ML25014A433

National Institute of Standards and Technology - U.S. Nuclear Supplemental Inspection Reports

ML25014A433
Person / Time
Site:	National Bureau of Standards Reactor
Issue date:	02/03/2025
From:	Jeremy Bowen NRC/NRR/DANU/UNPO
To:	Adams J US Dept of Commerce, National Institute of Standards & Technology (NIST)
Lin B
References
IR 2024201
Download: ML25014A433 (1)

Text

Dr. James Adams, Director National Institute of Standards and Technology NIST Center for Neutron Research U.S. Department of Commerce 100 Bureau Drive, Mail Stop 8461 Gaithersburg, MD 20899-8461

SUBJECT:

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY - U.S. NUCLEAR REGULATORY COMMISSION 3rd and 4th QUARTER 2023 SUPPLMENTAL INSPECTION REPORT NO. 05000184/2023202 and 1st and 2nd QUARTER 2024 SUPPLEMENTAL INSPECTION REPORT NO. 05000184/2024201

Dear Dr. Adams:

From July 1, 2023 - December 31, 2023, and January 1, 2024 - June 30, 2024, the U.S.

Nuclear Regulatory Commission (NRC) staff conducted an inspection at the National Institute of Standards and Technology (NIST) Center for Neutron Research facility in accordance with the NIST Supplemental Inspection Plan dated August 1, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22206A008). The NRC is implementing the supplemental inspection plan based on the violations identified in the NRC special inspection report dated March 16, 2022 (ML22066B312), and the confirmatory order (CO) dated August 1, 2022 (ML22202A423). The supplemental inspections covered in the enclosed report reviewed and assessed the licensees implementation of corrective actions. The enclosed report presents the results of that inspection, which were discussed on August 21, 2024, with you and members of your staff.

The supplemental inspection plan consists of activities specified in the Inspection Manual Chapter (IMC) 2545, Research and Test Reactor Inspection Program, additional inspection activities necessary to determine that the licensee has implemented adequate corrective actions, and inspection activities to support confirmation that the licensee has met the requirements of the CO. The NRC conducted supplemental inspections identified in this report using the following procedures:

• Inspection Procedure (IP) 69006, Class I Research and Test Reactors Organization and Operations and Maintenance Activities

• IP 69007, Class I Research and Test Reactor Review and Audit and Design Change Functions

• IP 69008, Class I Research and Test Reactor Procedures

• IP 69009, Class I Research and Test Reactor Fuel Movement

• IP 40100, Independent Safety Culture Assessment Followup

• IP 93100, Safety-Conscious Work Environment Issue of Concern Followup February 3, 2025

J. Adams 2

• IP 92702, Followup on Traditional Enforcement Actions Including Violations, Deviation, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders The NRC staff will continue to conduct supplemental inspections, in accordance with the supplemental inspection plan, to provide increased post-restart oversight until the NRC staff determines that reasonable assurance for the safety of the NIST test reactor operations can be achieved through routine inspections, in accordance with IMC 2545.

The supplemental 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 inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. No response to this letter is required.

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 Publicly Available Records component of the NRCs document system ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, Jeremy S. Bowen, Director Division of Advanced Reactors and Non-Power Production and Utilization Facility Office of Nuclear Reactor Regulation Docket No. 50-184 License No. TR-5

Enclosure:

As stated cc w/enclosure: GovDelivery Subscribers Reisi-Fard, Mehdi signing on behalf of Bowen, Jeremy on 02/03/25

ML25014A433 NRC-002 OFFICE NRR/DANU/UNPO NRR/DANU/UNPO NRR/DANU/UNPO/LA OE/AT/TL NAME BLin KRoche NParker DWillis DATE 1/16/2025 1/16/2025 1/17/2025 1/17/2025 OFFICE NRR/DANU/UNPO/BC NRR/DANU/D NAME TBrown JBowen(MReisi-Fard for)

DATE 1/22/2025 2/3/2025

Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No.:

50-184 License No.:

TR-5 Report Nos:

05000184/2023202 and 05000184/2024201 Licensee:

National Institute of Standards and Technology Facility:

National Bureau of Standards Test Reactor Location:

Gaithersburg, Maryland Dates:

July 31, 2023 - December 31, 2023 January 1, 2024 - June 30, 2024 Inspectors:

Brian Lin, Reactor Inspector Kevin Roche, Reactor Inspector Dori Willis, Safety Culture Assessor Carleen Parker, Safety Culture Assessor Approved by:

Jeremy S. Bowen, Director Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation EXECUTIVE

SUMMARY

National Institute of Standards and Technology National Bureau of Standards Test Reactor Supplemental Inspection Report Nos. 05000184/2023201 and 05000184/2024201 The U.S. Nuclear Regulatory Commissions (NRC) program for overseeing the safe operation of research and test reactors is described in Inspection Manual Chapter (IMC) 2545, Research and Test Reactor Inspection Program. A supplemental inspection was established in accordance with the National Institute of Standards and Technology (NIST) Supplemental Inspection Plan issued on August 1, 2022 (Agencywide Documents Access and Management System Accession No. ML22206A008). Inspectors conducted the supplemental inspection in accordance with the objectives described in the plan:

assure corrective actions to address the seven special inspection violations are timely, effective, and sustained assure restart readiness activities are comprehensive and necessary activities to restart and safely operate are completed assure corrective actions completed and planned direct timely actions to effectively address and correct issues and preclude re-occurrence.

This supplemental inspection report documents the NRC staffs inspection activities in accordance with the supplemental inspection plan objective areas outlined above. No violations were identified in this report.

For a summary of the status supplemental inspection objectives see table 1 in appendix A of this report.

REPORT DETAILS

1. Introduction NIST operates the National Bureau of Standards test reactor (hereinafter the NIST test reactor) at the NIST Center for Neutron Research (NCNR) located on the NIST campus in Gaithersburg, Maryland. The NIST test reactor is a heavy-water (D2O)- moderated-and-cooled, enriched-fuel, tank-type reactor designed to operate at 20 megawatts thermal power. The facility normally operates continuously during a seven-week operational cycle that consists of approximately 38 days of operation, followed by 10-day refueling and maintenance outages. The facility remained shut down following the February 3, 2021, event and restarted on March 16, 2023, intermittently at lower reactor power levels. On July 18, 2024, the facility shutdown and entered an outage period to prepare for reactor vessel cleaning and other scheduled maintenance items.

This supplemental inspection report describes the inspections conducted from July 1, 2023, through June 30, 2024. The NRC staff will update the supplemental inspection plan, continue supplemental inspections, and issue subsequent supplemental inspection reports. The supplemental inspection plan lists the objectives that will be conducted at the NCNR test reactor until the NRC staff determines routine inspections in accordance with the NRC IMC 2545 are adequate to ensure safety.

2. Emergency Plan and Event Response

a. Observations and Findings The inspectors did not review this area during this period and will continue to review the emergency plan and event response as part of the continued supplemental inspections.

An exercise is scheduled in 2025.

b. Conclusion

The previously reviewed supplemental inspection objectives documented in the 4th quarter 2022 report remain closed as noted in table 1 of appendix A. One objective remains open and will be inspected at a later date.

3. Fuel Handling

a. Observations and Findings The inspectors observed several fuel operations. Specifically, the inspectors observed fuel transfer system maintenance and defueling activities. The inspectors observed several shifts and training sessions focusing on element latch verification, fuel handling, and fuel element transfer. The inspectors noted that the licensee staff followed Administrative Rule 5.0, Procedure Use and Adherence, guidance on continuous use of procedures during the defueling evolution and that all workers were trained in safe fuel movement operations. The inspectors will continue to review the licensees training and implementation of the use and adherence to procedures to ensure the licensees corrective actions are sustained to inform the NRC staffs decision to restore the routine inspection program.

b. Conclusion

The inspectors concluded that the refueling/fuel handling supplemental inspection objectives in table 1 of appendix A remain closed. The inspectors will continue to monitor the licensees performance in this area. One objective remains open and will be inspected at a later date.

4. Reactor Startup

a. Observations and Findings Since March 9, 2023, NIST has operated intermittently at low power for operator requalification and maintenance activities. The inspectors observed the licensee briefing and conducting pre-critical reactor protection system checks that ensure the reactor safety systems were functioning in accordance with technical specification 4.1.1. The inspectors found the surveillance paperwork was consistent with the procedures and documented the satisfactory completion of the surveillances.

The inspectors observed the licensees pre-evolution briefs and noted that the briefs were thorough and included adequate time for questions to be addressed by the operator staff. In addition, the inspectors noted that the operators consistently referenced procedures and tracked the completion of all steps. Operators-in-training were coached by the senior reactor operators who challenged the trainees knowledge.

The effluent radiation levels in the reactor building continue to be higher than pre-accident radiation levels. Despite these higher-than-normal radiation levels, the inspectors determined that they are below the licensees lowered effluent monitoring setpoints that were conservatively set to address operations with fuel debris. On August 9, 2023, a loss of ventilation caused by a loss of power to the facility resulted in minor contamination of several NCNR personnel. The event highlighted the need to resolve helium leaks around the refueling plug and other penetrations that allow fission products gasses to escape from the reactor vessel. Effluent sample results were reviewed and found within regulatory limits. Since the August 2023 loss of ventilation event, the licensee mitigated the rise in radiation and contamination levels by conservatively limiting reactor power levels to 200 kilowatts during operator requalification training.

b. Conclusion

The inspectors observed that the precritical and reactor startup checklists continue to be adequate to ensure safe operation of the facility as observed during the reactor startup.

The conservative limits implemented during the reactor operations limited effluent radiation levels in the reactor building but did not provide sufficient data to verify that upgrades to the ventilation system were effective in limiting fission product gas release.

The helium leaks around the reactor vessel will be addressed prior to reactor vessel cleaning of the remaining fission products. The inspectors concluded previously reviewed supplemental inspection objectives documented in the 4th quarter 2022 report remain closed as documented in table 1 in appendix A. Due to the higher than pre-accident radiation effluent levels and current reactor vessel cleaning, the inspectors will continue to monitor the licensees performance of this area in future supplemental inspections.

5. Operator Licensing

a. Observations and Findings The inspectors observed training sessions on operator proficiency of reactor operations, fuel handling, refueling, and latch verification. Just-in-time training was conducted during extended periods of shut down for maintenance and holiday standdown. The licensee recently updated their operator requalification plan awaiting review and approval by the operator licensing examiners. The inspectors will continue to review operator licensing as part of the continued supplemental inspections.

b. Conclusion

The inspectors concluded previously reviewed supplemental inspection objectives documented in the 4th quarter 2022 report remain closed as noted in table 1 of appendix A. Due to reactor vessel cleaning activities that will be completed in 2025, the inspectors will continue to monitor the licensees performance in this area. Two objectives remain open and will be inspected at a later date.

6. Management Oversight

a. Observations and Findings The inspectors observed portions of the licensees training on reactor start up operations and fuel handling. Licensee management oversight was appropriate to ensure policies and procedures were discussed and questions and concerns were addressed. The inspectors additionally observed licensee management engage personnel with entering technical issues in their corrective action program (CAP).

The inspectors additionally observed and identified an operator not meeting all precautionary requirements of a radiation work permit for work in a contaminated area located in the C-100 level. The licensee verified there was no spread of contamination into uncontrolled spaces. The incident was evaluated and discussed with the operator by senior NCNR management. The licensee entered the details of the incident into the CAP and discussed the incident at an all-hands meeting with the Director of NCNR with the focus on safety culture and procedural adherence. The inspectors determined this incident to be isolated and not representative of the safety culture at NCNR.

Management oversight of procedure adherence continues to trend positively with appropriate observations completed during routine and infrequent activities.

b. Conclusion

The inspectors concluded previously reviewed supplemental inspection objectives documented in the 4th quarter 2022 report remain closed as noted in table 1 in appendix A. Inspectors will continue to monitor the licensees performance in this area in future supplemental inspections.

7. Corrective Actions

a. Observations and Findings In accordance with the CO, the licensee agreed to implement the CAP using a staggered approach completing the final stage on March 28, 2023. In June 2024, the licensees contractor completed a second independent assessment of the CAP. The contractor identified areas for improvement with a focus on increasing licensee staff to augment training on the CAP to ensure individuals identify and report issues that require further review, evaluation, or action for resolution.

During the inspection period, the inspectors observed an increased number of submissions into the CAP. Management continues to define and communicate standards that fosters participation in the CAP. Additionally, the focus on utilizing the CAP progressed with increasing questioning attitude and improvements of self-identified procedure and engineering deficiencies. The inspectors also noted that the independent assessment and resulting corrective actions are not completed, and the inspectors will continue to follow implementation of the CAP.

The inspectors verified the installation of a carbon dioxide isolation system by reviewing the engineering change notice and test procedure that verifies its operation. The inspectors walked the isolation system down to verify that it was installed as described in the engineering change notice. The inspectors determined that this supplemental inspection item is closed as reflected in table 1 of appendix A.

b. Conclusion

The inspectors concluded previously reviewed supplemental inspection objectives documented in the 4th quarter 2022 report remain closed as noted in table 1 in appendix A. Two objectives remain open, and the inspectors will continue to evaluate the licensees CAP in future inspections.

8. Safety Committee Oversight

a. Observations and Findings The inspectors did not review this area during the reporting period and will review observations from the Safety Assessment Committee (SAC) meeting at a later date.

b. Conclusion

During this inspection period, the inspectors did not inspect the open objective of reviewing the SAC recommendations disposition. The inspectors will review this item during a later inspection.

9. Procedures

a. Observations and Findings The inspectors observed several evolutions and identified several procedure changes were completed prior to implementation. Despite improvements in procedure quality, the process to review and approve procedures remain an area for improvement.

During the repair of the clutch of the #3 shim arm, the licensee determined that previous repairs were not adequate to prevent recurrence. The licensee determined that the #3 shim arm required re-alignment after several test runs of the shim arm drive system were reviewed at 100x speed. The clutch was observed to lose alignment over time and was not observed during normal operations. The licensee identified that procedures needed to be written to identify misalignment and alignment of the shim arm gear box.

An extent of condition was performed on shim arms #1, #2, and #4 and no intervention was required.

The inspectors observed improvement of the procedure process to ensure effective communication and implementation. This improvement contributed to the repair and documentation of the recent maintenance challenges of the shim arm system. The licensee acknowledged that progress continues to improve foundational knowledge and documentation of equipment and procedural issues.

b. Conclusion

The inspectors will continue to evaluate the licensee program to write, approve, and use procedures. The inspectors concluded the previously reviewed supplemental inspection objective remains closed as noted in table 1 of appendix A. One inspection objective in this area remains open and will be inspected at a later date.

10. Design Change Process

a. Observations and Findings The inspectors did not review this area and will continue to review the design change process as part of the continued supplemental inspections.

b. Conclusion

The inspectors concluded the previously reviewed supplemental inspection objective remains closed as noted in table 1 of appendix A. Two objectives remain open and will be inspected at a later date.

11. Safety Culture

a. Observations and Findings On February 26, 2024, the NRC staff conducted a pulse of the nuclear safety culture within the NIST NCNR organization. The staff reviewed the licensees progress on implementation of the corrective actions identified as part of the independent safety culture assessment provided in the July 26, 2023 (ML23207A039) letter to the NRC transmitting the assessment. The staff also reviewed the licensees implementation of related safety culture requirements as described in the NRCs CO.

Leadership Safety Values and Actions Based on the interviews and observations, the NRC staff continue to identify weaknesses under Leadership Safety Values and Actions in the attribute of resources.

Specifically, the NRC staff concluded that resources continue to be a challenge and an area for improvement for the NCNR and that NCNR continued to lack personnel in operations, training, and personnel to support prompt implementation of the corrective actions associated with the nuclear safety culture assessment. The NRC staff noted that NCNR has made key personnel selections for managers of the CAP program, and the engineering department. The NRC staff also determined that actions are being taken within those programs that seem to be viewed favorable by the personnel interviewed, such as a defined work plan for each engineer in the engineering department.

Work Processes Based on the interviews, the NRC staff determined that NCNRs actions in the area of work processes, specifically updating procedures and ensuring procedural adherence, is viewed by the NCNR personnel as having improved. However, some personnel commented that the new procedures have not been fully used and validated because NCNR has not yet been able to operate above 1MW power.

Self-Assessment NCNR continues to employ the support of contractors to complete the corrective actions identified by the nuclear safety culture assessment. The NRC staff reviewed the records associated with the training of leadership as required in the CO, section V.7.b. The training was completed with the support of the nuclear consultant.

Environment for Raising Concerns (Safety Conscious Work Environment)

The NRC staff determined that the environment for raising concerns at NCNR has remained consistent. Specifically, all personnel stated they would raise a concern. Most personnel stated that management is very engaged in resolving concerns as concerns are raised. However, some personnel stated that they were not confident that all concerns would be resolved, and they did not always receive feedback on the resolution of concerns. The NRC staff noted that NCNR has created a process for an Employee Concerns Program (ECP) and selected an ECP manager, but the ECP program has not yet been fully implemented. The NRC staff also determined that the corrective action program has not been fully implemented but actions have been taken to continue progress.

b. Conclusion

The NRC staff determined that the licensee has a plan to implement the corrective actions associated with the safety culture assessment. Additionally, the NRC staff concluded that the licensee is making progress on safety culture related requirements from the CO, such as developing an Employee Concerns Program and a Corrective Action Program, but several of these items are still not fully implemented.

The inspectors concluded the previously reviewed supplemental inspection objectives remain closed as noted in table 1 in appendix A. The inspectors noted that the licensees second independent safety culture assessment was completed and submitted to the NRC on June 7, 2024 (ML24166A197), along with a letter in which NIST committed to address areas for improvements and in need of attention. Inspection of the second independent safety culture assessment will be scheduled at a later date. Two objectives remain open.

12. Material Control and Accounting

a. Observations and Findings The inspectors did not review this area but will continue to review material control and accounting as part of the continued supplemental inspections.

b. Conclusion

The previously reviewed supplemental inspection objective remains closed as noted in table 1 of appendix A. The inspectors will continue to monitor the licensees performance in this area.

13. Exit Meeting The inspectors discussed the inspection with the licensee at the conclusion of this portion of the special inspection on August 11, 2024.

REFERENCES Administrative Rule (AR) 4.0, Fuel Manipulation Proficiency Requirements, Revision 1 AR 1.0, Conduct of Operations, Revision 2 AR 5.0, Procedure Us and Adherence, Revision 2 AR 5.4, Observation Program and Checklist, August 21, 2022 AR 7.1, Conduct of System Review Teams, dated August 24, 2022 AR 7.1.2, System Walkdown Guidelines, August 24, 2022 Operating Instruction (OI) 1.1.0, Reactor Startup Checklist, Revision 6 OI 1.1.1, Reactor Startup Up to 20 MW, Revision 3 OI 1.1.2, Low Power Reactor Startup, Revision 1 OI 1.1.5, Reactor Normal Operation, Revision 1 OI 4.2.9, CO2 Gas Valve Lineup Checklist, Revision 1 OI 6.1.3, Spent Fuel Transfer to the Storage Pool, Revision 3 OI 6.1.7, Rotational Latch Check, Revision 3 OI 6.1.8, Transfer of Elements from the Vessel, Revision 3 OI 6.3.1, 1/M Core Loading and Approach to Critical, Revision 2 Maintenance Procedure (MP) 5.68.03, ECN 1260-Automatic Closure of the CO2 Valve COV-8 Upon Major SCRAM, Revision 1 MP 5.83, Removal of Broken Screw #4 Shim Mechanical Seal, Revision 1 MP 5.79, Shim Arm Maintenance, Removal, and Replacement, Revision 1 MP 5.79.1, Shim Arm Maintenance: Overview, Tool List, Lockout Tagout, and Setup, Revision 1 MP 5.79.2, Shim Arm Maintenance: Drive Mechanism Removal and Installation, Revision 2 MP 5.79.3, Shim Arm Maintenance: Mechanical Shaft Seal Removal and Installation, Revision 1 MP 5.79.4, Shim Arm Maintenance: Restoration and Testing, Revision 1 MP 5.86.1, Shim Arm Drive Alignment Procedure, Revision 1 Technical Specification Procedure (TSP) 4.1.2, Core Excess Reactivity/Shutdown Margin Reactivity Worth of each Shim Arm and Reg Rod, Revision 2 TSP 4.4(3), Test to be Performed after Additional, Modification, or Maintenance has been made to Confinement, Revision 1 NIST Test Reactor Memo: Retest of Shim Arm #3 Drive System After Clutch Alignment

Attachment PARTIAL LIST OF PERSONS CONTACTED Licensee J. Adams Director T. Newton Deputy Director R. Strader Chief, Reactor Operations D. Sahin Chief, Reactor Engineering S. Dewey Chief, Health Physics D. Griffin Senior Reactor Operator J. Seiter Senior Reactor Operator, Training Coordinator A. Gahan Chief, Aging Reactor Management S. MacDavid Supervisory Electronics Technician D. Mattis Engineer INSPECTION PROCEDURES USED IP 69006 Class I Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007 Class I Research and Test Reactor Review and Audit and Design Change Functions IP 69008 Class I Research and Test Reactor Procedures IP 69009 Class I Research and Test Reactor Fuel Movement IP 40100 Independent Safety Culture Assessment Follow IP 92702 Followup on Traditional Enforcement Actions Including Violations, Deviation, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders IP 93100 Safety-Conscious Work Environment Issue of Concern Followup ITEMS OPENED, CLOSED, AND DISCUSSED Opened:

None Closed:

None Appendix A: Table 1 STATUS ACTIVITY PRE-STARTUP PROCEDURE CLOSURE REPORT Emergency Plan / Event Response Closed Evaluate adequacy of emergency response equipment identified in the Emergency Plan Yes IP 69011 4Q2022 Closed Evaluate adequacy of emergency plan implementation procedures Yes IP 69011 4Q2022 Open Observe implementation of emergency plan procedures No IP 69011 TBD Closed Review availability of items or systems for operators to check prior to control room evacuation No IP69011 4Q2022 Closed Review availability of post-evacuation checklist No IP69011 4Q2022 Closed Evaluate adequacy of guidance in Emergency Instructions for confinement re-occupation Yes IP69011 4Q2022 Refueling / Fuel Handling Closed Evaluate adequacy of fueling and defueling procedures Yes IP69009 4Q2022 Closed Observe implementation of fueling procedures Yes IP69009 4Q2022 Closed Observe implementation of defueling procedures No IP69009 4Q2022 Closed Evaluate adequacy of procedures used for latch checking Yes IP92702 4Q2022 Closed Observe implementation of procedures for latch checking Yes IP92702 4Q2022 Open Evaluate adequacy of loaded restart core for consistency with technical specifications and analysis Yes IP92702 TBD Startup Closed Evaluate adequacy of reactor startup procedures determined necessary for restart Yes IP69008 4Q2022 Closed Observe implementation of reactor startup procedures Yes IP69008 4Q2022 Closed Review pre-critical start-up procedures Yes IP69008 4Q2022 Operator Licensing Closed Evaluate adequacy of proficiency training of reactor operations personnel identified to be completed prior to startup (including fuel handling, refueling and latch checking proficiency of operators)

Yes IP69008 4Q2022 Open Evaluate adequacy of licensed operator proficiency training No IP69003 TBD Open Observe implementation of licensed operator proficiency training No IP69003 TBD Closed Evaluate adequacy of operator training on off-normal conditions during startup and operations conditions Yes IP92702 4Q2022 Management Oversight Closed Evaluate adequacy of qualification training for supervisors overseeing refueling operations Yes IP92702 4Q2022 Closed Evaluate adequacy of policies and procedures in place to ensure training of Reactor Operations and Engineering personnel on procedure adherence Yes IP92702 4Q2022 Corrective Actions Open Evaluate program to ensure expectations, processes, and procedures are in place to identify and implement safety improvements No IP92702 TBD Open Evaluate the adequacy of corrective actions for re-evaluated root cause analysis performed with emphasis on nuclear safety culture No IP92702 TBD Closed Confirm primary system characterization/readiness following fuel debris cleanup Yes IP92701 4Q2022 Closed Confirm that the appropriate shielding is in place to ensure safe access for maintenance Yes IP92701 4Q2022 Closed Confirm consideration of carbon dioxide build up potential in safety documentation and emergency plan No IP92701 TBD Closed Review root cause of #2 shutdown pump failure and corrective actions, including evaluation of the extent of condition No IP92701 4Q2022 Safety Committee Oversight Open Review disposition of safety assessment committee recommendations No IP69007 TBD Procedures Open Evaluate program and processes in place to ensure quality of written procedures, to ensure procedures can be effectively executed, and to ensure procedures are periodically evaluated to implement improvements No IP69009 TBD Closed Evaluate startup procedures for consistency with INPO-1103, Guideline for Excellence in Procedure and Work Instruction Use and Adherence Yes IP92702 4Q2022 Closed Evaluate reactor startup procedures to instruct operators to identify abnormal fluctuations in nuclear instrumentation Yes IP92702 4Q2022 Design Change Process Closed Review refueling tool wear and replacement program No IP69008 4Q2022 Open Review change process program and procedures for compliance Title (10 CFR) of the Code of Federal Section 50.59 No IP69008 TBD Open Evaluate effectiveness of Engineering Change Management Program for ensuring changes are made consistent with 10 CFR 50.59 No IP92701 TBD Safety Culture Closed Conduct safety-conscious work environment follow-up inspection prior to startup Yes IP93100 4Q2022 Closed Conduct safety culture inspection following 3rd party 1st assessment No IP93100 4Q2022 Open Conduct safety culture inspection following 3rd party 2nd assessment No IP93100 TBD Open Conduct safety culture inspection following 3rd part 3rd assessment No IP93100 TBD Material Control and Accounting IP85102 Closed Evaluate adequate implementation of nuclear material accounting for damaged fuel element No IP92701 4Q2022