ML20151G409
| ML20151G409 | |
| Person / Time | |
|---|---|
| Site: | University of California - Irvine |
| Issue date: | 04/04/1988 |
| From: | Lillyman W CALIFORNIA, UNIV. OF, IRVINE, CA |
| To: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20151G403 | List: |
| References | |
| NUDOCS 8804190379 | |
| Download: ML20151G409 (3) | |
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f SANTA B ARB ARA * $4NTA CRUZ IC ifa -8 P cp 45 THE VICE CH ANCELLoR 1RVINE. CALIFORNI A 92717 April 4, 1988 Ross A. Scarano, Director U.S. Nuclear Regulatory Cmmission Region V
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1450 Maria Lane Walnut Creek, CA 94596 RE: LCI TRIGA REACW)R - REPLY TO NCfrICE OF VIOLATION DATED March 3,1988 Docket: 50-326, License: R-ll6 Gentlemen:
May we please ask you to correct your records in one point. The correct nane for the Chair of the Chmistry Depart 2nent is Professor M. Caserio, aM not as printed throughout the report.
In regard to the notice, we respond as follows:
Item A.
Monthly maintenance checklists were inccmplete and/or not reviewed j
contrary to Standard Operating Procedures.
(1) As noted to the inspector, this occurred mostly as a result of reassigivnent of responsibilities within the Chenistry Department of the Assistant Reactor Supervisor. An additional factor was the lack of 3 detailed list of itens to review on the part of the Re' Actor Supervisor aM the Radiation Safety Officer (on behalf of the Reactor Operations Connittee (ROC)).
We would wish to note that there is no evidence that the lack of empletion or review resulted in an actual safety problen, or increased the likelihood of a safety-related incident. Most of the checklists relate to items that even if totally non-functional would not contribute to a hazard to perconnel or the cmmunity.
(2) The Reactor Supervisor, Assistant Supervisor, ard the Radiation Safety Officer have met to review the issue. The facility maintenance has been thoroughly checked and any outstanding itens already brotght up-to-date.
(3)
A review sheet is being created that will help to assure thorough review of all checklists during quarterly inspections se that any delinquencies can be brought to the attention of the Reactor Supervisor and the Reactor Operations Cmmittee at quarterly meetings. A review is being made of all checklists to see if the iterns thereon are appropriate. If unneeded itens are to be renoved, this will be done only with approval of the ROC, but may help speed up empletion of such lists.
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(4) We assert that the facility is now in empliance with respect to maintenance and surveillance, and will renain so.
Item B.
Implenentation of the Dnergency Plan failed to meet certain requirenents.
(1)
Rather than review the non-canpliance point by point, we choose to deal with this issue as one involving inadequate attention to review and full implenentation of the plan. Clearly our staff do need to exert more effut in this direction to assure that maintenance of the plan is effective.
(2) The Reactor Supervisor and the Radiation Safety Officer have mat specifically to review this issue. Actions are being taken within the O!f b of Environnental Health and Safety to correct several specific aussions.
(Your itens 1, 5, 6).
With respect to iten B.2, the reactor staff have calibrated the high volune air sampler unit as to air flow. However, the staff are not in agreenent with the inspector that this is an "instranent" in the usual sense of that definition.
It is not our intent that this iten be used for quantitative measurenents at our facility and we do not believe that our procedures imply such use so that strict calibration is felt to be unnecessary, and perhaps misleading. So many innediate factors can affect the parformance of such a sampler, that unless it is calibrated imnediately prior to use in an energency, the data from quantitativc utilization could be seriously in error. We propose only to use this device as a "grab" sampler, aM as such, calibration is really unimportant.
(3) The EH&S Office will schedule a meeting of senior personnel (to include the Radiation Safety Officer, the Reactor Supervisor, the Chief of Police, a M the Public Information Officer) during the month of January each year for the specific purpose of reviewing the status of the Facility Dnergency Plan, and to schedule an annual exercise.
'Ihis review shall include, but not be limited to, the following:
(a)
Mequacy of training for new personnel and docunentation thereof.
(b) Mequacy of retraining and plan familiarization for existing personnel.
(c)
Mequacy of supplies aM equipnent available in support of the plan.
(d) Mequacy of off-site response, aM status of agreenents to provide assistance.
Minutes of this meeting will be made aM retained for future inspections.
Prior to the first of such meetings, the Reactor Supervisor, Radiation Safety staff, and facility personnel will meet on a regular basis to update knowledge regarding the energency plan and review any other itens that need i
correction. One iten for imnediate discussion is planning for a 1988 exercise as a training and test event. Attendance at such meetings will be recorded and reported during quarterly reviews to ROC.
(4) We believe that further efforts are needed to reach full canpliance in this area. As an anticipated level of needed emercency response at a facility such as ours is very low it is not anticipated that this will result in any realistic reduction in safety of operation of the facility.
It is inteMed
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a that all inraediate energency needs be filled at orv.e.
Impleventation of full annual events should be in place by next January 31st (1389).
Your letter of transmittal requests that we cons! der the issue of minaganent oversight. We are of the opinion that this has been addressed within the context of the two specific arr.19 cited. However, the CN!mistry D2partment Chair and the Dean of the School of Physical Sciences are continuing to review this issue.
If significant changes in adninistration are anticipated, we will inform you accordingly.
We hope that this response will enable you to conclude that the UCI facility continuca to operate in a manner consistent with protection of the health and saf2ty of the public. We will be pleased to cooperate in a.ny further way that you see fit.
Sincerely, W
Sor W.J. Lillyman Executive Vice Chancellor cc:
U.S. Nuclear Regulatory Comnission Docunent Control Desk Washington, DC 20555 O
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