ML24088A015
| ML24088A015 | |
| Person / Time | |
|---|---|
| Site: | University of Utah |
| Issue date: | 02/27/2024 |
| From: | Allison A Univ of Utah |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML24088A015 (1) | |
Text
1 NUCLEAR REGULATORY COMMISSION Docket No. 50-407 University of Utah TRIGA Reactor Exempon Request I.
Background.
The University of Utah TRIGA Reactor (UUTR, the licensee) holds the U.S. Nuclear Regulatory Commission (NRC, the Commission) Renewed Facility Operating License No. R-126 for the UUTR Training, Research, Isotopes, General Atomics (TRIGA) reactor (the facility), which is a research reactor located in Salt Lake City, Utah. Under this license, the licensee is authorized to operate the facility up to a steady-state power level of 100 kilowatts thermal power. The license is subject to the rules, regulations, and orders of the NRC.
II.
Request/Action.
The University of Utah TRIGA Reactor (UUTR) is currently in a shutdown/secured state pending necessary repairs to the reactor tank, and it is not expected to return to operation until Fall, 2024. As such, UUTR facility is unable to perform annual operating exams required in accordance with 10 CFR 55.59(a) to maintain qualification status. Although UUTRs Requalification Plan states, The console examinations are required only during those years in which reactor operation is possible, UUTR requests an exemption to the annual operating exam requirement as outlined below to maintain sufficient operators in a qualified status for supporting licensed activities necessary to restore UUTR back to operational status:
- 1) Andrew Allison (SOP-504549) received his SRO license on November 30th, 2021, and has successfully completed all requalification requirements apart from a second annual operating exam that was due on November 10th, 2023. Per UUTR Requalification Plan, the console examination consists of another licensed SRO evaluating pre-start checks, start-up, operational power, and termination. On September 14th, 2023, another licensed SRO, Edward Goodell (SOP-505176) observed Andrew Allison perform a reactor startup, reach operational power of 90kW, and then terminate the run. Additionally, Edward Goodell monitored Andrew Allison satisfactorily perform pre-startup checks on February 24th, 2024. UUTR intends to use these activities to constitute his console examination as described in the UUTR requalification plan to satisfy the annual operating examination requirement of 10 CFR 55.59(a). Therefore, this exemption will have Andrew Allison retroactively complete his requalification plan requirements effective September 14th, 2023, to maintain his qualified licensed operator status.
- 2) Edward Goodell (SOP-505176), Jesse Snow (RO-505180), and Anthony Couey (RO-505181),
will similarly become out of qualification on the one-year anniversary of their licensing date, March 27th, 2024. Prior to the March 27th deadline, facility SROs Andrew Allison and Edward Goodell will administer a series of annual lecture-based trainings covering the lecture topics discussed in UUTRs requalification plan and administer a written examination. UUTR facility requests an exemption for the annual operating exam be provided for these operators to continue having Edward Goodell, Jesse Snow, and Anthony Couey maintain their operator qualification status. To maintain proficiency with the pre-startup checks, Andrew Allison or Edward Goodell will monitor Jesse Snow and Anthony Couey perform the pre-startup checks as Reactor Operator, and Andrew Allison will monitor Edward Goodell perform the necessary pre-startup checks as Senior Reactor Operator. UUTR facility believes this is sufficient justification for these operators
2 to be permitted maintaining in-qualification status for licensed duties associated with the shutdown UUTR.
- 3) Finally, UUTR facility requests an exemption from the 10 CFR 55.53(e) requirement that a licensee shall actively perform the functions of an operator or senior operator for a minimum of four hours per calendar quarter during the period of April 2024 until September 2024. Once the reactor tank is emptied, the licensed duties performed for a shutdown reactor such as pre-start checks and a stationed console operator will be purposeless until the applicable detectors/equipment is restored to the tank in preparation for reloading the reactor core. Andrew Allison, Edward Goodell, Jesse Snow, and Anthony Couey will have extensive experience with these shutdown reactor licensed duties from the transfer of the fuel to the storage pits in Spring, 2024 and the 2 fuel inspections of 2023. A special refresher training will be conducted with the aforementioned operators to further enhance proficiency with licensed duties for reloading the reactor core.
III.
Justification In the exemption issuance document, Docket Nos.52-025 and 52-026; NRC-2008-0252, the Commission stated that:
Exemptions are authorized by law where they are not expressly prohibited by statute or regulation. A proposed exemption is implicitly authorized by law if all of the conditions listed therein are met (i.e., will not endanger life or property and is otherwise in the public interest) and no other provision prohibits, or otherwise restricts, its application. As discussed in this section of the evaluation, no provisions in law restrict or prohibit an exemption to the requirements concerning control manipulations; the endanger and public interest factors are addressed later in this evaluation.
In accordance with 10 CFR Part 55.59(b), additional training, If the requirements of paragraphs (a) (1) and (2) of this section are not met, the Commission may require the licensee to complete additional training and to submit evidence to the Commission of successful completion of this training before returning to licensed duties. Hence a proposed exemption should be lawful if the applicant can demonstrate receiving additional training and submit evidence of this training to the commission prior to returning to licensed duties. UUTR facility will document all training received by its licensed operators for NRC review.
This exemption will not endanger life or property because the purpose of this exemption is to enable facility operators to continue performing licensed duties with a shutdown nuclear reactor, which they already have extensive experience performing as mentioned previously.
Public Interest: UUTR is the only research reactor in the state of Utah and only one of a handful of university research reactors in the United States. Having UUTR in operational status benefits the public through its use in research and nuclear operator training. Furthermore, the reactor fuel currently stored in the UUTR needs to be expeditiously transferred out of the tank since the tank is currently prone to leaks, which increases the risk of removing the water shielding for the fuel.
I declare under penalty of perjury that the foregoing is true and correct. UUTR requests the Commission issuance of exemption no later than 27 March 2024 for UUTR to continue with its fuel transfer plans.
Andrew Allison February 27th, 2024_________
Andrew Allison, UUTR Interim Director Date