ML20197J792

Responds to Violations Noted in Insp Rept 50-083/86-01. Corrective Actions:Suppl to 50.59 Evaluation/Determination 85-17 Generated to Meet 10CFR50.59(b) Requirements.Full Compliance Will Be Achieved by 860615

ML20197J792
Person / Time
Site:	05000083
Issue date:	04/17/1986
From:	Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL
To:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8605200172
Download: ML20197J792 (3)

Text

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a$ r a^' ***c= NUCLEAR FACILITIES DIVISION ca, VERS.ET90N. REACTOR MANAGER l

NUCLEAR REACTOR BUILDING UNIVERSITY OF FLORDA . .

GAIMESVILLE, FLORIDA 32611 e .

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, , , 12. April 17,1986

) ;a a United States Nuclear Regulatory Commission Region II 1 01 Marietta Street, N.W.

Atlanta, GA 30323 Attention: Roger D. Walker Director, Division of Reactor Projects Re: Inspection Report No. 50-83/86-01 (Inspector Paul Barnett)

Dear Mr. Walker:

Inspection Report No. 50-83/86-01 cites our facility with a Severity Level IV violation for failure to maintain adequate records of the safety evaluation (50.59 Evaluation #85-17 dated 4 October 1985) made to support modification of the UPTR control blade shrouds which involved cutting of inspection ports in the shroud spacers.

Admission of the Alleged Violation Unreviewed Safety Question Evaluation / Determination Number 85-17, "UFTR Shroud Spacer Cutting Alteration For Ease of Blade Inspection" is considered to have insufficient documentation that the protective (safety) function of the shrouds as delineated in Paragraph 4.1.1 of the Safety Analysis Report and the Technical Specifications in Paragraph 3.2.1 (1 ) had been adequately considered in concluding that the modification did not involve an unreviewed safety ques-tion. Information provided by Mr. Whaley (Reactor Manager), Dr. Ohanian (Chairman, RSRS) and Dr. Vernetson (Facility Director) shows that the proper SAR and TS references were considered as part of the 50.59 review, specifical- ,

ly, the protective function of the shrouds was carefully considered at the >

RSRS meeting where 50.59 Evaluation / Determination Number 85-17 was approved.

Nevertheless, we acknowledge not all.of this information had been provided as part of the supporting documentation for this modification review. Therefore, the violation citing lack of completo documentation is admitted though it is clear the proper reviews were made, simply not fully documented. The UFTR staff and RSRS members all agree there is no unreviewed safety question in-volved in this modification; the violation addresses only the failure to do-cument all items considered as part of the review - namely, that the protec-tive ( safe ty) function of the shroud is not compromised.

8605200172 860417 PDR Reasons For The violation G ADOCK 05000083 PDR 1

The failure to provide sufficient documentation of the shroud spacer modifica-tion is attributed to lack of sufficient detail about required documentation in the requirements of UFTR SOP-0.4, "10 CFR 50.59 Evaluation and Determina-tion" used to control and document reviews of potential unreviewed safety questions. This inadequacy led to insufficient notes from which the documenta-tion of review was generated. As a result one part of the evaluation process l

was not adequately documented.

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I Roger D. Walker April 17,1986 Page Two Corrective Steps Taken/Results Achieved The 50.59 Evaluation / Determination Number 85-17 was reviewed again at the first RSRS meeting on February 27, 1986 held following the NRC inspection which concluded on February 21, 1986. At that time the Subcommittee considered the Inspector's concerns expressed in the exit interview and reaffirmed its earlier finding that no unreviewed safety question was involved in the modifi-cation and documented that part of the basis for the decision is that the shrouds do continue to fulfill their protective (safety) function.

In a memorandum dated March 31, 1986, a supplement to 50.59 Evaluation / Deter-mination No. 85-17 was generated. This supplementary documentation was re-viewed at the RSRS meeting on April 17, 1986 and is considered to meet the 10 CFR 50.59(b) requirements that the licensee maintain records of changes made in the facility pursuant to 10 CPR 50.59(a).

Corrective Steps To Be Taken To Avoid Further Violations UFTR Management and the RSRS are committed to providing proper documentation of 50.59 evaluations / determinations. The incomplete documentation resulting in the cited violation is considered to be a relatively rare event considering the dozen or more 50.59 reviews inspected during the February 18-21 inspec-tion. Nevertheless, corrective action is in progress to assure this lack of documentation of items considered does not recur. In addition to the recon-sideration of Safety Review No. 85-17 by all parties and extensive discussions of the violation and its basis cited in Inspection Report No. 50-83/86-01, a revision of SOP-0.4 "10 CFR 50.59 Evaluation and Determination" is being de-veloped. This revision will include a requirement that a simple list of items considered in the 50.59 review be attached to each 50.59 review package to document all items considered. Therefore, SOP-0.4 will be revised to require that this list be generated for all 50.59 reviews calling specific attention to pertinent sections of the UFTR Safety Analysis Report, the Technical Speci-fications and/or Standard Operating Procedures to assure complete documenta-tion of 50.59 reviews.

Date When Full Compliance Will Be Achieved The specific violation cited is lack of full documentation for 50.59 Evalua-tion / Determination Number 85-17. With the generation of the documentation dated March 3, 1986 as a supplement in the original 50.59 evaluation, the necessary documentation now exists indicating that the protective function of the shroud was considered in the safety review of the modification. As to the corrective steps to be taken to avoid further violations, the revision of SOP-0.4 will be generated, approved and implemented by June 15, 1986. This revi-sion will be entirely adequate to assure this situation does not recur. There-fore, full compliance will be achieved by June 15, 1986, though the supplement to Evaluation / Determination Number 85-17 has already assured compliance in the one problem area.

e Roger D. Walker April 17,1986 Page Three Exit Interview Commitments As committed in the exit interview:

1. SAR Paragraph 7.2.3 on Non-Nuclear Instrumentation is being rewritten and will be revised as recessary by August 31, 1 986.

2. The CORA diffusion theory calculations for UFTR core fluxes will be re-viewed for proper identification of material regions and the SAR revised as necessary by August 31, 1986.

3.. The storage and potential release of Wigner Engery is not addressed in the UFTR SAR. This is not considered to be of signficant concern for the fluxes in the UFTR graphite regions. Nevertheless, the UFTR management is committed to evaluating the storage and potential release of Wigner Ener-gy in this graphite by May 31, 1987.

We trust this response satisfies the requirements delineated in the inspection report. If there are further questions, please advise.

Sincerely, h .

I William G. Vernetson ~

Acting Director of Nuclear Facilities WGV/ps cc: P.M. Whaley G.S. Roessler Reactor Safety Review Subcommittee (RSRS) 4 i