ML25272A191
| ML25272A191 | |
| Person / Time | |
|---|---|
| Site: | Idaho State University |
| Issue date: | 09/29/2025 |
| From: | Dunzik-Gougar M Idaho State University |
| To: | Miller A Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML25272A191 (1) | |
Text
September 29, 2025 ATTN: Mr. Andrew Miller U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Dear Mr. Miller
Subject:
Explanation of Exception to Quarterly OP-1 Performance in Requalification Plan Requirements for the AGN-201 at Idaho State University The Idaho State University Requalification Plan normally requires the performance of facility procedure Operating Procedure - 1 (OP-1) every quarter, which includes a complete start-up with pre-operational checks and shutdown of the AGN-201 reactor. The ISU AGN-201 has been in extended maintenance for the entirety of Q3 2025 and part of Q2 2025. The requirement in the Requalification Plan is in excess of the minimum operational expectations in 10.CFR.55.59(e)(3)(i), and is explicitly allowed when the reactor is inoperable in Section IV(c) of the facility requalification plan.
This letter formally documents the facilitys utilization of this exception, and additional steps taken to ensure operator qualification is maintained per 10.CFR.55.59.
Applicable Regulatory Requirement and
Background:
ISU AGN-201 Requalification Plan Section IV On-the-Job Training requires all licensed senior reactor operators and reactor operators to perform a complete start-up with pre-operational checks and shutdown using facility procedure OP-1 every quarter. This frequency is in excess of 10 CFR 55.59(e) requirements, which state in Section 3(i) Items described in paragraphs (c)(3)(i) (A) through (L) of this section must be performed annually; all other items must be performed on a two-year cycle. The facility is In compliance with 10.CFR.55.59, as all currently licensed reactor operators and senior reactor operators performed at least one complete start-up with pre-operational checks and shut-down per facility operating procedure OP-1 during the 2025 calendar year. The exception would apply to our facility requirement to perform OP-1 each quarter, which is explicitly allowed in Section IV(c) of the Requalification Plan when the reactor is inoperable.
To ensure all operations maintain a proficient and active license status despite not performing OP-1 this quarter, ISU has required all operators to perform On-The-Job training in the form of technical walk-throughs during Q3 2025 to observe the progress of the maintenance and remain apprised of the facility status. In addition, all operators earned their mandatory 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of quarterly licensed activities through other approved activities in the ISU Requalification Plan, and no actively licensed operators are delinquent in their requalification progress. The reactor is expected to be operational in Q4 2025, and all licensed Reactor Operators and Senior Reactor Operators will perform a complete OP-1 as required in our requalification plan. Additional On-The-Job training will be provided prior to operation of the reactor to ensure all operators are up-to-date on facility status post-maintenance. No exceptions from the Requalification Plan are expected in Q4 or after.
If you have any questions concerning this submittal, please contact the Reactor Supervisor Mr.
Theodore Pollock at 518-577-8708 or at theodorepollock@isu.edu or the Training Manager Ms Mackenzie Gorham at 208-840-0732 or mackenziegorham@isu.edu.
Sincerely, Mary Lou Dunzik Gougar Reactor Administrator cc. electronic submission to NRC mldg@isu.edu (208) 569-9915 Mary Lou Dunzik-Gougar Digitally signed by Mary Lou Dunzik-Gougar Date: 2025.09.29 09:01:33 -06'00'