IR 05000002/1993002
| ML20036C048 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 05/21/1993 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fleming R MICHIGAN, UNIV. OF, ANN ARBOR, MI |
| Shared Package | |
| ML20036C049 | List: |
| References | |
| EA-93-069, EA-93-69, NUDOCS 9306090071 | |
| Download: ML20036C048 (5) | |
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- NAY 21, 1993
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Docket No.50-002 License No.
R-28 EA 93-069 University of Michigan
'I ATTN:
Dr. Ronald F.
Fleming, Director Michigan Memorial - Phoenix Project
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3038 Phoenix Memorial Laboratory Ann Arbor,' Michigan 48109-2100
Dear Dr. Fleming:
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITICN OF. CIVIL PENALTY.- $3,750
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(NRC INSPECTION REPORT No. 50-002/93002(DRSS))
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This refers to the special safety inspection conducted during;the'
period of March 25-26, 1993, at the Ford Nuclear Reactor.
The-inspection included a review of your operation of the' reactor'at-a power level which exceeded the licensed maximum' power level.
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during a startup on March 24, 1993.
You reported this event to
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the NRC by telephone on March 24, 1993, and subsequently.
submitted a written report dated April 6, 1993.
The report f
documenting the inspection was sent to you by_ letter dated April
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-13, 1993.
- During this inspection violations of NRC. requirements-were identified.
An open enforcement conference;was. held on April.26,.
1993, to discuss the proposed violations, their_causes, and-your corrective actions.
The report summarizing.theLeonference.was.
l sent toLyou by letter dated May. 10,:1993.
At the enforcement conference, you took two exceptions to the sequence of events.
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described in the inspection report.
Those exceptions areinoted.
in the enforcement-conference report which also: contains; a revision to page 4 of the inspection report.-
j On March 24, 1993, the shift crew (two senior reactor operators)
was conducting a routine reactor startup.
At an indicated 1 f
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megawatt power level (50% of full power), the shift crew
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conducted a calorimetric determination of power which-found that the1 reactor was actually at 1.15 megawatts.
- At that point, the' shift. crew should have adjusted the linear power level setpoint used for automatic power control to 86%.
which, while in the automatic rod control mode, would have CERTIFIED MAIL l
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RECRJPT REQUESTED g)
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9306090071 930521 PDR ADOCK 050000G2-
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MAY 21 lpg University of Michigan-2
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reduced actual power to 1 megawatt.
However, the shift crew continued to raise reactor power to 2 megawatts (100% indicated power).
That resulted in actual power being 2.3 megawatts, 15%
above the licensed limit.
Approximately 10 minutes later, the Assistant Reactor Manager for Operations arrived in the control room, reviewed the calorimetric data, and immediately ordered the crew to return the reactor to 1 megawatt indicated power.
One violation is described in Section I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) for operation of the reactor at 2.3 megawatts for 10 minutes, a level in excess of the 2 megawatt licensed limit.
There were several root causes for the event.
There was a lack of management oversight of operations and poor communication between the shift supervisor and console operator.
Additionally, operator knowledge regarding the power level instrumentation was deficient, the operators failed to review or use the startup procedure, and had it been used, the procedural step covering the evolution was unclear.
The NRC recognizes that, in this case, the safety limit of 4.68 megawatts was not challenged.
Nevertheless, the' violation represents a significant failure to comply with a fundamental safety parameter specified in your license.
Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, this violation has been categorized at Severity i
Level III.
The NRC acknowledges your corrective actions which included, but were not limited to, permanently removing the shift supervisor from licensed activities; requiring that, when neutron channel adjust;nents are necessary to match thermal power, those adjustn'ents be made at one megawatt prior to proceeding to two megawattc; revising Operating Procedure OP-101, " Reactor Startup," to provide a smooth transition to OP-106, " Power Level Determination," and back to OP-101; conducting an unannounced oral and written examination of the reactor operations staff; and issuing a memorandum to emphasize adequate review of procedures prior to their use.
To emphasize the need for your strict compliance with your license, I have been authorized after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research to' issue the enclosed Notice in the amount of $3,750 for the violation described in the Notice.
The base value of a civil penalty for a severity Level III violation is $2,500.
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EN NU University of Michigan-3
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The civil penalty adjustment factors in the Enforcement Policy were considered.
The base civil penalty was not mitigate'l for identification in that the violation was identified as a result of a self-disclosing event and you did not demonstrate sufficient initiative in identifying its root causes.
The proposed civil penalty was mitigated by an amount. equal to 50 percent of the base civil penalty in recognition of the corrective actions discussed above.
The proposed civil penalty was escalated by an amount equal to 100 percent of the base civil penalty for your. poor past performance.
Of particular note is the. civil penalty of $1,250 that was proposed on August 21, 1992 (EA 92-123).
That civil penalty was issued for the failure to maintain the reactor suberitical during fuel loading changes, and the failure to ensure that all shim rods were fully inserted prior to the.
removal or insertion of fuel.
Some of the root causes of the violations in that case were similar to those, discussed earlier, which led to this event.
The fuel movement event involved poor communications between fuel handlers and the control room operator, the failure to review procedures prior to the fuel move, and the failure to use the procedures during the fuel move.
The other adjustment factors in the Policy were considered and no'
further adjustment to the base civil penalty is considered appropriate.
Therefore, based on the above, the base civil penalty has been increased by 50 percent.
Section II of the Notice describes two violations, ;' lated to
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exceeding the licensed power level, that were not assessed a civil penalty.
The first of these violations involved the failure of the Control Console operator to review'the reactor.
startup procedure prior to the startup.
The second involved-the
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failure to set the corrected linear level setpoint after completion of the calorimetric determination in accordance with the startup procedure.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to take.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,"
a copy of this letter, its enclosure, and your responses will be placed in the NRC Public Document Room.
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NAY 21 1993 University of Michigan-4
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The responses directed by this letter and the' enclosed Notice are not subject to the clearance procedures of,the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Public Law No.96-511.
Sincerely, h
W A.
Bert Davis Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/ enclosure:
PDR DCD/DCB (RIDS)
OC/LFDCB
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Dr. William Vernetson, Director of Nuclear Facilities Michigan Public Service Commission l
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University of Michigan WhY21 IW
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p_ISTRIBUTION SECY CA JSniezek, DEDR llThompson, DEDS JLieberman, OE JLuchman, OE LChandler, OGC JGoldberg, OGC TMurley, NRR JPartlow, NRR TMichaels, NRR Enforcement Coordinators RI, RII, RIV, RV FIngram, GPA/PA DWilliams, OIG Bilayes, OI EJordan, AEOD JLuchman, OE Day File EA File (2)
(DCS N State of Michigan RAO:RIII SLO:RIII PAO:RIII IMS:RIII i
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