ML20005E129

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-326/89-02.Requests That Response to Item C.2 of Notice of Violation Re Failure to Conduct Annual Operating Test Be Revised

ML20005E129
Person / Time
Site:	University of California - Irvine
Issue date:	12/22/1989
From:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Tien C CALIFORNIA, UNIV. OF, IRVINE, CA
References
NUDOCS 9001030341
Download: ML20005E129 (2)

See also: IR 05000326/1989002

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DEC 2 2 %9

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Docket No. 50-326

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. University of California

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Irvine, California 92717

Attention:

Executive Vice Chancellor

.-Chang-Lin Tien

Gentlemen:

SUBJECT: .UC IRVINE REPLY TO NOTICE OF VIOLATION

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Thank you for your letter dated October 25, 1989, in response to our Notice of

Violation and Inspection Report No. 50-326/89-02, dated September 27, 1989,

informing us of the steps you have taken to correct the items which we brought

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to your attention.

The Notice of Violation issued to you contained a citation in section C.2 for

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failure.to conduct an annual operating test.

In reply to this citation you

commented that the reactor supervisor and other reactor operators are in close

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collaborationregardingoperation,schedulinftenunderdirectassessment, maintenance

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operational issues and hence operators are o

but

to implement a diary of reactor o)erator meetings, discussions, pos

' documentation of the contact is weak or non-existent.

Your pro

and

observations of performance.- Eac1 operator will share responsibilities for

entries, although it will be the Supervisor's responsibility for opkeep of the

diary.

The NRC does not consider your reply to meet the intent of the requirement for

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an annual operating test. However, a diary system similar to that proposed by

you could meet this requirement if properly applied.

Following is an example

of an acceptable approach.

At the beginning of each requalification cycle, the Reactor Supervisor

must conduct an annual review of the training areas he intends to cover

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with each operator.

The review must ensure the training the Reactor

Supervisor intends to administer includes weaknesses noted during the

previous cycle for that operator, as well as a comprehensive sampling of

the applicable items listed in 10 CFR 55.45(a)(1) through (13).

A diary

methodology used for documenting these evaluations could be implemented,

as long as the performance of the items are observed by the reactor

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supervisor.

At the end of the cycle, a review should be conducted to

ensure the areas intended to be covered in training, particularly the

applicable 10 CFR 55.45(a) items, were indeed performed.

If the

prescribed areas were not covered, there should be a mechanism for

conducting a final evaluation to cover those missing topic areas.

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We request that you amend your response to item C.2 of the Notice of Violation

to commit to the above stated position for administering operating tests or

provide equivalent methods to assure the adequate administration of annual

o>erating tests.

Your reply should be submitted within 30 days of the date of

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t11s letter.

ONffnd GOTVd

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Ross A, 'Scarano Director

DivisionofRadIationSafetyand

Safeguards

cc w/ copy of letter dated 10/25/89:

Dr. George E. Miller, Reactor Supervisor

Department of Chemistry

UniversityofCalifornia}Irvine

Irvine, California 9271

bec w/ copy of letter dated 10/25/89:

docket file

State of California

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October 25th,1989

U.S. Nuclear Regulatory Commission, Region V,

1150 Maria Lane, Suite 210,

Walnut Creek, CA 94596

Attention: Director Ross A. Scarano

Docket 50-326

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License R 116

Re:

B@iv to n Notice of Vinlatinn dated Sentember 27th.1999

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Gentlemen:

With respect to the referenced Notice of Violation we respond as follows:

Item A. " Reactor operations continued even though none of the Operator Monthly Maintenance

checklists had been reviewed for the period August through December 1988."

(1) Comment:

As noted in remarks to the inspector this was an oversight on the part of the Reactor Supenisor

and Assistant Reactor Supervisor, even though all maintenance items had been completed on

schedule, and such a report made orally to the administrative staff.

(2)Conective steps:

The reactor daily start up checklist has been modified to mque reactor operators to verify the

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completion and sign off of appropriate checklists prior to any daily operation. This has been

implemented.

(3)Funher action:

Futme operator training and trqualification discussions will include reference to the importance

of sign-off on documentation and additional review of necessary conditions for continued

operation. The staff, and the Reactor Operations Committee will study possible revision of the

Operating Procedures so that single myiew may be all that is needed to assure compliance.

(4) Full Compliance:

Compliance with existing procedures is considered to have been accomplished.

Item II. "The Reactor Operations Committee failed to meet during the period August 19,1988, to

January 30,1989."

(1) Comment:

This item was reported to NRC by letter dated May 5th,1989. The reasons and the corrective

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action were described in the letter. A copy is attached for your infonnation.

(2) Corrective steps:

The steps taken are described in the attached letter.

(3)Funher action:

No further action is planned, except for consideration being given to requesting an amendment to

this Technical Specification item to reduce the frequency of required meetings.

(4) Full Compliance:

Compliance with existing requirements is considered to have been accomplished.

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Docket 50-326

Page1

10/25/89

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Item C.a. " Contrary to the above requirement the licensee did not document additional training

requalification examination." perator who scored less than 80% on two sec

provided to a senior reactor o

(1) Comment:

In his detailed repen on this item (Inspection Report, page 7, line 20), the inspector noted: "The

Reactor Supen'isor stated that the two sections of the examination were discussed with the SRO

as compensatory training. " This fact was documented by a note made on the front cover of the

senior operator's examination script maintained in the files as " Reviewed with PJR". The

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' operator's initials are PJR. At the time this was felt to be both sufficient training and

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documentation.

(2) Corrective steps:

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This issue has been noted by the Reactor Supervisor, who acts as the training and requalification

director. Future records will be made clearer.

(3)Further action:

None contemplated.

(4) Full Compliance:

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This issue did not arise with the 1989 requalification, where all scores were satisfactory. The

difference may have been because of a deliberate effort to make the examination even more

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" performance based".

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Item C b. " Contrary to the above requirement the Reactor Supervisor did not conduct an operating

test for evaluating operators or senior operators during the period of 1988 and 1989 to the date of

the inspection."

(1) Comment:

At this facility there have only been two licensed senior operators and one licensed operator

during the penod since 1987. One of the senior operators is the Reactor Supervisor, and the

other acts as Assistant Reactor Supervisor. All three individuals are in close collaboration

regarding operation, scheduling, maintenance, safety and all operational issues. Thus the other

operators are often under direct assessment by the Reactor Supervisor and there has never been

any question of their competence to operate the reactor safely. However, documentation of this

contact is weak or non existent.

(2) Corrective steps:

None taken at this time.

(3) Future Actions:

The Reactor Supervisor as training coordinator will implement a diary of reactor operator

meetings, discussions, and observations of performance for each licensed individual.

Each operator will share responsibility for entries, although it will clearly be the Supervisor's

responsibility for tne upkeep of this diary. This log should provide the necessary documentation

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for ongoing requalification. In addition, the Reactor Operations Committee will discuss the

possibility of applying for a license amendment to obtam permission for a more flexible

requalification program better suited to the needs of our facility than that imposed by NRC in

1974.

-(4)Fu!! Compliance:

The diary system should be fully implemented by the end of this year (December 31st,1989).

We hope this will satisfy full comphance as facility and department resources do not permit

arovision of additional full coursework for operators. Changes in the program will take much

onger to be drafted and approved.

Docket 50-326

Page 2

10/25/89

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Additional Item:

Your notice of transmittal asks for comments on "the level of management attention necessary to

assure continued safe operations". We are pleased that you agree that such matters "do not represent a

significant safety concem at this time". We comment as follows:

The Chemistry Department and the School of Physical Sciences are currently reviewing the staffing

situation at the facility. There had been a plan to combine a position of reactor operator and reactor

health physicist, with other chemistry departmental duties, mto a full time staff position. The

individual in mind for this position is no longer available. Whether to pursue this or some other model

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ofimproving paid staffing at the facility is currently under review.

In the meantime, the Reactor Supervisor has made a commitment to assign additional hours of his

time to facility management and operations. He and the Assistant Reactor Supervisor are discussing

teassignment of certain tasks between them to provide more assurance of timely documentation.

It is anticipated that plans will be firm by January,1990. Meanwhile, the facility will continue to be

operated safely under existing arrangements, but with closer attemion to details of documentation,

which appear to be the major issue for concern. Review by outside individuals fmm E,II&S will also

wy closer attention to details of documentation. They will be assisted in this task by newly created

.. adit checklists.

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Sincerely,

R'

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Chang

.ia Tien,

Executi e Vice-Chancellor

cc: H.W. Moore, Dean, Physical Sciences

M.C. Caserio, Chair, Chemistry

V.P. Guinn, Chair, Reactor Operations Committee

F.S. Rowland, Reactor Administrator

G.E. Miller, Reactor Supervisor

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Docket 50-326

Page 3

10/25/89

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UNIVERSITY OF CALIFORNIA, IRVINE

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etnKatty e Davis e say:NE e LOS ANCELES e RIVER &lDE e SAN DIECO e SAN FRANC SCO

SANTA BARBARA e SANTA CRUZ

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DEMRTMEKr oF O!EM!sTRY

IRv!NE. CAL.!FoRNIA 92717

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NUCLEAR REACTOR rACILITY

SUPERVISOR: DR. o.E. MILL.ER

hiay 5th,1989

TEL:(714) 856-6649 oR 714 856 6082

U.S. Nuclear Regulatory Commission,

Region V,

Docket:55 326

1450 hiaria Lane, Suite 210,

Licensee report of violation.

Walnut Creek, CA 94596

Gentlemen:

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I have to inform you that the Reactor Operations Committee (ROC) for the UCI Nuclear Reactor

Facility failed to meet in the period August 18th,1988 to January 31st,1989,in violation of the

requirements in the Technical Specifications that the Committee shall meet at least quarterly.

Thus the fall quarter was missed. In 1988 there were three regular meetings (February 18th, hiay

20th,and August 18th).In addition there were special meetings of staff before, on, and after hiny

2hd, when an emergency exercise was conducted, and on January 31st,1989 for a complete

rdew of the Emergency Plan.

The reasons were:

(a) routine operations were discontinued between December 13th and January 18th because of a

combination of staff reduction, staff illness, and the need to carry out additional maintenance at a

time when maintenance staff extemal to the facility were unavailable. A December meeting that had

been scheduled was thus postponed.

(b) difficulties with the unavailability of secretarial assistance.

These problems have been resolved.Special maintenance has now been completed and routine

maintenance conducted on schedule. The Reactor Supervisor now has a new secretarial assistant

who will be able to deal with reactor paperwork once her training period on other department

matters is complete. Committee meetings have been held on schedule - January 31st, hiarch 14th,

and planned for hiny lith,1989 to teview operations, emergency response plans and

maintenance.

It is important to emphasize that continual surveillance on behalf of the ROC has been maintained

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by the personnel of the Office of Environmental Health and Safety, who have reviewed both

performance and records at the facility involving not only safety matters, but also operations and

general maintenance. The results of their reviews have been given to the Reactor Supervisor on a

number of occasions and resulted in small corrective actions. The Committee is satisfied that the

facility has continued to operate with proper regard for the health and safety of the public in spite of

the absence of a formal meeting, and no hazarc has resulted, nor has the likelihood of hazard been

increased.

Sincerely,

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George E. hiiller

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Reactor Supervisor

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cc: Reactor Operations Committee members

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