ML20216B958
| ML20216B958 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 05/13/1998 |
| From: | Roe J NRC (Affiliation Not Assigned) |
| To: | Fleming R MICHIGAN, UNIV. OF, ANN ARBOR, MI |
| Shared Package | |
| ML20216B964 | List: |
| References | |
| 50-002-98-202, 50-2-98-202, EA-98-155, NUDOCS 9805190033 | |
| Download: ML20216B958 (3) | |
See also: IR 05000002/1998202
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20066-0001
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May 13, 1998
EA 98-155
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Dr. Ronald Fleming, Director
Phoenix Memorial Laboratory
Ford Nuclear Reactor
University of Michigan
2301 Bonisteel Boulevard
Ann Arbor, Michigan 48109-2100
SUBJECT:
NOTICE OF VIOL.ATION (NRC INSPECTION REPORT NO. 50-002/98202)
Dear Dr. Fleming:
This refers to the routine, announced inspection conducted February 23-27,1998, to
determine whether activities authorized by your license were being conducted safely and in
accordance with NRC requirements. The results of the inspection were discussed with you
and your staff and were detailed in the inspection report issued on March 24,1998. An
open predecisional enforcement conference was conducted in the Rockville, Maryland office
on April 22,1998, with you and other University of Michigan personnel to discuss two
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apparent violations, their root causes, and your corrective actions to preclude recurrence. A
copy of the University of Michigan's presentation materials and a list of conference
attendees are enclosed.
,
,
Based on the information developed during the inspection and the information that was
provided during the conference, the NRC has determined that two violations of
requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice)
and the circumstances surroe Wing them are described in detailin the subject inspection
report. The first violation invrsived the failure to adequately perform a required
10 CFR 50.59 evaluation of modification Request No.120 which installed a new primary
cooling pump and motor and removed the pump discharge check valve internals in April
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1996 Consequently, the modification resulted in a significant increase in reactor cooling
flow which altered the associated reactor temperature differential and ultimately precluded
the required limiting safety system setting, if it had been called upon, from automatically
preventing the reactor inlet temperature from exceeding the safety limit.
The actual safety consequence of the first violation was low because of the relatively
conservative assumptions used to establish the safety limit, the stable nature of the reactor
inlet (bulk pool) temperature, and the operating #:ocedure limits. Although the violation did
not result in any safety consequence and was not programmatic in nature, it is of
significant regulatory concern because the NRC must be able to rely on its licensees' ability
to conduct adequate safety evaluations prior to making modifications to the reactor that
effect the technical specifications. In addition, given a different set of circumstances, the
failure to perform an adequate 10 CFR 50.59 safety evaluation could have resulted in a
safety consequence. Therefore, this violation has been categorized in accordance with the
" General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement
Policy), NUREG-1600, as a Severity Level lli Violation.
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May 13, 1998
In accorda.?ce with the Enforcem::nt Policy, a base civil penalty in the amount of $2,750 is
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considered for a Severity Level ill violation. Because your facility has not been the subject
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of escalated enforcement actions within the last two years, licensee /denti// cation was not a
consideration factor. The NRC considered, however, whether credit was warranted for
Corrective Action in accordance with the civil penalty assessment process described in
Section VI.B.2 of the Enforcement Policy. NRC determined that credit was warranted for
Corrective Action because your staff, upon identification of the first violation, took prompt
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steps to implement temporary measures to ensure the reactor inlet safety limit was
protected by reducing the limiting safety system setpoint; prepared, property reviewed, and
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installed a permanent additional protection to supplement the required features; and
following NRC identification of the violation, submitted proposed technical specification
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Amendment 44 to make the limiting safety system setting based on the reactor core inlet
temperature consistent with the safety limit. Based on the above, the NRC determined that
credit was warranted for the factor of Corrective Action.
Therefore, to encourage prompt identification and comprehensive correction of violations, I
have been authorized, after consultation with the Director of Enforcement, not to propose a
civil penalty in this case. However, significant violations in the future could result in a civil
penalty.
The second violation involves failure to notify the NRC in writing within 30 days as required
by Technical Specification 6.6.2.b.2 following the discovery of the condition described
previously on October 8,1996. This violation has been characterized in accordance with
the Enforcement Policy as a Severity Level IV violation.
You are required to respond to this letter and should follow the instructions specified in the
,
enclosed Notice when preparing your response. The NRC will use your response, in part, to
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determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosures, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
ORIGINAL SIGNED BY:
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Docket No.50-002
License No. R-28
Enclosures:
1.
2.
University of Michigan Presentation Materials
3.
List of Attendees
DISTRIBUTION:
HARD COPY w/o enclosure 2
E-MAIL w/o enclosure 2
Docket File 50-002 PUBLIC
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Dr. Ronald Fleming
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In accordance with the Enforcement Policy, a base civil penalty in the amount of $2,750 is
l
considered.for a Severity Levellli violation. Because your facility has not been the subject
l
of escalated enforcement actions within the last two years, licensee /denti// cation was not a
consideration factor. The NRC considered, however, whether credit was warranted for
Corrective Action in accordance with the civil penalty assessment process described in
Section VI.B.2 of the Enforcement Policy. NRC determined that credit was warranted for
Corrective Action because your staff, upon identification of the first violation, took prompt
steps to implement temporary measures to ensure the reactor inlet safety limit was
protected by reducing the limiting safety system setpoint; prepared, properly reviewed, and
installed a permanent additional protection to supplement the required features; and
(
- following NRC identification of the violation, submitted proposed technical specification
Amendment 44 to make the limiting safety system setting based on the reactor core inlet
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temperature consistent with the safety limit. Based on the above, the NRC determined that
credit was warranted for the factor of Corrective Action.
Therefore, to encourage prompt identification and comprehensive correction of violations, I
have been authorized, after consultation with the Director of Enforcement, not to propose a
civil penalty in this case. However, significant violations in the future could result in a civil
l
penalty.
The second violation involves failure to notify the NRC in writing within 30 days as required
by Technical Specification 6.6.2.b.2 following the discovery of the condition described
previously on October 8,1996. This violation has been characterized in accordance with
'
the Enforcement Policy as a Severity Level IV violation.
You are required to respond to this letter and should fol!ow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosuras, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
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J ck W. Roe, Acting Director
ivision of Reactor Program Management
Office of Nuclear Reactor Regulation
Docket No.50-002
License No. R-28
Enclosures:
1.
2.
University of Michigan Presentation Materials
3.
Ust of Attendees
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