ML19340C008

Responds to NRC 790410 Ltr Re Violations Noted in IE Insp Rept 50-054/79-01.Corrective Actions:Clarification Made Re Interpretation of Term,At Controls.Also Discusses IE Bulletins 78-07 & 78-08 & Circular 77-14

ML19340C008
Person / Time
Site:	05000054
Issue date:	05/04/1979
From:	Voth M UNION CARBIDE CORP.
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19340C004	List: ML19340C008
References
IEB-78-07, IEB-78-08, IEB-78-7, IEB-78-8, IEC-77-14, NUDOCS 8011130099
Download: ML19340C008 (4)

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UNION CAREIDE COR?CRATION a_ U U i d

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@~D .y 'IU MEDICAL PRODUCTS DIV'SION

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? E L EP"ON E4 914 261 2131 j

l- May 4, 1979 i

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. U. S. Nuclear Regulatory Commission

! Region 1 t

! 631 Park Avenue j King of Prussia, Pa 19406 i

Attn: Mr. Boyce H. Grier, Director I

Subj: Reply to Notice of violation - Inspection 50-54/79-01.

Ref: Docket No. 50-54, License R-Bl.

Gentlemen:

1 This letter is in response to your April 10, 1979 repcrt on Inspection 50-54/79-01 and the related Notice of Violation.

Our response also discusses II Bulletins .73-07 ind 03 and Circular 77-14 and our management control systems for dealing with such matters, since these issues were also noted in the inspection. report. ,

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A. Reacter Operator Left Controls Our poliev. has genera 11v..been exc.ressed in terms of a licensed operator being recuired in attendance at the controls whenever the reactor is operating. A portion of the control room is out of direct line of sight of the controls by three or four paces. There is no need for an operator to spend a significant amount of time in the obscured area. An operator can respond to an audible alarm from that area in the same. relative length of time as if he were writing in the reactor log book. For these reasons, distinction between the centrols being attended and being in full view of the controls was not emphasized.

Nevertheless, the practice has been for operators to re-main in full view of the controls. With the lack of a e

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NRC Inspection 50-54/79-01 May 4, 1979 definitive interpretation of the words "at the controls",

and in his haste to produce a document for the NRC in-specto r, the operator on duty entered the obscured area of the control room in the case cited. After being in-formed of the NRC interpretation of "at the controls",

, a temporary memo adopting that interpretation into operating procedures was issued later that same day. Teo days later a formal notice was circulated. We believe this corrective action will prevent further occurrences.

S. SRO Not Present For Scram Recoverv n the situation referenced a valving error caused reactor pool water level to drop belcw the low pool level reacter scram setpoint. The Senior Reactor Operator on call deter-mined that his presence was not required for startup based on the September 3, 1965 exemption which reads as follows:

"~he presence of a senior cperator at the facility shall not be required during recovery. . .in instances which result frem. . . false signals, which, in the opinion of the Senior Operator, were properly verified to be f alse and to have resulted f cm. . . personnel inadvertence. . .

prwided that prior to the initiation of such a recovery, the Senior operat:r shall be notified. . .and shall deter =ine that the shutd=wn was caused by One of the enumerated occurrences, and shall determine that his presence at the facility during re::very is not required.

• Af ter the scram occurred, the Senior operater was properly notified. The cause of the scram was well understood by the Senior Operator on call as well as the Reactor Operators on shift. In the judgement of the serir operator, this event was within the intent of the exemption regarding false sig-nals due to personnel inadvertence, a term originating from our exemption request which used the words, " Accidental or inadvertent manipulations of controls or equipment in a manner that does not affect the safety of the reacter". We recognize that the letter of the law leaves room for a tech-nicality in the interpretation. However, we believe the presence or absence of the Senior Operator would have been irrelevant to the safety of the reactor. in the case cited.

If the Senior Operator had determined his presence to be required, the words e f the regulations and the exemption clearly require it. On this basis we conclude that no viciation had occurred.

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NRS Inspection 50-54/79-01 , May 4, 1979 C. NSC Review of Operations This item of non-compliance states that the Nuclear Safe-guards Committee has not reviewed facility operation fcr calendar years 1978 and 1979. The committee review function is performed by reviewing the audit report of a member of the committee who conducts the audit. A survey of recent audits reveals the following:

Audit Report Sent Review of Audit Audit Period To NSC Members Documented in NSC Minutes Sept. 76 thru Feb. 77 3/25/77 Meeting 81 (7/7/77)

Mar. 77 thru Aug. 77 9/29/77 Meeting 83 (10/5/77)

Sept. 77 thru Mar. 78 5/15/78 Not Documented Apr. 78 thru Aug. 78 9/29/78 I?ot Documented Sept. 78 thru Mar. 79 4/24/79 Next Scheduled Meeting Documentation clearly shows that audits were performed and submitted to all NSC members in a timely manner. The committee review of 1977 reports is documented. Members recall dis-cussing the 1978 reports but this fact can non be established from the meeting minutes. There has not been a meeting of the NSC since the 1979 report was distributed. At the next regular meeting the three outstanding audit reports (5/15/78, 9/29/78,

& 4/24/79) will be brought up for review an: documented. The NSC is establishing an audit committee with the responsibility for scheduling, reviewing follow-up action axi documenting l audits of facility operations as well as all other required audits. We believe this improvement will reduce the proba-bility for failure to document the NSC review of audits.

D. IE Bulletin 78-07 Respirators When the NRC inspector was on site, this bulletin could not be found, even though numerous individuals were familiar with the contents. Since the inspection, the original copy has been found with documentation indicating that it was reviewed by our Manager of Health, Safety and Environmental Affairs.

He determined that it was not applicable since our respiratory protection program does not include the use of supplied-air hoods or air-line supplied air respirators operated in the demand mode. Since the bulletin was not applicable, no re-sponse was required.

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l . WRC Insoection 50-54/79-01

• May 4, 1979 1

E. IE Bulletin 78-08 Fuel Transfer Tube This bulletin, likewise ,- could not be produced during the j, inspection but has since been located. A transfer canal at our facility connects the reactor pool and the hot cells; i shielding of the canal is equivalent to that of the reactor l pool. Responses to the bulletin were only required "where i

plant design incorporates a fuel element transfer tube". No response was considered necessary since the canal is not a ,

transfer tube and because a review of our facility showed that no parts of our farility were subject to the problem j discussed in the bulletin. l I

F. IE Circular 77-14, Seoaration of Water Systems ,

This Circular could not be located during the inspection.

While staff members recalled its contents, they could not l recall what type of facility review was done, if any. Since personnel have left and been re-assigned in the year and a half period since the circular was published, and because there was no documentation showing that a review had been completed, we have initiated a complete review of all water supply lines. Completion of the facility review and any appropriate modificarions are expected within one month.

l G. Management Control Systems l We believe the primary cause for the inspector's concern of our management control systems tnat permitted situations to

! occur was our handling of the II Bullet. ins and Circulars.

! In other respects we take exception to the suggestion that management control is inadequate. Both responsive action to NRC concerns and documentation of the responses have been addressed.

A new file has been created entitled."NRC-II Bulletins and '

Circulars " . In that file, we will include the NRC trans-mittals and the Carbide response to Bulletins and Circulars.

The file will also include documentation concerning the review and corrective action taken. The Manager of Nuclear Operations, a position created and staf fed last August, is assigned the responsibility of performing or arranging for the necessary review, corrective action and communication with the NRC on an appropriate schedule. We believe that centralizing the information and the overall responsibility will result in improvement in this area.

Verv trulv vours

. -Marcus H. Voth .

Manager Nuclear Operations

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