ML21134A245: Difference between revisions

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{{#Wiki_filter:An equal opportun:ty msu ut. ~r, MISSOURI S&T                            Nuclear Reactor Facility 250 West 13 th St, Rolla, MO 65409-0450 (573) 341-4236 I reactor@mst.edu I reactor.mst.edu May 14, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
{{#Wiki_filter:}}
 
==SUBJECT:==
SELF-IDENTIFIED VIOLATION OF OPERATOR REQUALIFICATION PROGRAM
                    §2.2 FOR MISSOURI S&T REACTOR (R-79)
 
==Dear Sirs:==
 
The Missouri University of Science and Technology Reactor ("MSTR" with License R-79, Docket No. 50-123) has self-identified and is reporting a violation of the MSTR Operator Requalification Program §2.2. The attached document details the observed violation and the surrounding circumstances as well as immediate efforts taken to restore compliance.
If you have any questions regarding this report, please contact either Dr. Joseph Graham, the Reactor Director, at 573-341-7759; or Ethan Taber, the Reactor Manager, at 573-341-4291.
Sincerely, Ethan Taber                                                        Joseph Graham, PhD Reactor Manager, MSTR                                              Reactor Director, MSTR Enclosure cc:    Radiation Safety Committee (S&T)
Dr. Ayodeji Alajo, Interim Chair of NERS (S&T)
Mr. William Kennedy, Project Manager (NRC)
Mr. Phillip O'Bryan, Facility Inspector (NRC) 1/ 1
 
MSTR Licensee Event Report 21-01 On February 19, 2021, several Standard Operating Procedures (SOP) for the Missouri University of Science and Technology Reactor (MSTR) were revised in accordance with facility Technical Specifications (TS), the facility Safety Analysis Report (SAR) and facility procedures. The revisions were editorial in nature and did not substantively change existing facility processes.
Following the revisions, all licensed operators were to have reviewed and signed for each revised procedure. The operator signoffs were believed (from cursory reviews by the reactor manager) to have been performed as required with one noted exception. However, on April 29, 2021, it was discovered during a records review for an upcoming inspection that due to a clerical error, no review block had been generated for SOP 108. As such, SOP 108 was not indicated to have been reviewed by any of the licensed operators.
The other, aforementioned exception to the procedure signoffs was with respect to SOP 106 by a single operator. This exception was documented and, due to a very limited basis, evaluated as not being a violation. However, following discovery of the SOP 108 matter, the SOP 106 event is included here as it may indicate a systemic issue with procedure revision at MSTR.
Regulatory Basis Per 10 CFR 50.34(b)(8), the Final Safety Analysis report shall include A description of the plans for implementation of an operator requalification program. The operator requalification program must as a minimum, meet the requirements for those programs contained in § 55.59 of part 55 of [10 CFR].
Per 10 CFR 55.59(c)(iii), [The requalification program must include on-the-job training so that -] Each licensed operator and senior operator is cognizant of facility design changes, procedure changes, and facility license changes.
Per the MSTR Operator Requalification Program §2.2 Each licensed operator shall acknowledge in writing a change in any operating procedure prior to conducting operations after the change has been implemented. This requirement is implemented in SOP 100, Preamble, B.4, as a tracking sheet present in the Reactor Managers Controlled Copy of the 1/3
 
SOPs. Additionally, SOP 103, Reactor Startup to Low Power, B.1., echoes the requirement for operator review of procedures prior to operation.
Surrounding Circumstances and Mitigating Factors The MSTR has historically relied upon minimalistic procedures that met regulatory and license requirements but enabled considerable (and in some cases, undesirable) flexibility in implementation. Additionally, while annual reviews of the procedures by facility staff and external audits have identified potential shortcomings and proposed changes, minimal progress has been observed on including such changes. The procedure revisions made on February 19, 2021 were targeted in reducing these shortcomings, improving readability, and including long-standing verbal guidance and interpretations (effectively standing orders) issued by Senior Reactor Operators.
For SOP 108, the revisions implemented on February 19, 2021 consisted of the following:
* Renumbering the procedure from 810 to 108, to move the procedure inline with other normal operating procedures.
* Removing security-sensitive steps (although not considered Safeguards Information) and relocating to SOP 818.
* Reformatting the procedure into a more readable format.
* Including a records retention notice.
The proposed changes to the SOPs were thoroughly discussed among the MSTR operators both prior to, and following, issuance. Two of the Senior Reactor Operators were involved (either as preparer or reviewer) in the revision of some or all of the revised procedures.
Readthroughs of the procedure drafts were performed by nearly all of the operators. Thus, while the operators were aware of all procedural changes (as required by 10 CFR 55.59(c)(iii)) acknowledgement of that awareness was not properly documented per the facilitys Requalification Plan in the case of SOP 108.
Causes The following causes were identified:
: 1. The sparse procedure revision process at the MSTR (as delineated in SOP 100 B.2-5) only describes requirements for who is allowed to revise procedures (and under what 2/3
 
conditions), where the controlled copies are to be stored, and a requirement for operators to acknowledge procedure revision. Checklists or other verification tools to ensure that the process is completed uniformly are not currently implemented.
: 2. Too many procedures were revised at one time, leading to staff and operator focus being distributed.
: 3. SOP lists and indices do not display a revision number or date, which may allow for a more straightforward determination by an operator on currency of any procedure updates.
: 4. Licensed operators were not sufficiently checking that they were current (at least as documented) on all procedures prior to operation.
Corrective Actions The following corrective actions have been performed by the facility:
: 1. All operators verified that they had reviewed the revised SOP 108 by close of business, April 29, 2021.
The following corrective actions are planned for future implementation:
: 1. A formal SOP regarding procedure revision shall be drafted, reviewed by the MSTR Radiation Safety Committee, and implemented. The new procedure should include provisions for better revision tracking requirements.
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Revision as of 12:58, 8 September 2021

Missouri Univ. of Science & Technology, Self-Identified Violation of Operator Requalification Program 2.2
ML21134A245
Person / Time
Site: University of Missouri-Rolla
Issue date: 05/14/2021
From: Graham J, Taber E
Missouri Univ of Science & Technology
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML21134A245 (4)
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