ML20153C489

Notifies of Transportation of 14 Shipments of Licensed Matl Between 860101 & 03 Not in Compliance w/10CFR71.12(b). Renewal of QA Program Approval Immediately Requested When Notification of 851231 Program Expiration Received

ML20153C489
Person / Time
Site:	University of Missouri-Columbia, 07100108
Issue date:	02/14/1986
From:	Alger D, Meyer W MISSOURI, UNIV. OF, COLUMBIA, MO
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8602210030
Download: ML20153C489 (4)

Text

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Research Reactor Facility UNIVERSITY OF MISSOURI Research Park February 14, 1986 {o[urnbia ssouggjj Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

REFERENCE:

Docket 50-186 University of Missouri Research Reactor License R-103

SUBJECT:

Peport of the Transportation of Licensed Material that was not in compliance with the requirements of 10CFR71.12(b).

INTRODUCTION The University of Missouri Research Reactor received notice, in a letter dated January 29, 1986 from the Transportation Certification Branch of the Nuclear Requ-latory Commission, that its Quality Assurance Program Approval for Radioactive Material Packages had expired December 31, 1985. This Quality Assurance Program Approval is required pursuant to 10CFR71.12(b) as a condition for conducting trans-portation activities under the General Licenses of Subpart C of 10CFR Part 71.

During the time period between January 1,1986 and February 3,1986 (the date the University of Missouri Research Reactor received the notification), the Uni-versity of Missouri Research Reactor conducted fourteen (14) shipments of licensed material. These shipments complied with the provisions of 10CFR71, Subpart C, with the exception of 71.12(b) which states: "This general license applies only to a licensee who has a quality assurance program approved by the Commission as satis-fying the provisions of Subpart H of this part."

DESCRIPTION On June 27, 1978, the University of Missouri Research Reactor submitted to the Nuclear Regulatory Commission, Transportation Certification Branch, for review and approval, a Quality Assurance Program based upon the requirements of 10CFR71 and the guidelines provided by Regulatory Guide 7.XX (May 15,1978) and ANS-15.8 (N402) " Quality Assurance Program Requirements for Research Reactors".

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Director February 14, 1986 Page 2 The Transportation Certification Branch, in a letter dated June 4,1980, re-quested the University of Missouri Research Reactor to resubmit a Quality Assurance Program addressing the need for additional information. The University of Missouri Research Reactor provided the additional information requested and resubmitted the Quality Assurance Program for review and approval July 31, 1980.

The University of Missouri Research Reactor Quality Assurance Program was subsequently approved September 10, 1980 in a document titled " Quality Assurance Program Approval for Radioactive Material Packages". At this time, the University of Missouri Research Reactor was considered to have a valid Quality Assurance Program which allowed the Research Reactor Facility to transport licensed material or deliver licensed material to a carrier for transport, under the General Licenses of Subpart C of 10CFR Part 71.

The management of the University of Missouri Research Reactor was not aware that the Quality Assurance Program Approval would require subsequent reapprovals at five year intervals. It was thought that the Quality Assurance Program was similar to the Physical Security Plan, in that it would become a document attached to the Reactor License (R-103) and have an expiration date the same as the Reactor License.

The University of Missouri Research Reactor has made many shipments of licensed material between the date of the Quality Assurance Program Approval and the present date. The records of these shipments have been routinely audited by Nuclear Regulatory Commission Region III inspectors to ensure compliance with the requirements of 49CFR,10CFR71, and our Quality Assurance Program. A review of our records of these inspections show no items of noncompliance identified in auditing transportation activities.

The Transportation Certification Branch of the Nuclear Regulatory Commission noti-fied the University of Missouri Research Reactor, in a letter dated January 29, 1986 and received by the Research Reactor Facility Februry 3,1986 ( Attachment I),

that its Quality Assurance Program Approval (No. 0108) had expired December 31, 1985. The letter further stated that since the Research Reactor Facility no longer had a valid Quality Assurance Program Approval, the General Licenses of Subpart C of 10CFR Part 71 to transport or deliver licensed material to a carrier for trans-port were terminated.

The Research Reactor Facility telephoned the Transportation Certification Branch to determine by what means the Quality Assurance Program could be expedi-tiously reviewed and reapproved. The Research Reactor Facility initiated a letter requesting reapproval in the form suggested by the Nuclear Regulatory ConNission and submitted it via telephone facsimile the afternoon of February 3,1986. The Research Reactor Facility, meanwhile, withheld from making a scheduled shipment on February 3 until the Quality Assurance Program was reapproved by the Transportation Certification Branch.

The Transportation Certification Branch, based on the submitted request for approval, reapproved the Quality Assurance Program February 4,1986 and transmitted the document to the Research Reactor Facility via telephone facsimile (Attachment II). The Research Reactor Facility continued transportation activities the after-noon of February 4,1986. ,

Director February 14, 1986 Page 3 CORRECTIVE ACTION The University of Missouri Research Reactor, when notified that the Quality Assurance Program Approval had lapsed, took immediate action to have the Quality Assurance Program reapproved. The Quality Assurance Program in its entirety was reapproved, with no changes, within one day of the submittal of a request for approval.

The Research Reactor Facility immediately terminated all shipments of licensed material upon notification by the Transportation Certification Branch. One sched-uled shipment was delayed until the Quality Assurance Program was reapproved.

The shipments made in January 1986, after the Quality Assurance Program Approval had expired, were conducted under the strict guidelines of the Quality Assurance Program which was reapproved without change February 4,1986. These shipments also conformed to applicable 49CFR and 10CFR71 regulations with the exception of 71.12(b). The P1 search Reactor Facility demonstrated an inadequacy of administration control in not seeking a timely renewal of the Quality Assurance Program Approval. A timely submittal would have prevented this occurrence, how-ever, as discussed earlier, the Facility administration was not aware that the Quality Assurance Program required renewal . Recent review of the expired Quality Assurance Program verified the expiration date referenced by the Transportation Certification Branch (Attachment III).

The Research Reactor Facility is now fully aware of this requirement and will institute the necessary controls to prevent a similar recurrence. The Research Reactor Facility believes this occurrence was an administrative error and in no way affected the safety of the general public or the safety of the shipments in January, which conformed to a program the Nuclear Regulatory Commission reapproved with no requirements for change.

Sin er y,

.5 f Wal t A. Meyer, dr.

Acting Reactor Manager Attachments (3)

I Endorsement: '

Reviewed and Approved )  %,

Don M. Alger \

Associate Director xc: U. S. Nuclear Regulatory Commission c/o Document Control Desk James Keppler, Regional Administrator US NRC, Region III Reactor Advisory Committee Reactor Safety Subcommittee I

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.)AN2^'056 University of Missouri ATTN: Mr. O. L. Olson 288-C Research Center Columbia, MO 65211 Gentlemen:

Notice is hereby provided that your Quality Assurance Prngram Approval for Radioactive Material Packages, Approval No. 0108, ext, ired on December 31, 1985.

If you are an NRC licensee and conduct activities under the General Licenses of Subpart C of 10 CFR Part 71 or an Agreement State Licensee subject to the requirements of 10 CFR Part 71, as required by 10 CFR Part 150.20, a Quality Assurance Program approved by the Commission as satisfying the provision of Subpart H of 10 CFR Part 71 is required.

Since you no longer have a valid Quality Assurance Program Approval, the General Licenses of Subpart C of 10 CFR Part 71 to transport or deliver licensed material to a carrier for transport are terminated.

Sincerely, Cea Ch(ar es E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS QQ2j;v i .l O 0

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Pursuant to the Atomic Energy Act of 1954,as amended.the Energy Reorganization Act of 1974, as amended, and Title 10. Code of Federal Regulations, Chapter 1. Pa t 71, and in reliance on statements and representations heretofore made in item 5 by the person named in item y 2, the Quai.ty Assurance Program identified in item 5 is br eby approved. This approval is issued to satisf y the requirements of Section

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NRC FCCM 311 US, NUCLE AR REGULATORY COMMISSION 1 APPROVAL NUMBE R

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QUALITY ASSURANCE PROGRAM APPROVAL 0108 FOR RADIOACTIVE MATERIAL PACKAGES REVISION NUMBE R 0 .g;;.

Pursuant to the Atomic Energy Act of 1954,as amended,the Energy Reorganization Act of 1974,as amended, and Title 10, Code of Federal Regulations, Chapter 1, Part 71, and in reliance on statements and representations heretofore rnade in item 5

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by the person named in item 2,the Q uality Assurance Program identified in item 5 is her eby approved. This approval is issued 1o satisf y the requirements of Sectiore 71.51 of 10 CF R Part 71. This approval is subject to all applicable rules, regulations, and  ::r orders of the Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.

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3. E XPIR AT ION DAT E bb University of Missouri 2"Ei sTaEET AoonEs5 December 31, 1985 """'

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2. the Ouality Assurance Program identified in item 5 is hereby approved This approval is issued to satisfy the requirements of Section f4 ly 71.101 of 10 CFR Part 71. This approval is subject to all applicable rules. regulations, and orcers of the Nuclear Regulatory Commission no. or nereaner in effect and to any condttions specified below.

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