IR 05000062/1987003

Forwards Summary of 870813 Enforcement Conference Re Violations Noted in Insp Rept 50-062/87-03 Concerning Potential Personnel Overexposures.List of Attendees & Recipient Handout Also Encl.Review of Issues Continuing

ML20238E306
Person / Time
Site:	University of Virginia
Issue date:	09/04/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
References
NUDOCS 8709140268
Download: ML20238E306 (41)

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Docket No. 50-62 License No. R-66 ,

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University of Virginia

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ATTN! Dr. R. U. Mulder, Director

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Ci2ridttesville, VA 22901 ' I

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Gentlemen:

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      ,3 s . SUBJECT: ENFORCEMENT CONFERENCE SUMMARY   v ,'
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bRC INSPECTION REPORT ;i0 M0-62/87-03) v

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i This letter' refers to the Enforcement Conference held at curf requeh. on l August 13, 198 This meeting concerned activities authorized for your l Vntversity of Virgir:f a. Reactor (UVAR). The issues discussed at this conference-l related to your actions associated with potential personnel overexposure. A- . list of attendees, and a copy of your handout are enclose l It is our opiniot that this meeting was beneficial and has provided a better

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understanding of the inspection findings, the enforcement issues, and the ( status of your . corrective actionc. ' We are continuing our review of these issues to sistermine the appropriateWinforcement actio , s , w

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in accorcance with Section ?.790 of use NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Roo '

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Should you have any questions conctcning this mat +er, please contact u ; Sinceraly, 0: a cy; i

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    < J. Nelson Grace     l
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     ';      i nclosurts: Enforcement Conference Summary ,
' List of Attendees HandcJt l

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i University of Virginia 2 ) i bec w/o encis: License Fee Management Branch bec w/encls: Document Control Desk Commonwealth of Virginia 1 J. Lieberman, DOE G. R. Jenkins, EICS:RII

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ENCLOSURE 1 Enforcement Conference Summary Licensee: University of Virginia Facility: University of Virginia Reactor (UVAR) License No.: R-66 l Docket No.: 50-62 Subject: Potential Personnel Overexposure { An Enforcement Conference was held at the University of Virginia, Charlottesville, Virginia on August 13, 1987, to discuss the licensee's actions 1 associated with potential personnel overexposur During the meeting, licensee personnel presented discussions of the sequence of events leading up to the violations identified in Inspection Report 50-62/87-03 and detailed the University's position concerning the specific violation I Licensee representatives pointed out that the sentence indicating the licensee took no exceptions to the violation concerning failure to document a survey in j Paragraph 2 of Inspection Report 50-62/87-03 was in error, in that the state-ment should have indicated that the licensee took exception to the violation concerning failure to document a survey. The licensee explained that the initial survey of the neutron radiography blockhouse (NRB) was made, on a brief entry, to verify a staff report of unusual high radiation fields within the  ; NR The licensee maintained that "under the unexpected circumstances of a , high radiation field of the order of 500 mil 11 Roentgen per hour (mR/hr), it j was impossible to ascertain the correct value and the exact position for which this measurement was made." The licensee pointed out that under lower power levels, with As Low As Reasonably Achievable (ALARA) considerations, surveys were made and recorded later that day and that " failure to include the first l measurement in no way compromised the survey records for the day, place and , event, or the licensee's subsequent actions." NRC representatives acknowledged i the licensee's position concerning the proposed violatio i i The licensee detailed the corrective actions taken and plans to prevent a  ; recurrence of the conditions which led to the potential for an overexposur !' Licensee representatives in the enforcement conference also agreed to define in I written procedures the guidance to be applied in distinguishing betweer, official surveys made to show compliance with the requirements of 10 CFR 20 and  ; unofficial surveys made for other purposes. The guidance would enable persnns , performing various surveys to know which surveys required documentatio '

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Enclosure 1 2

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NRC representatives expressed concern that violations of NRC requirements during modification of the nettron radiography building and control of l activities in the facility could have resulted in a significant overexposure of personnel in the facilit NRC representatives also discussed the NRC Enforcement Policy in general, and 1 expressed the opinion that the University of Virginia staff evaluation of the : ' potential overexposure and proposed violations had served to clarify and promote a common understanding of the issue i

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ENCLOSURE 2 Attendance List The following persons were in attendance: University of Virginia P. E. Benneche, Supervisor, Reactor Operations B. Copcutt, Radiation Safety Officer, Environmental Health and Safety D. W. Freeman, Research Scientist 0. T. Hale, Reactor Health Physicist R. A. Lowry, Associate Dean, School of Engineering J. L. Meen, Chairman, Reactor Safety Committee R. U. Mulder, Director, Reactor Facility A. B. Reynolds, Member, Reactor Safety Committee l T. G. Williamson, Chairman, Department of Nuclear Engineering !

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b. Nuclear Regulatory Commission A. Adams, Jr., Project Manager, Standardization and Non-Power Reactor Project Directorate, NRR J. P. Stohr, Director, Division of Radiation Safety and Safeguards, Region II L. Trocine, Enforcement Specialist, Enforcement and Investigation Coordination Staff, Region 11 F. N. Wright, Radiation Specialist, Facilities Radiation Protection Section, Region 11 S. J. Vias, Project Engineer, Division of Reactor Projects, Reactor Projects Branch No. 1, Region 11

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SEOUENCE OF EVENTS LEADING TO THE NOTIFICATION OF THE NRC ABOUT POTENTIAL RADIATION OVEREXPOSURE AT THE U. OF VIRGINIA REACTOR FACILITY l PERIOD EVENT

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Early June, 1987-Neutron radiography principal investigator (PI) and staff Research Scientist and SRO-discuss additional shielding and minor changes to be made to the neutron radiography blockhouse (NRB), consisting of a raised roof level and addition of a horizontal sample change No reactor-safety conccrn'is .! identified as being associated with these planned activities, hence no 10CFR50.59 review is don Reactor staff labor help is 1 requested by the PI, as funds are provided by a NR user for service wor t Written procedures do not appear to be required by TS or SOP' ! June 15-19, 1987 Work begins under Res. Sci.'s supervisio The PI is absent for a one week vacatio Roof of NRB is disassembled, with removal of cables to neutron camera,. electronic instrumentation, BF3 counter and electria ! illumination, etc. Beamtube water. discharge and charge system pump is disabled by1 opening electric breaker, with.beamtube fille i l Survey results show that radiation _ levels in i i the work area are less than 8"hRem/hPD c - y' Concrete blocks are added to raise ceiling level. Support stanchions and' iron I beams ' are installed. Wood beams and plywood ceiling cover are added. Res. Sci. begins his two week vacation at end.of Friday afternoo s

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a PERIOD EVENT

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I l i June 22-26, 1987 Res. Sci, is gone, but the PI is back from vacatio I UVAR is operated every day between 9 and 5 p. Corridor to NRB is  ; extended, gate frame being' removed. Support ) beams to corridor are added. Second layer of i plywood is put on roof. Graphite blocks, followed by paraffin blocks, are. replaced on roof. Electrical receptacles and lights are reinstalled. Horizontal sample changer installation is begun, and students become involved in activitie t f June 29, 1987 The PI is checking NRB progress. UVAR is i still operated daily from 9 to 5 p. Weekly radiation survey indicates same radiation levels, below 8 mrem /hr. Blockhouse I door frame is remounted, beamport sign is reinstalled, beamtube pump controls rewiring is begu ! l

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June 30, 1987 Pump wiring is finished and pump operation is j click tested in the fill mode, in the i presence of the PI. Blockhouse door alarm is reinstalled. BF3 counter is Dot reinstalled (would have compensated for operational pump).

July 1, 1987 Wire routings tidie Alignment of horizontal sample changer by students is in progres _ - _ -

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PERIOD EVENT

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July 2, 1987 'New light unit is installed.in NRB. Sample changer is.still in the process.cf alignment and mountin At 11.30'a.m., a staff member notices minute change in water level of hoses associated with the pumping system. The PI and his helpers clear water from hoses.to charging tank and leave for lunch. Water was believed to have come'from tank, not from beamtube,=as tank level is higher than'beamtub At about 1.00 p.m., a staff member enters NRB wearing a chirper'and exits shortly thereafter upon hearing increased beep rat Reactor Health physicist isLcalled to the area, and. verifies existence of high neutron and gamma radiation levels far in the corridor of theLNRB. Radiation levels in the areas exterior to the NRB are normal. Acces control is to remain in place from that point o Reactor Director is. informed of the situation shortly after' returning from. lunch at 1:45 p.m..- The PI and the Radiation Safety Officer are_then called to the scene by phone. The staff and students who worked on the NRB are called together, to gather information on recent work' periods in the area and to collect and replace film badge Personal objects such as chains and rings are also collected for NAA'. No water leak from the beamport area is evident. The PI. arrives and' concludes that beamtube can't be totally empty, by examination of water levels in hoses. Wit the beamtube condition unchanged,'UVAR power-is reduced to low powers to permit. documented

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surveys to be made, which allow extrapolation to high power.

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PERIOD EVENT

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! July 2, 1987 Rad. Saf. Officer l arrives andiLandauer is

 - (cont. ) contacted and arrangements are made to have film badges. developed on a 24 hr turn-aroun After surveys are finished, filling of. thel 1 beamtube is attempted with success, and I approximately 40, seconds =are necessary'before tubeyis fully filled'and doseLrates within the NRB' return to previously verified value It is concluded'that the charging system worked correctly, and1also that about 10% of the beamtube was draine The Department Chairman is informed by'the Director of the incident and is told that preliminary NAA results indicate low neutron exposures in the 20 mR range. Debriefing'

session'is held with affected staff and student , NRC is called'and informed of the incident by 1 the Rad. Safety Officer ' 1 1 1 l

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., , . LICENSEE RESPONSE TO NRC VIOIATION CITATIONS FIRST VIOLATION: 10CFR20.201 " Failure to perform adequate surveys".

DESCRIPTION: The rise in radiation levels within the neutron radiography blockhouse (NRB) , due to a partial draining of the water shield from the neutron beamtube, was not caught at its inceptio Consequently, for some time interval prior to the discovery of the field, the area was not posted as a high radiation area and access was not controlle PLEA: Violation is admitte MITIGATING OR The Reactor HP was not apprised of the EXTENUATING mechanism by which a radiation or high CIRCUMSTANCES: radiation area might be created within the ,

NRB. Weekly programed HP survey measurements indicated that the area was not a high radiation are l CORRECTIVE NRB was posted and access controlled after STEPS:

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the radiation field was foun SOP's have been written by staff and approved by the RSC. They specify the procedures to

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be followed henceforth for both operation and l modification of the NR Facility. (SOP's 6.9, j 2.12 and 2.13). SOP 10.9 requirements have been emphasized to the experimenter A safety evaluation of the NRB was performed by the PI and reviewed and approved by the RS Safety devices were installed, such as: i' a beamtube fill status indicator at the UVAR console; a second in-series pump enable switch for the reactor operator; alarms and a UVAR scram mechanism to act upon j inadvertent personnel entry into the NRB high ( radiation area with the UVAR on and beamtube ' less than filled; and a BF3 counter to serve as a redundant monitor of the beamtube fill statu '

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NRB was finished with a special work method in place, requiring the UVAR to be in the shut-down mode, and with survey and badging requirements. A final radiation survey of the NRB and neighboring areas was made, with the UVAR at full power plus the beamtube both i drained and filled . l l A Neutron Radiography Facility operating { procedure was developed by the PI and j approved by the RS ] The incident has been thoroughly discussed f during three special meetings of the RS { In perfect 20/20 hindsight, "necessary and reasonable" surveys would have taken the form of continuous radiation monitoring, or some j

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compensating fail-free shield of the beamport, during the work phase and with the UVAR in operation.

l SIGNIFICANCE: Management recognizes that a potential for overexposure was created by work done on the NRB. Overexposure did NOT occur, howeve Overexposure with the NR Facility are not likely to occur in the future, as a result of licensee corrective actions and sensitivity to the inciden )

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SECOND VIOLATION: 10CFR50.59 " Failure to perform a safety evaluation, in December of 1982, before beginning modifications to the beamport configuration, from the specifications mentioned in the SAR, to the form maintained-until June 1987."

DESCRIPTION: The neutron radiography principal investigator (PI) (also the Reactor Director in 1982), made a presentation to the RSC in j

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December of 1982, about his planned use of l the north beamport and the construction of a NRB. The RSC approved the installation of " beam catcher" and a closed system water charging / discharging system for this beamport. Upon completion of the changes, the ] l RSC received a memo from the PI, dated February 16, 1983, describing the blockhouse and assessing the safety features of the NR j facility. (This runs counter to a conclusion

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made in the NRC Inspection Report No. 50- l 62/87-03, page 5, that "a safety evaluation ' was not performed".

) It should be noted that the SAR description of the beamports is very succinct. The j beamtube water drainage system or method is not described. It is stated that "these ports are normally filled with water but may be drained individually when in use." and "when not in use these beam tubes are filled with concrete plugs with an offset in diameter to reduce streaming." The belief at the time was that the north neutron beamtube was being put into use, not that it was being " modified".

The NRC statements about "a modification of the beam port in 1983" may not be strictly correct, since the beamport itself was not modified from the description given in the SAR. True, a beam catcher (NRB) was installed to compensate for the removal of the concret inserts, but their removal was described in the SA _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ _ _ - _ _ _ - - _ _

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ADMISSION: A formal 10CFR50.59 analysis was not

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performed in 1982/1983.: ] REASONING: Was a formal 110CFR50.59-analysis needed?' ( That depends on'the definition.of what is~ j an experimental facility and what is a l modification. Was the beamport truly modified ! from the description given in.our SAR?.Is'the-blockhouse (biological' shield) an: experimental facility? OBSERVATIONS: ResearchLreactors.have only.recently been applying 10FR50.59 requirements to their operations. The NRC alerted the' community to increased NRC attention'to the enforcement of this regulation at n TRTR meeting held'in l 198 , l l ' NOTE: l The Reactor Facility's QA/QC' form for' meeting j 10CFR50.59' requirements was last revised on ; 12.05.85 and has been in use by the. reactor i l ' staff.for experiments and facilities'directly l related to our' reactor ; i LICENSEE The PI concluded'a safety-evaluation of-the ACTIONS: NR Facility, which was reviewed and .. approved by the RSC. A ' 10CFR50. 59 QA/QC-checklist was initiated'by the reactor

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staf The RSC met on August 11, 1987 to discuss i l ramifications from the present regulatory i difficulties and to evaluate future j compliance with 10CFR50.59. Generic SOP's L

 (2.12 and 2.13) were written to recognize and endorse use of 10CFR50.59 and have been approved by the RS !

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l i i SIGNIFICANCE: NRC inspectors have suggested in their discussions with us that a 10CFR50.59 j analysis would have of necessity addressed the radiological safety implications as well as the reactor safety aspects resulting from the modifications of the beampor Hence, the possibility of beamtube water shield drainage could have been anticipated and allowances made for this at the time of the recent work on the NR Our review of the . 10CFR50.59 wordir.g finds that it appears to ; directly stress reactor safety aspects, with i references made to the SAR, rather than j radiological safety. (It can be assumed that j in general SAR's will contain some general j mention of radiological concerns, as is true for our case.)

l SIGNIFICANCE: Also, quoting from the standard ANSI N402-1976 and ANS-15.8 on

 " Quality Assurance Program Requirements for Research Reactors":

2.14 Experimental Equipment The quality assurance program shall provide ] controls over the fabrication and installation of experimental equipment to the extent that these relate to reactor safet The management of the Reactor Facility concedes that radiological safety issues related to the recent activities on the NRB should have been addressed more fully, even if this lies outside of the scope of 10CFR50.5 Radiological safety is more fully addressed in 10CFR2 ~-

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THIRD VIOLATION: TS Violatio l TS 6.3 states " Written procedures, reviewed and approved by the RSC, shall be in effect  ! and followed for the items listed belo l These procedures shall be adequate to ensure the safe operation of the reactor, but should i not preclude the use of independent judgement  ; and action should the situation require suc q (1).....

  (2) installation or removal of fuel elements, control rods, experiments, and experimental facilities
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DESCRIPTION: The NRC inspectors cite as examples of the  ; violation: I

a) Failure to have approved written l procedures for the initial installation  ! of the NRB and modification of the beam { shield in 198 { b) Failure to have approved written procedures for the operation of the NRB ( between 1983 and July 2, 198 j c) Failure to have approved written procedures for modification of the , neutron radiography facility which began on June 17, 198 d) Failuro to have an approved written procedure addressing the surveillance testing of the BF3 neutron detecto ADMISSION: a) Approved written procedures for the installation of the NRB were not developed in 198 b) Approved written procedures for the NRB were not in existence between 1983 and July 2, 198 c) Approved written procedures were not developed for the.most recent work done i ' on the NRB, prior to the reported incident, d) Approved written procedure for the i surveillance testing of the BF3 detector was not develope l l L _ _________.__m

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l PLEA: If TS 6.3 was violated, it was due to our restrictedJinterpretation of its requirements. This-is not to say that approved written procedures would not have been useful in preventing the created

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violate TS l-1 l REASONING: TS 6.3 is entitled " Operating Procedures".

It states "these procedures'shall be adequate to ensure safe 1 operation of the

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j , ' reactor.." The' safety of reactor operation was not affected by the installation of the 1 NR j i

   .The experimental facilities for which written j and approved procedures have been developed in the past have been reactor related experimental facilities located in the j reactor pool. Tha NRB was until now not considered to be an " experimental facility" by our definition of an experimental facility. (Please reference definitions on page 1 of our TS). We admit that the beamports are experimental facilities, and are located in the UVAR pool. .The NRC inspectors' broader interpretation of the wording of our TS 6.3 would allow for experimental facilities to exist outside of
 '   that pool boundary, elsewhere in this-facilit While the inspectors' observations about the lack of approved written procedures is correct, it was not clear to us that they were required by TS 6.3. This issue'has been discussed by the RSC, and in view of the
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i ! occurrence and NRC concerns, the NRB will be considered subject taa TS 6.3 from now o LICENSEE Written and approved procedures are already 1

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STEPS: in place for items a), b), and c). They are being prepared for d). '

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t s The licensee'.is re-examining requirements. ho '

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     . written procedures for"its activitie Concern exists lthat' eventually'all--
      " licensee" , (reactor: staff, . faculty and student) activities will need to be covered
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by written procedures. :This would be'no ' (~ small: burden on. faculty.and student research'.

      " Policing" of faculty and' students by ..  .
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reactor staff, in addition to self-review,i j are also possible. issues for future discussio .I

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FOURTH VIOLATION: 10CFR20.201(b) " Failure to document a radiation survey (made on July 2, 1987)."

s DESCRIPTION: On July 2, 1987 the Reactor Health physicist j and the Reactor Supervisor responded to a j staff report of unusual high radiation fields { within the NR A brief entry was made into  ! the NRB with a portable gamma survey mete On verifying the high dose rate of about 500 i mR/hr, the survey was discontinued. This value was not recorded, although it was freely made available verbally to a NRC  ! , inspector, during a discussion of the even PLEA: This violation did not occu CIRCUMSTANCES: The Health Physicist realized that a serious problem had occurred when he obtained a high survey meter reading and that the order of' priorities required actions other than an immediate recording of the verified dose rat Soon thereafter, with the UVAR at reduced power, the survey was resumed in a careful and deliberate manner to characterize the radiation field in the NR It would have been unnecessary and also unwise to have performed the survey with the UVAR at full power, from ALARA considerations! j l REASONING: The resumed survey, which was performed and fully documented a little later on in the 1 afternoon of July 2, 1987, was complete and detailed. The failure to include the first ]

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measurement in no way compromised the survey records for that day, place and event, or the l licensee's subsequent action j l COMMENT: The licensee disagrees with the impression expressed in the NRC inspection report, in the last paragraph on page 13, that "the licensee experienced difficulties in determining the dose rates that were present (in the NRB) on July 2, 1987." While it is true that the range of the neutron meter goes

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i I i to 5000 mrem / hour neutron, and the neutron ] dose rate-directly in.the neutron beam at the

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exit of the port was higher.than that (1 REM) , . the reduction in UVAR power permitted I complete and accurate characterization of the j neutron and gamma fields at any UVAR power- ( level, with minimal radiation exposures to l personnel performing the survey CORRECTIVE Corrective STEPS: steps are not called-fo ) SIGNIFICANCE: A problem.of semantics'is apparent..It is not the industry practice to record every reading made during a survey, whether by an HP or an experimenter. A survey need only produce' sufficient numbers of measurements to be recorded such that adequate characterization.of radiation' levels in an area can be made. This was done by us on July 2,'198 ALARA considerations suggest that high radiation areas should not be frequented without need or benefi , The NRC. inspector recommended on page 13 of the report No. 50-62/87-03 that "if radiation , surveys are made for purposes other than showing compliance with 10CFR20, then the licensee should provide' guidance for- .1 s distinguishing.between official and i unofficial surveys in approved written procedures". We do not feel.that this is called for. We have procedures'which list which required surveys are to be documented, and we recognize the 10CFR20 regulation ., l Should this citation of a violation be imposed, it.might well discourage our l experimenters from carrying a meter and .l double checking ~the radiation levels.in.thei laboratories, due to the onus of having to  ; record all observed value , i 10 i l

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COMMENTS ABOUT THE NRC INSPECTION REPORT No. 50-62/87-03 The NRC Inspection Report No. 50-62 two special NRC inspections were unannou/87-03 nced. In states fact, that they the were made in response to the licensee phone report about a potential ! for overexposure having occurred at the University of Virginia , Reactor Facility, and were announce i Contrary to statement on page 1 of the NRC inspection report, the licensee took strong exception to NRC investigator's citing of an apparent failure to document a survey, at the time of his exit interview. Later, during a second NRC inspector's inspection, the licensee repeated his views on the matte The NRC report states on page 2, "The licensee modified the beam port in 1983." This might be misconstrued to mean that the beam port was physically altered (reconstructed), perhaps by replacement of the tube material with that of a different material and diameter. In reality, only the beam tube concrete inserts were withdrawn, a step foreseen in the SAR for enabling the use of the beampor ' To drain the beamtube of water, a i closed system with pump was attached to the unaltered beampor { This did not require a modification to the structure or drawings of the beamport. The SAR makes reference to the necessity of draining the beamtube as a means of putting it to use, however the SAR does not specify any method for accomplishing this. The so called " modification" then might well be defined as the consisting of the installation of a non-permanent beam catcher and a concrete blockhouse, whose sole purpose is to provide radiological shielding and access control. Of note is the fact that this part of the neutron radiography facility does not come into actual physical contact uith the beamports. It might be surmised that at some future date the blockhouse might be disassembled (it is not intended as a permanent and immutable construction, no cement having been used between the concrete blocks), the concrete inserts reinserted into the beamtubes and the fill / drain system disconnected, to take the beamport out of use, in a manner foreseen and briefly described in the SA On page 3, the 7;eport conveys the impression that the sole reason that the licr.nsee did not measure the dose rates in the blockhouse with the UVAR at 100% power and with the beam open was the lack of instrument capability to directly measure such high dose rates (12 Rem /hr) . Another reason for this licensee to only have measured dose rates at low reactor power was to comply with

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the ALARA concept. The survey at reduced power would have been done even if our instrumentation had the high range capability, so as to minimize the surveyor's exposure. The survey data I

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obtained at low power on July 2, 1987 was adequate for an extrapolation to higher power to be mad i On page 4 of the NRC report, it is stated that the licensee initially estimated that personnel exposures in excess of 50 rem may have occurred. This worst case assessment was induced by the line of question followed by the NRC representative who made a follow-up call to the Radiation Safety Officer, following the licensee's report to the NRC. This worst' case assessment was based on the highest beam dose rate of 12 Rem /hr and a postulated l continuous 5 hour occupancy right at the beamport exit! In fact, l other licensee representatives believed, and had NAA results to j substantiate their belief, that no reportable overexposure had j i even been incurred. It needs to be recognized that the

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University acted in a most conservative manner by immediately  ! reporting this even {l To supplement the NRC's inspectors comments given on page 6 re-garding the lack of approved written procedures for operation of the NRB, the licensee wishes to explain that the NRB was until this incident totally operated by the (faculty) principal investigator and his graduate students. The operator only ran the reacto The draining and filling of the beamport was done from the NRB switchboard, and this information was called in to the reactor operator mainly as a means of estimating neutron radiography use time for assessment of reactor fees to the  ; sponso Before the adoption of SOP 6.9, the facility SOP's did ' not cover beamport As regards the NRC comments about the " problem with water in the helium fill line around noon on July 2, 1987.", it was judged unlikely by the principal investigator that the water had come from the beamtube because the reservoir tank has an excess amount of water and it is placed at a higher level than the beamtub This encourages one to believe that if there is not a leak from the closed system to the environment, water would tend to flow from the reservoir to the beamtube. In hindsight, this initial observation should have been investigated further at that momen The licensee still believes that the amount of water that was lost from the beamtube (about 10% of total volume) could only have resulted from the operation of the pump, and not by the manipulation of the lines connecting the beamport and the reservoir tan t l ._-__-____-____a . .

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i l It is reported on page 7 that licensee management did not  ! consult with the radiation protection staff on the NRB wor i Although no written records were generated, the Health Physicist was informed about the work on the NR It is apparent that the Health Physicist should have had a greater input. Customarily, that is the case for staff originated project That level of i communication is more difficult to be established with i researchers. At the time this work was not seen-as a < modification to an " experiment", therefore it was handled ' informall A correction for page 9 is the true intended title of the  ! memo from the principal investigator to the Reactor Safety  ! Committee, dated July 15, 1987. It is "Recent Events Concerning i Potential Overexposure to Personnel During Blockhouse Construction."

i ' On page 13 of the report a possible failure to record a gamma survey is discusse It was explained to the NRC inspector that the so-called " undocumented survey" consisted of a hurriedly obtained value indicative of a high gamma field within the blockhouse. Under the unexpected circumstances of a high radiation field of the order of 500 mR/hr, it was impossible to ascertain the correct value and the exact position for which this measurement was made. Not much later, a complete and carefully documented radiation survey was made, under more desirable i ' conditions with the UVAR at low power, making irrelevant the need to record the imprecise initial reading. The investigator himself states most clearly that records must be kept "when the surveys are performed to demonstrate compliance with 10CFR20". Well, the first measurement indicated a problem, and the survey which was made to demonstrate compliance with 10CFR20 was documented.

l ' Contrary to the impression given in the last paragraph of page 13, we experienced no difficulty in determining the dos rates which were present in the blockhouse on July 2, 1987. While it is true that the instrument was capable of measuring up to t 5000 mrem / hour neutron radiation, it was not desirable to conduct a survey in fields of this and possibly higher magnitude. The method which was employed by us, consisting of surveying at l ! reduced reactor power, was plainly satisfactory and did not inconvenience us nor throw the results in discredit. We do not feel the need to have an instrument with a higher range than-the one at present because, during normal operation, the neutron radiography blockhouse is not occupied. Finally, the 800 rem / hour dose rate value first furnished to the NRC by the licensee (with the beam open and the UVAR at full power) is in j erro It is actually 180 rem /hr, as later reported to.the NR _ - _ _ _ - _ _ _ _ - ~

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UVAR, Revised 7/87 . 2.12 As per 10 CFR 50.59, changes to, tests of, experiments with, and new operating procedures:for facilities described in the WAR safety analysis report (SAR),

     (to.the extent that such changes, tests, experiments   1 and procedures are different from the description   {

, ' presented in'the SAR) may be made or adopted without -!

           '

prior NRC approval, provided that a change.in the UVAR

     ' Technical Specifications, or an unreviewed safety question, is not involve Such planned changes, tests, experiments, procedures, l

and written safety evaluations made to'show that an-  ! unreviewed safety question is not involved, shall be submitted to the Reactor Safety Committee'for review .! and approva Records of such changes, tests, experiments, procedures, and written safety evaluations, shall be.

l maintaine i

1 Reports of such changes, tests, experiments, procedures, and written safety evaluations, shall be submitted to the NRC, in an summarized fashion, in the i j l Reactor Facility's Annual Report. NRC recipients will be the Region II Office and the Director of Inspection ' and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 2055 Note:

In the WAR SAR,- the following is described:

1) General description of (Reactor) Facility Site,. building, "new construction", containment, shieldin ) Reactor Components and Control Reactor assembly, fuel elements, 4 I control rods and drives, instrumentation, scrams, interlocks and alarm ) Reactor Systems Pool, primary cooling system, secondary -; cooling system, heat exchanger, water purification, liquid waste disposal ) system, building ventilation and' -' I airborne discharge, core spray system, 4) Experiment Facilities Beam holes, large access facilities, rabbit facility,' fueled experiment )

1

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2.13 As per 10 CFR'50.59, changes to, tests of, experiments with, and new operation procedures for facilities described in the WAR safety analysis report '(SAR) which; involve a change in the WAR Technical Specifications, or an unreviewed safety question,'ma not be made or adopted without obtainin5 an amendment to'the operating license. In such cases,. provisions from 10 CFR 50.21 and:50.22 may' apply, and the reporting to NRC requirements should be re-examined to satisfy.the current statute '

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UVAR

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7/87 _ Neutron Beamoorts  ! General Considerations

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The reactor operator running the UVAR should be aware of

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the condition of the neutron beamports, whether filled or 1 drained, as indicated at the reactor console. Even a partially

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drained neutron beamport should be considered by the operator as ~ a potential source of high radiation, and attention should be j directed toward keeping personnel away from and out of radiation j areas. A high radiation area, created when the neutron radiography facility is in use, is presently confined to the inner cubicle of the concrete blockhouse which houses the

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i neutron radiography video camera. This blockhouse and its associated shielding materials affords appropriate levels of shiciding to personnel external to the blockhous i g Note: I A neutron radiography beam can generate dose rates I of up to 800 Rem /hr when a neutron beamport is fully drained and the UVAR is at 2 MW. Therefore, it is i I absolutely essential that personnel working in the immediate vicinity of the UVAR's two beamports take adequate precautions, to monitor the local radiation i ' field, to wear appropriate docimetry and to limit their i occupation of the are J A. Beamnort Oneration i 1) The experimenters wishing to perform neutron

radiography will have Reactor Safety Committee approved experimental procedure ,

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2) A copy of the neutron radiography experimental i procedures will be kept in the UVAR reactor room. A l copy of the list of Reactor Director approved neutron , l radiography users will be attached, { i 3) The neutron radiography experimenter (s) will request the UVAR reactor operator's assistance in draining a neutron beamport. Both the experimenter and .{ the reactor operator will have to activate separate electrical switches to operate the pump that will 1 drain or fill the beamport. The experimenter should l

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inform the reactor operator at the UVAR console that I the gate to the blockhouse hos been locked.

! 4) Whenever the beamport is not completely filled, a light beam inside the blockhouse will monitor inadvertent personnel entrances into the blockhouse, ! SOP 6-30 I i I L__-_-__-_-__--_--_----.---- - - - - - -

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e

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UVAR

. 7/87

_ in the event that'the normally locked gate and audibl'e entry alarm should fail to preclude entrance, as ' intended. A break in the continuity of th'e light beam will result in an audible alarm at the blockhouse and both audible and visible alarms in the UVAR contkol

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i room, in addition to an automatic UVAR scram, i

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5) Inadvertent entries into the blockhouse with the beamport drained and the UVAR at power should be reported by the reactor operator to the Reactor Health Physicist and the Reactor Directo ) The UVAR reactor operator should verify that the neutron beamports are filled when neutron radiography work ceases. Also, on the daily UVAR reactor start up checklist, the status of the beamports and the , ' blockhouse should be note B. Blockhouse Construction l l l 1) Planned major alterations to the blockhouse., which provides radiation shielding and permits the safe use of open (unfilled) . neutron beamports, will first -be discussed by the experimenters with the reactor staf i Discussions will also rake place for planned changes to neutron beamport inserts, or to the neutron beamport water draining / charging system. From these discussions, a work plan will be developed which will take radiological safety into account. This plan will be submitted to the Reactor Safety Committee for approval.

l 2) Work on a neutron beamport or its blockhouse wil * ' be performed with the UVAR shut down. Before such work is initiated, the UVAR will be tagged out of servic Daily UVAR checklists may still be performed with the reactor out of-service, provided the UVAR is not started up. The Reactor Director must give his permission before UVAR. rods are withdrawn to bring the UVAR to power, af ter blockhouse construction or - neutron beamport associated work has been initiate With the Reactor Director's permission, special radiation surveys may be done by the Health Physicist' or his designee, during a construction phase, with the

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UVAR reactor at power, to determine blockhouse shielding adequac SOP 6 31 Os N .

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3) Work on a neutron beamport or'its blockhouse will be done in the presence of supervising reactor staff g

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    ) and faculty members. The work may be performed by s    students and/or staff. The radiation levels will be monitored, as prescribed by the Reactor llealth Physicist in the approved work pla .
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e 50.59 Chwges, snta cnd superimentA

*          j (&X1) The holder of a !!certse a .59tb)

thorizing operation of a prDduction PART 50 o DOMESTIC I or ut!!!zation facility may (1) mane

, changes in the facility as described in a e the safety analysin report. Ui) make 8 cnanges m the procedures as described ,,l specified such shorterinternis in the license, as maY be g in the safety analysis report, and Ull) g (3) The records of changes in the
* conduct tests or experiments not d * facility shall be maintained until the I scribed in the safety analysis report, a date of termination of the license,and
         .

without prior Cornmission approva ; records of chariges in procedures and j unless the proposed change, test or ex- i periment involves a change in the * records oficsts and experiments shall I technical specifications incorporated 1 be maintained for a period of five year l in the hcense or an unreviewed safety q questio i (2) A proposed change, test, or e periment shall be deemed to involve ( an unreviewed safety question 18) if i the probability of occurrerie or the

,,, consequences of an accident or mal-
*: Junction of equipment important to
* sa.icly previously evaluated in the a safety analysis report may be in-creased; or (11) if a possibility for an I. accident or malfunction of a different type than any evaluated previously in the safety analysis report may be cre-ated; or (111)if the rt argin of safety as -      ,

dehned m the basis for any technical sc) The holder of a liceru,e autho specification is reduce izing operation of a production or utt- ] 1' hzation f acihty who desires (1) a j j

   = change in technical specifications or
-> (b)(1)The licensee shall maintain 2 (2) to make a change in the facihty or    )

records of changes m the facility and of R the procedures described in the safety changes in procedures snade pursuant to 8 snalysis report or to conduct tests or this section, to the chient that these . caperiments not described in the 2 changes constitute changes in the * swfety analysis report, which involve R fucihty as described in the safety an unreviewed safety question or a :s i analysis report or to the extent that they change in technical specihcations. $ 1

' constelute changes in procedures as shall submit an apphcation for amend- a i described m the snicly analysis repor , ment of his bcense pursuant to i 50.9 The licensee 6 hull utsu maintain records 2" of tests and experiments carried out pursuant to puregraph (a) of this section, i w j These records must include a written ( ; Safety evaluation which provides the i bases for the determination that the ) change, test, or experiment does not insch e an unreviewed asfety queshon.

l (2) The licensee shall submit, as 6pecified in 150.4, a report containing a bnri sicact ption uf any chur.ges. tests, and experi.nents, including a summary of the safety es ulcation of each.The report must be submitted annually or at Nov ember 30,1986 loCVR C039 _ . _ _ _ _ _ . .________.__________________w

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 (4) review reportable occurrences and the actions'i.hken t'    ,  correct
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the cause of the occurrences " J -i (5) ivviw significant operating h ..

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performance of facili

     . affect reacter saft.ty (6) review  .

con and audit the operational, records for compliance i procecW u , Technical. Specifications, and license provisions  :

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audits shall be performed at least once each cilendar year..) -

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6.3 Operatino Procedures ,i

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Written procedures, reviewed and approve by the Reactor Sa.fety Committee, shall be in effect and fo? lowed for the '1tems listed below. Those procedures

,

1 ' shall be adequate to ensure the safe operaticr. of the reactor, but should i not preclude the use of independent judgmer,t'aqd action should the situation

 ' require suc f (1) startup, operation,.and shutdown of the rtia.ctor (2) installation 'or remedl of fuel ele' ments, control rods, experimenf.si and experimental facilities     _

i (5) actions to be taken to corrtet specific anc foreseen potential malfunctions

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of systems or compon3nts, including responses to alarms, suspected primary coolant system leaks, abnurmal reactivity chhnges ! ) (4) e'mergency coaditions involving potential .or actual rekease of radioactivity, l including provjsions for evacuation, re-entry, recovery, and medical support (5) f,reventive and corrective maintenance operations that could have an effect on res.ctor safety '

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t f 3 S i (6) periodik: adtveillance (including test and calibt$ tion) of ' reactor hstruventation and safety systems- <

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t Radiation control procedures shall be m intained and made available to al1 ' operations ;:ersonne Substantive changet to the approved procedures shall be made oly with tne . I approval of:the Reactor Safety. Committee. . Changes that do not change the original intent sf the procedures may be made with the approyal of the heility Dirtxtor ,J All such minor c),anges to procedures shall be docpmen,ted and subsequently reviewed by the Reactor Safety Committo, l

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i I ; 6.4.1 Action To ( _ en

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In the event a safety limit is violated, the fo*J1ow n , aken:

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 (1) The reactor st.all be shut down and reactor operations shall not be res i)  until au';,horized by the Commissio e d ;
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( 7.' EXPERIMENT FACILITIES F, Beam Holes

Two B-inch neutron beam ports penetrate the concrete shield

in the south side of the pool. When not in use these beam tubes are filled with concrete plugs with an offset in diameter to reduce l streamin The door to each port has a 3-inch lead shield in i ! Aluminum ports extend the holes to the reactor face. These ports i

are normally filled with water but may be drained individually when in use. A blank flange aluminum plate separates the aluminum port ,

.

extension from the concrete shield penetration Beam hole detail is I \ shown in Fig. V- / 52 Large Access Facilities (( The south vall is also penetrated by two large access facili-

        !

ties meas 5-feet vide by 6-feet high. When not in use these f experimental f l les are filled with concrete rolled in on dollies j and lead bricks." E cility is closed off from the pool by a i l

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gasketed aluminum plate, se access facility is shown in Fig. V- h A thermal column may be incorp ' . in a large access facilit Rabbit racility Installed in the UVAR is a hydra bbit facility for the rapid transfer (20 seconds) of small samples into ut of the reactor.,'The system consists of a 1.0" OD aluminum tub ' the ca.mple sad a 0.5 D aluminum tube for return wate ' wg

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FACILITY DESIGN, CONSTRUCTION OR MODIFICATION EVALUATION FORM N (This Q/A Form based o CFR 5 requirements was approved by RSC on 1/ OS/85 .) _ . - Requested by: Date: Description: Safety Analysis: a) Is the facility to be designed, constructed or modified described in the SAR? Yes, in section No N/A i ' b) Is a change required in S0P as referenced in the SAR? Yes, updated S0P to be reviewed by RSC on / / . No N/A c) Does the prnposed change, test, experiment or facility involve a change in Technical Specifications? Yes, to Tech. Spe (therefore a license amendment pursuant to 10CFR 50.90 is required) No d) is the probability of an accident with or malfunci. ion of the equipment such that it may bear on safety items considered in SAR? Yes, bearing exists on SAR items _ No . e) Are the consequences of a malfunction of this equipment important to safety evaluations previously made in the SAR? Yes, affects evaluation in SAR section  ; No . f) is an accident or malfunction of a different type than previously evaluated in the SAR possible? i Yes, the scenarin not previously considered is

     .

i No . g) is the margin of safety as defined in the basis for any Technical Specification reduced? ,

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Yes, margin of safety fnr j reduce fis,are) j No I

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h) When' the answers to questions 3 (d.e,f, and g) are all

 "No", the Facility Director may conclude that the_ request does not constitute an unreviewed safety question.. Does the proposition constitute an unreviewed safety question?

Yes, because

      .

No Recordkeeping Requirements Required Completed Yes No Yes No Comments Safety Analysis 10 CFR 50.59 (a ! 4.2 Design Review l 4.3 Drawing Revision 4.4 New Drawings ' 4.5 Manual Change 4.6 Procedure Change

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4.7 P.SC Approval Tech.. Spec. .8 Tech. Spec. Change 10 CFR 50.59 (c!. , 4.9 License Change 4.10 NRC Approval 10 CFR 50.59 (c: 4.ll Procurement Review

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4.12 Material Control Review 4.13 Inspection and Tests 4.14 Non-Conforming Materials a.15 Failure Records _0fficial Approval: Facility Director or Reactor Safety Committee Approval for proposal was granted on / / ; Director's signature ___ Work Completed by: Title: Date: Form Completed by: Title: Date: l '

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"

DEPAIIT31ENT OF NUCLEAR ENGINEERING AND ENGINEERING PIIYSICS ) SCIIOOL OF ENGINEERING AND APPLIED SCIENCE

 ' UNIVERSITY OF VIRGINIA Phone: 924 7130
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MEMORANDUM February 16, 1983 Reactor Safety Committee .! TO: I FROM: J.S.Brenizer[8 d SUBJECT: Fast Neutron Beamport Experimental Setup l

, l As' discussed in the RSC meeting of December 14, 1982, the north fast i neutron beamport has been setup for use in neutron radiography experimen Several changes have been made to ensure the safety of personnel using the . bea , 1) The front tube of the north beamport (illustrated in Figure 1) is . d normally drained to atmospheric air pressure when the tube is opened 1 for use. A significant amount of argon-41 is produced while the tube j is air fille In the past, this. argon-41 was vented to the duct j exhaust system when the tube was refilled. To eliminate this production J and release, the front tube was modified to be a closed system utilizing i l demineralized water with a helium cover gas and a reversible peristaltic l pump as illustrated in Figure 2. h' hen the front tube is filled the tank holds a small amount of excess water and a large volume of helium j l cover gas. When the front tube is drained the tank is almost filled 1 with water causing the front tube to be' filled with helium gas. This .j eliminates the release of argon-41 to the atmosphere. The system pressure is 5 psig.

l i

 ' 2) A two-block-thick wall of high density concrete shielding blocks was  j l

constructed around the beam ports to protect personnel working in the l l core face area when the port. is drained and the reactor is operating at full power (2 MW) . Le shiciding wall was setup as shown in Figure l 3. The back wall thickness was increased to 3 blocks (24 inches) to-  ! reduce the radiation dose rate The beam stop is constructed of Cd ~l sheets, 3 inch Pb sheet,16 inches of concrete, and 6 inches of paraffi The roof of the structure is covered with graphite to reduce the . neutron scatte The measured dose rates are shown on Figure All accessible areas of the exterior of the shielding block house are within or belo the limits for a radiation are All . areas ' are being reviewed for possible additional dose rate reductio ) %e concrete plugs which normally fill' the dry side of the north beam-

. port were removed. Plugs of 15 inches of lead and 1 inch of bismut !

were inserted into the port to reduce the gamma photon dose rat ! With the front tube filled with water, the plugs in place, and the reactor at 2 MW, the dose rate at the entrance door of the beam- l port tube was 1.5 mrem per hour from neutrons and 6.5 mrom per hour j l

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1 from gamma photons. Although not directly measured,the dose rate with' the front tube drained and the beamport door open was extrapolated to be i 16 Rem per hour from neutrons and 9 Rem'per hour from gamma photon ! Thus, the interior of the shielding block house is' a radiation area  ! with the front section of the beam tube filled and the beam tube door i closed and secured. With the beamport door open and the front tube filled 1 the dose rate was measured to be about 600 mrem.per hour and thus, the .; interior of the shicIding block house is a high radiation area. Obviously, ' with the front tube drained, the interior is a high. radiation are > A door (with a lock) has been installed at the entrance of the bloc house to provide the required controlled access to the room's interio ) The sight-glass systems used in determining if the neutron beamports' are filled with water have been relocated outside the block house. These

        .

l l changes have been reviewed with all' reactor operations personnel, i Tnese modifications have allowed use of the north neutron beamport to expose radior.raphic films with the reactor at 2 MW without limiting personnel access to thu reactor core face area. Modifications - to refine the beam are continuing. 11owever, these modifications will not significantly change the dose rates outside the shielding block hous .1 l

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4,, Y Q k .sEPAltTalENT OF NUCLEAR ENGINEEltlNG AND ENGINEEILING PilYSICS ' SCHOOL OF ENGINEERING 'AND APPLIED SCIENCE

' UNIVEltSITY OF VIRGINIA Phone: 924 7136
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MEMORANDUM December 15, 1982 1 j TOi Reactor Safety Committee FROM: J.P. Farrar SUBJECT: RSC Meeting of December 14, 1982 The Reactor Safety Committee met on Tuesday December 14,1982. Members present were Messrs. Meem, Berk, Lapsley, Ribando and Reynolds. Also present were Messrs. Williamson, Brenizer, Farrar, Bly, and Varhu Action Items 1) Minutes of the meeting of September 7,1982 were reviewed and approved by the Committee. One open item is the Power Calibration of the CAVALIER rea ctor. The committee was informed that the calibration has been completed and the data is being reviewed and written u ) The Consnittee reviewed the request of Walter Varhue (memo dated 12-14-82) to operate a rotor experiment in' conjunction with the South Tangential Beam Por Dr. Reynolds moved that the experiment be approved and Dr. Lapsley seconded. The Committee approved the experimen ) The Committee reviewed the request of C.A. Bly (memo dated 12-14-82) for the welding repair of a leaky EPRI capsule. The staff agreed to have a ! staff member and/or Health Physicist present during'the welding operation to monitor the activity and assist in the operatio Dr. Reynolds moved to approve the procedure and Dr. Berk seconded. The Committee approved the procedur ) The Committee discussed the proposed changes to Section 10 of the standard operating procedures but deferred action on the request until they could review the changes in more detail. A meeting has been scheduled -for 2:30 PM on January 12, 1983 to review the change ) The Committee reviewed the request from B. Hosticka (memo dated 12-14-82) for the installation of a new rabbit system. The Committee' observed the operation of the system in the UVAR pool. Dr. Lapsley moved to approve the

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installation and Dr. Ribando seconded. The Committee approved the installation under the following restrictions. If the' streaming from the facility causes dose rates greater than 50 mr/hr at the top of the. reactor bridge the staff will have to report back to the committee to either justify the higher dose rate or propose modifications to reduce i I

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,, f .s .,5 Reactor Safety Coninittee Page 2 December 15, 1982 6) The Committee was informed of a proposed experiment involving neutron radiography using the neutron beam ports. This . experiment is very similar {

to ones that have-been approved in the past. The experiment will be written up in detail and sent to the Committee fo'r their. informatio Information Items The Committee reviewed the following information items

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1) The Emergency Drill that took place in September (memo dated 916-82).

2) Report to NRC on modification of emergency spray. system (memo.-dated 9-27-82).

i 3) Renewal of UVAR License and Licensing of new operators '(memo ifated 10-4-82).

4) Repair and reloadi.ng of EPRI Capsules #7, #9 and #10 (memo dated 10-5-82).

5) NRC' Compliance Inspection (memo dated 11-18-82).

6) EPRI Project Status (oral report.by J.S. Brenizer) The next meeting of the Committee is scheduled for 2:30 PM on Wednesday, January 12, 198 j Respectfully Submitted,

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J.P. Farrar, Reactor Supervisor, UVA Reactor Facility JPF:vs I

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