ML20217A745

Ro:On 970812,questioned Whether OSTR Matl Balance Rept Date of 970728 Was Date Completed or Date Not to Be Exceeded. Caused by Reactor Administrator'S Pressure of Work Load. Completed OSTR Matl Balance Rept

ML20217A745
Person / Time
Site:	Oregon State University
Issue date:	09/05/1997
From:	Dodd B Oregon State University, CORVALLIS, OR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9709220114
Download: ML20217A745 (4)

Text

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RADIATloN CENTER OREGON STATE UMVERStrY 100 Radician Cesder, Carvallis. oregon 97331.$903 Telephone 541737 2341 rax $417374480 September 5,1997 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Reference:

Oregon State University TRIGA Reactor (OSTR)

Docket No. 50-243, License No. R-106

Subject:

Self-Identification of a Violation of NRC Regulations Gentlemen:

This purpose of this letter is to formally report a recent incident in which there was a violation of 10 CFR 74.13(a)(1). An initial verbal notification of these events was made to Mr, Alexander Adams Jr., the OSTR's Senior Project Manager at the NRC, on September 3,1997.

} Background Information The OSTR is required by 10 CFR 74.12(a)(1) to submit a Material Balance Report "as of March 31 and September 30 of each year and file it within 30 days after the end of the period covered by the report." At the OSU Radiation Center the responsibility for special nuclear material (SNM) acce -itability and control has been assigned to the Reactor Administrator. To ensure that items such as t.us which have time constraints on them are performed within the appropriate interval there are four OSTR Operating Procedures (OSTROPs 13,14,15, and 16). These procedures cover items required to be performed monthly, quarterly, semi-annually and annually. Each procedure has a surveillance and maintenance (S & M) worksher which includes for each item a target date for completion, the date not to be exceeded, and the datc atually performed. It also has a place for the initials of the person completing the item. The date not to be exceeded is ollen related to some license, technical specification, or regulatory requirement based on when the item was previously performed. it is the responsibility of the Reactor Supervdor to routinely review the S & Ms and either to have the reactor stafTperform them in a timely manner or to notify the person responsible for that ite:n that it is due. f

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• U.S. Nuclear Regulatory Commission -

Page 2 September 5,1997 Description of the Incident In the middle of April the Reactor Supervisor notified the Reactor Administrator that the Material Balarce Report was due. The Reactor Administratcr acknowledged this reminder.

- At the end ofJuly the Reactor Administrator was notified by the USNRC that NAC International had not received the OSTR Material Balance Report. The Reactor Administrator immediately completed p the report and submitted it on July 28,1997. At this time he was not aware that late filing of this B information required a repon to the USNRC.' ,

During the OSTR Reactor Operations Committee (ROC) meeting on August 12,1997 the person L who audited the S & Ms reported that the 'date completed' for this item was after the 'date not to I be exceeded'. Since the Reactor Administrator was on vacation it was not clear to the ROC that the

!-July 28* date was actually the date the reports were submitted, it was postulated tlm the Reactor u - Administrator may have inadvertently insened the date when he initialed that the item had been completed.

The Radiation Center Director left for vacation before the Reactor Administrator retumed but seft

. a note asking him to clarify the matter. This was done in a memo to the Director dated August 28,1997. On the Director's return to work September 2,1997, the matter was discusn i and >

l the Reactor Administrator made several telephone calls to NAC International ud the USNRC.

Initially he was told that many facilities were late in filing these reports and that this was not-reportable. Further follow up calls determined that in fact this event should be reportei This was -

'immediately accomplished with the previously referenced call to Mr. Adams.

Cause of the Occurrence The pressure of his work load at the time rcsulted in the Reactor Administrator forgetting to prepare the Material Balance Report r.fler he was reminded by the Reactor Supe: visor.

Corrective Actions

,; The OSTR Material Balance Report was completed and submittcd by the Reactor Administrator when he was reminded by the USNRC that it had not yet been received, w

• U.S. Nuclear Regulatory Commission Page 3

. September 5,1997 I

hicasures to Prevent Recurrence of Such Events i i

l In this situation it is difficult to conceive of ways to improve the current methodology. There are a total ofalmost three hundred individual items each year which are covered on the S & M work sheets.

Very rarely is one of these ever performed late and license and technical specification requirements l are almost never missed. This is the first time that a Material Balance Report has been submitted late in at least twenty years. These data would lead to the conclusion that the S & M system in place I works very well and that this current event is an anomaly.

However, it should be recognized that the workload of the reactor staff has increased significantly I over recent years with increased regulatory requirements. In addition, budget cuts have also had their l impact on facility operations. The Radiation Center Director is currently working with the university I administration in sn attempt to address these issues by obtaining significant additional funding for the facility to hire more reactor staff. )

1 Conclusions In conclusion, we would like to point out that while we regret its occurrence, the event reported here was promptly correctml and reported once identified. Clearly this was a paperwork oversight event

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which has no radiological or reactor safety implications whatsoever. It should also be noted that the '

Radiation Center SNM inventory changes very little withjust a few grams ofburn-up and production occurring in the reactor fuel. In other words, we essentially report the same numbers year after year in our Material Balance Reports.

Should there be any questions regarding the information in this report or should you require more information, please let me know.

, Yours sincerely, r i

( ian r Dodd, PhD Director

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• U.S. Nuclear Regulatory Commission Page 4 September 5,1997 c: Al Adams, Senior Project Manager, Non-Power Reactors and Decommissioning Projects Directorate, U.S. Nuclear Regulatory Commission, M.S. 0-ll-B 20, Washington, D.C. 20555 Philip Ting, Chief, Operations Branch, Division of Fuel Cycle Safety and Safeguards U.S. Nuclear Regulatory Commission, Washington, DC 20555 Oregon Department of Energy,625 Marion Street, NE, Salem, Oregon 97310, Attn: David Stewart-Smith Richard A. Scanlan, Interim Vice-Provost for Research Stephen E. B:nney, Chairman Reactor Operations Committee Jack F. Higginbotham, Reactor Administrator David S. Pratt, Senior Health Physicist Arthur D. Hall, Reactor Supervisor I