ML20135E580

Responds to Violations Noted in Insp Rept 50-059/96-01. Corrective Actions:Completed Insp of AGN-201M Facility,Gave Copy of Required Quarterly Audits to J Holste & Made AGN-201M Facility Permanent Agenda Item

ML20135E580
Person / Time
Site:	Texas A&M University
Issue date:	12/03/1996
From:	Haden C TEXAS A&M UNIV., COLLEGE STATION, TX
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9612110349
Download: ML20135E580 (31)

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J.88 k ENGINEERING PROGRAM THE TEXAS A&M t NIVERSITY SYSTEM 301 Ree 1.. WienNker i nyincenng Rewart h Ci titi t letas A W l'aimrwiry = Collegs Statiosi. lcsas 77h43 3126 - (4(M 8451321

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! December 3,1996 i

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! U.S. Nuclear Regulatory Commission ATrN: Document Control Desk j Washington, D.C. 20555 j

SUBJECT:

REPLY TO A NOTICE OF VIOLATION j i

Dear Sir:

.l In accordance with NOTICE OF VIOLATION submitted to Texas A&M University, Docket No:

j 50-059, License No: R-23 the following is a written explanation for each of the three violations

! cited in NRC Inspection Report (50-059/96-01). Each Reply to a Notice of Violation is formatted in accordance with ENCLOSURE 1 of the Report.

If any other information is required in this matter please contact Dr. John W. Poston Sr., Head of the Nuclear Engineering Department and Reactor Administrator at Texas A&M University.

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l C. Roland Haden l Vice Chancellor and Dean of Engineering l Director, Texas Engineering Experiment Station

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Enclosure .

pc: Dr. James C. Holste Dr. John W. Poston, Sr.

Mr. Robert Berry 9612110349 961203 PDR ADOCK 05000059 G PDR 100042 1

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l Reply to a Notice of Violation Three separate Severity Level IV violations were noted during the last inspection of the AGN-201M reactor facility, this letter is intended to be a written statement to address these NRC Inspection Report (50-59/96-01) violations.

l Failure to Perform Quarterly Audits Severity Level IV violation (50-059/96-01) has been noted and accepted by the licensee. I This violation concerns the required quarterly audit which is performed by members of the Reactor Safety Board. The I individual performing the audit then reports the results to '

the Head of the Department of Nuclear Engineering and to the Reactor Safety Board at the next meeting. The requirements ,

for the scope of these audits and inspections are clearly '

detailed in the Technical Specifications.

The lack of properly documented audits conducted by the Reactor Safety Board stems from a breakdown in the lines of  !

communication between the Chair of the Board and the I Department. Dr. John Poston, as an ex-officio member of the l Board, attempted on numerous occasions to get the Board to i honor their responsibilities for the quarterly audits. The I root cause of the problem was the change in Chair of the l Board (three times in the past four years)and an inadequate '

transfer of responsibilities from one chair to the next. The level of knowledge regarding AGN-201M operations and requirements decreased with every change in personnel. The current Chair was unaware of many of his responsibilities for the required audits of the AGN-201M facility. Some efforts were made prior to the inspection to place discussions of the AGN-201M as the first agenda item at i every Reactor Safety Board meeting. But, this had not been implemented prior to the inspection.

In order to properly remedy this situation, the following corrective actions have taken place.

1) The current Chair of the Reactor Safety Board, Dr. James Holste was briefed by both the NRC inspector Dr. Blair Nicholas and Robert Berry AGN-201M reactor supervisor about the AGN-201M inspection and problems noted concerning audits conducted by members of the Reactor Safety Board.

2) On :tober 9, 1996 Dr. Holste and Robert Berry completed an inspection of the AGN-201M facility. Dr.

Holste was given a copy of the required quarterly audits for the facility and subject areas to be included in other

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f Reply to a Notice of Violation audits. The list of required audits included Technical Specifications and applicable license conditions l 3) AGN-201M facility has been made a permanent agenda item

! on the Reactor Safety Board agendas. This will ensure that l business concerning the AGN-201M will be addressed at every l meeting. If the AGN-201M facility has no business to conduct at that meeting, this will also be noted in the minutes of the meeting.

4) At th6 December 6th Reactor Safety Board meeting all board members will receive a copy of the NRC Inspection Report and the Technical Specification requirements for audits of the AGN-201M facility. At this meeting the Chair will assign auditors for the next year (i.e.,1997).

5) A copy of the audit report form also will be provided at this time. This form will have a signature line to document review by the Head of the Department of Nuclear Engineering as well as the Chair of the Reactor Safety Board. A copy of this form is included in Appendix A.

6) In order to meet the bi-annual review requirements of the Facility Security Plan and Facility Emergency Plan and implementing procedures, these reviews will be held in conjunction with the review of the bi-annual Reactor Emergency Drill. Since this drill requires a great deal of coordination with outside agencies and prior planning, joining all of these reviews together will ensure that all requirements are meet. The drill is conducted every other January. These review items will be placed specifically on the agenda for the next Reactor Safety Board meeting of the year

7) The reactor supervisor has been made an ex-officio member of the Reactor Safety Board. This was done to ensure that all required audit / reviews and activities of the AGN-201M facility are appropriately reported to the Board Full compliance with the Technical Specifications 6.1.6 and 6.4.3 will be met after the Reactor Safety Board Meeting on December 6, 1996 l

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Reply to a Notice of Violation l

l The second Severity Level IV violation the lack of an l Annual Radiation Protection Program Review (50-59/96-02) is I being contested by the licensee. Annual reviews of the Radiation Protection Program are conducted in December of  ;

each year. A letter from the Radiation Safety Officer and copies of the annual reviews performed in 1994 and 1995 are included with this response in Appendix B.

The required radiation program reviews including the AGN-201M facility were submitted on December 16,1994 and i December 21,1995. These reviews were intended to meet the l requirements of 10 CFR 20.1101(c) . l 1

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4 Reply to a Notice of Violation 1 4

'; The third Severity Level IV violation concerning the )

annual reviews by the Reactor Safety Board of the AGN-201M i Reactor Facility Security Plan (50-59/96-03) and lack of 4 reporting in the facility's annual report is accepted by the

! licensee.

1) The annual review will be performed during the Reactor j Safety Board meeting on December 6,.1996. .

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2) The Reactor Facility Security Plan and implementing I i procedures will be reviewed during the first Board meeting i in 1997. In the future the annual review of the AGN-201M j' Reactor Facility Security Plan will be conducted during the

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first Board meeting every year.

3) The' outline of the annual report for the AGN-201M has i been modified to include a separate entry for recording the

date of the annual review of the AGN-201M Reactor Facility  ;

i . Security Plan by the Reactor Safety Board.

i Full compliance with Section 3.5 of the AGN-201M Reactor l Facility Security Plan will be met after the Reactor Safety 4

Board Meeting on December 6, 1996.

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! TEXAS A&M UNIVERSITY DEPARTMENT OF NUCLEAR ENGINEERING Reactor Safety Board Quarterly Audit of AGN-201M Reactor Operations *  :

DATE OF AUDIT: j ACTIVITY AUDITED:

RESULTS OF AUDIT:

General Records properly maintained l

Information readily accessible Activity performance as specified COMMENTS:

i RECOMMENDATIONS:

Auditor llead of the Department of Nuclear Engineering l

l Chair of Reactor Safety Board

• attach all necessary documentation to this form

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Appendix B ,

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l TEXAS A&M UNIVERSITY Environmental Health and Safety Department l

i Sotery and Health Radiological Sofety College Station. Texas 77843-4472 Diving Sofety (409) 845-2132 College Station. Texas 77843-3261 (409) 862-4043 FAX (409) 845-1361 E-mail: Safety @tomu.edu November 21,1996 (409) 845-1348 FAX E mait:. Rad-Sofetyctamu.edu MEMORANDUM To: John .W. Poston, Sr.

Professor and Head Department of Nuclear Engineering

Subject:

Radiation Protection Plan Review, AGN-201 Reactor During the last USNRC inspection of the AGN-201 reactor, I was not asked by the inspector to provide a copy of the annual radiation protection program review. Shortly after that inspection, you called to ask whether my office had been performing an annual review of the radiation protection program as required in 10 CFR 21.1101(c). I informed you that we had. At your request,I placed a telephone call to USNRC Region IV Headquarters in Arlington. Mr. Blair Nicholas was not in the office on that day, so I left a message with the receptionist asking that he return my call. He has not returned my call, nor have I made any further attempts to contact him.

Enclosed please find copies of the reviews performed by this office for calendar years 1994 and 1995.

Please do not hesitate to call ifI may be further assistance.

Y LLLf,bb Christophe Jf. Meyer, C.H.P. i Radiological Safety Officer and Interim Director, Environmental Health and Safety Department x

. RADIATION PROTECTION PROGRAM: 1994 REVIEW Office ofRadiological Safety Texas A&M University Texas A&M University holds several state and federal licenses and state registrations which authorize the use ofbyproduct radioactive materials, source materials, special nuclear i materials, and radiation producing devices. In accordance with state and federal regulations (TRCR 21.101(c) and 10 CFR 20.1101(c), respectively) this report reviews the content and implementation of the radiation protection program for the calendar year 1994. j l

This report includes review of activities conducted under the following licenses and  !

registrations: ,

License Number Issuina Anency  !

LOO 448 Texas Department of Health, Bureau of Radiation Control I R00304 Texas Department of Health, Bureau of Radiation Control )

R14497 Texas Department of Health, Bureau of Radiation Control i R14498 Texas Department of Health, Bureau of Radiation Control RWO448 Texas Natural Resources Conservation Commission 42-09082-09 United States Nuclear Regulatory Commission SNM-1518 United States Nuclear Regulatory Commission R-23 United States Nuclear Regulatory Commission Review ofExternal Dosimetry Data As of this date, dosimetry data are available for the first three quarters of 1994. The TAMU dosimetry program is not subdivided by license or registration and the data presented below are not easily attributable to specific licenses or registrations. However, where such distinctions can be made, the data will be so noted.

On January 1,1994, the dosimetry program at TAMU was drastically reduced in scope.

Procedures were developed and implemented in 1993 to identify those persons needing dosimetry after January 1,1994 in view of the impending regulatory changes. The number of participants were reduced from greater than 2,000 to approximately 400. At present, the dosimetry program is extended to cover the TEES Nuclear Science Center only for administrative ease. The NSC is separately licensed by the USNRC (License No. R-83) and is responsible for complying with all regulatory aspects of their own dosimetry program. The Institute for Biosciences and Technology in Houston is still receiving dosimetry services through the ORS for approximately 60 persons.

Since IBT was issued its own license from TDH (on or about the first of October,1994), they will contract for their own dosimetry services (separately) beginning January 1,1995.

Table 1 contains cumulative doses for 1994 for all participants in the TAMUS dosimetry program excluding the Nuclear Science Center. Numerous difficulties with the dosimetry vendor were encountered in 1994, especially early in the year. The most vexing problem was the x-

, vendor's recurrent loss cr misapplication of control dosimeter readings. This resulted in large sets of dosunetry results being returned with uniform positive readings (20 to 40 mrem per quaner).

While these readings were not altered for the permanent personnel records, it is interesting to note that those readmgs accounted for more than 50% of the total cumulative dose through the first three quarters.

Table 1: Cumulative Doses at TAMUS,1994 Number of Cumulative doses Extrapolated Doses Group Panicipants throuah 3rd Otr. throuah 4th Otr.

TAMUS (excl. NSC) 360 4800 mrem DDE 6400 mrem DDE.

4870 mrem LDE 6490 mrem LDE 5100 mrem SDE,wb 6800 mrem SDE,wb highest individual 5650 mrem SDE,me 7530 mrem SDE,me TAMUS (excl. NSC, 360 2250 mrem DDE 3000 mrem DDE

. correcting for no 2320 mrem LDE 3090 mrem LDE control dosimeters) 2550 mrem SDE,wb 3400 mrem SDE,wb The maximum extremity dose was received by a Vetermary Medicine Nuclear Medicine Technician who prepares and administers I-131 for thyroid ablation therapy in felines. Effons to .

reduce doses, whole body and extremity, are being implemented and should manifest themselves l in the form oflower doses in the 4th quarter of 1994. The next highest extremity doses were to i an x-ray technician in veterinary medicine (2220 mrem) and to an employee of the Center for Chemical Characterization and Analysis (1960 mrem) who performs neutron activation analysis )

on large numbers ofsamples.

The AGN-201 reactor (License No. R-23) did not operate in 1994. Bob Berry, Senior Reactor Operator, had a 3rd quaner cumulative dose ofMinimal.

As a result of the downsizing of the dosimetry program, the ORS has realized a number of benefits other than reduced administrative workload. Among the chief benefits are:

1. Much more attention can be focused onto those individuals receiving the highest doses. Staff time available for investigation of elevated doses is increased so that more investigations are done at lower dose levels.

2. Lost or damaged dosimeters are tracked and reported on in a more timely manner

3. Increased use of radiation detectors has been observed in some laboratories presumably because dosimeters are no longer available to provide a false sense of security.

As a quality check on the decision to terminate dosimetry services for many TAMUS employees, a program was established whereby 10-15 dosimeters (whole body and rings) were distributed each calendar quaner by the ORS to selected persons in selected laboratories. The l

selections were not truly random. Each quarter, receipt records were reviewed to determine which Sublicensees had recently received the most radioactive materials. These Sublicensees were then contacted by telephone and asked to identify one or more persons in their laboratories 1

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yvho sh'o uld be receiving the highest doses. Those persons wtre then provided dosimeters for that calendar quarter. Results are summarized in Table 2 below:

Table 2: Results of Dosimetry " Quality Check" Numbers ofIndividuals falling within Dose Range Dates Dose Ranoa DDE LDE SDE wb SDE.me 1st Qtr' Minimal 9 9 9 5 (10 issued) <50 mrem 1 I 1 2 50 -100 0 0 0 1 860 mrem 0 0 0 1 2nd Qtr* Minimal 13 13 12 4 (15 issued) <50 mrem 1 1 1 7 150-200 0 0 1 3 360 mrem 0 0 0 1 3rd Qtr Minimal 14 14 14 10 (14 issued) < 50 mrem 0 0 0 3 530 mrem 0 0 0 1

' In 1st Qtr. one person lost their extremity dosimeters. Investigation of the 860 mrem exposure resulted in protocol changes. That individual was monitored again in the 2nd 4 quarter and his maximum extremity dose was reduced to 200 mrem. i 8 In 2nd Qtr. one person lost their whole body dosimeter j Dose monitoring for the embryos and fetuses of ten Declared Pregnant Females was performed in 1994. The maximum doses measured were 20 mrem in one month and 20 mrem total. Urine bioassays were performed to monitor for radioactive materialintakes in those DPF who were actively working with radioisotopes during their pregnancy. No intakes were identified.

Review ofInternal Dosimetry Data Routine thyroid bioassays were performed on persons using quantities ofIodines in excess of I mci per calendar quarter. No intakes were identified in 1994.

Non-routine urine bioassays were perfonned on two persons using approximately 1 Curie of H-3 for a short-duration synthesis. The procedure was conducted over a period of '

approximately one month. No intakes were identined in 1994.

Radiation Safety Training and ORS StaffImprovement Radiation safety training was expanded in several ways in 1994 in an effort to enhance the availability and convenience of training classes. Videotaped training continued to be very popular amongst campus users. Beginning in May of 1994, the standard 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (given over 5 consecu-tive weeks) radiation safety training course was offered as a one day class. The one day format allowed the ORS to condense the training into six hours. Student feedback was very positive 1

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, prompting us to make the class a regular offering immedittely before the beginning of each semester (typically January, May and August). These classes will be held in addition to the standard 5 week format classes in the fall and spring.

A training video was developed specifically for users of moisture and density gauges. This training session provides condensed training applicable to use ofportable gauges thereby fdling a significant void in the ORS training program. Additional training tapes are currently being planned ORS Staff received training in 1994 on several topics. An eight hour training class on DOT regulations for shipping, transporting and receiving hazardous materials (including radioactive materials) was held on September 12,1994 and was attended by Carsten, Johnson, l Menchaca, Meyer, and Rodriguez. These same individuals attended the two day regulatory l-conference held on August 18 and 19 in Austin. Douglas Johnson also attended a one week -

course on mammography and a one day course on environmantal regulations through the U.S.

Naval Reserve.

In 1994, Douglas Johnson was licensed as a Medical Health Physicist in the State of Texas. Christopher Meyer received Comprehensive Certification from the American Board of Health Physics. 1

Procedures l

l In 1994, the Office of Radiological Safety Staff embarked upon a major revision of the ORS Procedures Manual for the Use of Radioisotopes and Radiation Producing Devices. The intent of the effort was to convey information to permitted users of radiation (including laser users) more efficiently. Another aim was to proceduralize the routine functions of the ORS where i procedures had not existed heretofore. As of December 1, this effort was approximately 40% {

l complete. l l

Office Finances and Eapiament/ Software Purcham The ORS budget was incrcased by $25,000 to a total of $375,000 in Fiscal Year 1994 I (September 1,1993 through August 31,1994). This increase was granted despite a drastic reduction in support from the State of Texas (Radiological Safety is a Special Line Item on the  !

University Budget). The total TAMU contribution to the ORS budget rose from 0 to approximately $86,000 in FY1994. The budget for FY95 was further increased to approximately  !

$378,000.

The ORS provided numerous commercial services during 1994 which augmented the l budget. The ORS Staff conducted six training classes in 1994 which ranged in duration from 2 ,

l days to 3 weeks. In addition, monthly surveys of USDA laboratories netted $3,000 and contracted irradiation services netted approximately $6,000. This income plus that from previous years allowed the ORS to make several important capital equipment purchases 1) two j MicroRem survey meters from Bicron; 2) computer network capability and a soilware package

! designed to integrate inventory management and other routine health physics management l

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functions (dosimetry, training, calibr;tions, etc.), and 3) a Packard Mod:1 TR2500 Liquid i Scintillation Counter. These capital purchases are extremely important to the ORS and to our effons to improve the radiation safety program at TAMU.

Radipactive Waste Disoonal The only disposal facility which would accept radioactive waste from Texas generators closed June 30,1994. TAMU made one waste shipment in May,1994. That shipment virtually eliminated all stored solid waste which had accumulated. Each TAMUS College and Department which had generated waste paid a share of the disposal cost, approximately $140,000. Since that time, detailed records have been kept by the ORS which document the financial responsibility of each individual and dep.6a.: for ultimate disposal of wastes which have been collected but cannot be disposed. A Texas disposal facility should be available to accept waste from TAMU by 1997.

Maximum use of BRC-approved alternate disposal methods continues at TAMUS.

Among these methods are those allowed under TRCR Part 21.1304(a), (b), and (d) as well as J TRCR Part 21.1003.

l Inspections and Audits of the ORS The ORS was inspected twice in 1994. Once by the Texas BRC and once by the U.S.

EPA. No violations were identified.

Thineen TAMUS remete ;ites were inspected by the Texas BRC in 1994. Ten of the inspections resulted in no violatiou issued. Three of the inspections resuhed in a total of eleven violations. Each violation has been corrected by the ORS and closed-out by the BRC.

1 Reports from Senior Staff l t

l Attached are brief reports provided by each ORS Staff Member on ALARA-related activities performed in 1994.

1 Report Submitted By: h M JM tR d Date: /2/6!9 0 ()

Resiewed By: /A$ 2 $h;I Date: /2b2/9y Radiological Safety Officer I

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l TEXAS A&M UNIVERSITY  :

COLLEGE STATION,TIXAS 77843-3261  ;

Radiologimi Safety (409)S45 1361 ,

(409)R451348-FAX l December 13,1994 MEMORANDUM i TO: Chds Meyer, Associate Director Office of Radiological Safety 1

FROM: Douglas A. Johnson, Senior Health Physici '

Office of Radiological Saferv 1

SUBJECT:

1994 Radiation Protection Progam Review ]

REFERENCE:

TRCR 21.101(c)

1. The Student Health Center has implemented procedural and training changes which have  ;

resulted in a significant decrease in radiation exposure to patients. The x-ray retake mie has  ;

dropped from a high of 11.66% in April (first month of data available) to 4.80% in October  !

(last month of data available).

2. The Office of Radiological Safety Waste Shed has significantly reduced levels of radiation after a shipment of waste in May. A further decrease was achieved in November when the shielded storage area was redesigned. Current radiation levels are now about 750 R/hr at one meter fror@ shielded area.

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l File: 12/W AIARA revww i

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. ALARA Review - West Campus

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1. Brachytherapy Stall A. Replaces temporary arrangements B. Dose to public will be well under 2 mrem /hr and 100 mrem /yr even at high usage, > 50% occupancy; Current occupancy < 10%.

2 II. Nuclear Medicine Program Reviewed 1 f A. New written operating procedures 4

{ B. Radiation safety procedures reviewed and updated 9

i C. Dose reduction program begun for Nuclear Medicine staff 4

j 1. Structural shielding and use of syringe shields reviewed i 2. Hot lab design modified to minimize exposure of Nuc. Med.

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D General Electric technician adjusted large animal camera to improve image

[ quality i E. Member of Brazos Valley Medical Center (BVMC) Nuclear Medicine staff

} . consulting with TAMU Vet. Nuc. Med. staff )

1. Improving image quality by updating procedures and adjusting

i. image acqt.a.ition systems a

2. Discussed radiation safety in Nuclear Medicine

3. TAMU Vet. Nuc. Med technicians traveling to BVMC to observe Nuclear Medicine staff Ill. Routine Bioassays for Nuc. Med. Personnel IV. Personnel Dosimeters A. All Nuc. Med. and Radiology staff are badged (monthly or quarterly)

B. Pocket' dosimeters required for personnel assisting in radiography and I brachytherapy

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. l l l ALARA Input for Cyclotron Institute 1994  !

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l Roofover K500 Cyclotron 3 The roofover the K500 Cyclotron has been monitored as part of an ongoing project to ascertain the levels in unrestricted areas Initially, a single dosimeter was situated at the i assumed location of highest dose equivalent. This study led to the determination that the roof area was not an unrestricted area. Phase two of the study consisted of a definition of a

field contour with regard to the site of highest dose equivalent. Based upon the results of the field contours, a fence was constructed to restrict access as appropriate.

Training l l

i Machine specific operating procedures were developed as well as health physics training for the machine operators. Training will occur approximately Spring 1995.

i B21 l Shielding around the cobalt 60 irradiator was checked and increased as necessary. Also

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redesigned the calibration range source box to minimize user exposure. Additionally, rearranged and relocated sources stored within the room to minimize exposure to

); individuals working in the area.

1 Surveys l Surveys were performed at the Riverside campus to ensure that no radioactive material l was stored at an inappropriate location. Micro rem measurements were also performed at the cyclotron as well as other locations on campus to guard against unnecessary exposures.

Adminierative Took control of the wall plug bypass key to help prevent inadvertent entries that might j result in exposure.

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. RADIATION PROTECTION PROGRAM: 1995 REVIEW i '

Office ofRadiological Safety Texas A&M University 1

Texas A&M University holds several state and federal licenses and state registrations l which authorize the use of byproduct radioactive materials, source materials, special nuclear i materials, and radiation producing devices. In accordance with state and federal regulations j (TRCR 21.101(c) and 10 CFR 20.1101(c), respectively) this report reviews the content and j implementation of the radiation protection program for the calendar year 1995.

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This report includes review of activities conducted under the following licenses and d

registrations:

l License No. Issuinn Anency l LOO 448 Texas Department of Health, Bureau of Radiation Control R00304 Texas Department of Heahh, Bureau ofRadiation Control l

R14497 Texas Department of Health, Bureau of Radiation Control R14498* Texas Department ofHealth, Bureau of Radiation Control 6

RWO448 Texas Natural Resources Conservation Commission 42+yo82-09 United States Nuclear Regulatory Commission SNM-1518 United States Nuclear Regulatory Commission R-23' United States Nuclear Regulatory Commission

• Registration No. R14498 authorizes one cabinet x-ray device at the Texas Forest Service facility

. in Lufkin, Texas. That device was not operated in 1995, therefore, a radiation survey and interlock check of that device was not performed. Such procedures shall be performed and the facility inspected by the TAMU Office of Radiological Safety before the device is next operated.

6 License No. RWO448 authorizes only radioactive waste which has already been busied in a now closed and capped landfill. A radiation protection program specific to that license does not exist.

The site remains closed and there were no activities associated with this license in 1995.

• Reactor License R-23 is for the AGN-201 reactor in Zachry Engineering Building. To date in 1995, that reactor has been nonfunctional. Reactor Manager and SRO Robert Berry is the individual likely to receive the highest dose from sources and operations authorized under R-23.

His year-to-date deep dose equivalent through the first three quarters of 1995 was " Minimal" 1995 Radiation Protection Program Resiew PageIof1I

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1995 RPP Review Review of External Dosimetry Data i

Anolicable to Licenses L00448. SNM-1518 & R-23 and Raoiatrations R00304 & R14497 1

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j- As of this date, dosimetry data are uniformly available for the first three quaners of 1995, i The TAMU dosimetry program is not subdivided by license or registration and the data presented below are not easily attributable to specific licenses or registrations. However, where such distinctions can be made, the data will be so noted.

Few individuals at TAMUS are issued dosimetry because they are "likely to exceed 10%

of the annual dose limit". Instead, the vast majority of persons in the dosimetry program are issued dosimetry because they may have need to enter a high radiation area or because they may need to repair or use a radiation producing device without interlocks in use. Review of the third quaner dosimetry repons indicated that in that quaner,243 individuals were issued external dosimetry.

I The cumulative deep dose equivalent (DDE) for the first three quarters of 1995 for all l

participants in the TAMUS dosimetry program, excluding the Nuclear Science Center, was 4,580 millirem. Extrapolated through the fourth quarter, the projected cumulative DDE for 1995 is approximately 6,100 millirem. LDE and SDE,wb were not significantly different than DDE for any individual. More than half of the cumulative total measured thus far for all of the Texas A&M University System was received by individuals in the Veterinary Radiology and Veterinary Nuclear Medicine Departments (2,430 millirem, DDE).

The highest individual deep dose equivalent was received by a veterinary radiology technician: 1,180 millirem (DDE) year-to-date through the third quaner of 1995. That individual's assigned duties were not significantly different from those of other technicians who received much lower cumulative doses. As a result, a review of her work and her technique has been initiated by the TAMU ORS. The next highest individual DDEs were received by a veterinary nuclear medicine technician (500 millirem), and another veterinary radiology technician (230 mdhrem). The highest dose equivalents measured to the lens of the eye (LDE) and to the skin of the whole body (SDE,wb) were 1,190 millirem and 1,200 millirem, respectively (year-to-date through the 3rd quaner). The highest dose equivalent to the maximum exposed extremity of  !

any individual was 7,600 millirem (year-to-date through the 3rd quarter) received by the Veterinary Nuclear Medicine Technician. Second highest was to Vetermary Radiology ,

technician: 2,340 millirem. The Veterinary Nuclear Medicine per:,onnel work with material I licensed under LOO 448. Veterinary Radiology personnel work primarily with radiation producing devices registered under R00304.

The AGN-201 reactor (License No. R-23) has not operated in 1995 (to date). Bob i Berry, Senior Reactor Operator, accumulated a DDE of" Minimal" through the 3rd quaner.

Special nuclear materials possessed by TAMU under License No. SNM-1518 are not used l in a manner which could result in any individual receiving a dose which exceeds 10% of any annual dose limit. The only large sources authorized under that license are the Plutonium-239/ Beryllium sealed neutron sources. The two largest sources are 10 curies each and are used 1995 Radiation Protection Program Resiew Page 2 ofi1 l

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for infrequent calibrations ofneutron detectors. These neutron calibrations are performed only by

.the seriior staff of the Office of Radiological Safety. The maximum year-to-date dose equivalents (through 10/31/95) received by any member of the ORS senior staff from all sources and activities (including those authorized under SNM-1518) were 10 millirem (DDE, LDE, and SDE,wb).

Dosimeters are issued to persons on board the research vessel JOIDES Resolution (Registration No. R14497) for reasom Mher than "likely to exceed 10% of the annual dose limit".

Dosuneters are issued because of the remoteness of the vessel when at sea and because engineers anal technicians on a cruise might be called upon to perform repairs and/or x-ray beam alignments.

The collective dose for this group of eleven individuals was 320 millirem year-to-date (through the 3rd quarter of1995). However, nearly all ofthat dose may be attributable to no background subtraction because of a lack of appropriate control dosimetry.

As a means of monitoring a previous decision to drastically reduce the number of l individuals issued dosimetry, the ORS continued to issue 10-15 dosimeters (whole body and '

rings) each calendar quarter to selected persons in selected laboratories. The selections were not random. Each quarter, receipt records were reviewed to determine which Permitted Users had recently received the most radioactive materials. These Users were then contacted by telephone and asked to identify one or more persons in their laboratories who should be receiving the highest doses.~ Those persons were then provided dosimeters for that calendar quarter.

Numbers ofIndividuals falling within Dose Range Dates Dose Ranae DDE LDE SDE.wb SDE.me 4th Qtr '94 Minimal 14 14 14 .9 (14 issued) < 50 mrem 0 0 0 4 50 - 150 mrem 0 0 0 1 1st Qtr '95 Minimal 13 13 13 14 (16 issued) <50 mrem 3' 3' 3' 1 l 50 - 150 mrem 0 0 0 1 2nd Qtr Minimal 17 17 17 17 (17 issued) > Minimal 0 0 0 0 3rd Qtr Minimal 11 11 10 10 (11 issued) < 50 mrem 0 0 0 1 50 - 150 mrem 0 0 1 0

• Doses from control dosimeters not subtracted.

Dose monitoring for the embryos and fetuses of thirteen Declared Pregnant Females was performed in 1995. The maximum doses measured were 20 mrem in one month and 40 mrem total (DDE, LDE, and SDE,wb). Those dosimeter readings were likely the result of background radiation since control dosimeter readings were not properly subtracted. Urine bioassays were performed to monitor for radioactive material intakes in several of the DPFs who were actively working with radioisotopes during their pregnancy. No intakes were identified.

I 1995 Radiation Protection Program Review Page 3 of1I

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1995 RPP Review Review ofInternal Dosimetry Data Apolicable to License LOO 448 More than 50 routine and post-work thyroid bioassays were performed on persons using quantities ofIodines in excess of 1 mci per caler.dar quarter. One intake was identified in 1995 which was significantly below any action level prescribed in ORS procedures. That individual was not deemed likely to exceed 10% of the annual dose limit. ,

Routine urine bioassays were not required for any personnel. Non-routine urine bionssays were performed only for some declared pregnant females and persons performing work with large quantities of tritium in unsealed form. No intakes were identified in 1995.

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1995 Radiation Protection Program Rmiew Page 4 of I1 j

1995 RPP Review License Renewal and ORS Policies and Proceres Applicable to All License and Renistrations The Procedure Manual for the Use of Radioisotopes and Radiation Producing Devices (current version dated July 1990) comprises the bulk of the TAMU Radiation Protection Plan, for all licenses and registrations. That document has been widely distributed to every Permitted User of radioisotopes or radiation producing devices under all TAMU licenses or registrations.

License LOO 448 was due to expire on September 30,1995. An application for renewal was submitted to the Texas Bureau ofRadiation Control more than 30 days in advance of the expiration date. Therefore, the BRC issued a letter to TAMU which indicated that the renewal was deemed timely and that License LOO 448 could remain active until the BRC took action on the renewal application.

A great deal of the effort was expended by the ORS Staff to revise the Procedure Manual for the Use of Radioisotopes and Radiation Producing Devices. A new policy manual was created which specifically addressed the use of radionuclides. Additional policy manuals are currently being created which will specifically address other aspects of radiation safety at TAMU, i.e., radiation producing devices and lasers.

In addition to the policy manual, two procedure manuals were created by the ORS Staff.

The first procedure manual contains procedures applicable to ORS operations. This manual is rather comprehensive and is intended to be used as a training tool and reference for ORS personnel. The second procedure manual was written for users in laboratories to use. A separate (additional) section is included to address special needs of radioactive material users who are remotely located (not in Brazos County). The user procedures will be distributed in January 1996 while the ORS procedure manual has already been implemented.

The renewal request, the Policy Manual and the Procedural Manual were reviewed and approved by the TAMU Radiological Safety Committee at a special meeting held in August, 1995. Unfortunately, the Policy Manual cannot be implemented until the BRC begins review of the TAMU license renewal request. These documents are too large to be attached to this report but are on file at the ORS for any interested party to review.

Some key changes to policy, as established in the proposed Policy Manual, are planned for implementation in 1996 regardless ofwhether BRC approval is received. These are enumerated below:

1. The ORS will initiate annual inspections ofPermitted Users on the TAMU campus which will include reviews of records, security, training, procedures, etc.  !

2. The ORS will initiate a biannual retraining requirement for all persons using radioactive materials (including Permitted Users).

3. The ORS will require users of significant activities ofI-125 to procure scintillation i detectors. i 1995 R.taation Protection Program Resiew Page 5 of11 l

1995 RPP Review Radiation Safety Training and ORS StaffImorovemen.1 Apolicable to All Licenses and Registrations Approximately 250 TAMUS faculty, staff and students received training in radiation safety I from the TAMU ORS in 1995.

In August 1995, the ORS committed to developing a method of testing the students and staffwho attend ORS training. In addition, t'ne ORS committed to providing and requiring bi-annual retraining for all individuals, including Permitted Users. These matters were discussed and approved by the Radiological Safety Committee. Although these items have not yet become requirements because the Texas BRC has not yet reviewed and approved our revised policy manual, the ORS is preparing for implementation in 1996.

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l 1995 Radiation Protection Program Reiew Page 6 of11

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1995 RPP Review Radioactive Waste Disposal i

Applicable to L00448. SNM-1518. and 42-09082-09 1

i Although the low level radioactive waste disposal facility in Barnwell, SC reopened to out-of-compact waste generators in June 1995, TAhtJ did not ship any radioactive waste for i burial / disposal in 1995. At present, the ORS is working with TAMU Purchasing Department in a effort to put in place a contract for low level radioactive waste disposal services.

The waste inventory at the close of 1995 consists of approximately 25 barrels of compacted, long-lived, solid waste, approximately 75 gallons of mixed waste, and routine inventories of bulk liquid wastes and shon-lived (<300 day half-life) solid wastes awaiting disposal via the sanitary sewer system and the landfill, respectively.

r Maximum use of BRC-approved alternate disposal methods continues at TAMUS.

Among these methods are those allowed under TRCR Pan 21.1304(a), (b), and (d) as well as TRCR Part 21.1003.

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1995 Radiation Protection Program Resiew Page 7 of1I

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1995 RPP Review

Insoections and Audits of the ORS 1

Anolicable to All Licenses and Reuistrations I l

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1 The ORS was inspected twice in 1995. Once by the Texas BRC and once by the U.S.

EPA. Neither agency has yet issued an inspection report.

Eight TAMUS remote sites were inspected by the Texas BRC in 1994. Six of the  !

inspections resulted in no violations issued. Two of the inspections resulted in a total offive i violations. Each violation has been corrected by the ORS and closed-out by the BRC. Several i more remote site inspections have been conducted which have not yet been documented by the BRC. Sites inspected were Amarillo, Bushland, Sonora, La Copita, IBT, Corpus Christi, and i PrairieView A&M. Violations identified included (1) survey instruments out of calibration, (2) j records ofleak tests not available at time ofinspection, (3) failure to demonstrate compliance with j

l dose limits to members of the public, (4) personnel training documentation not available, and (5) l l transfer records for radioactive materials which left the site not available. l l

Of the five violations, four should be taken as reminders ofdocumentation reqmrements, '

i i.e., numbers (1), (2), (4), and (5). The violation for failure to demonstrate compliance with dose l

. limits to members of the public, number (3), requires a special survey of the radioactive material l l storage areas at each remote site. The ORS must do this survey since no remote site has the i

proper equipment to do so themselves. Therefore, the ORS will attempt to visit all remote sites during the first half of 1996 which have not yet had this survey performed In 1995, the ORS conducted inspections of seven Permitted Users at the following remote sites: Weslaco, Beeville, Corpus Christi, and Galveston. The ORS should have conducted more remote site inspections in 1995 per the requirement of the Procedure Manual for the Use of Radioisotopes and Radiation Producing Devices. We will attempt to " catch-up" in the first half of 1996. Of the inspections performed, only one revealed significant problems in a Permitted User's program A second inspection was scheduled and conducted (not yet documented) to verify that the Permitted User had brought the program into compliance with state and university regulations. A third inspection will be scheduled in the early part of1996.

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1995 RPP Review Incidents Which Occurred in 1995 Anolicable to All Licenses and Registrations Three noteworthy incidents occurred in 1995, one involving suspected intentional contamination j of a laboratory and two involving loss or theft of radioactive materials. j i

The suspected intentional contamination involved laboratory benches, floor, and equipment...not )

personnel. The suspicions of the act being intentional were not proved by the TAMU Police Depanment and charges were not brought against the individual. Ifintentional, this incident may not have been preventable since the suspected individual was also the lab manager. In any case, appropriate surveys conducted by the Permitted User promptly identi6ed the problem and were instrumental in mitigating the consequences of the incident.

Regarding the two incidents which involved loss or theft of radioactive material. the first concerned a vial containing a Phosphorous-32 labeled compound which was removed from a College of Veterinary Medicine laboratory, then returned nearly empty. This incident met the requirements for reponing to the Texas Bureau ofRadiation Control and was therefore reported.

In response to this incident, the BRC issued a Severity Level II Violation. The second incident was similar but involved a lesser amount of Sulfur-35 labeled compound. This incident did not meet reporting requirements and was therefore not reported to the BRC. Instead, the incident was documented and the report maintained on file at the ORS. These incidents highlight probable shortcomings in security oflicensed sources of radiation at TAMU. As a result, three letters have been sent by the ORS, two ofwhich went to every Permitted User within TAMUS, to alert Permittees of the potential problem and request their examination of security issues in their authorized facilities. Cursory inspections have indicated that compliance is improved but is not yet adequate. The ORS has addressed the problem in the proposed (revised) Policy Manual which is awaiting review by the BRC. In addition, security will be a major inspection point in the 1996 Permitteeinspection cycle.

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1995 Radiation Protection Program Resiew Page 9 of11

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1995 RPP Review Reports from Senior Staff Attached are brief repons provided by each ORS Staff Member on ALARA-related activities performed in 1994.

End of Repon Report Submitted By: L ZFL bW Date: /2!2/ 6 Radioldgical Safety Officer j Reviewed By: # Date: /[f[f[,

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1995 Radiation Protection Program Resiew Page 10 of 11

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7 TEXAS A&M UNIVERSITY COLLEGE STATION, TEXAS 77843-3366 a  ;

ODice of . _

Radiological Safety @ Cyclotron Institute f

Telephone: (409)845-1415

Facsimile

(409)845-1899 j Internet: d-i-menchaca@tamu.edu 4

20 December 1995 d

MEMORANDUM TO: C.M. Meyer, Radiological Safety Officer j Office ofRadiological Safety l FROM: D.I. Menchaca, Sr. Health Physicist .

Office ofRadiological Safety _ l

SUBJECT:

Summary of Activities for 1995.

I Aside from the nonnal activities in support of cyclotron operation and the northeast side of campus, some other tasks that were of note are below.

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• Worked on the problem of spurious high results on the liquid scintillation counter.

The resolution to the problem appears to be a combination of software and new e microvials. The software allows for a check on the validity of the result. The new 1 i vials seem to have completed the fix.

• Performed operator U.Juing for four operators in July 1995. This is the majority of l the staffin place at the time. Expect to complete all the staff soon.

• Gave training to Chemistry class in August. This was requested training for a senior i level course. l

• Gave training to the graduate level Nuclear Engineering course.

• Gave training to Cyclotron general staffin August 1995.

• Secured keys for the bypasses in safe in office. The safe arrived in November 1995. ,

As part of the support for the cyclotron and campus we performed surveys, leak tests, calibrated instruments, and counted surveys / leak tests.

cc: File

l TEXAS A&M UNIVERSITY '

COLIICE STATION, TEXAS 77843-326t ,

Ofce of .

RaliologicalSafety  !

(409)H45-1361 (409)MS 1348-FAX January 9,1996 ,

MEMORANDUM TO: Christopher M. Meyer, Interim Director .

Office of Radiological Safety FROM: Douglas A. Johnson, Senior Health Physicis 2 4 -

Office of Radiological Safety f

SUBJECT:

1995 Radiation Protection Program Review

REFERENCE:

TRCR 21.101(c)

1. The Student Health Center has implemented changes to tmck specific causes of x-ray repeats. Repeats due to technicians increased over the year. In the last quarter two new technicians weie hired to replace two more experienced technicians. The average number of  :

repeats from all causes is 6.74%.

2. No major shipments of radioactive materials were made in 1995 but exposure rates in the waste shed have been minimized by changes in location of sources and shielding.

Radiation levels on NW fence line increased from about 8 to 12 pirm/ hour. Inside levels were about constant at 50 rem / hour

3. Effective this year student workers will have approximately monthly urine bioassays to verify that no uptakes of radioactive material are occumng from routine work practices.

General effoits in training and operations have continued successfully to reduce exposure to ALARA levels.

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File; 12/95 0RS Al. ARA Review

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