ML20046B641
| ML20046B641 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 07/06/1993 |
| From: | Stohr J Office of Nuclear Reactor Regulation |
| To: | Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| References | |
| EA-93-153, NUDOCS 9308060002 | |
| Download: ML20046B641 (21) | |
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.a n s Docket No. 50-62 License No. R-66 EA 93-153 University of Virginia ATTN: Dr. R. U. Mulder, Director Reactor Facility Charlottesville, VA 22901 Gentlemen:
SUBJECT:
ENFORCEMENT CONFERENCE
SUMMARY
This letter refers to the Enforcement Conference held at our request on June 29, 1993. The meeting concerned activities authorized for your University of Virginia Reactor (UVAR). The issues discussed at the conference related to operating your reactor without some of the required safety system channels being operational and failure to verify that all the safety systems were operable before being returned to service following maintenance. We are continuing our review of these issues to determine the appropriate enforcement action.
A list of attendees and a copy of your visual aids are included in Enclosures 1 and 2 respectively.
During the Enforcement Conference you identified an error in NRC Inspection Report No. 50-62/93-02 in the characterization and discussion of one of the apparent violations. Wording changes to correct the error are included in.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Should you have any questions concerning this matter, please contact us.
Sincerely, ORIGINAL SIGNED BY J. PHILLIP STGHR J. Philip Stohr, Director Division of Radiation Safety and Safeguards
Enclosures:
(See page 2) l 9308060002 930706 PDR ADOCK 05000062 O
PDR ZEM
JG( Q 6 1993 University of Virginia 2
Enclosures:
1.
List of Attendees 2.
Handout 3.
Corrections to NRC Inspection Report No. 50-62/93-02 cc w/encls:
Dr. Paul Allaire, Chairman
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Department of Mechanical, Aerospace and Nuclear Engineering University of Virginia Charlottesville, VA 22901 Dr. William Vernetson i
Director of Nuclear Facilities i
Department of Nuclear Engineering Sciences University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611 Dr. Ratib A. Karam, Director Neely Nuclear Research Center Georgia Institute of Technology 900 Atlantic Drive, NW Atlanta, GA 30332 Mr. Pedro B. Perez j
Associate Director Nuclear Reactor Program North Carolina State University P. O. Box 7909 Raleigh, NC 27695-7909 Leslie P. Foldesi, Director Bureau of Radiological Health l
Division of Health Hazards Control 109 Governor Street, Room 916 i
Richmond, VA 23219 bec w/encls:
D. M. Collins, RII C. Bassett, RII C. Julian, RII J. Caldwell, NRR A. Adams, NRR Document Control Desk l
CONCURRENCES SEE PAGE 3 i
University of Virginia 3
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l ENCLOSURE 1 Management Meeting Attendees l
University of Virainia
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A. Reynolds, Chairman, Reactor Safety Committee R. Mulder, Director, Reactor Facility P. Farrar, Reactor Supervisor B. Hosticka, Senior Reactor Operator Nuclear Reaulatory Commission - Reaion II l
S. Ebneter, Regional Administrator B. Mallett, Deputy Director, Division of Radiation Safety and Safeguards (DRSS)
G. Jenkins, Director, Enforcement and Investigation Coordination Staff (EICS)
C. Evans, Regional Counsel D. Collins, Branch Chief, Nuclear Material Safety and Safeguards Branch (NMSS), DRSS C. Julian, Branch Chief, Engineering Branch, Division of Reactor Safety E. McAlpine, Se: tion Chief, Radiation Safety Projects Section (RSPS), NMSS, DRSS B. Uryc, Senior Enforcement Specialist, EICS R. Baldwin, Reactor Engineer, Operator Licensing Section (OLS), Operations Branch (OPB), Division of Reactor Safety (DRS)
J. Bartley, Reactor Engineer, OLS, OPB, DRS C. Bassett, Project Inspector, RSPS, NMSS, DRSS J
Nuclear Reaulatory Commission - Headauarters J. Caldwell, Section Chief, Operator Licensing Section, Operator Licensing Branch, Division of Reactor Controls and Human Factors, Office of Nuclear i
Reactor Regulation (NRR)
A. Adams, Project Manager, Non-Power Reactors & Decommissioning Project Directorate, Division of Operating Reactor Support, NRR r
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ENCLOSURE 2 ENFORCEMENT CONFERENCE PURPOSE SPECIFIC CORRECT MISSTATEMENT IN LAST NRC INSPECTION REPORT PROVIDE NEW INFORMATION DISCUSS VIOLATIONS, CAUSES AND SAFETY SIGNIFICANCE 4
PRESENT CORRECTIVE ACTIONS, SHORT AND LONG-TERM DISCUSS EVENT TO DETERMINE APPROPRIATE ENFORCEMENT ACTION DETERMINE AGGRAVATING OR MITIGATING CIRCUMSTANCES GENERAL ENSURE LASTING REMEDIAL ACTIONS & REGULATORY COMPLIANCE DETER FUTURE VIOLATIONS BY LICENSEE AND OTHERS 1
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FOUR APPARENT.NRC-IDENTIFIED VIOLATIONS (ORDER MODIFIED BY LICENSEE) j 1.
FAILURE TO FOLLOW A PROCEDURE BY NOT OBTAINING SPECIFIC APPROVAL FOR REMOVING JUMPERS IN THE REACTOR
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CONTROL CONSOLE.
2.
FAILURE TO HAVE ADEQUATE PROCEDURES FOR PERFORMING TROUBLE SHOOTING AND MAINTENANCE.
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- 3. PERFORMING MAINTENANCE ON A SAFETY SYSTEM COMPONENT WITHOUT SUBSEQUENTLY VERIFYING THAT THE SYSTEM WAS i
OPERABLE BEFORE IT WAS RETURNED TO SERVICE.
4.
OPERATING THE REACTOR WITHOUT ALL OF THE REQUIRED SAFETY SYSTEM CHANNELS OPERABLE.
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FAILURE TO FOLLOW A PROCEDURE BY NOT OBTAINING i
BPECIFIC APPROVAL FOR REMOVING JUMPERS IN THE REACTOR CONTROL CONSOLE.
UVAR TS 6.3, REQUIRES (AMONG OTHER PROVISIONS)
WRITTEN PROCEDURES FOR REACTOR OPERATIONS BE FOLLOWED.
UVAR SOP 2.D STATES THAT JUMPERS SHALL NOT BE INSTALLED OR REMOVED UNLESS SAFETY SYSTEM ID NOT COMPROMISED, A RECORD IS MADE IN LOGBOOK AND 3PECIFIC APPROVAL IS OBTAINED FROM i
REACTOR SUPERVISOR OR FACILITY DIRECTOR.
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DISCUSSION.
INADVERTENT INSTALLATION OF JUMPERS IN REACTOR CONSOLE
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WAS DIRECT CONSEQUENCE OF M/D EXCHANGE.
AS REQUIRED, RECORD OF M/D MODULE EXCHANGE MADE IN I
REACTOR LOGBOOK.
STILL, PRIOR APPROVAL NOT OBTAINED i
AND SRO EXCEEDED I!IS AUTHORITY.
PERMISSION TO MAINTAIN M/Ds IN EXCHANGED POSITION AND TO RESTART UVAR GRANTED BY REACTOR SUPERVISOR TO SRO PERFORMING TROUBLE SHOOTING.
- HOWEVER, PERMISSION INFORMAL & W/O CRITICAL ATTITUDE.
AS A
- RESULT, SAFETY SYSTEM FUNCTION PARTIALLY COMPROMISED BECAUSE NUMEROUS SCRAMS "JUMPERED TOGETHER."
THIS RESULTED FROM NON-SYMMETRY IN LAYOUT OF THE TWO SCRAM LOGIC LINES TOGETHER WITli EXCilANGE OF M/Ds liAVING INTERNAL JUMPERS TYING DIFFERENT SETS OF UNUSED INPUTS TOGETHER.
SRO AND SUPERVISOR SHOULD HAVE RECOGNIZED TROUBLE-SHOOTING AND MAINTENANCE BEING PERFORMED,
& SAFETY IMPORTANCE OF SYSTEM REQUIRED FORMAL REVIEW OF PLAN AND TESTING FOR OPERABILITY PRIOR TO REACTOR RESTART.
INTERNAL JUMPERS ON UNUSED M/D INPUTS (INTRODUCED IN EARLY 1970's)
NOT RECORDED ON SCHEMATICS, PERHAPS BECAUSE SCRAM SYSTEM LOGIC NOT AFFECTED WITH MODULES FIXED IN ORIGINAL POSITION.
EXISTENCE OF JUMPERS NOT RECALLED BY SRO RESPONSIBLE FOR ELECTRONIC WORK.
UVAR SAR CONSULTED BUT NO INFORMATION ON JUMPERS FOUND.
VIOLATION OF SOP 2.D AND UVAR TS 6.3 OCCURRED BECAUSE UNEXPECTED SITUATION CREATED WENT UNRECOGNIZED FOR FAILURE TO PERFORM OPERABILITY TESTING.
ADMISSION:
VIOLATION ADMITTED.
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FAILURE TO HAVE ADEOUATE PROCEDURES FOR PERFORMING TROUBLE SHOOTING AND MAINTENANCE.
UVAR TS 6.3 OPERATION PROCEDURES PRESCRIBES THAT PROCEDURES SHALL BE IN EFFECT FOR (AMONG OTHER ITEMS)
PREVENTATIVE AND CORRECTIVE MAINTENANCE OPERATIONS THAT COULD HAVE AN FFFECT ON REACTOR SAFETY.
UVAR TS 4.5 MAINTENANCE REQUIRES VERIFICIsTION OF CONTROL OR SAFETY SYSTEM OPERABILITY BE DONE FOLLOWING MAINTENANCE OR MODIFICATION & PRIOR TO RETURN TO j
SERVICE.
UVAR SOP 7 SYSTEM CALIBRATION AND MAINTENANCE DID NOT ADDRESS TROUBLE SHOOTINr-OF REACTOR CONSOLE.
i DISCUSSION:
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UVAR SOP 7 SYSTEM _ CALIBRATION AND MAINTENANCE, ON MAY 28, 1993, DID NOT CONTAIN DEFINITIONS FOR MAINTENANCE j
OR TROUBLE SHOOTING, OR PROVIDE GUIDANCE FOR "SUCH l
FUNCTIONS AS SWITCHI?'G THE M/D MODULES IN THE SCRAM
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LOGIC-DRAWER."
l HOWEVER, OPERABILITY CHECK COULD HAVE BEEN PERFORMED USING EXISTING DAILY CHECKLIST.
CONSOLE EVENT WOULD NOT HAVE HAPPENED IF THIS HAD BEEN DONE.
TROUBLE WAS, NEITHER SRO OR REACTOR SUPERVISOR JUDGED M/D EXCHANGE TO BE MAINTENANCE OR (POSSIBLE) CONSOLE MODIFICATION.
SAME ERROR OF JUDGEMENT MADE BY BOTH OPERATOR AND SUPERVISOR.
IMPROVEMENTS TO SDP 7 (AND OTHER SOPS)
MADE IN RESPONSE TO CONSOLE EVENT.
MAINTENANCE AND TROUBLE SHOOTING DEFINITIONS SIGNIFICANTLY IMPROVED SOP 7.
THESE TERMS ARE NOT DEFINED IN ANS-15 " OPERATIONS OF RESEARCH REACTOR GLOSSARY OF DEFINITIONS AND TERMINOLOGY." OTHER REACTORS POSSIBLY IMPACTED.
NOTE:
SINCE IT IS NOT POSSIBLE TO ANTICIPATE ALL FUTURE REQUIREMENTS FOR REACTOR OPERATIONS, HAVING ADEQUATE PROCEDURES AT ALL TIMES IS IMPOSSIBLE.
l REQUIREMENT SHOULD BE ON FOLLOWING ADEQUATE PROCEDURES l
{I.E.,
HAVING THEM IN EFFECT).
DETAILED PROCEDURES DEVELOPED WHEN NEEDED PRIOR TO INITIATING OPERATION.
ADMISSION:
VIOLATION
- ADMITTED, BUT APPEARS TO BE BROADER RESTATEMENT OF VIOLATION 1 (BASED ON SAME TS).
IT IS SUGGESTED THAT HAVE ADEQUATE BE SUBSTITUTED BY FOLLON AND VIOLATION 1 INCORPORATED INTO 2.
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3.
PERFORMING MAINTENANCE ON A SAFETY SYSTEM COMPONENT l
WITHOUT SUBSEQUENTLY VERIFYING THAT THE SYSTEM WAS i
OPERABLE BEFORE IT WAS RETURNED TO SERVICE.
UVAR TS 4.5 MAINTENANCE REQUIRES VERIFICATION OF CONTROL OR SAFETY SYSTEM OPERABILITY BE DONE FOLLOWING MAINTENANCE OR MODIFICATION & PRIOR TO RETURN TO SERVICE.
i DISCUSSION:
THIS STATEMENT IS CENTRAL TO CONSOLE EVENT.
EFFECTIVENESS OF LICENSEE'S CORRECTIVE ACTIONS SHOULD BE EVALUATED AGAINST FAILURE TO TEST.
VIOLATION 3 ALSO COULD BE INCORPORATED UNDER COMBINED RESTATEMENT OF VIOLATIONS 1 AND 2.
t TROUBLE-SHOOTING APPROACH OF EXCHANGING MODULES TO DETERMINE WHICH ONE MIGHT CONTAIN SOURCE OF SPURIOUS SCRAMS WAS SOUND.
TRTR PEER REVIEW REPORT STATES THIS.
HOWEVER, TROUBLE-SHOOTING PLAN SHOULD HAVE BEEN FORMALLY DOCUMENTED, ANALYZED AND APPROVED PRIOR TO BEING ATTEMPTED BY THE SRO.
AND, PLAN SHOULD HAVE CALLED FOR ADEQUATE TESTING ' RIOR TO REACTOR RESTART.
SRO AND REACTOR SUPERVISOR SHOULD HAVE UNDERSTOOD THAT, EVEN HAD THE M/Ds BEEN IDENTICAL, TESTING FOR OPERABILITY SHOULD HAVE BEEN DONE TO TAKE INTO ACCOUNT POTENTIAL FOR UNRECOGNIZED OR UNDOCUMENTED DIFFERENCE!
j ADMISSION:
VIOLATION ADMITTED.
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4.
OPERATING THE REACTOR WITHOUT ALL OF THE REQUIRED BAFETY SYSTEM CHANNELS OPERABLE.
FIVE INOPERABLE CHANNELS REQUIRED BY UVAR TS 3.2 WERE:
2 POWER-LEVEL INTERMEDIATE-RANGE PERIOD (LOW) PRIMARY COOLANT FLOW POWER TO PRIMARY COOLANT PUMP CHANNELS OPERABLE WERE:
POOL WATER TEMPERATURE ALL 3 MANUAL SCRAMS 2 POOL WATER LEVEL BRIDGE RADIATION MONITOR AIR PRESSURE TO HEADER FACE RADIATION MONITC EVACUATION ALARM TRUCK DOOR OPEN, ESCAPr, HATCH OPEN, MIF HI-TEMP PRIMARY COOLANT PUMP-ON HEADER DOWN WITH PUMP-ON i
DISCUSSION:
MINERAL IRRADIATION FACILITY (MIF) HIGH TEMPERATURE SCRAM AND HEADER-DOWN WITH PUMP-ON SCRAM PROVIDED
'l REASONABLE COMPENSATION FOR LACK OF POWER LEVEL AND OTHER SCRAMS.
THE 14-DAY REPORT DISCUSSED THIS IN SOME DETAIL.
HOWEVER, NO COMPENSATION-FOR PERIOD SCRAM, OTHER THAN LICENSED OPERATOR ATTENTIVENESS TO REACTOR PERIOD LEVELS UPON START-UP.
ADMISSION:
VIOLATION ADMITTED.
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1 CORRECTIVE ACTIONS, BHORT TERM UPON DISCOVERY OF NON-COMPLIANCE WITH LICENSE, REACTOR WAS SHUTDOWN FOR' EXTENDED PERIOD.
f ORIGIN & CONSEQUENCES OF EVENT INVESTIGATED.
LOSS OF SCRAM FUNCTION WAS UNPRECEDENTED.
1 TIMELY NOTIF2 CATION OF UNIVERSITY, COMMUNITY AND NRC.
THREE WRITTEN REPORTS SENT TO NRC.
L ReSC BRIEFED ON EVENT W/I 48 HOURS.
THREE FOLLOW UP MEETINGS HELD.
i 1-NEW MEMBER WITH ELECTRONICS EXPERTISE APPOINTED TO ReSC BY U.VA.'S PRESIDENT.
TRTR CONTACTED AND ASKED TO PERFORM PEER REVIEW.
NUMEROUS STAFF MEETINGS HELD TO, ANALYZE
- EVENT, f
DETERMINE POOT CAUSES AND PROPOSE CORRECTIVE ACTIONS.
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CONSOLE ELECTRONICS AND SCHEMATICS STUDIED AND I
COMPARED.
OFFICIAL SCHEMATIC UPDATED TO CORRECT A FEW MINOR DISCREPANCIES. SEARCH FOR SIMILAR " TRAPS" MADE.
CONSOLE ELECTRONICS CHECKED & FOUND UNDAMAGED.
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i MODULE CALIBRATIONS AND BENCH TESTS PERFORMED.
I SOURCE OF SPURIOUS SCRAM SOUGHT AND BELIEVED FOUND.
REACTOR CONSOLE MODULE LABELLING IMPROVED.
CAUTION PLACED SCPAM DRAWER ABOUT NO MODULE INTERCHANGE.
M/D MODULES RETURNED TO OFF-THE-SHELF STATE FOLLOWING
' NALYSIS, REVIEW AND ReSC APPROVAL.
I IMPROVED SOPS SUBMITTED TO ReSC AND APPROVED.
REACTOR STAFF MEETINGS HELD TO TRAIN STAFF ON REVISED PROCEDURES.
3 DUTY-BOARD LISTING NAMES OF REACTOR SUPERVISOR, COGNIZANT SRO AND OPERATOR AT CONSOLE POSTED AT i
ENTRANCE TO UVAR REACTOR ROOM.
IMPORTANCE OF FOLLOWING PROCEDURES RE-EMPHASIZED To REACTOR STAFF BY REACTOR DIRECTOR.
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j REACTOR MAINTAINED SHUTDOWN UNTIL ALL NEEDED AND
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SUFFICIENT SHORT TERM CORRECTIVE ACTIONS COMPLETED, E
1 ReSC RESTART APPROVAL OBTAINED AND DISCUSSIONS WITH I
NRC FINALIZED.
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i CORRECTIVE ACTIONS, LONG TERM i
COMMITMENT MADE TO NRC TO SHUTDOWN UVAR _FOR EXAMINATION AND MAINTENANCE IF 2 SPURIOUS SCRAMS OF UNDETERMINABLE CAUSE OCCUR W/I A 30 DAY PERIOD, DURING.
j FIRST 90 DAYS FOLLOWING RESTART.
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TRTR'S PEER REVIEW RECOMMENDATIONS TO BE CONSIDERED BY
'i JULY-10.
COPY OF FORMAL RESPONSE TO TRTR TO BE SENT i
TO NRC.
I SOP 3,
DEVOTED TO PERSONiL RESPONSIBILITIES, TO BE EXPANDED TO CONTAIN MORE DETAIL AND LEAVE NO DOUBT ABOUT CHAIN OF COMMAND AND AUTHORITY.
-I MODIFICATION OF 2 OTHER MODULES HAVING JUMPERED UNUSED INPUTS TO BE CONSIDERED.
IMPROVEMENTS TO CONSOLE TO BE STUDIED:
INCREASE REDUNDANCY TO. PERMIT SOME ELECTRONIC FAILURES WHILE MAINTAINING MINIMUM OF TS-REQUIRED CHANNELS i
OPERABLE...
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SOP IMPROVEMENTS t
DEFINITIONS FOR MAINTENANCE AND TROUBLE. SHOOTING ADOPTED. GUIDANCE AND TRACKING FORM DEVELOPED.
SAFETY SYSTEMS CHECKLIST, AN ABBREVIATED DAILY CHECKLIST, WILL TEST SCRAM AVAILABILITY FOLLOWING UNPLANNED SCRAMS PRIOR TO REACTOR RESTART.
BOTH REACTOR SUPERVISOR AND COGNIZANT SENIOR REACTOR OPERATOR TO~ PROVIDE RESTART AUTHORIZATION AFTER SAFETY SYSTEMS CHECKLIST IS SUCCESSFULLY COMPLETED.
CONDITIONS REQUIRING MANUAL TRIP EMPHASIZED IN SOP 2.
MANUAL TRIP RECOMMENDED IF UNSAFE OPERATION IS SO MUCH AS SUSPECTED.
PROCEDURE FOR HANDLING TS VIOLATIONS INTRODUCED.
REACTOR SUPERVISOR MADE " FOCAL POINT" FOR REACTOR OPERATIONS.
IMPROVEMENT OF MANAGEMENT CONTROL.
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j UVAR STAFF DEVELOPED DEFINITIONS j
I TROUBLESHOOTING IS THE SYSTEMATIC PROCESS FOR IDENTIFYING EQUIPMENT PROBLEMS AND THEIR CAUSES.
MAINTENANCE IS THE AGGREGATE OF THOSE FUNCTIOFS REQUIRED TO PRESERVE, RESTORE, ~ IT I
OR IMPROVE OPERABILITY OF FACILITY SYSTEMS.
INCLUDES SCHEDULED SURVEILLANCES, TROUBLE l
- SHOOTING, REPAIR, AND MODIFICATIONS.
IT I
EXCLUDES THE EXCHANGE OR REPLACEMENT OF CONSUMABLES (E.G. CHART PAPER, LAMPS, RECORDER PENS, BATTERIES).
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TECHNICAL AND SAFETY BIGNIFICANCE OF CONBOLE EVENT REACTOR OPERATED WITHOUT INCIDENT FOR SHORT TIME (5.5 HOURS).
REACTOR COULD HAVE OPERATED AT MOST 10 HOURS BEFORE DISCOVERY OF SCRAM LOGIC CHANGE.
OPERATIONAL PARAMETERS NOT EXCEEDED, NO SAFETY LIMITS VIOLATED.
RECORDERS INDICATE THIS.
REACTOR CONSOLE ELECTRONICS NOT DAMAGED BY MODULE EXCHANGE.
CONSOLE EASILY AND QUICKLY RETURNED TO ORIGINAL CONDITION.
OPERATOR HAD ALL VISUAL AND AUDIO ALARMS AND DISPLAYS OPERATIONAL.
MANUAL SCRAM AVAILABLE.
HIGH TEMPERATURE SCRAM ASSOCIATED WITH MINERAL IRRADIATION FACILITY PROVIDED REASONABLE SUBSTITUTION FOR POWER LEVEL SCRAMS.
l PERIOD PROTECTION NOT AVAILABLE.
HOWEVER, THIS IS IMPORTANT PRINCIPALLY DURING REACTOR STARTUP, WHEN OPERATOR IS FULLY ATTENTIVE TO PERIOD LEVELS.
AT BEST, PERIOD PROTECTION NORMALLY AVAILABLE ONLY WHEN i
INTERMEDIATE RANGE IS REACHED.
EXCURSION DUE TO EXPERIMENTS FALLING AWAY FROM CORE HIGHLY UNLIKELY.
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GIVEN THEIR LOW REACTIVITY, OPERATOR COULD MANUALLY SCRAM REACTOR ON HIGH POWER ALARM.
BARRING THAT, MINERAL IRRADIATION FACILITY HIGH TEMPERATURE SCRAM WOULD ACTUATE.
RiiODE ISLAND REACTOR HAD HEU AND LEU CORE 3 TART-UP ACCIDENT ANALYSIS PERFORMED FOR THEIR REACTOR.
RI'S REACTOR IS SIMILAR TO UVAR: 2 MW, 18 PLATES / ELEMENT, 124 C U 235 PPP PL?TZ.
ASSUMING BOTH PERIOD AND HIGli FLUX SCRAM PROTECTION FAILURE WITil STARTUP FROM COLD CLEAN CONDITION, REACTOR POWER RISES UNTIL LIMITED BY NEGATIVE REACTIVITY DUE TO VOID AND TEMPERATURE COEFFICIENTS.
CALCULATIONS FOR HEU SliOW CORE WOULD OPERATE IN NUCLEATE BOILING RANGE WITHOUT PHYSICAL DM4 AGE UNTIL REACTOR MANUALLY SCRAMMED.
MAXIMUM CLADDING TEMPERATURE BELOW 150 C (302 F), MUCH LOWER THAN CLAD MELTING TEMPERATURE OF 582 C (1080 F).
CONCLUSION:
UVAR CONSOLE EVENT HAD LOW SAFETY SIGNIFICANCE.
I
e APPROPRIATE ENFORCEMENT ACTION (SEVERITY LEVEL ASSIGNMENT)
NRC ENFORCEMENT POLICY RECOGNIZES REGULATION DOES NOT i
LEND ITSELF TO MECHANISTIC TREATMENT.
JUDGEMENT AND j
DISCRETION IS EXERCISED BY NRC IN DETERMINING SEVERITY LEVELS OF VIOLATIONS AND APPROPRIATE ENFORCEMENT SANCTIONS.
NRC CONSIDERS TECHNICAL SIGNIFICANCE'OF VIOLATIONS AND SURROUNDING CIRCUMSTANCES.
SEVERITY LEVEL I AND II VIOLATIONS GENERALLY INVOLVE ACTUAL OR HIGH POTENTIAL IMPACT ON PUBLIC. CLEARLY NOT THE CASE FOR UVAR CONSOLE EVENT.
l EXAMPLES IN APPENDIX C TO 10CFR20 SUGGEST SEVERITY l
LEVELS ASSIGNED TO PARTICULAR EVENTS.
SEVERITY LEVEL I
EXCLUDED IMMEDIATELY BECAUSE SAFETY SYSTEM NOT "ACTUALLY CALLED UPON TO WORK."
SEVERITY LEVEL II NOT APPLICABLE BECAUSE SAFETY SYSTEM STILL "ABLE TO PERFORM ITS INTENDED SAFETY FUNCTION."
ALL ALARMS AND DISPLAYS, AS WELL AS MANY AUTOMATIC AND ALL MANUAL SHUTDOWN FUNCTIONS WERE AVAILABLE.
SEVERITY LEVEL III IS APPROPRIATELY ASSIGNABLE TO THIS EVENT.
CLOSEST EXAMPLE APPEARS TO BE:
"C.
SEVERITY LEVEL III-VIOLATIONS INVOLVING FOR EXAMPLE:
2.
SYSTEM DESIGNED TO PREVENT OR MITIGATE A SERIOUS EVENT:
(A)
NOT BEING ABLE TO PERFORM ITS j
INTENDED FUNCTION UNDER CERTAIN CONDITIONS, 3
i LICENSEE ADMITS TO THREE OF THE VIOLATIONS CHARGED BY THE NRC.
NUMBER OF VIOLATIONS (3 OR 4) MAY SUGGEST THAT, IN AGGREGATE, A SINGLE, INCREASED SEVERITY LEVEL l
IS WARRANTED.
HOWEVER, THERE IS ONLY A SINGLE KEY I
VIOLATION (THAT OF NOT TESTING SCRAMS FOLLOWING EXCHANGE OF M/Ds. ) OTHER VIOLATIONS WERE UNAVOIDABLE, DIRECT CONSEQUENCES OF KEY VIOLATION.
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UVAR REGULATORY HISTORY INDICATES THESE ARE NOT i
REPETITIVE VIOLATIONS.
PAST LICENSEE PERFORMANCE REASONABLY GOOD, WITH MORE THAN TWO YEARS SEPARATING-MORE SERIOUS VIOLATIONS.
- THUS, NO BASIS FOR INCREASING SEVERITY LEVEL DUE TO POOR COMPLIANCE I
HISTORY.
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UVAR ENFORCEMENT HISTORY DATE DEPORIPTION S.
LEVEL FINE 07-04-83 SHUTDOWN MARGIN III
$ 1000 i
10-22-84 H.P.
SURVEYS III O
i 08-13-87 N.R. BEAMPORT III
$ 1250 i
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LAST VIOLATION CITED FOR REACTOR OPERATIONS DATE INSPECTION #
DESCRIPTION LEVEL 8-20-90 50-62/90-04 RSC NOT AUDITING LOGBOOK Il 1
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e-MITIGATING CIRCUMBTANCES INFORMAL TROUBLE-SHOOTING OF REACTOR CONSOLE NOT TRULY REPRESENTATIVE OF REACTOR OPERATIONS AT VIRGINIA.
AS NECESSARY, PROCEDURES AND METHODS COVERING REACTOR OPERATIONS ARE ROUTINELY DEVELOPED, REVIEWED AND APPROVED BY REACTOR SAFETY COMMITTEE AND/OR REACTOR DIRECTOR.
ReSC MEETINGS ARE FREQUENT AND NEW PROCEDURES AND METHODS REGULARLY CONSIDERED. THE ReSC MEETING MINUTES SHOW THIS TO BE TRUE.
A SINGLE SRO HAS BEEN PERFORMING CONSOLE MAINTENANCE.
HE IS VERY CAPABLE AND HIGHLY VALUED BY STAFF AND N.E.
FACULTY FOR HIS ELECTRONIC EXPERTISE.
DUE TO THIS, REACTOR SUPERVISOR WAS NOT SUFFICIENTLY CRITICAL.
(OTHER OPERATORS WOULD NOT HAVE TAKEN THE TROUBLE SHOOTING INITIATIVE WHICH LEAD TO EVENT.)
A SECOND OPERATOR WILL ASSIST THIS SRO IN FUTURE CONSOLE MAINTENANCE, AND PROVIDE LICENSEE SELF-CRITIQUE.
THESE ONE-TIME VIOLATIONS NOT WILLFUL OR COMMITTED IN CARELESS DISREGARD FOR REQUIREMENTS.
LICENSEE EMPLOYEES ACKNOWLEDGE THAT THEY FAILED TO EXERCISE GOOD JUDGMENT.
IN RETROSPECT, IT IS DIFFICULT TO BELIEVE THAT SYSTEM WENT UNTESTED AFTER M/D EXCHANGE.
DURATION OF VIOLATIONS WAS SHORT (5.5 HOURS).
DISCOVERY WOULD HAVE BEEN MADE NO LATER THAN PRIOR TO THE PERFORMANCE OF THE NEXT DAILY CHECKLIST (THE NEXT MORNING).
NON-COMPLIANCE IMMEDIATELY CORRECTED AND REPORTED UPON DISCOVERY.
LICENSEE VOLUNTARILY TOOK EXTENSIVE AND TIMELY CORRECTIVE ACTIONS.
PEER REVIEW SOUGHT TO ASSURE NO POSSIBLE CORRECTIONS OVERLOOKED.
MOST CORRECTIVE ACTIONS SELF-PROPOSED.
ALL SUGGESTIONS CONSIDERED AND THOSE REASONABLE USED.
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,6 CIVIL PENALTY BASE CIVIL PENALTY FOR RESEARCH REACTORS PROPOSED Ili TABLE 1A OF 10CFR2, APPENDIX C, IS $ 5,000.
MITIGATION OF FINE OF 50% IS IN ORDER FOR VIOLATIONS IDENTIFIED AND ROOT CAUSES PROMPTLY CORRECTED BY LICENSEE.
i ACTIONS HAVE BEEN COMPREHENSIVE, AND FOCUSED BROADLY TO AREA OF CONCERN. SIMILAR VIOLATIONS HIGHLY UNLIKELY IN FUTURE. CORRECTIVE ACTIONS WILL BE LONG-LASTING.
P MITIGATION OF UP TO 100% IS CONSIDERED, IF VIOLATION i
IS ISOLATED FAILURE INCONSISTENT WITH LICENSEE'S VERY GOOD PERFORMANCE IN PRECEDING 2 YEARS.
THIS APPLIES.
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ENCLOSURE 3 During the Enforcement Conference, University of Virginia representatives pointed out an error in the NRC Inspection Report No. 50-62/93-02.
The error was in the characterization and discussion of an apparent violation dealing with in installation / removal of jumpers in the mixer / driver (MD) modules in the reactor control console. The licensee indicated that, when the MD modules had been interchanged during the event, this had resulted in the installation of jumpers in the reactor control console rather than the removal of the jumpers as stated in the report.
l After reviewing the report and discussing the matter with the licensee, the NRC agrees that the report contained errors. The corrections to the report are as follows:
1.
In the
SUMMARY
portion of the report in the second paragraph in the "Results" section:
The last sentence read as follows:
i
"... and (4) failure to follow a procedure by not obtaining specific approval for removing jumpers in the reactor control console."
The sentences should read as follows:
... and (4) failure to follow a procedure by not obtaining specific approval for installing jumpers in the reactor control console."
l 2.
In the REPORT DETAILS portion of the report, Paragraph 3.d, page 4:
l The last sentence in the last paragraph read as follows:
"The failure to follow procedure to obtain specific approval for i
interchanging the MD modules which effectively allowed removal of various jumpers was identified as an apparent violation.of Technical Specification 6.3 (50-62/93-02-04)."
i This sentence should read:
"The failure to follow procedure to obtain specific approval for i
interchanging the MD modules which effectively allowed installation of various jumpers was identified as an apparent violation of Technical Specification 6.3 (50-62/93-02-04)."
.~ - - - -,
,.,.