ML20126B230

Responds to Violations Noted in Insp Rept 50-128/92-02. Corrective Actions:Mgt Overview Program Database Created for Tracing Biennial,Annual & Semiannual Routes to Ensure Timely Completion & Limited Access Badge Documentation Upgraded

ML20126B230
Person / Time
Site:	05000128
Issue date:	12/07/1992
From:	Hall K TEXAS A&M UNIV., COLLEGE STATION, TX
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212220017
Download: ML20126B230 (4)

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j ljNGINEERING PROGRAM THE TEXAS A&M UNIVEllSITY SYSTEM j m m a uw, m , , m n. ,a o m . tm m u,-, ..., . t. u sa..... s 3 ne . . im .,n nu December 7,1992 U. S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, D.C. 20555 Docket No: 50128, License R-83

SUBJECT:

Licensee Reply to Notice of Violation dated . November 5,1992 (NRC INSPECTION REPORT 50-128/92-02)

Dear Sir:

The following response is submitted by the Texas Engineering Experiment Station (Licensee), a part of the Texas A&M University System in regard to the notice of violation issued on November 5,1992 by the U. S. Nuclear Regulatory Commission, Region IV Office.

Stated Violation A. Texas A&M University license condition II.C states in part that the license is subject to the conditions specified in 10CFR 50.59.10CFR 50.59 staMs that the holder of a license authorizing a production or utilization facility may make changes in the facility as described in the safety analysis report without prior Commission approval, rnless the proposed change involves an unreviewed safety question.

l Contrary to the above, between October 1991 and September 21,1992, the licensee made changes to the reactor building ventilation system by incorporating the exhaust system of the fume boods located in the laboratory annex without performing an analysis to determine if (1) the probability of the occurrence or the consequences of an accident or malfunction of equipment related to safety may be increased, (2) the possibility for an accident or an equipment malfunction of a different type other than previously evaluated may be created, or (3) the margin of safety as defined in the basis for any technical specifications is reduced.

Licensee Resoonse A. The licensee admits to the modification of the reactor building ventilation system.

It is the NSC management's opinion that this modification was approved under Modification Authorization (MA) #37 " Installation of an exhaust system for chemical hoods located in the NSC Laboratory building". Slight changes were l

made to this system to improve airflow and system balance. MA #37 states "The 21-143 9212220017 921207 ADOCK 05000128

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Page 2 NRC December 7,1092 hazards associated with the above modification have been reviewed by the staff of the Nuclear Science Center. It is concluded that the proposed modification does not constitute a change in Technical Specifications and is not an unreviewed safety question. It is concluded that this modification will not increase the probability of occurrence of an accident previously analyzed in the Safety Analysis Report and does not increase the probability of a nuclear accident of a different type to be created." The MA is signed by a member of NSC management and a representatise of the Rev: tor Safety Board. Since, MA-37 already existed, the NSC management felt that this upgrade of the approved modification did not requin: an additional MA be created.

corrective Action A. Since the inspection, the NSC management team has reviewed all the Modification Authorizations and determined that for some of these mas the documentation is not complete. Therefore, the NSC management staffis in the process of reviewing all of the existing mas against the 10CFR 50.59 criteria and adding the documentation associated with these reviews to the mas.

Smted Violation B. Technical Specification 6.2.4 states that the Reactor Safety Board or a subcommittee thereof shall audit reactor operations at least quarterly, not to exceed 4 months. Audits shallinclude, but are not limited to: facility operations, the retraining and te qualification program for the operating staff, the facility security plan and records, and the reactor emergency plan. Intervals between audits shall not exceed 15 months. Contrary to the above, the Reactor Safety Board performed no audits during the fourth quarter of 1991 or during the first and second quarters of 1992. The program for the retraining and re qualification of operating staff was not audited between January 1991 and September 1992. The facility security plan and records were not audited between April 1991 and September 1992.

Licensee Resnonse B. The licensee admits that the audits were not performed as required by the Technical Specifications. It is the opinion of the NSC Management that the root cause of the problem was structure of the management tracking system. The system used prior to 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 reorganization of the NSC and the appointment of a new Director, in September 1991, these items were not tracked to completion.

Corrective Action B. The licensee has created a Management Overview Program (MOP) database for tracing biennial, annual and semiannual routines to ensure their timely completion.

This database will be administered by the Administrative Services Staff. The RSB audits have been added to this tracking system.

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NRC December 7,1992 i State Violation C. 10CFR20.203(f) rec uires that each container of licensed material shall bear a durable, clearly visi 31e label identifying the contents and shall bear the radiation caution symbol and the words, " CAUTION, RADIOACTIVE MATERIAL" or

" DANGER, RADIOACTIVE MATERIAL" Licensee Resnonse C. The licensee admits to having three bags of unmarked waste placed in a temporary radioactive waste storage area. The storage area was a apropriately marked as a radioactive materials area and the building was securec , with a door lock and a padlock. The only members of the NS . staff who have keys to this building were the Health Physics staff and the Materials Control staff. Evaluation of the waste handling process, indicated a difference in interpretation of the procedure regarding the temporary storage of waste.

Corrective Action C. As a res it of the evaluation, the waste handling 3ractices have been changed to ensure that the waste is tagged in accordance wit i the procedures. The SOP referenced above will also be revised to eliminate wording which resulted in the difference in interpretation. Of the three bags noted in the inspection, two of these bags were filters which had recently been removed from our air handling units.

These filters were waiting survey to verify that there was no radioactive material detectable. These filters were stored in the temporary waster storage area, because it is a secure area. In the future other storage locations will be used.

Stated Violation

. D. 10CFR19.12 requires, in part, that all individuals working in or frequenting any l portion of a restricted area be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portion of the restricted area, and that the individuals shall be instructed in the health protection problems associated with exposure to such radioactive materials or radiation and in precautions or procedures to minimize exposure. Contrary to the above, experimenters and custodial staff members who had access to the reactor building and laboratory buildings during August 1992 were not given proper instruction.

Licensee Resoonse D. The licensee admits to having improper documentation of the instruction given to blue badged (full access /expen,menter) and pink badged (limited access / physical plant) personnel. The NSC management staff believes that all the badged personnel were trained in accordance with 10CFR19.12 criteria, but the documentation was not complete. For example, Keith Carsten, the blue badge example, is a member of the Office of Radiological Safety's staff.

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. NRC December 7,1992

Corrective Action D. The NSC management staff has audited all the pink and blue badge records and

pulled all badges of those persons not having documentation on file at the NSC which indicates that they were trained in accordance with the 10CFR19.12 criteria.

l The NSC has also upgraded that documentation for limited access (pink) badges.

We have created an internal form (822) which indicates the topics in which a limited access person must be trained, and requires the person to initial each section to indicate training in that topic was received. The individual being trained and the

manager providing the training must both sign the completed form. The form is i given to the Administrative Services Group for filing and the badges are then issued. In addition, an annual audit of the pink an blue badges has been added to the Management Overview Progmm tracking system.

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

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! Respectfully submitted,

! M i Kenneth R. IIall

Deputy Director i Texas Engineering Experiment Station KRH:cee xc: K. L Peddicord, Director i Texas Engineering Experiment Station

Texas A&M University Feenan Jennings, Chairman Reactor Safety Board Texas A&M University W. D. Reece, Director

~i Nuclear Science Center Texas A&M University Milton E. McLain, Director Office of Radiological Safety Texas A&M University U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza. Suite 400

- Arlington,TX 76011 ATIN: John '",Greeves, Acting Director DivL.on of Reactor Safety and Safeguants

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