ML102720021

University of California at Irvine Nuclear Reactor Facility (Ucinrf) - Request for Additional Information Regarding the Ucinrf Operator Requalification Program

ML102720021
Person / Time
Site:	University of California - Irvine
Issue date:	10/01/2010
From:	Tran L N Research and Test Reactors Licensing Branch
To:	Miller G E University of California - Irvine
tran L, NRC/NRR/DPR/PRLB 415-4103
References
TAC ME2431
Download: ML102720021 (6)

Text

October 1, 2010 Dr. George E. Miller Department of Chemistry 516 Physical Sciences 1 University of California, Irvine Irvine, CA 92697-2025

SUBJECT:

UNIVERSITY OF CALIFORNIA AT IRVINE - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE UNIVERSITY OF CALIFORNIA AT IRVINE NUCLEAR REACTOR FACILITY OPERATOR REQUALIFICATION PROGRAM (TAC NO. ME2431)

Dear Dr. Miller:

We have reviewed the University of California Irvine Nuclear Reactor Facility (UCINRF) Operator Requalification Program that was submitted by letter dated April 24, 2000. During our review, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 30 days of the date of this letter in order for the U. S. Nuclear Regulatory Commission staff to complete the review. In accordance with Title 10 of the Code of Federal Regulation Section 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the requested information, we will continue our evaluation of your application. If you have any questions regarding this review, please contact Ms. Linh N. Tran at 301-415-4103 or Mr. A. Francis DiMeglio at 301-415-0894.

Sincerely,

/RA/ Linh N. Tran, Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-326

Enclosure:

As stated

cc w/encl: See next page

ML102720021 NRR-088 OFFICE PRLB:PM PRPB:LA PRLB:BC PRLB:PM NAME LTran GLappert JQuichocho LTran DATE 9/30/2010 9/30/2010 10/01/2010 10/01/2010 University of California at Irvine Docket No. 50-326 cc: Dr. Donald Blake, Chair Department of Chemistry University of California, Irvine Irvine, CA 92697-2025 Mr. Steve Hsu Radiological Health Branch State Department of Health Services P.O. Box 9442732 Sacramento, CA 94234-7320 Dr. Michael R. Gottfredson Executive Vice Chancellor University of California, Irvine Irvine, CA 92697-1000 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611 Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION UNIVERSITY OF CALIFORNIA IRVINE REACTOR FACILITY OPERATOR REQUALIFICAITON PROGRAM DOCKET NO. 50-326 Please provide responses to the following request for additional information within 30 days of the date of this letter.

RAI 1 Title 10 of the Code of Federal Regulations (10 CFR) Section 55.59(b) states:

(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.

The University of California at Irvine Nuclear Reactor Facility (UCINRF) Operator Requalification Program, under the heading "Requirements," Item #6 states:

6. Participate in review regarding any test ((1) or (2) above) item that is unsatisfactory prior to resuming any reactor critical or supercritical operation.

The phrase critical or supercritical operation is very narrow. How does the facility ensure that other licensed duties, not requiring reactor critical or supercritical operation (e.g. fuel movement) are also covered? Also, would an individual who failed a requalification examination be allowed to be the senior reactor operator (SRO) On-Call?

RAI 2 Regulation 10 CFR Section 55.59(c)(3)(iv) states:

(iv) Each licensed operator and senior operator reviews the contents of all abnormal and emergency procedures on a regularly scheduled basis.

The UCINRF Operator Requalification Program, under the heading "Requirements," Item #5 states: 5. Participate in immediate discussions whenever mechanical or procedural changes are implemented at the facility, whether or not they directly affect reactor characteristics.

How does the facility ensure that abnormal and emergency procedures are reviewed even when changes are NOT made to those procedures during the course of a requalification plan cycle?

RAI 3 Regulation 10 CFR Section 55.59(c)(4)(iv) states:

(iv) Simulation of emergency or abnormal conditions that may be accomplished by using the control panel of the facility involved or by using a simulator. When the control panel of the facility is used for simulation, the actions taken or to be taken for the emergency or abnormal condition shall be discussed; actual manipulation of the plant controls is not required. If a simulator is used in meeting the requirements of paragraph (c)(4)(iii) of this section, it must accurately reproduce the operating characteristics of the facility involved and the arrangement of the instrumentation and controls of the simulator must closely parallel that of the facility involved. After the provisions of § 55.46 have been implemented at a facility, the Commission approved or plant-referenced simulator must be used to comply with this paragraph.

The UCINRF Operator Requalification Program, under the heading "Requirements," Item #3 states: 3. Carry out reactor operations for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in each calendar quarter. These operations may include facility maintenance activities when the reactor is shutdown, but should include at least one start-up, one operation above 1 kilowatt power, and one shutdown (except when the reactor is not operational for any period exceeding three months.

How does the facility ensure that all operators are evaluated during simulation of emergency or abnormal conditions during the course of a requalification plan cycle, as required?

RAI 4 American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.4, Section 5.5, "Selection and Training of Personnel for Research Reactors," states:

5.5 Examination administration and evaluation The minimum acceptance score shall be 70% for each category of the written examination and 70% for the entire operating and oral examination. Individuals who did not achieve passing scores in one or more of the categories listed in Sec. 5.4 may be reexamined following retraining in the deficient areas. The responsible authority may waive reexamination in categories with passing scores provided the candidate has demonstrated proficiency in those portions of an examination.

The UCINRF Operator Requalification Program has no pass/fail criteria. Please provide pass/fail criteria for facility administered requalification written examinations and operating tests.

RAI 5 Regulation 10 CFR Section 55.53(h) "Conditions of Licenses," states:

[Each license contains and is subject to the following conditions whether stated in the license or not:] - The licensee shall complete a requalification program as described by § 55.59."

and 10 CFR Section 55.59(a)(1) and (2) state:

(a) Requalification requirements. Each licensee shall -

(1) Successfully complete a requalification program developed by the facility licensee that has been approved by the Commission. This program shall be conducted for a continuous period not to exceed 24 months in duration. (2) Pass a comprehensive requalification written examination and an annual operating test.

The UCINRF Operator Requalification Program, under the heading "Scope," states:

- One Senior Operator will be designated as the Training coordinator for each two year cycle. The Training Coordinator prepares and scores all examination materials, schedules reviews and documents operator performance and will only be required to meet items (3), (4) and (5) below. In theory, these two sentences could exempt one person indefinitely from the requirements of taking an annual operating test, and a biennial written examination. One way other facilities have been able to keep this wording in their requalification programs is to add an addition sentence specifying that this position is to be rotated among all senior operators, so that no one individual is permanently exempted from meeting the requirements for 10 CFR Section 55.53(h) and 10 CFR Section 55.59(a)(1) and (2). Please modify your scope to ensure that no one individual is permanently exempted from meeting the requirements of 10 CFR Part 55.