IR 05000112/1987001

Ack Receipt of 870414,0529 & 0720 Ltrs Informing NRC of Steps Taken to Correct Violtaions Noted in Insp Rept 50-112/87-01.Addl Info Re Violation a Provided in Adequate to Resolve Concerns,Per 870617 Telcon

ML20238A241
Person / Time
Site:	05000112
Issue date:	09/03/1987
From:	Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Egle D OKLAHOMA, UNIV. OF, NORMAN, OK
References
NUDOCS 8709090204
Download: ML20238A241 (2)

Text

I c5 > SEP 3 1987 In Reply Refer To:

Docket: 50-112/87-01 The University of Oklahoma ATTN: Dr. Davis M. Egle Director, AMNE 865 Asp Ave., Roon 212 Norman, Oklahoma 73019 Gentlemen:

Thank you for your letters of April 14, May 29, and July 20, 1987, in rcsponse to our letters and Notice of Violation dated March 16, 1987. Jr. your May 29, 1987, letter you stated that you did not feel that Violation A regarding the requirement to maintain contamination survey records in units of disintegrations per urit time or in curies had occurred. The bases for the Violation were discussed during a telephone conversation on June 17, 1987, between Messrs. Craig Jensen and Paul Skierkowski of your staff and Messrs. Blaine Murray and Ronald Baer of this office. Based on the results of the telephone conversation, your staff agreed to provide additional infor;2ation concerning corrective actions for Violation A. This additional information was provided in your July 20, 1987, letter and we find that your response is adequate to resolve our concerns.

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, ORIGINAL SIGNED BY:

Lawrence A. Yandell, Chief Radiological Protection and Safeguards Branch CC:

University of Oklahoma University of Oklahoma ATTN: Dr. E. H. Klehr, Chairman ATTN: Dr. C. Jensen, Reactor Director Reactor Safety Committee AMNE 865 Asp Avenue 865 Asp Avenue Norman, Oklahoma 73019 Norman, Oklahoma 73019 i

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• • • e-SCHOOL OF AEROSPACE, MECHANICAL '- I'

l AND NUCLEAR ENGINEERING l 865 Ato Avenue, Room 212 i

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Norman. Oklahoma 73019 Juiy 20, 1987 Hos) 325 5011 l

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Mr. J. F. Gagliardo, Chief Renetor I'rojects Branch USNRC - Region IV Gil Ryan Plaza Drive Sulte 1000 Arlington, TX 76011 Docket: 50-112/87-01 License: R-53

Dear Mr. Gagliardo:

You will find aLLached a ecp> of the updated Laboratory Sursey Report showing "LSC Efficiencies" for H-3 and C-14. As iridicated by Mr. Baer during a recent teicphone conversation, this will meet your requirements and violation A should be closed. 1 also understand that our reply to violations B and C have been accepted and that no further reply on our part. is necessary.

Sincerely yours,

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J[nsen Craigbr.

React DJ' rector CMJ/ujb i

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RADIATION SAFETY OFFICE - UNIVERSITY OF OKLAHOMA

LABORATORY SURVEY REPORT DATE N 106 User Rad. Safety Radioactive Material in use various L:boratory um TYPE survey conducted 4 p . t.b '

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1 x NOTES: Y Z = Room 105 Liquid Waste Storage Area Z CHECKS:

LSC Efficiencies H-3 C-14 NRC-3 posted Radioactive material sign on entry Storage & work areas posted Waste containers posted Emergency procedures posted Next survey scheduled for RSO Review Date

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University ofOklahoma School oF AEROSPACE,9AECHANICAL AND NUCLEAR ENGINEERING B65 Asp Avenue. Room 212 NS$7 May 29, 1987 Mr. Lawrence A. Yandell, Chief

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l Radiological Protection and Safeguards Branch USNRC - Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011

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Docket: 50-112/87-01 License: R-53

Dear Mr. Yandell:

The follwing is in response to y>ur letter of May 20, 1987.

Licensee's Response to Violation A Although some data is taken in units of cpm instead of dpm, we do not feel that a violation has occurred. Therefore, we do not admit a violation and our reasons are as stated in the succeeding paragraphs.

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The purpose of a survey swipe is generally to detect the presence of contamination that is not detectable by means of a survey instrument (eg. 94 survey meter) calibrated in the desired units. It further can confirm if contamination detected by a survey instrument is " removable" and if necessary It is the identity of the radionuclides often can be ascertained from such a swipe.

not necessary to convert from cpm to dpm (in liquid scintillation samples) to If ascertain that contamination exists and has been "rsoved" by a swipe test.

the output date from the scintillation counter indicates theChanging presencethe of units contamination then decontamination actions are initiated.

from cpm to dpm would have no effect upon this action p*ocedure.

As reported in our letter of 14 April 87, standards are utilized "where applicable" in our assay procedures and conversion to dx or uCiSimilarly, is made for ourany sample where necessary to compare to the regulatory standard.

survey meters are calibrated to give mR/hr readings which can be compared to regulartory ection levels. There is NO NRC standard or action level (in any radiation units) specifying levels of contamination detected by laboratory area swipes which require action. This fact was not only pointed out to the inspector at the time of the briefing but when queried he admitted he was unable to show us any standard for survey swipes. All he could do was cite 10CFR20.5 concerning the units.

Enclosed are blank forms we utilize for surveys of the nuclear laboratory and associated rooms.

Please note that for each survey point there are tw_o measurements. An mR/nr field is measured with a properly calibrated survey b' hfM t

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Mr. Lawrence Yandell May 29, 1987 Page Two instrument in the desired units and a swipe is made of the surface (for the purposes described above). We believe that these procedures more than meet the NRC requirements and request your reevaluation of this violation in light of this l additional infomation. Should you still feel we are in violation we would be l

willing to visit with pu at your regional office and present any other

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supporting documentation you may request or provide any further explanations.

Licensee's Response to Violation B 1) Admitted, the letter was out of date and overlooked. If this its is a violation and "ite-of-noncompliance" is not an alternative, as suggested by pur I

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letter, then the inspector who visited the facility should be instructed in proper procedure.

2) A letter from the Noman Regional Hospital was obtained and a copy sent with our letter of 14 April, which indicates that they will reply to the emergency needs of the facility. As pointed out by the NRC, the letter has no expiration date.

3) The letter has no expiration date, therefore, it will not expire and the violation cannot reoccur. Therefore, corrective action has been taken.

4) Full compliance was achieved as of the date of our previous letter dated April 14, 1987.

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Licensee's Reponse to Violation C 1) Admitted, the Norman fire personnel and University Police were not trained by their training officers in the procedures to be followed when responding to alarms at the reactor facility.

2) The Noman Fire Chief and University Police Chief will be required to submit to the licensee on an annual basis that training for all personnel that may respond to an emergency at the reactor facility has been perfomed. Assistance by the reactor and radiation safety office will be offered for this training.

3) Tne verification from the proper authority will be required annually.

4) The date of full compliance will be December 31, 1987.

Sincerely yo s, Crai M. ensen Rea tor irector CMJ/sjb

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RADIATION SAFETY OFFICE UNIVERSITY OF OKLAHOMA

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T 3 Reactor Records: Log Book ,

4 Isotope Production , Instrument Cal.

6 Smear Wipe Tests: Front of isotope storage 7 Glory Hole Room 106 West Pit Floor

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12 NOTES:

Date of Last survey of reactor facility

16 0 Neutron mrem /hr= mcpm iurveyetl by RSO Review Date

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NRC-3 posted Radioactive material sign on entry Storage & work areas posted Waste containers posted Emergency procedures posted Next survey scheduled for RSO Review Date L_____________