IR 05000186/1997201

Safety Insp Rept 50-186/97-201 on 971103-07.Violations Noted.Major Areas Inspected:Transportation Activities, Radiation Protection,Environmental Monitoring & Inspector Identified Follow Up Items

ML20203E963
Person / Time
Site:	University of Missouri-Columbia
Issue date:	12/11/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20203E932	List: IR 05000186/1997201 ML20203E925 ML20203E941
References
50-186-97-201, NUDOCS 9712170248
Download: ML20203E963 (7)

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U.S. NUCLEAR REGULATORY COMMISSIDN

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Docket No: 50 186 ,

e Uconso No: R103 Report No: 50 186/97201 Ucensee: University of Missouri at Columbia Facility Name: University of Missouri at Columbia Research Reactor Location: Columbia, Missouri Dates: November 3 7,1997

'I Inspectors: T. M. Burdick Approved by: Seymour H. Weiss, Director Non Power Reactor and Decommissioning Project Directorate 9712170248 971211 PDR 0 ADOCK 05000186 PDR

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' l Executive Summary l l

University of Missouri at Columbia Research Reactor r

- Report Nos. 50186/97201 (DRPM)

i This routine, announced inspection included espects of transportation activities (86740):

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Radiation Protection (83822); Environmental Monitoring (69004); and inspector identified ,

follow up items (92701),

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Radiation Protection (83743) t e The inspector identified one violation of posting requirements for radioactive material storage. (Section 1.0)

Environmental Protection (69004)

• Airborne and liquid effluent releases were within the regulatory limits. Radioactive waste accumulations were properly stored. (Section 2.0)

Transportation (86740)

• The inspector identified one violation of Technical Specifications requirements for procedures. (Section 3.0)

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1.0 Radation Control 4 Inspection Scope (83743) '

The inspector reviewed the radiation protection program to determine compliance with the requirements in 10 CFR Part 20 and T.S. 3.4, 3.6, 3.7, 5.1, 5.4, and , Observations and Findinas

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The inspector accompanied a health physics technician during weekly radiation instrumentation checks. All procedures and actions appeared appropriat The inspector noted that calibration sources used by the technician were belry stored in a room near the front lobby which was nct posted. Upon comparing the source strengths with the activity levels in Appendix C of Part 20 the inspector determined that a Plutonium 239 source was 157 times the amount specifie CFR 1902(e) requires that licensed materialin excess of ten times the amount of such material specifiad in Appendix C must be stored in areas that are ,

conspicuously posted with signs that include the radiation symbol and the wnrds

" CAUTION, RADIOACTIVE MATERIAL (S)" nr " DANGER, R ADIDACTIVE MATER!AL(S)." Fallure to post the radioactive materials Ltorage area is a violation (50186/97201-01).

The licensee immediately posted the area appropriately. No other similar circumstances were identified. The licensee had previously conducted an inventory of all sources and had stored the larger ones together in a posted roo The licensee could not identify a cause for overlooking the Pu 239 sourc Access to the rasctor bridge was being controlled due to a minor P 32 contamination event that was discovered on October 7 of this year. A single sample encapsulated in welded aluminum had breached at the weld after several weeks of irradiation. Similar failures of encapsulation were rare. The inspector observed reactor staff taking precautions to minimize any possible contamination spread. Contamination the licensee had identified was only slightly elevated above cdministrative limit Area radiation monitors and portable Instruments were calibrated as require The majority of postings, labeling, and st.rveys met regulatory requirements as observed on the tour of the reactor laborator A representative sample of areas were surveyed by the inspector for radiation levels including the beam port floor, hot cell, waste areas, laundry, and lab ;. No unexpected levels were identified. Some areas were temporarily elevated as the licensee had recently moved waste barrels out from areas that are inaccessible during operation in preparation for shipping. These areas were acceptably poste ._ _ _ _ , . .

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- 2-The licensee's annual radiation audit results had identified an ALARA concern on the adequacy of postings alerting workers to elevated radiation in the shipping package holding area. The licensee immediately responded to the concern by elevating employee awareness of the hazard through more prominent posting The inspector noted an unusually elevated dose for the operations manager during the May 1997 monitoring period. A discussion with the individual revealed that the dose had occurred when the manager helped retrieve a dropped radioisotope seed in the hot cell. The manager volunteered to work on the recovery to limit the dose of the hot cell workers. Operations personnel also received anticipated elevated doses during the September 1997 replacement of the Beryllium reflecto ALARA practices were consistent with program goals and requirements. -

Ongoing work at the reactor pool and hot c. ell were observed to assess radiation safety practices. Staff were well aware of the I.arards and implemented necessary precautions to minimize them, Conclusions The radiction protection program was effective in protecting the staff and publi One violation of posting requirements was identifie .0 Environmental. Protection inspection Scope (80745)

The inspectors reviewed the licensee's program for the dischargc or removal of radioactive liquid, gases, and solids from the reactor laboratory, Observations and Findinas The licensee has been aggressively pursuing the elimination of waste solids since the last inspection. Shipment activity in the past year has reduced inventory dramatically. Liquid and gaseous releases were reviewed and met 10 CFR Part 20 requirements, Conclusions

Controls for airborne and liquid effluent releases and solid wasta acceptably satisfied the regulatory limit ,

3.0 Transportation of Radioactive Materials Inspection Scope (86740)

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The inspectors reviewed the licensee's radioactive materials shipping program for compliance with the requirements in Department of Transportation (DOT) and NRC

= regulations 49 CFR Parts 170 through 177 and 10 CFR Part 71, respectively.

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3- Observations and Findinos The inspectors observed the reactor laboratory staff prepare various packages for shipping during all phases of preparation and handling without inciden During a revir sf the licensee's shipping events the inspector noted that in April 1997 s licensee customer received an empty package that was supposed to have contained 4 millicuries of Selenium (Se 75).

Because of the low energy radiation omitted by So-75, the error was not obvious during the verification of activity in the completed packag., just before shipment on April 14,1997. When the customer notified the licenses that the package arrived empty on April 20,1997, the licensee located the undisturbed sample in the transport pig where the technician had left it in the lab. The sample posed no radiation threa On April 10,1997, the licensee processed the sample of Se 75 from a prev.ously prepared batch. Unlike most radioisotopes produced at MURR the Se 75 had a sufficiently long half life to permit advanced preparation prior to the shipping dat The technician demonstrated to the inspector the procedure for processing the specified amount of material and the ultimate delivery of the material to the shipping staff for delivery to tht customer. Although there was an approved procedure for processing the Se 75 it did not contain any guidance for placing the sample in the shipping pig before delivering it to the shippers for further osckaging and ultimate delwer The licensee reviewed the event and determined that additional procedure guidance using second verification was appropriote for correcting the proble Second verification had been a licensee corrective action from previous shipping error The inspector reviewed the additional procedure guidance in the form of two additional steps requiring second verification added to the bottom of the in House Radioactive Shipping Request Form. Attachment 2 to MURR shipping procedure SAS-00004. The form is not an integral part of the Se 75 processing procedur The inspector and licensee agreed that the corrective action may not be appropriate since the form may not be completed at the time the intended steps were performed. The licensea is reviewing integration of the steps into the Se 75 processing procedure guidanc Other procedures for samp.'s processing reviewed by the inspector contained clearly emphasized steps for this type of evolution including second verificatio Each individual researcher had developed their own processing procedure as part of a pro'act proposal which received licensee review and additional conditions as necessary before approval and implementation. There was no standard for developing or reviewing these procedure = m ... .. : :-.=:= r.r.n. r r:. ncs;;.v ::.: ; m :r i----

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~4-Technical Specifications 6.1(b) requires that procedures be !. effect for shipping  ;

. radioisotopes produced in the reactor. The licensee's Pu / and Procedure '

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Manual, C4:050, * Shipping and Receiving Radioactive Materials," Rev 4,16,1995,

~ Charactortrationcocumentation, states that " internal procedures shall ensure that the proper shipning classification, packaging, shipping papers, merking, i labeling, and plac:,rdq are identified and maintained as the preparation for shipping procesi Failure to provido procedure guidanct for packaging processed samples for i shipping !s a violetion (50186\97201-02).

The inspector also determined that the technician had not obtained an  ;

independent second verification of the sample assay of activity eithough his ,

supervisor had signed as the reviewer on the in House Radioactive Shipping

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Request Form, A*:achment 2, Revision 04. Upon reviewing the guldence and discussing the intent of second verification with various licenses managers, the

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inspector determined that the practices and expertations varied among the

, departments and were unclear 'o the Acting Laboratory Director. The licensee acknowledged clarification was necessar ,

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During hot cell proporrtion of samples by shipping personnel the inspecto ,'

observed that second verification was independently obtained in critical steps of the procedure The inspector determined that the licensee's audit of the type A shipping program had brought the concern of potentially inadequate processing procedures to management attention in early 1996 and again in early 1997. The licenses had committed to correct these concerns by April 1997 but was still in the process at the time of this inspectio The licensee acknowledged the violation and stated that a Technical Specification '

(TS) change would be requested to include all related procedures in the requiremen The inspector noted one other shipping event where the licensee identified an error in over labeling before the shipment left the facility. This is an example of

effective licensee effort to control the quality of their progra The inspector attempted to follow up on a concem received from Region i NRC inspectors regarding an empty Model 8500 shipping container which uses  ;

depleted uranium shielding. The container had been delivered to Ginns nuclear puwer plant in August 1996_ where the licensee surveyed the package for radiation and contamination. The Gir.na technicians determined that the container measured 0.8 millirem per hour on contact. The package was shipped to Ginna >

from MURR as an excepted package empty packaging in accordance with 49

, CFR 173.428. The package contact radiation limit for this class of package is 0.5 millirem (mrem) per hour.

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t-5-The particuler package in this case, Serial No. 5 overpack with Serial No. 4032 depleted uranium liner, was in California and not available for inspection during the week of November 3,1997. The licensee agreed to hold the package for the next inspection visit in six month The inspector surveyed two other Model 8500 packages with two Victoreen Model 471 instruments and one Victoreen Model 4SO digitalinstrument belonging to the licensee. The Model 471 instruments c - commonly used by the shippers fer their routine surveys. Background radistk,;; oried due to the locations of these casks from 0.05 to 0.2 mrem per hour. The readings from the various instruments ranged from 0.5 te 0.7 mrem per 1 our. The instruments were unstable at these low readings and required interpretation. The inspector concluded that after subtracting background these two empty containers were at the DOT limit for excepted package empty packagin The licensee had only shipped one u.mty package in the period beginning January 1996 to the date of the inspection. Their resolution to this concern was to consider shipping this package and similar packages as Yellow ll in ..ie future but were concerned that over labeling is also inappropriet This item will be an Open item until the actual package is inspected during the next visit (50/186-97201-03). Conclusions Radioactive shipments were conducted in accordance with DOT regulations. One violation of the reactor Technical Specifications was identified, inconsistent understanding of licensee policy and use of second verification was identifie .0 Follow up on inspector Identified Problems Inspection Scope (97201)

The inspector reviewed previously identified inspector concerns and licensee performance within those area Findings and Observations Follow up Item 50186/9601-02 (clored): inspector concern with HP training weakness. The inspector reviewed HP response to events and conduct of responsibilities and had no further concern regarding the HP training weaknes This item is close Unresolved item 50-186/95004-01; 24 00513 36E/95004-01 (open): possible licensee transfer of byproduct material to an unauthorized individual. Additional inspection will be conducted in this area in 1998 by Region 111 materials inspectors. This item will remain ope ?% :nT7: .CT' ~ 7~ 7 :Q ~

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I-6- Conclusions 1-4 Further inspection will be require ,

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5.0 Persons Contacted University of Missouri Elaine Charlson' ' University of Missouri Associate R wost Charles McKibbon' MURR Interim Dirsaor Walt Meyer* MURR Reactor Manager John Ernst* MURR HP Manager Steve Gunn' iAURR Services Manager

. The inspectors also contacted other supervisory, technical and administrative staff

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personne * Denotes those attending the exit meeting on November 7,199 .0 Exit Interview (30703)

The inspectors presented the inspection results to members of the licensee management at an exit meeting on November 7,1997. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary. No proprietary

information was identifie Mspection Procedures Used IP 80745 Environmental Pe.tection

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_lP 83743 Health Physics

- . IP 8S740 !nspction of Transportation Activities IP 92701 Follow up on Inspectors identified Problems

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items Opened and Closed Opened

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50-186/37207-01 VIO Failure to post areas where radioactive material is stored.

d 50-186/37201-02 = VIO . Failure to provide adequate procedures for preparing radioisotopes for shippin .

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, ~ 50 186/97201 03 IFl - Proper labeling for errpty packagin Closed -

50 186/96001-02 IFl Weaknesses in'HP trainin Ust of Documents Reviewed Safety Analysis Report '

Safety Evaluation Report Reactor Operating Uconse Technical Specifications Administrative Procedures

. Surveillance Procedures Shipping records and procedures Dosimetry Records-Trmining Records Various Reports Ust of Acronyms Used ALARA As Low As Reasonably Achievable *

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CFR Code of Federal Regulations

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DOT Department of Transportation f HP Health Physics j

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MURR - Research Reactor Facility NGC Nuclear Rcgulatory Commission Pt/; - Public Document Room TG Technical Specifications

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