ML20129D906

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Insp Rept 50-156/96-01 on 960923.Violations Noted.Major Areas Inspected:Aspects of Organization,Operations & Maint, Procedures,Requalification Training,Surveillance, Experiments,Radiation Controls & Environ Protection
ML20129D906
Person / Time
Site: University of Wisconsin
Issue date: 09/23/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129D890 List:
References
50-156-96-01, 50-156-96-1, NUDOCS 9609300223
Download: ML20129D906 (20)


See also: IR 05000156/1996001

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-156

l License No: R-74

l Report No: 50-156/96001(DNHS)

Licensee: University of Wisconsin

Facility Name: University of Wisconsin Nuclear Reactor

Location: Madison, Wisconsin

Dates: August 19-23, 1996

Inspectors: T. D. Reidinger

T. M. Burdick

R. Krsek

Approved by: Gary L. Shear, Chief

Fuel Cycle Branch

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9609300223 960923

PDR ADOCK 05000156

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Executive Summary l

University of Wisconsin Nuclear Reactor )

Report No. 50-156/96001(DNMS)

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This routine, announced inspection included aspects of organization;  ;

operations and maintenance; procedures; requalification training;

surveillance; experiments; radiation controls and environmental protection;

' design change; audit and review; emergency preparedness; fuel handling

activities (IP 40750); transportation activities (86740); periodic and special

reports (IP 90713); and one inspectors identified followup item 50-156/94001-

01 (IP 92701).

Oraanization (IP 40750)

e The organizational structure and assignment of responsibilities were as

specified in Technical Specifications (TS). (Section 1.0)

Operations and Maintenance (IP 40750)

e~ The reactor was operated and maintained in accordance with the reactor's

license conditions and T5 requirements. The licensee's logs and records

satisfactorily documented reactor operations and maintenance activities.

(Section 2.0)

Procedures (IP 40750)

e The licensee had &pproved procedures to sufficieatly conduct reactor

operations, maintenance, experiments, surveillance testing and

instrument calibrations in compliance with TS requirements.

(Section 3.0)

Licensed Operator Reaualification (IP 40750)

e A satisfactory training program was being conducted in accordance with

the NRC' approved program. Adequate training records were being

maintained. (Section 4.0)

Surveillances (IP 40750)

e All reactor surveillance tests had been completed and documented at the

required frequencies, and the surveillance test results met TS

requirements. Ventilation flow tests for the reactor fume hoods were

not scheduled or conducted by the University Safety Office for several

years because of inadequate test schedules. Initial flow test records

were unavailable for review. (IFI 50-156/96001-03(DNMS)) (Section 5.0)

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Experiments (IP 40750)

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e All reactor experiments were conducted in accordance with properly

reviewed and approved procedures and satisfactorily documented in the  !

reactor operations log. (Section 6.0)

Radiation Control (IP 40750)

e Confusion and disagreements had existed between the reactor staff and

the campus radiation safety staff since 1992 regarding responsibility

for the reactor radiation safety program. The Radiation Safety Officer

(RS0) maintained that his office had no reactor health physics

responsibilities except as providing either courtesy T.S. audits or some l

health physics (HP) service on a case by case request from the reactor  !

laboratory. The Reactor Director (RD) maintained that the campus RSO

always had overall health physics oversight responsibility at the I

reactor. At the exit meeting, the licensee appointed the RSO as having  !

the oversight responsibility for the radiation protection program at the i

reactor laboratory.

Environmental Protection (IP 40750) l

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e Airborne and liquid effluent releases were well within the regulatory i

limits. The licensee installed a filtered liquid waste system to comply  ;

i with regulations for liquid releases discharged to the sewer system.

(Section 8.0)

{ Audits and Reviews (IP 40750)

, e. The University Health Physicist (UHP) failed to conduct monthly HP

1 inspections of the reactor laboratory as required by TS.

(Vio. No. 50-156/96001-01(DNMS)) (Section 9.0)

e The annual radiation protection audits of the reactor laboratory were

not detailed or technically comprehensive partly due to the lack of

ownership of the radiation protection program at the reactor laboratory.

(IFI No. 50-156/96001-02(DNHS)) (Section 9.0)

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Emeroency Preparedness (IP 40750)

e Emergency Plan exercises and training were adequate to ensure public

safety. The inspectors observed the licensee effectively implement

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their emergency plan and procedures for a public demonstration.

(Section 10.0)  ;

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Fuel Handlina (IP 40750)

e Procedures for fuel handling were adequate for reactor operations.

(Section 11.0)

Periodic and Special Reports (IP 90713)

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l e P.eq!iired reports had been submitted to the NRC in accordance with TS

requirements although the most significant radiation dose (105 millirem)

for the 1995-1996 reporting period was not included due to oversight.

(Section 12.0)

Transoortation (IP 86740)

e The transfer of irradiated material from the reactor to the broadscope

license was conducted per procedure. (Section 13.0)

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DETAILS

1.0 Organizatho

a. Inspection ScoDe (IP 40750)

The inspectors reviewed Technical Specifications (TS) and the

Safety Analysis Report (SAR) related to organization and staffing,

b. Observations and Findinas

The inspectors determined that the organizational structure and

assignment of responsibilities were as specified in TS 6. The

membership of the Reactor Safety Committee (RSC) was in accordance

with TS and the SAR.

Through log reviews, the minimum staffing requirements were

verified to have been met during reactor operations and fuel

hand, ling or refueling operations. Selected reactor operator logs

from May 1994 through July 1996 were reviewed with no concerns

identified. The operator logs were well maintained. The l

operating cycle reports accurately used data from the operator

logs to report the number of unscheduled shutdowns. The operators

appeared proficient, demonstrated good procedural compliance, and

made appropriate log entries for the observed evolutions, i.e., i

experimental sample protocol.

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c. Facility Tour

The control room, pool floor, and the beam port floor areas were

adequately illuminated, free of clutter and very clean. Fire

extinguishers in these areas and the basement had appropriate j

pressures and current inspection dates. i

d. Con..lusions

Compliance with TS requirements, SRC membership and reactor

programs was good.

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2.0 Operations and Maintenance Activities

a. Inspection Scope (IP 40750)

The inspectors reviewed the reactor operations and maintenance

logs and observed reactor operations to determine compliance with

Operating License Condition 3.A. and the requirements in TS 2.0

and TS 3.0.

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b. Observations and Findinos

The licensee operated the reactor from startup to full power and

, then to shutdown using the applicable procedures. The licensee

i operated the reactor for experiments, research, training, and

i irradiation of topaz. i

i The reactor operations logs and records were in compliance with

! the reactor's license condition and TS requirements. The licensee

l had operated the reactor at steady state thermal power levels not

in excess of 1.0 megawatt in accordance with Operating License

Condition 3.A. The inspectors verified that the reactor safety

limits had not been exceeded and were in compliance with TS 2.1.

During the annual shim safety control rod reactivity worth

determinations, the reactor shutdown margin and excess reactivity

were verified to be within TS limits. The inspectors also

verified that all of the required reactor control system

instrument channels,- safety circuits, and safety interlocks

required by the TS were tested and operable. The licensee's logs

and records. adequately documented reactor operations.

The reactor's maintenance logs and records were found to be in

compliance with the TS requirements. Safety-related corrective

maintenance performed on the reactor and operations console was .

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properly documented in the reactor's maintenance log.

The replacement of the control element (rod) timer and reactor

scram relay modifications and the related safety evaluations were

adequate. Meeting minutes indicated that the modifications,

associated procedure changes, and safety evaluations were also

reviewed by the SRC as required.

c. Conclusions

The reactor was operated and maintained in accordance with the

reactor's license conditions, safety limits and limiting

conditions for operation, and TS requirements. The licensee's

logs and records satisfactorily documented reactor operations and

maintenance activities.

3.0 Procedures

a. Inspection Scope (IP 40750)

The inspectors reviewed the licensee's written procedures for

operating and maintaining the reactor, performing surveillance

activities and reactor instrument calibrations, and conducting

experiments to determine compliance with the requirements in TS 6.5.

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b. Observations and Findinas

The inspectors reviewed changes to UWNR 142, " Procedure for

Measuring Fuel Element Bow and Growth, Revision 10." The

procedure changes highlighted a digital display modification

making the fuel element dimensional reading less prone to operator

interpretation or error. Discussions with the staff operators

l indicated that they were trained on the changes to the new

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procedure.

UWNR 005, " Procedure Preparation, Modification, Control, and

Distribution, Step 11," required that all old copies of procedures

i in the reactor lab be replaced when approved revisions have been

made. On the facility tour, the inspectors reviewed UWNR 109,

! " Procedure for Liquid Waste Disposal, Revision 17," at the

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modified liquid release discharge operating station. The review

specifically was to determine whether the prescribed valving

lineup in the procedure could inadvertently allow, by operator

error, a possible bypass of the filters causing a discharge of

radionuclide insolubles to the sewer. The inspectors determined

that the valves and system lineup did not compare to the installed

system. The inspectors determined that UWNR 109, located at the

local station had been superseded by Revision 18 on July 26, 1996.

Although the procedure was incorrect, no inadvertent discharge l

could have occurred with the outdated procedure. The licensee j

immediately replaced it with the latest revision from the master '

control room copy when notified by the inspectors.

c. Conclusions

The licensee had approved procedures to sufficiently conduct I

reactor operations, maintenance, experiments, surveillance testing l

and instrument calibrations in compliance with TS requirements. l

4.0 Requalification Training

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a. Insoection Scone (IP 40750)

The inspectors reviewed the reactor operator requalification

training program to determine compliance with the requirements in l

10 CFR 19.12, UWNR 004, " Operator Proficiency Maintenance l

Program," and 10 CFR 55.59. l,

b. Observations and Findinos

The licensee's Operator Proficiency Maintenance Program conformed

to the requirements of 10 CFR Part 55.59. The program had

established requirements for ensuring that operators maintain  ;

their licenses including attending training, performing the

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required number of reactivity manipulations, and passing annual

written examinations and quarterly operating evaluations, medical

qualifications, and remedial training if required.

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Requalification training records for selected operators were found

to contain all of the documentation required by the approved

requalification program. The reactor operator and senior reactor

operator requalification written examinations for 1994 and 1995

were reviewed. The annual written examinations continued to be

adequately thorough and comprehensive, and the content and scope

varied satisfactorily from previous examinations.

Remedial training and successful re-examination had been conducted

for one operator. The quarterly operating examinations appeared

to have been effective in evaluating licensed operator knowledge,

skills, and abilities.

The licensee had developed adequate records to track and document

operator requalification requirements. Interviews with reactor

staff verified that the requalification training program was

being carried out in accordance with the facility's approved

program and NRC regulations. The control room logs indicated

that most licensed operators had maintained active licenses for

1994-1996 and operators were knowledgeable in their licensed

responsibilities. Those who had not maintained an active license

were removed from licensed duties and the NRC was properly

notified,

c. Conclusions

A satisfactory training program was being conducted in accordance

with the NRC approved program. Adequate training records were

being maintained.

5.0. Surveillances

a. Inspection Scope (IP 40750)

The inspectors reviewed surveillance test results to determine

compliance with the requirements in TS 4.0.

b. Observations and Findinas

UWNR TS 6.5, " Operating Procedures," states, in part, that

" Written operating procedures shall be adequate to assure the

safety of operation of the reactor." UWNR 001, " Administrative

Guide, Section 15," states that "The Reactor Laboratory will

comply with the current Radiation Safety Regulations (RSR's)."

The RSR's Chapter IV, Section C., states that " Fume hoods must

have adequate air flow to ensure that restricted areas and hood

effluents remain below legally allowed effluent concentrations."

Evaluation of " Fume Hoods Inspection Flowchart" procedure,

paragraph II, states, in part, that the minimum air flow is

100 feet per minute. The inspectors noted that records were not

available to determine whether air flow testing was conducted when

fume hoods were installed. Discussions with the licensee

indicated that the University Safety Department employee

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responsible for fume hood testing was unaware that the reactor

i laboratory had fume hoods nor were the fume hoods included in the

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Safety Department's surveillance schedule for the laboratory fume

hoods since at least 1992.- It was noted that the licensee

conducted flow checks of fume hoods on campus annually.

The licensee promptly conducted a satisfactory air flow test of

the fume hoods before the inspection concluded. The inspectors

will review the adequacy of the procedure at the next scheduled

inspection. (IFI 50-156/96001-03(DNMS))

UWNR 100, " Surveillance Activities," Revision 30 and UWNR 100A,  !

"PM (Preventive Maintenance) Services," Revision 25, listed

weekly, monthly, semiannual, and annual surveillance or

maintenance activities that were required to be accomplished.

Selected schedules for May 1994 through July 1996 verified reactor

surveillances had been completed within the required time period.

Particular attention was given to the post fuel loading activities

in July 1996. Selected surveillance procedures were determined to

be adequate to verify the TS requirements.

c. Conclusions

All reactor surveillance tests had been completed and documented

at the required frequencies, and the surveillance test results met

TS requirements. The absence of the reactor laboratory fume hoods

on the testing schedule was an example of the weak university

oversight at the reactor laboratory.

6.0 Experiments

a. Inspection Scope (IP 40750)

The inspectors reviewed the licensee's program to control and i

conduct experiments performed in the reactor to determine

compliance with the requirements in TS 3.6, 4.2.5, 6.5, and 6.8.

b. Observations and Findinas

The inspectors observed experiment insertion and withdrawal using

the whale system, pneumatic transfer system, and grid box

facilities. The inspectors also reviewed the documentation of 4

several experimental samples placed into the core area.

Experiments were conducted in accordance with written procedures

which were approved and properly documented as required by TS.

c. Conclusions

All reactor experiments were conducted in accordance with properly

reviewed and approved procedures and satisfactorily documented in

the reactor operations log.

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7.0 Radiation Control

a. Inspection Scope (IP 40750)

The inspectors reviewed the radiation protection program to

determine compliance with the requirements in 10 CFR Part 20 and

TS 3.4, 3.5, 3.6, 4.2.3, 4.2.4, 4.2.5, 5.4, 6.2, and 6.6.

b. Qbservations and Findinas

The inspectors reviewed personnel exposure records from the last

inspection to the present. The records indicated that badged

reactor personnel had not exceeded 10 CFR 20.1201 regulatory

limits. The inspectors noted that for June 1996, one individual

had a total yearly accumulated dose of 20 millirem but the

previous month (May) the total yearly accumulated dose was

recorded as 60 millirem for 1996.

Discussion with the UHP revealed that approximately every other

month administrative errors by the dosimeter vendor resulted in

exposure discrepancies. The UHP further explained that the

vendor's administrative calculation errors were primarily the root

cause of the exposure errors, and why badges not exposed to

radiation indicated various amounts of exposure. Consequently, it

was learned that the vendor did not subtract the background

reading from the recorded exposures. The dosimeter vendor

subsequently issued corrected exposure records once informed by

the UHP.

The inspectors reviewed the reactor laboratory's HP documentation

associated with the reactor fuel elements transfer to the pool

pit, draining of the pool and welding of the reactor pool aluminum

liner. The RD enlisted the aid of a qualified campus welder to

assist in the welding of the crack in the pool liner. Generally

the HP contamination control practices appeared to be adequate.

In an interview with the campus pool welder, the inspectors noted

that his 10 CFR 19.12 radiation protection training was

appropriately conducted by the RD for the pool liner weld repair.

The inspectors reviewed the visitor's log entry and noted that the

welder was issued an electronic dosimeter during the pool liner

repair and received a dose of 105 millirem. However, the

inspectors also determined that the welder's official dose was not

included on the annual NRC report although it was the highest dose

for the reporting period at the reactor laboratory. The licensee

subsequently resubmitted the appropriate information to the NRC

after the exit.

Review of the reactor laboratory procedures and the campus RSR's

and discussions with the university RSO and RD indicated a

conflict over the responsibility and administration of the reactor

radiation protection program.

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The RSO indicated that the radiation protection program at the

reactor laboratory was not his responsibility because he. had no

l authority over the reactor license. The RSO pointed out that the

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RSR make no reference to the reactor laboratory whatsoever. The

RSO did not consider the reactor laboratory as a radionuclide

facility but a operating reactor.

l UWNR 001, " Standing Operating Instructions," Step 15, states, in

i part, that the RD will comply with the RSR and the RD is

l responsible for enforcing this policy.

The RSR " Health Physics Inspections and Enforcement of University

Radiation Safety Committee Regulation," Step A, states, in part,

thct the Radiation Safety Office will inspect all radionuclide

facilities at least once a year. Step B, states, that the

Radiation Safety Office will inspect for compliance with

university policies, State and Federal regulations. It also

states that the reactor laboratory is a radionuclide facility. ,

The RSO presented a copy of a 1992 licensee amendment sent to the

NRC, that provided an update on his status as the new RSO manager

and the applicable NRC licenses of responsibility and oversight.

In addition, he indicated that the letter sent to the NRC did not

list the reactor licensee as his responsibility. He further

explained that he considered the RD the RSO for the reactor

laboratory. The RS0 assumed that the reactor radiation protection

program was administered by the RD. However, the RD stated that

his understanding was that the RSO always had oversight

responsibility for the reactor radiation protection program

because the TS organization chart outlined the university campus

(health physics) radiation protection office as having structure

over the reactor laboratory. i

In addition, the inspectors noted that the university's ALARA

program that established the ALARA policy procedures and

instructions to foster the ALARA concept did not include the

reactor laboratory. During the exit meeting, the licensee

appointed the RSO responsible for oversight of the radiation

protection program at the reactor. In addition, the RSR's and the

ALARA Program will be revised accordingly to provide structure for

the radiation program oversight at the reactor laboratory. This

will be reviewed during the next inspection.

(IFI No. 50-156/96001-04(DNMS))

Postings, labeling, and surveys met regulatory requirements as

observed on the tour of the reactor laboratory. Operators were

observed using adequate, although sometimes inconsistent,

contamination control techniques; i.e., using plastic bags to

prevent the spread of possible contamination but without rubber

gloves during water sampling; using proper personal protective

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equipment and monitoring for personal contamination after removing -i

samples or experiments from the reactor pool without hand  !

l protection. In general, the staff appeared to be adequately

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trained and aware of the radiological conditions in their work i

areas.

Area radiation monitors and portable instruments were calibrated

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c. Conclusions

L All badged reactor personnel exposures were significantly below 10 l

l CFR 20.1201 limits. Training of the staff and radiation workers  ;

l appeared to be adequate. Confusion regarding the radiation i

protection program authority at the reactor laboratory resulted in i

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a lack of ownership in providing an active or dynamic oversight of  !

health physics aspects related to reactor operations.

8.0 Environmental Protection i

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a. Inspection Scone (IP 40750) (

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The inspectors reviewed the licensee's program for the discharge i

or removal of radioactive liquid, gases, and solids from the  !

reactor laboratory.  !

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b. Observations and Findinas  !

From May 1995 to June 1996, several planned liquid releases had I

occurred. A modification of the waste disposal system had been l

installed to ensure no radionuclide insoluables could be i

discharged. All sewer discharges were within regulatory limits.  ;

The inspectors evaluated the new waste pump and filter *

installation and determined that the new modification was

satisfactory. I

Airborne effluent monitoring records for 1994-1995 indicated that

the releases were well within the regulatory limits. Several

analysis records were reviewed and no deficiencies were noted.

The inspectors reviewed the COMPLY code input data for

radionuclide emissions from the reactor laboratory and no

deficiencies were noted.

The licensee had not transported any solid radioactive waste since

the last inspection. The inspectors determined that the solid

radioactive waste was properly stored and posted as required.

c. Conclusions

Both airborne and liquid effluent releases were well within the

regulatory limits.

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9.0 Audit and Reviews

a. Insoection ScoDe (IP 40750)

The inspectors reviewed the meetings, audits and reviews conducted

by the Reactor Safety Committee (RSC) to determine compliance with

the requirements in TS 6.1 and 6.2.

b. Observations and Findinos

Technical Specifications 6.1.c. required, in part, that a

University Health Physicist (UHP) conduct an inspection of the

reactor at least monthly to assure compliance with the regulations

of 10 CFR 20.

The inspectors identified, through review of the monthly audit

records, that the licensee failed to conduct the required monthly

or quarterly audits on multiple occasions in 1995 and 1996. For

example, the monthly reactor operations audits relating to health

physic compliance for September, October, November and December

1995 and February, March, April, and May 1996.

Discussions with the University RS0 and the UHP were held after

they were notified of the identified problems. The RSO stated

that he was assigned the responsibility of the campus radiation

safety office in 1992 and that since that time he was unaware of

any monthly audit requirements related to the reactor laboratory.

The RSO and UHP'both indicated that they did not have'a copy of

the reactor's TS and were never aware of the TS requirement to

conduct monthly HP audits of reactor operations. They also stated

that they were never informed of the TS requirement or their

commitment to conduct reactor operations audits. In addition,

they indicated that their monthly audits were normally conducted

as a " courtesy" for the reactor laboratory, not as a result of a

regulatory requirement. The licensee committed to immediately

implement corrective actions to comply with the requirement.

Failure to conduct monthly reactor operation health physics audits

is a violation of TS 6.1. (Vio. No. 50-156/96001-01(DNMS))

The inspectors reviewed the annual yearly radiation protection

audits of the reactor laboratory and determined that they were not

detailed or technically comprehensive partly due to lack of

ownership of the radiation protection program at the reactor

laboratory.

The annual audits generally consisted of reviewing the TS monthly

reactor operations audits over the past 12 months to ensure that

the reactor operation forms were correctly completed. The monthly

TS audit (noted to be conducted sporadically) guidance was

designed by the RD for use by the UHP and it covered generally a

documentation review of reactor activities. Independent

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assessments of other HP related activities at the reactor

, laboratory were never instituted by the RSO. For example, the

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reactor laboratory underwent a major evolution in draining the

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pool, removing fuel elements from the core, and welding on a

potentially activated aluminum pool liner over a one month period

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without any UHP involvement. Discussions with the UHP indicated

that the radiation safety office were unaware of this repair

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activity at the reactor laboratory.

In general, the health physics program audits appeared weak

l because they failed to cover a broad spectrum of ptogram areas.

The audit findings appeared to be superficial as they either

lacked adequate detail or appeared to lack recommendations or

solutions. The licensee agreed to review this area for

improvement. This will be reviewed during the next inspection.

(IFI No. 50-156/96001-02(DNHS))

c. Conclusions

RSC meetings were conducted as required. Communications between

the RS0 and reactor staff failed to address the implementation of

the monthly reactor operations audits as required by TS. Annual

audits were weak in scope and depth.

10.0 Emergency Preparedness

a. Inspection Scope (IP 40750)

The inspectors reviewed the emergency plan for the reactor

laboratory to determine compliance with the requirements in 10 CFR ,

50.54(q) and (r). The inspectors also followed up on a licensee l

identified weakness in the campus police and security alarm

response system. l

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b. Observations and Findinos

The emergency plan procedures were sufficiently detailed. The RSC

review of the audit of the emergency plan and procedures was l

appropriately documented in the RSC meeting minutes and met the j

requirements in TS 6.2. l

The inspectors reviewed documentation related to the emergency i

drills held on November 6, 1995 and October 31, 1994. The

r'nergency plan did not require any written objectives, critiques

or evaluations related to the drill that could help identify any

emergency drill weaknesses or suggest corrective actions. The

Reactor Supervisor stated that they had not identified any

weaknesses requiring corrective action during the drills.

Subsequent discussions with various reactor personnel confirmed

that these activities were conducted successfully. Documentation

indicated that the licensee's staff had been trained in the

emergency plan and procedures and had participated 4- the drill.

Records reflected that operators were retrained an' ,ly and .

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examined on emergency procedures as part of the op. . tor

i requalification program.

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The emergency equipment locker was maintained at a strategic

location and included monitoring equipment and contamination

control supplies. Emergency equipment had been inventoried ,

annually as required.

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The letter of agreement between the University of Wisconsin  ;

Nuclear Reactor and the University Hospital was current. Other

services have been mandated or had not required written agreements

was confirmed by the inspectors through police and security

interviews.

The inspectors conducted discussions with the campus police and

security and determined that they had an adequate understanding of

their roles in emergencies at the reactor laboratory. The

inspectors also discussed a licensee identified weakness regarding

the potential for the campus police dispatcher to make a computer

code entry error responding to reactor laboratory alarms. The

incorrect code could potentially misdirect the responders to the

wrong location, incorrect procedures, etc. The police dispatcher

had knowledge of the problem and was capable of demonstrating

adequate ability to respond to the reactor laboratory alarms.

Campus police and security have future computer software changes

planned that will eliminate the potential for error.

The inspectors identified errors in the several incorrect

emergency notification telephone numbers for the reactor staff on

the police computer data base. Although the police had the

updated numbers, they stated that updating the computer data base l

was delayed because of a staffing shortage but the updates were l

expected to be added shortly. The inspectors advised the reactor 1

staff of these concerns.

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The licensee and campus police implemented their procedures for

public demonstrations planned for August 22, 1996. The inspectors

determined that the police were strategically positioned and

prepared to safeguard the reactor laboratory. The reactor

laboratory staff had reviewed the appropriate emergency procedures

for the anticipated event. The demonstrators did not arrive at

the reactor laboratory as originally planned.

No significant changes in the Emergency Response Organization were

noted.

c. Conclusions

Review of emergency equipment and supplies, changes to the

emergency plan, and documentation relating to emergency drills as j

well as interviews and observations indicated that the licensee's i

emergency program was maintained in a state of operational

l readiness. (Closed Followup item 50-156/94001-01)

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11.0 Fuel Handling

a. " Inspection Scope (IP 40750)

The inspectors reviewed the fuel handling procedures at the

reactor laboratory to determine compliance with TS 6.

b. Observations and Findinas

The facility fuel handling program review included the

verification of procedures for fuel handling and the technical

adequacy in the areas of criticality safety and TS. Records

review and discussions with personnel indicated that fuel handling

operations had been carried out in conformance with procedures.

Log entries and fuel location maps for fuel handling activities

were appropriately documented.

c. Conclusions

Procedures for fuel handling were technically adequate for reactor

operations.

12.0 Review of Periodic and Special Reports

a. Inspection Scope (IP 90713)

The inspectors reviewed the licensee's submittal of reports and

notifications to the NRC to determine compliance with the

requirements in TS 6.7.

b. Observations and Findinas

The 1995 annual report had been submitted in a timely manner and

contained the information required by TS. No special reports had

been issued to the NRC since the last NRC inspection of the

reactor laboratory in May 1994.

The 1996 annual report was reviewed and the inspectors determined

that the highest whole body dose declared in the annual report was

less than the dose determined for the worker discussed in Section

7.0. The licensee attributed the error to an oversight by the

campus Radiation Safety Office. The licensee submitted a

correction on September 3, 1996.

c. Conclusions

Required reports had been submitted to the NRC in accordance with

TS requirements although the highest radiation dose for the 1996

report was not included.

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13.0 Transportation of Radioactive Materials

a. Inspection Scone (IP 86740)

The inspectors reviewed the licensee's radioactive materials

! shipping program for compliance with the requirements in

l Department of Transportation (DOT) and NRC regulations, 49 CFR

Parts 172 & 173 and 10 CFR Part 71, respectively.

l b. Observations and Findinas

e Reactor License

1

! The reactor laboratory transferred reactor irradiated material l

from the reactor license to the university byproduct material i

license. Radwaste would also be transferred to the university

broad scope license for packaging and disposal when the need

arose.

e Broadscope License l

l Inspection findings indicated that DOT regulations may not have

been followed in several instances following the transfer of l

irradiated material from the reactor license to users authorized

by the university byproduct material license. These findings will

be reviewed during the next broadscope inspection. ,

I

c. Conclusions

The transfer of reactor irradiated material was per procedure.

14.0 Followup Action on Inspectors Identified Items (IP 92701)

a. (Closed) Open Item No. 50-156/94001-01(DRSS): I

The inspectors reviewed the documentation of emergency drill

evaluations and determined that they had met the licensee's

program requirements. This item is closed.

I

15.0 Followup on Licensee reported events (IP 92700)

a. The inspectors reviewed all the activities to repair the reactor

pool leak and found that the licensee's actions had been in  :

accordance with procedures to unload and reload the core and

drain and refill the pool. The post repair tests indicated the

leak had been satisfactorily repaired.

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16.0 Persons Contacted

.

.

University of Wisconsin

M. Corradini* UW College of Engineering Associate Dean

Gilbert A. Emmert* University of Wisconsin Department Chair

, Kathy Irwin* UW Legal Services Senior UW Counsel

R.J. Cashwell* UW Reactor Laboratory Reactor Director

S. Matusewic* UW Reactor Laboratory Reactor Supervisor

.

Ronald Bresell* UW Safety Department Assistant Director

Additional technical, operational, and administrative personnel were

contacted by the inspectors during the course of the inspection.

'

  • Denotes those attending the exit meeting on August 23, 1996.

'

17.0 Exit Interview (IP 30703)

The inspectors presented the inspection results to members of the

licensee management at an exit meeting on August 23, 1996. The licensee

acknowledged the findings that were presented. They also requested

'

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additional time to revied the issues to provide additional information

if available. That request was taken into consideration by the

. inspectors while, preparing this report. The inspectors asked the

licensee whether any material examined during the inspection should be ,

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considered proprietary. No proprietary information was identified.  !

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Insoection Procedures Used

IP 40750 Class II Nonpower Reactors

IP 86740 Inspection of Transportation Activities

IP 90713 Review of Periodic and Special Reports

IP 92701 Followup on Inspectors Identified Problems

Items Opened and Closed

Opened

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l 50-156/96001-01 VIO Failure to conduct monthly audits of the radiation

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protection program

50-156/96001-02 IFI Anr.ta1 radiation protection audits were weak

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50-156/96001-03 IFI Surveillance of fume hoods was not performed

l 50-156/96001-04- IFI The Reactor inclusion into the University's and ALARA

radiation protection programs

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Closed .

50-156/94001-01 IFI Documentation of Emergency Plari exercises

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l List of Documents Reviewed l

Safety Analysis Report

Safety Evaluation Report

Reactor Operating License

!

Technical Specifications

Administrative Procedures

Operating Procedures

Maintenance Procedures

Surveillance Procedures

Maintenance and Surveillance Records

Emergency procedures

Training Program

Emergency P1an

i Dosimetry Records

i Training Records

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Various Reports

,

University Radiation Safety Regulations

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List of Acronyms Used

ALARA As Low as Reasonably Achievable

CFR Code of Federal Regulations ,

CORD Central Office for Receiving and Distributing  ;

DNMS Division of Nuclear Materials and Safeguards l

DOT Department of Transportation l

'

HP Health Physics

IP Inspection Procedure  !

NRC Nuclear Regulatory Commission  !

PDR Public Document Room

PM Preventive Maintenance .

RSC Reactor Safety Committee l

RSO Radiation Safety Officer '

SAR Safety Analysis Report

SPGHG Shipping Paper and Declaration of Hazardous Goods

TLD Thermal Luminescent Detector

TS Technical Specifications i

UHP University Health Physicist I

URSR University Radiation Safety Regulations ,

UWNR University of Wisconsin Nuclear Reactor I

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