and with a TI of 0.1
or greater a Yellow II label for the package as stipulated by 49 CFR 172.403 would
be required .
The following discrepancies were noted. On September 10, 2002, a package, with
a maximum radiation level of 0.06 mrem/hr one meter from the external surface of
the package, was shipped as White I. On November 4, 2002, a package, with a
maximum radiation level of 0.06 mrem/hr one meter from the external surface of
the package, was shipped as White I. On December 5, 2002, a package, with a
maximum radiation level of 0.06 mrem/hr one meter from the external surface of
the package, was shipped as White I. On January 7, 2003, a package, with a
maximum radiation level of 0.06 mrem/hr one meter from the external surface of
10
the package, was shipped as White I. On January 13, 2003, a package, with a
maximum radiation level of 0.1 mrem/hr one meter from the external surface of the
package, was shipped as White I. On January 15, 2003, a package, with a
maximum radiation level of 0.08 mrem/hr one meter from the external surface of
the package, was shipped as White I. On January 28, 2003, a package, with a
maximum radiation level of 0.2 mrem/hr one meter from the external surface of the
package, was shipped as White I. On July 30, 2003, a package, with a maximum
radiation level of 0.08 mrem/hr one meter from the external surface of the
package, was shipped as White I. On October 7, 2003, a package, with a
maximum radiation level of 0.08 mrem/hr one meter from the external surface of
the package, was shipped as White I. On October 17, 2003, a package, with a
maximum radiation level of 0.06 mrem/hr one meter from the external surface of
the package, was shipped as White I. On October 24, 2003, a package, with a
maximum radiation level of 0.07 mrem/hr one meter from the external surface of
the package, was shipped as White I. On March 9, 2004, a package, with a
maximum radiation level of 0.06 mrem/hr one meter from the external surface of
the package, was shipped as White I. As indicated above, in each instance,
except for the shipment on January 28, 2003, this would have yielded a TI of 0.1,
using the rounded up to the next tenth rule. The shipment on January 28, 2003,
would require a TI of 0.2. Also, a TI of 0.1 or greater would then require a Yellow
II label for the package as stipulated by 49 CFR 172.403. Therefore, the
packages listed above were shipped without the proper label attached and without
the appropriate TI being designated.
The licensee was informed that failure to assign the appropriate Transport Index to
packages of radioactive material with radiation level readings of 0.06 mrem/hr or
greater at 1 meter and failure to designate the shipments as Yellow II and to affix
the proper label to packages of radioactive material based on the TI (which was
the highest category required) was an apparent violation of 49 CFR 172.403(b)
(VIO 50-027/2004-201-02).
c.
Conclusions
Two apparent violations were noted during the review of radioactive material shipments
made by the licensee for failure to properly complete shipping papers by not listing the
appropriate TI and failure to assign the appropriate TI and affix the proper labels to
packages.
7.
Follow-up on Previously Identified Issues
a.
Inspection Scope
The inspector reviewed the actions taken by the licensee following identification of an
Inspector Follow-up Item, two violations, and a deviation during previous inspections in
May of 2002 and May of 2003, and documented in NRC Inspection Report Nos. 50-
027/2002-201 and 50-027/2003-201, dated May 30, 2002, and May 29, 2003,
respectively.
11
b.
Observations and Findings
(1) IFI 50-027/2002-201-02 - Follow-up on the clarification of the last step in the
Reactor Startup Checkout.
During a previous inspection, the inspector had reviewed a report sent to the NRC
by the licensee. The report detailed a licensee-identified monitoring failure that
occurred during the month of June 2000. Due to a personnel error, monthly
monitoring of the reactor pool water was not performed in June. The oversight
was detected July 31, 2000, at which time a pool water sample was obtained and
analyzed. The water sample showed no abnormal radionuclide levels. One of the
licensees corrective actions was to add an item to the Reactor Startup Checkout
to ensure that all operations, i.e., all required surveillances, are completed before
reactor operation. During a subsequent inspection it was noted that an item had
been added to the Checkout sheet but it was unclear as to what it directed the
operators to do.
The inspector again reviewed this issue during this inspection and found that the
licensee had clarified the step in the checkout. NRC Form No. 34, WSU Reactor
Start-Up Checkoff, last revised August 5, 2003, had been revised in Section
X.D.1, entitled, Surveillance, to required that all appropriate maintenance was
complete prior to reactor start-up. This clarified the meaning of this step in the
checkout. This issue is considered closed.
(2) VIO 50-027/2003-201-01 - Failure to conduct training for Pullman Memorial
Hospital emergency room personnel in radiation safety and WSU Nuclear
Radiation Center emergency procedures as required by the Emergency Plan.
During an inspection in May 2003, it was noted that during 2001, 2002, and until
May 2003, no training had been provided for Pullman Memorial Hospital
emergency room personnel in radiation safety and WSU Nuclear Radiation Center
emergency procedures as required.
During this inspection, the inspector verified that training had subsequently been
provided to hospital emergency room personnel. It was also noted that, just prior
to the most recent drill, held June 4, 2004, the licensee conducted training for
hospital and ambulance personnel so that the lessons being taught would be
reinforced during conduct of the drill. This issue is considered closed.
(3) VIO 50-027/2003-201-02 - Failure to provide the hospital with a copy of the WSU
Nuclear Radiation Center Emergency Plan and the associated implementing
procedures and failure to conduct annual drill exercises with the Pullman Memorial
Hospital.
During the inspection in May 2003, the inspection found that the Pullman Memorial
Hospital did not have a copy of the WSU Nuclear Radiation Center Emergency
Plan as required by the agreement between WSU and the hospital. It was also
noted that, although annual drills were required to be held, none had been held
during 2001, 2002, and as of May 2003.
12
During this inspection, the inspector verified that the licensee had provided a copy
of the WSU Nuclear Radiation Center Emergency Plan to the hospital emergency
room in June 2003. The inspector reviewed the form that a hospital representative
had signed indicating that the hospital had received a copy on June 13, 2003.
Also, the inspector verified that the licensee had held a drill with the hospital in July
2003. The drill involved handling and treatment of a simulated contaminated,
injured person from the Nuclear Radiation Center by ambulance and hospital
personnel. It was also noted that another drill was held on June 4, 2004. This
most recent drill again involved licensee staff, hospital emergency room personnel,
and the ambulance drivers. This item is considered closed.
(4) DEV 50-027/2003-201-03 - Failure to fulfill a commitment made to the NRC
concerning revision of the Emergency Plan to reflect actual training practices.
During the inspection in May 2003, the inspector reviewed the issue of revising the
Emergency Plan (E-Plan) to reflect actual training practices involving support
organizations. No revision had been completed as of the date of the inspection
despite a commitment made to the NRC to implement a revision to the E-Plan.
The inspector noted that, following that inspection, the licensee issued a pen and
ink change to reflect that the training was on a rotating basis, each organization
trained every third year. The licensee later submitted a letter to the NRC outlining
the change on June 23, 2003. By letter dated November 20, 2003, the NRC
indicated that the change was acceptable. This item is considered closed.
c.
Conclusions
The licensee had taken action to resolve previously identified issues involving an
Inspector Follow-up Item, 2 violations, and a deviation. The items were closed.
8.
Exit Interview
The inspection scope and results were summarized on June 10, 2004, with members of
licensee management. The inspector described the areas inspected and discussed in detail
the inspection findings. No dissenting comments were received from the licensee.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
E. Corwin
Senior Reactor Operator
K. Fox
BNCT Project Manager, Security Manager, and Emergency Director
S. Sharp
Reactor Supervisor
J. Smeltz
Reactor Operator Trainee
G. Tripard
Director, Nuclear Radiation Center
Other Personnel
M. Blair
Locksmith, WSU Facilities Operations
D. Hagihara
Chair, Reactor Safeguards Committee
L. Porter
Director, WSU Radiation Safety Office
S. West
Lieutenant, WSU Police Department
INSPECTION PROCEDURES USED
Class II Research and Test Reactors
Plans, Procedures, and Reviews
Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-027/2004-201-01
Failure to include the applicable TI on the shipping papers of
shipments of radioactive material packages labeled as Yellow II.
50-027/2004-201-02
Failure to assign the appropriate Transport Index to packages of
radioactive material with radiation level readings of 0.06 mrem/hr
or greater at 1 meter and failure to designate the shipments as
Yellow II and to affix the proper label to packages of radioactive
material based on the TI (which was the highest category
required).
Closed
50-027/2002-201-02
IFI
Follow-up on the clarification of the last step in the Reactor Startup
Checkout.
50-027/2003-201-01
Failure to conduct training for Pullman Memorial Hospital
emergency room personnel in radiation safety and WSU Nuclear
Radiation Center emergency procedures as required by the
-2-
50-027/2003-201-02
Failure to provide the hospital with a copy of the WSU Nuclear
Radiation Center Emergency Plan and the associated
implementing procedures and failure to conduct annual drill
exercises with the Pullman Memorial Hospital.
50-027/2003-201-03
DEV
Failure to fulfill a commitment made to the NRC concerning
revision of the Emergency Plan to reflect actual training practices.
PARTIAL LIST OF ACRONYMS USED
As Low As Reasonably Achievable
BNCT
Boron Neutron Capture Therapy
CFR
Code of Federal Regulations
DEV
Deviation
IFI
Inspector Follow-up Item
IP
Inspection Procedure
mrem/hr
millirem per hour
NRC
Nuclear Regulatory Commission
Optically stimulated luminescence (dosimeter)
Reactor Safeguards Committee
Shallow dose equivalent
Standard Operating Procedure
Senior Reactor Operator
Thermoluminescent dosimeter
TS
Technical Specifications
Violation
WSU
Washington State University