ML20023D834
| ML20023D834 | |
| Person / Time | |
|---|---|
| Site: | 05000148 |
| Issue date: | 04/19/1983 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Barnes C AFFILIATION NOT ASSIGNED |
| References | |
| FOIA-83-126 NUDOCS 8306030448 | |
| Download: ML20023D834 (1) | |
See also: IR 05000148/1983001
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NUCLEAR REGULATORY COMMISSION
W ASWNG TON, D. C. 20555
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April 19, 1983
Mr. Charles Barnes
Box 1255
IN RESPONSE P.EFER
Lawrence, KS 66044
TO FOIA-83-126
Dear Mr. Barnes:
This is in further response to your letter dated March 8,1983, in which
you requested, pursuant to the Freedom of Information Act, three documents
identified in your letter which related to the University of KLnsas
Research Reactor.
Please find enclosed the following document which is responsive to your
request.
March 24, 1983 - Letter to Dr. David Kraft, University of Kansas
from G. L. Madsen, NRC, attaching Notice of Violation and NRC
Inspection Report 50-148/83-01
This completes NRC's action on your request.
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Sincprely,
. M. Felton, Director
tvision of Rules and Records
Office of Administration
Enclosure: As stated
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8306030448 830419
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March 8,
1983
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Request is being made for AEC/NRC documents under the provisions of
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the Freedom of Information Act, 5 U.S.C. 552.
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FREEDOM OF INFORMATION
}
ACT REQUEST
Freedom of Information Act Request
FCU A -/3 -/;L6
Mr. J .M. Felton
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Director, Division of Rules and Recerds
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Of fice of Administration
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U.S. Nuclear Regulatory Coacnission
The NRC or Literature Research Company will be reimbursed $.05 per page
for duplicating expenses in addition to postage costs.
Reference:
Docket 50-148 Univ. of Kansas Research Reactor. License R-78.
Documents requested include:
Ltr 12-06-73 fm Univ. of Kan, re AEC 11-6-73
ltr & trans following:
Replies to a series
//* ' of Ques, contained in a ltr to Dr. W.P. Smith,
dtd 11-6-73. Date Docketed-Dec 10, 1973.
-8205020362 Submits annual operating report
pg(
- for July 1981-June 1982
Mesler, R.B. Kansas
f
University of.
820723. 2pp 14150;130
January 1983 Inspection Report re Univ. of
/ Kansas Research Reactor.
,
Sincerely,
cu
o
Charles Barnes
Box 1255
Lawrence, Kansas 66044
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MAR 2 41933
In Reply Refer To:
Dacket:
50-148/83-01
University of Kansas
ATTN:
Dr. David Kraft, Dean
School of Engineering
Lawrence, Kansas
66044
Gentlecen:
This refers to the inspection conducted by Mr. G. L. Plumlee III of this
office on February 28 - March 3,1983, of activities authorized by NRC Oper-
ating Liccase R-78 for the Bendix Pool Reactor at the University of Kansas
and to the discussion of our findings held with Dr. Russell B. Mesler of
your sta'ff at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the
enclosed inspection report. Within these areas, the inspection consisted
of selective examination of procedures and representative records, interviews
with personnel, and observations by the inspector.
During this inspection, it was found that certain of your activities were
not conducted in full co:rpliance with NRC requiremnts.
Consequently, you
are required to respond to this catter, in writing, in accordance with the
provisions of Section 2.201 of the NRC's " Rules of practice," Part 2,
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Title 10, Code of Federal Regulations. Your response shall be based on the
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specifics contained in the Notice of Violation attached to this letter.
In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of
this letter and the enclosed inspection report will be placed in the NRC's
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Public Document Room.
If this report contains any infomation that you
believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary
that you (a) notify this office by telephone within 10 days from the date of
this letter of your intention to file a request for withholding; and (b) submit
within 25 days from the date of this letter a written application to this
office to withhold such infomation.
If your receipt of this letter has
been delayed such that less than 7 days are available for your review,
please notify this office promptly so that a new due date may be established.
Consistent with Section 2.790(b)(1), any such application cast be accompanied
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by an affidavit executed by the owner of the infomation which identifies the
docuant or part sought to be withheld, and which contains a full statement of
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the reasons on the basis which it is claimed that the infomation should be
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withheld from public disclosure. This section further requires the statement
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MAR 2 41933
bniversityofKansas
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to address with specificity the conderations listed in 10 CFR 2.790(b)(4).
The infonnation sought to be withheld shall be incorporated as far as
possible into a separate part of the affidavit.
If we do not hear from you
in this regard within the specified periods noted above, the report will be
placed in the Public Document Room.
The responses directed by this letter and the acco:apanying Notice are not
subject to the clearance procedures of the Office of Management and Budget
as required by the paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
Oric!nal Signeg gy,
G L. MAoscu,
G. L. Madsen, Chief
Project Reactor Branch 1
Enclosures:
1.
Appendix A - Notice of Violation
2.
Appen' dix B - NRC Inspection Report 50-148/83-01
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APPENDIX A
University of Kansas
Docket:
50-148/83-01
License:
R-78
Based on the results of an NRC inspection conducted during the period of
February 28 - March 3, 1983, and in accordance with the NRC Enforcement
Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9, 1982, the
following violation was identified:
Technical Specification J.4 states, in part, that, "The University of
Kansas Committee on Radiation Sources . . . shall be composed as follows:
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"c.
a nuclear engineer, most reasonably the faculty reactor supervisor,
Contrary to the above, on March 2, 1983, the NRC inspector determined
that the Committee on Radiation Sources membership did not contain a
nuclear engineer.
A
This is a Severity Level V Violation.
(Supplement I.E.) (50-148/8301-01)
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Pursuant to the provisions of 10 CFR Part 2.201, University of Kansas is
hereby required to submit to this office within 30 days of the date of this
Notice, a written statement or explanation in reply, including:
(1) the
corrective steps which have been taken and the results achieved; (2) corrective
steps which will be taken to avoid further violations; and (3) the date when
full compliance will be achieved.
Consideration may be given to extending
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your response time for-good cause shown.
MAR 2 41983
Dated:
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APPENDIX B
U. S. NUCLEAR REGULATORY C0tiMISSION
REGION IV
Report:
50-148/83-01
License:
R-78
Docket:
50-148
Category:
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Licensee:
University of Kansas
P. O. Box 2067
Lawrence, Kansas
66044
Facility Name:
University of Kansas, Bendix Pool Reactor
Inspection at:
Univeristy of Kansas, Lawrence, Kansas
Inspection Conducted:
February 28 - March 3, 1983
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Inspector:
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G. L. Plumlee III, Reactor Inspector
_Date
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Approved:
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T. F. Westerman, Chief
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Reactor Project Section A
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Inspection Summary
Inspection on February 28 - March 3, 1983 (Report:
50-148/83-01)
Areas Inspected:
Routine, unannounced inspection of Organization, Logs and
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Records; Review and Audit; Requalification Training; Surveillance; Experiments;
Environmental Protection; Emergency Plan; Radiation Control; Licensee Action
on Previous Inspection Findings; and Follow Up, IE Circular, and Information
Bulletin.
The inspection involved 27 inspector-hours onsite by one
NRC inspector.
Results: Within the ten areas inspected, one violation was identified
TFailure to adhere to Technical Specification, Appendix B, paragraph 3).
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DETAILS
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PersobsContacted
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B. Fries'en, Radiation. Safety Officer
M. Lemon, Radiation Safety Technician
- R. Mesler, Reactor Supervisor.
H. F.'Rosson, Senior Rentor Operator
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H. Woody,,' Reactor Operatorf
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Licensee Action on Previcus initoection Finilin s y 3,'.
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(Closed) 'liolation (8201-01): Calibration Proceduke%'ot Akroki bj
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Nuclear Reactor Comittee.
The Nucle'ar Reactor Cois
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report on the calibration of the Jordan Area {brj" tors {tt'ee aob
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(Closed) Violation (8201-02):
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Failure to FollLw Prdt.edo,r,es.
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licensee iciterated access requirements to the heulekedp'$hg staff. ( i ' , w
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Organization, Logs on Records.
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The NRC inspector reviewed the following logs and records to verifyt
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cc.npliance' with Technical Specification requirements and identify
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Operations log and associated startup checksheets for the period
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Janua ry 12, 1982, to Decer.ber 13, 1982 (last entry).
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Maintenance logs for the, period January 12, 1982, to February 23, 1983
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to June 30, 1982.
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The logs and the annual report'appearito' be complete and to represent an
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accurate history of the facility's ope' ration.
Reactor startups were \\
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conducted for requalification training, absorber n.aterial irradiations,
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demonstrations, and testing / calibrations.
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During a.verifica
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March 2, 1983, th, tion of the facilities operating organization on
e'NRC inspector determined that the licensee's
Committee on Radiation Sources was not composed of the required
membership.
Techn'ical? Specification, Section J.4, states, in part,
3;
that, " . . . The Co mittee shall be composed as follows:
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asciehtistpithtrainingandexperiencewiththechemical
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manipulation of radioactive materials,
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'ascie'nt8st,with4trainingandexperienceinnuclearphysics
"b.
and inJthe egof generators of high energy radiation
(other .than nuclear reactors),
"c.
a nuclea,r engineer, most reasonably the faculty reactor
supervisor,
"d.
a scientist with training and experience in the radiation
effects and tracer metabolism in biological organisms,
"e.
a Radiation Safety Officer or health physicist, who is
a member of the Radiation Safety Service,
"f.
a representative of the Student Heal'th Service, unless
the Radiation Safety Officer is also an official represen-
tative of the Student Health Service."
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HoAever, thedicensee's procedure, " Policies and Procedures Governing
the use of , Radiation Sources," approved January 1, 1980, stated that
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the Connittee 'on Radiation Sources shall consist of:
"1)l'Two scientists with training and experience with the chemical
, manipulation of radioactive material.
"2)
A scientist with training and experience in nuclear or
<adiation physics and in the use of generators of high
energy radiation.
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"3)
A scientist with training and experience in the radiation
effects and tracer metabolism in biological organisms.
"4)
A Radiation Safety Officer who is a member of the Radiation
Safety Service.
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A representative of the Student Health Services, utiless the
Radiation Safety Officer is also an official representative
of the Student Health Service."
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The committee membership was confirmed by discussicns with the licensee
verifying that Professor Benjamin S. Friesen is the r'adiation safety
officer on the committee and from the review of a-letter dated January 18,
1983, to the_ Kansas State Department of Health and Environment from
Professor Friesen stating that the membership for the Committee on
Radiations Sources has been changed to the following:
" Professor Francis Prosser, Chairman
(Scientist with training and experience in nuclear or radiation
physics)
Professor Donald Robertson, Microbiology
Professor Robert Sanders, Biochemistry
Professor Peter Hierl, Chemistry
(Three scientists with experience in chemical manipulations,
radiation effects, and tracer metabolism), and
Dr. Dennis Dahl, M.D.
(a representative of the Student Health Service)"
The licensee was informed that the failure to have a nuclear engineer
as a member of the Committee on Radiation Sources is a violation (8301-01)
of Technical Specification requirements.
The NRC inspector had no further questions in this area.
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4.
Review and Audit
The NRC inspector reviewed the Nuclear Reactor Committee minutes for
March 4,1982, May 4,1982, September 28, 1982, and December 7, 1982;
and the facility annual audit dated June -16,1982.
It appears that
the Nuclear Reactor Committee met quarterly with a quorum present as
required by the Technical Specifications.
The NRC inspector did determine that the annual audit dated June 16, 1982,
was performed utilizing the March 1980, Technical Specification to
verify conformance of facility operations to the Technical Specification
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and applicable license or charter conditions.
This Technical Specifi-
cation was submitted to the NRC on March 4,1980, as part of the licensee's
application for licensee renewal.
It should be noted that this licensee
renewal has not been reviewed / approved by the NRC as of this date.
This was discussed with the licensee who is very concerned over the
apparent delay in the NRC's research reactor licensee renewal process.
The licensee also insured the NRC inspector that the appropriate
Technical Specification would be utilized until approval of the March 1980,
submittal by the Office of Nuclear Reactor Regulation.
No violations or deviations were identified.
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5.
Research Reactor Requalification Training
The NRC inspector determined that all currently licensed operators are
satisfactorily participating in the requalification program. The biannual
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written examination was. administered, as required, by H. O. Woody on
December 15, 1981.
Annual evaluations for all'cperators were documented
on December 13, 1982, and. the annual review of the emergency procedure
was conducted and documented, as required, The NRC inspector also
verified license renewal . applications for operator license with expira-
tion dates of January 1983 and September 1982 for R. B. Mesler and
H. F. Rosson, respectively.
No violations or-deviations were identified.
6.
-Procedures
The NRC inspector reviewed the Technical Specification, operating
procedures and administrative guidance to verify the following:
The responsibilities of operators and senior operators regarding
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adherence to procedures are clearly established in writing.
Methods of changing or deviating from procedures, both temporary
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and permanent, including approvals and levels of subsequent review,
are clearly established.
The level of review and approval of new and 'substantially changed
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procedures is clearly established.
Operating procedures are technically adequate and meet Technical
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Specification requirements.
Procedures in use have been approved as required.
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From this review, the NRC inspector determined that there appeared to
be sufficient procedures to meet the license requirements and that they
were adequate considering the level of use of this facility.
No violations or deviations were identified.
7.
Surveillance
The NRC inspector verified that all surveillance activities were conducted
at the required frequency and provided acceptable results. All Technical
Specification design criteria, limiting conditions for operation, and
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limiting safety system settings appear to have been met.
The following
procedures were selected for technical review:
Log Count Rate Meter with Period Amplifier Test
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Safety Amplifier Test
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Log N Amplifier Test
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Rod Drop Test
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The NRC inspector witnessed performance of the rod drop test for Control
Rod Drive #2.
The NRC inspector verified that the drop time stored
on the licensee's Type 564 Storage Oscilloscope was approximately
560 milliseconds. (limit is 1 second maximum).
During a walk through of the log count rate meter (LCRM) calibration
and/or test as required by the Technical Specification, the licensee
informed the NRC inspector that this test consisted of manually adjusting
the discriminator and gain of this instrumentation to obtain a greater
than two counts per second signal thus, allowing rod withdrawal for
startups.
From a review of the manufacturer's manual titled, "Ortec 452
Spectroscopy Amplifier," the NRC inspector determined that the manual
provided procedures for a pulser test and a calibration of the test
pulser.
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The NRC inspector's findings and concerns were discussed with the licensee.
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The licensee was informed of the NRC inspector's concern as to whether
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or not the licensee's present method of testing the LCRM was appropriate
to ensure that the LCRM was indeed measuring an accurate output from a
startup scurce.
The licensee was informed that this is considered an unresolved
item (8301-02) pending the licensee's verification from the manufacturer
and/or vendor of the appropriate calibration and/or testing to be
performed as required by Technical Specifications for the LCRM at
least semiannually.
The NRC inspector had no further questions b this area.
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Experiments
t
The NRC inspector reviewed the irradiation record and order forms
,
from December 29, 1981, to December 13, 1982 (last entry).
Irradiations
were performed on cobalt and indium foils, polyethylene vials of NaH PO ,
3 4
Each
NH CL, H O and blood serium, and an aluminum container of NagCO)s.
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irradiation was reviewed and approved according to the facility
experiments control procedure.
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The NRC inspector verified that these experiments were performed
utilizing the facility's pneumatic beam port negating any reactivity
effect.
No violations or deviations were identified.
9.
Environmental Protection
The NRC inspector verified that the licensee's methods of effluent
monitoring are adequately measured and that records required by
Technical Specifications are complete and adequate.
The following
records were reviewed for the period July 1981 to February 1983:
Annual Report Dated July 23, 1982
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Water Sampling Data sheets
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Air Sampling Data Sheets
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The NRC inspector also verified that all potential radioactive liquid
discharge paths contained a locked shut discharge valve, thus minimizing
the possibility of an unmonitored/ unauthorized release of radioactive
material.
During the above record review, the NRC inspector determined that the
amounts of activity released to both the sanitary sewer system and to
the atmosphere reported for the period of July 1,1981, to June 30, 1982,
,
in the-licensee's annual report, did not agree with the amounts
calculated by the NRC inspector from the licensee's records.
The
NRC inspector also determined that the report submitted to the reactor
supervisor from the Radiation Safety Service dated August 9,1982,
providing the nature and amounts of radioactive material released to
the environs during the report period did not agree with what the
licensee submitted.
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This was discussed with the licensee and the licensee assured the
NRC inspector that the incorrect information reported to the NRC was
not done so intentionally.
From discussions with the reactor supervisor,
who submitted the annual report, no determination could be made as to
where the values that were submitted came from.
The NRC inspector advised the licensee as to the necessity of submitting
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accurate reports and the consequences of submitting falsified records.
The licensee stated that an amendment to the annual report dated July 23,
1982, would be forwarded to the Division of Reactor Licensing incorporating
the correct amounts of radioactive material released to the environs
during the report period.
The NRC inspector had no further questions in this area.
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10.
Emeroency Plan
The NRC inspector reviewed the licensee's new emergency plan that
was submitted November 3,1982, as required by 10 CFR 50, and is presently
under review by the Office of Nuclear Reactor Regula~ tion (NRR).
This
plan currently has only been partially implemented.
The licensee
stated that they are actively working towards full implementation
capability by the end of )une 1983.
The NRC inspector's evaluation _of this emergency plan indicated the
following:
A general lack of knowledge exists amoung the facility personnel
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as to the plans content.
The licensee does not presently have the capability to impleme.nt
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this plan completely.
The licensee utilized NUREG 0849 and ANSI /ANS-15.16 - 1982 as
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guidance in an attempt to comply with 10 CFR Part 50, Appendix E
requirements.
The NRC inspector did determine that the licensee had documented and
evaluated as satisfactory an unanounced emergency building evacuation
that occurred on October 11, 1982, at 8:33 a.m. CST, and was accomplished
in 30 seconds.
The NRC inspector has recommended to NRC Region IV that a followup
inspection in this area should be scheduled for performance after the
licensee's incorporation of NRR's review comments into the emergency
plan and the licensee's full implementation of the plan.
No violations or deviations were identified.
11.
Radiation Control
The NRC inspector reviewed the facility's procedures, posting requirements,
radiation area markings, personal monitoring devices, and reviewed the
following records from February 1982 to February 1983:
(a) Air Sampling Data Sheets
(b) Water Sampling Data Sheets
(c) Reactor Demineralizer Check
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(d) Calibrations (Instruments)
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(e) Area Surveys (Form HP-9)
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(f)
Records of External Radiation Exposure
(g)
Reactor Bay Ventilation Filter Change Log
All recorded levels of contamination, radiation levels, and radiation
dose rates appear to be within the 10 CFR 20 limits.
The sample data
sheets were completed and the radiation instrument calibrations had
been completed during this year.
The NRC inspector reviewed a memorandum dated September 30, 1982, from
the radiation safety officer to the University of Kansas project directors.
This memo provided guidelines and instructions that were approved by
the Committee on Radiation Sources for the training and documentation
of radiation worker training and training of nonradiation workers in
laboratories containing radioactive materials.
The NRC inspector noted
that the reactor supervisor and those personnel working in the research
reactor area were not aware of the new requirements.
The reactor super-
visor assured the NRC inspector that he would followup on this and insure
that his department complies with the new training requirements.
No violations or deviations were identified.
12.
Followup, IE Information Type Bulletin
The NRC inspector verified that the licensee had received and reviewed
the following information notices:
80-32 Revision 1 dated February 12, 1982
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82-42 dated November 5, 1982
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82-46 dated November 26, 1982
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82-47 dated November 30, 1982
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The licensee had not received the following information notices from
which the NRC subsequently provided the licensee with a copy:
82-38 dated September 22, 1982
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82-49 dated December 16, 1982
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13.
Unresolved Items
. Unresolved items are matters about which more information is required in
order to ascertain whether or not the items are acceptable, violations
or deviations.
The following unresolved item was discussed-in the report:
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Paragraph
Item No.
Subject
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8301-02
Instrument Calibration / Test
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Exit' Interview
An exit interview was held with the reactor supervisor at the conclusion
of this inspection.
The findings noted above were identified by the
inspector and acknowledged by the reactor supervisor.
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