ML20118B952

Forwards Revised Operator Requalfication Program & Procedures for Implementation of Requalification Program

ML20118B952
Person / Time
Site:	University of Virginia
Issue date:	09/28/1992
From:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:	Alexander Adams Office of Nuclear Reactor Regulation
References
NUDOCS 9210080170
Download: ML20118B952 (11)

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SCHOOL OF ENGINEERING @

September 78, 1992 & APPUED SCIENCE Mr. Alexander Adams, Jr. NUCLLIR RLICIOR FACILITY Senior Project Managar U* " "* " ' d "" " k I '

Non-Power Reactors, Decommissioning ^ ""*" # " " ^ " "" P "" U " E and Environmental Project Directorate Unnce of wpna Division of Reactor Projects - III/IV/V N" l"" A V^ 2 3"3-2442 Office of Nuclear Reactor Regulation m e 34ao i A s w a c 5473 United States Nuclear Regulatory Commission Washington, D.C. 200555

Subject:

Docket No.50-62, Additional Information concerning the Operator Requalification Program for the University of Virginia Reactor Facility.

Dear Mr. Adams:

Please find enclosed a revised Operator Requalification Program and the Procedures for Implementation of the Requalification Program (which include an Annual Operator Evaluation Form). When the program was last revised by the reactor staff and reviewed and approved by our Reactor Safety Committee, the implementing procedures and evaluation form were -

part of the " package." I apologize for the implementing procedures not having been included with the program which was sent to you on June 4 for NRC review and approval.

These documents must be considered as a unit since the blanket statement made in the program, that research-reactor applicable portions of 10 CFR Part 55 are to be considered binding, is insufficient. Comparison of our program's statement with that of another facility in our region indicates that ours is shorter. Perhaps, the program for the other facility has its implementation built in implicitly. The justification for the short plan for our facility stems from an attempt by the staff to write (and in some cases, rewrite) facility documents with a -

minimalist principle in mind. We have found that repetition and verboseness in plans and their implementing procedures often lead to contradiction and misinterpretation.

Also, please find enclosed a 10 CFR Part 55 sub-part by sub-part comparison with the commitments made in our requalification program and implementing procedures. In this comparison, I indicate where, either (or both) in the program or the implementing procedures, the corresponding sub-parts of the regulation are addressed. With the g several modifications made in the program (approved by our RSC on )

09/22/92) and the additional material now provided tQ you, I expect that ,k)/

it will be possible to conclude that the progialatisets regulatory requirements. Nevertheless, please feel' f rdem t#clit 1Dild at (804)982-54 4 CL i ~1 - wr specifics are required.  % g pg t% gg,d daument is a true and Sinpere i e et capr of a _q m trewrM tefae

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Comparison of 10 CFR Part 55.59 Requirements With The UVAR Operator Requalification Program and Implementing Procedures.

50.59 Sub-Part Corresponding Requal Program or Procedures

.Section (a) (1) Program item A.1 (2) Program item B.3 & 4 (i) Procedure item C: a),b),c)

(ii) Procedure item B. & Annual Evaluation Form (iii) Not applicable to our reactor license (b) Not applicable to our reactor license (c) Requal Program approved by RSC and submitted to NRC (1) Program item A.1 (2) Procedures, A. (a through h)

(3)(i) Program A.2.

(ii) Procedures, B & Annual Evaluation Form (iii) Procedures A.h) and B.

(iv) Procedures A.b)

(v) Not applicable to our reactor license (4)(i) Program B.3 & B.4, Procedures B.& C.

(ii) Program B.3 and C (iii) Annual Evaluation Form (iv) N/A, no simulator, however there are emergency drills as per NRC approved Emergency .

Plan (v) Program, B.3 & Procedures, C.(last paragraph)

(5)(i) Program, C.1 and C.2.

(ii) Program, C.1 (iii) Program, C.1 (6) Not applicable to our reactor iicense (7) Use has been made of this provision to tailor the Program and its implementing Procedures to this facility.

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OPERATOR REOUALIFICATION PROORAM FOR Tile UNIVERSITY OF VIRGINIA REACTOR FACILITY A. Generel

1. This re.jualineation program applies to all licensed reactor operators of the University of Virginia Research Reactor (UVAR), located at the Reactor Facility of the University of Virginia. Reactor operator trainees may participate in the program as part of their training, however, since they are not licensed, the requali6 cation program does not cover their status.

The program shall meet the requirements of 10 CFR 55.59 and ANS Standard 15/., as applicable to research reactors. The piogram will follow a two year cycle. The program will be followed by successive requalification programs, that is, begin anew every two years.

2. In addition to a lecture series and annual operator evaluation, the requali6 cation program includes on-the-job training. For example, checklists, reactor startups and operation, core configuration changes, rod. drop measuremems and calibrations, shut-down margin and excess reactivity calculations, measurement at reactivity worth of experiments, emergency drills and surveillance activities are performed as required by UVAP Technical Specifications. These activities are infonnally critiqued by co- _

workers.

3. The Reactor Administrator or,in his absence, a designated Senior Reactor Operator, will be responsible for administering the requalification program.

4. This requalitication program is implemented by the " Procedures For implementing The Requalification Program For Licensed Operators Of The UVAR Reactor" which contains the "UVAR Requalification Program, Operator Annual Evaluation Form" mmu mm-amemmamamm.m_

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- B. Program _ i

~1. Start-utw and Checklists Each licensed operator will be required to complete reactor checklists and perform reactor start-ups and otherwise perform the functions of an operator or senior operator for a minimum of four hours per calendar quarter. If a licensed operator fails to operate the reactor during a calendar quarter, that indisidual will be ,

required to perform licensed duties for at least six hours under the cogninmce of a qualified senior operator prior to reinstatement as a qualified licensed operator.

2. Lectures During the program's two year cycle, each licensed operator is required to attend a series of lectures. Trainees may also attend these lectures. A cycle will normally begin in September (corresponding to the beginning of an academic year). The lectures will be pre-scheduled to run from September through June, with a break during the summer months of July and August, and continue the following September. The lectures will cover the following subjects: Reactor 'lteory and Principles of Operauon: Normal, Abnormal and Emergency Procedures; Techmeal Specifications; Reactor Instrumentation and Control Systems; Reactor Protective and Enginecied Safety Systems; Radiation Control and Safety; General and Specific Plant Operating Characteristics; applicable parts of 10 CFR and any major changes to procedures or equipment. The operator who .

misses a lecture will be required to review the lecture notes. This will be verified by the Reactor Administrator.

3. Written Examinations At the end of each two-year cycle a written exam will be administered to licensed operators to determine their knowledge of facility operations. An overall grade ot'.

70% or greater will be considered as passing. If an operator receives less than 70%.

on one or more sections of the exam, but has a passing grade overall, he/she will be ,

retrained in the deficient areas and given a make-up written exam covering only those arcat If an operator scores less than 70% overall on the examination, he/she will be excused from licensed duties, undergo retraining, and retake the entire exam.

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If an individual does not requalify within a calender quarter, Facility management will request the NRC to cancel the license of that individual.

The bi-annual exam will be composed and administered by a senior staff member with a Senior Operator License. This individual will be exempted from taking the exam required by this prognm.

The reactor operator trainec(s) may take the same exam as the licensed operators as part of their training whenever enough experience has been assimilated. The training program

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coordinator will review areas of weakness with the trainec(s).

4. Annual Operations Test Once cach calendar year, an evaluation will be made of each licensed perator. The supervisor (s) will observe the completion of checklists, reactor start-up and control.

If an operator is found to be deficient in some area of operation, this will be doenmented and the appropriate action to correct the deh*1cy taken and noted.

Reactor operator trainee (s) will receive this evaluation also, to gauge progress and areas that need strengthening. _

5. Physical Fitness.

Licensed operators will be required to undergo physical examinations at least once every two years to assure continued physierd titness to operate the reactor in a safe and ,

efficient manner.

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e C, Records

1. A file shall be kept for each licensed operator and operator trainee. The file shall contain legible secords obout checklists and start-ups perforrned by the individual, the content and results of written exams, the results of annual evaluations, additional trrining received covering areas of exhibited deficiencies, and the results of bi-annual medical exams. These personal records shall be retained until the opeator's or senior operator's license is renewed or surrendered or for a longer period if so ordered by the Nuclear Regulatory Commission.

2. Records showing the lecture schedule, content and attendance by the licensed operators and operator trainees will be kept in a separate requalification program tile.

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PROCEDURES FOR IMPLEMENTING Tile REQUALIFICATION PROGRAM FOR ,

l LICENSED OPERATORS OF TIIE UVAR REACTOR The following procedures are set forth to implement the Operator '

Requalification Program for the University of Virginia Reactor (UVAR).

The program will cycle on a 2 year schedule, running from September to June of each calendar year and terminating at the end of the second year with a written examination comparable to an NRC exam.

A. I.ectures All licensed operators will be required to attend a series of lectures.

A list of scheduled lectures will be distributed at the begining of each cycle, i.ectures will be scheduled to cover the following topics

a) Reactor Theory and Principles of Operation h) hormal, Abnormal and Emergency Procedures l

c) Technical Specifications

! d) Reactor Instrumentation and Control Systems e' 9eactor Protective and Engineered Safety Systems

' wadiation Control and Safety L g) General and Specific Plant Operating Characteristics j h) Applicable sections of 10 CFR i) Major Changes to Procedures or Equipment

- Each licersed operator will present at least one lecture during each cycle. If a lecture cannot be given on the scheduled date it.will be re-l scheduled at the earliest convenient date. If an operator or trainee misses

-a lecture, he/she will be required to review the lecture notes. This will be verified and do .mented by the Reactor Administrator. Self-study is also

, considered an adequate and appropriate training method.

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h it Annual Operating Test An annual evaluation will be made of each licensed operator and operator trainee (see attached form). Each will perform a duily checklist and a reactor startup. The evaluation will be made by the Reactor Supervisor (s) and will be based on compliance with written procedures and good engineering practices.

As a part of the evaluation, the evaluator (s) will question the operator or trainee on the appropriate actions to be taken for various emergency and/or -

abnormal conditions. Deficiencies uncovered during the evaluation will be noted and the operator or trainee retrained in the deficient areas.

C. Written 1 xammation At the end of each two-year cycle a proctored written exaniination will be given to all licensed Senior and Reactor operators. Operator trainees may also take the exam. The examination will be based on the current NRC format (systems approach) and cover the following areas:

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a) Reactor Theory and Facility Operating Characteristics. -

b) Normal and Emergency Operating Procedures and Radiological Control c) Facility and Radiation Monitoring Systems.

An overall grade of 70% or greater is passing. Individuals scoring less than 70% on one or more areas but passing the exam overall will be required to re-study and be ictested on those areas. Individuals scoring less than 70'X overall on the exam will be removed from licensed activities and required to take " rapid" retnini9g. After retraining they will be required to retake the entire exam.

Once a score of 70'3 or greater is achieved, operators can be returned to 2

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! licensed activities. If an operator cannot pass the exam within a calendar quarter after retraining, facility management will request the NRC to cancel the license of that individual.

The exam will be composed and administered by a senior staff member who is liceased as a Senior Reactor Operator. This individual will be exempt from taking the exam req sired under the requalification program. This exemption will be rotated among the senior icactor staff, as practical.

D. Physical Ikaminations 1.icensed operators will be required to take and pass physical exams by qualified medical personnel at least once every two years. If a medical problem is found that could result in incapacitation during the time the individual is operating the reactor, another licensed operator will be required to be present at the console whenever the individual with the anomalous medical condition is performing the duties of a licensed operator.

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If a licensed individual is found at work to be under the influence of alcohol or illegal or mind-altering drugs he/she will not be allowed to perform licensed activities and appropriate action will be taken by facility management in conformance witn UNa.'s substance abuse policy.

Licensed operators are requested to report to the reactor supervisor (s) prescription drugs that they may be about to take and which have known side affects, such as drowsiness, which may render them temporarily unsuited for reactor console operation.

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F. _QqcJmLef t AvaDability 6

I!very l! censed operator and trainee is given a personal copy of the requalifwation prograrn and procedures for permanent reference, fellowing each revision. These documents are required reading.

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. UVAR REQUaLITICATION PROGRAM

, , OPERATOR ANNUAL EVALUATION FORM a

Purpr, set to demonstrate operator *a ability to snicly ' operate' t he UVAR.

So satisfy +he requirements of 10 CPR $$.59(n)(2)(11).

Operator __

Dates This evaluation / / Last evaluations / 'l 1, Familiarity with' Daily Checklistl

[] Eacellent ((]VeryGood [] Good . Needs refresher 2, Manipulation of Console Controlst

[]In accordance with SOP's ((] Retraining and ratesting indica' ed

3. Accurate Instrument Readingst

([)Alltimes ((lHosttimes, retraining indicated

4. Correct Identification of Annunciatores

((j Yes ((] No, will be retrained and retested

5. Observed to rollow Procedures

((]Yes [] No, will be retrained and retested

6. Observes and Checks Instruments Regularlyt l))Ves [] No, will be retrained and retested

7. Knowledge of selected Alaras, Setpoints, Radiation Monitoring Systema and Significant Radiation flasards:

[] Yes [] No, will be retrained and reteated 8 Familiar.ity With Selected Tech. Spec. Requirementst

[] Yes [] No, will be retrained and reteated

9. Familiarity With Procedures For Abnormal Reactor Operating Conditione s

[]Yes -((jNo, will be retrained and retested

10. Familiarity With Selected Emergency Trocedures

(() Yes -[~]No, will be retrained and retested Certificationt([]Theaboveoperatorhas passed the annual operator' evaluation and in general, has during the past year discharged licensed responsibilities competently and safely.

[])The above operator has not passed the annual operator evaluation, therefore, he/she will be retrained and retnoted in those areas.

Reactor Administrator Reactor Supervisor (when applicable) --

I-have seen the above evaluation and I agree to-carry out the recommendations.

Operator Projected date of next evaluations j((]Copyofevaluationformsent to operator

[]Copyof. evaluation form sent to Reactor Director

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