ML20196B602

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Ro:On 901206,950424 & 970512,deficiencies Occurred in Shipping & Receiving Special Nuclear Matl.Caused by Misunderstanding of Procedure Uarr 127.Committee Discussed Matter in 981103 Meeting & Matter Was Described in Training
ML20196B602
Person / Time
Site: 05000113
Issue date: 11/25/1998
From: Williams J
ARIZONA, UNIV. OF, TUCSON, AZ
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9812010145
Download: ML20196B602 (3)


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NucirrReactorL borttory John G. Willir.ms, Director Engineering Building (20) e-m il:Jgw@bigdog.cngr.adzona.edu P. O. Box 210020 voice (520) 621-9729 Tucson, Arizona 85721-0020 gh FAX (520) 621-8096 Date: 25 November,1998 To: U.S. Nuclear Regulatory Conunission Attn: Document Control Desk Mailstop P1-37 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 From: John G. Williams, Director, Nuclear Reactor Laboratory, University of Arizona, Tucson, AZ 85721-0020 Re: Required report, transmitted within thirty days; Facility License R-52, Docket 50-113.

Technical Specifications for Facility License R-52, the University of Arizona, requires in section 6.7 c.4 a written report to the Commission of "Any observed inadequacies in the implementation of administrative or procedural controls." This report fulfills that requirement in the case of a discovered deficiency in implementation of University of Arizona Research Reactor procedure UARR 127, Procedure for Shipping and Receiving Special Nuclear Material.

Description of the Occurrence It was discovered during editorial review of UARR procedures that UARR 127 had not been followed during three shipments of special nuclear material (SNM) that occurred on December 6,1990, on April 24, 7

.1995, and on May 12,1997. These were the only shipments of special nuclear material to or from the Nuclear Reactor Laboratory since 1990. In each instance, the shipments were in compliance with federal regulations, including NRC and DOT regulations. Security seals were properly placed and checked, receipt of the material was properly notified and verified, and all three transactions were properly

)odb accounted for on semi-annual Material Balance Reports (NRC form 741). In addition, University of Arizona Radiation Control Office (RCO) procedures for shipment and receipt of radioactive materials were j followed. Not followed were the requirements in UARR 127 for advance notification and approval by the

University of Arizona Reactor Committee.

l The first two shipments were each of one unitradiated instrumented fuel element containing 20% enriched uranium sent by General Atomics on behalf of the US Department of Energy (DOE). The third shipment

! was of three, one Curie, Pu-Be sources shipped to a DOE laboratory as part of a plutonium reclamation prc,':ct.

In each instance there was no threat to public health and safety, and nor was the security r f the material compromised, as a result of the failure to follow UARR 127.

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9812010145 901125 PDR ADOCK 05000113 g PDR L

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pause of the Occurrence

! In cach instance, the failure to follow UARR 127 occurred because of failure on the part of the Reactor Supervisor and the Nuclear Reactor laboratory Director to recognize that a UARR procedure was l applicable to the shipments. Both were aware of applicable federal regulations and ensured that these were followed.

Possible Consecuences l The procedure UARR 127 is intended to ensure that appropriate procedures for shipment of SNM are approved in advance by the Reactor Committee. UARR 127 does not itself specify any particular procedures, but only that such special procedures as may be needed are prepared and are approved in advance by the Reactor Committee. In the instances documented here, the shipments were straightforward, l

and no special procedures, other than existing RCO procedures and the federal notification procedures were needed. UARR 127 could have been followed by listing those procedures and requesting advance approval 1

! by the Reactor Committee. There were, in these instances, no adverse safety of security consequences of l the failure ta do so.

Remedial Actions I l Dese three instances of failure to follow UARR 127 were notified to the Reactor Committee by the Reactor Supervisor and the Nuclear Reactor laboratory Director. He Committee discussed the matter in l

a meeting on November 3,1998.

l Discussion by the Reac'or Committee focused on whether a generic cause for the failures to follow the  ;

I procedure could be identified. It was recognized that the failures were not willful, but were due to ignorance or oversight of the requirements in the procedure. This meant that the use of this procedure was not initiated when it should. have been. Improved training oflicensed personnel, and especially of the Supervisor and Director, la the scope and content of UARR procedures was recommended.

Subsequently, this matter was described in an operator requalification class by the Reactor Supervisor, and alllicensed personnel were reminded of the need to be aware of the scope of all UARR procedures.

In addition the Supervisor and Director are specificeSy required to study the Contents pages of the UARR list of procedures, and familiarize themselves with r scope of each procedure. He Chairman of the Reactor Committee will be asked to prepare and gr e a test on this subject to be taken by the Supervisor and the Director. ,

I believe that these actions will prevent a recurrence of a similar oversight of the requirements of UARR procedures.

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J. G. Williams, Reactor Laboratory Director i

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copies to:

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Non-Power Reactor and Decommissioning Project Directorate

. Division of Reactor Program Management Office of Nuclear Reactor Regulation i One White Flint North j

'l1555 Rockville Pike Rockville, MD 20852-2738 The V.P. for Research, University of Arizona Michael A.Cusanovich l l

l The Chairman of the Reactor Committee  !

I Phillip A. Secker, Jr.

The Reactor Supervisor liarry J. Doane i

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