IR 05000160/1987003

Insp Rept 50-160/87-03 on 870407-10.Violations Noted:Failure to Label Containers of Radioactive Matl,Failure to Perform Radiological Surveys & Failure to Follow Procedures

ML20210B469
Person / Time
Site:	Neely Research Reactor
Issue date:	04/23/1987
From:	Bassett C, Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210B452	List: ML20210B447 ML20210B469
References
50-160-87-03, 50-160-87-3, NUDOCS 8705050333
Download: ML20210B469 (14)

Text

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• UNITED STATES

. M2 E Ec g oq'o NUCLEAR REGULATORY COMMisslON

[ p REplONli g j 101 M ARIETTA STREET, ATLANTA, GEORGI A 30323 V ,o

'+9 m .+ APR 2 71937-Report No.: 50-160/87-03 Licensee: Georgia Institute of Technology 225 North Avenue

= Atlanta, GA 30332 Docket No.: 50-160 License No.: R-97 Facility Name: Georgia Institute of Technology Research Reactor (GTRR)

Inspection Conducted: April 7-10, 1987 Inspector: ,9dd M/r M 3M7 B. K. Revsin Date 51gned C6 amer C. H. Bassett s whd?

Da'te Signed Approved by: N M'

h C. M. Hosey, Section Chief-

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N83h7 Date. Signed V Division of Radiation Safety and Safeguards

' SUMMARY Scope: This routine unannounced radiation protection ins'pection. involved the areas of transportation of radioactive materials,' internal exposure control, external exposure control and dosimetry, c'ontrol of ' radioactive materials and contamination, surveys and monitoring, and followup on previous enforcement item Results: Three violations - (1) failure to labelJcontainers of radioactive material, (2) failure to perform radiological surveys, and (3) failure to follow procedure %[Uh G

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d REPORT DETAILS A

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' Persons Contacted

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Licensee Employees

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• R. A. Karam, Director, Nuclear Research Center

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• R.- Boyd, Radiation Safety Officer P. Sharpe, Health Physics Technician S. Millspaugh, Health Physics-Technician-L. D. McDowell, Senior Reactor Operator

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• Attended exit interview . Exit Interview The inspection scope and findings'were summarized on April .10,1987, with

those persons indicated in Paragraph 1 above. Three violations concerning

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the following areas were discussed in detail: (1)labelingofcontainers= *

of radioactive material [ Paragraph 5.f]; (2) radiological surveys with two

examples [ Paragraphs 5.c and 5.g.2]; and (3) failure to follow procedures

concerning Radiation Work Permits [ Paragraph 5.b.2], wearing of protective clothing with two examples [ Paragraph 5.e], wearing required dosimetry

[ Paragraph 5.d], review and approval of experiments with two examples

. [ Paragraphs 5.g.1 and 5.g.2], completion of Experimenter's' Checklist.with

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two examples [ Paragraphs 5.g.1 and 5.g.2], personnel response to i criticality alarm [ Paragraph 5.h], and surveys - of radiation -levels near j the rabbit port during removal of the rabbit [ Paragraph 5.g.2]. The i licensee acknowledged the inspection findings and took no exceptions. The licensee did not identify as proprietary'any of the materials reviewed by

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or provided to the inspector during this inspection.

, Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation (50-160/85-03-02) Upranging the Gas, Monitor 'such that automatic alarm and isolation of containment would not occur unless the release rate was a factor of 100 above the limit. The inspector reviewed i the ~ licensee's response' dated July 22,11986, and verified that the -

corrective action'had been implemente '

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(Closed) Violation (50-160/87-02-01) Securing of- primary coolant sampling line except during monthly surveillance and conducting five separate l one-minute counts ior tritium analysis of waste tank samples. .The-4 inspector reviewed the licensee's response dated April 7,1987, and verified that the corrective action had been implemente ~

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4. . Transportation (86740)

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10 CFR 71.5(a)' requires each licensee who transports licensed material

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outside the confines of its plant 'or other place of use to comply with the

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anglicable requirements of the Department of Transportation in

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41 CFR Parts 170 through 189.

i The inspector reviewed the records of , shipments of radioactive material from the facility made between September 1986 through February 1987.

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No violations or deviations were identifie . Radiation Control (83743)

, Posting of Notices 10 CFR 10.11 requires' the licensee to post Form NRC-3, the license and other pertinent' information. If posting a document was not practicable, the licensee may post a notice which describes the document and states where it may be examined. During tours of the

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facility, the inspector verified that entrances to and from areas where licensed activities were conducted were posted with the l required documents or a notice describing the document and where it

may be examine No violations or deviations were identifie External Exposure Control I

(1) 10 CFR 20.101 specifies the applicable radiation dose-standard The inspector reviewed records of individual radiation exposures for the calendar year 1986 through' February 1987. All radiation doses recorded for plant personnel were well within the quarterly limits specified in 10 CFR 20.101(a).

(2) Technical Specification (TS)6.4.b states that written procedures shall be provided and utilized for radiation and radioactive contamination contro <

Health Physics Procedures (HPP), Revision 7, September 1985, l i Section 8 requires any work involving (1) entry -into a High I Radiation Area, (2) modification of biological shielding around

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the reactor and/or (3) penetration of any port hole in the )

i biological shield to be authorized by a RWP.

The inspector reviewed RWPs written for work in the containment building from August 1986 through March 1987. RWP No. 6355 issued on September 9,1986, for irradiations using the thermal

neutron column required that Health Physics (HP) monitor the job l from start to finis In discussion with licensee personnel, 1 l

the inspector determined that an' experimenter failed to notify 1 i

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i f -l HP' that the irradiation was being performed. , The experimenter

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had performed his own monitoring when opening the shutter of the thermal column.- The licensee ~ stated that-in

dose rates of 100 millirem per hour (mr/ hour)ganna general, average radiation -

and one mr/ hour neutron radiation were generated when the l-. neutron shutter in the biologicalLshield was' opened, thu's

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creating a High Radiation Area.-

L Failure to - follow instructions' specified on the RWP was -

identified as an apparent -violation of -TS 6.4.b

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(50-160/87-03-01). CFR 20.201(b) requires each licensee to make or cause to-be made such surveys as may be necessary for the licensee to comply .

i with the regulations in 10 CFR Part 20 and are reasonable:under-

~t he circumstances .to evaluate the extent of radiation hazards

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that may be present.

, 10 CFR 20.201(a) defines a survey to mean an evaluation ofl the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other. sources of radiation under- a specific ~ set of- condition '

When appropriate, such evaluation includes a-physical survey of the

location of materials and equipment, and measurements of levels j of radiation or concentrations of radioactive material present.

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During tours of the facility the inspector observed personnel-monitoring themselves for contamination preparatory.to exiting the Reactor Control Zone (RCZ). The inspector noted-that while

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a monitoring device was available for use, personnel exiting

through the vestibule doors at the back entrance of.theifacility

, failed to perform self-monitoring. During discussions with the

! licensee it was also ascertained that personnel on occasion

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exited the facility by1 the vestibule doors ' and left the

restricted area by the back gate. . Personnel monitoring was not performed. The licensee stated that the frisker had been placed -

j by the back door in case someone wanted to self monitor but that I i

frisking at the vestibule exit from the .RCZ had never been -  :

i require !

i f Failure of licensee personnel to monitor - themselves for

, contamination prior to exiting the ~RCZ was identified as an apparentviolationof10CFR20.201(b)'(50-160/87-03-02). i HPP, Revision 7, Septrl.wr 1985, Section 6.'d requires all i personnel entering the - RCZ to. wear appropriate personnel monitoring devices as designated and supplied by HP. -

Section 7.1.a requires regularly assigned personnel to wear film i i badges or other monitoring devices capable of detecting beta,

} gamma and neutron radiations at all times when inside the RCZ.

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, At the entrance to ' the RCZ the inspector. observed a posted i

notice which stated;that all personnel entering -the area must *

wear one film badge and one thermoluminescent dosimeterL{TLD).

During a review'of HP techniciar, log books the inspector noted

.that instances of personnel entering the RCZ without dosimetry

. were documented. These 'ocenrred on August 8, November 3 and -

i November 18, 1986. Discussions with ' licensee! representatives revealed that on two occasions, the same . individual: had failed

' to wear dosimetry.

i Failure of licensee' personnel; to wear required dosimetry :in the

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RCZ was . identified as an! additional example of an apparent violation of TS 6.4.b (50-160/87-03-01).

The NRC Enforcement Policy,10 CFR 2, Appendix C,1986 states that a Notice of Violation .will generally not be issued fo violations identified by the licensee if- (1) it-was identified -

by the licensee; (2) it fits in Severity Level IV or V;'(3) i was reported, if required; (4) it was or will be corrected,-

including measures to prevent . recurrence, within a reasonable

! time, and (5) it was not a violation' that could reasonably be 3 t expected to have been prevented by the -licensee's: corrective i actions for a previous violation, i The inspector reviewed the corrective action taken by the i

licensee. The licensee stated that'the individual involved on 1

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! each occasion was requested' to leave. the RCZ to obtain the

! appropriate dosimetry. One licensee representative stated that

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the Radiation Safety Officer (RS0) may have been notifie '

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Corrective action to prevent recurrence was not documented by i the licensee and through ' discussions .with 'the licensee- the inspector' detennined that no corrective action program was in place for the facility. The licensee stated that at one time a-

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Report of Violation of Health Physics Procedures Form 'was i completed in such instances which required the individual's

! supervisor to specify the corrective action taken. These forms

had not been used in several years -and no other mechanism had i been adopted to replace this extinct syste The inspector informed - the licensee that due to' the above factors, that failure of licensee personnel to wear required

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dosimetry in the RCZ would not be considered licensee identified.

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e. . HPP, Revision 7, September 1985, Section 7 states that it is

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mandatory for all persons having access to the' Nuclear-Reactor Control Zones to comply with HPPs and the Georgia-Institute of

Technology (Ga. Tech) Radiation Safety Manual.

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Ga. Tech Radiation Safety Manual, September 1986,Section IV.F.1.b states that protective clothing appropriate to the conditions shall be worn at all times when working with loose radioactive material HPP, Revision 7, September 1985, Section 6.j states that clothing used to prevent the spread of radioactive material shall not be worn in clean areas. Section 10 further states that protective clothing provided for radiological safety shall not be worn for any other purpose and shall be removed when passing from a contaminated area to a clean are During tours of the facility the inspector observed the protective clothing stored inside the RCZ which was available for use by personnel. In addition shoe covers were available at the boundary of each roped off contaminated area. Discussions with licensee representatives revealed that personnel sometimes failed to comply with protective clothing requirement The licensee stated that these instances were not always documented since there was no requirement for documentation, but on occasion, such instances may be recorded in the HP technician daily log book. The inspector reviewed the daily log books for 1986 and found that on April 29, 1986, two individuals had been observed in the hallway (a clean area) of the Nuclear Research Center Building (NRCB) dressed in protective clothing while on March 19, 1986, one individual was observed to have entered a contaminated area without donning shoe cover Failure to remove protective clothing prior to entering a clean area and failure to wear protective clothing appropriate to the conditions were identified as further examples of apparent violationsofTS6.4.b(50-160/87-03-01).

The licensee stated that the two individuals found in clean areas wearing protective clothing, were students and that they had been reminded of the appropriate areas for wearing protective clothing. No corrective action was documented or remembered for the March 19, 1986 even Review of other HP records, i.e., personnel files, Monday morning meeting minutes, etc., did not reveal any further corrective action In neither case were comprehensive corrective action taken to ensure that all personnel were aware of protective clothing requirement Due to deficiencies in licensee's corrective actions, the inspector informed the licensee that the above finding would not be considered licensee identified, f. 10 CFR 20.203(f)(1) and (3) require each container of licensed material to bear a durable, clearly visible label identifying the radioactive contents when licensed material is present in

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quantities greater than the applicable quantities specified in ~

' Appendix C of 10 CFR Part 20.

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i 10'CFR 20.203(f)(2) specifies that the above label shall: bear the' radiation caution symbol and the words:: " Caution -(or

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Danger), Radioactive Material," and shall provide sufficient i information .to permit individuals . handling or using - the

! containers, . or working in the vicinity thereof, . to take'

precautions to avoid or minimize exposures.

I j In. discussions with licensee personnel the inspector ascertained

that -on June 2, '1986, a sample of material -which had been

irradiated . in the . reactor was removed from the containment building to the decontamination room where.it was.left unlabeled >

and unattended. It was discovered by HP and was found t read 2 90 mr/ hour at contact with the external surface of the f containe The length of time the container. remained in the

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- decontamination room was estimated to be approximately one hour.

The inspector was informed that the quantity of radioactivity

! within the container was approximately 15 microcuries -of Na-24

! and therefore represented a quantity greater than that specified in 10 CFR 20, Appendix Failure to label each container of. licensed material as required -

j was identified as an apparent violation of 10 CFR 20.203(f)

j (50-160/87-03-03). The apparent violation was not~ considered licensee identified due to failure to take corrective actio Irradiation of Experiments i (1) Procedure 3102, Quality Assurance (QA) for Experiments,

October 28, 1982,Section II.B states that all experiments must be initially reviewed and approved by Georgia

Institute of Technology Research. Reactor.(GTRR) management via the Experiment Approval Fom (EAF).

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, Procedure 3100, Experimenter's Checklist, Revision 1 July 11, 1986, requires ' the experimenter to list 'any

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j changes in the experiment from those specified on the EAF.

i l The -inspector reviewed a letter written on September 26, i 1986, from P. B. Sharpe . to .the RSO concerning flux

measurement experiments performed between August 20 and i September 23, 1986. Documentation for these experiments,.

! Experiment Approval Form, and the accompanying RWPs, were

! reviewed by the inspector. The experiments approved by EAF I

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No. R6832 were measurements of flux rates using bare and Cd ~

j covered indium foils and TLD chips in beam ports H-9,-H-11 ,

and H-13 for 10 minutes at a reactor power level up to one

megawat RWP Nos. 6349, 6351', 6352 and 6359, were issued -

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for irradiations on August 20, August 29, September 4 and September 23, 1986, respectivel The inpector compared the beam ports used for the irradiations as specified on the RWPs with those authorized by EAF No. R683 EAF No. 6832 authorized use of beam ports H-9, H-11, and H-13. Beam ports specified on the RWPs were H-8, H-9, H-12 and H-13. Discussions with licensee representatives verified that the beam ports used for the irradiations were those stated on the RWP The use of unauthorized beam ports for the above experiments had been brought to the attention of -the Director of the facility via the letter specified above and an. approval after-the-fact was generated for . the experimen Facility personnel were notified by memorandum from the Director dated October 1,1986, that to ensure against recurrence, all future RWPs issued for the reactor would require the Director's approval. All personnel at the facility initialed the memorandum as having read the

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notification. The inspector reviewed all RWPs issued for i

the reactor since October 1,1986, through March 31,-198 Of the 51 RWPs that had been issued..nine had received the Director's approval. The inspector discussed this matter with the Director who stated that insufficient oversight had been exercise Failure to comply with the conditions specified on EAF No. 6832 was identified as an additional example of an apparent violation of TS 6.4 b (50-160/87-03-01). The apparent violation was not considered licensee identified in that corrective ' action was not carried out and recurrence of similar problems was observed (Paragraph 5.g.2).

The conduct of experiments was discussed with licensee representatives who stated that reactor experiments were controlled by a quality assurance (QA) program which was designed to ensure reactor and personnel safety. The primary means of implementing the QA program was through the Experimenter's Checklist, Procedure 3100, which required the experimenter and/or operator to certify that i the proposed experiment meets the requirements specified by the EAF.

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The inspector reviewed the Checklist that had been completed for the irradiation performed under EAF i

No. R683 Item D on the Checklist required that any changes in the experiment from that specified on the EAF be

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liste No changes to the irradiations perfonned on August 20 and 29, and on September 4 and 23,1986, were listed on the Checklist even though beam ports not authorized by EAF No. R6832 were to be use Failure to specify changes to approved experiments on the Experimenter's Checklist was identified as an additional example of an apparent violation of TS 6. (50-160/87-03-01).

(2) Procedure 3100, Pneumatic Tube Transport System Operation, Revision 1, October 10, 1974, Paragraph A.1 requires completion of an EA Procedure 3100, Experimenter's Checklist, Revision 1, July 11, 1986, specifies the necessary checks that must be completed in order to certify that an experiment meets the limitations specified by the EA Procedure 3102, Quality Assurance for Experiments, October 28, 1982, Paragraph II.0.1.d states that a radiation level near the rabbit port at the time of sample removal from the rabbit port will be recoroed on .the Schedule Form (Experimenter's Checklist).

On April 6,1987, an indium foil was inserted in the reactor via a plastic rabbi The reactor ..ad been operational at one megawatt and was shut down immediately prior to insertion of the rabbit. After completion of the irradiation, the operator returned the rabbit to the receiving station located in a laboratory in the NRCB. An alarm sounded which was heard in the HP office by the RSO who investigated. The alarm originated from a RM-14

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located approximately six to eight feet from the receiving station. While no actual measurement of the dose rate had been performed, the RS0 stated that had the dose rate been of a significant level, the radiation monitor in the hallway would have alarmed. The RS0 estimated that the activity of the activated experiment had' been 20,000 cp The inspector observed the RM-14 near the rabbit receiving station and noted that the background radiation levels were sufficiently high to necessitate that the instrument be set on its highest scal Consequently an alarm of the instrument would correspond to activity in excess of 50,000 counts per minute. The licensee stated that no dose rate measurements had been made and that on the date of the i irradiation, no dose rate instrument had been available in the room containing the rabbit receiving station to perform i such measurement l I

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Failure to adequately evaluate the extent of the radiation hazard that may have been present was identified as a second example of an apparent violation of 10 CFR 20.201(b)

(50-160/87-03-02).

The inspector reviewed the documentation covering the indium foil irradiatio During discussions concerning the applicable EAF, the licensee stated that indium foils were routinely irradiated, and after examining EAFs in the office files concluded that approval may have been authorized under either EAF No. 5371 or EAF No. 544 The inspector reviewed the reactor operator's daily log to determine which EAF number had been assigned to the irradiation and noted that no entry concerning the experiment had been mad The inspector also determined that the Experimenter's Checklist, completion of which is required for all irradiations and which requires listing of the EAF number, was not completed for the indium irradiation of April 6, 198 Failure to receive authorization for the experiment via an EAF and failure to certify that an experiment meets the limitations of the applicable EAF were identified as additional examples of apparent violations of TS 6. (50-160/87-03-01).

In addition to radiation level measurements required at the rabbit receiving station, Procedure 3012 required that radiation levels near the rabbit port at the time of rabbit removal be documented. The purpose of taking the radiation level measurements at the rabbit exit port was to notify the experimenter at the rabbit receiving station of the radiation levels to expect upon the rabbit's arrival. The licensee stated that a radiation level had not been taken on April 6,1987, and that past experience in irradiation of similar foils made the measurement unnecessar Failure to perform radiation level measurements near the rabbit port at the time of sample removal was identified as an additional example of an apparent violation of TS 6. (50-160/87-03-01). I 1 '

HPP, November 1983, Section 15.4.d.1 states that all personnel not in the containment building will evacuate the NRCB immediately upon sounding of the criticality alar During reviews of HP technician logbooks, the inspector noted that on May 1,1985, the criticality alarm sounded and the NRCB was evacuate A team entered the NRC8 to ameliorate / investigate the emergency, and upon re-entry, l l

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the team discovered that one individual had not evacuated upon sounding of the alarm. The individual was required to leave the buildin Failure to evacuate the NRCB upon sounding of the criticality alarm was identified as an additional example of TS 6.4.b (50-160/87-03-01). The apparent violation was not considered licensee identified due to failure to implement corrective actio . The inspector also noted recorded in the HP technician logbook several instances of events relating to the security of the facilit On March 2, 1986, both the back gate (entry to the restricted area), as well as the back door of the facility (the vestibule doors), were left open and unattende Other areas of note documented by the logbooks include personnel failure to wear security badge, November 18, 1986, and potentially unauthorized persons in the RCZ on October 7, 1986. The licensee was informed that these items would be referred to Region II's Physical Security Section for followup (IFI 5G-160/87-03-04).

6. Inspector Followup Items (IFI) (92701)

(Closed) IFI (50-160/87-02-03) Review results of waste tank replicate sample radiological analyses conducted by licensee and NRC Region II laboratories. Results of replicate liquid waste tank samples collected in February 1987 and analyzed by the licensee and NRC laboratories were discussed. Comparison of licer.see and NRC results are listed in Table I with the acceptance criteria detailed in Attachment 1. Licensee tritium results were variable among the three analyses, a maximum difference of approximately 50% among the samples; whereas, NRC data were more precise, a maximum difference of 2.5%. In general, licensee tritium results were higher than NRC data. The low licensee precision and biased tritium results may have resulted from failure to remove interfering nuclides from the liquid waste prior to liquid scintillation analyse Licensee gross activity results also were variable and biased low relative to NRC values, ratios of licensee to NRC values ranging from 0.04-0.80. The licensee methodology, use of filter paper to collect gross beta-gamma activity, would fail to collect activity associated with particles less than 0.45 microns in diameter and/or dissolved in the liquid wast Licensee representatives stated that they would be conducting a thorough review of their radiological analyses procedures to improve precision and accuracy needed to meet technical specification requirements. Furthermore, the licensee stated that a quarterly interlaboratory comparison of their analytical methodology would be initiate The inspector informed licensee representatives that their actions in this area would be reviewed during subsequent inspection ,

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(Closed) IFI (50-160/86-02-01) Review of respiratory protection progra The inspector discussed this issue with licensee representatives who stated that all respirators onsite were for emergency use only and that in no instance would protective factor credit be. sought for respirator usag l i

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TABLE 1 *

Results of Confirmatory Radionuclide Analyses for Georg ia Institute of Technology Research Reactor, February 1987 SAMPLE TYPE ISOTOPE CONCENTRATION fuCi/ Unit 1 RESOLUTION RAT 10 COMPARISON .

Qcensee  !!!LQ Licensee /NRC Liquid Waste Tank H-3 8.80 E-5 1.18 1 0.01 E-4 118 0.74 Di sag reement (Sample 1) Cross Activity 6.63 E-8 2.8 1 0.1 E-7 **NC 0.24 **NC Co-60 *NA 4.2 1 0.6 E-7 - *NA **NC Liculd Waste Tank H-3 1.61 E-4 1.21 1 0.01 E-4 121 1.33 Disagreement -

(Sample 2) Cross Activity 1.99 E-7 2.5 1 0.1 E-7 **NC 0.80 **NC Co-60 *NA 5.2 1 0.6 E-7 - *NA **NC Li(uid Weste Tank H-3 1,48 E-4 1.21 i O.01 E-4 121 1.22 Ag reement (Cischarge Sample) Cross Activity 1.11 E-8 2.5 1 0.1 E-7 **NC 0.04 **N Co-60 *NA 4.2 1 0.6 E-7 -

• NA **NCl ,

• NA = Not Applicable = lsotopic Analyses not Required by Licensee e*NC = Not Compa red Quantitatively = Gross Activity Measurements

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CRITERIA FOR-COMPARING ANALYTICAL MEASUREMENTS This enclosure provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra In these criteria, the judgement limits denoting agreement' or disagreement between licensee and NRC results are variable. This variability is a function of the NRC's value relative to its associated uncertainty. As the ratio of the NRC value to its associated uncertainty, referred to in this program as " Resolution"1 increases, the- range of acceptable differences between the NRC and licensee values should be more restrictive. Conversely,' poorer agreement between NRC and licensee values must be considered acceptable as the resolution decrqase For comparison purposes, a ratio 2 of the licensee value to the NRC value for each individual nuclide is computed. This ratio is then evaluated for agreement based on the calculated resolution. The corresponding resolution and calculated ratios which denote agreement are listed in Table 1 below. Values outside of the agreement ratios for a selected nuclide are considered in disagreemen NRC Reference Value for a Particular Nuclide 2 Resolution = Associated Uncertainty for the Value Licensee Value 2 Comparison Ratio = NRC Reference Value >

TABLE 1 - Confirmatory Measurements Acceptance Criteria Resolutions vs. Comparison Ratio

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Comparison Ratio for Resolution Agreement

<4 0.4 - . . .6 -31.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25

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0.85 - 1.18 i

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