ML20211H156
| ML20211H156 | |
| Person / Time | |
|---|---|
| Site: | 05000148 |
| Issue date: | 10/28/1986 |
| From: | Murray B, Wise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20211H152 | List: |
| References | |
| 50-148-86-01, 50-148-86-1, NUDOCS 8611050006 | |
| Download: ML20211H156 (10) | |
See also: IR 05000148/1986001
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report: 50-148/86-01 License: R-78
Docket: 50-148
Licensee: University of Kansas (KU)
School of Engineering
Lawrence, Kansas
Facility.Name: University of Kansas, Bendix Pool Resctor.
Inspection At: Lawrence, Kansas
Inspection Conducted: September 11-12, 1986
Inspector' '- fAJ /D/ bV/EC
R. Wise, Radiation Specialist, Facilities Date
Radiological Protection Section
C
Approved: h B. Murray, Chief, Facilities Radiological
/d[c2fr/76
Date'
s Protection Section
Inspection Summary
Inspection Conducted September 11-12, 1986 (Report 50-148/86-01)
Areas Inspected: Routine, unannounced inspection of the licensee's
organization, operations and maintenance logs, licensee's internal audit
program, requalification program, operating procedures, surveillance
requirements, experiments, radiation protection, environmental protection,
emergency planning, and physical security plan.
Results: Within the areas inspected, five apparent violations were identified
(see paragraphs 3, 16.f, 16.g, and 20.b).
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8611050006 861030
PDR ADOCK 00000148
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DETAILS
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1. Persons Contacted
- H. F. Rosson, Reactor Director
- R. B. Messler,-Professor, Chemical Engineering-
- B. S. Friesen,- KU-Radiation Safety Officer
- Denotes those present'during the exit briefing on September 12, 1986.
2. Followup on Previously Identified Items
(Closed) Violation (148/83-01): During the inspection conducted during
the period February 28.through March 3, 1983, and reported in
. report 50-148/83-01, the NRC inspector, when reviewing the The University
of Kansas Committee on Radiation Sources" membership, determined that the
committee did not contain a nuclear engineer.
The NRC inspector reviewed current TS dated May'31, 1984, and determined
that membership of the committee was as required by the current TS, Section 6.1.5.1. This item is considered closed.
- 3. Current Status of the Facility
The reactor was last operated on June 18, 1984. The licensee has no plans
to resume operation of the facility. - The licensee has dismantled much
of the support equipment and presently pursuing plans for final
decommissioning. The licensee amended their license for a " possession.
only" license in September 1986.
All nuclear fuel had been removed and shipped to DOE facilities.
Unirradiated fuel ~was shipped to Oak Ridge on January _8, 1986, and
, irradiated fuel was shipped to Savannah River Plant in two shipments on
- January 28 and February 2, 1986. The only special nuclear material
!_ remaining onsite is 1 gram of U-235'in a fission chamber monitor, and
!. 32 grams of plutonium encapsulated in two plutonium-beryllium neutron
i- sources. In addition, the licensee maintains an inventory of
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approximately 40 pounds of U-238.
All structural elements which had been activated had been removed and
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packaged for shipment to a waste burial facility. All other structural
, elements which had been surveyed and considered clean are stored in the
- reactor facility.
f The licensee stated that dismantling of some of the reactor components is
required for fuel removal and this is an approved maintenance practice.
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Since the current plans were not to replace the fuel elements, but for
f eventual decommissioning of the reactor, the components which were
! dismantled were not reassembled.
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It was determined by USNRC, Office of Nuclear Reactor Regulation (NRR),
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upon receipt of the licensee's- request to amend the operating license to a
" possession only" license that the' licensee had not submitted a request
for the authority to initiate dismantling of the_ reactor prior to removal
of reactor components from the reactor, as required by 10 CFR 50.82,
as recommended by RG 1.86, and the interim guidance provided by " Guidance
and Discussion of Requirements for an Application to Terminate a Non power
Reactor Facility Operating License," Revision 1, September 15, 1984.
The project manager, NRR, for the KU. reactor facility discussed with the
-licensee that the failure to submit a request for the authority to
initiate dismantling of the reactor prior to removal of reactor components
is an apparent violation of 10 CFR Part 50.82. (148/8601-01)
10 CFR 50.59(a) requires, in part, that the holder of a license any make
changes in the facility as described in the safety analysis report without
prior Commission approval, unless the proposed change involves a change to
the Technical Specifications or is an unreviewed safety question. An
unreviewed safety question is created if the consequences of an accident
or the malfunction of equipment important to safety previously evaluated
may be increased.
10 CFR 50.59(b) requires that the licensee maintain. records of changes in
the facility to the extent that such changes constitute changes in the
safety analysis report. These records shall include a written safety
evaluation which provides the bases for the. determination that the change
does not involve an unreviewed safety question.
It was determined, after discussions with the licensee during a telephonic
conversation on October 23, 1986, that the licensee had not performed a
proper safety analysis review for the removal of the reactor components
from the reactor tank during core unloading with the intention of
dismantling and eventual decommissioning of the KU reactor facility during
January - February 1986 period. However, the licensee stated that several
years ago a leak had developed in the reactor tank, and that a detailed
safety analysis was performed for the dismantling and removal of the
reactor components. In addition to the safety analysis performed at that
time, procedures for the dismantling and removal of these components were
developed. The failure to perform a proper' safety analysis is an apparent
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violation of the requirements of 10 CFR Part 50.59. (148/8601-02)
The licensee obtained reactor tank water samples prior to draining the
. reactor tank and obtained additional water samples at various levels to
determine radioactivity concentrations of the water as the release was in
progress to ensure 10 CFR Part 20 limits were complied with during the
release.
The reactor tank was drained, and contamination and radiation surveys were
performed by the licensee. No removable contamination was detected. The
maximum exposure rate was 30 mR/h, near the bottom of the tank in close
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proximity to where the core had been located. The remaining reactor
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components were removed. The licensee had fabricated a reactor tank cover
to prevent entry into the reactor tank.
4. Inspector Observation
The following are observations the NRC inspectors discussed with the
licensee during the exit meeting on September 12, 1986. These
observations are neither violations nor unresolved items. These items
were recommended for licensee consideration for program improvement, but
they have no specific regalatory requirement.
a. Portable Radiation Survey Instrumentation - Portable radiation survey
instruments were not labeled to indicate calibration data. Also,
instrumentation which is not currently calibrated or not operable was
not placed in a controlled location to prevent unauthorized use.
(See paragraph 16.a)
b. Audits - Audits by the Nuclear Reactor Committee were not of
sufficient depth to verify compliance with program requirements.
(See paragraph 7)
5. Management Organization and Controls
The licensee's management organization and controls were inspected to
determine compliance with Technical Specification (TS) Section 6.1.
The licensee's organization and assignment of responsibilities were
determined to be as outlined in TS Section 6.1, and appeared to be
adequate to provide the required management controls for the current
status of the program.
The NRC inspector reviewed the membership of the Nuclear Reactor
Committee, the Nuclear Reactor Committee meeting minutes, and other
matters concerning supervision of the reactor facility operations for the
period January 1, 1983, through June 1984. The NRC inspector noted that
the Reactor Director's Senior Reactor Operating license expires during
September 1986 and that no licensed operators will be present at the
facility, after his license expires.
No violations or deviations were identified.
6. Operation and Maintenance Logs
The NRC inspector reviewed logs and records to determine ccmpliance with
the requirements of TS Sections 2.0, 3.0, 4.0, and 6.6.
The NRC inspector reviewed reactor operations for the period January 1983
through June 1984 regarding maintenance, modifications to the facility,
personnel exposure and dosimetry logs, experiment records, startup
checklists, instrument response check records, reactor power level,
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reactor. pool water conductivity, fuel element measurements, portable
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radiation survey instrument calibration records, and area radiation
monitor calibration records.
All maintenance and operations activities appeared to have been conducted
in compliance with the TS requirements and administrative procedures.
No violations or deviations were identified.
7. Internal Audits and Review
The NRC inspector inspected the licensee's internal audit and review
program to determine compliance with the requiremerits of TS Section 6.1.5
and Section 6.1.5.2.
The NRC inspector determined from Nuclear Reactor Committee meeting
minutes review for the period January 1983~to September 1986 that the
committee had met semiannually, and appeared to meet the requirements of
The NRC inspector noted that an auditor had been named by the Nuclear
Reactor Committee to conduct the annual audits for compliance with the
requirements of TS, Section 6.1.5.. The NRC inspector reviewed the
completed audits and determined that the audits appeared to be adequate to
meet the current requirements of the program; however, the need to conduct
a more in-depth review of the radioactive material control program was
discussed with the licensee. The NRC inspector informed the licensee that
under the current plans for the facility, a review of the radioactive
material control program is important to demonstrate compliance with the
regulations. The current TS do not specifically identify this area as a
requirement of audits.
No violations or deviations were identified.
8. Reactor Operation
The reactor was used primarily for performing experiments associated with
teaching programs during 1983 along with operation for the operator
requalification program. As noted in paragraph 3, the reactor was last
operated in June 1984.
No violations or deviations were identified.
9. Requalification Training
The NRC inspector reviewed the licensee's reactor operator requalification
training program for compliance with TS Section 6.6.2 and 10 CFR 55,
Appendix A. The NRC inspector reviewed training documents for the
currently licensed operator and documentation for individuals that were
licensed during the period January 1983 through August 1986.
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The NRC inspector determined that requalification training requirements
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were satisfied.
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-No~ violations or deviations were identified.
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10. Qualifications and Training
Personnel-qualifications and training were reviewed to determine
, compliance with the requirements'of TS Section 6.2 and 10 CFR Parts 19 and
- 20.
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i The NRC inspector reviewed qualifications and training records for
personnel that support reactor facility such as the radiation safety
office, students granted access to the facility, and emergency response
personnel. Course material and attendance rosters for various classes
were reviewed.
The current reactor facility staff consists of one licensed operator, one
, chemical engineering professor who was previously a licensed reactor
operator, and the KU radiation safety office staff.
No violations or deviations were identified.
11. Surveillance Requirements
The NRC inspector reviewed surveillances of safety channel calibrations,
reactivity, control and safety system, radiation monitoring system,
reactor fuel, and sealed sources to determine compliance with TS, Section 4.0.
The NRC inspector verified from records review that safety channel
calibrations had been performed as required,~that control and safety
, system limits had not been exceeded, radiation monitoring system was
operational and maintained as required, that reactor fuel had been.
inspected as required, and sealed sources had been wipe tested for leakage
and/or contamination at the prescribed frequencies.
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No violations or deviations were identified.
12. Experiments
The NRC inspector reviewed the licensee's reactor logs to determine
compliance with TS, Section 6.3.
- The NRC inspector determined that the licensee had not placed any new
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experiments-in the reactor since the previous inspection.
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No violations or deviations were identified.
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13. Fuel Handling Activities
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The NRC inspector reviewed the licensee's fuel handling activities to
determine agreement with licensee's procedures during core unloading and
cask loading during fuel transfer operations.
The NRC inspector reviewed the licens'ee's procedures, check lists, area
radiation monitoring records, survey records, and personnel dosimetry
records. The NRC inspector determined from records review and discussions
with personnel that fuel handling operations were conducted in agreement
with the licensee's approved procedures.
No violations or deviations were identified.
14. Transportation (Fuel Shipments)
The NRC inspector reviewed the licensee's fuel shipment records to
determine compliance with 10 CFR Part 71; licensee's procedures dated
November 25, 1985, and the Quality Assurance Plan, approved December 5,
1985; certificate of compliance for the shipping cask; registered user
documentation for the shipping cask; and additional procedures and
checklists required by the licensee's procedures.
The NRC inspector _ determined from review of appropriate shipping
manifests, chscklists, radiation survey records, and material
accountability forms for fuel shipments which occurred on January 28 and
February 2,1986, that all requirements had been met.
No violations or deviations were identified.
15. . Nuclear Materials Safeguards
The NRC inspector reviewed the nuclear materials inventory program to
determine compliance with license conditions 2.B(2), (3), (4).
The NRC inspector reviewed the accountability procedures and practices
records and material status reports for the period January 1983 through
August 1986. The procedures, practices, and records were found to be
implemented. As noted in paragraph 3, the licensee had transferred all
fuel elements to 00E facilities.
No violations or deviations were identified.
16. Radiation Protection
The NRC inspector reviewed the licensee's radiation protection program to
determine compliance with the requirements of TS, Sections 3.3, 4.6, 6.2,
6.6, 10 CFR Parts 19 and 20, and KU Emergency Plan.
The NRC inspector reviewed records, interviewed personnel, made
observations', and performed independent surveys.
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a. Radiation Measuring Instrumentation
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The NRC inspector reviewed calibration records for portable radiation
survey instrumentation for January l',1983, through September 11,
1986. The NRC inspector noted that the instrumentation calibrated by
the licensee did not have a calibration label indicating the date of
calibration, calibration due date, or who performed the calibration.
The NRC inspector noted that several steps should be considered by
the licensee in order to improve the credibility of their calibration
program. The licensee stated during the exit briefing on
September 12, 1986, that-the NRC inspector's observation will be
reviewed.
The NRC inspector also noted that survey instruments that were not
working or not currently calibrated should be placed in a controlled
area to prevent inadvertent use.
No violations or deviations were identified.
b. Area Radiation Monitors (ARM)
The NRC inspector reviewed the licensee's calibration program for ARM
which are required to be function tested daily during operations and
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calibrated annually.
The NRC inspector reviewed operation logs and calibration
documentation for ARM. The NRC inspector noted from records review
that the ARM were in operation as-required by TS, Section 3.3, during
fuel transfer operations.
No violations or deviations were identified.
c. Personnel Monitoring
The NRC inspector reviewed the licensee's personnel radiation
exposure records for 1983, 1984, 1985, and 1986, and noted that no
person exceeded 30 mrem. In' addition, the'NRC inspectors reviewed
the personnel exposure records for personnel involved in the fuel
. transfer operations. All exposures associated with this operation
were less than 10 mrem.
No violations or deviations were identified.
d. Environmental Surveillance / Radioactive Releases
The NRC inspector reviewed operation records and interviewed
personnel concerning releases of radioactive effluents to the
environment. No releases of radioactive effluents occurred during
the period January 1,1983, through 1986 prior to the core unloading
and fuel transfer.
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The NRC inspector reviewed records of analysis on reactor pool water
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prior to release. Samples were taken at various levels during the
draining operations prior to release to unrestricted areas. All
sample results reviewed indicated that 10 CFR Part 20 limits were
complied with during the. release operations.
The reactor tank was drained in January 1986, a total of 7000 gallons
'of reactor pool water was released to-the sanitary sewer system.
Gross alpha, beta and gamma activities were determined as follows:
alpha - 7.55 E-9 uCi/cc
beta. '1.13 E-8 uCi/cc
gamma - 5.21 E-8 uCi/cc
No violations or deviations were identified.
e. Surveys
The NRC inspector reviewed radiation and contamination survey records
regarding surveys performed by the licensee's staff to determine
compliance with 10iCFR Part 20 and agreement with the licensee's
procedures.
The KU Radiation Safety Department routinely performs radiation
surveys and takes smears to determine contamination levels within the
' facility. All surveys are documented according to department
procedures. The R50 performed a radiation and contamination survey
on the reactor tank after draining and documented the'results in a
report to the Nuclear Reactor Committee.
The NRC inspector performed independent contamination and direct
radiation dose rate surveys of the reactor facility. The smears
taken by the NRC inspectors were analyzed on NRC Region IV laboratory
counting instrumentation with all results less than or equal to
minimum detectable activities. The direct radiation survey results
revealed no areas of radiation levels in excess of 10 CFR Part 20
limits.
No violations or deviations were identified,
f. Regulatory Matters Posting
10 CFR Part 19.11(a)(1), 19.11(a)(2), 19.11(a)(3), and 19.11(c)
requires, in part, that the licensee post current copies of the
following documents: (1) 10 CFR Parts 19 and 20, (2) the license,
license conditions, documents incorporated into the license by
reference and amendments, (3) operating procedures applicable'to-
licensed activities, (4) any notice of violation, and (5) a Form NRC-3.
10 CFR Part 19(b) states that if posting a document specified in
10 CFR Part 19.11(a)(1), 19.11(a)(2), or 19.11(a)(3) is not
practicable, the licensee may post a notice which describes the
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document and states where it may be examined. The NRC inspector
determined on September 12, 1986, that the documents required by
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10 CFR. Parts 19.11(a)(1), 19.11(a)(2), 19.11(a)(3), and 19.11(c) were
not posted.
The failure to post the required documents is an apparent violation
of 10 CFR Part 19.11. (148/8601-03)
g. Radioactive Materials Control
The NRC inspector reviewed the licensee's program for radioactive-
materials control to determine compliance with 10 CFR Part 20, TS,
and license conditions.
The NRC inspector noted that the fission monitor containing 1 gram of
U-235 was not properly labelled.
10 CFR Part 20.203(f) requires, in part, that each container or
licensed material shall bear a durable, clearly visible label
identifying the radioactive contents.
The failure to properly identify the fission monitor as containing
radioactive materials is an apparent violation of 10 CFR
Part 20.203(f). (148/8601-04)
17. Emergency Planning and Preparedness
The NRC inspector reviewed the implementation of the KU Emergency
Plan (EP) dated October 27, 1983.
The NRC inspector reviewed assignment of responsibilities, emergency
facilities and equipment, written agreements with offsite agencies, and
inventories of equipment.
The licensee had conducted training based on scenarios and had conducted
annual drills in 1984 and 1985. Critiques for annual drills were on file
and were reviewed.
No violations or deviations were identified.
18. Physical Security
The material discussed here contains Safeguards Information as defined by
10 CFR 73.21 and is reported in Attachment to this report.
19. Exit Briefing
The NRC inspector met with the licensee's representatives identified in
paragraph 1 of this report at the conclusion of the inspection on
September 12, 1986. The NRC inspector summarized the scope and inspection
findings.
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