ML20087A045

Forwards Rev 1 to Operator Requalification & Recertification Training Program Plan of Univ of Florida Training Reactor,Jul 1991 Through June 1993

ML20087A045
Person / Time
Site:	05000083
Issue date:	12/26/1991
From:	Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL
To:	Michaels T Office of Nuclear Reactor Regulation
Shared Package
ML20087A048	List: ML20087A045 ML20087A052
References
NUDOCS 9201080134
Download: ML20087A045 (4)

Text

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NUCLEAR ENGINEERING SCIENCES DEPARTMENT

, Nuclear Reactor Facility University of Florida -

Ef.S. Vemataan,04 octor WCtlAt HACTOe Sut0WG c*=* r** um December 26,1991 Pnene (904) 3921429.Teles M330 3

hir. Theodore S. hiichaels, Senior Project hianager Non-Power Reactors, Decommissioning and Environmental Project Directorate Division of Advanced Reactors and Special Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

UFTR Requalification Program

Dear hit. Michaels:

In response to your letter dated November 13, 1991 asking for responses to eleven (11) questions concerning the UFTR operator requalification program submitted May 31,1991, we have completely revised the UFTR Operator Requalification and Recertification Training Program Plan to reflect more accurately the program as we have been implementing it. As per our telecom of November 6,1991, we are and have been in i ' compliance with the new requirements of 10 CFR Part 55 and have decided to completely mvise the Plan to reflect this compliance.

Previously this Training Program Plan was updated only by adding items to the Training Schedule in Appendix A. Although a considerable number ofitems have been added in the past six(6) years to nearly double the number of scheduled training, examination .or other sessions, these changes were not reflected in the body of the plan. This is why the Plan as L

submitted did not appear to meet the new Part 55 requirements while the Plan as implemented has been considered to meet all Part 55 requirements.

Because so many changes were involved to update the body of the Plan and to renumber all Sections in a consistent format, the decision was made to revise the Plan in its entirety.

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Nevertheless, the opening section and the general order ofitems are uncnanged. The entire new Plan also had to be reentered for storage on disk since it no longer existed on any machine at our facility. In addition, the schedule in Appendix A is rekeyed but the two-year schedule of training sessions and other items in unchanged from that submitted in May,1991 for the July,1991 to June,1993 time period, do g e a Mpe' '

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Mr. Theodo;e S. Etichaels

. U.S. Nuclear Regulatory Commission December 26,1991 Page 2 To facilitate your review, the numbered questions posed in your enclosure with the letter i c r%vember 13,1991 are answered here along with reference to the original Plan submitted in May,1991 and to the appropriate sections of the enclosed UFTR Operator Requalification and Recertification Training Program (Revision 1, 12/91):

O_uestion Number Answer 1 Yes, the requirements of the revised 10 CFR 55 and the current revision of ANSI /ANS 15.4 are being met as referenced (per Section 0 now labelled Section 1.0,first paragraph).

2 Section llA of the previous Plan requires covering all but certain security procedures every year. Security procedures not available to the public are covered in Security Plan training conducted biennially. In the revised Plan, see Appendix A where SOP training is scheduled for February,1992 and April, 1993 with Physical Security Plan Training scheduled once in Decembe ,1992.

3 Yes, a comprehensive written examination is give to all operators biennially; only the exam producer is exempted. This required enmination is scheduled for June,1993 in Appendix A of the original Plan; in the revised Plan it is still scheduled in Appendix A for June, 1993 but the requirement is also delineated in Section 1.2.2.2.

4 No practical examination is given after fuel handling training; all operators are required to perform manipulations with the proper tools, cask and dummy fuel bundles as part of this practical training. The training is evaluated as satisfactory or not satisfactory and documented on training forms found in SOP-0.8. The annual examination on procedures does cover fuel handling procedures and so there is an examination at this point.

5 Yes, OJT is part of the UFTR training program. Though not delineated in the body of the original Plan, certain OJT training requirements are listed on the schedule in Appendix A~. In the revised Plan, the same items are listed on the schedule in Appendix A but the requirements are also outlined in the body of the plan in Section 1.3.2.6.

- Mr. Theodore S. Mice '

U.S. Nuclear' Regulatoiy Commission December 26,1991 Page 3 Ouestion Number Answer 6 Yes, there is a continuing requirement that a designated Senior Reactor Operator review the training folders / notebooks semiannually See Section Vill of the original plan and Section 1.9, Paragraph 1 of the revised Plan.

7 Yes, the 10 CFR 55.53(f) requirements are being met and have been met since the new Part 55 was effective. Though not referenced in the original Plan, this requirement is specifically addressed in Section 1.3.2.4 of the revised Plan. The remediation requirements of 10 CFR sis 3(f)in the event the requirements of Section 1.3.2.4 are not met are delineated in Section 1.3.2.5. In addition, the facility monthly reports have referenced the 4-hour requirement for licensed reactor operators since May,1987 when the new 10 CFR 55 became effective. Since the four-hour requirement was first tracked, the monthly reports indicate continual attention to this requirement.

8 Yes,Section VI A in the original Plan does refer to the two-year licenses allowed prior to March,1987. However, this meets the requirements for biennial examinations. Currently the biennial evaluations are performed biennially (every two years) per Section 1.6.6of the revised Plan. There is also a written comprehensive examination administered biennially per Section 1.2.2.2 of the revised Plan; this examination is also referenced in the answer to Question 3.

9 The reason for the differing times is that a nearly passing grade of 65%-79% generally indicates less additional study is required so only 60 days is allowed for retraining while accelerated retraining for grades below 60% is allowed 4 months for completion because of additional time that will be needed for study. These requirements are delineated in Sections 1.6.1.1 and 1.6.1.2 of the revised Plan.

10 In this area of grade requirements and retraining, there is considerable change in the revised Plan, in general using the guidance in ANS/ ANSI 15.4. Per Section 1.6.1.3,a 65%-79%

grade does not necessitate removal of an operator from licensed duties. Per Section 1.6.1.3, a grade of less that 65 %

necessitates an evaluation and the individual may be removed from licensed duties. In addition, Section 1.6.4 requires that any deficiency that affects safety shall be promptly remediated, l

Mr. Theodope' S. Michae's

, U.S. Nuclear Regulatory Commission December 26,1991 Page 4 Question NumbcI h er 11 Yes, the operator requalification training records are maintained in auditable form via the individual notebooks and the master training notebook. This requirement is addressed in Section Vill of the original Plan and in somewhat more detail in the revised Plan in Section 1.8.3 for Records Retention and in Section 1.9 for Requalification Document Review and Audit.

We trust that this submittal is complete and will facilitate review of our Training Program Plan. If you have further questions, please let us know.

Sincerely, William G. Vernetson Director of Nuclear Facilities y

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Enclosure cc: R. Piciullo RSRS

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