ML20128M524
| ML20128M524 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/15/1993 |
| From: | Cross J, Robinson W PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302220198 | |
| Download: ML20128M524 (5) | |
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y, meat Amt une en Portland General Electric Compeny i
James E. Cross j
Vice President and Chief Nuclear Officer February 15,1993 Trojan Nuclear Plant i
Docket 50-344 l
License NPF-1 l
U. S. Nuclear Regulatory Commission Attn: Document Control Desk j
Washington. DC 20555 l
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Dear Sirs:
l Request for Exemption from 10 CFR 50 bppendix E(IV)(F)(2_)
1 Portland General Electric (PGE) is requesting an exemption from the requirements of Title 10 l
to the Code of Federal Regulations, Part 50, Appendix E, Section (IV)(F)(2), requiring each licensee at each site to exercise its emergency plan on an annual basis. This exemption will be I
applicable only for the 1992 exercise currently scheduled to be conducted in the first quarter of 1993. This exemption will allow PGE to better allocate available resources in the development of a revised emergency plan that better reflects the permanently shutdown and defueled condition of Trojan. Additionally, PGE shall perform an exercise using the Permanently l
Defueled Emergency Plan, subsequent to its approval by the NRC. The planned submittal date for the Permanently Defueled Emergency Plan is March 1,' 1993.
l On February 2,1993, PGE certified to the NRC that the reactor fuel had been permanentiv removed from the reactor vessel at Trojan and placed in the spent fuel pool. The basis for the requested exemption is submitted in the attachment to this letter.
J Sincerely, AN sd % ge d W. R. Robinson 4-for J. E. Cross Attachment N/
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9302220198 930215 PDR ADOCK 05000344 F
.._,.aW Salmon Street, Portland, OR 07204 503/464-8897-
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j Document Control Desk i
February 15,1993 Page 2 i
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Mr. John B. Martin i
Regional Administrator, Region V U. S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy l
Mr. Kenneth Johnston NRC Resident Inspector l
Trojan Nuclear Plant i
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l Trojan Nuclear Plant Document Control Desk Docket 50-344 February 15,1993 License NPF-1 Attachment Page1 of3 Request for Exemption from 10 CFR 50 J
Appendix E(IV)(F)(2)
Description of Exemption Request Title 10 of the Code of Federal Regulations, Part 50, Appendix E, Paragraph I\\,
Section F, Item 2 states, "Each Licensee at each site shall annually exercise its emergency plan." As a result of an extended forced outage resulting from a steam generator tube leak in November 1992, the Commission granted a schedular exemption from this annual e
requirement, deferring this exercise until the first quarter of 1993. Portland General Electric (PGE) has made efTorts to comply with this regulation, but as a result of the permanent cessation of the operation of the Trojan facility, compliance with this regulation j
would not serve the underlying purpose of the rule requiring the annual emergency plan exercise, and would result in the misallocation of PGE resources if the exercise were conducted as scheduled. Should PGE decide to restart the Trojan facility, a full scale exercise would be conducted prior to plant restart. PGE is requesting an exemption from the requirements of 10 CFR 50 Appendix E(IV)(F)(2) only with regard to the 1992 annual exercise scheduled for the first quarter of 1993.
Basis for Exemption Request The provisions of 10 CFR 50.12 allow specific exemptions from the a.wrements of 10 CFR 50 provided the exemptions are authorized by law, are consistent with the common defense and security, are accompanied by special circumstances, and do not 4
present an undue risk to the public health and safety. PGE concludes that the actisities sought to be conducted under this exemption request are clear!y authorized by law, are consistent with the common defense and security, and do not present an undue risk to the public health and safety. PGE believes special circumstances exist with regard to the i
performance of the annual exercise as described below.
10 CFR 50.12 (a)(2)(ii) states, " Application of the regulation 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;... "
By letter dated January 27,1993, Portland General Electric informed the Nuclear Regulatory Commission of PGE's decision permanently ceasing operations at the Trojan Nuclear Plant. Fur.her, by letter dated February 2,1993, PGE informed the Commission that the Trojan reactor had been permanently shutdown and defueled, with the nuclear fuel placed in the spent fuel pool.
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e Trojan Nuclear Plant Document Control Duk l-Docket 50-344 February 15,1993 i
Li' cense NPF-1 Attachment l
Page 2 of 3 i
l PGE has concluded that the degree of emergency planning and preparedness necessary to provide adequate protection of the public health and safety in a permanently shutdown'and i
defueled condition is significantly less than that provided by the existing Trojan Radiological Emergency Response Plan (RERP). Therefore, exercising the existing Plan 3
would not serve the underlying purpose of the rule.
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1 10 CYR 50.12 (a)(2)(iii) states, " Compliance would result in undue i
hardship or other costs that are sigmficantly in arcess of those contemplated when the regulation was adopted, or that are signipcantly in arcess of those incurred by others similarly situated;... "
Preparing and conducting the annual exercise scheduled for the first quarter of 1993, will result in a misallocation of monetary and human resources. PGE would apply these resources to timely development of and training on a plan that is representative of the i
substantially reduced risks associated with a permanently shutdown and defueled facility.
1 The exemption would allow PGE to apply its resources to revising the existing emergency l
plan to reflect the reduced potential risks of a permanently shutdown and defueled facility.
l Conclusion 4
PGE has made efforts to comply with the requirements of 10 CFR 50, Appendix l
E(IV)(F)(2), requiring each licensee to annually exercise its emergency plan. However, due to the previously unt "ipated cessation of operations at Trojan, the conduction of the 1992 annual exercise.-. not serve the underlying purpose of the rule, and would :
incur undue burden on PGE in terms of misallocated staff workload and monetary costs.
Available resources would be more appropriately spent on development of a revised -
emergency plan that better reflects the permanently shutdown and defueled condition of-
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Trojan.
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Potential Environmental Impact 1-j Pursuant to the requirements of 10 CFR'50.12, PGE is requestmg an exemption from the requirements of 10 CFR 50, Appendix E, (IV)(F)(2) for the Trojan Nuclear Plant. This exemption is applicable only to the 1992 annual exercise scheduled for the first quarter of
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1993.
The requested exemption does not involve any measurable environmental impacts,- as the ;
- plant configuration and operation are not changed.: In addition, the likelihood of a radiological accident is not affected as a result of the requested exemption.-
- The proposed change does not affect non-radiological plant effluents. Therefore, there are -
i no significant non-radiological environmental impacts associated with the requested :
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Trojan Nuclear Plant Document Control Desk Docket 50-344 February 15,1993 License NPF-1 Attachment Page 3 of 3 As the requested exemption does not involve changes to plant configuration and operation, has no impact on the likelihood of a radiological accident, and does not affect non radiological eflluents, the requested exemption does not therefore involve a significant environmentalimpact.
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