IR 05000128/2014201

Texas A&M Univ., Reply to a Notice of Violation for Inspection Report 05000128/2014-201

ML14323A095
Person / Time
Site:	05000128
Issue date:	11/12/2014
From:	McDeavitt S Texas A&M Univ
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2014-0068
Download: ML14323A095 (3)

Text

JWtin TEXAS A&M ENGINEERINGNr I EXPERIMENT STATIONNUCLEAR SCIENCE CENTERNovember 12, 2014 2014-0068U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject: Reply to a Notice of Violation Inspection Report No. 50-128/2014-201(License R-83)This memo represents the reply from the Texas A&M Engineering Experiment Station(TEES) Nuclear Science Center (NSC) regarding the Notice of Violation (NOV) receivedas part of the routine inspection report No. 50-128/2014-201. The U.S. Nuclear RegulatoryCommission (NRC) conducted a routine inspection of the NSC on September 15-18, 2014.On September 18, 2014 The NRC discussed the preliminary findings with NSC and TEESpersonnel.As discussed at the inspection outbrief, the NSC welcomes the scrutiny that comes withour current situation. We deeply regret the conditions that contributed to the NOV and areworking to rectify underlying factors to achieve a new level of performance. This is aserious matter and the following items review the violation and the steps that have beentaken to advance the closure of the matter.The notice of violation documented in the report is as follows:Technical Specifications Section 6.1.3. a. 2 states that "The minimum staffing whenthe reactor is not secured shall be as follows.: a licensed reactor operator or seniorreactor operator shall be in the control room. "Contrary to the above, on July 25., 2014, the licensed operator on duty left thecontrol room for a period of two and one-half minutes while the reactor wasoperating at one megawatt.The following items present our response to the four topics required by the NOV:(1) The reason for the violation, or, if contested, the bases for disputing the violationor severity levelThis violation occurred because of lack of operational awareness in the controlroom staff. It was determined that current procedures did not require signatorytransfer of responsibility for control room operators. This method of operations wasin place at the NSC for several decades and, while it was never violated before, itdid enhance the potential for operational transgression.(2) The corrective steps that have been taken and the results achievedTEL. 979.845.7551 1 FAX 979.862.2667nsc.tamu.edu1095 Nuclear Science Rd. I 3575 TAMU I College Station, TX 77843-3575 In response to the noted violation, a number of steps were taken as a result of thistransgression.1. On the day of the event, the licensed operator on duty was suspended fromperforming licensed duty while the NSC conducted an internal investigationand initiated retraining.2. To facilitate and drive home the retraining requirement designed by NSCmanagement, the licensed operator on duty who left the control roomunstaffed prepared and conducted training on Technical SpecificationsSection 6 for all licensed operators at the NSC.a. Following the completion of this training exercise on September 4,2014, the suspension ended on that date.3. The NSC Director approved a revised administrative procedure requiringthe licensed operator on duty to also be the licensed operator of record inthe log book. This procedure results in an increased awareness amongcontrol room staff of who holds immediate responsibility for fulfillingcontrol room staffing requirements.4. The Texas A&M University System (TAMUS) and TEES initiated acompliance audit that is ongoing that has included a review of thesecorrective actions. The efficacy of these actions will be monitored by TEESleadership and the University Reactor Safety Board.These corrective steps are intended to achieve increased awareness amongcontrol room staff and to clarify the identity of the responsible licensed operatorat all times.(3) The corrective steps that will be takenThe new administrative sign-in procedure was implemented on September 29, 2014with a 60 day trial period to work through implementation challenges. Thisprocedure will be reviewed in mid-November by comprise seeking input from thelicensed operators and management staff at the NSC regarding lessons learnedabout the effectiveness of the procedure. Recommended improvements ormodifications will be evaluated and incorporated into the final procedure. Theprocedure will be implemented in final form effective November 28, 2014.(4) The date when full compliance will be achievedWhile we are currently operating in full compliance with technical specificationsand the new sign-in procedure, the review of the procedure is under way and thfinal version will not be effective until November 28, 2014. However, since thatdate falls on a holiday, the effective date that the NSC will begin operations thenew procedure will be December 1, 2014. That is the date when we will be able toconfirm with documentation that we are in full compliance.As I indicated at the inspection outbrief, I regard this to be a significant matter worthy.ofthe attention being focused on it. We welcome additional input and recommendations to further improve operations at the NSC. If you have any questions or comments, pleasecontact me at mcdeavittgtamu.edu or 979-845-7551 (NSC Phone).Sean McDeavittDirector, Nuclear Science CenterXc: 2.11 /central fileDirector, Office of Nuclear Reactor RegulationMike Morlang, U.S. NRC Inspector