ML20207T446
| ML20207T446 | |
| Person / Time | |
|---|---|
| Site: | 05000148 |
| Issue date: | 03/19/1987 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Bearse R KANSAS, UNIV. OF, LAWRENCE, KS |
| References | |
| NUDOCS 8703240024 | |
| Download: ML20207T446 (2) | |
See also: IR 05000148/1986001
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MAR I 91987
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In Reply Refer To:
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Docket: 50-148/86-01
University of Kansas
ATTN: Mr. Robert C. Bearse, Associate
Vice Chancellor
226 Strong Hall
Lawrence, Kansas 66045-2300
Gentlemen:
Thank you for your letter of January 13, 1987, in response to our letter and
Notice of Violation dated December 23, 1986. After reviewing your reply,
it remains our position that you were provided guidance in late 1985 ragarding
dismantling of the reactor and subsequent termination of the operating license,
and that you demonstrated careless disregard for NRC requirements. Our
position is based on the fact that you had telephone conversations with the
NRC Project Manager concerning dismantling activities and, as a follow-up to
these discussions, the Project Manager provided you a copy of NRC Regulatory
Guide 1.86.
We will review the implementation of your corrective actions during a future
inspection to determine that full compliance has been achieved and will be
maintained.
Your January 13, 1987, letter contained a Safeguards Information attachment,
which was properly marked. However, the letter itself was not marked
" Safeguards Information" to indicate conspicuously the presence of protected
information, as required by 10 CFR 73.21 (e). Please mark your copies of the
January 13, 1987, letter appropriately.
Sincerely,
ORIGINAL SIGNfD gy
RO8ERT D. MAgry
Robert D. Martin
Regional Administrator
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Kansas Radiation Control Program Director
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Tile UNIVERSITY OF KANSAS
offico of the m Chano llnr for Hncan h. Gr.ninato stu. lies, an.1 Public service,
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January 13, 1987
U.S. Nuclear Regulatory Commission
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Attn: Mr. Robert D. Martin, Regional Administrator
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Docket No. $0-148, License No. R-78
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NRC Inspection ftoport 50-148/86-01
EA 86-186
Dear Mr. Martin:
The following are our responses to your Notice of Violation of December 23,
1986.
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A.
Failure to Apply for Authority to Dismantle a Facility.
(1) The removal [of the grid plato assembly], which we now understand
to be diamantlement, was done to empty the reactor tank of as much
activated material as casily possible so as to make an assessment
of the magnitude of future problems of decommission 1 sng. At the
time, we did not considor the action to be a dismantlement in the
sense implied by 10 CFR 50.82. We appreciate your not proposing a
civil penalty for this violation. At the same time, we do not
understand and do not agree with the allegation that we
" demonstrated careless disregard for this requirement by not
complying with 10 CFR 50.82 even af ter being informed of the
requirement by the project manager, Office of Nuclear Reactor
Regulation." The dismantlement took place on March 211, 1986, and
was called to our attention as being a possible violation no
carlier than September or October, 1986.
No subsequent
dismantlement has occurred. We are unaware of any specific
requirements communicated by the project manager which we
disregarded.
(2) Corrective action has been taken to be certain by administrative
control that no further dismantlement of any kind will occur
without proper authority.
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(3) Correctivo action which will be taken is the same as (2) above.
(4)
In our opinion, we are now in full compliance. ENC 1.OSURE CONTAINS
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SAFEGUARDS INFORMATION.
SAFEGUARDS INFORMATION
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B.
Failure to Post Required Regulatory Documents.
(1) The violation occurred by socident during a clean-up when all
documents were removed from the reactor bay bulletin board.
(2) Corrective action has been to replace the required documents on
the bulletin board.
(3) Corrective action which will be taken is to insure by
administrative control that the documents not be removed from the
board in the future.
(4)
In our opinion, we are now in full compliance.
C.
Failure to Identify Radioactive Material.
(1) The fission monitor was normally in a sealed container under water
in the reactor tank.
After the container had been removed from
the tank during fuel transfer operations, we neglected to label it
properly.
(2) This was pointed out to us during the inspection of September 11
and 12, 1986, and the correct label was immediately applied.
Subsequently, the monitor has been transferred to Kansas State
University.
(3) Future corrective action is moot.
(4) In our opinion, we are now in full compliance.
D.
Response to Appendix D, Notice of Violation
This response may include Safeguards Information and is appended as a
separate document.
We hope that these responses are satisfactory and that no furter NRC
enforcement action will be necessary to ensure compliance with NRC
regulatory requirements.
Sincerely,
Robert C. Bearse
Associate Vice Chancellor
Enclosure marked " SAFEGUARDS INFORMATION"
Copies w/o enclosures Nuclear Reactor Committee
Carl E. Locke
w/ enclosure Vickle Thomas
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