ML20217D209
| ML20217D209 | |
| Person / Time | |
|---|---|
| Site: | University of Buffalo |
| Issue date: | 09/23/1999 |
| From: | Vasbinder D NEW YORK, STATE UNIV. OF, BUFFALO, NY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9910150062 | |
| Download: ML20217D209 (3) | |
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Occupational and Environmental Safety Services l
September 23,1999 Reply to a Notice of Violation l
Docket 50-57 License R-77 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C. 20555 Dear Sir or Madam This letter is in reply to the Notice of Violation issued to the University at Buffalo resulting from the inspecbon conducted by the NRC from August 24,1999. The notice of violation sites a failure to submit an annual technical report to the NRC as required by the facility Possession Only Technical Specifications (amendment #24 issued June 19,1997) for the balance of 1997 and calendar year 1998.
The University at Buffalo urr:arstands the violabon, and is committed to actions to correct the present deficiency and to prevent future occurrences l
Date and manner by which compliance will be achieved:
1 The required reports will be submitted to the NRC by October 30,1999.
1 Follow un actions to prevent reoccurrence:
4 In follow up to the inspecbon, the University has taken the following steps:
Ooeratino Committee / Staff Meetino The BMRC Opemting Committee convened (with additional staff in attendance) to discuss the violabon and potential corrective actions. At this " brainstorming session" the staff discussed underlying causes for the violation, and idenbfied opbons to improve performance 1
The staffidentified as potential underlying causes Increased woridoad due to staffing losses (both technical and clerical) resulting from e
resignabons, and retirements. In addition, staff turnover has elevated the training burden.
Difficulty in communicating cnd routing documents because personnel are physically distributed across multiple work locations.
Competition with other safety related issues and tasks (BMRC and campus). This competition results directly from the unavokiable staff losses, as well as from deliberate actions to place BMRC staff into more diverse, long-term empioyment opportunities.
1 Loss of focus on BMRC tasks.
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- The staff identified as options to improve performance Allocating addtional clerical resources to the BMRC project to help with reports genersbon, filing, and record keeping (freeing up technical staff time). TNs may require funding and sectionof anewpombon Retaning one or more engineering students (preferably with Navy Nuclear experience) for part time work at BMRC. These students would be trained to perform basic maintenance, housekeeping, and surveillance adivibes at the facihty This would also help technical staff to concentrate on more complex dubes at BMRC.
Consolidation of work locations (to the extent predical). A projed ves initiated several months ago to renovate space in the Winspear Avenue physical plant complex. This will allow the main omce of OmW and Erwironmental Safety to relocate to apar* within 200 meters of
. BMRC (Currently a one mile drive away).
In addtbon to these steps, the need was stressed for the staff at all levels, to re-incus their efforts towardsthe BMRC project.
Reactor Decommesioning Safety Committee Moebng (RDSC)
A meeting of the oversight commdtoe, (RDSC), was convened to discuss the violabon At this meeting, the Committee diamaaad reasons for the violabon and possible correchve achons. The Committee, while indicating that they did not see any immediale safety concem, dd reinforce that failure to submit the reports was unacceptable and that steps need to be taken to insure full compliance in the future.
BMRC managers expressed to the RDSC that the failure to autmt the required techrical reports, to a great extent resulted from dmcult choices to concentrate resources on issues of higher safety significance. All required survedlance tests and inspechons had been conducted, and all environmental rolesses were within appbcable limits. Records related to safety evaluabons, radioactwe affluents, erwironmental radiological surveys, radation exposures, contarnnation surveys, m$r rnairtenance opershons, and changes to the fadirty were available for review by the inspector. Some of these records, however, were not as well organized as in the past Corrective stens taken orlor to inspection:
Addibonal Discussion ty BMRC Mansoors The BMRC managers, prior to the inspection, idenbfied the following addebonal concems in various reamamens.
Need to adarpudaly support radiciogical safety programs at BMRC and regain momentum for BMRC projects Need to arlaryunaly support operabonal programs at BMRC and regain momentum for BMRC e
projects.
Need to retain key personnel As a result of these discuemons, the following adions were initiated prior to the inspection 1.
Recruitment of a Radation Protodion Manager, who wil drectly supervise the day to day radabon safety operations, review and updata procedures, ek:. This is a new position for which the candidate search is underway it is expected that the recrurtment process wig be completed by late fal.
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Recruitment of additional / replacement senior technical staff for Omemal and Environmertal SWety (OES). An Operabons and Training manager has been recruited.
Recruitment is
. underway for a Fire and ufe Safety Manger. In addition, recrutment for a senior industrial hygienist will begin soon. These stading additions will help the OES Director (Louis Henry), and Aaandant Director (Dowid Vasbmder) to focus more energy on BMRC projects.
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Retum of the BMRC Operations Manager (Mark Adams), to full time status witNn OES. Mr.
Adams, for an extended time penod, me timeshared between OES and the campus engineering and design department Since Mardi, Mr. Adams has been working for OES full time, dividng Ns efforts between BMRC and fadlities safety issues. While his time remains divided, he is now responsible to a single supervisor, and no lorger erks out of a North campus work locahon (nominally 5 miles from BMRC).
It is important to strou the Unrvensty at Buffalo's cxm1mitment to providing career opportunrbes to BMRC staff as an incenhve to remain with the Univenaity. TNs may rama temporal time and resource l
conflids. However, failure to do so will result in the loss of key staff with the potential for am-Gc loss in performance We believe that the correchve achons as idenbfied abcue will allow the University at Buffalo to safely maintain BMRC in compliance with the technical specificabons and applicable regulabons. Please contact me if additional infm ruiuc6 is required.
Sincerely, r
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Dewid R.Vasbinder Director, BMRC Cc: Tom Dragoun, USNRC Lou Henry, DirectorOES RogerMcGill, Chairman RDSC Mke Dupre, Aaane=#e Vice President for Facilities Mark Perro, Radation Safety Officer i
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