ML20199L657

Informs of Several Violations of TS at Facility.Corrective Actions:Full Insps & Recalibrations Have Been Carried Out & Specific Schedule Established & Posted in Facility Detailing Dates of Required Surveillance Activities Projected

ML20199L657
Person / Time
Site:	University of California - Irvine
Issue date:	11/29/1997
From:	Geoffrey Miller CALIFORNIA, UNIV. OF, IRVINE, CA
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199L649	List: ML20199L646 ML20199L657 ML20199L663
References
NUDOCS 9712020080
Download: ML20199L657 (3)

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' George E. Miller IRVINE. CA 92697-2025 Senior Lecturer Emeritus (714) 824-6649 Department of Chemistry and FAX: (714) 824-2011 or (714) 824-7621 Supervisor. Nuclear Reactor Facility Internet: GEMILLER@uci.edu Director, Science Education Programs. School of Physical Sciences November 29,1997 US. Nuclear Regulatory Commission, Document Control Desk, Docket: 50-326 Washington, DC 20555 License R-116 Licensee renort of violations of Technical Snecifications Sections 4.1.4.2.43. and Section 6.2.f.

Ladies and Gentlemer.

I regret to have to inform you of several violations of Technical SpeciGeations at this facility. Each of these involves frequency and "not to exceed" times between events regarding surveillance, and have occurred because of intense personal problems during the last year for the Reactor Supervisor, since there was essentially no staff back-up for routine administrative matters at this facility.

In ea:h case, it is our contention that no significant effect on reactor safety has been observable or measurable, nor has there been an increase in hazard or potential hazard to the public or to other per3onnel, it is clear that there is a very large margin of safety inherent in the frequency at which surveillance is required, even though these limits were extensively increased in amendments to the Technical Specifications approved in 1994.

The specifics on these items are as follows:

1) TS 4.1 states: "The standard fuel elements shall be measured for length and bend at intervals

........ but the intervals shall not exceed 36 months." " Fuel follower control rods shall be measured for bend at the same time interval."

TS 4.2 c. states "c. The control rods shall be visually inspected for deterioration at intervals not to exceed three years. "

Contrary to the provisions of these sections, the fuel measurements were not conducted between 1/30/93 and 11/9/97, an interval of almost 5 years. A misunderstanding in the minds of personnel had mistakenly set this limit at 5 years rather than 3. A recheck after attending the TRTR meeting.

in October, led to the realization that this was a myth - that the approved interval was only 3 years.

Ne are pleased to report that the results of the most recent inspection are in perfect agreement with those done in 1993 for both length and bend (within the 0.002 inch normal limit of reproducibility). Visual inspection of every fuel element, the fuel follower control rods (under water) and the transient control rods (in air) also revealed no changes since 1993.

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Three mitigating factors are :

a) The reactor was not operated between February 1994 and February 1995 while updates were being made to the control console circuitry.

b) The reactor has not been pulsed at all since October 25th,1993, c) Our nonnal operating schedule is now quite low, on average no more than two hours per week Thus stress on the fuel has been minimal during this time period, data are highly reproduced, so no effect on safety of fuel is observable as a result of the delay.

2) TS 4.2 states:

"a. The reactivity worth of each control rod shall be determined annually, but at intervals not to exceed eighteen months.

b. Control rod drop times shall be determined annually, but at intervals not to exceed eighteen months."

TS 4.3 d states:

"d. A channel calibration by the calorimetric method shall be made of the power level monitoring channels annually but at intervals not to exceed eighteen months."

Contrary to the specifications, the rod measurements and calibrations were not performed between April iIth 1996, and October 1Ith 1997, a period of eighteen months. The reactor was not operated again until November 13th,1997 when rod calibrations v/ere performed following the needed inspections described in (1). The calorimetric power calibration was carried out on November 14th 1997, following completion of the control rod calibrations and the core inspection.

Routine operations were re-instituted following the inspections and re-calibrations.

Calibration data were very close to former values, both for drop times, which were almost identical and remain well within technical specifications limits of I second, and for reactivity worths as shown in the following table:

End 4/11/9Q 11/13/97 FFR

$ 0.77

$ 0.67 ATR

$ 1.78

$ 1.83 SHIM

$ 3.66

$ 3.64 REG

$ 2.84

$ 2.84 Total Worth

$ 9.05

$ 8.98 Considering that all fuel elements and control rods had been individually removed from core and replaced between these two measurements, the agreement is remarkable and a testimonial to the stability of the TRIGA system and UCI configuration.

~ 3P TS 6.2.f. states "The Committee (Reactor Operations Committee) shall meet semi-annually, at intervals not to exceed nine mor ths."

Contrary to the provisions of this section, the Reactor OperaHons Committee failed to meet from August 8th 1996 until November 26th 1997.

During this period of time, operations continued to be inspected on a regular quarterly basis by staff of the Environmental Health and Safety _ Office, and were subject to review by the UCI Campus Radiation Safety Committee. Operations were at a low level as noted above, and no

changes were made in facility structures or operations that required review. Thus committee

• functi6n would have been of a purely routine nature during this period.

Measures taken:

• As noted above, full inspections und recalibrations have been carried out. These were in highly satisfactory agreement with previous measurements.

• A specific schedule has been established and posted in the facility detailing dates of required surveillance activitics projected over the next 3 years (which actually extends beyond the present license expiry date of November 1999). This includes agrced committee meeting dates.

Copies of these are being provided to all Committee members and other staff Sincerely, g 7NL C

George E. Miller Reactor Supeivisor cc: Reactor Operations Committee members

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