IR 05000182/2023201

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Purdue University - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000182-2023201 and Notice of Violation
ML23088A226
Person / Time
Site: Purdue University
(R-087)
Issue date: 05/23/2023
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Soon Kim
Purdue University Research Reactor
Arellano J
References
IR 2023001
Download: ML23088A226 (1)


Text

SUBJECT:

PURDUE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000182/2023201 AND NOTICE OF VIOLATION

Dear Dr. Kim:

From March 6 - 9, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Purdue University Reactor facility. The enclosed report documents the inspection results which were discussed on March 9, 2023, with you and members of your staff.

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 regulatory requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site 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.

May 23, 2023 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. 50-182 License No. R-87 Enclosures:

As stated cc w/enclosures: See next page Signed by Tate, Travis on 05/23/23

Purdue University Docket No. 50-182 cc:

Dr. Mark Lundstrom Interim Dean of Engineering Armstrong Hall of Engineering, Suite 3000 701 West Stadium Avenue West Lafayette, IN 47907-2045 Mayor City of West Lafayette 1200 N. Salisbury Street West Lafayette, IN 47906 John H. Ruyack, Manager Epidemiology Res Center/Indoor & Radiological Health Indiana Department of Health 2525 N. Shadeland Avenue, Suite E3 Indianapolis, IN 46219 Howard W. Cundiff, P.E., Director Consumer Protection Indiana State Department of Health 2 North Meridian Street, 5D Indianapolis, IN 46204 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

ML23088A226 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME JArellano AWaugh NParker TTate DATE 3/30/2023 4/3/2023 4/5/2023 5/23/2023

Enclosure 1 NOTICE OF VIOLATION Purdue University Docket No. 50-182 Purdue University Research Reactor License No. R-87 During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from March 6 - 9, 2023, at the Purdue University Reactor, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Purdue University research reactor technical specifications (TS) section 3.2, Reactor Safety System, states that [t]he two shim-safeties shall not be moved more than 6 [centimeters] cm from the fully inserted position unless the following conditions are met. Section 3.2.a, states that [t]he reactor safety channels and safety-related instrumentation shall be operable in accordance with Table I and II including the minimum number of channels and the indicated maximum or minimum set points. Table II, Safety-Related Channels (Area Radiation Monitors), lists one pool top monitor with the function of scram. Table II footnote (e) states,

[f]or periods of one week or for the duration of a reactor run, a radiation monitor may be replaced by a gamma sensitive instrument which has its own alarm and is observable by the reactor operator.

Contrary to TS 3.2 and TS 3.2.a, Purdue withdrew the two shim-safeties more than 6 cm from the fully inserted position with the pool top monitor replaced by a handheld detector with no scram function. Specifically, Purdue replaced the pool top monitor with a gamma sensitive instrument and operated the reactor for multiple periods from September 8, 2022, to February 2, 2023, exceeding the allowed period of one week as specified in Table II footnote (e).

This is a Severity Level IV violation (Section 6.1).

Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.201, Notice of violation, Purdue University 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.

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.

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 23rd day of May, 2023.

Enclosure 2 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.:

50-182 License No.:

R-87 Report No.:

05000182/2023201 Licensee:

Purdue University Facility:

Purdue University Reactor Location:

West Lafayette, Indiana Dates:

March 6 - 9, 2023 Inspectors:

Juan Arellano Andrew Waugh Approved by:

Travis 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

EXECUTIVE SUMMARY Purdue University Purdue University Reactor Inspection Report No. 05000182/2021203 The focus of this routine, announced inspection was the onsite review of selected aspects of the Purdue University (the licensee) research reactor facility safety program, including:

(1) organization and staffing; (2) operations logs and records; (3) procedures; (4) requalification training; (5) surveillance and limiting conditions for operation; (6) experiments; (7) health physics; (8) design changes; (9) committees, audits and reviews; (10) emergency planning; (11) maintenance logs and records; (12) fuel handling logs and records; and (13) transportation activities. 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.

Organization and Staffing

The inspector determined that the licensees organization and staffing were consistent with technical specification (TS) requirements.

Operations Logs and Records

The inspector determined that the operations logs and records were maintained consistent with the applicable TS.

Procedures

The inspector determined that procedures were controlled, maintained current, implemented, and followed in compliance with TS and license requirements.

Requalification Training

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

The inspector found that contrary to TS section 3.2, the licensee operated the reactor for multiple periods from September 8, 2022, to February 2, 2023, with an inoperable pool top monitor replaced by a gamma sensitive instrument. See section 5 of the report details below.

With the exception noted above, 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, procedural, and regulatory requirements.

Health Physics

The inspector determined that the licensees health physics program was conducted in accordance with TS, procedural, and regulatory requirements.

Design Changes

The inspector determined that design changes were conducted in accordance with TS, and regulatory requirements.

Committees, Audits and Reviews

The inspector determined that the licensees oversight programs were conducted in accordance with TS requirements.

Emergency Planning

The inspector determined that the emergency preparedness program was conducted in accordance with the emergency plan.

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

The inspector determined that the fuel movements and inspections were conducted in accordance with the TS and the licensees procedural requirements.

Transportation Activities

The inspector determined that radioactive material was transferred to the campus radioactive material license in accordance with the applicable regulations and licensee procedures.

REPORT DETAILS Summary of Facility Status The Purdue University research reactor was operated in support of training, experiments, and maintenance since the last routine inspection. During this inspection, the reactor was not operated.

1.

Organization and Staffing a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.01)

The inspector reviewed the following to verify compliance with the TS requirements for organization and staffing:

Purdue University annual operating report 2021

TS for the Purdue University reactor

change of Level 1 email dated June 30, 2022

prestart checklist and reactor operation records from 2021 - present

reactor logbook No. 62 from November 26, 2019 - March 16, 2021

reactor logbook No. 63 from March 16, 2021 - October 26, 2021

reactor logbook No. 64 from October 26, 2021 - May 24, 2022

reactor logbook No. 65 from May 24, 2022 - November 3, 2022

reactor logbook No. 66 from November 4, 2022 - present b.

Observations and Findings The inspector found that the facility staffing changed since the previous inspection and was maintained as required by TS 6.1.c, Staffing, for times that the reactor was not secured and when events required the presence of a senior reactor operator.

The inspector noted that there is currently an interim Dean of the College of Engineering (Level 1), due to the departure of the former Dean of College of Engineering, meeting the qualification requirements of the TS for the Purdue University reactor.

c.

Conclusion The inspector determined that TS requirements for organization and staffing were met.

2.

Operations Logs and Records a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.02)

The inspector reviewed the following to ensure that logs and records were maintained as required by the licensees administrative procedures and TS:

prestart checklist and reactor operation records from 2021 - present

reactor logbook No. 62 from November 26, 2019 - March 16, 2021

reactor logbook No. 63 from March 16, 2021 - October 26, 2021

reactor logbook No. 64 from October 26, 2021 - May 24, 2022

reactor logbook No. 65 from May 24, 2022 - November 3, 2022

reactor logbook No. 66 from November 4, 2022 - 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 several reactor operations met the TS requirements.

c.

Conclusion The inspector determined that operations logs and records were maintained consistent with applicable TS and the licensees procedural requirements.

3.

Procedures a.

Inspection Scope (IP 69001, Section 02.03)

The inspector reviewed the following regarding the licensees procedures to ensure that the requirements of TS 6.4 were met:

TS for the Purdue University reactor

PUR-1 standard maintenance procedure SMP-3, "RMS-3 RAM Calibration Procedure," Revision 0, dated August 25, 2021

PUR-1 standard maintenance procedure SMP-4, "AMS-4 CAM Calibration Procedure," Revision 0, dated August 25, 2021

PUR-1 standard maintenance procedure SMP-5, "RWMS Cooling Pump Motor Greasing Procedure," Revision 0, dated September 13, 2021

PUR-1 standard maintenance procedure SMP-8, "Procedure for Inspection of Fuel Plates," Revision 0, dated August 8, 2021

PUR-1 standard operating procedure SOP-05, Detector Relocation,"

Revision 0, dated September 12, 2021

PUR-1 standard operating procedure SOP-07-01, "SOP for Partial or Complete Disassembly and Reassembly of the PUR-1 Core," Revision 13, dated August 25, 2021

PUR-1 standard experiment procedure FCP-1, "Removal of Legacy Detector Holder," Revision 0, dated December 9, 2022

b.

Observations and Findings The inspector observed that the licensee maintained written procedures covering the areas specified in TS 6.4. The inspector found that the procedures in use by the licensee were current, reviewed and approved as required by TS 6.4, able to be implemented as intended, and adhered to by reactor personnel.

c.

Conclusion The inspector determined that procedural review, revision, control, and implementation satisfied TS requirements.

4.

Requalification Training a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.04)

The inspector reviewed the following aspects of the licensees requalification program to verify compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators Licenses, and the licensees NRC-approved operator requalification program:

"Operator Requalification Program for the PUR-1 Reactor Facility," dated April 1, 2017

select biennial requalification program records, dated 2021 - present

select requalification lecture records, dated 2021 - present

select individual data sheets, dated 2021 - present b.

Observations and Findings 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 the operator requalification program was conducted and completed in accordance with the NRC-approved program and regulatory requirements.

5.

Surveillance and Limiting Conditions for Operation a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.05)

The inspector reviewed the following to verify compliance with TS 3.0 and to determine if surveillance tests were performed as required by TS 4.0:

TS for the Purdue University reactor

Purdue University annual operating report 2021

PUR-1 maintenance log

reactor logbook No. 65 from May 24, 2022 - November 3, 2022

reactor logbook No. 66 from November 4, 2022 - present

select records of Cycle Schedule and Quarterly Cycle datasheets b.

Observations and Findings Purdue University research reactor TS section 3.2, Reactor Safety System, states that the two shim-safeties shall not be moved more than 6 cm from the fully inserted position unless the following conditions are met. Section 3.2.a, states that the reactor safety channels and safety-related instrumentation shall be operable in accordance with Table I and II including the minimum number of channels and the indicated maximum or minimum set points.

Table II, Safety-Related Channels (Area Radiation Monitors), lists one pool top monitor with the function of scram. Table II footnote (e) states, for periods of one week or for the duration of a reactor run, a radiation monitor may be replaced by a gamma sensitive instrument which has its own alarm and is observable by the reactor operator.

Contrary to TS 3.2, Purdue replaced the pool top monitor with a gamma sensitive instrument and operated the reactor over the allowed period of one week. Specifically, on August 26, 2022, the pool top monitor became inoperable and was replaced with a handheld ion chamber with an alert setpoint of 30 millirem (mrem)/hour and an alarm setpoint of 50 mrem/hour that was visually observable by the operator. For multiple periods from September 8, 2022, the reactor was operated with a handheld ion chamber until the pool top monitor was reinstalled and successfully calibrated on February 2, 2023.

In accordance with the NRC Enforcement Policy section 6.1.d, this is determined to be a Severity Level IV violation and will be recorded as Notice of Violation (NOV)05000182/2023201-01.

With the exception noted above, the inspector found that the surveillance tests were completed as required by the TS and the LCO verifications were completed on schedule and in accordance with the licensees procedures.

The NRC staff issued Apparent Violation (AV) 50-182/2020201-01, Exceeding Maximum Licensed Power Level (License Condition 2.C.1), and AV 50-182/2020202-02, Operating with Inoperable Nuclear Instrumentation (TS 4.2.g), to Purdue in its special inspection report dated December 7, 2020 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML20332A083). The NRC also identified the issues as open items. On February 16, 2021, the NRC staff issued a notice of violation (NOV)

for these issues (ADAMS ML21035A348). During this inspection, the inspector reviewed the licensees implementation of corrective actions as stated in its response to the NOV (ADAMS ML21035A014). The inspector found that the licensee returned nuclear instrumentation to service after appropriate surveillances required by TS were completed. The inspector also determined, based on reactor logbooks, the licensee operated the reactor several times since the violation within the licensed power level. Based upon

the above, the staff determined that corrective actions have been implemented appropriately and therefore, both open items for the AVs are closed.

c.

Conclusion The inspector found that contrary to LCO 3.2.a, the licensee operated the reactor for multiple periods from September 8, 2022, to February 2, 2023, with an inoperable pool top monitor replaced by a gamma sensitive instrument.

With the exception noted above, the inspector determined that surveillances were conducted and LCO were maintained in accordance with the TS requirements.

6.

Experiments a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.06)

The inspector reviewed the following to ensure that experiments were reviewed and conducted as required by TS 3.5 and 6.5:

form B, Request for Sample Irradiation, forms from 2021 - present

PUR-1 standard experiment procedure EXP-2, Irradiation and Testing of Neutron Detection and Instrumentation, dated October 15, 2021

PUR-1 standard experiment procedure EXP-3, Calibration of Equipment and Measurement of Ar-41 Effluent, dated February 17, 2022 b.

Observations and Findings The inspector found that experiments were reviewed and approved 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.

c.

Conclusion The inspector determined that experiments were reviewed, approved, and conducted in accordance with TS and regulatory requirements.

7.

Health Physics a.

Inspection Scope (IP 69001, Section 02.07)

The inspector toured the facility and observed radiological signs and postings.

The inspector also reviewed the following to ensure the licensees health physics program adheres to the requirements of 10CFRPart 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, Standards for Protection against Radiation, and TS 4.7:

Purdue University annual operating report 2021

select personnel and area dosimetry records from 2021 - present

select radiation safety training records

as low as reasonably achievable (ALARA) plan for the Purdue University Reactor PUR-1, dated March 10, 2022

Purdue University Radiation Safety Manual, dated January 7, 2022

PUR-1 Water Analysis Reports, dated 2021 - present

radiation and radioactive contamination surveys from 2021 - present

Electronic dosimeter signage sheets from 2021 - present

Purdue University radiological and environmental management remote area monitor calibration records from 2021 - present

Purdue University radiological and environmental management continuous air monitor calibration records from 2021 - present b.

Observations and Findings The inspector found that practices regarding the use of dosimetry, radiation monitoring equipment, placement of radiological postings, posting of notices, use of protective clothing, and the handling and storing of radioactive material or contaminated equipment was in accordance with regulations and the licensees radiation protection program. The inspector found that the radiological effluent releases and radiation survey, sampling, and monitoring met the regulatory requirements. The inspector also found that training was conducted for radiation workers and ALARA principles were implemented as required by licensee procedures.

The NRC staff issued NOV 50-182/2021203-01, Violation of TS 6.7.a, Annual Operating Report Due to Failure to Measure and Report Argon-41 Effluents, to Purdue on July 29, 2021, (ADAMS ML21189A289). During this inspection, the inspector reviewed the licensees implementation of corrective actions associated with the violation. The inspector noted that the licensee performed an experiment to obtain an equation to calculate the amount of Argon-41 released from the reactor based on reactor usage. The inspector verified that the Committee on Reactor Operations (CORO) reviewed and approved the experiment as required by TS and the method for determining the Argon-41 released. The inspector also found the licensee reported the quantity of Argon-41 released in the most recent annual operating report.

Based upon this follow-up, the inspector found the corrective action adequate; therefore, the NOV is closed.

c.

Conclusion The inspector determined that the licensees health physics program was conducted in accordance with TS, procedural, and regulatory requirements.

8.

Design Changes a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.08)

The inspector reviewed the following to ensure that modifications to the facility

were made in accordance with the requirements of 10 CFR 50.59 and the TS:

Purdue University annual operating report 2021

select 10 CFR 50.59 screening evaluations, dated 2021 - present

Committee on Reactor Operations (CORO) minutes 2021 3rd Quarter dated August 25, 2021

CORO minutes 2021 4th Quarter dated October 15, 2021

CORO minutes 2022 1st Quarter dated February 24, 2022

CORO minutes 2022 2nd Quarter dated June 21, 2022 b.

Observations and Findings The inspector found that design changes were reviewed and approved as required by 10 CFR 50.59. The inspector also found that the performance of modified equipment and the procedures and drawings related to that equipment met regulatory and TS requirements.

c.

Conclusion The inspector determined that design changes were conducted in accordance with TS and regulatory requirements.

9.

Committees, Audits and Reviews a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.09)

The inspector reviewed the following to ensure that committees, audits, and reviews were conducted as required by the licensees procedures and TS 6.2:

CORO minutes 2021 3rd Quarter, dated August 25, 2021

CORO minutes 2021 4th Quarter, dated October 15, 2021

CORO minutes 2022 1st Quarter, dated February 24, 2022

CORO minutes 2022 2nd Quarter, dated June 21, 2022

Reactor facility security plan audit, dated May 16, 2022

PUR-1 (# R-87) TS audit, dated February 16, 2023

PUR-1 (# R-87) TS audit, dated March 18, 2022

PUR-1 (# R-87) emergency plan audit, dated April 22, 2022

PUR-1 (# R-87) ALARA program audit, dated September 15, 2022

PUR-1 (# R-87) ALARA program audit, dated August 11, 2021

PUR-1 (# R-87) maintenance audit, dated January 11, 2021

PUR-1 (# R-87) maintenance audit, dated March 9, 2022

PUR-1 nuclear liability records retention audit, dated March 9, 2022

PUR-1 (# R-87) operator retraining and requalification audit, dated April 22, 2022 b.

Observations and Findings The inspector observed that the composition of the CORO was as specified in the TS. The inspector found that the CORO met at the prescribed frequency and the CORO provided the oversight and reviews of the reactor programs as

required by the TS.

c.

Conclusion The inspector determined that the licensees oversight programs were conducted in accordance with TS.

10.

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 reviewed the following selected portions of the licensees emergency preparedness program to verify compliance with NRC regulatory requirements, and the licensees emergency plan:

PUR-1 standard emergency procedure SEP-1, "Emergency Procedures,"

revision 2, dated April 6, 2021

"Emergency Plan for the Purdue University Reactor," revision 2, dated December 20, 2021

radiation emergency management drill after action review dated April 28, 2022

Purdue exercise plan reactor drill 2022 overview documents b.

Observations and Findings The inspector found that emergency plan training was conducted, drills were performed, 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 The inspector determined the emergency preparedness program was conducted in accordance with the emergency plan.

11.

Maintenance Logs and Records a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.08)

The inspector reviewed the following maintenance logs and records to verify compliance with the requirements of TS:

Purdue University annual operating report 2021

maintenance lists dated 2021 - present

PUR-1 maintenance log

reactor logbook No. 62 from November 26, 2019 - March 16, 2021

reactor logbook No. 63 from March 16, 2021 - October 26, 2021

reactor logbook No. 64 from October 26, 2021 - May 24, 2022

reactor logbook No. 65 from May 24, 2022 - November 3, 2022

reactor logbook No. 66 from November 4, 2022 - present b.

Observations and Findings The inspector found that schedules 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.

12.

Fuel Handling Logs and Records a.

Inspection Scope (Inspection Procedure (IP) 69001, Section 02.08)

The inspector reviewed the following fuel handling logs and activities to verify compliance with TS requirements:

2022 fuel inspection video

PUR-1 core status board

2021 fuel inspection results and notes memorandum

reactor logbook No. 63 from March 16, 2021 - October 26, 2021

reactor logbook No. 65 from May 24, 2022 - November 3, 2022 b.

Observations and Findings 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 The inspector determined that the fuel inspections and movements were conducted in accordance with the TS and licensees procedural requirements.

13.

Transportation Activities a.

Inspection Scope (IP 86740)

The inspector interviewed personnel and reviewed the following to ensure the licensees program for transporting radioactive materials met NRC and Department of Transportation requirements:

Purdue University Radiation Safety Manual, dated January 7, 2022 b.

Observations and Findings

The inspector verified that radioactive material waste generated at the Purdue University reactor was transferred to the Purdue University campus material license. The inspector found that these transfers were performed in accordance with facility guidelines.

c.

Conclusion The inspector found that radioactive material transfers were completed in accordance with procedural requirements.

14.

Exit Interview The inspection scope and results were summarized on March 9, 2023, with members of licensee management and staff. The inspector described the areas inspected and discussed the inspection results.

Attachment PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel Reactor Director S. Chatzidakis Associate Director T. Miller Reactor Supervisor B. Jowers Reactor Operator Other Personnel J. Young Radiation Safety Officer N. Claus Health Physicist T. Smith Undergraduate Research Assistant INSPECTION PROCEDURE USED IP 69001 Class II Non-Power Reactors IP 86740 Transportation Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-182/2023201-01 NOV Violation of TS 3.2.a, withdrawing the two shim-safeties more than 6 cm from the fully inserted position without a required pool top monitor.

Closed 50-182/2020201-01 AV Exceeding Maximum Licensed Power Level (License Condition 2.C.1)

50-182/2020201-02 AV Operating with Inoperable Nuclear Instrumentation (TS 4.2.g)

50-182/2021203-01 NOV Violation of TS 6.7.a, Annual Operating Report Due to Failure to Measure and Report Argon-41 Effluents.