ML20217M153
| ML20217M153 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 04/01/1998 |
| From: | Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-062-98-201, 50-396-98-201, 50-62-98-201, NUDOCS 9804080019 | |
| Download: ML20217M153 (7) | |
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SCHOOL OF ENGINEERING $
, April 1,1998
& APPUED SCIENCE DEPARTMEh70FMECHANICAL, AEROSPACE ANDNUCLEAR ENGINEERING U.S. Nuclear Regulatory Commission ATTN: Document Control Desk University of virginia Thornton Hall Washington D.C.
Charlottesville, VA 22903-2442 20555 804 S 24 7421 FAX: 804/982-2037 TDD: 804/982-1IEAR Re: Reply to a Notice of Violation and a Notice of Deviation, as per NRC Inspection Report No. 50-62/98-201 dated March 4,1998, for the University of Virginia Reactor (UVAR),
License No. R-66, Docket No. 50-62, and the CAVALIER, License No. R-123, Docket No. 50-396.
Gentlemen:
Please find enclosed a written statement offered in response to the report on the NRC inspection of January 26-28,1998 of the University of Virginia Reactor Facility in the area of Emergency Planning and Implementation. Asjustified in the enclosed reply to the notice ofdeviation, we are hereby reque '
the NRC to set aside U.Va.'s commitment of 1997 to revise the U.Va. Reactor Facility' erge y Plan and Implementing Procedures.
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. Mulde, irector I ner eby certify that the attached document is a true and U.Va. Nuclear Reactor Facility exact copy of a f
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encl: Reply to Noti:e of Violation Reply to Notice of Deviation Copy of Section 8.4(2) of the U.Va. Reactor Facility Emergency Plan Copy of Criticality Alarm System Calibration Form of Sept. 15,1997 i
Copy of Feb. 13,1998 Merr andum to U.Va. Reactor Safety Committee Copy ofMarch U, M8 Memorandum to U.Va. Reactor Safety Committee Mr. Craig Bassett, U.S. Nuclear Regulatory Commission, Region 11, 61 Forsyth St. SW, cc:
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' Notice of Violation Section 8.4(2) of the U.Va. Reactor Facility Emergency Plan requires that the evacuation alarm be tested once every six months. Contrary to the above, in 1997 the evacuation alarm was tested on January 22, and again on April 11, but was not tested again in 1997 as required. Also, the 4
alarm was not tested during the most recent emergency exercise on January 13,1998.
Reason For Violation
. Section 8.4(2)(c) states " Evacuation Alarm-The evacuation alarm will be tested once eveiy six months. This will be done during normal working hours to insure that everyone becomes familiar
. with the sound of the horn and that proper actions are carried out. A check of the entire Reactor Facility will be made to insure that everyone has evacuated the Facility and that the horns can be heard in all parts of the building."
The evacuation alarm in usually tested in conjunction with an evacuation drill. In 1997, the -
evacuation alarm was tested also on September 15,1997, however, not as part of an evacuation drill (see form enclosed) and thus the test did not result in an evacuation. The violation involves
~ 'our failure to hold an evacuation drill once every six months, rather than testing the evacuation alarm every six months. The explanation for this happenstance follows.
Normally, evacuation drills and alarm tests are documented and filed as evidence of compliance for NRC inspections. - When a licensee cannot produce such documentation, the NRC correctly must presume _ that the test did not occur. While the reactor director remembers participating in an evacuation drill in the fall of 1997 during which the evacuation alarm was sounded, the reactor staff was unable to produce the necessary evidence at the time of the last inspection. Thus, without documentation to the contrary, a violation of 8.4(2)(c) must presumed.
Corrective Steps The staff held a make-up evacuation drill and tested the evacuation alarm on January 30,1998.
The drill was described to the Reactor Safety Committee in a memorendum dated February 13, 1998.' The drill / test was successfully run and documented. Another evacuation drill and alarm test was held on March 31,1998.' To prevent a repeat violation of this type, the reactor staff will devote greater attention to properly documenting and filing paperwork in the future. Also, the reactor surveillance' schedule list has been modified. Henceforth, yearly evacuation drills using the criticality alarm will be held in February, and evacuation drills using the regular evacuation system will be held in August.
Da' e When Full Compliance Will Be Achieved t
The evacuation drill held on January 30,1998 tested the evacuation alarm and returned the licensee to full compliance.
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Notice of Deviation The licensee committed to revise the Facility Emergency Plan Implementing Procedures and I
present the revisions to the Reactor Safety Committee by July 1,1997, for review and approval.
Contrary to the above, the licensee did not revise the Emergency Plan Implementing Procedures and no revisims were presented to the Reactor Safety Committee for review and approval by July 1,1997.
Reason for the Deviation The NRC statement of deviation is correct. The revisions to the plan and implementing procedures were not carried out due to a loss of experienced reactor staffin 1997. The reactor employees who have retired or resigned since that time will not be replaced. Accordingly, the Reactor Facility began cutting back on reactor operations in February of 1998 and expects to -
cease operation by July 1,1998. It is anticipated that the University administration will make a decision on a formal announcement regarding permanent reactor shutdown within the next six months. Thus, the revision to the Emergency Plan proposed by the licensee has benr made 1
unnecessary and fulfillment of the commitment should no longer be required by the WRC. The present plan has served well during the past decade, and continues to be fully acceptable in its present form. The effort which would be required to complete a full revision of plan and implementing procedures far out-weights the potential benefits.
Corrective Steps Taken or To Be Taken i
The licensee hereby asks the NRC to set aside the licensee's commitment made in February of 1997, in view of the special circumstances described in the above paragraph. It is noted that there will be no impact on the health and safety of the public as a result of such a decision.
t Date Corrective Actions Will Be Completed This item will remain open, subject to an NRC decision rescinding the licensee's commitment to revise the Emergency Plan and Implementing Procedures.
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(2) (c)
Evacuation Alarm -: The evacuation alarm will be tested once every six months. This will be done during normal working hours to insure that everyone become familiar with'the sound of the horn and_that proper actions are carried out.
A che'ck of'the entire Reactor. Facility will be made to insure that everyone has evacuated the Facility and that the horns-can be heard in'all parts of the building.
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CRITICALITY ALARM SYSTEM CALIBRATION FORM I. SET POINTS As Found As Left A) Alarm (10 to 15mr/hr)
- 1. Detector 1 i7 IZ
- 2. Detector 2 IS ti B) Alert (10 to 15mr/hr) j
- 1. Detector 1 l 2-ik l
- 2. Detector 2 l '5I 15 l
II. FIELD CALIBRATOR
- 1. Calibrator Field
- Open fM00 Closed, 2.7,6
- 2. Acceptance Criteria: +/- 20% of Calibration Field
- 3. Detector Response Attenuator Detector 1 Detector 2 Position initial final initial final
- 1. open 2600 290 MOD 2fo9
- 2. closed 25 26 26 III. AIJJJi TESTING
- 1. Part of annual evacuation drill?
yes no
- 2. Alarm check:
Airst Floor zzanine 2
avalier Room k'ood Shop
- 3. Detector system used to initiate alarm?
COPJiENTS :
5 Reviewed by bl Date:
UNIVERSIT( OF VIRGINIA NUCLEAR REACTOR,FACluT(
DEPARTMENT OF MECHANICAL, AEROSPACE AND NUCLEAR ENGINEERING j
MEMORANDUM February 13,1998 To:
Reactor Safety Committee From:
Paul Benneche, Reactor Supervisor 1
Subject:
Semi-Annual Reactor Facility Evacuation Drill, January 30,1998 At approximately 3:42pm on January 30,1998 the Reactor Facility evacuation alarm system was activated by Reactor Supervisor Paul Benneche via the alarm button in the first floor hallway.
The UVAR reactor was not in operation at the time.
Previously, it was noted that the alarm level as heard in the UVAR reactor room needed to be somewhat louder. This improvement has not yet been made, but Marshall Crawford, the Reactor Electronics Supervisor, has purchased the needed hardware and will install a new horn soon.
All personnel from the Reactor reported to the assembly area by 3:47pm and the accountability check was completed by 3:49pm. The following personnel and equipment were cecounted for at the assembly area:
1 Reactor Supervisor (SRO) 5 portable radiation instrument 1
Research Scientist (SRO) 11 pocket dosimeters 3. other reactor staff members 2
copies of EPIP's 1
MANE (NE) faculty 3
personal dosimetry storage racks 6
students 3
portable radios (police).
2 student visitors 1
portable radio (fire) 14 Totalindividuals 2
walkie talkies (new) 1 cellular phone 1
visitor's log 2
copies of EPIP's All personnel evacuated from the building to the gate area within five minutes. The personnel secountability procedure was completed in about two minutes. All individuals were either present at the assembly area or their badges were on the storage rack (with the exception of the Machine Shop Manager who leaves daily around 1:30pm and leaves his badge in the shop, it was noted that his car was not present).
The drill was ended at approximately 3:50pm.
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UNIVERSIW OF VIRGINIA NUCLEAR REACTOR FACluTY D5PARTMENT OF MECHANICAL, AEROSPACE AND NUCLEAR ENGINEERING MEMORANDUM March 311998 To:
Reactor Safety Committee From:
Paul Benne:he, Reactor Supervisor
Subject:
Annual Reactor Facility Evacuation Drill (via Criticality Alarm), March 31,1998 At approximately 2:52pm on March 31,1998 the Reactor Facility criticality alarm evacuation system was activated by me to generate a building evacuation. The UVAR reactor was not in operation at the time.
This alarm is initiated at the CAVALIER reactor room and is interconnected with the regular evacuation alarm system horns. The alarm was heard throughout the building and all homs were found to be working.
All personnel in the building evacuated to the assembly area within three minutes (2:55pm).
All personnel from inside the building were either accounted for at the assembly area or their badges were on the film badge racks (with the exception of the Machine Shop Manager who leaves his j
badge in the shop but has been on sick leave for an extended time following an operation). The following personnel (from inside the building) and equipment were accounted for at the assembly area by 2:59pm. The evacuation drill was concluded at 3:00pm.
One discrepancy was noted in the accountability list. A student whose badge had been canceled was still on the written list. This will be corrected.
1 Reactor Supervisor (SRO) 5 portable radiation instrument 1
Research Scientists (SRO) 10 pocket dosimeters 3
other reactor staff members 1
copy of EPlP's 1
Reactor Health Physicist 3
personal dosimetry storage racks 2
MANE (NE) faculty 3
portable radios (police) 4 students 1
portable radio (fire) 12 Totalindividuals 2
walk la talkies (new)
)
1 cellular phone 1
visitor's log