ML20214W198

Responds to NRC Re Violations Noted in Insp Rept 50-112/87-01.Corrective Actions:Ltr from Norman Region Hosp Obtained & Sent w/ Which Indicates That Emergency Need Will Be Responded to

ML20214W198
Person / Time
Site:	05000112
Issue date:	05/29/1987
From:	Jensen C OKLAHOMA, UNIV. OF, NORMAN, OK
To:	Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8706150147
Download: ML20214W198 (4)

Text

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O University ofOklahoma SCHOOL OF AEROSPACE,00ECHANICAL ANO NUCLEAR ENGINEERING 86s Asp Avenue. Room 212 May 29,1987 N Yis 5 7 "

Mr. Lawrence A. Yandell, Chief Radiological Protection and Safeguards Branen USNRC - Recion IV 611 Ryan P'aza Drive Suite 1000 Arlington, TX 76011 Docket: 50-112/87-01 License: R-53

Dear Mr'. Yandell:

The following is in response to Sour letter of May 20, 1987.

Licensee's Response to Violation A Although some data is taken in units of cpm instead of dpm, w do not feel that a violation has occurred. Therefore, w do not admit a violation and our reasons are as stated in the succeeding paragraphs.

The purpose of a survey swipe is generally to detect the presence of contamination that is not detectable by means of a survey instrument (er. Gi survey meter) calibrated in the desired units. It further can confinri sf containation detected by a survey instrment is "rsovable" and if necessary the identity of the radionuclide of ten can be ascertained from such a swipe. It is not necessary to convert from cpm to dpm (in liquid scintillation samples) to dsCertdin that Containation exists and has been "rmoved" by a swipe test. If the output data from the scintillation counter indicates the Changing presencetneof units conteination then decontaination actions are initiated.

fra cpm to dpm would have no effect upon this action procedure.

As reported in our letter of 14 April 87, standards are utilized "where applicable" in our assay procedures and conversion to dpm or uCiSimilarly, is made forourany sample where necessary to compare to the regulatory standard.

survey meters are calibrated to give mR/nr readings which can be cunpared to regulartory action levels. There is fj0 NRC standard or action level (in any radiation units) specifying levels of containation detected by laboratory area swipes which require action. This fact was not only pointed out to the inspector at the time of the briefing but when queried he admitted he was unable to show us any standard for survey swipes. All he Could do Was cite 10CFR20.5 concerning the units.

Enclosed are blank fon:ts we utilize for surveys of the nuclear laboratory and associated rooms. Please note that for each survey point there are two measursents. An mR/nr field is measured with a properly calibrated survey bb kD a

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Mr. Lawrence Yondell May 29, 1987 Page Two instrument in the desired units and a swipe is made of the surface (for the purposes described above). We believe that these procedures more than meet the NRC requirments and request your reevaluation of this violation in light of this additional infomation. Should )ou still feel We are in violation We Would be willing to visit with you at your regional office and present any other supporting documentation you may request or provide any further explanations.

Licensee's Response to Violation B

1) Admitted, the letter was out of date and overlooked. If this ittsn is a violation and "ittsn-of-nonccmpliance" is not an alternative, as suggested by your letter, then the inspector who visited the facility should be instructed in proper procedure.

2) A letter from the Noman Regional Hospital was obtained and a copy sent with our letter of 14 April, which indicates that they will reply to the isnergency needs of the facility. As pointed out by the NRC, the letter has no exp ration d date.

3) The letter has no expiration date, therefore, it will not expire and the violation cannot reoccur. Therefore, corrective action has been taken.

4) Full compliance was acnieved as of the date of our previous letter dated April 14, 1987.

Licensee's Reponse to Violation C

1) Admitted, the Noman fire personnel and University Police were not trained by their training officers in the procedures to be followed wnen responding to alams at the reactor facility.

2) Tne Noman Fire Chief and University Police Chief will be required to submit to the licensee on an annual basis that training for all personnel that may respond to an tamergency at the reactor facility has been perfomed. Assistance by the reactor and radiation safety office will be offered for this training.

3) The verification from the proper authority will be required annually.

4) Tne date of full compliance will be Deconber 31, 1987.

Sincerely >o s, b(Y Crai[M. ensen Reactor irector CMJ/sjb

RADIATION SAFETY OFFICE UNIVERSITY OF OKLAHOMA

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NUCLEAR REACTOR LAB \ RADIATION SURVEY Date Time

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hite Subcrit. l '@ l.' Room 103 A66cnblij De Io o- ,_ ,

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Room 106 -

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clor pogg E t h & __ 'I PSN GAMMA NEUTRON

1. rnn/hr cpm mnem/hr* Reactor in operation during survey YES NO 1 I f ye s , Power level watts.

2 3 Reactor Records: Log Dock 4 Isotope Production Instrument Cal.

5 6 Smear Wipe Tests: Front of isotope storage 1 Glory llole Room 106_ West Pit Floor _

8 9 Survey Instrument:

W Gamma Probo Neutron Probe W

W NOTES:

Date of Lant survey of reactor facility 15 W -

• Neutron mHem/hr= Acpm Surveyed by RSo Review Date

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RADIATION SAFETY OFFICE - UNIVERSITY OF OKLAHOMA LABORATORY SURVEY REPORT DATE NEL 106 User Rad. Safety Radioactive Material in use various Laboratory s c i ,s o. t.b i.

Type survey conducted

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GM and Swipe lab benchf4 c Instrumentation

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Surveyor s

G Survey Results:

i mR/hr cpm g _

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NOTES: Y Z = Room 105 Liquid W ate Storage Area Z CHECKS:

NRC-3 posted Radioactive material sign on entry l

Storage & Work areas posted Wasto containers posted

Emergency procedures posted Next survey scheduled for i

i RSO RevicW Date L_