IR 05000284/1993001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-284/93-01

ML20058Q097
Person / Time
Site:	Idaho State University
Issue date:	12/21/1993
From:	Chamberlain D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gallagher M IDAHO STATE UNIV., POCATELLO, ID
References
EA-93-232, NUDOCS 9312280069
Download: ML20058Q097 (4)

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1. 400 UNITED STATES

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..... DEC 21 1993 Docket:- 50-284 License: R-110 EA 93-232 Idaho State University ATTN: Mr. Michael Gallagher Vice President Academic Affairs Box 8063 Pocatello, Idaho 83209 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-284/93-01)

Thank you for your letter of December 3,1993 in response to our letter and Notice of Violation dated November 4, 1993. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained. -

Sincerely,

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Dwight D. Chamberlairi Acting Director

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Division of Radiation Safety and Safeguards cc:

Idaho State University ATTN: Dr. V. H. Charyulu Reactor Administrator Dean of Engineering College of Engineering Pocatello, Idaho 83209

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9312280069 931221 PDR ADDCK 05000284 ,

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Idaho State University -2-Idaho State University ATTH: R. D.~Clovis Reactor Supervisor-College.of Engineering Box 8060 Pocatello, Idaho 83209 Idaho State University ATTN: Tom F. Gesell Radiation Safety Officer Physics Department

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Box 8106 Pocatello, Idaho 83209 Radiation Control Program Director Division of Environment 450 West State, 3rd Floor Boise, Idaho 83720

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bec w/ copy of licens e's letter dated December 3,1993: *

J. L. Milhoan, RA L. J. Callan, DRSS B. Murray, DRSS/FIPS L. T. Ricketson, DRSS/FIPS A. D. Gaines, DRSS/FIPS MIS Coordinator

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RIV File FIPS File Lisa Shea, RM/ALF (MS 4503)

T. Michaels, NRR Project Manager (MS 11 B20) *

J. L. Caldwell, NRR (MS 10 D22) .

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B. Murray, DRSS/FIPS  :

L. T. Ricketson, DRSS/FIPS i A. D. Saines, DRSS/FIPS i MIS Coordinator RIV File i FIPS File  :

Lisa Shea, RM/ALF (MS 4503) i T. Michaels, NRR Project Manager (MS 11 B20)  !

J. L. Caldwell, NRR (MS 10 D22)

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DED-61993 s December 3, 1993 REGIONN STKFE U.S. Nuclear Regulatory Commission, Region IV UNIVERSITY Attn: Regional Administrator 611 Ryan Plaza Dr., Suite 400 Arlington, Texas 76011

Dear Sir:

Oake of the D= I am enclosing our response to the seven violations and one college of deviation identified during the N.R.C. inspection of our Erencenna fagility by Mr. Larry Ricketson and Mr. Anthony Gaines canmus Ba 8060 during August 2-6, 1993 and the enforcement conference held P Ih at our facility on October 8, 1993.

We appreciate the thorough, diligent and professionally conducted inspection and enforcement conference by you and are hoping that you will find our response satisfactory. As you may note the management oversight has been increased and a tracking system has been put in place to avoid the reoccurrence of violations. Also, an improved documentation system is being reviewed.

If you have any further questions please contact us,.

Sincerely,

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Dr. V. Charyu u Reactor Administrator and Dean of College of Engineering

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cc: USNRC Document Control Desk ,~ # .

Washington, D.C. 20555 .

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(208) 2 % 2902 l FAX: %y (206) 236 4538 W- as70 ISU ls An Equal Opportunity Employer

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t RESPONSE TO NOTICE OF VIOLATION IDAHO STATE UNIVERSITY

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This is the response to the Notice of Violation issued to. Idaho State University (ISU) in the Nuclear Regulatory Commission (NRC) '

Inspection Report 50-284/93-01 on License R-110 pursuant to Title 10 of the Cede of Federal Regulations (CFR) Part 2.

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Item A: Violation 284/9301-01 - Failure of the licensee's Reactor '

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Safety Committee (RxSC) to administer an annual written-examination to a senior operator and two operators,1and failure of the licensee's RxSC to observe the operation

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of the reactor by two senior operators and two operators during 1992.

1) Reason for violation: The Reactor Supervisor (RS), at the ,

time of the infraction and senior operator, expressed that he did not have to take the requalification exam as per the NRC

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approved requalification program at the University of Utah where he was maintaining a valid SRO license. The two reactor operators were scheduled to take an NRC administered upgrade exam in November of 1992 which they successfully completed on November 3, 1992. The RS interpreted the upgrade to SRO from  !

RO for these two operators as having fulfilled the intent of ,

the requirement. The RS also assumed that he was an ex- 1 officio member of the RxSC, and that through his observations '

of the facility SRO and RO's operating the reactor, he would have satisfied the requalification requirement concerning observations of reactor operations by operators. Also note that this violation was self-reported to the NRC inspectors.

2) Corrective actions taken and results achieved: The former i RS has been replaced by a recently appointed RS. The new RS  :

has spent a significant amount of. time reviewing all facility i documents to determine where responsibilities lie within the

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facility administrative structure and to determine the

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periodicity of these responsibilities.

Further, a new requalification program for the operators has i been approved by the NRC cffective -June 1993. These new. '

requalification requirements have been reviewed-by the SRO's and have been implemented in the operator training program.  ;

According to the new requalification program the RxSC members {

are no longer required to administer the test nor are required to observe the reactor operation by the operators.

The new RS is using a tracking system that he has devised to ,

ensure when operators need their requalification exams and  !

reactor operations exams administered. Presently, the only two licensed operators at the facility are current on their

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i requalification requirements.in part by using the tracking system devised by the RS. The monthly reports generated by ,

the RS also assist in tracking future requalification '

requirements for the facility operators.

3) Corrective actions that will be taken to avoid further violations: Since corrective actions as stated in part A.2 above have been carried out, no further action is seen to be necessary at this time.

4) Date when full compliance will be achieved: Full compliance i has been achieved.

Item B: Violation 284/9301-02 - Failure of the licensee to ensure -

that an SRO receive his biennial medical examination.

1) Reason for violation: The SRO was on sabbatical leave beginning mid December of 1991 until the month-of August of 1992. He was not present at the facility on a regular basis during his sabbatical leave period. Since there was no formal i tracking system in place to ensure when operators needed their medical exams, the SRO in question lapsed his biennial medical .

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exam requirements. Also note that this violation was self-reported to the NRC inspectors.

2) Corrective actions taken and results achieved: The current RS has developed a tracking system to ensure when facility '

operators need to receive their biennial medical exams. In addition, he is also generating monthly reports that track upcoming requirements such as medical exams. Currently, the two facility operators meet their medical exam requirements in accordance with (IAW) 10 CRF 55.

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3) Corrective actions that will be taken to avoid further violations: Since corrective actions as stated in part B.2 above have been carried out, no further action istseen to be necessary at this time.  !

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4) Date when full compliance will be achieved: Full-compliance  ;

has been achieved as is explained in part B.2 above. ,

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Item C: Violation 284/9301-04 - Failure of the licensee to-keep records showing the receipt, transfer, and disposal-of ,

byproduct material. ,

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1) Reason for violation: Although the irradiated samples from 3

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the AGN-201 are generally of very low radioactivity, it has always been the practice to survey the irradiated samples as

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soon as they are removed from the reactor. Because of the relatively low neutron flux levels associated with the AGN-201 reactor, isotopes that were produced have generally been of ,

exempt quantities were transferred to recipients on campus  ;

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that did not possess a source material license. Since January ,

1993, prior to the present inspection, we have ensured that all transfers are authorized and documented, i

The facility recognizes the need for more proper documentation with respect to byproduct material.

2) Corrective- actions taken and results achieved: As mentioned, corrective actions'have been in place since Januarp of 1993 to assure proper records are kept concerning byproduct material. Training between the RS and the other SRO has been conducted to ensure that any byproduct material produced has proper record entries made to be in compliance with 10 CPR 30.51.

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3) Corrective actions that will be t3 ken to avoid further violations: The RS is drafting an improved record system for -

byproduct material produced by the reactor. This new :

documentation will further assure compliance with 10 CFR 30.51. Also, RxSC members are currently reviewing suggested revisions to the reactor operating procedures and forms to ensure that the necessary byproduct material record entries are made immediately after byproduct material production.

4) Date when full compliance will be achieved: The improved record system for byproduct materials and the revisions to the reactor operating procedures and forms will be approved and implemented by March 31, 1994 to meet full compliance. ,

Item D: Violation 284/9301-05 - Failure of the licensee to verify that persons receiving byproduct material were authorized to receive such material as is required by 10 CFR 30.41.

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1) Reason for violation: Since the byproduct material has been of very low activity, it has been the past practice to i transfer items without verifying that the recipients had an authorized program under the ISU campus broad scope material license. Lack of familiarity with 10 CFR 30, with regards to byproduct material, was the reason for this violation.

2) Corrective actions taken and results achieved:-The RS and the other SRO had held training with regards to transferring byproduct material to other users to ensure that the facility

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is in compliance with regards to 10 CFR 30.41. 'Also, since January of 1993, we have been following the necessary steps, ,

concerning byproduct material, set forth by the Technical Safety Office to ensure that byproduct material is only transferred to authorized users.

3) Corrective actions that will be taken to avoid further violations: The RS is drafting an improved record system for byproduct material produced by the reactor. This new

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documentation will further assure compliance with 10 CFR ,

30.41. Also, RxSC members are currently reviewing suggested :

revisions to the reactor operating procedures and forms to ensure that the necessary byproduct material record entries '

are made prior to transfer to other authorized users. ,

t 4) Date when full compliance will be achieved: The improved record system for byproduct materials and the revisions to the y!

reactor operating procedures and forms will be approved and implemented by March 31, 1994 to meet full compliance, t

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item E: Violation 284/9301-06 -

Failure of the licensee to I maintain radiation survey results IAW 10 CFR 20.

I 1) Reason for violation: Lack of. familiarity with 10 CFR 20, ,

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with regards to maintaining records of radiation surveys, and the lack of proper documentation are the reason for this violation.

2) Corrective actions taken and results achieved: The RS and the other SRO has held training with regards to the necessity to maintain proper radiation survey results to ensure that the facility is in compliance with to 10 CFR 20. Also, since January of 1993, we have been following the necessary steps to *

ensure that the required radiation surveys on byproduct material, set forth by the Technical Safety Office, are properly recorded and maintained. Therefore, the facility is and has been in compliance with 10 CFR 20 since January of ,

1993, prior to the inspection that took place'in August of 1993.

3) Corrective actions that will be taken to avoid further violations 1 The RS is drafting an improved record system for byproduct material produced by the reactor.. This new documentation will further assure compliance with 10 CFR 20.

Also, RxSC members are currently reviewing suggested revisions ,

to the reactor operating procedures and forms to ensure that the necessary byproduct material record entries are made with regard to radiation surveys.

4) Date when full compliance will be achieved: The improved ,

record system for byproduct materials and the revisions to the reactor operating procedures and forms will be approved and '

implemented by March 31, 1994 to meet full compliance.-

Item F: Violation 284/9301-08 - Failure of the Radiation Safety Officer (RSO) to provide training, IAW the NRC approved Emergency Plan, to the Reactor Administrator (RA).

1) Rq.ason for violation: The requirement for the RSO to train on emergency plan originated when the RSO and the RS were the i

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same individual. However, the dual position was split in December of 1991. The new RSO interpreted the training requirement as radiological control training in support of'

emergency preparedness, not complete training to the emergency response plan. Nonetheless, _ the RSO failed to perform a recognized duty by not training the Reactor Administrator in radiological support of emergency preparedness.

o 2) p.orrective actions taken and results ac.hieved: The RS has developed a' tracking system to ensure the r.ecessary Emergency Plan training for university personnel is given within the ' I specified periodicity. Currently, with the use of the tracking. system developed by the RS, Emergency Plan training

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is up to 'date and the facility is in full compliance.

3) Rgyrective actions that will be taken to avoid further i violatio_p_s; The Emergency Plan will be changed to identify the RA and RS as responsible for training related to the Emergency Plan. The RSO will assist the'RA and RS in radiological control training related tho the emergency plan. l 4) Date when full connliance will be achieved: Changes to the Emergency Plan will be complete by March 31, 1994.

Item G: Violation 284/9301-09 - Failure of the licensee's RxSC to '

conduct audits IAW the Technical Specifications within periodicity.

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1) Reason for violation: On February 4, 1992 RxSC meeting, the RS (at that time) presented an Audit and Review Plan that would correct the violations of the December 1991 NRC inspection. However, the Audit and Review- Plan failed to address that several audits were due before the recommended implementation date. Also, the Audit and Review Plan addressed how to perform the audits and not specifically how to track them. The lack of an adequate tracking system to ensure that audits required by the Technical Specifications are performed within periodicity is the reason for this violation. Also note that this violation was self-reported to :

the NRC inspectors.

2) Corrective actions taken and results achieved: The current RS has developed a Tracking system to ensure audits, along-with other facility requirements, are completed within periodicity. The RxSC has reviewed and approved the Tracking system at the November 23, 1993. Also, monthly reports generated by the RS track future administrative requirements. ;

This monthly report is one method used to ensure that facility personnel, other than the RS, are aware of their administrative duties. The Tracking system is in use and is ensuring that the facility is in compliance with all administrative requirements.

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3) Corrective actions that will be taken to avoid further violations: Since corrective. actions as stated in part G.2 above have been carried out, no further action is seen to be ,

necessary at this time.  :

4) Date when full compliance will be achieved: The facility is l presently in compliance, i Item H: Deviation - Failure of the licensee to establish Letters of Agreement (LOA) with off-site emergency response agencies.

t 1) Reason for deviption: The previous RS began to research the necessary requirements to develop LOA. This is evident by copies of. the LOA sent~to the previous RS from Texas A&M University Assistant Director of the Nuclear Science Center Laboratories dated 29 January 1992. After receiving this information, the previous RS failed to complete.the task of obtaining letters of agreement from the off-site emergency response agencies, although he (the previous RS) had reported to the RxSC that LOA's were sent-as reflected in the draft minutes submitted to the NRC.

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2) Corrective actions taken and results achieved: Draft LOA's were hand delivered to Bannock Regional Medical Center,-

Pocatello Regional Medical Center, Idaho State Police, and the City Attorney (for the purposes of city fire and . police ,

support) on Oct 5, 1994. All of these entities, wiil the exception of Pocatello Regional Medical Center, have verbally approved of LOA's with only minor revisinns to be made.

3) Corrective actions that will be taken to avoid i further

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deviation: Contact with the listed off-site emergency support agencies is and will continue to be maintained. . Understand that the facility can not make tL*tse support agencies sign the ,

LOA's. We can make no promise that they will sant to support ;

us for the purposes of emergency response, but we believe through the good faith of community service that there is no ,

reason that'they will not come to some final agreement on the LOA's.  ;

4) Date when full compliance will be achieved: The facility will continue to make a concerted cffort, as we have since' l October 5, 1993, to obtain the LOA's requested. The RxSC will 1 also provide oversight in ensuring that a strong effort is I made to acquire the LOA's. Therefore, we car. net no date.of j implementation , but only a very strong intent to have the ;

off-site support agencies sign the LOA's. We wish this c:: tion to occur on or before March 31, 1993.

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REACTOR SAFETY COMMITTEE MEETING .

NOVEMBER 23, 1993 [

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1. Election of Dr. Tom Gesell as alternate  !

chair of the Reactor Safety Committee.-

2. Discussion of Notification of Violations letter from the NRC dated November 1993.

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3. Other Business.  ;

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Minutes of the Idaho State University Reactor Safety Committee  ;

Date: November 23, 1993 Start time: 7:15 P.M.

End time: 8:45 P.M.

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Members Present:

Dr. Tom Gesell, Radiation Safety Officer .

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Dr. Hary Charyulu, Reactor Administrator Mr. R. David Clovis, Reactor Supervisor Dr. Frank Harmon Mr. Terry Smith l 4? >

Others Present: *. %

g none ~~e- y a 3 1. The meeting was called to order by the Reactor Administrator at 7:15 P.M.

2. Dr. Tom Gesell was appointed the Reactor Safety Committee Chair alternate.

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3. There was a broad discussion of all Nuclear Regulatory Commission (NRC) cited violations and deviations ofthe August 1993  !

inspection. The corrective actions in place and.those to be taken were reviewed. Af ter the review, it was agreed that all corrective actions will be in place by March 31, 1994. By April 30, 1994, the j

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Reactor Safety Committee (RxSC) will perform a review regarding the implementation of the corrective actions. Also, the RxSC will -

perform an ongoing review, effective immediately, to ensure corrective actions either been or are carried out. This'is a three step process: 1 a) The RxSC finds the methods to be used or that have been used to perform corrective actions for the deviations and violations as satisfactory, b) The RxSC will ensure that all corrective actions will be in place by March 31, 1994.  !

c) The Rx5C will conduct an on-going review between now and. j March 31, 1994 to ensure that the corrective actions are implemented in a timely fashion. I 4. Dr. Frank Harmon suggests that the Institute of Environmental llealth and Safety at Idaho State University review and upgrade (if ,

needed) the Reactor Emergency Plan.

5. Dr. Tom Gesell informed the RxSC that the Memorandum's of Understanding (MOU) between the university and off-campus emergency '

response organizations have been sent out and that three of four entities have responded regarding tentative approval of the MOU's.  ;

6. A motion was made to approve the plan to implement all  !

corrective actions, regarding the deviation and violations. The motion was passed unanimously. *

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7. Mr. Terry Smith would like the RxSC to consider giving authority ;

to an approval subcommittee with regards to approving new or  !

revised procedures, experiments, or configurations. '

8. The meeting was adjourned at 8:45 P.M.

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IDAHO STATE UNIVERSITY MONTHLY REACTOR REPORT SEPTEMBER 1993 t

Prepared by:

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R. David Clovis Reactor Supervisor 11/05/1993 s

RESPONSE (S) NEEDED FROM:

CHAIR, REACTOR SAFETY COMMITTEE REACTOR ADMINISTRATOR RADIATION SAFETY OFFICER L SENIOR REACTOR OPERATORS:

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REACTOR OPERATORS:

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ISU AGN-201 REACTOR REPORT - SEPTEMBER 1993 1.a. There were no changes to the facility design, performance characteristics, or operating procedures relating to reactor safety.

b. Results of major surveillance tests and inspections:

Completed HP-I Rod Maint. on 09/07/1993.

Completed Technical Specification (TS) 4.3.b Shield tank inspection for leakage on 09/30/1993.

2. The reactor was operated a total of 35.45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> during 23 individual operations.

Individual Operator Run Times R. David Clovis 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> 16 operations Dr. A.E. Wilson 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> 7 operations-Trainee Operations Kermit Bunde 9 operations Dale Boren 2 operations Bob Boston 4 operations Bruce Jensen 3 operations

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3. There were no unscheduled shutdowns.

4. Corrective Maintenance:

Replaced the Reactor Console " Power On" indicator light bulb.

Adjusted #1 Safety Rod drive worm gear output shaft.

S.a. There were no changes to the facility to the extent that it changed the description of the facility in the application for license or amendments thereto, b. There were no changes to the facility procedures as described in the facility TS.

c. There were no new experiments or test performed.

6. There were no new safety evaluations written, because no new experiments or test were performed.

7. Summary of the nature and amount of radioactivity effluents released or discharged to the environs:

a. Liquid waste - none b. Airborne waste - none c. Solid waste- none G. There were no environmental radiological surveys performed outside the facility.

9. Personnel Radiation Exposure:

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'o Third quarter radiation-exposure results are not back from Landauer as of yet.

The only recorded exposure to date for the calendar year is ,

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'for:

R. David Clovis 40 mrem ITEMS SCHEQULEQ_ EOR OCTOBER 1993 ,

Maint. and Surveillance: '

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J TS 4.1.a Estimates for Safety and Control rod reactivity worths.

TS 4.1.b Shutdown margin and excess reactivity TS 4.2.a Scram time and average reactivity insertion rate TS 4.2.b Seismic displacement interlock channel test Other:

NRC Enforcement Conference 10/08/1993 TRTR Meeting 10/19-22/1993 NRC Operator Licencing Exams 10/25-27/1993 "

Fuel status report due 10/25/1993 1TEMILEfliEDULED FOR NOVEMBER 1993 Requalification:

Dr. A.E. Wilson written and console exam R. David Clovis console exam Emergency and Security Plan:

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IIold Emergency Plan and Security Plan training with university personnel.

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Hold the annual emergency drill.

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