ML20246E110
| ML20246E110 | |
| Person / Time | |
|---|---|
| Site: | 05000112 |
| Issue date: | 08/17/1989 |
| From: | Baer R, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20246E098 | List: |
| References | |
| 50-112-89-01, 50-112-89-1, NUDOCS 8908290011 | |
| Download: ML20246E110 (9) | |
See also: IR 05000112/1989001
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APPENDIX'B
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s =U.S.' NUCLEAR REGULATORY COMMISSION
REGION IV-
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( NRC.' Inspect 1on Report: 50-112/89-01 Operating. License: R-53
Docket: 50-112
Licenseei- University of Oklahoma
865 Asp Ave., Room 212
- Norman,' Oklahoma . 73019
Facility Name: AGN-211P, Research Reactor (100 KW)
Inspection At: University of Oklahoma, Norman, . Oklahoma
Inspection Conducted: May 25-26, 1989
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Inspector: bwt G i
, Lorenzb WiWorn, Radia tion Specialist . Date
Facilities Radiological'l Protection Section-
l Accompanied
By: ' Ronald E. Baer, Chief, Facilities Radiological
Protection Section
- Approvedi hM
Ronald E Baer, Chie{, Facilii.ies Radiological Date'
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Protection Section (
Inspection Summary
Inspection Conducted May 25-26, 1989 (Report 50-112/89-01)
' Areas Inspected: Routine, unannounced inspection of the licensee's management
organization, reactor operations and maintenance logs, internal audit and
review program, radiological controls, emergency preparedness, physical
. security, nuclear materials safeguards, and transportation of radioactive
. material s.
Results: . The NRC. inspector determined that the licensee had not operated the
.AGN-211P research reactor during the period covered by this inspection.
The licensee had removed fuel from the reactor, shipped the fuel to a
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Department of Energy facility, and dismantled the reactor.
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Within the areas inspected, five violations were identified (failure to
properly compose a reactor safety committee, paragraph 4; failure to conduct
semiannual reactor safety committee meetings, paragraph 4; fa11ure to provide
emergency planning training, paragraph 8; failure to conduct annual audits,
paragraph 6; and failure to obtain proper authority to dismantle a facility,
paragraph 3. Even though the licensee had dismantled the reactor without
receiving NRC approval, it appeared that dismantling activities were conducced
in a proper manner with no risk to the public health and safety
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' DETAILS
1. Persons Contacted.
L *G. B. Walker, Associate Dean, College of. Engineering
- P. Skierkowski g Radiation ' Safety Officer
E. N. Stone, Deputy Chief of Operations, University of Oklahoma. Police:
Department
S..Long, Norman Fire Department
- Denotes tho.se present during the exit interview on May 26, 1989.
2.. Followup on Previously identified Inspection Findings (92701)-
(Closed) Violation (112/87C1-01): Failure to Record Radioactive
Contamination Survey Results in Proper Units - This violation was
identified in NRC Inspection Report 50-112/87-01 and involved the failure
to reco.rd the results of radioactive contamination-surveys of the Nuclear
Engineering Laboratory in the required terms of disintegrations. per unit
time or in curies. The. licensee had revised the= laboratory survey report
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form to reflect the proper units for the liquid. scintillation survey '
results.
(Closed) Violation (112/8701-02): . Failure to Revise / Update the Letter of
Agreement - This violation was identified in NRC Inspection
Report 50-112/87-01 and involved the failure to'have a current letter of
agreement between the licensee and the Norman Municipal Hospital required
by the licensee's Emergency Preparedness-Plan. The NRC inspector noted
that'the licenses had obtained a letter from the Norman Regional Hospital
dated Apr11 7, 1987, renewing the written agreement.
(0 pen) Violation (112/8701-03): Failure to Provide Emergency Response
Training - This violation was identified u NRC Inspection
Report 50-1:?/87-01 and involved the failure to provide training in
radiation safe ^.y and the facility emergency procedures to individuals from
the University Police and Norman Fire Department who would respond to an
emergency at the facility. The licensee's response to the violation
stated that training would be provided prior to December 31, 1987. The
NRC inspector noted from discussions with the University Police and Norman
Fire Department personnel that the University Police personnel had been
provided training in radiation safety and the facility emergency
procedures, but the Norman Fire Department personnel had not been provided
with such training. This is considered a repeat violation. (See
paragraph 8.) ]
3. Status of Facility
The AGN-211P research reactor has not been operated since April 24, 1986.
The NRC issued Amendment No.12 to Facility License No. R-53 on March 8,
1988, converting the license to possession-only status and the facility to
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i a mothball status. The licensee shipped the reacter fuel on April 20,
f 1988, to a Department of Energy approved recipient and the console and
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support equipment were dismantled during the period May 18, 1988, through
July 13, 1988. -The licensee submitted to the NRC on October 25, 1988, an
application for a license amendment to approve a Dismantling and
Decommissioning Plan for the University of Oklahoma research reactor. The
plan had not been approved by the NRC at the time this inspection was
conducted.
The licensee's dismantling included such activities as follows:
Removal of reflector elements.
Removal of the reactor control rods and drive housing.
Removal of the fuel element support grid plate.
Disassembly and removal of the reactor console.
Removal of the reactor support structure.
Removal of the demineralized tank and resin beds.
Draining of the reactor pool.
10 CFR Part 50.82 states, in part, that a licensee may apply to the
Commission for authority to surrender a license voluntarily and to
decommission the facility. Each application for termination of the
license must be accompanied, or preceded, by a proposed decommissioning
plan. If the decommissioning plan demonstrates that the decommissioning
will be performed in accordanct with the regulations and not inimical to
the health the safety of the oublic, and after notice to interested
persons, the Commission will approve the plan and issue an order
authorizing the decommissioning.
The licensee's dismantling of the reactor and associated reactor
components (decommissioning the facility) prior to submitting a
decommissioning plan and receipt of an' order issued by the Commission
authorizing the decommissioning is considered a violation of 10 CFR
Part 50.82. (112/8901-01)
4. Organization and Management Controls
The NRC inspector reviewed the organization and managements controls to
determine compliance with Technical Specification (TS) 6.1.
The current organization was verified to be consistent with the current
reactor facility status. Although the Dismantling and Decommissioning
Plan had not received final NRC approval, the licensee had initiated
implementation of the plan to include the administrative organization.
The TS Figure 1, " Administrative Organization of the OU Reactor,"
specified a Reactor Director staff position; however, subsequent to the l
shipment of the reactor fuel and dismantling of the reactor facility, the
position of Reactor Director was abolished. The Radiation Safety Officer
had taken over all responsibility of the dismantled reactor facility. {
After NRC approval of the Dismantling / Decommissioning plan, the Radiation j
Safety Officer will maintain responsibility through decommissioriing and i
clean up of the reactor site.
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.The: status'of Reactor Supervisor, licensed operators, membership and.
, meetings of the RSC, and other matters'concerning supervision of the
reactor facility were examined. . The minimum staffing requirements were
verified to be present during fuel handling operations. Subsequent to the
' shipment of the reactor. fuel, the licensed operators were terminated ana
the RSC ceased conducting meetings.
The NRC inspector reviewed the minutes of the RSC and verified that the
committee had met quarterly and reviewed matters related to the reactor
from the previous' inspection until March 28, 1988. TS 6.2.1 states, in
part, the RSC_ shall- be comprised of not less than four members appointed .
by the Vice-President for Administrative Affairs, two of whom will be the
Radiation Safety Officer and the Reactor Director. Since the
abolishment / termination of. reactor staff positions, the RSC could not be .
composed as required by,the TS. The licensee's failure to properly
compose a RSC during the period from March 28, 1988, to May 25, 1989, is
considered a violation of TS 6.2.1 (112/8901-02).
TS 6.2 6, states, in part, the chair shall be appointed by the
Vice-President for Administrative Affairs. The chair shall be responsible
to call the committee into session at least semiannually and shall make
assignments as necessary to the members of the committee. The RSC chair's
failure to call the committee into session semiannually during the period
March 28,z 1988, to May 25, 1989, is considered a violation of TS 6.2.6.
(112/8901-03)
.No deviations were identified in this area.
5. Operation and Maintenance Logs
The NRC inspector noted that the reactor had not operated during the
period covered by this inspection.
The NRC inspector reviewed the reactor maintenance logs to determine
compliance with TS 6.21(g) for the period January 31, 1987, to March 28,
1988, and TS 4.2 for the period March 28, 1988, to May 25, 1989.
All maintenance activities appeared to have been conducted in a manner
consistent with the TS requirements and administrative procedures.
No violations or deviations were identified.
6. -Internal Reviews and Audits
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The NRC inspector reviewed the licensee's review and audit program to
determine compliance with 10 CFR Part 50, and TS 6.18 for the period
January 31, 1987, to March 28, 1988, and TS 6.2 for the period March 28, ,
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1988, to May 25, 1989.
. TS 6.2.8 states, in part, that the duties of the RSC shall include an
audit performance at least annually of the reactor staff of the areas
facilities manual (procedures) maintenance logs and test procedures,
surveillance tests, and physical security plan.
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The NRC inspector determined that the Reactor Safety Committee had not
performed an annual audit of the reactor staff in the areas of the
facilities manual (procedures), maintenance logs and test procedures,
surveillance tests, and physical security plan during the period March 28,
1988, to May 25, 1989. The licensee's failure to perform such an annual
audit is a violation of TS 6.2.8.E (112/8901-04).
7. Radiological Controls
The NRC inspector reviewed the licensee's radiation protection program to
determine compliance with 10 CFR Parts 19.11, 19.12, 19.13, 20.101,
20.104, 20.201, 20 202, 20.203, 20.207, 20.401, 20.403, 20.405, 20.408,
20.409, and 50.54(q).
.The NRC inspector reviewed records, interviewed personnel, made
observations, and performed independent surveys.
a. Personnel Monitoring
The NRC inspector reviewed the licensee's personnel radiation
exposure records for the first quarter 1987 through the first quarter
1989, and noted that all neutron exposures were recorded as O mrem
and the maximum beta / gamma exposure was 125 mrem per quarter, with an
average of 18 mrem per quarter. This review included the personnel
exposure records for personnel involved in the fuel handling during
the fuel transfer and shipment operations. The exposures associated
with this. operation averaged less than 12 mrem.
No violations or deviations were identified.
b. Radiation Monitoring Instrumentation
The licensee's portable radiation monitoring instrumentation
calibration program appeared to satisfy the recommendations of NRC
Regulatory Guide 8.21 and ANSI Standard N323-1978. Calibration
records were found to be up-to-date and accurate.
The licensee's on-hand stock of portable radiation monitoring
instruments appeared adequate to support facility radiological
surveys. The licensee's completed facility radiation survey records
were reviewed and found to be well documented. The NRC inspector
conducted confirmatory measurements (beta gamma) of radiation and
found that the results were in agreement with the licensee's most
current results.
No violations or deviations were identified.
c. Radioactive Releases
The NRC inspector reviewed the licensee's analysis of the reactor
shield tank water prior to release to the sanitary sewerage system.
Samples were taken at various depths in reactor shield tank. The j
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licensee's analysis =for alphs, beta., tritium, and gamma radionuclides
indicated concentration levels below the units specified for
unrestricted areas in 10 CFR Part-20, Appendix B.
No violations or deviations were identified.
d. Surveys
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Tne NRC inspector reviewed radiation and contamination survey records
regarding surveys performed by the licensee's staff to determine
compliance with 10 CFR Part 20 and agreement with the licensw's
procedures. The licensee's staff had performed a radiation sud-
contamination survey on the reactor' shield tank after drain'.ng. All
surveys were documented according to department procedures. The
survey results revealed no areas with radiation levels in excess of.
the regulatory limits.
The NRC inspector noted that the licensee had used a Geiger-Mueller
tube type of laboratory instrument to perform alpha and beta
radiation contamination'ecunting. The background count rate was
approximately 54 counts per minute and the system efficiency had.
been determined to be approximately 4.6 percent for alpha
radiation. The NRC inspector discussed with licensee
-representatives that with a releast limit of 20 disintegrations per
minute-(dpm) for alpha radiation and 200 dpm for beta' radiation that
a more efficient counting system would be desirable. The licensee-
stated that all material being released for unrestricted usage and
the final release survey of 'the reactor laboratory facility would be-
swiped for removable radioactivity. These swipes would-be counted on
a instrument capable of determining separately the alpha and beta
radioactivity.
No violations or deviations were identified.
The NRC inspector reviewed the emergency preparedness program to determine
agreement with commitments made in the Emergency Preparedness Plan.
10 CFR Part 50.54(q) requires that a licensee authorized to operate a
research reactor shall follow and maintain in effect an emergency plan.
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I- The issuance of Amendment No.12 to Facility License No. R-53, dated
March 8, 1989, granted the licensee an exemption from 10 CFR 50.54(q),
which required an emergency plan for non power reactors.
The Emergency Plan had been properly implemented, except during the period
from January 31, 1987, to March 8, 1989. Section 10.1 of the Emergency
Plan addressed training that would be provided to individuals with
emergency response responsibilities and stated that the University Police
and Norman Fire Department shall be trained on annual basis in radiation
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safety and the Nuclear Engineering Laboratory facility emergency
procedures. The NRC inspector's discussions with representatives of the
University Police and Norman Fire Department revealed that three role call-
training sessions had been conducted for the University Police personnel,
but there had been no training provided to the Norman Fire Deps-tment
personnel with emergency response responsibilities.
The failure to provide the required training to all personnel is a
violation of 10 CFR Part 50.54(q) (112/8901-05).
Neither the applicable University Police nor the applicable Norman Fire
Department personnel had received the required training during the
January 26-30, 1987., NRC inspection; therefore, this is considered a
repeat violation.
No deviations were identified.
9. Physical Security
The NRC inspector reviewed the implementation of the licensee's physical
security program to determine agreement with commitments specified in the
Physical Security Plan.
The NRC inspector noted that the Physical Security Plan had been updated
on August 31, 1988, to reflect that the nuclear f uel had been shipped from
the facility and.the console disabled and power removed.
The physical security program appeared to be implemented in accordance
with the Physical Security Plan which clearly defined responsibilities and
response requirements. Additionally, the required surveillance tests were
being performed.
No violations or deviations were identified.
10. Nuclear Materials Safeauards
The NRC inspector reviewed the licensee's special nuclear materials
receipt, inventory, and accountability program to determine compliance
with 10 CFR 70.53 and the conditions of the facility license. The
accountability procedures and practices, records and material status
reports were found to be implemented. As noted in paragraph 3, the
licensee had transferred all reactor f uel to a Department of Energy
approved recipient.
l No violations or deviations were identified.
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The NRC inspector reviewed the licensee's management-controlled program
for radiological and nuclear safety in the receipt, packaging, and
delivery to a carrier of radioactive materials to determine compliance
with 10 CFR Part 71 and 49 CFR Parts 100-177.
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The NRC. inspector noted from review of appropriate shipping manifests,
checklists, radiation survey records, and material accountability forms
for a fuel shipment on April 20, 1988, that all requirements had been met.
No violations or deviations were identified.
12. Exit Briefing.
The NRC inspe: tor met with the licensee representatives denoted in
paragraph I of this report at the conclusion of the inspection on May 26,
1989. The NRC inspector summarized the scope and findings of the
inspection. The licensee committed to counting contamination smears for
alpha and beta, separately, for the final decommissioning plan radioactive
contamination surveys.
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