ML20151T503

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Application for Amend to License SNM-696,exempting NRC Licensed Reactor Operators from Retraining Requirements of License.Fee Paid
ML20151T503
Person / Time
Site: 07000734
Issue date: 12/21/1987
From: Asmussen K
GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To: Rouse L
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20151T506 List:
References
28908, 696-1159, NUDOCS 8804290051
Download: ML20151T503 (3)


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December 21, 1987 s/

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Mr. Leland C. Rouse, Chief

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Fuel Cycle Safety Branch Divisicn of Fuel Cycle, Medical, Academic

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Office of }Alclear Material Safety & Safeguards U.S. M1 clear Regulatory Cznission Qr Washington, D. C. 20555 d /g

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Subject:

Docket No. 70-734: St@t-696; Request to Exempt NFC Licensed

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Reactor Operators frca Retraining Requirernents of St@t-696 Dear Mr. Rouse Within the last several months, I have informally discussed with Mr.

Dave McCaughey the need for the subject exemption.

Mr. McCaughey agreed that such a request had merit.

Accordingly, the following request is hereby subnitted.

GA Technologies Inc.'s (GA) special nuclear material (St@l) license specificaticus state in Sectico 3.3.5, "Training," that enployees who handle Stm other than under the direct supervisico of another trained individual, uust have ccupleted a radiological safety course.

Further, in the same section under "Retraining," there is a requirement for annual retraining on selected subjects. Accordingly, GA has been requiring annual retraining of all such employees who handle SPE, including our NRC licensed reactor operators (ROs) and senior reactor operators (SRoe) who work at GA's TRIGA reactor facility.

In the case of the ROs and SROs, this requirernent of our S!Fr-696 license is redundant and unnecessary.

Etc licensed Ros and Saos are required by 10 CFR 55.59, "Operator's Licenses - Requalification," to successfully ccuplete cn a continuing basis a requalification program covering, among other topics, both ruliological and nuclear safety.

This requalificatica program is a ccotineous program, and upon its conclusion, is prceptly followed, pirsuant to a continuous schedule, by successive requalification programs.

The requalification program involves both lectures and on-the-job training with written examinations and operating tests.

Topics typically covered include, but are not limited to, radiation controls, radiologic safety, nuclear safety, health physics, health physics 8804290051 85 g g4 h M hge i

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instrmentation, shielding, reactor physics, and applicable portions of Title 10, Code of Federal Regulations.. Appropriate records of this training are maintained by 'IRICA facility management.

Clearly, the training our NRC licensed Ros and SROs receive fra the' regular and continuing requalification progra required by 10 CER 55 more than satisfies the retraining requirement inposed by our materials license.

It is not an efficient use c3 resources to have our R0s and SROs participate in duplicative and unnecessary training sessions.

%erefore, GA hereby requests that NRC licensed ROs and SROs be exempted frca the annud retraining requirement of our SW696 license.

Bey will, of course, continue to be subject to the regular and continuing requalification training program required by 10 CFR 55.59.

If you should have any questions regarding this request, please contact me at (619) 455-2823.

Very truly yours,

&Md d. k Keith E. Asmussen, Manager Licensing, safety and Nuclear Cepliance KEA/mk i

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