ML20216B967
| ML20216B967 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 05/13/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20216B964 | List: |
| References | |
| 50-002-98-202, 50-2-98-202, EA-98-155, NUDOCS 9805190039 | |
| Download: ML20216B967 (5) | |
Text
NOTICE OF VIOLATION l University of Michigan Docket No. l 50-002 License No. R-28 EA 98-155 During an NRC inspection conducted on February 23-27,1998, violations of NRC i
requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below.
- 1. 10 CFR 50.59 requires, in part, that licensees may make changes in the facility as l described in the safety analysis report, without prior Commission approval provided l the change does not involve a change in the technical specifications.
Ford Nuclear Reactor Technical Specification 2.1.1 " Safety Limits in the Forced l
Convection Mode," states, in part, that the objective of safety limits are to assure the integrity of the fuel clad. Paragraph 2 of Section 2.1.1, states that the true value of reactor coolant inlet temperature at 2 Megawatts shall not exceed 116 F.
Ford Nuclear Reactor Technical Specification 2.2.1, " Limiting Safety System Settings,"
states, in part, that the objective of limiting safety system settings is to assure that automatic protective action is initiated to prevent a safety limit from being exceeded.
The Ford Nuclear Reactor Safety Analysis Report Section 4.1 states, in part, that the flow rate in the primary coolant system is between 900 and 1000 gallons per minute (gpm).
Contrary to the above, the licensee, in April 1996, made a change to the facility by replacing a primary coolant pump and removing the pump's discharge check valve internals, which increased the primary cooling system flow to approximately 1100 gpm. Increasing the primary coolant flow resulted in the reactor limiting safety system setting for core outlet temperature no longer being able to assure that the safety limit of inlet temperature remained below 116*F at 2 Megawatts. A safety evaluation, in accordance with 10 CFR 50.59, was prepared for the pump replacement; however, the evaluation was inadequate because it did not consider the effect of increased flow on the inlet temperature safety limits, and did not identify that a charge to the facility's technical specification was required. Although the inlet temperatures never exceeded the safety limit, the reactor continued to be operated in that condition except for periodic maintenance and refueling shutdowns from completion of the modification in April 1996, until corrective action occurred on October 8,1996.
(01013)
This is a Severity Level til Violation (Supplement I)
- 2. Technical Specification 6.6.2.b.2 requires that the licensee prepare a written report to NRC and forward it within 30 days when they discover any substantial variance from performance specifications contained in the Technical Specifications and the Safety Analysis Report.
9905190039 990513 PDR ADOCK 05000002 G PDR
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Contrary to the above, the licensee failed to notify the NRC within 30 days when they discovered on October 8,1996, that the reactor outlet temperature limiting safety system setting would not prevent the reactor inlet temperature from being exceeded as required during 2 Megawatt operation. (02014)
This is a Severity Level IV Violation (Supplement 1)
Pursuant to the provisions of 10 CFR 2.201, the University of Michigan is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Region-based inspector within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the
! date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required i response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be
- modified, suspended, or revoked, or why such other action as may be proper shculd not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
- Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Because your response will be placed in the NRC Public Document Room (PDR), to the l extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessrsty to provide an acceptable response, then please provide-a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide sn acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Rockville, Maryland this
L.
FREDERICK C. NEIDH ARDT l VKE PRESIDENT FOR RESEARCH
! THE UNIVERSITY OF MICHICAN i
kM) FLEMING BULDING ANN ARBOR. MIOUGAN 4AhntW
'M "#>4-ilH FA% T34 TokW5 April 22,1998 Good afternoon! I am Frederick C. Neidhardt, the F. G. Novy Professor of Microbiology and Immunology , and Vice President for Research at the University of Michigan. As the Executive Officer responsible for oversight of the Michigan Memorial Phoenix Program (MMPP), of which the Ford Nuclear Reactor (FNR) is an integral part, I represent the licensee of the reactor in this discussion of the potential violations described in the letter of 24 March 1998 from the Nuclear Regulatory Commission to Professor Ronald Fleming, Director of the MMPP and FNR.
Allow me to introduce the individuals who have accompanied me to this meeting. Judy Nowack, Assistant Vice President for Research, sits on the FNR Safety Review Committee on my behalf. Ronald Fleming is the Director of the MMPP which houses our reactor. James Carey, Jr., chairs the University's Radiation Policy Committee for our Broad Scope License.
John Lee, Professor of Nuclear Engineering chairs our FNR Safety Review Committee. Ms.
Sally Cherchill is a University attorney. In addition, members of the FNR technical staff are here to answer any technical questions.
Although not a physicist, I have more than a passing acquaintance with the peaceful uses of nuclear physics through forty-five years of personal research experience with radioactive isotopes in microbiological research, and perhaps more relevant to today's discussion, I am just concluding a four-year term as a member of the Basic Energy Science Advisory Committee (BESAC) of the Department of Energy. During my term of service I have been called upon to review the operation of the nation's leading research reactors at its National Laboratories, notably those at Brookhaven and Oak Ridge. This service has broadened my awareness of the role of research reactors in an incredible variety of contemporary research that extends far beyond the domain of nuclear physics and into the areas of biology and material sciences. It has also heightened my sensitivity to the critical need for the highest possible level of attention to safety and compliance issues in the operation of these reactors.
I am leading this Michigan delegation as a representative of the Regents of the University and of its Executive Officers. I am here to underscore the level of interest that the University places on the Ford Nuclear Reactor, and therefore, the level of importance that we place on any discussion of its compliance with regulations of the Nuclear Regulatory Commission. I am grateful for this opportunity to appear before officials of the Commission to express our interest and concem.
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As you know, the FNR has been in operation the beter part of half a century. Physically it occupies a prominent place in our burgeoning North Campus, adjacent to new buildings for our l i
College of Engineering and our new and exciting Media Center. Given this prominence, the University has been interested in continual examination of oversight mechanisms for the f j
facility, and in examination of the continued role and need for a research reactor on a university l
campus. Over the past several years we have conducted periodic reviews of both the management structure and the educational and research role of the FNR. The latest l l
! management review was conducted in 1994, and resulted in strengthening of the extemal
' oversight of reactor operations. The latest review of the need for the reactor was conducted in 1997, and it resulted in the conclusion that the FNR was providing a unique research, f educational, and service role, therefore meriting the substantial annual subsidy from the l l i 1
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ATTENDANCE LIST UNIVERSITY OF MICHIGAN ENFORCEMENT CONFERENCE APRll 22,1998 NAMES ORGANIZATION TELEPHONE NUMBER Theodore Michaels NRC/DRPM/PDND (301) 415-1102 Thomas Burdick NRC/DRPM/PDND (630) 829-9864 Michael Rafky NRC/OGC (301) 415-1974 Marvin Mendonca NRC/DRPM/PDND (301) 415-1128 Fredrick C. Neidhardt University of Michigan (734) 764-1185 Mark A. Satorius NRC/OE (301) 415-2747 Thomas Myers NIST (301) 975-6257 Tawfik Raby NIST (301) 975-6257 Sue Gagner NRC/OPA (301) 415-8200 Judith Nowack University of Michigan (734) 763 1289 Sally Churchill University of Michigan (734) 764-0304 Office of General Counsel Seymour Weiss NRC/DRPM/PDND (301) 415-2170 Alexander Adams, Jr. NRC/DRPM/PDND (301) 415 1127 Christopher Brannon University of Michigan (313) 936-1576 John C. Lee University of Michigan (734) 764-9379 James E. Carey University of Michigan (734) 936-5155 l
Philip A. Simpson University of Michigan (734) 764-6221 Ron Fleming University of Michigan (734) 764-6215