ML20005E129
| ML20005E129 | |
| Person / Time | |
|---|---|
| Site: | University of California - Irvine |
| Issue date: | 12/22/1989 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Tien C CALIFORNIA, UNIV. OF, IRVINE, CA |
| References | |
| NUDOCS 9001030341 | |
| Download: ML20005E129 (2) | |
See also: IR 05000326/1989002
Text
.
-.
..
.-
-
1
t
-
%
, . .
'
. . .
DEC 2 2 %9
-i
l
~,;
.
'!
Docket No. 50-326
l
. University of California
.
Irvine, California 92717
Attention:
Executive Vice Chancellor
.-Chang-Lin Tien
Gentlemen:
SUBJECT: .UC IRVINE REPLY TO NOTICE OF VIOLATION
l
Thank you for your letter dated October 25, 1989, in response to our Notice of
Violation and Inspection Report No. 50-326/89-02, dated September 27, 1989,
informing us of the steps you have taken to correct the items which we brought
'
to your attention.
The Notice of Violation issued to you contained a citation in section C.2 for
!
failure.to conduct an annual operating test.
In reply to this citation you
commented that the reactor supervisor and other reactor operators are in close
l
collaborationregardingoperation,schedulinftenunderdirectassessment, maintenance
I
operational issues and hence operators are o
but
to implement a diary of reactor o)erator meetings, discussions, pos
' documentation of the contact is weak or non-existent.
Your pro
and
observations of performance.- Eac1 operator will share responsibilities for
entries, although it will be the Supervisor's responsibility for opkeep of the
diary.
The NRC does not consider your reply to meet the intent of the requirement for
'
an annual operating test. However, a diary system similar to that proposed by
you could meet this requirement if properly applied.
Following is an example
of an acceptable approach.
At the beginning of each requalification cycle, the Reactor Supervisor
must conduct an annual review of the training areas he intends to cover
i
with each operator.
The review must ensure the training the Reactor
Supervisor intends to administer includes weaknesses noted during the
previous cycle for that operator, as well as a comprehensive sampling of
the applicable items listed in 10 CFR 55.45(a)(1) through (13).
A diary
methodology used for documenting these evaluations could be implemented,
as long as the performance of the items are observed by the reactor
'
supervisor.
At the end of the cycle, a review should be conducted to
ensure the areas intended to be covered in training, particularly the
applicable 10 CFR 55.45(a) items, were indeed performed.
If the
prescribed areas were not covered, there should be a mechanism for
conducting a final evaluation to cover those missing topic areas.
@@90$$k $$
6
,
20!
_ -
3
.
I
O
.
,.
.-
~2-
,
!
We request that you amend your response to item C.2 of the Notice of Violation
to commit to the above stated position for administering operating tests or
provide equivalent methods to assure the adequate administration of annual
o>erating tests.
Your reply should be submitted within 30 days of the date of
-
t11s letter.
ONffnd GOTVd
'
Ross A, 'Scarano Director
DivisionofRadIationSafetyand
Safeguards
cc w/ copy of letter dated 10/25/89:
Dr. George E. Miller, Reactor Supervisor
Department of Chemistry
UniversityofCalifornia}Irvine
Irvine, California 9271
bec w/ copy of letter dated 10/25/89:
docket file
State of California
A. Johnson
i
8. Faulkenberry
-
J. Martin
J. Zo111 coffer
L. Miller
bec w/o copy of letter dated 10/25/89:
M. Smith
,
REGION VM
M
AJohn/89sonfl'
L GYuhls k
FWenslawski
RASc
12/Zf
12/Al/89
12/g(/89
12/ /89
,
]
E
NO
NO
E
vv
v
-
SEND TO PDR
YES / NO
!
1
-
-
I
o
..
.
i[,
'
,
- UNIVERSI".Y OF CALIFORNIA, IRVINE
sEcp;E0
g
.
,m
4
..
pt:RKIll'Y e DAVIG e 1RV!N1' e 1.0$ ANGil.t3 e RfYE R$1Di e SAN DWGO e $AM l'RANC15.CO id
l SAVI# IWNB AR A e SANI A CRUZ
l
M 00130
M0: 37
o
- uTWUE*oisn^ fin?"
,
October 25th,1989
U.S. Nuclear Regulatory Commission, Region V,
1150 Maria Lane, Suite 210,
Walnut Creek, CA 94596
Attention: Director Ross A. Scarano
Docket 50-326
'
License R 116
Re:
B@iv to n Notice of Vinlatinn dated Sentember 27th.1999
i
Gentlemen:
With respect to the referenced Notice of Violation we respond as follows:
Item A. " Reactor operations continued even though none of the Operator Monthly Maintenance
checklists had been reviewed for the period August through December 1988."
(1) Comment:
As noted in remarks to the inspector this was an oversight on the part of the Reactor Supenisor
and Assistant Reactor Supervisor, even though all maintenance items had been completed on
schedule, and such a report made orally to the administrative staff.
(2)Conective steps:
The reactor daily start up checklist has been modified to mque reactor operators to verify the
~
completion and sign off of appropriate checklists prior to any daily operation. This has been
implemented.
(3)Funher action:
Futme operator training and trqualification discussions will include reference to the importance
of sign-off on documentation and additional review of necessary conditions for continued
operation. The staff, and the Reactor Operations Committee will study possible revision of the
Operating Procedures so that single myiew may be all that is needed to assure compliance.
(4) Full Compliance:
Compliance with existing procedures is considered to have been accomplished.
Item II. "The Reactor Operations Committee failed to meet during the period August 19,1988, to
January 30,1989."
(1) Comment:
This item was reported to NRC by letter dated May 5th,1989. The reasons and the corrective
,
action were described in the letter. A copy is attached for your infonnation.
(2) Corrective steps:
The steps taken are described in the attached letter.
(3)Funher action:
No further action is planned, except for consideration being given to requesting an amendment to
this Technical Specification item to reduce the frequency of required meetings.
(4) Full Compliance:
Compliance with existing requirements is considered to have been accomplished.
Ygh
Docket 50-326
Page1
10/25/89
yp-y.
c-
.
.
.
'
.
<
..
Item C.a. " Contrary to the above requirement the licensee did not document additional training
requalification examination." perator who scored less than 80% on two sec
provided to a senior reactor o
(1) Comment:
In his detailed repen on this item (Inspection Report, page 7, line 20), the inspector noted: "The
Reactor Supen'isor stated that the two sections of the examination were discussed with the SRO
as compensatory training. " This fact was documented by a note made on the front cover of the
senior operator's examination script maintained in the files as " Reviewed with PJR". The
'
' operator's initials are PJR. At the time this was felt to be both sufficient training and
<
documentation.
(2) Corrective steps:
,
This issue has been noted by the Reactor Supervisor, who acts as the training and requalification
director. Future records will be made clearer.
(3)Further action:
None contemplated.
(4) Full Compliance:
.
This issue did not arise with the 1989 requalification, where all scores were satisfactory. The
difference may have been because of a deliberate effort to make the examination even more
-
" performance based".
'
Item C b. " Contrary to the above requirement the Reactor Supervisor did not conduct an operating
test for evaluating operators or senior operators during the period of 1988 and 1989 to the date of
the inspection."
(1) Comment:
At this facility there have only been two licensed senior operators and one licensed operator
during the penod since 1987. One of the senior operators is the Reactor Supervisor, and the
other acts as Assistant Reactor Supervisor. All three individuals are in close collaboration
regarding operation, scheduling, maintenance, safety and all operational issues. Thus the other
operators are often under direct assessment by the Reactor Supervisor and there has never been
any question of their competence to operate the reactor safely. However, documentation of this
contact is weak or non existent.
(2) Corrective steps:
None taken at this time.
(3) Future Actions:
The Reactor Supervisor as training coordinator will implement a diary of reactor operator
meetings, discussions, and observations of performance for each licensed individual.
Each operator will share responsibility for entries, although it will clearly be the Supervisor's
responsibility for tne upkeep of this diary. This log should provide the necessary documentation
!
for ongoing requalification. In addition, the Reactor Operations Committee will discuss the
possibility of applying for a license amendment to obtam permission for a more flexible
requalification program better suited to the needs of our facility than that imposed by NRC in
1974.
-(4)Fu!! Compliance:
The diary system should be fully implemented by the end of this year (December 31st,1989).
We hope this will satisfy full comphance as facility and department resources do not permit
arovision of additional full coursework for operators. Changes in the program will take much
onger to be drafted and approved.
Docket 50-326
Page 2
10/25/89
p
l
,
1
'
.
.
,
.-
.
.
.-
1
Additional Item:
Your notice of transmittal asks for comments on "the level of management attention necessary to
assure continued safe operations". We are pleased that you agree that such matters "do not represent a
significant safety concem at this time". We comment as follows:
The Chemistry Department and the School of Physical Sciences are currently reviewing the staffing
situation at the facility. There had been a plan to combine a position of reactor operator and reactor
health physicist, with other chemistry departmental duties, mto a full time staff position. The
individual in mind for this position is no longer available. Whether to pursue this or some other model
'
ofimproving paid staffing at the facility is currently under review.
In the meantime, the Reactor Supervisor has made a commitment to assign additional hours of his
time to facility management and operations. He and the Assistant Reactor Supervisor are discussing
teassignment of certain tasks between them to provide more assurance of timely documentation.
It is anticipated that plans will be firm by January,1990. Meanwhile, the facility will continue to be
operated safely under existing arrangements, but with closer attemion to details of documentation,
which appear to be the major issue for concern. Review by outside individuals fmm E,II&S will also
wy closer attention to details of documentation. They will be assisted in this task by newly created
.. adit checklists.
1
Sincerely,
R'
a~
Chang
.ia Tien,
Executi e Vice-Chancellor
cc: H.W. Moore, Dean, Physical Sciences
M.C. Caserio, Chair, Chemistry
V.P. Guinn, Chair, Reactor Operations Committee
F.S. Rowland, Reactor Administrator
G.E. Miller, Reactor Supervisor
l
,
1
Docket 50-326
Page 3
10/25/89
l
l
p
4
.
,
'
,s
t
'
UNIVERSITY OF CALIFORNIA, IRVINE
'
etnKatty e Davis e say:NE e LOS ANCELES e RIVER &lDE e SAN DIECO e SAN FRANC SCO
SANTA BARBARA e SANTA CRUZ
i
DEMRTMEKr oF O!EM!sTRY
IRv!NE. CAL.!FoRNIA 92717
i
NUCLEAR REACTOR rACILITY
SUPERVISOR: DR. o.E. MILL.ER
hiay 5th,1989
TEL:(714) 856-6649 oR 714 856 6082
U.S. Nuclear Regulatory Commission,
Region V,
Docket:55 326
1450 hiaria Lane, Suite 210,
Licensee report of violation.
Walnut Creek, CA 94596
Gentlemen:
e
I have to inform you that the Reactor Operations Committee (ROC) for the UCI Nuclear Reactor
Facility failed to meet in the period August 18th,1988 to January 31st,1989,in violation of the
requirements in the Technical Specifications that the Committee shall meet at least quarterly.
Thus the fall quarter was missed. In 1988 there were three regular meetings (February 18th, hiay
20th,and August 18th).In addition there were special meetings of staff before, on, and after hiny
2hd, when an emergency exercise was conducted, and on January 31st,1989 for a complete
rdew of the Emergency Plan.
The reasons were:
(a) routine operations were discontinued between December 13th and January 18th because of a
combination of staff reduction, staff illness, and the need to carry out additional maintenance at a
time when maintenance staff extemal to the facility were unavailable. A December meeting that had
been scheduled was thus postponed.
(b) difficulties with the unavailability of secretarial assistance.
These problems have been resolved.Special maintenance has now been completed and routine
maintenance conducted on schedule. The Reactor Supervisor now has a new secretarial assistant
who will be able to deal with reactor paperwork once her training period on other department
matters is complete. Committee meetings have been held on schedule - January 31st, hiarch 14th,
and planned for hiny lith,1989 to teview operations, emergency response plans and
maintenance.
It is important to emphasize that continual surveillance on behalf of the ROC has been maintained
'
by the personnel of the Office of Environmental Health and Safety, who have reviewed both
performance and records at the facility involving not only safety matters, but also operations and
general maintenance. The results of their reviews have been given to the Reactor Supervisor on a
number of occasions and resulted in small corrective actions. The Committee is satisfied that the
facility has continued to operate with proper regard for the health and safety of the public in spite of
the absence of a formal meeting, and no hazarc has resulted, nor has the likelihood of hazard been
increased.
Sincerely,
q . C. mal
.
!
George E. hiiller
.
Reactor Supervisor
i
cc: Reactor Operations Committee members
jD % t