IR 05000062/1993002
| ML20046B682 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 07/28/1993 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| Shared Package | |
| ML20046B683 | List: |
| References | |
| EA-93-153, NUDOCS 9308060063 | |
| Download: ML20046B682 (6) | |
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JUL 2 81993
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Docket No.
50-62
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License No.
R-66 EA 93-153
University of Virginia ATTN: Dr. R. U. Mulder, Director Reactor Facility Charlottesville, Virginia 22901
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Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$2,000 (NRC INSPECTION REPORT N0. 50-62/93-02)
This refers to the Nuclear Regulatory Commission (NRC) inspections conducted by Mr. P. T. Burnett on May 3, 1993, and Mr. C. H. Bassett on June 3 and 4, 1993, at the University of Virginia reactor facility. The inspections included a review of the facts and circumstances related to your staff's discovery that five protective scram functions required for automatic shutdown of the reactor were inoperable during full power operation for approximately five and one-half hours on April 28, 1993, as a result of modifications made
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to the reactor console circuitry. A Confirmation of Action Letter (CAL) was sent to you on April 30, 1993, documenting your actions to place the reactor in a shutdown condition and to initiate an evaluation to determine the cause of the event. The reports documenting the NRC inspections were sent to you by letters dated June 2 and June 18, 1993. As a result of these inspections, apparent violations of NRC requirements were identified. On June 29, 1993, an i
enforcement conference was conducted in the NRC Region II office with you and members of your staff that included the Reactor Administrator and the Senior Reactor Operator involved in the event to discuss the apparent violations,
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their cause, and your corrective actions to preclude recurrence.
A summary of this conference was sent to you by letter dated July 6,1993.
The event of April 28, 1993, resulted from an unintentional modification of the automatic shutdown logic circuitry by a Senior Reactor Operator who had been independently troubleshooting several spurious scrams that had occurred earl ier. While the reactor was shut down, he performed a modification that involved switching two sclid state relays within the reactor console which subsequently had no effect on the rate of spurious scrams. The Senior Reactor Operator then interchanged two mixer-driver modules and, after approximately
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30 minutes, during which time no spurious scrams occurred, the Reactor Administrator authorized a restart of the reactor.
Full power operations continued for approximately five and one-half hours with a change in Senior Reictor Operators every two hours.
No s. ram signals were received during this time. The Senior Reactor Operator at the reactor controls during the time for
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9308060063 930728 PDR ADOCK 0500
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normal daily shutdown decided to complete the shutdown by introducing a spurious period scram. To do this, the operator activated a test switch on i
the intermediate range instrument channel. The expected scram did not occur
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and an investigation was initiated to determine the cause of the problem.
The violations are described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice). Violation A in the Notice involves the failure to comply with Technical Specification (TS) 3.2 which requires that
the reactor be operated with all applicable safety system channels operable.
The interchanging of the two mixer-driver modules was made with the assumption l
that they were identical based on observation of their exteriors.
However,
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the mixer-driver modules had been modified internally with jumpers in the
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early 1970s. Consequently, when the mixer-driver modules were interchanged, five reactor scram functions, including both the power level and reactor i
period scrams, were not operable because of the internal jumper modification.
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Violation B in the Notice involves the failure to comply with TS 4.5 which requires that following maintenance or modification of a control, a safety system, or a component, operability shall be verified before it is returned to service or during its initial operation.
Neither the Senior Reactor Operator nor the Reactor Administrator recognized that the work performed during the troubleshooting activity was maintenance. Therefore, no post-maintenance testing was performed when the mixer-driver modules were switched in the scram logic drawer of the reactor console. Consequently, the system was not verified to be operable before it was returned to service.
The cause of the violations was personnel error in that your staff interchanged the mixer-driver modules and then failed to perform post-maintenance testing following that modification so as to ensure that the modification would not affect the safety system channels of the reactor.
In addition to the evident informality associated with maintenance activities, other contributing causes were the failure of the Reactor Administrator to review and question the Senior Reactor Operator's independent work associated
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with changing the mixer-driver modules and the Senior Reactor Operator's
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erroneous assumption that the two modules were identical.
These violations are of significant regulatory concern to the NRC because the reactor was operated for five and one-half hours in a condition that was unanalyzed and outside the bounds of the safety analysis, the primary basis for the operating license. Although operational parameters were not exceeded during the five and one-half hours and no safety limits were violated, the potential for a significant event nevertheless existed. Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, the violations have been categorized as a Severity Level II problem.
The NRC recognizes that actions were taken to assure a thorough understanding of the causes of the event. The NRC acknowledges that both internal and
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independent party reviews of the event were performed. Finally, the NRC notes that the reactor remained shut down until the event and its contributing causes were fully understood and appropriate corrective actions initiated.
Nevertheless, in order to emphasize the importance of ensuring that the reactor is operated within the bounds of the safety analysis and that all components of the safety system channels are maintained in an operable state for all expected design basis conditions, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulatien, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $2,000 for the Severity Level II problem. The base value of a civil penalty for a Severity Level II problem is
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$4,000.
The escalation and mitigation factors in the Enforcement Policy were considered as discussed below.
Because your staff identified and reported this self-disclosing event, 25 percent mitigation under the identification factor is warranted.
Mitigation of the base civil penalty by another 25 percent was warranted for your corrective actions that included maintaining the reactor in a shutdown condition, performing an analysis to determine the problems associated with the mixer-driver modules, management discussions with your staff to review operating expectations, initiation of appropriate actions related to the staff involved in the event, and the performance of the independent review of the event by the National Organization of Test, Research, and Training Reactors.
Hitigation by the full 50 percent that is permitted for corrective actions was not applied because in several instances the corrective action or the completeness of the corrective action was prompted by NRC involvement.
Neither escalation nor mitigation was warranted for previous licensee performance which was considered average for a non-power reactor licensee.
The factors of prior opportunity to identify multiple occurrences and duration were not applicable in this case. Therefore, based on the above, the base civil penalty has been mitigated by 50 percent.
Based on information you presented to the NRC during the enforcement i
conference and subsequent evaluation by the staff, apparent viola-tion 50-62/93-02-03, involving the apparent failure to have adequate procedures for perfurming troubleshooting and maintenance activities involving safety system coLponents, and apparent violation 50-62/93-02-04, involving the failure to follow procedures for obtaining specific approval prior to installing / removing jumpers in the control console, will not be pursued
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further. The TS violations that have been cited in the Notice clearly cover the failures to properly control activities that are of concern to the NRC.
You are required to respond to this letter and.should follow the instructions
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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 prevent recurrenc._
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JUL 2 81993 University of Virginia
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
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Should you have any questions concerning this letter, please contact us.
Sincerely,
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ORIGINAL SIGIED BY L, p,, pgygg Stewart D. Ebneter Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/ enc 1:
Commonwealth of Virginia
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DISTRIBUTION:
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PDR SECY OGC CA JTaylor, ED0 JSniezek, DEDR SEbneter, RII JLieberman, OE WTroskoski, OE JGoldberg, 0GC LChandler, 0GC FIngram, GPA/PA JPartlow, NRR Enforcement Coordinators RI, RIII, RIV, RV BHayes, 0I EJordan, AE00 DWilliams, OIG EA File Day File Document Control Desk D. Collins, RII/DRSS A. Adams, NRR PA0:RII IMS:RII RIl[
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