ML20044G280
| ML20044G280 | |
| Person / Time | |
|---|---|
| Site: | University of Buffalo |
| Issue date: | 05/26/1993 |
| From: | Landi D NEW YORK, STATE UNIV. OF, BUFFALO, NY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306020265 | |
| Download: ML20044G280 (4) | |
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w UMVERSITY AT BUFFALO m g !!y; n % M STATE UNIVERSITY OF NEW YORK 516g'ga Buffalcit New Ymk 142eo1611 F16)6453321 TAX F16)6452933 May 26, 1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C..
20555 Re:
Reply to Notice of Violation Docket 50-57 License R-77 Buf f alo Materiale Research Center (BMRC)
Dear Sir / Madam:
This letter is in response to the Notice of Violation dated April 28, 1993.
violations A.
Failuro of the Iacility Operating Committee to conduct annual reviews of the Emergency Plan and Emergency Procedures.
B.
Failure to conduct required action drills.
The inspection report is not accurate in stating that only one action drill was conducted in period 1989 through 1992.
Two action drills were conducted, one in October of 1989 and one in May of 1992.
The inspector did not review the 1989 drill which included participation by the VA Medical Center, Buffalo Office of the FBI, ambulance services, as well as the Buffalo and Erie County emergency service agencies.
Reasons for the Violations A.
Emercency Plan.nd Emercency Procedures Reviews:
During the subject period, the Emergency Plan and Emergency Procedures were j
reviewed by che Director of BMRC, Mr. Louis G. Henry.
It was his conclusion that:
1.
The existing Emergency Plan and Emergency Procedures were adequate to meet.the requirements of 10 CFR 50; however:
a.
It would be advantageous to improve both the Plan and Procedures based upon lessons learned in previous drills, as well as to create a better interface with local off-site emergency support agencies.
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1 b.
The most effective way to accomplish the improvements was by preparing entirely new emergency plan and emergency procedure documents.
j c.
It was not_necessary to modify the existing Plans and Procedures while the new, replacement documents were prepared and reviewed.
Based upon these conclusions, the Director began preparation of new plan and procedures documents.
Work l
in progress was reviewed in the course of the inspection.
B.
Action Drills:
Action drills were not conducted for several reasons:
i 1.
During 1990 and 1991 the reactor was dismantled and a new pool liner was installed.
This placed extraordinary demands "oon the reactor staff including:
a.
Dismantlement of all in-tank components.
b.
Design, fabrication, and installation of hot cell fuel storage tank.
j c.
Transfer to the reactor core out of the hot cell.
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d.
Supervision of numerous outside contractors.
e.
Contamination control and ALARA for all phases of 4
the repair.
f.
Assurance of welding and fabrication quality.
g.
Continuance of materials testing and isotope processing operations.
2.
The canter staff was reduced.
During the subject peri 1,
J Senior Health Physicist / Emergency Planning Offic
?O) became vacant.
This position was filled 3
by proacting a less experienced Health Physicist.
The cperating Committee concluded that this individual faced significant challenge in the area of Health l
Physics.
Based upon this assessment, and his relative inexperience in emergency planning, coincident appointment as EPO was not appropriate.
The Reactor Operations Manager and Director positions also became vacant.
The Assistant Reactor Operations Manager was promoted to Operations Manager.
The j
positions of Director and Assistant Operations Manager j
remained vacant.
The General Manager of Buffalo
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Materials Research, Sc. (the University's contractor for operation of Bhad), therefore, also functioned as I
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Director and Emergency Planning Officer for BMRC.
3.
With the reactor core in storage in the hot cell, there was a dramatic reduction in the core fission product inventory, and the primary accidents as analyzed in the BMRC Safety Analysis (loss of coolant, loss of flow, design basis [ criticality] accident), were no longer c:
credible.
Corrective Steps Taken and Results Achieved A.
Plan Reviews The Director of BMRC is continuing to work on the new plan and procedures.
A working draft of the new plan was forwarded to the Erie County Department of Emergency Services in February.
An Emergency Drill will be conducted on May 20, 1993.
The University's Environmental Health and Safety Department has participated in the planning of this drill and thc University's Radiation Safety Officer will serve as the drill's-Emergency Director.
The Operating Committee, having reviewed the results of the May exercise, will determine if any immediate changes in the plan or procedures are required.
They will then begin review and editing of the new plan and procedures.
B.
Action Drills An action drill was conducted in 1992, and the May drill will meet the 1993 requirements.
The 1992 exercise was conducted prior to the resumption of reactor operations and within the scope of the special operator training plan.
The 1993 exercise has been designed to nas mize the training benefit to less experienced personnel at BMRC.
The exercise will be conducted during the day; however, the scenario will be a night-time accident and the center will be staffed by back shift personnel.
Several " trainers" from the BMRC, the University's Environmental Health and Safety Department, and Buffalo Fire Department staffs will work with the drill participants.
Staffina Recruiting has begun to provide a full-time Director of BMRC.
This should significantly reduce the workload of the General Manager of BMRI.
A written plan to recruit the Director has been provided to the NRC (copy enclosed).
As BMRC is able to rebuild its' external support base, additional personnel will be added to the' reactor Operations group, further reducing the workload of the BMRI Operations Manager.
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e Corrective Steps to Avoid Further Violations Steps which will be taken to avoid further violations include:
t Increased staffing of the BMRC by filling the position of Director.
j Re-evaluation of the charter, role, and reporting relationships of the Nuclear Safety Committee.
Audits by the University's Radiation Safety Officer, who will provide written reports to the Vice President for Research.
r f
Active participation in Emergency Preparedness activiti<es by the University's Department of Environmental Health and Safety Department.
Date When Full Compliance Will De Achieved Critique of the May 20 drill and review of the existing plan and procedures, by the Operating Committee, will be completed by June 30, 1993.
The University is confident that the steps outlined above, including strengthened oversight of BMRC operations, will ensure future compliance with NRC regulatory requirements.
We hope that this reply adequately addresses the concerns of the Commission.
Sincerely,
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a Dale M.
Landi Vice President for Research DML 629 Encl.
cc:
Regional Administrator, Region I President William R. Greiner Provost Aaron N. Bloch l
Sr. Vice President Robert J. Wagner Y. Henkin, President HEA, Inc.
M.
Pierro, Radiation Safety Officer l
R. Nayler, University Services A.
Dahlman, Environmental Health and Safety H. Spector, Chairman NSC L. Henry, General Manager, BMRI I
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??R 2 g 1993 Docket No. 50-57 Dr. D. M.12ndi RECEIVED Vice President for Research State University of New York at Buffalo MAY 0 b 1993 Capen Hall Amherst, New York 14260 W est ce hurwaext:n CAUi n e
Dear Dr. Landi:
Subject:
Inspection No. 50-57/93-01 An announced inspection of your emergency preparedness and operator qualification programs ws conducted on March 3-5,1993, by Mr. Thomas Dragoun of this office, of activities authorized by NRC License No. R-77. Discussions of our findings were held by Mr. Dragoun with Mr. Louis Henry on March 5. Subsequently, the inspection was continued on March 17,1993, with a supplemental exit meeting that included discussion of
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potential programmatic concerns identified during Mr. Dragoun's March 3-5 inspection.
That discussion was held with you and others involved with operation of the reactor by Dr.
Seymour Weiss, Mr. James Joyner, and me. The inspection was concluded in the NRC Region I office on April 2,1993, upon review of Mr. Henry's submittal dated March 29, 1993, relative to the current status of your resolution of the allegation of an inattentive reactor operator.
Areas reviewed during Mr. Dragoun's inspection included the status of previously identified items, implementation of the Emergency Plan, availability of emergency equipment and off-site suppon, emergency drills, and reactor operating training. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel and observations by the inspector. Issues discussed at the supplemental exit meeting on March 17,1993, related to the potential impact on safe operation caused by an NRC-perceived decrease in the level of oversight of the reactc.r program by licensee management, as well as to concerns resulting from the current occreased I
level of staffing and funding of the reactor facility. The information provided at the supplemental exit meeting produced a better understanding of the oversight of reactor operations provided by the Nuclear Safety Committee, the relationship between the University and the Buffalo Materials Research, Inc. (your contractor responsible for the day-to-day operation of the reactor), the current level of staffing at the reactor, and the status of funding. The staffing and funding concerns were not considered by the NRC to have a current effect on the safety of operations. However, they are indicators of a developing problem that, if continued, could have a negative effect on operations. We found your assurances that the University will soon address te latter issues as providing a higher level Q 9,(
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2 Buffalo of confidence that safe operations will continue. A summary of our discussions, including
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the commitments made during both the meeting and your March 19 telephone discussion with me, is included in Section 7.0 of the enclosed report.
Based on the results of this inspection, certain of your activities were found to be in violation of requirements specified in your NRC-approved Emergency Plan, as specified in the enclosed Notice of Violation (Notice). The violations are of concern since they indicate that, during much of the period the reactor was shut down for repairs to the reactor tank liner, inadequate resources and/or oversight were allocated to the emergency preparedness program.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96.511.
Your cooperation with us is appreciated.
Sincerely, 7)?& >
Richard W. Cooper, II, Director Division of Radiation Safety and Safeguards l
Enclosures:
1.
NRC Region I Inspection Report No. 50-57/93-01 i
State University of New York -
3 2 8 7993 i
Buffalo cc w/encls:
L. G. Henry, Director M. A. Pierro, Radiation Safety Officer Dr. William Vernetson, TRTR K. Abraham, PAO (2)
Public Document Room (PDR) i 1.ocal Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
State of New York i
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NOTICE OF VIOLATION State University of New York at Buffalo Docket No. 50-57 Buffalo Materials Research Center -
License No. R-77 During an NRC inspection conducted on March 3-5,1993, violations of NRC requirements 3
were identified. In accordance with the " General Statement of Policy and Procedure for l
NRC Enfercement Actions," 10 CFR Part 2, Appeadix C, the violations are listed below.
A.
Emergency Plan Section 2 requires an annual review of the Emergency Plan and Emergency Procedures by the Facility Operating Committee.
Contrary to the above, no reviews of the Emergency Plan and Emergency Procedures were conducted by the Facility Operating Committee for the period 1989 through 1992.
B.
Emergency Plan Section 14 requires three emergency drills each year, including two i
evacuation drills and one action drill.
Contrary to the above, the licensee had conducted only one of the required action drills in the period 1989 through 1992.
These are Severity Level V violations (Supplement VIII).
Pursuant to the provisions of 10 CFR 2.201, the State University of New York at Buffalo is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: -(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is showm, consideration will be given to extending the response time.
D. Al at King of Pmsda, Pennsylvania this j day of April,1993
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U. S. NUCLEAR REGULATORY COhmHSSION REGION I Report No.: 50-57/93-01 Docket No.: 50-57 i
License No.: B-22 Licensee:
State University of New York at Buffalo Rotary Road. South Campus Buffalo. New York Facility Name:
Buffalo Materials Research Center Inspection At:
Buffalo. New York Inspection Conducted:
Maith 3-5.17. and Anril 2.1993 i
/QkJ Inspector:
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Thomas Dagoun, Proje/c Scientist, Effluents date Radiation Protection Section (ERPS), Facilides Radiological Safety and Safeguards Branch (FRSSB)
Approved By:
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Robert f/ Bores, Chief, ERPS, FRSSB, date Division of Radiation Safety and Safeguards Areas Reviewed: Implementation of the Emergency Plan, conduct of the annual emergency drills, and reactor operator trainmg.
Results: Emergency preparedness at the facility was determined to be adequate. As the result of potential programmatic issues identified by the inspector, a supplementd exit meeting was held between licensee and NRC managers on March 17, 1993. The information provided at the supplemental exit meeting resulted in a better understanding about the oversight of reactor operations provided by the Nuclear Safety Committee, the relationship between the University and the Buffalo Materials Research, Inc. (the licensee's contractor responsible for the day-to-day operation of the reactor), the current decreased level of
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g 2-staffing at the reactor and the status of funding. Assurances were providal by licensee t
management that the University will soon address the staffalg and funding issues. Neither of the latter isst.cs was considered by the NRC to have a current effect on the safety of operations.
During much of the period that the reactor was shut down for repairs to the reactor tank liner, the licensee failed to conduct certain required annual emergency drills and failed to' conduct specified annual reviews of the Emergency Plan and the Emergency Procedures.
These were identified as violations.
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i DETAILS i
i 1.0 Persons Contacted 1.1 Licensee Personnel M. Adams, BMRC Operations Manager
- A. Dolman, Acting Director, Environmental Health & Sr.fety (SUNY) o* L. Henry, BMRC General Manager and Acting Director
- D. Landi, Vice President for Research (SUNY)
R. Linde, Lt., University Public Safety (SUNY)
- R. Nayler, Associate Vice President, Facilities (SUNY)
- M. Pierro, Radiation Safety Officer (SUNY)
J. Slawson, BMRC Health Physics Supervisor 1.2 NRC Personnel
- R. Cooper, Director, Division of Radiation Safety and Safeguards, Region 1
- J. Joyner, Chief, Facilities Radiation Safety and Safeguards Branch, Region 1
- S. Weiss, Director, Non-Power Reactors and Decomm. Project Directorate, NRC-HQ o Attended the exit interview on March 5,1993. Other personnel were contacted or interviewed during the inspection.
- Attended the management meeting on March 17, 1993.
2.0 Purpose of Inspection The inspection was conducted to review the status of r.afety of operations at the facility, with emphasis on the status of licensee implementation of and compliance with the NRC-approved Emergency Plan. The facility licensed by the NRC includes a PULSTAR authorized to operate at power levels up to 2 megawatts..The State University of New York at Buffalo (SUNY Buffalo or SUNY) is the licensee, but day--to <iay operation of the reactor facility is performed by a mix of licensee and contractor personnel. The Buffalo Materials Research, Inc. is the contractor (also see Sectica 7.4), and employs most of the staff _who operate the facility, known as the Buffalo Materials Research Center (BMRC). Three of the NRC-licensed reactor operators are employed by SUNY Buffalo, the remainder of the staff (comprised of both licensed and non-licensed personnel) by the contractor.
3.0 Status of Previousiv Identified Items 3.1 (Closed) Unresolved Item (50-57/92-02-01I: Licensee to evaluate unanticipated opening of containment isolation dampers caused by a power transient. The manual " scram" push button for the dampers was replaced by a
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4 oneff toggle switch and the circuit rewired to prevent a bypass by contacts on the damper controller. The changes were reviewed and approved in accordance with requirements specified in 10 CFR 50.59. This matter is resolved.
3.2 (Closed) Followun Item (5457/92-02-02h Evaluate cause of sticking control rods during core reload. Evaluate performance of control rod drives with full core in place and at normal operating pool temperatures. A partial draft report was available during the inspection. On March 12, the licensee submitted a report that analyzed the rcot cause and safety significance of the problem.
The report was found to be satisfactory. This matter is closed.
3.3 (Onen) Inattentive Operator: On November 6,1992, the licensee reported to the NRC that a reactor operator was alleged to have been observed inattentive (sleeping) at the control console. The operator denied the allegation. The operator was relieved of duties and assigned to non-licensed activities pending the outcome of an investigation by the BMRC General Manager and the SUNY Personnel Office. At the time of the inspection, the licensee had not yet completed a review and resolution of the incident.
Although the event was reported about four months ago, there was no estimate of the time needed to reach a conclusion. This matter remains open (50-57/93-01-01).
4,0 Emervency Preoaredness Research reactor licensees are required by 10 CFR 50.34(b) to have and maintain an NRC-approved Emergency Plan (EPlan). The current version of the Buffalo Materials Research Center (BMRC) Emergency Plan is dated November 1988. The inspector reviewed the implementation of selected portions of this plan.
Section 2 of the EPlan requires an annual review of the EPlan and the implementing emergency procedures by the Facility Operating Committee, which is a subgroup of the Nuclear Safety Committee. This review is designed to satisfy the provisions of 10 CFR 50, Appendix E.IV.G, which stipulates that the Eplan and procedures be kept up to date. However, for the years of 1989,1990,1991, and 1992, the BMRC General Manager acknowledged that these reviews were not done. This failure constitutes a violation of the requirements of the EPlan (50-57/93-01-02). The BMRC General Manager showed the inspector a draft revised EPlan that contained several major revisions (described by the licensee as improvements) but no date was projected for final issuance.
Section 3 of the EPlan delineates the emergency organization and support to be provided by other organizations. The inspector noted that the Bh0tC General Manager is designated as the prime Emergency Director who will supervise
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emergency response. He also serves as the Emergency Planmng Officer, responsible for details of the Eplan such as maintaining equipment and updating procedures. He also has been filling the role of Facility Director for a few years. The need for one individual to fill multiple responsible positions indicates some understaffing. The inspector was advised by the BMRC General Manager that he has frequent contact with the campus, city and county emergency personnel to ensure the support described in the EPlan. A tour of the University Public Safety Dispatch facility confirmed the ability to notify key personnel and support organizations at any time.
Section 4 of the EPlan provides basic guidelines for emergency action. The inspector posed an accident scenario to two staff Health Physicists as an exercise. Although the basic responses were satisfactory, the HPs appeared unfamiliar with the credible accidents described in the facility's Safety Analysis Report (SAR). The licensee stated that the HP staff would be trained to recognize SAR accidents. This matter will be reviewed in a future inspectica (50-57/93-01-03). All initial evacuations of the reactor building will be to the emergency support center located in the Clark Gym. The inspector toured this facility and verified that the equipment in storage was inventoried and operationally checked semiannually as required by Sectica 9.4 of the EPlan. The inventories were completed by HP personnel, but there was no procedure assigning this responsibility or establishing a formal schedule. The licensee stated that this assignmen+ would be incorporated into the emergency procedures.
Section 14 of the EPlan specifies that two evacuation drills and one action drill be conducted each year. For the period 1989 through 1992, the licensee had conducted only one of the required action drills, that in March 1992. Failure to conduct the required drills is a violation of the EPlan (50-57/93-01-04). During much of this period, the facility was shut down to repair leaks in the pool liner. However, the reactor core was in storage on site. Records of the March 1992 drill indicated that the drill was well planned and executed with several lessons learned and incorporated into a draft revision to the EPlan.
5.0 Reactor Ooerator Trainine The licensee completed a two-plus year outage for reactor tank repairs early in 1992 and reloaded the core in June 1992. In October 1992, the NRC conducted initial and requalification examinations at the facility. The inspector reviewed the available records and attempted to verify performance of console manipulations by selected operators through a xview of records. No individual files are maintained for each operator to document manipulations, however, entries were made in the console operating log. No problems were noted during a spot check of the log. To determine the amount of training provided, the inspector interviewed selected operators and reviewed their class notes. No major omissions were noted, The inspxtor concluded that required opemtor training and performance of required console manipulations were conducted.
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6.0 Exit Interview The inspector met with the BMRC General Manager on March f,1993 and summanzed the scope and findings of this inspection.
l 7.0 Suonlemental Exit Meetine On March 17,1993, representatives of NRC and licensee management (as denoted in Section 1.0) met to discuss the inspector's findings, observations, and perceptions related to safe operation of the facility. The agenua for the meeting is Attachment A to this repon.
7.1 Procram Oversicht The licensee's Technical Specifications require that the Nucicar Safety Committee (NSC) meet twice per year. The BMRC General Manager explained that, during the reactor tank repairs, the NSC met much more often than required (four times in the past year), to review and discuss the repair activities and that, as needed to support the repair activities, consultants wem hired to provide specific expertise. In addition, the NSC reviewed the sticking control rod problem. He further noted that only once in about the past five years had the NSC not been able to meet for lack of a quorum. He also described the function of the Operating Committee (OC), a subgroup of the NSC consisting, among others, of the BMRC General Manager, the University's Radiation Safety Officer (RSO), and the BMRC Operations Manager. The latter three individuals act on routine matters related to facility operation for the OC, and pass on issues for consideration of the full OC or the full NSC as deemed necessary. Minutes of meetings of each of these three groups are maintained. The licensee acknowledged that some changes to the process of selecting the NSC are being considered, since the members are selected by the BMRC General Manager, and the NSC currently reports to the BMRC General Manager.
The involvement of the NSC in the sticking control rod issue (Section 3.2) and in the alleged inattentive reactor opemtor (Section 3.3) was described by the BMRC General Manager as aggmssive and very timely. The NRC '
acknowledged that the licensee had provided prompt notification of both issues, prompt action from a safety perspective, and periodic updates upon request. Wnile more comprehensive reports were not required by NRC regulations for these events, the NRC believed that the licensee had committed to provide them. The BMRC General Manager explained that final reports had not been provided to the NRC sooner in either case, partly because the licensee did not understand the NRC's expectations relative to the submission of the reports. For the control rod drive, other priorities prevented the BMRC m
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General Manager from completing a comprehensive report. A report provided to the NRC on March 12,1993, after a special request from NRC, was
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considered to have acceptably addressed the issue, but the BMRC General Manager noted that he plans to complete, and provide to NRC, a more complete report. No commitment was provided as to the date of submission of this more comprehensive report.
Relative to the alleged inattentive operator, the requirements of the collective bargaining agreement have resulted in protracted resolution of the matter. The licensee assured the NRC thzt potential generic causes of the alleged inattentiveness had been considered (such as extensive overtime by the operators, or frequent shift changes that could interfere with sleep patterns),
and that a broad problem had been ruled out. The inattentive operator was discussed at a special NSC meeting. The licensee was asked to provide to NRC a schedule for furnishing the final report on the inattentive operator and addressing the generic issue of inattentiveness among the operators. The licensee agreed to provide the information requested by the end of March 1993.
The BMRC General Manager, in a letter dated March 29,1993, provided the status of resolution of the matter, but the letter did not address the licensee's review of the generic i.csue described above. On April 22,1993, the licensee was asked to supplement its response. The licensee committed to provide this information by the end of April,1993.
7.2 Health Physics The licensee addressed the NRC's perceived concern that coere was insufficient involvement in the reactor facility's health physics program by the University's Radiation Safety Officer (RSO). The BMRC Ganeral Manager described the staff turnover experienced early in the reactor tank liner repairs, but noted that outside expertise with reactor outage experience had been brought in to assist the facility health physics (HP) staff. In addition, a Certified Health Physicist had reviewed the training program for the workers invcived in the tank repairs and the work procedures. The BMRC General Manager also noted his own earlier involvement with the HP program during reactor repair activities in 1977-78. The University RSO noted that he was comfortable with the HP coverage provided by the facility HP staff, and that he had visited the facility several times a month during the repairs. He also noted that the repairs were completed without any uptaics of radioactive material by the workers and with minimal radiation exposure. Further, currently he reviews and approves HP procedures, facility changes that have potential radiological safety impact, the personnel radiation monitoring service, radioactive waste service, and conducts audits of the HP operation. The Operating Committee, of which he is a o
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8 member, has snet monthly since the reactor restarted. The facility currently has the equivalent of 3.5 HPs on the staff. The NRC stated that the inspector assigned to inspect the reactor facility will meet with the RSO during the next inspection to discuss the RSO's activities during routine operations. The frequency of the RSO's audits, and the frequency of his visits to the reactor facility, also will be reviewed during those discussions (50-57/93-01-05).
7.3 Facility Staffine The NRC representatives noted that it was their understanding that the facility formerly had a staff of about 20, but that it was now about 13. The Operations Manager acknowledged that there are fewer members of the staff, reflective of the lower level of utilization of the reactor. He described the staff turnover over the past few years, including the hiring of several reactor operators, all of whom n now quahfied as Senior Reactor Operators by the NRC. He noted that two key positions wem not filled after the incumbents left, the Assistant Operations Manager and the Director, who reported to the BMRC General Manager and who was responsible for day-to-day operations, while the BMRC General Manager focused on the business cperations. The BMRC General Manager now performs both jobs. However, the BMRC General Managet now believes it appropriate to fill the Director position so that he can focus on the business end of the operation. The NRC representatives noted to the licensee that staffing was a concern that deserved their attention, including the issue of succession planning among the staff.
More importantly, the NRC viewed the accelerated hiring of a qualified individual to assume the Director duties of the BMRC General Manager as of utmost importance, to assure that the Director focuses his/her attention solely on day-to-day operations of the facility and divests involvement with business activities. The NRC representatives requested that the licensee review these issues (staffing and succession planning) and provide the NRC with a position or plan for addressmg them by the end of April 1993.
The licensee also noted that most of the staff is "home grown," having been degreed by, and only worked professionally at, the Buffalo facility. They believe they have sufficient HP staff, and as they rebuild their business, they would expect to hire additional operators as needed, preferably some with experience at other facilities. The facility meets the staffing levels specified in the Technical Specifications, and the licensee feels they currently have i
sufficient staff to assure the facility is operated safely.
Morale of the facility staff was discussed. While the staff reportedly has some concerns about the viability of the operation, they remain dedicated, according to the BMRC General Manager. The current difficult financial straits of the contractor that operates the facility for the licensee, BMR, Inc. and employs 9
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9 most of the staff, has contributed to this concern, but the University remains supportive of continued operation at this time. The licensee Vice President for Research, Dr. Landi, who assumed his post since the beginning of 1993, noted that he had not yet met with the facility staff, but that he would do so in the near future.
i 7.4 Funding The University contracts with the Buffalo Materials Research, Inc. to c". rate the facility. This corporation is owned by Materials Engineenng Asn ites, Inc. (MEA). Ownership of MEA recently changed hands, and the new president, Yair Henkin, was scheduled to meet with Dr. Landi later on March
- 17. A better understanding of the new owner's plans for the company is i
expected to be gained from the meeting. The licensee agreed to inform the NRC of the results of those discussions (see Section 7.6). The new owner thus far has been financially supportive of the BMRC.
7.5 Emervency Plan The BMRC General Manager acknowledged the apparent violations identified during the inspection. He noted that he has been active in emergency planning activities with the Erie County (New York) Emergency Planning Board, and has established a good relationship with the Board and the local fire department. Further, he had assumed responsibilities for emergency phnning that previously were assigned to the facility health physicist, one of those who left the facility in the past few years. The NRC noted that it was important to meet the requirements associated with the NRC license. It was also noted that the licensee could have requested some relief from the Emergency Plan requirements from the NRC during the period that the reactor was apart for the reactor tank liner repair!.. It was also noted that waivers of compliance had been granted during that period, upon request of the licensee, for certain surveillance requirements.
The BMRC General Manager noted that they had reviewed an event that required declaration of an emergency at another university reactor in 1992 (Reed Colicge, Portland, Oregon) for applicability to their facility, and noted specific differences between the two facilities that would further minimize the effects of a similar event at the Buffalo facility. The NRC was provided the date of the next EP exercise and invited to observe.
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7.6 Conclusion j
l The NRC representatives reviewed the commitments made during the meeting.
Mr. Cooper noted that the meeting had resulted in a better understanding on the part of the !!RC of the issues discussed, but noted that some of the j
discussions confirmed our concerns. In particular, he noted that the State University of New York at Buffalo is the licensee, not BMR, and that the University needs to assure that appropriate oversight of the contractor's operations is provided. Mr. Cooper requested that, following Dr. Landi's meeting with the new owner of BMR on the afternoon of March 17, Dr. Landi contact Mr. Cooper and advise him of the results of the meeting. Dr. Landi subsequently completed this commitment on March 19, 1993. During the l
March 19 telephone discussion, Dr. Landi noted that Mr. Henkin, the new owner of BMR, had committed to provide the licensee a plan shortly for recruiting a new Director (see Section 7.3). Dr.12ndi committed to submit to NRC by the end of April 1993 the plan for hiring the new Director, in addition to the succession planning scheme to which Dr. Landi previotaly committed (Section 7.3).
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1 UNIVERSITY AT BUFFALO ottice or ide erava+i
.--ice i'Te$lQe!'.t 107 Ketta!OM i
%oen ma 9TATI L NWERSITY CF NEW YORK m etn bMIISIO, )hrW iM h ^t m.-MI!i?
j April 30, 1993
)
i i
a Richard W.
Cooper, II Division Director U.S. Nuclear Regulatory Commission l*
Region I 475 Allendale Road j
King of Prussia, PA 19406 Re: Docket 50-57 License R-77
Dear Mr. Cooper:
At our meeting Wednesday, March 17, 1993 you inquired about the vacant position of Director at the Buffalo Materials Research Center (BMRC).
During a subsequent conversation by
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phone on March'19, 1993 it was agreed that the University-would-forward a plan by the end of April, 1993.
The enclosed recruiting plan, to be_ carried out on behalf of the University by'Mr. Louis Henry, General Manager at BMRC, is already underway.
Potential candidates are'being contacted and as of this date one candidate-has been scheduled.
for interviews.
Our goal is to have a new Director in place by
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Septemoer 15, 1993.
i We will notify your office if and when circumstances require a significant change to the recruitment schedule and, of course, when the search is completed.
I Sincerely, C
Dale M.
Landi Vice President for Researen t
DML 619 Encl.
b cc:
Y. Henkin 3
L. Henry q
9-r-
April 30, 1993 STATE UNIVERSITY OF NEW YORK AT BUFFALO RECRUITING PLAN DIRECTOR BUFFALO RATERIALS RESEARCH CENTER l
The position of Director of the Buffalo Materials Research Center has been vacant for over two years.
During this time the General i
Manager has also served as Director.
This interim arrangement was satisfactory while the reactor was down for repairs.
However with reactor operations restored, the workload has increased, creating a need for additional management support to ensure continuity of supervision and full compliance with NRC regulations.
I.
Responsibilities The Director is responsible for operation of the reactor and its' support facilities, The Operations Manager, Senior Health
[
Physicist, and Analytical Services Manager report to the
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Director.
The Director in turn reports to the General Manager i
who has overall responsibility for operations of the Center.
The responsibilities of the Cirector include:
Operation of the Reactor in compliance with NRC regulations and license conditions Performance of all required surveillances, tests, and calibrations Reactor Fuel Management Emergency Planning and Preparedness Experiment and Facility Changes - Safety Reviews and performance Staff Training and Qualification Testing Nuclear Material Accountability Radioactive Materials and Reactor License amendments and Renewals Design and performance of Experiments and Tests Radioactive Materials shipping t
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5 Recruiting Plan April 30, 1993 Page 2 J
Radiation Safety and ALARA programs 1
Personnel and Environ 2 ental Radiation Monitoring
[
Hot /Wara Cell operations and testing i
II.
Qualifications Experience Since many of the tasks are specific to the operation of a non-power reactor (NPR), direct experience in an NPR facility is preferred.
Experience in an NRC licensed facility (vs. DOE) is also preferred.
A background in Engineering and management is required.
Note that the challenge is to operate the facility and not to use it.
Experience as an experimenter at an NPR-is not considered an alternative to operational experience.
The Director does interact with experimenters,-however,.so an understanding of the experimenters' needs is required.
Experience in a commercial power or military environment may be acceptable, but broad-based experience would-be important.
Trainina and Education The Director should have a degree in nuclear engineering or a related field.
Military training and extensive _ experience may_be acceptable as well.
The preferred level of degree would be determined by the level of experience.
III.
Associate Director Option A candidate with the preferred qualifications as outlined above, may not be available.
In this case, a less qualified individual may be recruitc0, and initially appointed as an Associate i
Director.
Under this option, the General Manager would remain as Director, delegating appropriate responsibilities to the Associate Director.
The longer term goal would be to elevate the skills of the Associate Director, until qualified for promotion to Director.
i IV.
Recruitment Phase I Phase I efforts are already in process and consist of a direct effort to contact potential candidates.
The field of such.
candidates is narrow, and reasonably well known due to direct l
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Recruiting Plan April 30, 1993 Page 3 i
l interaction or through the Testing Research and Training Reactor Association (TRTR).
Candidate interest may need to remain confidential.
Therefore, this must be done by telephone _and limited mailing of a recruitment flier.
It is anticipated '; hat at least three candidates will be identified and interviewed under Phase I.
Offers of employment during Phase I would be restricted to exceptionally qualified candidates.
Phase II (Director or Associate Director)
If Phase I efforts are not_ successful, Phase II will include a direct solicitation by a mailing'to the TRTR community, advertisements in the TRTR newsletter and Nuclear News, and use of a professional recruitment / placement agency.
If timing is appropriate, the ANS placement service may also be employed.
This approach is expected to generate many responses.
At least three candidates will be selected for interviews.
V.
Schedule Phase I.
Ongoing and should be completed by I
May 30, 1993.
Phase II.
Thirty to 60 days after completion l
of Phase I.
Candidate on Board.
Forty-five days from acceptance of offer.
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