ML20059F723
| ML20059F723 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Rolla |
| Issue date: | 08/30/1990 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Bolon A MISSOURI, UNIV. OF, ROLLA, MO |
| References | |
| NUDOCS 9009110329 | |
| Download: ML20059F723 (2) | |
See also: IR 05000123/1990001
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AUG 3 01990
Docket No. 50-123
e University of Missouri - Rolla
. ATTN: Dr. Albert E. Bolon, D' rector
-Nuclear Reactor Facilitj
Rolla, MO 65401
Gentlemen:
/" This refers to the inspection conducted by Messrs. A. Dunlop, Jr., and
W. B. Grant of this office, and Mr. M. M. Mendonca of the Office of Nuclear
Reactor Regulations on August 13-14, 1990, of activities at the University-
of Missouri - Rolla Reactor authorized by t'RC Operating License No. R-79 and
to the discussion of our findings with Dr. A. E. Bolon at the conclusion of
the inspection.
The enclosed copy of our inspection resort identifies areas examined during '
the inspection. Within these areas, t,e inspection consisted of a selective
examination of procedures and representative records, observations, and
interviews with personnel.
During this inspection, certain of your activities appeared to be in violation
of NRC requirements. This apparent violation pertains to the failure to
perform a surveillance test per Technical Specification 4.2.?(1) for the .
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reactor period scram channel orior to each days operation end.is fully
described in Paragraph 8 of the enclosed insptetion report. This violation has
been categorized at a Severity Level IV/V and a Notice of Violation (Notice) is
normally issued for violations at that Sererity Level. However, the NRC wants
to encourage and support licensee's initiP ives for the self-identification and
reporting of potential corrective action, ucluding thorough root cause
analysis. Further, this violation does not appear to be either repetitive or
, willful in nature. Therefore, in accordance with paragraph V.G.1 of-the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
'(Enforcement Policy) 10 CFR Part ?, Appendix C, the NRC is exercising the
' discretion authorized by the Enforcement Policy and a Notice of Violation is
not being issued for this matter. You are requested to notify us in writing
within 30 days of the date of this letter only if you disagree with our
statement of your corrective action for the violation described in Paragraph 8
-of the enclosed inspection report. Otherwise, a reply to this issue is.not
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. required and we do not have any further questions at this time. The corrective
actions whien you implemented as a result of this violation were examined and
determined to be acceptable.
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- In'accordance with 10 CFR 2.790 of the Commission's regulations 'a copy of this
letter and the enclosed inspection rtpart will be placed in the NRC's-Public -
tDocumentiRoom.
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We will gladly discuss any questions you have concerning th's inspection. '
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+E Richard C. Knop, Chief
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Reactor.. Projects Branch 3 i
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Enclosure:-~ Inspection Report '!
No. 50-123/90001(DRP) ,
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F- Dr. Don Warner, Dean- 1
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MetallurgyL ,
Dr. William Vernetson, Director !
,.. of Nuclear; Facilities ,
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$ U.S. NUCLEAR' REGULATORY COMMISSION
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REGION III q
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Report No. 50-123/90001(DRP) ;
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Docket No. 50-123- License No. R-79 i
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Licensee: University Of Missouri - Rolla f
.l Facility Name: Rolla Reactor
Inspection At: Reactor Building, Rolla, Missouri ;
, Inspection Conducted: Auge',t 13-14, 1990 ,
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Inspector: A. Dunlop, Jr.. ) s. 9 e
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W. B. Grant
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M. M. Mendonca P 774
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1. N. Jackiw, Chief rfM b.?#-Fe
Approved By: ;
Reactor Projects Section 3A Date ,
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inspection Sumary i
Inspection on August 13-14, 1990 (Report No. 50-1?3/90001(DRP); ,
Areas Inspected: Routine, unannounced inspection to review actiot an:
followup on previous inspection items (9?701); organization, logs, and [
-records; review and audit functions; requalification training; procedures;
activitie>; emergency planning;
. radiation
surveillance; experiments;
controls; fuel handling (40750); transportation activities
radwaste management
(86740); and periodic and special reports (90713). ;
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Results: Of the 13 areas inspected, one non-cited violation was identified.
-This pertained to the failure to perform a surveillance test on the reactor
period scram safety channel prior to each day the reactor was operated (see
Paragra)h 8). The facility is being properly maintained and operated in an
accepta)1e manner.
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DETAILS
1. Persons Contacted
University of Missouri - Rolla
*A. E. Belon, Reactor Director
. *D. W. Freeman, Reactor Manager
R. Bono Director, Environmental Health / Risk Managenent and
Health Physic 4='
*C, Barton, Eleci. .c Technician / Senior Operator
*L. Pierce, Senior Secretary
* Denotes those attending the exit meeting on August 14, 1990.
2. General (40750)
This inspection, which began on August 13, 1990, was conducted to
examine the research reactor program at the University of Missouri
- Rolla. The facility was coured shortly after arrival. The generai
housekeeping of the facility is good.
The reactor is used for classroom instruction, training, research,
and irradiation service. The licensee provides tours of the facility
to over 2,000 visitors a year. The facility intends to convert to low
enriched uranium (LEU) fuel when funds from the Departnent of Energy
become available (scheduled 1991).
No violations or deviations were identified.
3. Action on Previous Inspection Items (90701)
a. (Closed) Open Item (173/85002-01): Requalification training
evaluations not perforned in accordance with approved program.
Senior Operators (50s) were performing the operator evaluations
where as the Requalification Training Program required the Reactor
Supervitor or Training Coordinator to do the evaluations. The
licensee has revised the program to state that the evaluation can
be performed by an S0. This item is closed,
b. (Closed) Open. Item (123/87001-01): No prior NRC approval on
changes to the operator Roqualification Training Program.
Region 111 requested guidance from the Office of Nuclear Reactor
Regulations (NRR) as to whether the changes to the program
identified by the inspector required prior NRC approval before
being implemented. Per an NRC memorandum, J. N. Hannon to
W. D. Shafer, dated February 19, 1988, NRR determined that the
changes in question did not require prior NRC approval per
10 CFR 50.54 (1-1). As such, this item is closed.
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c. (Closed) Violation (12?/87001-02): Failure to follow Standard
Operating Procedures (SOP) 600, Laboratory Rules, (Technical
Specification 6.3 violation) regarding not eating, drinking, and
smoking in the reactor bay area or the counting room, or while
handling radioactive materials and bypassing the frisker station
when leaving the bay area. The licensee has made certain additions
and changes to SOP-600 in order to clarify the purpose of the rules,
which prohibit eating, drinking, and smoking in the reactor bay and
the counting room and to add a section about use of the frisking
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station. The inspectors reviewed the revised 50P and made
observations in the licensee's facility which indicate the
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corrective actions have been effective. See Paragraph 13 for
additional discussion. This item is closed. ;
d. (Closed) Open Item (123/87001-3): . Desirability of having
' independent audits performed of reactor. health physics. activities
and that written responses be made to audit findings / recommendations. .
The inspectors reviewed the most recent audit of *a facility that ,
was conducted April 3,1990, by members of the Columbia Research ,
Reactor staff. Written responses to the audit findings / recommendations
have been completed. The Rolla Reactor Manager stated that this policy
will continue. This item is closed.
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e. (Closed) Open Item (123/87001-04): Licensee does not verify
ventilation system flow rates listed in Technical Spacification ,
3.5 (4,500 cfm), which requires a ventilation fan to te operating
when the reactor is at full power. Technical Specification 4.5 on
surveillance testing for the ventilation system only requires a ;
visus 1 monthly check for proper operation. The licensee reviewed
the design specifications of the three reactor building ventilation
fans and verified that each fan is rated greater than the 4,500 cfm i
requirement. It is not a Technical Specification requirement to
verify the flow rates on a pet 3dic basis, nor does it appear r
necessary based on the ratings of the three fans and procedural
requirement to have a fan operating. This item is closed.
I f. (Closed) Open Item (123/87001-05): Use of the facility portal
monitor should be improved and its operability checked on a routine
basis. The location of the portal monitor has been changed so that ,
workers must pass through the monitor in order to exit the facility.
Procedures for the correct use of the portal monitor have been
visibly posted at the. entrance to the monitor. In addition, the- >
instrument is routinely source checked for operability by the Senior
Electronics Technician. This item is closed.
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g. (Closed) Open Item (123/87001-06): The licensee should eveluate-
the need for extremity dosimetry. TLD ring badges have been .
purchased for extremity dose evaluation of reactor personnel who ,
perform sample irradiations and reactor maintenance. This item
is closed.
h. (Closed) Open Item (123/87001-07): Desirability of collecting and
analyzing the constant air monitor (CAM) filter media on a routine i
basis. The licensee changes the particulate filter on the CAM when
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particulate bui?iup on the filter reduces the air flow. The filters l!
are analyzed for isotopic content and no significant activity, other -
than naturally occurring isotopes have been detected. This item l
is closed.
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No violations or deviations were identified,
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4. Oroanization, Logs, and Records (40750)
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The facility' organization was reviewed and verified to be consistent with -
the Technical Specifications and Safety Analysis Report (SAR). The minimum
staffing requirements were verified to be met during reactor operation, and !
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fuel handling or refueling operations.
The reactor logs and records were reviewed to verify that: j
a. Records were available for inspection,
b. Required entries were made. ,
c. Significant problems or incidents were documented. .
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d. The facility was being maintained properly.
The previous Reactor Manager resigned from his position at the facility
in August of 1989. The position was filled in May 1990 and the new manager
is in the process of cualifying for an S0 license. He previously held <
an 50 license at the lniversity of Virginia reactor.
The inspectors reviewed o 3erator logs, pre-startup checklists (50P-102), ,
hourly operating logs (50)-104), and secure checklists (50P-105). The
logs were complete and of sufficient detail. ,
No violations or deviations were identified.
S. Reviews and Audits (40750)
-The licensee's review and audit program records were examined by the
inspector to verify that:
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a. Reviews of facility changes, operating and maintenance procedures,
design changes, and unreviewed experiments were performed by the -
Radiation Safety Committee as required by Technical Specifications
or SAR. .
b. The safety committee and/or subcommittee were composed of qualified
members and tFat quorum requirements and frequency of meetings had
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been met.
I c. Required safety audits had been conducted in accordance with
Technical Specification requirements and that identified problems
were resolved.
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The Radiation Safety Comittee met on a quarterly basis' and reviewed
' appropriate issues (e.g.,- new experiments.- NRC submittals, conversion t0
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1.EU fuel documents). An independent audit was' performed in April-1990 '
~y by personnel from the Missouri University Research Reactor at Columbia. '
Several: comments and recomendations were made in their report. The >
license adequately addressed these issues in a June 1990 memo.- ,
No vio'ations 1 or. deviations were. identified. {
6> Requalification Training (40750)
F 1: The inspectors reviewed procedures, logs, and training recordst and
= interviewed personnel to verify that the requalification' training program '
was being carried out in conformance with the facility's approved plan
'and NRC-regulations. The' inspectors reviewed the licensee's Requalification
Training Program dated May 1988, Revision 2. The inspectors verified through '
m documentation review that the licensee's -1989 program was complete, including
forms for the conduct of on-the-job training, requalification examination
L results, and operator assessments. The licensee is in the process of. '
completing the 1990 requalification program. No problems were noted. g
No violations-or deviations were identified. .
7. -Procedures (40750)
a The inspectors reviewed the licensee's procedures to determineLif i
procedures were issued, reviewed, changed or updated, and approved
in accordance with' Technical Specifications and SAR requirements.
This review also verified:-
a '. - That procedure content was adequM e a safely operate, refuel.:
4 :and maintain the facility.
b. That responsibilities were clea ly w 'ined. 4
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c. That. required checklists and fe c were
The inspector determined that the r; n-. *es were available
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mto.the operators and the contents i t.: w dures wer'e found
adequate. Procedures are reviewed e. <su o i . sir and revised as
required. .
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No violations or deviations were identified.
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8. Surveillance (40750).
The inspectors reviewed procedures, survc41 9 ce test schedules,
and test records and discussed the surveillance and preventive ,
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maintenance program with responsible personnel to verify:
a.- .That procedures were available and adequate to perform tests.
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b. . That tests were completed within the required time schedule.
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c. Test records were available.
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The" inspectors reviewed selected Technical Specification surveillance,
requirements and verified adequate testing was being conducted in all
but on5 case. Technical' Specification 4.2.2(1) requires a channel test
of each reactor safety system channel be performed each day before the
reactor is operated. The ins
channel (less than S seconds)pector
was notnoted
being that-the reactor
tested on period scram
the pre-startup-
checklist (SOP-102). The licensee informed the inspectors 6 hat during
a training lecture for the Requalification Training Program, the seu
deficiency was noted and a revision te UI M 2 was in progress to include
this testing. The licensee addressed 5hb 45ue with the operators and "
informed them that this test shodd w performed prior to a reactor startup
and documented in the log book at an V tecim process unt " the procedure
was revised. The licensee hrs been in a maintenance' outage mi no reactor
startups have been performd since the deficiency was identified.
Although-the licensee had not been performing this test as required by
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Technical Specifications'(daily), the test was being Jerformed on a
weekly basis with no identified problems. As such, t1ere is no apparent
safety significance to this issue since the chance of the channel failingi
to perform its intended safety function'was minimized due to the weekly
tests.
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Prior to the. inspectors-leaving the facility, the license had completed-
the revision to SOP-102 to include the required testing of the. period.
scram function. This revision was reviewed by the inspectors'and
determined to be adequate corrective-action.
The failure to perform the reactor period scram channel test prior
to each day.of reactor operations is a violation (123/90001-01) of
e -Technical Specification 4.2.2(1). This licensee-identified violation
is not being cited because the criteria specified in Section V.G of
the Enforcement Policy were satisfied. This item is closed.
The licensee is in the process of-establishing a schedule board that will.
. list tests, reviews, reports, and other items with the date scheduled and
date previously performed. - Although meeting schedule dates has not been
a problem, this will allow operators and managers to be more aware of
dates for scheduled items.
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One non-cited violation was identified. -;
9. Experiments (40750) i
The inspectors verified by reviewing experiment records and other
reactor logs that: y
a. Experiments were conducted using approved procedures and under
approved reactor conditions,
b. New experiments or changes in experiments were properly reviewed
and approved.
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c. . The experiments did notiinvolve an unreviewed safety question, I
i.e., 10 CFR 50;59- 4
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d. . Experiments involving potential hazards or reactivity changes
; .were identified in procedures,
e. Reactivity limits were not or could not have been exceedsd -
Jduring,anLexperiment. '
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The inspectors reviewed the licensee's 700 series SOPS that control
requests and conduct of experiments. The reviewed records' indicated that 1
approvals =and conduct of experiments were performed in accordance with
the procedural requirements.in all but a few isolated cases. Several'
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forms-did'not indicate that samples were surveyed for radiation levels
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as required.1 Based'on the type:of experiments and' associated measurements
on previous-similar samples, there a) pears to be no safety significance. '
The. licensee:comitted to evaluate t1ese findings and-take action, e.g., ,
staff briefing, to assure attention to detail in the completion of required :
information. The inspectors concluded this action is acceptable and no ;
further action is warranted. -
-No violations or-deviations were identified.
, 10. Fuel-Handling (40750)
The facility fuel handling program was reviewed by the inspectors.
The review included the verification of ap3 roved procedures for fuel
handling and their technical adequacy in tie areas of radiation
protection,-criticality safety, Technical Specifications, and security
plan requirements. The inspector determined by records review and
discussions with personnel that fuel handling operations were carried
,out in conformance to procedures. The licensee moves fuel for the
> annual control rod. inspections; no concerns were identified. ,
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No violations.-or deviations were identified. '
ill. . Emergency Planning (40750)
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The inspectors reviewed records and interviewed personnel to determine
that the approved emergency plan was being carried out by verifying:
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a. That. procedures were in place and required records were being 1
kept.
c b. That-required drills were conducted and evaluated.
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c. That required training had been conducted.
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The inspectors reviewed the licensee's Emergency Plan dated May 15, 1989,
Revision 3 and verified that the licensee complies with the plan's
requirements. Specifically, the licensee performs a building evacuation .
drill at the start of each school semester. Annual training on emergency i
preparedness is provided to the operators as part of the Requalification
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% Training Program. ' Environmental Health / Risk Management provides- training'
to campus health-physicists and other local agencies (police, fire, and
hospital personnel) required to respond to an event at the reactor,
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f No violations or deviations were identified.
nT =12. . Transportation Activities (86740)
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.The-inspectors reviewed the licensee's shipping program for compliance
with the requirements in Department of Transportation (DOT).and NRC
regulations, 49 CFR Parts 172 & 173 and 10 CFR Part 71, respectively.
Material is occasionally irradiated-in the reactor and transferred'
to on-campus users (normally less than ten transfers per year).
Irradiated samples are held at the reactor facility to allow
short-lived isotopes to decay, then surveyed (direct and smear).
prior to being released to users. Samples for use in laboratories-
. on the university campus are transferred to NRC Byproduct Material
License No. 24-00513-32. Procedure SOP-604, " Release of Byproduct
Material on Campus," provides guidelines for such transfers.
Records of transfers were selectively reviewed for 1989 and.1990
to date; no problems were noted.
No-violations or deviations were identified.
13. Radiation Control (40750) ,
The inspectors reviewed the radiation protection activities since
the last inspection. Rece ds were reviewed, personnel-were
interviewed, and observations were made to verify that radiation
controls were being carried out in accordance with' license and NRC
regulations.
Indoctrination Training
All reactor-related personnel are given an indoctrination-in radiation-
safety before they assume their work responsibilities. Additional'
radiation safety instructions are provided to those who will be working
directly with radiation or radioactive materials. Students and new
employees receive training pursuant to 10 CFR 19.12 by viewing a video
tape. Individuals sign a form attesting to their understanding of the
material presented in the tape. The video tape was viewed by the
inspectors; no problems were noted. In addition, employees are provided
and instructed to review Regulatory Guides'8.13. " Instruction Concerning
Prenatal Radiation Exposure," and 8.29, " Instruction Concerning Risks
From Occupational Radiation Exposure," and they are tested on their
understanding of them. They are also instructed in the licensee's
SOP-600, " Laboratory Rules."
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Instruments" and Equipment - <
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a. : Portable Survey Instruments' j
The licensee appears to have an adequate supply of appropriate ,
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portable survey instruments capable of? measuring beta,' gamma, and~ +
neutron radiation. Most portable survey instruments are calibrated
by the campus health physicist as authorized by NRC Material License
No. 24-00513-32.. Beta /gama measuring instruments are calibrated '
semiannually using a nominal 100 millicurie Cs-137 source. 'High.
range' instruments (ionization chambers) are returned to the -
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manufacturer for calibration. _The two neutron measuring instruments !
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are typically calibra wd by the manufacturer and response checked
by the licensee using their 5 curie Pu-Be source.- Calibration
records for 1990 were reviewed; no problems were noted. The
inspectors examined several instruments maintained in the reactor
facility; each instrument was operable and had a current calibration ,
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b. Area Radiation Monitors .
In accordance with Technical Specifications, the facility has
operable area radiation monitors located on the reactor bridge,
at the demineralizer, and .in the experiment room. Operability and
alarm setpoints are checked daily using internal check, sources;
performance of these checks were confirmed by a selective review- ..
of daily operational checklists for 1990 to date. In situ monitor
L calibrations are normally performed semiannually.using the L aforementioned Cs-137 standard.
c. Frisking Station and Portal Monitor-
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A hand held'frisker is located at the reactor bay egress . leading
to the counting room. An area posting and laboratory rules instruct
workers to frisk prior to leaving the bay area if they have been
L working with radioactive materials. Frisker operability is ; u periodically verified using a check source;' calibration is performed i using a Cs-137 source. The licensee has one walk-through portal L the facility. The monitor L monitor located in the hallway exiting
contains nine conventional G.M. tubes (three on each side, one for
each foot, and one above the head) linked to.an analog display.
Personnel normally walk through the-monitor when leaving the bay
L area, counting room, or control room to leave the facility. E Personnel are instructed to pause for a few seconds in the monitor-
and to observe the analog display. The portal monitor is routinely
checked for operability using a Cs-137 source.
- d. Air Particulate Monitor
The reactor facility has one continuous air particulate monitor -
(CAH) located in the reactor bay. The CAM is electronically pulse
checked periodically.
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Exposure Controls ,
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The' personnel dosimetry services of R.S. Landauer, Jr., and Company-
are utilized by the licensee on a bimonthly. exchange basis.1 All ,
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nuclear _ reactor facility staff members are provided with whole body ,
film badges capable of detecting beta, gama, fast and thermal neutrons. -l
Self-reading dosimeters are provided to visitors, temporary workers, and' *
other personne1~as warranted. Extremity TLD dosimeters are provided to
- selected reactor staff members and c.re used on an as needed basis. The
licensee will evaluate extremity exposure data in order to determine the
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future need.for the dosimeters.
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The vendor's whole body dosimetry reports were reviewed for 1989 and 1990
to date for reactor facility workers. All annual whole body exposures were
less than 50 mrem. .
Pool Sampling
e Pool _ water samples are collected every month and analyzed for tritium H content. The most recent tritium analysis of pool water showed a ,
concentration of about 3 E-6 uCi/ml; similar concentrations were- 4
p determined for. previous samples. Based on this analysis and typical '
pool water usage:(evaporation). less than 0.05 mil 11 curies of tritium ;
'is released from evaporation of reactor pool water per year. !
Surveys
a. Area Surveys
1. Direct radiation surveys and smear sampling are performed in
various reactor building areas on a monthly basis by the health
physics staff. Special surveys are performed as needed to evaluate
new or changing experiments; thermal column and beam port experiments
are surveyed after any. modifications. - The licensee relies on their-
!= area monitors for indications of unexpected radiation levels. , 1
The inspectors reviewed records of: smear and direct surveys for 1989 l
and 1990 to date. Smears are counted on the licensee's gas flow
proportional counter; removable contamination is rarely detected.
No problems were noted.
b. Air samples
The facility's CAM also functions as an air sampler. The .
p -licensee analyses the CAM filter media on a routine basis, no
- significant activity other than naturally occurring isotopes
1- .have been detected.
No violations or deviations were identified.
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14. Radwaste Management (40750)'
a. : Gaseous Radwaste
The principle gastous effluents produced are Ar-41'and neutron
F activated dust particles. These are produced by the irradiation
of the reactor pool water and to a lesser extent, air and.airborn'e
particles'in-the thermal column and the beam port. The air is swept
from the reactor bay snd the experimental areas by three exhaust
fans located in the roof of the reactor building. Technical--
Specifications require a ventilation fan with-a capacity of at
least 4,500 cfm to be operable when the reactor is at full power.
Each of the three fans are rated for this capacity.
n The licensee. collects a reactor bay gas sample with the reactor at
full power on an annual basis. The Ar-41 concentration in the reactor
bay at full-power was determined by the licensee to be.less than
2 E-8 uCi/ml. The licensee evaluates airborne releases monthly by
comparing operating times of building exhaust fans and reactor power
to annual measured air activity at full reactor power. The inspectors
reviewed; monthly release data for 1990 to'date. The maximum activity.
released'was'38 mil 11 curies in May 1990 at a concentration of less - -,
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than 2 E-7 uti/ml (less than 50% of Technical Specification /10 CFR 20 !
concentration limits). j
b. Liquid Radwaste ';
All drains in the reactor bay and equipment areas lead to the
s basement sump. The largest volume of liquid.radwaste is produced-by -
;
L regeneration of the demineralizer. Resin regenerations are initially 1
discharged into two 300-gallon retention tanks and allowed.to decay, j
The contents of-the tanks are eventually released to the basement !
'
" sump, pumped to the mid-level sump, and released to the sanitary
.
sewer system if analysis shows that concentrations are within.10 CFR j
20.303 limits. Licensee records show there'were ten liquid releases -i
from July 1989 through June 1990 totaling about 250 uCi-(gross a
activity) in about 6000 gallons. 4
c. Solio Radwaste
The licensee generates very little solid radwaste. The waste
consists primarily of spent resins and filters.which'are stored for .
-
.;
eventual shipment to a licensed disposal facility. According to the l
licensee there are nine 55-gallon-drums containing less-than 4 mci. ;
of'Co-60/Cs-137 in storage awaiting shipment at this time. .-Solid
L short-lived radwaste is held for decay, surveyed, and' disposed of
in the sanitary landfill. !
No violations or deviations were identified. (
,
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. !
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15. ' Review of Periodic and Special Reports (90713). =!
-f
. The inspector reviewed the following annual reports for timeliness of l
submittal and adequacy of information submitted:
PhogressReport 1987-88 'l
Progress Report 1988-89 :
Progress: Report:1989-90
The reports contained the information required per. Technical
Specification 6.6.1.with the exception of several rundowns that were
.not listed. This appears to be a problem in transcribing the information r
from the log books into the yearly reports. The licensee does evaluate
all scrams and rundowns and documents causes in the log book. l
No violations or deviations were identified,
y 16. Violations for Which a " Notice of Violation" Will Not be Issued
a, I- The NRC uses the Notice of Violation (NOV) as a standard method for !
' formalizing the existence of a violation of?a legally binding requirement.
However, because the NRC'wants to encourage and support licensees'
initiatives for self-identification and correction of problems, the NRC
'
i' L will not generally issue a NOV for a violation that meets the tests of - l 10 CFR 2, Appendix C, Section V.G.1. These tests are: (1) the violation l
.was. identified by the licensee; (2).the violation would have been
categorized as Severity 1.evel IV or V; (3)'the violation was reported
I to the NRC, if required; (4) the violation-will be corrected, including ,
measures to prevent recurrence, within a reasonable time period; (5) it-
' l- was not a. violation that could reasonably be expected to have been l' prevented by:the licensee's corrective' action for a previous violation. ;
A violation.of regulatory requirements identified during the inspection
'
L H for which a NOV will not be issued is discussed in Paragraph.8.
17. Exit. Interview (30703)
The inspectors met with licensee representatives denoted in Paragraph 1
during'and at the conclusion of the inspection on August 14, 1990. The.
y inspector summarized the scope and results of the inspection and discussed
the likely content of this inspection report. :The licensee acknowledged.
the information and did not indicate that any of the information disclosed. +
during the inspection could be considered proprietary in nature.
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