IR 05000326/1985001

Insp Rept 50-326/85-01 on 850903-06.Violations Noted:Failure of Reactor Operation Committee to Conduct Quarterly Meetings & Implement Licensed Operators Requalification Program

ML20205E429
Person / Time
Site:	University of California - Irvine
Issue date:	09/27/1985
From:	Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20205E421	List: IR 05000326/1985001 ML20205E416 ML20205E422
References
50-326-85-01, 50-326-85-1, NUDOCS 8510170304
Download: ML20205E429 (12)

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U.S.NUCLEARREGULATORYCONMISSION'

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Report N /85-01

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j Docket N . License N R-116 University of Calif'ornia at Irvine

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Licensee:

Irvine, California 92717 -

Facility Name: ,

Research Reactor - Triga Mark I Inspection at: Irvine California Inrpection conducted: September 3-6, 1985

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Inspector: d h d ub___ kr /A'7/8[

Da'te Signed M.Cill{s Radiation Spec 4g}&st Approved By: b Mob s j/27 /T G.P.YQa(, Chief .

Date $igned Facilitie M adiological Protection Section Summary:

Inspection on September 3-6, 1985 (Report No. 50-326/85-01)

Areas Inspected: Routine unannounced inspection by a regionally based inspector of facility operations and organization, radiation protection program, environmental . monitoring program, emergency preparedness program, review and audits, standard operating procedures, training, surveys, operating logs and records, transportation _ activities, reactor operator and senior reactor operator requalification program, surveillances,-experiments, org'anization,-Information Notices (ins), enforcement followup items, a tour of the facility, and a review of licensee June 19, 1985 letter. During this inspection, Inspection Procedures 40750, 42745, 41745, 61745, 69745, 82745, 83743, 86740, 92702 and 92717 were performed. .The inspection involved 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> of onsite time by one inspecto Resultst ,0f the seventeen areas inspected, two apparent violations were identilled.' ' Failure;of the Reactor Operation Committee to_ conduct quarterly meetings'(See paragraph 2(e)) and failure to implement the licensed operators requalification' program (See paragraph 2(d)).

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8510170304 850930 PDR ADOCK 05000326 O PM e-u .

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DETAILS .

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- Persons Contacted Professor G. Miller, Reactor Supervisor

• Professor V.'P. Guinn, Chairman,. Reactor Operations Committee (ROC)

• Mr. W. Smirl, Environmental Health and Safety .(EH&S) Of ficer,

• Ms. P. Rogers, Senior Reactor Opera' tor Traine *Mr. J. Tripodes, Radiation Safety Officer - -

• Mr. W. Nabar, Health Physicist ' . . ,

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• Ms. K. Swift, Radiation Safety?Te'chnician '

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'*Mr. H. Bair, Radiation Safety. Technician; .

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Lt.- W. Miller,- UC Irvine Policef Depaktme'nt

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• Denotes those individuals -~attending' the' exit interview on' September 9,

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3 4 1+ Reactor Operations

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u t ;, , Organization, Logs'and'Recoids ,.. [ ~ [y ,

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The organizational structure for, operation, radiation protection, and administ, ration of the'UC Irvine Triga Reactor was' examined.-

Sel'ected portions of the following facility operations and radiation protection surveillance logs and records for the period of June 1983 through September 1985-were reviewe *

. Standard Operating Procedures.(SOPS).

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Visitors Log Book

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Radiation Protection Log Book-

ROC Meeting Minutes and. Audit Reports -

Personnel Exposure Records

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. Technical Specificationsf(TS)

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General Employee Training (GET)

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• - Scram Logs

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1983-and 1984' Annual Reports

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Surveillance Checklist *

= Reactor Operator Requalification Program ' '

Daily. Reactor Checklists

Startup/ Shutdown Checklists

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Emergency Plan

Environmental Monitoring Records

Fixed and Po~rtable Instrument-Calibration Records p,

The results.of the-above record / document reviews are discussed in

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the ~ subsequent paragraphs of this inspection repor .The' licensee'sfcurrent staff consists of.one licensed' senior reactor

. ' operator (SRO),~and one.SRO trainee.< The licensed SRO is-the.

l reactor supervisor.' ' Health physics support is'provided by the' EH&S foffice staff. A five member-reactor operations committee..(ROC).

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~provides an ' overview service of the TRIGA reactor activities'.

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Administration of- the reactor operations'were ' essentially under the direction of the reactor supervisor. He is the only qualified reactor operator at the facility. He is responsible for maintaining the facility in accordance with the conditions prescribed in the T He is responsible for training the operating staff, development of operating procedures, implementation of the emergency plan, implementation of the security plan, and many other activities related to operation of the research reactor. Additionally, the reactor supervisor has an extrem'ely busy teach'ing schedule 'and is also engaged in other activities. The .above observations were discussed with the Chairman of the ROC' and were ' brought to the

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licensee's attention att the exit intervie ,

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b. Procedures . -

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Technical Specifications, Section 6;3, " Operating Procedures"

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requires that written procedures shall be in effect'and followed for certain items identified in.Section The inspector reviewed sel'ected procedures associated with reactor operations, conduct of experiments, facility and site' emergency procedures, and those procedures related to radiation protectio It was noted that the licensee has incorporated all of the procedures into an operations manual which is maintained at the reactors control consol The examination disclosed the following:

The operations manual did not contain a copy of the recent NRC approved emergency pla *

The operations manual contained two outdated emergency call out lists. A third call out list, which was in effect at the time of this inspection, was mounted on the control room wai *

Theoperationsmanualdidnotconthinarecentcopyofthe campus site wide emergency plan, dated 1984. The copy included in the manual is dated June 197 l The review and examination of records, and discussions held with the licensee's staff disclosed that the instructions provided in the manual are not always followed. Examples of this, discussed here and other portions of this reports, are as follows:

Failure co obtain liquid samples from the facility's sink trap /

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Failure to perform' annual calibrations of area radiation monitor *

Failure to perform rod drop time checks, and determine control rod worths following maintenance activities.

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Failure to perform semiannual gamma and neutron surveys while the reactor is at full powe Discussions with the reactor supervisor revealed that the instructions related to control rod calibrations and rod drop time checks needed to be clarified. The reactor supervisor stated that this would be accomplished by September 30, 1985. The licensee's staff informed the inspector that these concerns would be evaluate The radiation safety officer stated that the required surveys were performed, however, the survey record was either lost or misplace The inspector noted that the use of startup, shutdown, and monthly checklists are identified in the standard operation manual. The manual requires these checklists be utilized as a means of documenting reactor operations. However, a combination maintenance semiannual and annual checklist used for documenting reactor operations surveillances identified in Section 4.0, " Surveillance Requirements" is not identified in the manual. The inspector noted that the latter checklist is not consistently or effectively utilized as means for assuring that the surveillance requirements prescribed in the TS are accomplishe The inspector brought the above observations to the licensee's attention during the exit interview. The licensee stated that the inspectors observations would be evaluated. This item will be examined during a subsequent inspection (85-01-03).

c. Surveillances The inspector examined selected surveillance activities and records to verify completion as required by TS, Section 4.0 and to determine if facility operations were consistent with the limiting conditions prescribed in the TS and the licensee's standard operating procedure The inspector noted that a maintenance semiannual and annual checklist (see paragraph 2b) developed for documenting the surveillance performed was not always used. The inspector also noted that this checklist did not clearly-distinguish between TS surveillance and licensee imposed requirements. ~ It appeared the checklist was not an effective tool for assuring compliance with the TS or licensee imposed surveillance requirements. ~ None of these checklists could be located for 1982 through 1984. Assuring compliance-with the license conditions could only-be accomplished by reviewing the reactor operations log book. This was a slow and very tedious method and is subject to error. The combined review of the

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checklist and log book revealed th'at the reactiv'ity worth and rod drop times were not performed between the' peri'd o of January 13, 1984 and October 6, 1984. This' represents a. period'of nine months. TS,

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Section 4.2(a) and (b) requires these checks ibe ; determined .

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semiannual, but at intervals not to' exceed eight months. Further discussions with the licensee's' staff'and~a review of 'the reactor log book disclosed that the above'surveillances,could not be performed because of problems with the shim, control rod. The (

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'reactorwasshutdown_on~Sehtbebet4,s1985tooverhau1;the"[himrod .

drive mechanism. The required surveillances were accomplished:

immediately af ter the shim > rod * drive mechanisTn"was' overhauled'.

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The above observations were discussed with the-licensee'sl staff and at the exit interview. The licensee's. staff informed the-inspector that methods for improving the4 effective use of the checklist would be evaluated. This item will be' examined,during :a' subsequent inspection (85-01-05). . .

- Reactor Operators Requalification' Program Discussions were held with the licensee's staff and records related to the reactor operators'requalification program were examined for the purpose of' determining compliance with the licensee's NRCJ approved program of. February-20, 1974. The approved program i , designed to. meet the' requirements set forth in 10 CFR Part 50.54-(1-1), " Conditions of' License" and 10 CFR Part 55, Appendix A,

"Requalification Programs for Licensed Operators of Production. and-Utilization Facilities".

The~ licensee's program requires that annual written examinations

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.will be set for all reactor operator (R0s) and senior reactor operators (SR0s). The program also requires that records be maintained to document each RO and SRO participation in the progra The program requires that copies of written examinations, answer

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sheets, and the results;of' evaluations be maintained. Each R0 and SRO's performance are required to'be evaluated by the reactor supervisor. Knowledge of normal and emergency procedures, design

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changes and job performance are required to be evaluated. The SRO who. prepares the exam, grades;the exam, and performs the evaluations is exempt from taking the: examination It was noted that' a. licensee's letter dated June 19, 19_85, identified that a SRO continued to operate the 'UC Irvine Triga reactor for a period of two months after the individuals' SRO -

license had expired. The information reported in the' June 19, 1985-letter was also reviewed as 'part of this examinatio The examination revealed that the information provided in the June 19, 1985 letter indicated that the involved SRO has not performed:SR0s duties except a's' allowed by 10.CFR Part 55.9,

" Exemptions from License." The reactor supervisor ~ responsible for implementing the requalification program stated.that a request'for renewing the individuals license lwould be made' pursuant to_10 CFR,

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, Part 55. The reactor supervisor informed the inspector that.in the future R0s/SR0s license's would be displayed in the. facility and '

that a provisionLwill be: included on the facilities combined-semiannual and annual maintenance checklist as an additional t reminder. ;It is expected that.;these corrections'will act as a reminder of R0s/SR0s111 cense expirations and thereby prevent a recurrence of a'similar even >-

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The inspector's review of the R0s/SR0s requalification program disclosed that SR0s written examinations were not administered in 1982 and 1984. The 1983 SRO written examination had been administered by the NRC staff. The reactor supervisor performed the SRO/R0 evaluations as required, but had not developed a formal method for tracking and documenting this action. Discussions with the licensee's staff disclosed that written examinations were not administered to licensed operators because both the reactor supervisor, who holds an SRO license, and the individual's SRO license that expired, teach a Chemistry No. 253 class on reactor operations. The reactor supervisor and SRO both assumed that they were excluded from administrating and taking an annual examinatio The inspector informed the licensee that the approved requalification program is intended for licensed operators and not for individuals who may or may not eventually request a license pursuant to 10 CFR Part 5 The licensee's staff indicated that they just recently felt that this was the case and thought they should be administering the annual exam The above observations were brought to the licensee's attention at the exit interview. The licensee stated that existing R0s/SR0s licenses and the checklists would be modified by September 30, 198 This will be examined during a subsequent inspection (85-01-04).

The inspector informed the licensee that failure to administer the SRO annual written examinations was an apparent violation (85-01-01).

e. Review and Audit The licensee informed Region V by letter, dated June 19, 1985, that the Reactor Operations Committee (ROC) failed to conduct a quarterly meeting between the period of November 8,=1984 and June 20, 1985, as required by TS, Section 6.2(f). The report identified that this was a repeated item, with the most recent being in 1983. The report failed to provide a resolution for preventing recurrence of similar event An examination of the licensee's review and audit functions prescribed in Section 6.2 of the TS was conducted. ROC meeting minutes for the period 1983 through 1985 were reviewed and were found to be satisfactor Discussions were held with the ROC Chairman and other ROC members for the purpose of determining possible resolutions for assuring compliance with Section 6.2(f) of the T The staff offered suggestions'that would be more effective in preventing _a recurrence of a similar event; however, the suggestions must first be discussed with and approved by the RO The inspector informed the licensee that failure to conduct the ROC meeting during the first quarter of 1985 was an apparent violatio The inspector emphasized the importance for. adopting measures that will prevent a similar violations in the future. (50-326/85-01-02)

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The inspector examined irradiatiori requests and experiments completed since the last inspection. The examination disclosed that no new experiments have been approved since the last inspectio ,

' No ' violations or deviations 'were iderItified.~

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' [ Emergency Preparedness .:

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b rz Thelicensee'scapabilitiesforresponding[toemergencies-as-describedin

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their emergency plan that was developed pusshant to'10 CFR Part 50.54(r)-

were examined. The licensee's eme'rgency plan /was~ approved by NRC in

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Discussions related to this topic were held >with'the Campus Police

! Department,-reactor operating staff; Land'EH&S staff. Emergericy .

. procedures identified in the reactor" facilities operations manual, emergency call out lists (see paragraph 2(b)) arid other documents related

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The inspection disclosed th'e following:

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The discrepancies noted in paragraph 2(b).

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. Drills and exercises prescribed in Section 10.2 of the emergency plan'were conducted on August 28, 29, and 30, 1985. The drill involved all'onsite activities and the local Fire Department (FD).

The results of the drill had not-been. critiqued as required by the-emergency plan. The ' licensee's staff stated that a critique was beingLnegotiated with the FD as soon as involved personnel were availabl *

The emergency equipment described in Section 8.6 was~ inspected and found to consistent with the licensee's commitment *

The campus police department did not have copies of the latest emergency call out list or implementing emergency procedure *

Records of the training conducted were not being' documented or maintaine *

A memorandum of understanding with yestern Medical Center has not

, -been established even.though the medical center is expected to become involved ~in emergencies involving. injurie *

Procedures identified in'Section 11.0 of the Emergency-Plan are not

, consolidated'into an effective manual and'some appear, to be

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obsolete. The= inspector'noted that some. procedures'are dated 197 <

Discussions with the licensee's st'aff: indicated:their knowledge of these procedures was margina '

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The above observations were discussed with.the licensee's staff and at

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the exit interview. The licensee informed the inspector that the drills,

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y conducted during August 1985 identified many of the observations reported by the inspector. The licensee added that the inspectors observations would be evaluated. The inspector emphasized the importance for improving the weaknesses that were identified. This item will be examined during a subsequent inspection.(85-01-06).

4. Licensee Action On Previous Inspection Findings (Closed) Enforcement Items (50-326/82-01-01, 50-326/82-01-02, and 50-326/82-01-03). The licensee's corrective actions related to these items were examined and were found to be satisfactory. All of the items were related to limiting conditions on reactivity worth during normal reactor operations. This matter is closed (82-01-01, 82-01-02, and 82-01-03).

5. Annual Reports The inspector verified the data provided in the licensee's annual reports submitted to the NRC Region V office pursuant,t,o Section 6.7(f);of the T . .

No violations or deviations were identifie *

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6. Environmental Monitoring j , ,

' Gaseous Releases ,

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AnnualArgon-41releasesareideterminedbycalculationsb'asedonthe production of Argon-41 during " reactor; operations. ,The basis and

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calculated Argon-41 releases:are discussed.in Section 8.4 of the Safety Evaluation Report of,1968..The calculations are considered to provide conservative valu*e The 1983 and 1984 annual reports disclosed that the amount of Argon-41 released was approximately 2.4E4.microcuries. This represents a concentration of less than 4.0E-10 microcuries per milliliter (uCi/ml) when averaged over a 12 month period. This value is considerably lower than the MPC of 4.0E-8 uCi/ml allowed by 10 CFR Part 20, Appendix No violations or deviations were identifie Particulates A continuous air monitor (CAM) is located along side of the reactor pool. The CAM is operated continuously during reactor operations pursuant to TS, Section 3.3. The CAM draws a continuous sample from a location over the reactor pool. An audio-visual alert alarm is provided at the unit and at the reactor's control consol A review of the CAMS operations records for the period 1983 through June 1985 was conducted. The review revealed that particulate airborne concentrations were essentially non-detectable.

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4 4-f The inspector noted that the CAM was normally calibrated atLthe frequency specified in Section 5.0 of the facilities * operating procedures. The inspector also noted that the calibrations program does not include a requirement. for verifying the CAMS flow measurement as is recommended by. Regulatory Guide 8.25, " Calibration and Error. . .for Total Volume of Air: Sampled." The examination revealed that a reverification of the calibration is not always accomplished following maintenance activitie The inspector brought the above observations to the licensee's attention at the exit interview. The licensee informed the inspector that requirements will be established for verifying the CAMS air flow and for performing a recalibration following maintenance activitie No violations or deviations were identifie c. Liquid Waste Releases The licensee does not release any radioactive liquid waste to the sewer syste The licensee has established controls for assuring radioactive liquid effluents are not released to the sewer system. The controls include a requirement for sampling the reactor pool water and sampling the facilities sink drain traps. All liquid wastes-are collected in appropriate receptacles and transferred to the EH&S office for processing and subsequent disposal to a licensed facility. The results of pool water samples obtained in 1984 and 1985 indicated radioactivity levels averaging approximately 1.0E-7 uCi/m The inspector noted that the licensee's staff did not have the capability of obtaining a two milliliter water samples from the traps of facilities sink drains as required by Section 5.6.2(b) of the SOP. The lidensee's. health physics staff. informed the inspector that they were unable to get to the trap so they were only performing a contamination survey of the traps with the use of cotton swab The above observation was brought to the licensee's attention at the exit interview. The licensee stated that they were evaluating the problem and are considering that samples be taken from an alternate locatio ,

No violationc or deviations vere identifie d. Direct Radiation Measurements An array of ten thermoluminescent dosimeters (TLDs) supplied and processed by a certified vendor -are placed at, various locations within and adjacent to the reactor facility. 'TLDs are placed within the normal and emergency ventilation systems, exhaust plenum e

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The results of environmental data obtained from the above program were reviewed. The results gave no indication of changes in,the environs that are related to operation of the-licensee's facilit No violations or deviations were identif'ie . Radiation Protection Surveys

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The inspection disclosed that monthly radiation and contamination surveys were performed as required by Sections.5.1.3.2 and 5.1. of the SOP. As necessary, special surveys of irradiated samples and equipment removed from the facility are also performed. The-

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inspector noted that the special' gamma and neutron survey was not performed at the semiannual frequency prescribed in Section 5.1. of the SOP. Records of this survey performed between 1982 and March 1984 were not available. The licensee's staff stated that the surveys were performed; however, they were unable to determine why a record of the survey was not availabl The inspector noted that 5.1.3.1 requires that the gamma and neutron survey be performed while both the reactor and a neutron generator (located in the high bay room of the reactor facility) are at full power. Such surveys were conducted on March 21, 1984, October 9, 1984, and June 20, 1985. The inspector noted that significant neutron levels (e.g., up to 69 millirem) were found during the October 9,1984 survey that were not identified during previous or the June 20th surveys performed under similar conditions. The licensee's staff had failed to observe this even though the data had gone through an internal review. The licensee was also unable to provide the inspector the reason for . Laking a survey while both units were at full power. The licensee was unable to state with any degree of certainty the neutron contribution provided by the individual components (e.g., reactor, neutron generator). The above observations were discussed at the exit intervie The radiation safety officer stated that the staff has never observed any neatron contribution resulting from reactor operation He added that the data on the October 9,1984 survey was probably erroneously recorded or a defective instrument was used to perform the survay. The RSO stated that the neutron survey instruments would be checked and added that a survey would be taken to distinguish between the contribution provided by the neutron generator and reacto The inspector concluded that the licensee's survey program was consistent with 10 CFR Part 20.201, " Surveys".

No violations or deviations were identifie _ _

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b. Posting and Labeling The inspector verified that the licensee's posting and labeling practices were consistent with'10 CFR Part 19.11 and 10 CFR Part 20.203 requirement No violations or deviations were identifie .

c. Instrument Calibration Records associated with the calibration of portable radiation detection instruments and fixed area radiation monitoring instruments prescribed in TS, Sections 3.3 and 4.5 were examine Except in one instance, the examination disclosed that the functional tests and calibration conducted by the licensee's staf f appeared to be consistent with the recommendations of ANSI N323-1978, " Radiation Protection Instrumentation Test and Ca!ibration" and the facilities standard operating procedures. The inspector noted that calibrations were not always performed at the frequencies prescribed in Section 5.0 of the facilities SOP and as recommended by ANSI N323-197 The above observation aas brought to the licensee's attention during the exit intervie No violations or deviations were identifie d. General Employee's Training The licensee's GET program for assuring compliance with 10 CFR Part 19.12, " Instructions to Workers" was examine Training attendance records, written examinations, and the training outline used in administering the GET were reviewe The inspector concluded that the licensee's GET program was consistent with 10 CFR Part 19.1 No violations or deviations were identifie e. Radioactive Material Transfers / Shipments-An examination of the licensee's program related to the transportation of radioactive materials was conducte Instructions to this topic are provided in Section 5.10 of the facilities operating procedure The examination disclosed that transfers / shipments are made through the University's State of California radioactive material license.

i No violations or deviations were identified.

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11 Personnel Monitoring The inspection disclosed that the licensee's personnel monitoring program was consistent with 10 CFR Part 20.202, " Personnel Monitoring".

The maximum whole body and extremity exposures for 1983 and 1984 were maintained well below.the limits prescribed in 10 CFR Part 20.101, " Radiation Dose Standards for ,. Individuals in Restricted Areas." <

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8. Information Notices (ins) -

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An examination was conducted for the purp[se of ' determining if ins were routinely evaluated by the licensee's staff for applicability of activities conducted at the UC-Irvine reactor. ~) ,

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The examination disclosed that jhe re~ actor supervisor is . confident that ins are being received and evaluated; however, adequ' ate. records-are not

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being maintained of the evaluations. The licensee's staff' appeared to be aware of the purpose 'for the ins and inportance for their evaluation The inspector was informed that a more formal system for tracking and documenting the evaluations of ins would be establishe No violations or deviations were identifie . Exit Interview The inspector met with the licensee's representatives (denoted in paragraph 1) at the conclusion of the inspection on September 6, 198 The inspector summarized the scope and findings of the inspection. The licensee was informed of the violations discussed in paragraphs 2(d) and 2(e). The weaknesses identified in other areas as they relate to procedure compliance, implementation of the emergency plan, conducting meaningful surveys, and implementing measures for assuring TS surveillances were also discussed at the exit intervie The inspector informed that licensee that while none of the findings have an immediate affect on the health and safety of the public, they do indicate a need for management attention and support. The inspector

, stated it appeared that the effectiveness of the ROC reviews and audits should be evaluated. The inspector added that it appeared like the reactor supervisor could use some additional support in the administration of activities at the Triga reactor facilit t i

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