ML20244C499
| ML20244C499 | |
| Person / Time | |
|---|---|
| Site: | 05000083 |
| Issue date: | 04/04/1989 |
| From: | Kuzo G, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20244C492 | List: |
| References | |
| 50-083-89-01, IEIN-88-002, IEIN-88-008, IEIN-88-022, IEIN-88-032, IEIN-88-034, IEIN-88-062, IEIN-88-079, IEIN-88-100, IEIN-88-101, NUDOCS 8904200241 | |
| Download: ML20244C499 (19) | |
See also: IR 05000083/1989001
Text
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JO 'a - UNITED STATES '
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- NUCLE'A R REGULATORY COMMISSION
REGION ll-
g 4,,,, 101 MARIETTA ST., N.W.
ATLANTA GEORGIA 30323
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APR 0 7W
h 4 ' Report No.: 50-83/89-01'
' Licensee: University of Florida
202 Nuclear Sciences Center-
.Gainesville, FL 32601
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Docket No.: 50-83 License No.: R-56
Facility Name: University; of Florida Training Reactor
Inspection Conducted: February 27 - March 2, 1989 and March 27, 1989
-Inspector: lipo. O kn S loa 1 hS9
G. B. Kao Date Signsd-
Approved by: [
J. f. Potter, Chief
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patpSigned
Facilities and Radiation Protection Section
Emergency Preparedness and Radiation Protection
Branch
Division of Radiation Safety and Safeguards-
SUMMARY
Scope
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This routine, unannounced inspection involved onsite review of radiation
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protection progra. activities, including radiation controls, environmental ;
> surveillance and monitoring, transportation, and review of licensee actions I
concerning NRC Information Notices (ins) and previously identified enforcement
actions.
Results
Staffing and current organizational structure met Technical Specification
requirements and were adequate to implement the licensee's radiation protection
program. Strengths in the licensee's radiation protection program were noted
for management and Radiation Safety Review Subcommittee (RSRS) audits and
evaluations of radiation protection activities, low facility radioactive
contamination levels and low radiation exposure to personnel. The licensee
demonstrated timely and thorough responses ' to NRC initiatives including
improvements to procedures and methodologies for effluent measurement l
capability. Program weakr. esses included the need toL upgrade the review and i
documentation of training for persons frequenting the facility, and also to
improve radiation survey record documentation. An additional radiation control
program concern was identified as noted by apparent violations regarding the
adequacy of surveys conducted to evaluate localized radiation exposure levels
associated with selected reactor operations;(Paragraphs 2.e and 3.a) and which
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resulted in radiation levels in an unrestricted area exceeding 2 millirem per
hour (Pargraph 3.b).
The following violations were identified during the inspection:
- Failure to conduct adequate surveys to evaluate the radiation hazards
associated with selected reactor vertical beam port and " rabbit" facility
operations. Violation of 10 CFR 20.201(b) requirements (Paragraphs 2.e
and 3.b).
- Failure to maintain unrestricted radiation exposure levels, which could
result in an individual receiving a dose, to less than two millirems in
any one hour. Violation of 10 CFR 20.105(b)(1) requirements
(Paragraph 3.b)
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' REPORT DETAILS
1. Persons Contacted
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Licensee Employees
- D. Munroe, Radiation Control Officer, Environmental Health and Safety ;
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Division
- J.- Tulenko, Director Nuclear Facilities
- W. Vernetson, Director, University of Florida Training Reactor
- P. Whaley, Acting Reactor Manager
Other licensee emplcyees contacted included operators, Radiation Control
(RC) student assistants, and office personnel.
- Attended exit interview
- Participated in March 27, 1989, teleconference
2. Radiation Control (83743)
a. Organization and Staffing
Technical Specification (TS) Sections 6.2.1 and 6.2.2 detail
organizational structure and management responsibility for safe
operation of the University of Florida Training Reactor (UFTR)
facility.
The inspector reviewed and discussed with cognizant licensee
representatives the current staffing detailed to conduct routine and
nonroutine radiation protection activities at the UFTR. A RC
technician position, assigned limited radiation protection
responsibilities at the facility, recently was eliminated; however,
the change was not expected to impact the program. Currently, five
licensed operators, including the Director, UFTR, were trained
adequately to conduct radiation protection activities. Radiation
protection program duties conducted by the operators included weekly
radiation surveys, calibration of UFTR area radiation protection
equipment, and monitoring during experiments maintenance activities.
Additional assistance to conduct radiation protection program
activities is provided by personnel detailed from the University of
Florida, (UF), Environmental Health and Safety Division. Generally
four persons, three RC student assistants and the University
Radiation Safety Officer (RS0) are involved with radiation protection
activities at the UFTR including radiation monitoring during removal
of experiments from the reactor, quarterly radiation surveys
conducted in the restricted and unrestricted facility areas, prepara-
tion of liquid radioactive waste tank releases, and assistance during i
nonroutine UFTR activities, for example monitoring and assistance
during maintenance and fuel movement activities.
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The inspector noted during this inspection that current staffing,
utilizing UFTR and Radiation Control Office personnel, appeared
adequate to conduct routine and nonroutine radiation protection
activities for the facility.
No violations or deviations were identified.
b. Audits and Management Evaluations
TS 6.2.5 requires an independent review and audit of safety aspects
of reactor facility operations to advise management. The review and
audit functions are to be conducted by the Radiation Safety Review
Subcommittee (RSRS). TSs 6.2.5(1) and 6.2.5(2) detail RSRS member
composition and qualifications, and also meeting and audit frequency.
The inspector discussed with the Director, UFTR, the qualifications
of selected RSRS members. The Director stated that current sub-
committee members included personnel with previous and/or current
involvement in the commercial nuclear industry, including a Reactor
Safety Committee member and also a radiological environmental
monitoring program director for a commercial nuclear power plant.
The Director, Nuclear Facilities, believed the experience of the RSRS
members was appropriate to provide adequate technical guidance
regarding radiation protection activities at the UFTR facility.
TS 6.2.5(2) requires the RSRS to conduct quarterly meetings at
intervals not to exceed four months.
The inspector reviewed the minutes' of the RSRS meetings conducted
from January 1,1988 through' 0ctober 1988. During this time period
the RSRS and executive RSRS met the TS' requirements, conducting
approximately 16 meetings to review applicable items affecting
operation of the facility. The meeting minutes indicated that the
majority of' issues discussed and reviewed included, facility status,
10 CFR 50.59 reviews, and technical change notices. In addition, the
subcommittees reviewed results of an UFTR management evaluation, '
presented during a March 22, 1988, RSRS meeting. The evaluation was
conducted by licensee management to evaluate the UFTR's radiation
protection program relative to concerns noted at another research
reactor facility. Results of the evaluation were detailed in a ;
Memorandum from the Director, Nuclear Facilities, to the RSRS, dated '
March 11, 1988. The overall evaluation did not identify any serious )
deficiencies, and where appropriate, actions were initiated regarding l
suggested improvements in the radiation protection program. . Licensee
representatives stated that the frequent RSRS meetings and self-
evaluations would continue for the UFTR facility. The inspector
noted that continual review of licensee activities by the RSRS, ;
aggressive evaluations, and timely corrective actions indicated i
management's commitment to improve the quality of radiation
protection program activities at the UFTR facility.
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TS _6.2.5(4) ' requires quarterly audits to be conducted for facility
operations . for conformance with TSs and applicable license
conditions, at least once per calendar year.
The inspector reviewed and discussed'the audit program conducted for
the' UFTR facility. Standard Operating Procedure (50P) 0.5E, Quality
. Assurance.(QA) Program - Annual QA Audit Checklist, Revision (Rev.)
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1, dated February.1986, details audit- format, time interval between
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audits, areas for review, and records required. The ~ inspector noted
that the audits verified compliance with requirements and were not'
. performance. oriented. Details of the audit' checklist included
verification of health physics (HP) and maintenance records, and
commitments to the NRC. The inspector-reviewed the results of the
annual Calendar-Year Audit of UFTR - 1987, dated February 2,1988.
No significant findings were. identified. In ' addition,' licensee
representatives stated that the Annual Calendar-Year Audit of UFTR -
1988, conducted February 20, 1989, did not identify any significant
deficiencies or problems. However, at the time of the inspection,
documentation of this most recent audit was not available for review.
No. violations or deviations were identified,
c. Training
10 CFR.19.12 requires the licensee to instruct all individuals
working in or frequenting any portion of the restricted area in
health physics protection problems associated with exposure to
= radioactive material or radiation, in precautions or procedures to
minimize exposure, and in the purposes and functions of protective
devices employed, applicable provisions of Commission Regulations,
individuals' responsibilities and the availability of radiation
exposure reports which workers may request pursuant to 10 CFR 19.13.
The inspector discussed with cognizant licensee representatives
training provided to personnel frequenting the UFTR facility. The
licensee did not require verification of training for all personnel
frequenting the facility. The licensee indicated that, excluding !
visitors touring the facility, persons spending appreciable time
within the UFTR restricted area included operators, experimenters,
Community College RC Technician trainees, and UF Environmental Health
and Safety, RC student assistants. Only operators are allowed
unsupervised access to the facility. Applicable radiation protection
activities and issues are reviewed for these personnel during the
biennial operator requalifications. When in the protected area,
experimenters are supervised closely by an operator. Community
College RC Technician trainees are supervised and provided with
radiation worker instructions which meet 10 CFR 19.12 criteria.
Discussion with licensee management indicated that UF RC student
assistants, allowed to conduct routine surveillance within the
restricted area, were assumed to have had the applicable 10 CFR 19.12
training. However, no interviews to review previous experience i
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and/or training of these personnel were conducted to. verify the
- training received. The inspector interviewed selected RC student
assistants and determined that personnel were k' knowledgeable of the
applicable Federal regulations,10 CFR Parts 19 and 20, and UFTR
radiological- health and safety issues. Licensee representatives
, . stated that,the need to assure adequate 10 CFR Part 19 training and
maintain associated documentation for all personnel frequenting the
facility = would be evaluated. The inspector informed licensee
representatives that this issue would be considered an Inspector'
Followup Item (IFI) and would be reviewed during a subsequent
inspection (50-83/89-01-01).
No violations or deviations were identified,
d. Facility Tours
Posting-and Labeling Requirements
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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
to and from any licensed activity location. If posting of the
documents specified in (1), (2), .and (3) is not practicable, the
licensee.may post a-notice which describes the documents and states
where they may be examined.
Excluding nonroutine events. and maintenance activities requiring. use
of reactor cell west bay and entrance doors, all routine entry into
the restricted area is accessed through the control room. During
tours of the facility, the inspector noted that the applicable l
documents and/or. references to their location were posted at the
entrance to the rea'ctor control room. The posted documentation
indicated that copies of regulations and procedures were maintained
in.the control room and the Nuclear Facilities, Director's office .
10 CFR 19.11(e) states that a posted Notice of Violation (N0V) must
be posted fo'r a minimum of five working days or until action
correcting the violation has been completed, whichever is later.
The inspector noted that the licensee maintained a posting of an NOV
issued during a previous inspection, Inspection Report (IR)
No. 50-83/88-01. The licensee's response to the NOV, dated May 6,
1988, indicated corrective actions were to have been completed by
July 31, 1988. Licensee representatives stated that corrective
actions to the referenced NOV were completed as scheduled, but the
NOV was not removed pending review and closecut of the issue by the
NRC. Closecut of these issues is detailed in Paragraph 6 of this
report.
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10 CFR 20.203 specifies the requirements for posting radiation areas,
high radiation areas and labeling containers . of radioactive
materials.
Posting of entrances into the restricted area and the labeling of
containers were reviewed and discussed with licensee representatives.
The. entry door into the reactor control room is posted with signs
indicating, " Caution Radiation Area," and, " Caution Radioactive
Material." All waste containers in the reactor facility were visibly
labeled with tags indicating, " Caution Radioactive Material." During
a tour of the reactor cell, the inspector noted a shop vacuum cleaner
without ' labels or markings to indicate its contamination status.
Licensee representatives stated that the equipment was not used to
vacuum contaminated material or- areas. Contamination surveys of the
vacuum equipment requested by the inspector verified beta-gamma
activity to be negligible. The inspector discussed the potential for ,
use of the equipment for contaminated materials or areas within the i
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restricted area. Licensee representatives stated that even if the
vacuum became contaminated, all waste is surveyed and sorted as
contaminated or noncontaminated prior to removal from the restricted
area. However, to avoid use of the vacuum equipment on contaminated ;
material, resulting in an unnecessary increase in the volume of 'j
radioactive waste material, the licensee agreed to label the
equipment indicating use only for noncontaminated materials.
No violations or deviations were identified
e. Surveys
10 CFR 20.201(b) requires the licensee to make or cause to be made
such surveys as (1) may be necessary for the licensee to comply with
regulations in this part and (2) are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
TS 6.3 requires the facility to be operated and maintained in
accordance with approved, written procedures for personnel radiation
protection, consistent with applicable regulations.
TS 3.9.2(2)(a) requires weekly measurements of surface contamination
in the restricted area. Surface contamination greater than
100 disintegrations per minute per 100 centimeters square
(dpm/100 cm a
) beta-gamma and 50 dpm/100 cm2 alpha are limiting
conditir .s for operation requiring review and possible radiological
safety actions.
TS 3.9.2(2)(b) requires airborne particulate contamination to be
measured using a high volume air sampler during the weekly checkout. l
Measured airborne contamination 25 percent (%) above mean normal
levels are limiting conditions for operation requiring review and
possible radiological safety control actions.
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TS 3.9.2(3)(a) requires surveys measuring the radiation doses in the
restricted area to be conducted quarterly, at intervals not to' exceed
four months, and at any time a change in the normal radiation-levels
is. noticed or expected.
- The. following procedures detailing radiological surveys conducted
within the UFTR restricted area to meet the applicable TS
surveillance requirements were reviewed by the inspector.
Radiationf Control Techniques. (RCT) No.1, Instructions for
Performing Swipe Samples, dated April 1987.
RCT No.4, Instructions- for Performing Radiation Surveys, . dated
April 1987.
RCT No.8, Instructions for- Analysi3 of Swipe, Air and Liquid
-Samples, dated January 1989.
RCT- No. p 14, Instructions for Calibrating Portable Survey
Instruments, dated June 1988.
RCT No. 33, NMC' Proportional Counter Calibration, dated April
1988.
S0P D.1', UFTR Radiation Protection'and Control.
The. inspector selectively reviewed the UFTR restricted' area weekly
and quarterly radiological survey results conducted from January 1,
1988' through February 28,1989. .The following issues were reviewed
and discussed with licensee personnel.
Surface contamination levels within the facility were low,
survey data indicating beta-gamma surface contamination activity
levels were maintained below 50 dpm/100 cm2 Licensee
representatives stated that surfaces with measured activity
exceeding this value were decontaminated immediately. During
review of the weekly surface contamination records the inspector
noted mislabeled data and a calculational error for surface
activity . contamination levels, which if correct, would have
required additional licensee action. The inspector noted that
these data sheets were reviewed by the RC assistants conducting
the surveys and also by a cognizant supervisor and thus, the
errors should have been identified and corrected prior to the <
inspection. Licensee representatives made the appropriate I
corrections and agreed to review the need for improvement in
record documentation and subsequent review by supervisory ;
personnel. {
No abnormal levels of airborne particulate radioactive materials
were noted for the facility, reported airborne particulate !
beta-gamma activity concentrations approximated
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1.0 E-12 microcuries per milliliter (uCi/ml).
Exposure surveys were conducted with the reactor at zero and
full power. With the reactor at zero power, radiation exposure
values within the restricted area ranged from 0.01 to approxi-
mately 1 millirem per hour (mR/hr). For routine surveys
conducted at 100% power, the highest exposure values within the
restricted area approximated 40 mR/hr, in the vicinity of the
area where the pneumatic transfer system, " Rabbit System,"
breached the reactor shielding. During the onsite inspection,
licensee representatives stated that extensive surveys have been
conducted for this area and shielding modified appropriately.
In addition, review of quarterly exposure surveillance results
indicated occasional measurements of elevated exposure rates
above the center vertical beam port on the upper reactor shield,
reported values ranging from 7 to 85 mR/hr at an approximate
distance of one meter as measured by ion chamber
instrumentation.
10 CFR 20.201(b) requires the licensee to make or cause to be made
such surveys to be as (1) may be necessary for the licensee to comply
with regulations in this part and (2) are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
The inspector discussed and reviewed with cognizant licensee
representatives the elevated exposure values measured above the
center vertical beam port and noted that measurements were conducted
with the ion chamber held at waist height, approximately 1 meter (m),
from the upper reactor shield surface. Licensee representatives
stated that, occasionally, an inaccurate fit of the beam port plug
into the upper reactor shield resulted in radiation streaming around
the plug edges. At the time of the inspection additional shielding
was placed on top of the center beam port area, however, the location
around the beam port was not physically controlled, nor identified
and posted as a high radiation area. The inspector noted that survey
results were detailed for only a single location directly above the
center beam port plug and that the area potentially could be
classified as a high radiation area depending on the dose rates and
extent of the radiation fields as determined by detailed radiation
surveys. Licensee representatives stated that additional surveys,
which resulted in the licensee adding the extra shielding, were
conducted and, most likely, were entered in the operator's log book.
These survey records had not been located at the end of the onsite
inspection. The inspector informed licensee representatives that
pending review of surveys conducted, the adequacy of the licensee's
evaluation of the radiation hazards associated with radiation
streaming around the center vertical beam port would be considered an
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unresolved item (URI)* regarding 20.201(b) requirements
(50-83/89-01-02).
During teleconferences between the licensee and NRC representatives
on March 10, 1989, and March 27, 1989, NRC representatives were
informed that detailed exposure rate survey data for the center
vertical beam port were not located. Licensee representatives stated
that since the onsite inspection, additional surveys were conducted
and detailed to NRC Region II in a letter from the Director, Nuclear
Facilities, dated March 17, 1989. The licensee indicated that
detailed survey data concerning the center vertical port (CVP) were
not entered in the operations 109 Reference was made to an initial
evaluation of high dose rates recorded in early 1988, although high
dose rates were measured periodically during previous surveys. The
licensee's recent survey included results for the west, center and
east vertical ports with the west and center ports having ~ elevated
exposure rate values of approximately 65-75 mR/hr on contact and
24-32 mR/hr at 18 inches. The inspector noted that the quarterly
dose rate surveys made between February 10, 1988, to January 31,
1989, indicated exposure levels ranging from 7 to 85 mR/hr as
measured by an ion chamber held at waist height at the CVP without
additional surveys at the other ports and at several distances from
the shield to evaluate the hazards present. In addition, the most
recent surveys indicated elevated exposure levels were measured over
the West Vertical Port but no additional shielding was inplace
indicating previous quarterly surveys were not conducted at this port
location.
The inspector informed licensee representatives that the failure to
adequately evaluate the dose rates associated with the UFTR vertical
beam ports was an apparent violation of 10 CFR 20.201(b) requirements
(50-83/89-01-02).
The licensee's March 17, 1989 letter detailed actions taken to reduce
dose rates and potential exposure associated with the reactor
vertical ports including the fabrication and installation of new
shield plugs and caution signs for the area. Surveys conducted
following installation of new shield plugs indicated exposure rates
ranging from approximately 14 to 20 mR/hr and 8 to 9 mR/hr at contact
and 18 inches, respectively, from the reactor shield surface.
- An unresolved item is a matter about which more information is required to
determine whether it is acceptable or may involve violations or deviations.
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l~ f. : External Exposure Reviews
10 CFR 20.101 delineates the quarterly radiat_ ion exposure. limits to
the whole body, skin of the ~ whole' body, and the extremities for
individuals in restricted areas.-
The inspector reviewed and discussed the- exposures recorded for
persons working or visiting'the UFTR' facility from January 1. 1988,
through January 31, 1989. Personnel exposure measurements are
conducted using film. badges provided by an National Voluntary -
Laboratory Accreditation-Program (NAVLAP) accredited vendor. Vendor
specifications reported a detection limit 'of 10 millirem (mrem)' for-
the provided dosimetry. . Highest reported ~ exposure for the 1988
calendar' year was approximately ~250 mrem assigned to an operator.
The exposure resulted from activities associated with radiography
experiments, maintenance and fuel movement activity. All other
annual cumulative exposures, including exposures assigned to other
operators, were reported to be less than 100. mrem for the reporting a
period.
No violations or deviations were identified.
3. Environmental (80745)-
a. Effluents'
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10 CFR 20.303 details liquid effluent release' limits to the sanitary
sewerage system.
TS 3.4.5 requires liquid waste from the radioactive liquid waste
holding tanks to be sampled and the activity to-be measured, with the
results to be within limits specified in 10 CFR 20, Appendix B.
Table 1, Column 2, before release to the sanitary sewer.
The licensee conducts radioactive. liquid releases to the sanitary
sewer using the following procedures:
RCT No. 6 Instructions for obtaining and preparing a liquid
sample for analysis, dated July 1988. l
RCT No. 7, Instructions for Analysis of Swipe, Air, and Liquid
Samples, dated January 1989.
RCT No. 21, Instructions for Utilizing, Sampling and Discharging
Liquid Waste Holdup Tanks, dated July 1988.
The inspector discussed changes to the procedures since the previous '
NRCinspection(50-83/88-01). Procedures now require the calculation
of a Lower Limit of Detection (LLD) with each release and the
resultant value to be less than one percent of the Maximum
Permissible Concentration for water (MPCw) listed in 10 CFR 20,
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Appendix B, Table 1 Column 2< Furthermore, measured activity in'the
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liquid -to be released must be below 25% MPCw or-an estimate of the-
individual nuclides must be conducted.
From September 1987 through August 1988, the licensee'has conducted
seven waste tank' releases, with average radionuclides concentrations
ranging from 2.58 E-9 to 5.10 E-8 uCi/ml... A total of 9.82.uCi were
" released during the reporting period. These data are similar to
values reported for previous releases.
TS 4.'2.4(2) requiresithe Argon-41 (Ar-41) concentration in L stack
effluents -to: be ~ measured semiannually at intervals not .to ' exceed
eight-(8) months.
Calculation of the instantaneous Ar-41 release-rate is conducted.in
accordance with licensee 50P E.6, Argon-41 Concentration Measurement,
' Rev. O, dated January 1984. The inspector' reviewed and discussed
with . licensee. representatives semiannual air flow measurements. and
Ar-41 concentration' results recorded from July 1987 to January 1989.
Air . flow volumes = ranged from 12,995 cubic feet (ft3) .to 13,537 ft8
with-instantaneous. gaseous radionuclides concentrations ranging from
1.11 E-7 uCi/ml to'1.22 E-7 uCi/ml. Based on the monthly reactor run
time ' and the instantaneous 'Ar-41 concentrations, the calculated
releases from September 1987 through August 1988, ranged from
3.26 E+6 uCi/ month to 22.68 E+6 uCi/ month with a cumulative release
of 137.8 Ci for'the-reporting period.
No violations or deviations were identified.
b. Surveys
TS 3.9.2(1) requires monthly environmental radioactivity surveillance
outside the restricted area to be conducted by measuring the gamma
doses at selected fixed locations surrounding the UFTR complex with
acceptable personnel monitoring devices.
Environmental radiation exposure as a result of UFTR operations were
considered minimal, the annual reporting period cummulative dose
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ranging from 10-40 mrem and less that 10 mrem, as measured by film
badge and thermoluminescent dosimetry (TLD), respectively. The
higher film badges exposure measurements were believed to have
resulted from the absence of a control badge during handling and
processing of the dosimeters.
TS 3.9.2(3)(b) requires quarterly radiation exposure surveys to be
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' conducted in unrestricted areas surrounding the UFTR complex.
Licensee procedure, RCT No. 31, Instructions for Performing UFTR
Environmental ~ Monitoring, dated July 1988, details the conduct of
surveillance required to meet TS requirements. Surveys for
unrestricted areas adjacent to the UFTR facilities are conducted
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using a micro-R survey meter. A review of quarterly survey results
measured from October 1987 through January 1989, indicated exposure
values outside the UFTR building ranged from 10 to 75 microRoentgens
.perhour(uR/hr). Highest values were measured at-the west bay doors
of- thes UFTR building directly in alignment with the area. of the
reactor where the " rabbit system" breaches the reactor: shielding.
. Licensee representatives stated that these doors are not accessible
during reactor. operations and the general public does not frequent
this area.-
10 CFR 20.105(b)(1) requires- that no licensee shall possess, use, or
t transfer licensed material in such a manner as ' to create in any
unrestricted area radiation- levels which, if an individual were
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continuously present in- the area, could result in his receiving a
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dose in excess of two millirems.in any one hour.
10.CFR 20;201(b) re i
such surveys as (1) quires
may the licensee
be necessary for thetolicensee
- nake or
to cause
comply to be made
with
regulations in this part and (2) are reasonable under the
circumstances to. evaluate the extent of radiation hazards _that may be.
.present.
On March 21,-1989, the licensee notified the NRC Region'II office by-
telephone that while conducting surveys in' areas outside of the UFTR
restricted areas as followup to the February 28-March 2,1988,
inspection, exposure levels exceeding the 10 CFR 20.105(b)(1) limits,
that is, two (2) mrem /hr, were measured. .W ith the reactor operating
a: full power, contact exposure rates ranged from approximately 10 to
~20 millirem (mR/hr) at a height of four (4) feet above ground level
against the outside surface of a reactor cell west bay doors with
exposure levels decreasing below 2 mR/hr approximately 3 to 3.5 feet
from the door. The door is maintained as inaccessible during
operation of the reactor and the area is adjacent to a limited-access
UF parking lot.
Licensee representatives determined the source was a collimated beam
resulting from insufficient shielding around the area where the
pneumatic transfer system "nbbit system" breaches the reactor
shielding. Upon discovery oi 5e unexpected dose rates, the licensee
conducted immediate remedial actions including the installation of
temporary shielding which. resulted in a reduction of exposure rates
to less than 2 mR/hr levels at the boundary of the restricted area.
During a teleconference conducted March 27, 1989, cognizant NRC and
v licensee. representatives discussed the potential for exposure from
the source to personnel, and the implemented and proposed corrective
actions. Licensee representatives stated that they believed the
problem originated during the " rabbit system" shield modification
conducted January 20, 1987.
Based on the reactor operation run-time at full power, approximately
250-300 hours per year, the controls preventing access to the area
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during ' operation, and the limited potential for personnel to spend
time outside this immediate area of the UFTR building, the licensee
stated that potential for personnel exposure was negligible. The
licensee has detailed the issue to the UFTR RSRS and further remedial
and followup actions including review of the shielding, survey
procedure upgrades, and completion and submittal of a full report to
'
the NRC were planned.
NRC representatives stated that although corrective actions appeared
timely and thorough, and the potential for personnel exposure was
,- minimal, the failure to identify the elevated exposure values, that
is greater than 2 mR/hr, in the unrestricted area from January 1987 l
tt the present time . eld only subsequent to followup of a NRC
identified unresolved item, indicated the need for a detailed
evaluation of the current survey program. The creation in any
unrestricted area radiation levels which, if an individual were
continuously present in the area, could result in his receiving a
dose in excess of two millirems in any one hour was identified as an 1'
apparent violation of 10 CFR 20.105(b)(1) requirements
(50-83/89-01-03).
The inspector noted that from interviews with RC assistants and
review of previous restricted and unrestricted quarterly surveys of
the " rabbit system" and potential beam paths, the exposure results in
the unrestricted areas exceeding 1 mR/hr were not measured nor
expected. Licensee representatives agreed that the surveys conducted
for the " rabbit system" and the reactor cell west wall areas were not
adequate to evaluate the radiological conditions present following
rearrangement of the system's shielding approximately two years ago.
The inspector stated that the failure to conduct adequate surveys to
evaluate the radiation hazards associated with " rabbit system" was an
additional example of a violation of 10 CFR 20.201(b) requirements
(50-83/89-01-02).
c. Analytical Measurement Capability ;
10 CFR 20.201(b) requires the licensee to make or cause to be made
such surveys as (1) may be necessary for the licensee to comply with
regulations in this part and (2) are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
The inspector reviewed and discussed with cognizant licensee
representatives changes to the licensee's analytical radionuclides
measurement program. Changes in the following areas were discussed.
Improvements were noted for quality control methods associated
with use of the NMC Proportional Counter including the
development of operational performance criteria and establish-
ment of acceptance criteria for routine equipment calibrations.
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Analytical measurement procedures required calculation of an LLD
for the weekly contamination survey sample analyses. The
inspector noted that based on the stable operating characteris-
tics of the equipment and use of routine procedures to conduct
the surveys, the frequency of calculating the LLD for the sample
analyses could be reduced. Licensee representatives stated that
this issue would be reviewed and, if appropriate, LLDs would be
determined as a result of any significant changes in procedures,
equipment operating characteristics, background radiation levels -
and/or subsequent to routine calibrations.
RCT No 8, Instructions for Analysis of Swipe, Air and Liquid
Samples, dated ' January 1987, detailed a restricted area action
limit. 3 E-9 uCi/ml, for airborne particulate radionuclides
activity requiring reanalysis of the sample. The inspector
noted that 10 CFR, Part 20, Appendix B, Footnote 2.a lists the
most restrictive Maximum Permissible Concentration in air (MPCa)
as 6 E-13 uCi/ml for an unknown mixture of radionuclides in
restricted areas. The MPCa of 3 E-9 uCi/ml is utilized when
specific conditions regarding the nuclides present in the sample
are known. The inspector stated that unless the licensee had
evaluated the potential mixture of radionuclides in the sample,
the more appropriate action limit would be the most restrictive
MPCa value. Licensee representatives agreed to evaluate the use
of the detailed action limit. The inspector informed licensee
representatives that this issue would be considered an IFI and
would be reviewed during a subsequent 'nspection ,
(50-83/89-01-04).
No violations or deviations were identified
c. Environmental Reports
TS 6.6.1(5) requires a routine annual report covering the activities
of the reactor facility during the previous calendar year. The
prescribed year ends August 1 for the UFTR. Each annual operating
report is to include a summary of the nature and amount of
radioactive effluents released or discharged to the environs,
environmental surveys performed outside the facility, and exposures
received by facility personnel and visitors where exposures are
greater than 25% of the allowable limits.
The inspector verified that an annual report was prepared and issued
by the licensee in accordance with applicable TS requirements.
Details of the report are discussed in other paragraphs of this
report.
No violations or deviations were identified.
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4. Transportation (86750) .
10 CFk 71.5 requires .each licensee who transports licensed material
,
outside .the
applicable confines of of
requirements itsthe
plant or other' place
Department of use to comp
of Transportation (ly inwith the
DOT)
10 CFR Parts 170 through 189.
Processing, ' shipping, and ' storage of radioactive waste, activated.
material, and other radioactive materials at the UFTR were discussed with
' licensee representatives. Guidance for these activities is provided by
- the following procedures
S0P D.5 Reactor Waste Shipments: Preparation and Transfer, Rev. O,
dated April.1987.
S0P D.6 Control of UFTR Radioactive Material Transfers, Rev. O, dated
December 1988.
,
Licensee representatives stated that radioactive waste materials are
transferred .to the. State License for shipping. No radioactive waste
E shipments have been made since the previous inspection (Inspection-Report
No. 50-83/89-01-01) conducted March.14-17, 1988.
The majority of. shipping actions at the UFTR involved the transfer of
< activated material between ' the UFTR and other campus and research
facilities and required the establishment of regulatory authority and
accountability procedures for radioactive material. The inspector
discussed with licensee representatives NRC guidance regarding regulatory
esponsbilities for by-product material removed from non-power reactors.
The licensee noted that S0P D.b, Control of UFTR Radioactive Material
Transfers, details responsibilities for transfer and storage of such
material. The inspector reviewed licensee Transfer Records for January
through February 1989. Approximately 19 transfers were documented, four
activated foils and 15 transfers of materials irradiated in the " Rabbit
System." All transfers were in accordance with the established licensee
procedures.
No violations or deviations were identified.
5. Information Notices (ins) (92701)
The inspector determined that the following NRC ins had been received by
the licensee, reviewed for applicability, and distributed to appropriate
personnel.
'IN 88-02 Lost or Stolen Gauges, dated February 2, 1988.
IN 88-08 Chemical Reactions with Radioactive Waste Solidification
Agents, dated March 14, 1988.
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- :IN 88-22 Disposal of Sludge from Onsite Sewage Treatment facilities
at Nuclear Power Stations, dated May 12, 1988.
IN 88-32 Prompt' Reporting to NRC of Significant Incidents Involving
Radioactive Material, dated May 25. 1988.
IN 88-34 Nuclear liaterial. Control and Accountability of Non-fuel
E Special Nuclear Material at. Power Reactors, dated May 31, 1988.
'
.IN 88-62 Recent Findings Concerning Implementation of Quality
Assurance Programs by Suppliers of . Transport Packages,. dated
' August'12, 1988.
IN 88-79 Misuse of Flashing Lights for High Radiation Area Controls,
dated October 7, 1988.
IN 88-100 Memorandum of Understanding between NRC and OSHA Relating
to NRC-licensed Facilities (53 FR 43950, October 31, 1988) dated
December 23, 1988.
IN 88-101 Shipment of Contaminated Equipment between Nuclear Power
Stations, dated December 28, 1988.
No violations or deviations were identified.
6. - Licensee Action on Previous Enforcement Matters (92703)
.a. (Closed) Violation (VIO) (50-83/88-01-01): Failure to have approved
procedures for environmental surveillance and effluent monitoring.
The inspector reviewed and verified implementation of corrective
actions stated in the UF response dated May 6, 1988. The inspector
reviewed the' current RCT Procedures utilized by personnel conducting
radiation- protection activities at the UFTR reactor facility.
Currently, seventeen RCT procedures are approved by the Director,
UFTR,' for use in conducting radiation. protection activities. The
inspector noted that no directive existed detailing review and
approval authority for RCTs utilized by the licensee. Licensee
representatives stated that to improve guidance in this area, a
Memorandum of Understanding, dated February 28, 1989, regarding the
need for appropriate review and concurrence on applicable RCTs by
cognizant licensee personnel was issued from the Director, UFTR, to
the UF Radiation Safety Officer,
b. (Closed) VIO (50-83/88-01-02): Failure to conduct adequate surveys
for liquid and gaseous effluents. The inspector reviewed and
verified implementation of corrective actions stated in the UF
response dated May 6, 1988. The inspector reviewed changes to and
evaluations for gaseous and liquid effluent measurement analyses. To
evaluate Ar-41 concentration measurement accuracy, the licensee
purchased a National Bureau of Standards (NBS) traceable, simulated
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gas standard and conducted new efficiency calibrations for the
measurement system. The subsequent evaluation of Ar-41 concentration
o -measurements indicated that previous licensee analyses were
conservative ~ by approximately four percent. . For liquid waste
L releases : changes to the licensee RCTs included guidance regarding
calculation of the LLD for 'each release. and. verification that the
resultant LLD value.is approximately.one percent of, or less than the
MPCW for. gross. radioactivity in liquids released to the sanitary
sewerage . system. In . addition, the_ calculated gross activity is
required to be L below 25% MPCW or an estimate of the individual
isotopes must be conducted. Review of the most recent liquid release
records verified implementation of the licensee's corrective actions.
7. Exit Interview'(30703)
The inspection scope and findings were summarized on March 2,1989, with
those persons indicatec in Paragraph 1. The -inspector discussed and '
detailed the findings for each. area reviewed. Licensee actions regarding
p verification and-documentation of training was identified as an inspector
followup item (Paragraph 2.c). Details of the use of a 1 E-9 uCi/ml as an
action limit for airborne particulate contamination was identified as an
IFI (Paragraph 3.c). The adequacy of licensee surveys af elevated
exposure rates' around a central vertical beam port was identified as an
URI pending licensee review of previous surveys (Paragraph 2.e). Licensee
representatives acknowledged the inspector's comments. The licensee did
not identify as proprietary any of the material provided to or reviewed by
the inspector during this inspection.
During ' teleconferences between the licensee and NRC representatives on
March 10 and March 27, 1989, additional data concerning exposure rate
surveys associated with the vertical beam ports and rabbit facility were
detailed. The inspector informed licensee representatives that the
quarterly surveys were considered inadequate to evaluate the hazards
present with the vertical ports and " rabbit system" facility and thus the
URI was considered as an apparent violation of 10 CFR 20.201(b)
requirements (Paragraphs 2.e and 3.b). In addition, the determination
that exposure levels in an unrestricted area exceeded 10 CFR 20.105(b)(1)
requirements was to be considered as an apparent violation
(Paragraph 3.b).
Item Number Description and Reference
50-83/89-01-01 IFI: Verification and Documentation of-
Training for Personnel Frequenting the UFTR
facility (Paragraph 2.c).
50-83/89-01-02 VIO: Inadequate surveys to evaluate the
radiation hazards present associated with
reactor beam port and rabbit facility
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Item Number Description and Reference
,
operations. Violation of 10 CFR 20.201(b)
requirements (Paragraphs 2.e and 3.b).
'
50-83/89-01-03 VIO: Failure to maintain unrestricted area i
exposure levels, which could result in an
individual receiving a dose, to less than
two millirems in any one hour. Violation of
10 CFR 20.105(b)(1) requirements
(Paragraph 3.b).
~
50-83/89-01-04 IFI: Evaluation of airborne particulate
concentration action limit in regard to
10 CFR 20, Appendix B, MPCa requirements
(Paragraph 3.c).
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