ML11207A467
| ML11207A467 | |
| Person / Time | |
|---|---|
| Site: | University of Wisconsin |
| Issue date: | 07/19/2011 |
| From: | Agasie R Univ of Wisconsin - Madison |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 47053, RSC 1096 | |
| Download: ML11207A467 (5) | |
Text
Nuclear Reactor Laboratory UWNR University of Wisconsin-Madison 1513 University Avenue, Room 1215 ME, Madison, WI 53706-1687, Tel: (608) 262-3392, FAX: (608) 262-8590 email: reactor@engr.wisc.edu, http://reactor.engr.wisc.edu July 19, 2011 RSC 1096 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Docket 50-156, License R-74 University of Wisconsin Nuclear Reactor Violation of Technical Specification 6.1.3(1 (a) 14 Day Follow Up Special Report to Event Notification Report Number 47053 in Accordance with Technical Specification 6.7.2(l)(c), 6.6.2(4) and 6.6.2(5)
Dear Sir or Madam:
The following is the 14 day follow up special report to Event Notification report number 47053 in accordance with Technical Specifications (TS) 6.7.2(1) (c) in response to violating the staffing requirements at the University of Wisconsin Nuclear Reactor as defined in TS 6.1.3(1) (a). This report also meets the requirements of TS 6.6.2(4) to the Reactor Safety Committee.
VIOLATION The definition of REACTOR SECURED, in accordance with TS 1.3, is when the following conditions exist:
- a. All control elements are fully inserted, with the exception of the regulating blade in the event of an emergency,
- b. The reactor is shut down,
- c. The console key switch is in the "OFF" position and the key is removed from the console and under the control of a licensed operator or stored in a locked storage area,
- d. No work is in progress involving core fuel, core structure, control elements, or control element drives unless the work on the drive can not move the control element, and
- e. No experiments are being moved or serviced that have, on movement, a positive reactivity worth exceeding 0.7% Ak/k.
Technical Specification 1.3 further defines REACTOR OPERATIONS as any condition wherein the reactor is not secured.
During such time when the reactor is in operations (i.e. not secured) TS 6.1.3(1) requires the following minimum staff:
- a. A licensed reactor operator in the control room (if licensed senior reactor operator, may also be the person required in c).
- b. A second designated person present at the facility or readily available by phone or radio and within 1000 feet capable of carrying out prescribed written instructions.
- c. A designated senior reactor operator shall be readily available at the facility or on call. On call means the individual can be rapidly reached by phone or radio and is within 30 minutes or 15 miles of the reactor facility.
Contrary to TS 6.1.3(1) (a), on Thursday July 14, 2011, for a period of 85 seconds a licensed reactor operator was not in the control room while the console key switch was in the "TEST" position (not in the "OFF" position) and the key remained in the key switch and not under the control of a license operator.
SEQUENCE OF EVENTS The follow sequence of events has been verified following a review of electronic records and may differ in the times and duration as originally reported in event notification 47053 which were based on the recollection of the individuals involved.
On Thursday July 14, 2011 at 10:38AM CDT two licensed reactor operators were performing the UWNR 122 "Surveillance SCRAM Checks". This procedure ensures the staffing requirements of TS 6.1.3(I) (a), (b) and (c) are satisfied. Step 8 of the UWNR 122 involves testing the pool level high and low scrams and external alarm to the University of Wisconsin Police Department (UWPD) dispatcher. Step 8.e of the UWNR 122 requires calling the UWPD to verify that two alarms were received. The operator fulfilling the staff requirement of TS 6.1.3(I) (b), hereinafter referred as the second person, placed the telephone call to the UWPD. The operator fulfilling the staff requirement of TS 6.1.3(i) (a), hereinafter referred as the on-duty operator, continued to proceed with the UWNR 122, including turning the key switch to "OFF" and securing the reactor at 10:46AM CDT.
Subsequently, the second person informed the on-duty operator that the UWPD only received one alarm, instead of the expected two. Upon consultation with the cognizant senior reactor operator (SRO) it was determined that the duration between testing the high and low pool level trips was too short to be observed by the UWPD dispatcher. The SRO instructed the two operators to perform UWNR 122 step 8 again, but ensure a duration of 2 minutes between testing the high and low levels.
At 10:48AM CDT the on-duty operator inserted the key switch key and turned the key switch to "TEST". The second person subsequently tested the pool level float as instructed by the SRO. Having successfully verified the UWPD received both alarms, both operators left the reactor control room at 10:55:42AM CDT without turning the console key switch to "OFF" and removing the key in order to secure the reactor.
At 10:57:07AM CDT the cognizant SRO entered the reactor control room and immediately secured the reactor upon realizing what had happened. The reactor control room was unmanned for a period of 85 seconds while the reactor was not secured.
During the duration of non compliance all control elements were fully inserted, the reactor was shut down, no work was in progress involving core fuel, core structure, control elements, or control element drives and no experiments were being moved or serviced. Furthermore, current to the control element drive SCRAM magnets was unavailable by nature of the key switch being in "TEST". There were no visitors to the facility at the time and a review of the facility security plan indicated the facility was in full compliance at all times.
IMMEDIATE ACTIONS Immediate actions were taken to secure the reactor when the cognizant SRO entered the reactor control room at 10:57:07AM CDT on July 14, 2011, 85 seconds after the violation occurred. The reactor was already shut down and remained shutdown in accordance with TS 6.6.2(1).
At 3:50PM CDT on July 14, 2011 the Reactor Director was notified of the event and the immediate corrective actions taken with respect to the operations involved, in accordance with TS 6.6.2(2)
The Chairman of the Reactor Safety Committee was notified of the event by the Reactor Director on July 15, 2011 at 9:30AM CDT in accordance with TS 6.6.2(3)
ANALYSIS OF THE CAUSE The facility relies upon a binary input to the building automation network to report the pool level alarm to the UWPD.
Based on the network traffic at the time the report can be delayed by up to 2 minutes, but typically less than 30 seconds.
If the binary input changes state too quickly the network will only report the last known state. As a result, it is possible for the UWPD dispatcher to only observe one of the alarms, as was the case on July 14, 2011.
Because the on-duty operator proceeded to complete the UWNR 122 prior to confirming that the UWPD had received two alarms, required performing step 8 of the UWNR 122 again, after the reactor was already secured. The on-duty operator was instructed to perform step 8 of the UWNR 122 again and therefore the operator stepped into the procedure at step 8 and exited the procedure at the completion of step 8. As a result the on-duty operator failed to complete step 11, a second time, which is to turn the console key switch to "OFF" and secure the console key.
CORRECTIVE ACTIONS Immediate corrective actions were taken to secure the reactor when the cognizant SRO entered the reactor control room at 10:57:07AM CDT on July 14, 2011, 85 seconds after the violation occurred.
Follow up corrective actions include:
The UWNR 122 has been revised to be a check-off style procedure.
In accordance with UWNR 001, "Standing Operating Instructions",
section 15.a states in part, procedures requiring initialing of individual steps, must be on hand and followed step by step while the task is being performed. Therefore the operator may not proceed until the UWPD alarm has been verified. This will prevent the need to step into and out of the procedure at irregular points thereby reducing the risk of missing procedure prerequisites and finishing steps.
All operations staff was made aware of the event and subsequently trained on the UWNR 122 revisions.
If you should have any further questions, please do not hesitate to contact me at (608) 262-3392 or Agasie@engr.wisc.edu.
Sin ely, ert A.Ro asie Reactor Di ector Cc Mike Morlang, US NRC Facility Inspector Geoffrey Wertz, US NRC Facility Project Manager James Blanchard, 1.W Engineering Physics Department Chair Reactor Safety Committee - RSC 1096