ML20235W088
| ML20235W088 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 10/07/1987 |
| From: | Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235W069 | List: |
| References | |
| 50-297-87-03, 50-297-87-3, NUDOCS 8710150584 | |
| Download: ML20235W088 (8) | |
See also: IR 05000297/1987003
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UNITED STATES
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p 4- NUCLEAR REGULATORY COMMISSION
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REGION 11
< , 'j 101 MARIETTA STREET, N.W.
- 's ATLANTA, GEORGI A 30323 i
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OCT 0 01987
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Report No. 50-297/87-03
Licensee: North Carolina State University
Raleigh, NC 27607
Docket No.: 50-297 License No.: R-120
Facility Name: North Carolina State University Pulstar Reactor
Inspection Con ucted: September 29-30, 1987
Inspector: 3. Mb _
/O/ 7
Date Signed
B. K. Revstn'
Approved by: ado /0[7[J 7
C. M. Hosey, Sec tion Chief Date Signbd
Division of Radi ation Safety and Safeguards
SUMMARY
Scope: This routine, unannounced, onsite inspection was conducted in the area
of radiation protection and included: internal and external exposure control
and assessment; control of radioactive materials and contamination, surveys,
and monitoring; transportation of radioactive material and followup on previous
enforcement items, Bulletins and Circulars.
Results: One violr. ion - failure to maintain and adhere to radiation control
procedures.
8710150504 a71007
PDR ADDCK 05000297
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REPORT DETAILS
1 ~. .- Persons Contacted
Licensee Employees
P. J. Turinsky, Head, Department of Nuclear Engineering
G. D.. Miller, Associate Director, Nuclear Reactor Program
K. V..Mani, Reactor health Physicist
T. C. Bray, Reactor Operations manager
D. W._ Morgan, Radiation Protection Officer
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T. L. Brackin, Radiation Safety. Specialist
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2.. Exit Interview.
The inspection sccpe and findings were summarized on' September 30, 1987,.
with those persons indicated in Paragraph 1 above. - One violation
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.containing three examples of failure' to maintain.and/or adhere to written
radiation control procedures (Paragraphs 4.e and 4.f) were discussed /in
detail.. One unresolved item * (URI) concerning calibration- records for
,Eberline RM-14 personnel friskers- (Paragraph 4.f),- was also discussed.
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. Licensee management acknowledged the. findings and took no exceptions. 'The-
~1icensee did not identify as proprietary any of' the material provided .to
or reviewed by the inspector during this inspection.
3. LicenseeAction'on'PreviousEnforcementMatters(92702)
(Closed) Violation'(50-297/87-01-01) Failure'to post documents required by
10 CFR 19.11. The inspector reviewed the licensee's response' dated 'l
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April . 21, 1987, and. verified that the corrective action stated in the
response.had been implemented. J
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.(Closed) Violation (50-297/87-01-02) Improper shipping papers and failure
to meet limited quantity shipment requirements.' The inspector reviewed
the licensee's response dated April 21, 1987, and verified that the
corrective action specified in the response had been implemented.
(Closed) ' Violation- (50-297/87-01-03) Failure to verify authorization of
transferee to receive byproduct material. The inspector reviewed the
ilicensee's. response dated April 21, 1987, and verified that the corrective
action specified in the response had been implemented.
- An unresolved item is a matter about which more information is required to l
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l ' determine whether they are acceptable or may involve a violation or deviation.
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4. Radiation Control (83743) l
a.. 10 CFR 20.201(b) requires the licensee to perform such surveys as may i
be necessary and are reasonable under the circumstances to evaluate
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the extent of the radiation hazards that may be present.
Procedure HP-20-14, Radiation and Contamination Survey. Pulstar Bay,
Revision 1, January 1,1986, required that direct radiation surveys -
be performed monthly. The inspector reviewed the results of the
monthly direct radiation surveys between January 1 and September 1,
1987. The licensee stated that surveys were performed after the
reactor had been brought to 100 percent power for at least
30 minutes. Routinely, both gamma and neutron surveys were performed
and in general, dose rates were low, i.e., less than one and five
millirem per hour respectively.
.No violations or deviations were identified.
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b. 10.CFR 20.202 required that appropriate personnel monitoring devices
be worn by personnel likely to receive an exposure in excess of ;
25 percent of the limits specified in 10 CFR 20.101 or who enter high
radiation areas.
10 CFR 20.101 stated the quarterly radiation exposure limits to the
whole body, skin of the whole body and extremities.
During tours of the facility, the inspector observed personnel
monitoring devices being worn. The licensee used film badges
supplied by a National Voluntary Laboratory Accreditation program
approved vendor for measuring official dose. From July 1, 1986, to
June 30,1987, the academic year, the inspector verified that
exposures were well below regulatory limits in that the highest j
individual exposure was 60 millirem (mrem) followed by two i
individuals with exposures totaling 50 mrem each. J
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The inspector discussed the use of extremity dosimetry with the l
licensee with particular reference to loading and down-loading j
stringer baskets. These aluminum baskets hold the plastic bottles i
containing target material while they undergo irradiation in the l
reactor pool. The licensee stated that to the best of their j
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knowledge this question had been addressed a number of years ago but
the results of this study were no longer available for review nor l
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could the licensee recall the results of the study. The licensee
stated that it was not uncommon for dose rates from the baskets to
reach 5-10 Roentgens per hour (R/ hour), but that general practice was
not to actually remove the baskets from the pool but to release the
plastic bottles from the basket which would then float to the top
where they could be retrieved. Additionally two radiation monitors
were located overhead (6 to 8 feet) and would alarm should any
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unusual radiation field develop. The set point for the
Geiger-Mueller (GM) detector was 2.5 mR/ hour while the ionization
chamber detector had two set points, an alert at 10 mR/ hour and an
alarm at 100 mR/ hour. Receiving an alarm at 100 mR/ hour required
building evacuation. Due to the location of these monitors over the
reactor bridge and at the loading /down-loading area for the
stringers, the licensee felt confident that should any abnormal
radiation field exist, personnel would be sufficiently alerted.
Additionally, film badges worn by personnel had not indicated any
exposure problems. The inspector stated that depending on the
position personal dosimetry was worn by individuals, the whole body
dosimeter could be two to three feet from the activated aluminum
basket while the fingers could potentially reside next to this
radiation source. In conclusion to these discussions, the licensee l
agreed to re-evaluate the extremity dose received by personnel at the
facility. The licensee stated that extremity rings would be worn for
approximately six months to reassess the magnitude and significance
of personnel extremity dose. The inspector stated that this would be
reviewed during future inspections (Inspector Followup Item ;
50-297/87-03-01). ,
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No violations or deviations were identified.
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c. 10 CFR 20.203 specifies the requirements for posting radiation areas,
high radiation areas and radioactive material areas.
During tours of the facility the inspector observed the above posting
and verified through observation of survey records that postings and
survey measurements were congruent. l
No violations or deviations were identified.
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d. 10 CFR 19.11 requires each licensee to conspicuously post current
copies of (1) 10 CFR Parts 19 and 20; (2) the license; (3) operating
procedures; and (4) Form NRC-3, in sufficient places to permit
individuals engaged in licensed activity to observe them on the way '
If posting the documents
to and from any ) licensed activity location.specified in (1, (2) and (3) is
post a notice which describes the document and states where they may
be examined.
During tours of the facility the inspector noted the presence of the 1
required postings at both entrances and exits from the Pulstar
reactor bay,
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No violations or deviations were identified.
e. Technical Specification 6.3.a.8 states that operating procedures shall
be written, updated periodically and followed for radiation control
and shall be maintained and available to all operating personnel.
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Proceduro HP-4C 1, Utilization of Reactor Irradiation Facilities, '
Revision 1, January 7,1986, Paragraph 8 states that the stringer is
placed on the Bridge for dose rate measurement which shall be
provided to the Reactor Operator for entry on Form NRP-3 (Run Sheet).
Procedure HP-40-1, Paragraph 6 further states that Reactor Operations
will be notified before removing anything from the pool.
Further discussions with licensee personnel concerning reactor
irradiations elicited the fact that the control of each irradiation
was maintained by a Run Sheet which were kept on the operating
console of the reactor. The inspector reviewed the numerous Run
Sheets that had been completed during the month of July 1987, and
noticed that in the majority of cases, the column denoting radiation
level after experiment irradiation had not been completed as required
by procedure. The licensee stated that the reason for this was
twofold: (1) irradiations were often -left under water for several
days af ter irradiation to permit decay of short lived radioactivity,
and consequently dose rate measurements were not available, and
(2) actual practice had evolved at the facility such that personnel
removed experiments from the pool as needed without regard for the
presence or absence of Operations personnel in the Control Room to
record dose rate measurements. The -inspector pointed out that
procedure HP-40-01 required that Operations be notified prior to
removal of anything from the reactor pool. The licensee stated that
this was not usually done since irradiated material was often removed
early in the morning before Operations personnel were available and '
that the success of the program required flexibility in this regard.
Licensee representatives further stated that while dose rate
measurements had not recorded in many instances, such surveys had
been performed on both the aluminum baskets and on the target
material after removal from the plastic bottle by individuals trained
in proper survey technique. The licensee explained that since most
irradiations were for neutron activation analysis, a survey to ensure
low activity of the sample was mandatory to prevent destruction of
sensitive counting equipment. The inspector stated that for
radiation protection purposes, surveys of the baskets were of more
interest than the target material since dose rates may be several
orders of magnitude greater than those of the target which are
usually less than 5 mR. The licensee stated that surveys were always
performed even though the data on the Run Sheet did not reflect this
practice.
Failure to follow radiation control procedure HP-40-1 requirements to
record dose rate measurements on Run Sheets after irradiations and to
notify reactor operations before removal of material from the reactor
pool were identified as two examples of an apparent violation of
Technical Specification 6.3.a.S (50-297/87-03-02).
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f. ' Instrument Calibration
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, and are reasonable under the circumstances to evaluate
the radiation hazards that may be present. 10 CFR 20.201(a) defines
survey to mean an evaluation of the radiation hazards incident to the
production, use, release, disposal, or presence of radioactive
materials which may include a physical survey of the location of
materials and equipment, and measurements of levels of radiation or
concentrations of radioactive material present.
During tours of the facility, the inspector observed instruments in
use. At the exit from the reactor bay to the Control Room, two
Eberline RM-14s with HP-210 probes were available for personnel to
monitor themselves for contamination before entry into the Control
Room, a clean area. . Both of these instruments had calibration
stickers on them that indicated that calibration was approximately
six months overdue. The licensee stated that the instruments had
been calibrated on schedule (quarterly) and that the old sticker had
not been removed. To verify calibration of the instruments, a review
of licensee records was undertaken. During 1986, RM-14s were
calibrated on the required frequency; however, for the first two 4
quarters . of 1987, no calibration records could be found. The
licensee stated that instrument records had recently been reorganized
and that the ones in question must have been misplaced since they
believed the instruments had been calibrated on the appropriate .
frequency. At the time of the Exit Interview the records had not
been located. The use of calibrated instruments in performing
personal and other types of surveys was discussed. The inspector
stated that failure to be able to demonstrate that calibrated
instruments had been used to perform surveys would be conisdered a
violation of 10 CFR 20.201(b). Presently, however, this area will be ,
considered an unresolved item pending completion of the licensee's l
search for the records and will be evaluated during future
inspections (50-297/87-03-03), t
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Discussions concerning instrument calibration, source checks and ]
response checks were held with licensee representatives. The i
licensee stated that response checks were generally performed on a l
wee'kly basis and consisted of exposing the instrument and attached )
probe to a button source of Pu-239 with an activity of greater than j
150,000 disintegrations per minute (dpm). At times, other sources j
were used or were available for use. A positive deflection of the 4
instrument needle was considered ample verification of instrument j
performance although this methodology was not delineated in a j
The licensee also stated that source
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radiation control procedure.
checks of these RM-14 instruments were not performed, i.e. , exposing
an instrument to a known activity source in a fixed geometry in
relation to the detector and verifying that the instrument read
accurately, plus or minus a permissible error.
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Calibration of the RM-14 was ' discussed. =The licensee stated that an
' electronic calibration was performed following the' manufacturer's
recommendations; however, these ' recommendation.s' had never 'been
, formalized into a procedure. The inspector' stated that Technical
' Specification 6;3.a.8 required that radiationccontrol procedures be -
- written. Failure to ' maintain ' written procedures for instrument
calibration. was ' identified as an additional example of an. apparent
violation' of . Technical Specification 6.3.a.8 -(50-297/87-03-02).
The use' of source checks .versus response checks for instrumentation
was1 considered during which11t was pointed out by the inspector.,
that use of a response check, a needle. deflection in response to a
.snell radioactive ; source, failed to verify that an instrument. was
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performing accurately in that no acceptance criteria for instrument
performance ~under7 these conditions ' had been established. The
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inspector stated.that conducting source checks rather than response
checks for instruments between calibrations was standard industry.
practice :for. verifying that the instrument was working
appropriately. The . licensee stated that this practice would be
re-evaluated.
5. . Transportation (86740)
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'10 CFR 71.5(a) requires each licensee who transports licensed naterial'
outside the confines of its plant or other place of use to' comply with the
applicable requirements of the' Department of Transportation in
49 CFR Parts 170 through.189.
The inspector reviewed the records of shipments of radioactive material
from the facility made between April 1987 through August 1987.
No violations or deviations were identified.
6. Followup' on Bulletins and Circulars (92703)
s a. (Closed) Bulletin 78-01, Neutron Monitoring Practices. The inspector
reviewed current practices for neutron monitoring at the . facility.
Routinely, the reactor bay was surveyed for neutron radiation using !
an Eberline PNR-4: the results of which indicate a minimal neutron .
hazard (less .than 5 mR/ hour). These readings are taken after the
reactor has been at 100 percent power for at least 30 minutes. Other
administrative controls include prohibitions against beam ~ port
removal .with the reactor at power and use of the Radiation Work
ll Permit program. A Radiation Work Permit is required when neutron
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hazard is anticipated. Neutron dosimetry is not normally worn by
personnel, but is readily available should the need arise.
b. (Closed) Bulletin 78-08, Radiation Levels from Fuel Element Transfer
Tubes. This Bulletin is not applicable to the licensee's facility.
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- c. ~(Closed)' Circular 78-03.J Pack' aging' Greater than Type A-Quantities of.
. Low' . Specific Activity Radioactive . Material for~ Transport.
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The.
' inspector ; reviewed . the licensee's _- Quality Assurance Prograrn.. for.
transportation of ? greater _ than Type. A : quantities 'of: radioactive '
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-material and .found its provisions.iadequate to L meet regulatory -
requirements,
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'd.. (Closed) Bulletin 79-19, Packaging of Low-level Radioactive Waste .for:-
Transport and Burial. Procedure: HP-10-5, Transfer and Shipment of'
- Radioactive Material,' and its attendant checklists,3which implement '
theE elements of the . program - for - transportation.. of radioactive -
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materials, was reviewed .. and found to be ' congruent ~with .the-
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requirements of 49 CFR Parts 170 through 189.
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