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{{Adams | number = ML24054A539 | issue date = 02/23/2024 | title = GEH Additional Information Supporting Authorization of the GE Nuclear Test Reactor Possession-Only License (Pol) | author name = Murray S | author affiliation = GE-Hitachi Nuclear Energy Americas, LLC | addressee name = | addressee affiliation = NRC/NRR, NRC/Document Control Desk | docket = 05000073 | license number = R-033 | contact person = | case reference number = M240035 | document type = Letter | page count = 1 | project = | stage = Other }} =Text= {{#Wiki_filter:GEHitachiNuclearEnergy ScottP.Murray Manager,FacilityLicensing 3901CastleHayneRoad P.O.Box780 Wilmington,NC28402 M240035 USA T(910)8195950 February 23, 2024 scott.murray@ge.com 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 Elect ric Hitachi (GEH) Nuclear Test Reactor (NTR) : 2) GEH License Amendment Request - Permanent Cessation of the G E Nuclear Test Reactor (NTR) and Possession Only Authorization, 10/6/23 ( ADAMS accession #ML23279A110) : 3) Letter GEH Response to NRC Request for Additional Informatio n, 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 f ollowing information under Oath or Affirmation as the result of discussion (Ref. 4) with the NRC r egarding final approval of the NTR POL amendment request (POLAR) (Ref. 2) as supplemented by additiona l information provided on January 26, 2024 (Ref. 3). Three items were discussed as requi ring 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. GE H 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 th e Technical Specifications (TS) (Ref. 2, Enclosure 1) and reproduced in revision 8 (Ref. 3, Att achment 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 Oct ober 25, 2023, to ensure the NTR meets the record retention requirements of 10 CF R Part 50.59(d)(3). ITEM 3: The NTR Certified Fuel Handler Training Program (CFHTP) provide d as Attachment 3 to the {{letter dated|date=January 26, 2024|text=January 26, 2024, letter}} (Ref. 3) appears to contain a typograp hical 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 correc ted it, and is attaching a complete copy of revision 1 to the NTR CFHTP. 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 Enclosure 1 NTR Certified Fuel Handler Training Program (CFHTP) Revision 1 February2024Revision1 CERTIFIEDFUELHANDLERTRAININGPROGRAMFORTHE NUCLEARTESTREACTOR Page1of5 : 1. OBJECTIVE This document defines the personnel and training requirements o f the Certified Fuel Handler (CFH) program at the Nuclear Test Reactor (NTR). The NTR no longer requires licensed reactor (RO) or senior reac tor operators (SRO). By utilizing the existing core reel assembly as the fuel storage location an d modifying the reactor systems to a Possession Only License Shutdown Configuration (POLSC) as defin ed 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 perman ently 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 Hand ler (CFH) and the Certified Fuel Handler Supervisor. The selection and training of the CFH and CFH Supervisor provid es an appropriate level of oversight commensurate with the reduced risks and relative simp licity 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 t echnical specifications and approved fuel handling procedures. The CFHs are obligated to kn ow, 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 an d understand ALARA principles. Sufficient mechanical dexterity is required as eval uated by the Reactor Administrator (RA). At a minimum, requires a high school diplom a 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 requirement s. 2.2. CFH (Level 4 Certified Fuel Handler) - Requires a high sch ool diploma or successful completion of a GED test. Sufficient mechanical dexterity is re quired 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 requirement s. 2.3. Reactor Administrator (Level 2 Reactor Administrator) - e x perience 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 oper ator who has qualified in accordance with t h e N T R c e r t i f i e d 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 h andling operations are done safely, that staffing is adequate, and that CFHs have current d ocumented training and qualifications. The CFH Supervisor has the authority to author ize a temporary deviation to a procedure involved with fuel handling but must document that de viation and report it to the Reactor Administrator by the end of the next working day. A Ce rtified Fuel Handler Supervisor shall be in the reactor cell during fuel handling op erations. Page2of5 3.2. CFH - The certified fuel handler is a non-licensed operator who has q ualified in accordance with the NTR certified fuel handler training program approved b y 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 en sure that the NTR is maintained according to the facility license and applicable regulations an d is responsible for security and safety of the facility. The RA or his designated, certified alt ernate, will oversee CFH training including the assignment of generating, administering, and scor ing written and operating tests. The RA may hold the concurrent position of CFH Superviso r 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 Ho lder shall be responsible for review/approval of completed CFH Health Questionnaires. : 4. TRAINING PROGRAM The training phase of the Certified Fuel Handler Training Progr am 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 inc lude: 4.1.1. Design, function, and operation of systems used in handl ing, storage, monitoring of nuclear fuel, and auxiliary support systems. 4.1.2. Purpose and operation of the radiation monitoring system s. 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, includin g content, basis, and importance of Technical Specifications. 4.1.5. Assessment of facility condition and selection of approp riate 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. Page3of5 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, includi ng 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 train ing program to provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of CFH tasks. The comprehensive examinat ion shall include a written test and an operating test. Areas examined are describe d 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 Measu res (JPMs). Passing criteria for an individual JPM is that the examinee successfully complet es (or simulates) the assigned task in accordance with the governing procedure withou t missing any critical steps. Missed or incorrectly performed critical steps are the b asis for JPM failure. 4.3.3. An individual who fails to pass either the written or op erating test shall not perform CFH duties until he/she has completed a remedial training program a nd passes an appropriate retest. Only those portions of the original writte n 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 requirement s prior to participating in defueling the NTR. 5.3. Be cognizant of any changes to any part of the requirement s and obligations for safe and secure fuel handling. Changes made in procedures and the facili ty shall be reviewed before participating in defueling the NTR. 5.4. Participate in the annual emergency plan drill and partici pate 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 Questi onnaire 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. Page4of5 6.3. The Level 1 License Holder or his designate, will review t he CFH Health Questionnaire to determine that the candidate's medical condition is not such th at 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 maintaine d to document each CFH in the program. A summary document (log) will be maintained for each C FH that includes entries to support the CFH active-duty status, attendance dates for lectur es, and references for any on-the-job training activities. Records will also include copies of th e 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 shi pped out of the facility and CFHs/CFH Supervisor are no longer needed. Page5of5}}

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