ML20058L588
| ML20058L588 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/19/1993 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | PORTLAND GENERAL ELECTRIC CO. |
| Shared Package | |
| ML20058L584 | List: |
| References | |
| NUDOCS 9312170096 | |
| Download: ML20058L588 (8) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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PORTLAND GENERAL ELECTRIC COMPANY
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Docket No. 50-344 L
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(Trojan Nuclear Plant)
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EXEMPTION t
I.
The Portland 09neral Electric Company, et al., (PGE or the licensee), is the holder of Facility Operating (Possession Only) License No. NPF-1, which authorizes possession and maintenance of the Trojan Nuclear Plant (Trojan or the plant). The licensa provides, among other things, that the plant is subject to all rules, regulations, and orders of the Commission now or hereafter in effect.
l The plant is a permanently shut down light water reactor, currently in the process of being decommissioned, and is located in Columbia County, Oregon, on the Columbia River.
i II.
The Trojan Nuclear Plant permanently ceased power operations in November 1992, fuel was removed from the reactor and placed into the spent fuel pool, and detailed plans to decommission the facility were developed.
The license was modified to a possession only status on May 5,1993. This license prohibits operation of the reactor. On March 24, 1993, the NRC staff issued a confirmatory order that prohibits novement of nuclear fuel into the i
reactor building without prior written NRC approval.
As the Trojan Nuclear I
9312170096 931119 PDR ADOCK 05000344 P
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. Plant is permanently shut down and defueled, the NRC 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:
...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 to maintain the plant in a non-m erating 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 present an undue risk to the public health and safety, and are consistent with the common (efense and security; and (2) who e special circumstances are present when inter.a_lfa, application of the regulation in the particular l
ci rcur.,
would not serve the underlying purpose of the rule or is not i
necessary to achieve the underlying purpose of the rule, or that compliance would result in undue hardship or costs significantly in excess of those contemplated when the regulation was adopted or those incurred by others j
similarly situated.
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.
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IV.
The licensee in its letters dated August 10, October 14, and October 21, 1993, addressed the special circumstances related to why an exemption should be granted to the requirement that the Trojan training programs comply with 10 CFR 50.120. The reactor has been defueled and the fuel removed tc the spent fuel pool. The reactor cannot be returned to operation because the licensee is prohibited from operating the facility under the current rossession only license. The licensee has stated that the training requirements necessary to assure adequate protection of the public health and safety in a permanently shutdown and defueled facility are significantly less than the training requirements necessary to assure the public health and safety at an operating facility as required by 10 CFR 50.120.
In a letter dated October 21, 1993, the licensee stated that, in lieu of meeting 10 CFR 50.120, Trojan Technical Specification 6.3.1, shall be met, which requires that each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions to those listed in 10 CFR 50.120, except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, Rev. 2, April 1987.
The licensee training programs for the personnel categories comparable to those required by 10 CFR 50.120 shall be as follows:
Non-licensed Operators In lieu of non-licensed operators, certified fuel handlers shall be trained in accordance with the April 27, 1993 NRC-approved certified fuel handler (CFH) training program. This program provides both initial and continuing training appropriate to the handiing, storage, and cooling of
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i nuclear' fuel. Topics include heat transfer and fluid flow, radiation control and safe operation of spent fuel handling and storage equipment, auxiliary and support systems, and administrative controls. Non-certified operators may participate as trainees in the CFH retraining program on an as-needed basis.
Shift Supervisor l
The Trojan shift supervisors are certified fuel handlers who are accountable for safe and efficient plant operation in the permanently defueled s
mode, as Trojan will no longer operate.
Shift managers are required to participate in the CFH retraining program.
In their submittal of October 21, 1993, the licensee stated that management and supervisory skills training will be provided to the shift manager candidates as part of the position qualification process.
Shift Technical Advisor (STA) 3 There are no longer any STA positions at Trojan based on License Amendment No. 190, dated May 5, 1993.
t Instrumentation and Control (I&C) Technician. Electrical Maintenance Personnel and Mechanical Maintenance Personnel The continuing training programs for I&C technicians; and electrical and mechanical maintenance personnel will include facility changes, procedure revisions, and department improvement areas. Continuing training will be required when a training need is identified. Specific maintenance department i
individuals are designated to implement the training programs.
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'l Radiation Protection and Chemistry Technician Radiation protection and chemistry technicians shall have combined duties for individuals who were qualified in both chemistry and radiation protection.
The radittion protection (RP) technician training consists of administrative, f
fundamentals, personnel monitoring, instruments, exposure control, respiratory i
protection, plant systems, radioactive materials, and on the job training.
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The Chem /RP techniciar: program contains the RP training program plus I
additional topics in the area of chemistry, spectroscopy, chromatography, and sewage treatment. The training program for both groups is being implemented by a chemistry and radiation protection department individual, j
Enaineerino Sucoort j
i The licensee stated that engineering support personnel currently receive training on an as-needed basis, in 10 CFR 50.59, accident analysis, systems, technical specifications, and procedure technical reviewer.
l The licensee caintains that with all of the Trojan spent fuel stored in the spent fuel pool, the principal taks and activities performed on the site are those necessary to monitor and maintair, the spent fuel pool and associated support equipment, and that the tasks and activities associated with maintaining the fuel are relatively simple compared to the tasks and activities required to maintain an operating nuclear power plant.
For all categories of training described above, the licensee indicates that its training commitments provide the protection necessary to ensure public health j
i and safety given the current shutdown and defueled status of the
, facility. Therefore, the licensee maintains that requiring Trojan 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 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 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 Trojan that could result in exceeding the dose limits of 10 CFR Part 100, requiring Trojan to comply with the training requirements specified in 10 CFR 50.120 would not materially contribute to increasing public health and safety.
V.
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 Trojan in this permanently shut down condition; a fuel handling L_..
L accident in the spent fuel pool. The results of this analysis indicated that if a fuel handling accident were to occur at Trojan, the resulting offsite dose to the maximally exposed individual would be significantly less than the U.S. Environmental Protection Agency Protective Action Guidelines. The staff has also determined that the task t at remain to be performed by the Trojan 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 Trojan being permanently shut down, and (2) the reduced number and complexity of tasks to be performed by the Trojan site staff.
VI.
Based on the analyses presented in Sections IV and V above, the staff concludes that sufficient bases exist for approval of t,iis exemption. The staff finds that the speciF 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 underlying purpose of the rule where training will be provided commensurate with permanently shut down and defueled condition of the facility.
VII.
Based on the above evaluation, the Commission has determined that, j
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 sommission, hereby grar ts 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 NRC, including those set out above.
l Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not have a significant effect on the quality of the human environment (58 FR c1106, dated November 19, 1993).
This exemption is effective on November 22, 1993, the implementation date of the rule.
FOR THE NUCLEAR REGULATO COMMISSION M
Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 19th day of November 1993 i
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