IR 05000062/1993004
| ML20058P769 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 12/02/1993 |
| From: | Bassett C, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P766 | List: |
| References | |
| 50-062-93-04, 50-62-93-4, NUDOCS 9312270265 | |
| Download: ML20058P769 (13) | |
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UNITED STATES
-[psic% o i NUCLEAR REGULATORY COMMISSION '
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Report No.: 50-62/93-04 Licensee: University of Virginia Charlottesville, VA 22901 Docket No.: 50-62 License No.: R-66 Facility Name: University of Virginia Reactor (UVAR)
Inspection Conducted: November 1-4, 1993 ,
Inspector: 8NN h O \ ,rx c ll[2. b 3 C. H. Bassett '/ Date Signed ,
Approved by: MM bf atw E. J. McAlpine, Chief \
12 [7 Date Signed
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Radiation Safety Projects Section i Nuclear Material Safety and Safeguards Branch Division of Radiation Safety and Safeguards ,
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SUMMARY Scope:
This routine, announced inspection _ involved onsite review of radiation protection program activities including, radiation control, environmental surveillance and monitoring, and transportation of radioactive material; and review of specific portions of reactor operation Results: .,
The staffing level and current organizational structure were adequate to meet Technical Specification. (TS) requirements and to implement the licensee's radiation protection program. Facility contamination levels and-radiation i exposure to individuals were within the local administrative levels and '
exposures were well within federal regulatory limits. The environmental monitoring program appeared to be adequate to meet TS requirements. The reactor operations were being conducted by procedure.and the surveillances -
were being conducted in a timely manne .
Within the areas inspected, two non-cited violation (NCVs) were identifie The NCVs dealt with failure to-adhere to procedures for collecting and '
analyzing environmental air and water samples and failure to obtain the_
approval of the Reactor Health Physicist before releasing water from the pond 3
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near the facilit i 9312270265 931202 PDR O ADDCK 05000062 PDR I
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REPORT DETAILS
, Persons Contacted Licensee Employees
- P. Benneche, Services Manager 5
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- P. Farrar, Reactor Administrator l *R. Flack, Acting Chairman, Department of Mechanical, Aerospace, and Nuclear Engineering (MANE)
- R. Mulder, Director, University of Virginia Reactor Facility Other licensee employees contacted during this inspection included operators, technicians, and administrative personne +
Other Organizations
- J. Gilchrist, Deputy, University of Virginia (UVA) Environmental Health and Safety (EHS) Department
- R. Piccolo, Radiation Safety Officer, UVA EHS Department
- D. Steva, Reactor Health Physicist, UVA EHS Department
- Attended Exit Interview Radiation Control (83743) Organization and Staffing Technical Specification (TS) Sections 6.1.1, 6.1.2, and 6.1.3 detail organizational structure, management responsibility, and staffing requirements for safe operation of the UVAR facilit Through discussions with licensee representatives the inspector determined that management responsibilities at the facility had not changed since the previous NRC inspection of radiation protection activities in July 1992 (Inspection Report No. 50-62/92-01). The inspector determined that the Acting MANE Department Chairman retained overall responsibility for management of the facility as specified in the T The inspector reviewed, with cognizant licensee representatives, the current staffing available to conduct routine and nonroutine radiation protection activities at the facility. The licensee currently has five licensed senior reactor operators (SR0s) and one licensed reactor operator (RO) who perform various radiation protection activities at the facility. One SRO'and one R0 are assigned the responsibility of performing the routine daily and weekly radiation level and contamination level surveys that are :
required by the licensee's Standard Operating Procedures (S0Ps).
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The other SR0s are responsible for self-monitoring as well as I
decontamination of areas found to be contaminated during routine surveys.
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The inspector noted that the UVA EHS Reactor Health Physicist (RHP)
has responsibility for and oversight of the radiological safety '
program at the facility. The Radiation Safety Officer (RS0) also shares in this responsibility. The RHP and RSO are assisted by two UVA EHS radiation safety technicians who have been trained in the- *
performing the required surveys and have become familiar with the reactor facility. These technicians perform the monthly surveys o ,
the reactor facility, including the environmental surveys, and
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provide support for nonroutine. work activities and for shipping radioactive material as neede The inspector noted that the organization and staffing levels, including the UVAR operations and UVA EHS Department personnel, -
appeared to be adequate to conduct routine and nonroutine radiation protection activities for the facilit b. Audits and Management Evaluations
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TS 6.2 requires the Reactor Safety Committee (RSC) to review and audit reactor operations to ensure that the facility is operated in '
a manner consistent with public safety and within the terms of the facility license. TS 6.2.2 and 6.2.3 detail RSC membership and '
qualifications, and meeting and audit frequency. The RSC is required to meet, at a minimum, semiannually, to approve untried :
experiments, changes to the reactor, amendments and changes to the i facility license, TS and SOPS, to review reportable events and ;
operating abnormalities, and to conduct annual audits of operational record The inspector reviewed the composition of the RSC with the license The inspector determined that the composition of the RSC was as ,
prescribed in the TS and that the members had the appropriate I technical backgrounds as required. One member with a background in electronics had been added since the last inspectio ;
The inspector also reviewed the minutes of the RSC meetings held since the last inspection, from September 1992 through October 199 ,
The inspector noted that, during this time period, the RSC met 1 sixteen times. The meeting minutes indicated that the issues !
discussed and reviewed during RSC meetings included such issues-as irradiation requests, TS changes, Standard Operating Procedures- j (S0P) changes, 50.59 reviews, conversion of the reactor to the use I of Low Enriched Uranium (LEU) fuel, abnormal events, waste releases, the' annual RSC audit, NRC inspection results, and fuel movement / core reconfiguration The inspector also reviewed the audits that had been conducted by the RSC during 1992 and 1993. One biennial audit, scheduled for April - September but conducted in December 1992, reviewed the Emergency Plan (EP), Health Physics (HP) records, and the Security Plan and records. No major problems were noted but several recommendations were made on ways to improve the EP, the HP records, i
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and the security records. Another audit, from October-1992 through March 1993, consisted of a review of the reactor logbook, the !
maintenance and calibration logs, the irradiation request forms, and- !
the daily and hourly checklists used by the reactor operator !
Again, no major problems were noted but various recommendations were made. The licensee's response to this audit appeared to be adequate. Another audit was scheduled for November 8-12, 1993, in the areas of emergency procedures, the quality assurance program, and the entire training program. This audit will be reviewed during a subsequent inspectio c. Training 10 CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portion of the restricted area in health physics protection problems associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, in the purposes and functions of protective devices employed; also, to instruct them to observe the applicable provisions of Commission regulations, to instruct them in their responsibility to report problems, in the appropriate response to warnings in the event of problems and in the availability of !
radiation exposure reports which workers may request pursuant to 10 CFR 19.1 The inspector discussed, with cognizant licensee representatives, the training provided to personnel frequenting the UVAR facilit The licensee indicated that, excluding visitors touring the facility, persons spending appreciable time in the restricted area included operators, experimenters, students, and UVA EHS personne The licensee also indicated that only those persons who had received the appropriate training and who had been badged and received _a i dosimeter were allowed unsupervised access to restricted areas of a the facilit Personnel who handled radioactive material within the i facility were provided training by UVA EHS personne The inspector reviewed the training given to those persons who were -
given unescorted access. The training was given and/or renewed .4 annually and consisted of security, emergency, implementing i procedures, and health physics subjects pertinent to the facilit '
The inspector also reviewed the training given to those who handled radioactive material and the training given to Department of ;
Facilities Management personnel who had worked on a renovation
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project at the facility. The training given to these groups of individuals appeared to be adequate and covered the subjects outlined in 10 CFR 19.1 Facility Tours - Posting of Notices 10 CFR 19.11 requires each licensee to conspicuously post current copies of (1) 10 CFR Parts 19 and 20, (2) the license, (3) operating '
procedures, and (4) Form NRC-3, in sufficient places to permit
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r individuals engaged in licensed activities to observe them on the
! way to and from any licensed activity location. If posting of the documents specified is not practicable, the licensee may post a notice which describes the documents and states where they may be examine !
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During tours of the facility, the inspector noted that the l applicable documents and/or references to their location were posted at the entrance to the reactor control room. The posted documentation indicated that copies of regulations and procedures were maintained in the Reactor Supervisor's office, e. Area Posting and Radioactive Material Labeling - l 10 CFR 20.203 specifies the requirements for posting radiation ,
areas, high radiation areas, and labeling containers of. radioactive- -'
material Posting of entrances into restricted areas and the labeling of radioactive material containers within the restricted area were observed during tours of the facility. All postings of areas and labeling of radioactive material appeared to be adequate and in ;
compliance with applicable regulation f. Surveys 10 CFR 20.201(b) requires the licensee to make or cause to be made i such surveys as (1) may be necessary for the licensee to comply with-regulations and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen !
TS 6.3 requires radiation control procedures to be maintained and made available to all operations personne .;
Standard Operating Procedure (S0P) 10.4, facility and Environmental Surveys, dated November 1970 (as revised), details radiological i surveys to be conducted within the UVAR restricted are During a review of the various daily, weekly, and monthly survey maps that had been completed for_ the controlled and uncontrolled
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areas of the facility, the inspector determined that all required surveys were being completed as required. The survey results had been reviewed by a member of UVAR staff and by the RHP as require The inspector also observed the R0 as he performed a daily surve The individual demonstrated good survey techniques and performed '
adequate surveys of'the areas under' surveillanc Following a review of selected UVAR restricted area radiological !
survey results, the inspector noted that the surface contamination and radiation level results were generally constant. Surface contamination levels were usually below the administrative limit of 50 disintegrations per minute per one hundred square centimeters >
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I (dpm/100 cm2 ). When contamination levels above this limit were I noted during routine surveys, an operator was assigned to clean the area. General area radiation levels were noted to be less than 0.5 mR/hr when the reactor was not operating and ranged from less j than 0.5 to approximately 9 mR/hr in certain portions of the reactor room and in the ground floor reactor face area during reactor operatio Air Sampling 10 CFR 20.103 requires that suitable measurements of concentrations of radioactive material in air be performed to detect and evaluate the airborne radioactivity in restricted area Airborne particulate concentration survey. results were also examined by the inspector. These levels were generally well below twenty- ,
five percent of the Maximum Permissible Concentration (MPC) limits specified in 10 CFR Part 20, Appendix B, Table 1, Column 1. During the period of September 1992 through October 1993, the results of air samples taken in the UVAR room indicated activity from 2E-12 to 7E-12 microcuries per milliliter (uCi/ml). The MPC for the area-is *
3E-11 uCi/ml .
No violations or deviations were identifie . External Exposure Review (83743)
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 area The inspector reviewed and discussed with the licensee the exposure records of persons working in the UVAR restricted area during the last ,
two quarters of 1992 and from January 1 through September 30, 199 ~
Personnel exposure measurements were made using thermoluminescent .
dosimeters (TLDs) provided by a vendor. Vendor specifications reported a i detection limit of 10 millirem (mrem) for the dosimetry provided. The ,
highest cumulative whole body exposure reported for 1992 was 280 mre This had been received by a research scientist who was engaged in the licensee's neutron activation analysis (NAA) project. The majority of the remaining annual cumulative exposures for the other UVAR operations personnel and staff totaled less than 20 mrem eac During 1993 through the end of September, the highest cumulative exposure .;
was approximately 160 mrem, again received by the person engaged in the <
NAA project. And as in 1992, the majority of the remaining cumulative-exposures through September 1993 for the other UVAR operations personnel and staff totaled less than 20 mrem eac I
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The inspector also reviewed the licensee extremity monitoring program and-the monitoring results. During 1992, the highest cumulative extremity exposure being 1590 mrem. Through September 1993, the highest cumulative extremity exposure was 420 mrem. This extremity exposure was again received by the individual involved in the NAA project. The majority of the remaining cumulative extremity exposures for the other UVAR i operations personnel and staff totaled less than 20 mrem eac No violations or deviations were identifie . Internal Exposure Review '
10 CFR 20.103 establishes the limits for exposure of individuals to concentrations of radioactive materials in air in restricted areas and-requires that appropriate bioassays be performed to detect and assess individual intakes of radioactivit In discussing this requirement with UVA EHS representatives, they indicated that they had not had a problem with internal exposure and currently did not have a program to measure internal exposure. However, the RSO also indicated that a bioassay program was being developed and would be implemented by January 1,1994. He indicated that the program would include bioassay for iodine-125 and iodine-131. A bioassay and internal dosimetry program was also being developed for other radionuclides as well. Draft procedures had been developed and would be reviewed, approved, and implemented by January 199 No violations or deviations were identifie . Environmental Monitoring (80745)
' Environmental Reports TS 6.6.2 requires a routine annual report to be submitted by March 31, of each year covering the activities of the reactor facility during the previous calendar year. Each report shall include a summary of the nature and amount of radioactive gaseous, '
liquid and solid effluents released or discharged to the environs beyond the effective control of the licensee as measured or ;
calculated at or prior to the point of such release or discharge; ;
environmental surveys performed outside the facility and exposures- !
received by facility personnel and visitors; and a summary of *
radiation and contamination surveys performed within the facilit ;
The inspector verified that an annual report was prepared and issued by the licensee in accordance with applicable TS requirement Details of the report are discussed in subsequent sections of this paragrap f
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b, Liquid Effluent Releases (1) Liquid Releases TS 3.4.2 requires that the activity of liquids released beyond the site boundary shall not exceed 10 CFR Part 20 limit The inspector reviewed the data concerning the releases made from the facility by the license From January 1, 1992, through December 31, 1992, the licensee conducted 36 waste tank releases with an average radionuclide concentration of 5.77 E-9 microcuries per milliliter (uti/ml).- Total gross beta activity released during the year was 184 uti, excluding tritium. - Total i liquid volume released was 3.17 E7 liters. Total tritium activity released was 1.459 millicuries (mci) and the average tritium release concentration was 5.7 E-8 uti/ml. The concentrations released were within the limits specified in 10 CFR 20, Appendix B, Table II, Column (2) Air and Water Environmental Samples TS 6.3 requires radiation control procedures to be maintained and made available to all operations personne S0P 10.4.C, Facility and Environmental Surveys, dated November 1970 (as revised), stipulates that samples of air and water '
shall be collected and analyzed on a monthly basi The inspector also reviewed the analyses of monthly environmental water samples collected at selected upstream and downstream locations relative to the UVAR facility release point. The analyses appeared adequate and the average gross beta concentration measured at each location was less than the applicable Maximum Permissible Concentration (MPC) of 3E-8 uCi/m The inspector also reviewed licensee files that outlined a problem that had occurred during 1992. During the time period from July through November 1992, a number of air and water samples were not collected and/or not analyzed as required by SOP. Specifically, in July, the results of the air sample taken on the reactor roof could not be located. Also, samples ,
for tritium water analysis of the pond and pool water were apparently collected and analyzed but the results were not documente In September, environmental water samples were apparently collected and analyzed for tritium but, again, the results were not documented. In November, the environmental '
water samples were taken but not analyzed and appart:ntly subsequently discarded.
l Licensee representatives became aware of the problem and initiated an investigation. It was determined that work l
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schedules had been a factor in the problem and that the samples ,
were either not taken or the analyses were not performed or not recorded. Corrective actions were taken as a result. One month, one of the two EHS HP technicians assigned to help at the reactor facility would take the air samples and perform the analyses while the other would take the water samples and perform the required analyses. The next month, the two technicians would alternate taking the air and water sample Also, the EHS HP technicians would coordinate their schedules through the RHP to ensure that everyone knew who was to perform what task. To date, during 1993, no problems have been noted ,
and the samples have been taken and analyzed as required and .
the results have been documente t The licensee was informed that failure to collect and/or analyze air and water samples was a violation of TS However, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Policy (50-62/93-04-01).
(3) Pond Water Releases TS 6.3 requires radiation control procedures to be maintained and made available to all operations personne S0P 10.5.B.2.C, Reactor Facility Radioactiva Waste Disposal, j dated November 1970 (as revised), stipulates that the data on '
the release form, " Release of Pond Water Authorization", must be reviewed and approved by both the RHP and the Reactor i Supervisor prior to each pond water releas I During a review of the forms, " Release of Pond Water Authorization", the inspector noted that, on various occasions, i the forms were either initialed by the RHP or not signed or dated. The forms were not signed on November 30, 1992, June 4, i 1993, and July 20, 1993. The form with the dated of June 4, ,
1993, had a note written above the signature line indicating -l that a decision was made to release the pond water but that the ;
reactor staff could not contact the RHP. Therefore, the ;
Reactor Supervisor had apparently authorized the release in accordance with the criteria outlined on the form. The form !
indicated that, exceptional releases may be made as per UVAR i S0P 10.5.B.2.C with the consent of the Reactor Superviso :
However, as noted above, the 50P does not authorize the Reactor ;
Supervisor to release the pond water without the review and i approval of the RH When the licensee was made aware of this problem, they indicated that the form was correct and it was their intent to allow the Reactor Supervisor to authorize release of pond water in exceptional cases such as during a heavy rain storm when the j
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pond is at a level that it might overflo If the RHP cannot be reached, the licensee intended to allow the Reactor Supervisor to authorize a pond release to prevent inadvertent release of the pond water. The licensee subsequently revised the S0P to allow the Reactor Supervisor to authorize pond water-release in exceptional situation .
The licensee was informed that failure to have the RHP review and authorize pond water releases was a violation of.TS However, this NRC' violation is not being cited.because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied (50-62/93-04-02). Airborne Effluent Releases Gaseous effluent released during 1992 was approximately 3.5 curies '
(Ci) of argon-41 (Ar-41). For 1992, the licensee continued to rely on a calculated estimate of the maximum concentration of Ar-41 produced during normal operations. However, because the licensee received monies from the Department of Energy for facility upgrades, they had purchased two monitors to be used to monitor for noble gases (specifically Ar-41). One has been installed in the UVAR roo ,
and has been installed to monitor the exhaust. When testing has- :
been completed, the licensee's environmental monitoring program '
should be enhanced because they can directly measure the amount of 6 Ar-41 that has been discharged to the atmospher The inspector also reviewed the analyses of monthly environmental air samples collected at selected locations relative to the UVAR facility. The analyses appeared adequate and the average gross beta concentration measured at each location was less than the applicable MPC of IE-11 uCi/m (See Paragraph 5.b(2) above).
Two non-cited violations were identifie . Surveillance Requirements (61745) Shim Rods TS 4.1 requires that the shim rod drop times be measured annually ~
and that the shim rods be visually inspected annuall >
A review of the records of shim rod drop times and the visual inspection of the shim rods indicated that the shim rod' speed had been measured annually as required and the speed had not appreciably changed from 1991 to 1993. Also the visual inspections had been '
performed June 12, 1992 and July 12, 1993, and no problems had been note .l ;
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b. Maintenance TS 4.5 requires that, following maintenance or modification of a control or safety system or component, it shall be verified that the system is operable before it is returned to service or during its initial operatio During the reactor startup on November 3, 1993, the inspector noted that the licensee was experiencing some problems with some of the safety system equipment. The inspector subsequently observed licensee representatives perform maintenance / trouble-shooting activities on the source range channel. The applicable form,
" Trouble-Shooting / Repair Documentation Sheet", Rev. O, dated May 1993, was completed and approved by the Reactor Supervisor prior to commencing the troubleshooting / repair work. The trouble-shooting activities were then performed and some repairs were mad Following the repairs, the equipment was calibrated in accordance with procedure and tested to verify operability. A UVAR Daily Checklist and a UVAR Safety Related System Checklist were completed, as required by procedure, and then the reactor startup continue No other problems were noted and the reactor operated properl c. Confinement System Surveillance TS 4.6(2) requires that, at least once each month, a test be made of the truck door closed switch, the ventilation exhaust duct door, and the personnel door, to ensure the equipment is operable. TS 4.6(2)
also requires that, semiannually, a visual inspection of the seal and gaskets of the truck door, the personnel door, and the ventilation exhaust duct door be made to verify that they are operabl The inspector reviewed the records pertaining to the monthly and semiannual checks specified above. The licensee had performed the required monthly checks during 1992 and 1993 to date. The semiannual checks were also made during January and July of each year with acceptable result d. Primary Coolant Conditions TS 4.9 requires that the conductivity and the pH of the primary coolant shall be measured at least every two weeks and shall be
- s5 E-6 mhos/cm and between 5.0 and 7.5 respectivel The inspector reviewed the operations logs and verified that these measurements are performed daily. During periods of time when the reactor was shutdown for an extended period, the conductivity and pH were check weekly as part of the Security Checklist performed by the facility staff. The results of the measurements indicated that the conductivity and pH were within the limits specified. The inspector also checked the calibration records of the conductivity monitor and verified that the monitor was calibrated every six months as require .. -.
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No violations or deviations were identifie . Experiments (69745) .
The Routine Irradiation Request Forms (RIRFs) and Special Irradiation Request Forms (SIRFs) from July 1992 through October 1993 were reviewed and along with the Irradiations Log for the same period. All irradiations appeared to be routine in nature and consistent with activities that have been conducted in the past. Through interviews with licensee representatives and records review, the inspector determined -
that no new experiments had been performed nor were any being performed at the time of the inspectio ,
No violations or deviations were identifie . Transportation of Radioactive Material (86740) ;
10 CFR 71.5 requires each licensee who transports licensed material :
cu+, side the confines of its plant or other place of use to comply with O applicable requirements of the Department of Transportation (DOT) in u CFR Parts 170 through 18 .
The inspector reviewed the shipping paperwork and records for selected radioactive material shipments made since the last inspection. All shipment records were completed as required and the records were being maintained as required as wel ,
No violations or deviations were identifie . Licensee Event Followup (92700)
During the inspection, the licensee informed the inspector that a reactor pool leak had developed sometime in August. The magnitude of the leak r was estimated at about 100 gallons per day as determined by pool level decrease. A small amount of the water appeared to be flowing out of a small crack in the biological shield in the ground floor reactor face area but this only accounted for a few gallons a day. The majority of a the water was apparently leaking around penetrations in the pool wall and l running beneath the facility and into an adjacent retention pond. (The retention pond is routinely sampled before any releases are made.)
As a result of this problem, the licensee had initiated a program of sampling the streain water below the pond and sampling the pond water for !
tritiu (The reactor pool water is routinely sampled for tritium.) The licensee had contacted a contractor who s,pecializes in repairing such l breeche in containment. The contractor indicated that they could repair ;
the leak by drilling into the cancrete~ and injecting a water-activated l fluid that expands to become a closed cell foa j The inspector reviewed the results of the analyses of water samples taken -l from the reactor paol and the retention pond. The measured radioactivity l
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levels in'the water samples from the pool and pond were well below 10' CFR Part 20 limits for release to restricted and unrestricted areas respectivel ,
Due to the nature of the problem, the NRC sent the licensee a letter on '
November 10, 1993, requesting increased emphasis on sampling to monitor levels of radioactivity in both the pool and pond water. The letter also requested increased surveillance to note pool water level and a search -
for the cause of the leakage. The licensee agreed to collect water samples from the reactor pool and the retention pond on a daily basis and analyze those samples for gamma activity. Every third day, the licensee also agreed to analyze the water samples for tritium and gross beta activity as well. Further followup by the NRC is scheduled when the contractor attempts to repair the leak in the reactor pool wal . Exit Interview '
The inspection scope and results were summarized on November 4, 1993, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection findings, including the two non-cited violations outlined below. The staffing '
level appeared to be adequate to conduct the radiation protection program at the facility. The radiation exposures to individuals were maintained well within the facility administrative levels and the federal regulatory limit No problems were noted with shipments of radioactive materials from the facilit ,
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector.
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Item Number Descriotion and Discussion 50-62/93-04-01 NCV - Failure to collect and/or analyze environmental air and water samples (Paragraph 5.b(2)).
50-62/93-04-02 NCV - Failure to have the RHP review and authorize pond water releases as required by procedure (Paragraph 5.b(3)). ,
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