IR 05000160/1987001
| ML20209F629 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 04/09/1987 |
| From: | Jape F, Long A, Menning J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20209F551 | List: |
| References | |
| 50-160-87-01, 50-160-87-1, NUDOCS 8704300335 | |
| Preceding documents: |
|
| Download: ML20209F629 (30) | |
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SK880, UNITED STATES
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NUCLEAR RECULATORY COMMISSION
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Report No.: 50-160/87-01 Licensee: Georgia Institute of Technology 225 North Avenue Atlanta, GA 30332 Docket No.: 50-160 License No.: C-97 Facility Name: Georgia Institute of Technology Inspection Conducted: February 9-23, 1987 Inspectors: C. 8. b m . Y'7-F)
A. E. Long J Date Signed h tf.Meng7nglw v'- 9- 2 9-Q.' Date Signed Approved by:
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.mb F. gFtpe4 Chief y- 9-f;f Date Signed
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/* Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection included the areas of organiza-tion, logs and records, review and audit functions, requalification training, procedures, surveillance, maintenance, control of experiments, licensee events, and closeout of open item Results: Six violations, three unresolved items, and three inspector followup items were identified (Paragraph 2).
DESIC HTED ORIGINAL r iak d1 8704300335 870414 PDR 0 ADOCK 05000160 PDR
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REPORT DETAILS Persons Contacted Licensee Employees
- R. A. Karam, Director, Nuclear Research Center
- L. D. McDowell, Reactor Supervisor W. H. Downs, Senior Reactor Operator R. M. Boyd, Radiological Safety Officer J. A. Mahaffey, Chairman Nuclear Safeguards Committee M. F. Mercer, Electronics Engineer D. L. Cox, Reactor Operator Trainee
- S. N. Millspaugh, Deputy Radiological Safety Officer Other licensee employees contacted included members of the health physics staff, other Nuclear Safeguards Committee members, faculty members, students, and office personne Nuclear Regulatory Commission
- D. M. Verrelli, Chief, Projects Branch 1
- A. R. Herdt, Chief Engineering Branch L. S. Mellen, Project Engineer
- S. J. Vias, Project Engineer
- B. Kuzo, Senior Radiation Specialist
- Attended exit interview on February 23, 1987 i
l Exit Interview l The inspection scope and findings were summarized in an exit interview on February 23, 1987, with those persons indicated in paragraph 1 above and in a subsequent telephone conversation on April 13, 1987. The inspector described the areas inspected and discussed in detail the inspection findings. No dissenting coments were received from the license The following new items were identified during this inspection:
VIO 160/87-01-01: Failure to Provide or Utilize Procedures (Para-I graphs 3.a, 5.d, 6.c, 7.a. 7.d)
VIO 160/87-01-02: Failure to Control Experiments per Technical Specifications (Paragraphs 5.d, 9)
VIO 160/87-01-03: Failure to Perform Weekly Heat Balance Surveil-lance (Paragraph 7.d)
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VIO 160/87-01-04: Change Made to Facility, Involving Technical Specification Change, without prior NRC Approval (Paragraphs,5.b and 10 d)
i VIO 160/87-01-05: Failure to Comply with Approved Requalification Program (Paragraph 11)
VIO 160/87-01-06: Failure to Perform NSC Review'and' Audit Functions per Technical Specification 6.3 (Paragraphs 8.a,9, 10.f. 10.g. 10.h) x UNR 160/87-01-07: Formalize and Impicment Methodology to Control
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Temporary Changes to Procedures per Technical Specification 6. (Paragraph 6.a.1)
IFI 160/87-01-08: Formalize and Implement Methodology to Track Limiting Conditions for Operation (Paragraph 6.a.2)
UNR 160/87-01-09: Verify that Shim : Blade Positions are Adequate to Ensure Negative Trip per Technical Specification 3.1.d (Paragraph 7.a) \,
t UNR 160/87-01-10: Verify that Instrunent Calibrations Necessary for Operability of Safety Equipment in Te:hnical Specification Table are Performed (Paragraph 7.c) s IFI 160/87-01-11: Followup on General State of GTRR equipment
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IFI 160/87-01-12: Resolve verification of 10 CFR 74 Requirement that Spent Fuel have Self-Protecting Radiation Levels (Paragraph 12)
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters -
The inspector reviewed licensee corrective actions on the following violations: (Closed) VIO 85-02-01 Failure to Provide & Utilize Adequate Surveil-lance Procedures per Technical Specification 6. Technical Specification 6.4.b required that written procedures be ' '
provided and utilized for surveillance and testin Violation 85-02-01 included three . examples of inadequate procedures or failure to follow procedure The licensee had previo; sly committed to the following corrective actions in a letter dated Septecher 9,1985, from R. A. Karam to R. Walker:
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. ., Revise procedure-2006, " Weekly Reactor Shutdown Checklist," to verify and record D20 level alarm point . Revise procedure 7203, "ECCS - Monthly Surveillance " to include verification of actuation of the low level alar .
3 Revise procedure 7202, " Control Rod Drop Time" to allow either a universal counter or oscilloscope for measuring control rod drop tim ,
TheinspectorverifiedthattheaboveprocedureshadbeenrevtNedand (
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The following additional corrective action requirements were stated in a letter from R. Walker to R. A. Karam dated October 7, 1985: Interview all licensed operators to identify and correct any additional examples' of inadequate or inaccurate procedure . Retrain operators on the methodology for and the necessity of ,
effecting required temporary procedure changes prior to procedure utilizatio / 8 The fonnal interviews with operators committed to by the licensee to identify procedural inadequacies were not conducted, although a number of procedure revisions were subsequently made in addition to those made in response to the violation. These revisions were made in response to problems identified by operators or through audit However, during the inspection it was determined that procedural inadequacies were known to at least one operator and had not been corrected (Paragraph 7.a).
To implement retraining on the methodology and necessity of temporary procedure changes, operators were instructed to have temporary (pen and ink) changes to procedures incorporated into official revision The inspector identified a lack of provisions for effecting temporary
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i procedure changes prior to procedurequtilization. The licensee
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concurred that their policies on temporary changes should be defined and formalized (Paragraph 6.a).
- Violation 85-02-01 is being closed on the basis that the corrective
! actions which were not completed will be tracked as part of the
- follow-up of violation 87-01-01 identified during the inspection g (Paragraphs 5.d,6.c,7.a.7.d). (0 pen) VIO 85-02-02 Failure to Meet Scheduled Surveillance Require-ment per Technical Specification 4.2.A, Table 4.1.
! This violation involved failure to schedule and perform Procedure t 7141, "LI-D1 Check," in accordance with the requirements of Technical l Specification 4.2.a and Table 4.1 which jointly require semiannual
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The Licensee had modified procedure 7241 to require semiannual
- calibration of the reactor D20 level channels. This revision was l approved September 13. 1986, and was verified by the inspector to -
! adequately address the issue. The inspector also verified that
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, ' e completion of the surveillance on a semiannual frequency was up to
. date. This aspect of the corrective action was complet h . -
E In addition to the commitment to revise procedure 7241, the Licensee stated in a September 9, 1985, letter to the NRC that the GTRR staff was reviewing all license requirements towards full compliance. This review was performed during 1985. However, several licensee findings were not corrected including failures to verify certain limiting conditionsforoperation-(Paragraph 7.a).
An additional example of noncompliance was the failure to obtain a Technical Specification change prior to changing the cover gas fro ,
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helium to nitrogen (Paragraph.10.d).
Violation 85-02-02 will remain open until review of the licede '
conditions for compliance has been completed by the licensee and determined to be adat:ste by the NRC during a future inspectio (0 pen) VIO 85-02-04 Numerous Errors in Facility Drawings in Violation of Technical Specification 6.5. Technical Specification 6.5.b.6 requires the licensee to retain updated, corrected, and as-built facility drawings for the life ,
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This violation involved errors in system flow
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of the facilit diagrams, including components appearing on drawings but not actually
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3 installed in the facility, and piping system interconnections not 1 fonsistent with the drawing In the September 9,1985, response to this violation, the licensee connitted to comparing the drawings to the as-built facility, and correcting any discrepancie:. Additionally, the licensee committed to developing procedures for documenting authorized modifications to the facilit Development of procedures for documenting authorized modifications to the facility was satisfactorily completed by the license Procedure 4200, " Changes in Facility Design," was approved by the
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Nuclear Safeguards Committee on April 9,1986. This procedure 1 specifically requires all changes to the facility to be documentede p including the updating of drawings as appropriate.
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The licensee stated that the GTRR flow diagrams had been updated and verified through walkdowns, but that the electrical drawings had not yet been reviewe Violation 85-02-04 will remain open until the accuracy of all categories of facility drawings can be reviewed in more detail during t a future NRC inspectio (Closed) VIO 85-02-05 Reactor Operator Received Less than 80% on 1984 Requalification Examination and Licensee failed to initiate retraining per the August 5, 1974, approved progra This violation involved not ' satisfying the requirement of the 1984 NRC approved requalification program that an operator be retrained in any areas of the requalification examination in which he failed to
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Inspection Report 85-02 stated that as soon as the problem was
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identified by the inspector, the licensee initiated corrective action. The operator successfully passed all areas of the requali-
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fication examination in August 1985 and again in September 198 Licensee corrective actions in the areas of annual requalification examinations and ongoing operator training were determined to be adequately implemente The licensee stated in the September 9,1985 letter to R. Walker that retraining had been ' initiated on a permanent basis, beginning in July 198 Retraining in radiation protection commenced September 9, 1985, and continued for four week The inspector verified that ongoing weekly training sessions were being conducted (Para-graph 11.d).
As additional corrective action for VIO 85-02-05, the NRC letter of October _7,1985, from R. Walker to R. A. Karam instructed the licensee to continue to follow the approved Requalification Program per 10 CFR 50.54.1-1, in conjunction with the enhanced retraining addressed in the licensee's September 9,1985, lette The licensee did not satisfy this aspect of corrective action for VIO 85-02-05, in that reactivity manipulations and performance evaluations were not being documented as required by the requalifi-cation program and by 10 CFR 55 Appendix (Paragraph 11.c).
Violation 85-02-05 is being closed on the basis that the incomplete corrective action will be tracked with follow-up of VIO 87-01-0 _ _ - _ _ _ - _ - .
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6 (Closed) VIO 85-02-06 Failure to Hold Quarterly Meetings of the Nuclear Safeguards Committee as required by T. S. 6. The inspector reviewed meeting records and verified that the committee had met at the required frequency during the period June 1985 and February 1987 (see Paragraph 10.a). The licensee had supplemented the normal reminders to perform T. S. requirements on time with the inclusion in the NSC minutes of the date before which the Committee must next meet to stay in complianc (Closed) DEV 85-02-07 Failure to Train Operator Candidates to operate the reactor in a competent and safe manner as certified on the NRC Form 39 In response to this deviation, the licensee made the commitment to develop a formal training program for reactor operator license applicants. This program was to include (1) Training in the areas outlined in 10 CFR 55 and (2) Administering a written and oral examination to each applicant before certifying to the NRC that he or she was ready to take the NRC's examination. Implementation was expected to take about a yea At the time of the inspection, the facility had one operator license trainee, who had been previously licensed at the facility and was working under the direction of licensed personnel. This operator trainee had been attending weekly training sessions, but formal license candidate training per 10 CFR 55 was not being conducte Deviation 85-02-07 was closed on the basis that the licensee will have conducted the required training for any operator license candidates before certifying their readiness for the NRC examinatio Records documenting training were to be maintaine . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviation Three unresolved items identified during this inspection are itemized in Paragraph 2, accompanied by the paragraph numbers in which they are
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addresse . Organization, Logs and Records (39745)
The objectives of this portion of the inspection were to (1) Ascertain whether the licensee's organization was as delineated in the Technical Specifications and (2) Ascertain whether the licensee's records and logs were maintained according to regulatory requirement _ ..
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7 Organization The facility organization for management and operation of the reactor was compared to the requirements of Technical Specification 6.1. No problems were identifie Operations console logs from March 1986 through February 1987 were reviewed to verify that minimum crew composition requirements of Technical Specification 6.1.d were satisfie The inspector discussed responsibilities with operators, and confirmed their understanding of Technical Specification 6.1.e, which requires a licensed operator to be present at the controls unless the reactor is shutdow The inspector was informed of plans to reorganize the facility staf The licensee stated that they will be requesting a change to the Administrative Section of Technical Specification GTRR Annual Reports The annual reports for the GTRR covering 1985 and 1986 operations were reviewed and found to meet the requirements of Technical Specifications with one exceptio Technical Specification 6.7.a(1) requires that annual reports include changes to the facility. The annual report covering 1986 did not report the change of the cover gas from helium to nitrogen as a change to the facilit This was identified as a portion of VIO 87-01-04 (Paragraph 10.d). Retention of Records Technical Specifications 6.5.a and 6.5.b require that certain records be retained for five years and other records be maintained for the life of the facilit During the course of the inspection, the licensee demonstrated that records in each category were on file and were readily retrievabl Console Logs The inspector reviewed console logs #29, #30, and #31, which covered the period October 1985 to February 198 The inspector verified that logbook entries for shutdown were being entered and initialed, and the following Inspector Followup Item was closed:
(Closed) IFI 85-02-03: Console Log Not Initialed for Significant Log Entries when Reactor is Shutdown per Licensee Commitment in IE Report 50-160/84-0 _ _ - . ,_ . . ,_ . _. --
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The following violations were identified during review of the console logs:
(1) Missing Initial Condition Stamps - Procedure. 2000, " Reactor Operation" stated, " Log the following IC data: Each shim blade position, reg rod position, flux am settings, and picoammeter readings."pThis readings and gain was normally pot done by filling in an initial condition stam The inspection identified numerous examples where this ' stamp was missing from the log, including operations on May 19, 1986, May 21, 1986, and May 23, 1986. The licensee concurred that according to Procedure 2000, these initial condi.tions should have been logge (2) _ Missing Equilibrium Condition Stamps - Procedure 2000 further stated, "After thermal equilibrium is established,- log equilibrium operating date." The licensee stated that this requirement referred to a logbook stamp, and that the reactor must generally operate for one half hour to reach equilibrium conditions. The inspector observed that the stamp was rarely used during 1986, except when heat balances were performed, even when the reactor operated for periods of longer than an hou This item had been previously b.ought to the attention of the licensee as UNR 82-01-01, and the licensee's response included a commitment to use the stamp. The licensee concurred that the stamp should have been used regularl (3) A number of additional missing entries were identified in the logbooks reviewe Some examples were:
(a) Failure to log removal of an experiment from experiment facility V-24 on March 21, 198 (b) Failure to completely fill in the critical condition stamp on April 28, 198 (c) Missing Rabbit Experiment number on June 18, 198 (d) No check to indicate who filled out the log, page 71 of Log
- 2 (e) Initial condition stamp not completely filled out, page 133 of Log #2 The findings listed above were collectively identified as example 1 of the following violation:
(0 pen) VIO 87-01-01: Failure to Provide or Utilize Procedures
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The inspector also noted logbook entries which stated that engineer-ing class lab experiments were performed, but failed to provide any-information as to the nature of these experiments (Paragraph 9).
On pages 125,131,139, and 147 of Log #29, no dose rates were -
recorded for the rabbit runs. This was identified as example 1 of the following violation:
(0 pen) VIO 87-01-02: Failure to Control Experiments per Technical Specification . Procedures (42745)
The objectives of the review of GTRR procedures were to ascertain (1)
whether an effective procedure control system had been implemented and (2) whether the content and scope of the facility procedures were adequate to control safety-related operation Administrative Controls Temporary Changes to Procedures The inspector observed that provisions for making temporary changes to GTRR procedures have not been formally defined and documente Technical Specification 6.4.a requires all procedures and major changes thereto be reviewed and approved by the Nuclear Safeguards Committee prior to being implemente Changes which did not alter the original intent of a procedure may be approved by the Reactor Supervisor. Such changes shall be recorded and submitted periodically to the Nuclear Safeguards Committee for
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routine revie No GTRR procedure implements this Technical Specification requirement or provides details on how the requirement is to be satisfied.
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Consequently, current and previous violations for inadequate procedures and failures to follow procedures have resulted at
, least in part from the lack of a defined methodology for making, j approving, and documenting temporary changes. In addition, the corrective action commitment for VIO 85-02-01 to retrain
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operators on the methodology for and the necessity of effecting required temporary procedure changes was not completed (Para-
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graph 3.a).
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The licensee told the inspector that the policy on temporary changes was that all pen and ink changes were to be incorporated into permanent revisions. Further questioning revealed that there was no defined policy for temporary changes which were not intended to become permanent. The inspector determined that temporary changes to startup checklists were usually documented as handwritten notes on the procedure and as comments under
" Abnormal Conditions." The Reactor Supervisor approved these
" temporary changes" by signing the startup approval. Other situations which possibly amounted to temporary procedure changes were noted in the console logs. The licensee could not
identify provisions for documenting deviations from steps or requirements in procedures which were not completed in checklist format and filed. When asked what they would do if they were performing such a procedure and came upon a step which was
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impossible to perform at that time due to unusual circumstances, several licensee personnel told the inspector that they would
" caucus and do something equivalent."
The inspector determined that pen and ink changes to the daily and weekly startup checklist had been made for a year and a half, and in several instances were not made as necessary (Paragraph 7.d)..~
The licensee agreed to formalize and implement a methodology for making and documenting temporary changes to procedures. this methodology is to include measures to document changes made to procedures which will not be made permanently. Temporary changes authorized by the Reactor Supervisor per Technical Specification 6.4.a should be Reviewed by the Safeguards Committee. Committee approval of significant temporary changes prior to implementing the change should also be documente The thrust in developing the methodology for temporary changes should be prevention of inadequate procedures or failure to ,
follow procedure ; The importance of formalizing the requirement for verbatim compliance with procedures was also discussed with the GTRR staff.
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Followup in this area will be identified and tracked as:
(OPEN) UNR 87-01-07: Formalize and Implement Methodology to Control Temporary Changes to Procedures per Technical Speci-fication 6. . _ _ - - _
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11 Limiting Conditions for Operation The inspector observed that there was no procedure for documenting when the GTRR was operating in an LCO conditio Most of the Technical Specification LC0 time clocks were eight hours. The licensee stated that if a piece of equipment went out of service during operation, and they had redundancy, they would continue to operate for the remainder of the day, up to eight hours. If the equipment was Technical Specification related, it would be repaired before starting up agai Normally, equipment failing or being taken out of service was entered in the console logbook, but the inspector was aware of at least one case where that was not don This item will be tracked as (0 pen) IFI 87-01-08: Formalize and Implement Methodology to Track Limiting Conditions for Operation b. Procedure Adequacy Selected procedures for surveillance, maintenance, and control of experiments were reviewed for technical and administrative adequacy (Paragraphs 7, 8, and 9).
c. Procedure Compliance Several reactor operations procedures were discussed with the operators to determine whether or not the provisions of the procedures were being followe Review and discussions of the following procedures revealed no problems or noncomplianc The operator interviewed demonstrated a knowledge of the provisions and intent of these procedures:
1) Procedure 2250, " Shield Coolant System Operation" 2) Procedure 2300, " Bismuth Coolant System Operation" Procedure 2250 requires that the shield coolant pump remain on for eight hours following operation above 1 MW. The inspector verified that this requirement was followed after operation at 2.3 MW on 2/3/8 Noncompliance with a third procedure discussed with the operator was identified. Procedure 2210, " Cooling Tower Special Operation" requires that water be run through the cooling tower for at least an hour each week during periods when the reactor was shut down. No records documented that this was done when the reactor was not operating between 3/31/86 and 4/14/86, and between 7/24/86 and 8/19/86. This item was identified as Example 2 of VIO 87-01-0 .
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The inspector id.entified that as of February 23, 1987, the following procedures had not been modified to address the fact that the cover gas had been changed from helium to nitrogen in mid-1986:
Procedure 2350, " Blanket Gas System Operation" 5/2/74
Procedure 2400, " Gas Recombiner System Operation, 5/2/74 It is important to maintain and utilize up-to-date procedures, and a delay of this length represented inadequate procedure This finding was identified as Example 3 of VIO 87-01-0 Control of Revisions The inspector noticed that copies of Procedure 4200 (Approved 4/9/86)
and Procedure 3100 (Approved 7/11/86) were not included in the control room set of procedures. Up-to-date versions of three additional procedures were missing from the set belonging to the reactor superviso This problem was corrected while the inspector was on sit The inspector verified that the versions actually being performed were up to dat . Surveillance Testing (61745)
The objective of the surveillance segment of the inspection was to ascertain whether the licensee's surveillance program was adequate and conducted in accordance with Technical Specification requirement Surveillance was considered to be the verification of set points and conditions required by the Technical Specification. This included values or conditions specified or assumed by the Technical Specification that had no assigned surveillance frequency yet had a definite bearing on safet The overall purpose of the surveillance inspection was therefore to verify that the intent of the Technical Specification surveillance requirements were me Review of Technical Specification Requirement Implementation The purpose of this portion of the inspection was to confirm that each safety-related item identified in the facility Technical Specifications was being verified as require In the September 9, 1985, response to Violation 85-02-02, the licensee documented a commitment to review all requirements of the GTRR license and provisions for compliance. This review was performed by Mr. William Downs, Senior Reactor Operator, in September 198 .. _ _ _ _ _ _ _ - _ _
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The. inspector reviewed in detail with Mr. Downs the information
.which he had compiled, and found the study to be comprehensive and thorough. However, not all of the findings of the 1985 study had been corrected at the time of this inspectio The Technical Specification study identified the following limiting conditions for operation which were not being verified at- the GTRR:
(1) Excess Reactivity - Technical Specification 3.1.e required as a limiting condition for operation that the excess reactivity of the core be limited to 11.9% delta K/K. The purpose of this requirement was to ensure that the reactivity worth of any two of the four available shim blades would be adequate to scram the reactor. This Technical Specification was added in 1978, but no verification of excess reactivity was included in GTRR proce-dures. The licensee confirmed that no specific calculation of excess reactivity was being performe Licensee management verified for the inspector that the excess reactivity was currently within Technical Specification limits, and agreed to incorporate verification of the excess reactivity limits into a procedur (2) 02 in helium sweep - Technical Specification 3.6.e required the D2 concentration in the helium sweep system to be less than 2%
by volum The licensee confirmed to the inspector that this requirement was not being verifie (3) Building Isolation Time - Technical Specification 3.5. required that the time from initiation of closure to isolation '
valve closure not exceed five second The licensee told the inspector that this test used to be performed, but was somehow omitted from the version of Procedure 7200 dated July 1981. Therefore the test was not being performe The licensee committed to modifying procedure 7200 to include verification of isolation valve closure tim These three items have been identified as examples 4, 5, and 6 of VIO 87-01-0 Additional Technical Specification limiting conditions for operation which were not addressed in procedures were also identified:
(1) Secondary System Radioisotopes - Technical Specification 3. required the concentration of radioactive materials in the secondary coolant system to be less than the values listed in 10 CFR 20, Appendix B, Table II, Column ..
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The licensee was only measuring secondary tritium, and explained to the inspector that they assumed the tritium measurement was the most sensitive indicator of a primary to secondary leak and therefore sufficient. The inspector questioned the adequacy of using tritium to meet the requirements of Technical Specifica-tion 3. The adequacy of the licensee's leakage detection methodology will be reviewed by Region II in conjunction with IFI 87-02-02, which addressed the adequacy of measurement methodology for waste stream samplin (2) Shim blade minimum position - Technical Specification 3. stated " Prior to criticality each shim-safety blade which is withdrawn above full insertion shall be positioned so that a free fall of the blade towards its full inserted position will result in a reactor scram activated by a negative period scram."
The licensee could not identify for the inspector any procedure where this Technical Specification requirement was addresse The shim blades were normally positioned above 10 degrees. The licensee could not identify for the inspector where it had been established and documented that this position was sufficient to ensure a negative period scra Item 2 was identified as an unresolved item which will be closed when the licensee verifies and adec;uately documents that the shim blade worth at 10 degrees is suffic"ent to ensure a negative tri This iter. will be tracked as:
(0 pen) UNR 87-01-09: Verify shim blade position ensures negative trip per Technical Specification 6. b. Review of Surveillance Procedure Adequacy Technical Specification 6.4.b.7 requires that surveillance and testing of safety related systems be conducted in accordance with procedures which had been appropriately reviewed and approve This specification implied adequate procedures. The purpose of this portion of the inspection was to determine whether or not the GTRR surveillance procedures were adequate to accomplish the intended purpos The following GTRR procedures were reciewed for technical adequacy and no problems were identified:
(1) Procedure 7203, September 13, 1985, "ECCS-Monthly Surveillance" (2) Procedure 7222, July 17, 2982, "ECCS Semiannual and Annual Surveillance"
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(3) Procedure 7202, December 10, 1985, " Control Rod Drop Time" (4) Procedure 7220. July 17, 1981, " Building Isolation Test" The reviews of Procedures 7203, 7222, and 7220 included walk-throughs.
The portions of the following procedures concerning the testing of period trips were reviewed for technical adequacy and walked through:
- (1) Procedure 2002, December 10,1985, " Weekly Precritical Startup Checklist" ,
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(2) Procedure 2003, December 10,1985, " Daily Precritical Startup
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Checklist" Technical Specification 3.2.a and Table 3.1 require operable positive and negative period trip channels with setpoints equal to or more conservative than ten seconds. Technical Specification 4. ,
and Table 4.1 required these period trips to be tested prior to startup and calibrated semiannually.
, Period trips were being tested in the daily and weekly startup checklists by injecting a signal and. observing that a trip occurred.
No problems were identified with the adequacy of the positive period trip test, but the scale of the control board negative period meter
, only went down to thirty seconds. Thus, existing instrumentation was inadequate to show that the trip actually occurred at a period equal
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to or more conservative than the Technical Specification limi Many of the items on the daily and weekly checklists were only check 3 marked to indicate acceptable results without the actual setpoint being listed. The operators stated that they know the setpoints and
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make mental notes that the trips occur at the correct points, or that
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other parameters being verified are acceptable. The inspectors discussed with the licensee the possibility of identifying the
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expected values of additional parameters on the checklists to aid in
! identifying either instrument drift between calibrations or other degradation ' Instrument Calibrations i Technical Specification Table 4.2 specifically requires certain
! safety-related instrumentation to be calibrated at specified '
l frequencies. Calibration of various other instruments is included in the Technical Specification Table 4.1 requirements for calibrations
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The inspector reviewed documentation of completed instrument calibrations and verified that the - period trips, picoammeter channels, and D20 temperature channels had been calibrated semi--
annually during 1985 and 1986 as required by the Technical Specifica-tion Technical Specification 4.4.b requires the resistivity of the primary coolant to be measured weekl The involved sensor CRAD 1, was not being calibrated. In this case calibration would have been very difficult to accomplis Discussions. with the licensee indicated that calibrations of certain-senors or other instruments, which are part of the safety systems in Table 4.1, had been performed at one time but were possibly no longer being performe The licensee agreed to review the adequacy of calibrations of instruments not specifically addressed in the Technical Specification Table 4.2 yet required for the functioning of the safety systems in Table 4.1. This area will be reviewed in more detail in a future inspection and will be tracked as:
(0 pen) UNR 87-01-10 Verify Instrument Calibrations Necessary for Operability of Safety Equipment are Performe Audit of Surveillance Test Results Records of selected surveillance testing for 1986 were reviewed to verify that the tests were conducted within the required frequency-and that the results of the tests were acceptabl Records reviews for the following procedures identified no problem The test were performed at the required frequencies and the results were acceptable:
(1) Procedure 4000, " Containment Building Pressure Test" (2) Procedure 7203, "ECCS Monthly Surveillance" (3) Procedure 7220, " Control Building Isolation System Test" (4) Procedure 7223, "ECCS Tank Level Calibration Check" (5) Procedure 7226, " Annual Scram Signal Delay Time" (6) Procedure 7241, " Instrument and Reactor fank Level Maintenance and Surveillance and Calibration Check" The inspection findings were as follows:
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(1) Procedure 2002, " Weekly Precritical Startup Checklist", and
- Procedure 2003, " Daily Precritical Startup Checklist" l The inspector noted several omissions on Procedure 2002 in
, recording equipment which was out-of-commission, and equipment
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substitution Except for a few occasions, the Universal
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Counter was out of commission from May 1985 through the time of the inspection, February 1987 (a period of over a year and a half). This was usually properly noted under " abnormal conditions," and steps involving the Universal Counter were marked with an asterisk or "00C." Frequently, a "5216A" was substituted for the Universal Counter and used to take discriminator data. This was usually properly noted. However, instances occurred when the operators failed to write in as an abnormal condition that the Universal Counter was out of commission, cr recorded discriminator data without noting that the 5216A had been substituted. Examples of these errors occurred on March 3, 1986, February 24, 1986, and June 10, 198 The inspector had similar findings in the review of Procedure 2003. The licensee stated that a permanent change to these procedures was not made because they eventually planned to restore the Universal Counter to operatio Because the temporary changes had occurred for over a year and a half, and because omissions were made in the handwritten entries, this was deemed an inadequate procedure. This was identified as example 7 of VIO 87-01-0 (2) Procedure 2015, " Reactor Power Calibration Data Sheet,"
Technical Specification 4.2.b requires weekly calibration of reactor power to a heat balance when the reactor was operated at a power level at or above one megawat The inspector observed that the reactor was operated briefly at 1 MW on February 4,1986, and for approximately nine hours at 1 MW on February 7,1986, without the weekly heat balance being performe The console log and completed power calibration data sheets showed that heat balances had been performed January 22, 1986, and February 11, 1986. The licensee concurred that a required heat balance had been omitte Failure to perform the weekly heat balance surveillance as required by Technical Specifications was identified as:
(0 pen) VIO 87-01-03: Failure to Perform Weekly Heat Balance Surveillance Maintenance (39745, 40745, 61745)
The purpose of this portion of the inspection was to verify adequate performance, control, and documentation of maintenance activitie , <
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18 Administrative Controls Technical Specification 6.4.b.5 requires that preventive or correc-tive maintenance which could affect safety be conducted by written procedure Technical Specification 6.4.a required all procedures and major changes thereto to be reviewed and approved by the Nuclear Safeguards Committee prior to being effectiv The following procedures were reviewed to determine if the licensee had established adequate procedural measures to control and document maintenance and facility modification activities:
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Procedure 4900, February 4,1985, " System Worksheet"
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Procedure 4901, January 25, 1977, " Preventive / Corrective Maintenance on Safety Related Equipment"
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Procedure 4200, April 9, 1986, " Changes in Facility Design" Procedure 4900 tracked completion of surveillance and maintenance activities, Procedure 4901 provided specifications for preparing written " Job Plans" and Procedure 4200 documented changes in Facility Design and provided guidance with respect to 10 CFR 50.59 evalua-tion Although procedure 4901 contains administrative requirements for preparing job plans, there was no record that the written job plans were being rev'ewed or audited by the Safeguards Committee to satisfy the requirements of Technical Specifications 6.4.a and 6.4.b.5. This item will be tracked as as example 1 of:
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(0 pen) VIO 87-01-06: Failure to Perform Adequate NSC Reviews and Audits per Technical Specification requirements.
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The Inspector also noted that the licensee seldom identified the specific job plan used for a maintenance activity on the corre-
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sponding system worksheet. This made records difficult to trac To provide more traceable records, the licensee should identify associatedjobplansonsystemworksheet The inspector discussed administrative controls on instrument setpoints with the licensee. Calibrations were performed per vendor manuals as allowed by Technical Specifications. The actual setpoints were frequently not recorded on the system worksheets, which merely stated that the setpoint was "0K." Most of the setpoints ap] eared in the Technical Specification but those such as the period trip, which differed from the Technical Specification setpoints, were not tabulated in a procedur _ _ _ _ _ _ _ __ _
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19 Maintenance Review Naintenance records on the following items identified in the control room log were reviewed for compliance with procedural and Technical Specification requirements. No problems were identifie (1) Recorder Maintenance, 86-1006-352, October 24, 1986 (2) Repair of Flux Amp, 86-1007-359, October 7, 1986 (3) Repair of Reactor Tank Low Level Channel #2, 86-0212-086, February 14, 1986 (4) Repair of Gas and Water Recorder, 86-0217-083, February 17, 1986 (5) Kanne Detector Maintenance, 86-0225-141, February 26, 1986 (6) Kanne Detector Maintenance, 86-0507-186, May 8, 1986 (7) D20 Flow Recorder Maintenance, 86-0610-295, June 10, 1986 The following selected job plans were reviewed to verify that the were prepared in accordance with Procedure 4901, " Preventive / y Corrective Maintenance on Safety-Related Equipment." No problems were identifie (1) " Cooling Tower Mechanical Preventive Maintenance" (2) " Job Plan for Overhauling Drain Valve Air Actuators" i
(3) " Job Plan for Regulating Road Maintenance"
- (4) " Replacement of Vent System Low Flow Stack Switch"
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(5) " Job Plan for Emergency Airlock" (6) " Removal of Valve Operator on Outlet Reactor Isolation Valve" l
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(7) " Job Plan for Truck Door Gasket"
! (8) " Job Plan for Cleaning Bismuth Secondary Flowmeter" l
! The following System Worksheets were reviewed to determine if the l analyses of facility design changes were 3erformed as required by l Procedure 4200, April 9,1986, ' Changes < n Facility Design." No problems were identified.
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(1) 85-0831-392, Reactor Isolation Valves (2) 85-0601-308, Thermal Column Air (3) 86-0106-061, Containment Exhaust Stack Fan (4) 86-0623-299, Picoammeter #2 (5) 86-0214-087, Picoammeter #2 (6) 86-0911-357, Magnetic Actuator Amplifier (7) 86-1007-359, Flux Amplifier #1 (8) 85-0416-142, Airlock Doors (9) 85-1105-389, Airlock Doors (10) 85-0327-101, Air Dryers Experiments (69745)
The insaection objective with respect to reactor experiments was to ascerta" n whether experiments were conducted safely and in accordance with regulatory requirement The term " experiments" included such activities as incore irradiations, beam port irradiations, and class exercises or demonstration The inspector reviewed the Technical Specification and procedural requirements and determined that the files for each experiment, should include: 1) An Experiment Approval Form; 2) An Experiment Schedule Form for each time the experiment was performed; and 3) An Experimentor's Checklist for each time the experiment was performed after the procedure was implemented in mid 1986. In addition, records of each experiment should have been accurately entered on the data sheet of Procedure 2012,
" Operating Log Experiment Status."
The inspector reviewed the files of the experiments performed during 1986 to verify that the Experiment Approval Forms, Schedule Forms, and Checklists had been performed as required. The following problems were identified:
(1) The GTRR form " Request for Minor Experiment Approval," requires a copy of the calculations of estimated activities of principal i isotopes to be attached. Numerous copies of this form were on file
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(2) Procedure 3102 requires that an experiment Schedule Form be completed and retained in the files each time an experiment is performe l Experiment schedule forms were frequently not completed and filed for runs in the pneumatic facility or for Nuclear Engineering class j laboratory experiment (3) No "Experimentor's Checklist" form, which is required each time an experiment is performed, was on file for experiment R6512 for the run
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These findings were identified as examples 2, 3, and 4 of VIO 87-01-0 Technical Specification 6.2.e(5) requires the NSC to audit reactor
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operational records for compliance with procedures and Technical Speci-
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fication requirements. NSC reviews and audits should have included records of " Request for Minor Experiment Approval" forms, Experiment Schedule Forms, and " Experimenter's Checklists." This finding will be
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tracked as example 2 of VIO 87-01-06.
I A Nuclear Safeguards audit of the records for the year 1985 for Procedure
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2012 identified almost fifty errors, omissions or inconsistencie The l Committee responded to these audit findings by revising Procedure 2012 to provide more guidance on completing the " General Notesd section of this procedur This revision was implemented on January 20,1987, and i
the staff was told to exercise more care in completing the records.
- Insufficient time had elapsed between the implementation of the revision j and the inspection to assess the effectiveness of the NSC actions.
- Nuclear Engineering class laboratory experiments were frequently being
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performed at the GTRR, and the Inspector requested access to the
! experiment records for these labs. Some but not all of the Experiment
. Approval Forms for the labs were produced by the licensee. The forms produced indicated that the lab experiments included such reactivity
manipulations as rod worth measurements and moderator coefficient testin As these types of reactivity manipulations were of sufficient safety i significance to warrant approval of the procedures by the Safeguards Committe The licensee could not produce documentation of NSC review and
- approval of the lab procedures.
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l This item was identified as example 3 of VIO 87-01-06.
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In addition, the inspector observed that console log entries for NE labs frequently did not specify the nature of the experiment which was performed. The licensee agreed to provide sufficient information in j future log entries to ensure traceability.
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10. Review and Audit Function (40745)
The Nuclear Safeguards Committee (NSC) was responsible for the review and audit of operations conducted at the GTRR to ensure that the reactor was operated in a manner consistent with public safety and within the terms of the facility licens The objectives of inspecting the audit and review functions were to verify (1) that the NSC was acting in accordance with Technical Specification Requirements and (2) that follow through on important issues raised at the review level was effectiv OSC Administrative Requirements No problems were identified in this are The minutes of the NSC meetings for the period June 1985, through February 1987, were reviewed for compliance with administrative requirement The composition of the committee, the meeting attendance and frequency, and the distribution of the meeting minutes satisfied Technical Specification requirements, Experiment Approval Function Inspection of the NSC function of experiment approval is discussed in paragraph 9 of this repor Review of Reportable Occurrences and Unusual Events No problems were identified in this are Technical Specification 6.2.3(2) requires NSC review of reportable occurrence I ' occurrences reportable by the Technical Specification definition occurred during 1985 or 1986. The inspector observed that the committee took a conservative approach in deciding when to notify the NR Facility Design Change Review Function Technical Specification 6.2.e(4) requires that the NSC review and approve proposed changes to the Technical Specifications and proposed amendments to the facility license and review proposed changes to the facility made pursuant to 10 CFR 50.59 (c).
The inspector reviewed NSC committee minutes for the period between February 1985 and February 1987. The committee discussed the following proposed changes to the facility: 1) A change in the
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ionization chamber in one of the two safety power trip channels;
~2) Silencing the siren horn outside Emergency Command Center after the center is manned; 3) Modification of the "Do Not Enter" Light actuation circuitry; 4) Redesign of neutron radiography beam H-1 for better focusing; 5) Switching the cover gas to nitrogen and; 6) Termination of inflating of freight door gaske The NSC minutes showed each of these changes to have been adequately reviewed by the committee. However, although the minutes always stated whether the modification or change was approved or disapproved, the results of the 10 CFR 50.59 review were not always clearly indicate The inspector noted that although the cover gas had been changed from helium to nitrogen during 1986, no Technical Specification amendment had been made to change the reference in Technical Specification 3.6.e to a helium cover gas. 10 CFR 50.59 only allows facility changes if a Technical Specification change is not involved. This failure to obtain prior NRC approval for a facility change involving a change to Technical Specification was identified as:
(0 pen) VIO 87-01-05: Change made to Facility, Involving Technical Specification Change, Without Prior NRC Approva e. Review and Approval of Proposed Procedures No problems were identified in this are Technical Specification 6.2.e(3) required NSC review and approval of proposed operating procedures and proposed changes to operating procedures which change the original intent of the operating -
procedure in a non-conservative manne The licensee policy was for all permanent procedure changes to be approved by the NSC, not just changes which were non-conservativ The inspector reviewed all the procedure changes approved by the NSC during 1985 and 1986 and no problems were identifie f. Audits of Adequacy of Existing Procedures NSC audits of existing operating procedures for adequacy and assurance that they achieved their intended purpose are required by Technical Specification 6.2.e(6).
A formal review of the adequacy of eight selected Reactor Operating Procedures was conducted by the NSC during 1984. The inspector noted that the procedures chosen for the review included the checklists where most of the safety surveillance checks were performed. Results
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of the procedure reviews were discussed during the February 1985 meeting, and the minutes indicated that the reviews were thoroug ' Subsequent audits of these same procedures, conducted by the NSC during 1985 and 1986, yielded additional suggestions for procedure improvement The inspector verified that all the review findings were incorporated into approved procedure revision Because the same eight procedures were reviewed in 1984 and audited in 1985 and 1986, the inspector questioned whether or not other safety related GTRR procedures had been sufficiently reviewed by the committee in recent years to verify that they were still adequat This concern is identified as example 4 of VIO 87-01-0 Audits of Operations and Operational Records Technical Specification 6.2.e(5) requires the NSC to audit reactor operations and reactor operational records for compliance with internal rules, procedures, and regulations and with licensed provisions including Technical Specifications.
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The NSC performed audits during 1985 and 1986 (of 1984 and 1985 data)
for eight selected procedures and the control room log The inspector reviewed these audits and they appeared to be thoroug Instances of errors or omissions in completing several procedures
, were identified, and suggestions for upgrading the procedures were
! mad Operations responded to each audit finding, and no items from these audits remained open. The inspector verified that the agreed
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upon procedure changes were all implemente The NSC requested that operations use added care to ensure that entries in logs and procedures were not omitted or inaccurate.
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As previously noted in Paragraph 10f as example 4 of VIO 87-01-06,
- the facility Technical Specifications imply that the NSC should also i
be systematically reviewing various other records to ensure overall compliance with requirements and regulation Audits of Equipment Performance Technical Specification 6.2.e(7) requires the NSC to audit plant equipment anomalies, reportable performance with particular attention to operating occurrences, and the steps taken to identify and correct their cause ,
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During 1985 and 1986, equipment problems were addressed by the committee on a case by case basis. No systematic audit of plant equipment performance had been undertake The question of Technical Specification required reviews of equipment function will be example 5 of VIO 87-01-0 The inspector did note that an NSC review of safety-related electronics will be performed (Paragraph 13), and will be reviewed as part of followup on this violatio The minutes of the Nuclear Safeguards Committee meeting on September 7, 1984, listed several concerns which were expressed regarding possible problems at the facility. There was no documenta-tion in the minutes that these concerns were duly addressed and resolved. Staff members told the inspector that the concerns had been addressed, but could not recall the specific During the inspection, several staff members expressed additional concerns to the inspector about the reliability of the equipment at the facilit In response to a power excursion event on February 3, 1987, caused by faulty equipment, the NSC committed to thoroughly evaluating all of the safety-related GTRR electronics. The overall state of GTRR equipment will be reviewed in a future inspection as IFI 87-01-11 (Paragraph 13).
1 Requalification Training (41745)
The licensed operator requalifiertion training at the GTRR was inspected for (1) compliance with 10 CFR and the program approved by the NRC and (2)
adequate documentation to demonstrate compliance, Annual Examinations No problems were identified in this are The approved operator requalification program requires all licensed personnel to be requalified yearly by either passing or administering a written examination.
, The reactor supervisor of the facility held a senior reactor operator (SRO) license. There was on additional SRO, who passed written requalification examinations in August 1985 and September 1986. The examinations were administered by the reactor supervisor, satisfying the procedural requirements for his examination.
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b. Retraining Program No problems were identified in this are The approved requalification program requires special retraining if an operator failed to score at least 80% on all sections of the annual examinatio The inspector's review of the grades on each section of the requalification examination verified no accelerated operator retraining was require The licensee had implemented a permanent retraining program consisting of weekly training sessions. The inspector reviewed the records of this training, and attended a portion of the session on February 9,1987. The meeting agendas covered such topics as fuel cutting procedures, fireman briefing, respiratory training, hot cell training, preparation for emergency drills, housekeeping, equipment repair, approach to criticality procedures, and radiological safet c. Reactivity Manipulations and Performance Evaluations A violation of requirements for documentation of reactivity manipulations and performance evaluations was identified during the inspectio CFR 50.54 i-1 requires that "... the licensee shall not ... make a change in an approved operator requalification program ...."
10 CFR 55 Appendix A requires that requalification include control manipulations and documented observations and evaluations of the performance of operators under real or simulated emergency condition The licensee's requalification program which implements 10 CFR 50.54 and 10 CFR 55 Appendix A, requires each licensed operator to perform at least five reactivity manipulations each year. A summary of this information is required to be kept on file to document complianc Although it was obvious from console log book entries that each licensed operator had completed more than the required number of control manipulations, a summary of manipulations was not documented
as require The approved requalification program also requires that yearly observations and evaluations of the performance of each licensed operator be documented. The written evaluation must include a discussion of the operator's performance under either real or simulated emergency condition The most recent operator performance evaluation in the licensee's flies was dated December 1983. The reactor supervisor concurred that the required formal documentation had not recently been don ..
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This item will be tracked as:
(0 pen) VIO 87-01-05 Failure to comply with approved requali-fication program The licensee was previously cited for failure to do performance and competency evaluations in Inspection Report 81-0 . Refueling (60745)
There had been no core loading changes in the GTRR since April 13, 198 All but three of the unirradiated fuel elements at the site had been returned to Oak Ridge for storage in February 198 The inspector identified that the radiation levels of spent fuel stored at the site were not being verified to be self protecting. 10 CFR 73.67 (b)(1)(i) exempted irradiated fuel assemblies from certain physical safeguards requirements when the external radiation dose rate was in excess of 100 rems per hour. Usual practice at research reactors is to recycle spent fuel back tr,to the core to maintain the required 100 r/hr levels. Both operations and health physics personnel expressed a desire to verify the self protection of the fuel, but stated that measurements ef the radiation levels of the spent fuel would cause radiation doses to personnel and the risk of contamination. The licensee felt this would contradict the ALARA concep Operations personnel did once measure the radiation level of an assembly, and found it to be over 900 R/ hou However, Health GTRR personnel expressed a lack of certainty that the radiation levels of all the spent elements exceeded the 100 R/ hour requiremen The GTRR staff requested guidance from the NRC in this are This was identified as:
(0 pen) IFI 87-01-12: Resolve verification of 10 CFR 73.67 require-ment that spent fuel have self protecting radiation level . Reactor Power Excursion (92700)
An unintended power increase from 300 KW to 2.3/MW occurred at the GTRR on February 3, 1987. The inspector and the NRC project engineer for the GTRR attended the Nuclear Safeguards Committee meeting on February 10, regarding the even Prior to the incident, the reactor had been started up for a classroom demonstration and for a neutron radiography experiment using horizontal beam port H-1. The personnel around the beam port were accompanied by Health Physics. The reactor power level was at 300 KW when power began to increase on a positive period of approximately 15 seconds (equivalent to 0.0017 delta k/k). Af ter an estimated thirty seconds of increasing
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'28 reactor power, the area radiation monitors went off and Health Physics
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neutron meters near the beam port went off scale. At this point the senior operator on duty manually inserted the shim blades, and the power increase had been turned around within an estimated 45 seconds after the start of the excursion. Power had increased to approximately 2.3 No automatic scram on high reactor power level was actuated because the reactor was being operated in Mode 2, which allows 5 W operatio Technical Specifications define Mode 1 as power levels up to 1 W , but standard practice at the facility was to operate with Mode 2 settings even at low power levels. No positive period trip was actuated because the trip setting was ten seconds as specified in the Technical Specification No Technical Specifications appeared to have been violated in this inciden The power increase was caused by a failure in the automatic rod control system. The regulating rod took its signal to the servo motor from the sliding wire in the power level chart recorde The power increase occurred when the recorder jammed in such a way as to drive and hold the regulating rod fully ou The jammed recorder showed no deviatio The chart recorder was removed and cleaned thoroughl Possible causes of the malfunction were identified as a dirty wire, loose contacts, and the wire being off the pulley and instead of on the post that holds the pulley in place. The electronics specialist was not certain whether or not the cleaning process was responsible for the guide wire being out of its normal position. After the maintenance, the chart recorder was verified to be operating normall The dose to the personnel working around the beam port did not show an'
increase on their TLD's and was estimated to be about 17 mre The Nuclear Safeguards Committee discussed the incident and ways to prevent recurrences. Concern was expressed by several members that operator attentiveness and response were not adequate. It was agreed that sound engineered safeguards must be in place to backup operator action It was brought out that although the GTRR equipment was effectively designed, most of it was about 25 years ol The following recommendations were adopted:
' For operation at or below 1 W, the Mode 1 level trip setpoint of 1.25 W would be used.
i l The positive period trip setting would be 15 seconds instead of the Technical Specification Limit of 10 seconds.
l The operating staff would devise a design change to incorporate a l buzzer into the linear picoammeter not used for automatic rod control, to provide redundancy.
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29 The Chairman of the Committee would evaluate the condition and operability of all safety related electronic equipment. Most of the reactor scram functions depend on electronic . The operators would pay close attention to the controls as a matter of cours The results of this audit and the follow-up of the results will be reviewed by the NRC. As this audit was only to address electronic equipment, the condition and performance of other safety related equipment will also be reviewed by the NRC in future inspection This NRC follow up will be tracked as:
(0 pen) IFI 87-01-11 NRC followup on general state of equipmen i I
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