ML20058K399

Responds to Violations & One Deviation Noted During Insp Rept 50-284/93-01 on 930802-06 & Enforcement Conference on 931008.Corrective Actions:Former Reactor Supervisor Replaced & New Requalification Program Approved by NRC

ML20058K399
Person / Time
Site:	Idaho State University
Issue date:	12/03/1993
From:	Charyulu V IDAHO STATE UNIV., POCATELLO, ID
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 9312150195
Download: ML20058K399 (15)

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REG!ON N U* **D*# 3' 1993 m

STATE U.S. Nuclear Regulatory Commission, Region IV UNIVERSITY Attn: Regional Administrator ,

611 Ryan Plaza Dr., Suite 400 Arlington, Texas 76011

Dear Sir:

Onke of the Dean I am enclosing our response to the seven *.Inlations and one conege or deviation identified during the 'i . R . C . inspection of our Engineering facility by Mr. Larry Ricketson and Mr. Anthony Gaines Campus Box 8060 during August 2-6, 1993 and the enforcement conference b'. eld PocateU hho at our facility on October 8, 1993.

We appreciate the thorough, diligent and professionally conducted inspection and enforcement conference by you and are hoping that you will find our response satisfactory. As you may note the management oversight has been increased and a tracking system has been put in place to avoid the reaccurrence of violations. Also, an improved documentation system is being reviewed.

If you have any further questions please contact us.

Sincerely, t l' / /l 7 UO LJ Dr. V. Charyulu Reactor Administrator and Dean of College of Engineering t

cc: USNBC Document Control Deck Washington, D.C. 20555 I b O I ~ [,

Phone:

0 08) 236-2902

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FAX: Ty W 2n4538 f g 9312150195 T31203 0 94 0370 ISU is An Equal Opportunity Employer PDR ADOCK C5000284 J O PDR d

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RESPONSE TO NOTICE OF VIOLATION IDAHO STATE UNIVERSITY i This is the response to the Notice of Violation issue 6 to Idaho State University (ISU) in the Nuclear Regulatory Commission (NRC)

Inspection Report 50-284/93-01 on License R-110 pursuant to Title ,

10 of the Code of Fedcral Regulations (CFR) Part 2. i Item A: Violation 284/9301 Failure of the licensee's Reactcr Safety Committee (RxSC) to administer an annual writte.

examination to a senior operator and two operators, a:)d failure of the licensee's RxSC to observe the operation i of the reactor by two senior operators and two operators during 1992.

1) Reason for violation: The Reactor Supervisor (RS), at the  !

time of the infraction and senior operator, expressed that he '

did not have to take the requalification exam as per the NRC approved requalification program at the University of Utah -

where he was maintaining a valid SRO license. The two reactor operators were ocheduled to take an NRC administered upgrade i exam in November of 1992 which they successfully completed on November 3, 1992. The RS interpreted the upgrade to SRO from RO for these two operators as having fulfilled the intent of the requirement. The RS also assumed that he was an ex-officio member of the RxSC, and that through his observations  !

of the facility SRO and RO's operating the reactor, he would ,

have satisfied the requalification requirement concerning  !

observations of reactor operations by operators. Also note ,

that this violation was self-reported to the NRC inspectors.

2) Corrective actions taken and results achieved: The former RS has been replaced by a recently appointed RS. The new RS i has spent a significant amount of time reviewing all facility ,

documents to de. ermine where responsibilities lie within the facility administrative structure and to determine the periodicity of these responsibilities.

i Further, a new requalification program for the operators has  :

been approved by the NRC effective June 1993. These new requalification requirements have been reviewed by the SRO's and have been implemented in the operator training program. '

According to the new requalification program the RxSC members are no longer required to administer the test nor are required to observe the reactor operation by the operators. ,

The new RS is using a tracking system that he has devised to ensure when operators need their requalification exams and t reactor operations exams administered. Presently, the only  ;

two licensed operators at the facility are current on their '

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requalification requirements in part by using the tracking l system devised by the RS. The monthly reports generated by  !'

the RS also assist in tracking future requalification requirements for'the facility operators.

3) Corrective actions that will be taken to avoid further l violations: Since corrective actions as stated in part A.2 ,

above have been carried out, no further action is-seen to be necessary at this time. .

4) Date when full compliance will be achieved: Full compliance i has been achieved.  :

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Item B: Violation 284/9301 Failure of the licensee to ensure  ;

that an SRO receive his biennial medical examination. l t

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1) Reason for violation: The SRO was on sabbatical leave i beginning mid December of 1991 until the month of August of j 1992. He was not present at the facility on a regular basis -

4 during his sabbatical leave period. Since there was no formal -!

tracking system in place to ensure when operators needed their I medical exams, the SRO in question lapsed his biennial medical  !

exam requirements. Also note that this violation was self-  !

reported to the NRC inspectors.  !

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2) Corrective actions taken and results achieved: The current l RS has developed a tracking system to ensure when facility j operators need to receive their biennial medical exams. In 1 addition, he is also generating monthly reports that track  ;

upcoming requirements such as medical exams. Currently, the i two facility operators meet their medical exam requirements in  ;

accordance with (IAW) 10 CRF 55. l c

3) Corrective actions that will be taken to avoid further  !

violations: Since corrective actions as stated in part B.2 above have been carried out, no further action is seen'to be necessary at this time. [

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4) Date when full compliance will be achieved: Full compliance -

has been achieved as is explained in part B.2 above, i Item C: Violation 284/9301 Ft. lure of the licensee to keep '

records showing the receipt, transfer, and disposal of-byproduct material'.

1) Reason for violation: Although the irradiated samples'from 1 the AGN-201 are generally of very low radioactivity, it has always been the practice to survey the irradiated samples as.

soon as they are removed from the reactor. Because of the -

relatively low neutron flux levels associated with the AGN-201 )

reactor, isotopes that were produced have generally been of exempt quantities were transferred to recipients on campus r

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that did not possess a source material license. Since January 1993, prior to the present inspection, we have ensured that i all transfers are authorized and documented.

The facility recognizes the need for more proper documentation i with respect to byproduct material.  ;

2) Corrective actions taken and results achieved: As mentioned, corrective actions have been in place since January '

of 1993 to assure proper records are kept concerning byproduct material. Training between the RS and the other SRO has been conducted to ensure that any byproduct material produced has r proper record entries made to be in compliance with 10 CFR '

30.51.

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3) Corrective actions that will be taken to avoid further r y_iolations: The RS is drafting an improved record system for byproduct material produced by the reactor. This new documentation will further assure compliance with 10 CFR 30.51. Also, RxSC members are currently reviewing suggested j revisions to the reactor operating procedures and forms to  ;

ensure that the necessary byproduct material record entries  !

are made immediately after byproduct material production. ,

4) Date when full compliance will be achieved: The improved  ;

record system for byproduct materials and the revisions to the reactor operating procedures and forms will be approved and '

implemented by March 31, 1994 to meet full compliance.

Item D: Violation 284/9301 Failure of the licensee to verify that persons receiving byproduct material were authorized to receive such material as is required by 10 CFR 30.41.

1) Feason for violation: Since the byproduct material has been ,

of very low activity, it has been the past practice to i transfer items without verifying that the recipients had an i authorized program under the ISU campus broad scope material license. Lack of familiarity with 10 CFR 30, with regards to byproduct material, was the reason for this violation. *

2) Corrective actions taken and results achieved: The R5 and the other SRO had held training with regards to transferring byproduct material to other users to ensure that the facility is in compliance with regards to 10 CFR 30.41. Also,.since January of 1993, we have been following the necessary steps, concerning byproduct material, set forth by the Technical Safety Office to ensure that byproduct material is only i transferred to authorized users.  ;

3) Corrective actions that will be taken to avoid further  ;

violations: The RS is drafting an improved record system for  ;

byproduct material produced by the reactor. This new '

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4 documentatien will further assure compliance with 10 CFR 30.41. Also, RxSC members are currently reviewing suggested I revisions to the reactor operating procedures and forms to  !

ensure that the necessary byproduct material record entries >

are made prior to transfer to other authorized users. j

4) Date when full compliance will be achieved: The improved. [

record system for byproduct materials and the revisions to the. '

reactor operating procedures and forms will be approved and 7 implemented by March 31, 1994 to meet full compliance.  !

Item E: Violation 284/9301-06 -

Failure of the licensee to j maintain radiation survey results IAW 10 CFR 20.

1) Reason for violation: Lack of familiarity with 10 CFR 20,

• with regards to maintaining records of radiation surveys, and the lack of proper documentation are the reason for - this ,

violation.

2) Corrective actions taken and results achieved: The RS and' the other SRO has held training with regards to the necessity to maintain proper radiation survey results to ensure that the facility is in compliance with to 10 CFR 20. Also, since-January of 1993, we have been following the necessary steps to ensure that the required radiation surveys on byproduct material, set forth by the Technical Safety Office, are properly recorded and maintained. Therefore, the facility is and has been in compliance with 10 CFR 20 since January of 1993, prior to the inspection that took place in August of 1993.

3) Corrective actions that will be taken to avoid further violations: The RS is drafting an improved record system for I byproduct material produced by the reactor. This new documentation will further assure compliance with 10 CFR 20.

Also, RxSC members are currently reviewing suggested revisions to the reactor operating procedures and forms to ensure that the necessary byproduct material record entries are made with regard to radiation surveys.

4) Date when full compliance will be achieved: The improved record system for byproduct materials and the revisions to the reactor operating procedures and forms will be approved and  ;

implemented by March 31, 1994 to meet full compliance. l Item F: Violation 284/9301 Failure of the Radiation Safety 3 Officer (RSO) to provide training, IAW the NRC approved .

Emergency Plan, to the Reactor Administrator (RA). t i

1) Reason for violation: The requirement for the RSO to train i on emergency plan originated when the RSO and the RS were the l

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same individual. However, the dual position was split in December of 1991. The new RSO interpreted the training requirement as radiological control training in support of ,

emergency preparedness, not complete training to the emergency '

response plan. Nonetheless, the RSO failed to perform a j recognized duty by not training the Reactor Administrator in radiological support of emergency preparedness.

2) Corrective actions taken and results achieved: The RS has developed a tracking system to ensure the necessary Emergency Plan training for university personnel is given within the i specified periodicity. Currently, with the use of the tracking system developed by the RS, Emergency Plan training is up to date and the facility is in full compliance.

3) Corrective actions that will be taken to avoid further -

violations: The Emergency Plan will be changed to identify the "

RA and RS as responsible for training related to the Emergency Plan. The RSO will assist the RA and RS in radiological control training related tho the emergency plan. -

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4) Date when full compliance will be achieved: Changes to the Emcrgency Plan will be complete by March 31, 1994.

Violation 284/9301 Failure of the licensee's RxSC to Item G:

conduct audits IAW the Technical Specifications within l pariodicity.  :

1) Reason for violation: On February - 4, 1992 RxSC meeting, the '

RS (at that time; presented an Audit and Review Plan that would correct the violations of the December 1991 NRC inspection. However, the Audit and Review Plan failed to address that several audits were due before the recommended ,

implementation date. Also, the Audit and Review Plan addressed how to perform the audits and not specifically how to track them. The lack of an adequate tracking system to  ;

ensure that audits required by the Technical Specifications ,

are performed within periodicity is the reason for this violation. Also note that this violation was self-reported to  :

the NRC inspectors.

2) Corrective actions taken and results achieved: The current  !

RS has developed a Tracking system to ensure audits, along with other facility requirements, are completed within i periodicity. The RxSC has reviewed and approved the Tracking system at the November 23, 1993. Also, monthly reports l generated by the RS track future administrative requirements. '

This monthly report is one method used to ensure that f acility i personnel, other than the RS, are aware of their administrative duties. The Tracking system is in use and is ensuring that the facility is in compliance with all administrative requirements.

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3) Corrective actions that will be taken to avoid further l violations: Since corrective actions as stated in_part G.2 I above have been carried out, no further action is'seen to be i necessary at this time.

4) Date when full compliance will be achieved: The facility is presently in compliance.

Item H: Deviation - Failure of the licensee to establish Letters of Agreement (LOA) with off-site emergency response agencies.

1) Reason for deviation: The previous RS began to research the necessary requirements to develop LOA. This is evident by copies of the LOA sent to the previous RS from Texas A&M University Assistant Director of the Nuclear Science Center Laboratories dated 29 January 1992. After receiving this information, the previous RS failed to complete the task of {

obtaining letters of agreement from the off-site emergency  ;

response agencies, although he (the previous RS) had reported  :

to the RxSC that LOA's were sent as reflected in the draft  !

minutes submitted to the NRC. l

2) Corrective actions taken and results achieved: Draft LOA's  :

were hand delivered to Bannock Regional Medical Center,  ;

Pocatello Regional Medical Center, Idaho State Police, and the '

City Attorney (for the purposes of city fire and police 1 support) on Oct 5, 1994. All of these entities, with the _l exception of Pocatello Regional Medical Center, have verbally -!

approved of LOA's with only minor revisions to be made. *

3) Corrective actions that will be taken to avoid a further deviation: Contact with the listed off-site emergency support i agencies is and will continue to be maintained. Understand. '

that the facility can not make those support agencics sign the LOA's. We can make no promise that they will want to support us for the purposes of emergency response, but we believe  ;

through the good faith of community service that there is no reason that'they will not come to some final agreement on the j LOA's. +

4) Date when full compliance will be achieved: The facility will continue to make a concerted effort, as we have since  ;

October 5, 1993, to obtain the LOA's requested. The RxSC will 1 also provide oversight in ensuring that a strong effort is '

made to acquire the LOA's. Therefore, we ci vi set no date of implementation , but only a very strong intent to have the e of f-site support agencies sign the LOA's. We wish this action to occur on or before March 31, 1993. 1 1

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f REACTOR SAFETY COMMITTEE MEETING NOVEMBER 23, 1993 j i

i AGENDA' I f

1. Election of Dr. Tom Gesell as alternate l chair of the Reactor Safety Committee. '

2. Discussion of Notification of Violations letter from the NRC dat;0 November 1993.

3. Other Business. t f

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l Minutes of the Idaho State University  !

Reactor Safety Committee l t

Date: November 23, 1993 Start time: 7:15 P.M.

End time: 8:45 P.M.  ;

Members Present-  !

Dr. Tom Gesell, Radiation Safety Officer Dr. Hary Charyulu, Reactor Administrator /

Mr. R. David Clovis, Fenctor Supervisor  !

Dr. Frank Harmon ,

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Mr. Terry Smith f .!

Others Present: 'k I

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1. The meeting was called to order by the Reactoc Administrator at "

7:15 P.M. .

2. Dr. Tom Gesell was appointed the Reactor Safety Committee Chair j alternate. l

3. There was a broad discussion of all Nuclear Regulatory l Commission (NRC) cited violations and deviations ofthe August 1993 inspection. The corrective actions in place and those to be taken )'

were reviewed. After the review, it was agreed that all corrective actions will be in place by March 31, 1994. By April 30, 1994, the i Reactor Safety Committee (RxSC) will perform a review regarding the i implementation of the corrective actions. Also, the RxSC will- I perform an ongoing review, effective immediately, to ensure  !

corrective actions either been or are carried out. This is a three  :

step process:  !

a) The RxSC finds the methods to be used or that have been j used to perform corrective actions for the deviations and  :

violations as satisfactory. '

b) The RxSC will ensure that all corrective actions will be  !

in place by March 31, 1994. I c) The RxSC will conduct an on-going review between now and March 31, 1994 to ensure that the corrective actions are implemented in a timely fashion.  ;

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4. Dr. Frank Harmon suggests that the Institute of Environmental i Health and Safety at Idaho State University review and upgrade (if 'j needed) the Reactor Emergency Plan. i

5. Dr. Tom Gesell informed the RxSC that the Memorandum's of Understanding (MOU) between the university and off-campus emergency response organizations have been sent out and that three of four entities have responded regarding tentative approval of the MOU's.

6. A motion was made to approve the plan to implement all corrective actions, regarding the deviation and violations. The motion was passed unanimously.

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7. Mr. Terry Smith would like the RxSC to consider giving authority to an approval subcommittee with ~ regards to approving new or revised procedures, experine:4ts, or configurations. I

8. The meeting was adjourned at 8:45 P.M.

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l IDAHO STATE UNIVERSITY MONTHLY REACTOR REPORT l SEPTEMBER 1993 ,

Prepared by:

R. David Clovis Reactor Supervisor 11/05/1993  ;

RESPONSE (S) NEEDED FROM:

CHAIR, R..'.CTOR SAFETY COMMITTEE REACTOR ADMINISTRATOR  :

RADIATION SAFETY OFFICER SENIOR REACTOR OPERATORS:

REACTOR OPERATORS:

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i OTHERS:

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ISU AGN-201 REACTOR REPORT - SEPTEMEER 1993 1.a. There were no changes to the facility design, performance characteristics, or operating procedures relating to reactor '

safety.

b. Results of major surveillance tests and inspections:

Completed MP-I Rod Maint. on 09/07/1993.

Completed Technical Specification (TS) 4.3.b Shield tank -

inspection for leakage on 09/30/1993.

2. The reactor was operated a total of 35.45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> during 23 individual operations.

Jmdividual O_pgrator Rum Times R. David Clovis 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> 16 operations Dr. A.E. Wilson 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> 7 operations Trainee Opfrations  ;

Kermit Bunde 9 operations Dale Boren 2 operations ,

Bob Boston 4 operations Bruce Jensen 3 operations '

3. There were no unscheduled shutdowns.

4. Corrective Maintenance: '

Replaced the Reactor Console " Power On" indicator light bulb.

Adjusted #1 Safety Rod drive worm gear output shaft. 1 5.a. There were no changes to the facility to the extent that it changed the description of the f acility in the application for  ;

license or amendments thereto.  !

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b. There were no changes to the f acili ty procedures ar. described l in the facility TS.

c. There were no new experiments or test performed.

6. There were no new safety evaluations written, because no new experiments or test were performed.

7. Summary of the nature and amount of radioactivity effluents j released or discharged to the environs:

a. Liquid waste - none

b. Airborne waste - none i

c. Solid waste- none

8. There were no environmental radiol ogica] surveys performed outside the facility.

9. Personnel Radiation Exposure:

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Third quarter radiation exposure results are not back from Landauer as of yet.

The only recorded exposure to date for the calendar year is I for: -!

R. David Clovis 40 mrem t

ITEMS SCliEp3LEp_ EOR OCTOBER l_2.21 l i

Maint. and Surveillance:

TS 4.1.a Estimates for Safety and Control rod reactivity worths. l TS 4.1.b '

Shutdown margin and excess reactivity-TS 4.2.a Scram time and average reactivity insertion rate TS 4.2.b Seismic displacement interlock channel test i

Other:

f NRC Enforcement Conference 10/08/1993 [

TRTR Meeting 10/19-22/1993 NRC Operator Licensing Exams 10/25-27/1993 i Fuel status report due 10/25/1993 J_TEMS_S_C_liEDULED FOR NOVEM]ER 1993 i

Requalification:  !

Dr. A.E. Wilson written and console exam-R. David Clovis console exam Emergency and Security Plan: I Hold Emergency Plan and Security Plan - training with university personnel.

3 Hold the annual emergency drill. j S

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