ML20247B071

Responds to Violations Noted in Insp Rept 50-112/89-01 on 890525-26.Corrective Action:Training Program for Radiation Safety & Facility Emergency Procedures for Norman Fire Dept Being Initiated by Radiation Safety Ofc

ML20247B071
Person / Time
Site:	05000112
Issue date:	08/31/1989
From:	Egle D OKLAHOMA, UNIV. OF, NORMAN, OK
To:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8909120336
Download: ML20247B071 (5)

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! MECHANICAL ENGINEERING 865 Asp Avenue. Room 212 Norman, Oklahoma 73019-0001 H05) 325 son August 31,1989 Mr. A. Bill Beach, Director Division of Radiation Safety and Safeguards US Nuclear Regulatory Commission - Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington,TX 76011 Re: Docket: 50-112/89-01

Dear Mr. Beach:

The following is presented in reply to the Notice of Violation for the 25-26 May 89 NRC inspection of the University of Oklahoma Operating License R-53.

A. Authority to Dismantle e Facility The University admits the facility was dismantled afkr the fuel had been shipped off-site, but prior to receipt of NRC approval of our submitted Dismantling and Decommissioning Plan. It was our interpretation that since the reactor would not be refueled nor operate again that we could undertake certain activities while personnel were available to do such. As noted by your inspector, these activities, although premature, were conducted in a proaer manner and that simultaneous safety checks were made as work progressed. Although the reactor was dismantled, all components associated with the tank assembly have been retained on site for NRC inspection.

None of these materials will be released until NRC issues the termination order.

Only one item, the fine control rod, was ico nd to contain any residual radioactivity

[ identified by gamma s 3ectroscopy as Co-60 4 mR/hr surface,0.1 mR/hr at one meter]. This item will 3e disposed of by Radiation Safety along with other low level radioactive waste from the University at an approved low level radioactive waste >

disposal site. The dismantling and decommissioning plan was approved by NRC letter dated 5 June 89 and operations specified in this submission are presently being conducted in compliance in the plan by the Radiation Safety Office.

B. Reactor Safety Committee Composition The University admits that for the period specified the composition of the Reactor Safety Committee was not in compliance with Technical Specification 6.2 as approved by Amendment No.12 to Facility License No. R-53. The fuel was shipped off-site un 20 April 88 and the reactor director left the University for other employment that summer. It was our erroneous impression that with the fuel and director gone that j hk g-g%n OY'lesst28gi,,

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L e . l I y :y Mr. Beach _2 August 29,1989 compliance with the committee composition requirement was no longer necessary.

The requirement for a Reactor Safety committee was deleted from the new Technical Specifications approved by NRC letter dated 5 June 89.

C. Reactor Safety Committee Meetings The University admits that subsequent to its 28 March 88 meeting, the Reactor Safety Committee did not meet semi-annually as required in Technical Specification 6.2.6.

As mentioned in paragraph B. above, it was our erroneous impression that with the '

fuel and the reactor director gone that meetings were not necessary and that the Radiation Safety Officer should proceed with the Dismantling / Decommissioning task.

New Technical Specification 6.2 approved by .NRC letter dated 5 June 89 eliminates the need for a Reactor Safety Committee as an administrative control.

D. Audits The University admits that audits required by Technical Specification 6.2.8.E were not performed subsequent to the final Reactor Safety Committee meeting of 28 March 88. The requirement for subsequent audits was deleted from the new Technical Specifications approved by NRC letter dated 5 June 1989 E. Fmergency Resnense Training -

A trainin3 program for radiation safety and facility emerg cy procedures for the Norman Hire Department is being initiated by the Universi s Radiation Safety Office (see Attachment A) as part of the University's NRC road License program.

This program will be part of training conducted on a continuing basis by the Radiation l Safety Office.

incerely, WA-Davis M. Egle Director DME/rb Enc: Attachment A l cc: Dean B.C. C nes Dean G.B. W Iker Dr. Paul Skierkowski l- J' l

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University ofOkfahoma l nunuMW SAMNY ORW2 l em Ae.nmm 112 Normen, OMahome 73010 (406) 325-1015 23 August 1989 Mr. Steve Long Training Officer Norman Fire Department 411 E. Main Norman, OK 73071 Dear Mr. Long The Nuclear Regulatory Commission conducted an inspection of our Nuclear Reactor Facility on 25-26 May 1989. In conjunction with this 1 inspection they visited with you concerning our Emergency Preparedness l Plan. It appears that we have been deficient in coordinating such training with the Norman Fire Department.

Although the Nuclear Reactor Facility has been dismantled and the fuel chipped to the Department of Energy, we still maintain numerous other i labs which utilize radioactive materials in research. Although none cf these are of the level of the reactor and require an Emergency Pre- {

paredness Plan, we do maintain Emergency Procedures under our Nuclear Regulatory Commission license for these activities. Since the Norman Fire Department would be the responder for certain emergencies in these facilities it would be beneficial if we coordinated training in ,

radiation safety and the facility emergency procedures. l As a start I would like to invite you and any others you may chose to attend our Radiation Safety for Laboratory Personnel training session.

A syllabus for the program is attached. This program covers the basics of radiation safety for lab personnel working with radioactive materials and would also be applicable to personnel responding to an emergency. After this program is completed I would suggest that we meet to discuss further training and coordination in this area.

Thank you for your assistance in this matter and I look forward to working with you in this training need. Should you have any questions please contact me at 325-1015.

Sincerely, Paul Skierkowski, Ph.D.

R diation Safety Officer a

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The university of0R[anoma

o. wm Omee 906 Aap, Room 112 "P.ADIATION SAFETY FOR LABORATORY PERSONNEL" Norman. Okiehoma 73019 (406) 325 1016 In accordance with Nuclear Regulatory Commission requirements (10CFR19), all individuals working in an area involving exposure to radiation or radioactive materials must be instructed in the health protection problems associated with exposure to such, in precautions or procedures to minimize exposure, and in the purpose and function of protective devices employed.

If you have not attended this training program in previous years at this Universi-ty and will be working with radioactive materials or radiation producing devices, To assist in preparation of you should plan to attend ONE of tr.e sessiend below.

handouts etc., please call the Padiation Safety Office at 5-1015 or send your name to NEL 112 and indicate which session you will attend.

The sessions will be held in the Seminar Room at the Northeast end of the second floor of NEL. Enter the north door ( Asp St. side) of NEL and go to the end of the hallway at the top of the stairs.

DATES - TIMES Monday, September 11, 1:15 pm - 4:45 pm Thursday, September 14, 1:15 pm - 4:45 pm Friday, September 15, 8:15 am - 11:45 am

• • ATTEND ONLY ONE SESSION **

If you have any questions please call the Radiation Safety Office at 5-1015.

COURSE SYLLABUS I. Introduction to Radioactivity and Tenninology A. Radioactivity - definition, types and properties B. Units of measurement - quantities of radioactivity and radiation exposure C. Detection of Radiation - systems and applications II. Biological Risks frem Ionizing Radiation A. possible health effects of exposure to radiation

1. prompt offects

2. Delayed effects

3. Genetic effects III. Radiological Safety A. principles of protection from external exposure B. Principles of protection from contamination and internal exposure C. Radiation emergency procedures for laboratory accidents D. Waste disposal E. The worker's right to know and options F. Prenatal radiation exposure GgThe As _ Low As Reasonably Achievable (ALARA) concept Instruction will include lecture, audiovisual presentations and denvanstrations.

THE UNIVERSITY OF OKLAliOMA INTEROFFICE COMMUNICATION f  !

T, Users of Radioactive Material p,,, August 18, 1989 Safety Training l

l rr,.Badiation Safety su bf,,, . for New Personnel In order to provide the NRC required safety training for personnel working with radioactive material or working in an area involving exposure to radi-ction, we will again be conducting the program on " RADIATION SAFETY FOR LABORATORY PERSONNEL." The sessions will be conducted in the Personnel j Services Seminar Room, NEL 215, on 4 Monday, September 11, 1:15 pm - 4:45 pm Thursday, September 14, 1:15 pm - s:45 pm Friday, September 15, 8:15 am - 11:45 Ixn

• • ATTEND ONLY ONE SESSION **

Enclosed is an announcement concerning the program for dissemination to y ur personnel. Also enclosed is a listing of all the persons in your de-partment who have received the safety orientation in the past. The train-ing program is designed for your new personnel who have not previously at-tcnded such at this institution.

If you have personnel under your supervision who will be attending the training program, please give us a call at 5-1015 or write the name(s) below and return this memo as soon as possible to Radiation Safety NEL 112 (this will help us in preparing the appropriate number of handouts). Thank you for your cooperation.

Lab Director Name: STEUC L ou G , No are tw Fu(W hEPI.

Individuals who will be attending :

llame Social Security 6 Which session?

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