ML20209F976
| ML20209F976 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 04/28/1987 |
| From: | Fisher W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Richardson H TEXAS A&M UNIV., COLLEGE STATION, TX |
| References | |
| NUDOCS 8704300438 | |
| Download: ML20209F976 (2) | |
See also: IR 05000128/1987001
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APR 281987
In Reply Refer To:
Docker: 50-128/87-01
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Texas A&M University
ATTN: Dr. Herbert H. Richardson, Director
Texas Engineering Experiment Station
College Station, Texas 77843
Gentlemen:
-Thank you for your letter of April 8,1987, in response to our letter and the
attached Notice of Violation dated March 11, 1987. Your response was also
discussed during a telephone conversation on April 10, 1987, between your
Dr. J. A. Reuscher and Mr. H. D. Chaney of this office. As a result of our
review, we find that additional information is needed. Specifically, we need
copies of your records that will substantiate your position that the bromine
experiment was reviewed by the Nuclear Science Center staff before the bromine
was irradiated in the reactor.
Please provide the information within 15 days of the date of this letter.
Sincerely,
MWB:
Y
WILLIAM L FISHER
William L. Fisher, Chief
Radiological and Safeguards Programs
Branch
cc:
F. E. Vandiver, President
Texas A&M University
College Station, Texas 77843
M. E. McLain
Radiation Safety Officer
Texas A&M University
College Station, Texas 77843
F. Jennings, Chairman
Reactor Safety Board
Texas A&M University
College Station, Texas 77843
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Texas Bureau of Radiation Control
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Austin,-Texas 78756
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W. L. Fisher
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TEXAS ENGINEERING EXPERIM ENT STATION
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TEXAS A&M UNIVERSITY
COLLEGE STATION, TEXAS 77843-3575
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NUCLEAR SCIENCE CENTER
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Mr. Robert D. Martin
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Regional Administrator
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Dear Mr. Martin:
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Reference: Docket 50-128/87-01
The following is in response to the USNRC Region IV letter of 11 March 1987 re-
garding violations of NRC requirements identified by Mr. H. D. Chaney of your
office during an inspection of NSCR activities conducted on 12-14 January 1987.
1.
Failure to Evaluate Reactor Experiment
The management of the NSCR contends that the Bromo-Phenanthrene experiment of
18 December 1986 was properly reviewed and approved for irradiation under
Experiment Authorization E-1 "In-Pool Irradiations" (attached) with maximum
credit given to the design safety features of the long tube irradiation device
and the recognized relatively small total activity of 40 millicuries of e28r
gaseous activity (reference letter of 27 January 1987 from NSC Director to
USNRC Region IV).
In addition this experiment was reviewed in detail con-
cerning processing and packaging of the sample for delivery to the experi-
menter.
These detailed procedures are documented in NSCR Staff Meeting #374.
The development of procedures to prevent an accidental release during the
processing of the Bromo-Phenanthrene was of much greater concern than an
accidental gaseous release to the pool water during irradiation.
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RESEARCH AND DEVELOPMENT FOR MANKIND
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Contrary to the stated violation of Technical Specification 6.3.3(a), an
experiment of this type is evaluated against 3.6.3(b) which states:
"In calculations pursuant to 3.6.3(a), the following assumptions
shall be used":
(1)
If the effluent from an experimental facility exhausts through a
holdup tank which closes automatically on high radiation level, at
least 10% of the gaseous activity or aerosols produced will escape.
(2)
If the effluent from an experimental facility exhausts through a
filter installation designed for greater than 99% efficiency for
0.3-micron particles, at least 10% of these vapors can escape.
(3)
For materials whose boiling point is above 130 F and where vapors
formed by boiling this material can escape only through an un-
distributed column of water above the core, at least 10% of these
vapors can escape.
It is difficult to imagine that under the allowed conditions of 3.6.3(b) or
even a 100% release the resulting radiological consequences would be in excess
of the Design Basis Accident for the NSCR or for previously evaluated releases
of several curies of "3Ar.
It should also be noted that the W C values for
82Br are essentially the same as those for "3Ar as indicated in Appendix B of
A recent evaluation of 82Br accidental releases indicate that a re-
lease to the reactor building of approximately 100 curies over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period
would result in a 1 W C-Yr exposure to a radiation worker. For a release to
the site boundary from the exhaust stack, a 595 curie release over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> re-
sults in a 1 W C-Yr exposure. These values clearly demonstrate the orders of
magnitude difference in the 40 millicuries of a:Br gas when compared to
analyzed incidents.
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Immediate Corrective Action
Regarding the processing of Bromo-Phenanthrene in a toluene base and the con-
tamination incident of 12 December 1986, there is a suspension of this type of
experiment until new procedures are developed. Although the incident resulted
in contamination of personnel and the facility, the exposures were minimal
and releases did not approach reportable levels. USNRC Region IV and
the Texas State Department of Health were notified, however, and informed of
the events that followed the incident. A detailed report was issued to the
TAMU Radiological Safety Officer indicating a resulting whole body burden of
less than 1 mrem maximum among the four involved individuals.
The actions
taken by the NSC Senior Health Physicist with help from the TAMU Radiological
Safety Office were proper and highly comendable. The Chairman of the Reactor
Safety Board assigned Dr. Fred Sicilio of the TAMU Chemistry Department to
review the procedure for the handling of the toluene base Bromo-Phenanthrene
experiment. Several suggestions were made by Dr. Sicilio.
Future Corrective Action
New handling procedures will be developed for the processing of Bromo-
Phenanthrene incorporating Dr. Sicilio suggestions.
To improve the
review and approval of the irradiation samples that contain gaseous
activity, the NSC staff will consider an addition to SOP's which will
provide isotopic maximum curie content values of gaseous releases such
that when averaged over a year would not exceed the limits of Appendix
B of 10CFR20.
Compliance Date
The recent evaluation of a Br against Technical Specification 3.6.3 has been
performed and the results mentioned earlier in this report.
It was known in
advance that several curies of e2Br activity would be the resulting maximum
values.
Evaluations of experiments against 3.6.3 will continue to be made
using sample activity, encapsulation, and processing requirements as guide-
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lines to determine if detailed review is needed.
It is very important that
the policy of blanket approval of experiments be permitted not only for the
NSCR but for all research reactors.
It is not practical to provide detailed
evaluations for the thousands of samples irradiated in a single year of opera-
tion (face samples, rotisseries, pneumatic tube samples, etc.). This has
been the policy at the NSCR for over 25 years of safe operation with no re-
leases off-site of any consequence.
2.
Failure to Implement the Emergency Plan
Management agrees that the emergency support agreement letter with the St.
Joseph Hospital of Bryan, Texas had expired on 31 December 1986 and had not
been renewed at the time of inspection. Contrary to requirements of having
a signed agreement letter on file, the absence of such a document did not
result in the NSCR losing the support of St. Joseph Hospital which is really
of main concern.
The agreement letters and emergency training for support of
radiological events are obtained by the TAMU Radiological Safety Office and
the agreements cover University activities involving radioactive materials,
the AGN-201 reactor, the NSCR and the Cyclotron Institute.
Immediate Corrective Action
The Radiological Safety Office was notified of the expiration of the agree-
ment letter with St. Joseph Hospital and the RSO set out immediately to obtain
the agreement.
There was difficulty in getting a timely response from the
responsible St. Joseph administrator. This problem was explained in a memo-
randum from the RSO to the Director of the NSC.
The memorandum is attached.
Ironically while waiting on the hospital administrator to provide a signed
agreement, staff of the hospital were actively participating in the biennial
emergency exercise conducted on 4 March 1987.
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To circumvent the problem of obtaining signatures to agreements, it was
decided to negotiate an open renewal agreement to remain in force unless
terminated by either party to the agreement.
A request to change the NSCR
emergency plan to accommodate such agreements was denied by the USNRC
Standardization and Special Projects Directorate. However, two year
agreements are permitted and this change to the approved emergency plan will
be made and reported under 10CFR50.54(q).
Future Corrective Action
As stated in the RSO memorandum, future plans are to enter into agreement with
the new Humana Hospital in College Station, Texas as soon as possible. Future
agreement letters with the City of College Station for fire and emergency
medical support will be reviewed and renewed on a two year basis to coinside
with biennial emergency exercises.
Date of Compliance
An agreement letter with St. Joseph Hospital has been obtained which will
satisfy emergency hospital support requirements until an agreement is reached
with the new Humana hospital in College Station, Texas.
3.
Open Item: Potential Uncontrolled Drain Path From Radioactive Effluent Tank
The auxiliary liquid waste tank in question is normally empty and not on line
to the liquid radioactive waste sump pumps in the demineralizer room. There
is a small misunderstanding in Mr. Chaney's description for use of the tank.
Domestic water is sometimes stored in the tank to provide a supply for cooling
tower makeup or other uses rather than the stated use of reactor grade water.
The auxiliary tank is sometimes used to store reactor pool water if the stall
portion of the pool is drained.
The pool water is later returned to the pool
by way of the mixed bed demineralizer. Pool water is never used for cooling
tower makeup water.
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In reference to the installation of a drain valve to handle domestic water
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stored in the tank, its accidental failure would produce the same result as
failure of the tank sampling valve.
Both valves are located at the bottom
level of the tank. Thus installation of the special drain valve does not
present a hazard not previously reviewed in the SAR or SOP's.
The sample valves for the liquid waste tanks are not described in the SAR
but are in SDP VII, Figure VII-C-6.
Installation of the valve has been
reported under 10CFR50.59 in the 1986 NSC Annual Report issued March 1987.
Changes to S0P VII involving the drain valve on the auxiliary tank will be
made at the next Reactor Safety Board Meeting. Since the valve presents
no additional potential hazard, it will remain on the tank but its output
will be plugged to prevent an accidental draining of the tank if it is in
use.
4.
Open Item:
Radioactive Material Control
In reference to the control of radioactive materials within the reactor
building and the facility site boundary, a meeting of NSC and RS0
adninistrators was held shortly following the USNRC Region IV inspection.
The meeting was called to discuss licensing options that could be considered.
The chairman of the Reactor Safety Board was informed of the options and in
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turn suggested to the Licensee that the matter receive additional study.
At
present the NSC is waiting to receive requested licensing information from the
Texas State Department of Health. Hopefully this matter can be resolved with-
out undue burden on reactor operations or the Health Physics program at the
NSCR.
Respectively submitted,
Donald E. Feltz
Director
DEF/ym
Enclosure
cc:
H. H. Richardson, Director, Texas Eng. Experiment Station
F. Jennings, Chairman, Reactor Safety Board
M. E. McLain, Radiological Safety Office
K. L. Peddicord, Head, Nuclear Engineering Dept.
J. A. Reuscher, Director, Nuclear Research Reactor Programs
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A&M
UNIVERSITY
COLLEGE STATION, TEXAS 77843
officr of
March 25, 1987
RADIOLOGICAL SAFEn
(409)S45-1361
MEM0 RAN D UM
TO:
Mr. Don Feltz
Nuclear Science Center
Texas A&M University
THRU:
Dr. Milton
E.
McLain
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Director, Radiological Safety Office
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Texas A&M University
FROM:
Mr. John
E.
Simek
Radiological Safety Office
Texas A& M Universi ty
Request for signed letters of agreement from the
Associate Administration of St. Joseph Hospital, Bryan, Texas
have been submit ted-in a tim ely m anner each year.
The return of
such documents in a timely manner has not been an annual * event.
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As there is now under construction a new hospital in
College Station which will be closer and will also have a nuclear
medicine department , it is the intent of the Radiological Safety
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Office to request that the Reactor Safety Board petition Texas
A&H University to enter into an agreement of support with the new
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Humana Hospital, the opening date of which is scheduled for the
middle of April this year.
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All requirements of coordination and training would be
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as required under the existing agreement.
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The results of this proj ec ted change in support to an
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emergency shall be forwarded to Region IV upon completion of the
decision making process.
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All efforts short of bodily harm shall be continued to
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secure a copy of a signed letter of agreement from St. Joseph
Hospital.
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Form 111
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Rev 1/85
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EXPERIMENT AUTHORIZATION
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E.A. No.
IN-P0OL 1RRADIATIONS
TITLE:
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J/J2d/fG
1.
STAFF REVIEW
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Date
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2.
REACTOR SAFETY BOARD REVIEW -- The hazards associated with this experiment
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have been reviewed by the Reactor Safety Board.
It is determined that this
experiment does not increase the probability of occurrence of an accident
previously analyzed in the Safety Analysis Report, and does not increase
the possibility that an accident or malfunction of a different type than
any evaluated previously will be created.
Approved:
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Chairman,RSB(/
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Date
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EXPERIMENT AUTHORIZATION
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Director, NSC
~ Date
Approval sheet format revised 1/85 - Original authorization was OcIob& 2N,1980
and approval sheets are on file.
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SATETY EVALUATION OF IN-POOL IRRADIATIONS
1.
Scope of Authorization
This authorization covers the irradiation of materials positioned
in .the NSCR pool within or near the reactor core for the production of
radioisotopes or exposure to radiation.
The production of any radioiso-
tope in the periodic table is authorized.
2.
Description
Typical experiments covered by this authorization involving the
irradiation of materials in the reactor pool using the NSCR as the radi-
ation source are as follows: face samples, rotated samples (rotisseries),
dry tubes, samples positioned in core reflector vacancies, samples
positioned in fuel vacancies, samples positioned in water spaces between
fuel elements, and samples positioned at selected distances from the
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reactor core to establish gamma and neutron radiation exposures. Most
samples require encapsulation in water tight containers.
Loading of
the experiment into the reactor is through the pool surface or in dry
tubes at the reactor bridge.
3.
Safety Discussion
Past experience has shown that samples may be safely irradiated in
many different types of encapsulating devices. The devices most commonly
used are metal tubes with Swagelok fittings, heat sealed polyethylene s
tubes, aluminum rotisserie containers with rubber o-ring seals, welded
containers, and aluminum cans. These have provided adequate sample
encapsulation to prevent contamination of the pool or work areas when
used in accordance with the conditions listed in section 4.
Other
sample containers have also been safely used, which again are in accor-
dance with the conditions listed in section 4.
The pressure produced
inside the encapsulation device is censidered in the design of all
containers.
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4.
Conditions, Limitations and Restrictions
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Samples will be encapsulated as necessary to prevent contamination
of the NSCR pool. Approved encapsulation devices include, but are not
limited to, those listed in section 3.
Any encapsulation device must
be reviewed and approved by the staff of the NSC.
Samples which will
not cause pool contamination may be irradiated without encapsulation,
an example of which would be non-corroding flux wire.
Samples will
be prepared and handled in accordance with S0P IV-A, IV-B, and IV-G.
The following technical specifications apply to this authorization:
1.9, 1.10, 3.6, 4.3.lb, 4.3.5, 6.la, 6.2d, 6.5, 6.6.
Sample loading
and unloading into the NSCR will be coordinated by operations personnel
to minimize any unexpected reactivity changes.
5.
Conclusions
The hazands associated with the production of radioisotopes and
radiation exposure experiments conducted in the NSCR pool have been
reviewed by the staff of the NSC and it was concluded that t,his
authorization does not constitute a change in the Technical Specifi-
cations, is not an unreviewed safety question, and will not increase
the probability of an accident previously analyzed in the Safety
7AnalysisReport.
It will not increase the possibility that .an accident
or malfunction of a different type than any evaluated previously will be
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created, and it will not reduce the margin of safety as defined in the
bases for any Technical Specification.
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