IR 05000128/1987001

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Insp Rept 50-128/87-01 on 870112-14.Violations Identified: Failure to Evaluate Hazards Involving Irradiation & Handling of Bromine During 861218 Experiment & Failure to Renew Ref Ltr of Agreement on 861231,as Required by Emergency Plan
ML20212P582
Person / Time
Site: 05000128
Issue date: 03/03/1987
From: Chaney H, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212P543 List:
References
50-128-87-01, 50-128-87-1, NUDOCS 8703160160
Download: ML20212P582 (7)


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APPENDIX B i U.S. NUCLEAR REGULATORY COMMISSION P

REGION IV

NRC Inspection Report: 50-128/87-01 License: R-83 Docket: 50-128 Licensee: Texas A&M University (TAMU)

, Nuclear Science Center College Station,. Texas 77843 Facility Name: Nuclear Science Center (NSC) - TRIGA Reactor (1 Megawatt)

Inspection At: TAMU-NSC, College Station, Texas Inspection Conducted: January 12-14, 1987 M

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Inspector: , J 3 & '

H. D. Chaney,TRadiation Speciapst, Facilities Dat(

Radiological Protection Section

Approved: a t/) M l'b)(Aff; $i /

B. Murray, Chie'f, Faci,lities Radiological DAte Protection Section/

Inspection Summary Inspection Conducted January 12-14, 1987 (Report 50-128/87-01)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection, emergency preparedness, nuclear material safeguards, and physical-security programs. The contamination of personnel and release of airborne radioactive material involving irradiated bromine samples on December 18, 1986, was also reviewe Results: Within the areas inspected, two violations were identified (experiments, paragraph 4.c and emergency plan, paragraph 5). No deviations were identifie One unresolved item is identified in paragraph 4.g.

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e* DETAILS l

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m 1.' - Persons Conta'cted'

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.*D.' E.'Feltz, Director, NSC- .

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- * E. McLain, TAMU Radiation / Safety Officer -

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  • J.JAJ'Reascher, Director,.Research Reactor' Program
  • C. M..Meyer;; Senior' Health' Phys'icist (HP), TAMU-NSC

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J.~E.iSimek, TAMU_ Assistant' Radiation, Safety Officer

'R.-E. Wiatt, Director, Security & TAMU Police ;

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E. E.1Schneider;Jr., TAMU Police Chief . C. Dittman, Inspector, . Texas -Bureau of Radiation Control

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  • I'dicates n those present at the exit intervie I

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. Open"and" Unresolved Items Identified During this Inspection

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Unresolved items'a're matters about which more information is.. required to N

ascertain whether ;it. is an acceptable item, a deviation, or a violation.-

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Open items.are(matters that require further review and evaluation by the NRC inspector.-

l During=the course of-this inspection, o'ne unresolved and one open item weretidentified:

Unresolve Item ~

Title Paragraph -)

8701-03 Potential Uncontrolled Drain Path From Radioactive i Effluent Release Tank i

Open Item ~l 8701-04 Control Over Radioactive Material (RAM) at the NSC 4.j'

3 .- ~ Inspector Observations

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The'following is an' observation the NRC inspector discussed with the

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licensee during the exit meeting on January 14, 1987. This observation:is

.neither a violation nor an unresolved item. This item was identified for

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licensee consideration for program improvement, but has no specific l regulatory requiremen '

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Health Physics Staff Workload - The size of the health physics staff at  :

the NSC appears to be marginal and may be contributing to a less than  !

adequate oversight of radiation protection activitie (See paragraph 4.a I '

for details).

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4. Radiation Protection The licensee's radiation protection program was inspected to determine compliance with the requirements of the Facility Operating License, Amendment No. 9, and Technical Specifications (TS) 3.5, 3.6, 3.7, 4.5, 4.6, 6.1, 6.2.5, 6.3, 6.4, 6.6, and 6.7; 10 CFR Parts 19 and 20; the TAMU Emergency Plan (EP); and the recommendations of NRC Regulatory Guides (RG) 8.4, 8.7, 8.8, 8.10, 8.13, and 8.2 The NRC inspector reviewed selected records, interviewed personnel, made observations, and performed independent radiological survey Radiation Protection (RP) Organization and Controls The TAMU Radiological Safety Office (RS0) is responsible for providing health physics support at the NSC. Currently, the NSC health physics staff consists of two full-time HPs and part-time student technicians, when available. The NRC inspector noted that during this inspection only one part-time HP technician was available. The current reactor operating schedule involves at least two nights a week when the reactor is operated. During these extended operations, HP support is not present at the NSC and the reactor operator is responsible for RP matters. The NRC inspector discussed with the NSC and RSO managers, the apparent heavy workload imposed on the current NSC HP personnel and the possible effects it may have on control of radiation protection work activities at the NS No violations or deviations were identifie Qualifications and Staff Training The NRC inspector reviewed the licensee's RP staff qualifications, radiation worker training, retraining, and training record No violations or deviations were identifie Experiments The NRC inspector reviewed the licensee's program for evaluating experiments to determine compliance with TS 3. On December 18, 1986, the licensee telephoned NRC Region IV to report that personnel had been contaminated during off gassing procedures involving irradiated bromine samples and that airborne releases had caused the building ventilation monitors to alarm and had activated the building ventilation isolation system. The NRC inspector reviewed the circumstances surrounding the incident and determined that airborne releases and personnel exposures did not exceed regulatory limit However, the licensee had not performed a specific experiment review regarding the evaluation of radiological

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, consequences l associated with t.he' irradiation and subsequent handling

,of the. bromine samples ~. The failure to perform this evaluation-11s'an apparent' violation'of TF 3.6.3 (128/8701-01).

7 , (Nodeviations;wereidentifie ~

, Radiation Protection Instrumentation c

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The NRC! inspector reviewed the inventory of RP instruments'(portable survey' meters, laboratory counters, air samplers, etc.,),: including functional checks,' calibration records (1984-86), and traceability'of-calibration' sources and standards. Minor typographical. errors concerning calibration dates were noted on calibration stickers ~ .

No violations or deviations were identifie , .. ' Area Radiation Monitors (ARM)

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The NRC inspector reviewed the licensee's programs for ARMS to verify proper annual calibrations,(1985-86)~and functional. check .No violations or deviations were identifie , Personnel Monitoring The NRC inspector reviewed the personnel dosimetry records for'NSC'

personnel. The licensee's dosimetry processor was noted to have successfully participated in the National Voluntary Laboratory Accreditation Program. Records of extremity and whole body radiation exposures were properly documented and maintained on. forms equivalent to those referenced in 10 CFR Parts 20.102 and 20.40 , No violations or deviations were identifie ,f ' Environmental and Radioactive Effluent Releases The.NRC inspector reviewed the licensee's environmental-monitoring i program and' reports;. walked down the radioactive liquid waste (RLW)

L collection and discharge system; and reviewed RLW handling, sampling, and counting procedures. The NRC inspector noted that an uncapped

manual-valved spigot was present between RLW tank No. 3 and the discharge isolation valve, and that this arrangement provided a potential direct path of leakage or discharge to the environmen This valve is not shown on any system drawings (see Figure 12.1 of the TAMU Safety Evaluation Report (SER)-NUREG-0947). The licensee stated that the valve was placed in its current location so that the tank (normally filled with reactor grade water- of low radioactive concentrations) could be used to supply fire fighting water or reactor makeup water in the event the water utilities to the NSC facility were cut off. 10 CFR 50.59(b) requires that the licensee

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'shall maintain' records of changes in the facility and'of evaluations

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which provide the. bases for the determination that'the change does;

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not involve an unreviewed safety question. The1 licensee stated that-the necessary evaluation was performed, but that written documentation to' substantiate the evaluation could not be--locate .
- This is considered an unresolved' item pending further search to locate the written documentation. (128/8701-03) , Radiological Surveys The NRC inspector reviewed radiation and-contamination survey

l records.to determine compliance with the requirements of 10 CFR Part 20.201, and agreement with recommendations of industry standard p

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ANSI /ANS 15.11-1977. The licensee's beta, beta / gamma, and alpha Lanalyses of; contamination smears-were' reviewed. The licensee's survey procedures,-locations, survey frequencies, and the results of-completed surveys for 1985-86 were. reviewed. The NRC inspector also conducted independent-radiation and contamination survey L j No violations or deviations were identified.

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The licensee's program was reviewed-to determine compliance with 10 CFR Part 19.11.

l No violations or deviations were identifie Radioactive Material Control The NRC inspector reviewed the licensee's controls over RAM produced

~ in the reactor and RAM used to support reactor operation to determine compliance with the requirements of the License Condition II.(3).

TAMU also possesses an agreement state license.with Texas concerning.the regulation of byproduct material. The NRC inspector noted that, due to the NSC facility layout which includes

the reactor building (see TAMU-SER, Figure 4.1) and the attached I administrative and laboratory complex, there is some confusion over which license (state or NRC) applies to irradiated materials that do not leave the reactor building, but are processed, analyzed, or stored-in the reactor building. The NRC inspector I

stated that he would be responsible for reviewing the regulatory i authority for licensing matters and provide appropriate guidance to the license. This item is considered an open item pending clarification on regulatory authority regarding byproduct material produced and used at the NS (128/8701-04)

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6: Emergency Planning and Prepare'dness

~The NRC inspector reviewe'd the implementation of the TAMU-NSC Emergency Plan (Plan), to determine compliance with 10 CFR Part 50.54(q).

The NRC inspector reviewed assignment of responsibilities, development of implementing procedures, emergency facilities, letters of agreement with local emergency services, emergency kits and first aid facilities, communications lists, RSB audits of the Plan and critiques of drills, and-training of emergency response and TAMU Police Department personne The NRC inspector discussed with selected personnel their responsibi'ities during a reactor accident and reviewed the implementation of the Plan-during the December 18, 1986, bromine incident which involved the response of the TAMU-RS CFR Part 50.54(q) requires that the licensee follow and maintain in effect emergency plans. The.TAMU-NSC Emergency Plan requires, in paragraph 3.1, that written agreements with offsite organizations used for implementation of the TAMU or NSC emergency organizations be renewed on an annual basis, and that these agreements be included in Appendix A to the Plan. The NRC inspector determined on January 13, 1987, that the agreement with the hospital in Bryan, Texas, (St. Joseph) had expired on December 31, 1986,'and had not been renewed. This is an apparent violation of 10 CFR Part 50.54(q). (128/8701-02)

No violations or deviations were identifie . Nuclear Materials Safeguards The NRC inspector reviewed the nuclear materials inventory program to determine compliance with License Condition II.B.(2).

The NRC inspector reviewed accountability procedures, records, and materials status reports for the period January 1984 through September 1986. The RSB audit of fuel accountability was reviewe No violations or deviations were identifie . Physical Security The NRC inspector reviewed the licensee's program to determine compliance with License Condition II.C(3) and the requirements of the Physical Security Plan, Revision 1, dated June 197 The NRC inspector reviewed the licensee's physical security plan implementing procedures and RSB audits, observed an off-shift drill involving TAMU response to an intrusion alarm, reviewed security check

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-logs, and verified that'the'TAMU Police Department' possessed and properly controlled the Physical Security Plan and implementing procedure No violations'or deviations were identifie .

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Exit Interview

'Th'e NRC inspector met with the licensee representatives. identified in paragraph 1 of this report at the conclusion of the inspection on January 14, 198 The NRC inspector summarized the scope and inspection finding .

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