ML20043A835

Responds to NRC 900503 Ltr Re Violations Noted in Insp of License R-74.Event Cited Not Violation.If Wording in Emergency Plan Considered Inappropriate NRC Should Have Pointed Out During Plan Review Under NUREG-0949

ML20043A835
Person / Time
Site:	University of Wisconsin
Issue date:	05/14/1990
From:	Cashwell R WISCONSIN STATE UNIV.
To:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
RTR-NUREG-0949, RTR-NUREG-949 NUDOCS 9005230177
Download: ML20043A835 (3)

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University of Wisconsin

' NUCLEAR REACTOR LABORATORY ' ADDRESS-

. DEPARTMENT OF NUCLEAR ENGINEERING AND ENGINEERINO PHYSICS MECHANICAL ENGINEERINO DUILDINO PHONE (608) 262 3392 1919 UNIVERSITY AVENUE -

MADISON 63706-1562 May 14,~1990 f

United States _ Nuclear Regulatory Commission RegionLIII ,

799 Roosevelt Road Glen Ellyn, IL 60137 ,

~ Attention: R. C. Knop, Chief Reactor Projects Branch 3

Dear Sirs:

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.This letter is sent in response to your inspection report and .

notice of violation dated 3 May 1990,'concerning the University.

of Wisconsin Nuclear Reactor, Docket 50-156.

We strongly disagree that event cited was a violation. It appears that we are being cited for wording in our emergency plan -

'that, if considered inappropriate by NRC, should have been pointed out at-the time the plan was under review for approval 'l under NUREG-0949,_8tandard Review Plan for the Review and-Evaluation of Emergency _ Plans for Research and Test Reactors. As author of both the Emergency Plans and Emergency Procedures at this facility I believe the response to the event was in accordance with procedural guidance.

1 In support of this opinion I offer the following:-

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1. UWNR 155, Abnormal Operating Procedure, Annunciator L Responses indicates that-the pool' level alarm may occur for high or low water levels. For low water levels it a directs " Investigate possible leaks (See UWNR 151 and 006) or add pool water'1evel lost through evaporation."

L 2. UWNR 151, Leak Resulting in Draining of Reactor Pool, begins'with a caution indicating radiation levels that could result from if water level drops to only a few a feet above the core. It then states that the reactor L

should be shut down, and that pool-connected pumps and L

the pneumatic tube blower should be shut down, and that a SRO should be notified as the first 3 immediate P" actions.

! Step 4-states that an attempt should be made to locate and seal the leak, with a reference to a step in the procedure (under follow-up actions) that indicates amount of water that can be lost (due to system design) 56 IO 0 gg h0h k 0

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. Letter to U.S.' Nuclear Regulatory Commission Page 2  ;

May.14, 1990 and corrective measures (to limit the level decrease even . further) for possible leak locations. For the Makeup and Cleanup system, this step states:

i "Close valves 704 (pump' inlet)-and 719 (extension

' handle through grid). This will isolate the demineralizer system from the pool'and repair can be done on a routine basis."

The wording of this step was intended as a deliberate exit.from the procedure.

Subsequent immediate and follow-up actions deal with

-attempting to maintain pool level.to allow unloading the core to the storage pit and placing _a shielding H cover over the pit. The final step of the procedure l deals with required notifications and reports. None of '

these subsequent steps should have been considered in this event due to the exit from the procedure.

3. Technical Specification 5,7 requires that purification, cooling, and'other' auxiliary systems be designed to preclude draining of more than'15 feet of water from.

the: pool, and that a pool level alarm shall-occur if~

pool level drops approximately 1. foot below normal ,

level. The Bases for the specifications are such that~ r

-water' losses should be prevented by system design, and corrective action should be taken if level drops more ,

than 1 foot. -(Loss of 15 feet of water would leave '

approximately 5 feet of water above the core, assuring r sufficient shielding for protection of-the public from excessive radiation levels.) t We have chosen to operate within a more restrictive envelope, limiting water loss through the make-up and '

clean-up' system to l' foot, and setting the pool level. ,

alarm / reactor scram / external alarm to allow only a 4 inch variation in pool level without a pool level alarm. It does not appear appropriate that setting an alarm to initiate corrective action'more conservatively than required by. Technical Specifications should be grounds for a Notice of Violation.

4. UWNR'006, University of Wisconsin Nuclear Reactor Emergency-Plan, for the event " Loss of reactor pool water (without fuel damage) indicates an Emergency Action Level of " pool level alarm-from low pool level due to a leak or discovery of significant leak by m__

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direct observation". The action level is so stated because it is our desire that entry into UWNR 151 be

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l Letter to U.S. Nuclear Regulatory Commission Page 3 May 14, 1990 I

made upon either of those conditions, since thio procedure deals with all magnitudes of leaks, and it will result in classification and notification under UWNR 006 if that is where the procedure leads.

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The definition of Notification of Unusual Events from '

NUREG-0849 Appendix I states the action level is actual or projected affluents at site boundary exceeding 10 MPC averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 15 mrom whole body dose in j 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, severe natural phenomenon, or bomb threat.

None of these conditions was present, so no declaration of unusual event was warranted or made, l

our position remains that no violat.on occurred and that the SRO ,

responding to the alarm acted correctly in accordance with our q procedures. l Since commission representatives seem to have agreed that l Emergency Plan wording be interpreted literally and without regard to standard emergency classification definitions, changes to the Emergency Plan have been submitted to and approved by the ,

Reactor Safety Committee that:

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a. Change the description of the event in question to

" Substantial loss of reactor pool water (without fuel damage)".

b. Change the Emergency action level by adding "and pool level is or is likely to become greater than 15 feet below the poul curb".

c. Change other events in the emergency plan that indicate

" pool water is lost" or " pool empty" to state " pool near empty".

d. Change action 3evel.for these other events to indicate

" pool water greater than 15 feet below pool curb"  :

instead of " pool empty". l Sincerely, .

// O R. J. Cashwell Reactor Director 1

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