ML20045C209
| ML20045C209 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 06/18/1993 |
| From: | Newman S MICHIGAN, UNIV. OF, ANN ARBOR, MI |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-93-069, EA-93-69, NUDOCS 9306220208 | |
| Download: ML20045C209 (6) | |
Text
WILUAM C. KELLY VKT PRL5fITNT M* RISEARCit Tur UNIVERSUY Or MlOUGAN
$NO FILMING 15UllitNG ANN AklKR MK3ilGAN 4 Fir?+1MO 1
30 764-tW6 fax 30Mam5
)
June 18,1993 Director Officeof Enforcement U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Re:
Notice of Violation University of Michigan Ford Nuclear Reactor Docket No.50-002 License No. R-28 EA 93-069
Dear Director:
Enclosed is a check in the amount of $3750.00 submitted by the Regents of the University of Michigan ir. full payment of the civil penalty proposed in the above referenced Notice of Violation dated May 21,1993.
Also enclosed is the Reply to Notice of Violation. Thank you for your cooperation in this matter.
Sincerely, heb JGdcna;W a>n Sarah W. Newman Associate Vice President for Research, signing for William C. Kelly encl.
Payment of civil penalty (Check # 15867
)
Reply to Notice of Violation cc:
A. Bert Davis Regional Admini'strator r w LL}
n,p-9306220208 930618
)
I j
%n
. 14 0 V
PDR ADOCK 05000002 o'
j hl G
PDR fu c
REPLY TO NOTICE OF VIOLATION University of Michigan Docket No.50-002 Ford Nuclear Reactor License No. R-28 EA 93-069 Violation i
Operating License No. R-28, Condition 3.C(1), " Maximum Power Level,"
states that the licensee is authorized to operate the facility at power levels not in excess of two megawatts (thermal).
Contrary to the above, on March 24, 1993, the licensee operated the facility at 2.3 megawatts (thermal) for 10 minutes, a level in excess of 2 megawatts (thermal).
1)
The University admits this violation.
Violation 11. A & B Ford Nuclear Reactor Technical Specification 6.4.1 requires, in part, that written procedures, including applicable check lists shall be followed for startup of the reactor.
A.
Operating procedure OP-101, Revision 22, " Reactor Startup," Step 5.1, requires the Control Console Operator to review OP-101, Reactor Startup, as part of the startup procedure.
Contrary to the above, the Control Console Operator did not review OP-101 during the reactor startup on March 24, 1993.
B.
Operating Procedure OP-101, Revision 22, " Reactor Startup," Step 5.36, states that after completion of the calorimeter, set the corrected Linear Level setpoint.
i i
Contrary to the above, the licensee did not set the corrected Linear Level setpoint after completion of the calorimeter during the reactor startup on March 24,1993.
l 1)
The University admits these violations. i
4 2)
Reasons for the Violations It is our evaluation that the overpower violation occurred because one U
shift supervisor did not follow the procedure for determining reactor
~
power level.
He may have become confused when the results of the calorimetric determination of reactor power required him to adjust the Linear Level setpoint to a value below the lower limit of the normal operating range for the Linear Level system at power.
This evolution has been performed by dozens of licensed operators over the 35 years of I
operation of the facility without incident.
i Prior to his appointment, the shift supervisor was counseled by both the reactor manager and the assistant reactor manager for operations that, if any situation arose in which he became confused, he should stop, shutdown the reactor if necessary, and notify management.
Because this one person failed to follow the procedure, failed to communicate with others to resolve his uncertainty regarding indicated versus actual power, and perhaps most important:
he knew actual power was 1.15 Mw, but he did not recognize that doubling that power would put the reactor at 2.3 Mw in violation of the operating license, the University of Michigan has permanently removed him from the reactor operating staff.
No generic weaknesses were found among the other members of the
{
facility's operating staff.
Written and oral examinations did not reveal any weaknesses in the areas of reactor operation and power level determination.
In addition, the other shift supervisors are very communicative and proactive regarding operating evolutions.
3)
Corrective Steos and Results Achieved i
1.
The shift supervisor who was on shift during the overpower event has been permanently removed from Licensed duties; in fact, he is no longer an employee of the facility.
2.
Reactor instrumentation that requires adjustment following a reactor calorimeter are adjusted at 1 Mw prior to proceeding to 2 M w.
This requirement is now clearly and unequivocally delineated in Operating Procedure 106.
3.
When approaching mie 2 Mw power level, the reactor now is placed in automatic control 5% below 2 Mw and power is carefully increased to 2 Mw by increasing the automatic setpoint.
L
?,
At present, this procedure is delineated in a temporary operating instruction because it will be eliminated if license amendment 39, recently submitted for review and
- approval, is approved.
Amendment 39 increases steady state operating power to 2.2 Mw.
The licensed reactor power of 2 Mw has been historically interpreted as a steady state power limit.
It has never been interpreted as an absolute power limit, in the past, minor transient deviations above 2 Mw were allowed by management to attain automatic control in the manner believed to be most safe.
t 4.
Operating Procedure-101, Reactor Startup, has been modified to enhance the transition to Operating Procedure-106, Reactor Power Level Determination, when the performance of a calorimeter is required and the return to Operating Procedure-101 to finish the startup.
It is our opinion that the transition from one procedures to the other and back has always been clear and that any confusion in the process was the function of the single shift supervisor involved in the violation.
5.
Unannounced written and oral examinations were given by the reactor manager to every shift operator.
The examinations emphasized the more intellectually difficult procedures including rod shadow, calorimetric determination of power, adjustment of indicated power to match thermal power, and shim-safety rod calibration.
There was no indication of any sort of generic weakness on the part of the operators.
6.
Management is actively communicating with all operations personnel to emphasize the necessity to adequately review procedures prior to their use and to seek management guidance to clear up any uncertainties.
Each operator is aware that he or she must be able to answer "Yes" to two questions:
"Did you review the procedure prior to performing it?" and "Do you clearly understand how to perform the procedure?".
A review can range from a mental review to a detailed walkthrough.
4)
Planned Corrective Steos to Avoid Further Violations 1.
License and Technical Specification amendment 39 has been submitted to establish the reactor steady-state operating power at 2.2 Mw, the limiting Safety System Setting at 2.6 Mw, and the licensed operating power limit at 2.9 Mw.
3-
2.
Consumers Power Company ' has been requested to assist the Ford Nuclear Reactor by reviewing overall operation and.by providing guidance with job-task-analysis of evolutions at the. facility.
A preliminary meeting was held on May 11, 1993.
An attempt will be made to involve students from the University's Business School or an Engineering College department in the review.
3.
As part of the biennial requalification program, periodic review questions will be administered relating to
.s p ecific, conceptually difficult procedures such as:
a.
Operating Procedure-103, Rod Shadow Effect and Linear Level Setpoint Adjustment.
b.
Operating Procedure-104, Reactor Experiments and Cobalt-60 Irradiations.
c.
Operating Procedure-105, Core Excess Reactivity, Shutdown Margin, and Control Rod Reactivity.
d.
Operating Procedure-106, Power Level Determination and increase to Full Power.
e.
Operating Procedure-110, Verification of Magnitude of Core Negative Reactivity Equal to or Greater than 0.10 Delta K/K.
f.
Calibration and Maintenance Procedure-201, Shim-Safety Rod Calibration.
g.
Calibration and Maintenance Procedure-202, Control Rod Calibration.
h.
Calibration and Maintenance Procedure-502, Reactor Pool Water Surveillance.
i.
Administrative Procedure-301, Reactor Fuel.
j.
Administrative Procedure-302, Critical Experiment.
k.
Management Procedure-401, Reactor Experiment Review.
l.
Management Procedure-505, Reactor In-Core Fuel Management.
4.
Management expectations, in conformance with University policy, for reactor operators with regard to such items as personal conduct, job performance, training, and management notification that are not directly applicable to procedures are being formulated.
Input from shift supervisors and shift operators is being sought.
The expectations will be initially presented to the operators on a one-on-one, face-to-face basis and periodically reiterated ' during requalification training.
5)
Date When Full Comoliance Will be Achieved Full compliance was achieved on March 24,1993.
i Ch'andler W. Matthews affirms that _ hei s fully. authorized _to submit-this 1
i Reply _ to Notice of Violation on behalf of the Regents of the University of
^
Michigan as Associate Vice President for Finance; and he further affirms that he-has read this Reply to Notice of Violation, knows its contents and to the best of his knowlege, information and belief, the. statements made in this Reply to Notice' of Violation are true.
The Regents of The University of Michigan Richard L. Kennedy
/N Vice President for Government
]
elations & Secretary of~the b y '.
~ 4,4s,-ein.
eigning rcr C' handler W.- Matthews Associate Vice President for Finance j
Subscribed and sworn to before me this /fde day of ku-kki v
//
G40tary Public b(.hAZ hl
. County KAN W. BERKLEY Michigan
.h,y &,Waya wf,m My commission expires:
i -~,w Expi.es May 3 1997 Michigan Memorial Phoenix Project -
by V
Ronald F. Fleming, Director [
Subscribed and sworn to before me ths 17 day of Qm a _
lIlcodk Notary Pubfc i
[O e/A
. County Michigan My commission expires: hly Q/9Q KATHERINE A BLACKBURN Notcry Public.Washtenow County MI 5-MyComm!ssion Expires Feb.17,1997
,