ML20207F174

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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)


See also: IR 05000252/1986001

Text

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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 [
                         ,
                              R ' E.'  Baer,~ Radiation Speciflist, Facilities       Date
                        6/d . Radiological Protection Section
                                       lll       NlNdWlbl
                              B. Murray, Chief', Facilities' Radiological
                                                                                       bh0
                                                                                       Dhte '
                                                                                              /
                                 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 plan.
            Results: Within the areas inspected, four violations were identified (see
           paragraphs 8, 14, and 18).
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                                          DETAILS
     1.  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
        *D.  M. Woodall, Chief Reactor Supervisor
        *C.  O. Woodstock, Senior Electronics Technician
        * Denotes those present during the exit interview on May 22, 1986.
     2.  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 Committee.
         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 closed.
     3.  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 violation.
         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 details.
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         - 4.    Organization and Management Control
                 The NRC inspectors reviewed the organization and management controls to
                 determine compliance with Technical Specification (TS) 5.1.
                 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 him.
                 No violations or deviations were identified.
           5.    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

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                 procedures.
                 No violations or deviations were identified.
           6.    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 reactor.
                 It was verified that records reflected attendance by designated committee
                 members. The following items were routinely reviewed by the committees:

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                            Technical Specification Requirements
                            Organization, Staffing, and Licensing
                            New Facility Operation Manual
                            New Experiments

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                            Maintenance, Operations, and Inspection Logs
                            Excess Reactivity and Control Rod Worths
                            Procedure Changes
,                           Radiation Surveys

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                            Equipment Performance
                            Security and Security Response
                 No violations or deviations were identified.
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           7.         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 distribution.       The reactor is also operated during demonstration
                      courses and the operator requalification program.
                      On May 21, 1986, the NRC inspectors witnessed startup, operation, and
                      shutdown of the reactor _during performance of a standard operator
                      requalification program demonstration.
                      No violations or deviations were identified.
          8.          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, 1977.
                      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 committed.
                      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 results.
                      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."

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                      The NRC inspectors review of the individuai licensed operators files

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                      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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                school years 1984-85 and 1985-86 were not recorded, and (3) written
                examinations given on January 15, 1986, were not in the individuals file.
                The NRC inspectors noted that some written examinations did not indicate
                the date when the examination was administered.
                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).
           9.   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 safety.
                No violations or deviations were identified.
           10.  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 conditions.
                No violations or deviations were identified.
          11.   Experiments
                The NRC inspectors reviewed the licensee's experiment records and reactor
                logs to determine compliance with TS 3.0.
                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 conditions.
                No violations or deviations were identified.
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      12. Fuel Handling Activities
          The NRC inspectors reviewed the licensee's fuel handling activities to
          determine compliance with TS 4.2 and 4.3.
          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 safety.     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 procedures.
          No violations or deviations were identified.
      13. Transportation (Fuel Shipments)            u
          The NRC inspectors verified that there had been no fuel shipments since
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          the previous operational inspection.
          No violations or deviations were identified.
      14. 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 identified.
      15. 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 Plan.
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          The NRC inspectors reviewed records, interviewed personnel, made
          observations, and performed independent surveys.
          10 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. 45015.     The date appearing on the calibration sticker was
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       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
       stickers.
             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 calibrated.
       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 N323-1978.
       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 19.12.
       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 inspection.
   16. Environmental Surveillance / Radioactive Releases
       The licensee does not maintain a detailed environmental surveillance
       program; e.g., collection and analysis of water, soil, vegetation samples.
       There are no specific license requirements that such a program be
       maintained.
       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 limits.
       No violations or deviations were identified.
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     17. Nuclear Materials Safeguards
         The NRC inspectors reviewed the nuclear materials inventory program to
         determine compliance with license condition 2.b.
         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 inspection.
         No violations or deviations were identified.
     18. Emergency Planning
         The NRC inspectors reviewed the emergency preparedness program to
         determine compliance with emergency plan requirements.
         The emergency plan for the UNM AGN-201M reactor facility had been revised

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         on March 11, 1985, to incorporate changes requested by the NRC. This plan
         was approved by the NRC on June 11, 1985.
         The licensee had conducted an emergency drill on April 30, 1986.             The
         results of this drill and the associated evaluation was not available for
         review during the time of this inspection.
         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 monitors.
                     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

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                     individuals, directing ambulance crews of the contaminated injury
                     entrance, or notification to the hospital that a contaminated injury
                     is enroute.
                     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 list.
                     The licensee had a letter of agreement from the city of Albuquerque
                     fire department to provide fire suppression and emergency medical
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                services, but did not have a letter of agreement from the city of
                Albuquerque police department to provide services in an emergency.
                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 listed.
                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 accurate.
                The licensee stated they would review the questions raised by the NRC
                inspectors.
          No violations or deviations were identified.
      19. Physical Security
          Included as an attachment to this report.
      20. 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 report.
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