ML20055H408

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Insp Rept 50-160/90-02 on 900612-14.Violation Noted.Major Areas Inspected:Radiation Protection Activities,Including Radiation Control,Environ Surveillance & Monitoring & Followup & Review of Licensee Actions
ML20055H408
Person / Time
Site: Neely Research Reactor
Issue date: 07/11/1990
From: Bassett C, Gloersen W, Mcalpine E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20055H403 List:
References
50-160-90-02, 50-160-90-2, NUDOCS 9007260166
Download: ML20055H408 (13)


See also: IR 05000160/1990002

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UNITED STATES j

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NUCLEAR REGULATORY COMMISSION  !

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Report No.: 50-160/90-02

Licensee:- Georgia Institute of Technology

225 North Avenue

Atlanta, GA 30332  :

Docket No.: 50-160 License No.: R-97 j

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Facility Name: Georgia Institute of Technology Research Reactor

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Inspection Conducted: June 12-14, 1990

Inspectors: 44dbb _/ //!fO

C. H. Bassett, Senior Radiation Specialist Date/ Signed .

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SeniorRadiationjeci A st ate S gnad

Approved by:'" .- L

E. J. McAlpine, Chief

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Radiation Safety Projects Section

Nuclear riaterial Safety and Safeguards Branch

Division of Radiation Safety and Safeguards

SUMMARY

Scope:

This - routine, unannounced inspection involved onsite review of radiation

protection program activities including radiation control, environmental i

surveillance and monitoring, and followup and review of licensee actions i

concerning Inspector. Followup Items. .

Results:

The staffing and current organizational structure were adequate to meet ,

Technical. Specification requirements and to implement the licensee's radiation

protection program. A person has been hired to fill the position of Managor,

Office of Radiation Safety and is scheduled to start in July. The licensee has

continued' work on the radiation protection program at the facility and has

completed writing or revising nearly all of the procedures in this area.

Strengths in the licensee's program were noted in the areas of external and

internal exposure control through maintaining low facility radioactive

contamination levels and low radiation exposure to personnel, and in the area

of. environmental monitoring for the reactor facility.

9007260166 900711

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Within the. areas inspected, one apparent violation and one non-cited violation' l

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Failure to maintain a high radiation , area l acceptably controlled as

required by 10 CFR 20.203(c)(2).- This is discussed in Paragraph 5.

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Failure ~ to . perform = a personnel survey prior .to crossing ,from a .;

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controlled to -an uncontrolled area. This issue was characterized as: 1

1 a non-cited violation and is discussed in Paragraph =5. Li

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REPORT DETAILS

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1.- Persons Con +. acted

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L *R. Karam, Director, Neely Nuclear Research Center (NNRC) ,

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  • B. Revsin, Associate Director, NNRC and Acting Manager, Office of i

Radiation Safety

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Other licensee employees contacted during this 7,spection included

operators, technicians, and administrative personnel.

  • Attended the exit interview .

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E. Organization and Management Control - Radiation Control (83743)

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a. Organization, Staffing, and Qualifications

Technical Specification (TS) Section 6.1 details the organizational

structure, selected position responsibilities, and the reporting

chain of command for safety, safety policy, and radiation control at

the Georgia Institute of Technology Research Reactor (GTRR) facility.

The inspector reviewed and discussed, with cognizant licensee

personnel, the current staffing involved in conducting routine and

nonroutine radiation protection activities at.the GTRR facility. The f

inspec* r noted that the formerly vacant position of Manager, Office

of Rac.': tion Safety (MORS) has been filled. The licensee indicated

that the person who will be assigned to this position should begin  ;

work the first week in July. t

During a previous inspection, the inspector determined that the staff

performing health physics (HP) duties at the facility and reporting

to the MORS consisted of three full-time individuals (a Senior Safety

Engineering Assistant, a Research Scientist I, and a graduate

student) and two part-time student technicians. The licensee +

indicated that one of the full-time people had left the facility and

one of the part-time individuals had also quit. However, the

licensee was able to hire another part-time student technician and

now the staff consists of four individuals. The inspector noted that

the current staffing appeared to be adequate to conduct routine and

nonroutine radiation protection activities for the facility.

b. Nuclear Safeguards Committee

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TS Section 6.2 details the composition of the Nuclea- f afeguards

Committee (NSC), qualifications of its members, required

documentation of its responsibilities and authority, rules, and also

meeting frequency.

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The inspector discussed the composition of the NSC with the Associate

Director of the NNRC. The inspector verified that the various

members included personnel with a diversity of backgrounds as

specified in the TS. The licensee indicated that another member had

been added to the NSC.

The. inspector also reviewed the minutes of the meetings held by the

, NSC since the last inspection. The inspector verified that the group.

was functioning as outlined in the TS and that-issues reviewed and

discussed were' appropriate. These issues included procedure

revisions, experiments to be performed, the MORS position and a

replacement, radioactive waste generation and disposal, and unusual

events that occurred at the NNRC. The inspector also verified that

the meetings were being held even more frequently than required.

c. Audits

TS Section 6.2.e requires that the NSC audit- the safety aspets of

reactor facility operations in order to provide management with an l

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independent review of these aspects. This section also requires the

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NSC to review and approve proposed changes to procedures.

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l- The inspector reviewed the audit conducted by the NSC for the 1990 s

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calendar year. In the areas covered, the audit appeared to -be

L adequate and the aucitors found various discrepancies which were

l outlined for management attention. Because the audit. had only

recently been completed, the licensee had not had time to prepare

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responses to the audit findings. The . audit responses will be

reviewed during'a~ subsequent NRC inspection.  ;

d. Health Physics Procedure Revision and Review

The inspector discussed with cognizant 1 mensee personnel the status

of their program to review the MP procedures and have those in need

of revision revised and approved by the NSC. The inspector noted

that, since the last inspection at the facility, five new procedures

had been written and five others had been revised. The inspector

also noted that seven procedures were no longer used at the facility

but had not yet been deleted by the licensee and five still were in

need of revision. The licensee indicated that the procedure

governing the environmental monitoring , ogram and the procedure

outlining the method to obtain an exhaust stack grab sample and

perform the required analyses were in the process of being revised.

Therefore, only three procedures now remain which need to be revised

in the short term. The licensee indicated that a draft procedure had

been written to provide guidance in the area of transportation of

radioactive material but no final version was available to date.

No violations or deviations were ider;tified.

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3. ' External Exposure Review - Radiation Control (83743)

a. Exposure Control

10 CFR 20.101 delineates the quarterly radiation exposure limits to

'the whole body, skin of the whole body and the extremities for

. individuals in restricted areas.

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10 CFR 20.202 requires tha'. appropriate personnel monitoring devices -

be worn by personnel likely to receive exposure in excess of

25 percent of the limits specified in 10 CFR 20.101 or who enter i

high rad'ation areas.

T;ie inspector reviewed and discussed with licensee representatives

the exposure records for persons assigned to work at the NNRC for the

period from January 1,1990 through April 30, 1990. The licensee

uses film badges supplied by a National. Voluntary Laboratory  ;

Accreditation Program (NVLAP) approved vendor for measuring official

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dose. Vendor specifications reported a detection limit of.10 milli- -

rem (mrem) for the dosimetry supplied. The highest accumulated ,

individual-exposure for the year (through April) was 130 mre* The

highest accumulated individual exposure for the quarter (April) was ,

80 mrem. The licensee indicated that the majority of this exposure

was attributable to the handling of experiments.

During tours of the facility, the inspector observed personnel

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monitoring devices being worn as required,

b, Radiation Work Permit (RWP) Program

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The inspector reviewed selected RWPs used to date during 1990. The

RWPs dealt with various activities including experiment insertion and '

remcval, contaminated waste compaction, and core fuel rearrangement.

Through review and discussions with licensee representatives, the

. inspector determined that the RWPs used were appropriate to control

work, keep exposures as low as reasonable, and eliminate or control

contamination. The radiation protection requirements specified by

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the RWPs, including dosimetry, surveys, protective clothing, air

l' sampling, and HP coverage of the jobs, appeared to be adequate.

No violations or deviations were identified.

4. Internal Exposure Review - Radiation Control (83743)

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10 CFR 20.103 establishes the limits for exposure of individuals to

concentrations of radioactive materials in air in restricted areas.

o Section 20.103 also requires that suitable measurements of concentrations

L of radioactive material in air be performed to detect and evaluate the

L airborne radioactivity in restricted areas and that appropriate bioassays

E be performed to detect and assess individual intakes of radioactivity,

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a. Bioassay Program

The inspector reviewed selected results of the bioassay analyses that

had been performed to date during 1990. All the results had been

t reviewed by the individual assigned oversight responsibility, as well

p' as by the acting MORS. During that period the highest intake was

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' - calculated to have been 9.4 microcuries (uC1) of tritium. This

' exposure had occurred during compaction of contaminated waste. As a-

result of this exposure,1.56 Maximum Permissible Concentration-hours

(MPC-hrs) were assigned to the individual. The licensee indicated

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that MPC-hrs were not tracked formally but are tracked informally by

those-reviewing the results of the analyses.

[ b. Air Sampling

The inspector discussed the air sampling program with licensee

representatives. The program involves continuous air sampling

performed by air samplers located on top of the reactor and on the

main floor of the reactor building. The filters from eact of these

air samplers are changed weekly and analyzed to determ!ne the

concentration of alpha and beta-gamma radioactivity in the air. The

program also includes air sampling performed as requiret by RWP

during specific work evolutions.

The ' inspector reviewed the results of selected air sample analyses

since the last inspection. The results indicated that the airborne

concentration had seldom been above 25 percent of the MPC of the

radionuclides specified in 10 CFR 20, Appendix B. Table 1, Column 1.

When airborne activity exceeded such a concentration, decay counting

of the sample and/or isotopic analysis showed that the activity was

attributable to Radon. Airborne concentrations were generall'! in the

range of 1 E-11 to 1 E-12 microcuries per milliliter beta gamma and

lower for alpha.

No violations or deviations were identified.

5. Surveys, Posting and Contamination Control - Radiation Control (83743)

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a. Surveys

10 CFR 20.201(b) requires that the licensee perform such surveys as

may be necessary and are reasonable under the circumstances to

evaluate the extent of radiation hazards that may be present.

Licensee procedures, Procedure 9250, Facility Contamination Surveys,

Rev. 1, dated September 9, 1988 and Procedure 9304, Routine Facility

Radiation. Surveys, Rev. O, dated September 9, 1988, specify the

frequency and location of the surveys to be performed.

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The inspector reviewed selected records of daily, twice weekly, and

fortnightly contamination and radiation surveys performed in the

Reactor Control Zone (RCZ). The survey results were discussed with

licensee representatives. In general, the radiation and contamina-

tion survey results were below any action points specified by the

procedures. When action points were reached, as indicated by survey

results, actions were.taken to quickly resolve the problem. Resurvey

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resbits of the areas indicated that licensee actions had .been

effective.

The inspector also performed radiation level s;rveys of various areas

in the reactor building using ' NRC instrumentation. The inspector

verified the radiation levels indicated on licensee surveys,

No violations or deviations were identified.

b. Posting

-10 CFR 20.203 specifies the requirements for posting radiation areas,

-high radiation areas, and radioactive material areas.

Posting of entrances into the controlled area and labeling of

containers were observed and discussed with licensee representatives.

The, postings appeared to be adequate. The labeling of radioactive

material also appeared to be in compliance with the regulations.

10 CFR 20,203(c)(2) requires that each entrance or access point to a

L high radiation ar a shall be: (1) equipped with a control device

which shall cause the level o. radiation to be reduced below that at

which an individual might receive a dose of 100 mrem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> upon

entry into the area; or (ii) equipped with a control device which

shall energize a conspicuous visible or audible alarm signal in such j

a manner that the individual entering the high radiation area and the

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licensee or a supervisor of the activity are made aware of the entry *

or (iii) maintained locked except during periods when access to the i

area is required, with positive control over each individual entry.

During a tour of the containment building on June 13, the inspector

noted several areas that were posted as high radiation areas. Each

E of these areas had a door to the area that was locked except one.

This area was located on the main floor of the reactor containment

building adjacent to the biological shield. The area, which had

walls made of cement block stacked one on top of another, did not

have a roof or cover over the top and did not have a door at the

entrance. However, the entrance was blocked by three 4 x 4 foot, 1 I

inch thick pieces of polyethylene. Inside the area the licensee was

storing two graphite stringers which had been removed from one of the

horizontal beam ports in preparation for an experiment. Upon

performing a survey near the entrance of the area, the inspector

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roted levels to 50 millirem per hour (or/hr) at approximately

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18 inches from the sui face of the material. After completing an RWP  !

. to enter the high radiation area, a licensee representative and the

inspector performed radiation level surveys of the entire length of

the stringers. The stringers were found to have radiati levels of .

200 mr/hr at 18 inches from the surface of the stringers on the ends

that were closest to the reactor biological shield.

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, After being made aware of the problem, the licensee moved the-

stringers to a high radiation area with a de:- that _ locked and -

conducted an investigation to determine what had happened. A review

t- of the experiment authorization log indicated that the stringers had

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been in the unlocked area for approximately one week. The licensee

also determined that both operations and health physics (HP)

personnel had been present when the stringers were removed from the ,

beam port. The HP technician who had provided coverage for the

stringer removal had previously worked in a nuclear power plant. The

Technical Specifications for power plants stipulate that a high

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radiation area must be locked only when items inside have radiation

dose -rates in excess of 1,000 mr/hr. The individual was not aware

that a research reactor facility had lower criteria, i.e., 100 mr/hr,

for maintaining a high radiation area locked. The licensee informed

the person that items with radiation level readings in excess of ,

99 mr/hr needed to be placed in a locked high radiation area. The

licensee also considered installing some type of a door and locking

mechanism on the entrance to the bio-medical facility or room. This

facility is not currently used but is in close proximity to the beam

ports. This area could easily be used for the storage of stringers.

The inspector informed licensee representatives that the failure to

equip the entrance to a high radiation area with a control device

which would reduce the radiation level or energize an alarm signal,

or to maintain the entrance locked was an apparent violation of 10 7

L CFR 20.203(c)(2) requirements (50-160/90-02-01). '

One violation was identified,

c. Contamination Control

Technical Specification 6.4.b(6) requires written procedures to be

provided and utilized for radiation and contamination control.

L Procedure 9280, Personnel Monitoring, Revision 1, dated October 21,

L 1988, requires in Part 6.2.1 that, at the exit to the Reactor Control

Zone, hands and feet, at a minimum, shall be monito ed.

Following a tour of the Reactor Control Zone (RCZ) inclu ag the

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containment building on June 13, the inspectors werc performing a

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personal survey at the exit to the controlled area.

surveys were being completed, a maintenance worker was in the area,

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. on the controlled side of tie monitoring station, mopping the floor.

During this time frame, tht; inspector noted that the worker t ' the

mop, crossed over to the u teontrolled side of the monitoring st tion

without performing a persoial survey or having the mop surveyed, and ,

mopped the floor. The individual then crossed back to the controlled  !

area side of the monitori.ig station, proceeded out through a door -

into the RCZ and continued with his work. -

Af ter exiting the controlled area, the inspector brought this event

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to the attention of the licensee. In response to this problem, the

licensee counselled the worker that this was not an appropriate

practice and the individual was given instructions to perform < a

proper personal survey prior to leaving the controlled area. The

individual was also instructed not to take anything from the

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controlled area to the uncontrolled area without having it surveyed '

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by HP personnel. The areas on each side of .the monitoring station

were also surveyed and no contamination was detected. The surveys

that had.been performed at the station for the past six months were

reviewed by the inspector and it was determined that no contamination

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spread had occurred during that time period, The licensee indicated

that no spread of contamination due to such an incident had ever

occurred to anyone's knowledge.

The inspector reveiwed the training records for the worker involved'

and determined that he had received training to work in the RCZ but

this had been given in 1976. When asked whether or not the licensee

had a retraining program, the inspector was informed that no formal

retraining program existed. However, the licensee indicated that

individuals were given retraining, when required, on a case-by-case

basis. The licensee also indicated that it was difficult to get

maintenance people to work in the facility and that, although this

individual made an occasional mistake, he was one of the few willing

to work in the reactor building.

The inspector informed licensee representatives that failure of' an

individual to monitor at least the hands and feet was an apparent '

violation of TS 6.4.b(6) requirements. However,Section V.A of the

NRC Enforcement Policy states that, for isolated Severity Level V '

violations (those of minor safety significance), a notice of

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violation normally will not be issued regardless of who identifies

the violation provided that the licensee has initiated appropriate

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corrective action before the inspection encs. In such situations, a

i formal response from the licensee is not required and the inspection

H report serves to document the violations and the corrective actions.

' Af ter conferring with NRC management, the inspector determined that

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this NRC identified violation met those criteria and was not being '

cited (50/160/90-02-02).

One non-cited violation (NCV) was identified.

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6. Environmental Protection (80745B)

10 CFR 20.106(a) reouires that the licensee not possess, use, or transfer

- licensed material so as to release to an unrestricted area radioactive

material in concentrations which exceed the limits specified in 10 CfR 20,

Appendix B. Table II, except as authorized pursuant to 20.302 ar

20.106(b).

Technical Specification (TS) 6.7 a requires an annual operating report

covering the previous year to be submitted to the Of fice of the Regional

Administrator, Region II, with a copy to the Director, Office of. Nuclear

Reactor Regulation, by March 1 of each year. TS_6.7.a(6) requires a

statement of the quantities of radioactive effluents released from the

plant, with data summarized following the general format of : Regulatory

Guide 1.21. TS 6.7.a.(7) requires the licensee to provide estimates of

the likely resultant exposure to individuals and population groups and

assumptions upon which estimates are based, if levels of radioactive

materials in the environment, as determined by an environmental monitoring

program, indicate the likelihood of public intakes in excess of one

percent of those that could result from continuous exposure to the.

concentration values listed in Appendix B, Table II, 10 CFR 20.

The inspectors reviewed the licensee's Annual Operating Report covering

the period of January 1,1989, through December 31, 1989, to ascertain

whether. releases of liquid and gaseous radioactive material to the

environment were within regulatory requirements. The licensee's only

measurable gaseous waste release was Argon-41. The following table

summarizes the amount of Ar-41 released during 1989:

Average Release Max. Instantaneous

Total Concentration Release Rate  % Tech

Quarter Release (Ci) (uCi/cc) (uCi/sec) Specs *

1 9.683 9.85E-8 152 26.0%

2 16.259 1.65E-7 171 29.2%

3 1.100 1.12E-8 95 16.2%

4 0.744 7.57E-9 76 13.0%

  • TS 3.5.b.(1) maximum instantaneous release rate limit equals

585 uCi/sec.

There were no measurable amounts of gaseous tritium, iodine, or

particulates reported.

The predominant nuclides released via the licensee's liquid effluent

pathway included tritium and Cobalt-60. It should be noted that the Co-60

did not result from reactor operations, but was attributable to the Co-60

source storage pool facility which was under the State of Georgia

Radioactive Materials License No.147-1. There were no fission products

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released .via . the liquid effluent pathway. In addition, there were no.

mearnvable quantities of dissolved and entrained gases nor gross alpha

ra r - " tvity reported. The quantities of radioactive material released

via a+ .1 quid effluent pathway are'sumamrized below:

Nuclide - Co-60

. Quarter 1 2 3 4

Total Release (C1) 0.018 0.019 0.029 0.025

Average Release  !

Concentration * (uC1/cc) 9.20E-11 9.57E-11 1.44E-10 1.27E-10

% Tech. Specs. < 1% < 1% < 1% < 1%

Nuclide - H-3

Quarter 1 2 3 4

Total Release (C1) 2.282 3.870 5.101 2.769

Average Release

Concentration * (uC1/cc) 1.15E-8 1.94E-8 2.56E-8 1.39E-8 i

% Tech. Specs. < 1% < 1% < 1% < 1%  ;

Average release values were based on a Georgia Tech campus water ,

discharge rate of 1.99E11 cc/ quarter.

As noted above, neither the gaseous releases nor liquid releases exceeded

any technical specification limit and thus were well within the limits

prescribed by 10 CFR 20.106.

The inspectors also reviewed the licensee's methods of effluent ,

monitoring anu verified that effluents were measured adequately and that

records required by TS were complete and adequate. The inspectors

observed that the licensee was - still evaluating various methods of *

obtaining a respresentative stack sample in order to identify and quantify ,

airborne radionuclides being released from the plant process vent. This ,

issue was discussed in NRC Inspection Report No. 50-160/88-02 and 89-03 l

and was identified as an Inspector Followup Item (IFI): 50-160/88-02-08.

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Presently, the IFI remains open. Once the samples were collected,

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however, the licensee had the means to adequately identify and quantify

the radionuclides in the sample. The inspectors reviewed gaseous waste

release records from June 21, 1989 through April 18, 1990. Based on a i

review of selected grab sample analyses, no other nuclides in addition to

Ar-41 were released via the gaseous effluent pathway. In addition, the

inspectors -eseiwed liquid waste release permits from January 1,1990 to

May 7, 1990. ?he only measurable quantities of radionuclides released via

this pathway were Co-60 and H-3.

During the rev ew of the liquid waste release records, the inspectors also

reviewed Radiological Incident No. 90-01 which described water accumula-

tion in the lower levels of the reactor building. The source of the water

was from the Co-60 storage source pool which overflowed during the time

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period January 26-29, 1990 via an overflow pipe to the waste tank farm f

room. The incident report described the licensee's method for sampling

and ultimately pumping the water to the-sanitary sewer. After a review of  ;

the ' incident report, the inspectors . determined that the licensee ,

adequately sampled, identified, and quantified the amount of Co-60 in the ,

overflow water from the source storage pool before it was released. The

licensee took appropriate corrective action by installing a device which .

automatically limits the time of operation of the faucet used to fill the i

source storage pool. The inspectors had no further cuestions.

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The_ inspectors also reviewed the licensee's environmental monitoring .  :

program including procedure 9400, " Environmental Monitoring" (undated) and ,

the data provided in the 1989 Annual Operating Report. The inspectors

observed that the licensee had identified the need to revise  ;

Procedure 9400, however, the revision had not been completed. The

environmental parameter monitored for the Georgia Tech Research Reactor i

operations was that of direct radiation from the facility and from gaseous

effluents via a system of 30 film badges around the perimeter fence and

other similar locations. The film badge used for environmental monitoring

typically has a lower sensitivity of 10 mrem. Of the 30 film badge

stations, none showed activity above background due to reactor operations.  ;

The inspectors noted that the licensee performed a study on the adequacy ,

of the environmental monitoring program. Basically, the conclusion of the ,

study was that the present program was adequate to meet TS requirements.

This study did not, however, consider program. adequacy with respect to the

proposed radionuclide emission amendments to the Environmental Protection

' Agency's (EPA's) Clean Air Act. Under the amendments, the EPA is

proposing that radionuclide emissions from NRC licensees, including >

research reactors, shall not cause any individual to receive a dose

greater than ten millirem per year (mrem /yr). Emissions from this source

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category are presently covered by 40 CFR 190 which mandates that emissions

do. not cause any individual to receive a whole body dose of more than .

25 mrem /yr or receive a dose of 75 mrem /yr to any organ. The inspectors

discussed with the licensee the possibility ' of using thermolumiscent -

dosimeters (TLDs) for environmental monitoring purposes. Depending on the

TLD Phosphor used and the characteristics of the photomultiplier tube

used, the lower sensitivity limits have been reported to be from one mrem

to 0.5 mrem.

i No violations or deviations were identified.

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7. Action on Previous Inspection Findings (92701)

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a, (0 pen) Inspector Followup Item (IFI) 89-03-01 Followup on

the Development of a Procedure for the Shipment of Radioactive

Materials,

,

During a previous inspection, the licensee had agreed to evaluate the

l need for a shipping procedure. Although a draf t procedure had been

prepared, no final procedure was yet available for NSC review and

,

n; . n

L . . L

, i

-

,

11 .

!

y

approval: This item will remain open pending review, approval, and '

implementation of the procedure. j

'

b. (0 pen) IFI 90-01-01: Followup on the Revision of Procedure 9017,

Stack Grab Sample Analysis.

i

The inspector discussed the stack sampling process with licensee

representatives including those who actually climb the stack to

obtain the samole. The inspector also watched e demonstration of how  ;

the sample is currently obtained. This IFI wil remain open until a  ;

revised procedure is reviewed and approved by the NSC and implemented -

by the. licensee. *

1

'

8. Exit Interview (30703)

'

The inspection scope and results were summarized on June 14,1990, with

those persons' indicated in Paragraph I above. The inspector discussed the

findings for each area reviewed. The adequacy of the licensee's

organization and staffing in radiation protection was discussed. Internal

and external exposure controls employed by the licensee apparently hsve

been effective in maintaining exposures as low as practicable. Posting,

surveys and labeling of radioactive material throughout the facility

appeared to be adequate. The. apparent violation' concerning an unlocked

high radiation ' area and the non-cited violation concerning failure to i

perform a personal survey at the exit to the RCZ we're discussed. The

licensee did not identify as proprietary any of the material provided to

.

'

or reivewed by the inspector during this inspection.

Item Number Description and Reference

50-160/90-02-01 Violation - Failure to maintain a high

radiation area acceptably controlled

as required by 10 CFR 20.203(c)(2).

(Paragraph 5). -

50-160/90-02-02 NCV - Failure to perform a personal survey

at the exit to a controlled area.

(Paragraph 5).

Licensee management was informed that the two IFIs discussed in

Paragraph 7 would remain open and would be reviewed during a subsequent

inspection.

.

. _ . .