ML20203B961

Responds to NRC Re Violations Noted in Insp Rept 50-288/97-202 on 971215-18.Corrective Actions:Actions Which Would Have Been Taken at Missed Meeting Were Taken at First Meeting of Next Academic Year

ML20203B961
Person / Time
Site:	Reed College
Issue date:	02/18/1998
From:	Frantz S REED COLLEGE, PORTLAND, OR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-288-97-202, NUDOCS 9802250014
Download: ML20203B961 (3)

Text

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REED COLLEGE $\\lyp, Portlami, Oregon 97202 aracma rAQUrY Reply to a Notice of Violation February 18,1998 U.S. Nuclear Regulatory Commission NITN: Document Control Desk Washington, DC 20555 Docket: 50-288 License: R-112

Subject:

Reply to a Notice of Violation NRC Inspection Report 50-288/97-202 Dated January 23,1998 l Pursuant to the NRC inspection of the Reed Reactor Facility on December 15-18,1997, a Notice of Violation was issued to the facility. The Notice of Violation listed four problems (in paraphrase):

1) The Radiation Safety Committee did not meet twice yearly as required by Technical Specifications,

2) We did not comply with our procedures on frequency of contamination surveys and approval of Radiation Work Permits,

3) We did not comply with the code of Federal Regulations regarding shipment of radioactive material; labels and transport indexes were incorrect.

4) We did not submit our Material Status Reports in time.

For each of these violations our response will include a) the reason for the violation, b) corrective actions which have been taken and the results, c) corrective steps take to avoid reoccurrence, and d) the date when full compliance will be achieved. Nor.e of the violations are contested.

1) The Radiation Safety Commit se did not meet twice yearly as required by Technical Specifications a) The Radiation Safety Committee met twice during the academic year but there was not a quorum at the second meeting because of an unexpected absence. The purpose of the meeting was to review audits by committee members. The follow-up meeting did not take place until the next academic year.

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1 b) The actions which would have been taken at the " missed" meeting (review of audits) were  !

taken at the first meeting of the next academic year.

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c) The ROC and RSC meetings will be scheduled on an annual basis rather than scheduling them when the chair decides a meeting is required. Three meetings will be scheduled each year rather than the required two. The meetings will be added to the Reed Reactor Facility Planning Schedule for the appropriate months. The director will check if a quorum will be

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Reed Reactor, Docket 50 288 Reply to a Notice of Violation 2H8/98

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present and if the a quorum is not anticipated or does not appear, another meeting will be

- scheduled immediately.

d) Full compliance has been achieved. '

2) We did not comply with cur procedures on frequency of contamination surveys and approval of Radiation Work Permits a) The contamination surveya were missed due to personnel error. The reactor superviser is responsible to schedule the surveys and enswe they are completed. The reactor supervisor was not performing her duties as required, and the director was slow in recognizing this and taking corrective action.

Radiation Work Permits (RWPs) must be reviewed and approved by either the director or associate director. In this case the RWP was written by the associate director and reviewed by another SRO. Hus the associate director's signatum was in the " Writer" block instead o, the " Reviewer" block. The director is not required to review RWPs if the associate director reviews them. The intent of the procedure was met, but not the literal requirements, b) Surveys on April 30,1997 and May 23,1997 showed no contamination.

The director has reviewed the RWP and signed it, l c) To ensure that weekly and biweekly surveillances are completed, two movable signs have-l t

been added to the wall calendar in the control room. They indicate the latest date on which the weekly and biweekly surveillances must be done. This constant reminder should ensure that the checks are not missed in the future.

The RWP procedure will be changed to require two signatures, one of whom is the director or associate director. This will eliminate the problem outlined above, d) Full compliance has been achieved.

3) We did not comply with the code of Federal Regulations regarding shipment of radioactive material; labels and transport indexes were incorrect.

a) Shipping radioactive materialis one of the most complicated operations we perform at the

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reactor, and we only do it a couple times a year. The director completed a training session cn trans mrtation in 1997 and was involved in every shipment, therefore training is not the root pro )lem. The procedure was correct, but is quite complicated. It needs to be made clearer, b) Previous shipment papers will be annotated with the correct information.

I c) No shipments will be made until the procedure is improved. The director will rewrite the procedure and submit it for review to others in the field.

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, . 6 i:eed Reactor, Docket 50-288 Reply to a Notice of Violation 2118l98 d) Full compliance has been achieved. 'Ihe procedure will be corrected before any further shipments are made. This should be before May 31,1998.

4) We did not submit our Material Status Repons in time, a) The director was aware of the due date of the repons but allowed the mailing to slip in order to handle other items, b) The director has been made aware of how imponant it i; to tum in reports on time, c) The reports will be highlighted on the Reed Reactor Facility Planning Schedule for the appropnate months, d) Full compliance hr.s been achieved.

lf Stept n G. Frantz t'

Director, Reed Reactor Facility l

l cc: U.S. Nuclear Regula:ory Commission Test, Research and Training Reactor .

Regional Administrator, Region II Newsletter 61 Forsyth St., S.W., Suite 23T85 202 Nuclear Sciences Center Atlanta, G A 30303 University of Florida Gainesville, FL 32611 Oregna Depanment of Energy Director, Di"ision of Radiation Control Director, Oregon Department of Energy 625 Marion Street, N.E. 528 Cctcage Street, N.E.

Salem, OR 97310 Salem, Oregon 97310 .

Dr. Steven Koblik Mayor of Ci'y of Portlano President 1220 Southwest 5th Avenue Reea College Portland, Oregon 97204 Dr. Peter Steinberger Administrator Dean ef the Faculty Siting and Regulations Reed College Oregon Department of Energy Labor r.d Industries Building Curt Keedy Room 111 Chair of Reed College Radiation Safety Salem, Oregon 97310 Committee Dan Gerrity '

Chair of Reed College Reactor Opentions Committee Page 3

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