ML20090L657

Informs That Fuel Experiment Conducted W/Radiation Monitor, Part of Radiation Monitor Sys,Not Operational on 920211. Caused by Failure to Specify Semiannual Calibr Interval for Monitor.Film Irradiator Fueled Experiment Secured

ML20090L657
Person / Time
Site:	University of Missouri-Columbia
Issue date:	03/11/1992
From:	Mckibben J, Meyer W MISSOURI, UNIV. OF, ROLLA, MO
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 9203230005
Download: ML20090L657 (5)

Text

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i Research Reactor Facihty.

I sesemen m Columba M saoun t4211 UNIVERSITY OF MISSOURI COLUMBIA W

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bu pt,q W 3443-March 11,1992 Director of Nuclcar Reactor Regulation US Nucieur Regulatory Commission Mail Station P1 137 Washington, DC 20555

REFERENCE:

Document 50-186 University of Missouri Research Reactor License R-103

SUBJECT:

Report us required by Technical Specification 6.1.h(2) regarding:

(a) operation of a fuebd experiment with the experiment's direct radiation monitor out of service for source calibration check

and, (b) surveillance (calibration) interval for radiation monitors that acceded Technical Specification 5.4.a requirements.

MTRODUCTIO N On February 11,1992, the University of Missouri Research Reactor (MURR) operated a fueled c.tperiment for approximately six hours with a radiation moniter, part of the Area

~ Rad 2ation Monitor System (ARMS), required by Technical Specifications 3.6.o not operational.

In analping this situation, it was realized that four of the new ARMS detectors were scheduled on an annual calibration frequency and therefore not calibrated at the semiannual interval required

' by Technical Specifications 5.4.a.

REfiCRIPTIO.N The MURR operated until February 18,1991 with an ARMS of 1960's vintage built by Tracerlab, Inc, In upgrading the reactor instrumentation, a new Eberline Model RMS 11 ARMS was installed to replace the old Tracerlab system. The function of other instrumentation including the fission product monitor, the secondary monitor, the back up door air plenum monitor, and the film irradiation facility monitor were aho included in the new ARMS. On -

Febrimry 18,1991 after an extended testing period, MURR placed the new ARMS in service.

During an NRC ' Team" Inspection March 6-10,1989, a concern was expressed about the lack of traceability to NIST (formerly NBS) standards for the calibration of the ARMS monitors and instrumentation. In responso to this concern, the IIealth Physics Group developed a new calibration methodology for the new ARMS which is traceable to a NIST standard. The new calibration procedure for a channel requires re.noval of the detector module and the p

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4 ind, cation / alarm module. These are taken to the building where Campus IIcalth Physics have their J. L. Shepard Cs.137 calibration source to perform the check. This provides a calibration 1

- traceable to a NIST standard. The new ARh1S can be calibrated in this fashion since tho signal from the detector module to the indication /alrrm module is not dependent on the length of cable

. between the two modules,

- Because of this new requirement of removing the detector and electronic module, the Electronics Technicians and IIealth Physics Group who perform the source calibration checks of tho ARh1S changed the interval between surveillances on their maintenance procedures from i

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semi annual to annual. They were not aware of the Technical Specification requirements for

- eurveillance frequency for the reactor bridge monitor and the renetor exhaust plenum monitor.

These particular monitors are considered reactor instrumentation as por Technical Srecification i

3 A.n.

As reactor instrumentation, they are required to meet tho semi-annual calibration

. interval specified in Technical Specificatbn 5A.a. This Techmcal Specification applies to surveillance of the reactor ir. trumentation system, which includes the radiation monitore for the reactor bridge and the reactor building exhaust air plenum. Technical Specification 5.4.a. states:

"All instruments, as required by these specifications, shall be calibrated on semiannual intervals? Contrary to this requirement, the calibration of these radiation monitors had been g

changed to an annual frequency when the new ARh1S was placed in service February 18,1%1.

The A1URR ARh1S incorporates two reactor bridge monitors and two reactor exhaust

- plenum ~ monitors for redundancy (one of each type is required by Technical Specifications).

These monito:s were calibrated in January and February of 1991, shortly before the system was -

placed in operation on February 18,1991. - By Technical Specinention 5A.a and the deGnition or l-semi-annual in Technical Specification 1.2 (interval + 2 months), the reactor bridge Sud reactor h

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j exhaust plenum monitors s ould ave ben source ca i ration c ecked at t e atest in Septem er L

and October of 1991. Instead; since the maintenance pmcedure had been changed to ir.dicate an l

annual calibration interval, the source calibration checks were completed in February 1992.

i One of the ARh1S monitors calibrated in February 1992 was for the film irradiator facility l

st h1URR, ~a fueled experiment (see attached Figure 1) used to irradiate polycarbonate film. The

- film passes between two pairs of fission phtes and is irradiated by the fiwien products to make a

ionization tracks through the Glm. Fueled experiments with iodine inventories greater than 1.5 l-

curies or strontium-90 greater than 5 millicuries are required to be vented to the exhaust stack system through HEPA and ch'arcoal filters which are continuously monitored for ao increase in L

radiation levels (Technical Specincation 3.G.o).

At 0915 on February 11, IM1, the film irradiator fueled experiment was placed in operation.

Later that day at 1330, an Electronics Technician requested and received permission from the Control Room Operators to pull the Area Radiation hlonitor for the fihn irradiator experiment 4

along with several beamport Door area monitors for scheduled source calibration checks. The radiation monitor for the G!m irradiator experiment was pulled at this time for its calibration check-.

Electronics Technicians reported to the control room at 1715, the end of their normal woa

- day, that nnly two of four modubs were completely calibrated Control Room Orerators did not:

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March 11,1992 Page 3 request that either of the calibrated modnles be placed in service as the radiation monitor for the Ghn irradiator fueled experiment.

Later that evening, the Shift Supervisor of the night shift, which starts at 1830, called me (the Reactor Manager) after shift tumover to discuss the Alm irradiator fueled experiment

- operating without the direct radiation monitor for its exhaust filter bank. The Shin Supervisor recommended securing the experhnent; I concurred and the experiment was securet at 1915.

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The Ghn irradiator ueled experiment thereAre ran for a period of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 45 minutes with r

its direct radiation monitor out of service for its scheduid source calibration check. This is in viohition of MURR Technical Specification 3.6.o.- The fueled experiment should have been i

secured while the radiation monitor was out of service. It was while investigatit.g the cause of this Technical Specification violation that it was h.arne:I that the cahbration frequency of four I

detectors (two are require 1 by Technical Specification 3.4.a.)in the ARMS was not in comoliance with Technical Specification 5.4.a.

ANALYSIS The basis for Technical Speci0catico 5.4.a states: 'Seraiannual calibration of the reactor l

-instrumentation system rhennels will assure that long term drin of the ch.mnels will be corrected? Review of ue reactor console logs from February 1991 to February 1992 showed that the indications for the reactor bridge and reactor exhaust plenum monitors, which monitor a relatively constant background when the reactor is at 10MW power level, dii not experience ndceable drift. Additionally, the Technical Specification 5 4.b monthly requirement to rmum.o check these monitors was accomplished on a weekly basis as part of the re,ctor startup checkaheet.

Ifistorically,'the scheduling of calibrations for radiation detection equi ment ha been done by the Elcetronics Technicians and the Health Physics Group as part of thn/ preventive maintenance program. Records indicate that all the semiannual calibration requirements for thn Tracerlab ARMS had been met. The error in calibration interval was introduced when E'ectronics Technicians and the Health Physics Group prepared the new calibration procedurns for the Eherlitie RMS H. The fact that these new calibration proce< hires wero not reviewed for Technical Specification canpliance indientes an area of weakness in impleinentation af

. management control for surveillance of the ARMS equipment. These procedures should have

- been reviewed by the Reactor Manager and the Procedures Review Abcommiucuf the Reactor

- Advisory Gommittee.

Prior to the installation of the Eberline RMS H. extensive review of the Hazarda Summary

' and the safety stem compliance checks associated with the ART.1S was performed. The

-necessary modifications to the Hazards Summary Report were idwined an6 reported in the 1990-1991 Annual Report to the Nuclear Regulatory Commission as required by Technical Specification 6.1.h(4). The compliance check procedures for the safety system functions associated with the ARMS (Reactor Isolation und Scrand were rewritten. Discussicus between the Elcctroaics Technicians, the Health Physics Group, an'd me about hovi to schedule the ARMS calibrations were held. A decision was reached that the calibrations for the reactor bridge and reactor exhaust plenum monitors, which can initiate a Reactor Isolation, rust be accomplished on shutdown days when containment integrity is not requird The failure to specify the semiannal calibration t

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inurvwl for these same radiation monitors during these discussions indicate a weakness in f

implementing the necessary mann ement control for the ARMS e

o A similar weaknew resulted in Control Room Operators and Electronics Technicians removing inntrumentation, required by Technical Specification for operation of an experiment, to per1ivrm the new calibration checks 'md not being sensitive to the operational limitations it put on them. Since these calibration checks had previously been done with the detectors in place, the unw maintenaace procedures should have stressed the fact that the instrument channels would be taken 4

out of service to accomplish the calibration checks.

The film irradiator facility is a fueled experiment that has been operational since 1979.

MURR requested amendrents to License R 103 by letter dated February 15,1977, in order to conduct fueled emeriments with Ossion product inventories groater than had been previously

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autherized. Thh: was authorized by Amendment No. 8 to MURR License R.103 in February 24, t

1918. The Olm irradiator fueled experiment was approved for routine operation following extensive testing by the Reactor Manager on November 28,1979.

In develaping the basis for the Safety Evaluation to support Amendment No. 8, the Nuclear RegWatoif Commission (NRC) posed ten questions to MURR staffin a letter dated August 4,1977.

. Quenion 8 of this letter requests details of the monitors which would detect the failure of a fueled experimnt. MURR's responses to question 8 were contained in a letter to NRC dated Setenner 23,1977. In this letter MURR proposed that fueled experiments containing inventories of radioiodine isotopes 131 through 135 greater than L5 curies and strontiom 90 greater than 5 millicuries will be vented to the exhaust stack system through particulato and halogen filters which would be continuously monitored for increase in radiation level This proposal for a direct radiation monitor for fueled experiments was incorporated into Technical Specifications as 3.G.o.

It was also stated (page 16) that these " monitors will have a high level trip with visual and audible alarms both knally and in the reactor control room. These individual fueled experiment monitors will serve as a back up to the MURR exhaust stack monitor which will provide the most sensitive quMtative indication of any fission product release."

Duriag the 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 45 minutes on February 11,1992 that the film irradiator fueled

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experiment operattd without its direct radiation monitor, the primary indication of a fission product release, the exhaust stack monitor, was in continuess operatien. Any fission product release would have 1,een detected by the exhaust stack menitor which detects, measures and records

. airborne radioactivity in the form of particulates, iodine and_ gases separately und centinuously.

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Therefore the operation of the film irradiator experiment on Fehnmry 11,1992 for a period lI of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 45 minutes indicated a deficiency in management control but did not represent a hazard 6

to the health and safety of the public.

' CQ,RigCTIVE ACTIONS The immediate corrective action on February 11,1992 was to secure the film irradiator

fueled experiment until its rad!ation monitor was calibrution checked and returned to service.

-The following day before the tihu irradiator experiment was allowed to resume operation, a l

Standing Order was issued by the Reactor Manager to amplify the requirements of Technical Specifiention 3.6.o. The Standing Order states '.he radiation monitor for the Olm irradiator l

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y-March 11,1972 Page 5 experim9nt_will be verified operable before permitting an experiment ru rtup and that any time the radiation monitor for that experiment is not operable (either due to failure or being out of service for calibration) the illm irradiator expe iment will be red tagged secured, To further_ ut.ure compliance with Te6nical Specification 3.6.0, the operating procedures for the film irradiator experiment have been changed to mere that its radiation monitor is verift ed operable prior to experiment startup. The remote module (in the control room) will be marked with a red name tag (similar to the monitors that are considered reactor instrumentation) to indicate that it has a safMy related significance.

The preve.ifive maintenance procedure for the ARMS System has been changed to reflect that when the film irradiator ARMS is removed, the film irradiator equipment will be shut down and red taggeJ off. These preventive maintenance procedures for the ARMS are being-incorporated into the Reactor Operations Compliance Check System. The Compliance Check System has an extensive scheduling and tracking system for Technical Specification compliance relating to reactor instrumentation and the reactor safety system. This system is composed of compliance procedures which are approved by the Reactor Manager and reviewed by the Procedures Reviaw Subcommittee (PRSC) of the Reactor Advisory Committee. Any changes to the8e procedutts are nho reviewed by the PHSC as well no by all licensed operators as part of the requalification program.

The scheduhng of pre"entive maintenance for the ARMS has already been moved to the Reactor Operations Compliance Check tracking system. The Reactor Manager and licensed

-operators on stafY are determining if any ether Technical Specification surveillance requirensnts are not currently in the Compliance Check tracking system. As part of this determination, the scheduling of the preventive maintenance for the exhaust stack monitor has ahio txten moved to the Reactor Operations Complitmee Check tracking system, even though review of recorda indicates that specified surycillance requirements for the stack monitor have been met.

Sincerely, h

Yk' bO Walter A, Meyer. r Reactor Manager

/ // 0 ENDORSEMENT:

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Reviewed and Approved bddhhfh!Ifh mggha q g J. Charles McKibben n-Associate Director tcTAny mJouc STATE & ntssard

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00CNCCOUNTY

Attachment:

Fig.1 m cmmucH txp no.14.twI xc w/ene: Regional Administrator, NRC, Region 111 Reactor Advisory Committee Reactor Safety Committee

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DESCfUPTION _

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