ML113260616

IR 05000002-11-001; 08/09/2011, University of Michigan, Reply to a NRC Inspection Report Notice of Violation

ML113260616
Person / Time
Site:	University of Michigan
Issue date:	11/21/2011
From:	Alexander T University of Michigan
To:	Pederson C NRC/RGN-III
References
IR-11-001
Download: ML113260616 (2)

Text

~NIVERSITY OF MICHIGAN CAMPUS SAFETY SERVICES BUILDING 1239 KIPKE DRIVE ANN ARBOR, MI 48109-1010 OFFICE OF CAMPUS SUSTAINABILITY 734615-7025 FAX: 734 763-1185 TERRAKCE G. ALEXA.'1DER, EXECUTIVE DIRECTOR November 21, 2011 Cynthia Pederson Acting Regional Administrator U.S. Nuclear Regulatory Commission, Region III 2443 Warrenville Road, Suite 210 Lisle, Illinois 60532-4352 RE: Reply to a Notice of Violation NRC Inspection Report No. 050-00002111-001 (DNMS)

University of Michigan (License No. R-28 I Docket No. 050-00002)

Dear Ms. Pederson:

The U.S. Nuclear Regulatory Commission (NRC) conducted an on-site inspection August 9 11, 2011 at the University of Michigan - Ford Nuclear Reactor in Ann Arbor, Michigan with subsequent in-office review through October 12, 2011. The purpose of the inspection was to determine whether decommissioning actJvities were conducted safely and in accordance with NRC regulations.

Based on the results of the inspection, the NRC determined that a Severity Level IV violation of NRC requirements occurred and a Notice of Violation (NOV) was issued to the University in a correspondence dated October 24,2011. Specifically, Technical Specification 6.3 requires, in part, that decommissioning operations are independently monitored or audited to ensure they are being performed safely and in accordance with applicable license and registrations held by the University and in compliance with applicable federal and state regulatory requirements; the quality assurance is independently monitored or audited to verify that performance criteria are met as well as to determine the effectiveness of the program in satisfying the quality assurance requirements; and, monitoring or audits shall be performed annually, at a minimum.

Contrary to the above requirements, from 2009 until 2011, the University of Michigan had not independently monitored or audited either the decommissioning operations or the quality assurance program annually as required.

Reason for the Violation - the violation of Technical Specification 6.3 was an oversight on the part of the current FNR decommiSSioning staff. The reactor manager who had been responsible for overseeing all decommissioning activities since 200212003 resigned from the University in June 2009 and his duties were reassigned to staff who were less familiar with the technical specifications incorporated into the FNR license (R-28).

RECEiVED ~ttW 2 2 2611;

Corrective Steps Taken - the NOV and Technical Specification 6.3 were discussed with the FNR decommissioning staff and FNR Decommissioning Review Committee (ORC) during the DRC meeting held November 7, 2011. Recommendations were made with respect to who should conduct the annual review of the decommissioning activities and quality assurance program.

Corrective Steps To Be Taken - the University will obtain a qualified individual or individuals to conduct an independent audit of decommissioning activities and the quality assurance program and ensure these independent audits are conducted on an annual basis until decommissioning activities have been terminated. As noted in Technical Specification 6.3, the auditor shall not be directly associated with the decommissioning activities, shall not be a member of the FNR Decommissioning Project Team, and shall be familiar with quality assurance requirements applicable to the decommissioning of nuclear facilities.

Date of Full Compliance - the University will be in full compliance on or before February 29, 2012.

Thank you for your time, effort, and consideration in this matter. Please do not hesitate to contact me [(734) 647-22531 or Mark Driscoll I Radiation Safety Officer [(734) 647-2251] should you have any questions or comments regarding this U-M response to Inspection Report 050 00002111-001 (ONMS) dated October 24,2011.

cc: Mark Banaszak HolI, Ph.D., Associate VP, Chair- Decommissioning Review Committee Robert Blackburn, Assistant Manager, Laboratory Operations, MMPP Mark Driscoll, Radiation Safety Officer, Radiation Safety Service I OSEH Ruthann Nichols, Ph.D., Chair, Radiation Policy Committee 2