ML20150F339
| ML20150F339 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 07/12/1988 |
| From: | Elleman T North Carolina State University, RALEIGH, NC |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807180246 | |
| Download: ML20150F339 (4) | |
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North Carolina StateUniversity School of Engineering Departrnent of Nuclear Engineering Boa 7909, Raleigh, NC EM67909 July 12, 1988 Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C 20555 Subj ect: REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-297/88 03 Gentlemen:
In response to your letter dated June 13, 1988, transmitting the referenced Inspection Reports and a Notice of Violation, the attached written statements are submitted regarding the alleged violations pursuant to the provisions of 10 CFR 2.201 as stated in Enclosure of your letter.
If there are any questions in this matter, please advise.
Sincerely, lh,kflA Mill A Thomas S. Elleman Head, Nuclear Engineering TSE:edt cc:
(1) Nuclear Regulatory Commission Region II Mr. J. Nelson Grace Regional Administrator Atlanta, Georgia 30323 l
(2) Nuclear Regulatory Commission Region II Paul E.Fredrickson Section Chief Reactor Project Section lA Division of Reactor Projects Atlanta, Georgia 30323 (3)
Dr. Bernard Wehring
@O l Director, Nuclear Reactor Program North Carolina State University
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PDR ADOCK 05000297 -
O PNV North Carolina State University is a land. Grant University and a cornstituent irsstatution of The Urtiversity of North Carolin.t
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l Nuclocr Rsguletory Commiccion Page Two July 12, 1988 (4) Garry Miller Associate Director, Nuclear Reactor Program North Carolina State University (5)
Dr. Hayne Palmour Chairman, Reactor Safeguards Advisory Group North Carolina State University (6)
Dr. John Roberts Chairman, Radiation Protection Council North Carolina State University (7) William D. Morgan Radiation Protection Officer North Carolina State University
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Reference:
NRC Inspection Report No. 50-297/88-03 1.
STATEMENT OF VIOLATION Technical Specification 6.2.7 requires that the Reactor Safeguards Advisory Group (RSAG) meet ac least every six calendar months.
Contrary' to the 'above, RSAG did not meet during the period April 8,1987 to February 2S, 1988.
This is a~ Severity Level V Violation (Supplement I) 2.
RESPONSE
a) Admission or Cenial of the alleged violation The violation is admitted.
b) The reason for the violation if admitted We submit that the violation, while it exists, is of purely a technical nature and does not properly reflect the high degree of competence and ndividual RSAG members have invested considerable level of effort that i in this important function. In fact, when viewed over a broader time frame, the number of formal RSAC meetings per year results in a fre-quency of meetings considerably shorter than the six month required interval.
At North Carolina State University it has always been considered important to insure that the RSAG membership collectively represent two key elements - - the first being an assemblage of the relevant technical competencies and the second being demonstrable independence from the reactor program per se,. This has been-traditionally accom-plished by appointments of experienced, senior faculty members drawn f rom related departments such as Physics, Materials Engineering, Chemistry, etc. The pool of such persons having specific knowledge of the PULSTAR Reactor has declined in recent years due to attrition, rc-tirement, death, etc.
Those who remain and now serve are very senior faculty with many other administrative, teaching, and research dutles.
As a result, it has become more and more difficult to schedule effective RSAG meetings with the needed full attendance. This was a particularly acute problem during the last half of 1987. For example, Dr. Hayne Palmour, who took over as RSAG Chairman on 1 July 1987, then had to devote one full month to administrative duties within his own depart-ment, took two weeks of vacation, resumed academic duties in mid-August, and during the fall semester was away from campus on travel status for a total of 33 days (this included four dif ferent trips, one of which was for a 3\\ week period for professional meetings around the world).
The other current RSAC members have generally similar complex scheduling problems.
c) Corrective steps which have been taken and the results achieved See Item d) below.
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Reference:
NRC Inspection Report No.- 50-297/88-03, continued d) Corrective stops which will be taken to-avoid furtherl violations To facilitate-timely scheduling of RSAG activities'that effect techr.lcal
. specification compliance directly, it has bean established that such RSAG meetings will be scheduled bytthe. Manager of Nuclear Operations.
This will. insure that this audit activity is kept on the same master scheduling' list as are all other surveillance' activities.. Such meetings.
will normally take place in Apri1~and October of each. year ~During the transition to the preferred schedule, an appraisal visit will also;take place during July or early-August 1988 to insure a continued meeting frequency within the six month interval. All other RSAG-technical review and advisory functions will continue to be based on Radiation Protection Council requests as coordinated through the Radiation Protection Office.
The larger problem of insuring a continued pool of qualified RSAG members in the future will be an agenda item for a Radiation Protection Council meeting during the fall semester of 1988. Input will be obtained from the current RSAG, the Nuclear Reactor Program, and the University Administration.
e) The date when full compilance will be achieved Based upon the current meeting schedule, full compliance has been realized and by institution of the new scheduling mechanism, it will be maintained.
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