ML20074A750

Responds to NRC Re Violations Noted in IE Insp Rept 50-142/83-01.Corrective Actions:Routine Survey Findings to Be Routed to Radiation Safety Officer,Background & Calibr Check Data Entered Into Log & Survey Results Tabulated

ML20074A750
Person / Time
Site:	05000142
Issue date:	04/29/1983
From:	Wegst W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	Book H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
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ML20074A742	List: ML20074A750
References
NUDOCS 8305160037
Download: ML20074A750 (5)

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"=/' COMMUNITY SAFETY DEPARTMENT OFFICE OF RESEARCH & OCCUPATIONAL SAFETY IDS ANCELES, CALIFORNL4 90024 April 29, 1983 Mr. H.E. Book, Acting Director Division of Radiological Safety and Safeguards Program U.S. Nuclear Regulatory Cmmission 1450 Maria Iane Walnut Creek, CA 94596 Docket No. 50-142

Dear Mr. Book:

This is in response to your letter and enclosure of March 23, 1983.

In regard to paragraph five of your transmittal letter, the reactor managment, the Director of the Office of Research & Occupational Safety, and the Radiation Use Ccmnittee share your concerns in regard to general management oversight of the NEL. However, it is evident to all that the license renewal proceedings have to be prosecuted diligently to assure the future availability of the UCIA reactor, and therefore certain priorities have been established.

In particular, because of the implanentation schedule for anergency Response Plans, UCIA had to develop an Energency Response Plan in July of 1982, with little notice and approximately four months earlier than the deadline for U.S. research reactors in general. NRC guidance for low power research reactors was slow to solidify and necessitated multiple revisions of this plan in the first half of 1982. Drafting of the Annual Report promMM concurrently but at a less than normal rate because of the foregoing activity which delayed cxxnpletion of the Annual Report until July 8, 1982.

Personnel changes, and a desire to isolate the in-depth review function fran the operating groups, led to the adoption of a new policy of audit-and-review for CY 1980. The 1980 audit (done by the UCIA Office of Internal Audit) was very extensive and was not canpleted and subnitted to the Radiation Use Cannittee until September of 1981. The reccmnendations which followed fran that audit were largely accepted by the Radiation Use Ccmnittee and among other things set in motion a major effort devoted to generating a large number of written procedures for the reactor facility.

The UCIA Office of Internal Audit does not usually perfonn routine or annual audits of the same activity. Therefore, they initially declined to do the CY 1981 audit and the NEL management had to explore other possible methods for obtaining an independent audit.

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docketNo.50-142 During'1982, the NEL managenent held exploratory discussions with three different potential audit groups, but all of these possibilities failed for various reasons. - At that point, we again appealed to the UCIA Office of Internal Audit as the only independent group capable of maintaining the continuity of past audit practices. They agreed,with the proviso that they also audit sme fraction of the 1982 year to determine management response to the 1980 audit.

The late date at which this agreenent was reached and the work load of the UCIA Office of Internal Audit was such that the 1981 audit was not empleted until Novenber of 1981 and it was then decided to cmbine the 1981 and 1982 '

audits into a single report. That report was presented to the Radiation Use Ocumittee on April 20, 1983. The results were very encouraging. The auditors also provided an outline of the audit procedure, which will be helpful in accmplishing future audit-reviews.

1982 was also a year of procedure writing. We Radiation Use Cmmittee reviewed the Bqergency Response Plan and several procedures at their June 1982 meeting and twelve procedures at their December meeting. . The Comnittee has subsequently reviewed twenty five additional procedures (11 on March 24, 1983 and 14 on April 20, 1983). We frequency of RUC meetings has also been increased to provide for more innediate oversight and review of the operations of the NEL.

The " apparent decrease in the effectiveness of the radiation protection program". overlooks sme positive steps taken by the NEL managsnent in cooperation with the UCLA Radiation Safety Office. (1) A new neutron survey meter was procured and the reactor health physicist trained in the use of that instrtrnent. (2) Plans have been made, but not yet empleted, for the installation of an improved low-level ganna/ neutron calibracion facility to be used by the UCIA RSO to calibrate the NEL survey instruments. (3) A state-of-the-art neutron personnel dosimetry badge was obtained for use at UCLA, including the reactor facility. (4) The Radiation Use Ocmnittee has been strengthened by including two individuals having expertise in radiation safety. Note that the technical specifications require only that the health physicist assigned to the SEAS be on the Ommittee. This de-facto arrangenent is doctrnented by attendance of the UCIA Radiation Safety Officer at RUC meetings. We plan to continue this arrangement until the relatively new Health Physicist cains more experience on the reactor.

It should be recognized that major staff changes have been made in the line of cmnunication between the Office of Research & Occupational Safety and the NEL Staff. These new staff in one of the two independent line organizations required

-by Technical Specification VIII. F., must now carefully define their various areas of responsibility. We weaknesses in the lines of comunication which you perceived do not reflect serious working level antagonism, but rather expectations that were i unfulfilled because they were never clearly stated. To correct this last problem, the Reactor Manager & the UCIA Radiation Safety Officer will develop a Manorandum of Understanding. The first draft of this memorandum is due in my office by the end of May. Our specific answers to the Notice of Violation dated March 23, 1983 are attached as Appendix A.

I Very Truly Yours, cc:

W. Ca mler Y Y/

N. Ostrander Walter F. Wegst [

Director, Research &

Enclosures:

Response to NRC Occupational Safety Inspection Report 83-01 ,

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.. APPENDIX A

. DFJTAILED RESPONSE TO NRC IkwtLnON REPORT 83-01 A,1 dPoutine, weekly radiation measurenents, and the collection of swipe sanples at and near the reactor facility has been the practice for many years. Both the Technical Specifications (Appendix A to License R-71'as amended February 5,1976 and March 2,1983) and the regulatory section cited in the report (10 CFR 20.201) are quite general in character. However, in the opinion of the present Radiation Safety Officer, all parts of the past routine survey method may not be necessary nor sufficient to satisfy the regulatory requirement of;

" reasonable under the circumstances to evaluate the hazards that may be present". This statement is based on the following considerations.

Sumary. Personnel film badge findings have been minimal for a number of years. However, ccncern existed regarding the use of ineffective Type A neutron film. Canparison studies were done during mid-1982 with two kinds of camercial " neutron film badges" that contain more effective detectors.

These studies also showed minimal exposures. In October of 1982, the use of Type A neutron film at UCIA was discontinued and a more advanced camercial badge service was substituted.

Similarly, the reactor facility personnel undergo periodic total body counts and urinalyses (the latter primarily but not soley for H-3) . The results of these bioassays have been negative for years. Further, all personnel exiting the facility routinely check for contanination using the hand and foot counter.

It is important to note, then, that no serious or plausible questions of personnel exposure exist here. Therefore, it is incorrect to infer that the counting of collected swipe samples is either the sole or even major indicator of radioactive material contamination around the facility. Hence, the assumption that a faulty sanple counter constitutes a violation of the regulations or the technical specifications seems questionable. However, this oversight does violate good practices and, of course, should have been observed and acted upon during the period in question.

Corrective Action. The laboratory counter, a gas flow proportional counter system, is located in the Radiation Safety Office. This counter has been used since mid 1982, because the aging G.M. counter systems at the reactor facility were found to be unreliable and were taken out of use. No other useful equipnent was available at the reactor facility.

The following actions have been taken to assure measurcment quality.

1. Routine survey findings will be routed to the UCIA Padiation Safety Officer for review, concurrence, and any necessary followup.

2_. The present SEAS health physicist has begun a program of instruction and test, such that data on backgrounds and calibration checks are collected routinely and entered into a log dedicated to this instrument.

3. Each user of the counter is now instructed to collect calibration check

~ data along with swipe sample data.

4. The tabulation of survey results in appropriate units for retention in the reactor health physics records, is beginning (see following item C,2) .

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Actiens 1, 2, and 4 are currently being effected. It s 3 has been handled Arbally ard its effects will be monitored as per its 17 Its 3 will be made a formalized UCIA procedure, applicable to the NEL and in accordance with the develognent of information required for the renewal of UCIA's State of California Broad Scope License.

A,2 It is true that extremity personnel radiation nonitoring is smetimes prudent. However, monitoring of these activities with survey instruments has not identified any serious extraity exposures and the continuing minimal exposures of the personnel dosimetry badges indicate that no serious probles exist.

Corrective Action. Arrang m ents have been made to provide finger rings with TIDs. 'Ihey will be required for use by appropriate people at the reactor facility, under the guidance of the SEAS health physicist, as well as for other groups around UCIA. The date for this action is May 2, 1983.

The need for long term use of these monitors will be evaluated as a data base. is empiled.

B The annual audit of the 1981 and 1982 operating years is now cmplete and has been reviewed by the Radiation Use Cmmittee (minutes of April 20, 1983).

Corrective Action. The audit group (UCIA's Office of Internal Audit) has presented an outline of the audit procedure. This provides reactor management and the Radiation Use Cmmittee with nuch greater flexibility in meeting the requirements of future annual in-depth reviews. With this task definition, meaningful discussion can and will be undertaken with potential audit / review groups.

C,1 The cause of this violation remains a mystery. Reactor time was allotted on June 29, 1982, and identified as Run #2886, " PAR VAR". The survey *. ras conducted by the UCIA RSO, with the assistance of the Reactor Supervisor and the then-assigned health physicist. Beta-ganma survey instruments, along with three neutron survey instruments, were splayed. The three neutron instruments were two

" Snoopy" types (based on the Anderson-Braun type) and the new Eberline 9 inch moderator sphere-Rascal cmbination (referred to as PRS-2P) . The PRS-2P was procured jointly by the reactor facility and the Radiation Safety Office to

( replace an earlier "lin-log" PNR-4 version that was damaged during i transportation to an off-site location'for calibration.

All results, during full power operation were empletely negligible. On top of the reactor, measurable ganma-ray levels were found that justified the use of radiation area signs. The only neutron signal was observed next to the thermal column. (Incidentally, one " Snoopy" was found to be inoperative during these surveys, and it was removed fran service.) No significant radiation levels were found.

The cmpleted survey form was left in the custody of the then health physicist, because the findings, except for the inoperative instrument, required no follow-up. That record cannot be found. It was and is the responsibility of l

the SEAS Health Physicist to collect and maintain such records.

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Corrective Action. No new action is contenplated or required, except A assure that records are maintained. However, corrective action identified in A,1 its l_ above will also apply here.

C,2 te desirabi)i' of a requirement that records of measurements be maintained in m l units is self evident. A minor problen with the requirement has to do with curvey instrunents that are calibrated with known sources having outputs in units of mR/hr for ganma-rays, mrad /hr for the beta-ray sources or neutrons per second for neutron sources. Ths conversion of source outputs to instrument responses is not always straightforward, if the unit of mrs /hr is used so as to gain conformance to the basic radiation standards on personnel exposure specified in Part 20. We will use mrem for personnel exoosure data and appropriate response units for instruments.

A more significant problen is how to report the findings of swipe surveys. Despite what NBC believes, the uncertainty in collecting virtually any sanple, especially a swipe sample, is often unknown and large; the correction of such data to activity per unit area or any other specified area, then, seems inappropriate. Therefore, swipes will be reported in units of total activity in pCi of removable radioactive material. Air particulate activity will be reported in units of pCi/cc.

Corrective Action. 'Ihe present weekly and annual forms require modification and will be updated. The planned modification will clarify the instruments used and, where applicable, real units, i.e. pCi, will be required. Any use of CPM, i.e. c/ min, will be explained in a note that presents the appropriate conversion to activity and the radioactivity standard splayed.

We date for cmpletion and first use of these forms will be June 1,1983.

htY Date: May 1,1983 Walter F. Wegst Director, Research &

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