ML20038A968

RO Re Tech Spec Violations Reported on 811029.Procedural Aspects of New & Novel ESA Must Be Reviewed by Radiation Use Committee Prior to Implementation

ML20038A968
Person / Time
Site:	05000142
Issue date:	11/16/1981
From:	Wegst W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8111240535
Download: ML20038A968 (2)

Text

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UNIVERSITY OF CALIFORNIA, IOS ANGELES . .

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G W E 9 COMMUNITY SAFETY DEPARTMENT OFFICE OF RESEARCH & OCCUPATIONAL SAFETY LOS ANCELES, CALIFORNIA 90094 Q/ ,

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November 16, 1981 '

V* /:h p f {$x; Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Cocket 50-142 License R-71

Dear Sir:

Two possible violations of UCLA's Technical Specifications were reported by tele-phone to the USNRC Region V on October 29, 1981. The action constituting the first possible violation was committed on October 23. On October 27, it occurred to us that we might have violated the Technical Specifications, and we subsequently reported the action on October 29. We believe the reporting delay may also be cla'ssified-zt. a violation.

4 The first apparent violation was a failure to insert all control blades prior to re-moval of a sample of large negative reactivity (UCLA Technical Specification VII.B.2).

No physical consequences ensued as a negative shut down margin of 70 to 80 cents re-mained after removal of the sample.

If Technical Specification VII.B.2 was indeed violated then the reporting delay is also a violation under Technical Specification VIII.M.1 A.

The precise nature of the violation is uncertain and depends upon the interpretation of Technical Specification VII.B.2. That specification clearly applies to a critical reactor; but does it also apply to a sub-critical reactor containing a sample of known negative reactivity and known shutdown margin? UCLA requests NRC clarification of th;s question.

UCLA's Radiation Use Committee was convened on November 2,1981 to review the circum-stances of the apparent violations. (A copy of the meeting minutes is available if desired). The following is a management summary of those minutes:

First Violation - Findings

1. A new and novel experiment was run on October 23, 1981. The experiment was in-tended to identify a possible sample of positive reactivity.

2. The written procedure for the conduct of the experiment assumed that the sample would display a positive reactivity.

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. .- 3. The. Reactor Supervisor reviewed the written procedure and assumed that standard procedures would govern in the case of unforseen developments.

4. The written procedure was not submitted to the Radiation Use Committee.

5. The Senior Reactor Operator running the reactor followed the procedure as written, but failed to implement the standard procedure when it was found that the sample reactivity was in fact negative.

6. The Senior Reactor Operator acted with unnecessary haste, in prosecuting what may have been a deficient procedure. Although he knew his procedure was safe, he did not consider the possibility of a technical violation.

7. The principal cause of this apparent violation was a failure to anticipate, and correctly respond to an unexpected development.

First Violation' - Recommendation / Approvals

1. The Comittee approved a recommendation that the procedural aspects of new and novel ESA's must be reviewed by the Radiation Use Committee prior to implementation.

Second Violation - Findings and Recommendations.

2. All personnel normally expected to notify the NRC were reminded of their res-

.ponsibilities in that regard.

Very truly yours,

&$ b' Walter F. Wegst Director Research & Occupational Safety WW/jr cc: Walnut Creek USNRC Reg. V