IR 05000083/1989001: Difference between revisions

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{{Adams
{{Adams
| number = ML20244C499
| number = ML20247M647
| issue date = 04/04/1989
| issue date = 05/12/1989
| title = IR 50-083/89-01 on 890227-0302 & 27.Violations Noted. Major Areas Inspected:Radiation Protection Program Activities,Including Radiation Controls,Environ Surveillance & Monitoring & Licensee Actions Re NRC Info Notices
| title = Ack Receipt of 890504 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-083/89-01
| author name = Kuzo G, Potter J
| author name = Collins D
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name =  
| addressee name = Tulenko J
| addressee affiliation =  
| addressee affiliation = FLORIDA, UNIV. OF, GAINESVILLE, FL
| docket = 05000083
| docket = 05000083
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 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
| document report number = NUDOCS 8906050096
| package number = ML20244C492
| document type = CORRESPONDENCE-LETTERS, NRC TO EDUCATIONAL INSTITUTION, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 1
| page count = 19
}}
}}


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    - NUCLE'A R REGULATORY COMMISSION REGION ll-g 4,,,,  101 MARIETTA ST., ATLANTA GEORGIA 30323
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APR 0 7W h 4 ' Report No.: 50-83/89-01'
  ' Licensee: University of Florida
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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
      / f 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 action Results Staffing and current organizational structure met Technical Specification requirements and were adequate to implement the licensee's radiation protection progra 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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L 8904200241 890407 PDR ADOCK 05000083 Q
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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 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 hou Violation of 10 CFR 20.105(b)(1) requirements (Paragraph 3.b)
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    ' REPORT DETAILS Persons Contacted
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Licensee Employees
  *D. Munroe, Radiation Control Officer, Environmental Health and Safety ;
      '
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 personne * Attended exit interview
  # Participated in March 27, 1989, teleconference Radiation Control (83743) 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)
facilit 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 activitie 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 activitie __--_ _ -
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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 facilit No violations or deviations were identifie 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 frequenc 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 plan 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 facilit TS 6.2.5(2) requires the RSRS to conduct quarterly meetings at intervals not to exceed four month 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 facilit 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 facilit Results of the evaluation were detailed in a ;
Memorandum from the Director, Nuclear Facilities, to the RSRS, dated '
March 11, 198 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 facilit 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 facilit _ _ _ _ _ _
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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 yea 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'
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. performance. oriente 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 2,198 No significant findings were. identifie 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 revie No. violations or deviations were identified, 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 19.1 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 facilit 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 criteri 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 A _ _ _ - - .___ . _._ ____ . _ _ _
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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, Facility Tours Posting-and Labeling Requirements l
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 locatio 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 examine 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 late The inspector noted that the licensee maintained a posting of an NOV issued during a previous inspection, Inspection Report (IR)
No. 50-83/88-0 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 NR 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 material Posting of entrances into the restricted area and the labeling of containers were reviewed and discussed with licensee representative 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 statu 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 material 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 presen TS 6.3 requires the facility to be operated and maintained in accordance with approved, written procedures for personnel radiation protection, consistent with applicable regulation TS 3.9.2(2)(a) requires weekly measurements of surface contamination in the restricted are 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 action TS 3.9.2(2)(b) requires airborne particulate contamination to be measured using a high volume air sampler during the weekly checkou l Measured airborne contamination 25 percent (%) above mean normal levels are limiting conditions for operation requiring review and possible radiological safety control action .
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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 expecte :The. following procedures detailing radiological surveys conducted within the UFTR restricted area to meet the applicable TS surveillance requirements were reviewed by the inspecto Radiationf Control Techniques. (RCT) No.1, Instructions for Performing Swipe Samples, dated April 198 RCT No.4, Instructions- for Performing Radiation Surveys, . dated April 198 RCT No.8, Instructions for- Analysi3 of Swipe, Air and Liquid-Samples, dated January 198 RCT- No. p 14, Instructions for Calibrating Portable Survey Instruments, dated June 198 *
RCT No. 33, NMC' Proportional Counter Calibration, dated April 198 S0P D.1', UFTR Radiation Protection'and Contro 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 personne 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  <
inspectio Licensee representatives made the appropriate  I corrections and agreed to review the need for improvement in record documentation and subsequent review by supervisory  ;
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No abnormal levels of airborne particulate radioactive materials were noted for the facility, reported airborne particulate  !
beta-gamma activity concentrations approximated i


1
  . University of- Florida
_ _ _ _ _ _ _ _ _ _ _ - .       )
  . ATTN::'.Dr.-J. S. Tulenko      '
[ '
  ' Chairman, Nuclear b  . . .
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Engineering' Sciences Department-202. Nuclear. Sciences-Center-
  :Gainesville, FL .32611
  .Gentlemeni
  ' SUBJECT:- NRC-INSPECTION REPORT _NO.-50-83/89-01
        ~
Thank''you for your_ response'of May 4, 1989, to our Notice of. Violation, issued
  - on" April 7,1989, concerning activities ~ conducted at 'your. Unversity of Florida Training Reactor. facility. We have' evaluated your response and found that_it ~
meets the requirements of_10 CFR 2.20 We will- examine the implementation of _  <
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your corrective ' actions during future inspection We appreciate your cooperation in this ' matte


Sincerely,
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Douglas M. Collins, Chief
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    . Emergency Preparedness and Radiological Protection' Branch Division'of Radiation Safety _
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and'Sa.feguards cc: Dr.LW.'C.'Vernetson, Director of Nuclear Facilities, University of Florida
  .
   ' D Ratib A. Karam, Georgia Institute of Technology-Dr. T. S. Elleman, North Carolina State University Dr'. R. U. Mulder, University of Virginia-State of Florida
 
  ., bec: Document Control Desk T. Michaels,-NRR RII R1 RII g GKuzo J otter TDec er 5/o,/89 5 / 12-/ 8 9 5/'V/89
1.0 E-12 microcuries per milliliter (uCi/ml).
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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 appropriatel 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 instrumentatio 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 presen 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 surfac 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 boo 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, 198 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 locatio 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 surfac *An unresolved item is a matter about which more information is required to determine whether it is acceptable or may involve violations or deviation _ _ _ _ _ _ _ _ _ - _ .
 
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l~ : 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, 198 Personnel exposure measurements are conducted using film. badges provided by an National Voluntary -
Laboratory Accreditation-Program (NAVLAP) accredited vendo 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 operato 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 perio No violations or deviations were identifie . Environmental (80745)- Effluents'
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10 CFR 20.303 details liquid effluent release' limits to the sanitary sewerage syste 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 Table 1, Column 2, before release to the sanitary sewe 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 198 l RCT No. 7, Instructions for Analysis of Swipe, Air, and Liquid Samples, dated January 198 RCT No. 21, Instructions for Utilizing, Sampling and Discharging Liquid Waste Holdup Tanks, dated July 198 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, I
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    '1 >      I 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 conducte 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 release 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) month 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 198 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 perio No violations or deviations were identifie 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.
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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 dosimeter TS 3.9.2(3)(b) requires quarterly radiation exposure surveys to be
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'  conducted in unrestricted areas surrounding the UFTR comple 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: shieldin . 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 hou .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 b .presen 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 lo 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 are 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, 198 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
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the NRC were planne 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 progra 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 ag 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 presen The inspector reviewed and discussed with cognizant licensee representatives changes to the licensee's analytical radionuclides measurement program. Changes in the following areas were discusse 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 calibration I
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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 calibration 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 sampl 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 valu Licensee representatives agreed to evaluate the use of the detailed action limi 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 Environmental Reports TS 6.6.1(5) requires a routine annual report covering the activities of the reactor facility during the previous calendar yea The prescribed year ends August 1 for the UFT 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 limit The inspector verified that an annual report was prepared and issued by the licensee in accordance with applicable TS requirement Details of the report are discussed in other paragraphs of this repor No violations or deviations were identifie ._____mm.__ _ _ _ _ . __ __ _m_.___m
 
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14 Transportation (86750) .
10 CFk 71.5 requires .each licensee who transports licensed material
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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 18 Processing, ' shipping, and ' storage of radioactive waste, activate 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.198 S0P D.6 Control of UFTR Radioactive Material Transfers, Rev. O, dated December 198 ,
Licensee representatives stated that radioactive waste materials are transferred .to the. State License for shippin No radioactive waste E  shipments have been made since the previous inspection (Inspection-Report No. 50-83/89-01-01) conducted March.14-17, 198 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 materia The inspector discussed with licensee representatives NRC guidance regarding regulatory esponsbilities for by-product material removed from non-power reactor 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 procedure No violations or deviations were identifie . 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 personne 'IN 88-02 Lost or Stolen Gauges, dated February 2, 198 IN 88-08 Chemical Reactions with Radioactive Waste Solidification Agents, dated March 14, 198 _ - _ _ _ - - _ _ _ _ _ _ _
 
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    '' - :IN 88-22 Disposal of Sludge from Onsite Sewage Treatment facilities at Nuclear Power Stations, dated May 12, 198 *
IN 88-32 Prompt' Reporting to NRC of Significant Incidents Involving Radioactive Material, dated May 25. 198 IN 88-34 Nuclear liaterial. Control and Accountability of Non-fuel E    Special Nuclear Material at. Power Reactors, dated May 31, 198 '
    .IN 88-62 Recent Findings Concerning Implementation of Quality Assurance Programs by Suppliers of . Transport Packages,. dated
    ' August'12, 198 IN 88-79 Misuse of Flashing Lights for High Radiation Area Controls, dated October 7, 198 IN 88-100 Memorandum of Understanding between NRC and OSHA Relating to NRC-licensed Facilities (53 FR 43950, October 31, 1988) dated December 23, 198 IN 88-101 Shipment of Contaminated Equipment between Nuclear Power Stations, dated December 28, 198 No violations or deviations were identifie . -  Licensee Action on Previous Enforcement Matters (92703)
    . (Closed) Violation (VIO) (50-83/88-01-01): Failure to have approved procedures for environmental surveillance and effluent monitorin 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 facilit 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, (Closed) VIO (50-83/88-01-02): Failure to conduct adequate surveys for liquid and gaseous effluent 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 . syste 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 action . 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 inspectio 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
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operations. Violation of 10 CFR 20.201(b)
requirements (Paragraphs 2.e and 3.b).
 
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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).
 
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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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Revision as of 02:56, 10 February 2021

Ack Receipt of 890504 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-083/89-01
ML20247M647
Person / Time
Site: 05000083
Issue date: 05/12/1989
From: Dan Collins
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Tulenko J
FLORIDA, UNIV. OF, GAINESVILLE, FL
References
NUDOCS 8906050096
Download: ML20247M647 (1)
v • d • e


Text

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ttAY 12 35

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. University of- Florida

. ATTN::'.Dr.-J. S. Tulenko '

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' Chairman, Nuclear b . . .

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Engineering' Sciences Department-202. Nuclear. Sciences-Center-

Gainesville, FL .32611

.Gentlemeni

' SUBJECT:- NRC-INSPECTION REPORT _NO.-50-83/89-01

~

Thankyou for your_ response'of May 4, 1989, to our Notice of. Violation, issued

- on" April 7,1989, concerning activities ~ conducted at 'your. Unversity of Florida Training Reactor. facility. We have' evaluated your response and found that_it ~

meets the requirements of_10 CFR 2.20 We will- examine the implementation of _ <

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your corrective ' actions during future inspection We appreciate your cooperation in this ' matte

Sincerely,

_

< ,

Douglas M. Collins, Chief

. Emergency Preparedness and Radiological Protection' Branch Division'of Radiation Safety _

and'Sa.feguards cc: Dr.LW.'C.'Vernetson, Director of Nuclear Facilities, University of Florida

' D Ratib A. Karam, Georgia Institute of Technology-Dr. T. S. Elleman, North Carolina State University Dr'. R. U. Mulder, University of Virginia-State of Florida

., bec: Document Control Desk T. Michaels,-NRR RII R1 RII g GKuzo J otter TDec er 5/o,/89 5 / 12-/ 8 9 5/'V/89

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