ML20151G337

Responds to NRC Re Violations Noted in Safety Insp of Facility.Citation Improper & Should Be Dismissed Based on Inspector Using out-of-date Procedure SOP 600 & Treating SOP Matters as Tech Spec Matters

ML20151G337
Person / Time
Site:	University of Missouri-Rolla
Issue date:	12/22/1987
From:	Bolon A MISSOURI, UNIV. OF, ROLLA, MO
To:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20151G331	List: ML20151G328 ML20151G337
References
NUDOCS 8804190337
Download: ML20151G337 (2)

Text

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Nuclear Reactor Facihty UNIVERSITY OF MISSOURI ROLLA Nuclear Reactor Rolla. Missouri 65401-0249 December 22, 1987 Oc .aet No. 50-123 Mr. W. D. Shafer. Chief Emerg ency Preparedness an Radiological Protection Branch U.S. Nuclear Regulatory Commission l Region III 799 Roosevelt Road Glen Ellyn. IL 60137 l

l Dear Mr. Shafer l

l This letter ; ef ers to your letter dated November 24 1987, which i was concerned with a Notice of Violation of the same date, which resulted from a routine safety inspection conducted by Mr. W. J. l Slawinski on October 28-30, 1987.

It is our contantion that the citation is not proper and.

therefore, should be dismissed for the following reasons:

1. The inspector used as a basis for the citation an out-dated version of SOP 600. The one currentiv in effect i is dat ed June 19. 1985. That revision has the word "or" l omitted from item B(4) immediatelv before the last phrase "while handling r adioact ive mat er ials . "

There are only two official, controlled copies of the ,

Standard Operating Procedures for our facility. Copy 1 is kept in tae control r oom and Copy 2 i' kept in the lobby.

During his inspection, Mr. Slawir ski was provided with a copy of SOP 600 dated June 19. 1985. bat he apparently did not use it when he compiled his findings.

2. SOP 600, entitled "Laboratorv Rules", pertaine to the situation when irradicted materials are being handled in the bay area. At the frieker station (referred to in i SOP 600) a visible sign is posted which reads: "All i

personnel who have handled radioactive materials must check for possible contamination prior to exiting the bay area." At the time the inspector visited the facilitv. no laboratory or maintenance work involving irradiated materials was in progress in the bay area.

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Page 2 Therefore, according to the SOP 600, the personnel were not required to use the frisker station. We explained the above interpretation of the SOP 600 to the NRC ia-spector during the exit interview.

3. As a point of clerification we will add to SOP 600 in the purpose. "These rules apply to students in the laboratory courses, such as NE 304 and 308, as well as other persons (including reactor staf f ) who are ir-radiating samples or are counting irradiated samples.

To item 15 of SOP 600 we will add the introductory phrase in order to clarify the policy. "All personnel who have handled radioactive materials must' (rest the same -- "always use the frisker station when leaving the bay area.")

4. The NRC inspector states in point 16C. regarding his exit interview. "Acknowledged the inspector's comments regarding failure to adhere to SOP 600. "Laboratory Rules", and that this represents a technical specifica-tion violation (Section 7).

Those or us who were present simply listened to his presentation. We did not acknowledge that this matter represents a 'echnical specification violation.

As a matter of fact, we are seriously concerned that he has treated SOP-related matters as though they were Technical Specifications.

Thus, we helieve that the Notice of Violation shoul.1 be dismissed.

Sincerely.

. b Albert E. Bolon l Reactor Director AEB/1p Signed before me this 22nd day of December, 1987.

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