ML20058A549

Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120

ML20058A549
Person / Time
Site:	Three Mile Island
Issue date:	11/17/1993
From:	Grimes B Office of Nuclear Reactor Regulation
To:	GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20058A516	List: ML20058A514 ML20058A549 ML20058A563
References
NUDOCS 9312010117
Download: ML20058A549 (7)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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GENERAL PUBLIC UTILITIES

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NUCLEAR CORPORATION

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Docket No. 50-320

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(Three Mile Island Nuclear Station

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Unit 2)

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EXEMPTION l

I.

GPU Nuclear Corporation (the licensee), is the holder of Facility Operating (Possession Only) License No. DPR-73 which authorizes possession and maintenance of the Three Mile Island Nuclear Station, Unit 2 (TMI-2 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 placed in Post-Defueling Monitored Storage (PDMS), and is located at the licensee site in Dauphin County, Pennsylvania.

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II.

TMI-2 permanently ceased power operations in March 1979, fuel has been removed from the reactor and from the site, and detailed plans to place l

the facility in Post-Defueling Monitored Storage have been developed. By Amendment No. 45, dated September 14, 1993, License No. DPR-73 was modified to a possession only status. This license allows the licensee to possess, but not operate the facility.

In order to reflect the permanently shutdown and 9312010117 931117 PDR ADOCK 05000320 p

PDR-

, l defueled status of the plant, the NRC, on its own initiative, is granting an q

exemption from the requirements of 10 CFR 50.120. This rule states the l

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 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.

t 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

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present an undue risk to the public health and safety, and are consistent with the common defense and security; and (2) present special circumstances.

Section 50.12(a)(2)(ii) of 10 CFR Part 50 provides that special circumstances exist when application of the regulations in the particular 1

i circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

l 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.

t The licensee in its letter dated July 29, 1993, addressed the special circumstances related to the NRC requiring the THI-2 training programs to comply with 10 CFR 50.120. The reactor has been defueled and the fuel removed from the site. The reactor vessel internals have been removed and shipped offsite. The reactor cannot be returned to operation, i

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, The licensee has stated that the training requirements necessary to i

assure adequate protection of the public health and safety in a permanently shutdown and defueled facility are significantly less than the training t

requirements necessary to assure the public health and safety at an operating facility. The current TMI-2 training programs for the personnel categories required by 10 CFR 50.120 are as follows:

Non-licensed Operators The auxiliary operators currently assigned to THI-2 were previously qualified to work in THI-2. On entering PDMS, these individuals will become THI-I auxiliary operators and will be expected to complete the accredited non-licensed operator training and qualification program.

In preparation for PDMS, THI-1 auxiliary operators have begun classroom training and plant j

walkthroughs on selected THI-2 systems.

Prior to entry into PDMS, the TMI-1 auxiliary operators will have completed qualification on those systems.

Shift Supervisor There are no Shift Supervisors at THI-2. This category of personnel is not applicable to the current or future conditions at TMI-2.

r Shift Technical Advisor (STA)

There are no Shift Technical Advisors at THI-2. This category of personnel is not applicable to the current or future conditions at THI-2.

Instrumentation and Control. Electrical. and Mechanical Maintenance The' licensee stated that there are two instrumentation and controls technicians, two electricians, and two mechanics assigned to THI-2. These individuals were previously qualified to work in TMI-2 and possess years of THI-2 specific experience. Additionally, these individuals have been t

. qualified to the Systems Approach to Training (SAT) based training and qualification standards of the THI-1 accredited training programs. Additional personnel assigned to the TMI-1 Maintenance Department, who were previously assigned to THI-2, who possess the ex p ience to work on THI-2 equipment have also been qualified to THI-1 SAT-based accreditation standards. As systems are turned over to THI-1, additional training needs can be addressed, and TMI-1 maint.enance department personnel trained, as oppropriate.

Radiation Protection Technician All GPU Nuclear radiation protection technicians at TMI have completed the SAT-based and accredited THI-1 training and qualification program. All technicians attend continuing training which addresses changes to the plants (TMI-1 and THI-2) and plant and industry experience.

Basic technical skills required for THI-2 support are addressed.

Chemistry Technician All chemistry technicians supporting THI-2 are assigned to TMI-1 and have completed the SAT-based and accredited TMI-1 training and qualification programs.

All technicians attend continuing training which addresses changes to the plants (TMI-1 and TMI-2) and plant and industry experience.

Basic technical skills required for THI-2 support are addressed.

Enaineerina Support There is no THI-2 specific Engineering Support Personnel (ESP) Program.

On entering PDMS, TMI-2 engineers will be assigned to TMI-1 Plant or to Technical Function Division.

In addition, personnel in other departments will be transferred from THI-2 to Site Services. These personnel will be enrolled in the THI-1 ESP program, as appropriate.

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In addition to the above training, all individuals having unescorted access to the Three Mile Island plant site receive ger eral 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 TMI-2 defueled and decontaminated to a safe and stable conditior., the principal taske and I

activities performed on the site ar,e those necessary to monitor and maintain remaining systems. The tasks and activities associated with maintaining the remaining systems are relatively simple compared to the tasks and activities required to maintain an operating nuclear power plant. Therefore, requiring i

TMI-2 to comply with the literal training requirements specified in 10 CFR 50.120 is not necessary to achieve the underlying purpose of the rule.

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 TMI-2 in this permanently shut down condition. The results of this analysis indicated that if a release of radioactive materials were to l

occur at THI-2, the resulting offsite dose to the maximally exposed individual

- would be a small fraction of the 10 CFR Part 100 offsite dose limits. -The staff has also determined that the tasks that remain to be performed by the TMI-2 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

t on (1) the significantly reduced risk to the public health and safety due to TMI-2 being permanently shut down, and (2) the reduced number and complexity of tasks to be performed by the THI-2 plant 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 sati fies i

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 underlying purpose of the rule.

V.

I 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.

Accordingly, the Commission, on its own motion, hereby grants THI-2 an 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 i

NRC, including those set forth herein.

Pursuant to 10 CFR 51.32, the Commission has determined _that the a

l granting of this exemption will not have a significant effect on the quality of the human environment (58 FR 60704, dated November 17, 1993).

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' This exemption is effective on November 22, 1993, the implementation date of the rule.

FOR THE NUCLEAR REGULATORY MMISSION Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation Dated at Rockville, Maryland l

thir.17th day of November 1993 D

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