ML20057A081
| ML20057A081 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 09/01/1993 |
| From: | Cox C, Mccormickbarge NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057A079 | List: |
| References | |
| 50-002-93-04, 50-2-93-4, NUDOCS 9309130018 | |
| Download: ML20057A081 (10) | |
See also: IR 05000002/1993004
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
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Report No. 50-002/93004(DRSS)
Docket No.50-002
License No. R-28
Licensee: University of Michigan
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Facility Name:
Ford Nuclear Reactor
Inspection At:
Phoenix Memorial Laboratory, Ann Arbor, Michigan
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Inspection Conducted: August 9-13, 1993
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Inspectors:
S. Orth
T. Reidinger
C. McKinney
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Approved By:
. Cox, Team LeaW v '
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Date
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Approved By:
J. W. McCormick-Barger, Chief
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Non-Power Reactor Section
Inspection Summary
Inspection on Auaust 9-13. 1993 (Report No. 50-002/93004fDRSS))
Areas Inspected: Routine, announced team inspection to review actions on:
organization, logs, and records (Inspection Procedure (IP) 39745); review and
audit functions (IP 40745); requalification training (IP 41745); procedures
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(IP 42745); surveillance (IP 61745); experiments (IP 69745); transportation
activities (IP 86740); fuel handling activities (IP 60745); emergency planning
(IP 82745); radiation controls (IP 83743); environmental protection (IP 80745); licensee action on previous inspection findings (IP 92701); licensee
event reports (IP 92700); and periodic and special reports (IP 90713).
Results: One violation was identified involving two cases of not following
health physics procedures requiring use of a National Bureau of Standards
(NBS) traceable calibration sources for health physics surveillances (Section
13). One Inspection Follow-up Item (IFI) was identified concerning review of
environmental monitoring data to determine if a correction to the 1991 and
1992 annual report is required (Section 16). One Unresolved Item (UI) was
identified concerning the environmental impact of a release of radioactive
water to the drain tile around the facility building (Section 4). One UI was
closed regarding maintaining a Senior Reactor Operator license current.
Two
violations were closed regarding the overpower event in March 1993
(Section 3).
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9309130018 93o901
ADOCK 05000002 J4
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DETAILS
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Persons Contacted
University of Michioan
- W. C. Kelly, Vice President for Research
- R. Burn, Nuclear Reactor Laboratory Manager
- B. DuCamp, Assistant Manager for Reactor Operations
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- P. Simpson, Assistant Manager, Research Support Activities
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- M. Driscoll, Radiological Safety Officer
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- C. Schneider, Health Physics Technician
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- Denotes those attending the exit meeting on August 13, 1993.
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2.
General
This inspection was conducted to examine the research reactor program at
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the University of Michigan. The reactor operated on a biweekly cycle,
shutting down on Friday for refueling and/or maintenance outages and
restarting on Wednesday for a ten day run. The facility was used
primarily for irradiation services and research activities.
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During the course of the inspection, the inspectors observed routine
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operations including several control room shift turnovers, removal of
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experiments from the core, shim-safety rod inspections, rod drop time
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measurements, fuel loading, and routine health physics surveys.
The
operators and health physics technician appeared proficient and
knowledgeable, demonstrated good procedural compliance, and made
appropriate log entries for the observed evolutions. The general
housekeeping of the facility was adequate.
No violations or deviations were identified.
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3.
Action on Previous Inspection Items (IP 92701)
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a.
(Closed) Unresolved item (50-002/93002-04): Maintaining Senior
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Reactor Operator (SRO) licenses current. This unresolved item
concerned the applicability of counting time on watch by SR0s,
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performing Reactor Operator (RO) duties, towards, maintenance of an
SR0 license under Chapter 10 Code of Federal Regulations (CFR)
Part 55.53(e). A review by the Office of Nuclear Reactor
Regulation (NRR) maintained that the requirements for an SR0 in 10
CFR 55.53(e) could only be met by an SR0 standing watch four hours
per quarter performing the duties of an SRO.
At the time of the reactive team inspection on March 25-26, 1993,
the facility assumed that SR0s on rotating shifts would
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automatically accrue enough control room time to maintain their
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license current regardless if the time was spent as an SR0 or R0.
So, the facility did not differentiate the time spent as an SR0
versus an R0 in its tracking, and subsequently, the facility
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could not readily ascertain that all their SR0s held current
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licenses. When the issue was raised on March 26, 1993, the
licensee voluntarily suspended operations. The facility then
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determined that three SR0s held current licenses since they
received their licenses in February 1993. The facility arranged
for those three SR0s to start-up the reactor and brought the
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remaining SR0s current by having each stand watch under
instruction for six hours per 10 CFR 55.53(f)(2).
Finally, the-
facility revised their requalification program logs- to track SR0
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watch time independently of R0 watch time. A review of the
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requalification records during the routine inspection on August 9-
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13, 1993, indicated that all SR0 and R0 licenses were current.
Absent of a specific case of a licensed operator standing watch
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with a license not maintained current, this unresolved item is
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closed.
b.
(Closed) Violation (50-002/93002-1): Operation of the FNR at
power levels in excess of two megawatts (thermal). The SR0
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involved was permanently removed from licensed duties, and
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operating procedures were revised. All operators passed
unannounced oral and written examinations, demonstrating their
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knowledge level regarding power indications. Management
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expectations regarding procedure review and use were documentei in
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a memorandum from Dr. Fleming. A nuclear utility was contacted
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and agreed to assist the University of Michigan in a review of
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operations and human factors for procedures. The completed
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corrective actions were found to be adequate. The assistance from
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the nuclear utility will be an ongoing process.
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c.
(Closed) Violation (50-002/93002-2a and 2b):
Failure to follow
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two steps of Operating Procedure Number 101. The licensee's
corrective actions for this violation were the same for Violation
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(50-002/93002-01), which were found to be adequate.
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4.
Licensee Event Reports (IP 92700)
(0 pen) Reportable Occurrence No,18:
Release of Low Level Radioactive
Water from the Ford Nuclear Reactor Building to Drain Tiles Around the
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Foundation of the Building.
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As the result of a routine pool water inventory surveillance conducted
on April 27, 1993, the licensee determined that pool water inventory had
increased approximately 200 gallons. The surveillance was repeated on
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June 16, 1993, and the same inventory increase was noted. An
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investigation revealed that a check valve in the cold sump discharge
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line was allowing back-leakage. That back-leakage water was counted
twice in the surveillance and resulted in an apparent increase in
inventory.
Prior to scheduled replacement, the cold sump pump was
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tagged out of service on June 23, 1993, and the discharge line to the
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retention tank was secured. Overflow from the cold sump was expected to
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pass to the hot sump through a cross connect line. Another pool water
surveillance was conducted on July 21, 1993 with the new line-up, which
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indicated an apparent net loss of 640 gallons of pool water. After
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reviewing the surveillance for possible errors, the licensee returned
the cold sump to its normal line-up on July 30, 1993, suspecting the
change in line-up to be the cause of the pool inventory loss.
Further
review of drawings of the building and experiments were conducted to
determine the cause of the water loss. The reviews indicated that a
drain line, appearing in the original construction drawings for the
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laboratory dated 1955, from the drain tiles surrounding the building was
the release path. Apparently when the sump level reached the height of
the cross connect line to the hot sump, the water level was sufficient
to flow out through the drain line into the drain tiles surrounding the
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building.
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As a result of securing the cold sump pump, approximately 7500 gallons
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of low level radioactive water was discharged to the drain tile
currounding the reactor and Phoenix Memorial Laboratory buildings during
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the period from June 23 to July 30, 1993.
Sump water samples were taken
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and counted for radioactivity.
Several isotopes were found that
exceeded the allowable release concentrations to unrestricted areas per
10 CFR 20.106. Because of the release locations (approximately 30 feet
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underground) and the nature of the isotopes detected in the sump sample,
it did not appear to pose an immediate, direct threat to the general
public. However, pending a pathway analysis of the release, as
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described in 10 CFR 20.302(a), and a review of the results of
environmental sampling, the release of radioactive material to an
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unrestricted area will be tracked as an unresolved item (Unresolved Item
No. 50-002/93004-01).
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5.
Oraanization. Loos. and Records (IP 39745)
A new Assistant Manager for Operations (AMO) was hired in May 1993.
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current AMO was still assigned to the facility and will retire in
October 1993, after a two week turn-over to the new AMO.
The new AMO
held a degree in electrical engineering and was the operations
supervisor at the FNR in the early 1980's.
He also had several years
experience as a design engineer in the power reactor field.
The organization was verified to be consistent with the Technical
Specifications (TS) and Safety Analysis Report (SAR).
The minimum
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staffing requirements were verified to be met during reactor operations,
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fuel handling, and refueling operations by actual observation and log
reviews. Selected reactor operator logs for 1993 were reviewed.
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No violations or deviations were identified.
6.
Reviews and Audits (IP 40750)
The Safety Review Committee (SRC) meeting minutes were reviewed for
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1993. The SRC met more frequently than on the semi-annual basis
required by TS. No experiments or modification packages were reviewed
by the SRC since the January 1993 inspection.
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The inspectors reviewed two independent external audits of the facility
operations and one of the facility health physics program. The scope of
the audits were excellent and reflected the guidelines of the
International Atomic Energy Agency. Auditors were experienced reactor
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managers at other non-power reactor facilities. The audits were well
documented; audit findings and the responses to those findings were
appropriate. The revised Maintenance Procedure MP-102 " Quality
Assurance Audits" was used to define the scope of the 1993 external
audit.
No violations or deviations were identified.
7.
Recualification Trainina (IP 41745)
The inspectors reviewed procedures, logs, and training records and
interviewed personnel to verify that the requalification training
program was being carried out in conformance with the facility's
approved plan and NRC regulations. The inspectors noted that paragraph
5.3 in the approved requalification plan was not in agreement with 10
CFR 55.53. The plan allowed a four month period for maintaining an
operator license current while 10 CFR 55.53 required a three month
period. However, the licensee was tracking operator time on a three
month basis as per 10 CFR 55.53. The licensee acknowledged the
discrepancy and committed to change paragraph 5.3 in their
requalification plan. The licensee also agreed to clarify paragraph 5.3
to include the requirement of 10 CFR 55.53 which states that an operator
who has exceeded the three month period, stand a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> watch under
instruction to bring the operator license back to current status.
The annual requalification written examinations were very thorough and
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comprehensive, and the content and scope varied from the previous
examinations. The oral and emergency procedure examinations were
effective in evaluating licensed operator knowledge, skills, and
abilities. An improvement was noted in the training program.
The
facility had recently initiated a monthly requalification training
program.
Selected topic areas were expected to be reviewed by the
operators prior to taking a short written examination. The results of
the examinations would then be reviewed by management with the operator.
No violations or deviations were identified.
8.
Procedures (IP 42745)
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The inspectors determined that the required procedures were available to
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the operators and the contents of selected procedures appeared adequate.
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Procedure changes were reviewed and approved by the SRC.
The facility
procedures were currently undergoing a human factors review with the
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assistance of a nuclear utility.
No violations or deviations were identified.
9.
Surveillance (IP 61745)
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Shim-safety rod inspection and rod drop time surveillances were observed
by the inspectors.
Reviews of selected maintenance records, calibration
records, and other surveillance records detected no deficiencies.
However, the inspectors noted that the format of surveillance forms were
inconsistent. While some forms had acceptance criteria and/or
management signature review dates, others did not. Additionally, data
was recorded both in pencil and ink, without any consistency. The
inspectors noted that other permanent records were consistently kept in
ink.
No violations or deviations were identified.
10.
Exoeriments (IP 69745)
The inspectors observed the insertion of several experimental samples
into the core and reviewed the various experiment records, documenting
the specific exposure times for the experiments. No discrepancies were
noted.
No violations or deviations were identified.
11.
Fuel Handlina (IP 60745)
A core load was observed by the inspectors. Communications were very
formal and procedures were followed. No discrepancies were noted.
No violations or deviations were identified.
12.
Emeroency Plannino (IP 82745)
The licensee's emergency organization remained unchanged since the last
inspection. Annual training was scheduled as part of the operator
requalification program.
Emergency equipment inventories were completed
semi-annually.
No violations or deviations were identified.
13.
Radiation Control (IP 83743)
The Ford Reactor radiation control program remained as described in
Inspection Report No. 50-002/91004(DRSS).
Posting, labeling and surveys
were reviewed during tours of the facility with no problems noted. Area
radiation monitors and portable instrument calibration records were
reviewed. The portable Rem-ball used for area neutron surveys was
calibrated using a plutonium-beryllium (PuBe) neutron source. Although
this source emitted neutrons in the range of only a few MeV and the
energy of the neutrons emitted from the reactor was in the range of
10-100 kev, confirmatory measurements indicated that the instrument
responded appropriately and conservatively in the reactor fluence.
The inspectors reviewed the semi-annual pool water surveillance. This
surveillance was initiated in 1989 to calculate the pool water leak
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rate, assess any changes, and ensure that all pool water leakage was
being collected. This surveillance was instrumental in detecting the
release noted in Reportable Occurrence No.18 in Section 4 of this
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report and led to the detection of increased pool water leakage due to
degradation around the pneumatic tube penetration used for neutron
activation analysis.
The facility was in the process of evaluating
methods to replace the pneumatic tube system and secure that leak path.
Contamination surveys completed using the revised HP-101 " Facility
Contamination Survey" were reviewed. The inspectors noted that only
very low levels of contaminations have been detected and that the gas
proportional counter used to count the surveys was properly calibrated.
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The inspectors also noted several examples of poor contamination control
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practices. Operators were observed to use either no or torn latex
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gloves when handling tools from the reactor pool, occasionally touch
uncontaminated portions of their body with gloved hands, and bypass the
hand and foot counter when exiting the pool floor.
The practice of
removing protective gloves and washing hands prior to using the hand and
foot monitors was of particular concern, because facility policy only
required a whole body frisk if contamination was detected with the hand
and foot monitors. Thus, contamination to other parts of the body could
remain undetected. The licensee acknowledged the concern and will
review their contamination control practices.
The inspectors observed the collection of a pool water sample by the
technician. Good contamination control practices and good coordination
with control room personnel was demonstrated. The inspectors also
observed the counting of pool water samples and reviewed the calibration
of the germanium detector used to count the samples. The inspectors
noted that the certified National Institute of Standards and Technology
(NIST) calibration standard used in this analysis had expired in January
1993.
Because long lived radionuclides contained in the standard had
not significantly decayed, the licensee informally extended the life of
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the standard. However, the licensee did not perform an adequate safety
review to verify the stability of the calibration standard's media and
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the adequacy of the calibration curve based on the limited number of
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nuclides. The inspectors also noted that the calibration standard used
in the gaseous activity detector (GAD) calibration was not traceable to
the National Bureau of Standards (NBS) or, presently, NIST. The
calibration standard was prepared in 1982 from an aqueous cobalt-60
solution contained in a syringe and was originally quantified using a
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lithium drifted germanium detector in 1982. The results of this
analysis were used without any additional analysis or program to verify
the stability of the standard, i.e. leakage, evaporation, or chemical
stability.
The cobalt-60 standard was used to calibrate the licensee's
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Capintec ionization chamber which was used to quantify the argon-41 used
in the GAD calibration.
The licensee's Technical Specifications require the isotopic analyses of
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the reactor pool water and the calibration of the gaseous activity
monitor in sections 4.4 and 4.5, respectively, and require the licensee
to follow radiation protection procedures in section 6.4.
The
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licensee's procedure HP-105, "FNR Pool Water Analyses", Revision 4,
November 20, 1989, required the use of an NBS traceable standard to
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calibrate the germanium detector.
Procedure HP-210, "Capintec
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Ionization Chamber Calibration Procedure", Revision 2, July 21,1988,
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required that the Capintec detector be calibrated against an NBS
traceable standard prior to its use in the GAD calibration.
Failure to
calibrate the detectors used in the pool water and gaseous effluents
analyses with NBS traceable standards in accordance with procedures HP-
105 and HP-210 is a violation of the Technical Specifications (Violation
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No. 002/93004-02).
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External dose records were reviewed with respect to the requirements of
10 CFR Part 20. The Operations group continued to have the highest
radiation doses with several operators accruing over 1 Rem (10
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milliSieverts (mSv)) of whole body dose in 1992. All doses were within
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10 CFR Part 20 limits.
One violation was identified.
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Environmental Protection (IP 80745)
a.
Liouid Effluents
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The licensee adopted a zero discharge policy so there were no
planned liquid discharges for 1993.
However, an unplanned
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discharge occurred as described in section 4 of this report.
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b.
Airborne Effluents
The licensee continued to discharge airborne effluents through FNR
stack No. 2 and the reactor building ventilation system.
The
inspector reviewed the calibration of the GAD and the moving air
particulate detectors. A violation was identified (section 13)
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with respect to the calibration of the GAD.
The inspectors identified additional concerns regarding the
material condition of the air samplers and the stack flow
measurement. An inspector observed the replacement of several
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charcoal and particulate filters and noted degraded o-rings in the
sampling train, pump malfunctions, and the lack of calibration of
the volume meters. Also, the inspector toured several
environmental monitoring stations and observed similar concerns,
including missing o-rings and loose sample trains. The licensee
acknowledged the inspector's observations and agreed that
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additional quality control of the sampling equipment was
warranted.
The inspectors noted that the stack flows had not been measured
since November 1988, contrary to procedure HP-215, " Stack Air
Flow Evaluation", Revision 1, December 8,1988, which stated that
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the stack flow evaluation frequency should be annual. The
licensee acknowledged that this measurement was necessary to
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ensure the accuracy of the evaluation of the concentration of
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airborne effluents released and agreed to reevaluate the air flow
and to review past calculations based on the present flow rates.
The inspectors reviewed the licensee's calculations for 1991 to
present and no problems were noted. Applying the 400 dilution
factor, the calculated concentrations were below the limits
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contained in the TS.
No violations or deviations were identified.
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15.
Transportation Activities (IP 86740)
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The inspectors reviewed the licensee's spent fuel shipping program for
compliance with the requirements in Department of Transportation (DOT)
and NRC regulations, 49 CFR Parts 172 & 173 and 10 CFR Part 71,
respectively.
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Byproduct material was transferred from the byproduct and reactor
licenses only to valid NRC or Agreement State licensees.
The inspectors
reviewed the shipping records. No discrepancies were noted.
No violations or deviations were identified.
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16.
Review of Periodic and Special Reports (IP 90713)
The inspectors reviewed the 1992 and 1993 annual report for timeliness
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of submittal and adequacy of information submitted. The annual report
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was submitted in a timely manner and contained the information required
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by TS. However, the environmental monitoring section of the 1991 and
1992 annual reports contained several anomalies in the thermoluminescent
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dosimeter (TLD) data tables.
In 1991, the control TLD was reported as
having an annual dose of 235 mrem (2.5 mSv), which was significantly
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higher than any other TLD.
In 1992, the inspectors noted a large
discrepancy between the doses reported for the two background TLDs;
locations one and two were reported as accumulating 198 and
99 mrem (1.98 and 0.99 mSv), respectively. The inspectors discussed
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these anomalies with a licensee representative who initiated a review of
the vendor data for those periods. The licensee agreed to fully
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evaluate the TLD data for 1991 and 1992, to measure the flow through the
effluent stacks (Section 14.b) and, if necessary, to submit changes
necessary to correct data in the annual report.
Review of these
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activities will be tracked as an Inspection followup Item (IFI No.
002/93004-03).
No violations or deviations were identified; however, one inspection
followup item was identified.
17.
Exit Interview (IP 30703)
The inspectors met with the licensee representatives denoted in
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Paragraph I at the conclusion of the inspection on August 13, 1993. The
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inspectors summarized the scope and results of the inspection and
discussed the likely content of this inspection report. The licensee
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acknowledged the information and did not indicate that any of the
information disclosed during the inspection could be considered
proprietary in nature.
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