ML110460119

UC Irvine Nuclear Reactor Facility - Response to NRC Inspection Report 50-326-10-201 Notice of Violation

ML110460119
Person / Time
Site:	University of California - Irvine
Issue date:	02/02/2011
From:	Gottfredson M University of California - Irvine
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-10-201
Download: ML110460119 (2)

See also: IR 05000326/2010201

Text

UNIVERSITY

OF CALIFORNIA, IRVINE BERKELEY -DAVIS -IRVINE -LOS ANGELES -MERCED -RIVERSIDE

• SAN DIEGO * SAN FRANCISCO

SANTA BARBARA. SANTACRUZ Office of the Executive

Vice Chancellor

and Provost 509 Aldrich Hall Irvine, CA 92697-1000

(949)824-6296

(949)824-2438

FAX February 2, 2011 U.S. Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, D.C. 20555 References:

Docket 50-326. License R-1 16 UC Irvine Nuclear Reactor Facility NRC Inspection

Report 50-326/2010-201

Notice of Violation We are pleased that the recent inspection

report cited concluded

that our operation

of the nuclear research reactor was generally

found acceptable

and within compliance.

In one area your inspectors

determined

a violation

of regulations

had occurred: "Contrary

to Section 10.2 "Drills and Exercises" of the Emergency

Plan for the University

of California, Irvine Nuclear Reactor Facility, the licensee failed to conduct the required annual onsite emergency

drill; the last record for an on-site drill was in 2007." As requested, we respond to the Notice of Violation

as follows.1. Discussion

of Violation.

We regret that this has been seen as a violation

of regulations

or of our plan. Further we are concerned that this is seen as a "more than minor safety significance", since we believe firmly that adequate emergency

response continues

to be assured.Annual training exercises

for response personnel

were conducted

with the objective

of assuring appropriate

emergency

response to a radiologically

related emergency

at the facility.

As explained

below we are convinced

our response team is adequately

prepared to meet anticipated

emergency

incidents

at the facility even though the exercise was conducted

at an on-campus

location that was not within the confines of the reactor facility itself. Records of these exercises

were made available

to your inspectors.

The University

of California

Irvine (UCI) maintains

a comprehensive

emergency

response plan designed to provide effective

24/7 response by trained personnel

to emergencies

or disasters

anywhere on campus.Rapidly available

support is provided from off-campus

("off-site")

personnel (including

Orange County Fire Authority, Irvine and Newport Beach Police Departments).

The plan anticipates

the use of other specialized

groups to assist, when necessary, especially

with clean-up and recovery operations.

This is detailed in our ERT Response Plan "Red Book" that was made available

to inspectors.

A sub-group

of ERT is highly experienced

and trained to handle emergencies

with potential

radiological

impact since these could occur at a large number of sites on campus only one of which is the nuclear reactor laboratory.

This group is familiar through frequent visits and through membership

on the Reactor Operations

Conmmittee (ROC), with the detailed specifics

of the facility.

Training emphasizes

that these ,I/&

21Page NRC Inspection

Report 50-326/2010-201

Notice of Violation February 3, 2011 individuals

will provide guidance to other responding

personnel

entering the reactor or other laboratory

facilities

where radioisotopes

are used.Training and practice may therefore

occur at a number of locations.

Suitable locations

are selected based on incident likelihood, space available

for the size of the group to be trained, and the availability

of facilities

for table-top

exercises (seemingly

now favored for better rehearsing

responses).

The nuclear reactor facility has not always been favored since its space is quite restricted

and it has no conference

accommodation.

The reactor staff itself is extremely

small at our facility and relies on the rapid and properly equipped support from the ERT for effective

action in the event of any incident needing emergency

response.We would further comment on the specific language concerning "on-site".

The licensee of the UCI nuclear reactor is the "Regents of the University

of California".

They have designated

responsibility

to the Irvine campus Chancellor, with further designation

to the Executive

Vice-Chancellor

and Provost. These individuals

have the authority, in an emergency, to declare the entire campus, including

all facilities

and access roads, "closed" and to direct all emergency

operations

therein. Thus it is not unreasonable

for us to have interpreted "onsite" to imply "the Irvine campus" and to plan exercises

and drills based on our campus-wide

approach to emergency

response.

We perhaps should consider modifying

the language in our reactor facility emergency

plan to clarify this approach.2. Corrective

Steps Taken We have noted the concerns and will, pending a re-interpretation

as noted above, assure that an emergency

exercise/drill

be conducted

annually within the confines of Rowland Hall at the reactor facility.

Planning personnel

will design and designate

this as the "site".3. Further Corrective

Steps We believe that our commitment

to this change needs no further corrective

action.4. Full Compliance

We will implement

this exercise on our normal schedule, which is during the first half of the calendar year 2011, so it should be completed

by June 3 0 th of this year. The previous exercise on campus (which did not meet your on-site criterion)

was held in May 2010. Subsequent

exercises

will be conducted

each year on this schedule.Sincerely Michael R. Gottfredson

Executive

Vice Chancellor

and Provost C: Mr. Greg Schoenbeck, NRC Office of Nuclear Reactor Regulation

Mr. Craig Bassett, NRC Office of Nuclear Reactor Regulation

Dean Ken Janda, UCI School of Physical Sciences Members, UCI Reactor Operations

Committee