ML20206S577

Forwards Response to NRC 870312 Ltr Re Violation Noted in Insp Rept 50-284/87-01.Corrective Actions:Operating Procedure Modified to Indicate Which Barriers Must Be in Place Prior to Reactor Operation

ML20206S577
Person / Time
Site:	Idaho State University
Issue date:	04/10/1987
From:	Hutchinson J, Adam Wilson IDAHO STATE UNIV., POCATELLO, ID
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8704220420
Download: ML20206S577 (4)

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IDAHO STATE UNIVERSITY f. j

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VICE PRESIDENT FOR ACADEMIC AFFAIRS d POCATELLO, IDAHO 83203 aos> 2as2 ass Docket No.

50-284/87-01 April 10, 1987 J.E. Gagliardo, Chief Reactor Projects Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Dear Mr. Gagliardo:

I have asked Dr. Albert E. Wilson, Reactor Supervisor for the ISU AGN-201 nuclear reactor, to prepare a response to the Notice of Violation enclosed with your letter of March 12, 1987. His're-port is attached.

I concur with the conclusions and recommendations contained in Dr. Wilson's response. I have appointed Dr. Wilson to the posi-tion of Reactor Administrator and have asked that he assume responsibility for ensuring that his recommendations are carried out.

Should you have any questions concerning his report I would request that you contact him at (208) 236-2902. If I can be of -

further assistance, please let me know.

Si erely,

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[JohnM.Hutchinson Vice President for Academic Affairs JMH:kyt Enclosure 8704220420 87041o PDR 0 ADOCK 05000284 PDR ISUls An EqualOpportunity Employer hpol

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Y, PROPOSED REPONSE TO NRC NOTICE

! OF VIOLATION 1

i Prepared by Albert E. Wilson i

Reactor Supervisor i

i

Reference:

Docket No. 50-284/87-01 Letter from J.E. Gagliardo, 3/12/87

The following response to the NRC Notice of Violation as set  ;

i forth in appendix A of the letter from J.E. Gagliardo, Chief, Reactor Projects Branch, is submitted for consideration and ap-proval of the central administration of Idaho State University.

It should answer all of the questions concerning violation of 1 Technical Specifications raised during the NRC inspection con-

ducted February 4-6, 1987.

s j A. Reactor Administrator Qualifications I

j This violation occurred when facility staffing was reduced below +

the minimus deemed suitable for continued operation. ~During the  !

1984-85 academic year, Dr. A.E. Wilson, who holds a valid SRO j License, was on leave of absence to obtain additional profes-

sional experience at a commercial nuclear power plant. The only

! other licensed SRO at the facility, Terry Smith, resigned to ac-

! cept a position at Los Alamos National Laboratory. A formerly j licensed SRO, Jerry Ramsay, was re-examined and had his license j reinstated. However, Mr. Ramsay was not a full time employee of the University, and it was deemed by the Reactor Safety Committee I

{ that-it would be advisable to have a Reactor Administrator who j was at the facility full time. Unfortunately, the decision was

! not documented and the request for a change in Technical

! Specifications, which would have been required to implement the decision, was never submitted. For these reasons, the violation J occurred.

4 i The Reactor Safety Committee met on April 3, 1987 to review the i findings of the NRC inspection and make recommendations for l r3 solution of the findings. Their recommendation was two-fold:

1) that Dr. A.E. Wilson be appointed as Reactor Administrator (in I addition to his position of Reactor Supervisor) since he has a i

valid NRC SRO license and has returned to full time duties at ISU, and 2) that a request for a change in Technical Specifica-tions be prepared to eliminate the SRO requirement from the Reac-

. tor Administrator position. The change requested will provide j more flexibility in the future and prevent future violations of j this type.  ;

! Facility staffing has been completed. Two more persons are pre-pared to take the NRC SRO exam and two to take the RO exam.

] These exams will be given the week of April 13, 1987. Assuming I

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I that at least one person passes the SRO exam, there will be ade-quate qualified staff to satisfy present Technical l

Specifications.

Even so, a change in Technical Specifications will be requested so that staff qualification requirements will conform with ANSI /

ANS-15.4-1977 (N380), " Selection and Training of Personnel for Research Reactors." According to that document, the Reactor Ad-ministrator should meet Level Two qualifications which do not j include license or certification as an operator.

i Compliance with present Technical Specifications was achieved on April lo, 1987, when Dr. A.E. Wilson was appointed Reactor j Administrator.

j j Full compliance with the intent of ANSI /ANS-15.4 (1977) will be

{ achieved when the change in Technical Specifications is approved and implemented.

IJ B. Failure to Post High Radiation Areas i

One of the areas, adjacent to the side of the reactor, was posted as a radiation area. The other, on the top, was not posted but t the entire lab is posted as a radiation area when the reactor is in operation or when maintenance is being performed. An ad-ministrative control was in effect whenever the reactor was being j operated that neither of the areas could be entered without i operator permission. When permission was granted the operator would inform the person entering of the possible radiation and require that a hand-held radiation monitor be carried into the area. It is apparent, on review of the applicable regulations, that this procedure is not adequate when the reactor is operating ,

above 3 watts. After being advised of this fact by the NRC In- '

spector both areas were immediately posted as "High Radiation l Areas" by hand lettering the word "High" on existing radiation j area signs. Permanent, metal signs which comply with the re-

! quirements of 10 CFR Part 203(c) were ordered. These new signs j have been received and are now installed. The signs are hung on i chains across the entry to each of the two mentioned areas. Such . __a posting is very conspicuous since the chain must be removed to gain access. The administrative control requiring operator per-mission for entry is still in effect.

i i Full compliance was achieved on March 16, 1987, when the new i

chains and signs were installed.  !

1 j The operating procedure will be modified to indicate which bar-

! riers must be in place prior to reactor operation. This pro-

] cedure, and the check sheet which accompanies it, will prevent future violations.

3 C. Failure to Submit Annual Operating Report I

l The Annual Operating Report for 1985 was submitted approximately l

four and one half months late. The missed date was due, in large part, to a change in facility personnel. The position of Reactor l

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Supervisor had been filled on a part time basis by a College of Engineering faculty member. He did not review the annual re-quirements prior to leaving for the summer.

The position mentioned above was filled in the fall of 1986, pending completion of licensing requirements. The new person who is in training to be thE' Reactor Supervisor caught the oversight and prepared the report which was then submitted.

The report for 1986, due June 30, 1987, has already been submit-ted so we are in full compliance.  ;

AEW:lk I

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' Albert E. Wilson Reactor Supervisor fYrQ~

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