ML20209E827
| ML20209E827 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 08/25/1986 |
| From: | Copcutt B, Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8609110364 | |
| Download: ML20209E827 (4) | |
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I pAlb sy UNIVERSITY OF VIRGINIA ENVIRONMENTAL HEALTH AND SAFETY CAllATION SAFETY OFFICg a
SPECIAL MATERIALS HANDLING FACCITY hh,f ' '
d P.O. BOX 3425 BOX 262 - MEDICAL CENTER
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EDGEMONTROAD CHARLOTTESYlLLE VA.
2290s TELEPHON E: (804) 924 7334 CHARLOTTESVfLLE VA 22903 TELEPHONE (804) 924-7334 U.S. Nuclear Regulatory Commission Region II 101 Marietta Street Atlanta, GA 30323 Attn:
Mr. Roger D. Walker, Director Division of Reactor Projects SUBJ: Docket No. 50-62, License No. R-66
Dear Mr. Walker:
This letter is submitted pursuant to the provision: of 10CFR 2.201 in response to the Notice of Violation issued to ime Uni-versity of Virginia on July 30, 1986.
In this Notice, four violations were identified stemming from an NRC inspection at the University of Virginia Reactor Fccility on May 27 - 29, 1986.
Statements concerning each violation are presented below:
A.
The violation references the UVAR Standard Operating Proce-dures 10.4.B.4 (rev.
2/83) requiring that all non-controlled areas of the facility, including, but not limited to, representa-tive offices and classrooms shall be surveyed by the Reactor Health Physicist or his designee on a monthly basis.
The viola-tion states that "...the requirement to perform surveys in non-controlled areas of the reactor facility was not met in that during 1985, representative offices and classrooms were not sur-veyed."
The University of Virginia admits that this violation occurred.
The immediate cause of the violation was that the UVAR monthly radiation survey form did not specify that measurements be made in representative offices and classrooms.
The monthly survey included several exposure and contamination measurements made in hallways directly outside of offices and classrooms.
However, no measurements were made inside these areas.
The UVAR monthly radiation survey form has been amended to re-quire that exposure rate and contamination surveys be performed inside representative offices and classrooms.
In addition, in order to avoid further violations of this type, the UVAR S0P's are under review to assure that all health physics requirements are implemented in the routine health physics operations.
The facility is now in full compliance with this requirement.
B.
This violation states that "...
on February 11, 1985, and May 23, 1985, dose rates of 20,000 and 19,300 millirem per hour, 8609110364 860825 n
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Docket No. 50-62 FROM: University of Virginia License No. R-66 Page 2 respectively, were measured on gold-198 activated seeds using an instrument that was not calibrated for measurements on the 20 Roentgen per hour scale."
The University admits that this. violation occurred.
The staff member who made the measurements on the gold seeds mistakenly used an instrument that was not calibrated on its highest scale (20R/hr).
The instrument calibration label indicated that the instrument was not calibrated on the 20R/hr scale. Other instru-ments, calibrated on their higher scales, were available and should have been used for this measurement.
The measurement in question was made at contact with the unshielded gold seeds.
It should be noted that the measurement was not necessary for regu-latory compliance. The materials' activity was calculated from a measurement made at 1 meter from the unshielded source and compliance with DOT regulations was assured by measurement of the material in its shipping container.
These additional dose rate measurements were therefore adequate for evaluation of the radiation hazard associated with the material.
It is our feeling that this violation was caused by human error and is not indicative of other procedural or program problems.
Therefore, the corrective action taken has been to conduct a re-training seminar for the reactor facility staff emphasizing correct use of radiation measurement instruments. The University of Virginia is currently in full compliance in this area.
C.
This violation states that "... assurance that external radiation and contamination levels were within allowable limits was not obtained in that on August 20, 1985, a radioactive mater-ials shipment of pond water to an offsite contractor was made and no radiation or contamination surveys were performed."
The violation references 10 CFR 71.5(a) which requires compliance with applicable D0T regulations in 49CFR Parts 170 through 189.
Also referenced is 49CFR 173.475(i) which requires that "before each shipment of any radioactive materials package, the shipper shall insure by examination or appropriate tests that external radiation and contamination levels are within allowable limits."
The University of Virginia admits that this violation occurred.
The reason for this occurrance was that an assumption was made by the technician shipping the package.
The technician assumed that he could infer that no external exposure rates existed based on analysis of a sample of the material shipped.
The shipment consisted of 5,678 ml of pond water which contained less than 0.02 microcuries total activity (as determined by
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U.S. Nuclear Reg. Comm.
Docket No. 50-62 FROM:
University of Virginia License No. R-66 Page 3 counting on a low-background, hroportional counter).
The techni-cian also concluded that no external removable contamination was present on the pacLage since it had been prepared in a " clean" area (i.e. the Reactor Health Physics Office).
It should be,noted that the contents of the package had a specif-ic activity of less than 0.002 microcuries/ gram; and, therefore, as specified in 10CFR 71.10(a) would normally be exempt from all requirements of 10CFR Part 71 and would not fall under the defin-ition of " radioactive material" as specified in 10CFR 173.403(y).
.In ordertoavoidthksprobicminthefuture, a policy has been implemented whereby ALL radioactive packages, regardless of con-tents, are required to be monitored for external radiation levels and contamination levels.x This policy has been implemented through the use of a new worksheet for preparation of radioactive materials shipments and through training of the current Reactor HP technician. The Reactor Facility is currently in full compli-ance in this area.
9 D.
This violation states that "... instructions, procedures or drawings for activities affecting quality were not prescribed in that radioactive materials shipments for 1985 and 1986, were per-formed without procedures which prescribed activities affecting quality in the transportation of licensed material."
The violation references 10CFR 71.0(d) and 10CFR 71.111, Subpart H, as requiring the quality assurance activities cited above for the transport or shipment of licensed material.
The University of Virginia denies this violation on the basis of exemption frcm these requirements under 10CFR71.10(b) which states "A licensee is exempt from all requirements of this part other than 71.5 and 71.88 with respect to shipment or carriage of the following packages:
[1] A package containing no more than a Type A quantity of radioactive material if the package contains no fissile material or if the fissile material exemption stand-ards of 71.53 are satisfied; or [2]...".
All radioactive materials shipments from the Reactor Facility during 1985 and 1986 have met the criteria for exemption, except two shipments of spent reactor fuel elements and one shipment of unirradiated fuel elements.
The spent fuel shipments were per-formed according to instructions, procedures, and drawings spec-ifically approved for such shipments by the University of Virginia Reactor Safety Committee.
The shipment of unirradiated fuel was performed according tc instructions, procedures, and drawings con-tained in EGSG Idaho, Inc. Technical Report entitled " USA /57065/
AF (ERDA-ID) ATR Fuel Element Shipping Container Safety Analysis."
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Docket No. 50-62 FROM: University of Virginia License No. R-66 Page 4 Since tha NRC inspection of May 27-29, a decision has been made jointly by the University of Virginia Nuclear Engineering Depart-ment and Office of Environmental riealth & Safety to institute a search for a new Reactor Health Physicist.
The past Reactor Health Physicist was trained as a medical physicist and had not had previous experience at a reactor facility.
It was felt that the Reactor Facility health physics program could be improved if a suitable individual were found to be Reactor Health Physicist.
Also, HP Technician duties at the Reactor have been assigned to another Technician working for the U.Va. Environmental Health and Safety Office.
Currently the University Radiation Safety Officer is supervising the health physics program at the Reactor Facility. After hiring of a new Reactor HP, it is planned that this individual will take over operational responsibilty for the program on a full-time basis.
Sincerely, f- __
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Brian Copcptt Ph.D.
Radiation / Safe Officer Sworn to and s b:cftti t:' rs me thS dayof
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Witr my and r, c. ::;.si hb Md Nctary Public
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Robett Mulder, Ph.D.
Director, Reactor Facility My Commission Expires [f/2,gg[
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