ML19253C797
| ML19253C797 | |
| Person / Time | |
|---|---|
| Site: | University of Buffalo |
| Issue date: | 09/24/1979 |
| From: | Chon W NEW YORK, STATE UNIV. OF, BUFFALO, NY |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19253C794 | List: |
| References | |
| NUDOCS 7912120144 | |
| Download: ML19253C797 (2) | |
Text
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St#.a University of Naw'Iork nt 3uffalo
(! (A Wy Wct;u Sc:zscz axo Tecusotome Factury September 24, 1979 200.2.4.1 Docket 50-57 Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Sir:
Response to Inspection Report 50-57/79-01 Please excuse us for not replying to your report within the prescribed twenty days.
I respectfully wish to point out that while the inspection was conducted on February 26-28, 1979, the notice of noncompliance forwarded to us pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice" was not written until June 12, 1979. Considerable effort has been directed toward the solution to the areas of noncompliance identified by this inspection, and while this response is somewhat late, I am confident that it will meet with your approval.
With regard to item of noncompliance A (79-01-01), the following actions are being initiated:
Members of the Reactor Operations and Radiation Protection Departments are cooperating to compile lecture outlines and related training materials, to pro-vide members of the campus security force with adequate instruction in the areas specified in 10CFR 19.13.
Once these training materials have been collected and approved by facility management, the training of the security force will be per-formed by the reactor Senior Shif t Supervisors. This training will be documented, and such documentation shall be made available for inspection by the NRC.
Coordinating administrative procedures shall be implemented by the Nuclear Facility and the University Office of Public Safety (Security) to ensure that any new officers subsequently assigned to the facility tours shall also be properly instructed. Administrative procedures shall also ensure that all Security Officers be retrained on an annual basis. Retraining shall also be documented.
We expect to be within compliance of 10CFR 19.12 within sixty (60) days.
With regard to item of noncompliance B (79-01-02), the following actions have been taken:
A. memo was circulated to all members of the Operations, Research, and Radiation Protection Departments on March 23, 1979. This memo clearly explained the methodologies to be employed to ensure full compliance with the provisions set forth in 10CFR 20 with regard to posting and access control to Radiation and High Radiation Areas. All staff members were required to acknowledge, via written record, receipt and comprehension of this memo.
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Eldon J. Brunner, Chief - Page Two - September 24, 1979 Permanent posting has been erected at all access points to the reactor bridge area.
I wish to point out that the reactor bridge is located on the containment control deck, and not on the gamma deck, as indicated by the inspection report.
The equipment storage area on the control deck was properly re-posted, and subsequently examined by Mr. Donaldson Lamediately after the inspection exit interview.
Mr. Donaldson stated at that tLne that the new posting was within compliance of the provisions set forth in 10CFR 20.203(b).
In view of the above, we feel that we have been within full compliance of 10CFR 20.203(b) since March 1979.
With regard to unresolved iten (79-01-03), calibration of Geiger-Muller (GM) survey instruments, calibration of all such instruments shall henceforth include an operational test utilizing an appropriate reference standard.
In defense of past practices, I wish to point out that such a test could be construed as superfluous. The instruments are calibrated in the electronics shop, which is located on the control deck.
Background radiation levels are sufficient in this area to drive a sensitive GM instrenent up-scale. An operational check of the GM tube and cable has therefore previously been routinely made by simply turning the instrument on, after the pulser calibra-tion has been performed.
With regard to unresolved item (79-01-04), monitoring of airborne effluents, the following steps are being taken:
The Operating Committee has met and reviewed the question of anisokinetic particulate sampling. Please note that the linear flow rates specified in Mr. Donaldson's report do not sufficiently or accurately reflect the particulate sampling characteristics of our monitoring system. These flow rates merely reflect the stream velocities in the stack duct and in the hoses leading to the monitor detectors. As such, they do not accurately reflect the kinetic nature of the actual sampling hardware.
It is the opinion of the Operating Committee that further study is necessary on this matter.
If further study determines that the particulate sampling system is indeed anisokinetic, appropriate modifications shall be made to ensure accurate airborneieffluent monitoring.
It is expected that a review of the airborne monitoring system can be completed within sixty (60) days.
I trust that the actions we have taken will meet with your approval.
If you have any questions with regard to these matters, please contact me.
Very truly yours, fd CYr'Chon Director 1538 295
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P. M. Orlosky L. G. Henry