ML20079B348

Forwards Addl Info Requested W/Respect to Approval of Proposed Rev of Operator Requalification Program

ML20079B348
Person / Time
Site:	Idaho State University
Issue date:	12/22/1994
From:	Clovis R IDAHO STATE UNIV., POCATELLO, ID
To:	Mendonca M Office of Nuclear Reactor Regulation
References
TAC-M89577, NUDOCS 9501050475
Download: ML20079B348 (4)

Text

,

, ,- \

1 l

December 22,1994 l

f*0 -JG Marvin M. Mendonca, Senior Project Manager STATE UNIVERSITY Non-Power Reactors and Decommissioning Project Directorate United States Nuclear Regulatory Commission Washington. D.C. 20555-0001 -

Dear Mr. Mendonca:

Attached is the additional information (Ref: TAC NO. M89577) that you c% or requested with respect to approval of the proposed revision of our l D**i's requalification plan.

! Campus Box $XO rocaello Idaho 83209 a o Should you have any questions regarding the additional infomtion provided, please feel free to contact me at (208) 236-3637.

Sincerely, 9.LicM R. David Clovis Reactor Supervisor 7

% i t i t- OF InAHO )

) SS

' h COUNTY OF RANNOCK )

pd NUHNrHJBED AND SWORP BEFORE ME THIS M DAY OF T M p,xllbt . IR4 it<4, w--

OFFICIAL SEAL SI N URE-RESIDING AT: Ac D /

COMMISSION EXPIRES: 2/7MMO

/ /

l phone-

/ h (20r> 2%2902  %";.#

FAR (208) 2 4 4538 h h Dah obob B4 ISU is An Equal Opportunity Employer 0$0 ,

V PDR

, RESPONSE FOR REQUEST FOR ADDITIONAL INFORMATION i l FOR RESEARCH REACTOR OPERATOR REQUALIFICATION l PROGRAM j AT IDAHO STATE UNIVERSITY DOCKET NO. 50-284 (Ref: TAC NO. M89577)

ITEM #1: i Request: Provide clarification of this point to ensure that the operator is required to !

perform a minimum of six hours of shift function in a reasonable time period after the quarter in which the four hours of minimum licensed activity was not accomplished. 1 Response: In no case is it the intent of the proposed requal plan to bank hours from a time greater than two or more calendar quarters for the calendar quarter in which that the operator is trying to re-certify. As stated on page 4, Part VI, para. 2, "Part o/

these sbc hours oflicensed functions may be from the pnwfous calendar quarter. "

The word " previous" in the above sentence implies only the prior calendar quarter. It in no way implies that the requal plan is attempting to " bank" an operator's hours  ;

beyond that time frame. If an operator performs 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of licensed functions in quarter 1, he/she has failed to meet the required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of licer sed funct!ons to stayed certified, and is therefore da-certified. To re-certify, the operator needs to perform 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of licensed functions. This facility is requesting that we be allowed '.o  :

use hswo from the previous quarter only, in this case quarter 1, towards the 6 hoJrs needed for re-certification in quarier 2.

To provide further clarification, changes (italicized) have been made to the i proposed requal plan Page 4, Part VI, para. 2 to read as follows:

i "If an operator has not actively performed the functions of an operater duringa calendar quarter, he/she shall satisfactorily demonstrate birdher competence i

before resuming his/her licensed functions. This is accomplished by performing at least six hours of licensed functions, including at least one O.P #1 Startup and Shutdown, under the direction of a licensed operator. Part of these six hours of licensed functions may be from the hours from the previous calendar quarter on/f. Upon completion of this activity, the operator shall be certified for operation by the Reactor Supervisor."

Page 4 of the proposed requal program is enclosed. Please replace it with the copy of page 4 I sent earlier.  ;

To.re-iterate, the facility wants to use hours of licensed functions only from the

, prwlous quarter to be applied toward the six hours of licensed functions for recertification in the present quarter. If the operator has not performed any hours of licensed function in a calendar quarter (e.g. quarter 1), the operator must perform six hours of licensed function in the quarter of recertification (e.g. quarter 2, 3,4, etc.) '

The facility feels that knowledge and skill retention would not be degraded if this were approved. We are asking for approval of the part of the requal program under 10 CFR 55.59.c.7.

ITEM #2: -

Request: Provide what mechanism is provided for operators who miss a scheduled

• requalification lecture to be provided with a makeup lecture.

Response: The history of the 27 year old reactor facility has shown that there has never been a problem with operators attending the required requal lectures.

Furthermore, lectures are given to different operators at different times due to scheu ling conflicts of operator availability. Still, all the required lectures get i accomplished.

There are few operators here (5 total) compared to that of nuclear power plants and getting the lectures accomplished has never posed any difficulty. This says a lot for this facility considering that one operator is an undergraduate student, two work at the Idaho National Engineering Laboratory at Argonne National Labs - West, one is a full professor, and the other is a part time graduate student and full-time staff member at Idaho State University. Getting all operators in one room at one time is somewhat difficult, and therefore usually two lectures are given en each subject to ensure all ,

operators receive there minimum number of required lectures. The USNRC has also never required us to place " mechanisms" into motion to ensure lectures are accomplished for all operators. This is evident by reviewing all of our past approved and currently approved requal programs. However, in 1993, an Operator Requalification Tracking System (basically a scheduling tool) was implemented to ensure that all operators get their lectures, medical exams, written and console exams, and shift duties completed in an administratively controlled fashion. This facility has no intention of referencing this tracking system into the requal program; doing so is a sign of administrative over-regulation. What we have done for 27 years works well and that how we propose to keep it. (

l l

l l

l i

.s. ,

jw  !

h- .}

V,. . Evaluations (Continued) s .

2. Consple Examination. The licensee shall be assigned a rating of either  !

SATISFACTORY or UNSATISFACTORY. In order to attain a rating of ~ l SATISFACTORY, the licensee should demonstrate an understanding of the  !

operation of all apparatus and mechanisms. 'Ihis is evaluated through the j case and smoothness the operator performs the prestart checks, startup,  :'

power operation, and termination.' If the licensee fails to attain a rating of SATISFACTORY, the lic shall be removed from his/her licensed i duties and enrolled irian at training progam in the deficient area. -l VI. Operator Reinstatement ,

j An operator may be removed from active status by failing to actively perform the  !

functions of an operator during any calendar quarter or by failing to attain a satisfactory  !

grade on an evaluation exam. The calendar quarters are as follows: January through j March, April through June, July through September, and October through December. j 10CFR55.53(f) outlines the requirements for operator reinstatement.  :

i N, if an operator has not actively performed the functions of an operator during a calendar- l 3 quarter, he/she shall satisfactorily demonstrate his/her competence before resuming l

• his/her licensed functions. This is accomplished by performing at least six hours of  ;

licensed functions, including at least one O.P #1 Startup and Shutdown, under the j direction of a licensed . perator. Part of these six hours of licensed functions may be  !

from the hours from the previous calendar quarter only. Upon completion of this  !

activity, the operator shall be certified for operation by the Reactor Supervisor.  ;

) \

If an operator has failed to attain a satisfactory grade on any evaluation, he/she shall j demonstrate his/her compxnce before resuming his/her duties. This is accomplished through participation in additional training in the area of deficiency. Upon completion of the training, the operator shall be certified for on by the Reactor Supervisor  :

' ~

after successfully completing another ev area of deficiency. j VII. Records  % ,

Operator Requalification tracking shall be maintained through a number of. logs and forms. Lecture attendance shall be maintained on the Requalification/ Training Lecture ,

Forms. Each operator will record their performance of licensed functions upon  !

completion on the Individual Operator Licensed Function Tracking Form. The annual I written examination key sha'l be kept as part of the Operator Requalification records. j

A record shall be maintained for each licensee and shall contain a current copy of the 4 licensee's reactor operator license, copies of all written examinations administered to the licensee during the requalification penod, the medical examination form from the licensee's last medical exam, and the licensee's Requalification Program Progress Checklist. ,

i hev,1.TBA I Pep 4

)

l

.