ML20205N410

Responds to Violations Noted in Insp Rept 50-083/87-01. Corrective Actions:Notice Describing 10CFR19 & 20 Requirements & Stating Where Info Can Be Found Posted

ML20205N410
Person / Time
Site:	05000083
Issue date:	03/19/1987
From:	Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8704030020
Download: ML20205N410 (11)

Text

y NUCLEAR ENGINEERING SCIENCES DEPARTMENT Nuclear Reactor Facility University of Florida I

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• h Gainevine,FlorH 32411 March 19,1987 *

• Phone (904)392-14M Tolos$4330 United States Nuclear Regulatory Commission Region II 101 Matietta Street, N.W.

Atlanta, GA 30323 Attention: J. Nelson Grace Ragional Administrator Re: Inepection Report No. 50-83/87-01 (Inspector B.K. Revsin)

Dear Mr. Grace:

This report is divided into two parts to address the two violations cited in Inspection Report No. 50-83/87-01.

A. Inspection Report No. 50-83/87-01 cites the UFTR facility with a Severity Level V violation for failure to conspicuously post 10 CFR Parts 19 and 20 or post a notice describing the documents and stating where to find them Contrary to 10 CFR 19.11 requirements, on February 9-11, 1987, 10 CFR Parts 19 and 20 were not conspicuously posted nor was a notice posted describing the documents and statigg where they may be examined.

1. Admission or Denial of the ViNlation On the dates referenced,10 CFR Parts 19 and 20 were readily avail-able in the documents cabinet in the UFTR control room as part of a bound volume of 10 CFR Parts 0 to 199. Although Parts 19 and 20 were not separately posted, they were available to all individuals work-ing in the f acility. However, they were not conspicuously posted and no notice was posted describing the documents and stating where they could be examined. Therefore, the violation citing failure to post 10 CFR 19 and 20 is admitted, though it should be noted that the documents were available as part of a bound volume of regulations in the control room.

2. Reasons tor the Violation 1

The failure to comply fully with the requirements of 10 CFR 19.11 is i due to an oversite in failing to comply with the verbatim posting I requirements of 10 CFR 19.11 in that having the bound volume of 10 i CFR Parts 0 - 199 was considered to be meeting the posting require-ments.

3. Corrective Steps Taken/Results Achieved Prior to the conclusior. of the inspection on February 11, 1987, and l after consultation with Inspector Revsin, the posting requirements l of 10 CFR 19.11 were carefully revie"ed. Immediate corrective action was taken on February 11, 1987 to meet all posting requirements of 10 CFR 19.11 to include posting a notice describing 10 CFR 19 and 10 CFR 20 and statinn where they could be examined.

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.- o U.S. Nuclear Regulatory Commission March 19,1987 Page Two In addition, a quarterly surveillance data sheet (Q-6) has been gen-erated to assure meeting all 10 CFR 19.11 posting requirements. This Q-6 surveillance data sheet was first used on February 25,1987 to control posting of the Notice of Violation from Inspection Report 50-83/87-01 to demonstrate d2at this surveillance is implemented and effective at assuring 10 CFR 19.11 posting requirements are met. l

4. Corrective Steps to be Taken to Avoid Further Violations No further corrective steps are considered necessary, s

5. Date When Full Compliance Will be Achieved Full compliance was achieved on February 11,.1987. Final review and approval of the Q-6 surveillance data sheet form by the Reactor j Safety Review Subcommittee was concluded on March 12, 1987 to assure ;

the Q-6 surveillance is effective to preclude recurrence of this ,

violation. The Q-6 surveillance data. sheet will be installed in all SOP manuals by April 30, 1987.

B. Inspection Report No. 50-83/87-01 cites the UFTR facility for a Severity Level IV violation for failure to follow Technical Specification 6.3 re-quiring that the facility be operated according to University of Florida Training Reactor (UFTR) Standard Operating Procedure D.2, " Radiation Work Permit," Revision 9, approved May 16, 1985. The notice of violation cites failure to follow SOP-D.2 in six (6) areas as follows:

1. An index of radiation work permits (RWP) was not maintained in the RWP Notebook. ,

2. The initiation of RWP No. 86-14-I and the termination of RWP Nos. >

86-14-I and 86-12-II were not noted in the UFTR Daily Operations ,

Log.

3. RWP survey results were not recorded on RWP Nos. 85-22-II, 86-7-I, 86-8-I and 86-17-II. i

4. RWP survey measurements performed in 1986 did not include instrument name, serial number, distance from the measured object and the name of the individual performing the measurements.

5. RWP Nos. 86-10-I, 86-12-II and 86-14-I were not terminated within seven days of initiation.

6. RWPs issued in 1986 were not signed by both the senior reactor op-erator and the reactor manager.

These parts of the violation will be addressed individuully.

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U.S. Nuclear Regulatory Commission March 19, 1987 Page Three

1. An index of radiation work permits (RWP) was not maintained in the RWP Notebook.

a. Admission or Denial of the Violation The violation is admitted.

b. Reasons for the Violation The RWP index was not maintained because SOP-D.:2 does not have an index form associated with it. Coupled with the historical lack of index prior to Revision 9 of SOP-D.2 based on the mini-mal need for use of the procedure, the need for the index was overlooked in the review of the procedure. . The need for the in-dex was not detected because there was no checkoff item on the RWP Form SOD-D.2A to indicate entry of data on the RWP index.

c. Corrective Steps Taken to Date/Results Achieved An index for the 1984 through 1987 RWP logs has been generated and placed in the respective notebooks. The 1987 RWP index was developed and implemented on February 11, 1987. Indices for 1985 and 1986 were developed as of 16 February 1987. Minor cor-rections were completed as of March 16, 1987.

Training has been conducted on the existing SOP-D.l2 for all li-censed operators. Several RWPs generated and used since the in-spection have been entered properly in the 1987 index.

The generation of the 1987 index assures this violation item will not recur. In addition, a complete revision of SOP-D.2 has been generated to include an index form and a review space on the RWP form to assure complete index entries. While this SOP is in review for approval, training has been conducted for all facility operators to assure the index is used and verbatim compliance is followed with the existing Revision 9 of SOP-D 2.

d. Corrective Steps to be Taken to Avoid Further Violations A draf t version of Revision 10 of SOP-D.2 is under review. After Revision 10 is approved, training be conducted and this Revision 10 of SOP-D.2 will be implemented. With implementation of Revision 10, this violation will be assured not to recur and all corrective actions will be completed, w________

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U.S. Nuclear Regulatory Commission March 19,1987 Page Four

e. Date of Full Compliance Full compliance was achieved on 16 February 1987 when indices had been completed in the RWP Log Notebooks for 1985,1986 and 1987 with the 1987 index maintained since February 11, 1987.

Training will be conducted on the approved Revision 10 of SOP-D.2 and Revision 10 will be implemented by April 30, 1987.

2. The initiation of RWP 86-14-I and the termination of RWP Nos. 86 I and 86-12-II were not noted in the UFTR Daily Operations Log.

a. Admission or Denial Although no work controlled by RWP 86-14-I was ever initiated, the portion of the violation dealing with the initiation and termination of 86-14-I is admitted. This condition was not clear, especially since Revision 9 of SOP-D.2 has no provision for separate filing of approved but not issued RWPs.

Since RWP 86-12-II was not logged on the Daily Operations Log, this portion of the violation is admitted.

b. Reason for the Violation Although approved by the Radiation Control Officer and given an RWP Serial Number, records indicate RWP 86-14-I was never used to control any work. The work that would have been accomplished (had RWP 86-14-I been used) was accomplished under different RWP numbers.

No distinction exists in UFTR SOP-D.2, Revision 9, concerning approval of the conditions specified by an RWP, issuance of an RWP number, and approval to start the RWP-controlled work. Due to the administrative structures of the UFTR and University of Florida Radiation Control Office, approval and issuance of an RWP may occur on different days. With the potential for these functions to occur at different times, approval and issuance are clearly separate functions, though not clearly delineated on the current version of SOP-D.:2, which is recognized to need clarification in this regard. RWP 86-14-I was approved for use on July 22, 1986 to control installation / removal of the incore Rapid Sample Insertion (Rabbit) Assembly. Although approved for use, no exposure record is associated with the RWP because the work of installing and testing the new system was performed at a later date under RWP 86-15-II. Note RWP 86-14-II was issued in the interim on August 13, 1986 for other unrelated work. Shielding surveys were also performed under RWP 867 1 II; RWP 86-19-II was later usod to remove and replace the  !

rabbit for further testing. So no record of the use of RWP 86-14-I exists. In effect the RWP was not issued, and therefore

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i not entered or terminated in the Daily Operations Log, although physically placed in the RWP Log. While filed in the RWP notebook, RWP 86-14-I should have been marked unused to avoid confusion.

The failure to log termination of RWP 86-12-II was a personnel error. With special training conducted on verbatim compliance, this type of violation should not recur. With the generation and approval of a revised SOP with a checkoff to assure full RWP termination, the quustion of use of an RWP will be clear in the future.

c. Corrective Steps Taken/Results Achieved RWP 86-14-I has been properly marked as unused in the 1986 RWP log notebook and its index. Revision 10 of SOP-D 2 is under review to address differences of issuance versus approvalof RWPs and how to handle RWPs that are approved but not issued for controlling actual work.

RWP 86-12-II has been logged in the RWP notebook as terminated l using information taken from the Operations Log and logged on the RWP. Training has been conducted to assure verbatim compliance within the existing SOP-D.2 to assure proper initiation and termination of RWP';s. RWP's since the NRC inspection have all been properly initiated and terminated,

d. Corrective Steps to be Taken to Avoid Further Violations ,

Revision 10 to the RWP procedure will deal with RWP ap-proval, issuance of the RWP number and approval for the work to i begin as three separate conditions so that there will be no question about whether an RWP such as RWP 86-14-I has been used. In addition, RWPs that are approved and assigned Serial Numbers, but not issued or used to control work will be re-quired to be filed with a notation explaining non-usage.

The new revision to the RWP procedure will include a review checkoff to assure future RWPs are terminated in the Daily Op-erations Log to prevent recurrence of failure to terminate an RWP. When training has been conducted on Revision 10 of SOP-D.:2 and the revision has been implemented, this item will be con-sidered closed. j l

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l U.S. Nuclear Regulatory Commission

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e. Date of Full Compliance RWP 86-14-I was marked as unused on February 16,1987 with a 1986 index entry made as to its status. RWP 86-12-II was logged properly for termination as of February 16, 1987.

Full compliance with commitments including training on and im-plementation of Revision 10 of SCP-D.:2 will be achieved by April 30, 1987.

3. RWP surveys were not recorded for RWP 85-22-II, RWP 86-7-I, RWP 86-8-I and RWP 86-e7-II.

a. Admission or Denial of the Violation

< > This violation is admitted in that there was a failure to explicitly note that no survey initially was needed prior to work.

b. Reasons for the Violation The RWP procedure in Step 7.2.1.5 explains what the designation

" Survey Measurements" on the RWP form means. Step 7.2.1.5 does not specify that the surveys are required to be performed, merely details what is considered to be complete information if survey data is obtained prior to the task performance. The pro-cedure further delineates what must be included with a survey measurement. This step of the procedure, in contrast to pre-vious steps that specify the indicated information will be en-tered, does not require an entry for this blank on the RWP form. There is no procedural requirement that such surveys be performed except as specified by the RWP. Such a requirement was not made by the RWP's in question because the conditions

prior to accomplishing tasks specified by the RWP made such surveys meaningless; before the tasks were accomplished, the i radiation and contamination levels could not be other than l background. The monitoring that occurred during the work covered by the RWP's was not considered to be a survey.

Various tasks are performed at the UFTR with normal shutdown conditions prior to commencement of the tasks for cases where no condition exists that could cause radiation levels above normal shutdown / background levels, a pre-job survey provides no useful information to the performance of the task. These are frequently Level II RWP's as are two of the issued RWP's cited for no surveys. In these circumstances, unless required by

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U.S. Nuclear Regulatory Commission March 19,1987 '

Page Seven

! appropriate instructions in "special instructions" or " monitor-f ing required," a survey is not required. Additionally, RWP 86-14-I has been determined from records to have never been used

as explained under Item II. Therefore, surveys were not I considered to be required here.

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Surveys for PWP 86-7-I and 86-8-I were conducted and maintained by Radiation Control but not noted on the RWP form. Copies of

those surveys have been attached to the RWP's and the RWP'is de-4 noted to reflect the attachment.

l c. Corrective Steps Taken/Results Achieved j Training conducted on the existing SOP-D..2 has emphasized ver-batim compliance and the need to conduct and record surveys for all RWP's until a revised SOP-D.2 is installed to clarify this

. point. RWP's used since the inspection have all had surveys re-j corded. To assure clear requirements, Revision 10 of SOP-D.2.

has been generated to emphasize delineation of survey require-l ments to include a negative checkoff when none is considered

! necessary prior to opening the RWP and that monitoring, in it-

self, is a survey. Revision 10 specifies how to control and document approved but unissued RWP's like RWP 86-14-I. Final-ly, surveys maintained by radiation control for RWP 86-7-I and

. 86-8-I have been attached to the RWP's, and the RWP';s annotated to indicate the attachments.

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d. Corrective Steps to be Taken to Avoid Further Violations

, Revision 10 of SOP-D.:2 will be approved and training will be conducted on it for all operatorr to indicate when surveys are not necessary with a negative checkoff and monitoring with work in progress will be similarly documented; survey forms as at-

tachments will be explicitly permitted in Revision 10.

e. Date of Full Compliance Full compliance has been in effect since February 11, 1987 for-all RWPs issued subsequent to the NRC inspection. Again, . af ter review and approval of Revision 10 of SOP-D.2, training will be conducted and SOP-D.l2, Revision 10.will be implemented with full compliance with commitments achieved by April 30, 1987.

4. RWP survey measurements performed in 1986 did not include instrument

name, serial number, distance from measured object and the name of the individual performing the measurements.

a. Admission or Denial l

l This violation is admitted.

U.S. Nuclear Regulatory Commission March 19,1987 Page Eight

b. Reasons for the Violation The reason for this violation is failure of the RWP fom to be compatible with the SOP-D.2 requirements to assure a match of requirements with spaces to record data. As a result, the lack of a specified blank on which to record the data resulted in failure to record some survey measurement data.

c. Corrective Steps Taken/Results Achieved The corrective action to date has been twofold. Training has been conducted on the existing SOP to assure verbatim compli-ance. Second, all RWPs used since the inspection have included all required data. These steps have been effective as RWPs now include all survey information. In addition, information for all 1985 and 1986 RWPs has been reconstructed and included on RWPs where possible, always fully documented as to date entered.

Revision 10 of SOP-D.2 where compatibility of text requirements and RWP form blanks (UFTR Form SOP-D.2A) is implemented will provide long term assurance that this violation does not recur.

d. Corrective Steps to be Taken to Avoid Further Violations Revision 10 of SOP-D.2 with the RWP form (UFTR Form SOP-D.2A) will provide designated places on the form for required infor-mation, and a separate review to assure all appropriate infor-mation is included. When the revision is approved, training will be conducted on the Revision 10 of SOP-D.2. Subsequent im-pimentation of the Revision in combination with these two ac-tions will serve to prevent recurrence of this failure to re-cord information required related to survey measurements,

e. Date When Full Compliance Will Be Achieved Full compliance has been achieved as far as new RWPs are con-cerned as of February 11, 1987. Full compliance for all commit-ments including training on and implementation of Revision 10 of SOP-D.2 will be achieved by April 30, 1987.

5. RWP Nos. 86-10-I, 86-12-II and 86-14-I were not terminated within seven days of initiation.

a. Admission or Denial This violation is admitted. It should be noted that this viola-tion for RWP-86-12-II and RWP 86-14-I is essentially the same action as noted in Violation 2; and RWP 86-10-I was terminated via the Daily Operating Log, but not on the RWP.

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U.S. Nuclear Regulatory Commission March 19,1987 Page Nine o

b. Reasons for the Violation RWP 86-12-II was not terminated properly,' RWP 86-10-I was ter

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minated via the Daily Operations Log as specified in SOP-Dgf ,

Section 7.3.3 but was not terminated on the RWP Form SOP-D.2A.

The actions required by the step were not completely performed at that time due to personnel error and because there was no RWP index (see Violation 1). With respect to proper termination of the RWP as specified in 7.2.1.12, an additional failure for RWP 86-4-I was noted and corrected during review of all RWPs for 1984 - 1987.

With respect to RWP 86-14-I, see Section 2b.

c. Corrective Steps Taken/Results Achieved RWPs 86-4-I, 86-10-I, and 86-12-II, have been terminated and logged as such in all required locations including the 1986 RWP Index. RWP 86-14-I has been marked as unused - not issued.

Training has been conducted on the existing SOP-D.2 to assure verbatim compliance. Since the inspection, all RWPs have been terminated within seven (7) days to demonstrate the effective-ness of these corrective actions.. Finally, Revision 10 of SOP-D.2 has been generated to address full compliance of all RWPs  ;

with SOP-D.2 requirements.

d. Corrective Steps to be Taken to Avoid Further Violations Corrective steps to be taken to assure verbatim complianco including final review and approval of Revision .10 of SOP-D.2 followed by training on its use and subsequent implementation.

e. Date When Ful'1 Compliance Will be Achieved Full compliance for all existing RWPs was achieved by February 16, 1987. Full compliance for commitments involving training and implementation of Revision 10 of SOP-D.2 will be achieved by April 30, 1987.

6. RWPs issued in 1986 were not signed by both the senior reactor op- i erator and the reactor manager. i

a. Admission or Denial This violation is admitted. l l

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U.S. Nuclear Regulatory Coinmission ,

March 19,1987 Page Ten

b. Reason for the Violation At the UFTR, the reactor manager is a senior reactor operator, ,

and one signature is intended to meet both requirements, per revisions of the D.2 SOP dating back to 1976. Hence, the RWP Form (UFTR Form SOP-D.2A) only has space for a single signa-ture. Of course, the r ocedure itself caused confusion with respect to intent of his signature requirement. The entry,

" Senior Reactor Operator and the Reactor Manager or his designated alternate," read in an earlier revision, " Senior Operator (or Reactor Supervisor)." The title change from Reactor Supervisor to Reactor Manager and the requirement that the UFTR Reactor Manager hold a senior reactor operator license necessitated a change to the procedure which should have read

" Reactor Manager or his designated alternate (Senior Reactor Operator)." Note that this reading is more restrictive than the earlier revision. Revision 10 to the RWP procedure will clearly delineate the requirement for a single signature.

c. Corrective Steps Taken/Results Achieved Until the revised SOP-D.2 is approved, two signatures are being required to assure verbatim compliance. Training has been con-ducted to assure compliance. All RWPs issued since the inspec-tion carry two signatures to demonstrate effectiveness of the training, j

d. Corrective Steps to be Taken to Avoid Further Violations Training on the existing SOP will prevent recurrence until the revised SOP-D.2 is approved and implemented. At that point the single signature requirement will be clearly delineated.

Retraining on Revision 10 of SOP-D.2 will prevent recurrence of this violation. l

e. Date of Full Compliance Full compliance has been in ef fect since 11 February 1987.

Training and implementation of Revision 10 of SOP-D.2 will be completed by April 30, 1987.

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U.S. Nuclear Regulatory Commission March 19,1987 Page Eleven Final Comments Inspection Response actions to date include the following:

l 1. Correction of the Severity Level V violation on 10 CFR 19.11 and develop-ment of the approved and implemented Q-6 surveillance data sheet to as-sure all posting requirements are met. With these actions the response to the Severity Level V Violation is considered closed.

2. Review of all RWP notebooks for 1984-1987 to correct all deficiencies with memoranda generated to document review and corrective actions.

Training has been conducted to assure the existing SOP-D.2 is followed with verbatim compliance. This step assures all Severity Level IV Viola-tion items will not recur. All RWP's issued since the inspection have been properly documented and implemented. Revision 10 of SOP-D.2 has been generated to assure compatibility of SOP text and form format i as well as better delineation of some requirements to preclude re-

currence of all cited violation items including the uncertainty in l whether an RWP is approved and issued or not. Revision 10 of SOP-D.2 will be approved and training conducted to assure implementation of Revision 10 by April 30, 1987 to conclude response to the Severity Level IV.

We trust this response satisfies the requirements delineated in Inspection Re-t port 50-83/87-01. If there are further questions, please advise.

I I

Sincerely, ,

}l jdv r William G. Vernetr en Director of Nucle Facilities WGV/ps j cc: P.M. Whaley J.S. Tulenko )

Reactor Safety Review Subcommittee (RSRS) i k

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