ML20206S555

Responds to NRC Re Violations Noted in Insp Rept 50-262/87-01.Corrective Actions:Position of Burglar Alarm Switch Adjusted Following Insp to Allow Sys to Trigger Much Earlier than on 870203

ML20206S555
Person / Time
Site:	05000262
Issue date:	04/08/1987
From:	Stohlton J Brigham Young University, PROVO, UT
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8704220416
Download: ML20206S555 (2)

Text

ico , .. .,

', f p%. !2n Qn. h APR I 5 B E  !

e- Brigham Young University i L.U

/M,,t -

8mg i< An B. 5tohiton IN= becutne W e President April 8, 1987

-J.E. Gagliardo, Chief Reactor Projects Branch Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76011 Re: Docket 50-262/87-01

Dear Mr. Gagliardo:

This letter is in response to your letter of 12 March 1987 reporting on the finding of an inspection of our L-77 Reactor Facility on the 2nd and 3rd of February 1987. Three items of noncompliance were noted in your letter. The action taken and the current status of Brigham Young University's position relative to these items are summarized below.

A. Failure to perform surveillances.

All four of the items listed require that the reactor be operated. No reactor operations whatsoever have occurred since May 1982, 'and the two senior reactor operators at our facility, Dwight R. Dixon and Gary L.

Jensen, are no longer licensed to do any reactor operations. According to their NRC licenses, they are specifically prohibited from doing any reactor operations except for fuel handling and decommissioning activities.

The surveillances therefore cannot legally be performed.

In addition, there is no practical reason whatsoever for doing the surveillances indicated if the reactor is not operated. The control rods are fully inserted now, and performance of the surveillances would only give rise to an additional hazard. 1 B. Failure to perform the biennial review of the physical security plan.

It has been nearly five years since the reactor was operated, and Brigham Young University has been trying to  !

get the reactor decommissioned during the same time period.

During this time personnel changes and the switching of duties of the now defunct Reactor Safety Committee to the University Radiation Safety Committee were perhaps responsible for the slip-up on the review of the security plan. At the meeting on 4 March, 1987 of the University , g j 8704220416 87040s ADOCK 05000262 PDR

/p[bl

' fff fl ll[

s . m . _ P_ ,,, _ ,, , ,,_

, , , , , , P DL _ _ g a

._ g g i

t J. E. Gagliardo 4.

March 31, 1987 Page 2 4

I Radiation Safety Committee, a review of the security plan l was made. It is felt that the security plan is adequate.

Furthermore, the committee interpreted 10 CFR 73.6(a) as exempting us from the security plan requirement, since the

, enrichment of our fuel is less than 20%.

I C. Failure to secure the inner nuclear laboratory door.

j The outer door to the reactor building was locked on 3 February 1987, but the inner door was not. It appeared to be closed, but the lock was not engaged. Ho.ever, we note i

that the inner door was sufficiently closed that the i l

burglar-alarm system was in operation.

J The position of the burglar-alarm switch was adjusted I following the inspection so the alarm system triggers much i l

earlier than it did on 3 February 1987. This should '

4 prevent any future occurrences of this sort.  ;

i

Brigham Young University feels that it is now in full compliance l insofar as items B and C are concerned. There is no legal way for l

the University to comply with item A. Since we expect to have the reactor fuel removed within two months, it is strongly recommended that the surveillance tests not be required at this time. To do so would require further licensing, which would be unnecessarily costly j in time, money, and safety.  ;

Also, according to Appendix B, page 2, paragraph 2 of your i

letter we are to keep the NRC regional office informed of the core

unloading schedule. We have just been advised by Mr. R.D. Denney, Manager Fuel Handling and Storage Facilities, Westinghouse Idaho ,

Nuclear Company, Inc. that we can ship our material to them during the last week of April or the first week of May 1987. We will inform i you when we have an exact date. 1 1

6 l

I hope that this information will satisfactorily answer your letter.

If you should need more information please let us know.

I Sincerely',d

! I&

j JoNn'-Stohlton

]b [u  !

] , Executive Vice-President

/ /

! cca' Eugene H. Bramhall .

! General Counsel

.