ML18334A097

Univ of Texas - Revision to Previous Response to 07/26/2018 Request for Additional Information for Proposed Operator Requalification Program

ML18334A097
Person / Time
Site:	University of Texas at Austin
Issue date:	11/19/2018
From:	Whaley P M University of Texas at Austin
To:	Wertz G A Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML18334A097 (2)

Text

COIJ.EGE OF ENGINEERING THE UNIVERSITY OF TEXAS AT AUSTIN Departmmt of Mechanical Engineering*

1 University Station C2200

• Attstin., Texas 78712-0292 Te!ephone(512)471-I 131 FAX (512)471-8727 11/19/2018 ATIN: Document Gontrol Desk Nuclear Regulatory Commission Washington D.C. 20555-0001 Geoffrey A. Wertz Project Manager U.S. Nuclear Regulatory Commission Research and Test Reactor Licensing Branch

SUBJECT:

Docket No. 50-602, Facility Operating License NO. R-29, Revision to Previous Response to 07/26/2018 Request for Additional Information for Proposed Operator Requalification Program

REFERENCE:

1. Docket No. 50-602, Request for Additional Information Re: Operator Requalification Program Review for Renewal of Facility Operating License NO. R-29 for the University of Texas at Austin Research Reactor (EPID No. L-2017-RNW-0032)

Sir: 2, Docket No. 50-602, Facility Operating License NO. R-29, Response to 07/26/2018 Request for Additional Information for Proposed.Operator Requalification Program . . ;, ' . :~* We respectfully requ~st revision of the previously submitted response to Request for Additional Information 52 (of reference 2), regarding the Operator Requalification Program, to wit: 52. The regulations in 10 CFR 55.59(a)(2) state: "(a) Requalification requirements.

Each licensee shall -(2) Pass a comprehensive requalification written examination and an annual operating test." QPR Section 5.1.2 second bullet states: "Should (if possible) not to be exempt more than once during sequential training plan cycles." ORP Section 5.1.2 NOTE states: "Test writing responsibilities will be assigned (where possible) so .that no individual is exempt from the biennial comprehensive written examination more t,han one~ in sequential training cycles.;, . ORP Section 5.2 NOTE states: "The preparation and conduct of the Annual Operating Test will be assigned (where possible) so that no individual is exempt from the annual examination more than once each training cycle." The NRC staff finds that the phrases "if possible 1' and,"where possible" effectively negates the training requirements of each respective section of the ORP, and the /1 () D _? /fLJZ t? ;JI.I-licensed operator could be indefinitely exempt from the requirements of taking a written examination and operating test. ' Revise the ORP or clarify the phrases "if possible" and "where possible" to ensure that no one licensed operator is permanently exempted from meeting the requirements of 10 CFR 55.59, or justify why no change is needed. In the bulleted list at 5.1.2, the note revised will be formatted as the second bullet, and a third bullet added:

• Test writing responsibilities will be assigned so that no individual is exempt from the biennial comprehensive written examination more than once in sequential training cycles

• If the level of staffing does not permit a senior operator to participate in any sequential biennial comprehensive written examination (consistent with 1 OCFR55.59, Requalification (a) Requalification requirements (iii)) the facility will request at least 30 days prior to th.e examination schedule that the USN RC to administer the comprehensive requalification written examination; the senior operator is authorized to perform licensed duties until the examination is administered and the senior operator is certified successful The Section 5.2 NOTE (preceding 5.2.1) will be revised to state: The preparation and conduct of the Annual Operating Test will be assigned so that no individual is exempt from the Annual Operating Test more than once each training cycle. If staffing does not permit a senior operator to participate in any sequential Annual Operating Test (consistent with 1 OCFR55.59 Requalification (a) Requalification requirements (iii)) the facility will request at least ~O days prior to the examination schedule that the USN RC administer the Annual Operating Test; the senior operator is authorized to perform licensed duties until the examination is administered and the senior operator is certified successful.

If there are any questions, please feel free to contact P. M. Whaley at whaley@utexas.mail.edu or 512-232-5373.

Sincerely, P. M. Whaley I declare under penalty of perjury that the foregoing is true and correct. W. S. Charlton Director, Nuclear Engineering Teaching Laboratory