ML20207T362

Insp Rept 50-083/87-01 on 870209-11.Violations Noted:Failure to Comply W/Dot Requirements for Transportation of Matls,To Follow Radiation Protection Procedures & to Post Required Documents

ML20207T362
Person / Time
Site:	05000083
Issue date:	02/13/1987
From:	Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T346	List: ML20207T345 ML20207T355 ML20207T362
References
50-083-87-01, 50-83-87-1, NUDOCS 8703230480
Download: ML20207T362 (8)

See also: IR 05000083/1987001

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA STREET,N.W.

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FEB'2 01987

Report No.: 50-083/87-01-

. Licensee: University of Florida

202. Nuclear Sciences Lenter -

Gainesville, FL 32611

Docket No.: 150-083

License No.:

R-56'

Facility Name: University of Florida Training Reactor

' Inspection Conducted: - February 9-11, 1987

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Inspector:

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-B. K.-Revsin,

Date Signed

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Approved by:

C.M. Hose'y,SectipnChief

Date Signed

Division of Radiation Safety and Safeguards

SUMMARY

- Scope:

This- routine unannounced inspection involved onsite inspection in the

area ' of radiation control, environmental protection and transportation of

radioactive materials for the University of Florida Training Reactor (UFTR).

Results:

Three violations - (1) failure to comply with Department of

Transportation (DOT) requirements for transportation of radioactive materials,

(2) failure to follow radiation protection procedures, and (3) failure to post'

required documents.

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8703230480 870220

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REPORT DET ILS

1.

Persons Contacted

Licensee Employees

W. G. Vernetson, Director, UFTR

P. M. Whaleys, Acting Reactor. Manager

J. S. Tulenko, Chairman, Nuclear Engineering Sciences Department

D. L. Munroe, Radiation Control Officer, Environmental Health and

Safety

2.

Exit Interview.

The inspection-scope and findings were summarized on February -11,1987, with

those persons indicated in Paragraph 1 above.- Three. violations,'(1) failure

to adhere to DOT requirements for transportation of radioactive materials,

-(Paragraph 4.b); .(2) failure to adhere to radiological procedures

(Paragraph 3.c), and (3) failure to post required documents (Paragraph 3.f)

. ere discussed in detail.'. Licensee management acknowledged the findings and.

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took no exceptions. The licensee did not identify as proprietary any of the

materials provided to or reviewed by the inspector during this' inspection.

.3.

Radiation Control (83743)

a.

10 CFR 20.201(b) requires the licensee to perform such surveys as may

be necessary and are reasonable under the circumstances to evaluate the

extent of radiation _ hazards that may be present.

Technical Specification (TS) 3.9.2(2)(a) specifies that surface

contamination in the restricted area shall be measured by(taking random

swipes in the reactor cell weekly.

TS 3.9.2(3)(a) and b) specify

quarterly direct radiation surveys for the restricted and the

unrestricted areas respectively.

The inspector reviewed the quarterly radiation surveys conducted in the .

restricted and the unrestricted areas of the facility for 1986. Also

weekly surface contamination surveys for the same period were reviewed.

All surveys were conducted at 100 percent power (100 kilowatts).

In

general, both radiation and contamination survey results were found to

be low,

i.e., less than 50 micro Roentgens per hour and less than

100 disintegrations per minute (dpm) removable.

No violations or deviations were identified.

b.

10 CFR 20.202 requires that appropriate personnel monitoring devices be

worn by personnel likely to receive exposure in excess of 25 percent of

the limits specified in 10 CFR 20.101 or who enter high radiation

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areas.- 110 CFR_20.101 specifies the' quarterly radiation exposure limits

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to the whole. body, skin _of the whole body, and extremities..-

During tours ,offthe facility, Ithe inspector; observed ' personnel

monitoring : devices. being.-worn. . The licensee used film badges supplied

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by- a = National- Voluntary Laboratory Accreditationf Program -(NVLAP) .

approved contractor. for measuring official dose.'

Beta,1 gamma ' and

neutron radiation was measured by these devices; Extremity rings were;

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'also'.provided by the licensee in the1 form of' TLD chips which.were

. processed by the contractor.

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The. inspector examined personnel exposure records from January 1 to

December 31,1986, and verified that exposures were- being maintained

below applicable . limits.

For 1986, the highest whole body exposures-

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were 590 and 560 millirem.

No. violations or deviations were identified.

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- c.

Technical Specification 6.3_ states that'the. facility shall be operated

and - maintained in accordance with approved, written procedures. to

. include personnel radiation protection procedures consistent with

applicable regulations.

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UFTR Procedure D.2,- Radiation Work Permit, Revision 9, May 16,- 1985,

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states:

(1)

In. Paragraph 7.1.3 ' that the radiation work permit (RWP) will be

logged in the UFTR Daily Operations Log as well as the index of

the RWP notebook normally maintained at the reactor console.

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(2)

In Paragraph 7.3.3 that RWP termination will be noted in the

reactor operations daily Log and in the index section of the RWP

notebook normally kept at the UFTR console.

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(3)

In Paragraph 7.2.1.5 that all RWP survey measurements must have

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the survey results, the instrument name, serial number, distance

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from the measured object and the name of the person carrying out

the survey and recording the measurements specified on the RWP

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form.

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(4) In Paragraph 7.2.1.11 that signatures of the Senior Reactor

Operator and the Reactor Manager or his designated alternate are

required for all Level I and Level II RWPs.

(5)

In Paragraph 7.3.1.4 that a RWP must be terminated when the RWP

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has been issued for seven days and not re-issued.

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The inspector reviewed selected RWPs written in 1985 and 1986.

RWPs

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were divided into two categories designated Level I and Level II.

Level I RWPs were intended for work which had the potential of causing

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contamination or radiation exposure 'in excess of 10 CFR 20 limits,

- while Level II" RWPs were written for work which had the potential of

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exceeding facility administrative limits.

In reviewing RWPs against-

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- the requirements _ specified by- UFTR Procedure D 2, it was noted that

administratively

RWPs were not always implemented as specified.

In

discussions ,with licensee representatives it was determined that_ no

index was maintained in a RWP Notebook at the UFTR . console or at any

other location for logging RWP initiation and termination is required.

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Additionally,: examination- of the UFTR daily operations log showed that

RWP No. 86-14-I had not been ; entered in the Log and that RWP

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Nos. 86-14-I and 86-12-II had not been terminated in the Log.

A' review of survey documentation on the RWP forms showed that :in

several Linstances _ during 1986 survey- data 'for _ the RWP had not been

recorded.

The inspector _also noted that none-of the RWPs initiated in

1986 had.the instrument name, serial number,' distance from the measured

object and name of the . individual performing the measurements specified

as required. A: licensee representative stated that survey measurements

were often- taken during the work activity and that upon occasion,

documentation of the instrument readings on RWP forms was overlooked.

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RWP Nos. 85-22-II, 86-7-I, 86-8-I and 86-17-II contained no survey _

results. .

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It was. also noted that during 1986, the initiating signature for all

RWPs was that of the Reactor Manager rather than two signatures as was

required by UFTR Procedure D 2._ In fact, the RWP form had a designated

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space for only a single approval.- A licensee representative stated

that while the procedure required two signatures, that it had not been

intended to be limiting in that manner.

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-UFTR Procedure D.2 also required that RWPs be terminated within seven

days after initiation.

A review of selected RWP records showed that

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RWP Nos. 86-10-I, .86-12-II and 86-14-1 had not been terminated as

required.

Failure to implement the requirements of UFTR Procedure D.2 was

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identified as an apparent violation of TS 6.3 (50-083/87-01-01).

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No deviations were identified.

d.

10 CFR 19.12 requires that each employee who works in or frequents the

licensee -restricted area be given instructions in radiation protection

commensurate with their duties and potential hazard.

The inspector reviewed the radiation worker course lecture notes and

selected examinations taken by individuals after training.

No violations or deviations were identified.

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e.

10 CFR 20.203 states the requirements for posting radiation areas, high

radiation areas and radioactive materials areas.

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During tours of the . facility, the inspector noted the posting .of

radiological areas and material, and verified by independent survey

that such areas were adequately posted.

No violations or deviations were identified.

f.

10 CFR 19.11 requires each licensee to conspicuously post current

copies of (1) 10 CFR Parts 19 and 20; (2) the : license; (3) operating

procedures; and (4) Form NRC-3, in sufficient places to permit

individuals engaged in licensed activity to observe them on-the way to

or from any licensed activity location.

If posting of the documents

specified in (1),-(2) and (3) is not practicable, the licensee may post

a notice which describes the document and states where it may be

examined.

During tours of the facility, the inspector noted a Fonn NRC-3 posted

on the bulletin board near the UFTR console; however, the other

documents specified by 10 CFR 19.11 were not observable nor was a

notice posted describing the, documents and their location.

The

licensee stated that the documents were not posted but were available

in the bookcase by the UFTR console.

Examination of the bookcase

contents showed that while the license and operating procedures were

available, 10 CFR 20 and 10 CFR 19 were not.

Failure to post the documents specified by 10 CFR 19.11 or a notice

which described the documents and states where they may be examined was

identified as an apparent violation of 10 CFR 19.11 (50-083/87-01-02).

4.

Transportation (86740)

a.

Fuel Shipment

On February 21, 1986, a shipment of unirradiated fuel plates composed

of 93% enriched uranium-235 was made using a D0T 6M Type B package.

The inspector verified that the licensee had an approved quality

assurance (QA) program and that other D0T requirements were met for the

shipment.

No violations or deviations were identified,

b.

Waste Shipment

10 CFR 71.5(a) requires that each ' licensee who transports licensed

materials outside the confines of its plant or other place of use shall

comply with the applicable requirements of the regulations of DOT in

49 CFR Parts 170 through 189.

49 CFR 172.200 requires that each person who offers a hazardous

material for transportation shall describe the hazardous material on

the shipping papers as required by 49 CFR Subpart C.

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49 CFR1172.504 requires that vehicles transporting Yellow Label III

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radioactive materials be placarded on 'each end and_ each side and in

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accordance with other placarding requirements of Subpart F including

the' specifications for the_ placards.

49 CFR~173.441(a). states that except as provided in 49 CFR 173.441(b),

each ' package of radioactive materials offered for transportation shall

be designed and prepared for shipment so that under conditions normally-

incident : to ' transportation, the radiation level does not exceed

200 millirem per hour (mrem / hour) at any point on the external surface

of the package.

A shipment of waste consisting of two 55= gallon drums (DOT 7A Type A

packages) was made from the reactor cell on December 9,1985.

The

waste was uncompacted trash and -equipment resulting from the repair of

the control rod blade mechanism.

The two drums were surveyed, placed

on an open pickup truck and transported several miles across campus to

the Radiation Control (RC) Building where waste is picked up by ~a

carrier for movement to a land disposal facility.

Direct radiation

levels on the two containers were documented as 150 and 800 mrem / hour.

Upon resurvey at the RC Building dose rates on the two drums were

documented as 210 and greater than 1,000 mrem / hour respectively.

The

package reading greater than 1,000 mrem / hour was reloaded in the pickup

truck and returned to the reactor cell where it had remained stored as

of this inspection. The. licensee stated that eventually _the drum would

be routed to a land disposal facility.

During discussions with licensee representatives the inspector

determined that the waste drums had not been transported in accordance

with 00T requirements in that:

(1) shipping papers for the radioactive

waste shipment had not been prepared (49 CFR-172.200); (2) the

vehicle transporting the Yellow Label III radioactive material had not

been placarded (49 CFR 172.504); and (3) dose rates on the external

surfaces of the package exceeded 00T limits of. 200 mrem / hour

[49 CFR 173.441(a)].

The licensee stated that transfer of waste from

the reactor to the RC Building had not been considered to come under

the authority of D0T since the vehicle primarily utilized roads through

the campus.

The inspector stated that while these roads traversed the

campus, they remained public roads in that they were utilized by the

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general public, and further, the pickup truck necessarily had to cross

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major city / state roads to reach its destination.

Failure to comply with D0T requirements contained in 49 CFR Parts 170

through 189 was identified as an apparent violation of 10 CFR 71.5(a)

(50-083/87-01-03).

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- Environmental'Prote'ction(80745)

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. Technical Specification 3.4.3 requires -the reactor . vent system. to be

operated until :the stack monitor indicates-less than 10 counts per second

(cps).

On December 12, 1986, the licensee notified Region II by phone'of a possible

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violation of TS 3.4.3 and submitted a detailed written report of the event

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on December -19, .1986.

On December 11, 1986, the stack dilute fan and-the

core vent fan (reactor vent sysem)' were secured by actuation of the

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evacuation alarm and 'the evacuation alarm / core vent system interlocks.

At the tine - the count rate in the stack was approximately 300 cps..

Actuation' of the evacuation alarm was a part of the quarterly evacuation

drill.

The' primary effluent at the facility is argon-41 which has a half-life of

approximately 110 minutes.

The Ar-41 inventory in the ' stack was due to a

. previous run since the reactor .was not operational at the time of the

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evacuation drill..

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Some time after completion of the quarterly evacuation drill, one of the

reactor personnel remembered the reactor run prior to the drill and checked

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the count rate (strip chart) in the stack at the time of the drill

300 cps (approxinately 1.65 X 10~gt time was determined to be approximately

initiation.

The count rate at th

uCi/ml, 15% of the steady state release

rate at 100 percent power).

This activity is well within permissible

release rates for the facility.

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The Reactor Safety Review Subcommittee (RSRS) Executive Committee met on

December 12, and the full RSRS met on December 19, 1986, to discuss this

event.

It was concluded that the event posed no potential for compromising

reactor safety or the health and safety of the public.

Corrective action

proposed by the licensee consists of assuring that the stack monitor reading

is below 10 cps prior to drill initiation which will be listed as a checkoff

item on the drill scenario card.

In addition, the licensee is pursuing a

change to the TS with regard to the 10 cps on the stack monitor and will

request that the requirement for not securing the reactor vent system above

10 cps become a recommendation rather than a requirement.

Such a change

would eliminate the conflict in securing the reactor vent system in the

advent of an actual emergency following a reactor run.

b

The licensee was informed that failure to operate the reactor vent system

until the stack monitor indicated less than 10 cps would norwelly be

considered a violation of TS 3.4.3.

However, the NRC Enforcement Policy,

10 CFR 2, Appendix C, 1986, states that a Notice of Violation will generally

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not be issued for violations identified by the licensee if:

(1) it was

identified by the licensee; (2) it fits in Severity Level IV or V; (3) it

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was reported, if required; (4) it was or will be corrected, including

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measures to prevent recurrence, within a reasonable time; and (5) it was not

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a violation that could reasonably be expected to have been prevented by the

licensee's corrective action for a previous violation.

The inspector

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informed the licensee that this apparent violation met - the criteria

specified in ' 10 CFR 2, : Appendix C,-- and would be considered -' licensee

identified.

The inspector stated that the implementation of the long term

corrective action would be rev_iewed during future inspections

.(50-083/87-01-04).