ML19341C440

Responds to NRC 801208 Ltr Re Violations Noted in IE Insp Rept 50-326/80-02.Corrective Actions:Escort Provided to Any Person Required to Perform Work in Facility Which Is Not Directly Associated with Radiation Producing Device

ML19341C440
Person / Time
Site:	University of California - Irvine
Issue date:	12/24/1980
From:	Mcgaugh J CALIFORNIA, UNIV. OF, IRVINE, CA
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19341C437	List: ML19341C440
References
NUDOCS 8103030480
Download: ML19341C440 (8)

Text

9UNWEllSITY OF CALIFORNIA, IRVINE _~

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December 24, 1980 '6

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Region V., V N 'w N Fuel Pacility and Materials Safety Branch, 1990 N. California Blvd.

{,'_d W, jf' Suite 202, Walnut Creek Plaza Docket 50-326 Walnut Creek, California 94596 License R-ll6 Re: Notice of Violation dated 12/8/80.

Gentlemen, Ue are in receipt of a Notice of Violation dated 12/8/80, signed by H.E. Book concerning non-compliance with Part 19.12 of 10 CFR.

As noted by your investigators, this facility has taken the position that the need for adequate protection of the health and safety of the public and of employees of the University is met by provision of an escort, fully qualified in matters of radiation protection experience and knowledge of facility procedures, to accompany, at all times, any individual required to perform work in the facility which is not directly associated with any radiation producing device or radioactive material. As noted, this incident involved the proposed installation of electrical conduit on the ceiling of the facility and so came into this category. In following this policy we have never asked personnel from outside the facility staf f to perform work involving direct radiation hazard.

In each case, the escort gives the individual (s) oral instructions regarding areas and items to be careful of within the facility, proper response in the event that an alarm sounds, the need for use of personnel dosimeters and their care, and the need to observe instructions of the escort and other f acility staf f.

The above policy was ins tituted and followed at our facility because the nature of the " work force"on a University Campus and the work accomplished, does not warrant the creation of a class of " radiation workers" beyond the immediate facility staff. Personnel from groups such as Facilities Management, performing occasional tasks within the f acili ty , spend an extremely small fraction of their work career on tasks in any way connected with reactor facility operation.

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i December 24, 1980 Page 2 e i Docket 50-326 t

l l We are of the opinion that the above policy meets the general

requirement for protection of the health'and safety of the public

! and of employees. This policy was followed closely by our staff member C. F. DeKeyser, the escort for four facilities management personnel who were admitted on August 21st, 1980 and for the two persons

! from facilities management (one admitted also on the earlier date) adtmitted on 8/25/80. We cannot agree, therefore,with the conclusion that:

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, "------had not been instructed in any* of the topics identified in 4 10 CFR 19.12 prior to working in-----on August 25th, 1980--- ".

• (emphasis ours).

Commission staff obviously are of the opinion that our policy does not fully comply, especially as to documentation, with the require-monts of 10 CFR 19.12. We have thus made changes in our policy 1 and procedures in accordance with our statements to your inspectors j given on Pace 9 (Inspection report 50-326/80-02) which we trust will be seen to bring us into full compliance. These actions are

detailed on the following pages.

Sincerely, 4

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'l J. L. McCaug,n E>iecutive Vice-Chancellor cc: G. E. Miller, Chemistry F. S. Rowland, Chemistry d

D. Sherman, Pacilities Management J. G. Tripodes, Radiation Safety Officer a

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EXI.CUTIV E Vite Cll ANCLI I UR i

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• NI A H717 December 24, 1980 Docket 50-326 Notice of Violation 12/8/80 Licensee Rosponse L

(1) Corrective steps taken and results achieved.

On October 31st by memo sinned by the Reactor Supervisor and dis-tributed to all reactor staf f personnel who can permit facility access, and to Facilities Management, all persons not fully instructed and trained in the use of radiation and radioactive materials were  !

excluded from the f acility except for cases of " extreme emergency".

This ruling applies until such time as new procedures are fully established for instruction and training. This policy has been firmly enforced, and thus no further violations have been possible since that date, i Section 4.9 (Access to the Pacility), of the reactor facility Standard

+ Operating Procedures has been revised and approved by the Reactor I Operations Committee membership to accommodate the need for certification of instruction of all persons admitted to perform work within the I

facility. It should be noted that no one other than authorized facility users has keys to gain admittance to our facility. A copy of the revised section is attached for information. This cection requires that

! a certificate be issued by the Reactor Supervisor and signed by the individual worker stating that instruction has been given and received.

l Such certificates will carry an identification number which must be entered in the entry log to the facility at any time entry is permitted.

Escort is sti.ll required for such persons.

(2) Corrective steps which will be taken.

i In prepteration, by the Reactor Supervisor and the Radiation Safety

< Officer with assistance from Facilities Management, is a training document and program to provide all the information listed in 10 CPR

! 19.12. This wi11 be used in establishing certification of persons who need to enter the facility but who will not be considered fully author-ized facili ty users. It is anticipated that this documentation will be completed shortly. At that time, a process of identification will be started to select for training those employees most likely to need access to the reactor facility. As noted above, no one will be permitted to enter the facility until this certification has been accomplished.

As part of the instruction, ample opportunity for questions will be given to all workers entering the certification process. We expect this program to be fully operational before the end of January, 1981, i l l

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l 4 r Docket 50-326 i

, Notice of Violation 12/8/80

• Licensee Response Page 2.

{ Reactor staff personnel have been informed that a note must be

attached to any work order issued to Facilities Management Division  !

j for work in or connected with the Reactor Fricility to the effect that

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workers r.uct be fully certified to carry out the project.

j Facilities management will establish a new policy for the methods f supervision must employ in safety oriented worker relations which

, will mandate full consultation with E, H and S and with the pertinent  !

{ area responsible party. This will be accmpanied by use of a pre- 3 j work authorization form to be completed prior to entry into any potentially hazardous area on Campus. This will identify specific

potential safety problems, require a preparatory site review by super-visors and cuard aoainst conduct of experiments while Facilities Management workers are present in the area.

+ Efforts are beino made to incorporate a notice in job descriptions of I

certain classifications to the effect that work in radiologically j controlled areas may, at times, be required.

(3) It is anticipated that much of the program outlined above will be fully operational by the end of the Winter Quarter, 1981. It should

. be noted that the current policy of exclusion does bring us into I compliance immediately, in that no workers, not instructed fully in -

i accordance with 10 CFR 19.12 will be asked to enter the restricted

area.

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! Items cuch as revision of job descriptions will be accomplished i throughout the year as reviews are conducted. ,

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I 1 Signed _______(

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Date M'A b i

J. i.. McGaugh E::ocutive Vice Chancellor I

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' ' U.C.Irvine TRIGA Nuclear Reactor Facility Stanced Operating Procedures

. 4.9 Access to the Facility i

Access to the U.C. Irvine TRIGA reactor facility is restricted for reasons of radiation safety, radiation control and physical sL Lrity. Security procedures are part of a separate plan approved independently by the Nuclear Regulatory Commission. Knowledge of this plan is restricted to those involved in its implementation.

The procedures described here relate primarily to the need for

radiation control, although the methods used parallel those adopted i for security reasons.

. ine Reactor Supervisor has control over access to the facility -

comprising rooms BS4, BSAA, B548, B64 and B62 in the Physical Sciences Building. The decisions of the Reactor Supervisor are subject to review by the Reactor Administrator and the Reactor Operations Committee.

4.9.1 Access Authorization Catecories I Three categories of authorized user are established. All other persons are considered VISITORS. Persons are assigned to each category by the Reactor Supervisor. All authorized users are issued identification cards to aid in security control. A category of certified workers is established for those whose work does not normally involve rudiation or radioisotope use.

4.9.1.a Fully Authorized User. (Category A)

Persono in this category shall:

(i) Have completed a course in general radiation safety given by the campus radiation safety office.

9 (ii) Have received additional instruction by facility staff and passed a test in specific facility radiation control and

security procedures.

(iii) Have shown a responsible attitude to following procedures for radiation and security control and for conduct of experiments involving facility equipment.

(iv) Show a need for frequent entry to the facility.

Persons in this category will be permitted to enter the facility at any time, and may admit visitors to the facility.

4.9.1.b Authorized User. (Category 3)

Persons in this category must have met all the criteria for Category 1

A, except that in item (iv). The need to enter the facility will be only for limited periods to perform specific operations.

j Persons in this category will only be permitted to enter the facility when it is NOT in SECURE status, but may escort i visitors during such times.

Printed 11/12/80 l

4-9-1 Approved 12/12/80 u

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1 4.9.1.c Authorized Visitor. (Category C) ,

Persons in this category shall:

I (i) Have demonstrated or documented experience with general i radiation safety practices.

) (ii) Have received additional instruction and passed a test in i speci fic facility radiation control and security

, procedures.

(iii) Have demonstrated through experience or otherwise, a i responsible attitude to procedures for radiation and r security control and for conduct of experiments involving facility equipment.

! (iv) Show a need for a temocrary access to the facility.

Perscnc in this category will normally be permitted access only when the f acility is NOT SECURED. For brief, and specific, pericas of time such persons may be permitted access during times that the

facility a SECURED. Persons in this category may escort visitors into the racliity.

This category is used for persons wno are not employees or full time students at U.C. Irvine, but who are engageo in experiments using i equipaent Wit.nin the reactor facility.

4.9.2 Access Control.  !

Access to the facility is made oy using a key card, issued to notnorized u.;ers by the Reactor Supervisor. Key cards may not be transferrea. The controller for the key card system checks the authorizatico category of the user and permits access or denies access according to the status at the time.

While the react.or is in operation, the OPERATOR-IN-CHARGE (SOP 1 Section 4.1.1.b.) may deny access to any individual for any reason.

! A list of all authorized users will be posted in the reactor control rocm at all times. The list posted is considered to be the most current list.

4.9.3 Vinitorn.

All individuals not authorized under Categories A-C in section 4.9.1 i are considered visitors to the facility. Requirements for visitors

, are:

( i) Viuitors MUST be escorted AT ALL II!!ES that they are within the facility by an authorized user, Printed 11/12/80 4-9-2 Approved 12/12/60

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(ii) The name and company affiliation or full home address for EVERY visitor must be recorded clearly in the visitor's log by the escort.

(iii) All visitors must be issued dosimeters to wear during their visit within the facility. The date and time of entry to the facility, the number of the dosimeter, the initial reading, the final reading on exit and the difference between initial and final readings of the dosimeter MUST be read and recorded in the visitor's log by the escott. The name of the escort must be recorded. If the reading difference is greater than 2 me, alert level procedure (SOP 4.5.4) shall be followed immediately. For groups of visitors, dosimeters shall be issued to at least 1 individual for each five visitors. (Note: ALL names must be recorded.) A special form may be used to record the

names for tour groups.

VISITORS WHO WILL PERFORM WORK OF ANY TYPE WITHIN THE FACILITY MUST MEET T12 REQUIREMENTS OF SECTION 4.9.4.

4.9.4 Certified Workers l

Individuals not normally considered " radiation workers" may nave occasional need for access to the f acility . Such persons include janitorial staff, facilities management maintenance personnel, ant-lytical instrument services personnel, machine shop personnsi, students in one quarter classes, etc. Such workers are classified as VISITORS for the above regulations, and the requirements of 4.9.3 must be followed fully, except that a different log sheet is used.

In nddition to the requirements o f 4. 9. 3. , however, such persons must alco have received instruction in health protection problems associated with exposure to radioactive materials or radiation, in precautions needed to minimize exposure, the purposes and functions of protective devices, their responsibility to observe established procedurou at the facility, their response to instructions from i their escort, their responsibility to report observations or events that might have resulted in any exposure to radiation or radioactive materials, and their rights to receive reports of any radiation exposure incurred, and their rights to report apparent safety problems.

For students in classen using radioactive materials, this instruction must be given in the form of class lectures in aspects of radiation safety prior to the student's first entry into the facility. The course instructor must provide written certification to this effect for each student to be admitted. For other workers, this instruction must be approved by the Office of Environmental Health and Safety.

Before any individual in this category may he admitted to the facility by an escort, the escort shall confirm that a written, properly signed and authorized certification to the effect that each Printed 11/12/80 4-9-3 Approved 12/12/80

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individual, by name, has received such instruction, in on file at the facility. Signatures of the Reactor Supervisor and the individual being admitted must be on the authorization. The indivdua l's authorization number from the certification must be recorded in the entry log.

j The provisions of this section, (4.9.4), in no way relieve the

ESCCRT of his/her responsibility to properly fill out entry logo and issue dosimeters as needed, to remain with the the individuals ad.nitted AT ALL tit 1ES and to be FULLY RESPONSIBLE for assuring that no unplanned rsdiation exposure is afforded to such workers as a

. result of facility activities.

In the case of a serious emergency, needing the attention of an individual falling in this category, the escort may exercise judgement in admitting an uncertified person, if no certified worker

is available. Such an instance must be reported as soon as possible to the Reactor Supervisor and to the Radiation Safety Of ficer.

Any person wna performs any types of work or operations within the facility must comply with the reouirements of this section.

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Printed 11/12/80 4-9-4 Approved 12/12/80

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