ML20148B111
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| ML20148B111 | |
| Person / Time | |
|---|---|
| Site: | University of California - Irvine |
| Issue date: | 03/03/1988 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20148B053 | List: |
| References | |
| 50-326-88-01, 50-326-88-1, NUDOCS 8803210349 | |
| Download: ML20148B111 (12) | |
See also: IR 05000326/1988001
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. U.S. NUCLEAR REGULATORY COMMISSION
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REGION V
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Report'No. 50-326/88-01
Docket No. 50-326
License No. R-116
Licensee: University of California at Irvine
Irvine,-California 92717
Facility Name: -Research Reactor-TRIGA Mark I
Inspection at: Irvine, California
Inspection Conducted: January 27-29, 1988
Inspector: '
[ M8
M. Cillis,-Senior Radiation Specialist Date Signed
Approved by: % d[[
G. P. Yuhas, Chief
A 3/5 ff
Date Signed
FacilitiesRadiologic/alProtectionSection
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Summary:
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Inspection on January 27-29, 1988 (Report No. 50-113/88-01) l
Areas Inspected: Routine, unannounced inspection by a regionally based
inspector of reactor operations program, radiation protection program,
emergency preparedness program, radioactive material shipment and receipt
program, followup items, and a tour of the facility. Inspection procedures
30703, 39745, 40745, 41745, 42745, 61745, 69745, 82745, 83743, 86740, 92701,
and 92702 were addressed.
_Re sul ts: Of the six areas inspected, two apparent violations were identified
for failure to follow Standard Operating Procedures (50P) (see paragraph 2.E)
and failure to follow and maintain the Emergency Plan (EP) (see paragraph 4).
Weaknesses within the licensee's organization (see paragraph 2.B), the reactor
operator requalification program (see paragraph 2.F), the Review and Audit
program (see' paragraph 2.G) and the surveillance program (see paragraph 2.H)
were also identified. A slight improvement was observed in the radiation
protection program (see paragraph 3).
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8803210349 890303
PDR ADOCK 05000326
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OETAILS
1. Persons Contacted
* Professor M. Caverias, Chairman, Department of Chemistry
* Professor G. Miller, Reactor Supervisor
*Ms. P. Rogers, Senior Reactor Operator
*Mr. J. Tripodes, Radiation Safety Of ficer
*Ms. K. Swift, Radiation Safety Technician
*Mr. W. Nabar, Health Physicist
Mr. W. Smirl, Environmental Health and Safety (EH&S) Officer
* Denotes those individuals attending the exit interview on January 29,
1988.
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2. Reactor Operations
l- l A. General
The inspection disclosed that reactor operations were consistent
with the information provided in the licensee's 1986 and 1987 annual
reports.
No violations or deviations were identified.
B. Organization
The organizational structure for operation and administration of the
TRIGA Reactor facility remains unchanged from that previously
reported.
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Concerns related to the lack of support provided to the Reactor
Supervisor which were previously brought to the licensee's attention
in paragraph 2(a) and 9 of Inspection Report 50-326/85-01 appear to
i have worsened. The Reactor Supervisor's busy schedule in other ,
activities prevents him from providing the attention required for
l assuring activities at the TRIGA reactor are maintained in
accordance with regulatory requirements.
The above observation was brought to the attention of the Department
of Chemistry Chairman during the inspection and at the exit
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interview.
C. Experiments
The licensee's experiment program has not changed since the previous
inspection. Experiments performed have consisted of activation
analysis in support of various research projects and classroom
laboratory work. No new experiments had been performed since the
previous inspection.
No violations or deviations were identified.
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D. Changes
Discussions with the Reactor Supervisor and a review of reactor
operating records for the period January 1986 to the present date
disclosed that no changes were made to the facility or procedures
that would require a safety evaluation' pursuant to 10 CFR Part
50.59.
No violations or deviations were identified.
E. Procedures
. Technical Specifications (TS), Section 6.3, "Operating Procedures,"
requires that written procedures shall be in effect and followed for
certain items identified in Section 6.3.
It should be noted that paragraph 2(b) of Inspection Report
50-326/85-01 identified concerns in the area of procedure
compliance. This concern was brought to the attention of the
licensee who informed the inspector that the observations would be
evaluated. The concern was categorized as NRC Open Item No.
85-01-03. The inspector examined the implementation of Standard
Operating Procedures (50P) related to reactor operations.
Particular attention was given to the weaknesses discussed in
Inspection Report 50-326/85-01. The following observations were
made with respect to the status of previous inspection findings:
(1) Health physics activities, such as obtaining liquid samples,
performing calibrations of area radiation monitors and
performing semiannual gamma and neutron surveys while the
reactor is at power had improved.
(2) Concerns related to the use of monthly, semiannual and annual
checklists for tracking the status of TS and surveillance items
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are as follows:
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Appendix B of the licensee's SOPS includes "forms" such as
startup checklist, shutdown checklist, monthly maintenance
checklist, and a semiannual maintenance summary checklist. As
previously stated, the purpose for the checklist is to provide
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an easy method for tracking the status of surveillance items
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that are required to be performed by the license conditions.
l The surveillance items are required to be performed at various
frequencies; such as, daily, weekly, monthly, seminannually,
and annually. Normally, an operator is required to record the
data in the operator log book and also denoted it on an
I appropriate checklist. The checklists are then used as a tool '
to assure subsequent surveillances are performed at the
frequencies prescribed in the TS or a licensee procedure. If a
checklist is not used, it becomes a tedious task to verify that
the required surveillances are being performed due to the
amount of data recorded in an operations log book. In essence,
failure to use the checklist enhances the possibility for
noncompliance,
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.It should be noted that Section 4.1 of the licensee's SOPS
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states, in part: "
... Routine operations must comply strictly
with these procedures" and Section 4.7.1, dated April 21, 1982,
states,'in part: "
. . . In addition, a Monthly Summary Checklist
of maintenance and test activities shall be-completed. On this
sheet shall be listed the last date of maintenance for each
' identified item. This list shall be checked and signed each
month by the Assistant Reactor Supervisor and reviewed by the
Reactor Supervisor by the seventh working day. If this review
has not'bcen completed, reactor operation may not be resumed."
The review of monthly checklists disclosed the following:
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Checklists had not been completed since October 1987.
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Eight checklists between the period of January 1986 and
September 1987 were incomplete in that all line items had
not been verified.
* Four checklists initiated or comr,leted since January 1986
had not been signed by the Assistant Reactor Supervisor.
Checklists had not been reviewed by the Reactor Supervisor
since January 1986.
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Reactor operations continued even though the checklists
were not completed and had not been signed off by the
Reactor Supervisor.
Other observations are as follows:
The last semiannual checklist completed was dated
September 18, 1986. The semiannual initiated in January
1986 was annotated in pen and ink to read "annual." The
checklist had not been completed and was unsigned. The
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September 18, 1986, semiannual checklist had not been
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reviewed by the Reactor Supervisor. ,
The above observations were brought to the licensee's attention
at the exit interview. The inspector emphasi7ed the importance
of maintaining the checklists. The inspector stated that the
checklists provido an effective method for assuring that TS
- requirements are met.
The inspector concluded by stating that failure to comply with
Section 4.7.1 of the SOPS was an apparent violation. The
l previous open item, 85-01-05, is closed and a new item number
- has been assigned for the apparent violation (88-01-01).
Additional observations are as follows:
* The licensee has not established a program for performing
a periodic review of implementing SOPS. Several >
procedures had not been reviewed since 1977.
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The licensee still uses a stop watch to measure control
rod drop times of less than 1.to 1.8 seconds,
respectively. The inspector informed the licensee that
all other research reactors in the Region V area are using
oscilloscopes and/or some other sophisticated method as a
means for improving the accuracy for measuring rod drop
times. The Reactor Supervisor said that he felt that the
stop watches were as accurate as any other method. He
added that he and the Reactor Operations Committee were
planning to look into other means for measuring the rod
drop times.
F. Reactor Operator Requalification Program
The licensee's NRC approved Reactor Operator (RO) and Senior Reactor
Operator (SRO) requalification program dated February 20, 1974, was
examined. The program is designed to meet the conditions as set
forth in 10 CFR Part 50.54(i) and 10 CFR Part 55, Appendix A.
Selected training records, R0/SRO reactor operating logs and annual
R0/SRO examinations that were administered in 1987 were reviewed.
Additionally, the concerns raised in Information Notice (IN) 87-22,
"Operator Licensing Requalification Examinations at Nonpower
Reactors," and the recent changes in 10 CFR Part 55 were discussed
with the Reactor Supervisor.
The examination disclosed that the 1987 R0/SRO written examinations
was administered before IN 87-22 was issued, and therefore, the
exams were not proctored. The Reactor Supervisor informed the
inspector that future R0/SR0 written examinations will be
administered in accordance with the recommendations of the IN.
The inspector concluded that the licensee's RO/SRO requalification
program was consistent with the regulatory requirements prescribed
in their program dated February 20, 1974.
No violations or deviations were identified.
G. Review and Audit
A review of the licensee's "review and audit" functions prescribed
in Section 6.2 of the TS was conducted. Reactor Operations
Committee (ROC) meeting minutes for the period of January 1986
through January 1988 were reviewed.
The review disclosed that an ROC meeting was not conducted during
the period of April 23, 1986, through October 13, 1986. TS requires
that quarterly ROC meetings be conducted. A licensee letter
submitted to Region V on November 4, 1986, reported that the ROC had
failed to meet during the third quarter of 1986. The inspector
verified that quarterly meetings were conducted since the licensee
identified violation of November 4, 1986, was submitted to the NRC.
The inspector noted that a full three year schedule has been
submitted to all ROC members as a reminder of ROC meeting dates.
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The review of ROC meeting minutes disclosed that audits of reactor
operations have decreased since the previous inspection. The ROC
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minutes did not include any licensee documented audit reports. The
ROC review functions appear to consist of a paper work review rather
than a physical review of reactor operations.
The above observation was-discussed with the Reactor Supervisor and
at the exit interview. The Reactor Supervisor informed the
inspector that he has also noted that the ROC's review and audit
functions have fallen off during the past two' years. He added that
the TS only requires the ROC to act as a review group rather than a
review and audit group.
- The inspector informed the licensee that TS, Section 6.2, requires
that there shall be an ROC which shall review reactor operations to
ensure that the facility is operated in a safe manner consistent
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with public health and safety and within the terms of the facility
- license.
The inspector added that the violations and other findings
identified in this report could have been eliminated if the ROC had
implemented an effective review and audit program.
The above observations were brought to the licensee's-attention at
the exit interview. The inspector emphasized the importance for the
ROC to implement an effective review and audit program.
The inspector was informed that the above observations and the
findings of this inspection would be brought to the attention of the
ROC Chairman.
l H. Surveillance Program
Selected records associated with the performance of surveillance
i activities that are prescribed in TS, Section 4.0, were reviwed.
Weaknesses within the licensee's surveillance program were '
identified during the previous inspection (see paragraph 2(c) of
Inspection Report 50-326/85-01) at which time the licensee informed
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. the inspector that methods for improving the program would be
evaluated. The previous inspection finding in this area was
identified as followup item No. 85-01-05. These weaknesses are
j directly related to the problem associated with the use of i checklists that is discussed in paragraph 2.E of this report.
The inspection disclosed that no effort was taken to improve the
i program. The conditions identified during the previous inspection , l had deteriorated.
The 'r.spector was unable to verify that all of the required
surveillances specified in the TS were performed since the previous
inspection because of the tedious task of sorting out the data
1 documented in several operations log books. The review process was
- extremely slow and was subject to error. The inspector verified
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that the most recent surveillances that were due the previous month, ;
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six-nonth period, and twelve-month period had been accomplished. No
abnormal conditions were identified from the cursory review.
The inspector brought the above observation to the attention of the
licensee at the exit interview. The inspector encouraged the
licensee to utilize the checklists as an assurance that license
conditions have been accomplished. The inspector added that
followup item 85-01-05 was closed due to the apparent violation
discussed in paragraph 2.E which essentially points out the same
problem.
3. Radiation Protection Program
A. Liquid and Solid Waste
Liquid and solid wastes generated from the production of by product
materials at the reactor facility are disposed of through the
licensee's State of California license.
No liquid wastes were disposed of since the previous inspection.
Solid wastes, consisting of nine cubic feet, was disposed in the
last year. The nine cubic feet of material contained approximately
245 microcuries of mixed fission products.
No violations or deviations were identified.
B. Posting
The inspector verified that the licensee's posting practices were in
compliance with 10 CFR Part 19.11, "Posting of Notices to Workers."
No violations or deviations were identified.
C. Personnel Monitoring
The licensee's program for assuring compliance with 10 CFR Part
20.202 was examined and found to be consistent with the regulatory
requirements prescribed in 10 CFR Part 20.101 and 10 CFR Part
20.104. Personnel monitoring exposure records for the period of
January 1986 through November 1987 were reviewed.
l No violations or deviations were identified. I
D. General Employee Training (GET)
The licensee's GET program for assuring compliance with 10 CFR Part
19.12, "Instructions to Workers," was examined.
Training attendance records, written examinations, and the lesson
plan used in administering the training were reviewed.
The inspector concluded that the licensee's GET program was
consistent with 10 CFR Part 19.12.
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No violations or deviations were identified.
E. Surveys
The inspector verified that direct radiation surveys, contamination
surveys, and special surveys are performed on a routine schedule.
Survey records for the period of January 1986 through December 1987
were reviewed.. The results were consistent with the levels reported
in the licensee's annual reports. Survey data was well documented.
The licensee's monitoring program had showed a significant
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improvement over what was identified during the previous inspection.
No abnormal results were noted.
No violations or deviations were identified.
F. Particulate and Gaseous Effluent Releases
Annual Argon-41 releases are determined by calculations which is
based on the production of Argon-41 during reactor operations. The
basis and calculational method are discussed in Section 8.4 of the
Safety Evaluation Report of 1968. The calculations are considered
to provide conservative values.
The licensee's annual report for the period of July 1,1986, through
June 30, 1987, disclosed that the amount of Argon-41 was 1.8E4
microcuries. This represents a concentration of less than or equal
to 3E-10 microcuries per milliliters (pCi/ml) when averaged over a
12-month period. This value is considerably less than the Maximum
Permissible Concentration of 4E-8 pCi/ml allowed by 10 CFR Part 20,
Appendix 8.
A continuous air monitor (CAM) is located alongside the reactor
pool. The CAM is operated continuously during reactor operations
pursuant to TS, Section 3.3. The CAM draws a continuous sample from
a location over the reactor pool. An audio-visual alarm is provided
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at the unit and at the reactor console.
A review of the CAM's operating records revealed that particulate
airborne concentrations were essentially non-detectable.
No violations or deviations were identified.
G. Environmental Monitoring Program
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An array of thermoluminescent dosimeters (TLDs) supplied and
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processed by a certified vendor are placed at various locations
l within and adjacent to the reactor facility.
The results of environmental monitoring data collected over the past
two years were reviewed. The data gave no indication of changes in
the environs due to oporation of the licensee's TRIGA reactor
facility.
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No violations or deviations were identified.
4. Emergency Plan Implementation
10 CFR Part'50.54(q) states, in part: " A licensee authorized to . . .
possess-and/or operate a research reactor or fuel facility shall follow
and maintain in effect emergency plans which meet the requirements in
Appendix E of this part."
Paragraph IV.G of Appendix E to 10 CFR Part 50 requires the program to
describe the provisions to be employed to ensure the emergency plan,
emergency equipment and the emergency plan implementing procedures are
maintained up-to-date.
The capabilities for responding to emergencies as specified in the
licensee's NRC approved Emergency Plan (EP) of January 1985, and for
demonstrating compliance with 10 CFR 50.54(q) and 10 CFR Part 50,
Appendix E, were examined. The examination included a review of the EP
implementing procedures, inspection.of emergency response equipment,
inspection of the campus medical facility, a review of drill / exercise
scenario and drill critiques, and discussions with the licensee's staff.
Inspector's concerns related to this subject area were identified during
the previous inspection (see paragraph 3 of Inspection Report
50-326/85-01).
The following observations were identified:
- A. Several of the findings identified in the previous inspection still
existed; for instance,
(1) Records of training are not being maintained.
(2) The campus police department did not have a copy of the latest
emergency call out list.
(3) Although a memorandum of understanding (HOU) with Western
Medical Center had been established on October 21, 1986, it had
not been renewed since it was established on October 21, 1986.
Section 10.3 of the EP requires an annual renewal of all
agreements with off campus agencies.
B. Section 8.3.2 of the EP states, in part: "Several staff members are
qualified in first aid." The Radiation Safety Officer informed the
inspector that all of the staff members had allowed their first-aid
qualifications to lapse.
! C. Two emergency call out lists posted on the outside walls of the '
reactor facility were not in agreement with each other. The Reactor
- Supervisor removed the outdated call out list when it was brought to
, his attention by the inspector.
D. Section 8.2 of the EP identifies that a high volume air sampler is
maintained in the emergency supply closet. Discussions with the
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reactor assigned health physics technician revealed that the
individual had never used such a sampler and was not knowledgeable
on how to use it under normal or emergency conditions.
E. Section 10.1 of the EP states, in part: "Procedures shall be
established to ensure that annual review of the plan by all
personnel is accomplished and that new personnel are familiarized
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within 30 days of commencing their duties which would involve them
in emergency operations."
The examination disclosed procedures were not established to ensure
personnel other than reactor operators would review the plan;
therefore, annual reviews of the plan by personnel from the
Environmental Health and Safety (EH&S) and Security groups were not ;
performed since the plan was issued.
F. Section 10.2 of the EP states, in parti "An annual, on-site
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emergency exercise shall be conducted in which an event at the
reactor facility is simulated to test the preparedness of the staff
and the response of on campus assistance..."
The examination disclosed that an annual exercise had not been
conducted since December 19, 1986.
J G. Section 10.3 of the EP states, in part: "Emergency Call Lists and
Equipment Inventory Lists shall be updated as needed, but verified
at least at intervals not to exceed 3 months."
The examination disclosed that call lists are verified every 6
months and that equipment inventory lists are not used to verify the
contents of emergency supplies.
H. Section 8.6 of the EP requires that all instruments included in the
Emergency store room inventory shall be included in the regular
testing and calibration program of the facility and campus
radiological safety instruments.
The examination disclosed that the high volume air sampler
identified in subparagraph (C) above had not been included in the
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licensee's regular testing and calibration program for greater than
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two years.
The above observations were discussed with the licensee's staff and at
the exit interview. The inspector stated that failure to follow and
maintain in effect the Emergency Plan was an apparent violation
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(88-01-02). The inspector added that the previous followup item number
85-01-06 was closed.
! The inspector stated that the findings indicate there is a need for
immediate management attention and support to resolve the findings.
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5. Radioactive Material Shipment and Receipt
An examination of the licensee's radioactive material transfer and
shipping program was conducted.
A review of radioactive material shipping and receipt records disclosed
that transfers and/or shipments of radioactive materials were made
through the licensee's State of California license. Transportation
activities appeared to be consistent with the licensee's SOP, Section 5.0
and the appropriate' regulatory requirements prescribed in Department of
Transportation regulations, 49 CFR Parts 172-178.
No violations or deviations were identified.
6. Facility Tour
A tour of the licensee's facility was conducted during the inspection.
Independent measurements were performed with an Eberline Corporation
Model E-520 radiation measurement instrument, Serial Number 1586, that
was due for calibration on February 11, 1988.
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The independent measurements confirmed that the licensee's posting and
labeling practices were consistent with 10 CFR Part 20.203.
All fixed and portable radiation monitoring instruments were in current
calibration.
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The reactor office, control room, and reactor room were cluttered with
what appeared to be unnecessary extraneous material. This observation
was brought to the Reactor Supervisor's attention. The Reactor
Supervisor stated that he had come to the same conclusion; however, he
did not have the time and necessary resources to clean the facility.
No violations or deviations were identified.
7. Followup Items
A. Enforcement Items and Open Items
Corrective actions taken by the licensee to resolve enforcement
items, open items, and licensee identified items (85-01-01,
85-01-02, 85-01-04, 85-01-05, 85-01-06, 06-16-83, and 86-11-41) were
examined. Licensee's actions were satisfactory except for open
items 85-01-05 and 85-01-06. These items have been replaced with
enforcement items 88-01-01 (see paragraph 2.E) and 88-01-02 (see
paragraph 4). Items 85-01-01, 85-01-02, 85-01-04, and 06-16-83 are
closed.
B. Information Notices (ins)
The inspector verified that ins pertinent to research reactors are
routinely evaluated for applicability at the TRIGA reactor facility
after they are received.
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No violations or deviations were identified.
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8. Generic Letters (GL)
Discussions with the Reactor Supervisor ano Department of Chemistry
Chairman revealed that an evaluation of GL 85-11, "Distribution of -
Products Irradiated in Research Reactors," was reviewed. The inspector
was informed that the licensee does not have any current plans to
irradiate any gem stones for commercial use. The Reactor Supervisor
stated that the NRC would be informed of any future decisions to
irradiate gem stones for commercial or private use.
No violations or deviations were identified.
9. Exit Interview
The inspector met with the individuals (denoted in paragraph 1) at the
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conclusion of the inspection on January 29, 1988. The scope and findings
of the inspection were summarized. The inspector informed the licensee
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of the two apparent violations discussed in paragraphs 2.E and 4.
The inspector added that it appears that the weaknesses discussed during
the exit interview of the previous inspection held on September 6,1985
(see paragraph 9 of Inspection Report 50-326/85-01) had not been
corrected as was committed to by the licensee's staff attending the exit
interview. The inspector added that the two apparent violations might
have been avoided had management's attention and support been provided.
The Department of Chemistry Chairman informed the inspector that the
j inspector's observations would be carefully evaluated. l l l I , I l
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