ML24250A104
| ML24250A104 | |
| Person / Time | |
|---|---|
| Site: | University of Utah |
| Issue date: | 09/05/2024 |
| From: | Allison A Univ of Utah |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML24250A104 (1) | |
Text
September 5, 2024 ATTN: Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
University of Utah Supplemental Information Responses for Exemption Request To Whom It May Concern, This letter is in response to Supplemental Information Request for UUTR dated August 22nd, 2024 (Acc.# ML24220A021). The NRC proposed questions are italicized with UUTR responses following the proposed questions
- 1. It is not clear to the NRC staff as to why all of 10 CFR 55.59 (a) was requested to be exempt if the need is only for the annual operating exam. Please provide additional justification as to why an exemption to 10 CFR 55.59 (a) is required.
The requirement for the annual operating exam is listed under 10 CFR 55.59 (a). Specifically, 10 CFR 55.59 (a) paragraph 2 states Pass a comprehensive requalification written examination and an annual operating test. Which is in reference to what each licensee shall do for requalification requirement. UUTR is specifically requesting an exemption from the requirements of 10 CF 55.59 (a) (2.ii) which states, The operating test will require the operator or senior operator to demonstrate an understanding of and the ability to perform the actions necessary to accomplish a comprehensive sample of items specified in 10 CFR 55.45(a) (2) through (13) inclusive to the extent applicable to the facility.
- 2. The NRC staff notes that the licensee requested retroactive exemptions to requalification and license requirements that do not meet the regulatory requirements. The exemption request lists a start date of March 1, 2024 (for the 10 CFR 55.59 exemption) and April 1, 2024 (for the 10 CFR 55.53 exemption). Regulatory requirements are subject to NRC enforcement and retroactive exemptions to regulatory requirements is not authorized by law. Exemptions from NRC requirements are effective from the time of issuance by the NRC and for the period specified in the exemption granted. Please revise the exemption request accordingly.
UUTR Facility acknowledges this comment, and by this letter, modifies the exemption request to have exemption start date be effective starting at the NRCs earliest convenience. UUTR will bring its operators into active status by performing training as described in the next section.
- 3. The NRC staff requests additional information regarding the special refresher training that will be provided to the licensed operations staff prior to reloading the core. If the special refresher training is not in accordance with the NRC approved requalification program, please provide the content of the training, how this training will be used to bring operators back into requalification and/or active status, and how the training will be documented.
The special refresher training will be in accordance with NRC approved requalification program for UUTR. It will consist of the eight topics as outlined in the lecture program (Section 3 of UUTR requalification program). A written examination will be administered following completion of the lecture-based training. As an additional training to address UUTR staff going greater than a year without operating and a calendar quarter without performing licensed duties, UUTR will send an SRO(s) to Reed college (or Oregon State University as an alternate) to observe a TRIGA reactor
approach criticality and enter the power range. While other operators will be performing their associated duties with the reactor in a shutdown condition (such as reactor operator during the reloading of fuel into the reactor), the senior reactor operator(s) that observe approach to criticality and operation in power range will be responsible for operating/monitoring as an SRO the reactor during control rod calibration and thermal power calibration. In accordance with 10 CFR 55.53.f.2, these SROs will ensure all other operators from the facility perform six hours of shift functions under their SRO direction prior to the other operators performing their duties as a reactor operator while restoring UUTR to an operational status. Once UUTR is in an operational status (which will be recorded with the successful completion of a thermal power calibration at 90kW), UUTR will complete annual operating tests in accordance with the UUTR training plan description of a console examination. This training in combination with a written examination and an exemption from the annual operating test/quarterly licensed functions will bring operators back into requalification by having them complete all requalification requirements mentioned in 10 CFR 55.59 (a).
- 4. The exemption request provides the purpose of the request but does not provide the NRC staff a justification for how granting this exemption will not endanger life or property. The NRC staff requests: a. Justification for how exempting the reactor operators from the requirements will not endanger life or property when performing license duties under this exemption.
Exempting reactor operators from these requirements will not endanger life or property because the UUTR reactor has been designed and analyzed with various safety features to prevent damage to itself or life. The specific duties intended to be performed under this exemption are the movement of irradiated fuel and restoration maintenance of the reactor in order to perform operating examinations. UUTR staff is the most experienced it has ever been with moving irradiated fuel and the components of the annual operating exam have no relevance to fuel movement operations. Similarly, it is common for UUTR operators to go 2 years without performing fuel handling since fuel inspection is performed every two years. Although UUTR staff will have gone over a year without operational experience of the reactor, there will not be a risk to life or property when the reactor is operated because of the UUTRs protective actions and other safety features in its design. In the unlikely event if UUTR staff incorrectly operating the reactor, these safety features will shut down UUTR to prevent any danger to life or property. To further enhance safety, UUTR will perform the training described in the previous section to ensure operators are as proficient as possible prior to performing duties under this exemption.
- b. The request does not provide how exempting operators at the University of Utah from 10 CFR 55.59 (a) or 10 CFR 55.53 (e) will be in the best interest of the public. Justification for why this exemption is in the best interest of the public is requested.
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 reactor operator training. The state of Utah, via the tax payers of the public, provides a substantial portion of the budget required to fund the UUTR facility with the expectation that the reactor will be used for research and educational purposes.
Since this exemption will be used to restore the reactor to an operational status, it is in the best interest of the public to grant this exemption. The public interest of safe nuclear operations with this exemption is described in the above section.
I swear under penalty of perjury that the foregoing is true and correct.
If you have any questions or concerns regarding this request, please contact me at (314) 333-1420 (cell).
Respectfully, Andrew Allison Andrew J. Allison, University of Utah TRIGA Reactor Interim Director Department of Civil and Environmental Engineering University of Utah Office Phone: 801.581.4188 E-mail: andrew.allison@utah.edu