ML20150F318

Responds to NRC Re Violations Noted in Insp Rept on 880324.Corrective Actions:Immediate Check of Review Dates on All Procedures & List Made of All Mods of Any Type

ML20150F318
Person / Time
Site:	05000192, University of Texas at Austin
Issue date:	04/22/1988
From:	Bauer T TEXAS, UNIV. OF, AUSTIN, TX
To:	Callan L Office of Nuclear Reactor Regulation
References
NUDOCS 8807180231
Download: ML20150F318 (13)

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COLLEGE OF ENGINEERING -

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A . A .L k THE UNIVERSITY OF TEXAS AT AUSTIN

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\ DepartmentofMechanicalEngineering NudearEngineeringProgram. Austin, Texas 78712-(312)471-3136 p.p April 22, 1988 Mr. L.J. Callan, Director i Division of. Reactor Projects !l Nuclear Regulatory Commission ( B27E p 611 Ryan Plaza, Suite 1000

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Arlington, Texas 76011 Re: Docket 50-192

Dear Mr. Callan:

The enclosed report is provided for the inspection notice of violation dated March 24, 1988.

-An attachment of draft documents that supported the immediate response of the licensee to the referenced items is also included.

Please note that the licensee is experiencing the very unusual situation of construction, operation and dismantling acitivities at various stages of planning, implementation and completion. Curtailment of present routine operation activities are planned for April 29, 1988 with cessation of all operation by May. 29, 1988. The licensee continues to incorporate numerous improvements in the docket 50-602 facility that are identified or recognized docket 50-192 deficiencies.

Sincerely, A 2. E-Thomas L. Bauer Assistant Director Nuclear Engineering Teaching Laboratory TLB:dlw Enclosures (Items 1,2,3 64) cc: D. Klein H. Marcus l

8807180231 DR 880422

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1. - I Letter of Reply to Notice of Violation

' Univ. of' Texas. Docket 50-192' TRIGA Mark I Operating License 50-192

1. Reason for. violation items A and B-

. The. violations identified by the inspection report Har 24, 1988 were ,

the indirect result-of the development of multiple Technical-Specification ~ l documents during the period January 3, 1930 to November 9,.1984. The original document was in effect February 10, 1980 at the time of the license renewal request (docket 50-192) ._ The current docun ent was in effect July 29, 1983 at the issuance of the license renewal. Development of another document began in the subsequent months for the license application (docket 50-602) dated Ncvember. 9,1984. The latter two documents contained several changes to the administrative commitments from the~ original document. Unfortunately, the latter two documents also contain minor differences caused by different guidance material during the development' process. The first document was developed from another licensee's document while the latter used the guidance of the ANS standards more directly, as well as the example of other licensee's documents. This series of sequential Tech. Specs. developments thus led to less than adequate (timely) attention to the-details of the applicabic document and perhaps confusion on the part of the staff responsible both for development and implementation of the documents. A contributing factor was the lack of a one-to-one correspondence of the applicable Tech. Specs. with procedures.

written from previcus Tech. Specs.

The delay of actions by the licensee during the 41.5 month effective time for the original to current Tech. Spec. document development for docket 50-192 allowed the subsequent development of Tech. Specs. for docket 50-602 to interfere with the licensee's proper attention. It should be emphasized that the corrective action most important to these violations is the avoidance of a multiple commitment to license documents. This is

- clearly a one-of-kind situation that is expected to entst only during the existence of the University's commitment to two docket activities. The licensee will also be cctively changing the Tech. Specs. during the next 6 months to represent the shutdown condition of the Facility. No facility critical operation is planned after May 29, 1988.

2. Corrective steps and results Iten A An immediate check of the review dates on all procedures and a list was mcdc of all modifications, of any type. A list was made of all changes and is to be submitted to the reactor committee for review at the next scheduled meeting. Changes were classified as typographical (5),

clarification (3), and substantive (8). All substantive changes werc conservative changes or corrections to procedure supplements and not the l procedure itself.

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An immediate review by staff of section 6.5 items was made to determine which items were explicitly addressed.by procedures, which. items' were implicitly addressed by ranufacturer documentation and which items were not addressed by.either.

An alarm response procedure has been written and will be submitted for review by the reactor' committee. A routine maintenance procedure has been draf ted to identify applicable subject equipment.- Action an this procedure is expected to be deferred indefinitely since pending facility shutdown 4 - will probably negate the idea of "routine maintenance". No major routine maintenance items.were identified that impact safe operation. Transient rod-inspections and instrumentation and control system calibrations are already applicable procedures.

Item B.2 The positive period method used by the license is a variation of a method specified in an approved experiment. A specific procedure is being prepared to be applied at the docket 50-602 facility. This procedure will be reviewed and applied, if necessary, at the docket 50-192 facility.

Facility activities are expected to shutdown the docket 50-192 operation before the calibration procedure would be applicable. An amendment to the Tech. Specs, is planned.that would remove this specification and others that directly relate to reactor operation.

3. Corrective steps to avoid future violation

- Item A A procedural control has already been drafted for use with the docket 50-602 activities, its use on the 50-192 activities will be examined. The procedures after committee review will be redated with revised dates to reflect the current status. A procedure drafted to address the issue of procedure controis has been reviewed, and a e.odified form will be submitted to the committee for review. A version of this procedure with a slight modification will be implemented for the remainder of the anticipated license period for the docket 50-192 activities.

Item B No corrective action is proposed to prevent reoccurrence of this violation since a review and implementation of the appropriate procedures will resolve the deficiency. However, a nethod will be examined to better coordinate correspondence between the Tech. Specs. requirement with the applicable procedure. This coordination is already being applied to docket 50-602 activities.

4. Date for full compliance Item A

! Compliance of the items of part A are scheduled for a reactor committee meeting on April 29, 1988.

Item B Compliance of the items of part B are scheduled to be completed within a period determined by the "routine" requirement and the procedure applicability. This time period was chosen so that the Tech. Specs. can be j amended to reflect the shutdown condition of the reactor core prior to the

impicmentation of fuel shipment and facility dismantlement. The last i

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scheduled day for operation of the R-92 facility at full power is May 29, 1988.

Item B.1 Compliance with item B.I. will be effective the date of the April 29, 1988 meeting.

Item B.2 Compliance with item B.2. is scheduled for the next applicable calibration or the c.hange of Tech. Specs. to represent a shutdown facility condition.

This period will be less than 6 months (probably 90 days) after the next scheduled reactor cor:nittee meeting.

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. Item 2 Typographical. Corrections To Technical Specification Required Procedures

1. Procedure: Procedure For Determination.0f Reactivity Insertion Rates, Shutdown Margin, And Excess Reactivity Section: 3 Line 1 Original: Measurement of shutdown margin *(<.2% dK/K/sec):

Revised: Heasurement of shutdown margin *(>.2% AK/K):

2. Procedure: Procedure F5r Fuel Movement Section: 6, Step e, Line 2 Original: ... number shallbe plotted ...

Revised: ... number shall be plotted ...

3. Procedure: Appendix - Fuel Measurements Section: 3, Line 1 Original: ... to maximum bridge balance Revised: ... to maximum; bridge balance Sectfon: 8, Line 1 Original: ... to five position Revised: ... to fine position

4. Procedure: Procedure For Semi-Annual Measurement Of Rod Drop Times Section: 6, Step b, Line 1 Original: . . . terminal 16 to Revised: ... terminal 5 to

5. Procedure: Console Calibration Check Section: VII, Part C, Instruction 6, subpart a Original: 0.00001 molar kcl Revised: 0.0001' molar kcl Solutions used contain 7.465 mg/l KC1=0.0001 M KC1 Section: IX, Part B, Line 2 Original: ... using XA4TP Revised: ... using XA4TP1 Section: IX, Part B, Tests 2 and 5 Original: 2. 4.175 + 0.003 V DC S. 7.083 + 0.018 V DC Revised: 2. 4.715 I 0.03 V DC

5. 7.018 I 0.018 V DC 1-T

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Clarifications Added to Technical Specification Required Procedures

1. Procedure: Procedure For Semi-Annual Measurement Of Rod Drop Tines Section: 5, Step 2 Original: ... terminal #16.

Revised: ... terminal #17.

Section: 5, Step b Original: ... terminal #4.

Revised: ... terminal #5.

Section: APPENDIX, Channel A Original: Probe to terminal 16 Revised: Probe to terminal 17 Sectios.: APPENDIX, Channel 13 Originat: Probe to tereinal 4 Revised: Probe to termina) 5 Justification: Actuci Test Points Not changed, only numerical reference to point changed ro reflect clarification of label assignments discovered during detailed circuit traceing activiti2s.

Section: APPENDIX: Third set of instrui:tions Original: Cet trig RESET SINGLE Perform drop hevised: Set trig RESET SINGLE Set view CilANNEL A Perform drop 1

Section: Appendix '

Original: none, add note Revised: Note - Float Oscilloscope Power

- Crcund Oscilloscope to Rod Drive Chasis

2. Procedure: Console Calibration Che.

Section* I, part C Original: Unchanged, add nor.e L ow Revir.ed : Note: 1.og compercation voltage jack - J2C, Adjustment Pot.-R3 Linear compensation voltage jack-J2D, Adjus* ment Pot.-R4

• ction: II, Part D

.inal: unchanged, add note below ed: Suggested Equipment - Keithley Current Source (gtounded)

Keithley Micro-Hiero Ammeter (float ground)

Test Junction Box iction: III, Parts A thru D; V, Parts A thru D; VI, Parts A thru G; (Oy "III, Parta A and D y$f

@ f] Original: Entire sections as uritten

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Revised: Insert the following statement at the beginning of each-section - Completion of this section not required - Use discontinued ~or function duplicated during system upgrade.

'Section: VII, Part B, Instruct!on 3, line 1 Original: ... control R508 with ...

Revised: ... control R23 with ...

Section: VII, Part B, Instruction 4, line 1 Original: ... control R506 with ...

-- Revised : .., control 321 with ...

Section: VIII, Part B, Instructioti 1, Subpart c Original: As written Ravised: Add - Note: TC Element #5981 only has two functioning thermocouples Section: VIII, Part B, Instruction 2 thru 12 Original: As written Revised: Delete - Instructions 2 thru 12 in entirety ,

Add _ 2. Using DC voltage supply, such as Keithley M1111 volt Potentiometer 6 adjust voltage supply for signal representins 500 C from a chromel-alumel Thermocouple accounting for cold junction compensation in pyrometer Example: Vrequired = V(500 C) - V(ref) 19.8mv = 20.64 mv - 0.84 mv with reference junction temp of 21 C

3. Disconnect thermocouples from terminals 6, 7, 8, & 9 of TB1, verify pyrometers indicate full scale scrammed mode.

4. Connect voltage source to terminals for each meter, V=_, mV Meter Te rminal Polarity Right 6 +

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Left 8 +

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5. Read Pyremeters Left ,C, Right C

6. xeconnect thermocouples and compare fuel temperatures to reactor tank water temperature -

Water C, Left C, Right ~C

7. Verify fuel temperature trip level set at + 450 C Left trip C, Right trip C Section: IX, PL . A, Instruction 6 Original: ... meter deflection. __ x 10 -3 amgg Revised: ... meter deflection (125%).

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10 amps Suggested equipment: Harrison Meter Calibrator (float groun )

Beckman Voltmeter Test Junction Box 2-C

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m Section: IV, Part D, Instruction 2,3, and 4 Original: 2. ... A7TP2/S7 ...

3. ... A8TP3/S8 ...

4. .... A4TP3/S8 ...

Revised: 2. ... XA7TP2/S7 ...

3. .. .. XA8TP3/S8 ...

4. ... XA4TP3/S8 ...

Section: IX, Part D, Instruction 5 Original: 5 ... A4TP3/S8 Revised: 5 ... XA4TP3/S8 Add - Note: Source trip voltage level may be verified as.

>2 cps by the following process:

Pull source, connect pulse counter to J5. Count for 10 min. True CPS = measured CPS +-1200. If ,

XA4TP3 voltage with the source out is less than 1.5V and the true count rate calculated io greater than 2 cps, the source trip is at a level > 2 cps.

3. Procedure: Procedure for weekly calibration of area radiation monitors Section: Step 2, Line 2 Original ... Adjust each reading to <$00 volts as necessary Revised: ... Adjust each reading to the measured plateau as necessary Section: Step 4, Line 1. .

Original: ... in the Instrument Calibration ... obtained in #2 above Revised: ... in the Weekly Instrument Calibration ... obtained in step 3 Section beep 5, Line 3 Original: Lag this in the Instrument Calibration Log.

Revised: Log the alrvm icvel in the Weekly Instrument Calibration Log

4. Procedure: Control rod inspection procedure Section: Step 9, Line 2 Original: ... by prompt drops. ,

Revised: ... by prompt drops or positive period, l-

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Minor Substanative Changes to' Technical

! Specification Required Procedures L

1 L 1.. Procedure: Procedure For Fuel Inspection And licasurement l

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Section: 4, Line 1 Step b Original: Two' persons ...; b. One person Revised: ~Three persons ...; b. Two persons Justification: Change to more conservative condition

2. Procedure: Console Calibration Check Section: VII, Part A, Instruction 4, lines'3, 4 Original: ... HI range = 0.00005 pc/ce, 1 mr/hr; the to range = 0.005 pc/cc, 10 mr/hr.

. Revised: . . . III range = 0.00125 pc/cc, 2.5 mr/hr; the LO range =

0.0125 pc/cc, 25 mr/hr.

Justification: Reevaluation due to det ector aging and shif t of high volteFe plateau

3. Procedure Procedure for weekly calibration of area radfarfon monitors Section: Step'1, Line 1 Originals ... the 1 pc/2.5 pc radium ... test stand from the CAM drawer.

Revised: ... the 10 pc/0.8 pc radium ... test stand.

Justification:'Use of inrger test source resulto is more accurate point source approximation since source to detector distance for 81ven count rate is increased.

Section: Step 3. Line 1 Original: ... each of the first four ... with the 8.5 pc Revised: ... each of the four ... with the 10 pc Justification: Same as for Step 1 Line 1 Section: Step 5, Line 1 Original: ... of the five C/M ...

Revised: ... of the four G/M ...

Justification: Reflects actual number of detectors available as stated in Step 3.

4. Procedure: Emergency Plan Section: St. Emergency Call List, Emergency Contacts #1 and #2 Original: 1. T.T. Bauer Reactor Supervisor 471-5136 345-5044

2. M.G. Krause Senior Reactor Operator 471-5136 259-1355 i Revised: 1. T.L. Pauer Reactor Supervisor 471-5787 345-5044

2. M.C. Krause Senior Reactor Operator 471-5787 255-1355 Justification: Reassignment of secondary facility phone number to primary facility phone number, original primary phone number retained by facility di .ctor at reassigned office.

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Section: St. Emergency Call List, Emergency Contacts #5 & #6 ,

_ original: 5. D.H. Eppes Nuc1 car Technical Specialist 471-5136 448-4681

6. D.G. Decker Safety Engineer 471-3511 305-5914 Revised: 5. D.G. Decker Safety Engineer 471-3511 345-5914 Justification: Reflect change in personnel

' 5.; Procedure - Power Calibration Procedure, least-squares Linear Fit Section: 2, numerator of n term Original: EX ggY - IXg EY g Revised: EX Y - EX (EYg )/n

-Justification: Corrhetion of error in least squares curve fit equation 6, Procedure: Semi-annual Tests of Minimum Interlocks'and Safety Circuita Section: Step 10, ifne 2

. Original: zero adjustment.

Revised zero adjustment. Alternate method: Adjust % PUR zero control to give indicated reading at 10%.

7. - Procedures with no date in index

8. -CAM PROCEDURE - new solid state model r

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a Itta 3 Alarm Response Procedure INSTRUCTIONS:

1. Identify alarm.

2. Check system status.

3. Verify action level.

4 Take action specified.

EVENT:

ALARM - Area Monitor (Any 1 of 4)

CHECK - Identify radiation source end level with available equipment Take necessary steps to limit radiation exposure ACTION LEVEL - Measured Dose > 100 rR/hr, unknown source ACTION - Shutdown Reactor, Evacuate Reactor Room ALARM - Continuous. Air Monitor CHECK - Identify potential radiation source ACTION LEVEL - Countrate > 2000 CPM, unknown source ACTION - Evaluate CAM performance, monitor system closely ACTION LPVEL - Countrate > 5000 CPM, unknown source ACTION - Shutdown Reactor, Evacuate Reactor Room ALARM - Pool Water Activity CHECK - Verify meter nero, lo sensitivity mode, and/or switch purification suction from skimmer to direct ACTION LEVEL - Water Activity > 0.0125 pCi/cm 8 ACTION - Moniter CAM and other systems for abnormal radiation levels ALARM - Pool Teeperature CHECK - Observe installed instrumentation or reanure Fample With therremeter; do not place mercury thermometer directly in pool ACTION LEVEL - Water Temperature > 48 C (120 F)

ACTION - Initiate Pool Cooling or Shutdown Reactor ALARM - Pool Level CHECK - Visually observe pool level ACTION LEVEL - Water Level < 4.5 m (15') above top grid plate ACTION - Initiate Pool Fill or Shutdown Reactor ALARM - Heat Exchanger Differential Pressure CHECK - Observe setpoint and functico of differential pressure sensor, check for abnormal pressure indications in flow lines.

ACTION LEVEL - AP < 7 kPa (1 Psi)

ACTION - Adjust System Pressure or bhu Jewn Heat Exchanger l

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Procedure Title NETL Procedure Outline and Control line 8 Revision Date: 9 e 4/88 line 9 Personnel: administrative, supervisory operator, line 10 senior operator, reactor operator, research, faculty, assistant, technician, or student. _

Componento: equipment, instruments, or materials, line 15 safety devices, special tools, measurement instruments, calibration standards.

Supplements: methods to perform calculations, line 20 specific manuals, basic data tables, data sheets, forms, logs.

Prerequisites: other procedures or tasks, line 25 special physical conditions.

Instructions: line 30 1.- Identify procedure by descriptive title, date of original or latest revision, end the procedure page number, (ADM - 1).

2. Determine responsible person for the procedure. Classification of personnel required to perform the procedure is to be specified.  :

3. Ansemble applicable components for the procedure. Documentation of components required to complete the procedure is to be provided.

4. Locate the informetion reh,ted to the procedure. Sources of information applicable to c e procedure should be compiled.

5. Verify the proper prerequisites for the procedure. Assurance of proper conditions for the procedure should be determined.

6. Follow the procedure instruction steps. Deviations from the procedures should not alter the substance or intent of the procedure.

7. Document temporary or permanent changes to a procedure. Notes on procedures are for guidance only. A change log documents changes.

a. Temporary changes or minor changes require epproval of a senior operator. Record procedure page, effective date, initial, and change in the procedure change icg.

b. Permanent changes or major changes require review by the reactor committee. Revise and reissue the procedure by reprint with the changes end che revision date.

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0/N *~9*0' Record of Procedure Cha.nges Pnge Date Initial Change .

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