ML20212K989
| ML20212K989 | |
| Person / Time | |
|---|---|
| Site: | 05000148 |
| Issue date: | 01/13/1987 |
| From: | Bearse R KANSAS, UNIV. OF, LAWRENCE, KS |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| EA-86-186, NUDOCS 8701290273 | |
| Download: ML20212K989 (2) | |
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j THE UNIVERSITY OF KANSAS Office of the Vice Chancellor for Research, Graduate Studies, and Public Service, and Dean of the Graduate School 220 Strong Itall, Lawrence. Kansas 66045-2300 (913) 804-3301 January 13, 1987 a
U.S. Nuclear Regulatory Commission
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.. j Region IV 611 Ryan Plaza Drive, Suite 1000
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i Arlington, TX 76011
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. Attn: Mr. Robert D. Martin, Regional Administrator L
Re:
Docket No. 50-148, License No. R-78 NRC Inspection Report 50-148/86-01 EA 86-186 i
Dear Mr. Martin:
The following are our responses to your Notice of Violation of December 23, 1986.
A.
Failure to Apply for Authority to Dismantle a Facility.
(1)
The removal [of the grid plate assembly], which we now understand to be dismantlement, was done to empty the reactor tank of as much activated material as easily possible so as to make an assessment of the magnitude of future problems of decommissionisng. At the time, we did not consider 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 after being informed of the requirement by the project manager, Office of Nuclear Reactor Regulation." The dismantlement took place on March 24,1986, and was called to our attention as being a possible violation no earlier 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.
(3) Corrective action which will be taken is the same as (2) above.
(4)
In our opinion, we are now in full compliance.
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f Main Campus lawrence College of flealth Sciences and llospital. Kansas City and Wichita Q
e B.
Failure to Post Required Regulatory Documents.
(1) The violation occurred by accident 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 B, Notice of Violation
(
This response may include Safeguards Information and is appended as a j
separate document.
l 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 i
Enclosure marked " SAFEGUARDS INFORMATION" Copies w/o enclosure: Nuclear Reactor Committee Carl E. Locke w/ enclosure: Vickie Thomas l
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