ML20151Y903

Review of Texas A&M Univ Nuclear Science Ctr - Beam Port Experiment

ML20151Y903
Person / Time
Site:	05000128
Issue date:	07/15/1988
From:	Kenefick R, Poston J, Sandel P TEXAS A&M UNIV., COLLEGE STATION, TX
To:
Shared Package
ML20151Y885	List: ML20151Y882 ML20151Y903
References
NUDOCS 8808290083
Download: ML20151Y903 (61)

Text

_ _ _ _ _

l Reactor Safety Board Subcommittee Report Review of the Texas A&M University Nuclear Science Center - Beam Port Experiment July 15,1988

_a'in n W. Postdn, Head AdnA 2 des ~

Donald E. Feltz, Director uclear Engineering Department (Chair) Nuclear Science Center A 4 2 d//$ R GLG a,elc hoYert k. Ken'sfi'ckgrofessor gdhfi A. McInt r5lPTo15[or Physics Department Physics Department J .i] .

Philip S.'Sandel,' Hearth Physicist Gerald A. Schlapper, Asal6ciate Prof.

Radiological Safety Office Nuclear Engineering Department em

[E/ d.< <

Fred Sicilio, Professor Emeritus Chemistry Department gDRGOB290083 880728 g ADOCK 05000128 PNU ,

t j

Table of Contents Page G lo s sa ry o f Te rm s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Il I. I nt rodu ctio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. Training Program for NSC Experimental Facilities . . . . . . . . . . . . . . . . . . 3 Ill. Review of Radiological Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 IV. Review of Beam Port Experiment Procedures . . . . . . . . . . . . . . . . . . . . . . 9 V. Summary of Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Appendices A: Minutes of the RSB Subcommittee Meetings . . . . . . . . . . . . . . . . . . . . . . . . 11 B: Information Distributed to the RSB Subcommittee . . . . . . . . . . . . . . . . . . . 24 C: Proposed Training Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 D: Review of Rad.iation Controls Conducted by Office of Radiological Safety......................................................... 37 E: Proposed New Procedure for Experiment Review and Approval . . . . . . . 42 Y

i

GLOSSARY ALARA- As Lew As Reasonably Achieveable (c)(2) device A control device described in 10CFR20.203(c) (2) which shall provide a visible or audible alarm signal such that the individual entering a hi0h radiation area and the licensee or a supervisor of the activity are made aware of the entry.

EA Experiment Authorization ER Experiment Request ERA Experiment Review and Approval Exp Coordinator Experiments Coordinator High Rad / Rad Area High Radiation / Radiation Area HP Health Physicist LRL Lower Research Level MHA Materials Handling Area ,

N Rad Neutron Radiography NRC U.S. Nuclear Regulatory Commission NSC Nuclear Science Center NSCR Nuclear Science Center Reactor NSC Management Director, Assistant Director and Manager of Reactor Operations of the NSC, and Director of Nuclear Research Reactor Programs RO Reactor Operator

, PSB Reactor Safety Board

. .%CP Standard Operating Procedura SRO Senior Reactor Operator Tech Spec or T.S. Technical Specification Pn Pneumatic 10CFR Title 10, Chapter 1, Code of Federal Regulations, Part 20 11 I

O e

1. INTRODUCTION Charge to the Subcommittee:

A Subcommittee of the Reactor Safety Board (RSB) was appointed by Feenan Jennings, Chair of the Reactor Safety Board. The charge to the Subcommittee was:

1. To conduct a detailed review of experiments involving individuals working in "high radiation areas" at ,he NSC and to evaluate in particular the Beam Port #1 experiment conducted by Dr. Reuscher to determine the adequacy of existing procedures.

2. To recommend modifications / changes to procedures to include review, approval, surveillance and training requiremonta to conduct experiments.

3. To review changes in procedures prepared by the Nuclear Science Center (NSC) Operations and Health Physics (HP) staffs.

4. To evaluate the report of the Radiological Safety Office of their review of NSC procedures / practices as required by 10CFR20.203 (c), (2).

j 5. To review the proposed formal training program for NSC personnel /HP staff

~

and reactor users.

Subcommittee Membership:

John W. Poston, Head, Nuclear Engineering Department (Chair)

Donald E. Feltz, Director, Nuclear Science Center Robert A. Kenefick, Profess'sr, Physics Department John A. McIntyre, Professor, Physics Department Philip S. Sandel, Health Physicist, Radiological Safety Offica Gerald A. Schlapper, Associate Professor, Nuclear Engineering Department Fred Sicilio, Professor Emeritus, Chemistry Department Feenan Jennings, Ex Officio, Director, Office of University Rosearch 1

Structure of Activities:

(Details of these activities are given in the minutes of the Subcommittee. See Appendix A.)

The Subcommittee held its organizational meeting on May 16,1988. Documents pertinent to the charge of the committee were distributed (Appendix B).

On May 17 the Subcommittee toured the NSC. Particular attention was directed to the research facility at Beam Port #1 where a beam of neutrons and gamma rays enters the lower research level of the NSC.

The Subcommittee met on May 20 for discussion of the warnira lights and personnel access controls in the lower research level at the NSO. A draft of a flow chart for Experiment Review and Approval by the NSC was also submitted by Feltz for discussion by the Subcommittee. Suggestions were made for minor changes in the flow chart.

The review by the Radiological Safety Office of the "High Radiation Area Control at the Nuclear Science Center" was discussed by the Subcommittee at its May 30 meeting.

At the June 6 meeting, Sandel presented a draft for the proposed training program for NSC personnel and outside experimenters. Course content and the i selection of teachers were the main topics discussed. Feltz also distributed a revised flow chart for the Experiment Review and Approval P.ocedure which has been incorporated into a draft SOP IV-A. Chairman Poston then presented an outline for the Subcommittee report to the Reactor Safety Board and assigned portions of the report 1

to the various Subcommittee members, l

l .

2.

1 II. TRAINING PROGRAM FOR NSC EXPERIMENTAL FACILITIES A comprehensive training program has been recommended by the NSC staff to include routine experiment review, radioactive material handling experiment review and approval procedures, and ALARA review.

Specific training for Individual experimenters will be required prior to their being certified to operate experimental facilities in addition to the orientation and security procedure lectures currently required.

The complete training course outiine for each group as well as the examination procedure and instructor certification procedure are included in Appendix C of this report.

The Subcommittee has reviewed and recommends implementation of this training program with the additional recommendation that certification of instructors be submitted to the RSB for approval and that the RSB review and approve lecture outlines for the program.

Ill. REVIEW OF RADIOLOGICAL CONTROLS As stated above, the Subcommittee visited the Nuclear Science Center (NSC) to review current radiological control methods. The existing arrangements were reviewed in light of current NSC procedures, experiment approvals (EA's), and pertinent sections of Title 10 Code of Federal Regulations Part 20 (10CFR20). The review focused primarily on the lower research level but the upper research level (reactor pool level), the irradiation cell, and the equipment mezzanine were also included in the evaluation. in addition, the Subcommittee reviewed a report prepared by the Office of Radiological Safety regarding radiation controls at the NSC (Appendix D).

3

The Lower Research Level:

Current procedures transfer responsibility from the reacto,' operations staff to the individual experimenter when experiments are to be conducted on the lower level. An announcement is made throughout the NSC notifying personnel that the lower research level is off limits due to activities in the area. The extent to which the individual researcher is responsible for surveillance of an identified experimental area and for the protection of others is determined by the particular experiment. For example, neutron radiography is conducted in a heavily shielded area and entry into the immediate beam port area will (under certain conditions) cause a reactor scram.

Film cassettes are loaded remotely and the Individual involved is not exposed directly to a beam exiting the reactor. The loading area is equipped with a "(c) (2) - device" which is actuated upon opening the locked entry door. Other areas have some shleiding but the process or research activity may cause elevated radiation levels in certain areas outside the existing shielding and/or generate the potential for exposure to airborne radioactivity. Again, entry into this area, through a locked gate, will cause the actuation of a local "(c) (2) - device" as a warning.

The experiment which caused this detailed review represents another catego:v in t

that wire fences were not initially erected and entry into a high radiation area was controlled crity through direct surveillance by the experimenter as allowed by l

10CFR20 for periods of less than 30 days. During this initial period, control over entry into the lower research level was maintained through the outer control procedure.

! Extension of control from the entire lower research level to a much smaller area is I

called "outer to local-control." It was the failure to make this extension and the lack of many positive checks which could be root causes of the failure to controlIndividuals in a high radiation area.

4 L

Recommendations for improvement:

The recommendations listed below are intended to strengthen the radiation control aspects on the lower level and to ensure that the probability of accidental exposure of personnelis reduced to a minimum, in the past, a television camera was used to monitor activities on the lower research level. Due to lo.y use of the area, this camera was removed a number of years ago and relocated. It is recommended that at least one television camera be installed on the lower research level. The signal from this camera should be routed to the reactor control room. Such an arrangement will allow increased surveillance of activities on the lower level and will strengthen other recommendations included in this section.

Entry into the lower research level is under procedural control of the reactor operations staff. However, after the issuance of a key, there is truly little control over the identity of those entering the area. For this reason, the Subcommittee recommends that solenoid operated locks be installed on entry doors. These locks shall be actuated from the control room upon an oral request transmitted over an intercom system also located at each door. The Subcommittee recommends that procedures be developed to cover the details of entry and egress from the lower research level. It should be emphasized that the solenoid arrangement, etc. should not prevent egress from the lower levelin case of emergency. In addition, careful consideration should be given to whet.*er the solenoid lock will fail open or closed. The Subcommittee recommends failure in the closed position with a "key over-ride" for authorized entry by supervisory and/or emergency personnel. The number of keys should be limited only to essential 9

personnel and, perhaps, a single key in the control room "key box."

The Subcommittee also recommends that warning lights be located outside entry doors to the lower level. This is in contrast to the current arrangement in which each 5

door to the crea must be open:d to determine whether or not the w rning light is illuminated. This recommendation will bring the "(c) (2) - controls" more in line with existing national standards regarding such warning systems. Careful consideration should be given to the number of lights to be used, whether the lights should be flashing or not, the color of the lights, and the procedure for their activation. The Subcommittee has no strong feelings on these points as long as all possibilities are considered carefully and the meanings, appropriate responses, etc. are included in the training of all NSC personnel and users.

Concerning the warning lights,it is recommended that appropriate warning signs be placed on all entry doors indicating the status of the area based on the lights illuminated, the procedure for entry, dosimetry requirements, and any other requirements or restrictions imposed on those ontering. Procedures also should be established to ensure that warning signs are current and legible. The legibility question is especially important on the outside (truck ramp) door.

Entry to the lower research level could be gained, under unusual circumstancec, i

through the door to the balcony. Currently this door is not locked and is not controlled through alarms and/or procedures. Although the use of this door to gain entry to the lower research level would constitute a very unusual situation, it is certainly possible.

The Subcommittee recommends that this door be controlled by locking it and that access to the balcony be granted by the roccMr cparat!Onc stall through the issuance of a key Procedures must be developed to control this process.

The Subcommittee recommends that the warning light system in thu Beam Port

1. 4 area be improved. The current location of the warning light is poor and, in many cases, may not be visible to individual!. entering the area unless their attention is focused in a specific area of the room. One possible location for this light is directly 6

cbove cnd autside of the entry door to the area. A s

cond location would be directly inside the intry but in a location much more obvious to those entering. Since only a '

small area of the rocm may be a high radiation area dur'ng operations,it appa.ts that the second location would be preferabk .  ;

1 At present, beam port experiments may be conducted with "local (c) (2) - devices" attached to fences and actuated by gates, doors, etc. The doors include not only entry doors but also shleid doors covering beam ports. The Subcommittee reviewed the use ,

of a "selector" switch which allowed the experimenter to decide whether the gate or the i

beam port shield door would actuate the "local (c) (2) - device." The Subcommittee

] expressed some concern regarding this arrangement and recommends that it be change 1 It appears that the optimum arrangement would be one in which the waming device be actuated upon opening the gate or door to an area and that both this action and the opening of the beam port shield door be indicated in the reactor control room.

For situations in wh!ch an unprotected beam exists, e.g., the conduct of beam port radiation surveys, and testing and alignment of experiments and equipment, it is i

recommended that access to the lower research level be restricted to those directly l

l Involved with the unprotected beam. Under the recommended system of controls this recommendation represents a transfer from "local control" to "outer control."

l The Subcommittee also discussed the possiblity of interlocking the "(c) (2) -

device" with other safety devices, such as a water shutter, to reduce the possibility of personnel exposure upon entry into an exposed beam area. Clearly it would be l

possible to interlock and shleid the area such that no useful research could be conducted. For this reason, the Subcontmittee makes no recommendation on this

(

j point but suggests that this is a matter to be considered carefully during the experiment l review and approval process conducted by the NSC staff and the Reactor Safety i

7 i

..Atr n

Board.

The Subcommittee expressed concern over the number of keys issued to NSC staff which allow essentially unrestricted access to many areas within the Center. It is strongly recommended that a careful review of the need and distribution of keys be

~

l conducted and that the number of available keys be greatly reduced. It is not the Intent of the Subcommittee to impede activities within the NSC. However, it is prudent that I

accr:ss to potentially high radiation areas be controlled by more than an audible announcement placing an area "off limits to NSC personnel."

Perhaps, our most important recommendation is the initiation of an improved experirrental review procedure (Appendix E). With reference to the incident at Beam Port #1, there was no final review of the experiment conducted at the boam port. The tighter review procedure described in Appendix E will require RSB final review of all beam port experiments.

The Upper Research Level:

Two areas were included in the Subcommitteo review of this research level; these were the materials handling area and the irradiation cell. Neither of these areas require extensive changes to the methods of entry control. However, the Subcommittee discussed the need for additional barriers (gates) on the steps or between the reactor pool wall and the control room. Radiailon surveys in the area indicated that certain areas constitute high radiation areas while others have relatively low dose rates. The Subcommittee recommends that gates (and appropriate warning devices) be placed at the top of each set of stairs leading to the platform over the irradiation cell. These areas will be designed as high radiation areas during normal operations near the cell. Surveys to define the extent of the radiation field and define the boundary for posting radiation areas on the upper research level shall be the 8

resp nalbility cf th] NSC h alth physics staff. Procedures must be revised and/or developed to ensure the complete understanding of responsibilities and the conduct of cell operations.

The Equipment Mezzanine:

Entry into this area is essentially uncontrolled and warnings consist only of signs posted on the doors. Cerinin experiments cause a high radiation area on a portion of the mezzanine. For this situation, additional warning signs and a rope barrier is put in d

place. However, it is possible to enter the area from "behind the barrier" and for the individual to be unaware of the oxisting radiation field. The Subcommittee recommends that the source of this radiation field (an off-gas hold-up tank) be shielded appropriately so that posting of the area is not required.

IV. REVIEW OF BEAM PORT EXPERIMENT PROCEDURES Two members of the Subcommittee studied the review, approval, and procedures for conduct of beam port experiments at the NSC. Main emphasis was placed on the following Standard Operating Procedures, Experiment Authorizations, and Technical Specifications: SOP l A,1 B,1 C,1 D,1 E,1 F, ll A, ll C, ll M, IV-A, IV B, IV C, IV-D, IV E, IV F, IV-G, IV H, Vil A1, Vil A5, Vll B13, IV C13, Vll D1, Vill Et, E 1, E-3, E 4, E 5, E 6, E-12 E-17 E-19, E-20, E 21, and Tech. Spec's. 1.2, 1.6, 1.7, 1.8, 1.17, 1.23, 1.37, 3.6.1, 3.6.2, 3.6.3, and 3.7.

It must be stated emphatically that, even though the Subcommittee has recommended a number of improvements, it is our considered opinion that the existing controls and procedures meet the intent and requirements of 10CFR20,203(c)(2). In our opinion, the existing procedures, while not optimum nor as extensive as those found in nuclear power reactors, can serve to protect NSC personnel from inadvertent exposure to radiations emanating from reactor beam ports. The incident was caused 9

by failure to implement the written procedures. Modificatior.s of the procedures and additional training should aid in preventing a recurrence of this type of incident.

V. Summary of Recommendations The Subcommittee has conducted a detailed review of the experiment review and approval process at the Nuclear Science Center. In addition, the review included evaluation of radiation control techniques and procedures for use in NSC research areas. The Subcommittee has made the following recommendations:

a) an expanded training program should be implemented at the NSC. See section ll of this report and Appendix C.

b) improvements and/or modifications should be made to procedures and techniques used to control access to radiation and high radiation areas within 4

the NSC. See section til of this report for specific re. commendations.

c) the experiment review and approval process should be revised to include more RSB oversight and approval. See Appendix E for a draft procedure.

l l

l l 10

APPENDIX A Minutes of the RSB Subcommittee Meetings s

P t

f

's l

11

) MINUTES RSB Subcomittee for the Review of NSC Experiments and Radiological Control 11 May 1988 An organizational meeting of the Subcomittee of the RSS for the review of NSC experiments and radiological control was held on May 11,1988 at 9:00 s.m. in Room 307 of East Bizzell with the following in attendance:

Subcomittee Chairman, J. Poston: Subcomittee Menbers G. Schlapper, J. McIntyre, R. Kenefick, P. Sandel, D. Feltz, F. Sicilio and RS8 Chairman F. Jennings.

Jennings opened the meeting and announced the addition of F. Sicilio to the sub-comittee. Following a brief statement of why the subcomittee was formed (reference RSB Minutes of 4/4/88), the meeting was turned over to subcomittee chairman Poston.

Poston reviewed the memorandum of May 6,1988 from Jennings to the subcomittee chairman which outlines the tasks of the subcommittee and establishes deadlines for reports and implementation of recommendations.

The availability of subcomittee members during the time frame for completing scheduled tasks was discussed. Schlapper will be unavailable May 13 through May 28, June 6 through July 4 and July 12 through August 18. Kenefick will be un-

) available June 1 through July 10.

Poston requested that material be made available to menbers who do not have copies of the March 30, 1988 USNRC Region IV inspection report, the two USNRC Confir-mation of Action Letters of March 17, 1988 and April 20, 1988, the USNRC summary letter of April 21, 1988 regarding the enforcement conference, minutes of the special RSB meeting of April 4, 1988 to review the Beam Port #1 experiment, and Schlapper's notes of the exit interview following a return visit to the NSCR by USNRC Region IV on April 11 12, 1988.

The subcomittee reviewed the USNRC Region IV inspection report of May 5, 1988 regarding inspection of NSCR operations. No violations or deviations were identified during the inspection. The inspection report does however reference actions to be taken by the RSB to correct procedures and deficiencies in review and approval of experiments conducted at the NSC.

Poston noted that the subcomittee would concentrate on the items listed below and due to the large amount of work to be done in such a short time, it would be necessary to assign nenbers to handle certain tasks.

1. Training with special attention paid to 10CFR19.

2. Monitoring and control of individuals in "high radiation aress" and "radiation areas" in reference to 10CFR20 and national standards on radiation protection.

.]

12

. o a

3. Conduct a review of the experinent review and approval process and general procedures to conduct experiments at the NSC.

)

4. Review existing procedures and identify corrective measures to conduct beam port experiments.

The following committee assignments were made:

Sandel Review the draft of the formalized training program prepared by NSC and HP staff.

Sicilio, Poston look into the review, approval and procedures for conduct of beam port experiments.

Feltz, Poston Review ANS/ ANSI 15.11, "Radiological Control at Research l- Reactor Facilities" and N13 Radiation Protection Standards Group Meet on Friday, May 13, 1988, 9:00 a.m. at the Nuclear Science Center to tour the facility and-identify research activities and locations of potential "high radiation areas" and "radiation areas". Following the tour there will be a short meeting of the members for discussion.

Respectfully submitted, f^",

Donald E. Fe, z, Director Nuclear Science Center 4

13

MINUTES RSB Subcommittee for the Review of NSC Experiments and Radiological Con'rol 13 May 1988 j

The RSB Subcommittee for the review of NSC experiments and radiological control met on May 13, 1988 at 9:00 a.m. to tour the Nuclear Science Center with the following in attendance:

Subcomittee Chairman, J. Poston; Subcomittee Menbers G. Schlapper, J. McIntyre, R. Kenefick, P. Sandel, D. Feltz, F. Sicilio and RSB Chairman F. Jennings.

The tour began on the lower research level wi'h Feltz explaining the present "C-2" control of the Beam Port #1 area. It was explained that there is no present use of the facility until completion of review by the RSB and that the present "C-2" control was not the same setup that was present during the neutron diffraction experiment. The inner / outer "C-2" control of the lower research level and Beam Port #4 sample preparation room was also described. The Beam Port #4 neutron radiography cave and shield system was described and noted as being a "high radiation area" when in operation. Procedures and special equipment for the control of individuals working in the N-Rad facility were described. Other areas of interest on the lower research level were the thermal column film irradiator experiment, the chemical laboratory and vent hood systems and the delayed neutron counting lab. These are potential high radiation and radiation areas.

The group viewed the "high radiation area" produced by the filtering of fission product gases when the film irradiator is in use. Control of the "radiation area" that occurs near the filter tanks during conduct of the film irradiator experiment

) was also discussed. This area is located on the mechanical chase near the central exhaust fan.

The group then toured the upper research level where potential "high radiation areas" in the materiils handling area and irradiation cell were discussed.

Procedures for use of the irradiation cell were described. The "bone yard" which is used for storage of irradiated reactor components and expuiments was noted as being a "high radiation area". The "bone yard" is located outside the facility adjacent to the pool wall extension.

The subcomittee met briefly following the tour and scheduled the next meeting for 9:00 a.m., May 20, 1988 in Room 129-A of Zachry.

Sandel indicated he would meet with Kevin Crawford, Manager of Reactor Operations and Chris Meyer, Senior Health Physicist to review the draf t of the formalized training program prior to the next meeting.

Feltz indicated that a program to update approved experiment authorizations (EA's) was initiated in the fall of 1987 and some material is available for sub -

coninittee review.

Respectfully submitted, Donald E. , Director Nuclear Science Center la

. o MINUTES RSB Subcomittee for the Review of NSC Experiments y

and Radiological Control 20 May 1988 The RSB Subcommittee for the review of NSC experiments and radiological control met on May 20, 1988 at 9:00 a.m. in Room 129-A Zachry with the following in attendance: Subcommittee Chairman, J. Poston, Subcommittee Merrbers J. McIntyre, R. Kenefick, P. Sandel, D. Feltz, F. Sicilio and RSB Chairman F. Jennings.

Chairman Poston opened the meeting to a discussion of what the Subcommittee should focus on for the meeting. It was decided to direct attention to a review of present procedures for control of personnel and the isolation of potential high radiation areas and radiation areas on the lower level of the NSC.

Poston presented several suggestions for the improvement of control of the NSC lower research level during the conduct of experiments that result in a "high radiation area" 'or a "radiation area". The follosing is a list of suggested actions or evaluations:

1. Provide camera surveillance (CCTV) of experiments.

2. Provide additional visual "C-2" lights at the entry door to lower research level and the down ramp personnel door with signs that identify the meaning of the light.

, 3. "C-2" light in BP 4 cave needs review. Moving the light to be seen directly ahead upon opening the door to the prep-room or adding a light may be an improvement.

4. Consider earlier recomendation that the lower level be controlled by authorizing each individual entry by use of an intercom to the control room and a solenoid operated door latch to be actuated from the control room.

5. The door to the balcony on the icwer research level should remain locked.

, 6. Evaluate key control measures to ccntrol personnel.

7. Evaluate the optional "C-2" switch for control of Beam Port experiments that selects either the shield door microswitch or a microswitch located on a fence entry gate. A considered improvement would be an additional indication in the control room that either or both microswitches have been actuated.

8. Provide shielding of the fission product holdup filters located on the mechanical chase to reduce the fenced area at the filters to a "radiation area" rather than a "high radiation area".

kh 15

Minutes Page 2 Poston stated thu he and Sicilio had reviewed beam port experiment procedures and they found the procedures adequate with only minor changes needed. This was followed by a discussion regarding the failure to implement procedures and hcw to prevent a reoccurrence. Feltz indicated the NSC staff had been working on new review and approval procedures. A draft flow chart describing proposed review and approval procedures that would recpire additional staff review regJirements of new experiments and modifications to experiments was submitted by Feltz. Following discussion of the flow chart, the subcomittee recomended that the RSB have final approval of some but not all experiments that are performed under existing Experiment Authorizations. The requirement for review by NSC Staff Meeting will be followed by RSB Subcommittee review when specified as a regJirement in the Experiment Authorization. Feltz indicated he would modify the flow chart and prepare a draf t S0P for review and approval of experiments. The draf t would be ready for review on Friday, 27 May by Sicilio and presented to the subcomitee at the next scheduled meeting.

Sandel reported that he met with Crawford and Meyer at the NSC to review the draf t training program "Experiment Facilities and Procedures Program". He indicated the program should be reduced in detail and commitment. He reviewed the training program against ANS 15.11 and was satisfied and will also evaluate the program against ANS 15.4. The draf t training program should be available for subcomittee review soon.

The next scheduled meeting was set for Monday, May 30,1988 at 9:00 a.m. in koom 129-A Zachry.

Respectfully submitted, j [

Donald E. e tz Director, NSC

)

16

MINUTES g RSB Subcomittee for the Review of NSC Experiments

.1 and Radiological Control 30 May 1988 The RSB Subcomittee for the review of NSC experiments and radiological control met on 30 May 1988 at 9:00 a.m. in Room 129-A Zachry with the following in attendance: Subcomittee Chairman J. Poston, Subcomittee Members J. McIntyre, R.

Kenefick, P. Sandel, G. Schlapper, F. Sicilio, D. Feltz and RSB Chairman F.

Jennings.

The minutes of the May 20, 1988 meeting were reviewed with comment that a state-ment be added that the fission product filter tanks located on the mechanical chase of the NSC should be shielded to reduce radiation levels during operation of the film irradiator experiment. Typo's and a change to the date of the minutes were also noted.

Sandel reported that he met again with K. Crawforo and C. Meyer and reviewed the d ra f t training program "Experiment Facilities and Procedures Training Program".

The draf t is not completed but will be ready for submittal to the subcomittee pending addition to the program of testing reg >irements and acceptance criteria.

The subcomittee reviewed the report from the Radiological Safety Office of the review of high radiation area control procedures and practices at the NSC for compliance with 10CFR20,203(c)(2). The following comments were made reganjing the RSO findings and recomendations:

I. CONTROL 0F RADIATION AREAS AND HIGH RADIATION AREAS ON THE NUCLEAR SCIENCE CENTER LOWER RESEARCH LEVEL (LRL)

A. The subcomittee suggested that the solenoid locks for control of per-sonnel to the 1m er research level are to lock on loss of electrical power (voltage applied to unlock) and are to have NSC supervisor key override.

B. Sicilio suggested that the description of the "Radiation Area" sign to alert personnel that radiation areas may exist include the use of warning lights and that the sign apply only when the light is flashing (planned activity or noted conditions). Poston comented that two bulbs be used on the sign to provide redundancy.

C. A discussion followed a suggestion by McIntyre that water shutters to beam ports be actuated to close upon entry to a "C-2" controlled area as defined by a fence or cave. It was noted that this may not always be desired and should be considered during RSB review of each new experiment.

O b

• 17

11. CONTROL OF HIGH RADIATION AREAS ACCESSIBLE FROM THE UPPER RESEARCH LEVEL (URL) AND OTHER AREAS A. Sandel agreed to verify that "C-2" control is not needed for material handling on the upper research level. He will report to the board his finding regarding the levels of sample activity that would recpire "C-2" control during handling.

B. The suggested removal of the "C-2" control of the upp'er research level was discu ssed. It was recomended to retain the"C-2 for the URL not necessarily for implementation during irradiation cell operations but for its possible use during special fuel movements or measurements.

The subcomittee deferred final comments on the need for "C-2" gates for irradiation cell control until further evaluation. It was noted that during the perfonnance of these experiments there is visual and

dministrative control of the upper research level. The present pro-cedures may be adecpate. Sandel suggested that if gates are to be used, one could consider folding gates.to improve set-up reg;irements and to save space.

C. It was the opinion of the subcomitee that the implementation of "C-2" control of the cell entry door area was not necessary due to present instrumentation and administrative control procedural recpirements for making cell entries.

Ill. PROCEDURAL REQUIREMENTS FOR CONTROL 0F RADIATION AND HIGH RADIATION AREAS 3 In reference to the recommendations in this section, Kenefick noted that the subcomittee was presently reviewing draf t procedures for review and approval of experiments and a training program for individuals involved in experiments conducted at the NSC. Poston stated that the results of triese reviews and a summary of subcomittee comments and procedural recommendations regarding the RSO memorandum on control of high radiation area and radiation areas at the NSC would be contained in the draf t report to the chairman of the RSB.

The next scheduled meeting of the subcomittee was set for Monday, June 6,1988 at 1: 30 p.m. in Room 129-A lachry.

Respectfully submitted,

! /.11 Donald E. Fe z, Director Nuclear Science Center

)

18

MINUTES s

RSB Subconunittee for the Review of NSC Experiments

...) and Radiological Control 6 June 1988 The RSB Subconunittee for the review of NSC experiments and radiological control met on 6 June 1988 at 1: 30 p.m. in Room 129-A Zachry with the following in attendance: Subcommittee Chainnan J. Poston, Subccanittee Members J. McIntyre, P. SaMel, F. Sicilio, O. Feltz and RSB Chainnan F. Jennings.

The Subconinittee discussed the status of the NSC Experiment and Procedures Training P rogram. The follcwing questions were raised and then discussed:

(a) What is the procedure for the selection, training and certification of individuals presenting lectures?

(b) Who prepares lesson outlines?

(c) What is the procedure for review of lesson outlines?

(d) Will there be a procedure to upgrade an inactive experimenter?

The Subconunittee reconwnended that the certification of instructors be submitted in writing by the NSC Director and TAMU RSO to the RSB for approval. The RSB is to also review and approve lecture outlines.

3 The Subconunittee also reccanended that the NSC staff prepare and present to the RSB a plan for the selection of instructors, preparation of lecture outlines and their approval. The upgrade of inactive experimenters is to be conducted un a need basis. The upgrade may be accomplished by oral review.

McIntyre expressed his concern that an individual be permitted to work in the area of an unprotected radiation beam. He recommended that the beain be automatically closed upon entry into a "C-2" controlled workspace and that unprotected beams be limited to a specified radiation dose rate unless exempted by the RSB. Poston indicated he would evaluate the reccanendation to detennine the effect it might have on experiment set ms, conc luct of tests and radiation surveys.

Sandel reported that his ,.<aluation of routine sample handling activities con-ducted on the upper research '? vel would not constitute the need to control the area by "C-2" implementation. he suggested that the NSC Senior Health Physicist document this by memorandum to file and review the memorandum in a NSC staff meeting.

The subject of the need for "C-2" control of the irradiation cell deck and steps area was reopened pending a review by Sandel of existing surveys to identify "high radiation areas" associated with cell operations. If "C-2" control is reccanended Sandel suggested that the "C-2" area be established by conducting surveys using the new neutron instrumentation.

)

19

- Poston presented a proposed outline for the RSB Subcommittee report. Assignments

- were made to members for preparation of material for the report.

The next meeting of the Subcomittee was scheduled for Thursday, 23 June 1988 at 1:30 p.m. in Room 129-A Zachry.

Respectfully submitted, 6( n ,hi Donald E. Fei z, Director Nuclear Science Center

'l I

I i

i I

20

o- ,

MINUTES RSB Subcommittee for the Review of NSC Experiments and Radiological Control 23 June 1988 The RSB Subcommittee for the review of NSC experiments and radiological control met on 23 June 1988 at 1: 30 p.m. in Room 129-A Zachry with the following in attendance:

Subcommittee Chairman J. Poston, Subcommittee Members J. McIntyre, P. Sandel, F.

Sicilio. D. Feltz and RSB Chairman F. Jennings.

The subcommittee addressed the proposed outline for the report to the RSB. Members presented draft copies of sections of the report that were assigned to them. The material was reviewed and comments recorded as follows:

Introduction - McIntyre presented the draft introduction. No major additions or changed were made. Appandix B to the introduction ,which is a listing of documents provided to the committee for use in the review, is to be relocated to the Appendix section of the full report. A statement was added that the flow chart for the draft Experiment Review and Approval Procedure was reviewed and was incorporated into draf t S0P IV-A. Sicilio suggested that a glossary of terms be added to the report.

Training Program - Sandel presented a draft summary and recommendations of the sub-committee regarding content, implementation, and maintenance of the proposed training program. A renewed discussion of the need to test individuals resulted in the recommendation to retain testing requirements. Any further discussions of the testing requirement can be addressed by the full RSB committee during their review of the training program.

Review of Radiological Controls -

Poston issued a draft of this section of the

, report. The members asked that this section be reviewed at the next meeting to allow time to study the naterial and generate comments. Sandel reported the ,

results of surveys of the irradiation cell platform, steps,and the reactor bridge during cell 'perations. Survey results indicate that gates at the top of the steps on both sides of the platform would control entry into a "high radiation area" (the platform opening to the cell). The report will recommend "C-2" control at the top of the steps and the posting of radiation areas.

Review of Procedures - This section was presented by Sicilio and consisted of a listing of procedures, experiment authorizations and technical specifications.

Appendices - This section of the report is complete except for minutes of meetings.

These will be provided by Feltz. Final draft copies of the Proposed Training Program and Proposed New Procedures was submitted by Feltz.

Feltz submitted a proposed procedure for surveillance requirement for experiments. ,

The surveillance requirements would be generated during NSC Staff Meeting review of a specific experiment (NSC Form 512) and the performance of HP surveillance re-quirements would be documented in the daily .N!X: HP Log, 21

.. .t;.

'l The next meeting of the RSB Subcommittee was scheduled for Monday, June 27,.1988 at 1: 30 p.m. in Room 129-A of Zachry.

i Respectfully submitted.

A Al W?

W nald E.'Feltz, Director.  !

Nuclear Science Center. i i

r 4

i t

i r

I I

i.

22

D .

MINUTES '

RSB Subcommittee for the Review of NSC Experiments and Radiological Control 27 June 1988 The RSB Subcommittee for the review of NSC experiments and radiological control met on 27 June 1988 at 1:30 p.m. in Room 129-A Zachry with the folicding in attendance l

Chairman J. Poston, Subcommittee Members J.- McIntyre, P. Sandel, F. Sicilio and 0, l Feltz.

The subconunittee reviewed thi draf t report to be submitted to . the RSB. Typo-graphical errors, comments and corrections were made with no significant changes j

made to the subject matter presented in the report.

l Feltz and Sicilio were assigned the task of preparing a glossary of terms used in the report.

The scheduled meeting 6f the RSB Subcommittee was scheduled for July 13,1988 at 1:30 p.m. in Room 129-A Zachry.

Resppctfully submitted, Ah i

f

(&

Donald E. Feltz, Director Nuclear Science Center t

23

APPENDIX B Information Distributed to the RSB Subcommittee 24

1. Description of the Neutron Diffraction Studies E.;periment Conducted by Dr. J. A.

Reuscher at the Nuclear Science Center and a Chronological Listing of Events for the Period June 1987 to Present.

2. Letter to Dr. Hwrbert H. Richardson from the Nuclear Regulatory Commission.

Subject:

Confirmation of Action Letter. (March 17,1988)

3. NRC information Notice No. 8810: Materials Licenses: Lack of Management Controls over Licensed Programs. (March 28,1988) 4 Letter to Dr. Herbert H. Richaidson from the Nuclear Regulatory Commission:

Subject:

Inspection ccnducted by Mr. H. D. Chaney on March 7 9. (March 30, 1988)

5. Minutes of the Reactor Safety Board (April 4,1988)

6. Memorandum to J. W. Poston from G. A. Schiapper. Su ject: Fact Finding visit of Mr.

Dear) Chaney and Mr. Blaine Murray,

U.S.N.R.C. (11 and 12 April 1988) Exit Interview. (April 13,1988)

7. Letter to Dr. Herbert H. Richardson from the Nuclear Regulatory Commission.

Subject:

Enforcement Conference. (April 21,1988)

9. Letter to Dr. Herbert H. Richardson from the Nuclear Regulatory Commission.

Subject:

Inspection conducted by Messrs. H. D. Chaney and B. Murray on April 11-12,1988. (June 13,1988) l i

25

APPEN0lX C Proposed Training Program 26

r w ---4 w -- - --. - - - - - - - -

m. .- ,

NUCLEAR SCIENCE CENTER EXPERIMENT FACILITIES AND PROCEDURES TRAINING PRCCRAM June 8, 1988 Introduction The performance of experiments and radioactive materials handl. ng sre a najor portion of the daily routine of tha NSCR operation. The wide var. cy of experi-ments and procedures and sometimes infrequent perfor.aance p oviv . ample oppor-tunity for experimenter error. Tne facilities and Procedures % aining Program is designed to train reactor operators, health physicists, and experimenters on the p oper procedures. hardware design, potential problems and limitations of opern ,

tional experimenta. facilities at the NSC to elimina,e problems associated with performance of NSC tasks.

The scope of the prog,am includes routino experiments as well as general training such as radioactive materials handling experiment npproval, and ALARA. In addi~

tion, provisions for documentation of uns:heduled lectures for training on non-routine experiments and speuial proced:Jres are included. While indoctrinatien training is included - in the experimenter training (See Fxperimenter Training Lecture 1, part A for indoctrination training references), this program dnee not accommodate initial indoctrination training for hSC personnel.

The NSC Director or his deaignee is responsible for implementation and adsinistra-tion rf this training program.

Description Routine Training The training needs of operations, technical services, and health physics per-sonnel and experimenters are quite different. Therefore, to accommodate each group efficiently, the training program has been divided intn two groups. Each training group will be required to reevive a documented series of lectures biennially. The lecture outlines are included in this program. The lectures will

'ce detailed using the outlines, according ta the needs of the trainees. All lectures will be followed by testing of each trainee. Lectures on specific facilities will include both classroom and walk-around training. Lecturers will d

be assigned from NSC and HP strffs who have been certified by memo as qualified to conduct the training lecture. Biennially, the routine program will be reviewed j and updated to include experiment modificat4ons and new eyporiments.

Operations, technical services, and health physict group training will consist of a series of lectures on currently operational experiser.: facilities and will be

doeurented on NSC form 515a shown in the attachment. This continuous training program will be offered biennially. The training completien records will be main-tained in the Requalification/ Training Program file located in the reactor control e

27

~ ~

~

room. Personnel that are unable to atte d the lecture under extraordinary circum-stances will be required to read the lecture references before signing the training completion form. Written examinations will be given following training completion as described in the section "Examination Procedures". A complete series of training completion forms (currently nine forms) will be maintained with NSC Form 515b, the biennial training summary form.

Individual experimenter training will be recorded on NSC Form 515e shown in the attachment and maintained on file in the reactor control room. Experimenters will be required to attend the general lecture and exam and applicable specific lectures and exams before being certified to operate experimental facilities.

Experimenters will be required to complete i'.11 tial certification and biennial recertification. If NSC Management determines an experimenter requires additional training, retraining will be completed and documented en NSC Form 515c.

Non-routine Training Training on substantially modified and new experiments and procedures will initially be addressed separately from the routine program. After development and staff review of new procedures, a training session will be scheduled which will include operations, technical services, and health physics personnel as well as experimenters. Following the non-routine training lecture, completion of training on the new procedure will be documented on NSC Form 515d with attached NSC Form 521 as necessary and kept on file in the control room. Af ter development and staff review of modified procedures, a memorandum describing the modifications will be issued to all personnci as required reading and documented by a routing slip, new or modified procedures will then be included in the routine training during the biennial upcate of the routine training program.

Examination Procedures Each lecture will conclude with an exam that will consist of questions frem the lecture material. The exam will be graded by the certified lecturer and grades recorded on NSC Form 515a after the trainee has signed the training completion. A score of 80% or better will qualify as passing. A score of less than 805 will require additional training which will be documented by the lecturer on Form 515a.

28

, . - - - - _ _ _ _ _ - _ ._ _ _ _ - _ _ _ _ _. ~. . . - - . . . - . . . - . - . . . - - - _-.

7 o- .

\ l Operations, Technical Service, and \ Health Physics Staff Training t Lecture- Reference

11. General Training i a.. Experiment Approval SOP IV-A, B

2. General Training i

a. Experiments, Experimental Facilities, & Limitations Tech Spec 1.6, 1.7.

.b. Training Program 1.8. 1.17, 1.23, .

3 6. 4.6, 6.4  !

3 Specifio Training

a. In-pool Irradiations SOP IV-G, EA-1, 15 .

b. MHA Procedures  ;

c. Pneumatic System SOP IV-C EA-2

4. Specific Training

a. Bcam Port Operation SOP IV-D, EA-3, 6, 17

b. Neutron Radiography SOP IV-F, CA-3, 6, 17 5 Specific Training i

a. Irradiation Cell SOP IV-E, EA-4 <

b. Thermal Column SOP IV-H, EA-7, 19  :

6. Specific Training

a. . Other Facilities and Procedures EA-20, 21, Memos. .

[

, Guidelines, and i Staff Meeting ,

Minutes l t

7. Documentation and Radiation Health Training I

a. Reactor Operations SOP II-D, 2, 5, 6

8. Documentation and Radiation Health Trainin6

a. Radioactive Materials I (1) Released Off Campus SOP VII-C, 2 (2) Released On Campus SOP VII-C. 3 (3) Retained at NSC SOP VII-C, 4 '

(4) Handling SOP VII-C. 10  ;

9 Don mentation and Radiation Health Training

a. Exposures. Contamination, and Releases 10CFR19, 10CFR20.

(

i

b. ALARA and applicable Reg C. High Rad / Rad Area Guides l

Other references in addition to the above references include Technical Reports. (

Experiment Log, Staff Meeting Minutes, and Memos. l l

29

. .r ._ -

. . . . . . . . _ . _ . . . c_ , . _ _ _

i e' t. j Experimenter Training

\' ,

l t

Lecture Reference f

1. ' General Training f

a. Indoctrination Emergency Plan,  !

.(to include all topics listed in ANSI 15 11) 10CFR19, 10CFR20, l and applicable Reg  !

b. Experiment Approval Guides.

SOP IV-A, IV-B, and '

VII-C. 2. 3, 4, 10 i

2. Specific Training t

a. Experiments, Facilities, & Limitations Tech Spec 1.6. 1.7.

1.8. 1.17, 1.23,  !

3 6, 4.6, 6.4 as applicable:

(1) In pool SOP IV-0. EA-1, 15 (2) Pneumatic -SOP IV-C, EA-2 (3) Beam Port SOP IV-D, EA-3, 6 17 (4) Neutron Radiography SOP IV-F. EA-3, 6 17 (5) Irradiation cell SOP IV-E, EA-4 (6) Thermal Column SOP IV-H. EA-7, 19 (7) Other Facilities EA-20, 21 Other references in addition to the above references include Technical Reports.

Experiment Log, Staff Meeting Minutes, and Memos.

30

o_ .- . ~ . ..._

NSC form 515a 6-88 \

NSC Experiment Facilities and Procedures Training Program For Operations Technical Services, Health Physics Personnel Training Documentation Topic Instructor Date FLAME SIC!JATURE SCORES ORAL UPGRADE

'A score below 80% will require additional training.

31

O ,

NSC Porm 515b 6/88 NSC Experiment and Pro \

cedures Training Program For Operations. Technical Services. Health Physics Personnel Biennial Experiment Training Summary From: To:

Training Program Review Due:

Lecture Date Completed 1.

2.

3 4

5 6.

7.

8.

9 NSC Personnel who have sucessfully completed biennial experiaent training:

1. 10.

2. 11.

~

3 ,

12.

4 13 _

5 14

6. _

15

7. 16.

8. 17.

9 18.

Training Frogram Peview Ccmpleted:

NSC Management:

32

NSC Form 515c 5/88 NSC Experiments and Pro \

cedures Tesining Program For Experimenters e Training and Certification has successfully completed the Experiment?r Training Lecture Series cons'. sting of the following:

_ Topic Instructor Score Date (1) General Training (2) Specific Training (a) ,

(b) _

(c)

(3) Retraining (a)

(b) _

(c)

, I understand that I am expected to act responsibly in executing the activities for which I have been trained. I will not attempt to undertake activities for which I have not been trained.

Experimenter Date Certification is based on the experimenter's completion of the training listed above and that NSC staff is reasonably confident that the experi-menter has understood the information imparted in training. Certification may be revoked by any member of NSC Management or the Reactor Supervisor.

Reactor Supervisor Date 4

Healtn Physicist Date NSC Management Date Thic certification expires two years after Date 33

. _ . . _ , - _ .~

'NSC Fora 515d  !

5-88 (

NSC Experiments and Pr cedure Training Program. 3 l Training and Performance Evaluation Person-Evaluated: Date:

Description of Tasks or Experimental Procedures Evaluated: (Attach additional cages, sketches, surveys and/or references, if necessary)

Evaluation Performed By:

Evaluations should be thorough and sufficiently documented to enable reviewers at any later cate to ascertain the extent of the individual's understanding of the tasks to be performed, the experimental configuration and the working conditions present at that time.

1. Knowledge of Procedures and Equipment

4. Does individual know or have clear understanding of objectives?

b. Aware of written procedures, if available?

c. Exhibit ability to properly cperate equipment or perform tasks?

2. Knowledge af Radiatien Hazards i a. Does the individual understand the radiological conditions or range of conditions to be encountered?

l l (1) Uniform or non-uniform fields?

(2) Mixed-radiation fields present?

(3) Potential or existing contamination areas?

l j (4) Potential or existing airborne hazards?

I 34

.. . . . a. --. -.. .- ...

'Fcrb515d P go 2 (5) Location and magnitude of e\ch of above?

b. Does individual understand ALARA concepts as applied to this project?

c. Does individual have proper dosimetry and know where and how it is to be worn?

d. Can individual demonstrate or describe proper use of HP or NSC instru-mentation which is applicable and available? ( Ex: frisker, hand and foot monitors, area monitors, etc.)

3 Knowledge of Access Restrictions

a. Does individual understand requirements imposed upon initiation of work?

b. On termination of work? .

c. Key control?

d. Access restrictions and responsibilities, if any, for restricting access of others?

4. Emergency Response

a. Does individual understand emergency plan as applicable to him or her?

b. Proper response to encountering unexpected radiation hasards?

, c. Notification of NSC personnel?

d. Safe shutdown of experiment or tasks?

Approval:

NSC Management Senior Health Physicist as

.o . . . . _ ._. ...... .

y NSC form 521 6/85

\

}

REQUALIFICATION/ TRAINING LECTURE TOP lc _

INSTRUCTOR NAME DATE ,__

i Ni l

l 1

36

?

APPENDlX D Review of Radiation Controls Conducted by Office of Radiological Safety 37

- e

'o '.

TEXAS A&M UNIVERSITY COtttCE STATION, TEM 5 7784 M M1 OBkr of RAmol,OGICAL, SAFITY (409)845 1361 May 25, 1988 MEM0RANDUM TO: Dr. John Poston Radiation Safety Board Subcommittee FROM:

Health Physics Staffg77}

l THRU ' Mil ton E. i4cLai Radiological ,

ice

SUBJECT:

HIGH RADIATION AREA CONTROL AT THE NUCLEAR SCIENCE CENTER In response to the NRC's request that the Radiological Safety Office review hi 6h radiation area control procedures / practices f or com pliance with 10CFR20.203(c)(2), the following recommenda-tions are presented:

I.

CONTROL OF RADIATION AREAS AND HIGH RADIATION AREAS ON THE NUCLEAR SCIENCE CENTER LOWER RESEARCH LEVEL (LRL)

A. Access - each door which provides access to the LRL (stairwell door to LRL, stairwell door to the mez-zanine, downramp doors) should be equipped with an electronically actuated lock energized from the control Room. Intercoms should be located at each of these doors for personnel to identify themselves to the Con-trol Room prior to gaining entry. "Ope n doo r" swit che s should energize audible and visual alarms (panalarm) in the Control Room. All LRL access doors should open from the inside under any conditions to allow emergency egress. Special pass keys should be issued to key NSC personnel, as identified by the Director, for access during emergencies, power outages, and certain after-hours access requirements.

B. Posting of Radiation Aress - each door providing access to the LRL should be posted with a "Radiation Area" sign to alert personnel that radiation areas may exist at any or all LRL locations beyond the access point.

38

Page 2 - Poston C. Posting of High Radiation Areas - experimental facilities setups on the LRL that create high radiation areas must be further defined.

(1) Access to high radiation areas shall be restricted through use of portable framed cyclone fence or other equally restrictive barriers.

(2) The barrier shall be connected such that panels cannot be separated to gain unannounced access.

(3) On each entry to the high radiation area, a "gate open" sensor should be installed which energizes an alarm in the Control Room.

(4) The gate or door should be equipped with a lock and should remain locked when not under constant surveillance by trained NSC personnel, NSC HP personnel, or experimenters. Keys to these locks should be kept only in the Control Room and issued only by the SRO.

(5) Audible and/or visual alarms per 10 CFR 20.203 ( c)( 2 )

installed which automatically actuate upon person-nel entry into the high radiation area. However, where water-shutters or other dose rate reducing devices are installed, C-2 devices should be auto-matica11y actuated when high radiation levels exist (i.e. when the device is not reducing the dose rate to below high radiation area levels) rather than by gate position.

II. CONTROL OF HIGH RADIATION AREAS ACCESSIBLE FROM THE UPPER RESEARCH LEVEL (URL) AND OTHER AREAS A. Location and Frequency - High radiation areas only exist on the URL of the NSC during reactor cell opera-tions and routinely eatst in the lower portion of the irradiation cell (which must be accessed from the URL) as a result of activation of irradiation cell materials (especially cell window components). Radioactive material handling in the Materials Handling Area (MHA) of the URL rarely if ever constitutes a high radiation area. Although dose rate far in ext?ss of 100 mR/hr are routinely detected, handling procedures and equip-ment are suf ficient to limit doses in any one hour to '

less than 100 millirem. Furthermore NSC procedures require that both NSC and NSC HP personnel be present during sample handling o p e r .s t i o n s thereby ensuring direct surveillance pe- T C R F 2 0.2 0 3( c )( 4 ).

B. Posting of High Radi Areas During Cell Operations

. - It could be argue / xemption from the requirements of 10 <.' 23(c)(2) (per 10 C F R 2 0.2 0 3( c )( 4) e invoked since the Control Room must be occap. ei the r the RO or the SRO during reactor opera .on. However, the many other duties of the RO and /cr the SRO may make direct sur-veillance of the aren difficult sr impossible in some situations. Therefore. the following changes are recommended 39

Page 3 - Poston (1) The C-2 device now located on the reactor bridge should be removed or disabled as well as the microswitches on the URL and Control Room doors.

(2) The two entrances to the irradiation cell deck i should be equipped with lockable gates to be placed into service during reactor operations against the irradiation cell.

(3) An audible er visual alarm (to alert both the individual entering the area and Cont rol Room personnel) should be actuated upon opening either gate.

(4) The alarm system should be enabled and disabled l from the Control Room as part of the procedural

, controls associated with reactor operations against the cell.

C. Posting of High Radiation Areas in the Lower Portion of the Irradiation Cell - The size and location of the l high radiation area in the lower portie n of the irradiation cell is constantly varying with time, reactor location and reactor operating history. In light of these variables and the small size of the celi, recommendations for establishi'ng high radiation area controls are as follows:

(1) An audible or visible alarm should be installed in

the lower portion of the cell.

(2) The alarm should be actuated when the rollaway door is opened.

(3) The Cottrol Room should receive an alarm or indication that the door is open (this feature alre ad y exist s).

(4) Procedures and interlocks a'. ready exist which are acceptable for restricting access to the lower portion of the irradiation cell.

D. Posting of High Radiation Areas in the Bone Yard - The gate to the bone yard is already equipped with a lock, microswitch, C-2 device (flashing red light), signs, and Control Room annunciators. High radiation area controls for the NSC bone yard are considered accept-able as currently designed and equipped.

III. PROCEDURAL REQUIREMENTS FOR CONTROL OF RADIATION AND HIGH RADIATION AREA $

A. In the future, activities and experiments at the NSC will result in the generstion of new radiation areas and high radiation areas. At present, no procedures or guidelines exist which adequately address posting re-quirements and responsibilities. Several procedures in SOP Section IV, Procedure for Use of Experimental Facilities, have isolated statements included which are intended to key NSC personnel and NSC HP personnel to 40

• a k' '.

Page 4 - Poston consider special controls on particular types of experiments. Development of new procedures would cen-tralise these requirements and facilitate training of NSC and NSC HP personnel. At a minia'in the se pro-cedures should address (1) 10CFR20.203 requirements for posting of radiation areas and high radiatfon areast (2) acceptable versus unacceptable posting methods for high radiation areas under the options presented in 10 C F R 2 0. 203( C)

(3) special high radiation area limitations applicable to specific experiments such as besa stops. bean enclosures, barrier restrictions, continuous HP coverage ete and (4) establishment of a routine review of posted r.reas within the NSC to be conducted by non-NSC prir-sonnell B. A review of indoctrination training at the NSC should be perf otaed by the NSC staf f to ensure that all NSC nerronnel and experimenters are properly instructed to 4?ect radiation areas and high radiation areas warn-

4. <igns and alaras.

C. Nu ..a n s g e n e n t Shall Review each (1) "Routine" classified experiment or operation as to its operation in a radiation or high radiattor.

field and determine in conjunction with the HP the followinst (a) control of access (b) special training on procedures (c) area control procedures (2) "Non-Routine" classified experiments and operation shall have prepared in detail those requirements of III C a,b c f or submission to the RSS for review.

A audit trail shall be maintained by the NSC management that all personnel involved in work as defined in III C (1) and (2) shall certify their receipt of special training and procedures by signed acknowledgement statements which shall be placed on file.

41

APPENDIX E Proposed New Procedure for Experiment Review and Approval i

4;

- - - ._-.-~ _ i- <-. ..

NSC Form 112 Nuc1 car Science Conter STANDARD OPERATING PROCEDURES 1-73 Prepared by Subject Section Page DCD EXPERIMENT REVIEW AND APPROVAL IV-A 1

1. General gggg{

These procedures apply to the review and approval or e. iments utilizing NSCR facilities and services. The procedures apply to all experiments associated with the operation of the reactor and use of experimental facilities. No new experiment (see 2.b) shall be implemented until:

a. A hazards analysis has been pe'rformed and reviewed for compliance with the limitations on experimer.ts (Technical Specification 3.6) by the Reactor Safety Board.

b. An experiment review has been completed by the NSC staff and received management approval. Minor modifications to a reviewed and approved experiment may be made at the discretion of the SRO upon determination and documentation that the changes do not constitute a significantly new or different safety risk than the original approved experiment (Technical Specification 4.6(a)).

c. The reactivity worth of an experiment has been measured. Prior to the first use of an experiment for which there is no previous reactivity worth re-corded for the current operational core and position, the worth will be measured. An estimate of the worth is acceptable prior to the first use in lieu of the reactivity measurement provided that the worth has been measured in a similar core position at equal or higher neutron flux and was less than

$0.10 in that position.

2. Review and Approval of New. Routine and Modified Routine Experiments The approval procedure applied to each experiment or class of experiments will depend on whether the request for performance of the experiment is evaluated as a

~

new, routine, or modified routine experiment. Any experiment submitted for approval will be reviewed as outlined in the flow chart shown in Figure IV-A-1.

a. Experiment Request The initiation of the review and approval of all experiments is the sub-mittal by the experimenter of the NSC Form 511 (Experimer.t Request, Figure IV-A-2) to the Experiment Coordinator. The Experiment Cocrdinator verifies the completeness of the requested informacion and passes the NSC Form 511 to Management for evaluation. The information provided by the experimenter on NSC Form 511 is evaluated by NSC management to determine if the experiment requires initial RSB approval in the form of an approved EA or if the experiment is to be reviewed and approved under an existing EA by NSC Staff Meeting.

b. New Experiment A new experiment is any activity utilizing the NSCR or NSC experimental facilities that does not conform to an existing EA or has not been i

Approved:

Director, NSC Chairman, RSB Date 43 l

( Experimenter )

l l

l l

i r i form Experiment 511 Request I

( RSB )

n Experiment EA New Authorization -

Experiment l 1r 1r I

( Exp Coordinator )  :( NSC Management)  :

Form NSC Staff Meeting n Experiment 51 Reviev &

Modified ...................

Routine i Route Approval Experiment i determined ,

t by EA i (Reactor Supervisor)+-(RSB Subcommittee)

,r

( Exp Coordinator )

Approved Non-routine Experiment ,,

( Experimenter )

l

"- Routine Request Experiment Form for 514 4 ( Experimenter )

l Ir: ;diation l

l 7  ?[Sampie f f Sampie l s SR0/HP Approval,3 Prep Irrad i

1 Figure IV-A-1 Review and Approval of Experiments l

44

... .NSC Date Fara 511

~

ER #

5-88 Experiment Request Nuclear Science Center Tex s A&M University College Station, Texas 77843 Organization Project Title Principle Experimenter Title Tel. No.

Additional personnel who will be using the NSC:

Name Title Type of Activity:

Academic Teaching Organized Research Academic Research Sponsored Research Ph.D. __ M.S. . Commercial Other Undergraduate

. Experimental Facilities to be used if known (Pn, Rotisserie, Analyzer, Etc.)

Isotope License Number (Required if radioactive material to be removed from NSC.

Submit copy of license if not on file at NSC).

Complete the following for classroom or training activities:

Instructor Title Name of Course Level of Course No. of Students Date of Activity i

\

i Figure IV-A-2(a) i 45

\

Description of activities. (Attach additional sheets as necessary to fully s describe project). Include (where applicable) nature of experiment, experimental apparatus to be used, sketches of experiment, flux levels, irradiation time, identification and weights of all elements, chemical composition of samples, calculation of expected radioactivity for each element, etc.

I Signature of Experimenter NSC Use Experiment Coordinator .

Sr. Health Physicist Management i

Figure IV-A-2(b) 46

• e 9 y3 - + --, g-- 9-+-

-- ee - - --:n-, q y -e,----w e -m - - - - - - - - *e- - --=w

NSC Form 112 Nucitar Science Centor STANDARD OPERATING PROCEDURES 1-73 Prepared by Subject Section Page I 1

DCD EXPERIMENT REVIEW AND APPROVAL IV-A 2 previously performed. Approval of a new experiment is initiated by sub-mission of a completed NSC Form 511 by the experimenter to the NSC Experi-ment Coordinator. The NSC Form 511 is then submitted to NSC management for evaluation. Any new axperiment that constitutes an unreviewed safety question requires approval by the USNRC; other new experiments for which no EA is in place must be presented to the RSB for approval. A significantly modified routine experlment, where desired or planned changes and modifica-tions result in the experiment not conforming to an existing EA, requires RSB approval as a new EA or an amendment te an existing EA. Prior to the initial conduct of an experiment under an approved EA or EA amendment, a NSC Staff Meeting review will be conducted following the requirements of NSC Form 512 (Experiment Review and Approval, Figure IV-A-3). Final approval by RSB Subcommittee may be required as a stated restriction in the EA. If so, the completed NSC Form 512 and Staff Meeting Minutes of the experiment review will be provided the RSB Subcommittee for final approval. The approved experiment (NSC Form 512) is passed to the Reactor Supervisor and then to the Experiment Coordinator for scheduling of the experiment. The experimenter then submits a NSC Form 514 (Request for Irradiation, Figure IV-A 4) and the experiment receives its final approval by signature of the Senior Reactor Operator and Health Physicist.

c. Modified Routine Experiment A modified routine experiment is one where desired or planned changes or modifications to the experiment could result in a safety hazard which is greater than that of the routine experiment, but still conforms to an existing EA. Review and approval is accomplished through a safety review and completion of Forms 511 and 512, with RSB subcommittee approval if necessary. If review concludes that the experiment is not covered under

, an existing EA, then a new EA or Ek amendment will be presented to the RSB for approval prior to completing the staff review and Form 512.

d. Routine Experiment A routine experiment is one which conforms to an existing EA, has been reviewed by NSC Staff Meeting and has a completed NSC Form 512. Experi-menters requesting performance of routine experiments obtain subsequent approvals by signature of the SRO and HP on the NSC Form 514. Modifica-tions to routine experiments that do not present an additional safety hazard and conform to an EA and an approved NSC Form 512 may be approvea by the Reactor Supet .isor or Management. If a modified routine experiment presents an increased safety hazard or does not conform to an EA, the modification is presented to NSC management for evaluation.

N Approved:

Director, NSC C hai rman , "" Date i

i 47 l

, ,NSC ERA # 1

'F ra 512  !

5-88 Experiment Review and Approval )

i Texas A&M University Nuclear Science Center Experiment Review Experimenter Project Title Complete all.of the following: (Attach additional pages if necessary).

. Description of Experiment: (Attach Form 511) ER#

(1) Describe, if applicable, any new irradiation devices or facilities required for this experiment. Include sketches of the apparatus that will be used.

(2) Describe any special handling or operating procedures required to perform this experiment as pertaining to both personnel and the reactor.

(3) Do these procedures keep personnel exposures as low as' reasonably achievable?

(Yes/No)

Irradiated Materials

~

Location:

In-Pool Pneumatic System Dry Tube Irradiation Cell-Beam Port Other Describo (1) Describe the type of sample to be irradiated: (Describe encapsulation, radioactivity produced, sample material, etc.)

\

Figure IV-A-b(a) 48

\

l (2) Evaluate accidental releases of radioactivity as per Tech Spec. 3.6.3 Can this sample offgas, sublime, volatilize, or produce aerosols under normal conditions or possible emergency conditions? If yes, describe any possible hazard produced ty a release of this material to the environment:

(Include both radiation hazards as well as corrosive hazards. The hazard produced by any release of radioactive materials must be less than that defined in 10CFR20 Appendix B. Attach calculations as necessary.

This experiment has been reviewed against the following:

SOP's Old Staff Reviews Experiment Log NSCO Memos Training Requirements The experiment has also been reviewed against the following Technical Specifications: T.S. 3.6.1(a), T.S. 3 6.1(b) and T.S. 3.6.2(b).

Secured Experiment (<$2.00)

Non-secured Experiment (<$1.00)

Fueled Experiment (Iodine Inventory <10 Ci)

Explosive Material (<25 mg per irradiation for in-pool and 5 lbs. maximum for N-RAD) T.S. 3 6.2(a)

Maximum Reactivity Worth:

Minimum Shutdown Margin:

Maximum Activity Produced per Sample:

Experiment Approval Experiment requires a new Experiment Authorization (EA) (Yes/No)

Experiment conforms to the Conditions, Limitations and Restrictions section of Experiment Authorization Number Management Approval Sr. Health Physicist Staff Members Present:

i

( Does this approval require additional RSB review as specified in the EA?

l (Yes/No)

If yes, RSB approval:

RSB Member l

N Figure IV- A-3(b) 49 1.

NSC FORM 514

' '4- ~'

14C} ear 3Clerice @ter nsA.AA _ e .,,..

cou.a.: erAvio*,1sxA. vve4s wn ,

i MC MWG #

REQUEST FOR IRRADIATION [ ]

I EXPEtiMENTER CEPT OR COMPAN LICENSE NO PURCHASE ORDE8 LOCAflON IN CORE IRRADIATION DEVICE DATE Of litADIAflON 'tRADIAflON flME

$ECONDARY ENCAPSULATION: PflM A RY IN5f RVCTIONS FOR RELE ASE SAMPLE NO.

COMPOSITION .

SAMPLE MA55 150f0PFt51 ACTIVif Y' NO. OF SAMPtES latADIATED h as Cod Calcd AlPower IRRADIATION INFORMATION l H P. APPROVAt 520 APPtOVAL EXP AUTH #

flME toe ' AGE 80WER LEVE!

DATE IN flME tor ' AGE 4t! letAD DATE OU' COMMENf 5.

MATERIAL RELEASE SURVEY l MR / HR, PRINCIPAL RADI AflCN MAXIMUM RADIATION AT SAMPLE SURFACf CONTAMINATION OF SHIPPING CONTAINER l

NSC SHIELD # LOCK #

TYPE OF 5 HIPPING CCNTAINER M t / HR. @ 3 FEET Mt/NR MAX RADI ATION At SURFACE OF CONTAINER VEHICLE PLACARDED MATERIAL RELEASED TO TIME SuavEYO4 DATE RELEASED LOADEO BY, \ UNLOADED BYi l

COMMENTS:

Ficure IV-A-4 50

I NSC Formt 112 Nuclear Science Centor STANDARD OPERATING PROCEDURES 1-73 Prepared by Subject Section Page DCD EXPERIMENT REVIEW AND APPROVAL IV-A 3 3 Docuner,tation This section describes the forms required for documentation of experiment review and approval.

a. Experiment Request (NSC Form 511)

This form must be submitted for any new experiment. This form provides a description of the experiment or services requested and documents the individuals involved in the experiment. Once completed, this form is f submitted to NSC management for staff review.

I

b. Experiment Review and Approval (NSC Form 512)

This form provides a standard format for a staff review of an experiment l and final approval by RSB Subcommittee when' required. To complete this review, an official NSC Staff Meeting is scheduled and each section of the form is completed. This form provides a check against requirements of the Technical Specifications EA's, SOP's, and training as well as a l check against other applicable NSC documents. Completion of this form gives approval to NSC operations to perform the experiment described in the NSC Form 511.

c. Request for Irradiation (NSC Form 514)

The request for performance of irradiations or services of an approved experiment require NSC. Form 514 submittal and approval. This form which will be submitted with each service or irradiation describes the isotopes to be produced, the activity expected, and information regarding handling of radioactive materials. Information concerning the method of sample pre-paration, details of the irradiation record, and sample disposition are completed by the Operations and Health Physics Staff. This form must be signed and approved by the Senior Reactor Operator and Health Physicist prior to irradiation.

For guidance of the individuals reviewing NSC Form 514, the sample, its encapsulation, the procedures for handling it, and the method of positioning it in the reactor should satisfy the following criteria to be approved for irradiation.

1. Encapsulation will ensure sample containment to prevent contamination of the reactor pool, handling areas, and any laboratories involved.

2. The induced sample activity can be safely handled using available equip-ment.

N 1

Approved:

Director, NSC Chairman, RSB Date 51 l _ _ _ _ _ _ _ _ _ _ _ _ _ _

NSC

' Form 112 Nuclcar Science ContGr STANDARD OPERATING PROCEDURES Prepared by Subj ect SectionI Page DCD EXPERIMENT REVIEW AND APPROVAL IV-A 4 3 If a dimensional change of the sample is expected, adequate expansion space will be left in the irradiation capsule.

4. The expected reactivity change due to insertion and removal are within acceptable limits (see SOP II-D-6).

5 Significant reactivity variations due to sample movement (sway, bobbing, or rotation) will be prevented.

6. Expected activity should reflect either total activity of all samples or a per-batch amount from which total activity can be calculated. The activity should be categorized according to the major contributing isotopes. Activity level should be the level at the end of irradiation (i.e., decay time equals zero) unless the release time is known. When the time of release is known and the activity is calculated for such time, the time should be noted (e.g., 500 mci total @ 1200, 10-10-88).

7 Review and approval documentation is on file in the control room for the experiment.

4. Training Requirements for Conduct of Experiments Documented general and specific training and retraining of NSC experimenters, staff and HP personnel is required prior to the performance of approved experiments and shall be conducted in-accordance with an approved training program, "Experiment Facilities and Procedures Training Program", maintained by NSC management. The training program and records shall be located in the Reactor Control Room. Training requirements are to be completed prior to approval of NSC Form 512.

i l

l

\

I Approved:

Director, NSC Chairman, RSB Date-OA

l l

l f

l 1

i APPENDIX B h

1 l

l r

J l

f l

l l

l

[ _. - . _ . --

NSC Health Physics Section Page Fars 112A Nuclear Science Center STANDARD (PERATING PROCEDURES VII-C 11

~'

Prepared by Subject Procedure Rev.

ELJ, KCC RADI0 ACTIVE MATERIALS CONTROL VII-C8 1

8. Radioactive Liquid Waste System j

a. Introduction Radioactive liquid waste is generated on a daily basis at the Nuclear Science Center. This waste originates from laboratory sinks, decontami-nation showers, laundry room, floor drains, demineralizer system, pool skimmer pump drain, cooling equipment room valve pit sump, condensate from reactor building exhaust, and pool linear leakage. These sources of liquid waste are collected in the demineralizer room sump where it is pumped to the hold-up tanks for storage and analysis before release to the unrestricted environment,

b. Description The radioactive liquid waste system consists of three (3) ho dup tanks, (Figure VII-C-6) the demineralizer room sump with two (2) pumps, the cooiing equipment room valve pit sump with pump, and associated valves and piping.

The three (3) holdup tanks are located northwest of the reactor buildin6 Tank No. 2 has a capacity of 5,000 gallt us and Tanks No. 1 and "Auxiliary" have capacities of 12,000 gallons each. The status of these tanks is checked daily. Tank level gauges are provided at the base of each tank.

One (1) foot on the gauge represents 500 gallons for Tank No. 2. One (1) foot on the gauge corresponds to 1,000 gallons for "Auxiliary" and Tank No. 1. All tanks are equipped with raw water stirrer (Figure VII-C-7).

These stirrers are used to mix the contents of a tank prior to sampling for release. Each tank is equipped with a tank sampling line.

Under normal conditions. radioactive liquid waste is pumped to the holdup tanks by the demineralizer room sump pumps. The demineralizer and equipment room sump pumps are controlled by float switches through a switching relay.

c. Operating Procedure (1) Placing radioactive liquid waste system in service.

The radioactive liquid waste system is normally operated in an auto-matic condition. Water is collected in the demineralizer room sump and then is pumped to the holdup tanks for storage and subsequent release. When filling one tank the otbor two can be blocked off by input valves at the base of each tank. Upon occasion it may bc necessary to drain large volumes of water from the reactor pool for maintenance and/or modification cperations. In order to prevent the rapid depletion of the ion exchange bed by deionizing large volumes of raw water, water drained from the pool will be stored in the "auxiliary" tank for reuse. For this reason the "auxiliary" tank is not normally used for storage of radiaoctive liquid waste being held for disposal. The auxiliary tank may be equipped with a valved drain tap on the tank outlet for use as an emergency supply of water wh9$ the tank has been filled with comestic water.

Approved: .g {

Director, WSC' NM Chait)6an, RSB l.

C 7 /9/00 D'a t e

0>< < DOMESTIC WATER DISCH QUICK DISCONNECT CREEK

[]

i ,X, Dj WATER DISCHARGE S S S STlRRER VALVE VALVE OUTLE VALVE F U U D N AUXlLIARY TAN K N O.1 TA N K NO.2 TAP -l  ;

TAN K (OPTIONAL)

GAUGE INLET VALVE /

REMOTE . S ANPLING LEVEL VALVE INDICATOR hI

(

SUMP DR AINS ROO S P I- LOWER RESEARCH - FLOOR I

DRAINS , HOT CHANGE 8 CHEM LAB 2 - DEMINER ALIZER ROO M - >

FILTER S lON BED 3- MECHANICAL CHASC - CONDENSATE >

AIR HANDLING UNITS gf 4- VALVE PIT SUMP - WASTE [#

I S- UPPER RESEARCH LEVEL DR AIN O n 4/g FIGURE Vll-C-6 N(

RADIOACTIVE LIQUID WASTE DISPOSAL SYSTEM

e 9

)

APPENDIX C l

l l

t l

I i

l l

l t

--- - .~._ _-__ ____. _ . _ _ _ _ _ _ _ _ __ __ _ _ . . __ _

• NSC Nuclear Science Center Form 112 STANDARD OPERATING PROCEDURES Prepared by Subject Section Page KCC REACTOR POOL SURVEILLANCE III-0

4. Pool Dive Procedure

a. Introduction Tasks involving installation, maintenance, or repair below the reactor pool water level are typically accomplished using special tools and equipment witnout requiring entry into the water. However, some underwater tasks can best be accomplished by divers. These procedures provide guidelines for preparation, approval and performance of a dive operation.

b. Pre-Dive Requirements Preparation for a dive shall begin with a staff review. The staff shall formulate and approve primary and contingency plans (as necessary) for the specific task. Personnel assignments shall be made at this time to include the following minimum assignments:

(1) Project supervisor, (2) Lead diver,

( 3) Backup diver, and (4) Health physicist.

Also any special equipment necessary to accomplish the task shall be id ntified.

During formulation of the divers' tasks and identification of necessary equipment, reactor and personnel safety shall be considered. For work performed on beam tubes, plugs should be installed inside the tubes and port doors (as applicable) closed and latched as well as closing beam tube vents to the central exhaust system. Where latching doors to beam ports are not installed, the pool gate should be installed to isolate the work area in case of accidental loss of large quantities of pool water.

Also, care shall be taken to reduce radiation exposure to the divers.

The proximity of radiation sources to the work area shall be considered with the option to move the sources, move the work area or provide shielding.

The project supervisor shall be responsible for coordination of the project and acquisition of necessary equipment. He or his designee shall also serve as an observer during the dive. If only one diver is required to perform an underwater task, then the second diver should be underwater and in the vicinity of the first diver to lend any assistance needed but may remain outside the immediate work area to reduce his radiation exposure.

Prior to the dive, health physics shall perform a pool water analysis, a radiation survey of the work area, and a check of the divers' accumulated

/%

Approved: '

dj[ h C 7 Date

/f!//

ChaQA.an, RSEL

~

Director' W C

t. C Nuclear Science Conter 112 STANDARD OPERATING PROCEDURES Prepared by Subject Section Page KCC REACTOR POOL SURVEILLANCE III-0 dose. Using this information, the health physicist shall advise NSC management on the limitations which should be placed on the divers and the prudence of beginning the dive.

c. Approval and Training Requirements The dive shall not begin until management approval has been obtained and documented in the Reactor Operations Log. Final preparations for the dive will include training instruction by the project supervisor to all per-sonnel involved. The instruction shall include personnel assignments, approved procedures, and the results of the pool water analysis, radiation survey of the ark area, and the divers' accumulated dose. The reactor shall be shutdown and moved to a region which is remote to the divers' work area.

Placement of the appropriate dosimetry on the body of each diver will be determined by the health physicist and documented on NSC HP Form 30-b, "Special Personnel Dosimetry / Contamination Fecord" shown in Figure VII-C-12. The divers will then begin execution of the approved tasks.

d. Post-Dive Requirements Upon completion of the dive the divers shall exit the pool. The project health physicist shall conduct contamination surveys of the divers and equipment used in the pool. This information as well as the measured doses and exposure time shall be documented on NSC HP Form 30-a, "Special Radiation Survey or Activity" (Figure VII-C-11) and NSC HP Form 30-b.

l Approved: mM Ir ow 7/p[fs Di re c t or , ' t!E-C Chair (/an, RSS U Date