ML20024H203

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Proposed Tech Spec 6.0 Re Organizational Chart
ML20024H203
Person / Time
Site: Neely Research Reactor
Issue date: 05/15/1991
From:
Neely Research Reactor, ATLANTA, GA
To:
Shared Package
ML20024H202 List:
References
NUDOCS 9105300114
Download: ML20024H203 (46)
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Text

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6.0 ADMINISTRATIVE CONTROLS 6.1 ORGANIZATION i

a. The organization for the management and operation of the reactor shall be as indicated in Figure 6.1. The Director, Nuclear Research Center shall have over all I responsibility for direction and operation of the reactor facility, including safeguarding the general public and facility personnel from radiation exposure and adhering to all requirements of the operating license and Technical Specifications.
b. The Manager, Of fice of Radiation Safety, shall advise the Director, Nuclear Research Center in matters pertaining to radiological safety. She/he has access to the Vice-President, Interdisciplinary Programs and/or the President of the Institute as needed,
c. The minimum qualifications with regard to education and experience backgrounds of key supervisory personnel in the Reactor Operations group shall be as follows:

(1) Reactor Supervisor The Reactor Supervisor Dust have a college degree or equivalent in specialized training and applicable experience, and at least five years experience in a responsible position in reactor l operations or related fields including at least one year experience in reactor facility management or supervision. He shall hold a Senior Reactor Operator's license for the GTRR.

(2) Reactor Encineer The Reactor Engineer must have a combined total of at least seven years of college level education and/or nuclear reactor experience with at least three years experience in reactor operations or related fields. He shall be qualified to hold a Senior Reactor Operator's license.

d. Senior Reactor Operator's License Whenever the reactor is not secured, the minimum crew complement at the facility shall be two _ persons, including at least one senior operator licensed pursuant to 10 CFR 55.

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1 Attachment B I

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. __ _ _. _ ._______-.____._.__._______._____m. -

. _m Section 9 Ilealth Physics Operations 9010 Kanne Chamber Calibration 10/14/88 9012 Operation and Calibration of The Gas 04/28/89 '

Monitor 9013 Calibration and Testing of Moving Air Particulate Monitor 10/21/88 9014 Vibrating Reed Electrometer Calibration for Tritium 02/28/78 9015 Cooling Water Gamma Monitor 10/21/88 9016 Calibration and Testing of Filter 10/21/88 Bank Monitor 9017 Stack Grab Sample Analysis 10/14/88 9018 Charcoal Cartridge Analysis 10/14/88 9019 Cooling Tower Tritium Analysis 07/17/81 9025 Liquid Waste Tank Analysis 12/10/85 9037 Tritium Determination in Urine 04/28/89 9038 Bioassay Program 04/28/89 9040 Liquid Waste Tank Analysis 10/21/88 9041 Storage Pool Water Sampling and Analysis 12/30/88 9050 Basic Portable Ionization Chamber l

1 Calibration 02/28/78 9051 Basic Portable GM Survey Meter Calibration 02/28/78 9052 Basic Portable Alpha Meter Calibration 12/10/85 l

9053 Basic Portable Neutron Meter Calibration 02/28/78 9054 Calibration of The Low Beta II Alpha / Beta Counting System 10/14/88 9055 Operation of The Low Beta-II Alpha / Beta Counting System 10/14/88

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Section 9 Continued 9056 Calibration and Operation of The Ludlum 2000 Scaler 10/21/88 9057 Calibration Procedure for Eberline Model E-120 GM Survey Meter 12/30/88 9058 Calibration Procedure for dberline Model l RM-14 Rate Meter 12/30/08 ,

9059 "As Found" Calibration Check 12/30/88 9060 Calibration Procedure for Bicron Model RSO-5 Survey Meter 12/30/88 9061 Testing Procedure for Pocket Ionization 12/30/88 Chambers (PICS) 9062 Calibration Procedure for Victoreen Panoramic Model 470A Survey Meter 06/30/09 9063 Calibration Procedure for Ludlum Model 2 GM Survey Motor 03/30/89 9064 Calibration Procedure for Eberline Model RO-3A Survey Meter 06/30/89 9065 Calibrtion Procedure for Bicron Model RSO-500 Survey Meter 06/28/90 9066 Calibration Procedure for the Bicron Microanalyst Survey Meter 02/15/90 9068 Calibration of the SAIIIIC-RADECO Model H-809V Air Sampler 09/29/89 l

l 9069 Calibration of the Gast Model 0522 Oil-Less Vacuum Pump 08/25/89 9070 Calibration of the Harshaw Automatic Integrating Picoammeter Model 2000-B 04/28/89 9071 Calibration of Beam Intensity of Radiation Sources 08/25/89 l 9072 Calibration Procedure for Eberline Model RO-2 Survey Meter 09/29/89 9074 Calibration Procedure for Eberline Model PIC-6A Survey Meter 04/26/90 l

-9150 Operation and Calibration of Area l Radiation Monitors 08/25/89 i

Section 9 Continued 9151 Calibration and Operation of The Tri-Carb 2000 Serios Liquid Scintillation Counter 10/14/88 ,

l 9152 Basic Gas Proportional Flow Counter

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Calibration 02/28/78 9153 Dasic TLD Roador Calibration 02/28/78 9154 operation and Calibration of the Gamma Analysis System for Effluent Monitoring 10/14/88 9155 Determination of Count Times Based on a Priori Lower Limit of Detection (LLD) 12/30/88 9250 Facilition Contamination Surveys 09/09/08 9251 Procedure for Picking Up, Receiving, and Opening Radioactivo Packages in Accordance with 10 CPR 20.205 02/28/78 9252 Stack Flow Test 12/10/85 9280 Personnel Monitoring 10/21/88 9300 Respiratory Protection 08/06/80 9302 Protectivo Clothing Requiremonts 09/09/88 9303 Guidelines for Handling Radioactivo Spilla 08/08/89 9304 Routino Facility Radiation Surveys 09/09/88 I 9306 Preparation & Maintenance of RWP's 09/09/88 l 9300 Airborno Radioactivity Surveys 09/09/88 9310 Posting of Radiological Control Areas 10/14/88 and Materials 9400 Environmental Monitoring 9501 Control & Accountability of Radioactivo Sources 04/28/89 9502 Control and-Accountability of Radiation l Generating Devices 08/25/09 i

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, ATL ANT A. GE ORGIA 3033D-01CS p104 ) Ima -30 0a March 23, .1990 MEMORANDUM To Nuclear Safeguard Committee FROM: R. A. Karam W-W T SUBJECT. Audits At the request of the Chairman, Dr. Bernd Kahn, I am sending you this memo to remind you that audit assignments, as distributed to you on January 26, 1990, are due March 31, 1990.

The audit assignments are attached for your convenience.

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AUDIT ASSIGNMENTS FOR NSC MEMBERS Reports are due March 31, 1990 Audit records created by procedures 2000 series: Dr. J. Mahaffoy Audit records created by procedures 3000 serios: Dr. E. Barefield Audit records created by procedures 4000 series: Dr. H. Neumann Audit recordo created by procedures 6000 series and security plan and procedures: Mr. J. Vickory Audit records created by procedures 7000 series: Dr. P. Desai Audit records created by proceduros 8000 series: Dr. S. Abdel-Khalik Audit records created by procedures 9000 series: Dr. B. Kahn*

Dr. J. Gordon Dr. B. Livosay Mr. Los Potherick*

Audit actions taken to correct IFI's: Mr. E. Cobb*

  • Completed Audits

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n wmeer operations Department Georgiti Power March 22, 1990 l

l Dr. B. Kahn, Chairman Nuclear Safeguards Committee Old CE Building Georgia Institute of Technology Atlanta, Georgic 30332-0225

Dear Dr. Kahn:

I have completed the assignment to audit action taken on Nuclear Regulatory Commission (NRC) Open Items associated with Neely Nuclear Research Center (NNRC). The audit was conducted March 14, 1990 at the NNRC.

l There are thirteen open items. Nine items are ready for NRC review and i closure either now or at the next emergency exercise. The other four open l items remain open for action to be completed.

I Appendix A prc.vides a brief summary of the status of the thirteen open items. Appendix B is a more detailed description of each open item and current status.

Sincerely, E. F. Cobb dmc i

l Attachment xt: R. A. Karam p+w m.

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APPENDIX A

SUMMARY

OF NRC OPEN ITEMS l.lf!D MAhli  !

1. VIO 87-01-01 Ready for NRC review.

Utilize Procedure ,

2. VIO 87-01-02 Ready for NRC review. -

Control Experiments

3. UNR 87-01-10 Remains open to determine all Instrument Calibrations bench test instruments identified. ,
4. -Ifl 88-02-13 Remains open to evaluate test Reactor Coolant flow results.
5. VIO 89-02-01 Ready for NRC review.

Containment Test

6. VIO 89-02-02 Ready for NRC review.

Shim Blades

7. IFI 89-03-01 Procedure needs additional review Radioactive Material by NNRC.
8. Exercise Weakness 89-04-01 Confidential scenario will be used Fully Testing Emergency Plan fer next exercise. Ready for NRC revtew.
9. IFl 89-04-02 Ready for NRC review, Radio Transmission
10. IFI 89-04-03 This will be tested during next Test Off-site Components exercise. Ready for NRC review.

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11. IFl 89-04-04 Ready for NRC review.

Emergency Plan Training

12. IFI 89-04-05 Ready for NRC review.

Required Notification

13. IFI 90-01-01 Remains open to make a technical Stack Grab Sample change.

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l APPENDIX B STATUS OF NRC OPEN ITEMS

1. VIO 87-01-01. Failure to provide or utilize procedures.

1111M1 A letter response.by NNRC was made on July 15, 1987 to the NRC.

While not all corrective action was completed, all estimates of action completion were in 1987. This violation is ready for NRC review.

2. VIO 87-01-02. Failure to control experiments per Technical Specifications.  ;

it.ilt9.1 Same as VIO 87-01-01 stated above.

3. UNR 87-01-10. Verify that instrument calibrations necessary for operability of safety equipment listed in Technical Specifications Table 4.1 are performed.

Status The NRC reviewed status of the unresolved item during a NRC inspection which was reported in Inspection Report 89-02 on November ll, 1989. The following statement was made by the NRC:

"The licensee has records of calibrations of four instruments used in calibrating the instrumentation listed in Table 4.1. .

Those instruments are:

"HP Multimeter, SN 2237AIS867, Model 3468A; Keithley Picoampere Source, SN261, Model 261; HP Universal Counter, SN 2714A15245, Model 5314A; and HP VTVM, SN316-09668 Model 412A.

1 "All have current calibrations against NBS standards.

However, it was not determined that these are the only bench test instruments used in the calibration of the Table 4.1 equipment. Hence, this item remains open."

4. IFI 88-02-13. Develop and implement reactor coolant flow calibration procedure.

The following is quoted from NRC Inspection Report 88-02:

" Surveillance procedure 2015, Reactor Power Calibration, is required to be performed weekly when at 1 MW or higher power.

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"The measurement is performed by considering the heat removed by the primary coolant (02 0) flow and the light water coolant flow through the shield. (The latter appears to a negligible heat sink l during 1 MW operation.) The primary coolant flow detector, a turbine vane flow meter, has not been calibrated since it lef t the factory and does not appear to be susceptible to on site calibration. Hence, the accuracy of the power calibration, which is proportional to the product of flow times coolant temperature rise, is indeterminable as currently performed. '

"In the secondary coolant system, there is a calibrated flow orifice plate and the dP cell across the plate has been calibrated against a standard water gauge on occasion. The licensee has neither a procedure nor a schedule for this calibration.

"In order to justify a power calibration based on primary flow, that flow must be calibrated. That calibration can be accomplished by performing simultaneous heat balances on the secondary and primary sides, equating them, and solving for primary flow. The prerequisites to this measurement include calibration of the dP cell in the secondary flow system and calibration of the RTDs and thermocouples used in the temperature measurements. This flow and power calibration should be performed before exceeding 1 MW and at 1 MW increments as power is increased to the license limit of 5 MW.

, Appropriate procedures and schedules for the calibration of flow and temperature measuring devices must.be established by the licensee. The licensee committed at the exit to develop the appropriate procedures and implement them prior to exceeding 1 MW.

(IF1: 50-160/88-02-13)."

31i!1M The secondary coolant system calibrated flow orifice plate (venturi) has not been calibrated since original calibration. The venturi was inspected and found to be clean and useful for the establishment of secondary coolant flow. Heat balance tests have been made at IMW, 2MW, 3MW and 4MW. Test data and results are being evaluated.

5. VIO 89-02-01. Failure to perform the containment building leak-rate test in accordance with commitments.

l Statu NNRC has reported the fcilowing status to the NRC:

" Procedure 4000, Containment Building Pressure Test, was deficient in that the procedure did not provide adequate guidance to the operator in the area of data handling and treatment.

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- " Procedure 4000 has been revised and is currently being reviewed against Standard ANS 7.60 and other requirements.

"It is anticipated that an adequate procedure which meets the requirements of ANS 7.60 will, when completed, ensure that further violations in this area do not occur,

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" Full compliance will be achieved as of March 31, 1990."

Procedure 4000 was revised and procedures 4001 and 4002 written to correct deficiencies. The Nuclear Safeguard Committee reviewed and approved procedures 4000, 4001, and 4002 on March 22, 1990.

6. VIO 89-02-02. Procedures did not assure that any shim blade not fully inserted was withdrawn sufficiently to cause a negative rate trip when released into the core, as required by Technical Specification 3.1.d - paragraph 5.

Status NNRC has reported the following to the NRC:

"The Staff of the Neely Nuclear Research Center has been involved in upgrading o'perating procedures on many fronts:

Health Physics, Operations, Emergency Response, Environmental, Security, etc. Consequently, the procedure to assure that shim safety blades were always withdrawn to at least 5 degrees was overlooked.

" Procedure 7247 has been drafted to cover this area and is

currently undergoing review.

"The corrective action directed toward development of an adequate procedure which implements Technical Specification requirements will, when completed, ensure that further violations in this area will not occur.

" Full compliance will be achieved as of March 31, 1990."

The Nuclear Safeguard Committee has approved Procedure 7247.

7. IFl 89-03-01. Follow up the development of a procedure for the shipment of radioactive material.

Status The NRC reviewed status of the inspector follow up item during a-l NRC inspection which was. reported in Inspection Report 90-01 on February 5, 1990. The following statement was made by the NRC.

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l "The inspector verified that a draft procedure has been l written for handling radioactive waste and completing radioactive material shipment. The licensee indicated however, that the procedure still needs to be revised before being submitted to the NSC for review and approval."

The procedure has not been revised additional.

8. Exercise Weakness 89-04-01. Failure to conduct the annual emergency drill in a manner that would fully test implementation of the Emergency Plan.

Status This weakness involved the NP.C inspectors comment that the drill scenario should not be developed by a drill participant and that drill exercise players should not have advance knowledge of the scenario details. NNRC committed to ensure that exercises are conducted using a confidential scenario for fully testing the entire emergency organization. This will be demonstrated at the next emergency exercise.

9. Ifl 89-04-02. Conduct an evaluation of radio transmission over the entire EPZ to identify areas of impeded transmission.

Status A brief loss of communications between the Emergency Director and Health Physics personnel was caused by a communications dead spot in the vicinity of the storage pool. A radio test has been conducted over the entire EPZ. Action is completed.

10. IFI 89-04-03. Verify that the full-scale exercise conducted on a biennial basis, included an accident scenario that will test all on-site and off-site components of the emergency organization.

Status This item resulted from the simulated emergency event which was not a classifiable event that warranted off-site notifications to State, local and federal authorities. Drills are expected to conduct such notifications every two years. This will be tested at the next emergency exercise.

11. IFl 89-04-04. Proceduralize the emergency response training program to ensure documented compliance with Section 10.1 of the Emergency Plan.

Status A procedure has been written and approved to describe the emergency response training programs. The IFI is ready for NRC review.

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12. IFl 89-04-05. Review Procedure 6100 (Emergency Notification) to ensure that all required notifications are included and made in a ,

timely manner.

Status Procedure 6100 has been reviewed and revised to ensure that all required notifications are included in the procedure. This item is ready for NRC review.

13. IFI 90-01-01. Fallow the revision of Procedure 9017, Stack Grab Sample Analysis, Rev. 2, of October 14, 1988.

111191 The NRC reviewed status of the inspector fellow-up item during a NRC inspection. The following statement was made by the NRC in the Inspection Report:

"IFI 88-02-08, Stack Grab Sampling, was established due to the potential occupational hazards associated with climbing the exhaust stack while carrying sampling equipment. The licensee agreed to evaluate the stack samoling method and consider another possible method for obtaining the sample.

"The inspector discussed the sampling process with licensee representatives including those who actually climb the stack to obtain the sample. Although management and workers alike felt that climbing the stack posed only a limited safety hazard, the licensee has decided to change the method used to sample the air from the

, exhaust stack. This IFI (88-02-08) will be closed but another l established to follow and review the revised procedure. The NRC will track revision of Procedure 9017, Stack Grab Sample Analysis, Rev. 2, dated October 14, 1988, as an IFI (50-160/90-01-01)."

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d [Ut]f d 1, ,/ 4 suritoicAt. iscisiIRisc May 15,1990 cm,@ swimm>r ittiin >hin enu cmm wuo.os MEMORANDUM TO: Dr.13. Kahn, Chair, Nuclear Safeguards Conunittee  ;

I FROM: Prateen V. Desai SUlijECT: Audits I have now completed the audits of the 7000 Series Procedures. I randomly picked Procedure 7241 and Procedure 7420 for the audit.

Procedure 7241 concerns reactor tank level transmitter maintenance and calibration to be conducted twice a year. In particular, these were performed on 2/23/88,7/23/88, 2/23/89,7/26/89 and 2/12/90, in each case the procedure was performed as per its approved version by our committee.

Procedure 7420 concerned with providing channel check test or calibration for safety related instruments, it included several related procedures. Procedure 2003 dealt with 7

daily reactor pre startup checklist, Procedure 2002 dealt with weekly pre-startup checklist and Procedures 4010,9012,9013,9015,9016 and 9150 dealt with monthly and yearly checks.

For audits, I randomly picked the week of May 29th,1989 for the daily check, the weeks of May 29th,1989 and June 5th,1989 for the weekly checks and the month of May 1989 (5/08/89 - 6/08/89) for the monthly checks. I also randomly picked instrument

! channel Map-l for my audit. Weekly checks were performed as per approved procedure.

Daily checks were performed as per approved procedure for only two days during the week of May 29th, namely on May 30th and 31st, these being the only two days of the week when the reactor was operating. The monthly and yearly checks were also performed as per approved Procedure 9013.

In summary, my audit of two randomly chosen 7000 Series Procedures 7241 and 7420 indicates that the NNRC staff has satisfactorily performed the latest versions of the procedures approvedby thc Nuclear Safeguards Committee.

Sincerely, Prateen V. Desai Member Nuclear Safeguards Committee PVD/eb miu- ew-c.~ wm . u mom o-o ** *w

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... .i*4-MEMORANDUM ,

TO: Dr. Ratib Karam FROM: Jack Vickery[

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SUBJECT:

Audit--6000 Series Procedures and Security Plan I have reviewed the security plan of the NNRC and the following procedures:

1. Procedure 0001- Access Control and Accountability of Keys and Access Cards.

Approved 12/08/89

2. Procedure 0002--Security System Testing.

Approved 12/08/89

3. Procedure 0003- Emergency Power Generator Test.

Approved 12/08/89

4. Procedure 6010--General Rules and Guides for Handling Emergencies.

Approved 12/30/88

5. Procedure 6020. Response to Heavy Water Leakage in Containment Building.

Approved 02/02/89

6. Procedure 6030--Response to irradiated Fuel Element Becoming Unshielded.

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Approved 02/02/89 l 7. Procedure 6040- Response to Fire at NNRC.

Approved 02/02/89

8. Procedure 6050--Respcnse to Zine Bromide Leak in Hot Cell Window.

Approved 02/02/89

9. Procedure 6060--Response to Pool Water Draining with Co-60 Sources in Bottom. Approved 02/02/89 l 10. Procedure 6070--Response te Loss of Integrity of CO-60 Sources.

l Approved 02/02/89

11. Procedure 6090 Personnel Monitoring after Building Evacuation in Emergency l

l Situations. Approved 02/02/89

12. Procedure 6100--Emergency Notification.

Approved 02/02/89 Minor Change 09/28/89 l

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Page 2 My findings and recommendations are as follows:

1. Procedure 0001- Inventories of keys and rnagnetic cards are In procass of being transferred to forms SEC 005 and SEC 006 as requited by procedure.
2. Procedure 0002 Records of test of security system were on file and up-to date.
3. Procedure 0003--No record of test of emergency power generator located.
4. No records have been generated as a result of the implementation of l procedures 6010. 6020,6030,6040,6050,6060,6070,6090 and 6100.
5. Procedure 6080--Accidental Release of High Levels of Gaseous Activity to the Atmosphere, although referenced in other procedures, has not been written yet.
6. Procedure 6090--Appendix A (page 4) of this procedure is a list of NNRC personnel. This list was out of date in the manual, however, an up to date list was on file. Recommendation: Consider removing the list of personnel which is subject to change from the procedure, but maintain it in a separate file.

I hope this information will be of assistance to the management of the NNRC.

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.- l CC:RGIA T:CNC:3.*iACCNINSTITUTE ,

GEORGtA INSli1UTE Of TECHNot.OGY l ATLANTA GEORGtA 30332 I

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13 April 1990 MEMORANDUM TO: Dr. B. Kahn, Chainnan, Nuclear Sateguards Committee FROM: Dr. J. Mahaffey M

SUBJECT:

Audit of 1989 2000-level procedures (reactor operations)

As a spot check of general 2000-level procedures I have examined the Weekly Precritical Startup Checklists (2002) and the Weekly Shutdown Checklists (2006) for every week of 1989.

In general, the checklists appear correct, complete, and consistent. A few very minor ex-ceptions are as follow:

1) On 6 November , and 17 January no flux amp trip points were recorded. On 5 June trip point no. 2 was recorded, but trip point no. I was not. On 13 February the blarks reserved for trip point recordings were checked, with no numbers supplied. On two other occasions no trip points were recorded, but adequate explanations were written.
2) For each of the 37 weeks of operation the parameter labeled " upper window" was record-ed as "4.7," except for the week of 9 January, in which the recorded number was "440." There was no explanation offered for this 100X discrepancy.
3) Similarly, for each of the 37 weeks the parameter labeled " lower window" was recorded as ".21," except for the week of 9 January, in which the recorded number was "20."
4) The parameter labeled " fine gain" was always recorded as " 93," except on 3 January,4 January,10 May 17 May,6 march, and 24 February, when it was recorded as "9.3."

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TO: DR. KARAM NUCLEAR RESEARCl! CENTER.

/p; i PROM: J. NIC O l,GORp'Oh MD ' ,, ' _. 'g , , 4>

DIRECTQR/ OgN T/.B D ill ' j f/ y ,

RE: NEELY NUCLEAR RESEARC." CENTER AUDIT I. TESTING PROCEDURE FOR POCKET IONIZATION CHAMBER (PICS)

PIC calibration should be checked every 6 months. On the following PICS the checking wus several days late.

PIC NUMBER DATES CllECKED 4031577 9/8/89 - 3/16/90 4052633 9/6/89 - 3/16/90 4052634 9/11/89 - 3/14/90 II. BIO ASSAY The Bicassy procedure states that all employees should be examined with a urinary tritium and gamma isotope analysis as follows:

1. . Annually
t. Upon termination of employment
3. Any additional tin,es as determined by the Manager, Of fice of Radiation Safety (MORS) or designee.

FINDINGS:

It was found that the employees were t;io assayed annually and upon termination of employment as directed above. Only the tritium assay was done. It was then explained that only tritium is used and that the gamma ISOTOPE ANALYSIS was done only in special cases.

If this is so, the procedure 5.2.3 should be corrected, unit m e, um. rsa, s<si - a cem,a & a rua e a,o E m i- r.mi o u tonav mmuw

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NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9038 Numbar DIOASSAY PROGRAM Revision 01 By: Approved 04/28/89 Date / / Page 2 of 6 4.3.1 ANSI N343-1978, "American National Standard for Internal Dosimetry for Mixed Fission and Activation Products."

4.3.2 International Commission on Radiological Protection, Pub. 2, "3eport of Committee II on Permissible Dose for Internal Radiation," 1959.

4.3.3 International Commission on Radiological Protection, Pub. 10, " Evaluation of Radiation Doses to Body Tissues from Internal Contamination Due to Occupational Exposure," 1967.

4.3.4 International Commission on Radiological Protection, Pub. 10A, "The Assessment of Internal Contamination Resulting from Recurrent or Prolonged Uptaken," 1969.

4.3.5 NUREG/CR-4884, " Interpretation of Bionssay Measurements," 1987.

4.3.6 Regulatory Guide 8.32, " Criteria for Establishing a Tritium Bioassay Program," 1988.

5.0 PROCEDURES /REOUIREMENTS 5.1 Equipment / Materials Needed 5.1.1 None 5.2 Procedure 5.2.1 The estimation of radioactivity in the human body shall primarily be measured by analysis of urine samples.

5.2.2 The Radiation Safety office shall request a- urine sample from individuals and shall document the request in the bioassay logbook or record. ____ _

5.2.0 The primary analyses that shall be performed are tritium analysis and gamma isotopic analysis.

5.2.4 The routine bioassay program shall consist of:

5.2.4.1 Beginning employment bioassay.

5.2.4.2 A yearly bicassay.

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e Georgia Institute of Technology A UNIT Or 1 HE UNivt nsrTY GYST E M OF GL OHGIA I j NUCL E AN ENGtNEERING AND HE ALT H PHYSICS PMOGRAMS

. . ' ' 4p/ SCHOOL Or Mc CHANICAL ( NGINE EhiNG n.. . ..n. , w NuCu AR [ NGING RING AND HE ALTH PHYGiCG PROGRAMS ENGINE.EMING SCIENCE AND ME CHANICS Hullo 1NG GEORGLA INGT OF TECHNOLOGY ATL ANTA GEORGIA 30332 U S A Date  : March 12, 1990 R. Karam, Director, NNRC To  : Dr.

From  : B. Kahn, Nuclear Safeguards Committee f. J.e '

k Subject  : FY 1990 Audit of Procedures I selected, at random, two procedures to audit in Section 9, Health Physics Operations. Those selected were numbers 9037 and 9040. For this purpose I reviewed for each procedure the data entry sheets collected in a loose-leaf binder for the calendar year 1989, and compared the entries with the instructions in the procedure.

Both sets of data entries were, on the whole, recorded correctly and in accord with instructions, according to my observations. The following minor problems were found in the procedures and the data sheets.

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\m\karam2. mar Telephone 404 894 3720 Tesex: 5425o7 GTRIOCAATL F ax: 404 894 3120 (verb 404-H94-0951 )

l AN EQUAL EDUCATION ANO EMPLOYMENT OrV43ATUNITY INSTITUTION l

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A. Procedure 9037, Rev.00, dated 04/28/89 Tritium Determination in Urine

1. a. The procedure, in step 5.2.2.1, intends to refer to Appendix A, but the A is missing,
b. The space in Appendix A that shows " Final pH" should say " Initial pH".
c. In step 6.0, the procedure should refer to recording results in the sample log, Procedure 9038.
d. Appendix A should have line for the sample ID, and Appendix B should have a column for this purpose.
2. The summary record of results in the Procedure 9038 sample log should have consistent values with regard to precision (not a mix of 0.00, 0.1 0.714, 0.66, etc.).
3. The " Reviewed by" signature and date are missing in Appendix A for #15-19 and in Appendix B for #15-19 and
  1. 39-49.

B. Procedure 9040, revision 02, dated 10/21/88 Liquid Waste Tank Analysis.

1. The procedure, in step 7.0, should refer to the data sheet and authorization record.
2. The gamma-ray data have "less-than" signs missing for samples 89-02 and 89-09.

l GEORGIA INSTITUTE OF TECHNOLOGY '.="> \ .

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. A Unit of the Uruversity System of Georgia 5 . ,4 PLANT OPERATIONS DIVISION W' 915 Atlantic Drive, N.W. - Atlanta, Georgia 30318 404 - 894- 4035 February 14, 1990 lEIXXW D.M TO: Ratib Karam Director, Nuclear Research FROM: G. Les Petherick , [ ' ' #'~

Manager, Environmental Safety SUl3 JECT : Neeley Nuclear Research Center Audit I conducted an audit of Procedures numbered 9252 - 9400 on February !4, 1990. An in-depih review was conducted on the following Procedures: 9252, 9305, and 9306. No discrepancies were found in Procedures 9304 or 9306; however, Procedure 9252 needs to be revised.

it is r e c onmen d ed that Procedure 9?52, Stack Flow Test, be revised. The present procedure does not list the reason for the stack flow test, the type of instrumentation required for the test, any tech spec on the instrumentation such as required colibration eic., how many measurements wilI be taken inside the stock, the location of these measurements and if an average of the measurements be done and the average measurement be used as proper flow test rate required by the form, if there are any questions concerning this audit please feel free to conioct me at 894-4636.

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(404) 894 7452 (Fax) A Und of me un ersdv System of Georgia 29 March 1990 T0: Dr. Berndt Kahn, Chairman Nuclear Safeguards Committee From: Henry M. Neumann 2,4 2 2 wcL > n '

Subject:

Audit of records related to 4000 series procedures.

I have completed an audit of the procedures and records named above. Some procedures have been revised recently, while others heve been in effect for several years. The approval date for procedures are given below. I examined selected records, and below are comments resulting from the examination.

Procedures 4000, 4001, 4002 ( 22 March 1990)

These procedures, related to pressure test of the containment building, are very new. I did not examine records related to these.

Procedure 4005 (12 October 1966)

This procedure is related to changing filters in the reactor ventilation system. There is no specified time interval for these changes. Records, which go back to 1979, were found under " Filter Banks". The last recorded change was 6/3/88. Is this correct?

Procedure 4010 ( 6 May 1974)

This procedure describes removal of the bismuth block. There are no related records.

Procedure 4050 (6 May 1974)

This procedure relates to deuterization of the ion resin bed. The only requirement for record keeping related to this procedure is that entries should be made in the D2 0 Inventory Log when the procedure is performed.

l The records labeled "D,30 Inventory" are concerned with procedure 3500, which is to be performed quarterly. My conclusion from these records, l which go back to 11/8/85 is that procedure 4050 has not been performed l since that date. Is that correct?

Procedure 4051 (30 January 1986) l -This procedure describes the recovery of D2 0 from the ion resin bed.

There are no related records.

Procedure 4060 (10 February 1972)

This procedure describes measurement of the top reflector dump time.

The procedure must be performed four times per year at approximately 90 day intervals. A handwritten comment on the first page of the procedure says "Not a valid procedure". The measurement is now done as part of the Weekly Reactor chutdown Checklist (Procedure 2006). The latter records for 1989 were examined. Measurements were made much more frequently than the stated requirement.

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School of Chemistry Georgia Institute of Technology nTECH (404: 894 4002 (Tel.)

(404 894 7452 (Fax, Atlanta, Georgia 30332 A Unst of the University Symm of Georgia Procedure 4100 (6 May 1974)

This procedure relates to the hydrostatic test of the primary system using H2 0. I did not examine records related to this.

Procedure 4150 (30 June 1989)

This procedure related to maintenance, inspection, and testing of cranes.

Procedure is to be performed annually. Records indicate maintenance of the hot cell crane in 1987,1988, and 1989, and maintenance of the containment crane in 1986,1988, and 1989.

Procedure 4200 (28 April 1989)

This procedure relates to changes in GTRR design. I did not examine records related to this.

Procedure 4400 (30 October 1987)

This procedure relates to D,3 analysis in reactor cover gas, and is to be performed annually. The records for this analysis were contained in a folder incorrectly labeled "0 07 concentration analysis". The record for 1987 is only a strip of recorcer chart, with no date. The records, including a strip of recorder chart, for 1988 and 1989 are satisfactory.

Procedure 4950 (30 December 1988)

This procedure relates to tagging equipment out of service. I did not examine records related to this.

cc: Dr. R. Karam i

i an EquM Ed nat+n aad E ~rsoym-nt Oppoou rutyi _' etcon

Schoot of chomey Georgia Institute of Technology Acanta. Georgia 30332 TEL (404) 894 4002 TECH A UN W Re Unimuy Sysw M inga FAK (404) 894 7452 13 April 1990

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' Audit of records created by 3000 series procedures (Auxiliary Systems)

Performed by E. Kent Harefield 'hy p 4f]

6 April 1990 After reviewing the procedures that required logs to be kept, logs for procedures 3107 (llandling Samples irradiate in the GTillt), 3600 (Special Nuclear Materials inventory) and 3800 (Liquid Waste Disposal) were examined.

Proccdure 3107. Thirty eight irradiation experiments were logged for 1989. Log entries for experiments 8,18 and 34 were examined in detail. All forms were completed and approved as required by the procedure.

Procedure 3600. The inventories done in 1989 were based on the original procedure approved 5/6/74. This procedure called for inventories in January and July. The actual inventories were done in May and October, which was the schedule that has been followed for several years. The procedure revision dated 12/8/89 calls for inventory at six month intervals. Burn-up calculations were in place for the last inventmy.

Procedure 3800. Twenty discharges of water were made in 1989, all apparently from the Suspect Waste Tank. Forms 3800-01 and 3800-02 were properly executed and filed with the authorization sheet for each discharge. Pumping times were kept within the required 24 h clapsed time in each case.

Although unrelated to the audit itself, it should be noted that several discrepancies were found in the names of the procedures given in the Procedure Index and what is actually given on the procedure itself. Also one procedure, found in the notebook, number 3200,is not even listed in the Procedure Index. All of these things should be corrected and perhaps the entire Procedure Index should be checked against the procedures in the notebook.

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1 MEMORANDUM TO: DR. R. A. KARAM FROM: BILLY STATHAM /hb DATE: 3/16/90

SUBJECT:

IFI 50-160/87-01-10 FROM NRC The open item IFI 50-160/87-01-10 states " Verify that instrument calibrations necessary for operability of safety equipment list in TS Table 4.1 are performed."

Listed below are the Reactor and Safety Systems included in TS Table 4.1 and the procedure for testing each

1. Power trip (proc 7270)
2. Period trip (proc 7272)
3. Start up channel (proc 7273)
4. Logic and magnet amplifier channel (proc 7271) 5 Pico ammeter channels (proc 7274)
6. Reactor D 0 level channels 2 (proc 7241)
7. D 0 temperature channels 2 (proc 7291)
8. D 0 flow rate channels 2 (proc 7292)

Listed below are 4 calibrated instruments:

1. HP Multimeter Model 3468A s/n 2237A15867
2. Keithley Picoammotor Sourco Model 261 s/n 71987
3. HP Universal Counter Model 5314A s/n 2714A15245
4. Oscilloscope (on order, to include calibration)

Every signal necessary for test and calibration of the Safety Systems listed in TS Table 4.1 can be measured or supplied from calibrated instruments listed above.

instrument in listed below:

The function (s) of each

1. Multimeter to measure voltage and resistance
2. Picoammeter Source to supply current
3. Universal Counter to measure frequency
4. Oscilloscope to observe /moasure waveforms The guidelines of procedure 7900 are followed in the calibration of test instruments. Of the procedures referred to in this memo, only 7900, 7241, 7270 and 7271 are NSC approved. Proce and 7292 are in the process of being written and gTTilldures 7291 complete d by 5/1/90; this does not include NSC approval.

I think this item should oe closed on the follow up inspection.

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MEMORANDUM TO: DR. R. A. KARAM FROM: BILLY STATHAM DATE: 4/09/90

SUBJECT:

Reactor controls and instrumentation calibration This is a follow up on our recent discussion about the frequency of the reactor instrumentation calibration.

Listed below are the Reactor and Safety Systems included in TS Table 4.1 which must be calibrated on a 6 month cycle:

1. Power trip (Flux Amps) (proc 7270)
2. Period trip (LogN Per, & recorder) (proc 7272)
3. Start up channel (proc 7273)
4. Logic and magnet amplifier channel (proc 7271) 5 Pico ammeter channels (proc 7274)
6. Reactor D 2 O level channels (proc 7241)
7. D O temperature channels 2

(proc 7276)

8. D 0 flow rate channels 2

(proc 7277)

The remaining instrumentation could be calibrated on a 12 month cycle since there is no Tech Spec requirements for this calibration. In the past, there has been no distinction made between what is included in 4.1 and what isn't. Listed below are the devices that could be put on a 12 month cycle:

1. Area Monitor Recorder (could be part of ARM system calibration) (proc 7275)
2. Kanne Recorder (could be part of Kanne system calibration)

(proc 7279)

3. MAP-1 Recorder (could be part of MAP-1 sys. cal.) (proc 7280)
4. Gas Recorder (could be part of Gas Mon. sys. cal. ) (proc 7275)
5. Temperature Recorders TR-1 & TR-2 (proc 7281)
6. Temperature Recorder Secondary coolant (TRA-H1) (proc 7276)
7. Water Recorder (could be part of GWGM sys cal) (proc 7275)

NOTE: The procedures in this paragraph (7275 thru 7281) are in draft form and do not have NSGC approval.

There are 2 components from TS Table 4.1 that may need a procedure for calibration (calibration may not be correct term since trip point is the only test that can be mado). Listed below are the 2 components:

1. 2nd D20 temperature trip (thermocouple trip device)
2. 2nd D20 flow trip (diff. press. xmtr.)

The auto controller has no calibration procedure. This is on the things to do list (not included in TS Table 4.1).

Listed below are 4 calibrated (with traceablity to RIST) test instruments:

.-. . . = . . . .- .

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1. HP Multimeter Model 3468A s/n 2237A15867
2. Keithley Picoammeter Source Model 261 s/n 71987
3. HP Universal Counter Model 5314A s/n 2714A15245
4. Oscilloscope (on order, to include calibration)

The HP 5216A Electronic Counter (a/n 748-01239) has been calibrated using the HP Universal Counter listed above.

We need a policy decision on the frequency of calibration of the instruments not included in TS Table 4.1 before finalization of procedures 7275 thru 7281.

Information included in this memo can also serve as a summary of where we are on calibration procedures for the Reactor instrumentation systems.

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NEELY NUCLEAR RESEARCH CENTER eco ATLANTIC ORIVE

[ ATLANTA GEORGIA 30332-0425 March 27, 1990 TO: Dr. R. A. Karam [

S. I. Abdel-Khalik FROM:

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SUBJECT:

Audit of 8000 Series Procedure I have reviewed the above reference procedures. Thero were no records related to these procedures which needed to be examined.

I recommend that they be removed from the procedures manuel and placed in a " Systems Description" manual.

Thank you.

Te en . 542507 GTRIOCAATL F an. 404 804 3120 (Venty 404 894 6951)

A Umt of t"e tJruven System of Gwg a An Equa Educanon and Ernmoyment Ooportunity Institution

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4

- APPENDIX A

SUMMARY

OF NRC OPFft ITEMS

-item Status

1. VIO 87-01-01 Ready for NRC review.

Utilize Procedure

2. V10'87-01-00 Ready for llRC review.

Control Experiments

3. 'UNR 87-01-10 Remains open to determine all Instrument Calibrations bench test instruments identified.
4. IFI 88-02-13 Remains open to evaluate test Reactor Coolant Flow results.
5. VIO 89-02-01 Ready for NRC review.

Containment Test

6. VIO 89-02-02 Ready for NRC review.

Shim 81ades

7. IFl 89-03-01 Procedure needs additional review Radicactive Material by NNRC.
8. Exercise Weakness 89-04-01 Confidential scenario will be used Fully Testing Emergency Plan for next exercise. Ready for NRC review.
9. IFI 89-04-02 Ready for NRC review.

Radio Transn.ission

10. IFI 89-04-03 This will be tested during next Test Off-site Components exercise. Ready for NRC review,
11. IFI 89-04-04 Ready for NRC review.

Emergency Plan Training 12; IFI 89-04-05 Ready for NRC review.

Required Notification 13.- IFI 90-01-01 Remins open to make a technical s

Stack Grab Sample change.

A-1 1

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l APpfMDIX R ,

STATtIS OF NRC OPfN ITEMS

1. .V10 87-01-01. Failure to provide or utilize procedures.

Status A letter response by NNRC was made on July 15, 1987 to the NRC.

While not all corrective action was completed, all estimates of action completion were in 1987. This violation is ready for NRC review.

2. V10 87-01-02. Failure to control experiments por Te hnical Specifications.

Status Same as V10 S7-01-01 stated above.

3. UNR 87-01-10. Verify that instrument calibrations necessary for

'perability of safety equipment listed in Technical Specifications TwSle 4.1 are performed.

Status The NRC-reviewed status of the unresolved item during a NRC inspection which was reported in Inspection Report 89-02 on November 11, 1989. The following statement was made by the NRC:

"The licensee has records of calibrations of four instruments used in calibrating the instrumentation listed in Table 4.1.

Those instruments are:

"HP Multimeter, SN 2237A15867, Model 3468A; Keithley Picoampere-Source, SN261, Model 261; HP Universal Counter, SN 2714A15245, Model 5314A; and HP VTVM, SN316-09663, Model 412A.

"All have current calibrations against NBS standards.

However, it was not determined that these are the only bench test instruments used in the calibration of the Table 4.1 equipment. Hence, this item remains open."

4. IFl 88-02-13. Develop and -implement reactor coolant flow g calibration procedure.

The following is quoted from NRC Inspection Report 88-02:

I

" Surveillance procedure 2015, Reactor Power Calibration, is L

required to be performed weekly when at 1 MW or higher power.

B-1

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"The measurement is performed by-considering the heat removed by

. the primary coolant-(02 0) flow and the light water coolant flow

. through the shield. (The latter appears to a negligible heat sink during 1 MW operation.) The primary coolant flow detector, a turbine vane flow meter, has not been calibrated since it lef t the factory and does not appear to be susceptible to on site calibration. Hence, the accuracy of the power calibration, which is proportional to the product of flow times coolant temperature rise, is indeterminable as currently performed. _

"In the secondary coolant system, there is a calibrated flow orifice plate and the dP cell across the plate has been calibrated against a standard water gauge on occasion. The licensee has neither a procedure nor a schedule for this calibration.

"In order to justify a power calibration based on primary flow, that flow must be calibrated. That calibration can be accomplished by performing simultaneous heat balances on the secondary and primary sides, equating them, and solving for primary flow. The prerequisites 'to this measurement include calibration of the dP cell in the secondary flow system and calibration of the RTDs and thermocouples used in the temperature measurements. This flow and power calibration should be performed before exceeding 1 MW and at 1 MW increments as power is increased to the license limit of 5 MW.

Appropriate procedures and schedules for the calibration of flow and temperature measuring devices must be established by the licensee. The licensee committed at the exit to develop the appropriate procedures and implement them prior to exceeding 1 MU.

(IFI: 50-160/88-02-13)."

Status The-secondary coolant system calibrated flow orifice plate (venturi) has not been calibrated since original calibration. The venturi was inspected and found to be clean and useful for the establishment of secondary coolant flow. Heat balance tests have been made at IMW, 2MW, 3MW and 4MW. Test data and results are being evaluated.

.5 . VIO 89-02-01. Failure to perform the containment building leak-rate test in accordance with commitments.

Status imRC has reported the following status to the !!RC:

" Procedure 4000, Containment Building Pressure Test, was deficient-in that the procedure did not provide adequate guidance to the operator in the area of data handling and treatment.

B-2

" Procedure 4000 has been revised and is currently being reviewed against Standard ANS 7.60 and other requirements.

"It is anticipated-that an adequate procedure which meets the requirements of ANS 7.60 will, when completed, ensure that further violations in this area do not occur.

" Full compliance will be achieved as of March 31, 1990."

Procedure 4000 was revised and procedures 4001 and.4002 uritten to correct deficiencies. The Nuclear Safeguard Committee reviewed and approvec procedures 4000, 4001, and 4002 on fiarch 22, 1990.

6. V10 89-02-02. Procedures did not assure that any shim blcde not fully inserted was withdrawn sufficiently to cause a negative rate trip when released into the core, as required by Technical Specification 3.1.d - paragraph 5.

Status IE C has reported the following to the NRC:

"The Staff of the Neely Nuclear Research Center has been involved in upgrading operating procedures on many fronts:

Health Physics, Operations, Emergency Response, Environmental, Security, etc. Consequently, the procedure to assure that shim safety blades were always withdrawn to at least 5 degrees was overlooked.

" Procedure 7247 has been drafted to cover this area and is currently undergoing review.

"The corrective action directed toward development of an adequate procedure which implements Technical Specification requirements will, when completed, ensure that further violations in this. area will not occur.

" Full compliance will be achieved as of March 31, 1990."

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l The Nuclear Safeguard Committee has approved Procedure 7247.

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' 7. IFI 89-03-01. Follow up the development cf a procedure for the

-shipment of radioactive material.

Status The NRC reviewed status of the inspector follow up item during.a NRC inspection which was reported in Inspection Report 90-01 on February 5, 1990. The following statement was made by the NRC.

L B-3

"The inspector verified that a draft procedure has been written for handling radioactive waste and completing radioactive material shipment. The licensee indicated however, that the procedure still needs to be revised before being submitted to the NSC for review and approval."

The procedure has not been revised additional.

8. Exercise Weakness 89-04-01. Failure to conduct the annual emergency drill in a manne. that would fully test implementation of the Emergency Plan. 4 Status This weakness involved the NRC inspectors comment that the drill scenario should not be developed by a drill participant and that drill exercise players should not have advance knowledge of the scenario _ details. NNRC committed to ensure that exercises are conducted using a confidential scenario for fully testing the entire emergency organization. This will be demonstrated at the next emergency exercise.
9. IFI 89-04-02. Conduct an evaluation of radio transmission over the entire EPZ to identify areas of impeded transmission.

Status A brief loss of communications between the Emergency Director and Health Physics personnel was caused by a communications dead spot in the vicinity of the storage pool. A radio test has been conducted over the entire EPZ. Action is completed.

10. IFl 89-04-03. Verify that the full-scale exercise conducted on a biennial basis, included an accident scenario that will test all on-site and off-site components of the emergency organization.

Status This item resulted from the simulated emergency event which_was not a classifiable event that warranted off-site notifications to State, -local and federal authorities. Drills are expected to conduct such notifications every two years. This will be tested _at L the next emergency exercise.

11. IFI 89-04-04. Proceduralize the emergency response training l_

pranram to ensure documented compliance with Section 10.1 of the Eccogency Plan.

Status A procedure has been written and approved to describe the emergency i

response training programs. The IFI is ready for NRC review.

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12. lf! 89-04-05, Review Procedure 6100 (Emergency Notification) to

_ ensure that all required notifications are included and made in a timely manner, Status Procedure 6100 has been reviewed and revised to ensure thatitem This all is required notifications are included in the procedure.

ready for NRC review.

13. Ifl 90-01-01. Follow the revisicr. of Procedure 9017, Stack Grab Sample Analysis, Rev. 2, of October 14, 1988.

Status The NRC reviewed status of the inspector follow-up item during a NRC inspection. The following statement was made by the NRC in the Inspection Report:

"lFI 88-02-08, Stack Grab Sampling, was established due to the potential occupational hazards associated with climbing the exhaust stack while carrying sampling equipment. The licensee agreed to evaluate the stack sampling method and consider another possible method for obtaining the sample.

"The inspector discussed the sampling process with licensee representatives including-those who actually climb the stack to obtain the sample. Although management and workers _ alike felt that climbing the stack posed only a limited safety hazard, the licensee has decided to change the method used to sample the air _from the exhaust stack. This IFI (88-02-08) will be closed but another The NRC established to follow and review the revised procedure.

will track revision of Procedure 9017, Stack Grab Sample Analysis, Rev. 2, dated October 14, 1988, as an IFI (50-160/90-01-01)."

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l MEMORANDUM TO: DR. R. A. KARAM FROM: BILLY STATHAM DATE: 6/8/90 (UPDATE OF MEMO WRITTEN ON 3/16/90)

SUBJECT:

IFI 50-160/87-01-10 FROM NRC The open itam IFI 50-160/87-01-10 states " Verify that instrument calibrations necessary for operability of safety equipment list in TS Table 4.1 are performed.

Listed below are the Reactor and Safety Systems included in TS Table 4.1 and the procedure for testing each:

1. Power trip - (proc 7270)
2. Period trip (proc 7272)
3. Start up channel (proc 7273)
4. Logic and magnet amplifier channel (proc 7271) 5 Pico ammeter channels (proc 7274)
6. Reactor D,0 level channels (proc 7241)
7. D,0 temperature channels (proc 7276)
8. D2 O flow rate channels (proc 7277)

Listed below are 4 calibrated instruments:

1. HP Multimeter Model 3468A s/n 2237A15867
2. Keithley Picoammeter Source Model 261 s/n 71987
3. HP Universal Counter Model 5314A s/n 2714A15245
4. Tektronix Model 2225 Oscilloscope s/n E226957 Every signal necessary for test and calibration of the Safety Systems listed in TS Table 4.1 can be measured or supplied from calibrated instruments listed above.

instrument is listed below:

The function (s) of each 1.- Multimeter to measure voltage and resistance

2. Picoammeter Source to supply current
3. Universal Counter to measure frequency
4. Oscilloscope to observe / measure waveforms The guidelines of procedure 7900 are followed in the calibration of test instruments.

-I think this item should be closed on the follow up inspection.

4 Attachment D I

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AUDIT ASSIGNMENTS FOR NSC MEMBER _S Reports due by 3/31/90 Audit records created by procedures 2000 series: Dr. J. Mahaffey Audit records created by procedures 3000 series: Dr. K. Barefield Audit records created by procedures 4000 series: Dr. H. Neumann Audit records created by procedures 6000 series and security plan and procedures: Mr. J. Vickory Audit records created by procedures 7000 series: Dr. P. Desai Audit records created by procedures 8000 series: Dr. S. Abdel-Khalik Audit records created by procedures 9000 series: Dr. B. Kahn Dr. N. Gordon Dr. B. Livesay Mr. L Potherick Audit actions taken to correct IFI's:

Mr. E. Cobb NNRC RESPONSE TO NUCLEAR SAFEGUARD COMMITTEE AUDIT OF 1989 ACTIVITIES Jim Mahaffev - 2000 Series Procedures

1. Weekly Precritical Startup and Shutdown Checklists OBSERVATIONS - Several recording errors were identified on the weekly startup/ shutdown checklists.

RESPONSE - These mistakes were made by opera *. ors, and in several instances, check marks were ei. cered

. on the checklists instead of values for the flux amp trip set points. It appears that the operators are automatically completing the check list without using the procedure to verify that the checklist has been completed correctly. The corrective action that has been taken is that the operators have been sensitized to pay closer attention to the checklistr when completing and the importance generally of attention to detail.

K. Barcfield - 3000 Series Procedures OBSERVATION - The were discrepancies between the actual names of procedures and .the names listed in the Index, and other procedures were not listed at all.

RESPONSE - In April, 1990, a comparison was made between the Index and the procedures that are considered to be the official records for the facility. A new inden was compiled and issued on April 19, 1990.

Ilenry M. Neumann - 4000 Series Procedures OBSERVATION - Procedure 4005 is related to changing filters in the reactor ventilation system. There is not specified time interval for these changes. The last recorded change was 6/3/88. Is this correct?

i i RESPONSE - Yes. Filter changes are not performed on a set frequency but is dependent upon the pressure drop across the filter. The pressure drops are checked on the Daily Precritical Startup Checklist (Procedure 2003) and the values recorded on the Operating Data Log - Field (Procedure 2011). A pressure drop of > 4 inches of water across either the total filter bank or the absolute filter is the point where change is required.

OBSERVATION - Procedure 4050 relates to deuterization of the ion resin bed and requires that entries be made in the D0 Inventory Log when the procedure is performed. It appears

l. that 11/8/85 is the last time this procedure has been performed.- Is this correct?

RESPONSE - This is correct.

OBSERVATION - Procedure 4051 describes the recover of D 0 f rom 2 the ion resin bed. There are no related records.

l RESPONSE - The D 0 Inventory Log will contain an entry 2

f or the recovered D,0.

OBSERVATION - Procedure 4060 describes measurement of the top reflector dump time with required quarterly performance. The measurement is now done as part of the weekly shutdown checklist (Procedure 2006). These records were examined and found that the frequency of performance exceedad the required performance.

RESPONSE - Procedure 4060 needs to be deleted. This will be brought before the NSC in the near future.

Jack Vickery - 6000 Series Proceduren and Security Plan

1. Security Relat.ed Observations OBSERVATION - Inventories of keys and magnetic cards are in process of being transferred to forms SEC-005 and SEC-006 as required by procedure.

RESPONSE - Inventories of keys have been completed as required by procedure. Work is progressing on the magnetic card inventory and it is anticipated that it will be completed by September 1, 1990 OBSERVATION - No record of test of emergency power generator located.

RESPONSE - Procedure 0003 was approved on 12/8/89 and the work it covers is performed on a quarterly schedule. In the NNRC files are records covering two performances of the procedure. The folder containing these records is entitled " Power Generator Test."

OBSERVATION - No records have been generated as a result of implementation of Procedures 6010, 6020, 6030, 6040, 6050, 6060, 6070, 6090, and 6100.

RESPONSE -

These are the emergency preparedness procedures, and, fortunately, since we have not had any emergencies no records have been created.

OBSERVATION - Procedure 6080, Accidental Release of High Levels of Gaseous Activity to the Atmosphere, has not yet been written.

l

, . 1 RESPONSE -

That is correct. Discussions are currently underway to determine whether this procedure should be deleted from consideration or 1 whether it should be written. -In either case, the decision should be made with the 1990 Calendar year. l OBSERVATION -

Procedure 6090, Appendix A lists NNRC personnel. This list was out of date in the manual, however, an up-to-date list was on file. Recommendation:

Consider removing the list of personnel from the procedure since it is subject to change, but maintain it in a separate file.

RESPONSE -

The NNRC concurs with the above recommendation and will implement said recommendation by 9/30/90.

Prateen V. Desai - 7000 Series Procedures OBSERVATION -

Procedure 7241 and 7420 were evaluated for compliance. No discrepancies between requirements and practice were identified.

RESPONSE - No response required.

S. I. Abdel-Khalik - 8000 Series Procedures OBSERVATION -

There are no records related to these procedures. It is recommended that these " procedures" be L removed from the procedures manual and placed in a " systems description" manual.

RESPONSE -

It is agreed that the documents in this section do not constitute true procedures. A Systems Description Manual shall be created, and the Nuclear Safeguards Committee will be asked to approve the removal of the 8000 series documents to this new manual at the Committee meeting on June 28, 1990 .

31 Nicholas Gordon -

9000 Series Procedures I

l 1. Calibration of Pocket Ionization Chambers (PIC)

-OBSERVATION - It was found that three PICS were calibrated several days past the six month calibration l

. period.

RESPONSE -

This observation does not constitute a program deficiency because Technical Specifications.

1 1

1

4

, . e- ,

e

. Section 1.27 permits adjusting of the calibration interval to plus or minus 25% of the normal interval provided that the next calibration interval begins at the end of the original specified interval.

Although at the NNRC we try not to invoke this modifier, it is available for use in these circumstances.

2. Bioassay Program OBSERVATION - Employees were bioassay annually and upon termination of employment for tritium. Gamma isotopic analyses was performed only in special cases.

RESPONSE - The intent of paragraph 5.2.3 of Procedure 9038 was to indicate the laboratory capability at the NNRC, i. e., tritium and gamma analysis. It was not meant that everyone at the NNRC would routinely receive both types of analyses.

Procedure 9038, Step 5.2.3 will be modified to read as follows:

"The primary analyses that can be performed are tritium analysis and gamma isotopic analysis.

Each person shall receive the analysis appropriate to their exposure potential."

B. Kahn - 9000 Serien Procedures

1. Procedure 9037, 4/28/89, Tritium Determination in Urine OBSERVATION - Step 5.2.2.1 intends to refer to Appendix A but the A is missing.

RESPONSE - The Procedure will be modified to add the missing A.

OBSERVATION __ - The space in Appendix A that shows " Final pH" should say " Initial pH."

RESPONSE - The NNRC staff does not agree. The intent of this blank on the tritium bioassay form was to ensure that the pH was neutral when the distillation occurred. The actual pH of the initial urine sample not wanted or needed.

OBSERVATION - In step 6.0 the procedure should refer to recording results in the sample log, Procedure 9038.

RESPONSE - There is no requirement in Procedure 9038 or Procedure 9037 to record bioassay results in the sample log but rather that the results of the

e e

analyses be documented on the Bloassay Analysis Data Sheet, Appendix A. This is the same sheet that forms Appendix A of Procedure 9037 which is usou for documented the results of tritium analysis. A bicassay log is maintained simply to have a compilation of all bioassay- performed at one location.

OBSERVATION -

Appendix A should have a line for the sample ID and Appendix B should have a column for this purpose.

RESPONSE - A line has been added to the Appendix A, Procedure 9037 for sample ID. In the approved version of Appendix B sample Log, a sample ID space is already provided.

OBSERVATION -

The summary record of results in the Procedure 9038 sample log should have consistent values with regard to precision.

RESPONSE - The technician staff have been requested to limit the calculation to one decimal place.

OBSERVATION - The " Reviewed by" signature and date are missing in Appendix A for #15-19 and Appendix B for 15-19 and 39-49.

RESPONSE - These records were reviewed and signed.

The remainder of the bioassay records were also reviewed to ensure that appropriate signatures had been obtained.

2. Procedure 9040, Rev. 2, 10/21/88, Liquid Waste Tank Analysis OBSERVATION - The procedure, in step 7.0, should refer to the data sheet and authorization record.

RESPONSE - Step 7 of Procedure 9040 does not

, specifically mention the data sheet and l authorization record; however, it does specify the j fate of any record created by implementation of the procedure. This wording was approved by the

. Nuclear Safeguard Committee and has been adequate l

to ensure that all of the necessa 7 ard appropriate l records are maintained.

j OBSEPVATION - The Gamma-ray data have "less than" signs l missing for samples 89.-02 and 89-09.

RESPONSE - A review of the paperwork for waste release #89-02 and #89-09 shtws that for those two cases, the gamma-ray spectroscopy results did not 1

i

,' ,N.

. give "less than" values. The values stated appear to be correct as positive numbers.

l l

l L. Petherick - 9000 Series Procedures

1. Procedure 9252 OBSERVATION - Procedure 9252 needs revision.

RESPONSE - Procedure 9252 has been revised and was approved by the Nuclear Safeguards Committee at the April, 1990 meeting.

E. P. Cobb - IPI Review, The status of the IFI's as identified by PJ . Cobb are essentially correct and are appended to this document. Item 3, the unresolved item, has been resched and the test equipment that will be maintained NIST traceable have been identified. This list is also attached to this document in the form of a memo from Billy Statham to Dr. R. A. Karam, dated 6/8/90. The NRC has reviewed this list (USNRC operations inspector currently onsite as this meeting is taking place), but it is not yet known whether this will be considered adequate to resolve the item.

Item #4 Status -

Power calibration - Test evaluation have indicated some discrepancier between primary and secondary flow indAcating a need for directly measurement of flow in the primary.

NNRC management has learned that ultrasound flow detectors are now available commercially. Unfortunately, they are prohibitively expensive. Consequently, the NNRC is investigating whether it might be possible to rent such equipment for a specified time

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