ML19256E305

Responds to NRC 791003 Ltr Re Violation Noted in IE Insp Rept 50-228/79-01.Corrective Actions:Subj Experiment Signed by Committee Chairman on 791006,bringing Item Into Compliance

ML19256E305
Person / Time
Site:	Aerotest
Issue date:	10/15/1979
From:	Newacheck R AEROTEST OPERATIONS, INC.
To:	Crews J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19256E303	List: ML19256E305
References
NUDOCS 7911020072
Download: ML19256E305 (2)

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AEROTEST OPER ATIONS, INC.

3455 FOS ORI A 'i'tY . SAN R AMON. CALIFORNI A 94583 .(415) 837-4248 i

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F-4 United States Nuclear Regulatory Commission Region V, Suite 202 k L's Tp dW Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, California 94596 Attention: Mr. J. L. Crews, Chief Reactor Operations and Nuclear Support Branch

Reference:

Docket No. 50-228, NRC Inspection of Acrotest Research Reactor Facility

Dear Mr. Crews:

This is in response to your letter of October 3, 1979 which discusses an infraction identified during the unannounced NRC inspection of September 5 and 6, 1979. The infraction involves documentation of experiment review and approval.

Although the experiment in question was properly reviewed, we agree that documentation of the approval was not in strict compliance with procedural requirements. Additionally, the RSC meeting minutes did not contain sufficient information regarding the review of the experiment. Ilowever, we believe the intent of our Operating ProceduresSection VII, paragraph B was satisfied by a signed letter of approval by the RSC Chairman acting on behalf of the committee. In retrospect, it is obvious that we should have sent a copy of the "ARRR Experiment Type Review (AETR)", Figure 1 of Procedure VII, Paragraph B, to the RSC Chairman for signature and return to us for proper documentation. Normally, this action would not be necessary as the RSC Chairman would sign for the committee af ter the discussion at the RSC meeting.

Our Technical Specifications require that two of the five member RSC are not employees of Aerotest Operations, Inc. Although this assures outside monitoring of our operation by independent consultants, it does present some logistical problems since the RSC Chairman resides in Sacramento. In this particular -

case the Committee required some further information before final approval and f

7911020 07 A 7-G 1 r % 0 A SUBSIDI ARY OF fh

J. L. Crews U.S. Nuclear Regulatory Comm. 15 October 1979 authorized the Chairman to approve the experiment after receipt of the information provided he found it complete. A copy of the experiment form was sent to the RSC Chairman and the previously mentioned letter of approval was returned to Aerotest.

The subject experiment was signed by the Chairman of the RSC during his visit to Aerotest on October 6,1979, bringing this "non-compliance" item into strict compliance. The administrative procedures for preventing a recurrence of the " violation" have been discussed earlier, i.e. , under normal circumstances the experiment will be signed by the Chairman at the RSC meeting or, should a special situation arise as with the subject experi-ment, we will send the experiment form to the RSC Chairman for approval prior to conducting the experiment. This latter procedure will be used only when

~~ the RSC has approved the experiment subject to minor clarifications as reflected in the minutes of the meeting. We believe this response satisfies all of the requirements of your letter dated October 3,1979. Should you have any questions please call me.

Very truly yours, AER0 TEST OPERATIONS, INC.

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. Newacheck President RLN:be 1258 163