ML20236F852

Responds to NRC Re Violations Noted in Insp Rept. Corrective Actions:Emergency Equipment Maint Procedure SEP-8 Revised to Properly Reflect Desired & Required Inventories. Procedure Encl

ML20236F852
Person / Time
Site:	University of Missouri-Columbia
Issue date:	10/02/1987
From:	Alger D, Mckibben J MISSOURI, UNIV. OF, COLUMBIA, MO
To:	Patterson J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20236F854	List: ML20236F852 ML20236G539
References
NUDOCS 8711020317
Download: ML20236F852 (3)

Text

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7 Research Reactor Facility  !

UNIVERSITY OF MISSOURI Research Park Columbia, Missouri 65211 Telephone (314) 882-4211 October 2, 1987 U. S. Nuclear Regulatory Commission Region Ill Emergency Preparedness & Radiological Protection Branch 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J. P. Patterson Emergency Preparedness Section

REFERENCE:

Docket 50-186 University of Missouri Research Reactor License R-103

~

SUBJECT:

Response to Notice of Violation as Required by 10 CFR 2.201.

Dear Sir:

This is the written statement required by the provisions of 10 CFR 2.201 in response to the Notice of Violation in your / letter dated September 3,1987. The violation was identified as the following: /

10 CFR 50.54(r) requires that a licensee authorized to possess and/or operate a research reactor shall follow and maintain in ,

effect emergency plans. )

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Section 8.4 of the licensee's Emergency Plan requires that the l operational readiness of emergency equipment and supplies re-  !

quired by the procedures that implement the Emergency Plan l shall be maintained, calibrated, tested and periodically in-ventoried as detailed in the Equipment Maintenance Procedure.  !

The Equipment Maintenance Procedure shall cover detailed re- l quirements such as the required inventory of emergency supplies to be maintained at designated readily accessible locations.

Emergency Equipment Maintenance Procedure, SEP-8, requires that ,

self-contained breathing apparatus sets are inspected by the l Columbia Fire Department annually, and, that the number of I self-contained breathing apparatus in the copy room is three. I l Contrary to the above, one self-contained breathing apparatus j stored in the emergency equipment cabinet located in the l Research Park Development Building (RPDB) was last calibrated / i on January 24, 1986. y j 2 ') ~ ' I]

10gog 87 COLUMBIA KANSAS CITY ROLLA ST. LOUIS 10CT 1319873 an equal OD00ftunity institution J

-4' i U. S. Nuclear Regulatory Commission

' October 2,1987 i

Page 2-Additionally, there were only two self-contained breathing apparatus stored in the emergency equipment cabinet located in the copy room of the facility. ,

1 The licensee agrees that these items may comprise administrative deficiencies in 'our implementation of MURR's Emergency Plan, but does not agree'that these .

items constitute a violation nor do they present any hazard to the general public

.or the environment.

The' item of concern is having an adequate quantity of operable self-contained breathing apparatus (SBCA). As was pointed out during the August 11-13, 1987 j inspection, we are supported by the Columbia Fire Department who assure us they f can respond to any emergency at MURR within three minutes with a minimum of ten (10) SCBAs (which are tested routinely) and with personnel thoroughly trained and experienced in providing life saving rescue operations. Selected MURR staff from the.0perations and. Health Physics groups are also trained by the Columbia Fire '

Department on the use of SCBA in harsh environments If an emergency we e to occur, a Facility emergency staff member would be able to lead the mora experi-enced fire and rescue crews to specific locations within the Facility. Therefore, at no time was there an inability to comply with the requirements of 10 CFR l 50.54(r) and our Emergency Plan, Section 8.4. However, there was an administra-

! tive discrepancy in not revising our Emergency Equipment Maintenance Procedure I (SEP-8) to properly reflect the improvements in our method of meeting the . require- 1 ments for SCBA and to clearly differentiate between required and desired invento- 4 ries. In writing SEP-8, we only listed the desired inventory. MURR currently owns -I four SCBAs and their normal storage distribution allots three to the reactor 4 facility itself and one to the backup emergency control center (The Research Park d Development Building). When our listing of these four SCBAs on inventory lists is interpreted to be a minimum requirement, there is no provision for temporary 1 shortacas to send these SCBAs out for repair or testing on a periodic basis. Your j recommended improvement item from a previous inspection (Report 50-186/85-002) J concerning our emergency equipment check list certainly recognizes, as with most inventory sheets, that shortages might exist relative to the items stated on the list, particularly temporary shortages due to sending equipment out for testing. l The deficiency noted has made us recognize that the emergency equipment main- q tenance procedure should receive more definition with regard to equipment require- i ments and the need to address emergency equipment items that are removed from ser- l vice for an extended period of time for repair or testing.  ;

The following corrective action was taken to eliminate the discrepancy:

e The third SCBA was placed in the copy room after being recharged and tested by the Columbia Fire Department. It had been used by Facility personnel on July 16, 1987 to enter the cooling tower basement as an escort for Fire Depart-ment personnel as part of recovery from a sulfuric acid spill in the cooling tower. The SCBA was at the Columbia Fire Department Station on August 11-13, .

1987 I I

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U. S. Nuclear Regulatory Commission October 2, 1987 Page 3 e The SCBA at the Research Park Development Building was tested and recharged by the Columbia Fire Department, and returned to inventory.

The following corrective action was taken to avoid further discrepancies or violations of this type:

e The Emergency Equipment Maintenance Procedure (SEP-8) was revised to properly reflect desired and required inventories. The revised SEP-8 is attached to this letter.

The University of Missouri is now in full compliance with the requirements _

given in the Notice of Violation and has completed all stated corrective actions.

Sincerely, .

f O' .v.-.

. C. McKibben Reactor Manager ,

Endorsement:

1 Reviewed and Approved c- , g Dor, M. Alger Associate Director xc: Reactor Advisory Committee Reactor Safety Subcommittee 1

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