ML20204H186
| ML20204H186 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 10/13/1988 |
| From: | Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8810240350 | |
| Download: ML20204H186 (4) | |
Text
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e UNIVERSITY OF VIRGINIA DEPART 5fENT OF NIICLEAR ENGINEERING AND ENGINEERING PIIYSICS r,g, NUCLEAR REACTOR FACILITY
(
J SCliOOL OF ENGINEERING AND APPLIED SCIENCE CIIARLOTTESVILLE, VA 22901 7
October 13, 1988 Telephone: 801 924 7136 Iluclear Regulatory Commission ATTil: Document Control Desk Washington, DC 20555
Subject:
REPLY TO A flOTICE OF VIOLATION (Docket No. 50-62, License No. R-66)
Gentlemen:
Please find enclosed the University of Virginia's reply to the Notice of Violation of September 14, 1988 (NRC Inspection Report No. 50-62/88-02).
Our reply addresses three examples of a violation of 10 CFR 50.54 (q) cited in the notice, in the format requested by the NRC.
Security or safeguards information is not submitted at this time.
FOR T Ub i 2 Y OF VIRGINIA
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tb Robert U. Mulder, Director U.
of Virginia Reactor Facility Sen b :rf tet,-Nj t.fe: na th's -
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My Comtrk,slon Expircs 9/17/07.
cc:
Regional Administrator, USNRC Region II, Atlanta, Ga.
Dr.
J.
S.
Tulenko, University of Florida Dr. Ratib Karam, Georgia Institute of Technology Dr. Paul J.
- Turinsky, N.
Carolina State University p ol GG10240350 891013 I I PDR ADOCK 05000062 o
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LICENSEE RESPONSE TO NRC VIOLATION CITATIONS VIOLATION 1:
10 CFR 50.54 (q) : Not all requirements of Appendix E,.Part 50 were met.
LEVEL:
IV.
DESCRIPTION:
Four reactor staff members did not attend all of classroom training sessions required by section 10.1 of the Reactor Facility's Emergency Plan.
PLEA:
Infraction is admitted.
MITIGATING OR EXTENUATING CIRCUMSTANCES: The classroom trai: ling is provided by the staf f for the staff during requalification meetings.
It is difficult to schedule meetings dates such that all emergency personnel are present at the same time.
Some may be engaged in reactor operations, in research, in teaching, on vacation, or on sick leave.
SIGNIFICANCE:
There was no degradation in emergency preparedness as a result of the incomplete retrain.ing.
The inspector found the staff aufficiently knowledgeable in the emergency procedures, because almost all staff participated in the development 4
of the omorgency plan.
CORRECTIVE i
STEPS:
A two-year schedulo board, listing dates for emorgency training sessions, drills and other i
required actions, has boon developed.
j Future retraining in emergency responso procedures of requalification meeting absontoos will be i
accomplished with the utilization of video tapes i
of previously hold training sessions.
A classroom emergency plan training session is 3
l to tako place before the next major omorgency drill, scheduled for this autumn.
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DATE FOR FULL l
COMPLIANCE:
Full compliance with the retraining requiremont will have been achieved by the timo the next major i
drill is hold this autumn.
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S.
?b VIOLATION 2:
Requirements of Appendix E, Part 50 not met.
DESCRIPTION:
Some evacuation drills were not conducted on the six month frequency required by section 8.4.2.c of the Emergency Plan.
LEVEL':
V.
PLEA:
Infraction is acknowledged.
SIGNIFICANCE:
The emergency evacuation drill scenario is described during yearly training and retraining of personnel attending the Reactor Facility.
Some weeks following this training, the evacuation alarm has been sounded and evacuation drills conducted.
It is unlikely that the yearly frequency for evacuation drills, which has been 1
observed instead of the required semi-annual frequency, resulted in a lack in' emergency preparedness, because all evacuation drills that were performed were very successful.
MITIGATING i
OR EXTENUATING j
CIRCUMSTANCES: For lack of a schedule board, the semestral 1
requirement was overlooked.
Mental recollection of this requirement was faulty.
Also, due to a reduction in the staff size and subsequent re-l organization, the responsibilities for emergency preparedness were shifted from one reactor
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supervisor to another.
CORRECTIVE 1
STEPS:
A two-year schedule, listing emergency training i
sessions, drills and other required actions, has l
been developed.
DATE FOR FULL COMPLIANCE:
An evacuation drill, with the sounding of the i
alarm, will be held during the month of October, i
1980.
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VIOLATION 3 :
Not all requirements in Appendix E,,Part 50, were met.
LEVEL:
V.
DESCRIPTION:
Updated written comaitments of support from offsite emergency organizations (Letters of Agreement) wore requested after the two-year renewal period specified in the Emergency Plan.
PLEA:
Infraction is acknowledged.
SIGNIFICANCE:
The significance of the lapse in securing renowed agreements is judged to have been small.
Since the offsite omorgency agenclos are in the business of providing emergency support, it is unlikely that this support would have boon withheld had it actually been needed.
Of course, reminders of commitments to this facility by these agencies serves a useful purposo.
CORRECTIVE STEPS:
Again, the explanati.on for the lapse is due to reliance on memory for an action that required bl annually.
The requests should have been mailed out in the summer of 1987.
In July of 1987 the 4
staff was heavily involved in an analysis of and recovery from the neutron beamport incident.
This served to deviate staff attention from the required action.
The adoption of a two-year schedulo board should prevent re-occurrance of this and similar infractions.
Requests for Lotters of Agreement were mailed out before the recent NRC inspection in omorgency preparedness was hold.
It is believed that the synchronization betwoon the bi-annual holding of major emergency drills and the recoit of the Lotters of Agroomont has boon improved as a result of the lapso.
In the future, renewed commitments shoula be in hand shortly before the execution of the major emergoney drills.
DATE FOR COMPLIANCE:
Full complianco has boon achieved.
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