ML20046B656

Responds to NRC Re Implementation of Training Rule (10CFR50.120)

ML20046B656
Person / Time
Site:	Rancho Seco
Issue date:	07/29/1993
From:	Shelter J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
DAGM-NUC-93-162, NUDOCS 9308060019
Download: ML20046B656 (3)

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Qsuu-j SACRAMENTO MUNICIPAL UTIUTY DISTRICT O 6201 S Street, P.o. Box 15830. Sacramento CA 95852-1830,1916) 452-3211

j AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA _-

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. DAGM/NUC 93-162 l

i July 29,1993

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- U.S. Nuclear Regulatory Commission

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Attn: Document Control Desk Washington, DC 20555 3

Docket No. 50-312 Rancho Seco Nuclear Generating Station l

License No. DPR-54 1;

SUPPLEMENTAL -RESPONSE TO NRC LETTER DATED JUNE.25,1993:

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IMPLEM ENTATION OF TIIE TRAINING RULE (10 CFR 50.120) j Attention: Seymour Weiss In District letter DAGM/NUC 93-146, dated July 19,1993, we submitted our response to an -

j NRC letter (dated July 25,1993) requesting information regarding the implementation of the j

training rule (10 CFR 50.120). We submitted our position that the training rule should not j

apply to us because the NRC has granted Rancho Seco a Possession Only License (POL), and j

the District is no longer the " holder of an operating license" to which the rule is limited.

g Further, we stated that even if the NRC determined that the rule were applicable, we should j

be exempted from its application as a matter of policy. This letter provides additional l

information supporting an exemption.

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.We shut down Rancho Seco permanently in June 1989, as the result of a public referendum.

Plant stalTcompleted defueling the reactor in December 1989, and the NRC issued Rancho Seco a POL.in March 1992. Since defueling the reactor, the principal tasks and activities j

' conducted on site are those necessary to ' maintain'the fuel safely.

p As Rancho Seco transitioned from an operating plant to a decommissioning facility with a,

j POL, plant stalT modified the training program (s) to reflect the permanent changes in the

-l condition of the plant. Although reduced in scope, the training progmms remain adequate, and 1

are commensurate with the decreased safety significance of a POL facility.

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i PDR RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 3 935' a

S. Weiss DAGM/NUC 93-162 Each member of the Rancho Seco plant staff meets or exceeds the minimum qualifications of ANSI N18.1-1971 forcomparable positions, except forthe Radiation Protection Managerwho meets or exceeds the reconnuendations a nd qualifications of Regulatory Guide 1.8, September 1975. We select plant personnel, and train them for their assigned duties (with particular emphasis on the supen isory, technical, and operating staffs), to ensure that individuals conduct activities at Rancho Seco in a safe and efTicient manner.

We no longer have a centralized training department at Rancho Seco. Each department manager is responsible for their departmental training program. We have three qualified instructors who conduct operations training and General Employee Training. Supervisors, foreman, or individuals with specific technical expertise conduct departmental training.

We conduct retraining and implement replacement training programs for the plant operating staffin accordance with plant procedures. We ensure that retraining and replacement training meets or exceeds the requirements and recommendations of ANSI N18.1-1971 for non-operations stalT, and ANSI 3.1-1981 for operations stafT. The NRC approved Rancho Seco'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. We will maintain the CFH training program, and will not make changes that reduce its effectiveness without prior NRC approval.

As stated in 10 CFR 50.12, the NRC may grant exemptions from the requirements of 10 CFR 50 if special circumstances are present, and the exemption will not present an undue risk to public heath and safety. The following special circumstances outlined in 10 CFR 50.12(a)(2) are applicable:

(ii)

Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule oris not necessary to achieve the underlying purpose of the rule; (iii)

Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the rule was adopted..

Rancho Seco is a permanently sh utdown facility, and there is no credible event that could result in exceeding the dose limits of 10 CFR 100. With the reactor defueled, the principal tasks and activities performed on site are those necessary to maintain the spent fuel and associated support equipment safely. These activities are relatively simple compared to the tasks and

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S. Weiss DAGM/NUC 93-162

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l activities required to maintain an opemting nuclear power reactor. Based on the plant's permanent shutdown status, the limited number of activities' conducted onsite, and the dxreased safety significance of those activities, we believe that the existing training program is adequate to ensure that we operate Rancho Seco in a manner that presents no undue risk to public health and safety. Requiring literal cornpliance with the training rule is not necessary -

to maintain qualified individuals who perform in a safe and competent manner, and is not necessary to achieve the underlying purpose of the rule. (10 CFR 50.12(a)(2)(ii)).

Moreover, requiring literal compliance with the training rule would result in undue fmancial and administrative hardship significantly in excess of that contemplated when the NRC adopted the training rule.10 CFR 50.12(a)(2)(iii). Because Rancho Seco is a permanently shut down facility, we have dedicated our limited resources to safely decommissioning the facility.

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We no longer have a staff ofinstructors to develop and maintain a Systems Approach to Training (SAT) program. To require Rancho Seco to comply fully with the requirements of the SAT process, would result in an extre.me hardship to the District, would be an unnecessary and inemeient use of both District and NRC resources, nnd would not materially contribute to increasing public health and safety.

As stated above, we believe that the training rule should not apply to Rancho Seco. However, should the NRC deem that the rule is applicable, the NRC should grant a full exemption from the requirements of 10 CFR 50.120.

l Members of your stafTwith questions requiring additional information or clarification may l

contact Jerry Delezenski at (916)452-3211, extension 4914.

i Sincerely,

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poeJames R. Sheller Deputy Assistant General Manager Nuclear 9

i cc:

B. Faulkenberry, NRC, Walnut Creek I

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