IR 05000111/1979002

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IE Insp Repts 50-111/79-02 & 50-297/79-02 on 790313-16. Noncompliance Noted:Failure to Develop Procedures Required to Establish 10CFR21 Program & Failure to Document & Approve Temporary Procedure Change
ML19274F006
Person / Time
Site: North Carolina State University
Issue date: 04/02/1979
From: Dance H, Julian C, Mchenry T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19274E995 List:
References
50-111-79-02, 50-111-79-2, NUDOCS 7906070095
Download: ML19274F006 (7)


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UNITED STATES e REGuq[o NUCLEAR REGULATORY COMMISSION m

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Report Nus.

50-111/79-02 and 50-297/79-02 I 'ensee:

North Carolina State University Raleigh, North Carolina F

tlity Name:

R-63 and Puistar D ket Nos.

50-111 and 50-297 Lic,ase Nos.

R-63 and R-120

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Inspectors:

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I. J. McHenry Date Signed ('

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4f ' 2,/ 7 9 C. A. Julian Date Signed

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Approved by: H. C. Dance, Section Chief, RONS Branch Date Signed SUMMARY Inspection on March 13-16, 1979 Areas Inspected This routine, unannounced inspection involved 57 inspector-hours onsite in the areas of experiments, surveillance, requalification t raining, organiza-tion, logs and records, review and audit functions, procedures, 10 CFR 21, IE Circular followup and reportable occurrence followup.

A review of the R-o3.

possess but do not operate facility was also conducted.

Results Of the 11 areas inspected, no apparent items of noncompliance or deviations were identified in 9 areas; 2 apparent items of noncompliance were found in 2 (Infraction - Failure to develop appropriate procedures required to areas establish a 10 CFR 21 program; Deficiency - Failure to document and approve temporary procedure change).

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DETAILS 1.

Persons Contacted l

Licensee Employees

  • T. S. Elleman, Head, Nuclear Engineering Department J. R. Bohannon, Nuclear Operations Administrator kT. C. Bray, Reactor Supervisor R. D. Cross, Reactor Health Physicist G. D. Miller, Reactor Engineer
  • W. G. Douglas, Chief Reactor Operator
  • S. J. Bilyj, Chief of Reactor Maintenance L. T. Caruthers, Radiation Protection Officer D. W. Morgan, Jr., Associate Radiation Protection Officer Other licensee employees contacted included operators.
  • Attended exit interview.

2.

Exit Interview The inspection scope and findings were summarized on March 16, 1979, with those persons indicated in Paragraph 1 above. The scope and findings of the inspection were discussed, including the licensee's acknowledgement of two items of noncompliance.

3.

Licensee Action on Previous Inspection Findings Not inspected.

4.

Unresolved Items Unresolved items were not identified during this inspection.

5.

Review and Audit Function Meeting minutes of the Radiation Protection Council (RPC) and the Reactor Safeguards Advisory Group (RSAG) and other records relating to their activities for the past 12 months were examined and discussions were held with staff and management personnel to verify that the review and audit functions were conducted in accordance with the requirements of Technical Specifications. Section 6.2.

In addition, the inspector verified that facility design changes were consistant with the require-ments of 10 CFR 50.59 and Technical Specification, Sect ions 6.2.2.a,

6.2. 2. d, and 6. 2. 2. j.

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-2-During the past year RPC held a total of 7 meetings. The minutes con-firmed that the RPC reviewed matters associated with the reactor operating program which required their review.

Each meeting had <yuorum partici-pation with :aembership independent of reactor operations responsibility.

Records confirmed that coditions of approvals and recommendations of the RPC were complied with by reactor operations.

The RSAG conducted 2 aieetings during the past year which included visits to the reactor facility wi.ere audits of reactor operation were performed.

The minutes of these meetings were not specific on the extent of opera-tional record review, however, the inspector was informed by management that record examination was a routine part of the audit.

The inspector determined that the RPC does not review temporary changes to the Operations Manual until such time that the entire manual is revised incorporating the outstanding temporary changes. Specifically, 20 temporary changes had been approved in the Operations Manual over since January 1975 and had not been reviewed by RPC.

Even though Technical Specification 6.3.b does not specify a time limit for RFC review of temporary changes, the inspector stated that a timely review of temporary changes is necessary to assure that temporary changes do not conflict with the Technical Specifications. This matter was discussed with licensee personnel who stated that steps would be taken to provide a more timely review of temporary changes by the RPC. The inspector stated that this item would remain open pending a review of licensee's action on this item during a subsequent inspect ion (297/ 79-02-03 ).

6.

Procedures The Operations Manual, Revision 3 through advanced change number 144, was reviewed to ascertain that the scope and content of procedures are adequate to control safety-related operations required by Technical Specification, section 6.3.a.

The Operations Manual was also reviewed to assure that procedure controls were implemented as required by the Technical Speci fications, section 6.3.a.9 and 6.3.b.

The inspector determined that the existing procedure for making temporary procedure changes contained in Special Procedure (SP) 2.1, Section did not require documentation of a review prior to approval by the Nuclear Operations Administrator (NOA).

Specifically, Technical Specification 6.3.b allows a temporary change only if a change of intent does not exist. Further, Technical Specification 6.2.2.d states that the Radiat ion Protection Council (PRC) shall review and approve proposed changes to procedures having safety significance or which may constitute an

"unreviewed safety question" pursuant to 10 CFR 50.59(c). The inspector reviewed the most recent temporary changes to the Operations Manual and discussed the temporary change process with the Reactor Supervisor. The inspector dettcmined that temporary changes were reviewed to assure that

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-3-the conditions that must be satisfied as stated above were met prior to approval by the NOA even though no formal documentation of a review existed. The inspector stated that the lack of documented. review require-men.s prior to approval did not assure that all conditiortal aspects of a

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temporary change are satisfied.

The Reactor Supervisor stated that a

review of existing practices would be conducted and appropriate documen-tation of reviews prior to approval of temporary changes would be incorporated.

The item was discussed at the exit and the inspector stated that this item would remain open pending a review of licensee's actions with regard to this matter during a subsequent inspection (297/

79-02-04).

The inspector determined during a review of SP 4.2, Pulsing Procedure, that acceptance criteria for the reactivity balance check and steps to assure action taken to disable pulse capability after the test were not provided.

This item was discussed with a licensee representative who stated that appropriate revisions to SP 4.2 would be incorporated as described above before further pulse testing. This item will remain open and will be reviewed durinc; a future inspection (297/79-02-05).

7.

Surveillance The inspector reviewed selected surveillance procedures to ascertain conformance with associated requirements of the Technical Specifications.

The following surveillance tests were reviewed:

PS-1-09-1 Scram Logic and Magnet Power PS-1-10-1 Temperature Measuring Channel PS-2-02-4 Pool Level Channel PS-2-03 Flow Measuring Channel PS-7-02-01 Auxiliary Generator PS-3-01-4 Calorimetric Power Calculation The test results for the above procedures completed in 1978 vere reviewed to insure that limiting conditions for operations were met.

In addit ion.

completed procedures were reviewed to insure that they were properly reviewed and the record retention requirement of Technical Specification, Sect ion 6.6.a.4 were met.

No problems were identified.

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10 CFR Part 21 The inspector reviewed the licensee's implementing procedures and controls to assure reporting of defects and noncompliance as reqdired by 10 CFR

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Part 21.

The inspector determined that no documented 10 CFR 21 program existed since the licensee had interpreted that the facility was not subject to the regulation in 10 CFR 21-The inspector discussed this item with the Reactor Supervisor and stated that 10 CFR 21 definitely applies to the Pulstar facility.

Specifically, 10 CFR 21.21 states in part that each facility suject to 10 CFR 21 shall adopt appropriate responsible officer is informed if the procedures to assure that a operation of a facility or basic component contains a defect or fails to comply with the AEC Act of 1954 as ameaded or any rule, regulation.

order or license relating to a substantial safety hazard.

The above item has been identified as an infraction in the Notice of Violation (297/79-02-01).

9.

Review of IE Circular (IEC)

IE Circular 77-14, Separation of Contaminated Water Systems from Non-Contaminated Plant System, was discussed with licensee personnel.

Licensee representatives stated that they were not familiar with the IEC-77-14 and that they probably had not received a copy of this IEC.

The inspector discussed the general concerns which IEC-77-14 addressed and stated that an official copy of the IEC would be provided to the licensee.

The licensee indicated that facility design does provide a

very remote possibility of cross contamination and the matter would be reviewed.

This IEC will remain open pending the completion of the licensee's review and subsequent inspection by the NRC.

10.

Tour of Facility A f amiliarization tour of the Pulstar and R-63 f acilities was conducted.

The inspectors paid particular attention to general housekeeping and radiological controls. No problems were identified.

11.

R-63 Facility Status The inspector verified that the R-63 fuel storage area ias secured, access doors to the reactor and fuel storage area were locked, building ventilation system was in operation, and radiation monitoring systems were in operation.

The inspector also reviewed the surveillance check sheets for 1978. No problems were ident i f ie,

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Logs and Records Review The inspector reviewed the Pulstar reactor console log.jfrom6/18/76

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through 3/13/79, the meeting minutes of the Radiation Protection Council and the Reactor Safeguards Advisory Group from 1/26/78 to date, and the Scram / Unscheduled Shutdown Reports for 1978 and 1979 to date During this review it was noted that since January 1979 the operator would occassionally make a console log entry of the Log N Channel Compensation Voltage.

Discussions revealed that these log entries were made in response to a written standing order called " Setting of Compensation Voltage Prior to Reactor Startup" This standing order was put in effect by the licensee with verbal approval of the Nuclear Operations Administrator (NOA).

However, this standing order constituted a tem-porary procedure change which require documentation and subsequent review by the RPC as specified by Technical Specification 6.3.b.

This failure to document and review a temporary procedure change has been identified as a deficiency in the Notice of Violation (297/79-02-02).

During the record review the inspector noted that on two occassions (8/12/78 and 1/31/79) the pulse rod drive mechanism had bound up.

Lubrication corrected the first problem but since the second event the pulse rod has been tagged out of operation in fully withdrawn position.

The licensee stated the drive raechanism will be disassembled and repaired before future use. The inspector stated that this item will remain c. pen and will be reviewed during a f uture inspection (297/79-02-06).

13.

Reactor Operator Requalification Program

The inspector review documentation of the licensee s reactor operatcr requalification program for the ca.endar year 1978 to verity conformince with regulator requirements.

No deviations or items of noncompliance were identi fied.

14.

Reactor Experiments The inspector reviewed documentation and discussed with licensee repre-sentatives the reactor experiments beiig conducted to ascertain whether experiments were conducted safely and in accordance with regulatory requirements.

During the review of selected experiments the inspector determined that Experiment P-14 (Neutron Radiography) was approved f or initial testing on March 2, 1977 by the Radiation Protection Council (RPC). Since that time a neutron radiography facility has been const ructed and nearing routine operation.

The inspector stated that the facility design and test results should be promptly reviewed and approved by the RPC. The licensee agreed to perform this review and the inspector stated this would remain open pending a review at a latei inspection (297/74-02-07 ).

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Reportable Occurrence Followup The following reportable occur rences were reviewed onsite; to verify that the licensee's review, corrective actions and reportingiof the events were adequate and in conformance with the Technical Specifications:

a.

The inspector reviewed the circumstances of the events of August 11, 1978, when the reg blade drive switch became stuck in the "up" position and found that proper corrective action was taken. These events were reported to the NRC by letter dated August 18, 1978 for information only. This item is closed.

b.

The failure of Confinement Fan No. 1 on January 15, 1979, was reviewed and the inspector found that proper corrective actions were taken.

These events (AO-79-01) were reported to the NRC by letter dated January 24, 1979. This item is closed.

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