ML20216F428
| ML20216F428 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 04/14/1998 |
| From: | Perez P North Carolina State University, RALEIGH, NC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-297-98-201, NUDOCS 9804170066 | |
| Download: ML20216F428 (5) | |
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North Carolina State University f.i Nuclear Reactor Program Department of Nuclear Engineering Box 7900 Raleigh, NC 27895-7909 (919) 515-2321 FAX (919) 515-5115 14 April 1998 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Response to Notice of Violation Docket No.: 50-297 License No.: R 120
Reference:
Letter, NRC Inspection Report No. 50-297/98 201 and Notice of Violation, M.M. Mendonca, USNRC to P.B. Perez, NCSU, dated 18 March 1998
Dear Sir or Madam:
Pursuant to the provisions of 10CFR 2.201, North Carolina State University is hereby submitting a reply to the reference Notice of Violation. The attached response addresses the reason for the violation and the corrective steps thec have been or will be implemented to avoid further violations.
Please feel free to contact me at (919) 515-4602 if you have any questions or comments on the material submitted.
Sincerely yours,
'b.
Pedro B. Perez l
Associate Director, NRP l
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cc:
Mr. Al Adams, Jr., USNRC Mr. Craig Bassett, USNRC NCSU PULSTAR Operations Staff g
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Mr. Gerry Wicks, CHP, Reactor Health Physicist Charles W. Mayo, Ph.D., Chairman, Reactor Safety and Audit Committe 9804170066 9so414 i
PDR ADOCK 05000297 i
G PDR North Carolina State University is a land-grant university and a coastituent institution of The University of North Carolina.
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Docket No.
50 297 Reply to Notice of Violation rage 1 or 4 License No.
R 120 NRC Inspection Report No. 50-297/98-201 DESCRIPTION of VIOLATION (Severity Level IV)
NCSU Technical Specification (TS) 6.3.a.8 (dated 27 December 1984) required that procedures be written, updated periodically, and followed for radiation control. TS Section 6.3.b required substantive changes to procedures be made only with the approval of the Rndiation Protection Committee.
Special Procedure 2.1," Review and Approval of Proposed Design and Procedure Changes",
i Revision 4, dated 1 August 1994, Section 4.5 defined a procedure change (PC) as a change of intent to a written instruction that defined the policies and practices used to complete work, such as a change of purpose, method, or acceptance criteria (i.e, not editorial or l
temporary changes). Section 5.3 of the procedure required that a PC (e.g., substantive change to a TS required procedure) be reviewed by the Associate Director of the facility
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and by the Reactor Safety and Audit Committee and be approved by the Radiation Protection Committee.
Contrary to the above, during the first part of 1996, NCSU developed various Health Physics Instructions that were reviewed and approved by the Reactor Health Physicist. However, the Instructions were not reviewed by the Associate Director of the facility and the Reactor l
Safety and Audit Committee nor were the Instructions approved by the Radiation Protection l
Committee.
LICENSEE REPLY
Background
The Reactor Health Physicist (RHP) has been given specific areas of responsibility in the Safety Analysis Report (SAR) and Technical Specifications (TS), and the defined, approved radiation protection program in procedure HP 1.
Since 1994,10 CFR 20 requires a formal, documented program for radiation protection.
At the PULSTAR reactor this program is modelled after ANSI /ANS 15.11-1993 " Radiation Protection at Research Reactor Facilities".
Section 3 of this document states that management shall:
Ensure that there is a radiation protection organization with clearly defined o
responsibilities 1
Provide radiation protection personnel with the authority to carry out assigned o
responsibilities as defined in the radiation protection program
Docket No.
50 297 Reply to Notice of Violation Page 2 of 4 License No.
R-120 NRC Inspection Report No. 50-297/98-201 o
ANSI /ANS 15.11-1993 continues to state that a specific, qualified individual shall be given explicit responsibility and authority to implement the radiation protection program. The individual shall have the organizational freedom and authority to carry out defined radiation protection responsibilities.
Procedure HP 1 was written to meet 10 CFR 20 based on ANSI /ANS 15.11-1993. A method ensuring fulfillment of applicable regulations and license conditions while providing responsiveness to changing work activities was determined as being necessary by the RHP.
HPIs were developed to meet this need and it was recognized that HPIs had to be consistent with the SAR, TS, and facility license.
The HPI concept was included in procedure HP 1 which was reviewed by the Associate Director of the facility and RSAC with subsequent approval by the RPC. HPIs were limited in that only RHP activities were involved and that HPIs would be supplementary to Health Physics (HP) procedures or surveillance procedures (PS); that is, HPIs could not violate the radiation protection program or TS required surveillances and therefore could not contradict the methods or acceptance criteria given in HP procedures or surveillance procedures. HP 1 included all the topics covered by HPIs and provided the conditions, acceptable methods, and acceptance criteria relevant to those topics.
The radiation protection program including HPIs were subject to audits and inspections for compliance with TS and 10 CFR 20 as stated in procedure HP 1 and TS. HPIs were available to any member of the reactor staff, RSAC, and RPC upon their request.
Response to Notice of Violation The determination reached on the review and approval of HPIs made by the NRC Inspector is technically accurate. However, it should be clear that there was no attempt to mislead anyone or to usurp their authority. The Associate Director of the facility, RSAC, and RPC were included in the review and approval process which authorized the development HPIs and HPIs were included in various audits.
- 1) The reason for the violation was a failure to recognize:
TS 6.2.2b and TS 6.3e requirements for written procedures or instructions o
extended to the implementing and administrative details of the defined and approved radiation protection program, i.e. every aspect related to the l
radiation protection program regardless of its magnitude had to be reviewed l
and approved.
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l Docket No.
50-297 Reply to Notice of Violation Page 3 or 4 License No.
R 120 NRC Inspection Report No. 50-297/98-201 l
l The definition of procedures given in procedure SP 2.1 was applicable to any i
o written instruction in any document used to perform work.
Exemptions to the definition of procedures and the review and approval o
l process for procedures as given in procedure SP 2.1 can not be included in other reviewed and approved procedures.
l 2)
Corrective steps taken and results achieved include:
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Procedure HP 1 hr.s been revised to address this NOV. HPIs have been converted into HP and PS procedures. All of these procedures are currently i
in the review process (see attached matrix). RSAC appointed a subcommittee for this review effort in the 2 Mar 98 meeting.
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There have been two revisions of procedure SP 2.1 since HPIs were introduced including the review and approval of instructions and implementation of the revised Technical Specifications for review and l
approval of procedures.
o SP 2.1 now includes a definition of instructions as not being used for safety related, safety significant, or license commitments.
Also, review of l
instructions by the Associate Director, RHP, and Senior Reactor Operator are l
required by the revised procedure SP 2.1.
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3)
Corrective steps taken to avoid further violations (of a similar type) are addressed in item 2 above. Also, the NOV and response serve as a lesson learned. The i
inspection report, NOV, and response have been distributed to the RHP, reactor staff and RSAC.
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Date when full compliance will be achieved is expected to be 1 Jun 98. RSAC and l
RPC will be meeting in late April or May 98 to discuss the revised procedures. An effective date of 1 Jun 98 is necessary to allow for distribution of the revised procedures.
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Docket No.
50-m Reply to Notice of Violation eage 4 or 4 License No.
R-120 NRC Inspection Report No. 50-297/98 201 l
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HPI to PROCEDURE MATRIX i
I HPI Number New Procedure Number and Title j
HPI 1 Deleted (Procedure Sp 2.5 to be rewritten for procedure format)
HPI 2 HP 4 " Radiation Protection Program Self Assessment"
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HPI 3 HP 3 " Radiological Surveys" HPI 4 PS 6-16-1 " Assessment of Airborne Effluent" l
HPI 5 PS 6-16-2 " Sampling, Analyses, and Assessment of Liquid Effluent"
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HPI 6 HP 6 " Receipt, Transfer, and Shipment of Radioactive Material and I
Disposal of Solid Radioactive Waste" HPI 7 HP 7 " Leak Testing, Inventory, and Accountability of Special Nuclear Material rnd Licensed Sealed Sources" HPI 8 HP 8 " Radiation Work Permit an'd Protective Clothing" l
HPI 9 HP 9 " Respirator Use and Bioassay" l
HPI 10 HP 10 " Calibration, Operation, and Maintenance of Radiation Survey and Chemistry Instruments" l
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