ML20217P096

Forwards Response to 980105 RAI Re Revised Reactor Operator Requalification Program.Table Encl to Facilitate Review of Response Also

ML20217P096
Person / Time
Site:	General Atomics
Issue date:	02/24/1998
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
38-67-2877, TAC-MA0282, TAC-MA0283, TAC-MA282, TAC-MA283, NUDOCS 9803100030
Download: ML20217P096 (8)

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Febraary 24,1998 38/67-2877 1

VIA OVERNIGIIT DELIVERY SERVICE i Document Control Desk l

l ATTN: Alexander Adams, L., Senior Project Manager i Non-Power Reactors, Decommissioning and

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Enuronrr.:ntal Project Directorate Division of Advanced Reactors & Special Prejects 1 Office of Nuclear Reactor Regulation l U.S. Nuclear Regulatory Commission l Washington, DC 20555

Subject:

Facility Licenses R 38 and R-67; Docket t,50-89 and '0-163: Response to Request for  ;

Additional Information (TAC .Nos. MA0.: L and MA026 t)

Reference:

Mr. Alexander Adams, Jr., Letter to Dr. Keith E. Asmussen,"Requcst for Additional Inf ormation - Revised Reartor Operator Requalification Program (TAC Nos. MA0282 and MA0283)," dated January 5,1998

Dear Mr. Adams:

The purpose of this letter (and enclosure) is to provide General Atomics' {GA's) responses to the l

referenced request for additiorsal informatior.. Specifically, GA's respoases have bet n incorporated into a revised version ofits NRC-approved reactor operator requalification program. The revised operator requaliQcation program incorporates each of the changes requested, as well as the answers to cach of the questions asked. Because r f the extent of the revisions to this relatively brief document, a complete copy of the revised requalification progrva is attached for your review and approvol. Also enclosed is a copy of the associated " Annual Reactor Operator Evaluation" form.

To facilitate your review, also enclosed is a table which lists for each r _1uest/ comment from Refaence 1, the corresponding paragraph of the enclosed revised operator requalification prograra where GA's response may be found.

If you have any questions regarding the above, please do not hesitate to contact me at (619) 455-2823.

Very truly yours,

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(9 'N Dr. Keith E. Asmussen, Director f, 1.icensing, Safety and Nuclear Compliance l

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Enclosures:

as stated fl[ObV i 9803100030 900224

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' Enclosure to GA Letter No.38/67-2877 February 24 1995 Correlation Between NRC Requests /Commcats (of Ref. I) and Pt . graph of Operator j Requalification Program Incorporating GA Response ,

1 NRC Comment No. (Ref.th GA Response in keanni. Proeram Paragrsnh No.

1 II a (1) and II c (1) 2 IIc(2) 3 III 4 Il a (2), b (2) and c(2) and III b

$ II a (2), b (2) and c(2) and III b 6 II d and Illc ,

I 7 Ig I 8 IV e I

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l General Atomics TRIGA* Reactors Facility Reactor Operator Requalification Program

References:

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1. Amendment No. 43 to USNRC Facility Licer.se No, R-67, removing authority from the license to operate the TRIGA Mark F Reactor, issueo 22 Murch 95.  !

2. Amendment No. 3.i to USNRC Facility License No. R-38, removing authority ,

from the license to operate the TRIGA Mark I Reactor, issued 29 October 97.

L Participation in Day-to-Day Activities In compliance with the referenced Amerdments to the USNRC Facility Licenses No. R-67 and R-38, which were separately issued by the USNI C to place the Mark F and Mark I Reactors into Possession-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 General 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:

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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 amergency procedures.

c. Annual review of TRF administrative procedures.

d. Review of changes to TkF procedures, applicable regulations, and license amendments.

e. Annual review of theory and operation of Fuel Handling Tools, as described in the  !

, TRF Training Manual, current revision.

f. Annual review of Fue' Movement procedure, TRF Standard Operating Procedure No.16, current revison. I l g. Familiarization with the operational and maintenanu: requirements of TRF area 1 I radiation instrumentation, monitoring, and alarm systems, i

February 24,1998 - Page 1

II. Actual Reactor Operations

a. Practice Fuel Handling (1) Under the amended POL conditions for the TRIGA Mark F and Mark I Reactors, operation of either of the reactors is not authorized. License-authorized activities for RO/SROs shall necessarily be limited to fuel handling actions. The requisite skills associated with safe fuel handling shall be maintained by RO/SROs by the performance of in-pool practice

, handling transfer manipulations of standard dummy elements. In order to maintain current qualincation, each RO/SRO shall perform a minimum of five practice fuel handling manipulations each calendar year.

(2) Should a RO/SRO fail to complete the requisiie five practice handling transfers of standard dummy elements in a given calendar year, per Section iia (1) above , qualified RO/SRO status could be reinstated by the satisfactory cornpletion of five practice handling transfers of standard dummy elements under the supervision of the TRF Physicist-in-Charge (PIC) or qualified designee.

b. Annual Reactor Operator / Senior Reactor Opemtor Evaluation (1) The TRF Physicist-in-Charge (PIC) or qualified designee shall evaluate each RO/SRO for license re-qualification on an annual basis. This -

evaluation shallinclude an assessment of the knowledge and skills of the re-qualification candidate in the areas of facility startup/ shutdown, fuel 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.

(2) Should a RO/SRO fail to score satisfactorily in any of the topic areas of the Annual Reactor Operator / Senior Reactor Operator Evaluation, per Section iib (1) above, reinstatement of qualified RO/SRO status would necessitate specific review of the applicable topic (s), as directed by the TRF PIC or qualified designee, and the subsequent satisfactory re-evaluatiou of the candid:Je by the TRF PIC or qualified designee. Topical review may consist of discussions, hands-on familiarization sessions, lectures, and/or self-study documentation review, as deemed necessary and appropriate by the TRF PIC or qualified designee, to bring the candidate to an acceptable level of expertise.

February 24,1996 Page2

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c. Routine TRF Maintenance Activities l

(1) In or&r to maintain current familiarity with TRF systems and hardware, each kO/SRO shall spend a minimum of four hours per calendar quarter participating in routine facility maintenance tasks and/or related activities described in Section I. Time spent performing practice fuel handling l manipulations (Section iia), may be applied to fulfill this RO/SRO qualification requirement.

(2) Should a RO/SRO fail to meet the quarterly requirements, per Section IIc(1) above, reinstatement of qualified RO/SRO status shall be contingent upon the satisfactory completion of a minimum of six hours performance of routine TRF maintenance activities under the direction of the TRF PIC l or qualified designee.

d. TRF PIC Requirements If the TRF PIC or qualified designee is a SRO, that individual shall also

j. satisfactorily meet the operations and evaluation requalification requirements, as set forth in Sections iia, iib, and IIc above, on an alternating year sche <lule.

l III. P,iennial Written Examination i

a. The requirement set forth in 10CFR55.59(a)(2), for the satisfactory completion of

a biennial RO/SRO written examination, will be met by the administration of an j examination by the TRF PIC to each RO/S.RO covering the limited topics and l activities currently authorized under the TRIGA Mark I rnd Mark F Reactor l Possession-Only-License (POL) conditions. Satisfactory completion of the biennial examination would require a score of 70% or greater.

b. Should a RO/SRO fail to score less than 70% on the biennial written examination, reinstatement of qualified RO/SRO status would necessitate  !

specific review of the applicable topic (s), as directed by the TRF PIC or qualified designee, and the subsequent retesting and satisfactory scoring by the candidate.

Topical review may consist of discussions, hands-on familiarization sessions, lectures, and/or self-study documentation review, as deemed necessary and appropriate by the TRF PIC or qualified designee.

c. If the TRF PIC or qualified designee is a SRO, that individual shall also satisfactorily meet the written examination requalification requirements, as set forth in Section IIIa above, on an alternating ' jear schedule. )

February 24,1998 Page3 m

IV. Records Records shall be maintained for each licensed RO/SRO, by the TRF PIC or qualified designee, to document the following:

a. The review of TRF emergency and administrative procedures; Sections Ib & Ic.

b. The satisfactory completion of five practive fuel handling manipulations of standard dummy elements; Section iia (1).

c. Satisfactory Annual Reactor Operator Evaluation; Section iib (1).

d. Satisfactory completion of the requisite four hours sent in facility maintenance and related activities; Section IIc. Records substanking such time spent shall consist of appropriate logbook entries or other appropriate documentation, to be completed at the time of activity performance.

e. Results of satisfactory biennial written examinations (Section IIIa)

f. Information concerning any unsatisfactory RO/SRO evaluations and/or written examinations, and remedial actions taken; Sections iia (2), iib (2), and IIIb.

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February 24,1998- Page 4

l General Atomics TRIGA Reactors Fudity ANNUAL REACTOR OPERATOR EVALUATION Name SRO RO Limited SRO Period S = Satisfactory 11 = Unsatisfactory NA = Not Applicable l

.CAIEGOF Y_ EVALUATION I. FACILITY STARTUP & SHUTDOWN i'

a. Startup

l. Startup Checklist

2. Anticipation & Response to Events

c. Shutdown

1. Shutdown Checklist

2. Monitoring Requirements II. FUEL STORAGE & FUEL HANDLING SYSTEMS (

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a. Fuel and Fuel Handling

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l. Storage 1

2. Handling I

b. Fuel Storage Systems i

1. WaterTreatment System i

2. Water Conductivity Monitoring System

3. Water Radiation Monitoring System  !

4. Water Temperature Monitoring System

5. Tamper-Safe Security Systems l

c. Instrumentation and Control Systems

1. Area Radiation Monitoring System  ;

d. ElectricalSystems

1. Normal Operation

2. Alternate Supplies February 24,1998 Page 5

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l l General Atomics TRIGA Reactors Facility-An'nual Reactor Operator Evaluation i

CATEGORY EVALUATION

e. Ventilation

1. Normal Operation

2. Emergency Procedures _

f, Integrated Facility Operations

1. SNM Control / Accountability Requirements

2. Security Systems

3. Personnel Access Requirements III. FAMILIARITY WITH DOCUMENTATION

a. Standard Operating Procedures

b. Emergency Procedures

c. Administrative Procedures

d. Technical Specifications

e. Health Physics Procedures

f. SNM Control / Accountability Logs

g. Fuel Storage / Maintenance Logs IV. ADDITIONAL TRAINING REQUIRED (INDICATE AREA) l Any unsatisfactory evaluation shall be supported by a detailed explanation above.

The forgoing Annual Reactor Operator Evaluation perfonned by:

Signature.

Print Name:

Title:

Date February 24,1998 Page6