ML20054H084
| ML20054H084 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 05/18/1982 |
| From: | Cockrell R North Carolina State University, RALEIGH, NC |
| To: | Long F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20054H074 | List: |
| References | |
| NRP-RGC-82-108, NUDOCS 8206220556 | |
| Download: ML20054H084 (6) | |
Text
r ummoPanNM A T!.A N T A. C i.'.L e M NORTH CAROLINA STATE UNIVERSITY AT H ALEIGH ng g D nip OF ENGINEERING De rans su N r or Nu< a un Est.is,i niso Nui t un Re wnin Pn<n.nau nm s<> u, 7:e 27<.so May 18, 1982 NRP-RGC-82-108 Mr.
F. J. Long, Acting Chief Reactor Projects Branch 1 Division of Project and Resident Programs U.
S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.,
Suite 3100 Atlanta, CA 30303
Subject:
Report Nos. 50-297/82-01 and 50-111/82-02 Gentlemen:
In response to your letter dated April 21, 1982, submitting the referenced Inspection Reports and a Notice of Violation, attached are written statements regarding the alleged violations pursuant to the provisions of 10CFR 2.201 as stated in Appendix A of your letter.
We concur with the finding stated as Item B in Appendix A, but we do not think that Item A in Appendix A should be called " Severity Level V Violation." The following information from the Federal Register (Vol.
47, No. 46/ Tuesday, March 9, 1982/ Rules and Regulations 9991, first colum,)
supports our position on this matter:
"Because the NRC wants to encourage and support licensee initiative for self-identification and correction of pro-blems, NRC will not generally issue a notice of violation for a violation that meets all of the following tests:
(1)
It was identified by the licensee; (2)
It fits in Severity Level IV or V; (3)
It was reported, if required; (4)
It was or will be corrected, including measures to prevent recurrence, within a reasonable time; and (5)
It was not a violation that could reasonably be expected to have been prevented by the licensco's corrective action for a previous violation."
This incident and the reporting of its occurrence satisfies all five (5) tests listed in the Federal Register.
Therefore, we respectf ully request that the NRC Region II Office explain why we received a Notice of Viola-tion.
If the action taken by the Region II Office was appropriate, then 8206220556 820703 PDR ADOCK 05000ggi PDR
{.
Mr. F. J. Long, Acting Chief Page 2 Reactor Projects Branch 1 U. S. Nucicar Regulatory Commission, Region II what additional action should NCSU have taken to avoid receiving a Notice of Violation.
If the action taken by the NRC Region 11 Office was not in accordance with the Federal Register, then what action will Region II take to correct the error?
Very truly yours,
(
bcd-
- k. G. Cockrell RCC: 1pc Director l
Nuclear Reactor Progrum
Attachment:
Statement by Dr. L. W. Seagondollar, Chairman, Reactor Safeguards Advisory Group re Notice of Violation Statement by R.
G.
Cockrell, Director, Nuclear Reactor Program, re Notice of Violations.
cc:
Mr. James R. Miller USNRC, Washington, D. C.
Dr. L. W.
Seagondollar Mr. Thomas C.
Bray (all with attachments) l l
l l
f.
Reference:
NRC Reports Nos. 50-297-80-01 and 50-111/82-02, Appendix A 1.
STATEMENT OF VIOLATION 10CFR 50.54k nequiacs that an operator or senica operator Liccued puMuan,t to Paat 55 be pruent at the controls at aLL times duaing the ope 1ation of. the factLLty.
Technical Specification 1.4 defhten opetation as any condtLLon When the reQCloa is not seCuaed.
TEChai-cal Specification 1.2.b acqui,1es, as a condstron for acactoa secuacd, that power to the contaal aod magnets and actuating ci,1cutts be switched off and the console key acmoved.
Contaaag to the above, a Licensed sndividual was not at the coattolo dating the night of March 11-12, 1982 when the console key was left in the loch and OV with the contaol roan unattended and doched f.or apptoxi-mately six houM.
This is a Seveaity Level V Violation (Supplement S.D. J.
2.
RESPONSE
a) Adminion oa denmL of the alleged violatton.
This incident occurred on March 12, 1982, and was reported to Mr.
Caudie Julian, the inspector from Region II, by telephone on March 12.
Mr. Julian arrived on the campus of North Carolina State Uni-versity on March 15 to begin his week-long inspection. As a result of our March 12 phone call, he was aware of the incident prior to his arrival. We discussed the matter with Mr. Julian and submitted a written report to Region II on March 22, 1982, a copy of which is attached, in pursuance to NCSU PULSTAR Technical Specification 6.2.7.c.
b) The acasons for the violatton. if adattled.
See the attached letter.
c) Connective steps which have been taken and the acsults achieved.
The corrective measures that have been taken are delineated in the attached letter.
The result of these corrective measures is that the operators now have an increased awareness of the possibility of the liklihood of such an incident and will be more careful in the future.
d) Ca2acetive steps which wLLL be taken to avoid furthea violatwns.
An additional step to be taken to reduce the liklihood of a recur-rence of the subject event will be to increase the intensity of the " Reactor On" sign in the reactor console. This sign is 111umi-nated when the reactor console key is in the key switch and turned "On".
e) The date when full compliance wiLL be achieved.
The Administrative Controls necessary to assure full compliance have already been accomplished. We anticipate the modification to the reactor console to be complete by the first week of June.
1
-b >ee Ao 1 D r. R o be r t~ G. Cockrell Director, Nuclear Reactor Program Nor h Carolina State University
Attachment:
Our letter to Mr. Caudle Julian dated March 22, 1982
Reference:
NRC Reports Nos. 50-297-80-01 and 50-111/82-02, Appendix A.
1.
STATEMENT OF VIOLATION Technical Specification 6.2.7 requires that the Reactor Safeguards Advisory Group (RSAG) shall meet at least every six calendar months.
Contrary to the above, RSAG meetings were not hcid at least every six calendar months in that, no meetings were held in the intervals of August 7,1978 to Ap.~il 15, 1979 and November 19, 1980 to March 19, 1982.
This is a Severity Level V Violation (supplement I.E.).
2.
RESPONSE
a) Admission or denial of the allegod violation.
The Reactor Safeguards Advisory Group fully acknowledges and admits that the above-stated violation is correct.
b)
The reasons for the violation if admitted.
The Reactor Safeguards Advisory Group has concluded that the reason for the violation is oversight and lack of attention to insuring that the reactor appraisal inspection visits were per-formed at the proper intervals required by the Technical Speci-fications, c)
Corrective stops which have been taken and the results achieved.
See Item d) below.
d) Cbtrective steps which will be taken to avoid further violations.
The Reactor Safeguards Advisory Group held a meeting on March 31, 1982 to specifically address Items c) and d).
In this regard, it was concluded that:
The management of the scheduling of all future Reactor Safe-guards Advisory Group reactor appraisals will be performed by Mr. D. W. Morgan through the auspices of the Radiation Protec-tion Office.
Such reactor appraisals will be held at intervals no longer than six months.
Furthermore, as a matter of business during any given appraisal visit, the date and time for the next such meeting will be established.
The Minutes of this >brch 31, 1982 meeting are attached in support of this letter.
c)
The date when full compliance will be achieved.
The administrative controls necessary to insure full compliance have already been established and upon commencement on Fby 18, 1982, full compliance will be achieved.
L. W. Sengondolidr, Chairman Reactor Safegdd'rds Advisory Group North Carolina State University at Raleigh
o REACTOR SAFEGUARDS ADVISORY GROUP 31 March 1982 MINUTES - MEETING 19El-82/1 29 March 1982 - 1:00 P.M. Room 1121 Burlingion Engineering' Laboratories In attendance:
Dr. L. W. Seagondollar, Chairman; Mr. D. W. Morgan; Dr. Jimmie J. Wortman Visitor:
Mr. T. C. Bray I.
ITEMS FOR REACTOR SAFEGUARDS ADVISORY GROUP (RSAG) CONSIDERATION 1
A.
Discussion of Recent Nuclear Regulatory Commission (NRC) Inspection The RSAG members were informed by Chairman Seagondollar of the results of a recent NRC Inspection which points out that even though the RSAC met several times during the period from January 1979 to date, there were two occasiens when such meetings were not properly spaced in time to meet the condition that " independent appraisals of reactor operations" be made every six months.
It was concluded that in order to insure that this circumstance does not arise again, the management of the scheduling of all future RSAG reactor appraisals will be performed by Mr. Morgan through the auspices of the Radiation Protection Office.
It was further concluded that such reactor appraisals will be held twice annually in the months of June and December or as close thereto as possible.
Furthermore, it was concluded that as a matter of business during any given appraisal visit the date and time for the next such meeting will be established.
In this regard, the first appraisal of reactor operations for 1982 will take place on May 18, 1982 at 9:00 A.M.
B.
Discussion of RSAG Duties A full discussion of the history of the development of the RSAG and its duties was held to further familiarize Dr. Wortman with the overall mission of this group.
C.
Review of Draft Appraisal Checklist A draft appraisal checklist was prepared by Mr. Morgan for the con-sideration of the RSAG members.
It was concluded that each RSAG member would consider the checklist along with the larger question of defining the scope and content of future reactor appraisal visits. This topic is to be further discussed during the May 18th meeting.
D.
Agenda for May 18, 1982 Appraisal Visit It was concluded that the RSAG will consider the question of how the ALARA Radiation Protection philosophy is being factored into the reactor operations program during this appraisal visit.
II. ITEMS REFERRED TO RSAG BY THE RADIATION PROTECTION COUNCIL (RPC)
No items for review by the RSAG have been transmitted from the RPC since the last RSAG meeting.
Distribution:
APPROVED:
Of fice of the Chancellor M, v$,- y/ -
,f 4 ;)I Dr. N. N. Winstead
< "ff e Chairman, RPC L. W. Seagondo lar, Chairman Dr. P. J. Turinsky Dr. R. G. Cockrell Mr. L. T. Caruthers RSAG Members University Archives p
y 7y
NORTH CAROLINA STATE UNIVERSITY AT RALEIGH SCIIOoL OF ENGINEERING Dur4Rmrur or NucuAR Escistrassc March 22, 1982 Nuctr4R Rtacrom PR(X, RAM ADM 1-1-16-1 Bos 56% Zie 27650 l
Mr. Caudle Julian Project Inspector, Region II U. S. Nuclear Regulatory Cccmission 101 Marietta Street, N.W., Suite 3100 Atlanta, Georgia 30303 Docket No. 50-297 Facility License No. R-120
Dear Sir:
This letter is transmitted in pursuance to North Camlina State University PULSTAR Technical Specification 6.7.2.c. and describes a Reportable Event (Abnormal Occurrence per our Technical Specification 1.17.f.).
At 0606 on 12 March 1982, when cccmencing a routine reactor start-up checklist, the reactor operator observed the console key in the key-switch and the keyswitch in the "ON" position. 7he mactor was shut down (control rods ib11y down) and suberitical by the strne margin as would be expected under routine conditions. At that initial step of the checklist procedure, the console keyswitch should have been "OFF" and the key removed. The Senior Operator who came on duty at 0606/12 March 1982 reviewed the operating log and concluded that the console keyswitch had been left "ON" since the preceeding reactor shutdown had been performed, six (6) hours prior to the 0606/12 March 1982 discovery.
7he reactor control recra was doubly locked, as usual, and the facility intrusion alann was properly set and armed. Hence the zwactor controls were not accessible to the public.
The Reactor Operator who failed to tum off the keyswitch and re-rnove the console key was interviewed by the Reactor Manager and asked to describe the cirrumstances leading to the event. At the conclusion of the interview, it was deternined that failure of the Reactor Operator to follow the established shutdown procedure was due to inattention on the part of the Reactor Operator to the final steps of the shutdown pro-cedure.
Mr. Caudie Julian Mamh 22,1982 Page No. 2 l
Cormctive measures have been taken to avoid ibrther occurmnces of this type being reported and they are:
1.
Interview with the operator responsible to determine why the shutdown procedum was not followed in its entirety.
2.
Requalification lecture of all Reactor Operators and Senior Operators conceming the subject occurrence.
3.
Issuance of PULSTAR Standing Order No.47 entitled Guidance for Performing Reactor Checklists.
An additional step to be accomplished toward eliminating a recurrence of the subject event will be to increase the intensity of the " Reactor On" sign in the reactor console. This sign is illtrainated when the reactor console key is in the keyswitch and tumed "0N".
Please contact me at (919)737-2323 should you desire addition informa-tion concerning this report.
Sincerely, Y.
'Ihomas C. Bray Reactor Operations Manager
'ICB/bwl cc: Mr. Janes R. Miller USNRC, Washington, D.C.
Dr. R. G. Cockmll, Director Nuclear Reactor Program Departrnent of Nuclear Engineering North Carolina State University
.