ML20209F582
| ML20209F582 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 04/14/1987 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20209F551 | List: |
| References | |
| 50-160-87-01, 50-160-87-1, NUDOCS 8704300324 | |
| Download: ML20209F582 (5) | |
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.r ENCLOSURE 1 NOTICE OF VIOLATION Georgia Institute of Technology Docket No. 50-160 Atlanta, GA License No. R-97 During the Nuclear Regulatory Commission (NRC) inspection conducted on February 9-23, 1987, violations of NRC requirements were identified.
The violations involved failures to comply with the conditions of the license and the Code of Federal Regulations.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:
A.
Technical Specification 6.4.b(1) requires that written procedures shall be provided and utilized for normal startup, operation, and shutdown of the reactor and of all systems and components involving the nuclear safety of the system.
1.
Contrary to the above, the Licensee had not provided procedures to address the following Technical Specification Limiting Conditions for Operation, which were therefore not being verified:
a.
Technical Specification 3.1.e, which requires the excess reactivity of the core to be limited to 11.9 percent delta k/k b.
Technical Specification 3.6.e, which requires that the core shall not be made critical unless tne deuterium concentration in the helium sweep is less than 2% by volume c.
Technical Specification 3.5.b.6, which requires that containment isolation valve closure time shall not exceed five seconds 2.
Contrary to the above, the Licensee failed to provide adequate procedures in the following instances:
a.
Procedure 2350, procedure 2400, and other procedures concerning control of the cover gas had not been updated as of February 23, 1987, to reflect the conversion of the cover gas from helium to nitrogen in mid-1986.
b.
Certain handwritten changes were made to procedures 2002 and 2003 for over a year and a half without these changes being incorporated into a permanent revision.
On a number of occasions these handwritten changes were inadvertently omitted, causing a failure to follow the procedure as written.
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Georgia' Institute of Technology 2
Docket No.' 50-160 Atlanta, GA License No. R-97 3.
Contrary to the above, the Licensee failed to follow their procedures in the following instances:
a.
Procedure 2000 requires that initial critical condition data and
- equilibrium condition data be. entered in the console log for each reactor startup. The licensee did not log initial critical condition data for startups on May 19, May 21, May 23, and on other occasions during 1986.
Further, the licensee failed to log equilibrium condition data for numerous startups conducted:
during 1986, and numerous other required entries in console logs were missing.
b.
Procedure 2210 requires that water be run through the cooling towers for at least an hour per week during periods when the reactor is not operating.
The licensee failed to run water through the. cooling towers during the periods of reactor shutdown between March 31, 1986 and April 14, 1986, and between July 24, 1986 and August 19, 1986.
This is a Severity Level IV violation (Supplement I).
B.
Technical Specification 6.3 defines requirements for the administrative controls of experiments, including requirements for approval, quality assurance, and documentation.
Technical Specification 6.3.a(1) requires that no experiment shall be performed without review and approval by the Nuclear Safeguards Committee. Technical Specification 6.3.e requires that there shall be a quality assurance (QA) program to assure compliance with the limitations on experiments-in Technical Specification 3.4.
Technical Specification 6.3.c(3) requires that each experiment removed from the reactor be subject to radiation monitoring and the results be documented.
Contrary to the above, the licensee failed to meet the requirements of Technical Specification 6.3 for the approval, QA, and documentation of experiments in the following instances:
1.
Technical Specification 6.3.a(1) is implemented in put by the
" Request for Minor Experiment Approval" form, which piuides informa-
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tion necessary for obtaining and documenting Safeguards Committee approval of experiments. The " Request for Minor Experiment Approval" requires a copy of calculations of estimated activities of principal isotopes to be attached.
Numerous copies of this form were on file i
for 1986 without attached calculations of estimated activities.
t 2.
Technical Specifications 6.3.a(1) and 6.3.e are implemented in part by Procedure 3102, which requires that an Experiment Schedule Form be completed and retained in the files each time an experiment is performed.
The required Experiment Schedule Forms were frequently not completed and filed for runs in the pneumatic facility or for Nuclear Engineering class laboratory experiments.
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. Georgia Institute of Technology 3
Docke't No. 50-160 Atlanta, GA License No. R-97 3.
Technical Specification 6.3.e is implemented in part by the "Experi-mentor's Checklist" form.
No Experimentor's Checklist form was on file for experiment R6512 for the run on September 10, 1986.
4.
Technical Specification 6.3.c(3) is implemented for experiments performed using the pneumatic facility by entering the results of radiation monitoring in the console log. Dose rates for experiments were not documented as required on pages 125,131, and.147 of console log #29.
This is a Severity Level IV violation (Supplement I).
C.
Technical. Specification 4.2.b requires that a channel check of the power trip channels and pico-ammeter channels, comparing the channel checks to a heat balance, shall be made weekly when the reactor is operated at a power level at or above one megawatt.
Contrary to the above, no heat balance calibration check was made between March 31, 1986 ~ and April 14, 1986, although the reactor was operated at one megwatt on April 7,1986.
This is a Severity Level IV violation (Supplement I).
D.
10 CFR 50.59 allows the holder of a license to make changes in the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves a change in the Technical Specifications incorporated in the license or an unreviewed safety question.
The holder of a license who desires a change in the facility which involves a Technical Specification change shall submit an application for amendment of the license pursuant to 10 CFR 50.90.
Technical Specification 3.6.e addresses the use of helium as the cover gas of the Georgia Tech Research Reactor, stating that the reactor shall not be critical unless "The D2 concentration in the helium sweep is less than 2% by volume."
Contrary to the above, the licensee made a change to the facility involving a change in the Technical Specifications without prior Connis-sion approval, in that the cover gas was changed from helium to nitrogen in mid-1986 without first obtaining a Technical Specification change.
In addition, the licensee did not include the change from helium to nitrogen cover gas in _ the annual report to the NRC, as required by Technical i
Specification 6.7.a.
This is a Severity Level IV violation (Supplement I).
E.
10 CFR 50.54 paragraph (1-1) requires the licensee to have in effect an NRC approved operator requalification program which satisfies the require-ments of Part 55 Appendix A.
The licensee may not make changes in the
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approved program which decrease the scope or frequency of conducting j
different parts of the program.
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Docket No. 50-160 Atlanta, GA License No. R-97 10 CFR 55 Appendix A Paragraph 3 requires that the requalification program include control manipulations. Appendix A Paragraph 4.c requires that the requalification program include systematic observation and evaluation of the performance and competency of licensed operators including evaluation of actions taken or to be taken during actual or simulated abnormal and emergency conditions.
The licensee's approved requalification program requires that summaries of both the control manipulations and the performance observations required by 10 CFR 55 Appendix A Paragraph 4.c be documented annually.
Contrary to the above, as of February 23, 1987, yearly sumaries of control manipulations and annual observations of the performance of licensed operators under simulated emergency conditions had not been documented since 1983.
This is a Severity Level IV violation (Supplement I).
F.
Technical Specification 6.4a requires that all procedures and major changes thereto shall be reviewed and approved by the Nuclear Safeguards Committee prior to being effective.
Technical Specification 6.4.b(5) requires that written procedures shall be provided and utilized for preventive or corrective maintenance operations which could have an effect on the safety of the reactor.
Technical Specification 6.2.e(5) requires that the Nuclear Safeguards Comittee shall audit reactor operations and reactor operational records for compliance with internal rules, procedures, and regulations and with licensed provisions including Technical Specifications.
Technical Specification 6.2.e(7) requires that the Nuclear Safeguards Comittee audit plant equipment performance.
Technical Specification 6.2.e(6) requires that the Nuclear Safeguards Comittee audit existing operating procedures for adequacy and to assure that they achieve their attended purpose in light of any changes since their implementation.
Contrary to the above, the Nuclear Safeguards Committee failed to perform the review, approval and audit functions required by the license in the following instances:
1.
Procedure 4901 provides administrative requirements for preparing written job plans to satisfy the requirement of Technical Specifica-tion 6.4.b(5) that maintenance operations be conducted according to written procedures.
The Nuclear Safeguards Committee was not performing reviews or audits of the completed job plans as required to satisfy Technical Specification 6.2.e(5), 6.4.a and 6.4.b.5.
r Georgia Institute of Technology 5
Docket No. 50-160 Atlanta, GA License No. R-97 2.
Nuclear Engineering laboratory experiments were being performed each quarter without documentation that the Nuclear Safeguards Committee had ever reviewed the procedures as required by Technical Specifica-tion 6.4.a.
3.
Systematic audits of equipment function were not being performed as required by Technical Specification 6.2.e(7).
4.
Nuclear Safeguards Comittee audits of operations, operational 6.2.e(5) and 6.2.e(6) procedures required by Technical Specifications records, and existing were inadequate in that the same eight procedures were audited each year, and records of experiments were not being audited.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Georgia Institute of Technology is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation):
(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION b cak t\\
I Luis A. Reyes, Director Division of Reactor Projects Dated at Atlanta, Georgia thisg(dayof 1987 i
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