ML20057D189
| ML20057D189 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 09/27/1993 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | Shelter J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| Shared Package | |
| ML20057D185 | List: |
| References | |
| NUDOCS 9310010233 | |
| Download: ML20057D189 (7) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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SACRAMENTO MUNICIPAL UTILITY DISTRICT )
Docket No. 50-312
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(Rancho Seco Nuclear Generating
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Station)
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EXEMPTION I.
The Sacramento MuriHpal Utility District (the licensee), is the holder of Facility Operating (Possession Only) License No. DPR-54 which authorizes possession and maintenance of the Rancho Seco Nuclear Generating Station (Rancho Seco or the plant). The license provides, among other things, that the plant is subject to all rules, regulations, and orders of the Commission now or hereafter in effect.
The plant is a permanently shut down light water reactor, currently in the process of being decommissioned, and is located at the licensee site in Sacramento County, California.
II.
The Rancho Seco Nuclear Generating Station permanently ceased power operations in June 1989, fuel was removed from the reactor and placed into the spent fuel pool, and detailed plans to decommission the facility were developed.
By amendment dated March 17, 1992, License No. DPR-54 was modified to a possession only status. This license prohibits operation of the reactor and also prohibits movement of nuclear fuel into the reactor building without prior NRC approval.
In order to reflect the permanently shutdown and defueled 9310010233 930927 PDR ADOCK 05000312 P
status of the plant, the NRC, on its own initiative, is gra. icing a full exemption from the requirements of 10 CFR 50.120. This rule states the following:
...each nuclear power plant licensee, by November 22, 1993, shall establish, implement, and maintain a training program derived from a systems approach to training as defined in 10 CFR 55.4."
This exemption will relieve the licensee from all training program requirements of 10 CFR 50.120. However, it does not relieve the licensee from previous requirements or commitments to train and qualify facility personnel.
III.
The NRC may grant exemptions from the requirements of the regulations which, pursuant to 10 CFR 50.12(a), are (1) authorized by law, will not present an undue risk to the public health and safety, and are consistent with the cormon defense and security; and (2) present special circumstances.
Section 50.12(a)(2)(ii) of 10 CFR Part 50 provides that specic, circumstances exist when application of the regulations in the particular f
circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.
The purpose of 10 CFR 50.120 is to ensure that civilian nuclear power plant operating personnel are trained and qualified to safely operate and maintain the facility commensurate with the safety status of-the facility.
The licensee in its letters dated July 19 and July 29, 1993, addressed the special circumstances related to the NRC requiring the Rancho Seco training programs to comply with 10 CFR 50.120. The reactor has been defueled and the fuel removed from the containment to the spent fuel pool. The reactor i
cannot be returned to operation because of the March 1992 license amendment.
., The licensee has stated that the training requirements necessary to assure adequate protection of the public health and safety in a permanently l
shutdown and defueled facility are significantly less than the training requirements necessary to assure the public health and safety at an operating facility.
Each member of the Rancho Seco plant staff meets or exceeds the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the radiation protection manager who meets or exceeds the recommendations and qualifications of Regulatory Guide 1.8, September 1975. The current Rancho Seco training programs for the personnel categories required by 10 CFR 50.120 is as follows:
Non-licensed Operators For certified fuel handlers, the licensee provides training in accordance with the March 19, 1992, NRC-approved certified fuel handler 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 piocedures, and administrative controls. Training for non-certified I
operators is similar to that for certified fuel handlers except that the non-certified operators do not receive training on nuclear theory.
Shift Supervisor The Rancho Seco shift supervisors are no longer senior reactor operators.
They are certified fuel handlers who are accountable for safe and efficient plant operation in the permanently defueled mode.
In addition to certified fuel handler training, individuals designated as shift supervisors receive supervisor training consistent with the licensee training policy.
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There are no longer any STA positions at Rancho Seco based on license Amendment No. 117, dated March 17, 1992.
Instrumentation and Control. Electrical. and Mechanical Maintenance The licensee stated that it uses only qualified, journey-level individuals in these job categories. Therefore, initial technical training is not necessary.
Further, the licensee provides training on the a kinistrative 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 licensee 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.
Enaineerina Support This training consists of applicable procedure training, and the supervisor / manager training.
In addition to the above training, all individuals having unescorted 4$
access to Rancho Seco receive general employee training annually.
Thus, for all categories of training described above, the licensee indicates that the existing training requirements and commitments provide the protection necessary to ensure public health and safety given the current shutdown and defueled status of the facility.
With all of the Rancho Seco spent fuel stored in the spent fuel pool, the principal tasks and activities j
i performed on the site are those necessary to monitor and maintain the spent fuel pool and associated support equipment. The tasks and activities l
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'- i associated with maintaining the fuel are relatively simple compared to the tasks and activities required to maintain an operating nuclear power plant.
i Therefore, requiring Rancho Seco to comply with the literal training requirements specified in 10 CFR 50.120 is not necessary to achieve the underlying purpose of the rule.
Further, the licensee has also stated that compliance with the requirements of 10 CFR 50.120 would present an undue financial and administrative hardship.
Because the plant is permanently shut down, the licensee is dedicating its resources to safely decommissioning the plant once the NRC approves the decommissioning plan.
The licensee no longer has instructors to develop and maintain a systems approach to training (SAT) program, as defined in 10 CFR 55.4.
The licensee states that to require it to comply fully with the requirements of the SAT process would result in extreme hardship.
Further, the licensee contends that the regulation was established i
for power operation conditions because such conditions could result in the potential for an accident with significant offsite consequences. Since there now is no credible event at Rancho Seco that could result in exceeding the dose limits of 10 CFR Part 100, requiring Rancho Seco to comply with the training requirements specified in 10 CFR 50.120 would not materially contribute to increasing public health and safety.
The NRC staff reviewed and agrees with the licensee analysis described above.
In addition, the NRC has previously analyzed' the limiting design basis accident for Rancho Seco in this permanently shut down condition. This NRC Emergency Preparedness exemption to the Sacramento Municipal i
Utility District dated November 30, 1990.
. design basis accident is the fuel handling accident.
The results of this analysis indicated that if a fuel handling accident were to occur at Rancho Seco, the resulting offsite dose to the maximally exposed individual would be 0.14 rem,.'gnificantly less than the criteria provided in 10 CFR Part 100.
The staff '.as also determined that the tasks that remain to be performed by the Rancho Seco plant staff are fewer in number and significantly less complicated than the tasks performed by the staff of an operating nuclear plant. Thus, the NRC staff concludes the licensee justification for exemption is reasonable based on (1) the significantly reduced risk to the public health and safety due to Rancho Seco being permanently shut down, and (2) the reduced number and complexity of tasks to be performed by the Rancho Seco site staff.
IV.
Based on the analyses presented in Section III above, the staff concludes that sufficient bases exist for approval of this exemption.
In addition, the staff finds that the special circumstance present satisfies the requirement of 10 CFR 50.12(a)(2)(ii) in that requiring compliance with 10 CFR 50.120 is not necessary to achieve the cnderlying purpose of the rule.
V.
Based on the above evaluation, the Commission has determined that, pursuant to 10 CFR 50.12(a)(1), this exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security.
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. Accordingly, the Commission, on its own motion, hereby grants a full exemption to 10 CFR 50.120. This exemption does not relieve the licensee of any other training requirements or commitments which they have made to the j
NRC.
l Pursuant to 10 CFR 51.32, the Commission has determined that the granting
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of this exemption will not have a significant effect on the quality of the human environment (58 FR 47481).
This exemption is effective on November 22, 1993, the implementation date of the rule.
I FOR THE NUCLEAR REGULATORY COMMISSION
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- -- - t. y Brian K. Grimes, Director Division of Operating Reactor Support i
Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 27th day of September 1993 e
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