ML20023B905

Responds to NRC 830316 Ltr Re Violations Noted in IE Insp Rept 50-128/82-03.Corrective Actions:Training Sessions Conducted for Reactor Operations Personnel to Demonstrate Proper Preparation of Ice Bath

ML20023B905
Person / Time
Site:	05000128
Issue date:	04/12/1983
From:	Porter W TEXAS A&M UNIV., COLLEGE STATION, TX
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
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ML20023B904	List: ML20023B905
References
NUDOCS 8305090073
Download: ML20023B905 (8)

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i TEXAS ENGINEERING EXPERIMENT STATION Tile TI:X AS \&M UNIVERSITY SYSTI:M Zachry Engineering Center Texas A&M University College Station, Texas 77843 (713)845-1321 Ornce i,r the ihrn tor 12 April 1983 Mr. G. L. Madsen, Chief Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza, Suite 1000 Arlington, Texas 76011 Ref: Docket No. 50-128/82-83, License R-83

Dear Mr. Madsen:

In reference to the inspection of the Nuclear Science Center Reactor on December 20 and 21, 1982 by Mr. G. L. Constable concerning operation of the NSCR in ex-cess of licensed steady state power, the following is submitted in reply to the notice of violation in your letter of March 16, 1983.

Stated Violation Texas A&M University facility license, Section 2.A, requires that the reactor be operated in accordance with limitations described in the license. The following are three examples of a failure to adhere to license conditions in-volving one event.

1. Section 3A requires that the licensee may operate the reactor at steady state power levels up to a maximum of 1000 Kilowatts (thermal). Contrary to the above, on December 4 and 6,1982, the Texas A&M pool reactor was operated at approximately 1370 kilowatts (thermal).

2. Technical Specification, Section 3.3.3, " Reactor Safety System," requires that the reactor shall not be operated unless the safety channels (power level) function to scram the reactor when steady state power level exceeds 125%.

8305090073 830504 DR ADOCK 05000128 PDR RESEA R CH AND DE VE L OPM EN T FOR M A N KIND

Mr. G. L. Madsen Page 2 Contrary to the above, reactor safety channels (power level) were not operable during the period December 4 through 9,1982, due to an improperly conducted power level calibration test resulting in non-conservative calibration of the power level indicators that caused the reactor trip point to be set at about 157% of licensed steady state power level.

3. Technical Specification, Section 6.7, " Reporting Requirements," requires that a report be made to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and tele-graph of a violation of a limiting condition for operation (LC0).

Contrary to the above, the Texas A&M facility was in violation of LC0 3.3.3, " Reactor Safety System," (Item 2 above) from December 4 through 9, 1982. The licensee did not report this condition to the NRC until December 17, 1982.

Innediate Corrective Actions Taken to Avoid Further Violations and the Results of These Actions Following the investigation into the cause of error in the pool calorimetric measurement of December 4,1982, it was concluded that three significant factors contributed to the incident of violation of steady state licensed power. As a result of these findings, NSC management took imediate action in regard to correcting the following:

1. An improperly prepared reference ice bath which produced an error of approximately 37% in the measured heatup rate during performance of the calorimetric.

2. A weakness in reactor operator training that contributed to Item 1 above.

3. Failure of NSC management to provide adequate guidelines in the 50P's to reduce errors of judgement concerning the magnitude of the power adjustment that was made following the calorimetric. Also the S0P's did not point out the importance of observing certain reactor operating and facility para-meters following the calorimetric to verify normal reactor operations.

This reflected an operating philosophy lacking in awareness of and attention to changing parameters and reasonable questioning of these changes.

In reference to Items 1 and 2 above, special training sessions were held for reactor operations personnel to demonstrate the proper preparation of an ice bath. A special plastic holder was fabricated to maintain a fixed position of the thermocouples placed in the ice bath. This holder provided for the use of a thermometer to monitor the ice bath during performance of thg pool caforimetric p6 cedure. A thermometer with a temperature range of -5 C to

+5 C with 1/20 C scale increments was secured. It is now possible to monitor the ice bath with extreme accuracy to detect any error associated with the ice bath. The plastic holder also eliminates any possibility that a junction

j Mr. G. L. Madsen Page 3 could accidently touch the metal walls of the ice bath thermos. This new equipment has been used on three occasions and has provided assurance that the ice bath is not introducing errors into the performance of the calorimetric procedure. The training which was conducted using the new ice bath equipment has resulted in operations personnel being aware of the initial ice bath error and what to look for to prevent a reoccurrence in the future.

In reference to Item 3, a directive was issued and noted in the reactor operations log restricting adjustments of the reactor power level following a calorimetric. Adjustments that result in an increase in reactor power shall not exceed 10% of the actual measured power. This directive will be followed until the pool calorimetric S0P for reactor power measurement is reviewed and final restrictions and guidelines are established as scheduled in Appendix A.

At present a 100 sheet is being kept in the reactor control room that reflects area radiation monitor (ARM) readings and facility air monitoring readings at one hour intervals. This has been helpful in pointing out changes in building radiation levels due to experiments and facility activities such as maintenance or the handling of radioactive materials. Having documented changes in radiation levels due to specific experiments and other facility activities, changes resulting from reactor operations can be more readily identified.

In addition to facility radiation monitoring, the new log sheet provides for the recording of control rod heights for 1 Mw operation, and a comparison with previous heights is made on a daily basis. Any large changes require an explanation such as the effect of Xenon or experiments in the reactor.

The log sheet also requires a documented tour of the facility by a SR0 at 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> intervals during reactor operations. This tour provides information concerning facility activities. Already these measures are aiding operations personnel in day-to-day observance of operating reactor and facility parameters.

Future Corrective Steps Which Will be Taken to Avoid Further Violations As discussed in the Enforcement Conference of March 4,1983, maximum effort will be placed on the review of existing S0P's to evaluate their effectiveness con-cerning actions taken for correcting abnormal operating conditions and guidelines on decision making. In this regard a list of SOP's and a tentative schedule for their review is attached as Appendix A.

In addition to the S0P review, NSC and Nuclear Engineering Department staff plan to investigate further the parameters of the pool calorimetric that could lead to errors in the measurement. As an example, initial investigation indicates that the equilibrium conditions for the pool water, pool shield walls and reactor building environment are very important. Allowable variances in initial conditions need to be detennined and limits established and incorporated in the S0P for the pool calorimetric procedure.

Mr. G. L. Madsen Page 4 Achievement of Full Compliance In regard to maintaining licensed steady state reactor power by the performance of the pool calorimetric procedure, it is felt by the NSC management that compliance has been achieved. This has been demonstrated by the satisfactory performance and results of pool calorimetric measurements following changes to equipment, special training of reactor operations personnel, and the placing of interim restrictions on the magnitude of power level increase adjustments resulting from the pool calorimetric. Immediate actions were taken to achieve compliance concerning the stated violation; however, a longer time frame is required to achieve review of S0P's and to fully establish ai operating philosophy of awareness of changes in reactor and facility parameters and how, by monitoring, they can be used to improve reactor and personnel safety. The time frame for S0P review is indicated in Appendix A.

Comments and Clarification of the Stated Violation The statement of violation that the reactor safety channels (power level) were "not operable" is misleading and implies that this system was not certified operational as per Technical Specification 4.3.2(b) during the period December 4 through December 9, 1982. It is realized that the trip settings of the safety amplifier would result in a reactor trip at 157% of licensed power, however, the system was in operation and would have performed its intended safety function as stated in Technical Specification 3.3.3. That function is to protect the fuel from damage due to an unsafe condition by preventingg opergting temperatures in excess of the safety limit for FLIP fuel (1150 C or 2100 F). Based on the above arguments it is respectfully requested that the violation be clarified to indicate that the safety channels were operating during the stated period although with a nonconservative trip point setting that would result in a reactor trip of about 157% of licensed steady state power.

Closure It is important to the Texas Enginecring Experiment Station that the Nuclear Science Center continue to operate in a safe and competent manner as has been its past history. Even though this occurrence was not a significant threat to public safety, it is important that the areas of weakness contributing to this event receive our immediate attention and maximum efforts to upgrade and correct them. In particular we are sensitive to identified delays in reporting this incident to the NRC. Such has not been the demonstrated track record of the NSC in the past and will not be the case in the future.

All levels of management from the NSC up through this office are committed to reporting to the NRC in the future even the potential existence of a reportable event or occurrence. This commitment, plus the emphasis discuss + 1 above on fully establishing a more questioning attitude and philosophy on the past of all NSC operations staff, should preclude such delays in identifying, reporting, and correcting problems in the future.

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Our facility has a high utilization, and we are looked upon by other TRIGA ,

reactor facilities for leadership. We plan to maintain that position within '

the research reactor comunity. We will be happy to provide additional ' '

information concerning this event and we share your concerns for preventing

• a reoccurrence. s' i(

Sincerely. -

W. Arthur Porter Director cc: Feenan Jennings, Chairman Reactor Safety Board x

., .. .s C. A. Erdman, Head a Department of Nuclear Engineering and Head, Nuclear Engineering Research D. E. Feltz, Director Nuclear Science Center i

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s APPENDIX A REVIEW OF STANDARD OPERATING PROCEDURES Based on a preliminary review of standard operating precedures (SOP's) for the Nuclear Science Center the following procedures have been prioritized for modification, review, and approval on the timetable provided. Quarterly Reactor Safety Board meetings will be held to obtain the necessary review and approval once the revisions have been made and local NSC approval has been obtained. It should be noted that these procedures are considered essential' for day-to-day operations and are therefore, receiving first pricrity. An 18 month period (6 quarters) is considered to be adequate for completing this-review and modification. However, it is also planned to review the remaining chapters of the S0P's not included in this schedule in a tentative time frame of an additional 6 months. Therefore, over the next two years we feel that a complete, up to date, set of SOP's will be developed. The following schedule will be: implemented May 1, jl983, and RSB meetings will be' scheduled" toward the latter part of each. quarter:

1st Quarter (1 May 1983 - 31 July 1983)

S0P II-B Operations Records ' '

II-E Pulsing Operation II-J Power Calibration II-L Pulse Calibration III-C Linear Power Measuring. Channel Maintenance and Surveillance III-P '

Millivolt Potentiometer. Maintenance and Surveillance VII-A Health Physics Administration 2nd Quarter (1 August 1983 - 31 October 1983)

S0P II-C Reactor Startup II-D Steady State Operation ,

II-F Reactor Shutdown II-K Control Rod Calibration III-G Reactor Pulse Power Surveillance IV-A Experiment Approval VII-B1, VII-B12 Health Physics Maintenance and Surveillance t

3rd Quarter (1 November 1983 - 31 January 1984)

S0P III-A General (Reactor Maintenance and Surveillance)

III-B Fuel Element Temperature Measuring Channel Maintenance and Surveillance III-D Log-N Measuring Channel Maintenance and Surveillance IV-B Sample Handling Procedure II-H- Fuel Manipulations II-I Reactor Core Manipulations VII-B13, VII-B17 Health Physics Maintenance and Surveillance 4th Quarter (1 February 1984 - 30 April 1984)

S0P II-M Response to Alarms III-E Safety Power Measuring Channel Maintenance and Surveillance III-F Pulse Power Measuring Channel Maintenance and Surveillance III-J Transient Rod Drive Maintenance and Surveillance IV-C Pneumatic System Operation IV-G In-Pool Irradiations VII-Cl, VII-C5 Radioactive Materials Control 5th Quarter (1 May 1984 - 31 July 1984)

S0P II-A General Organization and Responsibilities II-G Movement of Reactor Bridge II-N Response to Abnormal Reactivity Changes III-I Scram Circuit Surveillance III-K Control Rod Inspection III-L Control Rod Drive Maintenance III-M Annual Control Rod Calibration and Determination of Shutdown Margin VII-C6, VII-C15 Radioactive Materials Control

6th Quarter (1 August 1984 - 31 October 1984)_

S0P II-0 Reactor Operator and Senior Reactor Operator Requalification Program III-N Reactor Bridge and Pool Light Maintenance III-0 Reactor Pool Surveillance III-Q Special Nuclear Materials Accountability III-R Evacuation Horn System Surveillance IV-D Beam Port Experiments IV-F Neutron Radiography Beam Port No. 4 VII-D Health Physics Training VII-E Personnel Dosimetry As previously noted Chapters I and VI will be reviewed for necessary changes following the completion of this schedule. The security and emergency plan Chapters (VIII, IX) will be reviewed separate to this schedule to implement the recently approved facility license renewal.

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