ML23018A129
| ML23018A129 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 01/16/2023 |
| From: | Joel Jenkins Texas A&M Univ |
| To: | Holly Cruz NRC/NRR/DANU/UNPL |
| References | |
| 2023-001 | |
| Download: ML23018A129 (1) | |
Text
01/15/2023 2023-001 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 FACILITY: Texas Engineering Experiment Station/Nuclear Science Center Reactor DOCKET #: 050-0128
SUBJECT:
Self-report of Radiation Levels Exceeding Regulatory Limits ATTACHMENT: Report of Radiation Levels Exceeding Regulatory Limits Pursuant to 10 CFR 20.2203, The Nuclear Engineering & Science Center Reactor Facilities, a part of the Texas A&M Engineering Experiment Station (TEES), is herein submitting a report of violations of certain parts of 10 CFR 20.
The enclosed report details the conditions and the causes of the conditions that led to the self-reported violations. Should you have any questions or require further information, please contact me at jere@tamu.edu.
I declare under penalty of perjury that the foregoing is true and correct. Executed on 15 January 2023.
Sincerely, Digitally signed by Jere H Jenkins Jere H Jenkins Date: 2023.01.15 16:27:11
-06'00' Jere H. Jenkins Director of Reactor Facilities, Nuclear Engineering & Science Center Cc:
Holly Cruz, Project Manager, U.S. NRC Patrick Boyle, Project Manager, U.S. NRC Johnny Hurtado, Director of TEES Lisa Akin, Chief Operating Officer, TEES NSCR Reactor Safety Board Nuclear Engineering and Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551
REPORT OF RADIATION LEVELS EXCEEDING REGULATORY LIMITS Facility: Nuclear Science Center Reactor (NSCR), License R-83 Docket No: 050-0128 Report Date: 15 January 2023
SUMMARY
In accordance with 10 CFR 20.2203, the Nuclear Engineering & Science Center (NESC) is reporting violation of some regulations listed in 10 CFR 20. The violations were the result of the improper staging of byproduct material for shipment from the facility. The material created a condition where:
x Dose rates in a restricted area were in excess of the level requiring marking as a High Radiation Area, as defined in 10 CFR 20.1003, but the required signs and access controls were not in place as required in 10 CFR 20.1601 and 20.1902.
x Dose rates in an unrestricted area adjacent to the restricted area where the material was stored exceeded those requiring marking as Radiation Area as defined in 10 CFR 20.1003, but the area did not have the appropriate signage as required by 10 CFR 20.1902.
x The public dose rate limit of 0.002 R/hr was exceeded in an area accessible to a small number of select university employees not directly associated with the NESC, or covered by the NESC Radiation Safety Program, as set by 10 CFR 20.1301.
The items above represent the regulations that were not met by the NESC staff in this situation.
NESC is self-reporting to the Regulator that this condition existed and providing the report in accordance with 10 CFR 20.2203. The licensee also states the following:
x These conditions were not the direct result of reactor operations.
x There was no offsite release of radioactive material.
x The byproduct material was at all times secured against theft and diversion.
x No member of the NESC staff received doses exceeding local administrative or Federal occupational limits.
x No member of the public received a dose in excess of the allowed regulatory limits.
The details and other required information are presented in the subsequent sections of this document.
DETAILS In late November during routine facility walk-through, it was discovered that Radioactive Byproduct Material being staged for shipment on the Lower Research Level had exposure levels that required marking as a High Radiation Area as defined in 10 CFR 20.1003, but they were not marked and controlled as such in accordance with 10 CFR 20.1601 and 20.1902.
Event report for 050-00128 Page 1 of 3 01/15/2023
The material was also close enough to a door to the outside of the building, therefore an unrestricted area, such that the dose rates in the area around the door exterior exceeded that requiring being marked as a Radiation Area as defined in 10 CFR 20.1003 and required under 10 CFR 20.1902. The dose rate at the door was measured at 0.007 R/hr, which exceeds the allowed dose rate for members of the public of 0.002 R/hr.
While the unrestricted area described above is within the fenced boundary of the facility, and access is controlled to members of the public, certain select members of the university staff not associated with the NESCand therefore not covered by the NESC Radiation Safety Programvisit the unrestricted area outside the door momentarily at various times during a 24-hour period. The total dose received for each of those visits to that area would be approximately 0.1 mR (0.0001 R).
From as best as can be determined, the condition existed for less than one week. If it is assumed that only one individual conducted all of the visits, and four visits were made per 24-hour period over 7 days, the total dose received by that one individual over the course of the week would not have exceeded 2.8 mR. Since the total number of possible visits would be distributed over at least 7 individuals during the seven-day period, the maximum total dose to any one individual would be less than 1 mR.
IMMEDIATE CORRECTIVE ACTIONS The following immediate corrective actions were taken on discovery of the described situation:
- 1. Access to the Lower Research Level and the area outside the door was restricted to personnel authorized by the Facility Director (FD) and the Facility Radiation Safety Officer (RSO).
- 2. A detailed survey of the area was conducted by the FD, RSO, and a member of the Radiation Safety Staff.
- 3. Appropriate signage and access controls were placed for the High Radiation Area and Radiation Area.
- 4. The facility entered an operational stand-down for fourteen (14) days, or until otherwise lifted.
SUBSEQUENT CORRECTIVE ACTIONS
- 1. The staged material was reconfigured and, in some cases, relocated to reduce the dose rates outside the door to much lower than the public dose limit of 0.002 R/hr.
- 2. NESC staff attended meetings on Safety Culture, ALARA principles, and procedures for material control.
- 3. Staff were counseled on the necessity of reporting situations relative to workplace safety to NESC leadership.
- 4. Staff were re-trained on procedures, proper storage of radioactive materials with the required access controls and signage, and the use of survey instruments.
- 5. Staff were counseled on the division of responsibilities of the Operations and Radiation Safety Office.
- 6. Procedures and procedural controls were examined for needed revisions.
- 7. Surveys are performed and dose maps are created and posted outside the staging areas when byproduct material is prepared for shipment.
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Revisions to the relevant procedures are underway and will be completed by 30 June 2023.
Prior to the situation described in this report, NESC staff had already undertaken a significant revision of the Radiation Safety Program Training Plan to align with ANSI/HPS 13.36. This revision will be completely implemented by 30 June 2023.
DOSE ESTIMATES OR MEASURED VALUES As stated in a previous section, no member of the public received a total dose in excess of the 0.100 R annual limit set by 10 CFR 20.1031. In the area accessible to the public, the dose rates varied from 0.007 R/hr to 0.013 R/hr. The area that would have been visited by the university employees was 0.007 R/hr. The estimated total dose to any of the university employees considered members of the public is 0.0028 R.
No NESC employees received doses in excess of Federal occupational dose limits.
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