ML20238F329

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp of License R-101

ML20238F329
Person / Time
Site:	Berkeley Research Reactor
Issue date:	09/10/1987
From:	Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Pister C CALIFORNIA, UNIV. OF, BERKELEY, CA
References
NUDOCS 8709160082
Download: ML20238F329 (1)

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• l SEP 101987 Docket No. 50-224 University of~ California Department of Nuclear Engineering Berkeley, California 94720 ,

Attention: Carl Pister, Dean College of Engineering Gentlemen:

Thank you for your letter dated August 20, 1987, informing us of the steps you have taken to correct the items which we brought to your attention in our j letter dated July 29, 1987. Your corrective actions will be verified during l a future inspection, j i

Your cooperation with us is appreciated.

Sincerely, J] }

F. A. Menslawski, Chief  ;

Emergency Preparedness and i Radiological Protection Branch l 4

cc w/cy ltr dtd 8/20/87:

State of CA bec w/cy ltr dtd 8/20/87:

RSB/ Document Control Desk (RIDS) (IE06)

B. Faulkenberry J. Martin J. Zollicoffer bec w/o cy of ltr dtd 8/20/87:

M. Smith Region V

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August 20, 19 87 Docket'No. 50-224 License No. R-101 l

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U. S. Nuclear Regulatory Commission i ATTN

Document Control Desk

(_ Washington, D. C. 20555 Subj ect: Reply to NRC Region V Notice of Violation Dated July 29, 1987

Dear Sir:

This letter is to reply to a Notice of Viol.ation dated July 29, 1987 to the recent 'NRC Region V inspection to our f acility.

A. Technical Specifications, Section 6.2(c) states in part: "The Reactor Hazards Committee or a Subcommittee thereof shall audit reactor operations at least quarterly but at intervals not to exceed four months."

Contrary to the above, Reactor Hazards Committee audits of reactor operations were not performed for the first and second quarters of 1986 covering a span of more than ten months.

i This is a Severity Level IV Violation (Supplement 1) .

Response: See attached letter of August 17, 1987 from Professor i Mark N. Christensen, Chairman, Reactor Hazarc'F Committee.

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B .' Techdical Specifications, Section 6.7(c)(4), requires a written report be submitted to the NRC within 30 days of any observed inadequacies in the implementation of administrative or procedural controls.

Contrary to the above, a 30-day report for failure of' the Reactor Hazards Committee to conduct the first and second quarter audits of 1986, spanning a period of more than ten months, had not been-initiated as of July 31, 1987.

This a Severity Level IV Violation (Supplement 1).

Response: See attached letter of August 17, ,1.987 from Professor Mark N. Christensen, Chairman, Reactor Hazards ' Committee.

Respectfully yours, t ,

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Thomas H. Pigford Reactor Administrator THP/jah Attachment cc. Dean Pister, College of Engineering, w/ attachment l Professor Christensen, Chairman, Reactor Hazards  !

Committee, w/attschment

. / Regional Administrator, Nuclear Regulatory  ;

Commission, Region V, w/ attachment j

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t Prof. Thomas Pigford Reactor Administrator Nuclear Engineering Campus Re: Reply to Notice of Violation

Dear Prof. Pigford:

I send. this letter to be included in your reply to t he recent NRC Inspection of TRIGA facility. The letter from F.A. Venslavski to Dean Pister, dated July 29, 1987, notes two violations for which I, as Chairman of the Reactor Hazards Committee, am responsible.

1 Two related violations are noted: 1) that "...RHC audits of reactor operations were not performed for the first and second quarters of 1986..."

and 2) that "...a 30-day report for failure of the IHC to conduct the Violation 1-failure to perform audits:

1) Reasons: a) One member of the Committee, Professer Cann of UCSF, failed to perform an audit which he repeatedly committed himself to, vent on sabbatical leave and withdrev from the committee vithout notice. It took some time to ascertain that he could not be expectee to perform the audit.

Professor Buxbaum was Chairman of the Committee at ihat time; this sequence of events took place as the end of Professor Buxbaur 's term approached and he was preparing to go on sabbatical leave.

b) Professor Bauxbaum himself was scheduled to perferm the subsequent audit. He was hit with unexpected workload as he piepared to leave. He notified me in timely fashion that he vould be unable to perform the audit as scheduled. During the summer of 1986, when this occurred, I was away from campus for extended periods; also there was de]ay in my appointment as Chairman of the Committee. By the time I was back on campus, properly appointed as Chairman, and prepared to take action io remedy the lapses, the end of the second quarter had passed.

2) Corrective Steps: The Committee doubled the number of audits in two subrequent quarters, so that the total number of aufits performed now corresponds to the specified numbered.

3) Heasures to Avoid Future Violations. If written audit reports, or firm assurances of delivery, are not in hand two weeks before quarter's end, responsibility for the audit vill be reassigned. Following the suggestion of Inspector Gillis, ex officio members of the Comm: ttee may be assigned to audit aspects of operations that are outside the,r own responsibility.

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4) Compliance is already as full as it can ever be. No direct remedy for tam./. ness is available.

Violation 2_ - Failure to report

1) Reason: My lack of familiarity with Tech Specs, Sec 6.7(c)(4), the 't i' reporting requirement. That requirement provides a simple, straightforward way to deal with the problem of missed audits. The Committee was highly ,

agitated about the missed audits, and pressed to male-up the missing audits, but the reporting requirement did not occut to me--or to any of the .'

other members of the Committee. ,

2) Corrective Steps:

reporting requirement, TheReactorstaffandIarenovallkeenlyawareof[]the' as a simple, straightforward way to deal with r; problems of this sort. Inspector cillis's pointing out of the requireme'nt is sufficient to achieve the specified results.

3) Steps to Avoid further violations: same as item 2).

4) Date of full compliance. This letter, I believe, should bring us into full compliance.

In retrospect, tighter procedures on checking progress of audits could have avoided most but not all of the problems with violation fl. The simple act of reporting 41, as specified in the Tech Specs, vould easily and constructively resolved both #1 and #2. I think ve have learned a useful lesson.

Res ec fully yours, f rk N.k Y/,I hristen en Chairman, REC cc. Dean Pister Dr. T. Lim, Reactor Supervisor l

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