ML20070G278

Responds to NRC Re Violations Noted in Insp Rept 50-062/94-04.Corrective Action:Many Routine Surveys Performed

ML20070G278
Person / Time
Site:	University of Virginia
Issue date:	07/13/1994
From:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9407200057
Download: ML20070G278 (7)

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. scnoouw ENGINEERING fiD my 13.1994 & APPUED SCENCE NUCLibtR RIG 1CTOR FACILHY U.S. Nucicar Regulatory Commission D " " "' "I M h ""i'" ' -

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Charlouewille. VA 220'O 2442 K04 AG544a FAT 804WS2-5473 REPIN TO A NOTICE OF VIOLATION Re: NRC Inspection Report No. 50-62/94-04, Docket No. 50-62, License No. R-66, for University of Virginia Reactor Facility Gentlemen:

As stated in NRC Inspection Report No. 50-62/94-04, Section 10 of the University of Virginia's License No. R-66 Standard Operating Procedures requires in Part 10.5.B.2.C.1 that samples of pond water be collected within two weeks prior to a planned release. Contrary to the above, during May of 1994, water samples were taken on May 2 and subsequently three releases were made on May 5, May 10, and May 23; the last release occurring outside of the two week window stipulated by procedure. The release form which must be completed requires review by 2 persons other than the person making the release. Emphasis is placed on ensuring that the concentration of radioactivity in the water to be released is below our administrative limit. The two people responsible for review failed to recognize that the two week window had been execeded.

Normally, the person performing the release ensures that current pond sample analysis results are available before a release is even planned. In this instance, the individual performing the release was in the process of terminating his employment at the facility. We feel this situation contributed to a lack of attention to detail on the part of the person preparing for the release.

All persons responsible for preparing and reviewing a release have been instructed to pay closer attention to all items requiring review on the release form. Although the form currently requires a box to be checked indicating the sample analyses are current, an additional check box will be added to the form closer to the signature location. This will put additional emphasis on the need to review sample dates prior to the release. As the May 23 release was the only release in non-compliance, we believe we are currently in full compliance in this area. Under the circumstances, we feel that this particular oversight was a rare occurrence and we are not aware of this ever occurring previously. We ask that you take this into consideration in your review of the violation and our response. The revised pond release form will be completed and put into use subsequent to approval by the Reactor Safety Committee on July 21,1994.

As stated in NRC Inspection Report No. 50-62/94-04 Section 2.k (page 9), record of operation checks for 3 quarters during 1992 were found to be missing. During this time period, the primary person responsible for maintaining these records was on an extended leave of absence.

A technician whose normal duties require similar survey instrument maintenance activities was asked to perform operation checks (opchecks) on reactor survey instruments during this time.

At the time of inspection we believed that if the meter had been in service, the operational checks must have been performed but not recorded. All reactor staff are instructed to check the j calibration sticker on a meter prior to use and to remove from service any meter which is out of 9407200057 940713 i PDR ADOCK 05000067 O POR fh'E f Y(fY$ k L

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c'alibration or opcheck. In the time since the inspection , the reactor H.P. realized that if the meter had been in service during this time period,it should have been noted on the cover sheet of one of the many routine surveys performed at the facility. By procedure, the calibration and opcheck duc date of the meter being used to perform a survey must be recorded on the cover sheet of the survey form. Consequently, the survey records for 1992 were retrieved from storage and reviewed. The meter in question (Eberline ESP-1, SN 2154) was noted to have been in service and was operationally checked as required in 1992. We respectfully request that you consider the submission of the following notarized copics of five survey cover sheets as recorded documentation that the required operational checks were performed. As noted in the inspection report, it is documented that an opcheck was performed on 4-27-92. The attached documents show:

Opcheck duc date 10-27-94 Indicating an operation check was performed on 7-27-92 Opcheck duc date 1-27-92 indicating an opcheck was performed on 10-27-92.

Records also show that the meter was opchecked on 1-29-93. We believe that we now have documentation showing all required operation checks of this instrument were performed in 1992.

As stated above, the apparent gap in the record keeping occurred during a time period when an individual was given duties to perform which were not totally routine for him and consequently must have forgotten to record the required opcheck results after performing the checks. In the two years since this event, a computerized data base has been used to track calibrations and operational checks. In addition to the traditional written records, copies of printouts generated from the computerized data base will be filed as backup record to avoid similar difficulties in the future.

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