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Category:Letter
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2023-08-25
[Table view]
Category:Licensee Response to Notice of Violation
MONTHYEARML12073A3272012-02-14014 February 2012
University of California - Irvine, Reply to a Notice of Violation, Dated January 17th 2012
ML1104601192011-02-0202 February 2011
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ML0319104312002-10-25025 October 2002
NRC Inspection Report and Notice of Violation 50/326/2002-201-01
2012-02-14
[Table view] |
Text
UNIVERSITY OF CALIFORNIA, IRVINE BERKELEY
- SAN FRANCISCO l SANTA BARBARA
- SANTA CRUZ Office of the Executive Vice Chancellor 509 Administration Irvine, California 92697-1000 (949) 824-6296 (949) 824-2438 Fax December 20, 2004 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Reply to a Notice of Violation.
References:
Docket 50-326. License R-1 16 UC Irvine Nuclear Reactor Facility NRC Inspection Report 50-326/2004-201 Notice of Violation
- 1. Discussion of Violation As noted in our prior response to a similar violation in October, 2002, we regret that our documentation was incomplete and/or incorrect. The short half-lives of the major isotope in this shipment of samples (manganese 56, 2.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) and the physical and chemical form (solid meteorite and rock fragments) fortunately precluded there being a significant safety hazard. The shipment would be below TI of Yellow II, even if the numbers present on the sheet were correct, by the time it entered main highways.
Unfortunately the individual responsible for this shipment has since retired from the University, and the addressee has apparently retained no records from this shipment, so we are unable to reconstruct the actual course of events.
- 2. Corrective Steps Taken We have instituted a checklist (copy attached) for radioactive shipments from the facility that requires review of all items needed. Further, a requirement is in place for a second knowledgeable individual (not an authorized shipper) to review the paperwork before the shipment is permitted to leave. Staff have been trained in the use of this checklist.
- 3. Further Corrective Steps We are confident that the checklist use will establish fully correct shipping procedures for Yellow II shipments (True Yellow III are very rare from this facility)._The checklist will be incorporated into Standard Operating Procedures (SOP) for the facility and appropriate training conducted at intervals not to exceed two years. A separate checklist will be created to address yellow III issues, and appropriate training conducted.
- 4. Full Compliance As indicated, full compliance with proper shipping procedures (49CFR 171-177) is already in place. The additional steps will help maintain compliance.
Ao')Lc
We appreciate the opportunity to respond to the referenced Notice of Violation, and also appreciate that all other aspects of facility operations that were inspected during the visit were found to be in compliance.
Sincerely Michael R. Gottfredson Executive Vice-Chancellor Cc: Mr. Craig Bassett, NRC Office of Nuclear Reactor Regulation Dean Ron Stem, UCI School of Physical Sciences Members, UCI Reactor Operations Committee
50-326 NOV December It 1 2004 Response Attachment UCI Radioactive Sample Shipping Checklist.
To be filed with shipping papers AT UCI.
Note: This is NOT a substitute for official shipping documents.
Date . ._Shipment to BEFORE PACKAGING YELLOW II FOR SHIPMENT.
- 1. Estimation of ISOTOPE (main) content in Bq (or MBq, etc) AND in Ci units. (previous similar shipments can be used for this).
USERS LICENSE INSPECTED
- 2. Isotope quantities and ID are OK.
- 3. verified expiry date beyond today's date DURING OR AFTER PACKAGING FOR SHIPMENT as YELLOW II*.
Package Measurements
- 4. SURFACE LEVEL ON PACKAGE is measured, recorded and is LESS THAN 50 mr/hr.
5.E 1 meter from surface of PACKAGE is MEASURED AND RECORDED and is LESS THAN 1 mr/hr.
AUTHORIZATION
- 6. Second person (usually Reactor SRO) has verified that these numbers have been recorded and meet the above criteria. RSO signs below to verify this.
- 7. Official Shipping paper finalized. Document has:
. identities of main isotopes,
- quantities in Bq (kBq,MBq, etc),
. physical and chemical form of isotopes,
- Transport Index (TI) Value
- Signature of K. Harkness ONLY is authorized.
- Emergency Telephone Number
- 8. Copies properly placed in vehicle.
- Yellow I or Yellow III shipments follow similar but rare practices.
Filled out by Signed as checked by:y