ML20080R415

Responds to NRC 831006 Ltr Re Violations & Civil Penalties Noted in IE Insp Rept 50-062/83-02.Corrective Actions: Procedures Implemented Requiring Proper Reactivity Measurements

ML20080R415
Person / Time
Site:	University of Virginia
Issue date:	11/03/1983
From:	Brenizer J, Williamson T VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20080R366	List: ML20080R415
References
EA-83-090, EA-83-90, NUDOCS 8402280275
Download: ML20080R415 (6)

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UNIVER5i,TYj OF VIRGINIAj g q.

SCHOOL OF ENGINEERING AND APPLIED SCIENCE CHARLOTTESVILLE. 22900 DEPARTMENT OF NUCLEAR ENGINEERING AND ENGINEERING 33rgCS'! PHYS 8 A9: 03 TELEPHONE: 804-924-7138 CEACTOR FACILITY November 3, 1983 Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Response to Notice of Violation and Proposed Imposition of Civil Penalty EA 83-90

Reference:

Inspection Report No. 5G-062-02

Dear Sir:

Attached is the University of Virginia Reactor (License No. R-66)

Facility's response to the Notice of Violation and Proposed Imposition of Civil Penalty (EA 83-90) as required by that notice. Also attached is a check (Check No. 105680) for $1000.00 to pay the imposed civil penalty.

Although we have decided not protest the civil penalty, we would like to note that we do not agree with all of the violations stated in the Notice (EA 83-90) and to emphasize our belief that, in this particular situation, the imposition of a civil penalty was excessive and not required to obtain management's attention and action. We would like to suggest that the NRC review the policy of imposing civil penalties on University licensees, to determine if such penalties serve the purpose of enhancing reactor safety.

Sincerely,

~Q L YW Swctn to trcJ vfdd 'd:'C C'2 lbu T. G. Williamson, Chairman J~~' ig[ Dept. of Nuclear Engineering 6; cf _. ,

and Engineering Physics

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j y [ fd_."":r;Pc:2 My Ccmmission Ex%res October 14,1985 ~ ~

- - "> % M JL4. Brenizer,4 1 rector Nuclear Reactor Facility cc: J. P. O'Reilly, Regional Administrator /

NRC,-Region II ,

l Recctor Safety Committee 8402280275 840216 gDRADOCK 05000062 PDR

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Response to Notice of Violation and Proposed Imposition of Civil Penalty Docket No.50-062 License No. R-66 EA 83-90

1. Response to particular violations A. Technical Specification 3.l(1) requires that reactor not be operated above lkw unless the minimum shutdown margin is greater than 0.4% delta k/k.

Contrary to the above, the reactor was operated at a power greater than lkw during the period May 25-30, 1983 without the required

. shutdown' margin.

Response

1) We admit that the reactor was operated at a power greater than lkw during the period May 25-30, 1983 without the required shutdown margin.

2) The violation occurred because the reactivity worth of a fuel element had not been. measured properly af ter its insertion into-the core, control rod worths were not required to be measured at specific intervals and a core configuration change was not

, quantitatively defined.

3) New procedures have been implemented which require proper measurement of the shutdown margin when changes are made in the core. The revised procedures'specifically define a core configuration change.

4) The revised procedures have been implemented and have been-incorporated in the training and requalification program. All senior operators were actively involved in the development of the new pro-cedures. New reactor operator trainees this summer were trained specifically on the importance of reactivity control.

5). Full compliance was achieved by implementation of procedures concerning reactivity measurements (Section 5 SOP) and incorporation of-procedural changes into'the operator requalification program.

These changes were implemented by July 5, 1983.

B. Technical Specification 4.l(2) requires that shim rod reactivity worths be measured whenever the rods are installed in a new core configuration. SOP 5.7 requires rod worth measurements be performed following core configuration changes.

Contrary to the above, a new core configuration existed resulting from core alterations made on May 20, but the required shim rod reactivity worth measurements were not made.

' Response:

1) We admit that shim rod reactivity worth measurements were not made

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Lafter core alterations on May 20.

)- 2) The reasons rod reactivity worth measurements were not made L 'was because, in our interpretation of the procedures in effect f; at that time, the core alterations on May.20 did not constitute a new core configuration.

3) We recognize the deficiency in the previous procedures which did not require that' shim rod reactivity worth measurements be made at' defined intervals. A core configuration change is now specifically and quantitatively defined in the procedures and rod calibrations ar'e performed when the core configuration is changed. In addition, the procedures now specify a time period for control rod recalibration based on the number of MW-days of operation.

. 4) . The revised procedures now define a core configuration change and require rod calibrations when-such change occurs. ,

5). Full compliance was achieved by July 5, 1983 by implementation of procedures concerning reactivity measurements (Section 5 SOP) and incorporation of procedural changes into the operator training and requalification program.

C. Technical Specification 6.3 requires that written approved procedures shall be in effect and followed for start-up, operation, and shutdown of the reactor and for the handling of fuel and experiments.

Contrary.to the above, the licensee did not have written approved procedures for determining reactor shutdown margin by accounting for changes in shutdown margin as a function of fuel manipulation, experiment manipulation, burnup, xenon concentration, or for calculating an esthmated critical position.

Response

1) . We pdmit.that we did not have written approved procedures specifically for determining reactor shutdown margin and for calculating estimated critical position. We deny that this is a violation of Technical Specifi-cation 6.3 because we had in place written approved procedures for start-up, operation, and shutdown of the reactor and for handling of the fuel and experiments. These procedures did require the determination of both the

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shutdown margin and the estimated critical position. We believe the difference is a matter of interpretation.by the inspectors as to the detail which must be covered by procedures. We believe that a perceived inadequacy of the'procedurec to cover in detail each particular operation

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is a judgement that should be the subject of discussion between the inspectors and the facility staff and is a matter which should be resolved without escalation to the categcry of a violation.

2) We deny that we violated our technical specification.

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~3) In spite of the' f act that we believe we did not violate Technical Specification =6.3, the startup, operation, and shutdown

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procedures'have been revised to include suggestions made by the inspectors. Specifically,=the~ procedures new specify the method of determining _and documenting the shutdown margin determination.

4) 'The. revised procedures have been implemented and have been incorporated in the training and requalification program.

-5)' Revised procedures concerning'startup, operation and shutdown of

'the reactor were incorporated by July 5, 1983.

II. ' Response-to other items covered in the notice of violation.

A.' 'We protest the statement "Further mitigation based upon

' corrective actions to prevent recurrence ,is not warranted because your long term actions were.not aggressively pursued".

u -The principal corrective actions to prevent recurrence was the revision of those section of the Standard Operating Procedures (SOP) relating to reactivity control, specifically section 5.

This section was rewritten, reviewed by the safety committee, th and in place by July 5, 1983. We also agreed to review and revise the entire SOP. -During the enforcement conference held at our facility on July'14, 1983, we agreed to have this completed by the end of-1983. We believe that completion by that date constitutes. an aggressive schedule in light of the magnitude of the job and'.the limits of staff time. We also note that the schedule. agreed to by the1NRC (Report No. 50-062/83-03) includes a completion date of revision of the SOP of December 31, 1983.

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The only difference betwe'en agreed upon schedule and the one we suggested at.the enforcement ^ conference is the details of completion dates for individual sections. We do not agree that this detailed schedule constitutes an act of aggressiveness which was lacking in our. proposed schedule.

5- We also stated at the enforcement conference that we would rewrite the Safety Analysis Report (SAR) by July'1984. After discussion with the NRC staff it was agreed that a complete rewrite and resubmission of the SAR was not necessary. We did agree to the creation.of an SAR like document with information in SAR Chapter 9 updated to include existing curved plate fuel analysis by October

'31, 1983. We believe this to be an aggressive schedule.

B. - .We agree that the violation can be classified as Severity III by Section 4 " changes in reactor parameters which cause unanticipated reductions in margins of safety". We do not agree that our situation warrants a civil penalty. The basis for our contention is that at no time was the public-health and safety compromised by this incident.

At no time was there any possibility of the reactor being super-critical-as we were always able to insert all rods to shutdown the

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reactor. Our procedures, which were in place at the time, require that:the operator note that the rods and their followers be fully 3

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4-inserted upon shutdown. At no time during the duration of the violation was.the reactor shutdown without assurance that all rods were inserted. Further, vc know of no evidence of solid blade type control rods, such as are in the UVAR, sticking in a research reactor core which has been in operation. Because the reactor was under control at all times and there was no realistic opportunity for an inadvertent supercriticality we believe that the imposition of a civil penalty magnifies the violation beyond its true significance.

III. Response to Items Noted in Letter from J. E. O'Reilly to J. S. Brenizer October 6, 1983;

Subject:

Proposed Imposition of Civil Penalty EA 83-90.

A. "We request that you include in your response corrective measures that you may take relating to the planning process and the conduct of independent audits following completion of work related to nuclear safetp."

Response

The reactor safety committee is an independent group which is charged with conducting periodic audits and is involved in the planning process.

We will request the reactor safety committee to consider further measures 3;-this area. We also are examining our staff organization to determine if planning and management efficiency can be improved.

B. "We believe it would be constructive for you to consider the desirability of conducting a " lessons learned" program for senior operators involved with the planning of core and experimental configurations."

Response

Since we have only six senior operators and all have been involved in the rewriting of procedures during the past several months,and all were involved in the evaluation of the violations, all are familiar with the

" lessons learned" from this incident. We have already included a " lessons learned" session in the training program for new reactor operators and have held two requalification lectures with all reactor operators and senior reactor operators. We will consider " lessons learned" programs in

[ the future.

g. IV. Response to Inspection Report No. 50-062/83-02 A. In the first paragraph of section 8, Corrective Action, the inspection report refers to minimum permissible critical rod position and predicted critical position and states that the licensee agreed to have a xenon worth curve developed and in use

!. by August 11, 1983.

Response

We do' pot believe that we agreed to have a xenon worth curve developed 4

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and in use by August:ll, 1983 and have no record of such agreement.

Specifically, the revised procedures which were reviewed by the inspectors during the' July 6-8, 1983 inspection, do not use the conception, or wording, of predicted (estimated) critical position.-

Without the requirement of a predicted critical position, a_ xenon worth curve is not res;* red for startup. In the revised procedures two reactor startup conditions are included. If the reactor is to be started from a shutdown condition with a constant source count rate, the procedures now require determining minimum permissible critical rod positions by adding the minimum shutdown margin (0.4% Ak/k) to the total worth of the highest worth rod and determining from the current rod worth curves the rod positions needed to. remove this amount of reactivity from the shutdown xenon-free core. Note that if the core is not xenon-free these positions beccme more conservative.

The minimum critical rod position is used as-a reference point to check for suberitical multiplication and instrument response, and to L

preclude operating at powers greater than'1 kw with a core which has an unacceotable shutdown margin.- The second condition is to start up

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the reactor from a shutdown condition with a decreasing source count

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rate. In this case, the positions of the shim rods at the time the

' reactor was last shutdown are used as the reference point for determining

,1 the presence of suberitical multiplication. The condition of a decreasing source count rate af ter shutdown persists for only about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> af ter extended 2 MW operation while the xenon reactivity worth does not peak until approximately 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after shutdown from extended 2 MW operation.

We have generated a xenon worth curve to determine the time after shutdown to the xenon free core, by August 11, 1983, however it was generated by solving the xenon equations for our reactor and had not been verified experimentally. The curves were experimentally measured on 10-10-83. Work is currently underway to develop a computer program to generate xenon worth curves for each new core configuration.

We are particularly disturbed to see the phases predicted critical position and estimated critical position in the report because we spent considerable time discussing this with the inspectors during both the June 2-3 and the July 6-8 meetings and were under the impression that our use of the concept'of a minimum permissible control rod position, rather than a predicted critical position, was agreed by all and that a xenon worth curve would not be required for startup.

B. On page 5 is included a. schedule of corrective actions.

Response

The schedule of revisions of the SOP, page 5, differs slightly from ours but we believe both meet the intent of having all revised procedures in place by December 31, 1983. Note, however, th at the reactor safety committee is an independent body and thus, we have agreed only to have the reactor safety committee review the procedures

.by the proposed'date. 'It is possible that the committee could request additional changes and rewriting before granting their final approval.

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