IR 05000112/1989001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-112/89-01

ML20247H321
Person / Time
Site:	05000112
Issue date:	09/13/1989
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Egle D OKLAHOMA, UNIV. OF, NORMAN, OK
References
NUDOCS 8909190289
Download: ML20247H321 (1)

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SEP il 3 !989'

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.-In-Reply Refer To: .

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Docket:. 50-112/89-01'.

i The-USiversity of Oklahoma

,LATTNi Dr. Davis M. Egle l Director,lAMNE

.J 865 Asp Ave., Room-212

. Norman,' Oklahoma 73019

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Gentlemen:

Thank you for'your ' letter of. August 31, 1989, in' response to our letter and Hotice of. Violation dated August 18, 1989. We have reviewed your reply.and ifind it responsive to the' concerns raised in our Notice of Violation. We will-review the implementation of your corrective actions during'a future inspection-to determine that full compliance has been achieved and will be maintained.

Sincerely,

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A. Bill Beach, Director Division of Radiation Safety and. Safeguards cc:

' The . University of Oklahoma ATTN: Dr. E. H. Klehr, Chairman Reactor Safety Committee

'865 Asp Avenue Norman,- Oklahoma 73019 bec to DMB (IE01)

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' SCHOOL oF AEROSPACE AND

.CECHANICAL ENGINEERING 86s Asp Avenue, Room 212 Norman, oklahoma 73019 o601 4

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pos)325.s011 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 d 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 a Facility The University admits the facility was dismantled ahcI the fuel had been shipped off-site, butpnar to receipt of NRC approval of our submitted Dismantling and

. Decommissionmg 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 were made as work progressed. pro?er manner and that simultaneous safet 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 found to contain any residual radioactivity

[ identified by gamma spectroscopy as Co-60: 4 mR/hr surface,0.1 mR/hr at one

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meter). This item will be disposed of by Radiation Safety along with other low level radioactive waste from the University at an appioved low level radioactive waste disposal site. The dismantling and decommissioning plan was approved by NRC letter dated 5 June 89 and operations s ecified in this submission are presently being conductedin compliance in the plan 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 on

' 20 April 86 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

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compliance with the committee com osition requirement was no longer necessary.

The requirement for a Reactor Safe Committee was deleted from the new Technical Specifications approved b 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 Response Training A trainin (program for radiation safety and facility emerg procedures for the Norman hire Department is being initiated by the Univers: Radiation Safety as part of the Umversity's NRC road License program.

Office (seewillAttachment This rogram be part o A)f training conducted on a continuing basis by the Ra Safe Office.

incerely, hph.

Davis M.Egle [

Director DME/rb Enc: Attachment A cc: Dean D.C. Crynes Dean G.B Walker Dr. Paul Skierkowski ,

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ses Asp.nsom.112 Normen,Omahams 73010

- pos)as tots 123: August 1989 Mr. Steve Long:

Training officer.

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Norman Fire Depart:nent

'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 ')

inspection they visited with you.concerning our Emergency Preparedness Plan.- It appears.that we have been deficient in coordinating-such Ltraining 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 labs which utilize radioactive materials.in research. Although none

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.cf these are'of.the level'of'the reactor and require an Emergency Pre- l paredness' Plan, we do; maintain Emergency Procedures under our Nuclear '

Regulatory Consnission 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.

'As'a start I would like to invite you..and any others you may chose to 1 attend our Radiation Safety for Laboratory Personnel training session.

- A syllabus for the program is attached. This program covers the ,

ibasics of radiation safety for lab personnel working'with radioactive

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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 p please contact me at 325-1015.

sincerely, l

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Paul Skierkowski, Ph.D.

Radiation Safety Officer  ;

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The university ofOklahoma m0-906 Aap, Room 112 " RADIATION SAFETY FOR LMj0RATORY PERSONNEL" r ,ven, Oldshome 73019 ,

, vis tots in accordance with Nuclear Regulatory Commission requirements (10CFR19), all individuals working in an area involving exposure to radiation or radioactive materials nnst 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, you should plan to attend ONE of the sessions below. To assist in preparation of handouts etc., please call the Padiation Safety Office at S-1015 or send your name to NEL 111 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 j i

• • ATTEND ONLY ONE SESSION ** I If you have any questions please call the Radiation Safety Office at 5-1015.

COURSE SYLLABUS I. Introduction to Radioactivity and Terminology 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 Riska from Ionizing Radiation .

A. Possible health effects of exposure to radiation I 1. Prompt effects 2. Delayed effects 3. Genetic effects III. Radiological Safety A. Principles of protection from external exposure B. Principles of protection from contamination and internal expcisure C. Radiation emergency procedures for laboratory accidents D. Waste disposal E. The worker's right to know and options F. Prenatal radiation exposure G; The As _L,ow As Reasonably Achievable (ALARA) concept Instruction will include lecture, audiovisual presentations and demonstrations.

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THE UNIVERSITY OF OKLAHOMA INTEROFFICE COMMUNICATION

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r, Users of Radioactive Material n.,, August 18, 1989 safety Training pr,. Radiation Safety 3 3,y,__{or New Personnel In-order to provide the NRC required safety training for personnel working )

with radioactive material or working in an area invo).ving exposure to radi- l ction, we will again be conducting the program on " RADIATION SAFETY FOR

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LABORA'!ORY PERSONNEL." The sessions will be conducted in the Personnel j l Services Seminar Room, NEL 215, on l

' l Monday, September 11, 1:15 pm - 4:45 pm i i Thursday, September 14, 1:15 pm - 4: 45 pm Friday, September 15, 8:15 am - 11:45 pm

• • ATTEND OttLY CEfE SESSICRI **

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-tanded such at this institution.

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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 Lon G ,

Noamow Fac e b e f T.

Individuals who will be attendino :

i Name Social Security # Which session?

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90-02S

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