ML20080N529

Responds to NRC Re Violations Noted in IE Insp Rept 50-072/83-01.Corrective Actions:Tech Specs Re Surveillance Tests Will Be Amended as Stated

ML20080N529
Person / Time
Site:	05000072
Issue date:	06/03/1983
From:	Jacobs H, Sandquist G UTAH, UNIV. OF, SALT LAKE CITY, UT
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20080N526	List: ML20080N529
References
NUDOCS 8402220276
Download: ML20080N529 (2)

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M o .. 1.,~, e, WM EEifEumo 0UN tur cem -

3 June 1983 hhhhkh i  !

U.S. Nuclear Regulatory Commission U -

Region IV JUN - 91983 3,i ,

611 Ryan plaza Drive, Suite 1000 Arlington, Texas 76011 < -

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Docket 50-072/83-01 Gentlemen:

During the period 21-22 April, 1983, Mr. M. E. Murphy of your staff conducted inspection activities of the Univer-sity of Utah's AGN-201 Reactor, License R-25. As a result of that inspection, a notice of violation was issued by your office as follows:

Failure to Conduct Required Surveillance Tests Technical Specifications surveillance tests 4.2.a,

" Safety and Control Rod Scram Times and Average Reactivity Insertion Rates." and 4.2.g, " Period, Count rate, and Power Level Channels calibration and Set Point Verification," ar required to be accomplished "... annually, but at intervals not to exceed 16 months." Technical Specifications para-graph 4.0, " Surveillance Requirements" states:

" Actions specified in this section are not required to be performed if during the specified surveillance period the reactor has not been brought critical or is maintained in a shutdown condition extending beyond the specified surveillance period. However, the surveillance requirements must be fulfilled

> prior to subsequent startup of the reactor."

We believe the basis of this alleged violatiori arises from a request;by;NRC _ (Washington) .for. amended 1 data as required by our Annual Operating Report to the NRC (Technical Specification 6.9.1, License R-25) and a logical inconsistency in Section 4.2.

Control and Safety System of the Technical Specifications In our annual report (1981) .a; discrepancy was claimed'by the iNRCi(Washington) on the excess reactivity measurement given for the AGN-201. .WeJwere requested to repeatEthe' measured and l confirm 1orimodify? our data: The AGN-201 had been maintained ra*1*e*PJ' G

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in a shutdown, (nonoperational condition) since 3 March 1981 and all activities required under Section 4 of the Technical Specifications had not been performed since that date as per-mitted by Section 4 as stated in the notice of violation. On 14 July 1982 inicompliance'with;NRC request we repeated the excess reactivity measurement for the 1981 annual report in the belief that that operation was simply a continuation (or repeat) of-that specific test for the surveillance test per-formed on 3 March 1981. However, Mr. Murphy pointed out as specified by the Section 4 that surveillance requirements must be fulfilled prior to subsequent 'startup of the reactor. Since the surveillance requirements entail startup of the reactor to perform, it is not possible without violation of the Tech-nical Specifications to return the reactor to operation after a long period of shutdown. Sections 4.2.a and 4.2.g were not performed on the 14 July 1982 surveillance test since the licensee believed that this test was a continuation of the earlier surveillance test.

The University of Utah proposes as corrective action for the alleged violation the following.

1) The NRC inspection report has been reviewed and assessed by the Reactor Safety Committee. The Committee made a proposal to amend the Technical Specifications to read "However, the surveillance requirements must be fulfilled with the subsequent initial startup operations of the reactor." Interestingly, the AGN-201 Technical Specifi-cations for R-25 are quasi-generic in nature and similar statements exist in the Technical Specifications of other AGN-201 licensees. "As~itistandsW however,. correction of?

the T al1ege: violation L(viz. , c performance ' of: 4;2.aland14.2.g)

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scannot"belperformedLwithout'a repeated; violation of thei iTechnical: Specifications Infthisiregard,.the11icensee l

would2 appreciate advice from the1NRC.3

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2) EAssuming;the: Technica1 ' Specifications ^are- amended'as nec- 4 Jessaryp'to- eliminateL this.' discrepancy, no further -violations arezexpectediregardingithisimatter.

3) TheLdatecfuel--compliance will;.be' achieved isisubject.to time; required for ,NRC1(Washington)Etoi reinterpret or Tap'-

prove an 2amendmentL to tthe ' Technical Specifications.

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Sincerely yours

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If. R. Jacobs p jr ltg