ML20046C666
| ML20046C666 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 07/29/1993 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-93079, NUDOCS 9308110329 | |
| Download: ML20046C666 (3) | |
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16805 WCR 191/2; Platteville, Colorado 80651 July 29,1993 Fort St. Vrain Unit No.1 P-93079 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Docket No. 50-267
SUBJECT:
Training Rule Implementation
REFERENCE:
NRC Letter, Grimes to Licensees of Plants in Decommissioning Process, dated June 25,1993 (G-93097)
Gentlemen:
As requested in the referenced letter, this submittal describes the existing training programs at Fort St. Vrain (FSV) for positions covered by the training rule (10 CFR 50.120), and explains why, with one exception, the systems approach to training (SAT) is not necessary for current decommissioning conditions. Based on this information, Public Service Company of Colorado (PSC) considers that an exemption from all but one category of the training rule should be granted for Fort St. Vrain.
Fort St. Vrain is currently being actively dismantled in accordance with an approved Decommissioning Plan. This project is well-defined, with a limited duration, and it is expected to be completed by the end of 1995. There is no nuclear fuel remaining under 10 CFR 50 license provisions and there are no credible accident scenarios that could result in offsite doses greater than a small fraction of the EPA Protective Action Guidelines. The only plant features relied upon for accident mitigation are reactor building confinement and ventilation, and extensive operations and/or maintenance training is not required. Section 2.6 of the approved FSV Decommissioning Plan identifies the licensing basis requirements for the decommissioning training program, and this section does not require that a systems approach to training be incorporated. Also, PSC is a single unit nuclear utility; there are no other nuclear facilities onsite or within our control that would require implementation of training rule provisions. With one exception, the benefits of implementing the training rule would clearly not be achieved during the Fort St. Vrain Decommissioning Project.
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P-93079 July 29,1993 i
Page 2 The nine categories of nuclear plant personnel specifically addressed by the training rule are as follows:
1.
Non-licensed operator 2.
Shift supervisor 3.
Instrument and control technician 5.
Electrical maintenance personnel 6.
Mechanical maintenance personnel 7.
Radiological protection technician 8.
Chemistry technician 9.
Engineering support personnel Of these categories, FSV does not have a shift technical advisor. The only category of personnel at FSV who perform duties comparable to those required during plant operations is radiological protection technicians, which include radiochemistry and radioactive waste personnel. For personnel in this category, PSC's decommissioning contractor does use a systems approach to training that complies with the new training rule. For the remaining categories, PSC's systems approach to training provisions were discontinued when the decommissioning training program was implemented, in accordance with Section 2.6 of the approved Decommissioning Plan. The decreased safety significance of these other personnel categories during decommissioning is such that use of the systems approach to training is not warranted.
PSC considers that the current decommissioning training program, as approved in the FSV Decommissioning Plan, is appropriate for ensuring the safe accomplishment of decommissioning activities. As described in the referenced letter, and as discussed 1
during a telephone conversation with the N'RC on July 7,1993, PSC anticipates that an exemption from the training rule requirements in 10 CFR 50.120 will be issued, for all personnel categories except radiation protection technicians.
lf you have any questions regarding this information, please contact Mr. M. H. Holmes j
at (303) 620-1701.
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Sincerely, A(b /T0NahJw Don W. Warembourg Decommissioning Program Director
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P-93079 July 29,1993 Page 3 DWW/SWC cc:
Mr. John H. Austin, Chief Decommissioning and Regulatory Issues Branch Regional Administrator, Region IV Mr. Ramon E. Hall, Director Uranium Recovery Field Office i
Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Health i
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