ML20247M728

Proposed Tech Spec Figure 6.1, Organizational Structure of Univ of Virginia Re Reactor Facility

ML20247M728
Person / Time
Site:	University of Virginia
Issue date:	05/25/1989
From:	VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:
Shared Package
ML20247M466	List: ML20247M462 ML20247M728
References
NUDOCS 8906050112
Download: ML20247M728 (7)

Text

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DISCUSSION OF PROPOSED CHANGE IN TECHNICAL SPECIFICATIONS (This text is not to be incorporated into TS)

Amendment:

The proposed amendment involves the substitution of the current Figure 6.1 located in both the UVAR and CAVALIER Technical Specifications (TS) with a revised Figure 6.1 (provided in attachment), to indicate a forthcoming change in the reporting status of the Reactor Health Physicist, from Radiation Safety Officer (RSO) to Chairman of the Department of Nuclear Engineering.

In addition to indicating the organizational change, the revised figure provides greater detail about the organizational structure of UVA relating to the Reactor Facility. No TS text changes will be required with this amendment, just a direct exchange of figures.

A copy of the reorganization proposal approved by the RSC is attached to this submittal.

Applicability:

Figure 6.1 complements the text in TS Sections 6.0 of both the CAVALIER and UVAR TS, which are entitled " ADMINISTRATIVE CONTROLS". The administrative controls referenced apply to the operation of the CAVALIER and UVAR reactors, both located within the Reactor Facility, which also houses the Department of Nuclear Engineering and Engineering Physics. The figure presents the channels of responsibility and communication for the organization at the University of Virginia's Reactor Facility as they will be following NRC approval of the amendments. Since there are no contradictions to be resolved between the revised figure and the present TS Sections 6.0 text, the amendments do not involve TS wording changes.

Obiective:

The objective of the organizational change depicted in the revision to Figure 6.1 is to place all responsibility for the hiring, job description, personnel evaluation, disciplinary actions and other personnel management activities related to the Reactor Health Physicist with the Department of Nuclear Engineering, where the HP is permanently assigned. Doing so should facilitate resolution of management problems which are believed conducive to frequent personnel turn-overs in the HP position.

As a result of this transfer in responsibility, the Office of Environmental Health and Safety (EH&S), to which the Radiation Safety Officer is attached, will be relieved of the responsibility for direct day-to-day laanagement of the health physics program at the Reactor Facility. However, its audit and suppcrt functions would still be retained. (Please refer to enclosed copy of the reorganization proposal approved by the Reactor Safety Committee).  ;

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.(Discussion.... continued.) .

Specifications:

Specifications are not required for the simple exchange of figures in the TS.

Basis:

The Office of Environmental Health and Safety 'is a university-wide body responsible for radiological and chemical safety at' the University of Virginia. As such, EH&S monitors-individual labs for compliance with university, state and federal' regulations. Only.'in the case of the Reactor Facility does EH&S currently provide for day-to-day health physics coverage. Recent discussions held between the Reactor Facility management, Chairman of the Department of Nuclear Engineering, EH&S, the Provost Office and the Dean of Engineering resulted in acceptance of the concept whereby the Department of Nuclear Engineering would become responsible for all aspects of research reactor operation, subject to-NRC approval., EH&S would continue to perform monitoring and support functions at the Reactor Facility following introduction of the new structure.

The proposed organizational change will not modify the present TS requirement of independence between the Health Physicist and the reactor operations group headed by the Reactor Director.

Both .the Reactor Director and the. Health Physicist will report directly to the Department Chairman, and.the HP position will be supported with funds from sources outside the Reactor Facility and the Department of Nuclear Engineering and Engineering. Physics.

Given the benefits. expected from the proposed change in reporting, and the continued independence of the HP and his right to consult directly with the RSO and EH&S in regards to matters which he believes are not being adequately addressed at the local level, it can be anticipated that radiological safety at the Reactor Facility will not be adversely affected.

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PROPOSAL FOR THE REORGANIZATION OF THE REACTOR HEALTH PHYSICS PROGRAM AT.'THE REACTOR FACILITY

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I. PROGRAM ORGANIZATION ~

A. A Radiation Safety Specialist position will be transferred from the Office -of' Environmental Health

& Safety (EH&S) 'to the Department of Nuclear Engineering .and Engineering Physics (NEEP) . The.

Reactor Health Physicist (HP) occupying this position will. be paid from sources outside the Reactor Facility and - the Department of Nuclear Engineering and Engineering Physics. NEEP will be.

responsible for hiring, job descriptions, employee evaluations, disciplinary action, etc. . The HP will report directly to the Chairman of the Department of Nuclear Eng Lneering and Engineering Physics, and will be independent of the reactor operations group.

B. The HP will have stop work authority over reactor operations. The HP may contact the Radiation

. Safety Officer (RSO) on any matters concerning radiation safety as he deems necessary. It -is assured that the HP will never. be penalized or reprimanded for contacting the RSO.

C. The EH&S Office will be responsible for conducting regular audits of the health physics program at the Reactor Facility.- These audits will provide the.

level of independent program review necessary for assuring regulatory compliance and worker radiation safety at the facility. EH&S audits will normally be performed by the RSO. Audits of routine compliance _ items will be carried-out on a regular schedule and a report in a " check-list" format will be forwarded to the NEEP Chairman. At least quarterly, a more detailed audit will be conducted by EH&S, which will include independent surveys taken throughout the facility.

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II.- EH&S OFFICE DUTIES AND RESPONSIBILITIES This section outlines the specific, duties and responsibilities of the EH&S Office concarning the health physics program at the Reactor Facility. In .i general,'NEEP will be responsible for the day-to-day responsibilities of running the program while EH&S . will provide whatever backup support may be needed.

A. Program auditing as described above in Section I, Part C, will be carried out by EH&S staff.

B. . Radiation Dosimetry

1. ' EH&S will supply the monthly dosimeter service for all Reactor personnel.

2. EH&S will maintain master copies of all dosimetry records for personnel at the Reactor Facility.

3. EH&S will review dosimetry readings and send copies of these to the Reactor HP.

The HP is responsible for: maintaining exposure histories for facility personnel;;

changing dosimeters; ordering service changes as required; and making documented investigation of any exposures exceeding University AIARA levels.

C. Radioactive Material (RAM)' Shipments

1. EH&S will order RAM under by-product and Virginia licenses as per standard regular routine for University users.

2. RAM package receipt and check-in will first be performed by EH&S at the Special Material Handling Facility (SMHF), then EH&S will deliver the packages to the Reactor Facility.

3. The Reactor HP will be responsible for RAM shipments initiated at the Reactor Facility. A shipping number must be obtained from the EH&S Office for each shipment. Shipping papers will be routinely audited by the EH&S Office.

i 3 i D. Personnel Training I

1. EH&S will provide training for all I personnel needing to work with by-product l material at the Reactor Facility. The (

U.Va. Radiation Safety Training Course (8 '

hours) is offered to interested University personnel at least four times per. year.

2. EH&S will train the technicians which a will assist Reactor Facility personnel during special operations, such as fuel shipments and Emergency Plan drills. l

3. The HP will provide site specific HP

-training for Reactor Facility personnel.

E. Instrument Calibration

1. EH&S will calibrate all portable radiation survey instruments in use at the Reactor Facility. EH&S will be responsible for initiating the calibration and quarterly op-checks of these instruments. NEEP will pay for calibration of those survey instruments which must be sent off-site for vendor calibration. EH&S will recalibrates repaired survey instruments on request.

2. NEEP is responsible for purchasing and maintaining survey instruments in good functioning order and in adequate number.

3. NEEP is responsible for meeting calibration requirements for the low background counter and the gamma-ray spectroscopy systems. All other survey instrumentation is considered portable and as such is covered by item E.1. above.

4. EH&S will make available its liquid scintillation counter for analyzing routine samples from the Reactor Facility.

5. EH&S will provide facilities for thyroid or whole-body counting, when needed.

6. EH&S will at its own initiative certify RAM use hoods by performing routine hood surveys of in-service hoods. HEEP must request surveys for those hoods being returned to service.

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F. NRC Inspection Support

1. The Reactor HP will carry the primary responsibility for ' interaction with NRC inspectors at the Reactor Facility in health physics matters.

2. EH&S will make its best effort to support the Reactor HP in meeting all requirements.

or demands made by the.NRC in the health physics and emergency planning areas.

' EH&S instrument calibration and personnel' dosimetry records will be available to all-

, NRC inspectors.

G. Radioactive Waste Processing and Disposal

1. Radioactive waste not to be shipped for burial will be picked up and processed by -

the EH&S Office. NEEP must request pickups and prepare the waste to meet DOT-shipping regulations for off-site transport before it can be removed by EH&S.

2. Reactor generated radioactive waste to be shipped for burial at a low-level waste repository will be packaged for transport and manifested at the Reactor Facility.

Normally, EH&S and NEEP will combine their accumulated waste into a single shipment for burial since this a very. infrequent and costly endeavor. EH&S will review the manifests and check the packaging of Reactor Facility radwaste before it is shipped off-site. ' Costs of shipments and burial will be divided proportionally between the Reactor Facility and EH&S.

3. The Reactor HP will have the primary responsibility for radiation protection coverage of spent fuel shipments. Such shipments are made according to detailed procedures reviewed and approved by the Reactor Safety' Committee.

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