ML20046A064
| ML20046A064 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/19/1993 |
| From: | Shetler J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| DAGM-NUC-93-146, NUDOCS 9307260074 | |
| Download: ML20046A064 (5) | |
Text
v (m.JSMUD SACRAhAENTO MUNICIPAL UTIUTY DISTRICT O 6201 S Street. P.o. Box 15830. Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA DAGM/NUC 93-146 July 19, 1993 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NRC' LE' ITER DATED JUNE 25,
- 1993,
SUBJECT:
IMPLEMENTATION OF TIIE TRAINING RULE (10 CFR 50.120) i Attention: Seymour Weiss In response to the NRC's letter dated July 25,1993, the District submits that the requirements of the NRC's new training rule (10 CFR 50.120) should not apply to Rancho Seco. The District believes that the rule is inapplicable to facilities such as Rancho Seco which the NRC has granted a Possession Only License (POL). The District is no longer the " holder of an operating license" to which the rule is limited. See 10 CFR 50.120(a).
Even if the NRC determined that the rule were applicable, the District should be exempted from its application as a matter of policy. The tasks associated with maintaining the plant in j
a possession only status are neither complex nor dimcult when compared to the tasks
'l associated with operating a nuclear power reactor. Additionally, the risk to the public is minimal in that there are no credible events that could result in a 10 CFR 100' release, and no -
offsite emergency planning is required.
To develop and maintain a Systems Approach to Training (SAT) program that complies with 10 CFR 50.120 would present an undue financial and administrative hardship to the District, would not enhance public health and safety, and would result in a drain of District and NRC l 0, resources.
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RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935,
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S. W eiss DAGM/NUC 93-146
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Background===
The District shut down Rancho Seco permanently in June 1989, as the result of a public referendum. Plant staff completed defueling the reactor in December 1989, and the NRC issued a POL to Rancho Seco in March 1992. At the time that Rancho Seco shut down, the training programs had full accreditation by the Institute of Nuclear Power Operations (I NPO).
However, after the permanent shutdown the District withdrew from INPO, and there were no requirements to maintain or support an SAT-based training program, including INPO-typejob task analyses.
As Rancho Seco transitioned from an operating plant to a decommissioning facility with a POL, plant staff modified the training program (s) to reflect the permanent changes in the condition of the plant. The principal tasks and activities conducted on site are those necessary to maintain the fuel safely in the spent fuel pool. The NRC approved the District's Certified Fuel Handler (CFH) training program in a letter dated March 19,1992 (TAC No. M82205),
indicating that the CFH training program is adequate to protect public health and safety.
Existing Training Programs Allindividuals having unescorted access to Rancho Seco receive General Employee Training annually, Current training for the personnel categories required by the training rule is as follows:
Non-licensed Onerator For Certified Fuel Handlers, the District provides t raining in accordance with the NR C-approved CFH Training Program. This program provides both initial and continuing training in Nuclear Theory, Heat Transfer and Fluid Flow, Radiation Control and Safety Operation of Spent Fuel Handling and Storage Equipment, Auxiliary and Support Systems, Normal and Casualty Procedures, and Administrative Controls.
Training for Non-certified Operators is similarly to that for CFHsexcept that the non-certified operators do not receive training on nuclear theory.
When Rancho Seco was an operating facility, District stafThad developed the operator training program using the SAT process, and the training program was accredited by INPO. The NRC-approved CFH program is based on lesson plans that District staff revised after plant shutdown to retain only those objectives and subjects applicable to a POL facility. As the NRC stated in the above referenced letter, the CFH training i
i S. Weiss
-3 DAGM/NUC 93-146 program "...provides the required level of training and certification consistent with the defueled condition of the plant."
The Operations training stalTreviews the lesson plans prior to instruction to insure that they reflect the most current plant configuration. Revisions to lesson plans are made in accordance with plant procedures to ensure that systematic changes to the lesson plans reflect the current plant status.
Shift Sunervisor The Rancho Seco Shift Supervisors are no longer Senior Reactor Operators. They are Certified Fuel Handlers who are accountable for safe and elTicient plant operation in the permanently defueled mode. In addition to CFH training, individuals designated as Shift Supervisors receive supervisor training consistent with District training policy.
Shift Technical Advisar(STA)
There are no longer any STA positions at Rancho Seco.
I&C. Electrical. and Mechanical Maintenance The District uses only qualified, journey-level individuals in these job categories.
Therefore, initial techm.'al training is not necessary. The District provides training on the administrative skills and knowledge required to accomplish tasks specific to Rancho Seco (e.g., work permits, clearance / test tags, plant drawing system, etc.).
Radiation Protection and Chemistry Technician The District uses only ANSI qualified Radiation Protection and Chemistry Technicians.
Training consists of task oriented on-the-job training, procedure training, industry events, and selected technical training.
Engineering Sunnort This training consists ofapplicable procedure training, and District supervisor / manager training.
l
S. Weiss DAGM/NUC 93-146 l
Basis for Exemption With all of Rancho Seco's spent fuel stored in the spent fuel pool, the principal tasks and I
activities performed on site are those necessary to monitor and maintain the spent fuel pool and associated support equipment. The tasks and activities associated with maintaining the fuel are
]
relatively simple compared to the tasks and activities required to maintain an operating nuclear power reactor. Based on the plant's shutdown status, and the limited number of tasks, staff training at Rancho Seco is adequate to qualify individuals to perform in a competent manner, and ensure the safe operation of the facility with no undue risk to public health and safety.
Moreover, requiring the District to comply with the requirements of the training rule would result in an undue financial and administrative hardship. Such action would not enhance public health and safety, and would result in an unnecessary drain and inefficient use of both District and NRC resources. While the existing training program at Rancho Seco is consistent, in principle, with an S AT-type program, the documentation no longer exists to meet the review criteria in NUREG-1220.
The following example illustrates the inordinate cost of complying with 10 CFR 50.120. The cost for initial INPO accreditation of the operator training program was approximately $10 million. Even with the reduced number of tasks and objectives, there are currently over 250 tasks associated with non-licensed operator training. Plant staffestimates that conducting and documenting thejob task analyses would require approximately 50 person-hours / task.' The resultant cost associated with developing the documentation required for an SAT program would be nearly 51 million. This cost is for non-licensed operator training only, and does not include the costs associated with developing an SAT training program for Radiation Protection, Chemistry, Maintenance, or engineering support.
Because Rancho Seco is a permanently shut down facility, the limited resources at the site are dedicated to the safe decommissioning of the facility. The District no longer has the
" operating" staff required to develop and maintain an SAT program. To require Rancho Seco to fully comply with the requirements of the S AT process, would result in an extreme hardship to the District, and would not materially contribute to increasing public health and safety.
i This would include conducting and documenting thejob task analysis, developing and documenting the associated learning objectives, developing a cross-matrix, management approval, and database generation.
1 j
I
.5 S. Weiss DAGM/NUC 93-146 Accordingly, if the NRC deems that 10 CFR 50.120 is applicable, the NRC should grant the District a full exemption from the requirements of 10 CFR 50.120.
Members of your staff with questions requiring additional information or clarification may contact Bob Jones at (916)452-3211, extension 4676.
Sincerely, d
SJames R. Shetler Deputy Assistant General Manager Nuclear cc:
B. Faulkenberry, NRC, Walnut Creek