ML20236J628
| ML20236J628 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1975 |
| From: | Kerr G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Dawson C KENTUCKY, COMMONWEALTH OF |
| Shared Package | |
| ML20236E585 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8708060225 | |
| Download: ML20236J628 (4) | |
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MAR 12 1975 i
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Mr. C. Leslie Dawson, Secretary Department for Human Resources Commonwealth of Kentucky Frankfort, Kentucky 40601 Dear Mr. Dawson
' Thank you for your February 5, 1975 letter responding to tne comments and recommendations made following our review of the Department's radiation control program. We appreciate your comments and support of the State's radiation control program.
I would like to offer the following comments and clarification regarding items 1(a), 3(b)(ii) and (iv), and 4(b) and (c) of my January 7,1975 letter.
1.
Items 1(a) and 4(b)
A review of.the materials 4eveloped in connection with our review
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show that the University of Louisville broad academic and broad medical licenses were last inspected on November 19 - 20, 1973.
The University of Kentucky broad academic and broad medical licenses were last inspected on April 18 - 21, 1972. Our comment, that two broad licenses were overdue for inspection by 2-1/2 years, related to the University of Kentucky licenses.
Kentucky's priority system dated October 1973 calls for inspection of broad medical and broad academic licenses initially within one year and thereafter at six year intervals. Therefore, according to that priority system these licenses are not overdue for inspection. However, Mr. Lohaus commented during the meeting that broad medical licenses should normally be inspected within six months following issuance of the license and reinspected thereafter on a yearly basis. The reinspection frequency for broad medical liconsees can be extended under favorable circumstances. Mr. Lohaus also suggested that the State might considor establishing more than.
one category for broad academic licenses similar to the categories the NRC has established for Type A, B and C broad academic licenses.
A graded system would allow certain broad academic licenses to be assigned a lower inspection priority.
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Based on a review of your comment and a reevaluation of the information
. developed during our. review meeting we offer the following comments m_
a..
Based on Kentucky's October 1973 priorfty system all broad l'
licenses are current.
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b.
We recommend that Kentucky use a reinspection frequency of eg one year for broad medical. licensas with limited extensions based on performance of the licensee. In addition, the State may want to use more than one category for broad academic licenses.
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c.
Based on the above, our original comment should have noted that only the University of Kentucky broad medical-license was overdue for inspection by a few months.
2.
. Items 3(b)(ii) and (iv)
The six items mentioned in 3(b) were cited as examples of factors which we believe should be considered when making a reassessment
'of the effectiveness of NECO's program for water management. These examples were not intended to be suggestions for additional z.ecion which should be required of NECO.
With respect to item 3(b)(ii) we were referring to the method the company uses to determine the depth of water in ~a sump. This comment was based, in part, on information contained in the raports of inspections conducted by the State on September 24-25, 1973 and October 9-11, 1973.,
i Item 3(b)(iv) was related to the possibility that the infiltration rate of ground and surface water Jnto certain trenches may approximate the rate of removal by. pumping, thus accounting for certain trenches not achieving a dry status. In addition, the recharge rate of certain trench. sumps may be slow making it difficult to. pump that trench dry since only a small quantity of water can be removed at any one time.
For example,.the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> soil backfill may create a number of discrete barriers to the movement of water through the trench and into the sump area.
3.
Item 4(c). We noted during the meeting that the program has improved the quality of the inspection reports. However, we believe that the quality of the reports could be further improved if they contained additional documentation on the scope and' status orner* _.................
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of.the licensee's program, the status of previous deficiencies, and the summary discussion held with management personnel at the j
conclusion of the inspection..The following are specific cases-
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'where these problems were noted:
a..
University of Louisville r
. License No. 16-BPA-34 C '
Report of inspection conducted on November 19, 1973.
The report did not indicate whether the results of the inspection were sinnmarized'with management personnel at the f.
conclusion of the inspection. Also, the report could have contained additional ~ documentation about what was covered and discussed during the inspection.
i b.
Tube Turns License No. 16-BPI-123 Report of inspection conducted on June 20,-1973.
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. The report did not appegr to docume't the status of all aspects of the licensee's program. There was insufficient information contained in the report to support a deficiency noted in the personnel monitoring records although specific information on this deficiency was contained in the enforcement letter.. The report did not document a summary discussion with management personnel. The letter dispatched to the licensee as a result of this inspection listed nine items i
of non-coupliance. It is the State's practice to review non-compliance i'tems with management personnel at the conclusion
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w of the inspection and documentation of that discussion should 1
be included as a part of the report.
c.
The Nuclear Engineering Co.
License No. 16NSF-1 Report (Octob'er 21, 1974 memo to files) on September 3 - 6, 1974 inspection.
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The report documented discussion with NECO personnel during.
I which it was determined trhich trenches were in a dry status.
11owever, the report did not document which trenches vera in l
a dry status.
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Unitersity of Louisville License 16-BPM-29 Rep' rt of inspectica conducted on November 20,.1973.
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The report states that a complete inspection was not conducted due to licensee problems at the time of the inspection. How-ever, the report did not appear to document in sufficient detail the particular' items covered during the ins'pection or whether a ausmary discussion was held with management.
c, -wy,-
I hope this has clarified the matters raised in your letter. Again, we
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appreciate your consideration of our comments and the actions being taken to improve the program.
Sincerely,
/H G. Wayne Kerr, Chief Agreements and Exports Eranch Division of Materials and Fuel i
Cycle Facility Licensing i
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