IR 05000112/1987001: Difference between revisions

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{{Adams
{{Adams
| number = ML20214H044
| number = ML20238A241
| issue date = 05/20/1987
| issue date = 09/03/1987
| title = Ack Receipt of 870414 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-112/87-01.Requests Addl Info Re Listed Violation from 870316 Notice of Violation
| 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 = Yandell L
| author name = Yandell L
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8705270256
| document report number = NUDOCS 8709090204
| title reference date = 07-20-1987
| document type = CORRESPONDENCE-LETTERS, NRC TO EDUCATIONAL INSTITUTION, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, NRC TO EDUCATIONAL INSTITUTION, OUTGOING CORRESPONDENCE
| page count = 4
| page count = 2
}}
}}


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{{#Wiki_filter:r
{{#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:
. .,
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.
MAY' 2 01987 In Reply Refer-To:
Docket: 50-112/87-01
- The University of Oklahoma ATTN: -Dr. Davis M. Egle Director, AMNE 865 Asp Avenue, Room 212 Norman, Oklahoma 73019 Gentlemen:
-Thank you for your letter of April 14, 1987, in response to our letter and the attached Notice of Violation dated March 16, 1987. Your response was also discussed during a' telephone-conversation between Mr. Craig Jensen and Mr. Ron Baer of this-office on April 24, 1987. As a result of our review, we find that additional information is needed. Specifically, the response directed in Appendix A, " Notice of Violation," transmitted with our letter of March 16, 1987, requires that the University of Oklahoma provide a written statement or explanation in reply, for each violation regarding: (1) the reason for the violation if admitted, (2) the corrective steps which have been taken and'the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved.


Your letter of April 14, 1987, did not contain the required information for the violations. listed below:
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.
Restatement of Violation A 10 CFR Part 20.401(b) requires that each licensee shall maintain records in the same units used in this part.


10 CFR Part 20.5 states that " radioactivity is commonly, and for purposes of the regulations in this part shall be, measured in terms of disintegrations per unit time or in curies." As described in 10 CFR Part 20.201(b), surveys are an evaluation of the radiation hazards incident to the production, i use, release, disposal, or presence of radioactive material or other sources of~ radiation under a specific set of conditions.
Sincerely, ORIGINAL SIGNED BY:
 
Lawrence A. Yandell, Chief Radiological Protection and Safeguards Branch CC:
The NRC inspector determined on January 29, 1987, that surveys of the Nuclear Engineering Laboratory to determine radioactive contamination levels performed during the period January 1, 1985, through December 31,
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
  ~1986, were not recorded in terms of disintegrations per unit time or in
bec: (see next page)
, curies.
RIV:FRPS C:FRPS C:RPSB.


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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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_ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.The University of Oklahoma 2 Summary of' Licensee's Response to Violation'A The~ licensee acknowledges the requirements'of 10 CFR Part 20.401(b)
requiring licensee's to maintain records in specified units and that records for posting radiation fields [20,203(b) and (c)], airborne radioactivity concentrations [20.103], radiation levels in unrestricted areas [20.106], releases to the sanitary sewerage system [20.303], and survey swipes of packages [20.205] are being complied with. The licensee '
contends that neither the regulations nor any regulatory guide specifically specifies any units or action levels (standard) for lab swipes. Therefore,.in the absence of a standard, their-procedure .
. identifies the presence of contamination and sets an appropriate level for corrective action.


NRC Evaluation of Licensee's Response The licensee denies the apparent violation. However, the licensee's response implied that the violation did occur, but no reason is given for its occurrence. The licensee did not address corrective measures to be taken to prevent further violations and when full compliance will be achieved. The licensee has provided no basis for withdrawal of the violation; therefore, the violation remains as proposed.
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Restatement of Violation B 10 CFR Part 50.54(q) requires that a licensee authorized to operate a research reactor shall follow and maintain in effect an emergency plan.
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j University of Oklahoma  '
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JA. 2 41987 '


Your emergency plan requires the reactor staff to review the plan annually to ensure it was up-to-date.
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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The NRC inspector determined on January 29, 1987, that the letter of agreement with the Norman Municipal Hospital, which is contained in your plan, had expired on October 31, 1984.
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


Summary of Licensee's Response to Violation B The licensee acknowledged that the letter of agreement was out-of-date, but contends that the emergency plan was not implemented is an incorrect observation. It is the licensee's position that there is much more to the emergency plan-than the letter update and they believe the emergency plan has been implemented. The licensee also stated the apparent violation should be an item of noncompliance, not a violation.
==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.


The licensee's response included an updated letter of agreement and stated that they are presently in compliance with the regulations.
Sincerely yours,
    - e ,
    / /
    ?;
J[nsen Craigbr.


NRC Evaluation of Licensee's Response The licensee neither admits nor denies the apparent violation. It is implicit in the licensee's response that the violation did occur. No reason is given for its occurrence. The response states that the letter
React DJ' rector CMJ/ujb i
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RADIATION SAFETY OFFICE - UNIVERSITY OF OKLAHOMA
The University of Oklahoma 3 of agreement was out-of-date and an updated letter was attached. The licensee did not address corrective measures to be taken to prevent further violations and when full compliance will be achieved. The updated letter from the hospital does not contain an expiration date. The.
*
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
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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
_ _ _ _ _ _ _ -


licensee stated that the apparent violation should be an item of noncompliance, not a violation. An item of noncompliance is a violation; therefore, the violation remains as proposed.
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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
,
l Radiological Protection and Safeguards Branch USNRC - Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011
~
Docket:  50-112/87-01 License: R-53


Restatement of Violation C 10 CFR Part 50.54(q) requires that a licensee authorized to operate a research reactor shall follow and maintain in effect an Emergency Plan.
==Dear Mr. Yandell:==
The follwing is in response to y>ur letter of May 20, 1987.


Section 10.1 of your Emergency Preparedness Plan states that individuals with emergency response responsibilities such as the University Police and Norman Fire Department shall be trained on an annual basis in radiation safety and the facility emergency procedures.
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 NRC inspector determined on January 29, 1987, that training in radiation safety and the facility emergency procedures was not being received by all individuals from the University Police and Norman Fire Department who would respond to an emergency at the facility.
"
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.


Summary of Licensee's Response to Violation C The licensee stated that the university radiation safety office conducts annual training for police and fire personnel. The persons that attend are generally the higher grade officers with training responsibility within their own departments. The licensee does not have jurisdiction over these departments and feel they have completed their obligation to the emergency plan. The licensee's emergency response procedure requires that a knowledgeable and trained individual is called and responds during an emergency. The reactor facility is in the process of being mothballed and the licensee plans to request that the emergency plan be modified or deleted.
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.


NRC Evaluation of Licensee's Response The licensee neither admits nor denies the apparent violation. The licensee does not propose any corrective action to ensure that support personnel are adequately trained to respond in an emergency nor action to prevent further violations. Therefore, the violation remains as proposed.
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.
The University of Oklahoma      4 Please provide the supplemental information within 20 days of the date of this letter.


Sincerely, ORIGINAL SIGNED BY:
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.
Lawrence A. Yandell, Chief Radiological Protection and Safeguards Branch cc w/ enclosures:
The University of Oklahoma ATTN: Dr. E. H. Klehr, Chairman Reactor Safety Committee 865 Asp Avenue Nerman, Oklahoma 73019 The University of Oklahoma ATTN: Dr. C. Jensen, Reactor Director AMNE 865 Asp Avenue Norman, Oklahone 73019 bcc to DMB (IE01)
bcc dist, by RIV:
RPB      E. H. Johnson, DRSP RSB      RPSB RSTS Operator      MIS System R. D. Martin, RA    RIV File R. E. Baer      H. N. Berkow, NRR B. Murray      L. A. Yandell R. L. Bangart      R. E. Hall M. E. Emerson
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4 .
Enclosed are blank forms we utilize for surveys of the nuclear laboratory and associated rooms.
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T/re    plE2M LL University ofOftfahoma     }j SCHOOL OF AEROSPACE, MECHANICAL ANO NUCLEAR ENGINEERING 865 Asp Avenue, Room 212 Norman. Oklahoma 73019 (405) 325 5011 April 14, 1987 Mr. J.E. Gagliardo, Chief Reactor Projects Branch USNRC - Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 Docket: 50-112/87-01 License: R-53 O
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
      -- -


==Dear Mr. Gagliardo:==
    ._
The following letter is in reply to the inspection of 'fr. R.E. Baer and _
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  .
  .
the notice of violation sent by your office dated March 16, 1987.
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
I want to make some general observations concerning the inspection and the discrepancies that were found. I have been involved with at least 5 inspections of AGN type reactors and no inspector or set of inspectors ever spent more than 2 days at the f acility. Especially one for which the last inspection showed no items of non-compliance, no violations, had not operated during the 10 month period prior to the inspection, sud whose total operating time during the two year period between it.spections was less than the time spent by the inspector at the f acility.
 
The second item that concerns me is the way in which the region of fice has conducted its evaluation of the report by Mr. Baer. At his exit interview, Mr. Baer indicated that he considered your violation A to be a violation, which we disagree with. while your violations B and C he considered
    .
to be discrepancies or items of non-compliance, with.which I concurred. With ,
that in mind, we set out to correct those deficiences that he found. Ihe i
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decision to upgrade those items to violations was not _ warranted and I believe
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to be incorrect.
supporting documentation you may request or provide any further explanations.


The following are specific replies to the list of violations:
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
A. As stated in the Notice of Violation, it is acknowledged that 10CFR Part 20.401(b) requires that "the Licensee shall maintain records in the same units used in this part, showing the results of surveys required by $20.201(b)."
 
j  $20.201(a) also states that "when appropriate (our emphasis) such
, evaluation includes a physical survey of the location of materials and l
'
equipment, and measurements of levels of radiation or concentration of radioactive material present."
 
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M April 14, 1987
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Page Two
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  $20.201(b)(2) requires that each license make surveys as are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
 
In keeping with our commitment to ALARA, this licensee conducts very
;. detailed surveys of laboratories. These " surveys" incicie, as appropriate, i  either measurements of radiation fields in mR/hr using calibrated survey i  meters and/or swipe tests to determine the presence of radioactive j  contamination.
 
A description of our procedure for swipe tests may be of value in  '
'
understanding our position. To determine the presence of radioactive
,  contamination.:which,would not produce a radiation field, i.e. an mR/hr field that could be detected in an area survey, .we take "Q Tip" swipes of physical
:  locations such as bench tops, sinks, floors, doors, etc. These swipes are I c- analysed in a liquid scintillation counter along with standards and background samples. The standards are used to verify instrument performance. The policy
 
in evaluating the swipe results (as. printed out by the instrument in cpe) is  -
  -
  -
that a sample giving a count rate of pwice background or greater requires
letter, then the inspector who visited the facility should be instructed in proper procedure.
;  attention, i.e. decontamination. It is our premise that if the standards
;  verify efficiency performance for the instrument, a comparison of sample and i  background eps values is a valid indication of the presence or absence of radioactive contamination.
 
~
!
l 10CRF20 is specific (in units of mR/hr, uCi or dpa) for posting of i
radiation fields [20.203 (b) and (c)], determining concentrations of radioactive materials in air in restricted areas [20.103], permissible levels of radiation in unrestricted areas [20.106], releases of licensed material to l
a sanitary sewerage system [20.303] and survey swipes of received packages of licensed materials [20.205]. Our systems comply, with these requirements -
including compliance as to units of radiation measurement.
 
However, neither 10CFR nor any Regulartory Guide detail specifics for lab swipes in any units as to " action levels." Contrast this, for example, with 20.205(b)(2) which specifies the limit of removable contamination in
    ,,
microcuries per 100 square centimeter of package surf ace. In other words  , if an absolute radiation unit standard (dpa or uCi, etc.) exists, then such conversion would be appropriate.


It is oor contention that, in the absence of a standard, our procedure, as previously stated, identifies the presence of contamination and sets an appropriate level for corrective action. And the accuracy of such action is verified by analyzing standards along with the test samples, as previously    ,
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.
described. To convert from cpu to dpm or uCi would be a meaningless (and in    '
consideration of the large number of samples we take, a non-productive and very time consuming) task which would not give any better indication of the presence of contamination nor give a radiation unit to compare to a standard since a standard does not exist.


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


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


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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.
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M April 14, 1987
.Page Three      .
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We therefore do not believe, we are in violation and request that you
,
~ reexamine our procedure of lab survey / swipe methods to determine whether or
; not ,it is in fact ameting the intent of the regulations. Should reexamination result in affirmation of your previous position we .would request that you
; establish;a regulatory standard so we_ will be able to set ~ action guidelines in  ,
response to the results._we will obtain by performing the conversions you would require.


,
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.
,
We appeal this violation and feel that we are in compliance at this
<
time.


;
3) Tne verification from the proper authority will be required annually.
B. Although the letter was out of date, your contention that the emergency
[ plan was not implemented is an incorrect observation. There is much more to the emergency plan than the letter update and we feel the emergency plan has
. been implemented and that this should be an item of non-compliance not a
, violation.


An updated letter is attached and_ we are in compliance at this time. _
4) The date of full compliance will be December 31, 1987.
- C. The Radiation Safety Office has annually conducted training for police and fire personnel and the University Safety office participates in the annual i and most monthly tests of the evacuation system. The persons that attend are generally the higher grade officers .with training responsibility.within their own departments. The reactor facility and the Radiation Safety office have also produced and distributed a video explaining the precautions and problems j. that any be encountered at the facility during an emergency. Wh have also
: extended our services in the training of these personnel. We feel that since we have no jurisdiction over these departments that.we have completed our i
obligation to the emergency plan.


Since it is obviously impossible to guarantee that every person is j trained, even if we had compulsory means to do so, the emergency response i procedures detail that some person from the emergency call list must be i
Sincerely yo s, Crai M. ensen Rea tor irector CMJ/sjb
contacted. This is to insure that a knowledgeable and trained individual is
_ _.
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at' the site during an emergency. In addition to the person from the reactor staff, the procedure details that the Radiation Safety Office must be notified. This again is an attempt to insure that a trained individual is present during any eme rgency.


Although we do not feel we are in non-compliance or violation, this item will be corrected. As was stated to the inspector and discussed previously with NRC of ficials in Region IV and Washington D.C.,  the reactor facility is the process of being mothballed, hence, the reason it has not been operated in over a year. The application for modification of the technical specifications will be completed and sent to the NRC by September 1,1987. As part of that application, we will request that the emergency plan also be modified or deleted, deleting the requirement for this training. In the interim, the fuel has been removed and is secured in the fuel storage facility where it will be kept during the mothball period.
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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
M April 14, 1987
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Guphite    Subcrit. l  @ U Pile    .__
Page Four We..will be in full compliance when the NRC issues new technical
Room 103
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specifications for the mothballed reactor.
A6sembly    Is o- _
 
            ,
If you have any questions concerning the above, please contact me at (405) 325-1754.
 
Sincerley y rs,
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Craig .J sen React r Di ctor cc: Davis M. Egle, Director, ANNE v
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Attachment e
 
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Room 105 Storage    @ Reactor Consote g    l
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NORMAN REGIONALHOSPITAL
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April 7, 1987    -
        -
Mr. Craig Jensen University of Oklahoma 865 Asp, Room 212 Norman, Oklahoma 73019
Room 106 Room *
:  Re: Services and use of Norman Regional Hospital facilities in the event of a radiological incident at the University of Oklahoma.
l
 
        .
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        '
==Dear Mr. Jensen:==
770 (h    ,_ _
-
      ? ctor E 't bt  5 West Pit e; pngz    l_,_
By this letter, Norman Regio'nal Hospital agrees to provide emergency
_
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_ _ .
PSN GAMMA    NEUTRON
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care and other necessary services to the University of Oklahoma in the event of the implementation of the " UNIVERSITY OF OKLABONA RADIO 1DGICAL EMERGENCY PREPAREDNESS PLAN". The emergency care specific to a radia-tion disaster will be provided in accordance with Normen Regional
_4 mR/hr  cpm mrem /hr* Reactor in operation during survey YES  NO 1      I f ye s , Power level  watts.
-
Hospital's radiation disaster plan, and in accordance with our regular Emergency Department services.


i
T 3      Reactor Records: Log Book    ,
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4      Isotope Production , Instrument Cal.
This agreement will be effective issuediately and remain in force as long l as the parties are in agreement. In the event Norman Regional Hospital
!
desires to terminate this agreement, a 60 day written notification will I  be provided to the University of Oklahoma.


Sincere 1 ,
6      Smear Wipe Tests: Front of isotope storage 7      Glory Hole Room 106 West Pit Floor


  '
9      Survey Instrument:
M l' ay
T6~      Gamma Probe Neutron Probe W
'[CraigW.
12      NOTES:
Date of Last survey of reactor facility


, Admini t stor ones
16 0 Neutron mrem /hr=   mcpm iurveyetl by      RSO Review  Date
   .


J CWJ: dig ec: Marge Rosenfelt Bruce Smith
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RADIATION SAFETY OFFICE - UNIVERSITY OF OKLAHOMA  l.
 
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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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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'

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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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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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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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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

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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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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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12 NOTES:

Date of Last survey of reactor facility

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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LABORATORY SURVEY REPORT DATE

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NEL 106 User Rad. Safety Radioactive Material in use various Laboratory ]

w ei.., to ,. t.b os Type survey conducted

-

-

,, j ,

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' '

GM and Swipe lab bechf4 *

c c. binet n g Instrumentation g

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x NOTES: Y Z - Room 105 Liquid Waste Storage Area E CHECKS:

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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