ML071640382
| ML071640382 | |
| Person / Time | |
|---|---|
| Site: | Rhode Island Atomic Energy Commission |
| Issue date: | 06/07/2007 |
| From: | Middleton M State of RI, Atomic Energy Comm |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IR-07-201 | |
| Download: ML071640382 (2) | |
Text
STATE-OF RHODE ISLAND AND PROVIDENCE PLANTATIONS.
RHODE "ISLAND ATOMIC ENERGY COMMISSION
-=--=Rhodezlsland-Nuclear-Science Center..=.---ýr =---
16-eactor Road Narragansett, RI 02882-1165 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Reply to Notice of Violation Dated 5/22/2007
Reference:
NRC Routine Inspection Report No. 50-193/2007-201
-'k'7/2067-The Assistant Director of Nuclear Operations has reviewed the referenced Inspection Report and the Notice of Violation. The past history of performing experiments under
- 'our general authorization (1008) was review firom 1999-presehnt. The method used to
'develokpanpexperiment from first principle to an authieduserwas also evaluated._ The
-_ follow~ing is a result of this evaluation:
The reason for the violation: The RINSC staff was performing an experiment under a Nuclear and Radiation Safety Committee approved authorization #1008 received a verbal
- approval from the SRO in the control rorm. The NSC-7a, Neutron Irradiation Request Form, Rev 9/94 requires an SRO to approve the irradiations. This sample irradiation was being performed under the 1008 authorization which was reauthorized 12/14/2006 by the Nucle ar and Radiation Safety,C, 9 itteeiz Therefore,;he Nl.."aratdfRadltidn' Safety
'(&xlttee aprov e expmt,, bt,
,v approva, receivd "r6m the SRO 'w'h-o -was operatingter,*actorr,,The,
..tn,,
cplete the paperWork (NSC-7a, Neutrbn Iriadiation Requpstj.V9rn after, the co ppetiofthe.1,2-secondp looftfo, Spriclsciple sanple ian adiation. Tbe Reactor Logbook -.properly identified the rraditioY dftlhe~mples,.but asc-~7a, Neutron Irradiation-Request-Fornvwas'never com "leted Tlii project was disus~s with the st~pt Dirctor; Rea tor Supervisor anid Health
'Physics,ell in"advance of this experiment taking place.
There is a conflict between the procedure #12, 'Use of Pneumatic Irradiation Facilities' and the NSC-7A Rev. 9/94. Procedure #12,'Use of Pneumatic Irradiation Facilities',
requires that the Assistant Director approve each Irradiation Request Form, but the NSC-7A Rev 9/94 requires only an SRO to approve the Irradiation Request Form.
Corrective:Steps tihat have been taken and the results achieved:.'.:Ptoeduiire #12, Use of Pneumatic Iradiation Facdilies', will be revised tobring;it, currentwith our jreseft mode ofoperatlon. In ad.odtiori to. t-1,NeutrorJrradiationR Requ.ýstForm approval chaihge, tlereremet'to hae theeqReetor,Utiiz teion amt.-eev thor-zeWexp'erfit* Will als~o Fýe~chaef1i 6d't6 hVtheý NUe16ie"ýr.afid Riadiatiou Sa
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,ortn1ttee, authd 3-1?
experiments. The. ReactorUtl,zrtion (,romýtte,,,a,,icth.e RaCaton. oa,,ty:om--aiirikLee wlere combmed m i 199to form.the,*Nuclear an.
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J. *revised procedure will also clarify sample irradiations done under the general
- auth6fizition for proof of principle type of work.
Subsequent sample irradiations for this experiment were performed under the Nuclear and Radiation Safety Committee approved authorization #1008. The NSC-7a, Neutron I-radiaitibhiRequest Form was completed. saimple irradiation for this experiment will
- continue-under authorization #1008 -until proof of-principle has been completed and a NSC-73"Rev 11/04, 'RINSC Facility Use Requesf Form' is completed and approved by the Nuclear and Radiation Safety Committee. Subsequent sample irradiations will than be done under the new authorization number.
Corrective Steps to avoid further violations: The RINSC staff was reminded of the need to-have the proper paperwork approved in advance. Even the simplest task requires the paperwork to be completed before proceeding.
- Procedure #12, Use of Pneumatic Irradiation Facilities', willbe revised and submitted for approvai'at next Nuclear and Radiation SafetyCoimittee meetihg.
Date-of Full compliance:- RINSC will be-in full complianceto bothissues after the next Nuclear and Radiation Safety Committee meeting,'. *In advance of the approval from the Nuclear and Radiation Safety Committee of the rv&procedure #12, Use of Pneumatic Irradiation Facilities', a Memo and a marked up procedure #12, Use ofPneumatic Irradiation Facilities', will be presented to RINSC&taff., The:Memo will remind everyoneto0 follow the marked up procedure and complete allrequired paperwork before proceeding.
The Inspection Report, Notice of Violation and this response will be reviewed at the next NRSC meeting as required by Tech Specs. If youwhave any questions or concerns, please contact me at 401-789-9391.
Michael Middleton Assistant Director of Nuclear Operations Rhode Island Nuclear Science Center cc:
Governor Donald Carcieri Kevin Witt, USNRC Dr. Stephen Mecca, RIAEC Dr. Andrew Kadak, RIAEC Dr. Bahram Nassersharif, RIAEC Dr. Peter Gromet, RIAEC Dr. Alfred L. Allen, RIAEC Dr. Harry Knickle, NRSC