ML20127P203

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License Change Application 230 to License NPF-1,revising Facility Staffing & Training Requirements in Light of Transition of Facility to Permanently Defueled Status
ML20127P203
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 01/27/1993
From: Robinson W
PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20127P193 List:
References
NUDOCS 9302010211
Download: ML20127P203 (7)


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l PORTIRlD GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD A!O PACIFIC POWER L LICHT COMPANY l Operating License NPF-1 Docket 50-344 License Chnnge Application 230 1 This License Change Application (LCA) requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant. This LCA proposes to revise the facility staffing and training requirements. ,

I, W. R. Robinson, being duly aworn, subscribe to and say that I am the i Vice President, Nuclear, for Portland General Electric Company, the i applicant herein; that I have full authority to execute this oath; that i have reviewed the foregoing; and that to the best of my knowledge,

! information, and belief the statements made in it are true. .

2  ;

Date January 2'l, 1993  ;

By _

W. R. Robinson Vice President, Nuclear On this day personally appeared before me W. R. Robinson, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act.

l GIVEN under my hand nnd seal this# th day of January 1993.

j. h1tg)))]. CHAst%LJ Notary Public l'u and for the State of Oregon Residing at G 22d/4 }

My commission expires /dNf13.3[k I

9302010211 930127  ;

PDR- ADOCK 05000344 p PDR u _. _ _ __ . _ . _ _ _ _ . - _ . _ _ _ _ _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ ._. . . .

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UNITED STATES OF AMERICA l NUCLFAR REGULATORY COMMIT.SION i

in the Matter of )

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PORTLAND GENERAL ELECTRIC COMPANY, ) Docket 50-344 ,

Tile CITY OF EUGENE, OREGON, AND ) Operating License NPF-1 l l'ACIFIC POWER t, LICi!T COMPANY )

)

(TROJAN NUCLEAR PIANT) )

CERTIEICATE_0L SERVICE l I hereby certify that copies of License Change Application 230, to the Operating License for the Trojan Nuclear Plant, dated January A7,1993, hr.ve been served on the following by hand delivery or by deposit in the l United States mail, first class, this /7th day of January 1993:

) State of Oregon Department of Energy 625 Marion St NE Salem OR 97310 Mr. Michael J. Sykes l Chairman of County Conunissioners Columbia County Courthouse St. Helens OR 97051 l _ _/

[' II.'K. Chernoff '

Manager, Licensing

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l On this day personally appeared before me 11. K. Chernof f, to me known to ,

be the individual who executed the foregoing instrument, and acknowledged '

that he signed the same as his free act.

GIVEN under sny hand and seal this f_]th day of January 1993. l J

tt u. }7. sc LO(Lu.)

Notary Public in and for the State of Oregon Residing at GI 'rt[ M My conunission expires /)111dl%f}N

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LCA 230 Attactm.ent A Page 1 of 5 l DACKGROUND_AND. RFASONJOR _ CilANGE Portland General Electric Company (PCE) has announced the decision to cease further operation of the Trojan Nuclear Plant. As such, PGE has, under separate cover, applied f or a revision of Facility Operating l License NPF-1 to stipulate that PGE will only possess nuclear fuel and no longer intends to utilize the fuel for the production of power. The reactor will be defueled and the fuel will be stored in the spent fuel faellity.

The current regulations in Parts 50 and 55 of Title 10 of the Code of Federal Regulations (10 CFR 50 and 55) provide, in part, rules governing the training, qualifiention and staffing requirements for licensed operators. These requirements assume licensed operatars would be controlling an operating facility that would experience transients and malfunctions from routine startup through full power operation.

In the defueled condition, there are no longer any credible design basis accidents associated with an operating plant from startup through full power operation. The design basis accidents relative to a defueled facility are a small subset of those considered for an operating facility. The operators will primarily monitor and maintain the spent ,

fuel storage iacility to ensure that the public health and safety are not compromised.

As such, the operators do not require training and qualification in areas that would be of benefit only during power operations. In light of this, PGE has autmitted separately a Certifieu Fuel Handler Training Program for Nuclear Regulatory Commission (NRC) approval. The program will provide the training necessary for operators at a defueled facility. In this document, PGE is proposing to revise selected specifications in Section 6.0, Administrative Controls, to define'the facility staffing and training requirements for a defueled facility.

In order to make the changes proposed herein, it has also been determined to be necessary to obtain exemptions in accordance with 10 CFR 50.12, Specific Exemptions, from specific provisions of 10 CFR 50.54, Conditions of Licenses. The necessary exemption requests have-also been separately-submitted.

DESCRIffl0M_ANDEASON f0lLSEECIEIC_CilANGES The proposed changes to the Trojan Technical Specifications are as follows:

1. Section 6.2.2, Facility Staf f. Subsection a. - The minimum shif t crew size of five for safe shutdown is being eliminated since'the plant will be in a defueled condition and there will be no need for accomplishing any safe. shutdowns.

Table 6.2-1. Minimum ShifL Crew Composition, is being revised.to '

indicate the position requirements for a permanently defueled condition. A Shift Manager and a Non-Certified Operator will be

i LCA 230.

Attachment A-Page 2 of 5  !

required on each crew. Since the Plant will not be operating, there  !

is no longer a need for licensed operators or a Shift Technical [

Advisor.  :

Since this table is not consistent with the minimum staffing requirements found in 10 CFR 50.54(m)(2)(1), a specific exemption has been requested from the provisions of this regulation by separate correspondence. A footnote has been added to the table indicating l that the minimum shift crew composition represents a specific exemption to 10 CFR 50.54(m)(2)(1). The date of the exemption will need to be filled in by the NRC upon issuance of the amendment and i approval of the corresponding exemption request.

2. Section 6.2.2, Facility Staff, Subsection b. - The wording is being revised to require that one individual qualified to stand watch in the control room be in the control room when fuel is in the spent-fuel pool. The control room watch can be either a non-certified operator or a certified fuel handler. Since the reactor will not be  !

operated there is no need for an operator licensed in accordance with 10 CFR 55.

3. Section 6.2.2, Facility Staff, Subsection c. - This subsection required two licensed operators to be precent in the control' room for certain evolutions. Since these evolutions will no longer be conducted this requirement is being eliminated.
4. Section 6.2.2, Facility Staff, Subsection d. - This subsection is being revised to require an individual qualified in radiation ,

protection procedures to be onsite during fuel handlinF operations rather than when fuel is in the reactor vessel. Since the-reactor will no longer be operated, the most significant time when radiation safety should be closely monitored would be during fuel handling-operations.

5. Section 6.2.2, Facil.ity Staf f Subsection e. - This subsection addresses supervision requirements during CORE ALTERATIONS. Since CORE ALTERATIONS will no longer occur due.to the reactor being defueled, the requirement is being revised to state that fuel handling operations shall be directly supervised by a certified .f uel handler. - This change will- ensure fuel handling is performed under qualified supervision.

- 6. Section 6.2.2, Facility Staff,-Subsection f. - The composition of the Fire Brigade is being revised to preclude the use of the certified fuel handler on shift rather than " members of the minimum shift crew necessary for safe shutdown of-the unit". The provisions for a.

" minimum shift crew necessary for safe shutdown" is being eliminated

-from Subsection a. of Section 6.2.2. ,

7. Section 6.2.2 Facility Staff, Subsection g. - The applicability of this subsection is being revised to apply to personnel whose functions are'important to the safe storage of irradiated. fuel-assemblies rather than those who perform safety-related functions.

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'- LCA 230 Attachment A Page 3 of 5 in the third paragraph of this subsection, the phrases "when the plant is operating" and " extended periods of shutdown for refueling" are being deleted as they no longer apply. Similarly, in paragraph

d. of this subsection on Page 6-3, the phrase "except during extended shutdown periods" is being deleted.
8. Section 6.2.2 Facility Staff, Subsection h. - This subsection is being revised to require the Shift Manager to be a certified fuel handler. Previously, this subsection dictated which shift positions required licensed operators.

In addition, a sentence is being added to this subsection to indicate that an operator holding a license as a Senior Reactor Operator in accordance with 10 CFR 55 is a certified fuel handler. -This provision will allow senior licensed operators to fill the certified fuel handler positions until the certified fuel handler training program is isnplemented and personnel are trained.

9. Section 6.3, Facility Staff Qualifications - This section is being revised to climinate the positions of Shift Technical Advisor and Operations Manager. The Shif t Technical /.e."sor is not required for a defueled reactor.
10. Section 6.4, Training, Subsection 6.4.1 - This subsection-is being revised to climinate the requirement-for an operator training program in accordance with Section 5.5 of ANSI N18.1-1971 and 10 CFR 55 and instead a NRC-approved certified fuel handler training program will be conducted.
11. Section-6.5.1.2, Composition - This section is being revised to eliminate the requirement that one member of_the Plant Review Board (PRB) hold a Senior Reactor Operator License on Trojan. Since Trojan will be in a permanently. def ueled condition, it is _not necessary f or a member of.the PRR to be so qualified.
12. Section 6.8.3.b. Temporary Changes to Procuoares - This'section is-being revised to require a certified fuel handler to approve temporary changes to procedures rather than a senior reactor operator.

6 NO SIGNIFICANI_11AZARDS_CONSIDF. RATION _ DETERMINATION In.accordance with the requirements of 10 CFR-50.92. Issuance of-Amendment, this license amendment request is judged to involve no significant hazards consideration based upon the following:

1. The proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change is to eliminate the requirements for licensed operators and a licensed operator training program and to replace those with certified fuel handlers and a certified fuel handler

LCA 230 Attachment A Page 4 of 5 training program. Since the Plant is to be defueled, the range of accidents for which an >perator needs to be trained will significantly diminish wch that a training program of the depth and breadth of that required a; 10 CFR 55 is no longer needed. In lieu of a 10 CFR 55 licensed og rator training program, a NRC-approved certified fuel handler training program will be utilized. Since this training program will adequately equip the oper *ns personnel for fuel handling operatiu.., ine'2 ding responses tt w ormal events /

accidents, there will ha no rease in the probab.dity of these events occurring or 1, the requences of these events. The proposed changes do not afit 1ent equipment or the procedures for equipment operation or response to abnormal events / accidents.

2. The proposed licenso amendment 'oes not create the possibility of a new or different kind of accicent from any accident previously evaluated.

The proposed change is to eliminate the requirements for licensed operators and a licensed operator training program and to replace those with certified fuel handlers and a certified fuel handler training program. This change ensures the qualifications of the operations personnel are commensurate with the tasks to be performed and the conditions to be responded to. This change does not affect Plant equipment or the procedures for operating Plant equipment and, therefore, does not create the possibility of a new or different kind of accident f rom any accident previously evaluated. ,

3. The proposed license amendment does not involve a significant reduction in a margin of safety.

The proposed change is to eliminate the requirements for licensed

, operators and a licensed operator training program tfd Lo replace those with certified fuel handlers and a certified fuel handler training program. This change ensures the qualifications.of the operatione personnel are commensurate with the tasks to be performed and the conditions to be responded to. The assumptions for a fuel handling accident in the Fuel Building are n;t af fect sJ 1-y the proposed changes. Therefore, the proposed an,eadment ccis not involve

a reduction in a margin a safety.

ENVlRDNMMTAk_IMACLDETE1011 NAIL 0N This amendment request meeto the criteria specified in 10 CFR 51.22(c)(9) for a categorical ev 1usion from the requirements to perform an environmcntal teview. The specific criteria contained in that section are discussed below.

(1) The amendment involves no significant hazards consideration.

As demonstrated above, the proposed amendment does not involve a significant hazards consideration.

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  • LCA 230-.

Attachment A-Page 5'of 5 (ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released-offsite.

The proposed changes involve no changes to the Plant or operating-procedures which would af fect the amounts of effluents or create new types of effluents.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed enanges do not affect radiation exposures to personnel nor do they affect radiation levels present in the Plant.

SCIIEDULILCONSIDEHATION It is requested that 30 days h - ne-- for implementation'of the changes required by this amendment.

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