ML20265A397

Reed College - Response to Notice of Violation 05000288/2020201

ML20265A397
Person / Time
Site:	Reed College
Issue date:	09/21/2020
From:	Frantz S Reed College
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR 2020201
Download: ML20265A397 (2)

Text

REED COLLEGE September 21 , 2020 IUACTOR FAC ILI TY 3203 Southeast Document Control Desk Woodstoc k Boulevard U.S. Nuclear Regulatory Commission Portland,Oregon Washington, DC 20555-001 97202-8199 Re: Response to Notice of Violation 50-288/2020-201-01 telephone Docket 50-288 503/777-7222 fax This letter is the Reed Research Reactor's response to the subject Notice of Violation (NOV) 503/777-7274 dated September 2, 2020. The NOV is not being contested.

email The NOV states, in part:

reacror@reed.ed u Reed Research Reactor technical specifications (TS) Section 3.4, "Ventilation web System," requires that the reactor not be operated unless the ventilation system is http://reactor.reed.edu operable in the normal or isolation mode. On May 25, 2018, ventilation system isolation damper V -11 failed to close during ventilation surveillance system testing due to a failed actuator. Since V -11 failed to close during surveillance testing, the ventilation system was not operable. The V -11 actuator was replaced and retested successfully on July 26, 2018. However, the reactor was operated regularly from May 25, 2018, through July 26, 2018.

Therefore, contrary to TS 3.4, from May 25, 2018, through July 26, 2018, the Reed Research Reactor was operated without the ventilation system being operable.

1. The reason for the violation.

The reason for the violation was an incorrect interpretation of TS 3.4 which states:

Specifications. The reactor shall not be operated nor irradiated fuel moved unless the facility ventilation system is operable in one of the following operational modes:

a. Normal mode: The exhaust, supply, and control room fans are operating. The reactor bay pressure is maintained negative with respect to the control room.

b. Isolation mode: Isolation mode as initiated by high radiation readings on the continuous air monitor. The exhaust and control room fans are operating. The reactor bay pressure is maintained negative with respect to the control room and all exhaust is diverted through a HEPA filter.

The reactor staff incorrectly interpreted this as meaning that the TS was satisfied if the ventilation system was operating in either the Normal mode or the Isolation mode. This interpretation did not fully consider the word "operable" in the second line of the specification. TS define "operable" as:

Operable: A system or component is operable when it is capable of performing its intended function.

The intended function of the ventilation system includes switching to the isolation mode with the isolation button. TS 5.4 states, in part:

The ventilation system shall be equipped with inlet dampers that can be closed from the control room. Closing the inlet dampers changes the ventilation system into isolation mode.

Therefore, the cause of the violation was an incorrect interpretation of the TS. The root cause appears to be a lapse in the Safety Culture at the reactor. The Director did not use a conservative interpretation of the TS and did not thoroughly review the situation.

2. The corrective steps that have been taken and the results achieved.

The ventilation system damper was repaired on July 26, 2018 thus enabling remote and automatic operation of the damper. This returned the system to operable status.

3. The corrective steps that will be taken to avoid further violations.

This incident will be covered as part of a special Safety Culture lecture at a Requalification Meeting to be held this semester. The lecture will include the need for taking conservative interpretations of our documents and the need to fully resolve questions before proceeding.

4. The date when full compliance will be achieved.

When the ventilation system was repaired on July 26, 2018 we returned to compliance. The Requalification Meeting will be held September 28, 2020.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: September 21, 2020 Sincerely, d~z~~

Interim Reactor Director Reed College cc Kathryn Oleson, Ph.D., Dean of Faculty Greg Casto, Chief, Non-Power Production and Utilization Facility Licensing Branch Travis Tate, Chief, Non-Power Production and Utilization Facility Oversight Branch