|
|
Line 2: |
Line 2: |
| | number = ML20066L353 | | | number = ML20066L353 |
| | issue date = 01/28/1991 | | | issue date = 01/28/1991 |
| | title = Responds to NRC 901227 Ltr Re Violations Noted in Insp Rept 50-199/90-02 on 901210-12.Corrective Actions:Gamma Monitors Will Be Calibr Against Calibr Survey Instruments Using Outside Source Prior to Loading Low Enriched Fuel | | | title = Responds to NRC Re Violations Noted in Insp Rept 50-199/90-02 on 901210-12.Corrective Actions:Gamma Monitors Will Be Calibr Against Calibr Survey Instruments Using Outside Source Prior to Loading Low Enriched Fuel |
| | author name = Berlin R | | | author name = Berlin R |
| | author affiliation = MANHATTAN COLLEGE, RIVERDALE, NY | | | author affiliation = MANHATTAN COLLEGE, RIVERDALE, NY |
Line 11: |
Line 11: |
| | contact person = | | | contact person = |
| | document report number = NUDOCS 9102070005 | | | document report number = NUDOCS 9102070005 |
| | | title reference date = 12-27-1990 |
| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE |
| | page count = 3 | | | page count = 3 |
Latest revision as of 15:09, 31 May 2023
|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20204H0361999-03-23023 March 1999 Forwards Amend 12 to License R-94 & Safety Evaluation.Amend Removes Authority from License to Operate Reactor & Authorizes Possession Only of Reactor.Amend Also Approves Decommissioning Plan ML20204B9211999-03-16016 March 1999 Forwards Environ Assessment & Finding of No Significant Impact Re Application for Amend 971218.Proposed Amend Would Amend License R-94 to Reflect That License Authorizes Possession But Not Operation of Reactor ML20199E0661999-01-0606 January 1999 Submits Criteria for Releasing Matl from Manhattan College Zero Power Reactor as Described in Section 8.1 of Decommissioning Plan Will Be Same as Those Previously Stated for Paragraph 3.2.2 ML20195E4201998-11-10010 November 1998 Confirms Earlier Conversation About Possibility of Criticality During Storage as Result of Fire Sprinklers in Fuel Storage Area ML20155F0181998-10-29029 October 1998 Informs That CC Stanton Verified with Manhattan College Provost,Second $30,000 Deposit Has Been Made to Reactor Decommissioning Fund as Described in ML20151P3781998-07-21021 July 1998 Forwards Addl Info Re Planned Decommissioning of Facility. Licensee Fully Prepared to Cover Costs Associated W/ Decommissioning & Will Adjust Transfers to Escrow Account According to Approved Plan & Schedule ML20236S4261998-07-20020 July 1998 Forwards Copy of Recently Approved Regulation in Fr Which Permits Colleges & Univs to self-guarantee Decommissioning Costs If Certain Criteria Are Met.Requests Provision of Criterion to Be Used If School Decides to self-guarantee ML20198M1111997-12-18018 December 1997 Informs That Licensee Wishes to Terminate License to Operate non-power Reactor,Iaw Requirements of 10CFR50.82.Encl Contains, Decommissioning Plan Manhattan College Zero Power Reactor ML20198E9891997-08-0505 August 1997 Informs That Responsibility for Non-Power Reactor Insp Program Has Been Transferred from Regional Ofc to Nrr. Addresses Listed ML20210J4711997-07-0707 July 1997 Forwards Insp Rept 50-199/97-201 on 970605.No Noncompliance or Significant Issues Noted NUREG-1534, Forwards Chapter 17 Part 1 & 2 of NUREG-1537 Re Decommissioning & Possession Only License Amends.Format That Should Be Followed for Decommissioning Plan Given in App 17.1,which Lays Out step-by-step Info Required.W/O Encl1997-05-14014 May 1997 Forwards Chapter 17 Part 1 & 2 of NUREG-1537 Re Decommissioning & Possession Only License Amends.Format That Should Be Followed for Decommissioning Plan Given in App 17.1,which Lays Out step-by-step Info Required.W/O Encl ML20138D2481997-04-24024 April 1997 Informs That Manhattan College Wishes to Cease Operation of Manhattan College Zero Power Reactor & Taking Necessary Steps & Procedures Mandated to Decommission Reactor ML20137P1781997-04-0202 April 1997 Responds to NRC Re Violations Noted in Insp Rept 50-199/96-01.Corrective Actions:Core Has Been Defueled W/ Elements Placed in Storage ML20134B7471997-01-28028 January 1997 Requests That NRC Be Informed of Plan for Future Use of Mczpr ML20134B5641997-01-23023 January 1997 Forwards Insp Rept 50-199/96-01 on 961209-12 & Notice of Violation ML20078E6691995-01-19019 January 1995 Forwards Revised Physical Security Plan.Plan Withheld Per 10CFR73.21 ML20078A1241995-01-17017 January 1995 Forwards Accelerated Operator Requalification Plan for Reactor & List Names of Two Operators Affected by Implementation of Program ML20076H0091994-10-11011 October 1994 Follows-up on Recent Conversation to Propose Mod to Reactor License R-94 & to Manhattan College Zero Power Reactor TS ML20058Q2181993-10-18018 October 1993 Forwards Insp Rept 50-199/93-02 on 930929.No Violations Noted ML20044G7681993-05-26026 May 1993 Advises That,Effective 930615,author Will Be Resigning as Reactor Administrator & RSO & Will Be Replaced by W Duggan. C Stanton Will Assume Position of Chief Reactor Supervisor ML20128F8251993-02-0505 February 1993 Forwards Insp Rept 50-199/93-01 on 930119-20.No Safety Concerns or Violations Noted ML20066L0311991-01-29029 January 1991 Requests Amend to Paragraph A,Number 2.B.(2),Line 3 of 900312 Order Modifying License R-94,requiring Conversion to Low Enriched U Fuel.Amend Will Increase Possession Limit of Contained U-235 from 3.8 Kg to 3.9 Kg ML20066L3531991-01-28028 January 1991 Responds to NRC Re Violations Noted in Insp Rept 50-199/90-02 on 901210-12.Corrective Actions:Gamma Monitors Will Be Calibr Against Calibr Survey Instruments Using Outside Source Prior to Loading Low Enriched Fuel ML20066K7251991-01-10010 January 1991 Expresses Thanks for Info on Results of 910107 Meeting W/ Manhattan College Re Reactor Violations & Radiological Health Inadequacies ML20059K2231990-09-14014 September 1990 Lists Factors Relevant to Cost Estimates for Decommissioning Nuclear Reactor Per 10CFR50.33(K) & 50.75.No Decommissioning Funding Vehicle Required ML20056A5311990-08-0606 August 1990 Advises That Response to Requirements of 10CFR50.33K & 50.75 Re Plan for Future Availability of Decommissioning Funds to Decommission Reactor Will Be Provided by 900930 ML20055H3141990-07-19019 July 1990 Advises That Reactor Operator Licensing Written & Operating Exams Scheduled for 900920 & 21,respectively.Encl Ref Matl Requested by 900727 ML20044A2411990-06-0606 June 1990 Advises That W Duggan Will Replace J Hu as Chief Reactor Supervisor at Beginning of Fall 1990 Semester in Aug 1990. Fuel Elements Removed from Reactor & Placed in Storage Containers Prior to J Hu Departure ML20006F0281990-02-13013 February 1990 Details Responses in 900124 Telcon W/B Carter Re Aspects of Procedure, Experiments for Reactor Power Level Determination Sent to NRC w/891212 Ltr ML20011D6111989-12-12012 December 1989 Forwards Responses to Items 1,2 & 3 of 891030 Ltr Re High Enriched U/Low Enriched U Conversion at College.Anticipates Shipping Spent Fuel as Scrap to ORNL Using 6M Shipping Containers ML20042E5391989-08-10010 August 1989 Forwards Response to Questions Re High Enriched U/Low Enriched U Conversion,Per NRC 890710 Ltr ML20245L4811989-08-10010 August 1989 Forwards Response to Questions Raised in Re Heu/ LEU Conversion at Facility ML20246F8471989-07-10010 July 1989 Forwards Questions Re High Enriched U/Low Enriched U Conversion at Univ.Tech Spec Sections,Needed to Accomodate Conversion,Should Be Resubmitted & Preparation of Emergency Shutdown Rod for Use in Event of Error Explained ML20247K8211989-05-19019 May 1989 Forwards Revised Conversion of Manhattan College Zero Power Reactor to LEU Fuel. Summary Table Page Corrected ML20246P3521989-03-22022 March 1989 Forwards Agenda for 890418-19 Research & Test Reactor Seminars in King of Prussia,Pa.Updated Agenda to Follow.Map of Local Area Also Encl ML20204B9281988-10-13013 October 1988 Requests Updated Conversion Schedule for low-enriched Fuel to Properly Plan Review & Safety Analysis Which Was to Have Been Submitted by 870831 as Indicated by Schedule ML20150D8641988-03-18018 March 1988 Informs of Relocation of NRR to Rockville,Md.Official Mailing Address Still Remains Same & Project Managers Have New Locations & Phone Numbers.Ts Michaels Still Lead Project Manager for Facility & a Adams Will Serve as Backup ML20236W4901987-11-30030 November 1987 Forwards Insp Rept 50-199/87-02 on 871022-23.Insp Indicates That Radiological Controls Program Associated W/Research Reactor Well Managed & That Tech Spec Requirements Being Implemented.Areas Requiring Improvement Detailed in Rept ML20236Q5861987-11-13013 November 1987 Forwards Safeguards Insp Repts 50-199/87-01 & 70-2951/87-01 on 871007 & 08.No Violations Noted ML20215D6811987-06-11011 June 1987 Informs of Recent NRR Reorganization.T Michaels Will Be New Project Manager ML20214V0931987-05-27027 May 1987 Informs of Recent Realignment within NRC Region I,Div of Reactor Projects That Affects Responsibility for Insp of Research & Test Reactor Facilities.Div Organization Chart & 10CFR50 & 51 Re Communications Procedures Amends Encl ML20206U2631987-04-20020 April 1987 Ack Receipt of Proposed Schedule for Conversion of Reactor from High Enriched to Low Enriched U,Submitted Per 10CFR50.64(c)(2)(i).Requests That TS Michaels Be Informed of Any Changes or Updates to Proposed Schedule ML20205M0971987-03-26026 March 1987 Forwards Amend 7 to License R-94 & Safety Evaluation.Amend Authorizes Reactor Administrator to Assume Added Position & Duties of Radiation Safety Officer.Administrative Inconsistency Also Corrected,Per 870225 Telcon ML20205B4251987-03-25025 March 1987 Submits Proposal for Conversion of High Enriched U Fuel to Low Enriched U Fuel.Proposal Covers Status of DOE Funding, Content of SAR & Schedule for Accomplishing Full Conversion Program ML20207P4481987-01-0909 January 1987 Forwards Exam Rept 50-199/86-03OL of Partial Written Exam Administered on 861203 ML20207P4621986-12-10010 December 1986 Forwards Comments on Answers to Questions H.01 & H.11 of Section H, Reactor Theory, Re Test Administered to R Berlin ML20207H4701986-07-11011 July 1986 Forwards Exam Rept 50-199/86-02 of Exam Administered on 860603-04 IR 05000199/19720011986-07-0808 July 1986 Forwards Amend 3,terminating License 50-19972-01,per 860530 Request ML20205T2961986-06-10010 June 1986 Forwards Insp Rept 50-199/86-01 on 860513-15.No Violations Noted.Inspector Identified Need for Improving Maint & Surveillance Procedures ML20140J4641986-03-27027 March 1986 Informs That TC Elsasser Will Replace EC Mccabe as Cognizant Section Chief for Facility,Effective on 860331,based on Project Realignment.Ec Wenzinger Will Remain Branch Chief 1999-03-23
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20199E0661999-01-0606 January 1999 Submits Criteria for Releasing Matl from Manhattan College Zero Power Reactor as Described in Section 8.1 of Decommissioning Plan Will Be Same as Those Previously Stated for Paragraph 3.2.2 ML20195E4201998-11-10010 November 1998 Confirms Earlier Conversation About Possibility of Criticality During Storage as Result of Fire Sprinklers in Fuel Storage Area ML20155F0181998-10-29029 October 1998 Informs That CC Stanton Verified with Manhattan College Provost,Second $30,000 Deposit Has Been Made to Reactor Decommissioning Fund as Described in ML20151P3781998-07-21021 July 1998 Forwards Addl Info Re Planned Decommissioning of Facility. Licensee Fully Prepared to Cover Costs Associated W/ Decommissioning & Will Adjust Transfers to Escrow Account According to Approved Plan & Schedule ML20198M1111997-12-18018 December 1997 Informs That Licensee Wishes to Terminate License to Operate non-power Reactor,Iaw Requirements of 10CFR50.82.Encl Contains, Decommissioning Plan Manhattan College Zero Power Reactor ML20138D2481997-04-24024 April 1997 Informs That Manhattan College Wishes to Cease Operation of Manhattan College Zero Power Reactor & Taking Necessary Steps & Procedures Mandated to Decommission Reactor ML20137P1781997-04-0202 April 1997 Responds to NRC Re Violations Noted in Insp Rept 50-199/96-01.Corrective Actions:Core Has Been Defueled W/ Elements Placed in Storage ML20078E6691995-01-19019 January 1995 Forwards Revised Physical Security Plan.Plan Withheld Per 10CFR73.21 ML20078A1241995-01-17017 January 1995 Forwards Accelerated Operator Requalification Plan for Reactor & List Names of Two Operators Affected by Implementation of Program ML20076H0091994-10-11011 October 1994 Follows-up on Recent Conversation to Propose Mod to Reactor License R-94 & to Manhattan College Zero Power Reactor TS ML20044G7681993-05-26026 May 1993 Advises That,Effective 930615,author Will Be Resigning as Reactor Administrator & RSO & Will Be Replaced by W Duggan. C Stanton Will Assume Position of Chief Reactor Supervisor ML20066L0311991-01-29029 January 1991 Requests Amend to Paragraph A,Number 2.B.(2),Line 3 of 900312 Order Modifying License R-94,requiring Conversion to Low Enriched U Fuel.Amend Will Increase Possession Limit of Contained U-235 from 3.8 Kg to 3.9 Kg ML20066L3531991-01-28028 January 1991 Responds to NRC Re Violations Noted in Insp Rept 50-199/90-02 on 901210-12.Corrective Actions:Gamma Monitors Will Be Calibr Against Calibr Survey Instruments Using Outside Source Prior to Loading Low Enriched Fuel ML20066K7251991-01-10010 January 1991 Expresses Thanks for Info on Results of 910107 Meeting W/ Manhattan College Re Reactor Violations & Radiological Health Inadequacies ML20059K2231990-09-14014 September 1990 Lists Factors Relevant to Cost Estimates for Decommissioning Nuclear Reactor Per 10CFR50.33(K) & 50.75.No Decommissioning Funding Vehicle Required ML20056A5311990-08-0606 August 1990 Advises That Response to Requirements of 10CFR50.33K & 50.75 Re Plan for Future Availability of Decommissioning Funds to Decommission Reactor Will Be Provided by 900930 ML20044A2411990-06-0606 June 1990 Advises That W Duggan Will Replace J Hu as Chief Reactor Supervisor at Beginning of Fall 1990 Semester in Aug 1990. Fuel Elements Removed from Reactor & Placed in Storage Containers Prior to J Hu Departure ML20006F0281990-02-13013 February 1990 Details Responses in 900124 Telcon W/B Carter Re Aspects of Procedure, Experiments for Reactor Power Level Determination Sent to NRC w/891212 Ltr ML20011D6111989-12-12012 December 1989 Forwards Responses to Items 1,2 & 3 of 891030 Ltr Re High Enriched U/Low Enriched U Conversion at College.Anticipates Shipping Spent Fuel as Scrap to ORNL Using 6M Shipping Containers ML20245L4811989-08-10010 August 1989 Forwards Response to Questions Raised in Re Heu/ LEU Conversion at Facility ML20042E5391989-08-10010 August 1989 Forwards Response to Questions Re High Enriched U/Low Enriched U Conversion,Per NRC 890710 Ltr ML20247K8211989-05-19019 May 1989 Forwards Revised Conversion of Manhattan College Zero Power Reactor to LEU Fuel. Summary Table Page Corrected ML20205B4251987-03-25025 March 1987 Submits Proposal for Conversion of High Enriched U Fuel to Low Enriched U Fuel.Proposal Covers Status of DOE Funding, Content of SAR & Schedule for Accomplishing Full Conversion Program ML20207P4621986-12-10010 December 1986 Forwards Comments on Answers to Questions H.01 & H.11 of Section H, Reactor Theory, Re Test Administered to R Berlin ML20137N8601985-11-19019 November 1985 Responds to 850927 Order to Show Cause to Describe Unirradiated High Enriched U Fuel Onsite & Future Possession.Three Fuel Plates,Containing 13 G U,In Possession.Plates Will Remain in Secure Status ML20128L0301985-05-14014 May 1985 Advises That Effective 850701,author Will No Longer Be Reactor Administrator.Requests Deletion of Name & Addition of Re Berlin on Mailing Label for IE Notices ML20128L4661985-05-14014 May 1985 Notifies That Effective 850701,author Will No Longer Be Reactor Administrator.Requests Deletion of Name & Addition of Re Berlin on Mailing Lists & License Activities ML20099M3091985-03-15015 March 1985 Forwards Rev 4 to Tech Specs,Per Feb 1985 Requests ML20101S5811985-01-29029 January 1985 Confirms Full Implementation of Emergency Plan,Per NRC 841010 Request ML20099D3791984-11-15015 November 1984 Forwards Rev 2 to Tech Specs for Manhattan College Zero Power Reactor,Requested During 840918-19 Site Visit.Response to NRC Final Questions Submitted on 841026.Commitments from Site Visit Complete ML20097A1571984-08-29029 August 1984 Forwards Preliminary Questions Resulting from Review of Proposed License Renewal Documentation for Manhattan College Zero Power Reactor.Tech Specs Adequate for Review But Deviated Somewhat from Format of ANSI 15.1 ML20094P8421984-08-13013 August 1984 Forwards Proprietary Financial Info Required for Renewal of License R-94 & Environ Rept, Per 840702 Telcon.Proprietary Info & Rept Withheld (Ref 10CFR2.790) ML20091H7611984-06-0101 June 1984 Forwards Rev 3 to Operator Requalification Program ML20083H5911984-01-0909 January 1984 Responds to Re Implementation of Operator Requalification Program.Categories Included in Licensed Operator Exam Listed ML20080S4911983-08-17017 August 1983 Responds to NRC Re Violations Noted in IE Insp Rept 50-199/83-01.Corrective Actions:Requalification Program Will Be Conducted Continuously Over 2-yr Cycles & Revised as Needed to Account for Changes in Equipment ML20080S4771983-08-0505 August 1983 Responds to NRC Re Violations Noted in IE Insp Rept 50-199/83-01.Requests 3-wk Extension to Provide Complete Reply Due to Changes in Personnel.Extension Will Enable Implementation of Operator Requalification Program ML20072G2271983-06-21021 June 1983 Notifies That G Kane Appointed Chief Reactor Supervisor, Effective 830702.Appointment Will Be Noted in License Renewal Application Being Prepared ML20065T8131982-10-29029 October 1982 Forwards Amended Physical Security Plan.Plan Withheld (Ref 10CFR2.790) ML20069L0801982-10-29029 October 1982 Forwards Public Version of Emergency Plan ML20065J0261982-09-28028 September 1982 Requests Guidance on Procedure for Renewal of 10-yr License R-94,which Expires on 830930 ML20052B2901982-04-22022 April 1982 Ack Receipt of 820311 Ltr Approving Revised Security Plan for License R-94.NRC Position Re Releasing Security Info to Local Govts Requested ML20078P1071981-10-11011 October 1981 Forwards Notarized Application for Renewal of License R-94, Per 830919 ltr,831003 Telcon & Approving Physical Security Plan.W/O ML20010D9691981-08-26026 August 1981 Forwards Figures Inadvertently Omitted from 810819 Ltr. Figures Withheld (Ref 10CFR2.790) ML19250B8551979-10-23023 October 1979 Forwards Executed Amend 11 to Indemnity Agreement E-41 Modifying Prefatory Language Re Course of Transportation ML19249D5181979-08-15015 August 1979 Responds to IE Bulletin 79-19 Re Disposal of Radwaste.No Radwaste Produced ML19249D6641979-07-0303 July 1979 Responds to NRC 790628 Ltr Re Violations Noted in IE Insp Rept 50-199/79-02.Corrective Actions:Emergency Procedure Posted Outside Zero Power Reactor Door 1999-01-06
[Table view] |
Text
. _ _ _ _ . _ - - _ - . - - _ - . _ - _ _ _ - _ _ _ _ _ _ - _ - _ - _ _ _ -
- +
ManheMan MANHATTAN COLLEGE PARCIWAY MECHANICAL ENOf4EERING DEPARTMENT RIVERDALE, NEW YORK 10471
.. (212) 920-0145 January 28,1991 4 U. S. Nuclear Regulatory Commission A*ITN: Document Control Desh Washington D.C. 20555 Reolv to a notite of violation
Subject:
Manhattan College Zero Power Reactor (MCZPR)
Docket No. 50-199, License No. R 94 Inspection No. 50-199/90 02 Letter, J. Joyner, NRC to R. Derlin of December 27,1990 Gentlemen: a Your letter of December 27,1990 transmitted, as enclosure A, a notice of violation iuenti-fying two violations of NRC requirements, and inspection report no. 50-199/90-02 documenting )
the results of an inspection performed on December 10-12,1990. The inspection report noted the existence of "several weaknesses" in our radiological protection and measurements program in addition to the two violations. The violations and weaknesses and our potential actions to cor-rect bcse situations were discussed at a meeting at Manhattan College on January 7,1991. This reply responds to the two violations; our actions to correct the weaknesses in the program are discussed in a separate response.
Violadon A "The two radiation monitoring channels of the Radiation Monitoring System had not been calibrated for at least the last three years". This violates MCZPR Technical Specifica-tion 4.7.3.A "" Radiation Monitoring System" that requims that a calibration of these two radi-ation monitoring channels be performed at least annually.
Reply:
1; The Reason For The Violation - The situation was originally noted as a " weakness" in the program in the inspection report 50199/87-02 prepared by Mr. S. Sherbini dated 11/23/87. As discussed in this report, and recently verified in conversation with him, the famier chief reactor supervisor Dr. Hu stated that he conducted operability and calibra-tion test of the two gamma radiatior monitors " regularly" but did not record this fact in the log. .However, as Mr. Sherbini's inspection report indicates (and discussed in our meeting of January 7,1991), calibrations are conducted near the low end of the scale on the monitor channels (up to 1.5 mr/hr) and it was suggested they be performed at higher dose rates (to at least the 6 mr/hr and 10mr/hr trip points for the two instruments)
/
- 9t02070005 910128 I ADOCK 05000199 l v s {DR ..
PDR
'V In response to this weakness noted by Mr. Sherbini, our consulting health physicist Dr.
Malsky developed a proposed approach pennitting calibration at higher dose rates which was dhcussed with Mr. Sherbini on the phone and transmitted in a letter dated 11/13/87 from Dr. Hu. No response was received. Subsequent inspections by the NRC did not note the uistence of this item as a weakness until the inspection performed by Mr. Austin on Dece.mber 10-12,1990 which resulted in the issuance of this violation.
Further, the reactor he not had fuel in it since November 1989. Thus no operation other than mainte. nance has been perfonned since that time. We are proceeding to cor-rect this violation.
- 2. Corrective steps that have been taken - the portable survey instruments have been cali-brated at NDL during January,1991, and arrangements have been made through our health physicist to use a source of sufficient strength to provide the calibration up to at least the T.S. trip points for the instruments. This approach will only be used prior to loading of the new LEU fuelin February. Actions have been initiated to obtain our own source to permit future calibrations at the higher dose rates.
- 3. Corrective actions that will be taken as noted above, the gamma monitors will be cali-brated against the calibrated survey instruments using an outside source prior to r.he loading of the LEU fuelin February. This procedure will be documented in the Log Dook. The necessary license will be obtained and a source purchased for future calibra-tions of the monitors. The calibration will be performed at least annually, with the next calibration done no later than January 1992. All future calibrations will be documented in the Log Book.
- 4. Date When Full Compliance Will Be Achieved - compliance with the T.S. n:quirements will be achieved with the calibration to be performed prior to the February fuel loading.
We understand that 2-3 months may be required to obtain our own calibration source.
' Violation m "--- the Reactor Operations Committee had not caused a biennial audit to be per-
, - formed by an outside individual or group familiar with the research reactor operations within at least the last thn:e years".
l Reply
. 1. Reason for the Violation - The audit has not been conducted in part because the Reactor has not been operable for an extended period during which maintenance was being con-ducted. Personnel changes were also made in the position of Chief Reactor Supervisor and membership on the Reactor Operations Committee (ROC). It was felt that the audit l _ could be deferred until a more stable situation existed.
l l
-e e I
- 2. Corrective Steps That Have Been Taken - Arrangements have been made for Mr. Wil-Ilam G. Ruzicka of Consolidated Edison's staff at Indian Point 2 to conduct the audit during February,1991. Mr. Ruzicka is a highly qualified individual who was formerly Manager of Nuclear Operations at Cintichem. lie is quite familiar with reactor opera-tions audit procedures and safety requirements and is curn:ntly a Management Opera-tions Analyst at Con Edison.
- 3. Corrective Steps That Will Be Taken Mr. Ruzicka will conduct an audit of the safety aspects of reactor facility operations and prepare a report to the ROC documenting the results of the audit. The ROC will review the audit report and assure that its findings are implemented through corrective actions or are eatisfied through further explanation or documentation. Responses to the audit report will be documented and provided to Mr.
Ruzicka. Both the audit and documented response will be kept on file for NRC review during subsequent inspecticas.
- 4. Date When Full Compliance _Will Be Achieved - The initial audit will be completed by Mr. Ruzicka by the end of February,1991. Subsequent audits will be conducted at no greater than biennial intervals.
I believe the actions described above should result in elimination of violations A & B.
Please let us 1:now if further action or clarification is required.
Sincerely, r ,
Ih Robert E. Berlin Reactor Administrator cc. Regional Administrator, Region 1 M. Austin, NRC Inspector, Region 1 U. S. Nuclear Regulatory Commission Region 1 475 Allendale Road King Prussia, Pennsylvania 19406 Dr. William Duggan Dr. Vincent Antonetti Dr. Joseph Lestingi .