IR 05000113/1988001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-113/88-01. Corrective Actions Will Be Verified During Future Insp

ML20151H698
Person / Time
Site:	05000113
Issue date:	04/08/1988
From:	Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Smerdon E ARIZONA, UNIV. OF, TUCSON, AZ
References
NUDOCS 8804200477
Download: ML20151H698 (1)

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APR - 81988 Docket No. 50-113 University of Arizona College of Engineering Tucson, Arizona -85721 Attention: 'E. T. Smerdon, Dean College of Engineering and Mines Gentlemen:

Thank you for your letter dated March 29, 1988, in response to our Notice of Violation and Inspection Report No. 50-113/d8-01, dated March 3, 1988, informing us of the steps you have taken to correct the items which we brought to your attentio Your corrective actions will be verified during a future  ;

inspectio Your cooperation with us is appreciate !

Sincerely, C' '

m ' L t F['k.WSNsINwski, Chief  !

Emergency Preparedness and  ;

Radiological Protection Branch bec w/ copy of letter dated 3/29/08:

State of Arizona  :

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G. Cook, RV 8. Faulkenberry, RV J. Martin, R'I docket file LFM8 bec w/o copy of letter dated 3/29/88: '

M. Smith

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T (602) 621-6601 hfarch $ 1988 US Nuclear Regulatory Commission License R-52 Washington DC 20555 Docket 50-113 Attn: Document Control Desk l

L Re: Reply to Notice of Violation This is the response to the Notice of Violation from the unannounced inspection of the University of Arizona Nuclear Reactor Laboratory on January 25-26,1983 by hir. hi. Cillis of your Region V inspection staff. The response was prepared by tha staff of the Nuclear Reactor Laboratory and was reviewed by the Reactor Committee on h1 arch U,1988, item A -- Content of Reactor Operator / Senior Operator annual examinatio As stated in the Notice of Violation, the requalification program for licensed personnel includes an annual series of lectures and quizzes and an annual written examination on the previous year's lectures. A required training lecture rresentation was given on the topic of Normal, Abnormal, and Emergency Operating Procedures, on May 19, 1987 followed by a quiz on the topic on the same date. Ilowever, the annual examination did not include questions on that toph. The reason was simply the failure of the person preparing the annual examination'to recognize there were no questions on the topic when 1:2 compared the questions to_ the list of required lecture topic As a coirective step, an addendum to the 1987 annual examination was prepared which contains only questions on this topic. This examination addendum was administered to all persons who took the 1987 annual examination, and the scores for that part were averaged with the presious score All persons taking the examination addendum passed it successfully, with scores in all cases abose 70 percent, which is the level below which retesting is required under the approsed requalification program. All operators have successfully completed the examination addendum, so the facility is now in full compliance with this condition of the requalification progra In order to assure the inclusion of questions on this and all required topics in future annual raqualification examinations, a standard format for unnual examinations has been developed 'I his format includes a separate page for questions dealing with each topic required in the requalification program, in addition, the scores achieved by each person will be summarized by topi Item 11 (1) -- Training required under the Emtrgency Pla As stated in the Notice of Violation, the Emergency Plan requires NRL Operators and staff, and members of the Radiation Control Office (RCO) with emergency response responsibilities to complete an initial training program and an annual review program. NRL operators and staff had their initial training under the Emergene) plan on May 30, 1984, and have had annual review '

programs as well as annual emergency training drills since that time. Five members of the Radiation Control Office Staff, including the Director, Assistant Director. Radiation Safety Office Chief Radiation Control Officer, and the most recently-hired health physicist, hase participated in at least one of these annual reactor emergency drills and the esaluation sessions which followe h~~h M

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US Nuclear Regulatory Commission h1 arch 29,1988 page 2 RCO staff members receive general emergency response training in order to respond to emergencies at the University, and inservice train:ng is provided for all RCO personnel with emergency-response responsibilities. This training includer topics in personnel radiation protection, swipe and survey techniques, contamination control, feder11 and state regulations, and interfacing with pelice and fire control agencies. Ilowever, this trairing was judged not to satisfy the requirements af the Plan because it was not specific to the Reactor Laboratory. The failure to include RCO members in emergency response training specific to the Reactor Laboratory occurred because the staff of the Nuct ar Reactor Laboratory, including the persons who wrote the Plan, interpreted the section of the Plan in questi on to require general emergency response training for RCO staff, but not training specific to the Reactor Laborator The facility staff Reactor Committee and RCO director agree that reactor-specific training for RCO staff is beneficial, and are willing to interpret the section of the plan as requiring it. An initial training session for RCO staff dealing with reactor response requirements is scheduled for April 6,1988; annual retraining will be held each year. As a corrective step to avoid further violations, the facility operating procedures have been amended to require this training unambiguously. This amendment was approved by the Reactor Committee on h1 arch 25,1988. The facility will be in full compliance after the April 6,1988 training is complete Since approval of the Emergency Plan, Reactor Operator Requalificati;n training covering the Emergency Plan and Emergency Procedures has been held each year. Each lie,:nsed Reactor Operator and Senior Operator has been trained in the use of Emergency Procedures as they apply to the Emergency Plan. The reactor staff believes that this training has included r otective action j decision making as required by the Plan. 11 review of the training records however, the staff  ;

concurs that the documentation is not sufficient to prove absolutely that this particular aspect was l included in the emergency trainmg. The reason for this is that in this training, copies of the Emergency Plan and Procedures were themselves used as handouts and as training outlines, as opposed to separately-prepared outlines which provide the documentation in othr training session In addition to the annual training in emergency response and the annual emergency drills, a Check of Operator Proficiency is performed at two-year intervals prior to operator license renesval as required by section 5 of the NRC-opproved requalification program. Documentation of this check is present in the requalification file of each Senior Operator. This check documents the observation of the operator's proficiency to respond to simulated or posed problems related to abnormal or emergency conditions in several areas. The problem areas required include Particulate Air hionitor Alarm. Area hionitor Alarms, Fire, Radiation Levels. Domb Threat Re ponse, ,nd Emergency Plan and Procedures. The satisfactory completion of this check is a verification that the appropriate knowledge had been imparted to the persons involve In order to satisfy the requirements of the Notice of Violation, a training session in protective action decision making was provided for licensed personnel on h1 arch 24,1988. All licensed personnel successfully passed the quiz on the topic Documentation of the content of the training has been placed in the training files. The facility is thus documented to be in full compliance with the Plan at this time. In order to avoid a similar problem in the future, training outlines and attendee lists will be required for all training sessions carried out in fulfilment of the Pla i

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US Nuclean Regulatory Commission March 29,1988 page 3 Item B (11) -- Distribution of copies of the Emergency Pla Copies of the Emergency Plan had previously been distributed to the University Police and the Arizona Radiation Regulatory Agency. It has now been verified by telephone that a current copy has been rond is currently avcilable at these supporting agencies. According to the inspector, the RCO had only a draft copy of the Plan available at the time of the inspectio The Radiation Control Office participated in the development of the Emergency Plan in two ways:

a) through one member of the RCO serving as a member of the Reactor Committee, participating fully in all discussions of and changes to the draft Plan, agreeing to its approval, and receiving, with all committee members, a final copy of the Plan, and b) through discussion of the Plan with the RCO Director and his agreement to RCO participation, followed by his review of the penultimate draft of the Plan prior to its final approval by the Reactor Committee. The reason for the violation was that no fixed procedure was in place at the time to assure a copy had been sent and had been received by the supporting agencie The RCO now has three current copies of the Plan, and written verification of their receipt is on file The facility is now in compliance with the requirement of the Plan. As a corrective step to avoid further siolations, the facility operating procedures hase been amended to require copies of the Plan, procedures, and agreements be sent to the RCO, the University Polce, and the Arizana Radiation Regulatory Agency each time there is a significant change, and to require written verification of receipt. This change to the facility operating procedures was approved by the Reactor Committee on March 25, 198 Item II (111) -- Semiannual calibration of portable health physics instrument Calibration of portable health physics instruments at the University is performed by the RCO. The University's state license for radioactise materials requires annual calibration of these instrument At the time the Plan was approved, calibration was done semiannually, but the frequency was changed by RCO to an annual calibration with a semiannual operational check as the uumber of instruments in use at the University in:reased. Prior to the writing of the Plan, the reactor facility also had a requirement for annual calibration of these instruments, and the armual checklist had a sectian for verifying only an annual calibration (even though it was then being done semiannually).

After approval of the Plan, the annual checklist was not changed to track twice-yearly calibrations and for this reason it was not recognized that the calibration interval was incorrect when it was extended tu one yea All of the portable health physics instruments in the Emergency Kit and in use in the Reactor Laboratory hase now been calibrated within the past 6 months, and RCO has agreed to recalibrate these instruments semiannually. To avoid future violations, the annual checklist has been modified to provide recording and serification of semiannual calibration of these instruments. Through these correctiw actions the facility is now in compliance with the semiannual calibration requirement of the Plan and will remain in complianc .

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US Nuclear Regulatory Commiss!on h1 arch 29,1988 page 4 The facility staff will be evaluating the appropriate frequency for calibration for these instruments in conjunction with the NRC Project hianager assigned to the facility. Other radiation monitoring equipment at the racility is required to be calibrated annually. National Standard ANS 15.1, Development of '. -hnical Specifications for Research Reactors, specifies that radiation monitoring systems be calibrated either annually or at two-year intervals. National Standard ANS 15.11, Radiation Protection Practices at Research Reactor Facilities, specifies that instruments shall be calibrated at least annually, but more frequently if they are subjected to extreme operating conditions, hard usage, or corrosive environments, if appropriate, a request for change of the calibration frequency requirement from semiannual to annual will be submitted, but semiannual calibration will be maintained until a change is approved by NR If there are any questions about this response or the corrective actions it describes, you may either contact me or the facility staff directl

Sincerely,

-_, _d Ernest T. Smerdon, Dean College of Engineering and Mines

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R. L. Scale, Nuclear and Energy Engineering U. Westerman, Radiation Control Office C. F. Tedford, Arizona Radhtion Regulatory Agency Aegional Administraur, Region V, NRC Reactor Committee Members ETS/km

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