IR 05000186/2018202

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University of Missouri-Columbia - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000186/2018202
ML18296A658
Person / Time
Site: University of Missouri-Columbia
Issue date: 11/14/2018
From: Anthony Mendiola
Research and Test Reactors Oversight Projects Branch
To: Robertson D
Univ of Missouri - Columbia
Schuster W, NRR/DLP, 415-1590
References
IR 2018202
Download: ML18296A658 (23)
v • d • e


Text

ber 14, 2018

SUBJECT:

UNIVERSITY OF MISSOURI-COLUMBIA - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000186/2018-202

Dear Dr. Robertson:

From October 14-18, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the University of Missouri-Columbia Research Reactor. The enclosed report documents the inspection results which were discussed on October 18, 2018, with 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 observed various activities in progress, interviewed personnel, and reviewed selected procedures and representative records.

Based on the results of this inspection, the NRC has determined that two Severity Level IV violations of NRC requirements have occurred. The violations are being treated as a 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 enclosure, 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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). If you have any questions concerning this inspection, please contact William Schuster at (301) 415-1590, or by electronic mail at William.Schuster@nrc.gov.

Sincerely,

/RA/

Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-186 License No. R-103 Enclosure:

As stated cc: See next page

University of Missouri-Columbia Docket No. 50-186 cc:

Les Foyto, Associate Director Reactor and Facilities Operations University of Missouri - Columbia Research Reactor Center 1513 Research Park Drive Columbia, MO 65211 Homeland Security Coordinator Missouri Office of Homeland Security P.O. Box 749 Jefferson City, MO 65102 Planner, Dept of Health and Senior Services Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102 Deputy Director for Policy Department of Natural Resources 1101 Riverside Drive Fourth Floor East Jefferson City, MO 65101 A-95 Coordinator Commissioners Office Office of Administration P.O. Box 809 State Capitol Building, Room 125 Jefferson City, MO 65101 Planning Coordinator Missouri Department of Natural Resources 1101 Riverside Drive Jefferson City, MO 65101 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611

ML18296A658 *concurred via e-mail NRC-002 OFFICE NRR/DLP/PROB/PM* NRR/DLP/PROB/LA* NRR/DLP/PROB/BC NAME WSchuster NParker AMendiola DATE 11/6//2018 11/6/2018 11/14/2018

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-186 License No.: R-103 Report No.: 05000186/2018-202 Licensee: University of Missouri-Columbia Facility: University of Missouri-Columbia Research Reactor Location: Research Park Columbia, Missouri Dates: October 14-18, 2018 Inspector: William Schuster Approved by: Anthony J. Mendiola, Chief Research and Test Reactors Oversight Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Enclosure

EXECUTIVE SUMMARY University of Missouri-Columbia University of Missouri-Columbia Research Reactor NRC Inspection Report No. 05000186/2018-202 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the University of Missouri-Columbia (the licensee) 10-megawatts Class I research reactor facility safety program, including: (1) operator licenses, requalification, and medical examinations; (2) organization and operations and maintenance activities; (3) review and audit and design change functions; (4) procedures; (5) fuel movement; (6) surveillance; (7) emergency preparedness; and, (8) event follow-up. The licensees program was acceptably directed toward the protection of public health and safety, and generally in compliance with U.S. Nuclear Regulatory Commission (NRC) requirements. Two Non-Cited Severity Level IV violations were identified.

Operator Licenses, Requalification, and Medical Examinations

  • Operator requalification was being completed as required by the requalification program and the program was being maintained up-to-date.
  • Medical examinations were being completed biennially for each operator as required.

Organizational and Operations and Maintenance Activities

  • The organizational structure and staffing were consistent with technical specification (TS)

requirements.

  • Reactor operations were conducted in accordance with procedures and the appropriate logs were being maintained.
  • The maintenance system was being used to ensure that maintenance tasks were completed in a timely manner.

Review and Audit and Design Change Functions

  • The facility Reactor Advisory Committee (RAC) was meeting quarterly, reviewing the topics outlined in the TS, and conducting annual audits of facility operations as required.
  • The review, evaluation, and documentation of changes to the facility satisfied NRC requirements.

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Procedures

  • The procedure review, revision, control, and implementation program satisfied TS requirements.

Fuel Movement

  • Fuel movements and inspections were conducted in accordance with TS and procedural requirements.

Surveillance

  • Surveillance activities at the facility were completed within the TS-prescribed time frames.

Emergency Preparedness

  • Emergency response equipment was being maintained as required.
  • The memoranda of understanding (MOU) between the licensee and various support agencies were being maintained.
  • Emergency drills were being conducted annually as required by the E-Plan.

Event Follow-up

  • A Severity Level IV non-cited violation (NCV) was issued for failure to comply with TS 3.6.a which requires the emergency electrical power system to be operable during reactor operation.

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REPORT DETAILS Summary of Facility Status The University of Missouri-Columbia continued to operate the 10-megawatts research reactor in support of isotope production, silicon irradiation, reactor operator (RO) training, and various types of research. During the inspection, the reactor was operated following the weekly maintenance shutdown, to support laboratory experiments and product irradiation.

1. Operator Licenses, Requalification, and Medical Examinations a. Inspection Scope (Inspection Procedure (IP) 69003)

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, the inspector reviewed selected aspects of the licensees program, including:

  • Operator Requalification Program - University of Missouri Research Reactor (MURR), dated January 7, 1997
  • 2 Year Physical & License Expiration Schedule
  • Annual On-The-Job [OJT] Checklist - OJT Progress Report 2017
  • Requalification Examinations, dated October 17, 18, and November 10, 2017
  • Written Examination Forms, for 2016 and 2017 documenting the facility-administered biennial exam completed by each operator
  • MURR Control Room Logbooks Nos. 363 and 364 from 2017-2018 b. Observations and Findings There were a total of 10 licensed senior reactor operators (SROs) and 11 licensed ROs on staff at the facility. Records and logbooks showed that operators were maintaining active duty status as required. A review of records also showed that training (including emergency procedures) was being conducted in accordance with the approved requalification and training program.

Procedure reviews had been completed and documented as required.

Records of the completion of quarterly reactor operations, reactivity manipulations, other operations activities, and Reactor Supervisor activities were being maintained. Records indicating the completion of annual operating tests and supervisory observations were also being maintained. Biennial written examinations were being taken by the operators. The inspector noted that the portion of the requalification program requiring removing an operator from licensed duties and remediation following not meeting a program requirement was being effectively implemented.

The inspector also noted that all operators were receiving the biennial medical examinations required by 10 CFR Part 55.

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c. Conclusion Operator requalification was being completed and maintained up-to-date as required by the Operator Requalification Program. Medical examinations were completed biennially for each operator as required.

2. Organization and Operations and Maintenance Activities a. Inspection Scope (IP 69006)

To verify compliance with the licensees TS requirements, the inspector reviewed selected aspects of the licensees organization, operations, and preventative maintenance program, including:

  • Research Reactor Center, Year 2018 Organization Chart, dated July 19, 2018
  • Technical Specifications for the University of Missouri Research Reactor, Facility Operating License No. R-103, Docket No. 50-186, dated January 4, 2017
  • MURR 2017 Reactor Operations Annual Report for the period from January 1, 2017 through December 31, 2017
  • MURR Control Room Logbooks Nos. 363, 364, 365, 366 from 2017-2018
  • Completed FM-43, Nuclear and Process Data, from January 2018-September 2018
  • Select procedures and forms from MURR Operations Procedures Manual, including:

o OP-RO-461, Pool Coolant Operation - 1 Coolant Pump, Revision 18 o OP-RO-410, Primary Coolant, Revision 16 o AP-RO-130, Crane Operation o FM-27, Long Form Startup Checklist, Revision 29

  • Maintenance Day Book 2018
  • Corrective Action Program (CAP) Overview List, dated October 16, 2018
  • Select records, CAP detail report
  • Work List Maintenance Shutdown List
  • Plan of the Week, October 15-21, 2018
  • Maintenance Day Book 2018
  • Select records, RO-PM PM Lists
  • Electronics Shop - 2017 Monthly Machinery History Report for Drive C
  • Work Package #18-5563, 1S4 Shim Switch Replacement
  • Select Preventative Maintenance Procedures, including:

o A1-A3 Room 114, 125 psig Air Relief Valve, VOP-36 o A1-A3 Post Maintenance Valve Line-up Checklist o A1-A4 Main Air System Cyclone Separator Relief Valve, A-10 o A1-A4 Post Maintenance Valve Line-up Checklist-5-

b. Observations and Findings (1) Organization and Staffing The inspector reviewed the organizational structure at the facility and found that it remained unchanged since the last inspection. The inspector noted that a new MURR Reactor Facility Director (Level 2) was selected and the licensee submitted a report of this effective change immediately on June 15, 2018, as required by TS 6.6.d.(2). The inspector reviewed the qualifications of the staff and found that they satisfied TS 6.1.g.

The subject of facility staffing was reviewed by the inspector. Through a review of selected reactor operation logs for periods in 2017-2018, through interviews with operations personnel, and observation of operating shifts, the inspector determined that the licensee operates with rotating crews. Each operating crew was staffed with two or three licensed individuals. Several crews were also staffed with an operator trainee. Operations shifts consisted of a 12-hour period. The inspector verified that staffing during reactor operations consisted of two facility staff personnel (1 SRO/RO, 1 knowledgeable individual) in accordance with TS 6.1.c.

(2) Operations and Maintenance The inspector observed facility activities on various occasions during the week including a reactor shutdown, reactor refueling, tagout, routine reactor operations, and the handling of samples and sample manipulating tools. Written procedures and checklists were used for each activity as required. The inspector noted operational staff were knowledgeable, adhered to procedures and professional in the conduct of their duties.

During the inspection, the inspector attended both a morning and evening operations crew shift turnover meeting. These turnover briefings were held at 6:30 a.m. and 6:30 p.m. each day. The status of the reactor and the facility were discussed on each occasion as required. All operators of the relief crews reviewed the appropriate logs and records and were briefed on the upcoming shift activities and scheduled events before assuming the operations duty. Through direct observation and records review, the inspector verified that the content of shift turnover briefings held during each shift change was appropriate and noted that shift activities and plant conditions were discussed in detail.

The inspector reviewed the licensees CAP, which had been developed to provide staff members with a formal process to identify deficiencies and bring safety issues, as well as other issues of concern, to managements attention for resolution. When issues were identified, each one was screened for safety significance, evaluated to determine the cause and its contributing factors, and assigned to a responsible manager for resolution. Corrective actions were developed and implemented consistent with the significance of the issue and according to an established schedule. Based on a review of a sample of CAP-6-

documents, the inspector found that the licensee had taken corrective actions as necessary or had assigned a responsible manager to take the needed actions.

The inspector attended the weekly maintenance meeting where maintenance activities are discussed and coordinated each week. The inspector also attended the Plan of the Week meeting where activities across MURR for the following week are collected from various groups and presented. The inspector reviewed the work control program, which was organized through the computer program known as Maximo. The program was designed to ensure that all maintenance activities (including periodic surveillance activities), were screened, planned, and completed as scheduled; that post maintenance testing was conducted; and, that the entire process was documented appropriately.

c. Conclusion The licensees organization and staffing were in compliance with the TS requirements. MURR reactor operations were conducted in accordance with procedure and the appropriate logs were being maintained. The work control program established and implemented by the licensee was being used to effectively complete maintenance activities at the facility in a timely manner.

3. Review and Audit and Design Change Functions a. Inspection Scope (IP 69007)

To verify compliance with (1) the licensees TS requirements for the conduct of reviews and audits; and, (2) 10 CFR 50.59, Changes, tests, and experiments, the inspector reviewed selected aspects of the licensees program, including:

  • Technical Specifications for the University of Missouri Research Reactor, Facility Operating License No. R-103, Docket No. 50-186, dated January 4, 2017
  • MURR 2017 Reactor Operations Annual Report for the period from January 1, 2017 through December 31, 2017
  • Committee/subcommittee charters and meeting minutes from October 2017-September 2018, including: RAC; Reactor Safety Subcommittee; Reactor Safety Procedure Review Subcommittee; Isotope Use Subcommittee; Isotope Use Procedure Review Subcommittee; and Reactor Action Subcommittee
  • Memo to file, Documentation of the Annual Audit of Facility Operations for Calendar Year 2017 as required by Technical Specification 6.2.e.(1)(i), dated February 5, 2018
  • Missouri University of Science and Technology, 2017 Independent Audit of MURR, dated December 14, 2017
  • Memo to file, Documentation of the Annual Audit of Operator Requalification Program for Calendar Year 2017 as required by Section 3.1 of the program, dated February 5, 2018
  • Memo from Simek to Meffert, University of Missouri Research Reactor-7-

(MURR) Requalification Program Audit 2017, dated January 4, 2018

  • Memo to file, Documentation of the Annual Audit of Corrective Action Items Associated with Reactor Safety for Calendar Year 2017 as required by Technical Specification 6.2.e.(1)iii, dated February 5, 2018
  • Memo from Gibson to Meffert, Emergency Plan and Procedures Annual Audit, dated January 8, 2018.
  • Agenda and associated documents, Reactor Safety Procedure Review Committee meeting, dated October 18, 2018.
  • Select procedures from MURR Operations Procedures Manual, including:

o AP-RO-115, Modification Records, Revision 12.

o AP-RR-003, 50.59 Screen b. Observations and Findings (1) Review and Audit Functions The inspector reviewed the charters and meeting minutes of the RAC and subcommittees. Composition of the RAC was as specified in TS 6.2.a.

Meeting minutes demonstrated that the committee (or subcommittees)

met as required by TS 6.2.b, and provided the reviews as specified in TS 6.2.a. Topics of the reviews were as required by TS and provided sufficient independent oversight to ensure safe operations of the reactor, planned research activities, and facility.

The inspector reviewed the 2017 audits pertaining to Facility Operations, Operator Requalification Program, Corrective Action items, and Emergency Plan. The audits appeared to be adequate. No problems were noted and two suggestions for improvements to procedures were recommended.

The inspector attended a meeting of the Reactor Safety Procedure Review subcommittee. The subcommittee reviewed compliance procedures, deviations from procedures, standing orders, administrative form, operations form, operator aid, and operations procedure.

TS 6.2.a.(2) requires review from the RAC, or designated subcommittee, for changes and modifications. Additionally, the inspector examined a sample of the past subcommittee meeting minutes and found reviews being completed as required.

(2) Design Change Function To satisfy the regulatory requirements stipulated in 10 CFR 50.59, the licensee has an established design change review function implemented through MURR procedures AP-RR-003 and AP-RO-115. The procedures address changes to the safety analysis report (SAR), modifications to the facility, changes to MURR procedures, new tests or experiments not described in the SAR, revisions to NRC approved analysis methodology,

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and/or proposed compensatory actions to address degraded or non-conforming conditions. In accordance with 10 CFR 50.59, MURR procedures include the screening and safety review of changes, tests, or experiments to determine if a change required the NRC approval prior to being implemented. The inspector found procedures in place to control the review process and evidence of adherence to the procedures.

c. Conclusion The RAC was meeting quarterly, reviewing the topics outlined in the TS, and conducting annual audits of facility operations as required. The facility design change program satisfied NRC requirements.

4. Procedures a. Inspection Scope (IP 69008)

To verify compliance with the licensees TS requirements for procedures, the inspector reviewed selected aspects of the licensees program, including:

  • Technical Specifications for the University of Missouri Research Reactor, Facility Operating License No. R-103, Docket No. 50-186, dated January 4, 2017.
  • FM-5, Document Revisions and Annual Review
  • FM-18, Deviation from Procedure Report, Revision 10
  • Status of FM-5 review for operations procedures
  • List of procedures, revisions, revision date, and committee review.

b. Observations and Findings The inspector reviewed the facility procedures and the processes to review, approve, change, and deviate from procedures. The inspector noted that facility procedures had been developed for the operation of the reactor and emergency planning as required by TS 6.4.a. The procedures were approved and annually reviewed by the Reactor Manager as required by TS 6.4.c. The licensee implemented MURR FM-18 to document deviations from procedures as required by TS 6.4.d.

c. Conclusion The current procedure review, revision, control, and implementation program satisfied TS requirements.

5. Fuel Movement a. Inspection Scope (IP 69009)

To verify compliance with the licensees TS requirements for the MURR fuel, the inspector reviewed selected aspects of the licensees program, including:

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  • Technical Specifications for the University of Missouri Research Reactor, Facility Operating License No. R-103, Docket No. 50-186, dated January 4, 2017
  • MURR Control Room Logbooks Nos. 363, 364, 365, 366 from 2017-2018
  • Completed FM-43, Nuclear and Process Data from January 2018-September 2018
  • OP-RO-250, In-Pool Fuel Handling, Revision 20
  • FM-08, Fuel Movement Sheet, Revision 9
  • Fuel Location Map b. Observations and Findings The inspector reviewed the fuel movement process used by the licensee and verified that fuel was moved according to established procedures and in conjunction with the selected fuel movement sheets. They were prepared by the Assistant Reactor Manager - Physics for core refueling, partial core refueling, fuel storage rearrangement, loading of spent fuel into a shipping container, performing end-of-life inspections of fuel elements, and transferring new unirradiated fuel from storage to the pool. Inspections were carried out on one of every eight-fuel elements that reached end-of-life as required by TS 4.1.d.

Additionally, primary coolant chemistry was continuously monitored and routinely sampled to detect the possibility of a fuel element failure, as required by TS 3.3.b.(1), TS 3.3.c, and TS 3.3.d. Therefore, the reactor was not operated with fuel in which anomalies were detected, as required by TS 3.1.d.

During the inspection, the inspector also observed fuel movement for reactor refueling. An SRO was present during the fuel movement as required by TS 6.1.f.(2). Reactor containment integrity was maintained as required by TS 3.4.b.(2). Review of the fuel movement sheets indicated that the licensee was following the approved procedural process. The inspector verified that fuel-handling tools were being properly maintained and were adequately controlled/secured when not in use.

The inspector compared the current location of selected fuel elements in the reactor core (as illustrated by a printed core configuration or map) with the information maintained on the fuel status boards in the Control Room and on the fuel movement sheets. Fuel was being used and stored in the required and approved locations.

c. Conclusion Fuel movements and inspections were conducted in accordance with TS and procedural requirements.

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6. Surveillance a. Inspection Scope (IP 69010)

To verify compliance with the licensees TS requirements for surveillances, the inspector reviewed selected aspects of the licensees program, including:

  • MURR Control Room Logbooks Nos. 363, 364, 365, 366 during the period 2017-2018
  • MURR Reactor Operations Annual Report for the period from January 1, 2016 through December 31, 2016
  • OP-RO-420, Primary and Pool Water Analysis
  • OP-RO-531, Primary and Pool Sample Station
  • Select completed CP-42 and associated Nuclide Activity Summary results for the period October 2017-September 2018
  • CP-43, Pool Water Analysis
  • Select completed CP-43 and associated Nuclide Activity Summary results for the period October 2017-September 2018
  • Primary coolant sample results for trending, Spreadsheet
  • Primary coolant sample results for trending - tritium, Graph b. Observations and Findings Routine maintenance and surveillance activities, including: verifications, calibrations, and testing of various reactor systems, instrumentation, auxiliary systems, and security systems and alarms, were typically completed during routine shutdowns for reactor refueling. The inspector reviewed select CPs, completed CPs, associated data sheets, and reactor console logbooks. The records indicated that the required tests, checks, verifications, and calibrations had been completed on schedule and in accordance with licensee procedures.

The results reviewed by the inspector were found to be within the TS and procedurally prescribed parameters.

c. Conclusion Surveillance activities at the facility were completed within the TS-prescribed time frames.

7. Emergency Preparedness a. Inspection Scope (IP 69011)

To verify compliance with Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, and the licensees NRC-approved operator requalification program, the inspector reviewed selected aspects of the licensees program, including:

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  • MOU, City of Columbia Fire Department, dated September 7, 2016
  • MURR Emergency Procedures Manual
  • Emergency Equipment Maintenance, EP-RO-20 Attachment 2.1
  • MURR Emergency Call List
  • MURR Annual On-Site Emergency Drill, June 11, 2018
  • MURR Annual On-Site Emergency Drill, May 8, 2017
  • Operator Requalification Program - University of Missouri Research Reactor (MURR), dated January 7, 1997
  • Memo from Gibson to Meffert, Emergency Plan and Procedures Annual Audit, dated January 8, 2018.
  • Memo from Hudson to Meffert, completion of required annual EP required training for 2017, dated January 3, 2018.
  • [Facility Emergency Organization (FEO)] Emergency Plan/Procedures Review 2017
  • Emergency Drill Review Presentation 2017
  • FEO Training 2017
  • University of Missouri Health Care, Health Emergency Management -

Focused Event - Decontamination Response - Plan, dated 1/24/16.

  • Various procedures, University of Missouri Health Radiation Emergency Assignment
  • University of Missouri Health General [Personal Protective Equipment (PPE)]

Donning/Doffing Checkoff Sheets b. Observations and Findings (1) Emergency Plan and Implementing Procedures The inspector reviewed the E-Plan in use at the facility. The inspector verified that the latest update on February 1, 2018, was made in accordance with the requirements of 10 CFR 50.54(q). In the transmittal letter, the licensee stated changes to the E-Plan did not reduce the effectiveness of the plan. The inspector notes that the plan, as revised, continues to meet the requirements in Appendix E to 10 CFR Part 50.

The inspector reviewed the E-Plan implementing procedures in use at the facility and verified updates were made using the MURR procedure review, revision, control, and implementation program. As discussed above, the E-Plan was reviewed and audited annually, which meets the requirement to be audited at least biennially by TS 6.2.e.(1).iv.

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(2) Emergency Equipment and Inventories The inspector verified that emergency equipment lockers were properly maintained and inventoried on a quarterly basis as required. Emergency call lists had been revised and updated as needed and were available in the control room, the front lobby, and in the various controlled copies of MURR emergency procedures manuals as required.

(3) Offsite Support The inspector, accompanied by the Reactor Manager, visited the University of Missouri Hospital and Clinics and met with the University of Missouri Health Safety and Emergency Preparedness Coordinator. The inspector toured the hospital spaces described in the E-Plan.

Discussions included ambulance response; decontamination room, activities, and equipment; and, hospital equipment, staffing, training, and response. The hospital also participates in emergency drills with the Federal Emergency Management Agency, Missouri State Emergency Management Agency, and Callaway Nuclear Power Plant.

(4) Drills The inspector reviewed documentation of the drills conducted during the past 2 years. Through record reviews and personnel interviews, emergency responders were determined to be knowledgeable of the proper actions to take in case of an emergency. Emergency drills had been conducted annually and included the participation of off-site support groups every other year, as required. The scenarios written for the drills and critiques held were well documented.

(5) Training Through records review, the inspector determined that emergency training for operators was completed and tracked through the operator requalification program. Emergency preparedness and response training for emergency support organizations was completed biennially, as required.

c. Conclusion The emergency preparedness program was conducted in accordance with the E-Plan. Emergency response equipment was being maintained as required.

The MOU between the licensee and various support agencies were being maintained. Emergency drills were being conducted annually as required by the E-Plan. Emergency preparedness training for personnel was being conducted.

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8. Event Follow-up a. Inspection Scope (IP 69006)

To verify compliance with the licensees TS requirements for reporting, the inspector reviewed selected aspects of the following:

  • Letter from the licensee to the NRC regarding a deviation from TS 3.4.b, dated January 12, 2018
  • Letter from the licensee to the NRC regarding a deviation from TS 3.6.a, dated March 15, 2018
  • Letter from the licensee to the NRC regarding a deviation from TS 3.2.a, dated June 11, 2018 b. Observations and Findings The inspector reviewed the licensees actions taken in response to three separate, self-identified deviations from TS 3.4.b, TS 3.6.a, and TS 3.2.a.

(1) TS 3.4.b deviation TS 1.26 states that Reactor Secured is when, in addition to other conditions, the Master Control Switch is in the OFF position with the key locked in the key box or in the custody of a licensed operator. TS 1.23 further defines Reactor in Operation as any condition wherein the reactor is not shutdown or secured. TS 3.4.a states that reactor containment integrity exists when, in addition to other conditions, reactor containment building is at a negative pressure (i.e. vacuum) of at least 0.25 inches of water with respect to surrounding areas. TS 3.4.b requires reactor containment integrity to be maintained when, in addition to other times, the reactor is in operation (i.e., not secured). Contrary to the above, on December 30, 2017, the reactor containment building differential pressure gauge was observed reading 0.0 inches of water vacuum while the reactor was operating.

After the reactor was secured, Reactor Operations management was notified. Mechanical and electrical portions of the containment system were tested. The cause was subsequently determined to be the formation of ice in the compressed air supply piping to ventilation plenum door air cylinders. Compressed air lines were heated to melt the ice and the water was drained from the system. The Interim Reactor Facility Director gave permission to start the reactor, as required by TS 6.6.c.(4).

The licensee subsequently notified the NRCs Headquarters Operations Officer (HOO) at about 1:16 p.m. on January 2, 2018, and submitted a letter detailing the event dated January 12, 2018.

Various corrective actions were initiated. Electric heat trace and insulation was applied to the lines as a short-term action to prevent freezing of any future moisture in the piping. Additionally, the Reactor Operations staff drains the compressed air supply piping every week to remove any accumulated condensation. Long-term actions include:

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1) installation of a continuous pressure indication and low differential pressure alarm in the Control Room; and, 2) installation of equipment to improve overall compressed air quality (e.g. desiccant, air dryer). The inspector reviewed the actions taken and verified that the licensee had completed all of the short-term corrective actions. The licensee was in the process of installing the continuous pressure indication and awaiting implementation of a system to improve overall compressed air quality.

The corrective action to improve overall compressed air quality is pending action and awaiting installation by another department at the University.

The event had been entered into the MURR corrective action program as CAP #17-0149.

The licensee was informed that the resolution of this deviation and the corrective actions to monitoring containment building differential pressure and implement a system to improve the overall compressed air quality would be tracked by the NRC as an inspector follow-up item (IFI) and would be reviewed during a future inspection (IFI 05000186/2018-202-02).

(2) TS 3.6.a deviation TS 1.15 states that a component or system is Operable when that component or system is capable of performing its intended function.

TS 1.23 defines Reactor in Operation as any condition wherein the reactor is not shutdown or secured. TS 3.6.a states that the reactor shall not be operated unless the emergency electrical power system is operable. Contrary to the above, on March 4, 2018, the Emergency Power Generator (EPG) was inadvertently switched out of automatic control for approximately 10 to 15 seconds.

The cause was determined to be the Reactor Operations Trainee (ROT)

inadvertently switching the EPG out of automatic control while attempting to obtain and record weekly EPG run hours. The lead SRO responded to the related alarm sounding in the Control Room and verified the EPG was correctly lined up for automatic control ensuring emergency electrical power system operability. Later, another RO conducted the EPG preoperational checklist. The Interim Reactor Facility Director gave permission to return to normal reactor operations, as required by TS 6.6.c.(4). The licensee subsequently notified the NRCs HOO at about 1:14 p.m. on March 5, 2018, and submitted a letter detailing the event dated March 15, 2018.

Various corrective actions were initiated. Training was provided to the ROT on the EPG and human performance error prevention tools. EPG run hours will be obtained weekly while performing the reactor pre-startup checklist when the reactor is not operating.

The inspector discussed the self-reported TS deviation with the licensee and interviewed various reactor staff personnel. The circumstances of the event and the notifications were reviewed.

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The licensee was informed that the issue of inoperability of the emergency electrical power system while the reactor was in operation was a Severity Level IV violation of TS 3.6.a. However, the potential safety consequence was low because the emergency electrical power system is not required to safely shutdown the reactor, maintain an acceptable shutdown condition, or protect the integrity of the fuel elements. As indicated above, the inspector determined that the problem had been identified and reviewed by the licensee and reported to the NRC as required. The event had been entered into the MURR corrective action program as CAP #18-0017. Corrective actions had been identified and had been completed as well. As a result, the licensee was informed that this non-repetitive, licensee-identified and corrected violation would be treated as a NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05000186/2018-202-03). This issue is considered closed.

(3) TS 3.2.a deviation TS 1.15 states that a component or system is Operable when that component or system is capable of performing its intended function.

TS 1.23 defines Reactor in Operation as any condition wherein the reactor is not shutdown or secured. TS 3.2.a states that all control blades, including the regulating blade, shall be operable during reactor operation. TS 4.2.a requires verification of control blade operability once each shift. Contrary to the above, on May 30, 2018, the control blades would not shim in the inward direction while performing the surveillance to verify operability.

After the reactor was shutdown and secured, the cause was determined to be failure of contact 1 on Control Rod Operate Switch 1S4. This contact supplies power for inward motion of all four (4) shim control placed. The switch was replaced and retested satisfactorily. The Interim Reactor Facility Director gave permission to start the reactor, as required by TS 6.6.c.(4). The licensee subsequently notified the NRCs HOO at about 8:54 a.m. on May 31, 2018, and submitted a letter detailing the event dated June 11, 2018.

The inspector discussed the self-reported TS deviation with the licensee and interviewed various reactor staff personnel. The circumstances of the event and the notifications were reviewed.

The licensee was informed that the issue of inoperability of the shim control blades while the reactor was in operation was a Severity Level IV violation of TS 3.2.a. However, the potential safety consequence was low because the initiation of a manual scram was able to safely shutdown the reactor. As indicated above, the inspector determined that the problem had been identified and reviewed by the licensee and reported to the NRC as required. The event had been entered into the MURR corrective action program as CAP #18-0053. The corrective action had been identified and had been completed as well. As a result, the licensee was informed that this non-repetitive, licensee-identified and corrected

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violation would be treated as a NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05000186/2018-202-04). This issue is considered closed.

c. Conclusion Two NCVs were reviewed and are considered closed. One IFI was opened.

9. Exit Interview The inspection scope and results were reviewed with the licensee on October 18, 2018.

The inspector discussed the findings for each area reviewed. The licensee acknowledged the findings.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel J. Custer Assistant Reactor Manager - Engineering R. Dobey Interim Manager, Health Physics & Safety Manager J. Ernst Senior Advisor L. Foyto Associate Director, Reactor & Facilities Operations R. Hudson SRO, Reactor Training J. Kroeckel Lead SRO K. Kutikkad Assistant Reactor Manager - Physics J. Matyas Access Control Coordinator B. Meffert Reactor Manager S. McCall Lead SRO C. Reams Manager, Document Control & Records Management S. Schaefer Assistant Reactor Manager C. Schnieders Health Physics Supervisor Other Personnel P. Van Hunnik Safety and Emergency Preparedness Coordinator, University of Missouri Health INSPECTION PROCEDURES USED IP 69003 Class I Research and Test Reactor Operator Licenses, Requalification, and Medical Examinations IP 69006 Class I Research and Test Reactor 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 69010 Class I Research and Test Reactor Surveillance IP 69011 Class I Research and Test Reactor Emergency Preparedness ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000186/2018-202-01 IFI Follow-up on installation of system or components to monitor containment building differential pressure and improve quality of compressed air.

05000186/2018-202-02 NCV Failure to comply with TS 3.6.a which requires the emergency electrical power system to be operable during reactor operation.

Attachment

05000186/2018-202-03 NCV Failure to comply with TS 3.2.a which requires all control blades to be operable during reactor operation.

Closed 05000186/2018-202-02 NCV Failure to comply with TS 3.6.a which requires the emergency electrical power system to be operable during reactor operation.

05000186/2018-202-03 NCV Failure to comply with TS 3.2.a which requires all control blades to be operable during reactor operation.

LIST OF ACRONYMS USED CAP Corrective Action Program CP Compliance Procedure E-Plan Emergency Plan EPG Emergency Power Generator HOO Headquarters Operations Officer IFI Inspector Follow-Up Item IP Inspection Procedure MURR University of Missouri-Columbia Research Reactor NCV Non-Cited Violation OJT On-The-Job NRC U.S. Nuclear Regulatory Commission RAC Reactor Advisory Committee RO Reactor Operator ROT Reactor Operator Trainee SAR Safety Analysis Report SRO Senior Reactor Operator TS Technical Specification-2-

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