ML20207T362
| 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: |
| References | |
| 50-083-87-01, 50-83-87-1, NUDOCS 8703230480 | |
| Download: ML20207T362 (8) | |
See also: IR 05000083/1987001
Text
-- '
K., .
, .,- ,
J s
- - ,
~
.
- Mou UNITED STATES
.
/3 ' jo,p -
NUCLEAR REGULATORY COMMISSION
1
[.
g.
-
j
REGION 11
101 MARIETTA STREET,N.W.
- *
t -
ATLANTA, GEORGI A 30323
g ***** f 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
Inspector: % NO!d )-
-B. K.-Revsin, 1
Date Signed
Approved by: fd-TA
C.M. Hose'y,SectipnChief
2/l3!dl
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. _
,
' '
-
8703230480 870220
PDR ADOCK 05000083
G PDR
.
.
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)
.were discussed in detail.'. Licensee management acknowledged the findings and.
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
swipes in the reactor area shall
cell weekly. be measured
TS 3.9.2(3)(a) andby(taking random
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
f
. . .. . .. - -. .~ . . . . -
,
T-
<0
,
..
.
2
- areas.- 110 CFR_20.101 specifies the' quarterly radiation exposure limits
-
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
' '
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;
~
.
'also'.provided by the licensee in the1 form of' TLD chips which.were
. . processed by the contractor. -
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- >
were 590 and 560 millirem.
No. violations or deviations were identified.
'
- 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
4
applicable regulations. '
c UFTR Procedure D.2,- Radiation Work Permit, Revision 9, May 16,- 1985,
i- 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.
(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.
(3) In Paragraph 7.2.1.5 that all RWP survey measurements must have
[ the survey results, the instrument name, serial number, distance
from the measured object and the name of the person carrying out
'
'
E the survey and recording the measurements specified on the RWP
form.
[
l (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
has been issued for seven days and not re-issued.
,
i
The inspector reviewed selected RWPs written in 1985 and 1986.
'
were divided into two categories designated Level I and Level II.
.
Level I RWPs were intended for work which had the potential of causing
l
'
!
4: . - , . .-_ _ . _ . .. . . ,. . . _ _ . - _ _ , _ _ , .._.___..__..._..-...., _.-_ _ ._
. . . . . - _ - . - -, , -
A
e
,
.
,
.
3
.
o
contamination or radiation exposure 'in excess of 10 CFR 20 limits,
- while Level II" RWPs were written for work which had the potential of
exceeding facility administrative limits. In reviewing RWPs against-
'
- _
- - 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.
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
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.
'
,
RWP Nos. 85-22-II, 86-7-I, 86-8-I and 86-17-II contained no survey _
'
, results. .
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
-
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.
-UFTR Procedure D.2 also required that RWPs be terminated within seven
days after initiation. A review of selected RWP records showed that
.
RWP Nos. 86-10-I, .86-12-II and 86-14-1 had not been terminated as
- required.
t
Failure to implement the requirements of UFTR Procedure D.2 was
identified as an apparent violation of TS 6.3 (50-083/87-01-01).
,
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.
f e. 10 CFR 20.203 states the requirements for posting radiation areas, high
j= radiation areas and radioactive materials areas.
.
t
.
- v -t -, mr- e 4 .r-r-r m ne ,r,ee,,-+-,w-w r,w--r,,,, w e-- ee - w cw r ws e ws. r -,,.e + w i r -,w~,-wwin,-w-.,w,,,.ww.-r,-,e-e.*,-w----n,-1,-wm, ,,---v---, rwn,
~
.
4
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.
.
5
49 CFR1172.504 requires that vehicles transporting Yellow Label III
radioactive materials be placarded on 'each end and_ each side and in
.
'
'
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
j general public, and further, the pickup truck necessarily had to cross
!. 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).
1
>
i
. , . . ..- . . . . . .. ._
1"L
- .
M} ,
.
6
4
i
- 5. - Environmental'Prote'ction(80745)
>
. 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
violation of TS 3.4.3 and submitted a detailed written report of the event ,
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
'
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
^
evacuation drill..
I Some time after completion of the quarterly evacuation drill, one of the
4
reactor personnel remembered the reactor run prior to the drill and checked
the count rate (strip chart) in the stack at the time of the drill
initiation. The count rate at th
300 cps (approxinately 1.65 X 10~gt uCi/ml, time was
15% of determined
the steady state to be approximately
release
rate at 100 percent power). This activity is well within permissible
,
release rates for the facility.
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
not be issued for violations identified by the licensee if: (1) it was
4 identified by the licensee; (2) it fits in Severity Level IV or V; (3) it
'
was reported, if required; (4) it was or will be corrected, including
'
measures to prevent recurrence, within a reasonable time; and (5) it was not
a violation that could reasonably be expected to have been prevented by the
licensee's corrective action for a previous violation. The inspector
!
4
+ .m. ,. r. -..._,--....,r. ,..-.~e. ,. ,,..._,,_...,.,-.,_,m-~,-_m--~___-,m -.___,_-,_m- - _ - . . .
,
..
7
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).