ML23017A035
| ML23017A035 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 01/16/2023 |
| From: | Joel Jenkins Texas A&M Univ |
| To: | Arellano J NRC/NRR/DANU |
| References | |
| Download: ML23017A035 (3) | |
Text
From: Jenkins, Jere H. <jere@tamu.edu>
Sent: Monday, January 16, 2023 3:32 PM To: Juan Arellano Cc: Holly Cruz; Patrick Boyle; Waer, Richard M.; Kurwitz, Abby; Vlassov, Viktor Y
Subject:
[External_Sender] Report of Technical Specification Violations, and violation of parts of 10 CFR 50.59.
Dear Mr. Arellano,
As discussed in our video conference last week, The Nuclear Science Center Reactor (NSCR, License R-83, Docket 050-0128) is reporting two separate sets of violations of the following Technical Specifications as a result of actions taken by NSCR staff in 2018:
- TS 4.5.1 - The area radiation monitoring system (ARM) and the FAM system shall be calibrated annually, shall be channel tested weekly, and shall be channel checked prior to reactor operation.
- TS 6.2.3.1 - [The review responsibilities of the Reactor Safety Board or a designated subcommittee shall include, but are not limited to the following:] Review and evaluation of determinations of whether proposed changes to equipment, systems, tests, experiments, or procedures can be made under 10 CFR 50.59 or would require a change in Technical Specifications or license conditions; Current NSCR staff cannot find a 50.59 review of the procedure change described below, so it is likely that the 2018 NSCR staff also violated 10 CFR 50.59.(c).(1).i and 50.59.(d).(1) as a result of their actions.
The Technical Specifications and regulations cited above were violated by actions taken in January of 2018, and again in November 2018, by separate actions related to the same system.
Description of Actions Leading to the Violations On 1/30/18, NSCR staff created a Procedure Change Notice (PCN) numbers 18-1 changing the NSCR Procedure VII-6B rev. 4 to make the Monthly Facility Air Monitoring Test a quarterly test. The justification for the change reads as follows:
The current Tech Specs, section 4.5, specification 1, states that the FAM systems shall be calibrated annually. This fact, in accordance with historical data, has led us to determine that a quarterly calibration is more than sufficient to correct for any variation in the system.
This PCN was signed by the Manager of Operations, the Radiation Safety Officer, the Associate Director of Operations, and the Director. It should be noted here that the procedure VII-B6 rev. 4 (dated 09/14/2007) was already not in compliance with Technical Specification 4.5.1, which requires that the channel be tested weekly, when the procedure required monthly tests.
This procedure change would have required a change to Technical Specification 4.5.1, which is a violation of 10 CFR 50.59.(c).(1).i, and there was no review by the Reactor Safety Board (RSB) in 2018, or at the previous RSB meeting in 2017. Thus, there was also a violation of TS 6.2.3.1. Since there was no record of a 50.59 review, the NSCR is also in violation of 10 CFR 50.59.(d).(1).
On 11/19/2018, a memo was issued by the Associate Director, who was also the Radiation Safety Officer, altering how the Facility Air Monitor channels were calibrated. The memo described a different interpretation of the existing procedures for quarterly testing (already not in compliance with TS 4.5.1) and annual calibration. This memo was issued to the Radiation Safety Program File and was not reviewed by the Facility Director or the Reactor Safety Board. Furthermore, there is no documentation of a 50.59 review of this change, and the procedures were not changed to reflect any of the new practices.
These procedure changes would have required a change to Technical Specification 4.5.1, which is a violation of 10 CFR 50.59.(c).(1).i, and there was no review by the Reactor Safety Board (RSB) in 2018 or 2019. Thus, there was also a violation of TS 6.2.3.1. Since there was no record of a 50.59 review, the NSCR is also in violation of 10 CFR 50.59.(d).(1).
Corrective and Other Actions Being Taken The following actions are being taken:
- 1. Calibration of the Facility Air Monitors will be performed in the next two weeks to bring the facility into compliance with TS 4.5.1.
- 2. Channels Tests will be conducted weekly to bring the facility into compliance with TS 4.5.1.
- 3. A detailed report of these violations will be prepared in the next 30 days for review by the Reactor Safety Board, and for your review during the next inspection.
Should you have any questions, or require further information, please do not hesitate to contact me.
I declare under penalty of perjury that the foregoing is true and correct, executed on 16 January 2023.
- Signed, Jere Jenkins Jere Jenkins Director-Reactor Facilities; Nuclear Engineering & Science Center Texas A&M Engineering Experiment Station jere@tamu.edu; (979) 845-7551 (o); 765.426.8972 (m)
Hearing Identifier: NRR_DRMA Email Number: 1911 Mail Envelope Properties (BN9PR11MB548105C5597EB329988D793EB5C19)
Subject:
[External_Sender] Report of Technical Specification Violations, and violation of parts of 10 CFR 50.59.
Sent Date: 1/16/2023 3:32:20 PM Received Date: 1/16/2023 3:32:35 PM From: Jenkins, Jere H.
Created By: jere@tamu.edu Recipients:
"Holly Cruz" <Holly.Cruz@nrc.gov>
Tracking Status: None "Patrick Boyle" <Patrick.Boyle@nrc.gov>
Tracking Status: None "Waer, Richard M." <rwaer@exchange.tamu.edu>
Tracking Status: None "Kurwitz, Abby" <caitlin.kurwitz@tamu.edu>
Tracking Status: None "Vlassov, Viktor Y" <yevgenievich@tamu.edu>
Tracking Status: None "Juan Arellano" <Juan.Arellano@nrc.gov>
Tracking Status: None Post Office: BN9PR11MB5481.namprd11.prod.outlook.com Files Size Date & Time MESSAGE 4492 1/16/2023 3:32:35 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: