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We would like to report a potential violation of our Technical Specifications, section 6.7.2.a.8 which states an observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to reactor operations. The details of the event are as follows: - January 14, (2015,) the Reactor Supervisor submitted paperwork for license renewal of an SRO (Senior Reactor Operator) to the director for signature. The director signs the paperwork. It was then assumed that the paperwork would be routed to the NRC for license renewal. The paperwork was signed but not sent to the NRC. - March 10, (2015,) the license for the SRO expires. - March 19, (2015,) the SRO completes the control room portion of the startup checklist. This includes manipulation of console controls and placing the reactor in 'OPERATING' condition. The SRO does not perform the reactor startup. - March 25, (2015,) staff determines that the reactor was placed in an OPERATING condition without a licensed operator at the console on March 19. No other staff was present in the control room during the performance of the startup checklist. - March 26, (2015,) reactor operation was suspended. It has been determined that the SRO did not perform any other license duties after his license had expired. The SRO will not perform license duties until his license is officially renewed.

• * * UPDATE AT 1905 EDT ON 04/08/15 FROM STEVEN REESE TO S. SANDIN * * *

On March 26, 2015, the Oregon State TRIGA Reactor staff self-reported a potential violation of Technical Specifications, section 6.7.2.a.8 which states 'an observed inadequacy in the implementation of administrative or procedural controls such that the inadequacy causes or could have caused the existence or development of an unsafe condition with regard to reactor operations.' The report was submitted due to the fact that the license of an SRO had expired on March 10, 2015, but that the operator performed licensed duties including placing the reactor in the 'operating' state on March 19, 2015. This individual did not perform any other license duties between the date his license expired and the date that a new license was issued. The initial notification e-mail sent by the reactor staff on 3/26/2015 (event notification 50927) informed the NRC of the event. In retrospect, we (Oregon State University) believe this event falls well below the threshold that would constitute a violation of Technical Specification 6.7.2.a.8. The individual has been a licensed operator of the Oregon State TRIGA Reactor for six years. None of the activities he (the operator) performed during the short period that his license was expired could realistically be construed as 'development of an unsafe condition with regard to reactor operations.' All duties that were performed during the event were reviewed by a licensed SRO as part of the daily start-up checklist. A new license was issued on April 2, 2015 (SOP-70794, Docket# 55-70933). The staff currently tracks all licensee due dates and it has been emphasized that maintenance of one's license is the responsibility of each licensed operator as well. The staff intends to add a tracking item to verify that 1) a license renewal is submitted at least 2 months prior to license expiration and 2) a license renewal is received at least one month prior to license expiration. It is expected that this information will reviewed during our (Oregon State University) next normally scheduled NRC inspection. No other follow-up or remedial actions are planned. This letter serves to retract the initial self-reported potential technical specification violation. Since it is deemed that a violation did not actually occur, there will be no subsequent 14-day written report. Notified NRR PM (Adams)