ML20043B609

Discusses Concern Re Procedure Used by Director for Latest Calibr of Gaseous Stack Monitor.Monitor Recalibr Last Wk Using Proposed SOPs Rather than Currently Approved Sops.Ltr to Radiation Safety Committee Encl

ML20043B609
Person / Time
Site:	Reed College
Issue date:	04/07/1990
From:	Terdal P REED COLLEGE, PORTLAND, OR
To:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 9005310004
Download: ML20043B609 (4)

Text

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'. Yh aggvED N April 7,1990 g Ag ,5 8 Paul Terdal SD . Reed Reactor Facility

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Box 832 Reed College m 3203 SE Woodstock Portland, OR 97202 -

. tel: (503)771-1112 x714

' Ross A. Scarano, Director Division of. Radiation Safety & Safeguards U. 54 Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596

Dear Mr Scarano,

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It has recently come to my attention that you are interested in the procedure used by the Director for the latest calibration of our Gaseous .

StMk Monitor. I am enclosing a letter I sent to our Radiation Safety Cc;.imittee on the subject.

I have spoken to the Director about my concerr3s, and about the concerns raised in your letter to President Powell, but he dentes.the validity of the allegations. He did, however, acknowledge that he ba)

" decided that the SOP was not applicable to the particular instrununt,' and j felt that.*there.may be an occasion in which the Director has to make a change in a standard operating procedure." When asked for the source of his authority to bypass the Radiation Safety Committee's authority granted in the Administrative Procedures to make such changes, he was unable to respond. He also acknowledged that he had "vlolated three SOP's recently -

and indicated that he did Mt consider this to be a problem. I also stand behind the other allegations made_in my letter to the Radiation Safety J Committee.

It may also interest you to know how I became aware of your concerns; I have enclosed a copy of a memo I received from the Director last g',

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week, Informing the chairs of the two Reactor Review subcommittees (/p (incorrectly, of course) that I had sent a le.tter of complaint to you on the j

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matter, and asking me for a copy of it. He explained verbally to me that he i contMers it "hlghly unethical

• to write a confidenttal letter of complaint, ,

and referred to Associate Director Michael Pollock and myself as t

" troublemakers' for (allegedly) colng so.

' Please note that this letter to you is not intended as a formal letter -

of comolaint, as per 10CFR19, but merely an inf ormal of fer of information.  ;

Please do not hesitate to contact me at the address or telephone number above if you have any questions on this matter.

Thank you, Paul Terdal, Senior Reactor Operator

'CC: Dr Ruby, Director RRF; ,

Dr Powell, President, Reed College; '

Dr Bennett, Provost, Reed College; Dr Gerrity, Chair, Reactor Review Committee; i Dr Dalton, Chair, Radiation Safety Committee; Mr Pollock, Associate Director, RRF,  ;

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t RFID REACTOR FACILTIY o 28 March 1990 To: Professon Gerrity and Dalton

From

L. Ruby

' ' I am enclosing a 1.tter from the NRC received by the Provost on 22 March, and tumed over to me on this date. By means of a copy of this letter to Paul Terdal,I am requesting a copy of his letter of complaint to the NRC.

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'o, UNITED STATES

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,, g 1450 MARIA LANE.SUITL 210 W ALNUT CREE K, CALIF ORNI A 94b96

%, " k g E . 4) t James L. Powell, President-Reed College Portland, OR 97202-8199 r

Dear Dr. Powell:

Recently, it was brought to our attention that the Gaseous Stack Monitor for your reactor facility may have been calibrated using a procedure that had not t,een given prior full administrative approval. During the course ,

of subsequent operations, statements by facility personnel may have been interpreted by listeners to mean that approved procedures need not always be followed.

We request that you look into this matter and inform us of your findings.

If-l can be of further assistance in this matter, please do not hesitate to contact me at (415) 943 3717.

Sincerely, h h ' Mb. f\n Y Ross A. Scarono, Director Division of Rac1ation Safety &

Safeguaros

.cc: T. S. Michaelt. NRR/PDNP L MMIc(7)Y l '/8~ j

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February 21,1990 To: Prof. Dalton, Chair, Radiation Safety Committee From:- Paul Terdal, (x714; Box 832)

Senior Reactor Operator Re: Recent miscalibration of the GSM CC: Prof. Ruby, Sarah Herbelin, Michael Pollock, Prof Gerrity As you may be aware, we have a very detalled procedure for the calibration

• of our Gaseous Stack Monitor (GSM), which monitors the air leaving the reactor f acility for radioactive gasses. The procedure involves irradiating a sample of argon gas and then injecting it into the GSM chamber, letting it count overnight. The Standard Operating Procedure has an equation to establish the alarm and f atisafe setpoints, based on government regulations and data collected during the procedure.

ADout a year ago, the air flow rate through both the GSM and APM ( Air Particulant Monitor) was increased to bring them into compilance with their specifications. This had the incidental result of increasing the background in the GSM. In the last three GSM calibrations, the equations in the approved S0P have yielded a fairly low alarm setpoint -- low enough that, during an eight hour run at full power, the background of ten goes high enough tn give us an alarm. Dr Ruby is planning on alleviating this problem by asking the committee to make the equations in the 50P more lenient, inserting a multiplier into them near the end to account for the dispersion of air at our outlet stack. The procedure, I understand, will be coming before the RSC_at its next meeting.

However, as I discovered yesterday (February 20], Dr Ruby went ahead and recalibrated the monitor last week [ February 14] with his proposed 50p, rather than the currently approved one. Whlle I think that the proposed procedure change has some merlt, I have some serlous problems with his decision, which I discussed with him this morning [ February 21):

First, his choice of a dispersion constant was pur~ly arbitrary; he literally just stuck some multipliers into the approved equation until he came across one that gave the value he wanted. He mentioned that he does have a means of deriving the dispersion more rigorously, and that th0 might be done in time for the committee meeting, but acknowledged that the number used for the official calibration was simply the first value he came across that gen him a convenient alarm level.

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4 Second, and most important, such a change in procedure is a major one, and requires committee approval before it is carried ,

out. He responded to this objection by complaining that it is

,. simply too inconvenient to obey the procedures all the time, and that he didn't want to wait for the next meeting to put the change into place. The arguments were based solely on the  !

Infrequency of RSC meetings and the hassle of seeking committee approval.  !

I find this very disturbing; the problem with the GSM Is not a new one, but one we have been living with for over a year. Af ter this much time, the three week wait until the next RSC meeting should not have been considered a major handicap. Even if it were, the Administrative Procedures allow voting by telephone when a prompt decision is needed. Also, were I a voting member of tne RSC, I would want to see a much more rigorous derivation and .

defense of the dispersion factor than existed when the change was implemented. The Radiation Safety Committee is charged with reviewing ,

the safety aspects of procedural changes before they are put into ef fect --

not simply whenever the staff gtts around to asking for advice.

Sin rely, p. >

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Paul Terdal, Senior Reactor Operator 5

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