ML20214T610

Responds to Violations Noted in Insp Rept 50-160/87-01 on 870209-23.Corrective Actions:Procedures 7246 & 7220 Being Modified to Account for A.1.a & A.1.c & Devising & Writing New Procedure A.1.b

ML20214T610
Person / Time
Site:	Neely Research Reactor
Issue date:	05/25/1987
From:	Karam R Neely Research Reactor, ATLANTA, GA
To:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8706100345
Download: ML20214T610 (12)

Text

,e hb 1 Georgia Institute of Technology i

8ke SL May 25,1987 NEELY NUCLEAR RESEARCH CENTER 900 ATLANTIC ORIVE ATLANTA, GEORGIA 303 S

, Ch Mr. Luis A. Reyes, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street Atlanta, Georgia 30303

Subject:

Inspection Report # $0-160/87-01 This letter is our response to the referenced inspection conducted by A.B. Long on February 9-23, 1987. An extension of one month for our response was granted by Mr. David Verrelli over the telephone on May 8, 1987. The response follows the same order of items as listed in Inspection Report Enclo.mure 1.

Items A.1.a. b and c. These items were lifted from a study I commissioned for the purpose of having in my hands a definite evaluation of whether or not we are meeting all our commitments under the requirements of our Technical Specifications. Unfortunately the unofficial memo which this study generated was inappropriately distributed and it fell in Miss Long's hands before I saw it. As far as I can tell my predecessors at the NNRC never performed any measurements or conducted any tests to ascertain that the requirements of A.1.a. b, and c were met.

We admit the violation. (I was under the impression, however, that since we discovered the violation that you would give us some credit for that.) The reason (s) for the violation is not clear since many personnel changes have taken place. The corrective steps we are taking are modifications of procedure 7246 and procedure 7220 and to account for A.1.a and ' A.1.c, and devising and writing a new procedure for A.1.b.

We have discussed with Savannah River Laboratory personnel (Dr. John Church, (803) 725-3177), the matter of how D 2 is analyzed for in the cover gas. SRL content in the cover gas. The uses gas chromatography Technical Specificationsfor determining limit the D}s for D2at SRL ' 3.8%. They claim that below 3.8% no explosion is possible with deuterium gas. Georgia Tech's Technical Specifications' limit is 21.

We have acquired a gas chromatography machine for meeting A.1.b requirements.

We expect that by 9/15/87 we would have developed an adequate procedure for this deficiency.

Item A.2.a. With regard to updating procedures to reflect the change in cover gas from He to N , 811 Procedures have been updated as of 5/22/87.

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c Mr. Luis A. Reyes Inspection Report 50-160/87-01 Page 2 May 25,1987 Item A.2.b. It was stated in inspection report (IR) that certain handwritten changes were made to procedures 2002 and 2003 for over a year and a half without these changes being incorporated into a permanent revision. The IR states further that on a number of occasions these handwritten changes were omitted causing failure to follow procedure as written.

4 The changes that the IR refers to are not chaages to procedures 2002 and 2003 but are comments on certain equipment operational status. The comments are limited to the phrase, "out of commission" being used to describe the status of the following equipment: (1) universal counter; (2) PA system; (3) storage pool drained for painting; (4) picoammeter #1, and so on. In all cases, except the universal counter, the changes are temporary. With regard to the universal counter, we have been unable to buy parts for this instrument to keep it in working order. No one makes this instrument any more. Consequently we decided to replace it. This will be done during fiscal year 1988 We deny any violation was committed as charged in A.2.b.

Item A.3.a. We admit that errors were committed as charged by not logging initial critical conditions and equilibrium condition data. I have discussed this issue with the operators and the reason they gave me for the error is simple oversight. I emphasized to the operators that we must methodically and step by step comply with all procedures. More care shall be taken to appropriately follow procedures. Additionally, I have instituted internal audits to monitor our conpliance.

Item A.3.b. refers to procedure 2210 which requires that water be run through cooling towers for an hour per week during periods when the reactor is not operating. We have discussed this matter at length and decided that this procedure should be deleted. The main reason for this decision is that we have limited resources and there appears to be no redeeming safety features for this requirement. Originally, this requirement was instituted during the extended period of no reactor operation at the time of conversion from one to 5 MW. The proposal to delete this procedure will be submitted to the Nuclear Safeguards Committee for approval. Incidentally, it is stated in item A.3.b that the reactor was not operated during the period March 31-April 14,1986 Item C on page 3 of IR states that the reactor was operated on April 7,1986 at one megawatt. The IR is inconsistent; it is true that the reactor was operated on April 7,1986 Item B.1 of IR stipulates that calculations of estimated activities of principle isotopes are required in every case. While this interpretation is possible based on the information requested on the " Request for Minor Experiment Approval Form," it was never meant to be a requirement. In fact the practice at the NNRC before I came was often not to fill-in this information.

I made a conscious effort to estimate the activities on the form based on knowledge of what was in the sample. Often however we have samples that we do not know the elemental composition of. Consequently, we approach the problem with care, i.e., we irradiate a small sample for a short duration at normally low power. The bottom line here is that we will make, to the extent possible,

Mr. Luis A. Reyes Inspection Report 50-160/87-01 Page 3 May 25,1987 analyses of the activities of the principle isotopes, but we do not treat this as a requirement. We therefore deny that any violations were committed in B.1 Items B.2, 3, 4 We admit that our procedures for tracking required information under Technical Specifications 6.3.a(1) and 6.3.c are somewhat confusing and unnecessarily complex. We are re-evaluating the whole process.

The root cause is that we have too many forms. The form consolidation and streamlining will be finished September 15, 1987. We are currently reviewing and re-evaluating all procedures to be finished October 15, 1987.

Item C. We admit that no heat balance was made between March 31-April 14, 1986. The operators claim it was an oversight. I continue to stress the need to minimize or eliminate oversight altogether. Our internal audits, started this year, will help monitor this problem. I will evaluate whether or not progress is being made in about one year from now.

Item D refers to Technical Specifications violation because the cover gas was changed from He to N and to another violation for not reporting the change 2

in the Annual Report. Our response to the charge of violation on the cover gas change is as follows: Although the word helium appears in the Technical Specifications 3.6.e, it was felt that the 3.6.e requirement is 25 by volume D n entration in the cover gas. The fact that the cover gas was mentioned 2

as helium is incidental to the requirement. For this reason we felt that l Technical Specifications 3.6.e was not violated. We, however, did not consult a lawyer and our opinion seemed reasonable. We still hold that view. We will however submit a formal request to change the Technical Specifications to reflect, among other things, the change in cover gas mentioned in 3.6.e and on page 24 of Technical Specifications.

With regard to a violation on account of not including the change in the Annual Report, we are guilty as charged. This again was a simple oversight that eluded reviews of seven different people. What corrective steps are needed to prevent reoccurrence is not clear. I have however established a punchlist for items to be done and this list will be updated weekly. On this punchlist there will be an item to review Nuclear Safeguards Committee minutes in January of every year. This review should help refresh appropriate memories of whether or not changes to the facility were incorporated.

Item E. The charge is that we failed to keep summaries of the control manipulations and the performance observations by licensed operators. Annual summaries of control manipulations do exist in our files. Therefore no violation was committed. The performance evaluations were not done since 1983. This appears to coincide with the change in personnel. The person in charge of this activity stated that he simply forgot.

As a step to correct this, I have begun to list all system worksheets, procedure 4900, on my punchlist with due dates listed. A copy of the punchlist for the week of May 25-29, 1987 is appended.

Hr. Luis A. Reyes Inspection Report 50-160/87-01 Page 4 May 25,1987 Item F.1 refers to the Nuclear Safeguards Committee not performing reviews and audits. The implication is that this committee must audit everything exhaustively and annually. The Technical Specifications do not specify such a requirement. Recent audits have been more extensive than in years past but not to the degree implied in item F. I would be delighted to have the Committee conduct exhaustive and thorough audits. But we all should realize that the Committee does this work on a voluntary basis and realistic expectations of how much they can do would be useful to all. I will distribute the inspection report and this response to the Committee members. I also will recommend to the president of Georgia Tech to enlarge the membership of the Committee so that more depth and breadth of audits can be realized.

Technical Specifications 6.2.e(5) requires that the Committee perform audits on reactor operations and reactor operational records but it does not specify at what frequency. Consequently no violation was committed in F.1; however, we appreciate NRC's efforts to bring this issue out in the open.

Item F.2 We agree that the records for approval of class experiments by the Committee were not found. But the experiments are all minor in nature and as such explicit approval by the Committee is not needed. Technical Specifications 6.2.e(1) states that the Committee shall: Review and approve proposed experiments and tests utilizing the reactor facility which are significantly different from tests and experiments previously performed at the GTRR. All experiments involving students have previously been performed many times. Consequently no violation was committed in F.2.

Item F.3 relates to audits equipment functions as required by Technical Specifications. Again we feel no violations were committed here for the same reasons given in F.1, We agree however that expanded audits by the Committee are necessary to meet the spirit and letter of Technical Specifications.

Item F.4 relates to audits by the Nuclear Safeguards Committee being inadequate. This charge is rather subjective and again no violations were committed. Expanded audits will however be instituted.

I hope that you will find our response satisfactory. If you have any questions please let me know.

Sincerely yours, 9% %~

R.A. Karam Director RAK:jlr pc Nuclear Safeguards Committee

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i GEORGIA TECll RESEARg8 CTO C t. apter  ! 3 rocedure 7246 M

9 . i ast Rev. 00/00/87 cr

!nstrumentation ! Control r' L; iv i Last Rev. App. 00/00/87

' l Page 1 of 3 Rev A

& surveillance l J 9 oh _

1. GeneralRequiremek A. ' Frequency d' Annual (except according to Tech. Spec. 4.1.a) ,

B. Technical Specification or other reference S ee 3.1. a , 3.1.e , 4.1. a ,

II. Prcrcquisites A. Applicabic startup checklist complete B. Licensed senior reactor operator and reactor operator on duty III. Reactivity Calibrations A. Regulating Rod - by Asymtotic Period 1 Startup and maintain reactor at minimum critical power; regulating rod in manual control at DOWN limit

2. Wait at least 15 min. , then withdraw regulating rod to 3.0 inches and allow reactor power to locrease

3. Take doubling-time data until repetitive values indicate that a stable asymtotic period has been achieved 4 Quickly reduce reactor power with shim blades to value in step 1, regulating rod remains at 3.0 inches

5. Repeat steps 2 thru 4 for regulating rod movements of 3 to 7 inches, and 7 to 12 inches

6. Using GTRR inhour curve, determine rt activity value assoc-iated with each regulating rod movement and plot the inte-gral worth curve B. Shim Safety __Blddes - by Rod Interchange n a 1 Maintain a primary coolant temperature of 75 F + 3 F throughout this phase of the calibration

2. Position selected shim-safety blade at DOUU limit (0 degrees). Position regulating rod at UP limit (12 'incfies)

3. Maintain reactor at a low (1 1 kw if possible) power usine remaining three shim-safety blades 4 Wait at least 15 minutes to establish equilibrium

5. Simultaneously withdraw the aelected shim-safety blade and insert the regulating rod to compensate

6. When the regulating rod is at or near its DOWM limit, s t a-bilize reactor pcwer and record both selected shim-safety blade position and regulating rod position

7. Withdraw regulating rod to UP limit, compensating with the three remaining shim-safety blades

l GEORGI A TECil RESEARCl! REACTOR i Chapter  ; l Procedure 7246 9 i I Last Rev. 00/00/87 Instrumentation i Control Element Reactivity l Last Rev. App. 00/00/87 4 Surveillance i Worth Measurement i Page 2 of 3 Rev A

8. Continue steps 5 thru 7 unti,1 the selected shim-safety blade is fully withdrawn

9. Adjust shim-safety blades so the next selected blade is on its DOWN limit and the regulating rod is at its UP limit 10 Repeat steps 5 thru 9 to complete calibration of all shim-safety blades 11 Shutdown reactor. Using the redulating rod worth curve, determine the reactivity value associated with each move-ment of each shim-safety blade. Plot the integral worth curve for each shim-safety blade IV. Acceptance Critoria Compare calculated values of control element worths to previous values to determine if significant changes have occured V. Excess Reactivity After all calibrations have been completed and the shutdown margin has been deteruined, fill out the Reactivity Worth Report Form (page 3) to calculate the excess reactivity. It must be less than 11.9 J.

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e l GEORGIA TECll RESEARCH REACTOR !

Chapter i l Procedure 7246 9 l  ! Last Rev. 00/00/87 I nstrut.4entation l Control Element Reactivity l Last Rev. App. 00/00/07

&_ Surveillance l _ Uorth ricasurement _- l Pade 3 of 3 Rev A Reactivity Ucrth Repprt Form Shiu Safety Blade Calibration done on:

S.",2 J1 worth:

SSB #2 worth:

SSB #3 worth:

SSB #4 worth:

Regulating Red Calibration don,e on:

R.t. worth:

(A.) Total Control Worth:

Shutdcwn ;1argin done on:

(B.) Shutdown mardin:

Excess Reactivity = (A.) - (B.) or Completed by: Date

1 GEORGIA TECH RESEARCH REA TOR l Chapter l 1 Procedure 7220 9 ' Last Rev. 00/00/87 Instrumentation i a. ' Last Rev. App. 00/00/87

& Surveillance l Building Iakldt est l Page 1 of 1 Rev A I. General Requiremen A.

A. Frequency i 1 D. Technical S on or other reference - see T.S. 4.3a II. Prerequisites Reactor shutdown or operating at a power level of 100 kw or less III. Procedural Instructionq A. Reset all building isolation circuits and select a channel to be tested B. Initiate an isolation trip from the selected channel & verify:

1 Trip setpoint correct for the selected channel

2. All containment isolation valves CLOSED. Check by physical inspection

a. Inboard & Outboard Inlet valves

b. Inboard & Outboard Outlet valves

c. H-15,16 flight and air supply valves-containment side

d. H-15,16 flight and air supply valves-laboratory side C. Cor.iplete steps A and B above for the following channels 1 Kanne 2 MAP-1

3. Gas Monitor 4 Filter Bank Monitor

5. D2 0 Leak Channel D. For one of the channels, determine the lendth of time it takes for the containment isolation valves to close IV. Acceptance Criteria Each channel causes a complete building isolation to occur at its l correct trip setpoint and the isolation valve closure time < S sec l

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NNRC PUNCHLIST Fby 25,1987 Item Person in Charge Date Due Date Comp.

1 Physicals for Respirator Use Daphne Aycock

a. R. Boyd 6/15/87

b. B. Downs 5/26/87

c. D. McDowell 6/1/87

d. J. Taylor 6/15/87

2. Devise a Method to Analyze Bob Boyd 8/15/87 Waste Water Paul Sharpe

3. Analysis of Liquid Waste Bob Boyd 6/1/87 Samples Comparison with Bernd Kahn 4 Review Emergency Plan and Bob Boyd 6/15/87 5/15/87 Procedures

5. Propose Changes in Emergency Procedures:

a. Inspection Persons Must Bob Boyd 5/30/87 5/13/87 Wear Self-Reading Monitors

b. Make Certain That People Bob Boyd 5/30/87 5/13/87 are Accounted For

6. Annual Training in Emergency Bob Boyd '(/15/87 Procedures

7. Required Signs for Radiation Bob Boyd 7/1/87 Control

8. Internal Audit for licalth Bob Boyd 3/15/87 Physics

9. Ilood Inspections Bob Boyd 8/15/87 10 i'and and Foot Counter and Bob Boyd 8/1/87 Procedures 11 Maps and Blueprints

a. Updating all Blueprints David Cox 5/15/87 5/15/87

b. Approved Changes Incor- David Cox 6/27/87 porated

12. Level Alarm of D20 David Cox 6/15/87 (Evaluation)

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Item Person in Charge Date Due. Date Comp.

13. Procedure and Surveillance.

a. Identification of Bill Downs 5/5/87 5/5/87 Procedures Which Need to be Written

b. Deficiencies in Current Bill Downs 5/15/87 5/15/87

' Procedures

.c. -Technical Specifications Bill Downs 5/15/87 5/15/87 Commitment & Deficiencies

d. Review and Evaluate all Bill Downs 10/15/87 Procedures 14 -Internal Audit for Reactor Bill Downs 8/15/87 Operations Dean McDowell

15. Consolidate Experiment Schedule Bill Downs 9/15/87 Form and Checklist Form 16.. Draft Procedure for Notifi- R.A. Karam 5/1/87 5/1/87 cation . in Case of Emergency

17. Response to NRC Inspections

a. Inspection # 50-160/87-01 R.A. Karam 5/14/87 to 6/14/87

b. Inspection # 50-160/87-03 R.A. Karam

c. -Inspection # 50-160/87-04 R.A. Karam 6/15/87

18. Monthly Progress Reports to R.A. Karam Monthly 5/13/87 Savannah River Laboratory

19. Proposal to Geor61a Power R. A. Karam 5/7/87 5/7/d7 20 Proposal to Emory University R.A. Karam 5/31/87 and National Cancer Institute 21 Proposal to Savannah River R.A. Karam 10/5/87 Laboratory 21a. Neutron Activation Analysis R.A. Karam 5/13/87 5/13/87-Report to SRL

~2 2. Review of Nuclear Safeguards R.A. Karam 1/1/88 Committee Minutes for Reporting Facility Design Changes to NRC in Annual Report

23. Audit of Ilot Cell Operation Jim Mahaffey 6/15/87

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Item Person in Charge Date Due Date Comp.

24 Compliance with Jim Mahaffey's Dean McDowell 6/15/87 Report Mitch Mercer

25. D Analyzer and Procedure Dean McDowell 8/15/87 2

26 Request to Renew B. Downs Dean McDowell 6/15/87 License

27. Special Nuclear Material Dean McDowell 9/14/87 Inventor

28. Requalification Exam Dean McDowell 6/15/87

29. Performance Observation of Dean McDowell 7/15/87 Licensed Operators 30 Hot Cell Monitoring System Mitch Mercer 5/22/87 _

31 Criticality Alarms Mitch Mercer 5/13/87 5/13/87

a. Above pool would not alarm

b. Monitor above Lab 149 does not work.

32 External Audit of Health Nuclear 11/15/87 Physics & Reactor Operations Safegusrds Audits Committee Procedures 2002, 2003, Annual Reports, 2004, 2005, 4901, 2006, 2010, 2011, Console Log, Health Physics, Experiment Approval Forms, Operating Procedures for Adequacy

33. Deletion of Procedure 2210 Nuclear 7/9/87 Safecuards Committ ee 34 Update Emer6ency Telephone Judy Rodgers Every 3 Roster Quarterly Months:

January, April, July, October

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Item Person in Charge Date Due Date Corap.

35. Update NNRC Punchlist Weekly Judy Rodgers Every Week 36 Modify Emergency Procedures Judy Rodgers 7/25/87 5/15/67 per Bob Boyd's Letter

37. liouse Cleaning

a. Hot Cell Jerry Taylor 5/15/87 5/1/87

b. Reactor Building Contain- Jerry Taylor 7/15/87 ment; All Three Floors

c. Office Space and Jerry Taylor 6/15/87 Laboratories

38. Change Resin Beds for Pool Jerry Taylor 6/1/87

39. Order New Resin Batch for Jerry Taylc- ' ' ' ' ' '

5/18/87 Reactor 40 Wash Chute with 11 2

0 na Jerry Taylor Weekly Weekly Basis l

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