ML20214N546

Notice of Violation from Insp on 870407-10.Violations Noted: Appropriate Labeling of Containers W/Radioactive Contents Not Performed,Radiation Hazard Evaluations Inadequate & Listed Procedural Requirements Not Met

ML20214N546
Person / Time
Site:	Neely Research Reactor
Issue date:	05/26/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214N531	List: ML20214N529 ML20214N546
References
50-160-87-03, 50-160-87-3, NUDOCS 8706020209
Download: ML20214N546 (4)

Text

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ENCLOSURE NOTICE OF VIOLATION Georgia Institute of Technology Docket No. 50-160 GA Tech Research Reactor License No. R-97 During the Nuclear Regulatory Commission (NRC) inspection condd:tud on April 7-10, 1987, violations of NRC requirements were identified. 1he Violations involved (a) failure to label containers of licensed material, (b' failure to perform radiological surveys, and (c) failure to follow procedu res. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2. Appendix C (1986), the violations are listed below:

A. 10CFR20.203(f)(1)statesthatexceptasprovidedby10CFR20,203(f)(3),

each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents.

Contrary to the above, appropriate labeling of containers was not performed in that on June 2,1986, a sample of material which had been irradiated In the reactor and which contained 15 microcuries of Na-24 producing radiation levels of 90 millirem per hour (mr/ hour) on the external surface of the container was left in the decontamination room unlabeled and unattended. The exemptions of 10 CFR 20.203(f)(3) did not apply.

This is a Severity Level IV violation (Supplenent IV).

B. 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

10 CFR 20.201h) defines a survey to mean 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.

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l Georgia Institute of Technology 2 Docket No. 50-160 j GA Tech Research Reactor License No. R-97 l

Contrary to the above, evaluations of the radiation hazard that may have been present were inadequate in that:

1. From April 7 through April 10, 1987, the inspector observed that although a frisker was located at the vestibule doors of the Reactor Control Zone (RCZ), personnel were routinely exiting the RCZ through the vestibule doors to the outside of the facility without monitoring themselves for contamination.

2. On April 6, 1987, a RM-14 instrument alarmed on its maximum setting j of 50,000 counts per minute upon the arrival at a nearby rabbit l receiving station of an activated indium foil and a survey was not l performed to evaluate the extent of the radiation hazard that was present.

This is a Severity Level IV violation (Supplenent IV).

C. Technical Specification 6.4.b(6) requires that written procedures be i provided and utilized for radiation and radioactive contamination control.

Contrary to tne aLove, procedural requirements were not met in that:

1. On April 29, 1986, two individuals were present in the hallway of the Nuclear Reactor Center Building (NRCB), a clean area, dressed in clothing used to prevent the spread of radioactive material. The l wearing of protective clothing in clean area is prohibited by Health PhysicsProcedure(HPP). September 1985,Section6.j.

2. On March 19, 1986, an individual entered a contaminated area without wearing the protective clothing (shoe covers) clothing appropriate to the cond' tion required by Georgia Institute of Technology Radiation Safety Manual,Section IV.F.1.b.

3. On August 8, November 3, and November 18, 1986, individuals entered i the Radiation Control lone (RCZ) without personnel monitoring j devices required by HPP, September 1985, Sections 6.d and /.1.a.

4. On September 9,1986, the requirement on Radiation Work Pennit 6355, which specified health physics monitoring of the work from start to finish were not followed as required by HPP, Section 8.

ThisisaSeverityLevelIVviolation(SupplementIV).

D. Technical Specification 6.4.b(2) requires that written procedures be provided and utilized for installation and removal of fuel elements, control blados, experiments and experimental facilities.

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Georgia Institute of Technology 3 Docket No. 50-160 GA Tech Research Reactor License No. R-97 Contrary to the above, procedural requirements were not met in that:

1. On August 26, August 29 September 4 and September 23, 1986, irradiations were performed in horizontal beam Ports H-8 and H-12 without review and approval of the experiments required by Procedure 3102, October 28, 1982,Section II.B.

2. On August 20 August 29, September 4 and September 23, 1986, experimental conditions were changed from those authorized by Experiment Approval Form (EAF) No. R6832 and the changes were not specified on the Experimenter's Checklist as required by Procedure 3100, July 11, 1986.

3. On April 6,1987, an indium foil was irradiated in the reactor without review and approval of the specific experiment as required by Procedure 3102.

4 On April 6,1986, the Experimenter's Checklist was not completed for the irradiation of an indium foil, nor were the required checks performed in order to certify that an experiment neets the limitations of the applicable EAF as required by Procedure 3100.

5. On April 6,1986, a radiation level determination was not perfonied for a rabbit containing an irradiated indium foil removed from the reactor as required by Procedure 3012.

This is a Severity Level IV violation (Supplement IV).

E. Technical Specification 6.4.b requires that written procedures be provided and utilized for actions to be taken to correct specific and foreseen potential malfunctions of systems or components, including responses to alarms and abnormal reactivity changes:

Contrary to the above, the procedural requirement was not met in that on May 1,1985, all personnel did not evacuate the NRCH af ter sounding of the criticality alarm as required by HPP, Section 15.4.d.1.

ThisisaSeverityLevelIVviolation(SupplementIV).

i l Pursuant to the provisions of 10 CFR 2.201, Georgia Institute of Technology is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply i including for each violation: (1) admission or dental of the violation.

(2) the reason for the violation if admitted (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will

Georgia Institute of Technology 4 Docket No,60-160 GA Tech Research Reactor License No. R-97 be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION cA*

J. elson Grace Regional Administrator Dated at Atlanta, Georgia this May day of 26 1987 l

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