ML20206L733

Responds to NRC Re Violation Noted in Insp Rept 50-297/88-04.Corrective Actions:Radiation Protection Ofc in Process of Updating All Procedures,Including Procedures Associated W/Radiation Surveillance & Effluent Monitoring

ML20206L733
Person / Time
Site:	North Carolina State University
Issue date:	11/21/1988
From:	Elleman T North Carolina State University, RALEIGH, NC
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8811300198
Download: ML20206L733 (3)

Text

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North Carolina State University

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. .t Department of Nuclear Engineering College of Engineering a m 7909 Raleigh, NC 2709M909 November 21, 1988 (919) 737 2301 l

Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

SUBJECT:

Neply to a Notice of Violation l NRC Inspection Report No. 50-297/88-04 i North Carolina State University  :

PULSTAR Reactor - License No. R-120 ,

Dear Sir:

This response is regarding the letter from Douglas M. Collins, NRC Region 11, Atlanta dated November 2,1988 describing one class IV violation against our PULSTAR facility. This violation was identified by the recent NRC inspection r.onducted by Mr. George B. Kuzo on September 26-29, 1988. Please find the attached document explaining in detail the reasons for the violation and the corrective actions implemented it our facility. Please contact me if there is any question concerning our response.

Sincerely yours, ggjg i (LRLGk l

Thomas S. Elleman l Department Head

Attachment:

l I cc: Administrator, Region II l i NRC Resident inspector, Region 11 Thomas L. Brac'a in K. V. Mani L Garry D. Miller l Larry K. Monteith D. William Morgan, RP0 i i Bernard W. Wehring

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0011300198 881121 PDR ADOCK 05000297 l

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North Carolina State Unkersity k a land grant unkenty and a comtituent imtitutk>n of The Unitenty of North Caroliu.

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. Enclosure 1 Response to violation and corrective actions taken.

Violation _

"Technical specification 6.3a(8) requires operating procedures to be written, updated periodically and followed for radiation control. These procedures will be maintained by operations personnel.

Contrary to the above, as of September 26, 1988, the licensee failed to have and maintain approved procedures utilized by tb4 Radiation Protection Office (RP0) to conduct liquid effluent and environmental sample radiological analyses."

This is a Severity Level IV violation (Supplement IV).

Response __to th_e _ violation

1) Admission or denial of the rialation.

The violation is acknowi+1,co.

2) The reason for the violation if admitted.

North Carolina State University has historically operated under the prin-ciple that environmental radiation surveillance in support of its Nuclear Peactor Program is performed by the University Radiation Protection Office (r>0). We considered it proper for the RPO procedures on environmental monitoring to cover the activities of the licensee. The procedures for the performance of these monitoring activities were therefore kept by the RP0 and were revised as needed. The procedures were considered to have Radiation Protection Council (RPC) approval since all activities of the RP0 are reported to the RPC on a continuing basis and all aspects of the Environmental Monitoring Program were originally approved by the RPC.

3) Corrective steps which have been taken and the results achieved.

As was discussed with Mr. Xuzo during his inspection, the Radiation Pro-

, tection Of fice is in the process of updating all of its procedures inclu-ding those associated with radiation surveillance and effluent monitoring in support of PULSTAR Reactor On:rctions. These procedures are being developed in a standard format and where required by Technical Specifica-tion 6.3a(8) they will be reviewed and approved as Reactor Procedures and be maintained at the PULSTAR Reactor as Technical Specification required documents. As such, RPC approval will also be required for any future changes of these procedures. The procedures required for approval have been identified and action is in progress to update them and place them before the RPC.

4) Corrective steps which will be taken to avoid future violations.

Once these procedures are on file at the PULSTAR Reactor and considered to be Technical Specification required documents, the document control system now in place will insure that the procedures will be properly mgintained.

5) The date when full compliance will be achieved.

All environmental radiation surveillance procedures performed in support of the NCSU PULSTAR Reactor will be placed in a standard format and sub-

mitted to the RPC for consideration by January 15, 1989.

Because some parallel work 's also in progress to see that all such pro.

cedures are compatible with performing inter-comparison studies with both the Radiation Prutection Section of the State of North Carolina and the U. S. Environmental Protection Agency, further refinements may be made to these procedures. This will take place in a period of time not to exceed six months and any such refinements to the procedures which may be thus required will be handled as a forinal amendment to the procedures and submitted to the RPC for consideration.

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