ML20134F347

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Insp Rept 50-193/85-02 on 850611-12.Violation Noted:Failure to Maintain Documentation of Test Certification for Reactor Bldg Cleanup Sys High Efficiency Particulate Filters
ML20134F347
Person / Time
Site: Rhode Island Atomic Energy Commission
Issue date: 08/12/1985
From: Cioffi J, Clemons P, Shanbaky M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20134F323 List:
References
50-193-85-02, 50-193-85-2, NUDOCS 8508210068
Download: ML20134F347 (5)
v • d • e


See also: IR 05000193/1985002

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 85-02

Docket No. 50-193

. License No. R-95 Priority Category F

Licensee: Rhode Island Atomic Energy Commission

Nuclear Science Center

South Ferry Road

Narragansett, RI 02882

Facility Name: Rhode Island Atomic Energy Commission

Inspection At: Nuclear Science Center, Narragansett, RI

Inspection Conducted: June 11-12, 1985

Inspectors M. ~

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ean A. C16ffi, Radiatisfi Specialist

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Afercy ClemonT, ~ Radiatio,n/ Specialist' dat4

Approved by: M.,N <IM/

Mohimad Shantiaky, Chie'f VPWR Radiation

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Protection Section, EPRPB

Inspection Summary: Inspection on June 11-12, 1985 (Report No. 50-193/85-02)

Areas Inspected: Routine, announced inspection of previously identified items;

radiological controls - including posting, labeling, and access control,

contamination surveys, personnel exposur records, calibration of instrumenta-

tion; effluent monitoring, airborne eff ents, liquid effluents, and transport-

ation activities. The inspection invol d twenty-one inspector hours onsite by

two regionally based NRC inspectors.

Results: One violation - failure to maintain documentation of test certifica-

tion for reactor building cleanup system high efficiency particulate filters

(paragraph 4.1).

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DETAILS

1.0 Persons Contacted

  • M. Doyle, Director of Operations
  • N. Jacobs, Radiation Protection Officer

E. Spring, Reactor Facility Engineer

  • denotes those present at the exit interview.

2.0 Licensee Action on Previously Identified Items

2.1 (Closed) IE Circular (79-SC-09) Informs licensees of Scott Air Pack

Respirator problems noted in IE circular 79-09. The inspector discussed

the details of this item with the licensee and concluded that this was not

an issue of concern at this facility. The licensee does not use the

respirators.

2.2 (Closed) Violation (83-01-01) RIAEC failed to appoint a Health Physicist

on April 5, 1983. The licensee's corrective actions, as described in

Inspection Report No. 83-01, were verified by reviewing internal memoranda

which discussed the reassignment of responsibilities during the period of

the absence of a qualified health physicist. Additionally, the licensee

modified their organization to include two individuals, a Radiation

Protection Officer, and a Health Physicist, to insure adequate coverage in

the event of an emergency.

2.3 (Closed) Violation (83-01-06). Licensee failed to post outside door into

heat exchanger room with high radiation sign. The licensee's corrective

action, as documented in Inspection Report No. 83-01 and verified on a

tour, appears sufficient to prevent recurrence.

2.4 (Closed) Follow-up (84-02-11). Improve the ability of the stack sampling

equipment to obtain a representative sample. The stack sampling equipment

has been relocated to a point inside the reactor building, and fitted with

an isokinetic probe to assure representative sampling. The licensee is  !

gathering data to determine the effectiveness of the new sampling location

and is reasonably certain,with preliminary measurements,that the new

sampling location is providing more accurate data on the amount of argon

being released through the reactor building stack.

3.0 Radiological Controls

The licensee's program for radiological controls was reviewed against

criteria contained in:

restricted areas"

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+ 10 CFR 20.103, " Exposure of individuals to concentrations of radio-

active materials in air in restricted areas"

disposal"

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The licensee's performance related to the above criteria was determined

by a tour of the facility, a review of selected records, and discussions

with licensee personnel.

Within the scope of this review, the following was found:

3.1 Posting, Labeling and Access Control

The " restricted area", as defined in 10 CFR 20.3(a)(14), consists of the

Nuclear Science Center building. Access into the building is controlled

through one door which is kept locked, or under surveillance, at all

times. Keys to the door area issued only to Nuclear Science Center staff.

Section A.2 of Appendix A to the facility license states that the boundary

of the three acre Nuclear Science Center is considered the restricted area

for the reactor as defined in 10 CFR 20, and will be conspicuously posted

to prevent unauthorized entry. The boundary, as defined in the facility

license was not conspicuously posted. Furthermore this area does not

constitute the " restricted area", as defined in 10 CFR 20. The inspector

discussed this inconsistency with licensee representatives. The licensee

stated that they will seek an amendment to the license to redefine the

" restricted area" of the facility in more accurate language. This item

will be reviewed in a subsequent inspection (50-193/85-02-01).

3.2 Contamination Surveys

The inspector reviewed the licensee's contamination survey records cover-

ing the period January 1983 through December, 1984. No detectable

activity in any of the areas surveyed was noted.

No items of noncompliance were identified.

3.3 Personnel Exposure Records

The inspector reviewed personnel exposure records covering calendar years

1983 and 1984. The review indicated that, in general, personnel at this

facility receive no detectable exposures based on film badge results. If

some exposure is reported, the Health Physicist conducts an investigation

into the possible reason to assure that the reported dose is accurate.

All investigations are documented.

No items of noncompliance :cre identified.

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3.4 Calibration of Instrumentation i

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The licensee calibrates portable survey instruments three times a year.

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The licensee has a calibration facility which is kept locked during

periods of non-use. A flashing light signals personnel to stay clear of i

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the area during instrument calibration. Records of survey instrument  !

l calibrations were reviewed and found to be in order.

I , The licensee performs a functional check of area radiation monitors daily.

1 However, the inspector noted that no calibration of the detectors high

range (10 mR/ hour to 100 mR/hr) is performed. The inspector discussed

with the licensee the need to ensure that the area radiation monitors'

high range was operable. The licensee stated that they will establish a

calibration of the high range of the area radiation monitors on a routine

i frequency. This item will be reviewed in a future inspection.

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(50-193/85-02-02),

i No items of noncompliance were identified.

4.0 Effluent Monitoring

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4.1 Reactor Building Cleanup System

i The licensee has a cleanup ventilation system which is designed to

i activate when the reactor building evacuation button is pressed, isolating

the building ventilation and routing the air through a high efficiency  ;

i filter bank.

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! The cleanup system is required by the technical specifications to centain

j two absolute filters which have been individually tested and certified by

j the manufacturer to have an efficiency of not less than 99.97% when tested

! with 0.3 micron diameter dioctylphthalate smoke. However, the licensee

l could not provide the documentation to verify that the cleanup filter

! system met the requirements stated in the technical specificatiens. This

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is an apparent violation of the technical specifications (50-193/85-02-03).

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There has been no subsequent in place filter test performed on the (

clean-up system filters to ensure that the filter bank will perform as i

j stated in the technical specifications.

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i The inspector asked the licensee if any periodic evaluation was made of

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" Testing of Huclear Air-Cleaning Systems".the cleanup system's in

The licensee stated that

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in place filter testing was performed in October of 1971,,

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In a telephone conversation on June 24, 1985, with Dr. Shanbaky of the

Region I NRC staf f, and Mr. Doyle, the director of Operations for the

research reactor, Mr. Doyle stated that in place testing of the reactor

building clean-up system with D0P penetrant, will be performed in the near

future.

This item will remain unresolved pending further review by the NRC

(50-193/85-02-04).

4.2 Airborne Effluents

The inspector reviewed airborne release data for 1983 and 1984. The

licensee monitors for gaseous and particulate releases, as required by the

technical specifications, however, only argon is released to the environ-

ment. The yearly average of argon released in 1983 was 1.49 x 10-4 uti/cc.

In 1984, the yearly average of Argon released was 1.92 x 10-4 uC1/cc. The

inspector noted that these releases were less than 1% of the limits

specified in the technical specifications.

No items of noncompliance were identified.

4.3 Liquid Effluents

The inspector reviewed the licensee's liquid effluent release records for

1983 and 1984. In 1983, the licensee released 19856 microcuries of

activity (primarily 11-3). This amount of activity was higher relative to

previous years. The licensee stated that the increased amount of activity

discharged was due to extensive pool cleanup activities in an effort to

locate and isolate a reactor pool leak. In 1984, the amount of activity

released was 1520 microcuries of activity. All releases were within the

Ifmits specified in 10 CFR 20, Appendix B. Table II, Column 2.

No items of noncompliance were identified.

5.0 Transportation Activities

The inspector reviewed the documentation for a shipment of dry solid and

absorbed aqueous waste made on April 26, 1985. The waste shipment

consisted of approximately 90 cubic feet of spent resins and dry active

waste. The manifest reviewed met all the requirements specified in

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10 CFR 61.55, 61.56, and 20.311.

No items of noncompliance were identified.

6.0 Exit Interview

The inspector met with licensee management (denoted in Section 1.0) at

the conclusion of the inspection on June 12, 1985, to discuss the scope

and findings of the inspection as detailed in this report.

At no time during this inspection effort was written material provided to

the licensee by the NRC inspector.

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