Text

Discusses Insp 50-062/87-03 on 870706-08 & 15-17 & Forwards Notice of Violation & Imposition of Civil Penalty
	ML20236M916
Person / Time
Site:	University of Virginia
Issue date:	10/26/1987
From:	Grace J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Starke E; VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
Shared Package
ML20236M921	List: ML20236M916; ML20236M957;
References
	EA-87-155, NUDOCS 8711130331
	Download: ML20236M916 (5)
	v • d • e

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OCT 261987 l

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Docket No. 50-62 l

License No. R-66 l

EA 87-155

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University of Virginia

ATTN: Dr. Edgar A. Starke, Jr., Dean

School of Engineering and '.

Applied Science

Thornton Hall

Charlottesville, VA 22903

Gentlemen:

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SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY l

(NRC INSPECTION REPORT NO. 50-62/87-03)

This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by

F. N. Wright, P. T. Burnett, and J. Caldwell; at the University of Virginia Pool

Reactor on July 6-8 and 15-17,,1987. . The inspection included a review of the

events associated with the significant potential for overexposure of personnel l

in tne neutron radiography facility which was identified by members of.your ;

staff and reported to the NRC on July 2,1987. The report documenting this

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inspection was sent to you by our letter dated August 6,1987. As a result of I

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this inspection, significant failures to comply with NRC regulatory' requirements

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were identified, and accordingly, NRC concerns relative to the' inspection

findings were discussed in an Enforcement Conference held at your facility on

August 13, 1987. A summary of the Enforcement Conference was sent to you-by

our letter dated September 4,1987.

The violations described in Section I of the enclosed Notice of Violation and

Proposed Imposition of Civil Penalty involved.(1) failures to perform the

surveys necessary to identify a high radiation area and to take appropriate

action to properly post and control access to the area and (2) failure to

provide written procedures for the installation, operation,. modification, and

surveillance of experimental- facilities. Although the highest radiation

exposure received by any individual was 270 mrem, which was less than the NRC

l limit, the NRC is concerned that these violations, collectively, caused a

significant potential for personnel exposures in excess of NRC Limits.- Radiation

l 1evels up to 180 rem per hour could have been encountered in the blockhouse had

l the water shield been fully drained. These violations also demonstrate the-

need for improvements in the administration and control of facility modifica-

tions to ensure the safe performance of licensed activities and adherence to

the NRC requirements.

l With respect to these violations, we are concerned over an apparent lack of

management authority to ensure that operation of your facility is conducted in

a safe manner. Technical Specification 6.1.1. states that the Chairman,. Depart-

ment of Nuclear Engineering, has the overall responsibility for management of

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the facility. Technical Specification 6.1.2 states that the Reactor Facility

Director has overall responsibility for facility operation. Our inspections in

the area of health physics and operations have revealed that, in the recent ,

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past, when activities have been under the managerial control of the Reactor

Facility Director, only minor health and safety problems have existed. But, it

appears that where that control has not been fully exercised, as in this

particular instance when experimental facilities were modified, adherence to

regulatory requirements involving health and safety decreases. We believe that !

the Chainnan, Department of Nuclear Engineering, has not given full authority to j

the Reactor Facility Director to control experimental facilities and their use 1

and this was a contributing factor to this problem. Consequently, in your l

response to the Notice of Violation and Imposition of Civil Penalty, you should I

discuss management control of all aspects of facility operations. !

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To emphasize the need for adequate control of high radiation areas and manage- j

ment control of facility design and modifications made for the purpose of l

performing experiments, I have been authorized, after consultation with the i

Director, Office of Enforcement, and the Deputy Executive Director for Regional l

Operations, to issue the enclosed Notice of Violation and Proposed Imposition

of Civil Penalty in the amount of Two Thousand Five Hundred Dollars ($2,500)

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for the violations described in Section I of the enclosed Notice. In accordance

with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1987) (Enforcement Policy), the violations described

in the enclosed Notice have been categorized in the aggregate as a Severity

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Level III problem. The base value of a civil penalty for a Severity Level III

problem or violation is $2,500. The escalation and mitigation factors in the

Enforcement Policy were considered, and no adjustment of the base civil penalty

amount has been deemed appropriate in this case. Any mitigation that may have

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been warranted for your prompt investigation of the circumstances surrounding

this event and your prompt and extensive corrective actions to preclude its

recurrence at the neutron radiography blockhouse is offset by the lack of

broader corrective action to assure that a similar problem does not occur in

other aspects of the operation of the facility. l

The violation described in Section II of the enclosed Notice involved failures

to conduct a safety evaluation of facility modifications in accordance with

10 CFR 50.59. This violation has been categorized as a Severity Level IV

violation,

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You are required to respond to this letter and should follow the instructions

l specified in the enclosed Notice when preparing your response. In your response.

l you should document the specific actions taken and any additional actions you

plan to prevent recurrence. After reviewing your response to this Notice,

including your proposed corrective actions and the results of future inspec-

tions, the NRC will determine whether further NRC enforcement action is neces-

sary to ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC Public Document Room.

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OCT 261987

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University of Virginia -3-

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The responses directed by this l'etter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required 1

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by the Paperwork Reduction Act of 1980, Pub, t No.96-511.

Sincerely.

'. ORIGINAL SIGNED BY

.: M. L ERN9f

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J. Nelson Grace

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Regional Administrator i

Enclosure:

Notice of Violation and

Proposed Imposition.

of Civil Penalty

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University of Virginia -3- OCT O S 1987

The responses directed.by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required j

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by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

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Sincerely, j

ORIGINAL SIGNED BY

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M. L E T

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,~ J. N 1 on Grace

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Regional Administrator j

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Enclosure: .j

Notice of Violation and

Proposed Imposition

of Civil Penalty

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ML20236M916

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