ML20141M456

Documents 920806 Telcon W/Nrc Re Senior Reactor Operator Requalification Exam Administered During Wk of 920713. Failed Emergency Scenario Involved Postulated Significant Pool Water leak-rate.Addl Session Re EP Scheduled

ML20141M456
Person / Time
Site:	University of Virginia
Issue date:	08/25/1992
From:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9208280316
Download: ML20141M456 (8)

Text

Gl$EERING f3 August 25, 1992 & APPLIED SCIEN( E

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U.S. Nuclear Regulatory Commission ^!#'""'""""'

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Washington, D.C. 20555

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388598W825559E53H28 Re: License R-66, Docket No. 50-62, for the Universit?8NiNfdlV8*'3 Research Reactor (UVAR).

Subject:

Senior Reactor Operator Requalification Exams Gentlemen:

This letter documents a telephone converWion held on August 6, 1992, from 1: 4 0 PF until 2 : 30 PM, betwee') isrs. Caldwell, Adams, Hankin, and Sartor of the NRC and Messrs. Farrar, Benneche, and Krause ef the University of Virginia Reactor Facility. The reactor director, Dr. Robert Mulder, was away on vacation and did not participate in this conference call. Ilowever, earlier that morning he had had separate telephone contacts with Mr. Caldwell and Mr.

Farrar and was aware of the issues and proposed solutions.

This letter also presents a final averview of the subjects discussed, lists the corrective actions taken and to be taken by the licensee, and includes concluding remarks intended to put several non-applicable " root-cause" hypothesis to rest.

Background:

The subject of the co;.ference call concerned the Senior Reactor Operator (SRO) Requalification Examinations held at the University of Virginia Reactor Facility during the week of July 13, 1992.

The re-examinations were administered jointly by the NRC and a specially designated UVAR staff member who did not need to be

. requalified. Three senior operators took these examinations. They passed the written parts of the exam with higii marks and responded correctly to four out of the five scenarios on the operating part of the exam. Since the failure of one scenario on the operating test was acceptable, the SROs maintained their NRC-licensed operator status, llowever, facility managemelit and NRC examiners l concerns arose based on the same scenario being f ailed by all three SROs.

The failed emergency scenario involved a postulated significant poolwater leak-rate. A key elerent in the response expected by the examiners was the activation of the Reactor Facility's Emergency Plan Implementing Procedures (EPIPs) by each operator. The responsibility for activating the EPIPs rested with the operators since each one was alone (hypotnatically) in the building at the 920B260316 920825 PDR ADOCK 05000062 1h V PDR

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start of the " event." While the operators indicated to the i examiners the immediate actions they would have taken to prevent the pool from draining down to the level of the reactor core, such as starting makeup water to the reactor pool, moving the reactor  !

bridge and core to the end of the pool opposite the leak and '

placing the gate in the center of the pool to isolate the reactor >

in the intact half of the pool, they did not declare an emergency ,

and activate the EPIPs in a timely manner. That-is, they failed to: 1) open a copy of the EPIPa which was readily available to '

them, 2) declaro a state of emergency and assume the (temporary)

• position of Emergency Director, 3) make phone calls (simulation only) to get the remaining reactor staff and support personnel on-site, 4) begin notification of local, state and federal agencies.

The emergency scetario was conceived by the UVAR SRO who served as the licensee representative examiner, in collaboration with the NRO ,

examiner. By quoting to the SROs a high poolwater loss rate, above )

the upper limit set in the emergency plan (EP), use of the EPIps by the operators was elicited. From interviews that ' :onducted with the SRO examiner and the'SROs who took the exam, .t appeara that 1 the operators did.not interpret the requirements of the scenario correctly, believing until too late that the response being called for by the examiners was limited to the " practical" options available to ameliorate the problem of a reactor poolwater leal-They correctly recalled from memory these. actions, which are statt a i in the EPIPs. Belatedly, one of the individuals did point out that j by the time the leak containment actions were to have been taken, 1 the facility would have had its emergency plan active. l The requirement for the senior-most operator present on-site to initiate the EPIPs at the imminence of an emergency -has been covered often in training. This requirement is stated in the Emergency Plan and its implementing procedures. Every staff member has a personal copy of these documents for reference. Since this requn ement has been known to the entire licensed staff all along,

! there is no defensible excuse for the requirement not to have been  !

! followed by the operators during the presentation of the emergency  ;

l scenario. Everyone is in agreement with these facts.

i

! Still, in fairness to the SROs who failed the scenario on this j simple yet key point, I would like to note that during almost all

annual emergency drills the reactor director has been the person L who.has acted as the Emergency Director, declaring the-emergency,

! directing the communications and having oversight over staff l -response, by virtue of his presence on site. Staff response has been limited mostly to simulating the taking of ameliorating l

actions, not handling " paperwork" or notifications which were taken care-of by the director and his secretary.

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! Drill scenarios involving a lone operator at the facility at the

' inception of an emergency has at come up yet, basically for lack i

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of opportunity! Other interesting and worthwhile scenarios were i developed for annual drills held since 1985. Hence, staff has not had a enance to (sorcise during drills for situations where the reactor d! rector ur.d supervisors might be absent. Future drills i will provice an opportunity for staff members with lower seniority to act as emergency directors. (Note: During one past emergency drill the reactor director was postulated absent, so that a reactor

supervisor had to assume the charge of emergency director and i initiating the EPIPs.)

i correctiva hetioast i A formal meeting was held shortly after the requalification examination between the Reactor Director and the reactor staff to

, discuss the implications of the generic scenario failure. All i involved were emotionally taken aback with the- negative development. It was stated by one individual that because the

" event" had been presented during an exam, there had been a reluctance to pick up the procedures and to refer to them. Instead t preference was given to answering the questions posed from memory, although use of references wasn't proscribed during the operating part of the exam. Two of the operators felt that the scenario being played out to them allowed them the option-to start makeisp +

, water to the pool, attempt to take appropriate actions to find and r

seal the leak, and move the reactor to safety, all in short order, thus averting a more serious emergency situation. In the ensuino ,

discussion it was agreed that this " solution" would not have been appropriate, given the conditions presented in the scenario.

i Several requalification sessions have been scheduled to augment training in energency procedures, beginning in September. (Please see a copy of the requalification schedule which is included in attachment.) A different scenario will be presented at each  !

session and different individuals will be assigned to act out the i role of Emergency Director.

Recognizing the opportunity afforded, I have entrusted the SRO in charge of the facility's emergency preparedness to initiate a study to streamline the EPIPs, by suggesting procedures which could be improved, consolidated and perhaps, clininated. Maybe, the EPIPs can be reformatted into a checklist style which would be used more easily. _ Recently, .of ficials .from - the Va. Of fice - of - Emergency Services visited the Reactor Facility to discuss their participation in an upcoming bi-annual drill. They remarked that they_would like to see U.Va. reduce its four reactor-emergency classifications to just two. This would reduce the size of the

, EPIPs and permit their simplification. This _ suggested consolidation of emergency classifications will also be studied.

It must be recognized, however, that actual rework of the Emergency

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l Plan and its EPIPs is a major and lengthy undertaking, which will j require input and review by the U.VA. Reactor Safety Committec l (RSC) and perhaps the NRC.

Concluding Remarks i

1 During the " root-cause" analysis period, now concluded, all

, possible (and impossible) reasons for the generic exam question i

failure were brought up by the reactor staff for consideration.

Potential difficulties with the use of the EPIPs was suggested as 1 a possible cause for the perception of " reticence" by the NRC on 1

the part of certain staff members to declare an emergency. Such

'.'dif ficulties" would be associated with the number of emergency implementing procedures (about 2 dozen) and the complex structure 1 1 (patterned after power reactors) calling for four emergency )

! classifications. Given the large number of procedures, the ability i of a single operator to carry them out in a timely fashion was 1 questioned as well.

l In response to the above, the general opinion among staff is that while the EPIPs could be improved, they are workablo at present.

1 Also, not all of the procedures would be applicable to every j emergency, or have to be executed immediately. If only a single individual were to be present at the Reactor Facility at the start i

of an emergency, the most important action he or che is expected to 2

take would be to initiate the EPIPs, by calling upon the reactor operators to return to the Reactor Facility and lend assistance in

. carrying out the EPIPs. These calls could be done within a 4

reasonably short time, i

As regards the adequacy of reactor staffing, in addition to the 1 current five full-time reactor operators, there is the reactor director, two shop supervisors, a reactor secretary and the U.Va.

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health physics staff which could be counted upon (excluding police, rescue squad and so forth). Compared with other similar U.S.

university reactors, the UVAR is reasonably well and competently staffed. At a good number of academic reactors there are as few as 5

three part-time operators, one usually being a faculty member and the rest students! Currently, all five UVAR operators are SROs, each with many years of research reactor experience.

4 Consideration was given to a possible lack of familisrity by the I reactor staff with the EP and EPIPs. Upon evaluation,-this charge is clearly wrong. All the SROs who failed the emergency scenario participated in the development and/or review of the EP and EPIPs at the time they were being developed by former reactor staff members, in the early 80's. These documents were reviewed several times by the RSC and the NRC. Drills have been held yearly using these documents since December 1985. Prior to' holding the annual or biannual drills, emergency training has been- covered in the operator requalification program. The SROs who missed initiating

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i i the EPIPs during the presentation of the emergency scenario, did in

] fact recollect correctly from memory the principal remedial and i recovery actions called for in the EPIPs for the scenario presented

to them.

While the current operators-in-training may yet have less familiarity than our licensed operators with the EP and EPIPs, a emergency response is a component of the reactor operator training

{ progrem. Exposure to the requalification program training and i further drilling will bring them to an acceptable level of l familiarity.

l Given the many long discussions that have taken place and a proper k self-critical attitude of the staff, the NRC can rest assured the

! reactor emergency preparedness at U.VA. is in good shape. Should '

i an accident occur or be imminent at the UVAR, even with as few as

one operator on-site, calls would be made to bring more support to

! the reactor site, and the appropriate local, state and federal

government agencies would be notified. Certainly, the staff is j well aware of the NRC examiner's comments at his exit interview, to '

the effect that the NHC prefers to receive f also alarms rather than

! tardy notification. Further, it has been made clear that the NRC l would not react regatively should it be told in a follow-up call.

l that additional information obtained by the licensee following the 4

declaration of an emergency had indicated that the emergency j declaration had been made in error.

l There is additional evidence to strengthen NRC confidence in the '

i good state of emergency preparedness at U.VA. . Several months ago,  ;

$ when the reactor supervisors were informed by the U.VA. police of i j a possible phoned threat against this facility,-1, as director, i initiated the EPIPs with all its ramifications. The NRC was duly

} notified, as required. I am confident that had I not.been present

! at the Reactor Facility, the reactor staff would still have taken i all required actions, even had the emergency been of a different j nature.

As a final note, I would like invite NRC representatives to a full-i scale (bi-annual) emergency _ drill currently planned for November,

1992. This exercise will involve off-site support organizations.

l The NRC will be sent a copy of the drill scenario in advance.

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(page 6, SRO Hequalification, cont.)

I believe that this letter will permit principal questions examinations. raised in connectionthe withclose-out of the the requalification the NHC, Should there be a need for additional follow-up by I am available at (804) 982-5440.

Sincerely,s Ii j);

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Robert U. Mulder, Director U.Va. Reactor Facility &

Asst. Prof. Nuclear Engineering j...

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hequalification Program Schedule cc:

U.Va. Reactor Safety Committee UVAR Staff Mr. Al Adams, Regional Administrator,Projcct Manager for U.VA., USNRC, Wash.

USNRC Region II, Atlanta, Ga. D.C.

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August 21, 1992 .

Mero To Reactor Operations Staff  !

2 From: J.P.Farrar '

Subject:

Reactor Operator ikqualification Lectures The Reactor Operator Roqualification Program for the U.Vn. Reacts Facility requires that the followirg subjects be covered in a lecture ceries, a) Norml Operatirg Procedures b) Abnorm 1 ard D'crgency Procedures c) Tochnical Specifications d) Plant Instrurentation e) Reactor Protective card Safety Systems f) Radiation Control aM Safety g) Reactor Thoory ard Plant Operating Characteristics h) Any Charges to Procedures cr Dguipment To meet these requirements a serica of lectures will be conducttd for ard by those irdivjduals holding RO/SRO Licenses on the UVAR reactor ard those

, trainiry to obtain a licenFe. These lectures will normlly be held on Morday afternoons at 2:00 P.M. on the dates irdicated ard should last approximtely one horr. The individual corducting each lecture should also prepare a comprehensive outline of the mterial covered for uso during their presentation. This outline will then be placed in a permnent file documentirg our roqualification program. The preparation of visual aids is highly desirable '

wherever apptxpriate. '

Lechires for chames to procedures, equipment, etc. will be scheduled as '

necessary.

Date Presenter Subiect 9-08-92 Benneche, Piccolo Dretyency/ Security /H.P. reorientation 9-14-92 Krause, Mulder Dmrgency Proccdures (Scenario) 9-21-92 Krause, Mulder Dnergency Procedures (Soenario) 9-28-92 Krause, Itilder DTIgency Procedures (Scenario) 10-05-92 Krause, Muld3r Dmrgency Procedures (Scenario) 10-19-92 Farrar Stardarti Operatirg Procedures, (SOP 2,3,4) 11-09-92 Hosticka Stardard Operating Procedures (SOP 5) l l 11-23-92 Benneche Standard Operatirg Procedures (SOP 6) 12-07-92 Krause Standarti Operating Proccdures (SOP 7,8) 1-11-93 Scheid Stardanl Operatirg Procedres (SOP 10,11,13)

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1-18-93 Doyle Technical Spccif3 cations (Scctions 2 & 3) 2-08-93 Farrar Technical Specifications (Sections 4,5,6) 2-22-93 llosticka Instrumatation & Safety Systems ,

, 3-08-93 Krause &crgency Plan & Procedures 3-22-93 Benncdle WAR Safety Amlysis 4-12-93 llosticka Reactor 'Ihcory & WN1 Omractoristics i

, 5-10-93 Farrar Entgency Cooling Systan '

June or July - Annual Roqualification D:am 9

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