IR 05000002/1997001
| ML20137K381 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 03/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137K356 | List: |
| References | |
| 50-002-97-01, 50-2-97-1, NUDOCS 9704070020 | |
| Download: ML20137K381 (14) | |
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U.S. NUCLEAR REGULATORY COP 911SSION
REGION III
Docket No: 50-002
. License No: R-28 Report No: 50-002/97001(DNMS)
Licensee: University cf Michigan Facility Name: University of Michigan Ford Nuclear Reactor-Location: Ann Arbor, Michigan Dates: February 24-28, 1997 Inspectors: T..D. Reidinger T. M. Burdick'
Approved by: G. L. Shear, Chief Fuel Cycle Branch
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Executive Summary j University of Michigan Ford Nuclear Reactor ,
Report No. 50-002/97001(DNMS) ;
This routine, announced inspection included aspects of organization, periodic ,
and special reports, and operations and maintenance (39745); operations and '
maintenance procedures (42745); requalification training (41745); surveillance (61745); experiments (69745); radiation controls (83743); environmental i protection (80745); design change, audit, and review-(40745); emergency '
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preparedness; fuel handling activities -(60745); transportation activities ;
(86740); and review of licensee reports (90713).
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Oraanization (39745) ,
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. * The University has been studying the viability of continued operation of the Ford Reactor. During the interim, using a temporary appointee as ,
Reactor Manager, the organizational structure and assignment of responsibilities were as specified in Technical Specifications (T.S.). >
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(Section 1.0)
Operations and Maintenance (39745)
- Reactor operations and maintenance were good and in accordance with the >
license conditions and T.S. requirements. Logs and records were adequate. (Section 2.0)
Procedures (42745)
- The licensee had approved procedures to safely conduct reactor j
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operations, maintenance, experiments, surveillance testing and l i
instrument calibrations in compliance with T.S. requirement (Section 3.0)
i Recualification Proaram (41745). Surveillance (61745). and Periodic and Special Reports (90713)
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- No concerns were identifie (Section 4.0)
Experiments (69745)
- The licensee reviewed and approved a new experiment involving mercuric l oxide irradiation. All experiments were conducted in accordance with approved procedures and satisfactorily documented in the reactor operations log. (Section 5.0)
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Radiation Control (8?2in e The radiation protection program was effective in protecting the staff ;
and public. The licensee took assertive action in response to a !
researcher's inadvertent entry into a high radiation area while !
conducting an experimen (Section 6.0) {
Environmental Protection (80745) l e Airborne releases were within the regulatory limits. Radioactive waste {
accumulations were adequately stored and shipped. (Section 7.0) j Audits and Reviews (40745) ,
e Safety Review Committee (SRC) meetings were conducted within the i specified time perio l
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- A radiation protection program audit was particularly rigorous in :
identifying good issues across a wide variety of plant areas and
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procer,se (Section 8.0) !
Emeraency Preparedness (82745) !
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- Emergency Plan exercises and training were conducted satisfactorily, i (Section 9.0) {
Fuel Handlina (60745) l
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e fuel handling procedures were last reviewed for use five years ago but will be reviewed prior to use later this yea (Section 10.0) ,
t Transportation (86740) i e Radioactive material shipments were processed under the University broad scope license. (Section 11.0) i
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DETAILS 1.0 Organization Inspection ScoDe (39745)
The inspectors reviewed Technical Specifications (T.S.) and the Safety Analysis Report (SAR) related to organization and staffing and compared the requirements with current condition Observations and Findinas The inspectors determined that the organizational structure and assignment of responsibilities were as specified in T.S. 6.0 with the interim appointment of an Acting Reactor Manage Although, no safety impact on reactor operations was noted, the reactor staff was feeling the impact caused by the loss of several licensed members recently. They scheduled three replacement operators to retake NRC license examinations that they had previously failed, immediately following this inspectio The membership of the Safety Review Committee (SRC) was in accordance with T.S. and the SA The inspectors verified minimum staffing requirements were met during reactor operation Facility Walk Down The control room, pool floor, basement, tank rooms, and beam port floor areas were adequately illuminated and generally clea Substantial amounts of low level radioactive resin waste had been properly disposed of since the last inspection. Potentially contaminated tools and equipment were adequately store ' Conclusions Compliance with T.S. requirements and observed reactor facility material conditions were goo .0 Operations and Maintenance Activities Inspection Scope (39745)
The inspectors reviewed the reactor operations and maintenance !
logs and observed ongoing reactor operations to determine i
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compliance with Operating License Condition 2.0. and the requirements in T.S. 2.0 and T.S. l
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! Observations and Findinas The licensee had operated the reactor at steady state thermal
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power levels in accordance with Operating License Condition 2.C'
The-inspectors verified that the licensee was in compliance with l T.S. !
' Selected reactor operator logs from March 1996 through February 1997 were reviewed. The operator logs were well maintained. The operators appeared proficient, demonstrated good' procedural l compliance, and made appropriate log entries for the observed i perio l l
i The inspectors accompanied operators conducting several sample insertions and removals from the reactor and abservea a safet !
conscious and professional attitude, Conclusions The reactor was operated and maintained in accordance with the- )
reactor's license conditions, safety limits and limiting conditions for operation. The licensee's logs and records i satisfactorily documented reactor operations and maintenance ;
activities. Operators were observant and systematic in both ;
operations and experiment activitie ;
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3.0 Procedures n Inspection Scope (42745) I The inspectors reviewed the licensee's written procedures for
operating and maintaining the reactor, performing surveillance activities, conducting experiments, and shipping radioactive
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materials to determine compliance with the requirements in .1 requirements.
i i Observations and Findinas _
The inspectors identified minor discrepancies to the licensee for correction. Procedures were adequate.
! Conclusions
- The licensee had approved procedures to sufficiently conduct reactor operations, maintenance, experiments, surveillance
, testing, instrument calibrations, and shipping in compliance with
- T.S. requirements.
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I 4.0' Requalification Training, Surveillance and Periodic Reports- }
a.1... Inspection Scope (41745) f
. . l The inspectors reviewed the reactor operators' requalification . !
training program to determine compliance with the requirements in [
10 CFR 19.12 and 10 CFR 55.5 l
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b.l. Observations and Findinos The licensee enrolled t*:o operators' into an accelerated remedial !
training program ba:;ed on their weak written examination ;
performance, j c .1'. Conclusions l An adequate training program was being conducted. Adequate !
training records were being maintaine !
Surveillance !
! Inspection Scope (61745) )
The inspectors reviewed selected surveillance test documentation ;
and observed activities to determine compliance with the requirements in T.S. Observations and Findinas The inspectors observed routine swipe surveys of the reactor la Survey results indicated backgroun Conclusions )
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All reactor surveillance tests had been completed and documented at the required frequencies, and the surveillance test results met
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T.S. requirement Review of Periodic and Special Reports ,
i Inspection Scope (90713)
The inspectors reviewed the licensee's submittal of reports and 4 notifications to the NRC to determine compliance with the !
requirements in.T.S. !
- Observations and Findinas
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The inspectors noted nothing unusual during the revie ,
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i Conclusions The licensee had submitted required reports to the NRC in accordance with T. S. requirement .0 Experiments.
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l Inspection SCoDe (69745) l
The inspectors reviewed the licensee's program to control and conduct experiments performed in the reactor to determine ;
compliance with the requirements in T.S. 3.6. and t Observations jwifigdinas >
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The inspectors reviewed a proposed experiment that was reviewed and approved by the SRO. The inspectors observed that insertion :
4 and withdrawal of mdterial from the reactor irradiation facility was conducted satisfactoril j
- Conclusions j All reactor experiments were conducted in accordance with properly reviewed and approved procedures and satisfactorily documented in the reactor operations log.
1 Radiation Control
- Inspection Scope (83743) l
- The inspectors reviewed the radiation protection program to t
. determine compliance with the requirements in 10 CFR Part 20 and T.S. 3.2, 3.5, 3.6, 4.5, 4.6, and 6.1.
' Observations and Findinas The inspectors reviewed the licensee's actions in response to a ;
researcher's inadvertent entry into a high radiation area while ;
conducting an experiment with a beam port. The researcher had not 1 taken precautions to verify dose rates prior to entering the 1 affected area. The researcher's dose was small because the beam )
width was highly collimated. The licensee determined his maximum dose would not exceed 38 mrem. His badge was immediately processed and read less than 10 mrem. The licensee removed the researcher's access to the reactor until they satisfactorily retrailwd him in access control procedures. A program was established that required the researcher to surrender his beam port key to the control room whenever he requested draining of the port. Ultimately, the licensee decided that the beam port would not be used for further research until they installed a more positive indication of beam port status and ieconfigured the
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barricade. The design and procurement of parts were ongoing during the inspection. The inspectors concluded that the redesigned indication and reconfigured barricade should be effectiv The inspectors observed that students or researchers could access the reactor basement, a high radiation area, through a steel door which led to a vertical pipe chase. Although the pipe chase was not a routine access to the basement, the staff installed a hasp ,
and padlock and posted the door immediatel The inspectors reviewcd two incidents involving dosimetry monitoring last Fall. One occurred when a reactor operator dropped his film badge onto the reactor and recovered it several -
hours later. He wore his finger ring dosimeters for the rest of his shift. At the end of his shift he returned the badge to the HP technician who issued him a new one. When the dosimetry vendor processed the exposed badge at the end of the regular period, they notified the Radiation Safety Officer (RS0) of the high exposur ,
(500,250 mrem)
Unaware that the HP Technician had the relevant facts of the situation, the reactor health physicist (HP) interviewed the ,
operator and learned of the event. Communication between the HP l technician and the llP regarding the event appeared ineffectiv '
The inspectors reviewed the licensee's dose reassessment of the operator and found it to be conservative and consistent with previous exposure. They assigned him 70 mrem which was slightly above his typical monthly dose of 65 mre The HP identified the second event when he reviewed the exposure reports for two successive months and noted that a licensed staff member had received 50 and 140 mrem respectively when his normal exposure was usually less than 10 mram. He interviewed the individual and learned that, unlike any time in the past, the person had stored the dosimeter in the workshop area which was directly above the cobalt 60 irradiator facility instead of a customary storage location for dosimetry. The employee stated that he had been t oing to determine the degree of exposure in his work are The HP cautioned him to store his dosimetry in a low dose area and to request additional environmental monitoring if neede Other than writing a report to the exposure file the HP did not discuss the event with either operations or his own managemen The inspectors interviewed both employees and determined that the licensee's accounts of both events were the same as those of the employee' The inspectors emphasized a need for effective communications regarding abnormal events and that management expectations with
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regard to dosimetry monitoring requirements should be made clear to the staff. The licensee acknowledged the concer The licensee's procedures did not require the employees to store their badges in low dose areas. The inspectors reviewed a licensee memorandum to clarify management policies regarding use and storage of personal dosimetry on February 28, 1997, and found it satisfactor Conclusioni All badged reactor personnel exposures were significantly below 10 LFR 20.1201 limit The licensee had not foreseen a need to establish explicit policies regarding the use of personal dosimetry and communications regarding unusual exposure. A written policy was developed when the inspection was conclude The licensee identified unusual exposure indications, but communications were limited and did not allow immediate intervention or corrective action by managemen .0. Environmental Protection Inspection Scope 180745)
The inspectors reviewed the licensee's program for the discharge or removal of radioactive liquid, gases, and solids from the reactor laboratory, Observations and Findinas The licensee does not routinely discharge liquid effluent but recycles it back to the reactor pool as makeu Airborne effluent monitoring records for 1995-1996 showed that the
releases were within the regulatory limit The inspectors determined that they properly stored and posted the solid radioactive waste as required prior to shipment to Barnwel Conclusions Airborne releases and solid waste disposal were within the regulatory limit .0 Audit and Reviews Inspection Scope (40745)
The inspectors reviewed the meetings, audits and reviews conducted by the Safety Review Committee (SRC) to determine compliance with the requirements in T.S. . Observations and findingi The inspectors found a recent radiation protection program audit by the RSO to be particularly rigorous. Discrepancies were noted in areas such as labeling, posting, material storage, and procedures. The licensee has committed to implementing corrective actions as warranted, Conclusions SRC meetings were conducted as required by Internal self assessment was goo .0 Emergency Preparedness . inspection Scope (82745)
The inspectors reviewed the emergency plan for the reactor laboratory, interviewed licensee employees, inventoried storage lockers, and visited the campus police dispatcher to determine i compliance with the requirements in 10 CFR 50.54(q) and (r). j Observations and Findinas !
The inspectors found that the emergency plan referred to respiratory equipment available for use although the licensee did ;
not certify most of the staff as users of the equipment nor was '
the equipment maintained. The licensee took immediate action to remove the equipment from the emergency storage locke Conclusions l
The licensee maintained the licensee's emergency program in a state of operational readines .0 Fuel Handling
- inspection Scope (60745)
The inspectors reviewed the fuel handling procedures and records at the reactor laboratory, interviewed employees, and inspected refueling tools to determine compliance with T.S. 5.5 and Department of Transportation (DOT) regulation Observations and Findinas fuel handling procedures were last updated in 1992 and will be reviewed prior to use later this yea Interviews with the staff indicated that the senior staff was familiar with the cask handling and fuel loading operation Fuel handling procedures required a special set of tools for fuel movemer.ts including a torque wrenc The licensee planned to
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- calibrate the torque wrench prior to using it in accordance with !
their quality assurance program requirement j Conclusions '
The licensee's plans to ship fuel this year will require some l preparations, i
< 11.0 Transportation of Radioactive Materials i Inspection Scope (86740) l The inspectors reviewed the licensee's radioactive materials i shipping program, reviewed logs, and interviewed employees to
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determine compliance with the requirements in DOT and NRC regulations, 49 CFR Parts 172 & 173 and 10 CFR Part 71, .
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l Observations and Findinas The licensee transferred radioactive materials to the broad scope l license for processing and shipmen The inspectors reviewed the log entries made to transfer the reactor byproduct material to the broad scope license and noted that past transfer entries were not always fully completed. The licensee identified this weakness in a recent audit and planned to j implement corrective action Conclusions The transportation program is adequately implemente l l
12.0 Persons Contacted j l
University of Michiaan
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- Ron Fleming, Director, Phoenix Memorial Lab
- Bernard Ducamp, Asst. Manager, Phoenix Lab
- Mark Driscoll, RSO, U. of Michigan The inspectors also contacted other supervisory, technical and administrative staff personnel as wel * Denotes those attending the exit meeting on February 28, 1997.
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s 13.0 Exit Interview (30703) !
The inspectors pre::ented the inspection results to members of the licensee management at an exit meeting on February 28, 1997. The licensee acknowledged the findings presented. The inspectors asked the )
licensee whether any material examined during the inspection should be considered proprietary. They identified no proprietary informatio i
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Insoection Procedures Used IP 39745 Class I Nonpower Reactors Organization, Logs,-and Records IP 40745 Review and Audits
- IP_41745 L Requalification. Training IP 42745 Procedures IP 6074 Refueling-IP 61745 . Surveillance
' IP 69745 Experiments IP 80745 Environmental Protection
- IP 82745 Emergency Plan IP 83743 Health Physics . .
IP 86740 Inspection'of Transportation Activities IP 90713 . Review of Periodic and Special Reports Items Opened and Closed
- None List of Documents Reviewed
- Safety Analysis Report Safety Evaluation Report Reactor Operating License-Technical Specifications Administrative Procedures Operating Procedures
. Maintenance Procedures Surveillance Procedures Shipping records and procedures Maintenance and Surveillance Records Emergency procedures
- Training Program Emergency Plan Dosimetry Records
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Various Reports l
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List of Acronyms Used
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ALARA As Low as Reasonably Achievable CFR . Code of Federal-Regulations CPM ' Counts Per Minute DNHS Division of Nuclear Materials and Safeguards
. DO Department of Transportation HP Health Physics
'IP Inspection Procedure mrem: millirem-NRC- , Nuclear Regulatory Commission PDR Public Document Room -
RSO Radiation Safety Officer SARL Safety Analysis Report - .i SRC -Safety Review Committee ;
TLD Thermal Luminescent Detector }
TS . Technical Specifications l
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