ML18333A277
| ML18333A277 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2018 |
| From: | Anthony Mendiola Research and Test Reactors Oversight Projects Branch |
| To: | |
| Montgomery C | |
| Shared Package | |
| ML18333A271 | List: |
| References | |
| Download: ML18333A277 (53) | |
Text
NRC Research and Test Reactor Oversight Activities Anthony Mendiola, Chief Research and Test Reactors Oversight Branch U.S. Nuclear Regulatory Commission 2018 TRTR Annual Meeting October 31, 2018
Presentation Agenda
- PROB Staff Changes
- Oversight Year in Review
- RTR Inspection Program Year in Review
- Focus on RTR Safety Culture
- RTR Operator Licensing Program Year in Review
- Operator Licensing Applications
- Process Improvements
- Focus on Application Issues and Medicals
- Operator License Reactivation
- RTR Security Program
Presentation Agenda
- PROB Staff Changes
- Oversight Year in Review
- RTR Inspection Program Year in Review
- Focus on RTR Safety Culture
- RTR Operator Licensing Program Year in Review
- Operator Licensing Applications
- Process Improvements
- Focus on Application Issues and Medicals
- Operator License Reactivation
- RTR Security Program
Oversight Branch Staff Anthony Mendiola, Branch Chief
- Craig Bassett, Reactor Inspector
- Michele DeSouza, Reactor Examiner
- Johnny Eads, Reactor Inspector
- Beth Reed, Security Specialist
- Mike Morlang, Reactor Inspector
- Mike Takacs, Security Inspector
- Ossy Font, Reactor Inspector
- Bill Schuster, Security Inspector
- John Nguyen, Reactor Examiner
- Nicole Parker, Licensing Assistant
- Paulette Torres, Reactor Examiner
- Angela Baxter, Op Lic Assistant
- Ashley Ferguson, Rx Inspector
- Caroline Jedie Randiki, Op Lic Assistant 4
Presentation Agenda
- PROB Staff Changes
- Oversight Year in Review
- RTR Inspection Program Year in Review
- Focus on RTR Safety Culture
- RTR Operator Licensing Program Year in Review
- Operator Licensing Applications
- Process Improvements
- Focus on Application Issues and Medicals
- Operator License Reactivation
- RTR Security Program
RTR Inspection Program -
Year in Review
- Inspection results continue to document that NRC-licensed RTRs are being operated safely and securely
- Violations have significantly decreased
- Overall Inspection observations and findings
- Repeated findings from previous inspections not an issue
- Inspection follow-up actions are up - minor issues 6
RTR Inspection Program -
Year in Review
- Severity Level IV Violations (3)
- NRC Approved Reviewing Official
- Tech Spec Annual Audit
- Evacuation Drills not held
- Non Cited Violations (2)
- Tech Spec Deviations
- Safety Conscience Work Environment (SCWE)
RTR Inspection Program -
Year in Review
- Future inspection challenges
- Mo-99 Facilities
- Physical security and cyber security threat
- Balancing Inspector workloads
- More inspectors on staff - cross qualifying staff
- Development of Mo-99 inspection staff 8
What is Safety Culture?
- The Commission defines Nuclear Safety Culture as the core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals to ensure protection of people and the environment.
What is the NRC policy on safety culture?
- The expectation that individuals and organizations performing or overseeing regulated activities establish and maintain a positive safety culture commensurate with the safety and security significance of their activities and the nature and complexity of their organizations and functions
Traits of a Healthy Safety Culture
- Leadership Safety Values and Actions
- Work Processes
- Effective Safety Communications
- Problem Identification and Resolution
- Continuous Learning
- Respectful Work Environment
- Personal Accountability
- Environment for Raising Concerns
- Questioning Attitude
Significance within the RTR community
- Very Significant
- RTRs have minimal direct interface with NRC regulators
- No resident inspectors - No region based inspectors
- NRC onsite time is small compared to other regulated facilities
- Associated staff support for a single facility is very small
- NRC must trust and rely upon all RTR managers and operating staff to demonstrate proper safety culture every day regardless of completing goals
NRC Educational Materials Available for Safety Culture https://www.nrc.gov/about-nrc/safety-culture.html
Operator Licensing Program -
Year in Review
- FY 18 RTR Exam Performance remains consistent
- Administered exams to 75 RO and 25 SRO candidates in FY18
- Written Exam Pass rate
- 67/75 for Reactor Operators (89%)
- 11/11 for Senior Reactor Operators (100%)
- Operating Exam Pass Rate
- 73/75 for Reactor Operators (97%)
- 25/25 for Senior Reactor Operators (100%)
14
RTR Operator License Docket Summary
- 375 Active RTR Licenses
- 193 Reactor Operators
- 181 Senior Reactor Operators
- 1 Limited Senior Reactor Operator
- 51% of active licenses have conditions
- Most of these are corrective lens (84%)
- Prescribed Medications (13%) Other (3%)
15
RTR Operator License Docket Management
- Electronic Processing System (RPS-OL)
- 88 Terminations
- 26 License Renewals
- 55 Waivers
- 146 Amendments (Changes to License)
- Still have issues related to the backlog of operator licensing paperwork.
Guidelines for RTR Op Licensing Applications
- New examination requests and any examination changes as soon as possible in advance
- Initial license applications submitted at least 14 days prior to the exam, sooner if waivers requested
- License renewal applications submitted at least 30 days prior to license expiration date
- Consider the use of EIE and ODD
- Protect against PII disclosures
- Check your mailing addresses 17
Presentation Agenda
- PROB Staff Changes
- Oversight Year in Review
- RTR Inspection Program Year in Review
- Focus on RTR Safety Culture
- RTR Operator Licensing Program Year in Review
- Operator Licensing Applications
- Process Improvements
- Focus on Application Issues and Medicals
- Operator License Reactivation
- RTR Security Program
Operator Licensing Application Process Improvements
- Standardized Application Forms
- Electronic Secure Submittal to the NRC
- Operator Digital Docket and RPS-OL
Standardized Application Forms
- NRC Form 396 and 398 Revisions complete
- Based on Industry feedback
- Provided Clarification of instructions
- Removal of unnecessary fields
- Available on NRC Forms website
- OMB approved forms which reduce burden on submitter
- Forms standardized to support for digital records
Finding NRC forms for Operator Licensing
Finding NRC forms for Operator Licensing
Operator Licensing Application Process Improvements
- Standardized Application Forms
- Electronic Secure Submittal to the NRC
- Operator Digital Docket and RPS-OL
Electronic Secure Submittal to the NRC
- Use of the Electronic Information Exchange (EIE) system
- Cost-effective, secure, timely delivery mechanism
- Requires a rudimentary certificate for authentication and authorization (https://pki.nrc.gov/ecs/apps/eie/dcc-eie-gf.html)
- Contact the EIE Helpdesk at 1-866-672-7640 or email at Meta_System_Help_Desk.Resource@nrc.gov
How to get an EIE certificate:
www.nrc.gov Site Help Electronic Submittals Application (https://www.nrc.gov/site-help/e-submittals.html) 25
Operator Licensing Application Process Improvements
- Standardized Application Forms
- Electronic Secure Submittal to the NRC
- Operator Digital Docket and RPS-OL
Operator Digital Docket (ODD)
- Automation of components of the OL process
- Electronic document delivery mechanism
- cost-effective, secure and timely delivery of documents to NRC
- Data extraction solution for submitted applications
- Parsed and delivered to the Reactor Program System
- Reduces the need to manually enter data into RPS-OL
- saves time
- minimizes the risk of data entry errors.
Improving Record Keeping
- NRC is moving to digital record keeping for operator dockets (Operator Digital Dockets (ODD))
- All medical related correspondence and records are maintained digitally
- Recommend use of EIE for sending and receiving medical information to/from NRC:
Security (encryption)
Expediency Cost savings (shipping)
Skips irradiation!
29
Presentation Agenda
- PROB Staff Changes
- Oversight Year in Review
- RTR Inspection Program Year in Review
- Focus on RTR Safety Culture
- RTR Operator Licensing Program Year in Review
- Operator Licensing Applications
- Process Improvements
- Focus on Application Issues and Medicals
- Operator License Reactivation
- RTR Security Program
Common Application issues
- Common application issues seen this year
- Unclear or missing application information
- Weeks of training calculation - 1 week = 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />
- Handwriting/spelling difficulties
- Mailing address issues - Student addresses
- Incomplete waiver information
- Medical information dates
Experience Information on NRC Form 398
Medical Information on NRC Form 396
Recap of medical information from last year
- Use the ANS 15.4 Standard, Selection and Training of Personnel for Research Reactors
- Various versions (1988, 2007 and 2016)
- Focus on Section 7, Medical certification and monitoring of licensed personnel
- Basis for the RTR medical professional assessments and NRC medical review officer recommendations
Basis for Health Requirements
- Physical condition and general health of operators shall be such that they are capable of carrying out licensed activities and perform associated tasks
- For conditions that involve sudden incapacitation, these may be accommodated by restricting activities, imposing a medical regime, or requiring a second individual present (no solo) who shall be able to shut down the reactor and summon help.
General Requirements
- Candidates shall demonstrate stability and capacity for all of the following:
- Mental Alertness and Emotional Stability
- Acuity of Senses and ability of expression
- Stamina, Range of motion, Dexterity to support assigned duties
- Candidates shall be free of any of the following:
- Mental or physical impairments
- Any medical, surgical, or other professional treatment
- Any condition, habit, or practice that might result in incapacitation.
Disqualifying Conditions The presence of any of the following conditions, which have a high probability of sudden or unexpected incapacitation, unless adequately compensated, shall disqualify the individual for solo operation.
Disqualifying Conditions
- Disqualifying conditions include:
- Respiratory (Asthma)
- Cardiovascular (Heart conditions)
- Endocrine, nutritional, metabolic (Insulin dependent diabetes)
- Neurological (epilepsy)
- Mental Condition (Psychological testing, personality disorders, suicide attempts/threats, psychotic disorders, alcohol and drug abuse)
- Medication (Serious prescription drug side effects)
- Some of these are disqualifying for all conditions, unless treated and corrected
Waivers and Limited Approvals
- Waivers - considered when minimum requirements not met, but applicant can demonstrate complete capacity to perform assigned duties. Information required:
- Medical history and results/findings of physical examinations
- Practical tests and demonstrations of ability to perform assigned duties
- Certification of Level 2 that individual can safely perform duties
- Limited Approval (no solo)
- 2nd person present when performing certain assigned duties
- 2nd person can be summoned when assistance needed
- Follow-up medical examinations (6 to 12 Months)
Presentation Agenda
- PROB Staff Changes
- Oversight Year in Review
- RTR Inspection Program Year in Review
- Focus on RTR Safety Culture
- RTR Operator Licensing Program Year in Review
- Operator Licensing Applications
- Process Improvements
- Focus on Application Issues and Medicals
- Operator License Reactivation
- RTR Security Program
Regaining Active Operator Status
- Issue encountered at multiple RTR facilities
- Multiple regulations (10 CFR 55), NRC publications, and historical practices involved
- Power reactor practices and simulator use
- License reactivation is distinct from the requalification requirement 41
10 CFR 55.53 Conditions of licenses
- 10 CFR 55.53 (e) If a licensee has not been actively performing the functions of an operator or senior operator, the licensee may not resume activities authorized by a license issued under this part except as permitted by paragraph (f) of this section. To maintain active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter. For test and research reactors, the licensee shall actively perform the functions of an operator or senior operator for a minimum of four hours per calendar quarter.
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10 CFR 55.53 Conditions of licenses
- 10 CFR 55.53 (f) If paragraph (e) of this section is not met, before resumption of functions authorized by a license issued under this part, an authorized representative of the facility licensee shall certify the following:
- (1) That the qualifications and status of the licensee are current and valid; and
- (2) That the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> must have included a complete tour of the plant and all required shift turnover procedures. For senior operators limited to fuel handling under paragraph (c) of this section, one shift must have been completed. For test and research reactors, a minimum of six hours must have been completed.
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10 CFR 55.53 Conditions of licenses (cont.)
- 10 CFR 55.53 (h) The licensee shall complete a requalification program as described by 55.59 44
Reactivation Scenarios
- A - Single operator is inactive
- B - All operators are inactive, but requalification program requirements are met
- C - All operators are inactive and requalification program requirements are not met 45
Scenario A Resolution
- 10 CFR 55.53 (f) If paragraph (e) of this section is not met, before resumption of functions authorized by a license issued under this part, an authorized representative of the facility licensee shall certify the following:
- (1) That the qualifications and status of the licensee are current and valid; and
- (2) That the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> must have included a complete tour of the plant and all required shift turnover procedures. For senior operators limited to fuel handling under paragraph (c) of this section, one shift must have been completed. For test and research reactors, a minimum of six hours must have been completed.
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Scenario B and C Resolution
- 10 CFR 55.53 does not address a scenario where there is no active licensed operator to supervise an individual for under instruction watch at the facility 47
Scenario B and C Resolution (cont.)
- Historical Context
- Practices allowed for power reactors
- RTR operational differences
- Very high turnover, small permanent staff 48
Next steps
- NRC is exploring how to best resolve Scenarios B and C
- Resolution may involve changes to NRC Examiner Standards
- RTR community will be informed prior to any changes 49
Presentation Agenda
- PROB Staff Changes
- Oversight Year in Review
- RTR Inspection Program Year in Review
- Focus on RTR Safety Culture
- RTR Operator Licensing Program Year in Review
- Operator Licensing Applications
- Process Improvements
- Focus on Application Issues and Medicals
- Operator License Reactivation
- RTR Security Program
Security Program Oversight
- Security Inspection Program
- OIG Audit - No issues
- Physical Security Plan Reviews
- Compensatory Measures Confirmatory Action Letter closures
- Security and Emergency Exercises
- Security Program Updates 51
Presentation Summary
- RTR Inspection results - facilities continue to be operated safely and securely, violations are down
- SCWE is an agency focus area
- RTR Operator Licensing examination performance has been consistent with slight improvements
- Operator Licensing process improvements implemented
- Applications and Medical paperwork is a focus area
- Operator Licensing reactivation solution under development
- Security Program successfully audited and active 52
Questions 53