IR 05000182/2021201

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Purdue University, Routine Safety Inspection 050182/2021201
ML21124A199
Person / Time
Site: Purdue University
Issue date: 05/06/2021
From: Travis Tate
NRC/NRR/DANU/UNPO
To: Soon Kim
Purdue University
O'Bryan P
References
IR 2021201
Download: ML21124A199 (14)


Text

May 6, 2021

SUBJECT:

PURDUE UNIVERSITY - U.S. NUCLEAR REGULATORY COMMISSION SAFETY INSPECTION REPORT NO. 05000182/2021201

Dear Dr. Kim:

From February 22-24 2021, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an announced safety inspection at the Purdue University Research Reactor. The enclosed report presents the results of that inspection, which were discussed on February 24, 2021, with you and members of your staff.

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 inspector reviewed procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the NRC has determined that one Severity Level IV, non-cited violation of NRC regulatory requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

The violation is described in detail in the enclosed inspection report.

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 (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (Agencywide Documents Access and Management System (ADAMS)). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

R. Bean -2-If you have any questions concerning this inspection, please contact Mr. Phil OBryan at 301-415-0266 or by electronic mail at Phil.OBryan@nrc.gov.

Sincerely,

/RA Travis L. Tate, 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 Enclosure:

As stated cc: See next page

Purdue University Docket No. 50-182 cc:

Dr. Mung Chiang, Dean of Engineering Purdue University School of Nuclear Engineering 400 Central Drive West Lafayette, IN 47907 Mayor City of West Lafayette 1200 N. Salisbury Street West Lafayette, IN 47906 John H. Ruyack, Manager Epidemiology Res Center/Indoor & Radiological Health Indiana Department of Health 2525 N. Shadeland Avenue, Suite E3 Indianapolis, IN 46219 Howard W. Cundiff, P.E., Director Consumer Protection Indiana State Department of Health 2 North Meridian Street, 5D Indianapolis, IN 46204 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Dr.

College Park, MD 20742-2115

ML21124A199 NRC-002 OFFICE NRR/DANU/UNPO/ NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME POBryan NParker TTate DATE 05/06/2021 05/06/2021 05/06/2021

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.: 50-182 License No.: R-87 Report No.: 05000182/2021201 Licensee: Purdue University Facility: Purdue University Research Reactor Location: West Lafayette, Indiana Dates: February 22-24, 2021 Inspector: Phil OBryan Approved by: Travis L. Tate, 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 Enclosure

EXECUTIVE SUMMARY Purdue University Purdue University Research Reactor Inspection Report No. 05000182/2021-201 The primary focus of this routine, announced inspection was the onsite review of selected aspects of the Purdue University (the licensee) research reactor facility safety program, including: (1) organization and staffing, (2) operations logs and records, (3) procedures, (4) requalification training, (5) surveillance and limiting conditions for operation (LCO),

(6) experiments, (7) design changes, (8) committees, audits and reviews, (9) maintenance logs and records, and (10) fuel handling logs and records. The U.S. Nuclear Regulatory Commission (NRC) staff determined that the licensees programs were acceptably directed toward the protection of public health and safety, and generally in compliance with NRC requirements.

Organization and Staffing

  • Organization and staffing were consistent with the technical specification (TS) requirements.

Operations Logs and Records

  • Operations logs and records were maintained in accordance with procedures and TSs.

Procedures

  • The program for changing, controlling, and implementing facility procedures was maintained as required by the TSs and the applicable procedures.

Requalification Training

  • Operator requalification was conducted as required by the Operator Requalification Plan.

Surveillance and Limiting Conditions for Operation

  • Surveillance activities at the facility were completed in accordance with TSs.

Experiments

  • The program for reviewing, approving, and conducting experiments satisfied TS and procedural requirements.

Design Changes

  • Changes to the facility were evaluated using the criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59, Changes, tests and experiments.

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Committees, Audits and Reviews

  • Review and audit functions performed by the Committee on Reactor Operations (CORO)

satisfied TS requirements.

Maintenance Logs and Records

  • Maintenance activity records were maintained as required by TS and facility procedures.

Fuel Handling Logs and Records

  • No fuel handling activities were performed during this inspection period.

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REPORT DETAILS Summary of Facility Status The Purdue University Reactor (PUR-1) was operated in support of graduate and undergraduate research and laboratory instruction, reactor operator training, and periodic surveillance. During this inspection, the reactor was not operated.

1. Organization and Staffing a. Inspection Scope (Inspection Procedure (IP) 69001, Section 02.01)

To verify compliance with the TS requirements for organization and staffing, the inspector reviewed select aspects of the licensees program, including:

  • Technical Specifications for the Purdue University Reactor, PUR-1
  • select records, Prestart Checklist and Reactor Operation Record
  • reactor logbooks
  • Annual Reports for 2018 and 2019 b. Observations and Findings The inspector verified that the facility staffing did not change since the previous inspection and was maintained as required by TS 6.1.c, Staffing, for times that the reactor was not secured and when events required the presence of a senior reactor operator.

c. Conclusion The inspector found that TS requirements for organization and staffing were met.

2. Operations Logs and Records a. Inspection Scope (IP 69001, Section 02.02)

To verify compliance with the TS and procedural requirements for logs and records, the inspector reviewed select aspects of the licensees program, including:

  • Technical Specifications for the Purdue University Reactor, PUR-1
  • select records, Prestart Checklist and Reactor Operation Record
  • reactor logbooks
  • select records, PUR-1 Maintenance Log
  • PUR-1 procedures manual
  • Annual Reports for 2018 and 2019 b. Observations and Findings The inspector verified records were maintained in accordance with administrative requirements.

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c. Conclusion The inspector found that operations logs and records were in conformance with the approved TS and administrative procedures.

3. Procedures a. Inspection Scope (IP 69001, Section 02.03)

To verify compliance with the TS requirements for procedures, the inspector reviewed selected aspects of the licensees program, including:

  • PUR-1 Restart Plan
  • Technical Specifications for the Purdue University Reactor, PUR-1
  • standard operating procedure (SOP)-1, Prestart Checklist
  • SOP-2, Reactor Startup, Operation, Shutdown, and Securing
  • SOP-3, Sample Irradiation
  • SOP-4, Power Calibration by Gold Foil
  • CORO minutes from 2019 to the present b. Observations and Findings The inspector verified that procedures were developed as required by TS 6.4, Procedures.

Inspector Follow-up Issue (IFI) 2019-201-01 was documented in inspection report No. 50-182/2019-201. This IFI concerned procedures that referenced an older revision of TS. During this inspection, the inspector noted that the licensee is adequately tracking this issue and is periodically updating procedures with the correct TS reference. This IFI is closed.

c. Conclusion The inspector found that procedural review, revision, control, and implementation satisfied TS requirements.

4. Requalification Training a. Inspection Scope (IP 69001, Section 02.04)

To verify compliance with the regulations in 10 CFR Part 55, Operators Licenses, and approved requalification program, the inspector reviewed select aspects of the licensees program, including:

  • operator requalification program for the PUR-1 reactor facility
  • biennial requalification program records for 2019 and 2020
  • individual data sheets for 2019 and 2020
  • individual operator medical records-5-

b. Observations and Findings The inspector found that training was conducted in accordance with the licensees requalification plan.

IFI 50-182/2019-201-02 was opened in 2019 to track the licensees completion of operating tests and literature reviews. The inspector found that operating tests and literature reviews were brought up to date and tracked. This IFI is closed.

c. Conclusion The inspector found that training was conducted in accordance with the licensees requalification plan.

5. Surveillance and Limiting Conditions for Operation a. Inspection Scope (IP 69001, Section 02.05)

To verify compliance with the TS requirements for surveillances and LCO, the inspector reviewed select aspects of the licensees program, including:

  • Technical Specifications for the Purdue University Reactor, PUR-1
  • PUR-1 maintenance log
  • PUR-1 [Planned Maintenance System (PMS)] records & description
  • select records, Cycle Schedule and Quarterly Cycle datasheets
  • select records, Prestart Checklist and Reactor Operation Record
  • select records, PUR-1 Water Analysis Report, May 5, 2017, to present
  • reactor logbooks
  • CORO minutes, 2019 to the present
  • Annual Report for 2018 and 2019 b. Observations and Findings The inspector observed that the licensee used surveillance datasheets to ensure the required annual, semiannual, quarterly, monthly, and weekly administrative and TS items were completed in the required periodicity. The inspector verified that surveillance requirements performed were documented in the reactor logbooks and surveillance datasheets.

c. Conclusion The inspector found that surveillance activities at the facility were completed within the TS-prescribed time frames or were deferred by the CORO in accordance with TS.

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6. Experiments a. Inspection Scope (IP 69001, Section 02.06)

To verify compliance with the TS requirements for experiments, the inspector reviewed select aspects of the licensees program, including:

  • Technical Specifications for the Purdue University Reactor, PUR-1
  • CORO minutes for 2019 to the present
  • reactor logbooks b. Observations and Findings The inspector observed that no experiments were performed during the inspection period.

c. Conclusion The inspector found that the program for reviewing, approving, and conducting experiments satisfied TS and procedural requirements.

7. Design Changes a. Inspection Scope (IP 69001, Section 02.08)

To verify compliance with the regulations in 10 CFR 50.59, the inspector reviewed select aspects of the licensees program, including:

  • Technical Specifications for the Purdue University Reactor, PUR-1
  • Annual Reports for 2018 and 2019
  • maintenance logs
  • reactor logbooks b. Observations and Findings The inspector found that no change which required prior NRC approval was initiated and/or completed at the facility since the last NRC operations inspection.

c. Conclusion The inspector determined the licensee reviewed changes at the facility in accordance with 10 CFR 50.59 and applicable licensee administrative controls.

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8. Committees, Audits and Review a. Inspection Scope (IP 69001, Section 02.09)

To verify compliance with the TS requirements for review and audit, the inspector reviewed select aspects of the licensees program, including:

  • Annual Reports for 2018 and 2019
  • CORO minutes, 2019 to the present
  • PUR-1 annual and biennial audit reports, 2017 to the present b. Observations and Findings (1) Observations.

The inspector observed that the composition of the CORO was as specified in the TS. The inspector found that the CORO met at the prescribed frequency and, except as noted below, the CORO provided the oversight and reviews of the reactor programs as required by the TS.

(2) Non-Cited Violation (NCV) 05000182/2021-01. Failure to complete CORO audits as required by TS 6.2.d., CORO Audit Function, and 6.2.e., Audit of ALARA Program, Purdue TS 6.2.d. requires that the CORO conduct audits in different operational areas annually or biennially. TS 6.2.e. requires that the CORO chair, or a designated alternate, conduct an audit of the ALARA program annually. Contrary to these requirements, from 2019 until early 2020, the audits were not performed within the TS-required periodicity.

The inspector found that several TS-required audits were not completed within the required periodicity between the last NRC inspection in 2019 and the spring of 2020. The inspector noted that a new CORO chairman was appointed in 2020 and all TS-required audits were completed after this appointment. Therefore, the licensee is credited with identification and correction of the issue. Since the issue is not repetitive or willful, it is dispositioned as an NCV in accordance with Section 2.3.2.b of the NRC Enforcement Policy. This is a Severity Level IV NCV (Section 6.1) and is designated NCV 05000182/2021-01.

This also closes IFI 50-182/2019-201-03, follow up on CORO meeting periodicity and audits.

c. Conclusion The inspector found that the review functions performed by the CORO satisfied TS requirements, and the audit function was completed except as noted above.

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9. Maintenance Logs and Records a. Inspection Scope (IP 69001, Section 02.11)

To verify compliance with TS requirements for maintenance records, the inspector reviewed select aspect of the licensees program, including:

  • PUR-1 maintenance log
  • PUR-1 PMS records & description
  • reactor logbooks
  • Annual Reports for 2018 and 2019 b. Observations and Findings The inspector reviewed reactor and maintenance logs since the previous inspection in this area. The inspector found that tasks were completed within assigned periodicity and associated grace period.

c. Conclusion The inspector found that maintenance activities were documented, and records maintained as required by TS and facility procedures.

10. Fuel Handling Logs and Records a. Inspection Scope (IP 69001, Section 02.12)

To verify compliance with TS requirements for the PUR-1 fuel, the inspector reviewed select aspects of the licensees program, including:

  • reactor logbooks
  • PUR-1 Core Status Board b. Observations and Findings Based on a review of the reactor logbook, the inspector determined that no fuel movements occurred since last inspection. The inspector verified that fuel handling tools were adequately controlled/secured when not in use.

c. Conclusion The inspector found that no fuel handling activities took place since the last NRC inspection.

11. Exit Interview The inspection scope and results were summarized on February 24, 2021, with members of licensee management. The inspector described the areas inspected and discussed in detail the inspection findings.

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel R. Bean Director, Radiation Laboratories C. Townsend Reactor Supervisor Other Personnel M. Tang Radiation Safety Officer INSPECTION PROCEDURE USED IP 69001 Class II Non-Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 50-182/2021-201-01 NCV Failure to Complete CORO Audits as Required by TS 6.2.d and 6.2.e.

Closed/Discussed 50-182/2021-201-01 IFI Follow up on updates to TS required procedures.

50-182/2019-201-02 IFI Follow up on annual operating test and literature review 50-182/2019-201-03 IFI Follow up on CORO meeting periodicity and audits Attachment