ML23017A207
| ML23017A207 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 01/13/2023 |
| From: | Sanford M Univ of Missouri - Columbia |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML23017A207 (1) | |
Text
January 13 , 2023 ATTN: Document Control Desk U.S . Nuclear Regulatory Commission Washington, DC 20555-0001
REFERENCE:
Docket No. 50-186 University of Missouri-Columbia Research Reactor Renewed Facility Operating License No. R-103
SUBJECT:
Written communication as required by University of Missouri Research Reactor Technical Specification 6.6.c(3) regarding a deviation from Technical Specification 6.1.f The attached document provides the University of Missouri-Columbia Research Reactor (MURR) Licensee Event Report (LER) for an event that was discovered on January 4, 2023 that resulted in a deviation from MURR Technical Specification 6.1.f.
If you have any questions regarding this report, please contact Ron Astrino, Reactor Manager, at (573) 882-5118.
Sincerely, I /((cur){~
Matt Sanford Interim Reactor Facility Director Enclosure cc: Reactor Advisory Committee Reactor Safety Subcommittee Dr. Mark McIntosh, Vice Chancellor for Research, Graduate Studies and Economic Development Mr. Geoffrey Wertz, U.S. Nuclear Regulatory Commission Mr. Craig Bassett, U.S. Nuclear Regulatory Commission Mr. Travis Tate, U.S. Nuclear Regulatory Commission
Enclosure U.S. Nuclear Regulatory Commission January 13 , 2023 Licensee Event Report No. 23 January 5, 2023 University of Missouri Research Reactor Introduction On January 5, 2023 , with the reactor operating at 10 MW in the automatic control mode, the Nuclear Regulatory Commission informed MURR' s Reactor Manager that an SRO' s license could not be renewed due to MURR not submitting the request at least 30 days prior to the expiration date as required by 10 CFR 55.55 . MURR submitted the renewal application on September 12, 2022 and due to the NRC being unable to act on the request before the expiration date, this meant the license expired on September 22, 2022. The Reactor Manager informed the interim Reactor Facility Director of this issue.
MURR validated the current SRO in the control room has a valid license and determined the reactor was in a safe condition. A review of our records shows that all other reactor operator and senior reactor operator licenses are current.
MURR reviewed all operating logs dating back to September 22, 2022 and has determined that there were three shifts during which this now unlicensed SRO was in the control room supervising evolutions that require an SRO to be present per Tech Spec 6.1 f. (Initial startup and approach to power, and the sole SRO relocation of any experiment with a reactivity worth greater than 0.0074 units).
Description of MURR' s Licensing Renewal Process MURR maintains all operator licenses expiration dates in a preventative maintenance system which automatically generates a maintenance item 45 days prior to a license expiring. This maintenance item is assigned to the Access Control Manager who gathers all required documentation, validates all requirements are met, submits it to the appropriate operator for review and signature, then forwards it to the NRC for review. This maintenance item is kept open and tracked by the Assistant Reactor Manager, Operations until the license is renewed by the NRC. Once the renewal is received, the maintenance item is closed out.
This process is well established and had not failed up to this point.
Description of Event The preventative maintenance item triggered 45 days prior to the affected operator' s license expiration date.
The Access Control Manager had resigned and was in the process of transitioning from MURR. Once they gathered all documents, they routed them to the operator' s in box for review and signature. The operator was on vacation which prevented their prompt action.
After returning from vacation, a few days lapsed before the operator signed the package and returned it to the Access Control Manager. The renewal request was sent to the NRC on September 12, 2022. This was 10 days prior to the license expiring on September 22, 2022 which fell outside the requirement of 10 CFR 55.55 which requires submission at least 30 days prior to expiration. MURR realized that time was short
Enclosure U.S. Nuclear Regulatory Commission January 13 , 2023 and did follow up with an email asking for confirmation four days after submittal and the NRC confirmed all material was received and would be reviewed.
Based on this, MURR assumed the license would be renewed with no issues. MURR had the operator continue to perfonn as a Senior Reactor Operator in the control room. Recently, it is common for a renewal request to take 90 days to be returned and has taken as long as 180 days.
On January 3, 2023 , the NRC informed the Reactor Manager that the license would not be renewed and that the effective expiration date would be September 22, 2022. The Reactor Manager contacted the NRC and asked for clarification on the process and how the expiration date was decided when all material submitted would normally have resulted in the license being renewed. The NRC and Reactor Manager held a conference call on January 5, 2023 to discuss the license renewal process. The Reactor Manager agreed with the NRC's conclusion and informed MURR' s interim Facility Director that a violation of Technical Specification 6.1.f- Events requiring the presence of a Senior Reactor Operator at the facility.
MURR reviewed all operating logs dating back to September 22, 2022 and has determined that there were three shifts during which this now unlicensed SRO was in the control room supervising evolutions that require an SRO to be present per Tech Spec 6.1 f. (Initial startup and approach to power, and relocation of any experiment with a reactivity worth greater than 0.0074 units). Those dates were November 1st, December 6th, and December 26 th all of 2022. The affected SRO has not been assigned to the control room since MURR was initially informed of the issue and they will not be assigned to the control room until they have a valid license.
Safety Analysis Based on this operator holding a Senior Reactor Operators license for 18 years, their satisfactory participation in our continuing training program and our requalification program, MURR feels at no time was the public or staff of MURR in any danger. A review of operating logs for those three days where it has been identified a deviation from Technical Specification occurred, revealed no abnormal trends or occurrences with reactor operations or radiation levels. Also, this is purely an administrative issue. If the paperwork had been submitted for renewal 20 days prior to when MURR submitted it, the operator' s license would have been renewed.
Problem, Causes, and Corrective Actions Problem 1 MURR submitted the license renewal paperwork less than 30 days prior to the license expiration date in violation of 10 CFR 55.55.
MURR made an improper assumption that the renewal application would be approved based on the confirmation email stating the renewal request had been received, even though MURR submitted the paperwork less than 30 days prior to the expiration date.
Corrective Action The Reactor Manager trained all of his managers on 10CFR55.55 and the reasoning behind the 30 day prior to deadline.
Enclosure U.S. Nuclear Regulatory Commission January 13 , 2023 Problem 2 The Access Control Manager was distracted with the transition to their new career. MURR did not have a second manager designated to review where we stood with submittal. This was a single point failure.
Cause Poor process. The established timeline is tight and there was no room for delays. In this case, the Access Control Manager became distracted, the operator felt no sense of urgency, and no other manger was involved.
Corrective Action The Reactor Manager and an Assistant Reactor Manager are now assigned as reviewers for the maintenance item adding additional layers of oversight to this process. This is no longer set up to be a single point failure.
Problem 3 Starting the renewal process at the 45-day point prior to expiration is too close to the 30-day requirement.
MURR internal process to meet the 10 CFR 55.55 30-day requirement for renewal submittal left no room for realistic delays.
Corrective Action MURR has reset the trigger for the associated maintenance item out to 90 days to ensure vacation or other distractions do not risk a renewal application being submitted within 30 days of license expiration.
Problem 4 Licensed Operators do not feel responsibility to ensure that their renewal is submitted on time. They simply trusted the process.
Licensed Operators did not understand the consequences to them if their license was not renewed due to a late renewal submittal.
Corrective Action The Reactor Manager is reminding all of their licensed operators that while the process or renewal supports them, they are an integral part of this process and ultimately, they should be ensuring their renewal request is submitted in time to allow them to maintain their license.
If there are any questions regarding this LER, please contact me at (573) 882-5118. I declare under penalty of perjury that the foregoing is true and correct.
Enclosure U.S. Nuclear Regulatory Commission January 13 , 2023 ENDORSEMENT:
Sincerely, Reviewed and Approved, Ronald M Astrino Matt Sanford Reactor Manager Interim Reactor Facility Director JENNIFER MARIE ROY Notary Public , Notary Seal State of Missour i Boone County Com mission# 22067459 My Commission Expires 01-17 -2026
\;;;;;;;;;..;;;.;.;;;;;;;.;;;.;;.:f
~