ML20028H280
| ML20028H280 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/09/1990 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-90-08, GL-90-8, P-90329, NUDOCS 9011190356 | |
| Download: ML20028H280 (6) | |
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y O eueiic service-ex.su P.O. Box 840 Denver CO 80201 0840 November 9. '1990
~ Fort St. Vrain A. Clegg Crawford
-Unit No. 1 vice er. idem P-90329 Nutear ogwredons U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Docket No. 50-267
SUBJECT:
Request for Exemption from Simulation Facility Requirements
REFERENCES:
- (1) Generic Letter 90-08, Simulation Facility Exemptions, dated August 20,1990(G-90192)
(2) PSC Letter, Williams to. Document Control Desk, dated January 20,1989(P-89026)
Gentlemen:-
In-Generic -Letter 90-08 (Reference 1), the Nuclear -Regulatory Commission (NRC) addrest.es the potential need for and method of requesting exemption.'from the simulation--facility requirements promulgated by the NRC in its regulations in c10 ' CFR Part-55.
In Reference 2, PSC advised the NRC that, due to the planned shutdown of
' Fort St'. Vrain (FSV) on or before June ~30,
- 1990, PSC would not construct a' simulation facil.ity and that a request would be submitted to= exempt :PSC-.'from' the-requirements -of. 10 CFR '55.45 and the guidelines in ES-601.
- In' accordance: with'10 CFR 55.11, PSC hereby. requests' exemption-from 110 CfR 55.45(b) in its entirety, 10 CFR 55.45(b) requires either a 4
.simulationf facility.-which the Commission'has; approved for use, or_a simulations facility consisting ~ solely!-of a' plant-referenced simulator which has.been certified toi the-Commission by the licensee.
In addition, Public Service. Company. requests exem various of =10 CFR 55,." Operators' Licenses",.(ption fromseeAttachment1).to portions the; extent:that the regulations require 'a simulation facility-to
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. grant or maintain operators' licenses.
- The requirements _ of 10 CFR 55
- for a simulation' facility are designed
.for, operating power reactors.: In view of the justifications in the L attachment' and due to the permanently shutdown condition of FSV, the requirement for a simulation facility would:not serve the underlying purpose Lof' the rule. -to provide for' improved nuclear power plant operations through appropriate operator training and examination.
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9011190356 001109 i
l PDR ADOCK 03000267 P
P-90329 Page 2
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November 9, 1990-The exemptions requested will not place FSV in a degraded plant condition.
While these exemptions represent a reductian from compliance with 10 CFR 55 as required for an operating nuclear power plant, the training which remains in place at FSV ensures protection of the public health and safeif and is consistent with potential safety hazards associated with a shutdown reactor.
Members of y>ur staff with questions requiring additional information or clarificettion may contact Mr. M. H. Holmes at (303) 480-6960.
Sincerely, M d' A. C. Crawford Vice President, Nuclear Operations ACC/MJR:dme
-Attachments cc: Regional Administrator, Region IV ATTN: Mr. G.-L. Constable, Section Chief l Technical Suppcrt Section Division of Reactor Projects
- Mr. J. B. Baird Senior Resident Inspector Fort St.-Vrain e
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1 to P-90329 November 9,199(i page 1 of 4 ATTACHMENT 1 W MPTION REQUESTS FROM A SIMULATION FACILITY AND SIMULATOR TRAINING AND TESTING Due to the pennanently shutdown plant condition at Fort St. Vrain, public Service Company of Colorado hereby requests exemption from the following sections of 10 CFR 55 related to the requirements for a simulation facility or the use of a simulation facility for training or testing in order to grant or maintain operators' licenses.
CODE OF FEDERAL REGULATIONS:
10CFR55.45(b)M (1) Administration" This section requires
" Implementation that: "The operation test will be administered in a plant walk-through and in either:
(1)
A simulation facility which the Commission has approved for use after application has been made by the facility licensee,'or (ii) A simulation facility. consisting solely. of a plant-referenced simulator which has been certified to the Connission by the facility licensee."
10 CFR 55.45(b)(2)
" Schedule for facility licensnes" Subsections (i) through (iv) detail the. schedular re 55.45(b)(1)(1) and-(ii)quirements for implementation of 10 CFR l
10 CFR 55.45(b)(4)
" Application for and Approval. of Simulation Facilities" identifies the application requirements for those licensees
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which propose,inaccordancewithparagraph(b)(1)(1)ofthis section, to use a simulation facility that is other than solely a plant-referenced simulator as defined in 10 CFR 55.4.
10 CFR 55.45(b)(5)
" Certification of Simulation Facilities" identifies the certification requirements for those licensecs which propose, in accordance with paragraph (b)(1)(ii) of this section, to use a simulator as defined in 10 CFR 55.4.
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Attachment I to P-90329 s'-
c November 9, 1990 Page 2 of 4 ATTACHMENT 1(Continued) 10CFR55.59(a)(?J "Requalification Requirements"
- states, "Each licensee shall...(2) Pass a comprehensive requalification written examination and an annual operating test."
_10 CFR 55.59(o(3)
"On-the-job training" states, in part, "The requalification program must include on-the-job training so that For reactor operators and senior operators these manipulations must consist of the following control mani'ulations...Those a
which are not performed at t'e plant may ae performed on a simulator..."
10CFR55.33(a)(2)
" Written examination and operating test" states, "The
. applicant has passed the requisite written examination and operating test in accordance with 55.41 and 55.45 or 55.43 and 55.H."
REQUESTED EXEMPTIONS:
PSC requests exemption from 10 CFR 55.45(b)1) 10 CFR 55.45(b)(2),10CFR55.45(b)(4),and10CFR55.45(sb)f5).
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Since 10 CFR55.45(b)(1)requiresthatasimulationfacility be used in the perfonnance of the operating test, PSC requests an exemption from the requirement to use a simulation facility l
in satisfyin 55.59(a)(2) and 10 CFR 55.33(a)g the requirements of 10 CFR (2).
3.
PSC requests an exempflon from the requirement to use a simulation facility in sstisfying the requirements of 10 CFR 55.59(c)(3).
To the extent that the regulations require a simulation facility or the use of a simulation facility for training or testing in order to grant or maintain operators' licenses, an exemption is requested.
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F a-to P-90329 November 9, 1990 Page 3 of 4 o
JUSTIFICATION FOR EXEMPTION The requirements of'10 CFR 55 for a simulation facility are designed for operating power reactors.
In contrast, Fort St. Vrain is in a permanently shutdown condition.
As described within the Statements of Consideration, Part 55, I, Background and (A) General Comments, the purpose of the proposed revisions to 10 CFR Part 55 was to achieve and " improve the safety of nuclear power plant operations by improving the operator licensing i
process. and examination process."
This element is essential to granting this exemption to Public Service Company, because this requirement was promulgated on the assumption that the operators would be controlling an operating facility which would experience transients and malfunctions from start-up through full power operations.
Under shutdown plant conditions, transients and malfunctions from start-up through full power operations are not credible. A simulation facility or plant-referenced simulator will 1
not significantly enhance or increase the capability of licensed operators to perform their normal duties or mitigate the consequences of an accident or malfunction over a more suitable examination process conducted within the facility itself.
This' exemption request is consistent with the principles of 10 CFR 50.12. " Specific Exemptions". The following paragraphs provide PSC's i
justification that this exenntion request meets the general exemption criteriain10CFR50.12(a)(').
1 Authorized By Law As required by 10 CFR 50.12(a)(1), granting the requested exemption is authorized by law.
Previously, the Commission has granted l
exemption from the simulation facility requirements to the Sacremento Municipal Utility District for its Rancho Seco Nuclear Generating Station (55 FR 21469).. The Commission has discretion to extend this 1
-same regulatory treatment to Fort St. Vrain.
'No Undue Risk to the Public Health and Safety, I
Consistent with the Common Defense and Security Also in accordance with 10 CFR 50.12(a)(1), it is PSC's position that l
with Fort St. Vrain in the pennanently shutdown. condition, granting l
_the. exemption from the simulator and simulator training requirements will not present an undue risk to the public health and safety and is I
consistent with the comon defense and security.
PSC has no intention to ever operate Fort St. Vrain again.
The absence of' a simulation facility and related simulator training at a permanently I
shutdown facility presents no risk to the public health and _ safety I
and has no adverse impact on common defense and securi ty considerations.
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to P-90329 o
November 9, 1990 Page 4 of 4 j
Special Circumstances Special circumstances as required by10CFR50.12(a)(2)doexist.
The following paragraphs provide PSC's justification that special circumstances as set forth in 10 CFR 50.12(a)(2)(ii) and (iii) exist for granting this exemption.
The special circumstances defined in 10 CFR50.12(a)(2)(ii)are present in that application of the regulation in these particular circumstances would not serve the underlying purpose of the rule.
l The purpose of.equiring a simulation facility and the related 1
training is to improve the safety of nuclear power plant operations
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and assumes the licensed operators will be controlling an operating facility. Having a simulator at a permanently shutdown rtactor which will never operate again does not further this purpose.
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Finally, maintaining compliance with the regulation meets the special circumstances defined in 50.12(a)(2)(iii) as it would result in undue hardship to PSC and costs significantly in excess of others similarly situated. PSC would have to bear the costs to design, test and install a plant-referenced simulator that would never be used. These costs would be in addition to the necessary treining costs related to the shutdown, defueling condition and create an undue hardship.
lhe training PSC continues to provide licensed operators at Fort St.
Vrnin ensures protection of the public health and safety and is consistent with potential safety hazards associated with a permanently shutdown reactor.
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