ML20199C103
| ML20199C103 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 01/22/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20199C091 | List: |
| References | |
| 50-288-97-202, NUDOCS 9801290132 | |
| Download: ML20199C103 (3) | |
Text
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5 ENCLOSURE 1 NOTICE OF VIOLATION Reed College Docket No. 50-288 TRIGA Mark-l License No. R-112 During an NRC inspect!on conducted on December 1518,1997, violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement 5.ctions," NUREG 1600, the violations are listed below:
1.
Technical Specifications (TS) Section 1.2 requires that the Radiation Safety Committee meet at least twice yearly to review safety aspects of facility operation.
Contrary to the above, the Radiation Safety Committee (RSC) met only once in 1997, in September. A meeting of the RSC was held in May 1997, but a quorum was not present and no official actions could be taken. No second formal meeting had been convened to meet the requirements.
This is a Severity Level IV violation (St.pplement 1).
2.
TS l.5 requires that written instructions shall be in effect.
a.
SOP 23, " Health Physics Wipe Tests," dated November 1997, Section 23.2 requires that wipe tests shall be performed (inside the Reed Reactor Facility) at least every two weeks, not to exceed 18 days, and whenever activities involving radioactive materials require additional wipe tests.
b.
SOP 20, " Radiation Work Permits," dated August 1994, Section 28.3 requi.es that Radiation Work Permits (RWP) shall be reviewed and approvod by the Director or the Associate Director prior to the operation.
Contrary to the above, a.
A biweekly wipe test was completed on April 11,1997, but not again until April 30, a period exceeding 18 days. Also, following the wipe test on April 30, 1997, the next wipe test was not conducted until May 23, a second period exceeding the 18 day maximum.
b.
Radiation Work Permit #2, dated No - mber 2,1996, Part I, had been written by the Associate Director, reviewed 8-
- ) proved by a Senior Reactor Operator (SRO), and used during an operation
.t had not been reviewed and approved by the Director prior to the operation as required.
This is a Severity Level IV violation (Supplement IV).
9901290132 980122 DR ADOCK 050002 8
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2-l 3.
10 CFR 71.5(a) requires that a licensee who delivers licensed material to a carrier for transport comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT)in 49 CFR Parts 171-189.
. 49 CFR 171.2(a) prohibits any person from offering hazardous material for transportation unless, among other requirements, the hazardous material is properly 4
classified, described, packaged, marked, labeled, and in condition for shipment required or authorized under the Hazardous Material Regulations (49 CFR 171-177).
7 Contrary to the above, several discrepancies were noted on the shipping papers as follows:
1-a.
The shipping papers for Shipment No. 95-1, dated March 30,1995, did not list the
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chemical or physical form of the material being shippsd.
b.
The shipping papers for Shipment No. 95-2, dated October 2,1995, indicated an incorrect Transport Index (TI).
e c.
The shipping papers for Shipment No. 96-2, dated May 17,1996, indicated that the package was incorrectly labeled compared with the external radiation level of the package.
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'd.
The shipping papers for Shipment No. 96-3, dated December 16,1996, listed an incorrect TI. Also, the chsmical and physical form of the material being shipped was not listed.
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.e.
The shipping papers for Shipment No. 97-1, dated May 6,1997, showed that the package was incorrectly labeled compared with the external radiation level of the package.
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.f.
The shipping papers for Shipment No. 97 2, dated July 11,1997, did not list the total activity in the International System of Units (Si units) or in both SI units and 4
the customary units (i.e., curies or millicuries e c.). The listing of total activity in j
- Si units or both Si arid customary units on the shipping papers was required af ter April 1,1997.
g.
The shipping papers for Shipment No. 97-3, dated December 1,1997, did not list the total activity in the International System of Units (SI units) or in both SI units and the customary units. Also, an incorrect Tl was listed.
This is a Severity Level IV violation (Supplement V).
4 4.
10 CFR 74.13(1) requires that each licensee shall compile a report as of March 31 and September 30 of each year and file it within 30 days after the end of the period covered by the report.
Contrary to the above, the Material Status Report (DOE /NRC Form 742) covering the i
period from October 1,1995, through March 31,1996, had not been submitted within 30 days of the end of the reporting period but had been submittod on May 22,1996.
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Similarly, the report for the period from April 1,1996, through September 30,1996 4
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had not been submitted until November 20,1996; the report for the period from October 1,1996, through March 31,1997, had not been submitted until May 13, 1997; and, the report for the period from April 1,1997, through September 30,1997 j
had not been submitted until November 4,1997.
This is a Severity Level IV violation (Supplement 111).
F seant to the provisions of 10 CFR 2.201, Reed College is hereby required to submit a written statement or explanation to the U.S. Nuclear regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the responsible inspector,.
U.S. Nuclear Regulatory Commission, Region ll,61 Forsyth St. S.W., Suite 23T85, Atlanta.
GA 30303, within 30 days of the date of this letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notlee of Violation" and i
should include for each violation: (1) the reason for the violation, or it contested, the basis fcr disputing the v:alation, (2) the corrective steps that have been taken and the results achieved, (3) the cc rective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. -If an adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued as to why the license should not be modified, suspended, or revoked, Or why such other action as may be proper should not be taken, Where good cause is shown, censideration will be given to extending the response
- time, because your response will be placed in the NRC Public Document room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please nrovide a bracketed copy of your response that identifies the information that should be prc ted and a redacted copy of your response that deletes such information, if you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure or information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response please provide the ;evel of 4
4 protection described in 10 CFR 73.21.
Dated at Rockville, Maryland this 22nd day of January 1998 1
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