ML20059H625
| ML20059H625 | |
| Person / Time | |
|---|---|
| Site: | Idaho State University |
| Issue date: | 11/04/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059H608 | List: |
| References | |
| 50-284-93-01, 50-284-93-1, EA-93-232, NUDOCS 9311100148 | |
| Download: ML20059H625 (36) | |
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APPENDIX B NOTICE OF DEVIATION Idaho State University Docket:
50-284 Idaho State University Reactor Facility License:
R-110 EA 93-232 During an NRC inspection conducted on August 2-6, 1993, a deviation from a commitment made during an NRC Inspection in December 1991 was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action",10 CFR Part 2, Appendix C, the deviation is listed below:'
During the exit meeting on December 12, 1991, following NRC Inspection 50-284/91-01, the licensee committed to establishing written agreements with offsite response organizations with regard to their responsibilities in the event of an emergency. The commitment was documented in the NRC inspection report transmittal letter dated January 9,1992, and Section 12 of the enclosed report of the inspection.
Contrary to the above, as of August 6,1993, the licensee had not established letters of agreement with offsite response organizations.
Please provide to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, in writing within 30 days of the date of this Notice, the reason (s) for the deviation, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further deviations, and the date when your corrective action will be completed. Where good cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas, this 4th day of November 1993 pj!! 024g 9333g4 G
DDCM 05000284 PDR
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ENCLOSURE 3 ENFORCEMENT CONFERENCE ATTENDEES OCTOBER 8, 1993 NRC D. D. Chamberlain, Deputy Director, Division of Radiation Safety and Safeguards Blaine Murray, Chief, Facilities Inspection Programs Section M. M. Mendonca, Project Manager IDAHO STATE UNIVERSITY Dr. M. C. Gallagher, Academic Vice president Dr. V. H. Charyulu, Reactor Administrator R. D. Clovis, Reactor Supervisor Dr. T. F. Gesell, Radiation Safety Officer F. H. Just, Chairman, Reactor Safety Committee
ENCLOSURE 4 NRC-ISU ENFORCEMENT CONFERENCE October 8,1993 INTRODUCTION AND BACKGROUND CHRONOLOGY OF REACTOR SUPERVISORS Mr. David Lavinskas 07/88-08/90 Dr. Albert Wilson 08/90-12/91 Dr. Kevan Crawford 12/91-03/93 Mr. David Clovis 03/93-Pres.
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GENERIC CAUSES FOR APPARENT VIOLATIONS LACK OF:
EFFECTIVE COMMUNICATIONS GOOD TRACKING SYSTEM DOCUMENTATION NEED TO IMPLEMENT IMPROVED MANAGEMENT CONTROL w.
.i PROPOSED CORRECTIVE ACTION'S t
i IMPROVE COMMUNICATIONS THROUGH:
REGULAR STAFF MEETINGS BETWEEN REACTOR ADMINISTR AT OR AND REACTOR SUPERVISOR (RS)
REACTOR SUPERVISOR TO MAINTAIN A LOG BOOK OF STAFF MEETINGS 4
MONTHLY REPORTS FROM AND TO REACTOR SUPERVISOR
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PROPOSED CORRECTIVE ACTIONS DEVISE A TRACKING SYSTEM THAT IS EASIER TO IMPLEMENT REACTOR SUPERVISOR HAS DEVISED A TRACKING SYSTEM WHICH HIGHLIGHTS THE REQUIRED REGULATORY ITEMS NEEDING ATTENTION, IN A TIMELY MANNER.
MONTHLY REPORTS FROM RS WILL PRIMARILY BE BASED ON ITEMS FROM THE TRACK-CHART.
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PROPOSED CORRECTIVE ACTIONS DOCUMENTATION RECORD RADIATION SURVEY RESULTS RECORD TRANSFER OF BYPRODUCTS MATERIAL TO AUTHORIZED USERS RECORD ANY AUTHORIZED CHANGES TO THE PROCEDURES AND/OR EXPERIMENTS
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SUGGESTED OUTLINE FOR MONTHLY REPORTS A.
ITEMS TRACKED AND COMPLETED:
B.
ITEMS BEING TRACKED:
C.
ITEMS DUE FOR TRACKING DURING NEXT MONTH:
D.
RESPONSE (S) NEEDED FROM:
O CHAIR-RSC O
SRO's - NAMES O
RO's - NAMES i
O REACT. ADMINISTATOR O
RSO I
O OTHER (such as RSC or other faculty users)
E, OTHER ITEMS OF INTEREST /IMPORTANCE:
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- 284/9301-01 REQUIREMENT:
Technical specification 6.3 requires that all licensed operators participate o
in the requalification program.
o A member or members of the Reactor Safety Committee cberic the operation of the reactor by each licensed operator or senior operator at least once during each calendar year.
APPARENT VIOLATION la:
The Reactor Safety Committee (RSC) had not administered tests to a o
senior reactor operator and two rea;. tor operators from Nov 91 to the time of this inspection.(Aug 93) 4
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i BACKGROUND:
o The SRO, who was also the Reactor Supervisor at that time, expressed that the Reactor Supervisor did not have to take the requalification exam as per the NRC approved requalificaton program at the University of Utah where he was maintaining a valid SRO license.
o The two RO's were scheduled to take an NRC administered up-grade exam in Nov '92 which they successfully completed 'on Nov 3,1992.
The Reactor Supervisor interpreted the upgrade to SRO from RO for these two operators as having fulfilled the intent of the requirement.
The Reactor Supervisor assumed that he was an ex-officio member of the RSC.
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i APPARENT CAUSE:
The misinterpretation of the requalification program by the previous o
Reactor Supervisor resulted in this apparent violation proposed.
CORRECTIVE ACTION (S) TAKEN:
The former Reactor Supervisor has been replaced and the newly appointed o
Reactor Supervisor very diligently went through the records and discovered the deviation from the requirements and promptly reported his findings to the NRC inspectors.
Further, a new requalification program for the operators has been o
approved by the NRC effective June '93.
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 RSC members are no longer required to-administer the test nor are required to observe the reactor operation by the operators. These duties have been assigned to the Reactor Supervisor.
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APPARENT VIOLATION lb:
The RSC did not observe the operations of the reactor by two senior o
operators and two operators during 1992.
APPARENT CAUSE:
The Reactor Supervisor (RS), had assumed that he was an ex-officio o
member of the RSC. Under his supervision the two's RO's operated the reactor.
The operation of the other SRO, had his run observed under the o
cognizance of the previous RS. Therfore, we were lead to believe that the Tech. Spec. 6.3 was not violated.
PROPOSED CORRECTIVE ACTION:
The previous RS has been relieved of his duties associated with the reactor o
and his license has been terminated.
Further, as explained earlier in la, the new requalification program does not require the RSC to observe the RO's operating the reactor.
Other steps such as tracking and monthly reports should correct this violation from reoccurring.
- 284/9301-02 REQUIREMENTS:
10 CFR 55.21 requires that an applicant for a license have a medical o
examination by a physician every 2 years to determine if the applicant or licensee meets the requirements of 10 CFR 55.33 (a) (1).
APPARENT VIOLATIONS (2):
The failure of the senior reactor operator to have a medical examination o
was identified as an apparent violation of 10 CFR 55.21.
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BACKGROUND:
The SRO under question was on sabbatical leave beginning mid December o
'91 till the month of August '92. He was not present at the facility on a regular basis during his sabbatical leave period.
Since there was no tracking system in place, the RS in charge failed to track the SRO's medical exam requirement.
Subsequently the SRO took the required medical exam, although some what late (in January '93).
CAUSE FOR VIOLATION:
Lack of proper tracking system.
o PROPOSED CORRECTIVE ACTION:
The proposed tracking system will ensure that all the operators will o
complete the physical exam requirement.
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- 284/9301-03 REQUIREMENT:
10.CFR 50.59 " Changes, Tests, and Experiments," states, in part, that a o
licensee may make changes to the facility and experiments not described in the Safety Analysis Report (Hazards Summary Report) without NRC approval, unless the proposed change involves an unreviewed safety question.
APPARENT VIOLATION (3):
The licensee acknowledge that a formal review had not been conducted to o
determine if the modification resulted in an unreviewed safety question and there was no written record of a safety evaluation. The failure to have a written record that determined if Experiment 21 involved an unreviewed safety question is considered an apparent violation of 10 CFR 50.59.
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APPARENT CAUSE:
The licensee was not asked for the information and has been misquoted or o
there was miscommunication between the inspectors and the Reactor Supervisor.
We have extensively reviewed the safety aspects of this particular experiment as reflected in the three theses (partial excerpts are being provided) and also as reflected in the Reactor Safety Committee meetings dating back to October 1971.
CORRECTIVE ACTION:
The RSC, upon recommendation from the RS, changed the procedural o
approval form to ensure that the facility complies with 10 CFR 50.59.
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- 284/9301-04 REQUIREMENT:
" Records," requires that each person who receives byproduct material shall keep records showing the receipt, transfer, and disposal of the byproduct material.
APPARENT VIOLATION (4):
o The failure to keep records of byproduct material transfers is considered an apparent violation of 10 CFR 30.51.
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BACKGROUND:
Although the irradiated samples from the AGN-201 are generally of very o
low radioactivity, it has always been the practice to survey the irradiated samples as soon as they are removed from the reactor.
Because of the relatively low neutron flux levels associated with the AGN-20lM reactor, isotopes produced-have generally been of exempt quantities.
For this reason, exempt quantities of radioisotope were transferred to recipients that did not possess a source material license. Since January 1993, prior to the present inspection, we have ensured that all transfers are authorized.
APPARENT CAUSE:
o Lack of documentation procedure.
PROPOSED CORRECTIVE ACTION:
The RS is currently developing the necessary forms for radioisotope o
production and disposition using pertinent parts of the Idaho State University's Radiation Safety Manual.
A draft of the necessary radioisotope forms will be submitted to the Reactor Safety Committee for their approval at the next meeting.
- 284/9301-05 REQUIREMENT:
10 CFR 30.41, " Transfer of Byproduct Material," states, in part, that no o
licensee shall transfer byproduct material unless the licensee transferring the material has verified that the transferee's licensee authorizes the receipt of the type, form, and quantity of byproduct material to be transf:rred.
APPARENT VIOLATION (5):
The failure to verify that persons receiving byproduct material were o
authorized to receive such material is considered an apparent violation of 10 CFR 30.41.
BACKGROUND:
o Since
- N radiated samples have been of very low activity, it has been the past practice to transfer items without the newly established proper procedutu.
However, since Jan 1993, we have been following the appropriate procedure set forth by the TSO.
APPARENT CAUSE:
Lack of proper procedure in the past.
o CORRECTIVE ACTION:
o As stated earlier in reference to apparent violation #4, new forms and procedures have been devised and will be followed.
- 284/9301-06 REQUIREMENT:
" Records of Surveys, Radiation Monitoring and Disposal," requires that o
each licensee shall maintain records of surveys required by 10 CFR 20.201 (b).
APPARENT VIOLATIONS (6):
o The failure to maintain radiation survey results is considered an apparent violation of 10 CFR 20.401 (b).
APPARENT CAUSE:
Lack of proper documentation procedure in the past.
o PROPOSED CORRECTIVE ACTION:
The newly developed forms, as stated earlier with reference to apparent o
violations #4 and #5, should correct this situation. We will implement this procedure and use the forms.
- 284/9301-07 REQUIREMENT:
10 CFR 20.201(b) " Surveys" requires that each licensee shall make such o
surveys as may be necessary for the licensee to evaluate the extent of radiation hazards that may be present.
APPARENT VIOLATION (7):
The failure to perform surveys of irradiated material removed from the i
o reactor is considered an apparent violation of 10 CFR 20.201(b).
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BACKGROUND:
It has always been a common practice to survey any components removed o
from the reactor, although in the past the activity level was not recorded, since these were oflow level. In particular, the BF Counter has not been 3
removed immediately after an experiment and removed only after the activity has decayed to background level.
Once it is removed, the BF3 counter is surveyed with a E-120N beta, gamma detector and placed on top of the reactor (on the thermal column), with the shield doors closed.
The activity has never been above background.
Experiment #21 makes use of a BF ion chamber to measure reactor o
3 power.
The ion chamber is placed in the thermal column on top of the reactor in lieu of the center graphite stringer. Since the maximum reactor power for Experiment #21 is 4 watts, the shield doors to the thermal column are closed by procedure.
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After Experiment #21 is completed and the reactor shutdown, the ion o
chamber is left in the thermal column until another experiment requires the thermal column configuration to be altered.
This is usually never done immediately.
For the next reactor operation, the startup procedure requires a routine survey of the reactor lab.
This survey requires that radiation levels be taken on contact with the thermal column shield doors and once the shield doors are opened, a radiation survey is performed near the thermal column surface to determine what the radiation levels are before lowering the Nuclear Instrumentation Channel #1 BF proportional 3
counter.
If changes to the thermal column are necessary, operators are aware of the radiation levels on the thermal column. The Eberline 120N beta, gamma detector is present and used to measure radiation levels while changes to the thermal column are made.
The results of the radiation survey are then recorded in the operations log.
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CORRECTIVE ACTION:
Although radiation surveys in the reactor lab are recorded prior to startup o
of the reactor, items inserted and removed from the AGN-20lM reactor experimental facilities should have more detailed comments of appropriate radiation surveys entered into the Health Physics log maintained at the reactor console.
Therefore, all experiments that are removed from the reactor experimental facilities will receive a radiation survey and an entry will be made in said H.P. log. To ensure proper entries are made, drafts of the Operating Procedure (OP) #1 and #2 are being submitted at the next meeting that reflect that operators have entered the necessary radiation survey.
Operators have already been trained regarding proper Health Physics log o
entries and will be trained again with the implementation of approved changes to OP #1 and #2.
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- REQUIREMENT o The training of university personnel who are responsible to act under this emergency plan is the responsibility of the radiation safety officer (Emergency Plan, pg. 20) e APPARENT VIOLATION o Failure of the radiation safety officer to provide training to the reactor administrator Inspection Report, pg. 9)
- EFFECT ON SAFETY o in view of Reactor Administrator's credentials and his experience gained by participation in previous emergency exercises, the safety impact appears to be minimal 0
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e APPARENT DIRECT CAUSE o Requirement for radiation safety officer to train on emergency plan originated when RSO and Reactor Supervisor were same individual o Radiation Safety office was split from Reactor, Fall 1991 New RSO interpreted training requirement as radiological O
control training in support of emergency preparedness, not complete training to the emergency response plan o in any case, RSO. failed to perform a recognized duty by not training the Reactor Administrator in radiological control in support of emergency preparedness o RSO accepts full responsibility for failing to train the i
Reactor Administrator in radiological control 1
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l CORRECTIVE ACTIONS FOR DIRECT CAUSE o The emergency plan will be changed to identify the reactor administrator and the reactor supervisor as responsible for training related to the emergency plan o The radiation safety officer will assist the reactor administrator and the reactor supervisor in radiological control training related to the emergency plan 0 Training will be scheduled and tracked by the Reactor Supervisor l
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- APPARENT ROOT CAUSE t
o Failure to perform a thorough review of duties and responsibilities of the reactor program and the radiation safety officer when the programs were split e CORRECTIVE ACTIONS FOR ROOT CA_USE o All current responsibilities of the radiation safety officer for the reactor program will be reviewed to determine whether they. are appropriate or should be reassigned o Radiological safety aspects of the reactor program will be reviewed to determine if the radiation safety officer should have additional responsibilities and duties l
0 Assignments of duties and responsibilities will be revised if necessary, documented and tracked l
- 284/9301-09 REQUIREMENT:
Technical Specification 6.4.3.a requires that the licensee audit the o
conformance of facility operations to the Technical Specification and applicable license conditions at least once every 12 months.
Technical Specification 6.4.3.b requires that the licensee audit the o
performance, training, and qualifications of the entire facility staff at least once per 24 months.
Technical Specification 6.4.3.c requires that the licensee audit the results o
i of all actions taken to correct deficiencies ' occurring in the facility equipment, structures, systems or method of operation that affect nuclear safety at least once per calendar year.
4 Technical Specification 6.4.3.e requires that the licensee audit the Facility o
Security Plan and implementing procedures at least once per 24 months.
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APPARENT VIOLATIONS (9):
The failure of the Reactor Safety Committee to audit facility operations is o
considered an apparent violation of Technical Specification 6.4.3.a.
The failure to audit the performance, training, and qualifications of the o
facility staff is considered an apparent violation of Technical Specification 6.4.3.b.
The failure to perform corrective action audits is considered an apparent o
violation of Technical Specification 6.4.3.c.
The failure to audit the Security Plan and implementing procedures is o
considered an apparent violation of Technical Specification 6.4.3.e.
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BACKGROUND:
On the Febuary 4,1992 Reactor Safety Committee meeting, the (RS) o presented an Audit and Review Plan that would correct the violations of the December 1991 NRC inspection.
The RSC approved the Audit and Review Plan and the facility agreed to implement this plan by July 1992.
DIRECT CAUSE:
The proposed Audit and Review Plan failed to address that several audits o
were due before the recommended implementation date. Also, the Audit and Review Plan addressed how to preform the audits and nat specifically how to track them.
CORRECTIVE ACTION:
The current RS has developed a tracking system that tracks all of the o
facility's periodic administrative requirements including audits.
The tracking system will be reviewed for accuracy and validity, with comments of the review to be sent to the RSC before the next RSC meeting. A RSC meeting will be called within the next 30 days to act upon the proposed tracking system.
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- 284/9301-10 REQUIREMENT:
o In the exit meeting of the December 12, 1991 NRC inspection, the licensee said that they would obtain letters of agreement with off-site response agencies.
APPARENT DEVIATION:
Failure to comply with a commitment made to oetain letters of agreement o
with off-site response organization resulted in an apparent deviation.
BACKGROUND:
The previous RS began to research the necessary requirements to develop o
letters of agreement. This is evident by copies of the letters of agreement sent to the previous RS from Texas A & M University Assistant Director
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of the Nuclear Science Center Laboratories dated 29 Jan 1992.
After receiving this information, the previous RS failed to complete the o
task of obtaining letters of agreement from off-site emergency response agencies.
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CORRECTIVE ACTIONS TAKEN:
o Draft letters of agreement were hand delivered to Bannock Regional Medical Center, Pocatello Regional Medical Center, Idaho State Police and the City Attorney on Oct 5,1993.
Continued correspondence with these organization will be maintained to finalize the letters of agreement and to maintain emergency preparedness with said agencies.
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