ML20203P182
| ML20203P182 | |
| Person / Time | |
|---|---|
| Site: | Kansas State University |
| Issue date: | 10/15/1986 |
| From: | Murray B, Wise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20203P177 | List: |
| References | |
| 50-188-86-02, 50-188-86-2, NUDOCS 8610270093 | |
| Download: ML20203P182 (8) | |
See also: IR 05000188/1986002
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
. REGION IV
NRC Inspection Report: 50-188/86-02 License: R-88
Docket: 50-188
Licensee: Kansas State University (KSU)
Department of Nuclear Engineering
Manhattan, Kansas 66505
Facility Name: Kansas State University
Inspection At: Manhattan, Kansas
Inspection Conducted: September 9-10, 1986
Inspector: <^="-"=
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Russell Wise, Radiation Specialist, Facilities Date
Radiological Protection Section
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Inspection Summary.
Inspection Conducted September 9-10, 1986 (Report 50-188/86-02)
Areas Inspected: Routine, unannounced inspection of the licensee's program
including: (1) radiation protection, (2) emergency preparedness, (3) material
accountability, and (4) physical security.
Results- Within the areas inspected, three violations were identified (see
paragraphs 3.a. 3.d, and 3.e).
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. DETAILS
1. Persons Contacted
- N. D. Eckhoff, Department Head, Nuclear Engineering
- R. E. Faw, Director, Nuclear Reactor Facility (NRF)
- J. F. Higginbotham, Reactor Supervisor
- F. L. Ferguson, General Manager, Physical Facilities
- J. Lambert, Radiation Safety Of ficer
- G. Simonis, Professor
- J. Daniels, Reactor Operator
- D. J. Whitfield, Reactor Operator
R. Tout, M.D., Director, Student Health Center
C. A. Beckom, Chief, KSU Police
G. D. Westcott, Industrial Hygienist
E. M. Hupe, Administrative Officer, Physical Facilities
- Denotes those present during the exit briefing.
2. Inspector Observation
The following are observations the NRC inspectors discussed with the
licensee during the exit meeting on September 10, 1986. These
observations are neither violations nor unresolved items. These items
were recommended for licensee consideration for program improvement, but
they have no specific regulatory requirement.
a. Documentation of Instrumentation Calibration / Response Tests - Records
of portable survey instrument calibrations and alarm setpoint tests
did not indicate what calibration source was used or who had
performed the calibration. (See paragraph 3.a.)
b. Calibration of Area Monitor - The area radiation monitor which
actuates the evacuation alarm is not currently calibrated above
100 mR/h. (See paragraph 3.b.)
c. Personnel Monitoring - Personnel monitoring devices were not approved
by National Voluntary Laboratory Accreditation for Personnel
i Dosimetry (NVLAP). (See paragraph 3.d.)
d. Neutron Surveys - Neutron radiation levels had not been established.
(See paragraph 3.f.)
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e. 10 CFR Part 19.12 Training - Documentation of radiation worker
, training did not include all categories of instruction in
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10 CFR 19.12. (See paragraph 3.g.)
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f. Emergency Equipment - A high range instrument was not available in an
- emergency kit. (See paragraph 4.)
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g. Key Control - Documentation of personnel authorized access to the NRF
was not current. (See paragraph 8.)
3. Radiation Protection
The licensee's radiation protection program was inspected to determine
compliance with the requirements of Technical Specifications (TS) F and H;
10 CFR Parts 19 and 20; the KSU Emergency Plan; and the recommendations of
The NRC inspector reviewed records, interviewed personnel, made
observations, and performed independent surveys.
a. Radiation Measuring Instrumentation
The NRC inspector reviewed calibration records for portable radiation
survey instrumentation for 1983, 1984, 1985, and 1986. It was noted
that calibration standards utilized for calibration and the' person
who was performing the survey instrument calibration was not recorded
on the data sheet. The licensee stated at the exit briefing on
September 10, 1986, that this observation would be reviewed.
The NRC inspector noted that calibration of portable survey
instrumentation was required to be performed in accordance with
Section 10.5 of the KSV Emergency Plan, dated October 14, 1982, which
- states, in part, that portable survey instruments will be calibrated
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semiannually. It was noted from the review of calibration records
that the following five portable radiation monitoring instruments had
been used to determine radiation levels, but had not been calibrated
semiannually.
Eberline Model E-120, Serial Number (S/N) 915, June 1984 -
July 1985
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Eberline Model E-120,.S/N 940, January - December 1985
- Eberline Model E-500B, S/N 968, January - December 1985
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Eberline Model E-500B, S/N 1021, January - September 1985
Eberline Model E-510, S/N 153, July 1985 - June 1986
The feilure to calibrate radiation monitoring instruments
semiannually as required is an apparent violation of Secticn 10.5 of
the KSU Emergency Plan. (188-8602-01)
b. Area Radiation Monitors (ARMS)
The NRC inspector reviewed the licensee's calibration programs for
ARMS which are required to be function tested daily during
operations, response tested quarterly, and calibrated annually.
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, The NRC inspector noted that documentation regarding calibration of
the ARM consists of a label placed on the readout panel of the
instrument: no other documentation was utilized to indicate what
sources were used, who performed the calibration, or the ranges of
operation at which the instrument was calibrated.
The NRC inspector noted that an area radiation monitor identified in
Section 8.3.1 of the KSU Emargency Plan, which actuates the ,
evacuation alarm at an exposure rate of 5 R/h, is only calibrated at
an upper radiation level of 100 mR/hr. The NRC inspector discussed
the need to calibrate instrumentation over the ranges of operation
addressed in the Emergency Plan.
c. Continuous Air Monitor (CAM)
The NRC inspector reviewed the licensee's program for monitoring
airborne concentrations within the reactor bay to determine
compliance with Sections F and H of the TS and Section 8.3.1 of the
Section 8.3.1 of the Emergency Plan states that the CAM is sensitive
to radioiodine and alarms at maximum permissible air concentrations
of Iodine-131 in restricted areas. The licensee stated that the
instrument is calibrated with a Technetium-99 source, but tha.t no
direct comparison results were available from the calibration results
to indicate the instruments' response to Iodine-131 levels. The NRC
inspector informed the licensee that Iodine-131 concentration might
be difficult to verify because of the masking effect of the noble
gases that are produced in the reactor bay during operations.
The NRC inspector noted that the calibration of the CAM is documented
only on the current calibration label placed on the readout meter of
the' instrument; no other documentation was utilized to indicate what
sources were used, who performed the calibration, or what ranges of
operation the instrument was calibrated.
d. Personnel Monitoring
The NRC inspector reviewed the NRF personnel radiation exposure
records for 1983, 1984, 1985, and 1986.
The personnel monitoring devices are provided by the KSU radiation
safety department. Two separate badges are utilized at KSU, a
beta gamma badge for researchers and a neutron gamma badge for NRF
staff. The NRC inspectors noted that the licensee had not conducted
testing of dosimeters as recommended in ANSI N13.11-1983.
The NRC inspector noted that the licensee had not developed written
calibration and operating procedures for use of the TLD monitoring
l system which is utilized for determining personnel exposures at KSU.
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TS, Section H, Administrative Requirements, paragraph 1, states
" written instructions, approved by the Reactor Safeguards Committee,
shall be in effect for, but not limited to:" specific areas noted in
Section H. The failure to develop written procedures for calibration
and operation of the TLD personnel monitoring system is an apparent
violation of TS, Section H.1. (188/8602-02)
The NRC inspector noted that the licensee had not participated in the
NVLAP program. The NRC inspector discussed with the licensee the
forthcoming 10 CFR Part 20 requirement that personnel monitoring
devices will need to be NVLAP accredited.
The NRC inspector noted that self reading dosimeters (SRD) are
calibrated semiannually with a radioactive source. However, the
licensee does not routinely, prior to calibration, perform testing on
SRDs to determine leakage. The NRC inspector discussed with the
licensee the recommendations of NRC RG 8.4 concerning testing and
calibration of SRD. The licensee stated at the exit briefing on
September 10, 1986, that the NRC inspector's observation would be
reviewed.
e. Environmental Surveillance / Radioactive Releases
The NRC inspector reviewed records of analysis on sump drain liquid
which is performed with a gamma spectroscopy system.
The NRC inspector noted that the licensee had not developed written
calibration and operating procedures for use of the gamma
spectroscopy system which is routinely used to analyze sump drain
water prior to release to unrestricted areas.
TS, Section H, Administrative Requirements, paragraph 1, states
" written instructions, approved by the Reactor Safeguards Committee,
shall be in effect for, but not limited to:" specific areas noted in
Section H. The failure to establish written procedures for
calibration and operation of the gamma spectroscopy system is an
apparent violation of TS, Section H.1. (188/8602-02)
Records indicated that all beta gamma radioactivity concentrations
were below 10 CFR 20 limits. However, liquid effluent is not
monitored for alpha activity. The NRC inspector noted that the
Americium / Beryllium neutron startup source located in the reactor
pool was not being routinely wipe tested for leakage and the
potential exists for the release of alpha activity into unrestricted
areas.
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
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that may be present." The failure to analyze liquid effluents for
alpha activity is an apparent violation of 10 CFR 20.201(b).
(188/8602-03)
The licensee stated that gaseous effluents are not routinely released
and that the normal pathway would be through an exhaust duct which
has been sealed and the fan switch disconnected to prevent operation.
Air intake to the reactor bay is from the outside with exhaust to the
reactor bay area. The licensee stated that elevated airborne
concentrations are present in the reactor bay atmosphere during
operations; however, no analyses have been performed to determine the
concentrations.
The failure to analyze reactor bay atmosphere to determine if
airborne concentrations exceeded 10 CFR 20 limits is an apparent
violation of 10 CFR 20.201(b). (188/8602-03)
f. Surveys
The NRC inspector reviewed radiation and contamination survey records
regarding surveys performed by the NRF staff to determine compliance
with the requirements of 10 CFR Part 20 and the recommendations of
industry standard ANSI /ANS-15.11-1977. The NRC inspector noted that
smears taken routinely to determine levels of contamination were
analyzed on the radiation safety department's liquid scintillation
counter.
The NRC inspector noted that procedures had not been developed by the
licensee for calibration and operation of the liquid scintillation
counter.
TS, Section H, Administrative Requirements, paragraph 1, states,
" written instructions, approved by the Reactor Safeguards Committee,
shall be in effect for, but not limited to:" specific areas noted in
Section H.
The failure to establish written procedures for calibration and
operation of the liquid scintillation counter is an apparent
violation of TS, Section H.1. (188/8602-02)
The NRC inspector performed independent contamination and direct
radiation dose rate surveys in the NRF. The smears taken by the NRC
inspector were analyzed on NRC Region IV laboratory counting
instrumentation, with all results less than or equal to minimum
detectable activities. Tne direct radiation survey results revealed
no areas of radiation levels in excess of 10 CFR'20 limits.
The licensee's survey program had not included an evaluation of
neutron levels with the reactor operating at full power. The NRC
inspector stated that neutron radiation levels are not usually
considered to be a problem at TRIGA facilities; however, surveys
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should be performed to establish that no significant neutron
radiation levels exist. The licensee stated at the exit brief!ng on
September 10, 1986, that the NRC inspector's observation would be
reviewed.
g. Radiation Worker Training
Personnel qualifications and training were reviewed and discussed
with the licensee to determine compliance with the requirements of
10 CFR Part 19.12 and the recommendations of RGs 8.13 and 8.29.
The NRC inspector noted that the licensee required all workers to
attend radiation protection training. However, documentation was not
available that all topics required by 10 CFR 19.12 had been covered.
The licensee stated that the topics required by 10 CFR 19.12 were
covered in training sessions, but they were not aware that
documentation to that extent would be required, and that
documentation on all future training conducted in this area would be
completed.
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The NRC inspector reviewed activity logs and determined that one
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female worked at the NRF and that instruction had not been provided'
to her and her co workers concerning the recommendations in NRC
4. Emergency Planning and Preparedness
The NRC inspector reviewed the implementation of the KSV Emergency
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Plan (EP) approved by the NRC on August 13. 1984, to determine compliance
with 10 CFR 50.54(r).
The NRC inspector reviesed assignment of responsibilities, emergency
facilities, and equipment (first aid and medical facilities,
communications, and radiation and contamination protection equipment).
The NRC inspector discussed with the KSV Student Health Center Director
their roles and responsibilities in the event of a reactor accident at the
NRF. The NRC inspector reviewed the placement and inventories of the
emergency equipment. The NRC inspector noted that the inventory of the
l cabinet located in the basement of Ward Hall indicated that two survey
- instruments, one high range and one low range instrument, would be
! available for use. At the time of the inspection, only the low range
l instrument was available for use. The licensee stated that the high range
instrument was out-of service. The NRC inspector discussed with the
licensee the need to provide a supplemental instrument to the kit to
provide for adequate inventory. The NRC inspector noted that the actual
- number and type of instruments and equipment are not specifically
l identified in the KSV EP.
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The licensee had conducted emergency exercises on August 16, 1984, and
, August 7, 1986. The critiques of emergency exercises were on file and had
l been reviewed by the Reactor Safeguards Committee (RSC) as required by the
l KSV emergency plan.
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The NRC inspector reviewed the biennial EP reviews conducted and approved
by the RSC, and the annual requalification training required for the NRF
staff. The NRC inspector noted that documentation of annual qualification
training was lacking as to specific subject matter.
l No violations or deviations were identified.
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5. Nuclear Materials Safeguards
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The NRC inspector reviewed the nuclear materials inventory program to
determine compliance with License Conditions 2.B and 2.C.
The NRC inspector reviewed the accountability procedures and practice
records and material status reports for the period January 1,1983,
through September 1, 1986. The procedures, practices, and records were
found to be well-implemented. Responsibilities and response requirements
were defined clearly and understood.
No violations or deviations were identified.
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6. Physical Security
The material discussed here contains Safeguards Information as defined by
10 CFR 73.21 and is reported in Attachment to this report.
. 7. Exit Briefing
The NRC inspector met with the licensee's representatives identified in
paragraph 1 of this report at the conclusion of the inspection on
September 10, 1986. The NRC inspector summarized the scope and inspection
findings.
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