ML20209D262

Responds to NRC Re Violations Noted in Insp Rept 50-112/87-01.Corrective Actions:Application for Mod of Tech Specs to Be Completed & Sent to NRC by 870901,including Request for Mod or Deletion of Emergency Plan

ML20209D262
Person / Time
Site:	05000112
Issue date:	04/14/1987
From:	Jensen C OKLAHOMA, UNIV. OF, NORMAN, OK
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20209D268	List: ML20209D262
References
NUDOCS 8704290218
Download: ML20209D262 (5)

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L University ofOklahoma y SCHOOL OF AEROSPACE, MECHANICAL AND NUCLEAR ENGINEERING 865 Asp Avenue, Room 212 Norman, Oklahoma 73019 (405) 325-5011 April 14, 1987 Mr. J.E. Gagliardo, Chief Reactor Projects Branch USNRC - Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 Docket: 50-112/87-01 License: R-53

Dear Mr. Gagliardo:

The following letter is in reply to the inspection of Mr. R.E. Baer and the notice of violation sent by your of fice dated March 16, 1987.

I want to make some general observations concerning the inspection and the discrepancies that were found. I have been involved with at least 5 inspections of AGN type reactors and no inspector or set of inspectors ever spent more than 2 days at the f acility. Especially one for which the last inspection showed no items of non-compliance, no violations, had not operated during the 10 month period prior to the inspection, and whose total operating time during the two year period between inspections was less than the time spent by the inspector at the facility.

The second item that concerns me is the way in which the region office has conducted its evaluation of the report by Mr. Baer. At his exit interview, Mr. Baer indicated that he considered your violation A to be a violation, which we disagree with, while your violations B and C he considered to be discrepancies or items of non-compliance, with _which I concurred. With that in mind, we set out to correct those deficiences that he found. The decision to upgrade those items to violations was not warranted and I believe to be incorrect.

The following tre specific replies to the list of violations:

A. As stated in the Notice of Violation, it is acknowledged that 10CFR Part 20.401(b) requires that "the Licensee shall maintain records in the same units used in this part, showing the results of surveys required by $20.201(b)."

$20.201(a) also states that "when appropriate (our emphasis) such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentration of radioactive material present."

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. ..s Mr. Gagliardo April 14, 1987 Page Two

$20.201(b)(2) requires that each license make surveys as are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

In keeping with our commitment to ALARA, this licensee conducts very detailed surveys of laboratories. These " surveys" include, as appropriate, either measurements of radiation fields in mR/hr using calibrated survey meters and/or swipe tests to determine the presence of radioactive contamination.

A description of our procedure for swipe tests may be of value in unders tanding our position. To determine the presence of radioactive contamination which would not produce a radiation field, i.e. an mR/hr field that could be detected in an area survey, we take "Q Tip" swipes of physical locations such as bench tops , sinks , floors , doors, etc. These swipes are analyzed in a liquid scintillation counter along with s tandards and background samples. The standards are used to verify instrument performance. The policy in evaluating the swipe results (as printed out by the instrument in cpm) is that a sample giving a count rate of twice background or greater requires attention, i.e. decontamination. It is our premise that if the standards verify efficiency performance for the instrument, a comparison of sample and background cpm values is a valid indication of the presence or absence of radioactive contamination.

10CRF20 is specific (in units of mR/hr, uCi or dpm) for posting of radiation fields [20,203 (b) and (c)], determining concentrations of radioactive materials in air in restricted areas [20.103] , permissible levels of radiation in unres tricted areas [20.106], releases of licensed material to a sanitary sewerage system [20.303] and survey swipes of received packages of licensed materials [20,205]. Our systems comply with these requirements -

including compliance as to units of radiation measurement.

However, neither 10CFR nor any Regulartory Guide detail specifics for lab swipes in any units as to " action levels." Contrast this, for example, with 20.205(b)(2) which specifies the limit of removable contamination in microcuries per 100 square centimeter of package surf ace. In other words , if an absolute radiation unit standard (dpm or uC1, etc.) exists, then such conversion would be appropriate.

It is our contention that, in the absence of a standard, our procedure, as previously stated, identifies the presence of contamination and sets an appropriate level for corrective action. And the accuracy of such action is verified by analyzing standards along with the test samples, as previously  ;

described. To convert from cpm to dpm or uCi would be a meaningless (and in  !

consideration of the large number of samples we take, a non productive and very time consuming) task which would not give any better indication of the presence of contamination nor give a radiation unit to compare to a standard i since a s tandard does not exis t.

.,a Mr. Gagliardo April 14, 1987 Page Three We therefore do not believe we are in violation and request that.you reexamine our procedure of lab survey / swipe methods to determine whether or

not it is in fact meeting the intent of the regulations. Should reexamination i

result in af firmation of your previous position we would request that you establish a regulatory standard so we will be able to set action guidelines in response to the results we will obtain by performing the conversions you. would require.

t We appeal this violation and feel that we are in compliance at this time.

B. Although the letter was out of date, your contention that the emergency plan was not implemented is an incorrect observation. There is much more to the emergency plan than the letter update and we feel the emergency plan has been implemented and that this should be an item of non-compliance not a violation.

An updated letter is attached and we are in compliance at this time.

l' C. The Radiation Safety Of fice has annually conducted training for police and fire personnel and the University Snfety of fice participates in the annual and most monthly tests of the evacuation system. The persons that attend are.

generally the higher grade officers with training responsibility within their own departments. The reactor facility and the Radiation Safety office have

, also produced and distributed a video explaining the precautions and problems

! that may be encountered at the f acility during an emergency. We have also l extended our services in the training of these personnel. We feel that since we have no jurisdiction over these departments that we have completed our obligation to the emergency plan.

Since it is obviously impossible to guarantee that every person is

! trained, even if we had compulsory means to do so, the emergency response procedures detail that some person from the emergency call list must be contacted. This is to insure that a knowledgeable and trained individual is

at the site during an emergency. In addition to the person from the reactor 4

staff, the procedure details that the Radiation Safety Of fice must be notified. This again is an attempt to insure that a trained individual is present during any eme rgency.

l Although we do not feel we are in non-compliance or violation, this item

will be corrected. As was s tated to the inspector and discussed previously

> with RRC officials in Region IV and Washington D.C., the reactor facility ib ,

the process of being . mothballed, hence, the reason it has not been operated in l over a year. The application for modification of the technical specifications I will be completed and sent to the NRC by September 1,1987. As part of that l application, we will reques t that the emergency plan also be modified or l deleted, deleting the requirement for this training. In the interim, the fuel i

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has been removed and is secured in the fuel storage facility where it will be j kept during the mothball period. I l i I

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i I I Mr. Gagliardo

. April 14, 1987 Page Four i

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We_ will be in full compliance when the NRC issues new technical 1

specifications for the mothballed reactor.

If you have any questions concerning the above, please contact me at (405) 325-1754.

Sincerley yours, I

Craig . Je sen l React e Didector

!I j cc: Davis M. Egle, Director, AMNE

! CMJ/sj b i Attachment j

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NORMAN IONALHOSPITAL April 7,1987 Mr. Craig Jensen University of Oklahoma 865 Asp, Room 212 Norman, Oklahoma 73019 i Re: Services and use of Norman Regional Hospital facilities in the event of a radiological incident at the University of Oklahoma.

Dear Mr. Jensen:

By this letter, Norman Regional Hospital agrees to provide emergency care and other necessary services to the University of Oklahoma in the event of the implementation of the " UNIVERSITY OF OKLAHOMA RADI0thCICAL EMERGENCY PREPAREDNESS PLAN". The emergency care specific to a radia-tion disaster will be provided in accordance with Norman Regional Hospital's radiation disaster plan, and in accordance with our regular e

Emergency Department services.

This agreement will be e ffective imrnediately and remain in force as long as the parties are in agreement. In the event Norman Regional Hospital desires to terminate cl.is agreement, a 60 day written notification will be provided to the University of Oklahoma.

Sincereig,

' [ Craig dw W. ones i Admini t stor .

v' CWJ: dig cc: Marge Rosenfelt Bruce Smith

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