ML20207T446

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-148/86-01.Careless Disregard for NRC Requirements Re Dismantling Activities Demonstrated

ML20207T446
Person / Time
Site:	05000148
Issue date:	03/19/1987
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Bearse R KANSAS, UNIV. OF, LAWRENCE, KS
References
NUDOCS 8703240024
Download: ML20207T446 (2)

See also: IR 05000148/1986001

Text

, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___.

, MAR I 91987

+

~

. In Reply Refer To:

Docket: 50-148/86-01

University of Kansas

ATTN: Mr. Robert C. Bearse, Associate

Vice Chancellor

226 Strong Hall

Lawrence, Kansas 66045-2300

Gentlemen:

Thank you for your letter of January 13, 1987, in response to our letter and

Notice of Violation dated December 23, 1986. After reviewing your reply,

it remains our position that you were provided guidance in late 1985 ragarding

dismantling of the reactor and subsequent termination of the operating license,

and that you demonstrated careless disregard for NRC requirements. Our

position is based on the fact that you had telephone conversations with the

NRC Project Manager concerning dismantling activities and, as a follow-up to

these discussions, the Project Manager provided you a copy of NRC Regulatory

Guide 1.86.

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.

Your January 13, 1987, letter contained a Safeguards Information attachment,

which was properly marked. However, the letter itself was not marked

" Safeguards Information" to indicate conspicuously the presence of protected

information, as required by 10 CFR 73.21 (e). Please mark your copies of the

January 13, 1987, letter appropriately.

Sincerely,

ORIGINAL SIGNfD gy

RO8ERT D. MAgry

Robert D. Martin

Regional Administrator

, cc:

Kansas Radiation Control Program Director

bec: (see next page)

J

'

RIV:FRP C:FRPS C:R&SPB 0: / RA

RWise/jt BMurray WLFisher RL rt EGa liardo gDo tin

) /gp /87 3 /p /87 J /l3/87 $/l(/87( 3/ /87' f/ /87

\

ENCLOSURE CONTAINS \

SAFEGUARDS INFORMATION.

UPON SEPARATION THIS

f

l703240024870319

DR ADOCK 03000148 PAGE IS DECONTROLLED.

ly

8 con

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

t

.

.

.. University of Kansas -2-

bec w/ copy of licensee's response w/ safeguards:

RIV Security File -

G. McCorkle, NMSS

J. Gibson,.SSPD/NRR

,

IE File

Resident Inspector t

R. D. Martin, RA '

R. L. Bangart, DRS&S i

Inspector '

Chief EPSPS

J. J. Dosa, Project Manager i

H. N. Berkow i

<

0. A. Powers

l B. Murray

bec w/ copy of licensee's response w/o safeguards:

CMB IE-04

RPB

! D. Weiss, RM/ALF

Section Chief (RPB/B)

RIV File

MIS

j' RSTS Operator

R&SPB -;'

W. L. Fisher, R&SPB

E. H. Johnson, DRS&P

R. E. llall, DRS&P

i  !

4

i  !

'

t

i

i r

4

ENCLOSUM CONTAINt

SAFEGUARDS INFORMATION,  !

UPON SEPARATION THIS

I

PAGE IS DECONTROLLED.

L

u

i

!

t

i

!

!

i

- .

'

'

SAFEGUARDS INFORMATION

7$,6 #

Tile UNIVERSITY OF KANSAS

offico of the m Chano llnr for Hncan h. Gr.ninato stu. lies, an.1 Public service,

an.1 ihtan of the Grailuato s< hool

22th Strong llall.1.awrenu.. Kansas ca un2:"Hi

(91.1) im 4 'I in 1

January 13, 1987

U.S. Nuclear Regulatory Commission , m,. . K

fogion IV

611 Ryan Plaza Drive, Suite 1000

ii,Q

i

C,. --~

'

3 o .

Arlington, TX 76011 b

m i g ggg7 ,

Attn: Mr. Robert D. Martin, Regional Administrator

'_

L

_j f -

Re Docket No. $0-148, License No. R-78 '

NRC Inspection ftoport 50-148/86-01

EA 86-186

Dear Mr. Martin:

The following are our responses to your Notice of Violation of December 23,

1986. .

.

A. Failure to Apply for Authority to Dismantle a Facility.

(1) The removal [of the grid plato assembly], which we now understand

to be diamantlement, was done to empty the reactor tank of as much

activated material as casily possible so as to make an assessment

of the magnitude of future problems of decommission 1 sng. At the

time, we did not considor the action to be a dismantlement in the

sense implied by 10 CFR 50.82. We appreciate your not proposing a

civil penalty for this violation. At the same time, we do not l

understand and do not agree with the allegation that we  !

" demonstrated careless disregard for this requirement by not

complying with 10 CFR 50.82 even af ter being informed of the

requirement by the project manager, Office of Nuclear Reactor

Regulation." The dismantlement took place on March 211, 1986, and

was called to our attention as being a possible violation no l

I

carlier than September or October, 1986. No subsequent

dismantlement has occurred. We are unaware of any specific

requirements communicated by the project manager which we i

disregarded. l

(2) Corrective action has been taken to be certain by administrative

control that no further dismantlement of any kind will occur

'

without proper authority.

(3) Correctivo action which will be taken is the same as (2) above.

(4) In our opinion, we are now in full compliance. ENC 1.OSURE CONTAINS

,

SAFEGUARDS INFORMATION. 1

SAFEGUARDS INFORMATION ueOn sEeAnATioN TsiS  !

PAGE IS DECONTROLLEC- 0 l

uain c.on

c. ,il..... .., , ,... i,h s ...n. ... n. ,e n . . l u re n. o

n...r.. u . - c" ~ ~ ""a k)

-- ----

cd

- _ _ - _ _ _ _ _ _ .

.

.

9

.

B. Failure to Post Required Regulatory Documents.

(1) The violation occurred by socident during a clean-up when all

documents were removed from the reactor bay bulletin board.

(2) Corrective action has been to replace the required documents on

the bulletin board.

(3) Corrective action which will be taken is to insure by

administrative control that the documents not be removed from the

board in the future.

(4) In our opinion, we are now in full compliance.

C. Failure to Identify Radioactive Material.

(1) The fission monitor was normally in a sealed container under water

in the reactor tank. After the container had been removed from

the tank during fuel transfer operations, we neglected to label it

properly.

(2) This was pointed out to us during the inspection of September 11

and 12, 1986, and the correct label was immediately applied.

Subsequently, the monitor has been transferred to Kansas State

University.

(3) Future corrective action is moot.

(4) In our opinion, we are now in full compliance.

D. Response to Appendix D, Notice of Violation

This response may include Safeguards Information and is appended as a

separate document.

We hope that these responses are satisfactory and that no furter NRC

enforcement action will be necessary to ensure compliance with NRC

regulatory requirements.

Sincerely,

Robert C. Bearse

Associate Vice Chancellor

Enclosure marked " SAFEGUARDS INFORMATION"

Copies w/o enclosures Nuclear Reactor Committee

Carl E. Locke

w/ enclosure Vickle Thomas

. - - - - - . - - - - - - - - - - - - - - - - - - . - - - - - - - - - - - . _ _ _ _ _ _ _ _ . - . - - - ----__________________________---------_a