ML20059K656

Notice of Violation from Insp on 930923-30.Violation Noted: Licensee Failed to Comply W/Listed Procedures

ML20059K656
Person / Time
Site:	Neely Research Reactor
Issue date:	11/01/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059K649	List: IR 05000160/1993002 ML20059K644 ML20059K656
References
50-160-93-02, 50-160-93-2, NUDOCS 9311160137
Download: ML20059K656 (3)

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ENCLOSURE 1 -

NOTICE OF VIOLATION Georgia Institute of Technology Docket No: 50-160 Atlanta, Georgia License No.: R-97 During an NRC inspection conducted September 23-24 and 27-30, 1993, apparent violations of NRC requirements were identified. In accordance with the  ;

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 '

CFR Part 2, Appendix C, the violations are listed below:

l. Technical Specification 6.2.e(11) requires, in part, that the Nuclear Safety Committee audit the retraining and requalification program for  ;

the operating staff at least once every other calendar year (interval between audits not to exceed 30 months).

Contrary to the above, the Nuclear Safety Committee was not conducting -

this audit, in that the Nuclear Safety Committee had delegated this-auditing function to the Manager, Operational Radiation Safety.

This is a Severity Level IV violation (Supplement I.D).

2. Technical Specification Section 6.4.b(6) requires that the procedures be provided and utilized for radiation and radioactive contamination control.

Procedure 9250, " Facility Contamination Surveys, Revision 4," dated  :

August 13, 1992, establishes the guidelines used by the licensee for ,

conducting and documenting the routine radiation survey program for the l Neely Nuclear Research Center (NNRC). Step 5.2.8 of the procedure requires that routine neutron radiation surveys shall be performed in ,

the general areas of the reactor building when the reactor is operating  :

at a level of 2: 1 megawatt. In the reactor building, neutron  ;

measurements shall also be made during insertion and removal of experiments in the reactor. Appendix A of the procedure specifies a ,

requirement that a semi-annual neutron radiation survey be conducted .in  !

the containment. l Procedure 9304, " Routine Facility Radiation Surveys, Revision 2," dated June 25, 1992, specifies the frequency and location of the contamination surveys to be performed. Appendix A of the procedure' specifies that contamination surveys of the entry / exit points in the Reactor Control  !

Zone of all containment step-off-pads, of all- containment building '

pathways, and of the top of the reactor, are to be performed at a frequency of twice per week.

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I 9311160137 931101 PDR ADDCK 05000160 j G PDR,

Enclosure 1 2 Procedure 9510, " Radioactive Material Shipment, Revision 0," dated March 21, 1991, requires in Step 5.2.2.4 that Form RS-87 be completed appropriately. Step 5.2.8.5 requires that radiation level readings for each package and the vehicle shall be documented on Form RS-28. Step 5.2.9.1 requires that contamination control data be documented on Form RS-28. Step 6.2 requires that Forms RS-28 and RS-35, which contain the survey data for the shipments, shall be maintained along with the shipping papers for the life of the facility.

Contrary to the above, the licensee failed to comply with (1) the procedure requiring specific radiation surveys be performed, (2) the procedure requiring that various bi-weekly contamination surveys in the

. Reactor Control Zone be performed, (3) the procedure requiring that Forms RS-87 be completed appropriately, and (4) the procedure requiring that survey data for shipments be maintained with the shipping papers in that,

a. During 1993, no routine neutron radiation surveys were performed when the reactor was operating at a level of 2: 1 megawatt, neutron radiation surveys were not performed for experiments inserted or removed from the vertical beam ports, and no semi-annual neutron radiation surveys were performed.

b. During 1993, the first of the two required twice-weekly contamination surveys were not performed during weeks when a holiday fell on a Monday.

c. The shipping r. apers for Radioactive Material Shipment Numbers 93-05, 93-08, and 93-10 were completed but contained the incorrect shipping name or an incorrect material identification number for the radioactive material being shipped.

d. The shipping papers for Radioactive Material Shipment Numbers 93-01, 93-04, and 93-05 did not include the survey data for the packages being shipped.

This is a Severity Level IV violation (Supplement IV).

3. 10 CFR 7: requires each licensee who transports licensed material outside the confines of its plant or other place of use to comply with the applicable requirements of the Department of Transportation (DOT) in 49 CFR Parts ;70 through 189.

49 CFR 172.202(d)(3) requires that the description for a shipment of radioactive material must include a description of the physical and chemical form of the material, if the material is not in special form. j

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Enclosure 1 3

49 CFR 172.604 requires that a person (organization) who offers a I hazardous material for transportation, must provide a 24-hour emergency -

response telephone number, that is monitored at all times the hazardous material is in transportation, for use in the event of an emergency ,

involving- the hazardous material. '

Contrary to the above, the licensee failed to provide the proper i description of the radioactive material being shipped and failed to '

include an adequate emergency telephone number on the shipping papers in that, of all the radioactive material shipments the licensee made during-1993, none contained a description of the chemical form of the material and the emergency telephone number provided on the shipping papers was that of the reactor control room which was not monitored 24-hours a day.

This is a Severity Level IV violation (Supplement V). '

Pursuant to the provisions of 10 CFR 2.201, Georgia Institute of Technology is hereby required to submit a written statement or explanation to the U. S. i Nuclear Regulatory Commission for items 1, 2, and 3, ATTN: Document Control Desk Washington, DC 20555, with a copy to the Regional Administrator, Region II, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be cleark marked as a " Reply to a ,

Notice of Violation" and should-include for each v1olation: (1) the reason i 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 i' date when full compliance will be achieved. If an adequate reply is not received in the time specified in this Notice, an order or Demand for Information may be issued as to 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 shown, consideration will be oiven to extending  ;

the response time. t i

a Dated this at /Atlanta, day ofGeorg)r A edt , 1993 i

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