ML19354D888

Responds to NRC 891218 Ltr Re Violations Noted in Insp Rept 50-083/89-04.Corrective Actions:All NRC Required Surveillances Tracked as to Day of Month Performed to Assure Allowable Surveillance Intervals Not Exceeded

ML19354D888
Person / Time
Site:	05000083
Issue date:	01/12/1990
From:	Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9001230165
Download: ML19354D888 (3)

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.M NUCLEAR ENGINEERING SCIENCES DEPARTMENT  !

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January 12, 1990 t Reply to Notice of Violation Inspection Report No. 50-83/89-04 ,

United States Nuclear Regulatory Commission Washington, D.C. 20555 ,

Attnt Document Control Desk

Dear Sir:

This report addresses the violation cited in Inspection Report No. 50-83/

89-04 dated 18 December 1989 which cites the UFIR facility with a Severity Level V violation of NRC requirements as followst.

" Technical Specification 4.0 requires that surveillance tests must be perfonned within the specified f requencien. .

Contrary t.o the. above , a blade drop time check was not performed within alght months (248 calendar daye) after beirs perforued on December 5, 1988, and quarterly scrac checks were not perfore.ed vithtr. four uonths (124 calendar days) after being performed on February 21, 1.969."

The following paragraphs constitute the written utrunt required in respocee to the Notice of Violation and address the five arenr, as rcquestedt

a. Admission or Denial of the Violation [ .

R The statement of violation repeated above 10 adsait ted ,

b. Reasons for the Violation The reason for the violation is administrative due to d interpretation of allowabic surveillnuce intervals per the UFTR teche.ical specific.>-

tiona. The f aci2Aty hes tracked all surveillance requir*J on a quarterly ,

or less of ten interval via a statue board and the f acilii:y's monthly ,

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Reply to Notice of Violation Inspection Report No. 50-83/89-04 i Page 2 report of surveillances completed and due. This tracking is done on a month-to-month basis, rather than on an elapsed time basis. Though not documented, a telephone communication with NRC some years ago had led e f acility management to interpret allowable surveillance intervals to include the entire month at the end of the surveillance interval; that

, is, a quarterly surveillance with an allowable 4 month interval would be acceptable if performed anytime in the fif th month, regardless of " hen in '

the month the surveillance was last performed. Of course, the sur' ail-lance would next be due in the month that would be in the normal 3 month interval to assure performance of the proper number of surveillances over longer periods of time,

c. Corrective Steps Taken/Results Achieved Since the NRC inspection on November 13-16, 1989 disclosed this 1 interpretation of allowable surveillance intervals, all NRC required I surveillances are being tracked as to the day of the month performed to assure that allowable surveillance intervals are not exceeded. All surveillances are currently up to date and subsequent violations of thie type have not occurred. To avoid future violations of allowable surveillance intervals, the tracking on the status board in the control room as well in the monthly teport- is converting to an elapsed-time tracking system, versus a month-to-month tracking system to indicate not only the month but also the day when surveillances are due so that the existing tracking system will assure allowable surveillance intervals are not exceeded.

d. Corrective Steps To Be Taken to Avoid Further Violations No other steps are considered necessary to avoid further violations relative to exceeding allowable surveillance intervals.

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e. Date When Full Compliance Will Be Achieved Full compliance has been achieved as of the November 16, 1989 date of the NRC Inspection exit interview when the inspector indicated that the facility administration interpretation of allowable inspection intervals l was probably incorrect and that a violation was likely to be cited.

The commitment to update the surveillance status board in the control room to indicate the day of the montt as well as the month when a surveillance is due has been implemented as of December 28, 1989.

Finally the commitment to track surveillances by month and day in the monthly report is being implemented with the December,1989 monthly report.which is expected to be completed by mid-January, 1990. Note, l however, that the surveillance tracking portion of the December monthly l

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i NRC Reply to Notice of Violation Inspection Report No. 50-83/89-04 Page 3 report will be completed by January 2, 1990 to assure full and effective ,

c implementation of the lapsed-time tracking system at the UFTR facility.

This early checking of the surveillances will be continued monthly to assure effective implementation of all lapsed-time tracking systems.

We trust this response satisfies the requirements delineated in Inspection Report No. 50-83/89-04. If there are further questions, please advise.

' Sincerely, W

William G. Vernetson Director of Nuclear Facilities WGV/p ect NRC Region 11 Regional Administrator P.M. Whaley J.S. Tulenko Reactor Safety Review Subcommittee (RSRS)

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