ML20154N006
| ML20154N006 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 04/19/1988 |
| From: | Neely Research Reactor, ATLANTA, GA |
| To: | |
| Shared Package | |
| ML20154M791 | List: |
| References | |
| NUDOCS 8806020154 | |
| Download: ML20154N006 (83) | |
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l THE NEELY NUCLEAR RESSARCH CENTER l
Response to The Nucleat Regulatory Commission Concerns Docket No. 50-160 License No. R-97 April 19, 1988 8806020154 880513 PDR ADOCK 05000160 P DCD
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TABLE OF CONTENTS Page ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . 11 I. INTRODUCTION . .. . . . .. . . . . . . . . . . . . . . . . 1 II. SPECIFIC RESPONSE TO ORDER . . . . . . . . . . . . . . . 2 III. ACTION PLAN . . . . . . . . . . . . . . . . . . . . . . S A. Add i *.ional Ope ra to rs . . . . . . . . . . . . . . . 7
- 3. Procedure for Two Ope rato rs . . . . . . . . . . . 22 C. Medical Evaluation o f sr. m. actor operator . . . . . . 28 D. Personnel Changes . . . . . . . . . . . . . . . . 29 E. Procedure Revisions . . . . . . . . . . . . . . . 43 F. Regulatory Sensitivity Training . . . . . . . . . 64 G. Outside Evaluation of NNRC . . . . . . . . . . . . 66 H. Other fianagement Actions . . . . . . . . . . . . . 71 IV. ROOT CAUSE AND ACTION
SUMMARY
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e T ABSTRACT -
Concerns expressed by the U.S. Nuclear Regulatc r y Commission about the GTRR operation required comprehensive assessments of all activ1;ies at the Neely Nuclear Research Center. Tr.ese ascessments produced an action plan with the f ollowing compo ner.t s.
A. Addi tional Reactor. Ope ra to rs B. Two Ope,rators Requirement in Control Room C. Medical Evaluations of Sr. Reactor Operator D. Personnel Changes E. Procedure Revisions F. Staf f Regulatory Training G. Outside Evaluation of NNRC H. Management Ac't io ns I. Root Cause and Action Summary Training for additional operators began April 11, 1988. A schedule of daily training sessions of two hours for more than 13 weeks is in progress.
A procedure for two operators in the control room has been written and approved by the Nuclear Saf eguards Committee.
Med ical evaluation of sr. Reactor operator by Dr. Everett c.
Kuglar, a nationally known authority, has been completed. No medical or psychological problems of any kind were found.
Radiation safety personnel have been replaced with more competent individuals. The change has had beneficial effects on staff morale and performance already. No personnel conflicts or bickering have occurred since the changes were made.
Procedure revision is occurring at two levels:
- 1. Immediate correction of cause of cadmium spill and mistakes which were made during cleanup. Needed procedures in this area have been written and approved by the Nuclear safeguards Committee.
- 2. Long term solution requiring entire GTRR procedures to be reviewed, revised, and supplemented where necessary, in a manner similar to industry standards. Target da te for completion is March 1989.
Regulatory training , already implemented, has three elements: '
(1) sensitivity to r eg ula t io ns , (2) time set aside of each weekly staff meeting for discussions or presentations of issues related to regulatory sensitivity, and (3) one staff member has been assigned to review NRC notices, bulletins, and circulars. Additionally,
-.her industry experiences, both good and bad, will be presented.
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outside evaluation of NNRC shows that changes in staffing that
'a v e Duca accomplished over the past neveral enths pr:duced a sign i f ican t improvement in the ability to operate the facility in a safe and efficient manner.
The NSRC has instituted a systen of internal raiits for r'1 d;cumentation. Every document will be audited for accaracy and completeness by management before it is filed. This added level of revies will sharply reduce the number of er rors and omissions in records.
Georgia Tech believes that the actions taken at several fronts created a management structure which will permit a much higher level of control than existed in the past. It is believed that conmitment to sa fe ope ra tion has been st reng thened aig ni ficantly.
NRC concerns taught the NNRC staff a valuable lesson. We believe it is safe to return the GTRR to f ull operatio n.
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I. INTRODUCTION Tne order of Januar, 20, 1983 by the :;uclear Re3ulatory Commission was partially answered during the Enforcement Conference of February 23, 1998. This document will extend th e information provided to the Commission during tnat conference. The in c i de re t report presented during the conference is included by reference.
This response spe'cificall'y addresses each of the conditions listed in the Order as well as the Action Plan developed by the Neely Nuclear Research Center to meet the concerns of the Order and to improve both reactor operations and health physics programs.
Tne action plan addresses the following issues:
Additional Reactor Operators Procedure for Two operators Medical Evalua tion of Sr. Reactor operator Personnel Changes Procedure Revisions Staf f Regulatory Training Outside Evaluation of the NNRC Management Actions Root Cause and Action Summary
2 II. SPECIFIC OESPONSE TO ORDER A. The licensee shall cease utilization of the reactor facility for irradiation experiments until the follcw;.g Jonditians are met and the NRC approves, in writing, the resumption of. ir radiation experiments.
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- 1. Management contro1s over f acility operation, including-irradiation experiments, are assessed to iden ti f y weaknesses.
Re s panse :
- 4an ag eme n t controls over f acility operation including irradiation experiments were found lacking in that:
- a. Written procedures for performing irradiation experiments permitted multiple runs of approved minor experiments without explicit management review.
- b. The Reactor Operator failed to obtain appropriate signatures and review of experiment.
- c. Inadequate procedures existed to control the length of ,
irradiation of experiments,
- d. No procedures existed to control opening of irradiated samples.
'e . Health Physics personnel were insufficiently trained to handle unexpected spill of radioactive material.
- f. Animosity between Health Physics and the remainder of the staff at the NNRC prevented cooperation necessary for effective operation.
9 Health Physics staf f openly opposed the authority of the 3
Director of the NNRC to manage health physics activities
, thereby rendering management unable to correct program inadequacies.
Corrective actions taken are:
- a. Procedures for minor experiments have been revised to require management approval for each run of all experiments,
- b. Reactor operators have been counseled individually and retrained in group meetings about the importance of absolute compliance with every step of the procedures.
Additional operators are now in training and a new procedure requiring two operators in the control room during reactor operations has been approved. An additional management control provides for a continuing internal audit of the completeness and accuracy of all documents and records.
- c. Revised procedures to control sample irradiation time have been approved.
- d. New procedures for opening irradiated samples have been approved.
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- e. The health physics staff 1Ta been replaced seith noce skilled technicians. A new acting Manager of Radiatton Safety has been appointed. A search for a staff health physicist with a Ph.D. deg n is in progr_a;.
Further details on the corrective actions taken are contained within the incident r.eport and in the following action plan.
- 2. A formal review is conducted, including record reviews and in-depth personnel interviews, to determine (a) if other occurrences similar to the August 1987 incident have occurred, and (b) the principal root cauces of the August 1987 :ncident and any other similar incident..
Response
- a. No other incidents which have the same root cause as the August 1987 incident have been found,
- b. The root causes of the August 1987 incident are described in the incident report on February 23, 1988 and are summarized in response item 1 above.
- 3. An assessment of internal exposure, external whole body, extremity, and skin doses to personnel involved in the August 1987 incident (any other identified inc id en ts) and/or decontamination activities is conducted.
Response
No internal exposure, excessive external exposure or skin dose to any personnel as a result of the August 1987 incident (or similar incidents) and/or decontamination activities was found.
Details are included in the incident report. ,
- 4. The GTRR health physics and operating procedures are reviewed to identify inadequacies which contributed to the August 1987 contamination event (and any other identified events) .
Response
GTRR health physics procedures permitted the reactor operator to open an irradiated sample while working alone on the reactor top. Newly approved sample handling procedures require all samples to be opened in a hood and checked for possible contamination. Failure of health physics to perform adequate surveys or to maintain adequate records of the limited surveys they did make were not procedural in nature. These problems have been handled administratively by replacing the health physics staff with qualified persons.
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- 5. Corrective actions are identiiied and a schedule established for implementing the corrective actions, including necessary char.ges in management contreln, operations, and procedures.
Response
Corrective action's have'b'een identified and are discussed fully in the following section on the action plan.
- 6. A training progran addressing all changes to management cont rols, operations, and procedures is developed and implemented.
Response
Tne training program to address all changes in procedures, management controls, and operations is included in the following action plan.
- 7. The licensee's reviews and assessments of the above materials are documented and a summary of these reviews and assessments, including ccrrective actions and appropriate schedules, are submitted in writing to the NRC for review and approval.
Response
Licensee's reviews and assessments are contained within the incident report of February 23, 1988 and this document.
- 8. Results of the licensee's survey of the house of the individual involved in the Augsut 1987 contamination event shall be provided in writing to the NRC within 10 days of the issuance of this order.
Response
Results of the survey of the individual's house showed no contamination. A full description of the survey and its results is contained in the incident report.
5 III. ACTIO:1 PLAN Tne action plan presented at the Enforcement Conferexte en February 23, 1988 is shown in the following tabic. Each item is either conplete or in process according to schedule. The following paragraphs describe t,he status of each item.
NTC /CTIG4 PL/N 1988 tturOW( MWH APRIL IVRY JLif JUL.Y I
/UlET I I I I 1 3 Mdit ionai Operators **************""*****************************""*****I " " * * * * * " * * * * " " " * * " 'i
{(CoTpletion expected in 5 to 12 months )
2 fAininira of 2 Operators *
(conplete 2/22/88) -
in Control 'J -
3 Upgrade FP Crganizat- *****************************+*************
ion, 1 PtO, 1 (Ms or Bs), 1 Technician 4a Upgrade FP and Operat- *** *****+ * ******* : : : : :
ions Procedures to '
Mdress Order Concerns 4b Upgrade Procedures for Both Cperations and
- * : : : : : : *** ** : : : : : : : : : : * : : : : : : : * * **** " * ** " * * * *** * * * ** * *** " * * ** ** * ** * *****+
lica'l th Physics (all)
(Carpletion scheduted for 2/28/89)
S Peepslatory Sensitivi ty ***:::==:::::
(corrplete staf f by 3/22/88 and then ongoing annually)
Trainin; G Ou t s i e : Evaluation *** (Evaluation begins 3/24/83) 7 Lift N C Order l 1 Pastricting irradia-
+ (Pending results of Outside Evaluation and ifC P4:vic.v) tion experiments.
-7 ADDITIO!4AL REACTOR OPERATORS The current number of -licensed operators is two. This number is the -minimum needed to - operate the reac to r. A training prog ram
-and schedule has been devised to train an additional five operators. The formal trainihg program began April 11, 1988 and is scheduled to end 13 weeks later. An outline of the program follows.
The NNRC personnel who will be trained are:
Dr. Rober t N. Macdonald Mr. J.M. Puckett Mr. David L. Cox Mr. Mitchell F. Mercer Mr. Dixon Parker
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Also in attendance are Mr. Dean McDowell and Mr. Bill Downs, both cf whom currently hold SRO licenses for the GTRR. The class
.is conducted by Dr. Ratib A. Karam. The course outline is attached.
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8 REACTOR OPERATOR TRAINING SCHEDULE AND OUTLINE Week _One I. Work Assignment Study Final Saf ety Analysis Report and Technical Specifications ,
II. Study Topic Final Safety Analysis Report and Technical Specifications III. Lecture Final Safety Analysis Report and Technical Specifications Week _Two I. Health Physics Training See outline Week Three ;
I. Work Assignment .
Weekly and daily checkouts. Each trainee should actively participate in at least le checkouts.
II. Study Topics Building ventilation, building isolation, airlocks, truck ,
door, compressed air system, applicable technical specification III. Lecture Assignments and homework (text Shif fer, see outline) '
Chapters 1, 2, 3, 4; problems, all Week ,Four I. Work Assigntaents Weekly and daily checkouts II. Study Topics Containment building, integrated leak test, shield system, secondary system, alarm and communication system; ,
criticality, fire, public address (PA), intercom system, i sound powered phone; 8000 series procedures, applicable
. technical specifications III. Lecture Assignnence ani. honework: Chapters 5 and 6 - all problems l
9 Week Five I. Work Assignment Checsauts as needed including monthly's II. Study Topics Primary coolant system; purification and transfer system; emergency core cooling; security system; 1000 series procedures; applicable technicci specifications III. Lecture and. Homework Chapter 7 - all problems Week Six I. Work Assignments Sample preparation - techniques and checkouts II. Nitrogen cover gas; recombiner; pneumatic system; GTRR d rawi ng s; 2000 series procedures; applicable technical specifications III. Lecture and Homework Chapter 8 - all problems week _Sev_en I. Work Assignments Perform typical health physics surveys and smears; two reactor startups for each trainee II. Study Topics Vertical and horizontal experimental facilities; bio-med room; thermal column; 3000-4089 series procedures; applicable technical specifications III. Lecture and Homework Chapter 9 - all problems Week Ei,ght I. Work Assignments Regulating rod calibration; reactor surveillauce; two reactor startups for each trainee II. Study Topics Reactar vessel; f uel elements; biolog ic al shielding; liqu:d waste; fuel storage; applicable technical specifications III. Lectare and Homework l
Chapter 10, 10-1 th ro ug h 10- 31 ; Problems 1-9 1,
r 10 Weel tline I. Work Assignments Toaperature coefficient; 2 startups; build Le tour :;
checkouts II. Study Topics (1) Rod drives; (2) shim safety; (3) regula ting rod; (C coolant piping; (5) crane; (6) fuel handling; (7) applicable cechnical specifications III. Lecture and' Homework Chapter 10 (10-32 through 10-83); Problems 10-13,.16-19, 25, 26 Week __ Ten I. Work Assignments 2 startups; instrument calibiation II. Study Topics Nuclear instrumentation detectors; flow and temperature detec to rs; principals of operation and calibration III. Lecture and Homework Chapter 12, all problems Week Eleven I. Work Assignments Approach to criticality; instrument calibration; startups II. Study Topics Control room instruments; signal sources; electrical power distribution; lighting; emergency generator operation III. Lecture and Homework Chapter 12 Week Twelve I, Work Assignments 3 startups; interlock testing II. Study Topics Interlock circuitry; d rawings,60-001, 60-002, sheets 1, 2, 3, 4 III. Lecture and Homework Chapter 11
11 Week Thirteen I. Work Assignmentc Startups; energency preparedness plan; cre rg ene" procedores
- I. Study Topics GTRR license; state licence III. Lecture .
Review Final Exam l
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LECTURES OUTLINE
. Mathematics A.. In tr od uc t ion B. Fractions C. Negative Number:
D. Use of Letters to Represent Numbers E. Solution of Algebraic Equations F. Computations with Units and Dimensions G. Exponents H. Powers of Ten .
I. Exponential Processes
- 3. The Base e K. Natural Logarithms L. Common Logarithms M. Problems II. Atomic Structure A. Structure of Matter B. Structure of Atoms C. Properties of Atoms D. Iso to pe s ,
E. Identification of Atoms F. Atomic Weights i G. Problems III. Physical Chemistry A. Electronic Structure of Atoms
.B. Chemical Properties of Atoms C. Ionic Chemical Reactions D. Covolent Reactions E. X-Rays
, R. Problems ;
IV. Radioactive Particle Emission .
A. Natural Radioactivity .
E. Alpha Particles l C. Beta Particles l D. Gamma Rays E. Radioactive Change F. Alpha Decay -
G. Beta Decay I
. H. Rate of Radioactive Decay I. Interaction of Charged Particles with Matter J. Interaction of Gamma Rays with Matter l K. Fundamentals of Gamma Ray Shielding i L. Problems I
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13 V. Mass, Energy, and Nuclear Stability A. The Equivalence of Mass and Energy B. The Electron Volt Unit of Energy C. Nuclear Forces D. Nuclear Stability E. Energy and Mass Considerations in Nuclear Structures F. Problems VI. Nuclear Reactions A. In t r od uc.t ion B. Transmotation Process C. Atomic Projectiles D. Proton Bombardment E. Alpha Particle Bombardment F. Deuteron Bombardment G. Ganna Ray Bombardment 4
H. Energy and Mass Considerations in Nuclear Reactions I. Problens VII. Neutron Behavior
! A. Introduction B. Neutron Sources C. Neutron Reactions D. Cross Section E. Dependence of Cross sections on Neutron Energy F. Classification of Neutron Energies G. Neutron Flux H. Neutron Reaction Rate I. Problems VIII. Nuclear Fission A. Introduction l B. Fission Cross Sections l
C. Fertile Materials D. The Fission Reaction and Energy Release E. Fission Products F. Radioactivity of Fission Products G. Fission Neutrons H. Spontaneous Fission I. Problems IX. Introduction to Nuclear Reactors and Nuclear Power Plant Cycles A. Introduction B. The Chain Reaction C. Type of Fuel D. Critical Mass E. Reactor Control F. Introduction to Power Reactors G. Power Reactor Systems H. Water Reactors I. Gas Cooled Reactor J. Liquid Metal Reactors
14 X. Reactivity Considerations in Water Moderated Reactors A. In trod uc tion -
B. Maltiplication Factor C. Epithermal Contributions to k ggg D. Reactivity E. Control Rods F. N0atron Sources G. Neutron Multiplication in a Subcritic2; Reactor H. Reactor Period and Power Level I. Startup, Rate J. Prompt Neutron Generation Timo K. Ef f ect of Delayed Neutrons Upon Reactor Behavior L. Prompt Critical M. The Relationship Between Reactivity and Period i N. Reactivity Coe f ficients
- 0. Xenon-135 ,
P.- Saaarium-149 l Q. Fuel Burnup i R. Problems XI. Chemical, Radiochemical, and Waste Disposal Considerations ;
in Water Reactor Operation ;
A. Introduction !
B. Acids, Bases and pH !
C. Corrosion of Materials D. Sources of Radioactivity in Reactor Coolant l E. Radiolytic Decomposition of Wate r F. Demineralizers G. Primary Coolant Chemistry Program H. Radioactive Waste Disposal I. Problems XII. Nuclear Instrumentation A. Introduction
- i B. Detectors !
C. Instrumentation and Control System Applications D. Problems l
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16 RADIOLOGICAL SAFETY TRAINING OUTLINE I. Description of Training Procram A. Introduction and purpose B. Subjects to be covered C. Open book and class participation examination II. Basic Radiation Technology A. "It All Starts here" - The Atom
- 1. What is an atom
- 2. Types of atoms, elements, molecules
- 3. Chart of nuclides ,
B. What is Radiation - Radioactivity
- 1. Our radioactive world
- 2. The rem
- 3. The curie
- 4. S. I. Units C. Types of Radiation
- 1. Ionizing . alpha, beta, gamma, x-ray, & neutron
- 2. Non-ionizing - microwave, laser, ultraviolet, sound, etc.
- 3. Interaction with matter D. Useful Radi$ tion Units & Terms E. Class Discussion & Demonstration with Some Small Sources of Ionizing Radiation F. More Details About Sources of Radiation
- 1. Non sealed sources
- 2. Sealed sources
- 3. Incapsulated sources
- 4. Leak test G. Ilow to Limit Exposure to Radiation i
- 1. Time
- 2. Distance
- 3. thielding ;
II . Actic. tion vs Contamination I. E: - Spacific Characteristics of Sources i
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- 2. Am-241 8. Pm-147
- 3. H-3 9. Tn-232
- 4. Cs-137 10. Pu-239
- 6. Co-60 12. Others J. Some Sources of Radiation Safety Information
- 1. Radiological Safety Handbook
- 2. Radiation Monitoring a Programmed Learning
- 3. 10 CFR 20 & 19
- 4. Basic Radiation Protection Technology, by Gollnick III. Radiological Safety Officer - Health Physicists A. Purpose - Control of Radiation and Compliance
- 1. History & Philosophy B. Authority - Organizational Structure C. Availability When Needed D. Surveys E. Training F. Duties G. ALARA Commitment IV. Introduction to Federal, State, and Local Regulations A. Title 10 Code of Federal regulations
- 1. Nuclear Regulatory Commission (NRC)
- a. 10 CFR Part 19 & 20 (Study in some detail)
- b. 10 CFR Parts 30, 40, & 70 B. Agreement State Rules C. Local or Other Rules and Regulations D. Some Definitions
- 1. By-product Material
- 2. Source Material
- 4. Other E. Inspections
- 1. Significance of Inspection
- 2. Description of Typical Inspection
- 3. Record Keeping
15 F. Emergencies
- 1. Action to be T/. ken
- 2. Who-& When to !;otify G. Regulatory Trends and Proposed Changes V. Licenses -
A. Type's of Licenses
- 1. Specific Licenses
- 2. Specific Licence With Broad Scope B. Control of,Sourect Other Than By-product Material
- 1. X-ray
- 2. Accelerators
- 3. Radium
- 4. Reactors C. Application for Radioactive Material License
! D. Typical License VI. Biological Effects of Ionizing Radiation A. Natural Radiation & Artificial Radionuclides B. Radiation Protection Guide
- 1. ICRP
- 2. NCRP
- 3. Other C. Linear vs Threshold Theory l
i l D. Symptoms from Overexposure E. Mutations
- 1. Somatic Mutations
- 2. Genetic Mutations F. Some Probable Effects from Various Acute & Chronic Doses ,
G. External vs Internal Exposure
- 1. Body Burden (MPBB)
VII. Portable Instruments Frequently Used to Detect
& Measure Radiation A. Film Badge B. Thermolumincscent Dosimeters (TLD)
19 C. Pocket Dosimeter ,
D, G. M. Survey Meter E. Cutie Pie Ionization Meter F. Neutron Meter ,
G. Alpha Mo' er H. Air. Samplers - Staplex I. Digital Meters
- /III. Fixed or Laboratory Instruments Frequently Used to Detcet & Measure Radiation A. G. M. Scaler
- 1. Efficiency determination
- 2. Basic counting statistics B. Gas Proportional System C. Scintillation Systems
- 1. Alpha counting
- 2. Beta counting Gamma counting 3.
- 4. Liquid Scintillation D. Solid State Systems IX. Proper Laboratory Techniques and Demonstration A. Marking, Labeling, & Posting of Signs
- 1. Use of assay date on label
- 2. Inventory quantity must check with labeled containers
- 3. Radioactive material
- 4. Radiation area
- 5. liigh radiation area
- 6. Airborne radiation area
- 7. Notice to employees B. Handling Techniques
- 1. Contaminacion control & use of protective clothing
- 2. Consideration of airborno activity
- 3. Action in case of a spill
- 4. Step-off pad S. Survey self after werk C. Waste Disposal
- 1. Solid waste
- 2. Liquid waste
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- 3. Marking of waste
- 4. Training others not to throw away waste
- 5. Inventory balance X. Radioactive Materials Shipment r
! A. S sic Regulations - 49 CFR
- 1. Review of requirements B. Common vs Solo Carrier
- 1. Isotope transfer & shipments
- 2. Waste management & shipments
! 3. Shipping paper C. Low Level Naste Disposal
- 1. Proper preparation
- 2. Sites in the U.S. & critoria for burial D. High Level Wasto XI. Practical Radiation Safety Practices, Measurements, Monitoring Techniques, Math, Rules of Thumb,
& Laboratory Exercises -(Not necessarily in this order)
A. Useful Math for Health Physicists B. Rules of Thumb & Application of Formulas C. Instrument Calibration
- 1. G. M. Survey Meter
- 2. Ionization Survey Meter
, 3. Neutron Survey Meter
! 4. Alpha Survey Mete.-
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D. Actual Use of Various Survey Instruments E. Take Air Sample & Calculate Results i l F. Take Water Sample & Calculate Results G. Identify Gamma Isotopes H. Make Use of a G. M. Meter & Make Probe & Wipe Survey
- 1. Isolate the source of radioactivity
- 2. Identify the source of radioactivity I. Make Use of Cutie Pie Ionization Meter, Set 9ose Rates, & Calculate stay Time J. Keep Log Book & Write Up Results of Surveys
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1 K. Make Smear & Dose Rate Survey & Log Results L. Dress Out in Full Protective Clothing 5 Use ;
Step-off Pad Properly M. Make Bioassay Analysis of Urine & Log Results N. Read and Charge' Pocket Dosimeter >
O. Road TLD P. Shielding Exercise i Q. Contamination Clean-Up R. Source Size & Other Correction Factors S. Sit at 5 Mw Reactor Console With Licensed Operator and Actually Operate The Reactor.
T. Send A Sample In The Reactor Core. Zone and 1 . Activates Then Observe Decay, Shielding, Isotope Identification, etc. 7 U. Practice Operating Hot Cell Manipulators 7 t
t XII. Review XIII. Examination (70% or better required to pass) ,
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22 B. Procedure for Two Operators The a ttached procedure number 2001, Two Ope ra to r Ope ra tiens, was approved by the Nuclear Safeguards Committee on April 6, 1988.
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E 23 Georgia Tech Research Reactor Procedure 2001
'/:ner ChaarA :! Revis!ca 00 by: TWO . OPE RATOR ' Approved 04/06/6S'
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. OPERATIONS Page 1 of 5 1.0 PURPOSE This procedurd describes the administrative controls necessary for safe operation of the reactor.
2.0 APPLICABILITY The Conduct of Reactor Operations Precedure is required to be used at any time the following are taking pla;c:
2.0.1 At any time the Technical Specifications require a Licensco Rca; tor Operator (RO) or Senior Reactor Operator (SRO) to be in the control room. These are: .
?.0.1.1 When the reactor is operating.(chim-safety blades not fully inserted OR control rod power is on and either of the preceeding is true with six or-more fuel elements are loaded in the core) OR 2.0.1.2 The reactor is not operating (shutdown) and
- b. Operations are in . progress which involve moving fuel elements within . the reactor vessel, the insertion or removal - of experiments from the core, or control rod rrraintrieance.
2.0.1.3 At any time the Director, Neeley Nuclear Center, or his representative determines the need Sr implementing this procedure.
2.1_ OEFINITIONS
'2.1.1 "Operator" is any individual who manipulates the controls of the -
f acility.
2.1.2 "Facility" is the Georgia Tech Research Reactor (GTRR). ;
2.1.3 "Senior Operator" is any individual licensed by -the United States Nuclear Regulatory Commission (NRC) to direct the licensed activities of licensed operators.
2.1.4 "Ccntrets" means apparatus and mechanisms the manipulation cf which aircolly af fect the reactivity or power level of the reactor.
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24 Procedure 2001 [ Georgia Tech Research Reactor) Page 2
.:.1.5 "Studen t" means an individual engaged in a ecurse of instructicn casigmJ to lead to a rea-tor operator license.
2.1.6 "Knowledgeabic individual" means a person previously licensed by the NRC as an operatcr en the GTRR or other reactor, a person .. he u, virtue of educaticn or experience adequataly u nd.'r st ands the significance of reactor parameters, or a person specifically designated and trained by the Director, NNRC, to perform certain emergency actions under a specific set of defined circumstances.
2.1.7 "Reactor Secured" means that:
- a. The reactor is shutdown
- b. Subcriticality of the cold xenon free core by al l east one dollar has bcea confirmed.
- c. No operation is in progress which' involves moving fuel elements within the reactor vessel, the insertion or removal of experiments from the core, or control rod maintenance.
2.1.8 "Reactor Shutdown" means that the shim-safety blades are fully inserted and the control rod power is of 8 The reactor is considered to be operating whenever this condition is not met and there are six or more fuel elements loaded in the core.
2.2 Precautions and limitations 2.2.1 No person may perform the function of an operator (RO) except as authorized by a license issued by the NRC.
2.2.2 No person mby pe: form the function of a sanior operator (SRO) except as authoriwd by a license issued by the NRC. ,
CAUTION IT IS THE DUTY AND RESPONSIBILITY, BY LAW, OF ANY LICENSED OPERATOR TO '
i REMOVE HIMSELF FROM THE PERFORMANCE OF Lt CENSED DUTIES SHOULD HE BECOME INCAPACITATED EITHER MENATLLY OR PHYSICALLY W ANY WAY THAT WOULD DETRIMENTALLY EFFECT HIS ABILITY TO PROPERLY PERFORM THOSE DUTIES.
2 2.3 No trainee or other person shall manipulate the controls of the reacter except under the direct control and supervision of the operator en cuty except as provided specifically in this procedure.
3.0 'ROCEDURE 3.1 Control room st-'fing require.ments.
25 Procedure 2001 (Georgia Tech Research Reactor) Page 3 3.1. Except as provided below, two licenscd operators are nauired to c; r, the control room at all times whenever the reactor is not secured.
. a. One operator shall be designated the prime operator. and shall be responsible for all technical specification and other operating requirements. This includes, but is not limited to, c6rrying'.out all required procedural operations, supervision of - trainees, logkeeping, etc.
- b. The second operator shall be designated the observing operator and shall be responsible for verifying that all actions taken by the prime operater are in strict compliance with any and all rules, reculations, tecnnical specifications and procedures pertaining to the operation of the GTRR.
3.1.2 At the beginning of each shif t or watch period, the prime operator shall enter the fact that he has assumed responsibility for the GTRR in the GTRR -logbook. At that time, the observing operator shall note his presence by indicating in the logbook that he has assumed those dutics.
J.1.3 If, at any time, for any reason, the operators should decide to exchange responsibility, it shall be formally entered into the GTRR logbook. ,
NOTE .
It is advisable for the two operators to exchange responsibility, particularly during periods of operation when there is little activity. This should be dene in order to enhance the operators' a!crtness. '
3.2 Normally permitted exceptions to the two operator requirement.
3.2.1 During the course of any ore hour, the observing operator may absent himself from the control room for a total of ten minutes, so long as he does not exit the containment building (does not open the inner airlock door, or enter the airlock if the door is open). .Thit action is not required to be entered in the GTRR logbook.
?.2.2 Snould it be necessary for the observing operator to leave the containment building (entering the airlock is, for this purpose, considered leaving the containment) he must obtain relief as follows:
- a. If his absence is to be longer than twenty (20) minutes, he must be relieved by an operator licensed by the NRC.
- b. If his absence is to be less than twenty (20) n' muhs, he may be relieved by, in order of preference:
- 1. A GTRR student
26 Procedure 2001 (Georgia Tech Research Reactor) Page 4
- 2. A knowledgeable person designated by the Director, NNRC.
- c. Any such relief shall be properly loo ed in the GTRR leg'ook.
c CAUTION <
UNDER NO CIRCUMSTANCE SHALL THERE BE PERMITTED A SITUATION WHERE THE REACTORIS NOT SHUTDOWN AND ONLY ONE OPERATOR AND NO OTHER PERSON (AS DESIGNATED ABOVE) IS IN THE CONTROL ROOM AND CONTAINMENT. IF THIS COf'!DITION CANNOT BE MET THE REACTOR SHALL BE SCRAMMED IMMEDIATELY AND BE PLACED IN A SHUTDOWN CONDITION.
3.2.3 If the time limits for relief noted above in section 3.2.1 are excccded by five (5) minutes, the reactor shall be shutdown in accordance with the above CAUTION. This exception is permitted only if compliance is unavoidably delayed yet immediately anticipated (eg., problems operating the airlock door).
NOTE Nothing in this procedure should be construed to relieve the basic requirement that whercycr the reactor is not secured, the micimum crew complement at the facility shall be two persoris, including at least one '
SRO. ,
l 4.0 DISCREPANCIES l
, '.1 if, during the course of operations, the observing reacter cperator l discerrs 8 violation of any rule, regulation, requirement, or procedure l he shall immediately and clearly bring it to the attention of the prime operator for correction. (
4.2 If the prime operator agrees that a discrepancy exists, he shall immediately correct the problem and make an appropriate entry in the GTRR logbook.
4.3 If the prime operator disagrees with the observing operator and if, af ter suitable but brief conversation has taken place to climinate the possibility of a misu"cc rM nding, agreement cannot te achieved, then the reactor shall immeciately be shutdown.
5.0 EMERGENCIES
.1 If the prime operatcr : :Omes incapacitated:
27 Procedure 2001 [ Georgia Tech Research Reactor) Page 5 S.1.1 if tne observing operator is present he shall:
- a. Press the SCRAM button (rec button at right en the console). Recorder pens thould move lef t,
- b. Take other action nece:cary to ensure resctor safety,
- c. Call for help i
28 C. Medical Evaluation of Sr. Feacto: i; cra cci .
Dr. Everett C. Ruglar, superintendent, Georgia Reg io nal Hospital in Augusta, is board certified in psychiatry and forensic psychiatry. In an oral report to Dr. R.A. Karam on April 4, 1988, he stated that he had, found nothing wrong either medically or psycholog ically with the senio'r Reactor Operator.
Dr. Kuglar's written report will be included in this report and sent to NRC as soon as Dr. Kuglar returns f rom a tr ip on May 15, 1988.
I
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29 D. Personnel Changes Radiation Safety The staff of the Office of Radiation Safety has been changed.
The two former staff members and the manager have been reassigned to other duties at Georgia Tech outside of the NNRC. Mr. Jerry Taylor, who has 12 years of-experience in health physics, has been reass igned f rom ho.t cell operations to health physics. Mr. Mike Puckett, an experienced radiation safety officer and former NRC inspector, has been appointed as acting Manager of the Office of Radiation Safety. Resumes of Mr. Taylor and Mr. Puckett are attached.
The Director of the NNRC has contacted three candidates for a new position of Assistant Director for Radiation Safety. Each of these people has a Ph.D. degree and extensive experience in health physics. Two interviews have been held. The first candidate proved unacceptable to Georgia Tech. The second was acceptable but financial negotiatior.s were not successful. The third candidate withdrew temporarily due to the recent unfavorable publicity. That candidate has now reconsidered and will come to Georgia Tech for an interview. A search for additional candidates is in progress, Hot Cell Operations Mr. David Cox has been assigned the duties of Manager of Hot Cell Operations in addition to his regular duties in reactor operations. Mr. Cox has demonstrated his proficiency with hot cell operations procedures to the satisfaction of State of Georgia inspectors and the Georgia Tech Nuclear Saf eguards Committee.
Management -
The position of Associate Directo. has recently been filled by Dr. Robert Macdonald. Dt. Macdonald is a graduate of Georgia Tech in nuclear engineering. He is familiar with the reactor and brings management as well as engineering experience to the NNRC. He is currently participating in the reactor operator training sessions and will obtain a senior operator's license. Dr. Macdonald's resume is attached.
Mr. Mike Puckett also enhances the management capacity of the NNRC. Mr. Puckett's knowledge of regulatory requirements and his skill in handling personnel issues have already proved of great value. Mr. Puckett is also participating in training for a senior reactor operator's license.
30 Conclusions These changes have already had a, beneficial ef f ect on statt morale and performance. No personnel- conflicts or bickering have occo'rred since the changes were made. Work is proceeding smoothly and personnel are cooperating;to assist one another. There is no rel uc ta nce to perform.any task regardless of the type. G eo rg ia
' Tech believes that the current staff is capable of safe operation and the personnel, problems of the past have been resolved.
To quote Dr. Bill Kerr of the University of Michigan, "The newly appointed health physics staff, and the commitment to an-additional staff member in the health physics area has added needed strength in this part of the staffing. It appears.that this move will also resolve some of the antagonisms that had led to a ,
needlessly adversarial relationship (one that could have -
compromised safety between the operating and health physics staff.
With the additional staffing, and the reorganization, morale in the staff seems to have improved markedly."
f u, ,
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l i
31 Robert Neill Macdonald, Ph.D.
160 Barkadale Drive N.E.
Atlanta, Georgia 30309 404/872-5383 Degree: Doctor of Philosophy Education:
Underaraduate Bachelor of Chemical Engineering, 1957, Georgia Institute of Technology, Atlanta, Georgia Graduate Master of Science in Nuclear Engineering, 1961, Georgia Institute of Technology, Atlanta, Georgia Doctor of Philosophy in Nuclear Engineering, 1966, Georgia Institute of Technology, Atlanta, Georgia Experience:
Goodyear Tire & Rubber Company, Akron, Ohio. Temporary job for summer 1956. Pilot plant work on synthetic rubber and plastics.
American Aviation, Inc., Los Angeles, California.
North Analytical Design Engineer in the Thermodynamics Group, June 1957 through December 1957. Assigned to a group designing the heating Left and air conditioning system for the F-100 fighter bomber.
to enter graduate school at Georgia Tech.
Pratt and Whitney Aircraft Corporation, Wes: Palm Det.ch, Florida.
Temporary position for summer 1960 as Research Engineer in the Advanced Technology Section. Project work included heat transfer and performance optimization studies of rocket systems.
Rocketdyne Division of North American Aviation, Inc., Canoga Park, California. Research Engineer in Advanced Design Section from March 1961 through October 1961. Performed heat transfer thermodynamic analysis of advanced rocket engine studies and concepts. Transferred to Atomics International Division in October 1961.
Aviation, Inc.,
Atomics International Division of North American Engineer the Systems Canoga Park, California. Research in Development Department fron October 1961 through March 1963.
Perforned core design studies and analyzed test stand results for SNAP nuclear reactors. Erphosis was on developing computer programs for solution of reactor physics problems. Left to enter the Ph.D. program at Georgia Tech.
i
2.
Gecrgia Institute of Technology, Atlanta, Georgia. I was in the first group of Ph.D. candidates admited to the nuclear Engineering program. This class was fortunate in being present for commisioning and initial startup of the reactor at the Neeley Nuclear Research Center. During my time in the program I was awarded an Atomic Energy Commission followship and a graduate teaching assistantship. I taught the introductory Nuclear Engineering course for two~ years. In 1966, I was in the first group of (2) students receiving a Ph.D. in Nuclear Engineering.
International Business Machines Corporation, Atlanta, Georgia.
Systems Engineer assigned to university accounts from April 1966 through December 1967. Work involved developing new computer applications in education and research. A major emphasis was on real-time data acquisition and control systems. Promoted and transferred to Washington, D.C. in December 1967.
International Business Machines Corporation, Washington, D.C.
Special representative for Data Acquisition and Control Systems from December 1967 through June 1969. Duties involved design of a hardware interface and programming system for nuclear physics data acquisition systems. Responsibilities also included technical sales support for laboratory automation in university and government research laboratories. Left to accept management position with a startup company in Atlanta, Georgia.
Infocybernetics, Inc., Atlanta, Georgia. Director of Research and Development from July 1, 1969 through September 1970.
Directed all technical activity relating to development of an automatic credit authorization system. This required design of special purpose point of sale credit authorization terminals, modems, automatic dialers, and embossed credit card readers.
Responsibilities included design of computer software to support real-time credit authorization terminals and the associated
> credit data base. I was also responsible for selection, installation, and operation of the computer system providing services to retailing and banking industries. Left when Infocybernetics filed for bankruptcy in September 1970.
Georgia State University, Atlanta, Georgia. Joined the faculty as Assistant Professor of Information Systems in January 1971; promoted to Associate Professor in September 1975. Taught both graduate and undergraduate courses in computer architecture and hardware, programming in both high-level and assembly languages, operating systems, and systems programming. Additional duties included serving as coordinator of computer syc;cnc for the Oc11ege of Business Administration and as director of the departmental computer laboratory. For several ;;- - ";; cf the department's graduate research assistants were ::c:: to the laboratory. I directed their activities in devt: ::.;rr a cross assembler and a PDP-11 machine simulator whic: r v. cn the
33 University's Univac 90/80 computer system. This software provided an effective multi-user environrc't for teaching assembly language, machine architecture, and systems programming.
The software has neu been roved to the University System's Cyber it is available throtch the university computer at Athens where system computer network. While at Georgia State, I was selected to serve on the Nuclear Safeguards Committee at Georgia Tech, a position which I still enjoy. I left the university in December 1985 to devote full time to my own business.
Automated Technologies, Inc., Atlanta, Georgia. ATI was founded in 1982 by myself and two other persons. In December 1985 I assumed full time duties as President and CEO of ATI. Our business is to develop and market computer based process information systems for industrial and municipal applications.
ATI's clients use our systems for boiler control, paper manufacturing, water plant, and sewage treatment plant control.
ATI manufactures remote control units to interface to real-time process signals, buys and resells computer systems with added software, and provides maintenance services for our equipment and software. ATI also provides consulting services for laboratory systems, maintenance management systems, special purpose computer based auditing applications, and . computer networks. ATI currently has 4 employees and sales of $400,000 per year. In addition to my duties at ATI, I have also served as lecturer in the University System Computer Science Institute held at Kennesaw College. This institute is supported by the Board of Regents for the purpose of developing skills of the computer science faculty at the smaller units of the University System.
Professional Associations:
Society of Sigma Xi IEEE Cocputer Society American Association for Advancement of Science Association for Computing Machinery Water Pollution Control Federation Papers and Publications:
"Nuclear Data for Reactor Studies." Nucleonics, August 1962.
(National /special interest journal, not refereed.]
"Supplemental Micror :;_ Cross Section Litrary for AIM-6 or FAIM," North Americ;.~ _hviation Technical Eppgrt NAA-SR-8082 (1963).
34 "Finetics Parameters of a Highly Enriched Heavy-Unter Reactor,"
Nuclear Encineerina Technical Report __flE-5, Georgia Institute of Technology, Atlanta, Georgia, April 1966.
"Cciculating Space-Dependent Reactor Transfer Functions Ucing Statics Techniques," Transactions of the American IIuclear Society, Vol. 8, No. 2, p. 501, November 1955. (coauthor: J.
Johnson) (National / Conference /Reforced]
"Calculation of Space-> Dependent Effects in Pile Oscillator and Reactor !!oise Measurements," Symposium on Neutron Noise Waves and Pulse Propagation, Gainsville, Florida, February 1966.
(coauthor: J. Johnson) (National / Conference / Refereed]
"Calculating Space-Dependent Reactor Transfer Functions Using Statics Techniques," Nuclear Science _and En1 ineeri_ng, 26:198-206, (1966). (coauthor: C. Cohn) (National / Journal / Refereed]
"A Method for the Analysis of Modulated Neutron Experiments."
Ph.D. Thesis, Georgia Institute of Technology, Atlanta, Georgia, 1966.
"Design of a Nuclear Data Acguisition System." Conference en the of Computers in the Nuclear _ Industry, Knoxville, Ef_fective Uses _
Tennessee', April 1969. (National / Conference / Refereed)
"A Two Dimensional Programming Language for Data Acquisition and Control." National Conference on the Use of On-line Computers in Psycholocy, Saint Louis University, October 31, 1973. (National /
Conference / Refereed]
"A Two Dimensional Programming Language for Data Acquisition and Control." Behavior Research Methods and Instrumentation, Mar;h 1974. (National / Journal / Refereed]
"RTS -
A Real-Time Operating System for the IBM 1800."
Information Systems Department Report, Georgia State University, 1973.
"CTS- A Computer Language for Real-Time Experiments."
Information Systems Department Report, Georgia State University.
1973.
"PASCAL-ll User's Guide." Information Systems Department Report No. ISD 78-6, March 1978.
"A Resolution to the Boolean Expression Evaluation Question."
Pascal News, Number 13, December 1978. (coauthor: M. Roberts)
' International /Special interest newsletter /not refereed]
"The Software Inductrial Revolution." International Conputer Syroosiun, Republic of China, December 16-18, 1980. (coauthors:
! D. Chand, R. Lamprey) (International / Conference / Refereed)
L-
f 35 Pl ingiyals of Programmino Usina Pascal.' Harper & Row, 1985.
(coauthors: M. Roberts, R. Lamprey) (Textbcok) i Patents:
"Method and Device for Cooling," a design for ~ a rocket engine based on'a principle- of non-regenerative
~
cooling. U.S. patent number- 3,267,664. August 23, 1966.
"Fault Location Apparatus in a System for Maintaining the Status of Credit Accounts." Filed July 23, 1970.
"Terminal Unit for Credit Account 1:aintenance Systems." Filed March 11, 1970.
"System for Maintaining the Status of Credit Accounts." Filed March 11, 1970.
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36 FISMiE John !!. Puckett 1270 West Peachtree Street, NW - 126 Atlanta, GA 30309 (404) 872-7604
{Mf!OYMENT HISTORY Period: August 1987 to present Firm: Georgia Power Company Address: 333 Piedmont Avenue, Atlanta, GA 30308 Supervisor: Len T. Gucwa, Manager, Nuclear Safety and Licensing Telephone: (404) 526-3718 Assistant to the Manager, Nuclear Safety and Licensing.
Perform an advisory function regarding the adequacy of Georgia Power Company response to Nuclear Regulatory Commission enforcement and licensing issues, participate as a member of the Corporate Nuclear Safety Subcommittee for operational issues and safeguards, regulatory compliance, evaluation of problems in all areas of licensed activity.
Period: July 1985 to August 1987 Firm: Energy Support Services, Inc.
Address: P. O. Box 6098, Asheville, NC 28816 Supervisor: Z. Vance Caudle, President Telephone: (704) 258-8888 Senior Consultant. Providing consulting services including adequacy of licensee response to NRC enforcement actions, participation as a consultant on lic.ensee corporate naclear safety committee, regulatory compliance evaluation, rind evaluation of problems ahd issues related to plant operations, quality assurance, radiation protection, radiochemistry, maintenance, and other licensee activities.
Period: April 1985 to July 1985 Fira: U. S. Nuclear Regulatory Commission, Region II Address: 101 Marietta Street, NH, Atlanta, Georgia 30303 Supervisor: Paul R. Bemis, Director, Division of Reactor Safety Technical Assistant, Division of Reactsr Safety: Responsible for review of correspondence, enforcement adequacy, administrative and personnel responsibilities as delegated by the Director. Acts as a technical resource for the director and provides evaluation of problems and issues.
37 Johm H. Puckett 2 Resume Period: April 1983 to April 1985 Firm: U. S. Nuclear Regulatory Ccmmission Supervisor: J. Nelson Grace, PhD., James- P. O'Reilly, Regional Administ,rators Director of Enforcement and Investigations Coordination Staff: Responsible for the implementation of the NRC Enforcement Policy in Region II. Maintained major responsibility for regional programs in all areas.
Trouble-shooter for the Regional Administrator. Dutics included evaluation of safety significance of occurrences, staff review and recommendation for enfc,rcement action, and liaison to other government agencies. Responsible for attending and participating in major enforcement conferences, Assured proper issue of all escalated enforcement correspondence. Member of Region II Principal Staff.
Period: Februhry 1982 to April 1983 Firm: U. S. Nuclear Regulatory Commission, Region II Enforcement Specialist: Qualified as BWR Senior Resident (not assigned to a plant). Drafted major enforcement actions.
Period: November 1979 to February 1982 Fira: U. S. Nuclear Regulatory Commission, Region II Senior Radiation Specialist / Radiation Specialist: Inspected radiation protection programs of regional powerplants and fuel f ab'ricators . Author of NRC Bulletins and Notices which contributed to the radiation safety of the nuclear industry.
Het qualification standard for CHP certification.
Period: September 1976 to fiovember 1979 Firm: Florida Pcwor & Light Company, Turkey Point Plant Operations Health Physics Supervisor: 3upervised 35 errployees. Has responsible for radiation safety for spent fuel pit rebuild, normal operational and unit refuelings.
Administered purchasing of materials, contract personnel and 3 million dollar waste disposal contract.
35 Johm M. Puckett 3 Resume Period: May 1975 to September 1976 Fira: RAD Services Inc.
Contract Sr. Health Physics Technician: Contracted for refueling and . steam generator repair work at Connecticut Yank.ee, Peach Bottom, Surry, and Turkey Point plants.
Period: September 1974 to May 1975 Firm: Morrison Knudson Inc.
Radiation Protection Technician: Ncrked as a technician for the refueling of the Navy's SIC prototype.
Period: April 1963 to July 1971 Firc: United States Navy Submarine qualified nuclear powerplant operator / instructor.
Engineering Hatch Supervisor (equivalent to PWR SRO).
Performed six Polaris Submarine patrols. Operator Instructor for 3 1/2 years at a Naval Prototype (land-based reactor).
EDUCATION Period: August 1971 to August 1974 School: Westfield State College (Hassachusetts State College System)
Hestern Avenue, Hestfleid HA 01085 Major: Psychology. Major GPA: 3.85. Overall GPA: 3.65/4.0. Major work also done in Physics, Philosophy, English and Fine Art.
BA awarded August, 1974.
Period: January 1982 to March 1982 School: USNRC Training Center Qualified as Boiling Hater Reactor Senior Resident Inspector.
Intensive course included systems, transient analysis, and simulator qualification on Browns Ferry simulator operated by TVA.
PERSONAL INFORMATION I am forty-three years of age and in excellent health. I maintain an avid interest in physical fitness, computer programming, painting and stairied glass, woodwork, swimming, and reading books of all kinds. Member of Hensa and the Atlanta Artist's Club. Patron, High Museum of Art, Member Atlanta Syrphony.
la BIGGRAPHICAL SKETCH TAYLOR, JER3Y E. Telephone: 9 ' 3-66 6 5 rieme Route 3, Box 3478 894-3605 Worr.
Hiram, Georgia 30141 Personal Data:
Born: Calhoun, Georgia - June 25, 1940 Health: Excellent Education:
Southern Technical Institute 1961 2 years Business Administration Graduate Douglas County High School 1959 E_mployment History:
Georgia Institute of Technology Health Physics 1988-Present Senior Radioisotope Lab Specialist 1978-88 Manager Hot Cell Operations Safety Engineering Assistant II 1975-78 Deputy Radiological Safety Officer Safety Engineering Assistant I 1972-75 Radiation Monitor 1968-72 Radiation Monitor Trainee 1966-68 Foreman of Custodial Service 1961-66.
C & S National Bank Addressograph-Multigraph Departinent 1960-61 Experience Summary:
The nature of work for Safety Engineering Assistant I, was technical and inspectional work in the administration of a safety, health, and sanitation program for Georgia Tech.
Work involved the inspection of buildings and facilities including shops and laboratories for fire prevention, health, sanitation and safety hazards. The preparation of inspection reports, including recommendations for improvements, were major responsibilities.
40 Jerry E. Taylor 2 Resume The nature of work for Safety Engineering Assistant II, w2:
skilled work in the Office of Radiological Safety involving tne formulation and administration of procedures for radiation control and the application of radiation detecting instrumentation to nuclear facilities.
The nature of work for Deputy Radiological Safety Officer is specialized technical work in the Office of Radiation Safety requiring the application of advanced skills and knowledge in radiation safety to nuclear research programs.
Work involves responsibility for conducting a complex radiation control program in research facilities where large amounts of radioactivity are in use.
Additional Experience:
- 1. Assist in kryptium production and shippino.
- 2. Operate and maintain hot cells and manipulators: Keep hot cells clean, decontaminate as needed. Keep special tools, etc. clean decontaminate as needed. Paint cell and isolation room when needed. Sweep and/or vacuum tops as needed.
- 3. Upkeep and maintenance of RAD waste system: Draw samples of RAD waste and have HP check before pumping waste to sanitary drain, keep waste tanks pumped out. Waste that cannot be pumped to sewer has to be treated or circulated through demineralizers. Keep sludge out of waste tanks by periodic opening of manhole covers and flushing out with water hose and submersible pump. Repair piping and valves to system as needed. Keep two waste pumps lubricated and in working order - repair as needed. Keep sump pumps (2)
Keep pump and in working order. Keep pump filters clean.
tank rooms clean. Maintain tank level indicators.
- 4. Storage pool: Keep storage pool clean by periodic vacuuming and skimming. Maintain acceptable purity conductivity by circulation through ion exchange columns with trasfer pump. Keep record of all materials stored in pool and see that it is properly placed and secured. See that unauthorized materials are not put or placed in storage pool.
- 5. De-lonizer rgnjp gelumns: Keep 4 units in working order and change re;ia o needed for proper pur'* .1tenance of poc1 log.
water; order nc rosins as needed. Kocp Maintain cuno filters (2) units.
42 Jerry E. Taylor 3 Resume
- 6. Still: Keep narnstead still operating by periedic ,
cechanical cleaning, and repairs. Take routine sample tc water purity. Repair still when needed. Keep maintenance log.
- 7. Hi-Bay area.and crano: Keep crane lubricated and in working order. Keep maintenance log. Keep Hi-Bay area reasonably clean and orderly.
- 8. Pecair and Maintenance of ten fume hood fans and filters for NRC labs roughing and absolute. Keep hot cell roughing and absolute filters clean by periodic changing.
Repair and maintenance of two large exhaust fans for hot cells. Keep maintenance log.
- 9. Package paper work and ship isotopes to customers.
Keep-up with shipping regulations for radioactive material. Keep records of all shipments.
- 10. Assist students and other users in setting up or moving equipment to prepare for and perform experiments.
- 11. Special clothing Room: Keep in orderly manner, order replacements as needed. Have checked and send to laundry, radiation clothing that is not radioactive or contam-
- inated.
- 12. Repair and maintenance of building vacuum pump. Keep maintenance log.
i
- 13. Check and maintain large pipe irradiator in storage pool.
Set-up Co-60 frames in hot cell and around pipe in pool.
- 14. Special set-ups for hot cell irradiations (removing hot cell blocks) perform dosimetry for hot cell and large-pipe (T.L.D. 800-in, Road, Calculate).
- 15. Loading and unloading of all equipment and objects for irradiation in hot cell. Small and large fork lifts and special equipment for loading and unloading trucks.
Maintain shipping department equipment and supplies.
- 16. Removing irradiated objects from cell, check-package paper work and ship nonradioactive objects back to customers.
- 17. Maintain all lights in high-bay, hot cell, pump and tank rooms and adjoining rooms and stairs, inside reactor Control ZonG.
42 Jerry E. Taylor 1 Resura
- 19. Maintain canning machine and tape machine, used in packaging isotopes and other shipments.
- 19. Plan and build:special-jigs and/or fixtures for isotopes shipments, hot cell irradiations and other experiments.
- 20. Ordering and/or purchasing supplies, equipment, and parts.
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43 E. Procedure Revisions The investigation which resulted from the cadmium spill of August 1987 has shown that procedures at GTRR need revision. At least two levels of revision are necessary. The first level corrects the immediate cause of the cadmium spill and mistakes which were made during cleanup. The second level of revistor. is required to provide a: long term solution and to bring GTRR procedures in line,with industry standards. These revisions are described below.
Lessons Learned from the Cadmium Incident A atudy of the cadmium spill identi fied deficiencies in four areas. These are:
Control of experiments inserted in the reac tor overirradiation of samples Handling of irradiated samples Record keeping Control of experiments has been improved by reducing the number of forms required by each experimenr. and prohibiting multiple runs of minor experiments following a single approval. The revised Procedure 3100, Minor Experiment Approval, is attached. This procedure forces approval on each and overy run of any minor experiment. Toe need for these changes had been recognized before the cadmium spill occurred. Procedural changes were in process, but unfortunately not complete, at the time this experiment was run.
Overirradiation of the samples resulted from the fact that Procedure 2012, Operating Log and Experiment Status Worksheets, did not contain a place to record the accumulated MWh of exposure.
Operators were trying to keep track of long exposures on separate pieces of paper and simply lost track of the MWh accumulated.
Revised copies of Procedure 2012 and Procedure 2004, Shift S.upervisor Startup Approval are attached.
Improper handling of the irradiated samples was caused from having no procedure to define proper handling practices. Lack of proper procedures was due to a philosophy of reliance on experience and training rather than on written procedures. A new Procedure 3107, Sample Handling, is now in effect. A copy of this procedure is attached.
Inadequate record keeping, particularly evident in radiation surveys and exposure data, was caused by a long history of lack of appropriate supervision of the health physics staff. Without supervision the health physics staff fell behind the state of the art. Under the guise of indepenfo-' . oor work habits and 1:w level technical performance becan; o accepted standard.
44 The reo rg aniz at ion o f .J uly 1987 was intended to correct the problem by providing closer supervision. Unfortunately the health physics scaff unanimously refused to accept supervision and tought steadily against every effort to improve their operation.
Ina d 2 qu c *.e performance and refusal to accept authority resulted in the r ea ss ig nmen t of all health physics personnel.
A review of health physics written procedures and unwritten practices showed that' total'r'evision would be necessary. This revision is now under way and is described in the next section.
Long Term Changes A review of the GTRH procedures for both reactor operations and health phycies has been done. We have concluded that while the procedures are for the nost part technically correct, they are not written at a level of detail which makes them usable for training.
They tend to be designed as checklists for individuals who are thoroughly f amiliar with the activities to be per fo rmed.
Deficiencies in these procedures have been recognized for some time. Previous attempts to modify the procedures have been met with resistance. NNRC personnel pref er red to have brie f procedures and to "rely on experience and training" rather than written descriptions for the tasks. The recent personnel changes have eliminated the resistance to upgrading our procedures.
4 Tc improve the procedures it has been decided to revise the entire collection so that they will be in standard format and have considarably more detail about each task. Procedures for managing the isotope source inventory and for performing surveys have been drafted. Copies of these procedures are attached.
Our target date for completing the revision is March of 1989.
In order to assure steady progress toward this goal, we will review each procedure in conjunction with operator training and requalification courses. As each topic is discussed in class, the corresponding procedures revisions will be identified. When ne procedure for the task exists, appropriate notations for creation of a new procedure will be made. Each procedure modified or created will be approved by the Nuclear Saf eguards Committee before it is placed into effect.
Conclusions Georgia Tech believes that the procedures now in place correct the deficiencies that were identified during the inspection.
Georgia Tech also believes that the procedures will permit safe operation while a new set of procedures is developed.
45 1 GEORGIA TECH RESEARCH REACTOR t
'hapter 1 1 Procedure 3100 5 i i Last Rev. 02/04/88
/.uyij ; , ry i 5 Last lle v . App. 02/04/88 bystems i Minor Experiment Approval % Page 1 of 1 Rev D Acccant Number to be charged: GTRR Referencc .. umber; har.c.of
Contact:
Desired Irradiation Data: -
Date: Facility: Power Level (Flux):
How Long7 + Weight Form Material to be irradiated:
Cherscteristics of Container & Isotopes (Attach copy of calculations): ;
Estimated Estimated Estimated Isotope Activity Isotope Activity Isotope Activity sentainer Total at end of irradiation
Estimated------------ ----------Observed------------
>se date/Dist Beta Gamma Beta Gamma factivity In.RR I ok/k In.RR % ok/k (A Considerations: Encapsult. tion-Code:
!. i l l there be any noticable effects from: (attach explanation if Yes)
'lempt ra ture Cnanges: Pressure Changes:
':a t e r i a l s : Chemical Reactions:
apccial Instructions: _ _ _
. .i PROV A'.5 : :
heactor Supervisor Date
':;r. Jffice Rad. Safety Date irectar Date zetual 'rradiation:
.actttty Power Date End of Total Time Irradiation Operations Date
> t mc r e 1 significant difference between the estimated and actual dose '
-uctivity effect ( v /:: )
- ? If Yes, a t tach c: ^1ana ticr: and
- . .etor.
aucit._ cy: Date:
. ~ , . - . ___._ ._,..-__-.~ _ ._,_,,.- _,._ ._.,_ . -
l 46 i GEORGIA TECH RESEARCH REACTOR 1 I Chapter i i Precedure 2012 4 % il Lart Rev. 02/04/88 Normal i Operating Log i Last fav . App. 02/04/86' Operation i Experiment Status 1 Page 1 of 2 Rev D The purpose of this procedure is to record the information pertaining to experiments run that day. This facilitates the review of experiment status before the next day's reactor operation. The following definitions and clarifications apply to the information needed to complete the data sheet of this procedure. The data sheet should be completed at the end of each day.
A. Facility: is the actual port number, vertical or horizontal, the experimenter is using. When training or class demonstra-tions are the object of operation, the wcrds "training" or "all" should be entered.
B. Experiment: a brief description of the experiment being run.
C. GTRR Reference Number: All experiments must have approved experiment numbers D. Desired MWH: is specified on the experiment approval form and should be recorded here i E. MWH Today: the megawatt-hours for each experiment for the day will .
be rounded to three (3) significant numbers. Example:
reactor runs for 13 minutes at 100 kw. MWH - 13 minutes /
60 min /hr
- 0.1 mw - 0.02167. Rounded off, this becomes 0.022 MWH F. MWH Cumulative: allows the total HWH for samples in the reactor for core than one day to be carried forward. 'For samples in the reactor for only one day or less: MWH Today - MWH Cumulative G. Remarks: gives the operator the opportunity to record any comment which might help reconstruct the conditions under which the experiment was run.
H. Power Level - Hours-Min - HWH: give the details regarding the power level, the length of time in hours and minutes at that power, and the computed megawatt-hours at that power.
I. Summary: the entries MWH for Date, Previous MWH for Week, Total MWH-Week to Date, Previous Total MWH, and Total MWH to Date are designed to allow the actual cumulative megawatt-hours for the GTRR to be determined.
J. General Notes: regarding the mode of shutdown, details about experiments run or noved, clock times for reactor power, remarks about whether or not the reactor wa3 ,tratet during that day, etc.
47
% GEORGIA TECH RESEARCH REACTOR t
{ Chapter i 1 Procedure 2012 4 1 t Last Rev. 02/04/88 dormal- 'i Operating Log i Last Rev. App. 02/04/88' 10peration i Experimen: Status is Page 2 of 2 Rev D Date Completed By:
GTRR ~ Desired MWH Mwh Facility. Experiment Ref. No. MWH Today Cumulative Remarks 1
- Ceneral Notes: Include SCRAM cause; assume normal shutdown if no note i 1 i
~
I Power
- Level Hours-Min MWH MWH for Date Previous MWH for Week Total MWH-Week to Date MWH for Date Previous Total MWH i
Total MWH to Date l
I
48 i GEORGIA TECH RESEARCH REACTOR %
Chapter i % Procedure 2004 4 i Shift Supervisor i Last Rev. 02/04/88 c r : a ?. 1 Startup Approval i Last Rev. App. 02/04/83
'J r e r c t i o n i _\ Page 1 of 1 Rev B
-Weekly Shutdown Checklist complete All electrical jumpers are on jumper beard
.;eekly ?recritical Checklist complete All bypassed instruments Daily Precritical Checklis,t complete appropriately tagged field Checklist complete Select Log !? - Period system to be recorded
'rocess Systems operating Select Picoammeter channel Process Equipment Roon clear to be recorded
, ECCS System operable Estimate readings at operating power:
Annunciator Panels clear Leadir.c correct Shim Blade bank
. Mode Regulatin8 rod in operating power kw Pico #1 amp pecial Instructions Noted below Pico #2 amp inperimental area ready Log N - Per #1 %
shielding in place (except as noted Log N - Per #2 I below)
Flux Amp #1 %
. ort and Thermal shutters closed texcept H-4) Flux Aup #2 __ I Experiments ready (Experiment Approval Form (s) i S Experiment Status Log reviewed)
.? proved for Startup:
Shift Supervisor Date Time inecial or abnormal conditions:
.: 3 1 GEORGIA TECH RESEARCH REACTOR %
{hapter 1 i Procedure 3107 5 t i Last Rev. 04/06/ds Auxiliary i t Last Rev. App. O'/06/ns Systems i Sample Handlinc $ Pa_cc 1 of 1 ,_
- 1. Purpose To allow the safe opening of irradiation containers of radioactive materiale; and to limit or e. valuate the contamination potential and/or radiation dos'c to f acility personnel and the public in the event of an encapsulation failure.
II. Experimenters
- a. Containers of radioactive materials received at the NNRC shall be opened in appropriately ventilated fume hoods. 1his pro-cedure applies to all containers regar'less of the physical form or point of origin of the material. It also applies to radioactive materials produced in the GTRR through vertical or horizontal experimental ports or the rabbit system. Exceptions to this rule are possible provided written approvals are ob-tained f rom the Reactor Manager, Manager of the Of fice of Rad-iation Safety, and the Director or Associate Director of the facility (a Radiation Work Permit).
- b. Two persons are required to be present when irradiation con-tainers of radioactive materials are opened in fume hoods. 'J n e person to do the actual opening and the other to conduct surveys to determine the radiation dose levels and whether or not there is loose contamination. The two person requirement does not apply to opening rabbit samples in the fume hood of the Neutron Activation Laboratory. The activities of irrad-iatnd samples that are pneumatically delivered to the Neutron '
Activation Laboratory shall be limited to approximately 100 rarem/ hour at 2 inches from the rabbit 'c surf ace.*
- c. Prctective clothing as specified on the RWP shall be worn ouring the handling of radioactive materials. Appropriate cab-incts for clothing stora8e in strategic locations will be provided.
- d. When the handling of radioactive materials has been completed, protective clothing shall be taken off, surveyed for possible contamination, and, if found clean, returned to the storage cabinet. Contaminated clothing shall be discarded in radioac-tive waste.
- This 100 mrem / hour value was chosen somewhat arbitrarily and will be reevaluated after operational experience is 8ained.
50 i GEORGIA TECH RESEARCH REACTOR t
.1 apter t t Procedure 3107 5 t~ t Last hcv. 04/06/So Auxiliary '
Last Rcv. App, a / ' o f ,' s Systems i Sample.Handline i Page 2 of 3 111. Procedures for Radioactive _ Spills If spills of radioactive materials should ever take place, our pri-orities shall be to first and foremost protect the public, to pro-tect personnel, a.nd to minimize damage to the facility. Protecting the public means taking steps to contain the incident and prevent the uncontrolled release of radioactive materials to the environment.
- a. The person (s) involved shall immediately inforr the Di rec tor ci the NSRC or his designated alternate of what had happened and shall take steps to make sure that contamination which may be on him (or her) is not spread to other locations.
- b. The NNRC Director together with the Manager of the Office of Radiation Safety and others will map out a plan to handle the emergency. Elements of the plan should include the following:
- 1. Contain and isolate the possible spread of the contamination
- 2. Attend to the medical and personal needs of the person (s) who may be contaminated. This shall include the quantita-tive evaluation of:
- a. the contamination on the person (s),
- b. the quantities inhaled and ingested by use of a whole body counter, and
- c. skin and whole body dose due to any contamination which may be present on the person (s).
require the analysis of The quantitative evaluation may /or fecal samples. Records nasalswipes, of the analyses sputum shal[ urine,andbe kept in a central file on the incident.
- 3. Immediate steps shall be taken to decontaminate the person (s) involved.
- 4. Provide medical assistance and/or observation by qualified physicians as needed
- 5. The spread of contamination must no be allowed to take place. However, if due to unforseen factors, the contam- to ination spreads to locations outside the NNRC, a program deal with it shall be developed immediately. Again, the determination of how much contamination went where is essential and records of this determination shall be kept in the central file. It is also important to immediately remove any and all contamination fron locations outside the NNRC. Georgia Tech authorities, the state, and the NRC shall be notified as appropriate, and may be requested to provide assistance.
(
a
51 t GEORGIA TECH RESEARCH REACTOR 1
' CFapter i i Procedure 3107 5 t t Lact Rev. 04/06/8s Auxiliary '
t Last Rev. Apr. L4/06/hd Systems i Sample Handling i Page 3 of 3
- 6. Develop a program to determine quantatively the extc.it v:
the spill within the NNRC and how much went where. Inis shall consist of making surveys, using appropriate survey meters, panoramic. smears of all-surfaces including vertical walls. Determination of the contamination in the air shall
~
be made. All data and records shall be placed in the central file for the incident.
- 7. Use the instrument of the Radiation Work Permit (RWP) tc devise a plan for decontaminating the affected areas in the NNRC. Breathing zone air monitoring shall be continuous during decontamination if required; otherwise the contin-uous area air sampler will be utilized to determine airborn activity. Appropriate attire during decontamination is specified on the RWP. Dosimeters for measuring the dose received during the decontamination period by workers must be worn. These dosimeters shall be initialized before the work begins and shall be read after it is finished. All data must be placed in the central file for the incident.
- 8. Dose reconstruction for the affected person (s) shall be made and recorded.
- 9. An overall report of the incident shall be made and dis-tributed to the state and NRC in accordance with 10 CFR 20.403 and 20.405 requirements. The Nuclear Safc8uards Committee shall be informed of all incidents.
- 10. Determine reportability.
[
52 Georgia Tech Research Reactor Precedure 9501
' ' i r C n r g e .1 - CONTROL AND Revision 00 ACCOUNTABILITY OF Approved --/--/--
- &~ ~ / / RADIOACTIVE SOURCEO Page 1 of 12 1.0 PURPOSE The purpose of this procedure is to describe the methods employed at The Georgia Institute of Technology (GT) for control and accountability of radioactive sources, from receipt to disposal.
2.0 PRECAUTIONS AND LIMITATIONS 2.1 Scurces not in use er installed in equipment shah be maintained in a locked storage facility with the keys under tho administrative control of the Principal Investigator (PI).
2.1.1 A storage f acility is a space, room or cabinet marked conspicuously with the radiation symbol, the words "Radioactive Materials" and the -
words "Authorized Storage Facility", if a cabinet or refrigerator, etc., is the storage facility, the room containing the cabinet shall also be marked with the radiation symbol and the words "Radioactive Materials".
2.1.2 Storage facilities shall remain locked while unattended.
2.2 Personnel handling radioactive sources shall exercise control measures such as time, distance and shielding to maintain exposures As Low As Reasonably Achievable (ALARA).
2.2 Personnel handling radioactive sources should be aware of the type of hazard involved, e.g., eye dose due to beta emitters cr serious internal hazard due to alpha emitters.
2.4 Sources of different nuclidos will not normally be mixed. Exceptions to this requirement are discussed in step 2.5 of this procedure. If a certified traceable mixed source is required, such sources will be obtained, with appropriate certification, from an approved vendor.
2.5 Sources which are not used for calibration of an instrument may be combined to make a mixed source used for performance checks of '
instruments, experimentations, or other appropriate use for non-traceable sources. Combining of sources shall be done only under the supervision of the appropriate Pl. The Pl shall determine which sources can be combined.
CAUTION 1
Care must be exercised when contining t
+ , - - - - . , - - --
- -- - - ,- .e., . . - -,m, - -
+, , c,---
53
+ . :m 0009.00a Page 2 of 12 sourcc: to accure any chemical or other reaction resulting from the combination is anticipated and compensatory measures arc taken to protect personnel.
2.9 Sealed sources containi..g licensed-materials shall not be cpencd or
.Otherwise breached..
.J . 7 l.icensed matchials shall not be used in or on human beings, or in any activity or' application where activity is released to the environment except as provided by specific conditions of the GT Radioactive Material License.
.o A precisicn of three (3) significant figures is recuired for all data recorded undar this procedure unless specifically exem; tcd by tha Manager. Of fice of Rcdiation Safety.
J. . CONTROL AND ACCOUNTABILITY Of RADIOACTIVE SOURCES 3.1 RECEIPT AND SYSTEM ENTRY J.'.' The Of fice of Radiation Safety (ORS) shall take custody of all i radioactive sources and materials received at GT within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> during normal working hours or within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> af ter the start of the working day following receipt on campus (unusual weekend or night delivery). -
Persons receiving such shipments during of f-hours should notify the MORS as soon as possible.
NOTE Each sealed source acquired from another l person ant. containing radioactive material, .
other thar. hydrogen-3, with a half-life greater than thirty d3ys and in any form other than gas shall be tested for contamination and/or leakage prior to use. In the absence of a certificate from a transferor indicating that a test has been made within six months prior to the transfer, a sealed source received from another person shall not be put into use until tested. The test shall be capable of detecting the presence of 0.005 microcurie of radioactive material on the test sample. The test sample shall be taken from the 50'1e0; source or from the surfaces of the device in which the scaled source is permanently or semipermanently mounted or stored on notch one might expect contamination to accumulate. Records of leak test rewts :;all i be kept in units of microCuries and maintained for inspection by the De r '"
of Human Resources of the State c' u.
l L
. 54
- w 0009.00a Pago 3 ot 12 CAUTION IF THE TEST REFERRED TO IN THE ABOVE NOTE REVEALS THE PRESENCE OF 0.005 MICR! CURIE OR MORE OF REMOVABLE CONTAMINATION, THE SEALED SOURCE SHALL IMMEDIATELY BE WITHDRAWN FROM USE. THIS EVENT REQUIRES FtEPORTING TO THE STATE OF GEORGIA IN ACCORDANCE WITH THE RADIOACTIVE MATERIALS LICENSE.
J.1.2 Af ter transportation and receipt survey recuirements have been met, the' source will be entered in the RADIOACTIVE SOURCE ACCOUNTABILITY MASTER INDEX.
- a. A sourco number will 60 assigned as foU:ws:
- 1. The source number will consist of three parts:
- a. The Pi identification Numtet b_. The consecutive source number for the Pl
- c. The split number d_. For example. 008-021-00; meaning: PI number 08, source number 21 split 0 (meaning no split).
- 2. For splitting sources, see part 3.7 of this procedure.
- 3. For combining sources, see part 3.8 of this procedure.
- b. Enter the atomic numbegnuclide or chemical symbol and mass number, e.g., 27Co
- c. Enter the half life in days, e.g., 9230 or 6.23 E+04
- d. Enter the Cssay date (mm/dd/yy)
- e. Enter the physical form (solid, liquid, gas, powder, scaled scurce, etc.) that best describes the source material.
- f. En:ct the enemical formula for the source, if known. This entry is "NA" for sealed sources.
- g. _ : 'r tre specific activity in citne- millicuries /g am or
~ 'hCuries/ milliliter, if known. This entry is "NA" for
05-
??dare 0009.00a ; Page 4 or 12 scaled source:.
- h. Enter tho total activity in -millicuries,
- i. For manual entrics, current activity is entorcd as "NA".
For computer entries, this value is calculated .by the computer.
- j. Enter the storage location. This entry should be descriptive Jenough so that a person knowledgable of the. campus'could easily. locate the source.
3.1.3 A copy of the updated RADIOACTIVE SOURCE ACCOUNTABILITY >
t.1 ASTER {NDEX s. hall be provided to the Pl by -the f
- ORS.
2.:.4 The source shall be stored in an approved container.
NOTE Only those source containers approved by the MORS in advance may be used for storage of radioactive material.
J.:.5 , - Affix to ths source container a tag or label with the following information:
- a. The words "RADIOACTIVE MATERIAL"
- b. Isotope 9 c. Acitivty (mCl)
- d. Specific activity (mCl/gm or mci /mi as appropriate, or-
"NA") ,
4
- e. Source Number ,
- f. Assay Date l
I' g. Physical form
- h. Chemical formula
.i
- i. Storage location NOTE !
Only storage locations approved in advance by the MORS may be used for the storage of radioactive material. !
4 NOTE
,6
- - A.re 0009.00a Page S of 12 cxempt sources may be excluccd from the above label / tagging requirement if the source is labeled by the manufacturcr or ver4 dor with the following information:
EXEMPT RADIOACTIVE MATERIAL ISOTOPE ACTIVITY -
The source number will be marked on the source by the MORS or, if more appropriate, the number will be placed on the source container.
J.1.G Store the source in its storage container in an approved storage area.
NOTE Storage areas shall be approved by the MORS before their use to storc radioactivo material.
c.2 Pl ACCOUNTABILITY; CHECKOUT AND RETURN
'.:.1 Sources that are in use shal' be accounted for through the use of the RADIOACTIVE SOURCE USE LOG.
3.2.2 Personnel using exempt quantity sources in the same work area as the storage facility need not use the RADIOACTIVE SOURCE USE LOG.
Exempt quantity sources, though carried on the accountability master list and inventoried as other sources, are a special case. Exempt sources shall be marked with the words "Exempt Radioactive Material", the isotope and activity. -
3.2.3 The RADIOACTIVE SOURCE USE LOG e.l.3.1 When an individual desires to use an accountable source, except an exempt source in the immediate work area, the following procedure is used:
J.2.3.2 Permission is obtained from the PI to use the source.
J.2.2.3 Tn3 following entries are made in the log:
- a. Source number,
- b. Isotope,
- c. Date Removed,
- d. Signature of the individual using the scurce J. Use location. This is a description of the place of un -
the source sufficiently descriptive so that the PI can ,
57
< 06: W 0009.00a Page 6 of IP locato and retreive the source, if necessary.
NOTE Sources shall not be awLy f rom th0 storage location for longer than seven consecutive days except as specifically noted below. When uhattended,'as in an experiment,- for example,
. the experimental area must be locked when the source is unattended and the area must conspicuously marked with the radiation symbol and the words "Radioactive Material".
- .2.2.4 When the source is returned to the storage !ccation the follo.ang !cg entries are made:
- a. Date returned and
- b. Signature of the individual returning the source.
NOTE If it is necessary far a source to be removed from the storage location for a period in excess of seven days, a new storago location should be identified and a transfer of the source should be performed using the RADIOACTIVE SOURCE DISPOSAL RECORD (PI) (see section 3.9 of this procedure) and a new entry in the RADIOACTIVE SOURCE ACCOUNTABILITY INDEX. ,
t 3.: ..: Weekly, the PI will review the RADIOACTIVE SOURCE USE LOG and verify the location of all sources assigned. The log entry across the next blank sequential line should be "(date) all sources accounted for (signature of PI)". Any missing or unaccounted sources shall be reported to tne MORS promptly.
NOTE Upon discovery that a source is missin0, the MORS shall institute an immediate search for the missing source. Should the sourCO fail to be recovered, the Pl shall return all remaining assigned sources to the MORS for safckceping until a review of the circumstances has been conducted by the Nuclear Safeguards Committee.
.2.f the RADIOACTIVE SOURCE USE ' OG shall bc kept at cach stc m Iccation, J.J USE OF THE SOURCE
58
.- t . uere G09.00a Page 7 of 12 CAUTION DO NOT LEAVE THE SOURCE UNATTENDED EXCEPT AS NOTED IN SECTIONS 2.1.1, 3.1.6 AND THE NOTE FOLLOWING SECTION 3.2.3.3 OF THIS PROCEDURE.
NOTE Certain sources used for instrument responso checks may be mounted on encumbering devices and are excluded from the following requirement.
- . .i Af ter checking out the source (section 3.2 of this prcccdure) transfer it directly to the work area. Sources shall be transported in the storage container e r a shicidud contamcr, as appropriate.
CAUTION TRANSPORTATION OF SOURCES IN LIQUID FORM REQUIRES SPECIAL PROTECTIVE MEASURES TO BE TAKEN. SUFFICIENT ABSORBENT MATERIAL SHALL DE MOVED WITH THE SOURCE TO ABSORB THE FULL QUANTITY OF SOURCE MATERIAL IN THE EVENT OF A SPILL.
CAUTION DO NOT TOUCH THE SURFACE OF THE
, ACTIVE AREA OF ALPHA SOURCES SKIN CONTAMINATION AND/OR DAMAGE TO THE SOURCE MAY OCCUR.
NOTE Personnel handling neutron sources will document neutron dose received in accordance with appropriato procedurcs.
,. .3 A handling device such as tongs will be used to remove a high activity sa;rce from its storage container.
.. 4 Place: the source in the proper position for its intended usc. Ensure the active surf ace of the source is toward the thing to be exposed.
.. .' 'cco completion of the usc of the scurcc, return it to its preocr acrage location in accorda::e witn section 3.2 of this proct. dure.
'1/dNTENANCE OF SOUPCE^
Scarces and source containtr; shall be maintained in good r: pair and be l
L.
59
'eu e 0009.003 Page 8 of 12 kcpt clean.
- .4.2 Do not use tools, abrasives or solvents on a source. Use only cemincralized water to c!can sources. Rub surfacco lightly. Do not attempt to clean the active area of alpha sources.
CAUTION DROPPED SOURCES SHOULD NOT BE USED UNTIL RETESTED TO ASSURE NO DAMAGE OCCURRED.
3.4.3 Sources which have cutlived their usefulness will to disposed of in ca approved manner. The MORS and Pl shoJld Review the RADIOACTIVE SOURCE ACCOUNTABILITY MASTER INDEX periodically and determine which sources will be discarded. Sources discarded will be deleted from the RADIOACTIVE SOURCE ACCOUNTABILITY MASTER INDEX ty drawing a line through the entry and entering the required informaticn on the RADIOACTIVE SOURCE DISPOSAL RECORD (PI) in accordance wit'i section 3.6 of this procedure.
3.4.4 Laucis will be replaced if faded or illegibl'e.
3.4.5 Steage cabinets will be maintained in a clean and orderly manner.
Locxing mechanisms shall be maintained in working order.
3.4.3 Damaged, suspect or leaking sources shall not be stored in the same location as usable and/or in-use sources.
3.J.7 Store flammable sources only in approved storage locations designed to accomodate flammable material (e.g., toluene based sources).
J.J.8 High level sources will normally be shielded while in storage to prevent i unnecessary exposure to personnel.
e.4.9 Liquid sources will normally be stored in containers with suf ficient absorbent material to prevent contamination of other sources in the event of leakage.
3.4.10 Gaseous sources will have the fill and vent connections capped. valve handwheels removed or lockwired, or be otherwise secured to prevent inadvertent opening.
3.5 INVENTORY OF RADIOACTIVE SOURCES
?.5.' inventory of radioactive sources shall be performed every six (6) months except for alpha emit..ing sources which are inventoried every three months. At the same U.no of the inventory, scaled cources shall be checked for leakage.
- a. Each scaled source f abricated by GT shan be inspected and tested for construction defects, leakage, and contamination prior to use or transfer as a scaled Ecurce.
60
.. .: . .e C000.00a Page 9 of 12 NOTE If the inspection or test reveals any construction defects or 0.005 microCum er greater contamination, the source shall not be used or transferred as a scaled source until it has been . repaired, decontaminated and retested.
- b. Each sealed source containing radioactive material, other than Hydrogen 3, with a half-life greater than thirty days and in any form other than gas shall b0 tested for leakage and/cr contaminatien at intervals not to exceed six months except that cach source designed for the purpose of omitting o!pha particles shall be tested at intervals r.ct to excccd three months.
NOTE The test shall be capabic of dctccting the presence of 0.005 microcurie of radioactive material on the test sample. The test sample shall be taken from the scaled source or from the surface of the device in which the scaled '
source is permanently or semipermanently mounted or stored on which one might expect contamination to accumulate. Records of leak test results shall be kept in units of microCurles an
- maintained for inspection by the State of Georgia, Department of Human Resources. this test doe $0 U EN'I U $ O'
- sources containing g Co while used in the Nuclear Research center (NRC) storage pool and hot cell.
CAUTION IF THE TEST REQUIRED BY THE ABOVE NOTE OR A SIMILAR TEST PERFORMED UPON RECEIPT OF A NEW SOURCE REVEALS THE PRESENCE OF 0.005 MICROCURIE OR MORE OF REMOVACLE CONTAMINATIOiJ, THE SOURCE SHALL IMMEDIATELY BE WITHDRAWN FROM USE AND THE MORS SHALL IMMEDIATELY BE NOTIFIED. THIS EVENT IS REPORTABLE UNDER THE RADIOACTIVE MATERIALS LICENSE.
a.f.: Ct:ain ceries of the current RADIOACTIVE SOL ACCOUNTABILITY MASTER INDEX for the appm-
- Pl.
61 i
L .e::ure 0009.00a ,
Page 10 of 12 NOTE Installed sources need not be removed.
Verification of the sourco by the use of the component detector, a hand-held instrument or other appropriato means is sufficient.
e.5.3 Inspect cach dource for physical damage or other deficiencier.
J.5.: For each source, note-its condition as satisfactory or ut. satisfactory.
Verify the storage location and initial each line. Report and missing or damaged sources to the MORS immediately.
e.5.- The completco copy of the RADIOACTIVE SOURCE ACCOUNi ADILITY MASTER INDEX will be irwarded to the MORS upon completion of the source inventory.
3.6 CISPOSAL OF SOURCES 3.6.1 Permanent disposal of a source:
- a. Obtain Permission from the MORS and responsible PI to permanently dispose of any radioactive source. Execptions to this requirement are discussed in sections 3.6.2 and 3.G3 of this procedure,
- b. The MORS will designato the method of disposal of the source.
- c. Complete the storage location of the RADIOACTIVE SOURCE ACCOUNTABILITY MASTER INDEX and indicate "Disposal" as the location.
- d. Complete the "Disposal" section of the RADIOACTIVE SOURCE DISPOSAL RECORD.
- e. Dispose of the source as prescribed.
- f. Remove any labels from the source container if retained.
J . .: . 2 Transfer of sources to another Pl
- a. Notify the MORS of the intenced transfer,
- b. Complete the storage location of the RADIOACTIVE SOURCE ACCOUNTABILITY MASTER INDEX and indicate "Transferred to (PI)" as the location.
- c. Complete the "Disposal" section of the RADIOACTIVE SOURCE DISPOSAL RECORD. Indicate "Transferred to (PIT' as the method of dispcsal.
- c. The MORf ' hon initiate a now entry on the receiving
G2 n . . .e 0009.003 Page 11 of 12 PI's RADIOACTIVE SOURCE ACCOUNTABILITY f.!ACTER
~
INDEX, as th0 ugh the trurco involved hr.d becn reccaco from outside of GT.
NOTE The preferred method of permanent disposal is for the responsible Pl to transfer the source t'o the MORS, who will accomplish the -
permanent disposal. Note also the provision for partial source disposal in section 3.7 of this procedure.
- 1. - SPLITTING SOURQES '
- .'. If the source is split (subdivided) cach part resultin0 from the split will have a new split number assigned. New sourcc/ split numbers sh ll be entered on the RADIOACTIVE SOURCE SPLIT RECORD. This subdivision record will be part of the source inventory audit.
NOTE No more than four splits can be made from one source at any one time, which is to say that each spilt must be accounted for on one RADIOACTIVE
., SOURCE SPLIT RECORD FORM. It can be demonstrated that proper use of this form does not interfere w'ith experimental procedurcs.
NOTE When a portion of a source is expended in the course of an experiment or other manipulation, that portions should be split from the original source and then logged out on the RADIOACTIVE SOURCE DISPOSAL RECORD (PI).
J.7.2 The first step in splitting a source is to log out the entire source on the RADIOACTIVE SOURCE DISPOSAL RECORD (PI). The method of l.
disposal in this case is "spilt".
2.7.3 The same source is then entered in the RADIOACTIVE SOURCE SPLIT RECORD's first entry.
J.7.4 Next, enter the information for up to four splits, including the remainder of the original source. Note that the romainder is assigned a new Eplit number.
l
) .i DECAY CORRECTIONS I
l J.J.1 Decaf ccrrection will normally ta donc by the MORS in the ~ ;;.r irvantcry.
I 1
l
.w . . = _ : = - =. . .v r.-- m ~ . _ a=,- - - - . . . . . - . , _ . . .
63 r: ecure 0009.00a Page 12 of 12
.3.? For the convenience of thC Pl the following formula is used:
A = A c' I
[ ,Where: A = final activity Ag = initial activity e = base of natural log 6 = Decay constont = .G93/ half-life t= time elapsed
.: .0 RECORDS RETENTION 1
4.1 Completed logs, other source records, disposal records, NBS Certification Papors and Shipping Papers will be kept for archival purposes and to permit regulatory agency review.
4.2 All records will be sent to the MORS for review and filing.
5.0 REFERENCES
5.1 10CFR20 Standards for Protection Against Radiation 5.2 10CFR30, Rules of General Applicability to Domestic Licensing of Byproduct Material.
5.3 10CFR70, Domestic Licensing of Special Nuclear Material.
- .: Technical Specifications, Appendix B. USNRC License Number R-97.
' 5'
. GTRR Safety Analysis Report.
2.0 State of Georgia Radioactive Material License Number GA147-1.
I
64 F. Regulatory Sensitivity Training Historically, in the early 1980's, Ca rolina Power and Light's (CPL) Brunswick Nuclear Power Plant was experiencing great difficulty in meeting the Nuclear Regulatory Commission (NRC) requirements for safe operation. After much analysis, the cause for these problems was attributed to the past establishment of a negative "culture" at'that facility which was characterized by a generally unprofes'sional attitude which pervaded the plant staff, both management and workers.
In order to correct this negative attitude, LoL instituted a series of lectures and discussions which were presented by CPL executives, management, and even representatives of the NRC. In time, these efforts were successful in reducing the numLer of noncompliances identified at the facility. Additional benefits appeared to be the enhancement of morale and an overall improvement in the appearance of the facility. These enchancements, it is presumed, resulted in an over:11 improvement in the degree of safety at the plant.
When the Neely Nuclear Research Center (NNRC) received the NRC order limiting operations in January,1988, an examination of the overall nature of the problemn at the center was undertaken by the NNRC staff. The examination revealed some similarities to the problems seen at CPL and other f acilities where a Regulatory Sensitivity program had been undertaken and proved helpful. The NNRC had a serious morale problem. Also, there were some examples of failures to comply with requirements.
The Regulatory Sensitivity Program initiated in March 1988 by the NNRC has three elements: (1) initial discussions have already been held with the facility staff with regard to what regulatory sensitivity is; (2) a portion of each weekly staf f meeting is set aside for discussion or presentation of issues related to regulatory sensitivity; and (3) a staf f member has been assigned to review NRC Notices, Bulletins and Circulars, as well as other sources of industry experience, to discern examples of both good and poor performance for presentation to the staff.
Because of the small size of the NNRC staff, the program is not as rigidly formal as that undertaken by CPL and others, but its informality does not detract f rom its potential ef fectiveness.
Whereas, in a large corporation it is impossible for management to demsonstrate consistent professionalism by example, at NNRC management is always highly visible, similarly, at the working level, each worker inter f aces with nar agement on a daily basis and has his/her professionalism evalentcJ c on st an tly.
65 In the future the weekly staff meetings' Regulatory Sensitivity Program will include discussions of new regulations and requirenents, evaluation of industry experience, and self criticisa--including suggestions for improvement i r. how all the staff, menagers and workers alike, can improve the professionalism of the cen'.or.
9
66
- 3. Outside Evaluation of GTRR Dr. Bill Kerr has visited the NNRC and reported his findings.
Dr. Kerr's report is included here, f
67 e .
FEPORT OF VISIT TO GEORGIA TECH RESEARCH REACTOR FACILITY TO INSPECT FACILITIES AND TO INTERVCIEW OPERATIONAL STAFF by s
William Kerr Ann Arbor, Michigan 29 March, 19AR FE*.5VED '
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REPORT OF VISIT TO GEORGIA TECH RESEARCH REACTOR FACILITY TO INSPECT FACILITIES AND TO INTERVIEW OPER;TIONAL STAFP by William Kerr Ann Arbor, Michigan Introduction At the request of Dr. Ratib Karam, Director of the Georgia Tech ,
Research Reactor (GTRR), a review was conducted on March 24 and 25, 1980 of the staff and the organization of the GTRR.
, Laboratory facilities were also inspected. The following nenbors of the staff were interviewed:
Dr. Ratib Karam - Director Dr. Robert Mcdonald - Associate Director Mr. Dean McDowell - Reactor Supervisor Mr. William Downs - Reactor Operator Mr. David Cox - Manager of the Hot Cell Facility Mr. Mitch Mercer - Electronics Technician .
Mr. Jerry Taylor - Health Physics Technician Ms. Daphne Aycock - Office Manager ,
' ' Enphasis was given to the recent changes in organization and
-- staffing, and the influence these may have on safe operation of the facility.
Conferences were also held with Dr. Thomas Stelson, Vice President for Research, and with Professor Bernd Kahn, Chairman of !
the Nuclear Safeguards
- Committee.
Conneats and conmelusions It appea-s that, as a result of the revisions in administrative structure, and the changes in staffing that have been accomplished over the past several months, a significant improvenent has occurred in the ability of the staff of the GTRR to operate the facility in a safe and efficient manner.
The addition of an associate director with a strong educational background, and with significant manaaerini experience, will t permit more detailed attention to personnel and operational ,
problems. This should make it less likely that problems that night develop in those areas will be left unattended.
The existing cadre of licensed operators is the minimun reauired for operation. Unavailability of either operator would make it virtually inpor ible to operate the reactor on an A hour shift (indeed the ptcat:. Tech Specs require thnt two licensed operators be c ; te during reactor op:: c. tion) . However the !
connitment of .; GTRR management to the cddition of three nere 7 1
09 licensed operators over the next 5 to 12 months will strengthen the onerating staf f, and will nake it less likely that an or,erator who is ill, or otherwise temporarily impaired, might feci pressure to go on duty in a situation in which he co':10 not function at full capability.
The newly appointed replacement health physics staff, and the conritnent to an additional staff nember in the health ohysics area has added needed strength in this part of the staffing. It epnears that this move will.also resolve some of the antagonisns that had led to a needlessly adversarial relationship (one that could have compromised safety) between the operating and the health physics staff. With the additional staffing, and the reorganization, norale in the staf f seems to have improved narkedly.
These existing units, plus an electronic technician, probably represent a ninimun, but adequate, operating staff. However with the sna11 operating staff that now exists, care nust be exercised to insure that the resulting multiplicity of responsibilities is not confusing This confusion may not be obvious to the distracted individual careful observation to avoid this possibility should be maintained.
The nanagement of the GTRR has also commited to a number of other initiatives yet to be fully developed. These include:
- 1) Upgrading the existing procedures, and, where appropriate, adding new procedures for operational and health physics activities.
- 2) The inauguration of a training procram for all staff members. The program is intended to insure awareness of and understanding (appropriate to the individual's responsibilities) of all relevant NRC rules and regulations These initiatives, if designed and implemented appropriately, should further enhance the capability of the staff in areas of safety and reliability.
Although clearly the time available linited those areas that could be investigated in depth, nothing was observed that would lead to a conclusion that the reactor can not now, with the existing staff, be operated safely.
Additional Comments The GTRR is one of the best research reactor facilities in the United States. It will be unfortunate if its potential contribution to research and graduate training at Georgia Tech, and in the recion, is not developed further.
Aosurance N39 qiven at the vice presidential level that the CTPn and i ts dir ector have the enthusias tic support of this office.
Powever th: financial assistance to the Research Reacter, with
70 the exception of income earned from outside activities, is almost negligibly small, even though the facilities of the laboratory are used in several regularly scheduled classes. It also appears that not nuch attention has been given to the center by the vice president's office except in times of crisis. An increase of both overr.ight and financial support would add to the effectiveness of the Research Reactor operation.
It appears that an unfortunate and sometimes bitter relationship between the health physics and the operational staff at the GTRR was permitted to. grow and to fester for many months. Although it is easier to identify this problem in retrospect than while it was developing, it is to be hoped that such a long standing, potentially harnful, situation can be av'oided in the future by rore careful oversight.
It is clear that detailed consideration was given to the local situation and to available resources before implementing the recent reorganization which nakes the director of the GTRR responsible for both radiation safety and for laboratory operation. The current situation is almost certainly an inprovement over what existed previously. However a situation in which the same individual has responsibility for both operation and safety can be perceived as a conflict of interest. Although it might be concluded, logically, that unless the same person is responsible for both, one or the other may be neglected, there is sono danger that a manager who does not have an appropriate perspective, or one who is under pressure to produce, may neglect safety. For this reason, it is recommended that continuing oversight of the current arrangement be maintnined.
The hiatus in operation which has occurred will produce a severe perturbation in facility income, and thereby result in additional restriction in what is already a severely strained budget.
- Additional internal resources may be required to insure that needed equipment repair and replacement continues, and that the commitnents for new staff are not.
I express my appreciation to Dr. Karan, and to the other staff members of the GTRR for their candid and thoughtful comments during our conversations.
wk 29-III-88 l
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i 71 H. Other Management Actions Participation in Professional _ Organizations ,
With the expansion of management personnel,_ Georgia Tech can now participate in such organizations.as TRTR. Previously when the Director of_the NNRC was absent, personnel problems were more.
noticeable. Since the personnel problems are now solved and with sufficient management coverage active participation is possible.
Internal Audits -
The NMRC has instituted a system of interbal audits for all documentation. Every document will be audited for accuracy and completeness by management before it.is filed. We expect this added level of review to sharply reduce the number of errors and omissions in our records.
Conclusions Georgia Tech believes that the management structure is now in place to permit much higher level of control than existed in the past. There are now sufficient management personnel available so that the NNRC can participate in appropriate professional organizations-and thereby maintain a program that is consistent with other research reactors.
1
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72
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Georgia institute of Technology 3,?d ,3 NEELY NUCLEAA AESEAACH CENTER
\ L - .* r 900 ATLANTIC OAIVE
\ ATLANTA GCCAGIA 30332-040S g (acalcoa M a March 23, 1988 MEMORANDUM ' '
T0 : All Personnel FROM: R. A. Karam
[t? (
SUBJECT:
Internal Audits In order to have assurance that our records are complete and appropriately filed it is necessary that we devise a system that is simple with built-in auditing features. This system works as follows:
- 1. All forms to be filed should be given to Mrs. Daphne !
Aycock. No one should attempt to file center records on ,
their own anywhere.
- 2. Daphne will collect on a weekly basis all records to be filed ~in a folder and give this' folder to Dr. Macdonald for final review for completeness and accuracy. Complete records will be initialed by Dr. Macdonald and channeled for filing. Incomplete records will be rejected and returned to the originator. On a weekly basis, incomplete records will be discussed at a staff meeting and each person who originated the incomplete record will be counseled and trained in how to complete forms.
- 3. This system of auditing records applies to health physics, hot cell operations, and to reactor operations. One goal here is to have complete compliance with rules, procedures, and regulations.
- 4. Daphne Aycock will be the coordinator of all records. She is responsiblo for this activity. She will not file any piece of paper which does not 'i> ear the initials of Dr.
Macdonald or his alternate (Mike Puckett).
- 5. Judy Rodgers will be Daphne's alternate. The record to be filed should bear the initials of the auditor (Macdonald or Puckett) and the initials of the filer (Aycock or Rodgers).
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73 IV. ROOT CAUSE AND ACTION
SUMMARY
The following list [ummari:es problems at the NNRC which were identified either in NRC Inspection Report No. 50-160/87-08 dated February 10, 1988 or by NNRC management review. The root cause of each problem and NNRC, actions. to resolve the problem are listed.
- 1. PROBLEM Failure to properly evaluate expected activity of irradiated material. Example, an estimate of "nil" activity was given for a run of 30 MWh.
ROOT CAUSE Conf usion over multiple forms (experiment approval vs.
experiment schedule) for minor experiments led to inconsistent data being entered.
CONTRIBUTING CAUSE Bad practice of not critically evaluating experiment forms and rejecting those which were obviously incorrect ACTION Experiment approval forms have been consolidated into one form 3
for each run. Procedure 3100, Minor Experiment Approval was adopted on February 4, 1988. Staff members have been counseled to carefully evaluate all forms and not to accept anything that is incomplete or incorrect.
- 2. PROBLEM Failure to obtain proper approval on the experiment schedule form before scheduling an irradiation experiment.
ROOT CAUSE Operations error and misjudgment that since the experiment had been approved, another signature to schedule the run was not required.
i ACTION Counsel the operations staff that all steps of each procedure must be completed without exception. Also eliminate multiple forms for minor experiments by combining the run schedule sheet and approval forms. This is the new Procedure 3100.
NNRC management has also implemented internal controls in which all documents are audited before being filed. The audit is intended to identify and correct errors and omissions.
- 3. PROBLEM Failure to follow procedural time limitation for irradiating samples leading to excess i r r ad ia tion .
74 ROOT CAUSE Procedure 2012, Operating Log and Experiment Status form did not contain a place to record to tal MWh received by an experiment and hence was inadequate. For long irradiations operators were trying to keep track of to tal MWh on separate pieces of paper which were not checked with suf ficient frequency. ,
ACTION Procedure 2012 was revised to include total MWh. In addition Procedure 2004, Shift Supervisor Startup Approval, was modified to require explicit review of both the Experiment Approval form and the Experiment Status Log.
- 4. PROBLEM Failure to have procedures for construction arid fabrication of experiment material.
ROOT CAUSE Experience with cadmium wrapped experiments indicated that no damage would occur at 30 MWh. Experiment planning relied upon experience rather than meticulous planning and hence did not consider the effect of irradiating the sample beyond the intended amount.
ACTION Additional materials safety considerations have been added to the experiment approval forms. Fur ther changes to prevent reoccurrence of this problem will be done in conjunction with the review of all operating procedures.
- 5. PROBLEM -
The practice of "self monitoring" when handling radioactive materials war,not sufficient to provide measurements of extremity dose when transferring material from one container to another.
ROOT CAUSE Self monitoring was an instrument created for the convenience of personnel.
ACTION NNRC management has cancelled all "self monitoring approvals" previously granted. Health physics monitoring is required while handling all irradiated samples until they have been demonstrated to pose no unanticipated hazards.
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75
- 6. PROBLEM i
Irradiated samples were opened on the reactor top rather than in a hood or other structure to contain the spread of contamination. !
ROOT CAUSE The operator f ailed to use due caution in assuming that the material was solid and thus could not cause contamination.
There was no procedure in place that forbade opening the sample.
ACTION A new Procedure 3107, Sample Handling, was approved in final f orra on April 6,1988. This procedure requires all samples from the reactor as well as packages from outside to be opened in a hood. NRC personnel have been cautioned not to assume that solid material contains no loose contamination.
- 7. PROBLEM
, Misleading and false statements were made to NRC inspectors by health physics personnel regarding spread of contamination in the containment building. These statements, which are documented in the NRC inspection report, are at variance with surveys made at the time of the incident and with data
- ' collected during the subsequent investigation.
ROOT CAUSE Health physics personnel opposed the reorganization plan ordered by acting president Bourne in July 1987. NNRC management has concluded that misleading statements were an 4
effort to embarrass management and to create a nonexistent safety question that would result in undoing the reorganization.
ACTION No direct action was taken since management does not know the identity of the individuals making the statements. Furthermore
- the statements were apparently verbal and management cannot prove malice.
- 8. PROBLEM Documented surveys showing there had been no spread of contamination in the containment building or in the laboratory building were withheld from the NRC ins pec t o r . This document 4 was in possession of the health physics staf f.
ROOT CAUSE This document would refute the verbal assertions of health physics that contamination was widespread. Withholding the doeurent aave /slidity to their assertions.
76 ACTION No direct action was taken since management c anno t prove malice.
- 9. PROBLEM Failure to conduct adequate surveys of the reactor building following discovery of the contamination.
ROOT CAUSE Health physics failed to perform their as '-
d duties in an adequate manner. -
ACTION Health physics staf.f has been replaced with more competent individuals.
- 10. PROBLEM Failure to maintain records of the limited surveys that were conducted.
ROOT CAUSE Health physics f ailed to perform their assigned duties in an adequate manner.
, ACTION Health physics staff han been replaced with more competent individuals,
- 11. PROBLEM Failure of health physics to conduct a survey to verify the absence of contamination at the operator's residence.
ROOT CAUSE Health physics failed to perform their assigned duties in an adequate manner.
ACTION Health physics sta ,1 has been replaced with more competent individuals.
- 12. PROBLEM Failure to use suitable measurements of concentrations of radioactive materials in the air and for detecting airborne radioactivity during decontamination.
ROOT CAUSE Health physics failed to perform their assigned duties in an adequate manner.
ACTION H e ,1 *. ' rhysics staif has been replaced with more competent in3i .2u3.91
77
- 13. PROBLEM Failure to have adequate procedures for air sanpiing analyses.
ROOT CAUSE The Manager of the Of fice of Radiation Saf ety ignored requests to improve health physics procedures, preferring instead to rely upon "training and experience".
ACTION The MORS has been replaced and new procedure development is in process.
- 14. PROBLEM Failure to maintain. records of the in-vivo chest surveys.
ROOT CAUSE Health physics failed to perform their assigned duties in an adequate manner.
ACTION Health physics staff has been replaced with more competent individuals.
- 15. PROBLEM '
Failure to have adequate procedures for the in-vivo chest surveys.
ROOT CAUSE The Manager of the Of fice of Radiation Saf ety ignored requests to improve health physics procedures, preferring instead to rely upon "training and experience."
ACTION The MORS has been replaced and new procedure development is in process.
- 16. PROBLEM Failure to properly analyze the urine sample for expected contaminants.
ROOT CAUSE i
Health physics failed to perform their assigned duties in an
- adequate manner.
1 ACTION Health physics staff has been replaced with more competent individuals.
- 17. PROBLEM Failure to have adequate urine bioassay analyses and internal exposure evaluation procedures.
. -, , -,,v.--- - , , - , , , - - , , , - . --- --
78-ROOT CAUSE The Manager of the Of fice of Radia tion Saf ety ignored requests to improve health physics procedures, preferring instead to -
rely upon "training and experience."
ACTION The MORS has begn replaced and new procedure development is in process.
- 18. PROBLEM
' Pallure to have adequate whole body counting or urine s bioassays conducted.
ROOT CAUSE Health physics failed to perform their assigned dut .es in an adequate manner.
ACTION Health physics staff has been replaced with more competent individuals.
In sunmary NNRC management feels that the new health physics team is committed to adcpt industry standards, perform jobs in ace'ordance with approved procedures, communicate with others in a
, professional manner, and insist on compliance with all roles and regulations. Exchange of procedures with other similar research facilities shall be encouraged.
Training for 5 additional operators began on April 11, 1988.
A schedule of daily training sessions of two hours for more than 13 weeks is in progress. ,
.A procedure for two operators in the control room has been written and approved by the Nuclear Saf eguards Committee.
Procedure revision is occurring at two levels:
- 1. Immediate correction of cause of cadmium spill and mistakes which were made during cleanup. Needed procedures in this area have been written and approved by the Nuclear Saf eguards Committee.
- 2. Long term solution requir ing entire GTRR procedures to be reviewed, revised, and supplemented where necessary, in a manner similar to industry standards. Ta rg e t date for completion is March 1989.
Regulatory training , already implemented, has three elementst
,(1) sensitivity to regula tions, (2) time set aside of each weekly staff meeting for discussione w presentations of issues related to regulatory sensitivity, ano (L one staff member has acen assigned
F~
79 to review MRC notices, bulletins, and circulars. Additionally, other industry experiences, both good and bad , will be presented.
Outside evaluation of NNRC shows that changes in staffing that have been accomplished over the past seve ral r..onths produced a s ig ni f icant improvement in the ability to operate the facility in a safe and efficient manner.
The NNRC has instituted'a system of internal audits for all doc umen ta tion . Every document will be audited for accuracy and completeness by management'before it is filed. This added level of review will sharply reduce the number of errors and omissions in records.
Georgia Tech believes that the actions taken at several fronts created a management structure which will permit a much higher level of control than existed in the past. It is believed that commitment to safe operation has been strengthened significantly.
NRC concerns taught the NNRC staff a valuable lesson. NNRC management believes it is safe to return the GTRR to full operation.
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