ML19269D392

Responds to NRC 790323 Ltr Re Violations Noted in IE Insp Rept 50-124/79-2.Correcctive Actions:All Procedures Being Rewritten & Monthly Reactor Operator Meetings Held

ML19269D392
Person / Time
Site:	05000124
Issue date:	04/18/1979
From:	Parkinson T VIRGINIA POLYTECHNIC INSTITUTE & STATE UNIV., BLACKSB
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19269D389	List: ML19269D392
References
NUDOCS 7906020178
Download: ML19269D392 (3)

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s VIRGINIA POLYTECHNIC INSTITUTE AND STATE UNIVERSITY '

3,/l Blacksburg, l'irginia 24061 Nect. tan AcnvaTiow Aw at.Tsis LA90E ATOtt 79 APR20 AIO: 0 f i April 18, 1979.

Mr. R. C. Lewis, Chief Reactor Operations and Nuclear Support Branch U. S. Nuclear Regulatory Comission 101 Marietta St. NW Atlanta GA 30303 Ref: RII: CJ. 50-124/79-02

Dear Mr. Lewis:

In response to your letter of March 23, 1979 pertaining to Inspection Report No. 50-124/79-02, I enclose our comments and actions taken. Because of the very time-consuming process of re-w uing all our procedures and having them reviewed and approved by the Radiation Safety Com=ittee, we request an extension of the completion deadline from June 30, 1979 to August 30, 1979.

With respect to two items of non-compliance, we do not concur that we should receive citations. Our reasons for this viewpoint are given in paragraphs A.2 and C. of the enclosed document. Accordingly, we respectfully request that the citations for these two ite=s be deleted.

As for the other items of non-co: pliance, we believe that tTie actions we have taken bring us into full co=pliance with the provisions of our license No. R-62.

Sincerely yours, NN T. F. Parkinson, Director Nuclear Reactor Laboratory Encl.

icc: Dr. Roger A. Teckc11, Chairman, PSC

. .J .Dr. A. Krebs, Vice-President for Administration

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\M8 Blacksburg, Virginia 24061 Nua.:an Acuv Anow AN ALvsis LASOR ATORT Comments on Inspection Report No. 50-124/79-02 A. Operator Re-qualification Plan

1. With respect to the requirement for monthlyHowever meetings of all no minutes reactor operators, such meetings have been held.

of the meetings held during the period April-June 1978 were on file.

We are now recording all such meetings in the " Conversational Log" so that verification of the meetings can be established.

2. With respect to the requirement that a list of qualified reactor operators be maintained "at the reactorWe console", such a Imve now moved list was posted in the reactor console room. In our judgement, this list to the ic=ediate vicinity of the console.

a citation is not warranted since the phrase "at the reactor console" is subject to different interpretations by different NRC inspectors.

3. To insure that all reactor operators review new and revised procedures, a check list has been distributed to each operator indi-cating the dates by which he or she must complete all requalification requirements.

4. Reactor operators are now recording the in operating times in the " Conversational Log". Individual records of operating times are also maintained in the "Requalification Notebook % and are logged on the Reactor Run Sheet.

B. Since the NRC has mandated that we completely re-write all our operating, maintenance and e=ergency procedures, approximately 6 man-conths have been devoted to this task with the objective of completing the documentation by June 30, 1979. We also maintain A a schedule showing when required maintenance ite=s are due.

status report on all items is reported quarterly to the Radiation Safety Com=ittee. In the period before the deadline, some interim procedures are being utilized while the permanent procedures are In our judge-in preparation and are being reviewed by the RSC.

ment the extensive documentation effort now in progress will, upon completion, preclude future infractions of the type cited.

C. We do not concur that an infraction should be givenAccording for the fission to product monitor being set at a value of 100 cr/hr.

the Technical Specifications, the set-point should be at a value 10 times its " normal background reading". The value of the normal

• background reading is subject to differing interpretations by different individuals. The" normal background reading" for this instrument depends on a number of factors such as the past operat-

,' ,' Turthermore, the actual set-point s e. $ng history of the reactor.

'"was at 100mr/hr..which amounts to about 2cm on the ceter scale

' - as compared to a value of 80 mr/hr. which the NRC inspectors

ruled should be the proper det-point. We question whether the 1

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accuracy of the meter movement and its associated magnetic latch make this small discrepancy of any actual significance.

We plan to revise the Technical Specifications when we apply for renewal of our reactor license to remove this ambiguity.

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