ML20236N567

Responds to NRC 871009 Ltr Re Violation Noted in Insp Rept 50-297/87-03.Corrective Actions:Procedure HP-40-1 Reviewed & Modified to Include Case of Unloading Samples When Reactor Shutdown

ML20236N567
Person / Time
Site:	North Carolina State University
Issue date:	11/06/1987
From:	Turinsky P North Carolina State University, RALEIGH, NC
To:	Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8711160231
Download: ML20236N567 (4)

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q 1 P; NorthCarolina StateUniversity n 2 School of Engineering 01!!CV Io ' v 3 : o q

' Department of Nuclear Engineering

-Box 7909, Raleigh NC 27695-7909'-

November 6, 1987 Dr. Douglas M. Collins, Chief

-Emergency Preparedness and Radiological Protection Branch  ;

Division of Radiation Safety & Saieguards US Nuclear' Regulatory Commission 101 Marietta Street N. W.

Atlanta,.GA 30323

SUBJECT:

Notice of Violation  !

NRC Inspection Report No. 50-297/87-03 LNorth Carolina State University PULSTAR Reactor - License No. R-120

Dear Dr. Collins:

This response is regarding your letter dated October 9, 1987 describing one class-IV violation against our PULSTAR Facility. This violation was identified by the recent NRC inspection conducted by Dr. B. K. Revsin on September 28-30, 1987. Please find the attached document explaining in detail the reason for the violation and the corrective actions implemented at our facility. For ease in presentation, I have repeated the violation.

Sincerely, 8

Paul J. Turinsky, Head i Nuclear Engineering PJT- e Attas; . ant

-cc: NRP RPO ,

RHP l Dean.Monteith 8711160231 DR 871106 ADOCK 05000297 PDR North Carolina State University is a Land-Grant University and a constituent institution of The University of North Carolina.

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Enclosure 1 Response to violation and' corrective actions-taken Violation Technical Specification 6.3.a.8 states that operating procedures shall be written, updated periodically and followed for radiation control and shall be maintained and available to all operating personnel.

Procedure HP-40-1, Utilization of Reactor Irradiation Facilities, Revision 1, January 7, 1986, Paragraph 8 states that the stringer is placed on i the bridge for dose rate measurement which shall be provided to the Reactor j Operator for entry on Form NRP-3 (Run Sheet).

Paragraph 6 of the above procedure states that Reactor Operations will be notified before removing anything from the pool, Contrary to.the above, operating procedures for radiation control were not written and/or followed in that:

1. Between June'22 and September 29, 1987, dose rate measurements were not entered on the Run Sheets for approximately 90 percent of the stringers removed from the reactor pool.

2. Between June 22 and September 29, 1987, Reactor Operations was not notified prior to removing stringers from~the reactor pool.

3. The methodology used for calibration of personnel contamination monitor

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(RM-14s with HP-210 pancake probet: was not maintained in a written procedure.

This is a Severity Level IV violation (Supplement IV).

Response to viclation items 1 and 2

1. Violation is acknowledged.

2. Reasons for the violation:

The procedure HP-40 1 describes the course of action required when the reactor was operating. When samples were unloaded during the time the reactor was operating, the dose rates were entered on the Form NRP-3 (Run Sheet). The HP-40-1 procedure did not address those cases where samples were unloaded when the reactor was not operating.

Over the years increased volume of neutron activation analysis (NAA) samples created the necessity to address sample unloading at all times. The j fact that NAA samples require a typical 7 day decay period also necessitated l unloading of samples during times when the reactor was not operating, j l

[. _ .The dose rate readinga were being taken by the NAA personnel but were not {

being recorded unless the measured dose rate exceeded the estimated dose rate. '

It was assumed by the Reactor Health Physicist (RHP) that the personnel unloading samples were entering the dose rates on the run sheets. The run

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• I sheet is initially reviewed by the RHP for radiation safety _ aspects and forwarded'to the operations group. : Traditionally, the run sheet has been totally maintained by the operatio.ie group. Hence, there was no provision for.

final-review by the RHP before filiag.

3. Corrective' actions taken:

The procedure HP-40-1 was reviewed and modified to include the case of unloading the samples when the reactor is shut down. The specially trained and certified NAA personnel will-unload the samples and enter the dose rates on the run sheet. The operations group will continue to maintain the run sheets and insure that all-required information is documented before final l filing. In addition, the RHP or his designated alternate will verify on a I weekly basis that dose rate entries are being recorded on the run sheet.

Response to violation item 3

1. This violation is acknowledged.

2. Reason for the violation:

The portable monitoring instruments used in the reactor facility and the various laboratories are calibrated on a quarterly basis by the Campus Radiation Protection Office (RPO). The calibration procedure and the records are kept'in the RPO for calibration of all portable survey instruments according to Section' 2.3.1.1.2 of North Carolina State University Handbook for Protection Against Ionizing Radiation (V Edition 1978). In the past, RPO calibrated RM-14 hand and foot monitor along with the other portable instruments as indicated by our earlier records. However, for the past 5 i years calibration and response checks have been accomplished by the Reactor Health Physics (HP) personnel. Since the RM 14 only provides an indication of the presence of radioactive materials, a specific electronic calibration was not being documented, even though it was being performed. Recponse checks were being accomplished and recorded on a monthly basis.

3. Corrective actions taken:

A procedure has been written (HP-20-16) to document the step by step calibration and efficiency determination. This procedure specifies that the calibration shall be performed at intervals not to exceed 13 months, Efficiency versus energy determination is accomplished annually not to exceed 13 months. Single source response checks will continue to be performed monthly. Records will be maintained for compliance.

Additional information

a. An unresolved item concerning response records for Eberline RM 14 personnel friskers: paragraph 4.f (report details)

At the time of the exit interview, the records had not been located.

These records have since been located and filed in the log book.

b. Records on earlier extremity dose monitoring study have been located in the Health Physice History book for 1978-79. In addition, extremity badges i

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.. i have been issued to personnel involved in loading and unloading samples.

Extremity dosimeters will be initially used for a period of six months'to, i determine.if dosimeters are needed on a more permanent basis.

-c. Regarding extremity. dose rates on paragraph 4.b, the. reports says

> "....that-it was not uncommon for dose rates from baskets to reach 5-10 R/hr".

This statement is true for most sample baskets at the time irradiation is complete. However, following the typical 7 day decay, dose rates are in the range of 5-10 mrem /hr when the samples are actually unloaded.

d. Parrgraph 4.e, middle of page 4, regarding the removal of stringers from the pool, when.the reactor is shut down, the report says that ".... irradiated material was often removed early in the morning before operations personnel vere available and that the success of the program required flexibility in this. regard".

The reactor control room and the bay is opened only by the senior reactor operator or his designee. -Therefore, it is impossible for anyone else to enter the reactor bay before the arrival of operations personnel. Safety has never been or never will be sacrificed for convenience. .

e. Regarding instrument calibration on paragraph 4.f, Pu-239 was mentioned i only as one of several sources available for use. In ' fact, a source of lower activity is being used for response checks.

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