ML20113D833
| ML20113D833 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 02/20/1985 |
| From: | Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20113D789 | List: |
| References | |
| NUDOCS 8504150616 | |
| Download: ML20113D833 (6) | |
Text
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UNIVERSITY OF VIRGINIA
, ap8N 1 DEPARTAIENT OF NUCLEAR ENGINEERING AND ENGINEERING PIIYSICS P
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SCIIM[QICENCI$1;E61gG AND APPLIED SCIENCE NUCLEAR REACTOR FACILITY L
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CIIARLOTTESVILLE, VA 22901 February 20, 1985 Telephone: 841-92!-7136 Mr. James P. O'Reilly U.S. Nuclear Regulatory Commission, Region II 101 Marietta Street NW Atlanta, Georgia 30303
SUBJECT:
Response to NOTICE OF VIOLATION of January 25, 1985, addressed to the University of Virginia Reactor Facility, Docket No. 50-62, License No. R-66, EA 84-111 Gentlemen:
A.
Admission or Denial of Alleged Violations 1.
Alleged violation of 10 CFR 20.201(b) and 10 CFR 20.105(b).
On November 1,1984 the licensee filed a Licensee Event Report with the Document Control Desk of the U.S.N.R.C..
In this report the licensee acknowledged that levels of radiation above the applicable 10 CFR limit had been found to exist in an unrestricted area at the Facility for a period of three weeks. The radiation field was localized to a very small area of relatively free access but extremely low occupancy rate. The radiation levels exceeding permissible limits were limited within a distance of about 32 inches from the ground and and a radius of about 39 inches away from a point at the base of the reactor building wall.
Contrary tc the NRC staff opinion, the licensee does not believe that the radiation " hot spot" was safety significant because:
a) A significant radiation exposure to an unmonitored person could only have occurred if the individual had crouched against the reactor building wall at precisely the optimum location. As stated, the area is unsuited for traffic and is essentially never occupied, so the overexposure assumption is not cred'tle.
b) The prior radiation surveys performed by the licensee, which did not reveal the " hot spot", were believed at the time to be adequate and reasonable under the circumstances to evaluate the extent of radiation hazards that could have been present. The
" hot spot" would otherwise have been found had it been centered at waist height, where it would have begun to have had potential for whole body exposure.
(Since the reported event the licensee has complied with the NRC's interpretation of " adequate" and
" reasonable" surveys.
Further " corrective" measures are described in following sections.)
8504150616 850328 PDR ADOCK 05000062 G
3 Mr. James P. O'Reilly Page 2 February 20, 1985-It is probable that the NRC staff's opinion is based on a statement made in the inspector's report which fails to properly address its location.
The licensee has reviewed public documents pertaining to NRC notices of violation served on other licensees, in order to verify consistency in the application of Severity Level III categories. The licensee believes that since this infraction was not of safety significance and was limited to one instance, a Severity Level IV' categorization would have been more appropriate. The review of the public documents seems to support this belief.
2.
Alleged violation of 10 CFR 71.5 (or 49 CFR 172.504, 49 CFR 172.202 and 49 CFR 170-189)
The last NRC inspector interpreted that the transfers of irradiated material between the Reactor Facility (Dept. of Nuclear Engineering.and Engineering Physics) and the Dept. of Chemistry, as well as of low-activity waste between the Facility and the U.Va. Waste Facility, constituted shipping of licensed material outside the confines of its plant, and therefore required compliance with DOT regulations.
Prior to the latest NRC inspection, the licensee assumed that the confir.es of its plant included all of the U.~ of Virginia " Grounds" area.
Therefore shipping manifests were not used, although transfer papers describing the materials being transferred were used by the Facility.
Also, the Facility did not consider itself a shipper in these_ instances, because the transfer of possession of radioactive materials from the Facility License to the U. of Virginia By-Products License was considered to occur within the Facility just before transfer was begun.
Following the NRC inspection the licensee adopted the NRC viewpoint in-regards to these contentions, and is presently using the required shipping manifests. This constitutes acknowledgement of this inadvertent violation.
3.
Failure to adhere to UVAR S0P 10.ll.C.2(a) and (b),
and UVAR S0P 10.5.C.
(UjVA_R_istheacronymfortheUniversityofVAR_eactor.)
The NRC inspector did indeed witness a failure to observe S0P 10.ll.C.2(a) and (b) by 2 staff members and also did in fact verify that S0P 10.5.C had.not been followed in several instances beginning at the time of the inspection.
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Mr. James P. O'Reilly Page 3 February 20, 1985 4.
Alleged violation of 10 CFR 20.203(e)
The NRC inspector correctly noted that the locked, below ground, liquid waste holding tank exclosure was not conspicuously posted as a radioactive materials area on its exterior lid.
B.
Reasons for Violations 1.
10 CFR 20.201(b) and 10 CFR 20.105(b).
The Licensee Event Report filed by the licensee contains a very detailed description of the occurrence.
In summary, the " hot spot" was not found during the licensee's regular radiation surveys because they were performed at waist level with a survey instrument of slow view-meter response. Both the procedure and the instrument were judged by the licensee to be reasonable and adequate up to the date of the last NRC inspection.
2.
10 CFR 71.5 The licensee did not observe 10 CFR 71.5 in the processing of "On-Grounds" transfers of radioactive materials because of its interpretation of the Federal Regulations. The Facility did not consider itself a shipper on occasions when irradiated materials and low activity waste were transferred to other "On-Grounds" facilities, i.e.
within the confines of its plant. Also, the relationship between the Reactor Facility's License and the U.Va. By-Products Material License was not interpreted by the licensee in the restrictive sense chosen by the NRC inspector.
3.
UVAR SOP's 10.ll.C.2(a) and (b) and 10.5.C.
The non-conformities with the Fac;iity's Standard Operating Precedures 10.ll.C.2 were a result of staff member carelessness and inattention.
In an effort to get the job done quickly, personal health physics working and survey procedures were overlooked. This was due in part to.the staff members' belief that an actual risk of contamination did not exist since the area where they were working had been previously decontaminated by the same 2 persons.
With regards to 10.5.C, inexperience was a basic cause for the infraction. The pond water pre-release activity data had never before exceeded the 50P limit requiring performance of the " additional analysis". The 50P's did not define what was meant by this additional analysis. A prior theoretical evaluation which may be consid9 red to be the required additional analysis had indicated that among the isotopes requiring identification (I-129, Ra-226 and Ra-228), I-129 could not possibly be present in effluent from our reactor, without the prior
Mr. James P. O'Reilly Page 4 February 20, 1985 appearance of I-131 in the weekly reactor pool samples. The Ra-226 and 228 isotopes are related to uranium mining operations and are therefore not present in the Facility s effluent. They are, however, naturally
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detectionlimitsof10~gratconcentrationlevelsbelowminimum present in our pond wat uCi/ml.
4.
Historically, the exterior of the enclosed underground locked liquid waste tanks have never been posted with the radioactive materials sign. Since the tank itself is inconspicuously located out of traffic areas, this non-compliance was never realized by anyone at the Facility.
C.
Corrective Steps Despite differences of opinion with the NRC staff regarding the characterization and seriousness of some.of the alleged violations, the management of the U.Va. Reactor Facility has taken corrective steps necessary to achieve full compliance and to avoid further violations.
The main specific steps which were taken are outlined below.
1.
10 CFR 20.201(b) and 10 CFR 20.105(b) e After the NRC inspector discovered the " hot spot", the experiment causing the radiation field was immediately relocated to a more suitably shielded area.
e The event was thoroughly studied for the extent and nature of the radiation field, its duration, its cause, and remedial actions made necessary to prevent re-occurrence, i.e. sealing of the experiment pipe shields sunk into the reactor floor next to the external wall.
e The event was documented and reported to the NRC.
e The event was thoroughly discussed at all staff and management levels.
l e Radiation survey procedures were modified to include the search for hazards at levels other than waist level.
i e An audible rate indicating survey meter has been purchased to replace the previous survey meter.
2.
10 CFR 71.5 e The licensee has adoped the 49 CFR 172.202 and DOT required shipping manifest for its transfers within the "U.Va. Grounds".
e ' Transfers of Yellow Label III radioactive materials are now l
being made with placarded vehicles as per 49 CFR 172.504.
e Transfers of low activity wastes are following manifest, labelling and placarding requirements described in 49 CFR Parts 170-189.
I
a Mr. James P. O'Reilly Page 5 February 20, 1985 3.
UVAR S0P 10.ll.C.2(a) and (b) e The 2 persons involved in the HP infractions were reprimanded.
e The same 2 staff members were required to attend a Health Physics short-course administered by the U.Va.
Radiation Safety Officer.
e The controlled area within the Reactor Room has been more clearly demarcated with physical barriers and now has a single access point.
e Tools and protective work clothing have been provided at the sole entry point into the controlled area within the Reactor Room.
e The survey instrument to be used on leaving the controlled area has been relocated to a position farther from the reactor, and is now more obvious to staff leaving the controlled area.
It has been shielded to increase'its sensitivity.
.e Cautionary and instruction signs have been placed where necessary to remind staff of proper procedures for a) entering and exiting a controlled area, b) entering and existing a contaminated area, c) donning appropriate work clothing and, d) proper frisking requirements following exit of the controlled area and the Reactor Room.
o Students and Faculty members with regular access to the Reactor Room have been instructed in required HP practices.
o An HP training program for all frequent occupants of the
^
Reactor Facility (which houses the Department of Nuclear Engineering & Engineering Physics) has been formalized and strengthened.
e Dilution of pond water with rainfall and fire hydrant water has brought down its activity to levels below the point where " additional analysis" is necessary.
e A new form controlling pond and waste water sampling procedures, sample data documentation and release authorization has been added to 50P 10.5.C.
e Samples of waste tank water and hold-up-pond water were sent for independent analysis to " Control for Environmental Polution Inc." of Santa Fe, New Mexico. The results indicate that, as theoretically expected, I-129, Ra-226 and Ra-g28cannotbefoundaboveninimumdetectablelimitsof 10- pci/ml.
4.
10 CFR 20.203 (e) e The underground tank enclosure lid was conspicuously posted with the radioactive materials area sign.
e All areas of the Facility were checked for compliance with this and other Federal Regulations.
Mr. James P. O'Reilly Page 6
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February 20, 1985 D.
Date of Full Compliance e The licensee is presently in full compliance with the NRC and Federal Regulations. The licensee made a good faith effort to return to compliance on all issues identified by the NRC inspector and achieved this in most cases by the time the inspector had left the Facility.
E.
Oath I affirm under oath that the statements made above are true and correct, to the best of my knowledge, 1
Date Y & 20,/96S~
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F RO)ert U. MDT55e, Director U.Va. Nuclear Reactor Facility cc: : Director, Office of Inspection & Enforcement USNRC, Washington, DC Sworn to and 5 r;tH t&re me this MN
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JAN251985 University of Virginia ATTN:
Dr. R. U. Mulder, Director Reactor Facility Charlottesville, VA 22901 Gentlemen:
SUBJECT:
SEVERITY LEVEL III VIOLATION, EA 84-111 FAILURE TO PERFORM AN ADEQUATE SURVEY (INSPECTION REPORT NO. 50-62/84-01)
A routine unannounced inspection was conducted by this office during the period of October 1-3, 1984 of activities authorized by NRC Operating License No. R-66 for the Pool Reactor facility.
As a result of this inspection, significant failures to comply with NRC regulatory requirements were identified, and accordingly, an Enforcement Conference to discuss these matters was held at the University of Virginia on October 22, 1984.
The violations described in the enclosed Notice of Violation include failures to perform an adequate radiological survey, properly transport licensed material, follow radiation control procedures, and identify a radioactive materials storage In particular, the failure to perform an adequate radiation survey was area.
safety significant because a radiation level of approximately 40 millirems per hour on contact and five millirems per hour at 18 inches was present outsice of your reactor confinement building for a period of approximately three weeks.
The NRC is concerned that this violation of regulatory requirements could have resulted in radiation exposure to unmonitored personnel.
You stated during the Enforcement Conference of October 22, 1984 that the cause of this event was storage of an irradiated experiment in close proximity to the outside wall in the reactor room.
In our view, a more basic cause of this event was failure to perform an adequate radiation survey.
Accordingly, the violation has been categorized at Severity Level III in accordance with the NRC's " General Statement of Policy and Procedures for Enforcement Actions," 10 CFR Part 2, Appendix C, as revised, 49 FR 8583 (March 8,1984).
The base civil penalty for a Severity Level III violation is $5,000.
However, we note that you promptly investigated the circumstances of this event, took prompt corrective action, and took decisive action to preclude its recurrence.
Also, your recent past performance in this area has been good.
In recognition of these factors, and af ter consultation with the Director, Office of Inspection and Enforcement, I have decided not to propose a civil penalty in this case.
You are required to respond to the enclosed Notice of Violation, and you should follow the instructions specified therein when preparing your response.
In your response, you should describe the action taken or planned to avoid similar violations in the future.
Also, as described in the enclosed Notice of Deviation, a deviation for failure to maintain records was identified.
A reply to the Notice of Deviation is also requested.
Your written reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is appropriate.
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University of Virginia.
JANl2 51985 2
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2, Title 10,. Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.
The responses directed by this letter and accompanying Notices are not subject to the-clearance procedures of the Office'of Management and Budget as required by the~ Paperwork Reduction Act of'1980, PL 96-511.
Sincerely, ORICfNAL SIGNED By JAMES p. O'Reri, y James P. O'Reilly Regional Administrator
Enclosures:
1.
Notice of Deviation 3.
Inspection Report No. 50-62/84-01
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4 ENCLOSURE 1 NOTICE OF VIOLATION University of Virginia Docket No. 50-62 Pool Reactor Facility License No. R-66 EA 84-111 The following violations were identified during an inspection conducted on October 1-3, 1984.
In accordance with the NRC's " General Statement of Policy and Procedure for Enforcement Actions," 10 CFR Part 2, Appendix C, as revised, 49 FR 8583 (March 8, 1984), and 10 CFR 2.201, the particular violations are set forth below.
1.
10 CFR 20.201(b) requires that each licensee shall make such surveys as may be necessary for the licensee to comply with the regulations in Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.105(b) states that no licensee shall possess, use, or transfer licensed material in such a manner as to create in any unrestricted area from radioactive material and other sources of radiation in his possession radiation levels which, if an individual were continuously present in the area, could result in his receiving a dose in excess of two millirems in any one hour.
Contrary to the above, during the period September 12 to October 2, 1984, the licensee did not conduct such surveys as were necessary to identify a radiation level in an unrestricted area along the outside east wall of the confinement building.
An individual, if continuously present there, could have received a dose in excess of five millirems in any one hour.
This is a Severity Level III violation (Supplement IV).
2.
10 CFR 71.5 requires that each licensee who transports licensed material outside the confines of its plant or other place of use shall comply with the applicable requirements of the regulations of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189.
Contrary to the above, the licensee transported licensed material outside the confines of its plant over a public road and did not comply with the requirements of DOT in that:
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A.
Although 49 CFR 172.504 requires that vehicles transporting Yellow -
Label III radioactive material be placarded, transport vehicles for three transfers of Yellow Label III material, specifically, irradiated experiments, from the licensee's reactor facility to the Chemistry building were not placarded on June 13, 1984, June 22, 1984, and August 10, 1984.
B.
Although 49 CFR 172.202 requires that a radioactive material shipping manifest contain the proper shipping name, hazard class, UN number, and quantity of material, the manifests used to transfer irradiated experimenta from the licensee's reactor facility to the Chemistry building did not contain the required information during the period June 1, 1983 to the time of the inspection.
C.
Although 10 CFR Parts 170-189 require a manifest, labelling, and placarding for radioactive waste shipments, a licensee repre-sentative stated during the course of the inspection conducted on October 1-3, 1984 that the manifest, labelling, and placarding requirements described by 49 CFR Parts 170-189 had never been met by the University of Virginia for transfers of low level radioactive waste drums from the licensee's reactor facility to the University of Virginia waste packaging area.
The licensee respresentative stated that these transfers had occurred on an approximately monthly basis since the license was issued.
Specifically, no shipping manifest was prepared as required by 49 CFR 172.202, the drums were not labelled as required by 49 CFR 172.400, and the transport vehicle was not placarded as required by 49 CFR 172.500 This is a Severity Level IV violation (Supplement IV).
3.
Technical Specification 6.3 requires that radiation control procedures be maintained.
The licensee has developed radiation control procedures to implement this requirement, specifically', the University of Virginia Activation Reactor (UVAR) Standard Operating Procedures (S0Ps).
Contrary to the above, UVAR SOPS were not adhered to in that:
A.
Although UVAR S0P 10.11.C.2.a requires that personnel in a controlled area shall wear appropriate protective clothing, a licensee employee was observed lying on his stomach performing an operation in a posted and controlled area inside the reactor room wearing only shoe covers and gloves on October 1, 1984.
B.
Although UVAR S0P 10.11.C.2.b requires that personnel survey themselves at the exit of the controlled area, personnel exited a controlled area in the reactor room and did not survey themselves at the exit on October 1, 1984.
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e Notice.of Violation 3
C.
Although UVAR SOP.10.5.C requires that, if the average activity concentgationofthethreepondwaterpre-release,samplesisabove 3 X 10- uCi/ml, additional analysis shall be conducted to ensure s
that the criteria of 10 CFR 20, Appendix B or Note to Appendix B are sa'tisfied, no additional analysis was conducted for liquid
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effluent release 84-46 on September 11, 1984, where the pond prereleasewatersamplesjndicatedanaverageactivity concentration of 2.4 X 10- uCi/ml.
This is a Severity Level IV violation (Supplement IV).
<4.
10 CFR 20.203(e) requires that each area or room in which licensed material is stored, and which contains radioactive material in an I
amount exceeding 10 times the quantity of such material specified by Appendix C of 10 CFP Part 20 be conspicuously posted as a y
radioactive materials area.
Contrary to the above, on October 1, 1984, an area used to store licensed radioactive material, the 5,000 gallon liquid waste holding tank, was not posted.
The tank contained licensed material in excess of ten tines the applicable quantity of such material listed in 10 CFR Part 20, Appendix C.
This is a Severity Level IV violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, the University of Virginia is hereby required to submit to the Director, Office of Inspection and Enforcement, USNRC, Washington, D.C. 20555, and a copy to the Regional Administrator, USNRC, Region II, 101 Marietta Street, Suite 2900, Atlanta, Georgia 30323, within thirty days of the date of this Notice a written statement or explanation including:
(1) admission or denial of the alleged violations, (2) the reasons for the violations', if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Consideration may be given to extending the respcnse time for good cause shown.
U;ider the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
JAN251985 g,,,,
ENCLOSURE 2 NOTICE OF DEVIATION University of Virginia Docket No. 50-62 Pool Reactor Facility License No. R-66 EA 84-111 As a result of the inspection conducted on October 1-3, 1984, the following deviation was identified:
University of Virginia letter dated December 14, 1978, to USNRC Region II stated in response to violation 78-02-01 that:
"The Reactor Health Physicist has been directed to measure the flow rates in the laboratory fume hoods on a quarterly basis and to maintain records of the measurements."
Contrary to the above, records of quarterly fume hood air flow measurements had not been maintained in accordance with their commitment.
This deviation existed from December 14, 1978 until the inspection took place on October 1-3, 1984.
l Please provide in writing within thirty days of the date of the Notice a description of corrective actions regarding these deviations, actions taken to avoid further deviations, and the dates when these actions were or will be completed.
Date:
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Report No.:
50-62/84-01 Licensee:
University of Virginia Charlottesville, VA 22901 Docket No.:
50-62 License No.:
R-66 Facility Name:
University of Virginia Reactor Facility Inspection Conducted:
October 1-3, 1984 Inspector:
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/f R. E. Wedcrin~gton g-Date Signed
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Approved by:
e*7(/0V stA-G. R. Jenkins, Section Chief Date Signed
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Division of Radiation Safety and Safeguards SUP9tARY Scope:
This routine, unannounced inspection involved 23 inspector-hours on site in the areas of radiation control, environmental protection, transportation and inspector follow-up items.
Results:
Four violations were identified - Failure to perform an adequate survey, failure to properly transport licensed material, failure to adhere to radiation control procedures and failure to post a radioactive materials storage
. area.
A deviation for failure to maintain records was also identified.
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2 REPORT DETAILS
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1.
Licensee Employees Contacted R. U. Mulder, Reactor Facility Directo'r P. E. Benneche, Research Engineer, SRO J. R. Gilchrist, Radiation Safety Specialist J. E. Henderson, Reactor Facility Health Physicist J. P. Farrar, Reactor Facility Supervisor R. O. Allen, Chairman, Radiation Safety Committee A. Turley, Reactor Facility Health Physics Technician B. Copcutt, University of Virginia Radiation Safety Officer 2.
Exit Interview The inspection scope and findings were summarized on October 3,1984, with those persons indicated in paragraph 1 above.
The following issues were discussed in detail:
an apparent violation for an excessive radiation level discovered by the inspector outside the confinement building (paragraph 3.a); an apparent violation for failure to comply with DOT shipping requirements (paragraph 4); an apparent violation for failure to adhere to radiation control procedures (paragraph 3.b and 5.b); an apparent violation for failure to. post a radioactive material area (paragraph 3.f); and an apparent deviation for failure to maintain records (paragraph 3.h).
The licensee acknowledged the inspection findings and took no exceptions.
3.
Radiation. Control (83743) a.
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.
The inspector reviewed the following records of licensee surveys for the periods indicated:
Daily Contamination Survey, June 1 through September 28, 1984 Weekly Contamination and Radiation Survey, July 5 through September 19, 1984 Monthly Contamination and Radiation Survey, January 3 through August 22, 1984 The inspector observed that numerous survey records were completed in pencil and that measurements appeared to have been taken in the same location for each survey.
Licensee representatives stated that they would ensure that the records were completed in ink in the future.
They verified that the same locations had been checked for each survey.
The inspector accompanied the facility health physics technician on a weekly radiation and contamination survey.
The inspector performed independent radiation and smear surveys after the licensee technician had completed his measurements.
No significant differences between the licensee and inspector smear results were noted.
v 3
While performing the radiation survey outside the east wall of the facility confinement building, the inspector noted an increase in radiation levels.
The licensee technicianebad not noted any abnormal radiation levels in the area.
Upon further evaluation, the inspector identified a hot spot on the outside wall of 39.3 millirem per hour at contact and 5.6 millirem' per hour at eighteen inches.
Licensee management was notified and they promptly investigated the cause of the excessive radiation level.
A pipe sunken in the concrete reactor room floor next to the inside wall was identified which contained an irradiated experiment.
The licensee removed the experiment to another storage area and verified by survey that the radiation field was no longer present outside the building.
The inspector verified the survey.
The licensee determined that the experiment had been at the storage location next to the wall for approximately-three weeks.
The licensee's routine weekly surveys had failed to identify the radiation level outside the building.
The inspector informed the licensee that the radiation level was in excess of that permitted in an unrestricted area by 10 CFR 20.105.b and would therefore be considerec' an apparent violation of 10 CFR 20.201.b since their surveys were not adequate to detect this excessive radiation level (50-62/84-01-01).
b.
Technical Specification 6.3 requires that radiation control procedures be maintained.
On a tour of the facility, the irspector observed work in the reactor room.
The area was a posted contamination control area and workers were dressed in shoe covers and gloves.
The inspector cbserved a licensee employee remove a cover plate on the bridge and then lay on his stomach to work on the centrol rod drive mechanisms through the opening.
The contamination levels in the vicinity of the opening were not determined.
Licensee procedure UVAR SOP 10.11.C.2.a requires that personnel in a controlled area shall wear appropriate protective clothing.
The inspector informed tl'e licensee that shoe covers and gloves were not adequate for this work and would therefore be considered an apparent violation of Technical Specification 6.3 (50-62/84-01-03).
The inspector observed that several persons in the same work area stepped across the controlled area boundary and walked about the reactor room while still wearing their protective clothing.
Upon completing the job, none of the licensee employees surveyed themselves for contamination at the control area exit.
Licensee procedure UVAR 50P 10.11.C.2.b requires that personnel survey themselves at the exit of controlled areas.
The inspector informed the licensee thfs would be considered a second example of an apparent violation of Technical Specification 6.3 (50-62/84-01-03).
10 CFR 20.202 requires that appropriate personnel monitoring devices be c.
worn by personnel likely to receive exposures in excess of 25 rercent of the limits in 10 CFR 20.101 or who enter a high radiation area.
i 4
During tours of the facility, the inspector observed personnel monitoring devices being worn.
By examination of selected records and '
discussions with licensee representatives the inspector determined that appropriate monitoring devices had been worn by licensee employees and visitors.
d.
10 CFR 20.101 states the quarterly radiation exposure limits to the whole body, skin of the whole body and extremities.
The inspector verified by examination of selected records and discussions with licensee representatives that exposures were being maintained well below the applicable limit.
10 CFR 19.12 requires that each employee who works in or frequents the e.
licensee restricted area be given instruction in radiation protection and emergency response commensurate with their duties and potential hazard.
The inspector reviewed the radiation worker course outline and lesson plan.
Selected records of personnel training were also reviewed.
f.
10 CFR 20.203 states the requirements for posting radiation areas, high radiation areas and radioactive materials areas.
While touring the facility, the inspector noted that the vault containing the 5000 gallon radioactive waste holding tank on the outside of the building was not posted as a radioactive materials area.
The vault had an access cover which a licensee representative stated was normally maintained locked.
The inspector observed the cover unlocked during the inspection and that the tank was filled to capacity.
Upon reviewing the radiochemistry analysis of the most recent tank water samples, the inspector determined'a quantity of licensed material in excess of ten times 10 CFR 20, Appendix C quantities were present in the tank.
The inspector informed the licensee that failure to post the holding tank as a radioactive materials area would be considered an apparent violation of 10 CFR 20.203.e (50-62/84-01-04).
g.
The inspector reviewed selected records of the calibration of licensee's portable survey instruments, air effluent monitors and area radiation monitors.
Records of pocket dosimeter leak checks were also reviewed.
h.
The inspector observed that the licensee laboratory fume hoods had position indicators and a dated label indicating the window position which would ensure 100 linear feet per minute of air flow into the hood.
The inspector observed that the labels indicated that the window positions had been determined within the last three months.
The licensee committed in a letter to Region II on December 14, 1978, in response to Violation 50-62/78-02-01, that the flow rate measurements would be performed on a quarterly basis and that records of the measurements would be maintained.
The inspector asked to see
5 the records of previous measurements.
A licensee representative stated that no such records were maintained.
The inspector informed'the licensee that failure to maintain records of measurements would be considered a deviation from a written commitment made to the NRC (50-62/84-01-05).
4.
~ Transportation (86740) 10 CFR 71.5 requires that each licensee who transports licensed material outside of the confines of its plant or other place of use shall comply with the applicable requirements of the regulations of 00T in 49 CFR, Parts 170 through 189.
The inspector determined that two categories of licensed material were transferred from the facility.
Irradiated experiments were transferred to the Chemistry Building on the University campus.
Low level radioactive waste was transferred to a central consolidation and repackaging area also on the University campus.
Both categories of material were transported on roads accessible to the public.
The inspector reviewed records of the shipments performed for irradiated experiments. The inspector noted that the manifests for these shipments did not contain all of the information required of a manifest in 49 CFR 172.202; specifically the proper shipping name, hazard class, UN number and quantity.
The inspector informed the licensee that failure to properly prepare the shipping manifests would be considered an apparent violation of 10'CFR 71.5 (50-62/84-01-02).
The inspector noted that several of the transferred experiments were labeled with DOT Yellow Label III.
The manifests for these shipments indicated that no placards had been affixed to the transport vehicle.
49 CFR 172.504 requires that vehicles transporting Yellow Label III' radioactive material be placarded.
The inspector informed the licensee that failure.to placard these vehicles would be considered a second example of an apnarent violation of 10 CFR 71.5 (50-62/84-01-02).
A licensee representative stated that drums containing low level radioactive waste were transferred in a university owned vehicle to a central area on the campus where the waste had been consolidated with that generated from other university areas and repackaged.
A contractor transfered the waste to a disposal site.
A licensee representative stated that the wastes are not L
transported in accordance with the DOT requirements in 49 CFR.
The inspector informed the licensee that failure to comply with 49 CFR requirements for the waste drums would be considered a third example of an apparent violation of 10 CFR 71.5 (50-62/84-01-02).
5.
Environmental Protection (80745) a.
Technical Specification 3.4.1 states that when either of the neutron beam ports is drained, the exhaust ventilation blowers and the Ar-41 monitor shall be operational.
4.
6 The inspector verified the above stated requirements were being met.
Approximately a year prior to the inspection, the licensde had made a change in the operation of one of the two beam ports to provide a tank to accumulate and reuse the drained water to reduce liquid effluent releases and to place a helium atmosphere in the beam port void to minimize Ar-41 production! The licensee had maintained a record of the change in the facility and had performed a safety review.
A licensee representative stated that the ventilation and Ar-41 monitor were maintained operable even though with the change in the facility they were not necessary since the beam port was now a closed system' and Ar-41 was not being released from that area.
The licensee stated that they did not want to request a technical specification change since the second beam port had not been modified even though it was not in use.
b.
Technical Specification 3.4.2 requires that the cctivity of liquids released beyond the site boundary shall not exceed 10 CFR 20 limits.
The inspector reviewed the records of radioactive liquid holding pond releases for calendar year 1984.
The year to date average water activity was 5 X 10 8 microcuries per milliliter with 1 X 10 7 microcuries per milliliter being the limit.
A total of 2003.1 microcuries had been released.
Licensee procedure UVAR 10.5.B.2.C requires that if the average activity concentration of the pond pre-release samples is above 3 X 10 8 microcuries per milliliter, additional analysis shall be conducted to insure that the criteria of 10 CFR 20, Appendix B or Note to Appendix B are satisfied.
The inspector noted the average activity of three pond pre-release samples for discharge 84-46 was 2.4 X 10 7 microcuries per milliliter, yet no additional samples had been obtained prior to the release.
A licensee representative stated that the procedural action point had been overlo'oked since that situation had not been previously encountered.
The inspector informed the licensee that failure to obtain additional samples would be considered a failure to adhere to procedures and therefore a third example of an apparent violation of Technical Specification 6.3 (50-62/84-01-03).
6.
Inspector Follow-up Items (Closed) 78-BU-01 Neutron monitoring practices.
The inspector determined by review of selected records and discussions with licensee representatives that applicable regulatory requirements were being met.
(Closed) 78-02-08 Film badge spiking program.
The inspector determined that the vendor supplying the monitoring devices used by the licensee was participating in an accreditation program and that supplementary action by the licensee would not be necessary.
(Closed) 78-02-09 Air flow balance in the reactor room.
The inspector reviewed a study performed by the licensee and determined that air flow into the reactor room and out the confinement vent met or exceeded SAR values.
r, 3
7 (Closed) 79-80-19 Packaging of low level radioactive waste.
Reference paragraph 4.
(Closed) 79 IFI-04 Packaging of low level radioactive waste.
Reference paragraph 4.
7.
Enforcement Conference An Enforcement-Conference was held at the University of Virginia Reactor Facility on October 22, 1984.
The following persons were in attendance:
a.
University of Virginia R. U. Mulder, Reactor Facility Director J. P. Farrar, Reactor Facility Supervisor D. Morris, Associate Dean, School of Engineering and Applied Sciences B. Copcutt, University of Virginia Radiation Safety Officer A. B. Reynolds, Acting Chairman, Department of Nuclear Engineering and Engineering Physics J. E. Henderson, Reactor Facility Health Physicist R. O. Allen, Chairman, Radiation Safety Committee R. S. Martin, Associate Legal Advisor J. S. Brenizer, Jr., Reactor Safety Committee Representative P. E. Benneche, Research Engineer, SR0 b.
Nuclear Regulatory Commission J. P. Stohr, Division Director, RII P. R. Bemis, Section Chief, Region II J. M. Puckett, Enforcement Director, Region II R. E. Weddingtor., Radiation Specialist, Region II A licensee representative took the NRC representatives on a tour of the reactor room and the area outside confinement where the excessive radiation level had existed to demonstrate how the event occurred and their corrective actions.
Licensee representatives then made a presentation for each of the violations and the deviation, outlining mitigating or extenuating circumstances, corrective actions and their position regarding the significance of each finding.
The Director, Division of Radiation Safety and Safeguards responded to the presentation.
The licensee's corrective action appeared to be timely and thorough and exhibited a positive management commitment toward ensuring future compliance.