ML20203A949
| ML20203A949 | |
| Person / Time | |
|---|---|
| Site: | 05000072, University of Utah |
| Issue date: | 07/14/1986 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20203A937 | List: |
| References | |
| 50-072-86-01, 50-407-86-01, 50-407-86-1, 50-72-86-1, NUDOCS 8607170368 | |
| Download: ML20203A949 (19) | |
See also: IR 05000072/1986001
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APPENDIX
- U.S. NUCLEAR REGULATORY COMMISSION
- REGION IV
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NRC Inspection Report: 50-72/86-01 Licenses: R-25
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50-407/86-01 R-126
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Dockets: 50-72
j 50-407
Licensee: University of Utah (UofU)
Salt Lake City, Utah 84112
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Facility Name: TRIGA and AGN-201 Reactor Facility
Inspection At: University of Utah, Salt Lake City, Utah
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Inspection Conducted: June 9-12, 1986
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1nspectar: 0] 1b h)/)1/${//
H. D. Chaney, Radiation Specialist, r Facilities
]flYfhh
Da'te
- /) Radiological Protection Section
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Approved: // / //db(///
B. Murray, Chief, Facil/ ties Radiological Ddte
N/b '
! Protection Section
Inspection Summary
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- Inspection Conducted June 9-12, 1986 (Report 50-72/86-01 and 50-407/86-01)
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- Areas Inspected
- Routine, unannounced inspection of the licensee's program for
i the operation of the AGN-201 and TRIGA reactors including: ' management controls
and organization, reactor operations, surveillances, experiments, radiation
i protection, emergency preparedness, physical security, radiological
environmental monitoring, and operator requalification training.
1 Results: Within the areas inspected, 11 apparent violations and 2 apparent
deviations were identified.
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DETAILS
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1. Persons Contacted
UofU
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- R. E. Turley, Reactor Administrator
! *C. Bryner, Associate Dean for Facilities, College of Engineering
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_G. M. Sar.dquist, Reactor Supervisor
- *W. D. Shepherd, Director of Public Safety
- K. C. Crawford, Senior Reactor Operator (SRO)
! *K. J. Schtager, Radiation Safety Officer (RS0)
i D. W. Hoeppner, Chairman, Department of Mechanical and Industrial
- Engineering
i D. R. Gunnell, Associate Administrator, University of Utah Hospital '
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K. M. McKnight, uofU Police Officer
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G. S. Pregman, UofU Police Officer
R. J. Hoffman, Health Physicist, Radiological Health Department (RHD)
D. Steinman, Mechanical Machine Shop Foreman
T. Sandquist, Student
C. M. Fejer, Radiation Safety Analyst
Others
f
) *B. Murray, Chief, Facilities Radiation Protection Section, NRC
! R. E. Carter, NRC Office of Nuclear Reactor Regulation (NRR),
ic Project Manager
!- J. L. Bateman, Captain, Salt Lake City Fire Department, Station 15
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- Denotes those present at the exit interview on June 12, 1986.
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l The NRC inspector also interviewed several other licensee employees and
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personnel associated with the VofU, such as police department dispatchers,
l students, Salt Lake City Fire Department personnel, plant maintenance, and
i radiological health.
4
I 2. Licensee Action on Previously Identified Inspection Findings
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i (0 pen) Violation (50-72/8301-01): Failure to Perform Technical
i Specification (TS) Surveillances - This item was identified in NRC
l Inspection Report 50-72/83-01 and involved the licensee's failure to
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perform certain required annual reactor surveillances on the AGN-201 '
reactor. The Reactor Safety Committee (RSC) has identified that one of
the control instruments for monitoring reactor power is malfunctioning and
replacement parts are difficult to obtain. Since this instrument's
- operation is necessary for reactor start-up, there has been no reactor
j op'eration for the last 3 1/2 years. As a result, the NRC inspectors
I could not verify that the licensee had implemented the required
i surveillance tests. This item is considered open pending repair of the
j control instrumentation and return of the reactor to full operating
j status.
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(0 pen) Open Item (50-407/8301-01): Reactor Facility Operating Manual
Update - This item was identified in NRC Inspection Report' 50-407/83-01 -
and involved out-of-date information in the operating manual concerning-
assignment of responsibilities and emergency phone numbers. The Reactor
Operations Manual was last updated and reviewed by the RSC on March 1,
1984. During this inspection, it was noted that information in the manual
. does not include current information concerning assigned responsibilies '
for management of the reactor facility,- membership on the RSC (handwritt'en
- corrections had been made to some names), and the phone numbers of some
key licensee personnel and the NRC Regional Office were in error. This
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item is considered open pending implementation of a program that will
ensure the Reactor Facility Operating Manual is updated at a frequency
commensurate with changes in management assignments and facility changes.
3. Inspector Observation
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The following are observations the NRC inspectors discussed with the
licensee during the exit meeting on June 12, 1986. These observations are
neither violations nor unresolved items. These items were recommended for
licensee consideration for program improvement, but they have no specific
regulatory requirement.
a. Records Storage - The licensee's records storage facilities at the
Nuclear Engineering Laboratory (NEL) do not provide sufficient
protection from damage by fire for records required to be kept for
the life of the facility. (See paragraph 6)
4
b. Documentation of Operations - NEL logs and RSC minutes do not provide
sufficient detail of the proposed switch-over to a computer based
reactor operating console for the TRIGA reactor. (See paragraph 6)
c. Housekeeping - The AGN-201 and TRIGA control rooms are not maintained
in an orderly fashion with regard to trash and combustible materials.
(See paragraph 6)
d. Technical Specifications - Obsolete reactor Technical Specifications
l were located at the TRIGA reactor operating console. (See
paragraph 8)
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e. 10 CFR Part 19.12 Training - The RHD heJ r - *' ablished minimum
performance criteria for written exami;ai aan ven in
10 CFR Part 19.12 training. (See paragraph 9)
f. RHD Involvement - The UofU RHD did not maintain coordination and
oversight of radiological activities taking place in the NEL. Also,
NEL supervision does not routinely communicate (outside of RSC
meetings) with the RHD regarding the radiological aspects of planned
maintenance and nonroutine reactor operations. (See paragraph 14) '
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g. NRC Information Notices and Generic Communications - The RHD does
not routinely receive NRC Information Notices or applicable NEL
correspondence that is sent to the UofU. (See paragraph-14)
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h. Neutron Surveys'- Neutron radiation levels have not been established
regarding operation of the AGN-201 and TRIGA reactors. -(See
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paragraph 14)-
1. Radiological Controls - Poor radiological controls existed involving
the handling of potentially radioactive materials. (See paragraph 14)-
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j. Portable Instrumentation - The licensee does not maintain
information on the calibration program for the portable radiation
dose rate monitoring instruments loaned to the NEL or a program for
the identification of instruments that are out of calibration. (See
paragraph 14)
l k. Emergency Drill - During the June 12, 1986, NEL emergency response
j drill, several problems were noted. (See paragraph 16)
4. Management Organization and Controls
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The licensee's management organization and controls were inspected to
determine compliance with AGN-201 TS 6.1, and TRIGA TS 6.1, 6.2, 6.5.1,
6.5.3, and 6.5.4; and the commitments contained in the Safety Evaluation
Report (NUREG-1096).
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The licensee's organization and assignment of responsibilities are contained
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, in the NEL Operations Manual. The NRC inspectors compared the existing
organization to the requirements in the AGN-201 and TRIGA TS. The
membership and procedures for the RSC were reviewed. The-NRC inspectors
noted that the Reactor Administrator had changed twice since the last NRC
inspection (April 22, 1983). The current Reactor Administrator assumed
this position in September 1985 and it was noted that he had also held the
position prior to 1983. The reactor supervisor was noted to have been on
sabbatical leave during the period of January through' June 12, 1986. The
RSC had approved on December 12, 1986, the assignment of the Senior
Reactor Operator as Acting Reactor Supervisor.
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The NRC inspectors also reviewed the support given to the NEL by the
Director of-Public Safety /VofU Police Chief and the RHD. The NRC inspectors
noted a lack of involvement and technical support in day-to-day activities l
at the NEL by the RHD. Furthermore, it was apparent that lack of reactor-
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management oversight and involvement in NEL activities resulted in problems
. with the Physical Security Plan (PSP) and the radiation protection program.
The~NRC inspectors noted that the numerous apparent violations identified
in this report are an indication of a breakdown in management controls-
regarding operations at the NEL.
No violations or deviations were identified.
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5. Reviews and Audits
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The NRC inspectors inspected the licensee's review and audit programs to
determine compliance with the requirements of AGN-201 TS 6.4.2 and 6.4.3,
and TRIGA TS 6.5.4 and 6.5.5; and the commitments of the Section 13.4 of
the safety evaluation report (SER).
The NRC inspectors determined that the RSC conducted operational and
record reviews as required by the TS. Minutes of RSC meetings for the
period January 1983 through March 1986 were reviewed as were operational
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logs, experiment approval forms, changes to operating procedures, and
verification of the biennial review of the Emergency Plan (EP) and PSP.
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The AGN-201 TS 6.4.3, states, in part, that " Audits of facility activities
shall be performed under the cognizance of the RSC . . . These audits
shall examine the operating records and encompass . . The Facility
Security Plan and implementing procedures, at least every.two years."
In discussions with licensee representatives and the review of records,
the NRC inspectors determined on June 11, 1986, that formal audits
regarding implementation of the PSP had not been conducted. The failure
to conduct required audits is an apparent violation of TS 6.4.3
(50-72/8601-01).
No deviations were identified.
$ 6. Logs and Records
The NRC inspectors reviewed logs and records to determine compliance with
6.5.6, and 6.9.
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The NRC inspectors reviewed reactor operations for the AGN-201 and TRIGA
for the period January 1, 1983, through June 9, 1986, regarding
- maintenance, fuel configurations, personnel exposure and dosimetry logs,
! experiment records, startup checklists, and instrument response check
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logs. The NRC inspectors determined that the maintenance history records
j for the TRIGA reactor were not documented in sufficient detail to provide
a clear description / understanding of previous maintenance activities.
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l This was especially evident regarcMng the maintenance work involving the
upper core support grid work performed during December 1985 and
January 1986 Also, the NRC inspectors discussed with the licensee the
need to update the history ~and current status concerning the proposed
implementation of a computerized operations console for the TRIGA reactor,
and to ensure that the NRR Project Manager is kept up-to-date on the
- planned modifications.
The licensee maintains required facility records and logs in binders or
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' loose leaf files in the TRIGA reactor control room (Room 1001-D) of the
Merrill Engineering Building, (see Figure 4.1 of the SER for detailed
layout of the NEL). The NRC inspectors determined that these important
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records are not provided adequate protection from fire or water damage.
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Room 1001-D does not contain smoke or fire alarms; however, Room 1001-D
] does have an overhead water sprinkler-fire suppression system. The
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system, if activated, would douse many of the logs and records.with water.
'Some files (about 50 percent) were noted to be kept in a metal file
cabinet. The NRC inspectors determined that the metal cabinet was not
fire / heat rated. The NRC inspectors also noted that the TRIGA control
room contained a large amount of combustibles and that general
housekeeping conditions needed to be improved. The AGN-201 reactor
console was covered with miscellaneous equipment and periodicals.
f No violations or deviationc were noted.
7. Procedures
The NRC inspectors reviewed procedures to determine compliance with
AGN-201 TS 6.4.2 and 6.6, and TRIGA TS 6.6.4 and 6.8; and the commitments-
of Section 4.7 of the SER.
The following procedures were reviewed:
NEL Operations Manual, RSC Approval dated March 1, 1984
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Procedure for Adding Water to the Reactor Tank (no date or approval)
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TRIGA Preliminary Check Sheet (no date or approval)
UofU TRIGA Reactor Monthly Inspections, RSC Approved February 1981
Approach to Critical Procedure (no date or approval)
Biennial Control Rod Check, RSC Approved February 120, 1981
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Procedure for the Biennial Fuel Rcd Inspection, RSC Approved
February 20, 1981
Procedure for Changing Filters in the Water Demineralizer Circuit,
RSC Approved February 20, 1981-
The NRC inspectors noted that the above procedures have not been reviewed
since February 20, 1981, and some procedures reference old TS that do not
agree with the latest TS. The TRIGA TS issued with the renewal of license
R-126, dated April 17, 1985, requires a biennial review of all standard-
procedures, whereas before no periodic caview was required. It was noted
that RSC members occasionally perform random reviews of completed i
procedures.
TRIGA TS 6.8, " Operating Procedures," requires, in part, that " Operating
procedures shall be in'effect for the following items: . . . (6)
performing preventive maintenance and calibration tests on the reactor and
associated equipment."
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AGN-201, TS 6.6, " Procedures," requires, in part, that "There shall be
written procedures that cover the following activities:
d. Preventive or corrective maintenance which could affect the
{ safety of the reactor.
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e. Surveillance, testing, and calibration of instruments,
q components, and systems as specified in Section 4.0 of the
Technical Specifications. (Technical Specification 4.4.a,
I , applies to installed and portable radiation monitoring and
control systems)."
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The NRC inspectors determined on June 12, 1986, that the licensee had
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performed maintenance on the TRIGA reactor core support components
involving remcval of stuck fuel elements (caused by chemical corrosion due
to a leak of chemicals from the SCRAM magnet), cleaning the upper core
support grid by machining, enlargement of the grid fuel element openings i
by drilling, and the re-anodizing of the support grid. This work was
performed by Vofu personnel and non-university personnel, during the
period of December 15, 1985, through January 25, 1986. This work was
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originally initiated by the reactor supervisor in December 1985, and
completed after January 15, 1986, by the senior reactor operator. The
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work on the core support grid resulted in several radiological control
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problems. However, the licensee did not develop any maintenance or
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radiological control procedures concerning the work activities. The RSC
meeting minutes indicated that they (RSC) were not aware of the work until
af ter it was completed on or about January 28, 1986. The failure to
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develop the necessary maintenance procedures is an apparent violation of
.
The NRC inspectors also noted that the licensee calibrates area radiation
monitors with a source that has an undetermined' radiation output and in
geometries that vary depending on who is performing the calibrations. The
1.icensee's records concerning calibration of the airborne radiation
monitor ventilation system indicated that during the period of
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January 1983 through May 1986, the type of source changed from Cesium-137 ,
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to Europium-152 and that readings for the Europium source varied by as
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much as 200 percent on several occasions. The licensee had not developed
procedures, other than the monthly inspection checklist, for calibration -
of the AGN-201 or TRIGA area radiation monitors. The licensee also could
not provide information on the calibration program or the sources used to
calibrate several of the portable instruments in use in the NEL.
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The failure to establish written calibration procedures for radiation
. monitoring equipment is an apparent violation-of AGN-201 TS 6.6.e
(50-72/8601-03).
No deviations were identified.
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8. Reactor Operations
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The NRC inspectors reviewed operation of the AGN-201 and TRIGA reactor;
for the period April 1,1983, through June 11, 1986.
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a. AGN-201
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The AGN-201 reactor has been placed in long term shutdown since
February 18, 1985, when during annual rod drop checks a
malfunctioning power range instrument was identified. This
instrument cannot be readily repaired because of the unavailability
of reple.ocent parts. The NRC inspectors determined that the
licensee nad not operated the AGN-201 since the last inspection of
this facility in April 1983. The licensee maintains a surveillance
program over the reactor facilities and critical components.
b. TRIGA
The NRC inspectors reviewed the operations history to determine
compliance with the following requirements.
l License Condition 2.c.(1), - Maximum Power Levels
TS 2.1 - Fuel Element Temperature
TS 2.2 - Safety System Settings
TS 3.2 - Reactivity Limitations
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TS 3.3.2 - Reactor Control System
TS 3.3.3 - Reactor Safety System
TS 3.5 - Ventilation System
TS'3.8 - Primary Coolant Conditions
TS 5.1 - Reactor Fuel
TS 5.2 - Reactor-Core
TS 5.3 - Control Elements
- TS 5.4 - Radiation Monitoring System
TS 5.5 - Fuel Storage i
TS 5.7 - Reactor Pool Water System
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The NRC inspectors determined that the TRIGA reactor was routinely
operated approximately 290 hours0.00336 days <br />0.0806 hours <br />4.794974e-4 weeks <br />1.10345e-4 months <br /> a year for the last 3 years for the
purpose of laboratory teaching, system tests, power measurements, and
sample irradiations. The sample irradiations involved routine experiments
and production of Gold-198 implant seeds for veterinary medicine
application, and activation of ore samples. The licensee's records
indicated that approximately 14 inadvertent SCRAMS occurred during both
1984 and 1985. The licensee initiated startup of the TRIGA reactor on
June 12, 1986, but sufficient time was not available to complete the- '
reactor startup and operation.
i As referenced in paragraph 7 of this report, the licensee had performed
i the biennial rod and fuel element inspections on the TRIGA during
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December 1985, through January 1986. The NRC inspectors noted in the
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. maintenance log entries that some fuel elements were difficult to remove
from the core support structure. The licensee identified in the log that
due to a leaking SCRAM magnet housing, lubricants leaked into the reactor
pool water and caused a corrosion buildup to form between the upper grid
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plate and fuel element similar to a weld. The information in the log
- indicated that seven elements were particularly difficult to remove and
they requirad a back and forth twisting motion with a fuel handling tool
in order to remove these elements. The licensee stated that the stuck
fuel elements were visually inspected for damage after removal and no
damage was identified. The NRC inspectors noted that certain evaluations
of this maintenance activity (machining, plating, and retesting of
components) were not adequately documented in the log. The NRC inspectors
emphasized to the licensee the need to fully document all aspects of the
work and perform an evaluation on the effects, if any, on the core grid
structure following the modifications and re-anodizing.
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The SER and TRIGA TS referenced the installation and use of a high
efficiency particulate air (HEPA) filter located in the NEL reactor
building ventilation system. This ventilation system is considered an
engineered safety feature in the SER. This system is designed, according
to Section 6.1 of the SER and TS 3.5 and 5.6(2), to control and filter
airborne radioactivity discharge from the reactor facility. The NRC
inspectors determined on June 10, 1986, that the primary HEPA filter in the
exhaust ventilation leg of the system, as referenced in Figure 6.1 of the
SER, would not be able to perfo.rm its intended function. The filter was
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not sealed to its mounting opening which would result in bypass leakage,
installed so that the flow of air was in the wrong direction through the
i] filter (manufacturer's flow requirement), and in the wrong orientation to
prevent sagging of the filter pleats. The licensee could not locate any
documents that would verify that the installation had ever been in place
tested to demonstrate that the system could perform its intended purpose.
The above conditions are an apparent deviation to good engineering
practices and industry standards (50-407/8601-04).
The NRC inspectors reviewed facility design changes and modifications to
determine compliance with 10 CFR Part 50.59. The licensea reported to the
NRC in the VofU TRIGA reactor Annual Operating Report for the period
July 1, 1984, through June 30, 1985, an RSC approved modification to the
TRIGA water tank recirculation system. This modification involved the
addition of a 20 kilo-watt heat exchanger. The modification was noted to
involve the hard piping of a water supply line from the recirculation
system to the Merrill Engineering Building potable water supply and the
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connect son of the recirculation system to a local sanitary drain system in
the NEL. The NRC inspectors noted that the connection to the potable
water supply involved a two valve isolation, one plastic and one metal,
but none of the operating procedures call for verifying these valves are
- shut or that their capability to isolate the potable water supply from the
- reactor water tank recirculation system is periodically verified. The two
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systems (potable water and sanitary system interfaces) had not been
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surveyed to determine the presence of radioactive contamination. The NRC
inspectors determined on June 11, 1986, that the licensee had not
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evaluated the interface of these two systems with the reactor water tank
recirculation system as an unreviewed safety question since the release.of
radioactive effluents via these two pathways were not discussed in the
SER, Section 11.2.2 Liquid Wastes, 12.3 Radiation Sources, or 12.6.2
Liquid Effluents. The failure to perform a proper safety analysis is an
apparent violation of the requirements of 10 CFR Part 50.59.
(50-407/8601-05).
During a review of reference material maintained at the TRIGA reactor
console, the NRC inspectors noted that an obsolete copy of.the TS'was the
only copy of this document readily available for operator use.-
9. Qualifications and Training
Personnel qualifications and training were reviewed to determine
compliance with the requirements of AGN-201 TS 6.2 and 6.3, and TRIGA
TS 6.3, 6.4, Appendix A, and 6.5.2; 10 CFR Part 19.12 and.10 CFR Part 55,
Appendix A; the recommendations of NRC Regulatory Guides 8.13, 8.27, and
8.29, and industry standard ANSI /ANS-15.4-1977.
The NRC inspectors reviewed qualifications and training records for
personnel that support the NEL such as radiation. control, emergency
resp,nse, and students granted access to the NEL for work with radioactive
materials or the reactors. Lesson plans and attendance rosters for
police Jnd firemen that may have to respond to an emergency at the NEL were
inspected. The inspectors noted that the licensee conducts annual
familiariz3 tion tours of the NEL facility for support personnel.
The NRC insptctors determined that the RHD and the NEL both provided
radiological training for personnel that require entry into the restricted
areas of the NCL. The RHD training program addressed the NEL in addition
to other VofU attivities involving radioactive materials. The NRC
inspectors discussed with the RSO their concern that the radiation
protection trainin] course examination given to personnel was not being
used as a feedback nechanism for determining weaknesses in the training
program and/or personnel trained. This concern ~ arose from the review of
examination results which indicated that a student, which works in the NEL
and has been involved with operation of the TRIGA reactor, had received a
score of about 45 percent; however, there was no indication of remedial
training or counsel being given and the student was noted to be working at
the NEL during this inspection. :
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The NEL staff consists of a Reactor Supervisor (senior reactor operator
(SRO)) licensed on the AGN-201 and TRIGA), one TRIGA SRO, and four TRIGA
licensed reactor operators (RO). The Reactor Supervisor is the only
individual licensed on the AGN-201.
The NRC inspectors reviewed the TRIGA reactor requalification training for
compliance with the program approved by the NRC on April 12, 1984. The
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requalification program states, in part, that training will include
planned lectures to cover the following areas:
Nuclear Theory
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Radiation Control and Safety
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Technical Specification and Reactor License
Reactor Operating Characteristics
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Reactor Control and Safety Systems
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Emergency Operating Normal and Abnormal Procedures
! Changes, Modifications, or Malfunctions Occurring to Reactor Systems
or Operational Procedures
l Applicable Portions of Title 10, Chapter I, Code of Federal Regulations
<
Operational Characteristics, Use, and Storage Locations of Existing
and New Radiation Safety Equipment
The requalification program also requires that annual evaluations of each
operator's knowledge and performance will be conducted by written examina-
tion, console performance examination, and an oral examination. Further-
- more, the requalification program requires that a record will be maintained
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for each individual and will contain the following information:
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Current copy of either the individual's reactor operator or senior
reactor operator license.
Copies of all written examinations administered to the individual and
the correct answers given to the individual during the
requalification period.
The annual evaluations of the individual documented in a memorandum
for record.
The summary of additional training received by the individual
documented in a memorandum for record and any additional documentation.
The NRC inspectors determined on June 12, 1986, that the licensee's
i records for licensed reactor operators (which were all kept in one
unorganized file folder) did not contain current copies of the operators'
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licenses, or annual evaluations for the operators. The NRC inspectors also
determined that the licensee had not provided formal classroom lectures or
prepared lesson plans for the purported informal lectures given to operators.
The failure to implement the TRIGA operator requalification program is an
apparent violation of 10 CFR Part 55, Appendix A (50-407/86-06).
i No deviations were identified.
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10. Technical Specification Surveillances Requirements
The NRC inspectors reviewed surveillance results to determine compliance
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with AGN-201 TS 4.0 and TRIGA TS 4.0. The NRC inspectors reviewed
representative logs, records, and documentation for the period
- January 1983 through June 1986.
- a. AGN-201
The reactor has been shutdown, except for one attempted startup in
February 1985. TS 4.0 does not require surveillances to be performed
on the reactor if it is maintained in a shutdown condition. .The
licensee is performing radiation monitor response checks in
accordance with TS 4,4 and routine facility inspections. .
i b. TRIGA
.
TS 4.1 " General" states: "Any additions, modifications, or
'
mair.tenance to the ventilation system, the core and its associated
support structure, the pool or its penetrations, the pool coolant
'
system, the control element drive mechanism, or the reactor safety
system shall be made and tested in accordance with the specifications
to which the systems were originally designed and fabricated or to
specifications approved by the Reactor Safety Committee. A system
shall not be considered operable until_after it has been successfully
tested."
i- The NRC inspectors determined on June 11, 1986, that written
documentation was not available to verify that the testing
.
requirements in TS 4.1 were completed following maintenance performed
j on the upper core structure (see paragraphs 7, 8, and 14 of this
i report) in January 1986. The failure to verify testing requirements
!
is an apparent violation of TS 4.1 (50-407/86-07).
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The licensee's records indicated that other surveillance requirements
were completed.
!
l No deviations were identified.
j 11. Experiments
I
! The licensee's program for the control and conduct of reactor experiments ,
was inspected to determine compliance with the requirements of AGN-201 l
j TS 3.3 and 6.4.2(c), and TRIGA TS 1.2, 3.2, 3.6, and 6.5.4(1); and the
recommendations of RG 2.2 and 2.4, and industry standard
- ANS-15.6/N401-1974.
i
The NRC inspectors reviewed the licensee's records of experiments
!
conducted in the TRIGA reactor (the AGN-201 has not been used since the
last inspection in this area). The TRIGA has been primarily used for the
j
1
irradiation of ore samples, biological tissue, and the production of
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Gold-198 seeds for veterinary applications. The licensee's review of
experiments and procedures were inspected, and it was noted that the RSC
and the reactor supervisor reviewed all new experiments.
No violations or deviations were identified.
12. Reactor Fuel Handling
The licensee's program and procedures for the handling and storage of fuel
were inspected to-determine compliance with the requirements of AGN-201
TS 5.2, and TRIGA TS 4.4 and 5.5.
The NRC inspectors reviewed biennial TRIGA fuel element inspection
records, fuel inventory records, and core configuration records. The NRC
inspectors noted that the fuel handling tools were kept outside the TRIGA
reactor room.
No violations or deviations were identified.
13. Transportation of Radioactive Materials
1
The licensee's program for the transportation of radioactive
materials (RAM) was inspected to determine compliance with AGN-201 and
TRIGA reactor license condition requirements, and the requirements of
10 CFR Part 71 and 49 CFR Parts 170 through 189. !
The licensee had reported in both the TRIGA and the AGN-201 annual reports
that no radioactive wastes have been generated as the result of reactor
operations. Most of the licensee's wastes are generated as the result of
experiments and transferred to the state of Utah byproduct materials
license for disposal.
License condition 2. A for the TRIGA reactor establishes the location of
the TRIGA reactor facility as on the campus of the UofU. License
condition 2.B.(1) authorizes the licensee to possess, use, and operate the
facility at the designated location in Salt Lake City, Utah,_in accordance
with the procedures and limitations set forth in the license. License
condition 2.C states, in part, that "This license shall be deemed to
contain and is subject to the conditions specified in Parts 20, 30,
50, . . . of 10 CFR. Chapter I . . 10 CFR Part 30.34(c) requires, in
part, that "Each person licensed by the Commission pursuant to the
regulations in this part . . . shall confine his possession and use of the
byproduct material to the locations and purposes authorized in the
license." The NRC inspectors determined on June 11, 1986, that the
licensee had on several occasions in the past (June 1983, January 1984, '
and January 1986) transferred radioactive TRIGA components (core support
grid plates and heavy water tanks) to unlicensed . locations off-campus for
maintenance work such as welding and anodizing. The transfer of
radioactive material to an unauthorized location is' considered an apparent
violation of license condition 2. A (50-407/8601-08).
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1.
i 10 CFR Part 30.34(c) requires, in part, that " Preparation for shipment and
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transport of byproduct material shall be in accordance with the provisions
of Part 71 of this Chapter." 10 CFR Part 71.5(a) requires, in part, that
- ' "Each licensee who transports licensed material outside of the confines of
i its plant or other place of use . . . shall comply with the applicable
j requirements of the regulation appropriate to the mode of transport of DOT
'
in 49 CFR Parts 170 through 189." 49 CFR Part 171.2(a) requires, in part,
! that "No person may offer or accept a hazardous material for
i
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transportation in commerce unless that material is properly classed,
described, packaged, marked, labeled, and in condition for shipment as
required . . . by this subchapter." 49 CFR Part 171.2(b) requires, in
- part, that "No person may transport a hazardous material in commerce !
,
unless that material is handled and transported in accordance with this
- subchapter . .
"
49 CFR Part 172.200(a) requires, in part, that "each-
, person who offers a hazardous material for transportation shall describe
'
the hazardous material on the shipping paper in the manner required by
this subpart." 49 CFR Part 172.203(d) requires, in part, that "The
4
description for a shipment of radioactive material must include . . . The
j name of each radionuclide in the . . material . . The activity
contained in each package . . ." 49 CFR Part 172.403(a) requires, in
part, that radioactive material packages must be labeled as provided for
in this section. During discussions with licensee personnel, the NRC
, inspectors determined on June 11, 1986, that a SRO transported the
j radioactive TRIGA upper core support grid plate from the UofU to a metal
l plating shop in Salt Lake City, Utah, on or. about January 25, 1986, and
j left it there for anodizing. The SRO knew that the plate was radioactive
4;
and that contact dose rates from the plate were in the range of
10 to 50 millirem per hour (mr/hr). Discussions revealed that the SRO had
'
used his own automobile to transport the plate, but had not prepared
shipping papers for the shipment, packaged the plate, or labeled the plate
1 to comply with regulatory requirements. The SRO could not provide any
j survey records of the plate taken prior to transport, which is required by
t
49 CFR Part 173.475(1). The failure to identify, package, and label the
radioactive core support grid is an apparent violation of the requirements
of NRC and DOT regulations (50-407/8601-09).
No deviations were identified. t
l
14. Radiation Protection
t
- The licensee's radiation protection program was inspected to determine
,
compliance with the requirements of the AGN-201 TS 3.3(c), 3.4, 4.4, and
i and 6.1.9, and TRIGA TS 3.7, 4.3.3, 4.3.4, and 5.4, and 10 CFR Parts 19
j and 20; and the recommendations of industry standard ANSI /ANS-15.11-1977.
i
j The NRC inspectors reviewed monthly radiation and contamination survey
records for 1984, 1985, and 1986 regarding surveys performed by both.the
VofU RHD and NEL personnel. Radiation exposure records for NEL personnel
j were also reviewed.
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The licensee's TRIGA reactor license renewal application in response to
NRC question number 48, which asked the licensee to describe the personnel
monitoring program, states, in part, that a radiation history and record
would be created for all personnel issued dosimetry. The RHD could not
provide a radiation exposure history file for two R0s that had been
routinely provided dosimetry at the NEL and had operated the TRIGA
reactor. This is an apparent deviation of a commitment to the NRC
regarding creation of personnel exposure history and records
(50-407/8601-10).
The NRC inspectors further discussed with the licensee the apparent lack
of control over personnel dosimetry at the NEL in that NEL access logs
show that several individuals used the same temporary (loaner badge)
badge during January, February, March, and April of 1986. During
January 1986, two loaner badges were each used by up to four different
individuals. The licensee stated that each individual also used a self
reading pocket dosimeter (SRD) on each entry, and that each person's
approximate dose could be computed from these entries. The NRC inspectors
informed the licensee that the SRDs used by the licensee appeared to be
surplus government SRDs (which are surplus when they can no longer meet
RG 8.4 equivalent performance criteria), and since the-licensee had not
evaluated the SRDs performance as recommended by RG 8.4, the SRD results
would be questionable.
The NRC inspectors also performed independent fixed and loose surface
contamination and direct radiation dose rate surveys of the NEL facility
and adjacent areas. The licensee was notified on June 11, 1986, by the
NRC inspectors, that elevated radiation and loose surface contamination
levels were identified by the NRC inspectors during surveys of the NEL
(restricted area) and the adjacent (unrestricted area) Mechanical
Engineering Department Machine Shop (MEMS) both located in the Merrill
Engineering Building. The elevated levels had not been previously
identified by the licensee during routine and special surveys. The NRC
inspectors also noted that the licensee had not initiated radiological
surveys of the Merrill Engineering Building potable water system or the
sanitary sewer outfall that services the TRIGA reactor pool water
recirculating system. The TRIGA reactor pool water system is also
discussed in paragraph 8 of this report.
10 CFR Part 20.201(a) states, in part, that "As used in the
regulations . . . " survey" means an evaluation of the radiation hazards
incident to the . . . use, release, disposal, or presence of radioactive
materials or other sources of radiation under a specific set of
conditions. When appropriate, such evaluation includes a physical survey
of the location of materials and equipment, and. measurements of levels of
radiation or concentrations of radioactive material present."
Part 20.201(b) requires, in part, that "Each licensee shall make or cause
to be made such surveys as (1) may be necessary for the licensee to comply
with the regulations . . . (2) are reasonable under the circumstances to
evaluate the extent of radiation hazards that may be present." During
independent NRC surveys of Room 1001-E (AGN-201 and TRIGA reactor
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location), on June 9 and 12, the NRC inspectors identified radioactive
components laying adjacent to the AGN-201 reactor that produced general
area radiation dose rates of apprcximately 22 mr/hr at 18 inches, and up
to 230 mr/hr on contact, and loose surface radioactivity levels of 3,000
disintegration per minute (dpm)/100cm 2beta gamma contamination on a
rubber floor mat above the TRIGA reactor. Discussions with the licensee
determined that the components had been received and stored in Room 1001-E
since about October 1985. On June 11, 1986, during an independent
surveying of the MEMS (Room 1003), it was determined that RAM was present
on the floor and several of the machines (two vertical milling machines
and one radial arm drilling machine). Survey results indicated that
surface contamination levels ranged from several hundred dom /100 cm 2
to
100,000 dpm/100 cm . Contact radiation levels of about 1.0 mrad /hr were
2
also identified. The licensee stated that the MEMS was used during
January 15, 16, 23, and 24, 1986, to machine and drill the TRIGA reactor
upper core support grid. The licensee stated that the MEMS had been
surveyed following the January work and no racloactivity was detected.
The general lack of knowledge on the part of the RHD and NEL personnel
concerning the presence of contamination within the MEMS indicate that a
serious breakdown in radiological controls at the NEL.
Routine monthly surveys performed by both NEL and the RHD routinely
identified direct radiation levels within the NEL as less than 0.02 mr/hr
and less than 1000 dpm loose surface contamination. The licensee could
not provide survey records concerning radiological conditions during
the core grid work or post work surveys of the MEMS. Also, the licensee
was not able to provide any documentation concerning radiological controls
in effect in the MEMS during the core grid maintenance work. MEMS
personnel that performed the milling and drilling stated that they were
not informed that the equipment they were working on was radioactive and
that no special controls were established. The NRC inspectors also noted
there was a lack of NEL management control and coordination involving the
above referenced work, in that the RHD was not involved in establishing
radiological controls for the core grid maintenance activities.
The RHD initiated surveys and decontamination of the MEMS in the afternoon
of June 11, 1986. In the late afternoon of June 11, 1986, licensee
representatives stated that the MEMS had been decontaminated to background
levels. The NRC inspectors performed a follow-up survey and determined
that previously identified contamination still existed in tne MEMS.
Following further decontamination by the RHD, the RSO provided the NRC
inspectors a report on the contamination evaluation and cleanup of the
MEMS, dated June 12, 1986, which summarized the RHD' efforts since being
informed of the problem on June 11, 1986. The report and discussions with
the licensee indicated that the MEMS had been decontaminated to background
levels. The NRC inspectors again performed a survey for fixed and loose
surface contamination and determined that one piece of equipment
previously identified by the NRC to +.he licensee on June 11, 1986, had
never been decontaminated and still showed loose surface contamination
level of approximately 4,500 dpm/100 cm2 and the presence of general
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radioactivity levels of 30,000 dpm/100 cm 2 on the machine's surfaces. The
failure to perform adequate surveys is an apparent violation of 10 CFR
Part 20.201 (50-407/8601-11).
The NRC inspectors noted that the routi'e surveys of the NEL conducted by
RHD personnel were of such insufficient detail, and con;ained mistakes as
to location of areas actually surveyed, that. they provided no practical
radiological control use. Furthermore, the NRC inspectors noted that the
NEL surveys for October and November 19f 5 appeared to be the same survey
with only a date change en a machine mare copy of the October survey.
The licensee's survey program had not inc1Lded an evaluation of neutron
radiation levels with the reactors operating at full power. The NRC
inspectors stated that neutron radiation levels are not usually considered
to be a problem at AGN-201 and 100kw TRIGA facilities; however, actual
surveys should be performed to establish that no significant neutron
radiation levels exist.
Discussions with the RSO disclosed that the RHD is not on a routine
distribution of NRC literature and relevant documents received by the
Uofu.
The NRC inspectors noted that a SR0 did not use protective clothing
(gloves) during handling of potentially radioactively contaminated
material that had been in contact with TRIGA reactor pool water.
Several portable radiation survey meters, supplied by the Nevada Office of
the Department of Energy, are used as auxiliary radiation monitoring
instrumentaticn to the permanently installed instruments. The NRC
inspectors noted that at least two gamma scintillation meters and two
beta / gamma ion chamber dose rate meters were available for use at the NEL.
The NRC inspectors brought to the attention of the licensee that one of
the beta / gamma dose rate meters stored with ready-to-use instruments was
out of calibration by approximately 2 years (last calibrated May 19,
1983).
15. Radiological Environmental Monitoring
The licensee's radiological environmental monitoring and protection
program was inspected to determine compliance with the requirements of
TRIGA TS 3.4 and 3.7, and 10 CFR Part 20.106; and the commitments
contained in Section 12.7 of the SER.
The NRC inspectors reviewed the licensee's reports concerning effluent
releases and observed environment monitoring equipment at the NEL. The
licensee's environmental monitoring program is primarily conducted by'the
Environmental Protection Agency in conjunction with routine environmental
monitoring the Uofu.
No violations or deviations were identified.
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16. Emergency Planning and Preparedness
The NRC inspectors reviewed the implementation of the UofU Emergency
Plan (EP) for the AGN-201 and TRIGA reactors; the requirements of 10 CFR
Parts 50.54(q) and (r); the commitments contained in Section 13.3 of the
SER; and the recommendations of RG 2.6 and industry standard
ANSI /ANS-15.16-1982.
The NRC inspectors reviewed assignment of responsibilities, emergency
facilities and equipment (first aid and medical facilities, communications,
rescue and fire, radiation and contamination protection equipment). The
NRC inspectors verified that the inventories of emergency equipment and
supplies agreed with the EP. The NRC inspectors discussed with the Salt
Lake City Fire Department and the UofU Medical Center their roles in the
event of a reactor accident or fire at the NEL. The NRC inspectors also
observed an emergency drill on June 12, 1986, designed to verify response
capabilities of organizations and personnel. The drill involved
participation from the Salt Lake City Fire Department and Hazardous -
Material Control Unit, UofU Police Department, the NEL staff, and the RHD.
The NRC inspectors discussed the following observations:
No one was designated as the emergency response director; all parties
performed independently.
The drill scenario was never made clear to participants and did not
cause a sufficient degree of realism to be shown by participants.
The NRC inspectors recommended the use of the reactor accident
scenarios in the SER.
The drill critique should be documented with assignments of corrective
actions provided to all participants.
The NRC inspectors noted that the licensee had provided annual
indoctrination training on NEL activities and facilities for fire
department, police and medical emergency service personnel.
No violations or deviations were identified.
17. Physical Security
The material discussed here contains Safeguards Information as defined by
10 CFR Part 73.21 and is reported in Attachment to this report.
18. Nuclear Materials Safeguards
The NRC inspectors reviewed the nuclear materials safeguards program to
determine compliance with AGN-201 and TRIGA license conditions 2.B.(2).
The inspectors reviewed accountability procedures and practices, records,
and material status reports for the period 1983 through 1986.
No violations or deviations were identified. '
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19. Reports and Notifications
The NRC inspectors reviewed reports and notifications to determine
compliance with AGN-201 TS 6.9.1 and 6.9.2 and TRIGA TS 6.10.
No violations or deviations were identified.
20. Exit Interview
The NRC inspectors met with the licensee's representatives identified in
paragraph 1 of this report at the conclusion of the inspection on June 12,
1986. The NRC inspectors summarized the scope and the results of the
inspection. The NRC inspectors emphasized that the numerous apparent
violations indicated a serious breakdown of management controls. The
licensee stated that a survey was performed on June 11, 1986, at the
offsite facility where the core grid support was anodized in January 1986
and no radioactive material was identified.
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