ML20212L958

Responds to Violations Noted in Insp Rept 50-252/86-01 on 860519-23.Corrective Actions:Operational Recertification Program Revised & Calibr Procedure & Schedule,Including Methods for Converting Cpm to M/H,Developed

ML20212L958
Person / Time
Site:	University of New Mexico
Issue date:	08/15/1986
From:	Williams F NEW MEXICO, UNIV. OF, ALBUQUERQUE, NM
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8608250314
Download: ML20212L958 (4)

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• The University of New Mexico DEPARTMENT OF CHEMICAL AND NUCLEAR ENGINEERING Albuquerque, NM 87131 gI Telephone 505: 277-5431 fh __

August 15, 1986 q $l8M J.E. Gagliardo Chief, Reactor Projects Branch -

US Nuclear Regulatory Commission, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76001 Ref: Docket 252/86-01 Gentlemen:

Enclosed is a reply to the Notices of Violation from the inspection conducted at our facility during the period May 19-23, 1986. The reply provides the following information for each violation:

1. Reason for the violation,

2. Corrective steps taken to date and results,

3. Corrective steps to be taken in the future, and,

4. Date when full compliance is expected.

We believe we have responded to each of the violations and indicated corrective actions which will bring our facility into full compliance with the applicable NRC requirements.

Sincerely, Frank L. Williams Reactor Administrator FW/kml cc: (w/o Safeguards Attachment)

NM Environmental Improvement Division R.D. Busch, Chief Reactor Supervisor, UNM W.L. Tabor, Director, Occupational Safety, UNM 8608250314 860315 , g PDR M'OC K 0000 r-gr\n % ly sy

Failure to Implement Operator Requalification Program Operational recertification in March and October

1. Operational recertification programs are held during the spring and fall semesters but not specifically during the renths of March and October. It was felt the the intent of the Feb. 21, 1977 letter was to propose a semester-based schedule with a list of activities which occurred within each semester, not necessarily identifying specific sonths. Based on this, the recertification programs are scheduled during each semester based on the availability of the reactor and operating staff. Since 1981, the written examination has been administered every other year in the spring semester. This was based on guidance from the NRC indicating that biannual examinations were acceptable for our facility. Pesever, we failed to notify the PRC of this change in our operator recertification program.

2. Fritten examinations have been administered during the susser to the operations staff to get us back on an annual examination schedule.

3. In the application for license renewal on the ACN-201M submitted June 6, 1986, a revised operator requalification program was included.

. This clarified the schedule to read, "A one day requalification training session will be scheduled semi-annually, during the Fall and Spring". The annual written examination is now scheduled to be administered during the Spring.

4. Full compliance is expected sometime in the fall when notice of the disposition of our license renewal application is received. If approved, then our retraining program should cosply with the revised ru,uirerents submitted in the application.

Operator requalification program documentation

1. Over the last four years, we have had four different Chief Reactor Supervisors and three different Reactor Administrators. Due to internal communications problems, details on the documentation requirements for the operator requalification program were loot. The retraining sessions have been held during the Fall and Spring, but the content of some of those sessions was not described in the docueentation of those sessions. In addition, a copy of the written examination for one of the senior operators was misplaced in the transfer of responsibility and documents between Chief Reactor Supervisors.

2. All of the records for the requalification progran are nos kept in ene place so there will not be future need to transfer records when a transfer of t e stersibility occurs.

, Response to FFC 2

3. A standard documentation form for the retraining sessions is being developed which indicates the content of the sessions and the rod manipulations performed by each participant in the sessions. This form will be used for all future retraining sessions starting with the one in the Fall of.1986. To avoid future problems with raisplaced and incomplete documentation, the Reactor Safeguards Advisory Committee (RSAC) has been tasked with an annual review of the records for the Operator Requalification Program.

'4. The expected date of full compliance is December 31, 1986 after the RSAC has met and reviewed the records and standard documentation forms.

Failure to Perform Adequate Surveys Failure to properly calibrate neutron survey meters

1. The neutron survey meter, PNC-4, was checked against FuFe source rcasuremente errvolly. We assumed that this ses sufficient, but according to the inspectors this did not constitute a calibration but only a operating check.

2. We have developed a calibration procedure and schedule which includes the method for converting cpm to mrem /hr. We have also sent the neutron meters to an outside vendor for calibration.

3. We have changed our survey meter use procedure so that meters will not be in service for longer than one year before being sent to an outside vendor for calibration.

4 Full compliance should be achieved by October 1, 1986 when the meters have returned and a survey is performed.

It was also noted in the inspection that the model 3 neutron meter, PAC-4S alphe meter and Model CPMU gamma meter were not calibrated. These instruments are used in the nuclear engineering lab for course work and demonstration purposce . They are not used in the reactor laboratory and are not readily eccessible in the case of a reoctor erergcncy.

Failure to properly calibrate remote area monitors

1. Fewote area monitors (RAMS) were calibrated with the internal check contces. We assumed that this was sufficient, but according to the inspectors, there needed to be a calibration check on the check sources or a separate calibration on each RAM.

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l 2. We are currently developing a calibration procedure for the FR s.

l Pesponse to IGC 3

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3. We vill calibrate the tionitors according to ranufacturer's instructions and then use the internal source and an external source to provide calibration checks at different levels on different ranges.

4. Corp 11ance will depend on availability of an external calibration source, full compliance is expected by March 1, 1987.

Failure to properly calibrate self readir.g desiteters

1. Ue vere tresore of the utility of telibration of an instrument which can not be adjusted.

2. We are currently developing a procedure for checking and calibrating the self reading dosireters.

3. Doeireters will be in service for no more than one year before being checked for calibration. The calibration check will involve at least two points on the range.

4. Full compliance is expected by March 1, 1987.

Failure to comply with Physical Security Plan Included as an attachment to this report containing Safeguards Information.

Response to NRC 4

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