ML20151E691
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| 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: |
| References | |
| 50-083-88-01, IEIN-87-003, IEIN-87-031, NUDOCS 8804150349 | |
| Download: ML20151E691 (10) | |
See also: IR 05000083/1988001
Text
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NUCLEAR REGULATORY COMMISSION
REGION 11
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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
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G. B. Kuz '
Date Signed
Approved by: /1% '7-/ D
C. M. Hosey, Section Chief
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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.
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8804150349 880407
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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.
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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
2 and comperstly for rot. tine and non-routine issues which were i
, cbserved during the inspection. I
UFTR and Radiation Control Office (RCO) personnel supporting
radiation protect lcn activities for the reactor facility were
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reviewed. The current UFTR staff includes one Class B and threc
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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,
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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
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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.
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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
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approximately 1,140 millned (mrem)posureIn general, exposures for RCO
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personnel providing HP f assistance during the maintenance ure less
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
J conditicas which may have resulted in an assigned oose of 130 mrem to
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.
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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
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S0P D.5.A. Request for UFTR Operation, September 1984 through
April 1987
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The inspector noted that physical restrictions on handling experiment
materials, for example, use of fume hoooa for opening enclosed
samples subsequent to irradiation, were specified in procedures. In
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// irradiata materials from the reactor cell were detailed. specific radiation levels for s
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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
activity of 200 mR/h when many experiments resulted in higher
d; 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.
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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 ;
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/ 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.
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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
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procedures and major revisions will be reviewed and approved by the
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Director of Nuclear facilities before going into effect.
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Technical Specification 3.4.5 requires liquid waste from the
radioactive liquid waste holding tanks to be sampled and the activity
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measured before release to the sanitary sewer system,
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, Technical Specification 3.9.2(3)(b) requires quarterly radiation
level surveys to be conducted in unrestricted areas surrounding the
UFTR complex.
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The inspector reviewed and discussed TS required and environmental
surveil' lances and liquid waste monitoring procedures with cognizant i
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, licenses representatives. Liquid waste tank sampling, analysis, and
1, subsequent releases, and also radiation monitoring surveys of areas 0 outsik th^ restricted area are performed by RCO staff and the data
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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: '
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9, Radiation Contro hTechnique No, i, Instructions for Obtaining .
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[(1) and Prepcring Liquf d Samples for i a ys-1)
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2 Radiation C00 trolt/ echnique 1.0. 13, In;tructions for Calibration /
[ (S ) and Use of Lahoratory yetection Equim]er,/
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and Discharging Nast? HtAdup Tanh), Instr csionn for ?JSwpli'p
(4) Radiat)on Contrcl Tecidique No.
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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
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dscussed with licedue represen Stives. %e Mspector '10ted that .
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pMnce , to address inrtrument s nsitivit: . limitations required by i
3 lF,r example, lov m; Mmit of, b.ectio., MD) requirements to be .-
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tss lhan 25 percen+ycS10 CFR ' art 2.,MPC w1!ies, were not addressed
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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
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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
the Nuclear FF jities 1
Jihe failure t1 have ada.d.e and apprtled h
procedures fo)iquid effluent releases and ths 'f ailure to have
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approved prc;Wuras for envi ror. mental ra @ tion surveys was s S
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identified a: 4 4:(parent"v S.tation of TS 6.3,[50 7,83/88-01-01).
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, b. Analytical Me.b.(ekent Capatility '\ .
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10 CFR 20.201(t') requires the licensee to n e or'cause to be made F
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such su. "eys as '(1) may be necessary for the licensee,to comp] g
regula tier.s in tt is part, and (2) are reasonable urder tr,, with
circumstar.es .0 ev'aluate the extent of radiatier, hazards that % f be
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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
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Technical Specificatior ' 6.b!1(5) requires a routine annual report :1 I covering the activitina of the reactor facility during the previcus '__
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) Cdlendar year. Each annual opero' ting D ort s W 1 include a summary -
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
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Appendix B, Table 1, Column 2. Appendix B, Table 1, Column 2 limits
gross radioactive maximum permissible concentration (MPC) in liquid
releases to 4 E-7 uCi/ml. The inspector noted that the LLO for
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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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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,
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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
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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.
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