ML21172A156
| ML21172A156 | |
| Person / Time | |
|---|---|
| Site: | Purdue University |
| Issue date: | 06/03/2021 |
| From: | Miller T Purdue University |
| To: | William Schuster Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML21172A156 (3) | |
Text
Director of the Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation ATTN. William Schuster U.S. NRC One White Flint North 11555 Rockville Pike Rockville, MD 20852 June 3, 2021
SUBJECT:
Request to Compensate for a Missed Annual Operating Test by Utilizing 10 CFR 55.59(b) for SOP-70830 at Purdue University, Docket 50-182
Dear Ms. Montgomery,
Purdue University Research Reactor, PUR-1 (Docket Number 50-182) is requesting a one-time re-instatement of operator proficiency for the facilitys senior reactor operator, SOP-70830, utilizing 10 CFR 55.59. The facility proposes that the annual operating exam for 2020, that he was unable to perform, described under 10 CFR 55.59(a), be compensated for by providing proof of additional training as described in 10 CFR 55.59(b).
The request is necessary as the operator was unable to complete the regularly scheduled annual operating exam in September of 2020. After completing a portion of the exam with the designated exempt SRO, the PUR-1 reactor was removed from service due to power calibration issues in October of 2020, before the remaining portion of the exam could be administered. By February of 2021 the reactor calibration issues were resolved, and normal operations resumed. However, during this period of operation the operator was not able to be at the facility due to personal leave. Following the operators return a combination of facility availability and personnel changes have prevented administration of the exam. The operator has maintained a license for over five years without issue and regularly performs the duties of a Senior Reactor Operator.
Currently, the reactor will not be operable until a power calibration study has been completed. In addition, the facilitys last qualified SRO, has left our facility as of June 1st. As such PUR-1 now has no individuals qualified to administer the operating exam to the operator. For these reasons the PUR-1 facility requests that the operating requirements be fulfilled by proof of additional training.
The following section lists multiple examples of additional training performed and abilities demonstrated, by the operator, to accomplish a representative sample of the 13 items enumerated in 10 CFR 55.45.
Items accomplished for 10CFR55.45.(a) accomplished a representative sample from among the following 13 items are as follows:
10CFR55.45.(a).(1). Perform pre-startup procedures for the facility, including operating of those controls associated with equipment that could affect reactivity.
Operator reviewed pre-startup procedure and walked though steps necessary to complete pre-startup operations.
l 516 Northwestern Ave l West Lafayette, IN, 47906 l 765-494-5739 l ne@purdue.edu l www.purdue.edu/NE
In addition, operator performed the SOP-1 Prestart Checklist on the following dates during the year of 2020: 1/29/20, 2/3/20, 2/6/20, 2/8/20, a second on 2/8/20, 2/12/20, 2/14/20, 2/18/20, 2/19/20, 3/11/20, 3/12/20, 3/24/20, 9/15/20, and 9/18/20.
10CFR55.45.(a).(2). Manipulate the console controls as required to operate the facility between shutdown and designated power levels.
Operator reviewed control design framework and chapter 7 of the safety analysis report. Actual console control not possible due to facility operability status.
Operator also performed all or portions of the SOP-2 Reactor Startup, Operation, Shutdown, and Securing Procedures on the following dates during the year of 2020: 1/29/20, 2/3/20, 2/6/20, 2/8/20, a second on 2/8/20, 2/12/20, 2/14/20, 2/18/20, 2/19/20, 3/11/20, 3/12/20, 9/15/20, and 9/18/20.
10CFR55.45.(a).(3). Identify annunciators and condition-indicating signals and perform appropriate remedial actions where appropriate.
Operator reviewed functional requirement specification for digital I&C upgrade as well as various initiating actions for all annunciators.
On 3/23/21, Operator trained a trainee on Engineering Safety Systems, specifically by demonstrating the securing of the Supply & Exhaust Fans, and the closing of the Condensate Drain Valve from the Console controls and pointing out the changes to the damper positions, the audible and visual alarms at the Digital I&C system.
On 3/25/21, Operator conducted a training evolution with a trainee on power cycling the Digital Reactor I&C System, conducting a power down and re-energization of the system operating all necessary controls and following indications.
10CFR55.45.(a).(5). Observe and safely control the operating behavior characteristics of the facility.
Operator reviewed historical operation campaigns and the control manipulations made as part of standard operating procedure. Actual operation not possible due to facility operability status.
Operator demonstrated safe control of operating behavior characteristics of the facility during startup, at power operations, and shutdown on the following dates during the year of 2020: 1/29/20, 2/3/20, 2/6/20, 2/8/20, a second on 2/8/20, 2/12/20, 2/14/20, 2/18/20, 2/19/20, 3/11/20, 3/12/20, 9/15/20, and 9/18/20.
10CFR55.45.(a).(6). Perform control manipulations required to obtain desired operating results during normal operations, abnormal, and emergency situations.
Operator reviewed emergency plan initiating events, mitigating actions and personnel notification requirements.
Operator performed control manipulations required to obtain desired operating results during normal operations on the following dates during the year of 2020: 1/29/20, 2/3/20, 2/6/20, 2/8/20, a second on 2/8/20, 2/12/20, 2/14/20, 2/18/20, 2/19/20, 3/11/20, 3/12/20, 9/15/20, and 9/18/20.
10CFR55.45.(a).(7). Safely operate the facilitys heat removal systems, including primary coolant, emergency coolant, and decay heat removal systems, and identify the relations of the proper operation of these systems to the operation of the facility.
Operator reviewed design of coolant processing system and associated settings to meet limiting conditions of operation as designated in the Technical Specifications.
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On 2/18/21, Operator conducted a training evolution with a trainee covering the facilitys heat removal system (also decay heat removal system), and the primary coolant system indicating the interface of the systems components to the Console, and related Console indications.
10CFR55.45.(a).(9). Demonstrate or describe the use and function of the facilitys radiation monitoring systems, including fixed radiation monitors and alarms, portable survey instruments, and personal monitoring equipment.
Operator reviewed radiation monitoring system design and calibration frequency as well as reviewed campus radiation protocol and location of portable survey instruments.
On 3/30/21, Operator conducted a training evolution with a trainee covering radiation monitoring systems, effluent monitoring equipment, portable survey equipment, and personnel monitoring equipment.
10CFR55.45.(a).(12). Demonstrate the knowledge and ability as appropriate to the assigned position to assume the responsibilities associated with the safe operation of the facility.
Operator reviewed the roles and responsibilities of a Senior Reactor Operator including those actions which must be performed under the direct supervision of an SRO.
On the following dates, 2/28/21, 3/18/21, 3/23/21, 3/25/21, 3/30/21, 4/1/21, and 5/6/21 operator conducted training sessions with a trainee demonstrating the knowledge and ability of responsibilities associated with the safe operation of the facility.
10CFR55.45.(a).(13). Demonstrate the applicants ability to function within the control room team as appropriate to the assigned position, in such a way that the facility licensees procedures are adhered to and that the limitations in its license amendments are not violated.
Operator reviewed normal protocol for normal operations, reactor demonstrations and other common use cases of the PUR-1 facility.
On 4/1/21, Operator conducted training with a trainee of the PUR-1 Technical Specifications.
Please feel free to contact me or any of us with questions or if you need further clarification.
I state under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
Sincerely, True Miller Reactor Supervisor N.E. Radiation Laboratory Coordinator School of Nuclear Engineering CC. Mung Chiang, Seungjin Kim, Stylianos Chatzidakis, David Storz Page 3 of 3