ML25121A307

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National Organization of Test, Research, and Training Reactors 2024 Presentation by Travis Tate on Non-power Production and Utilization Facilities Oversight
ML25121A307
Person / Time
Issue date: 10/01/2024
From: Travis Tate
Office of Nuclear Reactor Regulation
To:
National Organization of Test, Research, & Training Reactors (TRTR)
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ML25121A274 List:
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Download: ML25121A307 (1)


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Overview of NPUF Oversight Program TRTR Conference Albuquerque, NM October 1, 2024 Travis L. Tate, Branch Chief Non-Power Production and Utilization Facility Oversight (UNPO)

Meet the UNPO Branch Chief Travis L. Tate 2

B.S. Nuclear Engineering, University of Tennessee, Knoxville Science Applications International Corporation staff nuclear engineer supporting various Department of Energy activities at facilities in Oak Ridge, TN and Savannah River Site Nuclear Regulatory Commission Operating Reactor Licensing Project Manager Rotation to Salem/Hope Creek Resident Inspector Office NRR Division & Office Technical Assistant NRR Branch Chief (license renewal, accident dose analysis, reactor licensing)

Region I Acting Branch Chief NMSS Branch Chief UNPO since January 2020

UNPO Functions 3

Implements the NRCs safety and security inspection and operator licensing oversight programs for non-power production and utilization facilities (NPUFs) from initial licensing to decommissioning Conducts review of NPUF security and emergency plans and coordinates event response activites

UNPO Staff Examiner Staff John Nguyen - retired Michele DeSouza Amy Beasten Dan Hoang - transferred Tuan Le Timothy Ayres Margarette Maggie Goodwin Paulette Torres - PM 4

Travis Tate, Chief Inspection Staff Craig Bassett Andrew Waugh Juan Arellano Brian Lin Necota Staples Jonathan Braisted Jared Nadel Michael Balazik - PM Kevin Roche - PM Green = new Red = losses Blue = supplemental Licensing Assistants Nicole Parker Nia Jones - Operator Licensing Security Specialist Thomas Eck

NPUF Inspection Program FY 24 Results Inspection Manual Chapter 2545, Research and Test Reactor Inspection Program

  • Completed 41 inspections

- 12 Security inspections

  • 2 - Non-cited violations (NCV)

- 28 Safety inspections

- Supplemental inspection

  • No violations 5

NPUF Inspection Program Violation Trend 6

0 2

4 6

8 10 12 14 16 18 20 FY 2021 FY 2022 FY 2023 FY 2024 Violations Non-cited SL I SL II SL III SL IV Total

NPUF Inspection Program Timeliness Trend 0

10 20 30 40 50 60 70 80 FY 2021 FY 2022 FY 2023 FY 2024 Inspection Report Avg (days)

Percent (%)

Goal (days) 7

NPUF Inspection Program Activities Guidance

- Revised IMC 0615 Research and Test Reactors Inspection Reports (effective October 1, 2024)

  • Streamlined and standardized report language for efficiency
  • Formatted to allow use of Reactor Program System (RPS) report generator tool to improve efficiency
  • Removed inspection follow-up items and revised definition of unresolved items

- Revised IMC 2550 Non-Power Production and Utilization Facilities Licensed Under 10 CFR Part 50: Construction Inspection Program (CIP)

(effective May 16, 2024)

  • Incorporated lessons learned from SHINE and Vogtle 3 & 4 construction projects Access to inspection reports available on NRC website at:

https://www.nrc.gov/reactors/non-power/inspection-reports.html Inspection findings captured in RPS 8

NPUF Inspection Program Enhancements Response to the Office of the Inspector General (OIG) Inquiry Report Emphasize direct observation of risk significant activities when scheduling inspections Revise inspection guidance on safety and audit committee assessment Enhance inspector qualification and refresher training on safety culture Enhance inspector training on precursors to fuel damage Develop public webpage for inspection reports and operational experience Enhance the current annual licensing and oversight program review Formalize periodic reviews of inspection guidance for NPUFs Response to the OIG Audit of Inspection Program for Class II facilities Enhance guidance for creating, recording, and approving inspection hours in RPS Enhance inspector training tracking Conduct periodic reviews of inspector training program to reflect new training needs Update plans and schedule for complete transition of program management to RPS Enhance guidance for periodic review of inspection guidance 9

NPUF Inspection Program Enhancements (cont.)

  • Oversight observations:

- Implementation of Part 73 changes (Event Notifications)

  • Compliance date: January 8, 2024
  • This final rule modifies existing physical security event notifications, written follow-up reports, and recordkeeping regulations.
  • Changes to security plan and/or procedures should have already been made to include the new required notifications made to the NRC.

- Event reporting

- Fuel inspections

- Material control & accountability (MC&A) inventory

- Console key issues 10

NPUF Operator Licensing Program - FY 24 Results 378 active operator licenses 183 reactor operators (RO) 195 senior reactor operators (SRO) 26 facility examinations conducted 11 Type Total # of Written Exams

  1. of Written Exam Failures

(%)

Average Written Exam Grade Average Written Failure Grade Total # of Operating Exams

  1. of Operating Exam Failures

(%)

NEW 72 10 13.89%

85.33 74.38 72 3

4.17%

REAPP 2

0 0.00%

86.45 0

0 0.00%

RO 74 10 13.51%

85.36 74.38 72 3

4.17%

NEW 11 2

18.18%

85.31 70.00 11 1

9.09%

REAPP 2

0 0.00%

86.30 0

0 0.00%

UPGRADE 10 0

0.00%

10 2

20.00%

SRO 23 2

8.70%

85.46 70.00 21 3

14.29%

Total for HQ:

97 12 12.37%

85.37 73.65 93 6

6.45%

NPUF Operator Licensing Program - Trend 80 81 82 83 84 85 86 87 88 89 FY 2019 FY 2020 FY 2021 FY 2022 FY 2023 FY 2024 Average Written Exam Grade RO SRO Total 12

NPUF Operator Licensing Program - Trend 0

5 10 15 20 25 FY 2019 FY 2020 FY 2021 FY 2022 FY 2023 FY 2024 Written Exam Failures (%)

RO SRO Total 13

NPUF Operator Licensing Program - Trend 0

2 4

6 8

10 12 14 16 FY 2019 FY 2020 FY 2021 FY 2022 FY 2023 FY 2024 Operating Exam Failures (%)

RO SRO Total 14

NPUF Operator Licensing Program Timeliness Trend 0

20 40 60 80 100 120 FY 2021 FY 2022 FY 2023 FY 2024 Examination Results Avg (days)

Percent (%)

Goal (days) 15

NPUF Operator Licensing Program Activities

  • Eliminated licensed operator certificate backlog
  • Reduced termination letter backlog
  • Improved licensed operator data in Operator Docket Database (ODD) and RPS -

Operator Licensing (RPS-OL)

  • Conducted workshop on NRC Form 396/398
  • Reduced use of waivers/excusals 16

NPUF Operator Licensing Program Enhancements Revision 3 to NUREG 1478

- Clarifying language for 1 year facility experience

- Clarifying guidance on timing of actions (examination confirmations, application submittals)

- Clarifying guidance on use of waivers, deferrals, excusals Collaborative Learning Environment (CLE) tool

- Written examinations in CLE question bank ODD replacement project Observations

- Outdated NRC Form 396/398

- Renewal applications & timely renewal provisions

- Pre-examination schedule confirmations

- Pre-examination coordination of operational restrictions 17

Contact Info:

Travis Tate, Chief Non-Power Production and Utilization Facility Oversight Branch Email: Travis.Tate@nrc.gov Phone: 301-415-3901 18

Event Notification Regulations Travis Tate

Key Dates

  • Rule published in the Federal Register
  • Effective date: April 13, 2023
  • Public Meeting for NPUF licensees: May 10, 2023
  • Compliance date: January 8, 2024
  • To date there has been no submission to the NRC for security plan changes under 10 CFR 50.54(p) or license amendments requests

New Regulations 10 CFR 73.71 is no longer applicable, nor is Appendix G The following new regulations apply to NPUFs:

10 CFR 73.1200 - Notification of Physical Security Events The types of events may have changed The time for reporting has changed 10 CFR 73.1205 - Written Follow-up Reports of Physical Security Events 10 CFR 73.1210 - Recordkeeping of Physical Security Events This is a NEW requirement Discussions at the least two TRTR conferences discussed this new requirement

New Guidance Issued RG 5.62, Revision 3 (ML23299A176)

Physical Security Event Notifications, Reports, and Records RG 5.87, Revision 0 Suspicious Activity Reports Under 10 CFR Part 73 (ML17138A384)

Summary This final rule modifies existing physical security event notifications, written follow-up reports, and recordkeeping regulations, and adds new requirements for certain facilities or activities.

Changes to your security plan and/or procedures should have already been made to include the new required notifications made to the NRC