ML20245G237
| ML20245G237 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 08/01/1989 |
| From: | Bassett C, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20245G230 | List: |
| References | |
| 50-297-89-01, 50-297-89-1, NUDOCS 8908150295 | |
| Download: ML20245G237 (10) | |
See also: IR 05000297/1989001
Text
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a mE! ~UNifED STATES
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. NUCLEAR REGULATORY COMMISSION
REGION 11.
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g .101 MARIETTA STREET, N.W.
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.. ATLANTA, GEORGIA 30323
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AUG 2"1989
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' Report No.: 50-297/89-01
, Licensee: (NorthCaroldia'StateUniversity.
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Raieigh NC; 27695-7909
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Docket N : 50-297- ,
License No.: R-120
$ FacilityName: North Carolina State Univ'ersity
Inspection Conducted: June'28 - 30,31989-
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, v Inspe'ctor:
.C.~H.
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Bassett , Radiation Specialist
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Batg Signed
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-Approved by: b - i 8N/bf
- T. R. Decker, Section Chief-
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Date Signed
Radiation-Safety Projects Section._
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Nuclear Materials Safety and Safeguards Branch
~ Division of Radiation. Safety and Safeguards
SUMMARY
Scope:
This'. routine; unannounced inspectiontinvolved onsite review of the licensee's
radiation protection program including: staff organization, training,
radiation control and surveillance- activities, environmental monitoring,
-transportation activities, and followup on previous saforcement issues-and
y inspector followup items (IFIs).
Results:
Staffing andj the current organizational structure appeared to be ade.,uate
although two positions in the Nuclear Engineering Department were open at the
time of the E inspection. Personnel exposures were well below established
licensee administrative .and . regulatory limits. The radiation protection
program appeared adequate to protect the health and safety of the- facility
. staff and the public. The _ licensee responded .in a timely and ,-thorough' manner
to- a previously identified violation of procedures.
.Within the r/eas inspected, the following violations were identified:
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Failure to provide' adequate training to Radiation Safety Of fice
personnel performing contamination surveys in the reactor facility to
meet the requirements of 10 CFR 19.32, Paragraph 3.
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Failure to follow- environmental procedures for collecting and/or
analyzing millipore air filters and milk samples, Paragraph 5.c.
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O PDR ADOCK 05000297
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REPORT DETAILS
1. Persons Contacted
Licansee Employees
"S. Bilyj, Chief, Reactor Maintenance
- T. Elleman, Acting Head, Department of Nuclear Engineering
- R. Mangum, Supervisor, Radiation Safety
- K. Mani, Reactor Health Physicist
- G. iiiller, Associate Director, Nuclear Reactor Program
W. Morgan, Radiation Protection Officer
Other licensee employees contacted included technicians, operators and
office personnel.
- Attended exit interview.
2. Organization and Management Controls (83743)
a. Organizatiori and Staffing
Technical Specification (TS) Section 6.1 details the organizational
structure, management responsibility and lines of authority involved
in the safe and efficient operation of the reactor facility.
The inspector reviewed the facility staff organization and verified
that the current staff organization and experience met the
requirements outlined in the TS. From discussions with licensee
representatives, the inspector noted that the positions of Head,
Department of Nuclear Engineering and Director, Nuclear Reactor
Program were vacant. The licensee indicated that persons were being
considered for each of these positions and that it was anticipated
that the department head position would be filled within two months.
The majority of the routine radiation protection activities and
surveillance are performed by the facility operations staff.
However, other groups also are used to perform surveillance and
personnel from the campus Radiation Protection Office (RPO)
participate in radiation protection activities by conducting routine
contamination surveys and air sampling in the reactor facility.
These groups are used to meet the TS required surveillance and
protection functions. The staff and support group activities
appeared to be adequate to maintain the radiation protection and
safety programs at the facility <
b. Radiation Protection Council
TS Sec..on 6.2 details the composition of the Radiation Protection
Council (RPC), qualifications of its members, required documentation {
of its responsibilities and authority, rules, and also meeting !
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frequency. This section also requires the formation of a Reactor
Safeguards Advisory Group (RSAG) to be responsible for independent
, appraisals of reactor operations and outlines the RSAG composition,
the members' qualifications and meeting frequency.
The inspector reviewed the minetes of the meetings held by the RPC
and the RSAG since the last inspection. The inspector verified that
the meetings were held as required, the groups were functioning as
outlined, and that issues reviewed and discussed were appropriate.
c. Audits and Appraisals
During a previous inspection, the licensee had indicated that an
audit of the facility's environmental monitoring program, which is
administered by the campus RPO, was conducted by a group including
members from an NRC licensed utility. The inspector had reviewed
recommended changes to the environmental monitoring program
identific during the audit and had verified that selected upgraaes
had bee completed. Licensee representatives had stated that other
recome dations, for example, changing the samples collected and
anal).ed, were being evaluated and decisions regarding their
implementation were being made.
The inspector eviewed the status of the recommended changes tnat had
not been implemented. Licensee representatives indicate 6 that all
changes that were considered necessary had been completed. The
changes made and the reasons why others were not completed were
discussed at a meeting of the RPC on April 5,1989. Following the
discussion, the RPC agreed with the conclusion that all the needed
upgrades had been completed and no further action was required. A
formal report of these actions has yet to be completed by the
Radiation Protection Officer. This report will be forwarded to the
RPC for review.
No violations or deviations were identified.
3. Traintng (83743)
10 CFR 19.12 requires the licensee to instruct all individuals working in
or frequenting any portion of the restricted area in the health protection
problems associated with exposure to radioactive material or radiation, in
precautions or procedures to minimize exposure, and in the purpose 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 ,
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During an inspection conducted during September 1988, (Inspection Report l
No. 50-297/88-04), the licensee's training programs for personnel using
and frequenting the research reactor facilities were discussed. The
need to provide the general facility radiation training to personnel prior
to being allowed access to the facility was also reviewed. Licensee
representatives stated that campus RP0 personnel, who perform surveys in
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the reactor facility, were instructed in basic radiation safety by that
l group and were given "on-the-job" training regarding specific facility
l hazards during their initial visits to the research reactor. The licensee
also stated .that this training, conducted for activities covered by a
. State of North Carolina license, an " Agreement State", was sufficient .to
meet the intent of 10 CFR 19.12. However, at the time of the inspection
in September 1988, no documentation of topics presented, nor records
indicating the training was conducted, were presented to the inspeci.or.
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Therefore, an unresolved item (URI), concerning the adequacy of the
l training provided to the RP0 technicians, was opened pending review of
applicable training materials and records.
During the current inspection, the inspector reviewed records of the
training given the RPO technicians. The inspector verified that no
records of training prior to September 1988, existed except for emergency
response training given by the Reactor Health Physicist (RHP) at the
reactor facility on August 9, 1988. No training covering all the topics
regired by 10 CFR 19.12 could be documented. However, following the
September inspection, the RHP had conducted training for all RPO
technicians and supervisors. The topics co"ered included alarm systems,
potential hazards, monitoring, respanse to emergencies, and a review of
10 CFR Parts 19. The inspector verified that this training had been
conducted as indicated by training records dated October 13, 1988.
Further training, given by the RPO, was also reviewed by the inspector.
This training, as indicated by the records, was given June 28, 1989.
Although this training was primarily Hazard Communication training, it did
include radiation protection topics.
Failure to provide the training in all topics required was identified as
an apparent violation of 10 CFR 19.12 (50-297/89-01-01).
4. Radiation Control (83743)
a. Posting
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), or (3) is not practicable, the
licensee may post a notice which describes the documents and states
where they may be examined.
During tours of the facility, tFe inspector noted the presence of the
required postings at the entra', ice to the restricted access area of
the research reactor control room. l
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b. Surveys
10 CFR 20.201(b) requires the licensee to perform such surveys as may
be necessary and are reasonable under the circumstances to evaluate
the extent of the radiation hazards that may be present.
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Procedure HP-20-14, . Radiation and Contamination Surveys, Rev. 1,
, dated January 7, 1986, requires that contamination surveys be
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performed twice weekly and direct radiation surveys be performed
monthly in the reactor bay.
The inspector reviewed the results of the contamination surveys from
October 1988 through May 1989. In general, removable contamination
was reported as less than the Lower Limit of Detection (LLD) of the
proportional counter used for counting smears. The inspector also
reviewed the results of the monthly direct radiation . surveys.
l Surveys for both gamma and neutron radiation were reported on the
survey maps. The surveys from October 1988 through May 1989
indicated general area. dose rates of less than 1 millirem per hour
(mr/hr) for beta gamma and neutron exposure ~ respectively. The
highest c o n',a ct readings were generally from 20 to 50 mr/hr for
beta gamma and neutron exposure. These were readings at contact with
such items as vent or shield plugs. Radiation readings in the
reactor bay were performed after the reactor had been brought to
100 percent (100 *!,) power for at least 30 minutes.
I c. External Exposure Review
10 CFR 20.101 delineates the quarterly radiation exposure limits to
whole body, skin of the whole body and the extremities.
10 CFR 20,202 requires that appropriate personnei monitoring devices
be worn by personnel likely to receive exposure in excess of
25 percent of the limits specified in 10 CFR 20.101 or who enter high
radiation areas.
The inspector reviewed and discussed with licensee representatives
the licensee's exposure records for persons working at or visiting
the research reactor facility from January 1,1989 to May 31,1989.
The highest accumulated whole body exposure for the period was
approximately 20 millirem. The licensee indicated that these
exposures were received by faculty personnel performing shielding
experiments. The inspector noted that the majority of the recorded
exposures were less than the detection limit, approximately
10 millirem, of the vendor provided film badge.
During tours of the facility, the inspector observed persc'. iel
monitoring devices being worn as required. The licensee uses film
badges supplied by a National Voluntary Laboratory Accreditation
Program (NVLAP) approved vendor for measuring official dose.
d. Air sampling
10 CFR 20.103(a)(1) states that no licensee shall possess, use, or
transfer licensed material in such a manner as to permit any
individual in a restricted area to inhale a quantity of radioactive
material in any period of one calendar quarter greater than the
quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for
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13 week at. uniform concentrations of radioactive material in air ~
specified in 10 CFR 20, Appendix B, Table 1, Column 1.
The inspector '. observed the licensee's continuous air . sampling
performed by a sampler located on the reactor bay bridge adjacent to
the pool. Filters are changed' and counted for rac'ioactivity on a
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daily. basi s. .The inspector also reviewed the results of. daily air-
. samples taken by RP0' personnel . . Air sampling results from October
i1988 through May 1989 were . reviewed. Filters are routinely counted
immediately upon ' collection, three to four hours later, and then
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later.to permit radon decay. For the time period reviewed, the
results indicated that airborne radioactivity was minimal, generally
.less than 3 E-12 microcuries per milliliter u'.,i/ml.
e. Extremity Monitoring
During the previous. inspection in September 1988, the inspector had
discussed the issue of - extremity dose to personnel handling
irradiated sampling baskets and the licensee's use of finger ring ,
dosimetry to determine extremity exposure. The licensee stated -that
'the need for continued use.of extremity dosimeters would be evaluated _.
and a ; decision' made regarding their routine use by experimenters.
The inspector -reviewed and discussed this issue with licensee
representatives. They had decided to continue the use of finger ring-
dosimetry in order to fully satisfy the requirements of 10 CFR 20.202
ard ensure that no one received more .than the specified limits for
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extremity exposure.
No violations or deviations were identified.
f. Facility Tours
During tours of the research reactor bay, adjacent areas, and-
. associated laboratory facilities, the inspector noted a high degree
of cleanliness and organization of materials and equipment. Selected
review of instrumentation in use at various locations throughout the
facility verified that portable. and fixed radiation survey
instrumentation were calibrated and source checked in accordance with
approved procedures. ,
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No violations or deviations were identified.
5. Environmental Protection Program (80745)
a. Procedure Review
During a previous inspection, it was determined that the procedures
used by the RP0 personnel to implement the reactor facility's
. environmental protection program had not been reviewed, maintained,
or approved by the licensee. The inspector reviewed the actions
taken by the licensee to correct this problem. All the environmental
procedures used by the campus RPO personnel to demonstrate the
licensee's compliance with TS requirements were revised and rewritten
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in a standardized format. The environmental procedures were then
presented to the RPC for review and comment. Following incorporation
of comments, the revised procedures were again presented to the RPC.
During a meeting on March 15, 1989, the RPC formally approved the
environmental procedures and the committee chairman signed them on
April 28, 1989.
No violations or deviations were identified.
b. Analytical Measurements
During the inspection in September 1988, the inspector had discussed
with licensee representatives and RPO representatives their ability
to veri fy the accuracy of their effluent and environmental
radiological measurements. Three issues regarding quality control of
analytical radiological measurements were discussed: 1) the source
material used for standards by the laboratories were not updated on
an appropriate frequency, 2) the reactor facility had not conducted
nor performed an evaluation to determine the need for self-absorption
correction for conducting gross beta gamma analyses of liquid waste
tank release samples, and 3) the licensee was not participating in
an analytical measurements cross comparison program with other state
or NRC licensed f acilities nor with the Environmental Protection
Agency (EPA). The licensee had agreed to evaluate the need for
action concerning these issues.
The inspector reviewed the licensee's actions concerning the three
issues mentioned above. The licensee had made arrangements with the
EPA to receive updated National Bureau of Standards (NBS) traceable
source material samples for standards. The licensee now has NBS
tiaceable source material dated from late 1988 through 1989.
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oldest source material is Uranium-chain (U-chain) isotopes from 1984.
RP0 representatives indicated that the EPA was also contacted
concerning the possibility of the licensee's participating in a cross
comparison or split sampling program with the EPA. An agreement had
been reached and the RPO is currently performing analytical
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measurements in such a program with the EPA. The inspector verified
l that such a program was in place and that the RPO was performing the
required analyses.
, The RHP performed an evaluation of the need for self-absorption
l corretion for gross beta gamma analysis of liquid waste tanks release
samples. This was done based on absorption curve obtained in
January 1989 using Strontium-90 (Sr-90) as the isotopes and silica
gel as the absorption medium. The analysis demonstrated that samples
did not reach the level of density thickness that required correction
for self-absorption.
No violations or deviations were identified.
c. Environmental Sampling
TS 6.3.a(8) requires operating procedures to be written, updated
periodically, and followed for radiation control. Environmental
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Radiation Surveillance Report and Analysis Procedures, updated but in
.use prior to April,1989, require that millipore filters from air
samplars located on the rooftops of various buildings on campus,
including the Riddick Engineering Building, be collected weekly and
analyzed for gross beta act'vity and that milk samples from specified
locations be collected monthly and analyzed for Sr-90 activity.
Environmental Procedure ERS-MP, Rev. O, Millipore Filters, dated
April 28, 1989, requires that millipore filters from air samplers
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located on the rooftops of various buildings on campus, including the
Riddick Engineering Building, be collected and analyzed weekly to -
determine the gross alpha and beta activity.
During a review of the licensee's environmental protection
procedures, the inspector noted that various air sample, cows milk
rample, and vegetation sample analyses were required by piocedure.
The inspector reviewed the results of the analyses performed by RPO
personnel .to demonstrate the licensee's compliance with TS
requirements. During the review, the inspector noted that the
vegetation samples had been taken and analyzed at the required
frequency but that, on numerous occasions, collection and/or
analyses of millipore filters and milk samples had not been performed
as required.
After reviewing the results of the analyses of millipore air filters,
the inspector determined that no millipore filters were collected or
analyzed from the air sampler located on the roof of the Riddick
Engineering Building during a period fror. February 28, 1989 through ,
May 30, 1989. This problem was discussed with RPO representatives I
who indicated that the air filters had not been collected due to the
fact that the air sampler had not been operational during that
period. When the air sampler had been installed on the roof of the
Riddick Building, the electricians had not run the correct wiring to
the sampler. Instead of running electrical wire through a conduit in
a wall (hard-wired), an extension cord had been used to supply power
to the air sampler, When the area was inspected by safety personnel,
the power supply situation was found to be inadequate and RPO
personnel were instructed not to use the air sampler until correct
wiring was installed to supply the power needed. The modifications
were requested but final installation was dela;)d due to higher
priority work on campus. The modifications were completed in June
and the air sampler was again placed in operation. The inspector
verified that the modifications to the wiring had been made and that
the air sampler on the roof of the Riddick Building was functioning
properly.
Following a review of the results of the analyses of cows milk
samples from June 1988 through May 1989, the inspector determined
that no analyses cf milk samples were performed during July 1988, and
from October through December 1988, and from January through March
1989. Through discussions of this problem with RP0 personnel, the
inspector determined that the samples were not analyzed due to the
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inoperability of a fume hood in the Clark Labs where the RP0
radiological laboratories are located and these analyses are
performed. No negative pressure could be maintained inside the hood
and a "part" had to be ordered to correct the problem. During the
time period that the "part" was on order, no analyses were performed.
Another fume hood in the RPO radiological lab area was operable but
material had been stored inside preventing the use of the hood. In
April the second hood was cleared of material and the hood was used
to perform the milk sample analysis. Since then, the first hood has
been repaired and the analyses will again be performed there. The
Radiation Protection Officer, who is manager of the RPO, indicated
that should this problem arise in the future, the second hood will-be
made available ' immediately so that no sample analyses are missed.
The inspector verified that the first hood was functioning properly
and that the analyses of milk samples were being performed on a
monthly basis as required.
Failure to ' collect and/or analyze millipore filters weekly and cows
milk samples monthly was identified as an apparent violation of
TS 6.3.a(8) (50-297/89-01-02).
6. Transportation (86740)
10 CFR 71.5 requires that eacn licensee who transports licensed material
outside the confines of its plant or other place of use comply with the
applicable requirements of the Department of Transportation (DOT) in
49 CFR Parts 170 through 189.
The inspector discussed the transportation of radioactive material with
licensee representatives. Only one shipm nt had been made since the last
inspection which involved shipping enriched potassuim chloride to the
University of North Carolina medical school. Licensee records indicated
that the shipment had been made in accordance with Procedure HP 10-5,
Transfer and Shipment of Radioactive Material, dated April 23, 1987. The
inspector reviewed the associated shipping records and verified that
licensee activities in this area were conducted in compliance with
approved procedures and regulations.
No violations or deviations were identified.
7. Licensee . Action of Previous Enforcement Issues (92702)
a. (Closed) VIO 50-297/88-04-02: Failure to Maintain Procedures Used by
Radiation Protection Office Personnel for Radiological Effluent and
Environmental Measurement Analyses.
The inspector reviewed and verified implementation of corrective
art 'ons stated in the North Carolina State University response dated
t amber 21, 1988. The environmental procedures have been revised
and approved by the RPC as discussed in Paragraph 5.a.
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b. (Closed) URI 50-297/88-04-01: Adequacy of Training Provided to
Radiation Protection Office Personnel to Meet 10 CFR 19.12
Requirements.
The inspector reviewed the training that had been provided to the RPO
personnel prior to working in the reactor facility. No documentation of
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any training given was available and, therefore, this item will be
considered as an apparent violation of 10 CFR 19.12 as discussed in
Paragraph 3.
8. Exit Interview
The inspection scope and results were sunmarized on June 30,1989, with
those persons indicated in Paragraph 1. The adequacy of the licensee's
-organization and staffing was discussed as were the proceedings of the RPC
and the RSAG. The inspector noted that the external exposures received by
facility personnel were well within the established administrative and
federal limits. The high degree of cleanliness and organization of
facility equipment and materials was noted. The previous URI concerning
adequacy of training for RPO personnel performing surveys in the reactor
building was discussed and licensee representatives were informed that
this item would be considered as an apparent vioiation of regulatory
requirements. Another apparent violation concerning failure to collect
and/or perform required analyses of air sample filters and milk samples
was also discussed. The licensee did not identify as proprietary any of
the material provided to or reviewed by the inspector during this
inspection.
Item Number Description and Reference
50-297/89-01-01 Violation - Failure to provide adequate training
for Radiation Protection Office personnel
performing surveys in the reactor facility
(Paragraph 3).
50-297/89-01-02 Violation - Failure to follow environmental
protection procedures for collecting and/or
analyzing millipore air filters and milk samples
(Paragraph 5.c).
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