IR 05000252/1986001

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Insp Rept 50-252/86-01 on 860519-22.Violation Noted:Failure to Provide Annual Written Exams & Schedule Requalification Training & to Maintain Individual Records & Failure to Calibr Radiation Monitoring Instruments
ML20207F174
Person / Time
Site: University of New Mexico
Issue date: 06/30/1986
From: Baer R, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207F127 List:
References
50-252-86-01, 50-252-86-1, NUDOCS 8607220487
Download: ML20207F174 (9)


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APPENDIX C U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

F NRC Inspectio,n Report: 50-252/86-01 License: R-102 Docket: 50-252 Licensee: University of New Mexico (UNM) Albuquerque, New Mexico Facility Name: AGN-201/M Reactor (5 Watts) Inspection At: University of New Mexico Inspection Conducted: May 19-22, 1986 I Inspectors: / / /[bA () / [h'/A[/ h [

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R ' E.' Baer,~ Radiation Speciflist, Facilities Date 6/d . Radiological Protection Section lll NlNdWlbl B. Murray, Chief', Facilities' Radiological bh0 Dhte '

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Protection Section / Approved: A/ [[/l,(Y/ / [ 6 B. Murray, Chief, Facilitjts Radiological Ddte ' Protection Section / - 8607220487 860718 2 Inspection Summary PDR ADOCK 0500 G Inspection Conducted May 19-22, 1986 (Report 50-252/86-01) Areas Inspected: Routine, unannounced inspection of the licensee's organization, operations and maintenance logs, licensee's internal review and audit progran, requalification program, operating procedures, surveillance requirements, experiments, radiation protection, environmental protection, emergency planning, and physical security pla Results: Within the areas inspected, four violations were identified (see paragraphs 8, 14, and 18).

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  -2-DETAILS Persons Contacted
*F. L. Williams, Chairman, Chemical and Nuclear Engineering Department
*R. D. Busch, Reactor Supervisor G. W. Cooper, Reactor Supervisor R. Counsellor, Radiation Safety Manager
*B. D. Cox, Chief, UNM Police Department
*R. T. Raymond, Lieutenant, UNM Police Department A. E. Roybal, Captain, UNM Police Department
*W. L. Tabor, Director, Occupational Safety R. H. Williams, Assistant Dean, College of Engineering
* M. Woodall, Chief Reactor Supervisor
* O. Woodstock, Senior Electronics Technician
* Denotes those present during the exit interview on May 22, 198 . Followup on Previously Identified Items (Closed) Open Item (252/79-02): During the inspection conducted in November 1979 and reported in report 50-252/79-02, the NRC inspector, when reviewing the " Manual of Operation," did not find an administrative method for identifying approved procedures and experiments and for controlling temporary and permanent changes to these procedures and experiments. It was also reported that the terms " standard" and " nonstandard" as used to characterize experiment were not clearly defined and there was no guidance provided as to the generic types of experiments that could be run without ,

prior approval of the Reactor Safeguards Advisory Committee (RSAC) and the - Reactor Operations Committe The NRC inspectors reviewed the "AGN-201M Reactor Operation and Operator Training Manual" dated July 1984 and determined that the issues raised in Inspection Report 79-02 and 82-01, for identifying approved procedures and the terms " standard" and " nonstandard" which are presently referred.to as

" routine" and "nonroutine" have been included in Section III. This item is considered close . Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptance item, an open item, a deviation, or a violatio Unresolved Item (252/8601-05): Radiation Protection Training - This item involves the training provided to all personnel to satisfy the requirements of 10 CFR Part 19.12. See paragraph 14 for additional detail REMOVAL OF THE PAGES MARKED " "

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- Organization and Management Control The NRC inspectors reviewed the organization and management controls to determine compliance with Technical Specification (TS) The current organization was verified to be consistent with Section III,
 " Administration," of the AGN-201M Reactor Operations and Operator Training Manual, dated July 1984. The status of licensed operators, membership and meetings of the Reactor Operations Committee (ROC) and RSAC, and other matters concerning supervision of the reactor facility were examined. The NRC inspectors noted that the individual designated " Chief Reactor Supervisor" was terminating his employment with the UNM and a qualified individual had been identified to replace hi No violations or deviations were identifie . Operation and Maintenance Logs The NRC inspectors reviewed the following logs for the period April 1982 through May 1986 to determine compliance with TS 1.0, 2.0, and 5.3:

Reactor Operations Log Reactor Maintenance Log Monthly Reactor Inspection Log All maintenance and operations activities appeared to have been conducted in a manner consistent with the TS requirements and administrative ' procedure No violations or deviations were identifie . Internal Audits and Review j The NRC inspectors reviewed the minutes of meetings conducted by the ROC

and RSAC and verified that both committees had met semiannually since the previous inspection and reviewed matters relating to operating the reacto It was verified that records reflected attendance by designated committee members. The following items were routinely reviewed by the committees

' Technical Specification Requirements Organization, Staffing, and Licensing New Facility Operation Manual New Experiments ' Maintenance, Operations, and Inspection Logs Excess Reactivity and Control Rod Worths Procedure Changes

,  Radiation Surveys

' Equipment Performance Security and Security Response No violations or deviations were identifie REMOVAL OF THE PAGES MARKED " " DECONTROLS THE REMAINDER OF THIS DOCUMENT

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    -4- Reactor Operation The reactor is used primarily for performing experiments associated with the nuclear engineering teaching program. These experiments involve sample irradiation, approach to critical, reactivity measurements, period measurements, neutron temperature measurements, power calibration, and flux distributio The reactor is also operated during demonstration courses and the operator requalification progra On May 21, 1986, the NRC inspectors witnessed startup, operation, and shutdown of the reactor _during performance of a standard operator requalification program demonstratio No violations or deviations were identifie . Requalification Training The NRC inspectors reviewed the licensee's reactor operator requalification training program for compliance with 10 CFR Part 55, Appendix A. The NRC inspectors reviewed training documents for currently licensed individuals against the licensed operators and senior operators requalification program submitted on December 5, 1973, and additional information submitted on December 10, 1974, and approved by the Operator Licensing Branch, USNRC on January 13, 1975, including the recertification schedule submitted February 21, 1977, and approved on April 12, 197 The license had committed in the February 21, 1977, recertification schedule to perform operational recertification in March and October and the annual written examination to be given each March. The NRC inspectors noted from records and the minutes of the January 12, 1983, meeting of the RSAC that the licensee operator written examination had been extended to a 2 year frequency without approval from the Operator Licensing Branch, USNRC, and that the scheduled training (operational recertification) after -

March 1981 had not been conducted in October and March for succeeding training as previously committe The licensee's requalification program Section B.5 states that, "A separate file for each licensed operator or senior operator shall be established. The attached form will be used to record and certify:

 (1) participation in the requalification training' sessions, (2) reactivity control manipulations, and (3) written and oral e,xamination result These files will also contain copies of written examinations administered, the answers given the licensee, and any additional information regarding training or requalification of each licensee."

. The NRC inspectors review of the individuai licensed operators files ! indicated that these records were not being maintained for:

 (1) participation in requalification training sessions, the last entry recorded was June 22, 1984, (2) reactivity control manipulations for

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   -5-school years 1984-85 and 1985-86 were not recorded, and (3) written examinations given on January 15, 1986, were not in the individuals fil The NRC inspectors noted that some written examinations did not indicate the date when the examination was administere The NRC inspectors stated that failure to provide annual written examinations and scheduled requalification training, and maintain individual records was an apparent violation of 10 CFR 55, Appendix A and the licensee's approved requalification program (252/8601-01). Procedures The NRC inspectors reviewed operating procedures to determine compliance with the requirements of TS 5.2. The procedures associated with the reactor are contained in the manual, "AGN-201M Reactor Ope . tion and Operator Training Manual," dated July 1984. The manual co...ains procedures for the following categories:

General Desigt Features Administration Operating Procedures Maintenance and Inspections Emergency Procedures Technical Specifications Additional procedures and guides for radiological protection activities are found in the UNM manual on radiological safet No violations or deviations were identifie . Surveillance Requirements The NRC inspectors reviewed surveillance of reactor core, control, and instrumentation systems to determine compliance with TS 4.0. The NRC inspectors verified that limits regarding excess reactivity, control and safety rods worths, core tank design, scram capabilities, and safety systems were not exceeded. The records of surveillance test results did not indicate any unusual condition No violations or deviations were identifie . Experiments The NRC inspectors reviewed the licensee's experiment records and reactor logs to determine compliance with TS The NRC inspectors determined that the licensee had not placed any new experiments in the reactor since the previous inspection. Experiments which had been conducted were used with approved procedures and approved reactor condition No violations or deviations were identifie REMOVAL OF THE PAGES MARKED " " DECONTROLS THE REMAINDER OF THIS DOCUMENT

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   -6-12. Fuel Handling Activities The NRC inspectors reviewed the licensee's fuel handling activities to determine compliance with TS 4.2 and The NRC inspectors verified the licensee had approved procedures for fuel handling activities and reviewed them for their technical adequacy in the areas of radiation protection and criticality safet The NRC inspectors determined by record review and discussions with personnel that fuel handling operations and startup tests were carried out in conformance with the licensee's approved procedure No violations or deviations were identifie . Transportation (Fuel Shipments) u The NRC inspectors verified that there had been no fuel shipments since
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the previous operational inspectio No violations or deviations were identifie . License Conditions The NRC inspectors reviewed the following license conditions: 3.a - Maximum Power Level 3.c - Authorization of Changes, Tests, and Experiments 3.d.1-d.3 - Reports 3.e - Records No violations or deviations were identifie . Radiation Protection The NRC inspectors reviewed the licensee's radiation protection program to determine compliance with 10 CFR Parts 19.11, 19.12, 19.13, 20.101, 20.104, 20.201, 20.202, 20.203, 20.207, 20.401, 20.403, 20.405, 20.408, and 20.409 and the UNM Emergency Pla t The NRC inspectors reviewed records, interviewed personnel, made observations, and performed independent survey CFR Part 20.201(b) states "each licensee shall make or cause to be made such surveys as: (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present."

The licensee performed radiation surveys in and around the reactor area on November 25, 1981, April 30, 1982, November 12, 1982, December 6, 1984, and April 18, 1985, with the reactor at 5 watts power with a PCN-4 neutron meter, UNM No. 4501 The date appearing on the calibration sticker was REMOVAL OF THE PAGES MARKED " " DECONTROLS THE REMAINDER OF THIS DOCUMENT

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  -7-illegible, and the licensee was not able to provide any documentation that the instrument had been calibrated. The licensee also had the following instruments which had no record of calibrations and past due calibration sticker Model 3 neutron meter UNM No. 159877 PAC-45 alpha meter UNM No. 128236 Model CPMU gamma meter UNM No. 153578 The licensee had documentation of a calibration check performed July 22, 1985, on the PNC-4 and Model 3 neutron meters which recorded the source used, the distance from source to detector, and the observed count rate (between 50 and 1000 counts per minute) but did not record the expected count rate and did not encompass the range (12,000 counts per minute) that the instrument would be expected to evaluate during full power reactor operations. It was also noted that the licensee's procedures did not include a method for converting counts per minute readings into mrem /hr values. The NRC inspectors also noted that the self-reading pocket dosimeters and fixed area monitors required in Section 10.3.1 of the emergency plan were not bein3 routinely calibrate The NRC inspectors stated that failure to calibrate radiation monitoring instruments was considered an apparent violation (252/8601-04) of 10 CFR Part 20.201(b).

The NRC inspectors discussed with licensee representatives what was considered an acceptable calibration program including recommendations of the industry standard ANSI N323-197 The NRC inspectors reviewed the course outline for "ChNE-231-Radiation Safety Engineering" and " Introduction to Radiation Safety" the two courses presented to students prior to admission to the NELB to verify that these individuals were receiving all the training required in 10 CFR Part 19.1 The NRC inspectors were unable to verify that training require in Regulatory Guide 8.13, applicable provisions of commission regulations, and reporting responsibilities of individuals were being performed. The NRC inspectors stated this is considered an unresolved item (252/8601-06) and will be reviewed further during a future inspectio . Environmental Surveillance / Radioactive Releases The licensee does not maintain a detailed environmental surveillance program; e.g., collection and analysis of water, soil, vegetation sample There are no specific license requirements that such a program be maintaine A licensee representative stated that no liquid effluent releases have been made since the last inspection. The licensee's operation records indicate that gaseous releases are within 10 CFR 20 limit No violations or deviations were identifie REMOVAL OF THE PAGES MARKED " " DECONTROLS THE REMAINDER OF THIS DOCUMENT

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i-8-17. Nuclear Materials Safeguards The NRC inspectors reviewed the nuclear materials inventory program to determine compliance with license condition The NRC inspectors reviewed the accountability procedures and practices records and material status reports. The procedures, practices, and records were found to be well implemented. Responsibilities and response requirements were defined clearly and understood, and appropriate test procedures were being used. The licensee had not received or shipped any materials since the previous inspectio No violations or deviations were identifie . Emergency Planning The NRC inspectors reviewed the emergency preparedness program to determine compliance with emergency plan requirement The emergency plan for the UNM AGN-201M reactor facility had been revised ] on March 11, 1985, to incorporate changes requested by the NRC. This plan was approved by the NRC on June 11, 198 The licensee had conducted an emergency drill on April 30, 198 The results of this drill and the associated evaluation was not available for review during the time of this inspectio The NRC inspectors discussed with licensee representatives the following ! aspects of the emergency plan: Section 8.2.1 refers to the type of portable radiation survey 4 instrumentation of sufficient range that is stored in the Nuclear Engineering 8.aboratory Building (NELB). Section 8.2.3 discusses self-reading pocket dosimeters for emergency use stored in the NELB and 10.3.1 discusses the calibration of portable instruments including pocket dosimeters and fixed radiation monitor Section 8.3.2 addresses the Albuquerque fire department response and transport of injured personnel to the hospital. No provision has been made to provide for training on the handling of contaminated ' individuals, directing ambulance crews of the contaminated injury entrance, or notification to the hospital that a contaminated injury is enrout Appendix A will require updating to list the new chief reactor supervisor and administrator. It was also noted that Region IV, USNRC was not included on the phone lis The licensee had a letter of agreement from the city of Albuquerque fire department to provide fire suppression and emergency medical REMOVAL OF THE PAGES MARKED " " DECONTROLS THE REMAINDER OF THIS DOCUMENT

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   -9-services, but did not have a letter of agreement from the city of Albuquerque police department to provide services in an emergenc The licensee had included the emergency response plan dated September 1982 for the state of New Mexico's Radiation Protection Bureau, Environmental Improvement Division which is routinely applied to byproduct material licensees licensed by the state of New Mexico and transportation accidents but there was no letter of agreement that this plan would apply to the UNM AGN-201M reactor facility. The NRC inspectors also questioned whether the tables contained in the states plan had the correct individuals and telephone numbers liste The licensee also included the " procedures for admission and management of radioactively contaminated patients at Bernalillo County Medical Center and Cancer Research and Treatment Center, the University of New Mexico, Albuquerque, New Mexico, reviewed December 1981." There was no agreement from the hospital that they would accept contaminated injuries from the AGN-201M reactor facility and are the individuals and telephone numbers listed in the plan accurat The licensee stated they would review the questions raised by the NRC inspector No violations or deviations were identifie . Physical Security Included as an attachment to this repor . Exit Interview The NRC inspectors met with licensee representatives at the conclusion of the inspection on May 22, 1986. The Nf.C inspectors summarized the scope and findings of the inspection as discussed in paragraphs 8, 14, 17, and 18 of this repor REMOVAL OF THE PAGES MARKED " "

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