ML24054A539
| ML24054A539 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 02/23/2024 |
| From: | Murray S GE-Hitachi Nuclear Energy Americas |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| M240035 | |
| Download: ML24054A539 (1) | |
Text
M240035 February 23, 2024 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-001 10 CFR 50.90
Subject:
GEH Additional Information Supporting Authorization of the GE Nuclear Test Reactor Possession-Only License (POL)
References:
- 1) NRC License R-33, Docket 0500073, General Electric Hitachi (GEH) Nuclear Test Reactor (NTR)
- 2)
GEH License Amendment Request - Permanent Cessation of the GE Nuclear Test Reactor (NTR) and Possession Only Authorization, 10/6/23 (ADAMS accession #ML23279A110)
- 3)
Letter GEH Response to NRC Request for Additional Information, 1/26/24 (ML24026A196)
- 4)
GEH/NRC Post-POL Audit Meeting (Steams) to Discuss Approval of Final POL Amendment Request, 2/22/24 GE Hitachi Nuclear Energy Americas LLC (GEH) is providing the following information under Oath or Affirmation as the result of discussion (Ref. 4) with the NRC regarding final approval of the NTR POL amendment request (POLAR) (Ref. 2) as supplemented by additional information provided on January 26, 2024 (Ref. 3). Three items were discussed as requiring further clarification.
ITEM 1: The POLAR (Ref.2) includes a request on page 2 of 2 to delete R-33 License Condition 1.C.
RESPONSE: Upon further review, GEH has determined that License Condition 1.C is acceptable, and its inclusion is supported by the balance of the submittal. GEH therefore withdraws the request to delete License Condition 1.C. To further clarify, the POLAR is not requesting any changes to section 1 of the current operating license.
ITEM 2: Technical Specification 6.8.3(5) was added in revision 7 of the Technical Specifications (TS)
(Ref. 2, Enclosure 1) and reproduced in revision 8 (Ref. 3, Attachment 1) without providing justification in either case in the included safety analysis.
RESPONSE: TS 6.8.3(5) was added following the POLAR audit meeting on October 25, 2023, to ensure the NTR meets the record retention requirements of 10 CFR Part 50.59(d)(3).
ITEM 3: The NTR Certified Fuel Handler Training Program (CFHTP) provided as Attachment 3 to the January 26, 2024, letter (Ref. 3) appears to contain a typographical error in section 5.3 in that it contains an extra word and between the words facility and shall.
RESPONSE: GEH acknowledges that this is a typographical error, has corrected it, and is attaching a complete copy of revision 1 to the NTR CFHTP.
GEHitachiNuclearEnergy ScottP.Murray Manager,FacilityLicensing
3901CastleHayneRoad P.O.Box780 Wilmington,NC28402 USA
T(910)8195950 scott.murray@ge.com
M240035 U.S. NRC February 23, 2024 Page 1 of 2 Please contact me at (91 0) 819-5950 if you have any questions regarding this matter.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, S!ja~gp/~
Facility Licensing C/ : NTR Certified Fuel Handler Training Program (CFHTP), Revision 1, February, 2024 cc: NRC Region IV Administrator J. M. Borromeo, Branch Chief, USNRC/NRR/DANU/UNPL G. A. Wertz, USNRC/NRRIDANU/UNPL SPM 24-014
NTR Certified Fuel Handler Training Program (CFHTP)
Revision 1
Page1of5 February2024 Revision1
CERTIFIEDFUELHANDLERTRAININGPROGRAMFORTHE NUCLEARTESTREACTOR
Page2of5
- 1. OBJECTIVE This document defines the personnel and training requirements of the Certified Fuel Handler (CFH) program at the Nuclear Test Reactor (NTR).
The NTR no longer requires licensed reactor (RO) or senior reactor operators (SRO). By utilizing the existing core reel assembly as the fuel storage location and modifying the reactor systems to a Possession Only License Shutdown Configuration (POLSC) as defined by Technical Specification 5.3.1, the controls of the reactor can no longer be manipulated pursuant to 10 CFR 50.54(i).
Additionally, in the POLSC, ample negative reactivity is permanently affixed in the core so that the removal of fuel from the reactor (defueling) poses no potential for prompt criticality and defueling of the NTR is not an alteration of the core as discussed in 10 CFR 50.54(m)(2)(iv). Since licensed operators are no longer required to manipulate the controls of the reactor or to perform core alterations, they are to be replaced by the Certified Fuel Handler (CFH) and the Certified Fuel Handler Supervisor.
The selection and training of the CFH and CFH Supervisor provides an appropriate level of oversight commensurate with the reduced risks and relative simplicity of the facility systems needed for safe storage of spent fuel, including safe defueling, handling, and storage of spent fuel, and response to plant emergencies. CFHs must follow relevant technical specifications and approved fuel handling procedures. The CFHs are obligated to know, practice, and follow, when necessary, the facility safety and security programs.
- 2. EXPERIENCE/QUALIFICATIONS 2.1. CFH Supervisor (Level 3 Certified Fuel Handler Supervisor) - shall have at least 2 years of experience working in radiologically controlled environments and understand ALARA principles. Sufficient mechanical dexterity is required as evaluated by the Reactor Administrator (RA). At a minimum, requires a high school diploma or successful completion of a GED test. Maintain health/medical requirements required for the CFH job. The CFH Health Questionnaire will be used to assess health/medical requirements.
2.2. CFH (Level 4 Certified Fuel Handler) - Requires a high school diploma or successful completion of a GED test. Sufficient mechanical dexterity is required as evaluated by the RA.
Maintain health/medical requirements required for the CFH job. The CFH Health Questionnaire will be used to assess health/medical requirements.
2.3. Reactor Administrator (Level 2 Reactor Administrator) - experience requirements for this role are stated in Technical Specification (TS) 6.1.4.(1).
- 3. ROLES/RESPONSIBILITIES 3.1. CFH Supervisor - The CFH Supervisor is a non-licensed operator who has qualified in accordance with the NTR certified fuel handler training program approved by the NRC.
They will supervise other CFHs and perform CFH duties. The CFH Supervisor is responsible for fuel handling operations and ensures the fuel handling operations are done safely, that staffing is adequate, and that CFHs have current documented training and qualifications. The CFH Supervisor has the authority to authorize a temporary deviation to a procedure involved with fuel handling but must document that deviation and report it to the Reactor Administrator by the end of the next working day. A Certified Fuel Handler Supervisor shall be in the reactor cell during fuel handling operations.
Page3of5 3.2. CFH - The certified fuel handler is a non-licensed operator who has qualified in accordance with the NTR certified fuel handler training program approved by the NRC.
3.3. The CFH does not make decisions on fuel handing, decommissioning, or radiation protection. The CFH performs all necessary hands-on fuel manipulations under the direction of the CFH Supervisor and in compliance with approved fuel handling procedures.
3.3.1. The CFH only handles fuel when needed and only handles 1 fuel element at a time.
3.3.2. Fuel handling operations include only those required for defueling and fuel shipment from the facility.
3.4. Reactor Administrator - The Reactor Administrator shall ensure that the NTR is maintained according to the facility license and applicable regulations and is responsible for security and safety of the facility. The RA or his designated, certified alternate, will oversee CFH training including the assignment of generating, administering, and scoring written and operating tests. The RA may hold the concurrent position of CFH Supervisor as long as all requirements for the CFH Supervisor per section 2.1 above are maintained by the RA.
3.5. Level 1 License Holder (see TS 6.1.2.(1)) - The License Holder shall be responsible for review/approval of completed CFH Health Questionnaires.
- 4. TRAINING PROGRAM The training phase of the Certified Fuel Handler Training Program consists of lecture, and/or self-study of topics appropriate to the handling, storage, and monitoring of nuclear fuel, and includes training on CFH tasks as well as required fundamental topics.
4.1. Lectures and Self Study Topics to be covered include:
4.1.1. Design, function, and operation of systems used in handling, storage, monitoring of nuclear fuel, and auxiliary support systems.
4.1.2. Purpose and operation of the radiation monitoring systems.
4.1.3. Radiological safety principles and procedures including radiation hazards that may arise during normal and maintenance activities.
4.1.4. Conditions and limitations of facility license, including content, basis, and importance of Technical Specifications.
4.1.5. Assessment of facility condition and selection of appropriate procedures during normal, and emergency situations.
4.1.6. Fuel handling facilities and procedures.
4.1.7. Relevant NRC regulations and ALARA principles.
4.2. Job Performance Measures (JPM) CFH Training:
4.2.1. Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.
Page4of5 4.2.2. Manipulate (or simulation of) the fuel handling tool to obtain desired results during normal, and emergency conditions.
4.2.3. Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions.
4.2.4. Understand emergency conditions and remedial actions to be implemented according to the implementing emergency plan procedures for the facility.
4.3. A comprehensive final examination shall be administered at the end of the training program to provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of CFH tasks. The comprehensive examination shall include a written test and an operating test. Areas examined are described in 4.1 and 4.2.
4.3.1. The written test requires a minimum score of 80 percent to pass.
4.3.2. The operating test will consist of Job Performance Measures (JPMs). Passing criteria for an individual JPM is that the examinee successfully completes (or simulates) the assigned task in accordance with the governing procedure without missing any critical steps. Missed or incorrectly performed critical steps are the basis for JPM failure.
4.3.3. An individual who fails to pass either the written or operating test shall not perform CFH duties until he/she has completed a remedial training program and passes an appropriate retest. Only those portions of the original written or operating test that were failed need to be reexamined.
- 5. ACTIVE/INACTIVE STATUS To maintain active status, each CFH shall:
5.1. Successfully complete the required training prior to, but within six months of participating in defueling the NTR.
5.2. Maintain health/medical requirements required for the CFH job. The CFH Health Questionnaire will be used to assess health/medical requirements prior to participating in defueling the NTR.
5.3. Be cognizant of any changes to any part of the requirements and obligations for safe and secure fuel handling. Changes made in procedures and the facility shall be reviewed before participating in defueling the NTR.
5.4. Participate in the annual emergency plan drill and participate in drill critiques according to the site radiological emergency plan.
- 6. CFH HEALTH QUESTIONNAIRE AND REVIEW 6.1. All CFH applicants must fill out the NTR CFH Health Questionnaire when they apply to become a CFH.
6.2. All CFHs must fill out the NTR CFH Health Questionnaire within six months of participating in the defueling of the NTR.
Page5of5 6.3. The Level 1 License Holder or his designate, will review the CFH Health Questionnaire to determine that the candidate's medical condition is not such that it might cause operational errors that could endanger other plant personnel or the public health.
- 7. RECORDS Records of the training certification program will be maintained to document each CFH in the program. A summary document (log) will be maintained for each CFH that includes entries to support the CFH active-duty status, attendance dates for lectures, and references for any on-the-job training activities. Records will also include copies of the written and operating tests with the answers given by each CFH. Also, any additional training given in areas where CFH exhibited deficiencies. Records will be maintained until all fuel is shipped out of the facility and CFHs/CFH Supervisor are no longer needed.