ML20083H591

Responds to Re Implementation of Operator Requalification Program.Categories Included in Licensed Operator Exam Listed

ML20083H591
Person / Time
Site:	05000199
Issue date:	01/09/1984
From:	Kane R MANHATTAN COLLEGE, RIVERDALE, NY
To:	Chu A, Thomas C NRC, Office of Nuclear Reactor Regulation
References
NUDOCS 8401130265
Download: ML20083H591 (4)

Text

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.i MANHATTAN COLLEGE PARKWAY MECHANICAL ENGINEERING DEPARTMENT

. . RIVERDALC, NEW YORK 10471

.. (212) 92H145 January 9, 1984 Mr. Cecil O. Thanas, Chief Standardization and Special Projects Branch Division of Licensing United States Nuclear Regulatory Cmmission Washington, D.C. 20555 Attn: Ms. Angela T. Chu

Subject:

Docket 50-199, Your letter of October 31, 1983, Marthattan College Zero Power Reactor Operator Pequalification Program

Dear Ms. Chu:

In accordance with our letter of August 17, 1983, we implemnted our proposed Operator Requalification Program prior to approval action on your part. A status report was sent w Mr. H. Booher, Branch Chief for License Qualification on October 12, 1983. We are pleased that you feel our program meets nest of the requirements of Appendix A of 10 CFR Part 55. As requested in your letter of October 31, 1983, we provide our respones to your ocuments.

To place proper perspective on our response, please note the following.

i) The Manhattan College Zero Power Reactor is licensed for the loest power level by far of any academic research or test reactor in the United States, only 0.1 watt.

ii) The critical reactor is used only for experiments and demonstration in an undergraduate nuclear engineering course.

iii) The staff has only three licensed operators: one is the current (and recently installed) Chief Reactor Supervisor and another is the previous Chief Reactor Supervisor. All three staff mtbers are ful.1-time faculty members in either the Physics or Mechanical Engineering Departnents of Manhattan College who are only assigned on a part-time basis to the nuclear facility. All three licensed operators possess a doctorate in either Physics or Mechanical Engineering and are involved with the program only if they supervise the nuclear engineering course or associated laboratory. This represents orders-of-magnitude better qualification than power plant operators and orders-of-magnitude less ccnplication in the staffing needs.

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Mr. Cecil O. Thcznas January 9, 1984 iv) The reactor is of unique and unchanging design, developed by American Machine and Foundry in the late 1950's and possesses a small core within an open pool.

v) While we based our proposed program on the spirit and general guidelines of paragraph 1 through 6 of 10 CFR55, Appendix A, we point out that our reactor specifically falls under the guidelines of paragraph 7 of 10 CFR55, Appendix A, That paragraph states, "...the requalification prcgram for each licensed operator and senior operator of a research or test reactor. ..shall conferTn generally but need not be identical to the requalification program outlined in paragraphs 1 through 6 of this appendix." Paragraph 7 indicates that, "significant deviations. . .shall be permitted. . .if. . . approved by the Ccmnission. " We do not believe the deviations we have noted are significant (in terTrs of health and safety of the public) and are reasonible based on the unique nature of the facility and the unique qualifications of each operator at Manhattan College.

We now respond to the specific Staff Ccxme ,ts.

a) We agree with Staf f Coninent a; our letter of August 17, 1983 had two purposes: (1) to respond to a Severity Invel IV Violation anci (2) to describe a proposed Operator Requalification Program. The second purpose was acccxTplished by numbered paragraphs 1 through 6 of Attachment A to our August 17, 1983 letter. These nunbered paragraphs do not include specific names of individuals.

b) We agree with Staff ConTnent b and have reviewed 10 CFR 50.54 (i-1).

e c) We agree with Staff Content c and note that our intent is in exact accordance with the ccanent. We do not intend to allcw a licensed operator to remain qualified without such a lecture.

d) We have exanuned Section 5.3 of ANSI /ANS-15.4-1977 and note the consolidation of topics The categories of our examination will cover the seven topics listed.

(1) Nuclear Theory ad Principles of Operation (2) Design and Operating Characteristics (3) Facility Instrumentation and Control Systems (4) Facility Safety Systems and Fagineered Safety Features (5) Normal, AbnorTnal, and Dnergency Procedures (6) Radiation Control and Safety (7) Technical Specification and Bases e) We agree with Staf' Ccmannt e and would require additional training if the examination scores are unsatisfactory.

f) We do not agree with Staff Carnent f for the follcuing reasons.

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[ Mr. Cecil O. Thmas January 9, 1984 2

Appendix A is replete tith specific or implied exenptions i under the aecis of Paragraph 7 The Manhattan College Zero

Power Reactor is not a " production or utilization facility."

} As noted already in our introductory cantents, deviations which are insignificant for research and test reactors are

[ permissible. Significant deviations are permissible if approved by the Conmission.

The Introduction to 10 CFR Appendix A has the statment

" Individuals who maintain operator or senior operator j licenses for the purpose of providing backup capability to

} the operating staff shall participate in the requalification i program except to the extent that their normal dutires preclude the need for specific retraining in particular

. areas." The closest we care to a full-time operating staff

} is our Chief Reactor Supervisor and O would operate th3 a requalification programs. The normal duties of the Chief l-Peactor Supervisor and of the other part-time staff who provide backup include the administration of examinations and

, review of laboratory experiments on the theoretical aspects j of nuclear engineering on a mekly or nonthly basis. It is

} reiterated that every one of our operators has a dactorate in d

s either Physics or Mechanical Engineering.

j. Quite frankly, the administration of theoretical exarunations to these people would generate a great deal of paperwork without any tangible benefit whatsoever. These people are j eminently qualified by experience and training to ndminister J examinations in theoretical areas to (typically) non-degreed opera:rrs at production and utilization facilities. Final]y

~_ the Manhattan College Zero Power Reactor does not have the j "ccuplexity of design and operating modes of production and utilization facilities."

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g) We have reviewed the provisions of Section 6.5 of ANS 15.4 and

] Section 55.31 of 10 CFR Part 55 and agree with Staf f Cortnent g.

4 h) We do not agree with Staff Comtrer.t h. The cited 10 reactivitv i manipulations is apparently taken frce paragraph 30, Appendix A to 10 CFR 55. That paragraph applies specifically to a " production or utilization facility." That many manipulations represent a sizeable a

number of manipulations, particularly for our part-time staff, ampared a to the number we actually perform for teaching purposes over a two year

• period. The nurber of man-hours requir 2d to satisfy the requiremnts i Sac apply to a ful1-time staff on a production facility (if applied to i

j a part-time staff on a zero power test reactor) is an inappropriate g burden for our facility. There would be no benefit to this. Our Chief 1 Reactor Supervisor is the only staff nember who would normally operate the controls that rany times and he would operate the controls about i 100 times over a two-year period.

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Mr. ' Cecil O 'Ihmas January.9, 1984

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We hope our response is satisfactory and you can approve our Program. _

J Very truly yours,

& S,] k l-! Bonald S. Kane, Ph.D.

Chairman, Mechanical Engineering Dept.

} :- . Reactor Adnirtistrator RSK/ cod" cc: Br. Gabriel Kane, F.S.C., Ph.D.

Chief Reactor Supervisor

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