ML20066L353

Responds to NRC Re Violations Noted in Insp Rept 50-199/90-02 on 901210-12.Corrective Actions:Gamma Monitors Will Be Calibr Against Calibr Survey Instruments Using Outside Source Prior to Loading Low Enriched Fuel

ML20066L353
Person / Time
Site:	05000199
Issue date:	01/28/1991
From:	Berlin R MANHATTAN COLLEGE, RIVERDALE, NY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9102070005
Download: ML20066L353 (3)

Text

. _ _ _ _ . _ - - _ - . - - _ - . _ - _ _ _ - _ _ _ _ _ _ - _ - _ - _ _ _ -

1. +

ManheMan MANHATTAN COLLEGE PARCIWAY MECHANICAL ENOf4EERING DEPARTMENT RIVERDALE, NEW YORK 10471

.. (212) 920-0145 January 28,1991 4 U. S. Nuclear Regulatory Commission A*ITN: Document Control Desh Washington D.C. 20555 Reolv to a notite of violation

Subject:

Manhattan College Zero Power Reactor (MCZPR)

Docket No. 50-199, License No. R 94 Inspection No. 50-199/90 02 Letter, J. Joyner, NRC to R. Derlin of December 27,1990 Gentlemen: a Your letter of December 27,1990 transmitted, as enclosure A, a notice of violation iuenti-fying two violations of NRC requirements, and inspection report no. 50-199/90-02 documenting )

the results of an inspection performed on December 10-12,1990. The inspection report noted the existence of "several weaknesses" in our radiological protection and measurements program in addition to the two violations. The violations and weaknesses and our potential actions to cor-rect bcse situations were discussed at a meeting at Manhattan College on January 7,1991. This reply responds to the two violations; our actions to correct the weaknesses in the program are discussed in a separate response.

Violadon A "The two radiation monitoring channels of the Radiation Monitoring System had not been calibrated for at least the last three years". This violates MCZPR Technical Specifica-tion 4.7.3.A "" Radiation Monitoring System" that requims that a calibration of these two radi-ation monitoring channels be performed at least annually.

Reply:

1; The Reason For The Violation - The situation was originally noted as a " weakness" in the program in the inspection report 50199/87-02 prepared by Mr. S. Sherbini dated 11/23/87. As discussed in this report, and recently verified in conversation with him, the famier chief reactor supervisor Dr. Hu stated that he conducted operability and calibra-tion test of the two gamma radiatior monitors " regularly" but did not record this fact in the log. .However, as Mr. Sherbini's inspection report indicates (and discussed in our meeting of January 7,1991), calibrations are conducted near the low end of the scale on the monitor channels (up to 1.5 mr/hr) and it was suggested they be performed at higher dose rates (to at least the 6 mr/hr and 10mr/hr trip points for the two instruments)

/

- 9t02070005 910128 I ADOCK 05000199 l v s {DR ..

PDR

'V In response to this weakness noted by Mr. Sherbini, our consulting health physicist Dr.

Malsky developed a proposed approach pennitting calibration at higher dose rates which was dhcussed with Mr. Sherbini on the phone and transmitted in a letter dated 11/13/87 from Dr. Hu. No response was received. Subsequent inspections by the NRC did not note the uistence of this item as a weakness until the inspection performed by Mr. Austin on Dece.mber 10-12,1990 which resulted in the issuance of this violation.

Further, the reactor he not had fuel in it since November 1989. Thus no operation other than mainte. nance has been perfonned since that time. We are proceeding to cor-rect this violation.

2. Corrective steps that have been taken - the portable survey instruments have been cali-brated at NDL during January,1991, and arrangements have been made through our health physicist to use a source of sufficient strength to provide the calibration up to at least the T.S. trip points for the instruments. This approach will only be used prior to loading of the new LEU fuelin February. Actions have been initiated to obtain our own source to permit future calibrations at the higher dose rates.

3. Corrective actions that will be taken as noted above, the gamma monitors will be cali-brated against the calibrated survey instruments using an outside source prior to r.he loading of the LEU fuelin February. This procedure will be documented in the Log Dook. The necessary license will be obtained and a source purchased for future calibra-tions of the monitors. The calibration will be performed at least annually, with the next calibration done no later than January 1992. All future calibrations will be documented in the Log Book.

4. Date When Full Compliance Will Be Achieved - compliance with the T.S. n:quirements will be achieved with the calibration to be performed prior to the February fuel loading.

We understand that 2-3 months may be required to obtain our own calibration source.

' Violation m "--- the Reactor Operations Committee had not caused a biennial audit to be per-

, - formed by an outside individual or group familiar with the research reactor operations within at least the last thn:e years".

l Reply

. 1. Reason for the Violation - The audit has not been conducted in part because the Reactor has not been operable for an extended period during which maintenance was being con-ducted. Personnel changes were also made in the position of Chief Reactor Supervisor and membership on the Reactor Operations Committee (ROC). It was felt that the audit l _ could be deferred until a more stable situation existed.

l l

-e e I

2. Corrective Steps That Have Been Taken - Arrangements have been made for Mr. Wil-Ilam G. Ruzicka of Consolidated Edison's staff at Indian Point 2 to conduct the audit during February,1991. Mr. Ruzicka is a highly qualified individual who was formerly Manager of Nuclear Operations at Cintichem. lie is quite familiar with reactor opera-tions audit procedures and safety requirements and is curn:ntly a Management Opera-tions Analyst at Con Edison.

3. Corrective Steps That Will Be Taken Mr. Ruzicka will conduct an audit of the safety aspects of reactor facility operations and prepare a report to the ROC documenting the results of the audit. The ROC will review the audit report and assure that its findings are implemented through corrective actions or are eatisfied through further explanation or documentation. Responses to the audit report will be documented and provided to Mr.

Ruzicka. Both the audit and documented response will be kept on file for NRC review during subsequent inspecticas.

4. Date When Full Compliance _Will Be Achieved - The initial audit will be completed by Mr. Ruzicka by the end of February,1991. Subsequent audits will be conducted at no greater than biennial intervals.

I believe the actions described above should result in elimination of violations A & B.

Please let us 1:now if further action or clarification is required.

Sincerely, r ,

Ih Robert E. Berlin Reactor Administrator cc. Regional Administrator, Region 1 M. Austin, NRC Inspector, Region 1 U. S. Nuclear Regulatory Commission Region 1 475 Allendale Road King Prussia, Pennsylvania 19406 Dr. William Duggan Dr. Vincent Antonetti Dr. Joseph Lestingi .