ML20196A484
| ML20196A484 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 11/23/1988 |
| From: | Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196A474 | List: |
| References | |
| 50-170-88-04, 50-170-88-4, NUDOCS 8812060019 | |
| Download: ML20196A484 (14) | |
See also: IR 05000170/1988004
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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l Docket / Report No. 50-170/88-04
License No, R-84
Licensee: Armed Forces R Miobiology Research Institute
Bethesda, Maryland 20014
Facility Narne: Armed Forces Radiobiology Research Institute
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Inspection at: Bethesda, Maryland
j Dates: .
October 26 - 28 and November 7, 1988
Inspectors: J. H. Williams, Project Engineer
J. Gadzala, Reactor Engineer
D. T. Wallace, Operations Engineer
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Reviewed by:
[r J( . W1111ams, oject Engineer
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Approved by: . gfg_ N _ // ,7f/
U. C. O nvi}14, C tef, '/ ' ' dfte
Reactor Pro M d'Section/2A,
Division of Reactor Projects
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Summary Inspection on October 26-28 and November 7, '988
Areas Inspected: Routine, unannounced inspection by three region-based
inspectors [Whours) of facility operations, organization, reviews and
audits, operator requalification training, surveillance activities and
allegation followup.
I Results: Four apparent violations were identified associated with; (1) failure
l to perform safety reviews (see Sections 3.3 and 6.2), (2) inadequacy of and
l failure to follow procedures (see Section 5), (3) failure to monitor effluent
I releases (see Section 3.4), and (4) failure to adhere to the requalification
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training program (see Section 7). Three unresolved items are discussed related
to (1) assignment of responsibilities in the absence of the Reactor Facility
Director (see Section 6.3), (2) the impact of omitting information on license
renewals (see Section 7), and (3) NRC review of the reactor console safety
evaluation (see Section 8). Weaknesses were noted in documenting operations in
enough detail to allow the reconstruction of events at a later date and
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timeliness of safety reviews. Operator professionalism was considered a
I strength as was the questioning attitude displayed by the Safety Comittee.
8812060019 estjeg ,
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gDR ADOCK 05000170 :
PNU
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OETAILS ,
1. Persons Contacted
Col G. W. Irving, III Director, AFRRI
- M. L. Moore Chairman, Radiation Sources Department
- Maj J. R. Felty Reactor Operations Supervisor
- Maj L. A. Alt Radiation Sources Program Manager
- SFC W. W. Reed Senior Reactor Operator
SFC P. Cartwright Senior Reactor Operator
- SFC G. F. Talkington Senior Reactor Operator
- T. J. O'Brien Radiation Protection Officer, SHD
A. Munno Senior Reactor Operator
W. Ting Senior Reactor Operator
- Lt Col A. A. Elliott, Jr. Air Force Observer
- CMSGT D. J. Bragg, Jr. Air Force Observer
Interviews and discussions were conducted with other members of
licensee staff as necessary to support inspection activity.
- Attended the exit interview on October 28, 1938,
2. Followup on Outstanding Items
2.1 (Closed) Emergency Training Program (84-01-04)
The licensee was to consider strengthening the Emergency Training
Program by implementing eight suggestions. Review of this item
revealed that the eight suggestions have been considered, and have
been incorporated into the Emergency Training Program.
2.2 (Closed) Review and Tracking of As-Built Orawings (86-01-02)
Operators were unable to locate up to date, as-built drawings of
I the facility. Review of this item revealed that drawings of the
l facility are available to the operators. Efforts have been made
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by the facility to acquire more recent drswings, however these
efforts have not yet resulted in a complete set of detailed and
current as-built drawings.
Although drawings are available to the operators, management is
expected to take the necessary steps to acquire detailed as-built
drawings. This effort is being tracked under Unresolved Item
87-01-02.
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2.3 (0 pen) Vp to Date As-Built Drawings (87-01-02)
As discussed in paragraph 2.2 above, detailed current as-built
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drawings are not available to operators. Although r.everal requests
have been made to the site unit assigned to provide such drawings,
these requests have not been answered with deliver / of the requested
drawings.
3. Operations Review (NRC Inspection Manual Module 40750)
3.1 Facility Tour
The inspectors examined the facility by having an operator walk
through the "Daily Operational Start-up Checklist." The operator
demonstrated a good knowledge of the facility. Areas were generally
clean and well maintained although some debris was observed from
l construction activities. The inspectors examined the preventive
l maintenance program by checking the work done on the air compressor.
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Licensee records indicated that PM was performed twice in 1937 and
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three times in 1938. Equipment appeared to be well maintained and
I clearly labeled. No leaks or abnorrnal operation were observed.
l Postings as required by 10 CFR 19 were observed. No deficiencies
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3.2 Reactor Operators
The inspectors observed several Reactor Operators during the
course of reactor startups and pulse operations. The operators
demonstrated proper control room decorum and formality. A
positive attitude was conveyed. Operator professionalism is
considered a strength.
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3.3 Logs and Records
The following records were reviewed to evaluate operations:
Reactor Operator Log (1936 present)
Malfunction Log (1985 - present)
Gas Stack Monitor Historical Log (1937 - present)
Reactor Console Strip Chart Record (March 1936)
Meter calibration records
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A general weakness was noted in recording adequatr; details for non-
routine events to allow reconstruction of the events. An example '
was the March 6, 1986 failure of the linear channel pen during a
reactor startup. When this event was discussed, the licensee stated
that during this startup, a digital voltmater was used in the neutron
monitoring circuit in lieu of the failed pen. The inspector found
that a safety evaluation had not been performed to analyze the use of
this digital voltmeter in the linear channel. This is an apparent
violation of 10 CFR 50.59 (88-04-01). The digital voltmeter, which
appears to be commonly used, was also found to be out of calibration
since August 30, 1988.
Additional examples of inadequate documentation include the various
Gas Stack Monitor failures described in sections 3.4 and 5, Operator
Log entries for installation of the various neutron detectors, and '
placing equipment required by Technical Specifications to be operating,
out of service (section 5).
3.4 Effluent Monitoring
During a review of the Gas Stack Monitor (GSM) Historical Log, the
inspector noted that there was no hourly report printout from the GSM
for August 1, 1988, to document effluent samples for that day's
operations. The morning checklist which directs checking the GSM was
completed at 6:36 a.m., but the morning 1 minute printout from the
GSM is dated 01/01/061 at 02:02 which indicates a malfunction. The
Operator's Log showed that nine reactor operations occurred that day
during the period from 6:46 a.m. to 3:20 p.m.
Cognizant operators stated that upon completing operations, the GSM
electronics were found to have malfunctioned, neither measuring nor
storing effluent data. No log entry or other record was made to note
this. This is an apparent violation of Technical Specification 3.5.1
(b) which requires that gaseous effluents be sampled and measured
during reactor operations (SS-04-02). In addition Technical Specif t-
cation 1.21 (b) requires that any violation of a Limiting Condition
for Operation (LCO) be reported to the NRC and this was not done.
Section 5 contains additional information regarding this event.
Although environmental monitoring dosimeters had not yet been read
following this event, a backup system to the GSM was in operation
during this period. That system, the Reactor Deck Continuous Air
Monitor System, is also required by Technical Specifications and
would have provided a warning of any unusual effluent releases.
! 4. Surveillance Activities
The following surveillance requirements were selected from the Technical
Specifications for review:
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Description Frequency
Control rod worth (4.1) Annual
Control rod visual inspection (4.1) Annual
Clean / inspect pulse rod drive (4.1) Semiannual
Measure delta k/k at 100 kW and 1 MW (4.1) Annual
Measure control rod drop time (4.2.1) Semiannual
Power level channel calibration (4.2.2) Annual
Fuel temperature channel calibration (4.2.3) Annual
Shield door / plug / dolly interlock check (4.2.4) Annual
Fuel element inspection (4.2.5) Annual /500 pulses
Measure water conductivity (4.3) Weekly
Check ventilation damper mecharum (4.4) Monthly
Channel test radiation monitoring system (4.5) Quarterly
Calibrate radiation monitoring system (4.5) Annual
The inspector verified that the selected surveillance items had been
completed as required. The licensee uses a compact folder containing
index cards to document surveillance items and specify procedures to
be used. The file cards have clearly labeled tabs and are cross
referenced for ease of access.
No deficiencies were identified.
5. Procedures
The inspector reviewed Reactor Cperations Procedures I through VIII.
Deficiencies were identified in the adminstration of procedures and
sufficient instances of failure to follow procedures were found to
indicate an underlying sense of complacency towards procedural compliance.
Specific examples of the deficiencies include:
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GSM malfunctions on 7/26/88 and again on 8/1/88 were not recorded in
the Malfunction log as required by Procedure III.
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There was no record of the GSM hourly printout for 8/1/58 in the GSM
Historical Log as required by Tabs I and K of Reactor
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Operations procedure VI!!.
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Procedure I, Conduct of Experiments, requires completion of a
Reactor Use Recuest (RUR) prior to irradiation of materials.
l Af ter review of the reactor log, a Memorandum for the Record dated
6/21/88 and interviews it was concluded that an experiment was
conducted on 10/9/85 without completion of an RUR.
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The GSM pump was turned off on 6/3/87 due to apparent malfunction
(smell of smoke) without being recorded in the Malfunction Log
(Procedure III).
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L a rator's Log #78 (3/10/87 - 6/17/87) and the Activated Materials Log
were not reviewed by the Reactor Facility Director as required by TAB
A of procedure VIII and TAB A of procedure I respectively.
Interviews with the staff revealed that equipment required during reactor
operations is occasionally taken out of service without any formal method
to alert the operator of this fact. An example occurred when the Gas
Stack Monitor pump was turned off on June 3, 1987, between a series of
reactor operations. This practice has the effect of invalidating the
startup checklist which is performed to ensure that required equipment is
in service prior to reactor operations. It illustrates an inadequacy in
procedural control that increases the potential for reactor operation
outside the bounds required in the Technical Specifications.
This inadequacy in procedural control and the previous examples of
procedural non compliance have been classed as a single apparent violation
of Technical Specification 6.3 which eequires the licensee to have (and
comply with) written procedures adequate for safe operation (88-04-03).
Issuance, approval, and operator notification of procedures appears weak.
A specific example is the Pulse Operation procedure using the Cerenkov
detector. The procedure was not issued until a month after the April 1933
installation of the detector. Operator review of the procedure is dated
October 1933, and the preimplementation Reactor and Radiation Facility
Safety Committee (RRFSC) review is still pendinn.
During a tour of the facility on October 26, 1988 tne inspector noted
that the procedure for gas stack monitor operations posted at the monitor
had no information on it to identify the revision number, date, or any
other markings to ascertain it was the current procedure. This concern
was discussed with the licensee and actions were taken to correct the
problem.
6. Organization and Administration
6.1 Reactor and Radiation Facility Safety Committee (RRFSC)
The composition, qualifications, functions and authority of the RRFSC
are defined in section 6.2 of the Technical Specifications. The
inspector reviewed the minutes for meetings conducted in 1986 thrcugh
1988 as well as annual audit re orts for this period. In all cases
the requirements associated with quorum and frequency were net. The
RRFSC meeting minutes documented the review of audit reports,
procedure changes, and safety reviews. The supporting documentation
of the RRFSC meeting was noted to have improved in 1983.
No deficiencies were identified,
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6.2 Safety Reviews
Based upon discussions with licensee personnel it was determined
that when the new reactor console was installed in a monitoring
only mode of operation in early April, 1988, the licensee ;
exchanged the pulse ion chamber in Safety Channel Number 2 with a '
Cerenkov detector. This review by the inspector was prompted by
an allegation indicating a failure to perform a safety evaluation
prior to use of the Cerenkov detector.
The inspector examined current and early versions of the Safety
Analysis Report (SAR), the 10 CFR 50.59 evaluation for the new
reactor console, and other reports provided by the licensee to
determine if use of a Cerenkov detector was described or evaluated
from a safety standpoint. One early version of the SAR indicated the ,
Cerenkov detector would be evaluated during initial startup. No
information was available on these startup tests. The licensee ,
had a drawing showing the Cerenkov detector in the nuclear
instrumentation system but this was not part of the SAR, nor was
there any information provided to indicate that a safety +
evaluation was made. .
The licensee stated they had used the Cerenkov detector in the
past and believed it to be described in the SAR. However, the
50.59 evaluation dated May 11, 1988, for the new reactor console
ftates with respect to SAR changes; "the phrase 'three ion
chambers' has been changed to 'two ion chambers and a pulse
detector' to allow a Cerenkov detector or an ion chamber to be
used for pulse operation." It was also noted that the SAR
described a scram input from the pulse ion chamber which was not
described in the Technical Specifications and had been eliminated
from use apparently without a safety evaluation. The elimination of
the pulse ion chamber scram input is another example of an apparent
violation of 10 CFR 50.59 (88-04-01).
The capability and adequacy of the Cerenkov detector and the effects
of various parameters on its performance could not be determined based
upon the information available to the inspector. No written safety
evaluations exist to document the suitability of the Cerenkov detector.
This is yet another example of an apparent violation of 10 CFR 50.59
which requires a written safety evaluation to provide the basis for a
determination that a change to the facility does not involve an
unreviewed safety question (88-04-01).
Additionally, some other safety evaluatiors did not appear to be
performed in a timely manner. For example the safety evaluation for
the new reactor console was not submitted to the RRFSC until the
console was already in piece, and it did not address the additional
nuclear instruments prior to their installation. It is reco;ni:ed
that the console and additional instrumentation was not used to
cperate the reactor,
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6.3 Organizational Structure
l The inspectors reviewed the AFRRI organizational changes relating to
) the reactor facility and compared these changes to technical specif1-
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cation requirements. The creation of the Radiation Sources Department
headed by the Psactor Facility Director (RFD) enabled the Department
Chairman to be responsible for both the administrative and technical
aspects of reactor operations The Reactor Division is within the
Radiation Sources Department.
The inspector noted that the organizational changes were approved by
the RRFSC on August 14, 1987 and after further changes, again on
December 18, 1987. Minutes of the December 18, 1987 RRFSC meeting
indicate that the Reactor Operations Supervisor (ROS) and Reactor
, Division Chief should be two separate positions and that changes
- in the organization should be made in the SAR and technical
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specifications The annual report for 1987 discusses these changes,
The annual report states thit a dual chain now exists under the
Department Head, with the P'JS reporting to the Department Head /RF0 on
matters that pertain to reactor operations, and the Reactor Division
Chief reporting to the Department Head /RF0 on administrative matters,
Technical Specification 6.1.1 states that organizational changes
can be made as long as the RF0 has direct responsibility to the
Director of AFRRI for operation, safety and emergency control.
There is no Technical Specification requirement that the Reactor
Division Chief and the ROS be two separate positions, although
the RRFSC recommended this arrangement.
As a result of an allegation that the designation of the Acting RF0
was not in accordance with technical specification requirements, the
inspector examined licensee practice in this area. Techacal
Specification 6,1,2 states that the RF0 shall be respo...ible for
administration and operation of the Reactor Facility and for
determination of applicability of procedures, experiment
authorization, and maintenance operations. During the absence of the
RFD, the ROS shall have these responsibilities.
Documentation in certain memoranda, organizational charts, the
Safety Analysis Report and Annual Reports indicate a definite
awareness of the requirements in technical specification 6,1,2.
However, discussions and memoranda indicate that in many cases during
the absence of the RFD, his responsibility was assigned to the senior
person in the departeent or division. This iteru is considered
unresolved pending licensee clarification of the responsibilities of
the ROS in the absence of the RF0 (88-04-05).
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6.4 Reporting
The inspector discussed with the licensee an internal memo describing
an event of March 23, 1988 should be reported and addressed to NRC as
required by the technical specifications. A copy of the memo was
provided to NRC.
It was noted that Annual Reports to the NRC for 1985, 1986 and 1987
all stated that liquid radioactive effluents released were estimated
on a quarterly basis to be less than 25*4 of the allowable amounts
t,nder 10 CFR 20. The inspectors asked to see the basis for the
estimate and was told that there are no liquid releases from the
AFRRI reactor facility and therefore no data.
Section 3.4 of this inspection report discusses a failure to report
an LCO violation.
7. Operator Training
A review of licensed operator training (r* qualification training) was
conducced in order to deterinine whether the facility has successfully
implemented its NRC approved requalification program.
Improvements to the requalification program are currently being implemented
by the Training Coordinator. These improvements are intended to strengthen
the requalification program by improving scheduling control, tracking of
attendance, and establishing "performance based training". Because these
measures have not been fully implemented, the effectiveness of the measures
cannot be verified. However, the measures are recognized as being positive
factors inter.ded to improve requalification program quality.
The inspector verified that all licensed operators have been administered
the annual written, oral and operating exams required by 10 CFR 55.59
(a)(2). Documentation of the annual oral and operating examinations
included only a signed statement that these examinations had been performed.
No clarifying information sue.h as examination coverage, strengths or
weaknesses was available for any operator. Such clarifying information is
needed to identify strengths and weaknesses that are an important source
of data that can be used to improve the requalification program. Although
adequate documentation of these examinations existed in the operator files,
the thoroughness of the operating and oral examination documentation is a
program weahness.
A review of lecture training revealed that between 1986 and 19SS,
approximately twenty-two of thirty-nine schedu'ed lectures were
cancelled by management and not rescheduled, resulting in a
substantial amount of the requalification lecture eaterial not beir.g
covered as required. Examples of training lectures that were
cancelled by management and not perfor.med at a later date include:
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- "Calibration Procedures,"
- "Plant Instrumentation and Control Systems," >
- "Plant Protection Systems and Physical Security,"
- "Preview of Annual Shutdown"
- "Reactor Facility Update,"
- "Nuclear Reactor Kinetics,"
- "Biological Effects of Radiation," and
- "Operating Procedures."
In addition, of those requalification lectures that were performed, attendance
by-the operators was poor, resulting in every licensed operator missing be-
tween two and seventeen of the lectures during the 1986-1988 cycle. No
makeup of the missed lecture material was performed as required by the
AFRRI Requalification Program. Members of management apparently condoned
laxity regarding the requalification training program since all licensed
operators, including management, missed a substantial amount of the training,
Apparently, other concerns outweighed management's commitment to the requali-
fication program, resulting in scheduled lectures frequently being cancelled.
Management stated that a review would be performed to determine those opera-
tors who are deficient in requalification training and that remedial training
would be performed. The improved scheduling method was a means through which
management stated that full compliance with the requirements could be achieved.
Failure to perform requalification training lectures and ensure proper
attendance is an apparent Violation of 10 CFR 55.59(c) (88-04-06).
In addition, the ur. completed requalification training was not noted on
the NRC Form 398's which were submitted during 1983 for five licensed
operators applying for license renewals. Facility management must
certify on the Personal Qualifications Statement (NRC Form 393) that the
licensed operator has met all the requirements of the requalification
program. The impact of these omissions on the license renewal
applications is an Unresolved Item (23-04-07).
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l 8. Modifications
Modifications to the AFRRI facility were reviewed by the inspector in or-
. der to determine if the Reactor and Radiation Facility Safety Committee
l (RRFSC) had reviewed each modification, and whether an adequate Safety
l Analysis had been conducted.
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Safety Evaluations for the following modifications were reviewed:
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' Control Room Windows * Radiation Area Monitor Readuuts
- Reactor Building Roof "Gas Stack Monitor
- 0verpressure Relief Valve ' Air Supply For Dampers
- Reactor Cooling Tower "Exposure Room Monitoring
"Primary Water Makeup System "Reactor Control Room Air
Conditioner
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Each of the above modifications was verified to have been approved by l
the RRFSC. A brief review of the Safety Evaluations indicated that !
indepth analyses had been conductea for each modification, i
A brief review was conducted on the new reactor control console. A l
Safety Evaluation for the console, datad May 11, 1938, describes the
instrumentation and control of the system as well as features expected to ,
improve the overall operability of the reactor. !
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The facility contracted ORI Inc. of Alexandria, Virginia, to conduct
an independent review of the new console Safety Evaluation. ORI
agreed that no unreviewed safety questions existed for the new panel.
Facility management stated that a plausible five dollar ramp accident
over a two second interval was evai led by General Atomics with the l
conclusion that this scenario is encorrpassed in the existing safety [
analysis for the facility.
The adequacy and the appropriateness of the 50.59 safety evaluation of l
the new reactor control console is unresolved pending an NRC review '
(88-04-04).
9. Allegation Followup (RI-83-A-0102) y
Background !
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The inspectors investigated several allegations regarding technical l
specification violations, including failure to follow procedures, and i
violations of regulations.
Allegation
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The Reactor Division Chief and Reactor Operations Supervisor are two I
positions being filled by the same person; The designation of Acting RFD
is not per Technt:41 Specification 6.1.2. (See section 6.3) ,
Allegation !
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The linear channel was not operable during reactor operation in violation !
of Technical Specification 3.2.1. (See sect w n 3.3) J
A11egai; ion
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The GSM was not operable on June 3,1937, during reactor operations when j
the pump was turned off in the morning. NRC inspectors then onsite were
told it was turned of f in the af ternoon af ter completion of reactor
operations due to the smell of smoke.
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Interviews with staff and operators indicated that the Reac ra ';' rations !
Supery'isor secured the noisy GSM pump at about 9:00 a.m. on s -.. , 1987, l
to facilitah a meeting on the reactor deck. He wrote himself a reminder l
in his personal notebook and turned the pump back on af ter the meeting l
(about 10:30 a.m.). A log review indicates that reactor operations were l
conducted from 7:33 - 7:57 a.m., then again from 10:43 a.m. - 1:21 p.m. l
The second period consisted of two 5 minute runs at 2 kW, followed by a (
twenty minute run at 960 kW which ended at 1:21 p.m. ;
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The GSM Historical Log indicates that the GSM was not properly i
sampling during the final run, since the count rate only increased !
f Nm 1.592+01 cpm at 1:00 p.m. to 2.228+01 cpm at 2:00 p.m. This small !
increase appears inconsistant with the high power run. The expected l
increase is more aptly shoin in a June 8, 1938 GSM Historical Log l
entry for a similar 100*4 power, 20 minute run f rom 11:01 to 11:2) a.m. l
The count rate increased more than ten times from 1.482+01 at 11:00 i
a.m. to 1.636+02 at 12:00 p.m.
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NRC inspecturs then ensite, state that they noted the secured pump on the
GSM at about 2:30 p.m. The Reactor Facility Director (RFD) told them it
was secured about half an hour earlier due to the smell of smoke. The putp ,
was subsequently restarted.
The RFD had difficulty recalling this event and it is not documented in
licensee records. An investigation to obtain the additional information
necessary to conclusively substantiate a violation of Technical Specifi-
cations is not warranted since t'se weaknesses associ ted with these events
are identified in section 5 and a response discussing corrective actions
is being requested from the licensee. Environmental dosimetry records
indicate normal effluent disebarges during this period.
Allegation
The GSM was not operable during reactor operations or. July 25 and August 1,
1988. The July 25 malfunction is not recorded in the Malfunction tog as
required by local procedures.
A review of logs and interviews with operators indicates that storm induced
electrical surges caused an intermittent memory loss, not a malfuction in
the GSM, prior to operations on July 25. The GSM did malfunction on July
26 and August 1, neither of which are recorded in the Malfunction Log.
This is discussed further in sectirn 5. Tbt: July 26 malfunction occurred
prior to 6:54 a.m. and not during reactor operations. The August 1 eal-
function is an apparent violation as discussed in section 3.4.
Allegation
Radiation exposure to desteetry personnel was higher than aserage.
Experieents are run with insuf ficient consideration to ALARA.
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The inspector re :r.ed exposures of the persannel in question and examined l
Reactor Use Req mrts from the standpoint of the ALARA requirement in :
Technical Speif t, ation 3.8. The requirement is that consideration be given '
to siternativt operational profiles that might reduce exposures. The ,
inspector found that ALARA was being considered in running experiments and [
that exposures wer0 being adequately controlled. i
Allegation
l
'a exper beent was conducted on October 9,1985 without proper approval, ,
(See section 5) l
/,11egation
I
The xetivated Materials Log was not reviewed annually as required. (See ;
section 5) j
Allegation !
!
Ne procedure was written for pulse operation wi.~. Cerenkov detector. (See !
section 5)
l
A11egstion
l
No safety analysis was performed on replacement of Pulse Ion Chamber with
Cerenkov detector nor on parallel nuclear instrumentation installed in ,
conjunction with a new reactor control console. (See section 6.2) !
!
Allegation i
!
l
The 411eger was concerned about licensing a enior Reactor Oprator due
to that operator's hearing impediment. Tha alleger does not feel this .
person etM t the requirements of the AFS statdard for rnedical certification. r
(
The operater in questioi. ' olds a license which contains restrictions that l
l require the wearieg of a hearing aid when performing licensed duties and I
.
prohteit assuming the SRO posit'on of Commander, Emergency Response Team. I
l The operator was given an Operatio.3a1 Hearing Evaluation, an Auc.ological I
Evaluation and a standard license related iadical examination. Results of
the Operational Hearing Evaluation indicated that the operator is able to
l
recognize an abnormal condition indicated by an alarm on either the remote
area monitor or the reactor continuous air monitor with the same adeptt.ess
that any other oper.ator would exhibit.
Section 5.4.4 of ANSI /A & 3.4 1983 entitled Medical Certification and
l Monitoring Personnel Requiring Operator Licenses for Nuclear Power Plants,
states that: "f' audiometric scores are unacM ptable, qualification may be
based upon onst;e deronstration to the satisfaction of the facility eperator
of the examinee's ability to safe?y detect, hterm et, and respond to
speech and ,ther aucitory signals." Tt e operator's ability to parform thest
tasks was ver ified by the Operational Hearing Evaluation.
i
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Armed Forces Radiobiology
. Research Institute 14
These factors were all considered during the licensing process and the
NRC subsequently issued a restricted license on August 23, 1988. A review
,
of the issue maintained the original NRC position.
Allegation
Snail shells Irradiated on May 12, 1988 were not recorded in the control
room core experiment log.
A review of the core experiment log shows several May 12 entries
appearing in proper chronological order, one of which contains the
description "Snail Shells". This entry is consistent with other
entries in the log ard appropriately completed. The entry is cross
referenced to PUR 83 38. A review of that form also showed no
irregularities.
10. Unresolved Items
Unresolved items are items about which more information is required to
ascertain whether they are ar.ctotable, a violation, or deviation.
Unresolved Items are discussed in sections 2.2, 6.3, 7, and 8.
11. Exit Meeting (30703)
The scope and findings of this inspection were duscussed with licensee
representatives on October 28, 1988. No written inspection material was-
provided to the licensee during the inspection.
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