ML20035C340
| ML20035C340 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/29/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20035A470 | List: |
| References | |
| NUDOCS 9304070083 | |
| Download: ML20035C340 (5) | |
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
E WASHINGTON. D. C. 20555 5
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION r
OF A RE00EST FOR AN EXEMPTION FROM 10 CFR 50. APPENDIX E REQUIREMENT TO CONDUCT AN ANNUAL EXERCISE PORTLAND GENERAL ELECTRIC COMPANY TROJAN NUCLEAR PLANT LICENSE NO. NPF-1 DOCKET NO. 50-344
1.0 INTRODUCTION
By letter dated January 27, 1993, Portland General Electric (PGE) informed the Nuclear Regulatory Commission of their decision to permanently cease power operations at the Trojan Nuclear Plant.
Further, by letter dated February 2, 1993, PGE informed the Commission that the Trojan reactor had been permanently shut down and defueled, with the nuclear fuel placed in the spent fuel pool.
By letter dated February 17, 1993, PGE certified that they would not move fuel back into the containment building without prior NRC approval.
PGE has also concluded that the degree of emergency planning and preparedness necessary to provide adequate protection of the public health and safety in a permanently shut down and defueled condition is significantly less than that provided by the existing Trojan Radiological Emergency Response Plan (RERP).
Therefore, exercising the existing plan (which is primarily based on potential operating reactor accidents) is not necessary for a non-operating and defueled facility. The basis for this request is that it would allow the licensee to better allocate available resources in the development of a revised emergency plan that better reflects the permanently shut down and defueled condition of the Trojan Nuclear Plan.
According to the licensee, instead of preparing and conducting the annual exercise scheduled for the first quarter of 1993, PGE would rather apply these resources to timely development of and training on a revised emergency plan that is ~epresentative of the substantially reduced risks associated with a i
permanently shut down and defueled facility. The exemption would allow PGE to apply its resources to revising the existing emergency plan to reflect the reduced potential risks of a permanently shut down and defueled facility.
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2.0 BACKGROUND
NRC Inspection Report number 50-344/91-26 documented the evaluation of the September 24-25 1991, exercise at Trojan Nuclear Plant. The results of the
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inspection indicated that the licensee was fully capable and prepared to protect the public health and safety during an emergency. The report
- j presented the following results:
'i No. deviations, violations of NRC requirements, or exercise weaknesses were identified during this inspection..
Strengths were observed in each of the' emergency response facilities during the exercise.
Overall, the performance, by the licensee was much_ improved.. Areas for improvement identified in the 1990 exercise were noted to have been addressed.
Improvements in facility briefings and inter-facility support were especially noteworthy.
NRC Inspection Report Number 50-344/92-04, dated February 19, 1992, documented an evaluation of the operational status of the licensee emergency preparedness j
program. As a result of this inspection, the licensee was issued a Notice of Violation for failing to take corrective action for an identified weakness concerning the licensee capability to process site evacuees. -Subsequent to this. inspection, the licensee took appropriate action to resolve the-1 identified weakness as documented in NRC Inspection Report Number 50-344/92-13. The prompt and extensive corrective actions taken by the j
licensee as a result of the February 19, 1992, inspection were identified as a l
strength..The improved staffing level, including the appointment of an i
individual to fill the new position of Manager, Emergency Preparedness, was i
also identified as a strength.
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NRC Inspection Report Number 50-344/92-13, dated May 15, 1992, documented followup evaluations to items identified in previous inspections. No-1 deviations or violations of NRC requirements were identified during this i
inspection. The inspector verified the corrective actions resulting from the violation identified in Inspection Report Number 50-344/92-04. Three inspector followup items (IFIs) were closed; however, two new unresolved items evolved from two of the original _ issues. One unresolved item involved the absence of the onshift capability to calculate thyroid doses and the other unresolved item concerned the operability _of the emergency operations facility (EOF) ventilation system in the isolation mode. These unresolved items were addressed and closed in NRC Inspection Report 50-344/92-23.
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- NRC Inspection Report Number 50-344/92-23, dated August 27, 1992, documented followup evaluations on two items identified in Inspection Report Number 50-344/92-13 as unresolved items. One concerned an apparent failure of the EOF ventilation system to properly function. The licensee completed minor repairs to the system and it subsequently tested satisfactory. The unresolved item was closed. The second item concerned the licensee ability to perform thyroid dose calculation in the control room. The licensee revised procedures and appropriately trained staff so this capability is now available in the control room. The unresolved item was closed.
A review of the most recent Systematic Assessment of Licensee Performance (SALP) Report (No. 50-344/92-14), covering the period from April 1, 1991, through May 31, 1992, indicated the licensee was rated to be in performance Category 2 for the functional area of emergency preparedness. The licensee was rated as a performance Category 2 in the previous SALP period as well.
3.0 STAFF EVALUATION The licensee a:ade a good faith effort to conduct the 1992 exercise. The scope and objectives for the 1992 exercise were submitted to the NRC for review on August 12, 1992. The exercise was originally scheduled for November 17, 1992.
The licensee experienced a steam generator tube leak that resulted in a plant shutdown on November 9, 1992. To accommodate forced outage maintenance activities, the exercise was rescheduled to be conducted on December 15, 1992.
However, as a result of the continued forced outage, the 1992 annual exercise could not be practicably performed on December 15, 1992. The licensee was granted a one-time schedular exemption to allow the 1992 emergency plan exercise to be deferred until the first quarter of 1993.
It was anticipated the 1992 exercise would be conducted before March 31, 1993.
The licensee maintained an aggressive drill program during 1992, which fully met the commitments for drills found in Section 8 of the PGE emergency plan.
They conducted monthly communication drills and communication systems tests; i
two medical emergency drills, which involved onsite and offsite participation and were evaluated by the Federal Emergency Management Agency (FEMA);
five radiological monitoring / emergency operations facility drills, which included onsite and (at times) offsite monitoring teams; and three health physics drills, one of which included the post-accident sampling system. Many of these drills were subparts of five integrated drills the licensee conducted in 1992. These integrated drills included activation of onsite emergency response facilities (ERFs) and mobilization of the emergency response organization to staff the ERFs.
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_4-t The licensee decided to permanently cease operations at the Trojan Nuclear Plant in January 1993 and communicated this to the NRC by letter dated January 27, 1993. Nuclear fuel has been removed from the reactor and placed in the spent fuel pool as certified by the licensee.in a letter dated February 2,1993.
Further, by letter dated February 17, 1993, the licensee certified that they would not move fuel back into the containment building at Trojan without prior NRC approval.
Licensees are required by 10 CFR 50, Appendix E, Section IV.F.2, to annually exercise their emergency plan at each site.
Evaluation of the hst exercise at Trojan, conducted in September 1991, indicated that the licensee was fully capable and prepared to take actions necessary to protect the health and i
safety of the public. Also, the licensee SALP rating of Category 2 for f
emergency preparedness indicates that resources were adequate and reasonably allocated so that good plant performance was being achieved. Subsequent inspections have indicated the licensee continued to maintain these capabilities. Although some areas needing improvement were noted, the licensee has demonstrated efforts to address these areas and improvement has been noted.
l The staff finds that special circumstances exist [Section 50.12(a)(2)(ii) of 10 CFR 50] that warrant granting an exemption from the performance of'the annual exercise for 1992. The commitment by PGE to permanently cease operations and to not move fuel into the reactor building without prior approval of the NRC has significantly reduced the likelihood of an accident resulting in offsite releases which would exceed the current U.S.
Environmental Protection Agency protective action guides threshold. The i
degree of emergency planning and preparedness necessary to provide adequate protection of the public health and safety in the permanently shutdown and defueled condition is significantly less than that provided by the existing Trojan Radiological Emergency Response Plan (TRERP).
In consideration of this l
and the level of emergency preparedness provided at the site throughout 1992 consistent with 10 CFR 50.54(q), the requirement for the conduct of an annual exercise under the existing TRERP is not necessary to achieve the underlying purpose of the rule (10 CFR 50, Appendix E, Section IV.F.2).
Nonetheless, it is expected that the licensee will apply resources to the timely development of and training on a revised emergency plan that is representative of the reduced risks associated with a permanently shutdown and defueled facility.
Implementation of a revised radiological emergency preparedness plan will include the conduct of an annual exercise recognizing the new emergency planning basis.
4.0 ENVIRONMENTAL CONSIDERATION
Pursuant to 10 CFR 51.21, 51.32, and 51.35, an environmental assessment and finding of no significant impact has been prepared and published in the l
Federal Reaister (58 FR 16556) on March 29, 1993. Accordingly, based l
upon the environmental assessment, the Commission has determined that the issuance of this exemption will not have a significant effect on the quality of the human environment, j
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5.0 CONCLUSION
The staff recommends approval of an exemption from the 10 CFR 50, Appendix E, Section IV.F.2. requirement to conduct an annual exercise at the Trojan Nuclear Plant site for the year 1992 on the condition that the plant does not resume operation.
Should the licensee decide to restart the facility, the exercise must be conducted before the plant resumes operation.
Special circumstances exist in that the plant is in a shutdown and defueled status and the licensee has decided to permanently cease operation of the plant. The licensee has maintained in effect emergency plans which meet the requirements of 10 CFR 50.54(q). Thus, the conduct of an exercise is not necessary to achieve the underlying purpose of the rule.
Principal Contributer:
D. Barss Date:
March 29, 1993
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