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Category:Letter
MONTHYEARML24221A2882024-08-0808 August 2024 Follow-Up Report on EN-57239, Deviation from 10 CFR 50.54(k) and Missouri S&T Reactor (R-79) Technical Specification 6.1.3.1.a) IR 05000123/20242012024-07-0101 July 2024 Board of Curators of the University of Missouri – U.S. Nuclear Regulatory Commission Safety Inspection Report 05000123/2024201 ML24151A6642024-05-30030 May 2024 Submittal of 2023-2024 Annual Progress Report for Missouri University of Science and Technology Reactor ML24018A1112024-01-19019 January 2024 Board of the Curators of the University of Missouri – Change of Facility Backup Project Manager ML24017A1662024-01-18018 January 2024 Examination Confirmation Letter No. 50-123/Ol-24-02, Missouri University of Science and Technology (Must) ML23349A2062023-12-15015 December 2023 Missouri University of Science and Technology Reactor (Mstr), Follow-Up Report on EN-56878, Reportable Occurrence ML23311A0722023-12-12012 December 2023 Examination Report Letter No. 50-123/OL-24-01, Missouri University of Science and Technology ML23222A2202023-08-10010 August 2023 Examination Confirmation Letter No. 50-123/OL-24-01, Missouri University of Science and Technology IR 05000123/20232012023-08-0202 August 2023 Board of Curators of the University of Missouri - Us Nuclear Regulatory Commission Safety Inspection Report No. 05000123/2023201 ML23145A2542023-05-23023 May 2023 2022-2023 Annual Progress Report for Missouri University of Science and Technology Reactor ML23114A0762023-04-24024 April 2023 Examination Report No. 50-123/OL-23-01, Missouri University of Science and Technology ML23114A0772023-04-24024 April 2023 Examination Result Letter No. 50-123/OL-23-01, Missouri University of Science and Technology ML23040A3902023-03-13013 March 2023 Examination Confirmation Letter No. 50-123/OL-23-01, Missouri University of Science and Technology ML22280A1742022-10-31031 October 2022 Examination Confirmation Letter No. 50-123/OL-23-01, Missouri University of Science and Technology ML22298A3032022-10-17017 October 2022 Level 1 Personnel Change at the Missouri University of Science and Technology Reactor ML22235A7872022-08-23023 August 2022 Missouri & T Reactor, Response to Notification of Violation and Inspection Report 05000123/2022002 IR 05000123/20222022022-07-25025 July 2022 Board of Curators of the University of Missouri - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000123/2022202 and Notice of Violation ML22150A0072022-05-30030 May 2022 Submittal of 2021-2022 Annual Progress Report for the Missouri University of Science and Technology Reactor ML22098A2232022-05-0505 May 2022 Board of Curators of the University of Missouri - U.S. Nuclear Regulatory Commission Security Inspection Report (Cover Letter) ML22018A3062022-02-0101 February 2022 Examination Confirmation Letter No. 50-123/OL-22-02, Missouri University of Science and Technology ML21330A0462022-01-21021 January 2022 Board of Curators of the University of Missouri Issuance of Amendment No 23 to Renewed Facility Operating License No R-79 ML21257A1192021-09-23023 September 2021 Board of the Curators of the University of Missouri - Change of Facility Project Manager ML21203A0762021-07-28028 July 2021 Examination Confirmation Letter No. 50-123/OL-22-01, Missouri University of Science and Technology IR 05000123/20210012021-06-28028 June 2021 Missouri University of Science and Technology (Ms&T) Routine Safety Inspection 50-123/2021-01 ML21153A4322021-06-0202 June 2021 Missouri & T Reactor - Follow-Up Report on Violation of Technical Specification (Surveillance Requirement) 4.6.2(1), EN-55266 ML21134A2452021-05-14014 May 2021 Missouri Univ. of Science & Technology, Self-Identified Violation of Operator Requalification Program 2.2 ML21039A3422021-02-0808 February 2021 Examination Confirmation Letter No.50-123/OL-21-01, Missouri University of Science and Technology ML21005A0272021-01-25025 January 2021 Must Amendment No 23 Acceptance Review - Application Accepted 12-28-2020 (6) ML20337A1622020-12-0202 December 2020 Proposed License Amendment Request for Missouri University of Science and Technology Reactor (License R-79, Docket 50-123) ML20295A4242020-11-16016 November 2020 Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards ML20314A3622020-11-12012 November 2020 Board of the Curators of the University of Missouri - Issuance of Amendment No. 22 to Renewed Facility Operating License No. R-79 to Extend the Period to Perform Visual Inspections of the Shim/Safety Rods ML20309A6762020-11-0404 November 2020 Missouri University of Science and Technology - Written Communication as Specified by 10 CFR 50.4 Requesting Approval of an Exigent Amendment to the Technical Specifications Appended to Facility Operating License R-79 IR 05000123/20202012020-09-28028 September 2020 Missouri University of Science and Technology - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000123/2020201 ML20150A6062020-05-29029 May 2020 Missouri Univ. of Science & Technology - Submittal of 2019-2020 Annual Progress Report for Missouri University of Science and Technology Reactor ML19347B2142019-12-23023 December 2019 Examination Report No. 50-123/OL-20-01, Missouri University of Science and Technology ML20006C9282019-12-23023 December 2019 Examination Confirmation Letter No. 50-123/OL-20-02, Missouri University of Science and Technology ML19304B7332019-11-0505 November 2019 Examination Confirmation Letter No. 50-123/OL-20-01, Missouri University of Science and Technology ML19206A3642019-07-25025 July 2019 Examination Confirmation Letter No. 50-123/OL-19-02, Missouri University of Science and Technology IR 05000123/20192012019-07-0303 July 2019 Missouri University of Science and Technology - U.S. Nuclear Regulatory Commission Inspection Report No. 50 123/2019-201 ML19182A3592019-07-0101 July 2019 Level 1 Personnel Change at the Missouri University of Science and Technology Reactor ML19149A6242019-05-29029 May 2019 Missouri s & T Reactor - 2018-2019 Annual Progress Report for Missouri University of Science and Technology Reactor ML19028A2942019-01-17017 January 2019 Level III Personnel Change at the Missouri University of Science and Technology Reactor Facility, License R-79, Docket 50-123 ML19010A0822019-01-17017 January 2019 Washington State University - Change of Facility Project Manager ML18365A3532019-01-0808 January 2019 Missouri University of Science and Technology - Change of Facility Project Manager IR 05000123/20182022018-12-26026 December 2018 Missouri University of Science and Technology - U.S. Nuclear Regulatory Commission Security Inspection Report 05000123/2018202 (Cover Letter) ML18276A2842018-09-28028 September 2018 Missouri S&T Reactor - Submittal of Updated Operator Requalification Program ML18257A1372018-09-14014 September 2018 Missouri University of Science and Technology Reactor (S&T Reactor) - Reply to a Notice of Violation ML18233A4012018-07-0202 July 2018 Requesting Approval for Reviewing Official at Mstr ML18165A3982018-06-12012 June 2018 Missouri s & T Reactor - Submittal of Annual Progress Report 2017-2018 ML18085A6662018-05-15015 May 2018 Examination Report No. 50-123/OL-18-01, Missouri University of Science and Technology 2024-08-08
[Table view] Category:Written Event Report (30 or 60 day)
MONTHYEARML24221A2882024-08-0808 August 2024 Follow-Up Report on EN-57239, Deviation from 10 CFR 50.54(k) and Missouri S&T Reactor (R-79) Technical Specification 6.1.3.1.a) ML21153A4332021-06-0202 June 2021 Missouri & T Reactor - Follow-Up Report on Violation of Technical Specification (Surveillance Requirement) 4.6.2(1), EN-55266 ML21153A4322021-06-0202 June 2021 Missouri & T Reactor - Follow-Up Report on Violation of Technical Specification (Surveillance Requirement) 4.6.2(1), EN-55266 ML21134A2452021-05-14014 May 2021 Missouri Univ. of Science & Technology, Self-Identified Violation of Operator Requalification Program 2.2 2024-08-08
[Table view] |
Text
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
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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