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{{#Wiki_filter: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/&  
{{#Wiki_filter:UNIVERSITY  
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  
OF CALIFORNIA, IRVINE BERKELEY -DAVIS -IRVINE -LOS ANGELES -MERCED -RIVERSIDE  
 
* SAN DIEGO * SAN FRANCISCO  
SANTA BARBARA. SANTACRUZ Office of the Executive  
Vice Chancellor  
and Provost 509 Aldrich Hall Irvine, CA 92697-1000
(949)824-6296
(949)824-2438  
FAX February 2, 2011 U.S. Nuclear Regulatory  
Commission
ATTN: Document Control Desk Washington, D.C. 20555 References:  
Docket 50-326. License R-1 16 UC Irvine Nuclear Reactor Facility NRC Inspection  
Report 50-326/2010-201  
Notice of Violation We are pleased that the recent inspection  
report cited concluded  
that our operation  
of the nuclear research reactor was generally  
found acceptable  
and within compliance.  
In one area your inspectors
determined
a violation  
of regulations  
had occurred: "Contrary  
to Section 10.2 "Drills and Exercises" of the Emergency  
Plan for the University  
of California, Irvine Nuclear Reactor Facility, the licensee failed to conduct the required annual onsite emergency
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 concerned that this is seen as a "more than minor safety significance", since we believe firmly that adequate emergency
response continues  
to be assured.Annual training exercises  
for response personnel  
were conducted  
with the objective  
of assuring appropriate
emergency  
response to a radiologically  
related emergency  
at the facility.  
As explained  
below we are convinced  
our response team is adequately  
prepared to meet anticipated  
emergency  
incidents  
at the facility even though the exercise was conducted  
at an on-campus  
location that was not within the confines 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 designed to 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 County Fire Authority, Irvine and Newport Beach Police Departments).  
The plan anticipates  
the use of other specialized
groups to assist, when necessary, especially  
with clean-up and recovery operations.  
This is detailed in our ERT Response Plan "Red Book" that was made available  
to inspectors.  
A sub-group  
of ERT is highly experienced  
and trained to handle emergencies  
with potential  
radiological  
impact since these could occur at a large number of sites on campus only one of which is the nuclear reactor laboratory.  
This group is familiar through frequent visits and through membership  
on the Reactor Operations
Conmmittee (ROC), with the detailed specifics  
of the facility.  
Training emphasizes  
that these ,I/&  
21Page NRC Inspection  
Report 50-326/2010-201  
Notice of Violation February 3, 2011 individuals
will provide guidance to other responding  
personnel  
entering the reactor or other laboratory
facilities
where radioisotopes  
are used.Training and practice may therefore  
occur at a number of locations.  
Suitable locations  
are selected based on incident likelihood, space available  
for the size of the group to be trained, and the availability  
of facilities
for table-top  
exercises (seemingly  
now favored for better rehearsing  
responses).  
The nuclear reactor facility has not always been favored since its space is quite restricted  
and it has no conference
accommodation.
The reactor staff itself is extremely  
small at our facility and relies on the rapid and properly equipped support 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 UCI nuclear reactor is the "Regents of the University  
of California".  
They have designated  
responsibility  
to the Irvine campus Chancellor, with further designation  
to the Executive  
Vice-Chancellor  
and Provost. These individuals
have the authority, in an emergency, to declare the entire campus, including  
all facilities  
and access roads, "closed" and to direct all emergency  
operations  
therein. Thus it is not unreasonable  
for us to have interpreted "onsite" to imply "the Irvine campus" and to plan exercises  
and drills based on our campus-wide  
approach to emergency  
response.  
We perhaps should consider modifying  
the language in our reactor facility emergency  
plan to clarify this approach.2. Corrective  
Steps Taken We have noted the concerns and will, pending a re-interpretation  
as noted above, assure that an emergency
exercise/drill  
be conducted  
annually within the confines of Rowland Hall at the reactor facility.  
Planning personnel  
will design and designate  
this as the "site".3. Further Corrective  
Steps We believe that our commitment  
to this change needs no further corrective  
action.4. Full Compliance
We will implement  
this exercise on our normal schedule, which is during the first half of the calendar year 2011, so it should be completed  
by June 3 0 th of this year. The previous exercise on campus (which did not meet your on-site criterion)  
was held in May 2010. Subsequent  
exercises  
will be conducted  
each year on this schedule.Sincerely Michael R. Gottfredson
Executive
Vice Chancellor  
and Provost C: Mr. Greg Schoenbeck, NRC Office of Nuclear Reactor Regulation
Mr. Craig Bassett, NRC Office of Nuclear Reactor Regulation
Dean Ken Janda, UCI School of Physical Sciences Members, UCI Reactor Operations  
Committee
}}
}}

Revision as of 07:05, 14 August 2018

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)
v • d • e


See also: IR 05000326/2010201

Text

UNIVERSITY

OF CALIFORNIA, IRVINE BERKELEY -DAVIS -IRVINE -LOS ANGELES -MERCED -RIVERSIDE

  • SAN DIEGO * SAN FRANCISCO

SANTA BARBARA. SANTACRUZ Office of the Executive

Vice Chancellor

and Provost 509 Aldrich Hall Irvine, CA 92697-1000

(949)824-6296

(949)824-2438

FAX February 2, 2011 U.S. Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, D.C. 20555 References:

Docket 50-326. License R-1 16 UC Irvine Nuclear Reactor Facility NRC Inspection

Report 50-326/2010-201

Notice of Violation We are pleased that the recent inspection

report cited concluded

that our operation

of the nuclear research reactor was generally

found acceptable

and within compliance.

In one area your inspectors

determined

a violation

of regulations

had occurred: "Contrary

to Section 10.2 "Drills and Exercises" of the Emergency

Plan for the University

of California, Irvine Nuclear Reactor Facility, the licensee failed to conduct the required annual onsite emergency

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 concerned that this is seen as a "more than minor safety significance", since we believe firmly that adequate emergency

response continues

to be assured.Annual training exercises

for response personnel

were conducted

with the objective

of assuring appropriate

emergency

response to a radiologically

related emergency

at the facility.

As explained

below we are convinced

our response team is adequately

prepared to meet anticipated

emergency

incidents

at the facility even though the exercise was conducted

at an on-campus

location that was not within the confines 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 designed to 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 County Fire Authority, Irvine and Newport Beach Police Departments).

The plan anticipates

the use of other specialized

groups to assist, when necessary, especially

with clean-up and recovery operations.

This is detailed in our ERT Response Plan "Red Book" that was made available

to inspectors.

A sub-group

of ERT is highly experienced

and trained to handle emergencies

with potential

radiological

impact since these could occur at a large number of sites on campus only one of which is the nuclear reactor laboratory.

This group is familiar through frequent visits and through membership

on the Reactor Operations

Conmmittee (ROC), with the detailed specifics

of the facility.

Training emphasizes

that these ,I/&

21Page NRC Inspection

Report 50-326/2010-201

Notice of Violation February 3, 2011 individuals

will provide guidance to other responding

personnel

entering the reactor or other laboratory

facilities

where radioisotopes

are used.Training and practice may therefore

occur at a number of locations.

Suitable locations

are selected based on incident likelihood, space available

for the size of the group to be trained, and the availability

of facilities

for table-top

exercises (seemingly

now favored for better rehearsing

responses).

The nuclear reactor facility has not always been favored since its space is quite restricted

and it has no conference

accommodation.

The reactor staff itself is extremely

small at our facility and relies on the rapid and properly equipped support 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 UCI nuclear reactor is the "Regents of the University

of California".

They have designated

responsibility

to the Irvine campus Chancellor, with further designation

to the Executive

Vice-Chancellor

and Provost. These individuals

have the authority, in an emergency, to declare the entire campus, including

all facilities

and access roads, "closed" and to direct all emergency

operations

therein. Thus it is not unreasonable

for us to have interpreted "onsite" to imply "the Irvine campus" and to plan exercises

and drills based on our campus-wide

approach to emergency

response.

We perhaps should consider modifying

the language in our reactor facility emergency

plan to clarify this approach.2. Corrective

Steps Taken We have noted the concerns and will, pending a re-interpretation

as noted above, assure that an emergency

exercise/drill

be conducted

annually within the confines of Rowland Hall at the reactor facility.

Planning personnel

will design and designate

this as the "site".3. Further Corrective

Steps We believe that our commitment

to this change needs no further corrective

action.4. Full Compliance

We will implement

this exercise on our normal schedule, which is during the first half of the calendar year 2011, so it should be completed

by June 3 0 th of this year. The previous exercise on campus (which did not meet your on-site criterion)

was held in May 2010. Subsequent

exercises

will be conducted

each year on this schedule.Sincerely Michael R. Gottfredson

Executive

Vice Chancellor

and Provost C: Mr. Greg Schoenbeck, NRC Office of Nuclear Reactor Regulation

Mr. Craig Bassett, NRC Office of Nuclear Reactor Regulation

Dean Ken Janda, UCI School of Physical Sciences Members, UCI Reactor Operations

Committee

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