ML18204A394

University of Texas at Austin - Request for Additional Information Re. Operator Requalification Program Review for Renewal of Facility Operating License No. R-129

ML18204A394
Person / Time
Site:	University of Texas at Austin
Issue date:	07/26/2018
From:	Geoffrey Wertz Research and Test Reactors Licensing Projects Branch
To:	Charlton W University of Texas at Austin
Wertz G
References
EPID L-2017-RNW-0032
Download: ML18204A394 (7)

Text

July 26, 2018 Dr. William Charlton, Director Nuclear Engineering Teaching Laboratory The University of Texas at Austin Pickle Research Campus, Building 159 10100 Burnet Road Austin, TX 78758

SUBJECT:

UNIVERSITY OF TEXAS AT AUSTIN - REQUEST FOR ADDITIONAL INFORMATION RE: OPERATOR REQUALIFICATION PROGRAM REVIEW FOR RENEWAL OF FACILITY OPERATING LICENSE NO. R-129 FOR THE UNIVERSITY OF TEXAS AT AUSTIN RESEARCH REACTOR (EPID NO. L-2017-RNW-0032)

Dear Dr. Charlton:

The U.S. Nuclear Regulatory Commission (NRC) staff is continuing its review of the University of Texas (UT) at Austin for the renewal of Facility Operating License No. R-129, dated December 12, 2011 (under the Agencywide Documents Access and Management System (ADAMS) Accession No. ML12156A097), as supplemented by letter dated February 21, 2012 (ADAMS Accession No. ML12061A009).

The license renewal review includes a review of the UT Operator Requalification Program, dated March 14, 2017, as provided by letter dated March 15, 2017 (ADAMS Accession No. ML17094A528). During the NRC staffs review of the operator requalification program, questions have arisen for which additional information is needed. The enclosed request for additional information (RAI) identifies the information needed to continue the NRC staffs review.

It is requested that UT provide responses to the enclosed RAI within 60 days from the date of this letter.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.30(b), Oath or affirmation, UT must execute its response in a signed original document under oath or affirmation. The response must be submitted in accordance with 10 CFR 50.4, Written communications. Information included in the response that is considered sensitive or proprietary, that UT seeks 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, the NRC staff will continue its evaluation of the renewal request.

W. Charlton If you have any questions, or need additional time to respond to this request, contact me at 301-415-0893 or by electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely,

/RA by Alexander Adams for/

Geoffrey A. Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 50-602 License No. R-129

Enclosure:

As stated cc: See next page

University of Texas Docket No. 50-602 cc:

Bureau of Radiation Control State of Texas 1100 West 49th Street Austin, TX 78756 Dr. Gregory L. Fenves The University of Texas at Austin Office of the President 110 Inner Campus Drive, G3400 Austin, TX 78712-3400 Maurie McInnis Executive Vice President and Provost The University of Texas at Austin 1 University Station, G1000 Austin, TX 78712 DeAnn Walker, Director Office of the Governor Office of Budget and Policy P.O. Box 12428 Austin, TX 78711 Mr. Paul Whaley, Associate Director Nuclear Engineering Teaching Laboratory The University of Texas at Austin 10100 Burnet Road, Building 159 Austin, TX 78758 Larry Hall, Reactor Supervisor Nuclear Engineering Teaching Laboratory The University of Texas at Austin 10100 Burnet Road, Building 159 Austin, TX 78758 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611

ML18204A394 *via email OFFICE NRR/DLP/PRLB/PM* NRR/DLP/PRLB/LA* NRR/DLP/PROB/BC NAME GWertz NParker AMendiola DATE 7/24/2018 7/24/2018 7/26/2018 OFFICE NRR/DLP/PRLB/BC NRR/DLP/PRLB/PM NAME AAdams GWertz (AAdams for)

DATE 7/26/2018 7/26/2018 OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RENEWAL OF THE UNIVERSITY OF TEXAS AT AUSTIN TRIGA MARK II NUCLEAR RESEARCH REACTOR LICENSE NO. R-129, DOCKET NO. 50-602 The U.S. Nuclear Regulatory Commission (NRC) staff is continuing its review of the University of Texas (UT) at Austin for the renewal of Facility Operating License No. R-129, for the Nuclear Engineering Teaching Laboratory TRIGA Mark II Nuclear Research Reactor dated December 12, 2011 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12156A097), as supplemented by letter dated February 21, 2012 (ADAMS Accession No. ML12061A009).

The NRC staff has reviewed the UT Operator Requalification Program (ORP), dated March 14, 2017, as provided by letter dated March 15, 2017 (ADAMS Accession No. ML17094A528). During the NRC staffs review, questions have arisen for which additional information is needed. It is requested that UT provide responses to the enclosed request for additional information (RAI) within 60 days from the date of this letter.

The NRC staffs review used the regulations contained in Title 10 of the Code of Federal Regulations (10 CFR), Part 55, Operators Licenses, as well as the most recent industry guidance found in American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.4-2016, Selection and Training of Personnel for Research Reactors.

The RAI numbering is sequential and continues from the most recent NRC RAI letter, dated January 27, 2017 (ADAMS Accession No. ML16358A644).

51. The regulations in 10 CFR 55.59, Requalification, paragraph (a)(2)(ii) state:

(a) Requalification requirements. Each licensee shall (2) Pass a comprehensive requalification written examination and an annual operating test. (ii) The operating test will require the operator or senior operator to demonstrate an understanding of and the ability to perform the actions necessary to accomplish a comprehensive sample of items specified in § 55.45(a) (2) through (13) inclusive to the extent applicable to the facility.

ANSI/ANS-15.4-2016, Section 6.2.5, Operating test or evaluation, states: At least five tasks selected from Sec. 5.4 including a reactor start-up and shutdown shall be performed and evaluated. The performance of the task may be actual or simulated.

Enclosure

ANSI/ANS-15.4-2016, Section 5.4 (2), Operating and oral examinations, states:

(2) Operating and oral examinations. Operating and oral examinations shall be designed to test the candidates knowledge and skill to properly operate the reactor under normal and abnormal circumstances. Examples of those skills are anticipation of and response to events, facility awareness, use of references, and communications. The number and type of tasks to be performed are dictated by the complexity of the facility. The recommended number is five or more and should include reactor start-up and shutdown.

Tasks may be actual or simulated.

ORP Section 5.2, Annual operating tests, 5.2.1, third bullet states: Based on a representative sample of at least four of the following 13 items:

The NRC staff finds that ORP 5.2.1, states four which is inconsistent with the guidance in ANSI/ANS-15.4-2016, which states five. Furthermore, since four represents less examination tasks than five, the NRC staff finds that it does not appear to be consistent with the requirements in 10 CFR 55.59(a)(2)(ii), which require a comprehensive sample.

Revise ORP 5.2.1 to state five consistent with the guidance in ANSI/ANS-15.4-2016, or provide a justification for how the ORP meets the requirements of 10 CFR 55.59(a)(2)(ii) to provide a comprehensive sample.

52. The regulations in 10 CFR 55.59(a)(2) state: (a) Requalification requirements. Each licensee shall (2) Pass a comprehensive requalification written examination and an annual operating test.

OPR Section 5.1.2 second bullet states: Should (if possible) not to be exempt more than once during sequential training plan cycles.

ORP Section 5.1.2 NOTE states: Test writing responsibilities will be assigned (where possible) so that no individual is exempt from the biennial comprehensive written examination more than once in sequential training cycles.

ORP Section 5.2 NOTE states: The preparation and conduct of the Annual Operating Test will be assigned (where possible) so that no individual is exempt from the annual examination more than once each training cycle.

The NRC staff finds that the phrases if possible and where possible effectively negates the training requirements of each respective section of the ORP, and the licensed operator could be indefinitely exempt from the requirements of taking a written examination and operating test.

Revise the ORP, or clarify the phrases if possible and where possible to ensure that no one licensed operator is permanently exempted from meeting the requirements of 10 CFR 55.59, or justify why no change is needed.

53. The regulations in 10 CFR 55.59(c)(4)(v) state:

(4) Evaluation. The requalification program must include (v) Provisions for each licensed operator and senior operator to participate in an accelerated requalification program where performance evaluations conducted pursuant to paragraphs (c)(4)(i) through (iv) of this section clearly indicated the need.

ORP Section 6.2.3 states, in part:

In the event that facility conditions such as an extended shutdown prevent licensed operators and senior operators from completing at least 4-hours of operation within a quarter, prior to resumption of normal licensed activities all operators and senior operators shall complete a special Facility Retraining Program:

• The Facility Retraining Program shall be approved by the Reactor Oversight Committee.

The NRC staff finds that ORP Section 6.2.3 will satisfy the requirements of 10 CFR 55.59(c)(4)(v) if the following statement is provided:

• The Facility Retraining Program shall be approved by the Reactor Oversight Committee and be in accordance with 10 CFR 55.59 (c)(4)(v).

The NRC staff acknowledges that 10 CFR 55.59(c)(4)(iv) is addressed under OPR 5.2.1 NOTE on page 9 that states, in part: Simulation is acceptable for control manipulations related to emergency or abnormal condition, and actual manipulation of the plant controls is not required.

Revise ORP Section 6.2.3, to state: The Facility Retraining Program shall be approved by the Reactor Oversight Committee and be in accordance with 10 CFR 55.59 (c)(4)(v), or justify why no change is needed.