IR 05000128/2023201
| ML24024A132 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 04/22/2024 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Joel Jenkins Texas A&M Univ |
| References | |
| IR 2023201 | |
| Download: ML24024A132 (1) | |
Text
SUBJECT:
TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM, NUCLEAR SCIENCE CENTER - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000128/2023201 AND NOTICE OF VIOLATION
Dear Mr. Jenkins:
From December 11-14, 2023, and January 9-11, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Nuclear Science Center, Training, Research, Isotopes, General Atomic (TRIGA) facility. The results of this inspection are documented in the enclosed report.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed various activities, and interviewed personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements has occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs website at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the enclosed inspection report. The violation is cited in the Notice because it constitutes a failure to meet regulatory requirements that has more than minor safety significance and the licensee failed to identify the violation.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
April 22, 2024 During this inspection, the NRC has also determined that two Severity Level IV violations of NRC requirements occurred. The violations are being treated as non-cited violations (NCVs),
consistent with section 2.3.2.a of the Enforcement Policy. The NCVs are described in the subject inspection report. If you contest the violations or significance of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). To the extent possible, your response should not include any personal privacy or proprietary information, so that it can be made available to the Public without redaction.
If you have any questions concerning this inspection, please contact Juan Arellano at 301-415-0477, or by email at Juan.Arellano@nrc.gov.
Sincerely, Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-128 License No. R-83 Enclosures:
As stated cc: GovDelivery Subscribers Signed by Tate, Travis on 04/22/24
ML24024A132 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME JArellano NParker TTate DATE 03/13/2023 03/13/2024 04/22/2024
NOTICE OF VIOLATION
Texas Engineering Experiment Station Docket No. 50-128 Texas A&M University System License No. R-83
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted December 11-14, 2023, and January 8-11, 2024, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Texas Engineering Experiment Station (TEES) Texas A&M University System (TAMU) Facility Operating License No. R-83, Amendment No. 19, dated July 22, 2021, section 2.C. states that, This license shall be deemed to contain, and is subject to the conditions specified [in] 10 CFR Parts 20, 30, 40, 50, 51, 55, 70, and 73 of the Commissions regulations.
Title 10 of the Code of Federal Regulations (10 CFR) 55.25, Incapacitation because of disability or illness, states that, If, during the term of the license, the licensee develops a permanent or mental condition that causes the licensee to fail to meet the requirements of
§ 55.21 of this part, the facility licensee shall notify the Commission, within 30 days of learning of the diagnosis, in accordance with § 50.74(c).
Contrary to the requirement in 10 CFR 55.25, the NRC inspector found that the facility failed to notify the Commission within 30 days for two licensed operators that developed a permanent or mental condition not previously identified to the Commission. Specifically, the NRC inspector found that the operators medical examinations identified a change in medical conditions of the licensed operators that is identified in American National Standards Institute/American Nuclear Society (ANSI/ANS) 15.4, Selection and Training of Personnel for Research Reactors as a disqualifying condition or requiring accommodation. The licensee was notified of the change in condition for one licensed operator on November 11, 2023, and the licensee removed the operator from licensed duties on January 10, 2024. The licensee was notified of the change in condition for one licensed operator on August 29, 2023, and the operator was not removed from licensed duties until January 10, 2024, and continued routine reactor operations.
In accordance with the NRC Enforcement Manual, multiple examples of the same violation during the period covered by an inspection should be included as one citation. This issue involves two examples of the same non-compliance and has been determined to be a Severity Level IV violation (NRC Enforcement Policy section 6.4).
Pursuant to the provisions of 10 CFR 2.201, Notice of violation, TEES/TAMU System is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation, and should include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Enclosure 1
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If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
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Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System), accessible from the NRC website at https://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information.
If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.
In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post this Notice within two working days of receipt.
Dated this 22nd day of April, 2024.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.: 50-128
License No.: R-83
Report No.: 05000128/2023201
Licensee: Texas Engineering Experiment Station/Texas A&M University System
Facility: Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center
Location: College Station, Texas
Dates: December 11 - 14, 2023 January 9 - 11, 2024
Inspectors: Juan A. Arellano Craig H. Bassett
Approved by: Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
Enclosure 2 EXECUTIVE SUMMARY
Texas Engineering Experiment Station Texas A&M University System Nuclear Science Center Inspection Report No. 05000128/2023201
The focus of this routine, announced inspection was the onsite review of selected aspects of the Texas A&M University System (TEES) Texas A&M University (TAMU) System (the licensee)
research reactor facility safety program, including: (1) operations logs and records; (2) requalification training; (3) surveillance and limiting conditions for operation (LCO); (4) experiments; (5) emergency planning; (6) maintenance logs and records; and (7) fuel handling logs and records.
The inspector found that the licensees programs were acceptably directed toward the protection of public health and safety, and in compliance with U.S. Nuclear Regulatory Commission (NRC)
requirements, except where noted below.
Operations Logs and Records
- The inspector determined that the operations logs and records were maintained consistent with the applicable technical specifications (TSs).
Requalification Training
- The inspector determined that contrary to Title 10 of the Code of Federal Regulations (10 CFR) 55.25, Incapacitation because of disability or illness, the facility failed to notify the Commission within 30 days for two licensed operators that developed a permanent or mental condition not previously identified to the Commission.
- With the exception noted above, the inspector determined that the operator requalification program was conducted and completed in accordance with the NRC-approved program and regulatory requirements.
Surveillance and Limiting Conditions for Operation
- With the exceptions noted in section 3 below, the inspector determined that the surveillances were conducted and the LCOs were maintained in accordance with TS requirements.
Experiments
- The inspector determined that experiments were reviewed, approved, and conducted in accordance with TS, and regulatory requirements.
Emergency Planning
- With the exception noted in section 5 below, the inspector determined that the emergency preparedness program was conducted in accordance with the emergency plan.
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Maintenance Logs and Records
- The inspector determined that the maintenance activities were performed and documented in accordance with the TS requirements.
Fuel Handling Logs and Records
- With the exception noted in section 7 below, the inspector determined that the fuel movements and inspections were conducted in accordance with the TS and the licensees procedural requirements.
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REPORT DETAILS
Summary of Facility Status
The TEES/TAMU System Nuclear Science Center (NSC) research reactor was operated in support of training, experiments, and maintenance since the last routine inspection. During this inspection, the reactor was operated for experiments and maintenance.
1. Operations Logs and Records
a. Inspection Scope (Inspection Procedure (IP) 69001, Section 02.02)
The inspector observed the performance of a pre-startup checklist, observed a reactor startup and shutdown, and reviewed the following to ensure that logs and records were maintained as required by the licensees administrative procedures and TS:
- reactor operations logbook number 261 - 268
- NSC form 533, Reactor Operations Facility Checklist - Daily Surveillance, dated June 25, 2020
- NSC section II reactor operations procedure B, Reactor Startup, dated February 17, 2016
- NSC section II reactor operations procedure C, Steady State Mode Operation, dated February 17, 2016
- NSC section II reactor operations procedure E, Reactor Shutdown and Secure, dated February 17, 2016
- select NSC form 532 performed 2023 - present
- select NSC form 533 performed 2023 - present
- select NSC form 531, Morning Facility Checklist, performed 2023 - present
present
b. Observations and Findings
The inspector found that the licensees operation logs and records were maintained as required by the licensees TS and administrative procedures. The inspector observed that the measured parameters for reactor operations met the TS requirements.
c. Conclusion
The inspector determined that operations logs and records were consistent with applicable TS and the licensees procedural requirements.
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2. Requalification Training
a. Inspection Scope (IP 69001, Section 02.04)
The inspector reviewed the following aspects of the licensees requalification program to verify compliance with 10 CFR Part 55, Operators Licenses, and the licensees NRC-approved operator requalification program:
- Texas A&M University Nuclear Engineering & Science Center License and Access Status, dated November 13, 2023
- lecture sign in sheets performed 2022 - present
- NSC form 5005, Operator Requalification On the Job Training, for select individuals
- NSC form 5006, Annual Operator Requalification Operating Test, for select individuals
- medical examination records for select licensed operators
- written examination records for select licensed operators
- reactor operations logbook number 267
- reactor operations logbook number 268
b. Observations and Findings
Section 55.25, Incapacitation because of disability or illness, of 10 CFR states, in part, If, during the term of the license, the licensee develops a permanent or mental condition that causes the licensee to fail to meet the requirements of § 55.21 of this part, the facility licensee shall notify the Commission, within 30 days of learning of the diagnosis, in accordance with § 50.74(c).
Contrary to the requirement in 10 CFR 55.25, the NRC inspector found that the facility failed to notify the Commission within 30 days for two licensed operators that developed a permanent or mental condition not previously identified to the Commission.
Specifically, the NRC inspector found that the operators medical examinations identified a change in medical conditions of the licensed operators that is identified in American National Standards Institute/American Nuclear Society (ANSI/ANS) 15.4, Selection and Training of Personnel for Research Reactors as a disqualifying condition or requiring accommodation. The licensee was notified of the change in condition for one licensed operator on November 11, 2023, and the licensee removed the operator from licensed duties on January 10, 2024. The licensee was notified of the change in condition for one licensed operator on August 29, 2023, and continued routine reactor operations and was not removed from licensed duties until January 10, 2024.
The inspector identified that the licensee did not review medical examinations which would require NRC Form 396, Certification of Medical Examination By Facility Licensee, to be sent to the NRC if a change based on the American National Standards Institute/American Nuclear Society-15.4, Selection and Training of Personnel for Research Reactors, was identified by the physician. The inspector determined that the licensee not reviewing the medical examinations led the facility to fail to notify the Commission within 30 days for two licensed operators that developed a permanent or mental condition and were not removed from licensed duties until January 10, 2024. In accordance with the NRC Enforcement Manual, multiple examples of the same violation during the period covered by an inspection should be included as one citation, and in
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accordance with the NRC Enforcement Policy section 6.1.d, this issue is two examples of the same non-compliance and is determined to be a Severity Level IV violation and will be recorded as Notice of Violation (NOV)05000128/2023201-01.
With the exception noted above, the inspector found that the licensees training was conducted and documented in accordance with their NRC-approved requalification and training program, and that the licensed operators requalification records were maintained.
c. Conclusion
The inspector determined that contrary to 10 CFR 55.25 the licensee failed to report two operators that developed a permanent or mental condition not previously identified to the Commission.
With the exception noted above, the inspector determined that the operator requalification program was conducted and completed in accordance with the NRC-approved program and regulatory requirements.
3. Surveillance and Limiting Conditions for Operation
a. Inspection Scope (IP 69001, Section 02.05)
The inspector reviewed the following to verify compliance with TS 3, Limiting Conditions for Operation, and to determine if surveillance tests were performed as required by TS 4, Surveillance Requirements:
- select NSC form 532 performed 2023 - present
- administrative procedure-12, Maintenance/Repair, performed April 26, 2023
- NSC form 561, Annual Control Rod Time Surveillance, performed 2022 - present
- NSC form 562, Annual Control Rod Calibration and Shutdown Margin Determination, performed 2022 - present
- NSC form 568, Control Rod Inspection, performed 2022 - present
- NSC form 566, Annual Pulse Power Measuring Channel Maintenance, performed 2022 - present
- NSC form 549, Semiannual Reactor Pulse Power Surveillance, performed 2022 -
present
- NSC section III reactor maintenance and surveillance procedure G, Reactor Pulse Power Surveillance,: dated February 9, 2000
- NSC section II reactor operations procedure J, Power Calibration, dated May 10, 2000
- facility air monitoring systems book 2018
- select weekly facility air monitor (FAM) channel test performed 2023 - present
- CCP-01, "Weekly Facility Air Monitor (FAM) Channel Test," dated February 12, 2023
- "Monthly FAM Tests," memorandum dated November 29, 2017
- "FAM System Calibration Methodology Change," memorandum dated November 19, 2018
- "Charter for the Reactor Safety Board," revision 2 dated February 21, 2022
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b. Observations and Findings
On April 26, 2023, the licensee notified the NRC of a violation of LCO requirements at the facility. This was noted by the NRC as Event Notification#56489.
TS 3.5.1, Radiation Monitoring, states Reactor operation, movement of irradiated fuel elements or fuel bundles, conduct of core or control rod work that could cause a change in reactivity of more than one dollar, or handling of radioactive materials with the potential for airborne release shall not be conducted unless the radiation monitoring channels listed in Table 3 are operable, displays and alarms are operable in the control room, and displays are operable in the Emergency Support Center. Table 3, Radiation Monitoring Channels Required for Operation, lists a reactor bridge area radiation monitor.
Contrary to TS 3.5.1, on April 25, 2023, the facility determined that the reactor bridge area radiation monitor display in the Emergency Support Center was inoperable.
Specifically, after a power outage on April 6, 2023, the area radiation monitor display in the Emergency Support Center was inoperable while the licensee continued routine reactor operations through April 25, 2023.
The inspector reviewed the licensees corrective actions which included shutting down the reactor upon discovery and incorporating an additional step in the pre-start checklist to verify the display of the area radiation monitor in the Emergency Support Center prior to each startup. The inspector verified that the reactor was not operated after discovery until the area radiation monitor display in the Emergency Support Center was repaired.
During the inspection, the inspector was able to verify all displays required by TS were operable in the Emergency Support Center.
The licensee was informed that failure of the licensee to determine that the reactor bridge area radiation monitor display as required by TS 3.5.1 was a Severity Level IV violation. As indicated above, the inspector determined that the problem was identified by the licensee and reported to the NRC. Corrective actions were identified and completed as well. As a result, this non-willful, non-repetitive, licensee-identified, and licensee-corrected violation is treated as a non-cited violation (NCV), consistent with section 2.3.2.a of the NRC Enforcement Policy (NCV 05000128/2023201-02). The inspector found that the cause of the issue was identified, and appropriate corrective actions have been implemented, therefore, this issue is closed.
TS 6.7.2 states, in part, There shall be a report not later that the following working day by telephone and confirmed in writing by fax or similar conveyance to the NRC Headquarters Operations Center, and followed by a written report that describes the circumstances of the event and sent within 14 days to the Commission.
Contrary to TS 6.7.2, a written report that describes the circumstances of the event was not sent to the NRC within 14 days after the licensee determined that a reportable event occurred. Since the licensee could not provide the NRC with a reasonable time frame by which specific corrective actions would be taken, including immediate correction action and comprehensive action to prevent recurrence, this issue is considered an Inspector Follow-up Item (IFI). The licensee was informed that the issue will be reviewed during a future inspection (IFI 05000128/2023201-03).
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TS 4.5, Radiation Monitoring Systems and Effluents, specification 1 states, The area radiation monitoring system (ARM) and the FAM system shall be calibrated annually, shall be channel tested weekly, and shall be channel checked prior to reactor operation.
The licensee identified that channel checks and channel tests of the FAM system were completed in accordance with requirements specified in TS 4.5.1 and the applicable procedures. However, it was noted that the calibration of the FAM system were not performed in their entirety as required by TS 4.5.1 since November 19, 2018.
On January 11, 2023, the licensee notified the NRC of a violation of TS surveillance requirements at the facility. The licensee indicated that the affected FAMs were to be calibrated during the weeks of January 1, 2024, and January 8, 2024. The licensee was informed that failure to calibrate the FAMs annually as required by TS 4.5.1 was an apparent violation. However, because of the resultant problems caused by relocation of all the various instruments needed to perform the calibration the licensee was not able to calibrate the FAMs while the inspector was onsite. This issue is considered an Unresolved Item 05000128/2023201-04. which will be reviewed and assessed during the next inspection.
c. Conclusion
With the exceptions noted above, the inspector determined that surveillances were conducted and LCO were maintained in accordance with the TS requirements.
4. Experiments
a. Inspection Scope (IP 69001, Section 02.06)
The inspector reviewed the following to ensure that experiments were reviewed and conducted as required by TSs 3.6, Limitations on Experiments, and 6.5, Experiment Review and Approval:
- experiment authorizations binder
- reactor operations logbook number 261 - 268
- NSC section IV experimental facilities procedure A, Experiment Review and Approval, dated January 25, 2002
- NSC section IV experimental facilities procedure B, Sample Handling Procedures, dated February 15, 1984
- NSC section IV experimental facilities procedure E, Irradiation Cell Experiments, dated March 2, 2001
- select experiment irradiation information sheets performed from 2022 - present
- experimental device reactivity worth dated July 26, 2022
b. Observations and Findings
The inspector found that there were no new experiments that were reviewed and approved since the last inspection as required by TS 6.5 and 10 CFR 50.59, Changes, tests and experiments. The inspector also found that experiments were conducted in accordance with the licensees procedures and TS 3.5.
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c. Conclusion
The inspector determined that experiments were reviewed, approved, and conducted in accordance with TS and regulatory requirements.
5. Emergency Planning
a. Inspection Scope (IP 69001, Section 02.10)
The inspector visited the campus police dispatch center to observe an emergency alarm test from the control room. The inspector also observed the performance of the evacuation horn, inventoried the emergency supplies and equipment, and reviewed the following selected portions of the licensees emergency preparedness program to verify compliance with NRC regulatory requirements, and the licensees emergency plan:
- NESC Emergency Plan, revision 4 dated November 10, 2021
- 2023 PowerPoint Environmental Health & Safety (EHS) training
- emergency plan training quiz for EHS
- general employee training
- emergency training quiz for licensed personnel
- letter of agreement for Baylor Scott & White Medical Center
- letter of agreement from the City of College Station for fire protection, ambulance service, and emergency medical assistance
- Texas A&M University Police Department Policy Manual - Chapter 28, dated March 3, 2021
- annual training attendance for University Police Department 2022 and 2023
- evacuation drill dated October 14, 2022
- Reactor Operations Audit, dated August 26-28, 2022
- 2022 drill guide
b. Observations and Findings
NESC Emergency Plan, dated November 10, 2021, section 10.2, Conduct of Drills and Exercises, states, Onsite emergency drills will be conducted annually to test the adequacy of emergency procedures and to ensure that emergency organization personnel are familiar with their duties. At least every two years, these drills shall contain provisions for coordination with offsite emergency personnel and will test the communication links and notification procedures with those offsite agencies and support organizations.
Contrary to section 10.2 of the NESC Emergency Plan, the facility determined that no emergency drill was performed in 2023. Specifically, the inspector was informed during the inspection that the annual emergency drill was last performed October 14, 2022, and no other drill had been performed since.
Due to the continuous turnover in the licensees staff the licensee failed to plan and implement an emergency drill. The licensee relied on a single staff member to organize the annual emergency drill requirement. There was no facility turnover from this departing staff member. The inspector informed the licensee that a drill was required which included an accident scenario to include a medical emergency drill involving a
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simulated contaminated individual, radiological monitoring including contamination control methods, dose rate measurement, nonessential personnel evacuation, and record keeping, and communication drills designed to ensure reliability of the system(s)
and correct transmission and receipt of messages. The licensee informed the inspector a drill was planned for spring of 2024 to makeup the 2023 unaccounted drill. Since the licensee could not provide the NRC with a reasonable time frame by which specific corrective actions would be taken, including immediate correction action and comprehensive action to prevent recurrence, this issue is considered an IFI. The licensee was informed that the issue will be reviewed during a future inspection (IFI 05000128/2023202-05).
The inspector found that emergency plan training was conducted, emergency response call lists were maintained and posted, and emergency equipment was maintained and available as required by the emergency plan and licensee procedures.
c. Conclusion
With the exception noted above, the inspector determined the emergency preparedness program was conducted in accordance with the emergency plan.
6. Maintenance Logs and Records
a. Inspection Scope (IP 69001, Section 02.11)
The inspector observed maintenance performed on a control rod drive and reviewed the following maintenance logs and records to verify compliance with the requirements of the TS:
- AP-12, Maintenance/Repair, performed from 2023 - present
- NSC form 548, Semiannual Log Power Measuring Channel Maintenance, performed 2022 - present
- NSC form 547, Semi-annual Linear Power Measuring Channel Maintenance, performed 2022 - present
- reactor operations logbook number 268
- NSC section III reactor maintenance and surveillance procedure D, Log Power Measuring Channel Maintenance and Surveillance, dated August 19, 2003
- AP-04, Change Management, performed from 2023 - present
- AP-11, Change Management, performed 2023 - present
- NSCR-RPT-2302, 2023 Transient Rod Malfunction Analysis, dated August 13, 2023
present
present
- NSC form 559, Annual Control Rod Drive Maintenance, performed 2022 - present
present
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b. Observations and Findings
The inspector found that scheduled and unscheduled preventative and corrective maintenance activities were performed and documented in accordance with TS requirements and the licensees administrative procedures.
c. Conclusion
The inspector determined the maintenance activities were performed and documented in accordance with the TS requirements.
7. Fuel Handling Logs and Records
a. Inspection Scope (IP 69001, Section 02.12)
The inspector reviewed the following fuel handling logs and activities to verify compliance with TS requirements:
- reactor operations logbook number 267
- AP-11, Change Management, performed August 9, 2023
- NSC section III reactor maintenance and surveillance procedure B, Fuel Element Temperature Measuring Channel Maintenance and Surveillance, dated February 9, 2000
- NSC form 546, Semiannual Fuel Element Temperature Measuring Channel Maintenance, performed 2021 - present
- NSC form 578, Fuel Element Measurement and Inspection History, performed for all elements at the facility
- NSC form 581, Fuel Element Transfer Storage Basket Log, for basket No. T20
- NSC form 581 for basket No. T23
- NSC form 581 for basket No. 62
- NSC form 581 for basket No. 67
- Reactor Safety Board meeting minutes for October 16, 2023, meeting No. 204
- NSCR-RPT-2301, Proposed Core Configuration Change, dated August 2, 2023
b. Observations and Findings
On June 29, 2023, the licensee reported (EN#56595) to the Headquarter Operation Center that fuel pin #11394 did not pass the test criteria specified in TS 3.1.5, Reactor Fuel Parameters, during inspections. The licensee responded as required to identifying a degraded fuel pin and inspected the entire core. While conducting an inspection follow-up of the issue reported in EN#56595, the inspector determined a violation of TS 6.7.2 occurred and is addressed in this inspection. TS 6.7.2 states, in part, There shall be a report not later that the following working day by telephone and confirmed in writing by fax or similar conveyance to the NRC Headquarters Operations Center, and followed by a written report that describes the circumstances of the event and sent within 14 days to the Commission.
Contrary to TS 6.7.2, a written report that describes the circumstances of the event was not sent to the NRC within 14 days after the licensee determined that a reportable event occurred. Since the licensee could not provide the NRC with a reasonable time frame by
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which specific corrective actions would be taken, including immediate correction action and comprehensive action to prevent recurrence, this issue is considered an IFI. The licensee was informed that the issue will be reviewed during a future inspection (IFI 05000128/2023201-06).
The inspector found that the fuel handling activities were conducted and documented in accordance with the TS requirements and the licensees procedural requirements.
c. Conclusion
With the exception noted above, the inspector determined that the fuel inspections and movements were conducted in accordance with the TS and licensees procedural requirements.
8. Exit Interview
The inspection scope and results were summarized on January 11, 2024, with members of licensee management and staff, at the conclusion of the onsite portion of the inspection.
The inspector presented the re-exit meeting inspection results through a video conference call on March 11, 2024, to Mr. Jenkins.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel Director J. Grissom Assistant Director of Operations A. Kurwitz Radiation Safety Officer V. Vlassov Assistant Director of Engineering J. Goad Reactor Supervisor C. Crouch Program Administrator
INSPECTION PROCEDURE USED
IP 69001 Class II Non-Power Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000128/2023201-01 NOV Violation of 10 CFR 55.25, Incapacitation because of disability or illness. 05000128/2023201-02 NCV Violation of TS 3.5.1, Radiation Monitoring
05000128/2023201-03 IFI TS 6.7.2, Special Reports, for Event #56489
05000128/2023201-04 URI Follow-up on the licensees failure to calibrate the FAMs annually
05000128/2023201-05 IFI Emergency Plan section 10.2, Conduct of Drills and Exercises05000128/2023201-06 IFI TS 6.7.2, Special Reports, for Event #56595
Closed
05000128/2023201-02 NCV Violation of TS 3.5.1, Radiation Monitoring
Attachment