IR 05000297/2024202
| ML24254A306 | |
| Person / Time | |
|---|---|
| Site: | North Carolina State University |
| Issue date: | 09/16/2024 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Hawari A North Carolina State University |
| References | |
| IR 2024202 | |
| Download: ML24254A306 (1) | |
Text
SUBJECT:
NORTH CAROLINA STATE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000297/2024202 AND NOTICE OF VIOLATION
Dear Dr. Hawari:
From August 12-15, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the North Carolina State University PULSTAR Nuclear Research Reactor. The enclosed report presents the inspection results, which were discussed on August 15, 2024, 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 inspectors reviewed selected procedures and records, observed various activities, and interviewed personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements has occurred. The violation was evaluated in accordance with the NRC Enforcement Police. The current enforcement policy is included on the NRCs website at (https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the notice because it constitutes a failure to meet regulatory requirements that has more than minor safety significance and the licensee failed to identify the violation.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
September 16, 2024 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 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 https://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the Public without redaction.
If you have any questions concerning this inspection, please contact Andrew Waugh at (301) 415-0230, or by email to 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. 50-297 License No. R-120 Enclosure:
As stated cc: w/enclosure: GovDelivery Subscribers Signed by Tate, Travis on 09/16/24
ML24254A306 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME AWaugh NParker TTate DATE 09/11/2024 09/11/2024 09/16/2024
NOTICE OF VIOLATION
North Carolina State University Docket No. 50-297 PULSTAR Nuclear Research Reactor License No. R-120
During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from August 12-15, 2024, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
North Carolina State University (NCSU) PULSTAR reactor technical specifications (TS)
section 6.4, Operating Procedures, item g., states, written procedures shall be prepared, reviewed and approved prior to initiating any of the following: Implementation of the Emergency Plan and Security Plan.
Contrary to TS section 6.4.g, NCSUs emergency procedures did not contain necessary information to ensure that emergencies involving the reactor could be classified in accordance with the requirements of the emergency plan. Specifically, the emergency action level criteria listed in the emergency plan concerning the airborne effluent concentration with ventilation in normal mode with fan R-63 running were missing from emergency procedure 4 for Notification of Unusual Event and Alert. This ventilation lineup was also missing from emergency procedure 10 which is used to calculate the airborne effluent releases to determine if an emergency action level was reached.
The failure to meet the procedural requirements of TS section 6.4.g is a Severity Level IV violation in accordance with the NRC Enforcement Policy section 6.6.d. The NRC staff determined the safety consequences of the event were low since no actual emergency involving these emergency action level criteria occurred. The inspectors identified the violation so this issue will be treated as a Notice of Violation (NOV) (NOV 05000297/2024202-1), consistent with section 2.3.3 of the NRC Enforcement Policy.
This is a Severity Level IV violation (Section 6.6).
Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR)
Section 2.201, Notice of violation, NCSU is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation, and should include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Enclosure 1 Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.
In accordance with 10 CFR 19.11, Posting of notices to workers, you may be required to post this Notice within two working days of receipt.
Dated this: 16th day of September 2024
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.: 50-297
License No.: R-120
Report No.: 05000297/2024202
Licensee: North Carolina State University
Facility: PULSTAR Nuclear Research Reactor
Location: Raleigh, NC
Dates: August 12-15, 2024
Inspectors: Andrew Waugh Jared Nadel (RTR Inspector in Training)
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
Enclosure 2 EXECUTIVE SUMMARY
North Carolina State University PULSTAR Nuclear Research Reactor Inspection Report No. 05000297/2024202
The primary focus of this routine announced inspection was the onsite review of selected aspects of the North Carolina State Universitys (NCSU, the licensees) Class II research reactor facility safety program, including: (1) organization and staffing; (2) operations logs and records; (3) requalification training; (4) surveillance and limiting conditions for operation (LCO);
(5) emergency planning; (6) maintenance logs and records; and (7) fuel handling logs and records. 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.
Organization and Staffing
- The inspectors determined that the organization and staffing were in compliance with the technical specification (TS) requirements.
Operations Logs and Records
- The inspectors determined that the operations logs and records were maintained in accordance with the applicable TS and the licensees procedural requirements.
Requalification Training
- The inspectors determined that the operator requalification program was conducted and completed in accordance with the NRC-approved program and regulatory requirements.
Surveillance and Limiting Conditions for Operation
- The inspectors determined that contrary to TS 3.4.a the licensee operated with reactor power greater than 500 kilowatts (kW) with the nitrogen (N)-16 power measuring channel inoperable.
- With the exception noted above, the inspectors determined that surveillances were conducted and LCO were maintained in accordance with TS requirements.
Emergency Planning
- The inspectors determined that contrary to TS section 6.4.g, NCSUs emergency procedures did not contain necessary information to ensure that emergencies involving the reactor could be classified in accordance with the requirements of the emergency plan.
- With the exception noted above, the inspectors determined that the emergency preparedness program was conducted in accordance with the emergency plan.
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Maintenance Logs and Records
- The inspectors determined that the maintenance activities were performed and documented in accordance with TS requirements.
Fuel Handling Logs and Records
- The inspectors determined that the fuel movements and inspections were conducted in accordance with TS and the licensees procedural requirements.
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REPORT DETAILS
Summary of Facility Status
The NCSU 1,000 kW PULSTAR nuclear research reactor continued to be operated in support of graduate and undergraduate research and laboratory instruction, service irradiations, reactor operator training, and periodic surveillance. During the inspection, the reactor was started up, operated, and shut down to support these ongoing activities.
1. Organization and Staffing
a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)
The inspectors reviewed the following regarding the licensees organization and staffing to ensure that the requirements of TS 6.1 and 6.7.2 were met:
- SP 2.2, "Reactor Operator Assistant Qualification," dated January 13, 2005
- memo to the NRC concerning management change dated August 1, 2023
- select reactor logbook entries, dated 2022-present
b. Observations and Findings
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 requirements.
The inspectors found the minimum shift staffing for reactor operations continued to meet the TS requirement.
c. Conclusion
The inspectors determined that the organization and staffing were in compliance with the TS requirements.
2. Operations Logs and Records
a. Inspection Scope (IP 69001, Section 02.02)
The inspectors observed completion of a reactor startup checklist, reactor startup, reactor operations, reactor shutdown, and neutron radiography experiments. The inspectors also reviewed the following to ensure that logs and records were maintained as required by the licensees administrative procedures and TS 6.8:
- 2022 and 2023 annual operating reports
- select reactor logbook entries, dated 2022-present
- operating procedure (OP) 101, "Reactor Startup and Shutdown," dated December 6, 2022
- OP 103, "Reactor Operation," dated July 26, 2021
- select operating parameter logs, dated 2022-present
- select startup checklists, dated 2022-present
- unscheduled SCRAM and shutdown log, 2022-present
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b. Observations and Findings
The inspectors found that the licensees operation logs and records were maintained as required by the licensees TS and administrative procedures.
The inspectors observed that the measured parameters for several reactor operations met the TS requirements.
c. Conclusion
The inspectors determined that the operations logs and records were maintained in accordance with the applicable TS and the licensees procedural requirements.
3. Requalification Training
a. Inspection Scope (IP 69001, Section 02.04)
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:
- Reactor Operator Training and Requalification Plan, dated November 1, 2018
- select medical records, dated 2022-present
- select requalification records, dated 2022-present
- select lecture attendance records, 2022-present
- select requalification exams, 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, medical examinations were completed every 2 years, and that the license operators requalification training and medical records were maintained.
c. Conclusion
The inspectors determined that the operator requalification program was conducted and completed in accordance with the NRC approved program and regulatory requirements.
4. Surveillance and Limiting Conditions for Operation
a. Inspection Scope (IP 69001, Section 02.05)
The inspectors observed completion of a reactor startup checklist, reactor startup, reactor operations, reactor shutdown, and neutron radiography experiments. The inspectors also reviewed the following to verify compliance with TS 3.0 and to determine if surveillance tests were performed as required by TS 4.0:
- select reactor logbook entries, dated 2022-present
- select operating parameter logs, dated 2022-present
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- special procedure (SP) 2.5, "PULSTAR Reactor Surveillance," dated February 1, 1989
- PULSTAR surveillance procedure (PS)-8-3-1, "Core Flux Mapping," dated November 1, 2014
- select excess reactivity and shutdown margin calculation datasheets, dated 2022-present
- calibration records for the reactor bay with respect to atmosphere pressure gauge, dated 2022-present
- select rod worth and drive time data, dated 2022-present
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.
While conducting an inspection follow-up of an issue reported by the licensee to the NRC Operations Center on June 27, 2024, in Event Notification No. (EN) 57196, the inspectors determined that a violation (VIO) of TS 3.4.a occurred and is assessed in this inspection. Specifically, TS 3.4.a states, The reactor shall not be operated unless the following are operable: N-16 Power Measuring Channel when reactor power is greater than 500 kW.
Contrary to the above, the licensee operated at 950 kW on June 27, 2024, with the N-16 power measuring channel inoperable. During steady state operations at 950 kW on June 27, 2024, the reactor operator observed a discrepancy in power indications. The linear and safety power level channels were reading 950 kW while the N-16 power measuring channel indicated approximately 100 kW. The reactor operator shutdown the reactor and informed the senior reactor operator. The reactor staff performed multiple surveillances and evaluations of the N-16 channel components and replaced parts as necessary prior to resuming normal operations.
The N-16 channel was inoperable for approximately three minutes before the reactor was shutdown. All other power monitoring channels were operable during that time. The N-16 channel does not have any scram capabilities, but the other power monitoring channels do. The power level of the reactor stayed within the licensed limits throughout this event. Because of the above, the NRC staff determined the failure to meet the operational requirements of TS 3.4.a constitutes a VIO of minor significance in accordance with section 2 of the Enforcement Policy. This minor VIO (VIO 05000297/2024202-2) was corrected by the licensee and this issue is closed.
c. Conclusion
The inspectors determined that contrary to TS 3.4.a the licensee operated with reactor power greater than 500 kW with the N-16 power measuring channel inoperable.
With the exception noted above, the inspectors determined that surveillances were conducted and LCO were maintained in accordance with TS requirements.
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5. Emergency Planning
a. Inspection Scope (IP 69001, Section 02.10)
The inspectors toured the NCSU operations center and the alternate emergency support center. The inspectors also reviewed the following selected portions of the licensees emergency preparedness program 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 emergency plan:
- "PULSTAR Reactor Emergency Plan," dated March 29, 2017
- emergency procedure (EP) 1, revision 23
- EP 2, revision 24
- EP 4, revision 7
- EP 10, revision 6
- emergency locker inventory forms, 2022-present
- emergency drill records, 2022-present
- select emergency preparedness training records, 2022-present
- select off-site agreements, 2022-present
b. Observations and Findings
The inspectors found that the emergency plan training was conducted, drills were performed, emergency response call lists were maintained and posted, and emergency equipment was maintained and available as required by the emergency plan and licensee procedures.
NCSU PULSTAR reactor TS section 6.4, Operating Procedures, item g., states, that written procedures shall be prepared, reviewed and approved prior to initiating any of the following implementation of the Emergency Plan and Security Plan.
Contrary to TS section 6.4.g, NCSUs emergency procedures did not contain necessary information to ensure that emergencies involving the reactor could be classified in accordance with the requirements of the emergency plan. Specifically, the emergency action level criteria listed in the emergency plan concerning the airborne effluent concentration (AEC) with ventilation in normal mode with fan R-63 running were missing from emergency procedure 4 for Notification of Unusual Event and Alert. Specifically, for a Notification of Unusual Event these concentrations are 45,000 and 90,000 AEC fraction for noble gases and for radionuclides other than noble gases, respectively, and 225,000 and 450,000 AEC fraction for an Alert. This ventilation lineup was also missing from emergency procedure 10 which is used to calculate the airborne effluent releases to determine if an emergency action level was reached.
The failure to meet the procedural requirements of TS section 6.4.g is a Severity Level IV violation in accordance with the NRC Enforcement Policy section 6.6.d. The NRC staff determined the safety consequences of the event were low since no actual emergency involving these emergency action level criteria occurred. The inspectors identified the violation so this issue will be treated as a Notice of Violation (NOV) (NOV 05000297/2024202-1), consistent with section 2.3.3 of the NRC Enforcement Policy.
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c. Conclusion
The inspectors determined that contrary to TS section 6.4.g, NCSUs emergency procedures did not contain necessary information to ensure that emergencies involving the reactor could be classified in accordance with the requirements of the emergency plan.
With the exception noted above, the inspectors determined that the emergency preparedness program was conducted in accordance with the emergency plan.
6. Maintenance Logs and Records
a. Inspection Scope (IP 69001, Section 02.11)
The inspectors reviewed the following selected maintenance logs and records to verify compliance with the requirements of TS:
- 2022 and 2023 annual operating reports
- select reactor logbook entries, dated 2022-present
- unscheduled SCRAM and shutdown log, 2022-present
- reactor safety and audit committee meeting minutes 2022-present
b. Observations and Findings
The inspectors 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.
c. Conclusion
The inspectors determined that the maintenance activities were performed and documented in accordance with TS requirements.
7. Fuel Handling Logs and Records
a. Inspection Scope (IP 69001, Section 02.12)
The inspectors reviewed the following fuel handling logs and activities to very compliance with TS requirements:
- OP 301, Reactor Fuel Handling, dated November 1, 2014
- PS 4-7:B1, "Fuel Inspection," dated June 1, 2015
- select reactor logbook entries, dated 2022-present
- select fuel handling records, 2022-present
- fuel inspection records, 2022-present
b. Observations and Findings
The inspectors found that the fuel handling activities were conducted and documented in accordance with TS requirements and the licensees procedural requirements.
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c. Conclusion
The inspectors determined that the fuel movements and inspections were conducted in accordance with TS and the licensees procedural requirements.
8. Exit Interview
The inspection scope and results were summarized on August 15, 2024, with members of licensee management and staff. The inspectors described the areas inspected and discussed the inspection results.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel Director, Nuclear Reactor Program A. Wells Manager of Engineering and Operations A. Deak Reactor Health Physicist Z. Boulton Senior Reactor Operator C. Fleming Senior Research Scholar T. Kay Reactor Operator K. Williamson Reactor Operator
INSPECTION PROCEDURES USED
IP 69001 Class II Non-Power Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NOV 05000297/2024202-1 Contrary to technical specifications (TS) section 6.4, the licensees emergency procedures did not contain necessary information to ensure that emergencies involving the reactor could be classified in accordance with the requirements of the emergency plan.
VIO 05000297/2024202-2 Contrary to TS 3.4.a the licensee operated above 500 kilowatt (kW)
with the nitrogen (N)-16 power measuring channel inoperable on June 27, 2024.
Closed
VIO 05000297/2024202-2 Contrary to TS 3.4.a the licensee operated above 500 kW with the N-16 power measuring channel inoperable on June 27, 2024.
Discussed
None
Attachment