IR 05000002/2011001: Difference between revisions

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{{Adams
{{Adams
| number = ML11299A076
| number = ML113260616
| issue date = 10/24/2011
| issue date = 11/21/2011
| title = IR 05000002-11-001 and Notice of Violation, on 08/09-11/2011 - 10/12/2011, Univ of MI Ford Nuclear Reactor
| title = IR 05000002-11-001; 08/09/2011, University of Michigan, Reply to a NRC Inspection Report Notice of Violation
| author name = Lipa C A
| author name = Alexander T G
| author affiliation = NRC/RGN-III/DNMS/MCID
| author affiliation = Univ of Michigan
| addressee name = Alexander T
| addressee name = Pederson C D
| addressee affiliation = Univ of Michigan
| addressee affiliation = NRC/RGN-III
| docket = 05000002
| docket = 05000002
| license number = R-028
| license number = R-028
| contact person =  
| contact person =  
| document report number = IR-11-001
| document report number = IR-11-001
| document type = Inspection Report, Letter, Notice of Violation
| document type = Letter, Licensee Response to Notice of Violation
| page count = 11
| page count = 2
}}
}}


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=Text=
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{{#Wiki_filter:CAMPUS SAFETY SERVICES BUILDING 1239 KIPKE DRIVE ANN ARBOR, MI 48109-1010 OF MICHIGAN OFFICE OF CAMPUS 734615-7025 FAX: 734 763-1185 TERRAKCE G. ALEXA.'1DER, EXECUTIVE DIRECTOR November 21, 2011 Cynthia Acting Regional U.S. Nuclear Regulatory Commission, Region 2443 Warrenville Road, Suite Lisle, Illinois Reply to a Notice of NRC Inspection Report No. 050-00002111-001 University of (License No. R-28 I Docket No.
[[Issue date::October 24, 2011]]


Mr. Terry Alexander, Executive Director Department of Occupation Safety & Environmental Health 1239 Kipke Drive University of Michigan Ann Arbor, MI 48109-1010
==Dear Ms. Pederson:==
 
The U.S. Nuclear Regulatory Commission (NRC) conducted an on-site inspection August 11, 2011 at the University of Michigan -Ford Nuclear Reactor in Ann Arbor, Michigan with subsequent in-office review through October 12, 2011. The purpose of the inspection was to determine whether decommissioning actJvities were conducted safely and in accordance with NRC regulations. Based on the results of the inspection, the NRC determined that a Severity Level IV violation of NRC requirements occurred and a Notice of Violation (NOV) was issued to the University in a correspondence dated October 24,2011. Specifically, Technical Specification 6.3 requires, in part, that decommissioning operations are independently monitored or audited to ensure they are being performed safely and in accordance with applicable license and registrations held by the University and in compliance with applicable federal and state regulatory requirements; the quality assurance is independently monitored or audited to verify that performance criteria are met as well as to determine the effectiveness of the program in satisfying the quality assurance requirements; and, monitoring or audits shall be performed annually, at a minimum. Contrary to the above requirements, from 2009 until 2011, the University of Michigan had not independently monitored or audited either the decommissioning operations or the quality assurance program annually as required. Reason for the Violation -the violation of Technical Specification 6.3 was an oversight on the part of the current FNR decommiSSioning staff. The reactor manager who had been responsible for overseeing all decommissioning activities since 200212003 resigned from the University in June 2009 and his duties were reassigned to staff who were less familiar with the technical specifications incorporated into the FNR license (R-28). RECEiVED 2 2 Corrective Steps Taken -the NOV and Technical Specification 6.3 were discussed with the FNR decommissioning staff and FNR Decommissioning Review Committee (ORC) during the DRC meeting held November 7, 2011. Recommendations were made with respect to who should conduct the annual review of the decommissioning activities and quality assurance program. Corrective Steps To Be Taken -the University will obtain a qualified individual or individuals to conduct an independent audit of decommissioning activities and the quality assurance program and ensure these independent audits are conducted on an annual basis until decommissioning activities have been terminated. As noted in Technical Specification 6.3, the auditor shall not be directly associated with the decommissioning activities, shall not be a member of the FNR Decommissioning Project Team, and shall be familiar with quality assurance requirements applicable to the decommissioning of nuclear facilities. Date of Full Compliance -the University will be in full compliance on or before February 29, 2012. Thank you for your time, effort, and consideration in this matter. Please do not hesitate to contact me [(734) 647-22531 or Mark Driscoll I Radiation Safety Officer [(734) 647-2251] should you have any questions or comments regarding this U-M response to Inspection Report 00002111-001 (ONMS) dated October 24,2011. Mark Banaszak HolI, Ph.D., Associate VP, Chair-Decommissioning Review Committee Robert Blackburn, Assistant Manager, Laboratory Operations, MMPP Mark Driscoll, Radiation Safety Officer, Radiation Safety Service I OSEH Ruthann Nichols, Ph.D., Chair, Radiation Policy Committee 2
SUBJECT: NRC INSPECTION REPORT 050-00002/11-001(DNMS) FORD NUCLEAR REACTOR AND NOTICE OF VIOLATION
 
==Dear Mr. Alexander:==
On October 12, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed inspection activities at the Ford Nuclear Reactor, Ann Arbor, MI. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with the NRC requirements. Specifically, during an on-site inspection on August 9 through 11, 2011, and subsequent in-office review through October 12, 2011, the inspector evaluated decommissioning performance and conducted independent radiation surveys and soil sampling, with soil sample evaluation of the NRC samples by the Oak Ridge Institute for Science and Education (ORISE). At the conclusion of the on-site inspection, the inspector discussed the interim inspection results with members of your staff. A final report from ORISE of the results of the soil sample analysis was provided to the NRC on August 30, 2011. At the conclusion of the in-office review, a final telephone exit meeting was conducted on October 12, 2011, to discuss the final results with members of your staff. This inspection consisted of an examination of decommissioning activities at the Ford Nuclear Reactor as they relate to safety and compliance with the Commission's rules and regulations.
 
Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, and interviews with personnel. Based on the results of this inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's website at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because it was identified by the NRC.
 
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The guidance in NRC Information Notice 96-28, "Suggested Guidance Relating to Development and Implementation of Corrective Action," may be helpful. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/ reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, Proprietary, or safeguards information so that it can be made available to the public without redaction. We will gladly discuss any questions you may have regarding this inspection.
 
Sincerely,/RA/ Christine A. Lipa, Chief Materials Control, ISFSI, and Decommissioning Branch Docket No. 50-002 License No. R-28
 
===Enclosures:===
1. Notice of Violation 2. NRC Inspection Report No. 050-00002/11-001(DNMS) cc w/encls: S. L. Ceccio, University of Michigan M. Driscoll, University of Michigan K. Yale, State of Michigan consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/ reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, Proprietary, or safeguards information so that it can be made available to the public without redaction. We will gladly discuss any questions you may have regarding this inspection.
 
Sincerely,/RA/ Christine A. Lipa, Chief Materials Control, ISFSI, and Decommissioning Branch Docket No. 50-002 License No. R-28
 
===Enclosures:===
1. Notice of Violation 2. NRC Inspection Report No. 050-00002/11-001(DNMS) cc w/encls: S. L. Ceccio, University of Michigan M. Driscoll, University of Michigan K. Yale, State of Michigan DISTRIBUTION w/encls: Keith McConnell Bruce Watson Theodore Smith Anne Boland Patrick Louden Allan Barker Harral Logaras Jared Heck Steven Orth Paul Pelke Carole Ariano Linda Linn MCID Branch *See previous concurrence DOCUMENT NAME: G:\DNMSIII\Work in progress\IR- Univ of MI Ford Nuclear 2011001 r0.docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII DNMS RIII DNMS RIII RIII NAME JETapp: jm JET CALipa CAL DATE 10/24/11 10/24/11 OFFICIAL RECORD COPY Enclosure 1 NOTICE OF VIOLATION University of Michigan Docket No. 050-00002 Ann Arbor, Michigan License No. R-28 During an U.S. Nuclear Regulatory Commission (NRC) inspection conducted between July 9 and October 12, 2011, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: Technical Specification 6.3 requires, in part, that decommissioning operations are independently monitored or audited to ensure they are being performed safely and in accordance with all applicable licenses and registrations held by the University and in compliance with applicable federal and state regulatory requirements; the quality assurance is independently monitored or audited to verify that performance criteria are met as well as to determine the effectiveness of the program in satisfying the quality assurance requirements; and monitoring or audits shall be performed annually, at a minimum. Contrary to the above, from 2009 until 2011, the licensee has not independently monitored or audited either decommissioning operations or the quality assurance program annually as required.
 
This is a Severity Level IV violation. Pursuant to the provisions of Title 10 of the Code of Federal Regulations 2.201, the University of Michigan is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region III, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time. If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/ reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, Proprietary, or safeguards information so that it can be made available to the public without redaction.
 
2 Enclosure 1 Notice of Violation -2- If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21. In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt. Dated this 24TH day of October 2011.
 
Enclosure 2 U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No. 050-00002 License No. R-28 Report No. 050-00002/11-001(DNMS) Licensee: University of Michigan Facility: Ford Nuclear Reactor Location: Ann Arbor, Michigan Dates: August 9 - 11, 2011 (on-site) through October 12, 2011 (in-office review)
NRC Inspector: Jeremy Tapp, Health Physicist NRC Observers: Theodore Smith, Project Manager, FSME Stephen Giebel, Health Physicist, FSME Nicholas Hansing, Student Engineer, RIII Approved by: Christine A. Lipa, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety 2 Enclosure 2 EXECUTIVE SUMMARY University of Michigan - Ford Nuclear Reactor Inspection Report 050-00002/11-001(DNMS) This routine decommissioning inspection included a review of the licensee's current performance related to decommissioning activities, and the performance of radiation surveys and collection of soil samples. Areas reviewed included health physics and audits and reviews.
 
Research and Test Reactor Decommissioning * Inspector observations of the facility determined that facility radiological and industrial controls ensured worker safety and prevented loose radiological contamination in uncontrolled areas. Instruments were adequately tested before use to demonstrate functionality and calibrated as required by the applicable procedure. The licensee took appropriate actions when radiation survey results did not compare as expected (Section 1.1). * The annual Report on Reactor Operations was completed as required and comprehensive in content. Decommissioning Review Committee (DRC) meetings were conducted semi-annually with more than the required attendance, and discussed all current decommissioning activities. A Technical Specification violation was identified for not performing the required annual independent monitoring or audit of both decommissioning operations and quality assurance (Section 1.2).
 
3 Enclosure 2 Report Details 1.0 Research and Test Reactor Decommissioning (69013) 1.1 Health Physics a. Inspection Scope The inspector interviewed site personnel and performed a facility and site tour to observe field conditions. The inspector evaluated the site's material condition and housekeeping, area radiological conditions, and radiological access control and associated posting/labeling. Independent radiation measurements were made throughout the areas toured and compared to the licensee's postings. In addition, the inspector reviewed a sampling of routine contamination smear survey records from 2011 to evaluate whether the licensee's radioactive material controls were adequate. The inspector reviewed the licensee's radiological survey instrumentation by observing licensee personnel perform instrument and detector calibration and daily source check activities. The inspector verified the activities were performed in accordance with the required procedures, specifically HP-402, "Calibration of the Ludlum 2221 Scaler Ratemeter & Detectors," Revision 0, and HP-401, "Survey Instrument Source Checking," Revision 0. The inspector also reviewed calibration records for a Ludlum 44-142 Probe
# PR246233, completed on March 14, 2011, and a Ludlum 2221 Scaler Ratemeter # 216469, completed on June 30, 2011, to determine if they were calibrated as required by procedure. The inspector performed independent radiation surveys and soil sampling in a cavity along the Ford Nuclear Reactor (FNR) and Phoenix Memorial Laboratory (PML) wall. Beta surveys were performed on the concrete surfaces of the cavity along with the collection of three soil samples. The beta survey results were compared to the licensee's to confirm the validity of their results. The three soil samples were sent to the Oak Ridge Institute for Science and Education (ORISE) for analysis of Co-60, Cs-137, and Ag-108m. The inspector reviewed the results and will potentially use them in the future to support license termination, once derived concentration guideline levels (DCGLs) are approved for the FNR. b. Observations and Findings The inspector found that the facility was generally clean and free of debris and personnel hazards. Access control and postings were determined to be adequate for the radiological conditions of the facility. All routine contamination smear survey results showed no discernable loose contamination in the building. Health Physics staff used appropriate radiation sources and methods in accordance with their procedures to source check each instrument and applicable detector each day it was to be used and to calibrate each detector as required. Health Physics staff was knowledgeable of the calibration and source check process and procedures. During radiation surveys of the cavity along the FNR and PML wall, the inspector found most direct beta measurements to be in agreement with the licensee's results, which are found in Survey No. 2011-0033, dated April 20, 2011, and Survey No. 2011-0022, dated 4 Enclosure 2 March 29, 2011. But some results were approximately two times those recorded by the licensee. These results were passed along to the licensee, and subsequently, they discussed with the inspector plans to follow up and perform additional surveys. Because DCGLs for building surfaces have not been approved for the decommissioning of the FNR by the NRC, no comparison was made at this time between these survey results and their acceptability for supporting final license termination. In addition, three soil samples were obtained from the cavity, two from the west section and one from the east section. The soil was collected from the top 6 inches next to the FNR and PML wall, where the potential for the highest level of contamination is located.
 
The three samples were sent to ORISE and the final results were provided to the NRC in the document, "Letter Report for Analytical Results for Three Soil Samples from the University of Michigan Ford Reactor, Ann Arbor, Michigan," dated August 23, 2011 (ML112420852). The inspector reviewed the results and determined them to be reasonable compared to the licensee's initial results and subsequent remediation activities. Depending on the DCGLs that are approved in the future for this area, these results could be potentially used to support license termination.
 
No findings of significance were identified. c. Conclusions Inspector observations of the facility determined that facility radiological and industrial controls ensured worker safety and prevented loose radiological contamination in uncontrolled areas. Instruments were adequately tested before use to demonstrate functionality and calibrated as required by the applicable procedure. The licensee took appropriate actions when radiation survey results did not compare as expected.
 
1.2 Review and Audit a. Inspection Scope The inspector reviewed the licensee's annual Report on Reactor Operations to determine it was completed as required by Technical Specifications. The inspector reviewed Decommissioning Review Committee (DRC) meeting minutes from the previous two meetings on March 15, 2011 and September 27, 2010 to determine whether the committee performed its function as described in the Technical Specifications. The minutes reviewed also included minutes from the January 19, 2010 meeting. The inspector also reviewed independent audits required by Technical Specifications that were conducted in 2011 to determine the adequacy of their scope and evaluate the results. b. Observations and Findings The inspector found the Report on Reactor Operations was completed as required by Technical Specifications and the content reflected current licensee activities and status. The DRC met semi-annually as required, and a quorum existed in each meeting reviewed. The inspector found the DRC reviewed, in part, current decommissioning activities and a procedure change for soil sampling, as required by Technical Specifications.
 
5 Enclosure 2 The inspector requested the licensee to provide a copy of the independent audit or audits performed in 2011. The licensee could not provide any independent audit performed for 2011, as required by Technical Specifications. In addition, when the inspector requested the licensee provide the last independent audit performed, no audits could be found in the licensee's records. The inspector reviewed the DRC meeting minutes for 2010 and 2011 and found no mention of scheduling or reviewing independent monitoring or audits as required. A contractor for the licensee that performed Reactor Manager duties in the past was contacted by the licensee to determine when the last independent audit was performed. The licensee has verbally stated an independent audit was last performed in 2008.
 
Audits are required to be conducted to independently assess program performance and determine whether policies, procedures, and practices ensure health and safety. Audits are intended to identify flaws and prompt corrective action, which results in a substantial decrease in potential for significant issues to occur. Therefore, the failure to complete the required audits of decommissioning operations and quality assurance is of more than minor safety significance given the potential impact on overall program effectiveness.
 
For example, radiation survey reports performed in the February to June 2011 timeframe did not receive a timely quality assurance review, which was for six months, in the most extreme case. Technical Specification 6.3 states, in part, "the following are independently monitored or audited: a. Decommissioning operations to ensure they are being performed safely and in accordance with all applicable licenses and registrations held by the University and in compliance with applicable federal and state regulatory requirements. b. The quality assurance to verify that performance criteria are met as well as to determine the effectiveness of the program in satisfying the quality assurance requirements." In addition, Technical Specification 6.3 states, in part, "monitoring or audits shall be performed annually, at a minimum-" The failure to perform an annual independent audit, from 2009 until 2011, of both decommissioning operations and quality assurance, is a violation of Technical Specification 6.3. (VIO 05000002/11-01-01). c. Conclusions The annual Report on Reactor Operations was completed as required and comprehensive in content. DRC meetings were conducted semi-annually with more than the required attendance, and discussed all current decommissioning activities. A Technical Specification violation was identified for not performing the required annual independent monitoring or audit of both decommissioning operations and quality assurance. 2.0 Exit Meeting Summary The inspector presented the interim inspection results to licensee management at the conclusion of the onsite inspection on August 11, 2011. After in-office review was completed on October 12, 2011, a final exit teleconference was held. The licensee acknowledged the results presented and did not identify any of the documents reviewed by the inspectors as proprietary. ATTACHMENT: SUPPLEMENTAL INFORMATION Attachment SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee 1,2M. Driscoll, Radiation Safety Officer 1,2R. Blackburn, Assistant Manager of Laboratory Operations 1Indicates presence at the interim on-site exit meeting held on August 11, 2011. 2Indicates presence at the telephone exit meeting held on October 12, 2011. LIST OF PROCEDURES USED IP 69013 Research and Test Reactor Decommissioning ITEMS OPENED, CLOSED, AND DISCUSSED Opened Type Summary VIO 05000002/11-01-01 VIO Failed to perform independent monitoring or audits of decommissioning operations and quality assurance as required by Technical Specification 6.3 Closed None Discussed None LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations DCGL Derived Concentration Guideline Level DNMS Division of Nuclear Material Safety DRC Decommissioning Review Committee FNR Ford Nuclear Reactor NRC U. S. Nuclear Regulatory Commission ORISE Oak Ridge Institute for Science and Education PML Phoenix Memorial Laboratory DOCUMENTS REVIEWED Licensee documents used during the inspection were specifically identified in the Report Details above.
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Revision as of 05:34, 17 February 2018

IR 05000002-11-001; 08/09/2011, University of Michigan, Reply to a NRC Inspection Report Notice of Violation
ML113260616
Person / Time
Site: University of Michigan
Issue date: 11/21/2011
From: Alexander T G
University of Michigan
To: Pederson C D
NRC/RGN-III
References
IR-11-001
Download: ML113260616 (2)
v • d • e


Text

CAMPUS SAFETY SERVICES BUILDING 1239 KIPKE DRIVE ANN ARBOR, MI 48109-1010 OF MICHIGAN OFFICE OF CAMPUS 734615-7025 FAX: 734 763-1185 TERRAKCE G. ALEXA.'1DER, EXECUTIVE DIRECTOR November 21, 2011 Cynthia Acting Regional U.S. Nuclear Regulatory Commission, Region 2443 Warrenville Road, Suite Lisle, Illinois Reply to a Notice of NRC Inspection Report No. 050-00002111-001 University of (License No. R-28 I Docket No.

Dear Ms. Pederson:

The U.S. Nuclear Regulatory Commission (NRC) conducted an on-site inspection August 11, 2011 at the University of Michigan -Ford Nuclear Reactor in Ann Arbor, Michigan with subsequent in-office review through October 12, 2011. The purpose of the inspection was to determine whether decommissioning actJvities were conducted safely and in accordance with NRC regulations. Based on the results of the inspection, the NRC determined that a Severity Level IV violation of NRC requirements occurred and a Notice of Violation (NOV) was issued to the University in a correspondence dated October 24,2011. Specifically, Technical Specification 6.3 requires, in part, that decommissioning operations are independently monitored or audited to ensure they are being performed safely and in accordance with applicable license and registrations held by the University and in compliance with applicable federal and state regulatory requirements; the quality assurance is independently monitored or audited to verify that performance criteria are met as well as to determine the effectiveness of the program in satisfying the quality assurance requirements; and, monitoring or audits shall be performed annually, at a minimum. Contrary to the above requirements, from 2009 until 2011, the University of Michigan had not independently monitored or audited either the decommissioning operations or the quality assurance program annually as required. Reason for the Violation -the violation of Technical Specification 6.3 was an oversight on the part of the current FNR decommiSSioning staff. The reactor manager who had been responsible for overseeing all decommissioning activities since 200212003 resigned from the University in June 2009 and his duties were reassigned to staff who were less familiar with the technical specifications incorporated into the FNR license (R-28). RECEiVED 2 2 Corrective Steps Taken -the NOV and Technical Specification 6.3 were discussed with the FNR decommissioning staff and FNR Decommissioning Review Committee (ORC) during the DRC meeting held November 7, 2011. Recommendations were made with respect to who should conduct the annual review of the decommissioning activities and quality assurance program. Corrective Steps To Be Taken -the University will obtain a qualified individual or individuals to conduct an independent audit of decommissioning activities and the quality assurance program and ensure these independent audits are conducted on an annual basis until decommissioning activities have been terminated. As noted in Technical Specification 6.3, the auditor shall not be directly associated with the decommissioning activities, shall not be a member of the FNR Decommissioning Project Team, and shall be familiar with quality assurance requirements applicable to the decommissioning of nuclear facilities. Date of Full Compliance -the University will be in full compliance on or before February 29, 2012. Thank you for your time, effort, and consideration in this matter. Please do not hesitate to contact me [(734) 647-22531 or Mark Driscoll I Radiation Safety Officer [(734) 647-2251] should you have any questions or comments regarding this U-M response to Inspection Report 00002111-001 (ONMS) dated October 24,2011. Mark Banaszak HolI, Ph.D., Associate VP, Chair-Decommissioning Review Committee Robert Blackburn, Assistant Manager, Laboratory Operations, MMPP Mark Driscoll, Radiation Safety Officer, Radiation Safety Service I OSEH Ruthann Nichols, Ph.D., Chair, Radiation Policy Committee 2

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