IR 05000186/2023202
| ML23297A072 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 12/12/2023 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Sanford M Curators of the University of Missouri |
| References | |
| IR 2023202 | |
| Download: ML23297A072 (14) | |
Text
SUBJECT:
THE CURATORS OF THE UNIVERSITY OF MISSOURI - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000186/2023202
Dear Mr. Sanford:
From September 25-28, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Missouri University Research Reactor facility. The enclosed report presents the results of that inspection, which were discussed on September 28, 2023, with you and members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed various activities, and interviewed personnel.
Based on the results of this inspection, the NRC has determined that two Severity Level IV violations of NRC requirements occurred. These violations are being treated as non-cited violations (NCVs), consistent with section 2.3.2 of the Enforcement Policy. These NCVs are described in the subject inspection report. If you contest the violations or significance of these 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 Publicly Available Records component of the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
December 12, 2023 If you have any questions concerning this inspection, please contact Andrew Waugh at (301) 415-0230, or by email at Andrew.Waugh@nrc.gov.
Sincerely, Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-186 License No. R-103 Enclosure:
As stated cc w/enclosure: GovDelivery Subscribers Signed by Tate, Travis on 12/12/23
ML23297A072 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME AWaugh NStaples NParker TTate DATE 10/25/2023 11/15/2023 11/16/2023 12/12/2023
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.:
50-186 License No.:
R-103 Report No:
05000186/2023202 Licensee:
The Curators of the University of Missouri Facility:
Missouri University Research Reactor Location:
Columbia, Missouri Dates:
September 25-28, 2023 Inspectors:
Andrew Waugh Necota L. Staples Approved by:
Travis L. Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
- 2 -
EXECUTIVE SUMMARY The Curators of the University of Missouri Missouri University Research Reactor Inspection Report No. 05000186/2023202 The primary focus of this routine announced inspection was the onsite review of selected aspects of the Missouri University Research Reactor (MURR) facility safety program, including:
(1) operator licenses, requalification, and medical examinations; (2) experiments; (3) organization and operations and maintenance activities; (4) procedures; (5) fuel movement; and (6) surveillance. The U.S. Nuclear Regulatory Commission (NRC) staff determined that the licensees program was acceptably directed toward the protection of public health and safety, and in compliance with NRC requirements, except where noted below.
Operator Licenses, Requalification, and Medical Examinations
The inspectors determined that the operator requalification program was conducted and completed in accordance with the NRC approved program and regulatory requirements.
Experiments
The inspectors determined that experiments were reviewed, approved, and conducted in accordance technical specifications (TSs), procedural, and regulatory requirements.
Organization and Operations and Maintenance Activities
The inspectors determined that contrary to TS 6.1.f, there were three instances between November 1, 2022, and December 26, 2022, where the minimum staffing requirement was not met. See section 3 of the report details below.
- With the exception noted above, the inspectors determined that the organization and staffing were in compliance with the TS requirements. The inspectors also determined that operational and maintenance activities were performed and documented in accordance with procedures and TS requirements.
Procedures
The inspectors determined that procedures were reviewed and approved, controlled, maintained current, and implemented in compliance with TS and license requirements.
Fuel Movement
The inspectors determined that fuel was inspected, handled, and maintained in accordance with TS and the licensees procedural requirements.
- 3 -
Surveillance
The inspectors determined that contrary to TS 3.2.b, the reactor was operated above 100 kilowatts with shim blades differing by greater than one inch. See section 6 of the report details below.
- With the exception noted above, the inspectors determined that surveillances were conducted and limiting conditions for operation (LCO) were maintained in accordance with TS requirements.
- 4 -
REPORT DETAILS Summary of Facility Status MURR continued to operate in support of isotope production, reactor operator training, and various types of research. During the inspection, the reactor resumed operation 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)
The inspectors reviewed the following aspects of the licensees requalification program to verify compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators Licenses, and the licensees NRC-approved operator requalification program:
"Operator Requalification Program, MURR," dated January 7, 1997
MURR Procedure, AP-RO-105, MURR Operator Requalification Process, dated May 9, 2023
various reports and logs documenting operators completion of licensed activities
results of the 2022 annual operating test records for licensed operators
NRC Form 396, Certification of Medical Examination by Facility Licensee, for select licensed operators
medical exam records for select licensed operators
select console log entries, dated 2022-present b.
Observations and Findings The inspectors found that the licensees training was conducted and documented in accordance with their NRC-approved requalification and training program, and that medical exams were conducted in accordance with 10CFR Part 55. The inspectors also found that the license operators requalification training and medical records were maintained as required by the NRC-approved requalification and training program.
c.
Conclusion The inspectors determined that the operator requalification program was conducted and completed in accordance with the NRC approved program and regulatory requirements.
2.
Experiments a.
Inspection Scope (IP 69005)
The inspectors observed the performance of irradiation experiments and reviewed the following to ensure that experiments were reviewed and conducted as required by TS 3.8 and 6.5:
MURR Procedure, AP-RO-135, "Reactor Utilization Requests (RUR)" dated December 28, 2021
- 5 -
MURR Procedure, RP-RO-201, "Measurement of Reactivity worth of Flux Trap Loadings or Individual Samples, RTP-17(b)" dated September 2, 2021
MURR Procedure, RP-RO-202, "Measurement of Reactivity Worth of Moveable Samples, RTP-6," dated May 9, 2023
select RUR, experimental run sheets, and MURR online ordering system entries, dated 2022-present
select Reactor Safety Subcommittee meeting minutes, dated 2022-present
2022 annual operating report b.
Observations and Findings The inspectors found that new and amended experiments were reviewed and approved as required by TS 6.5 and 10 CFR 50.59, Changes, tests and experiments. The inspectors also found that experiments were conducted in accordance with the licensees procedures and TS 3.8.
c.
Conclusion The inspectors determined that experiments were reviewed, approved, and conducted in accordance TS, procedural, and regulatory requirements.
3.
Organization and Operations and Maintenance Activities a.
Inspection Scope (IP 69006)
The inspectors observed various reactor operations, reactor parameters, a tag out removal, and reviewed the following regarding the licensees organization, operations, and maintenance activities to ensure compliance with the requirements of TS:
select console log entries, dated 2022-present
MURR notifications to the NRC of staff changes, dated November 9, 2022, and August 1, 2023
2022 annual operating report
select operations monthly summary reports, dated 2022-present
select unscheduled/unplanned power reduction reports, dated 2022-present
MURR Procedure, AP-RR-015, "Work Control Procedure," dated February 18, 2021
MURR Procedure, GS-RA-100, "MURR Equipment Tag Out," dated December 28, 2021
MURR Procedure, AP-RO-110, "Conduct of Operations," dated May 19, 2021
MURR Licensee Event Report 23-01, dated January 13, 2023
NRC Event Notification 56296 b.
Observations and Findings (1) Organization and Staffing The inspectors found that the licensees organization was consistent with that specified in the TS, and that the NRC was made aware of the personnel changes in accordance with TS 6.6.
- 6 -
The inspectors found the minimum shift staffing for reactor operations continued to meet the TS requirement except as noted below.
While conducting an inspection follow-up of an issue reported in Event Notification 56296, the inspectors determined that a violation of TS 6.1.f occurred and is being assessed in this inspection. Specifically, TS 6.1.f states, in part, that a senior reactor operator (SRO) must be present at the facility for initial startup and approach to power, and relocation of any experiment with a reactivity worth greater than 0.0074 units.
Contrary to the above, on January 3, 2023, the licensee determined that there were three instances between November 1, 2022, and December 26, 2022, where this staffing requirement was not met. The licensee determined that the SRO in the three instances had a license which expired on September 22, 2022. The licensee had submitted a license renewal request to the NRC however it was not submitted 30 days prior to the license expiring in accordance with 10 CFR 55.55, Expiration. The licensee did not recognize the license expired on September 22, 2022, since the renewal request was not submitted in accordance with the timeliness requirements and allowed the SRO to continue to perform licensed duties.
While reviewing the license renewal application on January 3, 2023, the NRC notified licensee that the SRO license was expired and could not be renewed. The licensee immediately pulled the individual from licensed operator duties. The licensee also reviewed all operating logs dating back to September 22, 2022, and determined that there were three shifts which the individual was in the control room supervising evolutions which required an SRO to be present per TS 6.1.f. Operation logs for those shifts were reviewed and revealed no abnormal trends or occurrences. As corrective actions, the licensee conducted training and changed their internal procedure for submitting license renewals so that renewals would be submitted at least 30 days prior to license expiration moving forward.
The failure to meet the staffing requirements of TS 6.1.f is a Severity Level IV violation in accordance with the NRC Enforcement Policy section 6.1.d. The NRC staff determined the safety consequences of the event were low because the individual had 18 years of experience as an SRO at MURR, performed all requalification activities, was subsequently able to obtain an SRO license, and the issue was due to an administrative oversight in the timing of the renewal application.
This issue was reported to the NRC in Event Notification 56296. This issue is being treated as a non-cited violation (NCV), consistent with section 2.3.2.b of the NRC Enforcement Policy (NCV 05000186/2023202-01). The inspectors determined the licensee has implemented appropriate corrective actions and this issue is closed.
(2) Operations and Maintenance The inspectors observed various reactor operations and found that measured parameters were consistent with those required by TS and operations were controlled consistent with TS requirements. The inspectors also found that the scheduled and unscheduled preventive and corrective maintenance activities were performed and documented in accordance with TS requirements and the licensees administrative procedures.
- 7 -
c.
Conclusion The inspectors determined that contrary to TS 6.1.f, there were three instances between November 1, 2022, and December 26, 2022, where the minimum staffing requirement was not met.
With the exception noted above, the inspectors determined that the organization and staffing were in compliance with the TS requirements. The inspectors also determined that operational and maintenance activities were performed and documented in accordance with procedures and TS requirements.
4.
Procedures a.
Inspection Scope (IP 69008)
The inspectors reviewed various procedures and observed their implementation, including fuel movement, fuel shipment, and select experiments. The inspectors also reviewed the following regarding the licensees procedures to ensure that the requirements of the licensees administrative procedures and TS 6.4 were met:
2022 annual operating report
select safety procedure subcommittee meeting minutes, dated 2022-present
MURR Procedure, BC1-Q1, Containment Doors Gasket Inspection, dated January 19, 2023
MURR Procedure, A1-S1, Check Nitrogen Supply System Low Pressure Alarm Set Point, dated March 6, 2023
MURR Procedure A3-M1, Test Sample Alarms, dated January 9, 2023
MURR Procedure, CP-47, Auto Control Prohibit Channel Calibration, dated May 18, 2023
MURR Procedure, CP-3, Pool Low Level Scram (LC-966) dated March 6, 2023
MURR Procedure, CP-5, PT-917 - 10 MW, dated March 1, 2023
MURR Procedure, CP-6, Building Evacuation/Isolation Scram Building High Activity Scram, dated February 28, 2023 b.
Observations and Findings The inspectors observed that the licensee maintained written procedures covering the areas specified in TS 6.4 and included a summary of procedure changes in their annual reports as required by TS 6.6.e. The inspectors found that the procedures in use by the licensee were current, reviewed and approved as required by TS 6.4, able to be implemented as intended, and adhered to by reactor personnel.
c.
Conclusion The inspectors determined that procedures were controlled, maintained current, implemented, and followed in compliance with TS and license requirements.
- 8 -
5.
Fuel Movement a.
Inspection Scope (IP 69009)
The inspectors observed fuel movement operations, the preparation of a fuel shipment, and reviewed the following fuel handling logs and activities to verify compliance with TS requirements:
MURR Procedure, OP-RO-250, In-Pool Fuel Handling, February 6, 2023
MURR Procedure, RP-RO-100, "Fuel Movement," October 27, 2021
MURR Procedure, FB-SH-110, "Type B Shipment of Spent Fuel Using the BEA Research Reactor Package," dated May 20, 2022
select fuel movement sheets, for cores 22-48 through 23-48
select fuel location maps, for cores 22-48 through 23-48
select fuel element inspection records, dated 2022-present b.
Observations and Findings The inspectors found that the licensees fuel handling procedures were adequate to perform their intended functions and that fuel was moved and inspected consistent with TS requirements and the licensees administrative procedures. The inspectors also found that the licensee verified TS limits were met before resuming normal operations after fuel movements.
c.
Conclusion The inspectors determined that fuel was inspected, handled, and maintained in accordance with TS and the licensees procedural requirements.
6.
Surveillance a.
Inspection Scope (IP 69010)
The inspector reviewed the following to verify compliance with TS 3 and to determine if surveillance tests were performed as required by TS 4:
various completed compliance procedures and associated records, dated 2022-present
select console log entries, dated 2022-present
2022 annual operating report
MURR Licensee Event Report 23-03, dated June 6, 2023
NRC Event Notification 56534 b.
Observations and Findings The inspectors found that surveillance tests were completed as required by the TS and LCO verifications were completed on schedule and in accordance with the licensees procedures except as noted below.
- 9 -
While conducting an inspection follow-up of an issue reported in Event Notification 56534, the inspectors determined that a violation of TS 3.2.b occurred and is being assessed in this inspection. Specifically, TS 3.2.b states, Above 100 kilowatts, the reactor shall be operated so that the maximum distance between the highest and lowest shim blade shall not exceed one inch.
On May 23, 2023, the licensee conducted a reactor startup following a short duration shutdown. Contrary to the above, the licensee determined the reactor was operated for less than one minute above 100 kilowatts with control blade A 1.4 inches lower than the other three banked control blades. As part of the startup, three control blades were at 23 inches and the fourth control blade was pulled to the bank height as power was approaching 100 kilowatts. The reactor operator stopped shimming out on control blade A and shimmed in the other three rods individually to stop the power rise and get the control rods within 1 inch of each other prior to power reaching 100 kilowatts. The operators then continued the startup to full power (10 megawatts). Following the startup, the SRO raised a concern that power may have briefly spiked above 100 kilowatts while control blades exceeded a 1 inch difference in height. Strip chart recordings were reviewed by the licensee and determined that power spiked at 103.5 kilowatts for less than a minute while control blade A was 1.4 inches below the other three control blades which is greater than the TS limit of 1 inch.
TS 3.2.b provides a restriction to the maximum neutron flux tilting that can occur in the core to ensure the validity of the power peaking factors described in section 4.5 of the licensees safety analysis report. The licensee provided analysis to the NRC which determined that control blades could have up to a 4 inch difference with power greater than 100 kilowatts with no adverse effects to the peaking factors as analyzed in the safety analysis report. As corrective actions the licensee conducted training on this issue to prevent recurrence.
The failure to meet the requirements of TS 3.2.b is a Severity Level IV violation in accordance with the NRC Enforcement Policy section 6.1.d. The inspectors determined the safety consequences of the event were low due to the lack of neutron flux tilting that occurs when control blades differ by 1.4 inches and the short duration of the condition.
This issue was identified by the licensee and reported to the NRC on May 23, 2023, in Event Notification 56534. This issue is being treated as an NCV, consistent with section 2.3.2.b of the NRC Enforcement Policy (NCV 05000186/2023202-02). The inspectors determined the licensee has implemented appropriate corrective actions and this issue is closed.
c.
Conclusion The inspectors determined that contrary to TS 3.2.b, the reactor was operated above 100 kilowatts with shim blades differing by greater than one inch.
With the exception noted above, the inspectors determined that surveillances were conducted and limiting conditions for operation (LCO) were maintained in accordance with TS requirements.
- 10 -
7.
Exit Interview The inspection scope and results were summarized on September 28, 2023, with members of licensee management and staff. The inspectors described the areas inspected and discussed the inspection results. The licensee acknowledged the results of the inspection.
Attachment PARTIAL LIST OF PERSONS CONTACTED Licensee Reactor Facility Director R. Astrino Reactor Manager R. Hudson Reactor Training Manager C. Braun Assistant Reactor Manager of Engineering R. Gibson Assistant Reactor Manager of Operations D. Doenges Health Physics & Safety Manager L. Simek Senior Reactor Operator R. Fjell Senior Reactor Operator T. Gibson Senior Reactor Operator C. Welch Senior Reactor Operator INSPECTION PROCEDURES USED IP 69003 Class I Research and Test Reactors Operator Licenses, Requalification, and Medical Examinations IP 69005 Class I Research and Test Reactor Experiments IP 69006 Class I Research and Test Reactors Organization and Operations and Maintenance Activities 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 ITEMS OPENED, CLOSED, AND DISCUSSED Opened:
NCV 05000186/2023202-01 Violation of technical specification (TS) 6.1.f, by failing to meet the minimum staffing requirements.
NCV 05000186/2023202-02 Violation of TS 3.2.b, by operating for a brief time above 100 kilowatts with control rods differing by greater than 1 inch.
Closed:
NCV 05000186/2023202-01 Violation of TS 6.1.f, by failing to meet the minimum staffing requirements.
NCV 05000186/2023202-02 Violation of TS 3.2.b, by operating for a brief time above 100 kilowatts with control rods differing by greater than one inch.