ML20035A011
| ML20035A011 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/16/1993 |
| From: | Walt T PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20035A010 | List: |
| References | |
| NUDOCS 9303230233 | |
| Download: ML20035A011 (7) | |
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i PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD j
AND PACIFIC POWER & LIGHT COMPANY
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Operating License NPF-1 Docket 50-344 License Change Application 231 i
This License Change Application (LCA) requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant. This LCA proposes to relocate those portions of the Trojan Technical Specifications that are related to the Trojan Fire Protection Program to Topical Report PGE-1012, Trojar Nuclear Plant Fire Protection Plan.
I, T. D. Walt, being duly sworn, subscribe to and say that I am the General Manager. Technical Functions for Portland General Electric Company, the 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.
Date W
I b, 1993 By T. D. Walt 1
General Manager Technical Functions On this day personally appeared before me T. D. Walt, to me known to be the individual who executed the foregoing instrument, and acknowledged i
that he signed the same as his free act.
GIVEN under my hand and seal this //cU' day of NM 1993.
4Uh 'M t CMMRW Notary Public in and for the State of Oregon i
Residing at My commission expires d cM-W.
9303230233 930316 PDR ADOCK 05000344 P
PDR j
l UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION In the Matter of
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PORTLAND GENERAL ELECTRIC COMPANY,
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Docket 50-344 THE CITY OF EUGENE, OREGON, AND
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Operating License NPF-1 PACIFIC POWER & LIGHT COMPANY
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4 (TROJAN NUCLEAR PLANT)
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i CEEIlflC4IE_Of_EfAVlCE I hereby certify that copies of License Change Application 231, to the Operating License fer Trojan Nuclear Plant, dated J//6/9 3
, have
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been served on the following by hand delivery er by deposit in the United States mail, first class, this /g& day of /2 a//1993:
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State of Oregon i
Department of Energy 625 Marion St NE Salem OR 97310 i
Mr. Michael J. Sykes Chairman of County Conunissioners Columbia County Courthouse a
St. Helens OR 97051
,H.' K. Chernoff, Manager Nuclear Licensing Department Technical Functions j
On this day personally appeared before me
, to me known to i
be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act.
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GIVEN under my hand and seal this /gth dayofAbidT1993.
[ lb'VM M '/ h4LadAcr f,. ly '
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Notary Public in and for the
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State of Oregon
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h:b. },.y My commission expires J-88-9[_
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LCA 231 Attachment I I
Page 1 of 5 l
License Change Application (LCA) 231 -
Relocation of Fire Protection Technical Specifications j
Backcround And Reason for Chance
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f Nuclear Regulatory Commission (NRC) Generic Letter 86-10, " Implementation of Fire Protection Requirements", (April 24, 1986) provides guidance as to acceptable methods of satisfying NRC requirements pertaining to fire protection. Section F of Generic Letter 86-10, Addition of Fire Protection Program into FSAR",
mentions several problems for licensees and NRC inspectors in identifying the operative and enforceable fire protection requirements at each licensed facility.
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The NRC has attributed these problems to variations in license conditions and to the many submittals which typically constitute the fire protection " programs" for
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each plant. A specific problem identified is the difficulty in making changes to the approved fire protection program without first requesting a license amendment. As the NRC staff stated:
t "If the fire protection program committed to by the licensee is required
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by a specific license condition or is not part of the FSAR for the l
facility, the provisions of 10 CFR 50.59 may not be applied to make changes without prior NRC approval. Thus, licensees may be required to t
submit amendment requests even for relatively minor changes to the fire protection program."
i The NRC has concluded that the best way to resolve this problem is to incorporate I
the fire protection program and major commitments, including the fire hazards I
analysis, by reference into the Final Safety Analysis Report (FSAR) for _ the
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facility.
In so doing, the plant features associated with the fire protection program would be on a consistent status with other plant features described in the FSAR.
In addition, the provisions of 10 CFR 50.59 would then apply for changes made in the fire protection program that would not involve an unreviewed safety question.
The NRC also concluded in Generic Letter 86-10 that a standard license condition, requiring licensees to comply with the provisions of the fire protection program as described in the FSAR, should be used to ensure uniform enforcement of fire protection requirements.
Ceneric Letter 88-12
" Removal of Fire Protection Requirements from Technical Specifications," August 2, 1988, provided further guidance for the preparation-of the license amendment to implement Generic Letter 86-10.
It is suggested in Generic Letter 88-12 that the amendment remove the fire protection requirements from Technical Specification (TS) in four major areas: fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements.
The recommended intent of this amendment should be as follows:
1)
Institute the standard license condition for a Fire Protection Program i
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f LCA 231 Attachment I
'Page 2 of 5 2)
Remove requirements for fire protection systems from TS 3)
Remove fire brigade staffing requirements from TS 4)
Add administrative controls to TS that are consistent with those for other programs implemented by license condition Descrintion of Ghance The proposed license amendment serves to implement, in accordance with Generic Letter 86-10 and 88-12, modifications to the existing Trojan Technical Specifications (TTS) and operating license. Specifically, the proposed changes relocate those portions of the TTS which are related to the fire protection program from TTS to PGE-1012. " Trojan Nuclear Plant Fire Protection Plan". Section 9.5.1 of the FSAR references PGE-1012 for the description of the fire protection program. The TTS sections to be relocated to PGE-1012 are l
identified as follows-TTS Section Subiect 3/4.3.3.7 Fire Protection Instrumentation Table 3.3-10 Fire Detection Instruments 3/4.7.8.1 Fire Suppression Water System 3/4.7.8.2 Spray, Sprinkler, and/or Deluge Systems 3/4.7.8.3 Fire Hose Stations j
Table 3.7-4 Fire Hose - StaM ons i
3/4.7.9 Penetration Fire Barriers l
B3/4.3.3.7 Fire Detection Instrumentation Bases B3/4.7.8 Fire Suppression Systems Bases B3/4.7.9 Penetration Fire Barriers Bases 6.2.2.f Facility Staff (Fire Brigade) 6.4.2 Training (Fire Brigade)
In addition, the amendment adds an administrative control requiring Plant Review Board review of changes to the Fire Protection Plan to TTS 6.5.1.6. in order to provide consistent administrative control of the fire protection program. Also, the special reporting requirements in TTS Section 6.9.2, applicable to fire protection, are deleted. The reporting requirements of Title 10, Code of Federal Regulations, Part 50 Sections 72 and 73 (10 CFR 50.72 and 50.73) will govern as required by Section E of NRC Generic Letter 86-10.
Furthermore, License Condition 2.c.(8) is revised to conform with the model license condition cited in NRC Generic Letter 86-10 with the consideration that the Plant is permanently shut down.
Attachments II and III provide a copy of the TTS and Trojan Operating License, respectively, with the changes annotated.
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LCA 231 Attachment I
~Page 3 of 5 No Sienificant Hazards Consideration Determination In accordance with the requirements of 10 CFR 50.92 this license amendment request involves no significant hazards consideration based on the following:
i The proposed license amendment does not involve a significant increase in the probability or the consequences of an accident previously evaluated.
This amendment merely relocates the fire protection program elements from the TTS to PGE-1012. No change is being made to the content of the TTS being relocated.
Operating limitations will continue to be imposed, and required surveillances will continue to be performed in accordance with written procedures and instructions auditable by the NRC.
Although proposed future changes to the fire protection program elements l
previously located in the TTS will no longer be controlled by 10 CFR 50.90, proposed changes to the TS requirements relocated to PGE-1012 will be evaluated by a safety evaluation in accordance with the requirements of 10 CFR 50.59 to determine whether an unreviewed safety question exists.
Changes that do represent an unreviewed safety l
question will receive prior NRC approval before implementation.
Thus, programmatic controls will continue to assure that this change will not have the effect of permitting future proposed fire protection program changes to. create an unreviewed safety question.
It is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed license amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
PGE-1012, incorporated by reference in Trojan FSAR Section 9.5.1, -
contains the Trojan fire hazards analysis.
This amendment merely relocates the fire protection TS requirements from the TTS to PGE-1012.
No change to the fire protection TS requirements is being made and thus the change does not create the possibility of a new or different accident from those previously evaluated.
As noted above, proposed changes to the TS requirements relocated to PGE-1012 will be evaluated by a safety evaluation in accordance with the requirements of 10 CFR 50.59 to determine whether an unreviewed safety question exists.
Changes that do represent an unreviewed safety question will receive prior NRC approval before implementation.
LCA 231 Attachment I Page 4 of 5 l
The proposed license amendment does not involve a significant reduction in the margin of safety.
l This change does not involve a reduction to the approved fire protection program or TS fire protection requirements. The TS fire protection.
i requirements are being relocated, without alteration, to PGE-1012.
Since there is no change to the requirements, there is no reduction in the margin of safety.
As noted above, proposed changes to the TS requirements relocated to PGE-1012 will be evaluated by a safety evaluation in accordance with the requirements of 10 CFR 50.59 to determine whether an unreviewed safety question exists. Changes that do represent an unreviewed safety question will receive prior NRC approval before implementation.
i Environmental Impact Determination This amendment request meets the criteria specified in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements to perform an environmental review.
The specific criteria contained in that section are discussed below.
(i)
The amendment involves no significant hazards consideration.
As demonstrated above, the proposed amendment does not involve a significant hazards consideration.
(ii)
There is no significant change in the types or_significant increase in the amounts of any effluent that may be-released offsite.
The requested license amendment proposes to relocate the fire protection elements of the TTS to the FSAR, and documents referenced therein, and does not involve changes to any plant system or component. The proposed change does not authorize additional plant' activities beyond those that may already be conducted and thus has no impact on the types or amounts of any effluent that may be released offsite.
(iii)
There is no significant increase in individual or cumulative occupational radiation exposure.
The requested license amendment does not authorize additional or different plant activities beyond those
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presently authorized and thus does not affect radiation exposures to personnel or radiation levels present in the
- plant, j
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r LCA 231 Attachment I Page 5 of 5 On the basis of the preceding discussion, it is concluded that the requested license amendment is acceptable and meets the' eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), and thus no environmental impact st.tement or environmental assessment need be prepared in connection with the issuance of this amendment.
Schedule Consideration It is requested that the license amendment be issued prior to June 15, 1993 and that the effective date of this amendment be 30 days after the date of issuance by the NRC.
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