ML20043B721
| ML20043B721 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 05/10/1990 |
| From: | Pollack J REED COLLEGE, PORTLAND, OR |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 9005310201 | |
| Download: ML20043B721 (12) | |
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John B. Martin, Regional Administrator U.S, Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 i
Dear Mr. Martin:
Re: Docket 50-288, License R112 L
l have received from Dr. Lawrence Ruby a copy of a letter to you dated 27 April,1990.
l In his istter, Dr. Ruby raises concerns about the safety of the Reed Reactor Facility and of my serving as Acting Director. This letter responds only to the specific items in Dr. ;
Ruby's letter. I want to resiate the invitation of President Powell (May 1,1990) for you, j or any investigator from the NRC, to visit Reed at any time to evaluate these and any ;
other concerns. Except for the first three weeks in August, during which time I hope to take a short vacation and intend to shut the Facility down except for required surveillances, I will be available at any time during the remainder of the school year and during the summer. '
i I will address Dr. Ruby's concerns using the numbers from his letter.
l 1. The quotations included in this item are taken from an internal memo to l the Reed Administration and Reactor Oversight Committees which I wrote
'x j dated October 23,1989. I believe that they are taken out of context and i to avoid the same error, I have attached the complete memo for your :
review. While it is true that my memo raises questions about certain . I aspects of an NRC inspection,it was not written as a criticism of Mr. North !
I and I apologize if it is taken as such. The memo was written as a warning to the appropriate individuals at Reed to continue to be diligent in oversight of the reactor facility and to raise specific items in need of -
l action. '
- 2. Dr. Ruby raises two separate items related to compliance with the Reed Reactor Facility Administrative Procedures. Copies of the appropriate sections of this document accompany this response, a) (Section 3.1.18) On the morning of November 15,1989, the secondary water pump failed and an evaluation indicated that it would be out of service for several days. The primary pump had been turned off the previous day (11/14/89) and the reactor tank had been isolated by p
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G May 10,'1990 Page 2 iL j closing the tank inlet and outlet valves. An operation of less than one hour was conducted during the day on 11/15 with both water systems off and the tank isolated. Short operations, not requiring cooling of the tank ,
' water, are routinely performed with the primary system off. J On the morning of November 17, I received a hand written report from L.
' Ruby covering activities on November 16 (copy attached), in which he !
stated that he had interdicted all reactor operation until the pump was -;
restarted and that he felt that l_" acted unwisely" in allowing reactor. I operation. After reviewing the Administrative Procedures, I admitted to i him that.1 had incorrectly remembered this passage as requiring only that the pressure in the primary system not exceed that in the secondary. I a also Indicated that, upon reading the passage again, I agreed with him 1 and indicated that I would discuss with the Reactor Operations the i m possibility of amending this section since the intent of the passage is to prevent tank water from being released to the environment and that is "
' equally well assured by isolating the reactor with valves.
I raised this matter informally with members of the ROC at their meeting on November 20 (not reflected in minutes), it was indicated to me by at . ,
least one committee member that he recalled the reactor having been ;
operated in the past.with both pumps off and that this had been
, considered acceptable under the Administrative Procedure as written.
Never-the-less, I Indicated that I would prepare a suggested amendment i to the Administrative Procedures to clarify this matter before any further .
operations with the secondary pump off.
b) (Section 6.3.b.i) Although I have not been able to locate any written, nor do I.recali any verbal, admonishments relating to accompaniment of l trainees in the reactor facility, this is a subject which was discussed on '
several occasions.
' Our basic disagreement revolved around the definition of the phrase
" proper accompaniment," and whether there is a difference in the I
accompaniment requirement for an Individualin our training program i and an individual, say a high school student visiting the reactor, who has '
no knowledge of the facility and no training in radiation safety. Dr. Ruby indicated orally to me and to the operators that he considered accompaniment to mean literally " standing next to" the individual, presumably in a position to be able to physically intercede to prevent an unwanted action.
I argued that a more liberal definition of " maintaining visual contact" could, and in fact should, apply to individuals who are in our training program preparing to receive an operators license. These Individuals are well known to us, have had at least some radiation safety training !
prior to any work around the facility, and have a need to be extremely familiar with facility details as part of their training.
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. . John B. Martin 1 May 10,1990 L Page 3 l
l-l Two specific instances come to mind in which Dr. Ruby overruled my suggestion that tralnees could be in the reactor bay without an operator "next to them." First, during power calibrations, temperature.
measurements are made by inserting a thermocouple into the tank every 20 minutes. _ l suggested that, at the direction of and under the observation of an operator at the console, it would be appropriate for a tralnee to enter the bay to make this measu_rement. Dr. Ruby overruled and no trainee entered the bay unless a licensed operator accompanied them. I should add that, although radiation levels are elevated during h this operation, they are well documented and an individual performing j
L this operation should receive no measurable radiation exposure, Second, I argued that it was appropriate for a tralnee to observe the !
p operation of control rod drive motors and microswitches while an l
operator at the console raised, lowered, and scrammed the rod. It should I be noted that in this position, the tralnee is in full view of the operator and L the operator can communicate with the trainee over the P.A. system. In i o addition, I also argued that proper training of potential operators recuires them to spend time in the bay observing, examining, and drawing reactor l' i
components and systems, e.nd that if we have to have one operator present for each trainee, our trainees would be as unprepared for the practical portion of the exam as they apparently were last year. 1 in contrast, I argued that it was appropriate for a high school student who L
had just arrived for a seminar to remain in the control room to observe sample unloading fmm the reactor, in this position, the student would have been in full view of both Dr. Ruby and myself and away from the radioactive samples. Dr. Ruby argued that " proper accompaniment" required that she be in the reactor bay, despite the fact that high radiation levels are potentially possible during such an operation. This disagreement was resolved by locking the student out of the Facility completely, She was instructed by Dr. Ruby to wait alone for about 20 minutes in the radiochemistry laboratory. 4 in conclusion I will state simply that, although I disagreed with Dr. Ruby's position, between January 31 when Dr. Ruby issued his verbal ,
interpretation of the Administrative Procedures and April 16,1990,I '
never once violated it, instructed anyone else to violate it, nor was I present when anyone else violated it.
Since my appointment as Acting Director, I have verbally discussed this matter with operators and trainees. The interpretation I have given them is that:
a) Proper accompaniment of trainees in the facility means that the operator shall be either in the control room or the reactor bay, that the operator shall a know what the trainee is doing or intends to do in the bay, and that appropriate reactor doors shall be closed and locked and that they maintain visual contact as described in the Physical Security Plan; and
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' John B. Martin May 10,1990 Page 4-- ,
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b) The same does not apply to individuals who are truly " visitors" to the facility '
and that " proper accompaniment" for these individuals requires closer-supervision.
It is my intention to formalize these interpretations into revisions of the Standard :
Operating Procedure on Security for approval of the RSC in the fall.
L 3) My reason for being uncomfortable in personally handling fuel elements -
j has never been a secret from Dr. Ruby nor any other person on the f
reactor staff. I was handling the fuel element which became :
disconnected from the handling tool at Reed in 1974. For several years following that, I had nightmares about the incident.
However, it is completely untrue that I have no hesitation about asking. I trainees to perform these manipulations. To the contrary, I argued long '
and hard, both with Dr. Ruby and before the Reactor Operations l Committee, against removing from our Standard Operating Procedures, l a procedure whereby operators frequently move the neutron source. My arguments were based precisely on my concern about inexperienced l- individuals performing this delicate operation with fuel elements and my belief that source movement simulates fuel movement sufficient to :
L provide some training. I have insisted that individuals who handle fuel .
L have prior experience handling dummy fuel elements and have never '
L authorized an unpracticed person to handle fuel. ..
r I hope that this letter responds to the concerns raised b your inspectors to discuss them, or any other concerns,y Dr. Ruby with me directly and either on theI encourage ;
phone or in person.
s Sincerely,
(' is J. Michael Pollock Ac:ing Director i
cc: Douglas Bennett, Provost Enc.: 1) Memo: J. Michael Pollock to Reed Administration 10/23/89
- 2) Excerpts: Reed Reactor Facility, Administrative Procedures
- 3) Memo: Directors notes from 11/16/89.
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. October- 23, 1989 To: Reed Administration (Powell, Bennett), ROC, RSC From: J. Michael Pollock- i
Subject:
.NRC inspection of August 1-4, 1989 The inspection report on this NRC inspection has been received. On the surface, this report ~ appears to give an excellent view of current operation and management of the Reed Reactor Facility. I feel it is very important, however, that several issues be raised with respect to this inspection.
Let me state first of all that I agree with the inspector that the student operators who
.were assisting me during the NSF-sponsored workshop, which was in progress at the time, performed extremely well during the inspection and throughout the month of August. They ;
deserve a lot of credit for their work.
My concerns however are three fold. First, at the closing conference in Dr. Bennett's of fice, Mr. North made a statement which is dif fers significantly from recent inspectors. He stated that research reactors are not treated with the same concern as power reactors. He further stated that it is alright to operate the reactor in such a condition that the reactor power occassionally exceeds the licensed power level. He then at least implied that in other situations, exceeding limits or violating regulations was alright as long as they didn't last very long or occur very of ten. It would be very dangerous for Reed to adopt such an attitude. There are at least two reasons: Not all NRC inspectors are going to see things that way and we were previously cited (1982) fc: exactly the same situation which now appears to be acceptable; more importantly, we are an educational institution, training individuals some of who may work in the nuclear field, probably either as educators or managers.
Second, the inspection report contains an unusually large number of incorrect statements. I have described the most important, but certainly not all, of these errors on the attachment to this memo. Since I was unable to participate in this inspections I do not know whether the errors resulted from misinformation provided by facility or if they simply resulted from inadequate attention on the part of the inspector.
Third, unlike other NRC inspectors of recent years, Mr. North apparently did not review psevious NRC inspection reports and assurances made by the facility to the NRC with respect to progress of the facility in strengthening of weaknesses previously identifled. This is particularly important with respect to the compliance of instrument calibrations with NRC Regulatory Guides and American National Standards Institute requirements (see NRC inspection dated 6/29/88), and to assurances provided to the NRC +
by Dr. Cronyn, myself (as Acting Director), and Dr. Ruby (then a consultant to Reed) in a meeting.in Walnut Creek California in 1986 with respect to submission of revisions to the Technical Specifications to bring them into compliance with ANSI standards and NRC requirements. To date, no progress has been made on either of these items.
R would be extremely unfortunate for the future of the Reed Reactor Facility if the Administration and the reactor oversight committees viewed this inspection report as an indication that all problems at the reactor are passed. It will only be by continued involvement of all of us that a return to the problems of the past can be avoided.
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y4 e Comments on NRC inspection of Aug. 1-4, 1989 prepared by Michael Pollock The f ollowing errors and deficiencies appear in this inspection report. They are keyed ;
to report section numbers.
2.a. The license held by a professor at Pacific University is an RO license not an SRO ,
license as indicated. ;
2.b.1. The statement is made that three coramittees exist. In fact there are only two committees; the Reactor Review committee is a fictitious committee which hopefully willgp become the only committee upon adoption of the new Technical Specifications. The review of these Technical Specifications was completed, except for final approval, by the ROC
'Cnd RSC in 1987 and has sat on the Directors desk since.
- 11. The inspection report states that "due to infrequent committee meetings and the committees diligence in reviewing procedure changes, proposed changes are frequently delayed." At the closing conference, the inspector mentioned this problem in particular .
as it regarded revisions of the procedures for calibration of the fixed monitors (SOP's 30-33). Drafts of these procedures were prepared by the reactor supervisor during the summer of 1987; several items were left in an attached comment section for resolution of the Director. Prior to submission of the drafts to the RSC in the fall of 1987, the Director deleted these comments without resolution and without apparent review of the draft procedures. During the RSC's review it was noted that several items needed resolution and the procedures were assigned to one committee member, the Health h
Physicist, and the Director for revision. The committee member was subsequently forced to resign, and to date those procedures have never been returned to the committee, despite the fact that existing procedures are totally inadequate and are, in fact, being generally ignored in favor of the new draft procedures.
3.e. Experiments. The second paragraph refers to a computer program which I developed f at Portland State University several yurs ago. The statement is made that "the ROC had reviewed and approved the program for use at the faellity." In fact, the ROC has never been asked to review, nor is there any reason I can see why they should be asked to review this program.
3.g.l. Stack Monitors-Book 2 notes that calibrations were performed during July 1988 l and June 1989. These calibrations are required semi-annually and while they were done '
Lin. January, th? documentation was missing. Questions should have been raised during the inspection about the missing records.
I 11. Health Physics-Book 2. The inspector reported that samples were collected on V
'Sanuary 10,1989 ano lists concentrations of several isotopes in those samples, #
- ' aupposedly analyzed by U.S. Testing. In fact, although those samples were collected, l they were not analyzed by U.S. Testing or anyone else. i 111. Area Monitor. The inspector notes that calibrations were conducted on July p 25, 1988 and January 11, 1989. No summer 1989 calibrations were reported even though i the Technical Specifications would have required them to be done before the inspection.
ft is believed that they were conducted but the documentation is lacking. l f iv. Control Rod Calibrations. The reported calibrations were not the current ones l l at the time of the inspection.
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. 2.h. Procedures. The inspector noted that procedures were all submitted to the ROC prior to implementation. In f act, some procedures are approved instead by the RSC where g it is felt the expertise and safety concerns of that committee are more appropriate.
- 2.1. Requalifleation Training. This entire section describes the original operator !
license training program at Reed during the past year--NOT the regualification training program for those who already possess operators licenses. As a result, the section is full of false statements including:
a) He states that "the licensee conducts a regualification training program which j incorporates" and then he references several sections of the federal regulations. The existing NRC approved Regualification Plan does not meet these requirements. A revised plan, written by the Associate Director during the summer of 1988, was finally submitted j by the Director to and was approved by the ROC during the summer of 1989. It has now l been submitted to the NRC, however, they have requested revisions to several sections to bring even this new plan into compliance, b) "Two of the lectures were optional for RO and SRO requalification since they satisfied a State of Oregon training requirement for radioisotope handlers and users.
Attendance lists were maintained." In fact, had the inspector checked these attendance lists, he would have discovered that in almost no case were any of these lectures i attended by any licensed RO's or SRO's; they were not required to attend! He then goes i on to state that " individuals were responsible for reviewing the material presented <
during any missed lectures," again a false statement, i c) The inspector describes the annual written comprehensive test required by the Requalification Plan. He states correctly that, according to the Requalification plan, g!
- any RO or SRO who f alls to achieve a score of 80% on any portion of the written examination must complete an accelerated requalification program." He later states that "the requalification files of five student RO's and SRO's were examined... records were i adequate to demonstrate the accomplishment of the regualification training program." i There is no indication in this section of the inspection report that the inspector
- was ever provided with, and he certainly never reviewed, the requalification records for i the 1988-89 requalification year. The required meetings and lectures were far less l comprehensive than described in this inspection report and barely met the requirements !
of the existing Requalification plan, much less the referenced requirements of the NRC l for such a Plan. As of the meeting of the RSC in early October, at least two student i operators, one an RO the other an SRO, who had failed to achieve a score of 80% on one l or more portions of the annual exam for 1988-89 pr5 were continuing to operate the reactor without completion of an accelerated re; training program. The Director, who had chosen to administer this exam himself over the objections of several student operators, admitted a couple of days af ter the RSC meeting that he was aware that one of the students had not completed the requirement but he could not remember what the status of the other student was.
3.b. Personnel Monitoring. 1. Theinspectorstatefthat"resultsofthesecondquarter 1989 had not been received at the time of the inspection." This report was processed by /
Radiation Detection Company on July 28, 1989 and received at the Facility on August 1, N the day the inspection was begun. It was discussed that morning by the Director and the $
Associate Director with respect to the f act that the Director and a high school student chowed relatively high (for Reed) exposures to the hands.
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, 11. The inspector reports that TLD's are ved to perf orm environmental radiation measurements in the reactor room and 'on the roof of the reactor f acility". At one time these were on the roof, however problems with vandalism rer,ulted in their being raoved in
$1de the facility where they were place as near the ceiling as possible to give a 7 conservative indication of radiation levels to vandals on the roof. The Director has 1 8 now moved them down farther so that at least one of them is waist high and they no longer serve any function as environmental monitors.
- 4. Emergency Planning and Preparedness. It is stated in this section that the hospital declined to play in RRF drills, however the Reed staff were permitted to observe drills at the hospital when the hospital played during a Trojan Nuclear Power Plant drill. I believe that there are two misstatements or at least misrepresentations in thir, section. First, the hospital has signed an agreement that they will participate in drills and, if in fact they did decline, they are in violation of that agreement. The Director has been opposed since he arrived at Reed to the participation of either the hospital or ambulance personnel in drills. To alleviate the Directors concerns about f, unnecessarily burdening these institutions with our drills, the Assoelate Director !
suggested that Reed could coordinate a drill with, or participate in the Trojan medical /
emergency response drill. This has never occurred although it could be interpreted from the inspection report that it has. The Associate Director has participated as an emergency responder f or three years in the Trojan Emergency drills (but NOT the medical drill) and the Director is participating this f all.
- 5. The inspector states in this section that "the only individuals authorized to ship s or transfer radioactive materials of f campus are the RRF Director and Associate Nf Director." While this may be the case at present, the SOP approved by the RSC restricts shipping to individuals " approved by the Director" and the existing SOP for transf er allows any operator to authorize such transfers.
- 6. Information Notices. The inspector reports that he discussed the need for an amendment to the f acility license should the licensee wish to irradiate byproduct material. It is completely unclear to what he is referring since, by definition, any \p material produced in the reactor including all of the samples we have irradiated for the last 21 years are DEFINED as byproduct material in the NRC regulations.
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' Ree'd Reactor Facility Adminisn6tive Procedures page 12
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elements from the C ring of the reactor core. Maintenance work cannot be carried out on more than one (1) rod at a time. During maintenance work on a
/ji control rod, the magnet power to the remaining two (2) control mds must be I disconnected. If maintenance is to be performed on a control rod drive motor l i
I only,be may unically mec separate from the control rod drive motor assembly. leaving thl
- Under the direction of the Reactor Supervisor the control rod drive motor !
assembly may then be removed for maintenance. !
- 17) De reactivity worth of samples containing fissionable material must be I determined in position by operating the reactor at 5W power and the result j compared with the Technical Specifications before the sample can be activated in the reactor operating at higher power levels. De only exception shall be for pneumatic tube irradiations of naturally occurring fissionable nuclides to i' produce at most 2 a 1010 f ssions. All such experiments shall be treated as s _
18)De peial pressureexperiments of the lake water each in thetime theywater secondary aresystem performed.
of the heat exchanger must at all times exceed the pressure of the reactor pool water in the I heat exchanger. Before maintenance work on the secondary system can be i I started, the pool water circulating pump shall be tumed off and the heat exchanger system shall be isolated from the reactor tank by closing the j
j sppropnate valves.
3.2 Overhead Crane O wrmtion The crane trolley s allnot be o operation. De crane bridge, however,perated over the reactor when the reactor is i ;
operati,ng Permission to operate the crane must be obtained from the Director for each operation. ,
IV. REACTOR EXPERIMENTS s
4.1 Ernerimental Facilities The reactor has two (2) major experimental areas:
1)In-core: Pneumatic transfer system CentralThimble Fuel Element Replacement (Empty Source Holder)
- 2) Near core: Rotating specimen rack (L.azy Susan)
Poolirradiations near core 4.2 Clanes of Erne iments There are three (3) classes of experiments (routine, modified routine, and special) performed with the RRF TRIGA reactor:
- 1) Routine exneriments are those which involve operations under conditions which have been extensively examined in the course of the reactor test programs. Under the Facility Licenses for the reactor, routine operation within '
the limits of the Technical Specifications applicable to the reactor is pennissible at the discretion of the Director and no further review is necessary.
- 2) Modified routine exneriments are those which have not previously been performed but are similar to routine experiments in that the har.ards are neither significantly different nor greater than those for the corresponding routine experiment and are pennitted under the Technical Specifications. These modified ex 3eriments may be performed at the discretion of the Director without furtier review, provided that the hazards associated with the modified routine experiments are reviewed and the determination made and documented 10/87 Revision
E, , i Reed Reactor Facility Administrative Procedures page 15 ..
V. HANDLING, STORAGE, AND DISPOSAL OF RADIOACTIVE MATERIAL 5.1 Adminit'=tive Prnr+Amet
- 1) De Reactor Operator has the responsibility of removing all experimental materials (radioactive samples or apparatus) from the reactor pool. De Reactor Operator is also responsible for proper shielding and containment of the radioactivity as well as proper labeling o r the radioactive materials in accordance with the pertaining regulations and the Standard Operating Procedures. De radioactive material remains the responsibility of the Reactor .
I Operator until it is transferred to a person authoriand by the Director to receive it.
- 2) De Reactor Operator shall keep a record of the caperiment, the time when it was removed from the reactor, the amount of radioactivity produced, and the i radiation level of the specimen when removed from the reactor. De record '
must be continued to include the storage positions and shielding used for the i sample (s) and the dose rate on the outside of the shielding containers. l
- 3) De Reactor Operator shall record the transfer to an authoriaed person, the ;
name of such person, the time of the transfer, and a description of the container as well as the dose rate at the surface and one (1) meter from the surface of the shipping container at the time of the transfer. A copy of the record after disposa of the specimen will be kept by the office of the Reactor Facility, i
- 4) Radioactive material remaining at the facility shall be stored either in the storage cave, or in a properly shielded area ro zd off and labeled in accordance with 10CFR20. There shall be no area in t x Facility that is not roped off and labeled where the radiation level exceeds 5 mrem /hr or where a person can receive a 100 mrem dose during a 40 hr week.
- 5) No radioactive sample or specimen shall be stored in the Facility in excess of one (1) year, unless it is to be used at a later time. If the sample or specimen has not decayed to negligible levels within six (6) months, it should not be kept at the Facility.
- 6) All radioactive waste will be disposed of by the Health Physicist by shipment to a waste disposal area in accordance with all applicable regulations for such !
shipments. The waste disposal area now being utdized by the faellity is the Hanford Site (U.S. Ecology,Inc.).
5.2 Fuel and Snecial Nuclear Materint
- 1) Special nuclear material is at all times the property of the United States ,
Department of Energy (DOE). It is on lease to ne Reed Institute (Reed l College) which is accountable to DOE for its location and proper handling. 1 Primary accountability as far as the DOE is concemed thus rests with the Director of The Reed Reactor Facility. ,
- 2) De Director is responsible for all fissile and fertile material in the Facility. !
- 3) De Director is accountable to the Reactor Operations Committee for any changes in the fuel configuration in the reactor core and for proper storage of used and spart fucl elements.
VI. ACCESS TO THE REED REACTOR FACILITY '
6.1) %c only entrance to the Reactor Bay when the reactor is in operation shall be through the Control Room. De Register for visitors (Entry List B described
- below) and storage racks for personal ionization chambers (PIC's or dosimeters) will be located in this room.
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[.l Reed Reactor Facility Administrative Procedures page 16 ,,
6.2) Access to the Reactor Room will be permitted only to penons who have been given !
the necessary authorisation as set forth below. Attention is caBed to the fact that individuals under the age of 18 yean will require special authorisation as spelled out at the end of this section.
6.3) Persons who can be admined to the Reactor Room are divided into two categories !
as described below under Entry Ust A and Entry ust B.
a) Entw 1 i=t A: individuals are placed on this list only by the Director of the Reed Reactor Facility. Individuals who are eligible for naming to this list are
- 1) Members of the Reed Reactor Facility S ctff.
ii) Other persons requiring such access and meeting the requirements of ;
the Reed Reactor Facility Security Plan for unescorted access to RRF.
Entry Ust A shall be posted in the Control Room and maintained current by the Director. Penons on Entry Ust A do not need to be accompanied while -
in the Reactor Control Room or Reactor Bay. Dey may accompany other ,
individuals with whom they have specific business provided their entry has been authorized as described below for Entry Ust B. Individuals on the !
Reed Reactor Facility Staff need not sign in and out upon entering and leaving the Control Room or Reactor Bay. RRF Staff members will be assigned individual thermoluminescent dosimetry badges (TLD badges) and shal follow normal badge procedure with respect to wearing and stormg ,
' them. Any individual on Entry Ust A not havmg a permanent badge shall .
check out a personal ionization chamber and sign Entry Ust B prior to
>nt"ine the Reactor. Bay. _
b) Entry Ott B: 'Ihis list comprises visitors to RRF. Their entry to the Reactor j Bay can be authorized by those individuals whose names appear on Entry '
Ust A. De penon authorizing the access shall be responsible to assure that the individual's name and other pertinent data have been entered properly on Entry Ust B. The person authorizing an individual's access to the Reactor Bay shall also be responsible to assure:
i) Proper accompaniment for the individual has been arranged. -
- 11) De individual has been issued (and retums) the appropnate ;
_ __ dosimeter, themumbetoLwhich has hoen2ecorded.
l 6.4) Only the Director may authorize entry into the Reactor Bay by visitors under 18-years of age. It is undentood that the Dunctor will not grant such an authoritation :
unless he is confident that the total radiation dose to which the visiton will be i
i exposed does not exceed ten (10) mrem. In the event that circumstances will not permit authorization under the conditions specified, the young visiton will be restricted to viewing the Reactor Bay through the windows in the corridor.
10/87 Revision
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