ML20211B499

Requests Mitigation of Proposed Imposition of Civil Penalties Noted in Notice of Violation.Info Re Prompt Identification & Reporting,Corrective Action to Prevent Recurrence & Past Performance Noted in Support of Request

ML20211B499
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 8702190430
Download: ML20211B499 (5)

Text

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e Research Reactor Facility UNIVERSITY OF MISSOURI Research Park February 13, 1987 '

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, fs'$$$}i Submitted in accordance with 10 CFR 2.205 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

Subject:

Request to mitigate the proposed civil penalties Gentlemen:

We have submitted a response to abe.e referenced Notice of Violation and Proposed Imposition of Civil Penalty. We wish to submit tiie following InTormation in request for mitigation of proposed civil penalties in accordance with 10 CFR 2.205.

The above referenced Notice of Violation and Proposed Imposition of Civil Penalty proposes two civil penalties of $2,000 each for which we are requesting mitigation. In accordance with Section V.B. of 10 CFR 2 Appendix i C, the following information is submitted.

$e Violation I. A. of referenced report involving

@ a dose of approximately 115 rem extremity oc exposure contrary to 10 CFR 20.101(a)

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1. Prompt Identification and Reporting S@O Identification of the apparent overexposure was by phone call from our y dosimeter vendor on July 29, 1986. Reports were sent by i1VRR to the om Commission within the 30-day period required by 10 CFR 20.405.

S$e Sep tember 12, 1986 our dosimeter vendor reported an increase in dose value for the TLD finger ring from 23.5 rem to 115 rem. Compliance with 10 CFR 20.403(a)(1) was achieved that day by mailgram and phone g call to your Region III office. Letters were mailed October 7,1986 to k/ W a/

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A IN f COLUMBIA KANSAS CITY ROLLA ST. LOUIS 7 h an equal opportundy institution l

Nuclear Regulatory Commission February 13, 1987 Page two comply with 10 CFR 20.405(a)(1)(V) confirming the reported increase in dose. The one previous overexposure event at MURR occurred November 8, 1979. This event was reported promptly by MURR by a letter to Region III Office of Inspection on November 30, 1979 before the data available had clearly identified the event as an overexposure.

2. Corrective Action to Prevent Recurrence Immediately after receivin'g the phone call from our dosimeter vendor July 29, 1986 reporting the apparent overexposure the Associate Director announced that the thulium wafer process would not be repeated until resolution of the problem. On the same day the MURR Procedure HP-22 Committee to Review Unplanned Unusual Exposure was activated.

The committee met the next day to begin its investigations.

The thulium wafer process has not been repeated since July 29, 1986.

3. Past Performance No previous extremity overexposures have occurred at MURR. However, for a wholebody exposure event which occurred November 8,1979 the event was promptly reported as stated in Item 1 above. Corrective actions for that event included adding a requirement to Reactor 10 MW S0P Volume 1 Section I.4.3.(I) and (J) which provides for coordination of Control Room Operations and Health Physics surveyors who survey beam ports during reactor start-up. In addition, Procedure HP-29 Health Physics Monitoring of Beam Ports for Reactor Start-up was initiated to assure correct Health Physics performance. These measures have been very effective in that no significant exposure has been received by beam port surveyors since the November 8,1979 event.

To address a need for better neutron dosimetry July 1980 Landauer H type film badges were replaced by Landauer C-1 tyr2 Ladges which exhibit minimal fading of neutron data and are morc W sitive to neutrons.

As part of a continuing effort to impiov @" >n dosimetry and address the need for more accurate surveying 01 neuttu exposure levels a neu-tron spectrometer (Ludlum Model 42-5) was purchased. Then a graduate studen+, was funded by MURR to develop an operating manual specific for the neutron spect.rometer at MURR. May 1982 James Dwight Sohl, Jr.

submitted a theris Experimental Benchmarking of the Bonner Spheres Spectrometer Using Filtered Beams which provided an operating procedure and necessary computer codes to reduce the spectrometer data to rem exposure values. In August 1984 we added more beam port monitoring capability by putting an Eberline PNR-4 neutron survey meter into service.

A continuing ALARA effort results in exposure control for all opera-tions. A few accomplishments are listed for your information. In the Reactor Operations Annuel Report August 1982 we reported an expenditure

Nuclear Regulatory Commission February 13, 1987 Page three of $28,000 on nine specific items which reduce MURR exposure an esti-mated 9 man / rem per year. Also during 1985 and 1986, to maintain good radiation control in radiopharmaceutical laboratories, we have provided radiation workers with three additional laboratory rooms, three new gloveboxes,1/4 inch lead shielding on four gloveboxes, six new plexi-glass beta shields, and developed special procedures for greater shielding of hands when working with Yttrium-90 microspheres. We have developed and put into use a tool to open quartz sample irradiation vials with greater safety. To date, five of the tools have been put into use.

In the reactor services area we have put into use a new aluminum sample can opener to remotely open large sample cans with a minimum of expo-sure to the worker.

University auditors, American Nuclear Insurers inspectors and NRC inspectors routinely indicate Health Physics operations at the MURR are good quality. We take their suggestions seriously to continually improve radiation control.

A recent news release quotes an NRC public relations office as saying that MURR's Health Physics program "is above average". We value that comment from NRC and reporters highly and use it to inspire MURR staff to maintain a good public image.

4. Prior Notice of Similar Events No prior notice of event had occurred.

5. Multiple Occurrences There have not been multiple occurrences. The thulium wafer transfer process is unique at MURR. No other samples are processed with such a high beta exposure level and such a low gamma level. Previous thulium transfer operations were exploratory to learn how to process the thulium safely and efficiently.

Violation I.B. of referenced report involving apparent failure to perform adequate surveys contrary to 10 CFR 20.201(b)

1. Prompt Identification and Reporting Identification of this failure was made by the Committee to Review Unplanned Unusual Exposure on July 30, 1986, the day af ter our dosi-meter vendor called that the TLD finger ring had recorded 23.5 rem dose. Recommendation (3)(b) of the Committee reads " Create dose rate

U.S. Nuclear Regulatory Commission February 13, 1987 Page four map of transfer table to assist in evaluating accumulated dose during the evolutions." The Committee met again August 6,1986.

2. Corrective Action to Prevent Recurrence Recurrence of this violation was prevented by not performing the opera-tion until resolution of the problem.

Recurrence will be prevented by "3.a. Calculation and review of expected dose rates from Tm-170 for the activity ranges and distances of concern", quoted from Corrective Actions submitted in our Response to Notice of Violation I.A.

3. Past Performance The thulium wafer transfer process is n.ique at MURR. No other samples are processed with such a high beta exposure level and such a low gamma level that also are handled as open sources. Therefore, there are no other high beta exposure sources for which to consider past perfor-mance.

In a somewhat different situation the MURR was cited under 10 CFR 20.201(b) as a result of an inspection August 16-17, 1982 for failure to survey (determine the exposure rate) in small cross-section beams at MURR beam port E. The response dated October 13, 1982 explained that the beams had been surveyed October 23, 1980. MURR agreed that the information (exposure rates in the beam) had not been adequately communicated to radiation workers. A new posting method was adopted which has been examined during later NRC inspections and found adequate.

4. Prior Notice of Similar Events No previous notice has occurred.

5. Multiple Occurrences Calculation of beta exposure from Tm-170 to predict exposure from acti-vity to be handled should have been made prior to the July 1985 opera-tion. The same information would have been available for the later operations.

Because of the exploratory nature of the thulium transfer operations, l dry runs were not considered. They would not have contributed informa-tion of value for the July, August and October 1985 operations. For the June 9,1986 operation, hindsight tells us a complete dry run would have been of value.

Item 3. Past Performance immediately above discusses a violation under 10 CFR 20.201(b). However, that violation is not directly comparable to the violation which is the subject of this response.

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i U.S. Nuclear Regulatory Commission February 13, 1987 Page five In consideration of the identification and reporting by tiURR, the corrective actions, the good past performance, no previous similar events or multiple occurrences, we request that the civil penalties be mitigated.

Respectfullf' submitted, The Curators of the University of 141ssouri

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by fit Cs ((he, Robert 14. Brugger / '~ "

Director ( g g., ,

qs o LEGat s AFFIDAVIT \ ;

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STATE OF filSSOURI)

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COUNTY OF BOONE )

Robert 14. 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 liissouri, a public corporation of the State of liissouri, and as such officer is duly authorized to make this affidavit on behalf of said public corporation; that the facts contained,in the s foregoing Request to fiitigate the Proposed Civil Penalties are true t9 his best belief and knowledge. ,/

_bN Ro'bert li. Brugger '

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i k Subscribed and sworn to before me this 13+h day of February, 1987.

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I Notafy Public Sharon bendingharn fly Commission expires: 2 11.f <7 Notary Pub!!c Stato cf Missouri My Lemmusico Expires 2-21-87 OLO/mbs County of Boono cc: Regional Administrator U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, IL 60137