ML20155F662

Exemption from Requirements of 10CFR55.45(b)(1), 10CFR55.45(b)(2),10CFR55.45(b)(4),10CFR55.45(b)(5), 10CFR55.45(a)(2),10CFR55.53(e) & 10CFR55.53(f) Re Operators Licenses About Requirements for Plant Simulation Facility

ML20155F662
Person / Time
Site:	Three Mile Island
Issue date:	10/06/1988
From:	Varga S Office of Nuclear Reactor Regulation
To:	GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20155F656	List: ML20155F652 ML20155F662
References
NUDOCS 8810130349
Download: ML20155F662 (7)

Text

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7590-01 U,NITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of GPU NUCLEAR CORPORATION ) Docket No. 50-320 (Three Mile Island Nuclear Station Unit 2) )

KXEMPTION 1.

GPU Nuclear Corporation, Metropolitan Edison Company, Jersey Central Power and Light Company and Pennsylvania Electric Company (collectively, the licensee) are the holders of Facility Operating License No. DPR-73, w'.ich had authorized operation of the Three Mila Island Nuclear Station, Unit 2 (TMI-2) at power levels 4 up to 2772 megawatts thermal. The facility, which is ic:ated in Londonderry Township, Dauphin County, Pennsylvania, is a pressurized water reactor previously used for the commercial generation of electricitf.

i By Order for Modification of License, dated July 20, 1979, :% licensee's authority to operate the facility was suspended and the licensee's authority was l limited to maintenance of the facility in the present shutdown cooling mode (44 FR 45271). By further Order of the Director, Office of Nuclear Reactor

( Regulation, dated February 11, 1980, a new set of formal ' license requirements l .

was imposed to reflect the post-accident condition of the facility and to .

i l assure the continued maintenance of the current safe, stable, long-term cooling I

condition of the facility (45 FR 11292). The license provides, among other things, that it is subject to all rules, regulations and Orders of the  ;

l Comission now or hereafter in effect. l l

l 8810130349 PDR 881006 i ADOCK 05000320 PDC

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1 2-II.

By letter dated December 28, 1987, the licensee requested an exemption from the requirements 1) to administer the operating tests for operators and senior operators in a simulation facility, and 2) a reduction in the hourly requirements (watchstanding) for maintaining an active operator's license.

Exemption from the requirement to administer the operating tests for operators and senior operators in a simulation facility would eliminate the -

licensee's need for an f RC approved or certified simulation facility. The licensee therefore requested in the December 28, 1987 submittal an exemption from the requirement to submit a plan for the development of a siniulation facility or an application for use of a simulation facility.

Requirements for the content of operating tests are contained in 10 CFR 55.54 Also 10 LFR 55.45(b)(1) "Aditinistration" requires that the operating

! test be administered in a plant walkthrough and in a sin.ulation facility. The tern. "simulation facility" is defined in 10 CFR 55.4 as "one or more of the following components, alore or in combination, used for the partial corduct of operating test for operators, senior operators and candidates: 1. The plant,

2. A plant-referenced simulator, 3. Another simulation device." A schedule for implementing this requirement is contained in 10 CFR 55.45(b)(2) "Schedule for facility licensees." This section requires that within one year after the I effeciive date of this part [May ?6,1987) each facility 'shall submit a 4

plan for the development of its simulation facility. The licensee has also requested an exemption frcm this requirement consistent with their request for an exemption from the requirement to use a simulation facility to license s

operators.

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3-Application and certification requirements for a simulator facility are givenin10CFR55.45(b)(4)and10CFR55.45(b)(5)respectively. Again the licensee has also requested an exemption from these requirements consistent with their request for an exemption from the requirement to use a simulator facility in licensing operators, i Requalification requirements for operators are given in 10 CFR 55.59 "Requalification." 10CFR55.59(a)(2)"RequalificationRequirements"requires that each individual possessing an operator license shall pass a comprehensive i requalification written examination and an operating test. 10 CFR 55.45(b)(1) requires that a sirrulation facility be utilized in the conduct of the operating 1

test. Thus, the licensee requests an exemptien from the requirement to utilize l 1

a simulation facility in satisfying the requirements of 10 CFR 55.59(a)(2).

The licensee also requested in the December 28, 1987 letter an exemption i

fron, the hourly or watchstanding requirements for maintaining an active l

operator's license The hourly watchstanding requirements for maintenance of an operator's license a,a containedin10CFR55.53(e)and(f). To maintain active status 10 CFR 55.53(e) requires in part that the licensee actively perforn the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter. If this requirement is not tret, before resumption of functions authorized by a license,10 CFR t

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,! 55.53(f) requires, in part, that the licensee has completed a minimurs of i

40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The licensee proposed a substantial reduction in both above stated ,

watchstanding requirerrents, i

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The licensee, after discussions with the NRC staff, has revised their request for reduction in watchstanding requirements from their original proposal contained in the December 28, 1987 letter. The licensee now proposes the watchstanding requirement to maintain an active operator's license as described in 10 CFR 55.53(e) be reduced from a minimum of seven 8-hour shifts to four 8-hour shifts per calendar quarter. The licensee also proposed to reduce the watchstanding requirement to resume active status if the watch-standing requirement to maintain active status is not met from 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift function, as presently required by 10 CFR 55.53(f), to two 8-hour shifts.

III.

TVI-2 is currently in a post-accident, cold shutdown, long-tern cleanup mode, with sufficient decay heat removal assured by direct heat loss from the reactor coolant system to the reactor building atmosphere. The licensee is presently engaged in defueling the damaged reactor, decontaminating the facility and readying the plant for long-term storage. As of the end of June 1988 approximately 65% of the fuel contained in the reactor vessel has been I removed. Defueling the facility has progressed to the regions below the location of the original core volume. Defueling activities within the reactor building will be completed early in calendar year 1989. At that t'me, once

! the possibility of a criticality is precluded the licenseo will no longer be required to nian the control room with licensed operators.' The requirements to maintain safety related plant systems has already been deleted from the operating license and the control room is now principally used as a central location to monitor plant conditions. The present unconventional configuration

o of the TMI-2 plant and its continuing changing nature as defueling and decontamination progresses does not allow testing of licensed operators on evolutions nonnal to an operating facility.

The licensee has requested exemption from the requirements to use a simulation facility for licensed operator testing and requalification and has also requested reductions in the watchstanding requirements to maintain an operator's license, which requires an exemption from the regulations.

Due to the unique cold-shutdown, partially defueled condition of TMI-2, there is no plant-referenced simulator or simulation facility that reflects the current condition of TMI-2. The time to design, procure, install, and begin to operate a simulation facility would exceed the period of time in which licensed operators would be required at the facility. Furthennore, due i to the changing nature of the cleanup effort any design of a simulator would be quickly outdated. The use of the facility as a simulation facility. is not j practical since this would require facility manipulations not authorized by

_ the facility license.

The licensee does rnt plan to license any additional operators between now and the end of defuelirg next spring when licensed operatcrs will no .

longer be needed. Maintenance of current operator licenses will be through an approved TMI-2 Licensed Operator Requalification Training Program. Although

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I 10CFR55.59(a)(2)requiresthattherequalificationtrainingprogranconsist ofbothawrittenexaminationandanoperatingtestand10CFR55.45(b)(1) requires a simulation facility for conducting the operating test, the licensee proposes not to employ a simulation facility for annual requalification. The l NRC approved requalification program consists of pre-planned lectures, a plant drill program, an operational review program and an evaluation of each licensed operator, j

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The NRC staff has determined that the current and future plant conditions, the length of tirre that licensed operators will be needed, and the time necessary to construct a simulator warrant exemptions to the requirements of 10 CFR 55.45(b)(1), "Implementation-Adninistration," 10 CFR 55.45(b)(2),

"Schedule for facility licensees," 10 CFR 55 45(b)(4), "Application for and approval of simulator facilities," 10 C'155.45(b)(5), "Certification of simulation facilities," and 10 CFR 55.59 c )(2), "Requalification requirements" to the extent that they require a simulation facility or the use of a sin:ulation facility to grant or maintain operators licenses.

The staff recognizes that some reduction in the hourly watchstanding requirement for maintenance of an operator's license is appropriate. The current requirenents of 10 CFR 55.53 were based on the assumption that the operators would be controlling an operating facility which is not the case at TMI-2. The TMI-? operators furction largely to prevent a criticality in a l reactor in which the potential for a criticality is greatly reduced from operating facilities. Furthermore, the potential for recriticality at TMI-2 l

i decreases on an alnost daily basis as defueling progresses. In contrast to l

operating facilities, TMI-? is essentially in a static mode with little change i from day to c'ay. The principal operator activity is tronitoring various plant parameters to assure the continued safe shutdown of the facility and assist the ongoing decontamination and defueling activities.

Based on a review of the operator licensing requirements, the NRC staff finds that reducing the hourly watchstanding for maintenance of an operator's license from seven 8-hour shifts or five 12-hour shifts per calendar quarter to l four E-hour shifts per quarter appropriate. Further, the staff finds that if a 1

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licensed operator fails to meet the quarterly requirecent, before reinstatement and resumption of functions authorizeda 'y a license, the licensee must complete a minimum of two 8-heur shifts instead of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift wo'.k.

IV.

Accordingly, the Comission has determined that pursuant to 10 CFR 55.11, these exemptions are authorized by law, and will not endanger life or property and are otherwise in the public interest.

Accordingly, the Commission bereby grants exemption from the requirements of10CFR55.45(b)(1),10CFR55.45(b)(?),10CFR55.45(b)(4),10CFR 55.45(b)(5)and10CFR55.59(a)(?)totheextentthatthesesectionsrequirea sin >ulation facility to grant or maintain an operators license. The Conrnission also grants exemption from 10 CFR 55.53(e) and 55.53(f) to the extent that the hourly watchstanding requirements to n.aintain an operator's license is reduced to four 8-hour shifts per calendar quarter and the requirement to reinstate

the license if the quarterly requirement is not met is reduced to a minimum of

two 8-hour shifts.

Fursuant to 10 CFR 51.32, the Comission has determined that granting of this exemptien will have no significant impact on the environment (53 FR 37375).

This exemption is effective as of the date of issuance.

FOR THE NUCLEAR REGULATORY COPMISSION f&4v Aen a.a.>Direc Division of Reactor P je ts I/II Office of Nuclear Reactor Regulation Dated at Rockville, Maryland I

this 6th day of October 1988.

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