ML14014A123

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U.S. Geological Survey - Request for Additional Information Review of the Operator Requalification Program for the License Renewal for the Geological Triga Reactor
ML14014A123
Person / Time
Site: U.S. Geological Survey
Issue date: 01/22/2014
From: Geoffrey Wertz
Research and Test Reactors Licensing Branch
To: Nuccio V
US Dept of Interior, Geological Survey (USGS)
Wertz G
References
TAC ME1593
Download: ML14014A123 (7)


Text

January 22, 2014 Mr. Vito Nuccio Reactor Administrator Department of the Interior U.S. Geological Survey PO Box 25046 MS 975 Denver Federal Center Denver, CO 80225-0046

SUBJECT:

U.S. GEOLOGICAL SURVEY - REQUEST FOR ADDITIONAL INFORMATION RE: REVIEW OF THE OPERATOR REQUALIFICATION PROGRAM FOR THE LICENSE RENEWAL FOR THE GEOLOGICAL SURVEY TRIGA REACTOR (TAC NO. ME1593)

Dear Mr. Nuccio:

The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of the U.S. Geological Survey (USGS, the licensee) application dated January 5, 2009 (a redacted version of the safety analysis report provided with the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System Accession No.

ML092120136), as supplemented, for the renewal of Facility Operating License No. R-113 for the USGS TRIGA Reactor (GSTR). Your license renewal application letter indicated that there were no changes needed to your current Reactor Operator Requalification Program (a copy of the GSTR Reactor Operator Requalification Program was provided in the license renewal application). However, the NRC staff review of your license renewal application includes a review of your Reactor Operator Requalification Program, from which we identified some questions, which are provided in the enclosed request for additional information (RAI). Please provide your responses to the enclosed RAI within 30 days from the date of this letter In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, Written communications.

Information included in your response that is considered sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Any information related to security should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information:

Performance requirements. Following receipt of the additional information, we will continue our evaluation of your license renewal request.

V. Nuccio If you have any questions about this review, or if you need additional time to respond to this request; please contact me by telephone at 301-415-0893 or by electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely,

/Alexander Adams for RA/

Geoffrey A. Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-274

Enclosure:

RAI cc: See next page

U.S. Geological Survey TRIGA Reactor Docket No. 50-274 cc:

Environmental Services Manager 480 S. Allison Pkwy.

Lakewood, CO 80226 State of Colorado Radiation Management Program HMWM-RM-B2 4300 Cherry Creek Drive South Denver, CO 80246 Mr. Timothy DeBey Reactor Director U.S. Geological Survey Box 25046 - Mail Stop 424 Denver Federal Center Denver, CO 80225 Test, Research, and Training Reactor Newsletter Universities of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML14014A123; *concurred via e-mail NRR-106 OFFICE NRR/DPR/PRLB/PM* NRR/DPR/PRLB/LA NRR/DPR/PROB/BC NRR/DPR/PRLB/BC NRR/DPR/PRLB/PM NAME GWertz PBlechman GBowman AAdams (AAdams for) GWertz DATE 01/13/2014 01/16/2014 01/22/2014 01/22/2014 01/22/2014

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE REACTOR OPERATOR REQUALIFICATON PROGRAM FOR THE RENEWAL OF THE FACILITY OPERATING LICENSE FOR THE U.S. GEOLOGICAL SURVEY TRIGA REACTOR LICENSE NO. R-113; DOCKET NO. 50-274 The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of the U.S. Geological Survey (USGS, the licensee) application dated January 5, 2009 (a redacted version of the safety analysis report provided with the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System Accession No.

ML092120136), as supplemented, for the renewal of Facility Operating License No. R-113 for the USGS TRIGA Reactor (GSTR). The NRC staff review of your current Reactor Operator Requalification Program identified some questions, which are provided below. Please provide your responses within 30 days from the date of this letter.

1. Title 10 of the Code of Federal Regulations (10 CFR) 55.59(a)(1), states that each licensee shall successfully complete a requalification program developed by the facility licensee that has been approved by the Commission. This program shall be conducted for a continuous period not to exceed 24 months in duration.

The last sentence of Section 1, Program, of the GSTR Reactor Operator Requalification Plan states:

They are: (1) annual written examinations, (2) annual operating examinations and (3) stipulated minimum tasks which must be performed during the requalification period of two years.

The period of two years is not defined and it could mean 24 months or beyond. For example, if a written examination is administered in January 2013 and the next one in September 2015, this practice could be interpreted to meet the two year requirement of the GSTR Reactor Operator Requalification Program, but would not be in accordance with 10 CFR 55.59(a)(1). Please provide a definition for the period of two years and/or revise the GSTR Reactor Operator Requalification Program to include that the requalification period would not exceed 24 months in duration as required by 10 CFR 55.59(a)(1).

Enclosure

2. 10 CFR 55.59(a)(2) states that each licensee shall pass a comprehensive requalification written examination and an annual operating test.

The GSTR Reactor Operator Requalification Program, Section 2, Written Examination states:

Since the annual written examination will be prepared and corrected by the Reactor Supervisor; who is also required to hold a Senior Operator License, these functions will be deemed adequate to demonstrate and document continuing competence.

Contrary to the requirement in the regulations, this sentence exempts one person indefinitely from the requirements of taking a written examination. Propose changes to the GSTR Reactor Operator Requalification Program to ensure that no one individual is permanently exempted from meeting the requirements of 10 CFR 55.59; for example, through the addition of a requirement that examination preparation is rotated among the senior reactor operators.

3. 10 CFR 55.59(c)(2), states that the requalification program must include preplanned lectures on a regular and continuing basis throughout the license period.

The GSTR Reactor Operator Requalification Program does not appear to contain a provision to include preplanned lectures on a regular and continuing basis in accordance with the requirement of the 10 CFR 55.59(c)(2). Explain or provide a provision to the GSTR Reactor Operator Requalification Program to ensure that this requirement is satisfied.

4. 10 CFR 55.59(c)(5)(i), states that the requalification program documentation must include a requirement that the facility licensee shall maintain records until the operator's or senior operator's license is renewed.

Section 6, Records, of the GSTR Reactor Operator Requalification Program does not appear to provide a retention period for the facility to hold the records of the licensed operator and senior operator in the requalification program. Explain or provide a provision to the GSTR Reactor Operator Requalification Program to ensure that this requirement is satisfied.

5. Section 6, Records, 2.(a), of the GSTR Reactor Operator Requalification Program states:

Table 1,Section III, Parts a, b, c, d, and e will be contained within normal facility operating records.

Section III is not defined in the GSTR Reactor Operator Requalification Program, Table 1. Please explain Section III and/or revise Table 1 of the GSTR Reactor Operator Requalification Program appropriately.

6. Section 6, Records, 2.(d), of the GSTR Reactor Operator Requalification Plan states:

An annual statement by the Reactor Supervisor will be inserted in each Reactor Operators or Senior Reactor Operators file certifying continuing competency based on the (1) successful completion of the annual examinations plus any remedial work if required and (2) the actual performance of licensed duties as noted in Part 4-B.

The GSTR Reactor Operator Requalification Program does not contain a Part or Section 4-B. Please explain the reference 4-B, and/or revise the GSTR Reactor Operator Requalification Program appropriately.