IR 05000160/1985002
| ML20134N244 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 08/12/1985 |
| From: | David Loveless, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20134N231 | List: |
| References | |
| 50-160-85-02, 50-160-85-2, NUDOCS 8509050052 | |
| Download: ML20134N244 (11) | |
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UNITED STATES pWEcoq'o f NUCLEAR REGULATORY COMM!5SION
[ p REGloN ll 3 j 101 MARIETTA STREET. * E t ATLANTA, GEORGI A 30323 l
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Report No.: 50-160/85-02 Licensee: Georgia Institute of Technology 225 North Avenue Atlanta, GA 30332 Docket No.: 50-160 License No.: R-97 Facility Name: Georgia Institute of Technology Research Reactor (GTRR)
Inspection Con ted: Ju 8 - 16, 19 5 .
Inspector:
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D. P. Loveless
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D' ate Sihned Approved by:
Bruce Wilson, Sect um M / ~2 f[
Dite Signed Operator Licensing [on Chijff Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection involved 46 inspector-hours on site in the areas of logs and records, organization, review and audit, requalification training, procedures, refueling, surveillance testing, experiments, observation of operations, plant tours of the GTRR and AGN-201, open items and previous enforcement actions. Also, one area involved licensed operator examinations, which resulted in an enforcement conference conducted in the Region II offic Results: Of the eleven areas inspected, no violations or deviations were identified in five areas. Five violations were identified in five areas (Logs and Records -
Paragraph 7; Procedures - Paragraphs 5 and 6; Requalification Training -
Paragraph 9; Surveillance Testing - Paragraph 6; and Review and Audit -
Paragraph' 11). ~ One deviation was identified in one area (Licensed Operator Examinations - Paragraph 15).
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. n REPORT DETAILS Persons' Contacted'
Licensee Employees
- R. A. Karam,~ Director,' Nuclear Research Center
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- L. D. McDowell, Reactor Supervisor W. H. Downs, Reactor Operator R. M.-Boyd, Radiological Safety Officer M. F. Mercer, Electronics Specialist J. E. Taylor, Manager, Hot Cell Operations P. Sharpe, Safety Engineering Assistant J. L. Rodgers, Administrative Secretary Other licensee employees contacted included technicians and office personne NRC Regional Personnel
- P. E. Fredrickson, Section. Chief
- A. K. Hardin, Project Engineer
- Attended exit interview- Exit Interview The inspe'ction scope and findings for~all items excluding the deviation were summarized on July 16,1985, with those- persons indicated in -paragraph 1 above. The inspector described the areas inspected and discussed in. detail the inspection findings listed below. The licensee acknowledged the
. inspection findings without exceptio The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspecto during this . inspection. The' licensee was notified by telephone on July 22,
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1985, concerning the licensed operator; examination problems. An enforcement conference was scheduled and subsequently conducted on July 25, 198 . Licensee Action on Previous Enforcement Matters
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L(Closed). Deviation 160/77-04-10 In Inspection Report- 50-160/77-04, the licensee-was cited for failure to review its emergency plan semi-annually per licensee's. Safety Analysis Report (SAR). Reviews are evidenced by periodic update of the plan, and the licensee is currently in compliance, as they are implementing a new NRR
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' ' approved emergency _ plan. This appears to be adequate to resolve the above concern. The licensee conveyed some confusion as to the significance of the
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NRC approval. The inspector reiterated that the. licensee was still account-i .able_for all SAR commitments concerning the emergency pla .
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' (Closed)-Severity Level V violation 160-84-01-01 The~ licensee' was cited for failure to .have an adequate procedure (two examples). The violation involved non-incorporation of required temporary changes into - the permanent approved procedur Both cases were corrected per licensee's response dated April 26, 198 Furthermore, all procedures were reviewed by the licensee's Nuclear Safeguards Committee for incorporation of " pen-and-ink" changes. This was deemed adequate to resolve the above concer (Closed) Severity Level-V violation 160/84-01-02
'The-licensee was cited for-failure to hold quarterly meetings of the Nuclear
. Safeguards Committee and failure to distribute minutes properly as required by Technical Specification (TS) 6.2.c. _ The licensee initiated. action to establ.ish meeting dates and to . provide for proper distribution of the minutes. This response dated April 26, 1984, was deemed to be adequate to
- resolve the items of noncomplianc . Unresolved Items Unresolved items were not identified during this inspectio . Procedure Revie The following procedures were reviewed during the course of the inspection:
1000 New Fuel Element Inspection
'1500 Irradiated Fuel. Discharge to Storage Pool 1501 ' Lower Top-Shield Plug Removal From-Spent Fuel 1502 Fuel Handling in the Core -
-3101 Definition of Experiment Categories 3102 Quality' Assurance for Experiments 3103 Operation of Experimental Facilities 3104 Pneumatic Tube Transport System 2006- Weekly Reactor Shutdown Checklist 7203 ECCS'- Monthly Surveillance 7220 Building Isolation Test . .
7222: ECCS - Semiannual and Annual-Surveillance-7225 -Primary Coolant. System - Mechanical
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Hot Cell' Checklist Health Physics Procedures 7241 LI-D1. Check
'720 Control Rod Drop Time-
'4000- . Containment Building' Pressure Test
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4901 Preventive / Corrective Maintenance on Safety-Related Equipment In addition, the following procedures received thorough walkdowns: Procedure 7220, Building Isolation Test-The inspector verified this procedure to be technically adaquate and to meet the requirements of the licensee's Technical Specification. The test is performed using calibration sources in order to check the entire channel in one tes Procedure 7203, Emergency Core Cooling System (ECCS) - Monthly Surveillance
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The . inspector noted that during the low reactor level test, the operator would drain down the reactor locally until he heard the reactor isolation valves closed. This is contrary to the procedure which requires the operator to drain the reactor until the low D 20 level control room alarm is received. Although the intent of the procedure is~still met, this is failure to utilize the procedure and is in violation of T.S. 6.4.b.7. Technical Specifications require that procedures be followed and prescribe proper methods for procedure change when needed. This is the first of three examples of Violation 160/85-02-0 Procedure 7202, Control Rod Drop Time The inspector noted that the licensee had updated this procedure to include set-up and running the Hewlett Packard Universal Counter as a corrective action to violation 84-01-01. This was deemed adequate; but because of equipment failure, the licensee used an oscilloscope as the timing device in performance of this procedure in May and June of 198 Again, methods slightly different from that specified in the procedure were used, but no temporary change was made to.the procedure. This is a violation of T.S. 6.4.b.7 and is the second example of Violation 160/85-02-0 During the -course of the inspection, additional procedures were given complete walkdowns. These walkdowns were in order to determine technical adequacy, operator familiarization and proper utilization of the procedures. The following procedures were reviewed without-identifying error:
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7222, ECCS - Light Water Addition Test
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.7225, Primary Coolant System:- Mechanical
-- 3104, Pneumatic Tube Transport System
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1502, Fuel-Handling in the Core * , Preventive / Corrective Maintenance on Safety-Related Equipment
- Further documentation of this walk-through is documented in
[ paragraph ~12-of this report.
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The inspector observed that all procedures audited had been reviewed by the Nuclear Safeguards Committe It was further noted that all maintenance reviewed, that was not covered by approved procedure, was done under properly approved maintenance job plans per procedure 4901. Finally, the inspector verified that all work audited was done under a 4900, " System Work Sheet," as required administrativel . Surveillance Testing Surveillance requirements in the licensee's technical specifications were reviewed to determine that procedures existed for accomplishing the specificatio The licensee's program for scheduling and tracking of surveillance testing was reviewed and deemed to be adequate. Next, selected surveillance tests were reviewed by the inspector. These included:
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Control Rod Drop Time of Shim-Safety Rods
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Drive Time of Regulating Rod
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ECCS - Tests and Timing
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ECCS - Lightwater Addition Capability
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Containment Building Pressure Test
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D2 0 Level Channel Checks and Calibration This review involved examination of records, proper tracking, completeness and technical adequacy of procedures to meet the surveillance requirement During the course of this review, the inspector noted that procedure number 7241, LI-01 Check, had been scheduled and performed on an annual basis since 1978. Licensee's T.S. 4.2.a referencing Table 4.1, item 6, requires the D 20 level channels to be calibrated semi-annually. The failure to semi-annually performs the LI-01 calibration is in noncompliance with T.S. 4.2.a and will be addressed as violation 160/85-02-0 Table 4.1, item 6, also requires that a channel check of the D 0 level
channels be performed on a weekly basis. As part of this requirement, procedure 2006, Weekly Reactor Shutdown Checklist, requires testing of the reactor scram and ECCS initiation concurrent with low reactor level ( $12 inches below overflow T.S. 4.2.a, Table 4.1).
The procedure checks all associated signals at low reactor level; however, the actuai reactor level at which these occur is never absolutely verified or recorded. The license states that the level is checked; however, the procedure, as is, does not require level verification and is inadequate to perform the surveillance reqairement of T.S. 4.2.a. Inadequate procedures
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for performance of a surveillance requirement is in violation of T.S. 6.4. This item will be tracked as a third example of violation 160/85-02-0 ~
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7. Logs and Records Annual Report - GTRR The annual report for the GTRR was reviewed and found to moet the reoutrements of T.S. 6. Records T.S. 6.5.a and 6.5.b require that certain records be retained for five years and other records be maintained for the life of the facilit The. inspector selected several records in each of these categories and requested the licensee to retrieve the record The licensee demonstrated the records were on file and readily retrievabl . Console Log The reactor console log was reviewed for the period January 1984 to June :1985. The inspector found operating log entries to be complete, adequate and traceable to additional event documentatio Discussion of six selected events found that safety significant events had been reviewed and were sent to the Nuclear Safeguards Committee for further review as necessary. The inspector observed that the console logs had been audited by the Nuclear Safeguards Committee for 198 The licensee committed at the exit of NRC inspection 84-01 and in later correspondence dated April 26, 1984, to initial log entries made during periods of reactor shutdown. This factor of traceability was added to the logs-beginning April 26, 1984, but began to taper off approximately six months late Examples of this are entries for the dates November 26 and December 24, 1985, and January 8, 11, 14, 16, 17, and 22, 1985. The licensee was reminded of its commitment and. agreed to correct the error. This item will be tracked as Inspector Followup Item IFI 160/85-02-0 System Workbook Log The licensee's System Workbook is. used to schedule and track -all periodic work _done on the plant including ' preventive maintenance, surveillance testing, and system inspections. The inspector reviewed
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the log for the preceding. quarter and found it to be up-to-date and complet l Plant Drawings -
Technical Specification ' 6.5.b.6 - requires the licensee to maintain updated, corrected, and as-built facility drawings. During the plant tours, the inspector found numerous errors -in the facility flow diagrams including a test connection in plant that is not on the drawings, . ar valve on the drawing and not in the plant', and piping ,
system. connections. in ths. plant that are < inconsistant with th I drawings; A111 drawing errors found by the inspector were identified to
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_the licensee. These errors are multiple examples of violations of .5.b.6. -This item will be referred to as violation 160/85-02-0 . Organization The inspector verified that the organization for the Georgia Tech. Reactor meets the requirements of T.S. 6. It was further verified that the Reactor Supervisor and. the Reactor Engineer meet the minimum qualification requirements of T.S. 6. Finally, a spot check of the console log verified that the licensee met the minimum crew complement requirements of T.S. 6.1'.d when the reactor was operational. No violations or deviations were identified in this are . Requalification Training The inspector determined that all licensed personnel had taken the 1984 requalification exam required by the licensee's approved _ program dated August 5, 1984. Furthermore, all personnel received an overall passing grade. A single reactor operator (RO) received less than 80 percent in the area of Radiation Control and Safety. The licensee did not initiate appro-priate retraining. The program requires, " Tutoring and individual study and/or preplanned -lectures." The retraining should also include an appro-priate schedule including examinations covering .the areas 'of deficienc When identified to the licensee by the inspector, the licensee immediately
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- initiated corrective action. The above item is in violation of 10 CFR 50.54.1-1 which requires operator requalification training and will be tracked as violation 160/85-02-0 . Experiments The inspector reviewed approximately ten percent of the licensee's experiments listed from January 1, 1984, to June 30,1985 ;This review included adequacy.of procedures, use. of procedures, review and audit, and ccmpleteness of documentation. Most of the experiments conducted are relatively routine and 'present little hazard to the reactor, the reactor personnel, or to the public. Two experiments reviewed were noted as being significant. .One involved a hot " rabbit" being inadvertently sent to the
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wrong. location causing a criticality alarm and. subsequent manual scram of the reactor. The second event involved a pinhole leak'in a phosphorus lined can. Both problems were handled according to procedures and both received adequate Nuclear Safeguards' Committee review. No violations or deviations were identified in this are . Review and Audit Functions The Nuclear Safeguards Committee (NSC) minutes for the GTRR were reviewed for the period January 1,1984, through June 30, 1985. Seven meetings.were conducted during the period. The inspector verified'that the composition of the- Committee, collective experience of the members, quoru'm requirements, and subjects reviewed' met the requirements of T.S. 6.2. The inspector noted that Jthe NSC was" conservative _ in its approach, and reviewed more than requi-ad'by ,,
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One area of noncompliance was identified. T.S. 6.2.c requires the Committee to meet quarterly. Previous interpretation by both the NRC and the licensee determines this to mean 13 weeks i 25 percent. After the February 4,1985 meeting, the' next meeting was not until June 13, 198 Exceeding the maximum interval between meetings is a violation of T.S. 6.2.c and will be addressed as violation 160/85-02-0 The inspector observed that the NSC had conducted audits of the operations of the plant during the spring of 1985. These reviews involved procedures, experiments, and day-to-day operations. The . committee had identified' one area of concern to the inspector. Non-console log documentation of startups existed without documentation of a shutdown. Conversely shutdown checklists were found without matching startups. -This audit is a major agenda item for the next HSC meeting. The licensee committed to having these discrepancies
reviewe The inspector reviewed documentation of the only modification done at the plant during the previous year. This modification which replaced a nuclear detector -with a new design was determined to be done in accordance with applicable procedures and T.S. Furthermore, the inspector noted that a 10 CFR 50.59 review was done and the modifit tion deemed r.ot to be an unreviewed safety questio . Refueling No major refueling has been performed by the licensee since the last inspection. However, during the dates from January 9,1984, to January 11, 1984, a core shuffle was performed to insure the fuel in the Irradiated Fuel Storage Holds is self protecting (>100 rad /hr. at 1 meter). The procedures and documentations~ were reviewed for adequacy, completeness, and~ adherence to Technical. Specifications. The inspector verified that the procedures met the requirements and were followed during the evolutio The inspector noted that in Procedure 1502, " Fuel Handling 'in the Core," the precautions require that if the count rate on the nuclear instrumentation doubles ~ during an evolution that fuel handling should cease until the situation can be evaluated. However, no step in the core shuffle procedure
,. reminds or requires the . operator to look at his instrumentatio The licensee agreed that this was a potential deficiency-and that they would look into the matte No violations or deviations were identified in this are . 'Open Items i
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. The licensee committed _ to bringing plant drawings- up-to-date by including 'l modifications made since the last update. These items are currently in the plant drawings and documentation of a complete drawing review exist l
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(Closed) IFI 160/84-01-0 Concern over the disposition of AGN-201 Reactor was raised with this ite The licensee has NRC approved decommissioning plans. The inspector reviewed the status of the reactor, including a paperwork review, plant tour and interviews with the plant staf The reactor has been defueled and the water in the vessel tested with sati sfacto ry result Completion of decommissioning should come about by the end of the year. Based on this review and the results of this inspection in the affected functional area, the item was determined to require no additional specific followup and is close . Independent Inspection Effort The inspector reviewed several operational events, including a paperwork review and operator interviews. The most nuteworthy is described here. On December 14, 1984, during a cooldown after a 4500 KW run, the reactor operator received a low D0 2 level alar The operator immediately determined by control room indication and by the vessel level column that the reactor level was holding. Following Procedure 5000, " Objective and Code for Emergency Procedures", the cperator verified the air compressor was functional and thus verifying the validity of the LI-01 control room level indicator. After determining that there was no water leakage in tne process room, the operator went to reset on the . ECCS signal . When the ECCS spray valves would not close, the operator manually closed the block valves. The circulatory pumps were restarted to continue the cooldown and the level was monitored closelv for possible re-initiation of ECC The inspector veri fied that the operator's actions were correct and procedura He also verified that proper documentation and review of the event was performed. No viciations or deviations were identified in this are . Licensed Operator Examinations On July 10 and 11,1985, two reactor operator candidates for the GTRR were examined by a Region II licensed operator examiner. The eligibility of the applicants to take the exam was based on NRC Form 398s, Personnel Qualification- Statement - Licensee, submitted on June 5 and July 10, 198 On the NRC Form 398, the Director, Nuclear Research Center, certified that the applicants had " learned to operate the controls in a competent and safe manner." Grading of the written portion of the examination revealed that the candidates' knowledge of reactor operations was significantly below the minimum acceptable level required to operate the facility satisfactoril The acceptance crite.ria for the written exam is a 70 percent in all seven areas. Not only did neither candidate attain a 70 percent in any one area, but the overall scores for each applicant were both approximately 40
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percent. Although an applicant failing an NRC exam does, of itself, not necessarily reflect ' negatively on the certification provided by the licensee, the complete apparent lack of reasonable operations control
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knowledge exhibited by these two candidates places doubt as to the validity of the certificatio '
This failure to ensure that the two_ applicants adequately learned to operate the reactor controls as certified on the NRC Form 398 is identified as a deviation from an NRC commitment, given in the form of the NRC 398 certification (160/85-02-07). A subsequent enforcement- conference was conducted concerning this matter and is discussed in paragraph 1 . Enf'orcement Conference Introcaction An enforcement conference was held with~ Georgia' Institute of Technology on July 25,1985, at 1:00 p.m. in the Region II Office of Inspection and Enforcement. The purpose of.the meeting was to discuss the quali-fication requirements for personnel nominated by the licensee to take the NRC operator licensee examination for the Georgia Tech Research
Reactor (GTRR) docket 50-16 A.ttendees
) NRC Roger: D. Walker, Director, Division of Reactor Projects (DRP)
Region II
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Albert F. Gibson, Acting Director, Division of Reactor Safety (DRS)
Region II David M. Verrelli, Chief, Project Branch No. 1, DRP George R. Jenkins, Director,' Enforcement and Investigation
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Coordination Staff (EICS)
_ Paul E. Fredrickson, Chief Project Section IC, DRP
' Bruce Wilson, Chief, Operator Licensing Section, DRS
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Leo P. Modenos, Enforcement Specialist, EICS
-Austin K. Hardin, Project Inspector, DRP
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Georgia Institute of Technology
- .Dr. Ratib A. Karam, Director, Nuclear Research Center
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L. Dean McDowell, Reactor Supervisor
_ Meeting Summary The Division Director,' Reactor Projects, introduced the participants
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'and stated the purpose of the meeting. The Acting Director, Division of Reactor Safety, d'scussed the NRC's position relative to:the licensee's. responsibility in designating a candidate for NRC. licensed operator examination and requested the licensee to discuss the process
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they determined the candidates are adequately trained and have a reasonable potential for successfully passing an NRC license examinatio Dr. Karam stated they did not have formal classroom training to directly qualify personnel as operators for the GTRR. They teach one course, three hours / week 1for one quarter, relative to general reactor theory and reactor operation plus each candidate works with a qualified operator and learns by observatio Dr. Karam stated he believed the two candidates designated.were capable of passing the examination sirce they had trained the individuals consistent with previous reactor operator applicants and the candidates had led them to believe they were prepared for the exa Dr. Karam stated that the candidates did express doubt about their ability to pass the exam shortly before the exam was given, but he felt that the uneasiness could be accounted for by the students' nervousness and not by lack of ability. The NRC raised questions concerning the licensee's interpretation of the NRC Form 398 certification and the licensee's responsibility to ensure that its candidates are prepared to take the NRC exam. Dr. Karam stated that although the research center had provided some training for the applicants, their readiness for the exam'was based on th individuals' own determinatio The NRC then addressed the specific responsibility as addressed on the NRC Form 398 for the licensee to not only train the applicant on the reactor but also to develop some -
mechanism to satisfy the certifier that the applicant can, in fact,
" operate the controls in a competent and safe manner."
A general' discussion ensued as to the actions which Georgia Tech should take. The three major improvements addressed were-the need for a more structured training program, more rigorous criteria for selection of candidates, and better assessment of the candidates' capability and knowledge following trainin l The licensee agreed with the above items related to .inproving operator candidate preparatio The NRC stated that the discussion and exchange of views was most helpful and that the licensee's comments would be considered in further evaluatio .
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