ML20056D651

Resubmits Info Supporting Exemption from New Training Rule, 10CFR50.120,during Plant Decommissioning

ML20056D651
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/09/1993
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-93081, NUDOCS 9308170266
Download: ML20056D651 (3)

Text

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16805 WCR 191/2; Platteville, Colorado 80651 August 9,1993 Fort St. Vrain Unit No.1 P-93081 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Docket No. 50-267

SUBJECT:

Training Rule Implementation

REFERENCES:

1. PSC Letter, Warembourg to Document Control Desk, dated July 29,1993 (P-93079)

2. NRC Letter, Grimes to Licensees of Plants _in Decommissioning Process, dated June 25,1993 (G-93097)

Gentlemen:

In Reference 1, Public Service Company of Colorado (PSC) provided information regarding the existing training programs at Fort St. Vrain (FSV), to support an exemption from the new training rule (10 CFR '50.120) during Fort St. Vrain decommissioning. Based upon subsequent discussions with the NRC, PSC is hereby re-submitting this information to support a total exemption from the requirements of the ,

training rule. This letter supersedes the Reference I letter in its entirety.  ;

As requested in Reference 2., this submittal describes the current plant conditions during decommissioning and explains why the systems approach to training (SAT), as required by the training rule, is not necessary for FSV decommissioning personnel in the categories addressed by the training rule.

i 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 1 nonnn - \ t i 9308170266 930809 7 ,

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P-93081  :

hugust 9,1993 /'

Page 2 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 fac?lities onsite or within our control that would require implementation of training rule provisions. The benefits from implementing the training rule would clearly not be achieved during the Fort St.

Vrain Decommissioning Project.

I The nine categories of nuclear plant personnel specifically adaressed by the training rule  ;

are as follows:  ;

1. Non-licensed operator 7

2. Shift supervisor  ;

3. Shift technical advisor

4. 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 currently 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. As described in Section 2.6 of the approved Decommissioning Plan, FSV's decommissioning training program ensures that workers in radiologically _

controlled areas (such as the Reactor Building) receive training commensurate with the >

potential hazards, including general employee training, radiation worker training, and specific job training as appropriate. Based on the reduced nuclear safety hazards during decommissioning, the safety significance of these nine personnel categories is considerably less during decommissioning than during plant operations, to the extent that

- use of the systems approach to taining is not necessary at Fort St. Vrain.

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P-93081

' ugust 9,1993 A  ;

Page 3 j PSC considers that the current decommissioning training program, as approved in the [

FSV Decommissioning Plan, is appropriate for ensuring the safe accomplishment of _l decommissioning activities. As described in Reference 2, and as discussed during  ;

telephone conversations with the NRC on July 7 and August 4,1993, PSC anticipates .!

that an exemption from the training rule requirements in 10 CFR 50.120 will be i+ sued. j i

If you have any questions regarding the FSV decommissioning training programs f discussed above, please contact Mr. M. H. Holmes at (303) 620-1701. l t

1 Sincerely, ALynw 1 l

Don W. Warembourg . 'l Decommissioning Progfam Director i i

DWW/SWC j cc: Mr. John H. Austin, Chief '

Decommissioning and Regulatory Issues Branch j Regional Administrator, Region IV l i

Mr. Ramon E. Hall, Director Uranium Recovery Field Office Mr. Roben M. Quillin, Director Radiation Control Division ,

I Colorado Department of Health 1

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