IR 05000128/1992002: Difference between revisions

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=Text=
=Text=
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{{#Wiki_filter:November 5, 1992
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NUCLEAR REGULATORY COMMISSION    ,
N' ji    R EGION IV
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JAN 191993 Docket:- 50-128 Dr. Ken R. Hall Reactor Administrator Texas Engineering Experiment Station 301 WERC Texas A&M University College Station, Texas 77843 SUBJECT: NRC INSPECTION REPORT 50-128/92-02 Thank you for your letter of Decemoer 7,1992, in response to our letter and Notice of Violation dated November 5, 1992. We have reviewed your-reply and find it responsive to the concerns raised in our Notice of Violation. We will -review the implementation of your corrective actions during a futu e inspection to determine that full compliance has been acnieved anc will be maintainea.


Sincerely,
==SUBJECT:==
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Licensee Reply to Notice of Violation dated November 5,1992 (NRC INSPECT. ION REPORT 50128/92-02)
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Division of Radiation Safety and Safeguards-cc:
Dr. Daniel Reece
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College Station, Texas 77843 9301226011t930119-
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==Dear Sir:==
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The following response is submitted by the Texas Engineering Experiment Station (Licensee), a pan of the Texas A&M University System in regard to the notice of violation issued on November 5,1992 by the U. S. Nuclear Regulatory Commission, Region IV Office.
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Texas A&M University-


  -2-i M. E. McLain Radiation Safety Officer !'
Slated Violation A.
Texas A&M University College Station, Texas 77843 Texas State Department of Health 1100 West 49th Street Austin, Texas <87S6 Radiation Control Program Director Bureau of Radiation Control Dept. of Health 1100 West 49th Street Austin, Texas 78756-3189


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Texas A&M University license condition ll.C states in part that the license is subject to the conditions specified in 10CFR 50.59.10CFR 50.59 states that the holder of a license authorizing a production or utilization facility may make changes in the facility as described in the safety analysis report without prior Commission approval, unless the proposed change involves an unreviewed safety question.-
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Contrary to the above, between October 1991 and September 21,1992, the licensee made changes to the reactor building ventilation system by incorporating the exhaust system of the fume hoods located in the laboratory annex without performing an analysis to determine if (1) the probability of the occurrence or the consequences of an accident or malfunction of equipment related to safety may be -
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increased,(2) the possibility for an accident or an equipment malfunction of a different type other than previously evaluated may be created, or (3) the margin of safety as defined in the basis for any technical specifications is reduced.
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==REGION IV==
Licensee Resoonse A.
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f  AR LINGTON, TE XAS 760114064 JAN I 91993 Docket: 50-128 Dr. Ken R. Hall Reactor Administrator Texas Engineering Experiment Station 301 WERC Texas A&M University College Station, Texas 77843 SUBJECT: NRC INSPECTION REPORT 50-128/92-02 ThanK you for your letter of Decemoer 7,1992, in response to our letter and Notice of Violation dated Novemoer 5,1992. We have reviewed your reciy and find 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 cetermine that full compliance has ceen acnieved anc will be maintainea.


Sincerely
The licensee admits to the modification of the reactor building ventilation system.
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L: J. C~aT6 n, Director Division of Radiation Safety and Safeguards cc:
Dr. Daniel Reece Director Texas Engineering Experiment Station 301 WERC Texas A&M University ,
College Station, Texas 77843 D DOCK O Od 28    /A (
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It is the NSC management's opinion that this modification was approved under Modification Authorization (M A) #37 " Installation of an exhaust system for chemical hoods located in the NSC Laboratory building". Slight changes were made to this system to improve airflow and system balance. M A #37 states "The
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J. L. Milhoan, RA L. J. Callan, DRSS B. Murray, FIPS L. T. Ricketson, FIPS DRP DRS MIS Coordinator RIV File FIPS File    i Lisa Shea, RM/ALF (MS 4503)
T. Michaels, NRR Project Manager (MS 11 B20)
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Texas A&M University 1 .-2-M. E. McLain
- Radiation Safety Officer Texas-A&M University-College Station, Texas 77843-Texas State Department of Health.  ;
1100 West 49th-Street Austin,-Texas 78756 Radiation Control _ Program Director Bureau of Radiation Control Dept. of Health 1100 West 49th Street Austin,-Texas 78756-3189
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J. L. Milhoan, RA L. J. Callan, DRSS B. Murray, FIPS L. T. Ricketson, FIPS DRP DRS MIS Coordinator RIV File FIPS File Lisa Shea, RM/ALF (MS 4503)
T. Michaels, NRR Project Manager (MS 11 B20)
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Page 3 NRC December 7,1992 State Violation C.
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'l IWG10NIV-  1 U. S. Nuclear Regulatory Commission A'ITN: Document Control Desk Washington, D.C. 20555 Docket No: 50-128, License R-83 SUBJECT: Licensee Reply to Notice of Violation dated November 5,1992 (NRC INSPECT. ION REPORT 50128/92-02)
10CFR20.203(f) rec uires that each container of licensed material shall bear a durable, clearly visi)le label identifying the contents and shall bear the radiation caution symbol and the words, " CAUTION, RADIOACrlVE MATERIAL" or
" DANGER, RADIOACTIVE MATERIAL."


==Dear Sir:==
Licensee Resnonse C.
The following response is submitted by the Texas Engineering Experiment Station (Licensee), a pan of the Texas A&M University System in regard to the notice of violation issued on November 5,1992 by the U. S. Nuclear Regulatory Commission, Region IV Office.


Slated Violation A. Texas A&M University license condition ll.C states in part that the license is subject to the conditions specified in 10CFR 50.59.10CFR 50.59 states that the holder of a license authorizing a production or utilization facility may make changes in the facility as described in the safety analysis report without prior Commission approval, unless the proposed change involves an unreviewed safety question.-
The licensee admits to having three bags of unmarked waste placed in a temporary radioactive waste storage area. The storage area was appropriately marked as a radioactive materials area and the building was secured, with a door lock and a padlock. The only members of the NSC staff who have keys to this building were the llealth Physics staff and the Materials Control staff. Evaluation of the waste handling process, indicated a difference in interpretation of the procedure regarding the temporary storage of waste.
Contrary to the above, between October 1991 and September 21,1992, the licensee made changes to the reactor building ventilation system by incorporating the exhaust system of the fume hoods located in the laboratory annex without performing an analysis to determine if (1) the probability of the occurrence or the consequences of an accident or malfunction of equipment related to safety may be -
increased,(2) the possibility for an accident or an equipment malfunction of a different type other than previously evaluated may be created, or (3) the margin of safety as defined in the basis for any technical specifications is reduced.


Licensee Resoonse A. The licensee admits to the modification of the reactor building ventilation system.
Corrective Action
,
C.


It is the NSC management's opinion that this modification was approved under Modification Authorization (M A) #37 " Installation of an exhaust system for chemical hoods located in the NSC Laboratory building". Slight changes were made to this system to improve airflow and system balance. M A #37 states "The
As a result of the evaluation, the waste handling practices have been changed to ensure that the waste is tagged in accordance with the procedures. The SOP referenced above will also be revised to eliminate wording which resulted in the difference in interpretation. Of the tiiree bags noted in the inspection, two of these bags were filters which had recently been removed from our air handling units.
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These filters were waiting survey to verify that there was no radioactive material detectable. These filters were stored in the temporary waster storage area, because it is a secure area. In the future other storage locations will be used.
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Page 3 NRC December 7,1992 State Violation C. 10CFR20.203(f) rec uires that each container of licensed material shall bear a durable, clearly visi)le label identifying the contents and shall bear the radiation caution symbol and the words, " CAUTION, RADIOACrlVE MATERIAL" or
" DANGER, RADIOACTIVE MATERIAL."


Licensee Resnonse C. The licensee admits to having three bags of unmarked waste placed in a temporary radioactive waste storage area. The storage area was appropriately marked as a radioactive materials area and the building was secured, with a door lock and a padlock. The only members of the NSC staff who have keys to this building were the llealth Physics staff and the Materials Control staff. Evaluation of the waste handling process, indicated a difference in interpretation of the procedure regarding the temporary storage of waste.
Stated Violation D.


Corrective Action      ,
10CFR19.12 requires,in part, that all individuals working in or frequenting any portion of a restricted area he kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portion of the restricted area, and that the individuals shall be instructed in the health protection problems associated with exposure to such radioactive materials or radiation and in precautions or procedures to minimize exposure. Contrary to the above, experimenters and custodial staff members who had access to the reactor building and laboratory buildings during
C. As a result of the evaluation, the waste handling practices have been changed to ensure that the waste is tagged in accordance with the procedures. The SOP referenced above will also be revised to eliminate wording which resulted in the difference in interpretation. Of the tiiree bags noted in the inspection, two of these bags were filters which had recently been removed from our air handling units.


These filters were waiting survey to verify that there was no radioactive material detectable. These filters were stored in the temporary waster storage area, because it is a secure area. In the future other storage locations will be used.
August 1992 were not given proper instruction.


Stated Violation D. 10CFR19.12 requires,in part, that all individuals working in or frequenting any portion of a restricted area he kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portion of the restricted area, and that the individuals shall be instructed in the health protection problems associated with exposure to such radioactive materials or radiation and in precautions or procedures to minimize exposure. Contrary to the above, experimenters and custodial staff members who had access to the reactor building and laboratory buildings during 3 August 1992 were not given proper instruction.
Licensee Resnonse D.


Licensee Resnonse D. The licensee admits to having improper documentation of the instruction given to blue badged (full access / experimenter) and pink badged (limited access / physical -
The licensee admits to having improper documentation of the instruction given to blue badged (full access / experimenter) and pink badged (limited access / physical -
plant) personnel. The NSC management staff believes that all the badged personnel were trained in accordance with 10CFR19.12 criteria, but the documentation was not complete. For example, Keith Carsten, the blue badge example,'is a member of the Office of Radiological Safety's staff.
plant) personnel. The NSC management staff believes that all the badged personnel were trained in accordance with 10CFR19.12 criteria, but the documentation was not complete. For example, Keith Carsten, the blue badge example,'is a member of the Office of Radiological Safety's staff.
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Latest revision as of 16:31, 12 December 2024

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-128/92-02
ML20127G619
Person / Time
Site: 05000128
Issue date: 01/19/1993
From: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Hall K
TEXAS A&M UNIV., COLLEGE STATION, TX
References
NUDOCS 9301220011
Download: ML20127G619 (4)
v • d • e


Text

November 5, 1992

SUBJECT:

Licensee Reply to Notice of Violation dated November 5,1992 (NRC INSPECT. ION REPORT 50128/92-02)

Dear Sir:

The following response is submitted by the Texas Engineering Experiment Station (Licensee), a pan of the Texas A&M University System in regard to the notice of violation issued on November 5,1992 by the U. S. Nuclear Regulatory Commission, Region IV Office.

Slated Violation A.

Texas A&M University license condition ll.C states in part that the license is subject to the conditions specified in 10CFR 50.59.10CFR 50.59 states that the holder of a license authorizing a production or utilization facility may make changes in the facility as described in the safety analysis report without prior Commission approval, unless the proposed change involves an unreviewed safety question.-

Contrary to the above, between October 1991 and September 21,1992, the licensee made changes to the reactor building ventilation system by incorporating the exhaust system of the fume hoods located in the laboratory annex without performing an analysis to determine if (1) the probability of the occurrence or the consequences of an accident or malfunction of equipment related to safety may be -

increased,(2) the possibility for an accident or an equipment malfunction of a different type other than previously evaluated may be created, or (3) the margin of safety as defined in the basis for any technical specifications is reduced.

Licensee Resoonse A.

The licensee admits to the modification of the reactor building ventilation system.

It is the NSC management's opinion that this modification was approved under Modification Authorization (M A) #37 " Installation of an exhaust system for chemical hoods located in the NSC Laboratory building". Slight changes were made to this system to improve airflow and system balance. M A #37 states "The

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,

,

.

.

.

-

  • +

,

.-

Page 3 NRC December 7,1992 State Violation C.

10CFR20.203(f) rec uires that each container of licensed material shall bear a durable, clearly visi)le label identifying the contents and shall bear the radiation caution symbol and the words, " CAUTION, RADIOACrlVE MATERIAL" or

" DANGER, RADIOACTIVE MATERIAL."

Licensee Resnonse C.

The licensee admits to having three bags of unmarked waste placed in a temporary radioactive waste storage area. The storage area was appropriately marked as a radioactive materials area and the building was secured, with a door lock and a padlock. The only members of the NSC staff who have keys to this building were the llealth Physics staff and the Materials Control staff. Evaluation of the waste handling process, indicated a difference in interpretation of the procedure regarding the temporary storage of waste.

Corrective Action

,

C.

As a result of the evaluation, the waste handling practices have been changed to ensure that the waste is tagged in accordance with the procedures. The SOP referenced above will also be revised to eliminate wording which resulted in the difference in interpretation. Of the tiiree bags noted in the inspection, two of these bags were filters which had recently been removed from our air handling units.

These filters were waiting survey to verify that there was no radioactive material detectable. These filters were stored in the temporary waster storage area, because it is a secure area. In the future other storage locations will be used.

Stated Violation D.

10CFR19.12 requires,in part, that all individuals working in or frequenting any portion of a restricted area he kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portion of the restricted area, and that the individuals shall be instructed in the health protection problems associated with exposure to such radioactive materials or radiation and in precautions or procedures to minimize exposure. Contrary to the above, experimenters and custodial staff members who had access to the reactor building and laboratory buildings during

August 1992 were not given proper instruction.

Licensee Resnonse D.

The licensee admits to having improper documentation of the instruction given to blue badged (full access / experimenter) and pink badged (limited access / physical -

plant) personnel. The NSC management staff believes that all the badged personnel were trained in accordance with 10CFR19.12 criteria, but the documentation was not complete. For example, Keith Carsten, the blue badge example,'is a member of the Office of Radiological Safety's staff.

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