ML102790003

Dow Chemical Company - Request for Additional Information Regarding the Operator Requalification Program for the License Renewal and Power Uprate Application Review

ML102790003
Person / Time
Site:	Dow Chemical Company
Issue date:	10/27/2010
From:	Geoffrey Wertz Research and Test Reactors Licensing Branch
To:	Krahenbuhl M Dow Chemical Co
Meyer W, NRR/DPR/PRLB, 301-415-0897
References
TAC ME1595
Download: ML102790003 (5)

Text

October 27, 2010 Melinda P. Krahenbuhl, Ph.D.

Facility Director Dow Chemical TRIGA Research Reactor Dow Chemical Company Building 1602 Midland, MI 48674

SUBJECT:

DOW CHEMICAL COMPANY - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE OPERATOR REQUALIFICATION PROGRAM FOR THE LICENSE RENEWAL AND POWER UPRATE APPLICATION (TAC NO.

ME1595)

Dear Dr. Krahenbuhl:

The U. S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009.

During our review of the DTRR Operator Requalification Program questions have arisen which 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 accordance with Title 10 of the Code of Federal Regulations, Section 50.30(b), you must execute your response in a signed original document under oath or affirmation.

If you have any questions about this review, or if you need additional time to respond to this request, please contact Walter Meyer by telephone at 301-415-0897 or by electronic mail at Walter.Meyer@nrc.gov.

Sincerely,

/JQuichocho for RA/

Geoffrey A. Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-264

Enclosure:

As stated cc w/encl: See next page

Dow Chemical Company Docket No. 50-264 cc:

Office of the Mayor 333 West Ellsworth Midland, MI 48640 Office of the Governor Room 1 - Capitol Building Lansing, MI 48913 Alex Pollock Chair, Radiation Safety Committee 2030/410 Dow Center Midland, MI 48674 Dr. Kevin Hool, Level 1 Manager The Dow Chemical Company 1897 Building Midland, MI 48667 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML102790003

• Concurrence via e-mail NRR-088 Office PRLB:PM*

PROB:PM PRLB:PM*

PRLB:LA PRLB:BC PRLB:PM*

Name WMeyer PDoyle GWertz GLappert JQuichocho GWertz Date 10/05/2010 10/26/2010 10/25/2010 10/26/2010 10/26/2010 10/27/2010

ENCLOSURE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING THE OPERATOR REQUALIFICATION PROGRAM FOR THE LICENSE RENEWAL AND POWER UPRATE APPLICATION LICENSE NO. R-108; DOCKET NO. 50-264 The U. S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009. During our review of the DTRR Operator Requalification Program questions have arisen which require additional information and clarification.

These requests for additional information (RAI) are based on a comparison of the DTRR Operator Requalification Program with regulations in Title 10 of the Code of Federal Regulations (10 CFR), Part 55, Operators Licenses and American National Standards Institute (ANSI)/

American National Standards (ANS) -15.4-2007, Selection and Training of Personnel for Research Reactors.

1.

Regulation 10 CFR 55.59(a)(2) states that each licensee shall pass a comprehensive requalification written examination and an annual operating test.

In your Requalification Program, Sections B, C, and D state:

B.

A 1 to 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> "walk through the facility" with discussion led by the reactor supervisor.

C.

A simulated emergency situation with evacuation exercise.

D.

The above parts of the program shall be followed by a written examination containing at least 12 questions which can be answered in approximately two hours and will demonstrate the familiarity of the operator with the subjects covered.

Although these sections of the program may be deemed to fulfill the requirements of 10 CFR 55.59(a)(2), there is no pass/fail criterion associated with these tests. How does the facility ensure consistent evaluation for passing or failing of operators during these tests? ANSI/ANS-15.4-2007 Section 5.5 provides guidance for examination administration and evaluation. Please consider implementing this guidance or justify an alternate approach to establishing a pass/fail criterion.

2.

Regulation 10 CFR 55.53(e) states that.For test and research reactors, the licensee shall actively perform the functions of an operator or senior operator for a minimum of four hours per calendar quarter.

In your Requalification Program, Section G states: Each licensed operator shall operate the reactor at least once every 120 days and shall perform a minimum of ten reactivity changes during each calendar year.

Please explain how Section G meets the requirements of 10 CFR 55.53(e) for maintaining an active license and how your Requalification Program meets 10 CFR 55.53(f) requirements for returning inactive operators to active status.

3.

Regulation 10 CFR 55.59(c)(5) specifies the requirements for maintaining requalification program records and describes the type of records that must be maintained. Your requalification program states appropriate recordsfor each operator will be kept by the facility. Please explain how your Requalification Program meets the requirements of 10 CFR 55.59(c)(5).