ML20151E691

Insp Rept 50-083/88-01 on 880314-17.Violations Noted.Major Areas Inspected:Onsite Review of Radiation Protection, Environ Surveillance & Monitoring,Transportation Activities, Enforcement Issues & NRC Info Notices

ML20151E691
Person / Time
Site:	05000083
Issue date:	04/04/1988
From:	Hosey C, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151E647	List: ML20151E645 ML20151E674 ML20151E691
References
50-083-88-01, IEIN-87-003, IEIN-87-031, NUDOCS 8804150349
Download: ML20151E691 (10)

See also: IR 05000083/1988001

Text

{{#Wiki_filter:- 'g m%g , s - y" UNITED STATES g ,j NUCLEAR REGULATORY COMMISSION '* REGION 11 o, [ 101 MARIETTA ST., N.W. g 4,,,, ATLANTA, GEORGIA 30323 APR 0 71988 Report No.: 50-83/88-01 Licensee: University of Florida 202 Nuclear Sciences Center Gainesville, FL 32601 Docket No.: 50-83 License No.: R-56 facility Name: University of Florida Training Reactor Inspection Conducted: March 14-17, 1988 Inspector: le L b b c 31 F1.,1 If 33 l 1 G. B. Kuz Date Signed ' Approved by: /1% '7-/ D C. M. Hosey, Section Chief Date Signed ~ Division of Radiatic'n Safety and Safeguards SUMMArsy Scope: This- routine, unannounced inspection involved onsite review of radiation protection program areas including radiation control activities, environmental survoillance and monitoring, transportation activities, and review of licensee actions concerning previously identified followup items, enforcement issues, and NRC Information Notices. Results: Two violations were identified - failure to have approved procedures for environmental surveillances and effluent monitoring required by Technical Specifications and failure to conduct adequate surveys for liquid and gaseous effluents. - 8804150349 880407 PDR ADOCK 05000083 o DCD

,' ., s REPORT DETAILS 1. Licensee Employees Contacted

• D. Munroe, Radiation Control Officer, Environmental Health and Safety

Office

• M. Ohanian, Chairman, Reactor Safety Review Subcommittee

J. Tulenko, Director of Nuclear Facilities

• W. Vernetson, Director, University of Florida Training Reactor
• P. Whaleys, Acting Reactor Manager

Other licensee employees contacted included operators, and office personnel.

• Attended exit interview

2. Exit Interview (30703) The inspection scope and findings were summarized on March 17, 1988, with those persons indicated in Paragraph 1 above. Two apparent violations concerning failure to have approved procedures for environmental surveillance and monitoring rea,uirements (Paregraph 5.a) and inadequate liquid and gaseous effluent measurements (Paragraph 5.b) were discussed. Licensee representatives acknowledged the inspector's comments. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection. 3. Licensee Actirn on Previous Enforcement Matters a. (Closed) Violation (50-83/07-O'v'J1) Failure to follow RWP procedure. . The inspector reviewed and verified implementation of corrective actions stated in the University of Florida's (UF) response dated March 19, 1987. b. (Closed) Violation (50-83/87-01-02) Failure to post 10 CFR 19.11 documents. The inspector revieved and verified implementation of corrective actions in the University of Florida's response dated March 19, 1987. c. (Closed) Violation (50-83/87-01-03) Failure to meet D0T requirements for shipping papers, placarding, and dose rates on external surface of package. The inspector reviewed and verified implementation of corrective actions stated in the University of Florida's response dated April 23, 1987. __-

. . .- . - _. - - C .. , . ' 2 . 4. Radiation Control (83743) 4 a. Organization and Staffing , Technical Specification (TS) Sections 6.2.1 and 6.2.2 detail organizational structure and management responsibility for safe operation of the University of Florida Training Reactor (UFTR) facility. The independence of the campus Radiation Control Officer to oversee facility activities was discussed. The campus Radiation Control Officer does not report directly to UFTR management but does provide assistance with environmental monitoring and surveillance activities, and selectively reviews radiation protection issues at the facility. Furthermore, the University of Florida's Radiation Control Guide authorizes the Radiation Control Officer to suspend any UFTR operations as rapidly and safely as possible, if warranted. From discussions with, and observations of personnel conducting ' routine duties at the UFTR, the inspector verified that the facility

management responsibilities and organizational structure met TS

requirements. Review of activities at the facility indicated that management and staff rsrSonnel from both the UFTR facility and the Radiation Control Office appeared to interact and operate efficiently and comperstly for rot. tine and non-routine issues which were i 2 cbserved during the inspection. I , UFTR and Radiation Control Office (RCO) personnel supporting radiation protect lcn activities for the reactor facility were reviewed. The current UFTR staff includes one Class B and threc ' Class A operators. In addition, three persons, two of which were , i undergoing training at the time of the inspcction, were scheduled to be licensed by May 30, 1988. The majority of required radiation

protection surveillances and general health physics monitoring activities within the UFTR facility are performed by the UFTR ! operations staff. In addition, the RC0 has approximately six radiation control technicians available to conduct environmental radiation surveillances and/or assist with reactor health physics monitoring when requested. Of the six radiation control technicians, I two individuals have been involved in the majority of UFTR routine ' surveillances and special health physics coverage activities. l No violations or deviations were identified, b. Audits and Review ! l TS 6.2.5 requires an independent review and audit of safety aspects of reactor facility operations to advise management. The review and audit functions are to be conducted by the Reactor Safety Review Subcommittee (RSRS). TS 6.2.5(1) and 6.2.5(2) detail RSRS committee ! l I

. . s 3 member composition and qualifications, and also meeting and audit frequency. The inspector reviewed and discussed with cognizant licensee representatives, the RSRS meeting minutes and audits conducted from January 1987 through February 1988. During the period reviewed the RSRS met approximately on a monthly basis. The Committee reviewed current status of the facility, procedural changes, experiments submittea .or approval, and regulatory issues. Issues discussed during the RSRS meetings and requiring subsequent review were tracked by the licensee. All licensee actions regarding identified issues appeared to be completed in a timely manner as indicated by the tracking record. In addition, the inspector noted that an Executive RSRS as detailed in TS 6.2.5(2)(b) selectively met during the period to evaluate operating abnormalities in a timely manner. During the inspection, the executive comittee met to review and evaluate the safety significance, corrective actions and reporting requirements concerning failure of a Safety Channel No.1 circuit for the UFTR (Letters from W. G. Vernetson, Director Nuclear Facilities, UFTR, to J. N. Grace, Regional Administrator, NRC Region II, dated Mcrch 15, and 16, 1988). Licensee actions regarding this issue appeared to be thorough and were conducted in a titraly manner. The inspector reviewed and discussed with cognizant licensee representatives, results cnd licensee actions for audits conducted from January 1936 to February 1987. The audits focused on the performance of routine surveillance activities. The inspector questioned whether technical issues regarding surveillance and effluent measurement systems had been audited. Licensee representatives indicated that such review had not been conducted recently, but that the professional expertise to conduct such a review was available within the UF staff. The licensee noted that in light of the concerns regarding measurement of radioactive effluents identified during the current inspection (Paragraph 5.b) the need for a thorough review of all surveillance and effluent analytical measurements would be evaluated. No violations or deviations were identified. c. Facility Tours During tours of the reactor cell (building) and associated laboratories of the UFTR facility the inspector noted that all portable and fixed radiation survey instruments were calibrated properly. Licensee representatives identified a new screen enclosed storage area located in the reactor cell used for storage of potentially contaminated material. Storage areas for fuel were verified to be controlled and secured by locks. All areas within the reactor cell were maintained as non-contaminated, including the reactor shield top.

. . .

., ( - 1 , I ' 4 , i , Frisking requirements for exiting the reactor cel? were discussed. Licensee representatives stated that a hand and foot frisk was required only for persons subsequant to handlingland manipulating potentially contaminated materials. However. all, personnel who enter the reactor cell are required to pass through a portal monitor for a whole-body surveyj when exiting the _ area. Lic'ensee representatives indicated that a potential requirement of a hand and foot; frisk at all times when exiting the reactor cell in addition to the use of the portal monitor was being evaluated. / No violations or deviations were identified. d. External Exposure Review The inspector discussed the licensee's.perscnnel exposure records for- persons working at or visiting the UFTR facility for the three reporting periods from September 1,!1984, through August 31, 1987. Whole-body exposures were measured by film badges provided by an

NAVLAP accredited vendor laboratory. Highest whole-body exposure values were reported for the September 1,1985, to August 31,/1986, reporting period and were attributed to extensive reactor maintenance work. The highest individda) ex for that period was approximately 1,140 millned (mrem)posureIn general, exposures for RCO i , . ' ' ' personnel providing HP assistance during the maintenance ure less f than 100 arem. For the two other reporting periods reviewed, UTPF and RC0 staff exposure values did not exceed 100 mrem. During review of licensee expnure records, the inspector noted and discussed with licensee representatives potencial radiological conditicas which may have resulted in an assigned oose of 130 mrem to J a ViTR individual for May 1986. A, review of records indicated the ! exposure value to be a typodraphicab error. Licensee representatives stated that the error and' the correct dose assignment would be presented in the next annual yeport. No violations or deviations were identified. f e. Radiation control during Experiments Technical Specification 3.5 specifies limitations on experiments including experimental review requirements for acceptability of reactor power level and irradiation times. The following standard operating procedure (SOP) cnd selected S0P data sheets were reviewed and discussed with licensee representatives. , 50P A.5, Experiments, Rev. 3, dated April 1983 S0P 0.4. A, Record of Sample Irradiation and Disposition, January thnough December 1987 , f f l . - i"

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m - - , - )< 3 NfI '- .,' -l (; } ,( ., v % 5 ' y i S0P D.5.A. Request for UFTR Operation, September 1984 through April 1987 v, The inspector noted that physical restrictions on handling experiment 'f materials, for example, use of fume hoooa for opening enclosed samples subsequent to irradiation, were specified in procedures. In 'll. addition,6 materials from the reactor cell were detailed. specific radiation levels for s // irradiata a ' Radiation levels recorded for experiment materials removed from the reactor were discussed. Exposure values ranged from below detection up to 16 roentgens per hour (R/hr). The inspector noted that many r S0P D.S.A, Request for UFTR Operation, data forms indicated estimated d; activity of 200 mR/h when many experiments resulted in higher radiation levels when initially removed from the reactor. Licensee ') / ' indriduals stated that the values presented on the sheet indicated ' the expected radiation levels when released from the UFTR facility. The inspector questior.ed the importance of this data because the 200 mrem value was already assigned as the maxinra value allowed for release as specified by procedure. In addition, the inspector noted that the use of several separate data sheets to record parameters for a single irradiation experiment was confusing. Licensee representatives stated that the need to include maximum radiation

/ levels expected from the experiment material immedictely upon removal ' , from the reactor and also the collection of data for multiple ' irradiations for a single experiment would be evaluated. ' No violations cr deviations were identified. ' 5. Environmental (80745) , a. MonitoringaM Surveillance Procedures , ' Technical Specification 6.3 requires the facility to be operated and maintained in accordance with approved written procedures. All procedures and major revisions will be reviewed and approved by the ' Director of Nuclear facilities before going into effect. , Technical Specification 3.4.5 requires liquid waste from the , radioactive liquid waste holding tanks to be sampled and the activity 7 measured before release to the sanitary sewer system, e " Technical Specification 3.9.2(3)(b) requires quarterly radiation , level surveys to be conducted in unrestricted areas surrounding the UFTR complex. ' The inspector reviewed and discussed TS required and environmental surveil' lances and liquid waste monitoring procedures with cognizant i licenses representatives. Liquid waste tank sampling, analysis, and , , subsequent releases, and also radiation monitoring surveys of areas

1, 0 outsik th^ restricted area are performed by RCO staff and the data

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' .j y( ( ,f t e , / s i f' ' i 6 3[ 6 , i , (j i, h , ;;' .'f.'4 g , ' ' ' , s / I j / y > , . are tbsh prolded +,o appropria'.i ihar>gement at '31e VI(R. Guidance to con 6 Jt the surveys ind measurements are c'etailed iri the following l Rad'/ tion Contror TeshniqJe procedures: ' b ' i 9, Radiation Contro hTechnique No, i, Instructions for Obtaining . 'k [(1) and Prepcring Liquf d Samples for i a ys-1) [l t i 1 ' 2 Radiation C00 trol / echnique 1.0. 13, In;tructions for Calibration / [ (S ) t and Use of Lahoratory yetection Equim]er,/ ) i

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'( and Discharging Nast? HtAdup Tanh), Instr csionn for Swpli'p (3,1 Radiation Control Tetfique No. , ?J ' .),InquctniforPerformin { (4) Radiat)on Contrcl Tecidique No. ' ' UFTR avironmental '/on horing\\ -{ _ / / , ' \\ ' ,, The a[lln6611ity Od MOlicai ;deta is 5 the pipedures to _ adeoyat'ely addrest > hp?. TS and O CFl.1 Pi tt 20 r60'4 rements were 4 -- dscussed with licedue represen Stives. %e Mspector '10ted that . pMnce , to address inrtrument s nsitivit: . limitations required by i _ 3 lF,r example, lov m; Mmit of, b.ectio., MD) requirements to be .-* tss lhan 25 percen+ycS10 CFR ' art 2.,MPC w1!ies, were not addressed in the procedures. Tne failure to pr W d'e this guidance resulted in ' the TS violation regarding lic,uid waste tank effluent releases (Paragraph 5.b). Fepm reiie,w of procedures and discussion with - licensee r,,agrese.rteVives, t',v inspect.or noted that the Radiati o - Centrol Tect.hiqua proce & ds had not been approvth by the Direct h bf h the Nuclear FF jities Jihe failure t1 have ada.d.e and apprtled 1 procedures fo)iquid effluent releases and ths 'f ailure to have ' ' approved prc;Wuras for envi ror. mental ra @ tion surveys was S , s 6.3,[50 83/88-01-01). j ', identified a: 4 4:(parent"v S.tation of TS 7, ) . r , Analytical Me.b.(ekent Capatility '\\ . I ' g b. , . s 10 CFR 20.201(t') requires the licensee to n e or'cause to be made F such su. "eys as '(1) may be necessary for the licensee,to comp] with ' g regula tier.s in tt is part, and (2) are reasonable urder tr,, circumstar.es .0 ev'aluate the extent of radiatier, hazards that % f be k . ,

present, , , t i U 3 , Technical Spetbicatics 4.2.4(2) requi ms thc Args-41 '&-41) m concentration ;n' hp da'ck ef fluents to bomasured 4emiannually at intervals not q e) Leeo 8 months. ! i ' s, , Technical Specificatior ' 6.b!1(5) requires a routine annual report

1

- I covering the activitina of the reactor facility during the previcus '__ ) Cdlendar year. Each annual opero' ting D ort s W 1 include a summary - 4 of the nature and amont tf radicactile e'llaents re' eased or 9' discharged to the envirens. ihe summary shall it.clutie an estinate of individua> radionuci des pres:qt. If the esti mted average release I i I ) , , g . s h a + s T N ,

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, s , , , t., , , gross radioactive maximum permissible concentration (MPC) in liquid releases to 4 E-7 uCi/ml. The inspector noted that the LLO for '

, liquid effluent release made in 1987, was lower than this MPC but the licensee's survey was inadequate to evaluat if the radioactive concentrations were greater than 25% of MPC in which case identification of individual radionuclides was required as specified in TS. The failure to establish a LLD less than 25% of MPC or to identify individual isotopes present in effluents was identified as an apparent violation of 10 CFR 20,201(b) requirements (50-83/88-01-02). Ar-41 releases for the UFTR facility during the three reporting periods from September 1,1984, to August 31, 1987, were reviewed. The average monthly concentrations released during the review periods , ranged from 1.8 E-9 uCi/cc to 8.96 E-9 uCi/cc when the facility war operational. The annual total curies (Ci) of Ar-41 released ranged from 97.07 to 153.1 Ci. The inspector discussed the analytical accuracy of the licensee's Ar-41 measurements. Guidance for sample collection and analyses are detailed in S0P-E.6, Argon-41 Concentration Measurements, Rev 0, dated January 1984. Cognizant licensee representatives, stated that a liquid matrix standard (1,000 mi marinelli beaker) spiked with Cobalt-60 isotope was utilized for efficiency calibration of the gamma spectroscopy system. The inspector noted that use of a liquid matrix standard which occupied a 1,000 cc beaker volume differed from a matrix gas geometry which has a volume of approximately 1,250 cc. The liquid matrix standard relative to the gas standard would be

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., ., % 8 . positioned closer to the detector and thus, could bias the results in a nonconservative manner. However, the use of a 1,000 cc instead of the 1,250 cc volume of the gas sample collected to calculate the Ar-41 concentration would result in a conservative bias. The licensee stated that the total effect of these identified biases would be evaluated. The failure to use the proper calibration geometry and sample volume to conduct Ar-41 gaseous effluent measurements was identified as an additional example of a violation of 10 CFR 20,201(b) requirements (50-83/88-01-02). 6. Transportation (86740) Transportation of radioactive waste material for the UFTR was discussed. The inspector verified that the licensee has implemented and conducted training regarding new radioactive transportation procedures. Since the last inspection (IE Report No. 50-83/87-01) no shipments of radioactive waste have been conducted. No violations or deviations were identified. 7. Inspector Followup Items (IFI) (92701) a. (Closed) IFI 50-83/78-06-03, Followup of licensee's actions to allow removal of victims from Reactor Building. This item identified potential difficulties with evacuation of accident victims by stretcher from the UFTR facility following a radiological accident. Licensee representatives stated that during Emergency Preparedness drills, prob'ims with movement of accident victims from the UFTR emergency assembly area to the ambulance staging location by medical personnel using a standard ambulance stretcher have not been identified. The inspector toured the pathways between the assembly area and the ambulance staging area and noted no apparent physical obstructions or other difficulties, b. (Closed) IFl 50-83/87-01-04, Followup on corrective actions for failure to run reactor vent system until stack monitor reads less then 10 counts per second (cps). This issue concerned corrective

I actions regarding a licensee identified violation of technical specifications which occurred during an emergency preparedness drill when an energency actuation signal resulted in a secured reactor vent system with the stack monitor measurements greater than 10 cps which violated TS 3.4.3. In letters dated June 2,1987, and March 7,1988, from W. G. Vernetson, Director of Nuclear Facilities, UFTR, to the , NRC Office of Nuclear Reactor Regulation (NRR), the licensee has submitted TS changes to resolve the initial issue and subsequent concerns identified during review of the licensee's proposed TS changes. If adopteo, TS 3.3.1 will require the reactor vent system to be operated until the stack monitor indicates less than 10 cps unless indicated by facility conditions to include loss of building electrical power, equipment failure, cycling console power to dump primary coolant or to conduct test and surveillances and initiating

- _ _ _ _ _ _ _ _ _ _ _ __ ________ _ __ _ _ _ _ _ _______ _ . _ _ _ _ _ _ _ _ .,. ., . % 9 . . the evacuation alarm for tests and surveillances including emergency drills. As a result of the licensee's safety review of the issues and subsequent TS change submittals, this item is considered closed. 8. IE Information Notices (IEN) 92717) The inspector determined that the following NRC IE Information Notices had been received by the licensee, reviewed for applicability, and distributed to appropriate personnel. a. IEN 87-03: Segregation of Hazardous and low-level Radioactive Wastes b. IEN 87-31: Blocking, Bracing and Securing of Radioactive Materials Packages in Transportation Review of licensee training records and discussion with licensee representatives verified that actions, as appropriate, were taken. }}