ML20203K134

Informs That Licensee Has Revised NRC-approved Reactor Operator re-qualification Program Reflecting Regulatory Requirement for Facility to Have Licensed Reactor Operators as Long as Fuel Is Located at Facility

ML20203K134
Person / Time
Site:	General Atomics
Issue date:	12/16/1997
From:	Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Alexander Adams NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
38-67-2849, NUDOCS 9712220219
Download: ML20203K134 (6)

Text

4 m N AHMWCW December 16,1997 38/67 2849 0 4

• 90cument Control Desk ATTN: Alexander Adams, Jr Senior Project Manager Non Power Reactors, Decommissioning and Environmental Project Directorate Division of Advanced Reactors & Special Projects Of0cc of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Facility Lleenses R.38 and R 67; Dockets 50 89 and 50163: Submittal of Revised Reactor Operator Requall0 cation Program

References:

1) Amendment No. 43 to U.S. NRC Facility License No. R 67, withdrawing authorization to operate OA's TRIG A Mark F Reactor, issued March 22,1995

2) Amendment No. 35 to U.S. NRC Facility License No. R 38. withdrawing authorization to operate OA's TRIGA Mark i Reactor, issued October 29,1997

3) Tomasoni, Beth A (U.S. DOE), letter to Mr. J. Neal Blue (OA) dated December 17, 1996

Dear Mr. Adams:

. As you are aware, the facility licenses for General Atomics' (OA's) non-power Mark I and Mark F TRIG A reactors have both been amended to withdraw anthorization to operate, i.e., possession only license amendments have been issued,(Refs. I and 2). Furthermore, both reactors have been rendered incapable of operating by removing all fuel elements from their cores and placing them in the secure storage canal of the Mmk F reactor. Unfortunately, though the U.S. Department of Energy (DOE) is obligated to accept this fuel,it has indicated that it will not do so until some future date (Ref. 3). Tims, the fuel will have to remain in storage at GA's TRIGA Reactor Facility until such time DOE approves its shipment to an authorized DOE site.

The fact that GA must store fuel at its shutdown facility leads to a situation wherein, even though there is no longer a reactor to operate, there is a regulatory requirement for the facility to have licensed reactor operators as long as there is fuel located at the facility. Thus, GA must maintain licensed reactor operators whose responsibilities will be limited to only those activities associated with the safe secure storage of fuel and the eventual movement of the subject fuel when it is packaged for shipment off site to a DOE facility.

Accordingly, G A has revised its NRC-approved reactor operator re-quali0 cation program to reflect the above describi d situation consistent with the referenced license amendments. A copy of the revised requaline.: tion program is attached for your review and approval. Also enclosed is a copy of the associated

" Annual Reactor Operator Evaluation" form, if you have any questions regmding the above, please do not hesitate to contact me at (619) 455-2823, or Dr. Junaid Razvi at (619) 457 8850.

• I Very truly yours, Ell lE,5RP'IR '

MS Dr. K:ith E. Asmussen, Director Licensing, Safety and Nuclear Compliance M,,,

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r7 Attachment No.1 -

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GA Letter No.38/67 2849 December 16,1997 - Page 1 General Atomics' TRIGA Reactors Facility Reactor Operator Re-qualification Program

References:

1) Ame adment No. 43 to USNRC Facility License No. R-67, removing authority from the license to operate the TRIGA Mark F Reactor, issued 22 March 95.

2) Amendment No. 35 to USNRC Facility License No. R-38, removing authority from the license to operate the TRIGA Mark i Reactor, issued 29 October 97.

1: . Participation in Day-to Day Activitics In compliance with the referenced Amendments to the USNRC Facility Licenses No. R-67 and R-38, which were separately issued by the USNRC to place the Mark F and Mark i Reactors into Pc3 session-Only License (POL) status, the scope of daily routine duties and tasks to be performed by licensed Reactor Operators / Senior Reactor Operators (RO/SROs) at the tjeneral Atomics TRIGA Reactors Facility (TRF) must be reduced to reflect the amended license conditions. Accordingly, RO/SRO participation in day-to-day activities at the TRF under current POL license status will include the following:

a. Maintenance, monitoring. and surveillance of the Mark F Pool Canal utilized for the interim storage of spent TRIGA fuel elements,

b. Annual review of TRF emergency procedures.

c. Annual review of TRF administrative procedures,

d. Review of changes to TRF procedures, aoplicable regulations, and license amendments.

c. Annual review of theory and operation of Fuel 1landling Tools, as des.ribed in the TRF Training Manual, ev rent revision.

f. Annual review of Fuel Movement p.rocedure, TRF Standard Operating Procedure No.16, current revision.

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Attachment No.1 -

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' GA Letter No. 38/67 2849 December 16,1997 - Page 2 11:- Actual Reactor Operations .

. a, . Practice Fuelllandling- ,

3 Under the amended POL' conditions for the Mark F and Mark I Reactors, operation of either of the reactors is not authorized. Licen e-authorized activities -

'for RO/SROs shall necessarily be limited to fuel handling actions. The requisite -

skills associated with salb fuel handling shall be maintained by RO/SROs by the performance of five practice handling transfers of graphite dummy elements on an annual basis.

b'. l Annual Reactor Operator / Senior Reactor Operator Evaluation

- In addition to the practice fuel handling described in Part lla, above, the TRF Physicist-in-Charge (PIC) shall evaluate each RO/SRO for license Re-qualification on an annual basis. This evaluation shall include an assessment of the knowledge and skills of the Re-qualification candidate in the areas of facility startup/ shutdown, fue' storage / fuel handling systems, and familiarity with documentation. Successful RO/SRO Re-qualification shall be contingent upon the satisfactory evaluation of the candidate in all areas of applicability.

III: ' Hiennial Written Examination Due to the limited actions authorized under the POL license conditions, the current requirement for the satisfactory completion of a biennial RO/SRO written examination is considered unnecessary.

IV:. ' Records

' Rscords shall be maintained by the TRF PIC for each licensed RO/SRO to document the following:

a. The review of TRF emergency and administrative procedures (Part I).

b.- - The satisfactory completion of five practice fuel handling actions using graphite Edummy elements (Part fla).

c. Satisfactory Annual Reactor Operator Evaluation (Part iib).

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+l+C:NCAL ATOMIC 3 c i- TRIGA Reactors F '

ANNUAL REACTOR OPERA, 21 4.1ATION Nan.e ._. SROD !G od 8 = Satisfactory 1,J = Unsatisfactory

• 13g = Not Applicable CATEGORY EVAI,UATION

1. FACILITY STARTUP & SIIUTDOWN

a. Startup

1. Stariup Checklist

2. Anticipation & Response to Events

c. Shuh.own 1, Shutdown Checklist

2. Monitoring Requirements II. FUEL STORAGE & FUEL IIANDI.ING SYSTI".1S

a. Fuel and Fuel llandling

1. Storage

2. Ilandling

b. Fuel Storage Systems

1. WaterTreatment System

2. Water Conductivity Monitoring S~ sem

3. Water Radiation Monitoring System

4. Water Temperature Monitoring System

5. Tamper-Safe Security Systems

c. Instrumentation and Control Systems

1. Area Radiation Monitoring System

d. ElectricalSystems

1. Normal Operation

2. Alternate Supplies

Annual Reactor Oper: tor Ev luation Page 2 as *

e. Ventilation

1. Norma. Operation

2. Emergency Procedures

f. Integrated Facility Operations

1. SNM Control / Accountability Requirements

2. Security Systems

3. Personnel Access Requirements 111. FAMILIARITY WITH DOCUMENTATION

a. Standard Operating Procedures

b. Emergency Procedures

c. Administrative Procedures

d. Technical Speci0 cations

c. Ilealth Physics Procedures

f. SNM Control / Accountability Logs

g. Fuel Storage / Maintenance Logs 4

IV. ADDITIONAL TRAINING REQUIRED (INDICATE AREA)

• Any unsatisfacory evaluation shall be supponed by a detailed explanation above.

Date Performed By 1