ML20114B942

Responds to NRC Re Violations Noted in Insp Rept 50-297/92-01.Corrective Actions:Emergency Plan & Procedures Currently Under Review & self-contained Breathing Apparatus Placed on Maint Contract W/Approved Vendor

ML20114B942
Person / Time
Site:	North Carolina State University
Issue date:	08/27/1992
From:	Dudziak D, Mayo C, Perez P North Carolina State University, RALEIGH, NC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9209010001
Download: ML20114B942 (4)

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North Carolina State University 9>)1IUg, i

Noelcar neactoi honram y Department of Nuclear Engineering tw M 27 August 1992 Halemh. NC 56%7tm 1919; 515 4.0 1 l' A\ 1919) 5155115 J

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

REPLY TO NOTICE OF VIOIATION Docket No.: 50-297 License No.: R 120 Refer.mee: Letter, Notice of Vio.ation (NRC Inspection Report No. 50-297/92-01),

dated 31 July 1992.

Dear Sirs:

Pursuant to the provisions of 10 CFR 2.201, North Carolina State University is hereby submitting a reply to the referenced notice of violation. The attached response addresses the reason for the violations and the corrective steps that have been or will'.e taken to avoid further violations.

Should you have any questions concerning this reply, please contact us.

Sincerely yoars, w M. d Pedro B. Perez Associate Director Nuclear Reactor Program kkLJ h o .

Donalil J. Dudziak,'Ph.D.

r s Charles W. Mayo, Ph.D.

g Director, Nuclear Reactor Program Head, Department of Nuclear Engineering cao.

.80 copy w/ attachment:

1Oo g 1. USNRC, Region II, Regional Administrator 9@ 2. Dr. James A. Knopp, Chairman, Radiation Protection Council

- <c o gs 3. Dr. James A. Mulholland, Reactor Safeguards Advisory Group Mr. D. William Morgan, Radiation Protection Officer O$

> 2. e g 4.

[c North Carohna State Unitersity is a land-grant university and a constituent institution of The University of North Carolina.

t 4 4 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT No. 50-297/92-01 NORT11 CAROLINA STATE UNIVERSITY PUIJSTAR REACTOR - LICENSE No. R-120 VIOLATION (A): Severity Level IV

'0 CFR 50.54(q) requires a licensee authorized to possess and/or operate a resemch reactor to follow and maintain in effect an emergency plan.

Part 10.4.1 of the Emergency Plan, Revision 1, dated 1985, requires a biennid review of the Emergency Plan by the Radiation Protection Council.

Contrary to the above, a review of the Emergency Plan had not been conducted by the Radiation Protection Council since 1985, a period exceeding the biennial frequency.

RESPONSE TO VIOLATION (A)

The licensee acknowledges the violation and offers the following reason for the violation and corrective actions to avoid further violations.

The PULSTAR Reactor Emergency Plan, Section,10.4.1, Plan Revision and Update, specifically states:

"The Emergency Planning Coordinator is responsible for coordinating the updating of the Plan and its implementing procedures. He schedules a biennial review by the Radiation Protection Council. Any proposed changes to the Plan due to regulatory revisions, experiences of drills and exercises, or other requirements, are approved by the Radiation Protection Council.

Approved changes to the Plan and Procedures will be distributed to all vertinent organizations and ir N .C als with responsibilities for implementation wihin 30 days of the ro.. . ion. Rwision pages wi2 be marked to sho.v where changes have been made."

The requirement for a biennial review of the Plan by the RPC was interpreted as required only if there were revision made to the Plan. The reasoning for this is that the Plan and Procedures have been reviewed by the Reactor Safeguards Advisory Group (RSAG) during each of their annual audits. The RSAG members are appointed by the Chancellor at the 1

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I . REk LY TO A NOTICE OF VIOLATION NRC REPORT No. 50-297/92-01

, recontmendation of 'he Radiation Protection Council (RPC). The RSAG serves as a

permanent advisory ammittee to the RPC. The results of RSAG audits are reported to the Nuclear Reactor Program Associate Director and to 1.e RPC at its next meeting.

The exact review :equirements of 10.4.1 were not met since the Plan was not submitted to the RPC for review. However, the intent was met since the RPC reviews the RSAG audit results which includes the Plan and Procedures.

The Emergency Plan and Procedures are currently under review. The requirement in 10.4.1 for a biennial review of the Plan by the RPC will be changed in the next revision of the Plan to reflect what actually is performed:

i "The Reactor IIcalth Physicist is responsible for coordinating the updating of the Plan and its implementing Emergency procedures. The Plan will be reviewed biennially by the Reactor Sqfeguants Advisory Gmup (RSAG) during independent appmisals of reactor opemtions. Any proposed changes to the 4

Plan due to regulatory revisions, experiences of drills and exercises, RSAG review comments, or other requirements, are approved by the Radiation 1

Protection Council. Changes to the Plan and Procedures will be distributed to all pertinent organizations and individuals with responsibilities for implementation within 30 days of the approval ofthe revision. Revision pages

will be marked to show where changes have been made."

i The described corrective action will be implemented in Revision 2 of the Plan and submitted to the Radiatiort Protection Council by 1 September 1992 for review and subsequent approval.

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2 REPtX TO A NOTICE OF VIDIATION NRC REPORT No. 50 297/92-01 ,

VIOLATION (B): Severity Level V Technical Specification Section 6.3.a.4 requires that operating procedures pertaining to emergency conditions be written, updated periodically, and followed.

I IIcalth Physics Procedure 1-2, Maintenance of Self-Contained Breathing Apparatus (CCBA),

Revision 0, dated April 1,1989, requires that total system performance checks of the SCBAs be accomplished by either the manufacturer or an approved vendor annually, but at intervals not to exceed 15 months.

Contrary to the above, the licensee failed to comply with the procedures requiring total system performance checks for SCBAs in that maintenance records indicated such checks having been performed only in January 1990 and in March 1992, an interval exceeding 15 months.

RESPONSE TO VIOLATION (B)

The licensee acknowledges the violation and offers the following reason for the violation and corrective actions to avoid further violations.

The PULSTAR Reactor Health Physics Procedure HP 1-2, Maintenance of Self Contained Breathing Apparatus (SCBAL Rev. O, dated 1 April 1989, specifically states in Section 5.1:

" Total system perftm.ance checks will be accomplishea by either the manufacturer or an approved vendor annually, but at intervals not to exceed 15 months."

The required interval was exceeded due to personnel changes occurring during this specific time interval. The SCBAs were due to be inspected on January 1991; unfortunately, this corresponded to the time the Reactor Safety Specialist (RSS) position became vacant. An incorrect assumption was made that the SCBAs were serviced prior to the vacancy.

The SCBAs have been placed on a maintenance contract with an approved vendor. The

. vendor's normal practice is to send reminders to the customer that maintenance is due on the apparatus. In addition, each SCBA wiil have a log sheet on the instrument case showing

• the last maintenance, work performed, and the due date of the next maintenance.These two methods will serve as conspicuous reminders that service is due on the SCBAs. The corrective actions described were placed in effect on 30 July 1992.

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