ML20106B890

Rept on Receipt of 8,049 Ci of Sealed Sources of Co-60 at Washington State Univ on 880929

ML20106B890
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Site:	Washington State University
Issue date:	11/04/1988
From:	Srinivasan B WASHINGTON STATE UNIV., PULLMAN, WA
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ML20106B885	List: ML20106B890
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4 REPORT ON THE RECEIPT OF 8049 CURIES OF SEALED SOURCES OF 60C0 AT WASHINGTON-STATE UNIVERSITY ON SEPTEMBER 29, 1988 by B. Srinivasan (Report Completed Nov, 4, 1988)

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8 I TABLE OF CONTDr."S INTRODUCTION 2 RADIATION SAFETY CONSIDERATIONS 4 ARRIVAL OF SOURCES 4 RADIATION SURVEY OF THE SHIPMENT 5 OBJECTIONS BY-THE RADIATION SAFETY OFFICE STAFF 6 REMOVAL OF THE INNER LEAD CASK 7 REMOVAL OF THE SOURCES 8 RADIATION DOSE EQUIVALENT ESTIMATES 9 BUILDING RADIATION SURVEY AND POOL WATER ?SALYSES 10 EPILOGUE , 10

SUMMARY

11 CONCLUSIONS 12 APPENDICES 14 A. Communication Between WSU and Donors B. Plan for Receiving the Shipment C. Letter to DSHS from RSO D. Shipping Papers E. Leak Test Results F. Radiation Survey'of Incoming and Outgoing Shipment G. Building Radiation Survey H. Pool Water Analysis I. Letter to DSHS from David Barbee

Co-60 Report November 4, 1988 Page 2 INTRODUCTION A 60Co gamma irradiation facility is situated at the Nuclear Radiation enter (NRC) and is mainly used for research in biological sciences. In 1969, the 60C o content of the irradiator was at a maximum of 17,500 Curies. In the 20 years period, the source had decayed to 1200 Curies with concomitant reduction in the gamma dose rate. Since the researchers require higher dose rate than what was available from the 1200 Curie source, it became necessary to add fresh 60Co to the existing facility.

Mr. Marshall Scott of the NRC was able to obtain a donation of 27 individual sealed sources of 60Co from Northrop Corporation and J.L. Shepherd and Associates with a combined source strength of 8049 Curies. One single source among the 27 contained 5000 Curies of 60Co. It was planned to use this largest source to augment the 60Co contenc of the irradiator. Other 26 sources would be kept in storage for future use.

The irradiator is at the south east end bottom of the nuclear reactor pool. The nuclear reactor is operated under a license agreement with the Nuclear Regulatory commission.

However, the sources in the samma irradiator are listed under the WSU radioactive materials license from tae State of Washington. Thus the donated sources would be governed by the regulations of the State license, but physically situated in the nuclear reactor pool. Both the Radiation Safety Office (RSO) and the Nuclear Radiation Center are held jointly responsible for the operation of the samma irradiator and for any improvement on the irradiator.

Since July 1988, Mr. Scott had been in correspondence with Dr. Gary Serio of Northrup Corporation to arrange for the shipment of the donated sourcet from the General Electric Company in Pleasanton, California to WSU. Copies-of letters exchanged between Mr. Scott and the donors were given to the RSO earlier by Mr. Scott.

Mr. Marshall Scott had prepared a written plan for the receipt of the sources at WSU and submitted it to the Radiation Safety Office on September 14, 1988.

On September 19, 1988, I returned to Pullman to assume the position as Director of the Radiation Safety Office. On September 22 and 23 I was informed for the first time about the imminent shipment of the 60Co sources from California which was to arrive early the following week. Mr. Scott described to me the details about the shipment and the

Co-60 Report November 4, 1988 Page 3 planned procedures for unloading and storing the sources under water in the nuclear reactor pool. Furthermore, he showed me the special long tools which he was fabricating to lift the innermost container of the sources, under water. A summary of the infomation which vere gathered by me from conversations with Mr. Scott is given below.

1. The 27 individual sealed sources would be leak tested at the hot cell facilities of the General Electric Company in Pleasanton, California.

1. After successful leak tests, they would be placed inside 3 lead cask. About 6000 lbs of lead, would be used to provide adequate shielding from the samma rays.

3. The lead cask would then be placed in a lead lined steel container (outer pack).

4. The container classified as a type B package would be transported as an exclusive shipment on an open bed truck, with proper placards.

5. The truck upon arrival here will be backed into the pool room. Mr. Scott had made a request to the shippers that the package be. placed at the rear end of the truck (over the wheels for stability), so that the overhead cranes at the NRC pool rocm could be used to lift the lead cask and lower into the nuclear reactor pool.

6. After completing the essential surveys for the acceptance of the package, the lead cask would be lifted and placed under water as described in item 5_above.

7. Long tools would be used to remove the sources from the lead cask. -

8. The sources would then be laterally moved towards the center of the pool and placed on the floor (under water) closer to the south wall.

9. The empty lead cask would then be lifted out of the pool, cleaned, dried, swipe tested, placed. inside the steel container and returned to California.

10. Nuclear reactor pool water, would bz analyzed, before and after emplacement of the new sources to demonstrate that the sources were not leaking.

Co-60 Roport November 4, 1988 Page 4 RADIATION SAFETY CONSIDERATIONS .

On September 26, 1988 I informed (by telephone) Mr.

Robert Verellen of the Department of Social and Health Services (DSHS) in Olympia, about ths imminent shipment. I sent a letter to him the following day, with a copy forwarded to Dr. Tom Okita, Chairman of the Rad'stion Safety Cormittee.

Calculations made by me showed that the water in the reactor pool, the concrete walls of the pool and the unexcavated earth surrounding the wall would provide adequate shielding, from the gamma rays cf 8049 Curies of 60Co. in all occupied areas of the building. Even in the cave room, in the basement of the building, which is shielded by water and concrete only, the shielding was found to be adequate; note that the cave room, is used only sporadically- not more than a few hours per month. Actu-l radiation measurements completed after emplacement of the sources verified the above conclusions to be correct.

I asked that t'.e work crew for the unloading operations to be made up of a minimum number of experienced personnel.

All members of the work crew would wear audible - direct reading digital dosimeters in addition Lo the regular film badges and finger rings.

The members of the crew were Mr. Sco+t, Mr. Jerry Neideger, Mr. Prian Dunce (all three form NRC), and Mr. -

Donald Elting and me (both from RSO) . The NRC personnel \ ,, . ,a-would be in charge of the unloading operations and the RSO y perr cel would be in charge of radiation curvey. Note that

'4r. Weideger and Mr. Bunce are part of tne reactor operations staff and Mr. Scott is a NRC staff mcmber.

ARRIVAL OF SOURCES On feptember 29, 1988, the truck with the C3C o sources j

arrived at 1:40 p.m. at the NRC parking lot (east end). The

' shipping container was found placod at the middle of the truck bed instead of at the expected position at the rear.

Apparentl^. the shipment, weighing a total of 10400 lbs, could be transported safely in that position and not at the rear. Mr. Scott had not been informed about this change, l

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4 Co-60 Report November 4 1988 Page 5 In order to unload the sources with the facilities available here, it was decided to lift the inner lead cask and place it towards the rear of the truck, back the truck into the pool room and unload the sources using the procedures given above. Note that the inner lead cask weighed 7000 lbs and therefore it could be safely transported in that position - total distance driven with the lead cask in that position was less than 200 yards. The l WesMar construction Company in Pullman was asked to provido a movable crane, to lift the lead cask and place it towards the rear of the truck; no suitable crana was available at the WSU Physic al Plant to meet our need.

RADIATION SURVEY OF THE SHIPMENT The shipping papers were found to be in order. Along with the shipping papers, the results of the swipe tests of the individual sources carried out at the General Electric Company were also received. ThS swipe tests showed less than 0.005 microcuries of transferable activity from each of the sources and therefore all sources are acceptable for further use.

Mr. Elting and I carried out the required surveys before accepting the shipment. The maximum gamma radiation dose was less than 7mR/hr at all accessible external surfaces of the package, except at the bottom center. There the dose was 40mR/hr but this point was not easily accessible; the long cable connecting the meter to the GM probe was pushed through an annular space between the truck bed and the container to obtain the measurement at the bottom surface of the container. The dose at the edge of the truck bed, about 2 feet away from the container, was 0.4mR/hr. The driver's seat and all points 3 meters away from the package registered less than 0.05 mR/hr (not distinguishable from the background values). Note that the work crew and all other personnel remained at distances greater _than 3 meters away from the package, throughout the unloading operationa except for short periods of approach (5 -

to 10 minutes) by the work crew for conducting surveys, attaching the straps, clevises and crane hooks etc. The dose rate at a point be' - the middle of the container and beneath the truck bed v 4 mR/hr (about 3 feet away from the container).

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Co-60 Roport  !

Hovember 4 1988 Page 6 l

l The swipe surveys of the external surfaces of the steel container and the truck bed showed a maximum removable activity of about 70dpm per 100cm2 area.

The shipment was acceptable as received since it satisfied che regulatory requirements. (The dose rate at

- any point on the external surf ace of the package did not l exceed 200mR/hr and did not exceed 10mR/hr at 1 meter distance. Also the removable radioactivity was less than 2 2,000dpin/100 cm'4 . Individual sources were certified to pass the leak test) .

OBJECTIONS EY THE RADIATION SAFETY OFFICE STAFF Mr. Fred Miller of the RSO objected to the unloading of the shipment. He said that.there was a likelihood of accidental exposure even to those persons who were present i inside the building but not participating directly in the unloading operations. He requested that all personnel in the building be informed about the unloading work.

I called a meeting of all personnel at the building, at about 3 p.m. In that meeting, the details about the shipment and the procedures to be followed in the unloading operation were discussed. The following conc.usions were reached at that meeting and were implemented.

1. All personnel not involved in the unloading operation were given the option either to leave the building or to remain in the conference room inside the building. Note that the conference room is at the west end of the building, about 60 feet from the 60C o work area.

2. A road barrier would be set up to limit access to the work area, during the removal of the lead cack from inside the outer pack. (Mr. Neideser's suggestion).

3.- Film badges would be issued -to both the driver Mr. Frank-Kendall and the crane operator Mr. Bud Garrelts-(Mr.

Wilson's suggestion).

4. Mr. Scott ir formed all those present at the meeting about a recent telephone conversation he had with Mr. Todd Tillinghast of the General Electric Company. The call was made by Mr. Scott to apprise Mr. Tillinghast about our plans to'lif t the lead cask and place it r7 the rear of the truck i

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4 Co-60 Report November 4, 1988 Page 7 as the first part of our unloading operation. In that telephone call, Mr. Tillinghast told Mr. Scott to expect about 2R/hr radiation dose streaming through a centering recess at the bottom centers the thickness of lead shield at that cask.

recess is about a fev inches less than the rest of the The maximum radiation exposure to personnel could occur if personnel intercepted the streaming radiation from the bottom as could occur in an accidental placement of the cask on its side. This was considered unlikely. However, care was exercised thicughout the unloading operations to allow personnel to approach the cask only when it was placed on the ground: in this manner, only scattered radiation of lover intensity would cause exposure to workers. While the cask was lifted, personnel were about 15 to 20 feet away. A radiation monitor was used continuously to assess personnel-exposure of persons nearest to the cask, and found to be ,

negligible.

Mr. Bill Wilson of the NRC suggested (during the actual operations) that the lead cask be placed on absorbent papers in order to minimize any possibility of contamination. This was done.

I decided that we should unload the sources even though we were surprised by two aspects of shipment which came to our attention only after the package reached Pullman: a) the package positioned at the middle of the truck bed and b) the streaming dose of 2R/hr at the bottom center (due to less thick lead shielding in that place). The work crew was confident that the sources could be unloaded without

• cxceeding the maximwn, permissible levels of exposure to personnel. The alternative to refuse to accept the shipment was not considered by me.

REMOVAL OF THE INNER LEAD CASK Mr. Scott loosened the bolts on the top lid of the steal container and the lid was removed using the portable crane. Then the inner lead cask was lifted out of the steel container and was placed on absorbent paper on the ground beside the truck, t

Ine maxbmmn radiation doce on all accessible st f aces of the lead cask was less than 70mR/hr. No attempt was made

Co-60 Roport November 4 1988 Page 8 ,

to measure the streaming radiation dose at the bottom center, which was believed to be 2R/hr. The maximum rating of our instruments was 2R/hr and the higher range of 0 to 2R/hr was attainable only through the internal GM detector.

Any attempt to measure the 2R/hr field would unnecessarily increase the radiation dose to personnel, i The cemovable activity from the accessible surfaces of the lead cask was less than 45dpm/100cm 2, After completing the radiation survey, the lead cask was placed on absorbent papers at the rear of the truck.

The combined operations of removing the top lid, lifting the lead cask out of the steel container, radiation surveys of the lead cask and placing the lead cask at the rear of the truck took about 30 minutes. On the average the work crew might have been exposed to a radiation dose of about 7 mrem

(=70mR/hr x 0.1 hr). The driver and the crane operator would have received a smaller dose than given above.-because of larger distance of separation.

REMOVAL OF THE SOURCES The truck with the 1eLa cask positioned at the rear was backed into the pool room, through the open east bay door, within about 10 minutes; all work crew personnel were at .

least 10 feet away from the lead cask.

The lead cask was then lifted using the overhead crane in the pool room and the truck was moved forward. The lead cask was then kept on absorbent papers on the floor. The radiation dose was again found to be a maximum of 70mR/hr at l all accessible surfaces of the cask, when it was placed on the floor of the reactor hall.

! Mr. Scott loosened the bolts on the lid of the cask; the lid was left in place. Then the cask was slowly lowered to the bottom of the nuclear reactor pool and was placed at l the east end bottom of the pool. The lid of the inner cask l was lifted out of the pool and was placed on the south east I end of the pool room.

The sources inside the receptacle of the lead cask were removed, under water, using long tools. They were placed near the center of the south wall of the pool. Note that 26 (pencil) sources were kept in one container and an annular

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Co-60 Report November 4 1988 i Page C l

l source was kept separately (on the projection of the middle i partition wall). Radiation dose measurements on the surface of the pool at a point directly above the sources did not show any increase above ambient levels in the past (about 0.05mR/hr). Note that the reactor was not operating at this time.

The empty lead cask was lifted out of the pool, again using the overhead crane. Continuous dose rate measurements at the water surface above the etak, while it was lifted 1 out of the pool, showed that the cask was empty. The empty cask was placed on absorbent papers on the east wall of the pool. Water inside the receptacle of the cask was drained.

The body of the cask and the lid were wiped clean and dried.

Swipe samples of the cask showed a maximum rer _ovable activity of about 850dpm/100cm 2. The dose rate of the cask was at the ambient level (of the pool room) of about 0.05mr/hr. i The empty lead cask was then placed at the rear of the truck. The repacking operations were the reverse of the unpacking operations. The truck with the empty lead cask packed inside the steel container was released for the return journey to Cal!fornia. All the procedures given in this section were completed within about 90 minutes.

In all these operations, ti.e work crew might have received about 7 mrem of radiation dose (70mR/hr x 0.1 hr) mainly at the time of loosenin* the bolts and attaching the crane hooks to the cask. The driver and the cranc operator were stationed f ar away from the werk area.

RADIATION DOSE EQUIVALENT ESTIMATES 1

All seven digital dosimeters used by the work crew, the driv r and the crane operator were found to read less than imRem of radiation dose equivalent for whole body exposure.

However, the body extremities might have received a higher dose. I estimate from time of exposure x exposure rate that the radiation dose equivalent received by any part of the body is less than 15 millirem for any member of the work crew the driver and the - crane operator did not work near the lead cask and therefore would have received less tt.an 15 I

mrem of exposure. Note that the maximum permissib1<

! exposure is 1250 mrem for a calendar quarter. Tnus, the additional exposures received in this work vere well within 4

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Co-60.Roport l November 4, 1988 Page 10 the restlatory limits. In view of the above observations, I did not make a special request for immediate processing of the film badges. l t

BUILDING RADIATION SURVEY AND POOL WATER ANALYSES After emplacement of the sources in the nuclear reactor pool, various areas of the building were surveyed with portable instrument the same evening (September 29) by me.

The radiation levels on the 1st and 2nd floor of the building (offices and hall ways) were found to be less than 0.05mR/hr-typically 0.OlmR/hr-and showed no great variations from place to place. The cave room was monitored later and the radiation levels showed no increases relative to the past, i.e. before emplacement of the new sources. Pool water showed lictle or no changes in the 60C o concentrations compared to past observations.

From the above observations, I conclude tFst the addition of the new sealed sources of 60C o into reactor pool did not cause significant increases in the radiation level in all occupied areas of the building. The unloading operations did not result in leakage of the sources.

EPILOGUE It appears that one or more persons at the Radiation Safety Office made a request to Dr. Walfred Peterson, the WSU Ombudsman, to undertake a complete investigation of the events relating to the shipment, since they believed that the 60C o project was not planned and executed well. The complaint was made on or about October 7 a week after completion of the work. Dr. Peterson had contacted Dr.

David Barbee. Director of the Nuclear Radiation Center, who in turn requested Mr. Arden Scroggs of DSHS, on October 11.

for an-investigation. Note that Mr. Scroggs was at WSU during the period October 10-12, conducting the annual inspection of the Radiation Safety Program. Mr. Scroggs had discussions with the Radiation Safety Office staff and me and his findings were reported at a meeting on October 12.

Personnel present at the meeting were Dr. Robert Smith (Vice

Co-60 Report November 4, 1988 Page 11 Provost for Research). Radiatien Safety Committee members (except Dr. M.J. Smerdon), Dr. David Barbee, Mr. Donald Elting, Mr. Fred Miller and me. The major points of Mr.

Scroggs' report are given below.

1. Planning for the receipt of 60C o shipment was hapha:ard. '

2. Members of the Radiation Safety Committee, the staff at both NRC and RSO should have been briefed before the arrival of the sources. The occupants of the building were not adequately informed.

3. Lines of authority were not distinctly defined; the RSO is in charge of the sources going into the-NRC.

4. The Radiation Safety Committee did not authorize the receipt of the shipment.

5. A little bit more time should be allowed to develop plans and procedures for dealing with projects of this nature.

6. No one was hurt in the work. However, end does not justify the means.

7 A memo of understanding between the two groups (RSO and NRC) is essential.

SUMMARY

Sealed sources of 60C o of total activity of 8049 Curies were received as a joint donation from Northrop Corporation i and J.S. Shepherd and Associates. The sources will be used to upgrade the samma irradiation facility. The total value of the donation which includes transportation, leak testing ,

of the sources in the hot cell and manuf acturing costs is estimated to bc about $70,000 (extimate by Mr. Scott).

The sources were received at WSU on the af ternoon of.

September 29, 1988. The sources were unloaded and stored under water in the nuclear reactor pool; the unloading operation was completed in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The radiation exposure to personnel involved in the unloading operation was kept to the minimum achievable levels which were well within the regulatory limits. Direct reading digital dosimeters placed on the work crew personnel revealed less than 1 mrem

Co-60 Report November 4, 1988 Page 12 radiation dose equivalent per individual for the whole body exposure. It is possible that the radiation dose equivalent to the body extremities (hands and f eet) could be as high as 15 mrem, as estimated from rate of radiation exposure x worked time. The driver of the transportation vehicle and the crane operatcr who provided help were subjected to much lower levels of exposure relative to any personnel in the work crew. The radiation levels in the occupied areas of the building were not increased by the addition of the sources into the reactor pool. The sources show no evidence of leakage.

Copies of all documents related to the planning, shipping papers,-radiation survey and pool water analyses are kept at the Radiation Safety Office, s

CONCLUSIONS I returned to WSU on September 19, 1988 to assume the position of the Director of the Radiation Safety Office. On September' 22. I was informed abut the imminent shipment of 8049 curies of sealed sources of 60C o from California to

• nrrive here during the week of September 26. Even though I did not participate in the earlier planning. I assumed charge to ensure radiation safety of personnel during the -

work connected with the receiving of the shipment. If any lapses are seen in the radiation safety, then I must be held responsible for those lapses.

I give below a list of my conclusions deduced from my participation in the project, I have benefitted from discussions with Dr. David Barbee, Mr. Bill Wilson, Mr.

Marshall Scott, Mr. Jerry Neideser and Mr. Fred Miller who have successfully persuaded me to look into different aspects of the same problem. These individuals and others at the NRC and RSO who attended the meeting on September 29 made several useful suggestions to ensure safety in the unloading operation. I thank all these individuals.

I give below my conclusions.

1. In receiving the shipment of 60Co sources, radiation safety considerations were not compromised.

2. The shipment was received, the package opened anL the semled sources removed following a previously established

Co-60 Roport November 4, 1988 Page 13 protocol, modified to some extent because of two surprises:

1) the shipping container was not placed at the expected position on the transportation truck bed and 2) the radiation level at the bottom of the inner lead cask at 2R/hr was higher than expected. I decided to accept the shipment despite these two surprises.

3. All personnel who were involved in the unloading work of the shipment received minimum achievable levels of radiation exposure. I estimate the radiation dose equivalent suf fered by individuals as a result of this work is a small fraction (about 1 to 2%) of the muimum permissible level for the calendar quarter. ~

4. The radiation safety concerns relating to accidents and possibility of over exposure from it were addressed at a special meeting on the day of the arrival of-the shipment.

5. I suggest that the NRC and RSO buy a portable radiation meter capable of measuring high radiation fields (say 0 to 50R/hr). Note that the instruments available to us are capable of measuring 2R/hr fields only if the operator remain very close to the source to record a observation.

6. The NRC and RSO staff who participated in the actual operations worked very uell together to ensure safety. It appears.to me that some members of the RSO staff may still be concerned about the preparation for the operations. We are working together to allay these concerns, h

7. Additionally. I am trying to create a spirit of co- -

operation among the RSO staff including myself. so that all of us can succeed in our efforts to provide the required services to the researchers at WSU.

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St. ate Univer:31ty Nucicar Radiatica Ccotor, Pullcan. Washington 39164-1300 / 509-335-4641 M E M 0 R A 11 D U M To: Rad 14tlen Saf ety Of fice e

From: Marshall Scott Dates Sept. la 1953

Subject:

60 Co Scurces As we discussed the Ccbalt sources should be arriving scmetime around Sept. 27 or the 25th. This shipment will be sent from G.E. and the contact persen sncula be Todd Tillinghust (41?isc -4 To. If there ar2 anv questicns er problems. All the scurces will be in one shipping cast and will be removed under wa ter in the rascter pool. They will then be placed in s tcr age for use in the 60 Co irrac14 tion facility. Located in Elli Wilsens file is a list of the scurces and their last swipe test.

The f ollowing inf ormation might be useful for the file Lccatad in the reactor pool are two scurcas. The first scurce w+s irradiatad by Pictor and had a total activity of 3.!00 Ci as of Decamber s 17 1*c' ard the seccnd source was leradiac2d in the MTR reseter at Id ho Fal;s and it had a total activi ty of 13.000 Ci +s of Acril 1 1:45 and was taggad a s .45U-701. As of tcday the deca.ed act1< tv of scarce 41 12 120 C1. and scurce W5U-701 is 1.003 C4. The acurcas that are to be asi;vered in saat. art listad in the a::scred cer es;cncenes 4: 14.

FFCCEOUFE:

1. E.tamen the truck end cosk upcn arrival fc- dav daaege and suspe tha truc!. anc casi. fcr c en tamin.s tion .

2. Re. cove pcol es111ng from end of pcci anc cack true!. into poc1 recm

2. cidca Cables and cle"iaes on cask and secura te crane hock A. S'.owly raise 6,000 lb. cask from truck and Icwe- into pcol.

S. with the cask setting on the bottem of the pool ramove the end cap of the cask and set on pool roc.n floor.

6. We will then place the sourcas on the pec1 floor tempera 11y till they can be pleemd in the irradiation holder.

7. The empty cask will be lifted from the pool floor and placed on the truck.

S. Another swipe survey will be made of ,the cask and truck before the truck leaves the site.

NOTE: Pcol water ,calysis will be made befora and alter the sources are placed in the pool. Consideration to floer loading and poc1 i c on tamin a tion has been analy:ad. and found to be of little .

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?*, w .* u i.::a Sepennber 23, 1988 J. L. Shepherd & Associates 1010 Arroyo Street San Fe rnandu, California 91340

Dear Mr. Shepherd:

A'1 . surfaces of the following sources ho ee been s= eared and the surface act.ivi y has been found to be .e

• transforabia sour:n. s than 0.005 mic:scuries for each I"~'0?'. SES n C2 Ir pA I cuter Co.60 AEC'. XC2094:5C 670 72 9/25/g3 671 *

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Please 1e: us know if we can provida addirienal infor:a:icn, ,

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September 23, 1988 J.1. Shepherd 6 Associates 1010 Arro.vo Stren:

San Fernando. California 91340

Dear Mr. Shepher$:

All surfaces of the followir.g sout:es have been smeared ar.d the transferable surface activity has been found to be less tha,n 0.005 microcuries for each source.

Isr ?'S SE?'At C"S*ts DA?! SH'?'t)

Co.60 USMC J612 16

• 9/25/88 US:lC Jale *

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• USMC JL16 *

• USMC J417 *

• USNC J613 *

• USUC J619 *

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• USMC J421 *

• VSNC J422 *

• USNC J423 *

• US:1C J4:4 *

• Please 13: us kr.ow if we can provide addit:,onal infor ation.

Sincerely, U

ToddTillingMEs:

Sales Specialist Irradistion' Processing Operation (415) 862 4396

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,3 DEPARTMENT OF SOCIAL AND HEALTH'f(RVI ES Obm+ nurgron Mouovs = lf November 9, 1988 Robert Smith, Dean The Graduate School Washington State University Pullman, Washington 99163

Dear Dean Smith:

The purpose of this letter.is to confirm our telephone conversation with your Radiation Safety Officer, B. Srinivasan, on November 4, 1988, ordering Washington State University to immediately cease further manufacture and distribution of Prof esser Brian tctnb's atmospheric gas chromatographs, cease further receipt of sealtd sources for use in the pool irradiator, and to ensure that the fritium neutron ge.*ierator will not be used for cesearch until appropriate procedures are submitted te our office for evaluation. Dr.

Srinivasan's verbal statement of intent to comply with this order is hereby acknowledged. These actions have been taken for the following reasons:

1. On february 25, 1986, the University revested permission to conduct research and development work on Professor Brian Lamb's atmospheric gas chromatograph. Author 12ation was granted by Leo Wainhouse of this office, with the stipulation that this office would be notified prior to any distribution, and that NRC Fuel Cycle Directive 84-22 would be followed befort, distributing the GC units. Contrary to the above, seven gas chromatograph? 'Vve been manufactured and distributed, two of which were tent out e' tra country to the People's Republic of China.

2. The radioactive sources received from J. L. Shepherd & Associates for placanent in your pool irradiator are of unknown construction. Although a safety evaluation was performed by Dr. Srinivasan prior to receipt of these sources, he was unable to assure us that the sources were evaluated for water immersion. Therefore, we have serious concerns for the poten-tial contamination cf the pool, the pool reactor, and the containment bJ11 ding. Secled sources used in Category 3 pool irradiators must meet

'Cl Standard h542-1077. Furthermore, Todd Tillinghast of Vallecitos hoclear Center stated that the 5,000 curic GE source, serial number GEC-JCS-9147, which they encapsulated prior to delivery to you, was not evaluated for compliance with the AhS! standard.

3. Contsary to your Radiation Sciety Office's agreement with us that no research work would be cunducted with the Tritium neutron generator until the proper procedures had been rect:1ved and approved by our office, our recent inspection of the University showed that research work had been conoucted using the Tritium neutron generator. '

0 n//0 ib -

4 Robert Smith, Dean Page two Other items of concern from our compliance inspection of October 10-13, 1988, wl11 be documented in a fermal compliance letter to follow within the next 20 days; however, pursuant to this letter, I am requesting that the University provide the following material to me no later than the close of business, November 18, 1980:

1. An inventory of all st&ied sources received from J. L. Shepherd & Associ-ates and placed in your reactor pool, listing the manufacturer, model number, activity, and serial numbe , where applicable.

2. A copy of the Radiation Safety Officer's safety evaluation for all the above scaled sources.

3. A list of all the firms which received Professor Lamb's gas chromato-graphs, and copies of their current radioactive materials licenses.

4. Ccptes of all Radiation Safety Connittee meeting minutes in which the manufacture and distribution of the gas chromatograph units, acquisition of sealed sources for the pool irradiator, and/or use of the Tritium -

neutron generator for research were discussed.

The issues we have raisec in our October 10-13, 1988 inspection of your license, and in this letter concerning additional issues, are most serious, requiring an immediate followup inspection and review of radiation safety practices and the activities of the University's Radiation Safety Committee.

My staff will be in touch with you regarding acceptable dates for our return visit, 11 you have 4(.stions, feel free to contact me at (206) 753-3468, or Gary Robertson of my staff at (206) 753-3351.

Sincerely, f/h ng,-Chief

&rt {I

< . R. St 1RS:tf Office of Radiation Protection ec: B. Srinivasan Radiat' ion Safety Officer Jack Hornor U.S. NRC, Region V Richard McCartan Assistant Attorney General l

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HEMORANDUH  !

TO: Harry North, Pegiori V, ARC TROF1:

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• dj9c nj,(!n i 5/4 PRIORITY ATTENTION REQUIRED MORNING REPORT - REGION Y DATE: 11/16/88 1.1CENSEE/ FACILITY NOTIFICATION / SUBJECT Washington State University State of Washington Confirmatory Order Pullman, WN. DN $0-27 .

EVENT On November 9,1988, the State of Washington, Department of Social and Health Services, issued a confirmatory order to Washington State University to cease further receipt of sealed-sources for use in the pool irradiator. This order resulted from an inspection conducted by state personnel on October 10-13, 1988.

The order addressed several matters subject to the Washington State materials-license. The pool irradiator identified in the letter is located in the Triga reactor pool. A total of 27 cobalt-60 sealed sources encapsulated by different rnanufacturers, containing approximately 8049 curies, are presently in the reactor pool. The Washiagton State letter notes that the licensees radiation safety officer was unable to assure the State that the sources were evaluated for water innersion in accordance ANSI Standard N452-1977. The largest single source (S000 curies) encapsulated by General Electric Company for Washington State University was reportedly not evaluated for compliance with the ANSI standaro.

Region V has been in contact with both the State of Washington, Department of Social end Health Services and the licensee. The licensee has increased the frequency of analysis of pool water for Cobalt-60 contamination to three times a week. The Licensing Project Manager, Research Reactors, NRR has been informed.

NMSS is evaluating the sources which are in the reactor pool. TheSER(NUREG-0911) applicable to the facility identifies the presence of a Cobalt-60 irradiator, licensed by thi Washington State, in the reactor pool. - ,

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Contact:

G. P. Yuhas, FTS 463-3748, H. S. North,-FTS 463-3762.

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,' 10>-29 '88 12127 IDIDSHS RAD PROTECTION TEL ICl206-753-14% .#029 PS2

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$TATI OF WA9NCTON DEPARTMENT OF SOCIAL. AND HEALTH SERVICES 0%pk WnMgtus 9630K095 November 23, 1988 Vandy t. Miller i Assistant Director for State Agreements Program State, Local 4 Indian Tribes Program Office of Governmental a Public Affairs United States Nuclear Regulatory Commission Mail Stop WF-3-0 23 Washington 0.C. 20556 Deer Mr. Miller The purpose of tnts letter is to request your technical assistance in evalu-ating a number of old sealed sources used in a Category !!! pool irradiator located in what is apparently a resecrch reactor secondary fuel storage pool.

We are faced with two issues herft (1) what are the legal ramifications of the siate continuing to license sources in the research reactor pool (or can these different activit14: be separated physically as well at licensed separately by our two agencies)1 and (2) should the sealed sources in the pool (both those recently placed there, as well as those originally authorized by-the pre-Agreement State AEC _ license) be allowed to remain?

Recently, one of our licensees. Washington State University, who is also the holder of- an NRC license for a research reactor, received 27 individually cealed sources containing approxirnately 8,049 curies of Cobalt 60. Washington State University had acquired these source in order to upgrade its existing irradiator, and was expecting to_ receive additional sources. The original Itcense for an irradiator was issued by the U. 5. Atomic Energy Comission on May 19, 1961, and authorized a total possession for the pool irradiator of 16,000 curies. This _ original AEC license approved the _ placement of the irradiator in the Wtshington State University research reactor pool. In' reviewing the licensing history for this irradiator, no specific reference is made by the Atomic Energy Commission license to any particular manufacturers or model numbers of the-sealed sources. We took over this license when we became an Agreement State. In the.early years of our. Agreement State program, we automatically renewed the original license. However, in July of 1986, we-attempted to be-more specific'by stating in Item 7 (chemical- and physical.

form) that the authorized radioactive materials consisted of " Sealed sources -

game irradiation unit in nuclear reactor pool." We felt this would limit the licensee to only the M urces already in the reactor pool. However, as we now know, this too was not specific enough, and Washington State University was able to receive the additional 27 sources from different manufacturers, none of which have- been- te.ited to ANSI N642-1977 standards for Category !!!-

trradiators. q dl5-/

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-. . .~ - . . - -

,' to>-29 '00 12: 20 ID:DSHSRADPROTECTICU TELf0206-b3-2496 h029P03 Vandy L. Miller Page Two The sources which were received by Washington State University on September 29, 1988, were donated by J. L. Shepherd and Northrup Corporation. The following is a description of the 27 sources received.

Lt G Shthh.tDL 1 AECL type 132 stick source with an activity of approximately 1400 curies.

1 J. L. Shepherd Model 1099 annular souree with an activity of approxi-mately 700 curies.

1 J. L. Shepherd serial number JEC-JCS-9147 with an activity of approxi-mately 6000 curies.

Ihg korthruo Corooration 12 AECL Model XC-309 Cobalt sources with an apprcxistate activity of 72 curies each.

12 U.S. Nuclear Corporation type 368 Cobalt 60 sources with an activity of approximately 16 curies each.

Our first concern is whether the state of Washington should continue to have-Jurisdtetion over the irradiator, since it is located in the research reactor pool which is regulated by the U.S. NRC (reference is made to NRC Inspection Manual Part 9900: 10 CFR Guidance - Part 50). I have enclosed a copy of the original application and subsequent license which was issued by the U.S.

Atomic Energy Comission to Washington State University for the pool irradi-ator on May 19, 1961. Also included in this package is a copy 'of the renewal application and subsequent license issued on May it, 1966 by the U.S. Atomic Energy Comis sion and the Washington State University's application dated April 25, 1967, to the state of Washington for a Washington State radioactive materials license, which rss issued on May 5, 1967 (see Attachment t, License History).

Our second concern has to do with the integrity of the original sealed sources _

and also of those sources recently received by the University. All_of these sources appear to pre-date the Agreement State Programt thus, any sealed source evaluations would have been done by the AEC and would appear in your archives. We therefore request technical assistance to assure that there has been an adequate evaluation of both the original sources and the sources received on September 29, 1988. The following is a sumary of the sealed source infctmation contained in Attachment 21

1. Letter from Washington State University acknowledging receipt of the original source from Picker Research Center.

.g . - - - - - -

Vendy L. Miller Pese Three

2. Washington State license application and source diagram for the Idahc '

Nuclear Corporation source.

3. Information for J. L. Shepherd & Associates Model 1099 annular source.

4. Letter from Northrup Corporetton regarding the 12 U.S. Nuclear Corpors-tion' Type 368 sources, and the 12 AECL C-132 sources and a diagram of the-sources.

6. 'J. L. Shepherd 4 Associates special form test reports on the U.S.; Nuclear

Corporation Type 368 and the AECL Model C-132 capsules, and the Model 1099 annular source.

6. A letter from Nordion (formerly AECL) which provides data on the AECL C-132 and AC-309 sources.

A complete report frei, biashington State University on the evaluation and receipt of the Cobalt 60 sources on September 29, 19881s included as Attach-ment 3.

On November 8, 1988, we contacted Steve 8aggett of your office and received preliminary information concerning sosie of the sealed sources. We have since ,

been in contact with Jack Hornor and Dave Yuhus and apprised them of the  :

situation.- An order has been issued to the Dean of Graduate Studies et Washington State University to cease receiving further sealed sources for tne reactor pool until a determination can be made as to the integrity of all sources now in the reactor pool. Although the sources have passed the Depart-ment of Transportation requirements for special form, they have not been tested to the more stringent ANSI N542-1977 Category III trradiator standards.

o We would appreciate a response as soon as possible. If you have any questions, feel free-to contact me at (206) 686-8949.

l Sincerely.

T. S ng Office f Radiation Protection l= TRSakf Enclosures cci ' Jack Hornor Dean Kuaihiro e

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'. RADIATION SAFETY OFTICE

, 0 00)335 8916 MEMORANDUM TO: Dr. T. Okita, Chairman, Radiation Safety Committee I FROM:  !

Dr. B. Srinivasan, Director, Radiation Safety Office '

DATE: Dec. ember 5, 1988

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SUBJECT:

Fredthe on Miller's memorandg of December 1, 19 % , to you receipt of Co sealed sources and my analysis of Mr. Miller's concerns 1988, AtFredthe Radiation Safety Committee meeting on December 1, Miller discussed his continuing concerns about gdiation safety associated with the receipt of 8049 curies of Co sealed sources., At that meeting, he provided you with a memorandum licting those concerts. A copy of the memo is enclosed. Here I will provide answers to ecch one of those concerns, drawing upon my own observations and recall of events which happened on September 29 the day on which the aforementioned sealed sources were rece,ived at WSU.

In addition, I will provide an analysie of the progress we have made at the Radiation Safety Office (RS0) since my return to WSU on September 19, 1988.

the small I am heartened by even of progress. At the same time, I am disillusione, amountd by the continued misunderstanding distrunt which exists between different and even factions at the Nuclear Radiation Center building. I will try to bring into focus the cause for unhappiness among the Radiation Safety Office, as I perceive it. Thus,staff at the I am writing this-mems with the hope that it will provide an opportunity for healthy discussions, satisfactory resolutier of conflicts and the emergence of a spirit of cooperation. This must occur soon if we are to succeed in our work at the Radiation Safety Office.

E Co reDort of November 4, 1988:

l Earlier, in a report prepared on November 4, 1988, I provided the receipt of an analg is of the radiation safety aspects governing Co sealed sources. I wrote that report to satisfy the following three purposes:

1. A record of events related to the planning and execution of the work; i

l 2. A record of my analysis of radiation safety aspects; and

3. A reference guide for the future.

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% T. Okita December 5, 1908 Page 2 Since completing the report, I have sent a copy to DSMS in olympia to aid in their inspection vosk.

In preparing the report, I paid spncial attention to pointing out the work the cooperatisn which existed between members of and othercrew who carried out th*e actual unloading operation individuals in the building who proviccd ideas, suggescions and actual help (e.g., managing road barriers, di'atributing film badges and dosimeters). In that process, I avoihed mentioning the conflicts and infights be. tween individuals a~nd groups which had been in existence for several months prior to the arri'ral of the sources. Nevertheless, the personality conflicts and dif"erences were laid aside, even for a day, in order to completc the unloading operation in the sar.'est possible aanner.

of progress. This was seen by me surely as a sign However, I see signs of strc.:s again. It is ,

inperative that the root cause of this stress be identified and conflicts resolved. I will address this issue towards the-end of this memo, s r submitted list of si providing answers to the recently e concerns of Mr. Miller.

b8 Mr. Miller's concerns and my answers:

The six' specific concerns listed in Mr. Miller's memo of Decegber 1, 1988, and mv answers are given below.

1.

The first concern was that David Barbee, NRC Interim Director, and B.

Srinivasan both denied that the NRC building residents should be informed about the transfer of 8000 Ci of o0 Co from a semitruck in front of the NRC to the reactor pool. My answer follows.

I tooksafety radiation charge on September 22 to deal with the matters connected with the expected shipment. I ask3d Don Elting to join me as a member of the work crew and Fred Miller to glp me with the analyses of pool water samples for ca content. In addition, Marshall Scott of the of communications between him and the donor- of the-NRC had provided copies sources to the Radiation Safety Office, rven before my arrival at WSU. Furthermore, Mr. Scott wrote a memo to the Radiation Safety Office on September 14 - in which he described the proposed plans for unloading the sources.

Finally, I did show a copy of my letter addressed to Mr.

Vere 11en of DSHS in which I described the expected shipment to the RSO staff. Thus, the RSO staff were i

s aware of, the details about the expected shipmer.t.

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m T. Okita J ,

December 5, 1988 Page 4 The 60 Co shipment was expected to arrive at WSU with the shipping container placed near the rear of the truck.

If that had happened, the transfer operation would have been a simple one as shown in the written plan of September 14. However, the container was found to have been plar.ed near the middle of the truck. Therefore, the unloading plan drafted earlier had to be modified. The modified plan required moving the inner lead cask towards the )*ar of the truck. This required further information frca t - shippers and the services of a movable crane f r ;n 4

.ocal company. Ne were interested in completing anicading operation by the end of the day su that the tg Co sources could be placed in a locked area of the building rather than outside the building on the bed of the truck. Thus, a sense of urgency prevailed during the afternoon of September 29. The sources were transferred to the r.ottom of the pool with full consideration to rz.diatica safety in the operations.

I conclude that it is erroneous to call the transfer operation an emergency.

3. The third concern was that there was no written plan. My answer follows.

To t'he best of my knowledge, Mr. Scott had been in communication with the RSO staff during the period from July to September, 1988, about the donation of the sources and coordinating his efforts with the RSO in acquiring them. The last communication between the RSO staff and Mr. Scott before my arrival in Pullman was on September 14 in rhich he had described in writing the plans for enloading the sources.

I conclut that the stateraent in the third concern is not correct.

4. The fourth concern was that we used untested carrying gear. My answer follows.

Mr. Miller said that the carrying gear was in reference to the straps which were used to attach the inner lead cask to the hooks of the cranes used in the work. The straps and clevises were obtained by Mr. Scott from the WSU Physical Plant in early September. At that time, Mr. Scott was expecting the shipment to arrive in mid-September and thus he was prepared quite early.

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T. Okita

) December 5, 1988 Page 5 The straps and clevises used in the unloading operation are capable of supporting loads of 10,000 lbs.

As an additional measure of safety, Mr. Scott used two straps instead of the required one strap. Thus, the lead cask was lifted with a good margin of safety.

Recently (on December 2), I learned from Mr. Scott that he nad used the straps instead of chains or cables because these straps are used routinely by Physical Plant personnel to lift heavy loads of about 8,000 lbs. Mr.

Scott also learned from them and other heavy machinery operators that straps are superior to chains and cables because of stretching and shock absorbing characteristics.

I conclude that we used the appropriate carrying gear, relying on advice from routine users.

5. The fifth concern was that we moved in unbraced load. My answer follows..

I The inner lead cask was kept at the rear of the truck and moved unbraced. In that position, the total distance driven was less than 200 yards and at very low speeds (mostly in the reverse gear). The road was blocked for all other vehicular and pedestrian traffic (other than the work crew). We did not anticipate any accidents during this short trip.

I donclude that the unbraced load did not pose any safety threat to the operation.

6. The sixth concern was that of whether we hgCosatisfied for placing the in the federal NRC regulations reactor pool. My answer follows.

I believe that Mr. Miller is possibly referring to

• erry Strong's letter (from DSHS) dated November 9, 1988, in which Mr. Strong had asked whether the sources were suitable for wuter immersion. All the sources were

m. nuZactured according to the specifications required for special form radioactive materials. Although these sources were not specifically tested for water immersion, T.he shippers and donors of the sources state that these sources are suitage for safekeeping in the nuclear reactor pool. The Co concentration determination of

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T. Okita December 5, 1988

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pool water samples registers) no changes relative to pre-Septembe" 29 values.

DSHS personnel are investigating further into the question of whether these sources are suitable for water immersion. In view of this, I can give only my opinion that the st rces are suitable for water immersion.

Analysis of Mr. Miller's concerns:

I believn that Mr. Miller is repeatedly expressing his o Co shipment only to draw attention to the concern about the fact that he, Don Elting and Josy Drury (all from RSO) are unhappy about several unconnected events which took place at the NRC and RSO since June, 1988. Mr. Miller has become the spokesman for the above group of individuals. I have had lengthy discussions with Mr. Miller about their concerns. I have tried my level best to create a sense of cooperation between myself and the above-mentioned group. In this ordeavor I have L;en successful to a limited extent. All of us are working togsther with proper accord to radiation safety. This fact alone should not lead to a false sense of

) security. Tense working conditions such as these are sure to snap even with the least provocation. I want to establish a permanent and healthy environment at the RSO so that we may succeed in our efforts to better ourselves and to offer better services to the researchers at WSU. In this spirit, I will list some of my findings which are derived from my lengthy D discussions with Mr. Miller. I believe that Mr. Elting and Ms. Drury will concur with the views expressed by Mr. Miller -

and repeated here.

1. Mr. Miller, Mr. Elting and Ms. Drury are distrustful of the!r superiors. This specifically includes me and Dr.

Robert Smith.

2. They do - not trust Dr. Barbee. They refuse to believe that Dr. Barbee is trying his best to establish a strong and viable nuclear science program using the reactor facilities.

3. They do not believe in the university embudsman and in the system which adcresses complaints against different factions.

4. They do not believe in finding redress to the safety concerns through established reporting channels at WSU.

They have gone to both the orbudsman and DSHS personnel

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T. Okita

) December 5, 1988 Page 7 directly without giving the necessary chances for the local system to succeed.

I want to suggest here that Mr. Miller, Mr. Elting and Ms. Drury be provided an opportunity to write up their grievances and ; esent them to the proper officials toward finding a satisfactory solution for their concerns. I encourage them to address the real grievances and seek solutions for them. In this manner, the root causes for their unhappiness may be eradicated, resulting in a happy, productive working environment.

Enclosures cc: Members of Radiation Safety Committee Dr. R.V. Smith, Graduate School ,

Dr. W. Peterson, University Ombudsman y ters of staff of Radiation Safety Office BS: crc

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iT. Okita-December S,-1988 -

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Addition to the memorandum from Dr.

B. Srinivasan to-Dr. T.

'Okita Since writing the above memo ' and providing you with a handwritten copy on 12/5/88, Arden Scroggs, has completed the-follow-up inspection on the forenoon of 12/7/88.

The same af ternoon I met with Dr. Walfred Peterson, WSU Ombudsman,t and told him. about my desire that the ' Radiation Safety Program move forward and the users of _ radioactive materials get the- 3 best service possible from us. Towards that end, the RSO staff and I must rcaffirm our commitment to our duties and responsibilities at WSU. Here, I will make a personal appeal to the RSO staff to effect a spirit of cooperation.

honeal to Mr. Don Eltina, Mr. Fred Miller and Ms. Josv Drury During 1982-87, I have worked at the RSO in_ association with all of you for varying periods of time and found each one of you capable, conscientious and hardworking. I hold the same opinion today.

In the past two and a half months in your zeal to correct. '

events which- you perceived to be wrongdoings, you followed a >

path which y-passed the rurmal channels of. communication =and sought the aelp of Dr. Walfred Peterson, WSU Ombudsman, and Arden Scroggsf Compliance Inspector at DSHS. Because of your-direct dealings with neutral observers, I was forced to. limit 1 my . communications with you so that the = integrity of the investigations would not be compromised. '

The inspection work by Mr._- Scroggs _ is now comple'te.- We will have to rjddress'and remedy the deficiencies which.he will be communicating to us. Dr. Peterson has also.- completed ~ his work to a great extent in addressing your. complaints of the past few months. He-is of the opinion that we at the RSO must put away the differences which have divided us in the past and

. move ahead with . constructive plans- for ' the future.

I .liked his advice and I requested his--help. .He would like all of us -

to meet together with -him and : affirm - our intent to : work together with a - cooperative spirit. -I'have asked Dr. Robert '

Smith to visit us: at our coffee break . time on '12/16/88 and inform us -about- his - exper ations and define the role-for our; office in meeting the needs of the- University. I will be asking the. Staff Personnel: Office to provide; you with guidelines to,obtain re' dress for your complaintstagainst-me.

In' summary, I.have done my best to begin-the process"of communication between all of us. .I want to succeed in .

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. T. Okita December 5, 1988 Pago O establishing a good Radiation Safety Program. I want all of you to join me in this endeavor, 4

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j WASHlhU1 Div 6 Dia c 'un ti 4 a.s4 i e -

PULLM AN, WASHINGTON 991641302 .

(509)335tel6 R ADIATION SAFETY OFFICE MEMORANDUM TO: T. Okita, Chair, Radiation Safety Committee FROM: F. Miller, RSO DATE: 1 DEC 1988

SUBJECT:

Concerns relating to 60C o transfer My concern on 29Sep88 was that D. Barbee,IEC Director and B.

Srinivasan both denied that the Imc building residents should be infonned about the transfer of 8000 Ci of 60C o from a semi-truch in front of the IEC to the reactor pool.

I objected At a Radiation Saf ety Office staf f meeting -on 30SepB8, I to B. Srinivasan's statement that the transfer went smoothly. -

tated my conecrns that:

the transfer was handled as an emergency; there was no written plan we used untested carryin;; sear:

we moved an unbraced load; I questioned whether we had satisfied federal NRC c .

Jeculations for placing the 6000 in the reactor pool.

I pc: B. Srinivasan

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5 TATE OF WASHINGTON I

F Y NOTICE TO EMPLOYEES SW RADIOACTIVS MATERIALS LICENSE NUMBER (s) WN-T EMPLOYEF 3 +

a g i X RAY

} s REGISTRATION NUMBER (s)

FAA4 In the Radiation Control Regu'ations, the Department of Social and llealth Ser ices }{as Established Standards l'or Your Protection Against Radiation llazards YOUR EMPLOYER'S RESPONSIBILITY applicable limit as set forth in the regulations or in the

' Your employer is required to: license. The basic limits for exposure to employees are

1. Apply these regulations to work involvirg sources of ra- set forth in WAC 402 24-020, WAC 402 24-030, and diaa.n. WAC 402 24-035 of the regulations. These sections

2. Post or otherwise make wailable to you a copy of the specify limits on exposure to radiation and exposure to Depa ment of Social and Health Services regulations, concentration of radioactive material in att or water.

licensea, registrations and operating procedures which 2. If you work where personnel monitoring is required, and apply to work you are engaged in, and exphm their pro-if you request information on your radiation exposures, visions to you. These documents may " examined (a) Your employer must give you a written report, upon termination of your empicyment, of your

3. Post Notice of Violation involving radiological working radiation exposures, and conditions, proposed imposition of civil penalties and or*

(b) Your employer must advise yo9 annually of you-ders. This document may be examined exposure to radiation.

4. Provide adequate radiation safety training to you, in-cluding training in the use ead handling of radiation pro- BSPECTIONS ducing devices. as appropriate. All licensed or registered activities are subject to inspection by the Department of Social and Health Services or its duly authorired representatives. In addition, any worker or repre-YOUR RESPONSIBILITY AS A %ORKER ,

You should familiari,e yourself with those provisions of the sentative of workers w ho believes that there is noncompliance with Chapter 70.98 RCW, the regulaticns issuus thereunder, Department of social and Health Services regulations, and or the terms of the employer's license or registration with the operating procedures which apply to the work you are regard to radiological working conditions in which the engaged in. You should observe their provisions for your own protection and protection of your co-workers. work" is engaged, may request an inspection by sending a notice of the alleged noncompliance to the Departmen' of Social and Health Services. The request must set forth the WHAT IS COVERED BY THESE RFCULATIONS, specific grounds for the notice, and mast be signed by the u

1. Limits on exposure to radiation and radioactise material worker as the representative of the workers. During inspec-in restricted and unrestricted arcaw lions. Department inspectors may confer in private with

2. Measu~res to be taken after accidental espmure; workers, and any worker may bring to the attention of the

3. Personnel monitoring surveys and equipment; inspect rs any past or present condition which he believes

4. Caution signs. labels, and safety interlock equipment;

[b

5. Exposure records and reports;

6. Opiivns for workers regarding Department inspections; 7 Performance standards for x ray equipment; and INQUIRIES

8. Other related matters. Inquiries dealing with radioactive materials may be directed to the Department of Socia! and Health Services. Health REPORTS ON YOUR RADIATION Services Division Radiation Protection, Mail Stop LE-13, EXPOSURE HISTORY Olympia, Washington 98504, Telephone (206) 733 44gl. In-

l. The Department of Sodal and Halth Services regula. quiries dealing with x ray machines and facilities may be tions require that your employer give you a written re. directed 'o the Department of Social and Health Services, port if you receive an exposure in excess of any Radiation Protection, Mail Stop B17-14, 217 Pine Street, Scattle, WA 98101; Telephone (206) 464-6840.

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POSTING REQUIREMENT ^ TE..~ -_-

l ~ ','t r Copics of this notice must be conspicuously posted in a sufficient number of places

( where employees are employed in activitics licensed or registered pursuant to Chap-ter 40216 WAC and Chapter 402 22 WAC, by the Department of Social and Health ff Services. Radiation Protection. to permit employees working in or frequenting any portion of a controlled area to observe a copy on the way to or from such an area.

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eRMS 98 44 (Rev ,1 SM QA A 7 e6 8DW J M3 /

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Washington StateUniversity Nuclear qadiation Center, Pullman, Wasnington 99164-1300 / 509-335-8641 D MEMORANDUM TO: David Barbee, Gary S. Collins and B. Srinivasan FROM: Bill Wilson M d W - 4 DATE: Febraary 10, 1989

SUBJECT:

Synopsis of current status of the 60 Co source deliberations I have been in contact with the Nuclear Regulatory Commission people in Washington, DC and was informad that the Federal Government and the State of Washington gre in the process of making some decisions relevant to the Co sources stored in the reactor pool which were recently received by WSU as a gift from Nortup. The deliberations can be broken down into the following areas:

1. Jurisdic-ion - Do the sources fall under Federal or State jurisdiction? The Federal pecple in charge of the WSU reacter license have made the determination that the Stata should have primary jurisdiction. This determination. however, has not been approved by the C mmissioin management or Commission legal staff. Cnce a final-decision is approved by the Commission management and legal staff, that decision will be forwarded to the State and then on to WSU.

2. Ac uisition - During the process of acquiring the sources frcm Northup, did WSU fulfill all the Federal and State require =ents for the acquisition and shipment of such scurces? There do not appear to be any direct regulation violations in this area.

3. Safetv -

Were all the operations involved with transferring the sources to WSU, including placing the sources in the reactor pocl, done in a safe and competent manner and were all the require =ents of the applicable regulations followed? There does not appear to be any significant problem in this area.

4. Suitabilitv - Do the scurces meet all the requirements of ANSI Standard N542-1977 for Category III sources stored or used in the reactor pool? This is the real crux of ..

the situation involving the sources, if the sources are not suitable, WSU will have to remove them from the m reactor pool and store them elsewhere or dispose of them. i bl

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(cont.) The Commission people from Washington, DC looking into the question have made a site visit to Mr.

J.C.

Shepard's facilities in California to check out the certification question. I was told that t the present documentation from Mr. Shephard does not provide complete evidence that the sources meet the requirements of the Standard. I was also told that Mr. Shephard indicated to the Commission may show that the sources meet the standard.

that he had additional documentation that The commission did not look at the additirnal documentation but rather has formulated a series of questions that will eventually be sent to WSU once the jurisdiction question is resolved. I presume this means that WSU will, in all likelihood, have te pay Mr. Shepard to provide the additional documentation that he has and/or answer the questions pesed by the Commissiion in the area of certification of the sources, u

5. Ucending the gan=a irradiation facility Ln the reactor pool. If the sources ar2 found to meet the requirements of :1542-1977, then using the sources to upgrade the gamma irradiation facility is possible. The upgrade procedure would require submission of appropriata documentation to the Federal Government or State, whichever agent is determined to have jurisdiction. The upgrade documentation analysis and detailed drawing of the upgraded pool would need to include a detailed hazard irradiator and associated control and safety systems. ~

Such documentation wculd need to be reviewed and approved by the Reactor Safeguards Committee and the Radiation Safety Committee if the sources fell under State jurisdiction.

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. StateUniversity Office of the Vice Provost for Research and Dean of the Graduate School Pullman, Washington 991641030 / 509 335-3535 March 3,1989 Mr. Arden C. Scroggs Radiation Health Physicist Department of Social and Health Service Olympia, WA 98504 4 095 ,

Dear Mr. Scroggs:

Thank you for your letter of January 23,1989 and your thoughtful analysis of organizational and operational issues connected with our Radiation Safety Office (RSO). I am aleased that ro items of noncompli .nce wen: noted as a result of your recent visit; however, we

1 ave been very concemed about the issues of communication and cooperation in the RSO as outlined in your letters to me and to President Smith.

Since your visit we have taken several steps to remedy the communication and cooperation issues. Initially, this involved visits with each of the staff members, extenrNe discussions with the Director, Dr. B. Srinivasan and the Chair of Radiation Safety Commit:r:, Dr. Tom Okita . Our .

deliberations also included communicat;ons with several faculty served by the RSO.

As a result of.these activities, we are committed to the following course cf action:

1. A new Director of the RSO will be recruited and hired effecti e August 1,1989.

2. Dr. William Rayburn (Associate Vice Provost for Research) and.I will supervise a planning effort over the next three months which shsuld result in :

a. /c calargement and improvement in office space allocated to the RSO.

b. A reevaluation ofjob descriptions with possible reclassification of staff members c A thorough eva!uation of personnel needs of RSO.

d. An evaluation of chain-of-command and reporting functions of the RSO.

During the planning effons and the hiring of a new director, we expect to involve fully the present st.ff r .d engage in discussions with staff members of the NRC and the University Health and Safety D:nanment. We believe that the results of these efians will be a safe, compliant and

! smooth run .ing Radi:. tion Safety Office at WSU.

. Fo'.!- 1; r e responses to the specific recomm:ndations made in your letter of January l 23,1980. a c huGngs D., E. and F:

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lte m D, She in:inerator op. rator is provided with a dosimc:er. Also, a dosimeter has been l placed N 1. c.:. cf temporary storage (before incineration) of radioactive materials, in the mein *.n or hhg. l il i

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Item D.2. Thyroid and nrine tests for the incinerator operator, at quarterly intervals, will be given. We have completed such tests for de first quarter of 1989.

Item D.3. A special area, marked with pmper signs and separated by rope barrier, has been set aside on the southeast side of the incinerator building, for temporary s+orage of radioactive materials awaiting incineration. .

Item D.4. The top inside portion of the incinerator stack was monitored using penable survey instrument as well as by swipe samples. The survey showed that removable radioactivity as well as the radiation dose were close to back ground levels. The results are available for inspection.

Item D.5. Procedures are being developed that will be f llowed for the disposal of ash at the saritary landfill site. 'Ihese procedi es will take into account proper disposal methods for the ash in order to minimize radiation exposure to operation personne; and to achieve tbc least impact on the environment. These procedures can be inspected at the time of your next visit to the site.-

Item E. The semiannual visits by RSO staff to the off-campus areas will be implemented to carry out rad.iation surveys and to provide other required services (transportation of radioactive wastes, radiation safety instruction etc.). In the first quarter of 1989, the Radiation Safety Offic r visited the Puyallup Center to offer instruction in radiation safety, survey the laboratories and provide guidelines for safe storage of radioactive wastes.

Item F. We feel that the Radiation Safety Committee minutes have represented accurately the contents of the business transacted 2. the meetings. However, beginning in Februuy 1989, we are taping all meetings and making extraordinary efforts to assure that the minutes reflect completely the course of all Radiation Safety Committee meetings.

I tmst that you will contact me if you have further concems or suggestions regardmg rcdiation safety at WSU.

" hank you once again for recommendations on our Radiadon Safety Office.

Kind regards.

Sincerd) 0' aVW obert V. Smith, Ph.D.

Vice Provost for Research and Dean, Graduate School pc: President Samuel H. Smith pDr. B. Srinivasan, Director, RSO Dr. Tom Okita, Chair, Radiation Safety Committee t -

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Washington 7 '?Eo Rebh y StateUniversity Nuclear Radiation Center. Pullrnan, Washington 9916[f4C)op E 1 March 10, 1989 Alexander Adams, Jr.

Project Manager Standardi:stion 6 Nor-Power Reactor Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulat(,ry Commission MS KF1-11H3 Washington, DC 20555

Dear Mr. Adams:

Over the past year since Dr. Roy Filby resigned as Director of the Radiation Center to become Chairman of the Department of Chemistry and Dr. David Barbee ,

of the Vet School was appointed Interim Director, a number of problems have occurre:d at the Radiation Center. My health is deteriorating due to a y

medical problem that is significantly exacerbated by stress and thus I will be retiring on 7/1/89.

It is not clear to me at this point intirewhatresponsgilitiesIhavein relation to the requirement; of T.S. 6:10(3)C 6 D. The Co source and other problems may be viewed as be'ng directly related to the manner in which the -

Center is now being managed. You might want to call Dr. Filby at 509-335-3331 before calling me at 509-335-8317 with any advice. He can give you his view of the situation. He is now a member of the Reactor Safeguards Coraittee.

Sincerely, SVf s . Whwn K.E. Wilson Associate Director Enclosure KEK:cre l

0 h hSO ,

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1. I LWashington-  !

StateUniversity Nuclear Radiation Center, Fullman, Washington 99164 1300 / 509 335-8641-MEMORANDUM To: David Barbee, R.V. Smith and Reactor Safeguards Committee FROM: Bill Wilson N d #/V,./q DATE: March 9, 1989

SUBJECT:

My retirement and its impact on the Radiation Center-My position at the Radiation Center has been one involving long hours and lots of pressure and stress over a long period-of time due to the nature of a nuclear reacto'r operation. The impact of the job over a 20-year pariod, especially the' increased htress over the past two years, has had a significant impact on my health and my wife and family have prevailed upon no to retire from full-time employment un July 1, 2989. -

For many yeurs I have - been -arranging things so that I could retire on or after 10/1/86 when my service to the State, plus military service, equaled f' years. I . spent ten years in various management positions at the University of Washington reactor and the .-past 20 years in a management position at~ the Washington State University -TRIGA reactor. I have been' eligible to retire .under pERS I since 10/1/86. I was considering retirement in 1988 but -_ late in the Winter-of 1987.

I elected to continue my employmont at the Radiation Center.in deference to, the impact my retirement - - would have upon ' the'- -

staff of the Center (overriding my - personal . interests) due to

' the eminent possibility of decommissioning or _ refueling. It is now apparent that these activities will not'take place for a few years beyond - the - time I - am willing.- to work full-time because of health and p -sonal-considerations. -Accordingly, I ir. tend to retire - from tall-time employment- as previously-L stated above at the end-of June, 1989.

I will consider: helping to lessen the impact of my retirement-on. the Radiation Center by: Working part-time as is permi.tted -

under , the State Retirement- System regulatione. Tne wuximum that I would be allowed to work-is~40% (tv days a week) and'I -

I_

- would not desire toz do even this for more than about a year,  !

depending on my health. Such an arrangement should1 allow my, replacement to be hired and qualified while still meeting all; the staffing requiremants-of the reactor license'. l l

l Barbec, Smith & Safeguards committee  ;

March 9, 1989 Pagn.

WSU and the Radiation Center have one of two formidable tasks which must be completed in the near future. The fuel in the reactor must be changed from HEU to LEU fuel or, if the Administration so chocses, the facility decommissioned.

Either of these options will require a very experienced and SRO licensed reactor manenment person in adclition to the Reactor r1pervisor. These operations will require a thorough understanding of the Federal regulations as well as the requirements in the facility license and will involve quality assurance considerations, safety analysis of each major operation and criticality considerations. Recently, the Federal government made changes in the regulations concerning decommissioning planning for all non-power reactor s. Before July 26, 1990, WSU must rubmit a prelimirary decomissioning plan, including: 1) a cost estimate for decommissi.)ning, 21 a statement indicating the method by which the funds will ce provided, and 3) a method of periodically adjusting the cost estimate. The government is essentially forcing all non-power reactor owners to realistically look at the costs of decommissioning and to set up a mechanism or fund to cover the cost of this possible eventuality. I recently received a cost proposal for decommissioning the WSU reactor from the Nuclear and Advanced Technology Div ision of Westinghouse that will enable WSU to file the required information.

Historically, the Directer of '.he WSU Radiation Center has been an faculty member with a PhD in physical science and with a number of years experience in nuclear science research. The ANSI standard for the selection and training of perschnel at rerearch reactors does not givc specific requirements for the Level 1 person or director but' indicates that he should be a very experienced senior person. One of the unwritten rules in dealing with the Nuclear Regulatory Commission is that they will never, .naver let you decrease a specified requirement or self-imposed one once establish.d. Thus, I am not certain how the Commission will view ta permanent appointment of a director who is not a senior faculty member with a PhD and a number of years of nuclear science experience.

Another point that must be taken into concideration is that in 1969 when I came to work at the WSU reactor there were also two other nuclear engineers on the staff of the facility.

Thus, the number of professionally traine.i nuclear engineers vith extensive research reactor experience has dropped from three to one and is about to drop t- zero. Obviously, this will not be acceptable to the Commission and probably will be viewed as a violation of the facility license. A professionally trained nuclear engineer with research reactor

t Barbee, Smith, Safyguards Committee March 9, 1989 page 3 experis'm 6 thus must be hired to replace me as soon as lu

. possible.

The problem that WSU will encounter in hiring someone to replace me is that the pool of qualified people with the requisite acacemic training and research reactor experience is very, very small. I doubt very much that WSU will find a qualified person to replace me who will come to work at WSU unless WSU offers that person the director's position. The nunber of people entering nuclear engineering programs has significantly- declined in the past ten years and the demand for experienced nuclenr people at nuclear power plants has risen recently. There are numerous open faculty positions in the Nuclear Engineering programs of various schools and the University of Texas has he a hard time obtaining .a director for their new TRIGA N actvr facility. Thus, I highly

. recommend that considere un be sericusly given to collapsing the functions of the Direcus; and Associate Director into one full-time position and that an appropriately qualified person ce hired for the combined job. Such a person would need to be qualified and experienced in the areas of reactor physics, reactor operations and neutron activation analysis. This person would also need to obtain an SRO license for the WSU TRIGA reactor and meet the experience requirements of the ANSI standard for such positions. Also, this person should have good managerial skills and get along with the staff of the Center. The need for both a director and associate director no longer exists at the Center since the size of the operation and the number of faculty and staff at the Center has decreased by about a factor of two over the past ten years.

A nuclear reactor is not a toy but rather a very complex systen an'd refueling the core with a new type of fuel is a complicated task. The design of a new core is not a task for reactor operators or senior reactor operators but requires an experienced nuclear engineer. The original TRIGA core was installed by General Atomics and I have redesigned the core-arrangement a number of times since then, including shifting to a mixed core of Standard'and FLIP fuels. Over the years I have developed a computer code system to simplify the design task. However, it takes someone experienced in nuclear

-reactor physics and core design at least at the MS level to operate the code and to understand its c.,utput . The seven neutron energy group two-dinensional neutronic code that is used to simulate the WSU TRIGA reactor requires 200K of memory space on the University IBM mainframe comput.er to run and produces a pile or output one inch thick. A new library of cross-section data will need to be added to the code fo- the

4 Barbee, Smith, Safeguards Committec 4 March 9, 1989 Page 4 new LEU type fuel and calculated on a new core made with this nett data. The reactor license contains a number of constraints on the reactor core related to safety that nust be evaluated for each new core. The computer code significantly helps evaluate the safety-related parameters as voll as predicting the performance of the cors.

WEW: crc r

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MEM0RANDUM TO: Reactor Operating Staff ,

FROM: Roy H. Filby, Director [

DATE: October 6,1981

SUBJECT:

Administrative Procedures The management policies of the WSU Nuclear Radiation Center relating to the administration and operation of the WSU TRIGA reactor are set forth in the attached Administrative Procedures. The administrative procedures are designed to supplement the Standard Operating Procedures and are in-tended to clearly define the administrative requirements, responsibilities, and authority within the Reactor fueratirg Group.

RHF:efm ,

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1 W.S.U. NUCLEAR RADIATION CENTER Administrative Procedure RESPONSIBILITIES AND AUTlIORITY OF REACTOR OPERATING STAFF I. Ultimate Resconsibility The ultimate responsibility for the safe operation of the WSU TRIGA Reacter located at the Radiation Center is the Licensee, which is Washington State University. The university administration delegates this responsi-bility through the Graduate School to the management of the Radiation Center. Changes in the management of the Radiation Center shall be reviewed by the WSU Reactor Safeguards Committee. The responsibility of the Radiation Center management shall include, but not be limited to:

1) assuring the safe operation and maintenance of the W.S.U. TRIGA Reactor and associated equipment.

2) assuring that the facility is operated in accordance with all appli-cable state and federal regulations as well as the facility license, and

3) assuring the enforcement of rules for the protection of personnel from excessive exposure to radiation.

The responsibility and authority delegated to the Radiation Center Management for the safe oceration of the reactor is vested in the most senior licensed member of the Center Management. At the WSU Radiation Center, this individual is the Associate Director.

II. Associate Director The Associate Director shall be a licensed senior reactor coerator, shall assist the Director in the general direction of the Nuclear Radiation Center and assume the responsibilities of the Director in his absence and - - - -

shall have the following listed respons1bilities and authority:

1) managing the reactor operations group and administrative group,

2) being responsible for assuring the safe operation of the W.S.U. Reactor in accordance with apolicaole state and federal regulations and the facility j license.

IW.S.U./NRC Administrative ProcedureL

.Page-2 3); approving all procedures land changes of procedures, ,

4)- reviewing and approving the procurement of equipment and supplies for the operation of the reactor,

5) recommending to the Director the hiring and promotion of personnel as required,

6) functioning as the training coordinator and assuring that the proper training is conducted.:that the staff is properly qualified as speci-fied by-the requalification plan, and assuring _that the required -

training records are maintained,

7) handling all correspondence with the U.S. Nuclear Regulatory Comis-sion,

8) -maintaining a Special Nuclear Materials inventory system to meet-the requirements of federal regulations and the facility license.

This includes.the preparation and submission of Material Status' Reports and S.N.M. transfer reports, .

9) approving all-_ physical changes in or modifications' to the reactor core, reactor instrumentation, or other reactor related facilities and equipment,

10) reviewing and approving the safety analysis,for proposed 50.59 changes.and forwarding them to the' Reactor Safeguards Committee for-their review,

'll) ~ taking part in the designing of experiments for 'the reactor to

- ensure that they will be operable, safe, and_will not interfere with the operation of the reactor,-

i 12) . developing and submitting special plans required by state and fed -

eral regulations including -1) physical security plan, 2) reactor operator requalification plan,- ard 3) 2mergency response plan.

., l.~, , , , ._a.-_ w. .- _ . . ,

r h.S.U./fiRC Administrative Procedure Page 3 ,

13) submitting renewal requests to the N.R.C. for reactor operators and senior operators, and

14) preparing applications for facility license amendments and changes to the Technical Specifications of 'he reactor.

III. Reactor Supervisor The Reactor Supervisor shall be a licensed senior operator and shall have the following listed responsibilities and authority:

1) supervising all the personnel in the reactor operations group,

2) developing and maintaining operating procedures for assuring the safe operation and maintenance of the W.S.U. reactor in accordance with applicable state and fedaral regulations and facility adminis-trative procedures and assuring that the applicable procedures are adhered to,

3) reviewing Health Physics surveys for adequacy and initiating addi-tional surveillonce as required,

4) maintaining and assuring facility security in accordance with the i the physical security plan, includinosecurity training for staff 1

and police,

5) assuring that R.O. and S.R.0. operational and supervisory requali-fication requirements are mtt, l

6) developing and maintaining a record system on reactor operations as required by Facilities License R-76 and the facility administra-l tion procedures as listed below:

a) Reactor operating records, including power levels and periods of operation at each power level A

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%k W S'u St e c/

(7) offsite inventories and transfers (8) fuel irventories and transfers (9) fac.lity radiation and contamination surveys (10) r' adiation exposures for all personnel (11) updated, corrected, and as-built drawings of the facility Reporting Requirements ,

In addition to the requirements of applicable regulations, and in no way sub-stituting for those requirements, reports shall be made to the NRC as follows:

(1) A report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and telegraph _to the Region V Office of Inspection and Enforcement with a copy to the Director of Reactor 1.icensing, of (a) Any accidental release of radioactivity above permissible limits in unrestricted areas whether or not the release resulted in property damage, personal injury, or exposure; (b) Any violation of the safety limit; (c) Any reportable occurrence as defined in Section 1.1, " Reportable Occurrence," of these specifications.

.(2) A report within 10 days in writing to the Director, Office of Nuclear Reactor Regulation USNRC, Washington, D.C. 20555, with a copy to the NRC Region V Office of Inspection and Enforcement, of (a) Any accidental release or radioactivity above permissible limits in unrestricted areas whether or not the release resulted in property damage, personal injury, or exposure. The written report (and, to the extent possible, the preliminary telephone or telegraph report) shall describe, analyze, and evaluate safety irrplications, and out-line the corrective measures taken or planned to prevent reoccurrence of the event, (b) Any violation of a safety limit, (c) Any reportable occurrence as defined in Section 1.1, " Reportable Occurrence," of these specifications.

(3) A report within 30 days in writing to the Director, Office of Nuclear Reactor Regulation, USNRC, Washington, D.C. 20555, with a copy to the NRC Region V Office of Inspection and Enforcement, of (a) Any significant variation of measured values from a corresponding predicted or previously measured value of safety-cornected operating characteristics occurring during operation of the reactor, (b) Any significant change in the transient or accident analysis as described-in the Safety Analysis Report, (c) Any A nifican Q nges in facility organization, 34

4 (d) -Any observed inadequacies-in the implementation of admi_nistrative or procedural co71tTois..

(4) A report within 60 days after completion of startup testing of the reactor (in writing to the Director, Office of Nuclear Reactor Regulation, USNRC, Washington, D.C. 20555) upon receipt of a new facility-license or an amendment to the license authorizing an increase in reactor power level describing the measured values of the operating conditions including:

(a) An evaluation of facility performance to date in comparison with design predictions and specifications, (b) A reassessment of the safety analysis submitted with the license application in light of measured operating characteristics when such measurements indicate that there may be substantial variance from prior analysis.

(5) An annual report within 60 days following the 30th of June of each year (in writing to the Director, Division of Licensing, USNRC, Washington, D.C. 20555) with a copy to the NRC Region V Office of Inspection and Coforcement providing the following information:

(a) A brief narrative summary of (1) operating experience (including experiments- performed), (ii) changes in facility design, performance characteristics, and operating procedures related to reactor safety and occurring during the reporting period, and (iii) results of sur-veillance tests and inspections; (b) Tabulation of the energy output (in megawatt-days) of the reactor, hours reactor was-critical, the cumulative total energy output since initial criticality, and number of pulses greater than 1.005; (c) The number of emergency shutdowns and inadvertent scrams, including reasons for them;

_ (d) Discussion of the major maintenance operations performed during the period, including the effect, if any, on the safety cf the operation of the reactee and the reasons for any~ corrective maintenance required; (e) A brief description, locluding a summary of the safety evaluations of changes in the_ f acility or in procedures and of tests and experiments carried out pursuant to 10 CFR 50.59;-

(f) A summary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of-the licensee as measured at or-before the point of such release or

-disc"arge:

I Liould Waste--(summarized on a monthly basis)

(i) radioactivity discharged during the reporting period

- total estimated quantity of radioactivity released (in curies)_,

35

- .. - . .- - _- -- .~ .- _ - - . - - . -

3 6.5.2 Corposition and Qualifications .

The RSC shall be composed of at least five members knowledgeable in fields that

~

relate to nuclear reactor safety. The members.cf the committee shall; include

' one facility Senior Reactor Operator _ and.WSU faculty and staff: members designa-ted to serve on the committee in accordance with the procedure's.specified by the WSU committee manual. The university's Radiaiten Safety Supervisor shall be an exofficio member of the committee.

6.5.3 Operation ,

The Reactor. Safeguards Committee shall operate.in accordance with a written charter, including provisions for (1) meeting frequency: the full committee shall meet at least aamiannually and a subcommittee-thereof shall meet at least semiant.ually (2) voting rules (3) quorums: chairman or his designate and two members (4) method of submission and content of presentations to the committee (5) use of subcommittees (6) review, approval, and dissemination of minutes 6.5.4. Reviews The responsibilities of the RSC or designated Subcommittee thereof shall include, but is not limited to, the following:

(1) review and approval of all new experiments utilizing the reactor facility 3

(2) review and approval of all proposed changes to the facility license by amendment ard to the Technical Specifications (3) review of the operation and operational records of the facility (4) review of significant operating abnormalities or deviations from normal and expected performance of-' facility equipment that affect nuclear safety l (5) review and approval of all determinations of whether a proposed change,

-test, or experiment would consititute a change in _the Technical Specifi-cations or on unreviewed safety question as defined by 10.CFR 50 .

'(6) review of reportable occurrences and the reports filed with the

[ Commissions for said occurrences (7). review-and approval of all standard operating procedures and changes thereto (8)- biennial review-of all standard procedures, the facility emergency plan, and the facility security plan 31

_l., - _ _ . . _ _ _ . _ _ , - . -

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I l $7ATI C# WASNGTCN CEPyTMENT OF SOCIAL AND HEALTH SERVICES i C4npla, Washhstan 96504 4 95 t

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November 9, 1988 Robert 3mith, Dean TheGraduateScho)1 Washington State (lniversity Pullman, Washington 99163

Dear Dean Smith:

The purpose of this letter is to confirm our telephone conversation with your Radiation Safety Officer, b. Srinivasan, on November 4, 1988, ordering Washington State University to imediately cease further manufacture and distribution of Profesar Brian Lamb's atmospheric gas chromatographs, cesse further receipt of sealed sources for use in the pool irradiator, and to ensure that the Tritium neutron generator will not be used for research until apprapriate procedures are submitted to our office for evaluation. Dr.

Srinivasan's verbal statement of intent to comply with this order is hereby acknowledged. These actions have been taken for the following reasons:

1. On February 25, 1986, the University requested permission to conduct research and development wort on Professor Brian Lamb's atmospheric gas chromatograph. Author 123 tion was granted by Leo Wainhouse of this office, with the stipulation that this office would be notified prior to any distribution, and that NRC Fuel Cycle Directive Sa-22 would be followed before distributing the GC units. Contrary to the above, seven gas chromatographs have beer. manufactured and distributed, two of which were sent out of the country to the People's Republic of China.

2. The radioactive sources received from J. L. Shepherd & Associates for placement in your pool irradiator are of untnewn construction. Althougn a safety evaluation was performed by Dr. Srintvasan prior to receipt of these sources, he was unable to assure us that the sources were evaluated for water imersion. Therefore, we have serious concerns for the poten-tial contamination of the pool, the pool reactor, and the containment building. Sealed sources used in Category 3 pool irradiators must meet l

ANS! Standard N542-1977, rurthermore. Todd Tillinghast of Vallecitos Nuclear Center stated that the 5,000 curie GE source, serial number GEC-JCS-9147, which they encapsulated prior to delivery to you, was not evaluated for compliance with the ANSI standard.

t

3. Contrary to' your Radiation Safety Office's agreement with us that no research work would be conducted with the Trit'am neutron generator until the proper procedures had been received and approved t/ our office, our recent inspartion of the liniversity thawad that ratearch wnrk had been conducted using the Tritium neutron generator.

F- .

..,,3

• R$bertSmith, Dean-Page Two l

1

. i Other items of concern from our compliance inspection of Octo^ber 10-13, 1988, will be documented in a formal compliance letter to follow within-the next 20 dayst however, pursuant to this letter, I am requesting that the University provide- the following material to me no later than the close of business, November 18, 1968: .

1. An inventory of-all sealed sources received from J. L. Shepherd & Associ-ates and _ placed in your reactor pool, listing the man'ufacturer, vnodel '

number, activity, and serial-number, where applicable. *

2. A copy of the Radiation Safety Officer's safety evaluation for- all the above saaled sources. *

3. A list of all the firms which received Prt*essor Lamb's gas chromato-graphs, and copies of their current radioactive materials licenses.

4. Copies of all Radiation Safety Committee meeting minutes in which. the manuf acture and- dictribution of the 003 chromatograph units, _ acquisition  ;

of sealed sources for the pool ir,2diator, and/or use of. the_ Tritium neutron generator for research were discussed. *

/= issues we have rait*d in onr Oettber 10-13, 1969 _ inspection of your lir. nse, and in this letter concerning additional issues, are most serious,- R requiring an imediate followup inspection and~ review of ; radiation safety practices and the activities of the University's Radiation Safety Committee.

My staff will be in touch with you regarding acceptable dates for our return visit. . -

If ycu have questions, feel free to contact me at' (206) 753-3468, -

or Gary Robertson of my staff at (206) 753-3351.

Sincerely, H

. R. St ng, Chief IRS:tf

_ Office of Radiation Protec{ ion 1

)

cc: B..Srinivasan '

Radiation Safety Officer W

415- TV3 -9?*

• U.S. NRC, Region V .

j i Richard McCartan Assistant Attorney General ,

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Washington

. State University 7 Institute of Biological Chemistry, Pullman. 'NA 99~6d-63a.:

sT 509 335-3412 FAX 509-337fA3

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TO: Mr. Don Elting and the Radiation Safety Office Staff FROM: T.W. Okita, Chairperson, RSC J. id DATE: 7 April 1989 During the deliberations of the April 6 meeting of the Radiation Safety Committee it was noted by the Chair that several memos were sent by RSO staff members to.

University faculty which in nature set policy by your office. In one instance,- one memo (dated March 22,1989) to Ron ande was fowarded without prior approval or knowledge by your immediate supervisor. It was obvious to the Radiation Safety Committee that this memo created a great deal of misunderstanding between the RSO staff and R. Sande, a situation which should have never occurred. Irrespective of this point, it is totally beyond the responsibilities of staff members to foward official written communications to University faculty, personnel, or relevant state agencies. The University representative and spokesman for your office in business matters is the Radiation Safety Officer. In the future, please direct all University-related business communications through normal channels with the Radiation Safety Officer or his supervisor as the identifying sender with his appropriate signature on all correspondence.

cc RSC members B. Srinivasan W.R. Rayburn h

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