ML20058E335
| ML20058E335 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/19/1993 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20058E332 | List: |
| References | |
| NUDOCS 9312060266 | |
| Download: ML20058E335 (9) | |
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UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION In the Matter of
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SOUTHERN CALIFORNIA EDISON COMPANY
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Docket No. 50-206 l
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(San Onofre Nuclear
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Generating Station, Unit 1)
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[XEMPTION I.
The Southern California Edison Company (the licensee), is the holder of facility Operating (Possession Only) License No. DPR-13 which authorizes possession and maintenance of the San Onofre Nuclear Generating Station, Unit 1 (SONGS 1 or the plant. The license pr0Vides, among other things, that f
the plant is subject to all rules, regulations, and orders of the Commission now or hereafter in effect.
The plant is a permanently shutdown light water reactor, currently in the l
process of being decommissioned, and is located at the site of the licensee in i
San Clemente, California.
II.
I The San Onofre Nuclear Generating Station, Unit 1 permanently ceased i
power operations in November 1992.
Future operation of SONGS 1 is prohibited by License Amendment No. 150, dated October 23, 1992, which amended the Facility Operating License No. DPR-13 to remove the operating authority of the licensee and allows the licensee to possess but not operate SONGS 1.
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PDR ADOCK 05000206 P
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-license amendment became effective as of the date the licensee provided i
certification that operation of the reactor has been permanently terminated and all special nuclear material, such as reactor fuel, has been permanently i
removed from the reactor and stored in the spent fuel pool. The licensee l
completed removal of the fuel from the reactor to the spent fuel pool on Mtrch 6, 1993, and provided the required certification on March 9, 1993. As
- 50. LGS 1 is permanently shut down and defueled, the NRC on its own initiative, is granting an exemption from the requirements of 10 CFR 50.120 which are applicable to plants licensed to operate. This rule states the following:
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...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 the training program t
requirements of 10 CFR 50.120, except for certified non-licensed operators.
f However, it does not relieve the licensee from previous requirements or commitments to train and qualify facility personnel to maintain the plant in~ a non-operating defueled condition.
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
-i 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 circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.
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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 j
maintain the facility commensurate with the safety status of the facility.
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IV.
The licensee in its letter dated August 2, 1993, addressed the special circumstances related to why an exemption should be granted to the requirement l
that the SONGS 1 training programs comply with 10 CFR 50.120.
The reactor has I
been defueled and the fuel removed from the containment to the spent fuel pool. The reactor cannot be returned to operation because of License Amendment No. 150, which prohibits operation of SONGS 1.
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The licensee has stated that it believes that 10 CFR 50.120 was intended l
i to apply primarily to operational plants.
In publishing the regulation f
(58 FR 21904), the NRC stated that "If permanent changes in the condition of 1
the plant (i.e., decommissioning or Possession Only License) make some or all
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existing training programs unnecessary, the licensee would obtain relief from these requirements by applying for an exemption eliminating or modifying the I
affected programs." Further, the licensee stated that since the regulation I
was intended primarily for operational plants, and since a systems approach to training (SAT) program, as defined in 10 CFR 55.4, is not needed for SONGS 1 i
plant personnel, application of 10 CFR 50.120 to SONGS 1 would not serve the underlying purpose of the regulation. The current SONGS 1 training programs for the personnel categories required by 10 CFR 50.120 is as.follows:
tion-licensed Operators l
Training for certified fuel handlers (certified non-licensed operators),
will continue to be in accordance with the May 27, 1993, NRC-approved
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certified fuel handler training program. The licensee can make changes to this approved training under the provisions of 10 CFR 50.59 based on continued i
program conformance to 10 CFR 50.120.
7 Training for non-certified operators consists of training and i
qualification to monitor and manipulate plant equipment.
i Shift Supervisor The SONGS 1 shift supervisors are certified fuel handlers who are accountable for safe and efficient plant operation in the permanently defueled, mode, as SONGS 1 will no longer operate.
Shif t supervisors, as certified fuel handlers, receive training in accordance with the May 27, 1993, NRC-approved certified fuel handler training program, discussed above.
Shift Technical Advisor (STAl There are no longer any STA positions at SONGS 1 based on License Amendment No. 154, dated May 27, 1993.
Instrumentation and Control. Electrical. and Mechanical Maintenance.
The licensee stated that at SONGS 1 Instrument and Control Technicians, and Electrical and Mechanical Maintenance personnel perform the types of functions which are typical of these positions at an operational plant, such as calibration, and preventative and corrective maintenance of plant equipment. However, the number of systems and components involved is far. less than at an operational plant and the maintenance personnel need not be familiar with as many different types of equipment. The plant equipment which
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remains functional is not technically sophisticated and the skills required i
for maintenance are less complex.
Further, the licensee states that these
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individuals will be subject to the training requirements of 10 CFR 50.120 for the remaining two operating units onsite, although not for SONGS 1.
B_adiation Protection Technician l
l' The licensee states that radiological protection personnel functions at SONGS I are much less likely to involve activities capable of producing f
substantial personnel exposures than at an operational plant, since many of these activities have been eliminated. There will be no movement of 1
irradiated fuel into or out of containment. Containment entries while the plant is at power and the attendant neutron exposures have been eliminated.
There are no plans for work in high radiation, contamination, or airborne I
areas, or in harsh environments such as steam generator primary side entries.
The radiation levels of radioactive waste will be lower. Thus, the potential for personnel overexposure is much less at SONGS 1 than at an operational plant.
Further, the licensee states that these individuals will be subject to the training requirements of 10 CFR 50.120 for the remaining two operating units onsite, but not for SONGS 1.
Chemistry Technician t
The licensee states that the quantity of samples and types of analyses i
required of chemistry technicians at SONGS I are much less than at an l
operational plant. The only chemistry concerns are the quality of the spent fuel pool water and analyses of potential release pathways. Analyses of i
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primary coolant, steam generator, and condensate water are not needed, and l
water quality is not as critical for the spent fuel pool as it was for these j
other systems and components.
Further, the licensee states that these individuals will be subject to the training requirements of 10 CFR 50.120 for t
j the remaining two operating units onsite, but not for SONGS 1.
Enaineerina Support 9
The licensee states that a much lcwer level of engineering support is l
1 needed at SONGS 1 than at an operational plant, and the support required is generally less technically sophisticated..There are far fewer systems which must be kept functional, and those which are functional are not technically
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complex.
In particular, there are far fewer safety-related systems, and engineering support personnel knowledge of codes and standards, such as ASME Code, need not be as extensive.
There are no significant modifications or j
major component overhauls planned which would impose a large complex work load on engineering support personnel.
Further, the licensee states-that these i
individuals will be subject to the training requirements of 10 CFR 50.120 for two operating units onsite, but not for SONGS 1.
Thus, for all categories of training described above, the licensee indicates that the existing training requirements and commitments provide the
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protection necessary to ensure public health and safety given the current l
shutdown and defueled status of the facility. Although SONGS 1 personnel are i
subject to the SAT-based training program for the onsite operating Units 2'and l
l 3, when applied to Unit 1, such training does not fully comply with i
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10 CFR 50.120 since it was not formally developed considering all possible job tasks remaining at Unit 1.
14ith all of the SONGS 1 spent fuel stored in the j
spent fuel pool, the principal tasks and activities performed.on the site are l
l those necessary to monitor and maintain the spent fuel pool and associated support equipment. The tasks and activities associated with maintaining the f
i fuel are relatively simple compared to the tasks and activities required to j
maintain an operating nuclear power plant. Therefore, requiring SONGS 1 to
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comply with the literal training requirements specified in 10 CFR 50.120 is I
not necessary to achieve the underlying purpose of the rule.
The licensee states that to require it to comply fully with the requirements of the 10 CFR 50.120 would not serve the underlying purpose of l
the regulation.
The licensee contends that the regulation was established for i
i power operation conditions because such conditions could result in the j
potential for an accident with significant offsite consequences.
Since there f
now is no credible event at SONGS 1 that could result in exceeding the dose f
limits of 10 CFR Part 100, traditional non-SAT training is adequate for the l
personnel listed in 10 CFR 50.120 at SONGS 1.
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v.
r The NRC staff reviewed and agrees with the licensee analysis described above.
In addition, the NRC has previously reviewed the limiting design basis f
accident for SONGS 1 in this permanently shutdown condition. This design l
basis accident is the fuel handling accident. The results of this analysis,
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presented in Chapter 15.17 of the Updated Final Safety Analysis Report,
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1 indicated that if a fuel handling accident were to occur at SONGS 1, while the s
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I facility was still licensed to operate, the consequences would be'less than i
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the criteria provided in 10 CFR Part 100. The licensee in its letter dated November 5,1993, requesting approval to remove SONGS 1 from the site offsite-j emergency plan, provided the results of a fuel handling accident based on -
l current plant conditions. The results of this new analysis are a two-hour i
e dose to the thyroid of 0.5 mrem and a two-hour whole body dose of 1.3 mrem, at a
the exclusion area boundary. Thus, the consequences of the limiting design basis accident for the SONGS 1 facility are significantly less than 10 CFR i
Part 100, and significantly less than the EPA protective action guidelines of I to 5 rem. The staff has also determined that the tasks that remain to be performed by the SONGS 1 plant staff are fewer in number and significantly less complicated than the tasks performed by the staff of an operating nuclear l
plant. Thus, the NRC staff concludes that an exemption is reasonable based on (1) the significantly reduced risk to the public health and safety due to l
SONGS 1 being permanently shut down, and (2) the reduced number and complexity of tasks to be performed by the SONGS 1 site staff.
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i VI.
Based on the analyses presented in Section IV and V 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 l
i requirement of 10 CFR 50.12(a)(2)(ii) in that requiring compliance with 10 CFR l
t 50.120 is not necessary to achieve the underlying purpose of the rule where training will be provided commensurate with permanently shutdown and defueled l
condition of the facility.
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VII.
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 l
present an undue risk to the public health and safety, and is consistent with the common defense and security, i
Accordingly, the Conmission, on its own motion, hereby grants an exemption to 10 CFR 50.120 for training programs mandated by 10 CFR 50.120, except for certified non-licensed operator training. This exemption does not l
relieve the licensee of any other training requirements or commitments which they have made to the NRC, including those set out above.
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 61106, dated November 19, 1993).
I This exemption is effective on November 22, 1993, the implementation date
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of the rule.
I FOR THE NUCLEAR REGULATO OMMISSION t
Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation Dated at Rocxv111e, Maryland this 19th day of Ibverber 1993 i
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