IR 05000297/1988004

Insp Rept 50-297/88-04 on 880926-29.Violations Noted.Major Areas Inspected:Onsite Review of Licensee Radiation Protection Program,Including Staff Organization,Training, Radiation Control & Surveillance Activities

ML20205R013
Person / Time
Site:	North Carolina State University
Issue date:	10/31/1988
From:	Hosey C, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205Q992	List: IR 05000297/1988004 ML20205Q987 ML20205R000
References
50-297-88-04, 50-297-88-4, IEIN-87-003, IEIN-87-031, IEIN-87-3, IEIN-87-31, IEIN-88-002, IEIN-88-008, IEIN-88-032, IEIN-88-034, IEIN-88-062, IEIN-88-2, IEIN-88-32, IEIN-88-34, IEIN-88-62, IEIN-88-8, NUDOCS 8811090424
Download: ML20205R013 (13)

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• • . UNITED STATES .j NUCLEAR REGilLATORY COMMISSION o 8 REGION il '

101 MARIETTA ST., ATLANTA, GEORGIA 30323

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,. NOV 0 21988 Report No.: 50-297/88-04 Licensee: North Carolina State University Raleigh, NC 27607 Docket No.: 50-297 License No.: Pulstar R-120 Facility Name: North Carolina State University

, inspection Conducted: September 26-29, 1988 Inspector: I m,_ b b c)1 Od M M M CB. Ktizo Date Signed

Approved by: Tk C. M. Hosey, Section) Chief m /0 ;f /8 Date Signed 1 Division of Radiatich Safety and Safeguards I

. SUMMARY i

J Scope: This routine, unannounced inspection involved onsite review of the

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licensee's radiation protection program including staff organi7ation, training,

radiation control a td surveillance activities, environmental monitoring, transportation acti"ities, and followup of previous enforcement issues, inspector followup items and NRC Information Notices.

l Results: Program strengths were identified regarding licensee initiatives in using supplemental audits to evaluate the research reactor radiation protection and environmental raonitoring programs and in implementing specialized training for operators and experimenters at the facility. Program weaknesses included inadequate managenent review of support groups conducting routine radiation protection activities as noted by the failure to require the reactor program

general radiation safety training for selected Radiation Protection Office (RPO)

i personnel frequer, ting the facility and the failure to maintain procedures for i

specific effluent measurement and environmental monitoring program Within the areas inspected, the following violation was identifie '

- Failure to maintain procedures used by the Radiation Safety Office personnel for specific effluent measurement and environmental monitoring radiological analyses.

! One unresolved item was identified involving the adequacy of training provided to Raditaion Safety Office personnel conducting contamination surveys at the facility to meet 10 CFR 19.12 requirements, Paragraph 3.

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REPORT DETAILS rersons Contacted Licensee Employees

• Bowman, Associate Radiation Safety Officer

• Brackin, Rcdiation Safety Specialist

• Bray, Manager, Reactor Operations ,

• Ellerman, Chairman, Nuclear Engineering

• Mani, Reactor Health Physicist

• G. Miller, Associate, Director, Nuclear Reactor Program

• D. Morgan, Radiation Protection Officer

• B. Wehring, Director, Nuclear Reactor Program Other licensee employees contacted included experimenters, technicians, operators and office personne * Attended exit interview Organization and Management Controls (83743) Organi * tion, Staffing, Management Controls Technical Specification (TS) Section 6.1 details the organizational structure, management responsibility and the lines of authority involved in the safe and efficient operation of the reactor facility.

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The inspector reviewed the facility staff organization against applicable TSs. The facility organization and staff experience met the applicable TS requirements. From discussion with cognizant licensee representatives, the inspector verified that the Reactor Health Physicist reports directly to the Head, Department of Nuclear Engineering, and functions independently of the reactor operations organization. The reactor health physicist has extensive educational and practical experience in radiation protection issues and appreared  ;

capable of evaluating health physics activities at the facilit ;

i The majority of routine radiation protection activities and surveillances are performed by the facility's operations staff. In addition, selected surveillances, for example, confinement filter testing and routine contamination surveys were conducted by personnel

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not directly associated with the research reactor programs. The use of these support groups is needed for the licensee to meet TS required surveillances in areas where specialized training and equipment are require The use of staff and support groups appeared adequate to maintain the radiation safety program at the facilit No violations or deviations were identifie '

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b. Audits .

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TS 6.2 requires the Radiation Protection Council (RPC) to review and

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audit reactor operations to ensure that the facility is operated in a manner consistent with public safety and within the terms of the i i facility license. The RPC is required to meet every four months to ;

i review and approve untried experiments; changes to the procedures, ;

j equipment or systems; reportable events; changes to facility license [

and TS; and review and audit facility operations. TSs 6.2.2 through :

6.2.7 detail RPC committee composition and qualifications of members, I

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required documentation, rules, and also meeting and audit frequenc :

i The inspector reviewed and discussed the status of RPC audit program !

, with cognizant licensee representative Licensee representatives j i stated that from October 1987, through September 1988, selected RPC members conducted an internal Health Physics Audit of reactor operations. The comprehensive audit was initiated in response to the ;

licensee's awareness of recent documented deficiencies at other :

! research reactors and, in addition, to previously identified ,

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deficiencies regarding transportation and radiation protection ;

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activities (Inspection Report Nos. 50-297/87-01 and 50-293/87-03) for the North Carolina State University (NCSU) facility. The inspector i l reviewed monthly records of the audit committee meetings and noted l j areas reviewed including, 10 CFR Parts 19 and 20 requirements,

, verification of detection sensitivity for monitoring instrumentation, i t

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bioassay capability requirements, improvements in contamination [

surveys and posting requirements. The inspector noted that a final i report and recomendations were scheduled to be presented to the "

. Head, Nuclear Engineering Department in the near futur ,

i The inspector acknowledged the depth and extent of the HP audit j regarding daily activities, both thote directly associated with :

, facility operations and experiments conducted; however, the inspector noted that the HP audit did not review in depth, the applicability of l l

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similar requirements for support groups utilized by the reactor j facilit Licensee representatives stated that an audit of the facility's environmental monitoring program, which is conducted by !

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the Radiation Protection Office (RPO), was recently conducted. This t audit utilized staff from an NRC licensed utility. The inspector !

i reviewed and discussed recomended changes to the facility l i environmental monitoring program identified during the audit which :

l were detailed in a Memorandum to the RPC dated August 31, 198 From discussion with licensee representatives and tours of the laboratory ,

facilities, the inspector verified that selected recomendations, for l example, upgrading of the RPO's gama spectroscopy system used to

conduct gama spectroscopy measurements of environmental samples, I were implemente Licensee representatives stated that other

! recomendations, for example, dinging the samples collected end i 2 analyzed, were being evaluated, and decisions regarding their i j implementation were to be made on a timely basis.

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I TS 6.2.3 requires the Reactor Safeguards Advisory Group (RSAG) to be

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responsible for. independent appraisals of reactor operations, and subsequent reports of its invn tigations to the RPC, Department Head,

and Associate Directo ;

i This area was reviewed during a previous NRC inspection conducted [

t May 23-26, 1988. (Inpsection Report No. 50-297/88-03). The inspector i

, verified that a RSAG subcommittee met since the May NRC Inspection

and reviewed previous inspection findings, relicensing issues, and maintenance activities associated with the reactor.

j No violations or deviations were identifie l Training (83743) ,

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l 10 CFR 19.12 requires the licensee to instruct all individuals working in f

, or frequenting any portion of the restricted area in the health protection i problems associated with exposure to radioactive material or radiation, in !

precautions or procedures to minimize exposure, and in the purpose and '

j functions of protective devices employed, applicable provisions of !

j Comission Regulations, individuals responsibilities and the availability of radiation exposure reports which workers may request pursuant to

10 CFR 19.1 .

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The licensee's training programs for personnel using and frequenting the *

research reactor facilities were discussed. The licensee has developed ;

and submitted to the RPC for approval a new training procedure, HP-30-2, l

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Radiation Safety Training. The procedure will require a detailed reactor [

facility training course and subsequent testing to be provided on an I annual frequency to all faculty, staff, and students utilizing or l l frequenting the research reactor facility. Course topics to be included !

) in training already have been presented during training of the nuclear l l operations and nuclear services groups at the facility. The inspector !

j noted that topics included, basic radiation principles, risks associated !

l with exposure,10 CFR Parts 19 and 20 regulations, facility radiation ;

} practices and procedures, and responses to radiological emergencies.

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] The inspector discussed with licenser. representatives the need to provide l

the general facility radiation training to personnel prior to being a allowed access to the facilit Licensee representatives stated that t access without this training was allowed for personnel escorted by a

trained facility employee or to unescorted RP0 personnel providing support activities, for example, contamination surveys for the facility. All

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other unescorted individuals at the facility receive this training.

j Licensee representatives stated that the RPO personnel were instructed in j basic radiation safety training provided to all campus personnel provided with dosimetry and, in addition, were given "on-the-job" training

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I regarding specific facility hazards during their initial visit to the research reactor. Licensee representatives stated that the training was l presented for activities under the State of North Carolina license and as

an "Agreement State" met the intent of 10 CFR Part 19.12. However, at the

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time of the inspection, no documentation of topics presented, nor records

indicating the training conducted were presented to the insrector. The

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inspector interviewed selected RPO personnel and discussed the training i received. Although appearing knowledgeable of the general radiation ,

safety principles and hazards present at the facility, the inspector noted i that the technicians were unaware of a monitor specifying radiation leve'is  ;

in the mechanical equipment room and also were not instructed specifically ,

in the applicable provisici:s of Comission regulations, individual

] responsibilities and th( evailability of radiation exposure reports which .

workers may request pursuant to 10 CFR 19.1 The inspector informed

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licensee representatives that the adequacy of the training provided to the i RPO technicians conducting routine radiation protection surveys at the 4 reactor facilities to meet 10 CFR 19.12 requirements was considered an  !

unresolved item * pendin review of applicable training materials and  :

] records (50-297/88-04-01 .

In addition to the general training provided to all persons frequenting i

the facility, the licensee has implemented specialized "on the job" ,

training concerning specialized facility activitie The inspector i

, reviewed specialized training topic details and attendance records l concerning use of the rotating exposure port and pneumatic transfer system The most recent training for these activities was conducted during July through August 1987. Prior training in these areas was 1 provided in 1983. The inspector noted that similar specialized training '

j for the RPO technicians frequenting the facility was not documented in the i j selected records reviewed. Licensee representatives agreed to evaluate ,

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j the need to increase the frequency of training regarding specialized t activitie !

l j Radiation Control (83743)  ! Facility Tours - Posting, Surveys l i i 10 CFR 10.11 requires each licensee to conspicuously post current l

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copies of (1) 10 CFR Parts 19 and 20; (2) the license; (3) operating l i procedures; and (4) Form NRC-3; in sufficient places to permit '

! individuals engaged in licensed activity to observe them on the way 1 to and from any licensed activit if posting of the

! documents specified in (1), (2) y location,and (3) is not practicable the j

! licensee may post a notice which descrit.cd the document and states  :

j where they may be examine I

! During tours of the facility, the inspector noted the presence of the  !

required postings at the access area to the research reactor control '

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j * Unresolved items are matters about which more infonnation is required to

determine whether they are acceptable of may involve violations or deviations.

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10 CFR 20.201(b) requires the licensee to perform such surveys as may i be necessary and are reasonable under the circumstances to evaluate

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the extent of the radiation hazards that may be present.

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During tours of the research reactor bay area cnd associated ,

laboratory facilities, the inspector noted a high degree of

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cleanliness and organization of equipment and materials. Selected ,

review of instrumentation in use at the pneumatic transfer system.

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"rabbit," receiving stations and also access areas to the .facilityf [

verified that all portable and fixed radiation survey instrumentation [

i- were calibrated and source checked in accordance with approved  ;

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procedure !

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Procedure HP-20-14, Radiation and Contamination Surveys, Rev.1,  !

dated January 7,1966, details the required routine surveys to be 3 conducte The inspector noted that in addition to the routine {

j surveys conducted, weekly special surveys now have been implemented ;

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to upgrade the contamination surveillance program. From discussion t j with the licensee, the inspector noted that 200 disintegrations per !

minute per 100 square centimeters (dpm/100cm2) beta-gamma activity and 20 dpm/100 cmr alpha activity are considered significant surface l;

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j activity levels requiring decontamination. A review of selected l 4 August through September 1988, rpecial weekly survey results '

indicated that current surface activity levels within the reactor i J building are maintaint.d below 10 dpm/100 cm2 relative to background l j levels. A review of radiation exposure surveys conducted between <

4 May 1987 through September 1988, indicated exposure rates within the i i research reactor bay area to be less than or equal to five millirem :

i per hour (mrem /hr) for beta-gama activity and 25 mrem /hr for neutron :

Highest exposure levels were associated with the

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i exposure.

] radiography areas of the facilit l

1 10 CFR 20.203 specifies the requirements for posting radiation areas, j high radiation areas and radioactive materials, i i  :

1 During facility tours, the inspector observed postings and verified j i through discussions and review of survey records that postings were >

] applicable to the radiation levels presen .

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) No violations or deviations were identifie l l

I j b. External Exposure Review I

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l 10 CFR 20.101 delineates the quarterly radiation exposure limits to !

j whole body, skin of the whole body, and the extremities.

! The inspector reviewed and discussed the licensee's exposure records

! for persons working at or visiting the research reactor facility from i January 1, 1988 to June 30, 1988. The highest accumulated whole body

exposure for the period reveiwed was approximately 30 mrem. The inspector noted that the majority of recordings were less than the

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detection limit, apprcximately 10 mrem, of the vendor provided film badge, in response to a previous inspector followup item concerning extremity dose to personnel handling irradiated sampling baskets, the licensee initiated use of finger ring dosimetry for esplicable personnel in October 1987. The maximum accumulated extremity doses reported were 130 mrem for one person monitored during the first, and 280 mrem for another individual monitored during the initial two quarters of 1988, respectively. Licensee representatives stated that these exposure results were associate with personnel involved in the majority of rotati'n experimental port basket manipulation Licensee representatives stated that the need for continued use of extremity dosimeters would be evaluated and a decision regarding their routine use by experimenters made in the near futur No violaticns or deviations were identifie c. Surveillances TS 4.5.e requires the confinement filter train to be tested biannually but at intervals not to exceed twenty-six months; and prior to reactor operation following filter replacemen TS 4.5.f requires the 600 cfm air flow rate in the confinement stack exhaust duct to be verified annually but at intervals not exceed fourteen (14) month Surveillance testing and verification of operability of the confinement filter systems were discussed with cognizant licensee representatives. Air flow verification was conducted by licensee staff. From review of applicable records, the inspector determined that the system air flow was tested and verified to be in accordance with TS requirements from July 1982 through July 198 ,

The inspector discussed with cognizant licensee representatives the testing methodology for the confinement HEPA and charcoal filters.

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Testing methodologies are not specified by TS. System HEPA and l charcoal filter operability were verified using vendor procedures which were maintained ui the licensee. The inspector reviewed and discussed with cognizant licensee representatives confinement filter test results from June 1982 through July 1988. From review of !

records, and discussion with licensee representatives concerning

variations in testing criteria for iodine retention by charcoal, that is, performance requirements at either 30 degrees centigrade (*C)

versus 180 *C, the inspector noted that the test criteria utilized by the vendor were not specified by, nor familiar to licensee personne Further review of test data indicated that the acceptance criteria met the most consernztive specifications detailed in Table 5-1 ANSI /MSME H509 - 193':, Nuclear Power Plant Air Cleaning Units and '

Components. For the selected records reviewed, all HEPA and charcoal

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filters met the applicable acceptance criteria. The licensee agreed to evaluate the need for specifying testing criteria to the vendor to ensure that all performance criteria to verify system operability were me <

No violations or deviations were identifie . Environmental (80745)

i Effluent Releases TS 6.7.5 requires an annual report within 60 days following the 30th of June of each year (in writing to the Director of the USNRC Office of Nuclear Reactor Regulation with a copy to the Region 11 Regional Administrator) providii; a suamary of the nature and amount of radioactive effluents released or discharged to the environs beyond the effective control of the licensee as measured at or prior to the point of such release or discharg The licensee's annual reports for the July 1, through June 30, reporting period, for both 1987 and 1988, were reviewed and discussed in detail with cognizant licensee representative The inspector noted that for both years the licensee requested additional time to ;

provide the environmental data to the report. The collection of the environmental samples, their radiological analyses, and preparation of the environmental data results are conducted by Radiation Protection Office (RP0) staff. RP0 representatives indicated that l delays in providing the environmental sections of the reports [

resulted from equipment operability problems and time constraints of ;

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personnel during 1987 and 1988, respectively. The licensee indicated '

that selected actions were implemented and/or planned to improve the timeliness of the environmental sections of the annual reports, including new analytical equipment to conduct radiological analyses ,

and use of computer systems to improve data acquisition and

retrieval. The inspector noted that the RP0 recently had acquired a new gama spectroscopy system for use in conducting environmental sample analyses. In addition, RP0 staff were planning to develop an appropriate data sheet format for use with adequate vendor sof tware to computerire the routine storage, statistical analyses, and l

subsequent retrieval of the environmental data for preparing the i j environmental section of the annual report. The inspector stated I that the timeliness of the environmental sectierS would be reviewed during future inspections, t

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The inspector reviewed and discussed with cognizant licensee l i representatives, the effluent monitoring results detailed for July 1,

! 1986 through June 30, 1987, and July 1, 1987 through June 30, 1988.

, A significant reduction in the total activity released between the

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two reporting periods was noted for both liquid,101.5 compared to 68.9 microcuries (uti), and gaseous, 8.33 compare ( .o 4.6 curies (C1), effluents, respectivel The reported quantities of tritium I

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L (H-3) released decreased from 276.4 uCi compared to concentrations less than the minimum detectable activity (MDA) between the two reporting periods reviewed. Licensee represer.tatives stated that the l differences resulted from the types of experimental activities  ;

conducted and also from a shut down in operations required to repair '

a pool lea ,

No violations or deviations were identific Analytical Measurements The analytical sensitivity of the RP0's liquid scintillation methodology was discusse The inspector noted that for the July 1, 1987 through June 30, 1988, reporting period H-S activity released i was specified as less than HDA in contrast to 276.4 uCi for the ,

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previous reporting period. Furthermore, neither the actual MDA nor data to conduct appropriate detector sensitivity calculations were specified in the repor The inspector requested that the MDA for H-3 be calculated to verify that H-3 concentrations released did not exceed the Maximum Perm'ssible Concentrations in water (MPCw) allowed i for release to the sanitary sewer as specified by 10 CFR 20 Appendix B. Table 1 Column 2. Licensee representatives stated that the MDA l

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was approximately 3.9 E-5 microcuries per cubic centimeter (uCi/cc).

The inspector informed licensee representatives that either MDA or lower limit of detection (LLD) specifications should be included in the effluent and environmental sections of the annual reports when data are reported to be "less than" selected analytical limit i licensee representatives stated that this issue would be reviewed,

evaluated, and as appropriate, included in subsequent report '

TS 6.3.a(8) requires operating procedures to be written, updated periodically and followed for radiation control. These procedures will be maintained by operations personnel.

, The licensee utilizes RPO personnel and instrumentation to provide i

effluent H-3 and selected environmental radiological analyses. The l 1 inspector toured the RPO laboratory facilities used to process and i

] conduct environmental sample radiological and ef fluent H-3 analyses, i RPO analytical capabilities included H-5 analysis utilizing liquid

, scintillation methodology, gross beta /gama determinations using gas i flow proportional counters, and gamma spectroscopy using a aermanium j detection system. At the time of the inspection, the RP0 was not .

a utilizing approved procedures for gama spectroscopy analyses of [

soil, water and particulate filte*s nor with the procedures utilized for H-3 analyses of liquid 1ffluent in addition, the operations staff had not detailed minimum analysis specifications to the RPO,  ;

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for example, required detection limits for the analyscs conducte '

I Furthermore, the reactor facility staff members were not aware of the actual methodology utilized to conduct the analyses, for example, the use of self-absorption corrections for gross beta-gama measurements

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of environmental samples nor the detection limits of the H-3 effluent ,

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analyses. The importance of the licensee's review of the RP0's  ;

methodology, that is, to verify adequacy of the analyses conducted and 'their respective detection limits, was discussed with cognizant

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licensee representatives. Failure to have and maintain approvad l

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procedures utilized by the RPO for the facility's environmental and .

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H-3 violation effluent of TSradiolog(ical measurements was identified as an apparent 6.3.a 8) (50-297/88-04-02).

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! The inspector discussed the license's ability to verify the accuracy l of their effluent and environmental radiological measurements. The i I inspector discussed with both reactor facility staff and RPO a representative the following issues regarding quality control of  ;

analytical radiological measurement t l

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The laboratories utilized National Bureau of Standards (NBS) '

traceable souece material for standards, however, the most l recent source material was dated 1981. The sNrce material f i should be updated on an increased frequenc l

The RPO laboratory does self-absorption corrections for i

conducting environmental gross beta-gamma activity analyses, l l however, the reactor facility does not conduct nor perform an j 4 evaluation to determine the need for similar corrections for  !

! their gross beta-gamma analyses of liquid waste tank release  ;

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cross comparison program with, for example, other state, NRC i licensed facilities nor the Enviros ental Protection Agency *

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Licensee representatives stated that these issues would be discussed, evaluated, and where appropriate, actions taken, j Transportation (86740) ,

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l 10 CFR 71.5 requires that each licensee who transports licensed material f

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l applicable ofplant or other place the Department of use to comp (ly of Transportation DOT) with in the !

j 49 CFR Parts 170 through 189.

l The transfer of radioactive matetial, both radioactive waste or j experimental material, from the reactor facility was discussed. For  ;

material transferred from the reactor facility, authority for possession i i is transferred to the appropriate state licens Since the last '

j inspection of transportation activities at the facility, inspection Report i No. 50-297/87-03, the licensee has transferred two shipments of I radioactive waste material generated at the reactor facility. to the .

Radiation Protection Office. The waste included spent resin and dry i trash. In addition, two shipments of radioactive material were made to  :

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the Veterinary Hospital. Licensee records indicated that the shipments f

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were made in accordance with procedure HP 10-5, Transfer and Shipment of Radioactive Material, dated April 23, 198 The inspector reviewed :

selected shipping record Licensee activities . in this area were conducted in compliance with approved procedures, j No violations or deviations were identifie l Licensee Action on Previous Enforcement Issues (92702) [

! (Closed)VIO 50-297/87-03-02: Failure to Adhere to Radiation Control j Procedures for Handling Experiments and Failure to Maintain Procedure t for Frisker Calibration. The inspector reviewed and verified ;'

implementation of corrective actions stated in the North Carolina

State University response dated November 6, 198 Procedural

, controls for handling baskets used for irradiation experiments were ,

! reviewed and discussed with cognizant licensee representatives. In '

j addition, a procedure for calibration of the RM-14 friskers has been [

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developed and is maintained by the operations personnel. A review of ,

j licensee records verified implementation of the corrective actions -

1 , (Closed) URI 50-297/87-03-03: Calibration Records for RM-14s for ,

! 198 This issue concerned the adequacy of the RM-14 friskers to !

j perform radiation surveys. During a previous inspection, calibration r and response records were not available for review. The inspector l verified that both the electronic calibration and monthly response [

checks were being conducted as required. Licensee representatives

' stat 1d that in accordance with established procedures electronic !

calibrations of the friskers were conducted, however, a recuirement l 1 to perform an efficiency determination was not included n the d l

procedure. In response to this item, the licensee developed a new (

procedure which now includes an efficiency determination for each I

instrument. The inspector reviewed the new procedure requirements l 4 and verified their implementation to demonstrate operability of RM-14 '

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j Folicwup Items (92701) i

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The inspector reviewed licensee actions regarding previously identified f inspector followup items and also detemined that the following NRC ;

. Information Notices (ins) had been received by the licensee, distributed ;

] to the appropriate personnel, and reviewed for applicability to the !

radiation protection progra '

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] NRC Information Notices IN 87-03: Segregation of Hazardeus and Low-level Radioactive Wastes

IN 87-31: Blocking, Bracing, and Securing of Radioactive Matertuls ,

Packages in Tran$portation '

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) IN 88-02: Lott o. Stolen Gauges  ;

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11 IN 88-08: Chemical Reactions with Radioactive Waste Solidification Agents IN 88-32: Prompt Reporting to NRC of Significant incidents involving i Radioactive Material r

IN 88-34: Nuclear Material Control and Accountability of Non-Fuel Special Nuclear Material at Power Reactor ,

IN 88-62: Recent Findings Concerning implementation of Quality Assurance Programs by Suppliers of Transport Packages From discussion with licensee representatives, the inspector noted :

that although the NRC Notices were received by the Director, Nuclear Reactor Program, the notices were not routinely distributed to the ;

a reactor health physicist nor cognizant personnel in the Radiation i 1 Protection Office. The transmittal of appropriate NRC IN materials

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to these personnel was encouraged as a result of their involvement in support functions for facility operation Licensee management

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stated that the informa' ion would be forwarded to the appropriate !

personnel.

i InspectorFollowupItem(IFI) ,

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(Closed) IFI 50-297/87-03 01: Re-evaluation of Extremity Dose. This f

IFl concerned evaluating extremity doses received by experimenters !

retrieving baskets containing the irradiated samples from the reactor !

pool. The licensee initiated extremity dose monitoring using finger i ring thermoluminescent dosimeters (TLDs) in October 198 For two l experimenters conducting the majority of basket retrievals, highest extremity dose measured were approximately 120 millirem (mrem) for an individual monitored for a quarterly reporting period and 280 mrem i for another individual monitored for a six month interval. Results !

for other personnel were below the detection sensitivity (10 mrem) of t the monitoring devic . Exit interview The inspection scope and results were sumarized cn September 29, 1988, with those persons indicated in Paragraph 1. Program strengths regarding !

specialized training and audits of the radiation protection and I

, environmental monttoring programs were discusse Concerns regarding '

acceptable training for personnel providing support activities and also ;

maintenance of procedures utilized to neet regulatory compliance issues .

were discussed. Licensee representatives acknowledged the inspector's f coments and also stated that information detailing the extent of training

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provided to support personnel would be sent to the inspector for his i

review. During teleconferences held on October 24 and 25,1988, the i

. inspector informed licensee representatives that the requested training

! material had not been received and the concern regarding RPO personnel

) training would be considered an unresolved item. Licensee representatives ;

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acknowledged the failure to provide the requested material and stated that the information would be fomarded in a timely matiner. The licensee did not identify as proprietary any of the material provided to or reviewed by i the inspector during this inspectio .

Item Number Description and Reference  !

70-297/88-04-01 Unresolved item - Adequacy of training  ;

provided to Radiation Safety Office  !

personnel to meet 10 CFR 19.12 requirements ,

(Paragraph 3). i

,

70-297/88-04-02 Violation - Failure to maintain procedures used by Radiation Safety Office personnel for radiological effluent and environmental  ;

measurement analyses (Paragraph 5.b).

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