ML20148B877
| ML20148B877 | |
| Person / Time | |
|---|---|
| Site: | 05000113 |
| Issue date: | 03/03/1988 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20148B863 | List: |
| References | |
| 50-113-88-01, 50-113-88-1, GL-86-11, IEIN-87-022, IEIN-87-22, NUDOCS 8803220177 | |
| Download: ML20148B877 (10) | |
See also: IR 05000113/1988001
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U.S. NUCLEAR. REGULATORY COMMISSION
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REGION V-
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Report'No.
50-113/88-01
-Docket No.
50-113
' License No.
R-52
Licensee:
University of Arizona
LCollege of Engineering
Tucson, Arizona 85721
Facility Name: University of Arizona Research Reactor, TRIGA Hark I
Inspection at: Tucson, Arizona
Inspection Conducted: January 25-26, 1988
Inspector:
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M. Cillis, Senior Radiation Specialist
Date Signed
Approved by:
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G. P. Yuhas Chief
Date Signed
Facilities'Radiolo cal Protection Section
Summary:
Inspection on January 25-26, 1988 (Report No. 50-113/88-01)
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.
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Results:
Of the six areas inspected, two violations were identified.
Failure
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to include all required topic areas in the reactor operator / senior reactor
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operator annual written examination (see paragraph 2.F) and failure to follow
and maintain the Emergency Plan in effect (see paragraph 4).
The licensee's
performance in remaining areas that were examined appeared to be consistent
with the regulatory requirements.
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8803220177 880303
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ADOCK 05000113
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DETAILS
1.
Fersons Contacted
- E. T. Smerdon, Dean, College of Engineering and Mines
- T. Triffet, Associate Dean of Engineering and Research
- G. W. Nelson, Director, Nuclear Reactor
R. L. Seale, Head, Department of Nuclear and Energy Engineering
- B. Westerman, Director, Radiation Control Office
- B. O. Ganapol, Reactor Committee Chairman
- H. J. Duane, Reactor Supervisor
- C. Irwin, Radiation Safety Officer
M. C. Young, Assistant Director, Radiation Control Office
B. B. Piner, Chief, Radiation Control Officer
- Denotes those individuals attending the exit interview on January 29,
1988.
2.
Reactor Operations
A.
General
The inspection disclosed that reactor operations were consistent
with the information provided in the licensee's 1986 and 1987 annual
reports.
The inspection disclosed that the facility continues to provide
support for irradiations and teaching programs.
The inspector witnessed reactor operations that were performed
during the inspection.
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.
The organization was found to be consistent with Section
6.1 of the Technical Specifications (TSs).
No violations or deviations were identified.
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.
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No violations or deviations were identified.
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
,
The inspection disclosed that the licensee maintains in effect
reactor operating procedures es prescribed in TSs, Section 6.3.
The inspector reviewed the licensee's standard operating procedures.
The procedures appeared to provide thorough instructions.
The
inspector noted that the procedures are reviewed on a routine
schedule and whenever changes occur that may require revisions.
No violations or deviations were identified.
F.
Reactor Operator Requalification Program
The implementation of the licensee's approved Reactor Operator (RO)
and Senior Reactor Operator (SRO) requalification program, dated
August 29, 1974, was examined.
Applicable training lesson plans,
quizzes, and annual examinations administered in 1986 and 1987 were
reviewed.
Additionally, discussions related to Information Notice (IN) 87-22, "Operator Licensing Requalification Examination at
Nonpower Reactors," and the recent changes made to 10 CFR Part 55
were held with the licensee's staff.
The inspector also verified
through the review of applicable logs and records that the R0/SRO
requalification program was in compliance with Section 3 of the
approved requalification program.
Section 3 requires each operator
to perform at least ten reactivity control manipulations over the
two year term of his license, at least one reactor checkout, and one
startup per quarter.
The examination disclosed that the licensee had received a copy of
the recent changes made to 10 CFR Part 55 and IN 87-22.
The
Director of the Nuclear Reactor informed the inspector that an
evaluation of the IN had been completed.
He added that actions
have been taken to ensure that the problems identified in the IN is
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considered during the administration of future R0/SRO annual
examinations.
The licensee was still in the process of evaluating
the recent changes to 10 CFR Part 55 for applicable to activities
performed at the NRL.
The examination disclosed that the 1967 annual examination did not
include an examination in the topic area of "Normal, Abnormal, and
Emergency Operating Procedures" as required by Section 2 of the
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approved R0/SRO approved requalification program.
The reactor
supervisor was'not-aware that the topic area had not been included
in the examination.
He said it was probably due to an oversight on
his part.
The above observations were brought to the licensee's attention
during the exit interview.
The inspector informed the licensee that
failure to include the topic area of. Normal, Abnormal, and Emergency
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Operating Procedures in the 1987 annual R0/SR0 annual examination
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was an apparent violation (88-01-01).
The licensee. acknowledged the inspector's observation.
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G.
Review and Audit
The inspector verified that the licensee's review and audit program
was consistent with Section 6.2 of the TS.
Reactor Operations
Committee (ROC) meeting minutes for the period of January 1986
through January 1988 were reviewed.
The chairman of the ROC met
with the inspector to discuss methods for improving the
effectiveness of ROC review and audit functions.
The inspection
findings were brought to the attention of the ROC chairman.
No violations or deviations were identified.
H.
Surveillance Program
The inspector verified through the review of 1986 and 1987 reactor
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operating records, checklists, and logs that the licensee's
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surveillance program had been in compliance with Sections, 2, 3, and
4 of the TS.
The review dis osed that the surveillances were
performed in accordance wi^h the licensee's Standard Operating
Procedures (SOP) at a frequency that met or exceeded TS
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requirements,
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No violations or deviations were identified.
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3.
Radiation Protection Program
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A.
Liquid and Solid Waste
A review of records maintained by the licensee's radiation control
office and at the reactor facility disclosed that no liquid or solid
radioactive waste had been generated since the previous inspection.
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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,.
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No violations or deviations were identified.
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C.
Personnel Monitoring
The licensee's program for assuring compliance with 10 CFR Part 20.202,-"Personnel Monitoring," was examined and was found to be
acceptable.
Personnel monitoring records for the period of December
1985 through November 1987 were reviewed.
No abnormal exposures
were identified.
No violations or deviations were identified.
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 lesson
plans, examinations, and attendance records were reviewed.
The
inspector concluded that the GET program was consistent with 10 CFR Part 19.12.
No violations or deviations were identified.
E.
Surveys
The licensee's program for assuring compliance with 10 CFR Part 20.201, "Surveys," and 10 CFR Part 20.401, "Records of Surveys," wcs
examined.
Survey records for the period of January 1986 through January 1988
were reviewed.
The following observations were made:
(1) Monthly radiation and wipe measurements (surveys) are conducted
at the reactor facility by the campus radiation control office
staff.
Radiation measurements are normally obtained when the
reactor is shut down.
A radiation measurement had not been
performed while the reactor was at full power since the summer
of 1984.
This observation was brought to the licensee's
attention during the inspection and at the exit interview.
The
licensee informed the inspector that provisions will be
established to perform radiation measurements while the reactor
is at power on a quarterly basis.
The inspector noted that the results of survey data reviewed
were consistent with the levels reported in the licensee's
annual reports.
No abnormal results were identified.
(2) A review of reactor operating records disclosed that irradiated
samples transferred to other campus facilities are not normally
checked for contamination.
This obsurvation was brought to the
attention of the licensee's staff during the inspection.
The
inspector was informed, that future samples will be checked for
contamination prior to transfer from the reactor facility.
(3) A review of radiation measurements made on contact with the
reactors water purification system disclosed that surveys of
the unit, which is located immediately outside the reactor's
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north wall, are only performed once each month.
The system is
housed in a locked wire-mesh cage which measures approximately
3' square by 5' high.
The-system had never been posted or
controlled as a radiation area during the history of. reactor
operations at the"licensee's facility.
It was noted that the monthly survey did not necessarily
reflect the worst case condition; for example:
a.
Performing measurements immediately after reactor
shutdown, and-
b.
Performing measurements after operating the reactor at
full . power for one day or longer.
The inspector noted that on one occasion, (1984) radiation
levels of 20 mrem /hr were measured on contact with the
demineralizer housing and 4 mrem /hr at one foot from the unit.
The review further indicated that the reactor was seldom
operated at maximum power or for more than three hours per day
and, as a result, radiation measurements on contact with the
water purification system for the past two years had not
exceeded 2 mrem /hr.
However, it should be noted that the
surveys were performed anywhere from several days and/or longer
periods after the reactor had been shut down.
Therefore, any
short-lived radioactivity would have decayed before the
measurement was taken.
The inspector made a measurement of the system within 10
minutes of reactor operation at 1 Kw on January 26, 1988.
Radiation measurements on the outer surface of the wire mesh
cage were less than 0.2 mrem /hr.
The inspector brought the above observations to the licensee's
attention during the inspection and at the exit interview.
The
licensee's staff concluded that no violations of the regulatory
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requirements had occurred based on the facilities power history
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over the past several years.
The inspector concurred with the
licensee's conclusions.
This item will be examined during a
subsequent inspection (88-01-03).
The licensee informed the
inspector that an evaluation of the above observations would be
performed to verify compliance with 10 CFR Part 20
requirements.
F.
Particulate and Gaseous Effluent Releases
Annual releases of Argon-41 are determined by calculation.
The
calculations consider the production of Argon-41 during reactor
operations.
A constant air monitor (CAM) is used to measure
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concentrations of particulate radioactivity pursuant to Section 4.3
of the TS,
/ rgon-41 releases for the period of July 1986 through June 1987 were
determined to be 3.67 millicuries.
This value is less than 0.6% of
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the allowable Argon-41 releases per 10 CFR Part 20, Appendix B.
Particulate airborne concentration levels for this same-period were
essentially non-detectable.
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The inspector also verified that the CAM alarm setpoint-and
calibration were accomplished in accordance with TS Section 4.4.
No violations or deviations were identified.
G.
Environmental Monitoring Program
The licensee has established an environmental monitoring program
which includes the analysis of water and soil samples that are
obtained at various locations on the University of Arizona campus.
Dose measurements are also performed using an array of CaSO : Dy
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Thermoluminescent Dosimeters (TL0s).
Records of water, soil, and TLD measurements were reviewed and were
found to support the licensee's conclusion that there has been no
detectable or abnormal increases of radioactivity in the environment
as a result of reactor operations.
No violations or deviations were identified.
4.
Emergency Plan Implementation
The licensee's capability for responding to emergencies as specified in
their NRC approved Emergency Plan of December 12, 1983, and for
, demonstrating compliance with 10 CFR Part 50.54(q) and 10 CFR Part 50,
Appendix E, were examined.
The examination included a review of licensee's records, emergency plan
implementing procedures (EPIP), emergency response equipment, drill
scenarios and critiques, and discussions with the licensee's staff.
10 CFR Part 50.54(q) requires each licensee who is authorized to possess
and/or operate a research reactor to follow and to maintain in effect
emergency plans (EP) which meet the requirements of Appendix E to 10 CFR Part 50.
Paragraph IV.F of Appendix E requires that emergency plans
include provisions for training of personnel and exercising by periodic
drills to ensure personnel are familiar with their duties. Appendix E
further states that the program should identify specialized initial
training and periodic retraining programs.
Paragraph IV.G of Appendix E
also requires that the program describe the provisions to be employed to
ensure the EP, emergency equipment, and the EPIPs are maintained
up-to-date.
Paragraph 10.4 of the licensee's approved EP states, in part:
"Applicable portions of the plan, agreements, and implementing procedures
shall be distributed to the University Police, Radiation Control Office
and the Arizona Radiation Regulatory Agency.. . . ."
Discussions with the licensee's staff disclosed that the Radiation
Control Office did not have a copy of the EP or the EP implementing
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procedures.
A copy of the reactor's EP was made from the inspector's
copy of the licensee's EP by the Radiation Control Office staff during
the inspection.
Only one of six members from the Radiation Control
Office was generally aware of the instructions provided in the reactor's
Several members of the Radiation Control Office had not
read the plan since 1985.
The Radiation Control Office staff were not
aware of requirements prescribed in paragraph 10.5.2 of the EP which
states, in part:
"Pnrtable health physics instruments used in the NRL
and those in the emer gency kit are checked for operability quarterly and
calibrated by the staff of the Radiation Control Office semiannually."
Procedures from the Radiation Control Office require portable instruments
be calibrated annually and require that channel checks be performed
semiannually.
Section 3.1.2 of the EP states that the reactor supervisor is responsible
for training and conducting emergency tests and drills for the operating
staff of the NRL in conjunction with the Radiation Control Office.
Section 10.1 of the EP states, in part:
"NRL operators and staff, and
members of the Radiation Control Office with emergency response
responsibilities will complete an initial training program and an annual
review program... Specific training in protective action decisionmaking
will be included in the initial and periodic training for those
individuals who may serve as Emergency Director during an emergency.
Support groups will receive training commensurate with their degree of
pctential involvement."
No records of any training were maintained except for training provided
to operators; however, the training records for operators did not include
any specific instructions related to protective action decisionmaking
responsibilities for the Emergency Director or his alternates.
Discussions with the Reactor Supervisor and Radiation Control Office
staff revealed that the initial training had not been provided and an
annual review program had not been established and maintained.
Several
members from the Radiation Control Office informed the inspector that
they had not read the EP, had not received any specific training related
to the NRL approved EP plan and had not participated in exercises or
drills associated with a simulated NRL e:nergency.
The staff stated that
they had not been directed to review the plan.
The Director of the
Radiation Control Office stated that his staff had been trained to
respond to the University of Arizona campus EP.
The inspector noted that
the site-wide plan was quite different from the NRL approved EP.
The
reactor supervisor stated that he had not developed any specialized
training program for the Radiation Control Office staff.
Discussions witi, the NRL staff disclosed that a video tape had been
prepared so that the campus security group could train their staff.
The
examination disclosed the NRL staff had not verified whether the campus
security department was utilizing the video tape recording to train their
staff.
The examination disclosed that the annual exercises prescribed in EP
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Section 10.2 were conducted in 1986 and 1987.
The reactor supervisor
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stated that involved personnel were provided with some training in
preparation for conducting the drills.
Section 10.4 of the EP requires that the EP be reviewed annually by the
Reactor Committee (RC) to ensure that the plan is adequate and
up-to-date.
Section 3.1.2 also assigns the reactor supervisor the
responsibility for reviewing and updating the EP and procedures.
The inspector noted that the only review of the EP is performed by the
reactor supervisor.
The results of the reactor supervisor's review are
then presented to the Reactor Operations Committee for approval.
An
independent review of the EP is not performed by the RC.
The inspector summarized the above findings with the licensee's staff
attending the exit interview.
The inspector informed the licensee that
failure to distribute the EP to the Radiation Control Office, failure to
complete the initial training and annual review program, and failure to
perform quarterly calibrations of the inst ruments semiannually was an
apparent violation (88-01-02).
The licensee staff attending the exit interview acknowledged the
inspector's observations.
The inspector was informed that appropriate
actions would be established and implemented to resolve the observations.
5.
Radioactive Material Shipment and Receipt
A review of radioactive material shipping and receiving records revealed
that activities associated with the transportation and receipt of
radioactive material were consistent with 10 CFR Part 20, 10 CFR Part 61,
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10 CFR Part 71, and Department of Transportation (00T) 49 CFR Parts
173-178.
Shipments of radioactive material are made through the licensee's State
of Arizona radioactive material license.
No violatiens or deviations were ideatified.
6.
Facility Tour
The inspector toured the licensee's facility to check the general state
of housekeeping and to verify that posting and labeling were in
compliance with 10 CFR Part 20.203 and that radiation monitoring
instrumentation was in current calibration and was operating properly.
Independent radiation measurements were parformed using an NRC Eberline
Model E-520 Geiger Counter, Ser ial Number 1086, that was due for
calibration on February 11, 1988.
All fixed and portable radiation monitoring instruments were in current
calibration and the facility cleanliness was excellent.
No violations or deviations were identified.
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7.
Followup Items
Information Notices (ins) and Generic Letters (GLs)
The inspector verified'that the licensee's staff were receiving and
evaluating ins and GLs for. applicability to activities performed at the
research reactor.
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A licensee evaluation of GL 86-11, "Distribution of Products Irradiated
in Research Reactors," revealed that the licensee does not plan to
irradiate any gemstones for commercial use.
Reactor Director stated that
the NRC would be informed of any future decisions to irradiate gemstones
for commercial and/or private use.
No violations or deviations were identified.
8.
Exit Interview
The inspector met with the_ individuals (denoted in paragraph 1) at the
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conclusion of the inspection on January 26, 1988.
The scope and findings
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of the inspection were summarized.
The licensee was informed of the
apparent violations identified in paragraphs 2.(f) and 4.
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The violations and other observations discussed in the inspection report
were acknowledged by the licensee at the exit interview.
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