ML030020750
| ML030020750 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 01/15/2003 |
| From: | Beckner W NRC/NRR/DRIP/RORP |
| To: | Bill Russell Texas A&M Univ |
| Holmes S, NRC/NRR/DRIP/RORP, 415-8583 | |
| References | |
| IR-02-201 | |
| Download: ML030020750 (17) | |
See also: IR 05000128/2002201
Text
January 15, 2003
Dr. B. Don Russell, Deputy Director
Texas Engineering Experiment Station
1095 Nuclear Science Road
3575 TAMU
College Station, TX 77843--3575
SUBJECT: NRC INSPECTION REPORT NO. 50-128/2002-201 AND NOTICE OF
VIOLATION
Dear Dr. Russell:
This letter refers to the inspection conducted on September 17-20, 2002 at your Nuclear
Science Center (NSC) Reactor. The enclosed report presents the results of that inspection.
This special inspection was conducted in response to your loss of reactor pool water that
resulted in a declared Unusual Event and an uncontrolled radioeffluent release to the
environment. Areas of your reactor operations and health physics programs, directly related to
this event, were inspected. This included selective examinations of procedures and
representative records, interviews with personnel, and observations of the facility.
Based on the results of this inspection, the Nuclear Regulatory Commission (NRC) has
determined that a violation of NRC requirements occurred. The violation is cited in the
enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in
detail in the subject inspection report. The violation is of concern because it suggests a lack of
compliance with the requirements stated in your license. In addition, we are concerned that
operator inattention to detail appears to be a primary cause of the event.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
Dr. B. D. Russell -2-
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice", a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading
Room) http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning this inspection, please contact Mr. Stephen Holmes
at 301-415-8583.
Sincerely,
/RA/
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No. 50-128
Enclosures: 1) Notice of Violation
2) NRC Inspection Report No. 50-128/2002-201
cc w/enclosures:
Please see next page
Texas A&M University Docket No. 50-59/128
cc:
Mayor, City of College Station
P.O. Box Drawer 9960
College Station, TX 77840-3575
Governors Budget and
Planning Office
P.O. Box 13561
Austin, TX 78711
Bureau of Radiation Control
State of Texas
1100 West 49th Street
Austin, TX 78756
Dr. Warren D. Reece
Director, Nuclear Science Center
Texas Engineering Experiment Station
Texas A&M University
System F.E. Box 89, M/S 3575
College Station, TX 77843
Test, Research, and Training
Reactor Newsletter
202 Nuclear Sciences Center
University of Florida
Gainesville, FL 32611
Dr. B. D. Russell -2-
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice", a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading
Room) http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning this inspection, please contact Mr. Stephen Holmes
at 301-415-8583.
Sincerely,
/RA/
William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Docket No. 50-128
Enclosures: 1) Notice of Violation
2) NRC Inspection Report No. 50-128/2002-201
cc w/enclosures:
Please see next page
DISTRIBUTION:
PUBLIC RORP/R&TR r/f AAdams CBassett WBeckner LBerg
PDoyle TDragoun WEresian FGillespie SHolmes DHughes
EHylton PIsaac PMadden MMendonca BDavis (Ltr.only O5-A4)
NRR enforcement coordinator (Only for IRs with NOVs, O10-H14)
ACCESSION NO.: ML030020750 TEMPLATE #: NPR-106
OFFICE RORP:RI RORP:LA RORP:SC RORP:PD
NAME SHolmes:rdr EHylton PMadden WBeckner
DATE 01/ 13 /03 01/ 08 /03 01/ 14 /03 01/ 15 /03
C = COVER E = COVER & ENCLOSURE N = NO COPY
OFFICIAL RECORD COPY
NOTICE OF VIOLATION
Texas A&M University Docket No. 50-128
Texas Engineering Experiment Station Nuclear Science Center License No. R-83
During an NRC inspection conducted on September 17-20, 2002, a violation of NRC
requirements was identified. In accordance with the "General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR 50.10 (a) states that "Except as provided in §50.11, no person within the United States
shall transfer or receive in interstate commerce, manufacture, produce, transfer, acquire,
possess, or use any production or utilization facility except as authorized by a license issued by
the Commission.
Section II.C.(2) of NRC License No. R-83, Amendment No. 15 dated November 1, 1999, states
that; The Technical Specifications contained in Appendix A, as revised through Amendment
No. 15, are hereby incorporated in their entirety in the license. Texas Engineering Experiment
Station/Texas A&M University System shall operate the facility in accordance with the Technical
Specifications.
Technical Specifications, dated March 1983, Section 6.3 requires that operating procedures
"shall be in effect" for startup, operation, and shutdown of the reactor.
Contrary to the above, as demonstrated by the following examples, the licensee failed to
operate its facility in accordance with the Technical Specifications.
1) On September 17, 2002, the change in operating procedures for the diffuser system
was not documented in the shift change notebook as required by Standard
Operating Procedure II.D.5.
2) On September 17, 2002, the diffuser pump was not shutdown at the end of
operations as required by Nuclear Science Center Form 534, Facility Security
Shutdown Checklist--Daily Surveillance.
3) On September 18, 2002, four hundred eighty gallons of liquid effluents were release
to the environment prior to being analyzed as required by Standard Operating
Procedure VII.C9.
This is a Severity Level IV violation (Supplement IV ).
Pursuant to the provisions of 10 CFR 2.201, Texas A&M University is hereby required to submit
a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 within 30 days of the date of the letter
transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to
a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if
contested, the basis for disputing the violation or severity level, (2) the corrective steps that
have been taken and the results achieved, (3) the corrective steps that will be taken to avoid
further violations, and (4) the date when full compliance will be achieved. Your response may
reference or include previous docketed correspondence, if the correspondence adequately
-2-
addresses the required response. If an adequate reply is not received within the time specified
in this Notice, an order or a Demand for Information may be issued as to why the license should
not be modified, suspended, or revoked, or why such other action as may be proper should not
be taken. Where good cause is shown, consideration will be given to extending the response
time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of NRCs
document system (ADAMS), to the extent possible, it should not include any personal privacy,
proprietary, or safeguards information so that it can be made available to the public without
redaction. ADAMS is accessible from the NRC Web site at (the Public Electronic Reading
Room) http://www.nrc.gov/NRC/ADAMS/index.html. If personal privacy or proprietary
information is necessary to provide an acceptable response, then please provide a bracketed
copy of your response that identifies the information that should be protected and a redacted
copy of your response that deletes such information. If you request withholding of such
material, you must specifically identify the portions of your response that you seek to have
withheld and provide in detail the bases for your claim of withholding (e.g., explain why the
disclosure of information will create an unwarranted invasion of personal privacy or provide the
information required by 10 CFR 2.790(b) to support a request for withholding confidential
commercial or financial information). If safeguards information is necessary to provide an
acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Rockville, Maryland
this 15th day of January 2003
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
Docket No: 50-128
Report No: 50-128/2002-201
Licensee: Texas A&M University
Facility: Texas Engineering Experiment Station
Nuclear Science Center
Location: College Station, Texas
Dates: September 17-20, 2002
Inspector: Stephen W. Holmes, Reactor Inspector
Approved by: William D. Beckner, Program Director
Operating Reactor Improvements Program
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
EXECUTIVE SUMMARY
This special reactive, announced inspection was conduced in response to a declared Unusual
Event that included an uncontrolled radioeffluent release to the environment. The inspection
included onsite review of selected aspects of the reactor operations and health physics
programs. This facility is a one megawatt research reactor and at the time of this event was
operating four to five days a week with a second shift two to three days a week. Three
apparent related failures to follow procedures were identified.
On the morning of September 17, 2002 the Texas A&M TRIGA Reactor staff notified NRC
Headquarters of an Unusual Event. The notification was triggered, according to their
Emergency Plan (EP), when the reactor pool low-level alarm activated due to the loss of
approximately 8,000 gallons of water from the pool. The water was lost from the reactor pool
when a leak developed in the diffuser pump discharge piping. The water drained to the building
sump and was automatically pumped to the outside waste tanks.
At approximately 7:00 A.M. EDT Tuesday, September 17, 2002, during their checks of the
research center, the university police observed water spewing from the top of one of the three
10,000 gallon outside waste tanks. They immediately contacted the reactor supervisor (RS) at
his home. The RS arrived at the research center within 20 minutes and reconfigured the waste
tank valves to halt the overflow. He entered the reactor building and identified the loss of
reactor pool water. The RS then located the source of the leak (the diffuser pump pumping
water out through a separated discharge line connection) and secured the pump and
associated valving. The RS started refilling the pool using the demineralizer system in
accordance with procedures. During this time the low level alarm had activated putting the
facility into an Unusual Event as described in their EP. Reactor staff performed their
notifications to the NRC and other entities as required by the EP. At 9:20 A.M. EDT that
morning the event was terminated when the low-level alarm reset as the pool refilled to its
normal level.
A conference call regarding this event was held on September 17, 2002 with representatives of
the Texas Engineering Experiment Station Nuclear Science Center and the NRC Research and
Test Reactors Section staffs. The licensee stated that at no time could the reactor core be
uncovered during this event. The licensee estimated that less than 1000 gallons overflowed
from the tank onto the tank pad and then to the surrounding ground. Additionally, the licensees
preliminary analysis of the tank contents identified Sodium-24 at a concentration of about
4 percent of 10 CFR 20, Appendix B, Table 2, Column 2, limits for continuous release to the
environment.
An NRC inspector was dispatched from headquarters that afternoon and began an inspection
of the event Wednesday morning, September 18, 2002.
In investigating the root cause of this event the licensee has preliminarily identified a number of
items that may have contributed to it. The licensee has performed a number of corrective
actions for this event and is evaluating further corrective and preventive actions.
Plant Operations
- Written procedures for reactor operations were available as required by Technical
Specification Section 6.3.
-2-
- Operating logs and records reviewed provided an indication of operational activities.
However, they did not document the modified operating condition of the diffuser system.
Specifically, this condition was not noted in the shift change notebook as required by
Standard Operating Procedure II.D.5. This was a failure to follow procedure.
- The diffuser pump was not turned off at shutdown as required by Nuclear Science
Center Form 534, a second instance of failure to follow procedures.
- The inspector confirmed that, as required by Technical Specification Section 5.7, the
diffuser pump intake was no deeper than fifteen feet from the top of the reactor pool.
Therefore, the reactor core could not have become uncovered due to loss of water
through the diffuser system as a minimum of thirteen feet of water would have covered
the core when system draining would have stopped.
Radiation Counting Equipment
- Counting lab instruments were being maintained and calibrated as required by licensee
procedures. Counting system results would be acceptable to determine compliance with
NRC requirements.
Liquid Effluent Monitoring and Release
- Current procedures for sampling, analyzing, and releasing liquid wastes were clear,
concise, and accurately reflected liquid effluent amounts, concentrations, and release
fractions to the environment. The unintentional liquid effluent release was less than
5 percent of 10 CFR 20, Appendix B, Table 2 limits for continuous release to the
environment and thus did not exceed regulatory requirements. However, since this
release was not analyzed before release, as required by Standard Operating Procedure
VII.C9, this constitutes a third instance of failing to follow procedures.
Licensee Corrective Actions
- The connections on the diffuser pump discharge are going to be modified to reduce the
chance of future failure and other piping connections would be evaluated for similar
modifications.
- The waste tanks are going to be modified to allow them to overflow into each other,
reducing the likelihood of an uncontrolled release.
- Tag-out procedure will be used when equipment is operated outside its normal
parameters.
- The shift change log is going to be evaluated to insure it is relevant and useful to
turnover requirements.
- The facility shutdown checklist is going to be evaluated for inclusion of a final physical
walk through of the facility after reactor shutdowns.
REPORT DETAILS
Summary of Event Follow-up
In response to this event, the inspector reviewed the operational circumstances that attributed
to the drain down of the reactor pool and the inadvertent release of liquid effluent to the
environment. Additionally, the inspector reviewed pertinent sections of the licensees
instrument calibration and effluent programs to confirm and verify the licensees evaluation of
the release to the environment.
1. PLANT OPERATIONS
a. Inspection Scope (Inspection Procedure (IP) 69001)
The inspector reviewed selected aspects of:
- operational logs and records
- staffing for operations
- selected operational, startup, or shutdown activities
- Standing Operating Procedure (SOP) Reactor Startup II.C, Revision 4, March 2, 2001
- SOP Steady State Operation II.D, Revision 1, September 3, 1999
- NSC Form 533, March 25, 2002, Reactor Operations Facility Checklist-Daily
Surveillance
- NSC Form 534, January 25, 2000, Facility Security Shutdown Checklist--Daily
Surveillance
- SOP Maintenance and Surveillance of Support systems, VII.D, Revision 1, June 6,
1999
b. Observations and Findings
1) Diffuser System
The diffuser system draws water from the mid pool level (no deeper than
fifteen feet from the top of the pool as required by TS Section 5.7.C.) The
water is directed through nozzles over the top of the reactor core. This water
stream disrupts the thermal column rising from the core and breaks up the
bubbles of radioactive nitrogen sixteen (N-16) in the column, increasing the
time it takes for the gas to reach the surface of the pool. This results in
decreasing the radiation exposure at the pool surface produced by the short
half life N-16. Although not required by TS nor considered a part of the
reactor safety systems, licensee SOP II.C.3.b requires that the diffuser be
operating during power levels of 400 kilowatts or greater.
During startup, Monday, September 16, 2002, the console switch for the
diffuser pump failed. The licensee subsequently bypassed the control room
switch and used the diffuser pumps breaker box switch directly to operate
the diffuser. Operations staff then continued with the reactor startup and
normal operations.
-2-
Although the facility SOP contains a tag-out procedure, it was not used. The
reactor staff stated that they did not consider using it because it only
addresses equipment actively being maintained/repaired or undergoing
surveillance testing. The inspector confirmed that for this operating condition
the tag-out procedure was not required to be used. The licensee stated that
the tag-out procedure will be revised and used when equipment is operated
outside its normal parameters. This procedure revision will be reviewed in a
future inspection. This item is identified as Inspector Follow-up Item (IFI)
50-128/2002-201-01.
2) Shift Turnover
At the time of this event, the reactor was operating on a two-shift schedule.
During the shift turnover briefing that afternoon, the oncoming senior reactor
operator (SRO) was verbally briefed by the day shift SRO of the modified
operating condition of the diffuser system. A short time later the electronics
technician showed the SRO where the breaker switch was and how to use it
to operate the diffuser pump. Although the oncoming SRO was thus
informed of the change from normal operating procedures, it was not
documented in the shift change notebook as required by SOP II.D.5. The
failure of the licensee to operate its facility in accordance with TS Section 6.3
by not adequately following operating procedures for startup, operations, and
shutdown of the reactor is identified as Violation 50-128/2002-201-01. The
licensee stated that the shift change log will be used to ensure relevant and
useful turnover requirements are communicated. This will be reviewed
during a subsequent inspection. This item is identified as Inspector Follow-
up Item 50-128/2002-201-02.
3) Shutdown
At 8:55 P.M. CST reactor power operations were terminated for the evening.
As part of the shutdown the reactor needed to be moved to the opposite side
of the pool to provide irradiation of samples using decay gammas from the
core. This requires disconnecting the diffuser discharge piping at the top of
the reactor bridge. When the SRO disconnected the piping to move the
reactor, the diffuser pump was deadheading against the closed quick
disconnect. After moving the reactor, which took more time than normal due
to multiply difficulties, the SRO turned the control room diffuser pump switch
to the off position. Since the switch was bypassed this did not turn off the
pump. The SRO neither noted that the pump on light was still illuminated nor
remembered to turn the pump off at the breaker box as instructed. The
licensees failure to follow a procedure and not shut off the diffuser pump is
another example of Violation 50-128/2002-201-01. The SRO then finished
the facility security shutdown checklist-daily surveillance (NSC Form 534,
January 25, 2000), annotated that the diffuser pump had been turned off, and
secured and left the reactor. The licensee stated that the facility shutdown
checklist will be revised to include a final physical walk through of the facility
after reactor shutdowns. This will be reviewed during a subsequent inspection
and is identified as IFI 50-128/2002-201-03.
-3-
4) Diffuser pump connection failure
The diffuser pumps are located on the mid-level equipment area, called the
chase. The pumps outlets are connected to the system PVC piping through
flexible piping using a screw on compression fitting. In discussion with
licensee staff, the inspector found that the connection had unscrewed. This
allowed the pump to discharge pool water onto the chase floor. The water
then flowed through floor grates down to the lower floor and into the
demineralizer sump. From here the water was automatically pumped to the
waste tank header and filled the open tank.
The licensee could not determine if the connections failure was caused by the
pump deadheading, normal operation vibrations, or other factors. The
licensee stated that the connections on the diffuser pump discharge would be
modified to reduce the chance of future failure and that other piping
connections would also be evaluated for similar modifications. These
modifications will be evaluated during a subsequent NRC inspection and is
identified as IFI 50-128/2002-201-04.
5) Inspector Findings
By review of design drawings and direct measurements, the inspector verified
that the suction for the diffuser pump was less than fifteen feet from the top of
the reactor pool, as required by TS Section 5.7. Thus, a minimum of thirteen
feet of water would have covered the core. The inspector therefore
determined that the reactor core could not have become uncovered due to
loss of water through the diffuser system.
c. Conclusions
Based on the procedures and records reviewed and the observations made during the
inspection, the inspector determined that two cases of failure to follow procedures had
occurred.
2. RADIATION COUNTING EQUIPMENT
a. Inspection Scope (IP 69001)
The inspector reviewed selected aspects of:
- maintenance and calibration of radiation monitoring equipment
- periodic checks, quality control, and test source certification documentation
- SOP Calibration of Gas Flow Proportional Counters, VII.B16, Revision 4,
December 19, 1997
1999
2000
-4-
- calibration source certificates
b. Observations and Findings
Gamma analyses of liquid effluents are performed on an ORTEC HPGe GEM--20180
gamma spectroscopy system utilizing a Canberra GENIE 2000 software package.
When appropriate, representative samples are evaporated and counted for alpha/beta
constituents on a Ludlum 2200 gas flow proportional counter. Efficiency calibrations are
done annually using a three-liter merinelli mixed gamma source, and Technetium-99 and
Thorium-230 planchet sources, respectively. Additionally, energy calibrations, using a
Europium-152 secondary source, are performed on the HPGe system prior to each
analysis.
The inspector confirmed that the licensees gamma spectroscopy and gas flow
proportional counter system calibration procedures and frequencies satisfied licensee
and 10 CFR 20.1501(b) requirements, and the American National Standards Institute
N323 "Radiation Protection Instrumentation Test and Calibration" or instrument
manufacturers' recommendations. The inspector verified that the calibration and check
sources used were traceable to the National Institute of Standards and Technology and
that the sources geometry and energies matched those used in actual
detection/analyses.
Based on the review the inspector determined that licensee analytical results of liquid
effluents using their counting systems would be acceptable to determine compliance with
NRC requirements.
c. Conclusions
The inspector determined that counting lab instruments were being maintained and
calibrated as required by licensee procedures. Counting system results would be
acceptable to determine compliance with NRC requirements.
3. LIQUID EFFLUENT MONITORING AND RELEASE
a. Inspection Scope (IP 69001)
The inspector reviewed the following to verify compliance with the requirements of
10 CFR Part 20 and TS Sections 3.7, and 6.6.1.f)1).
- SOP Radioactive Liquid Waste Disposal, VII.C.9, Revision 3, May 10, 2000
- daily pool water sample analysis sheets
- alpha, beta, and gamma analyses for the September 17, 2002, overflow
- Environmental Analysis Report dated, September 19, 2002
b. Observations and Findings
-5-
The research center is located at a remote area off campus and is not serviced by a
sanitary sewer system. This situation requires that the NSC discharge liquid waste
directly to the environment. Therefore, the licensee purposely maintains the reactor pool
water radioactive material concentrations as low as possible. At the time of the overflow,
the facility had just completed their two-week annual shutdown of the reactor. This
resulted in a core power history less than 10 percent of normal, thus minimizing
concentrations in the pool even further.
Radioactive liquid waste at the NSC flows to the sump in the demineralizer room, where
it is pumped to the outside liquid waste tanks. Liquid waste from the NSC is held in three
above ground fiberglass tanks, each having a capacity of 10,000 gallons. Since the
tanks cannot overflow into each other, a vent is located near the top of each tank to
equalize pressure during filling operations. When the volume of water exceed the
capacity of tank three, the excess overflowed through this opening onto the concrete pad
and then to the ground. The licensee stated that the waste tanks will be modified to
allow them to overflow into each other, reducing the likelihood of an uncontrolled release.
This modification will be reviewed during a subsequent inspection and is identified as
IFI 50-128/2002-201-05.
The tanks have a recirculating water system to stir the liquid waste providing a
homogeneous mixture prior to sampling. Liquid wastes are routinely sampled and
analyzed in accordance with SOP VII.C.9, verified to meet 10 CFR 20, Appendix B,
Table 2, Column 2, concentrations, and then released to the environment. The inspector
verified that the current procedures for sampling, analyzing, and releasing liquid wastes
were clear, concise, and accurately reflected liquid effluent amounts, concentrations,
and release fractions to the environment.
Reactor pool water levels and waste tank effluent levels are checked and recorded each
day. Based on the September 16 and 17, 2002, readings the licensee determined that
480 gallons of reactor pool water was discharged unanalyzed from waste tank No. three
to the environment during this event. The licensee performed gamma spectrum and
alpha/beta analyses on water samples from the affected tank in accordance with SOP
VII.C.9. Gamma analyses identified Sodium 24 (Na-24) and Manganese 54 (Mn-54),
activated contamination and corrosion products normally found in research reactor pool
water. Gas flow proportional counting of evaporated samples identified beta activity
consistent with that attributed to the Na-24 concentration. No alpha activity was
identified. The licensee calculated the total effluent concentrations to be less than
5 percent of 10 CFR 20, Appendix B, Table 2 limits for continuous release to the
environment.
The inspector reviewed the September 16 and 17, 2002, reactor pool water and waste
tank effluent level documentation and confirmed the licenseess determination that 480
gallons of water was released to the environment during this event. The inspector also
verified the licensees gamma and alpha/beta analyses showing that the effluent
concentrations were less than 5 percent of 10 CFR 20, Appendix B, Table 2 limits for
continuous release to the environment.
Although the effluent concentrations were within regulatory limits for release to an
unrestricted area, the inspector determined that a violation of NRC requirements had
-6-
occurred. Since the release was not analyzed prior to discharge, this is a violation of
both TS Section 3.7, which states in part that liquid effluents "shall be analyzed" before
discharge and SOP VII.C9 which states in part that liquid waste concentrations "must be
determined" prior to release. The licensees failure to follow procedure and determine
the liquid waste concentration prior to release is another example of Violation
50-128/2002-201-01.
c. Conclusions
Liquid effluent releases satisfied regulatory requirements. A third case of failing to follow
procedure was identified.
4. EXIT MEETING SUMMARY
The inspector presented the inspection results to members of licensee management at the
conclusion of the inspection on September 20, 2002. The licensee acknowledged the
findings presented and did not identify as proprietary any of the material provided to or
reviewed by the inspector during the inspection.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
M. Spellman Assistant Director, NSC
B. Smith Senior Reactor Operator
D. Bagley Senior Reactor Operator
J. Remlinger Operations Manager, NSC
D. Reece Director, NSC
L. Vasudevan Radiation Safety Officer, NSC
INSPECTION PROCEDURE (IP) USED
IP69001 Class II Non-Power Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
VIO 50-128/2002-201-01 Failure to follow procedures on three individual incidences
IFI 50-128/2002-201-01 The licensee would evaluate the tag-out procedure for use when
equipment is operated outside its normal parameters.
IFI 50-128/2002-201-02 The licensee would evaluate the shift change log to insure it is
relevant and useful to turnover requirements.
IFI 50-128/2002-201-03 The licensee would evaluate the facility shutdown checklist for
inclusion of a final physical walk through of the facility after reactor
shutdowns.
IFI 50-128/2002-201-04 The licensee would modify the connections on the diffuser pump
discharge to reduce the chance of future failure and evaluate
other piping connections for similar modifications.
IFI 50-128/2002-201-05 The licensee would modify the waste tanks to allow them to
overflow into each other.
Closed
NONE
PARTIAL LIST OF ACRONYMS USED
NRC Nuclear Regulatory Commission
NSC Nuclear Science Center
RS Reactor Supervisor
SRO Senior Reactor Operator
SOP Standing Operating Procedure
TS Technical Specification