ML20211B462

Responds to NRC Re Violations Noted in Insp of License R-103.Corrective Actions:Study to Determine Specific Survey Meters Best Suited for Monitoring Tm-170 Operations & Adoption of Procedure for Thulium Water Transfer Planned

ML20211B462
Person / Time
Site:	University of Missouri-Columbia
Issue date:	02/13/1987
From:	Brugger R MISSOURI, UNIV. OF, COLUMBIA, MO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
EA-86-191, NUDOCS 8702190419
Download: ML20211B462 (8)

Text

I Research Reactor Facility UNIVERSITY OF MISSOUAl g,,,,,cn p,,g February 13, 1987 cu a

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Submitted in Compliance with Hotice of Violation issued under 10 CFR 2.201 Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

Reference:

DOCKET NO. 50-186 LICENSE NO. R-103 EA 86-191 Gentlemen:

We have reviewed your letter of January 15,1987 (Notice of Viola-tion and Proposed Imposition of Civil Penalty). Our response enclosed with this letter was prepared af ter much thought and discussion with members of liURR staff who are involved with each violation and with members of management.

The !!URR staff and management are dedicated to operating the reactor to support the mission of research, education and service. These many operations are carried out safely with an emphasis on good radiation con trol .

Please contact us to resolve any question you may have.

Sincerel , 7 8702190419 870213 ,b g / / ' / /,4 PDR ADOCK 05000106 G PDR Qyg l , y?j&g/'

Robert fi. Brugger /

Director j OLO/mbs Enclosure cc: Regional Administrator U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road g Glen Ellyn, IL 60137 Qf y 91 El , lE h '

's 4 COLUMBIA KANSAS CITY ROLLA an equal opportunity institution ST. LOUIS

1 The Response of the Curators of the University of Missouri to Notice of Violation January 15, 1987 February 13, 1987

Reference:

Docket No. 50-186, License R-103, EA 86-191 I. VIOLATIONS ASSESSED A PENALTY A. 10 CFR 20.101(a) provides in part that no licensee shall use licensed material in such a manner as to cause an individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation a total occupational dose in excess of 18.75 rems to the extremities.

Contrary to the above, in June 1986 during the second calendar quarter of 1986, an individual who handled radioactive thulium-170 pellets in a restricted area received a dose of approximately 115 rem to the hands while transferring the pellets into a container for shipment.

RESPONSE

We have not been able to identify a specific step which we think did 1

occur in the thulium wafer transfer procedure which could have resulted in the apparent 115 rem exposure reported for the TLD finger ring which was I

worn on the right hand. However, we cannot identify any mechanism by which I

the finger ring could have been exposed or given a high reading. Therefore, we are proceeding by accepting the Commission conclusion that an apparent exposure did occur.

Sone deviation from the planned procedure which violated the distance and or shielding factors had to occur to cause an overexposure.

Upon receiving a phone report July 29, 1986 from our dosimeter vendor that a TLD finger ring had recorded 23.5 rem, the immediate corrective action was a verbal instruction by the Associate Director that the procedure would not be repeated until the event had been investigated. It has not been repeated since that time.

Also on July 29, 1986 a Committee to Review Unplanned Unusual Exposure was appointed as per Standard Operating Procedure HP-22. That committee held a meeting the following day to investigate the exposure event. August 20,

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l The Response of the Curators of the University of Missouri to Notice of Violation January 15, 1987

February 13, 1987 Page two 1986 the Commission was notified of the apparent overexposure by written notice.

I The corrective actions to avoid future violations are:

1. Complete a study to determine specific survey meters best suited for monitoring Tm-170 operations. j

2. Utilize work station equipment which provides the operator multiple I beta radiation shields, such as a thulium wafer holder designed to prevent significant beta radiation fields in any direction except out through a tool opening. l

3. Adopt a procedure for thulium wafer transfer which provides:

a. Calculation and review of expected dose rates from Tm-170 for the activity ranges and distances of concern.

) b. Specification of survey meters to be used for monitoring the t process.

! c. Evaluation of assignment and placement of personnel dosimeters for persons performing or monitoring the process.

d. Instruction of operators and surveyors concerning the assessment j of radiation hazards associated with the process prior to per-forming the work and subsequently repeated for any significant change in procedure.

, e. Guidance for the necessary record to be generated to comply with i

10 CFR 20.401(b).

Compliance with 10 CFR 20.101(a) was achieved on July 29, 1986 by prohibiting additional performance of the procedure. The corrective actions a will be completed before the process is again performed.

i

The Response of the Curators of the University of Missouri to Notice of Violation January 15, 1987 February 13, 1987 Page three B. 10 CFR 20.201(b) requires that each licensee make such surveys as (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.

Contrary to the above, in July, August, and October 1985 and June 1986 the licensee failed to adequately perform such surveys (evaluations) as were necessary to ensure compliance with 10 CFR 20.101. Specifically, during the above time periods, the licensee failed to adequately evaluate the potential personnel exposures associated with the handling of curie quantities of thulium pellets. The licensee did not perform exposure rate calculations and preoperational dry runs. Furthermore, the licensee did not satisfactorily evaluate extremity dosimetry placement to ensure that the researcher's extremity exposure was adequately monitored.

RESPONSE

Since an overexposure could have occurred, adequate evaluations were not performed for the thulium transfer procedure.

When performing experimental operations with radioactive materials there is an element of danger in relying too heavily on assumptions made during planning sessions. Therefore, we depend to a considerable degree on the significance of data obtained by monitoring the work in progress. For the thulium wafer transfer procedure a more specific evaluation, namely, calculating exposure values and informing the surveyors of their signifi-cance in advance, would have enabled them to recognize failure of the survey meter to respond with the correct rem value.

Cessation of the procedure as stated for I.A. above also prevented i

additional violations for this item.

• i The corrective actions stated for I.A. above also apply to this item for avoiding further violations.

The Response of the Curators of the University of !!issouri to Notice of Violation January 15, 1987 February 13, 1987 Page four Compliance with 10 CFR 20.201(b) was achieved on July 29, 1986 by prohibiting additional performance of the procedure. The corrective actions will be completed before the process is again performed.

II. VIOLATIONS NOT ASSESSED CIVIL PENALTIES A. 10 CFR 20.401(b) requires that records be maintained showing the results of surveys required by 10 CFR 20.201(b). 10 CFR 20.201(b) requires surveys be made as necessary to comply with the regulations in Part 20 and are reasonable to evaluate the extent of radiation hazards that may be present.

Contrary to the above, as of the inspection on August 26, 1986, survey records were not maintained for the July 1985 thulium pellet handling

! cperation, and incomplete records were maintained for the August and October 1985 and the June 1986 thulium pellet handling operations.

Furthermore, the survey results for the June 1986 operations were recorded from menory in August 1986, and measured dose rates by the licensee documented on Radiation Work Permits were several orders of magnitude lower than the radiation fields that should have been expec ted.

j RESPONSE It is agreed that complete survey records were not maintained for the l

Tm-170 transfer operations.

l It has been a practice at MURR to consider Radiation Work Permits to be a survey record in compliance with 10 CFR 20.401(b). A review of the l

records for the thulium operations leads to a conclusion that a more com-l l

plete record should have been generated.

l Because the process has not been performed since the June 1986 opera-l tion no further violations have occurred.

l To avoid further violations for this item a more specific record proce-j dure for the thulium wafer transfer process will be defined and put into practice as stated in corrective action 3.e. in response to violation I.A.

l t

l

The Response of the Curators of the University of Missouri to Hotice of Violation January 15, 1987 February 13, 1987 Page five Compliance with 10 CFR 20.401(b) was achieved on July 29, 1986 by prohibiting additional performance of the procedure. The corrective actions will be completed before the process is again performed.

B. 10 CFR 20.405(a) provides in part that, within 30 days, each licensee make a written report to the Commission concerning each exposure to radiation in excess of the applicable limits in 10 CFR 20.101 or 10 CFR104(a) or in its license.

10 CFR 20.405(a)(2)(iii) and (iv) require that each report under 20.405(a)(1) must describe the cause of the exposure and corrective steps taken or planned to prevent recurrence. 10 CFR 20.405(b) requires that any report filed with the Commission pursuant to 20.405(a) include, among other information, the social security number and date of birth for each individual record.

Contrary to the above, the August 20, 1986 licensee extremity exposure report submitted to the Commission in accordance with 10 CFR 20.405(a)(1) did not describe the cause of the June overexposure to the hand of a researcher or corrective steps taken or planned to prevent recurrence and did not include the social security number and date of birth for the individual exposed.

RESPONSE

The referenced report did not comply with the requirements of 10 CFR 20.405(a)(1).

A statement about cause of the exposure was omitted because the cause i

of the exposure had not been satisfactorily identified at the time of l

writing the letter. The immediate correction action upon learning the TLD l

ring recorded exposure value was to prohibit further processing until reso-lution of the problem. However a statement about cause and corrective l action should have been put in the letter. The birthdate and social security number were inadvertently omitted when the final copy was prepared from a draf t copy.

The Response of the Curators of the University of Missouri to Notice of Violation January 15, 1987 February 13, 1987 Page 6 Effective immediately such reports will be edited by a second person prior to mailing. Therefore we consider ourselves to be in compliance for this item with the submission of the report.

C. 10 CFR 71.5(a) requires each licensee who transports licensed material outside the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, to comply with the applicable requirements of the regulations appropriate to the mode of transport of 00T in 49 CFR Parts 170 through 139.

49 CFR 172.203(d)(fii) requires the description for a shipment of radioactive material to include the activity contained in each package in terms of curies, millicuries, or microcuries.

Contrary to the above, on June 10, 1986 the licensee failed to include the correct activity of thulium pellets contained in a shipment to Lixi, Incorporated in Downers Grove, Illinois. Specifically, the shipping paper listed the cumulative thulium activity as 4.0 curies when the correct activity was later determined to be 9.0 curies, 25%.

RESPONSE

The activity recorded on documents for the referenced thulium shipment was not correct.

, We have determined that an incorrect activity was obtained verbally by the person who released the shipment under our Standard Operating Procedure l

l HP-16, Surveying Containers of Radioactive Materials for Transport by Common I

Carrier.

No further shipments of thulium wafers have been made since the refer-enced shipment, therefore no further violations have occurred.

l For future shipments violations will be avoided by changing S0P HP-16 to require the package surveyor to obtain the activity from a written j document prior to releasing the package for shipment. The written document is normally in a shipping folder which is the record for each individual l

t

The Response of the Curators of the University of filssouri to Notice of Violation January 15, 1987 February 13, 1987 Page seven shipment. If the statement does not exist the surveyor will not release the package for shipment until such a statement is prepared for the record.

Compliance with 10 CFR 71.5(a) was achieved on July 29, 1986 by prohibiting additional performance of the procedure. The corrective actions I will be completed before se process is again performed.

Respectfully submitted, The Curators of t'he University of lif ssouri

/

by I'( . 0'!L Robert M. Brugger

. lithh%/

/ Ay0y'[D Director V g AFFIDAVIT [

STATE OF filSS00RI)

)ss.

4 COUNTY OF BOONE )

i Robert M. Brugger, first being duly sworn, on his oath states: That he

is the Director of the Research Reactor Facility of The Curators of the University of Missouri, a public corporation of the State of Missouri, and as such officer is duly authorized to make this affidavit on behalf of said public corporation; that the facts contained in~the foregoing Response are true to his best belief and knowledge. ,f l _. / /. s f(L Qv h /

Robert M. Brugger Of({Cg/

i

, b' s/ -

Subscribed and sworn to before me this /F4 day of February, 1987.

/ M "b" aren VenianBinaHom My Commission expires: 'L - 2. /- 9 7 Notary Puh!ic Stoic cf Missouri My Ccmnnsuco Expkes 2-21-87 County of Bocne

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