ML20044C031
| ML20044C031 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 03/11/1993 |
| From: | Dudziak D, Mayo C, Perez P North Carolina State University, RALEIGH, NC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9303170008 | |
| Download: ML20044C031 (3) | |
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J North Carolina State University I
f Nuclear Reactor Program Department of Nucicar Engineering 11 March 1993 Raleigh, NC r;695 ~909 (91S) 515-2321 FAX (919) 515-5115 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION Docket No. : 50-297 License No, : R-120
Reference:
Letter, Notice of Violation and Notice of Deviation (NRC Inspection Report No. 50-297/93-01)
Dear Sirs:
Pursuant to the provisions of 10CFR 2.201, North Carolina State University is hereby submitting a reply to the reference notice of violation and notice of deviation. The attached response addresses the reasons for the violation and deviation, and the corrective steps that have been or will be taken to avoid further violations or deviations.
Should you have any questions concerning this reply, please contact us.
Sincerely yours, b]JL:> b (
Pedro B. Perez, Associate Director 16035' Nuclear Reactor Program C k,. M d '!
go j-Charles, W. Mayo, Ph.D.
. Donald J. Dudziak, Ph.D.
Director, Nuclear Reactor Program -
Head, Department of Nuclear Engineering copy w/ attachment:
1.
USNRC, Region II, Regional Administrator 2.
Dr. Frederick J. Fuller, Chairman, Radiation Protection Council
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3.
Dr. James A. Mullholland, Chairman, Reactor Safeguards Advisory Group i
4.
Mr. William Morgan,' Radiation Protection Officer f./
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9303170008 930311 '
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.hs g and a constituent institution of Tine Unitwrsity of North Carolina.~
4 REPLY TO A NOTICE OF VIOLATION AND NOTICE OF DEVIATION I
NRC INSPECTION REPORT No. 50-297/93-01 i
t NORTH CAROLINA STATE UNIVERSITY.
PULSTAR Reactor - License No. R-120 VIOLATION: Severity Level IV Technical Specification Section 6.2 requires that a Reactor Safeguards Advisory Group-i (RSAG) be formed to provide independent appraisals of reactor operations. Section 6.2.7 requires that the RSAG ' meet at least every six calendar months and upon the call of the Chairman of the Radiation Protection Council.
Contrary to the above, a review of the minutes of the meetings held by the RSAG during 1992, indicates that the RSAG met on February 26 and October 28, a time interval exceeding eight months.
RESPONSE TO VIOLATION:
The licensee acknowledges the violation and offers the following reason for the violation and corrective actions to avoid further violations.
The PULSTAR facility records show that this violation has previously occurred in 1982 (NRC Inspection Report No. 50-297/82-01) and 1988 (NRC Inspection Report No. 50-i 297/88-03). The current violation is a result of our failure to perform corrective actions previously implemented. Specifically, the reply to the 1988 violation established that thel RSAG meeting will be scheduled by the Manager of Nuclear Operations. The Manager of Nucle.ar Operations during that time performed the ' corrective function until his retirement in December 1990. It appears that during the turn-over of responsibility, the new Manager--
of Nuclear Operations was not made aware of his duty to schedule RSAG meetings.-
The current Manager of Nuclear Operations has been made aware of the corrective action -
previously implemented. A new PULSTAR Smveillance requirement has been established.
and incorporated into the existing PULSTAR Surveillance System. The new surveillance..
requirement, PS-7-07-1:S1; RSAG Meeting, will prompt the Manager of Nuclear Operations -
in March and in September to schedule an RSAG meeting through the RSAG Secretary for.
s April and October, respectively.
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REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION NCSU PUISTAR Reactor '
NRC Irfspection Report No. 50-297/93-01 Facility License R-120 Docket No.50-297 DEVIATION:
In a response, dated August 27,1992, to a Notice of Violation, the licensee committed to send a revised copy of its Emergency Plan to the Radiation Protection Council by.
September 1,1992, for review and approval.
Contrary to the above, the revised Emergency Plan was not submitted to the Radiation Protection Council (RPC) until October 1,1992. The RPC did not review the revised Emergency Plan until November 1992 and the action taken was to refer the document to the Reactor Safeguards Advisory Group (RSAG) for review and approval. As of January 29,1993, the RSAG had not met to formally review and approve the revised Emergency _
Plan.
RESPONSE TO THE DEVIATION:
The licensee acknowledges the deviation and offers the following reason for the deviation and corrective actions to avoid further deviations.
The response to the notice of violation made a commitment to revise the Plan as a result -
of the inspection. The revision was simple and September 1,1992 appeared to be an adequate deadline. However, the PULSTAR Reactor Emergency Plan was being reviewed simultaneously by both NCSU and off-site response organizations following the emergency.
drill of August 1992. Officials from the City of Raleigh, Wake County, and the State of North Carolina were given the opportt.nity to critique the Plan following the emergency-drill.
The licensee's Associate Director for the Nuclear Reactor Program decided to submit to the RPC a single revision of the Plan containing the combined changes from the review comments of the NCSU and off-site response organizations and the committed changes in response to the NRC inspection. Unfortunately, coordinating the review process with the
- off-site organizations became a lengthy process and the original commitment deadline was missed. The Associate Director did not notice the deviation due to other commitments with the State and/or County in support of the Plan review effort. As a_ result, the Associate Director failed to request from the NRC an extension.
The plan has been reviewed by the RSAG. and voted for approval pending two.small' grammatical changes. - The Associate Director will make the corrections and return the--
updated Einergency Plan to the RSAG Chairman by March 18, 1993.
- The deviation was a result of a simple scheduling conflict. The Associate Director is fully ~
aware of how this developed and has not previously missed any licensing commitment made to the NRC. There is no reason to believe that others will occur. As a result, no corrective action seems warranted.
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