ML20204F418

Reports Recent Incident in Which Violation of 10CFR74.13(a)(1),occurred.Failure to Submit Matl Balance Rept by Deadline of Oct 30.Importance & Specific Details of Regulatory Deadlines Emphasized,Reviewed & Clarified

ML20204F418
Person / Time
Site:	Oregon State University
Issue date:	03/05/1999
From:	Binney S Oregon State University, CORVALLIS, OR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9903250287
Download: ML20204F418 (3)

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. RADIATION CENTER s

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OaEcoN STATE UNIVERSITY 100 Radia: ion Center. Corvallis, Oregon 97331 5903 Telephone 541737-2341 Fax 541737 0480 March 5,1999 )

U. S. Nuclear Regulatory Commission Document Control Desk j Washington, DC 20555 l

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Reference:

Oregon State University TRIGA Reactor (OSTR)

Docket No. 50-243, License No. R-106

Subject:

Self-identification of a Violation of USNRC Regulations j l

The purpose of this letter is to formally report a recent incident in which there was a violation of l 10 CFR 74.13(a)(1). A voice mail message about this event was left for Mr. Alexander Adams, j Jr., the OSTR's USNRC Senior Project Manager, on February 26,1999 by the Director. On i March 1,1999 Mr. Adams returned the call and spoke to Dave Pratt, Sr. Health Physicist, who briefed him on the situation.

i Background Information The OSTR is required by 10 CFR 74.13(a)(1) to submit a Material Balance Report "as of March 31 and September 30 of each year and file it within 30 days after the end of the period covered by the repoit." At the Oregon State University Radiation Center the responsibility for special nuclear material accountability and control has been a; signed to the Reactor Administrator. To ensure that items such as this which have time constraints on them are performed within the appropriate interval, there are four OSTR operating procedures (OSTROPs 13,14,15, and 16) which cover items to be performed monthly, quanerly, semi-annually, and annually, respectively. Each f) procedure has an associated surveillance and maintenance (S&M) worksheet which includes for each item a target date for completion, the date not to be exceeded, and the date actually performed. The worksheet also has a place for the initials of the person completing the item. The _

date not to be exceeded is often related to some license or technical specification requirement, based on when the item was previously performec', or, as in this case, a regulatory requirement with a fixed date. It is the responsibility of the Reactor Supervisor to routinely review the S&Ms and either to have the reactor statTperform them in a timely manner or to notify the person responsible for that item that it is due.

Description of the Incident ~RQ h ,V C

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As is routinely done, several times during the month before the due date, the Reactor Supervisor

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March 5,- 1999 notified the Reactor Administrator about this deadline. The Reactor Administrator, who had recently moved into that. position on September 16,1998, acknowledged that he_was aware of the deadline. Although it was the responsibility of the Reactor Administrator to see that the report was submitted on time, in fact the previous Reactor Administrator had volunteered to submit the 1 I-report this time and in the process train the new Reactor Administrator as to how the report was l done. The new Reactor Administ. cor checked with the former Reactor Administrator several l times during this period to remind him about getting the report completed. The report was filed on October 31,1998.

During the audit of the S&Ms on February 25,1999 for the Reactor Operations Committee (ROC) meeting of February 26,1999, an auditor noticed that the completion date of the Material i Balance Report exceeded the target date by one day. At this point the auditor notified the Reactor Administrator, the Reactor Supervisor, the Director, and the ROC Chairman of the i situation.

I Cause of the Occurrence The former Reactor Administrator has been in a new position within the university since July 1998. Although the burden of his new position was upon him, he was aware of the deadline for j the Material Balance Report. The problem lay in the fact that he had in mind that the deadline l

was the end of the month [ October 31] rather than within 30 days after the end of the period covered by the repoit, i.e., in his mind he thought he had until October 31,1998 rather than

, October 30,1998 to coraplete and file the report. The report was completed, signed, and mailed j on October 31,1998, and, as such, was thought at the time to have been filed in a timely fashion.

l Corrective Actions The importance and the specific details of regulatory deadlines have been emphasized, reviewed, and chrified with the previous and present Reactor Administrators and with the Reactor Supervisor.

Measures to Prevent Recurrence cf Such Events This is the second situation in the 32 year history of the CSTR in which the Material Balance Report has been submitted late. The other time was discussed in the_OSU letter to the NRC dated September 5,1997. There is no pattern of common cause in these two situations. The present case is one in which the individual involved thought he was fully comp!ying with regulations until it was brought to his attention nearly four months later when the ROC audit was performed that he had submitted the report one day late.

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U.S. Nuclear Regulatory Commission -

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• March 5,1999 l

As part of the review of this situation, the Director and key staff will review the entire process for preparing and submitting the Material Balance Reports.

Conclusions In conclusion, while it is unfortunate that this violation occurred, it should be pointed out that its oc urrence was the result of a slight misunderstanding of the deadline, that the deadline was only missed by a single day, and that there were no associated radiological or reactor safety implications involved.

Should there be any questions regarding the information in this report or should more information be required, please let me know.

Sincerely,

/ .

tephen E. Binney Director c: Al Adams, Senior Project Manager, U.S. Nuclear Regulatory Commission, MS OllB20, Washington D.C. 20555 Philip Ting, Chief, Operations Branch, Division of Fuel Cycle Safety and Safeguards, U. S.

Nuclear Regulatory Commission, Washington D.C. 20555 '

Oregon Office of Energy,625 Marion Street NE, Salem, Oregon,97310, Attn: David Stewart-Smith Wilson C. "Toby" Hayes, Vice Provost for Research, Oregon State University Jack Higginbotham, Chairman, Reactor Operations Committee Steve Reese, Reactor Administrator Dave Pratt, Senior Health Physicist Art Hall, Reactor Supervisor l

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