ML25105A279

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Purdue University - Us Regulatory Commission Safety Inspection Report 05000182/2025201, and Notice of Violation
ML25105A279
Person / Time
Site: Purdue University
Issue date: 04/28/2025
From: Tony Brown
NRC/NRR/DANU/UNPO
To: Soon Kim
Purdue University Research Reactor
Nadel J
References
IR 2025201
Download: ML25105A279 (1)
v • d • e


Text

Dr. Seungjin Kim, Reactor Director Purdue University The School of Nuclear Engineering 516 Northwestern Avenue West Lafayette, IN 47906

SUBJECT:

PURDUE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000182/2025201 AND NOTICE OF VIOLATION

Dear Dr. Kim:

From March 3-6, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a safety inspection at the Purdue University Research Reactor Facility. The inspection results were discussed with you and members of your staff on March 6, 2025. The enclosed report documents the inspection results.

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 occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's website at (http://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 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.

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 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).

April 28, 2025

S. Kim 2

Should you have any questions concerning this inspection, please contact Jared Nadel at 301 415-2157, or via email at Jared.Nadel@nrc.gov.

Sincerely, Tony Brown, 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. 50-182 License No. R-87

Enclosures:

As stated cc w/enclosure: GovDelivery Subscribers Signed by Brown, Tony on 04/28/25

ML25105A279 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME JNadel NParker TBrown DATE 4/16/2025 4/28/2025 4/28/2025 NOTICE OF VIOLATION Purdue University Docket No. 50-182 Purdue University Research Reactor License No. R-87 During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from March 3 - 6, 2025, at the Purdue University Reactor, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Title 10 of the Code of Federal Regulations (10 CFR) paragraph 55.53(e) requires, in part, [f]or test and research reactors, the licensee shall actively perform the functions of an operator or senior operator for a minimum of four hours per calendar quarter. Paragraph 55.53(f)(2) requires, in part, if paragraph (e) of this section is not met, before resumption of functions authorized by a license, the licensee must complete a minimum of six hours of shift functions under the direction of a senior operator.

Contrary to the above, in the first quarter of 2023 and the second quarter of 2024, two different operators at Purdue failed to perform the functions of an operator for the required four hours. As a result, both operators performed the functions of an operator for greater than six hours in the following quarters, but these functions were not performed under the direction of a senior operator.

This is a Severity Level IV violation (Section 6.1).

Pursuant to the provisions of 10 CFR 2.201, Notice of violation, Purdue University 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.

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 https://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.

2 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 28th day of April 2025.

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.:

50-182 License No.:

R-87 Report No.:

05000182/2025201 Licensee:

Purdue University Facility:

Purdue University Research Reactor Location:

West Lafayette, Indiana Dates:

March 3 - 6, 2025 Inspectors:

Jared Nadel, Reactor Inspector (RTR)

Juan Arellano, Reactor Inspector (RTR)

Approved by:

Tony Brown, 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

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an inspection at the Purdue University Research Reactor, in accordance with the research and test reactor inspection program. This is the NRCs program for overseeing the safe operation of licensed research and test reactors. Refer to https://www.nrc.gov/reactors/non-power.html for more information.

List of Violations Failure to Maintain Operator Licenses in an Active Status Severity Report Section Severity Level IV NOV 2025201-01 Open 69001.04 The inspectors identified a Severity Level IV notice of violation of Title 10 of the Code of Federal Regulations (10 CFR) 55.53(e) and (f) when two operators failed to maintain their licenses in an active status and the facility subsequently failed to supervise them upon resumption of licensed duties.

Violation of Technical Specifications Associated with the Pool Top Radiation Monitor Severity Report Section Severity Level IV NOV 2023201-01 Closed 69001.05 The inspectors reviewed the licensees response to the notice of violation (NOV)05000182/2023201-01 and determined that the reason, corrective actions taken, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket. The licensee informed the inspectors that a memorandum to file would be written explaining the interpretation of the technical specification (TS) to address recurrence. This item is considered closed.

Additional Tracking Items None.

3 REPORT DETAILS Facility Status The Purdue University Reactor (PUR-1) 12.5-kilowatt research reactor operates in support of experiments, training, and periodic equipment surveillances. During the inspection, the reactor was operated for a brief period at 60 percent power but otherwise was not operated.

Inspection Scopes Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at https://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2545, Research and Test Reactor Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

69001 - Class II Non-Power Reactors This inspection included a review of selected aspects of the research and test reactor, since the last inspection, to verify activities were conducted safely and in accordance with regulatory requirements and licensee commitments.

Organization and Staffing (IP Section 02.01)

This inspection included a review of the licensees organizational changes and shift staffing records to verify compliance with TS requirements and licensee commitments. Specifically, the inspection included a review of the following:

2023 annual operating report management changes submitted to the NRC, dated 2023-present select reactor startup and shutdown checks, dated 2023-present select console operations logs, dated 2023-present Operations Logs and Records (IP Section 02.02)

This inspection included a review of the licensees operation logs and records to verify they were maintained and that significant issues were reported and resolved as required by the TSs and the licensees administrative procedures. Specifically, the inspection included a review of the following:

select reactor startup checklists, dated 2023 - present select reactor status logs, dated 2023 - present select console operations logs, dated 2023 - present scram log entries, dated 2023 - present annual operating report, 2023 select maintenance log entries

4 Procedures (IP Section 02.03)

This inspection included a review of selected licensee procedures to verify: administrative controls were in accordance with the TSs, license requirements, and licensee commitments; the procedures in use were current and reviewed and approved, as required; procedures could be implemented as intended; and reactor personnel were observing administrative controls and TS requirements relative to procedural adherence. Specifically, the inspection included a review of the following:

  • Prestart Checklist and Reactor Operation Record," dated April 6, 2021, Revision 3 standard operating procedure (SOP)-1, "Prestart Checklist," dated April 6, 2021, Revision 2
  • SOP-2, Reactor Startup, Operation, Shutdown and Securing Procedure, Revision 2 dated April 6, 2021
  • Committee on Reactor Operations approved facility procedures index dated March 5, 2023 Requalification Training (IP Section 02.04)

This inspection included a review of selected documents pertaining to operator requalification training to verify requirements of the licensees approved requalification plan and 10 CFR Part 55, Operators Licenses were met. Specifically, the inspection included a review of the following:

Operator Requalification Program for the PUR-1 Reactor Facility, April 1, 2017 biennial requalification program reactivity manipulation, references review, and training records for all operators who held a license at the facility from 2023-present biennial requalification program examination records for all operators who received an exam at the facility from 2023-present select console operation logs, dated 2023-present SOP-1, Prestart Checklist, dated April 6, 2021, Revision 2 SOP-2, Reactor Startup, Operation, Shutdown and Securing Procedure, Revision 2 dated April 6, 2021 Surveillance and Limiting Conditions for Operation (IP Section 02.05)

This inspection included a review of surveillances listed in the TSs to verify requirements were met. Limiting conditions for operation were also reviewed to verify that operating conditions were maintained in accordance with the licensees procedural requirements. Specifically, the inspection included a review of the following:

surveillances excel sheet performed from 2023 - present master maintenance list 2024 reactor logbook dated February 2025 reactor logbook dated May 2024 to January 2025 reactor logbook dated December 2023 to May 2024 reactor logbook dated August 2023 to November 2023 standard maintenance procedure (SMP)-2, Electronic Calibration of the Reactor Safety Channels, dated January 12, 2021 SOP-4, Power Calibration by Gold Foil, dated December 9, 2022 procedure 95-7-RR, Procedure for Determining the Worth of the Regulating Rod by the Use of Positive Periods, dated July 28, 1995 electronic calibration date sheets performed from 2023 - present

5 DWK 250 Digital Wide Range Channel, dated April 11, 2013 factory acceptance test, Digital Startup Channel DAK 250-g," dated June 2016 Experiments (IP Section 02.06)

This inspection included a review of selected experiments and procedures to verify licensee experiments were reviewed, approved, and conducted in accordance with TS requirements, licensee procedures, and the requirements of 10 CFR 50.59, Changes, tests and experiments.

Specifically, the inspection included a review of the following:

SOP-3, Sample Irradiation, dated October 8, 2020 SOP-05-01, Sample Irradiation - New Experiment, dated June 14, 2005 SOP-99-SSG-2, Sample Irradiation of SS Guide Tube, dated December 15, 1999 requests for sample irradiations, Form B, performed from 2023 - present Health Physics (IP Section 02.07)

This inspection included a review of the licensees health physics program to verify that the provisions of 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection against Radiation, TSs, and the licensees procedural requirements were met. The inspectors reviewed: licensees dose limits; required radiation surveys, sampling, and monitoring; calibration of radiological instruments; the personnel dosimetry program; effluent releases; posting requirements; training requirements; the implementation of as low as is reasonably achievable (ALARA) principles; and the radiation protection programs review and approval requirements. Specifically, the inspection included a review of the following:

ALARA Plan for the Purdue University Reactor PUR-1, dated March 10, 2022, Revision 0 Radiation Safety Manual, dated October 24, 2024 environmental dosimetry records performed from 2023 - present personnel dosimetry for the reactor facility from 2023 - present continuous air monitor calibrations performed from 2023 - present SMP-4, AMS-4 CAM Calibration Procedure, August 25, 2021 Reactor Water Sampling and Analysis Standard Operating Procedure Radioactive Material Area Survey, for the Reactor Room, March 5, 2025 Purdue University Reactor (PUR-1) Water Analysis Report, January 27, 2025 Design Changes (IP Section 02.08)

This inspection included a review of design changes to determine whether they were reviewed, approved, and implemented in accordance with 10 CFR 50.59 the TSs, and the licensees administrative procedures. The inspectors also verified that modified equipment would continue to meet regulatory and procedural requirements and licensee commitments. Specifically, the inspection included a review of the following:

10 CFR 50.59 Screening for Replacement of the Process Water System Pump, dated April 6, 2023 10 CFR 50.59 Screening for Reinstalling the CAM After Repairs, dated May 3, 2023 "10 CFR 50.59 Screening for Repairing the RWMSRAM After Repairs," dated September 5, 2023 "10 CFR 50.59 Screening for Repairing the Console RAM After Repairs," dated September 5, 2023 "10 CFR 50.59 Screening for UPS-2 Replacement," dated August 28, 2024

6 "10 CFR 50.59 Screening for Replacement of CAM Detector Head Unit," dated September 19, 2024 "10 CFR 50.59 Screening for UPS-1 Replacement," dated January 23, 2025 "10 CFR 50.59 Screening for Reinstalling the CAM After Repairs," dated February 18, 2025 117-2030-02, "Reactor Water Make-Up System," dated May 4, 2017 Committees, Audits and Reviews (IP Section 02.09)

This inspection included a review of the licensees committees, audits and reviews to verify the safety review committee and independent audits were conducted in accordance with the TSs and that issues identified from reviews were resolved in accordance with TS requirements and the licensees procedures. Specifically, the inspection included a review of the following:

CORO Minutes, dated February 16, 2023 CORO Minutes, dated October 5, 2023 CORO Minutes, dated November 14, 2023 PUR-1 (# R-87) Technical Specification Audit, dated March 18, 2024 PUR-1 (# R-87) Technical Specification Audit, dated February 16, 2023 PUR-1 (# R-87) Emergency Plan Audit, dated March 19, 2024 Reactor Facility Security Plan Audit, dated March 19, 2024 PUR-1 (# R-87) Operator Retraining and Requalification Audit, dated August 23, 2024 PUR-1 (# R-87) ALARA Program Audit, dated August 20, 2024 PUR-1 (# R-87) ALARA Program Audit, dated December 8, 2023 Emergency Planning (IP Section 02.10)

This inspection included a review of the licensees emergency procedures, exercises and drills, training, and equipment to verify compliance with the licensees emergency plan and applicable regulatory requirements. Specifically, the inspection included a review of the following:

  • 2023 Purdue Reactor Drill After Action Report,
  • PUR-1 Reactor Drill Exercise Plan, April 27, 2023
  • 2024 Purdue Reactor Drill After Action Report
  • PUR-1 Reactor Drill Exercise Plan, April 25, 2024
  • SEP-1, Emergency Procedures, April 6, 2021
  • interview and response facility tour at the Purdue University Fire Department Maintenance Logs and Records (IP Section 02.11)

This inspection included a review of the licensees maintenance logs and records to verify that operational and maintenance activities were conducted and maintained in accordance with regulatory and TS requirements. Specifically, the inspection included a review of the following:

scram log entries, dated 2023 - present select maintenance log entries, dated 2023 - present select console log entries, dated 2023 - present 2023 annual operating report SMP-3, RMS-3 RAM Calibration Procedure, August 25, 2021 SMP-4, AMS-4 CAM Calibration Procedure, August 25, 2021

7 SMP-5, RWMS Cooling Pump Motor Greasing Procedure, January 26, 2021, Revision 0 SMP-8, Procedure for Inspection of Fuel Plates, August 5, 2021 M-6, Procedure for Determining the Excess Reactivity, July 27, 1995 Fuel Handling Logs and Records (IP Section 02.12)

This inspection included a review of the licensees fuel handling logs and records to verify TS and procedural requirements were met. Specifically, the inspection included a review of the following:

select console operations logs, dated 2023 - present 86740 - Inspection of Transportation Activities This inspection included a review of the licensees transportation activities to verify they have established and are maintaining an effective management-controlled program, to ensure radiological and nuclear safety in the receipt, packaging, and delivery of licensed radioactive materials. Specifically, the inspection included a review of the following:

SOP-W08, Radioactive Waste Removal (Waste Pick-up), dated May 6, 2024 Purdue waste pickup forms performed from 2023 - present Form R-1, Radioactive Material Requisition, revised October 29, 2024 SOP-P05, Shipment of Enriched Uranium (limited quantity), dated August 25, 2016 SOP-P01, Package Delivery of Radioactive Material, Revision 2015 Inspection Results Failure to Maintain Operator Licenses in an Active Status Severity Report Section Severity Level IV NOV 2025201-01 Open 69001.04 The inspectors identified a Severity Level IV notice of violation of 10 CFR 55.53(e) and (f) when two operators failed to maintain their licenses in an active status and the facility subsequently failed to supervise them upon resumption of licensed duties.

==

Description:==

The inspectors identified two licensed facility operators who each had failed to actively perform the minimum of four hours of the functions of an operator as required by 10 CFR 55.53(e). Operator A performed licensed functions for less than four hours during the first quarter of 2023. Operator B performed licensed functions for less than four hours during the second quarter of 2024. In accordance with 10 CFR 55.53(f), if the four hours requirement is not met in any calendar quarter, the operator must complete a minimum of six hours of shift functions, under the supervision of a senior reactor operator, before performing functions under their license independently. The inspectors conducted interviews with the facility senior reactor operator and reviewed the operations console logs. The inspectors found that both operator A and operator B completed six hours of operations in the subsequent calendar quarters after failing to meet the 10 CFR 55.53(e) four hours requirement, but those six hours of operations were not conducted under the direction or supervision of a senior reactor operator. Through interviews, the inspectors discovered that facility staff believed that only six hours of independent operations was required to return the operators to an active status. By the time of the inspection both operators had left the facility and resigned their licenses, so the violations were no longer ongoing.

Corrective Actions: Both operators resigned their licenses and left the facility prior to the identification of this violation. Additionally, the licensee confirmed that a new tracking

8 spreadsheet was being created to more formally track the operating hours of licensed operators. The licensee also discussed additional potential actions, such as a memo to file or specifics being added to the tracking spreadsheet that make the requirements of 10 CFR 55.53(e) and (f) clear.

Analysis: The violation was evaluated in accordance with the NRC Enforcement Policy. The violation is cited as a Notice of Violation because it constitutes a failure to meet regulatory requirements, has a more than minor safety significance, and the licensee failed to identify the violation.

Enforcement:

Severity: The violation is categorized at Severity Level IV in accordance with section 6.9.d of the NRC Enforcement Policy.

Violation: Paragraph 55.53(e) requires, in part, [f]or test and research reactors, the licensee shall actively perform the functions of an operator or senior operator for a minimum of four hours per calendar quarter. Paragraph 55.53(f)(2) requires, in part, if paragraph (e) of this section is not met, before resumption of functions authorized by a license, the licensee must complete a minimum of six hours of shift functions under the direction of a senior operator.

Contrary to the above, in the first quarter of 2023 and the second quarter of 2024, two different operators at Purdue failed to perform the functions of an operator for the required four hours.

As a result, both operators performed the functions of an operator for greater than six hours in the following quarters, but these functions were not performed under the direction of a senior operator. Both operators subsequently resigned their licenses and left the facility prior to this violation being identified.

Enforcement Action: This violation is being cited as a Notice of Violation, consistent with sections 2.3.2 and 2.3.3 of the NRC Enforcement Policy.

9 Violation of Technical Specifications Associated with the Pool Top Radiation Monitor Severity Report Section Severity Level IV NOV 2023201-01 Closed 69001.05 The inspectors reviewed the licensees response to NOV 05000182/2023201-01 and determined that the reason, corrective actions taken, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket. The licensee informed the inspectors that a memorandum to file would be written explaining the interpretation of the TS to address recurrence. This item is considered closed.

Exit Meeting and Debriefs The inspectors verified no proprietary information was retained or documented in this report.

On March 6, 2025, the inspectors presented the NRC inspection results to Dr. Kim and other members of the licensee staff.

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