IR 05000112/1987001: Difference between revisions

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{{Adams
{{Adams
| number = ML20207S709
| number = ML20238A241
| issue date = 02/26/1987
| issue date = 09/03/1987
| title = Insp Rept 50-112/87-01 on 870126-30.Violations Noted:Failure to Maintain Records in Proper Units,Failure to Provide Emergency Planning Training & Failure to Maintain Ltrs of Agreement
| title = Ack Receipt of 870414,0529 & 0720 Ltrs Informing NRC of Steps Taken to Correct Violtaions Noted in Insp Rept 50-112/87-01.Addl Info Re Violation a Provided in Adequate to Resolve Concerns,Per 870617 Telcon
| author name = Baer R, Murray B
| author name = Yandell L
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Egle D
| addressee affiliation =  
| addressee affiliation = OKLAHOMA, UNIV. OF, NORMAN, OK
| docket = 05000112
| docket = 05000112
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-112-87-01, 50-112-87-1, NUDOCS 8703200200
| document report number = NUDOCS 8709090204
| package number = ML20207S705
| title reference date = 07-20-1987
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO EDUCATIONAL INSTITUTION, OUTGOING CORRESPONDENCE
| page count = 8
| page count = 2
}}
}}


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=Text=
=Text=
{{#Wiki_filter:7 --
{{#Wiki_filter:I c5 >  SEP 3 1987 In Reply Refer To:
. ..
Docket: 50-112/87-01 The University of Oklahoma ATTN: Dr. Davis M. Egle Director, AMNE 865 Asp Ave., Roon 212 Norman, Oklahoma 73019 Gentlemen:
APPENDIX C U.S. NUCLEAR REGULATORY COMMISSION REGION IV,
Thank you for your letters of April 14, May 29, and July 20, 1987, in rcsponse to our letters and Notice of Violation dated March 16, 1987. Jr. your May 29, 1987, letter you stated that you did not feel that Violation A regarding the requirement to maintain contamination survey records in units of disintegrations per urit time or in curies had occurred. The bases for the Violation were discussed during a telephone conversation on June 17, 1987, between Messrs. Craig Jensen and Paul Skierkowski of your staff and Messrs. Blaine Murray and Ronald Baer of this office. Based on the results of the telephone conversation, your staff agreed to provide additional infor;2ation concerning corrective actions for Violation A. This additional information was provided in your July 20, 1987, letter and we find that your response is adequate to resolve our concerns.
-
 
~NRC Inspection Report: 50-112/87-01 License: R-53 Docket: .50-112 Licensee: University of Oklahoma 865 Asp Ave., Room 212 Norman, Oklahoma 73019 Facility Name: AGN-211P, Research Reactor (100W)
We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
      <
 
Inspection At: University of Oklahoma, Norman, Oklahoma
Sincerely, ORIGINAL SIGNED BY:
-
Lawrence A. Yandell, Chief Radiological Protection and Safeguards Branch CC:
Inspection Conducted: January 26-30, 198/  I Inspector:
University of Oklahoma  University of Oklahoma ATTN: Dr. E. H. Klehr, Chairman ATTN: Dr. C. Jensen, Reactor Director Reactor Safety Committee  AMNE 865 Asp Avenue  865 Asp Avenue Norman, Oklahoma 73019  Norman, Oklahoma 73019 i
Rf E. 3aer, Radiation Specialist, Facilities 2/I Date '
bec: (see next page)
      /
RIV:FRPS  C:FRPS C:RPSB.
Radiological Protection Section-Approved: (llAdOl/l dAi(#1  8[b[b7 Date '
 
B. Murray, Chief,' Facilijties Radiological Protection Section Inspection Summary Inspection Conducted January 26-30, 1987 (Report 50-112/87-01)
I REBaer/j  BMutray UsYande
Areas Inspected: Routine, unannounced inspection of the licensee's organization and management controls, operations and maintenance logs, records, operator requalification program, radiation protection, radioactivity releases, transportation, emergency planning, physical security plan, nuclear material safeguards, and an allegatio Results: Within the areas inspected, three violations were identified (failure to maintain records in proper units, paragraph 8; failure to provide emergency planning training, and failure to maintain letters of agreement, paragraph 13).
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University of Oklahoma -2-bec to DMB (IE01)
bec distrib. by rih RPS R. D. Martin, RA RPSB RIV File DRSP RSB MIS SYSTEM l    RSTS Operator l    Inspector Section Chief L. A. Yandell l    R. L. Bangart R. E. Hall H. N. Berkow, NRR M. E. Emerson t
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j University of Oklahoma  '
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JA. 2 41987 '


8703200200 870316 2 PDR ADOCK 0500
ll
      ***e-SCHOOL OF AEROSPACE, MECHANICAL  '- I'
l  AND NUCLEAR ENGINEERING l  865 Ato Avenue, Room 212  i
        ,
Norman. Oklahoma 73019 Juiy 20, 1987 Hos) 325 5011 l
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_ __
Mr. J. F. Gagliardo, Chief Renetor I'rojects Branch USNRC - Region IV Gil Ryan Plaza Drive Sulte 1000 Arlington, TX 76011 Docket: 50-112/87-01 License: R-53
__--_--__-z---.- _ _ _ __----- _ __ _ -- _-- _ - _ __
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i L
DETAILS l~ Persons Contacted
* M. Egle, Director, School of Aerospace, Mechanical and Nuclear Engineering
*C. M. Jensen, Reactor Director and Senior Reactor Operator
*P. Skierkowski, Radiation Safety Officer M. C. Smith, Radiation Safety Technician K. A. Messana, Safety Inspector, Department of Public Safety D. McGhee, Captain, Norman Fire Department The NRC inspector also. interviewed other licensee and City of Norman employees including police officers and fireme * Denotes those present during the exit interview on January 30, 198 . Status of Facility The AGN-211P reactor was operated approximately 40 times between January 11, 1985, and April 24, 1986. The reactor has not been operated since April 24, 1986. The licensee no longer offers courses of instruction in the School of Nuclear Engineering or performs research in nuclear technology which would require the operation of the reactor. The licensee has discussed with the NRC procedures for "mothballing" the reacto . Organization and Management Control The NRC inspector reviewed the organization and management controls to determine compliance with Technical Specification (TS) The current organization was verified to be consistent with TS Figure 4,
" Administrative Organization of University of Oklahoma Reactor AGN 211P"-
except for the positions of Reactor Supervisor and Reactor Staff. The TS allows the Reactor Director to also serve as the Reactor Supervisor. The status of licensed operators, membership and meetings or the Reactor Safety Committee (RSC), and other matters concerning supervision of the reactor facility were examined. The NRC inspector noted that the position of Reactor Director had been filled by the only qualified senior' reactor operator presently on campu The NRC inspector reviewed the minutes of meetings conducted by the RSC and verified that the committee had met quarterly since thelprevious inspection and reviewed matters related to the reactor. It was verified that records reflected attendance by designated committee member The following items were routinely reviewed by the committee:
  . _ _ _ - _ _ - _ _ - - _ _ _ _ _ - _ _


    -  -
==Dear Mr. Gagliardo:==
      - .
You will find aLLached a ecp> of the updated Laboratory Sursey Report showing "LSC Efficiencies" for H-3 and C-14. As iridicated by Mr. Baer during a recent teicphone conversation, this will meet your requirements and violation A should be closed. 1 also understand that our reply to violations B and C have been accepted and that no further reply on our part. is necessary.
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Reactor Surveillance. Logs  *
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    ' Facilities Manual .
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    . Fuel Element _ Inspection and Inventory
  '
Reactor Maintenance Log-Requalification Program-Physical. Security Pla Emergency Plan . .
Reactor Operations and Sample-Irradiation Logs
. <-
  -
Reactor; Experiments
  ,
No violations'or' deviations were identifie ?_  14; Operation and Maint$ nance' Logs
    ~
  .The NRC. inspector reviewed the following logs for the period January 1,
=
  .1985, through January 27, 1987, to determine compliance with'TS 3.1, 3.2,
  !3.3,3.4,4.2,-o.21(g),anoo.21(n).


~  ~
Sincerely yours,
i ~~
    - e ,
!
    / /
    : Reactor Operations Log Reactor Maintenance Log-All maintenance and~ operations activities appeared to have been conducted
    ?;
      ~
J[nsen Craigbr.
1,
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in.a manner consistent 1with the TS requirements and administrative
{  ' procedures.


I No'violationshar deviations were identified.
React DJ' rector CMJ/ujb i
sn-m1
_- _-


; Procedures e  EThe NRC inspector reviewed operating and surveillance procedures to
I '''
,  . determine compliance with the requirements of TS 3.4, 4.1, 4.2,-and 6.12.
RADIATION SAFETY OFFICE - UNIVERSITY OF OKLAHOMA
*
LABORATORY SURVEY REPORT  DATE N 106 User Rad. Safety Radioactive Material in use various L:boratory um TYPE survey conducted 4 p . t.b      '
GM and Swipe
    -
    .n n lab benchf4
=    g  Instrumentation
  '*6f"''    Surveyor O
    -
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~      Survey Results:
    ;
      ,1  mR/hr epm g  a Bkg A
6    e!; :: I B
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C  '
      [iii88 D 13  E 1: I F e e  E t..J o B    H I
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1 x NOTES:      Y Z = Room 105 Liquid Waste Storage Area    Z CHECKS:
LSC Efficiencies H-3  C-14  NRC-3 posted Radioactive material sign on entry Storage & work areas posted Waste containers posted Emergency procedures posted Next survey scheduled for RSO Review  Date
_ _ _ _ _ _ _ -


L'-   The reactor operations manual contained procedures for:
- - - - - - - - - _ - _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _
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        :
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    " Normal Startup, Operation and Shutdown of the AGN-211 Reactor
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        'JUN - 5 987 g      #
Reactor Startup,-Operation and Shutdown L'og
L -
  *
University ofOklahoma School oF AEROSPACE,9AECHANICAL AND NUCLEAR ENGINEERING B65 Asp Avenue. Room 212 NS$7    May 29, 1987 Mr. Lawrence A. Yandell, Chief
;    Completion of the-Irradiation Request Form
  *
Experiment Request
  '*'
(   iProcedure for Core Rearrangement
;
L-
,
,
  .The surveillance activities log contained the procedures and logs for:
l Radiological Protection and Safeguards Branch USNRC - Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011
  *
~
I    Low Water Level Switch Interlock Test
Docket:  50-112/87-01 License: R-53
  *
 
Temperatcre Interlock ~
==Dear Mr. Yandell:==
  *
The follwing is in response to y>ur letter of May 20, 1987.
ll    Circulation Pump Interlock
 
  *' ' Water Conductivity-Meter Calibration i
Licensee's Response to Violation A Although some data is taken in units of cpm instead of dpm, we do not feel that a violation has occurred. Therefore, we do not admit a violation and our reasons are as stated in the succeeding paragraphs.
  *'
 
l    Air-Water Monitor. Adjustment
"
  *
The purpose of a survey swipe is generally to detect the presence of contamination that is not detectable by means of a survey instrument (eg. 94 survey meter) calibrated in the desired units. It further can confirm if contamination detected by a survey instrument is " removable" and if necessary It is the identity of the radionuclides often can be ascertained from such a swipe.
High Voltage'DC: Power Supplies Calibration
 
  ~
not necessary to convert from cpm to dpm (in liquid scintillation samples) to If ascertain that contamination exists and has been "rsoved" by a swipe test.
[  *
!  ~
  , *-
Low Power and Period Meter Calibration
!    Linear Power Channel Calibration
'  *
Neutronic Power Calibration l
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S  i


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the output date from the scintillation counter indicates theChanging  presencethe of units contamination then decontamination actions are initiated.
  .. - _ _ - - _ _ - - _ - - _ _ _ . - _ _ _ _ _ _ _ _
 
from cpm to dpm would have no effect upon this action p*ocedure.
 
As reported in our letter of 14 April 87, standards are utilized "where applicable" in our assay procedures and conversion to dx or uCiSimilarly,  is made for ourany sample where necessary to compare to the regulatory standard.
 
survey meters are calibrated to give mR/hr readings which can be compared to regulartory ection levels. There is NO NRC standard or action level (in any radiation units) specifying levels of contamination detected by laboratory area swipes which require action. This fact was not only pointed out to the inspector at the time of the briefing but when queried he admitted he was unable to show us any standard for survey swipes. All he could do was cite 10CFR20.5 concerning the units.
 
Enclosed are blank forms we utilize for surveys of the nuclear laboratory and associated rooms.
 
Please note that for each survey point there are tw_o measurements. An mR/nr field is measured with a properly calibrated survey b'    hfM t
      -- -
 
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Mr. Lawrence Yandell May 29, 1987 Page Two instrument in the desired units and a swipe is made of the surface (for the purposes described above). We believe that these procedures more than meet the NRC requirements and request your reevaluation of this violation in light of this l additional infomation. Should you still feel we are in violation we would be l
willing to visit with pu at your regional office and present any other
'
supporting documentation you may request or provide any further explanations.


Safety and Control Rod Surveillance
Licensee's Response to Violation B 1) Admitted, the letter was out of date and overlooked. If this its is a violation and "ite-of-noncompliance" is not an alternative, as suggested by pur I
  -
  -
Emergency Evaluation Horn Test Security Alarm System Test The NRC inspector verified that limits regarding excess reactivity, control and safety rod worths, scram capabilities, and safety systems were not exceeded. The records of surveillance test results did not indicate any unusual condition No violations or deviations were identifie . Records The NRC inspector reviewed the licensee's records 'for ' reactor operations, reactor component changes /replecement, and calibrations. The licensee had replaced the four control rod drive motors in .lulv 1985, in acenrdance ,
letter, then the inspector who visited the facility should be instructed in proper procedure.
with an. approved procedure. The licensee had not made any facility modifications during the inspection perio No violations or deviations were identifie . Operator Requalification Program The NRC inspector reviewed the licensee's reactor operator requalification training program for compliance with 10 CFR.Part 55, Appendix A. The NRC inspector reviewed training documents for the currently licensed operator and previously licensed individuals to determine agreement with the requalification program approved by the NRC on February 23, 193 The NRC inspector noted the last training session was held on April 25, 1986, at which time the three licensed reactor operators were in attendance. Since April 25, 1986, the 1icensee has lost the services of two of these reactor operator Records indicate the reactor was last operated on April 24, 198 No violations or deviations were identifie . Radiation Protection 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, and 20.409 and 50.54(q).
 
2) A letter from the Noman Regional Hospital was obtained and a copy sent with our letter of 14 April, which indicates that they will reply to the emergency needs of the facility. As pointed out by the NRC, the letter has no expiration date.


The NRC inspector reviewed records, interviewed personnel, made observations, and performed independent survey CFR Part 20.401(b) requires that each licensee shall maintain records in the same units used in this part, showing the results of surveys required by 20.201(b), . . . ."  10 CFR Part 20.5(a) states that h si -
3) The letter has no expiration date, therefore, it will not expire and the violation cannot reoccur. Therefore, corrective action has been taken.


. . .
4) Full compliance was achieved as of the date of our previous letter dated April 14, 1987.


radioactivity is commonly, and for purposes of the regulations in this part shall be, measured in terms of disintegrations per unit time or in curie The NRC inspector reviewed radiation and contamination survey records of surveys performed to satisfy the requirements of 10 CFR Part 20.201(b),
.
during the period January 1,1985, through December 31, 1986, in rooms 106 and 107 of the Nuclear Engineering Laboratory (NEL) building. The NRC inspector determined that smear surveys taken to detect removable contamination were recorded in counts per minute. It was also noted that the licensee's procedures did not include a method for converting counts per minute into disintegrations per minut The NRC inspector stated that failure to maintain records in the same units used in 10 CFR Part 20.5 was considered an apparent violation of 10 CFR Part 20.401(b). (112/8701-01)
Licensee's Reponse to Violation C 1) Admitted, the Norman fire personnel and University Police were not trained by their training officers in the procedures to be followed when responding to alarms at the reactor facility.
The NRC inspector reviewed the course outline, lesson plans, and viewed video tapes of the training program, " Radiation Safety for Laboratory
, Personnel." The NRC inspector verified that individuals were receiving the training required in-10 CFR Part 19.12 and recommended by Regulatory Guide 8.1 . Radioactive Releases The licensee does not maintain a detailed environmental surveillance program (e.g. collection and analysis of water, soil, and vegetation samples). There are no specific license requirements that such a program be maintaine A licensee representative stated that no liquid effluent releasas have been made since the last inspection. The licensee's operation records indicate that gaseous releases are within 10 CFR Part 20 limit No violations or deviations were identifie . Transportation (Fuel Shipments)
The NRC inspector verified that there had been no fuel shipments since the previous operational inspectio No violations or deviations were identifie . Nuclear Materials Safeguards The NRC inspector reviewed the nuclear materials inventory program to determine compliance with 10 CFR Part 70.53. The NRC inspector reviewed the accountability procedures and practices, records and material status report The procedures, practices, and records were found to be well implemented. Responsibilities and response requirements were defined clearly and understood, and appropriate test procedures were being used.


m
2) The Noman Fire Chief and University Police Chief will be required to submit to the licensee on an annual basis that training for all personnel that may respond to an emergency at the reactor facility has been perfomed. Assistance by the reactor and radiation safety office will be offered for this training.


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3) Tne verification from the proper authority will be required annually.
]-.: .


The licensee had not received or shipped any radioactive materials s_ince
4) The date of full compliance will be December 31, 1987.
  -
the previous inspectio No violations or deviations were identifie . Physical Security Plan The NRC inspector reviewed the implementation of the licensee's physical security program through visual examinations, review of records, and
~ discussions with appropriate faculty and campus security, personnel. The review indicated that the physical security plan was being implemented, responsibilities and response requirements were defined clearly and understood, and the required tests were being performe No violations or deviations were identified.


,   .
Sincerely yo s, Crai M. ensen Rea tor irector CMJ/sjb
1 Emergency Planning
_ _.
.The NRC inspector reviewed the emergency preparedness program to determine agreement with commitments made in the Emergency Preparedness Pla The licensee fully implemented,the Emergency Preparedness Plan in November 1984 and the emergency notification list was updated on March 7, 198 CFR Part 50.54(q) requires that a licensee authorized to operate a research reactor shall follow and maintain in effect an' emergency pla Section 10.4, of the Emergency Preparedness Plan states, '.'The' Emergency Plan shall be revised and updated as required based on drill results or changes in the. facility and shall be reviewed annually by the reactor as required based on drill results or changes in the facility and shall be reviewed annually by the reactor staff to ensure the plan is adequate and up to date." Section 3.1 addresses assistance from offsite organizations and states " Written agreements with-these organizations are included in Appendix A to this plan."


The NRC inspector determined on January 28, 1987, that the letter of agreement with the Norman Municipal Hospital dated November 15, 1983, expired on October 1, 1984. The NRC inspector stated that failure to review and update the letter of-agreement with the Norman Municipal-Hospital was an apparent violation of requirements of 10 CFR Part 50.54(q). (112/8701-02)
_ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
Section 10.1, of the Emergency Preparedness Plan addresses training that will be provided to individuals with emergency response-responsibilities and states that the University Police and Norman Fire Department shall be trained on an annual basis in radiation safety and NEL facility emergency procedure _
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RADIATION SAFETY OFFICE UNIVERSITY OF OKLAHOMA
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      /\    (11/82)
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NUCLEAR REACTOR LAB N RADIATION SURVEY Date Time
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Guphite    Subcrit. l  @ U Pile    .__
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Room 103
      .
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    '
A6sembly    Is o- _
  .The NRC inspector reviewed the video tape prepared by the licensee which
            ,
  : addresses the facility emergency procedures. The NRC inspector also-
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b    S
q discussed with representatives of the University _ Police and the Norman
          ,
      '
          ,
Fire Department the-training being received. The NRC inspector determined ~
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on January 29,.1987 that training in radiation safety and the NEL facility emergency procedures were not being received by all individuals from the University Police and Norman Fire Department who would respond to an emergency at the NEL facility. The NRC inspector discussed with licensee representatives the training _ requirements contained in the Emergency s Preparedness Pla The licensee stated that training.had been provided to selected individuals in the' police and fire departments. However, other individuals who might be-required to respond to emergenc situations had not received the required training. The failure to provide the required training to all personnel is an apparent violation-of-10 CFR Part 50.54(q). (112/8701-03)
_.
^
14. - dllegation (4-86-A-109)
The NRC h'ad received a copy- of the Oklahoma Observer newspaper article from the' licensee which' had alleged that personnel working near the
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University of Oklahoma reactor had: (a) received radiation overexposures during the past 10-20 years, (b) radiation exposures in adjacent rooms
,
were above the regulatory limits, and (c) the reactor staff failed to lock -
a room directly above the reactor while the reactor was in _ operation.


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Room 105 Storage    @ Reactor Consote g    l
The NRC inspector reviewed selected reports, radiation survey records',
  -
, environmental radiation dosimeter results, person'el n radiation exposure
  .
: histories, and reactor operation logs for the period' July 1971 through December 1986:    #
  -
p Allegation, Part (a)   , I
9   -.
,  The NRC inspector's review of radiation exposure histories and li  environmental radiation dosimeter results indicated the. highest recorded exposure was less than 750 millirem / year for personnel
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assigned to wear radiation dosimetry, and less than 120 millirem / year for areas monitored by environmental radiation dosimeters. The NRC inspector was not able to substantiate this portion of the allegatio Allegation, Part (b)
The AGN-211P reactor is located below grade level in the NEL building. The NRC inspector's review of facility records indicated that rooms adjacent to the reactor facility did not increase in radiation levels as a result of reactor operations. The NRC inspector was not able to substantiate this portion of the allegatio e
_
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PSN GAMMA    NEUTRON
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_4 mR/hr  cpm mrem /hr* Reactor in operation during survey YES   NO 1      I f ye s , Power level  watts.
 
T 3      Reactor Records: Log Book    ,
4      Isotope Production  , Instrument Cal.
 
6      Smear Wipe Tests: Front of isotope storage 7      Glory Hole Room 106 West Pit Floor
 
9      Survey Instrument:
T6~      Gamma Probe  Neutron Probe W
12      NOTES:
Date of Last survey of reactor facility


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16 0 Neutron mrem /hr=    mcpm iurveyetl by      RSO Review  Date
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RADIATION SAFETY OFFICE - UNIVERSITY OF OKLAHOMA  l.
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hM    Allegation, Part-(c)V S \:    h.'    d,  , s
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t    The licensee had includsd 'in th- reactor startup, . operation,/anh '        '
shutdownlog'acheckoffline$em"storageroom(NEL-214) locked"and
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  . the reactor ope *ator had the oaly key which allows access irito .this
  '7- -
   -
room The NRC'(inspcctor's,y(view of reactor logs . indicated tLe s
storige room.hid been lock!d prior to reactor operations. The NRC          r inspe'ctor was' jat able to Yubstantiate this portjoi of the allegatio Q,
      ,
3.,    s .s :! ;.
              ,
e j'      i-15~. Exit Interview    v


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LABORATORY SURVEY REPORT  DATE
y  1 e      .
        \
    -The NRC inspector met with licensee representatives at the conclusb n ofs, '          (
NEL 106 User Rad. Safety Radioactive Material in use various Laboratory        ]
'(q
w ei.., to ,. t.b os Type survey conducted
  -
  -
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Latest revision as of 22:07, 16 December 2021

Ack Receipt of 870414,0529 & 0720 Ltrs Informing NRC of Steps Taken to Correct Violtaions Noted in Insp Rept 50-112/87-01.Addl Info Re Violation a Provided in Adequate to Resolve Concerns,Per 870617 Telcon
ML20238A241
Person / Time
Site: 05000112
Issue date: 09/03/1987
From: Yandell L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Egle D
OKLAHOMA, UNIV. OF, NORMAN, OK
References
NUDOCS 8709090204
Download: ML20238A241 (2)
v • d • e


Text

I c5 > SEP 3 1987 In Reply Refer To:

Docket: 50-112/87-01 The University of Oklahoma ATTN: Dr. Davis M. Egle Director, AMNE 865 Asp Ave., Roon 212 Norman, Oklahoma 73019 Gentlemen:

Thank you for your letters of April 14, May 29, and July 20, 1987, in rcsponse to our letters and Notice of Violation dated March 16, 1987. Jr. your May 29, 1987, letter you stated that you did not feel that Violation A regarding the requirement to maintain contamination survey records in units of disintegrations per urit time or in curies had occurred. The bases for the Violation were discussed during a telephone conversation on June 17, 1987, between Messrs. Craig Jensen and Paul Skierkowski of your staff and Messrs. Blaine Murray and Ronald Baer of this office. Based on the results of the telephone conversation, your staff agreed to provide additional infor;2ation concerning corrective actions for Violation A. This additional information was provided in your July 20, 1987, letter and we find that your response is adequate to resolve our concerns.

We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, ORIGINAL SIGNED BY:

Lawrence A. Yandell, Chief Radiological Protection and Safeguards Branch CC:

University of Oklahoma University of Oklahoma ATTN: Dr. E. H. Klehr, Chairman ATTN: Dr. C. Jensen, Reactor Director Reactor Safety Committee AMNE 865 Asp Avenue 865 Asp Avenue Norman, Oklahoma 73019 Norman, Oklahoma 73019 i

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University of Oklahoma -2-bec to DMB (IE01)

bec distrib. by rih RPS R. D. Martin, RA RPSB RIV File DRSP RSB MIS SYSTEM l RSTS Operator l Inspector Section Chief L. A. Yandell l R. L. Bangart R. E. Hall H. N. Berkow, NRR M. E. Emerson t

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      • e-SCHOOL OF AEROSPACE, MECHANICAL '- I'

l AND NUCLEAR ENGINEERING l 865 Ato Avenue, Room 212 i

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Norman. Oklahoma 73019 Juiy 20, 1987 Hos) 325 5011 l

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Mr. J. F. Gagliardo, Chief Renetor I'rojects Branch USNRC - Region IV Gil Ryan Plaza Drive Sulte 1000 Arlington, TX 76011 Docket: 50-112/87-01 License: R-53

Dear Mr. Gagliardo:

You will find aLLached a ecp> of the updated Laboratory Sursey Report showing "LSC Efficiencies" for H-3 and C-14. As iridicated by Mr. Baer during a recent teicphone conversation, this will meet your requirements and violation A should be closed. 1 also understand that our reply to violations B and C have been accepted and that no further reply on our part. is necessary.

Sincerely yours,

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?;

J[nsen Craigbr.

React DJ' rector CMJ/ujb i

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_- _-

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RADIATION SAFETY OFFICE - UNIVERSITY OF OKLAHOMA

LABORATORY SURVEY REPORT DATE N 106 User Rad. Safety Radioactive Material in use various L:boratory um TYPE survey conducted 4 p . t.b '

GM and Swipe

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1 x NOTES: Y Z = Room 105 Liquid Waste Storage Area Z CHECKS:

LSC Efficiencies H-3 C-14 NRC-3 posted Radioactive material sign on entry Storage & work areas posted Waste containers posted Emergency procedures posted Next survey scheduled for RSO Review Date

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- - - - - - - - - _ - _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _

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University ofOklahoma School oF AEROSPACE,9AECHANICAL AND NUCLEAR ENGINEERING B65 Asp Avenue. Room 212 NS$7 May 29, 1987 Mr. Lawrence A. Yandell, Chief

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l Radiological Protection and Safeguards Branch USNRC - Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011

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Docket: 50-112/87-01 License: R-53

Dear Mr. Yandell:

The follwing is in response to y>ur letter of May 20, 1987.

Licensee's Response to Violation A Although some data is taken in units of cpm instead of dpm, we do not feel that a violation has occurred. Therefore, we do not admit a violation and our reasons are as stated in the succeeding paragraphs.

"

The purpose of a survey swipe is generally to detect the presence of contamination that is not detectable by means of a survey instrument (eg. 94 survey meter) calibrated in the desired units. It further can confirm if contamination detected by a survey instrument is " removable" and if necessary It is the identity of the radionuclides often can be ascertained from such a swipe.

not necessary to convert from cpm to dpm (in liquid scintillation samples) to If ascertain that contamination exists and has been "rsoved" by a swipe test.

the output date from the scintillation counter indicates theChanging presencethe of units contamination then decontamination actions are initiated.

from cpm to dpm would have no effect upon this action p*ocedure.

As reported in our letter of 14 April 87, standards are utilized "where applicable" in our assay procedures and conversion to dx or uCiSimilarly, is made for ourany sample where necessary to compare to the regulatory standard.

survey meters are calibrated to give mR/hr readings which can be compared to regulartory ection levels. There is NO NRC standard or action level (in any radiation units) specifying levels of contamination detected by laboratory area swipes which require action. This fact was not only pointed out to the inspector at the time of the briefing but when queried he admitted he was unable to show us any standard for survey swipes. All he could do was cite 10CFR20.5 concerning the units.

Enclosed are blank forms we utilize for surveys of the nuclear laboratory and associated rooms.

Please note that for each survey point there are tw_o measurements. An mR/nr field is measured with a properly calibrated survey b' hfM t

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._

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. .. .

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Mr. Lawrence Yandell May 29, 1987 Page Two instrument in the desired units and a swipe is made of the surface (for the purposes described above). We believe that these procedures more than meet the NRC requirements and request your reevaluation of this violation in light of this l additional infomation. Should you still feel we are in violation we would be l

willing to visit with pu at your regional office and present any other

'

supporting documentation you may request or provide any further explanations.

Licensee's Response to Violation B 1) Admitted, the letter was out of date and overlooked. If this its is a violation and "ite-of-noncompliance" is not an alternative, as suggested by pur I

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letter, then the inspector who visited the facility should be instructed in proper procedure.

2) A letter from the Noman Regional Hospital was obtained and a copy sent with our letter of 14 April, which indicates that they will reply to the emergency needs of the facility. As pointed out by the NRC, the letter has no expiration date.

3) The letter has no expiration date, therefore, it will not expire and the violation cannot reoccur. Therefore, corrective action has been taken.

4) Full compliance was achieved as of the date of our previous letter dated April 14, 1987.

.

Licensee's Reponse to Violation C 1) Admitted, the Norman fire personnel and University Police were not trained by their training officers in the procedures to be followed when responding to alarms at the reactor facility.

2) The Noman Fire Chief and University Police Chief will be required to submit to the licensee on an annual basis that training for all personnel that may respond to an emergency at the reactor facility has been perfomed. Assistance by the reactor and radiation safety office will be offered for this training.

3) Tne verification from the proper authority will be required annually.

4) The date of full compliance will be December 31, 1987.

Sincerely yo s, Crai M. ensen Rea tor irector CMJ/sjb

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RADIATION SAFETY OFFICE UNIVERSITY OF OKLAHOMA

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T 3 Reactor Records: Log Book ,

4 Isotope Production , Instrument Cal.

6 Smear Wipe Tests: Front of isotope storage 7 Glory Hole Room 106 West Pit Floor

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Date of Last survey of reactor facility

16 0 Neutron mrem /hr= mcpm iurveyetl by RSO Review Date

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NRC-3 posted Radioactive material sign on entry Storage & work areas posted Waste containers posted Emergency procedures posted Next survey scheduled for RSO Review Date L_____________

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