ML20096B920

Responds to NRC Re Violations Noted in Insp Rept 50-128/92-01.Corrective Actions:Amend to State of Tx License Requested

ML20096B920
Person / Time
Site:	05000128
Issue date:	04/27/1992
From:	Hall K TEXAS A&M UNIV., COLLEGE STATION, TX
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
92-267, NUDOCS 9205130039
Download: ML20096B920 (3)

Text

-. _ - -- - .._ __- . _ _ - - -

f

. TEX A S E N GIN E ElllN G EX PEltl M E NT STATIO N TEXAS A&M UNIVERSITY COMEGE STATKR TEKAS 77tLO 3575 p' April 27, 1992 Y J L_l NUCLEAR SCIENCE CENTER 409'845 7551 U.S. 11uclear Regulatory Commission 92-267 ATT!1s Document Control liesk Washington, DC 20555 Docket tio 50-128, License R-83 SUBJECT Licensee Reply to tiotice of Violation dated April 9, 1992 (11RC IllSPECTIOli SEPORT 50-128/92-01)

Dear Sir:

The following response is submitted by the Texas Engineering l1xperiment Station (Licensee), a part of the Texas A&M University System in regard to the notice of violation issued on April 9, 1992 by the U.S. Nuclear Regulatory Commission, Region IV office.

hLate,d Violatiga A. Texas A&M University license condition II.B.(3) states

" pursuant to the Act and 10 CFR, Chapter I, Part 30, " Rules of General Applicability to Domestic Licensing of Byproduct Material," to receive, possess and use in connection with operation of the reactor a twenty (20) curie encapsulated plu+. onium-beryllium neutron source and a three (3) curie americium-beryllium neutron source and to possess but not separate such byproduct material as may be produced by operatior, of the reactor." contrary to the license condition the NSC possessed several scaled sources which were not produced by the operation of the reactor.

Licensee Response A. The licensee admits to the storage of radioactive matarial not produced by the reactor at the facility. The Nuclear Science Center staff believed that since they had been issued a sublicense by the Of fice of Radiological Safety (ORS) for the possession of radioactive material at the NSC that this storage of material was. lawful. It was not the NSC management's intention to willfully violated the regulations.

When a sublicense is issued by the ORS, the new licensee dt.cs not commonly receive a copy of the entire university license, b"t rather a notice on what their individual sublicense will allow them. ,

9DP ADOCK 05000126 RESEARCH AND DEVELOVMENT FOR MANKIND G PDR 10

[

t O.C.11uclear Pagulatory Commission 92-267 Page 2 Discussion of the matter with the ORS revealed the following information. In the past, the State of Texas license did not exclude tho 11SC as an authorized storage location. When the OBS had the license amended in 1991, this unsolicited change was made by the State of Texas to resolve the past confusion hatween the 11uclear Regulatory Commission and the State over responsibility for material at the 11SC.

Correct.ive Actioil A. Atter discusteing the issue with the Office of Radiological Safety, it was determined that the most cost offective mothed of resolving the issue was to request an amendment to the State of 'lexas license. This amendment request will be to allow storage of radioactive material not generated by the reactor at the 11SC. A letter requesting this change to the license by the ORS on March 16, 1992. Discussions batween the ORS and the State of Texas indicated this request for amendment will be approved.

Stated Violation B. 10 CFR 50.54(q) requires that a licensee authorized to possess and operate a research reactor shall follow and maintain in effect emergency plans. Section 3.1.11 of the Emergency Plan approved tiovember 1982 requires that fireman be trained annually in the basic principles of radiation protection and the lluclear Science Center emergency procedures. Contrary to the above, the inspector determined that the licensee had not conducted trcining for fire department personnel since September 1990.

Licensee Response B. The licensee believes that the training was performed, but has been unable to locate the attendance sheets to verify performance of the training. The individual responsible for the training left the organization shortly after the period it is believed the training occurred. Since the licensee is unable to locate the verifying paperwork, the finding of violation must be accepted.

It is the opinion of the 11SC management that the root cause of the problem was structure of the management tracking system.

The system used at the time of the inspection consisted of a list of action items kept by the Director which indicated when tasks needed to be completed. With the recent reorganization of the 11SC and the appointment of a new Director, these items were not tracked to completion, including verification that the correct paperwork was filed. Audits by the Reactor Safety

,? <

O.S. Nuclear Regulatory Commission 92-267 Page 3 Board would have disclosed the missing training forms.

Correc11ve Action B. Because the paperwork cannot be found, the licensee has scheduled with the College Station Fire Department to conduct training on the Emergency Plan to all three shifts. These training sessions will be performed on May 12,13 and 14. In addition, the licensee has created a Management overview Pw7 ram (MOP) database for tracking biennial, annual and semianrual routines to ensure their timely completion. This database will be administered by the Administrative Services Staff.

Should there be any questions regarding this reply, please contact me at (409) 845-3357 or Dr. W. D Reece, Director, Nuclear Science Center at (409) 845-7551.

Respectfully submitted,

-Kenneth R. Hall Deputy Director Texas Engineering Experiment Station xc Dr. K. L. Peddicord, Acting Director Texas Engineering Experiment Station Texas A&M University Dr. Feenan Jennings, Chairman Reactor Safety Board Texas A&M University Dr. W. D. Reece, Director Nuclear Science Center Texas A&M University U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza, Suite 400 Arlington, Tx 76011 Attnt John T. Greeves, Acting Director Division of Reactor Safety and Safeguards

__