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 R 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, IRVINEBERKELEY -DAVIS -IRVINE -LOS ANGELES -MERCED -RIVERSIDE * SAN DIEGO * SAN FRANCISCO SANTA BARBARA. SANTACRUZOffice of the Executive Vice Chancellor and Provost 509 Aldrich HallIrvine, CA 92697-1000(949)824-6296(949)824-2438 FAXFebruary 2, 2011U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555References: Docket 50-326. License R-1 16 UC Irvine Nuclear Reactor FacilityNRC Inspection Report 50-326/2010-201 Notice of ViolationWe are pleased that the recent inspection report cited concluded that our operation of the nuclearresearch reactor was generally found acceptable and within compliance. In one area your inspectorsdetermined a violation of regulations had occurred:"Contrary to Section 10.2 "Drills and Exercises" of the Emergency Plan for the University ofCalifornia, Irvine Nuclear Reactor Facility, the licensee failed to conduct the required annual onsiteemergency 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 concernedthat this is seen as a "more than minor safety significance", since we believe firmly that adequateemergency response continues to be assured.Annual training exercises for response personnel were conducted with the objective of assuringappropriate emergency response to a radiologically related emergency at the facility. As explained belowwe are convinced our response team is adequately prepared to meet anticipated emergency incidents atthe facility even though the exercise was conducted at an on-campus location that was not within theconfines 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 designedto 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 CountyFire Authority, Irvine and Newport Beach Police Departments). The plan anticipates the use of otherspecialized groups to assist, when necessary, especially with clean-up and recovery operations. This isdetailed in our ERT Response Plan "Red Book" that was made available to inspectors. A sub-group ofERT is highly experienced and trained to handle emergencies with potential radiological impact sincethese could occur at a large number of sites on campus only one of which is the nuclear reactorlaboratory. This group is familiar through frequent visits and through membership on the ReactorOperations Conmmittee (ROC), with the detailed specifics of the facility. Training emphasizes that these,I/&

21PageNRC Inspection Report 50-326/2010-201 Notice of ViolationFebruary 3, 2011individuals will provide guidance to other responding personnel entering the reactor or other laboratoryfacilities where radioisotopes are used.Training and practice may therefore occur at a number of locations. Suitable locations are selected basedon incident likelihood, space available for the size of the group to be trained, and the availability offacilities for table-top exercises (seemingly now favored for better rehearsing responses). The nuclearreactor facility has not always been favored since its space is quite restricted and it has no conferenceaccommodation.The reactor staff itself is extremely small at our facility and relies on the rapid and properly equippedsupport 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 UCInuclear reactor is the "Regents of the University of California". They have designated responsibility to theIrvine campus Chancellor, with further designation to the Executive Vice-Chancellor and Provost. Theseindividuals have the authority, in an emergency, to declare the entire campus, including all facilities andaccess roads, "closed" and to direct all emergency operations therein. Thus it is not unreasonable for us tohave interpreted "onsite" to imply "the Irvine campus" and to plan exercises and drills based on ourcampus-wide approach to emergency response. We perhaps should consider modifying the language inour reactor facility emergency plan to clarify this approach.2. Corrective Steps TakenWe have noted the concerns and will, pending a re-interpretation as noted above, assure that anemergency exercise/drill be conducted annually within the confines of Rowland Hall at the reactorfacility. Planning personnel will design and designate this as the "site".3. Further Corrective StepsWe believe that our commitment to this change needs no further corrective action.4. Full ComplianceWe will implement this exercise on our normal schedule, which is during the first half of the calendaryear 2011, so it should be completed by June 30th of this year. The previous exercise on campus (whichdid not meet your on-site criterion) was held in May 2010. Subsequent exercises will be conducted eachyear on this schedule.

SincerelyMichael R. GottfredsonExecutive Vice Chancellor and ProvostC: Mr. Greg Schoenbeck, NRC Office of Nuclear Reactor RegulationMr. Craig Bassett, NRC Office of Nuclear Reactor RegulationDean Ken Janda, UCI School of Physical SciencesMembers, UCI Reactor Operations Committee