EA-98-320 - Oregon State University Research Reactor
July 31, 1998
Dr. Brian Dodd, Director
Oregon State University
Radiation Center, A100
Corvallis, OR 97331-5903
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-243/98-201)
Dear Dr. Dodd:
This refers to the inspection conducted by the U.S. Nuclear Regulatory Commission (NRC) on February 18-20 and May 6 and 11-13, 1998, of your Radiation Center TRIGA Mark-II reactor facility. The purpose of the inspection was to follow-up on the event of February 17, 1998, involving operation of the TRIGA Mark-II reactor without technical specification required scrams being operable. The results of the inspection were discussed with you and your staff and were detailed in the inspection report issued on June 19, 1998. The inspection report provided you the opportunity to either respond to the apparent violations addressed in the inspection report or request a predecisional enforcement conference. On June 23, 1998, you informed the NRC that Oregon State University did not wish to request a predecisional enforcement conference. By a letter dated June 24, 1998, you submitted a response to the apparent violations identified in the inspection report.
Based on the information developed during the inspection and the information that was provided in your letter of June 24, 1998, the NRC has determined that two violations of requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. The first violation resulted from a change to the wiring/circuitry of your reactor console at some point in the past. This change, when combined with the reactor console switch becoming stuck in the "reset" position, resulted in the reactor being operated for a period of approximately 14 minutes without any of the technical specification required automatic or manual scrams being available or functional. The second violation involved the failure to prepare and retain indefinitely updated, corrected, and as-built drawings of the facility. The change that was made to the reactor console wiring was not reflected in the as-built wiring schematics of the reactor console.
The actual safety consequences of these violations were low because the reactor was only operated for a short period of time without required scram protection, the automatic protection system was not called upon to scram the reactor during the period of operation, the TRIGA reactor is designed with a large, prompt negative fuel temperature coefficient, and the reactor operator had available other means to manually shut down the reactor. Although the violations did not result in any safety consequence and were not programmatic in nature, they are of significant regulatory concern because automatic safety systems are an important aspect of the multiple lines of defense used to prevent or mitigate a serious safety event. In addition, given a different set of circumstances where the system was called upon to perform its safety function, a situation could have developed with a safety consequence. Therefore, these violations have been categorized in accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, Revision I, as a Severity Level III Problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $2,750 is considered for a Severity Level III problem. Because your facility has not been the subject of escalated enforcement actions during the past two inspections, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty assessment process described in Section VI.B.2 of the Enforcement Policy. NRC determined that credit was warranted for Corrective Action because your staff, upon identification of the first violation, took prompt steps to (1) modify the reactor console circuitry to make it consistent with that shown and evaluated in the original design drawings for the TRIGA reactor, (2) conduct a point-to-point and electronic check of the scram loop circuitry to provide assurance that the as-built condition matches the circuitry shown in the facility documentation, and (3) modify the reactor start-up procedure to add a scram test that would confirm that the control rod magnetic power is de-energized when the console key switch is in the "reset" position. Based on the above, the NRC determined that credit was warranted for the factor of Corrective Action.
Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Director of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.
Your letter of June 24, 1998, included for each apparent violation (1) the reason for the apparent 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. The NRC considers that your docketed correspondence of June 24, 1998, satisfies the requirements of 10 CFR 2.201 for required responses to Notices of Violation. Therefore, no additional response is required for the enclosed Notice of Violation. These corrective actions appear adequate and will be examined during a future inspection.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room (PDR).
If you have any questions concerning this issue, please contact us.
|Jack W. Roe, Acting
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Docket No. 50-243
License No. R-106
Enclosure: Notice of Violation
NOTICE OF VIOLATION
|Oregon State University
TRIGA Mark-II Reactor Facility
|Docket No.: 50-243|
License No.: R-106
During an NRC inspection conducted on February 18-20, and May 6 and 11-13, 1998, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
|A.||Technical Specification 3.5.3
requires that the reactor not be operated unless the safety channels
described in Table I are operable. The safety channels in Table I include
automatic and manual scrams for the reactor.|
|Contrary to the above, on February
17, 1998, the reactor was operated for approximately 14 minutes
without any of the automatic or manual scrams described in Table I being
available or functional.|
|B.||Technical Specification 6.6.k requires
that the licensee prepare and retain indefinitely updated, corrected, and
as-built drawings of the facility.|
|Contrary to the above, a change
was made to the reactor console wiring and the facility circuitry drawings
were not updated and corrected or retained at the facility reflecting the
|These violations represent a
Severity Level III problem (Supplement
Because the information in your letter of June 24, 1998, met the provisions of 10 CFR 2.201, no response to this Notice of Violation is required.
Dated at Rockville, Maryland
this 31th day of July 1998