ML20127P181

Forwards Requests for Exemption from 10CFR50.54 Requirements That Specify Min Licensed Operator Staffing Levels,Based on Number of Operating Units at Plant Site.Requalification Program Will Be Replaced by Fuel Handler Program

ML20127P181
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/27/1993
From:	Cross J, Robinson W PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9302010206
Download: ML20127P181 (5)

Text

. . A 1( m y en - Portland General Electric Company .

- I,  !

James E. Cross .

Vice President and Chief Nucioar Officer -

January 27, 1993 i Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attnt Document Control Desk Washington DC 20555 Dear Sirst i Requests for Exemption from Certain ..

Requirements of Title 10 of the Code of Federal .,

Regulationa._Fati_.5DJLu0 CflL10dhL_Cund111ona_nLlicensca:

Portland General Electric Company has decided.to permanently _ cease- _.

.i operation of the Trojan Nuclear Plant. In support of this decision, the; reactor is being defueled and an application for a Possession only License has been developed. Atter completion of the reactor defueling:and receipt -

of the Possession only License, plant operating activities which require--

• Licensed and Senior Licensed Operators will no. longer be conducted. -

Therefore, requests for exemption from certain requirements of 10 CFR 50.54 i regarding Licensed Operators have been prepared.and are enclosed as-t Attachments I and II to this letter.

Sincerely, t k

W. R. Robinson ,

for J. E.-Cross Attachments c: Mr. John B. Martin Regional Administrator, Reg on V U.S. Nuclear Regulatory Commission ,

Mr. David Stewart-Smith State of Oregon Department of Energy h '

Mr. Kenneth Johnston V NRO Senior Resident Ins 440024 Trojan Nuclear Plant '1 gi 9302030206 930227-PDR m-P ADOCK-05000344' .

PDR _21 SW Salmon Street, Portland, OR 97204 1503/464-8897?

. Trojan Nuclear Plant Document Control Desk Docket 50-344 January 27, 1993 License NPF I Attachment 1 Page 1 of 2 REQUEST FOR EXEMPTION FROM TITLE 10 0F THE CODE OF FEDERAL _ REGULAT10N S . _ l'ARL50. 54_110_.0FIL50. 54 f m ) ( 2 ) ( 1 )]

Reques LIor_ Exemption The requirements of 10 CFR 50.54(m)(2)(1) specify the minimum Licensed Operator staffing 1cvels for nuclear power plant licensees. These staffing levels are based upon the number of operating units on a plant site. These requirements specify at 1 cast one Licensed Operator and one Senior Licensed Operator, per shift, for a plant site with no operating units. Portland General Electric Company is seeking specific exemption, in accordance with the provisions of 10 CFR 50.12, from these stafflug requirements, llackground Portland General Electric Company has decided to permanently cease operation of the Trojan Nuclear Plant. In support of this decision, the reactor is being defueled and an application for a Possession Only License has been developed. After completion of the reactor defueling and receipt of the Possession only License, plant operating activities which require Licensed Operators and Senior Licensed Operators will no longer be conducted. Therefore the requirements of the table in 50.54(m)(2)(1) to maintain these licensed personnel in the Control Room should no longer be applied to the Trojan Nuclear Plant.

Discuselon 10 CFR 50.54 specifies the conditions the Nuclear Regulatory Commission (NRC) attaches to facility operating licenses (whether they are stated within the license, or not ). These conditions restrict the conduct of certain activities to Licensed Operators or fienior Licensed Operators.

These activities are described below.

10 CFR 50.54(1) prohibits manipulation of the controls of a nucient power plant by anyone who is not a Licensed Operator or Senior Licensed Operator. Controls are defined in 10 CFR 55.4 as apparatus and mechanisms, the manipulation of which directly offects the reactivity or power 1cvel of the reactor.

10 CFR 50.54(j) requires that manipulation of apparatus or mechanisms, other than controls, which may affect reactivity or reactor power level be done with the knowledge and consent of a Licensed Operator or Senior Licensed Operator who is present at the controls.

a

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, 7.rojan Nuclear Plant Document Control Desk -]

, Docket 50-344 January 27, 1993 License NPF-1 Attachment I Page 2 of 2 10 CFR 50.54(k) requires a Licensed Operator or Senior Licensed Operator to be present at the controls at all times during operation of the facility.

Since the Trojan Nuclear Plant has ceased power operation and will be '

permanently defueled, plant operating activities which require Licensed Operators will no longer be conducted. Therefore, there will be no need to maintain these personnel on duty in the Control Room.

-i Based upon the infonnation above Portland General Electric Company has concluded that specific exemption requested herein is justified, will not present undue risk to the public health and safety and is consistent with #

the common defense and security. Furthermore, such an exemption, meets the requirements of 10 CFR 50.12(11). in that maintaining Licensed-Operators and Senior Licensed Operators in the Control Room ;when: plant operating activities requiring their presence will no longer be conducted, does not serve the underlying purpose of the rule. Such an exemption also meets the requirements of 10 CFR 50.12(111) in that compliance with the requirements to maintain licensed and Senior Licensed Operators in the Control Room would result in undue costs (associated with maintaining their qualifications) since activities requiring their presenc9 will no longer be conducted.

Rolential_InvirsnmentaLImpact Pursuant to the provisions of 10 CFR 50.12, Portland General Electric Company is requesting exemption to the requirements in the table of 10 CFR 50.54(m)(2)(1) to maintain Licensed Operators and Senior Liecused Operators in the Control Room once the reactor is permanently defueled.

The proposed exemption is administrative in nature. .As such, the ,

exemption will not result in a change in type or quantity of radioactive or nonradioactive effluents, an increase in the licensed power level or plant configuration. Therefore, the proposed exemption will not have a significant impact upon the environment.

7418W(3).0193 a._ _

a . . *

, Trojan Nuclear Plant Document Control Desk

. Docket 50-344 January 27, 1993 License NPF-1 Attachment II Page 1 of,2 REQUEST FOR- EXD!PTION FROM TITLE 10 0F IllE CODE OF fEDERAlcREGU1ATIDNLJAILT 50.54 110_!:r1L10dMy1L Requcal_for_ Exemption The provisions of 10 CFR 50.54(x) allow a licensee to take reasonable action that departs from a license condition or technical specification.

The provisions specify that this action may only be taken in an emergency when the action is needed to protect pubile health and safety and no-alternativo actions, consistent with license conditions or technical' ,

specifications are immediately apparent. 10 CFR 50.54(y) specifies that- >

licensee action permitted by paragraph 50.54(x) shall be. approved, as a minimum, by a Senior Licensed Operator prior to taking the action.

Portland General Electric Company is seeking specific exemption, in accordance with the provisions of 10 CFR 50.12, from the_ requirement-of paragraph 50.54(y) that action permitted by paragraph 50.54(x) receive print approval from a Senior Licensed Operator. In place of-this requirement. Portland General Electric Company requests that the authority to decide to depart from license or Technical Specification-conditions be placed with a Certified Fuel Handler.

Backgrnund Portland General Electric Company has decided to permanently cease operation of the Trojan Nuclear Plant. In support of this decision, the ,

reactor is being defueled and an application for a Possession only License has been developed. After completion of the reactor defueling_

and receipt of the Possession Only License, plant operating activities which require licensed personnel will no longer be conducted. Therefore, the Trojan Licensed Operator Requalification Program will be discontinued and replaced by a Certified Fuel Handler Program.

It is desirable to maintain the flexibility that 50.54(x)' offers to respond to unforeseen circumstances. However, it is not considered necessary to limit the authority to exercise this flexibility to a Senior Licensed Operator once the Plant has been permanently defueled.

Discussion r In the original notice as a Proposed Rule (August __18,_1982 Federal .

Register, 47 FR 35996), the provisions which became codified as 50.54(x) and 50.54(y) contained a comment f rom Nuclear Regulatory Commission -(NRC)

Commissioner Gilinsky. His comment was that the decision to operate outside the Technical Specifications should be made by a Senior Licensed' Operator. This was based upon his understanding that Licensed OperatoraL

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. Trojan Nuclear Plant Document Control Desk

. Docket 50-344 January 27, 1993 License NPF-1 Attachment'11 Page 2 of 2 were not trained or tested on both the basis and importance of the Technical Specifications. Commissioner Gilinsky solicited public. comment on this issue. On the basis of comments received, the NRC retained and clarified the origine11y proposed requirements that the decision to depart from the license or Technical Specifications be made by at least a Senior Licensed Operator.

Since plant operating activities requiring Licensed Operators or Senior Licensed Operators will no longer be conducted at Trojan, the Licensed Operator Requalification Program at Trojan will be discontinued. The Licensed Operator Roqualification Program will be replaced with a Certified Fuel llandler Program. Personnel trained as Certified Fuel Handlers will receive training and be tested on both the basis and the importance of the Technical Specifications. f Based upon the above, Portland General Electric Company has concluded that the exemption requested herein is justified, will not present undue risk to the public health and safety and is consistent with the common defense and security. -

Furthermore, such an exemption meets the requirements of 10 CFR 50.12(11) in that restricting authority to depart from license or Technical Specification requirements-to a Senior Licensed Operator, once the reactor is defueled, is not necessary to achieve the underlying purpose [

of the rule. The underlying purpose of this rule is accomplished by placing this authority with Certified Fuel llandlers who will be trained

'n accordance with an NRC-approved program.

EotentialEnvironmen.taLimpAA.t Pursuant to the provisions of 10 CFR 50.12 Portland General Electric Company is requesting exemption to the requirements of 50.54(y) that'  :

action pennitted by Paragraph 50.54(x) receive prior approval from a Senior Licensec Operator. In place of this requirement, Portland General Electric Company is proposing that the authority to decide to depart from-license or Technical Specification conditions be placed with a Certified -

Fuel llandler.

The proposed exemption is administrative in nature._ As such, the exemption will not result in a change in type or quantity of radioactive or nonradioactive effluents, an increase in the. licensed power level or.

Plant configuration. Therefore, the proposed exemption will not have a significant impact upon the environment.

7418W(5).0193 h