ADMIN
ADMIN-1 NETL Procedure Control
1.0 PURPOSE
This procedure provides a standard format and establishes administrative control for the preparation, review, modification, and approval of required NETL procedures.
1.1 Discussion
The NETL facility license R-129 Technical Specifications (TS ref. 1) require that written operating procedures be prepared, reviewed, and approved by the Director or a Supervisory Senior Reactor Operator (SSRO) and the Reactor Oversight Committee (ROC) for the safe operation, maintenance, surveillance, and administrative control of the NETL reactor and facility. The Emergency Response Plan and Physical Security Plan also require implementing procedures approved in the same manner, but their format may not match that of this procedure, which is written primarily for administrative and technical procedures.
Consistent and clearly written procedures enable safe facility operation. It is not necessary to have the procedure document open when performing a familiar or simple task, but infrequent or complicated procedures should be reviewed prior to performing tasks.
Procedures cannot be developed to cover all circumstances, therefore NETL personnel are expected to use good judgment when performing their duties.
2.0 SCOPE
2.1 General
This procedure supports section 6.3 of the Technical Specifications.
All NETL personnel are responsible to use and follow appropriate approved procedures.
Any member of NETL may draft a new procedure or prepare a revision to an existing approved procedure (see 5.4.4).
The format outlined in this procedure may not apply to all PLAN (see 5.1 Procedure Designation 1.g) procedures, which may be emergency or abnormal operating procedures (see 7.0 Definitions).
The Scope section shall include external requirements met by performing the procedure (e.g. regulations, NRC commitments, or Technical Specifications).
2.2 Schedule
Apply this procedure to prepare or revise an approved NETL procedure.
Procedures written under a previous revision of ADMN-1 shall remain valid and will require update to this format only when they require a change other than following this (rev.4) format.
3.0 PRECAUTIONS AND LIMITATIONS
Though precautions and limitations are typically not applicable to administrative procedures, the overall safety of NETL workers and the NETL reactor facility shall be considered when preparing new procedures or revising old ones.
If there is a problem or error with an approved procedure, the procedure shall be examined fully and, if required, a corrective action plan implemented as soon as practical consistent with the principles of a Safety Conscious Work Environment (ref. 2).
Procedure notes, cautions, and warnings (see ref. 3 sec. 4.15) shall be formatted and inserted where applicable with a border increasing in line density as in the below examples (see 7.0 Definitions).
Note
Notes provide important supplemental information to users. This information is explanatory and contains no action or command.
Caution
Cautions alert users to conditions, practices, or procedures that must be observed to avoid potential hazards involving products, equipment, and conditions adversely affecting site operations.
Warning
Warnings alert users to conditions, practices, or procedures that must be observed to avoid loss of life or severe injury.
Warnings alert users to potential hazards to personnel.
4.0 PREREQUISITES
Though Prerequisites are typically not applicable to administrative procedures, activities to be completed and requirements that shall be met prior to procedure performance shall be listed here.
pre-job brief requirement for complex or infrequently performed procedures
performance documents, such as other approved procedures or equipment manuals that shall be available while performing the procedure
Equipment and Materials if required
5.0 INSTRUCTIONS
5.1 Procedure Designation
Group a procedure by specifying the activity the procedure covers:
OPER: Startup, operation, and shutdown of reactor and reactor subsystems
FUEL: Control the movement of reactor fuel and experiments that may cause reactivity changes in the core
MAIN: Routine maintenance for major systems
SURV: Periodic surveillance required by license Technical Specifications or safety
ADMN: Administrative control
HP: Health Physics and radiation protection
PLAN: Implementation of required plans such as Emergency and Physical Security (These procedures may be emergency operating procedures or abnormal operating procedures.)
EXP: Performance of approved experiments and the use of experimental devices.
NETL: Activity not involving the reactor, radiation safety systems, or clearly falling into a listed grouping. This group does not require Reactor Oversight Committee review.
Number a procedure sequentially within its group to generate the procedure’s unique designator-number.
5.2 Procedure Structure
5.2.1 General
Format a procedure as a multi-page document with content surrounded within a fixed border with the following properties:
font shall be Times New Roman 12pt
the first page shall be an approval cover page with the following properties: (1) shall display the word “PROCEDURE” in all capital letters, designator-number, the procedure title, and integer revision number (2) shall not display the page number or header (3) each approver’s name shall be typed or printed with their signature
include a document header on each page, after the approval cover page, displaying the procedure title, designator-number, revision, approval date, and page count with a border around each element
the Table of Contents section shall use full pages
section 1.0 shall start on the first full page after the Table of Contents
an Attachment shall be paginated separately from its parent procedure
an Appendix shall be paginated as part of a procedure
Note
The basic structure for a NETL procedure is adapted from ref. 3 PPA AP-907-005 rev.2 Procedure Writers Manual. This manual provides a consensus standard for writing human factored procedures in the nuclear industry.
Structure a procedure numbering scheme to have up to three numbered levels of informational title such that the first level is capitalized and the second level is underlined as demonstrated in this document. The procedure steps and sub-steps shall be listed as demonstrated in this step.
see Procedure Writers Manual (ref. 3 sec. 4.9) for additional information on step enumeration and formatting
the current sub-step is 5.2.1 General 2.b. (1) this additional sub-step level may be used
this additional sub-step level may be used
Structure procedure steps understanding that different procedure types (e.g. administrative, technical, and emergency or abnormal) may require different levels of detail for their instructions (see 7.0 Definitions).
5.2.2 Procedure Sections
Organize the sections of a procedure as:
Approval cover page
Table of Contents page
1.0 Purpose
2.0 Scope
3.0 Precautions and Limitations (not applicable to administrative procedures)
4.0 Prerequisites (not applicable for administrative procedures)
5.0 Instructions
6.0 References
7.0 Definitions (optional)
8.0 Summary of Minor Modifications
9.0 List of Attachments (optional)
10.0 Appendices (optional)
Include all sections in a procedure regardless of its type.
Mark “Not Applicable” immediately after a section that is optional, or not applicable due to procedure type, if the section is not used.
An Attachment (see 9.0 List of Attachments) shall have the following properties:
shall not be required to perform the procedure
need not follow procedure formatting
shall be maintained in a separate document file from parent procedure
may be modified to incorporate operating experience
shall be referred to in a procedure note
An Appendix (see 10.0 Appendices) to a procedure shall have the following properties:
shall be a continuation of the procedure
may contain supplemental information, forms, tables, checklists, or additional instructions to support performing the procedure
shall be contained in the same document file as the procedure
may be used to capture data by printing and handwriting information or may be processed digitally with required approval signatures
appendix changes shall be performed as part of the procedure (see 5.3.2)
shall be referred to in the procedure body
5.3 Procedure Review and Approval
5.3.1 General
Designate the NETL member that drafts a new procedure or develops a revision as the Procedure Preparer (see 5.4.4) on the approval cover page.
Note
The NETL TS (6.2.3) specify that the ROC must review proposed changes in procedures to ensure they do not involve an unreviewed safety question.
This mandatory review as described in 10CFR50.59 is implemented with Appendix A: 50.59 Process.
The 50.59 Process applies to structures, systems, and components (SSC), procedures, tests, and experiments.
Use Appendix A: 50.59 Process to review new or revised procedures.
Note
Procedure preparation, revision, review and approval (including signatures) may be accomplished digitally.
Procedures that implement required plans such as the Emergency Response Plan or the Physical Security Plan shall not modify or remove a plan requirement.
Approve a procedure for use after the Director or SSRO and the ROC have signed it (TS 6.3).
5.3.2 Procedure Changes
Note
Revisions to an approved procedure are substantive changes to the intent (e.g. reduce the margin of safety, remove equipment or calibration requirements, or alter the way acceptance criteria are met) and meet the criteria for approval as a new procedure (TS 6.3).
Minor modifications to an approved procedure are changes that do not change the original intent and may be made by the Director or SSRO (TS 6.3).
Temporary deviations from a procedure may be made by a senior reactor operator in order to deal with special or unusual circumstances or conditions
Draft a procedure revision by:
revising the draft procedure pages as required
using Appendix A: 50.59 Process, to assess whether a 50.59 review process is required and complete all required forms
incrementing the revision number by 1.00 (e.g. Rev. 2.00 to 3.00) on all pages
restarting the minor modification counter (e.g. Rev. 2.01 to 3.00)
starting the revision number for new procedures at revision zero (e.g. Rev. 0.00)
approving the revision as per section 5.3.3
Perform a procedure minor modification by:
authorization of Director or SSRO
using Appendix A: 50.59 Process to assess whether a 50.59 review process is required and complete all required forms
documenting the minor modification in the Summary of Minor Modifications section with: (1) a description of the minor modification (2) a new revision number (3) name of the approver
performing the minor modification to pages as necessary
incrementing the revision number by 0.01 (e.g. Rev. 2.00 to 2.01) on pages changed
replacing the original pages with the changed pages
Archive changed procedures (revisions and minor modification pages) and retain for a period of not less than five years (TS 6.7.2.h).
Perform a temporary deviation (TS 6.3) from a procedure by:
deviating from a procedure to deal with special or unusual circumstances as required (SRO authorization required)
documenting the deviation in the reactor console logbook
reporting the deviation to the Director or SSRO
5.3.3 Approval Process
Note
The approval process for Minor Modifications includes only the Director or SSRO with 50.59 assessment (see 5.3.2)
The procedure preparer, using Appendix A: 50.59 Process shall assess whether the 50.59 process applies and complete all required forms.
For procedures involving general safety, radiological safety, or emergency planning, the NETL Health Physicist shall review, approve, and submit a draft to the Reactor Manager.
The Reactor Manager shall review, approve, and submit a draft procedure to the Director.
The Director shall review, approve, and submit a draft procedure to the ROC.
The ROC (or appointed subcommittee) shall review a draft procedure, make recommendations for revision as appropriate, and review the associated “Appendix A: 50.59 Process evaluation” documentation if required.
The Reactor Oversight Committee Chairperson shall request ROC approval and sign the cover page when conditions for approval of a draft procedure have been met.
5.4 Document Control
5.4.1 General
Prepare and review procedures using common software such as Microsoft Word.
Send documents to the ROC for final approval by using a common software format such as Adobe PDF.
Avoid emailing copies of draft procedures for review; reference a shared storage location when possible.
Send procedures to the ROC for review and approval by enclosing and referencing the following documents in a single folder:
proposed draft procedure (including appendices)
previously approved procedure (required for revisions)
attachment(s) (if used)
applicable records from Appendix A: 50.59 Process records (Screening and/or Evaluation)
a document outlining changes between the original and revised procedure, or describing a new procedure
if the 50.59 Process is not required, a document providing the reason
Perform procedures only from the master copy or the reactor control room copy.
5.4.2 File Naming Conventions
Name draft document files in the following manner:
begin the filename with the date in YYYYMMDD format
include “(DRAFT)” after the date
include the Procedure Designator-Number after DRAFT
include a reviewer’s name, as required, at the filename end
A reviewer’s name at the end of the Filename shall indicate suggestions or comments to the draft made by the last reviewer of the file.
Clean drafts are those incorporating a previous user’s comments or suggestions and shall not have a reviewer’s name appended to the filename [e.g. 20230214 (DRAFT) ADMN-1.doc]
Name approved and signed procedure PDF documents in the following manner:
begin the filename with the Procedure Designator-Number
include the procedure name
complete the filename by enclosing the approval month and year in parenthesis [e.g. ADMN-1 NETL Procedure Control (Apr 2010).doc]
5.4.3 Archival and Storage
Maintain a master copy of all approved NETL procedures via electronic file storage, or by printed and signed documents, but there shall be one dedicated location for the master copy.
Destroy or protect printed draft procedures to avoid confusion with approved procedures.
5.4.4 Procedure Preparer Responsibilities
The Procedure Preparer shall:
draft a new procedure or revisions adhering to this procedure
assess whether the 50.59 Process is applicable
begin screening process described in Appendix A: 50.59 Process as required
ensure that all reviewer comments and suggestions are incorporated or addressed in subsequent drafts
create new clean drafts for further review or final approval
provide assistance to the overall progress of the draft procedure until final approval
begin document outlining changes between approved procedure and proposed procedure revision
5.4.5 Reactor Manager Responsibilities
The Reactor Manager shall:
maintain a master file of approved and superseded procedures, drafts, and modified procedure pages (minor modifications)
maintain an approved working copy of all procedures in the reactor control room
update the master and control room copies with new procedures, revisions, and minor modifications
archive revised procedures, including minor modifications, to meet retention requirements
inform all licensed operators when a procedure is created or revised
6.0 REFERENCES
“NRC Docket 50-602 Facility Operating License, Appendix A: Technical Specifications Revision 1,” The University of Texas at Austin, December 1990.
“Guidance for Establishing and Maintaining a Safety Conscious Work Environment,” U.S. Nuclear Regulatory Commission, NRC RIS 2005-18, August 2005.
“Procedure Writers Manual,” Procedure Professionals Association, PPA AP-907-005, Revision 2, February 2016.
“Guidelines for 10CFR50.59 Implementation at Non-power Production and Utilization Facilities,” Nuclear Energy Institute (NEI), NEI 21-06 [Rev 0], August 2021. (available in NRC ADAMS as ML21236A089)
“Changes, Tests, and Experiments,” US Code of Federal Regulations, 10CFR50.59, as amended on August 28, 2007.
7.0 DEFINITIONS
Administrative Procedure: A document that specifies requirements and actions necessary to implement a program or process.
Caution: A statement placed immediately before applicable step(s) that informs users of undesirable equipment results such as potential for equipment damage, plant transients, or conditions that may adversely affect plant operation.
Emergency and Abnormal Operating Procedures: Documents that provide general guidelines and actions to take in the event of an emergency or abnormal situation.
Level of Detail: The technical detail necessary within a procedure step to successfully interface the individual user’s knowledge to the technology being used, instruction, or task being performed.
Note: Statements that provide explanatory information to support a procedure step or series of steps.
Procedure: A controlled document designed to improve human performance by clearly providing the purpose, specific intent, and sequenced direction for an activity, program, or process.
Technical Procedure: A document that outlines a series of steps for the operation, maintenance, or testing of a structure, system, or component.
Warning: A statement placed immediately before applicable steps to warn users of potential for personnel injury, loss of life, or health hazards.
8.0 SUMMARY OF MINOR MODIFICATIONS
Rev. |
Change Description: |
Approved By: |
|---|---|---|
4.01 |
Clarified wording in step 7 “All answers in Blocks (2)-(5) |
JMTerry |
4.01 |
Removed erroneous line on screen form to match instructions. |
JMTerry |
9.0 LIST OF ATTACHMENTS
Not applicable
10.0 APPENDICES
Appendix A: 50.59 Process
ADMIN-2 Procedures for Design Features and Quality Assurance
I. PURPOSE
Design features and conditions that are set by the Safety Analysis Report determine the requirements for quality assurance of specific facility features. This procedure provides the guidance for review and identification of structures, systems and components that require quality assurance of design changes.
II. DESCRIPTION
The level of quality assurance is relative to the safety features or design conditions of a structure, system or component. Two activities require the application of all sections of the quality assurance program. One structure or system is the clad system for the fuel elements that provides the primary physical barrier against fission product release. The second system is any transportation package, Type B, that will transport radioactive fuel elements.
Other building features, systems and components that are important to safety do not require complete quality assurance documentation. These building features or support systems none-the-less, may require quality assurance review to obtain an acceptable level and type of performance. Systems such as the instrumentation control and safety system, radiation monitoring or measuring systems and life safety equipment are examples of systems or components that should require implementation of one or more sections of the quality assurance plan. Application of any section will be to assure appropriate levels of system or equipment performance.
III. REFERENCES
Safety Analysis ReportInstrument, Control and Safety ManualMechanical Equipment ManualQuality Assurance Plan, Revision 0 1990
IV. EQUIPMENT
Fuel element claddingReactor structure systemInstrument Control and Safety SystemReactor Water SystemsAir Confinement SystemArea and Air Radiation Monitoring System
A. Design Conditions
Evaluate each system or component change to determine the appropriate requirements and specifications.
Review the Safety Analysis Report for specific design conditions.
Review appropriate plans and specifications for design details.
Identify the criteria, performance or standards appropriate for the design conditions or changes.
Determine whether a design change requires an amendment of the Safety Analysis Report, Safety Evaluation Report and License.
Assure that design conditions meet the safety analysis and license amendments.
Assure that design conditions meet other specified criteria, performance or standards.
Implement quality assurance program elements of the next section as necessary for safety items or to assure other quality control activities.
B. Quality Assurance
Identify quality assurance item as referenced by the Q-list (Section C).
Determine the elements of the quality assurance program according to Attachment. Refer to the Quality Assurance Plan for the specification of each QA requirement.
Specify or verify the QA documentation title, description, and quality level.
Specify or verify the participation and responsibility of personnel and the documentation applicable to quality control.
List the applicable sections of the quality assurance program.
Complete the quality control elements for each applicable section noting item identification, and quality assurance program section number according to Attachment.
Specify quality conditions.
Record comments on quality control.
Date and initial the initiation and acceptance of the quality control activities.
Review the complete quality assurance activity.
C. Q-list
Designation
Item Identification
Level
A
Fuel element, Fuel-control element
1
B
Fuel shipping package
1
C
Reactor core structure
2
D
Tank structure
2
E
Shield structure
2
F
Beam tube components
2
G
Rotary rack system
2
H
Pneumatic tube components
2
I
Installed core system
2
J
Instrumentation system
2
K
Control system
2
L
Safety system
2
M
Pool coolant system
2
N
Water purification system
2
O
Room confinement components
2
P
Area ventilation components
2
Q
Area radiation monitoring system
2
R
Air radiation monitor system
2
S
Fuel Storage Wells/Racks
2
T
All Other Systems*
3
*Level 3 quality requirements, if any, depend on user specifications and requirements for each system. Documentation or record, if any, of quality assurance will be the responsibility of the system user.
ADMIN-3 Procedures for Personnel and Operator Qualifications
I. PURPOSE
The choice of personnel for job positions at the NETL facility includes license commitments and university job classification requirements.
II. DESCRIPTION
The special nature of key job positions, such as persons that direct the operation of reactor operators and persons that are reactor operators require training and qualification that exceed the standard university job description. Guidelines for review of personnel requirements and standards are set forth. Permits for reactor operation responsibilities require special training to maintain license status.
III. REFERENCES
IV. PROCEDURE
A. Staff Personnel
Evaluate job tasks to determine the knowledge, skills, training and experience required.
Determine whether the job tasks specify the qualifications of a Director, Supervisor, reactor operator, health physics research support personnel or technician support personnel.
Review the appropriate university job descriptions and the applicable ANS standard.
Assure that the qualifications of a director or supervisor meet the criteria of the Safety Analysis Report and guidance documents.
Assure that qualifications of personnel that are to obtain certification as operators demonstrate the potential to complete successful qualification of personnel that will become reactor operators or senior operators.
Develop plans to provide qualification of personnel that will become reactor operators or senior operators.
Provide the appropriate training evaluation and examination necessary to complete the issuance of senior or operator permits.
Research support personnel should have the requisite qualifications appropriate to the specified job tasks.
Technician support personnel should have the requisite qualifications appropriate to the specified job tasks.
Provide initial and review training to students, faculty, staff and researchers.
B. Reactor and Senior Operators
Conduct appropriate training sessions in the subject matter specified in the training program over a period not to exceed two years.
Circulate changes in design, licenses, and procedures to all certified personnel in a timely manner.
Assure the maintenance of the Operator Qualification documentation in a timely manner.
Provide for the review of the contents of all abnormal and emergency procedures annually.
Prepare a written examination(s) covering the subject matter specified in the training program.
Evaluate the performance and competency of each certified operator.
Provide accelerated retraining for personnel who score below the acceptance criteria.
Schedule a physical examination of all certified personnel during each two year requalification cycle.
Prepare a specific training program, utilizing pertinent portions of these procedures, for operator trainees.
ADMIN-4 Radiation Protection Program
I. INTRODUCTION
A. PURPOSE
To establish a radiation protection program based on sound engineering and radiation protection principles.
B. DESCRIPTION
The unique hazards associated with exposures to radiation fields and radioactive materials require special considerations such as training of workers, monitoring of workers and work areas, and planning for unusual conditions. The importance of the radiation protection program requires the assignment of one person with the primary responsibility to implement the radiation protection program.
The NRC regulations in 10CFR20 are the ultimate basis for the procedures and requirements of the program. However, as Texas is an agreement state, some aspects of the radiation protection program must also meet the TDSHS regulations in 25TAC289.
C. SCHEDULE
Apply as necessary to establish and maintain an appropriate radiation protection program.
D. CONTENTS
E. EQUIPMENT and Materials
N/A
F. REFERENCES and Documents
Title 10, Code of Federal Regulations Part 20 (10CFR20), “Standards for Protection Against Radiation.”
Title 25, Texas Administrative Code, Chapter 289, Section 202 (25TAC289.202), “Standards for Protection Against Radiation”
Research Reactor Industry Standard ANSI/ANS 15.11-2009, “Radiation Protection at Research Reactor Facilities.”
II. PROCEDURE
The radiation protection program at the NETL is patterned after ANSI/ANS 15.11-2009 and includes the following areas as formal and/or informal processes.
man agement policy statement
c omprehensive administrative procedures
facility-specific exposure, and other, limits
as-low-as-is-reasonably-achievable program
records systems
design and preoperational reviews
surveillance activities
personnel exposure
radiation and contamination surveys
environs monitoring
effluent monitoring
warning and active protection systems functionality
as-approved operational limitation compliance
engineered protective systems (e.g., shielding and ventilation)
instrumentation
radioactive material control (e.g., accountability programs and control zones)
It is recognized that periodic inspection, calibration, testing, etc. is required to maintain a successful radiation safety program. The intervals as listed below are to provide operational flexibility and not to reduce frequency of the required task. Established frequencies shall be maintained over the long term. Allowable surveillance intervals are:
biennial - not to exceed 2.5 years
annual - not to exceed 15 months
semiannual - not to exceed 7.5 months
quarterly - not to exceed 4 months
monthly - not to exceed 6 weeks
weekly - not to exceed 10 days
protective equipment
calibration and quality assurance programs
training
waste program
emergency planning
audit and review programs
independent review committees
audit of the program content
audits of the program activities
regulatory compliance review
abnormal events
reviews, determination of root causes, and corrective actions
review and application of relevant experience
identification and classification of events subject to specific review
ADMIN-5 Protection Programs
I. Purpose
Provide for facility protection, including security of materials, response to emergencies, and fire-safety programs.
II. Description
Physical security and emergency response are the responsibility of NETL staff through the documentation of the respective plans. Fire and other safety programs include coordination with university programs.
III. References
Physical Security PlanEmergency Plan
IV. Procedure
Physical Security
Establish, maintain and implement a physical security plan.
Establish and maintain an access control system.
Review access control records each semester.
Notify University officials and regulatory agencies of security system failures as required.
Review the adequacy of the physical security plan at intervals not to exceed two years.
Review documentation of Physical Security Plan activities.
Emergency Response
Establish, maintain and implement an emergency plan.
Initiate agreements with non-university emergency service agencies. Review agreements at two-year intervals.
Establish and maintain communications with off-site elements of the emergency response team.
Designate locations for the posting of the current emergency call list. Update list at intervals not to exceed one year.
Notify university officials and regulatory agencies of emergency conditions as required.
Review the adequacy of the emergency plan at intervals not to exceed two years.
Review documentation of Emergency Plan activities.
Fire-safety Protection
Maintain a continual awareness of any changes to building features or hazardous conditions. Identify the possible impacts on passive or active fire protection systems or other safety equipment.
Evaluate any changes to the building that change the passive fire protective functions of the building layout, barriers or materials.
Perform checks, at approximately regular intervals, on the components of the active fire protection elements.
Identify and record significant ignition and combustion sources so that steps can be taken to prevent or mitigate potential accidents.
Initiate review of the fire protection program at biennial intervals.
Approve each activity suc as welding, cutting, open flames, or other sources that affect fire protection. Log approvals with fire safety program documentation.
Verify documentation of Fire Safety Program activities.
At all times good safety practices should be applicable for worker safety.