IR 05000186/2019202
| ML19340B199 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 12/11/2019 |
| From: | Anthony Mendiola NRC/NRR/DANU/UNPO |
| To: | Robertson D Univ of Missouri - Columbia |
| Schuster W, NRR/DANU/UNPO, 301-415-1590 | |
| References | |
| IR 2019202 | |
| Download: ML19340B199 (21) | |
Text
December 11, 2019
SUBJECT:
UNIVERSITY OF MISSOURI-COLUMBIA - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000186/2019-202
Dear Dr. Robertson:
From November 4-7, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted a routine announced safety inspection at the University of Missouri-Columbia Research Reactor facility. The inspection included a review of activities authorized for your facility. The enclosed report presents the results of that inspection.
During the inspection, the NRC staff examined activities conducted under your license as they relate to public health and safety to ensure compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has determined that three 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 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. 50-186 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 Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115
- concurred via e-mail NRC-002 OFFICE NRR/DANU/UNPO/RI*
NRR/DANU/UNPO/LA*
NRR/DANU/UNPO/BC NAME WSchuster NParker AMendiola DATE 12/10/19 12/10/19 12/11/19
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.
50-186
License No.
R-103
Report No.
Licensee:
The Curators of the University of Missouri
Facility:
University of Missouri-Columbia Research Reactor
Location:
Columbia, Missouri
Dates:
November 4-7, 2019
Inspector:
Accompanied by:
Geoffrey Wertz, Project Manager
Approved by:
Anthony J. Mendiola, 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
- 2 -
EXECUTIVE SUMMARY
University of Missouri-Columbia University of Missouri Research Reactor Inspection Report No. 05000186/2019-202
The primary focus of this routine, announced safety inspection included the onsite review of selected aspects of the University of Missouri-Columbia Research Reactor (MURR) facility 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.
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.
Organization and Operations and Maintenance Activities
- Organization and staffing were in compliance with the technical specification (TS)
requirements.
- Operations were conducted in accordance with procedures, appropriate logs were being maintained, and the work control program was being used for timely and effective completion of maintenance activities.
Review and Audit and Design Change Functions
- Review, audit, and oversight functions required by the TS were acceptably completed.
- Changes to the facility were being evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests and experiments, and were reviewed and approved when required.
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.
- 3 -
- The emergency preparedness program was conducted in accordance with the emergency plan (E-Plan).
- 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.
- Emergency preparedness training for personnel was being conducted.
Event Follow-up
- Three Severity Level IV non-cited violations (NCVs) were reviewed and are considered closed. One inspector follow-up item (IFI) was opened.
- 4 -
REPORT DETAILS
Summary of Facility Status
The University of Missouri-Columbia continued to operate the 10-megawatt research reactor in support of isotope production, irradiation services, research, education, and training.
1.
Operator Licenses, Requalification, and Medical Examinations
a.
Inspection Scope (Inspection Procedure (IP) 69003)
To verify compliance with 10 CFR Part 55, Operators Licenses, and the licensees U.S. Nuclear Regulatory Commission (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
AP-RO-105, MURR Operator Requalification Process, Revision 1
Current Two-Year Physical & License Expiration Schedule
Current Annual On-The-Job Training [OJT] Checklist - OJT Progress Report 2019
Current Crew Review Report per Requalification Plan Section 2.5
Select records, AP-RO-105, Attachment 9.1, On-The-Job Training Requirements/Checklist, for 2019
Select records, Written Examination Forms, for 2019
b.
Observations and Findings
The inspector reviewed requalification records for the 11 licensed senior reactor operators (SRO) and 11 licensed reactor operators (RO) at the facility. The inspector determined that all operators have performed the operator functions each calendar quarter, participated in a requalification program, and completed a biennial medical examination as required by 10 CFR 55.53, Conditions of licenses. At the time of this inspection, requalification program activities for 2019 were still in progress. Requalification program schedule, lectures, on-the-job training, evaluation, and records were consistent with the requirements in 10 CFR 55.59, Requalification. Lectures covered topics required by 10 CFR 55.59(c)(2). During the inspection, the inspector observed a required lecture for requalification on radiation instrumentation. The inspector noted the instructor was knowledgeable, engaged attendees, and presented training materials that were of appropriate depth and detail for the topic.
Licensed operators conducted manipulations required by 10 CFR 55.59(c)(3)(i).
Licensed operators passed comprehensive written examinations and operating tests as required by 10 CFR 55.59(c)(4). Inspector verified that written examinations consisted of a representative sample from the items listed in 10 CFR 55.41, Written examination: Operators.
- 5 -
c.
Conclusion
Operator requalification was being completed and maintained up-to-date as required by the Operator Requalification Program.
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:
- Technical Specifications for The University of Missouri Research Reactor, Facility Operating License No. R-103. Docket No. 50-186
University of Missouri-Columbia Research Reactor, Reactor Operations Annual Report, January 1, 2018, through December 31, 2018
Research Reactor Center, Year 2019 Organization Chart, dated July 1, 2019
MURR Control Room Logbooks from 2018-2019
Current Plan of the Week
Current Work List for Maintenance Shutdown
Work Package #19-9726, DCT Pump
Radiation Work Permit #19-158, DCT Pump
Current Form (FM)-23 MURR Tagout Index Record
Select records, FM-24, MURR Tagout Sheet
FM-25, MURR Tagout Monthly Audit, for 2019
Corrective Action Program (CAP) Overview List, dated October 31, 2019
Select records, CAP Monthly Summary, from November 2018-October 2019
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 subject of facility staffing was reviewed by the inspector. Through a review of selected reactor operation logs for periods in 2018-2019 and observation of operating shifts, the inspector determined that the licensee operates with rotating crews, staffed with two to four licensed individuals. Several crews were also staffed with an operator trainee. Operations shift 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
During the inspection, the inspector observed activities on various occasions during the week, including maintenance day activities and routine reactor operations. The inspector observed a portion of ongoing maintenance activities related to the DCT pump, conducted using an approved work
- 6 -
package. The inspector noted that all staff performing work were signed into the radiation work permit and wearing the appropriate personal protective equipment and dosimetry, as required. Written procedures and checklists were used for other activities, when required. The inspector attended an evening operations crew shift turnover meeting. Turnover briefings are 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. 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 appropriately detailed. The inspector noted operational staff were knowledgeable, adhered to procedures, and professional in the conduct of their duties.
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. During the inspection, the inspector observed a meeting of the CAP committee. The inspector noted that the meeting appeared to be an effective mechanism to discuss new issues, ongoing issues or issues of interest, assess the effectiveness of corrective actions, and close out issues after they have been addressed.
Based on a review of a sample of CAP documents, the inspector found that the licensee has a process to identify and record issues and corrective actions, when necessary.
The inspector reviewed the work control process and noted maintenance activities (including periodic surveillance activities) were: 1) screened, planned, and completed as scheduled; 2) that post maintenance testing was conducted; and, 3) that the entire process was documented, as required.
c.
Conclusion
Organization and staffing were in compliance with the TS requirements.
Operations were conducted in accordance with procedures, appropriate logs were being maintained, and the work control program was being used for timely and effective completion of maintenance activities.
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, the inspector reviewed selected aspects of the licensees program, including:
- 7 -
- Technical Specifications for The University of Missouri Research Reactor, Facility Operating License No. R-103. Docket No. 50-186
University of Missouri-Columbia Research Reactor, Reactor Operations Annual Report, January 1, 2018, through December 31, 2018
Committee/subcommittee meeting minutes from December 2018 through October 2019, including: Reactor Advisory Committee (RAC); Reactor Safety Subcommittee; Reactor Safety Procedure Review Subcommittee; and Isotope Use Subcommittee
50.59 Screens, for 2018 and 2019
Modification Record 88-07, Addendum 4, Addition of Charcoal Filters and Dehumidifier to HC-11 Exhaust
Modification Record 95-01, Replacement of Nuclear Instruments
Modification Record 96-02, Installation of Power Motion Inc. Rod Position Indication System
b.
Observations and Findings
(1)
Review and Audit Functions
The inspector reviewed the 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. Based on records review and interviews, the inspector verified the 2018 audits pertaining to Facility Operations, Operator Requalification Program, Corrective Action items, and E-Plan were completed as required by TS 6.2.e(1)i-iv.
(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, and/or proposed compensatory actions to address degraded or non-conforming conditions. It includes the screening and safety review of changes, tests, or experiments to determine if, pursuant to 10 CFR 50.59, 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.
- 8 -
c.
Conclusion
Review, audit, and oversight functions required by the TS were acceptably completed. Changes to the facility were being evaluated using the criteria specified in 10 CFR 50.59, and were reviewed and approved when required.
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
University of Missouri-Columbia Research Reactor, Reactor Operations Annual Report, January 1, 2018, through December 31, 2018
FM-5, Document Revisions and Annual Review
Status of completed FM-5 review for operations procedures
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, as required by TS 6.4.a. All operation procedures were approved and annually reviewed by the Reactor Manager as required by TS 6.4.c.
c.
Conclusion
The 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:
- Technical Specifications for The University of Missouri Research Reactor, Facility Operating License No. R-103. Docket No. 50-186
MURR Control Room Logbooks from 2018-2019
Completed FM-08, Fuel Movement Sheet, for Core 19-01 through 19-47
Fuel Location Maps, for Core 19-01 through 19-47
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
- 9 -
conjunction with the selected fuel movement sheets. Fuel movement sheets were specifically prepared for each 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. 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. The inspector determined that 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.
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:
- Technical Specifications for The University of Missouri Research Reactor, Facility Operating License No. R-103, Docket No. 50-186
MURR Control Room Logbooks from 2018-2019
University of Missouri-Columbia Research Reactor, Reactor Operations Annual Report, January 1, 2018, through December 31, 2018
Select records, completed Compliance Check Procedures (CP) for 2019
Select records from Maintenance Day binder for 2019
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 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.
- 10 -
7.
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 E-Plan, the inspector reviewed selected aspects of the licensees program, including:
- Technical Specifications for The University of Missouri Research Reactor, Amendment No. 38, dated December 19, 2018
Emergency Plan, University of Missouri Research Reactor, Revision 20, dated January 3, 2019
Letter from Office of City Manager, RE: City of Columbia Fire Department Response, dated December 19, 2018
Select Emergency Procedures (EPs)
EP-RO-020, Attachment 2.1, Emergency Locker Inventory
Current FM-104, MURR Emergency Call List
MURR Annual On-Site Emergency Drill 2019
Presentation, Emergency Preparedness Drill, All-Staff Review, 2019
Select records, AP-RO-105, Attachment 9.1, for 2019
Presentation, University of Missouri Research Reactor, 2019 Annual Training for Non-[Facility Emergency Organization (FEO)]
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 January 3, 2019, was made in accordance with the requirements of 10 CFR 50.54(q). The inspector notes that the E-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.
(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 EPs manuals as required.
(3)
Offsite Support
The inspector, accompanied by the Reactor Manager, visited the Columbia Fire Department and met with the Assistant Fire Marshall. The inspector toured the nearest fire station and discussed equipment,
- 11 -
capabilities, staffing, training, and response. The fire department provides routine response to the facility and participates in larger emergency planning drills organized by MURR.
(4)
Drills
Through record reviews, the inspector determined that emergency drills had been conducted annually and included the participation of off-site support groups, 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.
8.
Follow-up
a.
Inspection Scope (IP 69006, IP 92701)
The inspector reviewed licensee-submitted reports and associated documentation, including:
- Letter from the licensee to the NRC regarding a deviation from TS 3.4.b, dated January 12, 2018 (Licensee Event Report (LER) 17-06)
Letter from the licensee to the NRC regarding a deviation from TS 3.3.a(1),
dated January 31, 2019 (LER 19-01)
Letter from the licensee to the NRC regarding a deviation from TS 3.2.a, dated February 1, 2019 (LER 19-02)
Letter from the licensee to the NRC regarding a deviation from TS 3.2.a, dated May 10, 2019 (LER 19-03)
Letter from the licensee to the NRC regarding a deviation from TS 3.4.b, dated July 12, 2019 (LER 19-04)
Letter from the licensee to the NRC regarding a deviation from TS 3.2.a, dated August 7, 2019 (LER 19-05)
- 12 -
b.
Observations and Findings
The inspector reviewed the licensees actions taken in response to self-identified deviations from TS 3.4.b, TS 3.3.a(1), and TS 3.2.a.
(1) TS 3.4.b deviations
Example 1 - LER 17-06. TS 1.26 states that Reactor Secured is when, in addition to other conditions, [t]he 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, Reactor in Operation, states that [t]he reactor shall be considered in operation unless it is either 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 (in. H2O) 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 TS 3.4.b, on December 30, 2017, the reactor containment building differential pressure gauge was observed reading zero (0) in. H2O vacuum while the reactor was operating. The cause was subsequently determined to be the formation of ice in the compressed air supply piping to ventilation plenum door air cylinders. Short term corrective actions included:
1) application of electric heat trace and insulation to the air lines to prevent freezing of any future moisture in the piping; and, 2) Reactor Operations staff draining the compressed air supply piping every week to remove any accumulated condensation. Long-term actions included: 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 event was entered into the MURR CAP as CAP 17-0149. The inspector reviewed the actions taken, verified that the licensee had completed all of the corrective actions, and that the corrective actions appear to be sufficient to prevent recurrence. The IFI tracking the completion of the corrective actions (IFI 05000186/2018-202-01)
is considered closed.
Example 2 - LER 19-04. TS 1.26 states that Reactor Secured is when, in addition to other conditions, there is no work in progress involving the shim blades (rods) or shim rod drive mechanisms. TS 3.4.b requires reactor containment integrity to be maintained when, in addition to other times, no work is in progress involving the shim rod drive mechanisms. Contrary to TS 3.4.b, on January 27, 2019, the reactor containment building automatically-closing doors were inoperable while scheduled maintenance was occurring on two shim control rod drive mechanisms. The cause was subsequently determined to be due to electrical breakers for the automatically-closing doors being opened during unscheduled electrical preventative maintenance. Corrective actions consist of improvements to training on work authorization, procedural compliance, and TS-required system equipment identification. The event was entered into the MURR CAP as CAP 19-0097. The inspector reviewed the actions taken, verified that the licensee had completed all the corrective actions, and that the corrective actions appear to be sufficient to prevent recurrence. The licensee was
- 13 -
informed that the implementation of enhanced work control training would be tracked by the NRC as an IFI and would be reviewed during a future inspection (05000186/2019-202-01).
The licensee was informed that the failure to maintain reactor containment integrity while the reactor was in operation was a Severity Level IV violation of TS 3.2.a. As indicated above, the inspector determined that the problem had been identified by the licensee, reported to the NRC, and entered into the CAP. Corrective actions had been identified and had been completed as well. As a result, the licensee was informed that these non-willful, non-repetitive, licensee-identified, and licensee-corrected deviations would be treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (05000186/2019-202-02). These issues are considered closed.
(2) TS 3.3.a(1) deviation
LER 19-01. 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, Reactor in Operation, states that [t]he reactor shall be considered in operation unless it is either shutdown or secured. TS 1.27, Reactor Shutdown, states, in relevant part, that the reactor is shutdown when power is unavailable to the shim rod drive mechanism electromagnets. TS 1.17, Operational Modes states that [t]he reactor may be operated in any of three (3) operating modes, depending upon the configuration of the reactor coolant systems and the protective system set points. TS 3.3.a(1) states, in part, that the reactor shall not be operated in Modes I or II unless the anti-siphon system is operable. Contrary to TS 3.3.a(1), the anti-siphon system was not operable when the reactor was considered in operation after power was provided to the shim rod drive mechanism electromagnets. The cause was determined to be due to the presence of installed electrical test jumpers during the performance of a reactor pre-start checklist. Corrective actions included: 1) changes to a temporary procedure/standing order supplementing the normal primary coolant system startup procedure; and, 2)
changes to the Long Form Startup Checksheet (FM-57) to ensure electrical test jumpers are removed. The event was placed into the MURR CAP as CAP 19-0010. The inspector reviewed the actions taken, verified that the licensee had completed all the corrective actions, and that the corrective actions appear to be sufficient to prevent recurrence.
The licensee was informed that the failure to maintain the anti-siphon system operable while the reactor was in operation was a Severity Level IV violation of TS 3.3.a(1). As indicated above, the inspector determined that the problem had been identified by the licensee, reported to the NRC, and entered into the CAP. Corrective actions had been identified and had been completed as well. As a result, the licensee was informed that this non-willful, non-repetitive, licensee-identified, and licensee-corrected deviation would be treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (05000186/2019-202-03). This issue is considered closed.
- 14 -
(3) TS 3.2.a deviations
Example 1 - LER 19-02. 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, Reactor in Operation, states that [t]he reactor shall be considered in operation unless it is either 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 TS 3.2.a, shim control blade A would not shim in the inward direction while performing the surveillance to verify operability. 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. Corrective actions included:
1) replace and retest switch 1S4; and, 2) send failed switch 1S4 to the manufacturer for testing. Subsequent troubleshooting by the licensee revealed that the cause of switch 1S4 contact 1 failure was different from LER 18-02 (spring force vs contact alignment). The licensee took additional steps to prevent recurrence by following the change process to replace switch 1S4 with a similar switch considered for heavy duty use under Work Package # 19-1943. The event was placed into the MURR CAP as CAP 19-0013. The inspector reviewed the actions taken, verified that the licensee had completed all the corrective actions, and that the corrective actions appear to be sufficient to prevent recurrence.
Example 2 - LER 19-03. 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, Reactor in Operation, states that [t]he reactor shall be considered in operation unless it is either shutdown or secured.
TS 3.2.a states that [a]ll 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 TS 3.2.a, shim control blade D would not shim in the inward direction while performing the surveillance to verify operability. The cause was determined to be a broken wire to the inward direction control rod drive motor (CRDM) winding of shim control blade D, which would have also prevented shim control blade D from inserting due to a rod run-in condition. Corrective actions included: 1)
replace broken wire and retest shim control blade D CRDM; 2)
refurbishment of all CDRM motor relay sockets and wiring, to include relay retaining brackets and protective wiring bundle sheaths/brackets. The event was placed into the MURR CAP as CAP #19-0057. The inspector reviewed the actions taken, verified that the licensee had completed all the corrective actions, and that the corrective actions appear to be sufficient to prevent recurrence.
Example 3 - LER 19-05. 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, Reactor in Operation, states that [t]he reactor shall be considered in operation unless it is either shutdown or secured.
TS 3.2.a states that [a]ll control blades, including the regulating blade, shall be operable during reactor operation. Contrary to TS 3.2.a, the regulating blade would not move in the outward direction when the reactor was
- 15 -
operating. The cause was determined to be the drive chain for the rod position indication encoder disengaging, which prevented the regulating blade from moving in the outward direction. Corrective actions included: 1)
replace drive chain and verify alignment and tension; 2) tighten idler sprocket shaft connections; and 3) retest by cycling across full range of travel. The inspector also notes that the licensee has initiated the change process to redesign the regulating blade drive mechanism in order to eliminate current design weaknesses and prevent recurring issues. The inspector reviewed the corrective actions taken, verified that the licensee had completed all the corrective actions, and that the corrective actions appear to be sufficient to prevent recurrence.
The licensee was informed that the failure to maintain the shim control blades, including the regulating blade, operable while the reactor was in operation was a Severity Level IV violation of TS 3.2.a. As indicated above, the inspector determined that the problem had been identified by the licensee, reported to the NRC, and entered into the CAP. Corrective actions had been identified and had been completed as well. As a result, the licensee was informed that these non-willful, non-repetitive, licensee-identified and licensee-corrected deviations would be treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (05000186/2019-202-04). These issues are considered closed.
c.
Conclusion
Three Severity Level IV 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 November 7, 2019.
The inspector discussed the findings for each area reviewed. The licensee acknowledged the findings.
Attachment 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, MU 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 IP 97201 Followup
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000186/2019-202-01 IFI Follow-up on implementation of enhanced work control training
05000186/2019-202-02 NCV Failure to maintain reactor containment integrity (TS 3.4.b)
05000186/2019-202-03 NCV Failure to maintain anti-siphon system operable (TS 3.3.a(1))
05000186/2019-202-04 NCV Failure to maintain shim control blades operable (TS 3.2.a)
- 2 -
Closed
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.
05000186/2019-202-02 NCV Failure to maintain reactor containment integrity (TS 3.4.b)
05000186/2019-202-03 NCV Failure to maintain anti-siphon system operable (TS 3.3.a(1))
05000186/2019-202-04 NCV Failure to maintain shim control blades operable (TS 3.2.a)
LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations CAP Corrective Action Program CP Compliance Procedure CRDM Control Rod Drive Motor EP Emergency Procedure E-Plan Emergency Plan IFI Inspector Follow-Up Item IP Inspection Procedure LER
Licensee Event Report MOU Memoranda of Understanding MURR University of Missouri-Columbia Research Reactor NCV Non-Cited Violation OJT On-The-Job Training NRC U.S. Nuclear Regulatory Commission RAC Reactor Advisory Committee RO Reactor Operator SAR Safety Analysis Report SRO Senior Reactor Operator TS Technical Specification