IR 05000407/2023201
| ML23226A010 | |
| Person / Time | |
|---|---|
| Site: | University of Utah |
| Issue date: | 01/16/2024 |
| From: | Travis Tate NRC/NRR/DANU/UNPO |
| To: | Sjoden G Univ of Utah |
| References | |
| IR 2023201 | |
| Download: ML23226A010 (14) | |
Text
SUBJECT:
UNIVERSITY OF UTAH - U.S. NUCLEAR REGULATORY COMMISSION ROUTINE INSPECTION REPORT NO. 05000407/2023201
Dear Dr. Sjoden:
From July 10 - 13, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the University of Utah TRIGA Nuclear Reactor facility. The enclosed report documents the inspection results, which were discussed on July 13, 2023, with you and other faculty and staff members.
During the inspection, the NRC staff examined activities conducted under your license as they relate to public health and safety to ensure compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has determined that two Severity Level IV violations of NRC requirements occurred. The violations are being treated as non-cited violations (NCVs), consistent with section 2.3.2.b of the Enforcement Policy. The NCVs are described in the subject inspection report. No response to this letter is required. However, if you contest the violations or significance of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, Attn: Document Control Desk, Washington DC 20555-0001, with copies to be sent to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
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 website at https://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
January 16, 2024 If you have any questions concerning this inspection, please contact Craig Bassett at (240) 535-1842, or by email at Craig.Bassett@nrc.gov.
Sincerely, 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. 50-407 License No. R-126 Enclosure:
As stated cc: GovDelivery Subscribers Signed by Tate, Travis on 01/16/24
ML23226A010 NRC-002 OFFICE NRR/DANU/UNPO/RI NRR/DANU/UNPO/LA NRR/DANU/UNPO/BC NAME CBassett NParker TTate DATE 8/17/2023 8/18/2023 1/16/2024
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
Docket No.: 50-407
License No.: R-126
Report No.: 05000407/2023201
Licensee: University of Utah
Facility: University of Utah TRIGA Nuclear Reactor
Location: Salt Lake City, UT
Dates: July 10 - 13, 2023
Inspector: Craig H. Bassett
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
University of Utah University of Utah TRIGA Nuclear Reactor Inspection Report No. 05000407/2023201
The primary focus of this routine, announced inspection included onsite review of selected aspects of the University of Utah (the licensees) 100 kilowatt Class II research reactor safety program, including: (1) organization and staffing; (2) operations logs and records; (3) procedures, (4) requalification training, (5) surveillance and limiting conditions for operation; (6) experiments, (7) design changes; (8) committees, audits and reviews; (9) maintenance logs and records; and (10) fuel handling logs and records since the last U.S. Nuclear Regulatory Commission (NRC) inspection of these areas. The NRC staff determined the licensee's program was acceptably directed toward the protection of public health and safety and was in compliance with NRC requirements. Two non-cited violations (NCVs) were identified.
Organization and Staffing
- The organizational structure at the facility met the requirements specified in technical specification (TS) section 6.1.
Operations Logs and Records
- Operational logs and records were consistent with applicable TS and procedural requirements and reactor operations were conducted in accordance with TSs and procedural requirements.
- Shift staffing met the minimum requirements in the TSs for reactor operations.
Procedures
- Facility procedures and document reviews satisfied TS section 6.4 requirements.
Requalification Training
- Operator requalification was conducted as required by the Requalification Program and Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators Licenses.
Surveillance and Limiting Conditions for Operation
- The surveillance program, including periodic checks, tests, and verifications, was implemented in accordance with TS sections 3 and 4.
Experiments
- The experiment authorization (EA) and control program satisfied regulatory and TS requirements.
- A violation was noted for failure to have an adequate procedure for requesting irradiations and experiments.
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Design Changes
- Changes made at the facility during the past 2 years were completed in accordance with 10 CFR 50.59, Changes, tests and experiments, and applicable licensee procedures.
Committees, Audits and Reviews
- Review and audit functions required by TS section 6.2 were acceptably completed by the Reactor Safety Committee (RSC) or designated individuals.
Maintenance Logs and Records
- Maintenance activities were ongoing at the facility.
- Reactor tank repair was reviewed during the inspection, but the results are still being analyzed and will be reviewed during a subsequent inspection.
Fuel Handling
- Reactor fuel movements were completed and documented in accordance with procedures.
- The licensee failed to inspect all fuel elements on a biennial basis as specified by TS section 4.1.5.
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REPORT DETAILS
Summary of Facility Status
The University of Utah 100 kilowatt (kW) TRIGA Mark-I reactor (UUTR) was typically operated in support of educational demonstrations, laboratory experiments, reactor system testing, sample irradiations, and operator training. It was usually operated one or two days a week at various power levels up to 90 kW. During the inspection, the reactor was not operated due to ongoing reactor pool repair work.
1. Organization and Staffing
a. Inspection Scope (Inspection Procedure [IP] 69001, Section 02.01)
The inspector interviewed licensee personnel and reviewed the following records and logs to verify that the staffing requirements, personnel responsibilities, and organizational structure specified in section 6.1 of the licensees TSs were met:
- TRIGA Reactor console logbooks Nos. 42 and 43
- administrative controls and management responsibilities
- Utah Nuclear Engineering Program (UNEP) Procedure-001 (UNEP-001),
Prestart/Operation/Termination Procedure, Revision 18
b. Observations and Findings
The inspector confirmed that the organizational structure and management responsibilities at the UUTR facility were as stated in section 6.1 of the TSs.
c. Conclusion
The inspector determined that the organizational structure at the facility met the requirements specified in TS section 6.1.
2. Operations Logs and Records
a. Inspection Scope (IP 69001, Section 02.02)
The inspector reviewed selected aspects of the following to ensure that the reactor operations program was implemented as required in TS sections 3, 4, and 6:
- UUTR console logbooks Nos. 42 and 43
- UNEP startup and termination procedures and log
- selected surveillance data sheets, records, and tests
- various procedures and associated forms including UNEP-001R18 Prestart/Operation/Termination Procedure; UNEP-002R4, Biennial Fuel/Tank/Control Rod/Reflector Element Inspection; UNEP-020R14b, Monthly Inspection/Surveillance Procedure
- The UUTR Annual Operating Reports for the periods of July 1, 2020, through June 30, 2021, submitted to the NRC on July 30, 2021, and July 1, 2021, through June 30, 2022, submitted on July 29, 2022
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b. Observations and Findings
The inspector verified that the reactor operating characteristics, and other procedurally required data entries were logged and that the checklists were completed. The inspector also verified that the TS operational limits were not exceeded and that shift staffing met the minimum requirements. The inspector observed that a new reactor console was installed at the facility and was noted in the UUTR console logbook.
c. Conclusion
The inspector determined that operational activities were consistent with applicable TSs and procedural requirements and shift staffing met the requirements for reactor operations.
3. Procedures
a. Inspection Scope (IP 69001, Section 02.03)
To verify that facility procedures were maintained, revised, and implemented as required by TS section 6.4, the inspector reviewed various aspects of:
- UNEP-001R18, Prestart/Operation/Termination Procedure
- UNEP-003R8, Semi-Annual Control Rod Calibration
- UNEP-020R14b, Monthly Inspection/Surveillance Procedure
- procedural reviews and updates documented in the RSC meeting minutes
b. Observations and Findings
The inspector noted that licensee procedures were often comprised of checklists or forms to assist staff members in completing required work in a systematic, step-by-step manner. The inspector found that some job aides were also available for use. The inspector confirmed substantive changes to the procedures were reviewed and approved by the RSC as required. The inspector also confirmed that the licensees implementation of training of personnel on procedures and procedure changes was acceptable.
c. Conclusion
The inspector determined that, except as noted in Section 6 below, facility procedures were maintained, reviewed, revised, and implemented as required by TS section 6.4.
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4. Requalification Training
a. Inspection Scope (IP 69001, Section 02.04)
To verify that the operator requalification activities and training were conducted in accordance with various regulatory requirements in 10 CFR Part 55 and the requirements stipulated in the Operator Requalification Program contained in the safety analysis report (SAR), the inspector reviewed selected aspects of:
- UUTR console logbooks Nos. 42 and 43
- SAR chapter 12, section 9, Operator Training and Requalification
- selected requalification training records for the past 3 years
- selected medical examination records for the past 3 years
- various procedures and associated forms including UNEP-017R3, Familiarization Checklist, and UNEP-025R4, Requalification Checklist
b. Observations and Findings
The inspector noted that the active NRC-licensed staff at the facility consisted of three senior reactor operators (SROs) and four reactor operators (ROs). The inspector verified that all the licenses were current. The inspector confirmed that the operators successfully completed the facilitys requalification and training program by completing the minimum required hours of operating the reactor or performing maintenance duties per quarter. The inspector also noted that the operators completed annual operating tests and written examinations as required. The inspector also verified that the operators received the appropriate biennial medical examinations as required by the regulations.
c. Conclusion
The inspector determined that the operator requalification was conducted as required by the licensees Operator Requalification Program and 10 CFR Part 55.
5. Surveillance and Limiting Conditions for Operation
a. Inspection Scope (IP 69001, Section 02.05)
To verify that the licensee conducted the facility surveillance program in accordance with TS requirements, the inspector reviewed:
- UUTR console logbooks Nos. 42 and 43
- UNEP, Scheduled Surveillance Procedures and Log (SSL), and associated forms
- UNEP, Unscheduled Surveillance Procedures and Log (USL), and associated forms
- UNEP-020R14b, Monthly Inspection/Surveillance Procedure
- the two most recent UUTR annual operating reports
- selected UUTR required surveillances.
b. Observations and Findings
The inspector verified daily, monthly, and other periodic checks, tests, and verifications required by the TSs were completed. The inspector verified the recorded results were
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within the TSs and procedurally prescribed parameters. The inspector confirmed records and logs were complete and were maintained as required by procedure.
c. Conclusion
The inspector determined that the surveillance program, including periodic checks, tests, and verifications, was implemented in accordance with TS sections 3 and 4 requirements.
6. Experiments
a. Inspection Scope (IP 69001, Section 02.06)
The inspector reviewed selected aspects of the following to verify that experiments were conducted within the controls specified in TS sections 3.8, 4.8, and 6.5, and approved guidelines:
- UNEP experiment log
- survey and control of irradiated items
- UUTR console logbooks Nos. 42 and 43
- UNEP-027R6, Irradiation Request and Performance, and completed forms
- various authorized experiments and associated documentation
b. Observations and Findings
(1) Routine Experiment Review
The inspector verified that experiments conducted at the facility were reviewed and approved as required by the TSs. The inspector noted that substantive changes to previously approved experiments were implemented only after the appropriate review by the Reactor Supervisor and approval by the Level 2 official. The inspector verified that the results of irradiations completed under the approved experiments were documented in the UUTR console logbook and on the appropriate forms. The inspector also noted that experiments were conducted in accordance with procedural and EA guidelines and that materials produced were controlled as required by the radiation protection program.
(2) Negative Reactivity Worth Inconsistency
On December 9, 2022, the licensee notified the NRC Operations Center about a problem that occurred on December 6, 2022, at the UUTR facility. This was logged as Event No. 56267. The event developed as indicated below.
A UUTR RO was in the process of conducting a sample irradiation. During a reactor startup on December 6, 2022, the RO noted that the sample appeared to have a larger negative reactivity worth than anticipated. Therefore, the RO immediately shut down the reactor. An updated materials assessment of the sample and sample holder materials by the UUTR staff revealed a negative reactivity worth that was much larger than the original estimate. The licensee notified the NRC Operations Center in accordance with TS section 6.7.2.1.8 which states in part that, in addition
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to the requirements of applicable regulations, and in no way substituting therefore, reports shall be made by the UNEP Director to the NRC as follows: A report not later than the following working day by telephone... of an observed inadequacy in the implementation or 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 reactor was secured, and the Director ordered that reactor operations would not resume without his authorization. The Director also notified the NRC Project Manager and the inspector. The NRC determined that the issue would be assessed during the next routine inspection.
During this inspection, the inspector reviewed this issue, the licensees corrective actions, and considered the safety significance of the event. The inspector noted that the initial action taken by the RO in shutting down the reactor when the readings on the console were not as expected prevented a violation of TS section 3.8.1 which requires that the reactor shall not be operated unless the following conditions exist:
1. The absolute value of the reactivity worth of any single secured or unsecured experiment be less than $1.00, and, 2. The sum of the absolute values of the reactivity worths of all experiments shall be less than $1.20. The inspector verified that, after a review of the procedure, UNEP-027, Irradiation Request and Performance, which was last revised March 3, 2011, the licensee found that it did not contain sufficient guidance for experimenters regarding the completion of an effective reactivity assessment of all aspects of a sample to be irradiated. The inspector confirmed that the licensee took corrective actions by revising procedure UNEP-027 to delineate the proper calculation of reactivity worth of the sample and the sample holder. Another action was added to the procedure to require that everyone involved in an experiment attend a briefing held prior to the irradiation to discuss sample parameters and ensure all personnel were aware of potential experimental conditions or alterations that could affect sample reactivity. The licensee also revised the startup procedure to include a calculation of the maximum expected shim rod withdrawal position for a given experiment.
The inspector determined that failure to have an adequate procedure for experiments was a violation of TS section 6.4.6 which requires in part that written procedures shall be adequate to assure the safety of operation of the reactor and shall be in effect for...
administrative controls for operations and maintenance and for the conduct of irradiations and experiments that could affect reactor safety or core reactivity. The inspector determined that the violation was a Severity Level 4 (SL IV) violation because of the ROs quick actions to immediately identify the issue and shut down the reactor, there were no actual safety consequences, the potential safety consequences were small because the issue involved a larger amount of negative reactor than expected introduced into the reactor, and the issue was reported to the NRC in a timely manner.
The inspector noted that the licensee found the cause of the issue to be an inadequate procedure that had not been revised since March 3, 2011, and took immediate steps to revise it. The inspector determined that this non-repetitive, licensee-identified, and corrected violation is a Non-Cited Violation (NCV), consistent with section 2.3.2.b of the Enforcement Policy (NCV 05000407/2023201-01).
c. Conclusion
The inspector determined that, with the exception of the violation discussed above, the license's program for conducting experiments and controlling irradiated
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products satisfied regulatory and TS requirements.
7. Design Changes
a. Inspection Scope (IP 69001, Section 02.08)
To determine whether modifications to the facility were consistent with 10 CFR 50.59 and TS section 6.2, the inspector reviewed:
- form UNEP-035R4, Audit and Review Program
- RSC meeting minutes for 2021, 2022, and to date in 2023
- UNEP maintenance log, which included various 10 CFR 50.59 screenings and evaluations
- various UNEP Job-Aids including 002R1, 10 CFR 50.59 Screening, and 003R1, 10 CFR 50.59 Evaluation
- the two most recent UUTR annual operating reports
b. Observations and Findings
The inspector noted that the licensee created a procedure outlining the 10 CFR 50.59 process which was detailed and included job-aids as a supplement. The inspector verified the changes to the facility that were proposed since the last inspection, were documented, screenings were completed, and evaluations were conducted.
c. Conclusion
The inspector determined that changes made at the facility during the past 2 years were completed in accordance with 10 CFR 50.59 and applicable licensee procedures.
8. Committees, Audits and Reviews
a. Inspection Scope (IP 69001, Section 02.09)
To verify that the licensee conducted reviews and audits as required by TS section 6.2 the inspector reviewed:
- RSC meeting minutes for 2021, 2022, and to date in 2023
- form UNEP-035R4, Audit and Review Program
- the two most recent UUTR annual operating reports
b. Observations and Findings
The inspector found that the RSC met as required by the TSs and considered the types of topics outlined therein. The inspector also found that the RSC provided guidance and direction for safe reactor operations and ensured suitable use and oversight of the reactor.
The inspector noted that the RSC, or individuals designated by the committee, completed audits of the facility operations, programs, and procedures. The inspector
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noted that audits were scheduled so that the various aspects of the licensee's operations and radiation safety program were reviewed at least annually. The inspector verified facility documents, plans, and major facility procedures were also reviewed annually.
The inspector confirmed that the security plan was reviewed biennially. The inspector noted that the reviews and audits were thorough, and the resulting findings were meaningful.
c. Conclusion
The inspector determined that review and oversight functions required by TS section 6.5 were completed by the RSC.
9. Maintenance Logs and Records
a. Inspection Scope (IP 69001, Section 02.11)
To verify that the licensee conducted the facility surveillance program in accordance with TS requirements, the inspector reviewed:
- UUTR console logbooks Nos. 42 and 43
- various UNEP equipment repair/maintenance reports
- UNEP maintenance log, which included various 10 CFR 50.59 screenings and evaluations, for the period from 2021 through 2023 to date
- various UNEP procedures and associated forms including UNEP-002R4, Biennial Fuel/Tank/Control Rod/Reflector Element Inspection; UNEP-020R14b, Monthly Inspection/Surveillance Procedure; and, UNEP-022R4, Maintenance Log
- the two most recent UUTR annual operating reports
b. Observations and Findings
(1) Routine Maintenance Review
The inspector confirmed that maintenance activities, including scheduled and unscheduled preventive and corrective activities, were controlled and documented.
The inspector found that all maintenance activities were completed in a timely manner. The inspector verified that, after all maintenance items were completed, system operational checks were performed to ensure the affected systems were operable before returning them to service. The inspector noted that when more extensive repairs were needed, these projects were reviewed using the 10 CFR 50.59 screening/evaluation process.
(2) Reactor Tank Repair
The inspector reviewed the circumstances surrounding a communication made by the licensee on March 31, 2023, to the NRC regarding a reactor pool leak at the UUTR. The UUTR staff personnel noted the reactor tank developed a leak of approximately 24 gallons per day (gals/day). The licensee also noted that the reactor tank is composed of two concentric cylinders. The inner tank is made of aluminum and contained the demineralized water surrounding the reactor core. The outer tank
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is made of steel and has a 2-foot space between the two tanks filled with sand. The licensee noted that there was no indication of leakage from the outer tank to the environment and the leakage does not reach or exceed any reporting criteria. A few days later the licensee noted that the leak rate increased to about 50 gals/day.
The licensee determined the most probable leak site would be a degraded weld presumably toward the bottom of the circumference of the tank (the point of highest pressure). To resolve the leak problem, the licensee applied two-part epoxy sealant material to the weld areas around the bottom three sections of the tank.
During this inspection, the inspector observed the contractor preparations and repair work on the tank. The inspector noted that proper work controls were established, and appropriate radiation protection controls were in place for the job. The inspector verified that the contractor crew worked to clean the weld areas and apply the two-part epoxy coating with the UUTR staff in an oversight role. Following completion of the initial coating, the licensee found that the tank leak rate appeared to be decreasing. At the completion of the inspection, the inspector noted that the repairs appeared to be successful, and the leak rate or evaporation rate had returned to what it had been before the leak occurred. The success of the repair project will need to be evaluated further during a future inspection.
The licensee was informed that the issue of the reactor tank repair and the complete stoppage of tank water loss due to leakage would be considered an Inspector Follow-up Item (IFI) and would be reviewed during a future inspection (IFI 05000407/2023201-02). In addition, an Unresolved Item (URI) is warranted to follow up on the possible impact the tank leak may have had on the facility and/or the surrounding environment and any potential violations that may have occurred as a result (URI 05000407/2023201-03).
c. Conclusion
The inspector determined that maintenance activities were ongoing at the facility.
Reactor tank repair was reviewed during the inspection, but the results are still being analyzed and will be reviewed during a subsequent inspection.
10.Fuel Handling Logs and Records
a. Inspection Scope (IP 69001, Section 02.12)
The inspector reviewed selected aspects of the following to verify adherence to fuel handling and inspection requirements specified in TS sections 3.1 and the applicable procedures:
- UNEP core log
- UUTR console logbooks Nos. 42 and 43
- UNEP fuel procedures and log - aluminum and stainless steel
- various procedures and associated forms including UNEP-002R4, Biennial Fuel/Tank/Control Rod/Reflector Element Inspection; UNEP-005R5, Core Change and Critical Fuel Loading; and, UNEP-018, Fuel Element Inventory Sheet
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- UUTR core (element location sheet) and core configuration 24C
- the two most recent UUTR annual operating reports
b. Observations and Findings
(1) Routine Fuel Inspections
The inspector confirmed that the licensee maintained the required records of the various fuel movements that were completed. The inspector noted that the current UUTR core was designated as core configuration 24C. The inspector verified that fuel handling procedures provided a specific method to handle and check fuel consistent with the requirements and provisions of TS sections 3.1.4 and 3.1.6. The inspector noted that the fuel was required by procedure to be examined biennially.
The inspector verified that all but two of the various elements were last inspected in the May-June 2022 time frame as discussed in the following subsection. The inspector noted that fuel handling tools and equipment were controlled and secured when not in use.
(2) Failure to Inspect Two Fuel Elements
On May 31, 2023, the licensee informed the NRC about an issue concerning fuel element inspections at the facility. The issue developed as indicated below.
Because of the reactor tank leak problem discussed above, the licensee decided to perform an out of cycle biennial fuel inspection one year early to facilitate the tank repair outage. While inspecting the various fuel elements on the afternoon of May 31, 2023, an RO identified two fuel elements that had not been inspected during the routine fuel inspection in the May-June time frame of 2022 as required. The licensees TS section 4.1 requires, in specification 5, that all fuel elements be inspected for transverse bend, length, and cladding defect every 2 years. The licensee subsequently inspected the two fuel elements, and no problems were identified. The licensee notified the NRC of this issue through an email to the Project Manager and the facility inspector. The inspector noted that this issue did not require a special report to the NRC and the NRC determined that the issue would be reviewed during the next routine inspection.
The inspector reviewed this issue during this inspection, reviewed the licensees corrective actions, and considered the safety significance of the problem. The inspector verified that the license identified the issue with fuel inspection and then conducted an inspection of all fuel elements including the two fuel elements that were one year past due for an inspection as required by TS section 4.1.5. The licensee determined both elements were in satisfactory condition and were acceptable for continued use. Through records review and discussions, the inspector confirmed the licensees assessment. The inspector also found that the licensee intends to improve their fuel inspection process by revising the fuel inspection procedure, UNEP -002, Biennial Fuel / Tank / Control Rod / Reflector Element Inspection, by adding an audit step that will require two individuals to perform an audit of the operations logbook and the fuel element logbooks to ensure the proper elements are inspected.
The inspector reviewed the licensees TSs and confirmed that one of the Limiting
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Conditions of Operation (LCOs), as stated in Section 3.1.6, Fuel Parameters, requires that the reactor shall not be operated with damaged fuel elements and specifies that the elements be checked for transverse bend, length, and cladding defects. The licensee completed an inspection of all the fuel elements on May 31, 2023, which confirmed that the fuel was not damaged during the period from May-June 2022 to May 2023. The licensee was in compliance with the LCO listed in TS Section 3.1.6 for the various listed fuel parameters during the period from May 2022 to May 2023.
The inspector also noted that NUREG 1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Chapter 14, Technical Specifications, Appendix 14.1, Format and Content of Technical Specifications for Non-Power Reactors, Section 4, Surveillance Requirements, Subsection 4.1, Reactor Core Parameters, Paragraph (6), Fuel Parameters, states that All TRIGA fuel should be inspected for damage and all TRIGA non-instrumented fuel should be measured for length and bend at the following frequencies: For non-pulsing TRIGA reactors, the fuel should be inspected and measured on a 5-year cycle. Approximately 20 percent of the fuel could be inspected and measured annually. If an annual inspection identifies damaged fuel, then the entire core should be inspected and measured. While the licensee did not meet the requirements of their TSs, they were within the suggested guidelines provided in NUREG 1537 because they do not pulse their reactor.
The inspector determined that failure to inspect all fuel elements every 2 years was a violation of TS section 4.1.5. The inspector determined that this violation was a SL IV violation because the subsequent fuel inspection indicated there were no problems with the fuel, the potential safety consequences of the two fuel elements are small, and the licensee notified the NRC of the issue. Also, the fuel was inspected within the time frame suggested by NUREG 1537. The inspector noted that the licensee identified the cause of the problem and took immediate corrective action to inspect the two elements that were missed and the remainder of the elements in the core as well. The inspector determined that this non-repetitive, licensee-identified, and corrected violation is an NCV, consistent with section 2.3.2.b of the Enforcement Policy (NCV 05000407/2023201-04).
c. Conclusion
With the exception as discussed above, the inspector determined that reactor fuel movements and inspections were completed and documented in accordance with applicable procedures and TSs. The inspector determined that the licensee failed to inspect all the fuel biennially as required by TS section 4.1.
11.Follow-up On Previously Identified Items
a. Inspection Scope (IP 92701)
The inspector reviewed the licensees actions taken in response to previously identified items.
b. Observation and Findings
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IFI 05000407/2021201-02 - Follow-up on the licensees actions to revise procedure UNEP-002R4, Biennial Fuel/Tank/Control Rod/Reflector Element Inspection, to include maintenance actions needed during control rod inspection.
The inspector reviewed the circumstances surrounding a Special Report issued by the licensee, dated April 2, 2020, in accordance with UUTR TS section 6.7.2 item 1.5 documenting a component malfunction. On March 30, 2020, facility personnel completed the routine monthly inspection of various reactor components and systems and initiated a standard reactor startup and termination checklist to test all systems. One portion of this test was to withdraw the safety control rod to 100 percent and then disrupt the power to the magnet causing the rod to drop. The licensee staff noted that the safety rod did not drop as expected. After further review, the safety rod was disassembled, and rust and calcium deposits were noted and subsequently removed. Following these corrective actions, the safety rod was inspected, reassembled, and reinstalled in the core. Testing and calibration of the safety rod indicated that the malfunction was resolved, and the rod functioned properly.
During the 2021 inspection, the inspector reviewed this issue. In their letter to the NRC concerning the component malfunction, the licensee indicated that the procedure involving the inspection of the control rods, UNEP-002R4, Biennial Fuel/Tank/Control Rod/Reflector Element Inspection, would be revised to include checking for debris, binding, rubbing, or misalignment of the control rod drives that might prevent the control rods from dropping. The licensee was informed that the revision of the procedure would be considered an IFI.
During this inspection, the inspector determined that this revision was still pending. The Reactor Supervisor indicated that the procedure would be revised and presented to the RSC by the next meeting of the committee. This issue remains open.
c. Conclusion
The inspector determined that the procedure referenced in IFI 05000407/2021201-02 was not revised to date and the issue remains open.
11.Exit Interview
The inspection scope and results were summarized on July 13, 2023, with licensee representatives. The inspector discussed the findings for each area reviewed. The licensee acknowledged the findings and identified the console operating procedure as the only item reviewed by the inspector that was proprietary.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee Personnel
A. Allison Reactor Supervisor and Senior Reactor Operator T. Goodell Senior Reactor Operator C. Olson Reactor Operator Director of the Utah Nuclear Engineering Program
INSPECTION PROCEDURES USED
IP 69001 Class II Research and Test Reactors IP 92701 Follow-up on Previously Identified Items
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000407/2023201-01 NCV: Failure to have an adequate procedure for requesting irradiations and experiments. 05000407/2023201-02 IFI: Follow-up on the reactor tank repair and the complete stoppage of tank water loss due to leakage.05000407/2023201-03 URI: Follow-up on the possible impact the tank leak may have had on the facility and/or the surrounding environment and any potential violations that may have occurred as a result.05000407/2023201-04 NCV: Failure to all fuel elements every two years as required by TS section 4.1.5.
Closed
05000407/2023201-01 NCV: Failure to have an adequate procedure for requesting irradiations and experiments. 05000407/2023201-03 NCV: Failure to inspect all fuel elements every 2 years as required by TS section 4.1.5.
Discussed
05000407/2023201-02IFI: Follow-up on the licensees actions to revise procedure UNEP-002R4, Biennial Fuel/Tank/Control Rod/Reflector Element Inspection, to include maintenance actions needed during control rod inspection.
Attachment