ML20247A182

Responds to NRC Re Violations Noted in Insp. Corrective Actions:Personnel Trained by New Health Physics Procedure 30-2 & Permanent Electrical Svc Installed for Sampler by Univ Physical Plant Organization

ML20247A182
Person / Time
Site:	North Carolina State University
Issue date:	08/30/1989
From:	Elleman T North Carolina State University, RALEIGH, NC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8909120058
Download: ML20247A182 (4)

Text

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l North Carolina State University 1

Nuclear Reactor Program Department of Nuclear Engineering Box 7909 Raleigh, NC 27695-7909 (919) 737-2301 August 30,1989 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 REPLY TO A NOTICE OF VIOLATION Docket No. 50-297 License No. R-120 In response to the Notice of Violation, dated August 2nd 1989, from Mr. William E. Cline, Chief of the Nuclear Materials Safety and Safeguards Branch, our reply is as follows:

Violation: Licensee failed to instruct all individuals working the restricted area in that, no training covering all the subjects required by 10 CFR 19.12 was given to the' Radiation Protection Office personnel who routinely perform surveys in the reactor facility.

1. Admission or Denial:

4 The violation is admitted.

2. The reason for the violation if admitted:

l The Radiation Protection Office (RPO) provided basic radiation safety training and "on-the-job" specific facility training during their initial visits to the PULSTAR Facility. This training was necessary in support of other radiological activities under the State of North Carolina license (an Agreement State) and was considered to meet the the intent of 10 CFR 19.12. Documentation, however, )

concerning the details of this training was not available. Emergency response i training, pursuant to the PULSTAR Emergency Plan, had been provided and l

documented by the Reactor Health Physicist.

3. The corrective steps which have been taken and the results achieved:

All Radiation Protection Office personnel that require unescorted access at the L PULSTAR Facility, are now trained by the Reactor Health Physicist and his staff l as detailed by the new Health Physics Procedure 30-2, " Radiation Safety 8909120o58 890830 PDR ADOCK 05000297 0 PDC , l l I E i Nonh Carolina State University is a land-grant university and a constituent institution of The University of North Carolina. t l

Reply to a Notice of Violation Docket No. 50-297 License No. R-120 l

Training", Revision 0, January 20th 1989. This training includes specific facility features, alarm systems, potential hazards, response to emergencies, and a review of 10 CFR 19. Emergency response training, pursuant to the PULSTAR Emergency Plan, continues to be provided for these individuals as dictated by the l Emergency Plan.

4. The corrective steps which will be taken to avoid funher violations:

The use of Health Physics Procedure 30-2 for similar individuals who require unescorted access to the PULSTAR Facility shall prevent future violations of this type.

5. The date when full compliance will be achieved:

Additional training was provided to the Radiation Protection Office personnel on October 13, 1988. Health Physics Procedure 30-2 was approved by the Radiation Protection Council on April 10,1989. Therefore, full compliance is in effect at this time.

Violation: Licensee failed to comply with requirements of the procedures in that: (1)

From February 28,1989 through May 30,1989, no sample from the air sampler located on the rooftop of the Riddick Engineering Building and no analysis was made to determine the gross alpha and/or beta activity, and, (2) During July 1988, and from October through December 1988, and from January through March 1989, no milk samples were collected and/or analyzed for Strontium-90 activity.

1. Admission or Denial:

The violation is admitted for items (1) and (2).

2. The reason for the violation if admitted:

Item (1): No electrical power was available at the air sampler during the specified periods due to the need to make safety related changes to the electrical supply. This action resulted from an inspection by the State of North Carolina Department of I;tbor and University Life Safety personnel. Specifically, the original power supply, that incorporated an extension cord, was ordered to be removed from service by the Life Safety organization and replaced with conduit and permanent wiring. Therefore, the sampler was unavailable, pending installation of this permanent power supply by the campus Physical Plant organization. This work had to be handled through the university's normal work order system and higher priority work on campus delayed the permanent installation of the power supply during the specified period of violation.

Reply to a Notice of Violation Docket No. 50 297 License No. R.120 Item (2): A similar hardware problem existed,in the fact, that the fume hood used for the sample analysis in the Radiation Protection Office laboratories failed the university's ongoing hood certification and upgrade program, and was removed from service during the specified intervals. A second hood in the RPO radiological area was operable, but was being used in a different aspect of the RPO's radiation surveillance program and as a result had material stored inside preventing its use.

3. The corrective steps which have been taken and the results achieved:

Item (1): Permanent electrical service was installed for the sampler by the university Physical Plant organization and the air sampling started again.

Item (2): Because of the contium.d delay in getting replacement parts for the primary fume hood, the second ? nod was cleared and placed into service for performing the sample analysis Wik analysis as required, has continued since this change. In addition, the primary hood has been successfully repaired.

4. The correctiv: neps which will be taken to avoid further violations:

Item (1): The new permanent electrical service for the air sampler shall prevent additional violations of this type.

Item (2): Both fume hoods are operational an therefore do not inhibit the performance of the milk analysis. In the future,if either hood fails, the second hood will be used to accomplish the required analysis and therefore shall prevent additional violations of this type.

5. The date when full compliance will be achieved:

Full compliance is in effect at this time.

If there any questions in regard to our reply, please advise.

Respectfully submitted, Adsa 4 t&A Dr. Thomas S. Elleman Head, Nuclear Engineering i l

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, , i id;,1y to a Notice of Violation Den:ket No.50 297 License No. R 120 cc: NRC Regional Administrator, Region II K.V. Mani, Reactor Health Physicist Garry D. Miller, Nuclear Reactor Program Associate Director William D. Morgan, NCSU Radiation Protection Officer GDM:

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