ML19267A041
| ML19267A041 | |
| Person / Time | |
|---|---|
| Site: | University of New Mexico |
| Issue date: | 09/10/2019 |
| From: | Busch R Univ of New Mexico |
| To: | Document Control Desk |
| References | |
| EPID L-2019-LLL-0006 | |
| Download: ML19267A041 (11) | |
Text
September 10, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Subject:
Docket No. 50-252, Facility License R.., 102 Submittal of University of New Mexico AGN-201M Facility Response to n
Request for Additional Inform;tion regardi!!g Th.e Operat~r requalificatio Program for the University of New Mexico Aerojet General Nucleonics AGN-201M Reactor (EPID No. L-2019-LLL-0006).
ation (RAJ),
Transmitted herewith is our formal response to your Request for Additional Inform n Program. The dated July 16, 2019, regarding our update to the Reactor Operator Requalificatio enclosure contains the responses to the four items.
277-8027, If there are any questions or concerns with this response please contact me at (505) and/or e-mail me at busch@ unm.ed u ed on September I declare under penalty of perjury that the foregoing is true and correct. Execut 1
10 \ 2019.
Respectfully Submitted Robert D. Busch, Ph.D, P.E.
Chief Reactor Supervisor, UNM AGN-201M Reactor u.::, NM 87131-0001 The Univ.::rsiiy ofNew Mexico* MSCOI l 120
- I University ofNew Mexico* Albuqu,*rq Phone 505.277.5431
- Fm, 505.277.5433
- ne.unm.,xlu 209 Fan-is Engineering Center J
Response to Request for Additional Information From The University of New Mexico AGN-201M Reactor Docket 50-252 RAI responses on UNM Operator Requalification Program (EPID No. L-2019-LLL-0006)
Changes to the Reactor Operator Requalification Program from the January 2019 submittal are indicated in bold in this document, but will be in regular type in the Program document.
RAI-1. The ORP has been revised to address the timeliness requirement as follows:
requested change to the Technical Specifications regarding the definition of Explosive Material is hereby withdrawn. We will keep the current definition as below:
B. Requalification Program
- 1. Schedule The Requalification Program shall be conducted for a continuous period not to exceed 24 months in duration. As part of the program, a one-day requalification training session will be scheduled annually. All licensed personnel will be required to participate. For scheduling purposes the session may consist of two Yz day sessions. For experienced licensed personnel, the annual maintenance will suffice in place of the lectures.
RAl-2. The ORP has been revised to specifically identify the periodicity requirements for the written and operational exams. The time period for the written examination has been changed to every year. There has been no change in the requirements for an annual operating exam for all licensed personnel but a clarification has been added that each senior operator is evaluated by another senior operator (see RAI-4 for text change):
- 4. Evaluation Written Examination: Every year, each licensed individual'shall be given a written examination covering the areas described in Section B.2 of this document. (The licensed individual who develops, administers, and grades these examinations shall be waived from taldng the examination for that year, but will take a written examination the following year. The responsibility for the examination shall rotate among the licensed senior operators or other qualified individuals so that each licensed senior operator shall
- be evaluated at least every two years.) A score of 70% or higher will require no additional training.
RAI-3. The ORP has been revised to address shutdown of the reactor as part of the on-the-job training by adding an item h to the list of training activities:
- 3. On-the-job Training The other half-day of the training session will consist of the following activities:
- a. Review and perform a monthly maintenance check
- b. Review and perform a daily reactor checkout
- c. Startup of the reactor and operation at licensed power
- d. Measurement of excess reactivity
- e. Measurement of reactivity worths of typical samples used in the training and activation experiments*
f Measurement of a safety rod reactivity worth using rod-drop techniqt1es
- g. Simulated emergency with practice evacuation
- h. Reactor Shutdown
'r Manipulation of the controls during these checks and operations will be rotated among the participating personnel. Participation in this session will assure that each licensed operator or senior operator is cognizant of facility design changes, procedure changes, and facility license changes. All elements listed in (a) through (h) above will be tested as part of the annual operations exam for each Reactor Operator and Senior Reactor Operator.
In addition, the operating exam description has been modified to indicate that the exam shall include ... reactivity manipulations in startup, shutdown, and ...
RAI-4. The ORP has been revised to address the issue of observation and evaluation of operator knowledge of abnormal and emergency procedures by including this explicitly in the annual operational exam:
Evaluation of Reactor Operation by Certified Individuals: To maintain active status, each certified individual shall actively perform the functions of an operator or senior operator for a minimum of four hours per calendar quarter. Supervision of these functions by licensed senior operators shall be considered equivalent to actual performance. Each certified individual is required to take an annual operational exam requiring 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 10CFR55.45(a) (2) through (13) inclusive to the extent applicable tot.he facility. These shall include bur are not limited to reactivity manipulations in startup; 'shutdown, and other significant reactivity changes that demonstrate skill or familiarity with the reactivity control systems and general familiarity with the reactor safety systems. Also, the exam shall cover operator response to abnormal and emergency conditions as discussed in the UNM AGN-20 1M reactor Emergency Plan. Responsibility for these exams shall rotate among the senior operations staff with each senior operator being evaluated by another senior operator. If unsatisfactory performance is noted during the quarter or from the operational exam, then additional operation times will be scheduled for retraining. After this is completed, the individual will undergo an additional operational examination to ensure that the individual can competently manipulate the controls of the reactor. If the issue is in a safety area, then the individual will be relieved of licensed duties until the deficiency is corrected.
The revised Operator Requalification Program document is provided as Appendix A with the proposed changes inserted in the document at locations indicated by vertical change bars and bold font. These changes will be in regular type in the Program document.
OPERATOR AND SENIOR OPERATOR REQU.ALIFICA TJON PROGRAM FOR THE
.UNIVERSITY OF NEW MEXICO AGN-201M REACTOR FACILITY DocketNo. 50-252 License No. R-102 Department of Nudear Engineering MSC 01-1120 TheUnivetsit y of'New Mexico Alhuquergue, New Mexico 87131-00DJ I Prepared by:
Ropert Busch
- Ch.iefRe~ctor Supervisor
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Reviewed by: . . '*
Reactor Safety AdVJsory cornmrttee .
~(r,J2.C1Jf t\pprovedby:
GaryQooper Reactor Administrator Revised<as: of Septe111b¢r 2019
OPERAT OR AND SENIOR OPERAT OR REQUAL IFICATI ON PROGRA M UNIVER SITY OF NEW MEXICO AGN-201 M REACTO R FACILIT Y A. Introduct ion The Universit y of New Mexico AGN-201 M Reactor Fad.lity is used primarily as a training reactor for undergraduate and graduate students. Experiments performed include sample activation, an approach to critical, reactor period and reactivity measurements, control rod calibrations, importance function measurements, and transfer function measurements. The reactor has also been used for activation of samples and for graduate student research in foil self-shielding and perturbation theory.
Licensed* staff for the Facility is made up of personnel from three categories:
- 1. Faculty Members : Reactor supervisors (including the Chief Reactor Supervisor) are faculty members who are licensed senior operators. The faculty members are regularly engaged in teaching reactor theory, reactor engineering, and nuclear engineering laboratory courses.
- 2. Nuclear Engineer ing Students: Students serve as Lab assistants, teaching assistants, and licensed operators. These students are actively engaged in a rigorous academic program covering reactor theory, reactor engineering, and nuclear engineeri ng laboratory experimental methods. Students who have been licensed generally serve as operators for 2 to 3 years while they are completing their study programs.
- 3. Nuclear Engineer ing Laboratory Technician: The Technici an is a licensed operator or licensed senior operator who generally has had previous reactor experience, and who serves the dual function of teaching assistant, and reactor maintena nce technicia n.
. For all three categories of personnel, the typical training program for preparation to take the licensing exam has been about 1 day/week for 12 weeks. Because of the academic and work experience of the staff and the basic simplicity of the reactor facility and operating procedures, extensive training programs are not required.
Therefore it is concluded that the requalification program for licensed personnel of this facility will not be required to be as elaborate and extensive as that outlined in 10CFR55, but it is designed to be consisten t with ANS-15.4 Selection and Training of Personne l for Research Reactors and NUREG 1478 - Operator Licensing Examine r Standards for Research and Test Reactors.
- Revised as of Septemb er 2019 Page 1
UNM AGN-201 Operator and Senior Operator Requali:fication Program B. Requalification Program
- 1. Schedule The Requalification Program shall be conducted for a continuous period not to exceed 24 months in duration. As part of the program, a one-day requalification training session will be scheduled annually. All licensed personnel will be required to participate. For scheduling purposes the session may consist of two Yi day sessions. For experienced licensed personnel, the annual maintenance will suffice in place of the lectures.
- 2. Lectures One-half-day of the Training session will consist of a review and discussion of the Reactor Operations Manual and material prepared for new operator and senior operator trainees. This material includes:
- a. Fundamentals of reactor theory
- b. General design features
- c. General operating characteristics
- d. Safety systems
- e. Instrumentation and controls
- f. Shielding and containment
- g. Standard and emergency operating procedures
- h. Security Issues
- 1. Conduct of Operations and operating log entries J. Radiation monitoring equipment
- k. Radiological safety
- 1. Technical specifications and bases
- n. Review of guidance documents, e.g., ANS15.4 and NUREG 1478 The Chief Reactor Supervisor or the Reactor Administrator will keep the Operations staff current with changes in the facility and with information from other sources. This can be done through meetings of the Reactor Operations Committee, email, memo, RSAC minutes, or other written documents. Notification of substantial changes will be documel).ted in the individual training files of the licensed personnel.
Revised as of September 2019 Page 2
UNM AGN-201 Operator and Senior Operator Requalificati9n Program
- 3. On-the-job Training The other half-day of the training session will consist of the following activities:
- a. Review and perform a monthly maintenance check
- b. Review and perform a daily reactor checkout
- c. Startup of the reactor and operation at licensed power
- d. Measurement of excess reactivity
- e. Measurement of reactivity worths of typical samples used in the training and activation experiments f Measurement of a safety rod reactivity worth using rod-drop techniques
- g. Simulated emergency with practice evacuation
- h. Reactor Shutdown Manipulation of the controls during these checks and operations will be rotated among the participating personnel. Participation in this session will assure that each licensed operator or senior operator is cognizant of facility design changes, procedure changes, and facility license changes. All elements listed in (a) through (h) above will be tested as part of the annual operations exam for each Reactor Operator and Senior Reactor Operator.
Revised as of September 2019 Page 3
UNM AGN-201 Operator and Senior Operator Requalification Program
- 4. Evaluation Written Examination: Every year, each licensed individual shall be given a written examination covering the areas described in Section B.2 of this document. (The licensed individual who develops, administers, and grades these examinations shall be waived from taking the examination for that year, but will take a written examination the following year. The responsibility for the examination shall rotate among the licensed senior operators or other qualified individuals so that each licensed senior operator shall be evaluated at least every two years.) A score of 70% or higher will require no additional training.
An overall score of 60% to 69% requires additional training in those areas or topics where weakness or deficiencies are indicated. During the training, the individual can continue to perform licensed duties under the supervision of a
. licensed senior operator. After the training program is completed, an oral examination shall be administered to evaluate the individual's performance in those areas covered by the program. Unsuccessful performance on the oral examination shall require the individual to complete an accelerated training program followed by a written examination. An overall score below 60% requires that an individual be relieved of licensed duties and receive training in an accelerated program. The accelerated program shall cover those areas where weakness and deficiencies are indicated, and it shall be completed within four months following the grading of the written examination. After the accelerated training is completed, a written examination shall be administered and successfully completed before the individual can resume perfonnance of licensed duties.
Evaluation of Reactor Operation by Certified Individuals: To maintain active status, each certified individual shall actively perform the functions of an operator or senior operator for. a minimum of four hours per calendar quarter. Supervision of these functions by
- licensed senior operators shall be considered equivalent to actual performance. Each certified individual is required to take an annual operational exam requiring 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 10CFR55.45(a) (2) through (13) inclusive to the extent applicable to the facility. These shall include but are not limited to reactivity manipulations in startup, shutdown, and other significant reactivity changes that demonstrate skill or familiarity with the reactivity control systems and general familiarity with the reactor safety systems. Also, the exam shall cover operator response to abnormal and emergency conditions as discussed in the UNM AGN-201M reactor Emergency Plan. Responsibility for these exams shall rotate among the senior operations staff with each senior operator being evaluated by another senior operator.
Revised as of September 2019 *Page 4
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UNM AGN-201 Operator and Senior Operator Requalification Program exam, If unsatisfactory performance is noted during the quarter or from the operational ted, then additional operation times will be scheduled for retraining. After this is comple ation to ensure that the the individual will undergo an additional operational examin is in a individual can competently manipulate the controls of the reactor. If the issue d duties until the deficie ncy is safety area, then the individual will be relieved of license corrected.
- in active Resumption of Active Status: If an operator or senior operator fails to mainta status, he/she shall cease to perform the functions authorized under his/her license. To regain active status, the Chief Reactor Supervisor or Reacto r.
. Administrator shall certify:
( 1) That the, qualifications :and. status of theJicensee are current and valid; and the *
(2) That the licensee has corripleted a minimriin of six hours of functions under direction of an operator or senior operator as appropriate and in the positio n to which the individual has been assigned.
(3) After completing the requirements in (2), that the individual has successfully completed an operational exam.
After this training and certification, the licensee will be restored to active status.
- 5. Records The A separate file for each licensed operator or senior operator shall be established.
ation in the requali fication attached form will be used to record and certify (1) particip ng training sessions (2) reactivity control manipulations, and (3) written and operati examination results. These files will also contain copies of written examinations regarding administered, the answers given by the licensee, and any additional information shall be
- training or requalification or each licensee. Records of medical examinations included along with the requirement for the next medical exam (every two years).
Revised as of September 2019 Page 5
UNM AGN-201 Operator and Senior Operator Requalification Program REQUALIFICATION TRAINING RECORD AGN-201M REACTOR FACILITY UNIVERSITY OF NEW MEXICO Name License Number Title License Expiration Date Date of Last Medical Exam - - - - - - - - - Next Medical Needed Before _ _ _ _ _ _ __
Requalification Training or Annual Maintenance Sessions ( one per year)
Date Session Type & Comments Certification i;
i i
I i Operational and Supervisory Time (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per quarter)
Quarter Op hrs. Supv hrs. I I Other Certification I
I I I I I I I I I I I I I I I I I I I I I I I Examination Results (1 operating exam per year, 1 written every two years)
I
.Date Exam Type Performance I I
Certification Revised as of September 2019 Page 6