ML20216H042

Forwards Response to NRC 970818 Ltr Re Violations Noted in Insp of License R-059 on 970721-25.Corrective Actions:Last Three Required Surveillance Activities Were Completed on 970108

ML20216H042
Person / Time
Site:	University of Iowa
Issue date:	09/08/1997
From:	Bullen D IOWA STATE UNIV., AMES, IA
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9709160120
Download: ML20216H042 (4)

Text

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r Docket No. 50116 September 8,1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Reply to a Notice of Violation Dear sir; i

Please find attached the response to the Notice of Violation received by towa State University from the U.S. Nuclear Regulatory Commission on August 18,1997.

Sincerely, osm }

Dr. Danie'l B. Bullen, Facility Director c: American Nuclear Insurers A.F. Rohach, Chm, Reactor Use Committec E.E. Sobottka, Dir., Emironmental Health & Safety J.L. Melsa, Dean of Engineering R.A. Jacobson, Chm., Radiation Safety Committec S.E. Wendt, Reactor Manager T. M. Burdick, U.S. NRC, Region 111 801 Warrenville Road Lisle, Illinois 60532 '

W.R. DeVries, Chm., Mechanical Engineering Department W.R. Madden, Vice President for Business & Finance  !

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Violation The UTR 10 reactor was operated on December 31,1996 w hile three required annual safety system surveillance actisitics were incomplete.

Reason for violation At the time, the Reacter Manager was under the (incorrect) assumption that a 110% grace period existed for suncillance periods. Because of this he did not consider the three suncillance requirements in question to be overdue. Reactor operations were scheduled for December 31 in order to perform a fourth required (but not overdue) surveillance procedure. Unlike the three overdue surveillance activities, this procedure required the presence of two or more qualified staff. Because these qualified staff would not be available after December 31, it was decided to delay the three overdue surveillance requirements in order to complete the fourth. The three surveillance requirements were scheduled to be completed later in the week uhen only a single staff person would be available.

Both the limited availability of qualified staff and the incorrect assumption of a grace period led to the siolation.

Corrective steps that have been taken and the results achieved The last of the three required surveillance activities was completed on January 8,1997. The facility is in compliance with NRC regulations.

Corrective steps that will be taken to avoid further violations The following st?ps have been or will be taken:

1. An additional permanent staff member has been added to the reactor staff on a % time basis. This will ensure the availability of two qualified individuals on a regular basis.

2. Surveillance activities will be completed with no assumed grace period.

3. The annual surveillance and maintenance activities will be scheduled and performed on a continuous basis instead of all during a short period of time. This will now be possible because of the additional staff member and will prevent a large work load during any one period of time.

4. An amendment to the Technical Specifications will be submitted w hich adds the definitions for the terms monthly, quarterly, and annually. The new definitions will incorporate an allowed grace period for future surveillance activities which is similar to those that exist at other facilities.

Date w hen full compliance will be achieved Full compliance with NRC regulations was achieved on January 8,1997 aller completion of the three overduc surveillance activities.

The use of grace periods in relation to surveillance activities was tenninated in July 1997 after the NRC inspection. The new permanent staff member was added effective August 18,1997.

Additional steps taken As a result of the inspection, it was recognized that the recurring failure of one reactor component, the linear power wide-range channel, contributed to the conditions that lead to the violation. The small reactor staff was over-burdened with repairing the component AND maintaining the normal operating status of the reactor. It would have been prudent to replace the component before failure occurred.

With this in mind, the Reactor Manager conducted a resiew of all facility systems. Tim purpose of tim resiew was to identify all components that had tim potential to cause conditions similar to those caused a

by the recurring failure of the linear power wide-range channel. The area radiation monitoring system um identified as having a potential to fait prior to the completion of the proposed decommissioning activities. A decision was made to replace tie system before a failure could occur. A request for bids was issued August 6,1997 for 3 new area radiation monitors. It is expected that alw tww system will be operational by the end of 1997.

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f NOTICE OF VIOLATION Iowa State University Docket No. 50116 UTR 10 Argonaut Reactor License No. R 059 During an NRC inspection conducted on July 2125,1997, a violation of NRC requirements was identified. 'In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 16CO, the vlotation is listed below:

Technical Specification (T.S.) 4.0,' SURVElLLANCE REQUIREMENTS, states that "

Surveillance tests, except those specifically required for safety when the reactor is shut down, may be deferred during reactor shutdown, however, they must be completed prior to reactor startup "

Contrary to the above, the reactor was taken critical and operated at full power on December 31,1996, with the following surveillance requirements for safety' systems incomplete:

A. T.S. 4.2.3.B. requires that the drop time and delay time of all applicable control rods and the withdrawal time of each control rod be measured at least annually.

These measurements were last made on December 21,1995 and were not completed until January 8,1997.

,B. T.S. 4.2.3.E. requires that the instrumentation listed in Table 31 be calibrated at least annually. Shim safety rod position indication was last calibrcted on December 28,1995 and was not completed until January 2,1997.

C. -T.S. 4.3.3.A. requires that the coolant instrumentation listed in Table 3-2 be calibrated at least annually.' The moderator levelinstrument was last calibrated on December 19,1995 and was not completed until January 3,1997.

This is a Severity Level IV violation (Supplement I),_

Lua stare UHownu7r Pursuant to the provisions of 10 CFR 2.201, the University-oflown is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy.to the responsible inspector, U.S. Nuclear Regulatory Commission, Region Ill, 801 Warrenville Road, Usle,

-Illinois 60532, 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, (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 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.

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