IR 05000128/1987001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-128/87-01.Requests Records Substantiating That Bromine Experiment Reviewed by Nuclear Science Ctr Before Bromine Irradiated in Reactor

ML20209F976
Person / Time
Site:	05000128
Issue date:	04/28/1987
From:	Fisher W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Richardson H TEXAS A&M UNIV., COLLEGE STATION, TX
References
NUDOCS 8704300438
Download: ML20209F976 (2)

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APR 281987 In Reply Refer To:

Docker: 50-128/87-01 .

Texas A&M University ATTN: Dr. Herbert H. Richardson, Director Texas Engineering Experiment Station College Station, Texas 77843 Gentlemen:

-Thank you for your letter of April 8,1987, in response to our letter and the attached Notice of Violation dated March 11, 1987. Your response was also discussed during a telephone conversation on April 10, 1987, between your Dr. J. A. Reuscher and Mr. H. D. Chaney of this office. As a result of our review, we find that additional information is needed. Specifically, we need copies of your records that will substantiate your position that the bromine experiment was reviewed by the Nuclear Science Center staff before the bromine was irradiated in the reactor.

Please provide the information within 15 days of the date of this letter.

Sincerely, MWB: Y WILLIAM L FISHER William L. Fisher, Chief Radiological and Safeguards Programs Branch cc:

F. E. Vandiver, President Texas A&M University College Station, Texas 77843 M. E. McLain Radiation Safety Officer Texas A&M University College Station, Texas 77843 F. Jennings, Chairman Reactor Safety Board Texas A&M University College Station, Texas 77843 p

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Texas A&M University -2-Texas State Department of Health 1100 West 49th Street Autin, Texas 78756 Texas Bureau of Radiation Control ATTN: - C. Dittman, Region 6

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RPB R. D. Martin, RA R&SPB D. Weiss, RM/ALF RIV File  !

DRSP RSB MIS SYSTEM RSTS Operator Inspector Section Chief.

W. L. Fisher R. L. Bangart R. E. Hall PBSS/NRR J. J. Dosa, Project Director

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TEXAS ENGINEERING EXPERIM ENT STATION TEXAS A&M UNIVERSITY COLLEGE STATION, TEXAS 77843-3575 l' f

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NUCLEAR SCIENCE CENTER .

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409/845-7551 Mr. Robert 'rg g5 pb 3 rg Regional Administrator U.S. Nuclear Regulatory Commission

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611 Ryan Plaza Drive, Suite 1000 APR - 91987 Arlington, Texas 76011 , ,

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Dear Mr. Martin:

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Reference: Docket 50-128/87-01 The following is in response to the USNRC Region IV letter of 11 March 1987 re-garding violations of NRC requirements identified by Mr. H. D. Chaney of your office during an inspection of NSCR activities conducted on 12-14 January 1987.

1. Failure to Evaluate Reactor Experiment The management of the NSCR contends that the Bromo-Phenanthrene experiment of 18 December 1986 was properly reviewed and approved for irradiation under Experiment Authorization E-1 "In-Pool Irradiations" (attached) with maximum credit given to the design safety features of the long tube irradiation device and the recognized relatively small total activity of 40 millicuries of e28r gaseous activity (reference letter of 27 January 1987 from NSC Director to USNRC Region IV). In addition this experiment was reviewed in detail con-cerning processing and packaging of the sample for delivery to the experi-menter. These detailed procedures are documented in NSCR Staff Meeting #374.

The development of procedures to prevent an accidental release during the processing of the Bromo-Phenanthrene was of much greater concern than an accidental gaseous release to the pool water during irradiation.

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Contrary to the stated violation of Technical Specification 6.3.3(a), an experiment of this type is evaluated against 3.6.3(b) which states:

"In calculations pursuant to 3.6.3(a), the following assumptions shall be used":

(1) If the effluent from an experimental facility exhausts through a holdup tank which closes automatically on high radiation level, at least 10% of the gaseous activity or aerosols produced will escape.

(2) If the effluent from an experimental facility exhausts through a filter installation designed for greater than 99% efficiency for 0.3-micron particles, at least 10% of these vapors can escape.

(3) For materials whose boiling point is above 130 F and where vapors formed by boiling this material can escape only through an un-distributed column of water above the core, at least 10% of these vapors can escape.

It is difficult to imagine that under the allowed conditions of 3.6.3(b) or even a 100% release the resulting radiological consequences would be in excess of the Design Basis Accident for the NSCR or for previously evaluated releases of several curies of "3Ar. It should also be noted that the W C values for 82 Br are essentially the same as those for "3Ar as indicated in Appendix B of 10CFR20. A recent evaluation of 82Br accidental releases indicate that a re-lease to the reactor building of approximately 100 curies over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period would result in a 1 W C-Yr exposure to a radiation worker. For a release to the site boundary from the exhaust stack, a 595 curie release over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> re-sults in a 1 W C-Yr exposure. These values clearly demonstrate the orders of magnitude difference in the 40 millicuries of a:Br gas when compared to analyzed incidents.

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Immediate Corrective Action Regarding the processing of Bromo-Phenanthrene in a toluene base and the con-tamination incident of 12 December 1986, there is a suspension of this type of experiment until new procedures are developed. Although the incident resulted in contamination of personnel and the facility, the exposures were minimal and releases did not approach reportable levels. USNRC Region IV and the Texas State Department of Health were notified, however, and informed of the events that followed the incident. A detailed report was issued to the TAMU Radiological Safety Officer indicating a resulting whole body burden of less than 1 mrem maximum among the four involved individuals. The actions taken by the NSC Senior Health Physicist with help from the TAMU Radiological Safety Office were proper and highly comendable. The Chairman of the Reactor Safety Board assigned Dr. Fred Sicilio of the TAMU Chemistry Department to review the procedure for the handling of the toluene base Bromo-Phenanthrene

experiment. Several suggestions were made by Dr. Sicilio.

Future Corrective Action New handling procedures will be developed for the processing of Bromo-Phenanthrene incorporating Dr. Sicilio suggestions. To improve the review and approval of the irradiation samples that contain gaseous activity, the NSC staff will consider an addition to SOP's which will provide isotopic maximum curie content values of gaseous releases such that when averaged over a year would not exceed the limits of Appendix B of 10CFR20.

Compliance Date The recent evaluation of a Br against Technical Specification 3.6.3 has been performed and the results mentioned earlier in this report. It was known in advance that several curies of e2Br activity would be the resulting maximum values. Evaluations of experiments against 3.6.3 will continue to be made using sample activity, encapsulation, and processing requirements as guide-

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lines to determine if detailed review is needed. It is very important that the policy of blanket approval of experiments be permitted not only for the NSCR but for all research reactors. It is not practical to provide detailed evaluations for the thousands of samples irradiated in a single year of opera-tion (face samples, rotisseries, pneumatic tube samples, etc.). This has been the policy at the NSCR for over 25 years of safe operation with no re-leases off-site of any consequence.

2. Failure to Implement the Emergency Plan Management agrees that the emergency support agreement letter with the St.

Joseph Hospital of Bryan, Texas had expired on 31 December 1986 and had not been renewed at the time of inspection. Contrary to requirements of having a signed agreement letter on file, the absence of such a document did not result in the NSCR losing the support of St. Joseph Hospital which is really of main concern. The agreement letters and emergency training for support of radiological events are obtained by the TAMU Radiological Safety Office and the agreements cover University activities involving radioactive materials, the AGN-201 reactor, the NSCR and the Cyclotron Institute.

Immediate Corrective Action The Radiological Safety Office was notified of the expiration of the agree-ment letter with St. Joseph Hospital and the RSO set out immediately to obtain the agreement. There was difficulty in getting a timely response from the responsible St. Joseph administrator. This problem was explained in a memo-randum from the RSO to the Director of the NSC. The memorandum is attached.

Ironically while waiting on the hospital administrator to provide a signed agreement, staff of the hospital were actively participating in the biennial emergency exercise conducted on 4 March 1987.

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To circumvent the problem of obtaining signatures to agreements, it was decided to negotiate an open renewal agreement to remain in force unless terminated by either party to the agreement. A request to change the NSCR emergency plan to accommodate such agreements was denied by the USNRC Standardization and Special Projects Directorate. However, two year agreements are permitted and this change to the approved emergency plan will be made and reported under 10CFR50.54(q).

Future Corrective Action As stated in the RSO memorandum, future plans are to enter into agreement with the new Humana Hospital in College Station, Texas as soon as possible. Future agreement letters with the City of College Station for fire and emergency medical support will be reviewed and renewed on a two year basis to coinside with biennial emergency exercises.

Date of Compliance An agreement letter with St. Joseph Hospital has been obtained which will satisfy emergency hospital support requirements until an agreement is reached with the new Humana hospital in College Station, Texas.

3. Open Item: Potential Uncontrolled Drain Path From Radioactive Effluent Tank The auxiliary liquid waste tank in question is normally empty and not on line to the liquid radioactive waste sump pumps in the demineralizer room. There is a small misunderstanding in Mr. Chaney's description for use of the tank.

Domestic water is sometimes stored in the tank to provide a supply for cooling tower makeup or other uses rather than the stated use of reactor grade water.

The auxiliary tank is sometimes used to store reactor pool water if the stall portion of the pool is drained. The pool water is later returned to the pool by way of the mixed bed demineralizer. Pool water is never used for cooling tower makeup water.

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, In reference to the installation of a drain valve to handle domestic water stored in the tank, its accidental failure would produce the same result as failure of the tank sampling valve. Both valves are located at the bottom level of the tank. Thus installation of the special drain valve does not present a hazard not previously reviewed in the SAR or SOP's.

The sample valves for the liquid waste tanks are not described in the SAR but are in SDP VII, Figure VII-C-6. Installation of the valve has been reported under 10CFR50.59 in the 1986 NSC Annual Report issued March 1987.

Changes to S0P VII involving the drain valve on the auxiliary tank will be made at the next Reactor Safety Board Meeting. Since the valve presents no additional potential hazard, it will remain on the tank but its output will be plugged to prevent an accidental draining of the tank if it is in use.

4. Open Item: Radioactive Material Control In reference to the control of radioactive materials within the reactor building and the facility site boundary, a meeting of NSC and RS0 adninistrators was held shortly following the USNRC Region IV inspection.

The meeting was called to discuss licensing options that could be considered.

, The chairman of the Reactor Safety Board was informed of the options and in turn suggested to the Licensee that the matter receive additional study. At present the NSC is waiting to receive requested licensing information from the Texas State Department of Health. Hopefully this matter can be resolved with-out undue burden on reactor operations or the Health Physics program at the NSCR.

Respectively submitted, Donald E. Feltz Director DEF/ym Enclosure cc: H. H. Richardson, Director, Texas Eng. Experiment Station F. Jennings, Chairman, Reactor Safety Board M. E. McLain, Radiological Safety Office K. L. Peddicord, Head, Nuclear Engineering Dept.

J. A. Reuscher, Director, Nuclear Research Reactor Programs

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TEXAS A&M UNIVERSITY

• COLLEGE STATION, TEXAS 77843 officr of March 25, 1987 RADIOLOGICAL SAFEn (409)S45-1361 MEM0 RAN D UM TO: Mr. Don Feltz Nuclear Science Center Texas A&M University THRU: Dr. Milton E. McLain 4 ,

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Director, Radiological Safety Office Texas A&M University FROM: Mr. John E. Simek Radiological Safety Office Texas A& M Universi ty Request for signed letters of agreement from the Associate Administration of St. Joseph Hospital, Bryan, Texas have been submit ted-in a tim ely m anner each year. The return of such documents in a timely manner has not been an annual * event.

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As there is now under construction a new hospital in College Station which will be closer and will also have a nuclear medicine department , it is the intent of the Radiological Safety

,. Office to request that the Reactor Safety Board petition Texas I

A&H University to enter into an agreement of support with the new Humana Hospital, the opening date of which is scheduled for the middle of April this year.

I All requirements of coordination and training would be

! as required under the existing agreement.

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The results of this proj ec ted change in support to an l emergency shall be forwarded to Region IV upon completion of the decision making process.

! All efforts short of bodily harm shall be continued to l secure a copy of a signed letter of agreement from St. Joseph Hospital.

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NSC Form 111 Rev 1/85

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EXPERIMENT AUTHORIZATION

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E.A. No. E-1 TITLE: IN-P0OL 1RRADIATIONS

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1. STAFF REVIEW d[

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Date 2. REACTOR SAFETY BOARD REVIEW -- The hazards associated with this experiment .

have been reviewed by the Reactor Safety Board. It is determined that this experiment does not increase the probability of occurrence of an accident previously analyzed in the Safety Analysis Report, and does not increase the possibility that an accident or malfunction of a different type than any evaluated previously will be created.

Approved: - = . % b- - '-P Chairman,RSB(/

T - t% -6 V Date A iA 3 EXPERIMENT AUTHORIZATION

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~ Date Approval sheet format revised 1/85 - Original authorization was OcIob& 2N,1980 and approval sheets are on file.

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SATETY EVALUATION OF IN-POOL IRRADIATIONS 1. Scope of Authorization This authorization covers the irradiation of materials positioned in .the NSCR pool within or near the reactor core for the production of radioisotopes or exposure to radiation. The production of any radioiso-tope in the periodic table is authorized.

2. Description Typical experiments covered by this authorization involving the irradiation of materials in the reactor pool using the NSCR as the radi-ation source are as follows: face samples, rotated samples (rotisseries),

dry tubes, samples positioned in core reflector vacancies, samples positioned in fuel vacancies, samples positioned in water spaces between

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fuel elements, and samples positioned at selected distances from the reactor core to establish gamma and neutron radiation exposures. Most samples require encapsulation in water tight containers. Loading of the experiment into the reactor is through the pool surface or in dry tubes at the reactor bridge.

3. Safety Discussion Past experience has shown that samples may be safely irradiated in many different types of encapsulating devices. The devices most commonly used are metal tubes with Swagelok fittings, heat sealed polyethylene s tubes, aluminum rotisserie containers with rubber o-ring seals, welded containers, and aluminum cans. These have provided adequate sample encapsulation to prevent contamination of the pool or work areas when used in accordance with the conditions listed in section 4. Other sample containers have also been safely used, which again are in accor-dance with the conditions listed in section 4. The pressure produced inside the encapsulation device is censidered in the design of all containers.

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' Conditions, Limitations and Restrictions 4.

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Samples will be encapsulated as necessary to prevent contamination of the NSCR pool. Approved encapsulation devices include, but are not limited to, those listed in section 3. Any encapsulation device must be reviewed and approved by the staff of the NSC. Samples which will not cause pool contamination may be irradiated without encapsulation, an example of which would be non-corroding flux wire. Samples will be prepared and handled in accordance with S0P IV-A, IV-B, and IV-G.

The following technical specifications apply to this authorization:

1.9, 1.10, 3.6, 4.3.lb, 4.3.5, 6.la, 6.2d, 6.5, 6.6. Sample loading and unloading into the NSCR will be coordinated by operations personnel to minimize any unexpected reactivity changes.

5. Conclusions The hazands associated with the production of radioisotopes and radiation exposure experiments conducted in the NSCR pool have been reviewed by the staff of the NSC and it was concluded that t,his authorization does not constitute a change in the Technical Specifi-cations, is not an unreviewed safety question, and will not increase the probability of an accident previously analyzed in the Safety 7AnalysisReport. It will not increase the possibility that .an accident or malfunction of a different type than any evaluated previously will be

/ created, and it will not reduce the margin of safety as defined in the bases for any Technical Specification.

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