ML20245F510

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Responds to NRC Re Violations Noted in Insp Rept 50-284/89-01 Pn 890226-0301.Corrective Actions:Emergency Plan Drill Conducted on 880907 & Future Drills Will Be Conducted in Fall of Each Yr
ML20245F510
Person / Time
Site: Idaho State University
Issue date: 04/24/1989
From: Hutchinson J
IDAHO STATE UNIV., POCATELLO, ID
To: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8905020403
Download: ML20245F510 (5)


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Mr. Blaine Murray, Chief i Reactor Programs Branch l U..S. NRC, Region 4 '-

611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Dear Mr. Murray:

Ref: Docket 50-284/89-01 1

Enclosed is a response to the violations found during the NRC j inspection of February 26 - March 1, 1989, as detailed in the a Notice of Violation sent to us March 30, 1989. The response was prepared by Mr. David Levinskas, Reactor Supervisor; and reviewed and approved by Dr. A. E. Wilson, Reactor Administrator. The Reactor Safety Committee for our facility will formally meet on May 2, 1989, to discuss the Report and this response in detail.

After that meeting and the actions taken by the committee, we  !'

will be in full compliance.

If you have any further questions regarding the response you may contact Mr. David Levinskas, 208-236-2311, or Dr. Albert Wilson, 208-236-3933.

S c rely,

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flf, m l ohn M. Hutchinson Vice President for Academic Affairs JMH:kyt i Enclosure l

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RESPONSE TO NOTICE OF VIOLATION IDAHO STATE UNIVERSITY This is the response to the Notice of Violation issued to Idaho State University, Docket No. 50-284, License No. R-110, on f i

30 March, 1989.

l Item 1: Failure of the Reactor Safety Committee to observe j reactor operation by each licensed operator at least l once per calendar year.

This violation was the result of weaknesses in the opera- l tor requalification program identified as an open item in Part d.  !

of Appendix B of the notice of violation. The lack of a docu-  ! l mented means to track requalification activities resulted in the jl omission of the requirement for committee member observation of operators from the schedule board used to insure surveillance items are accomplished as required.

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The Reactor Safety committee will meet on May 2, 1989. At 1 1

that time both SRO's who have active licenses will be observed l operating the reactor by a member or members of the committee.

The requirement to perform these observations has been added to the surveillance schedule to insure its timely performance in the future. We anticipate that these actions will bring us into com- l plance on May 2, 1989.

i Item 2: Failure to conduct a drill of the ISU Emergency Plan during 1987.

An investigation of our records and operations for 1987 indicate that the Emergency Plan drill was not conducted due to

. the following circumstances. First, the drill was scheduled for the spring of 1987, however, it was not authorized at the spring meeting of the Reactor Safety Committee because the committee j i

limited its actions at that time to those necessary to address  !

violations and open items from the NRC inspection of February, 1987. Furthermore, the drill was not conducted during the summer because the absence of staff personnel during that time would have resulted in little benefit as far as experience for people who would be involved during the normal school year. Also during the spring and summer of 1987, the individual hired for the Reac-

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tor Supervisor position failed to qualify for a license. As a result his employment was terminated and a replacement was hired.

The change of personnel was a contributing factor to the viola-tion in that it appears the fact that the drill had not been con-ducted was overlooked during the transition. Finally, since the RSC did not meet again until 1988, the omission was not discov-ered until it was too late to correct it.

The 1988 drill was conducted on September 7. Future drills will be conducted in the fall of each year to insure that new staff and students will gain experience with emergency pro-cedures early in the school year.

Item 2 B: Failure to audit the Emergency Plan at least once every two years.

During each Emergency Plan drill, and at the drill critique immediately following, the entire Reactor Safety Commit-tee (RSC) conducts a complete examination of the Emergency Plan

and our conformance to it. While this procedure is not docu-mented as an audit, it does, in our opinion, perform the func-tions of the required audit. This procedure was followed for the '

drill of May, 1986, and again in September, 1988.

The use of the above procedure, and performance of associ- l-1 ated documentation, as a means to meet the audit requirements l will be addressed at the RSC meeting on May 2, 1989. '

Item 3: Failure to obtain NRC approval and submit Physical Security Pian changes to the NRC.

An audit of Rev.1 to the Physical Security Plan (PSP) 1 revealed that the physical description of the facility contained j in Rev.1 was incorrect. Revision 2 to the PSP corrected the er- )

1 rors and authorized possession of facility access keys by li-censed operators. Access keys were issued to three new operators  ;

when they received licenses from the NRC. Neither the physical configuration or the security procedures of the facility have ,

been changed, and as such, the effectiveness of the PSP has not I

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i been decreased. i l

I Licensed operators are authorized to be present in the I facility in the absence of both the Reactor Administrator (RA) and the Reactor Supervisor (RS). Possession of access keys by licensed operators was deemed necessary to permit the operators to lock the facility when operations not requiring the RS or RA were completed. In effect, possession of keys by operators was authorized to maintain the effectiveness of the PSP, and does not decreasc its effectiveness.

.s 4 . O fe The keys'!ssued to the' reactor operators'were returned to the RS on March 1, 1989. Revision 2 to the PSPLwas submitted'to'.

the NRC by registered mail'on March 10,'1989. These' actions bring us'into compliance with the currently authorized ~ PSP Rev.l.

Only the-RS and RA will hold. keys until' formal notification of action on Rev.2 is received.

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