ML20133P931

Insp Repts 50-160/85-03 & 50-276/85-02 on 850826-29. Violation Noted:Failure to Adequately Sample Liquid Waste During Release & Failure to Adhere to Tech Spec Requirements for Monitor Setpoints

ML20133P931
Person / Time
Site:	Neely Research Reactor, 05000276
Issue date:	10/09/1985
From:	Collins T, Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133P909	List: ML20133P908 ML20133P931
References
50-160-85-03, 50-160-85-3, 50-276-85-02, 50-276-85-2, NUDOCS 8511010266
Download: ML20133P931 (10)

See also: IR 05000160/1985003

Text

. _ . . _ . _ _ - . . _ _ _ . _ _ . . _ _ _ __

pn Ric UP$1T ED STATES

1. oq'o NUCLEAR REGULATORY COMMISSION

• [

g

' n REGloN 11

101 MARIETTA STREET, N.W.

j

t ATLANT A, GEORGI A 30323

\ ' " * *

/

. ,

OCT 181985

'

Report Nos.: 50-276/85-02 and 50-160/85-03

.

Licensee: Georgia Institute of Technology ,

225 North Avenue

Atlanta, GA 30332

Docket Nos.: 50-276/85-02 and 50-160/85-03 License Nos.: R-111 and R-97

Jacility Name: Georgia Institute of Technology

Inspection Conducted: August 26-29, 1985

Inspectors: -

-

Ab

'

M/&/&S'

] B/K.RevYin Date Signed

-

kkW

T. R. 'Co'l l i n s

. \

tahbr

Date Signed

i ,

Approved by: D4 NLW /c[7/[f

C.M. Hose'y,SektionChief Date Signed

i

Division of Radthtion Safety and Safeguards

4

i SUMMARY

Scope: This routine unannounced inspection involved 32 inspector-hours onsite in

the areas of radiation control, environmental protection, and transportation for

the Georgia Institute of Technology Research Reactor (GTRR). Also inspected were

disposition of radioactive material, confirmatory radiation and contamination

.

i

surveys and review of records associated with the termination of the operating

license for the AGN-201 reactor.

4

i Results: Two violations were identified: (1) failure to adequately sample

liquid waste during release, and (2) failure to adhere to Technical Specification

requirements for monitor setpoints and maximu:n release rates for gaseous

effluents.

8511010266 851018

'

PDR ADOCK 05000160

O PDR

____ _ . . . - . _ . _ - , _ . _ _ _ . , , , . _,,_,.,_.._-_m .

_ . _ _ . - . . _ , . , , _ _ . . , , _ _ _ . - . _ , , , _ , , , , , . , , _ _ _ , . . , , . . . . . . . - . _ . _ - _ _ -

_ . - _ . _ . . . _ _ _ ___ - _ _ _ _ _ _ _ _ _ _ _ . . ~ _ . _ _ _ _ -_ _ _ .._ ._

-

_ __

4

> .

REPORT DETAILS

1. Persons Contacted

i Licensee Employees

i R. A. Karam, Interim Director, Nuclear Research Center

i R. M. Beyd, Radiation Safety Officer

'

S. N. Millspaugh, Health Physics

P. B. Sharpe, Health Physics

i ,

2. Exit Interview ,

The inspection scope and findings were summarized on August 29, 1985, with

those persons indicated in paragraph 1 above. An apparent violation for

failure to adequately sample liquid waste during release (paragraph 6.a.(2))

, and an un-esolved item * (UNR) concerning radioactive gaseous effluent

4 release rates (paragraph 6.b(1)) were discussed in detail. Licensee

management acknowledged the inspection findings, taking exception only with

the UNR to which the licensee expressed the opinion that isolation of the

containment vent leading to the stack occurred upon receipt of the actuation

signal from, the Kanne ion chamber in a time frame sufficient to preclude

gaseous effluent release in excess of Technical Specification limits. The

i

licensee did not identify as proprietary any of the naterials provided to or

reviewed by the inspector during this inspection.

Licensee management was notified in a telephone conversation on October 9,

1985, between C. M. Hosey, of the NRC Region II staf f and R. A. Karam,

Interim Director of the Nuclear Research Center, that the unresolved item

concerning failure to maintain gaseous waste releases below applicable

limits, would be considered an apparent violation of Technical

Specification 3.5.b. The licensee was also informed that, failure to cease

gaseous effluent ' releases until the cause of the January 6,1984, release

was identified and corrected was identified as another example of an

apparent violation of T.S. 3.5.b. Failure to have the Geiger-Muller gas

monitor set to alarm and automatically isolate prior to gaseous waste

release exceeding the T.S. limit was idontified as a third example of an

apparent violation of T.S. 3.5.b. Failure to include in the gaseous

effluent release procedure methodology for calculating release rates

immediately preceeding and during exhaust duct isolation and to record

actual release rates were identified as an apparent violation of T.S.

.

6.4.b.(6).

• An unresolved item is a matter about which more information is required to

,

determine whether it is acceptable or may involve a violation or deviation.

l

l

l

l

_ _ _ ._, -. - _ _ _ _ _ _ _-

_. . . .- _ - - - - .

2 ,

!

3. Closecut Inspection and Survey (83890)

'

a. Disposition of Special Nuclear Fuel

The inspector verified that all fuel from the AGN-201 reactor (AGN) had

been physically relocated to the GTRR fuel vault and that all fuel was

accounted for. The AGN fuel had been transferred to the GTRR license

(R-97) by Amendment No. 6 which was reviewed by the inspector.

The fuel is to be transferred to the Department of Energy (DOE), Oak

Ridge, TN. The licensee is awaiting receipt of a fuel shipping cask

'

from DOE.

A radium-beryllium (RaBe) startup source had been retained by the

licensee and was transferred to Georgia Radioactive Material License

No. GA-147-1. The inspector reviewed License No. GA-147-1 to insure

,

that the RaBe source could be retained under that license.

a

b. Confirmatory Surveys

The inspector performed direct gamma, beta and alpha surveys on removed

internal reactor components which were stored in the basement of the

GTRR building. The AGN, which had been moved from the Emerson Building

to the protected area of the GTRR, was surveyed both internally and

i

externally. The room in the Emerson Building which had housed the AGN

was surveyed for gamma, beta and alpha radiation and contamination

smears of the room were obtained. The smears were returned to the f1RC

Regional laboratory for analysis. No radiation or contamination levels

above natural background levels were found.

Licensee surveys and inspector surveys had shown no loose surface

contamination to be present. Additionally, the licensee reported that

no loose surface contamination had ever been observed in the room

during the history of operation of the AGN. Consequently, environ-

mental surveys were not performed.

.

c. Reports and Records

'

1 The maximum whole body exposure received by personnel during 1984 due

to the AGN was 2 mrem which occurred during fuel removal. This

'

i exposure will be reported to the NRC in accordance with 10-CFR 20.407

, along with exposcres received due to the GTRR.

A licensee representative stated that the records required by

10 CFR 20.401(c) would be maintained by the licensee's radiation safety

i

office which continues to have an active radiation safety program

i associated with License R-97 and other non-NRC licensed activities.

l

- - .- -. - . -.. ~ ,- , - .- - - . - .~ , .- , . _ , . - -

- - . _ _ . . . - _ - _ - . . - - . - - - - . . .- .- -

i

l

l

i

3 l

.

I

d. Conclusions

The inspector verified by independent surveys that there was no

residual radioactivity in the AGN room in the Emerson Building, the

! reactor components in storage, or the reactor itself. Inspection of

j records and discussions with licensee representatives verified that all

special nuclear material had been transferred to License R-97 and the

,

RaBe startup source had been transferred to a Georgia state license.

.

4. Radiation Control (83743)

a. 10 CFR 20.201(b) required 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.

j

Technical Specification 6.4.b. required that written procedures shall

j be provided and utilized for radiation and radioactive contamination

, control.

The inspector reviewed the manual entitled " Health Physics Procedures,"

November 1983, and found that frequency for routine radiation and

, contamination control surveys was not addressed by this document. A

i

licenspe representative stated that the reactor facility complied with

the university-wide " Radiation Safety Manual" which addresses radiation

monitoring and control. The inspector noted that on page 1 of the

" Radiation Safety Manual" it was stated: "Special procedures apply to

j nuclear reactors which are present on the campus," which suggested that

i' the campus " Radiation Safety Manual" was not applicable to the GTRR.

The licensee acknowledged the comment and committed to revise the

" Health Physics Procedures" manual to include a statement which commits

the GTRR facility to compliance with campus " Radiation Safety Manual"

and its radiation and contamination survey frequency by November 1,

1985 (50-62/85-03-01). ,

i

The inspector reviewed the records of surveys for radiation and

! contamination control from January 1 to August 28, 1985. In general

j both radiation and contamination survey results were found to be low,

! 1.e., <0.5 mrem / hour and <100 disintegrations / minute removable.

No violations or deviations were identified.

b. 10 CFR 20.202 required that appropriate personnel monitoring devices be

worn by personnel likely to receive exposure in excess of 25 percent of

i the limits specified in 10 CFR 20.101 or who enter high radiation

areas.

I

10 CFR 20.101 stated the quarterly radiation exposure limits to the

whole body, skin of the whole body and extremities.

During tours of the facility, the inspector observed personnel

monitoring devices being worn. The licensee used film badges supplied

- - - - - - - . - _ _ _ _ _ _ _ _ _

__ . _ _ _ _ _ . _ _ __ . - _ , . . _ _ _ _ . , _ . _ . , _ __

- .- . . - _ -- - - - _ _ . _ - ~ . - -- - _ ~. _ .-._ . . . - - . -

i

4

l

4

1

,

i

by a National Voluntary Laboratory Accreditation Program (NVLAP) '

i approved contractor for measuring official dose. Beta, gamma and

neutron radiation was measured by these devices. In addition, the

licensee required personnel entering the reactor control zone to wear a ,

j CaF

2

thermoluminescent (TLD) chip which was processed onsite by the

licensee. Such devices were used to provide day to day dose control

, for personnel performing radiation work. Extremity rings were also

i' provided by the licensee in the form of TLD chips which were processed

onsite. Should an individual approach 25 percent of the quarterly

I

limit, a licensee representative stated that extremity monitoring

devices were then requested from its contractor for measurement of

i official dose. [

4

The inspector examined selected personnel exposure records from -

January 1 to June 30, 1985, and verified that exposures were being

,{ maintained below applicable limits. For 1985, the highest whole body

exposure through the month of June was 260 mrem.

!

No violations or deviations were identified.

c. 10 CFR 19.12 required that each employee who works in or frequents the

! licensee restricted area be given instruction in rediation protection

j commensurate with their duties and potential hazard.

l Theinspectorreviewedtheradiationworkg8courseoutlineandhand-out

material. Selected records of personnel' training were also reviewed.

i No violations or deviations were identified,

d. 10 CFR 20.203 stated the requirements for posting radiation areas, high

I

i

radiation areas and radioactive material areas.

During tours of the facility, the inspector noted the posting of

radiological areas and material and verified by independent survey that

,

'

,

.

such areas were adequately posted.

I

No violations or deviations were identified.

r

e. Technical Specification 6.4.b. stated that written procedures shall be

'  ;

provided and utilized for radiation control. -

[ Health Physics Procedure 8 required that any work involving the

i

' penetration of any port hole in the biological shield must be

authorized by use of Form RS-23, " Radiation Work Permit" (RWP).

The inspector observed an irradiation being performed at the thermal

neutron port under RWP No. 6245. The irradiation proceeded under

supervision of a health physics technician who performed gamma and  ;

neutron surveys as specified by the RWP.

l Ne violations or deviations were identified.

i

!

?_.,___.-,___ ---._c. . . - _ - . _ , _ . - . , - . _ . . . . - - - _ - . . _ - _ _ . _ _ _ , . _ , _ _ . . , . _ . _ _ _ _ _ .

_ . - _ _ _ _

. - . _- ._ _ .- - . . _ _ - _ _ - - _ - . - _ _ _

l

5

5. Transportation (86740)

I 10 CFR 71.5 required 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 Department of Transportation in 49 CFR,

Parts 170 through 189.

! The inspector determined that the licensee generated only small amounts of

waste from the reactor facility so that only 1-2 shipments are made each

i year for burial purposes. The licensee had contracted their waste disposal

program with an offsite contractor who, upon arrival at the site, took

i possession of the waste and acted as shipper and classifier based on data

'

provided by the licensee. The licensee provided data to the contractor

regarding quantities of radionuclides using isotope accountability

methodology.

f

j No violations or deviations were identified.

i

6. Environmental Protection (80745)

l a. Liquid -Effluents

l

l

(1) T9 chnical Specification 3.5.a.(1) specified tnat the concentration

of gross radioactivity, above background, in liquid effluents

discharged from the Reactor Building, excluding tritium, shall not

exceed 3 X 10 ' pCi/ml.

i

i Technical Specification 3.5.a.(4) required that the total annual

! quantity of gross radioactivity to be released in liquid effluents

from the reactor facility shall not exceed one curie to the

sanitary sewage system,

t

!

The inspector reviewed the records of liquid releases from

i October 4, 1984, to August 15, 1985, and verified that liquid

I releases had not exceeded the above limits. In 1984, approxi-

!

mately 42 mci had been released to the sanitary sewer from the

,

reactor facility.

, No violations or deviations were identified.

l (2) Technical Specification 3.5.a.(5) required that during release of >

liquid radioactive effluents, two independent samples of each tank .

j shall be taken, one prior to release and one during release; and '

! that an independent sample shall be taken from the discharge line

during release.

Examination of liquid effluent release records from October 4,

l

'

1984, to August 15, 1985, and discussions with licensee repre- -

sentatives revealed that tank sampling prior to release had been

performed routinely; however, no sample had been taken from the

tank during releases. Failure to sample the tank during release

l

,

- - . - . . - _ _ , _ . _ - _ _ , , _ , . - , _ , , _ _ . - - , - - , , , - . . . , . _ , , - . _ . - - , . _ ,

_ __ _ _ __ _ . _ _ __ _ _. _ _ _ _ _ _

0 -

.

6

was identified as an apparent violation of Technical Specification 3.5.a.(5) (50-160/85-03-01).

The inspector determined from liquid release records between  !

October 4, 1984, and August 15, 1985, that on October 4, 1984,

November 9, 1984, April 24, 1985, June 10, 1985, and June 11,

1985, samples from the discharge line were not taken during

i release.

Failure to sample the discharge line during the releases was

identified as a second example of an apparent violation of

!

Technical Specification 3.5.a.(5)(50-160/85-03-01).

,

b. Gaseous Effluents

Technical Specification 3.5.b specified the requirements for the

release of gaseous radioactive effluents from the facility.

1 (1) Technical Specification 3.5.b.(1) required that the maximum rates

of gross radioactivity in gaseous effluents not exceed 585 pCi per

1 second of Argon-41 equivalent.

l Technical Specification 3.5.b.(4) required that if tha maximum

I

release rate of Argon-41 equivalent gaseous effluent is exteeded,

! the gaseous discharge from the facility shall not be resumed until

l the cause of the excessive discharge is identified and corrected.

1

Technical Specification 6.4.b.(6) required that radiation con'.rol

] procedures be provided and utilized.

i

Technical Specification 6.5.b.(1) required that r ecords' and logs

of gaseous waste released to the environs be prepared and retained

at the facility for the life of the facility.

,

The inspector reviewed the atmospheric waste log for January 1,

l 1984, through July 1985, and noted that based on the concentration

(microcuries per cubic centimeter) and the exhaust flow rate on

January 6,1984, March 9,1984, September 21, 1984, December 11,

,

1984, and January 16, 1985, concentrations of radioactivity in

gaseous effluents in excess of 585 pCi per second were determined.

,' The release rate on January 6,1984, was estimated to be approxi-

mately 1323 pCi/second. The licensee informed the inspector that

the rates receded in the log were calculated for release at the

tip of the stack and took into account dilution flow from the

} stack fan. Examination of stHp chart recordings from the Kanne

ion chamber used to monitor gaseous releases showed peaks

j corresponding to activity in excess ' of 585 pCi per second for

these dates and that in each incident, containment isolation had

occurred on actuation signal from the Kanne detector.

i

!

l

l

i

.

!

-_. -

. _ , ._, . , _ - . , _ _ . _ _ ~ _ _ _ . _ _ _ . - . _ _ _ - . _ . _ , _ _

_

_ .-. . - . .. - . _ _ _ _

_ - - .

.

7

i

The licensee had conducted an investigation of the January 6,

1984, event and determined that containment isolation had been

achieved on an actuation signal from the Kanne ion chamber. Tests

conducted by the licensee demonstrated that an actuation signal

was initiated at the correct setpoint of 585 pCi per second

resulting in containment isolation. During the test, the licensee

noted that the strip chart recording from the Kanne detector

exhibited a continuing rise af ter isolation had been achieved,

which was attributed to an over-response of the Kanne detector.

The licensee concluded that with the containment building

isolated, Ar-41 could not be released regardless of the apparent

activity rate shown on the chart recordings. None of the other

release events were investigated.

Through reviews of records and discussions with licensee

representatives, the inspector determined that when the GTRR was

operating at 100*4 power under normal conditions, the gaseous

4

release. rate approaches the T.S. limit of 585 pCi per second. The

I

inspector noted that any perturbation in the system (i.e.,

'

withdrawal or insertion of a plug in the reactor) could result in

an increased release rate. The inspector also stated that since

the Karne detector sampling point for gaseous effluents was

i' dgwnstream from the isolation valves, even if containment

isolation were initiated by a signal from the Kanne detector, the

higher activity gas already present downstream from the isolation

valves would be vented to the stack. Main exhaust duct and Kanne

sampling line velocity calculations performed by the inspector

i revealed that the main exhaust duct velocity was approximatly

350 feet per minute greater than that of the ion chamber sampling

line. Therefore, the radioactivity would have already passed

downstream of the exhaust duct isolation valve prior to

'

transmission of an isolation signal from the Kanne detector.

After isolation occurred, radioactivity present in the approxi-

mately 20 foot run of exhaust duct between the isolation valve and

point of introduction into the main stack would continue to be

discharged into the stack. The gaseous effluent thus released

would be due to the inertia of the air in the exhaust duct and the

suction drawn on the exhaust line by the main stack flow,

i

A licensee representative stated that due to the action of the

dilution fan in the stack it was felt that the Technical

.

Specification limit had not been exceeded. No data were available

1 to substantiate this view. Under normal operating conditions, the

licensee applied a dilution factor to the radioactive effluent

concentration indicated by the effluent monitor to account for

, dilution of the radioactivity in the main stack. Whenever

l isolation occurred due to an isolation signal from the Kanne

!

detector, the licensee noted in their effluent log that the

j release rate had been 585 pCi per second. Though this latter

release rate may be less than indicated by the effluent monitor,

--_.. - -_- .- ._. - - . , - , - - - , . .

. - - _ -

_ - - - - - . - .- . - . _ - - - - - - . - - - . - - - .

.

a

8

I

the licensee had no means of establishing what the true release

rate was immediately preceeding and during exhaust duct isolation.

'

Failure to maintain gaseous effluent release rates below

585 pCi/second on five occasions between January 6, 1984, and

) January 16, 1985, would be a violation of T.S. 3.5.(b). During

further reviews of licensee records, the inspector noted that the

i licensee did not initiate an investigation of the January 6, 1984,

exhaust system isolation based on high release rate until late

February 1984.

Gaseous releases continued between January 6 and late

February 1984. Failure to cease gaseous effluent releases until

the cause of excessive releases was determined and corrected would

, be another example of an apparent violation of T.S. 3.5.(b).

i The inspector also noted that the licensee's procedure for gaseous

i

effluent releases did not contain the methodology for determining

the gaseous effluent release rates immediately preceeding and

during exhaust duct isolation. Nor did the procedure require the

'

actual release rate to be recorded. As previously stated, the

licensee recorded 585 pC1/second when isolation occurred even

! though evidence was available to indicate the rate was higher.

Failure to have an adequate procedure for determining gaseous

release rates and documenting the results under all conditions

l would be an apparent violation of T.S. 6.4.b.(6).

'

(2) Technical Specification 3.5.b.(5)(b) required that during release

-

of gaseous radioactive effluents, both gross radioactivity

=

monitors shall be set to alarm and automatically isolate the

1

gaseous waste releases prior to exceeding the release rates of

585 pC1 per second.

l

!

The containment building exhaust was monitored by two devices, a

j

'

Geiger-Muller detector (gas monitor), which samples the

containment exhaust between the containment and the isolation

-

valves, and a Kanne ion chamber, which samples the exhaust between

l the isolation valvet an the stack. Both monitors have the

i capability of isolating . containment when their setpoint is

reached. The Kanne detector isolates at an absolute value

!

(concentration of radioactivity) while the gas monitor initiates

isolation at 90% of full scale regardless of the range setting.

l From an investigation conducted by the licensee's staff, it was

i determined that on January 6, 1984, operations personnel - had

l' ranged the gas monitor up by two decades such that the gas monitor

was incapable of alarming and automatically providing isolation of

1 the gaseous waste release prior to exceeding the release rate of

l 585 pCi per second of Ar-41 equivalent.

l Failure to have the Geiger-Muller gas monitor set to alarm and

! automatically isolate the gaseous waste release prior to exceeding

. - _ _ . . -

.

.

9

the release limit would be an apparent violation of Technical

Specification 3.5.b.

The inspector stated that failure to meet the requirements for

release of gaseous radioactivity discussed above would be

considered an unresolved item pending further review by the

Regional Technical Staff and Management (160/85-03-02).

(3) Technical Specification 4.2.e. and 4.2.f. required that the

charcoal cartridge sampler on the containment building exhaust

shall have a radioisotopic anab sis performed biweekly and that

grab samples of the exhaust stack effluent shall be obtained and

have a radioisotopic analysis performed monthly.

Technical Specification 4.4.d. specified that samples of the

secondary coolant system shall be analyzed for tritium on a

monthly bases.

The inspector reviewed the licensee records for the above samples

from January 1, 1985, to August 20, 1985, and determined that

timely samples had been obtained and analyzed as required.

No violations or deviations were identified.

i

I

.-_ ._. . ... - - . - - . .