ML20022A362
| ML20022A362 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 01/22/2020 |
| From: | Mcdeavitt S Texas A&M Univ |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2020-001 | |
| Download: ML20022A362 (3) | |
Text
Texas A&M Engineering Experiment Station NUCLEAR ENGINEERING & SCIENCE CENTER January 22, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 2020-001
SUBJECT:
Reply to a Notice of Violation Inspection Report No. 50-128/2019-201 (License R-83)
This memo represents the reply from the Texas A&M Engineering Experiment Station (TEES)
Nuclear Engineering and Science Center regarding the Notice of Violation (NOV) received as part of the routine inspection report No. 50-128/2019-201. The U.S. Nuclear Regulatory Commission (NRC) conducted a routine inspection of the NESC on November 18-21, 2019.
The notice of violation documented in the report is excerpted as follows:
- 1. The TEES Nuclear Science Center (NSC), senior reactor operator (SRO) and reactor operating Requalification Program states in Section 4.2, that "[e]ach licensed operator shall take one comprehensive written examination during each 24 month requalification program," and Section 4.3 states that "[t}he examination will be designed so that a score of 70 or better out of 100 total points will be considered a satisfactory performance. Any licensee who scores less than 70 will be removed from their licensed duties and enrolled in an accelerated retraining program until they demonstrate acceptable proficiency (70 out of 100). "
Contrary to the requirements referenced above, on November 18, 2019, the NRC inspectors found that an SRO took a comprehensive written examination on December 14, 2017 (given during the 24 month requalification program) and received a score of less than 70 but was not removed from his licensed duties or placed in an accelerated retraining program until he could demonstrate acceptable proficiency (70 out of 100).
- 2. The TEES NSC technical specification Section 4. 3. 2 requires that, "During periods of operation, or radioactive material handling, the central exhaust system shall be verified operable weekly including automatic isolation on receipt of a high radiation signal. "
Contrary to the above, on several occasions during the past two years, namely during the weeks of September 2 and September 16, 2019, the C air handling unit inlet isolation damper failed to fully close during the weekly surveillance test; during the week of November 11, 2019, the A air handling unit inlet isolation damper failed to fully close during the weekly surveillance testing; and, starting the week of July 2, 2018, until the week of September 3, 2018, one of the exhaust fan isolation dampers either failed the weekly surveillance testing or was no tested due to on-going problems with the damper.
Nuclear Engineering and Science Center 1095 Nuclear Science Road, 3575 TAM U College Station, TX 77843-3575 Tel. (979) 845-7551
Therefore, due to these weekly surveillance test failures, the central exhaust system was not verified to be operable and was not functioning properly.
Response to Notice of Violation Violation 50-128/2019-201-01: Failure to restrict the duties of an operator who scored less than 70 on the biennial comprehensive examination (1) The reason for the violation, or, if contested, the bases for disputing the violation or severity level A grading error resulted in an undocumented discussion regarding what the SRO's score actually was on the comprehensive written examination. At the time of grading, there was a discussion of whether one of the questions should be removed, but this discussion and the result of the discussion were not documented.
(2) The corrective steps that have been taken and the results achieved The SRO in question is being retrained and will not perform SRO duties until requalification is completed satisfactorily.
(3) The corrective steps that will be taken The SRO in question is being retrained and will not perform SRO duties until acceptable proficiency is demonstrated. The Requalification Program defines acceptable proficiency as a score of 70 out of 100 on the comprehensive written examination.
(4) The date when full compliance will be achieved Full compliance was achieved on November 21, 2019. The duties of the SRO in question were restricted and requalification is in progress.
Violation 50-128/2019-201-02: Failure to verify the Central Exhaust System operable on a weekly basis as required by TS Section 4.3.2 (1) The reason for the violation, or, if contested, the bases for disputing the violation or severity level Two reasons for this violation were identified: (1) A misunderstanding by reactor staff of Technical Specification 4.3 "Confinement" (above), and (2) an error where the Reactor Safety Board did not audit the maintenance paperwork for the central exhaust system.
(2) The corrective steps that have been taken and the results achieved 2
When the inspectors identified the issue, reactor operations were placed in stand down mode and the reactor staff focused on diagnosing the system problems. It was determined that repairs Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551
to some of the dampers and all of the damper drive motors were needed. To date, all of the dampers needing repair and two of the four motors have been replaced. After the stand down review, the repair schedule was set and reactor staff implemented a daily test of the system to verify the system functions properly while the repairs are implemented.
The Reactor Safety Board had a regularly scheduled meeting on December 12, 2020. During this meeting we requested they add the maintenance paperwork for the central exhaust system to their maintenance audit, and they agreed to do so.
(3) The corrective steps that will be taken Two of the four motors are awaiting replacement. The daily system tests will continue while these replacements are underway. Once all replacements are complete the daily system tests will continue for two weeks to verify proper operation. Then the reactor staff will return to the regular procedure of weekly testing.
( 4) The date when full compliance will be achieved These repairs are underway and will be complete by February 29, 2020. The daily tests will continue for two weeks following their completion.
I regard these matters seriously and worthy of the attention noted above. We welcome additional input and recommendations to further improve operations at the NESC. If you have any questions or comments, please contact me at mcdeavitt@tamu.edu or 979-845-7551 or Jerry Newhouse at newhouse@tamu.edu or 979-845-7551.
Sincerely,
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Sean M. McDeavitt, Ph. D.
Director, Nuclear Engineering and Science Center Director, Nuclear Power Institute Texas A&M Engineering 3
Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551