IR 05000184/2025201
| ML25224A033 | |
| Person / Time | |
|---|---|
| Site: | National Bureau of Standards Reactor |
| Issue date: | 08/25/2025 |
| From: | Jon Greives Office of Nuclear Reactor Regulation |
| To: | Adams J US Dept of Commerce, National Institute of Standards & Technology (NIST) |
| References | |
| IR 2025201 | |
| Download: ML25224A033 (1) | |
Text
SUBJECT:
NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY - U.S. NUCLEAR REGULATORY COMMISSION 1rd and 2nd QUARTER 2025 SUPPLEMENTAL INSPECTION REPORT NO. 05000184/2025201
Dear Dr. Adams:
From January 1, 2025 - June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the National Institute of Standards and Technology (NIST) Center for Neutron Research facility in accordance with the NIST Supplemental Inspection Plan dated August 1, 2022 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML22206A008). The NRC is implementing the supplemental inspection plan based on the violations identified in the NRC special inspection report dated March 16, 2022 (ML22066B312), and the confirmatory order (CO) dated August 1, 2022 (ML22202A423). The supplemental inspections covered in the enclosed report reviewed and assessed the licensees implementation of corrective actions. The enclosed report presents the results of that inspection, which were discussed on June 29, 2025, with members of your staff.
During this inspection, the NRC determined that a Severity Level IV violation of NRC requirements occurred. This violation is being treated as a non-cited violation (NCV), consistent with section 2.3.2.a of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, 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.
The supplemental inspection plan consists of activities specified in the Inspection Manual Chapter (IMC) 2545, Research and Test Reactor Inspection Program, additional inspection activities necessary to determine that the licensee has implemented adequate corrective actions, and inspection activities to support confirmation that the licensee has met the requirements of the CO. The NRC conducted supplemental inspections identified in this report using the following procedures:
- Inspection Procedure (IP) 69002, Class III Research and Test Reactors
- IP 69003, Class 1 Research and Test Reactor Operator Licenses, Requalification, and Medical Examinations August 25, 2025 * IP 69006, Class 1 Research and Test Reactors Organization and Operations and Maintenance Activities
- IP 69007, Class I Research and Test Reactor Review and Audit and Design Change Functions
- IP 69008, Class I Research and Test Reactor Procedures
- IP 69012, Class I Research and Test Reactors Radiation Protection
- IP 40100, Independent Safety Culture Assessment Follow-up
- IP 93100, Safety-Conscious Work Environment Issue of Concern Followup
- IP 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders The NRC staff will continue to conduct supplemental inspections, in accordance with the supplemental inspection plan, to provide increased post-restart oversight until the NRC staff determines that reasonable assurance for the safety of the NIST test reactor operations can be achieved through routine inspections, in accordance with IMC 2545.
The supplemental 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 activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.
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 enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs document system ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, Jonathan Greives, Acting Director Division of Advanced Reactors and Non-Power Production and Utilization Facility Office of Nuclear Reactor Regulation Docket No. 50-184 License No. TR-5 Enclosure:
As stated cc w/enclosure: GovDelivery Subscribers Signed by Greives, Jon on 08/25/25
ML25224A033 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NRR/DANU/D NAME BLin NParker TBrown JGreives DATE 8/12/2025 8/14/2025 8/15/2025 8/25/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.:
50-184 License No.:
TR-5 Report Nos.:
05000184/2025201 Licensee:
National Institute of Standards and Technology Facility:
National Bureau of Standards Test Reactor Location:
Gaithersburg, Maryland Dates:
January 1, 2025 - June 30, 2025 Inspectors:
Brian Lin, Reactor Inspector Dori Willis, Safety Culture Assessor Carleen Parker, Safety Culture Assessor Approved by:
Jonathan. Greives, Acting Director Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
- 2 -
EXECUTIVE SUMMARY National Institute of Standards and Technology National Bureau of Standards Test Reactor Supplemental Inspection Report No. 05000184/2025201 The U.S. Nuclear Regulatory Commissions (NRC) program for overseeing the safe operation of research and test reactors is described in Inspection Manual Chapter (IMC) 2545, Research and Test Reactor Inspection Program. A supplemental inspection was established in accordance with the National Institute of Standards and Technology (NIST) Supplemental Inspection Plan issued on August 1, 2022 (Agencywide Documents Access and Management System Accession No. ML22206A008). The inspector conducted the supplemental inspection in accordance with the objectives described in the plan:
assure corrective actions to address the seven special inspection violations are timely, effective, and sustained
assure restart readiness activities are comprehensive and necessary activities to restart and safely operate are completed
assure corrective actions completed and planned direct timely actions to effectively address and correct issues and preclude re-occurrence.
This supplemental inspection report documents the NRC staffs inspection activities in accordance with the supplemental inspection plan objective areas outlined above. One violation was identified in this report.
For a summary of the status supplemental inspection objectives see table 1 in appendix A of this report.
- 3 -
List of Violations Violation of Title 10 of the Code of Federal Regulations (10 CFR) 55.53(h) for failure to meet requirements of the operator requalification plan prior to conducting licensed activities.
Severity Report Section Severity Level IV NCV 2025201-01 Open 69002 The inspector identified a Severity Level IV violation of 10 CFR 55.53(h) for the facility permitting senior licensed operators to conduct licensed activities when they did not meet all requirements as described in 10 CFR 55.59(a)(2)(ii) and section 3.2.5 of the Requalification Program for the National Bureau of Standards Test Reactor (NBSR). As a result, the licensee failed to ensure that senior licensed operators were properly evaluated during the annual operating test period.
Additional Tracking Items None.
- 4 -
REPORT DETAILS 1. Introduction NIST operates the NBSR (hereinafter the NIST test reactor) at the NIST Center for Neutron Research (NCNR) located on the NIST campus in Gaithersburg, Maryland. The NIST test reactor is a heavy-water (D2O)- moderated-and-cooled, enriched-fuel, tank-type reactor designed to operate at 20 megawatts thermal power. The facility normally operates continuously during a seven-week operational cycle that consists of approximately 38 days of operation, followed by 10-day refueling and maintenance outages. The facility remained shut down following the February 3, 2021, event and restarted on March 16, 2023, intermittently at lower reactor power levels. On July 18, 2024, the facility shutdown and entered an outage period for reactor vessel cleaning and other scheduled maintenance items scheduled for completion by October 2025.
This supplemental inspection report describes the inspections conducted from January 1, 2025, through June 30, 2025. The NRC staff will update the supplemental inspection plan, continue supplemental inspections, and issue subsequent supplemental inspection reports. The supplemental inspection plan lists the objectives that will be conducted at the NCNR test reactor until the NRC staff determines routine inspections in accordance with the NRC IMC 2545 are adequate to ensure safety.
2. Emergency Plan and Event Response a. Observations and Findings This inspection included a review of the licensees emergency procedures, exercises and drills, training, and equipment to verify compliance with the licensees emergency plan and applicable regulatory requirements. Specifically, the inspection included a review of the following:
Simulated security exercise prompting radiological monitoring, dose rate measurements, evacuation of non-essential personnel, communications between operators and support organizations, and medical response.
b. Conclusion The inspector closed the remaining inspection objective and concluded that the licensee conducted the exercise and critique adequately to identify and enter deficiencies into the corrective action program. The inspector noted that emergency drills were conducted annually and response training for operators were completed as required by the TS. The inspector will continue to monitor the licensees performance in this area in future supplemental inspections.
- 5 -
3. Operator Licensing a. Observations and Findings On May 6, 2025, the inspector reviewed selected documents and training records to verify the licensees operator requalification and training activities were conducted in accordance with the licensees approved requalification plan and 10 CFR Part 55, Operators Licenses. Due to the long-term shutdown, operators must still satisfy the requirements of the requalification program and 10 CFR 55.53(e) in order to maintain an active license. The requirement for maintaining an active operator license is independent of plant status and if provisions of 10 CFR Section 55.53, Conditions of licenses, cannot be met, a specific exemption should be pursued. Specifically, the inspection included a review of the following:
random selection of operator training records and requalification examinations
select medical examination records
control room logbook
requalification Program for the NBSR, dated May 2021 b. Conclusion The inspector identified a Severity IV NCV of 10 CFR 55.53(e) when operators did not complete tasks required in their operating tests and evaluations, resulting in all operators transitioning to inactive status. To restore compliance the licensee submitted an exemption request on June 5, 2025 (ML25162A200), and a training plan on June 18, 2025 (ML25177D077), to reinstate licensed operators to active status. The details of the NCV are listed in the inspection results section of this inspection report.
Two objectives remain open and will be inspected at a later date.
4. Management Oversight a. Observations and Findings The inspector observed portions of the licensees training on assisting the efforts on debris removal from the reactor vessel. Licensee management oversight was appropriate to ensure policies and procedures were discussed and questions and concerns were addressed. The inspector observed licensee management engage personnel with entering technical issues in their corrective action program (CAP).
Additionally, management oversight of procedure adherence continues to trend positively with appropriate observations completed during routine and infrequent activities.
b. Conclusion The inspector concluded previously reviewed supplemental inspection objectives documented remain closed as noted in table 1 in appendix A. The inspector will continue to monitor the licensees performance in this area in future supplemental inspections.
- 6 -
5. Corrective Actions a. Observations and Findings During this inspection period, the inspector reviewed several submissions into the CAP and focused on the following: weld failures on the refueling plug, snap ring failures, and reactor vessel cleaning. The inspector observed progress with locating much of the helium leakage from equipment in the refueling plug and will aid in with lowering radiation levels at the C-200 level. The NCNR staff recognized the need to address the several cracks in the structural welds in the lower section of the refueling plug.
Continued efforts are focused on restoring the structural integrity of the refueling plug and adding a redundant load path and monitoring system to identify additional weld failures. NCNR contracted a vendor to analyze the condition of the welds and propose a repair of the welds.
b. Conclusion The inspector concluded previously reviewed supplemental inspection objectives remain closed as noted in table 1 in appendix A. Two objectives remain open, and the inspector will continue to evaluate the licensees CAP in future inspections.
6. Safety Culture a. Observations and Findings From April 28-29, 2025, the NRC conducted a pulse of the nuclear safety culture within the NIST NCNR organization. To review the licensees progress on implementation of the corrective actions identified as part of the independent safety culture assessment, as provided in the June 11, 2024, letter to the NRC transmitting the assessment. On May 28, 2025, the NRC staff observed the Integrated Safety Culture Monitoring Panel (ISCMP).
- Leadership Safety Values and Actions Based on the interviews and observations, the NRC staff continued to identify a focus area under Leadership Safety Values and Actions in the attribute of resources.
Specifically, NCNR staff reported that resources continue to be a challenge and an area for improvement for the NCNR. The NRC staff noted that NCNR staff report that they are concerned about staffing to support future operation plans. The NRC staff does note that NCNR has made key personnel selections for training staff. The NRC staff determined that actions to implement continuous training were viewed favorably by the personnel interviewed.
- Work Processes Based on the interviews with NCNR staff, the NRC staff determined that NCNRs actions in the area of work processes, specifically updating procedures and ensuring procedural adherence, was viewed as having improved.
- 7 -
Environment for Raising Concerns (Safety Conscience Work Environment)
The NRC staff determined that the environment for raising concerns at NCNR has remained consistent. Specifically, all personnel stated they would raise a concern. Most personnel stated that management is very engaged in resolving concerns as concerns are raised. While some personnel stated they did not always receive feedback on the resolution of concerns that were entered into the CAP, the NRC staff determined that the system does send an email to the originator. Then the originator must go into the system in order to find the follow-up actions. In addition, NCNR did establish an Employee Concerns Program (ECP) and selected an ECP manager, but facility staff reported that they were not generally aware of the program.
The NRC staff determined that NISTs ISCMP members shared experiences in their different organizations and then three safety culture traits were discussed in detail including: Personal Accountability, Questioning Attitude, and Decision Making. The NIST staff used different indicators (CAP, the recent assessment) to grade NISTs culture and to determine if it was improving or declining. Members of the NIST ISCMP made suggestions to improve each trait, such as re-invigorating the good catch program. The NIST ISMCP cited the lack of resources several times as an issue. The NRC staff determined that NIST was implementing its ISCMP in accordance with their procedure.
b. Conclusion The NRC staff determined that the licensee has a plan to implement the corrective actions associated with the safety culture assessment. However, the corrective actions provided by the contractor seem to be more holistic and not discrete and easily actionable.
The inspector concluded the previously reviewed supplemental inspection objectives remain closed as noted in table 1 in appendix A. The inspector noted that the licensees third independent safety culture assessment was completed and submitted to the NRC on May 30, 2025 (ML25177C602), along with a letter in which NIST committed to address areas for improvement and in need of attention addressed as part of their Integrated Performance Improvement Plan. The inspection of the third independent safety culture assessment will be scheduled at a later date. The safety culture inspection following the 3rd partys 2nd assessment is closed with one objective remaining open.
Inspection Results Non-Cited Violation (NCV 05000184/2025201-01)
69002.03.02 The inspector determined that the violation was placed into the CAP to restore compliance and address recurrence within a reasonable period of time. As a result, this non-willful, non-repetitive violation will be treated as a NCV consistent with section 2.3.2.a of the NRC Enforcement Policy.
Violation: Section 55.53(h) of 10 CFR states that each licensee, shall complete a requalification program as described by 10 CFR 55.59.
Section 3.2.5 of NBSR requalification program requires that, At least five tasks selected from Section 3.2.5.1, including a reactor startup and shutdown, shall be performed and evaluated.
- 8 -
Contrary to the above, the inspector identified that the facility failed to ensure multiple senior operator license holders were evaluated during the annual operating test period to the appropriate level of their license prior to performance of licensed activities at the conclusion of an extended maintenance period in 2024. Specifically, operators did not fully complete the required tasks in the operating test during the requalification period prior to refueling operations and reactor start up in April 2024.
7. Exit Meeting The inspector discussed the inspection with the licensee at the conclusion of this portion of the special inspection on July 29, 2025.
Attachment REFERENCES Administrative Rule (AR) 4.0, Fuel Manipulation Proficiency Requirements, Revision 1 AR 1.0, Conduct of Operations, Revision 2 AR 2.2.2, RO/SRO Qualification, Revision 1 AR 5.0, Procedure Us and Adherence, Revision 2 AR 5.4, Observation Program and Checklist, Revision 2 AR 6.0, Engineering Program, Revision 1 AR 7.2, Corrective Action Program, Revision 1 AR 7.2.0, Corrective Action Program Level 0 Requirements and Workflow, Revision 1 AR 7.2.1, Corrective Action Program Level 1 Requirements and Workflow, Revision 1 AR 7.2.2, Corrective Action Program Level 2 Requirements and Workflow, Revision 1 AR 7.2.3, Corrective Action Program Level 3 Requirements and Workflow, Revision 1 Emergency Instruction (EI) 0.3, Emergency Organization, Revision J EI 2.4, Alert - Security Breach Affecting Reactor Confinement, Revision 1 EI 5.2, Non-Essential Personnel Evacuation, Revision 1 EI 5.3, Essential Personnel Evacuation, Revision 1 EI 5.5, Control Room Evacuation Checklist, Revision 1 EI 7.1, Interactions between NCNR and NIST Fire Department, Revision 1 EI 7.2, Interactions between NCNR and NIST Police Services, Revision 1 EI 7.4, Interactions between NCNR and NIST Fire Department, Revision 1 Health Physics Instruction (HP) 6.1, Ludlum 375 Rate Meter Calibration, Revision A HP 2.5, Process Room and Subpile Room Survey, Revision 1 HP 2.2, Conduct of Radiation and Contamination Surveys, Revision 1 HP 6.4, Releases of Airborne Radioactive Material to the Environment, Revision 1 Maintenance Procedure (MP) 5.3, Radiological Measurements of Fuel or Objects in Storage Pool, Revision 0 Operating Instruction (OI) 6.2.2, Fuel Transfer System Shutdown, Revision 3 OI 9.2.1, Tritium Monitoring System Operation, Revision 1 Technical Specification Procedure (TSP) 4.6(3), Reactor Emergency Power Equipment Test, Revision 1 NIST Refuel Plug Walkdown Summary - Engineering Information Record NIST Test Reactor Refueling Plug Weld Repair Evaluation - Engineering Information Record Design Request Note for Diverse and Redundant Engineering Safety Features for Refueling Plug -
NCNR-RE-TM-000670 Technical Memorandum-Refurbishment of Refueling Plug - NCNR-RE-TM-000673 System Requirement Document for the Refueling Plug Redundant Load Path - NCNR-RE-TM-000674 Refueling Plug Failure Modes and Effects Analysis - NCNR-RE-TM-000684 Refueling Plug Redundant Load Path Test and Validation Plan - NCNR-RE-TM-000685 NCNR Radiological Storage Pool Communication Exercise
- 2 -
PARTIAL LIST OF PERSONS CONTACTED Licensee Director T. Newton Deputy Director R. Strader Chief, Reactor Operations D. Sahin Chief, Reactor Engineering S. Dewey Chief, Health Physics D. Griffin Senior Reactor Operator J. Seiter Senior Reactor Operator, Training Coordinator A. Gahan Chief, Aging Reactor Management
S. MacDavid Supervisory Electronics Technician D. Mattis Engineer INSPECTION PROCEDURES USED IP 69002 Class III Research and Test Reactors IP 69003 Class I Research and Test Reactor Operator Licenses, Requalification, and Medical Examinations IP 69006 Class I Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class I Research and Test Reactor Procedures IP 69009 Class I Research and Test Reactor Fuel Movement IP 92702 Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders ITEMS OPENED, CLOSED, AND DISCUSSED Opened:
None Closed:
None
- 3 -
Appendix A: Table 1 STATUS ACTIVITY PRE-STARTUP PROCEDURE CLOSURE REPORT Emergency Plan / Event Response Closed Evaluate adequacy of emergency response equipment identified in the emergency plan Yes IP 69011 4Q2022 Closed Evaluate adequacy of emergency plan implementation procedures Yes IP 69011 4Q2022 Closed Observe implementation of emergency plan procedures No IP 69011 1Q2025 Closed Review availability of items or systems for operators to check prior to control room evacuation No IP69011 4Q2022 Closed Review availability of post-evacuation checklist No IP69011 4Q2022 Closed Evaluate adequacy of guidance in Emergency Instructions for confinement re-occupation Yes IP69011 4Q2022 Refueling / Fuel Handling Closed Evaluate adequacy of fueling and defueling procedures Yes IP69009 4Q2022 Closed Observe implementation of fueling procedures Yes IP69009 4Q2022 Closed Observe implementation of defueling procedures No IP69009 4Q2022 Closed Evaluate adequacy of procedures used for latch checking Yes IP92702 4Q2022 Closed Observe implementation of procedures for latch checking Yes IP92702 4Q2022 Open Evaluate adequacy of loaded restart core for consistency with technical specifications and analysis Yes IP92702 TBD Startup Closed Evaluate adequacy of reactor startup procedures determined necessary for restart Yes IP69008 4Q2022 Closed Observe implementation of reactor startup procedures Yes IP69008 4Q2022 Closed Review pre-critical start-up procedures Yes IP69008 4Q2022
- 4 -
Operator Licensing Closed Evaluate adequacy of proficiency training of reactor operations personnel identified to be completed prior to startup (including fuel handling, refueling and latch checking proficiency of operators)
Yes IP69008 4Q2022 Open Evaluate adequacy of licensed operator proficiency training No IP69003 TBD Open Observe implementation of licensed operator proficiency training No IP69003 TBD Closed Evaluate adequacy of operator training on off-normal conditions during startup and operations conditions Yes IP92702 4Q2022 Management Oversight Closed Evaluate adequacy of qualification training for supervisors overseeing refueling operations Yes IP92702 4Q2022 Closed Evaluate adequacy of policies and procedures in place to ensure training of reactor operations and engineering personnel on procedure adherence Yes IP92702 4Q2022 Corrective Actions Open Evaluate program to ensure expectations, processes, and procedures are in place to identify and implement safety improvements No IP92702 TBD Open Evaluate the adequacy of corrective actions for re-evaluated root cause analysis performed with emphasis on nuclear safety culture No IP92702 TBD Closed Confirm primary system characterization/readiness following fuel debris cleanup Yes IP92701 4Q2022 Closed Confirm that the appropriate shielding is in place to ensure safe access for maintenance Yes IP92701 4Q2022
- 5 -
Closed Confirm consideration of carbon dioxide build up potential in safety documentation and emergency plan No IP92701 TBD Closed Review root cause of #2 shutdown pump failure and corrective actions, including evaluation of the extent of condition No IP92701 4Q2022 Safety Committee Oversight Open Review disposition of safety assessment committee recommendations No IP69007 TBD Procedures Open Evaluate program and processes in place to ensure quality of written procedures, to ensure procedures can be effectively executed, and to ensure procedures are periodically evaluated to implement improvements No IP69009 TBD Closed Evaluate startup procedures for consistency with INPO-1103, Guideline for Excellence in Procedure and Work Instruction Use and Adherence Yes IP92702 4Q2022 Closed Evaluate reactor startup procedures to instruct operators to identify abnormal fluctuations in nuclear instrumentation Yes IP92702 4Q2022 Design Change Process Closed Review refueling tool wear and replacement program No IP69008 4Q2022 Open Review change process program and procedures for compliance in Title of the Code of Federal (10 CFR) Section 50.59 No IP69008 TBD Open Evaluate effectiveness of Engineering Change Management Program for ensuring changes are made consistent with 10 CFR 50.59 No IP92701 TBD Safety Culture Closed Conduct safety-conscious work environment follow-up inspection prior to startup Yes IP93100 4Q2022 Closed Conduct safety culture inspection following 3rd party 1st assessment No IP93100 4Q2024 Closed Conduct safety culture inspection following 3rd party 2nd assessment No IP93100 2Q2025 Open Conduct safety culture inspection following 3rd part 3rd assessment No IP93100 TBD
- 6 -
Material Control and Accounting IP85102 Closed Evaluate adequate implementation of nuclear material accounting for damaged fuel element No IP92701 4Q2022