ML20034C121
| ML20034C121 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 04/13/1990 |
| From: | Murray B, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034C115 | List: |
| References | |
| 50-128-90-02, 50-128-90-2, NUDOCS 9005020079 | |
| Download: ML20034C121 (10) | |
See also: IR 05000128/1990002
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APPENDIX C'
O.S.' NUCLEAR. REGULATORY' COMMISSION
REGION IV
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NRC Inspection Report:
50-128/90-02
-Operating License: .R-83
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Docket:
50-128
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Licensee: Texas Engineering Experiment Station
Texas.A&M University _
College Station, Texas 77843-3126
Facility Name: Texas A&M University _.
Inspection At: Texas Engineering Experiment Station - Nuclear--Science
Center (NSC)
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Inspection Conducted:
February 21-23, 1990
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Inspector:
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Lrrry/Rickpson, R{, fFadiation Specialist-
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Facilities RadiatioMrotection Section
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Approved:
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BTai'he Murray, Ctiief," ~Facilteb Radiological
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Protection Section
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Inspection Summary
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Inspection Conducted February 21-23, 1990 (Report 50-128/90-02)
Areas Inspected:
Routine, unannounced inspection of the licensee's radiation
protection program.
Results: Within the areas inspected, one violation was identified (see .
paragraph 9), and one deviation was identified (see paragraph 8).
The
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radiation protection program at the NSC was considered adequate; however,
several problems were identified.
Some essential radiation procedures had not
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been developed. The radiological indoctrination training for experimenters was.
lacking in_ some areas. A permanent senior health physicist had still not been-
hired. The health physicist technicians-assigned full-time to the NSC
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demonstrated good work practices, but these individuals were inexperienced.
Exposure controls appeared generally adequate; however, contamination control
procedures need improvements.
Surveillance and reporting requirements had been
met.
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DETAILS'
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1.
Persons Contacted
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- K. R. Hall, Deputy Director, Texas Engineering Experiment Station (TEES)
- F. D. Jennings, Executive Director, Office of University Research,
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Texas A&M University (TAMU), Chairman, Reactor Safety Board
- J. W. Poston, Director, Nuclear Engineering, TAMU
- D. E. Feltz, Director, NSC, TEES'
T..Ives, Manager, Reactor.0perations, NSC-
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- C. Meyer, Health Physicist, TAMU
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W. Short, HP Co-op; Student, NSC-
E. E.'Schneider, Associate' Director, University Police .
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C. Yeager, Training Officer, College Station Fire Department
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- Denotes those present at the exit meeting on February 23, 1990.
2.
Action on Previous Inspection Findings
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(Closed) Open Item (128/9001-03):
Loading Dock Warning _ Sign - This item
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was identified in NRC Inspection Report 50-128/90-01 and involved the. lack'
of barricades or warning signs to prevent unauthorized personnel from
entering the reactor building through the open door when radioactive
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shipments were being transferred from the materials handling area to the
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-loading dock. The inspector noted that.a chain'and. warning sign had been
placed across the front of the loading dock to prevent. individuals from-
. unknowingly. entering a restricted area. The NRC had no further questions-
in this area.
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3.
Open Items Identified During This Inspection
An open item is a matter that requires further review and evaluation by
the inspector, such as an item pending specific action by'the licensee or
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a previously identified violation,-deviation, unresolved item, or
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programmatic weakness. Open items are used to document, track, and ensure
adequate followup on matters of concern to the inspector.
The following
open items were identified:
Open Item
Title
Paragraph
128/9002-03
Contamination Controls
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128/9002-04
Decontamination Procedures
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128/9002-05
Unauthorized changes to standard
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operating procedures (SOPS)
4.
Observations
The following are observations the inspector discussed with licensee's
representatives at the exit meeting on February 23, 1990.
The
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observations are:not violations, deviations,. unresolved-items, or.open
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items. Observations are identified for' licensee consideration,. but have_
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- no specific regulatory requirement.
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There is no HP support at.the NSC during reactor operations conducted
from approximately 5 p.m. .until midnight.
(see paragraph. 5).
The licensee had'not implemented a comprehensiveiradiological'
controls examination.
(see paragraph 6)
The licensee had not issued an officia1 policy statement endorsingt
efforts to maintain radiation exposures as-low as reasonably
achievable (ALARA). _(seeparagraph7)
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The licensee.had self-containe'd breathing; apparatuses (SCBAs)
available for use, but did not- have a: respiratory: protection training'
program.
(see paragraph'7)
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The concept of radiation work permits has never beenLimplemented.
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(seeparagraph9)
5.
Organization and Staffing
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Theinspectorreviewedthelicensee'sorganizationandstaffinito.
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determine compliance with Technical Specification (TS) 6.1,1commitmentsiin
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the' Safety Analysis Report (SAR), and agreement with the recommendations
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of ANSI /ANS.15.11-1987,
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The inspector reviewed proposed Standard Operating Procedures-(SOP) I-C,
" Administration," and S0P II-A, " General Organization and -
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Responsibilities." The procedures set forth= management levels and defined:
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the relationships between the different groups having-responsibilities
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with regard to the NSC.
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The NSC radiation protection 1 office.(RPO) is. responsible for the
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development and implementation of the radiation protectionJprogram. _The
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RP0 is separate from the campus radiation. safety office (RS0) and is
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independent of the director of 'the NSC, reportirg directly to -the1 deputy.
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director of TEES.
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S0P II-A lists the positions in the RP0 as:
a' senior health physicist, a
health physicist, and a health physics technician. The ' procedure li sts :nce
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qualifications for any of the positions, but does list. general-
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responsibilities. The licensee had not, at the time of the inspection,:
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filled the position of senior health physicist, but was soliciting-
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applications. Two HP technicians. one a co-op student, were' employed
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full-time at the NSC. The' campus RSO was still supplying experienced HP
personnel to support reactor startup each morning.
Routine operation of
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the reactor involves first and second shifts between 8 a.m. and
12 midnight. HP coverage is normally only provided during the day shift,
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but operations continued without HP support until as late as midnight.
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-However, work such as preparation of material for shipment was-typically
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performed during this first shift.
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Audit requirements for the radiation protection program are included in
SOP I-H, "The Reactor Safety Board." The audit program was discussed in
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NRC Inspection Report 50-128/90-01.
The procedures referenced above had been signed by the director of the
NSC, but at the time of the inspection had not been signed by the chairman.
of the radiation safety board.
No violations or deviations were identified.
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6.
Training and Qualifications
The inspector. reviewed the training given by HP'as an_ indoctrination to
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experimenters working. in the NSC to determine' compliance with 10 CFR 19.12
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and agreement with the recommendations in Regulatory Guide (RG) 8.13,
8.27, and 8.29.
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The inspector noted that a discussion concerning the risks from
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occupational radiation exposure as outlined in RG 8.29 were absent from
the HP technician's lecture notes, but were referenced in another lecture
outline found in the training file. The technician stated that the
information from RG 8.29 would be incorporated into the material
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presented. The inspector noted that the material taught to experimenters
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included the material from RG 8.13 and generally..followed the guidelines
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of RG 8.27.
The inspector noted that.the test which followed the training
contained only 13 questions. Upon further review, the inspector noted
that two of those questions were essentially the. same.
The inspector-
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observed that the examination did not' include enough questions to
establish that the experimenter had a proper understanding of radiological
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controls.
Licensee representatives stated that the test material would be
reviewed.
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The HP technicians, one a full-time employee and the other a co-op student
in HP, have only limited on-the-job training with no prior HP. experience,
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The inspector observed that they adequately performed daily surveillances,
but were not given HP approval authority. The signature of a. senior HP
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from the campus RSO is still necessary for such operations as reactor
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startup, experiment approval, and liquid waste disposal.
The inspector met with representatives of the campus police force and the
City of College Station Fire Department and confirmed that -these-
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organizations received annual training concerning emergency responses to
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the NSC. The NSC HP technician and senior HP from the campus RSO
presented the annual training to hospital personnel.
No violations or deviations were identified.
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Exposure Control
The inspector reviewed the licensee radiation exposure control program to
determine compliance with 10 CFR Part 20.
The inspector inquired of the director as to whether the NSC had a written
statement by management of a commitment to keep exposures to personnel and
the general public ALARA. No statement was available, but the director
pointed out that annual reviews were performed by the Radiation Safety
Board to ensure that exposures were ALARA.
The inspector noted that
industry standard (ANSI-ANS-15.11-1987) recommends that a clear statement
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of this policy be included in the operating procedures or in the
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procedures on radiation protection.
Individuals are provided personnel monitoring in accordance with
10 CFR 20.202. The licensee decides during the experiment and approval
process what monitoring is appropriate for each experimenter. When it is
deemed appropriate, individuals are issued monitoring devices capable of
measuring both fast and thermal neutrons, in addition to beta and gamma
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radiation,
personnel monitoring is supplied by a vendor approved by the
National Voluntary Laboratory Approval Program.
The inspector reviewed personnel monitoring records for 1988 and 1989 and
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determined that no one exceeded allowable limits of 10 CFR 20.101. The
highest exposures received by any person at the NSC was less than 500 mrem
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per year.
The inspector observed that entrances to high radiation areas were locked
to prevent unauthorized entry. A camera on the lower level allows the
reactor operators to observe the area.
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Even though there are no regulatory requirements for a respiratory
protection program, the licensee has two SCBAs. The SCBAs would
presumably be used in case of emergency, but none of the licensee's
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personnel had been fit tested, given a pulmonary function test, or
otherwise evaluated to determine that they could successfully wear a
respirator. One former operator, now employed by one of the
experimenters, stated that he had received training from the fire
department on the donning and wearing of the respirators.
The potential
for injury or death exists if untrained, untested personr.el wear the
equipment into a hostile atmosphere and experience an improper fit of
the equipment; a medical problem or psychological reaction as a result of
wearing the equipment; or a problem as a result of inadequate instruction
on the correct use of the equipment.
The licensee's representatives
stated during the exit meeting that they would' reevaluate the possession
and use of the SCBAs.
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The licensee does not require whole body counting or have a program for
routine bioassays, having deemed them not necessary.
No violations or deviations were identified.
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Surveillances
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The inspector observed the performance of surveillances and reviewed
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records of surveillances to determine compliance with TS 4.5, commitments
in the SAR, and agreenent with the recommendation of ANSI-N323-1978.
The inspector observed the HP technicians as they performed the daily pool
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water radioactivity analysis, daily building integrity check, and daily
facility monitoring checks as required by 50P VII-B 2, 3, and 4.
All
items were performed in a manner consistent with good work practices.
The inspector reviewed records of monthly cooling tower sample analysis,
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monthly facility air monitoring tests, and calibrations of the stack
particulate monitor, stack gas monitor, reactor building particulate
monitor, reactor building gas monitor, and fission product monitor.
The inspector reviewed records of portable instrument calibrations and
noted that the neutron survey instrument, Serial No. 2103, was originally
calibrated by the manufacturer on July 15, 1988.
Records indicate that
the instrument was not calibrated again until January 9, 1990.
Licensee
representatives stated that the survey instrument was used at least five
times between July 15, 1989, and January 9, 1990, to measure radiation
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levels in areas near a beamport, where experimenters were to work.
Measurements performed by the NRC in April 1988 indicated that neutron
radiation levels as high as 20 rem /hr may be present.
S0P VII-B-13,
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" Portable Survey Instrument Calibration and Operability Check," requires
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that survey instruments be calibrated annually which is in agreement with
the recommendations of Industry Standard ANSI N323-1978.
Chapter X of the
SAR requires that procedures be followed by all personnel.
The failure to
perform annual calibrations is an apparent deviation from commitments made
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in the SAR.
(128/9002-02)
No violations were identified.
9.
Radioactive Materials Controls
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The inspector noted that the licensee had changed their procedures
concerning the inventory and control of radioactive material under the
control of either the NRC license or an Agreement State license.
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licensee had developed new inventory forms and implemented.their use to
track the materials.
The inspector reviewed records of radioactive materials retained at the
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NSC and noted that the records had not been reviewed by a senior HP since
October 1989.
The inspector reviewed records of radioactive materials released to campus
and to offsite locations. The licensee made approximately 425 such
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transfers in 1989.
The inspector identified that the licensee shipped
80 mil 11 curies of Na-24 to Teledyne Isotopes, Inc., in October 1989.
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copy of Teledyne's NRC license on file with the licensee listed the
expiration date as September 30, 1989.
10 CFR 30.41(c) requires that
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before transferring byproduct material, the licensee. transferring the
material shall verify that the intended recipient has a current license
which authorizes its receipt.
10 CFR 30.41(d) sets forth the methods of
verificatiun and requires specific action in regard to the expiration date
of the license.
The failure to follow one of these methods of
verification is an apparent violation (128/9002-01).
A senior HP from the campus radiation safety office stated that,
typic 611y, the status of the transferee's license is checked during the
experiment authorization stage, but that such a check had not been
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included as part of a specific procedure.
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The inspector confirmed that an application for renewal of
License 29-0005-06 belonging to Teledyne Isotopes, Inc., had been deemed
timely filed.
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The inspector inspected contamination controls in effect at the NSC.
The
materials handling area on the upper level of the reactor building was
observed to be a restricted area, due to the possible presence of
radioactive contamination.
Latest smear survey data indicated areas of
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contamination on the order of several hundred counts per minute.
One
operator was observed working in the area wearing shoe covers. Another
individual, not wearing shoe covers, was seen entering the area and
joir.ing the first.
The second individual exited successfully through the
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portal monitor, without contamination, and returned to the area a short
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time later wearing shoe covers. The inspector discussed ?.he apparently
nonuniform practices with the licensee and determined that there was no
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established S0P specifically addressing radiological requirements for area
controls, nor was there any type of radiation work permit or special work
permit to give specialized instructions.
The NSC director stated that the
area was sometimes surveyed and declared to be clean, while at other
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times, administrative controls were used to prevent the spread of
contamination.
He acknowledged that this lack of a consistent policy
probably led to confusion on the part of some workers as to what was
currently required,
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The inspector noted that individuals leaving the contaminated area stepped
onto the portal monitor wearing their shoe covers.
If the individual did
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not set off the portal monitor alarm, he removed the shoe covers and
placed them in the container marked " clean," for reuse.
If the shoe
covers were contaminated or torn, they were placed in the other container
so marked.
The containers were side-by-side in the clean area.
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inspector noted that the containers held approximately the same number of
shoe covers, so presumably some were found to be contaminated, since all
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in the second container were not torn.
Visually, the shoe covers were
indistinguishable, because all looked as though they had been used.
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practice could conceivably lead to confusion or neglect regarding the
separating of shoe covers into the proper container, tnereby contributing
to the spread of contamination. Additionally, it could lead to the
contamination of the portal monitor and its subsequent, temporary
withdrawal from service.
Contamination control practices were discussed
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at the exit meeting on February 23, 1990. The licensee acknowledged the
need for improvement and stated this area will be evaluated.
This matter
is considered an open item pending further NRC review.
(128/9002-03)
The inspector observed another area on the' lower level, near one of the
beamports, which was designated as contaminated.
It too had containers of
. clean and contaminated shoe covers at the entrance to the controlled area;
however, there was no contamination monitor in the immediate area to allow
individuals to determine whether or not shoe covers were contaminated nor
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were there any instructions to individuals informing them it should be
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assumed that, once used, shoe covers were contaminated.
An individual observed working on the lower level was identified to the
inspector as an experimenter and not employed by the NSC or Texas
A&M University, but by an outside company. The individual wore proper
personnel monitoring and wore shoe covers while in the controlled area.
The individual was heard to say that he had decontaminated (mopped) the
fenced, controlled area recently.
The inspector questioned the HP
technician, who had been aware of this activity.
The HP technician stated
that the decontamination had been monitored and contaminated liquids
properly disposed. The inspector determined that there was no S0P for
decontamination or guidance for these activities which would help prevent
personnel contamination or spread of radioactive materials to other areas.
The licensee's decontamination control activities were discussed at the
exit meeting on February 23, 1990. The licensee stated that
decontamination practices would be evaluated.
This is considered an
open item pending further review by the NRC.
(128/9002-04)
The inspector reviewed area survey records and determined that all areas
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are surveyed monthly. When questioned as to how the frequency was
determined, a senior HP from the campus radiation safety office speculated
that its origin was rooted more in history than technical reasoning,
carrying over from the time the campus RSO performed the surveys.
The radioactive materials storage-areas were inspected and determined that
they were properly controlled and posted.
No deviations were identified.
10. Radioactive Waste
The operations and records were inspected to determine compliance with
TS 3.5.2 and 3.7, 10 CFR Part 20 requirements, and agreement with
commitments in the SAR.
Solid waste is collected, characterized, and transferred to the campus
RSO.
No recent disposals of resin have been made, although the director
of the NSC stated that this may be necessary in the near future.
Resins
are not solidified.
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The inspector observed the sampling and subsequent release of liquid waste
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from a liquid waste storage tank.
Three storage tanks are available for
liquid waste use; however, one is typically reserved for pool water should
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it be necessary to drain it. Before sampling, the liquid waste is mixed
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unng the liquid stirrer. The inspector reviewed a study which the
licensee had performed, documenting the effectiveness of. representative
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sampling. A sample of the liquid waste was collected and counted
according to SDP VII-09. The inspector noted that handwritten changes
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were made in the HPs' copy of the SOP.
The changes indicated that the
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volume of the sample should be reduced by half and that the counting time
should be reduced from 10 minutes to 1 minute. The changes were not
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consistent with the official copy of the SOP maintained in the director's
office. The director stated that the changes had not been authorized.
The HP technicians stated that they were not responsible for_the changes,
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nor had they followed the changes and altered the original method of.
analyzing liquid waste samples. The inspector's observations confirmed
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that sampling and analysis activities were performed as stated in the
original SOP.
The matter of handwritten changes to SOPS was discussed
during the exit meeting on February 23, 1990.
This area is considered an
,o_ pen item pending further review by the NRC.
(128/9002-05)
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The liquid waste sample was counted and the concentration and total
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activity were printed by one of the licensee's computers. The inspector
noted that the program does not sum the activities of previous disposals
for a current, yearly total; however, he also noted that each individual
disposal was much less than the allowable total for the year.
A_ senior
health physicist is required to evaluate the sample results and give
approval for the release.
The senior health physicist interviewed stated
that the computer program had been validated by the campus RSO.
The inspector observed as the HP technicians performed the valve alignment
and liquid waste disposal from the liquid waste storage tank. Valve
position can be verified visually. A supervisor's key is necessary to
unlock the valve allowing the release of the liquid waste. The inspector
noted that the connection with the domestic water supply (used to stir,
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dilute, and flush) was broken after operations were complete to prevent
backflow.
The inspector reviewed the 1988 Annual Report and reports constituting the
raw data for the 1989 Annual Report and determined that the concentrations
of Ar-41 in the effluent gas at the boundary of the exclusion area did not
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exceed the limit of 4.8 E-8 microcuries per milliliter specified by
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TS 3.5.2, nor did the total release exceed 30 curies as specified by
No violations or deviations were identified.
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11.
Fuel Inventory
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The inspector reviewed the fuel inventory records to determine compliance
with License Condition II.B.(2), which limits possession of U-235 to a
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maximum of 17 kilograms.
Records indicate that the licensee possesses
approximately 13.1 kilograms of U-235 in both fuel life extension program
and standard fuel elements.
No violations or deviations were identified.
12.
Environmental Monitoring
The inspector reviewed the environmental monitoring program to determine
compliance with commitments in the SAR.
The licensee conducts environmental monitoring in conjunction with the
Texas Department of Health, Bureau of Radiation Control.
The two
organizations collect and split samples on a quarterly basis.
Soil
samples are taken in NSC creek; water samples are taken upstream in the
Brazos River and compared with those taken downstream in White Creek.
Vegetation and milk samples are taken at the university dairy.
Thermoluminescent dosimeters (TLDs) are placed around the perimeter of the
protected area of the NSC.
The dosimeters are processed by the state of
Texas and results are reported to the licensee. The licensee, in turn,
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reports the TLD results along with the sample results, in the annual
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report.
No violations or deviations were identified.
13.
Reporting Requirements
The inspector reviewed the 1988 Annual Report and determined that the
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licensee was in compliance with the reporting requirements of TS 6.6.
No violations or deviations were identified.
14. Exit Meeting
The inspector met with the licensee's representatives denoted in
paragraph 1 at the conclusion of the inspection on February 23, 1990, and
summarized the scope and findings of the inspection as presented in this
report. The licensee did not identify as proprietary any of the materials
provided to, reviewed by, the inspector during the inspection.
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