ML20036A747
| ML20036A747 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/06/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20036A745 | List: |
| References | |
| NUDOCS 9305140111 | |
| Download: ML20036A747 (7) | |
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
.j WASHINGTON. D. C. 20555 k...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.191 TO FACILITY OPERATING LICENSE NO. NPF-1 PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE. OREGON TROJAN NUCLEAR PLANT l
DOCKET NO. 50-344
1.0 INTRODUCTION
By letter dated January 27, 1993, Portland General Electric Company (PGE or the licensee) submitted a request for changes to the Facility Operating License No. NPF-1 for the Trojan Nuclear Plant. The Proposed changes would permit the licensee to replace the 10 CFR Part 55 licensed operator program with an approved Certified Fuel Handler Certification and Recertification Training Program (CFH) at the Trojan Nuclear Plant (Trojan or the plant).
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2.0 DISCUSSION AND EVALUATION The Plant is presently in a shutdown, non-operating, and defueled condition.
l On February 2,1993, the licensee notified the NRC that all reactor fuel had been permanently removed from the reactor vessel at Trojan and placed in the spent fuel pool. On February 17, 1993, the licensee notified the NRC staff that PGE will not move fuel back into the containment building at Trojan without prior NRC approval. On March 25, 1993, the NRC staff issued an order confirming the licensee commitment not to move fuel back into the containment building without prior NRC approval.
This order serves to require the plant to remain in the non-operating and defueled condition.
In another letter dated January 27, 1993, PGE requested an exemption from the requirements of 10 CFR Part 50.54.
10 CFR Part 50.54 specifies requirements for every license issued to a nuclear power plant or reprocessing facility.
In your request of January 27, 1993, you specifically requested an exemption to 10 CFR Part 50.54(m)(2)(i) which prescribes the minimum licensed operator staffing levels for nuclear power plant licensees. The staff is responding to this request separately concluding that no exemption is required since footnote 1 in the table contained in 10 CFR Part 50.54(m)(2)(i) allows for deviations from the numbers required by the table in accordance with criteria established in the units technical specifications. This license amendment approves those requirements in the Trojan Nuclear Plant technical specifications.
9305140111 930506 PDR ADOCK 05000344
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In a third letter dated January 27, 1993, the licensee requested approval of their CFH program for the facility; the NRC approved this program in a letter dated April 27, 1993. With the issuance of this license amendment, the licensee would now be able to implement the CFH program. The current TS require a minimum of one Senior Reactor Operator and a Licenzad Operator as a minimum shift crew composition with the facility in the current Mode 6.
The licensee proposes to change the minimum shift crew composition to a Shift Manager and a Non-Certified Operator.
Since the plant is permanently shut down, there is no longer a need for licensed operators or a Shift Technical Advisor. The Shift Technical Advisor has a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and response and analysis, of the Trojan Plant, to assist in transients or accidents during reactor operation. He is available to the shift personnel i
during the shift. The requirement for an individual qualified in radiation protection procedures will be required to be present only during fuel handling operations.
The staff evaluation of each of the licensee's proposed changes to the Trojan Appendix A Technical Specifications are as follows:
i (1)
Change Section 6.2.2, Facility Staff, Subsection a, by eliminating the minimum shift crew size of five for safe shutdown.
Evaluation: This change removes the requirement to have a minimum shift size 1
during safe shutdown operations. Since the facility is in a non-operating defueled condition, there will be no need for accomplishing any safe shutdowns. The staff finds the change acceptable.
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Change Table 6.2-1, Minimum Shift Crew Composition, by revising the table to indicate the position requirements for a permanently defueled condition. The licensee proposes that a Shift Manager and a Non-Certified Operator will be. required on each crew.
Evaluation: Since the plant has permanently ceased operation and is defueled, f
there is no longer a need for licensed operators or a Shift Technical Advisor.
As stated above, the Shift Technical Advisor has specific training in plant design and response and analysis to assist the shift in transients or accidents during reactor operation. Trojan is in a non-operating defueled condition and reactor operations are prohibited.
Therefore, PGE does not need licensed operators or a Shift Technical Advisor.
PGE may assign appropriately trained non-licensed personnel to perform any and all activities not specifically identified as " licensed operator activities" in 10 CFR 50.54 or in the Part 50 license issued to PGE. The issuance of this amendment, in conjunction with the approval of the CFH program, will allow for the appropriately trained non-licensed certified fuel handlers..The staff finds the change acceptable. The licensee also included a footnote to the revised table to indicate that changes to the table were allowed by an exemption to i
The staff has determined, by separate letter, issued i
concurrently with this license amendment that no exemption is required.
r Therefore, the staff did not include the footnote in the amended table.
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(3) Change Section 6.2.2, facility Staff, Subsection b. by revising the wording to require that one individual qualified to stand watch in the t
control room be in the control room when fuel is in the spent fuel pool.
The control room watch can be either a non-certified operator or a b
certified fuel handler.
i Evaluation: Since there is no fuel in the reactor and the licensee is prohibited from returning fuel to the reactor building by the staff's March 24, 1993 Confirmatory Order, the requirement that there be at least one licensed operator in the control room when there is fuel in the reactor is unnecessary. The licensee's proposal to require at least one individual qualified to stand watch in the control room (non-certified operator or a certified fuel handler) is appropriate. The staff finds the change acceptable.
l (4) Delete Section 6.2.2, Facility Staff, Subsection c.
This subsection requires two licensed operators to be present in the control room during l
reactor startup, scheduled reactor shutdown and during recovery from reactor trip. The licensee proposes to delete this section.
j Evaluation: Since Trojan is non-operating and permanently defueled these evolutions cannot occur; therefore, the minimum staffing requirements need not be specified in the TS. The staff finds the change acceptable.
(5) Change Section 6.2.2, Facility Staff, Subsection d.,
by revising the i
requirement for a individual qualified-in radiation protection procedures
'i to be onsite when fuel is in the reactor to when fuel handling operations l
are being conducted.
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Evaluation: Since there is no longer any fuel in the-reactor and the spent j
fuel is safely stored in the spent fuel pool, it is reasonable to limit the -
requirement to have an individual qualified in radiation protection be onsite '
to times when fuel handling operations are being conducted. This will ensure l
that qualified personnel are available during fuel handling activities, in-l which spent fuel is moved.
The staff finds the change acceptable.
(6) Change Section 6.2.2, facility Staff, Subsection e.,
by eliminating i
staffing requirements during core alterations, which cannot-take place since there is no fuel in the core,- and replacing it with the' requirement j
that all fuel handling operations shall be supervised directly by a certified fuel handler.
Evaluation: The requirement for licensed operators during core alterations can be eliminated since the reactor is defueled and the licensee is prohibited from moving fuel back into containment by the staff's March 24, 1993 I
Confirmatory Order. The licensee proposes to require that all fuel handling operations shall be supervised directly by a certified fuel handler.
The staff finds the change acceptable.
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- (7) Change Section 6.2.2, Facility Staff, Subsection f., by eliminating the j
prohibition in using the members of the minimum crew necessary for safe shutdown of the plant as members of the Fire Brigade.
Reference to the minimum crew necessary for safe shutdown of the plant is deleted and j
replaced by the phrase " certified fuel handler on shift." The certified i
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fuel handler on shift cannot be a member of the five person Fire Brigade.
l Evaluation: The purpose of this requirement was to prohibit the use of j
station operators as Fire Brigade personnel. The licensee proposes changing i
the technical specification to prohibit the inclusion of the certified fuel I
handler as a member of the Fire Brigade and drop the reference.to the minimum j
crew necessary in the control room for the safe shutdown of the facility.
Since the facility is already safely shut down, the staff finds the change i
acceptable.
(8) Change Section 6.2.2, Facility Staff, Subsection g.,
first paragraph, by changing the reference to senior reactor operators, reactor operators, health physicists, and auxiliary operators to certified fuel handlers, radiation protection personnel, and non-certified operators and changes the reference to safety related functions to the safe storage of irradiated fuel assemblies.
Evaluation: The proposed change changes the reference to specific positions i
on the shift crews consistent with the non-operating defueled condition of the facility and the approved CFH program.
The staff finds the proposed changes acceptable.
(9) Change Section 6.2.2, Facility Staff, Subsection 9.,
second paragraph, by deleting the phrase " safety related structures systems or components" and replacing it with "important to the safe storage of irradiated fuel i
assemblies."
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Evaluation: The proposed change changes how the licensee defines key
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maintenance personnel of the station narrowing the focus of concern of l
maintenance personnel from safety related structures systems or components 3
related to power operation to maintaining the facility in a safe and stable i
condition. This is consistent with the reduction in hazard associated with the current defueled, non-operating status of the facility.
The staff finds the proposed change acceptable.
(10) Change Section 6.2.2, Facility Staff, Subsection g.,
third paragraph, by deleting the phrases "when the plant _is operating" and " extended periods of shutdown or refueling."
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Evaluation: The current technical specification defines the baseline for computing overtime as the 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week. The specification however allows for deviations from the baseline during periods of extended shutdown using
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specific guidelines contained in the technical specification. During periods
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when the plant is not operating or during extended periods of shutdown for refueling,_as well as for other defined reasons, additional overtime using the guidelines in technical specification 6.2.2 g. a. through d. is allowed.
The licensee _ proposes to delete the reference to plant operation and extended periods of shutdown for refueling since neither is applicable to Trojan in the w
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current permanently shutdown and defueled condition. The elimination of these two statements actually makes the technical-specification more restrictive in the authorization of overtime. The current technical specifications allow the use of the guidelines for additional overtime at all times since the plant is no longer operating. The revised technical specification would allow the use j
of the guidelines for overtime to unforeseen problems, major maintenance or i
major plant modifications. The staff finds the change acceptable.
(11) Change Section 6.2.2, Facility Staff, Subsection g., Sub-subsection by i
deleting the phrase "Except during extended shutdown period."
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Evaluation: The current technical specifications define in sections 6.2.2 9
- a. through d. guidelines for the use of overtime during periods when there are l
unforeseen problems requiring substantial amounts of overtime, during major i
maintenance or major plant modifications.
Section 6.2.2 g. d. states that overtime should be considered on an individual basis and not for the entire i
staff on a shift except during extended shutdown periods.
Therefore during extended shutdown periods overtime does not have to be considered on an l
individual basis. The purpose of this prohibition was to prevent unequal overtime among individual members of a shift crew that were involved in operations that could affect safety. Since Trojan is permanently shutdown and l
defueled and therefore considered in an extended shutdown the use of overtime i
need not be considered on an individual basis at any time.
The proposed change now requires the licensee to consider overtime use on an individual basis at all times and therefore is more restrictive. The staff finds the l
change acceptable.
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(12) Change Section 6.2.2, facility Staff, Subsection h., by changing the l
requirement that the shift personnel hold operators licenses to the i
requirement that shift personnel be at a minimum certified as a fuel handler. The licensee proposes that an operator holding a license as a Senior Reactor Operator would satisfy the requirements of a certified fuel handler. This would allow Senior Licensed Operators to fill positions designated for Certified Fuel Handlers during the t
implementation of the CFH program.
Evaluation: Since the facility is non-operating and defueled, the licensee proposes that shift personnel should not be required to be licensed operators, but instead be required, at a minimum, to be a certified fuel handler.
Senior licensed operators possess the qualifications for Certified Fuel Handlers.
l The staff finds the change acceptable.
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(13) Change Section 6.3, Facility Staff Qualifications by deleting the i
requirement for a Shift Technical Advisor and an Operations Manager.
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Evaluation: Neither of these positions are required for a non-operating i
permanently defueled plant. The staff finds the proposed change acceptable.
-(14) Change Section 6.4, Training, Subsection 6.4.1, by eliminating the requirement for an operator training program in accordance with Section 5.5 of ANSI N18.1-1971 and 10 CFR Part 55 and replace it with the NRC-approved CFH program.
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' Evaluation: The requirement for an operator training program is being deleted to reflect the non-operating defueled condition of the plant.
In its place, the licensee has developed and the NRC has approved a CFH program consistent with the level of hazard at the facility in order to maintain the facility in a safe, and stable condition. The staff finds the change acceptable.
(15) Change Section 6.5.1.2, Composition, by eliminating the requirement that one member of the Plant Review Board (PRB) hold a Senior Reactor License.
Evaluation: Since Trojan is a non-operating permanently defueled facility, there is nn need to have a member of the PRB holding a Senior Reactor License.
The staff finds the proposed change acceptable.
(16) Change Section 6.8.3.b. Temporary Changes to Procedures, by removing the l
reqairement that temporary changes to procedures require at least one member of the plant management staff approving the change to hold a Senior Reactor License to raquiring one of the plant management staff to be a certified fuel handler.
l Evaluation: Since Trojan is a non-operating permanently defueled facility, there is no need for one of the plant managers approving temporary changes to procedures to hold an operator license. The staff finds the proposed change acceptable.
In summary with Trojan being permanently shut down, there is no need for 10 CFR Part 55 licensed operators.
Part 55 defines the duties of a licensed operator as:
...an individual licensed under this part to manipulate a control of a facility " The rule also states, " Controls when used with respect to a nuclear reactor means apparatus and mechanisms the manipulation of which directly affects the reactivity or power level of the reactor."
Power operation is no longer possible at the Trojan Nuclear Station, and the need for Part 55 licensed personnel has ceased. However, with the fuel and other radioactive components now in the spent fuel pool and the need for possible future fuel and radioactive component handling at the facility, qualified personnel will still be required to safely monitor and maintain the spent fuel pool and its associated. safety related devices. These changes to the technical specifications reduce the minimum shift complement of four licensed individuals to two certified fuel handlers. This is appropriate, due to the greatly reduced duties of the shift staff, since all power prrducing and associated safety related systems related directly to reactor operations are eliminated, and the facility is defueled and permanently shutdown.
Based on the above evaluation, we find that the licensee's January 27, 1993 requested changes to the Trojan Nuclear Plant technical specifications are acceptable.
3.0 STATE CONSULTATION
In accordtnce with the Commission's regulations, the State of Oregon cognizant individual was notified of the proposed issuance of this amendment. The State official had no comment.
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4.0 ENVIRONMENTAL CONSIDERATION
i The amendment changes the requirements with respect to installation or use of facility components located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no i
significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the i
amendment involves no significant hazards consideration, and there has been no public comment on such finding (58 FR 16869) dated March 31, 1993.
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no r
environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the amendment.
5.0 CONCLUSION
I The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
l Principal Contributor: Michael T. Masnik Date: May 6, 1993 i
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